ML19332B278
| ML19332B278 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/13/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19332B277 | List: |
| References | |
| 50-329-80-13, 50-330-80-14, NUDOCS 8009260413 | |
| Download: ML19332B278 (3) | |
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Appendix A NOTICE OF VIOLATION Consumers Power Company Docket No. 50-329 Docket No. 50-330 This refers to the investigation conducted by representatives of the Region III office at the Midland site on February 27-29, 1980; with subsequent visits March 5-6 at Southern Bolt Company; March 11-12 at J. W. Rex Company; Harch 18-19 at Bechtel; March 20 at Mississippi Valiey Structural Steel, April 18 at Bechtel, discussed during the May 2, 1980 meeting at the Region III Offices.
It appears that certain of your activities were in noncompliance with NRC requirements as noted below. Each item is an infraction.
1.
10 CFR 50, Appendix B, Criterion IV, requires, in part, that
" Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements, which are neces-sary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment,
. whether purchased by the applicant or by its contractors and subcontractors."
Governing procurement specification No. 7220-C-233(Q), Revision 3, states that reactor vessel anchor bolts and nuts will be utilized as ASME (American Society of Mechanical Engineers),Section III, Divi-sion 1, Class I component supports.
Complete requirements for Section III, Class I component supports were incorporated in the Winter 1973 amendment to Section III, and were identified as Component Supports, Subsection NF.
The purchase order for reactor vessel anchor bolts was dated September 16, 1974, making the applicable ASME Code Edition Winter j
of 1973 or Summer, 1974.
Contrary to the above requirement, Subsection NF was not made the requirement for reactor vessel anchor bolts with the following re-
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sults:
i a.
ASTM A354 Grade BD was specified as the stud material, which was not an ASME code allowable material.
b.
While fracture toughness tests were made, no attention was given to the brittle fracture indicated by lateral deforma-tion tests.
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Appendix A,
c.
There was no involvement of the Authorized Nuclear Inspector in this order of studs.
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2.
10 CFR 50, Appendix B, Criterion VII, states that
. " Measures shall be established to assure that purchased material, equipment, and ser-vices, whether purchased directly or through contr.ctors and subcon-tractors, conform to the procurement documents."
The governing procurement specification 7220-C-233(Q), " Technical Speci-fications for Purchase of Miscellaneous Metal for Consumers Power Company,"
in Section 5.10.4c which covers sampling frequency, states that the Charpy V-notch test shall be required for the bolts and nuts as follows: One sample shall be made for each lot of material where a lot is defined as one heat of material heat treated in one charge or as one continuous operation not to exceed 3,000 lbs. by weight.
Contrary to the above, measures were not established to assure pur-chased material conformed to the procurement document in that this order, while made up cf three different steel analyses, (one of which exceeded 3,000 lbs.) and nine or ten austenitizing tots, was delivered with only three Charpy tests having been performed.
3.
10 CFR 50, Appendix B, Criterion IX, requires, in part, that Heasures shall be established to assure that... heat treating, and nonde-structive testing, are controlled and accomplished by qualified person-nel using qualified procedures in accordance with codes, specifications, criteria, and other special requirements."
Contrary to the above, measures did not assure that heat treating and nondestructive tests were controlled in accordance with applicable codes and specifications. Examples are:
a.
The Southern Bolt Quality Assurance manual in Paragraph 2M, Section 10.0, requires that purchase orders state "where the heat treater is to Brinell (hardness test) pieces."
Contrary to this requirement, no location (e.g. surface of bolt) for this test was specified in the heat treatment purchase order.
b.
ASTM Code requirements (A-354, A-370) provide for hardness testing of bolting materials. These requirements call for surface hardness tests, with subsurface tests being allowed under specific and limited conditions.
Appendix A ~
Contrary to these requirements, greater than specified hard-ness results on the surface of the studs led to performing hardness tests at the mid-radius, on the end of tensile test specimens.
Conditions to allow such testing under ASTM Codes were not present, and such tests defeat the purpose of the hardness test as a nondestructive test.
c.
The heat treat procedure utilized for treating the reactor studs, J. W. Rex #1, Section 2, states that a " furnace load shall consist of approximately 10 pieces plus test bars."
Contrary to the above, furnace temperature charts submitted for documentation (dated April, 1975) indicate that tempering furnace loads exceeded 10 pieces (38-39 studs were tempered per furnace load).
(It is also noted that, in one case, two test pieces did not accompany production bars during heat treatment. Therefore, the test results for this test piece may not represent those for the production pieces),
d.
Purchase Order #24844, from Mississippi Valley Structural Steel to Southern Bolt and Fastener Corp., in section 5, indicated that " total material traceability is required."
J. W. Rex Heat Treat Procedure, J. W. Rex #1, Rev. 4, in sec-tion 2, required testing and documentation to be on the basis of material heats.
Contrar, sa the above, material traceability was not maintained in that J. W. Rex was not notified that the studs to be heat treated consisted of two types of steel and four material heats until initial heat treating had been accomplished.
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