ML19339C527
| ML19339C527 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/11/1980 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8011180549 | |
| Download: ML19339C527 (3) | |
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g SOUTH CAROLINA ELECTRIC a gas COMPANY j
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November 11, 1980,.--
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4 UNITED STATES NUCLEAR REGUI.ATORY COM'!ISSION Region II 101 Marietta Street, N.W.
Atlanta, CA 30303 ATTENTION:
Mr. James P. O'Reilly, Director g
Subject:
V. C. Summer Nuclear Station Unit #1', Docket No. 50/395 License CPRP-94, Reportable Item in Accordance with 10CFR50.55(e),
Ouestionable Material Acceptability of Pipe Hanger Components Gentlemen:
On October 10, 1980, Region II (J. Rausch) was notified of a reportable item relative to the questienable material acceptability of pipe hanger components.
Specifically, standard component parts (ie, pipe clamps, pins, ene brackets, transition tubes, paddle plate straps, U-bolts, etc.) were purchased from our pipe hanger vendor (Bergen-Patterson) as spare pr.rts and possibly interchanged with similar parts on safety related hangers. The safety related' hanger instal-lation system confirmed material acceptability while at the supplier and anticipated the installation of a complete hanger " mark" number assembly in the field without need to confirm material acceptability of individual component parts.
Investigation has shown that it is possible that hanger assemblies have not always remained intact. The possible interchanging of component parts would be acceptable if all pipe hanger parts had been purchased as safety related.
However, non-safety related hanger parts had also been purchased and used in non-safety related systems. This condition raised a question as to whether or not non-safety related hanger parts were used in safety related hangets. SCE&G Nonconformance Notice (NCN) 1154H was initiated to identify the subject con:ern and was dispositioned to require a reinspection of safety related hanger parts.
Tn d.4pm irioning NCN 1154H, the Engineer made a list of all Bergen-Patterson parts in the safety related and non-safety related catalogues. From 6.J laht-mation, a single list of parts in both catalogues was compiled. Next, all non-safety related purchase orders for hanger parts were reviewed and the items listed that would be duplicated on the previous Bergen-Patterson list. From this information, three groupings of parts were determined to be relevant to the rein-spection of the hangers:
1.
Parts that are only safety related.
2.
Parts from Bergen-Patterson that are safety related if marked with a lot code.
3.
Parts from a variety of sources, that are safety related, if marked with a lot code to Bergen-Patterson standards.
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'4 USNRC Page 11/11/80 Concerning the traceability of structural steel in hanger assemblies, both the safety related and the non-safety related structural steel specification state that unless otherwise noted on the drawings, all steel shall conform to Spec. ASTM A36-70a. This is identical to ASME SA-36 material per the requirement of ASME Section III. Therefore, all structural steel on site has a minimum requirement of ASTM A-36 which is acceptable for use in pipe sup-ports. Using the information herein, the SCE&G-reinspection of pipe hanger parts was initiated. Consequently, a number of components lacking adecuate identification were found and are presumed to be non-safety related. All pipe hangers with the applicable parts given in the NCE 1154H disposition will be reinspected and the rejected parts changed out using traceable i
material.
Cause The cause of the condition is the failure to properly control non-safety related pipe hanger parts. In addition, the cause is attributed to the lailure to install and verify the Bill of Material item with respect to traceability on the part of the Code craft and OC organization. This relates to the breakdown in the ASME inspection program previously re-ported, the reasons resulting from any of a combination of facters, including inadequate procedural coverage, training, competency, attitudes and supervision inadequacies. The lack of controls and failures to perform occurred commensurate with other facets of the Code QC Breakdown. Once discovered, a systematic means to identify parts involved and extent of problems wasl implemented concurrent to work in process with full know-ledge that an independent reinspection by SCESG/QC personnel would be involved.
Safety Implications To determine the exact safety implication, Engineering would need to evaluate each specific condition and the combination of conditions by hanger as they relate to their effect on a specific hanger and subsequently on a system.
The extent of this effort is indeterminate since the extent and specifics of the conditions are unknown prior to reinspection. Since it is apparent that defective conditions exist in that some material cannot be confirmed as adequate, it 10 net po==ible to rula anr the potential of some specific defect existing and having safety implication. For this reason, the condi-tions are conservatively being classified as a potential significant deficiency which will be corrected to remove any doubt as to product acceptability.
Actions to Correct Conditions SCE&G is in the process of implementing a controlled program to identify all safety related hangers which have been fabricated from the applicable parts listed in NCN 1154H, reinspect them and have all deficient unidentified parts replaced with acceptable parts. SCE&G/QC is performing the subject reinspection.
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Page'3 11/11/80 Corrective Action to Prevent Recurrence The applicable procedures have been. revised to reflect the criteria given in the disposition of NCN 1154H. Applicable training to these procedures has been performed.
All non-safety related parts have been removed from the field and placed in a controlled storage area so as not to become intermingled with safety related parts. SCE&G/QC had direct control over the pipe hanger reinspection and new hanger inspection activities and is exercising strict controls over the traceability of parts.
SCE&G believes the action outlined above will adequately-resolve the traceability concern with pipe hanger parts. Since a definite course of action is determined, this is considered a final report on.this subject.
Action taken will be avail-able at the construction site for NkC review. ' Also, ~ NCI 1154H will remain open sud che work snd inspectiva saLjecu su 5 Cia 6/ya surveillance. Since it is apparent that implementation or these actions will take some time, we will modify this final report only if any facet of the pipe hanger program changes to differ from that described herein. Sheuld further information be required, please con-tact us.
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Very truly yours, T. C Nichoir Jr TCN:jfr cc:
B. A. Bursey V. C. Summer G. H. Fischer W. A. Williams f
E. H. Crews D. A. Nauman 1
- 0. S. Bradham O. W. Dixon J. B. Knotts
'Ron Clary I&E (Washington) i Document Management Branch (55e/21/LER only)'
NPCF/Whitaker J. L. Skolds File 1
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