ML20107B349
| ML20107B349 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/14/1985 |
| From: | Grunthaler G GUYON ALLOYS, INC. |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| REF-PT21-85 NUDOCS 8502200354 | |
| Download: ML20107B349 (6) | |
Text
NYUli ALLOR 50, #"
Iih ]ll 55 TUBULAR PRODUCTS FOR THE ENERGY INDUSTRIES 5
950 South Fourth Street, Harrison, N.J. 07029 (201) 4855050 February 14, 1985 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attn: Mr. Edward L.
Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc: Mr. Gary G.
Zech, Chief /Mr.
E.T.
Baker Vendor Program Branch Division of Quality Assurance Safeguards, and Inspection Pro ~ grams
Subject:
Possible 10CFR Part 21 Notification 3/4" NPS S/40 SA-312 TP304 Stainless Steel Pipe of Sandvik, Inc. manufacture furnished to Commonwealth Edison Co.-Braidwcod Station Attached please find copies of a letter dated January 24, 1985 received from the Commonwealth Edison Co. and a Guyon Alloys reply thereto which in combination describe inside surface imperfections or deviations found in the subject stainless steel pipe by Commonwealth Edison.
Based on your March 1984 request for copies of notifications made in conjunction with Bonney Forge Material Lacking Chemical Overcheck, and in view of the criticism or questions regarding our 10CFR Part 21 procedures contained in your November 14, 1984 letter /
report of the NRC inspection of our Houston, Texas facility, it is requested that guidance be provided by your respective Divisions or Branches as to what 10CFR Part 21 notifications must be made by Guyon Alloys with regard to the circumstances outlined in the attached letters.
Please note that the referenced pipe was procured by Commonwealth Edison and in turn by Guyon Alloys prior to 10CFR Part 21 being published as an effective rule but shipment thereof was effected in December 1977.
We have reviewed our records and have identified 19 additional purchases of the same size, wall thickness, and grade of pipe from Sandvik, Inc. during the years 1976 thru 1978.
In turn, the recipients of 70 shipments of this additional pipe which was procured for nuclear or possibly safety-related use.
Whether or not the reported deficiencies are heat identity related, none of the additional pipe was of the same heat identities as furnished to the Commonwealth Edison Braidwood Station.
8502200354 050214 gDR pt$
ADOCK 05000 6
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CU,Y@,N. ALLGYO, INC.
February 14, 1985
. United States Nuclear Regulatory Commission Washington, D.C.
20555 Attn: Mr. Edward L.
Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Page #2 If the reported deficiencies are determined to create a substantial safety hazard and not to be related to size, wall thickness, grade..and/or heat identity of pipe, an indeterminable
. amount of time would be required to identify recipients of hundreds if-not thousands of shipments of all grades and sizes of pipe of Sandvik manufacture which has been furnished by Guyon Alloys for use at nuclear power plants.
An early response will be appreciated.
Very truly yours, GUYON ALLO
'S, INC.
I Ng
- &&W ~
George H.
Grunthaler Vice President Technical Services GHG:ldb Encl.
6
Commonwealth Edison Co, Braidwood St: tion RR 1, Box 81 Braceville, IL 60407 Telephone 815/458-2801 d
~
w January 24, 1985 Guyon Alloys, Incorporated h40 E. Swedesford Road Wayne, PA 19087 Attention: Mr. Jack Gardner Sub, ject:
Braidwood Station - Units 1 & 2 Commonwealth Edison Company Purchase Order
Dear Mr. Gardner,
Mandrel extrusion gouges affecting five linear inches of the above referenced pipe have been discovered. The abnormalities cover approximately one-fourth of the I.D. surface, and have resulted in a vorst case minimum vall thickness of 0.086" - 0.027" below nominal vall thickness. This material was purchased under the ultrasonic testing exemption defined in the 197h Edition, Summer 1975 Addenda of ASME Section III, Subsection NB, paragraph 2510. Use your discretion in determining the propriety of filing a 10CFR Part 21 notification.
Please direct your questions to me on (815) h58-2801 extension 2362.
Sincerely, R. J. Kelm Mechanical Field Engineer Braidwood Station RJK/ms cc:
T. Quaka, QA T. O'Connor, PGCo 85-31E
,o MYONAEUYS,IE g
TUBULAR PRODUCTS FOR THE ENERGY INDUSTRIES 950 South Fourth Street, Harrison, N.J. 07029
~
T (201) 485-5050 Commonwealth Edison Co.
February 14, 1985 Braidwood Station RR1, Box 81 Braceville, Illinois 60407 Attn: Mr.
R.J.
Kelm Mechanical Field Engineer Braidwood Station
Subject:
Braidwood Station - Unit 1& 2 Commonwealth Edison Company Purchase Order
- 207003, Dated 12/8/76 3/4", Sch/40, SA 312 TP 304, ASME Sec. III Cls 1 Pipe. Heat #783243 Receipt of your letter dated January 24, 1985 bearing the above reference is herewith acknowledged.
A review of our records indicates that 11371'-2" of 3/4" S/40 cmis. SA-312 Grade TP304 stainless steel pipe was furnished by Guyon Alloys for Item #15 of your order #207003 and that this pipe was shipped to your Braidwood Station on December 22, 1977 as part of a six truck load shipment. All of the 3/4" S/40 TP304 pipe was oanufactured by Sandvik Inc.under their ASME Quality System Certificate N-1400 and consisted of 6220'-1" of heat #783243, 3569'-0" of heat
- 745207, and 1582'-1" of heat #M0021.
The following confirms our telephone discussion of February 5, 1985 with regard to your letter and our understanding of the information provided by you during the discussion.
Per your advice, based on visual examination of pipe nipples cut from 3/4" S/40 TP304 pipe of heat #783243, in or about June 1983 one 3" long pipe nipple was found to contain an inside surface imperfection as described in your letter.
At that time approx. 2100 feet of the 3/4" S/40 TP304 pipe of heat #783243 (or all three heats?)
was unused and in your site storage area.
Resultant of subsequent visual examination of the bore and inside surface of all pipe lengths comprising the approx.2100 feet of pipe, one additional inside surface imperfection was discovered near the center of one pipe length.
Upon cutting the area containing the imperfection from the center of this length, it was determined that the imperfection was approx. 2" in length and extended approx.one fourth of the inside pipe circumference in width.
Therefore the five lirear inches of pipe described in your letter consists of the 2" long piece of pipe and the 3" long pipe nipple.
cc: Mr. Bert Herbert, Mgr. Q.A.
Sandvik. Inc., Scranton, Pa.
LCUYCpis ALLGYS,,INC.
E l
Commonwealth Edison Co.
February 14, 1985 Braidwood Station RR1, Box 81 Braceville, Illinois 60407 Attn: Mr. R.J.
Kelm Page #2 The worst case minimum wall thickness of 0.086" - 0.027"
~below nominal wall thickness (which is 0.013" below the 0.099" minimum wall thickness permitted by the SA-312/SA-530 material specification) cited in your letter you advised was determined by. micrometer measurement of wall thickness at point of greatest dopth of imperfection'after the 3" long nipple and 2" long piece of pipe had been longitudinally cut in halves.
The " mandrel extrusion gouges" description of imperfections contained in your letter is based on terminology provided by the
-Sandvik. Inc. Manager of Quality Assurance, Mr Bert Herbert, during
-a telephone discussion or discussions held by.you. directly with Sandvik sometime after the discovery of_the imperfections and prior to the date of your letter.or advice to Guyon Alloys.
During-your
-discussion (s) with Sandvik it was indicated that Sandvik had had Eat least one previous experience with the mandrel extrusion gouges problem.
You were advised during our telephone discussion that the 13/4" S/40 pipe furnished by Guyon Alloys was manufactured-by the cold drawn process at Sandvik's Scranton, Penna. manufacturing plant.
- mai4Therefore7-if mandrel extrusion gouges were the cause of-the inside ourface imperfections, such gouges would have originated in the Lextruded tube (pipe) rounds from which the final size pipe was cold drawn.
Being mechanical in nature, mandrel extrusion gouges would s
not necessarily relate to a specific heat identity, grade, or size and wall. thickness of pipe.
-You advised that although all of the 3/4" S/40 TP304 pipe had boen. procured for ASME'Section III Class I use based on the exemption from non-destructive examination per Paragraph NB-2510/NB-3673, none
-ofIthe 3/4" S/.40 TP304 pipe has been installed in Class 1 piping cystems.
Based on stress calculations performed, the majority of approx. 1100 feet' of the 3/4" S/40 pipe (of heat #783243 or all three heats?) installed in ASME Section III Class.2 or Class 3 systems has been
.dotermined to be satisfactory for intended services.
For three limited Ocope Class 2-or 3 systems, provisions are being made to addy current examine installed 3/4" S/40 TP304 pipe to assure its freedom from icperfections of the type under discussion.
Whether any of the balance of the pipe furnished has been used or installed in systems which may bo considered safety related was not discussed.
CUYGN* ALLGYC, INC.
Commonwealth Edison Co.
February 14, 1985 Braidwood Station RR1, Box 81 Braceville. Illinois 60407 Atta: Mr.
R.J.
Kelm Page #3 Formal notification of the discussed imperfections having boon found is.being provided to Sandvik, Inc. with copies of your letter and this reply thereto.
Sandvik is being requested to evaluate the information provided thereby and to furnish a written otatement of cause and steps taken or to be taken to correct the i
problem and preclude recurrence.
With regard to your letter advice to use our discretion in
-dotermining the propriety of filing a 10CFR Part 21 notification, in as much as Guyon Alloys and in.most cases a material manufacturer doas not have the capability of evaluating whether a deviation and cpoci.fically the discussed imperfections may create a substantial cafety hazard, under the provisions of 10CFR21 it is Guyon Alloys
. practice to notify and provide all available information to the purchaser to facilitate an evaluation by the purchaser, the licensee, or the licensee's designee.
In this case however, we are sending copies of your letter cud this reply to the Division of Emergency Preparedness and Engineering Response -Office of Inspection and Enforcement and to the Vendor Program Branch Division of Quality Assurance. Safeguards, and Inspection Programs at the Washington, D.C.
offices of the Nuclear Regulatory Commission with a request for their advice and guidance as to whether 10CFR Part 21. notifications are required and, if so, the extent thereof.
Very truly yours, l
l GUY DN ALLOY INC.
45l George H.
Grunthaler Vice President Technical Services GHG:ldb l
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