ML20114B660

Interim Potential Deficiency Rept 55-84-11 Re Uncertified Flanges Installed in ASME Sys & Stainless Steel thread-o-lets Mfg from Unqualified Stock Matl.Initially Reported on 840525

ML20114B660
Person / Time
Site:	Clinton
Issue date:	01/18/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-11, U-10241, NUDOCS 8501290405
Download: ML20114B660 (4)

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.s 1A.120 ILLINDIS POWER 00MPANY U- 10241 CLINTON POWER STATION. P.O. BOX 678. CLINTON, ILLINOIS 61727 January 18, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Potential 10CFR50.55(e) Deficiency 55-84-11:

Uncertified Flanges Installed in ASME Systems; Stainless Steel Thread-0-Lets Manufactured from Unqualified Stock Material

Dear Mr. Keppler:

On May 25, 1984, Illinois Power Company notified Mr. F.

Jablonski, NRC Region III, (Ref: IP memorandum Y-21457 dated May

'25, 1984) of a potentially reportable deficiency concerning uncertified flanges installed in ASME systems and stainless steel thread-o-lets manufactured from unqualified stock material. This initial notification was followed by two (2) interim reports (Ref. IF letter U-10172, D. P. Hall to J. G. Keppler, dated July 3, 1984; and IP Letter U-10205, D. P. Hall to J. G. Keppler, dated October 18, 1984). Our investigation of this issue is progressing, and this letter is submitted as an interim report in

-accordance with the requirements of 10CFR50.55(e). Attachment A provides the details of our investigation to date.

We trust that this interim report provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve the issue.

Sincerely yours, D. . Hall Vice-President RLC/ lag (NRC2) 85o129oy 50 fgn % g PDR AD PDR Attachment 8 cc: NRC Resident Office 20 Director, Office of I&E, US NRC, Washington, Illinois Department of Nuclear Safety DC JAd5543 G8rJ INPO Records Center A

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' ATTACHMENT A Illinois Power Company Clinton. Power. Station

' Docket.No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-11 1 -Uncertified Flanges" Installed in ASME Systems:

~ Stainless Steel Thread-0-Lets Manufactured from Unqualified Stock Material Interim Report

-Statement of Potentially Reportable Deficiency / Background

[ During a review of purchase order files by Baldwin Associ-

<ates-Quality Assurance group, it' was-identified that approximate-E

ly'1,035 small bore flanges were purchased without proper docu-L' ' mentation? certifying that the material met the requirements of

_ ASME ~ III, : NA-3700/NCA-3800.

JAn. internal review of Quality Assurance records by Gulf &

- Western (G&W)/ Bonney: Forge, a supplieritc Hub, Inc., revealed

. that various: stainless: steel thread-o-lets were manufactured .from

[ stock ~ material which was neither ,urchased under the provisions of ASME NCA-3800 nor did the stoc'c material' receive ~.the product-

[ ,

{ -analysis for upgrading per ASME requirements.

Investigation Results/ Corrective Action

- ' Illinois Power has prepared 1and is im)lementing an inves-itigation plan toLdetermine the extent of this' problem at Clinton-Power: Station (CPS).

The investigation plan includes:

1. - Review of Architect / Engineer material andidesign require :

p tments found in design' documents and specifications, b '

2. Review of Construction. Quality Control procedures ands inspection basis, s' 3i Review of: material _ procurement and receiving _ inspection methods,-

14L cReview of-the: record. review programs to determineLeapability~-

p to: identify ~ certification deficiencies,.and Review.of. deficiency document's (Nonconformance Reports-

~

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5.

(NCRs),' audit findings, etc.)_which11dentify certification

. discrepancies.

Page:1 of 3 Y

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= ATTACHMENT A (continued)

The uncertified flanges were purchased from Barr Saunders-Inc. under-P.O. No. C-14951 and received under Receipt Inspection Reports-(RIRs)'No. S-5111 and~S-5635. The total quantity of flanges. received was 1035 in sizes. ranging from 1/2" to 2" Linclusive, in ratings of 300f and 600f. Nonconformance Report (NCR)LNo.;70178 states that the Certified Material Test Reports (CMTRs) for these items'do not indicate compliance with ASME NA-3700/NCA-3800. There was also no objective evidence that National Flange and Fitting Co. (the-suaplier to Barr Saunders) was an'ASME Quality System Certificate holder or that-they were audited.by'either Barr Saunders or Baldwin Associates-(BA).

In order to identify those systems in which the uncertified flanges may_have been installed. BA-Resident Engineering (BARE)

. performed a review of all safety-related isometric drawings.

BARE thenl identified--the corresponding travelers containing pipe

-sizes between-1/2" and 2" inclusive and identified 76. flanges,

.-(with RIR No. S-5111) all of which were installed. The single item _ received under RIR No. S-5635 was returned to the warehouse .

and placed on' hold.

BAQA Document Review Group (DRG) which has;the.responsibil-ity of~ conducting a final review of all vendor - supplied and taite-generated records, including Fire Protection and Augmented .

Class.D, also identified one (1) additional safety-related installation (Ref: NCR No. 70363).

-The following is'a status (as determined by the-above review):of the'1035 flanges received under_RIRs No. S-5111 and S-5635:

-Number!of flanges' issued to construction 253 Numberiinstalled in~ safety-related-

systems- 77 Number not installed in safety-176-

, related systems Total issued 253 Number of flanges:on warehouse

hold 782

, - . Total flanges received 1035 Page 2 of 3

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ATTACHMENT A (Continued) 4

.Nonconformance= reports or traveler addendums were generated

which, replaced, with certified material, the 77 uncertified e  ;flangescinstalle:o in safety-related systems. All of the replaced

-flanges as-well as those on hold have been scrapped (Ref: NCR 24613).

I'

-The stainless _ steel thread-o-lets manufactured from.unqual-

ified stock material were purchased from Hub Inc. under P.O. No.

L -C-26876 <nd received under RIR No. S-12101. NCR No. 16881 identified these items as'being manufactured from material that was-not procured to the requirements of ASME NA-3700/NCA-3800.

Of the-12 items received, 10 are currently on hold and are to be downgraded for use on Non-ASME' systems, and the remaining 2 which were installed under travelers F-WF-776-A and-WZ-810 are accept-f able based.upon jurisdictional boundaries of the Code such that

-NA-3700/NCA-3800 is not applicable (Ref: Nonconforming Material =

Report (NCMR)'l-0258 and 1-0259, respectively).

Corrective action taken to date includes the issuing of-

- ' Corrective-Action-Request (CAR) ik). 147 to document and obtain resolution-regarding the requirements of ASME Section III, Subsection NA-3700/NCA-3800. Training' programs were conducted

-for personnel involved in activities associated with ASME Materials (procurement requisitions.and purchase orders,-vendor qualifications, document ~ review, etc.)

. . . ,Ourfinvestigation is currently' involved _in evaluating additional ~ deficiencies.similar to'those associated'with this Jissue. These' deficiencies involve various piping fittings installed in ASME systems for which there is no objective .

evidence that'the fittings were manufactured or material 1 procured under a program meeting the requirements of ASME (NA-3700/NCA-3800).

Safety Implications / Significance Illinois Power Company's investigation.of-this potentially reportable deficiency is-continuing for'those additionali

~. deficiencies discussed above. 'The safety-implications and

. significance:of-these deficiencies will be assessed'after further Lbackgroundfinformation'is evaluated.. S&L has performed'a safety significance evaluation of the NCRs involving the rubject-flanges and has concluded that if the identified deficiencies had-

.goneruncorrect'ed they would not have adversely affected the-safety ofJoperations of CPS. (Ref:-S&L Letter SLMI-13835).- It is

' anticipated approximately'45: days will be necessary;to complete

ourninvestigation,-determine reportability.and file a final

. report'on

' ~

the matter.

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