ML20154B725
| ML20154B725 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/08/1988 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| HVS-43, IEB-88-005, IEB-88-5, NUDOCS 8809140098 | |
| Download: ML20154B725 (10) | |
Text
_ - _ - - _ _ _.
Georgia hver Company 333 Piedmont Avenue Attanta, Geoga 30308 Tetephore 404 5266526 MaAr,g Address Past OEce Box 4545 Atlarta. Georgia 30302 ser y es nt u w c u ratons HVS-43 2114C X7GJ17-H110 September 8, 1988 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Hashington, D.C.
20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO 8ULLETIN 88-05 NONCONFORMING MATERIAL Gentlemen:
The subject NRC Bulletin (HRCB) 88-05, dated May 6, 1988, "Nonconforming Material Supplied by Piping Supplies, Inc. at Folsom, New Jersey and West Jersey Manufacturing Company at Hilliamstown, New Jersey" requested that Georgia Power Company (GPC) submit information regarding materials from Piping Supplies, Inc. (PSI) and Hest Jersey Manufacturing Company (HJH) that provide assurance that materials comply with the American Society of Mechanical Engineers' (ASME) Boiler and Pressure Vessel Code Section III, /.merican Society of Testing and Haterials (ASTM), and applicable procurement specification requirements, or that demonstrate that such materials are suitable for their intended service.
It further stated that the licensee should document and maintain for l
inspection a basis for continued plant operatirn if the program stated above had not been completed within 120 days of the date of receipt of the subject NRCB.
The Bulletin was received by GPC on May 11, 1988 and GPC began an extensive program including a document search of existing procurement record; to identify material from PSI or HJM.
This letter is l
to report the results of our investigation into the subject NRCB.
The issuance of Supplement I to the NRCB, June 15, 1988, narrowed the scope of review from ASME and ASTM certified materials to fittings and flanges.
It also instructed the affected licensees to commence appropriate testing of accessible flanges and. fittings promptly to identi fy conformance of materials to ASME and ASTM materials specifications on an accelerated schedule.
The NRC issued Supplement 2 to the NRCB on August 3, 1988.
The second supplement added an additional company, Chews Landing Metal Manufacturers, Inc. (CLM), to the search and modified the testing and reporting requirements.
As a
result of Supplement 2, we have suspended furthi-testing of material from CLM, PSI or HJM.
I G809140098 800900 il PDR ADOCK OS000321 II G
PNU 1
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1 Georgia Power d U. S. Nuclear Regulatory Commission September 8, 1988 Page Two During construction, Plant Hatch fellowed ASHE Section III Code requirements for material procurement and installation of piping systems.
Contractors involwd with the fabrication, installation and supply of ASHE Coda materials /equ:pment were properly certified by ASHE, or, in the case of some suppliers and manufacturers, either ASHE or the Certificate Holders.
ASME Section III requires that pressure retaining material be supplied to an N-type Certificate Holder by an organization qualified in accordance with specific ASHE rules.
Although CLH materials have not been used at Plant Hatch, the PSI and HJM materials used were supplied to N-type Certificate Holders, such as Bechtel.
The PSI material at Plant Hatch all tested within specifications.
HJH has been surveyed, audited and qualified by ASME or Bechtel (and other N-type Certificate Holders) in compliance with the ASME Code rules.
After Plant Hatch was ASME Code stamped, repair and replacement activities has been performed under ASME Section XI Code requirements. Work has been performed and material certified in compliance with ASHE code requirements.
NRCB 88-05 raised an important question regarding possibly fraudulently documented materials furnished by HJH.
Subsequently, blind flanges found at some nuclear plants did not appear to meet ASHE Code requirements.
This does not, however, demonstrate that all materials supplied to the nuclear industry by HJM failed to meet ASME Code requirements.
It has been recognized in the pressure vessel and piping industry for many years that the certified physical test results of a material lot tested at a steel mill may vary from tensile tests performed on that lot's formed product.
There are a number of reasons for these variations.
Tests on products often must be taken on a specimen with different orientation, depth or size than the original.
Substze tensile test specimens may yield more conservative (lower) results than full-size specimens.
Other reasons for variations are: the fact that steel is not homogenous, different amounts of work on the material goes into the manufacturing of various product forms, and cooling rates may vary.
The American Iron and Steel Institute (AISI) performed an elaborate study of plates and shapes to determine what tensile test variances could be expected between the results of mill tests and product test for carbon steel.
This study was issued in September, 1974 and showed that material with test coupons acceptable at the mill, when tested as products, can have tensile test results as much as 14,000 psi Iower or higher than the results reported on the CMTR (10-207. variance).
Variances were found to be greater for shapes than for plate products.
The results of tests on structural shapes would be expected to be closer to the results for flanges and fittings because of configuration, product method and amount of working.
The results of the AISI Study on variances in carbon steel strength were reported to the ASME Code Cournittee with the suggestion that allowable stresses be reduced for ASME Code materials.
The ASME Code Committee considered the AISI Study and determined that no changes in allowable stresses were necessary.
- However, the Code Committee did acknowledge that variances, as reported by AISI, were a known phenomena, 2114C
Georgia Power A U. S. Nuclear Regulatory Commission September 8, 1988 Page Three After publication of NRCB 88-05, NUMARC/EPRI iniciated an independent testing program to: (1) determine through destructive testing the tensile strength and other physical properties of approximately 250 pieces of warehoused carbon steel materials supplied by PSI or HJH to various i
utilities (2) develop a correlation between Equotip hardness test results and tensile strength values for carbon steel, and (3) perform magnetic testing, alloy analysis and physical testing on a sampling of the small percentage of stainless steel materials furnished by PSI and HJM.
Results I
obtained from the independent laboratory destructive testing revealed a bell-shaped tensile strength distribution curve very similar to the results obtained in the earlier AISI Study.
The tensile strength test results were within the range expected for carbon steel materials with the exception of I
certain blind flanges.
The interim results of the NUMARC/EPRI carbon steel study were presented to the NRC on July 29, 1988.
Additionally, a chemistry evaluation of the items tested proved to meet material spe(ification requirements.
NUMARC/EPRI supervised testing of the stainless steel specimens supplied by PSI or HJM to various utilities showed that the tested material was within the expected limits of the material specification requirements.
l He have found no evidence of PSI or CLH nonconforming materials being supplied to Plant Hatch.
To assure that unacceptable material was not installed in Plant Hatch, a program was undertaken to review and test HJM l
material which had been discovered.
The purpose of the investigation was to assure that nonconforming material was not installed in an ASME Code l
stamped system.
The initial action was to perform a documentation review to identify material.
The review included both primary and secondary suppliers.
Then separate tests were developed for carbon steel and stainless steel materials.
The testing of carbon steel (SA-105) consisted r
of measuring the hardness of each accessible piece.
The purpose of the I
hardness testing was to determine by direct conversion to tensile strength e
if any of the material appeared to have a lower tensile strength than would i
be expected for SA-105 materials.
Because of its availability, ease of I
use, and general acceptance, the Equotip hardness tester was selected, both for the industry-wide NUMARC/EPRI program and for the Plant Hatch test program.
Initially, each temperature corrected Equotip hardness test value was converted to a Brinell value, whicn in turn, was compared to the specified hardness value for SA-105 material.
The conversion to Brinell values was taken because no direct conversion from hardness to tensile i
strength was then available for Equotip testing.
Apparently, as a consequence of the double conversion rather than direct from Equotip to teasile strength, the initial hardness data erroneously indicated low strength material with the result that 43 items were reported as nonconforming to specification requirements because NRCB 88-05, Supplement 1, required Justification for Continued Operation (JCO) for "any deviation i
from the specification."
The NUMARC/EPRI Study provided the necessary direct conversion from Equotip to tensile strength 2114C t
i
Georgia Power d U. S. Nuclear Regulatory Commission September 8, 1988 Page Four which was unavailable during most of the initial evaluation period (when the failures were reported to the NRC).
The stainless steel material was tested by a magnet to verify that the material was austenitic stainless steel.
Upon further review, it was evident that the Equotip hardness test results had a bell-shaped distribution similar to the NUMARC/EPRI study.
Moreover, these results are also consistent with the AISI Study which performed product tests on material that had already met specification requirer nts by the official mill test. On this basis, it was demonstrated that the carbon steel meets ASME Code requirements.
Therefore a number of flanges which were initially, conservatively, reported to the NRC as nonconforming have been re-evaluated as meeting the Code specifications.
Additionally, GPC personnel performed magnet tests to assure that the HJM provided stainless steel was austenitic.
The material at issue which is installed in Plant Hatch has been tested, and it has been determined, using the NUMARC/EPRI carbon steel study presented to the NRC on July 29, 1988, as a basis, that only an extremely small percentage (approximately 1%) of the carbon steel or stainless steel material tested at Plant Hatch is discrepant.
Therefore, there is basis to conclude that ASHE Code requirements have been met for the vast majority of the HJM material.
For those unique cases where the material specifications were not met appropriate life-of-the-plant JCOs are on file. GPC, when the NUMARC final report becomes available, may re-evaluate the discrepant components and, if justified, remove them from the list of nonconforming material.
The plant specific response for Plant Hatch to the subject NRCB is enclosed to this letter.
If you have any further questions in this regard, please contact this office.
Mr. H. G. Hairston, III states he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.
GEORGIA POWER COMPANY t!
By:
/
it s E
H. G. Hairston, III
~
Sworn to and subscribed b ore me this 8th day of September, 1988.
_ ** &Y$aes 7 ' /)L
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'NotaryPu$
2114C
Georgia Power d U. S.. Nuclear Regulatory Comission September 8, 1988 Page Five
Enclosure:
Plant Hatch Response to Bulletin 88-05 MJB:ju c:
Georaia Power Comoany Mr. H. C. Nix, Jr., General Manager - Plant Hatch Mr. L. T. Gucwa, Manager Hatch Engineering and Licensing GO-NORMS U. S. Nuclear Regulatory Comission. Mashinaton D.C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Comission. Region II Dr. J. N. Grace, Regional Administrator Mr. J. E. Menning, Senior Resident Inspector - Hatch 2114C
o.
Georgia Power d ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES LPR-57, NPF-5 RESPONSE TO BULLETIN 88-05 NONCONFORMING MATERIAL PLANT HATCH RESPONSE TO BULLETIN 88-05 Plant Hatch has identified 459 safety-related and non-safety-related flanges and fittings that were supplied by HJM or PSI.
Hardness tests were conducted on 152 of the 459 to determine if the HJM or PSI supplied materials conformed to the applicable code requirements or procurement specifications.
Due to Supplement 2, hardness testing was terminated after 152 flanges and fittings had been tested and evaluated.
All HJM and PSI flanges and fittings located in the warehouse and safety-related systems had been identified before Supplement 2 was issudd.
Harriness tests were conducted on flanges and fittings classified in three areas: found in the warehouse (56), installed in the pl?nt during construction (91), and installed in the plant after construction (5).
Based on the initial hardness testing, there were 43 flanges which did not conform to the literal ASTM procurement specifications.
All 43 flanges were manufactured by HJM.
There were 13 blind flanges which were not yet installed in safety-related systems at Plant Hatch and 30 flanges which were installed in safety-related systems.
Based on further evaluation using the NUMARC/EPRI methodology, GPC has determined that 41 of the 43 flanges met the procurement specifications.
There is one blind flange in the warehouse and one installed in safety-related systems which do not meet the NUMARC/EPRI criteria.
Attachment 1,
to this enclosure, contains information requested by NRCB 88-05 for the 2 flanges which did not meet the criteria of the NUHARC/EPRI evaluation.
Included is the Hatch testing identification (e.g., C280), the duty in which these materials are to be used (e.g., ASME Code Section III Class 2), the application in which these materials are used (e.g.,
Plant System 2PSH), the material specification (e.g.,
ASTH A105), nature of the component (e.g.,
Flange Type RFHN), pipe size, pressure rating, and chain of purchase (e.g., Supplier 1 is HJM, Supplier 2 is Hub, Inc.).
Although not requested by the NRC, the Heat Number was included as part of the information provided for each flange.
As required by NRCB 88-05, Plant Hatch has demonstrated that the supplied materials are suitable for the intended servico by a JCO.
None of these flanges will require replacement.
The 13 HJM flanges which are not yet 2114C E-1 09/08/88 HVS-43
Georgia Power d ENCLO3URE 1 (continued)
PLANT HATCH RESPONSC TO BULLETIN 88-05 installed in safety-related systems will be retained until advised further by the NRC.
As requested, documentation of the specific actions taken for the identified materials will be maintained until after closure of the NRC8 by the NRC. lists the flanges which were initially found to be nonconforming but which ha'.'e been re-evaluated using the NUMARC criteria as meeting the procurement specifications.
As allowed by Supplement 2, Plant Hatch is suspenoing temporarily the field measurements, testing, records review and the JC0 process until further notice.
In summary, NRCB 88-05 material in-situ testing was stopped, due to the Supplement 2 suspension of testirig.
A documentation review has revealed that CLH materials have not been procured or installed at Plant Hatch, but PSI and HJM supplied flanges and fittings.
There were no indice.tions of PSI material being in nonconfomance with procurement specifications.
The l
HJM flanges and fittings tested at Plant Hatch have been largely determined to be in conformance with applicable code requirements and procurement specifications.
Those flanges which have been determined to be in nonconformance have appropriate life-of-the-plant JCOs on-file.
Attachments 1 and 2 present the findings of our investigation at Plant Hatch.
Due to the large sample and acceptable test results obtained on HJM flanges and fittings installed in safety-related systems GPC nuclear
- plants, there is substantial evidence to conclude that HJM supplied i
iaaterials used in system that are non-safety-related are suitable for their
[
intended use.
GPC believes this conclusion answers NRCB Action Requested Item 4.
i i
[
t 1
2114C E-2 09/08/88 HVS-43 I
Georgia Power d ENCLOSURE I (continued)
PLANT HATCH RESPONSE TO BULLETIN 88-05 ATTACHMENT 1 Flanges Which Did Not Heat The Evaluation Criteria HATCH ASME PLANT ASTM FLANGE PIPE PRESS.
HEAT SUPPLIER
_LJh.
CLASS SYS (1)
SP_EC2 TYPE (2)
SJ2E RATING E
J*_
2**
H14 2
N/A A105 Blind 1.50" 300#
R627 HJM CP P110 2
2RCIC A105 RFSH 1.00" 1500#
80508 HJM HUB 1.
Plant Syst. - Systems which have reported HJH material installed.
N/A
- Not yet installed (located in warehouse) 2RCIC
- Unit 2 Reactor Core Isolation Cooling 2PSH
- Unit 2 Plant Service Hater 2RHR Unit 2 Residual Heat Removal 2CS Unit 2 Core Spray Unit 1 Torus Hater Clean Up ITHCU 2.
Flange Type - type of flange installed RFHN
- Raised Face Held Neck RFSO
- Raised Face Screw on RFHN
- Raised Face Held Neck RFSO
- Raised Face Screw on RFSH
- Raised Face Socket Held HJM is West Jersey Manufacturing CP is Capital Pipe and Steel Products Co.
HUB is Hub, Inc.
KEL is H. H. Kellogg/ Pullman Kellogg/ Pullman Power Products GA is Guyon Alloys. Inc.
Abbreviations also apply to Attachment 2 2114C E-3 09/08/88 HVS-43
Georgiu Power [
ENCLOSURE I (continued)
PLANT HATCH RESPONSE TO BULLETIN 88-05 ATTACHMENT 2 Flanges Hhich Here Initially Found to be Nonconforming but Which Have Been Re-evaluated As Meeting the Procurement Specifications HATCH ASHE PLANT ASTM FLANGE PIPE PRESS.
HEAT SUPPLIER
,11 c' ASS SYS (1) SE L TYPE (2) 1111 BAllE R(k_
l' 2"
H13
".1 A105 Blind 1.50" 300#
R627 HJM CP W15 4'
A105 Bitnd 1.50" 300#
R627 HJM CP H31 A105 Bitnd 4.00" 1500#
2022 WJH HUB ID1
/A A105 Blind 4.00" 1500#
2022 HJM HUB
'A A105 Blind 4.00" 1500#
2022 HJM HUB i/A A105 Blind 4.00" 1500#
2022 HJM HUB N/A A105 Blind 0.75" 300#
CHV HJM GA N/A A105 Blind 0.75" 300#
CHV HJH GA N/A A105 Blind 0.75" 300#
CHV HJM GA 2
N/A A105 Blind 0.75" 300#
CHV HJM GA
&-v 2
N/A A105 Blind 0.75" 300#
CHV HJM GA H52 2
N/A A105 Blind 0.75" 300#
CHV HJM GA C100 2 2CS A181 RFHN 3.0" 300#
BH HJM KEL C101 2
2CS A181 RFHN 3.0" 300#
BH HJM KEL C107 2 2CS A181 RFHN 3.0" 300#
BH HJH KEL P134 6 ITHCU A350 RFHN 8.0" 150#
B3482 HJM HUB C225 2 2RHR A181 RFHN 16.0" 300#
BN HJH KEL C226 2 2RHR A181 RFHN 16.0" 300#
BN HJM KEL C227 3 2RHR A105 RFNN 10.0" 300#
B3 HJM KEL C228 3 2RHR A105 RFHN 10.0" 300#
B3 HJM KEL C229 3 2RHR A105 RFHN 10.0" 300#
B3 HJM KEL C230 3 2RHR A105 RFHN 10.0" 300#
B3 HJH KEL C231 2
2RHR A181 RFHN 3.0" 300#
BB HJM KEL C232 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C233 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C234 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C235 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C236 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C237 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C238 2 2RHR A181 RFHN 3.0" 300#
BB HJM KEL C243 2 2RHR A181 RFHN 4.0" 300#
BL HJM KEL C278 3 2PSH A105 RFSO 6.0" 300#
$5 HJM KEL C279 3 2PSH A105 RFSO 6.0" 300#
S5 HJM KEL C280 3 2PSH A105 RFHN 6.0" 150#
B2 HJM KEL C285 3 2PSH A105 RFHN 6.0" 150#
B2 HJM KEL C288 3 2PSH A105 RFHN 6.0" 150#
B2 HJM KEL C292 3 2PSH A105 RFHN 6.0" 150#
B2 HJM KEL C294 3 2PSH A105 RFSO 6.0" 300#
GL HJM KEL C295 3 2PSH A105 RFHN 6.0" 150#
B2 HJM KEL C296 3 2PSH A105 RFHN 6.0" 150#
B2 HJM KEL C298 3 2PSH A105 RFSO 6.0" 300#
SS HJH KEL 2114C E-4 09/08/88 HVS-43
P GeorgiuPowet 'b ENCL 0suRE 1 (continued)
PLANT HATCH RESPONSE TO BULLETIN 88-05 ATTACHMENT 3 Brinell Hardness HATCH
_lL_
AS FOUND ACCEPTABLE N14 97 137 P110 102 137 W13 107 137 HIS 115 137 H31 128 137 H32 134 137 H33 124 137 H34 130 137 H41 120 137 H42 130 137 H43 118 137 H44 115 137 H50 120 137 H52 134 137 C100 120 137 C101 120 137 C107 130 137 P134 128 137 C225 127 137 C226 121 137 C227 127 137 C228 134 137 C229 133 137 C230 136 137 C231 130 137 C232 131 137 C233 131 137 C234 127 137 C235 134 137 C236 135 137 C237 133 137 C238 131 137 C243 134 137 C278 131 137 C279 135 137 C280 187 186 C285 190 186 C288 227 186 C292 208 186 C294 198 186 C295 192 186 C296 199 186 C298 128 137 2114C
- A43 El-5 09/08/88 I
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