ML20212B379
| ML20212B379 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/29/1986 |
| From: | Miosi A COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1916K, 86-06, 86-6, NUDOCS 8608060311 | |
| Download: ML20212B379 (5) | |
Text
CORNRORWGGilh EdOOR O
-. One Fast Nabonal Plaza, Chcago, Innois Address Reply Lx Poet Omco Box 757 Chcago,innois60000 0767 July 29, 1986 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2 10 CFR 50.55(e) No. 86-06 30 Day Report Fastener Material Supplied by Cardinal Industrial Products l
NRC Docket Nos. 50-456 and 50-457
Dear Mr. Keppler:
On June 17, 1986, Commonwealth Edison Company notified Mr.
P. Pelke of your office of a deficiency reportable pursuant tc 10 CFR 50.55(e) relative to fastener material supplied by Cardinal Induscrial Products.
This deficiency was assigned number 86-06 for Braidwood Units 1 and 2 for your tracking purposes.
This letter fulfills the thirty day reporting requirements of 10 CFR 50.55(e) regarding this matter and is considered an interim report.
An extension in submitting this report was discussed with W.S. Little of your office on July 17, 1986.
Description of Deficiency Notifications relative to fastener materials supplied by Cardinal Industrial Products have indicated that these shipped loose j
fastener materials which have been supplied to Commonwealth Edison Company either may not comply with the purchase order requirements or have unresolved technical questions.
Analysis of Safety Implications The analysis of the safety implications is still being performed at this time.
Corrective Action Taken The following summarizes the reviews performed by Cardinal and the dispositions needed to provide corrective action for the deficiencies included in Nonconformance Report NCR 679, Revision 1 which was initiated to track this issue.
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Summary of Documentation Reviews Performed by Cardinal Cardinal performed a review of applicable documentation for bolting materials over 1" in diameter shipped prior to the issuance of the ASME Quality System Certificate on January 9,
1984.
This review was requested by Commonwealth Edison Company (Ceco) for purchase orders issued by Ceco and more recently for Cardinal materials received from Hub Inc. that were supplied to Ceco.
The Cardinal review was largely technical in nature and was not designed to verify ASME Code program requirements.
Cardinal performed a review of the material documentation as requested by ASME for bolting material over 1" in diameter shipped from January 9, 1984 (effective date of Quality System certificate) through August 15, 1985.
This was both a technical review and a check of the ASME program requirements.
All materials shipped after August 15, 1985 are considered to be in compliance with the ASME Code and Cardinal's QA program.
II.
Summarv of the Corrective Action for the Deficiencies Identified in the Above Reviews are as Follows:
(A)
Materials over 1" in diameter shipped during the period of January 9, 1984 through August 15, 1985 that are not included on notification letters are considered acceptable.
All materials shipped after August 15, 1985 where documentation received meets the purchase order requirements are also considered acceptable.
(B)
In reference to the potential 10 CFR Part 21, dated 8/21/84, where material rejected by the Cardinal NDE center was not properly identified or documented, NCR 679, Rev.
1, disposition was to replace the materials noted as reportable.
A separate evaluation by CECO determined that Cardinal's disposition of material found rejectable during the NDE process involved a lack of documentation and that the rejectable material was not shipped to Ceco.
Based on the i
above, matorials received with thu required NDE documentation can be accepted as is.
(C)
For size excluded material shipped prior to August 15, 1985 where ASME program requirements were not verified, Ceco has adopted the later ASME Code provisions of NX-2610(b).
For these materials, Ceco and the applicable NA Certificate holders have
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, evaluated the material during receiving inspection.
Further, Cardinal has performed additional testing as l
part of a controlled inventory material retesting program.
That program also provided assurance that the materials were furnished in accordance with the 1
material specification and with the special requirements of the applicable subsection (s).
With the exception of those items having specific technical questions, size excluded, materials are considered acceptable as.is.
(D)
For size included material where the ASME program requirements were not verified by Cardinal, Ceco has adopted the provisions of Code Case N-242-1.
This Code Case provides alternate rules for the acceptance of material.
Based on the results of the documentation reviews performed by Cardinal and additional reviews by Ceco, it has been determined that the provisions of the Code Case are applicable.
(E)
The Cardinal reviews have identified a concern where the heat treatment data shows the stress relieving was performed at a temperature greater than 100*F below the tempering temperature.
The 100*F difference was not a requirement of the 1974 Edition Summer 1975 Addenda of ASME Code Material Specifications.
In addition, the stress relieving temperature should have been lower than the tempering temperature, otherwise the yield and tensile strength would have been decreased.
Therefore, the subject items are acceptable as is.
(F)
The Cardinal reviews have identified a concern where the NDE required by the material specification was not performed on the final product.
Rejectable materials were found when the NDE was performed.
The material specification requires that each piece in the shipment be magnetic particle tested.
For those caser where the bolts are installed and the brackets are field welded per S&L drawing S-1113, Note 7, the bolt materials are being accepted as is since the weld carries the required load.
All other items in the shipment will be verified as acceptable by testing or will be replaced.
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, (G)
The Cardinal reviews have identified a concern where only a sample receipt inspection was performed and no additional. visual inspections were performed.
The CECO purchase order required that all bolting materials be visually axamined.
When visual inspections were performed, a rejectable indication was noted.
All items received in the subject shipment which are designated for installation will be visually inspected per the applicable requirements.
(H)
The Cardinal reviews have identified a concern where the charpy impact tests were not performed at the temperature required by the CECO purchase order.
Since the materials identified to have this condition have not been issued for installation, materials will not be used in ASME or safety-related system or components.
(I)
The Cardinal reviews have identified a concern where the objective evidence is not available to support the reporting of particular characteristic on the Certified Material Test Report.
The data on the test report has been, however, reviewed and found acceptable.
These items are being dispositioned as follows:
(i)
Retesting of the heat number has resulted in data that is in compliance with the mechanical properties of material specification.
These items can be accepted as is.
(ii)
Retesting of the heat number has resulted in data that is in compliance with ASTM /SA specification SAS40.
Sargent & Lundy has reviewed this substitution and found it acceptable for the applicable installations.
Theue items will be recertified by CECO to tha requirements of AS40 Grade B22, Class 5.
(iii)
Retesting of the heat number has resulted in data which does not conclusively show that the items meet the requirements of the material specification.
To expedite the closure of the NCR and since a minimal quantity of material has been issued, these items will be removed from stock or replaced if installed and will not be used in ASME or Safety-Related Systems or Components.
, (iv)
For the remaining heat numbers, the l
contractor records have indicated that the materials are still in stock or minimal quantities have been issued for installation.
To expedite closure of the NCR, these items will be removed from stock or replaced if installed.
They will not be used in ASME or Safety-Related Systems or Components.
The subject corrective actions have required that limited amounts of material be removed from stock or replaced if installed.
Ceco is still reviewing the Cardinal issue and plans to update your office as soon as more information is available.
Please address any questions that you may have concerning this matter to this office.
Very truly yours, k
A.D. M osi Nuclear Licensing Administrator ADM/pav cc: NRC Resident Inspector - Braidwood 1916K i
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