ML20236T692
| ML20236T692 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/25/1987 |
| From: | Capra R Office of Nuclear Reactor Regulation |
| To: | Stone J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20236T694 | List: |
| References | |
| TAC-66490, NUDOCS 8712020023 | |
| Download: ML20236T692 (1) | |
Text
November 25, 1987 Docket Nos. 50-317 DISTRIBUTION and 50-318
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SVarga NRCPDR PBoger PDI-1 Rdg.
CVogan-SMcNeil JPartlow-MEMORANDUM FOR:
James C. Stone, Actins Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards FROM:
Robert A. Capra, Director Project Directorate I-1.
Division of Reactor Projects, I/II
SUBJECT:
REQUEST FOR PUBLICLY DOCiKETED CORRESPONDENCE CONCERNING FASTENER.7SSCES AT CALVERT CLIFFS UNITS 1 AND 2 (TAC 66190)
On November 5,1987, Mr. Stephen F. Sims, $pecial Assistant for the U.S. House of Representatives Subcommittee on OversMt and Investigation, visited
-Calvert Cliffs Nuclear Power Plant to dkcuss BG&E's use of improper fastener material s.
At that time, Mr. Sims requested that the NRC staff provide him a copy of all publicly docketed records concerning this issue at Calvert Cliffs.
As Vendor Inspection Branch has the lead responsibility with regards to fastener issues concerning Mr. Sims, the enclosed documents are being provided '
to permit your facilitation of Mr. Sims' request.
Robert A. Capra, Director Project Directorate I-1 Division of Reactor Projects, I/II
Enclosure:
As stated BIN PDI-1 fphy PDI-1~
PDI-1 CVo n SMcNeil RCapra 11/
87 11/2f/87 11/M/87 8712020023 871125 PDR ADOCK 05000317 P
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b B A LT IMOR GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE. MARYLAND 21203
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JostPM A.TIERN AN Viet Poggioght NuCLEA A [ht m0' May 4, 1987 U.
S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
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SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 J
Use of Mechanical Parts Purchased Commercial Quality in ASME Section XI Code Class 1, 2,-and 3 Systems Gentlemen:
On Friday, May 1, 1987, we discussed our findings to date with Messrs. McNeil, Tripp, Foley, et. al.
One element of our plan to resolve the use of parts purchased commercial quality and installed in code systems is a sampling program for fasteners (studs, bolts, threaded rods, and nuts).
The sampling program plan is attached.
Although results are still preliminary, it appears that fasteners will make-up a
majority of. all parts involved.
Should the number of fasteners purchased commercial quality and installed in code systems be excessive, then we would consider this sampling program to reduce the work that would be required to ensure these commercial quality fasteners are suitable in code systems.
We may also use the in-situ. tests described in " Equivalent Material Specifications" to justify leaving commercial quality fasteners installed in code systems instead of replacing them.
We will continue to keep you informed of the status of our investigation.
We will also notify you when, and if, we find it prudent to use the attached sampling program.
8705000T9F B70504 4
0j PDR ADOCK 05000317 ta P
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i Document Control D3ak May 4, 198'i Page 2 Should you have any questions regarding the attachment or any other aspect of this issue,.please feel free to contact us.
Very truly yours,
/
JAT/ WPM /dlm Attachment cc:
D. A. Brune, Esquire J. E. Silberg, Esquire W. T. Russell, NRC.
R. A.
Capra, NRC S. A. McNeil, NRC T. Toley/D. A. Trimble, NRC i
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PROGRAM PLAN TO RESO. (E THE USE OF COMMERCIAL QUALITY FASTENERS IN ANSI B31.7 CLASS 1 AND 2 SYSTEMS AT l
CALVERT CLIFFS NUCLEAR POWER PLANT SCOPE Studs, bolts, threaded rod, and nuts (hereaf ter referred to as f asteners) purchased by BG&E as Commercial Quality but installed within the ASME Section XI Class 1,2, and 3 system boundaries.
OBJECTIVES Ensure a representative sample (defined later) of fasteners in Class 1,2, and 3 systems i
purchased as Commercial Quality meet material specifications equivalent (defined later) l to that provided in ASME Section XI.
j DEFINITIONS Equivalent Material Specifications Acceptable results in the following tests.
Chemical composition will be determined using an x-ray florescence analyzer, Model No 840 manufactured by Columbia Scientific Industrial. The major alloy constituents will be determined and acceptance criteria vill be in accordance
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with the applicable ASTM specification.
A hardness test will be performed in accordance with a BG&E Quality Assurance Program procedure with acceptance criteria based on the applicable ASTM specification.
An ultrasonic test will be performed in accordance with a BG&E Quality Assurance Program procedure with acceptance criteria based on the applicable ASTM specification.
A second examination in a lab may be required to differentiate between a f alse indication or in-service flaw and a manufacturing flaw.
i Representative Sample The number of f asteners that must be tested (as described above) i to provide a 95 percent confidence level that less than 5 percent of Commercial Quality i
fasteners installed on all Class 1, 2, and 3 systems do not meet equivalent material l
specifications.
The characteristics of each fastener will be assessed to ensure the j
representative sample is representative of the total population.
i This sampling program is similar to IE Bulletin No. 79-02 (Revision 2), Appendix A, j
Sampling Method (b), with one exception. The Bulletin's sampling program was to be
{
done on a system-by-system basis. We will sample over all Class 1, 2, and 3 systems l
because:
the suitability of fasteners purchased Commercial Quality in all Class 1,2, and 3 systems is at issue, and the source of Commercial Quality fasteners is identical for each system and class of system.
1
- PhOURAM PLAri TO RESOLVE THE USE OF COMMERCIAL QUALITY FASTENERS IN ANSI B31.7 CLASS 1 AND 2 SYSTEMS AT CALVERT CLIFFS NUCLEAR POWER PLANT PROGRAM ELEMENTS (1)
Maintenance Orders (MOs) involving ASME Section XI Class 1,2, and 3 systems are reviewed to determine the nature of the work.
(2)
Those MOs that indicate a fastener was exchanged are reviewed in detail to determine the means by which that fastener was purr.hased.
(3)
If we determine a fastener was purchased Commerica! Quality then it is identified as one member of the total population from which a representative sample will be tested. (if we cannot determine which fastener (s) within a bolt ring were replaced, then the entire bolt ring is assumed to be one member of the total population.)
(4)
A representative sample of the total population will be tested as described above in
" Equivalent Material Specifications." Members of the total population from Class I systems will be tested first. If necessary to obtain the representative sample, members of the total population from Class 2 and 3 systems will be tested.
(5)
An members of the total population that do not meet the equivalent material specification will be replaced with fasteners that meet the ASME Section XI requirements (Class 1,2, or 3, as appropriate).
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B ALTIMORE GAS AND ELECTRIC CHARLES CENTER + R O. BOX 1475 BALTIMORE, MARYLAND 21203 JostPM A.TIERNAN Vict Passioth?
NWCLEAR Engmor May 11,1987 l
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Relief from Replacement Requirements in Section XI of the i
ASME Boiler and Pressure Vessel Code, Articles IWA-7210, IWC-7600, IWD-7600, and IWF-7600 Gentlemen:
Pursuant to 10 CFR 50.55a(g)(5)(iii), we hereby request relief from certain requirements in the ASME Boiler and Pressure Vessel Code Section XI,1983 Edition with Addendum
,through Summer 1983.
Components for W nch Relief is Requested Fasteners (studs, oolts, threaded rod, and nuts, as applicable) for those components listed in Attachment A.
This list is not complete. We will submit a final list af ter we complete our investigation.
Code Requirement from Which Relief is Requested I
Article IWA-7210 and Article IWC-7600, IWD-7600, or IWF-7600, as applicable to i
I Certificate of Compliance and marking requirements.
Supporting Information The above articles require that replacements meet either the requirements to which the original component or part was constructed, or requirements of later editions of ASME
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Section 111 if certain other criteria are met. We recently identified f asteners for those 1
components listed in Attachment A that were purchased by our Safety-Related Commercial Quality method of procurement. In all cases, our purchase orders specified the appropriate ASTM specification. Receipt inspection was made to y nformance
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Document Control Desk May 11,1987 Page 2 to purchase orders. However, we did not specify or receive Certified Material Test Reports (CMTRs) or Certificates of Compliance (C of Cs) required by the original construction code, and we did not transfer the marking code when material was cut to make more than one piece.
We have determined it is impractical to replace the fasteners for those components listed in Attachment A with fasteners that have CMTRs or C of Cs for one of the following reasons:
1.
Results of tests of the fastener ensure us that the fastener is adequate to perform its safety function.
The tests to be performed are described in Attachment B.
It would be impractical to expend the considerable effort that would be required.
to replace these fasteners since they are adequate to perform their safety function.
That effort would involve at least 24 manhours of preparation, radiation control, quality control, and craf t labor for each component listed in 1
Attachment A.
Some replacements would involve work in high radiation areas' 4
and some fasteners will be difficult to replace.
2.
The fastener is similar to other fasteners tested and the results of those tests provide assurance, with a high level of confidence, that the fastener is adequate to perform its safety function.
(Our sampling program is described in Attachment C.)
As with item 1, it would be impractical to expend the considerable effort that would be required to replace these fasteners as well.
Exams Peformed in Lieu of Section XI Requirements Chemical composition, non-destructive, and hardness exams will be performed on all commercial quality pressure-retaining fasteners removed from Class I components and on a sufficient number of Class 2 and/or 3 fasteners to obtain the total sample size required by the sampling program (Attachment C). All commercial quality pressure-retaining fasteners for Class I components will be replaced and are outside the scope of this request for relief; however, fasteners removed from Class I components will be tested as part of the sampling program.
A flow diagram for the examinations referencing the BG&E procuedures being used and acceptance criteria for the chemical composition, non-destructive, and hardness exams are given in Attachment B.
l Schedule All tests will be completed prior to heatup. We estimate Unit I heatup will begin May 20 I
and Unit 2 on May 25. We will keep you informed of changes to our schedule.
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Document Control Desk May 11,1987 Page 3 Corrective Actions Future replacement fasteners for ASME Section XI Class I, 2, and 3 components will meet the applicable requirements of ASME Section XI. Additional controls on the use of commercial quality material have been imposed. Those personnel responsible for any aspect of installing replacement fasteners (from procurement to installation) have been informed of their responsibilities.
A formal repair and replacement program procedure has been implemented for Unit 1, and will be implemented for Unit 2 upon startup. This program requires a detailed l
review of replacements to ensure a suitability evaluation has been made for all replacements. Training for the implementation has been conducted.
Application Fee Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1910547 in the amount of
$150.00 to cover the application fee for this request.
Should you have further questions regarding this matter, we will be pleased to discuss them will you.
Very truly yours, l
6h 3AT/ WPM / dim Attachments cc:
D. A. Brune, Esquire i
- 3. E. Silberg, Esquire R. A. Capra, NRC j
S. A. McNeil, NRC W. T. Russell, NRC T. Foley/D. A. Trimble, NRC I
ATTACHMENT A FASTENERS FOR WHICH RELIEF 15 REQUESTED COMPONENT CONSTRUCTION CODE ASME SECTION XI CLASS Relief Valve, 1-51-409 ANSI B31.7, Class 2 2
Relief Valve, 1-51-431 ANSI B31.7, Class 2 2
Valve,1-BD-40ll ANSI B31.7, Class 2 2
Valve,1-BD-4010 ANSI B31.7, Class 2 2
Relief Valve, 1-51-439 ANSI B31.7, Class 2 2
Spool Piece, ILRT ANSI B31.7, Class 2 2
Flange, Containment ANSI B31.7, Class 2 2
Spray Piping Relief Valve, 2-51-439 ANSI B31.7, Class 2 2
Relief Valve, 2-51-431 ANSI B31.7, Class 2 2
Relief Valve,2-S1-241 ANSI B31.7, Class 2 2
ATTACHMENT B 1
FLOW CHART FOR MATERIALS TESTING AND EVALUATION OF STUDS,80LTS AM) NUTS COMPONENT $ IN FRDM PLANTS l
GLASS BEAD
/ CLEAN e
NATERIAL RECEPT /
IDENTIFICATION / 8 LOG IN l
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SURFACE. EXAM '
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- Note 1 (NDE 1800.$202) 1 ANALYSIS SY
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=^7'mJ;,*a-
, NO STORE CUT, MARK f laATERIA YES NOTE NI RESIDUAL
& TEST uRFER[
(EFICENCY LOG l
i HARDNESS TESTS
- ote 2 (NDE 5.903)
MACHifE TENSILE NO NOTE R'.
IN SPE LDe 7
sPSciesEN e TEST YES,N6
- Note 2 j
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- Note 2 QEMICAL ANALYSIS I
M NOTE IN LOS/
l TENSILE RCSULTS (WTE 27D02.E7004) 18s SPEC T APPEND IESIA7S l
' NO No 88 SPEC RECORO/SWE secTE IN LDS/
y MATERIAL APPDC RERJLTF SWE MATERIAL YES o
RECORD a PRW6CIPAL E5 uETAu.uRelST REvaw/
APPROVE I
1 NOTE 1 Any indication which is RESULTS TO rejectableaccordingtothe RESPONSIBLE ENGIPEER code for the technique enployed.
NOTE 2 The acceptance criteria is j
specified in the applicable ASIM Specification.
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ATTACHMENT C SAMPLING PROGRAM OBJECTIVE l
Ensure, with reasonable certainty, that the fasteners for components listed in Attachment A are adequate to perform their safety function.
1 SCOPE OR TOTAL POPULATION Fasteners installed in ASME Section XI Class 1, 2, and 3 pressure-retaining components and their supports purchased by our Safety-Related Commercial Quality method.
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SAMPLE SCOFE Sample fasteners.. nz be taken from ASME Section XI Class 1 pressure-retaining components first. The remaining sample fasteners that are required will be taken from the rest of the population. If we cannot determine which fastener (s) within a bolt ring were replaced, then the entire bolt ring is assumed to be one sample. All fasteners must 1
pass for that sample to pass.
l TESTING Each sample fastener will undergo non-destructive chemical composition, non-destructive, and hardness exams described in Attachment B.
If an additional exam is necessary to determine pass / fall, such as a tensile test, then it will be performed as described in Attachment B.
SAMPLE SIZE The sample size shall be sufficient to provide a 95% confidence level that more than 95%
of the total population are adequate to perform their safety function. That number is dependent on the number of failures that are found. This is illustrated below:
Sample Size Failures 59 0
93 1
112 2
149 3
The characteristics of each type of fastener will be assessed to ensure the samples are representative of the total population.
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ATTACHMENT C SAMPLING PROGRAM This sampling program is similar to IE Bulletin No. 79-02 (Revision 2), Appendix A, Sampling Method (b), with one exception. The Bulletin's sampling program was to be done on a system-by-system basis. That is, the total population was those items in one system. Our total population covers all ASME Section XI Class 1, 2, and 3 systems because:
the suitability of fasteners purchased Safety-Related Commercia! Quality is at issue, and the source of Safety-Related Commercial Quality fasteners is similar for each system and system class.
4 Pt-n o w c i t S ALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JostPH A.TIERNAN Vice Pacsiotut j
Nucuan Entmov i
May 11,1987 U. S. Nuclear Regulatory Commission I
Washington, DC 20535 I
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Exemption from inservice Inspection Requirements in
{
REFERENCE:
(a)
Letter from Mr. 3. A. Tiernan (BG&E), to NRC Document Control
[(/
Desk, Request for Relief from Replacement Requirements in Section XI of the ASME Boller and Pressure Vessel Code, Articles IWA-7210, IWC and D-7600, dated May 11,1987 Gentlemen:
We have determined that the relief from ASME Section XI requirements we requested in Reference (a) may also be granted by the Commission in the form of an exemption to the inservice inspection requirements in 10 CFR 50.55a(g). Pursuant to 10 CFR 50.12, we hereby request such an exemption.
We seek either relief from ASME Section XI requirements or an exemption from 10 CFR 50.55a(g). Both are not required.
Section 50.55a(g) states we must meet the requirements set forth in Section XI for all ASME Class 1, 2, and 3 components. This exemption request is limited to f asteners for those components listed in Attachment A of Reference (a) and the requirements in Articles IWA-7210, IWC-7600, IWD-7600, and IWF-7600 of Section XI as they pertain to Certified Material Test Reports or Certificates of Compliance and marking requirements j
only.
Granting this exemption will not violate any other applicable laws, including the Atomic j
Energy Act and the National Environmental Policy Act. This exemption will not present an undue risk to the public health and safety, and is consistent with the common defense and security.
We believe that special circumstances exist that would lead the Commission to consider I
this request.
Within the narrow scope previously defined, application of 10 CFR 50.55a(g) is not necessary to achieve the underlying purpose of the rule. The underlying purpose of 10 CFR 50.55a(g) is to ensure that structures, systems, and
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Document Control Desk May 11,1987 1
Page 2 components important to safety are maintained to quality standards commensurate with the importance of the safety function to be performed.
The safety function of the fasteners is to maintain their structural integrity under all expected operating and accident conditions. The quality standards are, as a minimum, those required by regulation at the issuance of the construction permit.
When construction is complete, those standards are maintained by following the requirements of ASME Section XI.
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We have established a new quality standard for fasteners of those components listed in Attachment A of Reference (a). That standard is the testing program described in Attachment B of Reference (a) and the sampling program described in Attachment C of Reference (a).
The examinations specified in the testing program are sufficient to determine that the structural integrity of the fasteners has been maintained. In the future, we will meet the requirements of ASME Section XI when we replace these fasteners.
By completing all tests, satisfying the sampling criteria, and following the requirements of ASME Section XI for future replacements, we will achieve the underlying purpose of 10 CFR 50.55a(g).
Application Fee Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1910548 in the amount of
$150.00 to cover the application fee for this request.
Should you have any further questions regarding this matter, we will be pleased to discuss I
them with you.
Very truly yours, j
l JAT/ WPM / dim cc:
D. A. Brune, Esquire
- 3. E. 511 berg, Esquire R. A. Capra, NRC S. A. McNeil, NRC W. T. Russell, NRC T. Foley/D. A. Trimble, NRC I
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