ML20246F081
| ML20246F081 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/23/1989 |
| From: | Barnes I, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20246F018 | List: |
| References | |
| 50-285-89-30, IEB-87-002, IEB-87-2, NUDOCS 8908300147 | |
| Download: ML20246F081 (7) | |
See also: IR 05000285/1989030
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~ APPENDIX:
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"AR REGULATORY.' COP 9IISSION;
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REGION IV
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ENRC' Inspection Report: .50-285/89-30
Operating License: .DPR-40:
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Docket: :50-285:
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' Licensee:SOmahaPublicTPowerDistrict(OPPD)
444 South 16th Street. Mall
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Omaha, Nebraska 68102-2247
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Facility Name: FortjCalhoun. Station
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. Inspection At:. Fort Ca'1houn Station. Blair, Nebraska
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,[j. y " Inspection Conducted:F July ~24-28 1989
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" -Inspectori"
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W . Stewa'rt, Reactor Inspector, Materials
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and Quality. Programs Section, Division of
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Reactor Safety'
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- p r. Barnes, Chief, Materials and Quality ;
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Programs Section. Division of Reactor Safety.
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Inspection Summary
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Inspection Conducted July:24-28, 1989 (Report 50-285/8V-30)'>4
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Areas Inspected: Routine f unannounced inspection of the implementation of
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corrective actions.in response to!NRC Bulletin 87-02 concerning. fastener
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testing and the. review of-procedures /controisiestablished to assure-
implementation'of'10 CFR Part 21 requirements.
LResults h In general 'the:11censee's documentation files reflected responsiveness
to Bulletin 87-02 and subsequent Supplements 1 and 2.
Tests perfomed on
selected safety-related fasteners indicated all samples met the specific '
imaterial specification requirements and therefore, no corrective action by the
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licensee was deemed necessary.
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'L'aboratory test' conducted on nonsafety, unmarked fasteners produced results-
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innoncompliancewithSAE.J429 Grade 5.-These/noncomplianceswereattributed
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to' previous-purchasing methods which were without specific OA requirements-
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,4 , and/or receipt inspection'for'nonsafety-related fasteners. The licensee has
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removed ~all unidentifiable fasteners from warehouse stock and has-revised
purchase order and receiving inspection procedures to preclude recurrences.
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The licensee's evaluation concluded that no failures of fasteners have
o; curred in 15 years of plant operations, and the likelihood of a nonsafety
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fastener failure in a nonsafety system, creating a significant safety-related
operat,111ty problem, is remote. Thus, the licensee's effort to identify all
possible locations'where the unmarked fasteners may have been used is not
warranted,
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The licensee's established implementing procedures and controls to ensure the
reporting of defects and noncompliance appear to be adequate to assure
implementation of 10 CFR 21 requirements.
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No violations or deviations were identified.
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DETAILS
1.
Persons Contacted
,0 PPD
- C. F. Simons Licensing Engineer
- D. J. Matthews, Supervisor, Station Licensing
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W. Richard, Assistant Plant Manager
- J. E. Zelfel, Operations QA
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NRC
- T. Reis, Resident Inspector
The inspector also interviewed other licensee personnel during the
inspection.
- Denotes those persons that attended the exit interview on July 28, 1989.
2.
Followup Inspection - Bulletin 87-02 - Fastener Testing and Corrective
Actions (TI 2500/27)
The NRC issued NRC Compliance Bulletin 87-02 cn November 6, 1987. This
bulletin required licensees and construction permit holders to review
their receipt inspection requirements and controls for vendor-supplied
fasteners and independently determine, through testing, whether fasteners
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(studs, bolts, cap screws, and nuts) in stores at their facilities met
applicable mechanical and chemical specification requirements. Response
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to Bulletin 87-02 was required within 60 days of its receipt.
On April 22, 1988, the NRC issued Bulletin 87-02, Supplement I which
requested licensees and construction permit holders to submit information
regarding the vendors which have supplied safety-related or nonsafety-related
fasteners within the last 10 years. This information was to include the
name and address of the manufacturer or supplier, and specification of the
fastener provided.
On June.10, 1988, the NRC issued Bulletin 87-02, Supplement 2, which
superseded the requirements of Bulletin 87-02, Sapplement 1.
Supplement -2
required addressees to provide within 90 days of receipt of Supplement 1:
"1.
A list of the suppliers and manufacturers from which safety-related
ferrous fasteners 1/4 inch in diameter or greater may have been
purchased, within the past 10 years, including addresses.
For those
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fasteners purchased from fastener suppliers and/or original equipment
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manufacturers, any available information that identifies the
manufacturer or subtier supplier of the fasteners also should be
provided. Approved Vendor L1st or Qualified Supplier Lists are the
intended sources for this information. Addressees are not required
<to search purchase order files, contact subcontractors to obtain the.
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information, or submit data on fasteners supplied as part of the
original component.
2 . For nonsafety-related fasteners the same information as required in
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the first two sentences of Item 1, above, except that a) the time of
interes*; is for fasteners procured in the last 5 years, and b) the
search of available records in this case should. include purchase
orders unless the licensee utilizes approved vendor lists or
qualified supplier lists in procuring nonsafety-related fasteners.
This information collection is understood to be on a best-effort
basis. Further, addressees are not required to contact
subcontractors to obtain the information or to submit data on
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fasteners supplied as part of an original component."
The objectives of this area of the inspection were to verify that the
licensee has complied with the testing of fasteners, as required by
Bulletin 87-02 (including the Supplements 1 and 2), and that corrective
action has been taken by the licensee for .any significantly out of
specification material found during testing of safety-related festeners.
Finding - Document Review
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As requested by Bulletin 87-02, the lict;nsee, with the particip? tion of
the senior NRC resident inspector, selected from warehouse stores, a
sample of 10 3afety-related fasteners (random sizes of bolts, studs,
and/or cap screws) and 10 nonsafety-related fasteners (random sizes of
bolts, studs,ard/orcapscrews).
Corresponding nuts (one- 4 r-one) were
also selected.
The 40 threaded fasteners were submitted to Taussig Metallurgical
Laboratory, Skokie, Illinois, for the various tests to determine
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conformance with their applicable material specifications. The ten
externally threaded safety-related fasteners were marked FC-C1 through
FC-CIO, and were subjected to tension testing. The associated nuts were
identified as Samples FC-CIN through FC-CION. All nonsafety-related
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externally threaded fasteners and nuts required hardness testing. All
40 samples were subjected to chemical analyses.
Material specifications applicable to the test samples included the
following ASME/ ASTM requirements:
Safety-Related
ASTM A193 B7/A194 2H
ASTM A193 B8/A194 2H
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ASTM A325 Tpl/A194 2H
ASTM A307 GRA/A675 GR60
ASTM A307/A194 2H
Nonsafety
ASME SAE J429 GR5/SAE J995 GR5
ASTM A325 Tpl/A325-74
3/4" Nut, ASME A194-B8
A review of the initial test results, documented in Taussig Report 78153,
dated December 30, 1987, revealed that one safety-related put
(Sample FC-C6N, A194 2:1) failed to meet the .40 percent minimum carbon
requirement of specification A194 2H.
In addition, six nons ?ty-related
bolts (Samples FC-1, 2, 6, 7, 8, and 9) and one nut (Sample FL-4N) failed
to meet ASTM /ASME specifications. The six nonsafety-related bolts failed
to meet the SAE J429 Grade 5 specification range of 25-34 Rockwell "C,"
and the carbon content of .28 .55 percent. The one nonsafety-related nut
was identified as in noncompliance with the A194-B8 specification for
hardness (60-105 Rockwell "B").
In view of the failure of the safety-related nut (Sample FC-C6N) to meet
- the carbon content of ASTM A194 specifications, the remaining nuts in
stores from the same lot were tagged as nonconforming and an additional
18 nuts (from the same lot of 48 total) were sent to the Taussig Laboratory
for metallurgical tests for proof load, hardness, and chemical aralysis.
The resulting Taussig Test Report 78575, dated January 15, 1988, indicated
that all 18 nuts met the ASTM A194 2H specifications.
In addition, the
licensee discovered that when the original 40 samples were returned from
the Taussig Laboratory, safety-related nut, Sample FC-C6N, was found in
the untested condition. Also, an extra nut originally shipped with
Sample FC-C7N was found to'have been tested twice. Sample FC-C6N was
resubmitted to the test laboratory, tested, and found to meet the
requirements for ASTM A194 2H fasteners. This information was contained
in a revised response to Bulletin 87-02, dated March 23, 1988. The
resulting retests indicate that no failures were attributed to samples
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selected from the safety-related fasteners in storage, therefore, no
further corrective action on the bulletin was anticipated or planned
relative to safety-related fasteners.
In reviewing the test data with regard to the nonsafety-related fasteners,
it appears from the test data taken that only the SAE J429 steel was found
to be in noncompliant.e with the SAE J429 Grade 5 specification.
In addition,
it was apparent from the fastener testing) data sheet (Attachment I to 0 PPD
letter LIC-88-023, dated January 19, 1988 for each sample, that the
failures occurred only from sen.ple lots of screws or nuts that were absent
of any identifiable markings (spr.cification and/or manufacturer).
In
discussing this observation wifa the cognizant licensee representative,
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the inspector was informed tnt the licensee's evaluation concluded, as
evidenced by the hardness and chemical analysis, that the unmarked screws
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or nuts ni m SAE Grade 2 rather than SAE Grade 5 as indicated by the
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licensee records ~.
It was further pointed out by the licensee representative
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that prior purchase orders for nonsafety-related fasteners did not contain.
specific material specifications nor impose.QA requirements on suppliers.
All unmarked screws or nuts have been subsequently removed from the
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warehouse.. stores. This was partially verified by sampling stock locations
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during a warehouse walkdown by the inspector, accompanied by the licensee
representative. Other corrective actions implemented include revisions to
the warehouse receiving stock locations cards to assure only clearly
identified SAE Grade-5 screws or nuts ar-e accepted at the warehouse,
and purchase orders contain more specific material specifications.
Licensee's Conclusion
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As stated in an internal memorandum, " Engineering Evaluation on CQE and
Non-CQE fasteners," dated May 2, 1988, and response letter to NRC, dated
March 23, 1988, the final results and engineering evaluations indicate
that all safety-related fasteners were within specifications and thus,
need not be subjected to further evaluation. 'The above evaluation
memorandum further -tates that piping systems which could contain
questionable fastehers would have been qualified through 15 years of
service without failure.
It is not apparent that failures have occurred
as a result of fasteners being in noncompliance. Thus, the licensee
concluded that any further evaluation of nonsafety-related fasteners was
unwarranted. During subsequent discussions with the cognizant licensee
representative, the inspector was informed that to evaluate further and
to verify each bolting application in nonsafety components would be exceedingly
burdensome, costly, and would not appear to be justifiable.
In addition,
the licensee believes that information provided in response to Bulletin 87-02
provides reasonable assurance that fasteners used at the Fort Calhoun
Station meet the requisite specifications and that operability of
safety-related components is not affected.
The licensee has performed an analysis of the requisite fastener testing
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and established an apparent cause. Corrective actions have been taken.
These licensee actions appear appropriate and no further inspection of
this matter is planned at this time.
3.
10 CFR Part 21 Review
The objective'of this area of the inspection was to determine whether
organizations and individuals subject to 10 CFR Part 21 regulations have
established and are implementing procedures and controls to ensure the
reporting of defects and noncompliance.
During the inspection, the inspector reviewed the following procedures:
Quality Assurance Plan, Section 10.5, "10 CFR 21 Reporting of
Defects and Noncompliance," Revision 3, dated August 1, 1988.
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QDP-19 " Quality Assurance and Quality Control Department Procedure,"
Revision 5, dated August 1, 1988.
QP-19. " Product Engineering Division (PED) Quality Procedure,"
Interim Revision, dated July 1, 1938.
N0D-QP-12. " Reporting of Defects and Noncompliance to the Nuclear
Regulatory Commission," Revision 3, dated April 19, 1988.
QP-26, " PED Quality Procedure," Revision 0, dated June 9, 1989.
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QP-6, " PED Quality Procedure," Revision 0, dated June 6, 1989.
gel-2, " General Engineering Instruction " Revision 1, dated July 19,
1988.
In addition to the'above review, the inspector selected three items
identified for review / evaluation applicable to potential 10 CFR 21
deportability requirements from a' listing of current items in the
review / evaluation process.
Items selected were as follows:
Item No. 89-0001, Check Valve, dated January 16, 1989.
Item No.89-003, Solenoid Valve, dated June 22, 1989.
Item No.89-006, Control Valve, dated June 26, 1989.
It was observed by the inspector that two of the items had been
previously reported to the Commission by the specific vendor, wherein
the third item (Item No.89-006) is relative 1o vendor supplied
conponents which require the licensee to revit:w the applicability to
their facility.
It appears that the items identified were consistent with the
licensee's estchlished procedures and that the information end data
appear to be factual and complete.
In addition, the findings
indicated that substantial safety issues do not exist.
No violations or devictions were identified.
4.
Exit Interview
The inspector met with Mr. A. W. Richard, Assistant Manager, Fort Calhoun
Station,, and other members of the itcensee's staff on July 28, 1989. At
this meeting, the inspector summarized the inspection findings. The
licensee did not identify any proprietary information to the inspector.
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