ML20247E498
| ML20247E498 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/1989 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Tosch K NEW JERSEY, STATE OF |
| References | |
| IEB-87-002, IEB-87-2, TAC-67948, NUDOCS 8909150298 | |
| Download: ML20247E498 (4) | |
Text
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September 6, 1989 4 ;. -
Mr.. Kent Tosch State of New Jersey Department of Environmental Protection Bureau of Nuclear Engineering L-CN 415 Trenton,'New Jersey 08625
Dear Mr.; Tosch:
SUBJECT:
' STATE OF NEW JERSEY COMMENTS ON BULLETIN 87-02, FASTENER TESTING TO-L DETERMINE CONFORMANCE WITH APPLICABLE MATERIAL SPECIFICATIONS (TAC NO.67948)
By letter dated April 8, 1988, the Bureau of Nuclear Engineering sent to Dr. Walter R. Butler comments (Attachment II of the letter) on NRC Bulletin 87-02, Fastener Testit g to Determine Conformance with Applicable Material Specifications. These comments were also discussed with Mr. Suren Singh of your staff on August 14, 1989. Enclosed is the NRC Staff's response to your C.omments.
Sincerely,
/s/
James C. Stone, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated
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. Mr.. Kent Tosch State of New Jersey Department of Environmental Protection Bureau of Nuc' lear Engineering CN 415 Trenton, New Jersey 08625
Dear Mr. Tosch:
SUBJECT:
STATE OF NEW JERSEY COMMENTS ON BULLETIN 87-02, FASTENER TESTING TO DETERMINECONFORMANCEWITHAPPLICABLEMATERIALSPECIFICATIONS(TAC NO. 67948)
By letter dated April 8, 1988, the Bureau of Nuclear Engineering sent to Dr. Walter R. Butler comments (Attachment II of the letter) on NRC Bulletin 87-02, Fastener Testing to Determine Conformance with Applicable Material Specifications. These comments were also discussed with Mr. Suren Singh of your staff on August 14, 1989. Enclosed is the NRC Staff's response to your comments.
Sincerely, James C. Stone, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated
[.
ENCLOSURE o
y 1.
Comment: Testing of 10 bolts in the safety-rele
' stock in use does not provide adequate assurance that variou.
Jats that are in the field will be covered.
In other words the warehouse stock may not represent all the heat numbers that are in the field.
Needless to say that the heat numbers cf bolts are not traceable from construction records.
Response: The purpose of Bulletin 87-02 was to gather data so the NRC Staff could determine whether or not mismarked or counterfeit fasteners were a problem in the nuclear power industry.
It was not intended to sample each and every heat number and fastener type being used in the nuclear industry. Warehouse stock was selected as the sample source because it was readily available and provided an acceptable representation of fasteners being used in the plant.
2.
Reaent:
BNE staff feels that the sample size is too small in relation to the number of bolts of questionable ASTM specs.
Response: The sample size,10 safety related and 10 nonsafety related bolts, and 10 safety related and 10 nonsafety related nuts was acceptehle to determine if a problem existed with mismarked or counterfeit fasteners. Tiie ASTM Specifications of interest listed in Paragraph 2 of Actions to be Taken represented the most commonly used fasteners and was not intended to imply these were questionable.
3.
Comment: The bulletin does not provide any resolution to discrepancies that are found upon testing of samples. The bulletin has addressed the resolution from the 11censee.
Response: All licensees are required to have a quality assurance (QA) program that conforms to 10 CFR Part 50, Appendix B.
Criterion XVI, Corrective Action, requires the program to take action to correct found deficiencies. Therefore, deficiencies found during the performance of Bulletin 87-02 were handled by the licensees' normal QA program.
4.
Comment: How will the liceasee and/or NRC ensure that the improperly marked bolts have proptr heat treatment such as solution J
annealing of ASTM a 193-B8 (to prevent stress-corrosion cracking). The tests recommended in the bulletin may not provide this assurance.
3
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' Response:.It was recognized at the time Bulletin 87-02 was issued that all attributes were not being tested. Again, it must be kept in mind that Bulletin 87-02 was looking for material substitutions (i.e. lower grade material marked and sold as higher grade material).
If a fastener were improperly marked (counterfeit) it would show up as a significant deviation from I
the applicable material specification (i.e. chemical and/or mechanical properties that were measured).
5.
Comment: The BNE staff recommends that the sample bolts be taken from the plant as well as from storage to assure that a representative sample is taken.
Response: See response to Comment 1.
6.
Comment: The test program could be similar to Bulletin 79-02 on anchor bolts.
Bulletin 79-02 was issued to correct a known problem with anchor.
bolts.Bulletin 87-02 was issued to collect data so the NRC staff could determine if a problem existed. NUREG 1349, Compilation of Fastener Testing Data Received in Response to NRC Compliance Bulletin 87-02 concludes "The results of the study did not indicate a safety concern relating to the use of mismarked or counterfeit fasteners in the nuclear industry."
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