NUREG-1402, Forwards NUREG-1402, Closeout of NRC Bulletin 88-005: Nonconforming Matls Supplied by Piping Supplies,Inc,At Folsom,Nj & West Jersey Mfg Co at Williamstown,Nj. Staff Evaluation of Response to Bulletin Closed
| ML20055C618 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/21/1990 |
| From: | Black S Office of Nuclear Reactor Regulation |
| To: | Kingsley O Tennessee Valley Authority |
| References | |
| RTR-NUREG-1402, TAC-68827, TAC-68828, TAC-R00423, TAC-R00426 IEB-88-005, NUDOCS 9005290121 | |
| Download: ML20055C618 (93) | |
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May 21, 1990 Docket Nos. 50-327 1
and 50-328 1
1 Mr. Oliver D. Kingsley, Jr Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place L
1101 Market Street Chattanooga, Tennessee 37402-2801
Dear Mr. Kingsley:
L
SUBJECT:
CLOSE0VT OF NRC BULLETIN 88 05 AND ITS SUPPLEMENTS (TAC R00426, R00423, 68827, 68828) (MPA X8-05) - SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 l
NRC Bulletin 88-05, " Nonconforming Material Supplied By Piping Supplies, Inc.,
l At Folson, New Jersey, and West Jersey Manufacturing Company At Williamstown, j
New Jersey", was issued on May 6, 1988.
The bulletin required that licensees submit information on materials supplied by Piping Supplies, Inc. (PSI) and West Jersey Manufacturing Company (WJM) and requested that they (1) ensure that these materials complied with the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code) and design specifications or were i
suitable for their intended service or (2) replace such materials.
Supplements I and 2 to the bulletin were issued on June 15 and August 3, 1988, respectively, l'
-In Supplement 2, another affiliated supplier, Chews Landing Metal Manufacturers, Incorporated (CLM), was identified.
In your letters dated August 2, August 25,- and September 26, 1988, you responded i
to the bulletin and its supplements.
In the latter letter, you stated that the WJW and PSI records for material supplied to Sequoyah identified only carbon-steel flanges.
The staff has evaluated your responses for Sequoyah and the responses from other-licensees for their plants; had meetings with Nuclear Management and Resources Council (NUMARC), Electric Power Research Institute (EPRI), and Bechtel Power Corporation; and evaluated the NUMARC testing program, generic analysis, and evaluation report dated October 27, 1988.
The staff's safety evaluation was issued as NUREG-1402, " Closeout of NRC Bulletin 88-05:
Nonconforming Materials Supplied by Piping Supplies, Inc., at Folsom, New Jersey, and West Jersey Manufacturing Company at Williamstown, New Jersey", dated February 1990.
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Mr. Oliver D. Kingsley, Jr. Enclosed is a copy of NUREG-1402 which closes out the bulletin and its Supple.
ments 1 and 2.
The staff concluded that (1) the analytical procedures used to qualify the non-conforming parts and the analysis results provide an adequate basis for resolving the staff's concerns regarding fittings and flanges; (2) even though the materials supplied by PSI, WJM, and CLM with falsified certifiedmaterialtestreportsdonotmeettheASMECode,(theiruseisanacceptable alterj i
ities in response to Bulletin 88-05 regarding fittings and flanges can be closed for all operating plants; and (4) licensees should evaluate the use of product forms other than fittings and flanges.
NUREG-1402 is the basis for closure of the activities specified in the bulletin for fittings and flanges for all plants having a full power license including Sequoyah. As stated in the report, some followup activities will be required for a few operating plants that received nonconfonning product forms other than fittings and flanges.
These materials are listed in Supplement 2 of the bulletin and are (nown to have been shipped to the Perry and Palo Verde plant sites and may have been shipped to other sites.
For operating plants that did receive such material, licensees should determine its location and perform an engineering evaluation where it was used in safety.related applications.
These evaluations are to be performed in accordance with 10 CFR 50.59 but are not required to be reviewed by the NRC for approval.
These evaluations will be subject to audit and inspection at the discretion of the NRC staff.
In your letter dated September 26, 1988, however, you stated that you had not identi.
fied that such material had been supplied to Sequoyah.
This, therefore, closes out the staff's evaluation of your responses to Bulletin 88 05 and its supplements.
If you have any questions, please contact Jack Donohew, Sequoyah Project Manager, at 301-492-0703.
Sincerely, Original signed by Thierry M. Ross for Suzanne C. Black, Assistant Director for Projects TVA Projects Division Office of Nuclear Reactor Regulation
Enclosure:
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. Mr. Oliver D. Kingsley, Jr. cc:
Mr. Marvin Runyon, Chairman Mr. Joseph Bynum, Acting Site Director Tennessee Valley Authority Sequoyah Nuclear Plant 3
ET 12A 7A Tennessee Valley Authority 400 West Sumit Hill Drive P. O. Box 2000 Knoxville, Tennessee 37902 Soddy Daisy, Tennessee 37379 Mr. C. H. Dean, Jr., Director Mr. Mark J. Burzynski l
i Tennessee Valley Authority Site Licensing Manager ET 12A 11A Sequoyah Nuclear Plant 400 West Sumit Hill Drive P. O. Box 2000 Knoxville, Tennessee 37902 Soddy Daisy, Tennessee 37379 Mr. John B. Waters, Director County Judge Tennessee Valley Authority Hamilton County Courthouse ET 12A 9A Chattanooga, Tennessee 37402 400 West Sumit Hill Drive Knoxville, Tennessee 37902 Regional Administrator, Region 11 U.S. Nuclear Regulatory Conunission Mr. W. F. Willis 101 Marietta Street, N.W.
Chief Operating Officer Atlanta, Georgia 30323 ET 120 16B 400 West Sumit Hill Drive Mr. Kenneth M. Jenison Knoxville, Tennessee 37902 Senior Resident Inspector Sequoyoh Nuclear Plant General Counsel U.S. Nuclear Regulatory Comission Tennessee Valley Authority 2600 Igou Ferry Road 400 West Summit Hill Drive Soddy Daisy, Tennessee 37379 ET llB 33H Knoxville, Tennessee 37902 Mr. Michael H. Mobley, Director Division of Radiological Health Mr. Dwight Nunn T.E.R.R.A. Building, 6th Floor Vice President, Nuclear Engineering 150 9th Avenue North Tennessee Valley Authority Nashville, Tennessee 37219-5404 6N 38A Lookout Place 1101 Market Street Dr. Henry Myers, Science Advisor Chattanooga, Tennessee 37402-2801 Committee on Interior and Insular Affairs Dr. Mark 0. Medford U.S. House of Representatives Vice President and Nuclear Washington, D.C.
20515 Technical Director Tennessee Valley Authority Tennessee Valley Authority 6N 38A Lookout Place Rockville Office Chattanooga, Tennessee 37402-2801 11921 Rockville Pike Suite 402 Mr. Edward G. Wallace Rockville, Maryland 20852 Manager, Nuclear Licensing and Regulatory Aff airs Tennessee Valley Authority SN 157B Lookout Place Chattanooga, Tennessee 37402-2801 l
L
O Mr. Oliver D. Kingsley, Jr. :
Enclosed is a copy of NUREG-1402 which closes out the bulletin and its Supple-ments 1 and 2.
The staff concluded that (1) the analytical procedures used to qualify the non-conforming parts and the analysis results provide an adequate basis for resolving the staff's concerns regarding fittings and flanges-(2)eventhoughthematerialssuppliedbyPSI,WJM,andCLMwithfalsifIed certified material test reports do not meet the ASME Code, their use is an acceptable alternative in accordance with 10 CFR 50.55a(a)(3)(ii); (3) activ-ities in response to Bulletin 88-05 regarding fittings and flanges can be closed for all o)erating plants; and (4) licensees should evaluate the use of product forms otler than fittings and flanges.
NUREG-1402 is the basis for closure of the activities specified in the bulletin for fittings and flanges for all plants having a full power license including Sequoyah.
As stated in the report, some followup activities will be required i
for a few operating plants that received nonconforming product forms other than fittings and flanges.
These materials are listed in Supplement 2 of the bulletin and are known to have been shipped to the Perry and Palo Verde plant sites and may have been shipped to other sites.
For operating plants that did receive such material, licensees should determine its location and perform an engineering evaluation where it was used in safety-related applications.
These evaluations are to be performed in accordance with 10 CFR 50.59 but are not required to be reviewed by the NRC for approval.
" - -" " " " '^-'
ne'-' " 4 th: "C ' r ;; r d These evaluations will be subject to audit and inspection at the_ discretion of the NRC staff.
In your letter dated September 26, 1988, however, you stated that you had not identified that such I
material had been supplied to Sequoyah.
This, therefore, closes out the staff's evaluation of your responses to Bulletin 88-05 and its supplements.
If you have any questions, please contact Jack Donohew, Sequoyah Project Manager, at 301-492-0703.
Sincerely, Suzanne C. Black, Assistant Director forProjects TVAProjectsDivision Office of Nuclear Reactor Regulation
Enclosure:
NUREG-1402 gl/ f[l h '
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i NUREG-1402 l
Closeout of NRC Bulletin 88-05:
Nonconforming Materials Supplied by Piping Supplies, Inc.,
at Folsom, New Jersey, and West Jersey Manufacturing Company at Williamstown, New Jersey u
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation
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NUREO-1402 i
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Closeout of NRC Bulletin 88-05:
l Nonconforming Materials Supplied by Piping Supplies, Inc.,
at Folsom, New Jersey, and West Jersey Manufacturing Company at Williamstown, New Jersey i
Manuscript Completed: February 1990 Date Published: February 1990 Omce of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 O
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ABSTRACT This report documents the activities that led to the closecut of U.S. Nuclear j
Regulatory Commission (NRC)Bulletin 88-05, which was issued on May 6, 1988.
The bulletin required that licensees submit information on materials supplied by Piping Supplies, Inc. (PSI) and West Jersey Manufacturing Company (WJM).
and requested that they (1) ensure that these materials complied with the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code ( ASME Code) and design specifications or were suitable for their intended service or (2) replace such materials.
Supplements 1 and 2 were issued on June 15 and August 3, 1988, respectively.
In Supplement 2 another affiliated supplier, Chews Landing Metal Manufacturers, Incorporated (CLM), was identified.
The staff concluded that (1) the analytical procedures used to qualify the non-conforming parts and the analysis results provide an adequate basis for resolving the staff's concerns regarding fittings and flanges; (2) even though the mate '
rials supplied by PSI, WJM, and CLM with falsified certified material test reports do not meet the ASME Code, their use is an acceptable alternative in accordance with Section 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations; (3) activities in response to Bulletin 88-05 regarding fittings and flanges can be closed for all operating plants; and (4) licensees should evaluate the use of product forms other than fittings and flanges.
l l
NUREG-1402 iii 02/05/90
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CONTENTS P,a,gg ABSTRACT..............................................................
- iii 1
INTRODUCTION.....................................................
1-1 F
2 DISCUSSION.......................................................
2-1 2.1 Issuance of HRC Bulletin 88-05 and Supplements 1 and 2......
2-1 2.2 Receipt and Review of. Licensee Responses....................
2-3 2.3 NUMARC's Programs for Testing and Generic Analysis..........
2-4 2.4 NRC Visit to Alvin W. Vogtle Nuclear Plant..................
28 2.5 NRC Meeting With NUMARC, EPRI, and Bechte1..................
2-10 2.6 NUMARC's Supplemental Generic Analysis Report...............
2-11 2.7 Staff Evaluation of Other Product Forms...............,.....
2-14 2.8 Staff Evaluation of Hardness Correlation....................
2-15 2.9 Brookhaven National Laboratory's Independent Testing Activities..................................................
2-16 2.10 Responses From Near-Term Operating License Applicants.......
2-18 3
CONCLUSIONS......................................................
3-1 4
REFERENCES.......................................................
4-1 APPENDIX A - NRC BULLETIN 88-05 AND SUPPLEMENTS 1 AND 2 APPENDIX B -
SUMMARY
OF SIGNIFICANT LICENSEE RESPONSES 1
TO NRC BULLETIN 88-05 APPENDIX C - CHRONOLOGY OF MEETINGS, TRIPS, CORRESPONDENCE, AND DOCUMENTS PERTAINING TO NRC BULLETIN 88-05 AND ITS SUPPLEMENTS NUREG-1402 v
02/05/901 i
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., e CONTENTS (Cont'd.)
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APPENDIX D - PRINCIPAL CONTRIBUTOR $
j APPENDIX E - ABBREVIATIONS i
TABLE i
2.1 Status of License Activities.....................................
2-4
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1 INTRODUCTION In early 1988, the U.S. Nuclear Regulatory Commission (NRC) obtained copies of certified material test reports (CMTRs) for material supplied to the nuclear industry by Pipeline Supplies, Inc. (PSI), Folsom, New Jersey, and West Jersey j
Manufacturing Company (WJM), Williamstown, New Jersey, that contained false i
information.
A domestic forging company's letterhead was used for a number of CMTRs to certify that commercial grade, foreign steel hett the requirements of Section III, Subarticle NCA-3800, of the American Socirsty of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code).
No evidence existed that PSI or i
I WJM had performed or had a subcontractor perform the testing required by Sectior)
III to upgrade the commercially produced steel designated on these falsified CMTRs.
The information avails le indicated that WJM had started supplying ASME Code components to the nuclear industry in 1976, both directly as well as through intermediaries, and that PSI had started supplying ASME code components to the nuclear industry, directly and through intermediaries, in 1985.
In addition, WJM held an ASME Quality System Certificate (QSC-385) as a material manufacturer from November 30, 1979, to November 30, 1985.
The NRC toncluded that potential generic safety implications existed at facilities that either had received direct shipments of pipe fittings and flanges furnished by PSI or WJM or had received piping subassemblies and other components from holders of ASME certificates of authorization or other subcontractors that had incorporated materials supplied by PSI or WJM.
l In response to these developments, the NRC initiated an in-depth program to evaluate the potential generic safety implications resulting from the use of material supplied by PSI or WJM in safety-related systems of the licensees' plants by issuing NRC Bulletin 88-05 and Supplements 1 and 2 between May and August of 1988.
l This report presents the staff's safety evaluation of licensee programs to locate, test, and analyze these materials and to resolve the staff's concerns NUREG-1402 1-1 03/13/90
- 0 I
regarding the qualification for service of nonconforming material described in
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WRC Bulletin 88-05.
1 Appendix A contains copies of NRC Bulletin 88-05 and its supplements. Appendix B contains the summary of significant licensee responses to NRC Bulletin 88-05 that was prepared by the NRC staff and its consultant, Brookhaven National Laboratory. Appendix C is a chronology of meetings, trips, correspondence, and f
documents pertaining to the bulletin and its supplements.
Appendix 0 lists the
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princ4 pal contributors to this report. Appendix E lists the abbreviations used in the report.
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k NUREG-1402 12 02/05/90
3 2 DISCUSSION 2.1 Issuance of NRC Bulletin 88-05 and Supplements I and 2 l
The NRC issued NRC Bulletin 88-05 on May 6, 1988, to all holders of operating i
licenses and construction permits for nuclear power reactors requiring that li-censees submit information on materials supplied by PSI and WJM and requesting that they (1) take actions to ensure that these materials complied with the ASME Code and design specifications or were suitable for their intended service or (2) replace such materials.
i The NRC staff ituka Supplement I to NRC Builetin 88-05 on June 15, 1988, after Carolina Power & Light (CP&L) informed the staff on June 10, 1988, that two flanges from the warehouse that had been supp'ied by WJM had been tested at the Shearon Harris Nuclear Power Plant.
The CP&L test results did not match those
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reported on WJM's certified material test reports (CMTRs) and did not meet the tensile and yield strength requirements delineated in the SA-105 specification of the ASME Code for SA-105 material.
The required minimum tensile strength is 70 kips per square inch (ksi); the measured tensile strengths, however, were 45 ksi and 46 ksi.
The tensile strength reported on the CMTR was 77 ksi.
The required minimum yield strength is 36 ksi; the measured yield strengths, however, were 27 ksi and 31 ksi.
The yield strength reported on the CMTR was 50 ksi.
t Measured chemistry composition also did not comply with the specification; nota-bly, percent carbon was very low - 0.045, and percent manganese was 0.32 (the required range is 0.6 to 1.05).
I Supplement I narrowed the scope of review from ASME and American Society for Testing and Materials (ASTM) " materials" to ASME and ASTM fittings and flanges.
Because it had been verified that flanges that did not comply with ASME and ASTM l
Specifications had been supplied to the nuclear industry, the time frames for l
certain actions were also modified by this supplement.
Licensees were requested to retain nonconforming materials until advised further by the NRC.
Nonconform-ing materials were to be segregated to ensure that they were not inadvertently used.
Licensees also were encouraged to report the results of tests of flanges NUREG-1402 2-1 02/05/90
and fittings supplied by PSI and WJM to the Institute of Nuclear Power Operations Nuclear Network for dissemination to the industry, i
The NRC staff issued Supplement 2 to NRC Bulletin 88-05 on August 3,1988, af ter it met with representatives of the Nuclear Management and Resources Council (NVMARC)onJuly 22, 1988, to discuss the status of licensees' actions in response to Bulletin 88-05 and Supplement 1.
During this meeting, NUMARC pre-sented information on licensee and NUMARC and Electric Power Research Insti-tute testing and evaluation methodology for PSI and WJM flanges.
NUMARC summa-rized this information in a letter to the NRC dated July 25, 1988, and submitted a detailed report and proposal on July 29, 1988.
On the basis of the reported measurement and analytical results, the NRC staff concluded that it was appropriate for full power licensees to suspend, temporar*
ily,thefieldmeasurements, testing,recordsreview,andpreparationofjusti-fications for continued operations (JCOs) that were request 9.1 by Bulletin 88-05 and Supplement I until further notice.
Addressees that hat not received a full-power' license were requested to continue the in situ testing and the records review.
The time frames remained as specified in the original bulletin, that is, January 1, 1976, to the present.
During the temporary suspension of the requested activities, the NRC staff reviewed the measurement and test data and the results of analyses and determined the extent to which further actions were appropriate to ensure the continued safe operation of nuclear power plants.
On July 22, 1988, the NRC staff completed its review of PSI, WJM, and Chews Landing Metal Manufacturers Incorporated (CLM)* purchase order and invoice records. On the basis of this review, the staff determined that PSI, WJM, and CLM had-provided product forms in addition to flanges and fittings.
The staff identified the additional product forms and compiled a list of nuclear power plants that were possible recipients of PSI, WJM, and CLM materials.
Copies of NRC Bulletin 88-05 and Supplements 1 and 2 are contained in Appendix A.
- In Supplement 2 of NRC Bulletin 88 05, CLM was identified as being affiliated with PSI and WJM.
NUREG-1402 2-2 02/05/90
g 2.2 Receipt and Review of Licensee Responses Licensees of 110 units located at'73 plant sites submitted responses in accord-ance with the reporting requirements of NRC Bulletin 88-05.
The NRC staff and consultants from Brookhaven National Laboratory (BNL) reviewed the responses and summarized the significant results in tabular form as shown in Appendix B.
In the summary table the licensee responses are categorized into three primary areas of interest:
(1) Records Search and Identification (a) Total number of fittings and flanges received from WJM, PSI, and CLM (b) Number installed in safety or non-safety-related systems (c) Number in the warehouse (d) Number unaccounted for (2) Test Results (a) Number of fittings and flanges tested l
Number with Brinell hardness number (BHN) less than 137 1
Number with BHN greater than 187
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(b) Number tested for chemical properties and the number found to be acceptable (c) Number tested for physical properties and the number found to be acceptable (3) Engineering Evaluations l
(a) Number of JCOs for accessible and inaccessible fittings and flanges NUREG-1402 2-3 02/05/90 o
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(b) Engineering evaluation method used The results of the detailed review of licensee responses indicated that approximately 8000 flanges and fittings had been procured from WJM, PSI, and
)
CLM and installed in safety-related systems of those plants reporting numerical data.
Several of the licensees did not report numerical results because Supple-ment 2 had suspended search activities.
The status of licensee activities reported in each of the three primary areas of interest is shown in Table 2.1.
A detailed breakdown for each response is contained in Appendix B.
Table 2.1 Status of licensee activities Records search and Engineering '
Status identification Testing evaluations Number of plant sites for which reporting is complete 53 40 35 Number of plant sites for which reporting is incomplete 20 33 38 The review of the responses indicated that, in general, most licensees were responsive to the requirements of NRC Bulletin 88-05.
The NRC staff and its consultants concluded that most licensees were concerned about nonconforming material at their plants and were engaged in activities requested by the bul-
.letin and Supplement I before Supplement 2 was issued.
2.3 NUMARC's Programs for Testing and Generic Analysis At a meeting held at NRC headauarters at One White Flint North, Rockville, Maryland, on July 22, 1988, NUMARC presented its program to address NRC Bulletin 88-05 relative to the NRC requirements for field testing and justifications for continued operation (JCOs).
In response to the staff's concern about the proper use of Equotip hardness readings taken on material at elevated temperature, EPRI reported that it had developed a' correlation to corre:t the Equotip results to the equivalent values NUREG-1402 2-4 02/05/90
1 at normal room (70*F) temperature.
This correlation was developed through
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testing performed by EPRI and was promulgated to.the industry by NUMARC on
)
July 12,1988.
After reviewing the methodology of the correlation, the NRC staff and its consultants were satisfied that the concern with respect to the proper use of elevated-temperature Equotip readings had been resolved.
NUMARC also reported that Bechtel had developed, through the NUMARC program to
]
address NRC Bulletin 88-05, a generic quantitative analysis methodology support-ing permanent installation of ferritic components that cannot be shown to meet J
the current NRC requirement of a Brinell hardness number (BHN) of 137 for SA-105 J
material.
The Bechtel report provided allowable values on a case-by-case basis for different types of flanges and fittings, schedules, and sizes.
NUMARC and EPRI stated that the purpose of the generic analysis and evaluation '
report (the Bechtel report) was to provide a basis for justification of suita-bility for indefinite service without replacement of potentially substrength material supplied by WMJ or PSI as identified in NRC Bulletin 88-05 and its sup-piements.
Licensees had conducted field tests to identify substrength components among these suspect items.
When properties could not be confirmed, determina-tion of suitability for indefinite service was based on conservatively assuming lower than specified strength values for suspect material and demonstrating that code design rules were satisfied with the assumed values.
If generic accepta-bility of certain items could not be established by the tables of the generic
-report or other elements of the NUMARC programs, the report provided guidance L
on plant-specific evaluations.
L The methodology used in the generic report was based on the following L
assumptions:
Conservative strength values of suspect material that are lower than specified code minimum values were assumed for the purpose of the generic analysis.
L Compliance with code design rules was generically established using conservative bounding assumptions.
l NUREG-1402 2-5 02/05/90 l
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When identification of a material c.0uld not be confirmed by field tests, the analysis assumed lower strength material properties.
2 In the meeting held on July 22, 1988, NUMARC also presented an analysis of util-j ity and laboratory test data obtaineo to date and, in a letter to Dr. Thomas
.curley of the NRC dated July 25, 1988, requested that licensee activities rela-tive to NRC Bulletin 88-05 and Supplement 1 be suspended.
In the letter, NUMARC committed to provide a written report to the NRC staff reflecting the test data
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and conclusions presented at the July 22 meeting and to provide quantitative statistical evaluations relative to the conclusions presented at the meeting.
On July 29, 1988, NUMARC provided the report to the NRC staff, which was included as Attachment 1 to NRC Bulletin 88-05, Supplement 2.
NUMARC's generic testing program in response to NRC Bulletin 88-05 included comprehensive laboratory testing of suspect items contributed by utilities and utility generated data of destructive laboratory tests and in situ tests of installed suspect items.
NUMARC laboratory test methods followed ASTM standards for tensile testing to produce values for ultimate tensile strength, yield stress, percent elongation, and percent reduction of area.
Tensile strength correlations were developed on the basis of Equotip testing.
For the chemical analysis, spectrographic analy-sis and portable X-ray fluorescence analysis methods were used.
All laboratory testing equipment was calibrated to appropriate standards.
Utilities principally used the Equotip device to conduct hardness testing of
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installed or warehouse items.
Other hardness test devices also were used in a few instances.
For austenitic stainless steel items, the principal test method was a simple magnetic check.
Some alloy analysis and replication metallography also were performed.
l At the time of the July 22, 1988, meeting, NUMARC had developed generic l
laboratory test data for 123 items.
The utilities provided data on 1334 items l
l-NUREG-1402 2-6 02/05/90
L 8
that had undergone field hardness testing and 108 tensile strength results.
NUMARC also provided the NRC staff with computer discs and printouts of the results.
The NRC staff and its consultants reviewed the Bechtel generic analysis and evaluation report submitted by NUMARC at the meeting.
Results of the review indicated the following:
(1) The generic analysis methodology is acceptable to the NRC staff for pres-sure and moment qualification of American National Standards Institute (ANSI) B16.11 fittings.
(2) The generic analysis methodology is acceptable to the NRC staff for pres-surequalificationofANSIB16.5flangedjoints.
(3) The generic analysis methodology is not acceptable to the NRC staff for moment qualification of ANSI B16.5 flanges, other than blind flanges.
The staff's concerns with respect to the applicability of the generic analysis methodology to moment qualification of ANSI B16.5 flanges were subsequently resolved by NUMARC in its supplemental report discussed in Section 2.6.
NUMARC presented its final report to the NRC staff at a meeting held at NRC headquarters at One White Flint North on October 27, 1988.
The report summarized the results of field testing, laboratory testing, and stress analyses performed in response to NRC Bulletin 88-05.
The report summarized the results of approximately 7100 field tests as well as performance or analysis of more than 1300 laboratory tests of samples of the suspect components and showed that for a large percentage of the components tested, test results indicated that they were the correct materials as specified in the ASME Code or ASTM standards.
The report identified 25 carbon steel blind flanges (out of 404 tested) that did not meet material specifications for tensile strength.
These blind flanges
. exhibited tensile strengths (in some cases inferred from hardness testing) of NUREG-1402 2-7 02/05/90
about 45 tsi.rather than the A5ME Code requirement of 70 ksi for SA-105 carbon steel. Metallurgical analysis indicated that these flanges were made of low carbon steel plate rather than the required SA-105 forgings.
For blind flanges, the stresses of concern are limited to pressure and boltup loads. The generic anclysis and evaluation report prepared by Bechtel under.
the NUMARC program and previously submitted to the NRC staff stated that, for blind flanges, tensile strengths of about 45 ksi are sufficient to accommodate stress allowable values with margin. The staff and its consultants reviewed the generic analysis and evaluation report and found that HUMARC had resolved-the concern with respect to acceptability for service of the low-material-strength blind flanges.
The staff and its consultants concluded that sufficient testing had been per-formed by NUMARC and the licensees to develop confidence that the scope and nature of the problem had been identified and addressed.
2.4 NRC Visit to Alvin W. Vogtle Nuclear Plant The NRC staff and its consultants from BNL visited Georgia Power' Company's Vogtle plant located in Waynesboro, Georgia, on August 22-23, 1988.
More non-conforming material had been found at the Vogtle plant than at any other plant site. The purpose of the visit-was to observe field procedures relative to that licensee's capability to respond to NRC Bulletin 88-05 and to discuss other pertinent problems and concerns.
The NRC staff and'its consultants discussed the licensee's plan for. Vogtle in response to NRC Bulletin 88-05 and requested details about the status and pro-cedures of its records search and identification, testing, and engineering eval-uations prog T s.
In response, Vogtle personnel demonstrated the Equotip hard-ness measuring equipment and conversion-to-tensile-strength procedure. The staff and its consultants visited the diesel generator building where field per--
sonnel demonstrated the procedure and took hardness readings on several flanges.
They went to the containment of Unit 2 where they inspected fittings supplied by PSI and WJM that had been installed in a Class 1 piping system.
NUREG-1402 2-8 02/05/90
,U 6
The NRC consultants reviewed several JCOs and stress calculation packages.
For fittings, such as half couplings, the procedure used at Vogtle is to determine the u t mate tensile strength (UTS).from Equotip measurements.
The adjusted li allowable value, which was assumed to be one-fourth of the UTS, was compared to the allowable value used in the analysis of the pipe (SA-106, Grade B) at oper-ating temperature.
If the adjusted' allowable value was found to be greater than that used in the analysis, the fitting was ruled to be acceptable; if the adjusted allowable value was found to be less than that used in the analysis, the calculated stresses in the pipe at the fitting from ASME Code,Section III equations were compared to the lower adjusted allowable value.
The licensee reviewed flanges for acceptability in regard to both pressurt and moment capacity.
The NRC staff found that the procedure for assessing flange pressure capacity was similar to that described above for fittings.
The-procedure used for assessing flange moment capacity was the same as that pro-posed by NUMARC where the flange noment capacity is calculated using the equa-tions in Subarticle NC-3658.3 of Section III of the ASME Code and compared to actual values.
The NRC staff and its consultants found that the engineering evaluations reviewed appeared to be consistent with NUMARC's methodology land that documentation and traceability were good. Where values of stresses in the pipe were calculated by computer, the values shown in the evaluation sheets were obtained from the-computeroutputandwererelativelylowevenwhencomparedwiththeadjusted (reduced) allowable values.
As a result of their visit to Vogtle, the staff and its consultants obtained a more detailed understanding of the scope, procedures, and methodology used at Vogtle in response to NRC Bullet'n 88-05.
They observed personnel locating, identifying, and testing nonconfor;ning material and were shown the analytical procedures and JCOs used at Vogtle to evaluate nonconforming components and to demonstrate adequacy for service in safety-related systems.
The information collected by the staff and its consultants at Vogtle provided additional data points for evaluating and verifying NUMARC's testing and generic NUREG-1402
- 2-9 02/05/90
analysis programs.
The staff and its consultants found that the test and engi-neering evaluation results at Vogtle were consistent with and confirmed the findings reported by NUMARC.
2.5 NRC Meeting With NUMARC, EPRI, and Bechtel NUMARC presented Bechtel's generic analysis and evaluation report and methodology to the staf f at meetings held on July 22 and October 27, 1988.
After reviewing the report, the NRC staff and its consultants generated 14 questions _in regard to.the report.
To resolve these technical issues, the staff and its consultants conducted an audit at the Bechtel office in San Francisco on November 16 and 17, 1988, to review in detail Bechtel's generic analysis and evaluation report and the results of tests sponsored by Bechtel and EPRI.
i On November 16, 9 88, the staff met with representatives of Bechtel, NUMARC, and-EPRI.
At that.aeeting Bechtel provided responses to the 14 staff questions.
The staff was shown typical calculations that demonstrated the methodology and as-sumptions used by Bechtel in generating the tabular values.
In addition, the staff was shown typical flange evaluations from three near-term operating license plants:
Limerick Generating Station, Unit 2; South Texas Project, Unit 2; and
-Vogtle, Unit 2.
The staff-questioned Bechtel about its assumption that the yield strength of the tested material is one-half of the ultimate tensile strength.
Bechtel determined the yield-to-ultimate strength ratio from the results of tests on the nonconforming material. The results showed that of-489 tests, the ratio
~
was greater than 0.5 for 446 specimens and slightly less than 0.5 for 43 speci-mens.
For those specimens with ratios less than 0.5, the lowest ratio was 0.43 and the-average was approximately 0.47.
The responses provided by Bechtel to the staff's questions increased the staff's concerns with regard to the adequacy of the assumptions and conservativeness of the methodology in the generic' analysis and evaluation report to provide assur-ance that the nonconforming material is suitable for service.
In particular, the staff and its consultants raised additional questions with regard to (1) several non-bounding assumptions that appeared to be nonconservative, (2) the exclusion NUREG-1402 2-10 02/05/90
of abnormal loading evaluations, and (3) the basis for the evaluation (e.g.,
rules given in-the ASME Code that were adjusted for below-minimum material properties).
The staff and its consultants determined that the responses and information provided by Bechtel at the meeting were insufficient to demonstrate the adequacy of the generic analysis and evaluation report to evaluate the fitness for service of nonconforming components and that additional information was necessary in order to complete the evaluation, i'e staff decided to concentrate most of the remaining review' effort on the generic stress analysis of the nonconforming components in order to determine their fitness for the applicable service conditions.
In letters to NUMARC dated December 9, 1988, and February 15, 1989, the NRC staff. described the remaining major areas of concern in addition to several lesser issues, which the staff requested that NUMARC resolve in a revised report or supplement.
The staff's major areas of concern were (1) acceptability of nonconforming components for known actual plant service loadingst (2) conserva-tiveness of the basic assumptions used to develop the methodology, and (3) ade-quacy of the generic analysis for abnormal loadings such as maximum internal fluid pressure and operating basis and safe shutdown earthquakes. With regard to assessing the acceptability of substrength components for known actual service loadings at operating plants, the staff requested that NUMARC evaluate a repre-sentative cross-section of nonconforming components from at least three plants:
one high seismicity plant, one plant of older design (circa 1960's), and one l,,
plant with many suspect components, and that all three plants be designed by different architect / engineer firms. The letter to NUMARC dated February 15, 1989, also contained the NRC staff position regarding the use of nonconforming warehouse material.
The NRC staff stated that before installation in safety-
.related applications, warehouse material must be screened by hardness testing and must be qualified by tensile and chemical tests of material from the same heat.
2.6 NUMARC'S Supplemental Generic Analysis Report As discussed previously, on the basis of its review of the generic analysis and evaluation report and associated analytical procedures, its meeting with NUMARC, i
NUREG-1402 2-11 03/13/90
4 EPRI, and Bechtel, and its review of licensee responses'from operating and near-term operating license plants, the staff determined that the information that had been provided by NUMARC was insufficient to demonstrate the adequacy of the nonconforming components.
The letters to NUMARC from the staff dated December 9, 1988, and February 15, 1989, contained specific comments and requests for addi-tional information.
NUMARC responded to these requests on August 30 and November 28, 1989, with a supplemental generic analysis report,
,~.
In response to the staff's request that a representative cross-section of nonconforming components from three plants be evaluated using the generic analy-sis methodology in order to assess the acceptability of suspected components, NUMARC analyzed 153 flanges selected from one high seismicity plant, one plant of older design (circa 1960's), and one plant with many suspect components.
Diablo Canyon Nuclear Power Plant, Units 1 and 2, Zion Nuclear Power Station, Units 16nd 2, and Limerick Generating Station, Unit 2, were chosen as being representative of these cases, respectively, while satisfying the requirement that all three plants be designed by different architect / engineer firms.
For the purpose of this analysis, each evaluated flange was conservatively assumed to possess the lowest bound of tensile strength determined from the NUMARC laboratory tests (61.6-ksi for non-blind flanges).
Of the 153 flanges, 134 were qualified directly by application of the generic analysis methodology and 19 were qualified by specific analysis using ASME Code design rules (as specified by the generic analysis methodology).
No concerns regarding stress were revealed by this analysis.
Moreover, the 134 flanges that were evaluated by direct application of the generic analysis methodology were also re-evaluated using ASME Code design rules to provide additional verification of the applica-bility of-the generic analysis methodology.
Again, no concerns regarding stress were revealed. Additional conservatism is reflected in the fact that the 95/95 statistical confidence level could have been maintained with up to three deviations in the selected population, but Zero deviations were observed.
In addition,-in the letters dated December 9, 1988, and February 15, 1989, the NRC staff requested that NUMARC evaluate certain assumptions used to calculate moment loads in its generic stress analysis methodology and show that they were NUREG-1402 2-12 03/13/90
i bounding with a 95-percent confidence level.
These assumptions were evaluated
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in NUMARC's supplemental report and, after review, the staff found them to be conservative with the required level of confidence.
.In the letters dated December 9,1988, and February 15, 1989, the NRC staff also requested that NUMARC evaluate abnormal loadings and demonstrate that they met appropriate ASME Code service stress limits.
The staff found that the generic analysis methodology was conservative in this regard with the specified 95/95 confidence level.
In a letter to NUMARC dated November 2, 1989, the NRC staff submitted the results of its detailed review of the supplemental generic analysis report, which was
- provided in response to the NRC staff concerns outlined in the letters dated December 9, 1988, and February 15, 1989.
The staff and its consultants deter- >
mined that the report was generally responsive to the staff concerns.
The staff, however, requested that NUMARC do the following:
(1) Show that 3 unacceptable flanges out of a population of 153 flanges provide a 95/95 statistical confidence level as stated throughout the supplemental generic analysis report.
(2)- Provide the correct design pressure for-flanges 33-36 in Table 3-2 (Zion).
These flanges were identified as 150 pound-class flanges used for a design
. pressure of 600 pounds per square inch gauge (psig).
HUMARC responded to the NRC letter of November 2, 1989, on November 28, 1989.
It responded to Item 1 with an enclosure that provided the calculational methodology used to arrive at the stated conclusion.
Using this methodology, NUMARC deter--
mined that the chosen sample size was acceptable for a population of more than 10,000 items, with an acceptance criterion of up to three deviations.
In re-sponse to Item 2, NUMARC reported that the 600 psig provided as the design pres-sure in the report is the highest design pressure for the system in which.these flanges are located.
The design pressure for these specific flanges is 192 psig.
-The staff found NUMARC's responses satisfactory and determined that all questions with respect to the supplemental generic analysis report and associated analyti-cal procedures had been resolved.
The staff is satisfied that application of NUREG-1402 2-13 03/13/90
the generic analysis to nonconforming fittings and flanges provides a 95 percent confidence that 95 percent of the components are structurally adequate for their intended service.
2.7 Staff Evaluation of Other Product Fo'rms In addition to fittings and flanges, Supplesent 2 of the bulletin listed other product forms that were supplied by PSI, WJM, and CLM.
Included were items, such as lugs, that could have been welded or otherwise attached as a support to a plant safety-related piping system. This is of potential concern to the staff because any substrength material in the piping supports could degrade the overall piping system.
The supplemental generic analysis report discussed in Section 2.6 considered only fittings and flanges and did not include these other product forms.
How-ever, staff believes that additional generic stress analysis is not warranted for the following reasons:
(1) The design rules for piping supports provide for lesser allowable stresses with respect to the _specified material yield stress than do the design rules for piping.
Since the design rules for piping were used for the evaluation of fittings and flanges, the determination of the reliability of the suspect '
fittings and flanges should ensure an equal or better reliability-of the-other suspect product forms.
(2) -These other product forms are not part of the pressure boundary.
If a few piping support components yield or f ail, there would most likely be suffi-cient margin in the other supports and piping to ensure the pressure bound-ary integrity of the system. This is not true for the piping components, such as fittings and flanges, that actually form the pressure boundary.
The use of these other product forms in safety-relateJ piping systems appears to be much less widespread than the use of fittings and flanges.
The list pro-vided in Supplement 2 indicates that unique or special orders of some of these materials were shipped to two plant sites, Perry Nuclear Power Plant and Palo Verde Nuclear Station.
Other plants may have received relatively small quanti-ties of these materials. With the exception of Perry and Palo Verde, licensees HUREG-1402 2-14 03/13/90 i
_.. __)
5 who determine that these materials were received at their plant sites should determine the location of these materials and confirm their bcceptability for service where they were used in safety-related applications.
These evaluations do not have to be submitted to the NRC for review and should be performed in accordance with Section 50.59 of Title 10 of the Code of Federal Regulations (10 CFR).
Perry and Palo Verde both received large quantities of shear-lugs and other product forms supplied by WJM, PSI, or CLM.
The staff will require that the licensees for these two plants perform an evaluation of the application of t
these other product forms and submit the evaluation for staff review, 1
12. 8 StaffEvaluationct_HardnessCorrelation The staff evaluated the relationship between measured hardness and tensile strength-for material supplied in accordance with the SA-105 specification of i
the ASME Code, which represented the largest portion of the carbon steel mate-rial supplied by PSI, WJM, and CLM.
Other carbon steel materials supplied in.
accordance with the SA-181, SA-234, or SA-350 specifications are similar to SA-105 material with regard to the hardness-to-tensile-strength relationship.
The SA-105 specification requires that the material conform to the chemical requirements and that an analysis of each heat of steel be performed. The pur-chaser is allowed to make a product analysis of supplied forgings, in which case the chemistry requirements must be met.
The specification requires that speci-mens for mechanical property testing be obtained from production forgings after heat treatment; separately forged test blanks are allowed.
One tension test must be made for each heat and for each heat-treating furnace charge.
In the
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case of forgings too small to permit cbtaining a sub-size specimen, hardness testing is permitted, in which case the hardness should be in the range of Brinell hardness number (BHN) 137 to 187 inclusive.
Since it was not possible to obtain tensile test specimens from installed items without destroying the components, the approach used by NUMARC was to perform in situ hardness tests as a screening test for potentially substandard materials.
The basis for the validity of this approach was provided by the industry-wide NUMARC program, under which approximately 7100 field hardness test results, 540 NUREG-1402 2-15 03/13/90
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a tensile strength results, and 770 chemical analyses were considered.
The staff accepted this approach but required a more conservative correlation of hardness to tensile strength than that suggested by NUMARC, as discussed below.
The staff's objective was to develop a criterion for identifying all potentially substandard carbon steel flange and fitting material and for determining its acceptability for service in safety-related systems.
The staff evaluated the NUMARC and industry data together with confirmatory tests conducted by the staff's contractor, Brookhaven National Laboratory, of samples selected by the staff from the NUMARC test material.
Rather than adopting the best-fit NUMARC Equotip-to-tensile-strength correlation, which overpredicts the tensile strength in many cases, the staff adopted the more conservative correlation specified by ASME Code, SA-370, " Specification for Mechanical Testing of Steel Products." This correlation has been shown to be conservative for the hvMARC-sponsored Bechtel laboratory tests and the independent' tests discussed in Section 2.9.
2.9 Brookhaven National Laboratory's Independent Testing Activities
'On September 12, 1988, the NRC placed a contract with Brookhaven National Laboratory (BNL) to provide assistance tc the NRC staff in reviewing both field and laboratory test data and to independently test 13 flanges supplied by PSI and WJM.
[
The 13 flanges were received at BNL on August 22, 1988 (from Bechtel Power Corporation) for independent testing.
The following testing protocol was followed for each of the flanges:
Hardness testing (both Brinell and Equotip)
Tensile testing (one specimen per flange)
Chemistry testing for the following elements:
carbon, manganese, phosphorus, sulfur, silica, chromium, nickel, molybdenum, vanadium, and i
I copper NUREG-1402 2-16 03/13/90
4
~I 0fithe 13 flanges tested, 12 appeared to be carbon steel; 1 flange (identified as PP-6).was stainless steel.
1' The testing of the 13 flanges yielded the following results:
- Flange identification no.
Comments c
- V0GT 1-4 Meets SA-105 specification requirements.
t SEA 1-54 Meets SA-105 specification requirements.
RB 1-17 Meets SA-105 specification requirements.
CAL-1
~ Meets SA-105 specification requirements..
OC 1-3 Meets SA-105 specification requirements.
WF.3-4 Meets SA-105 specification requirements.
PP Meets SA-105 specification requirements.
LIM 2 Meets SA-105 specification requirements,
.RGE;1 Meets SA-105 specification requirements, l
RB'l-14~
Meets SA-105 chemistry requirements; does not meet.
. required minimum reduction of area..
1 PER 1-33 Meets SA-105' chemistry requirements; one hardness'~
value is too high; elongation does not meet the specification minimum.
' SEA 1-31 Meets SA-105 chemistry. requirements; both elonga-
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tion and reduction of area do not meet the specifi -
cation minimum, i
PP-6 (stainless steel)
Meets mechanical. requirements for SA-182, Type F304 material; neither chromium nor nickel meets the-specification minimum.
With regard to the three carbon steel flanges that did not meet the mechanical requirements, both the reduction of area and elongation for SEA 1-31 were below the specification minimum. The reduction of-area'was 20 percent (22 percent required), and the elongation was 29 percent-(30 percentLrequired).
For PER 1-33, one hardness value (of three taken) exceeded the 187 Brinell maximum.(192 BHN), and the elongation was measured at 16 percent, instead of the 22 percent required by specification.
For RB 1-14, the reduction of area was'28 percent, instead of the 30 percent minimum required by specification.
1NUREG-1402 2-17 03/13/90
p Although these three flanges did deviate from the specification requirements to a minor degree, it is probable that the variances are small enough so that the flanges would perform their intended function during service.
Both the nickel and chromium content of the stainless steel flange (PP-6) measured at levels below the specification minimum.
The mechanical properties significantly exceeded the specification minimum.
It is probable that this flange would also perform its intended function during service.
The review of the NUMARC and Vogtle Unit 2 data coupled with the independent testing of-the WJM and PSI flanges has led the staff and BNL to conclude the following:
(1) 'The 13 flanges tested (12 carbon steel, I stainless steel) had test results that were indicative of the specified materials, although some deviations were noted.
All specimens exceeded the minimum tensile requirements of the appropriate specifications.
(2) The Equotip hardness test method can be a valuable tool.in estimating the tensile strength of materials if the limitations (temperature dependence, relative relationship'to Brinnell hardness, etc.) are understood and compensated for.
(3) The independent tests confirmed the test results of NUMARC and those for Vogtle Unit 2.
2.10 Responses From Near-Term Operating License Applicants Five near-term operating license (NTOL) applicants responded to NRC Bulletin 88-05 and its supplements by submitting the following to the NRC:
Georgia Power Company, Alvin W. Vogtle Nuclear Plant, Unit 2, Docket No. 50-425, letters to the NRC dated November 30 and December 15, 1988, and January 5, 1989 NUREG-1402 2-18 03/13/90
2
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Houston Lighting & Power Company, Sou'th Texas Project, Unit 2. Docket No. 50-499, letters to the NRC dated November 1, November 17, and Nte.ber 6,1988
)
J Long Island Lighting Company, Shoreham Nuclear Power Station, Docket 1
No. 50-322, letters to the NRC dated September 9 and December 21, 1988 Philadelphia Electric Company, Limerick Generating Station, Unit 2, Docket No. 50-353, letters to the NRC dated March 31 and June 2,1989 Public Service Company of New Hampshire, Seabrook Station, Unit 1, Docket No. 50-443, letters to the NRC dated August 25 and October 14, 1988 The staff and its consultants reviewed each submittal in detail.
The responses' contained descriptions of the following:
the methodology used to. identify, test',
and evaluate material supplied by WJM, PSI, and CLM; the document and procurement
-review and testing programs; and an engineering evaluation and analysis of the nonconforming items.
In all cases, the NRC staff sent requests for additional
.information and clarification to the-NT0L applicants.
Af ter it had reviewed the responses, the staff prepared safety evaluation reports (SERs),-e'ach of which y
contained an overview summary of the actions taken by the applicant and the eval-untion of the ' applicant's response.
In the SER the staff also discussed its-review of the applicant's submittal, with particular emphasis on the analytical h
methods used to demonstrate suitability for service of the nonconforming flanges and fittings, and its conclusions.
On'the basis of its review of.the submittals, 1
the staff found that the NTOL applicants had conducted adequate material property.
~ tests and structural analyses of the nonconforming flanges and fittings using
- acceptable and conservative analytical methods and evaluation criteria.
The staff,also found that the applicants were responsive to.the action and reporting-requirements of NRC Bulletin'88-05, Supplements 1 and 2, and..had qualified all-nonconforming parts as being suitable for the intended service.
The reports submitted by the NT0L applicants provided the staff and its consul-tants with additional data and confirmatory analyses demonstrating that the NUMARC generic analysis methodology was acceptable for determining the adequacy I
of-nonconforming components for service.
i NUREG-1402 2-19 03/13/90
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After1 reviewing the reports, the staff found that the nonconforming components in these five'NT0L plants are fit for service even though the staff does not consider the.aonconforminq parts to be material that conforms to'the 'ASME
. Code.
However, the staff finds that the NTOL applicants have satisfied the criteriaLfor meeting the requirements in NRC Bu11etin'88-05 and, therefore, the use of this material is an acceptable alternative in accordance with 10 CFR -50.55a(a)(3)(ii) because full compliance with all specified requirements would result.in hardship or unusual. difficulties without a compensating increase in the level-of quality or safety.
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NUREG-1402 2-20 03/13/90 1
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r 3 CONCLUSIONS The NRC staff and its consultants conducted an in-depth review program to re-solve the potential generic safety concerns at facilities that had received (1) direct shipments of materials furnished by PSI, WJM, or CLM or (2) piping sub-
[
assemblies and other components from holders of ASME certificates of authoriza--
tion or other subcontractors that had incorporated materials supplied by PSI, WJM, or CLM.
Activities included receipt and review of licensee responses to NRC Bulletin 88-05; multiple meetings with NUMARC, EPRI, and Bechtel; a visit to the Vogtle plant; review of the NUMARC testing program, generic analysis and evaluation report, and. methodology; independent testing and analysis; and pub-lication of SERs pertaining.to the responses to NRC Bulletin 88-05 from five near-term operating license (HT0L) applicants.
On-the basis of the activities listed above and its findings, the staff concludes the following:
(1) The analytical procedures used to. qualify the nonconforming material and the results of the analyses provide an adequate basis for resolving the staff's concerns with respect to demonstrating the adequacy of the material for service.
(2) The materials supplied with falsified certified material test reports do not meet ASME Code requirements.
g (3). Warehouse stock shall be screened, hardness tested, and qualified by l
' tensile and chemical tests as stated in the staff's letter to NUMARC' dated u
February 15, 1989.
L (4) Activities in response to NRC Bulletin 88-05 can be closed for fittings L
and flanges for all operating plants.
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u (5) --Activities in response to NRC Bulletin 88-05 can be closed for product forms other than fittings and flanges for operating plants that did not receive such material.
For. operating plants that did receive such material, licen-sees should determine its location and perform an engineering evaluation where it was used in safety-related applicatic.ns.. Licensees for Perry and Palo Verde will be required to submit their evaluations for NRC staff review.
For other operating plants, these evaluations are to be performed in accord-ance with 10 CFR 50.59 and are not required to be reviewed by the NRC for approval.
However, these evaluations are. subject-to audit and inspection at the discretion of the NRC staff.
(6) Activities in r'esponse to NRC Bulletin 88-05.will remain open for unreviewed-NTOL plants.
A plant-specific evaluation must be' performed for each NTOL plant before it-is licensed.
(7) The use of installed PSI, WJM, or CLM fittings and flanges is an acceptable alternative in accordance with 10 CFR 50.55a(a)(3)(ii) because full com-pliance with all specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality or safety.
a NUREG-1402 3-2 02/05/90 4
g 4 REFERENCES I
Industry Codes and Standards American National Standards Institute, B16.5, " Steel Pipe Flanges and Flanged i
Fittings," 1981.
---~, B16.11, " Forged. Steel Fittings, Socket-Welding and Threaded," 1973.
American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, SA-105, " Specification for Forgings, Carbon Steel, for Piping Components," 1985, t
--, SA-181, " Specification for Forgings, Carbon Steel, for General-Purpose Piping," 1985.
~
--, SA-234, " Specification for Piping Fittings of Wrought Carbon-Steel and Alloy Steel for Moderate and Elevated Temperatures," 1985.
--, SA-350, " Specification for Forgings, Carbon and Low Alloy-Steel, Requiring Notch Toughness Testing for Piping Components," 1985.
--, SA-370, " Specification for Mechanical Testing of Steel Products," 1977.
1.
--,Section III, Subarticle NC-3658.3, 1986 Edition.
--,Section III, Subarticle NCA-3800, 1986 Edition.
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-NUREG-1402 4-1 02/05/90
<c APPENDIX A NRC BULLETIN 88-05 AND SUPPLEMENTS 1 AND 2 1
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p OMB No.: 3150-0011 NRCB 88-05 l
UNITED STATES NUCLEAR REGULATORY COMMIS$10N OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 j
May 6, 1028 NRC BULLETIN NO. 88-05: NONCONFORMING MATERIALS SUPPLIED BY PIPING SUPPLIES, INC. AT FOLSOM, NEW JERSEY AND WEST f
JERSEY PANUFACTURING COMPANY l AT WILLIAMSTOWN, NEW-JERSEY Addressees:
All holders of. operating licenses or construction pennits for nuclear power i
reactors..
Purpose:
i The purpose of this. bulletin is to require that licensees submit infomation regarding materials supplied by Piping Supplies, Incorporated (PSI) at Folsom, New Jersey and West Jersey Panufacturing Company (WJM) at Williamstown, New Jersey and to request that licensees 1) take actions to assure that materials comply with ASME Code and design specification requirements or are' suitable for-their intended service, or 2). replace such materials.
Description of Circumstances:-
The NRC has obtained copies of certified material test reports (CMTRs) for j
material supplied by PSI and WJM'that contain false information about material-l supplied'to the nuclear industry. - A number of CMTRs were apparently used to l;
certify that consnercial-grade, foreign steel meets the requirements of ASME l:
Code Section !!!, Subarticle NCA-3800, by using a dcmestic forging company's l
l
-letterhead. There was no evidence that PSI or WJM performed or had a subcon--
R tractor perfom the testing required by Section III to upgrade the commercially.
produced steel for these falsified CMTRs. - The information available to date
!i indicates that WJM started supplying ASME Code components to the nuclear j
industry in.1976, both directly as well as through intennediaries, and that
?
PSI started supplying ASME Code components to the nuclear industry directly I'
and through intertnediaries in 1985.
In addition, WJM held'an ASME Quality-System Certificate (QSC-385) as a material manufacturer from November 30 1979' L
to November 30, 1985.
Z, The NPC has concluded that there are potential generic safety implications at facilities that either have received direct shipment of materials furnished by i
PSI or WJM li.e., pipe fittings and flanges) or received piping subassemblies y
and other components frem holders of ASME Certificates of Authoriration or L
.other subcontractors which incorporated materials supplied by PSI or VJM.
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.NUREG-1402 A-1 b
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NDCB U.n$
May 6, 19Pa Page 2 of a i
Actions Recuested:-
1.
Review purchasing records for your facility and detemine whether any WJM-or PS}-supplied ASME Code or ASTM materials have been furnished to your H
facility. The lists of purchasing and receivino companies given in q
. Attachments 1 and 2 have been developed throuch the: NRC's partial review u
of PSI and WJM documents.
It is emphasized that the NRC has not reviewed all documents; therefore, the review of records should not be limited to the companies on these lists.
The records review for PSI-supplied material-l --
should cover the period since January 1,1085.
The Wi P review should cover 1
the period since January 1,19"6.
2.
For ASME Code and ASTM materials furnished by PSI or WilP that are either L
not yet installed in safety-related systems at your facility or are in-L stalled in safety-related systems of plants under construction, the followin b or c) g actions are requested:
(perform action a and either action 4
a.
Provide a list of WJM-and PSI-supplied materials that are found not to be in conformance with the applicable code requirements or procure-H ment specifications and identify the applications in which these materials are used'or will. be used.
Include the material specifi-cation, the nature of the component (e.g., pipe. flange), size and pressure rating; also indicate the chain of purchase, and either L
b.
Take actions that. provide assurance that all-received materials comply L
with ASME Code Section III, ASTM, and applicable procurement specifica-t tion requirements, or that demonstrate that such materials are suitable for the intended service.
For example, this program should include-specific verification that austenitic stainless steels have been received in a non-sensitized condition, or,.
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-c.
Replace'all questionable fittings and flanges'with materials that have-been manufactured in full compliance with ASME Code Section.III. ASTM, and the applicable procurement specification reouirements.
- 3. ' For ASME Code and ASTM materials, furnished by WJM or PSI already installed in safety-related systems in operating plants, the following actions are i
requestedt a.
Provide a list of the WJM-and PSI-supplied materials that are found not to be in conformance with the applicable code recuirements or pro-s curement specifications and identify 'the applications in which the rraterials are used.
Include the material specification, the nature of-the component (e.o., pipe flange), size, and pressure rating; also L-indicate the chain of purchase.
?
b.
Take actions requested in 2b or 2c above. However, an evaluetion should be undertaken prior to replacing questicnable material in accordance with 2c above that considers the occupational radiation i
NUREG-1402 A-2 l
K
]
NRCB 88 05 May 6, 1988 Page 3 of 4 exposure that would be received during the replacement process. This evaluation should be considered in developing the method and. timing of material replacements.
c.
Document and inaintain for inspection a basis for continued plant
- operation if the prooram requested in item 3b has not been completed within 120 days of the date of receipt of this bulletin.
4 For any PSI-or WJM-supplied materials having suspect CMTRs and used in systems that are not safety-related, take actions commensurate with the function to be performed.
5._
Naintain for inspection the documentation of the specific actions taken for the identified materials.
6.
For operating plants, all scheduled actions should be completed before a i
restart from the next major outage starting after 180 days from the date of receipt of this bulletin..For t.lants under construction all scheduled actions and the reporting reouired by 2_ below should be completed prior to the planned fuel load date.
If any addressee cannot meet this schedule, 1;
they should justify to the NRC their proposed alternative schedule.
Reporting Reouirements:
1.
Provide a written report within IPO days of the date of receipt of this bulletin that either:-
l;
+
a.
States that no WJM-or PSI-supplied materials-have been furnished for L
your facility for use in safety-related systems, if such is the case,
-or b.
Provides the information requested in items 2a and 3a above that-indicates which materials have been found not to be in conformance with the applicable code requirements'or_ procurement specifications, i
confirms completion of other actions requested in items 2b or c. 3b and 4, and provides a schedule for. completing,any remaining actions.
2.
- Confirmation of completion of all scheduled actions shall be submitted i
to the NRC within 60 days of completion for operating plants and prior.
L to the fuel load date for plants under constructior;.
L The written reports, required above, shall be addressed to the U.S. Nuclear, P
Regulatory-Commission, ATTH:
Document Control Desk, Washington, D.C.
- 20555, under oath or affirmation under the-provisions of Section 182a, Atomic Energy Act of 1954, as amended.
In addition, a copy shall be submitted to the appro-priate Regional Administrator.
n L
This. requirement-for information was approved by the Office of Management and.
Budget under clearance number 3150-0011.
i
~NUREG-1402 A-3 L
y f', k }c
,i
v
' t l.
j NRCB 88-05 May 6. 1988 Page 4 of. 4 If you have any questions regarding this matter, please contact one of the i
technical: contacts listed below or the Regional Administrator of the appro-
-priate'NRC Regional Office.
l harles E. Rossi Director Division of Operational ~ Events Assessnent Office of Nuclear Reactor Regulation y-Technical Contacts:
Ray Cilimberg, NRR (301)492-3220 Ed Baker, NRR
-(301) 492-'3221 Attachments:
Table 2'- Known and Intended Recipients of Stainless Steel Materials furnished by PSI or WJM.
3.
List of Recently issued NRC Bulletins q
4
?
\\
e NUREG-1402 A-4
.. a 6
m 3
NRCB 88-05 May 6, 1988 Page 1 of ?
TABLE I YNOWN AND INTENDED RECIPIENTS OF CARBON STEEL MATERIALS FURNISHED By PSI AND %)M Purchaser Receivino Company Nuclear Plant (if known)'
Padnor Alloys, Inc.
Bechtel Power Corp.
Pilgrim Capitol Pipe & Steel Rechtel Power Corp.
Midland
, Pullman Power Products Pullman Power Products Palo Verde Pullman Power Products Daniel Wolf Creek Pullman Power Products Cleveland Electric Perry E
Pullman Power Preducts Bechtel Power Corp.
South Texas Pullman Power Products' Pullman Power San Onofre Pullman Power Products Pullman Power Vogtle Tyler Davison Bechtel Power Corp.
Grand Gulf Osborne Brothers Welding
- Supply-General Electric Perry
-HUB Incorporated Duke Power Oconee HUB Incorporated Bechtel Power Corp.
Arkansas HUB Incorporated Bechtel Power Corp.
WNP-?
Chicago Tube.& Iron Omaha Public Power Fort Calhoun District Chicago Tube & Iron Commonwealth Edison Braidwood Chicago Tube'&' Iron.
Cherne Construction Co. Marble Hill Chicago Tube 1. Iron Northern States Power Chicago Tube &-Iron Consumer Power Palisades Dravo. Corp.
-Dravo Corp.
Seabrook
-ioliet Valves, Inc.
Joliet Valves, Inc.
l
=
McJunkit Bechtel Power Corp.
San Onofre Guyon Alloys Babcock & Wilcox ITT Grinnell ITT Grinnell L
Guyon Alloys, Inc.
Bechtel Power Corp.
Limerick l
Guyon Alloys. Inc.
Northeast Nuclear Energy Millstone L
Company L
Guyon Alloys, Inc.
Bechtel c/o PP&L Susquehanna-L
. Guyon Alloys. Inc.
Duke Power Catawba-L
- Guyon Alloys,-Inc.
Bechtel Power Corp.
Hope Creek
[
GuyonLAlloys. Inc.
WNP-2 Guyon Alloys Inc.
Carolina Power & Light Brunswick Guyon Alloys. Inc.
Baldwin Assnciates Clinton
-Guyon Alloys, Inc.
South Carolina Electric V.C. Sumer and Gas
. Guyon Alloys. Inc.
Carolina Power & Light Shearon Harris Guyon Alloys. Inc.
Gulf States River Pend-
' Bellows l
American Standard American Standard Louis P. Canuso Bechtel/Public Service Hope Creek l
NUREG-1402 A-5 o
MATERIALS FURNISHIA BY PSI'AND.WJM (continued)
.1:
~ '
Purchaser Receiving Company-Nuclear Pl&nt (if known1 Capitol Pipe & Steel Bechtel Hope Creek Gulfalloy Pechtel Power Corp; Palo Verde Public Service Electric and Gas PSELG
$alem Conax' Conax Consolidated Power
- Pechtel Power South Texas Consolidated Power
- Duke Power McGuire Consolidated Power
- Boston Edison Pilgrim Consolidated Power
- Hiagara Mohawk Nine Mile Point Consolidated Power
- Philadelphia Electric Limerick Louis P..Canuso Bechtel Corp.
Hope Creek Dubose Toledo Edison Davis-Besse Dubose-Florida Power Crystal River Dubose TVA Sequoyah Dubose TVA Watts Bar Dubose.
PP&L-Susquehanna Dubose SMUD Rancho Seco Dubose Rochester Gas & Electric Ginna Dubose-Duke Power Oconee Pcwer Authority State FitzPatrick Dubose of N.Y.
Dubose South Carolina Electric and Gas
- Consolidated Power is also known as Consolidated Piping and Supply located in Birmingham, Alabama,' Furlong, Pa., and ~ Charlotte, N.C.
NUREG-1402 A-6
.~
- o Attachment ?
NRCB 88-05 May 6. 1988 Page 1 of 1-TAPLE 2 - KNOWN AND INTENDED RECIPIENTS OF STAINLESS STEEL MATERIALS EURNISFED BY PSI,AND WJM l
7 Purchaser Receivina Comoany' Nuclear Plant-fif known)
HUB Incorporated Bechtel Power Corp.
Limerick Radnor Alloys Radnor Alloys _
Pullman Power Products Pullman Power i
Dravo Corp.
Dravo Corp.
Seabrook.
Louis P. Canuso. Inc.
Philadephia Electric Peach Bottom-L. P. Canuso. Inc.-
Bechtel Power Corp.
.i I
I
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i u
is l-.
O I
NUREG-1402 A-7
g L
-OMB No.: 3150-0011-s NRCB 88 05, Supplement 1 i
UNITED STATES NUCLEAR REGULATORY COMMIS$10N.
OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 June 15,1988 e
NPC BULLETIN NO. 88-05, SUPPLEMENT 1:
NONCONFORMING MATERI ALS SUPPLIED BY PlPING SUPPLIES, INC. AT FOLSOM, NEW JERSEY AND WEST JERSEY MANUFACTURING COMPANY AT WILLI AMSTOWN, NEW JERSEY Addressees:
All holders of operating licenses or construction permits for nuclear power reactors.
Purpose:
The purpose of this supplement is to 1) provide additional information. con-cerning material supplied by Piping Supplies, Incorporated (PSI) and West.
Jersey Manufacturing Company (WJM), 2) reduce the scope of the requested
- materials review to only flanges and fittings, 3).. delineate actions licensees are requested to take to identify these materials end to determine whether
- the materials comply with ASME and ASTM design and material specifications, and:4) clarify what actiers licensees are requested to take once they identify
' material that does not comply with the above material specifications.
- Description of Circumstances; On June'10, 1988-the NRC staff was informed by Carolina Power & Light (CP&L).
4 that the.Shearon Harris Nuclear' Plant had tested two flanges from their ware-
' house that had been supplied by WJM. ' The-two flanges were identified as.
- belonging to Heat No. 7218 SA-105 material. The CP&L test results did not match those reported on VJM's Certified Material Test Reports (CMTRs) and did not meet the tensile and yield strength requirements for SA-105 material.
- Required minimum tensile strength is 70 KS! whereas the measured tensile.
strengths were 45 KS! and 46 KSt. The tensile strength reported on the CMTR was-77 KSI.
Required minimum yield strength is 36 KS! wb reas the measured yield strengths were 27 KSI and 31 KSt. The yield stren b a reported on the CMTR was 50 KSI.. Measured chemistry composition was also out of specification,
. notably percent carbon was very' low at 0.045 and manganese was measured at 0.32
.(required-range 0.6to1.05).
Bulletin 88-05 requires that all PSI and WJM supplied material be identified and'that a determination be made as to its suitability for the intended or 8806150186 a
NUREG-1402 A-8
k NRCB 88-05. Supplement 1 June 15, 1930 Page 2 of 3 J
actual application.
This supplement narrows the scope of review from ASME
- and ASTM " materials" to ASME and ASTM fittings and flanges.
In view of the recent verification that flanges which do not comply with ASME and ASTM speci-fications have been supplied to the nuclear industry, the time frames for certain actions are also modified by this supplement, Actions Recuested' The actions requested in Bulletin 88-05 remain in effect with the following additions:
1 1.
Review of purchasing records may be reduced in scope from ASME and ASTM " materials" to ASME and ASTM " fittings and fijnges" and the review should be initiated and completed promptly.
2.
The scope of paragraph 2 of Bulletin P8-05 is reduced from ASPE and ASTM " materials" to ASME and ASTM " flanges and fittings." All other provisions of paragraph 2 of Bulletin 88-05 remain in effect.
3.
'The scope of paragraph 3 of Bulletin 88-05 is reduced from ASME and ASTM
" materials". to ASME and ASTli " flanges and fittings." For ASME and ASTM flanges and fittings furnished by PSI or WJM already installed in safety-related systems in operating plants, the following actions are requested:
a.
Commence appropriate. testing of accessible flanges and fittings promptly to identify conformance of materials to' ASME and ASTM material specifications. Test results for flanges and fittings reported to be from the same heat should be compared for consist-ency and for confomance to the' ASME/ASTP specifications and to values listed on material CMTRs.
Any deviation from the specifi-cation requires an appropriate analysis justifying continued operation.-
b.
If any inaccessible flanges or fittings are identified,_an analysis must be performed justifying continued operation, c.
All other provisions of paragraph 3 of Bulletin 88-05 remain in effect.
4 For flanges and fittings already identified as having been supplied by PSI or WJM, the actions requested in-3a and 3b above are to be completed within 30 days of receipt of this supplement.
For flanges and fittings identified after receipt of this supplement, the actions requested in 3a and 3b above are to be completed within 30' days of identifying the flanges or fittings as being supplied by PSI and WJM.
jf Based on the discovery by CPAL of nonconfoming flanges and on NRC review of records of WJM's production of numerous flanges purportedly from Heat No. 7218. licensees should specifically be alert to identify records for flanges from Heat No. 7218.
NUREG-1402 A-9
NRCB 88-05, supplement 1 June 15, 19P,8 Page 3 of 3 5.
AddressePs-are requested to retain nonconforming materials until advised further by the NRC, Nonconforming materials should be segregated to ensure that-they are not inadvertently used.
6.
Addressees are encouraged to report the results of tests of PSI and WJW.
l supplied flanges and fittings to the INPO Nuclear Network for dissemi-nation to the industry.
e Reportino Recuirements:
The reporting requirements of Bulletin 88-05 remain in effect with the following additions-1.
The NRC Operations Center should be notified by telephone, 202-951-0550, of i
the need for analysis to justify continued operation as required in para-grcphs 3a and 3b. Where the need for analysis to justify continued operation results in a requirement for a report under 10 CFR 50.72, the notification to i
the Operations Center should-be in accordance with the reporting times re-quired by 10 CFR $0.72. If the need for analysis to justify continued operation would not result in a requirement for a report under-10 CFR 50.??,
the notification to the Operations. Center should be made within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
2.
Include the results of all tests of PSI or WJM materials in the written response to Bulletin 88-05.
The, written reports required above shall be addressed to the U.S. Nuclear ~
Regulatory Comission ATTN _: Document Control Desk, Washington, D.C. 20555, under oath or af#irmation under the provisions of Section.182a, Atomic Energy 1
h Act of 1954, as amended, in addition, a copy shall be submitted to the appro-priate Regional Administrator.
L This' requirement for information was approved by the Office of Management and Budget under blanket clearance number 3150-001). Comments on burden and dupli-ications should be directed to the Office of Management and Budget. Reports' Management, Room 3208, New Executive Office Building, Washington, D.C. 20503.
l~
If you have any questions about this matter, please contact one of the technical contacts listed below or the Regional Administrator of the appropriate NRC regional office.
,e.
X Charles ossi, Director Division of Oper:tional Events Assessmer.t o
Office of Nuclear Reactor Regulation J
l Technical Contacts: Ray Cilimberg, NRR (301) 492-3220 Ed Baker, NRR (301) 492-3221
Attachment:
List of Recently Issued NRC Bulletins NUREG-1402 A-10 f
'N.
'ky i
l Attachment E-NRCB 88-05, Supplement 1 June 15, IcP.C LIST OF RECENTLY ISSUED NRC BULLETINS
- Bulletin Date of.
No.
Subject issuente Issued to 88-07 Power Oscillations in 6/15/BB All holders of OLs Boiling Water Reactors (BWRs) or cps for BWRs.
88-06 Actions to be Taken for 6/14/88 All NRC licensees the Transportation of authorized to Model No. Spec 2-1 manufacture, Radiographic Exposure distribute, or Device operate radiographic exposure devices or source changers.
87-02,-
Fastener Testing to 6/10/88 All holders of OLs Supplement 2 Detemine Conformance or cps for nuclear with Applicable Material power reactors.
Specifications 80-05
- Nonconfoming Materials 5/6/88 All holders of Ots Supplied by Piping Supplies, or cps for nuclear-Inc. at Folsom, New Jersey power reactors, and West Jersey Manufacturing Company at Williamstown, New Jersey 88-04 Potential Safety-Related 5/5/88 All holders of 0Ls Pump Loss or cps for nuclear power reactors.
~ 85-03,.-
Motor-Operated Valve Common 4/27/08 All holders of OLs Supplement 1 Mode Failures During Plant or cps for BWP.s.
Transients Due to Improper Switch Settings-B7-02, Fastener Testing to 4/22/88 All holders of OLs Supplement 1 Detemine Conformance or cps for nuclear with Applicable Material power reactors.
' Specifications 88-03
.1 adequate Latch Engagement 3/10/88 All holders of' 0Ls
.n HFA: Type. Latching Relays or cps for nuclear Manufactured by General power reactors, electric (GE) Company OL = Operating License CP
- Construction Permit HUREG-1402 A-11 i
l
)
3
)
OMB he: 3150 0011 l
L kkC6 86 05. Supplement 2 Uk!1tD 51Att5 MUCLLAR REGUL A10RY CCW:15510k
)
0FFICE OF kUCLEAR R[AC10R REGULA110h WA5HlhG10h. D.C.
20556 j
Appust 2. 1900 l
l NRC BULLillh h0. 68 05, SUPPLEMthi 2:
h0hC0hf 0AMlhG mal [RI AL5 50FFL1t0 SY l
T" P1FlhG SUPPLl[5. Iht. Al FOL5CM, h[W JERSEY AND Wl51 JER5Lt MANUFACTURlhL COVFAhY Al WILLIAMSTOWN. htW JtkStY i
l' Aceressees:
All holders of operating licenses or construction permits for nuclear power reactors.
i 1
Furcosts i
The purpose of this supplement 18 to (1) modify the schedule for actions addressees were requested to perform in Bulletin 88 05 and Supplement 1 and (2) provide additional information concerning materials supplied by
' Piping Supplies. Incorporated (PSI). West Jersey Manufacturing (WJM),
ar.d a recently identified af filiated company Chews Landing Metal Manu.
facturers incorporated (CLM).
Description of Circumstances:
On July 22, 1906, the NRC staff met with representatives of the Nuclear Mensge.
ment and Resources Council (huMARC) to discuss the status of licensees' actions in response to Bulletin 88 05 and Supplement 1.
During this meeting. huMAtt i
presented information on licensee and h06 ARC /tlectric Fower Research Insti19te (CFRl) testing and evaluation methodology of PS!/WJM flanges. This inforv.ation was sufrarized in a letter to the NRC from NUMARC dated July 25,1988 and a detailed report and proposal was subsequently submitted on July 29. 1988 (Attachment 1).
Based on the reported measurement and ana'lytical results to date, the hRC has concluded that for full power licenstes it is appropriate to suspend terpo.
rarily, the field measurements. testing, records review, and the preparation of justifications for continued operations (JCOs) that were requested by Bul.
letin 88 05 and Supplement I until further notice. Addressets that h u not received a full power license are requested to continue the in situ N !!q cod the records review. The tirne frames of interest rec.ain as specified in the original Eulletin, January 1.1976 to present. During the tenporary suspension of the requested divities. the NRC will review the measurener,t anc test data and results of analysis performed and determine the extent to l
BB0E030289 NUREG-1402 A-12 i
n
kRC6 $6 05. Supplement 2 August 3. 19EB Page 2 of 3 l
which further actions are appropriate to assure the continued safe operation of nuclest power plants. However, addresseen should continue to analyse the test +esults perfortned to date.
On Jul) I2.196b. the NRC staf f ckple'ted its review of P51/WJM/CLM purchase creer and invoice receres. 6ased on this review. the staff has deteminee thtt P51/WP/CLM providec product forrts in addition to flanges and fittings. 1he additional procutt foms are icentified in Attachment 2 and t list of nuclear pomer plants that were identified as possible recipients of P51/WJM/CLM materials is provisen in Attachment 3.
The hRC staf f also identified Certified Material Test Eeperts (CM1Rs) for A5MI 5ection !!! materials from CLM. which also should bs considered as suspect. CLM was owned by parties involved in PS) and WJM and 1
the persons signing the CMIRs for CLM also signeo the CMTRs for PS) and WJh. provices a listing of seditional intershediary suppliers / fabricators of P51/hJM/CLM products. 8911etin 86 05 identified 1976 as the beginning cate for suspect ratet tals provided by PSI /WJM; however. information available to the hRC now incicates that WJM may have provided A5Mt materials as early as 1962.
The hRC is providing the above information to assist the industry in their uncerstar.cing of the P51/WJM/CLM issue, i
l Actions Secuested:
The actions requested in tviletin 86 05 and Supplement 1 are temporarily sus-penced with the follraih1 exceptions:
1.
Addressets that have not received a full power operating license are requested to continue the records review and the in situ testing of installed flanges and fittings.
2.
Addressets are requested to maintain for inspection the documentation of the specific actions taken for the identified materials.
1 3.
Addressets era requested to retain nonconforming matertfts ut,ti) advised further by the hRC.
4.
Addressets are encouraged to report the results of tests of Ml and WJM supplied flanges and fittings to the lhPO huclear ketwork for dissertinction to th* industry.
?
Segerting Requirettents:
The reporting requirements of Bulletin 88 05 and Supplement 1 are taporarily suspended with the following exceptions:
3.
Holders of full power operating licenses are recu, ired to report the results of their tecords review insting and analysis perforred as of the fate of this supp'ement in accordance with the 120 cay reporting requirement speci-r fied in pr regraph 1 of bulletin 88 05.
t I.
Holders of construction pemits are required to report the results cf the recorcs review, testing, and analysis prior to the pinnned fuel loud cate.
NUREG-1402 A-13
=
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~,
. ~ -, _....,.
e NRC6 88 05. Supplement 2 l
August 3. 1968 Page 3 of 3 i
If you have any questions about this' matter, please contact one of the technical contacts listed below or the Regional Ade.inistrator of the appropriate NRC regional office.
t Of
^Mi Charles L. Acssi Director Division of Operational Events Assesse.cnt Office of huclear Aestter Repuistion Technical Centacts: Ray Cilimberg. NRR (301) 492 3220 l
Ec Baker. NRR (301) 492 3221 Atta chrt.cnts :
3.
Ltr to NRC fr. huk.RRC. dtd July 29, 1982 2.
Product Forms Sole by WM/P51/ Chews Landing 3.
Nuclear Plants Receiving Suspect Material
.4.
Purchasers Receiving Suspect Material S.
List of Recently 1ssued hRC Bulletins NUREG-1402 A-14 j
.-s
-e m.
7 pf 1
-'m
I I
J i
f.er.
o q Attachment No.1 WRCS 88 05 Supolement 2 Nucitae WANdstutW1 AND etsDueOls couwCit August 3. 196b I., m...
- 1. e 2::. im'r:- :: M* *: N4
- . ! *; '; t,
f July 29, 1988 l
I Mr. Thomas 1. Martin Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation i
U. 5. Nuclear Regulatory Comission i
Washington, D. C. 20555
Dear Mr. Martin:
In a meeting held July 22 with NRC NUMARC requested that utility activities relat' ve to NRC Bulletin 88 05 and supplement I be suspended.
This suspension request was based on a generic analysis provided to NRC by i
NUMARC's letter of July 22.
In the subject NRC meeting. NUMARC also presented j
an analysis of utility and laboratory test data obtained to date. NUMARC's
- letter of July 25 to Dr. Thomas Murley formaltred the request for suspension.
in that letter NUMARC committed to provide a written report to NRC reflecting l
. the test data and conclusions' presented in the July !! meeting, and providing quantitative statistical evaluations relative to the conclusions presented i
st this meeting. That' report is'hereby provided as an attachment, l
t l-As noted previously, the NUMARC laboratory testing program will be carried L
to completion even if utility test efforts are suspended. An update of the l
attached report will be provided addressing conclusion of the NUKARC laboratory i
g testing program as well as inclusion of field test data not yet reflected.
We would like to reiterate the importance of timely action in your I
consideration of NUMARC's request for suspension. Utility resource t
expenditures of r.njor proportions are presently continuing without abatement, l
Continuation of testing is not resource effective and, as documented in the
- attachment. would not be expected to result in additional insights. Moreover, in conjunction with the generic analysis previously provided, the attachment i
substantiates that no significant public health and safety concern is represented by this issue.
i HUREG-1402 A-15 1
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Mr. Thomas 1. Martin July 29,1988 Fagt t l
NMRC is studying all available infomation to detemine what industry l
action should be taken to come to ' final resolution of this issue. We will discuss our intentions with you and your staff in the near future.
j s
If you or your staff have any questions, please do not hesitate to contatt us at any time.
Sincerely,
.j wW%
I a
William H. Rasin Dirertor Technical Division gg Attachment sc: Lawrence C. Shao Director, Division of [ngineering and System Technology D. J. Mcdonald
[recutive Director National Board of Boiler and Pressure Vessel Inspectors i
h 4
t NUREG-1402 A-16
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W N RC CENERIC 71571NC PROGRAM l
MSPONSI 70 NRC SULttTIN $$-05 l
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1NTERIM M PORT July 29,1988 i
I Prepared By lechtel Mstional, Int.
$an Francisco, California 94105 i
B Prepared For Electric Power 3412 M111 view Avenue Palo Alto, California 94203 i
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i NUREG-1402 A-17 n-w s-e w+
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Alg7 kACT The ERC Sulletin 68 05 addressed the alleged istelfiestion of Certified Meteriale Teet Reporte (Of7Re) by two owppliare. WJM and 981, of piping flanges end fittinge. WVMARC. threwgh the technical management of Etkl.
developed a awltifstated program to aselet utilities in addroeting this bulletin. 14betstory testing of owspect meterial the sempliation of utility test date and analysis of that data are reported. These data show in general that, estept for blind flanges, the svetect material meets tonelle strength retuitetente and is eatiefettory for ASME Code applicatione. The hardness testing reewlte for the ease seteriale achibit a broad stetter band which wowld jwetify application of a testing tolerante band in epoperison to the ASTM A370 eenvereien fres hardness to tensile strength. The field and laborettry testing results both enhibit the some broad statter band. A lateratery generated best fit surve le weed to relate mesoured field hardneee to tene!!e strength.
The field hardnese teet data for 1336 (tone show the same statter band as fewed in laboratory teste, and follows the sene general bell ehete hardnese distribution as labetstory hardnese teste. The siellerity in shapes and the lack of buere at either the low ende er the high ende of these laboratory and field histogrees indicates that there le not a sentern for new strength
' material or high strength asterial. Applying a best fit approath fres leberatory hardnese and tonelle date to field hardnese data reewits in an e s t iea t e o f et tength. The best fit appresth to the field data indicates that i
the vast nejerity are acceptable. Saeed on the laboratory testing and estensive field testing it is sentlvded there le me materiale problem, estopt 1
possibly for some blind flanges.
Blind flanges and other sosponents were addressed analytically in the WUMARC generit snelysis report, and it was shown that in the majority of seses there would not be a strees sentern even if strength in the order of 40 E81 were to be soevsed.
This interia report cent.udes that the seterial has etteptable attength and estept fer seat blind flanges is satisfattery for AgP.T Code applicatione. The sentinued use of these flanges and fittinge does met present a safety probles.
Retecoendations are sede for fellev-wp activities.
i t
.g.
11ths 1
NUREG-1402 A-18
_~
l NUMAtc CtNERIC TElf!MC PROCRAM RESPON$t to NRC SULLtf!N 88 05 t
v INTERIM REPORT TABLE OT 00RTEN75 Pete A987AACT................................................................
i T All t O F C O NTE NT S......................... '..............................
{i 3
L 18 7 0 F I LLU $ 7 AAT 10N $................................................... iii INTRODUCTION.......................................................
1 SACKCROVND....................................................
1 N UMA RC M VL71 T Act 7t b PR OC AAM...................................
1 CENERIC $7Atl$ ANALY$!$ (Refer to Previeve letter of t r a n s mi t t a l t o WRC )........................................
1 FVMA R C TE S T I N C PR DC AAM.............................................
1 NETHODS.......................................................
1 D AT A C0 HF I LA710N AND RE S ULT S..................................
2 AKALY$1$...........................................................
2 LADOKATORY 7tSTINC............................................
2 EQUO71P TEN $1LI C0kAELA730N..........................s........
2 U T I L I T Y TE S T I N C...............................................
3 F I E LD KAP.DNt s $ T O 7 t N$1 LI.....................................
3 SLIND TLANC15.................................................
3 4
D ATA QUANTITY AND $7 AT1871 CAL SICHITICANCE....................
4 TE S 7 ! N C S UN%AR Y...............................................
4 T O LI RAN C E S LOWL R AND UP PE R....................................
$7AINLIS$.....................................................
CONCLV$10N$........................................................
5 AEC01<ENDA730N.....................................................
5
$ U r? ! KD R E CO RD S R E VI EW........................................
5 l
CO MP LE T E LA R P R O C AA M..........................................
5 COMP 2 LE E X 15 71 N C T ! E LD TI ST D AT A..............................
5 W R I T E T OLLO W-O H RI PC R T........................................
5 l
, l l
318 9m
(
NUREG-1402 A-19 r
s l
L187 0F ILLU$7AA720Ns i
I Tant s Table l' lumery of High krdness Limits Table 2 Sumery of $tainless Steel Teste 1
I l
T1Ct4,I $
Figure 1 Histostam of laboratory fensile Results Figure 2 Egvetip as SMN Coopered to UTS and ASTM A370 i
Figure-3 Best Tit Equetit Coopered to V7$
Tigure &
Histegram of Laboratory Hardness i
Tigure $
Histogram of Field Hardness Figure 6 Best Tit Dets Applied to Field Hardness q
M 9
9 h
y
[
'j I
-lii-11833 L
NUREG-1402 A-20 l
L i:
~ -.. -. -
- ~ - _. -.
t ter710 DUCT 10N l
SACKCROUND he NRC issued Bulletin 88-05 regarding elleged f alsification of Certified Meterials Test Reports (Of7Rs) by West Jersey Manufacturing Co. (WJM) and Piping systems, Inc. (ps!). Specific actions were required of utilities. Some i
of these could efficiently be addressed by a generic progrooi. IrUnf.RC lnit ia t e d such a program..he NRC issued Supplement 1 to 48*05 subsequent to reports of two blind flanges having low tensile strength. he suppleoent required
?
utilities to perform field tests on identified inets11ed WJM/p31 items. he supplement also fetused ef fort on piping.'langes and fittings. he FMRC progree was modified to coordinate and standardiet field testing methods and to tempile utility generated data. Concurrently, the generle NUMARC leberatory testieg progres has been in prestese.
F M RC MV2.T! Tact 7tD PROCRAM Secause several actions were required by 88 0) which could be effitlantly addressed in a generie manner, NUMARC undertook 4he attivities described herein as well as the testing and test data analysis wh th are the subject of this report.
A.
Review of records to persit scope limitation.
'8.
Review of records to identify intermediate and setendary supply routes.
C.
Interf ace with Authorised Inspection Agencies and the Nations) Sosrd of Sciler and pressure vessel Inspectors.
D.
Generie stress analysis of fittings and flanges.
E.
Testing, data compilation and evaluation.
1 CINERIC $7p.ts$ ANA1.Y513 he generic stress analysis has %een seapleted, reviewed with and provided to the FAC. he analyste indicates that there is little concern for the stress integrity of the fittings or flanges even if the materials were of substantially lower strength when coepeted to the strength requireoents of SA 10). his report was forss11y trenesitted to the kRJ by FMRC on July 22 1988.
The testing program is described in the folleving section6 of this repcrt.
FMit TI$71NC proct.AM j.
MITHODS-i l
his program contains two asin elements: first. comprehensive laboratory testing of suspect itete contributed by utilities; and aetend, utility generated data of destructive laboratory tests and in situ teste of installed suspect items.
lith 3
NUREG-1402 A 21 L
u
1 i
WUMARC laboratory test methods follow At7M standards for tensile testing to produce valves for V78. Y$ IEl and thA. Tensile strength terrelations were developed based wron Equotip testing. Osemical analysis wtilisse l
spectrographic analysis and portable Karay fluorescente analysis methods. All 1sberatory testing equipoent is salibrated to appropriate standards.
Utility test data of installed items er warehouse itens has principal.ly been portable hardness testing by means of the Equotip device. Other hardness test devices may also have been used in a few instantes. The basis for eclection of hardness test methods and the WUMARC training / coordination have been described pre vious ly.
{
i For austenitic staintest steel items, the principle testa method has been a simple magnetic theck. Some alley analysis and replication metallography have been perf ormed.
To the estent that utilities have tentributed 1sberatory test data, these data has been accepted. These data are being reviewed for consistency and errors.
i DATA C0Hp3LA710N AND RESULT $
Generic laboratory test data has been developed for 123 (tems to date contributed by utilities.
To date, the utilities have provided data regarding 1334 field hardness test itens and 100 tensile results. The results are discussed in the following analysis. The actual amount of data used in this report is indicated en the plots or charts. Not all data is in the computer data base.
NUMARC has provided the NRC with toeputer discs and printouts as of 7/19/g3.
Some additional topies were provided during the July 22, 1938 eeeting.
ANA1Yst s LA50AA70RY TESTING All tensile test results esteed 70 K$1 or are within the anticipated tolerante band. Figure 1 shawa a histogras of laboratory tensile results. In general, field tests were perforved with 10U071P testers and the data converted to SHN.
For reasons discussed below. EQUO71P values are weed in this report.
1 Figure 2 shows a plot of laboratory tens!!e results and EQUO7!P hardness expressed as SHH data. Almost all the hardness data points f all at er below the ASTM A170 BHN tensile converef on line, indicating that this is a conservative approach, and that a test tolerante factor is required to avoid inappropriate rejection of atteptable material by field hardness test methods.
It is apparent that the BHN tensile conversion approach is no longer oppropriate for this application.
IQUOf tp*7tN$1LE Coh*iER$10N Another more atturate approach to assess the field hardness data is to develop a best fit line for the laboratory hardness using the original EQUOT!? (also referred to es L4eb values) and tensile data. Th a t line. shown in Figure 3, wa s developed by toeputer progras. The application of the tolerante or the li t hm
~2*
NUREG-1402 A-22
~%
1 best fit appreath are discussed below subsequent to a brief analysis of the wt!!ity field data. The h!stegree of laboratory hardnese data espressed in IQUc71p values is shown in yigure 4.
U7ILITY 7t$71NC The utility-provided laboratory data is consistett with the generie progras test date. The utilitiee have provided ent set of data en a blind flange.
West 7218 which is tensistent wi'th th's two teste cited in 88-05 Supplement 1.
This data point is not yet in the temputer printout. Other than this, no subetrength esterial has been reported based on tenelle testa. These ut!!ities have reported tenelle strength for 100 itese. Eight itee-o slightly below 70 K$1 have been reported. The ressining 101 values esteed 70 R$1. In one saae the utility engineer indicated there wee e subelse specimen removed free installed flange and was transverse to the primary working direction esther than parallet. These slightly low values are readily espleined by the test direction, and by published data which confirme that tonelle test teoults fran product testing may be se such as 10 percent below the minious specified strength. Mene of these utilities reported strength values are a sentern.
3 The utility generated hardnese data is shown in the histogres of Figure S.
This histogran has the same general ball shape as the histogras of laboratory hardnese data. In eleple terne, the bell shapes in both laboratory and field histograse and the leth of bumps at the new hardnese ende of the histograma indicatee that there is not a concern for low strength satorial. This seene that the vast osjerity of fleid (tees would esteed 70 R$1 if tested and that the ressinder would be within the espected tolerance band. The sent19sion le that installed itene are atteptable and do not present a saterial tentern, ascept for some blind f1seges.
T2 ELD KAADNI$$ 70 ftN$1LE It is appropriate to toepare the best fit curves of laboratory hardnese end tensile results and apply the results of that plot to the utility generated hardness data. When this is done, refer to Figure 6. all itese are shavn to be acceptable. It must be realised that a best fit surve of field hardnese should never be weed to reject installed itete, because arme stese which f all below the line can be within the acceptable tolerante band. This is shown by the f act that the original data had ease atteptable itete below the best fit avrve. The best fit curve way be applied to warehouse items prior to installation, and should not be the sole justification for renoval of installed itese. This curve increasee the confidente that the installed itese are as initially intended to be.
BLIND TLAN0t$
L The best fit curve applied to field dets, or a field hardnese test tolerance L
doe e not eliminate the f act that there are dets in the histegrass (but not ye t in the tor.puter data base) which indicates that blind flanges may be a concern f or strength reasone. Howeve r, the stres e analytical dat a provated to the NK; indicates that these substrength blinds are not a ett'ess probles for service conditions.
c 11 t he.
-)e NUREG-1402 A-23
The lowest hardness test result in either laboratory or field, aside free the suspect blind flanges, is 350 tp. his is the lowest of a sentinueve opectrue of values. The 13 suspect blind flenges are at appremiestely 3301, and appest to be a unique group seperate from the general population of acceptable seterial.
i 3ATA QUANTITY AND $7A72371CA3. 83CN!FICANCE Analysis indicates that there are sufficient field data upon which to draw conclusions. There (e no need for additional field har'dnese data. b ore le also substantial tonelle test data which perv.ite testerin conclusione Noteperametric tolerance limit statistical calculations were used. be 1eberstory tensile reeutta of 123 itene provide 95 percent renfidence that eers than 97 yercent of the population esteede 60.600 poi tenelle strength.
The ut!!(ty provided 100 tenelle test results provide 95 percent serifidence that more than 97 percent of the population esteede 66.400 poi tensile attength.
Aseveing the materiale some free the este population, see.bining both este of tenelle data provides 95 percent eenfidence that more than 98 percent of the populatsen exceed 60.600 poi ultimate tene!!e strength. Sie!!stly, there is l
t$ percent confidence that more than 98 percent of the population is less than 93.200 poi ultimate tonelle strength.
TESTIN; StfrptARY The laboratory tenelle dets indicates there le no technical tergern for the t-SA 10$ esterial be eisitarities between the laboratory hardnese distribution histogram and t'..e field hardnese histograms indicates that there should be no I
concern for installed iters given that the laboratory tensile tests iedicate no concern for this seterial. The best fit turve of hardnese to tonelle l
senversione applied to field hardness teste slee Indicates that there is ne sencern f or SA 105 esterial.
701.tkANCts LOVER AND IftetR The data indicate that there is me rest concern for SA 105 saterial. The blirid l
flanges of suspect material which have lov tonelle valute have hardness at appremisately 330 to.
Regarding high hardness. Table 1 shows the precedent to install sateriste over 187 BMW to 207 SMW which are cosmori fri nuclear plant pitihg. his table shows that 237 SMH is a value comoonly applied to f abricated items, welds, base metale end RA2, where H;$ etress corrosion cracking (SCC) is a concern in the petrochemical industry. Such SCC (e not a concern in light water teatter piping and thus a specific upper litit should not be imposed. De Structatal Welding Code applies a 265 BHN limit on subserted are welds and KA2 to secure adeguate strength, ductility and toughness. Wen recognised standards apply values such as 237 and 265 3HN to f abricated, welded and ir, stalled itete, a specific upper hardnese lirit i s not justified. This paragraph le discussed in SM H t e rze b e c a u s e t he Co d e u e s e SHN t e ru s.
The principle high hardnese concern is weldability. If the (fittalled itet has ecceptable weld inspections, has sustained bolt-up loads, hydrostatic teste.
proef te stirig. functional tes t and whatever p$1/151 that is applicabtr. then 313 5e NUREG-1402 A-24 a
4.-
-m
- m
_ _ _.. _ _ _ _ _ _ _ _ _ _ _. _. - _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ - - _ _ _ +., -
~
there are objective reasons to wet as (s. ne benefits of replacing installed high hardness items with acceptable welds and MA2 are minimal. In contrast, the risks in any replacee6ent are greater. The ALAAA sensiderations also indicate that high hardness itens not be replaced unless there is a plant-unique overriding eencern.
STAINLi$$ $71EL here is a relatively small amount of stainless steel inetelled, and very little in warehouses. To date, all tests perferoied on'steinless steel have been acceptable. Approminately four dozen itees have been tested. All tensile results are acceptable, all chemical snelyses are acceptable and all sensitisation tests are acceptabla. Approminately 10 desen magnetic checks were also acceptable. Only one of all these test results le slightly low; that is, one yield strength value was 28.5 R$1 vs. 30.0 K$1 and this dif ference is insignificant. These tests are summarised in Table 2.
wh!!e the absolute number of test results is not as great as for serben stest, the results indicate there is no concert.
5 CON 0ttf$10N$
The strength of SA 105 material and stainless steel itens which were suspect is mo t a c onc e rn.
, Rt COMMICATIONS 1.
he test results to date indicate there is no concern for materials and thus field testing may be suspended as there is sufficient data for e valua t ion.
ne generic stress analysis also indicates there is no concern for l
Plausible low strength sateri41s because it has been shown that even if
(
substrength materials were installed, the vast majority of these esses would be acceptable. bus, it is appropriate to suspend document reviews and field testing.
l l
2.
The laboratory progres should be completed subject to constraints of available material.
l-3.
ne existies utility generated dets should be compiled and analysed in the WMARC progres.
4 A sumary report should be generated.
l-l l
11th l l
NUREG-1402 A-25 l-o l
i i
LABORATORY TENSILE RESULTS as <,
{
do<
30<
NUMBER OF 25<
CASES 3o..
is, i
g
[
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,m c-eso all
>70
>78 Sto all oso TENSILE STRENGTH (KSI) -
l l
Data as of 1/32/SS 1
1
{
T10. 1 HISTOCMM OF LAbOMTORY TEN 51LE RESULTS l'
NUREG-1402 A-26 C
l--.~
,,4-,-m-,-
.,w-ww..
v-.-,
i l
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LABORATORY HARDNESS VS.
go a===
TENSILE STRENGTH c-5 g!;s n w ime
,es.
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.a 878-ygf ag5 a
a a
g EQUOTIP AS see <
4 gg r
e SMM ise<
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r
,,'4" a g,a' / f HARDNESS im<
4 r,
& a,a a#
, a, I
32e <, a s
393<
a 333 68000 6 Sees 7eem 7500s 00006 85004 9000s 95600 l
TENS 8LE STRENGTH 8%
6u E
9
---.-- -a--
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l Etwetlp M64nese vs. Unimste Terelle Stength um v n....
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se soote same vacco nas step asze some essoo L'"" T* W M Data as of i
7/22/88 F10. 3 BEST FIT EQUOTIP VS TEN 51LE STRENCTH l
l NUREG-1402 A-28 r
- ~.
.....,7
.-.-..~...._.-......,..--.u._.-..,.._.___~_4
- _ -. _ - - - -.. -.. - -,.. ~...
q t
L l>
4 l
J
.i L
,,"jj,",T,,
SA 105 LAB EQUOTIP 45<
I 40 Sla 30 HUMBER OF 25<
CASES go.
15 I
10<
Sa sPe
~
0
<348 348 364 381. SD6 410 434 437. Af > 463 475_ >4t6 4
363 380' 395 409 423' 436 449 462 474 486' HARDNESS CATEGORIES j
Data as of 7/22/88 i
TJC. 4 ~ HISTOGRAM OF LA& ORATORY EQUOTIP MAADNESS 1
f NUREG-1402 A-29
- ,fj
. - - ~,. _ -,,,...,
i 1
r I
i 4
i i
i SA105 FIELD HARDNESS DATA Da* ** d l
me.wyases 2;
350-G
)
i ase-e.
gg
- ase,
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0 8MMASER OF - 200 -
8 7
f
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CASES 954<
t;3 4
4 YC
- 100, 504
=
=
4348 34& 364-3st-396-4s& 424-437-45& 463-475- >486 363 300 395.409 423 436 449 462 474 446 l
l HARONESS. CATEGORIES.
[
+
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i 1
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i 5
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f Oburvations l
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kdb.$$$5 et
.. 5 ? ~ v,,,
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l
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i l
Data as of 7/19/88 FIC. 6 BEST FIT DATA AfPLIED 70 l
FIELD KAADNESS l-STAENGTH EST! MATE l
l n
NUREG-1402 A-31
~
-. ~ -.
I j
p-l 1
TABLE 1 St>H4Y OF HICH K2DN155 LIMITS r
l HAX. HARDNESS LIMITS v
i N
SA 350 197 SA 105 PRE 1972 N/A i
i SA 105 POST 1972 187 ONLY IF QUENCHED l
SA 234 WPB-SUPPLEMENTARY 197 4
F2 192 F 11 207 F 22 207 l.
l AWS D1.1 WELD & HAZ, HV280 265 NACE HR-01 75 Rc22 237 l
l-(
NUREG-1402 A-32 i
m-y
/w--ewyyw-e e-
- W *--
es e
u
-y--,--,=
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-eg w--er+-
u-.a-----#
-w
-w+=
-'=-a'-
e
I i
i TA Lt s m a y or stA m tss m et itsis 1
STAINuss RESULTS i
7/19/88 TENSILE 9
HARDNESS 8
CMDGSTRY 44 SENSITIEATION 38 L
MAGNETIC 120 t
I
)
l l
l NUREG-1402 A-33
Attach #hent 2 kRC8 88 05. Supplement 2 August 3. 1988 I
Product Fems Sold By WJM/P51/ Chews Landinc Flanges Half Couplings full Couplings Plate kings Penetration Plates.. $A516. GR70 Socket Weld Nottles (CLM)g (Ferry)2 Seal Plates.. $A516, GR7 Long Drain toss.. A162F11 & F22 Radiograph Plugs (CLM)
Square 6ar -
1016 Spacers Ser$le Probes Class 1 5A312.1304 (Perry) (CLM)
Guide Lugs.. $A240.1304 Socket Welded Half Couplings Class 1 5A182. F304L (Vogtle)
Special ho:21es Pipe Caps. 5A234 tups - 5A240. 1304 (Palo Verce) tugs -- 5A516. GR70 (Palo Verde)
Sectet Weld Coup 11pps
, Plate -. 5A36 (Perry)
Special toss - A234. A105. A739 Solts - 5A193. GRB7 (Confrentes/5 pain)
Jtstrument Penetration ind Plate -. $A516. GR70 (Perry)
Henger Lugs.. SA516. GR70 (Dravo /51te unknown)
Socket Wele 6 css -- Class 1 - SA182. f316 (Seabrook) (CLM)
Transition Piece. 5A105 (Vogtle).
Thernowells - A182 (Dravo / Hunter / Site unknown) (CLM) 8ar Stock -- A105 (Oravo/ Yellow Creek) (CLM)
This is a complete list of a11 product forms identified during the NRC staf f's review of available records.
2 Specific nuclear power plants or customers are noted in cases where the product form appeared to be a unique or special order and not wide spread.
3 Jndicates that material was sold by Chews Landing Meta) Manufacturers Inc.
NUREG-1402 A-34 l
i j
l NACB 88 05. Supplement 2 l
Aup6st 3. 1988 u
i I
I huclear Plants Receivinc $uspect Materta1 Seaver Va)1e'y J
Sellefonte i
Browns Ferry Callemay Calvert Cliffs Cock Diablo Canyon Duane Arnold fermi Match Montitello North Anna Prairie 16)and Quad Cities Shoreham' Tur6ey Point Waterford c
Yellow Creek 21erer r
Y I These nuclear power plants are in addition to those previously identified as receiving suspect material.
t NUREG-1402 A-35
3 1
6 NRCB 86 05. Supplement 2 August 3. 1988 i
Purchasers Atteivinc $Utpect Materia)I
~
Barr Saunders. Inc.
v
-Lake Crie pp (became Division of Pullman)
M.W. Aello Jron & Metal Co.. Inc.
Liberty Equipment. Co.
i.
Fatal Bellows (listed as 6e110ws in pulletin)
Power Piping Co.
Standarcs Fipe & Supply Co.. Inc.
Tioga Pipe Supply Co., Inc.
lyler Lawson (listed in error as Tyler Davison in Bulletin) b t
?
)
i i
1 l
i 3 These purchasers are in addition to those previously identified and are j
known to have received caterial for nuclear applications.
NUREG-1402 A-36
- _. ~. -. -
NRC8 88 05. Supplement 2 August 3. 1988 L157 0F RECENTLY ISSUED hkC BULLL11NS Bulletin Date of he.
Subject
!ssuance issued to 88 08.
Thermal Stresses in Piping 8/4/88 A11 holders of OLs Supplement 2 Connected to Reactor Coolant or cps for. light.
Systems water. cooled nuclear power reactors.
88 09 Thimble Tube Thinning in 7/26/88 A11 holders of OLs Westinghouse Atactors or CFs for E designed nuclear power reactors that utilise bottom mounted instrumentation.
L 88 08, 1hermal $ tresses in Piping 6/24/88 A11 holders of OLs Supplement 1 Ccnnected to Reactor Coolant or cps for light.
Systems water cooled nuclear power reactors.
66 08 1hemal Stresses in Piping G/22/88 All holders of OLs Cennected to Reactor Coolant or cps for light.
Systems water. cooled nuclear power reactors.
i 88 05 Nonconforming Materials 6/16/88 A11 holders of OLs Supplement 1 Supplied by Piping Supplies.
or cps for nuclear Inc. at Folsom. New Jersey power reactors.
I and West Jersey Manuf acturir.g
. Company at W1111amstown.
New Jersey 68 07 Power Osc111stions in 6/15/88
. All holders of OLs boiling Water Reactors (BWRs) or cps for BWRs.
E8 06 Actions to be Taken for 6/14/88 All hkt licensees the Transportation of authorized to Model No. Spec 2.T manufacture, kadiographic Exposure distribute, or Device operate radiographic exposure devices or source changers.
OL = Operating License CP = Construction Pern;it NUREG-1402 A-37
.m j,c w
.~.,..
f id j
g.
[4 APPENDIX B
SUMMARY
OF SIGNIFICANT LICENSEE RESPONSES TO NRC BULLETIN 88-05 I
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- U FTt C3 AtLDE_5MitfUCARLLICtH5tLRESE985ES._fe 6mia sa:95 S'
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. set. opes SfmeCue as'D TDr5TIFICartes "
YtsTtac enctisitetac fvatJamtress M
Tetet haber.
' 38eeber W
paher hsher Cheeteel f%yeteel thamhet taptenee tg atSULTS m
geweber toetstled lastelled.-
te sneceounted tee ttp peepeety -
propetey of teeteetten peceteed In Safety la 38**-S*f*tF seceansee. -
rev Teoted &
Teoee feete Jay's seeched are TTaTes peset te Systees Systeme 39 yleeg,e 343 34* -
12 219 Testede WR
~ pt it aceees.
~ IIe
- Teest am and 1stetten of 72 e 137 Buut inaccett, e.
een-eefeey.eeteted esteetete 2 Fittlage too = 303 ese yet -
eates teeted eteleteos preet 127,307 SIWI
- tch = 267 fleagee (9) and flottage (3) angeetteetly, and ett woe.
seeepeeble.
- a geneete gootteettee seg hoe been peepeeed to ederees
[
ett the taeceeeethle (one eateetedleefety-eetated eeeee t et e,
De forehow settees plassed.
myggf CitFFS et Fleages-34 6
3 0
91 Teerd 25 t$
N Wle att Mew floagee yt.
eiet ete fled for essest8es. IIe t
G e I)? SuGI attieetF terepat ce ptsamed.
ggy t.se.13I O e 107 9105
- se forest,eeerde gogg' g,e CI3 e
e 96 Mi*
22 Teeted M Teeted M Teeted '
2 festeeeetog IV C.ATAtita 1 ead 2 413 Flangee t
- 837 SeWI 16 accept, le accept.
Joege eet e*a-eefety-eeteved..
e.
26 8houher end locettee of to.
Lee = B)6 beeed on 1
I e IS7 SIGI speeeg lag etetted floagee end eneee whet 5:g4
- fit teede
- y be seveyped. sold ete.,
ere ese beoese,,
a dee peseteast enestnetlee of e semple blind flenge le elemmed. We othee settetty pleamed.
III I49 feeted O
O 93 ragteeeetag
- 191 floages met to oefeey.
130 veteeed eyotees ese to seeet ctgpfgur t 446 Flease.
ile 137 gust 3magemeet see either teetetted to een.
A beoed en Lair
- tie D
- 197 Sugt mereee emetyeti eefety eyetees ee eeld. all peefereed and defle teet floages found speeet tag seeepte4to fee opeeeeten. %
resolderettene, etete***e em feethee cettetty.
t See f ecemetee et end of table.
~
-s-J t
.m.
wt Pact 2 C
. 3 rft C3-
. [
$E9l$(WIG 4IUC8ElUCER5EE RE529ssts MMmte M Jh itSTlac esctmetatec tvatJnittopS O
pecceDS StArcts apt > tDeJeftrtcaTIcst FtApT Tetet gebee sheebet somber shaabee em Chotest ywyetees shahee togt.eeeg.g eggytyg mast per Iae'*II*d I****II'd I*
18"******'**
'9"*'IP
*9**ty tempoety of teelemetee Secetoed In Sefety in pen-Sofety 1perehe.se Fee Teeeed &
Teece Tesee JCD*.
fteched opD STATW5 Seoulte Systese Syseeme et feeeed O
O que se att eneeeeed fly se egeeg e
3 to 84 9
toes *4 *en hid*.
"
- R 37 8H' D.C. Corgt 97 riangen i anaf 2 t
- IGF SEEI
- 29 fleagee steettsted ee tejst eene free e tetoe perehees
- edees.
aet tetete, _
per Seppt. 2.
Coott1 STAft008 S4 Fleasee 2
2 30 0-St feeeed 0
0 S
et*enst geneete pen-eeteeyweteeed fieagee see
- lette
- aelde**d seeepeette beeed on 24 e 117 9858 tow
- 123 stsempC date eetshteentg a 129 E'W' ** e tesel etateus. se Oe 19F SIBI fecehoe mettetey pleased peter to meet sofeettag outage.
CRYSTAL Rivtt 3 52 Flossee 24 0
23e 4
24 feeeed+
0 0
19 m
et edetetenet flease to to ese to mea-eyeeee egespeeme.
19 e $17 SIGI eteet espeete fee te fleage.
tew 329 seee the esage of heedmeeeee.
O e 197 SIBI No fetehoe acttetty lasteeeed.
t II
- ' ***-** F #*I ** **
Daft $ BESSE B 279 Fleagee 23 WE M
88 t.A7 floages, eaty the it
- eesde
- I8 e 337 9858
.me,e.ac. esit.ete -.
p..
e.ee t.. Total==sebee ea=megeted.
t,M e 147 OsEt t-ci.ee
-ht es.Ii e.wie
.e.ad aetteley _
? pee Suppl.
2.
12 Sun a
ya 0
12 T m ed 12 Twed 4
testaneetag N eetet eewtee teeeed.
8 keept.
te accept.
onetyeto et settetey -
per DIA9tO CApTOss 23 Fleagee tedeced.
Seppl. 2.
I eM y.
eeteeget and eeeetce rendit tene
,,e 2,,
1,.
=
=
uttet t i.e e_.d.e,.ee t
fleages seeestle; to et
(
,,,,,e,e, pleet had he e seceeed. Se j
y,g 3 feces.e Gefees t.e.e mettetty et ehte stee, i
f l
5+e feeeeeeee se end of tente, u,
2
.m ~
~
-a 7
s-
.s-z' C
rect.
-:o m-c>',
. SpotastLOL.516stILICARLLICO5tLttimists_Imum sa:95 m
- afcotDS stAa W mpp IDepTYFICATION TfSTtsc EPCIWttSINC (TatDaf t0PS FtAFT feest
- 88*'h* F
%' hee IBuehoe.
peeber he cheeseet phys teet ouder tagtaneetag 9tSetTS wg neuebee testelled tao + elled '
to Oneccounted temettp Freperty Peeperty of testeet ten Deceteed la Sof"F t" 8**-?*f**F
. W***heese roe toeged &
Teete Teege Jce.,.
aseehod afsD STATUS Doeotte Syerees
-Syst*=5.
geygsg aspectD 38 Fleasee 33 0
ft*
'Oe
& Twed 26 Teeted M Teeted 0
E*etmeettaa of eteet nesgee see, ese g 3 e 337 31st 24 Accept.
23 Accept.
onelyeto beoed to penettee eettleg eempte. e Emo e 120 ce vedeced fleagee seropped petoe to S > 997 Bugt eteengehe per Sellette 90 95.-
eest end.
propeteeten of JCOS sad ethPe ep*fetlag setteley euepeaeed pee Sget.
eeget resemes.
2.
tatt 3 montenforetag to.
eestted fleases accepeeble fee eyee st gen. )
FA91.ET 1 ag 2 444 Fleageoe dose il 13 0*
B2 Tw d I feeted 0
12 ut e30s wetalese fleage, e.g t.
O
- lif test I Accept, teetty teeeed.
Se 197 anos ett fiengee pee =teesty dee.
peone of (fee men-eef ety.
esteted opptteettene).
We feethee settee.
ritpft 2 494 Fleeges 176*+
4 3e.+
43 144e+
IM Teeted e Teeted 4 Teeted 46+
2 Moyen swee IMm egoetly 9 e 137 engI 4 Accept.
4 Accept.
tested etth 24 eweelde ve.g.
m, of eeeepeettlety, Law = 33e 3
l6 o 147 set
- Gecese seeeeettle hteg estese saa teeted eftee sco gleh 3 220 em eed thee oce.,eeete.
e
- The lee easeeeeneed any feeteee eene taneetted en me, eefety-eeteted eyetees se went se these eeld se eueptoe, e othee, ese basen to have been seeptee.
se forehoe settetty mee, FIT 2 FAT 91CE 10 Fleases 0
0 90 0
0 0
0 e
se att to fle gee t eew for non-sofety-related opplice.
i ttee. Woe em 9eetter teatret t
" hold to moreheese.' pe
[
I feether settetty fasteeted, i
see feetnotes et end ef emble.
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-.g .e f.~ r Pect it h - tvt : O StROMtT_9EJ1GstIEICAIIT LICLE5EE Rt529H5t1Je BK OWLLETre at-95 .Em SECORDS 5fARCat AND SDerftFICaffdII TESTtWC SPCtWWE9tWC ifuiii=Tf0pf PLAfrf f*tet puebee Ipuebee w thumber shambee Chesteet Phyetest themhee. Sgteseetag gtggttg paper pueber-testelled testatted to heounted . tgweety Feeperty Peopeety of tveteette. Reces,ed to Safety in pen-Sofety Wegetesese Fee. Tested & Teets Teees JCD's method. app STpTTI. ' #**st to Systees =Systees ttggggycas 3 334 Fleesee 260 223 838 83 212 Tested SIR 8R 8 Campeeed 9**eek e.,tege. Toegsg t e 337 geur elleeable facompleee, ewetweet no ime = 120 steessee fece eemplete. mettetete. S e t97 Sist heedneee toets onepended to teteeleted
- Streeeee, tsoLF CRffE t 733 Fleages 3t9 SS BR 8R i 4 T*eees e feeeed 5E le 88 9**eet esertete. Teeel*e see-10 e 137 pest 4 accept.
peaded. Omettesetoe sto pee. 1,se
- 122
- 1 doe lateele Joselfteetten -
4 e get suur fee fastelled seeeniet. 14 - sigen e 2)$ Wttettee* JCOS for boedmeee teet fetteree. escotwed feen WJeg ee est.*I TApetre mout 1 0 ~ ~ ~ ~ ~ ~ ~ ~ $2 9 @e feettagl M be
- WIBupC geneete e.etweetoe Etcut t and 2 244 Flenges ag2e (JCD) fee to sotte, py,g e.ug g
Seete=*ed peefoeese eegag p lowee tegna yteld. 27 es, and 1FTT = 44 Det. Thte gaaef fe testifteettee to erpflesete fee emmy flengee te Deeedom. Quod Cttlee,end 2 ten. MR
- Not reported by itCensee SHft
- Brinnel hardness egaher toe
- tonest BHN walge.
Mfgh = Mtghest SHN value 2 Average SH'l value Avg = Not determined by ticonsee because of sospension of acttwittet on receipt of $upplement 2 NO .. ~. _....., - ~... _ _
- a. -
i I i APPENDIX C 4 CHRCNOLOGY OF MEETINGS, TRIPS, CORRESPONDENCE, AND
- 1;
- DOCUMENTS PERTAINING TO NRC BULLETIN 88-05 AND ITS SUPPLEMENTS May 6, 1988 NRC Bulletin 88-05 issued, j l June 15, 1988 NRC Bulletin 88-05, Supplement 1, issued. July 22, 1988 Meeting at NRC's One White Flint North office at-which NUMARC provided reports entitled " Generic Analysis and Evaluation of Suspect Material Identified in NRC Bulletin 88-05" (prepared by [ Bechtel Power Corporation).and " Evaluation of 3 Temperature Effects on the Equotip Hardness Tester"-(prepared by Electric Power Research ' Institute (EPRI)). July 22',-1988 - Letter from W. Rasin (NUMARC) to T. Martin (NRC)' submitting Bechtel's generic analysis and EPRI's Equotip temperature evaluation reports, j p . July 25,1988 Letter from W. Rasin (NUMARC) to T. Murley (NRC) j, regarding NRC Bulletin 88-05, i July 29, 1988 Letter from W. Rasin (NUMARC) to T. Martin (NRC) 1 regarding NRC Bulletin 88-05. L l I.: ' August 3, 1988 NRC Bulletin 88-05, Supplement 2, issued. l-l l l L j NUREG-1402 C-1 02/05/90 t 9
Y i H x+- o I 1 August 22-23, 1988 Trip to Georgia. Power Company's Vogtle plant, Waynesboroi Georgia, to obtain information and-observe field procedures relative to licensee's l capability to respond to NRC Bulletin 88-05.' 'l September-26, 1988 Summary table of licensee responses to NRC Bulletin 88-05 provided by Brookhaven National Laboratory "~' (BNL) to the NRC. September 28-29,_1988 Trip by BNL staff to NRC's One White Flint North i office to review and summarize licensee submittals-in response to NRC' Bulletin 88-05. ' October 7, 1988 Memorandum from L, Shao (NRC) to S. Varga (NRC) regarding criteria for resolving NRC Bulletin 88-05 issues for near-term operating license plants. 0ctober 13, 1988 Status and review' meeting between BNL and NRC. staffs at NRC's One White Flint North office to review status of' activities related to NRC Bulletin 88-05. October 27,_'1988 Meeting at NRC's One White Flint North' office at. which NUMARC presented.its-final report regarding NRC Bu11etin-88-05. October 27, 1988 Letter from W. Rasin (NUMARC) to F. Miraglia (NRC) l submitting NUMARC's final report. L L November 3, 1988 Memorandum from L. Marsh and C. Cheng (NRC) to D. Brinkman (NRC) submitting safety evaluation report for Seabrook Unit 1. n e l' November 4, 1988 Meeting at NRC's One White Flint North office at i. which Georgia Power Company provided its response I to NRC Bulletin 88-05 for Vogtle Unit 2. i l= l - NUREG-1402 ~ C-2 02/05/90 l j i
E p i + V * &: bo November ~16 and 17, 1988 Trip to Sechtel Power Corporation office in San Francisco California, to discuss-the generic analysis and evaluation report pertaining to NRC [ Bulletsn 88-05. December:9,~1988 Letter from L. Shao (NRC) to W.-Rasin (NUKARC). requesting additional information. December 15, 1988 MemorandumfromL.MarshandC..Cheng(NRC)Ito G. Dick (NRC) submitting. safety evaluation report 'for South Texas Project, Unit-2. December 1988 BNL Technical Report MT-3851-6, " Testing in Support of NRC Bulletin 88-05, WJM/ PSI Flange Evaluation," by C. J. Czajkowski, issued. January'9. 1989 Letter from W. Rasin (NUMARC) to' L., Shao (NRC) regarding NRC Bulletin 88-05. ' February 3, 1989 Memorandum from L. Marsh'and C.lCheng (NRC) to. J. Hopkins (NRC)' submitting safety. evaluation report for Vogtle Unit 2. ~ February 3, 1989 Memorandum from L. Marsh and C. Cheng (NRC) to S. Brown (NRC) submitting safety evaluation report for Shoreham. February 15, 1989' Letter from F. Miraglia (NRC) to J. Colvin (NUMARC). requesting additional information. U June 15', 1989 Memorandum from L. Marsh and C. Cheng (NRC) to R. Clark (NRC) submitting safety evaluation report for Limerick Unit 2. L 1 p. August 30, 1989 Letter from W. Rasin (NUMARC) to F. Miraglia (NRC) submitting supplemental generic analysis report. L 'NUREG-1402 C-3 02/05/90
r,p i: [' '..
- November 2, 1989 Letter from F. Miraglia (NRC) to W. Rasin (NUMARC) requesting' additional information on NUMARC report.
November ~ 28', 1989' Letter from W. Rasin (NUMARC) to F. Miraglis (NRC) - i responding to request for additional.Information. j 'I l a 'l I I i i T .t I i sj e r 4 NUREG-1402 C-4 02/05/90 g l. a. )
v t APPENDIX 0 PRINCIPAL CONTRIBUTORS 1 NRC staff, Organization [H.Conrad Office of Nuclear Reactor Regulation G.' Hammer Office of Nuclear Reactor Regulation R. Hermann. .0ffice of. Nuclear Reactor Regulation P.T. Kuo Office of' Nuclear Reactor Regulation Consultants-C.J. Czajkowski Brookhaven I.'ational Laboratory W.B.-Grossman Brookhaven National Laboratory E.C. ' Rodabaugh Brookhaven National-Laboratory NUREG-1402 D-1 02/05/90 i =
a .E &i i
- ,. y APPENDIX E ABBREVIATIONS ANSI-American-National Standards Institute i
ASME-American Society of Mechanical Engineers 1 h ASTM American Society'for Testing and Materials ,Bechtel Bechtel Power Corporation LBHN Brinell hardness number l BNL Brookhaven Natior,a1 Laboratory
- L CFR.-
' Code of Federal. Regulations a i CLM ' Chews Landing Metal Manufacturers, Incorporated s i CMTR certified' material' test report L CP&L Carolina Power'& Light EPRI Electric Power Research Institute JC0 justificationforcontinued-operation L L-NRC U.S. Nuclear Regulatory Commission 5 L -NTOL near-term operating license i ,i i 'NUREG-1402 E-1 02/05/90 L' +,
P y -0J ] .L q. NUMARC-Nuclear Management and Resources Council PSI ' Piping Supplies,.Inc. 5 -QSC quality system certificate-1 4 SER; safety evaluation report i -UTS ultimate tensile strength -WJM West Jersey Manufacturing Company -[ t s 't A i I ? .6 I k e i k-4 9 s s t i t ~ y' .NUREG-1402 E-2 02/05/90 t
p,- 1 d. Mr. Oliver D. Kingsley, Jr. 1 Enclosed is a copy of NUREG-1402 which closes out the bulletin and its Supple-ments 1 and 2. The staff concluded that (1) the analytical procedures used to qualify the non-conforming parts and the analysis results provide an adequate basis for resolving the staff's concerns regarding fittings and flanges; (2) even though the materials supplied by PSI, WJM, and CLM with falsified certified material test reports do not meet'the ASME Code, their use is an . acceptable alternative in accordance with 10 CFR 50.55a(a)(3)(ii); (3) activ-ities in response to Bulletin 88-05 regarding fittings and flanges can be closed for all operating plants; and (4) licensees should evaluate the use of product forms other than fittings and flanges. NUREG-1402 is the basis for closure of the activities specified in the bulletin for fittings and flanges for all plants having a~ full power license including Se uoyah. As stated.in the-report, some followup activities will be required i for a few operating plants that received nonconforming product forms other than fittings and flanges. These materials are listed in Supplement 2 of the bulletin and are known to have been shipped to the Perry and Palo Verde plant sites and may have been shipped to other sites. For operating plants that did receive such material, licensees should determine its location and perform an engineering evaluation where it was used in safety-related applications. These evaluations are to be performed in accordance with 10.CFR 50.59 but are not required to be reviewed by the NRC for approval, h^ c" ' rt' cr "4 " be - n:'-'-" b; th: 90 'r
- nri These evaluations will be subject to audit
-and inspection at the discretion of the NRC staff. In your letter dated -September 26, 1988, however, ycu stated that you had not identified that such material had been supplied to Sequoyah. J This, therefore, closes out the staff's evaluation of your responses to Bulletin 88-05 and its supplements. If you have any questions, please contact Jack Donohew, Sequoyah Project Manager, at 301-492-0703. Sincerely, Suzanne C. Black, Assistant Director 3 for Projects TVA Projects Division p Office of Nuclear Reactor Regulation i
Enclosure:
NUREG-1402 ,( / cc w/ enclosure: zi 0 See next page jj. /' hD> C ld y . OFC :NRR: /PM :NRR: Lead PM :EMEB:BC
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DATE:5/p90-
- 5/lC/90
- 5/
/90
- 5/
/90 0FFICIAL-RECORD COPY A0 Document Name: BULLETIN 88-05 gf. .}}