ML19289D164

Responds to NRC 781226 Ltr Re Deviations Noted in IE Insp Repts 50-329/78-16 & 50-330/78-16.Corrective Acions:Piping Fabricator & Supplier Are Being Consulted Re V-notch Charpy Test Specimen.Use of ASME Code Will Be Evaluated

ML19289D164
Person / Time
Site:	Midland
Issue date:	01/27/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19289D160	List: ML19289D164
References
HOWE-30-79, NUDOCS 7902230090
Download: ML19289D164 (4)

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OC0llSumBit; POWei (Q@ Qp Stephen H. Howell Semor Vwe Presslent General Of fices: 1945 West Pernall Road, Jackson, Michigan 49201 . (517) 788 0453 January 27, 1979 Hove-30-79

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Mr. J. G. Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANI - NRC ITEM OF DEVIATION INSPECTION REPORT NO. 50-329/78-16 AND NO. 50-330/78-16 This letter, with its enclosure, is in response to your letter of December 26, 1978 which transmitted the results of your inspection of the Midland construction site on November 13-16, 1978 and which requested our written statement on the item of deviation.

$b (v- Ud M% C C Enclosure

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Enclosure 1 Hove-30-79 CONSlNERS POWER COMPANY RESPONSE TO THE ITEMS OF DEVIATION DESCRIEED IN I;RC INSPECTION REPORT NO. 50-329/76-10 AND no. 50-330/70-16 -

MATERIAL ANALYSIS REPORPS FOR ASME CODE MATERIALS A. Descriptions of Noncompliance Appendix A, and section 5 of Details on pages k and 5 Report No.

50-329/78-16 and No. 50-330/78-16 provide the following:

" Midland FSAR, 'rable 3 2 h committed to the requirements of ASME B1PV Code,Section III,1971 Edition including Summer 1973 Addenda for nuclear piping supplied by ITT Grinnell.

ASME B&PV Code,Section III, Su==er 1972 Addenda, para-graph NC-2310, states, in pcrt, that ' , . . the test requirements and acceptance standards shall be as speci-fled in IG-2300 . . . ' ASME MPV Code,Section III, Summer 1972 Addenda, Paragraph NB-2332(b) states, in part, that ' Pressure-retaining materials with nominal vall thickness over 2 1/2 inch. for piping . .. . shall meet the requirements of NB-2331. '

ASME B&PV Code,)Section graph NB-2331(a (2), states,III, Su=mer in part, 1973 that Addenda,

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. each specimen of the Cv test (per NB-2321.2) shall exhibit at least 35 mils laterial expansion and not less than 50 ft-lbs absorbed energy. Retesting in accordance with NB-2350 is permitted . .. '

Contrary to the above, on November 17, 1978, the inspector established that Ladish Company Material Analysis Repcrt with Heat No. YS4538, used to fabricate pipe spools No.

Pm-12-S$32-3-1 and No. 2EIa-12-S632-3-2, indicated one V Notch charpy test speciren for the base metal has a value of 47 ft-lbs. Ultra;r.ctic thickness exaninution reports for the above pipe spools indicated that the vall thicknesses range from 3 0 to 3 8 inchs."

" Safety Related Piping - Review of Quality Records (Units 2)

The inspector reviewed ASME data reports, shop travelers, NDE reports, material certificates, repair records, stress relief charts and receiving inspection reports for the following components:

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a. Main Steam System Spools No. 2ELB-12-S632-3-1. and No. PFLR-12-S632-3-2.

b. Reactor Coolant System Spool No. 2ECC-3-S602-3-3A. .

The inspector determined that applicable code requirements were met except the following:

a. Ladish Company Material Analysis Report with Heat No. Y5k538, vroed to fabricate pipe spools No. PELR-12-S632-3-1 and No.

PELR-12-S632-3-2, indicated one V-notch charpy test specimen failed to meet the code requirement. .

This item is a deviation identified in Appendix A (50-330/

78-16-01)."

B. Consumers Power Comenny Response Based on the Bechtel and Consumers Power Quelity Assurance organizations' initial review of +,he described deviation, it appears that the su=mer of 1972 addenda is applicable. This addendo changed Charpy V-notch require-ments so that mils of lateral expansion is the determining factor in the acceptability of the Charpy V-notch tests. This is based on the nominal voll thickness of the pipe in question being 2 375 inches and, therefore, Section NE-2332(a) is the applicable Code Section rather than NB-2332(b) as stated in the deviation. NB-2332(a) requires that the Charpy V-notch specimens meet the requirements of Table NB-2332-1 for mils lateral expansion. All of these values have been met.

1971 Code Section II SA-370 describes the procedure for Charpy V-notch tests. When absorbed energy was applicable, the Code allowed one value to be below the minimum specified if the average of the three values was above the minimum. The described condition did meet these requirements.

It is recognized that the actual voll thickness, even though the nominal islessthan2-1/2 inches, exceeds 2-1/2inchesinsomecases.

Section NB-2331(a)(2), as referenced in the deviation, is used in the determination of a reference temperature. It requires that all values be at least 50 ft-lbs of absorbed energy.

It is our preliminary conclusion that the above paragraphs state the appropriate applicability of the Code sections to the steamline.

To confirm the initial review done by Consumers and Bechtel, the following action is being taken:

1. The piping fabricator (TTI Grinnell) and supplier (Ladish) are being consulted relative to the documentation received.

2. Bechtel Project En61 ncering and Material and quality Services are currently evaluating the deviation, the initial review and input from

' he t suppliers. The evaluation vill address the applicability of

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Section IB-2332(a) and im-2332(b) to the pipe and fittings involved.

The question of nominal vell thickness versus actuc1 vell thickness, for pipe and fittings, in the use of the Code vill be add,ressed.

It ic expected that the above actions vill be co::pleted by February 28, 1979 A final recponse (or a status of the evaluation) vill be submitted on or before March 9,1979

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