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~ ~REGULATORY INFORMATION DXSTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8909130281 DOC.DATE: 89/09/08 NOTARIZED- YES DOCKETFACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 05000275

50-323 Diablo'anyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323AUTH.NAME AUTHOR AFFXLIATION

SHIFFER,J.D. Pacific Gas & Electric Co.LOCKE,R.F. Pacific Gas &. Electric Co.

RECIP.NAME RECXPIENT AFFILIATIONMARTIN,J.B. Region 5, Ofc of the DirectorSUBJECT: Forwards addi 10CFR50.54(f) info re vendor activities.DISTRIBUTION CODE: XE01D COPIES RECEIVED:LTR ENCL SIZE:TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response

NOTES

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Pacifi Gas and Flectrtc Company 77 Beafe Street

San Francisco, CA 94106

4151972-7000

TWX910 372.6587

James D. ShifferVice PresidentNuclear Power Generation

September 8, 1989

PG&E Letter No. DCL-89-235

John B. Martin, Regional AdministratorU.S. Nuclear Regulatory Commission, Region V1450 Maria Lane, Suite 210Halnut Creek, CA 94596-5368

Re: Docket No. 50-275, OL-DPR-80Docket No. 50-323, OL-DPR-82Diablo Canyon Units 1 and 2Response to Request for Additional 10 CFR 50.54(f) Information

Dear Hr. Hartin:

As requested in Region V's letter dated August 24, 1989, enclosed isadditional information regarding PG&E's activities associated withvendor audits. The enclosed material provides clarifyinginformation related to PG&E's justifications for continued operationand responds specifically to the four questions identified in theAugust 24, 1989 Region V letter. It should be noted that some ofthe requested information enclosed was provided to the NRC duringits inspection activities of August 21-25, 1989. This informationsupplements discussions provided in PG&E Letter DCL-89-207, datedAugust 7, 1989.

Kindly acknowledge receipt of this material on the enclosed copy ofthis letter and return it in the enclosed addressed envelope.

Subscribed to in San Francisco, California this 8th day of September 1989.

Respectfully submitted,I

Pacific Gas and Electric Company

Howard V. GolubRichard F. LockeAttorneys for PacificGas and Electric Company

By. D. Shi f rice Pre ent

Nuclear Power Generation

Subscribed and sworn to before methis 8th day of September 1989

ByR chard F. Locke

890913028i 89090~~PDR ADOCK 05000275P PDC

OFFICIALSEALAORIANED. TOlEREE

HOTNYPICe CAIFORNl

QlCbtnm. ErateSOSe.22, 1%I2

Wdriane D. Tolefree, Notaryjpublicfor the County of Alameda,State of California

My commission expires December 22, 1992.

ml

l

John B. Hart)nPGLE Letter No. DCL-89-235

September 8, 1989

cc: H. H. HendoncaP. P. NarbutH. RoodCPUCDiablo D$ str$ but1on

Enclosures

2841S/0071K/BDP/1990

PGLE Letter No. OCL-89-235

ENCLOSURE l

NRC Request:

l. Your JCO 89-18, page 4 of 12, references JCO 88-07 ascontaining the )ustification for cont1nued operationof 1nadequately heat treated ASH pump impellers withcoaeercial grade parts. Please prov1de JCO 88-07 forour rev1ew.

PG&E Response:

This enclosure contains the )ustification for continued operation (JCO) 88-07,Revisions 0, l and 2 (Attachment 1). JCO 88-07 Revision l was provided to theNRC during the week of August 21-25, 1989, along with other information (NEC's"Evaluation of Commercial Grade Replacement Parts Presently Installed In TheASH 5 CCH Pumps," memorandum to file by R. Clark, S. Friedrich, H. Khan, andK. Smith; and the Metallurigical Evaluation of Impellers from Diablo CanyonPower Plant Auxiliary Saltwater Pumps, from S. Friedrich to S. Sabharwal)that has subsequently been incorporated into Revision 2 of the JCO. Revisionsto the JCO were made to incorporate the quality assessment of other partssupplied by Sulzer Bingham International for the ASH pumps. Based on theinformation provided in the JCO and the accompanying safety analysis,continued operat1on of Oiablo Canyon Un1ts 1 and 2 does not create anunreviewed safety question and will not adversely affect the public health andsafety.

2841 S/007 1 K/3

JCO 88-07 Rev 2Septber 8, 1989Page 1 of 9

AUXILIARYSALTWATER PUMP IKPELLERJUSTIFICATION FOR COKTIHUED OPERATION OF UNITS I ANO 2

X!STIIS QNO!TIOKS

On Aprf1 I, 1988, Auxiliary Saltwater (ASW) Pulp 1-1 was ~ved froiservice to perform a routine pump inspection when ft was deterwfncd thethe lower pump shaft required replaceacnt because of observed corrosionunder the shaft sleeves. Our1ng th1s maintenance activity the fapellerwas ~ved and sandblasted clean pHot'o refnstallatfon.

On ipr11 21, I988, the cleaned fepe11er was 1nspected and observed tohave pfttfnq throughout the aaterfal and crack 11ke corrosion in the hubarea. The fepeller was replaced with a new fspeller from warehousestock before puap reasseably. Upon post-eafntenance testing pump l-l itwas found that rated flow could not be ach1eved due Co Ifnor fapcllervolute differences restrfctfng flow. The lower flow rated puep )-I wasplaced 1n service temporar1ly to allow reeoval of pump 1-2 forinspection of the fipeller. The ASH pump l-2 was found to have cracklike corrosion and pftt1ng similar to pulp I-l. Oue to thc low flowcondition of pump l-l and the corrosion found on pump 1-2 fitpellcr, bothwerc subsequently replaced with new fepcller s with a larger dfaleter andreturned to service fn accordance with plant procedures. Also as aresult of the corros1on condition found 1n both pumps the Tcchn1calReview Group (TRG) required disassembly of Unit 2 ASM pumps forinspection fn the next refueling outage, further eetallurgfcalexamination of the 1mpcllcrs be performed by Technical and EcologicalServices (TES), and a gualfty Assurance aud1t of the vendor.

DQE specification 8758 rcqufred the or fgfnal ASN pump fmpe11crs to bcaanufactured in accordance with ASTK A296 CF-8K. This spec1f feat fonrequires solution heat treatment after cast1ng to restore the corros1onresistant properties of the stainless steel lost fn the casting process(f.c. heat treatment 1s requfred Co prevent sensftfzatfon and subsequent<ntcrgranular corrosion). Katcrfal samples werc cut froN the removedfapcllers and sent to TES for laboratory analys1s. The TES analysisdctcraincd that the impeller degradat1on was due to 1ntergranularcorrosion crack1ng (IGCC) and ft is probable Chat the IGCC occurred dueto the fepcllcr not being properly heat treated as required byspecification 8758. Th1s fnformat1on was reported to OCPP onSeptember 2, 1988.

Our1ng the Un1t 2 second refueling outage both pumps 2-1 and 2-2 weredisassembled and found to have corroded fepcllers sfmflar to pumps 1-1and 1-2. A detailed eetallurgfcal analysis was performed and found thatthe heat treatment was not adequate and thc fepcllers were fn thesensitized condition which resulted fn the accelerated corrosion. TheTRG was notified of the finding by TES 1n their letter dated October 14,1988. PQCE'iled a telephone l0 CFR Part 21.21 notification with thcKRC on October 21, 1988, and provided a wrftten follow up notif1cationfn Licensee Event Report (LER) 1-88-029.

fcoh88-07r2.ddm

JCO 88-07 Rtv 2

1 ~ SWtaaber 8, 1989Page 2 of 9

An inspection of the replacement impeller s prov1dad by the vendorfound that they werc fabricated using AS'743 CF-8H. The «atcrlalsubstitution was due to A296 being replaced by A743 for generalapplications and A744 for severe service by ASTM. The vendor. 81nghamInternational Incorporated, however, did not notify PGCE of thc «ater ialsubstitution.

ASTll A743 ls ln compliance w1th the heat treat«ent require«ents of PCtf~cfficatlon $758 (A296 has been replaced by A743). PGIE had contactedtie vendor of the 1«pcllers. The vendor stated the the lsycllers wereheat treated after cast1ng at the foundry by a sub-supplier and since noweld repairs werc «ade during the «achlnlng process by the vendor,further heat treating wis not required. Therefore, according to thevendor, the 1«pcllers provided to PGLE for ASM pu«ps were notsusceptible to IGCC.

ACE has subsequently performed a gA audit of the foundry's records thatcast the impeller s for Blngham International Incorporated. PQE gA hasraised questions as to the methods the foundry employed to heat treatth»'apellcrs and suspects that the heat treatment «ay hive not beenperfor«ed correctl y thus potentially «aking the f«peller s susceptible toIGCC. In addition, thc replacement 1itpellers that were also purchasedfrom Bingham International Incorporated were eetallurglcally examinedusing AS'-262 practice A. The results shoved that the new 1«pellerswerc not sensitized, however the test could not demonstrate that thelsyel)ers were coeplctcly corrosion resistive.

As a result of the indeterminate ASTM A-262 practice A test and OAconcerns about the vendor's control of sub-suppliers andi'or specialprOCCSSCS uSed by the Sub-SupplierS and VendOr, a detailed rCVlew Of allequlptlent supplied by the vendor was performed. The results of theinvestigations were documented in the nonconformance report (NCROC1-88-I8-N042). This JCO is written to address the concerns raisedregarding the indeterminate heat treatment condition of the l«pcllcrsand docu«cnt operability considerations of thc ASK and CCH pumps. Noredetailed reviews of individual sub-supplier parts provided by the vendorthat werc deter«lncd not to constitute a safety concern «ay be found lnthc NCR.

II. USTIFICATION F OPERATION OF UNITS I AND 2

A safety analysis was perfor«ed (see attached) to fust1 fy continuedoperation of Units 1 and 2, with the new 1«pcllars discussed above.Sascd on the attached safety analysis. continued operation of Units Iand 2 w1th the above discussed lapellers does not create an unrcvlewcdsafety question and will not adversely affect the health and safety ofthe public.

gcoh88-07r2.dan

III. 0 RATION AND SP CIAL CONDITIONS

JCO 88-07 Rev 2September 8, 1989Page 3 of 9

Th1s JCO rev1s1on supersedes JCO 88-07 and JCO 88-07 Rev1s1on I and w111~1n 1n effect unt11 a11 nonconfore1ng parts are e1ther replaced or 1t1s detera1ned by analys1s of ob)ect1ve ev1dance that the parts are f1tfor Operat1on past the current refuel1np cycle. Resolut1on of th1sproblea 1s tracked by nonconforiance DCl-88-8h-H042.

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AUXILIARYSALTWATER INPKLLERJUSTIFICATION FOR CONTINUED OPERATION OF UNITS I AND 2

SAFETY EVALUATION

The following is a safety evaluation for tht Justification for continuedoperation of Units I and 2.

l. VALUATION Of COMMERCIAL eRADE REPLACEMENT PARTS PRESENTLY INSTALLED IkL N Q U

guallty Assurance Audit 88244S of Sulzer b1ngham International (SBI} onSeptember 21-22 and October 4-5, 1988, identified slgnlf leantdeficiencies ln the S8I quality assurance program. Replacement partsfor the Diablo Canyon ASM and CN pumps, although ordered nuclear safetyrelated, were supplied by SSI under a comerclal grade quality assuranceprogrsh~

As dlscusscd below, Nuclear Englnetrlng and Construction Services (XECS)has investigated the impact of the use of these coaeercial grade partsand has concluded that their use does not prevent the ASH or CCk pumpsfrom performing their saftty related funct1ons.

ASN Pu I ellers

The ASN pump lmptlltrs are of cast austenit1c stainless steel whichrequires a solution heat treatment to prevent sensitization andsubsequent inttrgranular corros1on in a saltwater environment. The OA

audit of SBI concluded that insufficient controls were applied to theheat treatment of the ASM lmpellers. Test1ng by Technical andEcologica~ Services (TES) (reftrence I) concluded that the ASM impellersare either sens1tiztd or indeterminate. However, TES has also concludecthat even though it is likely that none of'he lmpellers rcct1vedadequate heat trtatment, the resultant corrosion rate is slow and theimpellers would not txper1enct failure duc to corrosion prior to

stvera'peratingcycles. This conclusion was supported by tht fact that theoriginal Unit 1 lapellers were found to bt severely sensitized (i.e. notproperly heat treated) and yet performed their function for severalyea~s and did not exper ienct fa1lure. Unt11 the impeller s are rep>acedby properly heat treated lmpellers, they should be inspected at eachrefue)1ng outage to Non1tor and assess thtlr condition.

The following dlscuss1on of 'ASW Pump Parts" applies to the iwpellers aswell as other ASH Pump Parts. Thc discussion of "CCM Pumps" documentsevaluations that have bean made regarding othtr safety-related pumpsprovided by the vendor.

gco188-07r2.ddm

N P P rts

JCO 88-07 Rev 2September 8, 1989Page 5 of g

The ASN yueps are vertical wet pit pumps that supply ocean water from the1ntake structure, through th» CCQ heat exchangers, and back to the oceanvia the discharge structure. Th1s 1s true of their normal dutyuse as well as during or after an accident condition. The only potentialsign1ficant d1fference between their normal duty and the1r accident duty1s the possibli earthquake loading.

The ASk pump and motor assewbly has been seiswically qualified anddocnted 1n Calculation SgE 6.I. The pump and motor assembly 1ssupported at various locat1ons, 1nclud1ng lateral restraints at the topOf the aotor and at the pump bowl. A rev1ew of the dynamic analysisshowed that the aost crit1cal coeponents/locations are (I) var1oussupports and (2} the clear ance between the pump 1wpeller and the casing.The majority of these components (supports} are designed and supp11ed by%LE (anchor bolts, lateral restraintsg etct).There are only two items supplied by SSI that could be critical to thedynamic analysis: (a) the pump to motor adapter bolts. and (b} the pumPiepeller and casing clearance. Our rev1ew indicates that for the abovebolts, there exists a sufficient stress margin such that even degradedbolt material (with yield and ultimate allowables similar to A-357bolts) wou1d be adequate to withstand the seismic load. A degradedimpeller or shaft material would have insignificant change on thedynamic deflection of the shaft and 1mpeller. Fur ther, there exists alarge Nargin between the calculated and allowable impeller to casingclearance. Therefore, the coneercial grade parts Supplied by SBI wouldhave 1nsignificant effect on the actual pump performance during aseismic event.

In sugary the seismic review concluded that even degraded comercialgrade SBI parts would withstand the seism1c loading. Thus,demonstration that the parts are adequate for normal operation issufficient to assure the pumps are capable of performing their safetyrelated funct ions.

The ASH pumps presently installed consist of SBI parts furn1shed as partof the original pump assemblies and SBI replacement parts that have been1nstalled during perforsance of aaintenance on the pumps.

As a corrective act1on for NCR OCI-BS-N-N042, which documents the ASW

impeller/commercial parts problem, PGCE 1s reevaluating all stockoeter1als purchased froe SBI and held 1n the warehouse. ReplacementParts Evaluat1ons (RPE) (Ref. RPE H-1196, et.al.) have been written toprovide dedicat1on activities and acceptance criteria for each of thespar e parts. The pr eliminary 1nspections, 1nclud1ng v1suel,dimensional, and aagnetic tests, as applicable, of all SBI spare partsin stock have been completed. Further, chem1cal compos1t1on testing asrequired by RPEs for many of the parts supplied by SBI is currentlybeing conducted by PQCE.

ScohN-O'er 2. ddm

JCO N-07 Rev 2Septoaber I, 1989t Poge 6 of 9

A11 parts, with the exception of the following two, passed the vfsuel,4faensfonal. and aagnetfc testing and inspections. The first involvedfncorrect dfeensfons on bowl and co1uin gaskets. The variation ln4feensfons and configuration of Che incorrect gasket would precludefmdvertent installation ln any of the ASM pumps. Therefore, becausethfs part would not have been installed, tt could not have lcd to any4IIradatfon ln thc capab11lty of the pueps to perfora Chelr safetyrelated function.

Tle second devfatfon 1nvolved incorrect aaterfal on one of the i~lierbeys ln stock. The lipeller key was observed to be slgnlffcanCly~ffferent ln color than the other stock partS. Upon further fnspectfonend aagnctfc test, lt was determfned that the key was of carbon steel orfmn Iaterfal rather Chan the required stainless steel. The pronounced4fffercncc fn appearance of the kcy would have elfafnated thepOSSfbflfty that this part would have been installed as a replacement inany of the ASk puips. ihfntenencc personnel rebufldfng the pump and gCpersonnel mnftorfng thc work would observe this type of variation fnwterfal appearance and thereby ensure that the fepropar pert fs notfnstallcd. Therefore, because this pert would not have been lnste11cd,ft could not have lcd ta any degradation fn the capability of the pumpsto perform their safety related function. (Subsequent to thc discoveryof the single carbon steel kcy, ell presently fnstelled and stocked keyshave been vcrif1ed to bc stainless steel by visual and aagnctfc test.)

Iascd on the visual, dimensional, end Iegnctfc tests end inspections afSSI parts in the warehouse, as described above, there is no indicationthat fnstalletfon of eny eccepteb1c parts would in any way degrade theability of the pumps to perform their safety-related function. Thedcvfatfans described above (gasket dimensions end key aatcrfel) arereadily recognizable and therefore the lfkc11hood of installing anfncarrcct part is nat credible. The successful visual, dfacnsionel, andaagnetfc testing end inspection of the warehouse stock, to date,contributes to our confidence that both the spare parts and installedparts are of the qua)ity required Ca assure that the puaps are capableof performing their safety-related funct1on.

In additlan ta the inspection end testing discussed above, chcmice1testing is required on cr iticel parts identified ln the RPEs. Theseparts include shafts, wear rings, couplfngs. sleeves, keys, lockcollars, etc. Of thc 20 caiponcnts (approximately 90 individual parts)tested to date, 19 werc fn full compliance with the aeterfe1spec1flcation chemical requfreaents. (Hate: The coepletc stock of eachcoaponcnt fs tested; f.c. lf Chere arc 15 wear rings ln stock, all l5arc Cested.) Thc one deviation fs the 316 shaft sleeves (part 171C)tested to date. Each of thc 7 sleeves tested slightly high fn chromium(19.10 to 19.60 per cent versus the specified 16.00 to 18.00 pcr cent).Six of the 7 also tested slightly low fn nickel (9.51 to 9.77 per centversus the specified 10.00 to 14.00 pcr cenC). These devfatlons havebeen analyzed by our mte11urgfsts who have concluded Chat the efnarcheafcal devlat1ans would have no detrimental effects on Chc aaterfalproperties ar corrosion resistance of the parCs ln this applicetian.

Sco4N-07r2.ddm

BCO 88-O~ aev 2Septisber 8. 1989tage l af

9'n

amary, Che cheefcal tescfng dont to date has deionstrated that thetested parts supplfed by Sulzer Bfngham eeet or exceed the crft1calwterfal coapos1tfon requfremtnts. Thfs further adds to our conffdencethat both the spare parts and 1nscalled parts are of the qual ftyrequfred to assure Chat the puNPs Perform the1r safety-related funct1on.

Ourfng the Unft 1 and 2 second refutlfng outages (6/88 and 10/88), each~ was overhauled, and replaceaent parts werc 1nstalled whereOn soot parts, normal servfct wear and efnfwal p1tt1ng ware

Observed; however, there was no damage or deter foratfon fn pump partsthat would effect the pueps safety-related functfon. Consfdtrfng thetfae duratfon the puwp parts had been fn servfce, the oaterfaldegradatfon observed was efnfaal (stt above dfscussfon on fiptllerAgradatfon).

The A5N system fs noraally fn optratfon and fs contfnuously aonftored.ln add1tfon, monthly and quarterly ASH system and puip tests sonftarperforwanct for Cht ASH pumps. Thfs prov1des added assurance that anychange fn puap perforeencc wfll be fdentfffed before ft becoiess1gn1f 1 cant.

Successful ded1catfon of tht SBl spare parts presently fn th» warehousefor use 1n the ASM pumps provfdts the level of conffdtnce requfrtd toConclude that tht orfgfnal parts end the spare parts fnstalltd fn thtASM pumps durfng aafntenance actfvttfts are of acctptablt qualfty.Regular pump Cestfng and normal day-to-day optratfon af the ASN pumpsdewanstrate that the puips perform adequately. Contfnutd properptrforianct af the pueps assures a low probab111ty that any sfgnfffcantaattrfal degradatfOn 1S takfng plaCt fn the pumpS. Planned perfadfCNafnttnanct and fnsptctfon of the pumps furthtr mfnfmfzt any possfbf lftyof sfgnff fcant Iattrfal degradation. All of these factors takenCogtthe~ are sufffc1ent to assure that the pumps are capable afptrforefng thtfr safety and dtsfgn functions.

~CCM Pue s

The CCQ pumps cfrculatt clean water 1n the closed loop CCM system. Theonly patcntfally sfgnff fcant dffferenct between the1r normal dutyduty and thefr acc1dtnt duty fs the potentfal sefsifc loadfng. (Thc changefn CN toaptraturt and system head are nat sfgnfffcant factors fn accessfngthe adequacy of comercfal grade parts.)

Sefsefc gualfffcatfon Reports 4. 1, 4.2 l3.l, and 13,4 have been revftwcdand 1t has been concluded Chat. w1th the exctptfon of the pump casfng topedestal bolts, the sefsifc Ioadfng on the CCH pumps and aotars fs anfnsfgnfffcant factor fn assessfng the adequacy of coeeercfal grade par ts.For the puep and mtor, sufffcfent aargfn exfsts beCween the calculated andallowable stresses and deflectfans ta account for pottntfally degradedc~rcfal grade parts suppl fed by S81. ffowever, for tht ASTN A325 boltsthat attach the puap casfng Co the SBI supptfed pedestal, sufffcftnt aargfndoes not exfst to coapcnsatc for the potent1al of fncorrect bolts scrtngtn.To assure Chat the carrect baits have been used, an fnspectfon has beenperformed and ft has been conffrmtd Chat .tht bolts are stamped "A325".

Scoh88-07r2.ddm

dCO 88-07 Rev 2~ SepCesbtr 6, 1989page 8 of g

In s~ry. the seiswfc review concluded that (wIth the exception of thebOltS diSCuSSed abOve) eVen degraded CMRCrCIal grade SBI partS WOuldwithstand the sefsefc loading. Therefore, dewonstratfon that the parts areadequate for norwal operation Is sufffcfent to assure the pueps are capableof performing their safety related functfons.

The CCM I~lier Is a cast bronze, not requiring heat treatment.Therefore, the problea of Inadequate heat treatment. as experienced withthe ASM ~ f~llers, Is not applicable to the CN puwp Iwpellers.

ln conclusion, as was the case with the ASM pumps, the successfuldedication and Installation of spare par ts, successful testIng of thepuaps, the successful day to day operation of the puwps, and the plannedperIod1c mfntenance and Inspection of the puips are suffIcfent toassure that the puwps are capable of performing their safety relatedfunctions for the design life of the equfpecnt.

Future the of Coeecrcfal Grade Parts

Unt11 such tfwe as SBI Is returned to the gualfffed Suppliers List,Replacewent Part Evaluations will be prepared to specify dedicationact1vftfes prior to fnstallat1on of SBI supplied replaceient parts.

~Susear

The NEcs safety evaluation (section I. above) provides a crit1cal reviewof all ftews that say have been provided by the vendor without anacceptable qua11ty assurance progran. Based upon the HE'CS evaluationand equfpment history reviews performed as part of HCR OCI-88-b8-N042 ithas been deterafned that the ASH pump fmpellers installed 1n Units I and2 are nonconforming and require a 10 CFR 50.59 evaluation to )ustifycontinued operation.

50. 59 EVALUATION

A. Ooes the continued oper atfon increase the probab111ty ofoccurrence or the consequence of an accident or Nalfunctfon ofequfpeent faportant to safety previously analyzed in the safetyanalysf s r eport.

The urgency core cooling system (ECCS), which uses the ASWsystem as an ultfaate'heat sink fs designed to cool the reactorcore following fnftfatfon of the followfng accidents analyzed inthe FSAR:

o ffpe break or spurious valve lifting In the ReactorCoolant Systei (RCS) (FSAR Sections 15.3. 1 and 15.4,1);

Rupture of a control rod drive eechanfsw (CROM) (FSAR

l5.4.6)'cog88-07r

2. dde

C.

JCO 88-07 Rev 2Septeaber 8, 1989Page 9 of 9

A pipe break or spurious valve lifting ln the steaesystea (FSAR Section 15.2.13, 15.3.2, and 15.4.2);

o A steam generator tube rupture (FSAR Section 15.4.3).

is dtscussed 1n the safety analysis above, failure of the pulpi~lier ls not considered feasible during the current Unit 1

cycle. Therefore. no degradatlon of operation of the ASM systemls expected, and there will be no increase ln the probability ofNy accident 41scussed above.

Does continued operation create the possibility for an accidentor aalfunctlon of a different type other than any evaluatedpreviously ln the safety analysis report?

As discussed ln the analysis section above, the evaluation ofthe tice to'failure perforsed by TES has substantiated that theASM pump iapellers are acceptable for the intended serviceconditions for the tice period of the current refueling cycle.Therefore, continued operation of the AS'K system with theselepellers installed will not create the posslb111ty for anaccident or malfunction of a different type other than anyevaluated previously in the safety analysis report.

Does the continued operation reduce the sargin of safety asdefined in the basis for any Technical Specification?

As discussed ln section 3/4.7.4 Sases, "Auxiliary SaltwaterSystem", the operabil1ty of the ASK ensures that sufficientcooling capacity is available for continued operation ofsafety-related equipment du~ing normal'nd acc1dent conditions.As discussed ln the analysis sect1on above, the evaluation ofthe tiae to failure performed by TES has substant1ated that theASH pump iapellers are acceptable for the intended serviceconditions for the time period of the current refueling cycle,Therefore, continued operation of the ASW system w1th these<apellers installed will not reduce the aargln of safety asdefined 1n the bas1s for Technical Speciflcat1on 3/4.7.4.

III'CLUIIDHeased on the above analys1s and 50.59 evaluation. continued operation ofUnits I and 2 with the installed iitpellers does not create an unanalyzedsafety question and will not adversely affect the health and safety oftie publ 1 c.

)cogN-07r2.dde

JCO 88-07-R1

AUXILIARY SAI.TMATER PUMP IMPELLERJUSTIFICATION FOR CONTINUED OPERATION OF UNIT 1

EXISTING CONDITION FOR UNIT l.

On Apr11 4, 1988, Aurflfary Saltwater Pump )-) was ~vcd from serviceto perform a routinely scheduled pump fnspectfon when ft was determinedthe the lower pump shaft requfrcd replacement because of observedcorrosion under thc shaft sleeves. Ourfng thfs aafntcnancc actfvfty thefapcllcr was removed and sandblastcd clean pr )or to rcfnstallatfon.

On Apr11 21, 1988, thc cleaned fmpeller was 1nspectad and obsetved tohave pitting throughout the materfal and cracks 1n the hub area. Thefapeller was replaced w1th a ncw fmpeller before pump rcasscibly.

Orf~fnal PGLE specification 8758 required the fmpeTler aaterfal for Unit1 &1 pumps to be manufactured in accordance wIth AS'296 CF-8M. ASTMA296 CF-N requ1res heat treatment of heat affected zones to 1,950degrees Fahrenheit and water quenched ai'ter welding to restore corrosionresistant properties of the stafnless steel. One of the crackedfepellcrs was sent to TES for analysis. TES analysfs detarlwfncd thatthe f~llcr cracked duc to fntergranular corrosion crack1ng (IGCC) and1t fs probable that the IGCC cracking occurred duc to the fspcller notbeing heat treated as requ1red by PGLE specification 8758. Thisinformation was reported to OCPP on September 2, 1988.

The replacement Unit 1 fmpcllers were fabrfcated using ASTM A743 CF-BM.The Iaterial substitut1on was due to A296 being replaced by A743 forgeneral applications and A744 for severe service. Thc vendor, 81nghamInternational Incorporated, d1d not notify PGLE of the materialsubstitution,

A743 1s 1n compliance with the heat treatment rcqufreicnts of PGEE

specification C~58 (A296 has been replaced by A743). OGLE had contactedthe vendor of t:c fmpellers. The vendor stated the the fmpellars areheat treated at the foundry. Since no weld repairs werc made during theaachfning process, further heat treating by thc Ianufacturc was notrequired. Therefore, according to the manufacturer, the fipellcrsinstalled fn Unit 1 AN pulps werc not susceptible to IBCC.

PIE has subsequently perforied a gA audit of the foundry's records thatcast the fiapellcrs for 8fngham International Incorporated. PSLE gA hasra1sed questfons as to the methods the foundry eiployed to heat treatthe 1lpcllers and suspects that the heat treatment may have not beenperformed correctly thus potcnt1ally aakfng the 1lpcllers susceptible toIBCC. In add1tfon, the new Un1t 2 fmpcllars that were also purchasedfrom Ifnghai Internat1onal Incorporated were actalagraphfcally examinedusing ASW A-262 practice A. The results showed that the new fmpellersware not scnsftfzcd, however the test could not demonstrate that theflpcllers ware coeplctely corrosfon resfstfve.

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STIFICATION FOR OPERATION OF UNIT 1

A safety analysfs was performed (see attached) to fustffy contfnuedoperatfon of Qnft I, wfth the new fmpellers dtscussed above. Sased onthe attached safety inalysfs, contfnued oper atfon of Unft I wfth theabove dfscussed f~ellers does not create an unrevfewed safety quest<onand w1ll not adversely affect the health and safety of the publfc.

III. JCO DNATION AND SPECIAL CONDITIONS

Thfs JCO revfsfon supersedes JCO 88-07 and wfll reiafn fn effect untf1the subject faptllers are efther replaced 1n Un1t 1 ASM puaps or 1t fsdeterafned that the Unft 1 ASM puip fapellers are fft for operatfon pastthe current Llnft 1 cycle.

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JCO 88-07-R1

AUXILIARY SALTWATER IKPELLERJUSTIFICATION FOR CONTINUEO OPERATION OF UNIT 1

SAFETY EVALUATION

The following fs a safety evaluation for the fustfffcatfon for continuedoperat1on of Un1t 1.

ANALYSIS~r

SECS and TES have perfarmed'n evaluatfon of the continued operat1on ofUnit 1 Auxflfary Salt Rater (ASH) Pumps with the present fmpellers.They have determfned that even 1f the present fmpellcrs were not heattreated that fntergranular corros1on crackfng (lGCC) of the fmpcllerswould not proceed at a rate that would cause f'af lure af thc fepellersduring the current cycle (sec attached evaluation}.

Sased on thc evaluation above, failure of the pump fapellcr fs notconsidered feasible during thc current Un1t 1 cycle. Therefore,sufffcfent safety Nargfns exist to allow operation of Unit 1 ASM pumpsuntf1 the next refueling outage.

50.59 EVALUATION

A. Ooes the continued operation increase the probability ofoccurrence or the consequence af an accident or ealfunctfon ofequipment important to safety previously analyzed fn thc safetyanalysis report.

The emergency cere cooling system (ECCS), which uses the ASMsystem as an ultfmate heat sink fs desfgned to cool the reactorcore following fnftfatfon of the following acc1dents analyzed inthc FSAR;

o Pfpe break or spurious valve lifting 1n the ReactorCoo1ant System (RCS) (FSAR Sect1ons 15.3.1 and 15.4. 1);

o Rupture of a control rod dr1ve mechanism (CRDH) (FSAR15.4.63;

o A pipe brcak or spurious valve 11ftfng 1n thc steamsystem (FSAR Sect1on 15.2.13, 15.3.2, and 15.4.2};

o A steam generatar tube rupture (FSAR'Sect1an 15.4.3).

As d1scussed fn the safety analysfs above, fef lure of the pumpfmpeller 1s not cons1dered feasible durfng th» currant Unit 1cyc1e. Therefore, no degradatfon of operatfan of the ASK system1s expected, and there will be no increase fn the probability ofany accfdcnt dfscussed above.

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S.

C.

~ ~Does cont1nued operat1on create the poss1b111ty for an accidentor ealfunct1on of a d1fferent type other than any evaluatedpreviously in the safety analysis report?

H

As discussed in the analys1s section above, the eva1uationof'he

t1se to failure perforsed by TES has substantiated that theASN pueP 1spellers are acceptable for the intended servicecond1tions for the t1ie period of the current Unit 1 cycle.Therefore, continued operation of the ASM system with these1epellers installed will not create the possib111ty for anaccident or malfunction of a d1fferent type other than anyevaluated previously 1n the safety analys1s report.

Does the cont1nued operation reduce the margin of safety asdefined in the basis for any Technical Specification?

As d1scussed in section 3/4.7.4 gases, 'Aux111ary SaltwaterSystea", the operab1lity of the ASH ensures that sufficientcooling capacity is available for continued operation ofsafety-related equ1peent during nomtl and accident condit1ons.As discussed 1n the analys1s section above, the evaluation ofthe tiiie to failure perfonncd by TES has substantiated that theASil pump iepellers are acceptable for the intended serviceconditions for the time period of the current Unit 1 cycle.Therefore, continued operation of the ASH system w1th theseispellers 1nstalled will not reduce the eargin of safety asdefined in the basis for Technical Specificat1on 3/4.7.4.

I II. QllICLUSIOII

Sased on the above analysis and 50.59 evaluation, continued operation ofUnit 1 w1th the installed iapellers does not create an unrealized safetyquestion and will not adversely affect the health and safety of thepubl1c.

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JCO 88-07

AUXILIARYSALTMATER PUNP INPELLERJUSTIFICATIOH FOR RESTART OF UNIT 1 AHO 2

E IST NG CDHOITIOH FOR UHIT 1 AHO UHIT 2

On Apr11 4, 1N8, Auxflfary Saltwater Peep 1-1 was removed froe serv1ceto perform a routfnely scheduled pump fnspectfon when ft was deterefncdthe the lower puap shaft requfred replacement because of observedcorrosfon under the shaft sleeves. Ourfng thfs safntcnance actfvfty thefwpeller was reaoved and sandblasted clean pr for to r efnstallatfon.

On Apr11 21, 1988, the cleaned fmpeller was fnspected and observed tohave pfttfng throughout the eaterfal and cracks fn the hub area. Thefapeller was replaced wfth a new fmpeller before pump reassembly.

Orfgfnal PQE spec1ffcatfon 8758 rcqufr cd the impeller aatcrfal for Unit1 AR preps to be wanufacturcd fn accordance w1th ASTN A296 CF-8N. ASTNA29& CF-N requfres heat treatment of heat affcctcd zones to 1,950degrccs Fahrenheit and water quenched after weld1ng to restore corrosionresfstant properties of the sta1nless steel. One of the crackedf~llers was sent to TES for analysis. TES analysis detcrmfncd thatthe fmpeller cracked duc to fntergranular corrosion crackfng (IGCC) and1t fs probablc that the IGCC crack1ng occurred due to thc fepe11er notbefng heat treated as required by PGfE spcc1ffcatfon 8758. Thisfnf~tfon was reported to OCPP on September 2, 1988.

Thc replacement fwpellcrs were fabricated using ASTN A743 CF-N. Theatter fal substftutfon was due to A296 bc1ng replaced by A743 for gener alapplfcatfons and A744 for severe scrv1ce. The vendor, BfnghamInternat1onal Incorporated, d1d not notify PG4E of the materialsubst1tut1on.

A743 fs fn coepl1ance w1th the heat treatment rcqufrcmcnts of PG4Espccfffcatfon 8758 (A296 has bee i replaced by A713, see attached). PG4Econtacted the vendor of the fmpe lers. The vendor stated the thefepellers are heat treated at the foundry. Sfnce no 'weld repairs wereolde durfng the wachfnfng process, further heat treatfng by theNanufa':ture was not requfrad. Therefore, accord1ng to the manufacturer,the Qapellers fnstalled fn Unit 1 ASH pumps are not susccptfble to IGCC.

The exfstfng f~llers are st111 fnstallcd fn Unit 2 ASM and areschedualed to be replaced durfng the upcoofng Unft 2 outage.

TIFI TIOH FOR RESTART OF UHIT l AHO 2

h safety analys1s was performed (see attached) to gustffy restart ofQnftf I, wfth the new fipellers discussed above and Unit 2, w1th theexfstfng fepellcrs that arc susceptfble to stress corrosion crack1ng,Sased on the attached safety analysis, restart of Units l and 2 with theabove dfscussed fapcllcrs does not create an unrevfewed safety questionand wf1) not adversely affect thc health and safety of the publfc,

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IlI. JCO QURATION NO SPECIAL CONDITIONS

Th1s JCO w1ll reia1n 1n effect unt11 the subject 1mpellers are replaced1n Un1t 2 ASM pueps.

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QCO 88-07

AUXILIARYSALTWATER IHPELLERJUSTIFICATION FOR RESTART OF UNIT I ANO 2

SAFETY EVALUATION

The followfng fs a safety»valuatfon for restart of Unft 1 and 2.

I. PALY~IS

TES has perforeed analysfs on the fwpeller removed from ASM pump )-) andhas d»t»rafned that the aechanfsa for crackfna was fntergranular stresscorrosfon crackfng (s»» attached report). OPING has»valuated TKS'sr»port and has md» the d»terifnatfon that fa1lur» of ASK puip 1-1'sfiipeller was not eefn»nt. The fspeller fn ASM puiip 1-1 had beenfnstall»d for approxfaately 10 y»ars prfor to replaceeent.

The newly Installed fepellers on Unft 1 ASM pumps have been detersfnednot to be susceptfblc to IGCC, therefore no safety hazards exfts fnr»let1on to restart of Un1t 1.

A sfaflar fimpell»r desfgn (orfgfonal Unft 1 ASH puiap fwpellers) exfstsfor the Unft 2 ASM puaps. At th1s pafnt fn tfme the fapcllers have beenfnstall»d for approxfaately 10 year s fn Unft 2 ASM pumps.

Based on the evaluatfon above, fa1lure of the puwp fgpeller 1s notconsfdered f»asfble based on the Unfts 2 ASlt fmpeller servfce tfmes andthe per1od of tfee requfred for the postulated faf lure eechanfse (IGCC)to cause structural faf lure of the fmpcllers. Therefore, suff fcfentsafety eargfns ex1st to allow operat1on of Unft 2 ASH pumps untf1 thenext refve11ng outage.

A.

+59 EVALUATION

Ooes the contfnued operatfon fncrcase the probabflfty ofoccurrence or the consequence of an accfdent or salfunctfon oftqufpeent fiportant to safety prev1ously analyz»d fn the safetyanalysfs report.

The emergency core coolfng systea (KCCS), whfch us»s the ASMsystem as an ultftmate heat s1nk *fs desfgned to cool the r'»actorcore fo1lowfng fnftfatfon of the following accfdents analyzed fnthe FSAR:

Pfpe break or spurfous valve lfft1ng fn the R»actorCoolant System (RCS) (FSAR Sectfons 15.3.1 and 15.4.));

Rupture of a control rod dr fve mechanfsit (CRDH) (FSAR15.4.6);

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B.

A pfpe break or spurfous valve 11ft1ng fn the steamsystem (FSN Sectfon 15.2. 13, 15,3.2, and 15,4.2);

o A steaw generator tube rupture (FSAR Sectfon 15.4.3).

As dfscussed fn the safety analysfs above, faflure of the ASH

puiip fepeller between the tfme of Unft 2 restart and ffnalreplacaeent of the fwpeller durfng the next schedualed outage fsnot probable. Therefore, no dcgradatfon of operatfon of th! ASW

system fs expected, and there w111 be no 1ncrease fn theprobabflfty of any accfdent dfscussed above.

0ts afntfnued operatfon create the possfblllty for an accfdentor aalfunctfon of a dffferant type other than any evaluatedprevfously fn the safety analysfs report?

As discussed fn the analysfs sectfon above, the evaluatfon ofthe tfee to faflure performed by TES has substantfated that theA% pump fayellers are acceptable for the intended servfcecondftf5ns for the tfse perfod of Unft restart to 1ipellerreplacement. Therefore, contfnued operatfon of the ASM systemw1th these fepellers fnstalled will not create the possfbflftyfor an accfdent or ealfunctfon of a dffferent type other thanany evaluated prevfously fn the safety analys1s repor t.

I

Oops the contfnued operatfon reduce the margfn of safety asdeffned fn the basfs for any Technfcal Spacfffcatfon?

As dfsrussed 1n sect1on 3/4.7.4 8ases, "Auxflfary SaltwaterSystea", the operabflfty of the ASM ensures that suff1c1entcoolfng capacfty ls avaflable for contfnued operatfon ofsafety-related equfpment durfng norial and accident condftfons.As dfscussed 1n the analysfs sectfon above, the evaluatfon of'he tlute to faflure performed by TES has substantfated that theASM puip fapellers are acceptable for the fntended servfcecondltfons for the tfne perfod of Unft restart to fepcllerreplacceent and wufffcfent safety IMLrgfns exfst to allow restartof Unft 2. Therefore, contfnued operatfon of the ASM systemwfth these fmpellers fnstalled wfll not reduce the margfn ofsafety as deffned fn the bas1s for Technfcal Specfffcatfon'3/4,7e4.

Ill. Qf~fC UgN

Qased on the above analys1s and 50.59 evaluatfon, restart of Unft 2with the Installed fapellers does not create an unrealfzed safetyquestfon and wfll not adversely affect the health and safety of thepubl fc.

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PG&E Letter No. OCL-89-235

ENCLOSURE 2

NRC Request:

2. Your OCO 89-18, page 7 of 12, paragraph C, lacks .

sufficient detail to allow a completion ofassessment. For example, you say that Barton testingresults in loadings which are more severe than thoseexperienced during normal operation without providingany statement as to whether the tested loadingsenvelope all design accident and transientconditions. Please provide this additional detail.

PG&E Response:

Hith regard to the discussion in paragraph c on page 7 of 12 of JCO 89-18,testing of Barton actuators envelopes all design accident and transientconditions. This conclusion is based upon a review of the installed operatingrequirements of actuators provided by ITT Barton. The maximum stem forcerequired of the actuators in the most severe accident situation (a faultedsteam generator with the auxiliary feedwater pump at shut off pressure at thesubject valve) is approximately 1488 pounds. Barton has tested theseactuators successfully to a stem loading of 1745 pounds. Thus, the force towhich the actuator is tested at Barton exceeds the maximum force expected inactual service under accident conditions. Consequently, PG&E is confidentthat the. tested loadings envelope all design accident and transient

conditions�

. This additional detail wi 1 1 be included as a revision toJCO 89-18.

2841S/007)K/4

PG&E Letter No. DCL-89-235

ENCLOSURE 3

NRC Request:

3. Your DCO 89-18, page 9 of 12, 1dentifies that DresserIndustries suppl1ed you with certa1n non-pressureretaining material, for use 1n safety-relatedapplications, which was purchased commercial grade.We note that you do not indicate whether th1ssituation appl1es to other Dresser suppliednon-pressure retaining material in addition to thatidentif1ed 1n your JCO. Please identify what othernon-pressure retaining material was purchased fromDresser Industries and whether a boundary can beestabl1shed on the time frame when Dresser wassupplying such commercial grade parts forsafety-related applications.

PG&E Response:

JCO 89-18 stated that the Dresser Industr1es audit identified deficiencies inthe qual1ty acceptance program from 1986 to l989 as applied to non-pressureretaining, essential-to-function parts. The JCO discussed one specificproblem regarding the program applied by Dresser to a series of purchaseorders involving a disc holder, disc guide, and an adapter compression screw.JCO 89-18 was based on an evaluation of all supplier audits performed byoutside contractors over the last 3.5 years.

ANSI N45.2.13 requires control of suppliers. PG&E's commitment to ANSIN45.2.13 became effective in 198l. PG&E has s1nce rev1ewed all purchaseorders from 1981 and found that there are four other purchase orders w1thDresser for non-pressure retaining, essential-to-function parts. PG&Eevaluated the acceptability of these Dresser parts based upon the assumptionthat all Dresser non-pressure retaining parts were purchased commercial gradeand that the qual1ty programs applied by Dresser were deficient. One purchaseorder furnished was for dr1ve pins an'd disc collar pins, and three purchaseorders were for spindles. The drive pins and d1sc collar pins were not1nstalled in the plant and have all been classif1ed as commercial graderequiring dedication prior to installation in safety related applications. Ofthe three purchase orders for spindles, one spindle has not been delivered,and two have been installed at DCPP. A review of the Certified Hater1al TestReports (CHTRs) suppl1ed by Dresser for these installed spindles indicate thematerial 1s certified to the requirements of ASHE Sect1on III and is therefore

2841 S/0071K/5

acceptable. Although these spindles are exempt from all ASHE Section IIImaterial requirements, Dresser supplied material that meets ASHE Section IIIand therefore the spindles do not require any additional dedication.

2841S/0071K/6

PG&E Letter No. DCL-89-235

ENCLOSURE 4

NRC Request:

4. Your JCO 89-18, page l of Attachment 1, states thatthe basis for acceptab1lity for 21 vendors was arev1ew of contractor generated audit reports. Basedon problems not ident1f1ed by contractor audits atSulzer-Bingham and PSA, what is the basis for hav1ngany confidence that a review of the audit reportswould detect inadequacies in the vendors'A program?

PG&E Response:

The problems not identif1ed by contractor audits of Sulzer-Bingham and PacificScientific were that these vendors were supplying non-code (non-pressureretaining/non-load bear1ng) safety-related parts as comnercial grade parts(1.e., these vendors were not applying a quality assurance program meeting therequirements of 10 CFR 50 Appendix B on parts exempt from ASHE Code, SectionIII, Subsection NF). These audits, which were to verify that these vendorshad adequate quality assurance programs for supplying non-code safety-relatedparts, failed to identify this problem because no non-code parts wereevaluated during these audits. The fact that no non-code parts were evaluatedduring these audits was identified by a review of the procurement control(Criterion IV/VII) portions of the audit checkl1sts for these audits. PG&E'sreview of the audits performed at Sulzer-Bingham and Pacific Scientific whenthe audit reports were first issued d1d not identify these defic1encies.

The rev1ew of the 2l contractor audits identified on page 1 of Attachment 1 ofJCO 89-18 was performed by a group of five certified lead auditorsknowledgeable of PG&E's vendor qualification program who have performed vendoraudits for PG&E. Each audit was initially reviewed by one of theseindividuals and then re-reviewed by a committee compr1sed of all five of theindividuals. Acceptance of each audit required a unanimous decision by therev1ew committee. These audits were reviewed to verify that: (1) the 1tems(parts) and activit1es evaluated during the aud1t were relevant to the scopeof work for wh1ch the vendor had been qual1fied by PG&E; (2) the audit was ofsufficient depth and breadth to form an adequate basis for determin1ng theadequacy of the vendor's QA program; and (3) ob)ective evidence had beensuff1ciently documented to support the results and conclusions of the aud1t.

2841S/0071K/7

The problem audits discussed 1n JCO 89-18 had def)c1enc)es that wereIdentified as: (1) no $ tems (parts) relevant to the specific scope of workwere evaluated during the aud)t; and (2) statements 1n the audit commentssections which did not provide suff1ckent ob)ective )dentlffcatfon of thettems or documents evaluated during the audit which ver)fled the1mplementat1on of the program. Our subsequent review of the 21 contractoraud)ts as descr)bed above ver)fled that these 21 audits did not contain thesetypes of deficiencies and also did not contain any other auditing deficiencieswhich would indicate that they were )nadequate.

2841S/0071K/8

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