United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 85-15: Nonconforming Structural Steel for Safety-related Use

                                                         SSINS No.:  6835 
                                                          IN 85-15 

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D.C. 20555 

                             February 22, 1985 

Information Notice No. 85-15:   NONCONFORMING STRUCTURAL STEEL FOR 
                                   SAFETY-RELATED USE 

Addressees: 

All nuclear power reactor facilities holding an operating license (OL) or  
construction permit (CP). 

Purpose: 

This information notice is provided to alert recipients of a potentially 
significant problem pertaining to the structural material provided by steel 
suppliers for safety-related use, especially plate that the steel suppliers 
cut into small pieces. It is expected that recipients will review the infor-
mation for applicability to their facilities and consider actions, if appro-
priate, to preclude a similar problem occurring at their facilities. 
However, suggestions contained in this information notice do not constitute 
NRC requirements; therefore, no specific action or written response is 
required. 

Description of Circumstances: 

On August 3, 1984, Illinois Power Company made notification of a potentially
reportable deficiency concerning ASTM A-36 plate material. A 1/2 x 15 x 15 
in plate of steel did not behave as expected in a mechanical cutting opera-
tion. Subsequent testing of this plate showed that the physical properties 
(yield and tensile strength) were less than that required by the A-36 mater-
ial specification. Confirmatory testing of samples from other plates having 
the same identification number (the material manufacturer's heat number) by 
a different laboratory also showed that the yield and tensile strengths were
lower than required. For all the samples tested with this identification 
number, the lowest yield strength was 14% below the ASTM minimum and 23% 
below the certified material test report (CMTR). The lowest tensile strength
was 24% below the ASTM minimum and 34% below the CMTR. The certified 
material test report, which accompanied this material, came from Phoenix 
Steel Corporation. The report showed that the material met the requirements 
of ASTM A-36 and was manufactured in 1980. 

Subsequently, Phoenix Steel performed a chemical analysis of two other 
samples with the same identification number and concluded that this material
was not made by them. Phoenix Steel makes steel from scrap and the analysis 
of trace chemical elements showed a purity not possible from the remelting 
of scrap material. Testing of an additional sample with the same identifi-
cation by an independent laboratory confirmed this analysis. 


8502200273  
.

                                                          IN 85-15  
                                                          February 22, 1985 
                                                          Page 2 of 3 

The Illinois Power Company began a thorough examination program and dis-
covered a 1/2 x 10 x 10 in. steel plate with a different identification 
number that also had yield and tensile strengths lower than required by the 
A-36 material specification. The certified material test report, which 
accompanied this material, came from Bethlehem Steel Corporation. The report 
showed that the material met the requirements of ASTM A-36 and was 
manufactured in the last half of 1980. Testing of an additional sample with 
the same identification by an independent laboratory also showed yield and 
tensile strengths lower than required. For all the samples tested with this 
identification number, the lowest yield strength was 16% below the ASTM 
minimum and 36% below the CMTR. 

The lowest tensile strength was 25% below the ASTM minimum and 45% below the
CMTR. Neither Bethlehem Steel nor Phoenix Steel sell steel cut into small 
pieces. In both cases, an independent supplier, Interstate Steel Supply 
Company of Philadelphia, Pennsylvania, provided the material to Illinois 
Power Company. Interstate Steel purchases plates, shapes and rectangular 
tubing in large quantities from steel mills and other suppliers. The 
material is usually resold, as is, to small users, but occasionally the 
material is cut into smaller sizes. Interstate Steel does not have an ASME 
Quality System Certificate, but does supply structural steel for 
safety-related use. The Clinton Power Station purchased material from 
Interstate Steel for safety-related pipe supports, conduit supports, beam 
stiffeners, and cable pan hangers. 

Traceability of Cut Material 

Until recently, Interstate Steel had a subcontractor perform all cutting of 
plate. A review of certified material test reports, shipping invoices and 
purchase orders, as well as discussions with subcontractors, indicated that 
traceability was not maintained when material was sent out for cutting. 
Interstate Steel was unable to show that the material that their vendor cut 
to size and shipped to Clinton was the material shown on the certified 
material test report. 

A comparison was made between the quantities of steel listed on the 
certified material test report, identified by heat number, and the 
quantities of steel received by Illinois Power Company with the same heat 
number. There were several instances where the quantities of cut plate 
shipped by Interstate Steel exceeded the dimensional limitations of the 
material supplied under the same heat number by Bethlehem Steel to 
Interstate Steel. The disparities have not been resolved. 

Safety-Related ASME Code Material 

A review of certified material test reports, which were supplied by Inter-
state Steel for material delivered after April 1982 to Clinton, revealed 
that Interstate Steel purchased material from sources that were not approved 
to supply ASME material, in accordance with the requirements of Subarticle 
NA-3700 of Section III of the ASME Code. The testing necessary to upgrade 
the material, as required by Subarticle NA-3700, was not performed. 

.

                                                          IN 85-15 
                                                          February 22, 1985 
                                                          Page 3 of 3 

Interstate Steel maintains inventory records by size, not by heat number, 
and it does not retain inventory records beyond 4 years. The records do not 
provide positive identification of the customers for a specific 
manufacturer's heat number. 

The Illinois Power Company is locating the material that is suspected of 
having lower-than-specified yield and tensile strengths and is evaluating 
the effect of reduced strength on safety. Further testing of material is 
being performed. 

Interstate Steel has provided a list (Attachment 1) of the nuclear power 
reactor facilities to which they have supplied material. In two instances, 
only the name of the utility was furnished. The list does not contain infor-
mation about the safety significance of the material. 

No specific action or written response is required by this information 
notice. If you have any questions about this matter, please contact the 
Regional Administrator of the appropriate NRC regional office or this 
office. 



                                   Edward L. Jordan, Director 
                                   Division of Emergency Preparedness
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contacts: P. Cortland, IE 
                    (301) 492-4175 

                    E. T. Baker, IE 
                    (301) 492-4874 

Attachments: 
1.   List of Nuclear Power Reactor Facilities 
     Receiving Material from Interstate Steel 
2.   List of Recently Issued IE Information Notices  
.

                                                          Attachment 1 
                                                          IN 85-15 
                                                          February 22, 1985 
                                                          Page 1 of 1 

                  LIST OF NUCLEAR POWER REACTOR FACILITIES 
                  RECEIVING MATERIAL FROM INTERSTATE STEEL 

UTILITY                              FACILITY 

Carolina Power & Light Company       Shearon Harris Nuclear Power Plant 
Consumers Power Company              Unknown 

Duke Power Company                   Unknown 

Duquesne Light Company               Beaver Valley Power Station 

Florida Power & Light Company        Turkey Point Plant 

Georgia Power Company                Alvin W. Vogtle Nuclear Plant 

GPU Nuclear                          Three Mile Island - 1 

GPU Nuclear                          Three Mile Island - 2 

Gulf States Utilities                River Bend Station 

Illinois Power Company               Clinton Power Station 

Long Island Lighting Company         Shoreham Nuclear Power Station Niagara

Mohawk Power Company                 Nine Mile Point 

Northeast Utilities                  Millstone Nuclear Power Station Unit 3

Pennsylvania Power & Light Company   Susquehanna Steam Electric Station 

Philadelphia Electric Company        Limerick Generating Station 

Philadelphia Electric Company        Peach Bottom Atomic Power Station 

Power Authority of the State         Indian Point Nuclear Power Plant 
  of New York 

Public Service Company of            Seabrook Station 
  New Hampshire 

Public Service Electric & Gas        Hope Creek Generating Station 
  Company 

Public Service Electric & Gas        Salem Nuclear Generating Station 
  Company 

Virginia Electric & Power Company    Surry Power Station
Page Last Reviewed/Updated Tuesday, November 12, 2013