IR 05000456/1985061
| ML20214D561 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/03/1986 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Asselstine, Palladino, Roberts NRC COMMISSION (OCM) |
| References | |
| CON-#186-331, TASK-AS, TASK-BN86-007, TASK-BN86-7 BN-86-007, BN-86-7, OL, NUDOCS 8603050281 | |
| Download: ML20214D561 (2) | |
Text
4o05
- * (f"%jo l5
..
UNITED STATES
't
[
f( gg NUCLEAR REGULATORY COMMISSION
,
L
/.j WASHINGTON, D. C. 20555
%,...../
'
M 0 31986 i
Docket Nos:
50-456 and 50-457 MEMORANDUM FOR:
Chaiman Palladino Comissioner Roberts Commissioner Asselstine Comissioner Bernthal Commissioner Zech FROM:
Thomas M. Novak, Acting Director Division of PWR I.icensing-A SUBJECT:
BOARD NOTIFICATION REGARDING THE REGION III REVIEW OF THE BRAIDWOOD PIPING MATERIAL TRACEABII.ITY ISSUE (BN-86-07)
This Notification is being provided to the Commission in accordance with the revised Comission's notification policy of July 6,1984.
The enclosed inspection report is applicable to Braidwood Station, Units 1 and 2.
The parties to the proceeding are being notified by copy of this memorandum.
Region III conducted a special inspection to assess the implementation
~
of the Material Traceability Verification (MTV) Program at Braidwood Station.
The results of this inspection are documented in the enclosed inspection report. Although the report identified a level IV violation for failure to follow material control procedures, engineering evaluation of the results of the MTV Program has demonstrated that all
.
installed components were capable of performing their safety functions.
The report further stated that both the procedures which control the MTV Program and the implementation of the procedures were found to be acceptable to address the MTV issues.
Region III has no remaining open issues regarding the MTV Program.
5%
-
Thomas M. Novak, Acting Director Division of PWR licensing-A
Enclosure:
Inspection Report
ec:
See next page
.
.
_ _. _ _
_.
-
.. _ -.
___
.
. _ _ _
_. _.
.... - _
-
..
,,
l'
i
!
REGION 111
,
y
i*
D
I
799 ROOSSVSLT ROAD
SLEN ELLYN. ILLgNOIS 40137
FEB 3
1986
,
l
.
!
'
i
'
!
'
Docket ho. 50-456
i
Docket No. 50-457
\\
Commonwealth Edison Company
l
I
ATTN: Mr. Cordell Reed
i
}
Vice President
]
Post Office Box 767
i
Chicago, IL 60690
,
Gentlemen:
,
.
This refers to the special inspection conducted by Messrs. J. W. Muffett and
,
!
J. M. Jacobson of this office on July 8, 9, 11, 25, 26; August 1, 2, 5;
j
September 17, 25, 26; November 18, 19, 21, 26; December 10, 17, 1985; and
,
January 9,1986, of activities at the Braidwood Station, Units 1 and 2,
'
]
authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to
)
the discussion of our findings with Mr. M. J. Wallace at the conclusion of
.
the inspection.
t
'
}
The purpose of this inspection was to assess the implementation of the Material
!
Traceability Verification (MTV) Program at the Braidwood Station. A prior
'
inspection report (50-456/83-09; 50-457/83-09) identified deficiencies
'
L
concerning verification of installation of correct piping materials. Our
questions concerning these deficiencies were made into unresolved items
(456/83-09-04A,457/83-09-04A;456/83-09-04B,457/83-09-048). The deficiencies
in your material control program identified in this prior report resulted in a
!
number of installed piping cmponents which did not comply with applicable
i
j
design specifications.
During the March 7,1984 enforcement conference, you described the MTV Program
,
which provided for 100% inspection of the piping installed during the period
i
j
of interest. The procedures which control the MTV program and the
implementation of the procedures have been reviewed and inspected by the
NRC as discussed in the attached report. Our inspections and reviews have
!
found both the procedures and the implementation of the procedures to be
j
acceptable to address this issue.
I.
The MTV Program, as discussed in your final report " Material Traceability
!
Verification at Braidwood", has discovered a number of instances in which the
'
material control procedures during the period of interest were not followed.
l
Although the MTV Program discovered examples of failure to follow material
control procedures and examples of installed piping components which did not
i
comply with the applicable design specifications, engineering evaluation
of the results of the MTV Program has demonstrated that all installed
'
j
components were capable of performing their safety functions.
>ky-y/:(Q
2pf
i
.
-. -
.
- -.
_
.-
.
.
..
,,
Commonwealth Edison Company
FEB 3
1986
,
Therefore, due to the lack of safety significance, it has been determined
that the violation for failing to follow the material control procedures is
a Level IV violation.
The inspection showed that action had been taken to correct the identified
violation and to prevent recurrence. Our understanding of your corrective
actions are described in Paragraph 2 of the enclosed inspection report.
Consequently, no reply to the violation is required and we have no further
questions regarding this matter at this time.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter and the enclosed inspection report will be placed in the NRC
Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
.,
%f-
A-_
amesG.Keppfef
Regional Administrator
Enclosures:
1.
2.
Inspection Reports
No.50-456/85061(DRS);
No. 50-457/85057(DRS)
)
See Attached Distribution
i
.
.
i
J
l
.
- -
. - - -.
-. -
. -
.
. -..
. -
.
.
.
.
-
...
.
. _.
_ _ _ _ _ _ _.
_
. _ _ _
_ _ _ _ -..
_ _...
. _ _ _ _.
___ _ ____
..
.,
'
i
i-
,
FEB 3
1986
'
Cosmonwealth Edison Company
,
!
Distribution
i
i
REGION III==
J
l
Reports No. 50-456/85061(DRS); 50-457/85057(DRS)
Docket Nos. 50-456; 50-457
Licenses No. CPPR-132; CPPR-133
Licensee:
Commonwealth Edison Company
Post Office Box 767
i
Chicago, IL 60690
l
\\
j
Facility Name:
Braidwood Station, Units 1 and 2
I
Inspection At:
Braidwood Site, Braidwood, IL
i
Inspection Conducted: July 8, 9, 11, 25, 26; August 1, 2, 5;
September 17, 25, 26; November 18, 19, 21, 26;
December 10, 17, 1985, and January 9,1986
d
d
J. eW. Muffett
i /t7 [86
~
Inspector:
Date
'!/7)/4
,
l
. M. Jacobson
'
i
Dat.e ~
l
kLd&;=
j
i
!
Approved By:
D. H. Y nielson, Chief
///M4
Materials and Processes Section
Date
J
.
I
j
Inspection Summary
i
!
Inspection on July 8. 9. 11, 25, 26: August 1. 2. 5: September 17. 25, 26:
' -
November 18. :9. 21, 26: December 10. ',7. 1985; and January 9. 1986
i
j
'-- (Reports No. 056/85061(DRS): 457/85057LDR5))
t
Areas
- nspected:
Special unannounced safety inspection of a previously
l
l
identi"ted unresolved item concerning traceability of piping and pipin
components and the licensee's Material Traceability Verification (MTV)g
j
!
program. The inspection involved a total of 160 inspector-hours by two NRC
inspectors.
Results:
In the area inspected, one violation was identified (failure to
]
follow procedures as identified in Paragraph 2.1.(2)).
)
i
i
h$)
.
fe
.
.
'
i
.
.
..
Summary and Ove,ral1_, Conclusion
e
c
Purpose
The purpose of this report is to document Region III review of the piping
material traceability issue at Braidwood.
In addition, this report documents
the actions taken to assure that the Braidwood Material Traceability Verifica-
tion Program (MTV) was properly carried out, and to document the review and
evaluation of the " Report on Material Traceability Verification at Braidwood",
dated November 1985, submitted by Comonwealth Edison Company (Ceco).
Background
A special Region III team inspection, conducted in June, July, August and
October of 1983 and during January and February of 1984, resulted in an
unresolved item concerning verification of correct heat number traceability
for piping and piping components. Specifically, it was determined that
Phillips Getschow Company (PGCo) had not been performing documented inspections
for correct material usage of piping and piping components at the time cf
installation and a few instances were identified where material traceability
could not be readily verified. At the time NRC Inspection Report No. 50-456/
83-09; 50-457/83-09 was issued, the exact extent and significance of the
programatic deficiencies were unknown; therefore, this issue was made an
unresolved item. As detailed in the CECO response to the inspection report,
two actions were taken. The first action was to modify the piping material
-
control and installation procedures to provide documentation of material
traceability verification at the point of installation. This action tends
to minimize the possibility of recurrence of traceability deficiencies. The
second action was to initiate the MTV program. The MTV program contains
the following basic elements:
1.
A material verification field walkdown on 100% of piping installed prior
to the procedure change.
2.
A Quality Control verification of the field verified heat numbers against
the heat numbers in the original stores request.
3.
A Quality Control verification to show that the installed items complied
with the design specification.
4.
A Quality Control review of the " stores request" for items which do not
have physical identification.
In addition to the concern related to material verification at point of
installation, there was a related concern dealing with specific examples of
failure to follow the applicable procedures in this area. The MTV Program
was also structured to identify these items.
Also, the MTV Program was
independently reviewed and audited by the National Board of Boiler and
Pressure Vessel Inspectors National Board. The Illinois State Division of
Boiler and Pressure Vessel Safety also reviewed the program. Both
organizations found the program acceptable.
i
-
,
..
.
Conclusions
Based upon the Region III inspections and the review of " Report on Material
Traceability Verification at Braidwood," dated November 1985, it is concluded
that:
1.
The MTV Program was sufficient to determine the traceability of the items
in question.
2.
The MTV procedures and work instructions were implemented properly.
3.
All items without the ASME Code required traceability have been removed
from the plant.
4.
A number of installed items did not comply with applicable Ceco or PGCo
procedures.
5.
The original material control system delineated in the PGCo QA manual
l
met the requirements of the ASME Boiler and Pressure Vessel Code (ASME
6.
The physical and chemical tests performed on the items removed (due to
lack of traceability) from the plant demonstrate that in fact that the
material installed was the correct material and could have performed its
,
safety function.
.,
7.
Review of documentation indicates that all of the installed items could
have performed their respective safety function.
8.
All installed items now have the ASME B&PV Code required traceability;
therefore, concerns relative to future 10 CFR Part 21 notifications are
resolved.
It is concluded that Ceco has taken adequate corrective action to resolve
specific instances of failure to follow material control procedures.
Also,
the results as delineated in the Ceco " Report on Material Traceability
Verification at Braidwood" demonstrate the extent and significance of
j
implementation deficiencies found in this area.
<
-
-
-
-
-
-
-
-
-
-
- --
-
-
-
-
-
..
TABLE 1
.
Braidwood Material Traceability Verification Program
Chronolony of Activities
April 1983
PGCo, Audit 83-BR3 identifies findings related to
material traceability.
June 1983
NRC. inspection begins; NRC inspectors identify
deficiencies in material traceability.
July 1983
Ceco issues a 50.55(E) notification concerning
material traceability.
March 1984
Enforcement Conference in Region III concerning
findings of inspection.
March 1984
NRC Inspection Report No. 50-456/83-09;
50-457/83-09 issued.
February 1985
National Board Audit Team arrives at Braidwood site.
June 1985
D. Gallup, State of Illinois, Superintendent of
Boiler and Pressure' Vessel Safety, issues letter
accepting MTV program.
June 1985
Public meeting held in Region III concerning Ceco's
plans for MTV program.
July 1985
NRC review and inspection of MTV program starts.
September 1985
National Board Audit Team issues final report on MTV
program.
September 1985
NRC Inspection Report No. 50-456/85043; 50-457/85042
issued.
Inspection Report documents review of
" Stores Request."
"
October 1985
Taussig Association issues report on test results of
" cut out" items.
November 1985
Ceco issues final report on MTV program.
November 1985
NRC Inspection Report No. 50-456/85050; 50-457/85048
issued.
Inspection Report documents independent
thickness measurements of a sample of installed MTV
items.
- -
- - -
- - - - - - - - - -
- - - - - - - - - - - - - -
-
- - - - - -
---
--
- - - - - - - - - - - - - - - - - - - - -
.
.
.
..
.
December 1985
Region III met with NRC IE and NRR personnel to
brief them on the MTV program and Region III
conclusions.
January 1986
Telephone conference with the Illinois State
Department of Nuclear Safety discussing the Region
III evaluation of the MTV program.
January 1986
Region III MTV insoection exit interview at the
Braidwood site.
.
e
e
i
.
_ - _. _. - _
._
.
_.
_ - _.. _ _ _ _ _ -. _. _ _ _.
__
_ _ _ _ _ _.
J
-
..
,,
r
j
.
DETAILS
!
'
i
l
1.
Persons Contacted
'
Comunonwealth Edison Company (Ceco)
i
i
- M. J. Wallace, Project Manager
j
- C
W. Schroeder, Licensing and Compliance Superintendent
l
- D. Shamblin, Project Construction Superintendent, Unit 1
J
- W. Vahle, Project Construction Superintendent, Unit 2
- D. Skoza, Mechanical Field Engineer
i
!
- Louis Kline, Supervisor, Licensing and Compliance Department
- P. L. Barnes, Licensing Engineer
i
- T. Quaka, Site QA Superintendent
- E. F. Fitzpatrick, Station Manager
j
G. E. Groth, Assistant Construction Superintendent
!
- M. R. Dougherty, Project Construction Engineer
!
- E. R. Wendorf, Project Field Engineer
!
- J. F. Phelan, Project Field Engineer
!
- J. K. Jasnosz, Regulatory Assurance Staff
i
- T. W. Simpkin, Technical Staff
- D. L. Cecchett, Licensing Engineer
]
- A. D. Miosi, Nuclear Licensing Administrator
i
- C. J. Tomashek, Startup Superintendent
- G. F. Marcus, Assistant to Quality Assurance Manager
,
,
,
'
- L. O. Del George, Assistant Vice President, Engineering and Licensing
!
l
Phillips Getschow Co. (PGCo)
l
J. R. Stewart, Project Engineer
i
The inspectors also contacted and interviewed other licensee and
!
j
contractor employees.
'
I
r
i
- Denotes those attending the final exit interview at the Braidwood
l
-
l
Station on January 9,1986.
l
.
I
2.
Licensee Action on Previous Unresolved Items
'
.
!
f
(Closed) 'Jnresolved Items (456/83-09-04(a); 457/83-09-04(a):
This item was
'
classified as unresolved until the completion of the MTV program. This
'
report documents the NRC review of the pertinent issues and activities.
!
!
Atur Code and Appendix B Traceability Requirements
l
a
l
The ASME B&PV Code gives no detailed information either on the
l
specific nature of material control systems or on the type of
>
-
Quality Control inspections required.
j
Code,Section III, which directly addresses this issue states:
+
l
'
\\
!
1
i
!
L
.
,
.
..
,,
,
"NA-4441 Establishment and Maintenance of Identification and Control
Measures:
Measures shall be established for identification and control of
material and items, including partially fabricated assemblies.
These measures shall assure that identification is maintained
either on the item or records traceable to the item throughout
manufacture or installation.
These measures shall be designed
to prevent the use of incorrect or defective items, and items
which have not received the required examinations, tests, or
inspections."
The language of NA-4441 closely parallels Criterion VIII of 10 CFR 50,
Appendix 8, which states, in part:
"These measures shall assure that identification of the item is
maintained by heat number, part number, serial number, or other
appropriate means, either on the item or on records traceable to
the item."
The intent of the material control system is to prevent the
installation of incorrect or defective items.
NA-4441 allows a
control system which utilizes records traceable to the item.- The
PGCo stores request system, as delineated in the QA manual, complied
with both the ASME B&PV Code,Section III, and 10 CFR 50, Appendix
B, Criterion VIII, prior to identification of the unresolved item.
When properly applied, this material control system provided a
record traceable to the item as required. The discrepancies in the
traceability of actual piping and piping components were the result
of failure to properly implement the stores request system.
l
b.
Review of MTV Procedures
'
Activitfes performed under the MTV program were controlled by two
procedures:
PGCo Procedure
Traceability Verification," QCP-831 Revision 4 " Material
and PGCo Work Instruction PGWI-17,
Revision 3, "QCT Review of MTV Program." The proceduras contain
five major requirements as follows:
(1) 100% field walkdown for subject piping.
(2).All material identification marking recorded.
(3) Field gathered data compared to stores request for item.
(4) Field gathered data compared to certified material test reports
(CMTR) for correct material specification, type, grade, class,
size, and schedule.
(5) Items found not traceable per stores request or otherwise
discrepant identified as nonconforming, and a nonconformance
report generated for each item.
I
.
'-
..
.
PGCo Procedure QCP-831 and Work Instruction PGWI-17 contain an
acceptable method for determining the traceability of installed
piping and piping components.
In addition, the NRC inspector reviewed PGCo Procedure QCP-831.1,
Revision 1, " Untraceable Material Sampling Program." The purpose
of this procedure is control of untraceable items and control and
storage of items removed from the plant.
This procedure provides
an acceptable method for controlling these activities,
c.
Nonconformance Board
The MTV program found 792 items to be in nonconformance with
applicable procedural requirements.
The disposition of these NCR's
were provided by consensus of a nonconformance board con.=isting of
representatives of Ceco, Sargent and Lundy Engineers (!&L),
PGCo, the Authorized Inspection Agency (AIA), and generally a member
of the National Board Audit Team.
The NRC inspector attended the
disposition of a number of nonconforming items.
i
The NCRs discussed while the NRC inspector was in attendance are as
i
follows:
NCR 2301
NCR 2230
NCR 2182 (Item Removed)
NCR 2179
NCR 3595
NCR 3669
NCR 3729
The disposition of these NCRs was acceptable.
The NRC inspector independently reviewed the NCR packages listed below:
NCR 3720
NCR 3301
NCR 3326
i
NCR 3161
NCR 3068
NCR 3046
NCR 3026
a
NCR f)20
NCR -373
NCR 4573
NCR 4601
NCR 3496
NCR 3423
,
NCR 2985
NCR 4769 (Item Removed)
HCR 2814
.
_
_
_
--
_. _ - - _
__
__
. _ _... _.
.-_
-
- _ - - _ _ _ _ _ _.,. _ _ _
-
..
.,
.
The information contained in the NCR packages complied with procedure
requirements and the dispositions of the individual items were
acceptable.
Of the 792 nonconforming items, it was determined that 647 items,
while in nonconformance with PGCo and Ceco procedural requirements,
were in compliance with the traceability requirements of the ASME
Code (Braidwood procedural traceability requirements exceeded those
of the ASME Code).
The remaining 145 items, listed below, were
removed from the piping systems and replaced with traceable material:
NO.
NCR NO.
MTV ITEM NO.
DESCRIPTION
CLASS
1.
1742
MTV #2
Rad Access plug
CS7-1
2.
1742
MTV #3
Rad Access plug
CS7-1
3.
1742
MTV #1
3"-S/405 Pipe; 18" long
CS7-7
4.
1742
MTV #2
3"-S/405 Pipe; 5" long
j
CS7,-7
5.
1742
MTV #7
3"-5/405 Pipe; 19" long
CS7-9
(Item Physically Tested)
6.
1831
Rad Access Plug
-
CS7-2
7.
1871
MTV #1
Rad Access Plug
CS23-7
8.
2071
MTC #2
4"-5/40 Pipe; 45" long
(Item Physically Tested)
9.
2073
MTV #3
3"-S/160 Pipe; l'0" long
IC-CV-25-4
10.
2085
MTV #2
2"-3000# SW 90 EL
2556A-71
11,
2089
MTV #33
1-1/4"-3000# SW 90 EL
2556A-35
12.
2089
MTV #34
1-1/4"-S/80 Pipe;
,
2556A-35
4-1/2" long
13,
2131
MTV #4
12'-6"X3/4"-3000#
Sockolet
9
-
-
.
..
.
14.
2131
MTV #5
3/4"-3000# SW Plug
15,
2133
MTV #8
6"-S/40 Pipe; 2" long
CC40-1
16.
2133
MTV #3
4"-S/40 Pipe; 6'-11" long
CC40-12
(Item Physically Tested)
17.
2176
3"-S/405 Pipe; 3" long
-
18.
2177
Rad Access Plug
-
CS-8-FW-5AP
19.
2177
Rad Access Plug
-
CS-8-FW-4AP
'
20.
2183
MTV #A
3"-S/40 Pipe; 3'-1" long
IC-CC-41
(Item Physically Tested)
21.
2183
MTV #B
3-S/40 Pipe; 4'-11" long
i
IC-CC-41
22.
2353
MTV #1
3/4"-S/80 Pipe 2" long
2544A-159
'
23.
2353
MTV #2
3/4"-S/80 Pipe 2" long
2544A-159
24.
2376
MTV #11
3"-S/40S Pipe; 4'6" long
(Item Physically Tested)
25.
2434
Rad Access Plug
-
CS9-17
26.
2434
Rad Access Plug
-
,
CS9-19
27.
2505
MTV #9
2"X3/4" 6000# SW
2537C-32
Reducing Insert
.
28.
2511
MTV #2
3"-S/160 Pipe; 10" long
IC-CV-39-10
.
29.
2516
MTV #18
2"X3/4" 6000# SW
2537C-39
Reducing Insert
30.
2785
MTV #2
Rad Access Plug
'
RH-8-2
31,
2785
MTV #3
Rad Access Plug
RH-8-3
-
.
- -
- -
-
-
-
.
.
..
.
32.
2785
MTV #2
Rad Access Plug
RH-8-5
33,
2813
MTV #2
3"-S/160 Pipe; 4" long
CV-10-4B
i
34.
2813
MTV-#1
3"-S/160 Pipe; 4" long
CV-10-4D
35.
2828
MTV #12
2"-3000# SW45 EL
2556A-72
36.
2873
MTV #1
3/4"-S/160 Pipe;
2539C-84
5'3"long
,
37.
2873
MTV #3
3/4"-5/160 Pipe;
2539C-84
l'9"long
38,
2873
MTV #5
3/4"-S/160 Pipe;
2539C-84
10'7"long
39,
2873
MTV #7
3/4"-S/160 Pipe;
2539C-84
4'6"long
(Item Physically Tested)
40.
2873
MTV #9
3/4"-S/160 Pipe;
2539C-84
l'1" long
41,
2875
MTV #7
2" 3000# SW 90 EL
(FW 7&8)
.
42.
2875
MTV #14
2"-3000# SW 90 EL
(FW 15&l6)
43.
2902
MTV #3
3/4"-S/80 Pipe; 18" long
(FW 3&4)
44.
2917
MTV #23
2"-3000# SW 90 EL
(FW 20A&21A)
45.
2919
MTV #8
3"-S/405 Pipe;
11-1/2" long
t
46,
2919
MTV #9
3"-S/40S Pipe;
14-1/2" long
47,
2919
MTV #10
3"-S/40S Pipe;
2" long
l
48.
2919
MTV #13
3"S/405 Pipe; 11" long
.
-
-
- - - -
- -
- -
-
-
. _
e
.
..
.
49.
2919
MTV #13
3"-S/405 Pipe; 39" long
50.
2919
MTV #14
3"-S/405 Pipe;
3-1/2" long
51.
2919
MTV #15
3"-S/40S Pipe;
2"&24" long
52.
2930
MTV #1
3"-S/405 Pipe;
8-13/16" long
53.
2953
MTV #1
3/4"-S/80 Pipe 5" long
2546A-79
54,
2973
MTV #13
2"-S/80 Pipe; 3" long
(FW16&l7)
55.
2973
MTV #47
2"-S/80 Pipe; 1" long
(FW35&36)
56.
2984
MTV #3
Ring & Bar lug
57.
2990
MTV #6
Rad Access Plug
58,
2993
MTV-#5
3/4"-S/80 Pipe 4" long
2537A-65
59.
2193
MTV-#19
3/4"-S/80 Pipe 4" long
2537A-65
60.
3027
MTV #9
3/4"-S/160 Pipe; 2" long
2546C-61
.
.
l
61.
3027
MTV #15
3/4"-5/160 Pipe; 2" long
'
2546C-61
j
62.
3126
MTV #5
3"-S/40(S) Pipe;
10-3/4" long
63.
3165
MTV #12
4"-S/40 Pipe; 2'3" long
CC-11-5
64.
3166
MTV #5
2 Plates, 2"X6" Welded
Attachment
.
65.
3215
MTV #5
Rad Access Plug
66.
3216
MTV #7
3/4"-6000# Coupling
t
PG-2539C-75
12
,
.
-
.
..
.
67.
3221
MTV #4
Nailer Ring (SA240)
OA-FC-3AB
Welded Attachment
68.
3226
MTV #1
6"-S/80 Pipe; 12" long
FW38-1
(Item Physically Tested)
69.
3275
MTV #2
Rad Access Plug
RH-2
70.
3291
MTV #1
24"-S/405 Pipe;
SI43-2
l'-6" long
(Item Physically Tested)
71.
3300
MTV #2
Rad Access Plug
72.
3318
MTV #3
5"-3"X3/4" 3000# SOL
CV4-5
,
't
'
73.
3327
MTV #6
4"-5/40 Pipe; l'0" long
(FP-33-11)
74.
3327
MTV #7
4"-S/40 Pipe; 6" long
(FP-33-9)
75.
3334
MTV #1
1"S/80 Pipe; l'-0" long
(FW-15)
76.
3334
MTV #19
1"-S/80 Pipe; 4" long
(FW-12)
77.
3335
MTV #2
4"-5/40 Pipe; 6'6" long
78.
3343
MTV #1
4"-S/160 Pipe; 8" long
79.
3350
MTV #13
2"-S/40 Pipe; 40" long
2537A-104
80.
3350
MTV #11
2"-S/40 Pipe;
2537A-104
10-1/2" long
.
81.
3365
MTV #25
1"-S/80 Pipe; l' long
(FW34&35)
82.
3365
MTV #27
1"-S/80 Pipe; l' long
(FW 36&37)
83.
3322
MTV #6
6"-S/120 Pipe; 5'4" long
(Item Physically Tested)
.
-
.- -
-
.
..
84.
3422
MTV #1
6"-S/120 Pipe; l'1" long
85.
3422
MTV #2
6"-S/120 Pipe; 10" long
.
86.
3432
MTV #2
Rad Access Plug
RC-16-5
87.
3432
MTV #3
Rad Access Plug
RC-16-5
88.
3433
MTV #17
6"-S/40 Pipe; l'6" long
(Item Physically Tested)
,
89.
3458
MTV #2
Welded attachment lug for
AF-16-2
2AF01028R
(Item Physically Tested)
90.
3465
MTV #1
3"-S/40S Pipe; 6" long
CV-7-6
91.
3470
MTV #9
4'-5/40 Pipe; 6" long
-
92.
3474
MTV #2
18"0D S/40 Stanchion
ISX02061X
93.
3474
MTV #3
18"0D S/40 Stanchion
_
ISX02061X
94.
3476
MTV #2
Rad Access Plug
)
95.
3487
MTV #2
3"-S/160 Pipe; 5" long
CV-2-12
96.
3488
MTV #1
4"-S/40 Pipe; 4'-6" long
CC-29-5
97.
3492
MTV #1
3/4"-S/405 Pipe; 3" long
2535A-38
98.
3518-
MTV #3
1/2" closure plate
CV33-5
99.
3520
MTV #3
2"-3000# 90 El
2556A-50A
)
100.
3553
MTV #18
2"-3000# 45 EL
2556A-71
101.
3594
MTV #8
1-1/2"-300# Flange
2537A-50A
'
.
..
.
102.
3594
MTV #10
1-1/2"-300# Flange
2537A-50A
103.
3594
MTV #11
1-1/2"-S/80 Pipe;
2537A-50A
7-1/2"long
104.
3992
MTV #25
1/2"-S/160 Pipe; 6" long
105.
4022
MTV #1
3"-S/40 Pipe; 5" long
106.
4032
MTV #6
4"-S/40 Pipe; 3-3/8" long
107.
4055
MTV #4
3"-S/160 pipe;
7'-10" long
108.
4079
MTV W1
4"-5/40 Pipe; 10" long
(Item Physically Tested)
109.
4100
MTV #1
10"-S/40 Pipe; 10" long
IC-SX-74-1
110.
4294
MTV.#19
2"-3000# - 90 El
2537C-12
111.
4527
MTV #55
1"-S/160 Pipe;
2539A-29
l'-10" long
(Item Physically Tested)
112.
4587
MTV #2
36"-12"X1"-3000#
Sockolet
113.
4589
MTV #1
2"-S/405 Pipe;
29549A-28
l'-10" long
114.
4605
MTV #1
14"-S/STD Pipe
IC-SX-34-8
l'7" long
(Item Physically Tested)
115.
4756
MTV #12
2"-S/405 Pipe;
2546A-5 Item 90
5'-2" long
116.
4756
MTV #4
3"-S/40S Pipe; 9" long
1A-CV-37 Item 8
-
117.
4756
MTV #1
1"-S/40S Pipe;
2539C-44 Item 128
6-1/2" long
118,
4756
MTV #3
1"-S/405 Pipe;
2539C-44 Item 73
6'-4" long
-_
_ _ - _ _
_
-
..
.
119.
4756
MTV #5
1"-S/405 Pipe; 12' long
2539C-44 Item 74
120.
4756
MTV #7
1"-S/40S Pipe;
2539C-44 Item 75
12'5" long
121.
4756
MTV #2
1"-S/40S Pipe; 4' long
2539C-89 Item 76
122.
4756
MTV #2
'2
1"-5/405 Pipe; 4' long
2539C-39 Item 127
123.
4756
MTV #9
2"-S/160 Pipe; 3'9" long
2546C-25 Item 68
(Item Physically Tested)
124.
4756
MTV #1
2"-S/405 Pipe;
2546A-46 Item 109
5-5/8" long
125.
4756
MTV #3
2"-5/405 Pipe;
2546A-46 Item 110
10-5/8" long
126.
4756
MTV #5
2"-S/40S Pipe;
2546A-46 Item 111
11-1/2" long
127.
4756
MTV #7
2"-S/40S Pipe;
2546A-46 Item 112
10-3/4" long
128.
4756
MTV #8
2"-S/40S Pipe; 4" long
2546A-46 Item 93
129.
4756
MTV #12
3/4"-S405 Pipe; 3" long
2546A-88 Item 95
130.
4769
MTV #2
5"-3"X3/4" - 3000# SOL
131,
4824
MTV #21
3/4"-S/405 Pipe;
2546A-2
15'10" long
(Item Physically Tested)
132.
4824
MTV #1
3/4"-S/40S Pipe; 4" long
2546A-2
133.
4824
MTV #9
3/4"-S/40S Pipe; 5" long
2546A-2
134.
4824
MTV #11
3/4"-S/40S Pipe; 5" long
2546A-2
135.
4824
MTV #13
3/4"-S/40S Pipe;
2546A-2
9'11"long
,
_ _ - _ _ _ - _ _
. _ _ _. -_-.
- _ _ _ _
___
_ _ _ _
.
,
-
.
..
,
136.
4824
MTV #15
3/4-S/405 Pipe;
2546A-2
10-1/2" long
137.
4824
MTV #17
3/4"-S/405 Pipe;
2546A-2
4'10" long
138.
4824
MTV #19
3/4"S/405 Pipe;
2546A-2
9-3/4" long
139.
4824
MTV #23
3/4"S/40S Pipe;
2546A-2
l'11-1/4" 7.ong
140.
4873
MTV #1
3/4"-S/404 Pipe; 1" long
2549A-16
141.
4973
MTV #6
Rad Access Plug
RH14-2
142.
5226
MTV #3
2"-S/40S Pipe; 12" long
2546A-92
143.
5226
MTV #22
2"-S/405 Pipe;
2546A-92
14-3/4" long
144.
5364
MTV #5
4"-S/160 Pipe;
CC12-1
13'2" long
145.
5490
MTV #1
10"-S/405 Pipe; 11" long
CSS-7
d.
Stores Request Review
One of the original concerns relative to piping material was the
viability of the PGCo " stores request" system as an effective
material control system.
To further develop assurance concerning
the implementation of the system, the NRC inspector performed a
detailed review on the documentation associated with 30 items whose
traceability was' established by the " stores request" document per
the original procedure.
The details of this inspection are contained
in NRC Inspection Report No. 50-456/85043; 50-457/85042.
Summarizing
the results, "None of the documents reviewed contradicted the
.
licensee's conclusions and in a majority of cases, independent
information, other than the stores request was on file in the
documentation packages which supported the licensee's conclusion."
Members of the National Board Audit Team reviewed documentation
associated with 50 installed items whose traceability was established
based on stores request documents only.
The results of their review
are contained in the National Board Supplementary Report dated
September 26, 1985, and addressed to Cordell Reed, Vice President,
Ceco (" Material Traceability Verification at Braidwood", November
1985, Appendix A), and states "The audit confirmed the integrity of
the stores request system."
. - -.
--.
.
.
..
-
-
..
l
-
,
e.
Thickness Measurement of Installed Items
As discussed in NRC Inspection Report No. 50-456/85050; 50-457/85048,
independent thickness measurements, using an ultrasonic digital
l
thickness measuring device, were taken on six piping systems which
contained MTV items. These measurements were taken to confirm that
the schedule of the installed piping (wall thickness) complied with
the design specification and agreed with the information used in the
,
MTV program. Measurements were taken on portions of the following
'
i
piping systems:
'
1D004AB - Diesel Fuel Oil
ICCD9AB - Component Cooling Water
!
ICC97A8 - Component Cocling Water
ISX17AB - Essential Cooling Water
ICCD8AB - Component Cooling Water
ID063A - Diesel Fuel Oil
All of the measurements taken confirmed the schedule of the installed
piping and also confirmed the acceptability of the information that
was developed by CECO.
In addition, the independent measurements
,
closely agreed with the measurements taken by CECO.
f.
Selection of Samples
At a point in time near the completion of the MTV, CECO decided to
i,
perform tests on the piping removed from the plant due to lack of
traceability. The purpose of these tests was to demonstrate that
the untraceable material was in fact, the correct material and
therefore the lack of traceability did not impact the ability of
the affected s
All of the items which
'
were removed (ystems to function properly.
except for 3 items mistakenly lost or scrapped) were
subjected to an analysis which determined the chemical composition
of the material. Sixteen of the removed items were subjected to
physical tests which demonstrated that they conformed to the
.
strength requirements of the applicable specification. Two
,
j
considerations determined which items were appropriate for physical
tests. The first consideration was size; approximately 90 of the
removed items were too small for physical testing. The second
consideration was the presence of manufacturers' markings. Approxi-
mately 30 items, with clear manufacturers' marks identifying material
type, did not have the same degree of uncertainty associated with
i
their physical properties, and therefore were not appropriate for
physical testing.
The group of items tested contained both carbon steel and stainless
steel and both large bore items and small bore items.
In addition,
the only(NCR 4756 Item 68). untraceable section of piping in an ASME Clas
tested
A portion of the testing was witnessed by
~
a NRC inspector.
>
f
I
.,
_
_
_
___
_ _.-
_ _ - _ _. _. _ _ _ _., _ _. _ _ _ _ _ _ _
_. _ __ _
_ _ _ _ _ _...
_._
. _ _ _ _ _ _ __
_.__
__
_ _. _.
_
__
!
'
,
..
i
All of the items subjected to the chemical testing conformed to the
applicable ASME/ ASTM specifications.
All of the items subjected to
the physical testing for strength conformed to the applicable
ASME/ ASTM specification.
The final report produced by Taussig Associates, Report No. 64188-1,
" Chemical and Tension Testing of Samples Associated with the MTV
Program," was reviewed. A number of the chemical composition results
were reviewed by the NRC inspector for compliance with ASME B&PV
'
Code requirements for chemical composition.
A number of the
physical (strength) results were also reviewed by the NRC inspector
for compliance with ASME B&PV Code requirements for strength. All
results demonstrated compliance with applicable code strength and
l
composition requirements.
g.
Review of Reports
'
As part of the inspections associated with the MTV program, Ceco's
Report " Material Traceability verification at Braidwood," the National
Board's letter of September 26, 1985, and the Office of the Illinois
State Fire Marshall, Division of Boiler and Pressure Vessel Safety
letter of June 21, 1985, were reviewed.
Based on the NRC inspections
i
of the MTV program and the review of the CECO's final report, it has
j
been determined that the Ceco final report is an accurate representation
of the activities conducted and their results.
In addition, our
review of the National Board activities and our review of their letter
.i
supports the National Board's general conclusions:
"The Phillips, Getschow quality assurance program, as written,
did provide the necessary controls to assure that the work
,
performed by PGCo at the Ceco Braidwood Nuclear Power Station
met the requirements of the ASME Code e d the certified design
'
specification."
"As noted previously in the report, there were implementation
'
{
deviations from the PGCo quality assurance program's requirements."
"These deviations led to the generation of the MTV program and
the resulting revisions to the PGCo quality assurance program
and material control procedures."
Duane R. Gallup, Superintendent of Boiler and Pressure Vessel
i
Safety for the State of Illinois, supported the MTV program in his
,
June 21, 1985 letter.
Quoting the letter,
"I am satisfied that the corrective action program which
Commonwealth Edison Company (Ceco) has undertaken will result
in assuring the piping systems at the Braidwood site will be
,
in compliance with the requirements of the ASME Code."
I
i
.
-.
=- -. -
_ _ _.
..
_-
--
-
-
-_
a
_ __-
.
.-
-
-- -
-
..
.
h.
Safety Stanificance Evaluation
!
.
As part of the overall MTV program, a " safety significance"
evaluation, composed of calculations necessary to demonstrate
!
compliance with ASME B&PV Code strength requirements, was performed
,
for all the items which were nonconforming due to insufficient
traceability.
A random sample of these noncomforming item
evaluations (listed below) was reviewed in detail:
NCR 2085
-
NCR 2183
NCR 2785
NCR 2873
NCR 2919
NCR 3027
NCR 3291
NCR 3350
NCR 3465
NCR 3553
NCR 4294
NCR 4756
NCR 4769
NCR 4873
NCR 5490
In addition, the Sargent and Lundy Report BRF-PMD-01 (November 13,
1985), " Design Significance Evaluation of Braidwood Material
Traceability Verification (MTV) Program Cut Out Items" was reviewed.
This report and the disposition of these NCRs were acceptable.
In NRC Inspection Report No. 50-456/83-09; 50-457/83-09, two items
'
were identified which did not have the required schedule of piping
installed.
Because these items were replaced prior to the
initiation of the formal MTV program they were not included as
items in the MTV program final report.
Safety significance
evaluations were performed which found that the installed items
could have performed their safety function in compliance with the
The evaluations were reviewed and found acceptable.
i.
Inspection Conclusions
Based on the NRC inspections and reviews of the MTV program, the
following conclusions have been reached:
(1) The original material control system contained-in the PGCo QA
manual complied with the requirements of the ASME B&PV Code.
i
(2) There were a number of instances in which the proper procedures
were not followed.
These are the 792 items identified in the
CECO final report as nonconforming.
This is the basis for a
violation of 10 CFR 50 Appendix B, Criterion V. (456/85061-01;
456/85057-01).
.
.
---
---m.
-
-
-
,_.m
., -
w
q.--em-
--.--
w--
q
-
-g-
7,
_. _
.-
_ __
__
__
__
,
,
-
.
i
'
.
,
(3) The specific instances of failure to follow procedures did not
i
appear to impact the ability of the systems to perform their
safety function.
+
i
(4) The MTV program was an effective method to determine the
traceability of the items in question.
(5) The MTV program was conducted in accordance with applicable
procedures.
(6) 145 Items lacking the required traceability have been removed
from the plant and replaced with items which have the required
traceability.
(7) It now appears, based on the results of the MTV program, that
the Material Control System originally employed by PGCo was
effective to the extent that no items were installed which
would have impacted the ability of the piping systems to
g
function properly.
3.
Exit Interview
_
The Region III inspectors met with licensee representatives (denoted under
Paragraph 1) at the conclusion of the inspection on January 9, 1986.
The
inspectors summarized the scope and findings of the inspection.
The
licensee acknowledged this information.
The inspector also discussed the
likely informational content of the inspection report with regard to
documents or processes reviewed during the inspection.
The licensee did
not identify any such documents / processes as proprietary.
!
r
i
_