IR 05000456/1985061

Board Notification 86-007:forwards Jg Keppler Forwarding Insp Repts 50-456/85-61 & 50-457/85-57 Re Review of Util Matl Traceability Verification Program.All Installed Components Capable of Performing Safety Functions

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)

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UNITED STATES l5't

, [ f( gg NUCLEAR REGULATORY COMMISSION L /.j WASHINGTON, D. C. 20555

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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 6,198 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 memorandu ~

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 function 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 Progra % -

Thomas M. Novak, Acting Director Division of PWR licensing-A

Enclosure:

Inspection Report ec: See next page

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REGION 111 g

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y G i* D I 799 ROOSSVSLT ROAD SLEN ELLYN. ILLgNOIS 40137

, FEB 3 1986  !

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Docket ho. 50-456 i Docket No. 50-457

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Commonwealth Edison Company l I ATTN

Mr. Cordell Reed i

} Vice President

] Post Office Box 767 i Chicago, IL 60690

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Gentlemen:

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, 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 ,

1 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 .

1 the inspection.

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} The purpose of this inspection was to assess the implementation of the Material Traceability Verification (MTV) Program at the Braidwood Station. A prior

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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 specification 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 I 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. The MTV Program, as discussed in your final report " Material Traceability

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Verification at Braidwood", has discovered a number of instances in which the material control procedures during the period of interest were not followe 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

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of the results of the MTV Program has demonstrated that all installed j components were capable of performing their safety function >ky-y/:(Q 2pf i ____ _ __

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, Commonwealth Edison Company 2 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 violatio 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 repor Consequently, no reply to the violation is required and we have no further questions regarding this matter at this tim 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 Roo We will gladly discuss any questions you have concerning this inspectio

Sincerely,

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%f-amesG.Keppfef A-_

Regional Administrator

Enclosures:

1. Notice of Violation 2. Inspection Reports No.50-456/85061(DRS);

No. 50-457/85057(DRS)

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See Attached Distribution i

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, Cosmonwealth Edison Company 3 FEB 3 1986

! Distribution i

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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

Inspector:

d d J. eW. Muffett

~ i /t7 [86 Date

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i l . M. Jacobson '

'!/7)/4 Dat.e ~

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! Approved By: D. H. Y nielson, Chief ///M4

Materials and Processes Section Date J

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I j Inspection Summary i

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' - Inspection on July 8. 9. 11, 25, 26: August 1. 2. 5: September 17. 25, 26:

i November 18. :9. 21, 26: December 10. ',7. 1985; and January 9. 1986 j '-- (Reports No. 056/85061(DRS): 457/85057LDR5)) 7 t Areas :nspected:

Special unannounced safety inspection of a previously l l identi"ted unresolved item concerning traceability of piping and pipin j components and the licensee's Material Traceability Verification (MTV)g

! program. The inspection involved a total of 160 inspector-hours by two NRC inspector Results: In the area inspected, one violation was identified (failure to

] follow procedures as identified in Paragraph 2.1.(2)).

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Summary and Ove,ral1_,

e Conclusion 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: A material verification field walkdown on 100% of piping installed prior to the procedure chang . A Quality Control verification of the field verified heat numbers against the heat numbers in the original stores reques . A Quality Control verification to show that the installed items complied with the design specificatio . A Quality Control review of the " stores request" for items which do not have physical identificatio 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 acceptabl i

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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: The MTV Program was sufficient to determine the traceability of the items in questio . The MTV procedures and work instructions were implemented properl . All items without the ASME Code required traceability have been removed from the plan . A number of installed items did not comply with applicable Ceco or PGCo procedure . The original material control system delineated in the PGCo QA manual l

met the requirements of the ASME Boiler and Pressure Vessel Code (ASME B&PV),Section III.

4 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 functio .

, Review of documentation indicates that all of the installed items could have performed their respective safety functio . All installed items now have the ASME B&PV Code required traceability; therefore, concerns relative to future 10 CFR Part 21 notifications are resolve 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.

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TABLE 1 Braidwood Material Traceability Verification Program Chronolony of Activities April 1983 PGCo, Audit 83-BR3 identifies findings related to 1 material traceabilit June 1983 NRC. inspection begins; NRC inspectors identify deficiencies in material traceabilit July 1983 Ceco issues a 50.55(E) notification concerning material traceabilit March 1984 Enforcement Conference in Region III concerning findings of inspectio March 1984 NRC Inspection Report No. 50-456/83-09; 50-457/83-09 issue February 1985 National Board Audit Team arrives at Braidwood sit June 1985 D. Gallup, State of Illinois, Superintendent of Boiler and Pressure' Vessel Safety, issues letter accepting MTV progra June 1985 Public meeting held in Region III concerning Ceco's plans for MTV progra July 1985 NRC review and inspection of MTV program start September 1985 National Board Audit Team issues final report on MTV progra September 1985 NRC Inspection Report No. 50-456/85043; 50-457/85042 issued. Inspection Report documents review of

" Stores Request."

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October 1985 Taussig Association issues report on test results of

" cut out" item November 1985 Ceco issues final report on MTV progra 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 item _

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December 1985 Region III met with NRC IE and NRR personnel to brief them on the MTV program and Region III conclusion January 1986 Telephone conference with the Illinois State Department of Nuclear Safety discussing the Region III evaluation of the MTV progra January 1986 Region III MTV insoection exit interview at the Braidwood sit .

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DETAILS

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Comunonwealth Edison Company (Ceco)

i i * J. Wallace, Project Manager j *C W. Schroeder, Licensing and Compliance Superintendent l * Shamblin, Project Construction Superintendent, Unit 1 J * Vahle, Project Construction Superintendent, Unit 2 i *D. Skoza, Mechanical Field Engineer

! * Louis Kline, Supervisor, Licensing and Compliance Department

*P. L. Barnes, Licensing Engineer i

• T. Quaka, Site QA Superintendent 1 *E. F. Fitzpatrick, Station Manager j G. E. Groth, Assistant Construction Superintendent

! * 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 1 *D. L. Cecchett, Licensing Engineer

] *A. D. Miosi, Nuclear Licensing Administrator i *C. J. Tomashek, Startup Superintendent ,

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• G. F. Marcus, Assistant to Quality Assurance Manager  :

*L. O. Del George, Assistant Vice President, Engineering and Licensing

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l Phillips Getschow Co. (PGCo)

1 l J. R. Stewart, Project Engineer i

The inspectors also contacted and interviewed other licensee and  !

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I r i * Denotes those attending the final exit interview at the Braidwood -

l Station on January 9,198 .

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Licensee Action on Previous Unresolved Items '

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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 '

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report documents the NRC review of the pertinent issues and activities.

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a Atur Code and Appendix B Traceability Requirements l 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

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Quality Control inspections required. The portion of the ASME B&PV j Code,Section III, which directly addresses this issue states

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"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 assemblie 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 ite 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 syste l b. Review of MTV Procedures

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Activitfes performed under the MTV program were controlled by two procedures: PGCo Procedure Traceability Verification," QCP-831 and PGCoRevision 4 " Material 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 pipin (2) .All material identification marking recorde (3) Field gathered data compared to stores request for ite (4) Field gathered data compared to certified material test reports (CMTR) for correct material specification, type, grade, class, size, and schedul (5) Items found not traceable per stores request or otherwise discrepant identified as nonconforming, and a nonconformance report generated for each ite I

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PGCo Procedure QCP-831 and Work Instruction PGWI-17 contain an acceptable method for determining the traceability of installed piping and piping component 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, 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 acceptabl The NRC inspector independently reviewed the NCR packages listed below:

NCR 3720 NCR 3301 NCR 3326 i NCR 3161 NCR 3068 NCR 3046 a NCR 3026 NCR f)20 NCR -373 NCR 4573 NCR 4601 i NCR 3496 NCR 3423 ,

NCR 2985 NCR 4769 (Item Removed)

HCR 2814

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The information contained in the NCR packages complied with procedure requirements and the dispositions of the individual items were acceptabl 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:

N NCR N MTV ITEM N ASME DESCRIPTION CLASS MTV #2 2 Rad Access plug CS7-1 MTV #3 2 Rad Access plug CS7-1 MTV #1 2 3"-S/405 Pipe; 18" long CS7-7 MTV #2 2 3"-S/405 Pipe; 5" long j CS7,-7 MTV #7 2 3"-5/405 Pipe; 19" long CS7-9 (Item Physically Tested) Rad Access Plug CS7-2 MTV #1 2 Rad Access Plug CS23-7 MTC #2 3 4"-5/40 Pipe; 45" long

1ASX92-1 (Item Physically Tested) MTV #3 2 3"-S/160 Pipe; l'0" long IC-CV-25-4 1 MTV #2 3 2"-3000# SW 90 EL 2556A-71 11, 2089 MTV #33 3 1-1/4"-3000# SW 90 EL 2556A-35

, 1 MTV #34 3 1-1/4"-S/80 Pipe; 2556A-35 4-1/2" long 13, 2131 MTV #4 2 12'-6"X3/4"-3000#

1AC-CC44 Sockolet

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1 MTV #5 2 3/4"-3000# SW Plug 1AC-CC44 15, 2133 MTV #8 3 6"-S/40 Pipe; 2" long CC40-1 1 MTV #3 3 4"-S/40 Pipe; 6'-11" long CC40-12 (Item Physically Tested)

1 "-S/405 Pipe; 3" long 1A-CS-8-9 1 Rad Access Plug CS-8-FW-5AP 1 Rad Access Plug CS-8-FW-4AP

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2 MTV #A 2 3"-S/40 Pipe; 3'-1" long IC-CC-41 (Item Physically Tested)

2 MTV #B 2 3-S/40 Pipe; 4'-11" long i IC-CC-41 2 MTV #1 2 3/4"-S/80 Pipe 2" long

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2544A-159 2 MTV #2 2 3/4"-S/80 Pipe 2" long 2544A-159 2 MTV #11 2 3"-S/40S Pipe; 4'6" long 1A-CS-9-6 (Item Physically Tested)

2 Rad Access Plug CS9-17

, 2 Rad Access Plug CS9-19 2 MTV #9 3 2"X3/4" 6000# SW

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2537C-32 Reducing Insert 2 MTV #2 2 3"-S/160 Pipe; 10" long IC-CV-39-10

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2 MTV #18 3 2"X3/4" 6000# SW 2537C-39 Reducing Insert 3 MTV #2 1 Rad Access Plug '

RH-8-2 31, 2785 MTV #3 1 Rad Access Plug RH-8-3

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3 MTV #2 1 Rad Access Plug RH-8-5 33, 2813 MTV #2 1 3"-S/160 Pipe; 4" long CV-10-4B i 3 MTV-#1 2 3"-S/160 Pipe; 4" long CV-10-4D 3 MTV #12 3 2"-3000# SW45 EL 2556A-72 3 MTV #1 2 3/4"-S/160 Pipe;

, 2539C-84 5'3"long 3 MTV #3 2 3/4"-5/160 Pipe; 2539C-84 l'9"long 38, 2873 MTV #5 2 3/4"-S/160 Pipe; 2539C-84 10'7"long 39, 2873 MTV #7 2 3/4"-S/160 Pipe; 2539C-84 4'6"long (Item Physically Tested)

4 MTV #9 2 3/4"-S/160 Pipe;

2539C-84 l'1" long 41, 2875 MTV #7 3 2" 3000# SW 90 EL (FW 7&8) .

4 MTV #14 3 2"-3000# SW 90 EL (FW 15&l6)

4 MTV #3 3 3/4"-S/80 Pipe; 18" long (FW 3&4)

4 MTV #23 3 2"-3000# SW 90 EL (FW 20A&21A)

4 MTV #8 2 3"-S/405 Pipe; t

1A-CV-13-3 11-1/2" long 46, 2919 MTV #9 2 3"-S/40S Pipe; 1A-CV-13-3 14-1/2" long 47, 2919 MTV #10 2 3"-S/40S Pipe; 1A-CV-13-3 2" long l 4 MTV #13 2 3"S/405 Pipe; 11" long 1A-CV-13-3

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4 MTV #13 2 3"-S/405 Pipe; 39" long 1A-CV-13-3 5 MTV #14 2 3"-S/405 Pipe; 1A-CV-13-3 3-1/2" long 5 MTV #15 2 3"-S/40S Pipe; 1A-CV-13-3 2"&24" long 5 MTV #1 3 3"-S/405 Pipe; 1A-BR5-5 8-13/16" long 5 MTV #1 3 3/4"-S/80 Pipe 5" long 2546A-79

54, 2973 MTV #13 3 2"-S/80 Pipe; 3" long (FW16&l7)

5 MTV #47 3 2"-S/80 Pipe; 1" long (FW35&36)

5 MTV #3 3 Ring & Bar lug 1A-SX-30-2 5 MTV #6 2 Rad Access Plug 1A-SI14-3 58, 2993 MTV-#5 3 3/4"-S/80 Pipe 4" long 2537A-65 5 MTV-#19 3 3/4"-S/80 Pipe 4" long 2537A-65 6 MTV #9 2 3/4"-S/160 Pipe; 2" long 2546C-61 .

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2 3/4"-5/160 Pipe; 2" long 2546C-61 j 6 MTV #5 2 3"-S/40(S) Pipe; 1A-CV-10-3 10-3/4" long 6 MTV #12 3 4"-S/40 Pipe; 2'3" long CC-11-5 6 MTV #5 2 2 Plates, 2"X6" Welded 2A-CC-31 Attachment .

6 MTV #5 2 Rad Access Plug 3 1C-FW-14-7 6 MTV #7 2 3/4"-6000# Coupling t

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67. 3221 MTV #4 3 Nailer Ring (SA240)

OA-FC-3AB Welded Attachment 68. 3226 MTV #1 2 6"-S/80 Pipe; 12" long FW38-1 (Item Physically Tested)

69. 3275 MTV #2 2 Rad Access Plug RH-2 70. 3291 MTV #1 2 24"-S/405 Pipe; SI43-2 l'-6" long (Item Physically Tested)

71. 3300 MTV #2 2 Rad Access Plug 1A-RH-4 72. 3318 MTV #3 3 5"-3"X3/4" 3000# SOL

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73. 3327 MTV #6 3 4"-5/40 Pipe; l'0" long (FP-33-11)

74. 3327 MTV #7 3 4"-S/40 Pipe; 6" long (FP-33-9)

75. 3334 MTV #1 3 1"S/80 Pipe; l'-0" long (FW-15)

76. 3334 MTV #19 3 1"-S/80 Pipe; 4" long (FW-12)

77. 3335 MTV #2 3 4"-5/40 Pipe; 6'6" long FP-20-4 78. 3343 MTV #1 2 4"-S/160 Pipe; 8" long 1A-SI-12-4R 79. 3350 MTV #13 3 2"-S/40 Pipe; 40" long 2537A-104 80. 3350 MTV #11 3 2"-S/40 Pipe; 2537A-104 10-1/2" long .

81. 3365 MTV #25 3 1"-S/80 Pipe; l' long (FW34&35)

82. 3365 MTV #27 3 1"-S/80 Pipe; l' long (FW 36&37)

83. 3322 MTV #6 3 6"-S/120 Pipe; 5'4" long 1A-AF-8-3C (Item Physically Tested)

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8 MTV #1 3 6"-S/120 Pipe; l'1" long 1A-AF-8-6 8 MTV #2 3 6"-S/120 Pipe; 10" long 1A-AF-8-6 .

8 MTV #2 1 Rad Access Plug RC-16-5 8 MTV #3 1 Rad Access Plug RC-16-5 8 MTV #17 3 6"-S/40 Pipe; l'6" long

, FP-21-5 (Item Physically Tested)

8 MTV #2 3 Welded attachment lug for AF-16-2 2AF01028R (Item Physically Tested)

9 MTV #1 3 3"-S/40S Pipe; 6" long CV-7-6 9 MTV #9 3 4'-5/40 Pipe; 6" long FP-77-7 -

9 MTV #2 3 18"0D S/40 Stanchion ISX02061X 9 MTV #3 3 18"0D S/40 Stanchion

_ ISX02061X 9 MTV #2 1 Rad Access Plug 2C-51-25 )

9 MTV #2 2 3"-S/160 Pipe; 5" long CV-2-12 9 MTV #1 3 4"-S/40 Pipe; 4'-6" long CC-29-5 9 MTV #1 2 3/4"-S/405 Pipe; 3" long 2535A-38 9 MTV #3 2 1/2" closure plate CV33-5 9 MTV #3 3 2"-3000# 90 El 2556A-50A

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100. 3553 MTV #18 3 2"-3000# 45 EL 2556A-71 101. 3594 MTV #8 3 1-1/2"-300# Flange

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10 MTV #10 3 1-1/2"-300# Flange 2537A-50A 10 MTV #11 3 1-1/2"-S/80 Pipe; 2537A-50A 7-1/2"long 10 MTV #25 2 1/2"-S/160 Pipe; 6" long 1FT-444-2 10 MTV #1 3 3"-S/40 Pipe; 5" long 1A-SX-15-10 106. 4032 MTV #6 3 4"-S/40 Pipe; 3-3/8" long 2FH-FP-28-14 107. 4055 MTV #4 2 3"-S/160 pipe; 2A-CV-28-12 7'-10" long 10 MTV W1 3 4"-5/40 Pipe; 10" long 2A-CC-27-6 (Item Physically Tested)

10 MTV #1 2 10"-S/40 Pipe; 10" long IC-SX-74-1 11 MTV.#19 3 2"-3000# - 90 El 2537C-12 11 MTV #55 2 1"-S/160 Pipe;

2539A-29 l'-10" long (Item Physically Tested)

11 MTV #2 3 36"-12"X1"-3000#

2A-CC-20-3 Sockolet 11 MTV #1 3 2"-S/405 Pipe; 29549A-28 l'-10" long 11 MTV #1 2 14"-S/STD Pipe IC-SX-34-8 l'7" long (Item Physically Tested)

11 MTV #12 2 2"-S/405 Pipe; 2546A-5 Item 90 5'-2" long 11 MTV #4 2 3"-S/40S Pipe; 9" long 1A-CV-37 Item 8

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11 MTV #1 2 1"-S/40S Pipe; 2539C-44 Item 128 6-1/2" long 118, 4756 MTV #3 2 1"-S/405 Pipe; 2539C-44 Item 73 6'-4" long

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11 MTV #5 2 1"-S/405 Pipe; 12' long 2539C-44 Item 74 12 MTV #7 2 1"-S/40S Pipe; 2539C-44 Item 75 12'5" long 12 MTV #2 2 1"-S/40S Pipe; 4' long 2539C-89 Item 76 12 MTV #2 '2 1"-5/405 Pipe; 4' long 2539C-39 Item 127 12 MTV #9 1 2"-S/160 Pipe; 3'9" long 2546C-25 Item 68 (Item Physically Tested)

12 MTV #1 2 2"-S/405 Pipe; 2546A-46 Item 109 5-5/8" long 12 MTV #3 2 2"-5/405 Pipe; 2546A-46 Item 110 10-5/8" long 12 MTV #5 2 2"-S/40S Pipe; 2546A-46 Item 111 11-1/2" long 12 MTV #7 2 2"-S/40S Pipe; 2546A-46 Item 112 10-3/4" long 12 MTV #8 2 2"-S/40S Pipe; 4" long 2546A-46 Item 93 12 MTV #12 2 3/4"-S405 Pipe; 3" long 2546A-88 Item 95 13 MTV #2 2 5"-3"X3/4" - 3000# SOL 2PC-44A 131, 4824 MTV #21 3 3/4"-S/405 Pipe; 2546A-2 15'10" long (Item Physically Tested)

13 MTV #1 3 3/4"-S/40S Pipe; 4" long 2546A-2 13 MTV #9 3 3/4"-S/40S Pipe; 5" long 2546A-2 13 MTV #11 3 3/4"-S/40S Pipe; 5" long 2546A-2 13 MTV #13 3 3/4"-S/40S Pipe; 2546A-2 9'11"long 16 ,

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l 13 MTV #15 3 3/4-S/405 Pipe; 2546A-2 10-1/2" long 13 MTV #17 3 3/4"-S/405 Pipe;  ;

2546A-2 4'10" long 13 MTV #19 3 3/4"S/405 Pipe; 2546A-2 9-3/4" long 13 MTV #23 3 3/4"S/40S Pipe; 2546A-2 l'11-1/4" 7.ong 14 MTV #1 3 3/4"-S/404 Pipe; 1" long 2549A-16 14 MTV #6 1 Rad Access Plug RH14-2 14 MTV #3 2 2"-S/40S Pipe; 12" long 2546A-92 14 MTV #22 2 2"-S/405 Pipe; 2546A-92 14-3/4" long 14 MTV #5 3 4"-S/160 Pipe; CC12-1 13'2" long 14 MTV #1 2 10"-S/405 Pipe; 11" long CSS-7 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

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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."

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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:

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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 CEC In addition, the independent measurements ,

closely agreed with the measurements taken by CEC ; Selection of Samples i,

At a point in time near the completion of the MTV, CECO decided to 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

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the affected s All of the items which were removedexcept (ystems forto3function items mistakenly properly. 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 1 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 testin The group of items tested contained both carbon steel and stainless steel and both large bore items and small bore items. In addition, the tested only(NCR 4756 Item 68).

~ A portion untraceable sectionwas of the testing of piping in anbyASME Clas witnessed a NRC inspecto >

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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 specificatio 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 l met the requirements of the ASME Code e d the certified design '

specification."

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"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."

i Duane R. Gallup, Superintendent of Boiler and Pressure Vessel

, Safety for the State of Illinois, supported the MTV program in his June 21, 1985 lette 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

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in compliance with the requirements of the ASME Code."

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. Safety Stanificance Evaluation

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. As part of the overall MTV program, a " safety significance"

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evaluation, composed of calculations necessary to demonstrate

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compliance with ASME B&PV Code strength requirements, was performed for all the items which were nonconforming due to insufficient traceabilit 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 reviewe This report and the disposition of these NCRs were acceptabl 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 ASME B&PV Cod The evaluations were reviewed and found acceptabl Inspection Conclusions Based on the NRC inspections and reviews of the MTV program, the following conclusions have been reached:

i (1) The original material control system contained-in the PGCo QA manual complied with the requirements of the ASME B&PV Cod (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).

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1 (3) The specific instances of failure to follow procedures did not i appear to impact the ability of the systems to perform their

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safety function.

i 4 (4) The MTV program was an effective method to determine the traceability of the items in questio (5) The MTV program was conducted in accordance with applicable procedure (6) 145 Items lacking the required traceability have been removed from the plant and replaced with items which have the required traceabilit (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 properl . 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.

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