ML20128K584
| ML20128K584 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/08/1985 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| (1643D), NUDOCS 8507240172 | |
| Download: ML20128K584 (48) | |
Text
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,y-Commonwealth Edison
) One First NstionIl Pina. Chictgo. Ilknois O 9 Address Reply to: Post Office Box 767 L
Chicago. Hlinois 60690 '
?y July 8, 1985 PalCRITY ROUTING Mr.. James G. Keppler Regional Administrator
' 4/ L U. S. Nuclear Regulatory Commission Region III 2
799 Roosevelt Road Q
Glen Ellyn, IL 60137 FIL%
SUBJECT:
Material Traceability Verification (MTV) Program Presentation Braidwood Station Units 1 and 2 NRC Docket Nos. 50-456/457
Dear Mr. Keppler:
On June 25, 1985 a presentation was made of the Braidwood Material Traceability Verification (MTV) Program. The purpose of this letter is to provide a summary of that presentation.
An Interim Report updating 10 CFR 50.55(e) No. 83-07 will be issued within a few weeks. It was delayed pending results of this meeting. The progress and findings of the MTV Program will be specified at that time.
Please address any questions that you or your staff may have concerning this matter to this office.
Very truly yours, L. O. DelGeorge Assistant Vice-President LOD /dak cc: NRC Resident Inspector - Braidwood Director of Inspection and Enforcement-U. S. Nuclear Regulatory Commission Washington, D.C.
20555 (1643d) 8507240172 850708 PDR ADOCK 05000456 A
r-4 ATTACHMENT 1 SUIMARY OF COfMENTS MADE BY ColmONWEALTH EDISON COMPANY PERSONNEL July 11, 1985 INTRODUCTION In the summer of 1983, NRC personnel had a concern about traceability of piping materials. Simply stated, their concern was whether, for a particular field location, the specified or correct material was checked out of the Warehouse and installed, and whether our documentation of the material used is correct.
COfMONWEALTH EDISON COMPANY RESPONSE To address the NRC concern and confirm our confidence in a system which the Phillips, Getschow Company had used for many years in doing ASME Work, we implemented a sampling review of the material traceability system. That review included a field walkdown of piping for identity of pipe markings, and a comparison of those markings to office documentation supporting material' traceability.
In February of 1984 we called in a team of ASME Code experts to review the Phillips, Getschow Company material traceability system, it's implementation, and the results of the sampling effort. That team consisted of the following individuals:
Ed Hemzy -- Commonwealth Edison Company Ernie Branch -- Sargent and Lundy Howard Dubell -- Hartford Steam Boiler It was the opinion of the ASME Code knowledgeable persons that the Phillips, Getschow system, as established, was adequate, and, as implemented was adequate to meet ASME Code Material Traceability requirements.
Commonwealth Edison Company personnel and the team of code experts, presented those conclusions to NRC personnel in February of 1984. Despite the conclusions presented, NRC personnel requested additional assurance that the material traceability system had been adequately implemented.
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's
, MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM In responding to the NRC's concern on this issue, commonwealth Edison Company implemented the Material Traceability 1
Verification Program, a 100% review of system implementation.
ACTIONS SUBSEQUENT TO MTV PROGRAM IMPLEMENTATION In addition to Ed Hemzy, Edison's Code knowledgeable person, the Project: retained the services of another ASME Code knowledgeable person -- Mr. Bill Gibbons.
Mr. Gibbons' expertise is in the materials area and materials application to ASME Code.
The ASME National Board was invited to Braidwood by Edison, in response to discussions with the NRC.
They have been at Braidwood since February 18, 1985. The National Board has been involved in the disposition of all non-conformances (NCR's) since about June 1,'1985, and is auditing NCR's dispositioned prior to their involvement. They are also auditing material traceability implementation after the 1983 cutoff dates.
Based on discussions with us, it is our understanding that they believe:
1.
That the Phillips, Getschow System, as implemented, provided adequate traceability of material and that the Stores Request System complies with the ASME Code.
2.
That in dispositioning NCR's, Edison is taking a conservative approach and meeting ASME Code requirements.
3.
That, given our approach to resolving MTV related issues, Edison will end up with a piping installation in full compliance with the ASME Code.
4.
That the Code recognizes the occurence of non-conformances as common, and therefore provides for non-conformance disposition and corrective action efforts, with involvement by the authorized inspection agency, as standard methods for assuring adequate resolution of the problems and compliance with the ASME Code.
I i
1
9 Commonwealth Edison Company, by it's own initiative, requested an opportunity to discuss the MTV Program and it's results with the Division of Boiler and the ASME L.ocal jurisdiction Pressure Vessel Safety of the Illinois State Fire Marshal's office. A meeting was arranged in Springfield on May 31, 1985 with representation also from the Illinois Department of Nuclear Safety. Subsequently, an additional meeting was held on June 17, 1985, at Braidwood. At the second meeting the results of the MTV Program were discussed in more detail, and the State of Illinois agencies had an opportunity again to discuss our efforts with the authorized inspection agency and the ASME National Board personnel.
Following the above meetings, Edison was informed that the personnel from the Illinois State Fire Marshal's Office were satisfied that our Program will result in assuring the piping systems at Braidwood site will be in compliance with the ASME Code. Further, they indicated that all decisions and acceptances of Edison's Program will be based on the advice and counsel of the ASME National Board personnel presently on the Braidwood site.
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- ATTACHMENT 2 COMMONWEALTH EDIS0N COMPANY BRAIDWOOD STATION MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM JUNE 25, 1985 NRC REGION III GLEN ELLYN, ILLINOIS L
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM AGENDA I.
INTRODUCTION MIKE WALLACE PROJECT MANAGER II.
PIPING MATERIAL TRACEABILITY DAN SHAMBLIN SYSTEM --
AND, MATERIAL CONSTRUCTION SUPT.
TRACEABILITY VERIFICATION (MTV) PROGRAM III.
RESULTS AND
SUMMARY
OF DAN SK0ZA MTV PROGRAM -
MECHANICAL FIELD ENG.
IV.
MTV PROGRAM FROM ASME ED HEMZY CODE PERSPECTIVE ASME B & PV COMMITTEE V.
MTV PROGRAM OVERSIGHT TOM QUAKA SITE QUALITY ASSURANCE SUPERINTENDENT VI.
SUMMARY
MIKE WALLACE PROJECT MANAGER (IS860)
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6 BIOGRAPHICAL DATA 0F PRESENTERS
BIOGRAPHICAL DATA Michael J. Wallace Assistant Manager of Projects (3 Years)
Braidwood Nuclear Power Station (2 Years)
Project Manager Education B.S.
Electrical Engineering Marquette University MBA (Specialization: Finance)
University of Chicago Nuclear Power School United States Navy evnerience Navy Nuclear Program 5 years U.S. Navy (Qualified Engineer officer)
Quality Assurance Engineer 3 years Clinch River Breeder Reactor Project Field Cost Engineer 1 year LaSalle, Byron, and Braidwood Project Coordinator 1 year Byron Project Asst. Station Superintendent 1 year State Line Station Station Superintendent 1 year Waukegan Station s.
Illinois Registered Professional Engineer Member, American Nuclear Society M er, Industry Review Group for construction Project Evaluation Division, Institute of Nuclear Power Operations (INPO)
I (1588d)
E BIOGRAPHICAL DATA Edwin J. Henzy Construction Manager (3 1/2 Years)
Station Construction Department Education B.S.M.E. Mechanical Engineering Illinois Institute of Technology MBA University of Chicago Experience Industrial / Utility Experience 39 years (Welding / Materials Engineering /
Manufacturing / Quality Assurance)
Station construction Department 16 years commonwealth Edison Quality Assurance company Engineering Staff For the past 12 years I have been deeply involved with ASME Boiler and Pressure Vessel Committee Activities including:
Gub-Committee on Nuclear Accreditation Sub-Connittee on Nuclear Power Main Committee Board of Nuclear Codes and Standards Board of Accreditation (1588d)
BIOGRAPHICAL DATA Daniel L. Shamblin Project Construction Superintendent Braidwood Nuclear Power Station (1 Year)
Education B.S.
Civil Engineering Michigan Techological University MBA University of Chicago Experience Construction Engineer 6 years Zion and LaSalle Project Coordinator 2 years LaSalle Project Assistant to Project Manager 2 years LaSalle Project Construction Superintendent 1 year LaSalle Project Field Engineering Manager 1 year Braidwood Project Illinois Registered Professional Engineer l
(1588d)
BIOGRAPHICAL DATA Daniel J. Skoza Special Projects Supervisor Project Field Engineering
.Braidwood Nuclear Power Station (1 Year)
Educetton B.S.
Astronomy University of Illinois M.S.
Physics Louisiana State University M.S.
Nuclear Engineering Iowa State University Experience Quality Assurance Engineer 3 1/2 years LaSalle Project construction Engineer 3 years LaSalle Project Tech Staff Engineer 3 months LaSalle Project (1588d) 1
a BIOGRAPHICAL DATA Thomas E. Quaka Quality Assurance Superintendent Braidwood Nuclear Power Station (1 Year) i Education B.S.
Mechanical Engineering University of Illinois MBA University of Chicago Experience Mechanical Engineer Dresden 6 years Station Nuclear
& Quad Cities Project Group Engineering Dept.
Quality Assurance Supervisor 2.5 years LaSalle Quality Assurance Superintendent 4.5 years LaSalle/Braidwood i
1 PROFESSIONAL AFFILIATIONS i
9 years (1975-1983)
Member of ASME Radweste Committee Chairman of operations Sub-Committee - 5 years (1977-1983) of the Radweste Committee Member Alternate - Sub-committee - 2.5 years (1983 to present) on Nuclear Accreditation l
(1588d)
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WILIJAM S. GIBBONS, PJL
SUMMARY
Mr. Gibbons has worked in manufacturing and the power industry since 1951.
His domestic and overseas experience includes foundry engineering, materials engineering of power plant components and fuel, process development, supplier and contractor evaluation and development, quality systems, quality assurance, inspection and site erection and construction. Mr. Gibbons is a recognized expert in quality for Regulatory and ASME Boller and Pressure Vessel Code Applications.
He has been involved in engineering review, licensing programs, and training. Since 1970, Mr. Gibbons has been an active participant as a member and chairman of Codes and Standards Committees in the development of requirements for power plant components.
He has served utilities, architect / engineers, and manufacturers as a consultant on design, construction, and quality systems.
RDUCATION:
M.B.A., University of California, Berkeley 1958 B.S., Metallurgical Engineering, University of California, Berkeley,1952 PROFEIMIONAL BACEGROUND:
American Society of Meehanical Engineers o
Member, Subgroup on General Requirements (SC II0 Co-Chairman, Working Group on Quality Assurance and Stamping (SC H0 o
l o
Member, Subcommittee on Nuclear Accreditation l
Task Group on Material Manufacturers and Suppliers (SC H0 o
o ASME-COURSE DIRECTOR, Quality Assurance ANIR/ASME NGA l
0 Committee on Nuclear Quality Assurance i
AMEarAN SOCIETY FOR QUAIErY COlfrROL Past Member o
ANSI B3L1, Power Piping o
ANSI B3L7, Nuclear Power Piping i
c ASME Subgroup on Materials (SC IH)
ASME Subgroup on Fabrication and Examination (SC H0 o
l o
ASTM Materials Committees 1
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WILIJAM S. GIBBONS, P.E.
Page Two 1
l PROFESSIONAL REGHrrRA'I10N:
i Metallurgical Engineer (State of California) i Quality Engineer (State of California)
Qualified Lead Auditor, ANSI-N-45.2.23 EXPERIENCE:
1981-present GIBBONS & ASSOCIATES Los Gatos, California President Currently Consulting with utilities, manufacturers and architect-i engineers 1980-1981 NUCLEAR TECHNOLOGY, INCORPORATED San Jose, California Chief Consultant, Quality 1969-1980 BECHTEL POWER CORPORA'I10N San Francisco, California Successively Supervising Metallurgical Engineer, Quality Assurance Manager, and Procurement / Supplier Quality Deputy Manager 1959-1969 GENERAL ELECTRIC COMPANY San Jose, California Successively Engineer, Manager, Quality Assurance Europe 1958-1959 SYLVAFIA (OTW Mountain Vlew, California Contracts Administration Analyst 1956-1958 RIDGE POUNDRY COMPANY San Learwiro, California Metallurgist 1954-1956 U.S. ARMY Fort Sill, Oklahoma Instructor l
1952-1954 WEB 11NGBOtBE ELECTRIC CORPORA 110N Pittsburgh, Pennsylvania Manufacturing Engineer l
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SECTION I INTRODUCTION PRESENTED BY M. J. WALLACE p
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MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM OVERVIEW l
NRC CONCERN ADEQUACY OF CONTROLS FOR ASSURING THE INSTALLATION OF CORRECT ASME CODE PIPING MATERIALS.
COMMONWEALTH EDISON COMPANY RESPONSE SAMPLING REVIEW 0F SYSTEM IMPLEMENTATION (AUGUST, FEBRUARY, 1984) 1983 REVIEW 0F SYSTEM FOR PROVIDING MATERIAL TRACEABILITY BY ASME CODE EXPERTS (FEBRUARY, 1984).
100% REVIEW 0F SYSTEM IMPLEMENTATION THROUGH MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM (JUNE, 1985)
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM MTV PROGRAM A UNIQUE, 30 MANYEAR, 100% PIPING WALKDOWN EFFORT VERIFIED MATERIAL TRACEABILITY THROUGH COMPARIS0N OF DOCUMENTATION WITH FIELD MARKINGS ON PIPE OVERALL OBJECTIVE ASSURE THAT BRAIDWOOD PIPING INSTALLATION IS FU.LLY IN COMPLIANCE WITH THE ASME CODE O
=
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM
SUMMARY
OF CONCLUSIONS THE MATERIAL TRACEABILITY SYSTEM (PROCEDURES AND PRACTICES), ESTABLISHED BY PHILLIPS, GETSCH0W COMPANY, MET ASME CODE REQUIREMENTS.
THE MTV PROGRAM CONFIRMS THAT THE SYSTEM ASSURED:
ADEQUATE TRACEABILITY OF MATERIALS ADEQUATE INSTALLATION OF CORRECT MATERIAL ASME CODE COMPLIANCE IS BEING ACHIEVED (1586D) 4,
e e.
SECTION 11 TRAbhA!fLMY kYhhEM AND kMkD A85A14" PRESENTED BY D. L. SHAMBLIN
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM TOPICS PHILLIPS, GETSCHOW COMPANY MATERIAL TRACEABILITY SYSTEM JULY, 1983 NRC CONCERNS AND ISSUES COMM0NWEALTil EDIS0N COMPANY RESPONSES MTV PROGRAM PURPOSE AND DESCRIPTION I
MTV PROGRAM IMPLEMENTATION
MATERIAL STORES REQUEST SYSTEM STORES REQUEST DENOTES:
- MATERIAL TYPE & GRADE
- CLASS SIZE, SCHEDULE i
- QUANTITY
- UNIQUE LOCATION
-HEAT / SERIAL NUMBER h
N YELLOW COPY y
/
STORES (
EOUEST PINK COPY-ENGR.
i FILE OFFICE Q.C.
WHITE COPY: VERIFICATION OF BLUE COPY CORRECT MATERIAL TO FIELD T
ER WITHDRAWAL ASME W/ASME 1
N-5 MATERIAL 4
I FIELD Q.C.
7 DATA REPORT
(
ASME PIPE i
U VERIFICATION OF I
O cm HT. *
)
1 9 CORRECT MATERIAL l L. INSTALLATION _;
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MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM NRC CONCERNS AND ISSUES JULY. 1983 A DOCUMENTED QUALITY CONTROL MATERIAL VERIFICATION AT THE POINT OF INSTALLATION SHOULD BE PERFORMED WITHOUT THE DOCUMENTED QUALITY CONTROL MATERIAL VERIFICATION, THE VALIDITY OF THE STORES REQUEST DOCUMENTATION AS AN ACCEPTABLE METHOD FOR MAINTENANCE OF HEAT NUMBER TRACEABILITY WAS QUESTIONABLE
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM COMMONWEALTH EDISON COMPANY RESPONSE PHILLIPS, GETSCH0W COMPANY WAS DIRECTED TO IMPLEMENT PROCFDURAL CHANGES REQUIRING QUALITY CONTROL INSPECTORS IQ BETTER DOCUMENT THEIR MATERIAL VERIFICATION INSPECTIONS DURING INSTALLATION ACTIVITIES (I.E. AT THE POINT OF INSTALLATION)
PHILLIPS, GETSCHOW COMPANY WAS DIRECTED TO UNDERTAKE A SAMPLE BASED MATERIAL TRACEABILITY VERIFICATION PROGRAM IQ ESTABLISH CONFIDENCE IN PAST INSTALLATIONS SAMPLE PROGRAM RESULTS MATERIAL TRACEABILITY WAS VERIFIED FOR AN EXCEPTIONALLY HIGH PERCENTAGE OF PIPING MATERIAL BY MATERIAL MARKING AND/0R STORES REQUEST DOCUMENTATION STORFS REQUEST DOCUMENTATION WAS VALIDATED THROUGH EXCEPTIONALLY HIGH CORRELATION WITH MATERIAL MARKINGS ASME CODE COMMITTEE MEMBERS REVIEW 0F THE MATERIAL TRACEABILITY SYSTEM CONFIRMED THAT ASME CODE REQUIREMENTS WERE MET.
100% REVIEW 0F NRC REQUESTED ADDITIONAL ASSURANCE INSTALLED ASME PIPING AND ATTACHMENTS
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MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRaB MTV PROGRAM PURPOSE AND DESCRIPTION PURPOSE l
PROVIDE ADDED ASSURANCE THAT CORRECT PIPING i
MATERIALS WERE INSTALLED l
j CONFIRM THE VALIDITY OF THE STORES REQUEST DOCUMENTATION l
l SCOPE 100% ASME LARGE BORE PIPING AND ATTACHMENTS INSTALLED PRIOR TO JANUARY 1, 1983 100% ASME SMALL BORE PIPING AND ATTACHMENTS INSTALLED PRIOR TO SEPTEMBER 6, 1983 DESCRIPTION SPECIAL PROCEDURES CONTROLLED PROGRAM ENGINEERING PREPARATION OF VERIFICATION PACKAGES INVOLVES FIELD AND OFFICE QUALITY CONTROL VERIFICATIONS COMPUTER ENTRY OF DATA FOR S0RTING
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SECTION III RESULTSg
SUMMARY
MTV PRO AM PRESENTED BY D. J. SK0ZA r_ -.,
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MATERIAL STORES REQUEST SYSTEM STORES REQUEST DENOTES:
-MATERIAL TYPE & GRADE
- CLASS, SIZE, SCHEDULE
-OUANTITY 2
-UNIQUE LOCATION
-HEAT / SERIAL NUMBER f6
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YELLOW COPY n
f STORES EOUEST [
PINK COPY _ ENGR.
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FILE OFFICE O.C WHITE COPY: VERIFICATIONIOF BLUE COPY CORRECT MATERIAL TO FIELD W/ASME I"##VELER WITHDRAWAL ASME p
N-5 MATERIAL 9
I FIELD Q.C.
1 DATA REPORT
(
ASME PIPE 1
O VERIFICATION OF I d
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)
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-- CORRECT MATERIAL' L INSTALLATION _j
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l-MTV OC VERFICATION OF l
CORRECT MATERIAL INSTALLATION BY:
VERIFICATION OF FIELD MATERIAL MARKINGS i
VERIFICATION OF STORES REQUEST DOCUMENTATION
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM MTV PROGRAM IMPLFMENTATION 57 PHILLIPS, GETSCH0W COMPANY QUALITY CONTROL PERSONNEL RECEIVED SPECIALI7ED TRAINING AND CERTIFICATION IN MATERIAL INSPECTIONS AND EVALUATIONS 44 PHILLIPS, GETSCHOW COMPANY QUALITY CONTROL FIELD PERSONNEL PERFORMED A lQQ1 INSPECTION OF APPR0XIMATELY 25.000 INSTALLED (ACCESSIBLE) CODE ITEMS IN A PERIOD OF 14 MONTHS 13 PHILLIPS, GETSCH0W COMPANY QUALITY CONTROL OFFICE PERSONNEL REVIEWED OVER 60.000 QUALITY CONTROL DOCUMENTS TO DATE APPR0XIMATELY 61,000 MANHOURS HAVE BEEN EXPENDED BY PHILLIPS, GETSCH0W COMPANY TO IMPLEMENT THIS PROGRAM.(43.000 FIELD: 18.000 0FFICE)
NUMEROUS AUDITS AND SURVEILLANCES COMPLETED BY INDEPENDENT PARTIES DURING PROGRAM IMPlFMENTATION (1587D)
MATERIAL STORES REQUEST SYSTEM STORES REQUEST DENOTES:
- MATERIAL TYPE & GRADE
- CL AS S, SIZE, SC HEDULE
-QUANTITY
- UNIQUE LOCATlON
-HEAT / SERIAL NUMBER fs N
YELLOW COPY a./
[ REQUEST STORES PINK COPY-ENGR.
FILE OFFICE O.C.
WHITE COPY-VERIFCATION OF BLUE COP (
CORRECT MATERIAL TO FIELD TR ELER WITHDRAWAL ASME W/ASME N-5 NATERIAL y F
FELD Q.C.
1 DATA REPORT
(
ASME PIPE
)
U
. VERIFICATION OF l i L D
C3 HT.#
/
1 5 CORRECT MATERIAL'
(_ INSTALLATION _j 4
iv TV OC VERF CATION OF
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F AT N
% TORES REQUEST ACCEPTABLE t
FIELD MARKINGS ACCEPTABLE NCR DISPOSITION
MATERIAL TRACEABILITY VERIFICATION (MTV)
ITEMS VERIFIED BY PHYSICAL INSPECTION AND/0R REVIEW 0F STORES REQUEST (SR) DOCUMENTATION (25,853 ITEMS) qp qf Y
PHYSICAL I.D.
SR ONLY PHYSICAL I.D.
NO PHYSICAL AND SR ONLY I.D. AND NO SR (81.9%)
(15.5%)
(2.2%)
(0.4%)
~
PHYSICAL I.D. AND SR PRESENT (21,164 ITEMS) 99%
THE SR AND PHYSICAL I.D. AGREE ESTABLISHING POSITIVE TRACEABILITY.
1%
THE SR AND PHYSICAL I.D. DO NOT AGREE. FURTHERMORE, (218 ITEMS)
DISPOSITION OF THE NONCONFORMANCES INDICATES 165
' ITEMS MEET ASME CODE REQUIREMENTS.
- THE CORRELATION OF 99% BETWEEN THE SR AND PHYSICAL I.D. IS EXCEPTIONALLY HIGH,
. THIS CONFIRMS THE ACCEPTABILITY OF THE PGC0 MATERIAL TRACEABILITY SYSTEM.
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SR ONLY (AS REQUIRED BY THE PHILLIPS, GETSCHOW COMPANY PROGRAH)
(4,006 ITEMS)
TRACEABLE ASME CODE ITEMS 3980 3374 THE ITEM HAS AN ACCEPTABLE SR WITH A TRACEABLE NUMBER, ALTHOUGH THE ASME CODE DOES NOT REQUIRE HEAT TRACEABILITY.
606 THE ITEM HAS AN ACCEPTABLE SR WITH A TRACEABLE NUMBER, WHEN THE ASME CODE REQUIRES HEAT TRACEABILITY.
26 ITEMS DISPOSITIONED FOR REPLACEMENT BECAUSE TRACEABILITY CANNOT BE ESTABLISHED.
i
PHYSICAL I.D. ONLY (579 ITEMS) 557 TRACEABLE ASME CODE ITEMS 273 MANUFACTURER'S MILL MARKING EXISTS ESTABLISHING TRACEABILITY 161 THE PHYSICAL I.D. INDICATES A TRACEABLE NUMBER ALTHOUGH THE ASME CODE DOES NOT REQUIRE HEAT TRACEABILITY THE PHYSICAL I.D. INDICATES A TRACEABLE 123 NUMBER WHEN THE ASME CODE REQUIRES HEAT TRACEABILITY ITEMS DISPOSITIONED FOR REPLACEMENT BECAUSE 22 TRACEABILITY CANNOT BE ESTABLISHED.
MORE THAN 99% OF THE TIME, THE PHYSICAL I.D. NUMBERS TRANSFERRED BY PGC0 HAVE BEEN DETERMINED TO BE CORRECT.
4 e
P NO PHYSICAL I.D. OR SR (104 ITEMS) 73 TRACEABLE ASME CODE ITEMS 64 ITEMS DISPOSITIONED AS ACCEPTABLE (THE ASME CCDE DOES NOT REQUIRE HEAT TRACEABILITY) 9 ITEMS DISPOSITIONED AS ACCEPTABLE (THE ASME CODE REQUIRED HEAT TRACEABILITY)
ITEMS DISPOSITIONED FOR REPLACEMENT BECAUSE 31 TRACEABILITY CANNOT BE ESTABLISHED.
NCR DISPOSITION 0F MTV ITEMS TO ASSURE ASME CODE TRACEABILITY REQUIREMENTS I.
ITEMS INITIALLY DETERMINED TO BE NONCONFORMING WERE DISPOSITIONED AS ACCEPTABLE WHEN THE FOLLOWING EXISTS TO PROVIDE HEAT TRACEABILITY:
MILL MARKING ADDITIONAL ASME CODE ACCEPTABLE PGC0 DOCUMENTATION II.
THE S&L SPECIFICATION AND PGC0 PIPING MATERIAL TRACE-ABILITY PROGRAM REQUIRES HEAT TRACEABILITY TO THE SPECIFIED LOCATION FOR ASME CLASS 1, 2, AND 3 PIPING.
IN CASES LISTED BELOW, THIS IS MORE RESTRICTIVE THAN ASME CODE RULES.
THE FOLLOWING ITEMS ARE DISPOSITIONED AS ACCEPTABLE WHEN THE PGC0 DOCUMENTATION INDICATES THE S&L SPECIFIED MATERIAL TYPE AND GRADE WAS INSTALLED.
l
. CLASS 1 AND 2 PIPING AND FITTINGS $ 3/4" o PER NA-3767.4(B) i
- CLASS 2 AND 3 INTEGRAL ATTACHMENTS PER NC/ND-2130 AND 2190 l
' CLASS 3 CONSTRUCTION PER ND-2150 l
III.
ITEMS DETERMINED AS NOT MEETING THE ASME CODE REQUIREMENTS ARE REMOVED AND REPLACED.
l
I MTV
SUMMARY
- THE ACCEPTABILITY OF THE PGC0 SR SYSTEM HAS BEEN CONFIRMED.
- PHYSICAL IDENTIFICATION OR PGC0 DOCUMENTATION EXISTS TO ESTABLISH MATERIAL TRACEABILITY.
80F THE.5% (132) 0F THE 25,853 ITEMS THAT REQUIRE REPLACEMENT DUE TO MATERIAL TRACEABILITY, PRELIMINARY ANALYSIS INDICATES
- FOR 122 ITEMS THE MATERIAL TYPE AND THICKNESS WERE KNOWN AND WERE CORRECT.
- ACTUAL STRESS LEVELS ARE LOW.
- NO DESIGN SIGNIFICANT DISCREPANCIES EXISTED.
- DISPOSITION OF ANY ITEMS UNRELATED TO MATERIAL TRACEABILITY, WHICH WOULD LIKELY BE FOUND IN A N-5 REVIEW, IS IN PROCESS AND WILL RESULT IN ACCEPTABLE MATERIAL.
1
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em SECTION IV I;
PRESENTED BY E. J. HEMZY e
1 1
i l
I ASME CODE /MTV PROGRAM CORRELATION CONCERNS INVOLVING MATERIAL CONTROL FOR ASME SECTION III CONSTRUCTION IS NOT UNIQUE TO THE BRAIDNOOD SITE.
THE SUBJECT i
i 0F ASME SECTION III MATERIAL INVOLVING DOCUMENTATION AND j
TRACEABILITY HAS BEEN DEBATED AND DISCUSSED AT LENGTH IN ASME COOSEITTEE MEETINGS, OVER CONNITTEE ACTIONS AND MOST CERTAINLY BY ColetITTEE PERSONNEL OUTSIDE OF ASME COMMITTEE ACTIVITIES.
l THE BOTTON LINE, HOWEVER, IS THAT ASME CODE RULES SUPPORT THE I
IDEA THAT TRACEASILITY TO THE POINT WHERE MATERIAL IS CONSUMED OR INSTALLED IN SYSTEMS OR COMPONENTS DURING INSTALLATION SATISFIES ASME SECTION III CODE RULES.
THE QUESTION OF THE PHILLIPS, GETSCHOW STORES' REQUEST l
PROCEDURE FOR MAINTAINING TRACEABILITY DURING INSTALLATION l
ACTIVITIES AT THE BRAIDWOOD SITE WAS REVIEWED AT LENGTH AT A l
l MEETING IN EARLY 1984 WITH NRC, AUTHORIZED INSPECTION AGENCY, 1
SARGENT AND LUNDY AND COOSEONWEALTH EDISON COMPANY PERSONNEL.
l i
AT THIS MEETING, CODE KNOWLEDGEABLE PERSONNEL OF THE PARTIES l
i INVOLVED REVIEWED THE SYSTEM IN DEPTH AND COIICLUDED THAT IT WAS
]
A VIABLE SYSTEM AND THAT THE PHILLIPS, GETSCHOW PROCEDURES l
INCLUDED THE MINIMUBE NECESSARY STEPS TO MEET THE ASME SECTION III CODE RULES.
FURTHERNORE, THE PHILLIPS, GETSCHOW BRAIDWOOD l
SITE. QUALITY ASSURAIICE PROGRAM, WHICH INCLUDED THE STORES j
REQUEST PROCEDURBS, HAS BEEN SURVEYED BY ASIEE ON THREE OCCASIONS AND HAS BEEN JUDGED ACCEPTABLE FROSE BOTH PROGRAISEATIC i
AND IMPLEMENTATION ASPECTS FOR IEEETING ASME CODE RULES.
ASME CERTIFICATES OF AUTHORIZATION WERE ISSUED IN ALL C$5ES.
FURTHERSIORE, I HAVE BEEN PERSONALLY INVOLVED IN DEEETINGS AND i
DISCUSSIONS OF THE PHILLIPS, GETSCHOW STORES REQUEST SYSTEM j
USED AT BRAIDWOOD AND I AGREE THAT IT WAS AND CONTINUES TO BE i
AN ACCEPTABLE PROGRAM AND CONFORMS TO ASME CODE RULES IN EFFECT FOR THE BRAIDWOOD SITE CONSTRUCTION.
j i
i
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IN ADDITION TO SCRUTINY BY ASME SURVEY TEAMS, THE PHILLIPS, GETSCHOW BRAIDNOOD SITE PIPING INSTALLATION ACTIVITIES HAVE BEEN UNDER CONTINUOUS SURVEILLANCE BY AUTHORIZED NUCLEAR INSPECTORS FOR ASME CODE COMPLIANCE.
IT HAS ALWAYS BEEN MY CONSIDERED OPINION THAT THE INDEPENDENT THIRD PARTY INSPECTION BY AUTHORIZED INSPECTORS IS THE STRENGTH AND BACKBONE OF THE ASME BOILER AND PRESSURE VESSEL CODE FOR ASSURING COMPLIANCE WITH ASME CODE RULES.
I BELIEVE I HAVE jT39t[g, SUPPORT FOR THAT OPINION.
FURTHER TO THE POINT OF ADHERENCE TO THE REQUIREMENTS OF ASME CODE CONSTRUCTION, COMMONWEALTH EDISON COMPANY HAS HAD ASME NUCLEAR ACCREDITATION FOR ASSUMING OVERALL CODE RESPONSIBILITY FOR CONSTRUCTION OF ITS NUCLEAR PONER GENERATING STATIONS SINCE EARLY 1975.
TOP MANAGEMENT HAS ALWAYS MAINTAINED A COMMITMENT TO SUPPORT THE ASME BOILER AND PRESSURE VESSEL CODE AND COMPLIANCE WITH ITS RULES.
THE CURRENT BRAIDWOOD MTV PROGRAM FOR M REVIEW OF DOCUMENTED RECORDS IS SUFFICIENTLY LONG AFTER WHEN THE WORK WAS PERFORMED TO RENDER POSITIVE CONCLUSIONS ABOUT INCOMPLETE MATERIAL TRACEABILITY BASED ON REVIEW OF MATERIAL MARKING SOMEWHAT MOOT IN MY OPINION.
THE CODE RULES IN EFFECT FOR THE BRAIDWOOD CONSTRUCTION ONLY REQUIRED THAT MARKING BE MAINTAINED ON A MATERIAL UNTIL INSTALLATION.
THESE WORDS CAN BE FOUND IN PARAGRAPH 4122 FOR ALL CLASSES OF CONSTRUCTION IN THE 1974 EDITION, 1975 SIDSEER ADDENDA RULES WHICH ARE IN EFFECT FOR THE BRAIDWOOD CONSTRUCTION.
IN THE TIME SPAN SINCE ACTUAL INSTALLATION OF MANY ITEMS, IT IS APPARENT THAT SOME OF THE IDENTIFICATION MARKINGS HAVE BEEN DISTORTED OR LOST BECAUSE OF SUBSEQUENT INSTALLATION ACTIVITIES.
THIS DOES NOT, IN MY OPINION, REPRESENT NON-COMPLIANCE WITH CODE RULES.
i THE ASME CODE RULES DO NOT ADDRESS THE NEED FOR MAINTAINING MATERIAL MARKING BEYOND THE TIME OF INSTALLATION.
THE I
RE-REVIEWS OF THE RECORDS STRONGLY SUPPORT AND HAVE SHOWN, WITH LITTLE DOUBT IN MY MIND, THAT THE PHILLIPS, GETSCHOW COMPANY STOhES REQUEST SYSTEM ASSURED ADEQUATE TRACEABILITY TO THE POINT OF INSTALLATION.
THE ASME CODE RULES HAVE ALWAYS RECOGNIZED THAT NOTHING IS PERFECT AND ALLOW FOR THE EXISTENCE OF NONCONFORMANCES.
TO THAT POINT, AN HISTORIC MEETING WAS CONVENED IN FEBRUARY OF 1984 AT DALLAS, TEXAS AND ATTENDED BY MANY ASME CODE KNOWLEDGEABLE PEOPLE.
MANY OF THOSE IN ATTENDANCE HAD
" HANDS-ON" EXPERIENCE WITH ASME SECTION III NUCLEAR PLANT CONSTRUCTION.
PERSONNEL REPRESENTED NRC, JURISDICTIONS,
' ARCHITECT / ENGINEERS, MANUFACTURERS, INSTALLERS, FABRICATORS, AND OWNERS.
I ATTENDED THAT MEETING AND THERE WAS STRONG l
CONCERN THAT SPECIFIC SITE PROBLEMS ARE BLOWN OUT OF CONTEXT.
AT THAT MEETING IT WAS AGREED THAT CONCERNS ARE BEST HANDLED BY CONTAINING THEM AT THE SITE AND RESOLVING THESE WITH THE INVOLVED PARTIES.
FURTHER TO THIS POINT, AN ASME POSITION STATEMENT WAS DEVELOPED AS A RESULT OF THAT MEETING AND PUBLISHED IN THE SEPTEMBER, 1984 EDITION OF MECHANICAL ENGINEER, THE OFFICIAL PUBLICATION OF ASME.
I WOULD LIKE TO QUOTE ONE VERY SIGNIFICANT PARAGRAPH FROM THAT ARTICLE.
"NONCONFORMANCE IS DEFINED IN NCA-9000 OF SECTION III, GENERAL REQUIREMENTS, AS A DEFICIENCY IN CHARACTERISTIC, DOCUMENTATION, OR PROCEDURE THAT RENDERS AN ' ITEM OR l
ACTIVITY UNACCEPTABLE OR INDETERMINATE.
THIS DEFINITION OF NONCONFORMANCE CAN CONCEIVABLY ENCOMPASS A WIDE RANGE OF POSSIBILITIES, BOTH IN VARIETY AND LEVEL OF SIGNIFICANCE TO SAFETY AND ADEQUACY OF THE EQUIPMENT.
-4 THE POSITION STATEMENT SIMPLY STATES THAT THE BEST APPROACH IN DECIDING WHAT NEEDS TO BE DONE TO VERIFY CODE COMPLIANCE WHEN A REPORTED DEFICIENCY MAKES THE QUALITY OF THE ITEM QUESTIONABLE, OR TO CORRECT A KNOWN DEFICIENCY, IS TO HAVE THE RESPONSIBLE PARTIES AGREE ON THE PLAN OF ACTION TO ENSURE THAT THE EQUIPMENT MEETS THE CODE."
IT IS MY CONSIDERED OPINION THAT THE MATERIAL TRACEABILITY VERIFICATION EFFORT AT BRAIDWOOD VERIFIES THAT THE PHILLIPS, GETSCHOW STORES REQUEST PROCEDURE ASSURED TRACEABILITY TO THE POINT OF INSTALLATION AND MET THE ASME SECTION III CODE RULES.
TO REACH THIS CONCLUSION I HAVE REVIEWED THE WORK OF SITE PERSONNEL USED IN COMPILING THE DATA FOR THE MTV PROGRAM AND DISPOSITIONING OF NONCONFORMANCES AND I AM CONVINCED THAT THERE HAS BEEN, AND WILL BE, PROPER RESOLUTION OF MATERIAL INSTALLATION.
THIS REVIEW HAS REINFORCED MY CONFIDENCE IN THE PHILLIPS, GETSCHOW STORES REQUEST SYSTEM FOR ASSURING INSTALLATION OF REQUIRED MATERIAL IN ASME SECTION III CONSTRUCTION AT BRAIDWOOD.
THIS IS CONSISTENT WITH THE POSITION WHICH I STATED IN EARLY 1984 AT
-l THE MEETING OF COMMONWEALTH EDISON COMPANY, NRC REGION III PERSONNEL, AND OTHER INVOLVED PARTIES.
THE QUALITY RECORDS ON FILE AT THE SITE ALONG WITH RELATED DOCUMENTATION STRONGLY SUPPORT THAT CORRECT MATERIAL WAS INSTALLED IN PIPING SSTEMS AT THE BRAIDWOOD NUCLEAR PLANT.
(lS92d) 1
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM ASME CODE /BRAIDWOOD MTV PROGRAM CORREL ATION ASME SECTION III RULES ARE SATISFIED BY MATERIAL TRACEABILITY TO POINT OF CONSUMPTION OR INSTALLATION PHILLIPS, GETSCH0W COMPANY STORES REQUEST PROCEDURE MEETS ASME CODE RULES AUTHORIZED NUCLEAR INSPECTION IS INDEPENDENT OVERVIEW AND VERIFICATION 0F CONFORMANCE TO CODE RULES COMMONWEALTH EDIS0N COMPANY MANAGEMENT IS COMMITTED TO ASME CODE COMPLIANCE BRAIDWOOD MTV PROGRAM VERIFIES THAT PHILLIPS, GETSCH0W COMPANY STORES REQUEST PROCEDURE PROVIDED METHOD FOR TRACKING REQUIRED MATERIAL TO POINT OF INSTALLATION ASME POSITION STATEMENT RECOGNIZES NONCONFORMANCES AND RESOLUTION TO MEET ASME CODE RULES
e o
e e
SECTION V MTV ObhGT PRESENTED BY T. E. QUAKA
OVERVIEW OF THE MTV PROGRAM BY EDISON SITE QUALITY ASSURANCE O
PARTICIPATED IN THE PROGRAM DEVELOPMENT 0
REVIEWED AND APPROVED IMPLEMENTING PROCEDURES 0
PERFORMED AUDITS AND SURVEILLANCES OF BOTH FIELD AND OFFICE ACTIVITIES.
ONLY MINOR ITEMS WERE IDENTIFIED.
O REVIEWED ALL MTV RELATED NCR'S GENERATED (ON-G0ING) T0:
ASSURE PROPOSED DISPOSITIONS WERE APPROPRIATE VERIFY.THAT CORRECTIVE ACTIONS ARE PROPERLY COMPLETED (3110A)
O INDEPENDENT OVERVIEWS e
MTV PROGRAM AND ITS IMPLEMENTATION WAS MONITORED / REVIEWED BY l
0 EDIS0'l QUALITY ASSURANCE O
PHILLIPS, GETSCHOW QUALITY ASSURANCE O
AUTHORIZED NUCLEAR INSPECTORS 0
NATIONAL BOARD 0
INSTITUTE OF NUCLEAR POWER OPERATIONS (INP0) 0 BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM (BCAP) h i
(3110A)
,wik
'e FXAMPlFS OF 0.A. ITEMS IDENTIFIED O
RESOLVE LOG INCONSISTENCIES DUE TO PROCEDURAL CHANGES.
O PRbCEDUREREVISIONADDEDAFORMANDDETERMINATIONOF NEED FOR BACKFIT WAS TO BE PERFORMED.
O ADD COMMENTS ON THE CHECKLISTS TO PROVIDE CLARITY WHEN CORRECTIONS ARE MADE.
(3110A)
~
OVERVIEW BY OTHER GROUPS 0
EDIS0N CORPORATE QUALITY ASSURANCE PERFORMED AN EVALUATION OF THE MTV PROGRAM AND CONCLUDED THAT THE ESTABLISHED PROGRAM 1
ADEQUATELY ADDRESSED THE ORIGINAL NRC CONCERNS.
O AUTHORIZED NUCLEAR INSPECTORS HAVE MONITORED THE PROGRAM ON AN ON-G0ING BASIS.
O PGC0 QUALITY ASSURANCE MONITORED THEIR PORTION OF THE MTV PROGRAM THROUGH AUDIT AND SURVEILLANCE.
0 OTHER ORGANIZATIONS LOOKING AT THE PROGRAM INCLUDED INP0, BCAP, AND MOST RECENTLY THE NATIONAL BOARD AUDIT TEAM.
THEIR COMMENTS HAVE BEEN ADDRESSED AND HAVE PROVIDED ADDED ASSURANCE THAT THE MTV PROGRAM WAS PROPERLY EXECUTED.
GFNFRAL CONCLUSION:
SITE QUALITY ASSURANCE INVOLVEMENT IN CONJUNCTION WITH THE COMMENTS FROM THE OTHER ORGANIZATIONS LEAD TO OUR CONCLUSION THAT THE MTV PROGRAM HAS BEEN PROPERLY IMPLEMENTED AND DOCUMENTED.
(3110A) 1
~
l 9
W SECTION VI
SUMMARY
PRESENTED BY M. J. WALLACE O
r-MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM
SUMMARY
1 OVFRAIL OBJECTIVE i
ASSURE THAT BRAIDWOOD PIPING INSTALLATION IS FULLY IN COMPLIANCE WITH THE ASME CODE ACTIONS SUBSEQUENT TO MTV PROGRAM IMPlFMENTATION REVIEW BY ASME CODE EXPERTS REVIEW BY ASME NATIONAL BOARD MEETINGS AND DISCUSSIONS WITH ILLIN0IS DIVISION OF BOILER INSPECTION, ATTENDED BY ILLIN0IS DEPARTMENT OF NUCLEAR SAFETY CONCLUSIONS THE BRAIDWOOD PIPING INSTALLATION COMPLIES WITH THE ASME CODE COMMONWEALTH EDISON'S INTENTION IS TO CONTINUE TO ASSURE COMPLIANCE WITH THE ASME CODE REGARDING I
RESOLUTION OF ANY PROBLEMS IDENTIFIED AND COMPLETION OF NEW INSTALLATIONS
.