ML20129F619
| ML20129F619 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/12/1985 |
| From: | Lauer R COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Brenner L, Callihan A, Cole R Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-811 ALAB-143, OL, NUDOCS 8507170412 | |
| Download: ML20129F619 (87) | |
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- < coussumsn uw Dogge Ten THREE FIRST NATIONAL PLAZA c-cA= -s-
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00CXETING & SERvif.f BRANCH Lawrence Brenner, Esq.
Chairman Administrative Law Judge Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, DC 20555 Dr. Richard F. Cole Dr. A. Dixon Callihan Administrative Law Judge Administrative Law Judge Atomic Safety and Licensing 102 Oak Lane Board Oak Ridge, TN 37830 United States Nuclear Regulatory Commission Washington, DC 20555 Re: In the Matter Of: Commonwealth Edison Company (Braidwood Nuclear Power Station, Units 1 and 2), Docket Nos. 50-456, 50-457. 'O(
Dear Administrative Judges:
In accordance with the disclosure requirements set forth in Duke Power Company (William B. McGuire Nuclear Station, Units 1 and 2), ALAB-143, 6 AEC 623 (1973), I have enclosed copies of a July 3, 1985 letter from A. D. Miosi, commonwealth Edison Nuclear Licensing Administrator, to James Keppler, NRC Regional Administrator, a July 3, 1985 letter from Duane R. Gallup, Superintendent of Boiler & Pressure Vessel Safety, to Michael J. Wallace, Braidwood Project Manager, and a July 8, 1985 letter from L. O. DelGeorge, Commonwealth Edison Assistant Vice-President to James Keppler.
These documents concern the Braidwood Material Traceability Verification Program and are directly relevant to issues 1.B. at page 20 and 10.B. at pages 37-38 of the amended contention, as admitted by the Board in its Order of June 21, 1985.
Respectfully,
! 8507170412 850712 M.* < j'.
i PDR ADOCK 05000456 4 %..
g PDN Rebecca J.'Lauer RJLibc One of the Attorneys For
! Encs. COMMONWEALTH EDISON COMPANY cc: Service List 1
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00CKETED USNRC j- UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION 15 Jul.16 Al0:09 l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GFFICE OF SECRtiAni 00CKETING & SERVlu' In the Matter Of: ) BRANCH
)
COMMONWEALTH EDISON COMPANY )
) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I, Rebecca J. Lauer, one of the attorneys for Commonwealth Edison Company, certify that copies of the letter, dated July 12, 1985, from Rebecca J. Lauer to the Administrative Judges, together with copies of the_en-closures thereto, have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 12th day of July, 1985.
"m. , <<t Rebecca J. Lauer ISHAM, LINCOLN & BEALE Three First National Plaza Suite f200 Chicago, Illinois 60602 (312) 558-7500 DATED: July 12, 1985 I
SERVICE LIST Lawrence Brenner, Esq. Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 C. Allen Bock, Esq.
P.O. Box 342 Dr. Richard F. Cole Urbana, IL 61801 Administrative Law Judge Atomic Safety and Licensing Board Ms. Bridget Little Rorem United States Nuclear Regulatory 117 North Linden Street Commission P.O. Box 208 Washington, DC 20555 Essex, IL 60935 Dr. A. Dixon Callihan Robert Guild Administrative Law Judge Douglass W. Cassel, Jr.
102 Oak Lane Timothy W. Wright, III Oak Ridge, TN 37830 BPI 109 North Dearborn Street Suite 1300 Myron Karman, Esq. Chicago, IL 60602 Elaine I. Chan, Esq.
Office of the Executive Legal Director Ms. Lorraine Creek United States Nuclear Regulatory Route 1 Commission Box 182 Washington, DC 20555 Manteno, IL 60950 Atomic Safety and Licensing Charles Jones, Director Board Panel Illinois Emergency Services United States Nuclear Regulatory and Disaster Agency Commission 110 East Adams Washington, DC 20555 Springfield, IL 62705 Atomic Safety and Licensing Appeal Board Panel United States Nuclear Regulatory Commission Wnshington, DC 20555
I' e' l i
Office of the 1/Hnois State Fire Marshal DIVISION OF BOILER AND PRESSURE VESSEL SAFETY July 3, 1985 l Michael J. Wallace, Project Marager Commonwealth Edison Company Braidwood Nuclear Power Station Rt. 1, Box 81 Braceville, IL 60407
Dear Mr. Wallace:
Attached is a copy of the minutes pertaining to the presentation given by Comonwealth Ediscn Company to the Office of the State Fire Marshal and the Department of Nuclear Safety held in Springfield, May 30, 1985.
tnaly yours,
~
h Duane R. Gallup Supt. of Boiler 6 Pressure Vessel Safety DRG: lab Enclosure 3150 Executive Park Drive, Springfield, Illinois 62706
- 217/782-2696
MEETING WITH COMMONWEALTH EDISON COMPANY l STATUS OF THE BRAIDWOOD NUCLEAR POWER STATION
.The presentation by Commonwealth Edison Comp'any personnel to the Office of the State Fire Marshal and the Department of Nuclear Safety on materials involved in ASME Code related installation work at the Braidwood Nuclear. Station was held at the Office of the State Fire Marshal, 3150 Executive Park Drive, Springfield, Illinois on Thursday, May 30, 1985.
Mr. Gallup opened the meeting at 10:00 a.m. and began with introductions. Those in attendance are listed below:
Commonwealth Edison Company Edwin J. Hemzy, Construction Manager, Technical Support Daniel J. Skoza, Project Field Engineering Supervisor Daniel L. Shamblin, Project Construction Superintendent Warren E. Vahle, -Project Field Engineering Manager Michael J. Wallace, Project Manager Department of Nuclear Safety Donald Benz, Lead Electrical Engineer Kathleen N. Knepper, Assistant Legal Advisor Dale Powell, Lead Mechanical Engineer Steven W. Swartz, Lead Nuclear Engineer Hartford Steam Boiler C. M. Dec ker, Regional Manager ,
R. T. Rainey, Assistant Regional Manager National soiler of Boiler and Pressure Vessel Inspectors Charles W. Allison, Field Representative Robert P. Holt, Consultant Michael F. Sullivan, Consultant Phillips, Getschow Company Jack Carlson, Quality Control Manager John A. Hite, Executive Vice President Office of the State Fire Marshal Harold L. 3chmeilski, State Fire Marshal Duane R. Gallup, Superintendent of Boiler Safety Victor Bogosian, Jr., Assistant Superintendent of Boiler Safety Lisa Bell, Secretary
Ff Commonwaalth Edison Company Page 2 Mr. Wallace of Commonwealth Edison started the presentation by stating they requested the meeting to update the Office of the State Fire Marshal and the Department of Nuclear Safety concerning material identification involved in ASME Code related installations at the Braidwood Nuclear Power Station. Based on a concern of the NRC in 1983 of documentation associated with material traceability of Code piping at the point of installation at the Braidwood site, an audit was performed by Commonwealth Edison, Phillips, Getschow, and Sargent Ldndy. Upon further request from the NRC, Commonwealth Edison agreed to a 100 percent verification effort. Mr. Wallace gave a summary of presentation to be given: The history of the program conducted cnd conclusions they are reaching as the program draws to a close; steps they are taking to resolve issues in the program; and proposal of a multi-party agreement as one alternative to document resolution
, of' certain material traceability verification issues.
Each speakers' presentation was implemented with visual documen-tation, copies of which are attached.
The next speaker was Mr. Shamblin who covered the piping material traceability verification program used by Phillips, Getschow Company which has been accepted in previous ASME Code surveys. He also discussed NRC concerns and the sample. program and results, the material traceability verification program's purpose, description and implemen-tation. He also showed a sample of the Stores Request document used by Phillips, Getschow and explained its use.
j Mr. Shamblin advised that in February, 1984, Mr. Hemzy and Sargent Lundy personnel met with the ASME to review the program and it was concluded the program met the ASME Code requirements. He further l
Commonwscith Edison Compnny Pcgn 3 listed the NRC's concern's, which are also included in the attached summary. He then described the sampling. program'used-to establish confidence in past installations and the results wherein more than 99 percent of the Stores Requests and material markings matched. It was at this point the NRC requested additional assurance -
a 100 percent verification of the material traceability program.
The next speaker was Mr. Skoza who supplied a summary of the material traceability verification program stating that, at a minimum, 97 percent of the material met the ASME material traceability require-ments. The remaining material will be dispositioned as non-conformities if verification is not achieved. Upon question, he indicated the items that are buried and inaccessible to physical verification were the ones where a Stores Request only check was used.
The next speaker was Mr. Hemzy, ASME Code person for Commonwealth Edison Company and his entire statement is attached.
Concluding for Commonwealth Edison was Mr. Wallace. He empha-cized that commonwealth Edison Company wants to assure Code compliance and the quality of the Braidwood project. He also described the on-
< going work being done to disposition all material and estimated the disposition would be completed within the next two weeks so all concerned could discuss a multi-party agreement, if necessary, at that time. Mr. Wallace advised if material does not meet the Code, they will cut out and replace. They want everyone to agree they have an acceptable installation wherein he suggested a meeting be held on June 13, 14 or 17 at the Braidwood site with members of the'jurisdic-tional authority to decide if a multi-party agreement is necessary.
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Commonwealth Editon Company '
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Mr. Wallace advised Commonwealth Edison was meeting with the NRC on June 20, 1985 and want to present results to the NRC of the material traceability verification program and conclusions. He further stated the National Board is presently performing an audit of the construction activities.
Ms. Knepper of the Department of Nuclear Safety questioned if everything is dispositioned and all non-conformities are resolved, if it would be necessary to have the multi-party agreement. Mr.
Hemzy-stated they may resolve all items but would still prefer to have the meeting to assure everyone agrees and they are interested in obtaining concurrence of the jurisdiction with the way they are achieving compliance.
Mr. Gallup asked for comments from the National Board and Mr.
Sullivan stated they have followed the material traceability verifi-cation program closely and have confidence in the work Commonwealth Edison is doing and stated the problem for the group to resolve was the issue of inaccessible pipe that is buried for which no physical verification can be made and whether it will impact the hardware in the future and these issues are what should be addressed in a multi-party agreement.
Upon question, Mr. Hite of Phillips, Getschow stated they verified items at the Braidwood site at the point of installation but ASME verification was not documented to back up the Stores Requests.
Mr. Rainey of Hartford Steam Boiler added they have followed the program closely and are also satisfied that it meets Code requirements.
Ms. Knepper inquired on the implications the proposed meeting with the jurisdiction would have on Commonwealth Edison's meeting with
Commonwcalth Edicon Company Page 5 the NRC on June 20, 1985. Mr. Wallace stated the NRC called the meeting and it would take place regardless of the meeting with the jurisdiction but they wculd like to present the contents of this meeting and the proposed meeting to the NRC. He further advised that Commonwealth Edison has no discussion with the NRC inspector on their findings as the NRC has taken the position that this is not a non-conformity but an unresolved item.
Upon question, Mr. Sullivan stated the National Board audit, after follow-up, may be completed by the end of July. Mr. Hemzy emphasized that'the material traceability verification is a specific issue they want to resolve now and the National Board is auditing many other items and Mr. Gallup added the National Board could possibly find other deficiencies. 'Mr. Sullivan stressed that the multi-party agreement does not superceed the Code and Commonwealth Edison would still have to meet Code compliance.
Mr. Allison of the National Board added that he felt Commonwealth Edison wants and plans to achieve Code compliance and approves of the program they now utilize.
After further discussion, a tentative meeting date was set for June 17, 1985 upon verification from the Department of Nuclear Safety's otaff and it was agreed the meeting date would be set up through Mr.
Gallup.
In his closing comments, Mr. Wallace thanked everyone for attending the meeting on such short notice as every day is important to them.
Mr. Gallup thanked them for the presentation and information presented.
The meeting was adjourned at approximately 12:00 p.m.
E COMMONWEALTH EDISON COMPANY BRAIDWOOD PROJECT PRESENTATION TO ILLINDIS DIVISION OF BOILER INSPECTION AND ILLINDIS DEPARTMENT OF NUClFAR SAFETY ON MATERIALS INVOLVED TR t
ASME CODE RELATED INSTALLATION WORK MAY 30, 1985 SPRINGFIELD, ILLIN0IS,
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I. INTRODUCTION PRESENTED BY MIKE WALLACE PROJECT MANAGER
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9 BRAIDWOOD PROJECT AGENDA I. INTRODUCTION MIKE WALLACE PROJECT MANAGER II. MECHANICAL ERECTION CONTRACTOR DAN SHAMBLIN MATERIAL TRACEABILITY PROGRAM CONSTRUCTION SUPT.
AND, MATERIAL 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 CONSTRUCTION MANAGER, AND ASME CODE PERSON FOR COMMONWEALTH EDIS0N V.
SUMMARY
MIKE WALLACE
, PROJECT MANAGER 1
BRAIDWOOD PROJECT OVERAll
SUMMARY
A. THE MTV (MATERIAL TRACEABILITY VERIFICATION) PROGRAM COMPLETED BY PHILLIPS, GETSCH0W COMPANY CONFIRMS THAT THE OVERALL PROGRAM FOR PAST MECHANICAL INSTALLATION WORK MET THE ASME CODE MATERIAL TRACEABILITY REQUIREMENTS.
B. THROUGH THE IMPLEMENTATION OF THE MTV PROGRAM, A UNIQUE, 30 MANYEAR, 100% WALKDOWN EFFORT, A LIMITED NUMBER OF POSSIBLE NONCONFORMANCES HAVE BEEN IDENTIFIED WHICH REQUIRE DISPOSITION.
C. THE INVOLVED PARTIES MAY CONSIDER IT USEFUL TO UTILIZE A
" MULTI-PARTY AGREEMENT" TO DOCUMENT RESOLUTION OF CERTAIN MTV ISSUES: IF S0, CONSIDER THE POTENTIAL PROCESS TO BE FOLLOWED.
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II. MECHANICAL ERECTION CONTRACTOR MATERIAL TRACEABILITY PROGRAM -- AND MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM PRESENTED BY DAN SHAMBLIN PROJECT CONSTRUCTION SUPERINTENDENT w - ~.~ --- -- ., ,..-.,,---..c-,
PIPING MATERIAL TRACIABILITY TOPICS PHILLIPS, GETSCH0W COMPANY MATERIAL TRACEABILITY SYSTEM INDEPENDENT REVIEWS OF PHILLIPS, GETSCH0W COMPANY MATERIAL TRACEABILITY SYSTEM NRC CONCERNS AND ISSUES --
JULY, 1983
~
SAMPLING PROGRAM AND RESULTS --
AUGUST, 1983 MTV PROGRAM PURPOSE AND DESCRIPTION MTV PROGRAM IMPLEMENTATION
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PIPING MATERIAL TRACFABILITY PHILLIPS. GETSCHOW COMPANY MATERIAL TRACEABILITY SYSTEM STORES REQUEST (SR)
MATERIAL TYPE AND GRADE, PIPING CLASS, SIZE, SCHEDULE AND QUANTITY DRAWING NUMBER AND REVISION HEAT OR SERIAL NUMBER OF WITHDRAWN MATERIAL STORES REQUEST INCLUDED IN INSTALLATION TRAVELER PACKAGE QUALITY CONTROL PERFORMED 0FFICE AND FIELD MATERIAL VERIFICATIONS DURING INSTALLATION ACTIVITIES STORES REQUEST PART OF DOCUMENTATION USED TO SUPPORT N-5 REVIEW AND SIGN 0FF
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PIPING MATERIAL TRACEABILITY INDEPENDENT REVIEWS OF PHIll IPS. GFTSCHOW COMPANY MATERIAL TRACEABILITY SYSTEM ASME ACCREDITATION SURVEYS ASME SECTION III, 1974 EDITION, SUMMER 197S ADDENDA THREE (3) SURVEYS PERFORMED, LATEST AUGUST, 1984
- PHILLIPS, GETSCH0W COMPANY INTERNAL AUDIT AND SURVEILLANCE COMMONWEALTH EDIS0N COMPANY AUDIT AND SURVEILLANCE THIRD PARTY (AUTHORIZED NUCLEAR INSPECTOR)
INSPECTIONS ASME CODE COM'MITTEE PERSONNEL FEBRUARY, 1984
PIPING MATERIAL TRACEABILITY NRC CONCERNS AND ISSUES --
JULY. 1983 NRC INSPECTOR STATED A DOCUMENTED QUALITY CONTROL INSPECTION MATERIAL VERIFICATION AT THE POINT OF INSTALLATION WAS REQUIRED IN ALL CASES TO MEET ASME
~~
CODE AND FEDERAL REGULATIONS
-NRC INSPECTORS QUESTIONED THE VALIDITY OF THE STORES REQUEST DOCUMENTATION AS AN ACCEPTABLE METHOD FOR MAINTENANCE OF HEAT NUMBER TRACEABILITY PHILLIPS, GETSCH0W COMPANY RESPONDED T0.NRC CONCERN WITH PROCEDURAL CHANGES REQUIRING QUALITY CONTROL INSPECTORS TO BETTER DOCUMENT THEIR MATERIAL VERIFICATION INSPECTIONS DURING INSTALLATION ACTIVITIES (I.E. AT THE POINT OF INSTALLATION)
PHILLIPS, GETSCHOW COMPANY UNDERT0OK A SAMPLE BASED MATERIAL TRACEABILITY VERIFICATION PROGRAM TO ESTABLISH CONFIDENCE IN PAST INSTALLATIONS
PIPING MATERIAL TRACEABILITY SAMPLING PROGRAM AND RESULTS --
AUGUST. 1983 RAND 0M SAMPLE BASED ON MIL STANDARD 105D INCLUDED 1404 SMALL BORE PIPING ITEMS AND 551 LARGE BORE PIPING ITEMS TRACEABILITY VERIFIED BY MATERIAL MARKING AND/0R STORES REQUEST DOCUMENTATION STORES REQUEST DOCUMENTATION VALIDATED BY CORRELATION WITH MATERIAL MARKING RESULTS POST-INSTALLATION MATERIAL TRACEABILITY WAS MAINTAINED FOR HIGH PERCENTAGE OF PIPING MATERIAL STORES REQUEST DOCUMENTATION FOR MATERIAL TRACEABILITY VALIDATED THROUGH HIGH CORRELATION (GREATER THAN 99%) WITH MATERIAL MARKINGS
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PIPING MATERIAL TRACEABILITY MTV PROGRAM PURPOSE AND DESCRIPTION NRC REQUESTED ADDITIONAL ASSURANCE --
100%
VERIFICATION PURPOSE ADDED ASSURANCE CORRECT PIPING MATERIALS INSTALLED PROVIDE HIGH CONFIDENCE LEVEL IN STORES REQUEST DOCUMENTATION SCOPE 100% ASME LARGE BORE PIPING INSTALLED PRIOR TO JANUARY 1, 1983 100% ASME SMALL BORE PIPING 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 SORTING
PIPING MATFRIAI TRACFABILITY MTV PROGRAM IMPLEMENTATION S7 PHILLIPS, GETSCHOW COMPANY QUALITY CONTROL PERSONNEL RECEIVED SPECIALIZED TRAINING AND CERTIFICATION IN MATERIAL INSPECTIONS AND EVALUATIONS 44 PHILLIPS, GETSCHOW COMPANY QUALITY CONTROL FIELD PERSONNEL PERFORMED A 100% INSPECTION OF APPR0XIMATELY 26.000 INSTALLED (ACCESSIBLE) CODE ITEMS IN A PERIOD 0F 14 MONTHS 13 PHILLIPS, GETSCH0W COMPANY QUALITY CONTROL 0FFICE 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 --
FAVORABLE RESULTS i
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SUMMARY
OF MTV PROGRAM PRESENTED BY DAN SK0ZA 4
MECHANICAL FIELD ENGINEER i
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MATERIAL TRACEABILITY VERIFICATION (MTV)
IlEMS VERIFIED BY REVIEW 0F STORES REQUEST (SR)
AND PHYSICAL INSPECTION (25,862 ITEMS) s/
%/ N/ %/
sf PHYSICAL I.D. SR ONLY PHYSICAL I.D. NO PHYSICAL AND SR (15%) ONLY I.D. AND N0 SR (82%) (2%) (1%)
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PHYSICAL I.D. AND SR PRESENT (21,164 ITEMS) 99% --
THE STORES REQUEST AND PHYSICAL I.D. AGREE, ESTABLISHING POSITIVE TRACEABILITY.
1% THE STORES REQUEST AND PHYSICAL I.D. DO NOT AGREE RESULTING IN POSSIBLE NONCONFORMANCES.
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SR ONLY (AS REQUIRED BY THE PHILLIPS, GETSCH0W COMPANY PROGRAM)
(3,998 ITEMS) 3.643 --
CODE ACCEPTABLE ITEMS 3.197 --
THE ASME CODE DOES NOT REQUIRE UNIQUE TRACEABILITY AND THE ITEM HAS AN ACCEPTABLE SR WITH A TRACEABLE NUMBER.
446 --
THE ASME CODE REQUIRES UNIQUE TRACEABILITY AND THE ITEM HAS AN ACCEPTABLE SR WITH A TRACEABLE NUMBER.
355 --
POSSIBLE NONCONFORMANCES ADDITIONALLY:
DIGITAL THICKNESS MEASUREMENTS HAVE BEEN PERFORMED ON ACCESSIBLE ITEMS TO CONFIRM THE SPECIFIED SCHEDULE OR POUNDAGE WAS INSTALLED.
- d. .
PHYSICAL I.D. ONLY (581 ITEMS)
SIl --
CODE ACCEPTABLE ITEMS 228 --
MANUFACTURER'S MILL MARKING EXISTS la5 --
THE ASME CODE DOES NOT REQUIRE UNIQUE TRACEABILITY AND THE PHYSICAL I.D. INDICATES A TRACEABLE NUMBER.
108 --
THE ASME CODE REQUIRES UNIQUE TRACEABILITY AND THE PHYSICAL I.D. INDICATES A TRACEABLE NUMBER.
_50 --
POSSIBLE NONCONFORMANCES l
- sc NO PHYSICAL I.D. OR SR j (119 ITEMS)
NCR'S HAVE BEEN WRITTEN ON ALL ITEMS:
SQ --
ITEMS ALREADY DISPOSITIONED AS CUTOUTS.
'S --
ITEMS UNDER REVIEW TO DETERMINE IF CODE COMPLIANCE CAN BE ACHIEVED.
SUMMARY
THE 100% VERIFICATION EFFORT CONFIRMS THE ORIGINAL PHILLIPS, GETSCHOW COMPANY SAMPLE PROGRAM.
THE CORRELATION BETWEEN THE SR AND PHYSICAL I.D. IS 99%. THIS CORRELATION, BASED ON AN AFTER THE FACT LOOK, IS EXCEPTIONALLY HIGH.
AT A MINIMUM, WE CONCLUDE THAT 97% OF THE MATERIAL MET THE ASME MATERIAL TRACEABILITY REQUIREMENTS.
NCR'S WILL BE DISPOSITIONED ASSURING ASME CODE COMPLIANCE.
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IV. MTV PROGRAM FROM ASME CODE PERSPECTIVE PRESENTED BY ED HEMZY CONSTRUCTION MANAGER AND ASME CODE PERSON FOR COMMONWEALTH EDIS0N COMPANY
ASME CODE /MTV PROGRAM CORRELATION ASME SECTION III MATERIAL PHILLIPS, GETSCHOW COMPANY --
SECTION III MATERIALS TRACEABILITY AUTHORIZED NUCLEAR INSPECTION COMMONWEALTH EDIS0N COMPANY ASME CODE COMMITMENT MTV VS. CURRENT TRACEABILITY NONCONFORMANCES AND ASME POSITION STATEMENT
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i ASME CODE /MTV PROGRAM CORRELATION CONCERNS INVOLVING MATERIAL CONTROL FOR SECTION III CONSTRUCTION IS NOT UNIQUE TO THE BRAIDWOOD SITE. THE SUBJECT OF ASME SECTION III MATERIAL INVOLVING DOCUMENTATION AND TRACEABILITY HAS BEEN DEBATED AND DISCUSSED AT LENGTH IN COMMITTEE MEETINGS, OVER COMMITTEE ACTIONS AND MOST CERTAINLY BY COMMITTEE PERSONNEL OUTSIDE OF COMMITTEE ACTIVITIES. THE BOTTOM LINE, HOWEVER, IS THAT THERE IS REASONABLE AGREEMENT THAT CODE RULES SUPPORT THE IDEA THAT TRACEABILITY TO THE POINT WHERE MATERIAL IS CONSUMED OR INSTALLED IN SYSTEMS OR COMPONENTS SATISFIES ASME SECTION III CODE RULES (NX-4122).
THE QUESTION OF THE PHILLIPS, GETSCHOW STORES REQUEST SYSTEM FOR MAINTAINING TRACEABILITY DURING INSTALLATION ACTIVITIES AT THE BRAIDWOOD SITE WAS REVIEWED AT LENGTH AT A MEETING IN EARLY 1984 WITH NRC, AIA. SARGENT AND LUNDY AND COMMONWEALTH COMPANY PERSONNEL. AT THIS MEETING, CODE KNOWLEDGEABLE PERSONNEL OF ALL PARTIES INVOLVED REVIEWED THE SYSTEM IN DEPTH AND CONCLUDED THAT IT WAS A VIABLE SYSTEM AND THAT THE PHILLIPS, GETSCHOW PROCEDURES INCLUDED THE NECESSARY STEPS TO MEET THE ASME SECTION III CODE RULES. FURTHERMORE, THE PHILLIPS, GETSCHOW BRAIDWOOD SITE QUALITY ASSURANCE PROGRAM HAS BEEN SURVEYED BY ASME ON THREE OCCASIONS AND IT HAS BEEN JUDGED ACCEPTABLE FROM BOTH PROGRAMMATIC AND IMPLEMENTATION ASPECTS. ASME CERTIFICATES WERE ISSUED IN ALL CASES. I WAS PERSONALLY INVOLVED IN MEETINGS AND DISCUSSIONS OF THE ;
PHILLIPS, GETSCHOW STORES REQUEST SYSTEM USED AT BRAIDWOOD AND I AGREE WITH THE CONCLUSIONS THAT IT WAS AN ACCEPTABLE PROGRAM. l 1
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IN ADDITION TO SCRUTINY BY ASME SURVEY TEAMS, THE PHILLIPS, GETSCHOW BRAIDWOOD SITE ACTIVITIES HAVE BEEN UNDER CONTINUOUS SURVEILLANCE BY AUTHORIZED NUCLEAR INSPECTORS FOR CODE COMPLIANCE. IT HAS ALWAYS BEEN MY CONSIDERED OPINION THAT THE THIRD PARTY INSPECTION IS THE STRENGTH AND BACKBONE OF THE ASME BOILER AND PRESSURE VESSEL CODE FOR ASSURING COMPLIANCE WITH CODE RULES.
FURTHER.TO THE POINT OF ADHERENCE TO THE REQUIREMENTS OF ASME CODE CONSTRUCTION, IT IS FACT THAT COMMONWEALTH EDISON COMPANY HAS HAD ASME NUCLEAR ACCREDITATION FOR OVERALL CODE RESPONSIBILITY OF ITS NUCLEAR STATION CONSTRUCTION SINCE EARLY 1975. TOP MANAGEMENT HAS ALWAYS MAINTAINED A COMMITMENT TO SUPPORT THE ASME BOILER AND PRESSURE VESSEL CODE AND I HAVE EXPERIENCED THIS COMMITMENT FROM A CLOSE VANTAGE POINT.
THE CURRENT BRAIDWOOD MTV PROGRAM FOR 100% REVIEW OF DOCUMENTED RECORDS IS SUFFICIENTLY LONG AFTER WHEN THE WORK WAS PERFORMED TO RENDER POSITIVE CONCLUSIONS ABOUT LOST MATERIAL TRACEABILITY 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. IN THE MANY MONTHS -- IN SOME CASES YEARS --
SINCE INSTALLATION OF MANY ITEMS, IT IS INEVITABLE THAT SOME OF THE MARKINGS APPEAR TO HAVE BEEN DISTORTED OR LOST BECAUSE OF SUBSEQUENT INSTALLATION ACTIVITIES. THIS DOES NOT, IN MY OPINION, RENDER SUPPORT TO ANY CONTENTIONS OR CONCERNS THAT NON-COMPLIANCE TO CODE CONSTRUCTION EXISTS. THE RE-REVIEWS OF THE RECORDS STRONGLY SUPPORT AND HAVE SHOWN WITH LITTLE DOUBT.IN MY MIND THAT THE PHILLIPS, GETSCHOW COMPANY STORES REQUEST SYSTEM ASSURED ADEQUATE TRACEABILITY TO THE POINT OF INSTALLATION.
l WE MUST REALIZE THAT THE 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 SECTION III NUCLEAR PLANT CONSTRUCTION. PERSONNEL REPRESENTED NRC, JURISDICTIONS, ARCHITECT / ENGINEERS, MANUFACTURERS, INSTALLERS, FABRICATORS, AND OWNERS. I ATTENDED THAT MEETING AND THERE WAS STRONG CONCERN THAT SPECIFIC SITE PROBLEMS ARE BLOWN OUT OF CONTEXT.
AT THAT MEETING IT WAS GENERALLY 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 AND PUBLISHED IN THE SEPTEMBER, 1984 EDITION OF MECHANICAL ENGINEER. 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, PROCEDURE THAT RENDERS AN ITEM OR ACTIVITY UNACCEPTABLE OR INDETERMINATE". THIS DEFINITION OF NONCONFORMANCE CAN CONCEIVABLY ENCOhiPASS A WIDE RANGE OF POSSIBII . TIES, BOTH IN VARIETY AND LEVEL OF SIGNIFICANCE TO SAFETY AND ADEQUACY OF THE EQUIPMENT. 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 T11E RESPONSIBLE PARTIES AGREE ON THE PLAN OF ACTION TO ENSURE THAT THE EQUIPMENT MEETS THE CODE."
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j
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l THE ASME POLICY STATEMENT HAS LED TO RECOGNITION OF WHAT MIGHT BEST BE DESCRIBED AS THE MULTIPLE PARTY AGREEMENT OR MPA. IT IS MY CONSIDERED OPINION THAT THE MATERIAL TRACEABILITY VERIFICATION (MTV) EFFORT AT BRAIDWOOD SUPPORTS THE CONTENTION THAT THE PHILLIPS, GETSCHOW STORES REQUEST PROCEDURE ASSURED TRACEABILITY TO THE POINT OF INSTALLATION AND MET THE INTENT OF ASME SECTION III CODE RULES. WHERE SOME QUESTIONS MAY EXIST FOR SPECIFIC CASES, I BELIEVE THE CONCEPT OF MPA CAN BE'USED AS A FINAL STEP TO SATISFY ALL INVOLVED PARTIES.
N
.j" 4
a V.
SUMMARY
PRESENTED BY MIKE WALLACE
. PROJECT MANAGER
..)
{'.
O STEPS TO ASSURE CODE COMPLIANCE DISPOSITION BY PHILLIPS, GETSCH0W COMPANY WITH CONCURRENCE OF THE AUTHORIZED NUCLEAR INSPECTION AGENCY.
ADDITIONAL DISPOSITIONS APPROVED BY SARGENT AND LUNDY AND COMMONWEALTH EDIS0N COMPANY WITH CONCURRENCE OF PHILLIPS, GETSCH0W COMPANY AND THE AUTHORIZED NUCLEAR INSPECTION AGENCY.
A MEETING IS PROPOSED FOR JUNE 13 OR JUNE 14, 1985 AT BRAIDWOOD SITE WITH REPRESENTATIVES OF JURISDICTIONAL AUTHORITIES TO DISCUSS IF A MULTI-PARTY AGREEMENT IS NECESSARY.
NATIONAL BOARD OF B0ILER PRESSURE VESSEL INSPECTORS ARE PRESENTLY MONITORING ASME CODE CONSTRUCTION.
OUR G0AL IS TO ASSURE ASME CODE COMPLIANCE HAS BEEN MET.
A
2 C2mm:nwacith Edison
- + s one First Nabonal Plata Chicago.1:hnois Iccress Reply to Post Othee Box 767 k Chicago. Ilknots 60690 July-3, 1985 Mr. James G. Keppler Regional Administrator U. S. Nuclear Regulatory Commission l Region III 799 Roosevelt Road Glen Ellyn, IL 60137 SU5 JECT: Material Traceability Verification Program - Corresponcence from Ill. State Fire Marshal's Of fice.
Braidwood Station Units 1 and 2 NRC Docket Nos. 50-456/457
Dear Mr. Keppler:
On June 25, 1985, Tom Maiman and Mike wallace, and others of Commonwealth Edison Company met with you and members of the your staff to present and oiscuss the Material Traceability Verification (MTV) program. As a part of that presentation, we indicated that the Division of Boiler and Pressure Vessel Safety of the Illinois State Fire Marshal's Office has been involveo in a review of the MTV
' Program. Specifically that group, along with the Illinois Department of Nuclear $afety, was present at meetings helo in Springfield on May 31, 1985 ano at Braidwood on June 17, 1985. In the course of those meetings, the State agencies haa opportunities to discuss the MTV Program with Commonwealth Edison Company personnel, the ASME Authorized Inspection Agency, and the ASME National Board.
Commonwealth Edison Company received the attached letter from the Division of Boiler and Pressure Vessel Safety of the Illinois State Fire Marshal's Office. Knowing of the interest that the NRC has.on this topic, this letter is being forwarded to you.
Please address any questions that you or your staff may have concerning this matter to this office.
Very truly yours, kM~
A. D. losi Nuclear Licensing Administrator cc: NRC Resident I'nspector - Braidwood Director of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 0331K
0 ' Office of the Illinois
, State Fire Marshal DIVISION OF BOILER AND PRESSURE VESSEL SAFETY l i l
i June 21, 1985 l
l l
Michael J. Wallace Project Manager Commonwealth Edison Company l
Braidwood Nuclear Power Station l Rt. 1, Box 81 l
[ Braceville, Illinois 60407 '
Dear Mr. Wallace:
The purpose of this letter is to extend to you my
}
appreciation for your keeping this office advised of the results of your Material Traceability Verification Program (MTV). As a result of our meeting on June 17, 1985, I am satisfied that the corrective action program of 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.
Again, I would like to reiterate my position which I stated at the June 17, 1985 meeting; all decisions and acceptances of CECO's corrective action programs l will be based on the advise and counsel of the National
} Board of Boiler and Pressure Vessel Inspectors' audit l team presently on the Braidwood site.
ary truly yours, .[1 l
( --- - ..!! ,
Duane R. Gallup
[ JL .
JUi271985 i...,,'-- , - - .
Supt. of Boiler & Pressure Vessel Safety
-l%dM1]
DRG: lab cc: Mike Parker, Department of Nuclear Safety Harold L. Schmeilski, State Fire Marshal Thomas W. Ortciger, Deputy Director 3150 Executive Park Drive, Springfield, Illinois 62706
- 217/782-2696
Commonw:cith Edison On2 First N' tion:1 Plaza. Chicago. Ilhnois Address Rep'y to Post Office Box 767 Chicago. tilinois 60690 9
July 8, 1985 Mr. James G. Keppler Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
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, i
l L. O. DelGeorge Assistant Vice-President l
l LOD /dak l
cc: NRC Resident Inspector - Braidwood Director of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l
l (1643d) l l
l
a y ATTACHMENT 1 SUPMARY OF COMMENTS MADE BY CODMONWEALTH 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.
COMMONWEALTH 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.
t MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM In responding to the NRC's concern on this issue, Commonwealth Edison Company implemented the Material Traceability Verification Program, a 100% review of system implementation.
ACTIONS SUBSEOUENT 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.
a t
Commonwealth Edison Company, by it's own initiative, requested an opportunity to discuss.the MTV Program and it's results with the ASME Local jurisdiction -- the Division of Boiler and 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 Beard 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.
(1608d)
. . - _ = - - _ _.- - - _ - - - _ - - - - - - - -- - ,_.
ATTACFJGIT 2 t
COMMONWEALTH EDIS0N COMPANY BRAIDWOOD STATION MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM JUNE 25, 1985 NRC REGION III GLEN ELLYN, ILLINOIS i
l l
.D MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM t
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 (1586D)
f BIOGRAPHICAL DATA 0F PRESENTERS l
J
l BIOGRAPHICAL DATA l
Michael J. Wallace j Assistant Manager of Projects (3 Years) i Project Manager ---
Braidwood Nuclear Power Station (2 Years) i Education B.S. Electrical Engineering Marquette University MBA (Specialization: Finance) University of Chicago ,
I Nuclear Power School United States Navy Experience Navy Nuclear Program 5 years U.S. Navy (Qualified Engineer Officer)
Quality Assurance Engineer 3 years Clinch Itiver 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
i l
Registered Professional Engineer -
Illinois Member, American Nuclear Society l
l Member, Industry Review Group for Construction Project Evaluation l
Division, Institute of Nuclear Power Operations (INPO)
(1588d) i i --- ,- - . ~ . ,_ _ , . . _ _ . . _ _ , _ , _ _ _ __ _ _ _ _ _ _ _ _ __ _
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 /guality Assurance)
Station Construction repartment 16 years e - nwealth Edison Quality Assurance company Engineering Staff For the past 12 years I have been deeply involved with ASME Boiler and Pressure Vessel Comunittee Activities including:
sub-coanaittee on Nuclear Accreditation
- Sub-Comunittee on Nuclear Power Main comunittee Board of Nuclear Codes and Standards
- Board of Accreditation S
(1588d) b
~ . . , . _ , _ _ _ , _ . - . . . , . . , _ _ , _ _ , , , , , . . _ . . _ _ , . _ _ _ . . _ . . - . . _ _ - . . . . . - . . - ,,
'l I
l 1
BIOGRAPHICAL DATA e
Daniel L. Shamblin Project Construction Superintendent Braidwood Nuclear Power Station (1 Year) ,
i Education B.S. Civil' Engineering Michigan Techological University NBA 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 P oject Field Engineering Manager 1 year Braidwood Project Registered Professional Engineer -
Illinois 9
(1588d)
' BIOGRAPHICAL DATA Daniel J. Skoza Special Projects Supervisor Project Field Engineering Braidwood Nuclear Power Station (1 Year)
Education 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)
, --.-..v_. _ . . _ _ - ..-__-....__-___m..._ _ - . _ _ . _ . . - _ _ _ . _ _ , _ . . _ _ , , , ,m. _ _ _ - - - , - . , ,.- , - .
r:
I l
l 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 PROFESSIONAL AFFILIAT M Member of ASME Radweste Committee 9 years (1975-1983)
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 6
(1588d)
WB11AM S. GIBBONS, PcE.
SUMMARY
Mr. Gibbons has worked in manufacturing and the power industry since 1951. His domestic and overseas experience includes foun&y 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.
i He has been involved in engineering review, licensing programs, and training. Since 1970, 2 Mr. Cibbons 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.
EDUCA'110N:
M.B.A., University of California, Berkeley 1958 B.S., Metallurgical Engineering, University of California, Berkeley,1952 PROFESSIONAL BACKGROUND:
American Society of Mechanical Engineers o Member, Subgroup on General Requirements (SC IID o Co-Chairman, Working Group on Quality Assurance and Stamping (SC IID o Member, Subcommittee on Nuclear Accreditation o Task Group on Material Manufacturers and Suppliers (SC HD o ASME-COURSE DIRECTOR, Quality Assurance ANSI /ASME NQA O Committee on Nuclear Quality Assuranee AMEE3CAN SOCIrrY FOR QUAIETY CONTROL Pest Member o ANSI B3L1, Power Piping o ANSI B31.7, Nuclear Power Piping o ASME Subgroup on Materials (SC HD o ASME Subgroup on Fabrication and Examination (SC DD o ASTM Materials Committees 1
........ . . . . . . . . . ~ . , . . . . , . , , . . s. . w . . ... . . , . . . .. . . . , . . . . . . .%
,0.........,,,.. . ....s...
J
. WILLIAM 8. GIBBONS, P.E. Page Two PROFESSIONAL REGBTRA'I10N:
Metallurgical Engineer (State of California)
Quality Engineer (State of California)
Qualified Lead Auditor, ANSI-N-45.2.23 EXPERIENCE:
1981-present GIBBONS & AMOCIATES Los Gatos, California President Currently Consultig with utilities, manufacturers and architect-engineers 1980-1981 NUCIJAE TECHNOLOGY, INCORPORATED San Jose, California Chief Consultant, Quality 1969-1980 BBCHTEL POWER CORPORA 110N 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 SYLVANIA (0110 M<vntain View, California Contracts Administration Analyst l
1956-1958 RIDGE FOUNDRY COMPANY San Leandro, California Metallegist 19544954 U.S. ARMY l
Fort Sill, Oklahoma Instructor 1952-1954 WESTINGBOUSE ELECYRIC OORPORAT10N Pittsburgh, Pennsylvania Manufacturing Engineer f
l 1
i i
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F-S 9
SECTION I INTRODUCTION PRESENTED BY M. J. WALLACE 6
k...
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM OVERVIEW NRC CONCERN ADEQUACY OF CONTROLS FOR ASSURING THE INSTALLATION OF CORRECT ASME CODE PIPING MATERIALS.
COMMONWEALTH EDISON COMPANY RESPONSE
- SAMPLING REVIEW OF SYSTEM IMPLEMENTATION (AUGUST, 1983 -- FEBRUARY, 1984)
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) e
I MATERIAL TRACFABILITY VERIFICATION (MTV) PROGEM MTV PROGRAM
- A UNIQUE, 30 MANYEAR, 100% PIPING WALKDOWN EFFORT VERIFIED MATERIAL TRACEABILITY THROUGH COMPARISON OF DOCUMENTATION WITH FIELD MARKINGS ON PIPE OVERAll OBJECTIVE ASSURE THAT BRAIDWOOD ?! PING INSTALLATION IS FULLY IN COMPLIANCE WITH THE ASME CODE O
P C__ _ _ _ _ _ _ _ . _ . _ _ _ _ . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ . . _ _ . . _ _ _ _ . _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ . _ . . . . _ _ _ _ _ . . _ _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . . _ _ _ _ _ _
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM
SUMMARY
OF CONCLUSIONS THE MATERIAL TRACEABILITY SYSTEM (PROCEDURES AND PRACTICES), ESTABLISHED BY PHILLIPS, GETSCHOW 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)
F-6 SECTION 11 .
TRkfkakfLbhhhkkEM AND kkkhkbbkkk PRESENTED BY D. L. SHAMBLIN
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM TOPICS
- PHILLIPS, GETSCHOW COMPANY MATERIAL TRACEABILITY SYSTEM NRC CONCERNS AND ISSUES -- JULY, 1983 COMMONWEALTH EDIS0N COMPANY REFPONSES MTV PROGRAM PURPOSE AND DESCRIPTION MTV PROGRAM IMPLEMENTATION I
l l
i MATERIAL STORES REQUEST SYSTEM STORES REQUEST DENOTES:
~
- MATERIAL TYPE & GRADE
- CLASS SIZE , SCHEDULE i
- QUANTITY
- UNIQUE LOCATION
, -HEAT / SERIAL NUMBER h
\
l YELLOW COPY H
STORES EOUEST PINK COPY- ENGR.
FILE OFFICE O.C.
BLUE COPY WHITE COPY: VERIFICATION OF CORRECT MATERIAL TO FIELD TRAVELER WITHDRAWAL ASME W/ASME PMG. --* N-5 MATERIAL 7 DATA REPORT y F FIELD O.C.
[ ASME PIPE i U VERIFICATON OF I D C H T.
- J J 9 CORRECT MATERIAy L _JN_STALkALO_N _;
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM NRC CONCERNS AND ISSUES --
JULY. 1983 A DOCUMFNTED 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 i
e
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM COMMONWEALTH EDISON COMPANY RESPONSE 4
- PHILLIPS, GETSCHOW COMPANY WAS DIRECTED TO IMPLEMENT PROCEDURAL CHANGES REQUIRING QUALITY CONTROL INSPECTORS IQ BETTER DOCUMENT THEIR MATERIAL VERIFICATION INSPECTIONS DURING INSTALLATION ACTIVITIES (I.E. AT THE POINT OF INSTALLATION)
- PHILLIPS, GETSCH0W COMPANY WAS DIRECTED TO UNDERTAKE A SAMPLE BASED MATERIAL TRACEABILITY VERIFICATION PROGRAM 10 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 RFOUEST 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.
NRC REQUESTED ADDITIONAL ASSURANCE 100% REVIEW 0F INSTALLED ASME PIPING AND ATTACHMENTS
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM MTV PROGRAM PURPOSE AND DESCRIPTION PURPOSE PROVIDE ADDED ASSURANCE THAT CORRECT PIPING MATERIALS WERE INSTALLED ,
CONFIRM THE VALIDITY OF THE STORES REQUEST DOCUMENTATION 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 SORTING
SECTION 111 RESULTS yiUMMARY MT PRO AM 4
PRESENTED BY D. J. SK0ZA 6
E MATERIAL Sf0RES REQUEST SYSTEM STORES REQUEST DENOTES :
. -MATERIAL TYPE & GRADE
- CLASS , SIZE , SCHEDULE
-OUANTITY
-UNIQUE LOCATION
_ -HEAT / SERIAL NUMBER 6
\
YELLOW COPY a f STORES EOUEST IENGR.
=
] PINK COPY _l FILE
~
OFF CE O.C.
BLUE COP ( W lTE CW: VERIFCATION OF CORRECT MATERIAL ,
TO FIELD TRAVELER WITHDRAWAL ASME W/ASME PKG.
- N-5 MATERIAL CATA REPORT 9 I FIELD Q.C. 7 h
( ASME PIPE i O VERIFCATION OF l D tm HT.# ~
) J CORRECT MATERIAL' 'e INSTALLATION _j -
MTV OC VERFCATION OF CORRECT MATERIAL INSTALLATION BY: VERIFICATION OF FIELD -
MATERIAL MARKINGS t
VERIFICATION OF STORES -
REQUEST DOCUMENTATION
MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM MTV PROGRAM IMPLEMENTATION
- 57 PHILLIPS, GETSCHOW COMPANY QUALITY CONTROL PERSONNEL RECEIVED SPECIALIZED TRAINING AND CERTIFICATION IN MATERIAL INSPECTIONS AND EVALUATIONS
- 44 PHILLIPS, GETSCHOW COMPANY QUALITY CONTROL FIELD PERSONNEL PERFORMED A 1901 INSPECTION OF APPR0XIMATELY 25.000 INSTALLED (ACCESSIBLE) CODE ITEMS IN A PERIOD OF 14 MONTHS
- 13 PHILLIPS, GETSCH0W COMPANY QUALITY CONTROL 0FFICE PERSONNEL REVIEWED OVER 60.000 QUALITY CONTROL DOCUMENTS
- TO DATE APPR0XIMATELY 61,000 MANHOURS HAVE BEEN EXPENDED BY PHILLIPS, GETSCHOW COMPANY TO IMPLEMENT THIS PROGRAM.(43.000 FIELD: 18.000 0FFICE)
NUMEROUS AUDITS AND SURVEILLANCES COMPLETED BY INDEPENDENT PARTIES DURING PROGRAM IMPIFMENTATION (1587D) b
MATERIAL STORES REQUEST SYSTEM STORES REQUEST DENOTES:
- MATERIAL TYPE & GRADE l
- CL AS S , SIZE , SC HEDULE I
-QUANTITY
- - UNIQUE LOCATION
, -HEAT / SERIAL NUMBER
\
YELLOW COPY n/ '
STORES REQUEST PINK COPY- ENGR.
E. FILE OFFCE O.C.
WHITE COPY- VERIFCATION OF -
BLUE COPr CORRECT MATERIAL TO FIELD RAVELER WITHDRAWAL ASME W/ASME PKG. -* N-5 MATERIAL MTA REPORT y F FELD O.C. 1 a
( ASME PIPE 1 0 .
VERIFCATION OF i D C3 HT.# 1 1 mCORRECT MATERIAL'
~
L INSTALLATION _,j 4
v TV OC'ERFCATION OF hST T N *
- &E * #
~
4 TORES REQUEST ACCEPTABLE
-* FIELD MARKINGS ACCEPTABLE -
(
-e NCR DISPOSITION -
r
MATERIAL TRACEABILITY VERIFICATION (MTV)
ITEMS VERIFIED BY PHYSICAL INSPECTION AND/0R REVIEW 0F STORES REQUEST (SR) DOCUMENTATION (25,853 ITEMS)
- qf q>
PHYSICAL I.D. SR CNLY PHYSICAL I.D. NO PHYSICAL AND SR ONLY I.D. AND NO SR (81.9%) (15.5%) (2.2%) (0.4%)
O
, , - . . . . - - - , - -- , - , , , , -- -+ r
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.
.._,,--g .
SR ONLY (As REQUIRED BY THE PHILLIPS, GETSCHOW COMPANY PROGRAM)
(4,006 ITEMS) 3980 --
TRACEABLE ASME CODE ITEMS 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 l
PHYSICAL I.D. ONLY (579 ITEMS) i l
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 123 --
THE PHYSICAL I.D. INDICATES A TRACEABLE NUMBER WHEN THE ASME CODE REQUIRES HEAT TRACEABILITY 22 --
ITEMS DISPOSITIONED FOR REPLACEMENT BECAUSE TRACEABILITY CANNOT BE ESTABLISHED.
MORE THAN 99% OF THE TIME, THE PHYSICAL I.D. NUMBERS TRANSFERRED BY PGC0 HAVE BEEN DETERMINED TO BE CORRECT.
.._,y ,, - - - - - , - - - - - , - - . , - - - - - - - -
NO PHYSICAL I.D. OR SR (104 ITEMS) l 73 --
TRACEABLE ASME CODE ITEMS 64 --
ITEMS DISPOSITIONED AS ACCEPTABLE (THE ASME CODE DOES NOT REQUIRE HEAT TRACEABILITY) 9 --
ITEMS DISPOSITIONED AS ACCEPTABLE (THE ASME CODE REQUIRED HEAT TRACEABILITY) 31 --
ITEMS DISPOSITIONED FOR REPLACEMENT BECAUSE TRACEABILITY CANNOT BE ESTABLISHED.
NCR DISPOSITION OF 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 i 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.
. CLASS 1 AND 2 PIPING AND FITTINGS $ 3/4" O PER NA-3767.4(B)
- CLASS 2 AND 3 INTEGRAL ATTACHMENTS PER NC/ND-2130 AND 2190
' CLASS 3. CONSTRUCTION PER ND-2150
1 l
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SUMMARY
i *THE ACCEPTABILITY OF THE PGC0 SR SYSTEM HAS BEEN CONFIRMED.
- PHYSICAL IDENTIFICATION OR PGC0 DOCUMENTATION EXISTS TO ESTABLISH MATERIAL TRACEABILITY.
e0F 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.
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- NO DESIGN SIGNIFICANT DISCREPANCIES EXISTED.
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- 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.
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' SECTION IV l
MTV PfqGR P hShITI k PRESENTED BY E. J. HEMZY i
ASME CODE /MTV PROGRAM CORRELATION CONCERNS INVOLVING MATERIAL CONTROL FOR ASME SECTION III l CONSTRUCTION IS NOT UNIQUE TO THE BRAIDWOOD SITE. THE SUBJECT OF ASME SECTION III MATERIAL INVOLVING DOCUMENTATION AND TRACEABILITY HAS BEEN DEBATED AND DISCUSSED AT LENGTH IN ASME COMMITTEE MEETINGS, OVER COMMITTEE ACTIONS AND MOST CERTAINLY BY COMMITTEE PERSONNEL OUTSIDE OF ASME COMMITTEE ACTIVITIES.
THE BOTTOM LINE, HOWEVER. IS THAT ASME CODE RULES SUPPORT THE IDEA THAT TRACEABILITY TO THE POINT WHERE MATERIAL IS CONSUMED OR INSTALLED IN SYSTEMS OR COMPONENTS DURING INSTALLATION SATISFIES ASME SECTION III CODE RULES. ,
i THE QUESTION OF THE PHILLIPS, GETSCHOW STORES REQUEST PROCEDURE FOR MAINTAINING TRACEABILITY DURING INSTALLATION ,
ACTIVITIES AT THE BRAIDNOOD SITE WAS REVIEWED AT LENGTH AT A
- MEETING IN EARLY 1984 WITH NRC, AUTHORIZED INSPECTION AGENCY, SARGENT AND LUNDY AND COMMONNEALTH EDISON COMPANY PERSONNEL.
AT THIS MEETING, CODE KNOWLEDGEABLE PERSONNEL OF THE PARTIES INVOLVED REVIEWED THE SYSTEM IN DEPTH AND CONCLUDED THAT IT WAS A VIABLE SYSTEM AND THAT THE PHILLIPS, GETSCHOW PROCEDURES INCLUDED THE MINIMUM NECESSARY STEPS TO MEET THE ASME SECTION III CODE RULES. FURTHERMORE THE PHILLIPS, GETSCHOW BRAIDWOOD i SITE. QUALITY ASSURANCE PROGRAM, WHICH INCLUDED THE STORES REQUEST PROCEDURES, HAS BEEN SURVEYED BY ASME ON THREE OCCASIONS AND HAS BEEN JUDGED ACCEPTABLE FROM BOTH PROGRAMMATIC AND IMPLEMENTATION ASPECTS FOR A*EETING ASME CODE RULES. ASME CERTIFICATES OF AUTHORIZATION WERE ISSUED IN ALL C5SES.
FURTHERMORE, I HAVE BEEN PERSONALLY INVOLVED IN MEETINGS AND DISCUSSIONS OF THE PHILLIPS, GETSCHOW STORES REQUEST SYSTEM USED AT BRAIDWOOD AND I AGREE THAT IT WAS AND CONTINUES TO BE AN ACCEPTABLE PROGRAM AND CONFORMS TO ASME CODE RULES IN EFFECT FOR THE BRAIDWOOD SITE CONSTRUCTION.
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! IN ADDITION TO SCRUTINY BY ASME SURVEY TEAMS THE PHILLIPS. GETSCHON BRAIDNOOD SITE PIPING INSTALLATION ACTIVITIES HAVE BEEN UNDER CONTINUOUS SURVEILLANCE BY
! AUTHORIZED NUCLEAR INSPECTORS FOR ASME CODE COMPLIANCE. IT HAS i ALNAYS BEEN MY CONSIDERED OPINION THAT THE INDEPENDENT THIRD l 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 l LT.E2lLQ 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 POWER 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 BRAIDNOOD MTV PROGRAM FOR 1Q91 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 SUMMER ADDENDA RULES WHICH ARE IN EFFECT FOR THE BRAIDWOOD CONSTRUCTION. IN THE TIME SPAN SINCE ACTUAL INSTALLATION OF MANY ITENS. 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.
THE ASME CODE RULES DO NOT ADDRESS THE NEED FOR MAINTAINING MATERIAL MARKING BEYOND THE TINE OF INSTALLATION. THE RE-REVIEWS OF THE RECORDS STRONGLY SUPPORT AND HAVE SHOWN, WITH LITTLE DOUBT IN MY MIND. THAT THE PHILLIPS, GETSCHOW COMPANY STORES 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
'" HAT 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 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 NAS DEVELOPED AS A RESULT OF THAT MEETING AND PUBLISHED IN THE SEPTEMBER, 1984 EDITION OF MECHANICAL i
ENGINEER, THE OFFICIAL PUBLICATION OF ASME. I WOULD LIKE TO f QUOTE ONE VERY SIGNIFICANT PARAGRAPH FROM THAT ARTICLE.
t "NONCONFORMANCE IS DEFINED IN NCA-9000 OF SECTION III, l GENERAL REQUIREMENTS, AS A DEFICIENCY IN CHARACTERISTIC, DOCUMENTATION, OR PROCEDURE THAT RENDERS AN } TEM OR 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.
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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 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.
(1592d)
I MATERIAL TRACEABILITY VERIFICATION (MTV) PROGRAM j 1
ASMF CODF/BRAIDWOOD MTV PROGRAM CORRELATION l
ASME SECTION III RULES ARE SATISFIED BY MATERIAL TRACEABILITY TO POINT OF CONSUMPTION OR INSTALLATION l
- PHILLIPS, GETSCHOW COMPANY STORES REQUEST PROCEDURE MEETS ASME CODE RULES 1
AUTHORIZED NUCLEAR INSPECTION IS INDEPENDENT OVERVIEW AND VERIFICATION OF CONFORMANCE TO CODE RULES COMMONWEALTH EDIS0N COMPANY MANAGEMENT IS COMMITTED TO ASME CODE COMPLIANCE
- BRAIDWOOD MTV PROGRAM VERIFIES THAT PHILLIPS, GETSCHOW 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 9
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SECTION V MTV
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PRESENTED BY T. E. QUAKA i
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OVERVIEW OF THE MTV PROGRAM BY FDISON 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.
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0 REVIEWED ALL MTV RELATED NCR'S GENERATED (0N-G0ING) T0:
ASSURE PROPOSED DISPOSITIONS WERE APPROPRIATE VERIFY.THAT CORRECTIVE ACTIONS ARE PROPERLY COMPLETED (3110A)
INDEPENDENT OVERVIFWS MTV PROGRAM AND ITS IMPLEMENTATION WAS MONITORED / REVIEWED BY 0 EDIS0N 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) e A
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O FXAMPIFS OF 0.A. ITEMS IDENTIFIED t
0 RESOLVE LOG INCONSISTENCIES DUE TO PROCEDURAL CHANGES.
O PROCEDURE REVISION ADDED A FORM AND DETERMINATION OF NEED FOR BACKFIT WAS TO BE PERFORMED.
O ADD COMMENTS ON THE CHECKLISTS TO PROVIDE CLARITY WHEN CORRECTIONS ARE MADE.
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(3110A)
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DyERVIEW BY OTHER GROUPS 0 EDIS0N CORPORATE QUALITY ASSURANCE PERFORMED AN EVALUATION OF THE MTV PROGRAM AND CONCLUDED THAT THE ESTABLISHED PROGRAM 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.
GFNERAL CONCLUSION:
SITE QUALITY ASSURANCE INVOLVEMENT IN CONJUNCTION WITH THE COMMENTS FROM THE OTHER ORGANIZATIONS LEAD TO OUR CONCLUSI0N THAT THE MTV PROGRAM HAS BEEN PROPERLY IMPLEMENTED AND DOCUMENTED.
(3110A)
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e SECTION VI
SUMMARY
PRESENTED BY M. J. WALLACE 1
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MATFRIAL TRACEABILITY VERIFICATION (MTV) PROGRAM l
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SUMMARY
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QMERALL OBJECTIVE 1 1
ASSURE THAT BRAIDWOOD PIPING INSTALLATION IS FULLY IN l COMPLIANCE WITH THE ASME CODE ACTIONS SUBSEQUENT TO MTV PROGRAM IMPL EMENTATION REVIEW BY ASME CODE EXPERTS REVIEW BY ASME NATIONAL BOARD MEETINGS AND DISCUSSIONS WITH ILLINOIS DIVISION OF BOILER INSPECTION, ATTENDED BY ILLIN0IS DEPARTMENT OF NUCLEAR SAFETY CONCLUSIONS THE BRAIDWOOD PIPING INSTALLATION COMPLIES WITH THE ASME CODE
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COMMONWEALTH EDISON'S INTENTION IS TO CONTINUE TO ASSURE COMPLIANCE WITH THE ASME CODE REGARDING RESOLUTION OF ANY PROBLEMS IDENTIFIED AND COMPLETION 1 0F NEW INSTALLATIONS
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