ML20136G515

Final Deficiency Rept 83-07 Re Matl Traceability Verification Program. Matl Traceability Verification at Braidwood, Encl

ML20136G515
Person / Time
Site:	Braidwood
Issue date:	11/12/1985
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
83-07, 83-7, NUDOCS 8511220375
Download: ML20136G515 (73)

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A h Commonwealth Edison 7

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l ' One First National Plaza, Chicago, Illinoia f, ,7 Address Reply to: Post Office Box 767

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. November 12, 1985 Mr.. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Generating Station Units 1 and 2 Material Traceability Verification Program 10 CFR 50.55(e) 83-07 Final Report NRC Docket Nos. 50-456 and 50-457

Dear Mr. Keppler:

On June 25, 1985, Commonwealth Edison personnel met with you and members of your Staff to discuss the results of our Material Traceability Verification (MTV) Program.

The purpose of this letter is to transmit the Report which documents the results of the Program. This transmittal also serves as a final report on the matter communicated to the NRC in 10 CFR 50.55(e) Report 83-07 on the Braidwood docket. The attached Report also provides the results of the testing of materials in connection with the MTV Program agreed upon with your Staff after the June 25, 1985 meeting.

If you have any questions on this Report or the Material Traceability Verification Program, please contact this office.

One signed original and three copies of this letter and the attachments are submitted for your use.

A redistribution of this Report in bound printed form is expected within five (5) working days. That redistribution will include twenty bound copies of this report for your use as well as 5 copies of the Report to both the Office of Nuclear Reactor Regulation and your headquarters office. t Very truly yours, 8511220375 851112 .

PDR ADOCK0500ggg6 s

44 Louis 0. De1 George Assistant Vice-President Attachments gi 4$6 '

cc: Mr.11. R. Denton (NRR) - w/o attachments Mr. J. M. Taylor (I&E) - w/o attachments ((2 7

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MATERIAL TRACEABILITY VERIFICATION AT BRAIDWOOD Table of Contents Section Page I. BACKGROUND I-l II. PROGRAM DESCRIPTION II-l 8

III. PROGRAM RESULTS III-l IV. DISPOSITION OF DISCREPANCIES IV-1 V. . DESIGN SIGNIFICANCE EVALUATION V-1 VI. CONCLUSIONS VI-l 8 APPENDIX A SUPPLEMENTARY REPORT ON MTV PROGRAM BY THE A-1 NATIONAL BOARD OF BOILER AND PRESSURE VESSEL INSPECTORS APPENDIX B CLASS 1 NDE MARKINGS B-1 APPENDIX C DETAILED RESULTS OF DESIGN SIGNIFICANCE EVALUATION C-1

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.e I. BACKGROUND Tne NRC staff conducted inspections at Braidwood Station during the second half of 1983 and January and Feoruary 1984, which were reported in NRC Inspection Report 83-09 on May 7,1984. The NRC Staff deter-mined, among other things, that Phillips-Getschow Company (PGCo), the on-site contractor responsible for the installation of ASME piping materials, did not have a documented inspection program requiring the quality control inspectors to verify at the time of installation that for the piping itens to be installed, the heat numbers on the items matched the heat numbars on the pertinent documents in the data package (i.e., Stores Request). Although not expressly stated in 83-09, it i appears the NRC Staff considered these inspections necessary to satisfy tne requirements in Criterion VIII of the NRC's Quality Assurance Criteria Appendix B to 10 C.F.R. Part 50 and the ASME Code for material control and traceaDility.

It was reported in NRC Inspection Report 83-09 that verification of material traceaoility may have been performed by quality control inspec-tors. Documentation of tnose inspections was not generally availaole because, in the Staff's view, undocumented inspections are not an appropriate means for satisfying tne NRC's Quality Assurance Criteria, and as such cannot be relied upon. Hence, tne NRC Staff concluded that a violation of Criterion X had occurred.

Criterion X requires tne performance of inspections to verify conform-ance with documented procedures, instructions and drawings establisned by the licensee and its contractors for the accomplishment of various activities during the course of nuclear power plant construction.

Apparently the NRC Staff reasoned that criteria VIII and tne ASME Code required these inspections in order to verify piping material traceabi-lity. In Commonwealth Edison's view, the inspections ider tified as

- necessary by the NRC Staff were not required by either the ASME Code or I-1 g -

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Criterion VIII for purposes of verifying material control and traceabi-lity; and, therefore, need not be a part of the procedures or instruc-tions developed by Edison or its contractor, Phillips, Getschow Company.

We believe that inspections as contemplated by Criterion X and as dis-cussed in 83-09 are not required to demonstrate material traceability.

Pnillips, Getschow Company had established a Stores dequest System for achieving the necessary piping material control and traceability required by the ASME Code and Criterion VIII. This system is referred to in Section 5 of tne Phillips, Getschow Company Quality Assurance Manual and it is described in Figure I-l of this report. In summary, piping material was inspected at the time of its receipt at the site.

Tne receipt inspection included verification of the traceability iden-I tification numbers on the material which was traceable to the vendor supplied documentation. When piping material was needed for field installation, a form called a " Stores Request" (Figure I-2) was completed oy a PGCo Field Supervisor and reviewed by PGCo field engi-neering and quality control for completeness. The stores request iden-tified the piping material required for a specific location. Upon review of the stores request, a warehouseman located the prescrioed piping material, recorded the heat numbers or other traceable iden-I tification on tne stores request and presented the material and a copy of the stores request to the requestor. The requestor then transported the material to the installation site. and it was installed. A copy of the stores request was placed in the data package and stored in the QC I

office for future reference. Tnis system, which was in effect at the time the plant materials questioned by the NRC Staff were installed, met the requirements of the ASME Code for material traceability. This conclusion is explained further below.

Tne requirenents applicable to the installation of the piping material in question are specified in the 1974 Edition and Sunener 1975 Addenda of ParagraphsSection III of the ASME Boiler & Pressure Vessel Code.

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NA-4440 and NA-4441 set forth the requirement for piping material  !

control and traceability. These paragraphs state:

NA-4440 IDENTIFICATION AND CONTROL OF MATERIAL AND ITEMS NA-4441 Establishment and Maintenance of Identification and Control Measures Measures shall be established for identification and control of material and items, including partially fabricated ass emblies. These measures shall assure that identification is maintained either on the item or on records traceable to the item throughout manufacture or installation. These measures shall be designed to prevent the use of incorrect or defective items, and items which have not received the required examinations, tests, or inspections.

' Sub-paragraph NA-4441 makes clear that measures for the control of materials shall assure that material traceability is maintained either on the piping item or records traceable to the piping item up through installation of the material. The ASME Code does not require permanent physical identification marked on the item. The ASME Code does not prescribe the means for implementing this requirement. Rather, compliance with this and other ASME Code requirements is determined by the approval of the measures proposed by a company when it seeks accre-I ditation from the ASME Subcommittee on Nuclear Accreditation. In the case of Phillips, Getschow Company, it was accredited by the ASME as a qualified installer of ASME Class 1, 2 and 3 piping material as early as 1971, using a traceability system similar to that employed at Braidwood.

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Prior to certification by the ASME for the Braidwood Project, Phillips, Getschow Company procedures and quality requirements were the subject of a complete accreditation survey by an ASME survey team which is made up of Code-knowledgeable experts. This survey was conducted in August 1978. A second ASME renewal survey was conducted in 1981 to verify con-formance witn ASME requirements. The accreditation included the Stores Request Systen described above. No exceptions were taken by the ASME l

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survey team with respect to the Stores Request System. In addition, the Authorized Nuclear Inspector (ANI) conducts periodic inspections of the Stores Request System as required by Section NA-5000 of the ASME Code.

Any issues raised by these inspections have been resolved to his satis- .

faction in order for the installation of piping material to proceed.

Based on the audits by the ASME survey team, the suDsequent Certifi-cation of Phillips, Getschow Company, and the ANI Inspections, it can only be concluded that the Phillips, Getschow Company Stores Request System met ASME Code requirements for the traceability of safety related piping materials without the need for permanent retention of physical identification markings on the piping.

A special review conducted in March 1984 by ASME Code-knowledgeable experts from Commonwealth Edison Company, Sargent & Lundy Engineers and the Hartford Steam Boiler Inspection & Insurance Co. independently exam-ined the Phillips, Getschow Company Stores Request System to determine whether the program met ASME Code requirements for material control and traceability. They concluded that the Phillips, Getschow Company Stores Request System provided a means for assuring traceability through installation of the piping material, and therefore that system satisfied the requirements of paragraph NA-4441. Finally, since there is no I substantive difference in the language of paragraph NA-4441 and the language of Criterion VIII, it can also be concluded that the Phillips, Getschow Company Stores Request System satisfied Criterion VIII. In addition, the National Board of Boile'r and Pressure Vessel Inspectors performed an assessment of the Stores Request System. As reported in Appendix A, this assessment resulted in the opinion that "there is no basis for believing that PGCo's Quality Assurance program, as described in the Quality Assurance Manual, did not meet the requirements or intent of the 1974, Winter '75 Addenda of the ASME Code,Section III, Para.

NA-4441."

The approach suggested by the NRC Staff in 83-09, namely, material tra-ceability verification by means of a documented QC inspection at the I-4

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time of installation, is also an acceptable means for meeting the Code

- and Criterion VIII. However, it is not the exclusive means of achieving i that result. The ASME accreditation system allows any type of system as

< long as it satisfies the obNctive of the Code, which in 'this case is the proper control and traceability of piping material. In fact, l

Phillips, Getschow Company had supplemented the Stores Request System by providing additional documentation requirements in its QA Manual.

Nevertheless, in order to answer the NRC Staff questions raised by Inspection Report 83-09 and to eliminate the uncertainty which those questions created, Commonwealth Edison directed Phillips, Getschow Company to modify their procedures to require the approach suggested by the NRC Staff, namely, a documented quality control verification of material traceability at the point of material installation. Modifi-cations to the procedures were implemented during 1983, and the change resolved NRC Staff questions with respect to ongoing and future work.

Additionally, in order to provide the NRC with assurance that the Stores Request System provided adequate material traceaoility and that the installed piping was acceptable, Commonwealth Edison directed Phillips, Getschow Company to reverify piping material installed prior to the '

s dates of interest. A sample reverification was initially performed as part of the effort by Commonwealth Edison to be responsive to the questions posed by the NRC Staff. However, the Staff continued to question compliance with the material traceaoility provisions of the ASME code and the NRC's Quality Assurance Criterion VIII. In light of the NRC's continued concerns, Edison performed a 100% reverification of the small bore and large bore piping materials installed prior to September 6,1983 and January 1,1983, respectively. This 100% reveri-fication program called the " Material Traceability Verification Program" (MTV), is the subject of this report.

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RECEIVING INITIATES INSPECTION 5 TORES REQ.

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II. PROGRAM DESCRIPTION The purpose of the MTV Program is two-fold. First, it demonstrates the reliability of the Stores Request System as a means to satisfy the '

material traceability requirements of Section NA-4441 of the ASME Code and verifies the traceability of ASME Class 1, 2 and 3 large and small bore piping and integral attachments for the time periods of interest.

Second, material installation acceptability was verified by checking the traceaoility results against installation specifications for correct material schedule, type, grade, and class.

A. Program Scope As discussed in Chapter I, the MTV program was established to provide 1005 verification of:

1. ASME Section III large bore (nominal pipe diameter 2-1/2" and larger) piping installed prior to January 1,1983; and

2. ASME Section III small bore (nominal pipe diameter 2" and smaller) piping installed prior to September 6,1983.

The total scope of the program involved 25,815 individual items inspected. An item is generally considered to be a single piece (i.e.,

pipe section or fitting), or unmodified spool between field welds. The number of items inspected were 13,941 small bore items,11,382 large

. bore items, and 492 integral attachments.

Not included in the above scope are 514 items of the containment spray system located in the dome of the Unit 2 containment building. These items are inaccessible until the erection of extensive scaffolding is practical. This scaffolding is planned to be erected later in the construction of Unit 2 at which time inspection of this system will be completed. It is not expected that the inspection of these items will

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yield results different from identical items inspected in Unit 1.

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i Therefore, the lact of these results for the Unit 2 containment spray system do not affect the conclusions in this report.

B. Program Procedure and Organization ,

A separate and special procedure, QCP-831, was developed by Phillips, Getschow Company (Figure II-1) to implement the MTV Program. This pro-cedure was reviewed and appioved by Phillips, Getschow Company, the Authorized Nuclear Inspector, Comonwealth Edison Company, and Sargent and Lundy.

Both large bore and small bore trial packages were developed and walked through this procedure. This walk through assured that the procedure met the Program objectives and acted as a " shake-down-run" to assist in final procedure refinements and personnel training.

The Phillips, Getschow Company Project Engineering Group identified the installations that fell within the established scope of the program.

That determination was made by a review of the Phillips, Getschow Company Weld Completion Documentation /Statusing Log, the production installation data package, the Field Change Order Control logs, and/or any other information source available that was beneficial to this I review activity.

After an installation was determined to be within the scope of this program, a Phillips, Getschow Company Material Traceability Verification (MTV) package was assembled for that installation by the Project Engineer. After the MTV package was prepared, it was independently reviewed for completeness of all engineering requirements by a checker.

The MTV Index/ Routing Traveler was signed off and the package was for-warded to the Phillips, Getschow Company QC Department. The QC Supervisor reviewed the Project Engineer's MTV package for completeness and accuracy. A QC sign-off on the MTV Package Index/ Routing Traveler documented completion of this review. The QC Supervisor then issued the II-2

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MTV package to QC Field Inspectors for verification actions in accor-i dance with the marked up drawings and inspection checklists /instruc- i tions. ,

1 C. MTV Documentation Package All Material Traceability Verification (MTV) packages consisted of the following items:  :

1. An MTV Package Index/ Routing Traveler itemized the total con- ,

. tents of the MTV package and served as a Signature / Routing ,

Traveler. This traveler followed tnat package from engi-neering assembly through QC final review, as. well as com-

' pilation of results, and final storage in the records vault.

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2. An isometric of the piping configuration was highlighted in a standardized color coding system which differentiates certain drawing / installation conditions. The standardized color coding was:

1 Red -- Fabricator's Spool Boundaries  :

. Yellow -- Phillips, Getschow Field Welc's

' Phillips, Getschow Added Welds Pink --

Green -- Unaltered Faoricator's Spools I

Orange -- Altered Fabricator's Spools

3. Phillips, Getschow rework spool drawings for those altered fabricator's spools, refabrications, or new spools fabricated i by Pnillips, Getschow Company at the Braidwood site were included in the MTV Package. These packages show the spool l configuration, and indicate the added Phillips, Getschow Company materials on the altered fabricator's spools. The Phillips, Getschow Company spool rework drawings (or the iso-

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metrics when conditions required) were marked with standar-

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dized stamps and symbols which indicate specific locations on those drawings where the QC Inspector was to record, by ini-tials and date, the information gathered during .his field verification.

4. Step-by-step inspection / instruction checklists for each spool to be inspected were provided. These checklists provided spe-cific direction in a standard, sequential manner for each spool inspection. They also provide inspection sign-off e points as well as inspection data recording locations. A set of standardized written instructions and pictorial represen-tations were an integral part of each checklist. This system minimized misinterpretation of required actions. Space is i also provided for the inspector to explain and/or detail uni-que or questionable conditions or situations. Provision existed for either a written description, or pictorial repre-sentation, or both.

For large bore pipe spools, the material traceability attri-butes on the quality control inspection checklist included:

fabricator's spool serial number and spool mark number, manu-facturer's heat or heat code numbers, manufacturer's specifi-

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cation number, Material and Equipment Receiving and Inspection Report (MRR) number, and NDE identification with method of marking for Class 1 piping systems.

For small bore piping, the material traceability attributes on the quality control inspection checklist included: material manufacturer's heat or heat code numbers, and NDE iden-tification with method of marking for Class 1 piping systems.

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5. A Material Traceability Verification log sneet listed the items to be inspected and verified. The engineering portions of this log were completed only after the package was finally

• assembled, checked, and reviewed for completeness. The Project Engineer completed the first three (3) columns of the MTV log. These columns noted the drawing, revision, component itemization and component description of the items being inspected. The remaining twenty-five (25) log entry columns

' were completed by the QC review technicians in their review / analysis of the field inspecti6n data.

D. Quality control Assessment Upon completion of the field inspection and documentation package by the Quality Control Inspector, PGCo Quality Control technicians performed an assessment. There were several phases in this assessment. Tne first phase involved a determination that each item did have traceable iden-tification and the second phase was to determine acceptaDility of the installed item.

For purposes of determining traceanility, the results of the field I inspection were first compared against the stores request. The tra-ceability information identified by field inspection was reviiwed for correctness to verify that the heat number was a valid number. PGCo Nonconformance Reports were written if the field inspected heat qumber

- could not be verified as a traceable heat numaer. The heat number log, which is a listing of acceptable heat numbers for ASME material received on site, and otter traceability documentation was used for this purpcte.

The stores request installation documentation from the data package fc-each item was then examined to compare the heat number from the documen-tation against the inspected heat number. Traceability was verified when these numbers agreed or could be easily reconciled. When.this com-parison resulted in irreconcilaole heat numbers, PGCo Nonconformance Reports were written.

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1 e The second phase of the quality control assessment, the determination of installation acceptability, involved comparison of the items, as defined through the traceability documentation in the first phase, with the installation specification. This included comparison through the tra- ,

ceable documentation back to the manufacturer's records for charac-teristics such as material, schedule, type, grade, and code classification against the installation specification for that item.

PGCo Nonconformance Reports were written for all deficiencies discovered in this check for acceptability.

E. Program Controls E.1 PGCo Program Controls i

The PGCo Braidwood Site Manager, in conjunction with the PGCo Corporate Q.A. Manager, had overall program responsibility for the contractor. The PGCo Project Engineer and the Supervisor-Quality Control were charged with the implementation responsiDilities of this program. The implementation of this program was subject to audit by the PGCo Site Q.A. Coordinator in accordance with the PGCo's Quality Assurance Manual and implementation surveillances required by Procedure QCP-831.

The Supervisor-Quality Control performed a second level review on 100 percent of the MTV packages. The minimum review percentage per package was 50 percent. The second level review included: a

- review of heat traceability numbers for acceptance / rejection; assurance that all sign-offs on MTV checklists were complete; assurance that all items on the MTV log were addressed for acceptance / rejection as applicable; comparison of the MTV computer printout to the MTV log for correctness. Discrepancies identified during second level review were documented and this information was fed back to the first level reviewer responsible for the discre-pancy to improve the quality of first level review.

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The program was implemented utilizing qualified and, where appli-cable, certified personnel. PGCo personnel were not allowed to proceed in any phase of this program without proper and documented training on the approved procedure QCP-B31.

A statusing/ reporting mechanism was established based on the sequence of signature completions on the progressing MTV Package Index/ Routing Traveler and the MTV Log Sheet.

9 E.2 Commonwealth Edison Company Program Controls The Braidwood Project Manager had the overall responsiDility for the MTV program. The Site Project Construction Superintendent had direct implementation responsibility for the PGCo activities rela-tive to this program. These responsibilities included: Procedure review and acceptance, monitoring status of program completion, and initial review of nonconforming conditions. Additionally, the Site Project Construction Superintendent closely monitored this program to assure that an adequate number of qualified personnel were assigned to ensure a timely completion.

Commonwealth Edison Company Project Engineering Department, and I Sargent and Lundy reviewed and accepted the contractor procedure.

Additional responsioliities included the review of nonconforming conditions and providing technical expertise to support program implementation.

Commonwealth Edison Company Quality Assurance monitored all aspects of the MTV program. Their review and approval of the PGCo imple-menting procedure assured that all necessary quality requirements were included. As an additional assurance, Site Quality Assurance performed audits and surveillances of this activity.

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l F. Comparison of MTV to N-5 Review t

PGCo is required to perform a separate and final documentation review prior to the ASME Code stamping of each system, called the N-5 review. This review is conducted in order to complete the Form N-5 Code Data Report in accordance with the requirements of the ASME Boiler and Pressure Vessel Code,Section III, Division 1. The N-5 review includes a document review to verify traceability and material acceptance, in addition to certifying completed bolting, welding, NDE, and the completion of hydrostatic or pneumatic testing.

The MTV program was structured in part to support the N-5 doct.:nen-I tation review with tne added benefit of field inspections. The MTV documentation fulfills the requirements of the N-5 review for those attributes inspected, namely, heat traceability numDers, correct material, schedule, type, grade and class, and pressure rating for fittings. It is reasonable to conclude that most of the findings discovered in the MTV program would have been discovered and dispo-sitioned later during the N-5 review.

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III. PROGRAM RESULTS The MTV Program inspected 25,815 items of large and small bore piping.

i A determination of the existence of material identification numbers on i the stores requests and the installed itens yielded the following four categories of data which are displayed in Figure III-1.

P 4 a. 21,167 itms had both physical identification and stores  ;

request documentation. l i I

. b. 3,990 items, of which approximately 900 items were inac-cessible, had stores request documentation only. The PGCo traceability system relied on the Stores Request ,

i System and did not require permanent retention of physi-  !

cal identification to meet Code requirements. l p c. 577 items had physical identification only. Physical identification marked on the item is an acceptable tra-

ceability system.

d. 81 items had neither stores request documentation nor physical identification.

1 The data in category a. above was used to establish the reliability of

< the PGCo Stores Request System as a means to effect material traceabi-

) lity. This subject is presented in Section 1, below. The 25,815 itens l 8 were evaluated to verify that they are in fa'ct traceanle. Tnis evalua-tion is presented in Section 2. The inspection results for the 25,815 l

items also were used to verify material installation acceptability

through an evaluation of the pertinent documentation. This information I ~is presented in Section 3.

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1. Reliability of Stores Request System t t

The efficacy of the PGCo Stores Request System can be determined by an analysis of the 21,167 items for which both physical iden- l tification and stores request documentation exist. A comparison of j

.' the material traceability markings on the itemsswith those recorded l f

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on the stores requests showed that 20,214 had matching iden-tification numbers. Of the 953 non-matching identification num-bers, 390 were deemed to be equivalent identification numbers.

Thus, out of a' total of '21,167 piping items that were supported by .

identification numbers recorded both on the stores request and the item itself, 975 had equivalent identification numbers.

Identification numbers on 344 of the reaining 563 items, though deficient in minor respects, were readily determined to be tra-ceable. These deficiencies were due solely to a failure to record accurately the identification number on either the stores request or the installed item. In these cases, the Stores Request System had otherwise been effective to assure that the item withdrawn from the warehouse was installed at the location documented in the stores request. Therefore, minor recording errors, which were readily reconcilable, could be considered equivalent identification numbers. If these items are included in the category of equivalent identification numbers, the success rate would increase to 995.

Tne renaining 15 (219 items) failed to have equivalent matching numbers and required further evaluation to determine traceability.

I The success rate of 975, or 995 if the readily reconciled recording errors are countej, provides adequate assurance to conclude that the ASME-accepted Stores Request System used by PGCo was a reliable system for establishing mater'ial traceaoility at the time of

. installation. Moreover, verification of the Stores Request System justifies its use to verify traceability of those items which are inaccessible or for which physical identifications are otherwise unavailable.

The 390 items that were deemed to be the equivalent of matching identification numbers involved partial physical identification of no more than two missing digits. Physical identification numbers III-2

on items with partially visible characters are to be expected given the fact that the inspections under the MTV Program were conducted many months and, in some i.'. stances, years after their installation.

Partially obliterated ma'rkings resulted from construction activi- .

ties during the interval between installation and the inspections.

Therefore, it would not be appropriate to classify items in this category as shortcomings in the Stores Request System provided that the partial physical identification could be reliably matched with a valid traceability numoer on the applicable stores request.

Partial physical identification missing two digits or less had to meet the following acceptance criteria before they could be con-sidered a match with the corresponding stores request. First, the I heat number log was reviewed to determine whether the apparent par-tial physical identification was not itself a valid traceability numoer. If the partial marking was not a valid traceable number, a review of the heat number log was conducted to determine that tne partial marking could not be identified with more than one valid traceable identification number. If the partial physical iden-tification passed both tests it was considered a match with the Stores Request identification number.

9 The 344 minor recording errors referred to above were only con-sidered readily traceable if the differences between the iden-tification numoers on the stores request and the installed item were due to:

a. A difference involving no more than two transposed adjacent characters within a valid traceability number. For example, if a valid number of A2481 is assumed, A42B1 would be a transposition that was readily corrected and, therefore, tra-ceable.

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b. A difference involving the improper substitution of no more than one character. For example, if a valid traceability

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number of 60321 is assumed, 60322 would be a substitution that was readily corrected and, therefore, traceable.

c. A difference involving the improper addition of no more than one character. For example, if a valid traceability number of 411A is assumed, 4111A would be an addition that was readily corrected and, therefore, traceable.

Items included in the above classifications were accepted only if a review of the heat number log showed that the markings on the itens were neither (1) traceability numbers nor (11) potentially tra-ceable to more than one valid traceability number.

Table III-1 presents a distribution of all items with both field markings and stores request documentation categorized by small bore piping, large bore piping and integral attachments. The first column gives the total number of items. The second column gives the number of items with matching marks. This column includes items with identical marks or items whicn were traceable to the stores request by a heat code or serial number sys+em included in the documentation. The third column gives the number of items whicn revealed only partial physical identification but for which equivalence was determined, and the fourth column includes those items that had stores requests with minor recording errors. The last column gives the total numoer of items whose stores request-and field markings could not be reconciled.

Having determined the reliant 11ty of the Stores Request Systen, the next section sets forth the results of the evaluation of the 25,815 items to verify that the Stores Request System was implemented effectively and material traceaoility achieved in fact.

III-4

2. Verification of Material Traceability As provided in the ASME Code, traceability was determined when a valid heat number or spool serial number, or heat code could be

• identified from either a physical identification on the item or the traceability number recorded on the corresponding stores request.

The identification numbers on either the installed items or the stores request were verified by crosschecking the PGCo heat numbe.r log or other pertinent documentation to assure traceability. The log is maintained as a controlled document to record heat numbers.

Material and Equipment Receiving and Inspection Report (MRR) num-bers, material type, grade and class for ASME material. The infor-

, mation in the log or other documentation effectively corroborates the validity of the identification numbers on the stores requests and the installed items, thereby verifying material traceability.

Out of a total of 25.815 items reviewed in the MTV Program, tra-ceability was established with respect to 25.023 items. NCR's were written on 792 itemsI (31). NCR's were written in each case when material traceability was considered a potential question. In some instances, material traceability was subsequently established I through the dispositioning process; nevertheless, these items are shown as nonconforming items. Therefore, the number of items with NCR's written under the MTV Program .is not necessarily reflective of the number of items with inadequate material traceability.

I A separate Nonconformance Report (NCR) was issued outside the MTV Program with respect to 570 piping spool items that had missing name-plates. Although piping material traceability requirements were con-firmed within the MTV Program by reference to identified spool records,_

additional verifications are being undertaken to provide positive tra-

• ceability of fabricator's shop welds and to eneply with ASME Code proce-dural requirements concerning removal of nameplates. Review of approximately 500 spools with missing nameplates has been completed at this time. The remaining 70 spools are still being reviewed.

III-5

The 792 items are categorized in the following manner:

a. For the category of items with both physical identification and stores request numbers (21,167 items), NCRs were written questioning the traceability of 293 items. 219 items had non-matening identification numoers that could not be reconciled as discussed in Chapter III. The remaining 74 itens included some items with matching numbers but which could not be verified oy reference to the heat number log or other documen-tation reviewed at the time. Also included in the 74 items are items for which additional evaluation was necessary to verify partial physical identification and minor recording

+

errors.

b. For the category of items with stores requests only (3,990 items), NCRs were written questioning the traceaDility of 349 items.

c. For items with physical identification only (577 items), NCRs were written questioning the traceability of 69 items, p d. For item. with neither stores requests nor physical iden-tification (81 items), NCRs were written questioning the tra-ceability of all of the items.

Table III-2 distributes the aoove data for small bore piping, large bore piping, and integral attachments. The MTV Program included ASME Class 1, 2 and 3 large and small bore piping and integral attachments. This is the case even though unique heat number tra-ceaoility is not required by the ASME Code for all these items.

The traceaollity findings in Table III-2 separates those items for which unique heat number traceability is not required, namely: for Class 1 and 2 piping and fittings less than or equal to 3/4-inch in diameter (ASME Code, Section NA-3767.4(B)), Class 2 and 3 integral III-6

attachments (Section NC/ND-2130 and 2190), and all Class 3 construction (Section ND-2150). For these items, the. ASME Code only requires a system to assure that the design-specified material ,

type, grade and class has been installed.

3. Verification of Material In*stallation Acceptability In addition to material traceability, the MTV Program reviewed the acceptability of installed items by comparing them against the installation specification 2 for the item. The purpose of this com-parison was to verify correct pipe schedul'e, correct grade, type and class of material was withdrawn from stores. In order to determine material installation acceptability, additional documen-tation checks were made to ascertain that the acceptability of every item checked, regardless of the source of the traceability information, was also acceptable for use as called for in the installation specification. This review required both a documen-tation review and a field dimensional check, where practical. In all cases where the installation did not conform to the installa-tion specification, a PGCo NCR was written. Not until the NCR was resolved, nowever, could the acceptability of installation be determined.

The review of material installation acceptability included dimen-sional checks of installed piping, when practical, to verify that I the installed pipe schedule was as described in Certified Material Test Reports or other material documents. In cases for which a physical identification was not located or was illegible on an item, or for which a PGCo applied field marking was identified without a supporting stores request, digital thickness measurements (DTMs) were taken on the pipe, if possible, for comparison to the

, applicable installation specification.

2Sargent and Lundy Specification for Piping System Installation (Section III Portion), F/L-2739.

III-7

Material class is questionable for certain Class 1 it ms because of possible lack of evidence of non-destructive examination (NDE) on what appears to be Class 1 piping material. This matter was iden-tified by Phillips, Getschow Company as a separate concern unre-lated to the Program. However, because of the substantial quantity of piping material to be inspected under the Program, inspection checklists were augmented to include the identification of NDE

[ markings as an attribute. Evidence of NDE is required by the ASME

! Code unless the Class 1 material has ,been exempted from this requirement. This evidence can be in the form of markings on tne items or in supporting documentation. Results of the review for

,' evidence of NDE for Class 1 piping material are presented in 4 6 Appendix 8 of this report.

i The 135 items for which material installation acceptability was in

question are catalogued below,

a. 24 items were of a greater poundage / schedule than stated in the installation specification; l

b. 10 items were of lesser poundage / schedule than stated in the installation specification; I 12 items were of a different grade / type of material than c.

stated in the installation specification;

d. 46 items were of a lower class material than stated in the installation specification; I e. 18 items had digital thickness measurements less than required by the material specification; and i f. 25 items failed to meet the installation specification i for various other reasons.

I l

These results are presented in Table III-3. The disposition of the NCRs covering the 135 items is discussed in Chapter IV.  !

III-8

t .

4. Summary The Stores Request Systen has been shown to be reliable based on .

- examination of 21,167 items for which both stores request and physical identification is available.

Out of a total of 25,815 items covered by the MTV program, 792 items are the subject of NCR's because of traceability issues, and 135 itens are the subject of NCR's because of material accep-tability issues. The distribution of these items by type of item is given in Taole III-4.

l III-9

Figure III-1 MATERIAL TRACEABILITY VERIFICATION (MTV)

ITEMS VERIFIED BY PHYSICAL INSPECTION AND/0R REVIEW OF STORES REQUEST (SR) DOCUMENTATION g (25,815 ITEMS)

D PHYSICAL I.D. SR ONLY PHYSICAL 1.D. NO PHYSICAL AND SR ONLY I.D. AND NO SR (82.0%) (15.5%) (2.2%) (0.3%)

i 21,167 items 3,990 items 577 items 81 items

)

111-10 f

. ~; .

-; 2 4, -

Table III-1 Distribution of Items With Physical Identification Verifying the Stores Request Items w/ Field Field Markings Item Markings and Matching Partial Phys. I.D. Recording Error and Stores Category Stores Request Identification Same Item Same Item. Request Don't Agree Small Bore 11,471 11,035 179 131 126

- 3 Large Bore 9,479 8,998 200 197 84 Integral Attachments 217 181 11 16 9 Total 21,167 20,214 390 344 219 L_ _ _ _ _ _ _ _ _ __ ___ _

e Table III-2 Distribution of Items by Inspection Category and Traceability Findinge No Phys. I.D. Phys. I.D. No Phys. 1.D. Phys. I.D. & Stores and No Stores Request and No Stores Request but With Stores Roquest Request are Present

! Treceability Traceability Trecombility Treceability Cetecory Items ER

• Iteme NCR* Items ER* Iteme NCR*

- San 11 Bore 24 24 202 31 2,244 16 11,471 146 Traceability Required 7 7 72 15 282 1 - 40 Treceability Not Required 17 17 130 16 1,%2 15 - 106 by ASME Code

- Large Bore 44 44 359 37 1,500 303 9,479 137 Traceability Required 18 18 171 21 327 62 - 66 Treceability Not Required 26 26 188 16 1,173 241 - 71

! [ by ASE Code 13 13 16 1 246 30 217 10 h - Integral Attachmente Traceability Required 0 0 5 0 5 0 - 0 Treceability Not Required 13 13 11 1 241 30 - 10 by ASME Code TOTAL 81 81 577 69 3,990 349 21,167 293 4

• Although ERe were written whenever traceability wee in question, in moet cases, they were dispositioned as acceptable.

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Table III-4 Summary Distribution of MTV Item Findings * ,

Items with Items with

• Total Traceability Acceptability Items NCRs NCRs Small Bore 13,941 217 50 Large Bore 11.382 521 55

. Integral Attact 492 54 30 TOTAL 25,815 792 135 I'

• Does not include NDE marking issue discussed in Appendix R.

I i

e 8

e III-14

~ ~ ..  !

IV. DISPOSITION OF NONCONFORMING ITEMS The. absence of ' both physical identification and valid stor.es request documentation, or the existence of material documentation discrepancies .

identified as part of the MTV review, resulted in identification of a nonconforming condition requiring further evaluation and disposition.

The Braidwood project nonconformance system was and is used to process and track each of the nonconforming conditions identified through the MTV Program.

One or more of the following actions were undertaken as part of the NCR evaluation process in order that each nonconforming condition could be adequately resolved:

e

1. Reinspection by another MTV inspector was employed to ensure a phy-sical marking was not overlooked in order to resolve apparent tra-ceability discrepancies.

2. Extensive searches of satellite record files and field document stations were made to locate stores requests which were not ini-tially retrieved in order to resolve apparent traceability discre-pancies.

I

3. Examination of field drawings, Field Change Orders, and as-built drawings, was completed in order to identify documents that were appropriate for use in the disposItioning of material traceability questions.

4. In-place material thickness measurements were taken where conflicts in the traceability records prevented verification of material schedule.

5. Engineering review of design parameters and conditions was per-formed to verify that conditions found not to conform to the

~

installation specification satisfied minimum applicable ASME Code design requirements.

IV-1

)

l 1

6. Removal and replacement was completed of nonconforming items for which traceability, when required, or acceptability was not established.

In addition to the normal project NCR disposition process applied to the NCRs developed from the MTV Program, a special review board was established. This Board consisted of a representative from the National Board of Boiler and Pressure Vessel Inspectors, the Hartford Authorized Nuclear Inspector, Commonwealth Edison Company Quality Assurance, Project Construction, Project Field Engineering and PGCo. With the exception of the National Board participant and Project Field Engineering who reviewed approximately 85% of the dispositions, the review board reviewed each disposition prior to the nonconformance being finally closed. This board verified for each disposition that documen-tation was properly utilized and, for each disposition, where no rework was recommended (i.e. use-as-is) that tne item was traceable and accep-tably installed. A copy of the National Board's final report is pro-vided in Appendix A.

The purpose of the following discussion is to provide a summary of the disposition of all items whicn received NCRs as part of the MTV Program.

' The distribution of the nonconforming " traceability" and " acceptability" conditions by item versus the total number of items evaluated was pre-sented in Table III-4.

1. Disposition of Traceability NCR Items This section describes the disposition of items identified as non-conforming for reasons of questionable traceability. The discussion is divided between accept-as-is items and items cut-out and replaced.

Out of a total of 792 items with traceability NCRs, the disposition of items between accept-as-is and cut-out is as follows:

IV-2

Items with physical identification and stores request -

Total traceability NCR items - 293 items accepted as-is - 230 .

items cut-out -

63 Items with stores request but no physical identification -

Total traceability NCR items - 349 items accepted as-is - 319 items cut-out - 30 Items with physical identification but with no stores request -

e . Total traceability NCR items - 69 items accepted as-is - 49 items cut-out - 20 Items with no physical identification and no stores request -

Total traceability NCR items - 81 items accepted as-is -

49 items cut-out -

32 6

1.A Accept-As-Is Items Out of 792 traceability NCRs, 647 items were dispositioned "use-as-is." The distribution of these items by type of disposition is given in Table IV-1. The types of acceptable dispositions have been categorized into the following areas.

Colunwi 1 shows the number of itens for which a supplemental documentation search located a stores request copy. The stores request copy was then reviewed to assure it was appli-

. caole to the installation. Although counted as traceability NCRs, these items were not nonconforming because a valid stores request did exist. ,

IV-3

Column 2 shows the number of NCR items which were accepted based on a further investigation of physical identification deficiency. This resolution was accomplished in two ways.

~

First, valid physical identification was verified by supple-mental inspection. Physical identification initially indi-cated as missing was either found or difficult to read numbers were discerned on a second inspection. These items were not traceability nonconformances because the heat traceability numbers did exist. Second, an item was accepted when the phy-sical identification consisted of an original manufacturers' marking process even though the stores request documentation did not agree. Such markings were traceable to valid material documentation and, therefore, represent primary evidence of traceability.

Columns 3 and 4 show the number of NCR itens which, althougn identified as nonconforming because of either errors on the stores request or in the physical identification which made the item potentially traceable to more than one heat of material, were later accepted based on evaluation. In this evaluation additional inspections of the item, reviews of I receipt inspection records, or a detailed look at the installation data package were made to show that the other numbers were not applicable to the installation.

I Columns 5 and 6 show the number of NCR items accepted because the evaluation indicated that the specified material type, grade, and class of material was installed. These items were originally identified as nonconforming Decause the tra-ceability information identified multinic heat numbers. A review of the multiple heat numbers established that each number met the material type, grade and class specified in the Therefore, the items were installation specification.

IV-4

accepted. This action is consistent with the ASME Code (Paragraphs NA-3667.4(8) and ND-2150) which does not require unique heat number traceability for the items in question. ,

Column 7 shows the number of NCR items for wnich traceability was established using other Project Quality Assurance documen-tation. Those items were originally marked as nonconforming because the stores request or physical identification-infor-mation was inadequate. The traceability information generated by the requirements of Section 5 of the.PGCo Quality Assurance Manual was evaluated. This traceacility information, which was in the form of traceability numbers documented in the data e package, was evaluated to assure that it was applicable to the installation. Also in this column are NCR ites for which additional reviews were done of the PGCo drawing revisions which controlled the modification of large bore piping spools.

This review verified that the modifications were accomplished according to the drawing and therefore that the vendor items were traceable to the documentation.

, Column 8 shows the number of NCR items found acceptable by reference to other information, including vendor documen-tation, to establish traceability for the items.

, 1.8 Items Cut-Out i  ;

f Out of a total of 25,815 items inspected in the MTV program, only 145 items were required to be cut-out due to indeter-minate traceability. The distribution of items where trace-i ability could not be estaolished are shown in Table IV-2. As discussed in Chapter V on interpretation of findings, each of

j. ,

those items has been evaluated for design significance.

j .

Column 1 in Taole IV-2 shows the number of items cut-out due I to multiple heat numbers documented for the same item.

IV-5 i

l L

i Because supplemental review did not resolve the discrepancy, the items were cut-out and replaced. 25 itms were cut-out and replaced for this reason.

Column 2 shows the results of a material usage review per-formed if the stores request did not indicate sufficient material was issued from stores to cover the length of pipe or number of fittings needed to complete the specific installa-tion in question. 16 items were cut-out and replaced for this reason. -

Column 3 gives the number of items cut-out because neither stores requests nor field markings were located and no other pertinent traceability documentation could be found to verify traceability. 59 itms were cut-out and replaced for this reason.

Column 4 snows the items cut-out because the physical iden-tifications and/or stores request could not be identified with either an acceptaole heat numoer from the heat number log or other pertinent traceaoility documentation. 44 items were -

D cut-out and replaced for this reason.

Column 5 includes 1 item that was cut-out and scrapped due to a piping reroute prior to the disposition of the NCR.

2. Disposition of Installation Acceptability NCR Items This section describes the disposition of itms identified as noncon-forming for reasons of questionaole item installation acceptability.

The discussion is divided between acceptable itens and cut-out and replaced items.

e IV-6

2.A Accept-As-Is Items Out of a total population of 135 items identified on NCRs dealing with installation acceptability, all items were dispo- -

sitioned as acceptable. The distribution of the 135 items that were accepted by the dispositioning process are grouped on Table IV-3. Columns 1 through 3 set forth the items origi-nally identified as having material characteristics not meeting the Sargent and Lundy installation specification, namely differences in: class, material or item type, or sche-dule.

For items originally identified as not meeting the class requirements, acceptable dispositions are categorized as follows:

o The item was later found to be outside the boundary covered by the ASME Code; and therefore, the class designation was not applicable.

o Additional non-destructive testing and/or documentation .

I upgrade was accomplished demonstrating that the material met the class requirenents.

o The provisions of paragraph NX-2610 in the Winter 1975 Addenda of the ASME Code and Code Cases 1713 or N-242-1 were utilized to accept materials for the ' applicable Class requirements. These provisions allow alternate means to accept materials that were not originally pro-cured in total compliance with the quality system requirements of the ASME Code.

All items of the type discussed above are shown in Column 1 of

~

Table IV-3.

IV-7

Columns 2 and 3 identify items for which material type or item, or schedule was substituted for that shown in the installation specification. A Sargent and Lundy review demonstrated that e'ither the item was not actually a noncon-formance or the suostitution was acceptable and met the appli-cable ASME Code design requirements.

In cases for which a physical identification was not located or was illegible on an item, or for which a PGCo applied field marking was identified without a supporting stores request, digital thickness measurements (DTMs) were taken on the pipe, if possible, for comparison to the applicable installation specification. Column 4 identifies those items for which the I DTM indicated the thickness was less than that required by the material specification. An NCR was written in each instance.

In each case, the iten was reviewed by Sargent and Lundy to determine whether or not the item could maintain its design function with the measured wall thickness. In a few of those cases, the Sargent and Lundy review indicated that the item was indeed within the minimum acceptable wall thickness and that the NCR need not have been written. For all cases in the I "DTM WALL VIOLATION" category, the evaluation resulted in the items being accepted as-is.

The fifth column contains all remaining items that were dispo-sitioned acceptable. All items in this category were disposi-tioned accept-as-is by locating necessary documentation including vendor supplied documentation when not supplied with the material. 14 items are thermowells which were dispost-tioned acceptable with the use of Code Case 1713.

IV-8

2.8 Itens Cut-Out Out of a total of 25,815 items inspected in the MTV program, no iten was required to be cut-out for reasons of material acceptability.

1 e

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IV-9

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', Table IV-2 Distribution of Traceability NCR Items By Disposition For Cut-Out 1 2 3 4 5 Stores No Stores . Stores i Piping Mult. Request Request and Request and/

Category HT is Footage No Physical or Physical Other Incomp. I.D. I.D. Unknown

- Small Sore Traceability Required 12 2 0 2 0 Traceability Not Required 4 14 13 20 1 2 by ASME Code

~

- Large Bore Traceability Required 6 0 28 15 0 Traceability Not Required 2 0 15 4 0 by ASME Code .

- Integral Attachments Traceability Required 0 0 0 0 0 Traceability Not Required 1 0 3 3 0 ,

by ASME Code TOTAL 25 16 59 44 1 I

a Table IV-3 Distribution of Installation Acceptability NCR Items by Disposition For Acceptance 1 2 3 4 5 DTM Piping Wrong Wrong Wrong Wall Category Class Material Schedule Violation Other

- Small Bore -

Traceability Required 2 4 7 0 0 Traceability Not Required 3 1 20 13 0 by ASME Code g - Large Bore Traceability Required 3 3 4 0 12 Traceaallity not Required 11 1 3 5 13 by ASME Code

- Integral Attachments Traceability Required 0 0 0 0 0 Traceability Not Required 27 2 1 0 0 by ASME Code .

TOTAL 46 11 35 18 25

~*

V. DESIGN SIGNIFICANCE EVALUATION In conjunction with the Braidwood MTV Program, 84 NCRs identifying 145 hardware items dispositioned for removal were evaluated for potential

• design significance. This evaluation was designed to determine whether or not any item removed would have represented a deviation from appli-cable ASME Code design requirements if it had not been replaced. This determination gives assurance that all safety related functions could have been performed within Code design limits under design loading and conditions.

1. Description of Items Evaluated

. Except for five items, all 145 items cut-out have been saved for further evaluation. As a conceptual measure of the small magnitude of the total items cut-out, all items could be transported in a 4' x 6' container. These items are stored for future access and examination on three shelves of a 10' x 20' area of a Ctco ware-house on site.

The 145 cut-out items were determined to be distributed as shown in ..

Table V-1. This table gives a breakdown by A5ME Code Class, item size, and system pressure rating class. The system pressure rating class was determined by the $ argent and Lundy pipini, design table specified for the particular item. 300-Ib Class and less is con-sidered low pressure application; 600-Ib Class and greater is con-sidered high pressure appitcation.

Seven of the eight Class 1 cut-out items were 1-inch diameter radiographic access plugs. The remaining item was a section of 2-inch nominal diameter Schedule 160 stainless steel pipe, approxi-mately 45 inches long, located in piping line number ICVA382. This

, line serves as the header for the reactor coolant hot and cold leg drains to either the excess letdown heat exchangers or the' reactor coolant drain tank.

V-1

The remaining 137 cut-out items were ASME Class 2 and 3, and together consisted of the following material:

o approximately 130 feet of small bore (2-inch and 'less) piping pieces a 19 small bore (2-inch and less) fittings o 12 1-inch radiographic access plugs, o 80 feet of 3 and 4-inch nominal diameter pipir.g pieces (approximate) o approximately 16 fegt of large bore (greater than 4-inch) piping pieces o 7 welded attachments out of a total of 492 attachments within the scope of the MTV Program.

• These quantities compare to a total MTV Program scope of approxi-mately 20,000 feet of large bore pipe and 50,000 feet of small bore pipe.

2. Evaluation The design significance evaluation of the MTV cut-out items con- .,

sisted of three phases. Phase ! included an evaluation by Sargent 3

and Lundy of each cut-out item (either "as-installed" prior to removal or after removal) for verification of correctness of criti-cal attributes required by the designer (Sargent and Lundy) in the installation specification. Such critical attributes included item size, wall thickness, rating, dimensional specifications (where appropriate), and material. Data was collected by inspection for manufacturer's identification markings, physical measurements involving ultrasonic thickness, micrometer and scale measurements, and magnetism testing for crude material evaluation.

,. Phase 11 included a review by Sargent and Lundy of the piping ana-lysis stresses, at the locations of the cut-out items in the piping system to assess the design margin available.

V-2

Phase 111 where required included a detailed examination of the material properties of the cut-out items to provide assurance that the material met the requirements of the ASME/ ASTM material spect-fications for the item specified. Each available item which did not have a readily identifiable manufacturer's mill marking physi-cally located on the item identifying complete ASME/ ASTM material specification and grade if required, was subjected to a chemical analysis performed by an independent laboratory. Taussig Asso-e ciates. Cut-out items later found to have manufacturer's mill markings were considered to be adequately and correctly identified to the material specification and required no further confirmatory testing. The chemical analysis for the remaining items was per-

formed to ensure that the chemical composition of the subject material met material specification requirements.

Additionally,16 cut-out items. (approximately 14% of the cut-out items which did not have manufacturer's mill marking of the material specification) were subjected to mechanical testing.

The mechanical testing was performed to provide further assurance that material tensile strength, yield strength, and percent elonga-

) tion properties met the applicable ASME/ ASTM material specifica-tions. The items which were mechanically tested were selected based on specimen size constraints, ability to retest (if needed),

and criticality level o* the intended service appitcation.

3. Results and Conclusions From the cut out item examination, testing and evaluation per-formed, it can be concluded that the material which had been dispo-sitioned to be removed was adequate for the intended service, and met all applicable ASME Code design requirements. Additionally,

,- nearly all of the cut out items (136 of 145 items, or 9.41) were found to comply with all verified critical attributes as specified V3 t

!: l I

l by 54L in the installation specification. The remaining 9 items -

(61)(sevenradiographicaccessplugsandtwopipestanchionwelded attachments) were found to deviate from specification requirements

! in certain aspects. None of these deviations were found to be

• l significant. Cut-out items found to be lacking in a design attri-bute were evaluated and found to be acceptable for the intended i service, in that pressure boundary integrity was shown to be main-l tained at stress levels within ASME Code design allowables.

1 No cut-out items were located in piping regions of high stress.

The vast majority of cut-out items (over 971) exhibited 50% or greater stress margin to the ASME Code design allowable stress, and of the 31 remaining, the minimum available margin was 341. In con-sideration of these large margins to ASME Code allowable stress, i the precise determination of material tensile strength and yield I

strength for each cut-out item was not warranted to establish cut-out item adequacy.

It is concluded that all cut-out material could have been safely utilfred to perform its intended safety function.

l

, A detailed discussion of the results and evaluation is presented in Appendix C.

V4 i

L

Table V-1

, MTV Cut-Out Item Profile PIPING ASME ASME ASME CATEGORY CLASS 1 CLASS 2 CLASS 3 TOTALS ,

1. Up to 3/4" diameter

a. 300-lb class  ;

and less 0 7 15 22

b. 600-Ib class-and greater 0 9 2 11 2.1" to 2"

. diameter -

a. Joo-1b class and less 0 8 23 31

b. 600-Ib class 3

and greater 1 7 0 8

3. 2-1/2" to 4" diameter

a. suu-Ib class and less 0 8 13 21

b. 600-1b class and greater 0 15 1 16

4. 6" to 8" diameter *

a. 399-10 class and less 0 0 2 2

b. 600-1b class and greater 0 1 3 4

5. 10" dia. 4 greater  :

. a. 300-Ib class and less 0 3 0 3 ,

b. 600-Ib class and greater 0 1 0 1

6. Radiographic access plugs 7 12 0 19 l

l 7. Attachments 0 2 5 7 1

TOTALS 8 Items 73 Items 64 Items , 145 Items 61 $01 445 100%

V5 (

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VI. SUPO4ARY OF RESULTS AND CONCLUSIONS

1. 25.815 items were verified under the MTV Program for traceability and acceptability.

o 21,167 items were determined to have both field iden-tification and stores request identification, o 20,214 items (955) had matching field and stores request identification without resort to supplemental records.

o 20,604 items (975) had matching field and stores request identification after reconciliation of partial field identification.

I o 20,948 items (995) had matching field and stores request identification af ter reconclitation of minor recording errors associated with either the fleid or stores request identification.

l o Only 219 items (15) had field and stores request iden-tification that could not be reconciled based,on the int-tial document review.

Based on the above results, the Stores Request System is judged to be reliable.

2. Of the 25,815 items reviewed, only 792 items (35) had apparent identification discrepancies that brought into question the tra-ceability of the item. All such items were documented on NCR's and were further evaluated.

Of the 792 items documented on NCRS due to apparent discrepancies in the traceability of the item, only 145 items (0.55) of the total

,- items verified (25,815) were required to be cut out.

vi 1 l

l

Of the 145 items cut-out all were judged based on analysis and testing to meet ASME Code design requirements and, therefore, to be capable of satisfying their safety-related function. .

i 3. Of the 25,815 items reviewed, only 135 items (0.5%) had apparent acceptability discrepancies that brought into question the accep-tability of the item. All items with apparent discrepancies were documented on NCRs and were further evaluated.

Of the 135 items documented on NCRs due to apparent discrepancies in the acceptability of the item, none of the items were required to be cut-out, and all were shown based on evaluation to meet ASME Code design requirements and therefore, to be capable of satisfying

( , their safety-related function.

4. On the basis of the reliability of the Stores Request System demonstrated in Section 1, above, and the overall traceability of materials demonstrated in Section 2, above, the Phillips, Getschow Company Piping Material Traceability Program (MTV) has been l

l demonstrated to be effective.

i

5. On the basis of the demonstrated acceptabilfty of materials ,

6 installed by Phillips, Getschow Company during the period verified within the MTV Program, the Phillips, Getschow Company Piping Material Control Program has been demonstrated to be effective.  ;

. 6. Although a limited number of apparent discrepancies were identifled l

by the MTV Program, no discrepancy was determined to have design l significance in as much as all discrepant items, including those few items (0.55) cut out based on irreconcilable records, are l

judged to be within ASME Code design requirements. No discrepancy j was shown after analysis and testing to have more than minor signi-ficance. On this basis, all items reviewed under the MTV Program were verified as capable of satisfying their safety related func.

tion.

VI 2

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SUPPLEMENTARY REPORT ON MTV PROGRAM BY THE NATIONAL 80440 0F B0ILER AND PRESSURE VE5SEL INSPECTOR 5 l .

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September 26, 1985 l Mr. Cordell Reed, Vice president Commonwealth Edison Company p.0. Box 767 Oitcago, IL 60690  ;

SUBJECT:

National Board Audit of the Braidwood Nuclear power Station I Units 1 & 2 Braidwood, Illinois  ;

Material Traceability and Verification program (NTV) -

Supplaneatary Report I

Dear Mr. Reeds Cosmonwealth Edison Company (CECO), in a letter dated November 9, 1984 to l Mr. 5. F. Marrison, then Esecutive Director of the National Board of Boiler  :

and pressure Vessel Inspectors (NS8pVI), requested the National Board to conduct an independent audit of the Braidwood Station. D e purpose of the audit was to i address specific Nuclear Regulatory Countasion (NRC) concerns about ASME f abri- l cation at the Braidwood site. The National Board /mdit Team (NBAT) arrived on  !

the Braidwood Nuclear power Station site on February 18, 1985. j i

Of the various ASME concerna which had been identified by the NRC, the one of prime l 6 interest to the NEAT was the Material Traceability and Verification program (NTV). j De MTV program was initiated because of concerns raised by the NRC and others  :

about the receipt, release, control and identification of materials used in the I construction of the ASME Code piping systems at the Braidwood site. It was their ,

contention that the ASME Code required jognented veriNeation of material identifi-cation and acceptability for use at the point of insta;iation by anality gontrol ,

f moreonnel, he NRAT was requested to make an evaluation of the adequacy of the phillips, Getechow Company's (PC-Co) " stores request system" for providing ASME Code  !

required material traceability. De NSAT was also requested by CICO to assess the (

scope and adequacy of the MTV program as a corrective action method to identify and disposition any items whose traceability was indeterminate.

To accomplish this evaluation, the NBAT initially undertook en assessment of the  :

"stnres request system" as described in the ciirrent pG-Co quality assurance program manual and all historical revisions. Naving completed this evaluation, the NBAT le of the opinion that there is no basis for believing that PG-Co's quality aneur-  ;

onee' program, se described in the quality soeurance manual, did not meet the require- i mente or intent of the 1974. Winter '75 Addenda of the ASME Code, Section !!!, i para. NA-4441. Dis, we believe, is also consistent with the opinions of the i several ASME survey teams who have surveyed the PG.co program for ASME accreditation j purposes. ,

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0 Page 2

- Commonwealth Edison Company HTV Supplementary Report September 26, 1985 While the NBAT is of the opinion that the PG-Co's Q. A. Program met ASME Code requirements, we also recognized that there were deficiencies in its implemen-tation. These deficiencies were spectiically in the areas of:

A) Transfer of material identification after cutting and prior to installation.

B) Loss of control documents which provided material traceability.

To provide the necessary audit and overview activities requested by CECO, the

• NBAT determined the following activities be carried out:

1) Evaluate MTV procedures and work instructions.

2) Perform an overview of disposition of nonconformance reports (NCR's) which were material traceability related.

3) Conduct an audit of HTV data input, including PG-Co stores requests only.

4) Perform an audit of the current PG-Co Material Identification and Traceability Program.

The following sections of this report describe the NBAT's actions and conc 1,usions of Items 1 through 4 above.

1. MTV PROCEDURES AND WORK INSTRUCTIONS:

PG-Co MTV Procedure B31 and Implementing Work Instruction PCW1-17 were I evaluated. The procedures addressed only large and small bore piping materials, including fittings and attachments, as well as stamped piping subassemblies. Further, the MTV procedures addressed only large bore items installed prior to January 1,1983 and small bore items prior to September 6, 1983, as those were the implementation dates of the revised PG-Co quality procedures requiring documented quality control verification of material identification at the time of installation for large and small bore items respectively.

The MTV procedures required a 100% field walkdown of the above described piping systems by quality control inspectors trained to the requirements of the MTV procedures. During the walkdowns all material identification markings were required to be recorded in the MTV packages. The data gathered was then to be compared to the information recorded on the stores requests (material issuance documents) that, by procedure, were required to contain a description of the material issued by specification, grado, type, size, schedule, class, heat / lot

• or code number and quantity, along with the drawing number against which the items were issued.

l .

The procedures also required that the traceability data gathered be verified to certified material test reports (CMTR's) or Code data reports and procure-ment documents as traceable itema for correct material specification, type, grade, class, mise and schelule.

A-2

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pase 3 6

Commonwealth Edison Company MV supplementary Report September 26, 1935 P

Further, the procedures required that items not traceable to the material certifications through physical markings on the items or documentation (stores requests) traceable to the items be considered unacceptable, and be documented on NCR's and dispositioned in accordance with ASME Code ,

requirements. l NBAT Opinion i

The NEAT is of the opinion that the procedures and work instructions contained an offactive method of confirming or denying material traceability within the scope of the pC-Co quality program used -

. for installation of items at the Braidwood station. r

2. MONCONFORMANCE REPORT OVERVIEW:

1 It was determined by the NBAT that we take an active part in the review of the disposition of material traceability related NCR's where dispositions were .

provided jointly by Comonwealth Edison, gargent & Lundy, and phillips, Getschow to insure compliance with ASME Code requirements. His commitment was made 2, during the week of May 27, 1935, and our activity began June 3, 1935. The i NEAT actively participated in the review for disposition of 35% of all MTV related NCR's. Our records indicate that 366 NCR's were written against 726 individual items. De NEAT provided an independent overview of 310 of these NCR's.

l NSAT Osinton.

l D e NSAT is of the opinion that the dispositions approved by the Certificate Nolder (pG-Co) and Owner (CECO) and accepted by the '

Authorised Inspection Agency (AIA) will result it. Code compliance for those specific items.  ;

3. AUDIT OF MTV DATA INPUT The NBAT prepared an audit plan and checklista designed to confirm the validity  ;

of the MTV data input. In order to provide an unbiased audit sample of suf-ficient sise cossensurate with the NBAT manpower level, it was determined ,

that it would be necessary to utilise pG-Co's quality control personnel to provide the reverification walkdowns and input data for the NSAT's use. To accomplish this, the NSAT randomly selected 20 small bore and 30 large bore l piping M V packages used by pC-Co. The original MV files were signed out to the NBAT and locked in our f fles to preclude pG-Co's quality control per- ' '

sonnel access to the original data.

pC-Co was then requested to prepare MTV verification packages in accordance with its MTV procedure QCp-331 and to reinspect the items in each package as '

had originally been done. Rose packages, along with any additional documen-tation required for validation, were then compared by the NSAT to the data j A-3 i

i

. Page 4 Commova#ealth Edison Company MTV supplementary Report september 26, 1935 in the original MTV data packages. This verification was done in accordance with the NBAT's " Verification of MTV Data" instruction and checklist. -

The sample size vaa reduced to 47 MTV packages, in that 3 of the original packages selected were for containment spray piping and at that time were inaccessible. The NEAT determined that if the audit of the reduced sample indicated any problems with the MTV data, the sample size would be increased.

To facilitate the audit, the NBAT required copies of all supporting documen-tation for the MTV packages. This included MT/PQ logs, material receiving records, and manufacturers' data reports for fabricated subassemblies. .

The audit addressed the traceability of approximately 613 individual items based on an average of 13 items per package. The sample size represents 2.3% of the entire population of MTV items.

" In addition, the NBAT conducted an audit of 50 installed items whose trace-ability was established based on a stores request document only. The audit confirmed the integrity of the stores request system.

NBAT Opinion P

The NBAT found that the scope and accuracy of the MTV program *as implemented and confirmed by our audit verified that all items whose traceability was not confirmed were identified, and removed or dispositioned in accordance with the requirements of the PC-Co quality assurance program and the ASME Code.

4. AUDIT OF CURRENT pG-C0 MATERIAL TRACgABILITY:

The NBAT conducted an in-depth implementation audit el the current PG-Co procedures QCP B4.0, 34.1, and 54.2 during the period from June 10 to July 12,

. 1965. These procedures address the receiving inspection, storage and handling, issue and control of materials.

, The intent of this audit was to determine whether the deficiencies which caused the development of the MTV program had been corrected.

f The audit specifically addressed material issuance and traceability since January 1,1983 for large bore piping and since September 6,1983 for small bore piping. These were the implementation dates for the above procedures.

,. NBAT Opinion The NsAT audit conclusion is that the procedures presently in effect contain the necessary controls to insure material tracsability and identification. Our audit results also indicate that the procedures are being implemented. .

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Page 5 Commonwealth Edison Company

MTV Supplementary Report '

September 26, 1985 CCNERAL CONCLUSIONS -

The NBAT has come to the following conclusions after our comprehensive review and audits of the MTV program and related documentation:

... The Phillips, Getschow quality assurance program as written did provide the necessary controls to assure that the work performed by PG-Co at the CECO Braidwood Nuclear Power Station met the require-ments of the ASME Code and. the certified design specification.

i

... As noted previousif-in this report, there were implementation deviations from the PG-Co quality assurance program's requirements.

... These deviations led to the generation of the MTV program and the resulting revisions to the PG-Co quality assurance program and material control procedures.

~ The NBAT accepts the MTV program as a corrective action. The purpose of corrective action is to

a) document conditions which are adverse to quality.

b) determine the cause of the problem. -

c) take corrective measures which will correct and prevent the recurrence of the problem.

This, we believe, has been done.

Based on our review and audit of data compiled by PG-Co and CECO, the NBAT has found that items where traceability was in question are identified and are being dispositioned in accordance with the requirements of the PG-Co program and the ASME Code.

I It is the NEAT's considered opinion that the corrective actions which were taken to correct deficiencies in the material control procedures at the Braidwood site are effective and have identified those instances where material traceability may have f ,. . been lost. Additionally, we believe that the revisions made to the program and

'~~

procedures will prevent the recurrence of these deficiencies.

.The NBAT wishes to express vur appreciation to CECO, PG-Co and others for their cooperation and assistance in the conduct of this audit.

As , identified earlier, this is a supplementary report and no response is necessary. -

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- . - - _ . . _ . , . . _ - - . - , . ~ _ - _ - , _ _ __ -- _. _

~

Page 6 Consnonwealth Edison MTV Supplementary Report September 26, 1985 Respectfull submitted, BP d D J. Mcdonald Executive Director l .

C. W. Allison National Board Coordinator

/d9/A Michael F. Sullivan Team Leader Robert P. Holt Team Member ,

C 4 -

C. Stephen Lindbeck

, Team Member W

ohn E. Storrs Team Member DJMcD/ CWA /MFS/RPH/CSL/JES:jsb cc: W. S. Little, NRC, Region III, Glen Ellyn, IL D. R. Gallup, State of Illinois Terry R. Lash, Dept. of Nuclear Safety, IL A-6

APPENDIX B

, CLASS 1 NDE MARKINGS e

e

'I APPENDIX B CLASS 1 NDE MARKINGS ,

The ASME Code requires that a record of NDE be retained for Class 1 materials, unless it can be shown that one of the following exemptions

~is' satisfied:

1. For piping material less than or equal to 1 inch, Class 2 rules may be used for Class 1 installation. Class 2 rules do not require NDE. (NB-3630(d))

2. For piping material greater than 1 inch but less than or equal to 2 e

inches, NDE is not required if the stress level of the installation satisfies a lower stress allowable (NB-2510(2)) than would other-wise be required for Class 1 installations when NDE is performed.

As a consequence of a concern unrelated to material traceability, the MTV Program was used to verify the adequacy of Class 1 materials. -

For small bore piping,1,043 items inspected received NCR's due to ina-dequate NDE records, approximately 40% of the Class 1 small bore piping i items. For large bore piping, 3 items received NCR's due to inadequate NDE records, less than 1% of the Class I large bore piping items.

Most of these discrepancies appear to have occurred because of changes in the installation specification that defined the NDE requirements as well as the NDE marking practices employed at that time. Originally, the installation specification did not require NDE for small bore piping in the expectation that the Code allowed exemptions would be applicable.

Much of the small bore piping material was purchased and received on-site in conformance with this specification without NDE required.

Subsequently, the installation specification was changed to require NDE

- for small bore piping. At that time nearly half of the small bore B-1

piping material had already been installed. The MTV Program was used to locate this material. .

Commonwealth Edison sent mso'e of the already purchased materials .

remaining in stores to be tested in order to satisfy the specified NDE requirements. This material was returned to stores with the proper markings and subsequently disbursed to the field for installation. When Phillips, Getschow Company cut the small bore pipe for installation, the material heat numbers were transferred thus maintaining traceability but the NDE markings may not always have been transferred. The MTV Program was used to locate these items as well.

For each item that the record for NDE on Class 1 piping materials did not meet the Class 1 requirements or coule not be shown to satisfy the exemption requirements provided in the ASME Code, NDE will be performed and documented.

Approximately 878 items have been successfully dispositioned for use as .

is. The acceptable disposition of the remaining 1-1/2 inch and 2-inch fittings is contingent upon successful nondestructive examination. This work has yet to be completed.

I B-2 1

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APPENDIX C

, DETAILED RESULTS OF DESIGN SIGNIFICANCE EVALUATION

. - . - _ _ _ . .= - _ -

I APPENDIX C a

DETAILED RESULTS OF DESIGN SIGNIFICANCE EVALUATION 9 '

r A. Phase I l Of the la5 cut-out items dispositioned to be removed,133 items were found to meet all verified critical attributes as specified (size, wall thickness, rating, dimensional specifications where appropriate and material specifications where determinate by manufacturer's mill markings).

Three cut-out items of the total of 145 cut-out items could not be phy-sically verified in the Phase I evaluation, since the material was not I available for examination (i.e., these three cut-out items were not retained). These items included one ASME Class 3, 2"x3/4", 6000-lb socket-weld reducing insert (PGCo NCR 2516), one ASME Class 2 radiographic access plug (PGCo NCR 3300), and one ASME Class 2, 1/2-inch 4 nominal diameter, 6-inch long schedule 160 stainless steel pipe (PGCo NCR 3992). Each of these items was found to be acceptable, however, using comparative evaluations and excess design margin to Code allowable stress.

3

. The nine remaining cut-out items consisted of seven radiographic access plugs and two pipe stanchions. The results of the Phase I evaluation of j these items is detailed below.

Seven radiographic access plugs of the total number of nineteen access l

l plugs in the MTV cut-out population did not completely conform tp the dimensional specifications required by the applicable standard, Pipe Fabrication Institute Standard ES-16. The questionable plugs were

, reported under PGCo NCR's 1742, 1931, 1871, 2177, 2434, and 3275.

All seven plugs were used in ASME Class 2 piping, up to 600-lb Class design (1-600-lb Class, 4-300-lb Class, 2-150-lb Class). All seven C-1

access plugs were found to be one-inch diameter access hole plugs, and met specified thread diameter and thread size. However, these seven plugs were found to deviate dimensionally with respect to the machined neck dimensions, which is the unthreaded region on the plug shank directly below the plug head. The deviations reduce the effective thread engagement of the plug. It is noted that the applicable standard also specifies that the plug must be sealed all around with a 3/8-inch fillet weld to the pipe upon completion of radiography. An engineering evaluation of the discrepant plug dimensions found that all seven plugs were acceptable, in that the reduced effective thread engagement was determined to be adequate, in all cases, to maintain pressure boundary integrity within ASME Code allowable stresses. This evaluation was con-servative in that it did not take credit for the 3/8" fillet weld seal which, by itself, would maintain pressure boundary integrity.

Thus, it is concluded that the seven discrepant radiographic access plugs deviated from specified dimensional requirements in minor respects, resulting in no significant degradation from specifications, and resulted in no design-significant deviations. -

Two 18-inch diameter pipe stanchions, both welded attachments for pipe support number ISX02061X, reported under PGCo NCR 3474, were found to I have sections of pipe wall slightly below the allowable mill tolerance per the applicable ASME/ ASTM material specification. The two pipe stanchions were specified as 18-inch Schedule 40 pipe per SA106 Gr B, ASME Class 3. The required minimum wall thickness per material specifi-cation (nominal wall minus 12.5%) is 0.492 inch. Actual measured wall was found to be as low as 0.462 inch, 0.030 inch less than the minimum specified (6.5% reduction). Review of the design calculations revealed, however, that tne stanchion design had been qualified based on thinner, standard wall pipe (0.375-inch nominal wall), and therefore, the slight reduction in wall from the as-specified condition has no design signifi-

,cance. Ne revision to the calculation was required since the hardware

~ was more conservative than initially specified. -

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i The following discussion integrates the results of the Phase II and III evaluation, with the Phase I evaluation, for the nine cut-out items which were found to deviate from specification requirements as pre-viously discussed.

In all nine cases, the discrepant cut-out items were found to be located in piping regions subject to relatively low stress levels, less than 50%

of the ASME Code allowable stress values, in the Phase 11 evaluation.

4 Additionally, all nine cut-out items were subjected to chemical analysis during the Phase III testing program, and were found to meet the chemi-cal composition of the ASME/ ASTM material specifications required by design. Because of the small sizes of the nine cut-out items in 4 question, specimens of the proper size could not be obtained to perform l testing for mechanical property verification.

Based upon the above, the nine cut-out items which were found to deviate in minor respects from specification requirements were determined to be adequate for their intended service, and met all ASME Code design requirements. .

i B. Phase II Phase II included a review of the analyzed piping stresses in the D.

regions of the cut-out items.

The evaluation of piping stress ratios for the cut-out items was con-ducted for the following purposes:

i

1. The piping stress ratio serves as an indicator of the level of per-formance demanded of the cut-out item.

2. The piping stress ratio determination was required to assess the need to subject cut-cut items to extensive mechanical testing, in l

addition to the chemical composition verifications performed in l

[ ,- Phase III, to establish cut-out item adequac,<. If considerable L margin was found to exist, to the point that mechanical properties C-3 l

l

_ , ~ - . . . - - - - - _ - - - . . , - __ - _ _ . . _ _ _ _ _ . _ _ . _ _. _ . -___ , ___ - _.. - . . .

~1 (tensile strength and yield strength) could not reasonably vary to the extent necessary to be significant in the determination of the cut-out item's adequacy, then confirmation of correct chemical com-position alone would be considered as acceptable

• evidence demonstrating the cut-out item's conformance to material specifica-tion requirements.

The piping stresses extracted from the associated piping analyses reflect the highest theoretical stress levels that could be achieved during design-basis events, as determined by ASME Code stress equations.

These values are very conservative, for the following reasons:

1. During normal operation, actual stress levels will be considerably lower than those indicated.

I

2. Stress values could have been lowered appreciably in many cases by further detailed analysis using analytical input criteria more spe-cific (less enveloping) for the individual piping regions of con-cern.

3. No attempt has been made to reduce stress values based on recently relaxed analysis damping factor criteria.

I The following is a summary of the piping stress conditions existing at the cut-out item locations:

NUMBER OF CUT-0UT ITEMS 1 CODE ALLOWABLE STRESS 141 (97.2%) less than or equal to 50%

2 ( 1.4%) 51 to 605 2 ( 1.4%) 61 to 70%

0 greater than 70%

145 TOTAL 97.2% of the cut-out items were found to be subjected to stresses less

' than or equal to one-half of the ASME Code allowable stress levels, and C-4

1 are characterized as low stress items. 2.8% of the cut-out items were found to be subjected to mid-range stress levels (51-70% range). Actual stresses in this group were found to vary from 56% to 66% of ASME Code allowables. No cut-out items were found to be subjected to high stress levels. It is noted that the ASME Code design allowable stresses them-selves include an inherent safety factor of 4 to 1 (tensile strength to allowable stress ratio for ASME Class 2 and 3 systems).

Due to the large margin available (minimum margin of 34%, and 50% or more in the vast majority of cases), it was deemed adequate to establish material specification conformance on the basis of chemical composition tests, where required, and 100% testing for cut-out material tensile property verification was not warranted to establish cut-out item ade-quacy. This assessment was further substantiated through a search of other ASTM piping materials for which the chemical analysis results of Phase III could have applied. .No materials were found to exhibit mini-mum tensile strengths low enough to result in the subject material's inability to perform intended safety functions if it had been inadver-tently installed. Mechanical testing was performed, however, on a spe-cially selected sample to provide further assurance that material tensile properties were acceptable. The mechanical testing sample selection and results are discussed in the Phase III section of this

)

appendix.

The following discussion focuses on the four cut-out items found to be in the mid-range stress level.

Two cut-out items were determined to be in piping regions experiencing stress levels in the range of 51 to 60% of allowable stress. These two items are sunnarized below:

PGCo NCR 2073 MTV Item 3, 3-inch nominal di ameter, Schedule 160 stainless steel piping spool, approximately 1 foot long,

. ASME Class 2. This pipe is located in piping line number 1CV10AA3, in the Regenerative Heat Exchanger 1A (Eqt No.

! C-5

1 ICV 03AA) discharge, downstream of check valve 1CV8320A.

Maximum piping analysis stress level, 56% of allowable.

PGCo NCR 3318 MTV Item 3, a 3x3/4-inch 3000-lb sockolet located on piping line number 1CV03B3, a 3-inch Schedule 405 stainless steel line; ASME Class 3. This 3-inch line serves as supply line from the mixed bed and cation bed demineralizers to the reactor coolant filter. Maximum piping stress level is 56% of allowable.

8 Two cut-out items were determined to be in piping regions experiencing stress levels in the range of 61 to 70% of allowable stress. These two items are sumarized below:

, PGCo NCR 2505 MTV Item 9, a 2x3/4-inch 6000-lb socket-welded reducing insert located on piping line number 1CC54AA2, a 2-inch Schedule 160 carbon steel line, ASME Class 3. This line serves as a component cooling water return line for Reactor Coolant Pump 1A. Maximum piping stress level is 64% of allowable.

PGCo NCR 2511 MTV Item 2, a 3-inch nominal diameter Schedule 160 stainless steel piping spool approximately 10-inches

)

long; ASME Class 2. This pipe is located in piping line number ICV 01CC3, which is one of three lines in the Regeneratfye Heat Exchanger discharge to the Letdown Heat Exchangers. Maximum piping analysis stress level is 66%

of allowable.

The following discussion integrates the results of the Phase I and Phase III evaluations with the Phase II evaluations, for the four identified items of mid-range stress.

Two of the above four cut-out items are small fittings. In the Phase I

- evaluation, both of these fittings were found to carry as ,specified manufacturer's mill markings identifying ASME/ ASTM material specifica-C-6

1 tions and fitted rating, thus providing confidence that the materials were correct. The remaining two items were short spools of pipe, which did not exhibit manufacturer's markings. These two items were chemi-cally analyzed during the Phase III testing program and wer'e' found to meet the chemical composition of the ASME/ ASTM material specifications required by design. Because of the small size of these pipe spools, specimens of the proper size could not be obtained to perform additional testing for mechanical property verification, and these items were not included in the tensile testing sample. However, based on the satisfac-tory results obtained from the samples which did undergo mechanical pro-perty tests, and the stress margin available, it was judged that the use of the properties associated with the as-specified ASME/ ASTM material was appropriate, in the Phase Il piping stress evaluation. On this e

basis, these pipe spools were determined to be adequate for their intended service.

C. Phase III Phase III consisted of a detailed material evaluation, where required, to verify that certain cut-out items met the requirements of the appli-cable ASME/ ASTM material specifications.

3 For 34 of the 145 cut-cut items, ASME/ ASTM material specification was confirmed as follows:

- 31 items were found to be physically marked, by the manu-facturer, with ASME/ ASTM material specification and grade.

- 1 item was found to be physically marked, by the manufac-turer, with.a heat number that was the same as a similar cut-out component which also had manufacturer's marking of ASME/ ASTM material specification, as well as heat number.

- 2 items which were not available for physical examination in ' Phase I, as they were not retained in storage, were

,- found to be acceptable by further evaluation and need not have t,een cut-out. ASME/ ASTM material specifications were confirmed for both items (PGCo NCR's 2516 and 3300),

as described in the results of the Phase I evaluation.

C-7

t.

For these 34 cut-out items, material type / grade was considered established, and no further testing was warranted. In each case, the as-found material matched the as-specified ASME/ ASTM material specifica-tion.

As discussed in the Phase II results, the confirmation of correct chemi-cal composition was considered to be a:ceptable evidence demonstrating that the materials of the subject cut-out items were adequate for their intended service. This criteria is further validated in that, project-wide, very few types of carbon steel and stainless steel piping materials have been specified. The types of piping materials that are I

specified are commonly used materials which are readily available. More exotic, restrictive carbon and stainless steel piping materials are not used on the project. Thus, if material can be established to meet the chemical properties of the specified carbon or stainless steel, it is unlikely to be anything else.

Of the remaining 111 cut-out items which did not physically identify material specification by the manufacturer,108 cut-out items were sub-jected to chemical analysis in accordance with ASTM A751 by an indepen-dent laboratory (Taussig Associates, Inc.) under S&L Consultation Specification 121. The results of the chemical analysis of these 108 I cut-out items are presented in Taussig's Report No. 64188-1, dated October 8, 1985. The independent laboratory found that all of the 108 cut-out items conform to the applicable ASME/ ASTM material specifica-tions, and that no evidence of any unusual alloying elements was iden-tified.

Two of the three remaining cut-out items of the total 111 items for which ASME/ ASTM material specification could not be confirmed by manu-facturer markings, reported under PGCo NCR 3492 (ASME Class 2, 3/4-inch

. Schedule 40S pipe, approximately 3 inches long) and PCGo NCR 4756 (Item 128) (ASME Class 2,1-inch Schedule 40S pipe, approximately 6 inches

- long) could not be subjected to chemical analysis, in that these cut-out items were inadvertently lost after remoin1. Prior to removal, Phase I C-8 k

r o -

9 examination had found both pieces of pipe to be non-magnetic, a trait characteristic of the specified material, SA312 TP304, in each case.

However, in PGCo NCR 5572, additional data was presented which would have established traceability for these two items, prior to their remo-val, had it been revealed earlier. Thus, based on this additional data, ASME/ ASTM material specification was established.

The one remaining cut-out item of the above described 111 cut-out items, reported under PGCo NCR 3992 (ASME Class 2, 1/2-inch Schedule 160 instrument sensing line pipe approximately 6-inch long), could not be subjected to chemical analysis, in that this cut-out item was scrapped after removal, as discussed in the Phase I results. For this item, ASME/ ASTM material specification could not be confirmed in Phase I or Phase III. However, due to the extremely low stress levels for this cut-out item, as determined in the Phase 11 evaluation, this cut-out item was found to be acceptable in that it could have adequately per-formed its intended safety function.

For additional assurance that materials of the cut-out items were as specified, 16 of the 108 cut-out items which had been subjected to che- i mical analysis were subjected to tensile testing by the same independent laboratory. This represented approximately 14% of the total cut-out I items for which material specifications were not identified by manufac-turer's marking.

The selection of the cut-out items for tensile testing was based on the

. following criteria:

1. Size constraints - Due to the small physical size of many of the cut-out items, standard specimens for testing could not be obtained. To eliminate potential uncertainty in the interpretation of results, such cut-out items were not considered for tensile testing. The independent laboratory required minimum pipe specimen

,- lengths of 18 inches for full-pipe testing, which was limited to 2-inch and smaller nominal diameter piping. Additionalli, reduced C-9 i

r e,d, S

• section tensile test specimens a minimum of 10 inches long were required for testing of pipe over 2-inch nominal pipe size (section of material extracted from the pipe wall of the subject cut-out item). Many of the cut-out items did not meet these sizi' criteria.

2. Retest capability - To ensure that adequate quantities of material would be available for retest in the event that the first tensile test performed was found to be invalid (i.e., machining flaws found, specimen breaking at elongation scribe mark, etc.), selec-tions were generally made from cut-out items which were physically large enough to yield more than one test specimen.

3. Criticality of service - Consideration was made to ensure that selections for tensile testing included cut-out items removed from i piping systems experiencing the most demanding service require-ments, when possible. Eleven of the sixteen cut-out items were large bore piping. Three of these eleven cut-out items represented the highest pressure rating / pipe size combinations from the entire

' cut-out population (6-inch Schedule 80 pipe under PGCo NCR 3226, 24-inch Schedule 40 pipe under PGCo NCR 3291, 6-inch Schedule 120 pipe under PGCo NCR 3422). Four of the sixteen cut-out items were small bore piping; three of the four were Schedule 160 piping.

I Also included in these four small bore specimens was the only Class A cut-out item in the entire population (other than radiographic access plugs), under PGCo (NCR 4756 Item 68).

. 4. Items to be tensile tested were collectively selected by represen-tatives of CECO, S&L, and the NRC.

Specimens were prepared for the selected sixteen cut-out items, and ten-sile tests were conducted in accordance with ASTM A370 to establish yield strength, tensile strength and elongation for each specimen. The results of the tensile testing are also presented in Taussig's Report

, 41 0 . 64188-1. The independent laboratory found that all tensile test ,

specimens met the tensile test requirements of their ' applicable  !

ASME/ ASTM specification. I C-10

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