ML20151T444
| ML20151T444 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/17/1986 |
| From: | Danielson D, Jacobson M, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151T415 | List: |
| References | |
| 50-456-85-61, 50-457-85-57, NUDOCS 8602100272 | |
| Download: ML20151T444 (21) | |
See also: IR 05000456/1985061
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U.S. NUCLEAR REGULATORY C0fMISSION
REGION III
' Reports No.'50-456/85061(DRS); 50-457/85057(DRS)'
- Docket =Nos. 50-456; 50-457
. Licenses No. CPPR-132; CPPR-133
Licensee:
Commonwealth Edison Company
Post Office Box 767
' Chicago, IL. 60690
Facility Name:
Braidwood Station, Units.1 and 2 -
Inspection At:-, Braidwood Site, Braidwood, IL
Inspection Conducted:
July 8, 3, 11, 25, 26; August 1, 2, 5;
September 17, 25, 26; November 18, 19, 21, 26;
December 10, 17, 1985, and January 9, 1986
W
Inspector:
J. W. Muffett
i /n /86
Date
/7 A
..M. Jacobson
8
Date ~
',bhieh
/ # #2
Approved By:
0
Materials and Processes Section
Date
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-Inspection Summary
Inspection on July 8, 9, 11, 25,~26; August 1, 2, 5; September 17, 25, 26;
Novemoer 18, 19, 21, 26; December 10, 17, 1985; and January 9, 1986
(Reports No. 456/85061(DRS); 457/85057(DRS))
Areas Inspected:
Special unannounced safety inspection of a previously
-identified unresolved item concerning traceability of piping and piping
components and the licensee's Material Traceability Verification (MTV)
program.
The inspection involved a total of 160 inspector-hours by two NRC
inspectors.
Results:
In the area inspected, one violation was identified (failure to
-follow procedures as identified in Paragraph 2.i..(2)).
8602100272 060203
ADOCK 05000456
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S umma ry a_n d_0 v_e ra l_1_ _Co n_c llu_s i o n s
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Purpose
The purpose of this report is to document Region III review of the piping
material traceability issue at Braidwood.
In addition, this report documents
the actions taken to assure that the Braidwood Material Tracec',ility Verifica-
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tion Program (MTV) was properly carried out, and to document the review and
evaluation of the " Report on Material Traceability Verification at Braidwoed",
dated November 1985, submitted by Conzonwealth Edison Company (CECO).
Background
A special Region III team inspection, conducted in June, July, August and
October of 1983 and during January and February of 1984, resulted in an
unresolved item concerning verification of correct heat number traceability
for piping and piping components. Specifically, it was determined that
Phillips Getschow Company (PGCo) had not been performing documented inspections
for correct material usage of piping and piping components at the time of
installation and a few instances were identified where material traceability
could not be readily verified. At the time NRC Inspection Report No. 50-456/
83-09; 50-457/83-09 was issued, the exact extent and significance of the
progrannatic deficiencies were unknown; therefore, this issue was made an
unresolved item. As detailed in the CECO response to the inspection report,
two actions were taken. The first action was to modify the piping material
control and installation procedures to provide documentation of material
traceability verification at the point of installation. This action tends
to minimize the possibility of recurrence of traceability deficiencies. The
second action was to initiate the MTV program. The MTV program contains
the following basic elements:
1.
A material verification field walkdown on 100% of piping installed prior
to the procedure change.
2.
A Quality Control verification of the field verified heat numbers against
the heat numbers in the original stores request.
3.
A Quality Control verification to show that the installed items complied
with the design specification.
4.
A Quality Control review of the " stores request" for items which do not
have physical identification.
In addition to the concern related to material verification at point of
installation, there was a related concern dealing with specific examples of
failure to follow the applicable procedures in this area.
The MTV Program
was also structured to identify these items. . Also, the MTV Program was
independently reviewed and audited by the National Board of Boiler and
Pressure Vessel Inspectors National Board. The Illinois State Division of
Boiler and Pressure Vessel Safety also reviewed the program. Both
organizations found the program acceptable.
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Conclusions
Based upon the Region III inspections ~and the review of " Report on Material
Traceability Verification at Braidwood," dated November 1985, it is concluded
that:
1.
The MTV Program was sufficient to determine the traceability of the items
in question.
2.
The MTV procedures and work instructions were implemented properly.
3.
All items without the ASME Code required traceability have been removed
from the plant.
4.
A number of installed items did not comply with applicable CECO or PGCo
procedures.
5.
The original material control system delineated in the PGCo QA manual
met the requirements of the ASME Boiler and Pressure Vessel Code (ASME
6.
The physical and chemical tests performed on the items removed (due to
lack of traceability) from the plant demonstrate that in fact that the
mdterial installed was the correct material and could have performed its
safety function.
7.
Review of documentation indicates that all of the installed items could
have performed their respective safety function.
8.
All installed items now have the ASME B&PV Code required traceability;
therefore, concerns relative to future 10 CFR Part 21 notificaticas are
resolved.
It is concluded that Ceco has taken adequate corrective action co resolve
specific instances of failure to follow material control procedures. Also,
the results as delineated in the Ceco " Report on Material Traceability
Verification at Braidwood" demonstrate the extent and significance of
implementation deficiencies found in this area.
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TABLE 1
Braidwood Material Traceability Verification Program-
-Chronology of Activities
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April 1983-
PGCo, Audit 83-BR3 identifies findings related to
material traceability.
June 1983
NRC inspection begins; NRC inspectors identify
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deficiencies in material traceability.
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July 1983
CECO issues a 50.55(E) notification concerning
material traceability.
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March 1984
Enforcement Conference in Region III concerning
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. findings of inspection.
March 1984
NRC Inspection Report No. 50-456/83-09;
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50-457/83-09 issued.
~ February 1985
National Board Audit Team arrives at Braidwood site.
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-June 1985
D. Gallup, State of. Illinois, Superintendent of
Boiler and Pressure Vessel Safety, issues letter
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accepting MTV program.
June 1985
Public meeting held in Region III concerning Ceco's
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plans for MTV program.
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July 1985~
NRC review and inspection of MTV program starts.
September 1985
National Board Audit Team issues final report on MTV
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program.
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September 1985
NRC Inspection Report No. 50-456/85043; 50-457/85042
issued.
Inspection Report documents review of
" Stores Request."
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October 1985-
Taussig Association issues report on test results of
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" cut out" items.
November-1985
Ceco issues final report on MTV program.
November 1985
NRC Inspection Report No. 50-456/85050; 50-457/85048
issued.
Inspection Report documents independent
thickness measurements of a sample of installed MTV
items.
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,,_.____..__..,...,--,__--_--_._-._.-...._r,.,._-__.,--.-,.-
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December 1985
Region III met with NRC~IE and NRR personnel to
brief-them on.the MTV program and Region III
conclusions.
January 1986
Telephone conference with the Illinois State
Department of Nuclear Safety discussing the Region
III evaluation of the MTV program.
' January 1986
Region III MTV inspection exit interview at the
Braidwood site.
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DETAILS
1.
Persons Contacted
Commonwealth Edison Company (CECO)
- M. J. Wallace, Project Manager
- C. W. Schroeder, Licensing and Compliance Superintendent
.
- D. Shamblin, Project Construction Superintendent, Unit 1
- W. Vahle, Project Construction Superintendent, Unit 2
- D. Skoza, Mechanical Field Engineer
- Louis Kline, Supervisor, Licensing and Compliance Department
- P. L. Barnes, Licensing Engineer
- T. Quaka, Site QA Superintendent
- E. F. Fitzpatrick, Station Manager
G. E. Groth, Assistant Construction Superintendent
- M. R. Dougherty, Project Construction Engineer
- E. R. Wendorf, Project Field Engineer
- J. F. Phelan, Project Field Engineer
.
- J. K. Jasnosz, Regulatory Assurance Staff
- T. W. Simpkin, Technical Staff
- D. L. Cecchett, Licensing Engineer
- A. D. Miosi, Nuclear Licensing Administrator
- C. J. Tomashek, Startup Superintendent
- G. F. Marcus, Assistant to Quality Assurance Manager
- L. O. Del George, Assistant Vice President, Engineering and Licensing
Phillips Getschow Co. (PGCo)
J. R. Stewart, Project Engineer
The inspectors also contacted and interviewed other licensee and
contractor employees.
- Denotes those attending the final exit interview at the Braidwood
Station on January 9, 1986.
2.
Licensee Action on Previous Unresolved Items
(Closed) Unresolved Items (456/83-09-04(a); 457/83-09-04(a):
This item was
classified as unresolved until the completion of the MTV program.
This
report documents the NRC review of the pertinent issues and activities.
a.
ASME Code and Appendix B Traceability Requirements
The.ASME B&PV Code gives no detailed information either on the
specific nature of material control systems or on the type of
Quality Control inspections required.
Code,Section III, which directly addresses this issue states:
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"NA-4441 Establishment and Maintenance of Identification and Control
Measures:
Measures shall be established for identification and control of
material and items, including partially fabricated assemblies.
These measures shall assure that identification is maintained
either on the item or records traceable to the item throughout
manufacture or installation. These measures shall be designed
to prevent the use of incorrect or defective items, and items
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which have not received the required examinations, tests, or
inspections."
The language of NA-4441 closely parallels Criterion VIII of 10 CFR 50, Appendix B, which states, in part:
"These measures shall assure that identification of the item is
maintained by heat number, part number, serial number, or other
appropriate means, either on the item or on records traceable to
the item."
The intent of the material control system is to prevent the
installation of incorrect or defective items.
NA-4441 allows a
control system which utilizes records traceable to the item.
The
PGCo stores request system, as delineated in the QA manual, complied
with both the ASME B&PV Code,Section III, and 10 CFR 50, Appendix B, Criterion VIII, prior to identification of the unresolved item.
When properly applied, this material control system provided a
record traceable to the item as required.
The discrepancies in the
traceability of actual piping and piping components were the result
of failure to properly implement the stores request system.
b.
Review of MTV Procedures
Activities performed under the MTV program were controlled by two
procedures:
PGCo Procedure QCP-B31, Revision 4, " Material
Traceability Verification," and PGCo Work Instruction PGWI-17,
Revision 3, "QCT Review of MTV Program." The procedures contain
five major requirements as follows:
(1) 100% field walkdown for subject piping.
(2) All material identification marking recorded.
(3) Field gathered data compareo to stores request for item.
(4) Field gathered data compared to certified material test reports
(CMTR) for correct material specification, type, grade, class,
size, and schedule.
(5) Items found not traceable per stores request or otherwise
discrepant identified as nonconforming, and a nonconformance
report generated for each item.
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PGCo Procedure QCP-831 and Work Instruction PGWI-17 contain an
acceptable method for determining the traceability of installed
piping and piping components.
In addition, the NRC inspector reviewed PGCo Procedure QCP-B31.1,
Revision 1, " Untraceable Material Sampling Program." The purpose
of thi.* procedure is control of untraceable items and control and
storage of items removed from the plant.
This procedure provides
an acceptable method for controlling these activities.
c.
Nonconformance Board
The MTV program found 792 items to be in nonconformance with
applicable procedural requirements.
The disposition of these NCR's
were provided by consensus of a nonconformance board consisting of
representatives of CECO, Sargent and Lundy Engineers (S&L),
PGCo, the Authorized Ir.spection Agency (AIA), and generally a member
of the National Board Audit Team.
The NRC inspector attended the
disposition of a number of nonconforming items.
The NCRs discussed while the NRC inspector was in attendance are as
follows:
NCR 2301
NCR 2230
NCR 2183 (Item Removed)
NCR 2179
NCR 3595
NCR 3669
NCR 3729
The disposition of these NCRs was acceptable.
The NRC inspector independently reviewed the NCR package
i?sted below:
NCR 3720
NCR 3301
NCF. 3326
NCR 3161
NCR 3068
NCR 3046
NCR 3025
NCR 2320
NCR 4875
NCR 4573
NCR 46'J1
NCR 3496
NCR 3423
NCR 2985
NCR 4769 (Item Removed)
NCR 2814
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The information contained in the NCR packages complied-with procedure
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requirements and the dispositions of the individual items were
acceptable.
Of the 792 nonconforming items, it was determined that 647 items,
while in nonconformance with PGCo and Ceco procedural requiremerits,
were in compliance with the traceability requirements of the ASME
Code (Braidwood procedural traceability requirements. exceeded those
of the-ASME Code).
The remaining 145 items, listed below, were-
removed from the piping systems and replaced with traceable material:
NO.
NCR NO.
MTV ITEM NO.
DESCRIPTION
CLASS
1.
1742
MTV #2
2
Rad Access plug
CS7-1
2.
1742
MTV #3
2
Rad Access plug
CS7-1
3.
1742
MTV #1
2
3"-S/40S Pipe; 18" long
CS7-7
4.
1742
MTV #2
2
3"-S/40S Pipe; 5" long
CS7-7
5.
1742
MTV #7
2
3"-S/405 Pipe; 19" long
CS7-9
(Item Physically Tested)
6.
1831
2
Rad Access Plug
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CS7-2
7.
1871.
MTV #1
2
Rad Access Plug
CS23-7
8.
2071
MTC #2
3
4"-S/40 Pipe; 45" long
(Item Physically Tested)
9.
2073
MTV #3
2
3"-S/160 Pipe; l'0" long
IC-CV-25-4
10.
2085
MTV #2
3
2"-3000# SW 90 EL
2556A-71
11.
2089
MTV #33
3
1-1/4"-3000# SW 90 EL
2556A-35
12.
2089
MTV #34
3
1-1/4"-S/80 Pipe;
2556A-35
4-1/2" long
13.
2131
MTV #4
2
12'-6"X3/4"-3000#
Sockolet
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14.
2131
'MTV #5
2
3/4"-3000# SW Plug
15.
2133
MTV #8
3
6"-S/40 Pipe; 2" long
CC40-1
16.
2133
MTV #3
3
4"-S/40 Pipe; 6'-11" long
CC40-12
(Item Physically Tested)
17.
2176
2
3"-S/405 Pipe; 3" long
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18.
2177
2
Rad Access Plug
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CS-8-FW-5AP
19.
2177
2
Rad Access Plug
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CS-8-FW-4AP
20.
2183
MTV #A
2
3"-S/40 Pipe; 3'-1" long
IC-CC-41
(Item Physically Tested)
21.
2183-
MTV #8
2
3-S/40 Pipe; 4'-11" long
IC-CC-41
22.
2353
MTV #1
2
3/4"-S/80 Pipe 2" long
2544A-159
23.
2353
MTV #2
2
3/4"-S/80 Pipe 2" long
2544A-159
24.
2376
MTV #11
2
3"-S/405 Pipe; 4'6" long
(Item Physically Tested)
25.
2434
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2
Rad Access Plug
CS9-17
26.
2434
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2
Rad Access Plug
CS9-19
27.
2S05
MTV #9
3
2"X3/4" 6000# SW
2537C-32
Reducing Insert
28.
2511
MTV #2
2
3"-S/160 Pipe; 10" long
29.
2516
MTV #18
3
2"X3/4" 6000# SW
2537C-39
Reducing Insert
30.
2785
MTV #2
1
Rad Access Plug
RH-8-2
31.
2785
MTV #3
1
Rad Access Plug
RH-8-3
10
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32.
2785
MTV #2
1
Rad Access Plug
RH-8-5
33.
2813
MTV #2
1
3"-S/160 Pipe; 4" long
CV-10-4B
34.
2813
MTV-#1
2
3"-S/160 Pipe; 4" long
CV-10-4D
35.
2828
MTV #12
3
2"-3000# SW45 EL
2556A-72
36.
2873
MTV #1
2
3/4"-S/160 Pipe;
2539C-84
5'3"long
37.
2873'
MTV #3
2
3/4"-5/160 Pipe;
2539C-84
l'9"long
38.
2873
MTV #5
2
3/4"-S/160 Pipe;
2539C-84
10'7"long
39.
2873
MTV #7
2
3/4"-5/160 Pipe;
2539C-84
4'6"long
(Item P5ysically Tested)
40.
2873
MTV #9
2
.3/4"-S/160 Pipe;
2539C-84
l'1" long
41.
2875-
MTV #7
3
2" 3000# SW 90 EL
(FW 7&8)
42.
2875
MTV #14
3
2"-3000# SW 90 EL
(FW 15&l6)
43.
2902
MTV #3
3
3/4"-S/80 Pipe; 18" long
(FW 3&4)
44.
2917
MTV #23
3
2"-3000# SW 90 EL
(FW 20A&21A)
45.
2919
MTV #8
2
3"-S/405 Pipe;
11-1/2" long
46,
2919
MTV #9
2
3"-5/40S Pipe;
14-1/2" long
47.
2919
MTV #10
2
3"-S/40S Pipe;
2" long
48.
2919
MTV #13
2
3"S/40S Pipe; 11" long
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49.
2919
MTV #13
2
3"-S/40S Pipe; 39" long
50.
2919
MTV-#14
2
3"-S/40S Pipe;
3-1/2" long
51.
2919
MTV #15
2
3"-S/40S Pipe;
2"&24" long
52.
2930'
MTV #1
3
3"-S/40S' Pipe;
8-13/16" long
53.
2953
MTV #1
3
3/4"-S/80 Pipe 5" long
2546A-79
54.
2973
MTV #13
3
2"-S/80 Pipe; 3" long
(FW16&l7)
55.
2973
MTV #47
3
2"-S/80 Pipe; 1" long
(FW35&36)
56.
2984
MTV #3
3
Ring & Bar lug
57.
2990
MTV #6
2
Rad Access Plug
58.
2993
MTV-#5
3
3/4"-S/80 Pipe 4" long
2537A-65
59.
2993
MTV-#19
3
3/4"-S/80 Pipe 4" long.
2537A-65
60.
3027
MTV #9
2
3/4"-S/160 Pipe; 2" long
2546C-61
61.
3027
MTV #15
2
3/4"-S/160 Pipe; 2" long
2546C-61.
_,.
62.
3126
MTV #5
2
3"-S/40(S) Pipe;
10-3/4" long
63.
3165
MTV #12
3
4"-S/40 Pipe; 2'3" long
CC-11-5
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64.
3166
MTV #5
2
2 Plates, 2"X6" Welded
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Attachment
65.
3215
MTV #5
2
Rad Access Plug
IC-FW-14-7
66.
3216
MTV #7
2
3/4"-6000# Coupling
PG-2539C-75
12
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67.
_3221
MTV #4-
3
Nailer Ring (SA240)
OA-FC-3AB
Welded Attachment
68.
3226
MTV #1
2
6"-S/80 Pipe; 12"~1ong-
FW38-1
(Item Physically Tested)
69.
3275
MTV #2
2
Rad Access Plug
RH-2
70.
3291
MTV #1
2
24"-S/40S Pipe;
SI43-2
l'-6" long
(Item Physically Tested)
71.
13300
MTV #2
2
Rad Access Plug
72.
3318
MTV #3
3
5"-3"X3/4" 3000# SOL
CV4-5'
'
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73.
3327
MTV #6
3
4"-S/40 Pipe; l'0" long
(FP-33-11)
74.
3327
PfR/ #7
3
4"-S/40 Pipe; 6" long
(FP-33-9)
75.
3334
MTV #1
3
1"S/80 Pipe; l'-0" long
(FW-15)
76.
3334
MTV #19
3
1"-S/80 Pipe; 4" long
(FW-12)
77.
3335
MTV #2
3
4"-S/40 Pipe; 6'6" long
78.
3343
MTV #1
2
4"-S/160 Pipe; 8" long
79.
3350
MTV #13
3
2"-S/40 Pipe; 40" long
2537A-104
80.
3350
MTV #11
3
2"-S/40 Pipe;
2537A-104
10-1/2" long
81.'
3365
MTV #25
3
1"-S/80 Pipe; l' long
(FW34&35)
82.
3365
MTV #27
3
1"-S/80 Pipe; l' long
(FW 36&37)
83.
3322
MTV #6
3
6"-S/120 Pipe; 5'4" long
(Item Physically Tested)
13
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84.
3422
MTV #1
3
6"-S/120 Pipe; l'1" long
85.
3422
MTV #2
3
6"-S/120 Pipe; 10" long
86.
3432
MTV #2
1
Rad Access Plug
RC-16-5
87.
3432
MTV #3
1
Rad Access Plug
RC-16-5
88.
3433
MTV #17
3
6"-S/40 Pipe; l'6" long
(Item Physica11y' Tested)
89.
3458
MTV #2
3
Welded attachment lug for
AF-16-2
2AF01028R
(Item Physically Tested)
90.
3465
MTV #1
3
3"-S/40S Pipe; 6" long
CV-7-6
91.
3470
MTV #9
3
4'-S/40 Pipe; 6" long
92.
3474
MTV #2
3
18"0D S/40 Stanchion
ISX02061X
f
93.
3474
MTV #3
3
18"0D S/40 Stanchion
ISX02061X
94.
3476
MTV #2
1
Rad Access Plug
95.
3487
MTV #2
2
3"-S/160 Pipe; 5" long
'-
CV-2-12
96.
3488
MTV #1.
3
4"-S/40 Pipe; 4'-6" long
CC-29-5
97.
3492
MTV #1
2
3/4"-S/40S Pipe; 3" long
2535A-38
98.
3518
MTV #3
2
1/2" closure plate
CV33-5
99.
3520
MTV #3
3
2"-3000# 90 EL
2556A-50A
100.
3553
MTV #18
3
2"-3000# 45 EL
2556A-71
101.
3594
MTV #8
3
1-1/2"-300# Flange
2537A-50A
14
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.
.
102.
3594
MTV #10
3
1-1/2"-300# Flange
2537A-50A
103.
3594
MTV #11
3
1-1/2"-S/80 Pipe;
'2537A-50A
7-1/2"long
104.
3992
MTV #25
2
1/2"-S/160 Pipe; 6" long
,
IFT-444-2
105.
4022
MTV #1
3
3"-S/40 Pipe; 5" long
106.
4032
MTV #6
3
4"-S/40 Pipe; 3-3/8" long
107.
4055
MTV #4
2
3"-S/160 pipe;
7'-10" long
108.
4079
MTV #1
3
4"-S/40 Pipe; 10" long
(Item Physically Tested)
109.
4100-
MTV #1
2
10"-S/40 Pipe; 10" long
IC-SX-74-1
110.-
4294
MTV'#19
3
2"-3000# - 90 EL
-2537C-12
111.
4527
MTV #55
2
1"-S/160 Pipe;
2539A-29
l'-10" long
(Item Physically Tested)
112.
4587
MTV #2
3
36"-12"X1"-3000#
Sockolet
113.
4589
MTV #1
3
2"-S/40S Pipe;
29549A-28
l'-10" long
114.
'4605
MTV #1
2
14"-S/STD Pipe
l'7" long'
(Item Physically Tested)
115.
4756
MTV #12
2
2"-S/40S Pipe;
2546A-5 Item 90
5'-2" long
116.
4756
MTV #4
2
3"-5/40S Pipe; 9" long
1A-CV-37' Item 8
,
117.
4756
MTV #1
2
1"-S/40S Pipe;
2539C-44 Item 128
6-1/2" long
118.
4756
MTV #3
2
1"-S/40S Pipe;
2539C-44 Item 73
6'-4" long
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119.
4756
MTV #5
2
1"-S/40S Pipe; 12' long
2539C-44 Item 74
120.
4756
MTV #7
2
1"-S/40S Pipe;
-
2539C-44 Item 75
12'5" long
121,
4756-
MTV #2
2
1"-S/40S Pipe; 4' long
i
2539C-89 Item 76
122.
4756
MTV #2
2
1"-S/40S Pipe; 4' long
2539C-39 Item 127
123.
4756
MTV #9
1
2"-S/160 Pipe; 3'9" long
2546C-25 Item 68
(Item Physically Tested)
124.
4756
MTV #1
2
2"-S/40S Pipe;
2546A-46 Item 109
5-5/8" long
'
125.
4756
MTV #3
2
2"-S/405 Pipe;
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2546A-46 Item 110
10-5/8" long
i
126.
4756
MTV #5
2
2"-S/40S Pipe;
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2546A-46 Item 111
11-1/2" long
127.
4756
MTV #7
2
2"-5/40S Pipe;
2546A-46 Item 112
10-3/4" long
128.
4756
MTV #8
2
2"-S/40S Pipe; 4" long
.
2f46A-46 Iteni 93
129.
4756
MTV #12
2
3/4"-S40S Pipe; 3" long
2546A-88 Item 95
130.
4769
MTV #2
2
5"-3"X3/4" - 3000# SOL
,
,
1
131,
4824
MTV #21
3
3/4"-S/40S Pipe;
2546A-2
15'10" long
(Item Physically Tested)
,
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132.-
4824
MTV #1
3
3/4"-S/40S Pipe;.4" long
,
2546A-2
'
133,
4824
MTV #9
3
3/4"-S/40S Pipe; 5" long
2546A-2
134,
4824
MTV #11
3
3/4"-S/40S Pipe; 5".long
2546A-2
135.
4824
MTV #13
3
3/4"-S/40S Pipe;
2546A-2
9'11"long
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136.
4824
MTV #15
3
3/4-S/40S Pipe;
2546A-2
10-1/2" long
137,
4824
MTV #17
3
3/4"-S/40S Pipe;
2546A-2
4'10" long
138.
4824
MTV #19
3
3/4"S/40S Pipe;
2546A-2
9-3/4" long
1J9.
4824
MTV #23
3
3/4"S/40S Pipe;
2546A-2
l'11-1/4" long
140.
4873
MTV #1
3
'3/4"-S/40S Pipe; 1" long
2549A-16
141.
4973
MTV #6
1
Rad Access Plug
RH14-2
142.
5226
MTV #3
2
2"-S/40S Pipe; 12" long
2546A-92
143.
5226
MTV #22
2
2"-S/40S Pipe;
2546A-92
14-3/4" long
144.
5364
M1V #5
3
4"-S/160 Pipe;
CC12-1
13'2" long
145.
5490
MTV #1
2
10"-S/40S Pipe; 11" long
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d.
Stores Request Review
One of the original concerns relative to piping material was the
viability of the PGCo " stores request" system as an effective
material control system.
To further develop assurance concerning
the implementation of the system, the NRC inspector performed a
detailed review on the documentation associated with 30 items whose
traceability was established by the " stores request" document per
the original procedure.
The details of this inspection are contained
in NRC Inspection Report No. 50-456/85043; 50-457/85042.
Summarizing
the results, "None of the documents reviewed contradicted the
licensee's conclusions and in a majority of cases, independent
information, other than the stores request was on file in the
documentation packages which supported the licensee's conclusion."
Members of the National Board Audit Team reviewed documentation
associated with 50 installed items whose traceability was established
based on stores request documents only.
The results of their review
are contained in the National Board Supplementary Report dated
September 26, 1985, and addressed to Cordell Reed, Vice President,
Ceco (" Material Traceability Verification at Braidwood", November
1985, Appendix A), and states "The audit confirmed the integrity of
the stores request system."
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.e.
Thickness Measurement of Installed Items
As discussed in NRC Inspection Report No. 50-456/85050; 50-457/85048,
' independent thickness measurements, using an ultrasonic digital
thickness measuring device, were taken on six piping systems which
contained MTV items. These measurements were taken to confirm that
the schedule of the installed piping (wall thickness) complied with-
the design specification and agreed with the information used in the
MTV program. Measurements were taken on portions of the following
piping systems:
ID004AB'- Diesel Fuel Oil
ICCD9AB - Component Cooling Water
ICC97AB - Component Cooling Water
ISX17AB - Essential Cooling Water
ICCD8AB - Component Cooling Water
ID063A - Diesel Fuel Oil
All'of the measurements taken confirmed the schedule of the installed
'
piping and also confirmed the acceptability of the information that
was developed by CECO.
In addition, the independent measurements
closely agreed with the measurements taken by CECO.
f.
Selection of Samples
At a point in time near the completion of the MTV, CECO decided to
perform tests on the piping removed from the plant due to lack of
traceability. The purpose of these tests was to-demonstrate that
the untraceable material was in fact, the correct material and
therefore the lack of traceability did not impact the ability of
the affected s
All of the' items which
H
were removed (ystems to function properly.except for 3 items mistakenly los
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subjected to an analysis which determined the chemical composition
of the material.' Sixteen of the removed items were subjected to
physical tests which demonstrated that they conformed to the
strength requirements of the applicable specification. Two
considerations determined which items were appropriate for physical
tests. The'first consideration was size; approximately 90 of the
removed items were too small for physical testing. The second
consideration was'the' presence of manufacturers' markings. Approxi-
mately 30 items, with clear manufacturers' marks identifying mate' rial
type, did not have the same degree of uncertainty associated with
their physical properties, and therefore were not appropriate for
physical testing.
The group of items tested contained both carbon steel and stainless
steel and both large bore items and small bore items.
In addition,
the only untraceable section of piping'in an ASME Class I system us
tested (NCR 4756 Item 68). A portion of the testing was witnessed by
a NRC inspector.
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All of the items subjected to the chemical testing conformed to the
applicable ASME/ ASTM specifications.
All of the items subjected to
the physical testing for strength conformed to the applicable
ASME/ ASTM specification.
The final report produced by Taussig Associates, Report No. 64188-1,
" Chemical and Tension Testing of Samples Associated with the MTV
Program," was reviewed.
A number of the chemical composition results
were reviewed by the NRC inspector for compliance with ASME B&PV
Code requirements for chemical composition.
A number of the
physical (strength) results were also reviewed by the NRC inspector
for compliance with ASME B&PV Code requirements for strength. ~All
results demonstrated compliance with applicable code strength and
composition requirements.
g.
Review of Reports
As part of the inspections associated with the MTV program, CECO's
Report " Material Traceability verification at Braidwood," the National
Board's letter of September 26, 1985,.and the Office of the Illinois
State Fire Marshall, Division of Boiler and Pressure Vessel Safety
letter of June 21, 1985,.were reviewed.
Based on the NRC inspections
of the MTV program and the review of the Ceco's final ~ report, it has
been determined that the CECO final report is an accurate representation
of the activities conducted and their results.
In addition, our
review of the National Board activities and our review of their letter
supports the National Board's general conclusions:
"The Phillips, Getschow quality assurance program, as written,
did provide the necessary controls to assure that the work
performed by PGCo at the CECO Braidwood Nuclear Power Station
,
met the requirements of the ASME Code and the certified design
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specification."
"As noted previously in the report, there were implementation
deviations from the PGCo quality assurance program's requirements."
"These deviations led to the generation of the MTV program and
the resulting revisions to the PGCo quality assurance program
and material control procedures."
Duane R. Gallup, Superintendent of Boiler and Pres 9ure Vessel
i
Safety for the State of Illinois, suuported the MTV program in his
June 21, 1985 letter.
Quoting the letter,
"I am satisfied that the corrective action program which
Commonwealth Edison Company (CECO) has undertaken will result
in assuring the piping systems at the Braidwood site will be
in compliance with the requirements of the ASME Code."
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h.
Safety Significance Evaluation
As part of the overall MTV program, a " safety significance"
evaluation, composed of calculations necessary to demonstrate
compliance with ASME B&PV Code strength requirements, was performed
for all the items which were nonconforming due to insufficient
traceability. A random sample of these noncomforming item
evaluations (listed below) was reviewed in detail:
NCR 2085
NCR 2183
NCR 2785
NCR 2873
NCR 2919
NCR 3027
NCR 3291
NCR 3350
NCR 3465
NCR 3553
NCR 4294
NCR 4756
NCR 4769
NCR 4873
NCR 5490
In addition, the Sargent and Lundy Report BRF-PMD-01 (November 13,
1985), " Design Significance Evaluation of Braidwood Material
Traceability Verification (MTV) Program Cut Out Items" was reviewed.
This report and the. disposition of these NCRs were acceptable.
~
In NRC Inspectio'n Report No. 50-456/83-09; 50-457/83-09, two items
were identified which did not have the required schedule of piping
installed.
Because these items were replaced prior to the
initiation of the formal MTV program they were not included as
items in the MTV. program final report.
Safety significance
evaluations were performed which found that the installed items
could have performed their safety function in compliance with the
The evaluations were reviewed and found acceptable.
i.
. Inspection Conclusions
Based on the NRC inspections and reviews of the MTV program, the
following conclusions have been reached:
(1) The original material control system ~ contained in the PGCo QA
manual complied with the requirements of the ASME B&PV Code.
(2) There were a number of instances in which the proper procedures
were not followed.
These are the 792 items identified in the
CECO final report as nonconforming.
This is the basis for a
violation of 10 CFR 50 Appendix B, Criterion V. (456/85061-01;
456/85057-01).
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(3) The specific instances of failure to follow procedures did not
appear to impact the ability of the systems to perform their
safety function.
(4) The MTV program was an effective method to determine the
traceability of the items in question.
(5) The MTV program was conducted in accordance with applicable
procedures.
(6) 145 Items lacking the required traceability have been removed
from the plant and replaced with items which have the required
traceability.
(7) It now appears, based on the results-of the MTV program,' that
the Material Control System originally employed by PGCo was
effective to the extent that no items were installed which
would have impacted the ability of the piping systems to
function properly.
3.
Exit Interview
The Region III inspectors met with licensee representatives (denoted under
Paragraph 1) at the conclusion of the inspection on January 9, 1986. The
inspectors summarized the scope and findings of the inspection. The
licensee acknowledged this information.
The inspector also discussed the
likely informational content of the inspection report with regard to
documents or processes reviewed during the inspection.
The licensee did
not identify any such documents / processes as proprietary.
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