ML20205M836
| ML20205M836 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/11/1986 |
| From: | Oconnor T COMMONWEALTH EDISON CO., PHILLIPS, GETSCHOW CO. |
| To: | |
| Shared Package | |
| ML20205M802 | List: |
| References | |
| OL, NUDOCS 8604150396 | |
| Download: ML20205M836 (31) | |
Text
9
, oEt ATED CORRESPONUt "W April 11, 1986
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSzgf .4m u BEFORE THE ATOMIC SAFETY AND LICENSING BOARDP2,.7g r-
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In the Matter of ) #C J'
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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
TESTIMONY OF THOMAS G. O'CONNOR ,
(ON ROREM Q.A. SUBCONTENTION 10.B) ]
(Material Traceability) !
Q.l. Please state your full name for the record.
J A.l. Thomas G. O'Connor.
I 0.2. Who is your employer and what is your occupation?
I am employed by the Phillips, Getschow Company (PGCo) as
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A.2.
Site Manager for Commonwealth Edison Company's (CECO 's)
Braidwood Project. I am responsible for supervising those ,
activities within the scope of PGCo's work at the site.
O.3. Please state your professional work experience.
A.3. I have approximately 30 years of experience as a pipefitter, craft supervisor and manager in the field of mechanical construction activities. At least 16 of those years involved employment by mechanical contractors as a supervisor or manager at nuclear projects.
i 8604150396 PDR 860411 ADOCK 05000456 PDR
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I began my career with a five year pipefitter apprentice-ship in 1956, two years after graduating high school. I then worked as a journeyman pipefitter and supervisor of pipefitters on various construction jobs until 1968, when I joined the Pope-Morrison Companies. My assignment was as the Area Supervisor for the Reactor Containment Buildings during the construction of CECO's Zion Nuclear Power Station, Units 1 and 2. In that capacity, I super- 1 vised pipefitters in the installation of piping, pipe supports and restraints and equipment in the Units 1 and 2 l
Reactor Containment Buildings.
I was hired by Morrison Construction Company in 1974 as a ,
i Construction Superintendent. In that capacity, I was assigned to various piping-related jobs in a refinery,-
steel mill, gas extraction plant and food processing plant. In addition, I was assigned to Morrison's corporate office as a member of a team assigned to !
formulate a quality assurance program for ASME Section III ;
construction. Based on my Zion installation experience, I drafted procedures and installation checklists for piping installations for Morrison's Corporate Quality Assurance i Manager.
In 1975, I was assigned to CECO's LaSalle Nuclear Power Station, Units 1 and 2, as Morrison's General Project
, s Superintendent. Morrison was the main mechanical contractor on the construction of the LaSalle project. In that capacity, I supervised all field activities (except quality control inspection) for Morrison. This included general supervisory responsibility for Morrison's installation program for safety-related small bore and large bore piping. In April 1983, I was assigned as the Morrison Project Manager at LaSalle. In addition to the responsibilities of the General Project Superintendent, I assumed the responsibility for management of the engineering and welding departments as well as the payroll and accounting functions. In August 1983, I went to Braidwood as the Site Manager for Phillips, Getschow Company.
Q.4. What are your responsibilities with respect to the Braidwood Project?
A.4. As Site Manager, I am responsible for managing the site activities of PGCo, except for quality assurance and quality control activities necessary to the construction and installation of the mechanical systems for the Braidwood Project. PGCo installs, among other things, the various safety-related piping systems, so-called "ASME Section III construction." My responsibilities include working with PGCo's Quality Assurance and Quality Control Departments to formulate and implement various corrective ;
1 action-programs, such as the Material Traceability Verification Program (MTV Program).
Q.5. What is the purpose of your testimony?
A.S. My testimony addresses certain aspects of the MTV Program carried out by PGCo in conjunction with CECO. The MTV Program was conducted in response to questions raised by the NRC and reported in Inspection Report 83-09 concerning the traceability and acceptability of certain PGCo piping installations at Braidwood. This issue is the subject of Intervenors' subcontention 10B. The NRC's questions arose from the structure and implementation of the material traceability and control system, called the " Material Stores Request System," used by PGCo up to September 1983.
My testimony describes the Material Stores Request System, the planning and development of the MTV Program, the examination and review activities conducted thereunder and the process by which it was determined whether the examined piping items were traceable and acceptable as required by the ASME Code.
Q.6. What does the term " piping items" mean as used in your testimony?
A.6. The term " piping items" means single pieces of pipe, that is, pipe sections or fittings, unmodified pipe spools l
located between two PGCo welds, or integral attachments, that is, material welded to the piping pressure boundary to provide support or attachment capability. A fitting is a connection to a pipe section such as an elbow, flange, tee, or coupling. A spool is a welded piping assembly containing sections of pipe and fittings prefabricated to a specified design configuration. Spools are generally prefabricated off-site.
Q.7. Please describe the Material Stores Request System used by PGCo during the period of time covered by the MTV Program.
A.7. The period of time covered by the MTV Program begins in June 1976 with the first installation of large bore piping material and it ends on September 6, 1983. The latter date is the date when the procedures for QC verification of both installed small and large bore piping systems were effectively in place. Despite a number of revisions to the PGCo Quality Assurance Manual over this 7 year period, i the Material Stores Request System characterized in the Manual remained substantially unchanged.
The principal provisions of the Quality Assurance Manual that comprise the Material Stores Request System are l Sections 8.3 - " Release of Items to Construction," and 5.3.6. - " Installation." The steps of this process are i
depicted on Figure 1, which is attached to my testimony as Attachment 10.B. (O'Connor-1).
As shown on Figure 1, the Material Stores Request System consists of the following steps to assure material traceability and control:
- 1. The Superintendent, using an S&L installation drawing, or Rework Sketch, as appropriate, initiates the material Stores Request, Form PG-109-8, listing drawing number, ASME Code Class, component identification number or, for bulk material, the requested material j
type, grade, diameter, schedule and quantity.
- 2. The Stores Request is then reviewed by the Field Engineer against the installation drawing to assure that correct material for the application has been requested and that correct material is available in i on-site inventory and is acceptable for release.
- 3. The Quality Control Supervisor reviews and approves the Stores Request for completeness.
- 4. The Superintendent then presents the Stores Request to
, the Warehouseman for material release. l f
1
- 5. As material is released for installation, the Warehouseman records the material heat number for the material (or Material Receiving Report number for stamped items) on the Stores Request. A copy (yellow) of the Stores Request is retained on file at the warehouse; one copy (pink) is sent to Field Engineering for inventory control; one copy (white) is sent to the Quality control office; and after March 1979, one copy (blue) is included in the traveler package for field fabrication or installation, as applicable. The blue copy of the Stores Request is retained by the Superintendent in the field office.
- 6. The Stores Request copy sent do the QC office is reviewed against documentation containing a oescription of the requested material's origin and characteristics, l such as Certified Material Test Resports (CMTRs), or the acceptable material log -- the MT/PQ Log to verify ,
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that an acceptable material heat number has been l l
issued. This copy is retained in the QC office until the traveler package is returned to the QC office after I field fabrication or installation, as applicable.
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- 7. The Superintendent, using the traveler package, including the installation drawing and Field Fabrication Process and Data Sheets, performs field i
fabrication or installation of the material, as applicable. The Supervisor of Quality Control records the acceptable material heat number on the installation drawing or on the FFP&Ds. (After December 14, 1982, the Superintendent performed this function.) The traveler package is then returned to the QC office where it is compared with the QC office copy of the Stores Request.
- 8. The traveler package and QC office Stores Request are then stored together in the QC vault until they are needed to develop "as-constructed" drawings which are ultimately used during the ASME Code N-5 Review.
J.8. When did PGCo's involvement in the MTV Program begin?
A.8. In January 1984, when CECO directed PGCo to conduct the MTV Program. The Program consisted of a 100%
reverification of the small bore and large bore piping materials installed at Braidwood prior to September 6, 1983 and January 1, 1983.
Q.9. What action did you take in response to CECO's direction?
A.9. I took several actions. However, the first and most important step was to assure that CECO and PGCo had a mutual understanding with respect to the scope and a
developmeat of the MTV Program. I met on a number of occasions for this purpose with Mr. Groth, who was at that time CECO's Lead Mechanical Engineer in the Project Construction Department at Braidwood.
Q.10. Please describe the scope of the MTV Program that evolved from your discussions with CECO.
A.10. The MTV Program was structured to include reverification of all small bore piping items installed prior to September 6, 1983 and alllarge bore piping items installed prior to January 1, 1983. The only exception was the 514 piping itpms that were installed prior to September 6', 1983 in the Containment Spray System for Unit 2. The reason for excluding these items from the ,
MTV Program is explained in Mr. DelGeorge's testimony.
Those piping items includdd in the Program were required 1
tobeexaminedandthesupportingdocumentatponwas required to be examined to verify the existence of 1
material traceability and that the correct piping items had been installed.,
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, 3 0.11. Why were the dates indicated in A.9. used as the ending dates for the MTV verification effort?
\
A.11. The 100% reverification under the MTV Program was ,
p performed for all small bore and large bore piping items
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installed prior to the modification of PGCo's small bore and large bore installation requirements to add a documented quality control verification of traceability and acceptability at the point of material installation.
These changes were implemented in late June 1983 through a revision to PGCo's small bore piping installation procedure, QCP-B21; and in December 1982, for large bore piping, through a revision to the large bore piping installation Field Fabrication Process and Data Sheet attached to PGCo's QA Manual. The end dates indicated in A.9. were arbitrarily selected to assure that all piping items were either installed under the QC verification requirements of the revised requirements or included as part of the MTV Program reverification effort.
Q.12. What action, if any, did you take towards developing the MTV Program once you achieved a mutual understanding on the scope of the Program?
A.12. I assembled a PGCo working group. The primary task of the working group was to write a procedure and checklists to establish a controlled method for verifying the traceability and acceptability of piping items within the MTV Program scope.
Q.13. Who participated in the PGCo working group?
A.13. The working group included myself; Joe Hamilton, my administrative assistant; Jim Stewart, the PGCo Project Engineer for Braidwood; Jack Carlson, PGCo's Quality Control Supervisor for Braidwood and Len Butler, a member of my Project management staff.
Q.14. What was the basis for the selection of these individuals? I A.14. The formulation and implementation of the reverification efforts under the MTV program required engineering expertise for developing checklists and addressing the different types of piping installations encompassed by the program scope. Quality control expertise was required for performing and documenting reverification examinations and for reviewing and evaluating the collected data. The individuals selected to participate in the PGCo working group were selected based on their extensive experience and expertise in these areas.
Joe Hamilton had previously been the Project Manager for Morrison, the main mechanical contractor at the LaSalle Project. Jim Stewart was the Project Engineer for Morrison at LaSalle. Both men have substantial engineering experience in installing ASME Section III piping systems. Jack Carlson, the Quality Control Supervisor at Braidwood, was experienced in implementing 1
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PGCo's overall Braidwood Quality Control program. Len Butler served first as the Assistant Project Engineer and subsequently as the Assistant Quality Control Supervisor for Morrison at LaSalle and, as such, had extensive experience in both engineering and QC.
Q.15. Did the working group develop a procedure and checklist?
A.15. Yes, a procedure and checklists were prepared and they were reviewed and approved by PGCo and CECO. The Procedure was also reviewed and accepted by Sargent &
Lundy and the Authorized Nuclear Inspector. The Procedure, designated QCP-B31 and entitled " Material Traceability Verification," was issued for use on March 15, 1984.
Q.16. Please describe the principal elements of Procedure QCP-B31.
A.16. The Procedure provided the controlled method for (a) identifying the piping installations encompassed by the MTV Program, (b) developing the "MTV Package," which included the checklists and other documents needed to support data-gathering activities, (c) performing field examinations.to collect material traceability data on installations covered by the Program, (d) conducting documentation reviews of field results to demonstrate
material traceability and installation of acceptable items, and (e) developing a document, called the "MTV Log" which was used to record the Program data as it was developed by the individuals assigned to the Program.
Q.17. How were the installed piping items that were intended to be covered by the MTV Program identified?
A.17. I believe my answer must include a brief description of the piping installation process because it will be helpful in understanding this subject.
As a prelude to piping installation, PGCo's Engineering l
Department developed an installation traveler package for each piping isometric drawing. The traveler package contained many of the same documents that were later included in the MTV packages. The traveler packages were listed by the Engineering Department in a drawing control log by the date they were issued to the field.
As piping installation proceeded, each installation activity was documented on a process control record.
First, a weld rod withdrawal slip documented the date of weld rod issue by weld and drawing number. As each weld was completed, its inspection and final acceptance was recorded and dated on a Field Fabrication Process and Data
-Sheet for large bore piping and for small bore piping on a
i weld data traveler which was stamped on the installation drawing.
Upon completion of the installation as defined by a single installation drawing, the traveler package, including weld rod withdrawal slips, Field Fabrication Process and Data Sheets and the completed installation drawing was returned to the Quality Control Department where the information contained in these documents was set forth in the weld control and status log designated as BB-01.
To determine the piping installations covered by the MTV Program, the PGCo Engineering Department first j
l reviewed the drawing control log to identify the traveler packages that had been issued for piping item installations within the time frame of the Program. The weld control status log was then examined to obtain the weld completion dates for the piping items covered by the traveler packages. The installation dates of the piping systems included in the MTV Program are established by determining the dates the welds were made that connected the system components.
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In the event the weld control status log had not yet been completed for an installation drawing, the traveler package was examined directly for the installation dates l
of the welds for the piping system represented-in the drawing to determine if any welds had been completed within the time frame specified for the MTV Program. If-this was the case, all items shown on the installation drawing were included in the MTV Program.
If the traveler package for an installation drawing had not been returned to the QC office, weld rod withdrawal slips for welds listed on the installation drawing were ;
examined to determine whether weld rod had been issued for
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the welds within the MTV time frame. If the dates on the weld rod withdrawal slips fell within the MTV time frame, a field check was made to determine if any of the welds were completed within the MTV time frame. If this was the case, all of the items shown on the installation drawing were included in the MTV Program.
As added corroboration, individual piping items were reassessed to determine whether they either fell within or outside of the MTV time frame following completion of the MTV field reviews. This assessment was performed by PGCo QC technicians during the office review of field verification results by confirming, on a weld-by-weld basis, the accuracy of weld inspection dates for the items reverified by the MTV field examiner and recorded-in the MTV data package.
- Q.18. Were any of the piping items covered by the MTV Program inaccessible?
A.18. Yes.
Q.19. How were inaccessible piping items addressed in the MTV Program?
A.19. The MTV Program included 900 items that were inaccessible because generally they were either buried underground or embedded in concrete. These items were evaluated based on the adequacy of the Stores Request documentation only.
All but 36 of these items were determined to have adequate traceability documentation. NCRs were written for the 36 items. Because material traceability may be achieved by either documentation traceable to the item or markings on the item itself, these NCRs may have been unnecessary since no effort was made to ascertain whether the inaccessible piping items were marked.
Q.20. What is the purpose of the MTV data package? l A.20. The MTV data package, which should not be confused with reference to " traveler package" in A.17., was developed by the PGCo Engineering Department. It consisted of all documentation necessary to perform the required field data !
l gathering activities and subsequent QC documentation i reviews. The data package was used to track the status of l
the piping item to which it applied throughout the course of the reverification process.
Q . 21. - What documents are contained in the MTV data package?
A.21. The MTV data package contains various documents needed to verify material traceability. The documents common to both large and small bore piping are isometric drawings, checklists, MTV logs and an MTV data package index/ routing 1 traveler. In addition, the MTV data package for large
, bore piping contained PGCo rework sketches and integral attachment drawings, when applicable.
Q.22. Please describe each of the documents included in the MTV l data package and its purpose.
i A.22. I will describe the documents in the order identified in A.21.
i Isometric Drawings. An isometric drawing depicts the installed piping system that is to be verified for material traceability and acceptability. It is used by the field personnel to locate the installed piping systems. The isometric drawings are reproductions of the
< applicable design or installation drawing. However, the PGCo Engineering Department identified each pipe item or l 1
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I 1
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- spool earmarked for verification by imprinting unique .
l symbols.on the isometric drawings.
l j Checklists. Three types of checklists were developed for use in the MTV Program, one for small bore and two for large bore piping items. One large bore piping checklist covered unaltered piping spools and the other checklist
. was for spools that were altered by PGCo during installa-tion or that were field-fabricated by.PGCo. The only i
significant difference between the two checklists was that l the altered spool checklist provided'more room for
- recording additional information which might have resulted J
from the spool modification.
3 MTV Log. -The MTV log, initiated by the Project Engineer, j
contained a separate entry with a unique identification 1
number for each piping item identified on the isometric l drawing and any supplemental drawings in the MTV data i
i package. There was a description of the item for each j entry. Upon completion of the field examination, the QC i
4 office technician entered all. field verified information i
onto the log. The technician also entered data on the log from the Stores Request and any material traceability i entries on the isometric drawing that had been QC verified _
i l at the time of installation. The QC technician then
! evaluated this data for. material traceability and i
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, _ . _ . . . . - _ . ~
acceptability and recorded the results of this evaluation on the MTV log sheet.
Index/ Routing Traveler. This document contained an index of all of the documents in the MTV package. As the MTV data package progressed through the Program cycle, the index/ routing traveler was signed and dated by the person performing the activity to document the completion of engineering preparation, initial QC review, field QC review, field QC verification, final office QC review and ,
1 data entry onto the MTV log. There is also a space l provided on the form for remarks.
Q.23. Who conducted the field examinations?
A.23. Field examinations were conducted by PGCo Level II Quality Control inspectors under the supervision of the PGCo l
Quality Control Supervisor. l Q.24. Did the inspectors receive any training?
A.24. Yes. All MTV inspectors were given classroom training which consisted of: training in the MTV Procedure, QCP-B31; training in the performance of visual inspections, PGCo Procedure VE-Ol;-training in the performance of digital thickness measurements, PGCo Procedure QCP-B16; training in large bore and small bore
l piping installation inspections, PGCo Procedures QCP-B28 and QCP-B21; training in material control, PGCo Procedure QCP-B4; training in equipment calibration, PGCo Procedure QCP-B33; and training in quality control monitoring, PGCo Procedure QCP-B27.
The duration of the classroom training varied with the
- inspector's qualifications. An inspector previously qualified in " Process Piping and Instrumentation" required 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of classroom training. An inspector qualified to other QC inspection activities or a newly hired QC inspector received 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of classroom training. Upon completion of classroom training a proficiency examination was administered and an 80% passing grade was required.
In addition, all MTV inspectors received practical training.
Practical training for those MTV inspectors assigned to the Program from its inception consisted of performing verification activities on 20 sample MTV data packages.
This training was administered by the PGCo Field QC Supervisor and Assistant QC Office Supervisor. Practical training for the MTV inspectors who were added to the Program after it had begun, included performing mock examinations using current MTV checklists. These mock examinations were performed either while accompanying a 1
J
qualified Level II MTV inspector ~in the field or through the use of training modules. A score of 100% on the mock examinations was required to quality a trainee as an MTV inspector and a trainee's performance was evaluated by a qualified Level II MTV inspector.
All training was documented and is retained by PGCo's
! QC Department for each inspector.
Q.25. How did the inspector use the MTV Package?
A.25. The dccuments in the MTV package were used by the
! inspector to locate the piping installation and identify the items requiring verification. The inspector then recorded identification markings taken from the material itemized on the checklist. Finally, the MTV package was used as a traveler mechanism to transmit completed checklists and Digital Thickness Measurement Reports to the QC office for traceability and acceptability reviews.
Q.26. What did the inspectors do when the marking or markings on the items either were covered with an obstruction or were illegible or missing altogether? (
l A.26. If markings were not visible on the piping item, the QC inspector requested the piping Superintendent to remove any obstruction to ascertain whether or not a marking was !
concealed by the obstruction; and, if so, it was recorded.
This same procedure was followed when an obstruction concealed part of a marking. The QC inspectors were directed to record only those markings they could verify and not to record any marking information based on conjecture.
If the QC inspector found a six digit marking with some numbers illegible, for example the third and fifth i numbers, he would record it as 78?676. If the whole marking was illegible to the QC inspector, another QC inspector examined the marking. If both inspectors concurred, the marking was considered illegible. In the cases where there weren't any markings or the markings were illegible, the inspector recorded "HNNI" (heat number not indicated) on the checklist. In these cases, the wall thickness of the pipe was measured with a digital thicknest meter (DTM).
Q.27. What was the purpose of the digital thickness measurements?
A.27. DTMs measured the thickness of the pipe wall to determine whether the installed pipe was of a schedule, i.e.,
thickness, required by the design engineer and whether the-installed pipe conformed to the schedule listed on the Stores Request for that item.
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Q.28. Were the results-analyzed once field examinations were completed?
A.28. Yes. Upon completion of the field review and compilation of the data package by the QC inspector, an assessment was performed by a certified PGCo Level II QC office techni-
- cian.
Q.29. Did the QC office technicians receive any training prior to assessing the results of the field inspections?
A.29. Yes. Guidance and training were provided to the QC technicians to direct them in the process of determining whether matching markings existed when non-identical 5
numbers from field markings and stores requests were found and could be traceable to the same heat number. This process relied solely on controlled, quality verified i
project documentation.
Q.30. Please explain the manner in which the Quality Control assessment was conducted.
A.30. The assessment was conducted in two phases. The first phase involved a determination of whether each piping item examined did have traceable identification. The second phase involved a determination of the material acceptability of each installed item to design documents. i i
For the purposes of determining traceability, the results of the field examination and the Stores Requests documentation were examined to confirm acceptable heat number markings on the item and/or on the Stores Request.
The traceability information identified by field examination was reviewed for correctness to verify that the heat number was a valid number. PGCo NCRs were written if the heat number recorded in the field could not be verified as a traceable heat number. The heat number log, which is a PGCo listing of acceptable heat numbers for ASME material received on site, and other first generation traceability documentation was used for this purpose.
The Stores Request installation documentation from the traveler package for each item was then examined to compare the heat number from the documentation against the heat number identified by field examination. Traceability was deemed verified when these numbers agreed or when minor discrepancies between the heat numbers could be j easily reconciled. When this comparison resulted in irreconcilable heat numbers, PGCo NCRs were written.
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For the items not having markings recorded in the field, the Stores Request documentation was verified against the heat number log to determine traceability. When this j
comparison resulted in irreconcilable heat numbers, PGCo NCRs were written.
The second phase of the Quality Control assessment, the determination of installation acceptability, involved a comparison of the items, as defined through the traceability documentation in the first phase, with the installation specification. This included comparison through the traceable documentation back to the manufacturer's records for characteristics such as, material description, diameter, schedule, type, grade and code classification against the installation specification for that item. PGCo NCRs were written for all deficiencies discovered in this check for acceptability.
Q.31. What were the minor discrepancies in the heat numbers mentioned in A.30. that were reconciled as valid heat numbers?
A.31. The minor discrepancies in the heat numbers refe to in ,
I A.30. were heat numbers with characters (letters or '
numbers) interchanged, substituted, added or deleted from a known traceable number. These discrepancies were collectively called " transposition errors." In addition, heat numbers with partially visible characters were evaluated as minor discrepancies to determine whether traceability existed. These transposition errors and
partial markings were evaluated under PGCo Work Instruction, PGWI-17, "QCT Review of MTV Program."
This work instruction states:
- a. two adjacent characters interchanged within a known traceable number, e.g., if the known traceable number is 462428, a transposition error would be 462482.
- b. a single character deleted from a known traceable
]
number, e.g., if the known traceable number is A24B1, a transposition error would be A24B.
- c. a single character substituted by a foreign character from a known traceable number, e.g., if the traceable number is 411A, a transposition error would be 4111A.
Once a transposition error was identified, the QC technician first determined whether the number believed to be a transposition error represented a valid heat number.
This was done by checking whether the transposition error number was traceable exclusively to a known heat number or i
heat number code. If no other valid heat number could be determined to apply to the transposition error as written, it was considered to be a valid transposition error traceable to a known heat number.
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27 -
For partial field markings, the QC technician compared the field markings to the marking recorded on the Stores Request to determine the acceptability of the marking as a match to the Stores Request. A matching mark was confirmed if it passed two checks. First, a review of the MT/PQ Log was made to confirm that the identifiable
. markings, without considering the missing digits, did not constitute a known heat number. If such a match occurred, the partial marking was considered an invalid heat number.
However, if no match resulted from the review against the MT/PQ Log, a second review was made to determine if the identifiable characters and the missing digits could be traced to only a single valid heat number. If the. partial marking was traceable to more than one heat number, the partial marking was considered to be an invalid heat
! number.
i l- Those items with heat numbers with either transposition I errors or partial field markings were initially recorded as. deviations. However, those transposition errors or
! partial field markings that satisfied.the above acceptance criteria were not ultimately considered by PGCo to represent valid traceability deviations.
Q.32. Why was it appropriate to evaluate these minor discrepancies in this manner instead of dispositioning them under the PGCo NCR process?
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A.32. I am glad you asked that question. At the very outset of the MTV Program it was realized that 100% verification of each heat number traceability marking with Stores Request would not be possible because of deteriorated field markings and potential recording errors in transferring numbers from one document to another. These conditions may be expected to occur given the fact that the examinations under the MTV Program were conducted many months, and in some instances, years after their installation and because a number of documentation steps were required before the QC technician performed the traceability assessment.
1 Recording errors that resulted in inconsistent findings from field marking inspections and Stores Request documentation of the type described in A.31. did not properly represent nonconforming conditions for which the condition of the item is in question or for which the effectiveness of the Material Stores Request System should be measured because the minor discrepancies were easily reconciled without further investigation.
{
Partial field markings were not viewed as shortcomings in the Material Stores Request System provided that the partial physical identification could be reliably matched with a valid traceability number on the applicable Stores
)
C
't Request. In addition, a conservative refinement was added
.to this evaluation during the process of reporting the MTV results by limiting partial field markings to no more than two missing characters. This matter is discussed at pages III-2 and III-3 of Attachment 10.B. (DelGeorge-1) to Mr. DelGeorge's testimony. Credit for such markings was used to evaluate the accuracy of the Material Stores Request System.
1 Q.33. Did anyone check the Quality Control assessment performed l
by the QC office technician?
i A.33. Yes. The QC Supervisor performed a second level review on 100 percent of the MTV packages. The minimum review for each 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 completer assurance that all items on the i
! MTV log were addressed for acceptance / rejection as f applicable; an'd comparison of the MTV computer printout to i
i the MTV log for correctness.
i i Discrepancies identified during the second level review i were documented and this information was fed back to the i i
first level _ reviewer responsible for the discrepancy to
< improve the quality of the QC technician's assessments.
j i
Q.34. Did PGCo report the results of the MTV Program?
A.34. A draft report of the Program results was developed by PGCo. However, the report was never finalized because CECO prepared the document called " Material Traceability Verification at Braidwood," dated November 1985. This report included the information covered in the draft PGCo report. PGCo reviewed and concurred in the MTV Report
- prior to its issuance.
Q.35. What is your opinion, if any, with respect to the significance of the MTV Program results?
A.35. I agree with the conclusions stated in the MTV Report. In particular, I believe the Material Stores Request System provided material traceability in compliance with Section III of the ASME Code and that the MTV Program demonstrated that the ASME material installed by PGCo at f Braidwood is traceable and acceptable.
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- 1 Attachment 108 '
(O'C:nnor - 1) e FIGURE 1 MATERIAL STORES REQUEST SYSTEM (Effective between June 1976 and September 6,1983)
- 1. Superintendent initiates Stores Request
- 2. Field Engineer reviews !
Stores Request for correct material o
- 3. QC reviews Stores Request for completeness l
- 4. Superintendent presents Stores Request to warehouseman i
pink Engineering Department copy -
g inventory control
- 5. Warehouseman issues material an' records Yell 0W :
Warehouse records heat number on Stores COPY Request (*)
white 6. QC office verification copy ' of material supplied --
per Stores Request o
- 7. Superintendent performs installation and Supervisor QC(**) 4 records heat number on QC puts white copy in installation drawing traveler package and FFP&Os in traveler I package j i 1
- 8. Traveler package traveler package . returned to QC for of fice storage blue copy Stores Request retained (*) - After 3-79, the Warehouseman issued by Suparintendent in the blue copy of the Stores Request field office for inclusion in traveler package
(**) - Af ter 12-14-82, the Superintendent performed this function
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