ML20205M844

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Testimony of Ws Gibbons Re Intervenor Rorem QA Subcontention 10.B Concerning Matl Traceability.Related Correspondence
ML20205M844
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 04/11/1986
From: Gibbons W
COMMONWEALTH EDISON CO., WILLIAM GIBBONS & ASSOCIATES, INC.
To:
Shared Package
ML20205M802 List:
References
OL, NUDOCS 8604150399
Download: ML20205M844 (14)
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6 pose @G April 11, 1986 ,

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h UN TED STATES OF AMERICA NUCT *R REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING AR@ 14 P2:15 Crnr2 .

In the Matter of ) ,.'

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Station Units 1 and 2) )

TESTIMONY OF WILLIAM S. GIBBONS (ON ROREM Q.A. SUBCONTENTION 10.B.)

0.1. Please state your full name for the record.

A.l. William S. Gibbons.

Q.2. Who is your employer and what is your occupation?

A.2. I am self-employed. My company is called Wm. Gibbons &

Associates, Incorporated. My business address is 236 North Santa Cruz Avenue, Suite 249, Los Gatos, California 95030.

Q.3. Please state your educational background and professional experience.

A.3. I have a Bachelor of Science in Metallurgical Engineering (1952) and a Master of Business Administration (1958) from the University of California, Berkeley. I am a Registered Professional Metallurgical and a Registered Professional 8604150399 860411 6 PDR ADOCK 0500 T

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Quality Engineer in California; and I am qualified as a Lead Auditor in accordance with ANSI N-45.2.23.

Since 1970, I have been an active participant in the American Society of Mechanical Engineer's (ASME) Codes and Standards Committees including:

o Member, Sub-committee on Nuclear Accreditation o Member, Sub-group on General Requirements (SCIII) o Co-Chairman, Working Group on Quality Assurance and Stamping (SCIII) o Member, Task Group on Material Manufacturers and Suppliers (SCIII) o Member, N-626 Committee I am a Course Director in Quality Assurance for Nuclear Components for the American Society of Mechanical Engineers. Since 1978, I have lectured and participated in numerous quality assurance courses and seminars.

I am a member of the American National Standards Institute /American Society of Mechanical Engineers (ANSI /ASME) Committee on Nuclear Quality Assurance.

I am a member of the American Society for Quality Control.

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I I am a past member of the following committees:

ANSI B31.1, Power Piping ANSI B31.7, Nuclear Power Piping l

ASME Subgroup on Materials (SCIII)

ASME Subgroup on Fabrication and Examination (SCIII) i

! ASTM Materials Committees i

I have worked in the manufacturing and the power industry since 1951 as follows:

1984 - Present: Wm. Gibbons and Associates, Inc.

Los Gatos, California

, President l l I Currently consulting with utilities, manufacturers, and architect / engineers.

These consulting services have been primarily concentrated on the resolution of ASME Code problems and quality aystem l

problems. I have been assisting numerous manufacturers in the development and implementation of ASME Code quality assurance programs, and in addition, have provided litigation assistance services for several consulting engineering firms.

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s 1981 - 1984: Reedy, Herbert, Gibbons and Associates, Inc.

Los Gatos, California Vice President, Projects l The major efforts while with RHG&A were as director of the development and implementation of the Independent Design Review quality assurance program for the Diablo Canyon Project, the G.K. Newberg ASME QA program, and the Ceramic Cooling Tower ASMM QA program. In addition, I participated in the resolution of numerous ASME Code and quality problems, in particular, those associated with the National Board review of the Cincinnati Gas & Electric Company's Zimmer Project.

1980 - 1981: Nuclear Technology, Inc. '

San Jose, California ,

I Chief Consultant, Quality My major accomplishment at Nutech was as Director of the team assisting the Marble Hill Project, for Public Service of Indiana, to successfully obtain an ASME "N" l

certificate. In addition, I consulted with other clients on ASME Code and quality assurance program applications.

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, I 1969 - 1980: Bechtel Power Corporation .

San Francisco, California successively: Supervising Metallurgical Engineer, Quality Assurance Manager, and Procurement / Supplier Quality, Deputy Manager.

While at Bechtel, I became active in the referenced ASME Code committees and frequently worked with the many Bechtel power projects to resolve fossil and nuclear code issues. My initial effort in 1970 was to assist in the successful development and implementation of Bechtel's Nuclear ASME Quality Assurance Programs. While Quality Assurance Manager for the San Francisco Power Division, from 1972 to 1976, I was responsible for Bechtel's Nuclear Safety-Related QA Program, the initial Bechtel Topical QA Program, and their ASME QA Program.

1959-1969: General Electric Company San Jose, California Successively: Engineer, Quality Assurance; Manager, Japan, and Quality Assurance Manager, Europe.

At General Electric, I was initially engaged in the development and application of materials and processes for nuclear steam supply system components. This included

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.' 9 participation in several ASTM materials committeed,\^.

's Subsequently, I became responsible for Quality Assurance for the first Japanese BWR and then several General Electric plants in Europe in Holland, Spain and Switzerland. These projects involved the application of

,4 the ASME Code at suppliers' sites'and'at the job sites.

s In sum, I have over'25 yea'rs of experience with ASME Code work.

4 0.4. What has been your connection with 'the Braidwood Pr'oject?

A.4. I have been retained since 1984 by Commonwealth Edison Company (CECO) to provide c'onsultingss ervices regarding ASME Code,Section III applications with respect to CECO's Material Traceability Verification Program (MTV) and other activities at the Braidwood Project. Specifically, I have participated in the resolution of various issues concerning material certifications,-treceability, application and procurement-qualification of material manufacturers and material suppliers. ,;4 s

Q.5. Whatisthepurposeofyourtestimony??[

A.S. My testimony presents an evaluation of the Phillips, Getschow Company IPGCo) Q.A. manual and the Material Stores Request System used by PGCo for matArial '

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traceability and control for the purpose of determining whether this System meets the material traceability and control requirements of Section III of the ASME Code.

Q.6. What versions of the PGCo Quality Assurance manual were the focus of your evaluation?

A.6. My evaluation began with the original version of the PGCo QA Manual, which was issued on April 28, 1976 and I examined each revision thereafter through Revision 14, which was in effect to September 21, 1983. The Material Stores Request System that is covered by the PGCo OA Manual through Revision 14 is described in A.7. and Figure 1 (Attachment 10B (O'Connor-1)) of Mr. O'Connor's testimony. The purpose of this review was to determine what quality assurance programmatic requirements PGCo had for the control and identification of material and items.

Q.7. What version of the ASME Code applies to the fabrication and installation of piping systems by PGCo at Braidwood?

A.7. The 1974 Edition, Summer 1975 Addenda of Section III, Division I, of the ASME Code is applicable to the fabrication and instellation of piping systems by PGCo at Braidwood. Under Section III, PGCo, based on the authorization granted by ASME, must certify compliance of its work with tris Section of the ASME Code prior to turnover of the piping systems to CECO.

i 0.8. Has PGCo been authorized by the ASME to certify compliance with the Code?

A.8. Yes, PGCo first received its Certificates of Authorization and NA and NPT stamps from ASME in 1978.

Thereafter, PGCo's Certificate of Authorization was reviewed by an ASME survey team every 3 years and, if the review was favorable, the authorization was renewed.

PGCo's Certificates of Authorization were renewed in 1981 and 1984.

Q.9. Please describe the process used by the ASME to accredit PGCo.

A.9. The steps to achieve ASME Certificates of Authorization are:

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1. PGCo develops a Quality Assurance Manual, supporting I procedures and implementing practices to demonstrate compliance with the applicable requirements of the ASME Code,Section III.
2. PGCo obtains an agreement for inspection and audit services with an Authorized Inspection Agency.
3. An ASME Survey Team, at PGCo's request, performs an on-site review at the location (s) where the Code activities are being performed. This review consists

of a review of PGCo's Quality Assurance Manual to assure that it complies with the applicable requirements of NA-4000, " Quality Assurance," and an l audit of the PGCo quality assurance program to determine that it has been properly implemented. The Survey Team documents their review in a report which recommends either issuance of a certificate or that a resurvey is required. The ASME Survey team is generally comprised of an ASME survey team consultant, a representative of the National Board of Boiler and Pressure Vessel Inspectors, a representative of the State of Illinois, Nuclear Inspection Supervisor, an Authorized Nuclear Inspector from the Authorized Inspection Agency and a Utility Representative.

4. The Survey Team's report is sent to ASME's Subcommittee on Nuclear Accreditation for approval. Upon approval, the ASME will issue a certificate of authorization valid for three years, at which time another survey is required for renewal.

Q.10. What provisions of the 1974 ASME Code, Summer 1975 Addenda apply to the traceability and control of piping material installed by PGCo at Braidwood?

A.10. The provisions of the ASMD Code differ depending upon the class of piping system involved. Code piping systems are

divided into three possible classes, Class 1, 2 and 3.

The Code has special material traceability and material control provisions that apply to the fabrication and installation of Classes 1 and 2. However, no requirement for material traceability exists for Class 3 piping systems. Therefore, the traceability questions raised by the NRC apply only to Class 1 and 2 piping systems and I will answer the question in the context of these systems.

The principal provision of the quality assurance requirement in subsection NA of the ASME Code that governs material control and traceability of Classes 1 and 2 systems is NA-4441, " Establishment and Maintenance of Identification and Control Measures." NA-4441 states:

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 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.

This provision leaves to the Certificate Holder, in this case PGCo, the flexibility to determine the methods and procedures needed to assure the proper identification and control of material appropriate for Class 1 and Class 2 piping systems.

Q.ll. Why does the Code provide the Certificate Holder so much discretion?

A.ll. It is intended that the ASME Code quality assurance requirements provide objectives in a manner that gives Certificate Holders the responsibility and flexibility to develop proper implementing quality assurance measures appropriate to their individual activities.

Earlier versions of NA-4441 were more specific in prescribing measures for material traceability and control. However, these provisions were revised because the Code writers and the engineering community realized the provisions were too detailed. They reasoned that l Certificate Holders should be allowed the freedom to determine the most appropriate means commensurate with their activities for meeting Code quality assurance requirements.

l Q.12. What was the next step in your review process?

A.12. I compared the PGCo Material Stores Request System, including Sections 5. and 8. of the QA Manual with the requirements of NA 4441 to determine compliance. The focal point of my evaluation was to assess and decide whether, as' required by NA-4441, PGCo had established the

" measures" for material identification and control that

" assure" identification is maintained either on the piping material or on records traceable to the material throughout fabrication and installation, that is, from material issuance through installation.

Q.13. What conclusion did you reach?

A.13. The Materials Stores Request System and the QA manual used I by PGCo to maintain material traceability and control during the period April 28, 1976 through September 21, 1983 met the requirements of the ASME Code,Section III, Division I, NA-4441 - " Establishment and Maintenance of Identification and Control Measures." My evaluation includes the time period addressed in NAC Inspection Report No. 83-09.

Q.14. What is the basis for your conclusion?

A.14. The eight steps of the Material Stores Request System described in A.7. of Mr. O'Connor's testimony provide for piping material identification from the time the material is issued from the Warehouse, through installation, to the point of preparation for the N-5-review. Thus, the System provides for material identification from the time of material issuance through the time of installation as

B required by NA-4441. Of equal importance is the fact that several of the steps provide substantial assurance that piping material identification and traceability will be maintained throughout fabrication and installation. These steps are:

1. The Field Engineering Department checks the Stores Request that has been prepared by the production forces before it is presented to the Warehouse. The purpose of this review is to assure that the correct material for the application has been requested and that the correct material is available on-site and acceptable for release from the point of storage, the Warehouse.
2. After the material has been issued by the Warehouseman, and the required information concerning material identification and description has been written on the Stores Request, the Quality Control Department reviews the Stores Request to assure that acceptable material has been issued.
3. Finally, using the material Stores Request record copy, the Quality Control Department records the acceptable material heat number or other material identification code on the applicable installation drawings or on the Field Fabrication and Process Data Sheets. These l

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a documents are used for the N-5 review, a process that >

assures that the material in the installed piping systems is traceable and acceptable prior to system turnover to CECO.

Q.15. Does the ASME Code require QC verification of material traceability and acceptability at the point of installation in order to assure satisfactory material traceability and control measures?

A.15. No. Documented verification in the field at the time of installation by Quality Control inspectors of material identification and correct material installation is not l required by the ASME Code. The PGCo Material Stores Request System that was the subject of my evaluation did not include this feature; yet, as I have testified, that System provided the requisite assurance of material traceability and control required by the Code.

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