ML20205M848
| ML20205M848 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/11/1986 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20205M802 | List: |
| References | |
| OL, NUDOCS 8604150402 | |
| Download: ML20205M848 (58) | |
Text
l
- p April 11, 198.6 e-en.ATED CORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I4 pg,.7$
L tc ~ _
03N',;f :-
In the Matter of )
- /
' Mlf ,'3~
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
TESTIMONY OF LOUIS O. DEL GEORGE (ON ROREM Q.A. SUBCONTENTION 10B (Material Traceability) 0.1. Please state your full names for the record.
A.l. Louis Owen Del George.
l 1
0.2. Who is your employer and what is your occupation?
l A.2. I am employed by Commonwealth Edison Company (CECO) in its Corporate Offices in Chicago, Illinois. i l
I am an Assistant Vice-President, responsible for Engineering and Licensing activities related to all l I
operating nuclear reactors within Commonwealth Edison's j Nuclear Operating Division. I am also responsible for licensing activities related to the nuclear reactors which Commonwealth Edison is currently constructing at Byron and. ,
l Braidwood Stations. In addition, the engineering I I
organization that reports to me maintains functional j 1
i C604150402 860411 PDR ADOCK05000g6 I
m-i p oversight of the engineering activities related to the reactor facilities under construction to provide for the uniform application of Commonwealth Edison's engineering procedures at both our operating nuclear plants and nuclear plants under construction.
Q.3. Please state your education and professional experience.
A.3. I received a Bachelor of Science Degree in Engineering Science from the Illinois Institute of Technology in 1970.
I also received a Juris Doctor degree from the Chicago Kent College of Law of the Illinois Institute of-Technology in 1977.
I began my professional career at the Bettis Atomic Power-Laboratory in 1969-where I held various positions of increasing responsibility related to the design and' fabrication of nuclear reactor internals. While employed at the Laboratory, I was appointed to the-Shock and:
Vibration Design Review Committee which assessed the adequacy of vibration design practices for all pressurized water reactor plants designed at the Laboratory, including the Shippingport facility. I also' attended the Laboratory's Reactor Engineering School which provided graduate level instruction in the design of nuclear power systems.
. , t In 1974, I joined Commonwealth Edison and have held positions of increasing responsibility in the Station Nuclear Engineering and Licensing Departments. In connection with my engineering experience, I managed numerous backfit projects related to the Dresden and Quad Cities Stations between 1974 and 1978.
In connection with my licensing experience, from 1978 to 1981 I was responsible for all licensing activities i
related to the LaSalle County Station including development of the Company response to all NRC questions concerning design and construction activities. In this regard, I directed the development of all licensing positions in response to NRC regulatory initiatives. In addition, I participated in the development of numerous construction verification programs created to address questions raised concerning the adequacy of structural and mechanical construction activities.
In July, 1981, I was appointed Director of Nuclear Licensing for Commonwealth Edison at which time I assumed responsibility for all licensing activities related to the Company's nuclear facilities both operating and under construction, including Braidwood Station. In this capacity I participated directly in major decisions affecting the licensing of Braidwood Station including
e , )
managament meetings and enforcement conferences requested 4
by the Nuclear Regulatory Commission.
1 In January, 1983, I assumed the position of assistant to the Assistant Vice-President of Engineering and Licensing with primary responsibility for coordinating all Company positions affecting the licensing of Byron Station, including hearings before the Atomic Safety and Licensing Board. I gave testimony to that Board in March, 1983 and July, 1984 on matters related to Commonwealth Edison's nuclear licensing activities and the Byron Quality Control Inspector Reinspection Program.
In November, 1983, I assumed my current position of l Assistant Vice-President. In this position I am responsible for all engineering activities at Dresden, Quad Cities, Zion, LaSalle County and Byron Unit I. This responsibility includes the direction of all safety related modification work at those facilities. I have l l
been directly involved in pipe inspection and repair activities on our boiling water reactor facilities, and ;
l steam generator inspection and repair activities on our !
pressurized water reactor facilities, and steam generator inspection and repair activities on our pressurized water reactor facilities. These responsibilities also include 1
.1
4 .
- the coordination of purchasing, construction and testing activities associated with this work.
l I am also responsible for managing all communications between Commonwealth Edison and the Nuclear Regulatory Commission. This responsibility involves directing those l l
Edison employees who have any contact with the Nuclear l
Regulatory Commission, and assuring that all questions i I
raised by that agency and directed to any Commonwealth' !
Edison nuclear facility are understood, thoroughly reviewed and effectively answered. In this regard, I and the licensing personnel reporting to me, review actions committed by Commonwealth Edison to resolve questions or concerns raised by the Nuclear Regulatory Commission to provide added assurance that such actions are adequate and responsive.
Since March 1985 I have,been responsible for directing all Commonwealth E'dison technical and licensing actions in i i
preparation for litigation of the quality assurance contention raised by intervenor Bridget Rorem, et. al.
Q.4. What is the purpose of your testimony?
l A.4 The NRC staff raised questions concerning the traceability and acceptability of certain installed piping materials I
l 1
' 3 during inspections conducted at Braidwood in 1983 and 1984. The results of these inspections were reported in NRC Inspection Report 83-09. The NRC Staff characterized the matter as an unresolved item pending its review of the results and conclusions of Commonwealth Edison Company's 100% reinspection program called the " Material Traceability Verification Program ("MTV Program").
Intervenors' subcontention 10B is based on the NRC inspection report.
My testimony together with the testimony of the other witnesses on this issue addresses the MTV Program. In particular, I am testifying with respect to the results of the MTV Program, the conclusions to be drawn from the Program, and in part, the dispositioning of certain nonconforming items identified during the Program.
Q.5. Were the results of the MTV Program documented?
A.S. Yes, the MTV Program is documented in a report entitled
" Material Traceability Verification at Braidwood," dated November 1985.
b Q.6. Did you participate in the development of the MTV Report?
A.6. Yes.
, Q.7. What was the nature of your participation?
A.7. The MTV Report was prepared under my supervision and direction in my capacity as Assistant Vice-President for Licensing with respect to the Braidwood Project. In this capacity, I have assumed direct line responsibility for the preparation of responses to NRC findings on Braidwood and, in particular, those responses involving major reports requiring the integrated review of more than one department or organization.
I was responsible for the organization of the data set forth in Section III of the MTV Report. I was the primary drafter of Sections III and IV, and I wrote the conclusions set forth in Section VI. Sections III, IV, and VI of the MTV Report are attached as a part of my testimony as Attachments 10B (DelGeorge-1, 2 and 3) respectively.
I developed the conclusions in Section VI by relying in part on the MTV Program description described in Mr. O'Connor's testimony, the design significance evaluation described in Mr. Schimmel's testimony, and the conclusions stated in the report of the National Board of Boiler and Pressure Vessel Inspectors. The National Board's report, dated September 26, 1985, is attached to my testimony as Attachment 10B (DelGeorge-4).
i l
i s , Q.8. Please state the background that led to the initiation of the MTV Program.
A.8. The NRC Region III Staff reviewed the Phillips Getschow program for the installation of safety-related piping materials in June, 1983. At that time, the NRC inspector indicated that a documented inspection program did not exist for quality control inspectors to examine small bore piping components at installation to assure correct material installation. The NRC staff subsequently documented its concern regarding what was identified as a lack of quality control inspection records to verify correct material installation in Inspection Report 83-09, dated May 7, 1984.
Commonwealth Edison acknowledged that apparent l
documentation problems existed which necessitated ,
I corrective action, and agreed to issue a report l l
identifying a " potential deficiency concerning quality control verification and documentation of heat or mark numbers of installed piping system components" in accordance with 10 CFR 50.55(e). That report was made on July 1, 1984 (Braidwood 55(e) Report No. 83-07).
Commonwealth Edison indicated therein that a sample inspection of installed piping would be performed.
g--- - , , - -- -- , -w,
. , Although not expressly stated in Inspection Report 83-09, it appears the NRC Staff considered documented quality control inspections necessary to assure the requirements in Criterion VIII of the NRC's Quality Assurance Criteria, 1
Appendix B to 10 CFR Part 50, and the ASME Code requirements for material control and traceability.
Following the identification of the concern by the Region j III inspector, Commonwealth Edison completed the sample program, consistent with the commitment made in the Fall of 1983, and reported the results to the NRC staff.
Although the results of that program were satisfactory in the view of Commonwealth Edison, the Company, nevertheless, committed to perform a 100% verification of all piping materials installed prior to the time at which documented inspections of a type acceptable to the NRC inspector were implemented in the Phillips Getschow program. The issue was identified as an Unresolved Issue in 83-09 pending completion of the 100% verification i 1
program and the NRC's review of the results of that program.
It was reported in NRC Inspection Report 83-09 that verification of material traceability may have been l performed by quality control inspectors. Piping records sometimes did include QC inspectors' signoffs and all 1
1 inspectors interviewed by the NRC at the time of its !
review attested to the practice of performing inspections at the time of installation though without always documenting the inspection. Because, in the Staff's view, undocumented inspections are not appropriate means to satisfy the NRC's Quality Assurance Criteria, the NRC concluded that a violation of Criterion X, which addresses the performance of inspections to verify conformance with I
documented procedures, instructions and drawings, had occurred.
Although Commonwealth Edison did not believe that the Phillips Getschow piping material installation program violated either the NRC Quality Assurance Criteria or the ASME Code, isolated deficiencies in the implementation of that program and the concern expressed by the NRC led to a comprehensive program to assure effective material traceability and control. To resolve concerns as to ongoing and future work, the Phillips Getschow procedures for large and small bore piping installation were reviewed and modified as necessary to provide for documented QC inspection of material traceability at the time of installation. Documented inspections had already been implemented for large bore piping in December, 1982, before the NRC review. For small bore piping, a similar
e >
procedure was implemented in June, 1983 to close an earlier Phillips Getschow audit finding on this matter.
To resolve the NRC concern regarding large and small bore piping materials installed prior to these procedures being implemented, a 100% verification of those materials was performed. The program to accomplish this 100%
verification is called the Material Verification Program (hereafter referred to as MTV).
Q.9. Please explain the scope of the MTV Program.
A.9. All large bore piping materials installed prior to January 1, 1983 and all small bore materials installed prior to September 6, 1983 were covered by the MTV Program, a total of 25,815 individual items (13,941 small bore and 11,382 large bore and 492 integral attachments) . The cut off dates were chosen to provide a reasonable interval after the effective date of the implementation of the documented QC inspections of piping materials discussed previously in my answer to 0.8.
Phillips Getschow was directed by Commonwealth Edison to develop the necessary procedures and related materials in order to implement this program. A detailed discussion concerning the formulation and implementation of the
- . MTV Program is set forth in Mr. T. O'Connor's testimony on this issue.
Q.10. Were the Piping items of the containment spray system located in Unit 2 installed during the time periods covered by the MTV Program?
A.10. Yes. However, they have been excluded from the scope of the MTV Program.
Q.ll. Why?
A.ll. The containment spray piping consists of a circular piping loop (514 total piping items) in the Unit 2 containment.
Because of its location, this piping is only accessible after the construction of a very extensive scaffold system. At the time the MTV Program was performed, scaffolding was installed in the Unit 1 containment to ;
support work completion and final system verification I
activities. That scaffolding is still installed in Unit 1, where it is now being used to facilitate containment liner cleaning as a part of Unit 1 containment completion prior to fuel loading. Disassembly and reassembly of this scaffolding to provide access to the Unit 2 containment spray loop would have taken approximately 11 to 2 months. That extensive time, plus j the time necessary to complete the Unit 2 inspection and
. , reassemble the scaffolding in Unit 1 would have had a significant effect on the efficient management of work in the Unit 1 containment which, as indicated earlier, is still ongoing.
The Stores Requests for the material items associated with the Unit 2 containment spray system were reviewed at the time the MTV Report was being prepared. It was determined that all large bore piping was issued as unaltered large bore spools, with the exact number of associated small bore nozzles required for each piping section specifically identified on the applicable stores request form. This i record did not suggest the existence of a traceability or acceptability problem. However, physical verification of the installation would have been required to complete the material verification under the MTV Program. Because that verification was impracticable, for the reasons previously stated, and because the Stores Request record alone did not demonstrate a nonconforming condition, it was decided not to count the 514 Unit 2 containment spray material items in the MTV Program data base, and to defer final verification of the adequacy of those items to a later date. This was considered appropriate in as much as the Unit 2 containment spray records themselves did not manifest a problem and because there were no cutouts associated with Unit 1 containment spray material items
l
. , j i
1 that might otherwise suggest the existence of a problem with the Unit 2 material. l l
Q.12. What were the objectives of the MTV Program? j A.12. The MTV Program was established to determine the ;
i reliability of the Phillips Getschow material installation control program prior to the time documented QC inspections of material installation were implemented.
This program was based on the Stores Request System which was intended to control piping material installation. In addition the MTV Program was established to provide a documentary record of the traceability and acceptability of each material item reviewed. The engineering evaluation of the results of the verification, which was
~
included as a part of the effort, and was intended to I
provide a defensible basis for determining the existence or non-existence of design significant discrepancies.
l l
The data base produced as a result of the MTV Program was also expected to be used as part of the final material review required of all ASME Code material installations.
Because of the completeness of the MTV records many miscellaneous uses not originally foreseen were also made of the Program data. These ancillary uses were not specific objectives of the MTV Program.
r,. ,vv -
Q.13. Do the-results of the MTV Program serve to satisfy those objectives? o A.13. Yes.
Q.14. What do the results show?
A.14 The reliability of the Phillips Getschow Stores Request System can be assessed by a review of the MTV Program results.
Those results show that for the 25,815 items verified under the MTV Program:
o 21,167 items were determined to have both field identification and Stores Request identification.
o 20,214 items (95%) had matching field and Stores Request identification without resort to supplemental records.
o 20,604 items (97%) had matching field and Stores Request identification after reconciliation of partial field identification.
1 I
q o 20,948 items (99%) had matching field and Stores ]
Request identification after reconciliation of minor a
= . recording errors associated with either the field or Stores Request identification.
o Only 219 items (1%) had field and Stores Request identification that could not be reconciled based on the initial document review.
This data, which is reported in Section 1 of Attachment A validates the Stores Request System.
Section 2 of Appendix A provides a basis for assessing the adequacy of traceability of the material items covered by s
the MTV Program. Out of the total of 25,815 items reviewed in the MTV Program, traceability was established with respect to 25,023 items.
Nonconformance Reports (NCRs) were written on_792 items (3% of the total items) . NCRs were written in each case l
when material traceability was considered a potential l l
question. In some instances, material traceability was l subsequently established through the dispositioning process; nevertheless, these items.are shown as nonconforming items. Therefore, the number of items with NCRs written under the MTV Program is not necessarily reflective of the number of items with inadequate traceability.
a . Section 3 of Appendix A provides a basis for assessing the acceptability of the material items covered by the MTV Program for the location they were installed. The purpose of this review was to verify that correct pipe material type, grade, schedule and class were withdrawn from stores and installed. Out of the total of 25,815 items reviewed in the MTV Program, acceptability was established without apparent deficiencies with respect to i 25,680 items. Nonconformance reports were written with I respect to 135 items (less than 0.5% of the total items) .
In order-to establish material installation acceptability, additional documentation 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 documentation review and a field dimensional check, where practical. In all cases where the installation did not conform to the installation specification, an NCR was written.
Q.15. Were traceability nonconformances identified for piping items for which traceability is not required by the ASME Code?
A.15. Yes. 562 of the 792 items determined to have questionable traceability did not require such traceab.ility under the
...:. y applicable provisions of the ASME Code. Therefore, for
o piping items that required traceability under the ASME Code, only 230 items had questionable traceability.
Q.16. Why did the MTV Program include piping items that did not require traceability under the ASME Code?
A.16. The Phillips Getschow piping material installation program required material traceability for all Class 1, 2 and 3 piping materials notwithstanding the traceability exclusions allowed by the ASME Code. Because the MTV Program was established to assess the effectiveness of the installation program as it was implemented at Braidwood, the less demanding ASME Code provisions were not used to exclude piping materials from the MTV Program.
Q.17. Returning now to the results of the MTV Program, how were the discrepant items dispositioned?
A.17. The discrepant items were divided into two categories, traceability and acceptability. The process employed to disposition these discrepancies is discussed in Attachment B. This process relied on the established Braidwood Project NCR disposition process. In addition, a special review board was established consisting of a representative of the Commonwealth Edison Project Construction and Project Field Engineering Departments, Commonwealth Edison Quality Assurance Department, Phillips Getschow, the Hartford Authorized Nuclear Inspector (ANI),
- . and the National Board of Boiler and Pressure Vessel Inspectors. With the exception of the National Board and the Project Field Engineering participant who reviewed approximately 85% of the dispositions, the review board reviewed each disposition prior to the nonconformance being closed out. This review board verified for each disposition that documentation was properly utilized and, for each disposition where no rework was recommended (i.e., use-as-is) that the item was traceable and acceptably installed.
Out of the 792 items identified on NCR's dealing with traceability, 647 were dispositioned accept-as-is. The remaining 145 required the piping material item be cut out. These cut outs constitute approximately 0.5% of the 25,815 items reviewed.
Out of the 135 NCR's written dealing with acceptable installation, all were dispositioned accept-as-is.
Therefore, no cutouts were required because a material item did not satisfy the specified piping material type, grade, class and schedule within the requirements of the ASME Code.
= .
r A more detailed discussion of the dispositioning process that provided the data reported in Attachment B is set forth in the testimony of Mr. McClenahen on this issue.
Q.18. What conclusions have been drawn with respect to the MTV Program?
A.18. The conclusions that were drawn from the results of the MTV Program are set forth in Attachment C. My overall conclusion is that the Phillips Getschow piping material installation program was effective. In addition, because none of the limited number of discrepancies was determined to have design significance, including those few items (0.5%) cut out because of irreconcilable records, all' piping materials covered by the MTV Program satisfy their safety function.
Q.19. What was the purpose of the review conducted by the National Board Audit Team as reported in Attachment D?
A.19. The purpose of the review conducted by the National Board Audit Team was to evaluate the adequacy of the Phillips Getschow " Stores Request System" for providing material traceability. The Team's review was undertaken to address the concern raised by the NRC with respect to the adequacy of that system. In addition, at the request of Commonwealth Edison, the Team wasurequested to assess the scope and adequacy of the MTV. Program as a corrective
l action method to identify and disposition any items for which traceability was indeterminate.
Q.20. What were the conclusions of the Team?
A.20. The National Board Audit Team concluded, based on its review and audits of the MTV Program and related documentation that the Phillips Getschow quality assurance program, prior to the implementation of the MTV Program, did provide the necessary controls to assure that the work performed by Phillips Getschow at Braidwood met the requirements of the ASME Code and the certified design specification; and that the deviations from hat quality assurance program are being identified and dispositioned in accordance with the requirements of the Phillips Getschow program and the ASME Code. This latter conclusion was based on the Team's review and audits of the data compiled by Commonwealth Edison and Phillips Getschow through the MTV Program, which the Team accepted as appropriate to:
(a) document conditions adverse to quality, (b) determine the cause of a problem, and (c) take corrective measures which will correct and prevent the recurrence of a problem.
Finally, the Team indicated that the actions taken to correct deficiencies in the material control procedures at Braidwood are effective and have identified those instances where material traceability may have been lost.
The Team further indicated that revisions made to the Phillips Getschow program and procedures will prevent the recurrence of previously experienced deficiencies.
Q.21. Was an independent audit of the MTV Program conducted by the Institute of Nuclear Power Operations (INPO)? I A.21. Yes. INPO conducted an audit of the MTV Program in June, 1984 as part of its regular Construction Project Evaluation Program.
Q.22. What were the INPO findings?
A.22. INPO conducted its audit approximately 3 months after the commencement of the MTV Program as the Program was in the early states of implementation. INPO found that improvement was needed in the implementation of the MTV Program. This finding was attributed to the observation that some items of indeterminate traceability had been accepted by the MTV Program. Also, some MTV reviews were not completed prior to hydrostatic testing.
INPO recommended that direct utility involvement in the supervision of the MTV Program should be increased, additional technical training of document control personnel be conducted, and that Program priorities should be factored into the Phillips Getschow schedule for related activities.
It is worth noting here that INPO's express goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant construction. The recommendations made by INPO are based on best practices, rather than minimum acceptable standards or requirements.
Q.23. What was Commonwealth Edison's response to the INPO comments concerning the MTV Program?
A.23. Commonwealth Edison with Phillips Getschow took the actions delineated below to produce the recommended improvement in the MTV Program.
- a. An experienced documentation review supervisor, with knowledge in ASME Section III Code and materials, was added to the piping contractor quality control staff.
This individual's primary responsibility was to direct the correct and successful completion of the MTV Program.
- b. Two senior level Commonwealth Edison Company engineers, with knowledge and experience in documentation review and ASME Section III Code and materials, performed an independent assessment of MTV Program activities.
These engineers were made available to the piping contractor during the implementation phase of MTV Program improvement activities.
- c. A Commonwealth Edison Company engineer, with knowledge and experience in the ASME Section III Code and materials, was appointed specifically to overview MTV Program activities.
- d. Additional training was given to MTV review personnel on the documentation review aspects of the MTV Program.
In particular, this training emphasized verification of material heat numbers with the use of first generation documentation (i.e., actual certified material test records and piping design table specifications).
- e. MTV review personnel were asked to provide feedback to management on methods to reduce errors in job performance. Resultant feedback underwent management review and subsequent action.
L
l In addition, the MTV Program priorities were considered in establishing the hydrostatic testing schedule. However, completion of MTV Program activities were not established as a constraint on hydrostatic testing.
/
Furthermore, as was discussed in response to Q.17. a review board was established with significant Commonwealth Edison participation to further assure the adequacy of the disposition of all deficiencies identified by the MTV Program.
This response was considered satisfactory by INPO.-
Q.24. Has the NRC Staff reviewed the results of the MTV Program?
A.24. Yes.
Q.25. What are the Staff's findings and conclusions?
A.25. The NRC Staff conducted numerous inspections between July, 1985 and January, 1986 of activities related to the MTV Program. The purpose of these inspections was to assess the implementation of the Program. Based on these inspections and reviews, the Staff found that both the procedures and the implementation of procedures under the MTV Program were acceptable to address the concern related
- - to unverified piping material installation identified earlier in NRC Inspection Report 83-09.
The Staff further found that although the MTV Program discovered examples of installed piping components which did not comply with applicable design specifications, the 1
engineering evaluation of the results of the MTV Program
. demonstrated that all installed components were capable of performing their safety function.
l Finally, the Staff concluded that action had been taken to correct the violation identified in Inspection Report 83-09 and to prevent its recurrence.
The NRC documented these findings, and the bases for them, 1
i in Inspection Report No. 456 / 85061/ (DRS) and 457 / 85057 (DRS) dated February 3, 1986..
l 1
_ . - - - _. _ ~ __ _ _ _ . - _ . _ _ - - ~ _ . _ - - .
, Attachment 10.B -
I (DelGeorge - 1) 111-1 I III. PROGRAM RESULTS l The MTV Program inspected 25,815 items of large and small bore piping. A determination of the existence of material identification numbers on the stores requests and the installed items yielded the following four categories of data which are displayed in Figure III-l.
- a. 21,167 items had both physical identification and stores request documentation.
- b. 3,990 items, of which approximately 900 items were inaccessible, had stores request documentation only. The PGCo traceability system relied on the Stores Request System and did not require permanent retention of physical identification to meet Code requirements.
- c. 577 items had physical identification only. Physical identification marked on the item is an acceptable traceability system.
- d. 81 items had neither stores request documentation nor physical identification.
l The data in category a. above was used to establish the reliability of the PGCo Stores Request System as a means to effect material traceability. This subject is presented in Section 1 below. The 25,815 items were evaluated to verify that they are in fact traceable. This evaluation is presented in Section 2. The inspection results for the 25,815 items also were used to verify material installation acceptability through an l evaluation of the pertinent documentation. This information is presented in Section 3. l l 1. RELIABILITY OF STORES REQUEST SYSTEM The efficacy of the PGCo Stores Request System can be determined by an i analysis of the 21,167 items for which both physical identification and stores request documentation exist. A comparison of the material traceability markings on the items with those recorded on the stores request showed that 20,214 had matching identification numbers. Of the 953 non-matching identification numbers, 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, 97% had equivalent identification numbers.
l -
I
~
I III-2 Identification numbers on 344 of the remaining 563 items, though deficient in minor respects, were readily determined to be traceable. 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 99%. The remaining 1% (219 items) failed to g have equivalent matching numbers and required further evaluation to y determine traceabilitv.
I
~
The success rate of 97%, or 99% if the readily reconciled recording errors are l counted, provides adequate assurance to conclude that the ASME-accepted Stores Request System used by PCCo was a reliable system for establishing m ' dal traceability at the time of installation. Moreover, verification of the Storea dequest 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. Poysical identification numbers on items with partially visible characters are to be expected given the f act that the inspections under the MTV Program were conducted many months and, in some instances, years after their installation. Partially obliterated markings resulted from l construction activitie. 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 idemification could be reliably matched with a valid traceability number on the applicable stores request.
p
,b .
III-3 Partial physical identification missing two digits or less had to meet the L following acceptance criteria before they could be considered a match with the corresponding stores request. First, the heat number log was reviewed to determine whether the apparent partial physical identification was not itself a valid traceability number. If the partial marking was not a valid traceable ,
I number, a review of the heat number log was conducted to determine that the
' partial marking could not be identified with more than one valid traceable identification number. If the partial physical identification passed both tests it was considered a match with the Stores Request identification number.
The 344 minor recording errors referred to above were only considered readily traceable if the differences between the identification numbers 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 A24B1 is assumed, A42B1 would be a transposition that was readily corrected and, therefore, traceable,
- b. A difference involving the improper substitution of no more than one j character. For example, if a valid traceability 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, 4111 A 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 items were neither (i) traceability numbers nor (ii) potentially traceable to more than one valid l traceability number.
III-4 Table III-l 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 which were traceable to the stores request by a heat code or serial number system included in the documentation. The third column gives the number of items which 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 number of items whose stores request and field markings could not be reconciled.
1 Having determined the reliability of the Stores Request System, 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 traceability achieved in fact.
- 2. VERIFICATION OF MATERIAL TRACEABILITY As provided in the ASME code, traceability was determined when a valid heat I number or spool serial number, or heat code could be identified from either a physical identificatior. on the item or the traceability number recorded on the i corresponding stores request. The identification numbers on either the installed items or the stores request were verified by crosschecking the PGCo heat number 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) numbers, material type, grade and class for ASME material. The information 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.
I E
E
111-5 Out of a total of 25,815 items reviewed in the MTV Program, traceability I was established with respect to 25,023 items. NCR's were written on 792 items (3%).
NCR's were written in each case when material traceability was In some instances, material traceability was considered a potential question.
subsequently established through the dispositioning process; nevertheless, 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 The 792 items are categorized in the following manner:
- a. For the category of items with both physical identification and stores it.ms), NRCs were written questioning the request numbers (21,167 219 items has nonmatching identification traceability of 293 items. The numbers that could not be reconciled as discussed in Chapter !!I.
remaining 74 items included some items with matching numbers but which could not be verified by reference to the heat number log or other documentation reviewed at the time. Also included in the 74 items ar 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 traceability of 349 items. 1 For items with physical identification only ($77 items), NCRs were 8 c.
written questioning the traceability of 69 items. I S
1 A separate Nonconformance Report (NCR) was issued outside the MTV Program respect to 570 piping spool items that had missing nameplates. Although piping i traceability requirements were confirmed within the MTV Program by reference to !
identified spool records, additional verifications are being S Review of approximately 500 spools requirements concerning removal of nameplates.with missing namepla p;
v~
still being reviewed.
i h
ww
. . 5 III-6
- d. For items with neither stores requests nor physical identification (81 items), NCRs were written questioning the traceability of all of the items.
Table 111-2 distributes the above data for small bore piping, large bore piping, and integral attachments. The MTV Program included ASME Class I,2 and 3 large and small bore piping and integral attachments. This is the case even though unique heat number traceability is not required by the ASME Code for I all these items. The traceability findings in Table 111-2 separates those items l 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 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 INSTALLATION ACCEPTABILITY In addition to material traceability, the MTV Program reviewed the acceptability of installed items by comparing them against the installation specification2 for the item. The purpose of this comparison was to verify correct pipe schedule, correct grade, type and class of material was withdrawn -
from stroes. In order to determine material installation acceptability, additional documentation 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 documentation review and a field l dimensional check, where practical. In all cases where the insta!!ation did not l conform to the installation specification, a PGCo NCR was written. Not until l the NCR was resolved, however, could the acceptability of installation be determined.
l 2
5 argent and Lundy Specification for Piping System Installation (Section III Portion),
F/L-2739.
E f
I
111 - 7 The review of material installation acceptability included dimensional checks of installed piping, when practical, to verify that the installed pipe schedule was as described in Certified Material Test Reports or other material docu-ments, 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.
Material class is questionable for certain Class 1 items because of possible lack of evidence of non-destructive examination (NDE) on what appears to be Class 1 piping material. This matter was identified by Phillips, Getschow Company as a separate concern unrelated 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 I material has been exempted from this requirement. This evidence can be in the form of markings on the items or in supporting documentation. Results of the review for evidence on NDE for Class 1 piping material are presented in Appendix B of this report.
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; 10 items were of lesser poundage / schedule than stated in the installation specification;
- c. 12 items were of different grade / type of material than stated in the installation specification; h
1
= .
III-8
- d. 46 items were of a lower class material than stated in the installation specification;
- e. 18 items had digital thickness measurements less than required by the material specification; and 4
- f. 25 items failed to meet the installation specification for various other reasons.
These results are presented in Table 111-3. The disposition of the NCR's covering the 135 items is discussed in Chapter IV.
- 4.
SUMMARY
The Stores Request System has been shown to be reliable based on examination of 21,167 items for which both stcres request and physical identification is available.
1 Out of a total of 25,815 items covereo by the MTV program,792 items are the subject of NCR's because of traceability issues, and 135 items are the subject of NCR's because of material acceptability issues. The distribution of these items by type of item is given in Table III-4.
.t i
I
. i
' ~ e ,
, _ - , . , . - . ... - - , . . . . , , . - _ _ , - - - _ _ . - _ _ _ . - - _ - - - - , . - - -,m.. - - - . _
l- .
Figure 111-1 I Material Traceability Verification (MTV)
Items verified by physical inspection and/or review of stores request (SR) documentation (25.815 items)
I Physical ID and SR SR only Physical ID only No physical ID and no SR (82.0%) (15.59.) (2.2%) (0.3%)
21,167 items 3.990 items 577 items 81 items I
I I
l I
E E
I f
f
- " ~ ~ '"-'
I
Table 111-1 Distribution of items with Physical Identificat. n Verifying the Stores Request l
Field Markings le d M rkings Partial and Stores Request and Stores Matching Physical ID Recording Error Do Not Agree Request identification Same item Same item item Category 179 131 126 Smatt bore 11,471 11.035 8,998 200 197 84 Large bore 9,479 11 16 9 Integra! 217 181 attachments 390 344 219 Total 21.167 20.214 i
h i
I I
I I
I - !
I f
_, ,,,.,0
, 4, l
. , . . , _ _ . _ _ , . . . _ . ~ . _ , . . . _ _ . . - . _ _ _ . _ _ _ _ __ .._ . _ _ _ _ _ _ _ _ . . _ . _
I Table 111-2 Distribution of items by inspection Category l and Traceability Findings I No Physical ID and Physical ID and Physical 10 but with Stores Request Physical ID and Stores Request No Stores Request No Stores Request Are Present Traceability Traceability Traceability Trac eability NCR' NCR* Items NCR* Items Cat e gory items NCR* Items 31 2,244 16 11.471 146 Small bore 24 24 202 72 15 282 1 -- 40 Traceability 7 7 required 106 i 1,962 15 --
Traceabil:ty not 17 17 130 16 required by ASME cc0e I Large bore 44 44 359 37 1,500 303 9.479 137 66 Traceability 18 18 171 21 327 62 --
required 16 1.173 241 -- 71 Traceab'tity not 26 26 168 recuired by ASME coda integral 217 10 attachments 13 13 16 1 246 30 Traceabaty 0 0 5 0 5 0 -- O required 11 241 30 -- 10 Traceabihty not 13 13 1 required by ASME coce 577 69 3,990 349 21,167 293 Total 81 81
'Although NCRs were written whenever traceabihty was in question, in most cases, they were dispositioned as acceptable.
S S
S l f
asoo-a is.es os lll.11 S
f 2I
l ,
Table 111-3 Distribution of items with NCRs Because Material Installation Acceptability Was in Question l .
I Wrong Sch.
Cla s s OTM Other Total No. No./Sch. No./Sch. Materlat or < S&L Spec. Questions Questions
> S&L Spec. < S&L Spec. Item Type Category of items I 20 7 5 5 13 0 Small bore 50 4 2 0 0 13 5 2 Traceability 8 required 3 13 0 37 15 5 1 Traceability not required by ASME I code 5 14 5 25 55 3 3 Large bore 4 3 0 12 22 2 Traceab;lity 1 required 1 11 5 13 Traceability not 33 2 1 required by ASME code Integral 2 27 0 0 attachments 30 1 0 0 0 0 0 Traceabihty 0 0 0 required 2 27 0 0 Traceability not 30 1 0 q
1 required by ASME code 12 46 18 25 Total 135 24 10 C
0 0
111 - 1 2 esm-e is.es nas g 4
1 Table Ill-4 ,
Summary Distribution of MTV Item Findings
- Items with items with Total it em s Traceability NCRs Acceptability NCRs i
Small bore 13.941 217 50 Large bore 11.382 521 55 Integral attachments 492 54 30 Total 25.815 792 135 l
- Dees nct inctade NOE marking issue discussed in Appendix 8.
i l
l l
l l
l l
l i
asco-rit.es xps lfl.13
Attachnunt 10.B lg . (DelGeorge - 2)
IV-1 l l
IV. DISPOSITION OF NONCONFORMING ITEMS The absence of both physical identification and valid stores 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 systems 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 5 process in order that each nonconforming condition could be adequately resolved:
- 1. Reinspection by another MTV inspector was employed to ensure a physical marking l
was not overlooked in order to resolve apparent traceability discrepancies.
I 2. Extensive searches of satellite record files and field document stations were made to locate stores requests which were not initially retrieved in order to resolve I apparent traceability discrepancies.
- 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.
l
- 4. In-place material thickness measurements were taken where conflicts in the traceability records prevented verification of material schedule.
l l 3. Engineering review of design parameters and conditions was performed to verify l that conditions found not to conform to the installation specification satisfied minimum applicable ASME Code design requirements.
- 6. Removal and replacement was completed of nonconforming items for which l
traceability, when required, or acceptability was not established.
3 y
u l
B' IV-2 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 documentation was properly utilized and, for each disposition, where no rework was recommended (i.e., use-as-is) that the item was traceable and acceptably installed. A copy of the Naticnal Board's fmal report is provided in Appendix A.
The purpose of the follow mg discussion is to provide a summary of the disposition of all items which 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 presented in Table III-4
- 1. DISPOSITION OF TRACEABILITY NCR ITEMS This section describes the disposition of items identified as nonconforming 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 R
accept-as-is and cut-out ja as follows:
Items with physical identification and stores request -
Total traceability NCR items -
293 items accepted as-is -
230 items cut-out -
63 EI l
E
i IV-3 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 -
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 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.
Column i shows the number of items for which a supplemental documentation search located a stores request copy. The stores request copy was then reviewed to assure it was applicable to the installation. Although counted as traceability NCRs, these items were not nonconforming because a valid stores l request did exist.
I Column 2 shows the number of NCR items which were accepted based on a further investigation of physical identification deficiency. This resolution was i accomplished in two ways. First, valid physical identification was verified by 1
i
IV-4 supplemental inspection. Physical identification initially indicated as missing g was either found or difficult to read numbers were discerned on a second W inspection. These items were not traceability nonconformances because the )
heat traceability numbers did exist. Second, an item was accepted when the physical identification consisted of an original manufacturers' marking process even though the stores request documentation did not agree. Such markings were traceable to valid material docume.atation and, therefore, represent primary evidence of traceability.
Columns 3 and 4 show the number of NCR items which, although identified as nonconforming because cf either errors on the stores request or in the physical identification which made the item potentially traceable to more than one l heat of material, were later accepted based on evaluation. In this evaluation l l
additional inspections of the item, reviews of 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.
Columns 5 and 6 show the number of NCR items accepted because the evaluation indicated that the specified inaterial type, grade, and class of '
material was installed. These items were originally identified as nonconforming because the traceability information identified multiple heat ,
l numbers. A review of the multiple heat numbers established that each number met the material type, grade and class specified in the installation specification. Therefore, the items were accepted. This action is consistent with the ASME Code (Paragraphs NA-3667.4(B) 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 which traceability was established using other Project Quality Assurance documentation. Those items were originally marked as nonconforming because the stores request or physical identification information was inadequate. The traceability information generated by the requirements of Section 5 of the PGCo Quality Assurance Manual was evaluated. This traceability information, which was in E
E
IV-5 the form of traceability numbers documented in the data package, was evaluated to assure that it was applicable to the installation. Also in this column are NCR items 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.
I Column 8 shows the number of NCR items found acceptable by reference to other information, including vendor documentation, to establish traceability for the items.
I 1.B Items Cut-Out ,
l Out of a total of 25,815 items inspected in the MTV program, only 145 items were required to be cut-out due to indeterminate traceability. The distribution of items where traceability could not be established are shown in Table IV-2. As discussed in Chapter V on interpretation of findings, each of those items has been evaluated for design significance.
Column 1 in Table IV-2 shows the number of items cut-out due to multiple heat numbers documented for the same item.
Because supplemental reviev. did not resolve the discrepancy, the items were cut-out and replaced. 25 items were cut-out and replaced for this reason.
Column 2 shows the results of a material usage review performed 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 installation in question.16 items were cut-out and replaced for this reason.
E Column 3 gives the number of items cut-out because neither stores requests nor field markings were located and no other pertinent traceability I
E u
El IV-6 documentation could be found to verify traceability. 59 items were cut-out and replaced for this reason.
Column 4 shows the items cut-out because the physical identifications and/or stores request could not be identified with either an acceptable heat number from the heat number log or other pertinent traceability documentation. 44 items were cut-out and replaced for this reason.
Column 5 includes I item that was cut-cut 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 items identified as nonconforming for reasons of questionable item installation acceptability. The discussion is divided h
W between acceptable items and cut-out and replaced items.
2.A Accept-As-Is items Out of a total population of 135 items identified on NCRs dealing with installation acceptability, all items were dispositioned as acceptable. The distribution of the 135 items that were accepted by the dispositioning process are grouped on Table IV-3. Columns i through 3 set forth the items originally identified as having material characteristics not meeting the Sargent & Lundy installation specification, namely dif ferences in: class, material or item type, or schedule.
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 f Code; and therefore, the class designation was not applicable, o Additional non-destructive testing and/or documentation upgrade was accomplished demonstrating that the material met the class requirements. I l
W
IV-7 l
o The provisions of paragraph NX-2610 in the Winter 1975 Addenda of the t
ASME Code and Code Cases 1713 or N-242-1 were utilized to accept materials for the applicable Class requirements. These provisions al ow alternate means to accept materials that were not originally procured in total compliance with the quality system requirements of the ASME Code.
Allitems of the type discussed above are shown in Column 1 of Table IV-3.
l 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 &
Lundy review demonstrated that either the item was not actually a noncon-I formance or the substitution was acceptable and met the applicable ASME Code design requirements, i
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 I specification. Column 4 identifies those items for which the DTM indicated the thickness was less than that required by the material specification. An NCR was written in each instance. In each case, the item was reviewed by l Sargent & 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 & 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 "DTM WALL VIOLATION" category, the evaluation resulted in the items being accepted as-is.
The fifth column contains all remaining items that were dispositioned f acceptable. All items in this category were dispositioned accept-as-is by 1
Y.
d I
0 1
~
IV-8 locating necessary documentation including vendor supplied documentation when not supplied with the material. 14 items are thermowells which were dispositioned acceptable with the use o' Code Case 1713.
2.B Items Cut-Out g
Out of a total of 23,815 items inspected in the MTV program, no item was W required to be cut-out for reasons of material acceptability.
B B
B B
B B
R R
R R
R:
E E
E
/
Table IV-1 Distribution of Traceability NCR ltems by Dispositbn for Accepta*1ce I
4 5 6 7 8 1 2 3 Recording Stores Physical Error Physic. al lO r Class 1&2 Class 3 Suppl.
Request ID Engineering Engineering Ac c ep.*
- Docu. Other Category Located Located Evaluation Evaluador _
)
$ 3/4"*
- Small boro 7 0 0 9 3 Traceability 3 24 1 required 17 3 3 11 8 Traceabit ty net 6 49* 5 required by ASME code Large bore 0 0 66 11 Traceability 9 17 3 12 required 0 29 240
- 4 l Traceability not 23 28 1 8 required by ASME code
, Integral attachments 0 0 0 0 0 0 0 Traceability 0 required 2 0 5 0 0 18 2 /
Traceability not 20 required by ASME code j --
120 10 49 3 32 344 28 e Total 61 i
- One item from each of these categories was cut out due to a piping reroute, however the items were acceptable.
- Except for items in these cofumns, even though traceability was not required as indicated, disposition 1 ventied unique heat number traceability, i
I I
._,_. .9 g
i i
1 Table IV-2 '
Distribution of Traceability NCR ltems by Disposition for Cutout 1 2 3 4 5 Stores Request No Stores Stores Request Multiple Footage Request and and/or Physical ID Piping Category HT Nos. Incomplete No Physical ID Unknown Other j Small bore ,
Traceability 12 2 0 2 0 receired Traceability not 4 14 13 20 1 l required by ASME 1 coce l
l Large bore Traceability 6 0 28 15 0 required Traceability not 2 0 15 4 0 recuired by ASME Code Integral attachments Traceability 0 0 0 0 0 required Traceability not 1 0 3 3 0 required by ASME code Total 25 16 59 44 1 1
I i
ll l
esco-e ti-es os IV-10 1
i l
Table IV-3 l Distribution of Insta!!ation Acceptability NCR ltems by Disposition for Acceptance 3 4 6 1 2 Wrong Wrong DTM Wall Other wrong Class Material Schedule Violation Piping Category Small bore 4 7 0 0 Traceability 2 required 1 20 13 0 Traceabihty not 3 required by ASME code Large bore 4 0 12 Traceacihty 3 3 required 3 5 13 Traceability not 11 1 required by ASME code Integral attachments 0 0 0 0 Traceability 0 required 2 1 0 0
- Traceability not 27 required by ASME code 11 35 18 25 Total 46 I
8 8
8 g _ , . , _ ,
' Attachment 10.B (DelGeorge - 3)
VI-l VI.
SUMMARY
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 identification and stores request identification.
E o 20,214 items (95%) had matching field and stores request identification without resort to supplemental records.
o 20,604 items (97%) had matching field and stores request identification af ter reconciliation of partial field identification.
o 20,943 items (99%) had matching field and stores request identification af ter reconciliation of minor recording errors associated with either the field or stores request identification.
o Only 219 items (1%) had field and stores request identification that could not be reconciled based on the initial document review.
l l
Based on the above results, the Stores Request System is judged to be reliable. l
(
- 2. Of the 25,313 items reviewed, only 792 items (3%) had apparent identification discrepancies that brought into question the traceability 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 (0.5%) of the total items verified (25,815) were required to be cut-out.
E n=
a
VI-2 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.
- 3. Of the 25,815 items reviewed, only 135 items (0.5%) had apparent acceptability discrepancies that brought into question the acceptability 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 demonstrated to be ef fective.
- 5. On the basis of the demonstrated acceptability of materials 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 identified by the MTV Program, no discrepancy was determined to have design significance in as much as all discrepant items, including those few items (0.5%) cut-out based on irreconcilable records, are judged to be within ASME Code design requirements. No discrepancy was shown after analysis and testing to have more than minor significance. On this basis, all items reviewed under the MTV Program were verified as capable of satisfying their safety-related function.
A 14 tu w
Attachment 10.B e
Ef r National Unarb of Uniler anii (Jrrasurr 11cunel iny(DelGeorge . u u u. - 4)
- . s. w . - i . .
BDasi;, of TRU$'f E$ e ;6
- 1. a
.., . . --; .qz';
+ .- . . . . ,. ..
( -
t"'.- 4 ..
. 1979 66- 1985 -
e., . s v.. c. 4%$ains m' , ,. ,
September 26, 1985 Mr. Cordell Reed, Vice President Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 I
SUBJECT:
National Board Audit of the Braidwood Nuclear Power Station Units 1 & 2, Braidwood, Illinois Material Traceability and Verification Program (MTV) ,
, Supplementary Report l l
4 lI
Dear Mr. Reed:
Commonwealth Edison Co=pany (CECO), in a letter dated November 9, 198!. to l Mr. S. F. Harrison, then Executive Director of the National Board of Boiler and Pressure Vessel Inspectors (NBBPVI), requested the National Board to conduct 4 an independent audit of the Braidwood Station. D e purpose of the audit was to I address specific Nuclear Regulatory Commission (NRC) concerns about ASME fabri-cation at the Braidwood site. The National Board Audit Team (NBAT) arrived on f !
the Braidwood Nuclear Power Station site on February 18, 1985. I I
Of the various ASME concerns which had been identified by tae NRC, the one of price li '
interest to the NBAT was the Material Traceability and Verification Program (MTV).
The MTV program was initiated because of concerns raised by the NRC and others I about the receipt, release, control and identification of materials used in the construction of the ASME Code piping systems at the Braidwood site. It was their contention that the ASME Code required. documented verification of material identifi-I cation and acceptability for use at the point of installation by quality control personnel. The NBAT was requested to make an evaluation of the adequacy of the Phillips, Getschow Company's (PG-Co) " stores request system" for providing ASME Code l required material traceability. The NBAT was also requested by CECO to assess the scope and adequacy of the MTV program as-a corrective action method to identifv and '
disposition any items whose traceability was indeterminate.
To accomplish this evaluation, the NBAT initially undertook an assessment of the
" stores request system" as described in the current PG-Co quality assurance program manual and all historical revisions. Having completed this evaluation, the NBAT I is of the opinion that there is no basis for believing that PG-Co's quality assur-ance program, as described in the quality assurance manual, did not meet the require-ments or intent of'the 1974, Winter '75 Addenda of the ASME Code,Section III, i
lg Para. NA-4441. This, we believe, is also consistent with the opinions of the
i .
A-1 4
l -
Page 2 Commonwealth Edison Company MTV Supplementary Report Septe=ber 26, 1985 While the NBAT is of the opinion that the PG-Co's Q. A. Program met ASME Code I
require =ents, we also recognized that there were deficiencies in its imple=en-tation. These deficiencies were specifically in the areas of: -
A) Transfer of material identification after cutting and prior to installation.
B) Loss of contrcl docu=ents 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 MW precedures and work instructions.
- 2) Perfor= an overview of disposition of nonconformance reports (NCR's) which were material traceability related.
- 3) Conduct an audit of .E data input, including PG-Co stores requests only.
- 4) Perfor= an audit of the current PG-Co Material Identification and Traceability Program.
The toilowing acions o' this report describe the NBAT's actions and conclusiens of Ite=s 1 through 4 above.
MTV PROCEDURES AND WORK INSTRUCTIONS:
PG-Co MTV Procedure B31 and I=plementing Work Instruction PGWI-17 were evaluated. The procedures addressed only large and small bore piping g materials, including fittings and attachments, as well as stamped piping 5l subassemblies. Further, the MTV procedures addressed only large bore itees 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 i systems by quality control inspectors trained to the requirements of the MTV 3' procedures. During the walkdowns all material identification markings were E' 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, grade, type, size, schedule, class, heat / lot or code number and quantity, along with the drawing number against which the items were issued.
The procedures also required that the traceability data gathered be verified to certified material test reports (CMIR's) or Code data reports and procure- 3 5
ment documents as traceable items for correct material specification, type, grade, class, size and schedule.
A-2
N
- g. ,
rG Pane 3 b Commonwealth Edison Company MTV Supplementary Report September 26, 1985 O
Further, the procedures required that items not traceable to the material C
certifications through physical markings on the items or documentation b (s tores requests) traceable to the items be considered unacceptable, and be documented on NCR's and dispositioned in accordance with ASME Code R requirements.
LJ NBAT Opinion The NBAT is of the opinion that the procedures and work instructions
" contained an effective method of confirming or denying material traceability within the scope of the PG-Co quality program used p
for installation of items at the Braidwood station.
J
- 2. NOSCONFORMANCE REPORT OVERVIEk':
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 Com=onwealth Edison, Sargent & Lundy, and Phillips, Getschow to insure compliance with ASME Code requirements. This commitment was made during the week of May 27, 1985, and our activity began June 3, 1985. The NEAT actively participated in the review for disposition of 85% of all MTV related NCR's. Our records indicate that 366 NCR's were written against 726 individual ite=s. The NBAT provided an independent overview of 310 of these NCR's.
NBAT Opinion _
'Ihe NBAT is of the opinion that the dispositions approved by the Certificate Holder (PG-Co) and Owner (CECO) and accepted by the Authorized Inspection Agency (AIA) will result in Code compliance for those specific items.
- 3. AUDIT OF MTV DATA INPUT:
The NBAT prepared an audit plan and checklists designed to confirm the validity of the MTV data input. In order to provide an unbiased audit sample of suf-ficient size cot:rrensurate with the NBAT manpower level, it was determined that it would be necessary to utilize PO-Co's quality control personnel to provide the reverification walkdowns and input data for the NBAT's use. To accomplish this, the NBAT randomly selected 20 small bore and 30 large bore piping )frV packages used by PG-Co. The original MTV files were signed out to the NBAT and locked in our files to preclude PG-Co's quality control per-sonnel access to the original data.
PG-Co was then requested to prepare MTV verification, packages in accordance with its MTV procedure QCP-B31 and to reinspect the items in each package as had originally been done. These packages, along with any additional documen-tation required for validation, were then compared by the NBAT to the data
)
4 A-3 I.$h
. .. o Page 4 Commonwealth Edison Company MTV Supplementary Report September 26, 1985 in the original MTV data packages. This verification was done in accordance with the NBAT's " Verification of E' Data" instruction and checklist.
The sample size was 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 NBAT deter =ined 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 approxicately 613 individual items based on an average of 13 ite=s per package. The sample size represents 2.3*. of the entire population of MTV itecs.
In addition, the NBAT conducted an audit of 50 installed itecs whose trace-ability was established based on a stores request docu=ent only. The audit confir=ed the integrity of the stores request system.
NBAT Opinion The NBAT found that the scope and accuracy of the MTV program as implemented and confirced 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-Ce quality assurance program and the ASME Code.
- 4. AUDIT OF CURRENT PG-CO MATERIAL TRACEABILITY:
1 ne NBAT conducted an in-depth implementation audit of the current PG-Co procedures QCP B4.0, B4.1, and B4.2 during the period from June 10 to July 12, 1985. 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.
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 n e NEAT audit conclusion is that the procedures presently in effect contain the necessary controls to insure material traceability and identification. Our audit results also indicate that the procedures are being implemented. '
A-4
...o Page 5 Co==onwealth Edison Company KTV Supplementary Report Septe=ber 26, 1985 GENERAL CONCLUSIONS J
The NBAT has coce 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 the work did performed provide the necessary controls to assure thatthe CECO Braidwood Nuclear P by PG-Co at ments of the ASME Code and the certified design specification.
f
... As noted previously in this report, there were imple=entation deviations f ro:- the PG-Co quality assurance program's requirements.
These deviatiens led to the generation of the MTV program and the resulting revisions to the PG-Co quality assurance program and material ;
control procedures. I The NBAT accepts the MTV progran as a corrective action. The purpose of corrective action is to:
a) document conditions which are adverse to quality.
b) deterrine the cause of the problem.
c) take corrective measures which will correct and prevent the recurrence I of the problem.
This, we believe, has been done.
I Based on our review and audit found that of data co= piled by PG-Co and CECO, the NBAT has items where traceability was in question are identified and are being dispositioned in accordance with the requirements of the PG-Co program and the a ASME Code. f It is the NBAT's considered opinion that the corrective actions which were taken to correct d d iciencies in the caterial control procedures at the Braidwood site are f ef fective and have identified those instances where material traceability may have ,
l 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 our 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.
N l A-5
..Y
... g Page 6 Cocrnonwealth Edison I
W MTV Supplementary Report September 26, 1985 Respectfully submitted, 0]//' dL DF J. Mcdonald g'
Executive Director l .
C. W. Allison National Board Coordinator
/J9/L Michael T. Sullivan
\
l Tea = Leader fQ"f/
Robert P. Holt Team Member e/ M /k W C. Stephen Lindbeck
\
Team Me ber ohn E. Storrs Team Me=ber DJMcD/ CWA /MFS/RPH/CSL/JES:jsb cc: W. S. Little, hTC, Region III, Glen Ellyn, IL D. R. Gallup, State of Illinois l Terry R. Lash, Dept. of Nuclear Safety, IL l A-6 W l