ML20214V787
| ML20214V787 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/14/1987 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20214V785 | List: |
| References | |
| NUDOCS 8706120297 | |
| Download: ML20214V787 (26) | |
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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: VII.a.1
Title:
Material Traceability REVISION 1
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ISAP VII.a.1 Material Traceability
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC USNRC I.etter January 8, 1985, Issue 11, Materials "The as-built review effort by the TRT included a material traceability check on 33 of the same pipe supports that the TRT had
,6 field inspected. The material traceability was adequate for those 33 pipe supports, with the exception of four material identification discrepancies, as noted in Section 4 on as-built inspections.
In another case, TUEC failed to maintain material traceability for U
safety related material and numerous hardware components. This QA breakdown was identified in an ASME Code survey in October, 1981 yet was not reported to the NRC in accordance with the requirements of 10CFR50.55(e)."
NRC NUREG-0797, Supplements No. 10 and 11 With the issue of NRC NUREG-0797, Supplements No. 10 and 11 the TRT addressed the following areas:
Material traceability for a hanger piece was lost due to several heat numbers listed for different pieces on a receipt inspection report.
Fif teen (15) to twenty (20) hangers lacked material traceability.
Traceability of heat exchanger bolting is missing.
TUEC failed to maintain material traceability prior to October, 1981.
Heat numbers for material used in safety related applications were assigned improperly in the field.
Safety-related bulk pipe joints were sandblasted, which removed all heat markings used for traceability.
2.0 ACTION IDENTIFIED BY NRC
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Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT."
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1 Pcgn 2 of 25 RESULTS REPORT V
ISAP VII.a.1 (Cont'd) 2.0 ACTION IDENTIFIED BY NFC (Cont'd)
" Address the root cause of each finding and its generic implications..."
" Address the collective significance of these deficiencies..."
" Propose an action plan...that will ensure that such problems O
do not occur in the future."
3.0 BACKGROUND
I Issues identified by the TRT trere addressed in the following manner:
Material identification discrepancies on pipe supports were addressed by Action Tian VII.b.3, " Pipe Support Inspections."
TUGC0 feilure to report "a significant breakJcvn in any p'
portion of the quality assurance program...", under the d
provisions of 10CFR50.55(e) was addressed by this Action Plan.
." Material Traceability Controls in the Procurement Process,"
i.e., through manufacturing and receipt inspection at the site, were addressed by Acti.on Flan VII.a.9, " Adequacy of Purchased Safety-Related Material and Equipment."
Material control / traceability issues associated with the below listed action plans were included in the evaluations j
performed durin'g,the implementation of this action plan:
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4 Action Plan VII.c, " Construction Reinspchtion/Documentction Review Plan" Action Plan VII,b.1, "Onsite Fabrication" Additional background information was included in the Safety
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Evaluation Keport Supplement on QA/QC issues (SSER #11, May 1985).
Under Category SE, Materials Issues, the TRT addressed eight
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allegations relating to material traceability. These allegations
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ranged from ttie improper marking of " scrap" matedal. v.fch heat i
l numbers of acceptable material to the upgrading of "nonsafety-gr.ade" material to " safety-grade" through'the use'of j
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1 Pcgo 3 of 25 RESULTS REPORT p3 ISAP VII.a.1 (Cont'd)
3.0 BACKGROUND
(Cont'd) interoffice memos or other unauthorized means. The areas delineated in Section 1.0 are examples. The TRT could not substantiate seven of the eight allegations. The one alleSation that was substantiated related to the findings of the October 1981 ASME Code survey of Brown & Root. The TRT QA/QC Group concluded "that the allegations and concerns identified with respect to materials have neither quality significance nor generic implications. The material identification problem, which existed in the early years, was corrected. The other concerns could not be substantiated or pertained to activities that were conducted in accordance with acceptable procedures."
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology This Issue-Specific Action Plan assessed the adequacy of the O
material traceability and control systems implemented during construction at CPSES.
The following tasks were implemented to achieve this objective:
Assured that Action Plan VII.c, Construction Reinspection / Documentation Review, provides requirements for verification of material traceability as appropriate.
l Evaluated the 1981 ASME B & PV Code Survey results and Brown & Root corrective action.
Reviewed Brown & Root and TUGCO procedures for establishment of material control measures.
Reviewed results of Action Plans VII.b.1, VII.b.3, and VII.c for deficiencies and/or adverse trends related to material control.
Reviewed external source findings, such as SSERs, NRC RIV Inspection Reports, and other management evaluations, related to material control to assure resolution of findings and for adverse trends or programmatic deviations, s g b
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1 Page 4 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The specific methodology was as follows:
4.1.1 Interfaced with the Issue Coordinator of Action Plan VII.c to ensure the Construction Reinspection / Documentation Review Plan included 4
verification of material traceability requirements during the course of the reinspection process in order that a final determination of the overall adequacy of the control methods and procedures could be reached.
4.1.2 Evaluated the procedural controls that are in effect for material control against requirements of 10CFR50 Appendix B, Criterion VIII and the FSAR to determine if these requirements were and still are included.
4.1.3 Evaluated the TRT finding regarding failure to maintain material traceability as identified in the October, 1981 ASME Code survey. This evaluation was to be O.
conducted in sufficient depth to determine the root cause and generic implications of the original ASME Code finding and whether TUGCO's corrective actions in response to the ASME Code Survey were appropriate.
4.1.4 Reviewed and identified all SSER findings relating to material traceability and verified action is being taken to resolve the findings.
4.1.5 Reviewed the results of Action Plan VII.b.3 to verify that the concerns regarding material traceability of pipe supports have been properly addressed, and to identify any root cause and/or generic implications that could have an impact on material traceability.
4.1.6 Reviewed the results of Action Plan VII.b.1 to determine if the concerns regarding material control / traceability involving onsite fabrication shop activities have been resolved and to determine if any root cause or generic implications were identified which could have an impact on material control / traceability. Also reviewed and analyzed the deviations referred to this action plan by the Issue Coordinator of Action Plan VII.b.1 for impact on material control / traceability.
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ISAP VII.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.7 Reviewed the results of Action Plan VII.c for deviations related to material traceability. Performed an evaluation of deviations identified for Action Plan VII.c populations to determine if there are any adverse trends or any impact on the overall adequacy of material traceability. Reviewed root cause and generic implication evaluations to identify items that might impact this material traceability evaluation.
4.1.8 Reviewed the results of other action plans for any adverse trends or impact on material traceability that were identified. Also reviewed the same reports for root cause and generic implication evaluations which could impact this material traceability evaluation.
4.1.9 Conducted a detailed analysis of the data from the reviews in paragraphs 4.1.1 through 4.1.8.
Data were analyzed to determine if the implementation of the material control systems has met the requirements of 10CFR50 Appendix B, Criterion VIII and the FSAR.
4.2 Participants Roles and Respons..lities 4.2.1 TUGCO, CPSES Proj ect 4.2.1.1 Scope TUGC0 assisted in identifying and locating applicable information and documentation to support the review team activities.
4.2.1.2 Personnel Mr. D. W. Snow TUGC0 QC Coordinator 4.2.2 CPRT QA/QC Review Team 4.2.2.1 Scope The QA/QC Review Team assessed the adequacy of material traceability and control to assure that only correct and accepted material, parts, and components are installed and used at CPSES.
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1 Pags 6 of 25 L'
l-RESULTS REPORT 1
ISAP VII.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Personnel (Prior to March 1, 1986)
Mr. J. L. Hansel QA/QC Review Team Leader Mr. S. L. Crawford Issue Coordinator 4.2.2.3 Personnel (Effective March 1, 1986)
Mr. J. L. Hansel QA/QC Review Team Leader Mr. G. W. Ross Issue Coordinator 4.2.2.4 Personnel (Effective February 26, 1987) 1[
Mr. J. L. Hansel QA/QC Review Team j.
Leader
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Mr. V. J. Barish, Jr.
Issue Coordinator 4.3 Qualifications of Personnel No inspections were required during the implementation of this Action Plan; therefore, inspection personnel certified in accordance with ANSI N45.2.6 were not required. Inspection personnel who performed inspections under Action Plans VII.b.3 and VII.c were certified in accordance with ANSI N45.2.6.
Other participants were qualified to the specific requirements of the CPRT Program Plan.
4.4 Procedures Checklists, guidelines, data sheets, and matrices were developed as an integral part of the evaluation. These are retained in the Action Plan working file to support the conclusions.
4.5 Standards / Acceptance Criteria Material traceability activities shall be in compliance with 10CFR50, Appendix B, Criterion VIII
" Identification and Control of Materials, Parts and Components" and the associated
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commitments of CPSES/FSAR paragraph 17.1.8.
Specifically, such activities are acceptable if:
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Page 7 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5.1 Measures have been established to identify and control materials, parts and components through receipt, storage, fabrication, erection and installation.
4.5.2 Identification of such items is maintained by unique identifier either on the item or on records traceable to the item.
4.5.3 Where identification marking is employed, the marking is clear, unambiguous and indelible.
4.5.4 Where required, items can be traced to drawings, specifications, inspection, test or other records.
4.5.5 Such control measures are documented in procedures and are properly implemented.
O 5.0 INPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The following sections describe the evaluation performed and the results obtained during the implementation of this Action Plan.
5.1 Review of Action Plan VII.c Development The Issue Coordinator for this Action Plan interfaced with the Issue Coordinator and the discipline and population engineers responsible for the development and implementation of Quality Instructions (QIs) for the appropriate VII.c populations to ensure that the implementation of VII.c included the appropriate verification of material traceability requirements. It was determined that the VII.c Quality Instructions (QIs) addressed the applicable requirements for material control and traceability contained in the codes and standards to which TUGC0 was committed.
However, it was recognized that many of the applicable codes and standards were silent regarding specific traceability requirements for some types of materials / commodities, particularly in the electrical and instrumentation and control disciplines. As a result, some QIs do not address traceability attributes. Because the NRC and members of the QA/QC Review Team had expressed an interest in the degree of traceability maintained by TUGC0 for certain of these items, O
investigations into these areas were performed.
The TUGCO practices for maintaining traceability of electrical cable,
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1 Page 8 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) cable tray and conduit, cable tray supports, cable splice and termination kits, and electrical and mechanical equipment replacement parts were determined and are discussed in Section 5.9 of this report.
5.2 ASME Survey - October 1981 In October 1981, the ASME performed a survey of the Brown &
Root QA Manual and its implementation as a prerequisite to renewal of the Brown & Root "N" Certificates which were due to expire in January 1982. Among the negative ASME findings contained in their report dated 11/23/81 were two (2) that pertain to material control / traceability.
For the first item, II (C)(2), the report stated that the survey team identified plate material in the production shop with work in process that had not been receipt inspected. In addition, the material had not f-'s been identified as required by the Brown & Root
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purchase order.
Brown & Root had divided the material and transferred the material identification incorrectly. At the time, Brown & Root practice did not include the QC verification of the transfer of material identification. During the survey team review of the B&R QA manual, B&R stated that this verification was unnecessary.
(The TRT review of the Brown & Root manual in effect at the time of the ASME survey and of the currently applicable procedure concluded that QC verification of heat numbers was, in fact, required prior to subdividing. This interpretation was not substantiated by the QA/QC Review Team review of the procedure in effect at the time of the survey.)
For the second ites, II(F), it was stated that component supports were procured by the Owner as Code stamped items. The component support was supplied to Brown & Root by the owner with only the Code Data Report. As a result of design changes, many of the owner supplied supports could not be used. B&R instituted a support salvage program to reuse the materials. Brown & Root cut the component support, removed the welds, and used the material to fabricate other component supports. Brown & Root did not have the Certificates of Compliance for the material.
A written responae to the October 1981 survey was provided to the resurvey team leader at the time of the resurvey in January 1982 that addressed the traceability items as follows:
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1 Paga 9 of 25 RESULTS REPORT
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ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Corrective action for item II(C)(2) stated that NCR M-2971 had been initiated; that the material in question had been receipt inspected and found to be acceptable; the material had been identified with the entire heat number; and that the piece that had had the heat number transferred erroneously had been replaced.
B&R actions taken to prevent recurrence had been to revise the QA manual and appropriate procedures to require QC verification and documentation of transfer of markings for correctness prior to dividing the material. These revisions also applied to bundled material prior to division of the bundle.
For item II(F), the corrective acticn stated that NCR M-3131 had been initiated to centrol the deficiency identified by the survey team; that the vendor (NPSI) had been requested to provide Certificates of Compliance or Material Test Reports traceable to their
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identification (MIC) number, stating the type and grade of material being supplied; and that quality engineering would review the documentation provided by NPSI to assure acceptability of the documentation and material supplied.
(These actions were completed and NCR M-3131 was closed on 1/11/83.) The action to prevent recurrence consisted of placing the hanger salvage program on hold pending receipt of proper documentation from the vendor.
A letter dated March 19, 1982 from the ASME to Brown & Root following the resurvey, transmitted approved Certificates of Authorization indicating that the resurvey found the Brown &
Root corrective actions acceptable. However, the letter also stated that the corrective action for item II (F) vs.s in programmatic control but that additional time was needed for
" complete resolution of work already completed". The letter further stated that an unannounced audit uould be conducted some time during the life of the Certificates.
Another letter from the ASME to Brown & Root, dated June 23, 1982, stated that an unannounced audit had been conducted on May 7,1982, that a favorable report was submitted by the auditor, and that no further action was required.
The methodology for this Action Plan required a determination (f g) of root cause and generic implications of these ASME findings l
and an evaluation to determine if TUGCO's corrective actions
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Page 10 of 25 RESULTS REPORT s/
ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) were appropriate. Using the limited material available the most likely root cause was determined to be insufficient detail in the Brown & Root QA Manual. This lack of detailed requirements resulted in a limited inspection requirement in the procedure rather than an inspection requirement in each case. Specifically, QC verification of the transfer of ID markings on bulk material prior to separation or cutting was required on a random surveillance basis and documented once per shift on an inspection report. Craft was required to
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maintain a Material Identification Log (MIL) for each hanger package and each MIL was verified by QC.
Brown & Root corrective actions were to revise the QA Manual and procedures as previously detailed above.
Generic implications are that procedures involving material traceability characteristics and also other implementing procedures may have lacked aufficient detail because of the O
lack of detail in the QA Manual. Applicable procedures addressing the material traceability issue were revised and were acceptable to the ASME. Procedures nor specifically addressed by this actica plan were addressed by other action plans. The overall evaluation of procedural adequacy will be addressed by Collective Evaluation.
The corrective action taken in response to the ASME survey findings was evaluated by the ASME resurvey team, including consideration of work already completed, and found to be acceptable. This, along with the report of the subsequent ASME survey in October 1984 that did not identify problems in this area, leads to the conclusion that the corrective actions taken by Brown & Root were appropriate.
The evaluation of onsite fabrication performed under Action Plan VII b.1 confirms that the current ASME program, including the hanger salvage program, is effective in maintaining material traceability.
USNRC letter of January 8, 1965 referenced the 1981 ASME Survey and indicated that the material traceability issues identified therein were not reported in accordance with 10CFR50.55 (e). Based upon the discrepancies identified for
- material traceability during the 1981 ASME Survey, the ASME Survey Team did not identify a "significant breakdown" in the material traceability program practiced by Brown & Root. The
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ASME decision, based upon their total findings, was to allow the NA and NPT certificates to expire, not to revoke them. A f
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ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) revocation would have signaled a significant breakdown and would have been reportable. Therefore, the QA/QC Review Team concludes that this issue was not reportable in accordance with the requirements of 10CFR50.55(e).
5.3 Current Program Review When governing codes and standards, e.g., ASME B&PV Code, require traceability to the point of installation, applicable procedures must provide for the maintenance and documentation of traceability.
For other items / material, the requirement is to provide sufficient control to preclude use of unacceptable material. The techniques utilized to achieve this may vary depending on the nature of the material being controlled.
Current procedure indexes were reviewed to identify procedures, by title. that might contain material control / traceability requirements.
Identified procedures were O
then reviewed to identify those that contained requirements, references or instructions for traceability of material.
These were then reviewed to determine whether inspection and/or verification of traceability requirements were addressed and to determine if there were requirements, references or instructions for the documentation of traceability characteristics. A listing of procedures reviewed and the review results are presented in Attachment 1.
Construction procedures addressed the related craft activities, e.g., transfer of heat numbers, and generally referenced " appropriate" or " applicable" procedures for inspection and documentation requirements.
Inspection procedures addressed traceability inspection and/or documentation requirements, as indicated below.
Receipt Inspection - For Q material (including ASHI),
traceability characteristics are inspected / verified and documented. A separate procedure for non-ASNE material addresses material traceability and verification but refers to the procedure for Q material for documentation requirements. Procedures are considered adequate by the QA/QC Review Team.
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1 Pags 12 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Civil - For structural and miscellaneous steel that is ASME-related or is utilized for seismic applications, traceability characteristics are inspected / verified and documented. Cable tray supports, conduit supports, electrical equipment supports or attachments associated with these supports do not require material identification or an MR for materials conforming to ASTM A-36 or ASTM A500 Grade B specification.
Mechanical - Traceability characteristics are inspected / verified and documented for permanent plant "Q" equipment, ASME-related piping and supports and seismic category II supports.
Electrical - Traceability characteristics are inspected / verified and documented for cable,. splice and-termination kits. Traceability characteristics for cable tray and conduit are not addressed in current procedures. TUGC0 has no commitments in'this area.
Instrumentation - Traceability characteristics are inspected / verified and documented for the fabrication and installation of instrumentation tubing.
Inspection procedures address the traceability requirements to which TUGCO is committed. They are deemed to be adequate.
Further discussion pertaining to the TUGC0 traceability practice for ASTM A-36 and A-500 Grade B steel and other specific types of material as related to current industry practice is contained in Section 5.9 of this report.
5.4 External Source Issues l
l SSER findings and other external source issues that have been j
identified by the CPRT as being applicable to this Action Plan were evaluated and the QA/QC Review Team concurs with the TRT or other source conclusions as restated below:
The topic of the "four material identification I
discrepancies" discussed in the NRC letter of January 8,1985, is addressed in the ISAP VII.b.3 Results Report.
(Refer to Section 5.6 of this report).
One item identified by the NRC addressed the lack of traceability identified in the ASME survey of Brown &
Root in October 1981. This item is discussed in Section 5.2 of this report.
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RESULTS REPORT ISAP VII.a.1 (Cont'd) l 5.0: IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTb (Cont'd)
Both the Construction Appraisal Team (CAT) report and the Management Analysis Company (MAC) report evaluated the program for material control / traceability. Neither identified adverse findings. The MAC report stated that TUGC0 was expending too much offort in maintaining traceability for embedded items and recommended discontinuing the activities. TUGC0 elected to reduce their effort in this area.
An allegation was made pertaining to the transfer of a heat number of a piece of Q-steel to a piece of scrap steel d'uring the fabrication of a hanger. The TRT was not able to substantiate the allegation and no further action is required.
i An allegation was made that valid heat numbers had been i
transferred to unqualified foreign steel, allegedly Japanese. The TRT investigation could find no evidence
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that this had occurred, or that Japanese steel had been on the project. However, during the TRT evaluation, j
one case of a questionable disposition on a material traceability NCR associated with CAR S-41 was identified and was subsequently resolved.
The final u ternal source item concerned the lack of traceability information in the files for vertical residual heat exchanger bolts. The TRT investigation indicated that although there were no material traceability records in the file ~ for the bolts, the QA system had in fact identified the problem. An NCR had been issued and dispositioned to replace the bolts with some that had traceability. The TRT concluded that appropriate action had been taken.
Appropriate action was concluded to have been taken by TUGC0 to address the confirmed cases of inadequate material traceability. For other issues identified in the SSER the TRT was unable to substantiate the allegations and required no further action. The QA/QC Review Team has reviewed these i
unsubstantiated findings and concurs that no further action is required.
5.5 Review of Action Plan VII.b.1 Results The Deviation Reports initiated during the implementation of Action Plan VII,b.1, "Onsite Fabrication," were reviewed to determine the extent of material traceability problems
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ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) identified. Twenty-five CPRT Deviation Reports docviented material traceability problems. The following is a summary of the review of these DRs:
Traceability in question due to documentation inconsistencies (one deviation)
Material not traceable to a specific heat number, multiple heat numbers identified (four deviations)
Traceability data not recorded on records (four deviations)
Errors in recording traceability data (six deviations)
Record necessary to establish traceability missing from records package (seven deviations)
Hardware mismarked (two deviations)
Generic DR to document that, except for identification of the material specification, traceability was not maintained for cable tray supports (one deviation)
The deviations described in these Devfation Reports were evaluated for safety significance. The deviations were determined to be not safety-significant as related to the hardware associated with the documentation packages evaluated.
Paragraph 5.7 of ISAP VII.b.1 Results Report identified a trend in that document discrepancies were found in a majority of documentation packages reviewed during the implementation of that ISAP. The material traceability discrepancies identified in these deviation reports will be considered with material traceability discrepancies identified in other population deviation reports to evaluate for potential trends.
(See Paragraph 5.10.)
5.6 Review of Action Plan VII.b.3 Results A review of the results of Action Plan VII.b.3, " Pipe Support Inspections," reveals that no traceability problems were identified that were associated with the pipe supports in this I
population. Although some material items in four pipe supports lacked material identification on the item as reported in SSER 11 sufficient alternate documentation was available to confirm that acceptable material was used.
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1 Pags 15 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.7 Review of Action Plan VII.c Results Data generated during the implementation of Action Plan VII.c, Construction Reinspection / Documentation Review, were reviewed to determine the extent of material traceability / material control problems identified during the reinspection / documentation review program.
Over 200 Deviation Reports were identified that pertained to material control / traceability. These were then evaluated and categorized by the Action Plan VII.a.1 Issue Coordinator as to type and cause.
Almost half of the Deviation Reports reviewed were initiated because traceability information was not included in the QA records when required. A little more than half of the remainder were initiated because material control / traceability information was missing from the hardware. Either the O
information had not been applied to the hardware or subsequent operations concealed, obliterated, or destroyed the identification that had been applied. The remaining Deviation Reports identified cases where the material control /
traceability information in the QA records did not match the identification on the hardware. These resulted from incorrect hardware being installed, incorrect identification of the hardware, or incorrectly recording information in the records.
None of the Deviation Reports pertaining to material control / traceability initiated during the implementation of Action Plan VII.c was determined to be a construction deficiency, nor were adverse trends or unclassified trends identified.
Although the reinspection portion of Action Plan VII.c is essentially complete, the final evaluation of all data is incomplete. As a result, there exists a potential for the identification of construction deficiencies or trends applicable to Action Plan VII.a.1.
If this should occur a reassessment of the results of this action plan will be conducted. However, review of the remaining data indicates that no new issues involving material control / traceability are being raised and therefore additional impact on Action Plan VII.a.1 is not anticipated.
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1 Page 16 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 1MPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.8 Review of Other Action Plan Results A review of the Action Plan I.a.1, Heat-Shrinkable Cable Insulation Sleeves, Results Report revealed four instances in which there was apparently no traceability for heat-shrinkable cable insulation sleeves since there had been no QC inspection of the installation. However, since the Action Plan VII.a.1 Review Team determined that traceability by lot number could generally be reconstructed through the use of logs maintained at the Termination Shack, these instances of lack of QC inspection are considered to have no impact on the overall adequacy of the traceability of these items.
A review of the Action Plan VII.b.2, Valve Disassembly, Results Report identified an Out-of-Scope Observation relative to missing code data tags on thirteen valves. This observation was resolved through the issuance and disposition of NCR M-22071. The missing code data tags did not constitute O
a Material Traceability problem since serial numbers were present on the valves. However, the missing code data tags were not documented in accordance with applicable QC procedures; therefore, a deviation report was issued by Action Plan VII.a.1.
Appropriate QC documentation was subsequently generated by Brown & Root.
5.9 Investigation of Other Areas / Commodities As stated in Sections 5.1 and 5.3, TUGC0 procedures and practices were evaluated for adequacy of material traceability control for materials not requiring traceability to the point of installation by codes or standards.
Based on the results of these evaluations, further research was conducted to determine the documentation / traceability requirements for the following categories of materials / commodities:
Cable i
Cable tray / conduit Cable tray hanger Splice and termination kits Electrical equipment / mechanical equipment replacement parts and valve gaskets / packing.
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1 Paga 17 of 25 RESULTS REPORT N-I ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
FSAR Chapter 17 and Appendix 1A(N), Reg. Guides, IEEE Standards, ANSI Standards and quality and construction procedures were reviewed for traceability requirements.
The most significant aspect determined from the review effort was the lack of clearly defined requirements for traceability of materials that are not governed by the ASME Code,Section III. The requirements of the Code are specific. Various Code Cases and Interpretations have further identified acceptable standards for maintaining traceability of safety-related parts, components, and materials.
However, there is not a comparably defined set of guidelines for the traceability of electrical parts, components and material. The general statements in 10CFR50 Appendix R, Criterion VII and in ANSI N45.2, Section 9 are not addressed in detail in IEEE Standards or Reg. Guides regarding traceability of electrical items.
)
In order to evaluate TUGC0 practices for material control / traceability of the above materials / commodities, documentation packages associated with these items were identified. A directed sample of 58 of these packages representing the years 1980 through 1985 was selected for review.
The results of these evaluations, plus the related industry experience of QA/QC Review Team personnel, are discussed below. The discussion of related industry experience is not meant to imply requirements beyond those to which TUGC0 is committed, but is presented for information to assist in understanding the results of this evaluation.
Electrical Cable - Traceability has been maintained by manufacturer's reel number to the point of installation. The current procedures contain this provision. This is consistent with industry practice.
Cable Tray / Conduit - Traceability has not been maintained once the materials have been received, accepted, and warehoused.
Current procedures do not address traceability. The CPSES practice is consistent with industry experience, in that conduit is normally procured as an off-the-shelf item with no specific quality-related characteristics; and cable tray is
()
procured as Q material.
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-s RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Cable Tray Supports - Traceability was maintained for those hangers fabricated by CB&I, but was later discontinued when Brown & Root took over cable' tray support fabrication.
Current procedures require that only Q material is requisitioned for the fabrication of cable tray supports but do not require heat number traceability when ASTM A-36 or A-500 Grade B uaterial is specified. QC verification of the issue of this material to craft is not procedurally required.
The consensus of experience is that specific traceability of bulk material, such as these steels, is not required if adequate controls are in place to assure that only acceptable material is used. For example, it can be the practice of the owner to procure all ASTM A-36 steel as "Q" material. If this is done, then only acceptable material is available for use, and traceability need not be maintained unless otherwise required by codes and standards. However for this to be effective, positive controls must be provided to prevent "non-Q" material from entering the system, or to provide positive identification and traceability for "non-Q" material.
Splice and Termination Kits (Heat Shrinkable) - Consistent with industry experience there is no formal program for traceability of splice and termination kits (heat shrinkable).
Current procedures require control of "Q" material at receipt onsite and during storage. Kit type and lot numbers are recorded by QC inspectors on installation inspection reports.
However, no mechanism is defined that relates this information to purchase orders and receiving inspection records. During the investigation of earlier installations traceability by lot number could be reconstructed through the use of uncontrolled logs and records maintained by the Electrical Tool Issue Room (Terminations) personnel.
These logs and records have been maintained since the commencement of the issuance of these kits and are essentially intact. TUGC0 has committed to permanently retain these records and has included specific instructions in a proposed revision to procedure EEI-10 to that effect.
Maintenance of this log will provide, if necessary, traceability of splice and termination kits to an Receiving Inspection Report (RIR) or purchase order.
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1 Pags 19 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATIO i 0F ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Replacement Parts - Current procedures do not directly address replacement parts, but it is expected that travelers would require the recording or verification of component data. This in itself does not necessarily provide assurance of traceability. During the investigation, it was determined that traceability is maintained for mechanical / piping items on travelers. It appeared less likely that traceability was being maintained for electrical items, particularly in cases in which a component is removed from one piece of equipment for use in another. The consensus of industry experience is that common electrical items, e.g., terminal blocks, relays, etc., should be purchased as "Q" material, identified as such, and relate the issuance of these items to the purchase order through paperwork. The current practice at CPSES provides somewhat less control than is industry practice but does not violate FSAR commitments.
5.10 Evaluation of Findings
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The analysis of the data from the reviews performed during the implementation of this action plan reveals the following:
An overall evaluation of the material traceability deviations identified through Action Plans VII.b.1, VII.b.3, and VII.c indicates that there is no trend of material traceability problems. The total number of deviations identified, less than 300, is very small in comparison to the number of opportunities for error represented by the samples investigated by these Action Plans.
In the majority of cases, the traceability problem was resolved through field observation or location of missing or alternative documentation which confirmed that acceptable material was used. It is highly probable that similar material traceability problems occurring in the remainder of the plant population could be resolved in the same manner.
There were deviations identified, primarily involving ASTM A-36 material, for which traceability as acceptable material could not be established, thereby making the safety-significance evaluation indeterminate.
In these cases, the Action Plan VII.c Population Engineer established a basis to conclude that the lack of traceability would have no impact on O
the ability of the hardware to perform its intended
- function, i.e.,
the lowest grade of material for
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RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) structural purposes, typically ASTM A-36, has a yield strength of 36 kai which is the design yield strength for these applications.
[ Refer to the VII.c Results Report, Appendices 28 and 30 for examples.] The evaluations of the individual material traceability deviations provide a reasonable assurance that similar deviations occurring in the plant populations would have no adverse impact on the ability of the hardware to perform its intended function; and are therefore considered to be not safety-significant.
The TUGC0 program for material control / traceability complies with the requirements of 10CFR50 Appendix B, Criterion VIII, the applicable portions of ANSI N45.2-1971 and applicable codes and standards to which TUGC0 was committed.
Implementing procedures are generally adequate, Os however, several procedures have weak controls which should be reviewed and revised to more positively preclude the use of incorrect material in safety-related applications. Specifically, since September 1983 inspection procedures for the inspection of site fabrication and installation of structural and miscellaneous steel have excluded the requirement for craf t presentation and QC verification of a copy of Material Requisitions (MR) in cases where ASTM A-36 material is equired. A-500 Grade B material was added to the exclusion in September 1984.
Prior to the above mentioned exclusions of ASTM A-36 and A-500 Grade B materials, requirements for identification marking for conduit supports, electrical equipment supports, and associated attachments had already been-deleted from both construction and inspection procedures.
In a program in which only "Q" material is purchased and allowed onsite, these exclusions would be an acceptable practice and are common in the industry. However, as detailed below, TUGC0 has purchased some "non-Q" ASTM A-36 material:
A review of purchase orders issued for structural and miscellaneous steel, specifically ASTM A-36 and A-500 Grade B materials, identified that from January 1981 to date, 20 purchase orders were issued for ASTM A-36 O
material without requiring a QA program; six for welder training material and 14 for other special applications. Of the 20 purchase orders, 13 required material certification.
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1 Page 21 of 25 RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Since the specific exclusion of ASTM A-36 material from' traceability at installation only six purchase orders were identified for non-Q material, two with certification, four without. Intended end use of material was identified in procurement documents in all cases.
All purchase orders identified for A-500 Grade B material required a QA program.
The availability of "non-Q" ASTM A-36 material onsite and the possibility for intermingling and inadvertent use in a safety-related application necessitated the continued overview of craft by QC to insure the use of only appropriate materials in onsite fabricated items. However, QC verification of the issue of "Q" material and verification of that issue at installation were minimized in both construction and QA/QC procedures which resulted in a marginally adequate program i
with regard to these materials.
[
Although deviations involving traceability of ASTM A-36 l'
material were documented in several ISAPs none was determined to be a construction deficiency nor were adverse trends or unclassified trends identified.
5.11 Recommendations for Improvement Industry experience has shown that difficulties occur many i
times with programs such as the program implemented and practiced at CPSES for structural and riscellaneous bulk steel.
Based on the evaluation of findings in Paragraph 5.10 above and on industry experience, the following recommendations for improvement are presented:
TUGC0 commit to the purchase of only qua'lified structural and miscellaneous steels and develop a program which assures that only appropriate materials are purchased, or TUGC0 review the requirements of construction and QA/QC inspection procedures related to the purchase, control and use of structural and miscellaneous steel with the O
goal of assuring that positive controls are in place for an integrated control / traceability program to prevent the use of incorrect or defective material in
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RESULTS REPORT ISAP VII.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) safety-related applications.
Specific emphasis should be placed on QC verification of the issue of "Q" material and the verification and documentation of that issue at the point of installation.
6.0 CONCLUSION
S It is concluded that the material control / traceability program is in accordance with TUGC0 commitments in the FSAR. The implementation of this program, even though some procedures are considered to have weak controls, is generally adequate. The overall program could be improved by implementing a more rigid control of the purchase of all materials or the implementation of an integrated procedure system to provide stronger overall material control.
7.0 ON-GOING ACTIVITIES There are no ongoing QA/QC Review Team activities.
8.0 ACTION TO PREVENT RECURRENCE The current program meets the requirements. Past problems have been adequately addressed.
Implementation of recommendation for improvement will reduce the likelihood of future problems.
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i ISAP VII.a.1 i
(Cont'd)
Procedure Review Traceability Traceability:
- Addresses ; Verification Documentationi
d"
Addressed i Addressed l Remarks CCP 21. Rev 10 Yes Yes N /A QC to verdy CCP 22. Rev 4 Yes N /A N,A Transfer of numbers CCP 31. Rev 1 No N !A NiA CEI 20. Rev 9 Yes No No
.l.ength i O Die Stame CP CPM 6 98, Rev. 3 Yes N /A N /A i
CP CPM 6 9C. Rev 2 Yes N /A N /A CP CPM 6 9E. Rev 8 Yes i
N /A N /A CP CPM 7 3, Rev 1 Yes No No i
CP CPM 7 38. Rev 0 Yes Yes Yes
. Refers to *a00hCable* QC crocec. ts CP CPM 7 3E, Rev.0 Yes No No l Refers to "accropriate* Drocec. +5 CP CPM 7 3F Rev 0 Yes i
No No Refers to " appropriate
Yes Yes
(
ECP 10. Rev. 8 g
Yes Yes Yes
! A 36 4 A 500 Gr.8 esemot t
gel-1, Rev.1 No No No CP - QAP - 8.1, Rev. 9 Yes Yes Yes CP 0AP 12.1, Rev.18 Yes Yes Yes CP - QP 8.0, Rev. 5 Yes Yes N/A Refersto"appNestle* procedures l
, CP - QP 11.3, Rev. 5 No No No Refers to *Q0 *s
- for added details l CP - QP 11.14, Rev 1 No No No CP - QP 1121, Rev 2 No No No QI - QAP '1 ' 26. Rev '8, Yes I
Yes Yes Qi - QAP 11 5 28. Rev 34 Yes Yes Yes Qi-QP 11.3 23. Rev 15 Yes No No Color Code for Train 1.0.,
i not traceability QI - QP 11.3 24, Rev. t 5 Yes No No Color Code for Train 1.0.
, QI - QP 11.3 25 Rev. 26 Yes No No Color Code for Train f.O.
! QI-QP 11.3 26, Rev. 30 Yes Yes Yes on I.R. after 09 09 85 i Q1 - QP 11.3 28, Rev. 30 l Yes Yes Yes QI-QP 118 5, Rev. 20 l Yes Yes Yes Qi - QP 11.10-2, Rev. 29 ;
Yes l
No l
No I A 36 4 A 500 Gr4 esempt Qt -QP 11.141, Rev 24 ;
Yes Yes Yes l
On -QP 11 14 4. Rev 15 Yes j.
Yes Yes
! A 36 4 A 500 Gr 8 esempt l
! Solting not addressed
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RESULTS REPORT ISAP VII.a.1 (Cont'd)
(Cont'd)
Procedures Reviewed Procedure Subject CCP-21, Rev. 10 Misc. Steel Fabrication, Non-Nuclear, Safety-related CCP-22, Rev. 4 Erection, Structural Steel CCP-31, Rev. 1 Misc. Steel Installation CEI-20, Rev. 9 Hilti Bolt Installation CP-CPM-6.9B, Rev. 3 Procurement & Control of Weld Filler Metal CP-CPM-6.9C, Rev. 2 Control & ID of Components via Marking, Color Codes
)
i CP-CPM-6.9E, Rev. 8 Piping Fabrication & Installation CP-CPM-7.3, Rev. 1 Ceneral Fabrication Procedure CP-CPM-7.3B, Rev. O Fabrication of ASME NF & 1, 2, 3 and Seismic CAT II Supports CP-CPM-7.3E, Rev. O Cable Tray, Conduit Supports CP-CPM-7.3F, Rev. O Miscellaneous Steel CP-CPM-9.10, Rev. 15 Installation of Component Supports CP-QAP-8.1, Rev. 9 Inspection of "Q" Items CP-QAP-12.1, Rev. 16 Mechanical, Component Installation CP-QP-8.0, Rev. 5 Receipt Inspection "Q" Non-ASME Items CP-QP-11.3, Rev. 5 Outline of Electrical QC Inspection Program CP-QP-11.14, Rev. 1 Inspection of Structural Steel, "Q" Non-ASME i
l CP-QP-11.21, Rev. 2 Weld Inspection of Structural Misc.
Steel, "Q" Non-ASME
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RESULTS REPORT ISAP VII.a.1 (Cont'd)
(Cont'd)
Procedure Subject ECP-10, Rev. 8 Fab., Store., Install. Cable Tray &
Supports GEI-1, Rev. 1 Non "Q", Subcontractor Weld Filler Metal Control QI-QAP-11.1-26, Rev. 18 Fab., Install. & Inspection of Perm.
Plant "Q" Equip. & Code Pipe QI-QAP-11.1-28, Rev. 34 Fab., Install. & Inspection of ASME 1, 2, & 3 Supports QI-QP-11.3-23, Rev. 15 Class IE Conduit, Raceway Inspection QI-QP-11.3-24, Rev. 15 Inspection of Class 1E Cable Tray.
Raceway QI-QP-11.3-25, Rev. 26 Inspection of Class IE Lighting System QI-QP-11.3-26 Rev. 30 Inspection of Elect. Cable Installation QI-QP-11.3-28, Rev. 30 Class 1E Cable Termination QI-QP-11.8-5, Rev. 20 Instrument Tubing Fab. & Install.
Inspection QI-QP-11.10-2, Rev. 29 Inspection of IE & Non-1E Supports in CAT I Structures QI-QP-11.14-1, Rev. 24 Structural & Misc. Steel Fab. &
Installation QI-QP-11.14-4, Rev. 15 Traceability Requirements for Seismic Structural & Misc. Steel Fab.
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