ML20151T444

Insp Repts 50-456/85-61 & 50-457/85-57 on 850708-860109. Violation Noted:Activities Affecting Quality for Small & Large Bore Piping Not Accomplished Per Instructions & Procedures

ML20151T444
Person / Time
Site:	Braidwood
Issue date:	01/17/1986
From:	Danielson D, Jacobson M, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151T415	List: ML20151T411 ML20151T422 ML20151T444
References
50-456-85-61, 50-457-85-57, NUDOCS 8602100272
Download: ML20151T444 (21)

See also: IR 05000456/1985061

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U.S. NUCLEAR REGULATORY C0fMISSION

REGION III

' Reports No.'50-456/85061(DRS); 50-457/85057(DRS)'

Docket =Nos. 50-456; 50-457 . Licenses No. CPPR-132; CPPR-133

Licensee: Commonwealth Edison Company

Post Office Box 767

' Chicago, IL. 60690

Facility Name: Braidwood Station, Units.1 and 2 -

Inspection At:-, Braidwood Site, Braidwood, IL

Inspection Conducted: July 8, 3, 11, 25, 26; August 1, 2, 5;

September 17, 25, 26; November 18, 19, 21, 26;

December 10, 17, 1985, and January 9, 1986

W

Inspector: J. W. Muffett i /n /86

Date

..M. Jacobson 8

/7 A

Date ~

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Approved By: 0 ,bhieh / # #2

Materials and Processes Section Date

.

-Inspection Summary

Inspection on July 8, 9, 11, 25,~26; August 1, 2, 5; September 17, 25, 26;

Novemoer 18, 19, 21, 26; December 10, 17, 1985; and January 9, 1986

(Reports No. 456/85061(DRS); 457/85057(DRS))

Areas Inspected: Special unannounced safety inspection of a previously

-identified unresolved item concerning traceability of piping and piping

components and the licensee's Material Traceability Verification (MTV)

program. The inspection involved a total of 160 inspector-hours by two NRC

inspectors.

Results: In the area inspected, one violation was identified (failure to

-follow procedures as identified in Paragraph 2.i..(2)).

8602100272 060203

PDR

O ADOCK 05000456

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S umma ry a_n d_0 v_e ra l_1_ _Co n_c llu_s i o n s

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Purpose

The purpose of this report is to document Region III review of the piping

material traceability issue at Braidwood. In addition, this report documents

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the actions taken to assure that the Braidwood Material Tracec',ility Verifica-

tion Program (MTV) was properly carried out, and to document the review and

evaluation of the " Report on Material Traceability Verification at Braidwoed",

dated November 1985, submitted by Conzonwealth Edison Company (CECO).

Background

A special Region III team inspection, conducted in June, July, August and

October of 1983 and during January and February of 1984, resulted in an

unresolved item concerning verification of correct heat number traceability

for piping and piping components. Specifically, it was determined that

Phillips Getschow Company (PGCo) had not been performing documented inspections

for correct material usage of piping and piping components at the time of

installation and a few instances were identified where material traceability

could not be readily verified. At the time NRC Inspection Report No. 50-456/

83-09; 50-457/83-09 was issued, the exact extent and significance of the

progrannatic deficiencies were unknown; therefore, this issue was made an

unresolved item. As detailed in the CECO response to the inspection report,

two actions were taken. The first action was to modify the piping material

control and installation procedures to provide documentation of material

traceability verification at the point of installation. This action tends

to minimize the possibility of recurrence of traceability deficiencies. The

second action was to initiate the MTV program. The MTV program contains

the following basic elements:

1. A material verification field walkdown on 100% of piping installed prior

to the procedure change.

2. A Quality Control verification of the field verified heat numbers against

the heat numbers in the original stores request.

3. A Quality Control verification to show that the installed items complied

with the design specification.

4. A Quality Control review of the " stores request" for items which do not

have physical identification.

In addition to the concern related to material verification at point of

installation, there was a related concern dealing with specific examples of

failure to follow the applicable procedures in this area. The MTV Program

was also structured to identify these items. . Also, the MTV Program was

independently reviewed and audited by the National Board of Boiler and

Pressure Vessel Inspectors National Board. The Illinois State Division of

Boiler and Pressure Vessel Safety also reviewed the program. Both

organizations found the program acceptable.

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Conclusions

Based upon the Region III inspections ~and the review of " Report on Material

Traceability Verification at Braidwood," dated November 1985, it is concluded

that:

1. The MTV Program was sufficient to determine the traceability of the items

in question.

2. The MTV procedures and work instructions were implemented properly.

3. All items without the ASME Code required traceability have been removed

from the plant.

4. A number of installed items did not comply with applicable CECO or PGCo

procedures.

5. The original material control system delineated in the PGCo QA manual

met the requirements of the ASME Boiler and Pressure Vessel Code (ASME

B&PV),Section III.

6. The physical and chemical tests performed on the items removed (due to

lack of traceability) from the plant demonstrate that in fact that the

mdterial installed was the correct material and could have performed its

safety function.

7. Review of documentation indicates that all of the installed items could

have performed their respective safety function.

8. All installed items now have the ASME B&PV Code required traceability;

therefore, concerns relative to future 10 CFR Part 21 notificaticas are

resolved.

It is concluded that Ceco has taken adequate corrective action co resolve

specific instances of failure to follow material control procedures. Also,

the results as delineated in the Ceco " Report on Material Traceability

Verification at Braidwood" demonstrate the extent and significance of

implementation deficiencies found in this area.

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f. TABLE 1

Braidwood Material Traceability Verification Program-

-Chronology of Activities

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April 1983- PGCo, Audit 83-BR3 identifies findings related to

material traceability.

June 1983 NRC inspection begins; NRC inspectors identify

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deficiencies in material traceability. '

July 1983 CECO issues a 50.55(E) notification concerning

material traceability.

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March 1984 Enforcement Conference in Region III concerning ,

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. findings of inspection.

March 1984 NRC Inspection Report No. 50-456/83-09;

- 50-457/83-09 issued.

~ February 1985 National Board Audit Team arrives at Braidwood site. ,

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-June 1985 D. Gallup, State of. Illinois, Superintendent of

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Boiler and Pressure Vessel Safety, issues letter

accepting MTV program.

June 1985 Public meeting held in Region III concerning Ceco's

L plans for MTV program.

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July 1985~ NRC review and inspection of MTV program starts.

September 1985 National Board Audit Team issues final report on MTV

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program.

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! September 1985 NRC Inspection Report No. 50-456/85043; 50-457/85042

issued. Inspection Report documents review of

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" Stores Request."

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October 1985- Taussig Association issues report on test results of

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" cut out" items.

November-1985 Ceco issues final report on MTV program.

November 1985 NRC Inspection Report No. 50-456/85050; 50-457/85048

issued. Inspection Report documents independent

thickness measurements of a sample of installed MTV

- items.

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December 1985 Region III met with NRC~IE and NRR personnel to

brief-them on.the MTV program and Region III

conclusions.

January 1986 Telephone conference with the Illinois State

Department of Nuclear Safety discussing the Region

III evaluation of the MTV program.

' January 1986 Region III MTV inspection exit interview at the

Braidwood site.

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DETAILS

1. Persons Contacted

Commonwealth Edison Company (CECO)

• M. J. Wallace, Project Manager

• C. W. Schroeder, Licensing and Compliance Superintendent

.

• D. Shamblin, Project Construction Superintendent, Unit 1

• W. Vahle, Project Construction Superintendent, Unit 2

• D. Skoza, Mechanical Field Engineer

• Louis Kline, Supervisor, Licensing and Compliance Department

• P. L. Barnes, Licensing Engineer

• T. Quaka, Site QA Superintendent

• E. F. Fitzpatrick, Station Manager

G. E. Groth, Assistant Construction Superintendent

• M. R. Dougherty, Project Construction Engineer

• E. R. Wendorf, Project Field Engineer

• J. F. Phelan, Project Field Engineer

.

• J. K. Jasnosz, Regulatory Assurance Staff

• T. W. Simpkin, Technical Staff

• D. L. Cecchett, Licensing Engineer

• A. D. Miosi, Nuclear Licensing Administrator

• C. J. Tomashek, Startup Superintendent

• G. F. Marcus, Assistant to Quality Assurance Manager

• L. O. Del George, Assistant Vice President, Engineering and Licensing

Phillips Getschow Co. (PGCo)

J. R. Stewart, Project Engineer

The inspectors also contacted and interviewed other licensee and

contractor employees.

• Denotes those attending the final exit interview at the Braidwood

Station on January 9, 1986.

2. Licensee Action on Previous Unresolved Items

(Closed) Unresolved Items (456/83-09-04(a); 457/83-09-04(a): This item was

classified as unresolved until the completion of the MTV program. This

report documents the NRC review of the pertinent issues and activities.

a. ASME Code and Appendix B Traceability Requirements

The.ASME B&PV Code gives no detailed information either on the

specific nature of material control systems or on the type of

Quality Control inspections required. The portion of the ASME B&PV

Code,Section III, which directly addresses this issue states:

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"NA-4441 Establishment and Maintenance of Identification and Control

Measures:

Measures shall be established for identification and control of

material and items, including partially fabricated assemblies.

These measures shall assure that identification is maintained

either on the item or records traceable to the item throughout

manufacture or installation. These measures shall be designed

to prevent the use of incorrect or defective items, and items ,

which have not received the required examinations, tests, or

inspections."

The language of NA-4441 closely parallels Criterion VIII of 10 CFR 50,

Appendix B, which states, in part:

"These measures shall assure that identification of the item is

maintained by heat number, part number, serial number, or other

appropriate means, either on the item or on records traceable to

the item."

The intent of the material control system is to prevent the

installation of incorrect or defective items. NA-4441 allows a

control system which utilizes records traceable to the item. The

PGCo stores request system, as delineated in the QA manual, complied

with both the ASME B&PV Code,Section III, and 10 CFR 50, Appendix

B, Criterion VIII, prior to identification of the unresolved item.

When properly applied, this material control system provided a

record traceable to the item as required. The discrepancies in the

traceability of actual piping and piping components were the result

of failure to properly implement the stores request system.

b. Review of MTV Procedures

Activities performed under the MTV program were controlled by two

procedures: PGCo Procedure QCP-B31, Revision 4, " Material

Traceability Verification," and PGCo Work Instruction PGWI-17,

Revision 3, "QCT Review of MTV Program." The procedures contain

five major requirements as follows:

(1) 100% field walkdown for subject piping.

(2) All material identification marking recorded.

(3) Field gathered data compareo to stores request for item.

(4) Field gathered data compared to certified material test reports

(CMTR) for correct material specification, type, grade, class,

size, and schedule.

(5) Items found not traceable per stores request or otherwise

discrepant identified as nonconforming, and a nonconformance

report generated for each item.

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PGCo Procedure QCP-831 and Work Instruction PGWI-17 contain an

acceptable method for determining the traceability of installed

piping and piping components.

In addition, the NRC inspector reviewed PGCo Procedure QCP-B31.1,

Revision 1, " Untraceable Material Sampling Program." The purpose

of thi.* procedure is control of untraceable items and control and

storage of items removed from the plant. This procedure provides

an acceptable method for controlling these activities.

c. Nonconformance Board

The MTV program found 792 items to be in nonconformance with

applicable procedural requirements. The disposition of these NCR's

were provided by consensus of a nonconformance board consisting of

representatives of CECO, Sargent and Lundy Engineers (S&L),

PGCo, the Authorized Ir.spection Agency (AIA), and generally a member

of the National Board Audit Team. The NRC inspector attended the

disposition of a number of nonconforming items.

The NCRs discussed while the NRC inspector was in attendance are as

follows:

NCR 2301

NCR 2230

NCR 2183 (Item Removed)

NCR 2179

NCR 3595

NCR 3669

NCR 3729

The disposition of these NCRs was acceptable.

The NRC inspector independently reviewed the NCR package i?sted below:

NCR 3720

NCR 3301

NCF. 3326

NCR 3161

NCR 3068

NCR 3046

NCR 3025

NCR 2320

NCR 4875

NCR 4573

NCR 46'J1

NCR 3496

NCR 3423

NCR 2985

NCR 4769 (Item Removed)

NCR 2814

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The information contained in the NCR packages complied-with procedure ,

requirements and the dispositions of the individual items were

acceptable.

Of the 792 nonconforming items, it was determined that 647 items,

while in nonconformance with PGCo and Ceco procedural requiremerits,

were in compliance with the traceability requirements of the ASME

Code (Braidwood procedural traceability requirements. exceeded those

of the-ASME Code). The remaining 145 items, listed below, were-

removed from the piping systems and replaced with traceable material:

NO. NCR NO. MTV ITEM NO. ASME DESCRIPTION

CLASS

1. 1742 MTV #2 2 Rad Access plug

CS7-1

2. 1742 MTV #3 2 Rad Access plug

CS7-1

3. 1742 MTV #1 2 3"-S/40S Pipe; 18" long

CS7-7

4. 1742 MTV #2 2 3"-S/40S Pipe; 5" long

CS7-7

5. 1742 MTV #7 2 3"-S/405 Pipe; 19" long

CS7-9 (Item Physically Tested)

6. 1831 -

2 Rad Access Plug

CS7-2

7. 1871. MTV #1 2 Rad Access Plug

CS23-7

8. 2071 MTC #2 3 4"-S/40 Pipe; 45" long

1ASX92-1 (Item Physically Tested)

9. 2073 MTV #3 2 3"-S/160 Pipe; l'0" long

IC-CV-25-4

10. 2085 MTV #2 3 2"-3000# SW 90 EL

2556A-71

11. 2089 MTV #33 3 1-1/4"-3000# SW 90 EL

2556A-35

12. 2089 MTV #34 3 1-1/4"-S/80 Pipe;

2556A-35 4-1/2" long

13. 2131 MTV #4 2 12'-6"X3/4"-3000#

1AC-CC44 Sockolet

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14. 2131 'MTV #5 2 3/4"-3000# SW Plug

1AC-CC44

15. 2133 MTV #8 3 6"-S/40 Pipe; 2" long

CC40-1

16. 2133 MTV #3 3 4"-S/40 Pipe; 6'-11" long

CC40-12 (Item Physically Tested)

17. 2176 -

2 3"-S/405 Pipe; 3" long

1A-CS-8-9

18. 2177 -

2 Rad Access Plug

CS-8-FW-5AP

19. 2177 -

2 Rad Access Plug

CS-8-FW-4AP

20. 2183 MTV #A 2 3"-S/40 Pipe; 3'-1" long

IC-CC-41 (Item Physically Tested)

21. 2183- MTV #8 2 3-S/40 Pipe; 4'-11" long

IC-CC-41

22. 2353 MTV #1 2 3/4"-S/80 Pipe 2" long

2544A-159

23. 2353 MTV #2 2 3/4"-S/80 Pipe 2" long

2544A-159

24. 2376 MTV #11 2 3"-S/405 Pipe; 4'6" long

1A-CS-9-6 (Item Physically Tested)

25. 2434 -

2 Rad Access Plug

CS9-17

26. 2434 -

2 Rad Access Plug

CS9-19

27. 2S05 MTV #9 3 2"X3/4" 6000# SW

2537C-32 Reducing Insert

28. 2511 MTV #2 2 3"-S/160 Pipe; 10" long

1C-CV-39-10

29. 2516 MTV #18 3 2"X3/4" 6000# SW

2537C-39 Reducing Insert

30. 2785 MTV #2 1 Rad Access Plug

RH-8-2

31. 2785 MTV #3 1 Rad Access Plug

RH-8-3

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32. 2785 MTV #2 1 Rad Access Plug

RH-8-5

33. 2813 MTV #2 1 3"-S/160 Pipe; 4" long

CV-10-4B

34. 2813 MTV-#1 2 3"-S/160 Pipe; 4" long

CV-10-4D

35. 2828 MTV #12 3 2"-3000# SW45 EL

2556A-72

36. 2873 MTV #1 2 3/4"-S/160 Pipe;

2539C-84 5'3"long

37. 2873' MTV #3 2 3/4"-5/160 Pipe;

2539C-84 l'9"long

38. 2873 MTV #5 2 3/4"-S/160 Pipe;

2539C-84 10'7"long

39. 2873 MTV #7 2 3/4"-5/160 Pipe;

2539C-84 4'6"long

(Item P5ysically Tested)

40. 2873 MTV #9 2 .3/4"-S/160 Pipe;

2539C-84 l'1" long

41. 2875- MTV #7 3 2" 3000# SW 90 EL

(FW 7&8)

42. 2875 MTV #14 3 2"-3000# SW 90 EL

(FW 15&l6)

43. 2902 MTV #3 3 3/4"-S/80 Pipe; 18" long

(FW 3&4)

44. 2917 MTV #23 3 2"-3000# SW 90 EL

(FW 20A&21A)

45. 2919 MTV #8 2 3"-S/405 Pipe;

1A-CV-13-3 11-1/2" long

46, 2919 MTV #9 2 3"-5/40S Pipe;

1A-CV-13-3 14-1/2" long

47. 2919 MTV #10 2 3"-S/40S Pipe;

1A-CV-13-3 2" long

48. 2919 MTV #13 2 3"S/40S Pipe; 11" long

1A-CV-13-3

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49. 2919 MTV #13 2 3"-S/40S Pipe; 39" long

1A-CV-13-3

50. 2919 MTV-#14 2 3"-S/40S Pipe;

1A-CV-13-3 3-1/2" long

51. 2919 MTV #15 2 3"-S/40S Pipe;

1A-CV-13-3 2"&24" long

52. 2930' MTV #1 3 3"-S/40S' Pipe;

1A-BRS-5 8-13/16" long

53. 2953 MTV #1 3 3/4"-S/80 Pipe 5" long

2546A-79

54. 2973 MTV #13 3 2"-S/80 Pipe; 3" long

(FW16&l7)

55. 2973 MTV #47 3 2"-S/80 Pipe; 1" long

(FW35&36)

56. 2984 MTV #3 3 Ring & Bar lug

1A-SX-30-2

57. 2990 MTV #6 2 Rad Access Plug

1A-SI14-3

58. 2993 MTV-#5 3 3/4"-S/80 Pipe 4" long

2537A-65

59. 2993 MTV-#19 3 3/4"-S/80 Pipe 4" long.

2537A-65

60. 3027 MTV #9 2 3/4"-S/160 Pipe; 2" long

2546C-61

61. 3027 MTV #15 2 3/4"-S/160 Pipe; 2" long

_,. 2546C-61.

62. 3126 MTV #5 2 3"-S/40(S) Pipe;

1A-CV-10-3 10-3/4" long

63. 3165 MTV #12 3 4"-S/40 Pipe; 2'3" long

. CC-11-5

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64. 3166 MTV #5 2 2 Plates, 2"X6" Welded

2A-CC-31 Attachment

65. 3215 MTV #5 2 Rad Access Plug

IC-FW-14-7

66. 3216 MTV #7 2 3/4"-6000# Coupling

PG-2539C-75

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67. _3221 MTV #4- 3 Nailer Ring (SA240)

OA-FC-3AB Welded Attachment

68. 3226 MTV #1 2 6"-S/80 Pipe; 12"~1ong-

FW38-1 (Item Physically Tested)

69. 3275 MTV #2 2 Rad Access Plug

RH-2

70. 3291 MTV #1 2 24"-S/40S Pipe;

SI43-2 l'-6" long

(Item Physically Tested)

71. 13300 MTV #2 2 Rad Access Plug

1A-RH-4

72. 3318 MTV #3 3 5"-3"X3/4" 3000# SOL

CV4-5'

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4"-S/40 Pipe; l'0" long

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73. 3327 MTV #6 3

(FP-33-11)

74. 3327 PfR/ #7 3 4"-S/40 Pipe; 6" long

(FP-33-9)

75. 3334 MTV #1 3 1"S/80 Pipe; l'-0" long

(FW-15)

76. 3334 MTV #19 3 1"-S/80 Pipe; 4" long

(FW-12)

77. 3335 MTV #2 3 4"-S/40 Pipe; 6'6" long

FP-20-4

78. 3343 MTV #1 2 4"-S/160 Pipe; 8" long

1A-SI-12-4R

79. 3350 MTV #13 3 2"-S/40 Pipe; 40" long

2537A-104

80. 3350 MTV #11 3 2"-S/40 Pipe;

2537A-104 10-1/2" long

81.' 3365 MTV #25 3 1"-S/80 Pipe; l' long

(FW34&35)

82. 3365 MTV #27 3 1"-S/80 Pipe; l' long

(FW 36&37)

83. 3322 MTV #6 3 6"-S/120 Pipe; 5'4" long

1A-AF-8-3C (Item Physically Tested)

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84. 3422 MTV #1 3 6"-S/120 Pipe; l'1" long

1A-AF-8-6

85. 3422 MTV #2 3 6"-S/120 Pipe; 10" long

1A-AF-8-6

86. 3432 MTV #2 1 Rad Access Plug

RC-16-5

87. 3432 MTV #3 1 Rad Access Plug

RC-16-5

88. 3433 MTV #17 3 6"-S/40 Pipe; l'6" long

FP-21-5 (Item Physica11y' Tested)

89. 3458 MTV #2 3 Welded attachment lug for

AF-16-2 2AF01028R

(Item Physically Tested)

90. 3465 MTV #1 3 3"-S/40S Pipe; 6" long

CV-7-6

91. 3470 MTV #9 3 4'-S/40 Pipe; 6" long

FP-77-7

92. 3474 MTV #2 3 18"0D S/40 Stanchion

ISX02061X

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93. 3474 MTV #3 3 18"0D S/40 Stanchion

ISX02061X

94. 3476 MTV #2 1 Rad Access Plug

2C-51-25

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95. 3487 MTV #2 2 3"-S/160 Pipe; 5" long

CV-2-12

96. 3488 MTV #1. 3 4"-S/40 Pipe; 4'-6" long

CC-29-5

97. 3492 MTV #1 2 3/4"-S/40S Pipe; 3" long

2535A-38

98. 3518 MTV #3 2 1/2" closure plate

CV33-5

99. 3520 MTV #3 3 2"-3000# 90 EL

2556A-50A

100. 3553 MTV #18 3 2"-3000# 45 EL

2556A-71

101. 3594 MTV #8 3 1-1/2"-300# Flange

2537A-50A

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102. 3594 MTV #10 3 1-1/2"-300# Flange

2537A-50A

103. 3594 MTV #11 3 1-1/2"-S/80 Pipe;

'2537A-50A 7-1/2"long

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104. 3992 MTV #25 2 1/2"-S/160 Pipe; 6" long

IFT-444-2

105. 4022 MTV #1 3 3"-S/40 Pipe; 5" long

1A-SX-15-10

106. 4032 MTV #6 3 4"-S/40 Pipe; 3-3/8" long

2FH-FP-28-14

107. 4055 MTV #4 2 3"-S/160 pipe;

2A-CV-28-12 7'-10" long

108. 4079 MTV #1 3 4"-S/40 Pipe; 10" long

2A-CC-27-6 (Item Physically Tested)

109. 4100- MTV #1 2 10"-S/40 Pipe; 10" long

IC-SX-74-1

110.- 4294 MTV'#19 3 2"-3000# - 90 EL

-2537C-12

111. 4527 MTV #55 2 1"-S/160 Pipe;

2539A-29 l'-10" long

(Item Physically Tested)

112. 4587 MTV #2 3 36"-12"X1"-3000#

2A-CC-20-3 Sockolet

113. 4589 MTV #1 3 2"-S/40S Pipe;

29549A-28 l'-10" long

114. '4605 MTV #1 2 14"-S/STD Pipe

1C-SX-34-8 l'7" long'

(Item Physically Tested)

115. 4756 MTV #12 2 2"-S/40S Pipe;

2546A-5 Item 90 5'-2" long

116. 4756 MTV #4 2 3"-5/40S Pipe; 9" long

1A-CV-37' Item 8 ,

117. 4756 MTV #1 2 1"-S/40S Pipe;

2539C-44 Item 128 6-1/2" long

118. 4756 MTV #3 2 1"-S/40S Pipe;

2539C-44 Item 73 6'-4" long

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119. 4756 MTV #5 2 1"-S/40S Pipe; 12' long

2539C-44 Item 74

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120. 4756 MTV #7 2 1"-S/40S Pipe;

2539C-44 Item 75 12'5" long

121, 4756- MTV #2 2 1"-S/40S Pipe; 4' long i

2539C-89 Item 76

122. 4756 MTV #2 2 1"-S/40S Pipe; 4' long

2539C-39 Item 127

123. 4756 MTV #9 1 2"-S/160 Pipe; 3'9" long

2546C-25 Item 68 (Item Physically Tested)

124. 4756 MTV #1 2 2"-S/40S Pipe;

2546A-46 Item 109 5-5/8" long

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. 125. 4756 MTV #3 2 2"-S/405 Pipe;

l 2546A-46 Item 110 10-5/8" long

i 126. 4756 MTV #5 2 2"-S/40S Pipe;

i 2546A-46 Item 111 11-1/2" long

127. 4756 MTV #7 2 2"-5/40S Pipe;

2546A-46 Item 112 10-3/4" long

. 128. 4756 MTV #8 2 2"-S/40S Pipe; 4" long

2f46A-46 Iteni 93

129. 4756 MTV #12 2 3/4"-S40S Pipe; 3" long

2546A-88 Item 95

, 130. 4769 MTV #2 2 5"-3"X3/4" - 3000# SOL

,

2PC-44A

1

131, 4824 MTV #21 3 3/4"-S/40S Pipe;

2546A-2 15'10" long

,

(Item Physically Tested) '

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132.- 4824 MTV #1 3 3/4"-S/40S Pipe;.4" long

'

2546A-2

133, 4824 MTV #9 3 3/4"-S/40S Pipe; 5" long

2546A-2

134, 4824 MTV #11 3 3/4"-S/40S Pipe; 5".long

2546A-2

135. 4824 MTV #13 3 3/4"-S/40S Pipe;

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2546A-2 9'11"long

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136. 4824 MTV #15 3 3/4-S/40S Pipe;

2546A-2 10-1/2" long

137, 4824 MTV #17 3 3/4"-S/40S Pipe;

2546A-2 4'10" long

138. 4824 MTV #19 3 3/4"S/40S Pipe;

2546A-2 9-3/4" long

1J9. 4824 MTV #23 3 3/4"S/40S Pipe;

2546A-2 l'11-1/4" long

140. 4873 MTV #1 3 '3/4"-S/40S Pipe; 1" long

2549A-16

141. 4973 MTV #6 1 Rad Access Plug

RH14-2

142. 5226 MTV #3 2 2"-S/40S Pipe; 12" long

2546A-92

143. 5226 MTV #22 2 2"-S/40S Pipe;

2546A-92 14-3/4" long

144. 5364 M1V #5 3 4"-S/160 Pipe;

CC12-1 13'2" long

145. 5490 MTV #1 2 10"-S/40S Pipe; 11" long

CSS-7

d. Stores Request Review

One of the original concerns relative to piping material was the

viability of the PGCo " stores request" system as an effective

material control system. To further develop assurance concerning

the implementation of the system, the NRC inspector performed a

detailed review on the documentation associated with 30 items whose

traceability was established by the " stores request" document per

the original procedure. The details of this inspection are contained

in NRC Inspection Report No. 50-456/85043; 50-457/85042. Summarizing

the results, "None of the documents reviewed contradicted the

licensee's conclusions and in a majority of cases, independent

information, other than the stores request was on file in the

documentation packages which supported the licensee's conclusion."

Members of the National Board Audit Team reviewed documentation

associated with 50 installed items whose traceability was established

based on stores request documents only. The results of their review

are contained in the National Board Supplementary Report dated

September 26, 1985, and addressed to Cordell Reed, Vice President,

Ceco (" Material Traceability Verification at Braidwood", November

1985, Appendix A), and states "The audit confirmed the integrity of

the stores request system."

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.e. Thickness Measurement of Installed Items

As discussed in NRC Inspection Report No. 50-456/85050; 50-457/85048,

' independent thickness measurements, using an ultrasonic digital

thickness measuring device, were taken on six piping systems which

contained MTV items. These measurements were taken to confirm that

the schedule of the installed piping (wall thickness) complied with-

the design specification and agreed with the information used in the

MTV program. Measurements were taken on portions of the following

piping systems:

ID004AB'- Diesel Fuel Oil

ICCD9AB - Component Cooling Water

ICC97AB - Component Cooling Water

ISX17AB - Essential Cooling Water

ICCD8AB - Component Cooling Water

ID063A - Diesel Fuel Oil

All'of the measurements taken confirmed the schedule of the installed i

'

piping and also confirmed the acceptability of the information that

was developed by CECO. In addition, the independent measurements

closely agreed with the measurements taken by CECO.

f. Selection of Samples

At a point in time near the completion of the MTV, CECO decided to

perform tests on the piping removed from the plant due to lack of

traceability. The purpose of these tests was to-demonstrate that

the untraceable material was in fact, the correct material and

therefore the lack of traceability did not impact the ability of  :

the affected s All of the' items which H

were removed (ystems to function properly.except for 3 items mistakenly los1

subjected to an analysis which determined the chemical composition

of the material.' Sixteen of the removed items were subjected to

physical tests which demonstrated that they conformed to the

strength requirements of the applicable specification. Two

considerations determined which items were appropriate for physical

tests. The'first consideration was size; approximately 90 of the

removed items were too small for physical testing. The second

consideration was'the' presence of manufacturers' markings. Approxi-

mately 30 items, with clear manufacturers' marks identifying mate' rial l

type, did not have the same degree of uncertainty associated with l

their physical properties, and therefore were not appropriate for

physical testing.

The group of items tested contained both carbon steel and stainless

steel and both large bore items and small bore items. In addition, I

the only untraceable section of piping'in an ASME Class I system us i

tested (NCR 4756 Item 68). A portion of the testing was witnessed by

a NRC inspector.

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All of the items subjected to the chemical testing conformed to the

applicable ASME/ ASTM specifications. All of the items subjected to

the physical testing for strength conformed to the applicable

ASME/ ASTM specification.

The final report produced by Taussig Associates, Report No. 64188-1,

" Chemical and Tension Testing of Samples Associated with the MTV

Program," was reviewed. A number of the chemical composition results

were reviewed by the NRC inspector for compliance with ASME B&PV

Code requirements for chemical composition. A number of the

physical (strength) results were also reviewed by the NRC inspector

for compliance with ASME B&PV Code requirements for strength. ~All

results demonstrated compliance with applicable code strength and

composition requirements.

g. Review of Reports

As part of the inspections associated with the MTV program, CECO's

Report " Material Traceability verification at Braidwood," the National

Board's letter of September 26, 1985,.and the Office of the Illinois

State Fire Marshall, Division of Boiler and Pressure Vessel Safety

letter of June 21, 1985,.were reviewed. Based on the NRC inspections

of the MTV program and the review of the Ceco's final ~ report, it has

been determined that the CECO final report is an accurate representation

of the activities conducted and their results. In addition, our

review of the National Board activities and our review of their letter

supports the National Board's general conclusions:

"The Phillips, Getschow quality assurance program, as written,

did provide the necessary controls to assure that the work

,

performed by PGCo at the CECO Braidwood Nuclear Power Station

! met the requirements of the ASME Code and the certified design

specification."

'

"As noted previously in the report, there were implementation

deviations from the PGCo quality assurance program's requirements."

"These deviations led to the generation of the MTV program and

the resulting revisions to the PGCo quality assurance program

and material control procedures."

i Duane R. Gallup, Superintendent of Boiler and Pres 9ure Vessel

Safety for the State of Illinois, suuported the MTV program in his

June 21, 1985 letter. Quoting the letter,

"I am satisfied that the corrective action program which

Commonwealth Edison Company (CECO) has undertaken will result

in assuring the piping systems at the Braidwood site will be

in compliance with the requirements of the ASME Code."

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h. Safety Significance Evaluation

As part of the overall MTV program, a " safety significance"

evaluation, composed of calculations necessary to demonstrate

compliance with ASME B&PV Code strength requirements, was performed

for all the items which were nonconforming due to insufficient

traceability. A random sample of these noncomforming item

evaluations (listed below) was reviewed in detail:

NCR 2085

NCR 2183

NCR 2785

NCR 2873

NCR 2919

NCR 3027

NCR 3291

NCR 3350

NCR 3465

NCR 3553

NCR 4294

NCR 4756

NCR 4769

NCR 4873

NCR 5490

In addition, the Sargent and Lundy Report BRF-PMD-01 (November 13,

1985), " Design Significance Evaluation of Braidwood Material

Traceability Verification (MTV) Program Cut Out Items" was reviewed.

This report and the. disposition of these NCRs were acceptable.

~

In NRC Inspectio'n Report No. 50-456/83-09; 50-457/83-09, two items

were identified which did not have the required schedule of piping

installed. Because these items were replaced prior to the

initiation of the formal MTV program they were not included as

items in the MTV. program final report. Safety significance

evaluations were performed which found that the installed items

could have performed their safety function in compliance with the

ASME B&PV Code. The evaluations were reviewed and found acceptable.

i. . Inspection Conclusions

Based on the NRC inspections and reviews of the MTV program, the

following conclusions have been reached:

(1) The original material control system ~ contained in the PGCo QA

manual complied with the requirements of the ASME B&PV Code.

(2) There were a number of instances in which the proper procedures

were not followed. These are the 792 items identified in the

CECO final report as nonconforming. This is the basis for a

violation of 10 CFR 50 Appendix B, Criterion V. (456/85061-01;

456/85057-01).

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(3) The specific instances of failure to follow procedures did not

appear to impact the ability of the systems to perform their

safety function.

(4) The MTV program was an effective method to determine the

traceability of the items in question.

(5) The MTV program was conducted in accordance with applicable

procedures.

(6) 145 Items lacking the required traceability have been removed

from the plant and replaced with items which have the required

traceability.

(7) It now appears, based on the results-of the MTV program,' that

the Material Control System originally employed by PGCo was

effective to the extent that no items were installed which

would have impacted the ability of the piping systems to

function properly.

3. Exit Interview

The Region III inspectors met with licensee representatives (denoted under

Paragraph 1) at the conclusion of the inspection on January 9, 1986. The

inspectors summarized the scope and findings of the inspection. The

licensee acknowledged this information. The inspector also discussed the

likely informational content of the inspection report with regard to

documents or processes reviewed during the inspection. The licensee did

not identify any such documents / processes as proprietary.

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