IR 05000456/1985061

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)

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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

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Approved By: 0 ,bhieh / # #2 Materials and Processes Section Date

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-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 inspector 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 PDR

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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: A material verification field walkdown on 100% of piping installed prior to the procedure chang . A Quality Control verification of the field verified heat numbers against the heat numbers in the original stores reques . A Quality Control verification to show that the installed items complied with the design specificatio . A Quality Control review of the " stores request" for items which do not have physical identificatio 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 acceptabl .

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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: The MTV Program was sufficient to determine the traceability of the items in questio . The MTV procedures and work instructions were implemented properl . All items without the ASME Code required traceability have been removed from the plan . A number of installed items did not comply with applicable CECO or PGCo procedure . 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 II . 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 functio . Review of documentation indicates that all of the installed items could have performed their respective safety functio . All installed items now have the ASME B&PV Code required traceability; therefore, concerns relative to future 10 CFR Part 21 notificaticas are resolve 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 are . . . . _ _ . = _ - . ._ . _ . _ .

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. 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 traceabilit '

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

- 50-457/83-09 issue ~ February 1985 National Board Audit Team arrives at Braidwood sit ,

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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 progra 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 start 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" item November-1985 Ceco issues final report on MTV progra 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

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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 conclusion January 1986 Telephone conference with the Illinois State Department of Nuclear Safety discussing the Region III evaluation of the MTV progra ' January 1986 Region III MTV inspection exit interview at the Braidwood sit .

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• J. Wallace, Project Manager

• C. W. Schroeder, Licensing and Compliance Superintendent

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• D. Shamblin, Project Construction Superintendent, Unit 1

• 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

• R. Dougherty, Project Construction Engineer

• E. R. Wendorf, Project Field Engineer

• J. F. Phelan, Project Field Engineer

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• 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 employee * Denotes those attending the final exit interview at the Braidwood Station on January 9, 198 . 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 activitie 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 assemblie 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 ite 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 syste 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 pipin (2) All material identification marking recorde (3) Field gathered data compareo to stores request for ite (4) Field gathered data compared to certified material test reports (CMTR) for correct material specification, type, grade, class, size, and schedul (5) Items found not traceable per stores request or otherwise discrepant identified as nonconforming, and a nonconformance report generated for each ite i~

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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 component 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 activitie 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 item 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 acceptabl 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 acceptabl 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:

N NCR N MTV ITEM N ASME DESCRIPTION CLASS MTV #2 2 Rad Access plug CS7-1 MTV #3 2 Rad Access plug CS7-1 MTV #1 2 3"-S/40S Pipe; 18" long CS7-7 MTV #2 2 3"-S/40S Pipe; 5" long CS7-7 MTV #7 2 3"-S/405 Pipe; 19" long CS7-9 (Item Physically Tested) Rad Access Plug CS7-2 . MTV #1 2 Rad Access Plug CS23-7 MTC #2 3 4"-S/40 Pipe; 45" long 1ASX92-1 (Item Physically Tested) MTV #3 2 3"-S/160 Pipe; l'0" long IC-CV-25-4 1 MTV #2 3 2"-3000# SW 90 EL 2556A-71 1 MTV #33 3 1-1/4"-3000# SW 90 EL 2556A-35 1 MTV #34 3 1-1/4"-S/80 Pipe; 2556A-35 4-1/2" long 1 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)

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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)

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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" lon A-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-6 . 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

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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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6 _3221 MTV #4- 3 Nailer Ring (SA240)

OA-FC-3AB Welded Attachment 6 MTV #1 2 6"-S/80 Pipe; 12"~1ong-FW38-1 (Item Physically Tested)

6 MTV #2 2 Rad Access Plug RH-2 7 MTV #1 2 24"-S/40S Pipe; SI43-2 l'-6" long (Item Physically Tested)

7 MTV #2 2 Rad Access Plug 1A-RH-4 7 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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7 MTV #6 3 (FP-33-11)

7 PfR/ #7 3 4"-S/40 Pipe; 6" long (FP-33-9)

7 MTV #1 3 1"S/80 Pipe; l'-0" long (FW-15)

7 MTV #19 3 1"-S/80 Pipe; 4" long (FW-12)

7 MTV #2 3 4"-S/40 Pipe; 6'6" long FP-20-4 7 MTV #1 2 4"-S/160 Pipe; 8" long 1A-SI-12-4R 7 MTV #13 3 2"-S/40 Pipe; 40" long 2537A-104 8 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)

8 MTV #27 3 1"-S/80 Pipe; l' long (FW 36&37)

8 MTV #6 3 6"-S/120 Pipe; 5'4" long 1A-AF-8-3C (Item Physically Tested)

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8 MTV #1 3 6"-S/120 Pipe; l'1" long 1A-AF-8-6 8 MTV #2 3 6"-S/120 Pipe; 10" long 1A-AF-8-6 8 MTV #2 1 Rad Access Plug RC-16-5 8 MTV #3 1 Rad Access Plug RC-16-5 8 MTV #17 3 6"-S/40 Pipe; l'6" long FP-21-5 (Item Physica11y' Tested)

8 MTV #2 3 Welded attachment lug for AF-16-2 2AF01028R (Item Physically Tested)

9 MTV #1 3 3"-S/40S Pipe; 6" long CV-7-6 9 MTV #9 3 4'-S/40 Pipe; 6" long FP-77-7 9 MTV #2 3 18"0D S/40 Stanchion ISX02061X f

9 MTV #3 3 18"0D S/40 Stanchion ISX02061X

9 MTV #2 1 Rad Access Plug 2C-51-25

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9 MTV #2 2 3"-S/160 Pipe; 5" long CV-2-12 9 MTV # "-S/40 Pipe; 4'-6" long CC-29-5 9 MTV #1 2 3/4"-S/40S Pipe; 3" long 2535A-38 9 MTV #3 2 1/2" closure plate CV33-5 9 MTV #3 3 2"-3000# 90 EL 2556A-50A 10 MTV #18 3 2"-3000# 45 EL 2556A-71 10 MTV #8 3 1-1/2"-300# Flange 2537A-50A

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10 MTV #10 3 1-1/2"-300# Flange 2537A-50A 10 MTV #11 3 1-1/2"-S/80 Pipe;

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

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10 MTV #25 2 1/2"-S/160 Pipe; 6" long IFT-444-2 10 MTV #1 3 3"-S/40 Pipe; 5" long 1A-SX-15-10 10 MTV #6 3 4"-S/40 Pipe; 3-3/8" long 2FH-FP-28-14 10 MTV #4 2 3"-S/160 pipe; 2A-CV-28-12 7'-10" long 10 MTV #1 3 4"-S/40 Pipe; 10" long 2A-CC-27-6 (Item Physically Tested)

10 MTV #1 2 10"-S/40 Pipe; 10" long IC-SX-74-1 110.- 4294 MTV'#19 3 2"-3000# - 90 EL-2537C-12 11 MTV #55 2 1"-S/160 Pipe; 2539A-29 l'-10" long (Item Physically Tested)

11 MTV #2 3 36"-12"X1"-3000#

2A-CC-20-3 Sockolet 11 MTV #1 3 2"-S/40S Pipe; 29549A-28 l'-10" long 11 '4605 MTV #1 2 14"-S/STD Pipe 1C-SX-34-8 l'7" long'

(Item Physically Tested)

11 MTV #12 2 2"-S/40S Pipe; 2546A-5 Item 90 5'-2" long 11 MTV #4 2 3"-5/40S Pipe; 9" long 1A-CV-37' Item 8 ,

11 MTV #1 2 1"-S/40S Pipe; 2539C-44 Item 128 6-1/2" long 11 MTV #3 2 1"-S/40S Pipe; 2539C-44 Item 73 6'-4" long

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.f 11 MTV #5 2 1"-S/40S Pipe; 12' long 2539C-44 Item 74

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12 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 12 MTV #2 2 1"-S/40S Pipe; 4' long 2539C-39 Item 127 12 MTV #9 1 2"-S/160 Pipe; 3'9" long 2546C-25 Item 68 (Item Physically Tested)

12 MTV #1 2 2"-S/40S Pipe; 2546A-46 Item 109 5-5/8" long

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. 12 MTV #3 2 2"-S/405 Pipe; l 2546A-46 Item 110 10-5/8" long i 12 MTV #5 2 2"-S/40S Pipe; i 2546A-46 Item 111 11-1/2" long 12 MTV #7 2 2"-5/40S Pipe; 2546A-46 Item 112 10-3/4" long

. 12 MTV #8 2 2"-S/40S Pipe; 4" long 2f46A-46 Iteni 93 12 MTV #12 2 3/4"-S40S Pipe; 3" long 2546A-88 Item 95

, 13 MTV #2 2 5"-3"X3/4" - 3000# SOL

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2PC-44A

131, 4824 MTV #21 3 3/4"-S/40S Pipe; 2546A-2 15'10" long

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

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

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13 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 13 MTV #19 3 3/4"S/40S Pipe; 2546A-2 9-3/4" long 1J MTV #23 3 3/4"S/40S Pipe; 2546A-2 l'11-1/4" long 14 MTV #1 3 '3/4"-S/40S Pipe; 1" long 2549A-16 14 MTV #6 1 Rad Access Plug RH14-2 14 MTV #3 2 2"-S/40S Pipe; 12" long 2546A-92 14 MTV #22 2 2"-S/40S Pipe; 2546A-92 14-3/4" long 14 M1V #5 3 4"-S/160 Pipe; CC12-1 13'2" long 14 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; 50-457/8504 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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. 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

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piping and also confirmed the acceptability of the information that was developed by CEC In addition, the independent measurements closely agreed with the measurements taken by CEC 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 testin 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 inspecto I i

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All of the items subjected to the chemical testing conformed to the applicable ASME/ ASTM specification All of the items subjected to the physical testing for strength conformed to the applicable ASME/ ASTM specificatio 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 requirement 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 result 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

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performed by PGCo at the CECO Braidwood Nuclear Power Station

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"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 lette 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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.. 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 reviewe This report and the. disposition of these NCRs were acceptabl ~

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 Cod The evaluations were reviewed and found acceptabl 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 Cod (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 functio (4) The MTV program was an effective method to determine the traceability of the items in questio (5) The MTV program was conducted in accordance with applicable procedure (6) 145 Items lacking the required traceability have been removed from the plant and replaced with items which have the required traceabilit (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 properl . 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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