ML20080B305

Testimony of RP Tuetken Re Util Reinsp Program of Work Performed by Contractor Insp Personnel Prior to NRC Region III Mar,Apr & May 1982 Insps.Appropriate Steps Taken to Remedy Problems

ML20080B305
Person / Time
Site:	Byron
Issue date:	08/03/1983
From:	Tuetken R COMMONWEALTH EDISON CO.
To:
Shared Package
ML20080B300	List: ML20080B295 ML20080B305 ML20080B309
References
ISSUANCES-OL, NUDOCS 8308050405
Download: ML20080B305 (11)

Text

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Commonwealth Edison Company Date: August 3, 198 q)

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AMwg Mae (\\

UNITED STATES OF AMERICA  %

NUCLEAR REGULATORY COMMISSION 9- $US 4 1983 s -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD orr

,3, s b=74 sI e In The Matter of ) 4

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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL

) 50-455 OL (Byron Nuclear Power Station, )

Units 1 & 2) )

SUMMARY

OF DIRECT TESTIMONY OF RICHARD P. TUETKEN I. Richard P. Tuetken is the Assistant Superintendent, Project Construction Department, Byron Station.

II. Mr. Tuetken is familiar with results of the inspection of QA/QC personnel training and certification which was conducted by the NRC's Region III Staff as a part of its special team inspection of March, April, and May, 1982.

III. In response to the special team inspection Common-wealth Edison has implemented a reinspection program of the work performed by contractor inspection personnel prior to the NRC's team inspection.

IV. Mr. Tuetken describes the operation of the re-inspection program as it applies to Byron contractors generally.

V. If the reinspection program finds improper installation or construction appropriate steps are taken to remedy any problem.

VI. Mr. Tuetken then describes the operation of the reinspection program with regard to Hatfield Electric Company.

VII. It presently appears that one Hatfield weld inspector will fail to meet acceptable quality levels, and therefore the sample of Hatfield inspectors whose work is being reinspected will have to be enlarged.

VIII. Hatfield work that is found to be unacceptable as the reinspection program proceeds is reworked to an acceptable level.

8308050405 830803 PDR ADOCK 05000454 T PDR

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DIRECT TESTIMONY OF RICHARD P. TUETKEN Q.l. Please state your name.

A.l. Richard P. Tuetken.

Q.2. By whom are you employed?

A.2. Commonwealth Edison Company.

Q.3. What is your present position with Commonwealth Edison Company?

A.3. I am the Assistant Superintendent, Project Con-struction Department, Byron Station.

Q.4. What is the scope of your. testimony?

A.4. My testimony discusses the reinspection program being implemented by Commonwealth Edison at Byron in response to the special team inspection per-formed by the Region III Staff in March, April and May, 1982.

0.5. How long have you held your present position?

A.S. Since April, 1981.

i Q.6. What positions did you hold before you became the assistant superintendent for construction at Byron?

A.6. Immediately prior to assuming my current position I was lead mechanical engineer with the Construction Department at Byron, from April, 1976, to April, 1981. Before that, I was an engineer in the Station Nuclear Engineering Department for the Byron and Braidwood projects, from November, 1974, to April, 1976. From November, 1973, to November, 1974, I was a staff assistant to an Edison vice president, and from February, 1970, to November, 1973, I was an engineer in the Station Construction Department assigned to various projects, including Zion, Powertoli, Quad Cities, and Kincaid.

Q.7. What are your responsibilities as assistant superintendent of construction at Byron?

A.7. I am responsible for overall coordination and management of construction activities. This encompasses the expediting of design information, overseeing the delivery of equipment, components and materials, and overseeing installation and start-up activities.

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Q.8. What are your responsibilities specifically with regard to Hatfield Electric Company?

A.8. As Assistant Superintendent I supervise Hatfield's activities, either directly or through the elec-trical engineers and other individuals who report to me.

Q.9. Are you familiar with the results of the inspection of QA/QC personnel training and certification which was conducted by the NRC's Region III Staff as a part of its special team inspection of March, April and May, 1982?

A.9. Yes, I am. Michael Stanish described these results in his testimony before the Board.

Q.10. Mr. Stanish referred in his testimony to a rein-spection program that is presently being implemented in response to the results of the special team inspection. Are you familiar with this reinspection program?

A.10. Yes, I am. Commonwealth Edison is presently engaged in a reinspection program which is designed to

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verify that the deficiencies in past QA/QC personnel training and certification identified by the NRC did not result in unsatisfactory work being undetected.

Q.ll. Please describe the operation of the reinspection program.

A.ll. Basically, the reinspection program consists of the following:

For six contractors, every fifth inspector (20%) was selected from a chronological listing based on the date of certification of each QC inspector certified since the beginning of the project. Further, a minimum of three additional inspectors for each contractor was selected by the NRC senior resident inspector. Each individual inspection performed during the first three months by the selected inspectors is being reinspected, where accessible.

For two contractors, Powers-Azco-Pope and Johnson controls, each quality control inspector certified since the beginning of the project up to September, 1982 (when contractor certification procedures were revised and approved for use), was selected and each individual inspection performed during the inspector's first three months is being reinspected, where accessible.

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i These two contractors are being reinspected on this basis because of particular concern about their certification procedures. For example, these contractors utilized open book testing in qualifying inspectors, unlike the other contractors on site.

Inaccessible inspections are defined as those which would require dismantling to gain access.

Ex.imples are components embedded or buried in concrete, internal piping alignments, etc.

Additionally, inaccessible inspections are those where the process was an event which cannot 4

be recreated. Examples are tension achieved during cable pulling operations, welding interpass temperature, etc.

The need to remove fireproofing or piping insulation does not classify an item as inaccessible, and such components are removed when necessary.

Provisions are contained in the program to make another selection if all or most of an inpsector's inspections are inaccessible.

The reinspection program is designed to ensure that the work of each inspector attains a 95% quality level for objective attributes and a 90% quality level for subjective attributes.

An objective attribute is one which is readily measurable or discernable, such as dimensional

6 configuration or type of material. A subjective attribute, on the other hand, is one which requires the interpretation of the inspector, such as weld profile and undercut.

If the reinspection program demonstrates that an inspector has failed to meet acceptable quality levels with regard to an attribute inspected by the inspector during his first three months' work, the inspector's next three months of inspections of the attribute in question is reinspected. If this sample also fails to meet acceptable quality levels, 100% of the inspector's inspections of the i

attribute in question is reinspected. In addition, if the inspector's work with regard to a particular attribute fails to meet acceptable quality levels

! for the first six months of work, the original sample of inspectors whose work is being reinspected is expanded by 50% for the attribute in question.

That is, if one inspector out of an initial sample of ten inspectors fails to meet acceptability criteria with regard to one of the items he was required to inspect, the work of an additional five inspectors involving the item at issue is reinspected.

Q.12. What steps are taken if the reinspection program finds improper installation or construction?

A.12. Any improper installation or construction work is reworked or evaluated to an acceptable level.

Q.13. When is the reinspection program due to be completed?

A.13. The first phase of the program is due to be completed by the end of August, 1983. To the extent initial inspector samples for any contractors are required to be enlarged because of the results of the first phase, the additional phases of the program will be conducted in subsequent months.

Q.14. Please describe the operation of the reinspection program with regard to Hatfield Electric Company?

A.14. With regard to Hatfield, 22 inspectors were selected through the previously-described process. Eighteen of these inspectors were selected at random, and 1

the other four were selected by the NRC senior resident inspector. This total sample represents approximately 25% of the population of Hatfield inspectors certified up to September, 1982, which is the date Hatfield's certification procedures were revised and approved for use by Commonwealth Edison.

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t Attributes that were inspected by the Hatfield inspectors, and thus are being reinspected, consist of equipment setting, equipment modifications, conduit and conduit hangers, cable pans and cable pan hangers, bolting, welding, and cable terminations.

Two of the 22 inspectors selected conducted inspections of equipment setting in their first three months.

Two of the 25 inspectors selected conducted inspections of equipment modifications in their first three months.

Fourteen of the 22 inspectors selected conducted inspections of conduit and conduit hangers.

Two of the 22 inspectors selected conducted inspections of cable pan and cable pan hangers.

One of the 22 inspectors selected conducted inspections of bolting.

Seven of the 22 inspectors selected conducted inspections of welding.

Five of the 22 inspectors selected conducted inspections of cable terminations.

Q.15. What are the results to date of the Hatfield re-inspection program?

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.15. It appears that one inspector will fail to meet the acceptable quality level with regard to his first three months' work, while another inspector apparently will fail to meet acceptability criteria for his first six months' work. The attributes involved relate to weld inspection, and are all considered to be subjective attributes. The attributes include weld detail, type and profile, size, length, cracks, fusion, porosity, undercut, slag, craters, and overlap. The majority of inspection deficiencies identified to date involve weld undercut and overlap.

It appears that the first of the inspectors will achieve only a 75% acceptability level for his first three months of work, but his inspections in the next three months apparently will meet the 90% acceptability criteria for subjective attributes.

The other inspector apparently will attain a quality level of 85% for both his first three and next three months of inspections. Therefore, it appears that all of the inspections performed by this inspector will need to be reinspected, and in addition the original sample of Hatfield inspectors will be expanded by 50% with regard to the attributes at issue. That is, the original sample of 18 inspectors (only the inspectors selected at random,

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and not those selected by the NRC senior resident inspector, constitute the basis for the calculation) will be expanded by nine weld inspectors.

Q.16. When do you anticipate the initial reinspection of Hatfield inspection work to be completed?

A.16. I expect the initial phase of the reinspection program to be completed by mid-August. Of the initial 22 inspectors chosen, the work of seven at this point has been entirely reinspected, and each of these inspectors exceeded the established acceptable quality level.

Q.17. What steps are being taken for Hatfield work which is found to be unacceptable as the reinspection program proceeds?

A.17. Any work found to be unacceptable is being reworked to become acceptable. In those cases where the pertinent acceptance criteria have evolved over the years to be less restrictive than those applied originally the work is being evaluated against the contemporary criteria for acceptability.