ML20092P787

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Summary of Direct Testimony & Testimony of RP Tuetken Re Reinsp Program.Related Correspondence
ML20092P787
Person / Time
Site: Byron  Constellation icon.png
Issue date: 07/02/1984
From: Tuetken R
COMMONWEALTH EDISON CO.
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OL, NUDOCS 8407090373
Download: ML20092P787 (85)


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July 2, 1984 UNITED STATES OF AMERICA DOCKE7go NUCLEAR REGULATORY COMMISSION O'itlRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ag4 E '9 All :

In The Matter of )

) (fijcr p: ,c COMMONWEALTH EDISON ) Docket Nos. 30-454NOI;cdi,.n M COMPANY ) 50-455 OL O

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(Byron Nuclear Power )

Station, Units 1 & 2) )

SUMMARY

OF DIRECT TESTIMONY OF RICHARD P. TUETKEN I. Richard P. Tuetken is the Startup Coordinator -

Byron Station.

II. Mr. Tuetken testified before this Board on Aug.

11, 1983 (Tr. ff. 7760).

III. Mr. Tuetken is familiar with the Reinspection Program implemented at Byron in response to the NRC Staff's 1982 CAT inspection. As Assistant Superintendent, Project Construction Department, Mr. Tuetken was the senior construction manager directly responsible for implementation of the Reinspection Program. Mr. Tuetken also participated in the development of the Program.

IV. Mr. Tuetken describes the implementation of the Reinspection Program, beginning with the initial meeting, at which participating contractors were instructed in the operation of the Program.

Subsequently, weekly me etings were held between those contractors and 3;dison's Byron Project Construction Department and Byron Quality Assurance Department.

V. Mr. Tuetken describes the role of Allen Koca in the Reinspection Program.

VI. Mr. Tuetken describes the steps taken by the cor. tractors to identify the inspections performed by the inspectors selected to be reinspected in their first three months of work.

VII. Mr. Tuetken then testifies concerning the cert-ification of-inspectors who acted as reinspectors in the Reinspection Program.

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  • VIII. Mr. Tuetken's testimony also describes the measures -

that were taken to ensure that reinspections were performed properly. This testimony also encompasses the issue of whether the fact that reinspectors were aware of whose work they were reinspecting biased the results of the Program. Mr. Tuetken also discusses the procedure that was followed when contractors raised questions concerning the manner in which the Reinspection Program was to be implemented.

IX. Mr. Tuetken's testimony also includes discussion of those inspections performed by Hatfield, Hunter and Pittsburgh Testing Laboratory which were included in the Reinspection Program, and which types could not be reinspected due to inaccessibility or non-recreatability.

X. The testimony then describes the documentation generated by Hatfield, Hunter and PTL during the Program, and the measures that were taken to confirm the accuracy of the reinspection data that was generated by the contractors.

XI. Mr. Tuetken testifies concerning the problem that arose with regard to the documentation of discrepancies identified by Hetfield, Hunter and PTL during the Reinspection Program.

XII. The testimony then discusses the third-party review of reinspections of visual weld inspections and the results of this third-party review.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL

) 50-455-OL (Byron Station, Units 1 and 2) )

TESTIMONY OF RICHARD P. TUET}*EN Q.1. Please state your name.

A.I. Richard P. Tuetken Q.2. Did you testify before this Board on August 11, 1983?

A.2. Yes.

Q 3. Who is your employer?

A.3. Commonwealth Edisen Company Q.4. Do you hold the same position at this time that you 3_ held at the time of your earlier testimony?

A.4 No. On August 11, 1983, I held the position of Assistant Superintendent, Project Construction Depart-ment - Byron Station. On January 9, 1984, I assumed the position of Startup Coordinator - Byron Station.

As Assistant Superintendent, Project Construction -

Byron Station, I was responsible for overall coordina-l J

, .s tion and management of construction activities asso-ciated with construction of the Byron Generating Units.

Q.5. Please describe your current job responsibilities.

A.5. As Startup Coordinator, I am responsible for overall coordination of design, construction, and preopera-tional and startup testing operations associated with the commissioning of the Byron Station.

Q.6. Please describe your work experience prior to becoming Assistant Superintendent, Project Construction Depart-ment.

A.6. As I testified during my prior appearance before the Board, immediately prior to assuming my current posi-tion I was lead mechanical engineer with the Construc-tion 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, Powerton, Quad Cities, and Kincaid.

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  • Q.7. Are you familiar with the reinspection program imple-mented by Edison at Byron in response to noncompliance item 82-05-19 identified in the NRC Staf f's 1982 CAT inspection?

A.7. Yes.

Q.8. What is the scope of your testimony?

A.8. My testimony discusses the implementation of the QC inspector Reinspection Program at Byron, with emphasin on Hatfield Electric Company, ilunter Corporation, and Pittsburgh Testing Laboratory. My testimony will encompass the release of Allen Koca, as well as some of the questions concerning the Reinspection Program that were explicitly raised at pages 28 and 29 of the Atomic Safety and Licensing Appeal Board's Byron Memo-randum and order (ALAB-770, May 7, 1984).

Q.9. What was your role in the implementation of the Rein-spection Program?

A.9. As Assistant Superintendent, Project Construction-Department, I was the senior construction manager directly responsible for implementation of the Rein-spection Program. I also participated in the develop-ment of the Program prior to its actual implementa-tion. My primary role during implementation was to' 3-

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direct the contractors in execution of the Program, and I also oversaw the tabulation of reinspection data by the participating contractors.

Q.10. How many hours did you personally spend in implement-ing the Reinspection Program?

A.10. Between February, 1983, and February, 1984, I spent 20% to almost 100% of my time in any given week on the Reinspection Program, depending on the nature of the work being implemented at the time.

Q.11. When did implementation of the Reinspection Program begin?

A.11. Implementation of the Reinspection Program began in February, 1983, when I, Robert Klingler, and one or more representatives of the site quality assurance department met with specific contractors whose work was to be reinspected. Mr. Klingler is the Byron Pro-ject Construction Department Quality Control Super-visor, and he was responsible for the day-to-day implementation of the Reinspection Program, reporting directly to me.

Q.12. What was discussed at that meeting?

A.12. At the initial meeting the purpose and nature of the reinspection activities to be performed and the

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requirements of the February 23, 1983 letter from Edison to the NRC Staff which outlined the program and criteria for reinspection were discussed. The basic instructions given to the contractors were that:

(1) the reinspections were to be conducted employing the original acceptance criteria used at the time of the original inspections; and (2) individuals involved in reinspection of work could not be the same inspec-tors who performed the original inspection. The con-tractors also were informed that the need for removal of fireproofing, paint, and insulation did not render an item inaccessible for the purposes of reinspection.

Q.13. Were there subsequent meetings with contractors regarding the Reinspection Program?

A.13. Yes. As the Frogram proceeded, weekly meetings were held between the participating contractors and Commonwealth Edison's Byron Project Construction Department and Byron Quality Assurance Department to communicate and resolve questions concerning the ongoing program, to establish mennods to be employed in recording results, and to determine action to be taken on discrepancies observed in the reinspection effort.

I v i Q.14. What steps did the contractors take to implement the Reinspection Program?

A.14. After the first meeting, at the end of February, 1983, the contractors began the process of searching their records to identify the inspections performed by the selected inspectors during the first three months of '

these inspectors' work after their initial certifica-tion. This process produced a sufficient volume of work to enable physical reinspection activities to begin by about the middle of March, 1983. In addition to the general guidance discussed above, specific guidance concerning implementation of the reinspection program was provided to each contractor. Mr. Klingler provided oral guidance in the first three to six weeks of the Program to each of the participating contract-ors, including Hatfield, Hunter, and-PTL, so that the contractors implemented their reinspection programs in appropriate fashion. Among the items on which Mr.

Klingler provided guidance were the identification of appropriate reinspection procedures and criteria to be applied to the selected inspection pcpulation.

Q.15. What contractor officials were responsible for imple-mentation of the Program?

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-A.15. The contractor officials primarily responsible for implementation of the Program were the senior site quality assurance personnel for each contractor. The exception to this was that in the case of Peabody Testing Services, which was no longer on site, Pittsburgh Testing implemented the reinspection of Peabody Testing's inspection work.

Q.16. What was the role of Allen Koca in the Reinspection Program?

A.16. Allen Koca's role in the Reinspection Program was limited to supervising the Hatfield QA clerical staff review of certification records to identify the roster of inspectors based on certification date(s). This roster provided the basis from which the first and every fifth inspector thereafter were drawn for the Reinspection Program. Subsequent to this, Mr. Koca's role consisted solely of supervising the clerical staff members who were responsible for searching the inspection record files to identify each individual inspection performed by the selected inspectors in their first 90 days.

Q.17. Was Mr. Koca's release from Hatfield in October, 1983, related in any way to his work on the Reinspection Program?

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A.17. No. l Mr. Koca was released because of the fact that <

friction between Hatfield quality control inspectors and Mr. Koca was believed to be undermining his abil-ity to assist in the implementation of an effective quality assurance program by Hatfield. In addition, the NRC Region III Staff had expressed concern about Mr. Koca's job capabilities generally, and Edison shared the Staff's concern.

Q.18. Was the work performed by Mr. Koca on the Reinspection Program satisfactory?

A.18. Mr. Koca's work was satisfactory, as demonstrated by audits performed by the Commonwealth Edison Byron Site Quality Assurance Department in June, 1983 (Audit 6-83-66) and August, 1983 (Audit 6-83-124). These audits confirmed that Hatfield had properly prepared the chronological listing of inspectors from which the reinspection sample was selected, and had properly established the population of inspections for each selected inspector.

Q.19. What was the role of Edison's Byron Project Construc-tion Department as the Reinspection Program proceeded?

A .19 .- The role of Edison's Byron Project Construction Department basically was to guide the contractors in 1

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l the implementation of the Program, responding to ques-tions of implementation, coordinating schedules for implementation, monitoring performance and assessing and directing personnel and time resources. This direction was provided primarily through weekly sched-uled meetings with the contractors and through direct involvement on a daily basis with the contractors by Mr. Klingler.

Q.20. Please describe Mr. Klingler's responsibjlities as Byron Project Construction Department Quality Control Supervisor.

A.20. As the Project Construction Department Quality Control Supervisor Mr. Klingler is responsible for the devel-opment by site contractors of their quality assurance procedures and for the training by the contractors of their QA/QC personnel. Mr. Klingler's responsibili-ties also include execution of corrective action taken in response to items identified by the NRC and by Edison's site and corporate quality assurance depart-ments, direction of Field Change Request close-outs, and direction of receiving inspections for the site.

Q.21. Please describe Mr. Klingler's work experience prior to his becoming Project Construction Department Qual-ity Control Supervisor. l 1

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, o A.21. Mr. Klingler became Project Construction Department Quality Control Supervisor in October, 1981. Imme-diately prior to that Mr. Klingler was a Quality Assurance Supervisor at Byron, with responsibilities in the areas of electrical work, independent testing, and documentation. As a QA Supervisor Mr. Klingler was directly responsible for the site quality assur-ance department's involvement with Pittsburgh Testing Laboratory and Hatfield. Mr. Klingler was a QA Super-visor from December, 1980, to October, 1981. From March, 1978, to December, 1980, Mr. Klingler was a Quality Assurance Engineer at Byron with responsibili-ties in the electrical and mechanical areas. As a QA engineer Mr. Klingler performed quality assurance functions involving Hatfield and Hunter. Mr. Klinger began his employment with Commonwealth Edison in 1975.

In October, 1980, Mr. Klingler was certified as a Level III Inspector in quality assurance. At the time l

he was a QA Engineer Mr.Klinger was certified as a l Level II Inspector in the areas :f sual weld, radio-graphic, liquid penetration, magnetic particle, re- I ceiving, and other types of ir.r t::icns. Mr. Klingler received a Masters Degree in Electrical Engineering from Purdue University in 1974.

, s Q.22. How was the work performed by Hatfield Electric Com-pany, Hunter Corporation, and Pittsburgh Testing Laboratory inspectors in their first 90 days of work identified?

A.22. Great care was taken to identify and isolate the inspections performed during an inspector's first three months of work. Such care was necessary because of the fact that over the years many attributes were inspected more than once, by different inspectors.

Multiple inspections of an attribute could occur under various circumstances, such as where an installed com-ponent was reworked as a result of a design revision or other reason. Consequently, contractor personnel, under the supervision of Edison's Byron Project Con-struction Department and Byron Quality Assurance, carefully reviewed inspection records to ensure that the appropriate initial inspections were reinspected.

In order to ensure that appropriate steps were being taken to identify the appropriate inspections, M r .-

Klingler personally reviewed the programs being fol-lowed by each contractor.

With regard to Hatfield Electric, due to the fact that the inspection records were filed by inspection report number rather than by inspector or by component, the process of identifying those inspections performed by l

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  • the selected inspectors required that every inspection report be reviewed to determine its^ inspector. Also, due to the fact that the inspection reports were filed sequentially by inspection report number, the files were reviewed to ensure that an inspection report associated with an inspector's first 90 days had not been superceded by a revision to the installation which was covered by a subsequent inspection report.

Due to the vast number of weld traveler cards prepared for installation and inspection of Hatfield components (i.e., a single Hatfield component could have as many as 10 weld-traveler cards prepared during the course of installation), steps had begun prior to the rein-spection program to place weld traveler data on a Wang electronic data base in order to assure accuracy and accessibility for Hatfield weld records. This program was completed during the course of the reinspection program, and the electronic data base was used to ensure that the appropriate weld inspections were reinspected for the selected inspectors.

Hunter Corporation recorded inspections by component.

Thus, determination of the inspections performed by the' selected inspectors'in their first 90 days was primarily done by review of the inspectors' daily logs to determine the components they had inspected, l

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, . 1 With regard to Pittsburgh Testing Laboratory, the in-l spections were filed by inspection, a system similar to that described above for Hatfield. The inspection reports on file were reviewed to identify the inspec-tions performed by the selected inspectors during their first three months. To ensure that the identi-fied inspections had not been subsequently superceded, PTL also conducted further reviews. For visual weld reinspections PTL examined the component files of Blount Brothers Corporation, Mid-City Architectural Iron, and American Bridge to determine whether revi-sions to welding had occurred after the date of ini-tial inspection. PTL inspectors performed weld inspections for these contractors, and review of the contractors' component records was necessary because of the fact that PTL's own inspection records would not necessarily include the inspection data detail found in the component records. For concrete expan-sion anchors, the other attribute reinspected by PTL, any modification of the component would be evident at the time of reinspection. Therefore, PTL would either review the component records of the installing con-tractor or, if a contractor's work did not provide ready accessibility to information on CEAs, examine the component in the field.

Q.23. Why was it important to reinspect the actual inspec-tion performed by a particular inspector, rather than to simply reinspect the attribute that had at one time been inspected by the inspector?

A.23. It was important to reinspect the actual inspection performed by a particular inspector due to the fact that the questions and uncertainties which caused the Reinspection Program were associated with the qualifi-cation and certification practices used to establish inspector capability. In order to address this ques-tion, the necessary focus was on the performance of individual inspectors rather than on types of inspec-tions. Therefore, identification and' isolation of the inspections performed by the selected inspectors was a prerequisite to valid results as the Reinspection Pro-gram progressed.

Q.24. Who were the inspectors that performed reinspections?

A.24. The inspectors who performed reinspections were QC inspectors for the contractors whose work they were reinspecting.

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Q.25. Were the inspectors who performed reinspections prop-erly qualified and certified?

. A.25. Yes. These inspectors were qualified and certified to

the standards that were/ developed by Edison in 1

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> , / response to IE Report Nos. 50-454/82-05 and 50-455/82-04. In response to noncompliance 82-05-19, t-on June 9, 1982, Edison directed its Byron contractors to develop inspector qualification and certification programs which incorporated standardized requirements

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O for the attributes included in ANSI N45.2.6, such as work experience, education, on-the-job training, test-ing, and demonstrated capability. The procedures

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.. inspection Program were reviewed by Edison and all were approved for use by the end of September, 1982.

t Hunter's and Hatfield's revised procedures were ap-proved in August, 1982, and PTL's in September, 1982.

From the point that a contractor's revised inspector qualification / certification procedures were approved for use each new inspector was trained and certified to the new procedures. In addition, beginning at the time of procedure approval, each existing inspector

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,.  ; was recertified to the new procedures.

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During subsequent review of these procedures by Edi-son's Byron Quality Assurance Department, minct modi-g 1 < fications were made to the contractors' certification O

t, ', procedures. These modifications did not require significant alteration of the procedures in place, however, and Edison's site QA department deemed all l

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inspectors who were certified to the procedures ap-proved by the end of September, 1982, to be properly qualified and certified.

Consequently, the 'einspection Program was performed by reinspectors who had been either newly-certified or properly recertified before commencing reinspections.

It should be noted that a Hunter inspector began rein-specting on April 7, 1983, even though he was not for-mally recertified until April 26, 1983. This inspector, however, had completed the training neces-sary for recertification by March 24, 1983, and thus was certifiable under the revised procedures although the documents indicating that he was officially recer-tified were not signed off until several weeks later.

One inspector, who had performed inspections subse-quent to his recertification, later was determined to have not been properly certified.. In early 1983, the NRC Senior Resident Inspector, William Forney, deter-mined that a Hatfield weld inspector, Tom Wells, was not properly certified. Mr. Wells had been recerti-fied in October, 1982, but Mr. Forney concluded that Mr. Wells' experience background did not meet the requirements for prior nuclear-related work, in that-much of Mr. Wells' prior work experience involved non-safety-related work for Eko-cel, a Byron contrac-  ;

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tor. Hatfield had interpreted the prior experience requirement for inspector certification to allow in-clusion of this non-safety-related work performed at the site. Mr. Wells was a veteran Hatfield inspector, and in order to demonstrate his capability as an in-spector Hatfield reinspected the first 30 days of Mr.

Wells' work subsequent to the date of his recertifica-tion. This reinspection resulted in a 99.07% accept-ance rate for the reinspectable visual weld inspec-tions performed by Mr. Wells during the 30-day period. Mr. Wells' qualifications as an inspector were further demonstrated by his performance in the reinspection program; Mr. Wells was one of the Hat-field weld inspectors whose work was reinspected, and he achieved an acceptability level of 96.9% in the first three months of inspections that he performed for Hatfield. Subsequently, in April, 1983, Mr. Wells was again recertified through the substitution of additional training for prior work experience. Mr.

Wells did not perform reinspections until he was re- ,

certified in April, 1983.

Q.26. Did Hatfield, Hunter, and Pittsburgh Testing Labora-tory inspectors who were already on-site at the time l that the revised certification procedures were approv-l ed for use by these contractors continue to perform inspections pending their recertification?

A.26. Yes. These inspectors continued to perform inspec-tions pending their recertification.

Q.27. What is the assurance that the inspections performed by these inspectors prior to their recertification were performed properly?

A.27. The work of all these inspectors was encompassed by the Reinspection Program, insofar as these inspectors had been certified prior to the approval of the re-vised certification procedures. Consequently, the Reinspection Program's demonstration of the quality of the inspection work performed by inspectors certified prior to September, 1982, encompassed the inspections performed by inspectors who subsequently were recerti-fied in accordance with the revised procedures.

Moreover, the Reinspection Program itself reviewed inspections performed subsequent to the approval of revised certification procedures. That is, the pro-gram examined the first three months of work performed by inspectors who were certified frem 1976 right up to the date the revised procedures were implemented; thus, the program included the first three months of work of at least a small number of inspectors who were certified during the summer of 1982, and this three-month period extended into or beyond September, 1982.

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Q.28. How many inspectors performed reinspections?

A.28. For all of the. .ontractors participating inlthe Rein-spection Program, a total of 152 inspectors partici-pated in the Program as reinspectors.

Q.29. How many man-hours were involved in the performance of reinspections?

A.29. Approximately 80,000+ man-hours of actual reinspec-tions were performed, and approximately 160,000+ addi-tional man-hours were spent in construction, clerical, and administrative support work related to the Rein-spection Program.

Q.30. How many reinspections were performed?

A.30. Over 202,000 inspection points were reinspected.

Q.31. Were measures taken to ensure that the reinspections were performed accurately?

A.31. In order'to ensure that the reinspections were being accurately performed, Commonwealth Edison's Byron Quality Assurance Department carectec Pittsburgh Test-ing Laboratory to perform a special unit concept in-spection to determine if PTL's inspectors would independently arrive at the same inspection results as the contractors' quality control inspectors who were performing the reinspections. This overinspection was  !

i performed during the period of August 1 through Sep-tember 19, 1983. The PTL overinspectors rechecked the work of seventeen reinspectors who were employed by Hatfield, Hunter, Blount Brothers, NISCo, Johnson Con-trols, and Powers-Azco-Pope. Work which these con-tractors' reinspectors had found to be acceptable was rechecked by the Pittsburgh Testing inspectors. The PTL overinspection was then supplemented by indepen-dent third-party reviews of the visual weld inspec-tions rejected by PTL. Of about 1,185 objective and subjective items checked by overinspection, only nine (involving six inspectors) were deemed to be discre-pant after the unit concept inspection and independent third-party review. Therefore Edison concluded that the reinspections were being performed in accurate fashion. '.

4 Q.32. Were measures taken to ensure that inspectors did not reinspect their own work?

A.32. Yes. When supervisors assigned work to reinspectors they did so after verifying that the inspector per-forming the reinspection was not the original inspec-tor.

Q.33. Were the reinspectors aware of whose work they were reinspecting?

A.33. In most cases, the reinspectors were aware of whose work they were reinspecting. Generally, the informa-tion provided to reinspectors to enable them to per-form their reinspections contained the name or initials of the original inspector. The exception to this was the case of as-built dimension inspections.

For these reinspections the original documents which recorded the results were not provided and in their place drawings and information which did not contain the original inspector's initials or name were provid-ed for implementation of reinspection.

Q.34. Did the results of the Reinspection Program indicate whether or not reinspectors demonstrated bias in favor of the inspectors they reinspected?

A.34. The unit concept inspection conducted by Pittsburgh Testing Laboratory, described in answer to Q.31 above, demonstrated that the reinspectors did not bias their results in favor of the inspectors whose work they were reincpecting. The PTL inspectors who performed the unit concept inspection were totally independent from the contractors being reviewed, and consequently I

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integrity of the reinspections performed by the con- )

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l Q.35. LDid the contractors performing the reinspections pro- l vide periodic reports to Edison?

A.35. Yes. The contractors performing reinspections provid-ed periodic status reports to Edison's Byron Quality Control Supervisor (Mr. Klingler), usually in the weekly scheduled meetings. In the initial stages, these reports consisted primarily of information re-garding record searches being performed to identify the appropriate population of inspections for each inspector; subsequently, as actual reinspections were occurring, the reports encompassed the number of rein-spections completed, the resources being committed to reinspections in terms of numbers of inspectors, iden-tification of needs for craft support to enable access to perform the inspections, and other needs and infor-mation pertaining to Reinspection Program coordina-tion. As the Program reached its approximate mid-point, the reports identified the results of reinspec-tions, either on tabulation sheets or through oral communication. As the Program was approaching its end-point, contractor repcrts identified the develop-m,it of appropriate nonconformance system documenta-tion associated with corrective action requirements for discrepancies found in the program, and ultimately the final statistics associated with each individual inspector.

I Q.36. As the Program proceeded did the contractors raise questions concerning the manner in which the Reinspec-tion Program was to be implemented?

A.36. Yes. When a contractor had a question concerning implementation of the Reinspection Program, its per-sonnel would raise the issue with either Robert Klingler or myself. If Mr. Klingler or I determined that the issue required the contractor's implementa-tion of the Program be modified to reflect the problem, we would direct the contractor to place its question in written form. Upon receipt of the written request for interpretation of the Reinspection Pro-gram, Mr. Klingler or I would sign off on the re-quest, numbering each such request sequentially to ensure that they were properly recorded. A total of 22 such " interpretations" were generated during the reinspection process, and they are apoended to my testimony as Attachment A. These interpretations were disseminated to all of the contractors involved in the Reinspection Program, for their guidt.nce.

Q.37 Aside from the questions which led to the creation of the interpretations described in Q.36, above, did other problems arise during Hatfield's, Hunter's, and PTL's implementation of the Reinspection Program?

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A.37 The audits and surveillances performed on the Reinspection Program by Edison's Byron Quality Assurance Department noted several findings and observations in the implementation of the Program by the contractors. These audits and surveillances are discussed by Mr. Shenski.

Other than these issues, and in addition to the broad-er questions which led to the creation of the inter-pretations, minor implementation problems did arise for each of these contractors. For example, changes made in the identification numbers of plant components by Sargent & Lundy as a result of S&L's ongoing engi-neering evaluations performed during construction posed problems for severcl of the contractors partici-pating in the Reinspection Program, particularly Hat-field; the elimination of original surveyor point-of-reference marks at locations in the plant made it more difficult to establish reference points for some of the inspections that were being re, inspected; and con-struction activity rendered a::ccr tr therwise rein-spectable inspections significantly more difficult.

Although problems such as the::  ::sd Obstacles to performance of the reinspections which were to be con-ducted by Hatfield, Hunter, and PTL, the contractors were instructed to devote the additional effort neces-

, o sary to identify the appropriate inspections to be reinspected and to obtain access to the inspections.

In short, unless the contractor formally obtained approval from Edison's Byron Project Construction Department, through a numbered interpretation, to not perform particular reinspections, the contractor was required to take the steps necessary to properly implement the Reinspection Program.

Q.38. What types of inspections performed by Hatfield, Hunter, and Pittsburgh Testing Laboratory were includ-ed in the Reinspection Program, and what types could not be reinspected due to inaccessibility or non-re-creatability?

i A.38. Attachment B to my testimony presents a tabulation which lists type of inspection, whether it was rein-spectable or not, and if not, why it was inaccessible and/or not recreatable.

Q.39. Approximately what proportion of total inspections performed by Hatfield, Hunter, an PIL could not be reinspected because of inaccessibility and/or non-recreatability?

A.39. For Hatfield, approximately 80% of the total inspec-tions performed during the contractor's tenure at Byron (up to the date its revised certification proce-o .

dures were implemented) was reinspectable. For. ,

l Hunter, this number was approximately 70%. For Pitts-burgh Testing Laboratory, appreciably less than 50% of the inspections performed prior to the implementation of its revised certification procedures was reinspect-able.

Q.40. Please describe the documentation generated by Hat-field, Hunter, and PTL during the Reinspection Program.

A.40. The contractors developed documentation which consist-ed of the original inspection report prepared by the reinspected inspector, the record generated by the reinspector (which generally was a duplicste of the original inspection record with the reinspector's notations added), the tabulations prepared for each inspector to determine whether the inspector satisfied acceptability requirements, and the tabulations of discrepancies identified through reinspections.

Q.41. What measures were taken to confirm the accuracy of the reinspection data generatec =y Hatfield, Hunter, and PTL?

A.41. Edison's Byron Quality Assurance Department conducted an audit (6-83-93) and surveillances to ensure that the tabulations of data prepared by the contractors were accurate. Audit 6-83-93 and the surveillances are discussed in Mr. Shewski's testimony.

In addition, in late 1983 and early 1984 Sargent &

Lundy reviewed the data generated by these contractors when it performed its evaluation of the discrepancies .

identified during the Reinspection Program. With minor exceptions, Sargent & Lundy confirmed that the numbers reported by the contractors for acceptable and unacceptable inspections were accurate.

Q.42. Did problems arise with regard to the documentation of discrepancies identified by Hatfield, Hunter, and PTL as the Reinspection Program progressed?

A.42. Edison Byron Quality Assurance Department Audit 6-83-66, conducted in June and July, 1983, found that certain contractors, including Hatfield, Hunter, and Pittsburgh Testing Laboratory, had not yet initiated the documentation required by the contractors' quality assurance p t ograms to correct or disposition discrep-ancies identified by the Feinspection Program. Each contractor was recording all discrepancies on its reinspection records, but each dir:repancy had not yet been documented either on an individual discrepancy report or as part of a nonconformance report.

Q.43. What steps were taken by Hatfield, Hunter, and PTL in response to Audit 6-83-66?

A.43. Documentation of discrepancies was performed through the utilization of discrepancy reports and nonconfor-mance reports, in accordance with the contractors' quality assurance programs.

Q.44. Were all discrepancies identified by Hatfield, Hunter and PTL, in the Reinspection Program, whether identi-fled before or after Audit 6-83-66, documented in accordance with the QA programs of these contractors?

A.44. Yes. All discrepancies which had been identified prior to the issuance of the audit, as well as those identified subsequent to the audit, were documented through the use of discrepancy reports or nonconfor-mance reports.

i Q.45. Were all identified discrepancies included in the data base of the Reinspection Program, regardless of whether they were identified before or after Audit

^

6-83-66?

! A.45. Yes.

Q.46. Please describe the third-party review of reinspec-tions.

1 A.46. In order to assure that reinspection results of visual weld inspections were consistent and valid, thirdparty l l

overview inspection was performed on those weld in-spections which were found to be discrepant by rein-spectors. Third-party review of weld reinspections was incorporated into the Reinspection Program due to recognition of the subjective nature of visual weld inspection; third-party review by a Level III inspect-or was designed to ensure that rejections of original inspections were proper, and that such rejections were not the result of overconservatism on the part of re-a inspectors. All but one of the third-party reviewers were Level III inspectors employed by Sargent & Lundy and by Daniels Construction Company, the other being a Sargent & Lundy Level II inspector.

Q.47. What were the results of the third-party review of reinspections for Hatfield, Hunter, and PTL?

l A.47. The results of the third-party review are found in Table A-5 of Appendix A of the February, 1984, Report on the Byron QC Inspector Reinspection Program. The i

third-party reviewers examined 3,136 weld discrepan-cies identified by Hatfield reinspectors, and deter-mined that 1,150 of these should have been accepted by the reinspectors rather than rejected. The thirdparty reviewers examined 121 weld discrepancies identified

by Hunter and determined that 12 should have been

accepted rather than rejected. For PTL the i

third-party reviewers examined 999 weld discrepancies identified by reinspectors, concluding that 94 should actually have been accepted. PTL reinspectors also were responsible for the reinspection of work per-formed by Peabody Testing, and third-party reviewers

examined 46 weld discrepancies identified by PTL rein-l spectors, determining that six should have been accepted rather than rejected.

These third-party review results confirmed for Edison that the reinspectors of Hunter, Hatfield, and PTL generally were evaluating weld inspections consistent-ly and accurately, except for the conservatism which appeared in the results of each of the contractors.

Such conservatism enhances the results of the rein-spection effort of visual weld inspections, suggesting that the contractors' overall reinspection results have a slight conservative bias, in addition to the conservatisms built into the P.e-- ;trt:cn Program as a

! whole.

Q.47. When was the Reinspection Program completed?

A.47. The basic Reinspection Program was completed in

m.id-January, 1984. The Report on the Byron QC Inspec-l

l tor Reinspection Program was then completed in February, 1984. As a result of questions by the NRC Staff, supplemental inspections (which were not encom-passed by the requirements of the Reinspection Pro-gram) were performed between February and April, 1984. In addition, a Supplement to the February, 1984 Report was completed in June, 1984, reflecting further review of the Reinspection Program by Sargent & Lundy and Edison's Project Engineering Department.

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TUETKEN ATTACHMENT A i

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l PJ.Tr! .! u : : scru e cr; :w p$ CAiGC i.??:..=.:..a2: rrY:G l $/ i f To: I'hCM: All Lend Ir.spectors J.K. Buchanan q I l0g gl ()l,h V 14 DiTE: '~ arch 12, 1983 '

          .4 .7.7:CT:       4 c ., . . r , in:;r.raction :'.h Please be advised that all reinspecti:ns perforced in the secpc of Managers Instruction 108 shall be done by taking *,v data =>-d en- a-4ne namn with the orevious we allow the inspec tor to tar.e     insrec
ne 2.nicrsa tion non-data.JIn currently no case in tne sr.all Itle 7I and simply reverify the data.. _ #

See me at once if you have any questions concerning this directive. This direction is a result of a discussion with Bill Forney and Kevin kb Connaughlar of the U.S.,N.R.C.

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                  --                                                          p          p IN ER COMP        Y ORRESPONDENCE h

WE April 12, 1983 f .hk

                                                                                       /     g m-rau Suonct Bob Klingler Lee E. Hadick NPC Reinspection Meeting of April 11, 1983 I

f

                                                                                      !'   i\/

r It was my understanding that we will not perform any turn of the nut inspections. They will be shown as inaccessable. If punch marks are not present on a fit-up inspection (small h bore) the inspection will be shown as inaccessable. hI Final torque will be verified by using a calibrated wrench. We will tighten each bolt in sequence, stop when the nut begins to turn, and record this data for each stud. We will not bring the bolt up to final torque condition. g#f On type 3/4 inspections damage will be considered inaccessable. g b If we are verifying a type 3 inspection and a type 4 was performed, 4 it will be shown as inaccessable. If we are verifying a type 4 inspection and another type 4 (45 day) was performed, it will be shown as inaccessable. If we are verifying a type 4 inspection, we will do it without removing the covering (inplace, intact). We will proceed in the fashion shown unless otherwise informed.

                             ,h.Ynt        e LEE E. HADICK Quality Control Supervisor cc:   M. L. Somsag LEH/pb 1

I A-4

g Johnson Controls, Inc.

                                                    .              Pow r Unit-Midwest
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720 Industrill Driva

 -                                                                 Bensenville. IL 60106 Tel. 312/595 5650           A
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Systems Engineering & Construction Division NU a A 9 f Date: April 29,1983 OJMMOtMEAL'HI EDISON CCr@ANY Byron Station Construction R.R. #1 P.O. Box B Dyron, Illinois 61010 Attn: Mr. R. Klingler

Subject:

N.R.C. Re-Inspection bbeting of April 11, 1983

Dear Bob,

It was my understanding that we will not perform any receiving inspections as nuterial has already been used. They will be shcun as inaccessable. We will proceed in the fashion shcun unless otherwise infomed. Sincerely, Bansi Sluh QA obnager BS/Im

I ,

         *..                                                                                                                l
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                                                                                                                            \

S F REPLY X IN WRITING FH0M. PITTSBURGH TESTING LABORATORY O BY TELEPHONE

      ,              Byron Station                                                                (815) 234 5095
  • P.O. Box 416 Byron, IL 61010 e do A/. [ .c- f); 'f_ ,. ,

f kJ I O BY AS S N AS ARE O /@T NECESSAFtY

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  • DATE RETURNED:

FOt D hf hbY ' f@ Q' k &f( is de u pP' 76 cA 4 RadMrfeOki/ 0p 5Aeticruta jo/V'ld9. /4 xdo dy' < Pt L cluunap%h' d'ef dol sks ue ;rsl[8"Yuwf id6mut lastedac4 shesn ya pee / G ea 4 A od is ds n E s tis Pg w a d o '= sranna/ .Bv/y!)pg, P/ade' AdMo- SIGNED ll[N

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                      .snzbv A4/ onaudu-SIG N E D
                                   . C:mm:nwsilth Edis:n '                                      dj y n Ga erating Station      ,

y j, Byron Illinois 31010 May 11, 1983 . 4 TO: llunter Corporation Powers-Azco-Pope gf+9 = P. O. Box 674 Byron IL 61010 P. O. Box 392 Byron IL 61010 p ATTN: B. Krasawaski ATTN: B'. Schulz f0 t I

SUBJECT:

Relaxation of Bolt Torque y g h h)1 Due to the physical phenomena of decrease in bolt stress as a resuiu f& gU of creep in the bolt and/or gasket material, activities of reinspec- V tion of piping system bolt torque shall use the reduction value i identified in the attached Sargent & Lundy letter SLBT-1050. {] 1 < If you have any questions on the foregoing or attached, please contact us. Very truly yours, COMMONWEALTH EDISON CO. 2 e o I / 83 R. Tuetken Assistant Superintendent Project Construction Dept. HPT:bg Attachment cc: M. Lohmann (1/wl) M. Stanish (1/wl) B. 'Klingler T~.(1/wl~) ' D. DeMoss (1/wl) M. Somsag (1/wl) B. Larkin (1/wl) 1

                                                                                                               +

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CARGENT & LUNDY '

4. * . ENGINELRG
                                                           . cu nct.co BYRON FIELD TRANSMITTAL FORM Date                   5-06-83 COMMONWEALTIl EDISON COMPANY Byron Station - Units 1'& 2                                                   Trans. No. SLBF-1050
                                                                             ~

Page 'l of 1 Project Nos. 4391/92

Subject:

Piping System Bolt Sorque Relaxation - Alloy Steel Bolts From: D.'n. Gallagher/D. Demoss To: R. P'. Tuetken , Company: Commonwealth Edison cc: W. C. Cleff - 22 S&L has reviewed piping system bolt torque relaxation and finds reductions in torque of up to 30% of initial torque can occur. If bolt torques are found to be below 70% of initial torque, the bolts should be pulled up to achieve the initial torque. Bolts used include A-193, A-325 and A-490. Crane Engineering . Data Handbook Section 31 - Bolting --contains an

   .      expanded discussion of bolt torque relaxation.

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me - 1 HUNTER CORPORATION . 3800 179TH STREET. HAMMOtJD. ItJDIAtJA 46323. (219)845-8000 (312) 731-8000 i( l g, + y Date: June 1, 1983 [ F To: Bob Klinger From: Lee E. Hadick

Subject:

NRC Reinspection [j Per our conversation of May 31, 1983: When hardware / weld reinspections cannot be performed due to the hot functional testing taking place in Unit 1, we will show it as inaccessible and state why. The inspectors surveillances will be researched sequen-tially for the next hardware / weld inspection (beyond his first three months) which will then be used in lieu of the original. We will proceed in the fashion shown unless otherwise informed, b . d[42/ LEE E. HADICK Quality Control Supervisor cc: M.I.. Somsag i a S f ( \p A-? l CHICAGO, LLINOS HAniseONO.. INDIANA CAAL5040 CAttOAN'A

l

        ~
   .,        .                              Hatfield Electric Company
         '                                                                                  (       I     i Byron Units 1 & 2                                        I QA/QC Memorandum #876 48 a-          )(D
                                                                                 \9                         ,

TO: FROM: R. Klingler, CECO P.C.D. J. T. Ilill, QA/QC Manager l 3 V'. M\ V l DATE: 6-20-83 '

SUBJECT:

Removal of Transco Firestops for reinspection of Conduit age t There are some conduit hangers involved in the N.R.C. reinspection program which have been covered by "Transco" firestops thru floor penetration. Locations are: 451' - IPA 04J, IPA 09J, IPA 10J, IPA 12J, and IPOA22J, Aux, equipment room. Should we request removal of this material or delete them from the reinspeciten program? Known hanger population at this time is 27. Removal of this material could possibly damage cables encasd in these firestops. Please Advise!

                                                   /#

J. T. liill QA/QC Manager JTil/1js 0 BC kk dL#** 8[ , aL A su  : a us"& p . & n d A t w ns. ~ .c '( W f ' " 0 "' k . 19a,pc/s c$d*k s. - k to

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  • REPLY O IN WRITING
                                                              ~

FROM: 'PITTSBURGH TESTING LABORATORY O BY TELEPHONE Byron Station (815) 23+-505 P.O. Box 416 Byron, IL 61010

p ELRoLH*s NAML O AS SOON AS ABLE
  • M.R. Tallent. Jr. f CH-3850 C NOT NECESSAflY
                                                                            ,          I   BY                                Date
                                                                                       )   susJECT:

TO: . h, I Reinsoection oare stur: R.B. Klingler > Junn 7. 14R1 CECO PCD d l r (' " ' ' " ' ' ' " ' ' ' I,, l oarco acreo upon g

                                                                  \1             D y h 8.\                               ^"""""'o'
, _ } g[J rni n V- VU Per our recent conversation, we are considering that welds for RSM are "not reproduceable" due to the following features:
1) The welds have been, and are being, reworked
2) We do not have a tracking system to determine reworked items
3) Ue cannot determine, from our reports, wnich welds on a given hanger were originally inspected.

d1h ,,au,, gpy (,.7_fg

                                                                                         /

a-u S- J 4 _ ,, , $ 75

                         - .          .-                                                             <1
        .f a            ,-         .-   Commonwealth Edison'
  • i- -5 Byron Gen: rating Stition *
  • 6, . .Af'/ P.O. Box 8
                                      . Byron. lilinois 61010 July 7, 1983 TO: Hatfield Electric                                     Pittsburgh Testing Lab / Peabody Attn: T. Hill                                  Attn: M. Tallent Hunter Corp.                                   NISCO Attn: L. Hadick                                Attn: K. Jackson Blount                                         Johnson Controls Inc.

Attn: W. Wills Attn: B. Shah Powers-Azco-Pope Attn: R. Larkin l

SUBJECT:

Quant,ity_o[ ,0C Inspector Reinspections QIp,terpretation t No. ,9),' REi-ERENCE: Letter Stiede to Keppler dated 2/23/83 Durin$ the selection of itemcd Ato be reinspected for each QC inspector, it is possible that within the initial 90 day period a low quantity of reinspectable items exsist. ~ The following minimum quantity of items are to be respected per inspector: Contractor Minimum Items PTL, Peabody 25 Hatfield, Hunter, 50 JCI, Blount, . PAP, and Nisco - If required the addit'ional items falling outside the' initial 90 day period shall be chosen chronologically up to and including the last , day of scheduled reinspection for the entire population. 4 e [ l l A'Ir .

  • l *^ .
         '                                                                                                                 page 2
   -,-            ..                                                                                                                                       1 Please contact me if you have any questions or cannot meet this mini-                                              .

mum requirement. Note h An installation (or part of) which requires evaluation to all checklist criteria.

                                                                                                                          *7 Robert B. K1'r ler Project Construction Dept.

OC Supervisor Byron Station cc: G. Sorensen R. Tuetken ,. M. Stanish File, G9.0; 82-05/82-04 f 6 l 0.

                                                                                                                                                   .' ~

i

>                                                           A - 13'.                                                              .

Z-ll e - HUNTER CORPORATION 3800-179TH STREET, HAMMOND, INDIANA 46323, (219)845-8000 (312) 731 8000 p Date: July 8, 1983 a k. g/V gf/ fd 1 To: Bob Klinger gp . From: Lee E. Hadick

Subject:

NRC Reinspection Class D Inspections have not been included as a part of the NRC Reinspection Program; consequently, they will not be listed on the computer printouts. Please inform us if this policy is acceptable.

b. kA q LEE E. HADICK Quality Control Supervisor
                                                                                                       '/r f

cc: M. L. Somsag V h [/ cj j

                                                                            / /) W                             p?

(9/ - 4 S i A -19 CH'CAGO. ILLINOIS HAA%'ONO. INDIANA CARLS8AD CALFORNi4

4 PTL-CHICAGO Pittsburgh sr.m g nM*"' Laboratory N

                                                                                                                             \\    m s

f [ (3 July 11, 1983 Letter #70-83-040 .* v i lJ g q

                                                                                                                          ,l 13 Mr. R.P. Tuetken                                                                                  r       j Asst. Construction Superintendent                                                                        h, COMMONWEALTH EDIS0N COMPANY Byron Nuclear Power Station Byron, Illinois      61010 f/

SUBJECT:

Reinspection Program

Dear Mr. Tuetken:

We have been carefully evaluating the resultant data obtained from our reinspection activities, and have noticed an item relating to visual welding inspection that causes us some concern. - This concern is as follows:

1) We believe the acceptance criteria we are currently using, regarding visual welding inspections made by our Reinspection Team, is not the same as that used in the original inspection.

NOTE: We are aware that AWS Dl.1 is the written criteria which was stated as acceptance criteria for the original inspection. However, we believe the original inspectors did not envoke all the criteria of AWS D1.1, Clapter 6 and Para 8.15, as we are now trying to do, plus, the original inspectors were using more " judgement" in their inspections than today's Reinspection Team. This is due, in part, to our practice of now trying to apply the letter of the Code (AWS) rather than the intent. Based on this concern, we have prepared what we propose to use as acceptance criteria, with justification, for the reinspection of visual welding inspector's work. This data is shown by ATTACHMENT 1 to this correspondence. Please note that in this correspondence, we are not saying the proposed criteria is necessarily correct or incorrect, merely that this criteria was used in the original inspection. A - 65 4 218 W FECOSEVEL T AOAO # >*sLL S+DE. ILUNOS EiOW

  • 1341 d49-S050 SERVING WORLOWsOS THROUGH F4FTV P ACtL4TeSS
         '     . fir. R.P. Tuetken .

i i

  • Asst. Construction Superintendent COMMONWEALTH EDIS0N COMPANY
                       ' Byron Station July 11, 1983 Page                          Please review the proposed criteria, and advise of acceptability.

If ycu have any questions, please do not hesitate to contact me. Very truly yours,

                                                                         ~

PITTSBURGH TESTING LABORATORY Y??A M.R. Tallent, Jr. Site Manager Byron Station dlh Attachment s l O A -lb - m __m , _ , , . . ._ y 9

ATTACHf1ENT 1 PROPOSED ACCEPTANCE CRITERIA FOR VWI REINSPECTION 10 A weld subject bt visual inspection shall be acceptable if visual inspection shows that:

1) The weld has no cracks.
2) Thorough fusion exists between weld metal and base metal.
3) All craters are filled to the full cross section of the welds.
4) Weld profiles shall be in accordance with the following:

A) Undercut shall not exceed 1/32" in depth. Justification: The 0.01" criteria shown by AWS for certain conditions is dependant upon knowing various design stresses. Our inspectors would have no knowledge of these stresses. B) Welds shall be free from overlap. Definition of overlap: Overlap shall be considered as "the protrusion of weld metal beyond the bond at the toe of the weld" (This is to say that overlap exists when unfused weld metal lays on the base metal at the toe of the weld). Justification: This is standard industry practice and we believe the wording / diagrams / photographs contained in the following documents support this conclusion:

1) " Welding Inspection" '(Published by AWS)
2) ASME Section VIII, Division 1, Appendix III, Titled " Definitions"
3) AWS A3.0-80 Figures 27C and 270 C) Insufficient throat shall be cause for rejection on we1ds other than fillet welds, and shall be evaluated based on item 6 below for fillet welds.
5) The sum of diameters of piping porosity shall not exceed 3/8" in any linear inch of weld and shall not exceed 3/4 in any 12" length of weld.
6) Fillet welds in any single continuous weld shall be permitted to underrun the nominal fillet size required by 1/16" without correction provided that the undersize weld does not exceed 10% of the length of the weld. On web-to-flange welds on girders no underrun is permitted at the ends for a length equal to twice the width of the flange. .

Sk Q b W wY d.,L d6 M Y^' pra xee m A-I1 q//%d vri.7/s-

Fnom. PITTSBURGH TESTING LABORATORY Byr:n St; tion a TELE ONE I' . P.O. B:n 416

      ..    .      Byr:c, IL 61010
IEu tag m AME 8 O AS SOON AS ABLE M.R. Tallent. Jr. CH- 50 o uOr neceSSAny By Date i

SusJECTs

                                                        .                   Torque Insoection of CEA's To:
  • 9k
  • R.B. Klingler p \p f ,

p 3 oATe sear July 6. 1983 DATE RECEf VED:

                                                          \                   DATED ACTED UPON:

( V Q\ e f

  • DATE RETURNED:
                                                    ,       +_

roto WeproposetocategorizeCEAtorqueinspect[o as a non-reproduceable item based on the following: The torque value in a CEA decreases over a period of time, thus making the original inspection for this attribu e non-reproduceable. Please advise as to your acceptance of this pr posal. l d1h 3,an,o Sje, %

                                                                                                      ~

N \& yl @ N v sY & h , of# *f 7 9)3 f ,$ f fg-SIGNED RECIPIENT a_ -- b

                                        ~

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                .        9*                                             *
           ,                                             SARGENT,& LUNDY                                 gg       ,

Ewomszus FOUNDED 8898 S. , SS EAST MONROE STREET CHICAGO, ILLINOIS 60603 ' (3 23 269 2000

                                                           +'       TW X 910 - 2 21 - 2 0 0 7                                      .
           ' ~

July 28, 1983 . Project No. 4391/4392 File Nos. 1.1/5.27 ,.c e Commonwealth Edison Company Byron Station - Units 1 & 2 Re-Inspection Criteria for Concrete Expansion Anchors l l

                  /             Mr. R. Tuetken Commonwealth Edison Company Project Construction
             <                  Byron Station Byron, Il 61010

Dear Mr. Tuetken:

We have reviewed Mr. R. Byers request regarding re-inspection of concrete expansion anchors. We were requested to provide the re-inspection torque for expansion anchors installed as long as 5 years ago. Our test data to establish a re-inspection torque is limited to tests measuring anchor relaxation up to 500 days. Variables .j,. - that exist in the actual installation that were not considered t' in the test program include: 5-

a. The effect of concrete creep in relation to the compres ' h" sive strength of concrete. * ,
                                                                                                                            . ,E,1
b. The~effect of loading applied to the expansion anchor due to a support attachment to the plate. .

1 It is our understanding that the purpose of this re-inspection  ; M program is to show that previous QC inspections were performed adequately. Establishing a re-inspection torque value from the limited test data available will not answer if the original in-spection was adequately performed. However, if original installa-tion,was being questioned, then retorquing the anchor to the , original installation torque would be recommended. , l l 9 L a ._ s ~, _

i

                                                                                       .                                                                                 \
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                  *                                           ,                  ,                       ,                                                               I
      ..,,                                                                             SARGENT &' LUNDY.                                                                 <

t 8 , e' . . EN G I N E E R S l

    .U,,.-#                                                                                      CHICAGO i
                                  ' Commonwealth Edison Company                             -
                                                                                                     " July 28, 1983
                  -;.             .Mr. R. Tuetken                                                     Page 2
                                                        ' ' Y. .' t *
                                                 ." .'r
                                                                   ;.u...>,                                     -

If you have any questions,on this information, please do not hesi-

      , ,                           tate to call us.
                                            .             . .                                         Your      er   tJu y, R. . Net 1                                      -

Se ior S uctural Project Engineer RJN:kg

                            ,      Copies:
                                  .G. Sorensen                                                                                                              -

R. Cosaro f M. A. Stanish R. E. Querio

      ' !                         'D. L. Leone /W. C. Cleff                                                                                                   '

l B. G. Treece

      ./                           R. Hooks /D. C. Patel T. J. Ryan/G. Willman O
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j l Hatfield Electric Company Byron Units 1 & 2 g' p QA/QC Memorandum //959 (5i h l TO: R. Klingler, CECO A . FROM: J.T. Hill, QA/QC Manager DATE: August 29, 1983

SUBJECT:

Tolerances for "As-Built" Reinspections 0

         '.t the present time we are using a tolerance of       1" for location measurements on the "As-Built" reinspection program. However, the original "As-Built" program had no tolerances specified.. The         6" field installation tolerance was the only criteria specified on any drawing. Per J. I:elnosky, S 6 L, all "As-Built" information received used the 6" tolerance as a basis for any required calculations on hangers. Can we therefore use t 6" as acceptance criteria for field measurements?

JTH/k1h g f, cc: File 9.07 h 0212C

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REPLY O IN WRITING FROM: PITTSCURGH TESTING LABORATORY ~ - O BY TELEPHONE Byron Station (815) 234-5095 P.O. Box 416 O IMME DI AT E LY

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O O AS SOON AS ABLE M.R. Tallent, Jr. CH-3850 C NOT NECESSARY BY Date

SUBJECT:

J 0? Rninenoction TO:

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DATE $dNT: R. Klingler p(([ 'l ,

                                                                    ,    Y     ,'   ,[       8/31/83 DATE RECEIVED:
                                                               ,'       (     )             DATED ACTED UPON:
                                                                                ,$1
  • DATE RETURNED:

FOt.D Problems with traceability on certain Peabody reports make it impossible to determine the specific welds inspected initially. Based on this data, we request your concurrance to classify these cases as inaccessable. Reports of this nature comprise approximately 80% of the Peabody VWI activities. NOTE: This memo is to supercede the previous memo on this subject dated 8/16/83. l dlh sicsso 44M Cflo PCD wa"% r d ~ k g n A f yw W p gd weA6 FOL O e SIGNE D _ u -

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e HUNTER CORPORATION 3800- 179TH STREET, HAMMOND, INDIANA 46323 (219)845-8000 (312) 731-8000 I

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September 15, 1983 Commonwealth Edison Company h 4450 North German Church Road Byron, Illinois 61010 i /\ Attention: Mr. R. Tuetken b Assistant Superintendent Project Construction Dept.

Subject:

NRC Reinspection Program, Piping System Bolt Torque Relaxation. Mr. Tuetken: In your opinion does the attribute of piping system bolt torque (as it applies to the NRC Reinspection Program) fall within the definition of inaccessible? Yours very truly, (.l fe, LEE E. HADICK Quality Control Supervisor G Yes @ No G. Mb , date y I s7 3

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SAnornT Se LUIVDY l E'NGINEERS b l FOUNDED 1890 1 55 EAST MONROE STREET [ CHICAGO ILLINOIS 60603 - , (312) 269-2000 September 14, 1983

       ;.,                                                                               Project Nos. 4391/4392-00       ,
                        'q
                                  '.' Commonwealth Edison Company
       .cf                             Byron Station - Units 1 & 2                                                                                       i
                                       ' Flange Bolt Torque Relaxation
                         ,                                                                                                           3.          1
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           , :<                        Mr. G. Sorensen
              ,3 Commonwealth Edison Company                                                               ,               l Byron Station .
           -/       ,

P. O. Box B - Byron, Illinois 61010

Dear Mr. Sorensen:

At the request of Mr. R. P. Tuetken, we have reviewed the subject of flange bolt torque relaxation and determined that all flange bolts will experience some degree of torque relaxation. The two mechanisms responsible for bolt torque relaxation are flange bolt relaxation and flange gasket creep and relaxation. Flange bolt relaxation normally results from piping system opera- 3 . tion (pressure and temperature effects) and operating transients. 42

        ,                              Flange gasket creep and relaxation normally occur immediately following flange bolt torquing. Flange gasket relaxation may also                          ,,

result from plant construction activities and system start-up , testing. Evenit is understood, though thepossible is not phenomena of flange predict to accurately bolt torque the relaxation level [f.,' N" of total bolt torque relaxation. . .~/. 3 In summary, fla'nge bolt torque values will relax over time. This '. , will result in lower final bolt torque values than initially applied. If you have any additional questions on this subject, please call me. Yours very truly,

                                                                                             /414M           iM Dennis Demoss     ~

Mechanical Engineer - DD:cl ' Copies: J. T. Westermeier D. L. Leone /W. C. Cleff R. Cosaro B. G. Treece M. Lohmann R. J. Netzel R. P. Tuetken gg D. A. Gallagher ,

                                                                                                                                           .a'.

Hatfield Electric Company Byron Units 1 & 2 Sy? QA/QC Memorandum //980 TO: R. Klingler, CECO t

                                                                              //#f(/           A FROM:      J.T. Hill, QA/QC Manager
                                                                                               ]

DATE: September 19, 1983

SUBJECT:

N.R.C. Reinspection Program gr During the years 1980 and 1981 many verbal approvals for changes to installation drawings were given by on-site S & L Engineers with paperwork to follow. In some capqs these changes did not get incorporated on the applicable drawingsW As a result we are experiencing some rejections in the reinspection program because the drawings do not reflect the installations as production was instructed to install them. I do not believe the inspectors should be penalized with rejections because of this. Please advise. M e_ concar, 1 *- e- C 8*5 "

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N SCO NUCLEAR INSTALLATION SERVICES COMPANY

                                        . . . .       , . . . ~ . . .

P.O. BOX 752 , BYRON, ILL. 61010 TELEPHONE (815) 234-5240 September 19, 1983 , 3004-BYC-264 J Commonwealth Edison Co h i Project Construction , M PO Box B Byron, IL 61010 g[ } kh sU 9 Attention: R. Klingler {hsh During the QA verification of the Reinspection Program, Pittsburgh Testing identified (4) four full penetration welds which had only been welded partially penetrated. This incident immediatly made the original inspections of T.J.Pruitt and R.Shultz suspect. I am submitting the following information to clarify this situation. The Process Control Sheets which were used for the original inspections called for a Hold Point and QC Inspection of fitup to be done according to Drawing S-844. The final weld was to be Visual Inspected per NISCO's ES-100-5 prior to PT Inspection. The Process Control Sheet step (5.0) five which called for "QC Perform Visual Inspection of Finished Weld" was applied to inspect the front surface condition of the weld for size, undercut, underfill, over-fill, weld / profile and obvious cracks, prior to PT Inspec-tion. In this case both the original inspectors and the reinspectors performed the same inspections and found the same acceptable results. Pittsburgh Testing while performing their QA verification found a deficiency with the back surface of these welds. The deficiency is a result of the clarity of the Process Control Sheet and should not be a reflection on the insp-ectors ability. *

e. m$,d / e_ sac e Sincerely, k ue.I e 4 L 7 ./,. i t L l a. h(* **a*j m\ ,, o7 re. 3
                                                                                                                                      ,n     d, Q             <                                              ,=,       h N .J.+               Yr*=a l,                   .o n~                                            :   e 3.e% ,

sn>}c P.E. Deeds, Jr. Asst. Corp. QA Manager

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imumminim e - HUNTER CORPORATION 3800 179TH STREET, HAMMOND. INDIANA 46323.(219) 845-8000., HC-QA-485

                                                                                                  'Q 6    L                       l December 15, 1983 sz- \6-83 Commonwealth Edison Company                                                                  (

4450 North German Church Road Byron, Illinois 61010 Attention: Project Construction Department R.P. Tuetken Assistant Project Superintendent Subj ect : Interpretation for NRC Reinspection Mr. fuetken: The Hunter Corporation requests the following interpretation. Interpretation No. 1: Is it acceptable to use 2.3.2 and 2.3.2.1 from AWS D1.1-82 for the inspection of fillet wolds? Interpretation No. 2: Attachments 2, 3, and 4 indicate the accuracy of the welding gages we use for the measurement of fillet size. As you can see the best they can offer is

                                                      .025". Telephone conversation with Goodwin Lycan, President of the GAL Gage Co. indicated that there are no commercially manufactured gages that are more accurate than his. Comparison of his fillet gages against like gages manufactured by Fibre Metal have shown differences of up to .050". Therefore, using similiar gages will it be acceptable to find any fillet weld up to .025" undersize acceptable under the NRC reinspection program?
                                                                                            ~

Yours very truly g \y} - L L [, M ,;., t it b d1I b 6./h A d /, mia y 3e h\\) 5 b \.\

2. u .t g g g s:o ae es R.3.2 LEE E. HADLCK Quality Control Supervisor Lb Mid 2 w\ina r e s vi k cc: M.L. Somsag RA\i wu ,;% 6 J c, ., /AcJs 3 K. Selman .
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CHICAGO. ILLth0IS H A vvo.ND INDIA 4A YOUN3STCWN CHIO

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ME/ AWS b. l- N 6 4 /DEslGN OF WELDED CONNECUoNs . TTV\c H M e T l (1) having an included angle of 60 deg or greater at nominal area of the hole or slot in the plane of the faying the root of the groove when deposited by any of the surface. following welding processes: shielded metal arc. sub-merged arc. gas metal arc. flux cored arc. or electrogas 2.3.4 The effective throat of a combination partial joint welding; or penet, tion groove weld and a fillet weld shall be the (2) having an included angle not less than 45 deg at shortest distance from the root to the face of the diagram-the root of the groove when deposited in Dat or hortzontal matic weld minus 1/8 in. (3.2 mm) for any groove detail positions by gas metal arc or Gux cored arc welding. requiring such deduction (see Appendix A). 2.3.1.4 The effective throat thickness for flare groose welds when filled Bush to the surface of the solid section of the bar shall be as show n in Table 2.3.14. (1) Random sections of production welds for each welding procedure, or such test sections as may be re. quired by the Engineer, shall be used to verify that the

 ;                 effective throat is consistently obtained.

(2) For a given set of procedural conditions, if the contractor has demonstrated that he can consistently pro-vide larger effective throats than those shown in Table 2.3.1.4. the contractor may establish such larger effective PartB throats by qualification. StructuralOctallS J (3) Qualification required by (2) shall consist of h sectioning the radiused member. normal to its axis, at J midlength and terminal ends of the weld. Such sectioning 2.4 Fillers shall be made on a number of combinations of material sizes representative of the range used by the contractor in 2.4.1 Fillers may be used in construction or as required by the Engineer. 2.4.1.1 Splicing parts of different thicknesses. 2.3.1.5 The minimum effective throat of a partialjoint 2.4.1.2 Connections that. due to existing geometric penetration groove weld shall be as specified in Table alignment. must accommodate offsets to permit simple 2.10.3. framing. 2.3.2 Fillet Welds. The effective area shall be the effec- 2.4.2 A filler less than 1/4 in. (6.4 mm) thick shall not be

   ,               tive weld length multiplied by the effective throat. Stress used to transfer stress but shall be kept flush with the in a fillet weld shall be considered as applied to this          welded edges of the stress-carrying part. The sizes of
   -I              effective area. for any di.rection of applied load.              welds along such edges shall be increased over the re-l                2.3.2.1 The effective length of a fillet weld shall be the quired sizes by an amount equal to the thickness of the overalllength of the full-size fillet, including end returns. filler (see Fig. 2.4.2).

No reduction in effective length shall be made for either the start or crater of the weld if the weld is full size 2.4.3 Any filler 1/4 in. (6.4 mm) or more in thickness throuchout its length. ~ shall extend beyond the edges of the splice plate or con-l 2.i.2.2 The effective lencth of a curved fillet weld shall nection material. It shall be welded to the part on which it be measured along the center line of the effective throat. is fitted, and the joint shall be of sufficient strength to if the weld area of a fillet weld in a hole or slot computed transmit the splice plate or connection material stress from this length is greater than the area found from 2.3.3. applied at the surface of the filler as an eccentric load. then this latter area shall be used as the effective area of The welds joining the splice plate or connection material the fillet weld, to the filler shall be sufficient to transmit the splice plate 2.3.2.3 The minimum effectise lencth of a fillet weld or connection material stress and shall be long enough to i shall be at least four times the nominal' size. or the size of avoid overstressing the filler along the toe of the weld (see the weld shall be considered not to exceed one fourth its Fig. 2.4.3).

   -E              effective length.

2.3.2.4 The effective throat shall be the shortest dis-tance from the root of the face of the diagrammatic weld. See Appendix A. Note: See Appenda B for formula 2.5 PartialJoint Penetration Groove l gggg3 l governing the calculation of effective throats for fillet . l I welds in skewed T. joints. A comenient tabulation of l measured legs (W ) and acceptable gaps tGi related t Partial joint penetration groove welds subject to tension I ef fectise throats t El has been provided for dihedral angles normal to their longitudinal axis shall not be used where between 60 deg and 135 deg. desien criteria indicate cyclic loadine could produce fa-t gue failure. Joints containing such' welds made from

   )               2.3.3 Plug and Slot Welds. The effective area shall be the       one side only, shall be restrained to prevent rotation.

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                                                                                       ,6TTAc tAMt oT 2 G.A.L. Gage Co.                                    .        1.

Post Office Box 23 Idv W>M * ^ 2953 Hinchman Road d Stevensville, Michigan 49127 f 3 616 465 5750 November 23, 1982 Mr. Lee Hadick c/o Hunter Corp. P. O. Box 674 Byran, IL 61010

Subject:

72 Partial Sets Fillet Weld Gage P. O. #265003

Dear Mr. Hadick,

The manufactures tolerance of the Fillet Weld Gage on your P. O. #265003 are within the .025+ range. The welding gage is intended for general dimensional inspection of welded fabricaticn where close tolerances are not ecpected. It should not be compared in precision with gages where a high degree of accuracy is required. Sincerely, G.A.L. Gage Co. 1 M,1<-

  • c< b c,;f./ v t/

Goodwin A. Lycan President GAL /jkh ( 1 m-MANUFACTURERS AN INDISPENSIBLE l OF THE "Hi-LO" TOOL FOR FIT UPS WELDERS GAGE AND RADIOGkAPHED WELDS. A-3l

w i f I L% . G.A.L. Adjustable Fillet Weld Gage g 4-) MEASURE ANY F LLETWELD T01 n" ACCURACY A- W TH JUST ONE S MPLE-TO-USE GAGE.

            ~

g Measuring fillet welds used to be a trial The G. A L. Adjustable Fillet Weld Gage 32nds, with metric equivalents given. so you pointer in position for future reference. lf the L with complicated or inaccurate gages. Not uses an offset arm which sides at a 45* angle get more accurate readings. Four screws hold weld is concave, more filler material can be

!     g g          anymore. Now you can measure fillet welds                                           to make fJlet weld length measurements.                          the offset arm in position for future           added to build the we'd throat up to standard.

9 from %"to 1* (with hf accuracy)with Simply adjust the arm until it touches the toe adjustments. The G A L. Adjustable Fillet Weld Gage is

! '     -          one economical, simple-to-understand gage.                                          of the vertical leg. The gage is calibrated to                      This gage also measures weld throat          made of durable, rust resistant stainless steel, thicknesses to        its 2W" x 3 slim design weighs only in oz.,

G.A.L. Adjustable Fillet Weld Gage is easy to use.pointer M'1"'"unti it "Sn'?" W a=r measurements, t e chance of losing essential i touches the center fillet weld gage blades is eliminated. Fumbling .. 25 et o00 - 25 c1 - of the weld. A thumb through seven different, inaccurate gage ' 2s m 000 _, screw holds the bladesis also eliminated. 3 53- 9 53 3

                                                                                                                                                                              " ^* **                                                                                  .

E Made m U s A. ,..t.. _ v- y Read the weld size indicated. The To measure fillet welds placeirregular curve Adjust the offset arm uf or down along

                  $r$g          e sin ne wit e$or o tal                                                 e t$e op itheYeld                        fo .$1Yourner$5a               eE$edt$ tot $e I                  member.                                                                                                                        surface and filled for easier reading.                     ..
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Q T CJ\ k :k ' U.S. patents pending. I Gages tvailable through your welding supply 4

                                                                                                                                                                                                                                                   /

I distributor, or contact: m, / /, G. A.L. Re"v"m'im':::wn br="as:::" :,"1 G.A.L. y~  % e,dca, m m u t~ r"m:en':a::,1n,,, :nt=" e' maw::"" it touches the face of the weld, them with additional filler material to meet Gaae Co* sg

                                                                                                                                                                                                                                              '""%'a*='

standards. P.O. Box 23, Stevensville, Michigan 49127 Telephone 616/465-5750 TELEX 729453 GAL GAGE STVL C1983.S.A L Sage Co. G 8

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WELDING GAUGE IMPORTANT NOTICE The Welding Gauge is intended for ge: eral dimensional inspection of welded fabrications where close tolerances are not expected, it should not be compared in precision with gauges used for measuring machined components and, where a high degree of accuracy is required, machine shop type measuring instruments will need to be used. The Welding Institute Abington Hall Cambridge CB16AL 01/80 s L l t l A ~sa

h I Hatfield Electric Company

                                                                      , 9@)/}-l                  -

Byron Units 1 & 2 ,$ QA/QC Memorandum #1135 ' TO: Bob Klingler FROM: J.D. Spangler DATE: January 25, 1984

SUBJECT:

NRC Reinspection , In HEco's Procedure 13AE, Rev. O, Issue I, dated 2-8-79, which is used in the reinspection of Peter Lane. Paragraph 5.2 states that deviations from the requirements of the welding procedure will constitute unacceptability. In the welding Procedure 13AA, Rev. O, Issue I, dated 6-1-78, paragraph 5.8.5, states that cracks or blemish cause by arch strikes should be ground to a smooth Contour. Could you please interpret the acceptance criteria and corrective action for arch strikes. W y J ob , t0 , dl $0 { ht);ne R&w /-f]S- ((f

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HATFIELD ELECTRIC COMPANY 9 iM,

                                                                                       \f   l UNITS 1 & 2                                     h QA/QC Memorandum #1148                         ff l

TO: Bob Klingler FROM: Daryl L. Heider DATE: February 2, 1984 It has been brought to my attention that welds are being re-jected for overwelding. Situations noted are:

1. Where a continuous weld has been made in place of stich welds.
2. Weld lengths in excess of detail requirements.

Also these situations do not have any visual distortion. Could you please interpret the acceptance criteria and correct-ive action for overwelding.

                                                            />tarf         s Daryl [ ileifier DLH/klh                    '

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QA/QC Memorandum #1170 ' ' c' f TO: R. Tueken/R. Klingler, CECO y?/d i FROM: J.T. Hill, QA Supervisor d DATE: February 18, 1984

SUBJECT:

Tolerances on HP-9A-1 Supplement Sheets I am inquiring as to what tolerances are allowed when grading HP-9A-1 Supplement Sheets (Cable Pan Hangers) used for the NRC Reinspection Program. Measuring inspected. criteria has changed since hangers in question were originally

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I 6 0 0 a TUETKEN ATTACHMENT B 1 D 1 l l l l I

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1 Tuetken Attachment B Page 1 of 13 HATFIELD ELECTRIC Attribute Inspection Summary 4 Procedure Inspection Type Reinspection Condition Why Inaccessible /Not Recreatable

                #2         ' Embedded Conduit           Inaccessible             Encased in concrete 83           Underground Duct Runs      Inaccessible             Encased in concrete, buried
                #5           Material & Equipment     .Not Recreatable           Physical condition changed by subsequent
          .                      Receiving                                       activities 49A '       Cable. Pan llangers        REINSPECTED
                $98         Cable Pans                 REINSTTCTED
                $9C        -Cable Pan Covers           Re f r.spectable, Dut     No Inspector Captured in Sample
  • No Inspections Captured
               #9E          Cab 1N Pan                 Reinspectable, But        No Inspector Captured in Sample
  • Identification No Inspections Captured
               #10          Cable Installation         Not Recreatable           Pulling tension in-process event; initial
                                                        & Inaccessible           raceway condition covered by cables; cables buried amongst others, to trace required disassembly to use signal generator til          Cat >1; Terminations       REINSPECTED
               #12          Equipment Installation     REINSPECTED
             . 812A        Equipment Modifications     REINSP':CTED c
               $12D        Non-Seg Bus Duct'           Inaccessible &           Requires disassembly to access Not Recreatable
              #13AE'       Visual Weld Inspection      REINSPECTED

! #14 Material llandling Not Recreatable Inspections performed in process

         'No inspectors being reinspected performed this type of inspection during the first three months of work.                                    9 i                   L

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1 Tuetken Attachment B Page 2 of 13 UATFIE!.D ELEC'IAIC Attribute Inspeccion Summary Procedure Inspection Type Reinspecticn Condition hhy Inaccessible /Not Recreatable

     #20       Expcsed Cenduit            FEINSFECTED
     #25       A325 Bolt Installation     REINSPECTED 826       Stud Welding               Inaccessible                Pequires disassembly to access: Bending adequate by Visual and Load Test
     $27       Limit Switch Gasket        Not Recreatable            Affected switches subsequently replaced Feplacement
     $28       Peceval of Heat            Not Recreatable             Inspecticns performed in process Shrink Tubing On Conar Penetrations
     #30       Housekeeping               Not Recreatable            Ongoing activities change conditions N/A       C-.duit As Built           REINSPECTED i      .

i i ' Tuetken Attachment B Page 3 of 13 IIUNTER CORPORATION Attribute Inspection Summary Attribute Reinspection . Classification Inspection Type Condition Why Inaccessible /Not Recreatable (1) Visual Weld Piping - Visual REINSPECTED Weld Inspection (1) Visual Weld Whip Restraint - REINSPECTED Visual Weld Inspection (1) Visual Weld Component Support - REINSPECTED Visual Weld Inspection

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Tuetken Attachment D Page 4 of 13

                                             !!UNTER CORPORATION Attribute Inspection Summary Attribute                                  Reinspection Classification      Inspection Type             Condition         Why Inaccessible /Not Recreatable (2) Docur.entation  Piping - Mech. Jt.       REINSPECTED Documentation (2) Documentation   Ferrite Inspection       Not Recreatable      Inspector of record change because of Documentation                                re-review (2) Docurentation   !!ydrostatic Test        REINSPECTED Documentation (2) Documentation   Weld Interpass Temp.      REINSPECTED Documentation (2) Documentation   Joules Test               Not Recreatable     Inspector of record change because of Documentation                                 re-review (2) Documentation   Code Name Plate           Not Recreatable     Inspector of record change because of Change Documentation                          re-review (2) Documentation   Documentation of         Not Recreatable      Inspector of record change because of Weld Defect Removal                           re-review Cavity 1

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b a Tuetken Attachment B Page.5 of I3 HUNTER CORPORATION Attribute Inspection Summary Attribute Reinspection Classi ficat ion - Inspection Type Condition Why Inaccessible /Not Recreatable

                -(2) Documentation      Piping - Weld              REINSPECTED Documentation
                                             ~

(2) Documentation Whip Restraint - REINSPECTED Weld Documentation (2) Documentation Component Support - REINSPECTED Weld Documentation (?) Documentation. Piping - Component REINSPECTED Inspection Documentation e (2) Documentation; Whip Restraint -' REINSPECTED Component Inspection Documentation (2) Documentation Piping - Fitup REINSPECTED Documentation (2) Documentation, Whip Restraint - REINSPECTED Fitup Documentation

               - (2) Documentation      Piping - Bend.             REINSPECTED
                                      . Documentation (2) Documentation' Component Support        ' REINSPECTED Inspection --

Documentation. (2) Documentation _ Dimon'slonal Location REINSPECTED of Field Welds 9 il L h __e- _ -,

o l Tuetken Attachrent B Page 6 of 13

                                                  !!UNTER CCEPORATION Attribute Inspection Summary
      \ttribute                                   Reinspection Classification      Inspection Type               Cnndition        Why Inaccessible /Not Recreatable (2) Documentation   Buried Pipe Covering       REINSPECTED Inspection -

Docur.entation (2) Documentation Concrete Expansion REINSPECTED Anchor - Documentation (2) Documentation Piping - Pre-Heat REIt:SPECTED Insp. Documentation (2) Documentation Whip Restraint - REINSPECTED Pre-Heat Inspection Documentaticn (2) Documentation Pipe Weld - Shield REINSPECTED Cas Documentation (2) Documentation Component Support - Not Recreatatle Inspector of record change because of Snubber Stroking re-review Documentation l l (2) Documentation Piping & Component REINSPECTED Support, Terporary Attachments Documentation (2) Documentation Dolting - Turn-of-Nut Not Recreatable Inspector of record change because of Documentation re-review I =

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                                                                                                                                      .Tuetken Attachment B Page 7 of 13
                                                                                        - IIUNTER CORPORATION Attribute Inspection Summary l                                           . Attribute                                    Reinspection Classification        Inspection Type               Condition          Why Inaccessible /Not Recreatable a

(2) Documentation . Piping - Small Bore REINSPECTED Final Inspection (Type 3) Documentation (2) Documentation ~ Piping - Small Dore REINSPECTED 3 Final Inspection (Type 4) Documentataon (2) Documentation Whip Restraint - REINSPECTED Final Inspection (Type 3) Documentation (2) Documentation Whip Restraint - REINSPECTED r Final' Inspection

  • i (Type 4) Documentation (2) Documentation Piping - Large Bore REINSPECTED Final Inspection '

(Type 3) Documentation (2) Documentation Component Support - Re i nspecta bl e, But No Inspector captured in samp1t" Final Inspection . No Inspections (Type 3) Documentation Captured , (2) Documentation- Component Support - Reinspectable, But No Inspector captured in sample

  • Final Inspection No Inspections (Type 4) Documentation Captured i

(2) Documentation Equipment Installation- REINSPECTED Final Inspection

                                                             .(Type 3) Documentation
                                        'No inspectors being reinspected performed this type of inspection during the first three months of work.                        1 k

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i, Tuetken Attachment B Page 8 of 13

                                                                !!UNTER CORPORATION Attribute Inspection Summary Attribute                                 Reinspection Classification       Inspection Type-             Condition        Why inaccessible /Not Recreatable (3) Hardware       Piping - Mech. Jt.         REINSPECTED Torque

_( 3) Hardware Visual Inspection Inaccessible Requires disassembly to access of Valves (3) Hardware. . Ferrite Inspection Inaccessible' Inspections performed in process k- (3) Hardware. Piping Hydrostatic Not Recreatable Inspections performed in process sTest l (3) Hardware Piping Weld Interpass Not Recreatable Inspections performed in process Temperature Inspection . (3) liardware Joules Test Not Recreatable Inspections performed in 'rocess Inspection

               .(3) Itardware        Code Name Plate           Not Recreatable      Inspections performed in process                            l 1

Change-(3) liardware' Inspection of Weld Not Recreatable Cavities refilled Defect Removal Cavity

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              . ( 3) ' !!ardware _   Piping.- Component-       REINSPECTED-Inspection 4
              - (3) !!a rdware . Whip Restraint -           REINSPECTED

[ ' Component Inspection

,               (3)'llardware      -Piping - Fitup &           REINSPECTED          Inspections performed in process 4

Tack Weld. -(Limited Amount) t

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3 4 1 .. t L Tuetken Attachment B Page 9 of 13 HUNTER CORPORATION Attribute Inspection Summary

       ' Attribute                                   Reinspection Classification   Inspection Type                  condition        Why Inaccessible /Not Recreatable
     .(3)-Hardware     Whip Restraint -              Not Recreatable     Inspections performed in process
                      .Fitup & Tack Weld (3) Hardware. Piping - Bends                REINSPECTED (3) Hardware     Component Support             REINSPECTED Inspection (3) Hardware     Dimensional Location          REINSPECTED of Field Welds (3) Hardware     Corponent Support             REINSPECTED Torque (3l Hardware      Buried Pipe Covering          Inaccessible       Encased in concrete, buried Incpection (3) liardware     Concrete Expansion            REINSPECTED Anchor Inspection (3) Hardware      Piping - Pre-IIcat            Not Recreatable    Inspections performed in process Inspection.

(3) Hardware- Whip Restraint - Not Recreatable Inspections performed in pracess Pre-tiea t ' Ins pect ion (3) Hardware Pipe Weld - Shield. Not Recreatable Inspections performed in process Cas Verification (3) flardware . Component Support - Inaccessible Requires disassembly to access

                     - Snubber Stroking 9

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                         . - .              - - - - , - - . - ~ - . . .             .-    - - . - - - . . - - . .                      . _ . ~    . , - . , ~ , - . - . - - . - ~               -. .    .- , -     i     .    - . -
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w- e , N i~ , i Tuetken Attachment B. Page 10 of 13 , liUNTER CORPORATION Attribute-Inspection summary j Attribute Reinspection . Classification Inspection Type Condition Why Inaccessible /Not Recreatable

j. (3) Hardware piping & Component FEINSPECTED Support, Temporary Attachments (3) Ifardware Colting - Turn-of-Nut Ect Recreatable Inspections performed in process  ;

(3) tiardware Piping'- Small Bore . REINSPECTED Final Inspection-

                                                                         '(Type 3).

i . (3) !!ardware - Piping - Small Dore REINSPECTED Final Inspection ' (Type 4) (3) !!ardware Whip Restraint - REINSPECTED , Final Inspection ' (Type 3) i (3) Hardware Whip Restraint - REINSPECTED

Final Inspection' (Type 4) i (3) Hardware Piping - Large Bore REINSPECTED l' . Final Inspection I (Type 3)

(3) liardware Component Support - .- Reinspec table, But No Inspector captured in sample

  • Final Inspection No Inspections
                                                                         .( type 3)                                    Captured
                                     'No inspectors icirag reinspected performed this type of inspection during the first three months of work.

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f e 4 4 I b Tuetken Attachment B Page 11 of 13 tiUt:TER CORPORATION Attribute Inspection Sumn.ary Attribute Reinspection Classification Inspection Type Condition M.y Inaccessible /Not Recreatable (3) IIardware Component Support - Reinspectable. But  !;o Inspector captured in sample

  • Final Inspection  !!o Inspectiones (Type 4) Captured

( 3) liardware Equipment Installation No Inspections No Inspector captured in sample

  • Captured StJo inspectors 1.cing reinsg>ected performed this type of insticetion during the first three months of work.

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3 d t A P Tuetken Attachment B Page 12 of 13 PITTSBURGil TESTING LABOPATORY Attribute Inspection Surmary Attribute Reinspection Classification Inspection Type Condition Why Inaccessible /Not Recreatable CEA's - Blount Supports, Columns REINSPECTED CEA's - !!unter Piping, flangers CEA's - If a t field Conduit / Catie Pan !! angers CEA's - P-A-P Instrument Piping Hangers CEA's - RSM Ductwork llangers CEA's - JCI Instrument Piping I! angers Retar Detection - For Installation of Nct Recreatable Requires disassembly to access Blount CEA's l'unt e r I:at f ield P-A-P FSM JCI Colting - Connections Not Recreatable Inspections performed in process Turr-of-Nut - Blount Calibrations - Torque wrenches, Not Recreatable Change of conditions from initial state Blount Therrometers,

   !!u n t e r        Feeler Gauges, Ifatfield          Scales, Gauges P-A-P RSM JCI NISCo Midway 1

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e m d 1 i . Tuetken Attachment B Page 13 of 13 PITTSBURGli TESTI!;G LABORATORY Attribute Inspection Suneary I Attribute Reinspection Classification Inspection Type Condition W1.y I na cce s s i tsl e /t?ot Pecreatable Calwelds - Blount ReNar Coupling f;ot Recreatable Visual,?!easure, Record Data CC-CWI-l soils - Blount Cack Fill Not Recreatable Compaction, moisture content, density, CC-ST-1 Concrete Field - Placement Not Recreatable Mcnitor pour, sample, slump, air, unit Eleunt weight, mold specirens, temperature & sign off. CC-FSTC-1 Concrete Lab - Aggregate Not Fecreatable Sample, run C-29, C-40, C-117, C-123, Blount C-127, C-128, C-136, C-142, C-119, C-235 flonitor curling temps., Cap, Measure & Dreak Cutes. CC-LT-1 Visual Weld Weld Inspection REINSPECTED Insg>ect ion - Am. Dridge Mid-City Blount 9 is L t _ _ _ _ . __}}