ML20092P794
| ML20092P794 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/02/1984 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20092P775 | List: |
| References | |
| OL, NUDOCS 8407090381 | |
| Download: ML20092P794 (80) | |
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65 RELATED CC.EISPC;;DENCE COMMONWEALTH EDISON COMPANY Date: July 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Al -9 m b
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In The Matter Of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL
) 50-455-OL (Byron Nuclear Power Station, )
Units 1 & 2) )
SUMMARY
OF THE TESTIMONY OF LOUIS O. DEL GEORGE ON CONTENTION 1 (REINSPECTION PROGRAM - INSPECTOR OUALIFICATION AND WORK QUALITY)
I. Louis O. Del George .4s Commonwealth Edison Tompany's Assistant Vice President responsible for licensing and engineering activities within the Nuclear Opera-tions Division, including licensing activities for j~ the Byron Station. Mr. Del George managed the develop-ment of the Reinspection Program.
II. Mr. Del George describes the structure of the Reinspec-tion Program and discusses the results of the Program for Hatfield, Hunter, and PTL.
III. Mr. Del George explains that the Reinspection Program was developed to verify the effectiveness of inspector qualification and certification practices utilized by site contractors prior to September, 1982.
IV. Mr. Del George explains the four essential elements of the Reinspection Program.
A. Selection of Contractors - 8 of 19 contractors who performed safety-related work at Byron were subject to the Reinspection Program. These 8 contractors accounted for approximately 93% of the safety-related work. The other contractors were not included because they were subject to a different s'_andard, or they were undergoing a separate reinspection, or their work was neither accessible nor recreatable for purposes of rein-spection.
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.; l l B. Selection of Inspectors - All inspectors for two contractors were reinspected. An adequate sample of inspectors for the other six con-tractors was selected.
C. Selection of amounts of each inspector's work subject to reinspection - The first three months of each selected inspector's work was reinspected.
D. Establishment of Acceptance Criteria - For objective inspections, an agreement rate of l 95% was applied. For subjective inspections an agreement rate of 90% was applied.
V. Mr. Del George explains that the work performed by Hatfield, Hunter and PTL was categorized into discrete work activities called " attributes," which are com-prised of more basic " elements." All " accessible" and i
"recreatable" attributes (explained by Mr. Del George) of safety-related work for the inspectors three month period were reinspected. Some attributes were not inspected by any of the sampled inspectors for the three month period.
- VI. Mr. Del George explains that the attributes were further categorized " objective" (not significantly affected by qualitative interpretation) or " subjective" (require qualitative interpretation). Visual weld examinations were the only subjective attributes.
VII. Mr. Del George explains that acceptable items were defined as those for which the reinspector agreed with the condition on the original inspection record, using criteria that applied at the time of the original inspection.
VIII.Mr. Del George explains the basis of the 95% acceptance level for objective attributes and the 90% acceptance level for subjective attributes. All observed dis-crepancies were evaluated for design significance.
IX. Mr. Del George explains that if an inspector failed to i
meet the applicable acceptance criterion, the sample was expanded to focus specifically on areas where qualification was suspect. For Hatfield, Hunter, and PTL, no inspectors were found unqualified regarding objective attributes. For subjective attributes, the indeterminate qualifications of some of their inspec-tors, and the failure of one PTL inspector, led to sample expansion.
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X. Mr. Del George explains that the Reinspection Program results for Hatfield, Hunter, and PTL demonstrate that their procedures for qualification and certification of QC inspectors prior to September, 1982 were effective.
These results also show that all other contractors' inspectors certified in accordance with these same practices were also adequately qualified, based on the large data base and the fact that no discrepancies were found to have design significance.
XI. Mr. Del George explains why his conclusions are not affected by the fact that some attributes were inacces-sible or not recreatable.
XII. Mr. Del George explains how discrepancies found during the Reinspection Program were dispositioned. None were I
' found to have design significance. Discrepancies were evaluated to determine whether any_ trends existed which would warrant further review. Two trends were identif-ied, however, the trended discrepancies were found to be insignificant from a design standpoint.
XIII.Mr. Del George explains that the NRC Staff reviewed the results of the Feinspection Program and reached a con-clusion that the safety-related work done by the Byron contractors is of acceptable quality. Mr. Del George also discusses two recent NRC reports relating to Hatfield QC activities which identified two apparent items of non-compliance. Mr. Del George explains that these NRC reports do not affect his opinion regarding the effectiveness of Hatfield's QC inspector certifi-cation program.
XIV. Mr. Del George concludes that the quality of the work performed by Hatfield and Hunter is adequate and that there is reasonable assurance that the equipment and systems associated with this work will not compromise the safe operation of Byron Station. Mr. Del George explains that the basis for this opinion is based upon the results of the Reinspection Program and on the general effectiveness of programs implemented by CECO to assure the quality of construction activities.
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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 LOUIS O. DEL GEORGE Q.1. Please state your full name and place of employment.
A.l. My name is Louis Owen Del George. I am employed sy Commenuealth Edison Company in its Corporate Offices in Chicago, Illinois.
Q.2. Please describe your job responsibilities.
A.2. I am an Assistant Vice-President, responsible for Licensing and Engineering activities related to the
! nine operating nuclear reactors within Commonwealth Edison's Nuclear Operations Division. I am also responsible for Licensing activities related to the four nuclear reactors which Commonwealth Edison is currently constructing, including the two reactors at Byron Statien. In addition, the engineering organica-f tion that reports to me maintains fitnctional oversight of the engineering activities related to the reactor i
facilities under construction to provide for the uni-
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form application of Commonwea.th Edison's engineering procedures at both our operating nuclear plants and nuclear plants under construction.
Q.3. Please state your educational background and work experience.
A.3. I received a Bachelor of Science Degree in Engineering Science from the Illinois Institute of Technology in 1970. I also received a Juris Doctor degree from the Chicago Kent College of Law of the Illinois Institute of Technology in 1977. I began my professional career at the Bettis Atomic Power Laboratory in 1969 where I held various positions of increasing responsibility related to the design and fabrication of nuclear reac-tor-internals. While employed at the Laboratory, I was appointed tc the The Shock and Vibration Design Review Committee which assessed the adequacy of vibration design practices for all pressurized water reactor plants designed at the Laboratory, including the Shippingport facility. I also attended the Laboratory's Reactor Engineering School which provided graduate level instruction in the design of nuclear power systems.
In 1974, I joined Commonwealth Edison and have held e
positions of increasing responsibility in.the Station 2-
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Nuclear Engineering and Licensing Departments. In l
connection with my engineering experience, I managed numerous backfit projects related to the Dresden and Quad Cities Stations. These projects included struc-tural, mechanical and electrical design and construc-tion activities, and involved work governed by both the American Society of Mechanical Engineers (ASME) and American Welding Society (AWS) Codes.
In connection with my licensing experience, from 1978 to 1981 I managed all licensing activities related to the LaSalle County Station including development of the Company responses to all NRC questions concerning design and construction activities. In this regard, I participated in the development of corrective action programs some of which involved reinspection of work previously completed and included construction activi-ties governed by the ASME and AWS codes. This in-cludes a reinspection program for hanger welding performed in accordance with AWS Dl.1. by the LaSalle County heating, ventilating and air-cenditioning (HVAC) contractor, the sample reinspection of large and small bore piping supports and the reinspection of ASME bolting by the LaSalle County mechanical contrac-tor, the sample reinspection of cable routing and sep-aration by the electrical contractor, and a structural I
steel sample reinspection program which included visual inspection of welding performed in accordance with AWS Dl.l.
In 1982 I was appointed Director of Licensing at which time I assumed responsibility for all licensing activ-ities related to the Company's nuclear facilities both operating and under construction. In 1983 I assumed my present position of Assistant Vice-President, after acting for approximately one-year as staff assistant i
to my predecessor in this position. It was in this latter role as staff assistant to the Assistant Vice-President of Licensing and Engineering that I previ-ously gave testimony in this preceeding.
Q.4. Did you participate in the development of the Rein-spection Program at Byron Station concerning the quality of QC inspectors?
A.4. Yes.
Q.5. Please describe your respensibilities concerning the Reinspection Frogram.
A.S.
My responsibility as Director of Nuclear Licensing included the development of the Company's response to NRC Staff inspection findings. In 1982, acting in that capacity, I managed the development of a program l
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for verifying the effectiveness of contractor prac-tices for the qualification and certification of QC inspectors at the Byron site, hereafter referred to as the " Reinspection Program" or " Program". The affected Company departments were assembled under my direc-tion. The principal contributors to the Program definition were the Project Construction Department, which had overall responsibility for site contractor activities; the Quality Assurance Department which maintained oversight of site contractor activities and had insight on the standards affecting these practices and their application at the Byron site; and the Nuclear Licensing Department, which provided technical quidance on methods for resolving the findings based on experience gained in the resolution of similar 4
issuec involving reinspection of completed construc-tion work.
Q.6. What was the objective of the Reinspection Program?
A.6. The Reinspection Program undertaken at Byron was developed to verify the effectiveness of inspector qualification and certification practices utilized by site contractors prior to September, 1982. The Pro-gram examined, on a sampling basis, inspections per-formed by QC inspectors who were certified prior to September, 1982 under those practices. By demonstrat-I
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ing that the performance of previously certified inspectors could be reproduced at an appropriate acceptance rate through reinspections performed by inspectors whose qualification and certification met current standards, the qualification of inspectors previously certified under the former practices would be confirmed.
This objective is more easily understood when viewed agains'. the background which preceded the Program. A special NRC inspection was conducted at Byron during the Spring of 1982 by an NRC Construction Assessment Team (CAT). One of the findings of the team, pub-lished in IE Report Nos. 50-454/82-05 and 50-455/82-04, questioned the adequacy of the on-site contractors' programs for qualifying, and thereby certifying QC inspectors. Specifically, the NRC inspectors found deficiencies in (1) the contractors' evaluations of initial inspector capabilities, (2) the documentation of initial certification, and (3) the criteria used to establish inspecter qualification.
Although there was no finding that these deficiencies had compromised the quality of c:nstruction, the NRC adopted the position that the site contractors' QC inspector qualification programs had to be upgraded and that the quality of the inspections already com-pleted required verification.
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The purpose of the Reinspection Program ;as to vali-date former inspector certification practices under ANSI N45.2.6 (1978), and not to confirm the adequacy of construction quality generally. With validation of-certification practices the objective, the Reinspec-tion Program focused on demons ~. rating the repeatabil-ity of inspections previously performed, from which the effectiveness of qualification and certification practices could be directly demonstrated. However, the large volume of inspection data associated with the Program does produce a strong inference of the adequacy of construction quality at the site.
Q.7. What is the purpose of your testimony?
A.7. My testimony will describe the structure of the Rein-specticn Program, and will discuss the results of the Program for Hatfield Electric Company ("Hatfield"),
Hunter Corporation (" Hunter"), and Pittsburgh Testing Laboratory ("PTL").
Q.8. In general terms, identify the essential elements of the Reinspection Program.
A.8. The Reinspection Program consisted of four essential elements. These are: (1) Selection of Contractors, (2) Selection of Inspectors (3) Selection of Inspec-tors' Work, and (4) Establishment of Acceptance Cri-l teria.
Q.9. Were all the contractors who performed construction work at the Byron site subject to the Reinspection Program?
A.9. No. Eight of the 19 cont actors who had performed or were performing safety-related work at the Byron Station were subjected to reinspection. These site contractors were:
- a. Blount Brothers Corporation - responsible for most 1 structural work including concrete / masonry, installation of post tensioning tendons, miscel-laneous structural steel, and fireproofing.
b.
Johnson Controls Incorporated - responsible for installation of Heating, Ventilating, and Air-Conditioning HVAC controls and instrumentation including tubing, hangers and instrumentation, and instrument panel installation.
c.
Hunter Corporation - responsible for mechanical erection activities associated with equipment setting, piping, component supports, and pipe whip restraints.
- d. Nuclear Installation Services Company - responsi-ble for installation of the NSSS system. including control rod drive mechanisms reactor vessel set-l ting, r' tor coolant pump setting, and miscella-neour aandling equipment erection.
e.
Hatfield Electric Company - responsible for elec-trical work on site including embedded and exposed conduit and underground duct, cable pan installation including hangers, ladders and covers, as well as cable installation and termi-nation. This contractor was also responsible for installation of fire detection, fire protection and security systems.
f.
Powers-Acco-Pope - responsible for installation of small bore instrument piping and miscellaneous small bore (2" and under) systems.
g.
PTL - responsible for nondestruction testing of welds, concrete testing,, aggregate testing, con-crete expancien ancher testing, soils testing, calibration and structural steel bolting inspec-tion.
- h. Peabody Testing - responsible for same scope as PTL who succeeded Peabody in September, 1977.
The work inspected by these contractors amounted to approximately 93% of the safety-related work at the Byron Station.
(See Attachment A).
These contractors all certif'ed their QC inspectors using the guidance provided in ANSI N45.2.6. With 9_
I respect to the NRC questions concerning the adequacy ,
of inspections performed between the start of safety-related construction in 1976 and September, 1982, the program proposed for resolving the matter was devel-oped based primarily upon experience gained in the resolution of other NRC findings related to program-matic concerns where no construction defects had.been identified. In that regard, a-reinspection based on a focused sampling process was considered prudent because it allowed for the allocation of resources in a way that would most effectively uncover potential 3 discrepancies.
Of the 11 contractors excluded from the Program, three
. were excluded because they were not subject to ANSI N45.2.6 (1978) and, hence, the qualification of their QC inspectors was not in question. Three other con-tractors were already undergoing extensive reinspec-tion of their work, thereby rendering it unnecessary to address the question of their QC inspector qualifi-catien. The remaining five were excluded from the heinspection Frogram because their work was neither accessible nor recreatable for purposes of reinspec-tion. The procedures and practices for the qualifica-tion and certification of QC inspectors for these five
. contractors were established under the same guidelines
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as was the case for the eight contractors included in the Reinspection Program.
Q.10. How were the inspectors who were the subject of the Reinspection Program selected?
A.10. All QC inspectors for two contractors (Powers-Acco-Pope and Johnson Controls) were reinspected to the extent their work included reinspectable items. This was responsive to broad concerns raised in the CAT Inspection Report.
The work of the QC inspectors of the six remaining contractors was reinspected by a sampling technique.
To ensure a representative selection of inspectors from the total population, Commonwealth Edison com-piled rosters of the six contractors' QC inspectors.
The names of the inspectors were listed chronologi-cally by date of certification. The first inspector on each roster was selected and every fifth inspector thereafter was included in the Program. After the original sample populatior. was selected, the NRC Senior Resident Inspector (who had conducted the CAT review) reviewed the sample and added two to four names to each contractor's group of inspectors. For example, four names were added to the sample popula-tion for Hatfield,.three for Hunter, and three for PTL. This NRC input was solicited to assure that any inspector whose certification might in any way be held suspect by the NRC would be captured by the initial reinspection sample.
Q.11. Was the sampling plan used to select the QC inspectors for reinspection adequate to assure that this group was representative of the total population of inspec-tors?
A.11. The Reinspection Program sampling scheme as described here was not designed on a formal statistical basis.
Rather, it was a result of an engineering judgment that for small populations, a sampla size of about 20%
will provide a reliable indicator of the quality of the total population. In the Byron Reinspection Pro-gram, the selection of every fifth individual on a list chronologically ordered by initial certification date assures a wide ranging representation of inspec-tion activities over.the time period of the contrac-tor's participation in the plant's construction. The addition of inspectors identified by the NRC as sus-pect would result in conservative bias to the sample if those suspicions were justifiable.
As shown in the following table, the inspectors whoce work was reinspected span the entire period of inter-est from the start of safety-related construction to September, 1982.
Distribution of Inspectors Reinspected by Contrator by Year 1976 1977 1978 1979 1980 1981 1982* TOTAL 4
Blount Brothers 2/7 2/3 O/2 3/12 0/2 1/2 8/28 Johnson Controls 1/2 3/4 1/1 5/7 Hunter 1/2 2/6 1/6 2/7 4/19 9/31 3/13 22/84 NISCo 1/3 1/1 1/2 1/2 4/8 Hatfield .
Electric 1/3 2/4 1/1 2/5 15/60 2/13 23/86 Powers-Acco-Pope 2/2 5/5 9/10 3/4 19/21 Pittsburgh Testing 6/34 6/16 3/18 2/5 3/7 3/5 23/85 Peabody Testing 1/23 5/14 6/37 TOTAL 4/32 16/60 10/31 11/40 15/37 40/116 14/40 110/356
- to September 1982 Note: In the above table, the numbers shown as x/y incicate the number of inspectors reinspected versus the total number of inspectors certified.
Eased on the above, it car. be seen that the Reinspec-tion Program included a reasonable distribution of inspectors over the timeframe of interest, and the sample size for each contractor was large enough to
provide assurance that the results of the Program are representative of each contractor's total inspector population.
The adequacy of the sample size can also be judged by comparison with those specified by Military Standard 105D (Military Standard 105D, " Sampling Procedures and Tables for Inspection by Attributes," Washington, D.C.; U.S. Government Printing Office, 1963.
Also appears as ANSI /ASQC Z1.4-1981.) Military Standard 105D is a standard ANSI document containing sampling plans for performing inspection by attributes. The standard specifies sample size as a function of popu-lation size. The follcwing table lists the total population of inspectors, number of inspectors who were reinspected, and the number of inspectors required to be sampled for each contractor, based on a Military Standard 105D single sampling plan and a normal inspection level.
1
Sample Sizes Used in Reinspection Program vs. Those Required in Military Standard 105D 4
No. of No. of Inspectors Total Population Inspectors to be Reispected per Contractor of Inspectors Reinspected Military Standard 105D Blount Brothers 28 8 8 Johnson Controls 7 5 2 Hunter 84 22 13 NISCo 8 4 2 Hatfield 86 23 13 Powers-Azco-Pope 21 19 5 Pittsburgh Testing 85 23 13 Peabody Testing 37 6 8
,. 356 110 64 Note: All of the inspector population was reviewed for possible reinspection for Johnson Controls, Powers-Azco-Pope, and Peabody Testing. There were no rein-spectable items for those inspectors not included.
1 Thus, I conclude that the sampling plan used to select the QC inspectors was adequate because its size cap-i tured a significant number of inspectors distributed over the entire period of interest. In addition, the samples compare favorably with those suggested for such plans in MIL STD 105D, which is recognized in the field of statistical quality control.
Q.12. How much of each, inspector's work was subject to rein-spection?
i A.12. The Program required that the first 3 months (i.e., 90 l
days) of each selected inspector's work be reinspected.
Q.13. Why was only the first 3 months used? .
A.13. A random sampling of each selected inspector's total work was not judged adequate to indicate the inspec- f tor's initial qualification. Rather, the first 3 months of each inspector's work was judged to be a conservative measure of that inspector's qualifica-tions because any deficient work by an inexperienced inspector is most likely to be performed during the early months on the job. This sampling approach introduced a conservative bias which would support the adequacy of the inspector sample discussed in response to Q.11.
Q.14. Was there any requirement that an inspector have a minimum number of inspections before he qualified as a candidate for the Reinspection Program?
A.14.
Yes, in order to provide a baseline for assessing the performance of the selected inspectors, a minimum num-ber of reinspections was incorporated into the Program guidelines.
Generally, an inspector had to perform a minimum of 50 reinspectable inspections during the period subject to reinspection, In the case of inde-i pendent testing agency personnel (Pittsburgh Testing and Peabody Testing), 25 inspections were accepted because of the limited number of inspections for the typical inspector. When required, the next inspector listed chronologically was substituted. In those cases for which reinspection was initiated for the original inc.pector but a " minimum quantity" was not reinspectable, all reinspections actually performed for the original inspector were also included in the '
Program data base.
Q.15. What work performed by Hatfield, Hunter, and PTL was reinspected.
A.15. The work was categoriced into discrete work activities called attributes. Each attribute was subdivided into more basic elements, wheriin the inspection of an i i
attribute encompassed inpection of its elements. All attributes of safety-related work inspected in the 90-day period were reinspected if they were both recreatable and accessible. Some attributes were not inspected in the 90-day period by any of the sampled inspectors. In the case of Hatfield, 9 of 11 inspec-tion types were captured in the Reinspection Program, the remaining two (cable pan covers and cable pan identification) were not inspected by any inspector sampled in his first 90 days. In the case of Hunter 43 of 48 inspection types were captured in the Rein-o
, spection Program, the remaining five involving compo-nent support and equipment final inspection (Type 3 or 4 hardware and document reviews) had not been initiat-ed prior to September, 1982. All of the attributes reviewed for incorporation in the Program are deline-ated in Attachment B.
Q.16. Is it your testimony that only accessible and recreat-able attributes were reinspected?
A.16. Yes.
Q.17. Please explain the manner by which attributes were determined to be either accessible or recreatable.
A.17.
An attribute inspection was considered to be recreat-able if it could be identified to a specific inspector and the condition or state originally inspected was capable of reinspection at a later time. For example, an inspection was not recreatable if the attribute inspected was reworked at some time after the original inspection. An inspection was not recreatable if the attribute was subjected to inspection on a sampling basis without element specific documentation, such as conduit support bolting for which the inspection of a specific support could not always be identified to a specific inspector. In addition, certain attributes are only amenable to inspection at the time the origi-
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i nal work is being done, such as weld interpass temper- !
l l ature or equipment rigging hold points.
An attribute inspection was accessible for reinspec-tion if extensive dismantling was not required to ensble the reinspection to be performed. Thus, cer-tain attributes were inaccessible due to their being embedded in concrete, or located within structural or mechanical enclosures which would require removal of hardware in order to make reinspection possible.
Attribute inspections were deemed to be accessible,
, however, if reinspection could be accomplished through the erection of scaffolding or through the removal of
- paint, insulation or fireproofing.
Q.18. Were the attributes further categorized for purposes of the Reinspecton Program?
A.18. Yes. For the purposes of the Reinspection Program basic attributes inspected were characterized as either " objective" or " subjective". This characteri- .
i zation was made based on the manner by which a partic-ular inspection was carried out, t
l Q.19. What is the difference between a subjective and objec-t tive attribute?
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A.19. An objective attribute is one for which its inspection fs not significantly affected by qualitative inter-pretation. An element of such an inspection can usually be easily quantified or measured, such as material type, size, shape, traceability, dimensional configuration, etc.
A subjective attribute is one for which its inspection requires qualitative interpretation by the inspector.
An example is visual weld examination without support-ing gauges, for which an inspector is called upon to reach judgments on weld elements which cannot be readily quantified, such elements as overlap, poros-ity, lack of fusion, etc. Weld length was also con-sidered a subjective feature if it was assessed quali-tatively, i.e.,
without the use of a mechanical meas-uring device.
Visual weld examination was the only subjective attribute in the Reinspection Program.
Q.20. How was it determined that original inspections were acceptable?
A.20. The focus of the keinspection Program was to assess
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i the qualifications of the site c:ntractors' QC inspec-tors who had performed inspections during the 1976 to September, 1982 timeframe. This was accomplished by using QC inspectors to reinspect the original inspec-t t
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l tors'. work who were qualified under the certification ;
i procedures accepted by the NRC in mid-1982 and approved for use by the site contractors beginning in September, 1982. The original inspection record and I
the reinspection record were compared and evaluated to >
determine whether any discrepancy between the two i
records existed. '
Each contractor used its own QC inspectors as rein- !
t spectors and as indicated above, the reinspectors were properly qualified. Reinspections were performed to !
the same or in some cases more stringent criteria than had been used in the original inspection. Thus, even if design requirements or inspection criteria had been relaxed subsequent to the initial inspection, accepta-bility of the work performed by the original inspector was evaluated according to the earlier, stricter criteria. It was deemed important to recreate the conditions of the original inspection because the objective of the Reinspection Program was to evaluate the quality of the original inspectcr's performance. '
Acceptable items were defined as those for which the reincpector agreed with the condition recorded on the original inspection record. Without that agreemer.t. I the item was graded as unacceptable. These stat 11 tics !
were compiled and recorded in such a way that correla-i l
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tion to the original inspector could be accomplished.
The grading was executed in this manner regardless of whether or not the installed item was in conformance with design drawing tolerances. If the original inspector recorded a value for a finite dimensional measurement and the reinspector could not obtain the l
l name measured value, the item was graded as unaccept-able (hence an observed discrepancy), even if the j installed product dimensions were acceptable to design i
drawing tolerances. For example, if the original l
inspector identified the distance between two points as 3 feet 2 inches, but the reinspected value was 3 e-l feet 1-5/16 inches (a difference of 11/16 inch), a I
discrepancy was recorded even though both measurements L
meet the requirements of the design drawings, i.e.,
they are within the decign tolerance.
l All observed discrepancies were recorded and tabulated and subsequently compared to the Program acceptance criteria. It is important to reiteratt that all obterved discrepancier were counted against the orig -
nel inspector whether or not the observed discrepancy was later demonetrated to be a valid discrepancy when compared to current design or installation parameters and tolerances.
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l l Q.21. What were the acceptance criteria?
l A.21. For the purpose of this Reinspection Program, the fol- '
lowing acceptance criteria applied: i l
l 1. For objective inspections - 95% agreement rate.
- 2. For subjective inspections - 90% agreement rate. ;
The agreement rate is the rate at which the reinspec-tor agreed with the condition recorded by the original i
inspector on the original inspection record. '
f i
t Q.22. What is the basic for the 95 percent acceptance level !
h for objective attr1Duten?
A.22. Acceptance criteria were established that Commonwealth !
Edison judged would provide reasonable assurance of '
- the adequacy of the inspector's qualifications. For objective inspections, such as an inspection performed l
with calibrated instruments or the inspection of a material heat number, agreement between the reinspec-I tion 'and the original inspection was required to meet j
or exceed a rate of 95%. This acceptance criteria was considered a reasonably conservative acceptance level, that recognized that unintentional human error pre-cluden 2007, agreement. Moreover, many objective inspections require some subjective Judgment on the part of the inspector, thereby reducing the likelihood of complete agreement between the original inspector and the reinspector, i
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The use of the 95% agreement fate should not be inter-preted to mean that 5% of objective work can be defee -
tive. All discrepancies were evaluated for design significance. Although the situation did not present itself, had valid discrepancies with design signifi-cance been identified, a determination of the root cause of that discrepancy would have been made and l l
- further reinspection or other appropriate remedial 1
action would have been implemented. This intent was
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contemplated within the expansion criteria defined for the Program.
I Q.23. What is the basis for the 90 percent acceptance level for subjective attributes?
A.23. Subjective inspections were known from past exparience to involve qualitativo interpretation. Therefore, i
l agreement between the reinspection and the original I
inspection was required to meet or exceed a rate of j 90%. This acceptance criterion was applied only to j visual welding inspections performed without support-ing gauges. The 90% acceptance level recognized the j likelihood for reasonable disagreement between inspec-I tors and reinspectors where judgmental decision making
! was involved in the inspection.
i
l For the case of visual welding inspection, Edison's extensive prior experience in the reinspection of similar welding features at other construction sites formed a basis for the 90% criterion. First, the Com-pany was aware that such attributes, even if truly acceptable, are not amenable to a high agreement rate when reinspected. This is supported by the discussion of inspector activities in the Quality Control Hand-book (J. M. Juran, et. al., McGraw Hill, 1962), to which reference was made at the time the Byron Program
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was developed. Second, Edison's experience clearly indicated that inspectors are inherently more conser-vative in their judgments when they are participating in a reinspection program which is subject to close outside scrutiny. Although that conservatism cannot be quantified, we considered a difference between the expected agreement rates for objective and subjective attributes of 5% to be a reasonable bound.
In order to further ensure that visual weld inspection results were consistent and accurate, the Reinspection Program accepted by the NRC staff provided for a third-party review of identified discrepancies. The third-party review found that the reinspectors were often overly conservative in their interpretations.
This judgment was confirmed by the NRC-Region III Staff.
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As in the case of observed discrepancies identified for objective attributes, all observed subjective dis-crepancies were evaluated for design significance.
This gives evidence of the Program intent to assure with high confidence that defects of design signifi-cance did not go undetected.
Q.24. What action was taken, if any, if an inspector's work did not meet the acceptance criteria?
A.24. As was discussed in response to Q.12. and Q.13., a sampled inspector's first 3 months of inspections were reinspected. If an acceptance criterion was not met for that period, the inspector's certification was considered suspect. In order to determine whether the inspector should be deemed to be unqualified, an expanded sample covering the second 3 months of the individual's inspection tenure was reinspected for the attribute (s) found to fail the acceptance criterion.
If the results of the second three month period alone did not meet the acceptance criterion, the inspector was judged to be unqualified. In this event, 100% of the inspections performed by that inspector of the type found to fail the acceptance criterion were rein-spected. In addition, the original inspector sample population for the particular contractor involved was expanded by as much as 50% for the attribute in ques-9
~
tion, depending on the number of inspectors still available for inclusion in the Program.
If an inspector had no inspections beyond 3 months and did not meet a Program acceptance criterion, the next inspector certified chronologically was substituted and his first 3 months of work was reinspected." The qualification of the original inspector in such a case was considered indeterminate, but his results were retained in the Program data base, and all observed discrepancies were evaluated for design significance.
If expansion was required, Commonwealth Edison's selection of the inspectors to be added to the sample was made from an overall list of inspectors certified in the specific area where the unqualified inspector was identified. Thus, the expansion focused specif-ically on areas where qualification was suspect. This approach resulted in a very broad sampling of the potentially discrepant area of qualification when a single inspector failed to meet the Program acceptance criteria.
With respect to Hatfield, Hunter, and PTL the applica-tion of the Program criteria is shown in Attach-ment C.
For objective attributes, the adequacy of certification for all inspectors was demonstrated
~27-i
through the reinspection of the first 3 month period.
No inspectors were adjudged unqualified and conse-quently no expansion of the reinspection sample was !
i required. For the subjective attribute, both Hatfield and Hunter had one inspector whose qualification was indeterminate after reinspection of the first 3 month 1
period. PTL had two such inspectors. Because these !
individuals had no further work, their qualification j could not be assessed further. A substitution was made for each of these individuals and the substi- '
tute's reinspected work was shown to meet program acceptance criteria. Therefore, no expansion resulted. '
PTL had one other inspector whose performance did not l
meet the subjective program acceptance criteria for either the first 3 month period or for the second 3 j month period. Therefore, PTL was subjected to an j inspector sample expansion. In this case the failure of just one inspector resulted in an expansion that 4 captured the first 3 months of work for the attribute in question (visual welding inspection) of all remain-ing inspectors wnose work was accessible. Each of the i
4 additional inspectore passed the Program acceptance 1
criterion.
A Program flow chart that describes the logic path for Program expansion is provided as Attachment D.
l
.t -
i E . 2 :
r Q.25. What were the results of the Reinspection Program with i i ,
respect to the qualification of the QC inspectors for L Hatfield Electric Company? -
A.25. The primary result of the Reinspection Program was the 2
f demonstration that all Hatfield Electric inspectors sampled, for whom sufficient work could be reinspected to assess their qualifications, passed the Prog' ram ]
acceptance criteria.
This result demonstrates that the prncedures implemented by Hatfield Electric Corpo- f L
1 ration for the qualification and certification of QC 1'nspectors prior to September 1982 were effective.
- Thas, the uncertainty raised by the NRC CAT inspection j t
] concerning the qualification of Hatfield inspectors is !
i resolved. Moreover, the Reinspection Program results i i
support the conclusion reached by the NRC Staff in I
1980 that the Hatfield program for qualification and j
i certification of QC inspectors was adequate. The 1980 judgment is set forth in IE Report No. 50-454/80-01, j
in which the NRC Staff indicated that all Hatfield inspector certification packages that were reviewed (8 '
in total) were found to be acceptable. I note that 4 1
- of the 8 anspectors whose documents were reviewed in 198C were included in the Reinspection Program and met k
- the Program acceptance criteria.
Q.26.
Pave you drawn any other conclusions from the Hatfield resulta?
1 I
- +__a__-_a_ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ . _ . _ _ . _ _ _ - - - - _ . . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . . - _ _ _ _ . _ _ _ _ .
p i
A.26. Yes. I can also conclude with high confidence that !
(
all other inspectors enrtified in accordance with l i
these same practices and procedures were also I adequately qualified. This opinion is based on the i
number of inspectorc whose qualifications were demonstrated, the significant number of inspectors whose work was actually reinspected (27%) and the concomitant statistical significance of this sample t i
(see response to Q.11.), the extremely large and diverse data base upon which the conclusion is founded '
(87,783 inspections total; 60,245 objective and 27,538 i subjective), and also the fact that although a limited !
number of discrepancies were found, no discrepancy was !
identified which had design significance. '
Q.27. What were the recults of the Reinspection Program with !
respect to the qualification of the QC inspectors for Hunter Corporation?
A.27. The primary result of the Reinspection Program was the '
demonstration that all Hunter inspectors sampled, for whom sufficient work could be reinspected to assenc his quellfacation, passed the Program acceptance criterna. This result demonstrates that the proce- I l
dures implemented by Hunter Corporation for the quali- '
fication and certification of QC inspectors prior to i September 1982 were effective. Thus, the uncertainty t
i i
_ - . _ _ , _ _ _ _ . _ _ . _ . _ _ - - - - - - - - - - - - - ^ - - - - ' ~ - ~ ^ ^ ^ ~ ^
r
(
i l
[ t raised by the NRC CAT inspection concerning the quali- '
fication of Hunter inspectors is resolved. Moreover, i
! }
the Reinspection Progran results support the conclu-sion reached by the NRC Staff in 1980 that the Hunter !
l progtam for qualification and certification of QC inspectors wat adequate. The 1980 judgment is set forth in IE Report No. 50-454/80-01.
i Q.28. Have you drawn any other conclusions from the Hunter results?
A.28. Yes. I can also conclude with high confidence that l
all other inspectors certified in accordance with !
these same practices and procedures were also ade- !
quately qualifted. This opinion in based on the num- t ber of inspectors whose qualifications were demon-f ctrated, the significant number of inspectors whose work was actually reinspected (26%) and the concomi- I tant statistical significance of this sample (see I response to Q.11.), the extremely large and diverse (
data bate upon which the conclusion is founded (73,349 inspections total: 69,624 objective and 3,725 subjec-tive), and also the fact that although a limited num- I ber of discrepancies were found no discrepancy was ;
identified which had design significance. '
i e
i i
Q.29. What were the results of the Reinspection Program with l
respect to the qualification of the QC innpoctorn for PTL7 A.29. The primary renuit of the Reinspection Program was the l
demonstration that all but one of the PTL inspectors campled, for whom sufficient work could be reincpoeted to annean his qualification, panned the Program acceptance criteria. One individual, whose work ulti-mately was 100!; reinnpoeted, did not pans the Program subjectivo acceptance critoria for both the first and second 3-month period. This resulted in the expansion in the cample of inspectors reinnpoeted as was din-cuaned in response to Q.24. Thus, the uncertainty rained by the t:RC CAT inspection concerning the effoc-tivenean of the qualification and certification prac-I tices implemented by PTL in resolved.
Q.30. Have you drawn any other conclusions from the PTL results?
A.30. Yoc. I can also conclude with high contadence that all other innpoctors certiflod in accordance with those name practices and procedures were also adequately qualafted. This opinion in baned on the num.ber of inspectors whose qualifications were demonntrated, the significant number of inspectorn
, 1 P .
l
- whose work was actually reinspected (27%) and the ,
concomitant statistical significance of this sample .
i (see response to Q.11.), the extremely large and diverse data base upon which the conclusion is founded (12,153 inspections total: 6,137 objective and 6,016 I
subjective), and also the fact that although a limited
, l l
num.ber of discrepancies were found, no discrepancy was !
identified which had design significance. !
l i
Q.31. Does the fact that certain inspections were inaccessi-ble or not recreatable affect your conclusions on the I reinspection program regarding inspector qualifica-
[
tions?
A.31. No.
One must keep in mind the fundamental objective of the Reinspection Program which was to verify by l
reincpoetion the adequacy of the qualification and certification practices for contractor QC inspectorn.
5 The Program demonstrated the effectiveness of those practices for a representative sample of inspectors .
from which it can be inferred that the same practices were effective as applied to tua remaining inspectors t
i and, therefore, as to all inspection work performed by ,
the entare inspector population.
The fact that certain inspection elements were either- I not recreatable or were inaccessible does not affect
{
my conclusion for several recsons. First, the data I
base developed within the Reinspection Program is extensive. Hundreds of thousands of inspections were recreatable and accessible, providing an enormous data '
base from which to assess the effect1veness of qua11-facation and certification practices. Second, the qualification of anspectors for many of the attributes with anaccessible or not recreatable elements can be l
anferred from the fact that adentical accessible ele-l rents an other attrsbutes were reinspected and the qua12facataon of the inspectors has been verified.
l For example, the amount of pipe, conduit or duct run encased an concrete as small by comparison to and as !
I directly represented by the pipe, conduit, and duct l run in air subjected to reinspection in the Program.
The primary eierente of :nspection are the same se the results of reinspection of the accessible inspections can be used to draw conclusions regarding the non-reinspectable work. This is further demonstrated by the summary discussion of these attributes contained an Attachment E.
l l
The gus11tacatzon and certsfacation programs for these inaccessible and not recreatable attributes are the same as those verified by the Byron Pennspection Pro-gram. In fact, many of the inspectors whose work was
reinspected in the Program also performed inspections in areas not reinspectable. Generally, inspectors were qualified for many attributes. The requirements imposed for prior experience, job training, and per-formance demonstration have the same general scope and technical content for each of these attributes, and those attributes not reinspected are similar in many respects to those captured for reinspection.
For these reasons, I am convinced that the conclusions reached in the Reinspection Program based on the scope of attributes actually reinspected are valid and defensible.
Q.32 In your previous answers concerning the results of the Reinspection Program for Hatfield, Hunter and PTL you indicate that discrepancies were uncovered as a result of the program. How were these discrepancies disposi-tiened?
A.32. Before the reinspection effort was undertaken, Common-weath Edison recognized that, in all probability, dis-crepancies would be found. In order to create a data base sufficient to determine whether the discrepancies were either non-critical or critical to the design basis requirements, the contractors were directed to record all the reinspection results but not to imple-
=
ment corrective action immediately. This approach was !
taken so that the "as found" physical conditions could be observed at a later date for possible detailed analys:s. As the Reanspection Program progressed the various contractors were directed to incorporate the unacceptable conditsons into their particular non-cen-formance systems in order to implement corrective action, including trending of the discrepant cond;-
tions.
All discrepancies that were determined to exceed an ASME Code examination acceptance criteria were repaired, even though they were also determined by evaluation not to have design significance..
All other valid discrepancies were either repaired or disposit:ened as acceptable "as-is" based on engineer-ing evaluation results. Although physical rework in these latter cases was not mandatory because the dis-crepant condition did not compromise the design bar:s, some rework wa: performed. For example, all ob;ect:ve d:screpanc2es related to documentation were corrected.
Q.33. In response to Q.32. you 2nd:cate that d:screpant con-d:tions'were reviewed for trends. Describe this pro-cess, and the results, if any, for Hatfield, Hunter and PTL. I l
l I
=
A.33. A brief review of the overall Program data trends is I 1
instructive. First, the Program identified 3,247 observed discrepancies associated with 156,926 objec-tive inspections (2% discrepancy rate). The results for Hatfield, Hunter and PTL are given below.
Summary of Cbyective Discrepancies by Contractor Number of Observed Valid Contractor Inspect 2cns Discrepancies Discrepane es Hatfield 60,245 2,115 432 Hunter 69,624 684 70 PTL 6,016 66 65 From this it 2s clear that the general acceptance rate for ob;ect:ve attributes was exceptionally high. When the observed discrepaneses for Hatfield, Hunter and FTL were screened to eliminate those observations that are not valid discrepanc2es, the discrepant populat:en for Hatf2 eld, Hunter and PTL is approximately l', of the total of inspections performed. In the case of Hunter, only 0.1% of the objective population inspect-ed was shown tc have a val 2d discrepancy assoc:ated with 2t. This 2ncludes those d2screpanc2es 2dentified that 2nvolved documentation, none cf which displayed an apparent trend.
Second, the. Program identified 4,001 observed subjec-tive (visual weld) discrepanc2es associated with
45,858 subjective inspections (9% discrepancy rate).
The specific results for Hatfield, Hunter and PTL are given below.
Summary of Weld Discrepancies by Contractor Number Observed Val:d Contractor Inspected Discrepancies D:screpant es Hatfield 27,538 2.986 1,978 Hunter 3,725 109 84 PTL 6,137 905 904 Although the d2screpancy rate is somewhat higher for subjective than for objective attributes, it must be remembered that these visual weld discrepancies are more likely to occur due to the inherently subject:ve nature of the inspection attribute. However, althcugh the discrepancy rate is higher, the ultimate issue :s whether these discrepancies are systematic and s:gni-facant enough to compromise the design. As was ind;-
cated in previous responses, no visual weld discrep-ancy was found to have design significance.
The resultc for all attributes were evaluated on a contractor-by-contractor basis to determine whether any trends existed in the observed discrepancies (:.e.
reject rates) that might warrant further review. This evaluation 2nvolved a sorting of the observed discrep-aneses into discrete elements w2th a comparat2ve
assessment made of these elements. If any element demonstrated a significant contribution to the dis-crepancy total, its significance was reviewed and any inspection practice ramifications were considered.
W2th this preliminary discussion complete, I will turn to the specific trends uncovered within the Re:nspec-tion Program data concerning Hatfield, Hunter and PTL.
- 1. For the sub]ective attribute of visual weld 2nspect en, the results for each contractor were analyced using approximately five elements. PTL had a minor problem in reproducing the original visual weld inspection report. The requirements for the welds in question were not specific as to the accept- able tolerance range. Therefore, agreement rates between inspectors were predictably lower due to the fact that the app 12 cable drawing requirement was strictly applied on reinspection. This was complicated by the fact that the feature being inspected, i.e., small fillet welds, were 2nspected for leg and length d: mens 2ons without gauges, thereby increasing the subject 2vaty of the inspection. Because the fillet leg dimension in question was typically small, it was diff2 cult to reproduce inspection results. Cur-rently, both dimensional tolerances and weld gauges are being used to make these inspections more objec-
o .
tive than was the case at the time the original in-spections were done.
In addition, PTL showed an undesirable discrepancy rate for the attributes of undercut and overlap. Ocn-stant training during the visual weld inspecters' tenure has much improved the cons 2stency of their judgments made in the areas of undercut and overlap.
Discrepancies of this type were shown to be ins gr.:f:-
cant.
- 2. In evaluating observed discrepanc es associated with Hatfield visual weld inspections, it was noted that a disproportionately large fraction of the dis-crepancies were related to the inspection of sheet steel welds. This is not necessarily an indication of a specif2c problem with a particular inspector but rather a manifest'ation of an issue pertinent to the entire industry, related to visual inspection of sheet steel welds. This trend is not unexpected.
The standard applied in the past and wh:ch was used in the reinspection program was AWS Di.1., a structural steel code. That code makes no specific provision for welding the 12ght gauge sheet steels at issue here. A modified code has been developed specifically for sheet steels, AWS DI.3. That code is now being 1mple-
mented at Byron. Most surface finish discrepancies previously recordable under AWS Dl.1 have been elim:-
nated by this new sheet steel code.
1 From a design impact standpoint, these discrepancies I are insignifacant. Not only were these discrepancies specifically evaluated and determined to be of no cen-sequence but also sheet steel welds generally have very low load requirements. The strength afforded by even a code rejectable weld is almost always much greater than that needed to fulfill the design-re-qui reme nt s . This conclusion has been validated by
, actual tensile tests previously performed on a similar sample of rejected welds on another project. The tests showed that welds which would be rejectable under AWS Dl.1 criteria had margin in excess of what is required by design. In fact, in almost all cases, the fa: lure under load resulted in failure of the sheet metal rather than the weld itself.
In summary, all observed discrepancies have been assessed for possible trends. Except for the twc dis-cussed above, none was identified.
Q.34. Has the NRC Staff reviewed the results of the Rein-
! spection Program, and have they reached any conclu-t l
1 1
sions relat2ve to the adequacy of work performed by l site contractors at Byron.
A.34. Yes. The review of the results of the Byron Reinspec-tion Program by the NRC Staff is documented in IE Report Nos. 50-454/84-13 and 50-455/64-09. In those reports it is stated that contractor inspectors did not overlook significant safety-re'ated hardware def:-
cienc;es and that safety related work dene by the Byron contractors is of acceptable quality. Althcugh the classif2 cat:on of weld length as a subjective in-spect:or. feature was commented on by the NRC Staff when it accepted the program in March, 1983 and in test; mony before this Board, the Staff has not commun-2cated any further concern regarding this issue. The Staff has closed the item of noncompliance which gave rise to the Reinspection Program.
Q.35. Since the completion of the Byron Reinspection Pro-gram, has the NRC Staff reported on any other matters concern:ng the QC inspector activities of Hatfield, Hunter, or PTL.
A.35. Yes. Two sets of inspection reports which relate to Hatf2 eld Electric QC act2Vitles have been issued.
Q.36. Would you please summarize those reports.
l l
l i
1 I
. l A.36. First, IE Report Nos. 50-454/84-27 and 50-455/84-19 were issued on June 9, 1984. That report identified two apparent items of non-compliance.
(1) A design drawing notation (Note 47 on S&L Drawing 6E-0-32378, Rev. L) was not incorporated into procedures which required the electrical contractor to install cable tray covers, whether or not explicitly specified, if field conditions resulted in a violation of cable pan separation requirements without the covers. This was considered a Level V violation (minor safety-significance). Although training of Hatfield personnel including QC inspectors was con-ducted to review this drawing requirement, appropriale procedures controlling the installation of pan covers under these special circumstances had not been imple-mented. As a result, a limited number of cable pan inspections had been performed (126 cable pan inspec-tion reports) without documentation of a review against the drawing notation. The necessary proce-dural revisions have since been made and implemented and a 100' reinspection of the aflected cable pan pre-v2cusly installed was undertaken, with completion of the reinspection scheduled for July 13, 1984.
(2) Certain cable tray hangers were identified as discrepant after an extensive reinspection of similar N
hangers had been completed. This was considered a Level IV violation (more than minor safety-signifi-cance). Hatfield Electric had reinspected over 4000 cable tray hangers to verify hanger configuration because the Hatfield QA manager identif:ed a documen-tation deficiency in 1982. The connection between the structura' steel and certain hangers (345) were judged to be inaccessible for reinspection because of fire-proof ng or encasement in walls. In 1982, it was determined that if these hangers had valid weld traveler records including weld inspection records, no further reinspection was considered to be necessary.
In 1984, at the request of the NRC inspector the hang-crs within this class were reinspected with the fire-proofing removed, and 129 apparent discrepancies were cbserved involving 119 hangers. It has since been established that 91 of the observed discrepancies, affect 2ng 91 hangers involved gaps in the fit-up between the hanger and the auxiliary support steel to which the hanger was attached. An inspection for this fat-up gap wac not introduced as an inspect:on re-quirement unt21 February, 1984, and all of the fit-up gap discrepanc2ec ident2 fled were found te have no design s2gnificance. Of the remaining observed d:s-crepancies only 11 affecting 11 hangers were valid discrepancies; the remainder having been shown to be in conformance with current design requirements. Each of the 11 discrepant hangers are being evaluated to determine whether remedial action is required.
Second, IE Report Nos. 50-454/64-09 and 50-455/84-07 were issued on March 19, 1984. That report ident f:ed one apparent item of non-compliance involving a s;ngle Hatfield discrepancy report (DE-3382) that dealt with the removal of a cable from a conduit. The discrep-ancy report inaccurately described the pulling force applied in the removal of that cable, resulting in a def:clent engineering evaluation. This was considered a Level IV violation (more than minor safety-signifi-cance). This event was determined to be an isolated occurrence based on a review of all other discrepancy reports involving cables pulled out of conduit, and was closed by the NRC in IE Report 50-454/84-27. This item 1s d2scussed in some detail in testimony filed by Mr. J. O. Bander of Commonwealth Edison and Mr. B. G.
Treece of Sargent & Lundy.
Q.37. De the f acts underlying those ::~.: repcrts affect your opinion relative to the effectiveness of the Hatfleid Electr2c QC inspector qud 2 f 2 cation and certification program.
A.37. No. The matters addressed in those inspection reports are not significant. This is true whether viewed individually or collectively.
With respect to the first item involving the failure tc an :rperate a drawing requirement concerning cable pan ecver installation into the inspection procedure, the affected centractor personnel had been trained en the drawing requirement and are believed to have prep-erly implemented it. The procedural deficiency which should be and has been resolved will provide ob;ective evidence that the requirement is being implemented.
There is no apparent basis to conclude that inspecters who were trained did not effectively monitor the pan ecver installation activities.
The second iter involving cable pan hangers identified a very limited number of di'screpant hangers attribut-able to deficient inspector activity. The majority of the observed discrepancies involved an inspection ele-ment only recently applied (fit-up gap) and does net, therefore, compromise the integrity of previously per-formed inspections. The valid discrepancies were shown not to be significant.
The third item involving cable pull tension has been t the subject of extensive review by both Commonwealth r
, 1 l l
- I t
Edison and the NRC Staff. The isolated violation in-volving a single cable rework event has been disposi-tiened and closed to the satisfaction of the NRC Staff. No like violation has been identified after reviewing all cable pulls of a similar type.
Taken together, these events do identify an apparent weakness in translating design requirements into in-i spection procedures. However, this fact alone does not compromise the integrity of inspector qualifica-tion and certification programs. These procedural discrepancies have not resulted in major rework on the affected safety-related components, which further sup-ports my opinion that the events are not significant.
It remains my conviction that the QC inspection acti-vities of Hatfield were and are effective and that those activities were implemented in a way that sys-tematic problems of design signifi nee have not gone undetected.
Q.38. Do you have an opinion with respect to the quality of the work performed by Hatfield and Hunter?
l A.38.
It is my opinion that the Hatfield and Hunter work is adequate, and that reasonable confidence exists to ll conclude that equipment and systems associated with l I
,
- i
. _, e i 1
1 this work will not compromise the safe operation of Byron Station.
Q.39. What is the basis for that opinion?
A.39. As I previously stated, it is my opinion that the work performed by Hatfield and Hunter is adequate and that reasonable confidence exists to conclude that the equipment and systems associated with this work will not compromise the safe operation of Eyron Station.
In this regard, PTL was not responsible for any under-lying construction work and will not be further dis-cussed here.
My opinion is based upon the results of the Byron Re-inspection Program and the inferences that can be drawr. from the results of that Program. It is further supported by my belief in the general effectiveness of the programs implemented by Commonwealth Edison at Byron to assure the adequacy of construction activi-ties.
First, the vast majority of Inspectors whose werk was reinspected in the Byron QC inspector Reinspection Program passed the Program acceptance criteria. On this basis the effectiveness of Hatfield and Hunter QC 1 anspector programs were revalidated. The effective-l
I ness of these programs ensures that work performed by these contractors was adequately inspected, from which it can be inferred that the contractors construction work is of adequate quality. Although some uncertain-ty has been expressed relative to the procedures for documenting work, those uncertainties are resolved by the demonstrated adequacy of the actual work. Recal-ling the conservatism in the agreement rate calcula-tion, wherein all observed discrepancies were counted against the original inspector, the demonstrated effectiveness of these programs provides reasenable assurance that no systematic problem was left undetec-ted.
As can be seen from the table below, a significant number of items were reinspected in this Program. The rate at which these items were found acceptable is also quite high. Although some discrepancies were found, none were determined to have design signifi-cance. This determination is discussed in detail by the S&L w:tnesses, and g2Ves added support te ry cen-clus2on that construct 2on defects of s2gn:ficance have not gene undetected l
l e
Reinspection Program Summary Tctal Objettive Subjective Objoctive No. of Inspection No. of Inspection and Objective Results Subjective Results Subjective Contractor Inspections Acceptablel Inspections Accer. table 2,3 Ir.sp. tiens Hunter 69,62!. 9 9 ,0'. 3,725 9 7 . 0'. 73,319 Hatf:cid Electric 60,215 9e.5% 27,53E 92.0% 67,763 Netes for Tablej.F '-
- 1. Program acceptance craterion is 95%.
- 2. Program acceptance criterion is 90%.
- 3. Includes concurrence by th2rd party inspector.
Second, building upon my first point, the extensive and diverse data base developed for Hatfield and Hunter allows me to infer that the quality of work :s adequate over the full range of plant work items that ,
were the responcibility of Hatfield and Hunter.
4 Because of the broad Reinspection Program undertaken at Byron, I am convinced that the general work qual:ty of Hatf: eld and Hunter is adequate. This convict:en is based upon my review of the type and nu:.ber of d:s-crepanelec attr2butable to these Byron contractors.
Prev 2ous reinspections of sam 11ar items at other s:tes have, in my opin2on, yielded similar results. Th:s s
o , .
l particularly true of the fillet weld attribute which was found to have the highest observed discrepancy rate in the Program. With this perspective, I have high confidence that the plant-wide reliabilities that can be derived from the Reinspection Program data base are extremely high and conservatively bound the actual reliability of work performed by these contractors.
[ The data base developed for Hatfield, Hunter and PTL is summarized in Attachment E. The data for each inspector by attr2bute are tabulated, and the cumula-tive average of this data by attribute for each of the contractors is provided.
- My judgment in this case also takes account of the t
fact that certain work attributes could not be re:n-spected in the Reinspection Program. However, as 1
shown in Attachment B, many of the inaccessible and not recreatable attributes had related indic:a of l
acceptability.
l
, Third, there have been many independent layers of :n-l spection and review of fielo installations implemen:ed at Byron for both Hatf2 eld and Hunter. The most obvious of these are the multiple tiers of aud:ts and inspections conducted by the contractors, Commonwealth 1
i
. p e
Edison, and the NRC Staff. I am familiar with these reviews and believe them to be effective.
My own personal involvement has been more closely cen-nected to reinspection and reverification programs which are the outgrowth of those reviews. In that regard, Hatfield has implemented several reinspect en programs over the course of its tenure at Eyron.
These involved concrete expansion anchor ver:f: cation in 1979, cable routing reinspection in 1981, 100% weld traveler card validation and 100% cable pan hanger configuration and dimension reinspection between 1982 and 1984, as well as the Byron QC inspector Reinspec-tion Program. In add: tion, Hunter has also implement-ed several re nspection programs. These involved a 100% re:nspection of all hangers installed prior to 1980, concrete expans:on anchors installed prior to 1979, as well as the Byron QC inspector Reinspection Program. From these various programs an extremely large and diverse cross-section of work was reinspect-ed. Although some d2screpancies were identified and some rework was requ2 red, those remedial actions are not inconsistent with conparable actions ta"en by the electrical and mechan 2 cal contractor at LaSalle County Station with wh2ch I have had extens2ve experience.
e
Also of significance to me in this regard is the broad program of overinspection conducted by the Common-wealth Edison Quality Assurance Department, which is referred to as the Unit Concept Inspection (UCI) Pro-gram. This prograr was instituted in September, 1982 and involves the reinspection of all items installed within specific spatial boundarles or in conjunction with spec:fic equipment. The items are inspected for compliance to vendor and engineer.ing design docu-ments. More than 69 of these UCI inspections have been conducted at Byron encompassing a wide spectrum of electrical and mechanical work. For example, ever 25,000 mechanical items, over 5000 linear feet of p ping and insulation, over 25,000 electrical items, and 1,500 sections of cable pan and conduit have been inspected. The results of this program have nct iden-t:fied any significant cons'truction discrepancies and, therefore, support the judgment that the underlying werk quality is adequate.
1 DelGeorge Attachment A i
-i l f -
L Percent of Safety-Reisted alte Work i
Mormed by Contractors Evaluated by l Ste Re:nspooWon Program .
L i
i f
i l
l s l I
i l
l 4
Site work performed by
, remaining contractore "
4.3% i i
I i
N Sheet bbetag Nwers Arco-pope 5%
(DfVAC) 3% l
, i NISCo 0.5%
Johnson Controls 1.0%
Pittsburgh heung 2.0%
! heboe rbemas e.2%
8 l ,
a.7%
i I
)e M SNe work pefformed by centreetori e ,seuseos my h Ele .% , ::^"L. program %N l
6 l
- b w Dc!Ceorge Attachment B
- Page 1 of 14 If ATFIt't.D FIJCTPIC At t r it ut e Ins,pectson Suemary I
Precedure Inseetinn_ Type peinpp reion_ Con.,lieirn l'r_i ma ry_ Inspect ion rea t ures 82 rat edac<l Con <tn i t Inaccessillo Sire, Type, Incation, De n<1s , Condition (Same an Procedure. e20)
- 3 linderq rcund fluct Puns i n.iccens i te t e Sire, Typa, I,ocation, tienels , Conef i t ion (Same as Proce<fure B20) 85 M.iterial 4 l'qu i pmen t Not Pec rea t at'l e Shippinq Damaqe Peceivinq (Same as l'rocedure 812 & 820; i.e.
Crendition) faA Cal-le Pan !!anqcts Fri tJSI'f CTI~f t Type' ennfiguration, I.ocation. 31ol t Torque 89P Ca bl e Pans l'f f t.SI'ITT FD Sire, Ty r'e , Incation, Radius, Separation, 4
Pa n tie l el Iktwn s , Complete 89C Cable Pan Covers PeinspectalIc, rut Type. Istration, Conelition No I nsl'ect ions (Same as Procetture #90)
C.3r't u r ed 891: Ca ble Pan Feinspectalle, fiut 3
Identification No Inspections Segregation Co<les, Colors, Spacing Capt ur c 1 (Iike Procedure 820) 810 Ca t. l e Installation Not Perreatalle Pan Con <t i t ion, Conduit Condition, Ca bl e a
A Inaccensille Collinq, Cable Damage. Ca bi c fiend s , Cable Tension, Routing Points. Cable Fntry Into Equipment. Vertical Cable Supports, Cal >1e Training 811 Cable Terminat ions PI:l tis PFCTFD f.uq Sire & Type, Bolt Sire & Type, Taping 1( i t Stre, F:mposed Conductor, Minimum Dend, intry Int o Fquipment , Training, Segregation
. . - . _ _ _ _ . m _, . . .
b L ~ ' '
1 b
DelGeorge Attachment B
- Page 2 of 14 li ATP II'I.D FI.FCTRIC Att: ilent e Inspectinn Summary Procedure ,Inspectinn Type Pc,i nspert ion Con <li e inn Primary J spection Features
- 12 rquipment Installation I;F I NSPP C7 Fit (1) Type, I.D., Con <li t ion, Anchoring,-
Aleqnment, f.evel, Tornuc*
el?A repa l pmen t floeli f i ca t ions FF I NSPf t'Tf.D Mountinq, lescat ion, Type /Mo<tel, Polt Torquc*, Wire Type, 'f o r m i na t i on I.oca t i on, I.uq/ Connect or , Wel.1 'I raveler 812D Non-Seq Dus Duct . i naccess il.l e Equipment / Support T O ' ft , Installation Crnfiguration, Pott Tnrque ( l.i t e Pro-cc.lu r e #2D) 013AE Visual Weld Inspection PEINSPFCTFD Weldin<l
- 14 Material llandling Not Pecreatable Pioging, Tool Inspectinn, Operation Cotuli t son of Piqqing Equiprent 820 Exposed Conduit Pf:INSPirTfD Sire, Type, Iccation, Pe n<ls , Condition, 4
Segregation Coele Markers, Polt Torque (I);
Inc l uiles Inspect ion of Junct inn Domes, SupportF, Concr et e I:xpansion Anchors
$25 A325 Bolt Installation P FI NS PfrTP:D Dolt Type, nolt Site, Condition of Surfaces, Bolt Tension l'y Turn-of-the-Nut (1) 826 Stud Welding inaccessible l'on< ling Antequat e by VI ,ual and load Tes t
( I.i ke Provelure flJAE) 027 1,imit Switch Casket Not Pec r ea t a bl e Peplacement Verification of Parts (Note: All switches have since been replacert) i
- Specifle inspection feature inaccessitle/not r ecr ea t a bl e (1) P* inspected and reported in Supplement 1. Ant <li t iona l i ns pect i ons pe r f or me<l t o increase data base.
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litJNTTP COPI'OPATION Attril4 ate Innpeetinn Summary At t r it'ut e Peinnpectinn Classification Inspectinn Type rein li t ivire Pr i met ry_ Inspect i nn l'en t u r es (2) Documentation P i p i ri<t - Mecle . .i t . ITINSPirTFD Pecorefing De a th umentatitin (2) Documentatinn Ver r i t e Inspertiors Vot Pecte.itatle Pecoreling Dat a fWesnevit a t ines ( f.i k e nf lier vincoment at ion act i vi t ies )
(2) Documentation Ilyeltogt at ic Test PriNSPTCTID Pecortling Dat a ,
Inocuaren t a t i on (2) Documentation Wel1 Interrass Terp. POINSI'fCTrD Reenr ef i ng Da t a Dncumentatinn >
(2) Documentation Joules Test Not Pecr ea t alit e Pecorating Data Documentation ( l.i l.c ot lier documentat ion ac* ivi t ies )
(2) Documentation Code Nae. Plat e Not Pecreatal,le Pecorefing Data Change ibcumc?.t at inn ( l.i b e nther elocument a t ion act i vi t ies )
(2) Documentation Documentation.of Not Pec r ea t a bl e Pecoreli tig Data Wele! Defect Prenval (l.i be ot tier elsw ueentat ion act ivit ies)
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jm 2 I -
t DelCeorge Attachment il * .
Page 1 of 14 ttttt:Tl l' Criff f'OPAT ION j Attriteste Insjie e t enn Suceary l
At t r i but e Peirim pcct iors t Classification Insg+ct son Tylv' ren.1eison l'r i na ry_I n vec t inri reat ur er.
i
! (2) Ds'cueentatinn Pur icd Ps 3 e Cr*ver iswi Pt ItJSITe~TI f1 Pee oreliner Data l Inag ect ion -
I* rue nf.ition (2) Decurentatson Concrete r u pans i rsr* FF !Fl* l'f 87 911 Pernr eli ng fla t a j Anchor - INicueent at sein ,
(2) Docurentatinn Piping - Fr e-IIca t l'I'I tJSPT CTi ts l'eco r el i nq l'at a Insp. Dncueentatiors i (2) Docueentation Whip Festraint - I'r I NT.PI CT F D Pecording I'ata l'r e-Ifea t Insivect f ore [
Docurentatson t
(2) Decumentation 'I'ipe Weld - Shield PFINSPPCTFD Pecorating Data r.as thw usent at inn L (2) Documentetion Component Sul twir t -
Not Ferreatatle Pecor <t i rwy Da t a Snut ter St rob s ng lxicaseent a t inn (Iike other documentation activities) f i
(2) Documentation Piping & Cepponent Prit;SPFrTFD Pecor< ling Pata Surger t . Tergw*r a r y Attachmenta tiocument at ion !
r (2) Documentatieri Tbl t ir>g - Testn-of-Nut flot Perreatable Pecordin<y Data j Documentation (l.ike ot her elocurentat lors act ivities)
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Page 9 of 14 If1 trii P Cf >ProPATie N A t 9,r a _t eat e t er j e e 9_a < *re_ ? ewe r y At t r itwf t e Pe n nm g e. t s e.re Claesef,cateen I nspey tj nn__Tyg c ,
- r. .n.l se s<.n rr s ca ry_ I nygw r.t s on_ Feaf ea r_es
( 3) l'astware ripin q - Pier ti . Jr. 5 f l M.I'f e T i lt Cond i t s e m , Al s qv+ent , I n i t i a ! Tor que * /
- 1. . .;ue '-.p.erc*, Irit e r me.1 e a t c T e r epre * / *:ceguenre * ,
FevosI T .: q ue / * r ue n. c *
(3) If irefwa r e V a sisa l Inspeetion Inorreas Ole l ett e r na l Cle.ingsness, s' erd i t s on of VaIvem (le6e I e gi s v.<a /kt. : I. Pee,'
- a e r, e reeponent i n, g *e-v t s e m )
(3) lia r .fwa r e Ferrete Irspertseu I na. e t-s s i t'l e INang Ferrite Ir.l' ator riieck four l'oints on We ! . ! ?. ( Th s v. wa. e ainsrFal, non-routEne, r, rec s a l s ne per t s ' a i . I
{3) Ita r ile.a r e ripsnq Ify.trcntatse t4,t Pec r e-* ' .n b l e Inspect irm <>l Tr s e Parameter Achieweeent, Test V =;na? I n.. pert s e m <> f We l .ls (3) lia r efwa r e Piping Weld Interrass Plo t Pers e st at le In.lcetsen of Matal Terperature Teereratute Insg* et sem (3) tia r dwa r e Joules Test 7:et Per r e.s t a bl e Peaten3 leit a f re = Instrueents. Calculat s nq Inspect ott l'ea t I n pe n' (3) Ita r<twa r e Code Pla ce Plate !!ot Perreatatile Watnessinq Perevil of Crwie Nareplate Charv3e (!.s b c Teel 4.r.e r y At t .seteren t Perova!)
Inspection nf Wel1 Not re cr eat atile Me4=urceceit, Mal r i r*q , Eva l ua t i on (3) fia r dwa r e Defert Peroval Cavsty ll.s h e Vssual Wel' Inspection)
Piping - Cawgenene PflNSIICTIft 1.fent i f i r.e t e r.rs, the mage , Internal Cleantiness.*
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b h DelCeotrie Attachment Il Paqc 12 of 14 Itt'NTf'P Cort'OFAT ION A_f f r 1,l'u t e I ncpce f g ain *;iunma ry Attrittste Fe i rir.pce t i ren Cl.assafacttson I n s}7 e t _i tin _Tyly j't r u f I t l e g1_ ,l',r i r,a r y_I n s{.c c t i tif t I'catures (3) fla r elw.i r e Pigia riq - 1.a r ge l'or e P t: I t:SI'I t "I l l' Complete, Pecor<f Ver i f i ca t ion, Ploncon-F t ri.il I ris[ ce t I sin f o r it .its e o I ce r>r el S t .s t u e,
( T) g c 3)
(3) Ibs r rlw a r e Comgonent Sugfort - Pe n n r.g ect al l e , Itu t Complete, Fecorel Ve r i f i c.s t ir,n, ?!nncon-Final Inspectitn tlo t rie.pec t i ons f or marn e Tscror I ?:t a t us (Type J) C.i r.t u r es t (I.i b e l'i r e final Int:r ect non)
(3) If a r tfwa r e C<eponent Surgort - Feinepectable, fiu t In I' l a r e , Intar8, tinct.irarsc<l F's n.n l I ns pec t t rin F:o Insr ect invis (I.i ke l' a g.e Fanal Inspectton)
(Type 4) Ca g t u r e.1 (3) Ila rilwa r e Fquig nen t Installatsen Fe i ns ect alit e, Itu t Identification, inca t irin , Orientation, i r$ Inng cet ions i.ev e l , l'ounela t i on I ol t Coruli t ion,
- Cag t ut vil Pie rha n i r,i l Cr,n ru*ct i nns , Crouting.
Aliqnrent, Intact, l'n<la m incel
- Specific inspection feature inaccessible /not recreatatte e
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- l'a q <- 1J of 14 l'ITT SPf'T Cl! TI STirlG f.A Poli A T(iH Y M t r i t ut. . I r e g.e r (a ori_ ,S u en..i r y Attritute l'* i ne.g cr e i on Classifacaticn Inspectinri Tyie __ re n tie <in. Pr,imary,Inppertinn Featurcs C." A ' s - nieunt Support"., Co l orin s I'l~ l r SI'rCT f D Torqua, r.pa r i nq , t eriq t h, emt erfelcel l enq t li, CI A's - Itunt e r l'i g* riq , llanqctr w.ia he r s , g t urnt-nes s , a nctio r projectinn, ClA's - f Lit f s elst Cerulu s t /
Catle l'a ri Itanqer s CI A 's - P-A-P Instsument P a p i riq tlangers CFA's - PSPI Purtwork fla nqe r s Cf' A 's - JCI Instrurent l'a pirup flanqe r s Petat Petection - '!< ' ' l'ec r ea t a t l e plount For Inst allat ieri of CFA's
- f. ora t e arul vesii) ?H Day' Cure llunter Ifat f neld P- A - l' FSP1 JCI notting - Connections Turn-of-Nut -
Not Ferreatatale Witnens & Recorel Data. (fike CFA's) nlount Calitrations - Torque wrenches, plount Thermometers, Not Recreatatile Visual, Cal / Verify per letter & procedure Itunt e r Feeler Ga mles .
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e DelGeorge Attachment C Program Results for Inspectors Performing Objective Inspections QC Inspectors Passing QC Total No. of Acceptance Criteria Inspectors Inspectcrs At At Did Not Pass Qualification Feinspected fer 3 Mo. 6 Mo. Total Threshold Indeterminate Subjective Inspections (3 Hunter 20 --
20 -- --
20 Hatfield Electric 17 --
17 -- --
17 Pittsburgh Testing 9 --
9 -- --
9 Procrar Fesults for Inspectors Ferformine Sub$cetive Inspecticns QC Inspecters Passing Cc Total No. of Acceptance Criteria Inspectors Inspecters At At Did rot Pass Qualification Feinspected for 3 Mo. 6 Mc. Tctal Thresnold Indete rr.inate f l ) Sut]cetive Inspectione(3)
Hunter 16 --
16 --
1 17 Hatfield Electric 7 --
7 --
1 E Pittsburgh Testing 10 1(2) 1 1 11 2 14 Note: (1) Inspectors failed to meet the acceptance criterion at the end of the first 3 renth period and had no mere reinspectable work. A substitution was made in accordance with Program requirements.
(2) One inspector unacceptable for the first and second 3 month period. All his work was reinspected. Program expansion was implemented, resulting in all in spectors qualified to perform visual welding being reinspected (4 total). A1:
of the added inspectors met the Program acceptance criterion for the first 3 month period.
(3) The total of Hatfield Electrie inspectors reinspected was 23 (15 with objective inspections only, 6 with subjective inspections only, and 2 with both objective and subjective inspections). The total number of Hunter inspectors reinspected was 22 (5 with objective inspections only, 2 with subjective inspections only, and 15 with both objective and subjective inspections. The total number of PTL inspectors reinspected was 23 (9 with objective inspections only and 14 with subjective inspections only).
De1 George Attachment D Process for Determining the Effectiveness i of a Contractor's inspector Qualification (
Program i
\
S First 3 months of inspections for en inspector are reinspected I A i N t
Reinspect.ons meet Yes applicable critenon 2 (90% or 95' )
ir No S
An additional 3 months of inspections reinspected i s 1f Reinspections meet Yes applicable critetton ;
(90% or 95%)
i ,No For the stes(s) that criter6on was not met:
100% reinspection forinspector plus 50% increase of number of inspectors for contractor s %
Mave all No inspectors for the contractor
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been selected?
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' S
, y,, Contractorinspector l qualificallon program jgge.e of controClor's ' ' '
,,,,, effective when all of g, g the selected inspec.
tors have been reveewed l t s s (
., p - , . , y w.*y ,w
T DalGeorge Attachment E Reinspection Results
~
Hatfield Eicctric A. Results by Inspection Type Reinspection Results (Acceptable / Total)
M Les el 11 Rei .spectio, Third-Party Review Subjective 88.6% 92.8 %
(24,402/27,533) (25,552/27,53S)
Objective 96.5% (2)
B. Results by inspection Attribute initial Sample Period Expansion Sarnple Period No. of People Final 9a No. of Peopic Final to Attribute Reinspected Acceptable Reinspected Acceotab!e
- 1. Visual weld (Subjectis e) 8 92.3% (1) (1)
- 2. Conduit 6 97.6 % (1) (1)
- 3. Terminations (Objective) 5 99.9 % (1) (1)
- 4. Equipment setting 0 0% (1)
. (Objective) (1)
- 5. A325 bolting i 100.0 % (1)
(Objectis e) (1)
- 6. Equipment modification 3 100.0 % (1)
(Objective) (1)
- 7. Conduit as-built J 95.9% (1)
(Objective) (1)
- 8. Cable Pan hangers 2 95.5% (1) (1)
(Objective)
- 9. Cable Pan 1 100.0 % (1)
(Objective) (1)
Notes
'Results are cumulative. 3,136 observed discrepancies were reinspected by third-party inspectors.
(1) Not required (2) Not applicable
r
\
DalGeorge Attachttent E Page 2 of 7 Detailed Inspector Results Hatlicid Electric
~
Attributes inspector No. I No.2 No.3 No.4 No. 3 No.6 No.7 No. 8 No.9 A 833/S63 - - - - - - - -
B - - - - - -
4795/4974 - -
C 630/712 - - - - - - - -
D -
80/SO 63S/638 (1) 8/S - - - -
E 10554/11501 187/lSS 48/43 - - - - - -
F -
178/179 72/72
~
2/2 - - -
G 1132/1211 3S6/401 544/546 - -
1/1 - - -
H - - - - - -
3985/4112 - -
1 4462/4701 - - - - - - - -
3 -
639/661 - - - - - - -
K -
1256/12S4 - - - - - - -
L - - - - - -
M - - -
705/742 -
10952/11457 - -
N 33SI/34S9 - - - - - - - -
O 50/50 - - - - - - - -
P - - - - - -
2001/2081 - -
Q - - - - - -
481S/5055 - -
R - - - - -
S - -
11734/12205 - -
T - -
2753/2S79 - -
U -
1917/2014 - -
6473/64SO (2) -
24/24(2) - - -
V - - - - - -
W 4510/3011(3) - - - -
3S$t/4034 SC/10 TOTAL 25552/2753S 2726/2793 7775/7734 -
8/S 27/27 42955/44777 4559/4776 80/80 Notes No expanded sampling was required; a substitution (W) was made for (C) in Attribute No. I because (C) f ailed the first 3-month period but had no further inspections to reinspect.
Attribute 1 - Visual weld .
A* tribute 2 - Condait Attribute 3 - Terminations Attributt 4 - Equipment setting Attribute 5 - A325 bolting Attribute 6 - Equipment modification ,
Attribute 7 - Conduit as-built Attribute 8 - Pan hangers Attribute 9 - Pan I
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DelGeorge Attachment E Page 3 of 7 NOTES:
- 1. Upon review of reinspection report for equipment setting for Inspector "D", it was found that the reinspection had been performed on an installation which has been reworked since the time of the original inspection, thereby making reinspection of the original inspector "not recreatable".
As a result of this, the results for Attribute 4 reported in the January 12, 1984, report have been removed in accordance with Program requirements.
- 2. Upon review of reinspection reports for equipment modification, it was found that the summary tabulation for Inspector "U" had been entered into equipment setting rather than equipment modification tabulation. As a result of this, the results reported for Attribute 4 in the January 12, 1984, report have been removed and located appropriately in Attribute 6.
- 3. Upon completion of the initial accumulation of data, Inspector "W" failed to achieve the subjective acceptance criterion. Upon further review of re rejected for "not per detail" and " arc-strikes" ports it was found that orts had been improperly graded; for example,some the rep'not per detail" was a condition where excess weld was present and
" arc-strike" reported as a visual weld discrepancy was not present on the weld itself. After correction of these items, the results were accumulated as tabulated above.
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e o De1 George Attachment E Page 4 of 7 l
Reinspection Results Hunter A. Results by inspection Type Reinspection Results (Acceptable / Total)
Type Level 11 Reinspection Third-Party Review Subjective 96.3% 97.0 %
(3604/3725) (3616/3725)
Objective 99.C% (2)
B. Results by inspection Attribute Initial Samole Period Expansion Samole Period No.of No. of Peop:e Final % People Fina! %
Attribute Reinscected Acceotable Reinspected Acceptab:e
- 1. Visual welding 17 97.0 % (1) (1)
(Subjective)
- 2. Documentation (Objective) 20 93.9 % (1) (1)
- 3. Hardware (Objective) 17 99.3% (1) (1)
Notes
'Results are cumulative. 121 observed discrepancies were reinspected by third-party inspectors.
(1) Not required (2) Not applicable I
l L
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DelGeorge Attachment E Page 5 of 7 Detailed Inspector Results Hunter Attributes Inspector No. I No.2 No.3 A 47/48 -
B -
14/14 134/133 C 34/34 D 1181/1136 -
33/33 101/102 E -
2S3/3Cl 20S3/2144 F 205/214 61/64 G 40/41 25S/265
!!6/129 161/161 H 49/55 21/21 1 19/19 12/12 315/319 47/47 3 - 129/133 K 2195/2269 7336/7393 33a/344 250/234 L
273/273 IS6/190 M -
366/366 204/206 N -
126/130 331/339 0 -
239/294 903/921 P 416/442 1246/1253 249/263 3141/82Ik Q 333/392 925/935 R 6315/6331 5355/5372 232/237 3503/8520 5 S1/S1 131/131 329/33l T - 949/952 U 1789/1304 6243/6323 S03/S22 3671/3739 V 3004/3032 62/66 -
TOTAL 3616/3725 36191/36632 32749/32992 Notes .- .
No expanded sampling was required; a substitution (V) was made for (H) because to reinspect.(H) failed the first 3-month period but had no further inspt ctio Attribute 1 - Visual welding Attribute 2 - Documentation Attribute 3 - Hardware l
l L ;
e a 6 DelGeorge Attachment E Page 6 of 7 Reinspection Results Pittsburgh Testing A. Results by inspection Type Reinspection Results (Acceptable / Total)
Tyne Level 11 Reinspectio i Third-Party Review Subjective 33.7%
85.3% (3)
(3,133/6,137) (5,232/6,137)
Objectn e 93.9% (2)
B. Results by inspection Attribute Initial Samole Per:cd Exoansion Samo!e Period No. of No.of People Final % People Final %
Attricute R e.nscected Acceptable Reinscected Acceotable
- 1. Visual welding 14 36.0 (Sub;ective) 2 77.0(3)
- 2. Concrete expansion 9 95.9 (1) (1) anchor (Objective)
Notes
'Results are cumulatne. 999 observed discrepancies were reinspected by third-party inspectors.
(1) Not required (2) Not applicable (3) 100% of the work was inspected for the two inspectors in the espanston sample period. Discrepanc:es had no design signi!.cance.
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, o DelGeorge Attachment E Page 7 of 7 Detailed Inspector Results Pittsburgh Testing Attributes insoector No. I No.2 A -
1759/2125 B -
442/437 C -
35/63 C(exp) -
27/23 D -
13/13 E 522/524 -
F -
306/616 C -
11/12 H -
7/7 I -
$17/558 3 -
749/929 J(exp) -
377/497 K 299/300 -
L 377/331 -
M 1057/1033 -
i N 359/374 -
0 l 975/10C3 -
l' P 933/935 -
Q 333/893 -
R 46/46 -
5 -
125/131 T -
63/69 U -
432/482 V -
73/79 4 -
31/31 TOTAL 595t/6016 5232/6137 Notes
- Espanded sampling was required. T, U, V, and W were added in Attribute 2 due to failure of J.
The "exp." designation represents the expansion of an inspector's sample period when the acceptable threshold was not met.
Attribute 1 - Concrete expansion anchors Attribute 2 - Visual 'velding 6