ML20113D365

Update to Results of Quality Programs for Const of Clinton Power Station

ML20113D365
Person / Time
Site:	Clinton
Issue date:	04/30/1985
From:	Hall D ILLINOIS POWER CO.
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Download: ML20113D365 (218)

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Update to Results of Quality Programs for Construction of Clinton Power Station NRC Docket No. 50-461 t

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ILLINDIS r ,

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L j POWER April 1985 i

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t UPDATE TO RESULTS OF QUALITY PROGRAMS FOR CONSTRUCTION OF CLINTON POWER STATION NRC DOCKET NO. 50-461 ILLINOIS POWER COMPANY APRIL 1985 1

Approved by:

D. P. Hall -

Vice President - Nuclear

EXECUTIVE

SUMMARY

A. INTRODUCTION This report describes and evaluates the major programs and actions implemented to provide confidence in the quality of Clinton Power Station construction.

The quality of Clinton Power Station construction can originate only from two fundamental sources: the strong commitment of Illinois Power Company management to a quality product and the dedication to a quality product of each individual employee. Through these sources, Illinois Power Company has built high quality directly into the Clinton Power Station. In addition, the programs and actions described herein have operated as a systematic, multi-level composite to reinforce and verify the quality built into the Clinton Power Station. The programs and actions described herein have involved both massive efforts toward improvement of Clinton Power Station quality assurance organization activities and equally massive efforts to improve directly the performance of the Clinton Power Station construction work itself.

The major programs and actions described herein are as follows:

1. Quality Assurance Program - From the outset of the project, Illinois Power Company has implemented and continued its efforts to maintain its Quality Assurance Program in accordance with 10 CFR Part 50, Appendix B.

2. Recovery Programs.- In response to specific deficiencies identified during 1981 and 1982, Illinois Power Company stopped work in nine major func-tional areas of construction and implemented extensive recovery programs.

3. Programmatic improvements - Subsequently, Illinois Power Company instituted a broad range of fundamental programmatic improvements.

These programmatic improvements resulted in substantial upgrading of the management and experience level of personnel, quality assurance organizations, nonconformance and corrective action programs, and control of construction and inspection activities.

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4. Overinspection Program - Illinois Power Company implemented a major program for reinspection of safety-related, augmented class D (radioactive waste), and fire protection structures, systems', and components in those areas related to the stop work actions. In practice, this has resulted in three separate quality inspections for virtually all sach reinspectable structures, systems, and components.

5. Record Verification Program - Illinois Power Company implemented a Record Verification Program which calls for 100% review of completed quality records by the constructor, Baldwin Associates, followed by a 20%

sample review by Illinois Power Company Quality Assurance.

6. General Assessment and Corrective Action Activities - Throughout the course of Clinton Power Station construction, Illinois Power Company has maintained or has initiated aggressive assessment and corrective action activities, which augment and complement the programs and actions mentioned above. These activities include the 10 CFR Section 50.55(e) and Part 21 reporting systems, the Material Assurance Program, responses to the Nuclear Regulatory Commission inspections, third-party audits, systems for addressing employee quality concerns, the configuration control system, and the Management Corrective Action Request Program.

B. CLINTON POWER STATION QUALITY-RELATED PROGRAMS IN PERSPECTIVE The size and complexity of the Clinton Power Station project are such that no summary report could impart a true sense of the efforts that Illinois Power Company has undertaken to assure Clinton Power Station construction quality. In an attempt to aid the reader, the text of this report is structured to present summaries of the evaluations of the major quality-related programs. Detailed information supporting the evaluations discussed in the text is provided in the appendices contained in a separate volume.

This report evaluates the results of each of the six major classes of Clinton Power _

Station quality-related programs and actions. When these program 3 and actions w

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are . considered on a collective basis, several important overview observations

-emerge:

e The -quality-related - programs and actions are designed to identify, document, and correct deficiencies in Clinton Power Station construction.

e While error-free construction may be a goal, it is neither attainable nor required.

e The Clinton Power Station quality-related programs and actions have been effective in identifying and documenting deficiencies.

e The deficiencies identified have not had adverse implications for Clinton Power Station safety.

e Individual deficiencies have been corrected and effective actions have been taken to preclude their recurrence.

e Illinois Power Company has been diligent in examining the root causes of deficiencies and in effecting substantial programmatic changes to remedy those causes.

The magnitude of the Clinton Power Station project has produced quality-related programs and actions of correspondingly large scope. Reinspections conducted to date show high rates of conformance with design drawings and specifications for structures, systems, and components and have not resealed any nonconformances which have safety significance. The overall trend is to even higher rates of conformance, and, in certain judiciously selected areas, it may soon be possible to relax some verification programs where regularly established quality programs have been demonstrably effective. However, Illinois Power Company recognizes that in certain areas the verification programs have been beneficial, and these aspects of the programs will be maintained to ensure that I!!inois Power Company will continue to receive the beneficial results of these programs, i

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l C. THE CLINTON POWER STATION QUALITY ASSURANCE PROGR AM lilinois Power Company management's strong commitrhent to assuring the quality of Clinton Power Station construction is reflected in the establishment, maintenance, and continuing improvement of the Clinton Power Station quality assurance organization. Illinois Power Company management is actively involved in ensuring the independence and effectiveness of the Illinois Power Company quality assurance organization and providing leadership to ensure that all employees produce and assure a quality product.

The Illinois Power Company Quality Assurance Program, which was established in conformance with 10 CFR Part 30, Appendix B, includes three basic types of activities that are fundamental to achieving adequate confidence in the quality of Clinton Power Station construction:

e Activities affecting quality are conducted in accordance with controlled written instructions, procedures, and drawings by appropriately trained and qualified personnel to ensure that these activities are performed correctly in the first instance.

e Activities affecting quality are subject to inspection by appropriately trained and qualified persons, who did not perform the activities inspected, to verify that the activities have been pericrmed correctly.

e All aspects of the quality assurance program are subject to a comprehensive system of audits and surveillances by appropriately trained and qualified personnel, who do not have direct responsibility for the aspects audited, to verify that those aspects of the quality assurance program are properly implemented.

Because quality-related problems inevitably arise during construction, the Clinton Power Station Quality Assurance Program includes measures to ensure that conditions adverse to quality are promptly identified and corrected, the cause of ,

any such condition is determined, and action is taken to preclude its recurrence.

The Clinton Power Station Quality Assurance Program has been subjected to ES-4 _

numerous audits by both cognizant Clinton Power Station project personnel (see Appendix B) and third parties (see section VII.E). The results of these audits indicate that activities affecting Clinton Power Station quality, on the whole, have been conducted in accordance with applicable requirements, and numerous specific and programmatic corrective actions have been taken to resolve problems identified by those audits. in short, the audit results portray a quality assurance system which is not problem-free, but which is functioning effectively.

D. RECOVERY PROGRAMS Prior to 1981, the type of deficiencies identified during Clinton Power Station construction were similar in kind and quantity to those expected during

, construction of any commercial nuclear power plant. Thereaf ter, the Nuclear Regulatory Commission, Illinois Power Company, and its contractors identified deficiencies in the implementation of the Clinton Power Station Quality Assurance Program that led Illinois Power Company and Baldwin Associates to i stop the affected work activities. The Nuclear Regulatory Commission took confirmatory action in regard to the stop work actions. Illinois Power Company l- then developed and implemented specific recovery programs to address and correct the deficiencies for each affected area of work.

l While the specific corrective actions varied with the area of activity affected,

! there were certain common denominators within these actions. The major types l of actions included upgrading of procedures to assure complete and precise direction for work and inspections, training of personnel to improved procedures, reduction of inspection backlogs, accelerated closure of open nonconformance reports, and, where indicated, the performance of additional inspections in the affected area of activity. After Illinois Power Company implemented the corrective action in each recovery program area, the Nuclear Regulatory

! Commission conducted inspections to verify effective implementation and gave its concurrence to lif ting the stop work actions. By the end of 1983, all stop work actions had been lif ted and work had resumed in all affected areas at Clinton Power Station in addition, Clinton Power Station project audits and surveillances of the recovery programs were performed and, where appropriate, additional corrective actions were taken to ensure that effective implementation continued.

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E. PROGRAMMATIC IMPROVEMENTS 6

Illinois Power Company implemented extensive programmatic improvements in four key areas: (1) management and experience level of personnel; (2) quality assurance organizations; (3) nonconformance and corrective action programs; and (4) control of construction and inspection activities.

In the area of management and experience level of personnel, Illinois Power Company hired a new vice president with extensive nuclear experience to direct key nuclear activities, including quality assurance. It also hired new managers for: Nuclear Station Engineering, Quality Assurance, Nuclear Training, Project Management, Nuclear Support, and Nuclear Planning. In addition, the Illinois Power Company and Baldwin Associates organizations were augmented by more than two hundred experienced Stone & Webster Engineering Corporation personnel. Baldwin Associates also hired a new Manager of Quality and Technical Services and a new Project Manager. In addition, the Baldwin Associates organization was restructured to establish dedicated groups for nonconformance review, traveler review, and training. Illinois Power Company nuclear project personnel were consolidated and moved to the site. Both Baldwin Associates and Illinois Power Company issued policy statements which admonish against intimidation and encourage employee reporting of quality concerns. Both Illinois Power Company and Baldwin Associates established training departments to centralize project training and to establish and upgrade training programs for orientation and job-specific training for all site personnel.

Illinois Power Company and Baldwin Associates also substantially increased the size of their quality assurance organizations. As of July 1984, the Illinois Power Company Quality Assurance organization had grown from 25 in 1982 to more than 300 persons, while the Baldwin Associates Quality and Technical Services organization had grown from 191 in 1982 to more than 900 persons. The Illinois Power Company Quality Assurance organization was restructured to provide a supervisor and staff for each major quality assurance function. In practice, Illinois Power Company Quality Assurance became more involved in all levels of daily project activities, and the number and frequency of audits and surveillances ES-6 L

were significantly increased. Finally, a full-time quality assurance / quality control training staff was established, the quality assurance / quality control training program was augmented, and existing ins'pector certifications were verified.

In corrective action programs, emphasis was placed on increasing control over

-non. onformance identification and documentation, tracking nonconformances by computer to ensure timely corrective action, and notifying management of delay in resolution cf conditions adverse to quality and of the status of corrective actions. The corrective action program was upgraded to include computer-assisted trending of conditions adverse to quality, analyses of individual conditions to identify root causes, and notification to senior management of the results of trend analyses.

Improvements in the controls for construction and inspection activities have concentrated on upgrading the traveler system, project procedures, and measures ,

for document control. Among the major steps were establishment of formal constructicn and engineering reviews of travelers end a dedicated Baldwin Associates traveler review group. The Illinois Power Company Quality Assurance Department reviewed Baldwin Associates procedures and instructions to ensure conformance with quality assurance requirements and clarity of direction.

Document control was enhanced by establishment of a computer-assisted traveler l tracking system, an automated system to track controlled documents, and field l satellite- document stations that maintain updated controlled documents for reference at locations convenient to field workplaces.

Illinois Power Company's ongoing process for audits, surveillances, and third party i audits indicate that the programmatic improvements have been implemented I

effectively. Taken together, this array of programmatic improvements has ensured that Clinton Power Station quality-related activities receive greater attention and more effective execution. These improvements have enhanced confidence in quality and, thus, the success of the project.

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F. OVERINSPECTION PROGRAM l The Overinspection Program applies to safety-related, augmented class D (radioactive waste), and fire protection items in those areas in which stop work j actions were issued. Both old work and new work are covered. For purposes of evaluation, July 26, 1982, was selected as the point of demarcation between old and new work (see subsection V.C.4). The Overinspection Program provides for additional inspections of completed and previously inspected work on two levels:

a sample inspection by the Baldwin Associates Field Verification Group and a subsequent sample inspection by the Illinois Power Company Overinspection Group. As of December 31, 1984, both the Field Verification and Overinspection l[

Groups have performed inspections of nearly 100% of all inspected lots. This has resulted in three inspections for virtually all reinspected work within the scope of the Overinspection Program.

Illinois Power Company has performed an evaluation of the results of the Overinspection Program. This evaluation addressed five issues: (1)whether the available data from the program are sufficient to support reliable inferences as to the quality of Clinton Power Station construction, (2) whether the noncon-formances identified by the program would have been safety-significant had they remained undetected by the Overinspection Program, (3) whether the as-constructed plant shows a high rate of conformance with design drawings and specifications,(4) whether the quality of new work differs from that of old work, and (5) whether the results can be applied to work not inspected under the program.

For the purpose of this evaluation, data from the Overinspection Program through December 31, 1984, were used. As of that date, more than 2 million attributes Q had been subjected to inspections under the Overinspection Program. In terms of the number of items within the scope of the program, approximately 12% of the R total number of items have been inspected under the Overinspection Program.

Illinois Power Company's analyses show that these data are sufficient to permit reliable conclusions to be drawn regarding the quality of Clinton Power Station construction.

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Engineering evaluations of the nonconforming conditions identified by the Overinspection Program were conducted to determine if any such conditions would have been safety-significant if they had remained undetected by the Overinspection Program. These evaluations are Illinois Power Company's primary basis for veritication of Clinton Power Station construction quality. All nonconformances identified by the Overinspection Program were evaluated by the Clinton Power Station architect-engineer, Sargent & Lundy. The results of many evaluations were obviously not significant (e.g., cosmetic defects such as superficial arc strikes). Others required detailed engineering analysss to examine the nonconforming condition and its relationship to performance of intended safety functions. No nonconforming condition was safety-significant; that is, even if the norconformances were to have remained unidentified by the Overinspection Program, it would not have resulted in a loss of capability of a structure, system, or component to perform its intended safety function. The results of the engineering evaluations for safety-related structures, systems, and components are summarized as follows:

Overinspection Program Evaluation Nonconforming Attributes Attributes identified By Safety-Significant inspected Overinspection Nonconformances 2,402,471 48,745 0 R in addition to the primary engineering evaluations,. Illinois Power Company performed quantitative evaluations of the results of the Overinspection Program to determine whether the as-constructed plant shows a high rate of conformance with design drawings and specifications. The overall conformance rate for field verification inspections is high (97.6%). The rate for the subsequent R overinspections by Illinois Power Company Quality Assurance is still higher (98.8%), thereby indicating the effectiveness of the field verification level of R inspection. Conformance rates were also calculated on the basis of disciplines and commodities. The results of these evaluations also show generally high conformance rates. The results of the evaluation also demonstrate that the conformance rate for new work is generally higher than for old work, thus reflecting the favorable effect of the recovery program actions and ES-9

programmatic improvements implemented since 1982. Finally, favorable inferences for the quality of items not inspected under the Overinspection Program (e.g., nonrecreatable attributes and inaccessible items) can be drawn from the results for items inspected within the program.

In broadest terms, the Overinspection Program confirms that the quality of Clinton Power Station construction is adequate. The primary measure of confidence in overall plant safety is gained from the engineering evaluations of the nonconformances identified by overinspection. None of the nonconformances would have caused a loss of capability of any structure, system, or component to perform its intended safety function if uncorrected by the Overinspection R

Program. In certain areas where favorable results are most apparent, it may be possible to relax or eliminate selected program elements. For present purposes, it is sufficient to conclude that the operation of Illinois Power Company's Quality Assurance Program, coupled with its additipnal recovery programs, programmatic improvement actions, and Overinspection Program, provides a high level of confidence in the quality of Clinton Power Station construction.

G. RECORD VERIFICATION PROGRAM Illinois Power Company implemented the Record Verification Program to verify the adequacy of Clinton Power Station construction quality assurance records generated before the stop work actions and to provide additional assurance as to 4

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. the adequacy of records generated after the stop work actions. The reviews conducted under the program apply to quality assurance records for all completed Baldwin Associates construction work packages and site-generated purchase order documentation packages for safety-related, augmented class D (radioactive waste), and fire protection structures, systems, and, components. These reviews are conducted in addition to the activities governing records under the normal lilinois Power Company Quality Assurance Program. These reviews are conducted on two levels: Baldwin Associates' Document Review Group reviews all records within the scope of the program for acceptability, and Illinois Power Company's Records Review Group reviews a random sample of approximately 20% of the records reviewed by the Baldwin Associates' Document Review Group. A document exception list is prepared and maintained for each work package or ES-10

purchase order reviewed. The document exception list records the results of the review, including any record deficiencies disclosed during the review.

Illinois Power Company initiated an evaluation of the results of the Record Verification Program as of March 3,1985. This evaluation consisted of three R elements: (1) the safety significance, if any, of potential hardware-related nonconformances resulting from record reviews;(2) the implications for hardware quality, if any, of record deficiencies identified in record verification reviews; and (3) the basis for confidence in the acceptability of Clinton Power Station construction quality assurance records.

When potential hardware-related nonconforming conditions are identified as a

, result of record reviews, nonconformance reports are initiated. During the course of the record verification review, more than 58,000 record packages, which include more than 7,600,000 attributes, have been placed in review, and 890 R nonconformance reports have been initiated. Of these,214 had a potential safety implication and were subjected to engineering evaluation by Sargent & Lundy.

Each of these nonconformance reports was reviewed against the pertinent design criteria, as set forth in the applicable codes or standards, to determine whether the nonconforming conditions identified were safety-significant; that is, if a particular nonconforming condition had remained undetected by the Record Verification Program, it could have resulted in a loss of capability of a structure, system, or component to perform its intended safety function. None of the nonconforming conditions in the 214 nonconformance reports were found to be R safety-significant. In round numbers, the results of the engineering evaluation are summarized as follows:

Record Verification Program Engineering Evaluation Nonconformance Nonconformance Reports Reports With Record Resulting Potential Attributes Deficiencies From Record Implications Safety-Significant Reviewed Identified Reviews For Safety Nonconformances 7,600,000 147,000 890 214 0 R ES-Il

4 The record deficiencies identified in the Record Verification Program were reviewed to determine whether any had adverse hardware implications. The rates of record deficiencies for the program as a whole, ndw work and old work, were low (about 1.9% for the entire program). The rate of deficiencies for new work is [

less than for old work by about a factor of two - an apparent reflection of Illinois Power Company's implementation of improvements and corrective actions in regard to quality records subsequent to the stop work actions. Examination of deficiency rates with respect to individual disciplines, items of work, and types of attributes indicated no outstanding trends that would warrant further action.

Record deficiency resolutions also were reviewed to confirm that none were indicative of adverse hardware quality. This review confirmed that the resolutions had no adverse implications for hardware quality and that the only record deficiencies with a potential for hardware implications were those for which nonconformance reports had been initiated. As stated above, the Sargent &

Lundy engineering evaluations of nonconformance reports indicated no instances of safety significance.

Confidence in the acceptability of Clinton Power Station construction quality assurance records is further bolstered by the results of Illinois Power and Baldwin Associates audits and surveillances, third-party audits, and Nuclear Regulatory Commission inspections. While specific open items have been identified through these audits and inspections, Illinois Power Company has taken or will take appropriate corrective action to ensure that record verification program activities will continue to.be effectively implemented.

On the basis of the evaluation in this report:

e None of the potential hardware-related nonconformances resulting from record reviews are safety-significant. That is, if the nonconforming conditions were left unidentified by the Record Verification Program, no loss of capability of a structure, system, or component to perform its intended safety function would have resulted.

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e The other record deficiencies identified in the program and their resolutions have no adverse implications for hardware quality.

e There is adequate confidence in the acceptability of the Clinton Power Station construction quality assurance records.

H. GENERAL ASSESSMENT AND CORRECTIVE ACTION ACTIVITIES Throughout the course of the Clinton Power Station project, Illinois Power Company has maintained or initiated many assessment and corrective action activities, which operate in conjunction with the normal Quality Assurance Program, the recovery programs, programmatic improvements, Overinspection Program, and Records Verification Program, to buttress and complement Illinois Power Company's level of confidence in Clinton Power Station construction quality. Among these activities, the following programs and actions have particular importance in maintaining compliance with regulatory requirements and in providing management with effective tools to ensure Clinton Power Station construction quality.

With regard to regulatory compliance, the activities associated with 10 CFR Section 30.53(e) and Part 21 reporting and the responses to Nuclear Regulatory Commission inspections warrant emphasis. In the case of the reporting systems, Illinois Power Company's practice has been to employ these systems for providing the Nuclear Regulatory Commission with early notice and continuing information as to potentially reportab.le conditions and to ensure that corrective actions are timely and responsive. Illinois Power Company's responses to Nuclear Regulatory l Commission inspections have served to focus management attention on ensuring

effective corrective action and on maintaining compliance with regulatory j requirements. The decline in noncompliances found by the Nuclear Regulatory Commission over the past several years serves as a measure of Illinois Power Company's improved performance in this area.

Third-party audits conducted by the Joint Utility Management Audit team, Lapp-Rice-Staker consultants, the American Society of Mechanical Engineers, and the Institute of Nuclear Power Operations have augmented the Nuclear Regulatory ES-13

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I Commission inspections- to provide an additional management tool for Quality l Assurance Program improvement and continued effective implementation. l l

i As a result of experience with several findings in a 10 CFR Section 50.55(e) investigation involving material traceability, Illinois Power Company management implemented a Material Assurance Program for all safety-related, augmented

! class D (radioactive waste), and fire protection activities at Clinton Power Station. This program encompasses an evaluation of procedures, their implementation, and audit and surveillance plans and schedules. Existing audit and surveillance reports related to material issues were reviewed and studies of l record reviews of material purchases were conducted to resolve any open materials-related issues. The Material Assurance Program provides additional y confidence that Clinton Power Station materials will meet design requirements.

Illinois Power Company developed and implemented a Configuration Management I

Program consisting of four elements: configuration control, status accounting, v'erl'iication, and management training. This program provides an additional effective management tool to ensure that Clinton Power Station structures, l systems, and components conform to the approved design, that their physical characteristics are properly reflected in technical, procedural, and training documents, and that the plant configuration will meet regulatory requirements and commitments. ,

Illinois Power Company management has instituted two additional programs that provide mechanisms for r.alsing quality-related issues for management attention and action. The first of these consists of three systems for addressing employee quality concerns: the quality concern telephone hotline, the Executive Vice President's Quality Report System, and the SafeTeam project. In addition, Illinois Power Company management has an open-door policy under which any employee may voice quality concerns and, of course, any employee may report his concerns to the Nuclear Regulatory Commission. Altogether, these systems have been effective in encouraging employees to express concerns and in giving visibility to Illinois Power Company's commitment to quality. The second of these is the Management Corrective Action Request System, which provides a mechanism for bringing specific quality issues to the attention of senior management for ES-14

immediate action or evaluation. The Management Corrective Action Request

-System also can be used to identify when previous corrective action proved inadequate or delinquent. That system has been u'ed s to effect high priority corrective actions when necessary and has augmented the effectiveness of the Clinton Power Station Quality Assurance Program.

I. CONCLUSION The programs and actions for quality-related activities provide multiple tiers of assurance for the quality of Clinton Power Station construction. Illinois Power Company's management has maintained its commitment to effective implemen-tation of the Quality Assurance Program, recovery programs, programmatic im-provements, Overinspection Program, Record Verification Program, and general assessment and corrective action activities. The evaluation of the results of the programs and actions presented in this report bear out their effectiveness.

Collectively, these programs and actions provide high confidence in the quality of Clinton Power Station construction.

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V. OVERINSPECTION PROGRAM IP established an Overinspection Program in 1982 to verify the quality of construction of CPS. All nonconformances identified by the Overinspection Program have been or will be reworked or determined to be acceptable as is.

This section presents an evaluation of the results of the Overinspection Program for CPS as of December 31, 1984. These results verify that construction of CPS would R have been of acceptable quality even if it is assumed that the nonconformances identified by the program had been left uncorrected by the Overinspection Program. R i

in analyzing the'results of the Overinspection Program, IP has relied primarily on an i engineering evaluation of the safety significance of the nonconformances identified by the program to verify that structures, systems, and components at CPS are capable of performing their intended safety functions. Secondarily, IP has performed a

! quantitative analysis of the results of the Overinspection Program to verify that the

QA Program for CPS has been effective in providing reasonable assurance that structures, systems, and components comply with design drawings and specifications.

Thus, IP has taken two different but complementary approaches to shcw that the results of the Overinspection Program verify that the quality of constructica of CPS is acceptable.

IP originally submitted the Overinspection Program plan to the NRC in a letter dated November 15, 1982. On December 3,1982, the NRC concurred with the intent of the Overinspection Program. A revision to the program was transmitted on December 20, 1982, and was acknowledged by the NRC on January 25,1983. A subsequent revision was transmitted on June 18, 1984. The discussion which follows is a brief summary of the Overinspection Program plan.

A. PROGRAM PLAN DESCRIPTION

1. Purpose The purposes of the Overinspection Program are to verify that the struc-tures, systems, and components within the scope of the program are l properly installed and to provide IP with assurance that BA is performing V-1

installation and inspection work that satisfies the applicable requirements of codes, standards, drawings, and specifications. These objectives are ac-complished by performing additional inspections of completed and inspected work, whether performed before issuance of the stop work actions in 1982 (old work) or after the stop work ctions were lif ted (new work). The inspections conducted under the Overinspection Program are in addition to those normally performed as part of the QA Program for CPS. Therefore, the Overinspection Program is a supplement to the QA Program and not a

- substitute for it.

2. Scope Ins'pections in the Overinspection Program focus on installation of safety-related, augmented class D (radioactive waste), and fire protection items in the following areas:

e Large bore piping e Small bore piping e Mechanical equipment e Structural steel e HVAC, as defined in the IP HVAC recovery plan e Electrical hangers e Electrical conduit and raceways e Electrical terminations e Electrical equipment e Electrical and mechanical instrumentation Other areas, such as concrete structures and masonry walls, are not subject to the Overinspection Program because no significant concerns have been identified in those areas.

3. Program Management IP QA is responsible for the direction of the Overinspection Program. .

Within IP QA, the Overinspection Group performs the activities necessary to execute program commitments. The BA portion of the Overinspection Program is executed by the Field Verification Group, which reports to IP V-2

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QA through the BA Manager of Quality and Technical Services. Over 200 full-time personnel are currently assigned to perform the supervisory, administrative, and inspection tasks required by the Overinspection Program.

4. Operation The program consists primarily of the elements described below,

a. Field Verification Inspections BA Quality and Technical Services performs inspections (termed " field verification" inspections) of a sample of completed and inspected work. If the results of the field verification inspections do not satisfy the acceptance criteria described in subsection V.A.5 below, the results are evaluated to determine the need for further inspections of the lot from which the sample was selected. These further inspections may be limited to those attributes for which the results of the sample mspections did not satisfy the acceptance criteria, or the entire lot ,

may be inspected. When the field verification inspection of a lot is complete, the lot is turned over to IP QA.

Nonconformances identified by field verification inspections are documented and processed according to approved procedures. These 4

procedures require that the nonconformances be res iewed and evaluated and that appropriate corrective action be taken in each case. When rework, repair, or replacement of plant hardware is required to correct a nonconformance, this work also is inspected and the results of the inspections are documented to provide assurance of acceptability.

b. Overinspections

! Following the completion of field verification inspections and turnover of the lot to IP QA, IP QA selects a sample of the work and conducts inspections (termed "overinspections"). If IP QA determines from the results of these overinspections that the sample of the work satisfies the acceptance criteria described in subsection V.A.5 below, the work l

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I L is considered acceptable. If the results of the sample overinspection do not satisfy the acceptance criteria, either the work is returned to BA for reevaluation and possible reinspection or IP QA may elect t R reinspect 100% of the remainder of the lot. For work returned to BA, reinspections may be limited to specific attributes that are identified through reevaluation as having an unacceptable level of deficiencies.

The relationship between overinspection and field verification inspections described above is graphically depicted in Figure V-1.

Nonconformances identified by field verification inspections are not

. subject to validation by the Overinspection Group. Instead, the Overinspection Group assumes that the nonconformances identified by field verification inspections are valid nonconformances, and it does not include them in the group of nonconformances identified by overinspection. Only nonconformances originally identified by overinspections are documented by the Overinspection Group. These nonconformances are processed according to the same approved procedures used for field verification inspections.

c. Departure Inspections in addition to conducting overinspections in series with field verification inspections, IP QA also has performed overinspections prior to field verification inspections by BA. These overinspections are termed " departure" inspections. Departure inspections were performed early in the Overinspection Program to enable 1,P to use overinspection personnel before BA began turning work over to IP QA in sufficient volume to make the program function efficiently.

Nearly 170,000 attributes were inspected by means of departure inspection. Of these, approximately 60,000 were subsequently R inspected by the Field Verification Group as of December 31, 1984, pursuant to the program described in subsection V.A.4.a below. None of these attributes were subsequently subject to the overinspections described in subsection V.A.4.b below. The relationship between V-4

departure inspections and field verification inspections is graphically depicted on Figure V-1.

d. 100% Inspection by IP QA Overinspection Group in certain instances after October 1984 IP QA has elected to perform 100% inspection of specific lots or specific types of items. IP QA decisions to conduct 100% inspection are in two categories.

First, as discussed previously, for some lots which have been rejected upon completion of sample inspection by IP QA, the lot has not been returned to BA for reevaluation and possible reinspection. Instead, IP QA has elected to reinspect 100% of the remaining items in the lot. In these cases, the tot is normally small, the amount of reinspection necessary to complete the lot has not been significant, and it has been more elficient to complete the reinspection using IP QA personnel. R Second, in some cases IP QA has elected to perform 100% overinspec-tion of lots or types of items which have not been inspected by BA.

When IP QA performed 100% inspection on this basis, no field verifi-cation inspection is performed and no sample inspections are performed. This is the case for structural steel as is discussed in paragraph C.3.d, below. Other examples include old work items in which large numbers of items are not installed, thus providing small lots which can be efficiently inspected at the 100% level because sample sizes approach total lot size.

5. Sampling Inspection Criteria The sampling procedures used by BA and IP in the Overinspection Program are based on sample sizes and acceptance criteria derived from MIL-STD-10$D, a commonly used industry standard for inspection of samples from lots. Attributes inspected under the Overinspection Program are characterized as either critical or noncritical. For critical attributes (i.e.,

those which, if nonconforming, could adversely affect the safety of the installation) the acceptance quality level is set so that 95% confidence exists that at least 95% of the critical attributes in the entire lot under V-5

investigation are conforming. The acceptance quality level for noncritical attributes is set so that 95% confidence exists that at least 85% of the noncritical attributes in the entire lot under investigation are conforming.

It should be noted that although the Overinspection Program was designed for sampling inspections, as of December 31,1984, due to the small size of R the lots and the stringency of MIL-STD-105D and the acceptance criteria, BA has inspected 100% of all but 10 of its lots and IP has inspected 100% of R

all but 19 of its lots.

6. Control

a. Procedures The Overinspection Program is implemented in accordance with IP- and BA-approved procedures and instructions. Inspections are performed using BA-developed inspection checklists which identify the specific attributes to be inspected. These checklists were initially reviewed by S&L and by Stone & Webster to ensure that the checklists contained adequate inspection requirements, including the proper identification of critical attributes. Revisions to the checklists are reviewed and accepted by S&L. The checklists and revisions also are subject to review and approval by IP QA.

b. Personnel Personnel performing the field verification inspections and over-inspections are trained and certified under a CPS-specific training program.

c. Records The results of the inspections are recorded and retained. Noncon-formances identified during the Overinspection Program are controlled as described in section V.A.4, and documents generated by the Overinspection Program are tracked from generation through placement in the record vault to provide a management tool for control of the Overinspection Program.

V-6

7. Audits and Surveillances Activities under the Overinspecticn Program are subject to several layers of.

audits and surveillances. For example, BA field verification activities are subject to surveillances by IP QA overinspection personnel and to audits and surveillances by IP QA. Similarly, IP overinspection activities are subject to IP QA audits and surveillances. These audits and surveillances provide continuing assurance that Overinspection Program activities are conducted in accordance with procedures and provide IP management with further confidence in the results of the Overinspection Program and the quality of CPS.

8. Summary As a result of the Overinspection Program, systems, structures, and components must pass through three levels of formal inspections before it is deemed acceptable: (1) an initial inspection of hardware under the normal BA QA Program, (2) the sample field verification inspection by BA Quality and Technical Services, and (3) the sample overinspection by IP QA. This redundancy verifies that systems, structures, and components comply with applicable installation requirements. Additionally, the Overinspection Program is conducted by trained and certified QA personnel in accordance with approved procedures, instructions, and checklists; the results of the program r.re documented and evaluated; and the program activities are subject to QA audits and surveillances.

B. PROCESS FOR EVALUATING RESULTS The results of the Overinspection Program were evaluated from several perspectives. Each of these is described below.

First, the results of the Overinspection Program were evaluated to determine whether sufficient data from the Overinspection Program are available to permit reliable conclusions to be drawn regarding the quality of construction of CPS.

The results of this evaluation are discussed in subsection V.C.1 below.

V-7

Second, the results of the Overinspection Program were subjected to an engineering evaluation to determine whether any of the nonconformances identified by the Overinspection Program would have been safety-significant if lef t unidentified by the pr6 gram. The purpose of this evaluation is to verify that structures, systems, and components at CPS are capable of performing their intended safety functions. The results of this engineering evaluation are discussed in subsection V.C.2 below.

Third, the resuits of the Overinspection Program were evaluated quantitatively to verify that the QA program for CPS has been effective in providing reasonable assurance that construction complies with applicable design drawings and specifications. This evaluation includes a comparison of the results from IP's overinspections and BA's field verification -inspections to determine the effectiveness of the BA field verification inspections. The results of these evaluations are discussed in subsection V.C.3 below.

Fourth, the results of the Overinspection Program were evaluated to determine whether the quality of old work is different from the quality of new work. The results of this evaluation are discussed in subsection V.C.4 below.

t l Finally, the results of the Overinspection Program were evaluated to determine whether the results are applicable to items that have not been inspected in the Overinspection Program. A summary of this evaluation is presented in subsection i V.C.5 below.

l It should be noted that the discussion presented below only reflects the results of r

the Overinspection Program for safety-related structures, systems, and components and seismically-designed non-safety-related HVAC systems. The lR l results for the augmented class D (radioactive waste) and fire-protection systems are presented separately in Appendix D, part E, because these systems are not safety-related, have not been subject to all of the QA provisions of 10 CFR Part l 50, Appendix B, rnd, as expected, contain proportionally more nonconformances than the safety-related structures, systems, and components.

l l

V-8 L

L

]

C. RESULTS

1. Sufficiency of Data for Evaluation The Overinspection Program has been in operation since December 1982 and is continuing. For purposes of this evaluation, a reference date was selected to permit evaluation of a fixed set of information from the Overinspection Program. Specifically, information generated by the Overinspection Program on or before December 31, 1984, was evaluated. R The Overinspection Program generated sufficient information by this reference date to permit reliable conclusions to be drawn regarding the quality of CPS construction.

As is shown in Table V-1, BA Quality and Technical Services and IP QA had inspected 2,402,471 attributes under the Overinspection Program as of December 31, 1984. Many of the same individual attributes were inspected by both BA and IP. Nevertheless, BA alone inspected a total of 1,672,414 R different attributes under the Overinspection Program as of December 31, 1984. IP estimates that this number represents approximately 12% of the total number of attributes within the scope of the Overinspection Program.

Appendix D, part A, discusses the distribution of the Overinspection Program inspections among the various construction disciplines and types of items in the plant. As this appendix demonstrates, more than 200,000 field R verification inspections have been performed for each discipline.

Furthermore, a large number of' field verification inspections have been performed for each type of commodity. Consequently, given the magnitude R and distribution' of these inspections, any significant adverse condition applicable to a type of item or discipline should be evident from the results of the Overinspection Program as of December 31, 1984. Therefore, as R shown in Appendix D, part A, these results provide a sufficient basis from which reliable conclusions regarding the Nality of construction of CP.i can be drawn.

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2. Engineering Evaluation

a. Introduction IP requested S&L (with input from GE as necessary for GE-designed components) to evaluate each NCR to determine whether any of the nonconformances identified by the Overinspection Program were safety-significant. For purposes of this report, a safety-significant nonconformance is defined as a nonconformance which, were it to have remained unidentified by the Overinspection Program, could have resulted in the loss of capability of a structure, system, or component to perform its intended safety function.

NCRs that documented more than one nonconforming attribute were initially reviewed to identify the number of evaluations required to determine the significance of the nonconformance. For many cases in which one of the nonconforming attributes determined the total adverse impact upon the item, only an evaluation of that nonconformance was conducted. For example, if an item contained.

more than one surface defect such as an arc strike, gouge, and scratch, the most limiting defect 0,e., the' defect with the deepest penetration) was selected for evaluation. For cases in which one NCR documented nonconformances on different items or in which one item contained nonconforming attributes of differing natures (e.g., loose bolt and arc strike), separate evaluations of the impact of the nonconforming attributes on each item were conducted to ensure that all possible adverse impacts were addressed.

In general, S&L evaluated each nonconformance by one of three methods. First, many nonconformances on their face have little or no impact on the integrity of an item. Nonconformances in this category, for example, typically include minor documentation errors and cos-metic defects such as those arc strikes which do not reduce base metal thickness. These nonconformances can be designated as having no safety significance, with no need to conduct more detailed evaluations.

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Second, there are many types of nonconformances which do not adversely affect the function of an item because of the inherent conservatism of the design for the item. Many of these nonconformances, such as minor cases of undercut and surface slag on welds, are readily identifiable from engineering experience and knowledge of the design without the need to conduct detailed calculations.

Finally, any nonconformance not falling within one of the above two categories was subject to detailed engineering evaluations to determine whether the nonconformance adversely affected the capability of a structure, system, or component to perform its intended safety func-tion.

Although S&L evaluated each nonconformance identified by the Over-inspection Program to determine whether it was safety-significant, it should be emphasized that most of the nonconforming items have been reworked in accordance with applicable design drawings and specifica-tions and the remainder have been determined to be acceptable as they are. Consequently, the evaluations below were undertaken to deter-mine the safety significance of the nonconformances assuming they had been left uncorrected by the Overinspection Program. R

b. Results

1) Introduction The results of the S&L engineering evaluation of the nonconformances identified by the Overinspection Program demonstrate that none of these nonconformances was safety-significant.

The discussion below identifies the type of nonconforming attributes identified by the Overinspection Program and explains, in general, why these nonconformances had no safety significance. Additionally Appendix D, part B, identifies each of V-11

the major types of commodities inspected under the Over-inspection Program and explains, in general, why the nonconformances in these commodities were not safety-significant.

The_ nonconforming attributes identified by the Overinspection Program were divided into 42 categories. Table V-2 lists the lR number of nonconforming attributes occurring within each category.- As is evident from this table, four of these categories (insufficient weld size, arc strike, undercut, and incorrect lR identification markings) comprise more than half of the total number of nonconforming attributes, and 14 of these categories R

account for approximately 90 % of the total number of nonconforming attributes identified by the Overinspection

~ Program. Since these categories encompass the vast majority of nonconformances discovered by the Overinspection Program, each is discussed below in order of decreasing frequency, together with an explanation of why the nonconformances in each category are not safety-significant.' The remaining categories are defined in Appendix D, part C.

It should be noted that the discussion below does not account for

- seven individual nonconformances. S&L was unable to determine R the precise impact of these nonconformances on the affected items because the items had been reworked and the NCRs did not contain sufficient information to permit performance of detailed engineering calculations.' Nevertheless, as is demonstrated in Appendix D, part D, the NCRs contain sufficient information, except in one case, to determine that none of these noncon- R formances would have caused a. safety-significant condition to exist at CPS.

V-12

2) Evaluation by Type of Nonconforming Attribute (a) Weld Size Nonconformances involving insufficient weld size comprise 16.6% of the total number of nonconforming attributes R identified by the Overinspection Program.

Some of the welds which were reported to be undersized were not designed to perform a load-carrying function, including fillet weld caps on full penetration welds.

Consequently, the fact that the weld is undersized is immaterial to the function of these welds.

Other welds identified as having insufficient size were evaluated to determine the effect of the reduced size on the load-carrying capacity of the weld. For purposes of the .

evaluation, the capacity of the wold was calculated based on the reduced size of the weld, in each case, the load-carrying capacities of the connections with the undersized welds were determined to be sufficient to meet the design loading. Consequently, none of the nonconformances was safety-significant.

(b) Arc Strikes Arc strikes comprise 14.8% of the total number of nonconforming attributes identified by the Overinspection Program.

An arc strike is a surface indication on the base metal or a weld which results when a source of welding current has inadvertently contacted the weld or base metal and produced some localized fusion. In general, arc strikes are cosmetic defects that do not penetrate the base metal to any appreciable extent. Consequently, most arc strikes are not potentially safety-significant because they do not V-13

approach the required minimum wall thickness for pressure-retaining components or reduce the base metal of other components to a sufficient degree to affect load-carrying capacity significantly.

In some cases, the. Overinspection Program identified arc strikes on components with relatively thin walls, such as tubing. In these cases, S&L compared the actual wall thickness (as reduced by the arc strike) against the minimum wall thickness requirements. As a result of this I* comparison, S&L determined that none of the arc strikes violated minimum wall thickness requirements.

Consequently, none of the arc strikes affected the required function of any item.

(c). Undercut R

Undercuts comprise 13.9 % of the total number of nonconforming attributes identified by the Overinspection Program.

Undercuts a' re unfilled grooves in the base metal adjacent to a weld which are created during the welding process.

Undercut may reduce the thickness of the base metal and, if it exceeds code allowables, may result in a reduction in pressure-retaining or load-carrying capacity. Undercut nonconformances identified by the Overinspection Program were evaluated by assuming reduced capacity of the affected item. All connections having undercut were found to provide adequate capacity to meet the code allowable stresses. Consequently, none of these nonconformances was determined to be safety-significant.

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(d) Missing or Incorrect Identification Markings Missing or incorrect identification markings'on items com-prise 8.0% of the total number of nonconforming attributes lR identified by the Overinspection Program.

S&L evaluated all cases of missing, incorrect, or damaged identification markings to assure that the proper identity had subsequently been established. In all cases, the correct items were installed. In addition, the plant startup and g testing process would have identified these cases and the missing, damaged, or incorrect equipment tags would have been replaced. Consequently, none of these noncon-formances was safety-significant.

(e) Tolerance Items installed outside of specified tolerances comprise 7.4% of the total number of nonconforming attributes R identified by the Overinspection Program.

For items that were out-of-tolerance, S&L evaluated their ds-built Condition to determine the impact, if any, on the design loadings and clearance requirements for the items.

For example, if, as a result of the evaluation, component loadings for a support changed significantly, a further evaluation was performed to determine the impact of the resultant loads on the design margins of the affected sup-port. None of the nonconformances identified by the Over-inspection Program resulted in an inability of out-of-tolerance items to satisfy calculated loads or clearance requirements. Consequently, none of these nonconfor-mances was safety-significant.

(f) Loose Hardware Loose nardware comprises 5.1% of the total number of lR nonconforming attributes identified by the Overinspection Program.

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Loose hardware consists primarily of loose nuts and bolts.

With the exception of the nonconformances discussed below, these nonconformances were evaluated to assess their impact on the affected item's overall strength. None of the nonconformances was determined to reduce the strength of the item below that required to satisfy design loads.

The most frequently observed example of loose hardware consists of loose jam nuts on adjustable rod and sway strut pipe supports. These items do not have a structural load-carrying function in the present dead load service condition. Furthermore, there is a requirement that these items be examined and corrected in the normal preservice inspection and adjustment checkout. Consequently, these nonconformances were determined to have no safety significance because they would have been identified and corrected even if the Overinspection Program had not been performed.

(g) Overlap Nonconformances involving overlap on welds comprise 4.9% R of the total number of nonconforming attributes identified by the Overinspection Program.

Overlap is the protrusion of weld material beyond the edge of the weld. Welds with overlap pose a potential problem because the overlap could mask a lack of fusion between the weld material and the base metal or mask an insufficiently sized weld. .

IP established a program to determine if overlap reported on NCRs at CPS involved lack of fusion or insufficiently sized welds. This program used a selection of 141 structural  ;

steel welds with overlap identified by the Overinspection l Program which had not yet been reworked. The overlap on '

V-16

these welds was re-examined and, where necessary, subjected to grinding to determine the size of the weld and whether lack of fusion was present beneath the overlap. It was determined that the welds were of sufficient size and that lack of fusion did not exist in any of these 141 welds.

Consequently, IP concludes that welds with overlap do not indicate lack of fusion or insufficiently sized welds at CPS and, therefore, they were not safety-significant.

Finally, it may be noted that many nonconformances involving overlap also were determined to be acceptable by confirming that the individual weld had sufficient size and fusion to perform its function or by evaluating the connection assuming lack of fusion or undersized welds.

(h) Wrong Weld Nonconformances involving wrong weld type compri::e 3.8%

of the total number of nonconformances identified by the Overinspection Program.

Wrong welds were reported when the weld type specified on the design drawings differed from the actual weld on the installed item. An example of this type of nonconformance is the use of an intermittent weld in lieu of a continuous weld or a continuous weld in lieu of an intermittent weld.

In each case, the nonconforming weld was evaluated to determine if the load-carrying capacity of the connection was sufficient to ensure that allowable stresses were not exceeded, in some cases, the wrong weld was actually stronger than that specified by the design. All of the wrong welds were found to provide adequate strength and, therefore, were not safety-significant.

o V-17

(i) Missing Hardware R

Nonconformances involving missing hardware comprise 3.1%

of the total number of nonconforming attributes identitled by the Overinspection Program.

Most of the nonconformances involving missing hardware pertained to mechanical and electrical hangers or equip-ment foundations which were missing nuts, washers, or clamp spacers. Missing jam nuts and clamp spacers on pipe supports did not perform any load-carrying function and were determined not to be safety-significant. Missing hard-ware on adjustable pipe supports was determined not to be safety-significant because these nonconformances would have been identified by subsequent inspection and testing even if the Overinspection Program had not been per-formed. Missing hardware on other items was evaluated to determine if any reduction in load-carrying capacity of the items would occur or if the function of the items would be jeopardized. As a result of its evaluation, S&L determined that none of this missing hardware would have affected the function of any item. Consequently, the missing hardware was not safety-significant.

(j) Gouges, Scratches, and Cuts R

Gouges, scratches, and cuts comprise 3.0% of the total number of nonconforming attributes.

Gouges can reduce base metal thickness. Most of the damage to items due to gouges had only minor impact on the base metal thickness. In each case, it was determined that the reduction in the base metal thickness was not sufficient to violate minimum wall thickness requirements for pipes or to result in a condition in which allowable i stresses were exceeded for tubing. Consequently, these nonconformances were not safety-significant.

V-18 1.

(k) Slag Slag in welds comprises 2.5% of the total number of lR nonconforming attributes identified by the Overinspection Prcgram.

Slag is a nonmetallic material which results from the welding process. Slag is generally found on weld surfaces as a result of incomplete cleaning af ter the weld is made and, as such, does not affect the weld integrity. However, if slag is entrapped in the weld itself, the slag reduces the volume of the weld metal and consequently reduces the weld strength.

Each case of slag inclusion identified by the Overinspection Program was evaluated by assuming that the affected portion of the weld did not contribute to the strength of the weld. In each case, it was determined that the affected connection had sufficient load-carrying capacity to satisfy design loads. Consequently, none of these nonconformances was safety-significant.

(1) Lack of Fusion Lack of fusion in welds comprises 2.4% of the total number of nonconforming attributes identified by the Overinspec-tion Program.

Lack of fusion generally describes a condition in which the welding material is not completely fused to the base metal. For welds with no load-carrying function, reduction in weld strength caused by lack of fusion was not safety-significant. For other welds, incomplete fusion was evaluated by assuming that the defective portion of the weld provided no lead-carrying capability for the weld in question. Furthermore, lack of fusion was evaluated to V-19

determine whether it could have caused crack propagation.

If it was determined that cracks would propagate such that the entire weld would be lost, the weld was assumed to have zero strength in evaluating the capacity of the connection.

In each case involving incomplete fusion, either the unaffected portion of the nonconforming weld and/or the other welds in the connection were determined to possess adequate strength to satisfy design loads. Therefore, these nonconformances were not safety-significant.

(m) Wrong Hardware R

Nonconformances involving wrong hardware comprise 2.3%

of the total number of nonconforming attributes identified by the Overinspection Program.

Nonconformances pertaining to wrong hardware involve the substitution of a hardware item different from that specified on the design drawings. Typically, wrong hardware identified by the Overinspection Program resulted from incorrect size components being installed, usually bolts, washers, nuts, or lugs. Wrong hardware identified by the Overinspection Program was evaluated to determine if any reduction in load-carrying capacity would result. In many cases, components were substituted which actually increased the strength of the item. All items evaluated were found to provide the required load-carrying capacity, and, consequently, none of the wrong hardware was found to be safety-significant.

(n) Orientation / Configuration Nonconformances involving orientation and configuration of hardware resulting from the installation process comprise 'R 2.1% of the total number of nonconforming attributes identified by the Overinspection Program.

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Orientation and configuration are reported as nonconform-ing when the as-installed condition does not agree with the design drawing. In each of these cases, S&L evaluated the as-installed condition to determine the impact on design loadings and clearance requirements. Further evaluations R

were performed as necessary to ensure that adequate design margins existed for various operating conditions such as thermal and seismic loading. None of the nonconformances identified resulted in an inability of the item to satisfy the calculated loads or clearance requirements. Consequently, none of these nonconformances was safety-significant.

(o) Other Nonconforming Attributes lR The remaining types of nonconforming attributes cumulatively account for approximately 10% of the total lR number of nonconformances identified by the Over-inspection Program. Each individually accounts for less R

than 1.5% of the total nonconformances identified by the Overinspection Program. These nonconformances range from minor defects which did not impact the integrity of items, such as dirt and debris, to more significant cases, such as cracks in welds.

In particular, cracks were evaluated to determine if localized stresses would cause cracks to propagate. If the cracks could propagate, the strength of the connection or supporting member was evaluated by accounting for any reduction in capacity resulting from the crack. In all cases, the connections were determined to have sufficient capacity to satisfy design loads. Consequently, none of these nonconformances was determined to be safety-significant.

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3) Conclusion Of the more than 2 million inspections conducted under the lR Overinspection Program, none revealed any safety-significant nonconformances. Therefore,.the Overinspection Program has verified that the type of nonconformances being- identified by the program would not result in the loss of capability of a structure system, or component to perform its intended safety function if left uncorrected R by the Overinspection Program.

3. Quantitative Evaluation

a. Introduction The engineering evaluation of the nonconformances discussed in the preceding section is the primary factor relied upon by IP to verify the quality of construction of CPS because the engineering evaluation verifies that the type of nonconformances being identified by the Overinspection Program would not result in the loss of capability of a

. structure, system, or component at CPS to perform its intended safety function if lef t uncorrected by the Overinspection Program. To provide lR a secondary confirmation of quality, IP also has performed a quantita-tive analysis of the results of the Overinspection Program to verify that the QA program has been effective in providing reasonable assurance that construction complies with applicable design drawings and specifications.

For both overinspections and field verification inspections, several types of information were compiled in order to perform a quar.titative evaluation of' the nonconformances identified by the Overinspection Program. First, the number of inspected and nonconforming attributes was calculated for the plant as a whole, for each construction discipline, and for each type of commodity. Based on this information, various rates of conformance (expressed in percent attributes con-forming with design drawings and specifications per nspected attribute) were calculated. These conformance rates were then evaluated to verify that the QA Program for CPS has been effective in V-22

providing reasonable assurance that structures, systems, and components at CPS comply with applicable design drawings and specifications.

In evaluating the conformance rates identified by the Overinspection Program, IP has used a conformance rate of 95% as a threshold indicator that the QA program for CPS has been effective in providing reasonable assurance that construction complies with applicable design drawings and specifications. This rate reflects the fact' that a 100%

conformance rate is unobtainable and unnecessary in practice and that a conformance rate of 95% is a reasonable indicator of quality. For those disciplines or items with conformance rates of less than 95%, IP has taken various factors, discussed below, into account, including the significance of the nonconformances being identified, to determine whether additional action may be warranted to assure the quality of construction of these disciplines or items.

- The discussion presented below is based primarily on the conformance rates for field verification inspection because these rates are the lowest (and thus the most conservative) rates identified by the Overinspection Program.

b. Overall Conformance Rates As of December 31, 1984, 1,672,414 attributes had been inspected and R

39,712 nonconforming attributes had been identified by field verifi-cation inspections, for an overall field verification conformance rate of 97.6 % Additionally, 730,057 attributes had been inspected and 9,033 R nonconformances had been identified by overinspection, for an overall overinspection conformance rate of 98.8% R These high overall conformance rates verify that the QA Program has been effective in providing reasonable assurance that structures, systems, and components at CPS comply with applicable design draw-ings and specifications.

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. _ - - - - . ._. _-- .- - _ .. - _= - - _ . _- - _ _ . - -.

c. Discipline Conformance Rates -

Table V-3 presents the conformance rates found by field verification inspections, departure inspections, and overinspections performed in series with field verification inspections for the three major disciplines (structural, electrical and instrumentation, and piping and mechanical).

Table V-3 shows that the conformance rate for structural attributes is 93.8% for field verification inspections, which is the lowest rate for R any of the construction disciplines. However, IP had previously decided to perform overinspections on 100 % of the accessible primary structural members in the plant (i.e., those members which must perform their intended design functions during normal ope' rations and safe shutdown, including those members which support safety-related components). Consequently, these inspections will assure that nonconformances in structural steel will be identified for corrective action.

The conformance rates in the other disciplines are more than 97% for R

field verification inspections. Consequently, these rates verify that the QA Program has been effective in providing reasonable assurance that construction in these disciplines complies with applicable design drawings and specifications.

Other data on Table V-3 should be noted. First, the conformance rates for departure inspections are lower than the conformance rates for overinspections performed in series with field verification inspections.

This is expected because the departure inspections were initial reinspections, whereas the series overinspections have been performed for work on which nonconformances have already been identified for corrective action by the field verification group.

Table V-3 also shows that the conformance rate for overinspections performed in series is extremely high (99.1%) and is significantly higher R than the conformance rate for field verification inspections. Since overinspections performed in series have, in practice, been redundant V-24

0.

of those conducted by the Field Verification Group, this high rate indicates that field verification inspections have been effective in identifying nonconformances.

R

d. Commodity Conformance Rates Table V-4 presents the conformance rates found during overinspections and field verification inspections for each type of commodity. As is evident from this table, with three exceptions, the field verification R conformance rates for each commodity are greater than 95%. There-fore, these rates indicate that the QA Program has been effective in providing reasonable assurance that construction of these commodities complies with applicable design drawings and specifications.

For the three types of commodities with field verification conformance R rates less than 95%, IP is taking appropriate action to assure that the commodities will be of acceptable quality after completion of construction. Specifically:

1) Structural Steel The field verification conformance rate for structural steel is 93.8%. As mentioned above, IP has decided to perform lR overinspections for 100% of the accessible primary structural members, thereby assuring that the quality of the structural steel is acceptable.

lR

2) Electrical Equipment The field verification conformance rate for electrical equipment is 93.1%. IP is continuing to perform the Overinspection Program R

for electrical equipment and will perform additional evaluations as more data specifically applicable to electrical equipment become available.

3) Mechanical Equipment R

Given the 93.8% field verification conformance rate for and the relatively few inspections conducted on mechanical equipment, IP V-25 m

believes it is appropriate to continue performing the Overinspection Program for mechanical equipment.

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4. Evaluation of Old and New Work To evaluate the effectiveness of corrective actions which IP implemented after the identification of deficiencies in 1982, the work which has been inspected under the Overinspection Program has been divided into old and new work.

For purposes of this report, July 26, 1982, was selected as the date for dividing construction between old and new work (this date is after the issuance of the major stop work actions in 1982 and before the lifting of them). More specifically, construction work is classified as old or new based on the following criteria. All structural work within the scope of the Overinspection Program has been classified as old work for purposes of the Overinspection Program because it was completed prior to July 26, 1982.

All HVAC work has been classified as new work because it was turned back to the contractor for rework and inspection after July 26, 1982. Finally, electrical cable and instrument panels for which construction was completed by July 26,1982, have been classified as old work; electrical and mechanical hangers and raceways inspected by QC personnel by July 26, 1982, have been classified as old work; all other construction work for which documentation was completed by July 26, 1982, has been classified as old work; and all remaining work has been classified as new work. The results of evaluations based on these classifications are conservative because much construction work that was completed but not inspected or documented by July 26,1982, has been classified as new work. Since the conformance rate for old work is lower than the conformance rate for new work, this has resulted in a lower conformance rate for new work than would have existed if the old work /new work classification had been based solely on the completion date of the insta!!ation work.

Table V-5 presents the conformance rates for old and new work for each of lR the censtruction disciplines. As can be seen from the field verification inspections, the conformance rate for new work is 98.9%, which is signi- R V-26

ficantly higher than the conformance rates for old-work. This indicates improvement in the quality of new work and reflects favorably on the effectiveness of the corrective actions that have been implemented since 1982. Furthermore, the high conformance rate for new work verifies the quality of that work.

lR

5. Items Not Inspected Under the Overinspection Program As discussed above, the scope of the Overinspection Program did not include all types of safety-related items. Additionally, all items within the scope of the Overinspection Program have not been inspected. Nevertheless, the Overinspection Program provides a basis from which conclusions can be drawn regarding the quality of construction for the categories of items that have not been inspected under the Overinspection Program. Each of these categories is briefly discussed below,

s. Items Within the Scope of the Overinspection Program As was demonstrated in subsection V.C.1, given the large number of inspections that have been performed for each construction discipline and for each commodity, any significant adverse condition which is applicable to a class of items would have been identified by the Overinspection Program. Consequently, the results of the Overinspec-tion Program as of December 31, 1984, are generally applicable to the R uninspected items within the scope of the program,

b. Items Not Within the Scope of the Overinspection Program The only safety-related discipline not encompassed within the scope of the Overinspection Program is civil, which consists of such items as rebar, concrete, masonry walls, and soil compaction. Although both the NRC and IP have identified some deficiencies in civil work during construction of CPS, these deficiencies have been relatively minor in both number and severity and have been typical of the types of deficiencies expected during construction of any nuclear power plant.

As a result, IP concludes tLt the QA Program for CPS has been effective for civil work, that the quality of civil work is acceptable, and that a reinspection program for civil work is unnecessary.

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Also, to the extent that the Overinspection Program has shown that the overall quality of construction of CPS is acceptable, that conclusion is applicable to civil work since BA performed both the civil work and most of the remaining construction work at CPS. Consequently, the results of the Overinspection Program reinforce IP's position that no reinspection program is necessary for civil work.

c. Non-Recreatable Attributes . .

During construction of a nuclear power plant, inspections of attributes are performed for many in-process activities. Often, af ter the process is complete, it is no longer possible to inspect the same attribute because the attribute is non-recreatable. Examples of such attributes are welding preheat and cable pull tension. Consequently, it was impossible for the Overinspection Program to inspect these types of non-recreatable attributes. Nevertheless, there is no reason to believe that the quality of non-recreatable attributes would have been significantly different than the quality of the attributes which were actually inspected by the Overinspection Program.

d. Inaccessible Items There are individual items within the scope of the Overinspection Program which are not available for inspection because the items have been rendered inaccessible by subsequent construction. An example of such an item is a piece of pipe or conduit that has been embedded in a wall. However, there is no single type of commodity within the scope of the Overinspection Program that is generically inaccessible, i.e.,

which is always inaccessible to inspection. Since there is no reason to believe that the quality of inaccessible items is significantly different from the quality of accessible items, the results of the Overinspection Program apply equally to inaccessible items and to other items which were not inspected.

e. Vendor-Supplied Items The purpose of the Overinspection Program is to verify the quality of construction and installation activities at CPS. Consequently, the V-28

Overinspection Program has included inspection of installation of pumps, valves, and other components fabricated offsite by vendors, but has not included inspection of the internals of these types of items.

Fabrication of these components is subject to the vendors' QA programs, with appropriate receipt inspections, surveillances, and audits under the QA Program for CPS. The vendors' QA programs provide adequate confidence that vendor-supplied items will perform their safety-related functions during operation.

D. CONCLUSION The more than 2 million inspections conducted under the Overinspection Program R

as of December 31, 1984, verify that the overall quality of construction is acceptable.

None of the nonconformances identified by the Overinspection Program would have adversely affected the capability of structures, systems, and components at CPS to perform ti.eir intended safety functions, thereby demonstrating that construction of CPS is of acceptable quality.

l-Additionally, the overall conformance for field verification inspections is 97.6%

R and the overinspection conformance rate is even higher at 98.8% These rates indicate that the QA Program for CPS has been effective in providing reasonable assurance that structures, systems, and components comply with applicable design drawings and specifications.

The data from the Overinspection Program also demonstrate other positive trends. For example, the overall conformance rate for new work is higher than that for old work, which indicates that corrective actions and improvements implemented by IP after the identification of deficiencies in 1982 have been effective. Additionally, the conformance rate for overinspections performed in

! series is very high and significantly higher than the conformance rates for field j verification inspections, thereby indicating that BA Quality and Technical Services has been effective in identifying nonconformances in the lots subject to field verification inspections.

V-29 i

I

Table V-1 Number of Attributes Inspected by BA and IP Under the Overinspection Program as of December 31,1984 Number of attributes inspected by BA's field verification 1,672,414 Number of attributes inspected by IP overinspection 730,057 Total 2,402,471

Page 1 of 2 Table V-2 Nonconformances Within Nonconformance Types Number of Percent of Nonconforming Total h Attribute Attributes Nonconformances Welding Weld size 8,081 16.6 Undercut 6,791 13.9 Overlap 2,379 4.9 Convexity 60 0.1 Concavity 105 0.2 Lack of fusion 1,184 2.4 Porosity 193 0.4 Slag 1,225 2.5 Crack 188 ~0.4 Reinforcement 145 0.3 Transition 4 0.0 Subtotal 20,355 41.8 Installation Wrong hardware 1,142 2.3 Missing hardware 1,502 3.1 R

Loose hardware 2,t.93 5.1 incomplete 253 0.5 Cold set 39 0.1 Orientation / configuration 1,019 2.1 Tolerance 3,630 7.4 Clearance / interference 310 0.6 Slope 50 0.1 Routing 22 0.0 Bending radius 74 0.2 Wrong weld 1,859 3.8 Gaps $59 1.1 Thread engagement 108 0.2 Termination error 107 0.2 Subtotal 13,167 27.0

Page 2 of 2 Table V-2 Nonconformances Within Nonconformance Typet Number of Percent of Nonconforming Total Type Attribute Attributes Nonconformances Arc strike Damage . 7,206 14.8 Grinding 534 1.1 Dent / bent / warped 576 1.2 Gouge / scratch / cuts 1,464 3.0 Bolt / nut broken 47 0.1 Coating missing 150 0.3 Defective material 190 0.4 Dirt / debris S4 0.2 Protection 16 0.0 Rust 41 0.1 Holes 263 0.5 Gaps 85 0.2 Subtotal 10,656 21.9 R Documentation ID missing / incorrect 3,837 8.0 Drawing incorrect 403 0.8 Traceability 123 0.3 Inspection error 154 0.3 4,567 Subtotal 9.4 l

Total 48,745 100.0 i

1

Table V-3 Conformance Rates by Construction Discipline Number of Type of Attributes Nonconforming Conformance Inspection Discipline Inspected Attributes Rate (%)

Firld verifi- Structural 273,609 16,956 . 93.8 cetion (FV) Electrical / instrumentation 690,387 12,917 98.1 Piping / mechanical 708,418 9,839 98.6 Total 1,672,414 39,712 97.6 Ov2rinspection departure Structural 86,317 3,014 96.5 inspection Electrical / instrumentation 52,166 839 98.4 R (prior to FV) Piping / mechanical 31,380 342 98.9 Total 169,863 4,195 97.5 OvIrinspection Series Structural 279,768 4,097 98.5 Inspections Electrical / instrumentation 146,838 314 99.8 (post FV) Piping / mechanical 133,588 427 99.7 Total 360,194 4,838 99.1 1

l l

l

Table V-4 Nonconformance Rates by Type of Commodity -

Ficid Verification Overinspection Attributes Nonconforming Conformance Attributes Nonconforming Conformance Commodities inspected Attributes Rate (%) Inspected Attributes Rate (%)

Beams and structural steel 273,609 16,956 93.8 366,085 7,111 98.1 Cable 21,861 501 97.7 8,031 32 99.6 Cable termination 117,036 453 99.6 48,277 31 99.9 Conduit 22,717 59 99.7 1,056 0 100.0 Cable trays 87,092 111 99.9 0 4 2 -

Electrical equipment I 14,899 1,025 93.1 9,053 372 95.9 Electrical hangers 403,546 10,675 97.4 107,460 712 99.3 Instrumentation 6,465 2 > 99.9 613 0 100.0 Instrument pipe 16,77I 91 99.5 24,514 4 > 99.9 R Large bore pipe 32,673 675 97.9 16,317 40 99.8 Small bore pipe 49,140 440 99.1 22,223 30 99.9 2 3,491 Mechanical equipmegt 217 93.8 416 14 96.6 Mechanical supports 326,096 5,623 98.3 102,344 676 99.3 IIVAC duct 218,889 1,952 99.1 11,402 4 >99.9 IIVAC hangers 78,129 932 98.8 12,266 5 >99.9 Total 1,672,414 39,712 97.6 730,057 9,033 98.8 I

includes electrical boxes, electrical panels, and switchgear.

2 includes compressors, pumps, valves, and miscellaneous equipment.

3 Includes anchor plates, expansion anchors, and hangers.

4 Identified during cable inspection; therefore no inspection attributes are credited.

Table V-5 Conformance Rates for Old Work and New Work Field Verifica : ion Inspections Number of Number of Attributes Nonconforming - Conformance Discipline Work Inspected Attributes Rate (%)

Structural Old 273,609 16,956 93.8 lR New N/A N/A N/A Electrical / Old 228,159 9,327 95.9 instrumentation New 462,228 3,590 99.2 Piping / Old 77,080 1,412 98.2 R mechanical New 631,338 3,427 98.7

- Totals Old 578,848 27,695 95.2 New 1,093,566 12,017 98.9 Overinspections Number of Number of Attributes Nonconforming Conformance Discipline Work Inspected Attributes Rate (%)

Structural Old 366,085 7,111 98.1 lR New N/A N/A N/A Electrical / Old 99,631 759 99.2 instrumentation New 99,373 394 99.4 Piping / Old 54,873 313 99.4 R mechanical New 110,095 456 99.6 Totals Old 520,589 8,183 98.4 New 209,468 850 99.6 N/A = Not applicable. All structural is old work.

l

Flow Diagr:m cf the Types Figure V-1 cf Inspections Performed ,

Under the Overinspection Program

1. L".ts Subject to Field Venfication inspection and Overinspection FGid venficat.on Do results Field venfication Do results inspection on satisfy acceptance inspection of all or +

Owennection satisfy acceptance sample of lot (No; on sample of tot Criteria? part of remainder of lot ,

g (Yes)

(Yest l

(No)

Lot returned to Baldwin Associates _

Ovennspection Program _

finished for lot for $ valuation and possible reinspection or o*tinnspection of 100%

of rsmainder of tot

11. Lots Subject to Ovennspection Departure inspections (status as of December 31,1984)

R Departure inspection (109 690 attnbutes) No field venfication

inspection as of on 169.863 attnbutes _

12/31/84

, (60.173 attributes)

Field ye ification Do results Field verification

• satisfy acceptance inspection of all Ovennspection Program inspection finished for lot critena (No) or part of remainder of lot  %

(Yes) 8133-1 04 323

VI. RECORD VERIFICATION PROGRAM IP developed the Record Verification Program in response to the June 1982 stop work actions (SWA) to verify the acceptability of CPS construction QA records. The program serves both to verify the adequacy of construction QA records generated before the issuance of the SWAs and to provide additional assurance as to the adequacy of such records generated after the SWAs. The rev.ews conducted under the Record Verification Program are performed in addition to those normally performed as part of the QA Program for CPS. They a: 2 a supplement to the CPS QA Program and not a substitute for it.

The following discussion presents a summary description of the major elements of the program and an evaluation of the results of the program. This evaluation of results shows that:

e None of the hardware-related nonconformances identified as a result of the records verification review are safety-significant.

e The rates of record deficiencies identified in the program are low, no adverse trends are evident that warrant further action, and none of the record deficiencies identified in the record verification review have adverse implications for hardware quality.

e The program provides adequate confidence in the acceptability of CPS construction records.

A. MAJOR PROGRAM ELEMENTS The Record Verification Program plan was originally described in detail in IP's November 15, 1982, letter to the NRC. The NRC's December 3,1982, letter concurred with the intent of the program plan. On January 20,1983, IP submitted revisions to the program plan in response to NRC comments. On September 26, 1984, IP refined and clarified the program plan as it has developed and evolved during the course of its implement 6 tion.

VI-l

IP QA is responsible for managing the Record Verification Program. The reviews conducted under the program apply to quality records for all completed BA l

construction work packages for safety-related, augmented class D (radioactive waste), and fire protection structures, systems, and components, and BA safety-related purchase order packages. These reviews are conducted on two levels-BA's Document Review Group (DRG) reviews all records within the scope of the l program for acceptability and IP's QA Records Review Group (RRG) reiiews a l random sample of approximately 20% of the records reviewed by the BA DRG.

As stated above, the reviews are conducted for completed work packages (travelers) and purchase orders drawn from the BA records vault. A document exception list (DEL) is prepared and maintained for each work package ,or purchase order selected for review. The DEL records the results of the review, including any record deficiencies (referred to as " DEL items") identified during the review.

The reviews and any associated field validations are performed by trained and certified QA personnel using approved checklists that specify the applicable review acceptance criteria. The acceptance criteria include legibility, completeness, traceability, and identification of the item involved, as well as compliance with applicable codes, standards, specifications, and procedures. At completion of CPS construction, there will have been more than 140,000 work packages generated, which include some IS million reviewable record verification attributes.

Record deficiencies identified in a work package are documented on the DEL and routed to the DEL Resolution Group for resolution or initiation of a nonconformance report (NCR) for potential hardware-related conditions. After resolution, records are reprocessed through the BA DRG for final acceptance review. All documentation packages accepted by the DRG are then transmitted to the IP RRG for selection of the review sample.

The IP RRG sample review of approximately 20% of completed packages trans-mitted by the BA DRG uses the same criteria and checklists used by the BA DRG. Record deficiencies identified in the IP RRG review are recorded on a VI-2

r i record deficiency report (RDR), which is forwarded to the BA DRG for resolu-tion. After evaluation, BA DRG may prepare DEL items or NCRs, as appropriate, and process all deficiencies for resolution. Following resolution, the completed record packages are routed back to the IP RRG for final review and acceptance.

The record review process is monitored by computer-assisted systems that enable BA and IP management to track the status of documents and deficiencies and analyze trends resulting from the records review. In addition, record verification activities are subject to audits and surveillances by the BA and IP QA organizations. Pertinent data developed from the Records Verification Program are presented in Appendix E.

B. EVALUATION OF RESULTS The following ivaluation of the results of the CPS Record Verification Program consists of three elements: (1) the safety significance, if any, of potential hardware-related nonconformances resulting from record reviews; (2) the impli-cations for hardware quality, if any, of record deficiencies identified in record verification reviews; and (3) the basis for confidence in the acceptability of CPS construction QA records. For purposes of this evaluation, records verification data were accumulatec through March 3,1985, and resolutions of NCRs and R record deficiencies wert accumulated through March 17,1985.

1. Potential Hardware-Related Nonconformances As indicated in the foregoing discussion, potential hardware-related nonconformances identified during the course of record verification reviews are documented on NCRs. As of March 17, 1985, 890 NCRs had been R

initiated as a result of record verification reviews. The 890 NCRs can be categorized as follows:

VI-3

T NCR Category Number of NCRs '

Open: pending disposition or closure. 19 Invalid: NCRs that have been determined 31 not to document valid nonconformances.

Superseded: closed and covered 39 by a new NCR. l Material rejected: material rejected 2 in stores before installation. Not used; therefore, no safety significance.

Transferred to IP Operations for evaluation 33 as a nonconforming material report (NCMR)

(for systems already turned over tt !P .

Operations).

Not hardware-related or "use as is" 166 evaluation by S&L: Disposition is used when a nonconformance does not affect permanent plant hardware or S&L has evaluated the item for all engineering functional requirements, including performance, maintainability, fit, R and safety. None of these items has safety significance in the operation of CPS.

Not hardware-related or "use as is" evaluation 419 by IP or BA: No violation of design or plant hardware existed. A "use as is" disposition may be used when it can be established that the discrepancy will result in no adverse condition and that the item under considera-tion will continue to meet engineering func-tional requirements, including performance, maintainability, fit, and safety. Therefore, these items are not safety-significant.

Dispositioned by rework based on an evaluation 27 by S&L.

Dispositioned by rewo-k based on evaluation by IP/BA. 154 Total 890 VI-4

i Excluding the 19 NCRs that are now pending dispositionI , there are also 72 Rl NCRs that are invalid, superseded, or involve material rejects prior to installation. These NCRs, therefore, do not present a potential for affecting hardware quality or plant safety. Five hundred eighty-five of the lR NCRs were subjected to the existing CPS process for evaluation and disposition of NCRs and were determined to be unrelated to hardware quality or technically acceptable for use as is (i.e., without any rework).2 3

The remaining 214 NCRs were subjected to engineering evaluations by S&L R to determine whether any condition significant to plant safety would have existed if the nonconforming conditions had remained undetected by the Record Verification Program.

S&L evaluated each NCR to determine the hardware impact if the nonconforming condition h'ad gone undetected by the Record Verification Program. For NCRs that impacted hardware quality, S&L determined whether the nonconformance was safety-significant. A safety-significant nonconformance is defined for the purposes of this evaluation as one which,.

had it remained unidentified by the Record Verification Program, could have 'resulted in the loss of capability of a structure, system, or component to perform its intended safety function.

For purposes of describing the S&L evaluation results, the nonconformances can be divided into eight categories. Each category is discussed below, together with an explanation of why the nonconformances were not safety-significant. Nonconformances in the first five categories had no impact on i The 19 open NCRs have not been dispositioned due to insufficient' time available for closure prior to issuing this report. There is no reason to believe that any are unique or have any greater potential for safety significance than the 871 NCRs R already dispositioned.

2 Additional description and discussion of the disposition of these 585 NCRs is contained in Appendix E, Part B. R 3

Three evaluations were not complete as of April 2,1985. lR VI-5

i hardware quality. Nonconformances in the last three categories were such that their presence would not result in the failure of any structure, system, or component to meet the plant design basis.

a. Documentation and Procedural Nonconformances Documentation and procedural nonconformances, with 89 occurrences, lR were by far the most prevalent type of nonconformance evaluated by S&L. These nonconformances typically dealt with improperly or incompletely documented items in the construction traveler packages, receipt inspection reports, certified material test reports, or other construction documents. In all cases, the acceptability of the meaerial or construction was subsequently confirmed and only the documents themselves had to be corrected. The procedural nonconformances reported instances in which project procedures were not correctly.

followed. None of these nonconformances were determined to af fect hardware quality.

b. Material Supplier Qualification in 11 cases, the material supplied could not be confirmed initially as R being supplied in accordance with an ASME Section til acceptable material control program. These items were either downgraded or replaced. In each case, a review of the item's certified material test report demonstrated that the material originally supplied was the same as the material specified, and the hardware was determined to be acceptable.

c. Welding Preheat Temperature incorrect welding preheat temperatures were identified in 18 cases.

The purpose of performing welding at specified preheat temperatures is to reduce the effect of the localized rapid heating and cooling caused by welding on thick material sections. In the worst case, incorrect preheating might result in the weld cracking as it cools. However, acceptability of each weld was verified by nondestructive examinations VI-6

performed after the weld had been completed and cooled. These examinations determined that the welds had not cracked due to improper preheat.

d. Inspection Not Performed Iri 22 cases, either an inspection was not performed or it was performed but not documented properly. In 20 cases, a subsequent inspection was performed to confirm the acceptability of the original material or construction. In one case, installed tack welds in an electrical pull box R

were inacessible and could not be inspected. In the other case, a weld had been reworked so that a subsequent inspection could not be performed. However, the originally installed conditions were deter- lR mined to be acceptable based on an evaluation of the design loads applied to the connections. R

e. Items Identifiable Through Subsequent Inspection and Testing Nineteen nonconformances were reported that would have been lR detected and corrected during subsequent plant construction and testing. These nonconformances involved items such as flow direction indicators on valves not being visible, shop hydrostatic testing being _

waived in lieu of field system hydrostatic testing, meggering electrical cables and equipment, and one case of a valve motor operator qualification that would have been inspected and detected during another program. These nonconformances would have been detected and corrected in the normal course of other programs.

f. Component Substitution Fif teen occurrences of component substitution were reported. These lR cases dealt with substitution of a heavier schedule pipe spool, substitution of botting material, substitution of different size bolts, substitution of weld rod, or substitution of plate material thicker than R that specified. In each case, it was determined that the substituted component was capable of performing its intended function.

VI-7

f

g. Material Traceability Thirty-six occurrences of failure to maintain material traceability were lR evaluated. These cases typically dealt with bolting or structural materials .that, upon examination, no longer had the proper identi-fication marks. Each such occurrence was examined assuming installa-tion of the lowest grade material available at the site for botting material and the lowest grade available commercially for structural material. In each case, there was sufficient margin in the design to allow for the lower grade material substitution. Thus, ev3n though material traceability could not be established, structural integrity was demonstrated to be within the design criteria. ,

h. Bolt Torque One case of an inadequately torqued condait support anchor was evaluated. The reduced torque value was determined to be acceptable based on the capability of the bolt in its original condition to transfer the applied loads within the design basis.

In summary, the S&L engineering evaluations of the nonconforming conditions identified by the Record Verification Program showed that, even if the nonconforming conditions had remained unidentified by the record verification review, no loss of capability of any structure, system, or component to perform its intended safety function would have resulted.

That is, none of the nonconforming conditions were safety-significant.

2. Evaluation of Record Deficiencies The record deficiencies identified in the Record Verification Program as of March 3,1985, were evaluated to determine: (1) whether there were any R outstanding trends in record deficiency rates that would warrant additional action and (2) whether any adverse hardware implications are evident from the resolutions of record deficiencies completed by March 17,1985. Each R of these evaluations is discussed below.

VI-8

a. Deficiency Rates As of March 3,1985, a total of 58,556 work packages or purchase R orders have been placed in the Record Verification Program review process. Upon completion of CPS construction, approximately 140,000 record packages will have been generated. Of the 58,556 packages in R

review to date,38,255 are for new work and 20,301 are for old work.

The 58,556 packages include 7,602,553 individual attributes that were R reviewed by BA for compliance with the applicable acceptance criteria. Within these attributes, 147,018 DEL items or record deficiencies have been identified. Over 4,305,000 attributes are associated with new work and nearly 3,298,000 are associated with old R work. Approximately 60,600 DEL items were identified for new work and approximately 86,000 were identified for old work.

The rates of record deficiencies for the total program (1.9%), new work R

(1.4%), and old work (2.6%) are low. The significantly lower rate for new work relative to old work indicates IP's effective implementation of programmatic improvements and corrective actions in regard to quality records.

The IP RRG conducted a sample review of the record packages previously accepted by the BA DRG. The IP RRG review encompassed over 1,261,000 attrr utes, within which 1,358 record deficiencies were-identified. The IP RRG deficiency rate of 0.11% can be contrasted R b with the BA DRG overall program deficiency rate of 2.6%, indicating that the BA DRG reviews have been effective in identifying record deficiencies. The overall trends for the Record Verification Program results are favorable and indicative of an effectively functioning program.

VI-9

Appendix E, Part A presents tabulations of the data for NCRs generated from the Record Verification Program as of March 17,1985, R and record deficiencies as of March 3,1985, to show the distribution of NCRs and record deficiencies by old and new work, by discipline, by work item type, and by checklist attribute group. These data were ,

evaluated to determine whether there were any adverse trends that might warrant further action. The results are discussed below.

Table E-1 correlates NCRs by work item for both old and new work.

All nonconformance rates are low, new work rates are lower than old work rates, and no outstanding adverse trends warranting further action are evident.

Tables E-2 and E-3 correlate DEL items by discipline for both old and new work and for DRG and RRG reviews, respectively. Deficiency rates are generally low and new work rates are essentially all below old work rates. No outstanding trends warranting further action are evident from RRG reviews. In the DRG reviews, one discipline (old work procurement) shows a deficiency rate warranting further R examination. This is discussed in Appendix E in connection with the evaluation of Table E-4.

Table E-4 correlates DEL ltems identified in DRG reviews by item of work for both old and new work. While deficiency rates were generally low and new work rates were lower than old work rates, the rates for four items warranted further examination. As explained in Appendix E, lR no further action beyond continuation of the DRG reviews was warranted for any of the four cases. R Tables E-6 and E-7 correlate record deficiencies by checklist attribute for each work item type for both old and new work and for DRG and RRG reviews, respectively. The rates are low, new work rates are VI-10

generally less than old work, and no adverse trends warranting further action are evident.

Appendix F presents an analysis of the Record Verification Program data base to show that, with the exceptions noted in Appendix E, Part A, the population of records reviewed to date is sufficient to lR enable reasonable inferences to be drawn for the program as a whole.

In summary, the evaluation of deficiencies for the Record Verification Program shows low deficiency rates for the overall program, lower rates for new work relative to old work, and effective identification of record deficiencies by the BA DRG. Further examination of record deficiencies in terms of their distribution by discipline, by work item type, and by checklist attribute indicate no outstanding trends that warrant further actions. The evaluation indicates that the Record Verification Program has been effectively implemented, and has been effective in confirming the acceptability of CPS QA records.

b. Record Deficiency Resolutions The resolutions of record deficiencies identified in the Record Verification Program as of March 17, 1985, were evaluated to deter- R mine whether any of those deficiencies had adverse implications for hardware quality. In general, record deficiencies are related solely to documentation and do not involve nonconformances in the hardware itself. Of course, each record deficiency is ultimately resolved and any potential hardware deficiencies are documented as NCRs and resolved. Nevertheless, this evaluation examines the two major classes of record deficiency resolutions employed in the CPS Program - generic resolutions and specific resolutions - to confirm that this has remained the case.

VI-l i L

1) Generic Resolutions Of the 147,018 record deficiencies evaluated herein,58,102 were R resolved by generic resolutions (GR). A GR is a preapproved resolution that can be directly applied by a document reviewer for closing a particular type of recurring record deficiency.

Appendix G describes each individual GR, its current status, and function in narrative format. For each GR, the underlying problem and its resolution are described, along with the reasons and justification for the resolution action. These reasons and justification show that all record deficiencies resolved by GRs have no adverse implications for hardware quality.

2) Specific Resolutions After resolution of more than 58,000 record deficiencies by GRs, R the remaining deficiencies were resolved by specific resolutions.

These case-by-case resolutions resort to additional sources of information available to substantiate quality and resolve the record deficiency. The specific resolution process consists of four basic approaches which can be used sequentially as necessary to resolve any particular deficiency. Each of these four basic approaches are described and illustrated in the following discus-sion:

e Resolution of the DEL item by the BA DRG reviewer by obtaining the necessary information from other documents in the traveler package being reviewed or from supplemental records. Examples of other documents that can be used include:

welder qualification log Q&TS certification matrix

- heattog VI-12

computer printout of the history of instructions and i

procedures material requisitions receiving inspection reports e Resolution of the DEL item by BA DEL resolution personnel by obtaining the necessary information from other

' documents in the traveler package or from supplemental records.

The DEL Resolution Group uses the same methods as the BA .

. DRG reviewer in the approach described above. However, this group has more information and evaluations at its disposal. The BA DEL Resolution Group is comprised of Quali,ty Engineering and Resident Engineering personnel.

The 'BA DEL Resolution Group Quality Engineering was developed from the consolidation of Quality Control, Technical Services, and Quality Assurance Level 11 and 111 1- personnel who were previously assigned to DEL r'esolution l . activities. This group may review and evaluate drawings, procedures, and other revised documents against the stated deficiency to determine acceptability. This group performs further research and evaluations while the BA DRG n

l reviewer can only evaluate from reference tables and logs I '

contained within the BA DRG Program area.

e Resolution of the DEL ltem by obtaining the necessary I

information from reinspection of the stored or installed L hardware.

1-j' Most reinspections are conducted to provide additional I verification of heat number, serial number, or some form of material or part ID. These inspections are accomplished in i

VI-13 L

T accordance with applicable procedures and documented by one or more methods.. If the discipline DEL resolver per-forms the inspection, the results are usually documented on the DEL. If another quality group does the inspection, then a separate inspection report is generated and inserted in the

^

docun.ent record package.

e Cicsure of the DEL item by issuing an NCR for resolution of the deficiency.

The specific resolution approaches described above provide a controlled, systematic method for assuring that all deficiencies are properly resolved and that no questions remain as to hardware quality. The first two approaches to specific resolution were applied. to reyolve some 80,342 deficiencies. hardware R

inspections resolved another 1,470 deficiencies, and NCRs were used to resolva 1,780 deficiencies that were identified as having

. potential ha dware-related nonconformances. The NCRs were evaluated a$d none were determined to be safety-significant.

There e.re 5,324 record deficiencies that are open pending' lR resolution. The bulk of the open deficiencies have not been resolved because their resolution has not been necessary to , !

support system turnovers. Consequently, there is nothing inherent in these open deficiencies which would suggest that their resolution would be significantly different than the deficiencies which have been resolved. The 5,324 open DEL ltems are reasonably distributed in time and result from the lag time between identification and resolution with no other imposed R

priority. In order to evaluate the potential impact on overall nonconformance rates due to lack of closure of these DEL items,  ;

the rate of NCR generation for closure of those DEL items between January 17, 1985, and March 17, 1985, was examined.

VI-14

During this period,24,000 DEL items were resolved, resulting in 303 NCRs. Projecting this NCR rate to cover the balance of open R record deficiencies would add 67 NCRs to the total generated by the Record Verification Program to date. This would increase the overall program ratio of NCRt per inspection attribute by only 0.0009E Moreover, the nonconforming conditions identified R were similar in kind to those already observed in the evaluation of the overall population for the program. Finally, the distribution of record deficiencies by work item for old and new work was consistent with the distribution observed in the evaluation of the overall program. This confirms that the evaluation of results presented in this report is not significantly affected by the existence of pending record deficiency resolutions. Nevertheless, these deficiencies will be resolved, and the results will be evaluated and documented.

In conclusion, with the exception of the 890 NCRs, the record lR deficiencies identified by the Record Verification Program do not have adverse implications for hardware quality. For the 890 R NCRs, it has been shown in subsection 2 above that none of the nonconforming conditions were safety-significant.

3. Basis for Confidence in Acceptability of Records The evaluations of deficiency rates discussed above indicate that a small portion (0.6%) of the record . deficiencies identified in the Record R Verification Program involve potential hardware-related nonconformances and thus result in NCRs. More importantly, the evaluations of the hardware-related nonconforming conditions identified in those NCRs showed that none of the nonconforming conditions were safety-significant. This affords a high level of confidence in the ultimate quality and safety of CPS hardware.

VI-15 i

_ _ _ _ . _ , _ , _ _ _ . _ _ _ _ . . . _ . _ _ _ _ _ _ _ _ _ _ ~ . . _ _ _ , _ _ _ _ . _ _ . . . _ _ . ._

On a secondary level of analysis, the overall deficiency rate for the Record Verification Program is low (1.9%), and the rate for new work is roughly a R factor of two less than for old work. This indicates that, in general, CPS construction QA records are of acceptable quality and that IP's l programmatic improvements and corrective actions in regard to Q/ scords I have been effective. The small rate of deficiencies identified by IP RRG reviews (0.11%) indicates that BA DRG reviews have been effective in R i

identifying record deficiencies. Evaluation of NCR and record defactency rates for both old and new work by discipline, by work item type, and by I checklist attribute isolated four areas in which further examination was R necessary to determine whether further action was warranted. That examination, however, indicated that no further action, beyond continuation of the program in those areas, was warranted.

The methods employed for resolution of record deficiencies have been effective in identifying potential hardware-related record deficiencies and in assuring that identified record deficiencies are properly resolved and do not have adverse implications for hardware quality.

The effective implementation of the Record- Verification Program is confirmed by the results of IP and BA QA audits and surveillances, third- I party audits, NRC inspections, and IP and BA corrective actions.

The Record Verification Program has been subjected to audits and surveillances by IP QA and BA QA, and audits by third parties. Since December 1982, IP QA has performed three audits and eight surveillances, and BA QA has performed four audits and nine surveillances. In 1982 and 1983, the Joint Utility Management Audit group audited the Record Verifi-cation Program. In April 1984,1. app-Rice-Staker Management Consultants performed a management assessment for the CPS project that included an assessment of Record Verification Program activities. The major findings t

VI-16

- - . . . . . _ ~ - . . . - - - - .

and recommendations resulting from each of these activities and the cor-rective actions taken by IP in response are briefly summarized in Table V!-1.

Since the beginning of the program, the NRC has conducted inspections that have included Record Verification Program activities. The results of these inspections are documented in NRC IE Inspection Reports 30-461/83-08,83-16,84-02,84-17, and 84-43. One item of noncompliance was identified by investigation of record verification activities. This finding represents an isolated occurrence and not a generic deficiency in the program. No corrective action is anticipated. No other items of noncompliance have been identified. There are, however, three specific items which remain open from these inspections: 84-02-02, 84-02-04, and 84-17-03. A brief description of each open item and the associated corrective actions taken by IP or the IP action plan and schedule for closure on each item is given in Table VI-2.

The results of the evaluation of the safety significance of NCRs; deficiency rates and trends; resolutions of deficiencies; and audits, surveillances, and inspections together confirm that the Record Verification Program has been effectively implemented and that the program affords high confidence in the quality of CPS QA records.

C. CONCLUSION This evaluation of the results of the record verification program shows that:

e None of the potential hardware-related ncnconformances resulting from record reviews are safety-significant. That is, if the nonconforming conditions were left unidentified by the Record Verification Program, no adverse effect on plant safety would have resulted.

e The rates of record deficiencies identified in the program are low, no adverse trends are evident that warrant further action, none of the -

VI-17

record deficiencies identified in record verification reviews have adverse implications for hardware quality, and none of the 890 NCRs R contained safety-significant deficiencies.

e There is adequate confidence in the acceptability of the CPS construction QA records.

VI-18

l

-Tame V5-l ,

Escued Umrifscatism FWeyann Ass 3d Seemits_and Cervedive Artisms Dates Total Activity Qumptity Performed Fandsnes Ressats Corrective Action IP QA and BA 17 4/23/83 21 No maior findings requiring rereviews e Training was increased .

. surveinances identified S/3/83 e Instructions and procedures were '

Minor findings were categorized as revised and clarified 5/6-9/33 follows:

e Upper management directives

1. S-9/33 e Administrative deficiencies were issued 10/27/83 e t.ack of a&erence to instructions or e Checkout logs were established procedures It/22/83 e Chedlists were reviwd to provide o Chedlist inadequacies adequate controls to ensure 12/2/83 accountability and review of e Inadequate implementation of documents 12/26-30/33 generic resolution e Generic resolutions were revised

.l/5-10/84 to ensure proper irnplementation 3/25-29/14 e Controlled manuals were reviewed and verified as complete and 3/23-4/I434 accurate 3/31/34 e In several instances, no corrective action was necessary because 4/9-10/84 existing administrative controls were more than adequate 5/18-21/s4 5/24-6/I/s*

1. 5/st .

7/27 and 3/2I-22/84

a.c=4 warme==- re.orasIaMW a.mt me-n. and cws.es-. ace.as

?

Dates Total Activity Quantity Performed I indinrs Results Corrective Action IP QA and MA QA 7 7/6-12/33 16 No mijor findangs requiring rereviews e increased training in specific areas Audits identitied (i.e., administration and 3/IS-23/83 instructions and procedures) was I Minor findWs were categorized as incorporated into the training 9/21-10/5/33 follows: prograrn

! 10/19-21/83 e Administrative deficiencies e instructions and procedures were

! revised and clarstied 1/23-25/84 e Lack of training e Entry and/or process instructions 6/5-15/S4 e Lark of adherence to instructions or were printed on back of forms used procedures 3/27-30/34 e Department responsibilities were e inadequate procedures reassigned

! LRS management I 4/84 0 No major findings requiring rereviews The following resulted from the assessment identified recommendetions:

revnew LRS conssitants recommended: e Removed duplication of functions in TPRG and DRG e Consahdate all dorismentation verificats and centrol into one e Checklists used by TPRG and DRG organization were revised to be consistent e Interchange of personnel between e DEL resolution was removed from TPRG aruf DRG to redste incen. QC and placed under Quality sistent practices Engineering where it will receive a higher priority and higher level of e Improve the QC inspection support attention to receiving dimtation and DEL resoluti<wn e Second-shif t support of Q & T5 organizations to DEL resolution shcusid be increawd JUM A third-party audit 2 9/13-17/82 0 No major findings requiring rereviews IP was developing a ec. Aasive identified records management plan using the services of consultants with expertise Rece....a-Ad IP review the programs ' from other projects used by other utilities in the records retrieval / turnover documentation area The IP plan addressed the need for the followig

i hp3d4 l

Tdte 45-1 Receed War'ar=neen preyamo Cacemets and Carvective Actions Dates Total Activity guantify Performed Findings Itesults Corrective Action e A system for the BA QA final review of incoming safety-related, augmented class D (radioactive

[

' waste), and fire protection records e A system for transfer of records from BA and S&L e A system for handling records generated dsing the startup program o A system for handling records generated during operation, maintenance,and modification 9/26-30/83 The records management and document N/A

• • wnover as planned appears to adequately address IP gsality and hardware support regsirements ERA %CO I I/I6/84 0 No mapw findings reqesiring rereviews RA aggressively pursued the hiring of Thar<s-Party Cost identified additsonal review personnel A Estamate and Con- resolution group has been established struction Schedule It was re, e.. .. -4 4 that RA re- to ensure timely resolution of defi.

Evaluation evaksate stat f ang icvels, both present ciencies. RA added 23 personnel to and proiccted, and increase staff DRC as of 7/30/84.

aggropriately to enuwe timely completion of att requared QA records review ,

Hartford Steam Basler 2 3/I2-14/34 I No significant findings concerning BA BA DRG personnel were instructed to Impectaan and Insurance DRG were identified enstre that all change documents Co. ANSI WM.0 10/I5/94 attached to a traveler are closed out Audits One finding concerning change documents (NCR) identifacd. During the final review of a traveler by DRG, the attached NCR was a " reference only - Not to be used for construction" copy and was not ianal reviewed by Q& TS.

Page4of4

-Table VI-I~

Record Ve-ification Prograrm Audst Rcsalts and Corrective Actions O

r Dates Total Actisity Quantity Per f ormed f~sndq Ress!ts Cortective Actinn i

I IP specht revicw of I If 4 to 4 No major findings requiring rereviews e Additional record types were SA DRG isnal review 4/I3/34 identif aed identified for review check hsts With some enceptions, the applicable e Diecklist revised to provide 1 DRG checkints,along with the general adequate controls to ensure (hecklist, med with the corresporufirg accountability and review of BQAl-l10-series instruction by trained documents arei qualified reviewers, are capable of, and wahd for, determining and ensuring e Instructions and procedures were the completeness, traceabelsty, revised and clarsiied leghihty, and accountabelety of records in the package for shech they were e Training was increased entended. The euceptions were d4wumented as IP Q A surveillance Iwmfangs and categorized as follows:

e Records not addressed by ur covered in the IM DRG checklasts e SSt.-approved arut status-stamped cwees of DRG cherklists mere not on f ala in the d.rument record renter e 5.peref rherklasts not efeleted from approved instructson e Checkhsts <w instructions were laciang specsfac points or d<wuments to be (hecked or revsewed

Page I of 2

-Table V1-2 f

@C.,_EM_s Concetmng ite&d Verirscation Progra_m -

NRC IE Date of Report # inspection R esults Status Comments SG/461/8%CS 6/21-25/81 No items of CImed noncompliance were identif sed 50 461/Skl6 9/Ibl6/83 No items of Closed IP met the requirements for overinspection and noncompliance document review program as described in the CAL of

=cre identified September I,1982 05/461/34/02 9/18-20/84 No items of Closed dring routine inspection Open item 50-461/84-02 procedures BQA 184 and noncompliance 50-441/84-15 perf armed on 5/24- BAP 2.1.1 appeared to require lurther clarification md were identified 25/8%. revision. BAP 2.1.1 was revised 2/13/84 stipulating in

$cction 6.2.1 the method in which the applicable disciplines review exception list items, including the document distribution order. BQA 184 is in the process of being revised, deletmg the portion of the job description for Levels 11 and III regarding the interpretation and evaluation of results.

Awaiting closure of 50.55(e) 50-461/84-02 Cable tray structural support report whit to is estimated to be traceability answered by 4/15/85. lg Closed dring routine impection Open item 50-461/84-02 The generic resolution 50-461/84-15 performed group supervisor was previously in the process of 5/24-25/84. 4xumenting the 10 CFR Section 50.55(e) review for a!! Generic Resolutions. During the inspection, the insocetor determined that the Generic Resolution Group supervisor has reviewed all generic resolutions for 10 CFR Section 50.55(e) applicability. This review has been documented. The inspector reviewed generic resolutions I, 3,10,15, 20, 24, and 39.

CAR 162 was generated which 50-461/84-02 DEL generic resc lutions are not requires a rereview of all generic adequately supported by document justafication.

resolution corrective actions, such as training and survei!Iance. CAR 862 was closed on 4/1/85.

R

W TaMr Vl-2

• BBC E Reports Caecesisu Record VerWecatism Rugrasm NRCIE Date of ,

Report # bispection Results Status Comments 6/Il-15/84 No items of Awaiting NRC evaluation of 30-MI/84-17 Open item: The BA Document 50-MI/84-17 Review Program generates DEL items. Recently, the noncompliance proposed corrective action per were identified C. Anderson letter CEA-1732334, unresolved backlog DEL curve is increasing while the dated 7/13/Sg number of DEL items per document package is decreasing. The NRC inspector believes that these two conditions are contradictory.

One item of Evaluation has been completed BA has accepted documents for 3/4" ASME valves.

50-%I/St-43 12/3-14/84 Five certifications of compliance /conformance, which noncompliance and response is in preparation.

was identified Preliminary aswssment is that contained no dates, were provided as back-up to ASME related to 14A finding was related to s@- NPV-l data report. BA DRG failed to identify the DRG piementary data and not part of missing informati< n.

sequired documentation to be reviewed as per the approved rimilist.

Talde VII-2 Charrent Status of IP Piogrgsfer Reporting Concerns System QumEty W ty kiitiation Quality Non-QuaEty Total Investigations Concerns Concerns System Date Concerns Concerns concerns C-- . :ed seestantiated Se6stantiated Quality report 2/82 75 49 124 122 17 of 75 14 of 47 IP QA hotline 11/83 12 9 21 17 2 of 8 4 of 9 g SafeTeam 6/84 988 321 1,109 770 34 of 659 44 of Ill, This table reflects the status of concerns as of March 8,1985. lR

1 APPENDIX D -

OVERINSPECTION PROGRAM SUPPLEMENTAL INFORMATION Contents P_ age A. Sufficiency of Data from the Overinspection Program for Purposes of Evaluation of the Quality of Construction D-1 B. Engineering Evaluation of Nonconformances by Type of Commodity D-3 C. Nonconforming Attribute Types D-19 D. Nonconformance Reports Containing Insufficient Information D-26 E. Evaluation of the Quality of Augmented Class D (Radioactive Waste) and Fire Protection Systems D-29 Tables R Table D-1 Number of Attributes inspected by Construction Discipline D-31 Table D-2 Number of Attributes Inspected by Type of Major Commodity D-32 Table D-3 Nonconforming Attributes by Commodity D-33 D

APPENDIX D OVERINSPECTION PROGRAM SUPPLEMENTAL INFORMATION A. SUFFICIENCY OF DATA FROM THE OVERINSPECTION PROGRAM FOR PURPOSES OF EVALUATION OF THE QUALITY OF CONSTRUCTION Baldwin Associates (BA) and Illinois Power Company (IP) have conducted more than 2 million inspections under the Overinspection Program as of December 31, 1984.

R Moreover, as is demonstrated in Table D-1, BA has inspected at least 200,000 attributes in each of the major construction disciplines. Given the.large number of attributes inspected within each discipline, any significant adverse condition applicable to a class of attributes should be identifiable.

In order to confirm that the inspection samples were sufficiently comprehensive within each discipline, IP has calculated the number of attributes inspected under the Overinspection Program for each type of major item within the scope of the program. The results are presented in Table D-2. As this table demonstrates, each type of major item has had at least 2,000 attributes inspected by BA. Any signifi- R cant adverse condition applicable to a type of item should be evident from such a large number of inspections. Thus, sufficient data are available to evaluate the quality of each type of item with 2,000 or more inspected attributes.

lR Statistical analysis lends support to the judgment that sufficient data from the Overinspection Program are available for analysis. The large number of attributes inspected under the Overinspection Program permits judgments regarding the quality of construction of Clinton Power Station (CPS) to be drawn with a high degree of statistical confidence. For example, based on an overall total of 1,672,414 R attributes inspected by BA, and assuming an infinitely-sized lot, statistical analysis predicts that the rate of conformance in the lot would have a maximum uncertainty D-1 1

O of only 0.08% at the 95% confidence level.I For a type of item such as mechanical R

equipment that has been subject to relatively few inspections (3,491 field verification inspections of attributes), the maximum uncertainty in the conformance rate is reasonably low at only 1.7% at a 95% confidence level. These small R uncertainties indicate that sufficient data are available for evaluation from the Overinspection Program as of December 31,1984. R As of December 31, 1984, the Field Verification Group had inspected over 50% of the structural steel, cable tray, instrumentation, and large bore pipe; 40 to 50% of the mechanical equipment and mechanical supports; 20 to 30% of the cable, R electrical equipment, small bore pipe, and HVAC duct; 10 to 20% of the cable terminations, electrical hangers, and HVAC hangerst $ to 10% of the conduit; and less than 5% of the instrument pipe. Given the large number of inspections that have been conducted, these percentages permit reliable conclusions to be drawn on both a statistical and judgmental basis.

I At the 95% confidence level, the maximum uncertainty is determined from the following equation:

U = 1*9N x 100%, where 2o = N[p(1-p)} = .25N and where U = maximum uncertainty in conformance rate at a 95% confidence level o = Standard deviation N = Number of inspected attributes p = Probability that an attribute is nonconforming D-2

B. ENGINEERING EVALUATION OF NONCONFORMANCES BY TYPE OF COMMODITY The results of the Overinspection Program were evaluated for each type of commodity within the program. The number of nonconforming attributes for each type of commodity (including augmented class D [ radioactive waste] and fire R

protection) is presented in Table D-3, together with an indication of the number of nonconformances that have been determined to be safety-significant. As is evident from this table, none of the commodities contains any safety-significant nonconformances. For each commodity (except augmented class D [ radioactive waste] and fire protection which are discussed in part E below) a discussion is R provided which explains, in general, why the nonconformances are not safety-significant.

1. Conduit Supports The Overinspection Program identified 10,223 nonconforming attributes on R conduit supports. As is discussed below, nc ' of these was safety-significant.

Approximately one-third of the nonconformances were minor, involving documentation nonconformances (such as unsigned travelers), minor damage (such as gouges), and installation errors (such as tolerance nonconformances, wrong welds, and wrong hardware). These types of nonconformances generally do not significantly reduce the strength of the conduit support since the attributes in question have little or no bearing on support strength.

Approximately two-thirds of the nonconformances (6,607 in total) pertained to lR arc strikes and welds between the conduit support and the supporting steel. Of these, 2,689 nonconfor~mances were arc strikes and weld profile violations that R generally are cosmetic and do not reduce the strength of the weld. Most of the remaining welding nonconformances involved weld size, undercut, slag, and other discrepancies which were determined to reduce the strength of the weld but not to affect the capability of the weld to satisfy design loading conditions. None of the nonconformances was determined to be safety-significant.

D-3

2. Cable Tray Hangers -

The Overinspection Program identified 1,164 nonconforming attributes on lR cable tray hangers. In general, these nonconformances were similar to trose identified on conduit supports. Approximately 53% of the nonconformar ces R were minor, having little or no relationship to the strength of the hangers. The remaining nonconformances all pertained to discrepancies in the welds attaching hangers to supporting steel. All of these welding nonconformances were either cosmetic or did not reduce the strength of the weld below that required to satisfy design loading conditions. Consequently, none of the nonconformances was determined to be safety-significant.

3. Cable Tray One hundred thirteen nonconforming attributes were identified on cable trays lR by the Overinspection Program. As is discussed below, none of these was safety-significant.

Seventeen nonconformances involved the lack of proper support for cables which drop out of the bottom of ladder-type trays. This support was only required to prevent the weight of the cables from bending the supporting rung of the cable tray. These nonconformances were determined not to affect the function of the cables or the cable trays' ability to function as designed.

Forty-seven nonconformances involved dirt and debris in cable trays. This R condition, though not desirable, was evaluated as having no impact on the system design capabilities.

The remaining nonconformances involved missing or incorrect tray l

identification tags or cable wear strips, an inspection error dealing with cable R t routing, or tolerance violations. All of these were shown not to af fect the tray design capabilities or the subsequent installation of cables in the trays because (1) other documentation properly identified the trays, (2) the wear strips provide an extra measure of cable protection, but are.not necessary in and of themselves, (3) the cable routing was verified to be correct, and (4) the tolerances were not exceeded by a significant margin and the affected items ,

were capable of performing their design functions.  !

l D-4 1

l

4. Electrical Equipment (Elec trical Boxes, Switchgear, Panels, Motors) R

a. Electrical Boxes Seven hundred twenty-one nonconforming attributes were identified on R electrical boxes by the Overinspection Program. As is discussed below, none of these was safety-significant.

One hundred seventy-three nonconformances involved damage such as lR dents or arc strikes and gouges on pull boxes or junction boxes or associated supports. The damage was minor and did not affect the functional capabilities of the boxes.

One hundred thirty-eight nonconforming attributes were identified in the lR welding for structural attachments and supports for the electrical boxes.

These nonconforming items were evaluated and determined to provide adequate strength to support the electrical boxes.

Sixty-four nonconformances involved documentation nonconformances such as missing dimensions on drawings, threaded fasteners not having R

identification markings, or boxes with incorrect, damaged, or missing identification labels. Drawings with missing dimensions were evaluated to determine if the missing information was critical to the installation of the electrical box or if the existing dimensional information was adequate to allow proper installation. Threaded fasteners were previously-dispositioned "use-as-is" on the NCRs and, therefore, were found to be acceptable with no replacement required. Boxes with incorrect, damaged, or missing labels were all properly identified on the installation drawings R which were used to verify that the installed boxes were correct. In all cases, the nonconforming conditions involving documentation on electrical boxes were minor and had no impact on the design function.

Three hundred forty-six nonconformances involved electrical box lR installation discrepancies, such as installation outside of specified tolerances and wrong or missing hardware. The tolerance discrepancies were evaluated for possible structural impact on the support member to D-5

which the electrical box is attached. In all cases, the as-installed condition had negligible effect on the supporting member. Wrong and missing hardware discrepancies primarily involved washers used on electrical boxes. Many washers were not installed per the detail drawings, or a material was substituted other than that specified per the details. In all cases, other notes existed on electrical drawings which either allowed the material substitution or made installation of the designated washer an option. None of these nonconforming attributes was found to be safety-significant.

b. Switchgear Two hundred twelve nonconforming attributes were identified by the R Overinspection Program on the switchgear. As is demonstrated below, none of these nonconformances was safety-significant.

Sixty-five of these nonconforming attributes involved the switchgear hold- lR down welds. Although these nonconformances were postulated to reduce the strength of these welds, all nonconforming welds were found to be l

acceptable due to the large margin between the calculated stresses in the welds and the . maximum allowable stresses in the welds permitted by the applicable code.

Eighty-six nonconforming attributes involved loose, missing, or incorrect lR hardware, such as nuts, bolts, and vibration washers. In each case,'the strength or vibration damping of the affected connection was determined l to be sufficient to satisfy design loads and damping requirements.

Twelve nonconforming attributes involved insulated low voltage wires 1 which touched bolt threads. An inspection showed that the wires were touching but not resting on the bolt threads. Also, the bolt threads were dull and were not causing any damage to the wire insulation. Thus, these nonconformances were not affecting the design function of these wires.

Twelve nonconforming attributes involved low voltage molded case panet R

circuit breakers. Six breakers were missing shunt trips which were in the i

D-6 l

• - - .w- -

7 p-, *+- -_a _

process of being replaced when inspected under the Overinspection Program; thus a valid nonconformance did not exist. Five attributes involved breakers with the wrong size trip elements. These breakers are primarily for short circuit protection of the connected low voltage circuits, and subsequent pre-operational inspection and/or testing would have discovered and corrected these five nonconformances. One attribute was a circuit breaker that was being scraped by opening and closing a cubicle door. The function of the breaker was unimpaired by the scrapes and was evaluated to be of no safety significance.

Eight nonconforming attributes involved documentation non-conformances. Six attritiutes involved missing nameplates; in each case other documentation, such as installation drawings, was available to verify proper identity. Two documentation nonconformances were for R incorrectly designated equipment locations on the cable tabulation. The as-installed condition was acceptable and the cable tabulation was corrected.

Eight nonconforming attributes involved damage to switchgear, such as oroken door latches, bent door panels, or cracked switch handles. Each of these conditions was evaluated and had no impact on the proper operation of the switchgear and, therefore, was of no safety significance.

The remaining nonconforming attributes involved loose terminal strips or damaged hardware (such as screws). Any movement of the loose terminal strips would have been restricted by wire training and wire wraps used to hold in place the conductors terminated on the terminal strips.

Addi ionally, any possible movement of the terminal strips would not l affect the function of the switchgear because the movement would not be sufficient to disrupt any connections. Similarly, the damaged hardware were located in a door-locking device that did not affect the operation of the switchgear. Consequently, the loose terminal strips and damaged hardware were not safety-significant.

D-7

c. Electrical Panels -

Four hundred fifty-five nonconforming attributes on electrical panels R were identified by the Overinspection Program. As is discussed below, none was safety-significant.

Two hundred forty-six of the nonconformances involved missing washers R on bolts. The evaluation of these nonconformances found that the structural integrity of the bolts and the seismic capability of the panels were not affected.

Fifty-six nonconformances involved missing or loose bolts and screws on panel-to-panel connec'tions. The results of the evaluations show that these

.nonconformances had no impact on the panel's dynamic qualifications.

Eight nonconformances were attributable to inspectors who interpreted R documents incorrectly or too stringently. None of these cases involved hardware that did not satisfy design specifications or drawings.

Eight nonconformances involved incorrect or missing identification tags, R but this equipment was properly identified on the drawings. Consequently, none of these nonconformances was safety-significant.

Eighty-six nonconformances involved panel hold-down welds. An analysis R I was performed which showed that the panels would have remained fixed at all four corners during a seismic event. Consequently, these nonconforming welds did not affect the design function of the panels.

Nineteen nonconformances involved damage, such as rust, bent doors, and scratches on panel surfaces, which would not affect the design function of the panels. R Finally, none of the remaining miscellaneousi nonconformances in  :

electrical panels were determined to be safety-significant. )

l D-8

d. Motors -

Nine nonconforming attributes were identified on a non-safety-related, non-seismically-designed HVAC motor. Eight of these involved minor damage to the steel motor support and one was a missing motor hold-down R bolt. None of these nonconforming conditions affected the function of the motor or the integrity of the support.

5. Conduit Fifty-nine nonconforming attributes were identified on conduits by the R Overinspection Program. As is discussed below, none of the nonconformances were safety-significant.

Eighteen of the nonconforming attributes involved documentation. Sixteen nonconformances were missing or contained damaged conduit identification labels. However, in each case, other documentation, such as installation drawings, was available to verify the identity of the conduits. The remaining two documentation nonconformances included an incorrect conduit elevation on the installation drawing and an alternative bonding jumper installation on a flex conduit. A review of applicable installation drawings showed that the as-installed condition of the conduit was acceptable and that the conduit elevation on the installation drawing should be revised accordingly. Also, the alternative conduit bonding jumper installation is now an accepted practice and installation documentation has been revised accordingly.

R Thirty-seven of the nonconforming attributes involved conduit installation discrepancies, such as installation outside of specified tolerances, loose or missing hardware, or bend radius violations of flex conduit. The tolerance l

l discrepancies were evaluated and found to satisfy the requirements of the design as installed. Loose and missing hardware discrepancies normally involved conduit fittings used on conduit terminations at electrical boxes. The loose fittings were evaluated and in each case found not to affect the proper

! operation of the circuit since the conduit is adequately su > ported by the electrical box and conduit supports. The missing fittings irvolved conduit l

bushings which are, used for additional cable protection but are not necessary to the function or protection of the cables. These cases were evaluated and D-9

found to 'have no safety significance. The minimum bending radius discrepancies of the flex conduit were evaluated and found not to affect the integrity of the cable within and hence were considered not to be safety-significant. R The remaining four nonconformances involved dents or nicks on flex conduit or rigid steel conduit. The dents were very small and did not affect the integrity of the conduit.

6. Cable The Overinspection Program identified 533 nonconforming attributes affecting R cable. As is described below, none of these nonconformances were found to be safety-significant.

One hundred forty-eight of the nonconforming attributes involved documen- R tation nonconformances, such as the absence of or damage to a cable's identifying tag. Since other documentation verified that the correct types of cable were properly installed, this type of nonconformance did not affect the cable's capabilities.

One hundred thirty-one nonconforming attributes were attributed to missing hardware, including missing edge guards for cables, missing cable supports, and R missing ground wires. Edge guards provide an extra margin of cable protection, but each multiconductor cable and each conductor's insulation was provided with a protective jacket. Thus, the conductor insulation, as per design, was adequately protected even though some edge guards were missing. With respect to the missing cable supports, the cable manufacturer's cable support requirements are less restrictive than project requirements.

When missing supports for cables were evaluated against the cable manufac-turer's criteria, it was determined that the cables were adequately supported.

Instances of missing ground connections on cable tray sections and on a flexible conduit connection were noted. These giound connections are R

installed to provide a primary grcund path for fault currents and also to provide far personal safety. Alteinative ground paths' were determined to D-10 L

provide adequate grounding and this condition was found not to be safety-R significant.

Twenty-five small cuts were reported in the insulation of the conductors near R the termination points. These cuts, which did not remove any insulation, were on conductors whose insulation is rated 600 volts (the applied voltage was only 125V DC or 120V AC, which is far lower than the rated 600 volts). Also, the cuts in the insulation were all located inside a junction box, termination cabinet, or other such controlled environment which would prevent further damage. The locations of all cuts were evaluated and found not to provide a grounding fault path. Thus, none of these nonconformances affected the design function'of the cables.

One hundred and twenty-one gouges and dents were reported in the outer jacket of cables; however,100 of these were accounted for by one low voltage instrumentation cable and the gouges were determined to be cosmetic damage R

to the jacket.' The conductor insulation was not damaged on any of these cables; therefore, these nonconformances would not affect the design function of any of these cables.

The remaining nonconformances included incorrect, improperly installed, or loose hardware, which were primarily cable grips; and cable routing errors (in the routing itself or in bend radius). Each of these was evaluated and determined to have no safety significance.

7. Cable Terminations Four hundred eighty-four nonconforming attributes in cable terminations were lR identified by the Overinspection Program. As is discussed below, none of these nonconformances was found to have safety significance.

One of the more frequently occurring nonconforming attributes (9%) involved R lugs that were not tightly connected to the terminal' block (inspector could move the lug from side to side). However, all lugs used were of the ring-tongue type, which were specifically used to prevent the lug from coming off of the terminal block even if the hold-down screw is not properly tightened.

Thus, electrical continuity was ensured.

D-Il

~ _ .- -- _ _ _ _ - - _ .

Other nonconformances (31%) involved conductor termination errors. IP will R be conducting preoperational system testing which will include operation of all interlocks, alarms, lights, and relays. This will ensure construction completeness and proper :ystem operation and will identify nonconformances involving electrical termination errors. Consequently, these nonconformances ,

were not safety-significant because they would have been identified and corrected even if the Overinspection Program had not been performed.

Discrepancies concerning bending radii of the control conductors near the

~

termination point comprised 9% of the nonconformances. The specifications R for bending' radius at CPS are more conservative than required by the manufacturer. The actual bending radius was compared to the manufacturers' requirements and 11 were found slightly to exceed those requirements. These were further reviewed and found to be installed in a physically protected and controlled environment. Consequently, even if the insulation at the bend were to have developed a crack, the connection would not have been grounded.

Bent lugs comprise 4% of the nonconformances in cable terminations. R Information furnished by the suppliers of these lugs showed that these bends did not adversely affect the integrity or function of the lugs. Consequently, none of the bent lugs were safety-significant.

Approximately 19% of the nonconformances involved wire crimps in which*the lR wire did not extend out the far side of the lug barrel. However, in each case, it was determined that the wire was firmly secured in the lug barrel, and, therefore, the termination was able to perform its design function.

An additional 5% of the nonconformances involved documentation errors such lR as missing wire code labels. These tables are only for later convenience in maintenance and checkout. They are not needed for correctly terminating the wire. ,

About 13% of the discrepancies involved use of mechanical compression lR connections instead of ring-tongue lugs. However, use of the compression D-12

connections was permitted by the equipment supplier. Thus, these terminations were capable of performing their intended design function.

Approximately 8% of the nonconformances pertained to spare conductors, R trimming and cosmetic scratches to the lugs, untidy bundling of conductors in panels, and missing wear strips. Spare conductors, trimming of lugs to fit the terminal block, and cosmetic scratches would not prevent the terminations from meeting their design requirements. Neat bundling of conductors is not necessary but is desirable to facilitate later checkout and maintenance. Also, wear strips are an extra measure of protection for the control wire, but are not necessary because the wires are provided with a tough outer jacket which pre.ents' damage to the underlying insulation. Consequently, none of these nonconformances was safety-significant.

None of the remaining 2% miscellaneous nonconformances was determined to R be safety-significant.

8. Structural Steel The Overinspection Program identified 24,067 nonconforming attributes on lR structural steel. As is discussed below, none of these nonconformances was found to have safety significance.

Approximately one-half of the nonconforming attributes (11,975) involved R welding nonconformances. Most of the welding nonconformances were insufficient weld size, undercut, or overlap. Insufficient weld size included reouctions in the effective throat size of the weld, as well as the length of the weld. Undercut involved reductions in the effective thickness of the base metal. Both insufficient weld size and undercut can reduce the strength of the structural steel. Each nonconformance that a'fected strength was evaluated, and it was determined that the reduced capacity it.each case was sufficient to support the required loads. Finally, since S&L determined by a sampling program that overlap identified by the Overinspection Prg am did not mask lack of fusion or undersized welds, the overlap did not reduce de strength of the structural steel. Therefore, overlap nonconformances were not safety-significant.

D-13

The -secon5 largest category of nonconforming attributes identified in st'ructural steel involved installation nonconformances (5,773). This category R of nonconformance generally consisted of minor tolerance nonconformances or loose hardware. The tolerance nonconformances and other strength reducing nonconformances were reviewed, and adequate capacity was found in the structural members to accept the nonconformances. Loose hardware in structural steel normally consisted of loose high-strength bolts. While this condition may reduce the ability of the connection to perform as a friction connection, the connections had adequate capacity when the bolts were considered as bearing bolts.

The third largest category of nonconforming attributes identified in structural

,. steel. involved documentation (3,292). For the most part, these R nonconformances consisted of missing nut and bolt identification. Since these nonconformances did not physically affect the structural steel, none was found to be safety-significant.

The last category of nonconformances was damage (3,027). The majority of R

the instances of reported damage to structural steel were arc strikes (1,840),

which are only cosmetic and do not reduce the capacity of the structural steel.

The other cases of damage were evaluated on a case-by-case basis. While some cases of damage did reduce the strength of the structural sttel, adequate reserve capacity was available for the structural steel to support the required loads.

9. Piping The Overinspection Program identified 1,185 nonconforming attributes on R

safety-related piping. As is discussed below, none of these nonconforming attributes was determined to be safety-significant.

The majority (744) of the nonconforming attributes involved minor damage to R pipe walls. Damage to pressure-retaining components was evaluated by considering if the , reduction in the wall thickness was acceptable considering the minimum allowable wall thickness. Arc strikes constituted almost all of D-14

this type of damage and were determined to be acceptable based on the minimum allowable wall requirements for piping. The gouges, scratches, and cuts in piping also were judged to be acceptable based on minimum allowable wall thickness requirements.

One hundred forty-seven welding nonconformances affecting piping were lR evaluated. About one-fourth of the nonconformances were determined to be localized cosmetic surface defects, such as concavity, porosity, and surface slag. For more severe welding problems involving overlaps, undercut, lack of fusion, and undersized welds, localized pipe stresses were examined to determine the adequacy of the weld under all loading conditions. In no case was the applicable code allowable stresses exceeded.

There were 171 installation nonconforming attributes identified. These items were mostly due to small installation tolerance violations and loose botting. R These were determined to be acceptable. One hundred twenty-three documentation and procedural nonconformances were examined which required only " paper" corrections that had no impact on the physical design.

10. Mechanical Equipment Mechanical equipment consists safety-related valves, pumps, HVAC fans, other miscellaneous equipment, and equipment foundations. Two hundred thirty-one nonconforming attributes were identified that affected mechanical R equipment. The majority of these items (134) dealt with missing or damaged identification tags and arc strikes on equipment and valve bodies. The arc strikes were evaluated to be acceptable within the original design basis since none violated minimum wall thickness for the valves in question. The missing or damaged identification tags had no impact on the design function of any component. The remainder consisted of miscellaneous types of nonconformances, none of which were evaluated to be safety-significant.

11. Instrument Tubing .

Ninety-five nonconforming attributes were identified by the Overinspection R

-Program in instrument tubing. The primary nonconforming attributes involved damage and installation nonconformances.

D-15

Damage to instrument tubing was primarily due to arc strikes. All damage penetrating into the exterior wall of the tubing was evaluated for minimum wall violations. No arc strikes caused the minimum wall thickness to be reduced below that required by the design. Therefore, these nonconformances R were not safety-significant.

Nonconforming attributes identified in the installation of instrument tubing were comprised primarily of improper slope and, in some cases, inadequate clearance. Installation nonconformances were evaluated to determine the affect on the design function of the instrument line in the overall system performance. It was determined that all lines with improper slope could still perform their design function, and all nonconformances were found to have no safety significance. Most clearance problems involved instrument lines in contact with conduit supports or with insulation from surrounding piping.

These interactions were evaluated to assess potential impact on the tubing.

R The evaluations indicated that the structural integrity of the tubing would be maintained, and that none of the installation-related nonconformances was determined to be safety-significant.

Finally, some welding nonconformances were identified, primarily involving concavity in welds. None of these was safety-significant.

12. Piping Supports A total of 6,299 nonconforming attributes were identified by the Fi Overinspection Program in piping supports. The largest number (2,667) of nonconforming attributes identified were in the welding area. The next most

. prevalent nonconforming attributes were in the area of damage (2,056) and R

installation nonconformances (1,458).

Welding nonconformances on pipe supports primarily involved undersized welds, overlap, undercut, and slag inclusion. When the nonconforming welds could not be determined to be acceptable by other means, the nonconforming welds were evaluated by comparing the actual weld stresses (excluding damaged areas) to maximum stresses allowed by design. This comparison D-16

verified that sufficient margin existed in the nonconforming weld and the

' remaining welds on the support to preclude failure of the support.

Over 27% of the nomonforming attributes involved arc strikes. The majority R of the remaining damage was comprised of gouges, defects caused by grinding, and bent component items. Arc _ strikes and gouges were evaluated to determine the effect of the reduction in base metal on the support's design capacity. No support was found to have sufficient _ reduction in base metal to cause any piping support to fail. None of the remaining damage was determined to be safety-significant.

Installation nonconformances on pipe supports involved loose or incomplete hardware installation, incorrect adjus'tment of supports, lack of clearance or interference, and construction tolerance nonconformances. Each nonconform-ing condition was evaluated to determine if the nonconformance was of a type that would be specifically examined in subsequent preoperational testing. For example, inspections that specifically check for hot and cold positions of adjustable support components would ensure that proper construction tolerances and construction completeness are verified prior to operation.

Consequently, these nonconformances were not significant because they would not have been left unidentified and uncorrected if the Overinspection Program had not been performed. For supports which are not adjustable, such as rigid or welded supports, specific preoperational programs to inspect for proper installation and fitup do not exist (other than 79-14 walkdowns conducted on piping and support systems). In these cases, the nonconforming attributes were evaluated for their impact on the structural integrity of the support and the complete piping system. Several nonconformances were for clearance requirements on guide or " box" type supports. These conditions required a detailed evaluation of specific load increases on adjacent supports and the R structure and detailed reanalysis of the affected piping system. In no case was a safety-significant condition identified among the instal!ation n'onconfor-mances evaluated. .

l Documentation-related nonconformances accounted for less than 2% of pipe support nonconforming attributes and typically pertained to the lack of a D-17

welder ID or hardware ID tag. Since evaluations determined that all identifications required for safety-related hardware were recoverable from other records, there were no safety-significant nonconformances in this group.

13. HVAC Ducts and Duct Supports The Overinspection Program identified 2,893 nonconforming attributes in R HVAC. These nonconforming attributes affected both HVAC ductwork and the duct supports and primarily involved installation and welding nonconfor-mances. As is discossed below, none of those nonconformances was safety-significant.

Over half of the nonconforming attributes identified were minor tolerance violations, incorrect orientation or configuration, installation gaps in the R

ductwork, and loose, missing, or wrong hardware. The nonconforming conditions involving tolerance, orientation, and configuration were evaluated against the design drawings and were determined to have no impact on operational performance of the duct system or the support system.

Installation gaps occurred when ductwork sheet metal would deflect and not lie flat against a support or.when a small portion of the gasket used in companion angle mating surfaces was missing or damaged. These gaps were evaluated and R found not to affect the integrity of the companion angles or duct support system. Other hardware nonconformances involved duct companion angles for which design criteria had been revised subsequent to the performance of the Overinspection Program for the items. When compared against these revised criteria, the items were acceptable.

4

, Nonconforming attributes involving loose and missing hardware primarily l

l involved nuts and bolts used to connect duct companion angles. These were not tightened adequately, were improperly installed, or were missing from the connection. Wrong hardware was reported primarily for incorrectly-sized access door assemblies in the ' ductwork. None of these nonconforming attributes were determined to adversely affect the integrity of the connections or the function of the duct systems.

! D-18 l

i k m.

F'

' Approximately one-fourth of the nonconforming attributes involved welding ,

and consisted of minor nonconformance;in weld size and various weld defects, resulting in reduced capacity of the weld connection. Each nonconforming condition was evaluated to determihe if the connection, excluding the defective weld, would cause code allowable stresses to be exceeded. No nonconforming conditions were found to result in excessive stresses in the ductwork or support system.

Physical damage to HVAC ductwork and supports consisted mostly of scratches, gouges, arc strikes, and grinding marks. A number of pin holes in R ductwork were the result of abandoned insulation pins. All cases of physical damage were evaluated to determine if the integrity of the duct system was violated or if a reduction in strength of a duct support occurred as a result of base metal damage. None of the nonconformances was determined to affect the design function of the duct system.

14. Instrumentation Two arc strikes on instruments were identified by the Overinspection  !

Program. Neither affected the ability of the instrument to perform its design R function.

C. NONCONFORMING ATTRIBUTE TYPES Provided below are definitions of the various types of nonconforming attributes and a brief description of the nature of the possible impact of the nonconformances on the integrity of af fected items.

Arc strike: Damage on or adjacent to a weld resulting in localized ,

fusion caused by the inadvertent establishment of current between electrical arc welding equipment and a weld on base metal. in general, arc strikes are cosmetic defects. Severe cases of arc strike can result in a reduction in the volume of the weld or base metal.

i Convexity: Weld metal on the face or surface of a weld that is in excess of the weld metal necessary for the required weld D-19

size. Convexity results in a weld of poor appearance, but has no adverse effect on the capability of the weld to perform its design function.

Concavity: A condition where a weld face or surface has less weld metal than is required for the specified weld size. If severe enough, concavity can reduce the strength of the weld.

Slag: A nonmetallic material which results from the welding process. Slag is generally found on weld surfaces as a result of incomplete cleaning af ter the weld is made and, as such, is a cosmetic defect. If slag is entrapped in the weld itself, it reduces the volume of the sound weld metal and, therefore, the load-carrying capacity of the weld.

Undercut: A groove that is melted into base metal adjacent to a weld and that remains unfilled with weld rnetal.

~

Undercut may result in a reduced thickness of the base metal and may affect the strength of the metal.

Weld size: A welding attribute that identifies an inadequacy in the size, dimension, or length of a weld as specified by code or on the design documents. Inadequate weld size typically will result in a weld that will have reduced load-carrying capacity.

Lack of fusion: A condition in a weld when the base and weld metal fail to fuse during the welding process. Lack of fusion may cause a reduction in weld strength and, in the worst case, a potential for weld failure. .

1 Excessive weld metal that protrudes over the interface Overlaps .

of a weld and the adjacent base metal. Overlap is not a 1

l D-20 1

m concern unless it obscures lack of fusion or an insufficiently-sized weld.

Reinforcement: A condition in a weld due to the deposit of excess weld metal. Reinforcement does not cause a reduction in weld strength.

Porosity: Cavity type discontinuities formed by gas entrapment during the solidification of a weld. Porosity is a nonpropagating defect with minimal impact on weld capacity.

Crack: A linear discontinuity in material that reduces material strength and may propagate under stress and cause failure of an item. To determine if a crack will propagate, the localized stresses must be determined and a fracture mechanics analysis applied.

Cold set: . The position of a variable support when the piping system is at the temperature of the environment. This position is confirmed during preoperational testing to document functional capability and does not present a safety concern during construction.

Transition: The weld surface exceeds a 3 to i slope between two metals of different thicknesses. Typically, the strength of the weld is not reduced by improper transition.

Grinding: The base metal thickness of a commodity is reduced by abrasion from a grinding tool. The reduction in base metal could reduce the strength of a component.

Dent, bent, warped: The commodity has been dented, bent beyond specified limits, or warped, which could result in a reduction in D-21

design capacity, improper fit-up, or modification in the performance of an item.

Ovality: The flattening that may occur when a pipe has been bent. Excess ovality can hinder performance by re-stricting flow or causing localized overstressing of the piping system.

Gouge, scratch, cut: Surface defects in an item due to removal or severance of base material. These can result in a reduction in the strength of a component or provide a potential path for shorts in electrical components.

Bolts / nuts broken: A broken nut or bolt resulting in loss of connection strength.

- Coating missing: Paint, galvanized coating, or other protective coating missing from a surface specified to be coated. Typically, coatings are not required for the strength of a commodity, only for its protection against adverse elements. The specific purpose of each missing coating must be evaluated based on the intent of the original design specification.

Defective material: Material that does not satisfy all of the specified design requirements. This nonconformance presents a potential for a reduction in capacity.

Dirt / debris: Dirt or debris allowed to collect on an item in violation of storage and maintenance procedures. Typically, dirt and debris will not affect an item's structural integrity or component operation and is flushed out of a piping system during preoperational flushing.

D-22

Protection: Failure to protect an item from surrounding elements per established storage and maintenance requirements. Lack of protection could result in damage from subsequent work in the area.

Rust: Accumulation of iron oxide on the surface of an item.

Rust typically has no safety significance unless left for extended periods of time or allowed to become pervasive, reducing the strength of the component or hampering its operating characteristics.

Holes: An item has holes drilled through a surface meant to be free of holes. Holes can cause a reduction in strength.

ID missing /

incorrect / damaged: An item identification tag, nameplate, or label is either missing, incorrect, or damaged. This does not imply lack of material traceability. In most cases, the item can be identified through other documentation or field inspection.

Drawing incorrect: A fabrication or construction drawing does not correctly reflect the design. The drawing errors require review on a case-by-case basis to determine if the errors could cause a reduction in a component's capability to perform its design function.

Traceability: The ability to trace or verify through certified docu-ments that an item is constructed from the specified material. Incorrect material can result in various adverse conditions such as material incompatibility or strength reduction. In gene.ral, nonconformances involving lack of traceability can be determined not to be safety significant by conducting investigations to re-establish traceability, testing, or determining that

! D-23 4

traceability is not a requirement for the commodity identified.

Inspection error: This consists of nonconformance reports (NCRs) written incorrectly against a conforming attribute. Since no nonconformance actually exists, these NCRs have no effect on hardware quality.

Wrong hardware: Installation of items not specified or referenced on design documents, or substitutions of components not specifically allowed by appropriate codes or standards.

The impact of using the wrong items depends on the strength and capabilities of the substituted hardware. In some cases. the substituted hardware may actually have greater capacity than hardware specified in the design.

Hardware missing: Missing items required by design documents. The impact of the nonconformance depends on the function of the item and the existence of other hardware that serves similar functions (e.g., one missing bolt on a multiple

~

bolt connection).

Hardware loose: Items that are not adequately torqued or snug tight.

Loose hardware may reduce the strength of the overati connection.

Incomplete: Items or materials for which the installation has not been completed. In some cases, incomplete installation may result in a reduction in strength of the component.

Orientation /

configuration items which are not oriented or configured in accordance with design requirements. Typically, nonconformances involving orientation or. configuration involve cases in which construction tolerances were not specified for the installation or inspection process. Such nonconformances D-24

could potentially impact upon adjacent components or affect the function of, or stresses in, the nonconforming item.

Tolerance: Tolerance nonconformance involves installation of an item outside the dimensional envelope permitted by design. The actual location of the item must be evaluated to determine whether there is any change in ,

the stresses on the item or adjacent items.

Clearance /

interference: The space between two items is less than the minimum allowable space specified by design. The actual movements of the items during operating conditions, thermal transients, or seismic events must be evaluated to determine whether any interactions might result.

Slope: Incorrect slope of an instrument sensing line or other line requiring a slope for proper function. Improper slope could affect the function of the line.

Routing: The routing of a commodity (e.g., cable tray, conduit) does not agree with construction drawings. The as-routed configuration could alter support loads and stresses used in the original design analyses.

Bend radius: The bending radius of the electrical cables or electrical conduits are less than the minimum specified by design.

This could impact the ability to pull cables, but would not affect cable function if the cable is undamaged or if the cable is protected in a controlled environment.

Wrong welds: Welds installed were not the type specified (e.g.,

intermittent welds in !!eu of continuous welds). The 9

strength of the weld could be altered if the wrong weld is installed.

D-25

Caps (Installationh A gap which exists between two items that is not in accordance with design documents. The as-installed gap could impair the function of one or both of the items.

Thread engagement: When the threads of a bolt do not extend through the entire nut as required to provide maximum contact of load-bearing surfaces. This condition reduces the strength of the connection.

Gaps (Damageh A gap caused by damage to a supporting or interfacing concrete surface, such as by spalling of concrete caused by the heat generated in welding. The gaps in this category could cause a reduction in the ability of the concrete to support a load.

Termination / error: When electrical cables have not been connected to the correct terminals or were connected in an improper manner. This nonconformance could result in improper operation if not identified by subsequent testing.

D. NONCONFORMANCE REPORTS CONTAINING INSUFFICIENT INFORMATION Seven NCRs prepared during the Overinspection Program did not contain sufficiently R

detailed information for purposes of this evaluation, and the nonconforming item was reworked prior to commencement of the S&L evaluation. Therefore, it was not possible for S&L to evaluate the impact of those nonconformances on the integrity of the affected item. However, as is demonstrated below, except for the seventh R

nonconformance, S&L was able to determine that none of the nonconformances was significant to safety.

The first nonconformance involved a half-inch diameter stainless steel instrument tube in the main stream system that had " numerous nicks and gouges." The depth of the gouges was not documented on the NCR. The tubing was subsequently replaced, eliminating both the nonconforming condition and the information required to D-26

evaluate its significance. However, this particular instrument line is connected to one of four redundant first-stage turbine low-pressure transmitters. The pressure transmitters signal the turbine stop valve and control the valve fast closure trip bypass, using a two-out-of-four logic. As such, the signal from any one transmitter cannot initiate any plant system response. Consequently, even if it is assumed that this item would fail, failure of this item would not impact plant safety.

The second nonconformance involved a half-inch stainless steel instrument tubing line in the residual heat removal system which had several arc strikes. The depth of the arc strikes was not recorded on the NCR, and the tubing was subsequently replaced, eliminating both the nonconforming condition and the information required to evaluate it. However, even if it is assumed that this item would fail, the loss of this line would not impact plant safety. The line provides the residual heat removal pump minimum flow control valve positioning (open/close) signals, based on the low pressure coolant injection flow rate. If the instrument line lost pressure, the minimum flow control valve would be automatically closed and the full low pressure coolant injection flow rate would be provided to the reactor vessel.

The third nonconformance involved a half-inch diameter stainless steel instrument tube in the residual heat removal system which was observed to have several arc strikes on the tube wall. The depth of the arc strikes was not reported on the NCR and the tubing was subsequently replaced, eliminating both the nonconforming condition and the information required to evaluate it. Further evaluation of the tubing and the associated instrumentation indicated that, even if failure were postulated to occur, loss of pressure in the line would provide the permissive signal i

required for operational testing of the low pressure coolant injection valve. These permissives allow the operator to manually cycle the valve. The permissives are R timed for 15 minutes and are automatically negated after that. This test loop is not required during either plant normal or post-accident operating condition. Loss of pressure to this line would cause no automatic system response. Consequently,

. failure of this line would have no impact on plant safety and is therefore not safety-significant. .

The fourth nonconformance involved an arc strike on the diesel oil day tank IDG0lTB level sensing line. The depth of the arc strike was not reported on the D-27 l

i i

NCR and the tubing was subsequently replaced, eliminating both the nonconforming condition and the information required to evaluate it. Further evaluation of the tubing and the associated instrumentation indicated that, even if failure was postulated to occur, the loss of pressure in the line would cause the diesel oil transfer pumps to start and refill the day tank, replacing the leakage, and ensuring an adequate fuel supply to the diesel generator. Any such postulated leakage does not present a safety-significant condition from a fire protection standpoint since complete rupture of the day tank is a postulated event and adequate protection has been provided.

The fifth nonconformance identified a crack visible on the end of a load pin installed in the rear-end bracket assembly of a large-bore pipe support. No information was given regarding the depth of this crack, and the pin was subsequently replaced. It was, therefore, impossible to determine whether the condition was a simple surface defect or a more significant structural condition. Consequently, the support was assumed to fail and the piping system was analyzed in detail with this support removed from service. Analysis showed that even without this support, the system R loads were within design limits and would not impact the safety of the plant.

The sixth nonconformance involved a cut on a jumper wire inside the valve limit switch enclosure for valve IE12-F0278. The location of the jumper wire and the cut on the wire was not documented in enough detail to evaluate its significance.

However, in the event that the jumper would fail, the valve indicating lights on the Main Control Board would go out. Also, an alarm in the Main Control Room would be annunciated, indicating a loss of valve control power, and thus would be immediately repaired.

Valve IE12-F027B is the outboard containment isolation valve on the B-loop of the residual heat removal low pressure coolant injection line. This valve is open in all modes (normal and accident) of plant operation and can only be closed by independent operator action from the Main Control Room. Valve IE12F027B is provided to comply with 10 CFR 50, General Design Criteria 56. There are no design basis events that require closure of this valve. Therefore, this would not result in a safety-significant condition.

D-28

The seventh nonconformance also involved a cut on a jumper wire inside the valve limit switch enclosure for valve IFC037. The location of the jumper wire and the cut on the wire was not documented in enough detail to evaluate its significance.

Therefore, it is not possible to evaluate whether this condition might have been safety-significant. However, in the event that the jumper fails, the valve would fail in its current position and the indicating lights on the Main Control Board would go R out. Also, an alarm in the main Control Room would be annunciated, indicating a loss of valve control power. Valve 1FC037 is the inboard containment isolation valve on the reactor vessel pool flooding line. This valve is normally open and closes on a containment isolation signal. Automatic closure of outboard containment isolation valve IFC036 will provide for containment isolation.

E. EVALUATION OF THE QUALITY OF AUGMENTED CLASS D (RADIOACTIVE WASTE)

AND FIRE PROTECTION SYSTEMS The augmented class D (radioactive waste) and fire protection systems are not safety-related and have not been subject to all of the quality assurance provisions of 10 CFR Part 50, Appendix B. Consequently, the results of the Overinspection Program for the augmented class D (radioactive waste) and fire protection systems are discussed separately from the results for safety-related structures, systems, and components.

~

More than 77,000 attributes of the augmented class D (radioactive waste) system and 1,600 attributes on the fire protection system were inspected by the Field R Verification Group as of December 31,1984.

On the augmented class D (radioactive waste) and fire protection systems, 6,663 nonconforming attributes were reported. Of these, 2,637 nonconforming attributes R were evaluated by S&L. The remaining 4,026 nonconforming attributes could not be evaluated for significance because the nonconformance reports did not contain sufficiently detailed descriptions to permit performance of these evaluations.

Of the engineering evaluations that could be performed, the results are similar to their safety-related counterparts. Minor damage, such as arc strikes, gouges, and D-29 t

grinding . marks on the pipe surface, was involved in 1,506 of the nonconforming lR attributes. In all cases, it was determined that the minimum allowable wall thickness was not violated.

Seventy-seven nonconforming welding attributes were evaluated. While these lR welding problems may have resulted in a reduced weld capacity, in no case were the applicable code (ANSI B31.1) allowable stresses exceeded.

The 301 installation nonconformances associated with the augmented class D R

'(radioactive waste) and fire protection systems and components are primarily due to

. the increased use of flanged connections in these systems. Installation problems dealt with loose bolts, insufficient thread engagement, missing gaskets, poor alignment, or other flange-related problems. The flange-related problems that result in a loose or poor connection would have been discovered during the system hydrostatic testing and would have been reworked to an acceptable condition. All others were determined to be acceptable based on an evaluation. This group of installation problems was found not to be significant.

The Overinspection Program identified 953 nonconformances involving documen- R tation. The most prevalent documentation nonconformance dealt with use of a substitute bolting material. However, this material was previously determined to be generically acceptable. Another common type of nonconformance dealt with installed spool length that did not agree with the constructor's installation isometric drawing. However, the nonconforming spools were found to be in accordance with the design drawings, and the contractor's isometric drawings were reworked to reflect the design and the installed condition.

Of the nonconforming attributes not evaluated due to lack of information on the NCRs, 91% involved damage, 6% welding, 2% installation, and 1% documentation.

The description of the nonconforming attributes noted on these NCRs is similar to those already evaluated. Consequently, these nonconformances would not be expected to adversely affect the function of the augmented class D (radioactive R waste) or the fire protection system if lef t uncorrected.

D-30

Table D-1 Number of Attributes Inspected by Construction Discipline Type of Construction Number of Attributes inspection Discipline Inspected Field Structural 273,609 verification Electrical / instrumentation 690,387 Piping / mechanical 705,418 Total 1,672,414 R Overinspection Structural 366,085 Electrical / instrumentation 199,004 Piping / mechanical 164,968 Total 730,057

- a D-31

---wr .,m v- -w- yww p -- n--wp- +-- - -- y- - - -w-+ w w--g g w

c Table D-2 ' I Number of Attributes Inspected by Type of Major Commodity l Number of Inspected Attributes Commodity FV Of Structural steel 273,609 366,085 Cable 21,861 8,031 Cable termination 117,036 48,277 Conduit 22,717 1,056 Cable trays 37,092 0 Electrical hangers 403,546 107,460 Electrical equipment l 14,899 9,053 Instrumentation 6,465 613 R

instrument pipe 16,771 24,514 Large bore pipe 32,673 16,317 Small bore pipe 49,140 22,223 Mechanical equipment 2 3,491 416 Mechanical supports 3 326,096 102,344 HVAC duct 218,889 11,402 HVAC hangers 78,129 12,266 Total 1,672,414 730,057 l includes electrical panels, switchgear, and electrical boxes 2

includes compressors, pumps, valves, and miscellaneous equipment 3 1ncludes anchor plates, expansion anchors, pipe hangers, and instrument supports D-32 i

j

P:ga 1 cf 11 Table D-3 Nonconforming Attributes by Commodity -

Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Conduit supports Weld size 1,354 0 Undercut 1,128 0 Overlap 608 0 Convexity 7 0 Concavity 22 0 Lack of fusion 294 -

0 Porosity 8 0 Slag 755 0 Crack 29 0 Reinforcement 2 0 Wrong hardware 305 0 -

Hardware missing 94 0 Hardware loose 90 0 Incomplete 6 0 Orientation / configuration 188 0 Tolerance 869 0 Clearance / interference 31 0 Wrong welds 277 0 Gaps 206 0 Thread engagement 23 0 R Arc strike 2,600 0 Grinding 201 0 Dent / bent / warped 179 0 Gouge / scratch / cut 192 0 Bolt / nut broken 7 0 Coating missing 110 0 Defective material 48 0 Dirt / debris 11 0 Protection 1 0 Rust 37 0 Holes 116 0 Gaps (damage) 32 0 ID missing / incorrect /

damaged 292 0 Drawing incorrect 202 0 Traceability 37 0 Inspection error 62 0 Total 10,223 0 D-33 i

s

_ _ . . . - - , .n ,,-,.,.,,-,-_.--v-. , - . . . , - . , - , - _ . . , . - - . -

,,..,n-- n-, c. ,

P;ga 2 cf 11 Nonconforming Attributes by Commodity Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Cable tray hangers Weld size 270 0 Undercut 64 0 Overlap 43 0 Concavity 6 0 Lack of fusion 53 0 Porosity 7 -

0 Slag 35 0 Crack 2 0 Reinforcement 5 0 Wrong hardware 44 0 Hardware missing 83 0 -

Hardware loose 45 0 Incomplete 3 0 Orientation / configuration 22 0 Tolerance 91 0 Clearance / interference 3 0 Wrong weld 133 0 R

Gap 12 0 Arc strike 122 0 Grirding 24 0 Dent / bent / warped 9 0 Gouge / scratch / cut 16 0 Bolt / nut broken 1 0 Coating missing 2 0 Dirt / debris 1 0 Holes 6 0 Caps (damage) 5 0 ID missing /incor.ect/

damaged 18 0 Drawing incorrect 13 0 Traceability 1 0 Inspection error 5 0 Total 1,164 0 D-34

P:go 3 cf 11 Nonconforming Attributes by Commodity Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Cable Tray Wrong hardware 2 0 Hardware missing 28 0 Hardware loose 3 0 Orientation / configuration 1 0 Tolerance 21 0 Clearance / interference 1 0 Dirt / debris 47 0 ID missing / incorrect /

damaged 8 0 Drawing incorrect 1 0 Inspection error 1 0 Total 113 0 Electrical equipment Weld size ;20 0 Undercut 84 0 Overlap 25 0 Lack of fusion 11 0 Slag 9 0 Crack 1 0 Reinforcement 4 0 Wrong hardware 124 0 Hardware missing 361 0 Hardware loose 43 0 g incomplete 8 0 Orientation / configuration 48 0 Tolerance 172 0 Clearance / interference 18 0 Wrong welds 15 0 Gaps 19. O Thread engagement 9 0 Termination Error 1 0 Arc strike 61 0 Grinding 8 0 Dent / bent / warped 55 0 Gouge / scratch / cut 17 0 Bolt / nut broken 12 0 Coating missing 26 0 Defective material 18 0 Dirt / Debris 2 0 Rust 2 0 Holes 32 0 Gaps 3 0 l ID missing / incorrect /

( damaged 40 0 Drawing incorrect 35 0 Traceability 1 0 Inspection error 13 0 Total 1,397 0 D-35

P;g2 4 cf 11 Nonconforming Attributes by Commodity Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Conduit Hardware missing 4 0 Hardware loose 8 0 Incomplete 1 0 Orientation / configuration 18 0 Clearance / interference 1 ,

0 Wrong welds 4 0

Thread Engagement 1 0 Dent / bent / warped 2 0 Gouge / scratch / cut 1 0 Defective material 1 0 ID missing / incorrect / -

damaged 16 0 Incorrect drawing 1 0 Inspection error 1 0 Total 59 0 Cable Wrong hardware 23 0 R Hardware missing 114 0 Hardware loose 2 0 Incomplete 17 0 Orientation / configuration 12 0 Tolerance 17 0 Clearance / interference 3 0 Routing 22 0 Bend radius - 25 0 Dent / bent / warped 6 0 Gouge / scratch / cut 141 0 Defective material 1- 0 ID missing / incorrect /

damaged 121 0 Drawing incorrect 13 0 Inspection error 14 0 Total 533 0 D-36

P:ge 5 cf 11 Nonconforming Attributes by Commodity Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Cable terminations Wrong hardware 65 0 Hardware missing 20 0 Hardware loose 43 0 Incomplete 44 0 Orientation / configuration 15 0 Tolerance 93 0 Clearance / interference 3 -

0 Bend radius 43 0 Termination error 106 0 Dent / bent / warped 18 0 R Gouge / scratch / cut 5 0 Bolt / nut missing 1 0 -

Defective material 3 0 ID missing / incorrect /

damaged i1 0 Drawing incorrect 4 0 Traceability 1 0 inspection error 7 0 Total 484 0 D-37

Prg2 6 of 11 Nonconformance Attributes by Commodity .

Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Structural steel Weld size 4,926 0 Undercut 4,744 0 Overlap 1,052 0 Convexity 38 0 Concavity 51 0 Lack of fusion 574 0 Porosity 90 0 Slag 275 0 Crack 111 0 Reinforcement 114 0 Wrong hardware 397 -

0 Hardware missing 526 0 Hardware loose 1,722 0 Incomplete 102 0 Orientation / configuration 169 0 Tolerance 1,310 0 Clearance / interference 57 0 Wrong welds 1,328 0 Gaps 143 0 R Thread engagement 19 0 Arc strike 1,840 0 Grinding 103 0 Dent / bent / warped 213 0 Gouge / scratch / cut 754 0 Bolt / nut broken 22 0 Coating missing 12 0 Defective material 50 0 Dirt / debris 21 0 Holes 11 0 Gaps (damage) 1 0 ID missing / incorrect /

damaged 3,157 0 Drawing incorrect 35 0 Traceability 70 0 Inspection error 30 0 Total 24,067 0 4

D-38

P ge 7 cf 11 Nonconforming Attributes by Commodity Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances Piping Weld size 75 0 Undercut 30 0 Overlap 4 0 Convexity 2 0 Concavity 9 0 Porosity 13 0 Slag 1 0 Crack 1 0 Reinforcement 9 0 Transition 3 0 Wrong hardware 11 -

0 Hardware missing 13 0 Hardware loose 51 0 incomplete 6 0 Orientation / configuration 46 0 Tolerance 20 0 R

Slope 14 0 Bend radius 2 0 Thread engagement 8 0 Arc strike 655 0

, Grinding 24 0 Dent / bent / warped 13 0 Gouge / scratch / cut 37 0 Defective material 2 0 Protection 13 0 ID missing / incorrect /

damaged 77 0 ,

Drawing incorrect 27 0 Traceability 8 0 Inspection error 11 0 Total 1,185 0 i

D-39

7-Page 8 of 11 Nonconforming Attributes by Commodity

. Number of Number of Safety Significant Commodity Attribute Nonconformances Nonconformances Mechanical equipment Wrong hardware 8 0 Undercut 13 0 Overlap 2 0 Concavity 2 0 Lack of fusion 2 0 Hardware missing 4 0 Hardware loose 3 0 Incomplete 1 0 Orientation / configuration 10 0 Tolerance 2 -

0 Clearance / interference 2 0 Arc strike 91 0 Grinding 2 0 Dent / bent / warped 1 0 Bolt / nut broken 2 0 Defective material 29 0 Protection 2 0 Gaps 1 0 ID missing / incorrect /

damaged 43 0 Drawing incorrect 6 0 g Inspection error 5 0 Total 231 0 Augmented class D Weld size 64 0 (radioactive waste) Undercut 41 0 cnd fire protection Overlap 31 0 Convexity 3 0 Concavity 43 0 Lack of fusion 43 0 Slag 3 0 Reinforcement 48 0 Transition 48 0 Wrong hardware 49 0 Hardware missing 31 0 Hardware loose 66 0 Incomplete 16 0 Orientation / configuration 104 0 Tolerance 27 0 Clearance / interference 9 0 D-40

Page 9 of 11 Nonconforming Attributes by Commodity Number of Number of Safety Significant Commodity Attribute Nonconformances Nonconformances Augmented class D Slope 25 0 (rrdioactive waste) Bend radius 1 0 (Cont.) Wrong welds 3 0 Gaps 12 0 Thread engagement 49 0 Arc strike 4,668 0 Grinding 46 0 Dent / bent / warped 17 0 Ovality 13 0 Gouge / scratch / cut 183 0 Defective material 5 0 Dirt / debris 6 0 Protection 3 0 Rust 1 0 Holes 6 0 ID missing / incorrect /

damaged 910 0 Drawing incorrect 31 0 Traceability 26 0 Inspection error 12 0 R Total 6,663 0 Instrument tubing Weld size 4 0 Concavity 11 0 Reinforcement 2 0 Orientation / configuration 1 0 Tolerance 1 0 Clearance / interference 3 0 Slope 36 0 Arc strike 27 0 Dent / bent / warped 2 0 Gouge / scratch / cut 3 0 Dirt / debris 1 0 ID missing / incorrect /

damaged 1 0 Drawing incorrect 3 0 Total 95 0 D-41

l Page 10 of 11 Nonconforming Attributes by Commodity Number of Numb'er of Safety-Significant Commodity Attribute Nonconformances Nonconformances Piping supports Weld size 1,019 0 Undercut 602 0 Overlap 742 0 Convexity 13 0 Concavity 2 0 Lack of fusion 97 0 Porosity 30 0 Slag 127 0 Crack 25 0 Reinforcement 9 0 Transition -

1 0 Wrong hardware 86 0 Hardware missing 79 0 Hardware loose 263 0 ,

Incomplete 18 0 Cold set 39 0 Orientation / configuration 83 0 Tolerance 476 0 Clearance / interference 186 0 Wrong welds 97 0 Gaps 90 0 R

Thread engagement 43 0 Arc strike 1,717 0 Grinding 91 0 Dent / bent / warped 46 0 Gouge / scratch / cut 158 0 Bolt / nut broken 1 0 Defective material 16 0 Dirt / debris 1 0 Rust 2 0 Holes 14 0 Gaps (damage) 9 0 ID missing / incorrect /

damaged 86 0 Drawing incorrect 27 0 Traceability 2 0 Inspection error 2 0 Total 6,299 0 D-42

Page11ofi1 Nonconforming Attributes by Commodity Number of Number of Safety-Significant Commodity Attribute Nonconformances Nonconformances HVAC ducts and Weld size 305 0 supports Undercut 126 0 1 Overlap 103 0 Concavity 2 0 Lack of fusion 153 0 Porosity 45 0 Slag 3 0 Crack 19 0 Wrong hardware 83 0 Hardware missing 176 0 Hardware loose -

220 0 Incomplete 47 0 Orientation / configuration 406 0 Tolerance 558 0 Clearance / interference 2 0 Wrong welds 9 0 Gaps 89 0 Thread engagement 5 0 Arc strike 91 0 R Grinding 81 0 Dent / bent / warped 32 0 Gouge / scratch / cut 140 0 Bolt / nut broken 1 0 Defective material 20 0 Holes 84 0 Gaps 34 0 ID missing / incorrect /

damaged 17 0 Drawing inc'orrect 36 0 Traceability 3 0 Inspection error 3 0 Total 2,893 0 Instrumentation Arc strike 2 0 Total 2 0 D-43

APPENDIX E RECORD VERIFICATION DATA This appendix presents the record verification data as of March 17, 1985, for re lution of onformance reports (NCRs) and as of March 3,1985, for record R

de tciencies generated from the Record Verification Program- (Part A) and a description of "Use As Is" NCRs as of March 17,1985 (Part B). The data are tabulated to establish the distribution of NCRs and record deficiencies by old and new work, by discipline, by item type, and by checklist category. '

A. DOCUMENT EXCEPTION LIST ITEM DEFICIENCY RATES R Table E-1 gives the number of NCRs developed by work item type and a breakdown between old and new work. Tables E-2 and E-3 give the status of the Document Review Group's (DRG) review and Records Review Group's (RRG) review, respectively, by discipline for total record attributes inspected and for old and new work. Table E-4 displays the distribution of new and,old work document exception list (DEL) items for DRG versus the total recordpttributes inspected by work item category. -

. 's Table E-5 gives the number of record deficiency reports (RDR) for old and new work versus the total number of attributes by work item category.

Table E-6 gives the distribution of DEL items for old work by checklist attribute in each work item category.

Table E-7 shows the same information as Table E-6 for new work.

A description of the checklist attributes used for Tables E-6 and E-7 is given in Table E-8.

Table E-4 gives the distribution of old and new work DEL items by work item.

Some individual categories of work items have deficiency rates which warrant further examination to determine whether further action is warranted in regard to the individual work item categories, as explained below.

E-1

1. Old Work

a. Cable Trays - The relatively high (11.5%) deficiency rate should be lR considered in light of the relatively limited data available for evaluation in this work item categcry to date. In addition, over 81% of R

the deficiencies involve accountability, completeness, legibility, procedure and drawing revisions, or non-checklist items. The resolutions of these deficiencies to date have indicateil no adverse-implications for hardware quality. IP is continuing to perform the R Record Verification Program for records related to cable tray old work and will perform additional evaluations as more record review data applicable to cable tray old work becomes available.

IR

b. Electrical Equipment - The 7.5% deficiency rate for records related to R

electrical equipment is concentrated in only 119 records. Most of the electrical work at Clinton Power Station (CPS) that is subject to the Record Verification Program is new work. The number of new work attributes reviewed is ten times that for old work and the deficiency R

rate for new work is only 1.3E Since only 11 NCRs resulted from record reviews related to electrical equipment and none were safety-significant, the continued performances of the Record Verification Program for records related to electrical equipment old work is sufficient to assure that the quality of these records is acceptable.

lR

c. Purchase Orders - Within the 5.4% deficiency rate, more than 66% of R the deficiencies involve such attributes as accountability, legibility, completeness, improper corrections, whiteout, and line-through. The resolutions to date have been shown to have no adverse hardware implications. Since only 123 NCRs resulted from the 25,336 record R deficiencies (0.5%) and none was found to be safety-significant, the continued performance of the Record Verification Program for old work purchase orders is sufficient to assure that the quality of these records is sufficient.

E-2

2. New Work Cable Trays - 82% of the record deficiencies that make up the 11.6% R deficiency rate involve such attributes as accountability, legibility, completeness, procedure and drawing revisions, and non-checklist items.

The resolutions to date have been shown to have no adverse implications for hardware quality. Only two NCRs resulted from the identified record deficiencies, and neither was found to be safety- significant. The continued performance of the Record Verification Program for records related to

~

cable tray new work is sufficient to assure that the quality of these records is acceptable.

R

3. Summary The individual work items generally show a decline in deficiency rates from old work to new work. In several cases (see attached Table E-4), there was a slight increase from old to new work, but that difference is not considered R significant in light of the nature and extent of the deficiencies identified.

All record deficiencies have a very low rate of potentially significant nonconformances. These low record nonconformance rates and the fact that no safety-significant hardware deficiencies have been found indicate that there are no adverse implications for CPS hardware quality and safety.

B. "USE AS IS" NCRs R As discussed in chapter VI, out of the total of 890 NCRs initiated from the R

Record Verification Program,585 were dispositioned not hardware related or "use as is" by Illinois Power Company (IP)/Baldwin Associates (BA) or Sargent & Lundy onsite reviewers. The distribution of these NCRs and a discussion of the rationale for disposition "use as is" is discussed below.

1. Process or Procedure Issues A number of NCRs,175, dealt with deviations from process or procedure R requirements. Examples of these are incorrect weld preheat, incorrect weld interpass temperatures, concrete placement time violations, or concrete curing temperature deviations. In all NCRs of this type, the impact of the process or procedure deviation was evaluated to have an acceptable impact E-3

on the finished product; hence, no rework was recommended. In the welding issues, the condition of the final welds were all determined not to impact the functional requirements of the item. On the concrete process questions, test cylinder results, rebound hammer tests, and other results were used to determine that no structural impact existed.

2. Material Specification, Substitution and Traceability issues In the broad area of material specification, substitution, and traceability, 177 NCRs were initiated and dispositioned "use as is." Examples of these R are deviations in specified materials installed, missing material traceability, and missing material code certifications. In each case, the NCR was evaluated and the replacement material determined to be one of the following: (1) acceptable for the function intended, (2) traceability not required or equivalent traceability established, or (3) downgraded code requirements acceptable for the function intended. In a few cases, a higher grade material was used and later verified to be acceptable. In all cases in this category, the issue was rigorously pursued and evaluations completed to allow a "use as is" decision, with no requirements for rework.

3. Sequence or Inspection Signoff issues and Traveler Entry Errors In the broad area of inspection or inspector signoff and incorrect traveler entries, !!O NCRs were issued. Use as is determinations were made using R additional follow-up information for all NCRs of this type. For example, for incorrect signoff sequence or hold points bypassed, the condition of the item was determined acceptable by subsequent inspection documentation.

For missing or improperly documented weld travelers, the correct information was recovered and, based on this information, no rework was required. Questions on welds or inspector certifications were later verified to be acceptable, and evaluations indicated no hardware impact.

4. Missing or incorrectly Documented Tests or inspections in 98 instances, NCRs were initiated due to missing or incorrectly 'lR documented tests, calibrations, or inspections. In each case, either an additional test or calibration was performed, a vendor statement of certification was received, actual test reports were recovered, or the test E-4

r ,

was determined not to be essential to the performance of the items. In each of these cases, a use as is determination was made based on equivalent or replacement documentation, and no deviation was found to put the item performance outside the plant design basis.

3. Drawing Issues in 25 cases, NCRs were initiated due to drawings that did not properly R reflect as-built conditions. In each case, a drawing discrepancy was identified and the as-built condition was verified as correct arid acceptable within the plant design basis. All of these NCRs resulted in use as is determination with no rework required.

6. Summary As a result of the Record Verification Program, 585 NCRs were initiated R l that originally raised potential questions as to the adequacy of quality documentation and ultimately resolved with a non-hardware or "use as is" I

1 disposition. In each case, the issue was rigorously pursued to determin's whether or not the item function would be impaired with respect to the plant design basis, the documentation was corrected, and none of the it< ems l required any rework within the process of NCR evaluation.

i i.

h

/

E-5 L~ . - _ - - - _ _ - . . . _

1 i

Table E-1 Nonconformance Report Distribution by item Nonconformance Rates by Type of item Per Attribute Old Work New Work Rate Rate item Attributes NCRs (%) Attributes NCRs (%) ,

Beams and structural steel 298,980 109 0.04 117,150 . 12 0.01 Civil-earthwork 374,578 73 0.02 17,986 1 0.01 Cable 5,962 2 0.03 241,724 3 0.001 Cable terminations 2,538 0 0 150,228 6 0.003 Conduit 0 0 0 126,820 1 0.007 Cable trays 590 0 0 20,330 2 0.01 Electrical boxes 0 0 0 39,216 0 0 Electrical hangers 585,808 73 0.01 498,060 9 0.001 Electrical equipment 10,115 11 0.!! 106,760 3 0.002 Instrumentation 85 0 0 14,535 8 0.06 Instrument pipe 56,508 5 0.01 502,656 16 0.003 P/M hydro packages 3,422 5 0.15 45,902 4 0.01 M 1.crge bore pipe 211,110 67 0.03 575,218 49 0.01 Small bore pipe 1,085,963 49 0.004 814,022 56 0.01 Mechanical equipment $4,166 12 0.02 88,298 15 0.02 Mechanical supports 136,009 42 0.03 731,759 88 0.01 Purchase orders (includes HVAC) 471,660 123 0.03 127,050 34 0.03 M:ggers/hypots (cable tests) 10 0 0 7,890 7 0.09 Miscellaneous *

(non-traveler) 0 0 0 79,440 5 0.01 Totals 3,297,509 571 0.02 4,305,044 319 0.01

• The number of attributes shown for old work in the February 1985 report was incorrect. Some travelers did not show a traveler type in the DRG printout which R caused them to fall in the wrong categories. These travelers have been corrected.

E-6

Table E-2 Document Review Status Document Review Group Distribution by Discipline Old New Wwk Wwk Total DEL Rate DEL Rate Discipline Attributes Attributes items (%) Attributes items (%)

Electrical 1,788,151 605,013 22,801 3.77 1,183,138 27,014 2.28 Piping / mechanical 3,745,874 1,490,675 22,434 1.5 2,255,199 20,941 0.93 Instrumentation 573,784 56,593 1,332 2.35 517,191 5,975 1.16 Civil / structural 808,694 673,558 14,492 2.15 135,136 2,558 1.89 Purchase orders (includes HVAC) $98,710 471,660 25,336 5.37 127,050 2,309 1.82 R M:gg:rs/hypots (cabl] tests) 7,900 10 0 0 7,890 287 3.64 Misc 11aneous' (non-traveler) 79,440 0 0 - 79,440 1,539 1.94 T tals 7,602,553 3,297,509 86,395 2.62 4,305,044 60,623 1.41

• The number of attributes shown for old work in the February 1985 report was incorrect. Some travelers did not show a traveler type in the DRG printout which R caused them to fall in the wrong categories. These travelers have been corrected.

E-7

Table E-3 l Document Review Status  ;

Records Review Group Distribution by Discipline Old Work New Work

. Total Rate Rate Discipline Attributes Attributes RDRs (%) Attributes RDRs (%)

Electrical 350,662 97,333 193 0.2 253,309 405 0.16 Piping / mechanical 689,637 331,244 256 0.08 358,393 234 0.07 Instrumentation 67,091 8,528 34 0.4 58,563 62 0.! !

Civil / structural 20,374 12,692 7 0.06 7,682 3 0.04 Purchrse orders (includes HVAC) 47,960 0 0 0 47,960 123 0.27 R Megg:rs/hypots (cabl2 tests) 2,786 0 0 0 2,786 1 0.04 Misc ll:neous (non-traveler) 82,800 0 0 0 82,800 35 0.04 Tctals 1,261,310 449,817 490 0.!! 811,493 868 0.!!

E-8

Table E-4 Document Review Status Document Review Group Distribution by Type of Item Deficiency Rates by Type of item Total Old Work New Work Attributes DEL Rate DEL Rate item Reviewed Attributes items (%) Attributes items (%)

Be:ms and .

structural steel 416.130 298,980 5,883 2.0  !!7,150 2,289 2.0 Civil-earthwork 392,564 374,578 8,609 2.3 17,986 269 1.5 C:ble 247,686 5,962 211 3.5 241,724 1,897 0.8 Cable terminations 152,766 2,538 32 1.3 150,228 836 0.6 Conduit 126,820 0 0 0 126,820 1,038 0.8 Cabl2 trays 20,920 590 65 11.5 20,330 2,358 11.6 Electrical boxes 39,216 0 0 0 39,216 263 0.7 Electrical hangers 1,083,868 585,808 21,729 3.7 498,060 19,219 3.9 Electrical equipment 116,875 10,115 761 7.5 106,760 1,403 1.3 Instrumentation 14,620 85 1 1.9 14,535 244 1.7 Instrument pipe 559,164 56,508 1,331 2.4 502,656 5,731 1.1 P/M hydro packages 49,324 3,422 29 0.9 45,902 547 1.2 R Lcrg? bore pipe 786,328 211,110 4,131 2.0 575,218 4,123 0.7 Sm:ll bore pipe 1,899,990 1,085,968 12,123 1.1 814,022 3,678 0.5 Mechanical cquipment 142,464 54,166 2,340 4.3 88,298 1,335 1.5 Mechanical supports 867,768 136,009 3,811 2.8 731,759 11,258 1.5 Purchase orders (includes HVAC) 598,710 471,660 25,336 5.4 127,050 2,309 1.8 M:ggers/hypots (c ble tests) 7,900 10 0 0 7,890 287 3.6 Misc:llaneous*

(non-traveler) 79,440 0 0 - 79,440 1,539 1.9 Totals 7,602,553 3,297,509 86,395 2.6 4,305,044 60,623 1.4

• The number of attributes shown for old work in the February 1985 report was i

incorrect. Some travelers did not show a traveler type in the DRG printout which R caused them to fall in the wrong categories. These travelers have been corrected.

1 E-9

Table E-5 Document Review Status Record Review Group Distributed By Type of item Deficiency Rates by Type of item Total Old Work New Work Attributes Rate Rate item Reviewed Attributes RDRs (%) Attributes RDRs (E)

Be:ms and structural steel 20,374 12,692 7 0.06 7,682 3 0.04 Civil-earthwork 0 0 0 0 0 0 0 Cab!] 57,671 1,072 2 0.19 $6,599 39 0.1 Cabl]

termination 38,967 62 0 0 38,905 65 0.17 Conduit 26,433 0 0 0 26,433 7 0.03 Cabla trays 3,725 0 0 0 5,725 39 0.68 Electrical boxes 7,200 0 0 0 7,200 1 0.01 Electrical hangers 189,034 94,261 181 0.19 94,773 205 0.22 Electrical equipment 25,632 1,938 10 0.51 23,674 29 0.12 Instrumentation 2,403 0 0 0 2,403 3 0.12 Instrument pipe 64,688 8,528 34 0.4 56,160 59 0.11 R P/M hydro packages 5,490 610 1 0.16 4,880 4 0.08 L rga bore pipe 102,592 34,808 41 0.12 67,784 44 0.06 Small bore pipe 348,080 250,526 167 0.07 97,554 47 0.05 Mechanical equipment 19,500 6,375 2 0.03 13,125 28 0.21 Mechanical supports 213,975 38,925 45 0.12 175,050 til 0.06 Purchase orders 47,960 47,960 I (includes HVAC) 0 0 0 128 0.27 Meggers/hypots 2,786 I (cable tests) 2,786 0 0 0 I 0.04 Misc:llaneous I

(non-traveler) 82.800 0 0 0 82.800 35 0.04 Totals 1,261,310 449,817 490 0.11 811,493 868 0.11 I Non-traveler items: old or new, not identified in data base t

E-10

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                                                           ' Table E-S CheckEst Attribeste Cromys Group Number              Checklist Group Description                                                     Comrcents
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      !       QA/QC/TS personnel certifications / qualifications         This is the review of quality-related documentation to ensure that non-certified Indiviesals did not sign for quality-related activities, and that impectica personnel did not exceed the limits of their certified capability,i.e., cross-discipline sigrwoff of quality inspections.

2 Welding informat m, welder qualifications, needed This is the review of quality-related documentation to ensure that the ID, and inspection required information for welder-listed variables and inspection personnel is correct for the weldmg process listed on the documentation. 3 Inspection reports / checklists supporting documen- This is the review of inspection documentation that checks for . tation compliance to the quality instructions and for inspection documentation that reflects the type of inspection performed. 4 Accountability, completeness, and legibilit y 1his is the review of quality documentation to verify that all documentation required by procedures, standards, and codes have been completed and can be read. J Improper corrections, whiteouts, line throughs, etc. This is a review of documentation to verify that correctsons were made by individuals authorized to correct errors or entries and to ensure that any obliterated data does not have an impact on the quality of the hardware. 6 Personnel sign-ofis, initial and final review, and This is a review to assure that all required hold or inspection points hold and inspection points were completed and that all necessary reviews were completed. This review is completed in conjunction with Groups I and 2. 7 Material traceability This is a review of material to verify that the material listed on the installation is traceable to the receiving or purchase documentation. Additionally, this review verifies that the material listed on the installation agrees with the material shown on design or installation drawings. 8 Procedure and drawing revisioris This is a review to verify that procedure or drawing revisions listed on the installation documentation are correct for the time period used. 9 Calibration This is to ensure that properly calibrated tools were used to perform quality impections. 4 1 1 E-I5

Page 2 of 2 Tame E-8 Oteckust Attribute Groups Group Number Checklist Group Description Comments 10 Change documents and AE review and concurrence, This is to ensure that the documentation package contains the correct engineering change notices, nonconformance re- change documents required for the installatlon, that the documents are ports, field change requests, field engineering referenced in the installation package and that all in-process drawing change notices, red-line drawings to blue-line changes have been incorpos ated into tb final blue-line drawing drawings, etc. contained in the installation package. 11 Inspection and test requirements This is to ensure that all tests and inspections required by procedures, codes, arut starklards have been completed and are documented in the traveler package and that the test is acceptable. 12 Vendor requirements This is a review of purchase and receiving documentation to ensure that all vendor- and site-generated documentation complies with the purchase order and that all procedural requirements have been complied with. 13 General items not covered by specific checklist This group is used for special cases not covered by a checklist attribute attribute in the preceding 12 categories. 14 Data base input errors This group accounts for errors in the computer data base caused by typographical keypunch errors or reviewer errors entered into the computer. b .I 1 E-16

APPENDIX F ANALYSIS OF RECORD VERIFICATION DATA BASE FOR SUFFICIENCY OF DATA The Record Verification Program has completed more than 7,600,000 attribute R cxaminations as of March 3,1985. As is demonstrated in Table F-1, at least 500,000 Ettributes have been examined in each of the major construction disciplines. Given the large number of attributes examined within each discipline, any significant rdverse record conditions applicable to a construction discipline class of attributes should be identifiable. In order to confirm that inspection samples were sufficiently comprehensive within cach discipline, Illinois Power Company has calculated the number of attributes cvaluated under the Record Verification Program for each type of major item within the scope of the program. The results are presented in Table F-2. As this table demonstrates, each type of major item has had at least 14,000 record attributes R cvaluated. in all categories except instrumentation, the number of record attributes examined exceeds 20,000. Any significant adverse record condition applicable to a R type of item should be evident from such a large number of record attributes cvaluated. Thus, sufficient data are available to evaluate the quality of records for cach type of item. Statistical analysis lends support to the judgment that sufficient data from the Record Verification Program are available for analysis. The large number of record attributes cxamined under the Record Verification Program permits judgments on the quality of construction records of the Clinton Power Station to be drawn with a high degree of confidence. F-1

For example, based on the overall total of 7,602,553 record attributes examined and R assuming an infinitely large lot, statistical analysis predicts that the nonconformance rate in the lot would have a maximum uncertainty of only 0.04% at the 95% confidence level.I For the instrumentation item category, which has the least number (14,620) of record attributes evaluated, the maximum uncertainty in the noncon-formance rate is reasonably low at only 0.8% at a 95% confidence level. These small uncertainties indicate that sufficient data are available from the Record Verification Program as of March 3,1985, to permit evaluation. R 1 At the 95% confidence level, the maximum uncertainty is determined from the fol-lowing equation: U = I j96 o x 100%, where o =N(p(1-p) max =.25N and where U = maximum uncertainty in nonconformance rate at a 95% confidence level o = standard deviation N = number of inspected attributes p = probability that an attribute is nonconforming i F-2

Table F-1 Number of Record Attributes Examined by Construction Discipline Construction Number of Discipline Attributes Evaluated Electrical 1,788,151 Piping / mechanical 3,745,874 Instrumentation 573,784 Civil / structural 808,694 R Procurement 598,710 Others 87,340 Total 7,602,553 s.

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Table F-2 Number of Record Attributes Examined by Type of Major Item Number of item Evaluated Record Attributes Beams and structural steel a l6,130 Civil-c ethwork 392,564 Cable 247,686 Cable terminations 152,766 Conduit 126,820 Cable trays 20,920 Electrical boxes 39,216 Electrical hangers 1,083,868 Electrical equipment 116,875 Instrumentation 14,620 R Instrument pipe 559,164 P/M Hydro packages 49,324 Large bore pipe 786,328 Small bore pipe 1,899,990 Mechanical equipment 142,464 Mechanical supports 867,768 Purchase orders $98,710 Others 87,340 Total 7,602,553 F-4

APPENDIX G GENERIC RESOLUTIONS IN THE RECORDS VERIFICATION PROGRAM Table G-1 lists the current status and function of generic resolutions (GR) in a narrative format. For each GR, the underlying problem and its resolution are described, along with the reasons and justifications for the resolution action taken. These reasons and qualifications show that all record deficiencies resolved by GRs have no adverse implications. GRs are numbered sequentially as they are prcposed. If a proposed GR is disapproved, the number is retired and not used again. The issuance and distribution of GRs are handled and controlled as a controlled document under standard Baldwin Assnciates (BA) document control procedures. GRs are prepared in a standard format which includes subject, references, problem description, resolution, and justification sections. Specific criteria and instructions are written in the resolution section so that the application and use of each GR can be clearly understood. Training in their use is an integral part of the program. Each controlled GR write-up includes references to applicable procedures, codes, and backup documentation. Underlying problems and root causes are presented, along with a detailed account of the resolutions. A justification statement must be included in each GR which explains why the resolution is suited to the problem. The justification includes accurate references to historical policy and policy changes, procedure and code citations, quotations or references to commitments from Illinois Power Company (IP) or the Nuclear Regulatory Commission (NRC), and explanations or clarifications of procedures, drawings, or systems. The GR acknowledges the role of quality assurance (QA) field verification in assuring project quality by citing specific QA field verification activities that will relate to the GR's subject. The Manager of Quality Engineering must evaluate each proposed GR and each revision for potential 10 CFR Section 50.55(e) and 10 CFR Part 21 reportability and must document the results in writing. These evaluations by the BA Manager of Quality Engineering, reviews and approvals by cognizant disciplines, and the concurrence of IP QA G-1

provide the controls and assurance that GRs do not affect the safety of plant operations or quality by violating established site commitments or procedures. Once approved, a GR is implemented into the Document Review Group (DRG) review process by training users to assure accurate understanding of the criteria for use, the reason and justification for its use, and when it cannot be used. Revisions to GRs are approved and implemented in the same way as new GRs. The GR Program assures that records accepted through the use of a GR acceptably document that the hardware was properly purchased or installed to i perform its safety-related function during operation. i G-2

Table G-1 Generic itesolutions Glt Subject Disciplinc I lleason/Probis rii Justification and Significance to Safety No. Itev. linproper corres.tions made (All) Correc tions, additions, and deletions Per site procedures, docunients that must be <_orrected i I to docurnents, including have been unproperly inade on docu- due to update or deletion of infornution, hunian error, correction fluid and tape nients. Ttus violates Arnerican or other stull be done by placing a single line through Natiorul Standards lac.titute (ANSI) the original entry, the date of the correction, and the N4).2.9 requirements, projwt initials of the individual rnaking the change. direc tives, and procedur es. Contrary to this, corrections, additions, and deletions luve been made on quality docuinents that did not coniply with site procedures. This Glt allows tiiese insiproperly (orrected docuenents to be reviewed and evaluated by a certified Level 11 or Level !!! reviewer. If the correction does not involve acceptability, traceability, identif u.ation of the hardware, vendor docmnents, or BA records and does not leave iride terriiiriate or idesitify a (otidationi found ta be potentially adverse to the quality, it niay be accepted. I C/5-Civil /Str uctural Iblilet trical P/M-Piping /Meclunical Pit O/SU B- Procurement /Subcon t rac t A L L-All disciplines G-3

Cerwr;c Resolutions GR Justification and Simpificance to Safety No. Rev. Subicct Discipline Reason / Problem i I (Continued) llowever, the reviewer evalutes the condition and : determines that hardware may be aflected. As nwn-

tioned above, he indicates the condition as a document exception list (DEL) item, which is then closed af ter initiation of a nonconformance report (NCR) that is used to bring the item back to a conforming condi-tion. Plant quality and safety at Clinton Power Station (CPS)is maintained with the use of this GR.

2 3 Illegible data on documents (All) Data on documents are illegible due The Level 11 reviewer evaluates and determines if the lR due to mishandling, poor to mishandling and poor obliterated entries af fect the acceptability, trace-reproductions, holes, folds, reprodiction. ability, or identification of the hardware, vendor tears, or creases records (documents provided by the t'ardware and material suppliers), and BA documents. BA documents art. records that provide architectural design criteria, construction, and quality inspection data. The data indicates the receiving, f abrication (putting material together to make a completed item), and installation status of items and equipment. If the obliterated entry does not allect the acceptability of the docu-mentation or hardware, or if other records within the traveler substantiate the missing information, no DEL item is required. When the obliteration nnkes a complete evaluation impossible or af fects the acceptability of a document or hardware, a DEL item is written. The resolution of the DEL item may be to insert a replacement copy of the document into the package. The replacement copy contains the legable data. If the item requires re-inspection by a quality inspector, the results are attached to the DEL to substantiate that the hardware is acceptable. G-4

4 1 Generic Resolutions 1 GR i No. Rev. Subject Dis _tipljine Reason / Problem ~ . Justificalion and Siciificance to Safety

    '3           Sane as GR2 (not issued)                                                                    The use of this CR relieves the reviewer of having to document each and every obliteration when it is clear that the obliteratioins do not affect the quality of the documentation or hardware installed in the plant.

6 2 Red-line as-built drawisigs (P/M) Augineetited clan D (radioactive CR 4 addresses the attachment of red-line con-in vaulted augmented class waste) travelers do not have struction drawings to a traveler when blue-line as-built D (radmctive waste) - complete blue-line as-built drawings drawings were required by an engineering job traveler packages as rsquired by Ji-P-020, althouyh instruction. Specificalion K-2832 and l'CR-18005 accept red-lire drawings. When drawings are issued by the design engineer to 4 construction, they are cominonly leiown as blue-bre drawings (because they have a blue tint). These

drawings give the construction infor nation tieeded to install the equipment. It is otten necessary to make field changes during installation.

These ch,4nges are noted on a blue-line drawing by using red ink or red pencil, thus giving the drawing the term, red-line. , These changes are approved by engineering and quality control (QC) prior to innplenentatson by construction. Af ter completion of the installation, QC uses tre red-I hne drawing for inspection and acceptance of the item. l When inspection and acceptance of the itean is 1 ' completed, the red-lire drawing becomes the reflection of the item as it is installed in the plant or , as-built. l 1 . as . J 1 a 5

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Generic Resolutions GR No. Rev. Sutdect Disciplire Reason / Problem Justification and Significarce to Safety 6 Not issued / I Absence of welder identifi- (C/S) QA/DRG is unable to verify welder The DEL items ttut stiinulated this GR were written cation (ID) on ANSI and (E) qualification for some welds on AWS in response to a ctecklist item that called for veri-American Welding Society (P/M) and ANSI related travelers where the fication of welder qualifications. Many travelers do (AWS) related travelers welder ID was not docuinented on not show welder ID, aruf, therefore, welder qualifi-the traveler, rations in these cases cannot be verified frorn the documentation. Both ANSI and AWS standards require that welder ID be placed either on the documentation or near the weld. Consistent with these requirernents, BA's general weldmg specification, BTS-401, requires only that the welder ID be placed adjacent to tie weld. Welder ID and qualifications are serified in the field by BA Technical wrvites (TS) welding inspectors per project procedure BTS-40). Accordingly, the absence of weider ID on tie traveler violates no requirernents and in no way comprormses the integrity of the docu-mentation of the quality of the welds. 3a 2 Level I inspection sign-ofis fC/S) Travelers and inspection docurnents Level I personnel have been trained and certified to on travelers and supporting (E) tuve been sigrmd of f by Leve! I L6.plem et inspection a^d test procedures and to re-inspection reports (P/M) inspectors without objective cord the results of such inspections. Alter the LevelI evidence of a Level 11 review. inspector implements the appbcable inspection pro-cedure, a Level 11 inspector evaluates the inspectiori results and docurnents their validity by signing the traveler " final review" block. G-7

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electrical, sinechartical, civil / structural), the docuisient reviewer does not docurnent this as an exception.

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Generac Resolutions - GR' , htification anni Simpiilicanct to fafety . Rev. Subject - Discipline Reasawi/Prubleni _No. 11' 2 Since GR 11, revision 2, was superseded by CR 10, revision 1, all descriptions and significance to di sign - and safety are contained within tie superseding CR. 124 2  : Incorrect revisions for (P/M) DRG reviewers were writing OliL GR 12a was initiated to cover cases of incorrect - M06, M0/, and isonietric iteins for incorrect M06, M07, and. revisions of M06, M07, and isometric drawings hsted in drawings on coinponent isometric drawing revisions listed in . the reference block of con ponent support (hanger) support travelers except the reference block on component travelers. This GR is not used for headfitting headlittings support travelers (excluding travelers. headiittings). These drawings are listed on component support travelers as references only, and the revision level is not a ' ways updated on the travelers. Tlw piping . drav. ngs show the layout of the pipe system including loca ion of the valves, fittings, component supports, etc. They do not govern the installation of the hangers and, therefore, do not directly affect the work per-formed in component support travelers. The construction and installation of a hanger is governt d by Sargent & Lundy's (S&L) hanger drawing included in the traveler package. This drawing gives the exact locations of the hanger attachments. Any changes to the referenced piping drawings that af fect the hanger design are incorporated by S&L in the hanger drawing. Quality of the hardware construction, installation, and acceptance is not af fected, ard, therefore, the use of this GR can have no impact on the safety of the operation of CPS. G-il _____________m

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Generic Resolutions CR No. Rev. Subject Discipline Reason /ihdalein Justification and Significance to Safety I/d O (Continued) M04 drawings concern equipnient ioundations and provide a means of identifying the location' of a piece of equiprnent. The lower nuinbered drawings hsted above are general in Kope, cover large areas, cited give the totation of several pieces of equipment. M04 drawings numbered 1037 and above contain this same informatios., plus greater detail. Any design change in the lower numbered drawings are incorporated into revisions of the higher numbered drawings. If the correct revision of them higher nurnbered drawings is listed m the traveler, the lack of (orrect revisions on the subject drawings can have no adverse impact oii the quality of construction or safety of operationi of the plant. If the currect revision of the higher nurntwred drawings is not hsted m the traveler, the QA/ORG reviewer will issue a DEL item and forward it to the DEL Resolution Group. I3 2 Deletion of QC and TS (P/M) QC and TS mspwtion personnel Inspection and sequence pomts were assigned to inspection and sequence marked "N/A" or lef t blank the in- certain inspection attributes during initial review of points indicated by initial spection/ sequence points on aug- augmented class D (radioactive waste) and fire review Level 11 on aug- enented class D (radkuctive protection travelers. These inspection points specify a mented class D waste)/ fire protection fabrica- particular attribute that must be inspected befase (radioactive waste)and fire tion / installation travelers (JV->77). work continues on other items or specifies a particular protection travelers sequence of events in the construction activity. G-14

Genieric Resolutions GR No. Rev. sus (t Discipiire Reavwi/Pruhk in Justification and Significance to Lfety 13 2 (Continued) QC and TS personnel nurked "NA"or lett blank tie inspection and sequence points that were designated by initial Level 11 review personnel on augniented class D (radioactive waste) and fire protection /fabri-cation / installation travelers (Forin JV-377). These conditions are docuinented as DEL iteins and accepted per GR 13 with the following chceptions:

                                                                          - Location and orientatiori, afigittiieint and con-figuration, fitut dimensions, or protective seals and covers. If these attributes are siot inspected ori tin-corresponding installation traveler, DELs are written and substintted to the DEL resolver group for resolution.
                                                                          - Skx k 8 of Forni JV->//, GR 13 applies to all stenis in block 8 other than " weld cornplete." If welding is perforrned, the weld toinplete block n ust be filled in or a DEL itein is subunited to the DEL Resolution Group. The only regtured sign-of f by < code or standard is " weld toniplete."

G-IS

         ._ _. _ . - _   , , . _           _. .    . . _ _    ,m          .

i l I 3 Generic Resolutions - i GR ' , m. Rev. . Subject Discipline Reason / Problem Justification and Sianificance to Safety i 13 2 (Continued) Fabrication travelers are inspected prior to installation travelers; therefore, the acceptance of the installation traveler would supersede the acceptarce ' of the fabrication traveler, The acceptance criteria is j the same for both travelers. A final review is perfornwd for each completed i traveler in accordance with site procedures by a , certified Level 11 inspector. This review includes, but is not limited to, verifying that all required inspections e have been completed and that deleted inspection and sequence points are not applicable. Tte Level 11 personnel performing firut review are trained and certified and have demonstrated capabilities in tie validation and acceptance of inspections, examinations, and test results. Therefore, the deletion of taese inspection poirits tus no adverse elfect on the quality of the plant or the

;                                                                                                            integrity of the applicable documentatior.

[ l t+ Not issued

1) Nt issued 1

1 l C-16

                                                                                                                                                                           'I i

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                                                          -                  -                  --       .--   4                                , _ _        , ,

- - - .. - - - _ - . . . - - - . . - .~ . . . . _ . . . - . . -. - - . - Genmc Resolutions GR gi. - Rev. Subyct Discs >line Neason/ Problem Justification and Sanificance to Safety 16 'O QA CR for discrepancies (PRO /SUB) ' QA GR for discrepancies involving JV-Ils is an obsolete checklist type forni that was mvolving the JV-lla form number JV-l18. used by procurement engineers as an aid to assure that (requisition / purchase order the information on a requisition was incorporated on [POJ review form) the PO. At no tirne did it provide documentary evidence of the quality of items or activities. Tie information provided on JV-II8 was a reiteration of the information provided on both the PO and the purchase requisition. Both the PO and the requisition dre subject to review for quality requirenents and require management level approval, which is authenti-cated by date and signature. The use of this CR does not compromise tte safety of the plant or of tte docurnentation because all quality-related requirements are extracted from approved codes, standards, and specifications, which in themselves are used by DRG for the review and approval of ste requisitions and PO, not the JV-113. 17 Not issued la 0 QA/DRG CR for cases (P/M) QA/DRG CR for cases wtere final CR 18 was initiated for cases where final cleaning was where firal cleaning was cleaning was desigruted as a designated as a sequence step on travelers, but was out - designated as a "sequer(e" "sequerice" but was not signed-of f. signed by BA inspection personnel. Per site procedures but was not signed-of f and directives, sequence points naust be signed and dated by authorized personrel. G-17

Generic Resolutions GR No. Rev. Subicct Discaphne Reason /ihelem Justification and Sistnificance to Lfety la 0 (Continued) Final cleaning is designated by S& L in Specification K-2832 as IP's responsibility. Though it is considered a procedural violation to leave a sequeire step blank, the quahty of the hardware is siot af fected in these instances because IP verifies that the final cleaning - during startup and pre-op testing fm been perfornied per design requirements. It was never the responsibility of BA and should not have been se-quenced on the travelers. Therefore, a deficiency of this nature can have no impact on the quality of documentation or construction nor on the safety of operation of CPS. 19 i Since GR 19, revision I, was superseded by CR 72, revision 0, all descriptions arx1 sigmficance to design and safety are contained within the superseding CR. 20 Itetracted This GR dealt with enaterial traceability or the lack of material traceability docurnented on NCRs or discre-pancy reports which were part of corrective action request (CAR)-073. The use of this GR did not com-promise the safety or design of the installation because the problems associated with material traceability on electrical installations prior to 1/1/54 have been resolved by CAR-073, NCR 23422, and GR 1f1. G-15

Generic Resolutions GR-No. Rev. Subint Diriphne Reasun/ Problem Justification and Sisiilicance to Lfety 21 -0. QA/DRG CR for items and (P/M) QA/DRG GR for items and materials Non-Safety RIR numbers (RIR numbers with an "N" materials with non-safety . with non-safety RIR numbers hsted prefix) do not denote a lack of QA involvement, receiving inspection report on augmented class D (radioactive (RIR) numbers listed on waste) travelers, form JV-377. The use of the non-safety RIR number was generated auginented class D by QC to document receipt of iterns and snaterials (radioactive waste) purchased in accordance with attachment A of the travelers, foran JV-577 procurement manual for ren-safety Pos. Becauw items and inaterials received un safety- and non-safety-related RIRs are mspected per the same criteria, it is assured that the implementation of this CR could have no adverse elfect on the design or safe-ty of the plant. 22 0 GR 22 addressed incorrect heat or RIR rusenbers on - elec trical installatioris. Since CR 22 was superseded by GR 111, all descriptions and significarce to design and safety are contained within the superseding GR. 23 Not issued 24 0 GR 24 addressed various sizes and dimensions of sheared plate installed in ciectrical installations without heat or RIR numbers for material traceability. Since CR 24 was superseded by GR 111, all descriptions and significance to design and safety are contained within the superseding CR. 25 Not issued G-19

                                                                                                                                                        ._a

      .                 .             ~ .    . _

i. 4

Generic Resolutions CR Rev. Subject Discipline Reason / Problem Justification and Significance to Safety 4

) 26 Not issued 2/ 1 Missing JV-146 forms and (PRO /5UB) Completed JV-146 and JV-133 forms GR 27 addresses two site documents: JV-146 (QA deleting duplicate data on tlkit are required to be iniclude d sii . docunientation checklist) and JV-l>$ (QC receiving JV-I46 ar.d JV-IS) forius record packages are missing. Also, inspection instructions). This GR is used where one or from scope of QA/DRG data on these forms is nnssing, both of these documents are missing frona record review incorrect, or has been improperly packages and for deleting duplicate data entries made ] corrected, etc., but this data is on these forms. Where one of these documents is duplicated data on other project missing, an acceptable copy of the missing original records. must be obtained, reviewed, approved, and inser ted in i the package or a new original must be initiated, reviewed, approved, and inserted in the package. 2 Certain data (e.g., re quisition nunibers, nanees of . suppliers, CPS unit numbers) appear on nunierous sitt-

documents (RIRs, the PO, the subcontracts, etc.) and j dre duplicated on both JV-146 and JV-13). The data do not significantly af fcct the quality of the plant, hardware, or vendor documentation as it is not used to accept or reject documents. The PO, subcontract, and RIR contain this same data and it is on these forms i that this data is reviewed and approved or rejected; therefore, no design or safety significance exists.

) 28 Not issued 29 Not issued G-20 i

I-J Ceneric Resolutiores

       .GR No. ~ Hev.             Nabject              Disciphne                 Rcason/Problesn           'lustification and Significance to %fety 30            Not issted 31     2-     Arrows, continuation lines,       (C/S)   Arrows, continuation lires, and ditto    Though the use of ditto nurks, arrows, and '

and detto marks used to E) nurks have been used to carry dat. . continuation lines is'a practice widely used in nuny carry data forward on flA (P/M) forward on llA travelers and other industries to signify inclusiveness, its u>e had rut travelers and checklists t hecklists, and their use is not been addressed by site procedures, codes, or directives addressed by codes, standdrds, etc. until 9/13/83, per memo .1F 34883. This policy mennoranduin accepts this practice for use on 13A documentation prior to 9/13/83, providing that af ter review by a certified Level 11 reviewer, the subject docurnentation is found to be legible and readily cornprehensible. Any other condition would leave the quality of the item indeterrninate and require that a DEL stem bei generated. This situation would autossiatically triake the item subject to reinspection or resolutton by an NCit where the quality of the hardware is deterinined . to be questionable. 32 Not issted 33 Not issued 34 Not issued G-21

Generic Resolutions

 .GR No. Rev.           Subject              Disciphne                Reason / Problem          Justification and Significance to Safety

3) 0 GR for acceptance of (PRO /SUB) CR for acceptance of LevelI ~ This GR was initiated to accept Level I inspector sign-Level I inspector sign-ofis inspector sign +fis on receiving ofis on receiving inspection docurnentation forms. The on receiving inspection m>pection documentation forms.

                                                                                            ' DRG will not write DEL items when the following docuenentation forms,                                                             conditions exist:

s

                                                                                             - RIR (form JV-132)is signed and dated in the
                                                                                  /f-           " inspected by" block by a Level I inspector and the
                                                                                               ." reviewed by" block is signed by a certified Level 11 inspector. Level I inspection personnel are trained and certified in accordance with industry standards, which allow a Level I inspector to implernent inspec-tions, examinations, and test procedures. The RIR is subject to a review by a Level!! inspector who evaluates the inspection results and documents their validity by signing the " reviewed by" block.
                                                                                             - RIR form JV-1 $) is signed, initialed, and dated by a Level I inspector and the " reviewed by" block on RIR form JV-152 is signed by a certified Level 11 on or df tt'r the Level l Inspection date. Receiving inspection instruction form JV-13) is part of the inspection documentation and must be attached to RIR form JV-IS2 at the time the Level 11 reviewer performs the documentation review. The Level 11 reviewer will not accept the documentation package without a completed JV-1)$ form. The Level 11 reviewer evaluates the inspection results recorded by the Level I inspector and documents their vahdity by signing the " reviewed by" block on form JV-IS2.

G-22

Generic Resolutions GR Subikt Disciphne : Reason / Problem Justification and Simnificance to Safety No. H ev. , 3) 0 (Contsued) - Script or printed naines or initials that are in agreement with the authorized signature card are acceptable, provided there is no disagreement noted with the authorized signature card, il a disagree- 'S ment does exist, the presence of a higher level _ .- review resolves the item. Incorporating this GR into the document review program does not adversely aflect the quality of the documentation or the physical integrity of the plant.

                 %                              1  Referenced change                                 (C/S)           Change documents, such as NCRs,          This GR has been issued because change documents i                                                   documents not in traveler                         (E)             deviation reports (DR), field change     that are required by procedure to be listed as packages                                          (P/M)           requests (FCR), field engineernig        attachments to a traveler package or that are not (hange notices (FECN), and               marked with " approved for construction" control stamp engineermg change notices (!!CN),        as required are not attached to the package. This required by governing procedures are     applies to travelers in the civil / structural, electrical, to be listed as attachesiesits to        and piping / mechanical disciphnes.

traveler pat ^kages and im.hxfed in the traveler packages. llowever, they This GR entares that traveler packages list and con-are not included in packages or are tain the required change documents in the followmg not sisarked with "opproved for manners construction" control stamps. The Level 11 or 111 reviewer must first determine that the suspect document is, in f act, required. If they are required but missing, the QA/DRG reviewer will obtain a copy of the change document and place it in this i package af ter verily mg that it is complete, closed by site procedures, and stamped " approved for 4 construction." C-23 1 a

Generic Resolutions GR _R e v__. Subject Discipline Reasosi/Pruhlem - Justification and Significance to Safety _No_ . .3, I (Continued) If the above conditions cannot be snet, a DEL item is  ! generated and remains open until the above requirements are satisfied. In this way, the quahty of the plant is assured and no design of safety significance exists. 37 Same as GR 13 (not issued) M Not issued 39 Not issued 40 0 Use of non-black ink on (All) Lise of non-blak ir.k on project ANSI and site requires that documentatian be suitable project records is deleted records deleted from the scope of for rnicrofilming. The onsite microfilm equipnient will from the scope of QA/DRG QA/DRG review. reproduce any color ink, and using black ink or non-review black ink will neither enhance nor detract from the quality of the documentation. The use of this GR, therefore, has no effect on acceptability of the documentation or on the quality of the hardware installed in the plant, and no design or safety significance exists. 41 0 Blank inspection checklists (E) Blank inspection checklists in As part of the initial traveler review (R/O of traveler), in electrical traveler electrical traveler packages. blank inspection checklists are inserted into the packages traveler package per project procedures. The requirement for placing blank checklists into the traveler for subsequent traveler revisions has been deleted. For subsequent traseler revisions, checklists will be added when necessary by the QC inspector at the time of inspection.

                                                                              ~~.

G-24

Generic Rewiutions GR- .

                                                                                                                         . Justification and Significance to Safety p.

f 'Rev. Subject - Discipline Reason /Probtern' 41 0 (Continued) Placing electrical inspection checklists into traveler packages at the time of the initial review is in complete accordance with project procedures. Deleting the requirement to add checklists at each initial review for subsequent traveler revisions does not af fect project quality. When a traveler is found with blank forms, initiated prior to the procedure changes, a Dtil item is written to document the occurrence it is resolved by accepting the package with the blank forms under this GR. Project quality is not adversely af fected, using the same logic as described above. 0 Verification of signature (All) Delete authorized releaw signature GR 42 deleted a requirement to use the authorized 41 and initials authorization list. release sigtkiture list to verif y that people were deleted from scope of authorized to sign partitular signature blocks on . documentation whether the 3 gnature was quality QA/DRG review related or not. This GR clarified tiust people had to be certified to sign quality inspection or review and acceptance blocks on documentation. These certifications are f ound on the Quality and Technical 5ervices (Q&TS) certification matrix, which is a coinputerized record of all quality personnel listing the dif ferent types and certification leveis for each person (a person's

                                                          ~                                                                 certification is determined by education, experience,
                                                                                                                                                                               ~

and test results). G-2)

Generic Resolutions GR gi. Rev. Subjat Discipline Rcason/I%blern Jostification and Significance to Safety 42 0 (Continued) Non-quality signature blocks do not itxficate acceptance of a quality-related attribute, and the reviewer verifies only that a signature is in the block. The authorized release signature last is used only to niatch a signature with a riaine. The naine is then used to verify certification status of the individual. The use of this GR does not adversely af fect the quality of the hardware or documentation at CI's. 43 0 GR 43 addressed innproper corrections on BA docuinents. Since this was superseded by CR I, revision 1, all descriptions and significance to design and safety are contaired within the superseding CR. 44 I QC hold guints deleted on (P/M) Travelers (1V->/7) containing QC This GR was issued because augmented class D augniented class D hold points assigned at the tune of (radioactive waste) and fire protection fabricatiori and (radiocative waste) and fire initial review have been deleted installation travelers (form JV-377), which contained protection piping travelers during inspection activities. QC hold points assigned at the time of initial review, (JV-377) had been deleted during inspection activities. A hold point is an inspection point established on the traveler by QC beyond which work canrsot proceed without the QC inspector's initial and date sign-off on the traveler. G-26

Generic Resolutions GR No. Rev. Subicct Discipline Rcason/ Problem Justification and Sianificance io Lfety .% 1 (Continued) DRG document reviewers document findings for this condition on a DEL, unless any one of the following conditions exist:

                                                                                                    - All inandatory hold points (all raw material has been identified with heat and RIR numbers) have been satisfied or the item being installed on an installation traveler has had all hold points satisfied on the fabrication traveler.
                                                                                                     - Work has not progressed beyond a point where the inspector could witness the operation and verify that.

the initial and date sign-ofis on the traveler (or on other approved documents attached to the traveler package) are in the proper sequence.

                                                                                                     - The initial and date sign-of fs for deleting a hold point for material traceability is concurrent with or later than the initial and date sign-of f s for inaterial issued within the traveler package.

Site procedures state that mandatory hold points must be placed on travelers covering the fabrication of spools furnished by Southwest Fabricators to ensure that the raw material has been identified with a heat and RIR number. Each hold point requiring a QC inspector signature must be signed and dated before the next operation in the fabrication sequence can be perfoi med. G-21

E Generic Resolutions , 1 i GR Subject Discipline Reason / Problem Justification and Significance to Safety No. Rev. (Continued) Since all mandatory hold points required by site 44 I procedures were satisfied, deletion of other established hold points would not adversely af fect tre quality of the hardware or the documentation. JV-874 deleted from scope . (PRO /SUB) JV-874 deleted from scope of DEL items are not to be written on items involving to 0 of QA/DRG review QA/DRG review. form JV-874 (vendor documentation review) and vendor documentation review letters. The docu-mentation checklist (JV-146)is the foran used for vendor documentation received onsite with or for a given PO and its subsequent acceptance by BA vendor - i

                                                                                                                         . QA.'

l I'orm JV-874 and vendor documentation review letters are not required to verity assurance of quality of tie documentation or of the plant. 1 l 46 1 Interdiscipline QC (C/5) Interdiscipline QC inspectors sign- C/S QA/DRG reviewers gercrated DEL items when QC inspector sign-ofis on C/S ofis on C/S fabrication / installation inspectors who were not certified in C/S discipt.ne [

l. fabrication / installation travelers for enibedded iterns. signed of f C/S fabrication / installation travelers for travelers for embedded embedded items. GR 46 was initiated to resolve those l

items DEL items and to more clearly def ere signature and authorization requirements of QC inspectors for the QA reviewer. G-28

                                                   " Generic Resolutions GR                                                                                              .

No. Rev. Subiect : . Discipline Reasun/ Problem - Justificalion and Sis:nificance to Safety 4t, I (Continued) Inspection of embedment snaterial by QC inspectors not certified in the C/S discipline does not compromise the quality of the fabrication or installation because dll QC inspectors dre trained and Certified to periorin work governed by 13AP 2.14 (fabrication / installation of

                                                                                         . items, systems, and components). The required general knowledge in this procedure is not limited to specific QC disciplines. Wten a QC inspector other than C/S signs for ernbeament material intended for electrical or piping / mechanical use, the final location and orientation of the embedment is inspected by C/S QC prior to placing the concrete. This inspection is documented on a pre-placement inspection checkhst and is included in its respective concrete pour traveler.

Per this clarification, the presence of any certified QC inspector's signature on embedment f abrication or installation is acceptable and assures that the items have been constructed, inspected, and accepted as meeting design requirements. Therefore, this snatter - has no impact on the quahty of construction or safety of operation of CPS. 4/ 0 . Items / materials rejected (PRO /SUB) lierns/ materials rejected on RlRs items or materials rejected for cleanhness during on RIRs OV-IS2) for . OV-132) f or cleanliness, receipt inspection are acceptable per this GR. cleanhness DRG reviewers accept items listed on the RIR, form JV-IS2, with a final disposition of "A"(conforming) even though the comments block of the RIR indicates the item was rejected for not meeting the cleanliness requirements. G-29

7 r Gesneric Resolutions Gl No. Rev. Subjec t Discipiiru- Iteason/Probleen Justification and Significaru'e to Safety r/ e 0 (Con tinued) lleins that conforen except for cleanliness likey be accepted by QC at receipt inspection by flarf,ing the* discrepant items with red tape to denote cleanmg is required. Cleaning is perfortned by the responsible discipline and is verified by QC to be acceptable in accordance with site procedure. An NCR is not required for ininor contamirutions tiut can be cleaned onsite. Stupinents of all pipe and piping cornponents received without closure caps attached are either flagged with red tape or documented on an NCR. Therefore, the use of this GR does not af fet t the quality of the hardware of the plant. 43 GR 48 was issued to accept open change docurnents against 11A installations, provided the changed document was identified on the IP systern turnover punchlist. The GR was approved, issued, and retracted on 10/19/83. GR 48 was not used to resolve Dtil items, and the original was roarked as voided and vaulted. W 0 GR for auginented class D (C/5) Augmented (Lss D (radioactive For work on augmented class D (radioactive waste) and (radioactive waste) (ti) waste) work was covered by tlee fire protection systems performed under the NSWP, travelers listing incorrect (P/M) NSWP until llAP 2.26 was issued on the proper revision of the NSWP was not always revisions of the non-safety 9/l>/81. Specific quality require- recorded in the documentation. This prompted the work program (NSWP) ments that should have been accom- writing of DEL iterns during review, plished prior to this date were not delineated in the NSWP. G-30

i l l Generic Resolutions . ! GR . _ft. Rev. Subject Discipline Reason / Problem Justification and Significaste to Safety l [ 49 0 (Continued) Analysis of the NSWP revisions 10 through 24 arid l separately imposed safety requirements revealed that,

except for work types dehneated in CR 49, all of the l revisions inet requirernents for plant quality.

l Therefore, any revision is acceptable for all but the excepted work types. l The acceptance of documentation for work in the ! excepted work types requires QC involvement to , assure that safety reqmrernents were snet. For thew I areas, reviewers write DEL items that are appro-priately handled on a case-by-case basis by QC and any other appropriate disciplines. l The use of this GR does not allect the quahty of the turdware or docuinentation at CPS.

                       %                    0   Welders qualified for        (C/S)          4 elders qu.shfied for alternative QA/DRG reviewers were urksbie to verify the difernative weldmg pro-      (E)            4 PS for non-ASME travelers.       qualification of a welder to an alterrkative weloing cedure specifications (WPS)  (P/M)                                              procedure specified on a non-ASME type traveler.

for non-ASME travelers This GR allows QA/DRG reviewers to accept the qualifications of a welder to an alternative welding procedure when those procedures have sirnitar acceptance criteria. G-31

                                                                                                                                                 .I w                                                                                                                                        '
                     -w tj
                                                                                                                                                           'l Ceneric Resolutions CR                                                                                                                                 ..

Rev. Subject , Discipline Reasun/Prublem Justification and Simnificance to Sefety

_No. . ~ SO - 0 . (Continued) The similarities in alternative welding procedures and the welder qualifications to those procedures are verified in the field by BA's TS welding inspectors. Therefore, quality is not adversely 41fecti d. Si 0 Missing JV-In for RIRs (PRO /SUl!) Missing JV-l>> for RIRs (JV-l>2) Prior to 9/28/76, the QC receiving inspection (JV-l>2) that contain the that contain the signed-of f instructions were included on the QC RIR form JV-signed-of f inspection ' inspection requirenient. 132. Prior to 9/28//6, RIR form JV-132 contained suf ficient evidence to document the activities requirements atfecting quahty as required by 10 CFR Part 30, Appendix B, Section XVil, and ANSI N4).2.9. Also un 9/28/76, revision 0 of Baldwin Associates procedure (B ?,P) 2.3 was issued to remove the inspection instructions from form JV-132 and placed them on form JV-lM. As shown, tie requirements of receiving inspectitva are met throughout tre proces , thus assurang the safety and design integrity of the plant arxl the documentation. C-32

p

                                                                                                                                                                        1 Generic Resolutions CR Na. Rev.            Subject           Discipiire                    Reasun/ Problem          Justification and Simpificance to Safety

$2' 2 Q&TS acceptance mas king (PRO /SUB) Vendor retords lave been snarked as Though the ruethod of signif ying review and accept- c of vendor records acceptable by combinations of ance of records is inconsistent, the criteria for various Q&T5 revsew stamps and acceptance has not significantly changed. In other sign-of ts that are inconsistent and in words, even though particular starnps or methods of disagreement with both current and sign-of f dif fer, they all signified that the vendor previous projwt procedure require- records are acceptable to codes, standards, project rnents. procedures, and procurement docuanent requirements. As long as the acceptability of each record is clear, tre application of this GR wall have no adverse etin1 on the safety of the pl.nt, its design intent, or the quality of docu'nentation. M I Non-qtuhty sendor (PRO /SUB) Present QA/DRC docuinent review CR 53 addresses the acceptance of DEL items written docun,ents deleted from tus generated nun erous DEL items against specific non-quality documents such as in-scope of QA/DRG review. on the following non4piality docu- voices, transmittals, packing slips, shipping papers, n.ents: bills of lading irom transportation compames, etc. These documents (unless they are referenced by the

                                                  - bills of materiot

• vendor on his certificate et comphance or CMIRs to

                                                  - transnuitals                            assure material traceability) are not considered
                                                  - bills cf lading / shipping papers'      records and have no bearing on the safety, turdware,
                                                  - invoices                                or quality of documentation mandated by the codes,
                                                  - packing slips

• standards, and specifications used in the construction '

of CPS.

• Note: When retereni cd on vergjor certificate of compliance or certified rnaterial test reports (CMTRs) and required to assure traceabihty, these dix urnents become y2ahty records, asid tinis CR does not apply.

G-33

Gerwric Resolutions GR No. Rev. Sabiect Discipline Reason / Problem Justification and Significasice to Safety 33 f. (Contisiued) In those instances where ttue ebove referenced docu-ments have been used by the vendor to provide or assure traceabihty, these documents becorne quality records and are subject to the same review and approval cycle as any other quality record, and this GR cannot be applied. Therefore, in instances where this CR is used, no design or safety significance exists. M 0 Controlled documents (PRO /SUB) Dilt items have been written on GR 34 addresses the acceptance of DEL items written referetxed or contained controlled documents (for example, against controlled documents ("Those documents which within PO packages used NCRs, DRs, FCRs, design specifica- have been formally reviewed and approved for project for basis, justification, or itwis, ECNs, FECNs, field deviation construction activities which require strict control fur making archases deleted disposition requests, drawings, etc.) distribution and/or traceabihty." Ref. BAP 2.0, from the scope of QA/DRG ui PO packages or have been paragraph 2.1) that were used o_nly as a basis or review reterenced on the requisition, P0, or justification for making purchases. This practice does riders that were used (M as a basis not compromise the safety of the plant or quahty of or justilscation for the purchase of the documentation because the above defined iterns, materials, etc. These documents were used only as attachments or controlled documents were attached references, and therefore no design or safety _ to or referenced on the requisition, significance exists. PO, and riders, but were not imposed on the vendor by the P0 or riders. G-34

4 W

                                                              - Geseric Resolutianis CR                                                                                                       Justification and Sianificass_e to Lfety Rev.              Subiect                Disciptore                     Rm=i/Prilem

_m. QA/DRG (.haktists, deparsmen -' This CR is used to addren tho:,e instances wtic re both . lR'

3) '4 Q&T5 certification type (PRO /5UB) '

and level required for . .. tal/ project procedures / instructions - departmenta? and project procedures, instructions, and Q&T5 sign-ofis on JV-146, .. and form require Q&TS sign-olis of fornis require Q&TS sign-otts on docunnents, but do not VJ-13), JV-413, JV-340, forms JV-l% (documentation clearly specify the level or type of certification - and JV-661 - checklist), JV-l>> (QC receiving required. This GR detires those parameters in con-

                                                                  . inspection instructions), JV-661            junction with the aforernentioned procedures, (engineering documentation                 . instructions, and Iorms and, in and of itself, has no dwcklist), JV-340 (request to               impact on the design or salety of the plant or the upgradt siksterials),and JV-413             tardware.

(atems or indterials returned report), but do not clearly stipulate the specified levels and types of certifications ttut are acceptable. l

      %            NtaGR 3/           NtaCR 33           Not a GR                                                                                                                                                                  1 1

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Gescric Resolutions .CR Justification and Simnificance to Lfety No. Rev. Subject Diwipline Reason / Problem 66 0 Missmg cleantiress re- (PRO) DliL iteens have been written on  !! lus been determined that items and materials quirernents on Pos for requirenwnts for piping items, end received on site that conf arm except for cleanliness-piping iteens. - protection, closure and end caps, or snay be accepted by QC at receipt inspection by cleanliness that were stated on the identifying the descrepant items to denote that purchase requisitions but were . cleaning is required. Cleaning is then performed by 'l oinitted from the POs. the responsible discipline and verified by QC as , I acceptable to the applicable cleanliness class, prior to issuance for construction. Shipment of all items received without end protection or cleanliness are either identified as such and deaned . i or are docuf nented on an NCR, dependmg on tic .j severity of the contamination.  ! In arlJition, approved site procedures require QC f personnel to verify cleanbress of all piping itenis prior to issuance to construction ior field installation or use. With the above stated requirements in elfect, it is assured that the quality of the docuanentation arid l safety of the plant meet the requirernents of the l design intent. G-37

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            .    .l '    l!            ,!                     ,          4l            ,li!j,}iii1jIj                                                     ,4 fi! iia'    ;1it )i    !

Gcewric Resolutisms GR _No. Rev. Subject Discipline Reason / Problem Justification and Significance to Safe 3 u 1 (Continued) The interpass ternperature is an essential variable only for piping welds that require innpact testing. Piping welds made on carbon steel material, which do not require impact testing, are acceptab:e even though the interpass temperature violates a site welding procedure. The integrity of the physical plant is not . affected. 67 i Ruse I inspection signed (P/M) Ile Phase I irrspec: ion for piping The TS inspectors sigruture on the traveler form out of sequence with the tungers on form JV-39/ has been (JV-397) for Phase I location and orientation of tre fit-up sign-of f on piping segreed of f as acceptable by TS either primary attachment to the building documents that he'. tunger travelers. prior to or atter the prinary attach- has verified that the locatiosi of the attachnie rit aswe ts a nient fit-up sign-of f date. Phase I design requirements. In additura, this verification is sign-of fs that are prior to or atter docurne nted on a TS 1%se I tunger inspection check-the date of the fit-up for tie pri- list (JV-723). nury attactunent weld violate s llAP 3.2.3, paragraph 6.4.1, which states The TS inspector % sigruture on the traveler form for that the primary attadunent loca- the fit-up sequence documents that the weld has been tion and orientatiori will be verafi d done in accordancea with codes, specifications, asid site by a TS inspector during the fit-up procedures. mspection hold point. At one time, the governing procedure for the fabrication and installation of hanger support travelers (IlAP-3.2.3) specified tIwt these inspections be performed at the same time. In violation of BAP 3.2.3, Phase I sign-of fs tuve been documented on the traveler form prior to or af ter the date of the fit-up L inspection. G-39

Generic Resolutions GH No. Rev. Subbet Diriphne Reason / Problem Justification and Significance to S.ifety u  ! (Continued) Per the GR, this violation will not be written as a DEL itern if the hanger was tack welded into its pernianent location on or prior to the Phase I inspection date. Tack welds can be verified by documentation of weld rod issuance. This infor nation can be found in the subject traveler. Futher, a DEL itein is not required if truere is a JV-728 included in the traveler package docurnenting that the location and orientation of the prirnary attachinevnt a was inspected and coniormed to design requirements. If neither of the above conditions are snet, tic QA/DRG reviewer writes a DEL itetii and forwards it to the DEL Resolution Group. The procedural violation does not adversely af fect tre quality of the inspection because verificatron of location and orientation can be perfornwd any time af ter the attachtnent has been tacked in its perrnanent location, if the limiting conditions stated in the GR are snet, the required ba<.k-up documentation will assure that this has been done. This situation can have no irnpact on the quality of construction or operational safety of the plant. G40

_. ___.- -. _ .. __ _ _ _ _. . _ _ . _ . _ ._....m __.

                                                                           ~

I 4 Generoc Resolutions l Gu

b. Rev. Saesect Disciplesm- Reasani/Pradelem Justification and Simiificance to Safety 4

63 1 Acceptance of any DEL (P/M) Old JV-lu forsns (docunentation l'rior to 9/82, the JV-l% contained an informational items on tre receiving ctecklist) contain a receiving segnature type block which was used to identify the QC a inspection " performed by- inspectim "perIorned by date" .. receiving inspector who receipt-inspected the items t date" section on JV-146 section. This section was leit blar A, and nuterials as ttey were received on site. As this 4 fcents, partully cornpleted,innproperly toed block was informational, quite of ten it was either lett out, marked N/A, etc. blank, partially cosnpleted, imptoperly hned out, nurked N/A, etc. This section of the JV-l% is a duplicate of those sign-ofis on the JV-152 (RIR). 1 Tte JV-l>2 is the quality record used to docurrent tie i actual receipt and inspection of the lurdware. GR 68

is used to address errors and omissions of the receiving inspection "perfornwd by" block of the old JV-146

(prior to 9/82) only. It has no inspect, therefore, two i the design of safety of the plant, the hardware, or the j documentatiosi.

2 1, 1 ) 1 G 48 i l 1 i

f.crwric Resdutions GR. No. Rev. %biect Drreplume Reasco/Probican Justification and Significance to Safety 69 0 Acceptaru.e of docun:ent (PRO /5UM) Q& TS personrel, cer tified as This GR addresses those instances where Q& TS enamarer and lead auditor document examiners or lead audi- personnel, certified as document examiners or lead certification .o heu of QA tors, have signed of f procurenwnt- auditors, signed of f procurement-related documents in procurement engurer, related documents its lieu of QA heu of QA procurenwnt Level 11 and ill engineers pr ior Level 11 or Ill, prior to procurement engineers, Level 11 or to 3/29/77. On 3/29/77, revision I of BQA-182 was 3/29/77 111, prior to the 3/29/77 approval assued. Since both lead auditors and procurement date of BQA-132, revision I, engineers are certified under ANSI N4).2 and the

                                                        'Q2ahtication and Certification for           certification requirements for lead auditor are more QA Proct.rernent Personnel."                  stringent than those for procuremer.t engineers, this GR has no impact on the design or safety of the plant or hardware.
 /0       Not a GR 71   0   Au eptance of anissing,    (PRO /StilO        Prefises to ttw control nun.lers on            This GR resolves instaru es of missing, incorrect, uxorrect, m properly                          RIR, JV-132, that sinutd be hsted as           improperly corrected, etc., JV-132 numbered RIR correc ted, etc., RIR                         "5" f or safety-related and "N" for           prefixes. These prefixes consi;.t of an "S" for safety-number prefixes                               non-safety related, are missing,               related and an "N" for run-safety-related RIRs, and incor rec t, innproper t y cors et ted, etc. are used as an isi-house aid only to denote the status of the RIR. The prefines are unique to CPS and are not required by codes, standards, or procedures, in and of itself, the RIR prefix has no unpact on the design or safety of the plant, hardware, or documentation.

l G-42

Gen cric Resolutions CR. Decipluie Justification and Sisiificance to Safety % Rev. Sabsect Reasun/Probican 12 I 11A CR for improperly (E) tiA CR for improperly filled out or CR 72 Ms a two-fold purpose. First,it accepts an . filled out or missing missing containment Mnger location engineering location verification instead of QC contamm.ent Nnger data or missing QC witress sign-of f > location verification for condust supports (hangers) in location data or niraing on JV-663 and JV-713. the contairunent buildug. QC witnew sign-olis on

        - JV-663 (QC electr: cal                                                         Secosul, this CR provides direction for accepting an Mager installation                                                              N/A in the " location drawing and rev." block of the checklists) and JV-719                                                          QC electrical hanger installation checklist (JV-668) for (curitamrnent electrical                                                        contaisunent conduit supports. Prior to 3/27/81,it was Mrger location forms)                                                           QC's responsibility to verify that the location of all safety-related electrical hangers was in accordance with construction drawings. On 3/27/81, a privedural cNnge shif ted tne responsibility to verify location of electrical hangers m the containment buildmg trum QC to the senior cositaisunent engirw cr.

In May 1982, another procedural change required QC to witness the location verification by the senior containment engineer arwt to sign and date the containment electrical Mnger location forsn (3V-718). In August 1952, QC was directed to sign tie JV-188 foren only if the semor containment engmeer put the exact location of tte hangers on the JV-713. G-43

Geswric Resolutions CR. No. Rev. Subsect Discipline Reason / Problem Justification and Simpificance to Liety 12 I (Continued) Using the aforementioned dates, DEL items were generated for missing QC signatures on the JV-718 (af ter they were required) and if the exact kication was not noted on the JV-718. When the original procedural change occurred on 3/27/81, QC was no longer required to list the location ~. drawing and revision number on their inspectson checklist JV-668. They could put "N/A"in the bkwk. There was a conflict between the procedure and ite - QC instruction which nunde it dif ficult for the DRG reviewer to determine if QC was or was not allowed to "N/A" the drawmg location and revision block. Since this was not clear, DEL stems were generated. GR 72 directs that any containment electrical funger location form (JV-718) that is sigrrd by a containneent engineer is acceptable. It also defines 3/27/81 as the date QC could "N/A" the location drawing aruf revision block on the QC checklist JV-668.

                                                                                                                                                                        !! QC marked "N/A"on this bkxk prior to 3/27/81, a DEL item was written. Therefore, no safety significance to operation of CPS exists.

cm

Generic Resolutions GR. _No. Rev. Subject Dnciplire Reason /IMiem Justification 'and Signiticarce to %fety n G Certification of QC (C/S) Inspections of miscellaneous n.etal QC inspections of rniscellaneous discipiire installation mspector sign-of f s on installation (includmg masonry (including rnasonry colurnns), which are governed by traseie rs for miscellaneous colurrans), whic h are governed by K-29de9," Specification for Miscellaneous Metal Work n eta!> K-2949, BAP 2.l4 and apphcable and Embedded 4 ork," BAP 2.14. " Installation / mstallation traveler, were signed of f Fabrication of iten.s, Sptems, and Components." and by Level !! C/$ mspectors not tuving the apphcable installation traveler, have been signed

                                                       .trut tural steel cerlificatiosi. ar d accepted by Level II C/S inspectors rwt tuvang structural steel certification.

Although miscellaneous neetals, including nusonry colurnns and tee's, are irntailed per K-2%9, they are not considered structural steel and are irstalled per site procedure BAP 2.14, and the apphcable traveler instructions. In this snstance, a structural steel certification is rot required to sign-of f thi> type of iropestson because all C/S inspectors are trained and qualit ed to BAP 2.14. Ttey are, therefore, qualified to inspect inixellaneous metal fabrications and irstallations, thause the irspectors were traised and certilsed to ite requirenents of BAP 2.14, it is assured ttut the quahty of the plant has not been altered by the use of this CR. Therefore, no design or safety significance exists. G-U

e Cencric Resolutions CR. _m . Rev. Suigect Discipime Reasen/ Problem Justification and Simpificance to Safety 74 NtaCR

7) O Piping hanger inspections (P/M) . QC inspections prior to QC Per site procedures, various measuring devices are with no record of tool instruction QCI-300, revision 4, did required to be periodically checked to ensure serial nuinbers or not require entering tool serial accuracy. The BA QA Manual requires entering tool cahtwatson due dates rumters and calibration due dates serial numbers and their corresponding calibration due for measurements made during Phase dates on the applicable quality documents.

Il piping lunger inspections. DEL items are written for this condition unless the hanger inspections were performed prior to 9/24/82. Quality records for hanger inspections (travelers and inspection records) did not document tool numbers or - cabbration due dates prior to issuance of QCI-300, revision 4, on 9/24/82. Phase 11 inspec Lions are no's and have been considered in-process type inspections, with ultimate hanger acceptability depetidmg on the results of the f arut inspection. The fmal inspection will both determine the final acceptance and provide the documentation required by the QA Manual. All in-process items } requiring the use of cahbrated tools are re-checked i during final inspection and documentation on a Ph.se i Ill checklist. I 1 1 l l l 1 1 G-% i I I 4 4

  . . _ _ _     . __ . ._. _ _           ._ . _.         . _ __._              _    _ _ . _ . . . . _ .             _ _ ~ . _                    _        . . , _ . __                 -_ .. .__._  -

3 1, 1 I, Ccnceic Resolutions i CR. . g Rev. Subsect Daciphne Reasen/Probleen Justification and Sisinficance to Safety -  ! t 76 0 Fittmg/ material type, (P/M) Entries for fitting type, anaterial This CR was issued for f atting type, material type, t traceable code, and RIR type, traceable code, and RIR traceable code, and RIR rumbers entered in blocks of i data entered in wrong numbers w ere entered in blocks of instrumentation travelers that were not specifically

blutks instrunentation travelers that were labeled to accept this type of data. This CR applies 7 not labeled to accept these types of only to Parker-Hanifin type fittings.

j data. RIR numbers for fittings were { entered in the RIR/ heat number Site procedures do not state where this extra column instead of in the filler heat information is to be entered. Because this information

~

number or lot nurnber columns of Roes beyond procedural requirernents, it could confuse block 12, as required by BAP 2.6. future documentation users af ter the plant is licensed. 1 The codes have been entered an f 11er j type column, the nuterial requisition The DRG does not write DEL items for this extra 1 column,or RIR/ heat rumber column information, except for fitting traceable code or RIR anstead of the filler locat nun Isr riurnbers that are entered in colurons other than the columns as required by BAP 2.6. filler heat and lot number colunos. These DELs are to docuneent the condition only and are clowd by entering i the following in the DEL resolution column: ! " Traceable Code (and/or RIR #) for fitting accepted l per GR 76 R/O." i i This extra information benefits traveler users, bath ) during construction and DRG review and throughout the life of the plant. It is particularly useful to the authorized nuclear inspector during his review. Also, since there is no block for this extra information, .

having the data on the same line as the base naterial r

! (tube or pipe) nukes the data more useful and less i subject to confusion or transcription error. This l 4 j G-47 n . k i i 4 i 4 h

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                                                                                                                       . , = , - _ . - - -              -

Generic Resolutions GR. _No. Rev. Subject Discipime Reason /lvablem Justification and Simpificance to Safety 76 0 (Continued) added information is not detrimental to the quality of the documentation or the safety of the plant. 7/ 0 Acceptance of QC check- (C% Rs) QC inspection personnel are required This CR addresses a disregard for a procedural hst OV-639) wittmt (E) to reference all of the apphcable requirement to list CWRs in the remarks section of QC referenced construction CWRs in the comments section on checklist, form JV-689. The GR allows this oversight work requests (CWRs) form JV-689. This has been a when the applicable CWR used to perform tre work is requirement since BAP 3.3.7, referenced on an attached JV-707. revision 3, was issued on 9/17/82, but QC inspection personnel Nve not The JV-707 form is used by engineering to reference followed those procedural all engineering directives needed to complete an requirements. Also, traveler installation, included in this form is a block for each ' preparation review group reviewers referenced directive that the QC inspectors initial and Nye overlooked this requirement in date when installation is complete and is acceptab!e their review; subsequently, ttese per the referenced directive. travelers have been sent to the vault without complying with the This procedure requirement has been changed, allowing pr.,cedural requirements of BAP the QC inspector to omit reference to the CWR in tre 3.3.7, revisions 3 through 3. remarks section of the QC checklist. The lack of the referenced CWR on the QC checklist does not aflect the quality of the hardware as long as it is referenced on the JV-707. The use of CR 77 does not adversely af fect the qua'ity of the hardware or documentation at CPS. G-48

Ge wric Resolutions GR. g Rev. Subject Discipline Reason / Problem Justification and Simpificance to Safety 78 I Delete imm JV-185, QC (C/S) Form JV-135 was an inventory of GR 78 deletes form JV-185 from the scope of the DitG

            - traveler review from the    (E)           docuenent reviews for individual .      review. The JV-185 form was required documentation scope of QA/DRG review       (P/M)         traveler packages and was a required     from 1/77 to 10/77.

traveler attachment f rorn 1/77 to 10/77. Form JV-185 has not been a Form JV-185 was an inventory of reviewed documents, regular part of applicable traveler such as other JV forms, drawings, and instructions, packages nor has it tren filed that applied to a particular traveler. These documents - separately in the vault. This has were reviewed prior to being listed on form JV-185. resulted in traveler packages with no ' Data required by this form are documented and form JV-185, contrary to the accepted using the review signatures on other procedural requirements that were appbcable JV forms which are also contained in the then in force. traveler packages. Form JV-185 only provides redundant data. Its presence is superfluous aruf does not significantly aflect the quality of the plant. M 0 JV-668 not having same (E) QC inspection personnel are required This GR was written because the electrical conduit location drawing and . to record the location, docuenent hanger location drawing referenced by QC inspectors revision as JV-667 nurnter, and revision of S&L-approv- on the QC checklist did not always agree v ith the ed documents used to verify hanger hanger location drawing referenced by engirseering on location on the QC checklist (JV- tte cover of the traveler package. By project 668). Per QCI-401 R/7, paragraph procedure, the location drawing hsted on the traveler 7.2, "These numbers (the location must also be referenced on the QC checklist. document) shall agree with the Ifowever, the drawing listed on the traveler is usually traveler except that an earlier the area location drawing and is not always detailed revision may be listed on the travel- enough to determine the exact location of a particular er." The document listed on the hanger. When this occurs, elevation drawings are used electrical hanger traveler is usually to determine the location of an individual tanger. It is l the area location drawing (Elli series this evaluation drawing that QC inspectors have been drawings); however, the individual referencing on the QC checklist. G-49 i

                                                                     +-                                                                 -

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                                                 . Generic Resolutions CR.

No. Rev. Subject Disciplire Reason /Probleni Justification and Simnificarte to Safety 79 0 (Continued) hanger locations are soinetones Tle elevation drawings used'by QC inspectors are shown as section views located on actually supplemental drawings to the main hanger - elevation drawings (El 1200 series) location drawings. They 'appedr on tfe location which are supplemental drawings to drawings as " cut" or "section" Wews and have the area location drawings. The QC traceability from the main location drawing to the inspection personnel have been supplemental drawing and vice versa. Tre recording the actual drawing number supplemental drawing, when used in conjunction with and revision used, even though it the main location drawing, actually enhances the does not agree with the traveler, assurance of proper conduit hanger locations therefore, quality is not adversely af fected. 30 0 inco. rect revisions on - (C/5) DEL items are being generated This GR deals with BA-generated drawings that have reference drawing . (E) against BA drawings because . S&L drawings listed as reference drawings, but list (P/M) relerenced drawings are not up to . incorrect drawing revisions. ' The aforementioned S&L the current revision. S&L design drawings are currently ny being used for construction drawings that are relerenct d on the and are listed on the BA drawing or traveler as a BA drawings are reviwd without BA reference only. updating the revision block on the liA drawing. The revision block for Any changes to the S&L reference drawings that reference drawings on the BA affect the BA drawing will result in a change to the drawing is updated only when a BA drawing to incorporate the change. In addition, if reference drawing af fects tte BA field personnel or quality inspectors need to refer back drawing. to the S&L reference drawing, they must use tie G-30

1 Gescric Resolutions Git. Justification and Significance to Lfety No. Itev. Subject Drsciphne Reauwi/Probk in 0 (Continued) current revision of the " approved for constructiora" 30 controlled drawing. Plant safety is further assured because field verification perfiwiiis a review of desigri docutiicists during trear overinspectier. In consideration of ttese facts, it can be concluded that no design ur safety sigiuf stance exists with ilie use of this GR. l 31 Not a Git Missing or incornplete data (C/5) Senior discipline engucers (C/S) This Gil was issued becauw the sernor diwipine 31 0 for block 9 of focne JV-433 of ten ornitted or did not f ully engircers (C/s) of ten onsitted or did rut fuity cornplete cornulete entering appbcable data in entering applicable data in block 9 (sub-assenibly block 9 s norin JV-433 infornution) of foran JV-453. (f abr ica tion / ins ta lla t ion tra v e ler ). , DEL iterns are set written Ior this condition sir (e the  ! inforination for block 9 is tie san.e infornution as I entered in block 8 of the forrn. Due to the lengthy cescription required in Insting sub-asseniblies for bkwk 3, Itey were of ten not repeated in block 9 because of irudequate space. Tte onussion of Got l 1 I

w c . . _ _ _ _ _ _ s l l l l Generic Resolutions GR. Justification and Sir.ruficarce to Safety Rev. Subject Disciphne Reason /Probtern 32 0 (Continued) this information does not aflect either the hardware or the documentation and, therefore, does rot cornpro-mise the safety of the plant or quality of the documentation. 33 0 incorrect or missing (E) BAP 3.3.6 and QCl-401 did not This GR was issued to resolve deficiencies *here trat address spaces or filler plate or RIR numbers were rnissing from the QC fabrication beat /RIR numbers on form JV-668 material traceabihty requirements and inspection checkhst for filfer or shim plates used directly; however, the procedures in bolted connections on Category I electrscal conduit defined how traceability was to be supports. maintained Ior all truterials listed on the bills of material. Inspection S&L design drawings E05-1980, sheet I, revision All, personnel verified heat and/or RIR note 40, and E05-1980, sheet 2 revision B, note M nuinbers on filler plates and shirn (hanger installatiori notes) were revised to allow the plates used in bolted connections on use of any commercial grade of steel in bolted Category I i lectrical conduit connections for electrical supports. Traceabthty of supports. the material to a specific type or grade or manufacturer's heat or lot nuinber was no longer required. This change deletes the requirernent to document heat or RlR numbers on QC checkhsts for electric ! conduit hanger 3. This GR is used to apply current construction and inspection requirements to hanger installations completed prior to the etfective date of the drawings and ehminates the neca to document missing or incorrect heat or RIR numbers (for filler or shim plate) on QC inspection or fabrication checkhsts for electrical conduit hangers. There is, therefore, no ( design or safety significuce. l G-52

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Getieric Resolutiivis GR. Justification and Significance to %fety Rev. Subject Disciphrm- Reasori/Probiern g. BA has created these drawings to stow locations of lR u, I (Con tinued) einbedded plates. The drawings are reproductions of 5&L structural drawings to be used as a construction , and in placing enibeds, niaterial take-ofis, and l procurennent. Therefore, they do rot need review by S&L and are acceptable wittout the S&L status stainp. The safety of the plant or !!n quahty cf the docuanentation is rot df fected by this GR. CMTRs f roin Capitol Manufacturing Certified tnaterial test results frorn Capito! lR 37 i Capitol Manufacturing (PRO /SUB) Manuf acturing Cosniuny have a $ prefix to son e !=>at Cornpan) CMTRs (P/M) Cornpany have a $ pref n to sonie in.at codes; BA QC does not todes that BA QC does not (onsistently referein.e (ni consistently referein'e the $ prefix associated BA docunients, such as RlRs, nuterial i I on the associated BA dotuinents (for withdrawal slips, and travelers. exaniple, RlR, anaterial withdr awal i shps, travi it rs, etc.). Olit ite siis are not writtiin tui this (oridationi; howt se r, I tte DRG will ensure that the heat cod is eritered in tie heat log, both with and wittout tin prefix, to f' i indicate to all subsequent aners of the RIR, CMTRs, associated travelers, or ottw r related docurnentation I ttut the heat nunibers without the 9 are a(ceptable. I G-M

Generic Resolutions GR. No. Rev. Subject Discipline Itcason/Problern Justification and Signitscance to Safety 3/ I (Continued) Acceptance of the existing paperwork is based on the lR supphers' statement and confirination in writing that 9 is a registered trademark and is used to identily iteins manufactured from bar stock at their Columbus, Ohio, plant from bar stock. The intet,rity of the hardware and the documentation is not af fected; therefore, there is no significance to the sale operation of LPS. 83 Not a GR 39 Not a GR 90 0 inconiplete checklists for (C/S) The embedded raceway checklist The embedded raceway checklist used by QC inspec-embedded electrical (ii) forin, JV-506, has sections ttut have tors during post-pour (concrete) inspections tuve raceways not been used during tie post-pour attributes 13,16, and 17 either marked N/A or lett inspection (attribute i$ indicating blank. In addition, the post-pour inspectson section tus tlut the installed raceway has been rm) QC inspector or QC Level 11 review sign-ofis, swabbed; attribute 16 indicating that the installed raceway sus been This GR was written to allow QA/DRG reviewers to nundrilled; arid attribute 17 close all open DEL iteriis writteri agairwt JV-306s indicating ttut the installed raceway where attributes !),16, and 17 were lef t blank or is capped or plugged). These attri- marked N/A and where there was no QC inspector or butes have been either marked N/A QC Level 11 review signature sign-ofis. or lef t blark. In addition, the post-pour inspection section has no QC This is justified because attributes 13 and 16 are inspector or a QC Level 11 review covered by JV-333 (cable installation checklist), are l sign-of f. governed under BA procedure 3.3.2, and require that l l G-36

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Gerwric itesolutions Gil. Subject I)iscipline Ileason/Prablem Justification and Sir.nificance to Safety N. Itev. (Con tinued) conduits be swabbed or cleaned. Attribute 17 does rot 90 0 apply because embedded conduit cannot be capped or ' plugged af ter the cable tus been pulled through the einbedded conduit. Thereiore, quality is not adversely af fected. 91 Improper processing of (C/S) During concrete test cylinder During the processing of concrete test cylinders, lR 1 concrete :est cylinders processing, attributes that create various attributes (which create optirnurn curing optinnuin curnig conditions were out conditions) were out of specification iequireriierits. of installation specification These optimurn attributes are curing temperatures and requirements. Despite this, the stripping times (the tEne of removing the cylinders corx. rete test cylinders reached the froen their molds). required strength. The various optiinum attributes that luve bsen Codes, specifications, and site procedures stipulate found out of specif watson that concrete test cylinders are to be procewed in a requirements are: initial cure unitorm manner. Tius aids in developing a uniform teinperatur e, cure room tempera- statistical base for evaluating concrete perfor snarn t in ture, early stripping of test reaching its required strength. l cyluxiers, and late stripping of test  ; cy hnders. The curing teinperature is one of the many variables l af fecting the strength of the concrete specimens. Minor variances from the optimal curing conditions would rot cause a significant clunge in the strength of the concrete cylmders. The af fect on the statistical base would be even less significant. G-37

Generic Resolutions Git. Justification and Significance to Safety No. R ev. Subia t Discipline Reason /lvoblern

   <> l   I     (Continwd)                                                                           A niinimuin stripping time for concrete cytirujers is lR stipulated so that the cyhnders are not damaged by        l premature stripping. Late stripping of tiie cylinders     I could result ir. dif ficulty in strippmg the molds f rorn the cylinders. Both early ard late stripping are l

procedural violations and could reduce the cornpressive l strength if the test cylinders were physically l damaged. This would not enhance the cylmder strength. Acceptance of cylmder strengths is based on minimum design rquired strengths. Therefore, this GR instructs QA/DRG reviewers not to write Dtil items for violations in processing the concrete test cyhnders, provided that the minimurn design strength is enet. As iong as ininimum strength requirements are met, violations of this type have no significant inipact on the quality of construction, inspection, or safety of operation of the plant. 92 0 Missing revision nuinbers (C/S) The supplemental travelers have Supplemental travelers are issued when the o. iginal for supplernental travelers (E) been improperly identified by the traveler has been previously vaulted. To properly omission of the revision level frorn identif y a supplemental traveler, the word "SUPP" is the traveler identification in itx= written on ttie traveler, followed by the next traveler nuriiber bloi.k. sequential traveler nuniber, i.e., SUPP. 01, or SUPP. 02, etc. Note: This does not apply to cable pull cards cornpleted prior to $/3/34 l (BAP 3.3.2) and cable ternonation cards prior to 7/6/34 (BAP 3.3.3). l l G-58 _-' O

Generic Resolutitw3 Git. No. Rev. Subject Discipline Reassui/ Problem Justification and Sir.nificarsce to Lfety 92 O (Continued) The GR allows QA/DRG reviewers to close all open DEL items where tie traveler SUPP revision level has been omitted froin the traveler identification. The omission of supplemental traveler revision level is a proper probtem and does not af fect the quality of the hardware. 93 1 U.S. Testing persormet not (C/S) U.S. Testing personnel that This CR is used to address document exceptions in certified to perforan test performed tests in accordance with which U.S. Testing perwuinet were not certified to per ASTM D421 ASTM D422, D423, and D424 were prepare soil siinples per ASTM D421 " Dry Preparation certified to perform such te:ts. of Soil Sariiples for Particle-Size Analysis and However, for the document of Deterrnination of Soils Constants." This soil sarnp'e qualification, several U.S. Testing preparation operation was necessary when perforenarig ernployees do not indicate tie following soils tests: ASTM D422. " Particle Size cer tification for ASTM D421. ASIM Analysis of Soils," ASTM D423, " Liquid Limit of D421 specifies the proper niethod of Soils," and ASTM D424," Plastic Lirnit and Plasticsty obtauung sainples for tests ASTM Index of Soils." D422, D423, and D424. For an individual to be certified for a specific ASTM test, he must be able to perforin the test as described by the ASTM inethod. G-39 l

Gerwric Resolutiusis GR. Justification and Significarn e to Safety No. llev. Subject Discipline Reasori/Problern Each of the tests (ASTM D422, D423, and D424)

9) 1 (Con tinued) specifically references ASTM D421 when describing the sainple preparation inethod, snaking ASTM D421 part of the method and separate certification unnecessary.

U.S. Testing inanagement concurs with the justification of GR 93, letter UST-JAG-10/ 34-10 from J. A. Grmun (U.S. Testing) to R. McCullough (tlA/QE). Therefore, this condition has no impact on the quality of construction nor the safety of operation of CPS. (Pit 0/StJt)) Numerous DEL items have been JV-146s are the project records used to identif y the 94 0 locorrect data on the

           " check if received" column                     written on missing or incorrect QA       required vendor documentation and to indicate its docuinentation circklists(Form JV-       receipt. This GR is used to address those instances on the JV-146 146). Ibese forens are used to          where the data in the " check if received"coluinn is identify required vendor docuinenta-     incorrect, i.e., a document shown as received in 1977 tion and to do(uinent its receipt.       is no longer in the package or is incorrect. Snice tin-Frequently, the receipt status is        JV-146 is not the project record used to review vendor missing or was added atter the           documentation, the application of this GR has no fladlerial had been received, as in the  impact on either the design or aafety of the plant or case el a JV-146 being reconstructed     the hardware.

to replace a missing one. Many times, vendor documents have been noted as received on the JV-146 (" check if received" column); however, when the package reaches QA/DRG for review, some of the l G-60

Generic Resolutions GR. Rev. Subject Disciphne Reason / Problem Justification and Significance to Safety No_.

       'M    0     (Continued)                                   docuinentation has of ten bet onic separated froin the package. This results in two separate DEL iteins:
                                                                 -   a DEL item stating that JV-146                                                                  l is incorrect; it shows receipt of a docuinent no longer in the package,and another DEL itern for inissing docurnentation as relerenced on the requirernents side of the JV-146.
       'n     i    K-specification aniendnient (C/5)             K-specifications referein ed on ISA       Tius GR allows tre acceptance of iny> roper K-speuti- l R not current at final review (E)               documents have inicorrect airietid-       cation (contract specification) ainendinents (revision (P/M)             ments hsted at the final revicw.          levels) being referenced on travelers at the linee of This does not show ttut dotuinents        traveler final review. Uspecifications provide the have been reviewed to all changes of      basic rules, regulations, and specifications f or the the K-specification.                      design, construction, and installation activatses at i                                                                                                           CPS. In accordance with site procedures, the current K-specification arnendment was required to be referenced on the traveler when the traveler underwent final review. The lack of this did not mean itut changes were sinade to tir specifications without any evaluations being performed to deternune impact on bardware or documentation.

l l 1 l G-61 l n s n S M m-

Generic Resolutions Gil. Subject Discipline Reasni/I'robleni Justification and Significance to Safety No. Itev. 95 I (Continued) fiAN RE Group perfornis a design review of all K- lR specification changes independent ot the travelers. l During this review, RE identifies changes that are niore restrictive and evaluates if they will irripact any travelers or procedures. There are also two checks on REN perforniance. First, IP's Nuclear Station Engnwering Departenent reviews l R all specification changes to deterniine site inipact. Second, S&L incorporates changes in the K-i specifications into the design drawings. Changes in I the design drawing will be incorporated into the traveler or procedures or will cause the isstmince of suppleinental travelers (suppleniental travelers are issued to continue work on an itein that had previously been completed and accepted). The lack of proper K-specifications amendinent and l the implementation of this GR does not adverwly af fect the quality of the hardware or the l documentation of the plant. 96 Not a GR G-62

I Gerieric itesolutions Gil. Subject Disciphne lleason/l*roblein Justification and Significance to Safety

g. Elev.

Traveler docurnent pack- (All) Git for traveler document potkuges This Git addresses a probteni wh.re docussients (sutti as 9/ 0 age: where attacted w her e at tached documents (exc ept inspection reports, equipment requisitions, engirrernig documents (except change change documents) are not listed as changes, etc.) are pres;nt in the traveler packages docunients) are not listed at tachnien ts. without being hsted as attachments. This violates l as at tac hinents project procedures. l t

                                                                                               %len a traveler packags is revit wed by DitG, all l                                                                                               documents in tir package are listed on the DitG table of contents OV-942), which then beconnes the of f K ial hsting of all docuanents within the traveler package.

There is no reason to re-enter documents as attachnients to the original traveler cover page once the table of contents has been filled out. No DEL itern is required as all docurnents will be h>ted by the DitG reviewers. This Gil does riot adversely af f ect the quality of the docurnentation. 93 Not a Gil G-63

l Generic Resolutions Git. N. Itev. Subject I)iscipine Reason / Problem Justification and Significance to Safety

 'O     O      Iloid Points signed without     (11)       TS welding inspection hold points      This GR resolves cases where a TS weld inspector fails correct traveler revision                  have been signed-of f and dated, but  to enter the current traveler. revision in ef fect at the level                                      the inspector failed to enter the     time of the TS hold point sign-of f.

traveler revision that was current at the time of the weld inspection. TS hold points are designated steps in ti.e installation process where an inspection is required to take place, inspectors are trained to complete their work to the latest revisions of the traveler. Since current traveler revisions are the only revisions available to the inspectors when they do their inspections, the weld sign-of f has to be accomplished during the current revision. l l The correct traveler revision that should be listed by l an inspector can be ast.crtained by comparing the TS j weld sign-of f date to the closest 'raveler initial review l date, that is, prior to the sign-of f date. When this situation occurs, a GR stan.p is apphed next tu the deficiency to indicate it was sioted by the DRG reviewer. This GR does tot adversely af fect the quality of the hardware or the documentation for CPS. G-64 h a a M O

w Generic Resolute GR. Justification and Significance to Safety No_. Rev. Subjat Disciphic IMm / Problem . 0 Pre-inspection checklists (C/5) Pre-inspection chec khsts have been Th'- GR was issued to resolve DEL items written ttut l 100 (JV-$31, JV-$41, JV-542, cornpleted with an itein quantity identity pre-inspection checklists (JV-331 JV-541, i and JV-343) ttut conflict that does not agree with design JV-$42, and JV-543) having quantities that conflict l with quantities on design drawings. ITAP 3.1.1 prestribes with quantities given on design drawings. drawings completing these checklists, but there are no procedural requirernents Site procedure l)AP 3.1.1 prescribes cornpleting tiese ttut govern their use or detine their forins, but only as an aid to inspection and not as an ultiinate purpose. Acceptance instrunmnt to delineate the inspection criteria criteria were obtained froin drawisigs requireine nts. This procedure requir es using the and change notices. Ilowever, errors applicable drawings and change notices to deterinine have occurred in transferring the pour scope and inspection requiren ents. quantity information froin the design Acceptance of itern q untities are then docuanented on criteria onto the pre placement forrn JV-326 to reflect the requirements stated in tic checklists. design draw mg3 and applicable change documents, installation and quality attributes, such as quantity, are docuinented on Iorin JV-191 (pre-place:nent check-list). Information (oncerning quantities of penetration and cadwelds are docuinented in the applicable travelers l ' and then listed on the traveler checklist (JV-525) and pre-inspection checklists (JV-331, JV-341, JV-542, and JV-343). In addition, surs eyors, concurrence on quantities, and location is doeurnented by the C/S engineer's sigruture on the concrete pour travelers (JV-239). G-63

Generic Resolutions l GR. ! No. Rev. Subject Disciphru- Heastwi/ Problem Justification and Sir,nificance to Safety 100 0 (Continued) in summary, although the inforination on forms JV-331 JV-541, JV-$42, arid JV->43 is misleading, the I true quality configuration is properly docuriiented on I forrns JV-325, JV-526, JV-191, and applicable travelers, thus assuring Liut the quality of docurnentation and interit of desigri are stiaintained. 101 0 lleat number not docu- (PRO /SUB) Because of past interpretations of Because of past interpretations of procedures, heat enented for botting procedures, heat nuinbers are not numbers are not documented on the RIRs for bolting material 1" and under docurnented on t!w RIR for bolting materials 1" and under that do not have heat numbers materials I" and under that do not physically marked on the snaterial. This violates tuve heat numbers physically raiarked current and past site procedures. on the material. This violates current and past BAP 2.3 revisions. When the JV-146 (documentation checklist) and the PO (This GR only applies to document required the vendor to submit CMTRs, the DRG packages completed belore I/3/34.) reviewer verifies that the applicable CMTRs are reviewed, found acceptable, staanped with the correct RIR number, and included in the PO package. DRG i reviewers will accept cases that meet this criteria. RIRs with JV-146 forms prescribing CMTRs require that the material purchased be traceable to individual ' test analysis. When the CMTRs are stamped with the applicable RIR number and are reviewed, found acceptable, and included in the PO package, this provides traceability to the CMTRs ard PO through the RIR, thus ensuring the quality of tre documentation and safety of the plant significance would exist. G-66

Generic Resolutions GR. Justification and Sinnificance to Lfety Rev. Subject Disciph Reason /Probiern _No. Traveler items in wtuch (C/5) Note i on back of JV-433 state s,"All The traveler has been reviewed and signed by the RE, 102 0 content is not required are (P/M) items shall be completed on the f ace QC, and TS departruents signi!ying that the scope of inarked N/A per JV-483 of the form. If contents is not work defined on the traveler had been completed; required, the steins shall be marked therefore, the absence of N/A in drawing items outside

                                               'N/A' by the responsible depart-       the scope of the traveler does not af fect the quality of ,

ment." This requirement was not hardware or installatiori. Further, the DRG reviewer ( inet. must verify that the traveler documents tin scope of work defined in the traveler. t)y signing, the DEL is signif ying that the use of this GR does not have any impact on quality of the plant or hardware. 103 0 Absence of JV-933 froin (C/S) Form JV-933,"th ument Review This GR resolves deficienicies noted where JV-933 traveler packages Chaktist for Concrete Travelers," forrns are missing from concrete travelers. was a required coin rete traveler atta(hinent froin il/l/32 to The JV-933 was required as an attachment to corscrete 3/23/54. liv m JV-9 33 has not been travelers from 1:/1/32 to 3/23/34 and was uwd to part of appla able concrete traveler asust in the traveler review by BA engineering and T5 packages nor has it tx esi filed final review personnel. separately in the vault. The absence of form JV-933 from coinrete trave- The BA DRG firul review is perforrned in accordance Iers is contrary to procedural with procedures and specifications in ellect at tiit-requirements that were then in tiene the work was (ompleted frorn requirements force, independent of the JV-933 forms. Therefore, the use of this GR does not af feet the quality of the iurd*are or the plant when the form is nussing because it is redundant to the review of the traveler and is not used to verif y QA. G-67

Gerwric Resolutions GR. Justification and Significarre to Safety No. Rev. Subi&t Disciphic Reason /l'roblem Improperly checked attri- (11) T he inaximum tensioti attribute on Tte maximum tension attrabute is only observed when 104 0 bute for proper cable the QC inspection decklist (JV-333) a tension monitoring or hmiting device is prescribed by tension on the JV-333 has been erroneously inarked as project engineering and is used Ior installation. inspection form acceptable, even though cable tus been hand-pulled or hand-layed and The requirements stated in K-2999 and project no tension morutoring or tension procedures governing cable installations are that a hmiting devices have been used. tension monitoring or limiting device will be used if liAP 3.3.2 requires the attribute to the tension expected by the pull will exceed /$% of l the cable % maximum allowable tension. Projett l be marked N/A. engineering will indicate on the cable installation l traveler when tension monitormg or limiting l equipment will be required. Therefore, the GR allows QA/DRG reviewers to accept these erroneously marked attributes without coinpromising project quality. sequenced TS in process (C/S) Sequenced TS in-process weldmg AWS D1.1, " Structural Welding Code,"only requires as l 10) 0 welding inspection hold (li) inspec tion hold points were deleted a minimum that the final weld be inspected and l documented 100% of the time. AWS Dl.1 does not points were deleted af ter af ter work was completed, without

              " weld complete" sign-ofI                revising the traseler as reqmred per require that in-process inspect on such as fit-up, on structural attachments                BAP 2.14; in most cases to date, the cleanliness, and weld pre-heat be documented; and liA (AWS code work)                          traveler has the statement "only     welding inspection procedure BT5-40) requires trat weld complete required" as a hold    the various in-process inspection be conducted on a point.                               random surveillance basis to assure compliance to codes or standards. By signing for final weld inspection, the weld inspector is signifying ttut the completed weld meets the requdements stated by both AWS DI.1 and BTS-40) and that either he or tte BA TS final reviewer may delete the pre-established G48

Generic Resolutions J GR. Justification and Significance to Safety No. Rev. Subj&t Disc sphne Reason /Problein (Continued) hold points for AWS DI.I welding without a traveler

10) 0 revision. Therefore, since the final weld is acceptable, the use of this GR will not coinproniise the safety or design of the plant.

(ALL) Fabricatiosi/iisstallation traveler was Fabrication and installation traveler initial review by 106 0 Fabrica tion /installa tion reviewed by QC af ter the BA engineeris.g, QC, and TS was signed out of se-traveler initiation review by engineering, T5, and QC engineering review but prior to TS quence. BA procedures require that traveler initial was signed-off out of review. This is contrary to review be perforrned in a specific sequence (1: engi-procedural requirements which state neering, 2: TS, 3: QC). Regardless of the sign-of t secpence that the resident engineer will sequence, all required reviews are completed and forward the traveler to TS for signed of f prior to the traveler being issued to tre review, arnt then TS will forward the field for work. Each traveler review group tus traveler to QC for review. independent criteria to fo!!ow which do not interface l with other departinents; therefore, tins CR does not af fect the saf ety of the plant or quality of the i hardware. (P/M) BA/DRG is reviewing docnientation GR 107, revision 0, was issued because BA/DRG was I 10/ 0 IP-purctused material not ' for IP-purt tused nuterials that are responsible for resiewing docuinentation for IP-hsted/statused I on the purchased noterals tlut are in the augnwnted class D equipment document hst in augmented class D (radioactive waste) systems. This documentation (radioactive waste) systeins. The documentation has tus been identified as being outside been identified as being outside of the scope of BA/QC of the scope of BA/QC review, but it review, but was still not excluded from the scope of has still not been of f acially exchxfed BA's Records Verification Program. froin the scope of BA's Records Veritication Program. BA's responsibility is to install IP-purchased augmented class D (radioactive waste) materials. Also, in letter M60-54-(03-30)-L. IP authorized BA to perform a documentation inventory as a service to IP, in order that they might scope IP-purchased equipment. 1 G-6) l

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Generic Resolutions GR. Justification and Significarce to Safety twi. Rev. Subjec t Disciplism- Reason [Probiern Prior and subsequent revisions to BAP 3.3.6 do not los 0 (Con tinued) requtre that JV-M0 be included in revised or supple-rnental hariger travelers, unless the anchor bolt loca-tion or torque wall be disturbed. The GR allows QA/DilG to accept those suppleniental travelers where the scope of work does not aflect tht- , anchor bott location or torque. Therefore, projett j quality is not adversely af fected. (L) Prior to //26/32, inspection data and This GR was written because condtut hanger I 109 0 Errors and omissions or i nussing forms froin JV-66/ other intorination was incorrect, f abricalion arx1 iristallation checkhsts (JV-663) and tin-and JV-663 for conduit ornitted f roin, or incoinplete on BA welding inspection sections on conduit hanger travelers I elet tr scal hanger travelers QC suppori fabrication / installation (3V-667) cornpleted prior to 7/26/32 had incorrect l data, errors and ornissions, and nicornplete inf orniation l vaulted before 7/26/32 chet kiists (JV-663) and TS

                                                       " electrical welding inspection"              recorded on the traveler.

sections on conduit tunger travelers (JV-667). In sorne areas, :n> JV-663 The GR allows QA/DRG to accept these travelers if is in the package. the following criteria have been snet:

                                                                                                      - The conduit tunger traveler was vaulted prior to 7/26/32
                                                                                                      - The conduit hanger was reinspected ur&r the conduit support Field Verification Progranit.
                                                                                                      - All af fected attributes or data have be t n verified to be cornplete and acceptable on the new inspection reports.

When these criteria are snet, project quality is not adversely af f ected. G-71

Generic liesolutions GR. Justification and Significarce to Safesy No. Rev. Subject Discipline Reastwi/ Problem 110 0 La<.k of JV-1340 forms for (E) Di1G reviewers are writing DEL This GR was writte n because cable pull installation flex-conduit and missing items for missing JV-1340 forms and travele rs involving cable pulls through flex-conduit calculations for cable pulls for lack of calculations on JV-1340 were missing either the pull-tension calculation form forms for cable pull-through (JV-1340) or the actual pull-tension calculations. flex-conduit. Sidewall tension is not ineasurable in flex-conduit as the K-2999 and project procedure BAP 3.3.2, governing conduit is fixed only at one end dur- electrical cable installations, required that liiaxiniurn ing the cable pull. pull-tension calculations be included in all cable pull travelers, llowever, sidewall tension is not measurable in flex-conduit if the conduit is fixed at only one end during the actual cable pull. The flex-conduit is shpped over the cable during the pull. The inut coupling of the flex-conduit is accomplished af ter completion of the cable pull. Therefore, QA/DRG's use of CR 110 does not adversely af fect project quality. til 0 Missing or incorrect heat (E) Electrical material identifica tion Site procedures required that the material traceability and RIR numbers on QC required per BAP l.) was not noted (heat and RIR numbers) be noted on QC inspection inspection checklists or or was noted incorrectly on QC checklists for specific types of material used in travelers installed prior to inspection ( hecklists or travelers for electrical installations. This was not done in rnany 1/1/34 items installed prior to 1/1/84. This instances, which made it impossible to determine if lack ol information nude it impos- the purchased truterial was safetr related. sible to determine il the purchased material was safety-related. Also, This missing information was documented on NCRs. NCRs were written documenting this Finally, a prograin was developed that required fact, with the disposition from 5&L intensive testing and sanjpling to verif y that all to " accept as is, providing BA QA inaterials installed prior to 1/1/84 met the contract verifies material is A-36." There specifications to be considered safety-related. was no documentation provided G-72

j r-x _-__- Generic Resolutions GR. Justification and Signifinure to $sfety No. Rev. Subj&t Disciphre Reastui/Problein 111 0 (Coritinued) af firiinng ttut sut h scrifications had The results of this prograin were written on an NCR beeninade. which was accepted and dispositioned "uw-as-is" by IP and S&L. The result of this NCR provided direction (through GR 11!) to accept all siiaterial installe d ivi ele ctrical installations prior to 1/1/34 Material installed on or alter 1/1/34 is reqtured to have the rnaterut traceability inforination noted on the QC inspection chtsklist.1I at is inissing us incorrect, a DEL iteni will be gevierated arid resolved on a case-by-case basis iri accordance with site pr ocedures. Tte use of this GR does not or will not' adversely af fect the quahty of tie hardware or docunientatus of CI'S. 112 0 Not approved in lxocess 113 0 Not approved in process Infor nation written on All Coin rete trta k nunibers have been The truck nuniber is entered on the batch ticket by R 114 0 quality documents in written on batch tickets OV-293) in tutch plant personnel at the tune of batching. The perw st. pencil contrary to project directives. batch ticket is brought to the placement by the concrete truck driver with the represented batch of concrete and presented to the U.S. Testing personnel for testing. G-73

Generic Resolutions GR. thsciphne Reason /l*roblein Justification and Significance to Safety No. Rev. Subint At tlut time, the U.S. Testing representative visually l i te 0 (Con tinued) checked the truck nurnbcr on the batch ticket and confirmed that it matched the number on the truck. This number was then transferred to the in-process l concrete test report, which was then coinpleted during the course of the placenient. As stated above, the inf ormation noted on tte documents is correct and can be confirrned. The f act that it was annotated with the use of a pencd has no adverse af fect on the turdware or its documentation. Quality information has beta written l'or pencilled item (other tlan batch tickets) a on documents (other than batch certified true copy of the information provides a ticLets) in pencil, permanent record, as does duphcation of information in other documents within the traveler, to provide R assurance that the use of this general resolution can luve no adverse af fect on the quality of the lurdware or its documentation. 11> 0 Not approved in process 116 0 Not approved in process Concrete test cyhnders are docu- Both of the U.S. Testing forms hst the batch ticket 11/ 0 Concrete traveler packages Civil /Struc- number which represents the concrete batch tested. contain an in-process con- tural enented on two ditferent U.S. Testing formst the in-process concrete test By using this number, the sample can be traced from crete test report and a the in-process test report to the report of concrete reporI of concrete report and the repor t of concrete cyhnders. Each set of test cylinders test cylinders. The field test results and conditions cyhnders which show are directly traceable to the compression test results, identity numbers that is assigned a unique identification number by U.S. Testing personnel. laboratory test, and curing conditions, thereby dif fer from each other. G-74 l

Generic Resolutions GR. Justification and Significance to Safety No. Rev. Subject Discipline Reason /Problern (Continued) This identit scation nuinber dif f ers assuring that the use of this Eeneral resolution will Ii/ 0 have no adverse af fect tw1 quality of the docurnenta-between the in-process concrete test report and tir report of con < rete tion or the safety of the physical plant. cylinders, though this nuniber repre-sents the saine set of cylinders. The ditference is either 1) the CL prefix ('CL - Cyhnder) to the saniple nuinber is deleted on one or both I forius or 2) the nuinerical sulfix to I the sainple nuinber, which designates the set nuinber within the winnple, tus been deleted on (die or both f or nis. l 113 0 Not approved in process g l 119 0 Not approved in process 0 incorrect drawing revisions P/M, C/5,11 Reference drawing revision designa- Engineering is responsible for initiating the guidelnes 120 of a traveler and snaintaining configuratiori control listed on travelers and/or tions are listed on the traveler, and associated docurnentation. the drawings used for inspection are through the traveler's inittal and final review process, placed in the package during the which includes evaluation of design changes. li, at traveler's initial review. QC and final review, it was deterinined that the installed Techincal Services inspectors used configuration did not sneet the latest design criteria, the drawings in the package to per- an addenduin to the traveler or another traveler was forin their inspations even though issued to bring the hardware into confortnance with the drawaiigs did not necessarily the latest design drawings. The fact that final agree with the revision in ef fect on reviewers sonichirnes did not update drawing revisions the date of inspe( tion or final  !!9+M on travelers when the revisions did not af fect review, the traveles a .vk had no adverse hardware quality consequences. l l G-D l l i

l Generic Resolutiawis GR. Justification and Sinnificaire to Safety Subject Ditiphse R cason_if Probtern g,. Rev. In the case of concrete travelers, drawing revision 120 0 (Con tinued) control was niaintained by the QC concrete inspection during the course of the placement inspection, with another verification at tie tinie of final review sign-of f. If drawing ctunges af fected the placenient,' tle concrete inspector verified that they were reflected in the hardware. All revision clunges were noted on tie appropriate drawing checklist. By signing the traveler, engineering and quality final g review signifies in an of ficially and prograinniatically acceptable inanner that the inspetted configuration conforens to the latst design requirernents. In addition, of tie inore tlan 54,000 packages reviewed to date,15 packages tuve resulted in 1i NCRs, and none of those rnandated turdware anodif cations, fur-ther assuring that the use of this generic resolution will not adversely af fect tie quality and safety of tie turdware or its documentation. f l l G-76 I 1}}