ML20205C254

Partially Withheld Ltr Advising of Listed Understanding Re Increased Sample of Visual Weld Insps,Per 831128 Telcon

ML20205C254
Person / Time
Site:	Byron
Issue date:	12/07/1983
From:	Hayes D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20205C137	List: ML20205C134 ML20205C154 ML20205C168 ML20205C219 ML20205C254
References
FOIA-88-345 NUDOCS 8810260431
Download: ML20205C254 (3)

Text

,7 u. e.. :... t u

,.,//2 g NUCLEAR REGULATORY COMMIS$lON

[' ]

[*

f ctoioN m e

8 no noosevcut

..o

> "a. ' E,' [4 t

oten n tvu.:.mois son, DEC 7 1983 MEMORANDUM POR:

R. C. Knop. Cbief. Projects Branch 1

(

TROM:

D. W. Bayes. Chief. Projects Section 15 SU3 JECT:

BTRON REINSPECTION PROGRAM

REFERENCES:

1. CECO preliminay report of status of Byron reinspection i

program dated October 28, 1983

2. N1tC letter to CECO dated November 10, 1983; providing Region III compeuts on item 1 above.

t As a result of Region III's review and comments on CECO preliminary report and the licensee's subsequent rereview of the program commitments, it vas agreed that an increase in sample size of visual veld inspections (Ws) would be necessary for Pittsburgh testing. Hatfield, and Hunter inspectors. -

The following understanding was reached on the increased sample of WIs during a telephone conference betvcen Tom Trans of Ceco and R. C. Knop, W. S. Little. D. W. Hayes and J. Hinds on November 28. 1983.

1.

When a condstion exists that a selected inspector fails to achieve the necessary aFreement rate (i.e. 90% or 95% as appropriate and without CECO Level III review) in the first 3 month period, and the inspector f

has no inspections of the failed attribute to reinspect after the first three month period, then subetitute the next ch onological inspector who performed inspections of the failed attribute.

Besed on the above. status is as follows:

a.

Tet Batfield, the next inspector has been identified.

It appears we tospected approximately 8000 velds during his first 90 days.

I The records are being pulled and sent into the field for removal of fireproofing and painting.

b.

Por Hunter, the next inspector has been identified, and it appears there vill be a population.at approximately 400 welds. ne records are being pulled and sent into the field for removal of fireproofing j

and painting.

[e'lM

• I Cll 89l0260431 880928 i

PDR FOIA tWRPHY88-345 PDR

\\

2 Q{Q 7 jgg3 R. C. Knop 2.

When 4 condition exists that a selected inspector fails to achieve the necessary agreement rato (i.e. 90% or 95% as appropriate and without C :Co Level III review) in the second 3 eonth period and an inspector population expansion is required then expand the population by recycling thru the chronological listing, selecting every fifth inspector vbo performed inspections of the failed attribute in his first three month In this period until the 50% of initial population quota is reached.

process exclude the it apectors who did not have the minimum quantity in these first 3 month period.

Based on ites 2 above, status is as follows:

PTL has 12 inspectors selected in initial population, in order to maintain compliance with program, substitution was inacted due to no reinspectable quantity in certin selected inspectors. This yielded after substitution was executed 10 inspectors who had physical work rainspected and 2 in.

~

spectors who had~no quantity inspections.

Of the 10 above. when the Ceco Level III results are eliminated. 6 exceed the necessary threshold and 4 are short of the necessary threshold.

Of the 4, 2 have no insp6ctions performed after the first 3 months. I has inspections af ter the first 90 days and they are presently being rein-spected, the other had inspections, af ter the first 90 days and they have been reinspected and the inspector again failed to achieve the necessary.

threshold.

Therefore, condition exists that population expension is required.

Initial population of r, elected inspectors certified in f ailed attribute (i.e. WI) vas l_2, therefore, a population expansion of 6 inspectors is required.

2 There were 23 inspectors certified in this attribu.e 23 minus 12 yields 11, inspectors to select from to establish increased quota of 6.

Of the lit i

One inspector, certitled in WI in first 3 months, has minimum quantity 4

in first 3 r.onths.

]77 inspections).

One inspector, certified in WI in first 3 mont s required extension I-25 beyond 3 months to achieve minimus quantity.

1 inspections).

l Three inspectors, certified in WI af ter first 3 months, have minimun

~

1 pe ons d

l j

R. C. Knop 3

(i[- i. [

i One inspector, certitied in VWI in first 3 mont s does no have minimum quantity in total of all inspections.

-5 inspections).

One inspector, certified in VVI af te_ _ first 3 months dose not have r

minimus quantity in total of all inspections. { g ]- 3 inspections).

Pour inspectors, certified in VWI but formed no visual veld inspections.

Records are being pulled for the five PIL inspectors certified in the failed attribute (VWI) that have conducted the required minimum number of inspections even the this requires looking beyond the first 90 dsys.

f<./c

.D. W. Hayes, Gief Projects Section 1B cc C. E. Norelius R. L. Spessard

~

W. S. Little D. Danielson/K. Ward C. C. Williams /R Love J. Hinds R. Leach l

l l

I

?

!}

'N I.~

Commonwealth Edloon 6 n c.m c, be b P

One Fwst National P' ara, CNego. Hfinole XToress Reply to: Post Offie BMO FNJ Chics 90, lihnols 60690 August 17, 1981 Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Wa:hington, DC 20555

Subject:

Dresden Station Units 1, 2 and 3 Quad Cities Station Units 1 and 2 Zion Station Units 1 and 2 LaSalle County Station Units 1 and 2 jytsn Station Units 1 and 2 Braidwood Station Units 1 and 2 Response to NRC Generic Letter No. 81-01 "Qualification of Inspection, Examination, Testing and Audit Personnel" O'

NRC Docket Nos. 50-10/237/249, 50-254/265, 50-295/3C % 50 373/374 50-454/455 and 50-456/457 1

Reference (a):

D. G. Eisenhut letter t'o 511 Licensees cated May 4, 1981.

Dear Mr. Eisenhut:

Ref erence (a) requested that-the Commonwealth Edison Company provide A commitment to meet the intent of Regulatory Guide 1.58. Revision 1 (positions C.S. 6, 7, 8 and 10) and 1.146, dated

{;

August 1980, within ninety (90) days.. If we elected not to adopt the methods given in these Regulatory Guides, we were requested to pp..

describe our alternate methods for complying with 10CFR Part 50, evt.

Appendix B, regarding the qualification of nuclear power plant inspection, examination, testing, and qualification of audit personnel.

r,..

-c' 5' -

The Commonwealth Edison Company Quality Assurance Program

.:n qs Topical Report CE-1 A currently provides such commitments to

~ Regulatory 091 des 1.58. Revisicn 1 and 1.146 dated August 1980.

The Topical Report also states that "exceptions or alternatives to this

-- Topical Report for specific plants identified in the Safety Analysis

Report or' Technical Specification will take precedence over commitments in this Topical Raport."

f f,

f.k o

i t

_ w T

-_,y

-, - -,. - -,. - -. - - * +

f

,leu

~

D August 17, 1981 o

. G. Eisenhut However, Reg. Guide 1.58, Revision 1, position #6 requires that a candidate for Level I, !!, or 111 Inspector for inspection and test activities be a high school graduate or should have earned the General Education Development equivalence of a high school diploma.

In our judgement, this is an unnecessary and unfair restriction.

Personnel can be trained, evaluated and tested to detehaine if they are qualified for a specific test or inspection function, regardless of whether they have a high school or equivalent diploma or not.

A perso-

.hould be utilized based upon his capability to perform the job,,. J on his qualifications and abilities.

In our view, continual on the job trair.ing with timely performance reviews is an acceptable method of complying with 10CFR Part 50, Appendix B regarding such qualification of plant inspection, exemination and testing personnel.

Please address any further questions that you may have concerning this matter to this office.

One (1) signed original and one-hundred and thirty-nine

-(139) copies of this letter with enclosure are provided for your use.

C Very truly yours, L. O. DelGeorge Director of Nuclear Licensing t

cc:

J. G. Keppler, Region !!!

All Region !!! Inspectors Enclosure n

im

";?l@

W

/.c?.M.2 xh1.

1 1

241ON

,9 Y

. w.,,

O 'J '

4 O., t O.-

4k Of

):qs f.I

^^

o k

Commonwee dison t

> One Fust Natione f.ke, Ctucago, Ithnois j

,g

~

7 Address Reply to: host Othee Box 767

' Chicago, lihnois 60690 N_-

$<8 October 28, 1983 19 l

Mr. Ames G. Keppler, Regional Administra'or U.S. Nuclear Regulatory Comission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Generating Station thits 1 and 2 Inspector 0;alification and Certification Inspection Report Nos. 50-454/82-05 and 50-455/82-04 References (a): June 24, 1982, letter from C. E. Norelius to Cordell Reed.

(b): February 23, 1983 letter from W. L. Stiede to J. G. Keppler.

Dear Mr. Keppler:

This letter provides a preliminary report on actions taken to verify the adequacy of QC inspections during construction of Byron Generating Station. This reinspection was undertaken as described in reference (b) in respor.le to a Violation identified in reference (a).

The enclosed report describes the Byron reinspection program and sumarizes the results. A ruber of minor discrepancies were identified during the reinspections, but when taken as a whole the results do not indicate generic defects in past practices for the training and certification of QC inspectors. For this reason, no further inspection is judged necessary at this time, i

Final analysis of the results is not yet t.oTplete. The final report cill be provided within four weeks and will document our complete analysis of the inspection results.

In the interim, we art available at your convenience to discuss the enclosed report. We are aware that regional inspection personnel have been involved in reviewing the reinspection program during its condxt. To the extent that we are aware of concerns identified during those reviews, those concerns will be addressed in the final report.

Fo rd - Pb 3 ff" h

6/3 N

YB 0073 1 1983

c e

J. G. Keppler October 28, 1983 To the best of my knowledge and belief, the statements contained herein and in the attachment are true and correct.

In some respects these statements are not based on my personal knowledge but upon in.'ormation furnished by other Conmonwealth Edison employees and contractor employees.

Such information has been reviewed in accordance with Conpany practice and I believe it to be reliable.

Please direct any questions that you or your staff :nay have concerning this matter to this office.

Very truly yours, lAh

/

Louis 0. DelCeorge

(

j Staff Assistant Office of Vice President, R;clea' Operations im l

7511N 1

i i

t 4

f i

g 3

q F

j i

t i

P l

J J

l 1

FRELIMINARY REPORT ON REINSPECTION l

CDOUCTED AS A RESULT I

OF G CO R IANCE ITEM J

50-454/82-05-19 & 50-455/82-04-19, 1

l l

i r

d I

r i

i i

1 1

i i

I i

l.

i r

l i

I 1

i October 28, 1983 i

i i

i 7511N

.i t

j

{

. = - - -..

h b

4 i

I t

(DNTENTS i

)

I SYPXPSIS t

i II BACXCROUPO a

I III SCCPE I

IV OEPTH OF REINPECTION PROGRAM t

l V

REIN PECTION RESULTS t

i VI QUALITY ASSURANCE CONTROL OF REINSPECTION PROGRAM 1

]

APPENDIX A REIN!PECTION RESULTS BY TYPE / AREA 0F CERTIFICATION APPEtOIX B REINPECTION RESULTS BY INSPECTOR APPEPOIX C SUBJECTIVE INPECTION DISOEPANCIES - EVALUATION OF SIGNIFICANCE 1

i APPENDIX D OEDECTIVE INPECTION DISCREPANCIES - EVALUATION OF SIGNIFICANCE u

i.

f I

7511N 4

i i

i i

I i

i j

f 1

l l

i

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

N

{

{

.O

.l I.

SYNOPSIS i

i The reinspection program conducted as a result of concerns defined in IE Inspection Report Nos. 50-454/82-05 and 50-455/82-04 associated with the qualifi-cation and certification inspection personnel is nearly completed. The results demonstrate the past and present capability of the quality control / quality assurance inspection personnel to perform the measurements, interpretations, comparisons, and judgements associated with evaluation of the quality of installation of structures, components, cnd assemblies at the Byron Generating Station.

The physical reinspection activities are conplete. Activities remaining are compilation and analysis of data, and engineering analysis of the significance of l

discrepancies found. The results of the Program, which are discussed in greater detail in subsequent sections, are sumnarized below by contractor.

i IABLE 1.1 REINPECTION FHCCRfN StJfMRY l

Number of Reinspection Number of Reinspection Cbjective Results Subjective Results Contractor Reinspections Acceptable (l)

Reinspections Acceptable (2)

Blount 2,390 98.8%

0 WA Johnson Controls 7,812 99.4%

1,459 95.5%

H;nter 69,598 99.0%

3,662 96.7%

Nisco 2,792 99.64 229 100.04 Hatfield Electric 58,71S 96.7%

21,905 94.2's j

J I

j Powers-Azco-Pope 9,104 e6.04 7,646 8(.1%(3) l l

Pittsburgh Testing 7,269 99.1%

4,973 91.3%

i Peabody Testing 0

N/A 163 96.9%

)

I l

Note (1): Program Acceptance Criteria is 9).0%

l (2): Program Acceptance Criteria is 90.0%

(3):

100% of accessible work was reinspected based on Program defined j

l saTple expansion.

l

.I i

A large cercentage of the deficiencies recorded in the reinspection program involved subjective attributes. Subjective attributes are those in which review of

]

the work performed required the inspector (and reinspector) to make an item-by-item j

Judgment of attribute quality based on visual observation, as opposed to the quan-l tifiable characteristics of objective attributes. Examples of subjective attributes

)

include weld overlap and undercut, while examples of objective attributes include A significant portion of the deficiencies component size and material type.

In identified upon initial reinspection involved subjective weld attributes.

j; August, a review of the initial reinspection effort by the MC staff suggested that

C the inspectors performing the reinspections were interpreting criteria in an excessively conservative manner. Third party review of initial reinspections of sWjective weld attributes confirm the excessive conservatism in applying criteria for the acceptability of such attributes. Thus in many situations attributes which i

were rejected won initial reinspection were found to be acceptoble upon third i

party reinspection managed by Sargent & Lundy.

In addition, in some situations in which attributes were rejected upon initial tnird party reinspection, subsequent reinspection by a Commonwealth Edison Level III reinspector determined that the attributes were acceptable. As discussed below, engineering analysis has cemonstrated that even those subjective weld ar. tributes rejected af ter both levels t

of third party review provide an appropriate factor of safety.

[

n Section II, BACxm00N3 describes the evolution of events which lead to reinspection progru and provides a brief description of the reinspection program 1

criteria.

Section III, SCOPE descrfbec in brief form the quantity of features reinspected and provides a brkf description of the resources required to execute 1

the reinspection effort.

Section IV, DEPTH OF REINSPECTION PROGRAM provides dat,a in a format which l

describes the volume and extent of the reinspection program.

Section V REINSPECTION RESULTS provides a sunnary by contractor of the results t

for the inspec, tors selecTeo ror reinspection against the thresho.d established by the criteria for demonstration of acceptability. Only one ccotractor required expansion into the second and third phase of the reinspection program criteria.

Almost one hundred percent of the work previously performed by this contractor was reinspected as a part of the reinspection program.

It is important to identify and recognize that the subject contractor's installation-inspection program contained a l

j multiphase inspection and inspection confirmation structure which by execution of planned subsequent inspections would have identified many of the discrepancies i

established in the reinspection program. All other contractors demonstrated acceptability against the threshold established by the criteria in the first phase of the program. (Final validation of this data will be cocpleted prior to submittal of the final report.)

Section VI, QUALITY ASSLRANCE CONTROL OF REINPECTION PA0 GRAM describes the i

OJality AssuranceTc'tivities performed to establish and verify that the reinspection program was properly irrplemented.

APPENDIX A, REIN PECTION RESULTS BY TYPE / AREA 0F CERTIFICATION and APPENDIX B,

REINSPECTION RESULTS BY INSPECTOR present the detailed statistics created by 3

the reinspection program.

l APFENDIX C, SUEDECTIE INSPECTION DISCREPANCIES - EVALUATION OF SIGNIFICAPCE and APPENDIX 0, OIDECTIW INSPtECTION DISCREPArCIES - EVALUATION OF SIGNIFICANCE i

present a description of the types of discrepancies identified in the reinspection

-l program, the corrective actions taken, and engineering analysis of significance of i

the identified discrepancies.

7511N j

. _ = _ -

C G

~ '

s l

II. EMCXCR0tND An NRC special team inspection was conducted at Byron Station during the period of March 29-31, April 1-2, 5-9,12-14, and May 11, 1982. During the inspection several violetions were identified, one of which was an apparent noncogliance with the requirements for the initial qualifications of 2

personnel who perform inspection, examinaiion and testing to verify conformance to specified requirements. The Notice of Violation dated Ane 24, D82 identified this as noncompliance 82-05-19/82-04-19. The noncompliance letter also requested that Comonwealth Edison assure the validity of inspections performer, by quality control inspectors who were deemed to bq improperly trained and qualified.

The issue of nWompliance item 82-05-19/82-04-19, was one where the NRC Inspector found tha', the contractor programs for qualifying Q.A./Q.C.

personnel at Byron were inconsistent with the current NRC int 0pretation of the requirements of ANSI N45.2.6-lO78. Specifically, the Inspector found deficiencies in the contractor's evaluations of initial inspector capabili-ties, in documentation of initial certification, and in the criteria used to establish inspector qualififNtion. The NRC staff did not find that these j

procedural deficiencies had compromisid the quality of plant construction.

l However, in issuing the violation, they made it clear that the qualification j

programs were to be upgraded and the quality of work already completed was to be varified in some manner. With the completion of the reinspection program outlined below, those obligations have been met.

s Over the years, inspector certification practices have been continually upgraded to remain consistent with the changing interpretation of the applic.

able standard, ANSI N45.?.6.

Prior to this NRC inspection, Commonwealth Edison had relied largely upon reinspections, audits and surveillances to assure the effectiveness of contractor programs for certification of QC

]

inspectors. As a result rf NRC concerns stated during the inspection. On i

j April 27,1982, the Byron site contractors were instructeo to revise their certification practices to incuporate standard features and methods established by Comonwealth Edison. These features and methods were further l

upgraded on Nne 9,1982 based on coments from NRC inspectors. Contractor l

programs were all revised by September 30, 1982.

In the 11y 30,1982 response to the Notice of Violation, Commonwealth Edison outlined a program which would validate previous QC inspections.

This was to be accomplished by requalifying the inspector, reviewing the inspector's l

qualifications to new criteria, or by overinspection of a portion of the j

f inspector'. work. The NRC found that this verification program did not i

adequately address the quality of inspections performed early in the j

inspector's employment over the full course of the plant construction perled.

1 Alternate verification programs were discussed with the NRC during several meetings. Options discussed included a "vertical slice" reinspection program i

1 I

l

4 involving complete multi-disciplin8ry reinspection of representative plant areas. Also dis:ussed was a reevaluation of all inspectors' qualifications and experience according to a complex formula.

Finally, an extensive program of reincpections was agreed upon and documented in a Commonwealth Edison letter dated February 23, 1983. A program of reinspections was initiated which would verify on a contractor-by-contractor basis the adequacy of past QC inspector training and cartification practices at Byron Station.

A brief sumary of the reinspection program follows:

A(1) For 6 contractors, every 5th inspect 0r selected (NRC Senior Resident *nspector added from 2 to 4 inspectors per contractor).

A(2) For 2 contractors, every inspector selected.

l B

For each selected inspector, each individual inspection performed during the inspectors first three months reinspected, where accessible.

i C

Reinspection conducted utilizing inspection criteria applicable to initial inspu tion period.

l O(1)

Inspections classified as objective require 95% agreenent rate in repeat inspection.

0(2)

Inspections classified as sWjective require 904 agreement rate in repeat inspection.

O(3) Subjective inspections would be sWject to independent third party review to establish true rejectability.

E When selected inspector failed to achieve 95% agreement i

i rate on objective inspections, or 904 agreement rate on i

sWjective inspections; then additional three months of inspection work reinspected for the type of inspecticn which failed to achieve required agreement rate.

F If selected inspector failed to achieve 954 agreement rate or 90% agreement rate, as approprirte, in second three month period, than all inspections performed by the inspector of the type which failed would be reinspected; and the original sample size of inspectors would be increased by 506.

1 In an effort to identify deficiencies in certification programs, this reinspection program focuses on the quality of the work performed by QC inspectors imediately after their certification.

It covers the entire period of a contractor's work on site and it icknowledges that all inspections are I

repeatable in varying degrees, dependia upon the subjectivity of the feature l

J

O o

c

• being inspected.

It contains conservative acceptance criteria.

It also provides for higher level overDwpections to compensate for possible excersively conservative application of acceptance c lteria by reinspectors and provides for expansion of tha reinspections when a deficiency in the contractor's certification program is apparent.

In the course of development and execution of the reinspection program, it became necessary to establish a minimm quantity of items to be reinspected by each inspector chosen in order to create an adequate data base for I

evaluation. When the mininum quantity established was not obtained in the first three-month period reinspection went beycod the initial three-month period in order to achiev,e the minimum quantity.

In those cases where a, selected inspector did not function as an inspector for a three-month period and thus did not have the minimum quantity in this period, the results of the reinspection were recorded but no exptnsion occurred due to lack of population. Additio' tally, in the course of the development and execution of 3

reinspection program it was necessary to establish other such programmatic features associated with the recreatability of inspections in order to conplete the agreed-upon reinspection program and dat. analysis.

In order to assure that reinspection results were consistent and accurate, the program accepted by the NRC provided for a Level III third party over-inspection to review the determinations made by the initial reinspectors.

The provisions for the third party review recognized the nature of judgmental reinspection of subjective attributes such as weld surface quality.

As previously indicated to the Recion III Staff, and as docunented herein, Sargent & Lundy managed initial third party review, and a Commonwealth Edison i

1 Level III inspector provided an additional layer of third party reivew. All such inspections are reported and were included in the reinspection data base. The evaluation made by the Cortnonwealth Edison Level III Inspector with 1

regard to those attributes which he examined determined the ultimate i

acceptability of those attributes.

DJring the course of execution of the reinspection activities, the NRC

)

Region III staff conducted numerous reviews of the, activities and maintained a l

l relatively high level of involvement in the proceedings.

Inspection Report Nos. 50-454/83-26, 50-454/83-37, and 50-454/83-38 sunvnarize relevant site inspecticas.

r I

7511N f

O c'

C-d l -

i i

III. SCL.PE i

i 1he reinspection program began February 22, 1983 by meeting with contrac-tors to identify purpose and content of the activities to be performed. The individual inspectors selected to be reinspected was established, and the process of record search to identify individual inspections to be reinspected was initiated.

a The quaritity of.nspectors selected to be reinspected is presented in d

Table 3.1.

i Table 3.1 QJantity Of Inspectors Reinspected i

i l

4 Total tt;mber Of Percent Of Population Of Inspectors Inspectors l

Contractor Inspectors Reinspected Reinspected 29%

I 8 (1)

Blount 28 5

714 M nson Controls 7

Hunter 84 21 25%

i NISCo 8

4 504 l

Hatfield Elec.

86 22 264 Powers-Azco-Pope 21 19 (1) 905 l

Pittsburgh Testing 85 19 225 2

j Peabody Testing E

J (1) 164 I

TOTAL:

356 104 294 NOTE (1):

100% of the inspector population was reviewed for performance of the reinspection. Those inspectors not included had no reinspectable items.

L 4

4 1

a i

7511N

(

a t

t t

l j

i i

C C

. The quantity of individual inspections reinspected is presented in Table 3.2.

Table 3.2 Quentity Of Items Reinspected Wmber Of Wmber Of Reinspec.cd*

Cbjective Stejective Inspection

,(ontractor Inspections Inspectionj Months Blount 2,390 0

89 Jchnson Controls 7,812 3,459 1

18 Hunter 69,598

,662 62 NISCo 2,792 229 12 Hatfield Elec.

58,718 21,905 65 Po wers-Azco-Pope 9,104 7,646 149 Pittsburgh Testing 7.269 4,973 100 Peabody Testing 0

163 20 TOTAL:

157,683 40,037 515 The reinspection effort regulred a significant committnent of insnhours and materials to execute.

After February 22, 1983 it took three weeks to search inspection records to establish the initial voltrne of individual inspections te be reinspected. Actual conduct of reinspection began Ha.ch 14, 1983.

The reinspections were performed by quality control inspectors who were qualified cred certified by the contractors to the methods established as a result of the corrective action in response to noncompliance 82-05-19/82-04-19. Through Septenter 27, 1983 twenty-seven weeks of reinspection have been conducted with the secunulation of 1166 inspector weeks expended.

In order to perform the inspections it was necessary to erect scaffolding, remove paint, fireproofing, insulation, etc. These activities through September 27, 1983 have accumulated over 3050 man weeks of craft labor support.

The reinspection operation lus been functioning nominally on 58 hour6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> work weeks.

Through September 27, 1983 over 240,155 manhours of effort have been expended in the execution of the reinspection program.

• K)TE:

This is total amount of 3-<nonth periods and any necessary expansion of original Inspector's activity.

7511N

g g

• IV. OEPTH OF REIN!PECTION PROGRAM d

The method established for selection of inspectors to be reinspected was formulated to be representative of inspectors over the duration of the project from the begiming to the point where methods enployed to qualify and certify inspectors were revised to address the MC Inspectors concerns of noncompliknce 82-05-19/82-04-19.

In order to test the selected population of inspectors relative to the areas of qualification of the total population of inspectors, a conparison was performed. The results of the comparison are presented on a contractor basis j

in Tables 4.1, 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, and 4.8.

Table 4.1 - Blount Number Of NJmber Of Percent Area Of Inspectors QJalified inspeClors In IOCluded In Qualification In Area Area Reinspected Reinspection Concrete 12 2

17%

Masonry 6

2 33%

Concrete Expansion Anchors 5

2 ACA Weld Inspection / Structural 11 4

364 f.st-Tensioning

• 10 0

OE Cadwelding' 4

0 OE Calibration

• 5 0

OE Fire-Proofing

• 3 0

OE Receiving' 6

0 CR NOTE:

• areas of inspection which camot be recreated for a reinspection.

Table 4.2 - Johnson Controls Rante'r Of MJnter Of Percent Area Of Inspectnrs QJalified Inspectors In Included In QJalification In Area Area Reinspected Reinspection Visual Inspection 7

5 715 Table 4.3 - Hunter Ranber Of Ramber Of Percent Area Of Inspectors QJalified Inspectors In Included In Qualification In Area Area Reinspected Reinspection Piping / Hangers 57 15 265 Piping 6

1 175 Piping As-Built 21 5

244

l p

g.

1 l

Table 4.4 - NISCO r

Mster Of Meter Of Percent Area of Inspectors Qualified Inspectors In Included In 4alification In Area Area Reinspected Rt. inspection Visual Welding 6

4 67%

Mechanical 6

4 67%

Table 4.5 - Hatfield MJnt>er Of MJ2er Of Percent Area Of Inspectors QJalified Inspectors In Included In Qualification In Area Area Reinspected Reinspection Visual Welding 20 7

35%

Conduit Installation 21 6

29%

Cable Terminations 21 5

24%

Equipment Insta11: tion 14 2

144 Equipment Modification 12 2

17%

Ccble Pan Installation 21 1

5%

i Cable Pan Hinger 22 2

9%

C:nduit As-Builts 28 8

29%

A-325 Bolting Insp.

11 1

95 Table 4.6 - Powers-A co-Pope MJ2 er Of Number Of Percent i

Area Of Inspectors 0;alified Inspectors In Included In Qualification In Area Area Reinspected

_ Reinspection I

Welding Inspector 20 19 955 Receiving Inspector

• 2 0

04 I

o Indicates areas of inspection which cannot be recreated for a reinspection l

l

c-c l

r Table 4.7 - Pittsburgh ;'esting MJmber of Msrber Of Percent l

Area of Inspectors OJalified It spectors In Included In Qualification In Area Aret Reinspected Reinsreg. ion 1

Concrete Expansion l

Anchors /Structutcl 43 9

215 Visual Welding 21 10 485 i

Coicrete-fielWLab/ Plant

• 93 0

OE Soils - FielWLab' 29 0

04

]

Cadweld' 10 0

0E Post-Tensioning' 3

0 05 a

l Fireproofing*

4 0

04 Coatings

• 2 0

05 Calibration

• 17 0

0E l

Electrical

• 12 0

0%

• Indicates areas of inspection which cannot be recreated for reinspection.

l For example, inspection of fireproofing and coatings are performed on the surfaces to be coated and during the coating process rather than after the

]

application is complete. Electrical inspections were of cable tray cleanliness and cable pulling tension, i

I l

i i

l 7511N l

]-

i i

.I, i

l 1

i d

l i

l i

4 i

1 l

i i

i

)

c F

. Table 4.8 - Peabody Testing Netber Of Merber Of Percent Area of Inspectors Qualified Inspectors In Included In 0;alification In Area Area Reinspected Reinspection Visual Welding /

Structural Steel 6

6 1004 Concrete

• 28 0

05 Soils

• 20 0

CE Cachveld*

8 0

05 Coatings

• 1 0

04 Calibration

• 1 0

05 o Indicates areas of inspection which cannot be recreated for a reinspection In order to test the selected population of inspectors and their corresponding volume of time reinspected to the volume of time of inspections accumulated, a comparison was performed. The results of the comparison are presented in Table 4.9 TABLE 4.9 Percent of Total Accumulated Reinspected Inspection Inspection Manths Inspection Months Months Reinspected

[

Blount 424 89 21%

Johnson Contrels 60 18 304 M;nter 1,107 62 6%

NISCo 51 12 24%

Hatfield Elec.

628 65 104 i

Powers-Azco-Pope 15 2 149 984 I

Pittsburgh Testing 1,015 100 104 i

Peabody Testing 181 20 114 TOTAL:

3,618 515 14%

Tables 3.1 and 4.1 thru 4.8 demonstrate that the samling basis achieved the selection of a significant portion of the population of inspectors, and achieved the selection of a significant portion of the inspector population in an area of certification. Tables 3.2 and 4.9 demonstrate that a significant quantity of items and percentage of inspection activities were covered through this sampling basis.

The sample of one out of five on a chronological basis tas a technique which resulted in inspections of work of many types and of varied types being reinspected. Even though the percentages varied somewhat.

te are confident that the results are typical of the whole.

J

e c.

i t

' V.

REIN!PECTION RLlJLTS The results of the reinspection program are presented on a by contractor basis in Tables 5.1, 5.2, 5.), 5.4, 5.5, 5.6, 5.7, and 5.8.

inble 5.1 - Blount l

Inspection Status Of l

Type Reinspection Condition Cbjective Complete All 8 inspectors who performed objective inspections, acceptable at end of first 3 month period.

j Subjective tet Applicable All inspections included in i

reinspection population l

classified as objective.

4 r

Table 5.2 - Johnson Controls i

1 Inspection Status Of l

Type Reinsoection goMition I

i Cbjective Complete 4' inspectors who performed I

objective inspections, acceptable at end of first 3 month period.

1 inspector who performed objective inspections did not i

have minins quantity in first 3

)

month period, nor in second 3 month period, nor in total of inspections, all of his work was 1

reinspected.

Subjective Cortplete All 4 inspectors who performed

]

subjectiveinspections acceptableatendoffIrst3 J

month period.

7511N j

(-

(~t

-D.

Table _5.3 - H;nter Inspection Status Of Type Reinspection Condition Cbjective Complete 19 inspectors who performed objective inspections, acceptable at end of first 3 month period.

1 inspector who performed objective inspections did not have mininum quantity in first 3 month period, nor in second 3 month period, nor in total of i

l inspections, all of his work was reinspected.

Subjective Complete 15 inspectors who performed subjective inspections, acceptable at end of first 3 month period.

i 1 inspector who performed subjective inspections did not have minimum quantity in second 3 month period, all of his work was reinspected.

Table 5.4 - NISCo i

Incpection Status Of J.

Type Reinspection Condition Cbjective Complete All 4 inspectors who performed objective inspections, acceptable at end of first 3 month period, j

I Subjective Complete All 4 inspectors who performed I

subjectiveinspections, acceptable at end of first 3 k

month period.

l i

6

(

l t

i i

i J

(.

p.

l l

Table 5.5 - Hatfield Electric Inspet;.lon Status Of Type Reinspection Condition I

(bjective Complete All 16 inspectors who performed i

objectiveinspections,neceptable at end of first 3 month period.

Subjective Complete All 7 inspectors who performed subjective inspections acceptableatendoffIrst3 month period, l

t l

t 7511N

~

e

(

c Table 5.6 - Powers-Azco-Pope Inspection Status Of e

Type Reinspection Condition Cbjective Complete 12 inspectors who performed objective inspections, acceptable at end of period'.

2 inspectors who performed objective inspections did not have minimum quantity in period *,

all of his work was reinspected.

5 inspectors who performed objective inspections triacceptable at end of period *,

all or their work was reinspected.

Subjective Ccynplete 7 inspectors who performed stbjective inspections, acceptable at end of period *.

2 inspectors who performed subjective inspections did not have minimum quantity in period *,

all of their work was reinspected.

10 inspectors who performed subjective inspections unacceptable at end of period *,

all of their work was reinspected.

• For this contractor, the period consisted of the first six month's work; that is, first and second three months results combined. The data generated during the reinsoection program is not readily separable into first and second three month periods.

c.

c

' Table 5.7 - Pittsburgh Testina Inspection Status Of Type Reinspection Condition Cbjective Complete 8 inspectors who performed objective inspections, acceptable at and of first 3 month period.

1 inspector who performed objective inspections, acceptable at end of second 3 nonth period.

Subjective Complete 10 inspectors who performed subjective inspections acceptable at end of fIrst 3 month ceriod.

l Table 5.8 - Peabody Testing l

l Inspection Status Of I

Type Reinspection Condition l

Cbjective Not applicable All inspection included in reinspection population classified as subjective.

Subjective Complete 3 inspectors who performed subjective inspections, acceptable at the end of first 3 month reinspection period.

3 inspectors who performed subjective inspections did not l

have minimun quantity in first 3 l

month period, nor in second 3 month period, nor in total of inspections, all of their work was reinspected.

7511N

e c

. VI. QUALITY ASSLRANCE CONTROL OF REINSPECTION FROGRAM The Commonwealth Edison Quality Assurance Department has been actively involved in the re-certification of current on-site Q.C. inspectors and the monitoring of the re-inspection of work perfonned by Q.C. inspectors who were on-s'.te during the early stages of construction. In early 1982, Comonwealth Edison comitted to re-certify all site Q.C. Inspectors to ANSI N45.2.6-1978, in accordance with guidelines and interpretations established by Edison.

The Site Quality Assurance Department and Project Construction Department each assigned personnel to work full time with the site contractors to iglement the re-certification program. The results of the re-certification program oere, in turn, audited by the Edison General Office Q.A. Department to assure compliance to the Edison guidelines. As a result, it has established that the site contractors have properly re-certified their Q.C. Inspectors.

Audit of Re-inspection Program Implementation When the re-inspection program was established in February,1983, and re-inspections began in late March, the Site Q A. Department performed audits and surveillances to monitor the re-inspection activity.

The first audit was i

perfonned June 21 through Jul I

of the re-inspection program.y 6,1983, which was about the expected mid-point The audit (#6-83-66) was conducted by a six man l

team and covered the activities of the following seven site contractors:

Hmter, Hatfield, Johnson Controls, Pittsburgh Testing Laboratories, Powers Azco Pope, NISCO, and Blount Brothers. The purpose of the audit was to verify that the re-inspection program was being implemented in accordance with the commitments made in the Edison letter dated February 23, 1983, from Mr. Stiede to Mr. Keppler. The audit examined:

1)

Re-inspection sagle size 2)

Application of inaccessibility 3)

Third party review 4)

Disposition of discrepancies 5)

Docunentation of inspection results 6)

Qualifications of re-inspection personnel The audit identified two basic concerns. First, it was found that four contractors had not yet established the means for implementing actions to correct or disposition the discrepancies identified in the re-inspection process. The four contractors were H;nter, Hatfield, PTL, and Blount Brothers.

This was classified as a finding.

Second, it was found that there was some misunderstanding among the ccatractors regarding how to handle special problems. For exagle, in one case a component had been inspected in January,1980, and again in May,1982.

The contractor chose to classify the first inspection as "inaccessible"

c c.

• cithout evaluating if the second inspection corrpletely superseded the earlier inspection.

In another case a contractor had a Q.C. inspe: tor who had been certified in several different disciplines within the first three months of his employment, but the contractor had only re-inspected the first discipline in which he was certified.

In total, eight observations were identified which addressed issues, such as these, which needed clarification.

Overall the audit te3m concluded that the contractors were actively implementing the re-inspection program. The audit however, served the purpose of clarifying how the re-inspection guid'ines were to be interpreted.

Special Audit of m tfield As the re-inspection program progressed beyond the early stages, Edison Quality Assurance and Project Construction personnel became aware of problems at Hatfield in determining which welds were to be included in the re-inspection.

These problems were primarily due to the manner in which Hatfield generated and mcintained inspection records during the early years of construction. Also, the NFC advised Edison of concerns with the Hatfield inspection records. As a result, Edison Site Q. A. perforned an audit to specifically address these concerns. The audit (#6-83-124) was conducted by a three man team during the period 8/24/83 through 9/1/83.

The scope of the audit included the following:

1)

Review doctsnentation practices 2)

Correlation of weld record cards to welders and inspectors 3)

Identifying the latest weld record 4)

Re-nmbeilng hangers 5)

Re-inspection - incorrect assurrptions 6)

Procederes not being followed It was found that, in some cases, it could not be determined which inspector originally performed an inspection on a particular weld. As a rcsult, the weld was removed from the re-inspection population in accordance cith the guidelines of the re-inspection program. This helped achieve accuracy in associating weld inspections to the proper inspector. Because of the general manner in which the inspection records were kept, it was clear that personnel not familiar with all aspects of the record keeping process may cisunderstand the manner in which the weld traveler records were selected for the re-inspection program. To resolve these issues, S tfield is currently irtplementing a computerized data base management system to reconcile weld travelers to hangers.

This should insure that the initial hanger inspections assigned to each inspector were correct and it should provide an accurate means for identifying those hangers which do not have complete inspection records.

g

(

. 0;alification of Inspectors DJring Re-inspection In order to assure that Q.C. personnel performing re-inspections were fully qualified, Site Q.A. directed PTL to perform a surveillance to verify that their inspectors could independently at: rive at the same inspection results as the contractors Q. A. inspectors who were performing the re-inspections. The surveillance ran from August 1,1983 to September 19, 1983. The results show a correlation ranging from 944 to 10CA and it appears that the contractor's Q.C. personnel doing re-inspections are doing accurate and acceptable work.

Conclusion Based on the above information, Quality Assurance concluded the following:

1)

Edison commitments in the February 23, 1983 letters were properly implemented.

2)

Re-inspectors have done acceptable work.

3)

Based on results to date, Q.C. inspectors who were on-site during the early stages of construction did acceptable work.

751LN

C' r

_m.

APPENDIX A l

1

]

REINPECTION RESULTS BY TYPE / AREA 0F CERTIFICATION i

A tabulation of inspection results by inspection type and by inspection area of certification is presented on a by contractor basis in Tables A.1, A.2, i

A.3, A.4, A.5, A.6, A.7, and A.8.

Appendix B shows actual quantities of acceptable and rejectable results by attribute.

Table A.1 - Blount Bros.

I.

Results By Inspection Type, 1

i Reinspection Results (Acceptable) l Level 11 l Independent Third l Leve) III Type Reinspection i

Party Review l

Reinspection -

I I

I Subjective 1

(2) l (1) 1 (1) i l

l l

i l

Objective 98.8%

l (1) l (1) r l

l l

t II.

Results By Inspection Attribute I

l Initial Sample Period i

Expansion Sample Period l

i i

i l

I I

No. Of I

l No. Of I

People Final X l

People Final A Attribute Reinspected Acceptable Reinspected Acceptable 1

I

1. Weld Detail l

l l ' #'

l 4

1 98.7%

1 (1) 1 (1) l I

l j

(Objective)

I I

2. Concrete l

l l'

I 1

2 1

10m I

(1) l (1) i 1

t (Cbjective)

{

3 I

i

3. Masonry I

l I

l l

2 1

99.4%

l (1) l (1)

I I

I I

(Objective) l l

J l

i

4. Concrete i

l I

]

Expansion i

2 l

96.1%

l (1)

I (1)

{

i Anchor i

l l

l l

(Objective) i i

l I

i (1) Not required (2) Pet applicable

_.=_.

,a

' l Table A.2 - Johnson Controls 1.

Results By Inspection Type i

Reinsg,ection Results (Acceptable) j l

Level II l Independent Third i Level III Type l

Reinspection Party Review' Reinspection i

4 l

Subjective 94.9%

95.5%

l (1)

(1386/1459)

(1394/1459) l-1 I

(bjective 1

99.4%

(1)

(1) l t

11. Results By Inspection Attribute j

l Initial Sample Period l

Expansion Sample Period i

I I

I l

No. 0f I

l No. 0f l

l People l

Final %

People l

Final %

l Attribute l

Reinspected Acceptable Reinspected l Acceptable i

1. Visual I

j Welding l

4 1

95.5%

(1)

(1) i 1:

ll l

(Subjective)

I 3

i 1

~

l

2. Mechanical l

l i

I l

4 l

99.4%

l (1) l (1)

I l

l 1

((bjective) l l

l NOTE:

• Results Cununulative. 73 Rejects Were Rej,nspected.

i a

(1) Not required l

i i

i l

751N l

l 1

(

(.

' Table A.3 - HJnter I.

Results By Inspection Type Reinspection Results (Acceptable) ll Level 11 1 Independent Third l Level III Type Reinspection Party Review

• Reinspection 1

\\

Subjective 94.3%

96.7%

1 (1)

(3452/3662)

(3544/3662) l Objective 99.0%

(1) l (1)

II. Results By Inspection Attribute l

Initial Sample Period l

Expansion Sample Period i

l l

l l

No. Of l

l No. Of l

l People l

Final %

l People l

Final X Attribute ll Reinspected Acceptable Ruinspected Acceptable

1. Visual I

I l

Welding l

16 l

96.8%

l (1) l (1)

I l

(Subjective) '

1

2. Documentation!

l l

l l

20 l

98.9%

l (1) l (1) l l

l l

(mjective)

3. Hardware l

l l

l l

17 l

99.2%

l (1) l (1) 1 I

l I

(@jective) l l

l l

NOTE:

• Results Cummulative. 210 Rejsets Were Reinspected.

(1) Not required 7511N

(?,

([ '

l I

Table A.4 - NISCo 1.

Results By Inspection Type Reinspection Results (Acceptable) t l

Level 11 l Independent Third Level III Type l

Reinspection l

Party Review Reinspection I

I I

Subjective 1

100.04 (1) l (1)

Objective 1

99.6%

l (1) l (1) l l

l

11. Results By Inspection Attribute

[

l Initial Sample Period l

Expansion Sample Period l

1 1

I I

i i

Ns. Of I

l No. Of I

i l

People l

Final %

1 People l

Final 4 r

Attribute Reinspected 1 Acceptable Reinspected Acceptable

1. Visual Welding ll 4

h 100.04 (1)

(1) 1 l

l l

(Subjective) l

2. Mechanical I

l I

l l

4 1

99.6%

1 (1) l (1) i i

l i

I (ejective) l l

l l

l (1) 2 t required l

7511N l

~

_=

o s

' t Table A.5 - Hatfield Electric I.

Results By Inspection Type Reinspection Results (Acceptable) r l

Level II I Independent Third I Level III t

Type Reinspection Party Review' l

ReinspectiorF*

l l

l 1

1 1

Subjective 1

88.41 92.7%

l 94.2%

1 (20253/22905)

(21226/22905)

(21576/22905) 1 Objective 96.7%

(1) l (1) l i

II. Results By Inspection Attribute I

Initial Sample Period l

Expansion Sample Period l

l 1

i tb. Of l

No. G.

l People l

Final 4 1

People l

Final %

Attribute Reinspected l Acceptable Reinspected Acceptable i

i I

i

1. Visual Weld ll l

l l

7 94.24 (1)

(1) 1

(

a ll i

2. Conduit

!i

'l I

6 96.9%

l (1) 1; (1) l l

t I

l

3. Terminations l l

l l

l 5

99.9%

l (1)

(T \\

4. Equip.

l l

ll l

Setting l

2 l

100.04 l

(1) 1 (1) 1 l

l l

5. A325 l

l l

l j

Bolting I

1 100.05 l

(1) l (1) l i

6. Equip.

l l

l l

Hodification i 2

l 100.04 l

(1) l (1)

I i

I i

7. Conduit l

l l

l

]

As-built P

95.95 (1)

(1) 4 (1) Pbt required

. =.

(,

(.,

6 II. Results By Ins;;ection Attribute (Cont'd)

[

l Initial Sa gle Period l

Expansion Sagle Period l'

l 1

l l

l No. Of l

l No. Of I

l I

People l

Final %

l People l

Final 5 1

Attribute Reinspected Acceptable Reinspected Acceptable i

I i

8. Pan L

Hangers 2

l 96.9%

l (1) l (1) l l

L

~

l I

9. Pan l

l l

l l

l 1

l 100.04 I

(1) l (1)

I I

l l

NOTE:

• Results Cumulative. 2,652 Rejects Were Reinspected.

NOTE: **ResJ1ts Cumulative.

422 Rejects Were Reinsp2cted.

(1) Not required i

1 i

t 1

7511N I

'l l

d 4

i

j

(

26 -

Table A.6 - Powers-Azco-Pope I.

Results By Inspection Type Reinspection Results (Acceptable)

Level II Independeal; Third Level III Type Reinspection Party Review

• Reinspection 1

i t,

subjective ll 86.0%

l 86.1%

l (1) l (6579/7646) l (6583/7646)

I I

I I

Objective 96.0%

l (1) l

(.1) 1 I

l i

II. Results By Insperction Attribute f

l Initial Sample Period l

Expansion Sample Period l

I No. O f No. Of

(

i People Final 2 People Final X Attribute Reinspected Acceptable Reinspected Acceptable 1

1 i

1. Pipe Material:

1 I.

Verification l 19 l

98.0%

l l

1 l

l l

(1) 1 (1)

(Cbjective) l l

ll 4

1

2. Pipe Weld l

l l

i i

i Visual i

19 l

93.7%

l 4

l 88.7%

I I

I I

l (Subjective)

I i

l

3. MangerMount l l

l Material l

19 l

96.2%

l 2

l 98.8%

l

)

Verification l l

l l

(Cbjective)

4. Hanger Weld I I

l Visual l

19 l

75.0%

1 7

l 83.1%

(Subjective)

I i

l j

5. Final l

l l

l i

Hanger l

10 74.3%

l 1

l 81.8%

i j

((bjective) i (1) Not required 1

1

_, _ _ = -.

f.

(

\\

II. Results By Inspection Attribute i

i l

Initial Sample Period l

Expansion Sartple Period l

I I

I No. Of l

l No. Of l

People l

Final %

l People

'l Final N i

Attribute Reinspected Accept 6ble Reinspected Acceptable

6. Flex l

l l

Hose l

7 l

100.05 l

(1) 1 (1) ll 1,

1 ll (Cbjective) 4

7. Pipe l

l ll Bend l

9 L

95.7%

l (1) ll (1)

I I

l l

i (Cbjective) l l

l

[

i i

NOTE:

'Results Cumulative. 1,067 Rejects Were Reinspected.

l l

(1) Not required l

}

l 1

l I

i l

{

i 4

i l

1 l

l 7511N i

j l

I I

O N

(

_ Table A.7 - Pittsburgh Testina I.

Results By Inspection Type Reinspection Results (Acceptable) l Level II Independent Third Level III Type l

Reinspection Party Review

• Reinspection **

I I

l Subjectivt l

83.44 1

85.4%

l 91.3%

i (4147/4973)

(4249/4973) l (4543/4973)

I I

I Objective 1

99.14 (1) l (1) l (7200/7269) l l

II. Results Ry Inspection Attribute l

Initial Sample Period l

Expar.sion Sample Period l

l l

l l

No. Of I

l No. Of l

l People l

Final X l

People l

Final 4 Attr,1bute Reinspected Acceptable Reinspected Acceptable 1

l

1. Visual i

l l

l Welding l

10 l

91.3%

l (1) l (1) l 1

l l

(Subjective) l l

l i

2. Coveete I

il l

j Expansion l

9 l

99.1%

l (1) l (1)

Anchor l

l l

l (Cbjective) l l

l l

l NOTE:

• Results Cummulative. 826 Rejects Were Reinspected.

NOTE: **Results Cumulative. 301 Rejects Were ReinspJcted, l

(1) Not required l

7511N

(-

(

1

- 29 l

Table A.8 - Peabody

)

I.

Results By In_spection Type _

Reinsouction Results (Acceptable) l Level II Independent ThJrd Level III l

l Type Reinspection Party Review' Reinspection **

1 l

l Subjective 1

71.8%

1 74.85 l

96.95 I

(117/163) 1 (122/163)

(158/163)

I ODjective l

(2) l (1) l (1)

I I

l

)

71. Results By Inspection Attribute l

Initial Sa m le Period l

Expansion Samle Period

[

i l

l l

l l

i No. Of l

l No. Of l

)

l People l

Final 4 l

People

{

Final 2

]

Attribute Reinspected Acceptable Reinspected Acceptabl2 i

l 10 Visual l

l l

Welding l

6 l

96.9%

l (1) l (1)

(Subjective) 4 I

NOTE:

• Results Cummulative. 46 Rejects Were Reinspected.

NOTE: **Results QJmmulative. Al Rejects Were Reinspected.

l i

I

)

(1) Not required I

(2) Pet applicable

+

I i

i 7511N l

1 j

. _ _ _ _ _ = = -

l

(.,

(-

l l

l

.n.

l l

APPENDIX 8 f(IN!PECTION RESULTS BY IN!PECTOR

[

1 I

1 A tabulation of detail inspection results by Inspector and type of inspection is presented on a by contractor basis in Tables 8.1, 8.2, 8.3, E.4, 8.5, 8.6, l

8.7, and 8.8.

I r

Table 8.1 - Blount Stos.,

l r

Detailed Inspector Results Insp.

Attr. #1 Attr. #2 Attr. #3 Attr. #4 l

A 636/640 8

70/70 l

C 4}7/440 D

427/443 E

253/255 49/51 F

75/75 G

335/333 25/26 55/55 H

t Totals 1835/1858 145/145 306/310 74/77 NOTE:

N3 expanded sampling was requhed.

Attribute 1 - Weld Detail Attribute 2 - Concrete Attribute 3 - Masonry Attribute 4 - Concrete Expansion Anchors i

7511N

1..

(-

(

' Table 8.2 - Johnson Controls Detailed Inspector Results Insp.

Attr. #1 Attr. #2 25/28 A

8 222/230 3170/3178 C

(28/660 2761/2781 0

80/84 499/499 E

464/485 1310/1326 i

Totals 1394/1459 7765/7812 i

NOTE:

(

Na expanded sampling was required.

Attribute 1 - Visual Welding Attribute 2 - Mechanical i

i I

(

i i

i 7511N l

i s

I l

i i

I

s

(

o 1

Table 8.3 - Hnter Detailed Inspector Results i

Insp.

Attr. #1 Attr. #2 Attr. #3 A

47/51 8

14/14 134/138 C

33/34 1181/1185 t

i D

33/33 101/102 l

E 283/301 2088/2144 61/64 F

208/214 40/41 258/265 G

116/129 161/161 21/21 H

49/55 19/19 12/12 i

I 315/319 47/47 129/D3 2195/2269 78M/7893 J

K 333/344 260/283 186/190 l

L 273/273 366/M6 204/206 126/D0 331/332 l

M 289/294 903/921 N

415/442 1246/1253 i

0 l

P 249/263 8143/8214 925/935 i

Q 381/392 6303/6363 5366/5390

)

R 232i237 8504/8520 81/81 l

S 181/181

28/331 932/934

[

1789/1804 6251/6323 l

T 1

U 797/822 3651/3725 8024/8060 i

Totals 3544/M62 36160/35578 32768/33020 NOTE:

1 j

No expanded sampling was required.

I Attribute 1 - Visual WeldiN l

J Attribute 2 - Documentation Attribute 3 - Hardware j

i l

l r

i I

)

7511N l

i

e +.

(

. Table B.4 - N!SCO Detailed Inspector Results Inso.

Attr. #1 Attr. #2 A

103/103 930/930 5

69/69 1567/1579 C

32/32 165/165 0

25/25 118/114 TOTALS 229/229 2780/2792 NOTE No expanded svpling was required.

Attribute 1 - Visual Welding Attribute 2 - Mechanical 7511N

3 t

(-

(

l 8

l i

I 5

l 4

t j

- 3A -

l f

Table 8.5 - Hetfield Electric f

Detailed Inspector Results t

j Inso.

Attr. el Attr. #2 Attr. #3 Attr. #4 Attr. #5 Attr. #6 Attr. #7 Attr. #4 Attt. # j l

I 1

A 478/906 f

l 8

47'S/4974 C

690/706 j

p 32/32 770/770 24/24 8/8

]

E 10797/11762 37/38 60/60 2/2 137/137 132/132 r

1/1 G

1177/1218 289/304 562/M4 3985/4112 H

I 4477/4639 1

J 539/561 l

K i

1019/1046 193/198 t,

10952/11457 M

N 3516/M21 0

51/51 i

1 P

2001/2081 l

i o

4818/30M i

l R

11734/12205 I

5 2753/2879 T

1917/2014 8201/8208 24/24 U

V 1696/1752 80/80 !

i Totals 21576/22905 2053/2118 9725/9734 48/48 8/8 3/3 429M/44777 1889/1950 80/80 I

WTE:

(

l No expanded sampling was required.

f Attribute 1 - Visual Weld Attribute 2 - Conduit

(

Attribute 3 - Terminations Attribute 4 - Equipment Setting I

Attribute 5 - A325 Bolting Attribute 6 - Equipment kodification i

Attribute 7 - Con &Jit Asbullt Attribute 8 - Pan Hengers Attribute 9 - Pen i

7511N 1

l d

i 1

r

(.2 i

l l

li cle 8.6 - Powers-Azco-Pope

,0steiled Inspec'.or Results i

f Insp.

Attr. #1 Attr. #I Attr. #3 Attr. de Attr. #5 Attr. #6 Attr. #7 A

23/23 IV11 6/10 5/8 8

54/54 34/35 24/34 11/11 i

C 52/52 108/117 37/48 47/74 C(exp) 33/35 85/93 l

D U1 16/18 193/195 50/52 E

47/48 275/328 111/114 87/127 2/2 1

E(exp) 19/21 IU12 F

152/155 218/272 95/97 M/61 i

F(exp) 60/72 23/29

)

G 67/68 330/351 62/62 39/54 3/3 2/2 H

10/10 24/24 68/68 43/35 j

I 40/41 259/286 240/242 38/72 11/22 1/1 5/5 I(exp) 9/9 3/10 1

J 47/59 163/178 139/142 97/112 1/1 l

K 108/108 99/101 262/262 68/115 7/16 2/2 l

K(exp) 3/5 L

137/139 83/83 213/221 36/40 8/18 5/5 t

M 295/302 536/546 858/946 82/181 16/41 2/2 12/12

(

M(exp) 555/M1 208/246 18/22 t

lI N

23V237 468/484 503/508 172/'218 2/2 O

359/370 379/404 793/823 197/272 2/2 8/10 l

O(exp) 5/7 P

IVil IV12 8/8 4/4 Q

32V321 38V395 710/729 478/591 6/6 8/8 1/1 a(exp)

R AV46 97/102 178/184 80/101 27/35 1/1 L

R(exp) l 3/4 5

176/177 113/113 175/177 90/113 139/154 1/1 8/8 l

t Totals Initial-2493/2543 3986/4255 5385/5599 2138/2852 225/303 25/25 45/47

)

Expanded-173/195 558/565 286/344 18/22

_ NOTE:

l The "exp" designation represents the expansion of an inspectors j

sample period when the acceptable threshold was not met.

Attribute 1 - Pipe Material Verification I

Attribute 2 - P1pe Weld Visual Attribute 3 - Hanger / Mount Material Verification Attribute 4 - Hanger Weld Visual Attribute 5 - Final Hanger Attribute 6 - Flex Hose Attribute 7 - Pipe Bend 1

m

(

{. '

f i

b

-M-l l

Table 8.7 - Pittsburgh Testing Detailed Inspector Results l

Inso.

Attr. #1 Attr. #2 A

1699/1875 B

404/445 t

c 64/68 D

18/18 E

522/524 l

T 357/389 i

G 12/12 1

H 7/7 I

596/657 l

J 1277/1389 t

K 299/300 l

L 377/381 M

1057/1058 i

N 864/874 0

2216/2261 P

934/935 i

Q 883/890 R

46/46 S

109/113 l

Totals 7200/7269 4543/4973

[

NOTE l

No expanded sampling was required.

j Attribute 1 - Concrete Expanston Anchors i

Attribute 2 - Visuel Welding i

7511N l

0

(

37 -

1 I

I Table 8.8 - Peabody I

i Detailed Inspector Results

}

Insp.

Attr. #1 j

l A

26/26 8

14/14 C

19/24 i

I D

16/16 E

41/41

_L 42/42 l

t TOTALS 158/163 l

l NOTE:

I 10% of work was reinspected for Inspector C.

f I

Attribute 1 - Visual Welding i

i I

i 7511N i

i i

[

l l

p g

4.

I l

i l

i 33 5

' APPENDIX C

])

SUBXCTIVE IN!PECTION DISCREPANCIES EVALUATION _OF $1CNIFICATE i

The reinspection activity identified s'atistically 3,010 discrepancies associated with visual weld inspection.

The quantities by contractor are as l

follows:

1 L

B%nt WA JoM son Cont 1ols 65 l

Hunter 118 NISCo O

j Hatfield Electric 1,329 i

j Powers-Azco-Pope 1,063 i

Pittsourgh Testing 430 i

Peabody Testing 5

j W

I J

As idutified below, for the engineering evaluation the weld discrepancies jl uere categorir.ed ast J

f i

Categ0ry A Arc Strike i

Convexity

[

f Spatter t

l 4

Category B Crater Incorplete Fusion f

CNerlap Porosity 4

J thdercut j

thoerrun l

t Category C Cracks j

i f

Of the 3,010 discrepancies,10 to 20 rercent would fall into Category A,

~

60 to 90 percent would fall into Category a, and 0 percent would fall into Category C.

i l

1 1

i

]

7511N i

l i

p

. Disposition Of Discrepancies All discrepancies identified as a part of the reinspection are being corrected either by physical remork to correct the condition or by detailing condition on nonconformance reports to perform engineering analysis to determine acceptability of the condition without correction.

The determina-tion as to the course of action employed to disposition the condition is a f unction of the estimate of tha more cost effective path to resolution.

That is, when it appears that the cost to physically Correct condition is less than the cot.ts associated with detailing data and performing an engineering analysis, then physical correction is chosen, and vice versa.

Evaluation Of Sionificance In addition to the action taken to correct the individJal discrepancies, a statistical sampling is being prepared and an engineering analysis is baing performed on the statistically selected discrepancies to establish their significance.

The types of discreparies luentified are similar or identical i

to conditions which have previously been addressed in the history of the i

project and found acceptable.

This data ace n lation, development, and evaluation is approxirr.ately fifty percent complete.

The results of this population is presented below.

The balance will be included in the final report.

7511N 4

(

(

. EN0DEERING EVALUATION OF VISIAL ELD INSPECTION DISCREPAM'lES The purpose of the engineering evaluation was to determine the design impact of weld discrepancies discovered as part of the reinspection of QC inspector work. A total of 100 welds were included in the programi 50 welds tere from the corbined scope of Pittsburf1 Testing Laboratory and Peabody, rnd 50 welds were from it,tfield Electric Certpany's scope of work.

In order to 4

insure a conservative engineering evaluation, the 100 welds chosen for the evaluation were those welds which the independent third party inspectors identified as the melds with the most wield quality discrepancies.

The intent of this evaluation was to determine what factor of safety in weld design

' mists for the 100 rnost discrepant welds.

It was demonstrated that all these welds have large factors of safety with the reserve capacity to transfer the design loads in accordance with the original design criteria conmittt:d to in the FEAR.

The project work specification requires visual weld inspection in accordance with AWS D1.1 Structural helding Code.

To perform the engineering evaluation of the 100 worst welds, all discrepancies which did not meet the AWS weld quhlity acceptance criteria for visual inspection, were indicated by tho inspectors on weld maps.

A weld map is a detailed sketch of the as-built weld, showing size and location of all weld discrepancies.

The weld mnps were separated into one of three categorier., based on the type of discrepancy reported.

Welu discrepancies that were considered struc-turally acceptable because they did not reduce the lead carrying capacities were placed in Category A.

The AWS weld quality criteria consicered in Category A consist of are strikes, convexity, and spatter.

Arc strikes and i

l spatter are costretic discrepancies and only have irrpact on weld i.trength when j

they appear in an entreme case.

If the extrerte case appeared, it would have been reported on the weld map and the weld discrepancy would have been re-categorized. In this evaluation, there were no discrepancies reported associated with are strikes or spatter. Convexity is only considered a potentia' problem in fatigue design of welds. Fatigue is not an applicable loading condition in the design or strtrtures/ supports where AWS welding is specified.

If the reported weld disetepancy resulted in a reduction to the size, length, or capaelty of a weld, it was placed in Category B.

This category included all weld quality discrepancies which caused portions of a mt:ld to be cor.Mdered ineffective.

The AnS weld quality discrepancies considered in Category 0 includes craters, incocplete fusion,luate welds =lth Category B averlap porosity, undercut, and moerrun. The design procedure used to eva discrepancies was to consider these portions of the meld to be totally ineffective and then calculate the section properties of the remaining ace:ptable weld. This is a conservative approach because discrepancies only reduce the capacity of that pertion of the meld where discrepancies are located, but there is always sve reserve capacity even with the presence of the weld quality discrrpancy.

{

{

, APPENDIX D OEDECTIVE INSPECTION DISCREPANCIES EVALUATION OF SIGNIFICANCE The reinspection activity identified statistically 3,138 discrepancies associated with objective type inspections. The quantities by coni.ractor are as follows:

Blount 28 M nson Controls 47 Hunter 670 NISCo 12 Hatfield Electric 1,957 Powers-Azco-Pope 355 P1ttsburgh Testing 69 Peabody Testing 0

3,138 Disposition Of Discrepancies All discrepancies identified as a part of reinspection are being corrected either by physical rework to correct the condition or by detailing the condition on nonconformance reports to perform engineering analysis to determine acceptability of the condition without correction.

The determina-tion as to the course of action employed to disposition the condition is a function of the estimate of the more cost effective path to v! solution.

That is, when It appears that the cost to physically correct the condition is less than the costs associated with detailing data and performing an engineering analysis, then physical correction is chosen, and vice versa.

Evaluation Of Significance In addition to the action taken to correct the individual discrepancies, a statistical sampling is being prepared and an engineering analysis is being performed cn the statistically selected discrepancies to establish their significance.

The types of discrepancies identified are similar or identical to conditior" which have previously been addressed in the history of the project and found acceptable. The results of this evaluation will be provided in the final report.

i 7511N

.