ML20214B288

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Intervenor Exhibit I-ROREM-181,consisting of Pages from QA Overview,
ML20214B288
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 10/23/1986
From:
AFFILIATION NOT ASSIGNED
To:
References
OL-I-ROREM-181, NUDOCS 8705200216
Download: ML20214B288 (10)


Text

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% QUAL 1TY ASSURANQ5 QVERVIKV

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Braidwood Site Quality Assurance has been directly involved with the QCIRP since its inception. This involvement included the review and concurrence of all QCIRP related procedures / work instructions and program activities. A member of the SITE Q.A. Staff has been assigned as a primary contact point for the Ceco Task Force (CTF) of the QCIRP since the program was developed, and this established a daily interface with the day-to-day activities involved with this program, as defined in Project Procedure PM-11".

This Q.A. CTF contact had the responsibility for the review and concurrence of.

j all QCIRP related documents processed through the Site Quality Assurance organization.

In addition to the day-to-day involvement with the CTF, the QCIRP was also addressed by audits and surveillances by other Q.A. Personnel to assure effective implementation of the overall program.

Audit 20-85-515 (9/09-13/85) and Audit 20-85-587 (11/18-22/85) verified implementation of the QCIRP by review of all site contractors included in the QCIRP and the activities of the Ceco Task Force, to assure all applicable procedures were being acceptably implemented. Both of these audits noted that the QCIRP was being ir.plemented according to the approved procedures with only minor concerns, which were addressed during the audits, and no deficiencies were noted on either audit.

i Surveillance of the QCIRP has included eight surveillances that covered various activities of each specific contractor included in the QCIRP.- The surveillance coverage was conducted by contractor, as follows:

LKC Surveillances 4432 and 4730 PGCO Surveillances 4902, 5056, 5525, 5659, and 5758 PTL Surveillance 5046 The Poco surveillances include two that were conducted to assure that PGCo QCIRP HCR's processed through Site Q.A. included all valid discrepancies for each inspector included in the QCIKP. As Site 9.A. receives QCIRP NCR's for LKC and PTL, further coverage of these contractors will also include the Site Q.A. verification to assure that all valid discrepancies have been addressed. As such, Site Q.A. coverage of QCIRP continues and will include the review and concurrence of the final QCIRP results.

Site Q A. surveillance 85700 verified the acceptable Sargent & Lundy implementation of Project Instruction FI-58-97 which controls S&L activities for the QCIRP.

VI.

CC9CLUSICN The QCIRP provides an additional basis for Commonwealth Edison's confidence in the contractor programs for the certificarices of gc inspecto : prior to the Fall of 1982. These certification programs have been preven effective in that no design significant discrepancies were identified.

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e TABLE IV.E--PTL SUBJECTIVE 2EINSPECT10N RESULTS--Pase 22 of 23 Acceptable Unac c ept abl e' Total Inspector Elemento Current Enalacering

!)esign Code No Reinspected kequirements Evaluation Significant

- - - - - - - - INSPECTORS IN SAMPLING PROGd*.M - - - - -

P01 7h 67 3

0 P02 261 244 17 0

PO4 55 55 0

0 P06 60 39 21 0

P07 2176 1936 240 0

P09 54 48 6

0 Pio 50 39 31 0

Fil.

409 396 13 0

INSPECTORS 100% REINSPECTED - - - - - - - - -

PC3 177 113 64 0

P13 12 9

3 0

P14 3

3 0

0 P15 4

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12 3336 2951 (88%)

305 (12%)

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Inspectors 1

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July 8, 1986 Page 16 of 23 Egg.: There were 21 discrepant welds for inspector P06 out of a total of 60 i

reinspected welds.

Three welds displayed undercut which resulted in less than a 2% loss of section.

The remaining 18 discrepancies were all identified to be weld size.

Twelve of the discrepancies resulted in insignificant reductions in capacity and the remaining capacity was twice that required for the other nine discrepancies.

292:

Inspector P07 had 240 discrepancies on 21'16 welds. Most of the discrepancies involved weld size, length or lack of fusion.

Generally the lack of fusion is only for a pcrtion of the weld. Most of the discrepant welds were undersized by only 1/16 inch or less, and maintained at least 80% of their specified length. There were 201 welds which had insignificant capacity redactions and none of the defects were design significant.

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Inspector P09 was reinspected for 54 welds, with six welds noted as discrepant. Three of the welds had insignificant reductions and three occurred on two double angle connections used to attach the vertical posts of metal enclosures to floor embeds. Due to tha design redundancies at these connections, the discrepent condition can be acconsmodated with the remaining design margin more than twice that required.

P10:

Inspector P10 had 11 discrepancies on 50 welds with nine cf those discrepancies resulting in insignificant capacity reductions.

hone of the discrepancies were design significant.

IV.E.3 Sussnarv No design significant discrepancies were found in any of 3336 reinspected elements.

Three inspectors were 100% reinspected and 6 of the 9 inspectors in the sa:npling program had less than a 90% conformance rate.

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July 8, 1936 paga 15 of 23 twenty-three of the~ discrepancies were due to welds not installed per the specified detail. These consisted of eleven relocated welds due to plate width and angle length changes, eight fillet welds installed as penetration welds, three stitch weld spacing discrepancies and one weld missing from a group of four specified. Most of these discrepancies resulted in insignificant capacity reductions and adequate design margins were maintained in all cases.

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The remaining twenty-three miscellaneous discrepancies included twenty minor base metal reductions, two fillet weld shim plate burn-throughs and one slag inclusion. All of these miscellaneous discrepancies resulted in insignificant capacity reductions.

e IV.E.2.

RESUL,TS BY INSPECTOR All twelve PTL. inspectors with recreatable subjective inspections were included in the QCIR Program and Table IV.E lists the results for each inspector.

Three inspectors were 100% reinspected because their number of.recreatable inspections was less than the minimum 50 required for reinspection on a sampling basis.

l cne of the nine inspectors who were reinspected using the QCIA sampling methodology had no discrepancies and six (P03, P06, P09, P01, P07, P10) were below the 90% conformance rate threshold.

P01: Inspector P01 performed 75 of the inspections reinspected in the QCIR Program. Only eight discrepancies were identified, with four of the discrepant welds located on one connection. These included two welds which were 1/4" shorter than the design length and two welds which were installed as penetration welds instead of the specified fillet welds. These discrepancies were determined to be not design significant. The other four discrepanci,es were insignificant.

Eq).: A total of 177 welds were reinspected for P03, with 64 found to be discrepant. Approximately 80% of the discrepancies resulted in insignificant capacity reductions. Nearly all discrepancies involved weld size or length deficiencies. Most of the welds were undersized by only 1/16 inch or less, and many weld lengths were not less than,

90% of their specified length. Further, the connections displayed redundant and/or nitigating welds which compensated for the Icss of weldsent on the discrepant element. The entire recreatabis inspection work scope for inspector p03 was reinspected, and none were design significant.

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July 8, 1986 Page 14 of 23

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PITTSBURGH TESTING LAB. SUBJECTIVE REINSPECT 1Ctl RESULTS IV.E.1.

RESULTS BY CATECORY A total of 2761 inspection reports with 3336 elements wera reinspected in this portion of the QCIM Program.

The overall centractor conformance rate was 88% which is only 2% below the 90% conformance threshold established for QCIRP. None of the discrepant conditions are design significant.

of the 3336 elements reinspected, only 385 were identified as discrepant.

These discrepancies are categcrized and discussed below:

Percentage of Total Reinspected Subiective Discrepancy TYDe Ouantity Elernent s Weld Size 218 6.5%

Weld Length 79 2.4%

Lack of Pusion 42 1.3%

i Weld Location 11 0.3%

Weld Type 8

0.2%

Weld spacing 3

0.1%

Missing Weld 1

0.0%

Hiscellaneous 23 0.7%

385 11.5%

The majority of the discrepancies were due to undersize and/or underlength welds.

In many cases, only portions of the welds were undersized.

More than 75% of these discrepancies resulted in insiginificant capacity reductions and adequate design margins were maintained in all cases.

Portiens of lack of fusion was the primary discrepancy on 42 welds.

More than 85% of these discropancies resulted in insignificant capacity reductions and the remaining discrepant ccnnecticns retained a capacity twice that required.

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.e Pega 1 of 23 I.

SYNCPSIS The Quality Control Inspector Reinspection Program (QCIRP) was initiated by Commonwealth Edison to reconfirm the effectiveness of the contractor programs for the certification and qualification of Quality Control (QC) inspectors prior to the Fall of 1982.

Section II Provides background information with respect to the development of the QCIRP.

Section III Describes the QCIRP Secticn IV Provides the results of the QCIRP.

Section V Indicates the Ccemonwealth Edison Quality Assurance coverage that occurred throughout the duration of the QCIRP.

Section VI Provides a stsumary of the QCIRP and the conclusions reached free the results of the QCIRP.

II.

BACKGROUND Commonwealth Edison NCR 688 was initiated in December of 1984 in order to track Braidwood site concerns on the certification of QC inspectors.

To address the period from the start of the project to the Fall of 1982, a program entitled "The Quality control Inspector Reinspection Program" (QCIRP) was developed. The Fall of 1982 was used as a cut-off because of the upgrade of site contractor certification programs in resgense to ccanittaents agreed upon during that time period at the syron Station.

on May 15, 1985, Supplement I was added to NCI 688 to provide specific guidelines for the implementation of the QCIRP, Attachment A of Supplement 1 lists the Braidwood contractors that performed on-site work during this time frame and indicates why each contractor was included or excluded from the QCIRP. Based on Attachment A, three contractors were included in the program:

Phillips-Cetschow Co. (PGCo)

Mechanical L. K. Comstock (LXC)

Electrical Pittsburgh Testing Laboratories (PIL)

Independent Testing and Inspection Agency AR003237003237

July 8, 1986 Pego 2 of 23 e

For each of these three contractors, the areas of certifications were reviewed to determine their applicability to the program. Attachment B of supplement 1 lists, by contractor, the inspection areas and inspection attributes included in the QCIRP. Attachment C of Supplement 1 lists, by contractor, the inspection areas excluded from the QCIRP.

III,.

PROGRAM DESCRIPTTcti l

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(* N alth Edison procedure PM-11, Quality Control Inspector Reinspection.

was developed to provide guidelines for the QCIRP. PGCo, 1.KC and PTI. then developed work instructions to govern the day-to-day 1:aplementation of the l

program with respect to their companies.

L To determine the number of inspectors and inspections that ve. e included in l

the program, a listing was generated of inspectors certifi-in the areas of certification to be reinspected.

Inspection records from the start of the project unti1~the applicable QCIRP cut-off dates were reviewed to define the number of. original inspections performed by these inspectors. The inspection reports were then grouped into two categories, 1) Subjective (Type A) or welding inspections and 2) objective (Type 3) or non-welding inspections.

Inspection Reports were randomly selected from each inspector's first 90

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days of work and then reinspected by inspectors from the same contractors.

t The inspectors who performed the reinspections were required to be currently l

certified in the inspection area and could not reinspect their own work.

Some of the original inspections were determined to be not recreatable.

For the purposes of the QCIRP, "not recreatable" means items that are i

inaccessible (require extensive dismantling), nonrepeatable, removed, reworked and/or reinspected.

I An expansion of the initial sample was required if any of the discrepancies were determined to be design significant.

No design significant j

discrepancies were found and therefore no sample expansion was required.

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Table III-1 indicates the quantity of inspectors included in the program for each contractor. The Total Inspectors soployed column indicates the number of inspectors employed in each of the contractor's QC depat taents throughout the GCIRP time frame. The Total Eligible Inspectors coltart represents the l

number of inspectors who held at least one certification in the areas i

determined to be reinspectable as indicated in Attachment B.

The Number of i

Inspectors Reinspected column provides the number of inspectors who, after f

determining which items were recreatable, actually had reinspections performed on their original inspections.

The Percent of Eligible Inspectors l

Reinspected column ccupares the number of inspectors actually reinspected to the number of eligible inspectors.

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TABLE III-l CONTRACTOR OC INSPECTOR DISTRIBUTIC+i Percent Total Total No. of of Eligible Inspectors Eligible Inspectors Inspectors CCNTRACTOR Employ?d InsDectors ReinsDeCted ReinsDected UC ming ums r ecer Immun PcCo i

PTL 102 26 12 46%

TOTAL M

i Table III-2 lists the quantities of Inspection Reports determined to be within the scope of the QCIJtP from which the reinspection sample was selected. The table subdivides the total number of Inspection Reports into the two established categories, subjective and objective.

I TABLE III-2 ELIGIBLE INSPECTOR CUANTITY OF INSPECTION REPORTS CONTRACT 0M SUBJECTIVE osJECTIVY g

M M

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my PTL 6052 0*

6052 TOTAL M

g All PTL Objective inspections are not recreatable because they were either in-process or overview inspections.

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July 8, 1986 Paga 4 of 23 A significant percentage of the Inspection Reports that were included in the QCIRP were reinspected. Table III-3 lists the percentages for each contractor and category of reinspection.

TABLE III-3 PERCENT OF INSPECTION REPCRTS REINSPEC*TD CONTRACTOR SU8JECTIVE CBJECTIVE TCfrAL LxC g

g M

PGCo 3

g PTL 46%

46 TOTAL M

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July 8, 1986 Pago $ of 23 IV gIgggEPANCY EVALUATIcWS AND RESULTS i

Discrepancy reports prepared by the QCIRP reinspectors were reviewed using the current visual weld acceptance criteria (NCIG-WAC) and the latest design drawings. Over 45% of the conditions initially reported 4

as rejectable were determined to be nondiscrepent during this review.

For example, over 90% of the minor weld undercut conditions reported by PTL are acceptable per MCIG-WAC.

Discrepancy reports were also reviewed to determine if the conditions reported were due to post-inspection construction activity in the vicinity of completed components.

For example, conditions such as aissing nuts and misaligned clamps are expected during construction and are being corrected during the POCP-48 formal walkdown procedure.

These items were retained as discrepancies for determining the inspector j

conformance rates but are not significant.

The remaining discrepent conditions were subjected to an engineering evaluation to determine the extent to which the discrepancy affected an 3

i item's ability to perform its safety-related design function.

Evaluations were performed by comparing the discrepancies with design parameters, tolerances and design margins using either documented engineering judgement or calculations. The majority of the

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discrepancies required only simple evaluations to establish that the discrepancy had an insignificant effect on the item's capacity. Other i

discrepancies required more detailed evaluations to confirm that they i

did not impair the item's ability to perform its safety related design function.

Mone of the QCIAP discrepancies were determined to be design significant.

Code design margins were maintained and code design criteria and equipment functional requirements were met.

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The discrepancies for each inspector in the sampling program with a conformance rate below the 90% subjective and 95% objective QClaP i

thresholds were subjected to an additional level of review. This review considered the nature of the discrepancy, the frequency of occurrence and the reductions in capacity in relation to the inherent design margins that exist for similar components.

It was judged that the likelihood of design significant discrepancies existing in the i

l unreinspected portion of these inspectors work was negligible.

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The following five sectices discuss in detail the contractor and individual inspector results.

The results are presented in terms of

'1N rection elements". An " inspection element" is a single line item on the objective inspection checklist or a single weld en the subjective inspection checklist.

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