View source for U-600163, Forwards Corrections to Overinsp Program at Facility,Per 850422 Meeting Re Util Request to Remove safety-related Piping & Mechanical Supports from Program.Technical Assessment Outlined

{{Adams
| number = ML20127A873
| issue date = 06/14/1985
| title = Forwards Corrections to Overinsp Program at Facility,Per 850422 Meeting Re Util Request to Remove safety-related Piping & Mechanical Supports from Program.Technical Assessment Outlined
| author name = Hall D
| author affiliation = ILLINOIS POWER CO.
| addressee name = Keppler J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION III)
| docket = 05000461
| license number = 
| contact person = 
| document report number = U-600163, NUDOCS 8506210281
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 55
}}

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  /                                               U-600163
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ILLINOIS POWER COMPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 June 14, 1985 tWITY FM Wibul$2,
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Docket No. 50-461                                       87. p w' .mF ic  i i_
Mr. James G. Keppler                                                       C IRC' M   '
Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

==SUBJECT:==
Illinois Power (IP) Company Overinspection Program Results Data

==REFERENCES:==
: 1)   Let ter, D. P. Hall to J. G. Keppler, Proposed Changes in the Illinois Power (IP) Company Overinspection Program, File No. U-0828 of March 29, 1985.
: 2)   Let ter, D. P. Hall to J. G. Keppler, Response to NRC Questions Concerning Illinois Power Request for Concurrence to Remove Safety Related Piping and Mechanical Supports from the Overinspection Program, File No. U-600008 of April 19, 1985.
: 3)   Meeting between the USNRC and IP on April 22, 1985, in the Office of the USNRC, Region III in Glen Ellyn, Illinois.

==Dear Mr. Keppler:==

By Reference 1, Illinois Power Company (IP) forwarded a request for concurrence to remove safety related piping and mechanical supports from the overinspection program at Clinton.
Reference 2 responds to specific NRC questions regarding the IP request to change the Overinspection Program. During a meeting on April 22 (Reference 3), further questions were raised concern-ing data contained in Enclosure 1 to Reference 2. IP has reviewed the data and supporting calculations. An independent technical assessment and quality review of the process which produced the data is complete, and the following information is submitted:
Duplication of information -
A clerical error resulted in the same information being presented for different buildings. Other minor cler-ical errors were also identified and corrected.
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            *-   Nonconformances where no inspections were performed --
10n items that cross elevation or building boundaries, a single-location is assigned to the item. If nonconfor-mances are found on that. item in a different elevation or. building, it will appear as though a nonconformance was found even though no inspection was performed.
While this may cause some confusion, no~ distortion of the~1nspection or nonconformance data is caused.
Fewer inspections performed through December 1984 than through July _1984 in some buildings / elevations -
Complete removal of non-safety related items from the HIP data has in some cases reduced the. inspection data.
As noted in the April 22 meeting, only data related to safety-related items were used.
10P has required S&L to perform an extensive re-review of the S&L evaluations of.the results of the Overinspection Program for piping and mechanical supports. This re-review produced the following changes in data:
                 -     The number'of nonconforming items was reduced by 37 (2%).
                 -     The severity level (A, B1, B2) of some nonconform-ing conditions changed._ Overall,.the number of B2 nonconformances was reduced and the A and B1 categories increased.
                 -     Old work versus new work designations for noncon-forming conditions were refined. No significant data revision resulted.
The number of nonconforming attributes was re-reviewed resulting in a total reduction of 124; 48 in piping and'76 in mechanical ~ supports. Con-  l sidering the number of~ attributes inspected (over 120,000 for piping and over 425,000~for mechanical supports), the effects of the data changes are negligible.
No_ changes have been identified in the data that would alter IP's conclusions regarding the quality of piping or mechanical supports or the confidence factors established for these conclus-
     . ions. Each iteration of data has resulted in a reduction, however slight, in number of nonconforming conditions and, therefore, an improvement in program results.
While IP does not underestimat e the importance of providing error-free data, in every case the significance of questions concerning the nonconforming conditions in the area of 4

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  -overinspection of piping and mechanical supports is diminishing.
While additional methods of analysis, presentation of the data, and correction of accounting errors similar to those addressed above may always be possible, none can reasonably be expected to affect the conclusion that all the analyses have reached -- the quality of Clinton Power Station construction for piping and mechanical supports is acceptable.
IP believes that, with the corrections forwarded in Attach-ment 1, the base of information before the NRC is sufficient for a decision to approve the request to remove piping and mechanical supports from the Clinton Overinspection Program at the earliest possible time.
Sincerel   yours,
                                       . P. a1 Vice President JEK/j sp Attachment cc:   Director, ' Office of I&E, USNRC, Washington, D.C. 20555 B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Illinois Department of Nuclear Safety Allen Samelson, Assistant Attorney General, State of Illinois

Attachment 1 to U-600163 Dated June 14, 1985 This attachment consists of two enclosures. Enclosure 1 completely updates Enclosure 1 of the Reference.2 letter, except that it deletes all data as of July 31, 1984, since the December 1984-data is all inclusive. The pages are numbered identically to the original Enclosure 1 (certain pages have been deleted as they relate to the July 1984-data).
Enclosure 2 is an update to a handout that was provided at the Reference 3 meeting.

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* ENCLOSURE 1 ILLINOIS POWER RESPONSE TO NRC QUESTIONS AND COMMENTS REGARDING IP'S REQUEST TO REMOVE SAFETY RELATED PIPING AND MECHANICAL SUP. PORTS FROM THE OVERINSPECTION PROGRAM This enclosure responds to the NRC questions and comments regarding Illinois Power (IP) letter U-0828, D. P, Hall to J. G. Keppler dated March 29, 1985 and the IP Report,                                                                                                                          -
Results- of Quality Programs for Construction of Clinton                                                                                                        -
Power Station, Chapter V and Appendix D. The NRC comments and questions are quoted directly from Enclosure 2 of the NRC letter from J. G. Keppler to IP, attention W. C.
Gerstner, dated April 11, 1985 and are followed by the IP responses. Where two or more questions are related to a single topic, these are grouped together and a single IP response is provided.
       .                              NRC COMMENT A.1:                                     One of the objectives of the Overin-spection (OI) Program is to prove that the structures, systems, and components (SSCs) at the Clinton Power Station
('
(CPS) are properly installed in order to assure safety of operation. The data presented in references 2 and 3 concerning piping and mechanical supports are defined in terms of attributes which are sub-elements of plant SSCs.
Plant SSCs are composed of varying quantities of these attributes, depending upon commodity and degree of complex-icy.                 In addition, some of these attributes do not neces-sarily act independently in achieving the safety function of the SSCs to which they apply (i.e., some attributes of a pipe support, would have a greater impact on the integrity of that support when taken together than when considered separately).
I NRC QUESTION A.1: Provide OI program results for piping and mechanical supports (including confidence factors) in terms of plant SSCs rather thhn SSC sub-elements.
IP RESPONSE TO QUESTION A.1: The table below provides the requested data. Confidence factors are presented as                                                                                                                -
reliabilities at the 95% confidence level, based on the evaluation results which demonstrate no safety significant nonconformances, using the following formula.
R = 1 - 2.9955 n
where:
R = Reliability at 95% confidence level
   ,                                                             assuming an infinitely sized lot i                                              n = number of items inspected
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4 RESULTS OF OI PROGRAM IN TERMS OF COMPONENTS (SSC's)
(MITH CONFIDENCE FACTORS)
Data as of December 31, 1984 Ite ms       Safety     Reliability      Items   Items    Safety      Reliability Total     Inspected    with 4    Significant Based on 95%    Inspec5ed  with   Significant Based on 95%
Commodity               Plant      by FF      NCR's          NCR's     Confidence     by OI    NCR's 4    NCR's      Confidence
{.LargeBorePipe l
7,679      5,516        .275           0          > 99%        1,050     23          0         > 99%
Small Bore Pipe l
17,189      3,30 5        231           0          > 99%       2,448      19          0         > 99%
M2chanical Hangers 2   13,255      8,10 4     1,469            0          > 99%        2,455    289          0          > 99%
NOTESg Piping is in Number of Pipe Spools 2    Mechanical Supports are in Number of Units 3    Since the length of pipe spools varies widely throughout the plant, the number of pipe spools in.
this table was calculated by dividing the number of linear feet of large and small bore piping by the linear total number of pipe spools and obtaining an average spool piece length of 7.3 feet for p                  large bore pipe and 3.8 feet for small bore pipe. The number of spool pieces inspected by FV and OI s                  was then caiculated by dividing the number of linear feet inspected by this average spool piece length, p             '
This' column contains the number of items (pipe spools or mechanical support) which contained one or more nonconforming attributes.                            ,
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NRC COMMENT A~.2:   Reference 2, attachment 2, provides IP's-response to open-item 461/84-37-01. .That response is data in.termsoof percent complete and number of attributes inspected for safety related piping 'and mechanical sup-ports.
NRC QUESTION A.2:    Provide more' detailed information concerning piping and mechanical supports'which forms the basis for the data provided (e.g., total linear feet of safety related large bore piping and the number of feet actually; inspected total number of safety related pipe supports.and the number actually inspected, etc.).
IP RESPONSE TO NRC QUESTION A.2:       The information requested is provided in the table below.
DATA AS OF DECEMBER 31, 1984 Items       Reliability Total          Inspected      Based on 95%
Commodity                  Plant            . by FV       Confidence Large Bore Pipe
* 56,055             40,267         99%
Small' Bore Pipe
* 65,320             12,559         99%
Mechanical Supports **     13,255               8,104        99%
* Piping is in Linear Feet
       ** Mechanical Supports are in number of Units NRC COMMENT A.3: The data presented in references 2 and 3 related to piping and mechanical supports are presented quantitatively with only-limited qualitative information.
This presentation does not provide a meaningful basis for June 13, 1985

an independent reviewer to judge the actual' significance of OI findings.
4 NRC QUESTION A.3: Provide additional qu'alitative data related to piping and mechanical supports which was the basis for statements contained in referepces 2 and 3 -
                                                                 - regarding the significance of OI findings'(e.g., refer to                                             ;
.                                                                   the Byron report provided to IP at the meeting'in Region
:                                                                  III last October 25 Exhibit C-2, page 8 of 15, Table CE-9). The response should consider all applicable attri-butes 1nspected.
NRC COMMENT B.3: Because of the dependent nature of i                                                                  certain sub-elements (attributes) of plant SSCs, the actual confidence achieved in terms of the ability of an individu-al SSC to perform its intended safety function has not been clearly established. For example, a pipe support may be composed of a concrete foundation, a base plate, anchor bolts, r.uts, several structural shapes arranged in a f
defined geometry, interconnecting welds, connecting rods, U b.olts, clamps, etc.. These individual parts of the support i
have attributes defined by IPOI. IP has demonstrated a high degree of confidence in the conformance of these individual attributes. However, the support must act as                             a unit in order to perform its safety function.
(                                                             NRC QUESTION B.3-                        Can IP demonstrate a high degree of confidence in pi ing and mechanical supports when the i                                                                  individual attri utes are arranged as a unit (or item),
considering the dependency of certain attributes, using the
[                                                                  data obtained to date under the OI program? Provide the i                                                                  detailed analytical results.
l                                                                  NRC QUESTION B.4: Considering the response to item (B.31 above, is the conformance criterion sufficient when applied                                           ,
to piping and mechanical supports without restriction?
IP RESPONSE TO NRC QUESTION A.3, B.3 and B.4:                             The objec-tive of the_ engineering evaluations performed on the
,                                                                  nonconformances was to deterqine the potential significance to plant safety had the nonconforming condition (s) been undetected.by the Overinspection Program. These engineer-ing evaluations demonstrated that ths identified nonconfor-mances would not have impaired the ability of the safety related large and small bore pip ng and mechanical supports -
to perform their safety related esign function. The design margins of each iping s stem or mechanical support, considering the reporte noncon ormances, were determined to be within the specified design limits.
The engineering evaluations considered the potential effect that all identified nonconforming attributes may have had
(,                                                         ' on the piping system or mechanical supports. This eval-uation addressed both singular and cumulative effects
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(attributes which may not act independently), as appropri-ate.for the nature of the reported nonconforming attributes and the affected components. For example, if two or more nonconforming attributes affected a load bearing weld, the net effect of all nonconforming attributes in reducing the
           ,                   weld capacity was considered.
The results of the engineering evaluations on a component basis have been divided into the four categories described below, and are summarized in the table following the description of the four categories. These categories have been developed in order to quantify the significance of the -
nonconformances with respect to the design or design margins.
Category A     The nonconforming attribute (s) reported on the piping components or mechanical supports are acceptable because they do not affect the struc-tural integrity or functional capability of the component. These items are not significant with respect to the plant design and, therefore, have no effect on the plant safety.
Category B     The nonconforming attribute (s) reported on the piping components or mechanical supports resulted in an acceptable reduction in the functional
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capability or structural integrity of the compo-nent. The components so affected have been divided into Categories B1 and B2 to quantify the signifi-o                        cance of the nonconforming attribute (s) as follows:
Category B1    The reported nonconforming attribute (s) resulted in a potential reduction in weld capacity or component design margin of less than 10%.
Category B2    The reported nonconforming attribute (s) resulted in a potential reduction in the weld capacity or component design margin equal to or greater than 10%.
Category C     The onconforming attribute (s) resulted in a reduction in functional capability or structural integrity beyond that allowed by the plant design basis. There are no piping or mechanical support     -
systems or components in this category.
( -

Y a                                                                                                     SIGNIFICANCE OF IDENTIFIED NONCONFORMING CONDITIONS EXPRESSED IN TEKMS OF CAPACITY OR DESIGN MARGIN REDUCTION:
                                                                                                                                                          .a 1                                                                                                           Data as of December 31, 1984-i' Category A    Category 31   Category B2 Category C        Total
: c.         Commodity.                                                                                   ~(No-Impact)    (<10%)        (210%)
    ~
Large Bore' Pipe Spools                                                                         73'(24%)    198 (66%)     27 (10%).      0 (0%)      298 (100%)
With Nonconforming Conditions.
Small- Bore Pipe Spools                                                                         91 (36%)    144 (58%)     15 (6%)        0 (0%)      250 (100%)
With Nonconforming Conditions Mechanical Supports                                                                            245-(14%)-  1207 (69%)    306.(17%)       0 (0%)     1758-(100%)
1
            . With Nonconforming Conditions                                                                                                                              _
            -TOTAL                                                                                          409 (18%)   1549 (67%)    348 (15%)       0 (0%)     2306 (100%)
^
CATEGORY A NONCONFORMANCES Nonconformances that were classified as Category A were those that could be shown to have no effect on an item's ability to meet its design basis parameters or tolerances by' comparison with the current design basis or consid-1                                                                     eration of mandatory programs which demonstrate compliance with the design basis. Typical nonconformances identified by the Overinspection Program that resulted in a Category A June 13, 1985 i
      , ~ ,   a >_ _ _ _ _ _ _ - _ _ _ _ _ _ - - - - - _ _ -. _ _ _ - - - - - _ - - - - _ - . - - - . - _

classification are cosmetic weld defects, loose and incom-plete installation, incorrect adjustment, lack of clear-ance, construction tolerance violations, and minor documen-tation errors.
Cosmetic weld. defects were comprised mostly of weld spatter and are strikes that did not cause a reduction in base metal.
C Installation-related nonconforming attributes, such as loose or incomplete hardware, incorrect adjustment, lack of
                        .          clearance, and interferences and tolerance violations were--
evaluated to determine if the design requirements for installation would be programmatically inspected or tested during startup or some other subsequent testing program.
Programmatic tests such as hydrostatic testing, preopera-tional testing and hot functional testing are considered to be part of a design basis program to confirm that the designated design requirements relating to a component's installation will be met, not only from a component basis but also from a system basis. No further evaluations were performed to determine the design significance of these ~
since they would have received subsequent inspection.
4 Documentation errors, missing or damaged identification tags or code data plates, and lack of welder identification
(,                            are typical discrepancies grouped under documentation.
                                ---Since proper identification was established or recovered from other files, they were classified as Category A and no further evaluation effort was required to demonstrate design basis compliance.
1 Documentation discrepancies involving incorrect fabrication or construction drawings were, in most cases, previously reviewed for design impact by the originating design
:                                  organization and decisions     were made to utilize the
:                                  as-installed configuration     ("use-as-is") and make the aapropriate corrections to     the design drawings to reflect t3e "as-built" condition.      These were readily determined to e                                  have no impact on design based on the disposition of the i
originating.NCR and, hence, were classified as Category A.
CATEGORY B NONCONFORMANCES 1
!                                  Nonconformances classified as Category B involved those           -
nonconformances which required the comparison of the discrepancy to the weld capacity or component design margins. In many cases detailed engineering analysis and calculational comparison to the original design was l                                  required. Discrepancies that resulted in potential weld I                                  capacity or component design margin reductions of less than 10% are classified as Category BI and those with capaci-l                                  ty/ margin reductions equal to or greater than 10% as t
(                              Category B2. The most prominent examples involved minor i
1 1
                                                                                                                                                                     ~
l             - - . _ _ .   ._.       .~ .     .      ___

                                 ~
e damage to piping and mechanical supports where a comparison of the depth of the damage (arc strike, gouge, cut, etc.)
was made to the manufacturer's minimum wall /section thick-ness requirements or base metal section modulus to ensure minimum wall requirements were not violated. If minimum wall /section thickness requirements were violated, a calculation was performed to determine that the minimum design requirements were satisfied. Weld related defi-ciencies of this type included such nonconformances as lack of fusion, weld undercut and base metal reduction, weld overlap, slag inclusion, and undersized welds. Addition-ally, where actual weld capacity (affected portion exclud-ed) had to be compared to the design capacity for the weld to preclude stress related failure, a Category B classifi-cation resulted.
Detailed piping evaluations required review of the piping stress reports for the subsystems being affected and in some cases, reevaluation of the piping analysis to deter-mine if the applied loads to a given support or the lo-calized piping stresses would have resulted in exceeding code allowable stresses under dynamic loading.
As noted in the above Table (Data as of 12/31/84), forty-two (42) piping (large and small bore) components had nonconforming attributes identified that potentially could have reduced their capacity or design margin by equal to or greater than 10%. These reported nonconformances were comprised of: fourteen cases of gouges, dents, overgrinds, and arc strikes: fifteen cases of undersized fillet welds on penetration head fittings and pipe fittings: one case of nonconforming pipe routings two cases of loose bolting on flanges; and the balance of butt or fillet weld concavity and undercut.
Welding nonconformances resulting in Category B2 classi-fications on mechanical supports primarily involved un-dersized welds, overlap, undercut, and slag inclusion.
These nonconforming welds were evaluated by comparing the actual weld stresses (excluding affected areas) to code allowable stresses.
Several nonconformances were for clearance requirements on guide or " box" type mechanical aupports. These conditions required a detailed evaluation of specific load increases on adjacent supports and the structure and detailed reanal-ysis of the affected piping system. In no case was a safety significant condition identificd among the noncon-formances evaluated.
IP RESPONSE TO NRC QUESTION B.3: As noted in the response
  'to Question A.3 above, cumulative effects were considered where appropriate. Therefore, IP has demonstrated a high June 13, 1985

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degree of confidence in pi response to Question A.1). ping and mechanical supports (See IP RESPONSE TO NRC QUESTION B.4: Yes. Considering the responses to Question A.3 and B.3 above, the conformance criterion proposed in IP's letter of March 29, 1985 is sufficient when applied to piping and mechanical supports.
                                                                             ~
NRC COMMENT A.4:       The data presented.in references 2 and 3 related to piping and mechanical supports does not provide ~~
sufficient relevant information (e.g., numbers of SSCs inspected, numbers of inspections performed, and OI find-ings broken down by-discipline, by building and elevation, and by old vs. new work).
NRC QUESTION A.4:      Quantify OI results for piping and mechanical supports in terms of numbers of SSCs inspected, and numbers of inspections performed broken down by disci-pline, by building and elevation, and by old vs. new work.
                                                                                               ~
IP RESPONSE TO NRC QUESTION A.4: The data requested are i
provided on the. following 36 charts, except for the craft
;                              discipline information requested. No specific data is available for this informations however for piping all work f                         is performed by pi
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i                             approximately 95% pe fitters and for mechanical supportsof the work is p with the remaining 5% divided between boiler makers and i
iron workers. As is demonstrated by these charts, the i
results of the Overinspection Program provide a representa-l                              tive sample of all buildings and elevations containing i                              piping components and mechanical supports subject to the l                              Overinspection Program.      This, coupled with the number of l                              inspections performed, demonstrates that a large random sample has been reinspected and therefore the results represent the quality of these items at CPS.
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ATTRIBUTES INSPECTED
:                                                        UNDER OVERINSPECTION PROGRAM AS OF 12/31/84                                            ,
By: Building Elevation i    _22 BAFV/IPOI OLD/NEW i
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BLDG i                                                                                     NO                 BUILDING i
22  SCREEN HOUSE 25  TURBINE BUILDING
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25                      31                             26  AUXILIARY BUILDING 27  REACTOR BUILDING 28  FUEL BUILDING 29  DIESEL GENERATOR & HVAC BUILDING J,                                                                              30  CONTROL BUILDING e
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29                              Buildings containing items subject to IP Overinspection Program 2,,8_
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QUANTITY INSPECTED UNDER OVERINSPECTION PROGRAM AS OF 12/31/84                                           .,
i   E         By: Building Elevation BAFV/IPOI OLD/NEW                                   -
l BLDG NO                 BUILDING 22  SCREEN HOUSE 25  TURBINE BUILDING 25              31                              26  AUXILIARY BUILDING 27  REACTOR BUILDING 28  FUEL BUILDING 29  DIESEL GENERATOR & HVAC BUILDING w                                                                                      30  CONTROL BUILDING 31  RADWASTE BUILDING 26     -
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                                               -       27  -
KEY PLAN:
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i NRC COMMENT B.1:       Ten thousand attributes inspected does not appear to be a consistent criterion which can be meaningfully applied to different plant SSCs. For example, a simple beam installation may consist of 150 sub-elements (attributes) while a complex beam installation may consist of 800 or more attributes. Thus the 10,000 attributes criterion may be satisfied by inspecting as few as 13 complex beam installations or 67 simple beam installations.
Neither number of installations appears to be an adequate Sasis for obtaining reasonable assurance in the total population of safety related beam installations at CPS.
This comment is equally applicable to piping and mechanical supports.
NRC QUESTION B.1:      Quantify the minimum number of mechan-ical supports and the minimum number of feet of large and anall bore pipe which would have to be inspected in order to achieve the 10,000 attributes criterion.                 Is that number an adequate basis for obtaining reasonable assurance in the total population of sbnilar plant SSCs? Provide the technical basis for your determination.
IP RESPONSES TO NRC QUESTION B.1:        It is not possible to uniquely quantify the minimum number of feet of pipe or the number of mechanical supports that would have to be in-spected to achieve 10,000 attribute inspections. This number varies widely depending primarily on the number of welds inspected for a length of installed pipe or the size and configuration of a mechanical support.
Empirically, based on Overinspection activity to date, IP has quantified the information requested in the table below. This data was obtained using the quantities of pipe and mechanical supports overinspected through July 31, 1984 l      and the attributes accumulated for the same period.
4

E s
QUANTITIES. REINSPECTED (BY FV) TO REACH 10,000 ATIKIBUTES REINSPECTED (Data Based on 12/31/84 Results)
C. Quantity to Reach A~. Quantity     B. Attributes       10,000 Attributes Commodity                    Inspected       Inspected        (A/B x 10,000).
Large Bore Pipe
* 40,267         32,747               12,296
    -Small Bore Pipe
* 12.,559        49,045                2,561 Mechanical Supports **         8 ,10 4      300,148                  270
* Piping is in Linear Feet
                    ** Mechanical Supports are in Units While:the-above empirical data have limited meaning for any given lot, the more important consideration relates to-whether 10,000 attributes.provides a high degree of confi-dence in the results of the Overinspection Program.
Regardless of the quantity of a commodity that would have
                 .to be reinspected to reach 10,000 attributes inspected, in         i IP's judgement 10,000 attributes is sufficiently reflective of the installation processes involved (i.e. , welding, bolting, locating, assembling, etc. ) that any significant adverse condition applicable to a type of item should be evident from such a large number of inspections and that meaningful conclusions can be drawn. . Additionally, as is~
shown in Exhibit 1, when 10,000 attributes have been accumulated, the degree of uncertainty (at the 95% confi-dence factor) is extremely low, on the order of'1%. For piping and mechanical supports, the number of attributes accumulated is in excess of 10,000, and accumulation of additional attributes will not significantly improve the certainty. This supports IP's conclusion that meaningful information is available at the 10,000 attribute level.
June 13, 1985

e4 DEPENDENCE OF UNCERTAINTY IN NONCONFORMANCE UPON THE NUMBER OF ATTRIBUTES INSPECTED
                                                                  .98 AT 95% CONFIDENCE LEVEL s.0-U=M
    .                                                              WHERE     U= MAXIMUM UNCERTAINTY IN NONCONFORM ANCE R A TE
?   '
f N= NUMBER OF ATTRIBUTES INSPECTED 4.0-8 E
          =
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       ! 01.0 -
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Small bore piping and
_g
       ,g Data on this figure represents                                                                    ~
l                                 FV Data only.                           mechanical supports for l    lg                                                                   7-31-84 data; and all l    lg                                                                   commodities for 12-31-84
  !     :a                           '                                      are off the chart                                              .
l                                                    .     .      .     .
20#0 O                 .    .      .    .
9000 40,000                        15.000 3000 4000   6000 6000  7000  0000
-                  1000  2000

1
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NRC COMMENT B.2:    Five percent of the items (SSCs) in-spected may 'oe a reasonable basis for extrapolating confi-dence in the total population of similar SSCs installed, provided that:
: 1)  The total p pulation of similar SSCs is sufficientl large, or
: 2)  An adequate level of confidence can be established with smaller total populations of similar SSCs on some other basis.
: 3)  Provided the 5% sample is a random sample of old work (pre-July 1982).
;                                           The basis for any determination regarding small populations of similar-SSCs must be clearly established.
4 NRC QUESTION B.2: Can IP demonstrate that required confi-
.,                                          dance levels will be achieved using the 5% criterion even when small total populations of SSCs are inspected under the OI program?
1                                          IP RESPONSE TO NRC QUESTION B.2: As is shown in Exhibit 2, I'                                          for all cases where the total number of commodities in the plant exceeds 4,000, and for those cases where the number                               -
of commodities is between 2,300 and 3,000, reinspecting 5%                            ,
of the commodity will result in equaling or exceeding the sample size specified by the 95/95 criteria established by IP and concurred with by the NRC for the Overinspection Program. The quantity of piping and mechanical supports already reinspected under the Overinspection Program substantially exceeds the number which would be required to
;                                           meet either the 95/95 or the 5% criteria.
I r
i 4
I J
4 i

400                                                                                                        Piping and mechanical supports are off this "Y  eV eV     *\*    *\*            *\*              chart for both 7-31-84 O   O
* b              D                 and 12-31-84 data.
W 300 O
Ld o
e W
us 01 95/95 SAMPLE SIZE
         $'          3  200                                                f
   .                 $                                                                                 Relationship between number of total O
items in plant to be inspected using 95/95 i
[                                                                                 criteria from MIL-STD-lOSD and various 2
percentages of items in plant.
i                    U                                                                  '
NOTE: Data in this figure represents j
[
O
                                                                      /                                         FV Data only.
5
 .                      100 5% CRITERIA IP PROPOSAL J
95/35 CURVE REPRESENTS SAMPLE l
PLAN FROM MIL. STD -105D t
O                                           3        4       5         6           7            8        9                                                  10 I                     '
2 NUMBER OF ITEMS IN PLANT (x 1000)

4 1
Lf 4
Although not. subject of the present IP request, of the other commodities that are within the scope of the Overin-spection Program, there are only two where the reinspection of 5% of the items would not exceed the sample size spec-ified 95/95 criterion. .These are instrumentation (500                                                l i                                                                                    pieces) and mechanical equipment (904 pieces). IP has already reinspected more than 5% of the instrumentation and                                         -
2                                                                                    mechanical equipment. The amount inspected to date is well                                             l above that required to meet the 95/95 criterion.               Even if                                l this were not the case, IP's judgment is that the installa-tion of instruments and mechanical equipment is similar to other commodities where substantial quantities are installed and have been reinspected. If the quality of these other items is satisfactory, the smaller sample of instrumentation and mechanical equipment would adequately confirm their acceptability since the installation work is
;                                                                                      similar and is performed and inspected by the same groups of personnel during the same time frames and under similar controlled conditions.
Regarding the question of the randor distribution of reinspections of old work, the figure 6 presented in re-sponse to question A.4 provide these data.
l Regarding the question of old work versus new work, the results of the overinspection Program do indicate that new work has a higher conformance rate than old nork. In the
,                                                                                      aggregate the difference was 3.6% as of July 31, 1984 and 3.7% as of December 31, 1984 using attributes inspected by BAFV. This improvement in inspection results is the effect of the numerous program improvements made by IP in 1982.
However, many of the problems noted in 1982 which resulted i                                                                                       in stop work action at CPS and ultimately the                                                    ,
1                                                                                       Overinspection Program were programmatic in nature.               In I                                                                                       these cases, hardware defects were not substantial enough to have warranted the stop work action. Work was stoppe*d i                                                                                       because inspection activity was far behind construction and documentation was deficient so that hardware quality-could not be ascertained. Further, although conformance rates for old work are lower than for new work both are above the i                                                                                        95% criteria established by IP as the threshold for
!                                                                                        considering removing a commodity from the Overinspection                                        ,
;                                                                                        Program. Additionally, and most importantly, the engineering evaluation performed by S&L on nonconformances detected by the Overins7 action Program did not identify any ~
condition in old work wtich would, if left uncorrected by the Program, have had an impact on plant safety.
IP recognizes that the NRC's interest in the Overinspection                                    '
Program beginning in 1982 has centered on the question of l                                                                                         old work.      However, for the reasons stated above, IP believes that the restriction of the "5%" criterion to old work is unnecessary and unwarranted.                                                            l 1
I i
                                                                                                                                                                                                                                                 ~
i                                                                                                                            .          ..

               * * * *******************x                                                 ***x                       x *****
NRC COMMENT B.5:                 Criterion C (related to defense in depth) appears to be a valid criterion, subject to the veracity of the engineering evaluations performed (see                                                                  -
comment C.2).                                                                      _<
NRC QUESTION B.5: Can IP demonstrate that this criterion is met for piping and mechanical supports when the engi-neering evaluations performed for safety significance conform to the stated premises (refer to comment C.l. for premises)?
IP RESPONSE B.5:              Considering the information provided in response to question A.1, A.3, and B.3 above and to ques-tion C.1 below,-IP concludes that the criterion has been fully satisfied for piping and mechanical supports.
;                          NRC COMMENT C.1:              In the engineering evaluations document-ed in reference 2, attachment 2, third gage last paragraph, and in reference 3, Chapter V, paragraph C.2.b.2)(f) and (j ) , IP takes credit for future activities, the scope, depth, and quality of which may be undefined.                                         For example, the reference 2 paragraph states in part:
Installation nonconformances on pipe supports involved loose or incomplete hardware instal-lation, incorrect adjustment of sup lack of clearance or interference, ports,             and construction tolerance non-conformances.
Each nonconforming condition was evaluated to decernine if the nonconformance was of a type that would be specifically examined in subsequent preoperational testing.                       Conse-quently, these nonconformances were not significant because they would not have been left unidentified and uncorrected if the Overinspection Program had not been performed (emphasis added).
This methodology for evaluating construction deficiencies is not in accordance with 10CFR50.55(e), and does not                                                                      ~
appear to be consistent with a premise stated in reference
 ;                          2, attachment 2, first page, last paragraph, as follows:
Although S&L evaluated each nonconformance i                                   identified by the Overinspection 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 specifications and the remainder have                                                           -
i I
I
       , , , .    -  , - .   ,-m.-     ,,,,-,---.v-e___-                 - - . - - - _      , , , - - , -    ,..n,,-

l been determined to be acceptable as they are.                                                                        !
Consequently, the evaluations below were                                                                             I
  .                                        performed to determine the safety signifi-cance of the nonconformances assuming they had been left uncorrected (emphasis added).
~'
In addition, this methodology appears to depart from a stated premise in reference 3, Chapter V, paragraph C.2.a.,
as follows:
For purposes of this report, a safety signif-icant nonconformance is defined as a noncon-formance which, were it to have remained unidentified by the Overinspection Program (emphasis added), could have resulted in the loss of capability of a structure, system, or component to perform its intended safety function.
Reference 3 adopts the above premise by reference.
NRC QUESTION C.1:           Does IP intend that engineering eval-uations of OI findings conform to the requirements of 10CFR50. 55 (e) and the above premises?                                  If so, what are the results of IP's evaluations of OI findings concerning piping and mechanical supports when performed in accordance with the stated requirements and premises?
IP RESPONSE C.1:           NCRs initiated under the Overinspection Program are reviewed with respect to 10CFR50.55(e) criteria as part of the normal IP corrective action program.                                    These evaluations have been conducted taking no " credit for future activities" and no nonconformances were reportable under 10CFR50.55(e).
The engine'ering evaluation of Overinspection Program results reported in the February 1985 IP report entitled "Results of Quality Programs for Construction of Clinton Power Station" (Results Report) and the April, 1985 IP Report entitled " Update to Results of Quality Programs for Construction of Clinton Power Station" (Updated Results Report) was not undertaken for the purpose of satisfying the requirements of 10CFR50.55(e) . Those evaluations were performed assuming that the nonconformances had not been                                             ~
corrected as a result of the Overinspection Program.
                                       " Credit for future activities" was taken only for purposes of these evaluations.          If there was a downstream program or procedure in place as part of the normal quality assurance program (startup, testing or plant walkdowns for example) which could reasonably be expected to identify and correct the nonconforming condition, IP concluded that the condition would not represent a safety significant condition at CPS even if the Overinspection Program did not exist.
- - - - - - . - - . - c- - - - - - _          4.. __ _~r- , - __            -
                                                                               -,,-------i---,,,.---,,-----,--                   .y----m.     -m , , -, , - - -

                                                                                                                                           \
1 It is not IP's intent that the Overinspection Program be the only mechanism used to identify and correct nonconform-ing conditions at CPS.               As stated in the Overinspection Program Plan, the Overinspection Program supplements but does not replace the Quality Assurance Program for CPS.
This is also reflected in the definition of safety signifi-cance provided in Reference 3, Chapter V, Paragraph C.2.a which is cited above. The IP Updated Results Report contains language revisions which should clarify this matter and eliminate any potential inconsistencies.
NRC COMMENT C.2:             Reference                    3, Chapter 5, pages. V-9 through V-10, states:
For cases in which one NCR documented noncon-formances on different items or in which one item contained nonconforming attributes of differing natures (e.g., loose bolt and arc strike), separare evaluations of the impact of the nonconforming attributes on each item were conducted to ensure that all possible adverse impacts were addressed.
:                                   This statement seems to imply that multiple nonconforming conditions identified on a single item were treated sepa-                                      ~~--
rately.
4 l                                  NRC QUESTION C.2:            If this is what was intended by the
;                                   statement above, can IP justify the methodology used in
;                                   light of the dependent nature of certain attributes (as discussed in A.l. and B.3. above)?
             .                       IP RESPONSE TO NRC QUESTION C.2: As discussed in the response to Question A.3 above, both singular and cumula-tive effects were considered, as appropriate, for the nature of the reported nonconforming attributes and the
:                                    affected components.
                        **w          ******w                ***********************
NRC COMMENT C.3:            Reference 3, Chapter 5, paragraph C.2.b.2)(c), Arc Strikes, does not differentiate between                                           ~
superficial and severe are strikes. A severe arc strike 2
may reduce piping wall thickness substantially and/or include a localized crack, usually at the bottom of the pit created by the strike.
NRC QUESTION C.3:          Provide both qualitative and quantita-tive analytical results from the engineering evaluations performed on arc strikes identified on piping and mechan-ical supports.
r
   -   . . _ _ _ .       . ~ . ,       ___ ____ ___ ._              _,. _ _ _. _ ._ _ . _ __                 _ _ _ _ ___ .___. _ ,

IP RESPONSE TO NRC QUESTION C.3: As discussed in the response to Question A.3 above, arc strikes were evaluated to determine their potential effect on the piping compo-nents and mechanical supports. In no case were any lo-calized cracks reported that were a result of the are strike. Therefore, only the effect of the arc strike on the pipe's minimum wall thickness, mechanical supports section modulus or weld size, required evaluation. Where the depth of the arc strike affected the weld capacity or component design margin, detailed calculations were performed. The tables below summarize the results of the evaluations. As is evident from the table, the majority of arc strikes had little or nor effect on the affected component. In some cases, the reduction in weld capacity or design margin was calculated to be greater than 10%.
This was due to the conservative assumption that the por-tion of the weld affected by the arc strike was assumed to carry no load. In all of these cases, the remaining weld (portion unaffected by the are strikes) was determined to be capable of carrying the design loads within the design basis. In other cases, the arc strike in conjunction with other nonconforming attributes resulted in a reduction in capacity or design margin of equal to or greater than 10%
and were determined to be acceptable within code allowable stresses.
June 13, 1985

NUMBER OF COMPONENTS WITH REPORTED ARC STRIKES (Data as of 12/31/84)
Number of Number of Piping Spools       Mechanical Significance         Large Bore      Small Bore      Supports Category A                23             11            52 Category B1              134             67           425
( <10%)
Category B2                4              2              4
( 2.10%)
Category C                 0              0              0 NRC COMMENT C.4: Reference 3, Chapter 5, paragraph C.2.b.2)(d) provides the engineering evaluation of missing or incorrect identification markings. That evaluation does not appear to consider the potential impact of missing or incorrect identification on the correct performance of operating activities (operations, maintenance, and surveil-lance).
In addition, there is no indication as to the type of criteria applied by S&L in evaluation of missing or incor-rect material markings. This is of particular importance in view of the substance of IP's 10CFR50.55(e) reports 55-84 -02 and 55-84 -18.
NRC QUESTION C.4(1):     Provide the following additional information related to engineering evaluations performed on missing or incorrect identification markings:
(1) The results of evaluations performed related to the impact of missing or incorrect component identification markings (related to piping and mechanical support components) on the correct performance of operating activities.
IP RESPONSE TO NRC QUESTION C.4(1): As is discussed in IP's February 1985 Report entitled "Results of Quality Programs for Construction of Clinton Power Station" (Re-sults Report), Chapter V, paragraph C.2.b.1(d), "S&L l
ovaluated all cases of missing, incorrect, or damaged identification markings to assure that the proper identity had subsequently been established. In all casea, the correct items were installed. In addition, the plant startup and testing process would have identified these June 13, 1985 L

s cases and the missing, damaged, or incorrect equipment tags would have been corrected.          Consequently, none of these nonconformances was     safety-significant."
NRC QUESTION C.4(2):        The criteria used by S&L in disposi-tioning nonconformance reports dealing with missing or incorrect material identification markings on piping and mechanical supports.
IP RESPONSE TO NRC QUESTION C.4(2):                            Eight pipe spools, fittings or connecting bolts and one mechanical support's expansion anchor bolting were initially identified as lacking material traceability. In each case, the material traceability was subsequently reestablished by reinspection or through existing documentation. No further criteria for acceptance of these nonconformances were required.
NRC COMMENT C.S.a: S&L form 350-A (seismic) states that the actual design attachment of equipment to a structure must be simulated in mounting the equipment for a test.
NRC QUESTION C.5.b: Has IP considered the impact of OI findings on the results of seismic testing and analyses performed? What are your results?
IP RESPONSE TO NRC QUESTION C.5.b:                          S&L form 350-A (Seis-mic) does require equipment to be seismically tested or 1              analyzed to verify that the actual design attachment of the equipment to the structure is properly simulated. This requirement does not apply to piping and mechanical sup-ports. For piping systems, a dynamic analysis is performed which includes the appropriate seismic res1onse spectra.
The seismic loading for each support and the resulting stresses induced in the piping were considered in each overinspection evaluation where a reduction in strength resulted from a nonconforming condition. For all small and large bore components / piping and mechanical supports evaluated, thesyste code allowables.
NRC QUESTION C.5.c:       Has IP quantified the impact of engineering analyses performed under the Overinspection Program in terms of reduction in safety margin on piping and mechanical supports? What are your results?
IP RESPONSE TO NRC QUESTION C.5.c:                         There has been no reduction in safety margin, in terms of IP's definition of safety significance, for piping and mechanical supports as determined by the engineering evaluations. Quantified                            -

t C
results for capacity and design margin for each commodity are provided in the response to NRC Question A.3 above.

U-600008

==Subject:==
Rasponse to NRC Concarning Request to                   L37
* R:mova Componsnts from OI Program                       1A.120 bec  W. C. Gerstner, B-13
            .D. P. Hall, V-275 H. E. Daniels, V-650 J. S. Perry, V-275 S. B. Fisher, V-913 J. W. Wilson, T-31 J. H. Greene, V-130 H. R. Victor, V-928 W. Connell, V-923 J. R. Patten, V-922 A. E. King, V-500 L. W. Osborne, V-900 J. G. Cook, T-31 K. L. Patterson, V-750 R. E. Wyatt, V-914 K. R. Graf. V-913 R. P. Rasho V-780 J. S. Spencer, V-920 F. A. Spangenberg, V-920 R. E. Campbell, V-923 K. B. Roys, V-645 J. E. Loomis, V-650 E. P. Rosol, V-500 D. K. Schopfer V-270 J. Greenwood, V-600 H. M. Sroka, S&L (Atten: H. S. Taylor)
S. A. Zabel, Schiff, Hardin & Waite J. R. Newman, Newman & Holtzinger P. J. Telthorst, IPC (Newman & Holtzinger)
CPS Central File, T-31 i
e

s ENCLOSURE 2
- OVERINSPECTION PROGRAM NONCONFORMANCES BY:
BUILDING - ELEVATION ITEM - ATTRIBUTE
           -      PIPING IS IN NUMBER OF SPOOLS MECHANICAL SUPPORTS ARE IN UNITS BA FV - IP OI OLD - NEW 12-31-84 DATA Juno 13, 1985

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