View source for U-600008, Responds to NRC 850411 Questions Re Licensee Request for Concurrence to Remove safety-related Piping & Mechanical Supports from Overinsp Program.Nonconformances Reported Determined to Be within Specified Design Limits

{{Adams
| number = ML20116C856
| issue date = 04/19/1985
| title = Responds to NRC 850411 Questions Re Licensee Request for Concurrence to Remove safety-related Piping & Mechanical Supports from Overinsp Program.Nonconformances Reported Determined to Be within Specified Design Limits
| 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-600008, NUDOCS 8504290189
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 61
}}

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ILLIN0/8 POWER COMPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON, ILLINOIS 61727 ggy TYP A n             Docket No. 50-461 April 19, 1985 i F~
                                                                                             , 'l Mr. James G. Keppler                                      -l                k.
Regional Administrator                                                   J        ~
Region III                                                         Ef1 U.S. Nuclear Regulatory Commission                                    m 799 Roosevelt Road Glen Ellyn, Illinois 60137 Subj ect:  Response to NRC Questions Concerning Illinois Power                                          /
Request For Concurrence to Remove Safety Related                                           /
Piping and Mechanical Supports from the Overinspection                                     ~[
Program

==Dear Mr. Keppler:==

By {{letter dated|date=March 29, 1985|text=letter dated March 29, 1985}} (I-0828, D. P. Hall to J. G.
     .        Keppler), Illinois Power Company (IP) submitted additional information requested by the Nuclear Regulatory Commission (NRC),
Region III in support of IP's request for concurrence to remove safetyLrelated piping and mechanical supports from the Overinspection Program. Enclosure 2 to NRC's {{letter dated|date=April 11, 1985|text=letter dated April 11,1985}} (J. G. Keppler to IP Attn: W. C. Gerstner), forwarded additional NRC Region III comments and questions concerning IP's March 29,'1985 letter U-0828.
Enclosed are IP's responses to the NRC Region III comments and. questions contained in Enclosure 2 to NRC's {{letter dated|date=April 11, 1985|text=April 11, 1985 letter}}. IP will be prepared to discuss these responses at the April 22, 1985 meeting to be held at the Region III offices.
NRC's {{letter dated|date=April 11, 1985|text=April 11, 1985 letter}} also forwarded comments and questions contained in Enclosure 3 to that letter which relate to future proposals to terminate overinspection of additional commodities. In accordance with that NRC letter, IP will address those comments and questions prior to submission of any such future proposal.
IP has received a copy of the Illinois Attorney General's {{letter dated|date=April 12, 1985|text=April 12, 1985 letter}} to J. G. Keppler providing comments and questions on IP's February,1985 Report entitled "Results of Quality Programs for Construction of Clinton Power Station".
IP has reviewed this letter and is prepared to address those comments and questions within its purview as the NRC deems appropriate.
8504290189 850419                                         m ,, ,
PDR   ADOCK 0500046?
G               PDR APR 2 21985

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IP believes that the information previously submitted and the enclosed responses provide a complete base of information for i the April 22, 1985 meeting and for an NRC Region III decision on IP's request for concurrence at the earliest possible time.
                                            .'.        ours,
                                                  -]Lf j'/
: r. P. all Vice President JEK/cah Attachments 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

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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 SUPPORTS 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 t           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-ity.-  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 attributas of a pipe support, would have a greater impact on the integrity of that support when taken together than when considered separately).
NRC QUESTION A.1:    Provide OI program results for piping and mechanical supports (including confidence factors) in terms of plant SSCs rather than 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 n = number of items inspected i
RESULTS OF OI PROGRAM IN TERMS OF COMPONENTS (SSC'e)
(WITil CONFIDENCE FACTORS)
Data as of July 31, 1984 Items       Safety       Reliability    Items     Items     Safety     Reliability Total   Inspec3ed    with       Significant Based on 95%    Inspec5ed  with 4   Significant Based on 95%
Cocznodity                Plant    by FV      NCR's 4         NCR's      Confidence    by OI    NCR's        NCR's     Confidence Large Bore Pipe l         7,700       998        181             0           99%         460       12           0        > 99%
l Small Bore Pipe          17,200    1,719         166             0           99%       1,720       11           0        > 99%
2
   !!echanical Supports     13,500    3,10 0        939             0           99%       1,100     209            0        > 99%
Data as cf December 31, 1984 Items       Safety       Reliability    Items     Items     Safety     Reliability Total    Inspec5ed    with       Significant Based on 95%    Inspected  with     Significant Based on 95%
Comodi ty                Plant     by FV      NCR's 4         NCR's      Confidence    by 01"   NCR's 4      NCR's     Confidence Large Bore Pipe l        7,70 0    4.380         295             0           99%         920       23          0          >99%
l 3,60 0 4
Small Bore Pipe         17,200                   243             0           99%       3,100       19           0        >99%
2 ffecbanical llangers 13,500        5,400      1,477              0           98        1,700     287            0        >99'%
NOTES-f    Piping is in Number of Pipe Spools ffechanical 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 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 large bore pipe and 3.8 feet for small bore pipe. The nunier of spool pieces inspected by F0 and OI was 4    then calculated by dividing the number of linear feet inspected by this overage spool piece leng t.h .
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 terms of 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 JULY 31, 1984
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Items                         Reliability Total                             Inspected                        Based on 95%
                                ' Commodity                              Plant                                 by FV                         Confidence Large Bore Pipe
* 56,100                                   7,300                          )>99%
Small Bore Pipe
* 65,300                                   6,500                           :>99%
Mechanical Supports **                  13,500                                  3,100                            :>99%
DATA AS OF DECEMBER 31, 1984 Items                         Reliability Total                               Inspected                        Based on 95%
Commodity                           Plant                                    by FV                          Confidence
: j.                               Large Bore Pipe
* 56,100                                   32,000                            > 99%
l'                                Small Bore Pipe
* 65,300                                   13,700                            > 99%
Mechanical Supports **               13,500                                      5,400                          >99%
* Piping is in Linear Feet
                                  ** Mechanical Supports are in number of Units i
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

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an independent reviewer to judge the actual significance of OI findings.
NRC QUESTION A.3: Provide additional qualitative data related to piping and mechanical supports which was the basis for statements contained in references 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 chould consider all applicable attri-butes inspected.
NRC COMMENT B.3: Because of the dependent nature of 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, nuts, several structural shapes arranged in a defined geometry, interconnecting welds, connecting rods, U bolts, clamps, etc.. These individual parts of the support 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 piping and mechanical supports when the individual attributes 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 detailed analytical results.
NRC QUESTION B.4: Considering the response to item [B.3]
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 determine the potential significance to plant safety had the nonconforming condition (s) been undetected by the Overinspection Program. These engineer-ing evaluations demonstrated that the identified nonconfor-mances would not have impaired the ability of the safety related large and small bore piping and mechanical supports to perform their safety related design function. The design margins of each piping system or mechanical supp>rt, considering the reported nonconformances, were determined to be within the specified design limits.
The engineering eyaluations 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 capability or structural integrity of the compo-nent. The components so affected have been divided into Categories B1 and B2 to quantify the signifi ,
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 nonconforming 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.
_5

SIGNIFICANCE OF IDENTIFIED NONCONFORMING CONDITIONS EXPRESSED IN TERMS OF CAPACITY OR DESIGN MARGIN REDUCTION:
Data as of July 31, 1984 Category A   Category B1   . Category B2 Category C    Total Commodity                (No Impact)    (<10%)          Q.10%)
Large Bore-Pipe Spools     60 (30%)    110 (57%)       23 (13%)     0 (0%)    193 (100%)
With Nonconforming Conditions Small Bore Pipe Spools     65 (37%)    106 (60%)        6 ( 3%)     0 (0%)    177 (100%)
With Nonconforming Conditions Mechanical Supports       148 (13%)    823 (72%)      177 (15%)     0 (0%)   1148 (100%)
With Nonconforming Conditions                                        ,
TOTAL                     273 (18%)   1049 (69%)     206 (13%)      0 (0%)   1518 (100%)
Data as of December 31,'1984 Category A   Category B1    Category B2 Category C     Total Commodity                (No Impact)    (<10%)          &10%)
Large Bore Pipe Spools     86 (27%)    201 (63%)       31 (10%)     0 (0%)    318 (100%)
With Nonconforming Conditions Small Bore Pipe Spools     94 (36%)    159 (61%)        9 (3%)      0 (0%)    262 (100%)
With Nonconforming Conditions Mechanical Supports       242 (14%)   1246 (71%)     276 (16%)      L (0%)   1764 (100%)
With Nonconforming Conditions                                                         _
TOTAL                     422 (18%)   1606 (69%)      316 (13%)     0 (0%)   2344 (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 basic parameters or tolerances by comparison with the current design basis or consid-eration of mandatory programs which demonstrate compliance with the design basis. Typical nonconformances identified by the Overinspection Program that resulted in a Category 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 arc strikes that did not cause a reduction in base metal.
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.
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 baats compliance.
Docurantation 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 appropriate corrections to the design drawings to reflect the as-built" condition. These were readily determined to have no impact on design based on the disposition of the originating NCR and, hence, were classified as Category A.
CATEGORY B NONCONFORMANCES 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 required. Discrepancies that resulted in potential weld capacity or component design margin reductions of less than 10% are classified as Category B1 and those with capaci-ty/ margin reductions equal to or greater than 10% as Category B2. The most prominent examples involved minor 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 1 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 classification 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 ifLthe 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 (40) piping (large and small bore) components had noncon-forming 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: seventeen cases of gouges, dents, overgrinds, and are strikes sixteen cases consisted of undersized fillet welds on penetration head fittings and pipe fittings one case consisted of nonconforming pipe routings and the balance consisted 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 supports. 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 identified 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
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degree of confidence in piping and mechanical supports (See response to Question A.1).
                  ? 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 01 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 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 is performed by pipe fitters and for mechanical supports approximately 95% of the work is performed by pipe fitters with the remaining 5% divided between boiler makers and iron workers. As is demonstrated by these charts, the results of the Overinspection Program provide a representa-tive sample of all buildings and elevations containing piping components and mechanical supports subject to the Overinspection Program. This, coupled with the number of 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                          '
            - j,                   AS OF 7/31/84 By: Building Elevation g              BAFV/IPOI   OLD/NEW l
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w 29    DIESEL GENERATOR & ilVAC BUII. DING
?                                    30    CONTROL BUILDING 31    RADWASTE BUILDING 26               30 KEY PLAN:
29                   Buildings containing items subject to IP Overinspection Program 2_8,

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                          -         27     -6                                KEY PLAN:
29                  Buildings containing items subject to IP Overinspection Program 28 P

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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 basis 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 small 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 similar 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 and the attributes accumulated for the same period.
i I
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r QUANTITIES REINSPECTED (BY FV) TO REACH 10,000 ATTRIBUTES REINSPECTED (Data Based on 7/31/84 Resulta) e C. Quantity to Reach A. Quantity      B. Attributes       10,000 Attributes Commodity                    Inspected       Inspected        (A/B x 10,000)
Large Bore Pipe
* 7,300         19,376                3,800 Small Bore Pipe
* 6,500         32,114                2,000 Mechanical Supports **         3,100        178,435                  174
* 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 IP's judgement 10,000 attributes is sufficiently reflective of the installation processes involved (i.e. , welding, bolting, locating, ussembling, 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.
s FIGURE 1                ,
DEPENDENCE OF 1)NCERTAINTY IN NONCONFORMANCE UPON THE NUMBER _QF ATTRIBUTES INSPECTED s.0 -                                                             U = .98 AT 95% CONFIDENCE LEVEL N
WHERE        U= MAXIMUM UNCERTAINTY IN NONCONFORM ANCE R ATE N: NUMBER OF ATTRIBUTES INSPECTED O.0-E co I
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'g                                         FV Data only,                               mechanical supports for 7-31-84 data; and all a                                                                                   commodities for 12-31-84 are off the chart                                             '
1          0    ,      ,           ,        .      .                    .
15,000                    20pc S000  6000    7000   0000   9000 10,000 1000  2000        3000   4000 NUMBER OF INSPECTED ATTRIBUTES

                                                                                                                                              /
NRC COMMENT B.2:                                              Five mercent of the items. (SSGs) in-
                                      .spected may be a reasonaile basis for extrapola. ting confi-dence in the total population of similar SSCs installed, provided that.
: 1)      The total population of similar SSCs is sufficiently large, or;                                                              -
: 2)      An adequate level of confidence can be established w'ith                                                                                                                ,
smaller total populat! ions of similar SSCs on-some dther                       '
                                                                                                                                                                                                                       /
basis.                                                          .                                                                                                                     q
: 3)       Provided the 5% sampielis a random sample of old work
                                        * > pre-July 1982).
_(
                                                                                      .                ,s The' basis for .any determination regarding small popuhtfons of.similar SSCs must be clearly established.                                                                                                    i'
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                                / NRC QUESTION B.2:                                                  Can              IP    demonstrate                      that   requ'            ired confi-3ence levels will be; achieved using the 5% criterion even when small total populatio'ns of SSCs are inspected \ under the OI program?                                                       ,
                                                                                                             ,.                                                                    r IP RESPONSE TO NRC QU'ESTION B.2: As is shown in' Exhibit 2, for all cases where the total number of commodities in the plant exceeds 4,000, and for those cases where the number                                                                                                             N:
j of -co'mmodities is betwcpn 2,300 and 3,000, reinspecting '5%
                       '                of th'e commodity will result in equal.'ng or exceeding'th4 sample,' size specified by the 95/95 criteria established by IP and concurred with by the NRC for't,he Overinspection Program.                               The quantity of piping and mechanical supports p          4       already reinspected.under the Overinspection Program substantially exceeds;the number which would be, required to L. meet either the 95/95 or the 5% criteria.           '
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I 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 pieces) and mechanical equipment (904 pieces). IP has already reinspected more than 5% of the instrumentation and mechanical equipment. The amount inspected to date is well above that required to meet the 95/95 criterion. Even if 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 framec and under similar controlled conditions.
Regarding the question of the random distribution of reinspections of old work, the figures presented in re-sponse to question A.4 provide these data.
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 work.        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 in stop work action at CPS and ultimately the Overinspection Program were programmatic in nature.        In these cases, hardware defects were not substantial enough to have warranted the stop work action. Work was stopped 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 95% criteria established by II' 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 Overinspection Program did not identify any condition in old work which 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 old work. However, for the reasons stated above, IP                   '
believes that the restriction of the "5%" criterion to old work is unnecessary and unwarranted.

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 supportc.
NRC COMMENT C.1:      In the engineering evaluations document-ed in reference 2, attachment 2, third page 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 supports, lack of clearance or interference, and construction tolerance non-conformances.
Each nonconforming. condition was evaluated to determine 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 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
                                         .gg.

r been determined to be acceptable as they are.
Consequently, the evaluations below were 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 frcm 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 01 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 engineering 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.
                                                        .- -, . . - - _                 - - -. _ ~. - -             .- -.-. - -.-. -. - - . . . - . -

r 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), separate 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.
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.
NRC COMMENT C.3:     Reference 3, Chapter 5, paragraph C.2.b.2)(c), Arc Strikes, does not differentiate between superficial and severe arc strikes. A severe arc strike 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.
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p 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 arc strike. 'Therefore, only the effect of the are 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     I evaluations. As is evident from the table, the majority of arc strikes had little or no 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 portion 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 are 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.
NUMBER OF COMPONENTS WITH REPORTED ARC STRIKES (Data as of i/31/84)
Number of Number of Piping Spools        Mechanical Significance      Large Bore      Small Fore        Supports Category A             7                4             36 Category B1           68               35            275
(< 10%)
Category B2            1                1             58 (2.10%)
Category C             0                0              0 fE l
l 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             17               10              53 Category B1            83               46            353
(< 10%)
Category B2             4                2              69 (it 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 l               markings (related to piping and mechanical support components) on the correct performance of operating activities.
l 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 evaluated all cases of missing, incorrect, or damaged identification markings to assure that the proper identity had subsequently been established. In all cases, the correct items were installed. In addition, the plant startup and testing process would have identified these e                         -
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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.5.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 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 response 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 piping and mechanical supports evaluated, the components / systems were determined to be acceptable within code allowables.
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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 r.
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results for capacity and design margin for each commodity are provided in the response to NRC Question A.3 above, r
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==Subject:==
Response to NRC Concerning Request to               L37 Remove Components from OI Program                   lA.120 e
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 l
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