ML20092P778

Summary of Testimony & Testimony of Wj Shewski on Contention 1 Re Reinsp Program,Inspector Qualification.Related Correspondence

ML20092P778
Person / Time
Site:	Byron
Issue date:	07/02/1984
From:	Shewski W COMMONWEALTH EDISON CO.
To:
Shared Package
ML20092P775	List: ML20092P774 ML20092P778 ML20092P781 ML20092P785 ML20092P787 ML20092P789 ML20092P792 ML20092P794 ML20092P795
References
OL, NUDOCS 8407090364
Download: ML20092P778 (159)

Text

r.

l REL/E s^

~

"# CQMMONWEALTH EDISON COMPANY DMteT July 2, 1984 UNITED STATES OF A rib ~9 SII.*49 NUCLEAR REGULATORY COMMISSION fjF Fl a n : y n n .

BEFORE THE ATOMIC SAFETY AND0iMENSING,, BOARD cdANCH In The Matter Of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL

) 50-455-OL (Byron Nuclear Power Station, )

Units 1 & 2) )

SUMMARY

OF THE TESTIMONY OF WALTER J. SHEWSKI ON CONTENTION 1 (REINSPECTION PROGRAM - INSPECTOR QUALIFICATION)

~ ,

I. Walter Shewski is Commonwealth Edison Company's Cor-porate Manager of Quality Assurance.

-II . Edison's QA department conducted three audits and four surveillances of the Reinspection Program. Additional surveillances were performed to close out audit findings and observations. In addition, throughout much of 1983, Quality Assurance personnel attended weekly meetings held with contractors involved with the Reinspection Progrtm. Mr. Shewski's testimony describes the scope, results, and corrective action, if any, for each of the audits and surveillances of the Reinspection Program, with particular attention to Hatfield, Hunter and PTL.

III. Edison's QC department directed PTL to conduct a special Unit Concept Inspection of a sample of attributes '

reinspected by site contractors during the Reinspection Program. This special inspection provides an additional level of confidence that the contractors' QC personnel were performing adequate reinspections under the Rein-spection Program. Mr. Shewski describes the qualifica-tions of the PTL overinspectors, how the work to be inspected was selected, and the results of the special Unit Concept Inspection as they pertain to Hatfield and Hunter Reinspection Program implementation. The reproducibility of Hatfield's and Hunter's results by PTL demonstrates that no favoritism was shown to any ,

particular inspector during the deinspection Program.

{

('>'1 8407090364 840702 PDR ADOCK 05000454 T. PDR l

IV. One PTL inspector involved in the Reinspection Program

(~g failed to achieve the acceptance threshold at the end

(/ of both the first and second three month periods.. A thorough review of his certification package showed that it was complete and accurate.

V. Mr. Shewski's testimony describes the steps taken by Edison's QA department to ensure that reliable Rein-spection Program records were maintained by site con-tractors. He concludes that there is no evidence that the certification records of QC and QA personnel or the Reinspection Program results are inaccurate or unreliable.

VI. Mr. Shewski concludes as follows:

A. That the Reinspection Program was properly implemented in accordance with the Program requirements; B. That the personnel performing the reinspec-tions were properly qualified and were not reinspecting their own work; and C. That the Program results were properly pro-cessed and evaluated and that the corrective actions for the deficiencies identified in the Edison QA audits were appropriate and adequate to resolve the audit concerns.

VII. Mr. Shewski describes the scope of the work performed by PTL at Byron, including nondestructive testing of welds, concrete testing, aggregate testing, concrete expansion anchor inspection and testing, soils testing, calibration, bolting inspection, and overinspections of work already inspected by site contractors. In addi-tion, since 1982, PTL has been performing Unit Concept Inspections.

VIII.Mr. Shewski finally describes the extent of Edison's QA oversight of Hatfield, Hunter and PTL since August 1983. Edison's program of audits and surveillances continued to be actively and intensely performed to identify problems, ensure that requirements are ful-filled and verify that inspection and testing of facilities were performed, reviewed and accepted by properly qualified personnel.

( 1 l

l i

? .-

- }

4-. l I

t i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

j COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL

) 50-455-OL (Byron Station, Units 1 and 2) )

TESTIMONY OF WALTER J. SHEWSKI

, Q.l. State your full name A.l. Walter J. Shewski Q.2. By whom are you employed?

A.2. Commonwealth Edison Company Q.3. In what capacity?

A.3. I am the Corporate Manager of Quality Assurance for the Company.

Q.4. Have you previously testified in this proceeding?

A.4. Yes.

Q.5. On what date?

A.5. My prior testimony was bound into the transcript of March 28, ]983.

i l

l o e 1 Q.6. Is the statement of your professional qualifications appended to your previous direct testimony still accurate and complete?

A.6. Yes.

Q.7. Please describe the scope of your present testimony.

A.7. The scope of my testimony is a description of (1) the activities of Commonwealth Edison Company's Qualtiy Assurance Department in the conduct of the quality control inspector reinspection program (" reinspection program") which was conducted at the Byron Station; (2) the results of an examination of the certification package of the one quality control inpsector (employed by PTL) who did not achieve a " passing" grade in the reinspection; (3) the steps taken to assure that the documentation of the Quality Control Inspector rein-spection program was accurate and reliable; (4) a de-scription of the scope of PTL's inspection activities at the Byron site; and (5) the extent of Ceco's quali-ty assurance oversight of Hunter, Hatfield and PTL since the previous close of the record in this pro-ceeding August, 1983.

Q.8. What is your personal involvement in the Quality Assurance Department's activities in connection with the reinspection program?

r

. . i l

g .

l A.8. After the formulation of the program in February, 1982, I reviewed and evaluated reports and surveil-lances prepared by quality assurance personnel and I reviewed the inspection reports on the reinspection program prepared by the NRC Staff. In addition I pre-pared a portion of the report on the reinspection pro-gram; more specifically Chapter IV which describes quality assurance activities in connection with the reinspection program and Appendix E.

Q.9. Please describe generally the activities of the Qua-lity Assurance Department in connection with the rein-spection program in so far as that program reviewed-the qualifications of quality control inspectors em-ployed by Hatfield Electric Company ("Hatfield"),

Hunter Company (" Hunter") and Pittsburgh Testing Laboratory ("PTL").

A.9. Through the course of the reinspection program (Feb-ruary, 1983 through the conclusion of the program)

Quality Assurance conducted 3 audits and 4 survell-lances of the reinspection program. Additional sur-veillances were performed to close out audit findings and observations. These audits and surveillances are discussed in detail in subsequent portions of my tes-timony. Two of these audits involved the activities

.w. - -- ev-

l of all site contractors including Hunter and Hatfield. The third dealt with Hatfield alone. Three of the 4 surveillances dealt with the activities of Hatfield and the other one involved the disposition of an interpretation of the reinspection program ini-tiated by Hunter.

Q.10. Did the Quality Assurance Department participate in any other activities concerning the reinspection pro-gram?

A.10. Yes. Concurrent with the start of the reinspection program in late March, 1983, weekly meetings were held with contractors involved with the reinspection pro-gram until mid-September, 1983. The purpose of the meetings was to resolve any questions that the con-tractors had relative to implementation of the reinspection program, to obtain information on the progress made by each contractor on a weekly basis.

Quality Assurance was present at a majority of these meetings. Either the QA Superintendent or a desig-nated QA representative involved with the recertifica-tion / reinspection attended the meetings. During the ,

meetings, questions arose relative to the implementa-tion of the reinspection program, many of which reculted in documented interpretations that were

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

r ,

5 -

acceptable to Site Quality Assurance. The QA audit performed in June, 1983 provided formal documentation of acceptance of the existing interpretations.

Q.ll. What other activities of the Quality Assurance Depart-ment took place in connection with the reinspection program?

A.11. The QA Department directed Pittsburgh Testing Labora-tory ("PTL") to conduct a special Unit Concept Inspec-tion of a sample of attributes reinspec'ted by site contractors during the reinspection program. This special Unit Concept Inspection, which is discussed in detail later in my testimony, was designed to deter-mine whether the results reported in the reinspection program were reliable and valid. This was done by reinspecting again the work of the site contractors.

Q.12. Please identify the surveillances of the reinspectien program by number.

A.12. The surveillances are identified as #5682 dated 1/21/84, #5700 dated 1/23/84, #5753 dated 2/2/84 and

1. 5811 dated 2/21/84.

e Q.13. Please describe the scope, results and corrective action, if any, for Surveillance #5682.

s .- i A.13. Surveillance #5682 (Attachment A) reviewed the tally-l ing accuracy of the reinspection results for a Hatfield inspector's first ninety (90) days of inspec- ,

tions after his certification in the visual welding i area. The reinspection record and the third party '

concurrence for 20% of the weld travelers were reviewed. 'With the exception of one weld traveler, the results given were accurate. For the one weld traveler, the number of welds rejected by the Hatfield inspector totalled 18 not 28. The correction was made to the data base. the error did not impact true rejectability as determined by the third party.

Q.14. Please describe the scope, results and corrective action, if any, for Surveillance #5700.

A.14. Surveillance #5700 (Attachment B) was a review of i

Interpretation 19 which provided concurrence to (1) use AWS D1.1-82, Articles 2.3.2 and 2.3.2.1 for inspection of fillet welds, and (2) to allow a vari-ance of up to .025" undersize as acceptacle when inspecting fillet weld size. This variction was f

deemed acceptable because of varying accuracy between j gauges employed by Hunter Corporation. Quality Assur-ance determined from the information prcvided that

-i I

L - ______ _ ___ _ _ _ __ _ _______ ________ _ ___ _ ___ _ __ _ _ _______ _ _ _ _ _ _ _ _ _

l l

i L l l

I I

this interpretation is reasonable and would not affect t

the validity of the inspection results. <

Q.15. Please describe the scope, results and corrective action, if any, for Surveillance #5753.

A.15. Surveillance #5753 (Attachment C) dated February 2, 1984 again reviewed the issuance and processing of fie ld problem thuets by l'atfield. The use of these sheets had first been identified es a problem in Audit 6-83-66 (see Answer 19). This surveillance was under-taken to confirm that Hatfield was continuing to use j field problem sheets to identify problems needing attention and not as a substitute for discrepancy or nonconformance reports. Various field problem sheets were reviewed. It was fe,und that they were correctly being written by Hatfield P2 sduction to Hatfield Engi-neering describing problems which prevented installa-tion per the design document and that no field problem '

sheets were being used in lieu of deficiency reports.

Also, it was found Hatfield was documenting deficien-cies using the deficiency report and nonconformance system as provided in their procedure. No deficien-cies were identified and no further corrective action as a result of this surveillance was required.

l l <

l l

4 I

L.____________-.__--- 1

s -

l l

. Q.16. Please describe the scope, results and corrective .

l action, if any, for Surveillance #5811.

l l A.16. Surveillance #5811 (Attachment D) was a review to verify the accuracy of the data tabulated by Hatfield in connection with the ReinspectioniProgram. The nine (9) attributes reinspected by Hatfield were visual welding, conduit, cable termination, equipment-setting and modification, bolting and cable pan hanger and cable pan inspections and all were checked. Tabula-tion errors were identified and corrected. The cor-rections did not affect the final results. It was found that the Reinspection Program results involving there nine (9) attributes were acceptably tabulated.

I i

( '

Q.17. Are the audits of the reinspection program identified l by number?

1' A.17. Yes. They are identified as #6-83-66, #6-83-93 and I

1. 6-83-124.

Q.18. What was the scope, findings and observations of audit-

1. 6-83-66?

l A.18. Audit #6-83-66 is in evidence as Intervenors Exhibit

29. That exhibit describes the scope of the audit, its findings and observations. For the convenienca ef-i

i. __ _ ._ _ _ ., , - - - --- ,- - . - -

. + l l

l i

the " card and the parties that audit is attached to my i i

testimony as Attachment E.

f Q.19. Please describe how the findings directed at the activities of Hatfield, Hunter and PTL in audit ,

1. 6-83-66 were resolved. l A.19. Finding #1 Part A applies to Hunter; Finding #1 Part B i

applies to Hatfield; and Finding #1 Part C applies to PTL.

I Finding #1 Part A identified two potential problems which could have affected the analysis of reinspection F

i results. The first item involved the use of field f problem sheets rather than a discrepancy report by  :

Hunter. Quality Assurance Surveillance #5189 (Attach-ment F) dated 10/1?/83 verified that discrepancy reports had been inititated for the supports identi-I fled in Finding #1 Part A as required by Hunter's pro-cedures.

a The second problem identified in Finding #1 Part A was

! concerned with the reinspection of bolted connections by Hunter. This item was dispositioned by a letter i

from Sargent & Lundy which stated " flange bolt torque values will relax over time" and thus are not repro-ducible. .

1

}~

Finding #1 Part B identified the fact that Hatfield was ucing field problem sheets to resolve discrepan-cies identified during reinspections for the conduit and termination attributes. Quality Assurance Sur-veillance #5202 R1 (Attachment G) identified that HECo. NCR #674 was written to disposition a deficient item discovered during the reinspection process which had previously been the subject of a field problem sheet.

Finding #1, Part C identified the fact that PTL had not yet transmitted inspection reports generated dur-ing the Reinspection Program to the appropriate con-tractors. These inspection reports described dis-crepant conditions in work performed by other contrac-tors, but inspected by PTL. PTL was working on the premise that reports with nonconforming conditions would be reported to the contractors upon completion of the Program. Upon being advised during the audit to immediately transmit nonconforming reports to the appropriate contractors after cen:urrence by the independent third party inspector, PTL began and con-tinued transmitting such reports at they were pre-pared. No further corrective action was required.

Quality Assurance surveillance 4939 (Attachment H) l I

described the corrective action taken to close this  !

.I audit finding.

n

r Q.20. Were nonconformance reports issued as a result of any audit finding of Audit #6-83-66 included in a trend analysis program?

A.20. Hatfield issued NCR-674 for an isolated problem deal-ing with a relay which was eventually determined to be a temporary installation. This NCR was included in the 1983 third quarter trend analysis by Hatfield.

All other NCRs initiated as a result of discrepancies observed during the reinspection program were included in trend analyses.

Q.21. Please describe how the observations directed at the activities of Hatfield and Hunter in audit #6-83-66 were resolved.

A.21. Observation #1 applies to Hunter and Hatfield. The Hunter portion of Observation #1 wac closed by Quality Assurance Surveillance #5188 dated 10/12/83 (Attach-ment I). The curveillance stated "per R. B. Klinger, CECO PCD, the Hunter Corporation application of inter-pretation #2 is correct." Interpretation #2 was a clarification of the turm inaccencible as used in the reinspection program. The Hatfield portion of Obser-vat' ion #1 was similar in nature to the Hunter item ani was closed by Quality Assurance Surveillance #5210 dated 10/14/83 (Attachment J). Hatfield researched the inspections termed inaccessible. Hatfield

. ~

response dated 8/4/83 to Audit 6-83-66 clarified that some inspections identified as inaccessible were actually not recreatable. In both instances, it was not possible to redo the inspections that were ini-tially performed. .

Observation #2 applies to Hatfield. Quality Assurance Surveillance #5211 (Attachment K) dated 10/14/83 docu-ments the fact that Hatfield determined that the fire-proofing had been removed and the original hanger inspection did include verification of the connection detail. The inclusion of connection detail verifica-tion with the proper inspection to be reinspected assured that this reinspection was properly performed.

Observation #3 applies to Pittsburgh Testing Labora-tery. Quality Acsurance Surveillance #4939 (Attach-ment L) dated 8/26/83 documents that after complete review of certification packages o! inspectors in-volved with the Reinspection Progr am that only one PTL inspector had two inspection cer:ifications. They covered visual weld incpection and concreto expansion anchor installation inspection. Only visual weld inspection was covered by the Ruinspection Program as concrete expansion anchor torque checks are not recreatable. Thus, there was no deficiency and no further corrective action was required.

l t

1 i

i observation #5 Part A applies to Hunter. In the case of Hunter, Quality Assurance Surveillance #5187 ,

l (Attachment M) documents the expansion of three i inspectors' data base to include all their work during i employment. For two of the inspectors, the minimum l sample size could not be achieved but were deemed acceptable based on the fact that all their inspec-tions of this attribute during employment were rein-spected and their original inspections of other attributes were found to be acceptable under the Rein-i spection Program.

Observation #8 applies to Hatfield. Observation #8 was a situation in which Hatfield was gathering data con-cerning an inspection which was actually not recreat-able. Conduit bolt torque could not be reinspected.  ;

i Bolt count was a portion of the original bolt torque inspection. Surveillance #5210 (Attachment J) docu-ments the fact that since torque checks were not with-in the reinspection program, bolt counts would also be excluded. Since the original inspector and the indi-vidual reviewing his inspection reports were no longer

! employed by Hatfield, there were no means available to identify which conduit bolts were subject to the orig-

inal inspection.

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

1 Q.22. When was Audit #6-83-93 conducted?

A.22. Audit #6-83-93 (Attachment N) was conducted between l November 14 and November 17, 1983.

l Q.23. What was the reason for that audit?-

A.23. The purpose of Audit 6-83-93 was to assure that con-clusions drawn from the Byron Reinspection Program were valid and reliable.

Q.24. Please describe the Audit Program.

A.24. For each of the 7 contractors involved in the rein-spection program a review was conducted of the a) correction of discrepancies b) expansion of an

! inspector's reinspection sample size and the number of I

j l

inspectors to be inspected upon a failure to pass the '

acceptance criteria, c) independence of the reinspec-  ;

f I

tion program reinspection personnel and d) accuracy of results reported in the Interim Report to NRC. Also, the design basis for the Sargent & Lundy evaluations of the vicual weld discrepancies, the qualification of the individuals who perform the third party review of i

subjective deficiencies and the adequacy of the basis for Interpretations established by the Project Con-struction Department were reviewed during the course of the audit.

i

1 l

l Q.25. What were the results of audit 6-83-93 as concerns the activities of Hatfield, Hunter and PTL?

A.25. One audit finding was applicable to PTL. After imple-l mentation of Interpretation 11, PTL had changed the i

deficient status of some welds that previously had received third party concurrences for true rejectabil-ity without allowing the independent third party inspector to concur or disagree with the changes. The i

completed corrective action for this Finding was the resubmittal to the third party inspector of the rein-spection reports that changed the deficient status of welds rejected for reason other than those addressed by Interpretation 11. Also, the contractors were advised to carefully watch that such second inspec-tions are not done without allowing the third party to i

concur or disagree. Thic corrective action was docu-mented in CECO Surveillance 5696 (Attachment 0).

I No audit findings or observations were identified for Hunter or Hatfield. There was, however, one minor misunderstanding by Hatfield regarding the timing of submission of confirmed weld discrepancies to Sargent 1

and Lundy for engineering evaluation. Any confirmed i

weld discrepancies resulting from this third party re-view were to be submitted to engineering for evalua-tion and disposition under a Commonwealth Edison non-

- - =. --. _

l

. e l

l conformance report rather than issue Hatfield defi-ciency reports. Hatfield deficiency reports were used to disposition objective deficiencies identified by the Reinspection Program. The use of a Commonwealth Edison Company nonconformance report insured that no

)

repair of the discrepant weld would take place prior

, to the engineering evaluation. Hatfield was document-ing welding inspection deficiencies on inspection reports and weld maps and accumulating them after

third party review. All weld discrepancies were being identified and controlled on weld traveller cards as well as being reported to Project Construction for inclusion in weekly computerized status updating of '

the Reinspection Program results. During the audit a Commonwealth Edison Company nonconformance report was issued to engineering covering the weld deficiencies identified during the Reinspection Program by Hatfield and confirmed as deficiencies by the third party reviewer. Issuance of the NCR insured that Sargent and Lundy engineering evaluation would be initiated.

1 a

A.27.

Audit #6-83-124 (Attachment P) was conducted between August 24 and September 1, 1983.

Q.28. Why was this audit conducted?

l A.2J. The purpose of Audit 6-83-124 was to versfy proper l implementation of Hatfield's QA Program as applicable to the QC Inspector Reinspection Program. This audit specifically examined welding and Hatfield's method-l -

ology of reinspection in this area.

l l

l Q.29. What was the scope of this audit?

A.29. The scope of this audit included the following:

A. Inspection B. Inspection, Test, and Operating Status C. QA Records The audit consisted of field and record reviews to l determine whether Hatfield had adequate traceability l

i of weld travelers to installations in the field. Weld l travelers are the document setting forth the basic characteristics of welds on a particular connection as well as its inspection history. The reviews were accomplished by retrieving weld travelers for a com-ponent from Hatfield and then going into the field to determine which weld travelers corresponded to which weld on the component. Since welcers identify welds on a component with a unique identification number assigned to them traceability of weld traveler to weld could be made. In addition, this audit reviewed the method that Hatfield used to identify hangers which

l had been reworked or renumbered so that a reinspection could be performed if required. This was performed by reviewing the inspection history of a component to 4 1  !

determine the completeness of inspection as well as identification of the most current inspection. ,

Finally, the audit was performed to verify whether Hatfield was properly inspecting combination cable pan hanger welds (hangers shared with the HVAC contrac-tor). This was performed through identification of ,

combination hangers, and review of installation and inspection documentation to support the installation.  !

I Q.30. What were the results of the audit?

A.30. As a result of this audit, two findings and one I i

observation were identified. The first finding was i

that in some cases the weld traveler cards did not adequately identify the weld in the field for inspec-tion. The second finding was that not all combination hangers had inspections documented to indicate con-clusively that the inspection was completed. The observation identified one hanger that was inspected and accepted to the wrong hanger detail, r

Q.31. What corrective actions were implemented for the find-ings and observation of audit 6-83-1247 l

. s l

i A.31. The corrective action for Finding 1 was to correlate I L

the weld traveler inspection data to design drawing  !

cable pan hanger data using computer data base manage-i ment techniques to demonstrate traceability of inspec- i tion. This use of the computerized date base identi- i y

fied the welders and inspectors who worked on and i f

l inspected the component as well as compor.ents not ,

inspoeted. For those components which for no correla-tion existed between component and inspection data, an inspection was initiated to complete the documentation and any repair requirements. This corrective action f was documented in Surveillance 5275 (Attachment Q).

l The corrective action for Finding 2 consisted of the identification of all combination hangers for which -

F i inspection accountability was indeterminate. The i

l hangers identified were considered never inspected.

i An inspection was performed and where required, rework was performed. This corrective action was documented in Surveillance 5274 (Attachment R). t The corrective action for the comervation consisted of  :

a reinspection of the identified hanger which was j inspected to the wrong drawing detail. When inspected i l to the correct hanger detail, this hanger was found l acceptable. In addition, a sample of 10 additional hange's whose hanger type had changed from the origi-l 1

O nal design were reinspected for acceptability. The results indicated that all hangers inspected were found acceptable. This corrective action was docu-1 mented on Surveillance 5276 R1 (Attachment S).

Q.32. You previously referred to an overinspection of the

reinspection program by PTL. What was the reason for this overinspection?

l A.32. A special Unit Concept Inspection was conducted, to provido an additional level of confidence that the on-site contractor's QC personnel were performing ado-quate reinspections under the Reinspection Program.

l l

l Q 33. Please describe the qualifications of the PTL person-nel who conducted the overinspection.

A.33. The rein =pection activition woro conducted by five (5)

PTL Technicians, who were qualified and cortified to  !

the requirements of ANSI N45.2.6-1978.

1 Q.34. How wac the work to be overinspected selected?

A.34. PTL wac inctructed to perform a samplo reinspection of the Atoms inspected during the reinspection program.

l PTL was instructed by CECO QA to randomly select the QC Inspector and randomly select QC activities for reinspoetion. The inspection was conducted in accor-dance to PTL's approved procedure.

. s Q.35. What were the results of the special Unit Concept Inspection for Hatfield and Hunter reinspection pro-gram implementation?

A.35. An evaluation by CECO QA of the results of the over-inspection performed by the Unit Concept group of PTL found the six contractors' inapectors to be within the acceptance standard set forth in the February 23,

! 1983 letter of response to I&E Inspection reports, 4

Number 50-454/82-05 and 50-455/02-04. During the l

! overinspection of Hunter, five (5) inspectore were overviewed and eighty (80) items were reinspected.

l The renuits are as follows:

Hunter Inspector Items Inspected  %-_of correct calls G. Inboden 19 100%

D. Sager 16 100%

i J. McVeigh 18 100%

S. Burstoin 17 100%

J. Lincoln 10 100%

During the overinspection of !!atfield, seven (7) QC inspectors were overviewed and 917 items were rein-(

cpected. The results are as followc:

Hunter Inspector Itemn Inspected %_of Correct __ Calls D. Opantry 259 100%

J. Moehling 98 90.8%

J. Mandurano 162 100%

J. Elgin 157 98.1%

C. Cavins 87 95.4%

D. Richards 68 100%

T. Wells 86 96.5%

o Furthermore, this independent check by PTL of the respective contractor inspectors provided good corre-lation of the acceptability of the reinspection activities, provided verification the contractors QC personnel were doing accurate and acceptable work, and provided added confidence that the reinspection results were valid.

i i

{ Q.36. What conclusions, if any, did you draw from the spe-

! cial Unit concept Innpeetion regarding any favoritism which might have been shown in the reinspection pro-gram towardo a particular inspector's work?

3 A.36. The special Unit Concept Inspection as well an the i

a results of audit 6-83-93 verified that the reinspec-1 J tion personnel for Hatfield and Hunter were not

)

involved in the reinspection of work that they had i

originally inspected. In addition, the reproducibil-ity of the results by PTL, whose inspection personnel l

had no known connection with Hatfield and Hunter l employeen, demonstrates that no favoritism was shown to any particular inspector during the reinspection j program.

l Q.37. Did the Quality Assurance Department have the results j

and qualifications of Inspector J. Moshling examined?

a

~22-

A.37. Yes. An evaluation was performed to determine if the 90.8 percentage by J. Moehling was an indication that his qualifications were suspect. A third party inspection was performed by the S&L Level III inspec-tor, as welding inspection is a subjective examina-tion. The result of the third party inspection found five (5) of the deficiencies to be acceptable. This acceptance of the welds by the third party inspector placed J. Mochling's correct calls at 98%. An addi-tional review was performed on J. Moehling's QC per-sonnel qualification /cortification package which iden-tified that he received a general education degree and had worked as a welder from 1972 to 1983. While work-ing an a welder, he obtained a cortification as an AWS Visual Wold Innpoctor in llovember,1980. After work-ing one (1) year and nino (9) menths with !!atfield Electric Company, J. Moehling was trained and certi-fiod as a Level !! Visual Wold Inspector, lie received scores of 90% in the specific exam, 95% in the Quality Annurance exam, 88% in the general exam and 97.5% in his practical exam. The review found that J. Moehling exceeds the minimum qualification requirements as a Level !! Visual Weld Inspector. Based cn the results of the reinspection by PTL and the third party review by Sargent & Lundy, it han been determined that J.

Moehling has adequately performed inspections within

the acceptable standard set forth in the February 23, 1984 letter of response to I&E Inspection Report i 50-454/82-05 and 50-455/82-04.

Q.38. Were the certification documentation packages of other  :

inopoctors of Hunter. Hatfield or PTL involved with c

the Reinspection Program examined?

A.38. Yes, where they failed. One PTL insporter involved in the Reinspection Program failed to achieve the Accep-tance threshhold at the end of both the first and 1

second throo month periods. His certification packago l was examined and in accordance with the reinspection program all his work was reinspected. A review of the cortification package four.d that he had received indoctrination and technical training and had success-fully pacaod the related oxams. Initial certification as a Lovel ! was based on the training and exams. The cortification packago was complete and accurate.

Q.39. Please describe the stops taken to assure that the j

documentation of the Quality Control Inspector Rainspection Program was accurato and reliable.

l A.39. I have previously described Audit 6-83-93 insofar as that audit involved review of the independence of the reinspection program reinspection personnel, and the accuracy of the results reported in the interim report i

.o .

to the NRC, and the reliability of the records so I addressed. Similarly, the special Unit Concept

, Inspection with its emphasin on reproducibility of i

resulta, was a strong indicator of reliable documenta-tion. I I

Q.40. Did the Quality Assurance Department undertake any other measures to ensure that reliable records were being maintained by the site contractors?

A.40. Yes. Since mid-1992 and continuing to the present, special attention has been given by Byron Site Quality l Assurance to actions by site contractors which could i lead to inaccurate and unreliable records. Training for detecting possible alterations to documents was conducted for Site Quality Annurance personnel. Lead Auditor retraining also covers this subject. Auditors have been trained to check for improper records as part of document review activities, even when specific l

l questions are not on the audit checklist. Indication of such checking in evident in the objective evidence established on the audit checklist. Cases havo been identified where records have not been properly revised much as the une of white-out which in contrary to procedures. There is no evidence that the records of certification of Quality control and Quality Assur-

l l

ance personnel and the reinspection program are in-accurate and unreliable.

As a follow-up of the two month CECO audit of over 10,500 records in late 1982 to verify the authenticity

{ of contractor quality control documentation, another related audit was performed by General Office Quality

- Assurance in early 1984 relative to the Reinspection Program. Hunter, Hatfield and PTL records were covered by the audit. One purpose of the audit was to ensure that no fraudulent documentation practices had occurred. The contractors' method of control and

, administration of QC qualification tests were re-

,, viewed, including reviews to verify that retests were

.e " done with a different test than the original and that tests and test answers were controlled.

In addition, calibration records were reviewed to ensure that information/date was unique, complete and not improperly altered and that signatures on docu-ments were original and by authorized personnel.

Reviews to verify that CECO Site Quality Assurance was checking contractor welder qualifications and QC Inspector qualification packages for acceptability and authenticity were also conducted. No fraudulent

, activities were. identified.

SL' s-%

e F

Q.41. As a result of the quality assurance activities which l you have described in the testimony, have you reached any conclusion regarding the reinspection program?

A.41. Yes. The Quality Assurance Department monitored the contractors' QC inspector requalifications and the Reinspection Program through audits, surveillances and meetings. On the basis of these activities, we have concluded that: (1) the Reinspection Program was properly implemented in accordance with the Program requirements, (2) the personnel performing the rein-spections were properly qualified and were not rein-specting their own work, (3) the reinspection results were properly processed and evaluated and the correc-tive actions for the deficiencies identified in the

-CECO QA audits were appropriate and adequate to resolve the audit concerns. It is concluded that the Reinspection Program provided reliable results.

Q.42. Please describe the scope of PTL's work at the Byron site.

A.42. PTL has been on site at Byron since September 1977.

PTL reports to the Commonwealth Edison Site QA Depart-ment and performs independent inspections, destructive testing and nondestructive' testing involving many of the key activities of the site contractors. The scope of work performed by PTL includes nondestructive test-

ing of welds, concrete testing, aggregate testings, concrete expansion anchor inspection and testing, soils testing, calibration, bolting inspection, etc.

The non-destructive testing includes radiographic testing of welding and most of the magnetic particle, liquid penetrant and ultrasonic testing. Site QA also uses Pittsburgh Testing to perform overinspections to check construction work performed and inspected by the site contractors and to perform surveillances of many contractor activities in the structural, mechanical and electrical disciplines. These overinspections by PTL are in addition to the QC inspections required to be done by the site contractors. These independent overinspections have been performed since about 1980, i

generally cover up to 10% of a work activity and have been concentrated in the areas of welding, electrical installatione aand HVAC installations. The purpose of these overinspections is to provide another level of confidence that the field work and the inspection activities by the contractors have been done accepta-bly. In September-1982, another form of inspection was added by Commonwealth Edison Quality Assurance to the work scope for PTL to perform each week at Byron.

i This new inspection is called " Unit Concept Inspec-tion" ("UCI"). PTL uses a team of inspectors who are qualified in various disciplines per ANSI N45.2.6. l 1

(1978) to inspect items installed within specific spatial boundaries or in conjunction with specific equipment for compliance to vendor and engineering documents. This inspection encompasses all contrac-tors who performed work activities within a given area. These UCIs are also in addition to the normal inspection and the specifically directed overinspec-tions performed on site.

As part of the Reinspection Program and as described above, PTL was specifically directed to perform a Unit Concept Inspection to provide an additional level of confidence that the contractors' QC personnel were performing adequate reinspections which is discussed previously herein.

Q.43. Please describe the extent of the Company's quality assurance oversight of Hunter, Hatfield and PTL since the close of the record in this proceeding in August, 1983.

A.43. Since the close of the record in this proceeding in August, 1983, our program of audits and surveillances continued to be actively and intensely performed to identify problems, ensure requirements are fulfilled and verify inspection and testing of the facilities were performed, reviewed and accepted by properly

. o l

qualified personnel. The frequency of the audits and surveillances for these contractors were nearly doubled during the period.  !

In the case of Hunter, Commonwealth Edison Quality Assurance conducted fourteen audits and at least 142 separate surveillances of this contractor since August, 1983. The auditing coverage included the key aspects of Hunter's work activities and Quality Pro-gram requirements as was the case for the other site contractors. Coverage by these audits included, for example, whip restraint installations, handling, stor-age and shipping, nonconformances, welder qualifica-tion testing, inspector qualifications, the Reinspec-tion Program, design and installation methodology, control of Field Change Notices, concrete expansion anchors and bolted connections, equipment installa-tion, corrective action, auditing, piping and equip-ment component support, installation and engineering activities, document control, Quality Assurance _ Pro-gram implementation, etc. The results of these audits demonstrated exceptional performance on the part of Hunter in view of the extensive scope of these audits. Of the sixteen (6 Findings and 10 Observa-

-tions) deficiencies identified, none were f,ound to be

significant and only required minor corrective

t l

I action. The deficiencies weto closed by audit close 1

out surveillances. The (142) surveillances performed l on Hunter involved such items as personnel qualifica-tions, calibration activities, welding and weld rod control, housekeeping / storage, inspecting and walkdown activities and installation activities.

For PTL, eight audits and at least fifty-one surveil-lances were performed since August, 1983. The audits covered PTL's work -activities involving such areas as: tool, gauge and instrument control, calibration activities, c o r re ctive,p.c tio'ns , trending, inspectionc of electrical installati-ons, document control, test /

inspection reports, visual weld inspections, handling, storage and shipping, procurement and material con-trol, the Reinspection Program, QA records, auditing, radiographic and ultrasonic examination, etc. These eight audits identified ten deficiencies (4 Findings and 6 Observations) requiring corrective action. The findings involved an inspector incorrectly accepting seven two-inch welds, a receiving inspector not being certified, white out being used by one person on sam-ple logs and documentation on a Ultrasonic Test Records not being complete. The corrective actions mainly involved retraining. The fifty-one surveil-lances of PTL covered such items as calibration

~

-+

i l

f 1

l l

cation errors, inadequate identification on weld traveller cards, lack of inspection of combination hangers, improper disposition of Discrepancy Reports and failure of certain QC Inspectors to perform required read / study activities.

The corrective actions consisted of additional inspec-tions, auditing, training, review of personnel docu-mentation packages and review of Discrepancy Reports to assure proper disposition. Acceptable corrective action has been achieved or is underway. The two hundred twenty-two (222) surveillancer performed on Hatfield involved such items as corrective actions, personnel qualifications, calibration activities, document control, welding, inspection reports, instal-lation activities, design change control, etc.

The Commonwealth Edison Quality Assurance audits and surveillances of Hatfield Electric have examined and evaluated applicable areas of Hatfield's Quality Assurance Program. These audits and surveillances have identified deficiencies which resulted in correc-tive actions that improved Hatfield's performance and

, QA Program implementation. Overall,'the quality assurance implementation by Hatfield during this t

period has been acceptable.

]

m activities, personnel qualifications, ultrasonic, radiographic, magnetic particle and dye penetrant examinations, visual weld inspections, document con-trol, material control and civil testing activities.

Overall, the findings and observations did not have significance, and the corrective action were easily achieved.

Hatfield was audited fourteen (14) times since August, 1983. Also, at least two hundred twenty-two (222) surveillances were performed. Special audit and sur-veillance attention and emphasis was applied to Hatfield during this period to ensure requirements were being fulfilled. The audits covered Hatfield's work activities involving such items as welder quali-fication testing, material traceability, procedures, inspections, auditing, personnel qualifications, cor-rective actions, training, installation activities, calibration activities, records, fire protection, the Reinspection Program, storage and housekeeping, field change requests, design control, document control, etc. As a result, seventeen (17) deficiencies (7 Findings and 10 Observations) were identified by Commonwealth Edison Quality Assurance. The findings involved audit. follow-up and objective evidence i

)

omissions, personnel qualifications and certifi-l i

I l

J , D j

i ( n .- -

/ (

1

+d BYRON SITE O. A. SURVEILULNCE i

h. QF: 2790.22.2.1 ,

Report No'." $

Date: 01/21/84 Contractor / Organization : Hatfield Electric Co.

SUBJECT:

Reinspection Program Results OBSERVATIONS:

Reviewed the tallying of the " reinspection" results for Peter Lanes' .

first ninety (90) days oc inspections after his certification in the visual welding area. This review entailed a review of the reinspection record and the third party concurrence for 20% of the Weld Travellers to verify that the numbers listed were accurate. those items reviewed are highlighted on the attached list. With the exception of Weld Traveller 22438. the results given were accurate. For Weld Traveller 22438. the number of welds rejected by the HECo. reinspector total eighteen (18) not twenty-eight (28). The correction has been made to the data base. Sts error did not impact true rejectability as determined by the third party.

This surveillance is closed.

Reported by !i Rrt- Date/.IS-M Approved by h. 16 Dated.r4,b4 .

LAS:tj:16475 pf Attachment /~

cc: W.Jr 5h /G.F. Ma

- QA Supt./ Site Q.As Fil h kqy I

Contractor PCD Supt V I t.AS T t

I i

l l

Attachment A l

A

[ . .

TIME: 3:00 P.M.

DATE: 01-20-84 WPS 10.00360 PETER LANES - 1st 90 Days _ _ REJECTED b

W/7 Amt - MECa Rei Third Party Inspection Date # Cds Comments

/T304104 6.  % 1 79-02-26 1 2 V 's > ** 3/ (J J />-U.. Va 1 27711 39 1 1 79-03-05 1 31026 12 7 7 79-03-05 1 22359 4 2 2 79-03-06 1

-f23606L 2 1 1 79-03-06 1 32028 20 1 1 19-03-06 1 22686 4 1 1 79-03 07 1 31944 18 0 0 79-03-08 1 28301 30 15 14 79-03-10 1 vff374c4 8 6 4 19-03-12 1 22455 33 2 2 79-03-17 1 2/010 39 1 1 19-03-13 1 27023 20 4 4 79-03-13 1 28226 4 1 1 79-03-13 1 Ef353?K 6 2 2 79-03-14 1 22355 8 2 2 79-03-14 1 22460 4 2 2 79-03-14 1 22690 4 3 3 79-03-14 1 23479 2 1 1 79-03-15 1 418610A 4 2 2 79-03-15 1 22461 18 7 7 79-03-16 1 20442 8 1 1 79-03-20 1 26678 6 1 1 79-03-20 1 2J851 4 3 3 79-03-20 1

@ OO80A 21 3 2 79-03-20 1 27009 26 1 1 79-03-20 1 28115 4 1 1 79-03-20 1 28136 4 3 3 79-03-20 1 28)45 1 1 1 79-03-20 1 tr24774K 5 2 3 79-03-22 1 22481 7 2 2 79-03-22 1 22482 4 2 2 79-03-22 1 23380 10 4 4 79-03-22 1 22J66 12 4 4 79-03-26 1 V26050K 8 1 1 79-03-26 1 22665 8 2 2 79-03-26 1 27669 6 3 2 79-03-27 1 22601 24 2 0 79-03-28 1 22603 12 1 0 79-03-28 1

.rf40286 8 1 1 79-03-29 1 27491 2 1 1 79-03-29 1 26854 6 3 3 79-03-29 1 27247 8 1 1 79-03-29 1 28955 11 3 2 79-03-29 1

.28'9570 A- 0 0 0 79-03-29 1 4WLSee W/T 29012 29039 8 1 0 79-03-29 1 22606 8 2 2 79-04-02 1 22439 12 2 1 79-04-03 1 2)2 94 4 3 2 79 04 03 1 42502cA 10 4 4 /9-04-03 1

• - THESE WELDS WERE REPAIRED BEFORE S/L COULD GIVE AN EV4LUATION.

A-2

TIME: 3:00 P.M.

, DATE: 01-20-84 '

WPS ID.0036D _

PETER _ LAN_ES - 1st 90 Days _- REqECTED W/T Amfg . HECo Rei Third Part_y Inspection Date # Cds Comments 30892 .6 .2 2 79-04 03 1 9 1 224o9 e 4 / y -ug-v a 27499 2 1 0 79 04 05 1 l

22500 12 4 2 79-04-05 1 SE35320ML 4 2 2 79-04-05 1 l l

26513 24 1 1 79-04-05 1 l

28966 11 4 4 79-04 0's 1 28968 8 2 2 79-04-05 1 29011 8 8 7 79-04-05 1 vf0725pt 8 2 2 79-04-06 1 2901208L 8 7 7 79-04-06 1 23367 6 7 2 79-04 09 1 23371 16 2 2 79-04-09 1 233/2 6 2 2 79-04-09 1

-233730A 4 1 0 79-04-09 1 23531 16 8 8 79-04-09 1 20724 8 1 0 79-04-10 1 29010 40 2 3 79-04-10 1 29033 10 1 2 79-04-10 1 216500A 8 2 2 79-04-10 1 22495 4 3 2 79-04-11 1 22696 8 4 0 79-04-11 1 22504 6 6 4 79-04-13 1 26782 16 2 2 79-04-13 1 ff8500A 28 #T'a-j'#p" 4 3 79-04-13 1 26855 16 5 5 79-04-13 1 29034 8 1 0 79-04-16 1 23376 16 3 2 79-04-17 1 23534 4 1 0 79-04-17 1

-f'66920A 11 7 6 79-04-17 1 26693 14 6 6 79-04-17 1 26780 33 5 4 79-04-17 1 27063 12 1 1 79-04-17 1 28046 6 2 0 79-04-17 1 f7696W4 21 1 1 79-04-19 1 27697 8 1 1 79-04-19 1 27698 32 2 0 79-04-19 1 22582 8 1 1 79-04-20 1 26847 8 6 5 79-04-20 1

&fB062cA 2 1 0 79-04-23 1 28064 6 3 1 79-04-23 1 28965 8 / 7 79-04-24 1 28993 33 6 5 79-04-24 1 2J372 11 1 1 79-04-25 1 11651or( 11 2 2 79-04-25 1 21676 16 1 1 79-04-25 1 26515 2 2 1 79-04-25 1 26827 20 5 4 79-04-25 1 2 057 20 1 1 79 04-25 1 1//020F* 14 3 3 19-04-25 1 29393 8 3 3~ 79-04 25 1

• - THESE WELDS WERE REPAIRED BEFO2E S/L COULD GIVE AN EVALUATION, A-3

TIML: 3:00 P.M.

", , DATE: 01-20-84 WPS ID.0036D PETER LANES - 1st 90_ Days _- REJE.CTED A

W/T--- Amt MECo Rei Third Party Inspection Date # Cds Comments _

29399 10 '6 6 79-04-75 1 l'an i a bS b 4 / >. U4 / *> 1 l 296360L 241 36 19 79-04-25 1

.2963786- 0 0 0 79-04-25 1 06500 W/l 29636 29639 16 3 3 79-04-25 1 29640 0 0 0 79-04-25 1 Sec L/1 2963(

29647 8 5 4 79-04-25 1 20727 8 2 2 79-04-26 1 622210D#- 2 2 2 79-04-26 1 22211 4 2 1 79-04-26 1 22212 4 2 1 79-04-26 1 2??98 2 2 1 79-04 26 1 22299 4 4 2 /9-04-26 1 6262220 4 3 3 79-04-26 1 26226 2 1 1 79-04-26 1 29391 7 2 2 79-04-26 1 29662 9 1 1 79-04-26 1 2 p16 10 3 3 79-04-30 1 46684 Cfs 4 1 1 79-04-30 1 26818 6 1 1 79-04-30 1 27710 33 1 1 79-04-30 1 28981 17 11 11 79-05-01 1 22Q16 30 2 8 79-05-02 1

-?f020N' 4 2 2 79-05-02 1 22832 4 1 1 79-05-02 1 22834 4 2 2 79-05-02 1 22842 2 1 1 79-05-02 1 26815 6 4 4 79-05-02 1 62631706- 10 2 1 79-05-02 1 26819 8 1 0 79-05-02 1 26820 8 1 0 79-05-02 1 27706 12 2 2 79-05-02 1 28980 8 1 1 79-05-02 1 w?6692C(. 8 1 1 79-05-03 1 20723 8 1 1 79-05-03 1 20732 11 2 2 79-05-03 1 22886 13 1 1 79-05-03 1 26860 16 14 14 79-05-03 1 HTf367DK 8 4 4 79-05-03 1 29656 0 0 0 79-05-03 1 See W/T 29636 29658 0 0 0 79-05-03 1 See W/T 29636 26541 8 1 0 79-05-04 1 26646 16 1 1 79-05-04 1 rf705 CP( 15 4 4 79-05-06 1 21371 8 2 2 79-05-07 1 29231 11 3 3 79-05-07 1 29233 19 8 9 79-05-07 1 2)7 16 4 3 2 79-05-09 1 (20130F

• 2 2 2 79-05-10 1 22014 2 1 1 79 05-10 1 23991 8 1 1 79-05-10 1

• - THESE WELDS WERE REPAIRED BEFORE S/L COULD GIVE AN EVALUATION.  ;

A-4

TIME: 3:00 P.M. * . DATE: 01-20-84 WPS 10.0036D PETER Lf NES - 1st 90 Days _- R.E3ECTED

' # Cds Comments W/T Amt Co Rej Thip Party Inspection Date 23993 80 -

12. 6 79-05-10 1 2s995 4/ 4 4 /v-02-10 1 J4648 7 5 4 79-05-10 1 29649 8 2 1 79-05-10 1 29652 8 3 3 79-05-10 1 33862 3 3 3 79-05-10 1 22795 8 3 2 79-05-11 1 M796 clL 8 4 3 79-05-11 1 27799 6 4 4 79-05-11 1 20661 8 3 1 79-05-16 1 22840 4 3 3 79-05-16 1 29651 6 1 1 79-05-16 1 4653CL 8 2 0 79-05-16 1 29654 6 6 4 79-05-16 1 33866 6 1 1 79-05-16 1 21674 10 2 0 79-05-17 1

. 22024 20 3 2 79-05-17 1 42T)26tA 2 1 0 79-05-17 1 22028 8 3 3 79-05-17 1 22388 2 2 2 79-05-17 1 22389 2 2 2 79-05-17 1 22397 6 6 6* 79-05-17 1 a fs980lb 12 12 12* -d#F- 79-05-17 1 22446 4 4 4 79-05-17 1 22447 2 2 2 79-05-17 1 22448 4 4 3 79-05-17 1 22449 2 2 2 79-05-17 1 WFi5b k- 2 2 2* - d dd 79-05-17 1 22452 2 2 2 79-05-17 1 22453 4 4 4* 79-05-17 1 22755 10 3 2 79-05-17 1 2 2 2 2 79-05-17 1 2J89 4 3 79-05-17 1 77683CN 14 37356 8 8 8 79-05-17 1 37360 10 6 6 79-05-17 1 37367 3 4 4 79-05-17 1 24 2 2 79-05-18 1 2f18 79-05-21 1

%;rl .ir23911,DK 14 27127 20 6

3 4

2 79-05-21 1 27682 32 4 4 79-05-21 1 37363 16 2 2 79-05-21 1 23 82 34 5 3 79-05-22 1 983 % 113 9 6 79-05-22 1 26946 2 1 1 79-05-22 1 29666 8 1 1 79-05-22 1 37357 16 4 4 79-05-22 1 37358 16 4 4 79-05-22 1 v37362bb 12 4 4 79-05-22 1 21625 16 3 3 79-05-23 1 21647 12 3 0 79-05-23 1 2167/ 10 3 2 79-05-23 1

• - THESE WELDS WERE REPAIRED BEFORE S/L COULD GIVE AN EVALUATION. l A-5

TIME: 3:00 P.M.

9 . SATE: 01-20-84 WPS 10.00360 PETER LANES -_Ist 90 Dayt - REJECTED 4 Comments Co Rei Third Party Inspection Dale # Cds bi][

j 224387 3 ,' X#ll , g,u-t418- 9-05-23 1 vf7bOOoK 8 ," $ b ;^ - '*/9-0S-23 1 27117 4 2 2 ks 79-05-23 1 27118 6 6 6 8 4M 79-05-23 1 27122 6 5 4 79-05-23 1 27123 6 4 4 79-05-23 1 v47130C#- 4 1 1 79-05-23 1 27207 8 3 2 79-05-23 1 29638 24 2 1 79-05-23 1 29659 6 4 2 79-05-23 1 29661 8 1 1 79-05-23 1 2.646 700 5// 215

• - THESE WELDS WERE REPAIRED BEFORE S/L COULD GIVE AN EVALUATION.

A-6 .

7 g' BYRON SITE O.A. SURVEII.t.ANCE [f5[

y QG: 54.3 f/

Report No. 5700 Date: 1-23-84 Contractor / Organization : Project Construction Dept.

SUBJECT:

Reinspection Program Interpretations OBSERVATIONS:

Quality Assurance has reviewed Interpretation 19 issued by the Project Construction Department to be used in the implementation of the Reinspection Program. In light of the information supplied (attached), this interpretation is reasonable and will not affect the validity of the reinspection results.

This surveillance is closed.

Reported by :_ ,f . 4. - Date / f ' 'J Approved by K'.' d t. S Vf Date i. r.r4 V

LAS:jc: 1667S ,,

~gv cc: W.JbewskUG.F. Ma (' I QA Supt./ Site Q.A. File, Contractor PCD Supt k

gej \ h[ l LAS Attachment B e

u

h N l

hbdC L

. ammuumummu r . .

... . '.f. . .., w -

• ( HUNTER CORPORATION u '-

y: . ye s it -:. . : .: .: :. . a:. .. ~. \

Q HC-QA.485 b l I g-16 83 Decemb0r 15, 196.i h l,b Commonwca!Lh Ldison Conceny y 4450 North Cernan Church Road Byron. Illinois 61010 Altention Project Construction Department R P. Tuetken Assistant Project Superintendent Subject- Interp elation for N C Reinspect;on Mr fuetken.

The Hunt 3r Cor;; ation requests the folle.;r.g interpretation.

Interpretation No 1: Is it acceptable to use 2.3.2 and 2.3 2.1 fr;- tWS 01.1-82 for the inspection of fillet -elds' InterproLstion No. 2:

( Attachr?r.ts 2. 3. and 4 indir.ata the accurm y c f the welding 933.'s we use for the measuret2nt ci fil 3t si20. As yCu can s:'e the best they can e f fer is

+ .02d" Teleph.'..e carre-sation with C cc.;. Ly:c-President of the GA, Gage Co Ind:cate: th;t t* r+ are no cc?r.orcially T.anufactured gages that are mcre accurate than his Co ; ariscn of his fillt: 9.y. n a'3ainst like gages ma Fac;ur d by ~i':r ? "' T '. :.?

sh0wn differences of up to 0 C liere't 0. u s '. g s;miliar gages iil it ';e acce::::12 to f : -d a c, # 1 1 '. o :

weld up to 025" ur:c-s;:, a;c:p. nic .- cr ; r. e '. ; ;

reinspection progrr.7

't , .

-

• b -

a'-*gis(\

Yours very truly Ny -

L" u p d * ' c .t. l i 's i s b .s. h';.' i h \ \ a d. ~ \ .  : 'a 2

% . / i .

an$ , 3., ,

t , , ,, .-. ,g . - 3 Lt.E E. HADICK Quality Control Supervisor L g ,, Q , g b

- .s - . s .., ec.33,. .t-O i t 4 cc:

m . s\..t b w.4 3. a ~ > 1.

0 3 % ., , . -

M.L. Sc.tsag .

K. Sciran vac

..,h .ss. . . . - A c..

) .,2 CA Vaull a

r 4

4 ...I). 7 :d

/?. . ( s . 1

• a s s i q;, . g

. sa . s s...'t.* ..es.

% ( e 'p*

LEll/pb #

.. f M\ . ,;... ... s. ., a %

/

,C t

• v. 3. = %

e -

< c. 6. . . . ./ . i , grm. ,. ,,,.s ~ je a qo ,w'

-:..; .s s.- -- . .

B-2 ,

m

.~ Ti s u T s. Q.,. L,.u 'c *. a. s w L: LC k *$ '#5 Y W- N iWL t -hA% dl. l- 62 $ l V' -

4/DEsics or % Etero CoutcTioss 9 T PV. H A ve ' ' i- (

t I) hasing an meluded angle of 60 de; or greater at nom:nal area Of the hole or slot in be p.ane et be :ay:ng the root of the groose when depouted by any at the surfa; followmg weldmg processes. shielded me:al are. sub- ,

merged are. gas metal ar;. flus cered are. or eie;trega-

. 3.4 The effe:tne throat of a comb:nanan es a. ;0:n:

weld:ng. or penetranen groese wel.,, and a fil!ct weld 'ta.: re :ne (2i hasm; an m:iuded an:le not le>< than 45 dec at sho~eu is:ance from the root to tne face < : :re lagr2m.

. man weld m:nu,15 m 3.> mm+ f0 m ; c.me ::.:.

the root of the groase unen depe,ited m :,.at or henior.:ai reqamn; su.n ded.:: tion nee A" enis A.

position > by pas me:2! at: Or rius ;cred are weldmg 2.3.1.4 The effectae threa: mickness for flare pr00se welds shen ittled :L:sh :o the sur:a.e of the 30!id >e: tion of the bar shau be 23 shown m Tabie 2 314 e Ii Random se:: en of proda:::On welds f0r each weling precedure. or su:h ten e:nons as may be re-quired by the En;:neer. sha de u ed to senf> tha: tce effe::ae threa! .* on a:en:!) co:amed t2i Fer a gnen se: c: pro:: aural :0ninen . it :ne con:ra tor ha demens: rated ma: ne ;an co . nten::3 p 0 ude tar;er e!f t::ne :nv.c ma . :ne : t3sn m T.: .e Part 8 2 314. tne con:ra:ter may estar::in sa:n .arger e: fee:ae .

tw..

... 2: . q . .. .. .. .. . . t e.,. Structural Detmh g i3, Quani::anen req.: red by O sha:l cen t cf secuemnp the ratased mette no-:2! to it as. at h

I m:dien;m and :e mma: end3 cf:he we:d Su; . >ee:.orm; 2.4 fillers sha:1 be made en a namrer of ;0memanen> 3: ma:ena sizes represertatae Of tne #.pe 23:4 ty tre contra;:Or :n 2.4.1 F:::ers mas ce u ed m constru:non or a reaa: red by me Engm:er 2.4.1.1 Sri:: Ire pa 0: 6: eren

~

.sne- :-

2.3.1.5 The m:n;m;m e::e; e tnr0;.: 0: a pr.2. e :n- 2.4.1.2 Cerne:nens :nat Jae 0 es: ~ ; se: e -

.L

( pere:ranen 10 .'

grocse we.J ,n2:i re a *pec :.e4 .n Ta-:e 4.:nme-: ma t a::0mmodre c::e fram:rg re- r.:

2.3.2 Fi!!ct Melds. Tne e":. e area >ha3 de me e::.. 2.4.2 A : ::er :es mar : 2miel-- a 'ne -' '

ine ae!d !:ng2 mah:pi.ed r3 me e:it; se :nrer Str:

• used t0 uancer ue> r2: >n..: re i pt :.an " m ne m a fiMe weid sna" be :0nsidered a apphed :0 :na we.Je: edges of the tress..a-.e; p:r Tne ::e Of

@ efte::ae area. for an.s 6_:: .On 0: a phed icad t me.d> a:0n; sa:n ed es sha!! Se m;rea ed Net me re-2.3.2.1 Tne effe :ne leng:n of a fillet weid sha!! be:he qu: red sizes by an ame.n: equa. :: me T..~.re c ne -

os er.1.: ien;;h of the f;!!.s::: f: lie- a:! air:; end re:u- - fi;.::.see F:g 2 ; h No reda nOn :n effe::n 6-' a:: de made for :::her n .

the s:a-: or crater et te we.J :f tne wel a tu.. >ize . ..

-' a 3 Ara. *;P"* - i 4 in 4 6 mm. er . re .: :t.ar. -

th.0...

. ...s.,.,.its1.. . . . . ..

.. . _ ~ sh l estend Deycnd me edi;) N me ' '-- p I' Ci M

.s. '.... w.

.m ..L..a. . ..a.s.......e

. . . . . . e.. e 4 .".

<i.e e. u ...

.i ta+..

ne:ren crer:2! It >han. Sc we:de ,'c me 74~ Jn ^n J' F m.,., u ...a.-. , . .n. ,. ..... .r .. .. ....= t n . ..e.-.n ... .e . w...m . ,a. .

6 fmed. and tr.e .ic:nt scall be et 3r: :::: suen;m :0

. .a e . 4 .,a l . .... .. .,.' 2 . .e. r.. , w e -

.r a ...o, e i,,. s.0: s.e.. .....

t anc.'!. :he spi.;e p;, ate er co .r:e;* 0n C+.e w.  :::"

apphed r n e >udace of me . ,.uera a-e = . m .,

from ten ten *- is grerer :ne :re sea :0and : rem : 3y then tha lat t area sna:: Se u ed a :r:e eMe :3e ares e: Tr" "'A' ""e rm- n *-h:' *",. ate er e0.n nen mate':al gg f pg, gg,j 10 Ze nU'r5:J2 De C :.; eeI U n# I. 'e N *e Of #'# #

. 'IaE','.'A..i.'.,,',...

1. ""'i ' ## " 3 '. . . . .' ' " ' " ' ' ' " ' " - " " ,

2.3.2.3 The mm: mum enectat Wr:m 0: a : '::: weid

- sha!; or at few :Our nme me nc m. tie or tre a: a'"id ?Wr'ne"inJ Zd ! " i " # d " C '##

l.'lN the aeid nail N :On >:Jer.d r. t f.' e*.e:J ene :a. . :t- 4.#'

ette;:ne len;tn 2.3.2.4 Tne :::.. .e rea: naa N me ner*e : da tance t Om tne root ot :ne :2.e See AppenJa A S. te See Arper.e. H :a tem a.'

nc e .;r.immat. we.J 2.5 PartialJoint Penetration Gree l gosem.n; the calcula:...n 0: er:..tne inreat ter !;i!:t Welds I I

we:d m dewed T~a:nt- A orn.c ent teu.. ten ot rnea ureJ Ic ; Pa%: ioint pent ration gree we..' ~.. :e . n

'M ',and ;..pte., ;; ; G. re:a:ed io nerna! to the. ian;;:LJma! asi rw n. : : a ed <cre ette ...ae ttroat* i s .a eeen pra.Jed :or o.le r.! an;ie-t'etween ev d;j anj lM Jg.," d; :; .riter:a indi. te eyJli; loaJ: i . 2 P.'J... la-t:;;c :ai. art lo:nt oma n:n; a.r ..e J. nad-e -,

h 2.3.3 Plug und bl.it Wid>. The er ;tae area ta!' 5e tte one :Je ona. tai de restram d : ' cresen  :.ti -

B-3

l rr u ,;..er o 3 G.A.L Gage Co. 3

h. w n. ,~

(

d Post Office Box 23 1 2953 Hinchman Road N l Stevensville. Michigan 49127 fuc .3 -

616 465 5750 d

cce er 23, :.se2 Mr. Lee Had; k c/o Hunter Corp.

,. c. ,cx Eyran, IL ticic 52::ect: 72 Iar:;al Se:s 7:11e: .;eli Sa:e F. C. 42d 5:C3

Dear Mr. Hadic.e,

7:.e ranuf actures ::lerance Of ne Fille: Wel: G ag e 0.. i:::

F. C. a 26 50:3 are w: th.n the .025- range.

( Tr.e weld;n; gage 1 intended f:: general d. sns;:nal :.nsre :::n

f welded f ahr; at;:n wnere c1:se :leran:e are n:: e peete:.

It sn:ald :: de ::rpared n pre:;s;;n v;:n ; ares vne:e a :::r de;:ee :E a::::::y is req;irei.

Sincere;y, G.A.L. Gage Cc.

~

, w w..d ~ Ll .,.]

• /

GC xfw;n A. Lycan Fres; dent GAL / :k.-

.g.

WANUFACTUR[R$ AM 30'1'!i!!3'!

0F THE "HtLO" 100L FCR fif O's MELDER $ GAG [ AND RADIOGRAPH [D R[LO$

B-4

• r l G.A.L. Adjustable Fillet Weld Gage

%(

MEASURE ANY FILLET WELD To b2" ACCURACY

$.) WITilJUST ONE S MPLE-TO-USE GAGE.

Measurmq idlet wek!'. used to be a h s.tl ilie G A L Ail ustat l le f ahet Wehl Gage 3?n:Is with inrtor coinvalents given so you guni:tre m posituin for future reference 11 the t with comphtated or en.sttuiJte QaQP5 Nul n'.es an oilsel asm wiurh sinles at a 45 angle get sinne .u tus.ite se.e.lvi'r. Itius scicws t'fA3 vr"Itl v. e neu ave, snose lifics m.itesial t.m be g _7 anymote Now you can nicasuie fellel wek15 to m.ike htirI weki lein;iu siv:.isuerments the oil .rl asin in po .ihori lor lutute achteil lie luuhl the wekt throat up to st.init.pd

• g ,

llom Fe" to t * (weth

• Yif arcutxy) with Supply ailiusi llic .orm untelil lourhes the loe adjustments llu'G A L Aalust.shleisihrt l Weht Gaoe ts one economacal, supple to taiderstand gage of the vetiscalle0 Ibe? g.sge 35 cahbrated to lhes gage also me.tsusa . welit throal an.nle of slutable. rust rev.t.ent St.iinkiss steel 3- thanesses to it . r . 3 sinn ese.nin weighs only su oi .

g G.A.L Adjustable Fillet Weld Gage is easy to use. =tPlunldil inPaslHPInPfils jHHn

> = M': %'0 2="

I le (h4nle Dl lUsHly c'.sefilial F  % kHM fu's flee Crtitel lith t *chl yJyc blades is cluninated l uanbhng

,1 g x ,

) Meseem M 80 t (sea ' 7, M t dim'! - N of lH! Wold A thumb thenugh seven sjellefernt. attaccusale gage mg m u #. g,,,, , , , , , ,

!d scw hold 5 the blJde5 45 also eluntnaled

' i

-m -1 _ _ _ _

. " . .,". ** h  %

e.

& ~

..gs#

99;,

pak

-*g

- ***

• mi, ,, p g, a 1. / f e' l 9 N la measure hNel nelas platt ettequi.x cut >t AJ,ust I!re all598.etits sip oc <!an's .ti u1Q t lle.M the nekt .o.* untn aled Ihe tL*gt llush to hotoontal tot of neld 50 the the daannnel slots

• rlal the tro e I the not rements .soe u.

• oe anst *s'maahangs up straoght t'igt r$ nes hnt wdh the hontorslal aten10uLhts the100 Of the ntM la I

• Allmurort.et. Ane ett hett wola Ilot .

memtme* surtale am*Ialra too e.nwt scathng q.

~#'* *

['{ ^ 1 'l n M 'S? e ,,,..

9,- s,. .

(

' g, -

, p 64 II S patents pend.rus -

LfL ' G tqcs ; v.ol.itale tbrough l f yo"f v.Pd:14 w.pp8y l distributor or runt.nl - ,/ I I GAi 1Q Intasult etU tht0JI thdotss plaCt lighten the thurnh slice as.<lstadI!ne q Adl uslJhle fillel the 45 ' angit end flush to the hocyantal turbsurement hans the ' e 1ahtuat'ons e e e Weu G399 nurasures both and verbcaln embers loosen the a'ong the poonter A quoi n. s ne e ny la 1.sul leglengths and neld fluoat it,ottab stitw and sirdt the 90 salt! Unbl coners 09 totX. eve neMs anet la lot tril follet meld thdnes s

~

• 09 touches theIJCe 01the atId intin nulh addet:0nalhilcf malenalla meet 5'J'"8d'd5 P 0. Bos 23. Stevensville. Maclugan 49121 Telephone 616/465 5750 TLLEX 729453 G.R GAGE SIVL cissa.e a a ess.c.

l b

t____ . _ _ _ . _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _

a-

,~~

,- f, 9 M 4 i ij

{ i  !

M( ,o 4 J ~G=

WELDING GAUGE IMPORTANT NOTICE The Welding Gauge is intended for geretal dimensional inspection of welced fabricaticrs where c!ose tolerar.ces are not expectec. It should not be comparea in prects;on with gauges usec for measuring macninec com::enents anc. where a

( high degree of accuracy is recuired, rnacv.e stec type measuring inst'uments will need to te used.

The Weldirg institute Abington Hait Cambridge CB16AL c1.Bc l

1 l

L l l

l B-6

BYRON SITE 0.A. SURVEILLANCE )

l QF: 2790.22.2.1

- Py .

i Report No. 5753 Q f

Date: 2-02-84 Contractor / Organization : Hatfield Electric Co. i

SUBJECT:

1. Document Control

2. Installation Activities OBSERVATIONS:

A surveillance was conducted at Hatfield to document the issuance and processing of field problem sheets.

Field problem sheets are written by prodJction to Hatfield Engineering Department, describing problems encountered in the field which cannot be installed per the design document. The equipment has not been installed and the foreman is asking a question. "How should I install it". Problem sheets are categorized by drawing area.

These field problem sheets have suggested corrective action. such as: a drawing or drawings may be changed, an FCR may be written, a DR may be written if it pertains to a drawing error or it may remain as is, g DR's and NCR's are written by the QC Department after work has been completed by production and the equipment has been turned over for inspection. A DR is written to document a deficiency in which the installation is not per the drawing. If the foreman cannot rework the deficiency into an acceptable conforming item a HECo. Nonconformance Report (NCR) is written.

Field problem sheets are not used in lieu of a DR. Copies of field problems may be found in QC but only as a reference document. No QC inspector signs these field problem sheets. Deficiencies are documented using the DR and NCR system proceduralized in HEco.'s Procedure #6.

Twenty-three (23) field problem sheets were reviewed. Of these twenty-three (23), two (2) field prob m sheets referenced a deficiency report. Fifteen (15) field proble sheets are attached for reference. All were found acceptable.

This surveillance is el .

v 5

^ ' ~

' ~~

Repor ted by , /* ' - - / Date -

-9'r s ~.

2 Approved by M M Mdr>Date 2. a - sd-MVD:jc:17067cc: .u'.:.

g V aki/G.F.

QA Supt./ Site O.A. F Contractor PCD Supt ]gi

! MvD 1 l

l l

l l

Attachment C l

. ~

FMIE s t .) (dr. h [ '

FPS

• l[Ag 7-f S- s 3 XtAl ,r FC R ' F -

FOREMAW D, Ols e n '

PRIMT" e-337V C A St.Ed IREV 6& - F ) [

i A R.oSS- REASohl o LotATtoM tirs-f a E LV.45 /_ FOR CHANGE CannoI (BMD /A ' d, dio2 ' 0-D I

PKoBLEM ,

Sed eom " 8 - B em o-33 7</ s ke u,3 ytottA ts, no u, 14.,,condoA ea c:w3 a ssteeve o> n ' Q we l l w a.s c k a." 5 ,e d W w t O.2 eA o-I574 c T 1 A.M , Y g reEFERENCE GMD' ,

NOT TO BE USED FOR INSTALLATION '

SUGGESTION:

4A .4 IAK0ps Wf -M B.r7, & di" A, vllLL MT W aj iuve M ML. kenue. , %"+ mv. te Oeim v,ev To wooxce M eWAW ML T4 Yk. k  % " 4 To 2" treakwe 9{o0Lc) Vie theo @ %% 4 Qore'T. Geds To en 95vrer)

M VW4. (pg K.4hF*i) 1-%-83 o <

FIELD PROBLEM SHEET SYS PATE G. E i

[$N!O FPS

• ipn (,-l,-533 1( u) i FC R + F -

FOREMAMC . R ei nb5 g PRIMT" o- 3 3 74 REV A H

//

/7,2 7' -~p r CABLE # ipnone spRoob REASo bJ LotATioNlg + o.u s ELV.yr/ FOR CHANGE 3l_ cont St<uctoca\ //o wnev

! PKoBLEM '.

h e.d ye_- b esp F c, c 4wa C L - 4 o 'J' # RemoveJ pec O R R 31 Olo ,

t;46 4

_. ... .. .< _. . . t u ',

?

w

...,~.--,w,.***

NOT TO BE USED FOR INSTALLATION SUGGESTION:

6-3374A - Kev. AK ) ,

0-as74eal - rw. AA " 6/2Jr3 0 - 3374 602 - Ecv'. A F ,

pummsma g 9 * *

• I*

G a s t h P. ..r. . "mni.! .

f , i .t. :l.., 0

.m t

l3 ? ;

.. M iR

.g  :.., . p, .

y- a i x pij w 8

\

e g . x h i.. :_ ___.. x s .

g g 'g t d i}_:T:'.. -j '= i g x

e u t s s

%s .

DSw s$G . v

. L zA og N s i

kW W O

34 G A.

O h

)x /

E A a e W, w A

~

2B N N Ws m g

• i i

m O .N s ,

i

\ t 7

2O <2 4 k O 'N- ~

Q m3 k T 9

F N

N N q I S < ,d s <J x\ q 'Q i we 3 $ I, kO r

C N I s e e  %

x @ N k Z V u-kI E O x s w h o b  ;

i d b

.- kb b. h <& i l x we r n s a a N .

lw Q n ,

4 w b .

k h I g ,b M D I 67 8 uu N Q g_- 2  %

w N Ed s n .

< .. enN u -b mo  %

i s,h 7 7 k( N rbv  % p \

I l %

l <2 9 y 2!

ON n;

to J

ym c\

, o co b Ed O O m e l'p LL!

W " E D

~2 D <o

'D 0 Q Hg e i n 1 O c ( A P' '

VD

':- ! E 0 O .O

.t -

Z CO

.- C-4

SYs PATE i <,,p 3 y -

G. E FPS

• J- Y-r y pp% -

e FCR*F-FOREMAM J <Scfkhlfstifc/14 l PRINT"o - J57s p REV(r

, gg CABLE # REASON LotATioN f. A + /2. 7 E LV. %'/_ FOR CHANGE

,.n. _g u's u t'W" PKoBLEM *.

fjkNE O -5.57)D 5/10 w'C CcA/D W r cOR8JD)

/iV'(0.bfA.,\.'Th

/PA 28 & N0Y /^'M "' ,.I, ym , m.N:'.*,N

r. >

u- 1., ._. ,. . u ..a .>..u o.. a

? 8A/ rRi^/r o-337( c-ra uy go co sis u< r-ls ~^P~f~r2 /

w SMo v4 a cosiswr 84 fH

• TEP f40M d '5} 7'P NOT TO BE USED FOR INSTALLATION SUGGESTION:

0 '8'8'7/9 i

'er" Hf-f4 4

r- s e . t v rKo6LEM SHEET '

Sys PATE G. E / Og FPS

• ly[ g/7]pg jygg Ec f$lY FCR*F-

=n:.".,*.;2EN/;* b14 8/ '$1' AI PRINT"B.A97#/)/ REV y

' 33526 yp ggl d

CABLE /ptSgS.Sa4SS3

~

REASON I LocATIOM//)-L ELV4f]_ FOR CHANGE __

sg6n _ _ jpismsn ,

I

.PROBLE M ' p_.337ggj & &CffS WS'[ m M'ea 'e '

                                                                                           .s 9
    =                                                                                        'u.48jiA: ? tq

{ o DEC191983 d; ilAlfillD ELECTRIC COMPAl:'I i - NOT TO BE USED FOR INSTALLATION SUGGESTION:

                                                               ,,       a 6 '307(40                -

2 'q fg 73

1- I t . L D t'KO 6L E M SHEET ' ~ SYS PATE G. E F PS"  ;/1/r5 FC R + F - FOREMAM .-

                                                                                                                                                  ~

PRIMT" O -3N,4 REV AP \ C ^ai.C " NsR. Foe IJs126c A REASohl LotATioM sde 6et.ew ELV. - FOR CHANGE N6. IMEPMW PRO BLE M ". No Nonva soors t o<:.ari u<, Diususions Fo e. ida 2_2 60 A

                                                                                                                                    .                     -i;;

Z gpEREMCEOMCI . oc1 71983 ,ljjj

                                                                                                                                              ...     . .:. aa 4..._._._

Rar.-D.R. 2821 NOT TO BE USED FOR INSTALLATION cc .e < v.1 ' a c v. ar ' pif,5,, SUGGESTION: v. . r ,,, / n.w. J w we - ew N *-

                                                                                    - *we mmmmmmp 6 = - p    _

                                                                                             ..-_....-.-.o                   - -- o                                                             -               -

SYS PATE G. E FPS * $ j5 Ic.-/5'-83 0 - FC R ' F - FOREMAbJ C,et>ttw W, dCJ6fc= 4 , PRiuT* o L5T 3 REV/39 -- ^

                                                                                                                                                              ,4f                            g, l CAME* 3./(1 5 fl A                                                    REASohl                                                                                                         !

LotATiohj l'd" gaf ELV. W/c' 7 ,, FOR CHANGE I PROBLEM ". k ef f & xaurch$*"em L 4. A Im % d Ae-Ah &i k.Ab

                                    -        M M my                .

TFJENRO '

c l <

                                                                                                                                      .   .....,p.s o        J AN 2 41964                         _L" v((
                                  ?

(4'c.\, t.N',\-<.. x' i..' m IIAlllELD ILLC1RIC COMPAtlY

                                  =                                                                                                                                                                                 ;

NOT TO BE USED FOR INSTALLATION SUGGESTION: y & DSo - l'S "(* M6' Ioth 0 a

                                      -g ^<cedo e's" o- 3*3 g.e V ev
                                                                                                                       .V l

v- d l l 8 4- I PcA F z.4169 1

s FIELD ' PROBLEM SH EET SYS PATE G. E FPS

• 2 pg /wp 73 wrz js' FC R
• F -

FORE MA M G ,,, /-/,/ffe

                                                                                                                                   'W'" Wr
                                                                                                                                                        ~'

PRIMT" p _71c1 a REVgg CABLE # 2 v till REASON LotATioM 2. f 4 a ELV. _ FOR CHANGE _

 ' PROBLEM ".

C' 7 3 s~S CC - /-? 9' ,,<< rea.f,),/ X ,, y e nI0c eS /en, ' 3~ agerr ' o,,f are lo e&O P^o cdu W y J U T da cll X sZL/ / I'; 7S "x3"x u 8 ),efsen, 7le &> d ycar as cAl S a EcA/ S~M 9  ?,

                                                                                                                    .I      TRRWikap'                   "l 7 , , j c7                                         g n.                                        -
                                                                                                       ~

DEC191983 j[i o __ [reu[e-s [ 8 '/ / P 9 A 8 e,, f -r M e pvId., HAltlELD LLECTRIC COMPANY

                                                                                                                             ""                 ~ ~ ~ ~
                                                                                                                                                                    ~-

NOT TO BE USED FOR INSTALLATION SUGGESTION: 0-33G3 CO2 RE\l. A3 12.-2.1 - r3 1 ._ _._ .. . _ _ . . - _ . . _. _._ _ __

                                          ,---.~v--.                  . -, wu o                                                             - -

FPS 8 2v4 /o - 2 T-ff e a.

                                                              ,,_    _ , ,                            FC R + F -

FOREMAM G. o. H Jfx. ' I'~"'I # , PRIMT*o ~334 w REN:p G b\% ~~ CABLE

• 2 u g /45 REASob)

LocATIOM 2 f.+ y ELV.qjy_ FOR CHANGE PROBLEM *.

             , , y,    cc      yy qnd         cc-12y           pe . J         *C. o    ire     y. ,770e4-d                                 t*
    .f < t u pa < c .d ty c a a. 7'h e y         an      /s c a t- d            to     e /* s =       T#                       9 /I ' "'

a fa c A n a-r f* < E c s) J~f 7' - C# a c*~~ uf "' ! foe b g L r..'/ fae e yh c A . %, 7A-se gus g ), , ,, , ,7lli?Q.',5,'G.V.u ' pggEBCE !lirNshal..'] NOT TO BE USED FOR INSTALLATION .

                                                                                                  .-      .l . _ . . _ . . ..

SUGGESTION:

                                       $4A                ~6769              (2-[- PS I

F) ELD PROBLEM SHEET ~ ' SYS PATE s. E FPS

• 2yg to.47 73 t'yce FC R
• F -

FofEMAM Ceo. }/e jfKe y

                                                                                                      .- g-       ,5 PRIMT"o-1343            REVSv                                                                       I              <        _

CABLE *2 o g a7 2, co3, c 7c g g g s o y; ,, LocATioM2r4 /'- 5 E LV.in t, FoR CHANGE O //c r 27e' h C " = </- .' r #-a

                                    ~

PROBLEM *. a ,s p r s x C o nele<:t3 + }J a tre a /"u// /sor ur s A sw u LD'a Lu' .' / / kr ' v e o v" ' 27o" o f B" WJ ['y s[ g(f.'ya . Oi*TS "' T ' * # 5Y TJ ' q j f u) a /s c , Te T ir e /0 ~// / t J ' ' *- Y < /s e a fe d /o' S " f T h ' ' f'~~f l*c*" ' ' ' fe // fs, d Ts , . sp . e. 7. ' s . r n .1 w < is s /d d o r A e. sue < 2ro' ja r i, - s .

  ' UT TO BE USED FOR INSTALLATION                                             . ..
                                                                        ....l.t SUGGESTION:                                                         bV' 0 - 3 3 fo %           REAl.BR              IO-2&-(S                              I

SYS PATE s. E F PS* '2pr c7 - z 1-r' L U <t w . -. FC R

• F -

                                                                                                                                                 , M hd " /' NN FOREMAM Ce,. //,/Tre                                                                                                                                           g' 7
                                                                                                                                     +<              * ' ':

PRIMTb.3 , u. post,17p R E.M BC,1; Fjft{f

                                                                                                                                                                                               \'                                          _

w t ny to r d' CASLE* 2 /p y 95,47t, t 11 / REASokl ccadu:r ll n.s n'7' LOCATioM 174 L ELV.y ig , FOR CHANGE c a h, p. t Fs, - 1 . r n ,* s ~r ,' ,. r c eJ/e s ..

                                                                                                               /fl        .7      C7B PROBLEM *.                                  V z sn :s crp                C0       z rn s 77            o-3176                   i 5 Csndu:t                         f r> ~                                                                        *

43. // Vd // * '

ls c , te d ip co ef--r e r ,, -r ef c c 4 ' v- f L</ /> c A c s ,, d . . -r s-a rA

                                                                 ~7' < i , : n r,%            -F             c., A /- s .       m.- J         t-       r . /a c a r.

y t- < n , w -r w d ' C a fs~r s v. z ' (pn s t.u e.,7 </ ~ cnAk gq595W -.. NOT TO BE USED FOR INSTALLATION SUGGESTION: ,, 0-s % Z.wol-w

                                                                                                                                       - FIP -).                                                                                             '

a 40tp - Rk O - ?/b'l 2 - - - bd O'l0'O A _ .- T 3/ 401 ud

FIELD PROBLEM SHEET ' ' SYS PATE G. E , FPS

• 7t/)( 9-./t.-F'1 4/ez FC R
• F -

YOREMAM Ga . //r d*Xfe- -- _g ! _PRIMT* # O-33 cz.vo3 REV g C A B l. E :L u d a t f REASohl i

                                ,LotATioM / f+ #                        ELV.479_       FOR CHANGE i                                ._.

PKoBLEM *. R p e b /c to e / d f'/osefg q<ASw r To / /* ^ 9 s

                                                                -t. o S 1, "w #-                  10     DeY      A-     4   Sc  M~ #
                                                                                        , s   w:i/             iv    " T      ~ // *

• u3 *C #

5 3 g /S* f /> . e T h :e. A v s<L T cro u. w JoA" S T~ - " y2. p c p. pt, f<r ias re// / . ..1A ,'

                                                                                                                          ,? O hjV
                                                                                                               .. e;3. , .cw:-    .

NOT TO BE USED FOR INSTALLATION l-SUGGESTION: 6-3362_)83 "g" lggg3 I i. I! B la I

PATE SYS G. E FPS * /c x / 2- / r-F1 &E A FC R + F - VOREMAN Ge o. He21kr PRINT d 0-33cz 0' REV #6' CABL E d Jc x / 2 9 _ , REASohl f, j , , g, f LotATioM /ef 4. L E LV. v 7_,_ FOR CHANGE C 0 !! d E~o PKoBLE M ". c s < l ny 4 /*. C 0 4' SS7  ? 7'# I~' y ; p g, f ., , w:rA :p 7 cs u. s- s y ,, , b le t- a w- be e -r w /- - - ce re 6 a <. n y,ad pa w /se. & a F" A/- gcgi s'~~ ,

                                                                                                                              }}

NOT TO BE USED FOR INSTALLATION

SUGGESTION:

r}.l;.ymne;Gajrh I

                                                                                                                                                          .in,\ :..h Y' .'" L ,dj).
                                                                                                                                                       $      ysN 7 I?N 'i.              .
                                                                             && #6fL           ?9A 1O                         (-/.ft                  k,hir6in:_'-}"

g ; y ,. . .-

• _

i

          .                                               - = = =

FIELD PROBLEM SHEET sys PATE G. E F P.S* jyJ 12-3-73 km. p FCR*F-FOREMAM G e, //c/fr. PRINT" 0 -17 c 2. REVgW

                                                                      ,,,  jp      4 g

l f CA BL E '* J t'5 - 4 7 7 REASohl L o c.A T i o N ELV. _ FOR CHANGE PROBLEM ". Cs*J~'f C

• A 08 Y""fd T' " ' ' " ' ~""*"'

                                   ,sj          ,   C s o,d e.' f  y s ~ 1e d t'     C-'     Sec 7~o %                          W W*

• ds

          -f'

• f"~a < , ,. n . Y e 7p' S~ec T*5 W N. -,

  ?

C'

                                                                                                  .m().

l j'

                                                                                                                        . .s
                                                                                                                                       '0bl?i;                        !lii ik DEC 121933 ll!',i
                                                                                                 ' 81 l.,'ilTlt I's Ll' c1,'::c cy ',Jrf I

i - - . . _ _ . . . . NOT TO BE USED FOR INSTALLATION SUGGESTION: ' gpggMCE.O'ii'l 6 g s 7 6 g. ^== W 0 % 1-9-73 w..

FIELD PROE5LEM SH EET SYS PATE G. E 't FPS d jd G -2 66 Q.C f,'9, f FC R ' F - foREMAM A . 6cuarr / wp gg lf PRIMT"o- 3 574 REV D.Tn v G. CtACr-. ' CAe>LE SvA od~5vacn2. was REASohl toenTion zi i s E LV.+5L FOR CHANGE ._ _ _ cav'Avn Ar12 - FtWcTtoMIAL PROBLEM *. 6"/.G"C C FRoh z a e> G87A- To ov^oRD dA6 A 9' COtaDo iT DhME pwoe ea 40s aav. m > c - ^~o-eco,= ,1 onva enems suasso, wsT-ua meu.a mr 4"co.aoo T ts Tco 6s ou_ To puu mesa cnews wam Ae_e iz /c

• s 6 m m*, u , e mwv: r>nn nen u, wa. n u smac, tor.ncuse, ene,ws.

W unb WE. cAME. Peo81 E K 00 0 0 'T L 6'Oe -

                 ?
                                                                                                                 . < .: t bw,u
                                                                                      'v k... .5..An. t.. ... r. M.          , , t ,. p
                   'sdT TO BE USED FOR INSTALLATION SUGGESTION:                  .
                                                      ,,          gc_ f.g       ge/!; 2 3, 4 9 1. -                                     ,
                                                     , a _ ., ., , , > , ..- o
                                                                                   .J v a-ls                       o      ED74C"' 26VAB a        '     T.: 2 _, o     2G1/   N
                                                                                                                       <D'
                                                                                                                                /7           .

J

                                                                                ~

k I Puu19 2VAofo

               . . . .   . A" FLEX FROM _23S587A : C ASLE s CA %LES yET To SE PMG; 7L'hol\                 2VA 254 2VAct?        _2YA sco             :

2VA023 2VA 350 eur & 2 VAA2l fYA774 TOTAL A LLC'dA% L C f/LL FO R A 4"# SLEEVi; 7G3 SYA75S ACTUAL f/LL INCLUDidq cABLis, yer 7e ar PocLED: 4.6M2Yh]90 ALLOWASL C f/(g fcp f')$ Cegpus y : 5 09 )f?Q$0 6'bG"WV' FROM 23S567A: CASLES PULLED .z fPo72 CASLES yer To et P.*atep : 2VA767 2fPo76 TVA29i 2 VAc \ c 2VA O:: CASLES THAT sgout') Mar MAy7 greg 2VA C 31 2h'A 032 12 ViRc Vsy' ~ 2 Fib 72 2Ffb78 ': = *, , , 2JA c5 A 2 Yh '2 %

                                                           ~

2VA'2% s 2VA319 .. 7 VA 319 ,, , 2VA784 , 2 VA 396 '

                                                                                         /

2\A3ii-2VA754 2VA 794 TOTAL ALlodASLE f/t.L FOR A A"9 Serc/E : 7. G. sactuoids cketts yer ro es PjL/SCO = 7.42. AcruAt p/tt.

                                                                                                          ~

l ALLoVAscC r/t L FOR CA G "w' M = 8.00 C-17

[

 #                                         BYRON SITE O.A. SURVEILLANCE                       7 QF: 2790.22.2.11

( Report No. 5811 # Date: 2/21/84 contractor / Organization : Hatfield Electric Co.

SUBJECT:

NRC Reinspection Program Results Verification OBSERVATIONS: Attribute #1 - Visual Weld Inspections The visual weld inspection attribute for Hatfield Electric Company included eight (8) inspectors. For two (2) of the eight (8) inspectors. a complete 100% verification of the data used in the final database was performed. The two (2) inspectors were P. Lane and E. Dumas. For each inspector, the primary source documerits (weld traveller and third party inspection record) used for the initial data were compared to the Hatfield Wang database. For P. Lane a total of 488 weld travelers were reviewed which accounted for approximately 5000 welds, and for E. Dumas a total of 205 weld travelers were reviewed which accounted for approximately 700 welds. Then the Wang data was compared to the final inspection report database dated February 15. 1984. In all cases for both inspectors, the final data was found to be an ( accurate representation of the primary data. Minor typographical errors were found but were minimal. The effect of the errors was randemly distributed and did not skew the final results. Errors found during the course of the surveillance were addressed during the surveillance and corrected as necessary. Attribute #2 - Conduit Attribute No. 2 (Conduit Inspections) consisted of the work of six inspectors performing 134 inspections. The initial review of the tally sheets. inspection reports and reinspection reports raised a number of questions regarding the method used to tabulate the results. This matter was discussed with Mr. Greg Cason of Hatfield, Group Leader, who originally tallied the results. It was determined that Mr. Cason had not included those items marked "not applicable" on both the original checklists and reinspectica checklists in the total reinspection population. Since this was contrary to the method used in tabulating the results for the other attributes, a recount was performed. The resulting tally sheets were reviewed by J. Bergner of CECO. QA for mathematical accuracy and found acceptable. The reinspection sheets for inspectors "G", "J". and "K" were checked against the tally sheets to verify the accuracy of the tally sheets. This sample, which included 120 of the 134 inspections, indicated that the tally sheets were accurately and correctly completed. Based on the aforementioned activities. it appears that the results of attribute No. 2 are correct.

     /

Attachment D (17735)

I .

    ,,   surv.2111cnc2 R; port No. 5811 Page 2                                                                                ,

Hatfield Electric Co. I Attribute #3 - Termination The ' third attribute, terminations. involved the reinspection of five (5) inspectors

• work and covered approximately 664 original inspections. 100% of the reinspection reports for Dumas and Buchanan and a random sample of the reinspection reports for Getzelman. Cripps and Hanson were verified against the termination tally sheets. The tally sheets appeared to accurately reflect the data contained in the reinspection reports: however, the final results contained in the " Detailed Inspector Results" did not accurately reflect the j data in the tally sheets. Specifically, the total number of items and the number of acceptable items both included those items that were found to be

non-reproducible. It appears that the error occurred when the total item i

count was computed by multiplying the total number of reports by the nu:ter of items per report. The error was pointed out to Hatfield QA and a recount was performed in the presence of J. Bergner of CECO. QA. The resulting figures are now believed to be accurate and acceptable. At t ribute #4 - Eculpment Setting In the area of equipment setting (Attribute #4), no results were shown en the " Detailed Inspection Results". The reason for this, as verified by review of the reinspection reports, was that the few inspections performed in this area were either inaccessible or nonreproducible. Attribute #5 - A325 Boltina A325 Bolting, which is listed as Attribute #5 included only two (2) inspections by one (1) inspector. These inspections were reviewed by C. Nagel and J. Bergner of CECO. QA with one (1) apparent discrepancy noted. Cne of

'          the items on a reinspection checklist had been marked unacceptable because three (3) of four (4) nuts in a bolted connection had been turned around and could not be verified to be of A325 composition. Upon review of Precedure 25 (A325 Bolting) it was verified that this was an "in process" type of i            inspection where the original inspector would have been able to check the markings on each nut. Since the nut that was accessible was of A325 composition and the other three (3) nuts were effectively inaccessible this item was found to be acceptable. Based on this, the " Detailed Inspector 7
~

Results" were found to be correct. r Attribute #6 - Fquipment Modification The reinspection reports for equipment modifications (Attribute #6), involved inspectors Dumas. Cripps, and Hanson. The six (6) reinspecticn l reports that make up this area were examined and found acceptable. I 1 h (1773S)

    ~

Survaillance R2 port No. 5811 P P ge 3 Hatfiold Elcctric Co. I Attribute #7 - Equipment Modification In the matter of Attribute #7. (Conduit As-Built), forty-nine (49) conduit as-built reports were examined for numerical accuracy. Items on the reports were counted and compared to results found on the clarification of as-built information sheets. It appears that the number of items inspected have been accurately tallied. l The reinspection reports were examined for the equipment modification l inspections and no rejectable items were found. thus confirming the results of the final report in this area. Attribute #8 - Cable Pan Hangers The results of Attribute No. 8 (cable pan hangers) are comprised of the reinspection of two (2) inspectors' work consisting of 324 inspecticn reports. The initial tabulation of the reinspection was found to be in errer due to the method used to tally the items. The 9A-1 inspection reports consists of two parts: the HP-9A-1 form, which is a six (6) item check!ist. and a supplementary sheet which contains detailed information regarding hanger dimensions. connection types, aux. steel, etc. The reinspections were performed using the supplementary sheets but the tally sheets accounted for only the six (6) items on the HP-9A-1 checklists. The reinspection population appeared much lower than it actually was because of tnis. A recount was ( performed on 2/18/84. When this recount was reviewed by CECO. PCD and Hatfield QA. several new problems were noted. First, a clerical error was noted in that the Hatfield QC personnel performing the recount were using a tolerance of zero to plus three inches for internal braces and zero to plus six inches for external braces. The actual tolerances were plus or minus three inches and plus or minus six inches respectively as noted on note 37, drawing 0-3275 and note four, drawing 0-3277. A second problem encountered during the recount was that, in certain instances, criteria used during the reinspection have changed since or were non-existent during the original inspections. In these cases, it was decided that the original criteria should be used in determining the validity of the original inspection. The aforementioned items were reviewed by M. Dellebetta. CECO. QA. and found acceptable. Mr. Dellabetta also reviewed forty-nine (49) of the reinspection reports against the tally sheets and checked the addition on the tally sheets for errors. Both were found acceptable. Based on the items examined, it appears that the final results of the recount are accurate. Attribute h) - Cable Pan The reinspection of cable pans, (Attribute #9) involved eight (8) inspections by one (1) Hatfield inspector. The reinspection reports were reviewed and compared to the " Detailed Inspector Results". All of the aforementioned were found acceptable. D-3 (1773S)

Survaillanc2 R; port No. 5811 Page 4 Hatfield Electr$c Co. Evaluation All nine (9) attributes reviewed during the course of this surveillance were found to be acceptably documented, and in accordance with the guidelines and interpretations of the NRC Reinspection Program I&E Report 50-454/82-05 and 50-455/82-04. The following CECO. QA personnel were involved in this surveillance: P. T. Myrda J. W. Zid M. V. Dellabetta C. J. Nagel J. L. Bergner S. Stimac T. G. Hibst L. Bihlman This surveillance is closed. . Reported by @ /g./ w Date4 M/ 4" Approved by 4! b f 1 @/q, Dates,Iu ;U O JLB:jc:1773S 34'SY p ( cc: W.J. Sh-: Ski /G.F. M , r QASupt./SiteQ.A.Fi{e Centractor PCD Supt f} Y P.T. Myrda K.J. Hansing E.L. Martin J.L. Bergner .! M.V. Dellabetta D-4

r

                                                                                                     )
 ',                         Commonwealth Q.P. FORMlh.

Edison Company DATE J/4/81 7 QUALITY ASSURANCE MANUAL - AUDIT REPORT Byron Reinspection Progmm Audit

                                             #6-83-66 g

Type Audit: / / Program Audit CProduct Inspection Point

               /   / Records          g /Special To:      (As Listed on Distribution Page)

Project _ Evren 6/21/83 Visit Date 7/06/83 Report Date_7/1a /"? System Various Co=ponent Identification N/A Material Description N/A Vendor Site Contractors Location Ev' on Subcontractor _ N/A Location N/A Contacts See Attached Renorts P.O. No._ va-4~,- Spec. No._ Variour - Reco= mended Inspections: 6 mos 3.mos 1 mo Other: As Scheduled Notes: iesponse, please respond by 8/05/83.For items listed i and Responses to Findings

• 1. Observations will include the following: ,
• 2. Corrective Action to actionrecurrence.

prevent and results achieved.  ! j

• 3. Date of full compliance.

           *Auditor (As requir[ed/

_ Ib / /a..e con' n* of each item) ' Date yd/Mr Reviewed 8[ w AJR:jc:0221A -Date7/i//f -7 l

                                                                                                 . i Attachments                     ,4@

cc: Es. % N 7 Man cer-Protects Prefeed-ManageF Eng,-Manacer

                                                  &*/b//5 Bireeter IA-Genstructica             (As Listed on Distribution Page)

Site-Gens 4Fue44GC Superintendent. Site-GA Auditee

                   $tttrth-Supervi-sor Attachment E A

s DISTRIBUTION PAGE C0110NWEALTH EDISON AUDIT OF THE BYRON REINSPECTION PROGRAM  ! TO: M. L. Somsag Hunter Corporation J. T. Hill Hatfield Electric Company B. Shah Johnson Controls Inc. M. R. Tallent Pittsburgh Testing Lab. R. P. Larkin Powers Azco Pope R. Allen NISCO R. H. Bay Blount 3rothers Corporation cc: M r ]5 nager Projects Project Manager Eng. Manager Director QA Construction Site Construction Superintendent Site QA Auditee Site QA Supervisor Director Nuclear Licensing QA ANSI N45.2.6 Coordinator E-2 (0221A)

            ..                            ~.

LIST OF AUDITEES I Contractor P.O. Specification Hunter Corporation 207010 2739 Hatfield Electric Company 197131 2790  ; .j - Johnson Controls Inc. 213415 2783 Pittsburgh Testing Lab. 216025 2850 Powers-Azco-Pope 222445 2906 i NISCO 213839 2834 j Blount Brothers Corporation 181186 2722 I ! i I 1 i i i 1 1 I ) i i i i f ) r

E-3 1

(02214)

o COMMONWEALTH EDISON AUDIT OF THE BYRON REINSPECTION PROGRAM AUDIT No. 6-83-66

Purpose:

l To observe, assess and verify the implementation of the Reinspection Program at Byron as performed by on-site contractors and directed by C.E.Co. Project Construction Department. A description of the reinspection program l and the audit methodology is included in this report. Description of the Byron Reinspection Program: In March of 1983, a reinspection program was instituted to validate the certification programs of the Byron on-site contractors as they relate to l Level I and Level II QC inspectors. The program was outlined in a letter from W. L. Stiede to .7. G. Keppler dated February 23, 1983. (See Attachment). The mechanics of the program were directed by Commonwealth Edison Project Construction at Byron. Description of the Reinspection Program Audit: The audit was conducted between 6/21/83 and 7/06/83. The auditors observed all contractors involved in the reinspection program for the items listed under scope. The reference document for the audit was the W. L. Stiede letter dated February 23, 1983, which was the response to I&E Inspection Report Numbers 50-454/82-05 and 50-455/82-04. Deficiencies or items of l concern identified during the audit are listed in the appropriate portion of I the audit report. With each deficiency, the organization responsible for l response is listed. All responses to items identified in this report will bo l reviewed by Commonwealth Edison Quality Assurance Department to determine l acceptability. Several items identified during the audit were closed prior to or at the exit meeting. These items are presently acceptable and are not classified as deficiencies in this report. In most cases, these items required clarifying information to be resolved. A section of the audit report labeled " Items Dispositioned during the Audit" describes these items and their respective dispositions. ' Scope: The audit examined the following areas:

1. Reinspection sample size of inspectors and inspection items.

2. Items determined to be inaccessible.

3. Third party review of potentially unacceptable subjective type

! inspections.

4. Dispositions of nonconforming conditions discovered during the reinspection program.

5. Adequate documentation of the reinspection program as implemented by the contractors.

6. Qualifications of inspection personnel performing reinspection.

E-4 (0221A)

c.

  ,      Audit R; port No. 6-83-66 Pag) 2 Byron Reinspection Prcgram Audit Team:

The reinspection audit team consisted of the following personnel: A. J. Rosenbach Lead Auditor QA Inspector - Byron L. A. Simon Auditor QA Engineer - Byron S. A. Altmayer Auditor QA Engineer - Byron P. T, Myrda Auditor QA Supervisor - Byron C. J. Nagel Auditor QA Engineer - Byron M. A. Stanish Auditor QA Superintendent - Byron Summary: An entrance meeting was held on 6/21/83 at the Byron Quality Assurance Department. Attendees were as follows: P. T. Myrda C.E.Co. QA M. A. Stanish C.E.Co. CA A. J. Rosenbach C.E.Co. QA L. A. Simon C.E.Co. CA C. J. Nagel C.E.Co. QA S. L. Bindenagel Hatfield Electric Co. T. Maas Hatfield Electric Co. J. D. Spangler Hatfield Electric Co. M. R. Tallent Pittsburgh Testing Lab. B. Shah Johnson Controls Inc. L. E. Hadick Hunter Corporation D. L. Smith Pittsburgh Testing Lab. M. L. Somsag Hunter Corporation R. P. Larkin Powers-Azco-Pope G. Cason Hatfield Electric Co. R. B. Klingler C.E.Co. PCD Bob Allen NISCO C. C. Novak NISCO Ghaus Mohammed Pittsburgh Testing Lab. S. A. Altmayer C.E.Co. QA Two exit meetings were held, one on 6/30/83 and the other on 7/06/83. Attendees were as follows: 6/30/83 exit with C.E.Co. PCD: R. P. Tuetken C.E.'Co. PCD R. B. Klingler C.E.Co. PCD M. A. Stanish C.E.Co. QA E. L. Martin C.E.Co. QA P. T. Myrda C.E.Co. CA K. J. Hansing C.E.Co. QA L. A. Simon C.E.Co. QA A. J. Rosenbach C.E.Co. QA E-5 (0221A) 1

Audit Report N3. 6-83-66 Page 3 Byr:n R2insp cticn Progr:m 7/06/83 exit with Byron Contractors: A. J. Rosenbach C.E.Co. QA R. H. Bay Blount Brothers Corp. L. E. Hadick Hunter Corporation J. T. Hill Hatfield Electric Co. K. J. Hansing C.E.Co. QA E. L. Martin C.E.Co. QA M. R. Tallent Pittsburgh Testing Lab-D. L. Smith Pittsburgh Testing Lab: R. P. Larkin Powers-Azco-Pope S. A. Altmayer C.E.Co. QA M. L. Somsag Hunter Corporation R. B. Klingler C.E.Co. PCD R. P. Tuetkrq C.E.Co. PCD At the exit meetings, def'iciencies and items of concern were discus sed to I assure understanding by all involved parties. The auditors would like t) express their appreciation for the level of cooperation exhibited by contractor and PCD personnel during the audit. The Reinspection Audit resulted in a total of one (1) finding and eight (8) observations. Findings and Observations are listed and discussed in Part A of this audit report. Responses are required from the following organizations as delineated below: Finding #1 Hunter Corp., Hatfield Electric, PTL, and Blount Brothers Observation #1 Hunter Corp., Hatfield Electric Observation #2 Hatfield Electric Observation #3 Pittsburgh Testing Lab Observation #4 Powers-Azco-Pope Observation #5 Hunter Corp., NISCO Observation #6 Blount Brothers Observation #7 Powers-Azco-Pope Observation #8 Hatfield Electric E-6 (0221A) f

i I a PART A AUDIT No. 6-83-66 Finding #1: Contrary to 10CFR50 Appendix B, Criterion XV, certain contractors were not taking appropriate measures to identify, document, segregate, disposition, and t notify affected organizations of nonconforming items identified under the , g.[v , reinspection program. fj-Q gg s . Discussion: Finding #1 Part A (Hunter Corporation) During the reinspection program, nonconforming conditions were identified which did not result in discrepancy reports being initiated. Problems with component support 2FP12016 were documented on Field Problem Sheet #FP109F rather than on a discrepancy report. No DR was issued for rejectable items P associated with component support 2FP14056X because Hardware Removal Q,b[h q Report #1380 has been initiated due to W ECN 52901 dated 6/22/83. The

                                               ~

S reinspection for 2FP14056X was prior to the issuance of the ECN. The ' following mechanical joints failed to meet the specified torque of 707. of the initial value when reinspected: SSX 100-23 MJ177, SSX 100-23 MJ178, SAB 100-43 MJ23, SD0 100-34 MJ49; these joints were retorqued by production immediately following inspection. No DR's were issued to document this Discussion: Finding #1 Part 8 (Hatfield Electric) During the reinspection program, nonconforming conditions were identified E which did not result in discrepancy reports being initiated. Field Problem (/ d Sheets were being implemented to resolve reinspection items in the conduit ard vg terminations area. The Field Problem Sheet is not proceduralized. Discussion: Finding #1 Part C (Pittsburgh Testing Lab) At the time of the audit, PTL had not yet transmitted open inspection reports generated because of the reinspection program to the appropriate  % @g ) contractors. Therefore, no corrective action has been taken for the Y % apparently nonconforming conditions. \' Discussion: Finding #1 Part D (Blount Brothers Corporation) At the time of this audit Blount Brothers Corporation had not yet p generated any reinspection DR's or DRC's for rejectable items discovered as a result of the,. program. e3 (\ v du E-7 (0221A)

                                            . 4 l

Pag 2 A2 Observation #1: Application of the term " inaccessible" to those items which receive multiple inspections does not correspond directly to the definition of "inac.essible" offered in the Stiede-Keppler letter dated February 23, 1983. Discussion: Observation #1 Part A (Hunter Corporation) 1 According to the Stiede-Keppler letter, " Inaccessible shall be defined as: S Y

   ' condition where dismantling would be required to gain access, or condition       h, ,\y 3 where process was an event which can not be recreated."

When inspections of the same type occur after that inspection to be sampled in the reinspection program, the item of the original inspection is labeled by Hunter as inaccessible. For example, if a Type 3 inspection is performed in .7anuary,1980 and a subsequent Type 3 performed in May,1982, the one in 1980 is termed inaccessible. This is done without research to determine if the later inspection occurred as a result of rework etc. thus making the original inspection unrecreateable. Discussion: Observation #1 Part B (Hatfield Electric) According to the Stiede-Keppler letter, " Inaccessible shall be defined as: condition where dismantling would be required to gain access, or condition where process was an event which can not be recreated." Hatfield was using the term inaccessible to disposition reinspections to which this definition does not apply. The example noted during the audit was, Hatfield had termed those items with subsequent inspections as inaccessible without determining if the original inspection was an event which cannot be recreated because of rework, design change, etc. Observation #2: (Response: Hatfield Electric Company) Hatfield has not performed an evaluation of QA/QC Memorandum #295 for its potential effect in the reinspection program. Discussion: Hatfield Electric Company CA/QC Memorandum #295 dated 9/17/82 states that an acceptable weld inspection of cable pan or conduit hangers implies verification of the correct connection detail. This manner of acceptance occurred when the cable pan or conduit hanger inspection could not verify the detail due to the presence of fireproofing. Due to the fact that the reinspection program requires re-creation of the original inspection, a determination must be made as to what type of inspection, either weld or hanger inspection', originally included the connection detail. After this determination is made, the connection detail can be included as an element of the proper type of reinspection. E-8 (0221A)

Page A3 Observation #3: (Response: PTL) Pittsburgh Testing Laboratory is not reinspecting each individual p\. inspection performed during the inspector's first three (3) months, where " b ) accessible. Discussion: For inspectors certified in several disciplines within the three month time frame, only those inspections in the area of the original certification during the first 90 calendar days w re reinspected as opposed to "eech individual inspection performed during the inspector's first three narths" as cited in the Stiede-Keppler letter dated February 23, 1983. An example of this situation would be if an inspector was originally certified in ore type of inspection and later certified in a second type of inspection, the first certification was reinspected. The second type of inspection was not reinspected even though certification and inspections within that area may have taken place during the inspector's initial 90 days. Observation #4: (Response: PAP) p The status of rejected reinspection items is not determinable. 4e \ G gp Discussion: 4 The reinspection sample record does not note the FIS report number which is used to disposition nonconforming installations. Without this inforration supplied, the status of the open items could not be determined by PAP at the time of the audit nor could the auditor assure a discrepancy report had been initiated for those items. Observation #5: For some inspectors, the number of items reinspected, though in agreement with the Stiede-Keppler letter, do not provide an adequate sample size. ,f Discussion: Observation #5 Part A (Hunter Corporation) I h

• hs .

Commonwealth Edison's Project Cor struction Department verbally directed all contractors, with the exception f PTL/ Peabody, to provide a minimum a sample size of fifty (50) items. bhV 4p 3 Of the five (5) Level II QC inspectors reviewed during the audit, three V go (3): P. Pepitone, S. Kilpatrick, and J. Ooten, didn't have the minimum of fifty (50) items reinspected. l E-9 (0221A)

                                        . 1 Page A4 Discussion: Observation #5 Part B (NISCO) e Commonwealth Edison's Project Department verbally directed all contractors with the exception of PTL/ Peabody to provide a minimum sample size of fifty    f
                                                                                       .[

(50) attributes. Oj)Ol The following inspectors were reinspected for less than 50 inspections: R. Schultz 16 Inspections M. Weir 39 Inspections T. J. Priutt 30 Inspections The number of items per inspection cannot be determined from information provided. Observation #6: V, (Response: Blount Brothers Corporation) S.C y n\.L ,( One inspector chosen for the reinspection program was not reviewed in all F areas of inspection activity during his first three (3) months of certification. Discussion: R. H. Bay had performed masonry inspections during his first 90 days of certification at Blount Brothers Corporation; these have not been reinspected. Observation #7: (Response: PAP) v Six (6) months as opposed to three (3) months of an inspector's work was U reinspected in the original sample, c Discussion: Because of a misunderstanding, PAP considered the six month time period to be the original sample; failure to meet the acceptable quality level after this time frame, resulted in an additional 90 days of reinspection rather than the entire remainder of an inspector's work as specified in the Stiede-Keppler letter. E-10 (0221A) I

t' Page AS Obstrvation #8: (Response: Hatfield Electric Company) Hatfield Electric could not determine if a portion of the conduit inspection is subject to the reinspection program. Discussion: Torque checks in the conduit area were determined to be non-reproducable inspections; dispite this, bolt counts were taken during reinspection. The bolt count was included in the original conduit in.spection to determine the proper number of torque checks to perform. Differences in bolt counts between the original inspection and the reinspection are being entered as rejectable items in the reinspection program. These items are remaining open due to confusion on how to disposition them. Hatfield Electric Company needs to determine if bolt counts should be a part of the reinspection program and, if so, how to resolve these items. I 1 'l E-ll (0221A) l

                             .   ---.                      .   . - _ . .     - -    ~       . .   -
     -                                                 i Paga A6 Items Dispositioned during the Audit During the audit, several items were identified which were dispositioned prior to or at the exit meetings. Because these items no longer exist at the time this report is being written, they are not considered deficient.

During the audit, it was noted that the population of Pittsburgh Testing Laboratory inspectors changed due to factors such as inaccessibility and the minimum number of required inspections. It was also noted that it could not be determined which inspectors were replaced and for what reasons they were 1 replaced. Before the exit meeting, a list of Level I and Level II initial and subsequent inspectors selected was provided. The list developed included inspector's level of capability and reasons fcr all inspector's chosen. Due to the acceptability of the PTL inspector list provided, this item requires no response. j Additionally, it was noted that the status of PTL reinspection reports to i be submitted for third party evaluation was difficult to determine. Before j the exit meeting, PTL provided a form which included the steps necessary to

!          procure reinspection reports. The PTL form is acceptable.

Powers-Azco-Pope's inspectors were included in the reinspection program only if their certification date fell before March 1982. PAP's new

,         certification procedure was accepted in July, 1982. R. Sutherland was PAP's only CC inspector certified between March and July. His qualification package was reviewed by C.E.Co. QA on Surveillance #4624 dated 5/25/83; it was
;         acceptable to current criteria.

As a result of the audit, it was determined that Hatfield Electric Company CA was not aware of the proper number of additional inspectors to include in the reinspection program. Per the Stiede-Keppler letter, when a failure in the reinspection program occurs, the population of additional inspectors should equal 50% of the initial number of inspectors chosen to be reinspected. Due to the fact that the results of the reinspection program have not yet been analyzed, no additional inspectors have been selected.

!         Prior to the selection of additional inspectors, C.E.Co. PCD will provide Hatfield Electric Company with the proper number of inspectors to include.

j Also identified, two of Hatfield Electric Company's reinspection j inspectors did not meet the experience / education requirement at the time of ! certification. Hatfield Electric Company failed to verify high school j education or its equivalency for D. Moehling and D. McCarty. This item was identified and followed by C.E.Co. CA Surveillance #4750. Their i certifications were revoked prior to any inspections being performed. Presently, McCarty has his high school diploma on file and Moehling a copy of

his.GED. Both individuals have been recertified, f

E-12 (0221A) l

1

                                             .                                     l Page A7
 .      At the time of the audit C.E.Co. Site QA has not completed review and      ,

verification of all qualifications of those QC inspectors performing 7 reinspections. This item was previously identified and being followed by Finding #4 on General Office QA Audit of Byron Station Construction, Ju,ne 1983. Review of those qualification packages is currently underway. If any dificiencies are noted, these will be tracked on the surveillance documenting the review. Problems with Blount Brothers Corporation not properly documenting all facets of their certification program for their reinspection inspectors are documented on Byron Site QA Surveillance #4699. Resolution of these problems will be through this mechanism. J c f E-13 ' l (0221A) l

I Page A8 Summary and Assessment, Byron Reinspection Program Audit The audit team found that all contractors involved are in the process of implementing the reinspection program described in the Stiede-Keppler letter dated February 23, 1983. The audit team also found that in some cases i clarification is needed to provide the reinspection program with continuity. , l It is suggested that all clarifications and directions required be put in ' writing. The audit team found that in the past, verbal direction had resulted ) l in differences in interpretation and implementation of the Stiede-keppler letter. In order for C.E.Co. Project Construction to perform a meaningful l analysis of the program results, differences in implementation should be eliminated. As a result of this audit, a total of one (1) finding and eight (8) l observations were identified. The only potential QA program violation identified was the finding which concerned identification of non-conforming conditions . The audit team felt that this finding resulted from difficulties incurred when attempting to combino a special program with the contractor's regular program. This finding applied to four of the seven contractors audited. The observation; (J etified in this report were, for the most part, the result of different interpretations of the Stiede-Keppler letter. These differencos resulted in discrepancies in such areas as samplo size, both 1 initial and expanded, of inspectors and inspections to be reinspected. Another examplo of a difference in interpretation is the application of the term " inaccessible" to items which do not fit the description of

    " inaccessible" offorod in the Stiedo-Koppler letter.

Because the audit occurred while the reinspection program was in progress, the results of the program could not be analyzed. The audit team felt that this situation provides an advantage as it will provide Project Construction l with a list of itoms that could, if not resolved, impact the analysis of the l results of the program. This fact is evidenced by the number of items rosolved both during the Judit and at the exit meeting. Resolution of the finding and observations 7dentified in this report should provide the reinspection program wifth sufficient clarity and continuity to enable Project Construction to identify the adequacy of the contractor's past QC inspector

certification programs. The reinspection program is expected to be comploto l

in September of 1983. The audit team hopes that this audit will assist Project Construction ~1n fulfilling the commitments made in the Stiedo-Keppler l letter. E-14 (0221A)

     'i*  '

Post Ot' ire DU

• w' s,r-p.CNcrgi Armet, Re.

lit n!'s t0690ply 7('-

         ,,,9
                                                                                    /h.'Mhe NT, dadi r- (o -t3-f g
                                                                         /
     ,                                                               ,             February 23, 1983
                                                                       -    i Mr. James C. Keppler, Regional Administrator Directorate of Inspection and

• Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 1 & E Inspection Report Nos. 50-454/82-05 and 50-455/82-04 References (a): June 24, 1982 letter from C.E. Norelius to Cordell Reed (b): July 30, 1982 letter'from W.L. Stiede to J.C. Keppler * (c): ' September 22, 1982 letter from C.E. Norelius to Cordell Reed (d): November 5, 1982 letter from W.L. Stiede to J.G. Keppler 6

Dear Mr. Keppler:

This letter provides a revised response to an item of noncompliance at Byron Station which was identified as y1alatinn_2 in reference (a). In references (b) and (d) we proposed actions to be taken to provide additional assurance that _ contractor avality control inspectors were properly trained and qualified or to assure that their inspections were

• valid. This le the previously tter documents proposed programs. an alternate plan which We believe supercedes this plan will satisfyinNRC part concerns presented in references (a) and (c) and clarified in discussions uith Region 111 personnel.

During the subject inspection the NRC found that the contractor programs for qualifying Q. A./0.C. personnel at Oyron were inconsistent eith .the r interpretation of the requirements of ANSI Na$,2,61978, ppecifTc,a(lly, they' found deficiencies in our contractor's evaluations of jinitial inspector capabilities, in documentation of initial certification , and in the criteris< osed to establish inspector guslification. The NRO did not find that these deficiences had compromised the quality of plant l instruction. In issuing a violation, however, they made it clear that ' she qualification programs were to be uDgraoed and the quality of work completed was to be verified in some manner.

           \ ,

E-15

                ...                                           /

g . J. G. Keppler . ' ' February 23, 1983 Before' explaining the program which we propose to implement in verifying the quality of the work completed, it is appropriate that we describe the history of changes made to the inspector qualification practices at Byron. This will demonstrate that we have always required qualified inspectors and that the contractor programs for inspector certification have been upgraded over the ye'ars to address the changing interpretation of the applicable industry standards. Certification Practices ANSI N45.2.6 is the standard applicable in establishing. qualification programs for nuclear power plant 0. A./0.C. personnel. Since its inception in the early 1970's the interpretation of acceptable application of this standard has evolved throughout the industry and at Byron. ' From 1974 to 1977 our contractors were required to develop quality assurance programs and procedures for certification of inspectors which were directed toward their specific contractual scope of work. The certification programs depended on training and experience as the primary basis for qualification in accordance with the intent o f ANSI N45.2.6-1973. To assure that the installations and inspections performed by the various contractor organizations were acceptable, the work was checked by

              , reinspections and surveillances conducted by an on-site independent                    i j

l testing contractor directed by the Commonwealth Edison Quality Assurance 2 i i Department and by tecWRTEal audits and surveillances performed by (ICommonwealth Edison Quality Assurance personnel. In 1979 and 1980 the contractors' programs and procedures for certification of inspectors were reviseo to adoress NRC concerns raisec in a 1979 inspection. The procedures were made more specific with regard to the basis for qua-lification and certification of inspectors; yet they remained directed contractor's specifictoward scopethe various activities associated with the of work. The work continued to be checked by the independent testing contractor's reinspections and surveillances and, the Quality Assurance Department's te.chnical aucits and surveillances.6 In early 1980 an audit was perforTed of the records of all inspectors who c were then certified to assure that their training, qualification and certification activities and records conformed to the augumented requirements established after the 1979 NRC inspection. The NRC reviewed' the results of this audit and the implementation of the augumented requirements and closed the deficiency identified in the 1979 inspection. We believed that our inspector qualification activities were acceptable eccording to the interpretation of ANSI N45.2.6 which was being applied at that time. ,, s ' In 1982 the NRC has again reviewed the programs for qualification and certification of contractor inspectors at Byron. They found that J m i f o ra-c+14etia h a d not be_en established for qualification of inspectors of various contractors that chose to develop alternate parameters and limitations. E-16

(- t ' l J. G. Keppler 3- February 23, 1983 l N45;2.6 specifically states that the parameters contained there are recommended and that alternate means are acceptable. The standard provides no guidance on development of the alternate parameters and limitations so the contractors each developed these dif ferently. The procedures and methodologies set forth by the various contractors have l been reviewed, approved and audited for compliance by Commonwealth  ! Edison. They all conform to ANSI N45.2.6-1978. As a result of various other inspection and audit results we are confident that the inspections were and are being performed in an acceptable manner. To address the inspector's concern, however, minimum parameters and limitations were established in April 1982 to institute a common basis for inspector certification requirements ror the various contractors. With input from NRC inspectors these requirements were further enhanced and reissued to the contractors on J_une 9. 1982. The applicable site contractors' procecures for qualification and certifi-cation of inspectors were- revised between July and September 1982 to incorporate these new requirements. To summarize, our contractors' inspector qualification and certification activities have been'upgraced to remain consistent with the ghanging internretation of er-anta51a annlication of ANST NL;_?.A. The ertification upgrading activities do not imply deficiencies in work reviously inspected. This conclusion has been verified through over-check inspections, audits, and surveillances. Procosed Corrective Action In responding to Violation 2 in reference (b) we established a program for assuring that all current inspectors are certified to upgraded requirements established in new contractor procedures. That program is not changed by this letter. A new plan has been developed to address the NRC's concerns regarding work perf ormed by inspectors no longer on site or inspectors wno cannot presently be shown to have been qualified. Details of this' plan are provided in Attachment A to this letter. Generally, we are proposing various reinspections which verify the adequacy of past QC inspector training / certification practices employed at Byron. For each site contractor we have delineated the manner in which construction quality would be reverified through reinspection of representative portions of the accessible work. In some cases reinspections which would accomplish this goal have been completed or are in progress. For other contractors new inspection programs are described here. We have delineated the scope of reinspections to be performed and the acceptance criteria which would be utilized. Schedules for this work have not yet

      ' 'en set. In the few cases where all of a contractor's work is
         . accessible for reinspection we have highlighted the oversight inspections and testing which provide addition assurance of quality.

E-17 I

2 . .

   ,    s<

6~ J. G. Keppler February 23, 1903 We understand that NRC concurrence in these corrective actions is necessary to close out this noncompliance. We also understand that the NRC may wish to identify up to three additional inspectors of eech contractor's work to be checked. The reinspection program would be . conducted most ef ficiently if these additional names were known at the outset of our records review. Please contact Tom Tramm with these names as soon as possible and no later than March 1, 1983. Please contact me if additional information is needed. Very truly yours, h* W. L. Stiede Assistant Vice-President TRT/lm Attachment

• 6029N E-18

I \ , l IU, I

  '$                                      BYRCN SITE OA SURVEXLLANCE l 3                                             AUDIT CLOSE OUT                  QG: 53.4          '

Report No. 5189 AUDIT No. 6-83-66 Date 10/12/83 Contractor / Organization: Hunter Corp. at // PINDING #1: P447' A Contrary to 10CFR50-B Criterion XV certain contractors were not taking appropriate measures to identify, document, segregate. disposition, and notify affected organizations of nonconforming items identified under the reinspection program. DISCUSSION: During the reinspection program, nonconforming conditions were identified which did not result in discrepancy reports being initiated. Problems with component support 2FP12016 were documented on Field Problem Sheet #FP109F rather than on a discrepancy report. No DR was issued for rejectable items associated with component support 2FP14056X because Hardware Removal Report ,

            #1380 has been initiated due to M ECN 52901 dated 6/22/83. The reinspection     .

for 2FP14056X was prior to the issuance of the ECN. The following mechanical joints failed to meet the specified torque of 70% of the initial value when reinspected: SSX 100-23 MJ177. SSX 100-23 MJ178. SAB 100-43 MJ23. SDO 100-34 MJ49: these joints were retorqued by production immediately following inspection. No DR's were issued to document this. Hunter Reponse Dated: 9/1/83 In relation to 2FP12016. at the time support was initially reviewed by Quality control. it was suspected that the support was installed outside of tolerances. Our Engineering Department was querried about the condition, and unknown to Qualty Control, the Engineering Department initiated a Fleid Problem which resulted in the ECN. At that point in time. Quality Contol was just beginning reinspection and the scenario for handling this type of problem may not have been finalized. DR number QC-2FP12-001 was initiated on 7/11/83 to resolve problems associated with this support. In relation to 2FP14056. reinspection was performed 6/7/83 and 6/8/83. The reinspection resulted in generation of Field Problem AB37580. S&L ECN 8233, and DR no. QC-2FP14-004. Hardware Removal Number 1380 and M ECN 52901 are associated with hanger number IPS190001 not 2FP14056. In relation to the mechanical joints, data has been turned over to PCD for evaluation of the phenomena associated with this problem. The evaluation will determine a course of action to be taken. ACTION TO PREVENT RECURRENCE: I None required. Reinspection is completed. l l Attachment F (1228S) 9

                          =

g e . Page 2 Surveillance Report No. 5189

• Hunter Corp.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: i Due to the isolated nature of the cited problembe inand actions compliance at taken s nce the actual time of the problem, we consider ourselves to this time. FOLLOW-UP: 10/12/83 - Reviewed Hunter Corp. discrepancy report QC-2FP12-0 (Attached) and QC 2FP14-004. Hunter Corp. discrepancy report cssociated with component support 2FP12016. Hunter Corp. has bolt torque QC-2FP12-004 is associated with component support 2FP14056X. received direction from CECO. pCD which enables them to considerS  ! inspections as inaccessible. I and S&L letter dated 9/14/83. This surveillance is closed. This closes Part "A" Findina #1 of Audit 6-83-66. ----- p

       ------------ --- ------- ..-------------- --------------- -------                      I g

Prepared by _ 4/ M Date //)MJMl_

                                                    ?, -

Date /#/,7 /f 3 Approved by

                                                  /

AJR:tj: 1228S L Attachments /C -/ P 9 D cc:Q.A.WWs

                                       /

37f D l# Supt./ File Contractor , Q.A. Audit Staff Jesg.  ! PCD St'pt . l Project Manager  ! AJR

                                                                                                       ]

F-2

r

                                                                                                                          .g
                                                   . D!SCREPANCY REPORT                                                  .L 2       ,

I ( A/fC HUNTER CORPORATICN e 7 DR k hhlb b'N - INITIATED AT INSPECTION TY C. M'-

   / .,,.dlNG NO. M b8/T O/0 8                    REV    g
                                                          /4       REWORK DRAWING NO.                        REV PROCESS SHEET NO                                         REV.            LINE NO @[O OCUMENTATION        AREA 816I     M eb                           /  /          '#[

l ARDWARE ogySE g , DISCREPANCY SKETCH ON B ACK L sa,- k & G & L A 's s 6s 2

                                         % Y / nr.s?2 N N b '8                   tDuditJAd,&Y                           &&
                    &                    ces.d_w I%-d{u#uo M MEnWI'                                                              \

oAMndt & ~ N d Ace W Y VP.df4 &n a//un' w

                              "          4LfffLJ J 2% W e/MAE                                                         # W f              ,shM ' '                                                                                      i
                                         -Q                                                                                       :
                                                                                                  ,,                              i
                                                                                                   .Qr yr           .

l J/NOn "2-l2/fo o>&Oauf Yd!-U Sdt7/583  ! N DA 3 PROD.OENGIOCA,cC0 Dic"REPANCY REPORTE BY - ~ f -' f 0/ V RESOLUTION bk k $&MWYk r 1

                   .v A^e, e

DATE O PRODUCTION

      . .,CREPANCY RESOLVED BY O ENGINEERING l

OA APPROVAL OF RESOLUTION DATE O OA/OC O MATERIAL CONTPCL j

                                                                                                                'C"" 4 '" " 3 * ' '

WHITE . O A N .OC GREEN . FILE CAH4RY . RESOLUTlON L____-____ - - - - . _ -

r-, , DISCREPANCY REPORT .ll--2 l G lo#Z . HUNTER CORPORATION DR bd . Ek/ . b'W INimTED ATINSPECTIONTYP

• CC/v4E' #E/MCPM WING NO. /Y8 OI REV C- REWORK DRAWING NO. 2//A REV. M ,

CROCESS SHEET NO A REV M LINE NO. DEN MI4 - /O RDWARE O DOCUMENTATION AREA b Y

• bl M M3O "8 M ** - bbd.

O SE DISCREPANCY SKETCH ON BACK y bUK1h4 AbtL kKlWSPretieAt of Mis N6tGER 7)TE }bacwNG NSunPAktks hlERE AltrEb : [inspreseo k 7Xcatv */13o w 4 2 met) .

                              ~

i 1Mr AIMc.UA4ptsD#dtst.ysiusngvn Ass 7Ns snmu!nq s Amss.

                          ; ave ac rue smakes ~ racmstie w rseMe atAtwr is suurev N $ Cdb ElfVAr>Ott W THE N/E SMeu/d if$5 '8"-                                     /r /5 N'S 6' 'I% ACTUAL .

Trm *A E JVHv /3 </0 Vrsrun rr /sSnre'b os u%B xicM*

l l Flo'- / lSycr krntirb /Er deh THE LgArrev #7")W JVSLb2 //As' W CWANGC5 (enp f/ cM 700 8Nb Bm e re Asrwsus - DISCREPANCY REPORTED BY 8 DATf: 7' ~ 3 PROD. ENG. O OA/OC b f., 1 AR AdiwA V y eaun afanv"H3E*" ~ f.f - f

                        /

l br5CnEPANCY RESOLVED BY DATE O PRODUCTION O ENGINEERING l l OA APPRO'/AL Or' RESOLUTION DATE O OA/OC O MATERIAL CONTROL WHITE . O A IN -OC FCW "C "* *1 " ' " CANp AY . RE SOLUTION CREEN . FILE

f

• DISCREPANCY REPORT E-2, 2 c. , ,  !

fiUNTER CORPORATION c On_ _. EM/b b#! INITIATED ATINSPECTION TYPF NW CC: N-O #'kA8dbCO ' A f 0 8 N REV d- REWORK DRAWING NO. A REV. # (. ING NO. [- t-r40 C S SHEET NO. N REV 4#!M LINE NO. N8 NO / O HARDWARE D DOCUMENTATION AREA 8[ / OyySE DISCREPANCY SKETCH ON DACK WO A3 PJjli-r uowr AeM 171cmces was Bezx rouus OV Nv' n f 7'HEcr trEn T. L tn * & Nov- Alf h)f L h$ t>! TYfM

• A _ABF EADL V (JNW

                   $4"W/M+%v[XtEss oc %a ~ nEd -ract1Amru er ne We s). '[dt WELb ON'TNE /WS/bd Of tnt *1'cy FLAAdifC D ' TTEN 'a av TW S.t. 9b6 mas acce/

W%Hsdv Sd to HMrs / % "tcivs 6s ex /Wn- //uvrn G7e. Dameare ' 01MA3r CR/m eV MAv hw Y1 /WWof h22

                                                                                                                          ~

19EAf l$ sudb,a;L-rnken - C Landa saw - CDs ' c

• l H 0L.n T A s ~ p.-1321 AM 1Eh $y 6W 13*rr 7-2-95 SOWf DATF 7~8 N 3 PROD U ENG. O OA,0C E DISCREPANCY REPORTED BY RESOLUTION 1

SCREPANCY RESOLVED DY DATF OPnNUC'M O rNGWff f 8WG OA APPROVAL OF RESOLUTION DATE _ O OA Ol' ['] t.t A li fi: AL Ct %1 stot CnCEN.rnt """"O einic . o A CANARY . RE SOLUTION Pm OC F-5

F - s mammmmme l

   -    H        -

l HUNTER CORPORATION 46323. (2t9) 845-8000 (3121731 8000 3800-179TH STREET. HAMMOND. INDIANA 4 \;

                                                                                               ;          //

September 15, 1983 '; / f Commonwealth Edison Company 4450 North German Church Road gs)\ Byron, Illinois 61010 Attention: Mr. R. Tuetken Assistant Superintendent Project Construction Dept. i

Subject:

NRC Reinspection Program, Piping System Bolt Torque Relaxat o Mr. Tuetken: (as it applies  ; In your opinion does the attribute of piping system bolt torque b to the NRC Reinspection Program) fall within the definition of inaccessible.. . Yours very truly,

                                                                . ,, h .  -

Id G LEE E. HADICK Quality Control Supervisor date 9by , _ G Yes @ No 4.J.A R. Tuetxen

n. ' qf /'# S e e. StA.1 "o5L l d.< o s

            "    ":hg5*9                   Ey. Qt <L h A tA s.fE .n,an l

I fi1e  % & LEH/pb F-6

                                       - -  ..a e = a N Catsc%a

I SAnozuT & Lc3DY

• ENGINEERS b FOUNDEDtoes f se CAST MONROC STREET CHICAGO. ILLINOIS 606C3 s s.s > ses socO September 14, 1993 Project Nos. 4391/4392-00 Commonwealth Edison Ccmpany Byron Station - Units 1 & 2 Flange Bolt Torque Relaxation Mr. G. Sorensen Cc=monwealth Edison Ccmpany Byron Staticn P. O. Box B  ;

Byron, Illinois 61010

Dear Mr. Scrensen:

At the request of Mr. R. P. Tuetken, we have reviewed the subject of flange bolt torque relaxation and determined that all flange bolts will experience scme degree of torque relaxation. The two mechanisms responsible for bcit torque relaxation are flange bolt relaxation and flange gasket creep and relaxation. Flange bolt relaxation normally results frcm piping system opera-tien (pressure and temperature effects) and operating transients.- Flange gasket creep and relaxation normally occur immediately following flange bolt torquing. Flange gasket relaxation may also result frca plant construction activities and system start-up testing. Even though the phencmena of flange bolt torque relaxatien is understcod, it is not possible to accurately predict the level of total bolt torque relaxation. In summary, flange bolt torque values will. relax over time. This will result in lower final bolt torque values than initially applied. If you have any additicnal questions on this subject, please call me. Yours very truly, hr4 2. @M Dennis De= css Mechanical Engineer DD:cl Copies: J. T. Westermeier D. L. Leone /W. C. Cleff R. Cosaro B. G. Treece

M. Lohmann R. J. Netzel R. P. Tuetken D. A. Gallagher

                 ,                   F F

hE.8. ! .A..Gr3iTe

                      -                                                                      r ,,., .g. .; ..g J~~-                                                                  PJ
    ,                 mmmmmmme                                                                                   l HUNTER CHORPORATION                                                                        1 l

38co.179TH STREET. HAMMOND INDIANA 46323. (2191845-80C0 #312) 731 8000 l HC-QA-412 Soptember 1, 1983 Commonwealth Edison Company 4450 North German Church Road Byron, Illinois 61010 Attention: Construction Quality Assurance Mr. A.J. Rosenbach Lead Auditor Subj ec t : Expanded Hunter Corporation response to your organizations report of Audit 6-83-66. References (1) Hunter Corporation letter number HC-QA-402 (which is superceeded by this correspondence)  ! (2) CECO letter number BY 9628 l Mr. Rosenbach:

           ' apologize for the failure to provide a response to observation 5 in letter
       .   .nber HC -Q A-402.        The responses for Finding 1 and Observation 1 are reiterated in this correspondence along with the response for Observation 5.

CECO Findino #1: Contrary to 10CFR50 Appendix B, Criterion XV, certain contractors were not taking appropriate measures to identify, document, segregate, disposition, and notify affected organizations of nonconforming items identified under the reinspection program. Discussion part A: During the reinspection program. nonconforming conditions were identified which did not result in discrepancy reports being initiated. Problems with component support 2FP12016 were documented on Field Problem Sheet #Fp109F rather than on a discrepancy report. No DR was issued for rejectable items essociated with component support 2FP14056X because Hardware Removal Report

      #1380 has been initiated due to W ECN 52901 dated 6/22/83. The reinspection for 2FP14056X was prior to the issuance of the ECN. The following mechanical joints failed to meet the specified torque of 70% of the initial value when reinspected:            SSX 100-23 MJ177, SSX 100-23 MJ178, SAB 100-43 MJ23, SDO-100-34 MJ49; inspection.

these joints were retorqued by production immediately following No DR's were issued to document this. F-8 CMsCaGO WNO'S MauvCp.o avosa%a CamiMaD Ca6soava

\. ' e

 'i    ter Corporation Response:

Corrective Action Taken and Results Achieved: In relation to 2FP12016, at the time support was initially reviewed by Quality Control, it was suspected that the support was installed outside of tolerances. Our Engineering Department was querried about the condition, and unknown to Quality Control, the Engineering Department initiated a Field Problem which resulted in the ECN. At that point in time, Quality Control was just beginning reinspection and the scenario for handling this type of problem may not have been finalized. DR number QC-2FP12-001 was initiated on 7-11-83 to resolve problems associated with this support. In relation to 2FP14056, reinspection was performed 6-7-83 and 6-8-83. The reinspection resulted in generation of Field Problem AB37580, S&L ECN 8233, and DR no. QC-2FP14-004.  ! Hardware Removal Number 1380 and W ECN 52901 are associated with hanger number 1PS190001 not 2FP14056. In relation to the mechanical joints, data has been turned over to PCD for evaluation of the phenomena associated with this problem. The evaluation will determine a course of action to be taken. .

                                                                                 ?

Action Taken To Prevent Recurrence:  ! None required. Reinspection is completed. [ e When Full Comoliance Will Be Achieved: Due to the isolated nature of the cited problem and actions taken since the actual time of the problem, we consider ourselves to be in compliance at this time. CECO OBSERVATION #1: Application of the term " inaccessible" to those items which receive multiple inspections does not correspond directly to the definition of " inaccessible" offered in the Stiede-Keppler letter dated February 23, 1983. DISCUSSION: According to the Stiede-Koppler letter, " Inaccessible shall be defined as: condition where dismantling would be required to gain access, or condition where process was an event which can not be recreated." When inspections of the same type occur after that inspection to be sampled in the reinspection program, the item of the original inspection is labeled by Hunter as inaccessible. For example, it a Type 3 inspection is performed in January, 1980 and a subsequent Type 3 performed in May, 1982, the one in 1980 is termed inaccessible. This is done without research to determine if the later inspection occurred as a result of rework etc. thus making the original inspection unrecreateable. I l F-9

\.

r O

       .1ter Corporation Response:

Corrective Action Taken and Results Achieved:

      -None required,   lhis approach was in accordance with Reinspection Interpretation #2, a copy of which is attached to this response.

Action Taken to Prevent Recurrence-N/A Date When Full Compli6nce Will Be Achieved: N/A CECO Observation #5: For some inspectors, the number of items reinspected, though in agreement with the Stiede-Keppler letter, do not provide an adequate sample size. Discussion: Observation #5 Part A ' Commonwealth Edison's Project Construction Department verbally directed all contractors, with the exception of PTL/ Peabody, to provide a minimum sample size of fifty (50) items. Of the five (5) Level II QC inspectors reviewed during the audit, three (3)- P. Pepitone, S. Kilpatrick, and J. (50) items reinspected. Ooten, didn't have the minimum of fifty Hunter Corporation Response: Corrective Action Taken and Results Achieved: Mr. Pepitone's data base was expanded to include his full term of employment as an inspector with Hunter Corporation. This resulted in reinspection of 51 of his inspections. In relation to Mr. Ooten and Mr, Kilpatrick, an inquiry was made to your organizations Quality Control Supervisor (Mr. R.B. Klingler) to obtain a disposition of their cases. A copy is included as Attachment 1. Action Taken to Prevent Recurrence: None required. Reinspection is completed. 1 a Date When Full Compliance Will Be Achieved: l We are in full compliance at .this time. 9 I I F-10 $ 1 1 l 1 l

5 g e-1

       .                                                                                                       1

( .-

      .o_

If'you-haue any questions or comments, please contact me.

          = Sincerely yours.

HUNTER-CORPORATION bW ~ M.L. Somsag

                          ~_- 2 Quality Ass      ce Supervisor
            .cc: K.R. Selman B. Krasawski L. Hadick M.L. Somsag CECO ~ Audit 6-83-66 jm i

1 i 4 i e l-a. 'l . a 4 T F-ll l l l l l

                                                                                                             .I 1
                                         ,   _     . _ . . . . . _ _ _ . . . ~ . - - . - . . . . - -   . . -

r ATTA & NM FNT 6

                                                                      /       7o       H c. da - qjz
   ,                _a H

HUNTER CORPORATION 3800- 179TH STREET HAMMOND INDIANA 46323 (219)845 8000 (312)731 8000 HC-QA-411 September 1, 1983 cc: R. Klingler K.R. Selman Commonwealth Edison Company L. Hadick 4450 North German Church Road M.L. Somsag Byron, Illinois 61010 Original to NRC Reinspection File Attention: Project Construction Department Mr. R. B. Klingler Quality Control Supervisor Subj e c t : NRC Reinspection Program Mr. Klingler: . In completing our reports for the subject activity it has been identified that we could not attain the minimum of 50 reinspections each for 3  ! individuals (R. Sturgess, J. Ooten and S. Kilpatrick) The quantities of reinspections that could be performed for each individual are listed below. P Sturgess (#9208) 19

      . oten                 (#1211)        28 S. Kilpatrick              (#1354)        30 In attempting to comply with the minimum of 50 reinspections for each of the 3 individuals. we expanded the 90 day time frame of each individual to their full term of employment as an inspector. As a result of these circumstances, I present the following inquiry.

Is it necessary to expand the inspector populatiun or will it be acceptable to let the record stand as is. Please indicate your responst in the area provided. Sincerely yours, ilUi4TER CORPORATION __ b h M.L.~ Som%g -

                                      ~

Quclity Assu nc upervisor CECO Response O Expand Inspector population. Record may stand as is. l R.S. K11'gler// n j Date 'hb Ceco Q.C. S gervisor . l 1 jm CM'caGO WNC's pauvowo poa%. a b causon% a

rV- -$ D BYRON SITE OA SURVEILLANCE AUDIT CLOSE OUT QG: 53.4 4 Report No. 5202R1 AUDIT No. 6-83-66 Date 10-13-83 Contractor / Organization: Hatfield Electric Co. FIlOING #1: TWT S Contrary to 10CFR50 Appendix B. Criterion XV. certain contractors were not taking appropriate measures to identify, document, segregate, disposition, and notify affected organizations of nonconforming items identified under the reinspection program. DISCUSSION: During the reinspection program, nonconforming conditions were identified which did not result in discrepancy reports being initiated. Field problem sheets were being implemented to resolve reinspection items in the conduit and terminations area. The field problem sheet is not proceduralized. Hatfield Response Dated 8/04/83 CORRECTIVE ACTION: Field problem sheets were generated for conduit items which could easily be corrected by the area foreman in a short time period. Some items were corrected immediately, the balance is being checked for completion. All field

;     problem sheets are filed to verify that all corrections were made. Field problem sheets were generated to C.E.Co. OAD to find out if they had made a change to the wiring diagram as the items in question were turned over to the owner.

NCR #674 was written to correct this problem. ACTION TO PREVENT RECURRENCE: Instruct inspectors not to use field problem sheets. FOLLOW-UP: 10/13/83 HECo. NCR #674 was written to disposition the deficient items discovered during termination inspections. This NCR was closed 8/22/83 (See attached). Discrepancies which had been identified on field problem sheets were included in the results of the reinspection program as submitted to CECO. PCD. A review of the reinspection program reports submitted for E.A. Durras. J. Buchanan. K. Cripps. E. Getzelman. H. Holze and F. Keep revealed field problem sheets to be included. The inclusion of field problem sheets with the reinspection program reports enabled CECO. pCD to make a determination concerning the acceptability of inspections which resulted in field problem sheets being generated. This appears to be an isolated case which has been adequately resolved. (1237S) Attachment G

                                                      . .i Survaillanca R^ port No. 5202R1 P ge 2 Hatfield Elcctric Company i

This surstillance is closed. This closes the Hatfield portion of Findinq #1 Audit 6-83-66. Prepared by A>L Date / 4!/1 Approved by 9 ate /c -n-P3 AJR:je:1237S

                                / f.95h cc: W.J.-shewski /. . S . Mn1 0.A. Supt./ File Contractor Q.A. Audit Staff Desg.

PCD Supt. Project Manager AJR i G-2

m

                                                                                                 "                   I oJPds.s'i 3'C'V
                                                      %. s'.M ig%c    -

M) o

                                                             ' NONCONFORM4SCE REPORT                                                                   ~              #

REPORT

./                                                                                                                               HOLD TAG No.

b7b l P.O. No M/A MRR No.X/.A MSR No "/f Material: Vendor M /1 383 Columns 15 _ a N O Elevation Eguipment: Drawing 1 h665A R ev. 1AP22E Compt. A1 Equipment Description

                                                                                                                                                     ,- 21,e       gn, Tha w"S"E agastat was installed in ecrpT A1 d eqw i n e.

l Nonconformance: n 7n??AC. hut GAD fumi ehed n 7012AC which woe ivete11ad.

                                   <<' W(/W/ *      .]       <@.                                                     Date:           9 #-b5    -

Observed By-m Co e A Ma,a,e,

                                                                          ~/F                                        Da,e e-<-e>

awIb/[< w .s Y e e,,ce. s .

                                     $/                                 4 .er ll.       Corrective Action:

c , o e es s k

                                                                  /       '

APA # ESS~ C e /h , *n +$e 0 Ah \l <l a r , m .s..,, w

• i m r= r-c~~+ U

                                                                                 ,s-.

O L:t;r.n\ .:.i;r.n vi ?-3,y. }: l f* 7' 1983 R J4 L.!i.li AUG 15 s Action to Prevent Recurrance: M/S ., m vsu w=x ccw= e May FroceedWith The Fo :o ing P trictions: Work: May Nct Pro:eed av P

                                                                                          ..           nMD O C5't!qi De.n n -
                                             -g(-/{l-                 g-I Date.       WE'/f.3                          lI Aporowed by CECO FCD                    -

_ CECO Hold Tag No ( 4 CECO NCR No. 0 K 2-23 l Concurred By CECO Q. A.: -% thb Date: Date. 9'N '8 113. Corrective Action Completion Verified By: -/ Action To Prevent Recurrence Comoieted

                                                                                                             #                                             g,,y y - $ 3 f

Verified By: , j

                                                                                   ^
                                                                                                                                               O'

• He'd Tag Remo.ed By*

9-x 43 NC9 Close out Reviewed By: _@A *',0/"',f (Level lipt Higher) [fG-3 O'* Page 1 of I

7

w. O BYRON SITE OA SURVEILLANCE y

 .                                     AUDIT CLOSE OUT    F1 f 05         QF: OG 53.4    h  ,

Report No. 4939 AUDIT No. 6-83-66 Date 08/26/83 Contractor / Organization: Pittsburgh Testing Laboratories FINDING #1: Contrary to 10CFR50-B, Criterion XV. certain contractors were not taking appropriate measures to identify, document, segregate, disposition and notify affected organizations of nonconforming items identified under the reinspection program. DISCUSSION: At the time of the audit. PTL had not yet transmitted open inspection reports generated because of the reinspection program to the appropriate contractors. Therefore, no corrective action has been taken for the apparently nonconforming conditions. PTL Response: Corrective Action Taken: PTL will transmit reports with nonconforming conditions to the respective contractors through the normal transmittal system. Action to Prevent Recurrence: PTL was working on the premise that reports with nonconforming conditions would be reported to the contractors upon full completion of the reinspection program. PTL has since been advised to transmit nonconforming reports upon concurrence with Mr. M. Provenzano. S&L Representative. As this appears to be an isolated incident, no further action is necessary. Date of Full Compliance: August 8. 1983 , FOLLOW-UP ACTION: PTL has started transmitting tejectable reports to BBC. The first transmittal was #10479 dated 7/1/S3. The latest was #18828 Dated 6/19/93. This process is ongoing. This was determined by reviewing PTL transmittal log and trans'nittal. Attachment !! (1040S)

i i l P;g? 2 l Survaillance Report No. 4939 PTL 1 s OBSERVATION #3: (response PTL) PTL is not reinspecting each individual inspection performed during the inspector's first three (3) months, where accessbile. DISCUSSION: For inspectors certified in several disciplines within the three month time frame, only those inspections in the area of the original certification during the first 90 calendar days were reinspected as opposed to "each individual inspection performed during the inspector's first three months" as cited in the Stiede-Keppler letter dated February 23. 1983. An example of , this situation would be if an inspector was originally certified in one type ' of inspection and later certified in a second type of inspection, the first certification was reinspected. The second type of inspection was not reinspected even though certification and inspections within that area may have taken place during the inspector's initial 90 days. PTL is not reinspecting each individual inspection performed during the inspector's first three (3) months, where accessible. Corrective Action Taken: PTL is now reinspecting each individual inspection performed during the inspector's first three (3) months, as directed by Commonwealth Edison via the Stiede-Kepplor letter 2/23/83. Action to Prevent Recurrence: A complete review of selected inspectors certification package to determine what discipline (s) those individuals were certified in during initial three (3) month period. Date of Full Compliance: August 8, 1983 Observation #3: " The only inspector who had two (2) different certifications and was chosen for the reinspection program was S Cushman. This was researched by M. I Tallent, FTL Site Manager and D. Smith. Unit Ccr. cept Supervisor. The type inspection reinspected was visual weld inspecticn. The certification which also occured during Cushman's first 90 days was concerte expansion anchor installation. Concrete expansion anchor torque checks were inspected by { Cushman due to relaxation torque checks are nonreproducable. l l H-2 (1040S)

( l Paga 3 Surv2illanca R: port No. 4939 PTL 4 This surveillance is closed. This closes the PTL portion of Findinq #1 and Observation #3 of Audit

   #6-83-66.

Prepared by $ f$ 4 /[bnwhgate If f) Approved by . Date $'36 83 AJR:tj:1040s 0 y"-fi- Q cc: 'J. J. .;,ki/J M nital Q.A. Supt./ File Contractor "3RD' c . : e.U 0.A. Audit Staff Desg. PCD Supt. Project Manager AJR l l H-3

s BYRON SITE OA SURVEILLANCE x 6 .: P AUDIT CLOSE OUT QG: 53.4 Report No. 5188 . AUDIT No. 6-83-66 Date 10/12/83 contractor / Organization: Hunter Corp.

           -- __- --_________- - = ====_________==                      ===

l 1 OBSERVATION #1: l Application of the term " inaccessible" to those items which receive multiple inspections does not correspond directly to the definition of

      " inaccessible" offered in the Stiede-Keppler letter dated February 23, 1983.

DISCUSSION: Observation #1 Part A (Hunter Corporation) According to the Stiede-Keppler letter, " Inaccessible shall be defined as: condition where dismantling would be required to gain access, or condition where process was an event which cannot be recreated." When inspections of the same type occur after that inspection to be sampled in the reinspection program, the item of the original inspection is labeled by Hunter as inaccessible. For example, if a Type 3 inspection is performed in January, 1980 and a subsequent Type 3 performed in May, 1982, the one in 1980 is termed inaccessible. This is done without research to determine if the later inspection occurred as a result of rework etc. thus making the original inspection unrecreateable. Hunter Response: Dated 9/1/83 None required. This approach was in accordance with Reinspection Interpretation #2, a copy of which is attached to this response. ACTION TO PREVENT RECURRENCE: N/A DATE WHEN FULL COMPLIANCE WILL SE ACHIEVED: N/A FOLLOW-UP: i 10/12/83 - Per R.B. Klingler. CECO. PCD, the Hunter Corp. application of interpretation #2 (See Attached) is correct. When subsequent inspection of the sane type occured. the later inspection was reinspected and the earlier inspection is considered inaccessable. Attachment I (1227S) r

r I f 9:g2 2 5 Surveillance Report No. 5188 p' Hunter Corp. 1 This surveillance is closed. j This clos'Es Part A of Observatien #1 of Audit #6-83-66. Prepared by /Ef/ vV-n2 Date /()b 4// 3 f / Approved by <[,I[AI Date k/15/83 AJR:tj:1227S s' Attachment fy/*g

                         "/

cc: W.J. ski M el Q.A. Supt./ File ' p. g-7,.y Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager AJR 1 1 l I-2 i 9

BYRON SITE OA SURVEILLANCE // 3/b" AUDIT CLOSE OUT C QG: 53.4 s._. / Report No. 5210 AUDIT No. 6-83-66 Date 10-14-83 Cont ractor/Or.,:3nitation: Hatfield Electric Co. OBSERVATION #1: Application of the term " inaccessible" to those items which receive multiple inspections does not correspond directly to the definition of

              " inaccessible" offered in the Stiede-Xeppler letter dated February 23, 1983.

DISCUSSION: According to the Stiede-Keppler letter. " Inaccessible shall be defined as: condition where dismantling would be required to gaAn access, or condition where proce::s was an event which can not be recreated." Hatfield was using the term inaccessible to disposition reinspections to which this definitien does not apply. The example noted during the audit was. Hatfield had termed those items with subsequent inspections as inaccessible without determining if the original inspection was an event which cannot be recreated because of rework, design change, etc. Hatfield Response Dated 8/4/83 Items which could not be physically reached or where conduits and hangers had been changed per print revisions. FCR's or ECN's and had been reinspected at a later date were inadvertently noted " Inaccessible" during conduit reinspection. This was an error in terminology and actually the items were non-retrievable. All items noted incorrectly as " Inaccessible" had been researched and the original inspections could not be recreated. FOLLOW-UP: 10/14/83 The error in terminology has been resolved via the research performed by Hatfield. In:gections which cannot be recreate'! are prcperly termed "inaccess2ble". OBSERVATION #8: Hatfield Electric could not determine if a portion of the conduit

           $nspection is subject to the rejnspection program.

Attachment J (1240s)

 ,      Surv3111&nca RIport No. 5210

• P g2 2 Hatfield Electric Company 4 l 1

DISCUSSION: Torque checks in the conduit area were determined to be non-reproducible inspections: despite this, bolt counts were taken during reinspection. The . l bolt count was included in the original conduit inspection to determine the  ! proper number of torque checks to perform. Differences in bolt counts between ' the original inspection and the reinspection are being entered as rejectable items in the reinspection program. These items are remaining open due to i confusion on how to disposition them. Hatfield Electric Company needs to determine if bolt counts should be a part of the reinspection program and. if so. how to resolve these items. Hatfield Response Dated 8/25/83 Bolt counts will not be inclLded as part of the reinspection criteria. Differences in bolt counts on the reports cannot be investigated since both the original inspector and report reviewer are no longer employed by Hatfield Electric Company. FOLLOW-UP: 10/14/83 The elimination of bolt counts from the reinspection program has resolved / this deficiency. / This surveillance is closed. T_his closes Observation #8 of Audit 6-83-66. This closes Observation #1 Part B of Audit 6-83-66. Prepared by [* ' Date te[ 7/,c 3 Approved b hat Date /o - M -L3 AJR:jc:1240s N

                          'j1 cc: W.J. S5ewstTTL E m ted O.A. Supt./ File                                                                     '

Contractor Q.A. Audit Staff Desg.

    .      PCD Supt.

Project Manager AJR J-2

SW .( h o BYRON SITE OA SURVEXLLANCE U AUDIT CLOSE OUT ' g QG: 53.4 i Report No. 5211 AUDIT No. 6-83-66 Date 10-14-83 contractor / Organization: Hatfield Electric Co. OBSERVATION #2: Hatfield has not performed an evaluation of QA/QC Memorandum #295 for its potential effect in the reinspection program. DISCUSSION: Hatfield Electric Company QA/QC Memorandum #295 dated 9/17/82 states that an acceptable weld inspection of cable pan or conduit hangers implies verification of the correct connection detail. This manner of acceptance occurred when the cable pan or conduit hanger inspection could not verify the detail due to the presence of fireproofing. Due to the fact that the reinspection program requires re-creation of the original inspection, a determination must be made as to what type of inspection, either weld or hanger inspection, originally included the connection detail. After this determination is made, the connection detail can be included as an element of the proper type of reinspection. Hatfield Response Dated 8/25/83 Fireproofing was removed on All items which had to be reinspected for the program. If it was the pan hanger detail itself or a weld traveler to be reinspected, the material was removed so that the connection detail or the welds could be inspected as individual attributes. Memo #295 was not considered during the reinspection. Hatfield Response Dated 8/30/83 Please be advised that connection detail verification is originally included in hanger inspection report.

 . FOLLOW-U?:     10/14/83

' / The determination by Hatfield that the c nnection detail verification is ' part of the hanger inspection closes this deficiency. 4 f I Attachment K (1241S)

Survaillcnca R: port No. 5211 ' Page 2

- Q Hatfield Electric Co.

This surveillance is closed. This closes observation #2 of Audit 6-83-66. Prepared by *

                                             . dM d     #          D     /*[' 7[85>

Approved by w% Date lo -e7-y3 AJR:jc:1241S y //-7-Y ') cc: W 1- Rhew h l Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager AJR ( l K-2

   )     %

et $ $) BYRON SITE CA SURVEILLANCE AUDIT CLOSE OUT QF: QG 53.4 N Report No. 4939 AUDIT No. 6-83-66

• Date 08/26/83 Contractor / Organization: Pittsburgh Testing Laboratories FINDING #1: Ow.T" C Contrary to 10CFR50-B. Criterion XV. certain contractors were not taking appropriate measures to identify document. segregate disposition and notify affected organizations of nonconforming items identified under the reinspection program.

DISCUSSION: ' At the time of the audit. PTL had not yet transmitted open inspection reports generated because of the reinspection program to the appropriate contractors. Therefore, no corrective action has been taken for the apparently nonconforming conditions. PTL Response: Correctivo Action Taken: PTL will transmit reports with nonconforming conditions to the respective

       $      contractort through the normal transmittal system.

Action to Prevent Recurrence: PTL was working on the premise that reports with nor. conforming conditions would program. be reported to the contractors upon full completion of the reinspection PTL has since been advised to transmit nonconforraing reports upon concurrence with Mr. M. Provenzano. S&L Representative. As this appears to be an isolated incideat, no further action is necessary. Dato of ru_l! Cempliance: August 8, 1983 FOLLCW-UP ACTION: PIL hus started transmitting rejectable reports to BBC. The first transmittal was #18479 dated 1/1/83. The latest was #19828 Dated 8/19/83. This process is ongoing. This was determined by reviewing PTL transmittal log and transmittal. Attachment L (1040s)

   ?

r

• Page 2 '

e Surveillance Report No. 4939 PTL OBS response PTL) PTL is not reinspecting each individual inspection performed during the inspector's first three (3) months, where accessbile. DISCUSSION: For inspectors certified in several disciplines within the three month time frame, only those inspections in the area of the original certification during the first 90 calendar days were reinspected as opposec to "each individual inspection performed during the inspector's first three months" as cited in the Stiede-Keppler letter dated February 23, 1983. An example of this situation would be if an inspector was originally certified in one type of inspection and later certified in a second type of inspection, the first certification was reinspected. The second type of inspection was not reinspected even though certification and inspections within that area may have taken place during the inspector's initial 90 days. PTL is not reinspecting each individual inspection performed during the inspector's first three (3) months, where accessible. Corrective Action Taken: PTL is now reinspecting each individual inspection performed during the q

      ,s inspector's first three (3) months, as directed by Commonwealth Edison via the

( ,) Stiede-Kepplot letter 2/23/83. a Action to Prevent Recterence: A complete review of selected inspectors certification package to determine what discipline (s) those individuals were certified in during initial three (3) month period. Date of Full Comoliance: August 8. 1983 Observation #3: The only inspector who had two (2) different certifications and was chosen for the reinspection program was S. Cushman. This was researched by M. Tallent. PTL Site Manager and D. Smith, Unit Concept Supervisor. The type inspection reinspected was visual weld inspection. The certification which also occured during Cushman's first 90 days was concerte expansion anchor installation. Concrete expansion anchor torque checks were inspected by Cushman, due to relaxation torque checks are nonreproducable. 4 m v L-2 (1040s)

1

'          Pago 3 Surveillance Report No. 4939 PTL e,
    #          This surveillance is closed.

ThisclosofiiiePTI.portionofFindinc#1andObservation#3ofAudit

           #6-83-66.

Prepared by [fdb[d /[dradgate 8 //!/,7 Approved by .- A Date 8*3 0 #S AJR:tj: 1040s o  ! f3/M cc: W.J. " s 1/J.S. Bitel Q. . Supt./ File Contractor M .A. Audit Staff Desg. PCD Supt. Project Manager AJR - l l 1 J ' L-3

) h'Cfilf5 t 79 BYRON SITE OA SURVEILLANCE AUDIT CLOSE OUT QG: 53.4 Report No. 5187 AUDIT No. 6-8' 66 Date 10/12/83 Contractor / Organization: Hunter Corp. OBSERVATION #5:  ; For some inspectors. the number of items reinspected, though in agreement

 ,with the Stiede-Keppler letter, do not provide an adequate sample size.

DISCUSSION: Observation #5 Part A Commonwealth Edison's Project Construction Department verbally directed all contractors, with the exception of PTL/ Peabody, to provide a minimum sample size of fifty (50) items. Of the five (5) Level II QC inspectors reviewed during the audit, three (3): P. Pepitone. S. Kilpatrick and J. Ooten did not have the minimum of fifty (50) items reinspected. Hunter Corporation Response: CORRECTIVE ACTION: Mr. Pepitone's data base was expanded to include his full term of employment as an inspector with Hunter Corporation. This resulted in reinspection of fifty-one (51) of his inspections. In relation to Mr. Ooten and Mr. Kilpatrick, an inquiry was made to your organizations Quality Control Supervisor (Mr. R.B. Klingler) to obtain a disposition of their cases. A copy is included as Attachment 1. ACTION TO PREVENT RECURRENCE: None required. Reinspection is completed. DATE WHEN FULL CCMPLIANCE WILL BE ACHIEVED: We are in full compliance at this time. FOLLOW-UP ACTION: 10/12/83 - Reviewed records of individual reinspections submitted to CECO. PCD by Hunter Corp. P. Pepitone. Emp #1284. had a total of fifty-one (51) inspections reinspected. Per R.B. Klingler, CECO. PCD, the number of inspections for Ooten and Kilpatrick were determined to be acceptable. (See attached Hunter Memo HC-QA-411 dated 9/1/83) Attachment M (1226S) t a

[ P;g2 2 Surveillance Report No. 5187

   ,       Hunter Corp.

This surveillance is closed. This closes part A of Observation #5 of Audit #6-83-66.

           -----------==- ===-__

_=__ _ _=__=_-

                                                                   +. _ _ _ _ _ - .

Reported by M' Date /C f//f Approved by 4 Date to/<7/f 7

                                                                 /                          '

AJR:tj: 1226S Attachme * /-/ #' / cc: W.J ski / QA Supt./ Site Q.A. File 4 giM. k//') Contractor PCD Supt AJR

                                                                                                              't l

e M-2 e

 ',                                                                                                       Q.P. FORM 18                                 Commonwealih                    Edison Company                             DAM _ 9 /Wel                            l GUALITY AGGURANCE MANUAL                                                     <'s      4 AUDIT REPORT                                                      ,

l

#6-83-93 -

f Type Audit: / / Program Audit / / Product Inspection Point

                 /   / Records          XX /Special To:

R. B. Klingler, PCD QC Supervisor Project Byron Visit Date11/14-17/83 Report Date 11/28/8-System N/A Component Identification N/A Material Description N/A Vendor N/A Location N/A Subcontractor N/A Location N/A Contacts See Attachment "B" P.O. No. N/A Spec. No. N/A Recommended Inspections: 6 mos 3 mos 1 mo Other: As specified Please respond with Notes: 1. Corrective action

2. Action to prevent recurrence 3 Date of completion for the above items for Finding

                                  #1 by December 15, 1983 Prepared by               -

Date // 83 Auditor .' Date #[//#5 J . Hale - Lead Auditor Reviewed M A. b e DateIdi93 ' LAS:tj:0437A Attachments

                                                     ^ --

O cc:  !" N i ElUh Man 2cer Projects Project Mann;;er Enr; . Manager Director CA Ccnstruction - Site Construction Superintendent 3 Site QA - ~ ~ - - - - " - - ~ ' l Auditee - -~ ~ " ~~ Site CA Supervisor Attaphment N l JSH - ~

                                                                                       ~      .   -
                                                                                                                                                  \

1 if QUALITY ASSURANCE AUDIT BYRON SITE REINSPECTION PROGRAM NOVEMBER 14-17, 1983

                                              #6-83-93 INTRODUCTION AND PURPOSE:

From November 14 to November 17, 1983, the Commonwealth Edison Byron Quality Assurance conducted an audit on the Byron Site's Reinspection Program. The purpose of the audit was to assure that conclusions drawn from the Reinspection Program are valid and reliable. SCOPE: The scope of the audit covered the following areas:

1. Accuracy of Reinspection Program results as reported to the NRC in the Interim Report.

2. The design basis for the engineering evaluation of Visual Weld Inspection Discrepancies as described in the Interim Report.

3. Qualifications of the third party inspectors.

4. Documentation of third party inspections.

5. Basis for PCD " Interpretations" in regards to the Reinspection Program.

6. Correction of deficiencies identified as a result of the Reinspection Program.

AUDIT AGENDA: An entrance meeting was conducted and the audit started on November 14, 1983. The audit lasted four (4) days with two (2) exit meetings held on November 17. 1983. Attendees of entrance and exit meetings are listed in Attachment "A". A list of those personnel contacted during the audit is given in Attachment "B". AUDIT TEAM: The audit team consisted of J.S. Hale. Lead Auditor, L.A. Simon. Auditor and T.J. Mitoraj Observer. N-2 (0437A)

          .                                                                                                           j l

Page 2 Audit No. 6-83-93 l* Byron Reinspection Program l GENERAL EVALUATION: The following four (4) areas were reviewed at each of the seven (7) contractors involved in the reinspection Program.

1. Correction of discrepancies - All contractors with the exception of PTL and Hatfield Electric Co. were found to have identified and have or are correcting deficiencies in accordance with their approved nonconformance procedure. PTL and Hatfield have taken these actions on some deficiencies but have refrained on items in which an engineering evaluation is to be performed.

2. Expansion of an inspector's reinspection sample size and the number of inspectors to be reinspected upon a failure as defined by the Stiede-Keppler letter of February 1983 - All contractors were found to have expanded sample size accordingly with those results given in the Interim Report.

3. Independence of the Reinspection Personnel - The reinsepction personnel at /

each contractor were verified to have not been involved in the reinspection of work that they had originally inspected or had reviewed ,/ and accepted.

4. Accuracy of results reported in the Interim Report - The items reviewed during the audit at all contractors matched up with the exception of JCI and PTL. Differences identified at these contractors are discussed in Attachment "C" under Observation #1 and Finding #1 respectively. '

Also reviewed during the course of the adult were the following areas which were directed towards the Project Construction Department in their implementation of this program. The engineering evaluation of the Visual Weld Discrepancies performed by Sargent and Lundy was reviewed for adequate design basis. Calculations which support the evaluation were performed in accordance with appropriate

              " Structural Design Standards" and the approved Design Control Summary. The Design Control Summary outlines assumptions to be followed in performing the calculations. These assumptions appeared to be based on industry standards and practices. This approach was presented to the NRC on September 22. 1983.

Those individuals who performed the third party review of subjective deficiencies were properly qualified for the task. Additionally, adequate documentation of these inspections exists. Lastly, those Interpretations offered by the Project Construction Department during the Reinspection Program have adequate basis and fall between the guidelines of the program. N-3 l (0437A) l

Page 3

• Audit No. 6-83-93 Byron Reinspection Program ASSESSMENT:

On the basis of this audit. it appears that conclusions drawn from the Reinspection Program results will be valid and reliable. N-4 (0437A)

Page 4

    .      Audit No. 6-83-93 Byron Reinspection Program l

ATTACHMENT "A" BYRON REINSPECTION PROGRAM AUDIT #6-83-93 ENTRANCE MEETING 11/14/83 NAME TITLE ORGANIZATICN J.S. Hale Lead Auditor CECO. QA L.A. Simon Auditor CECO. T.J. Mitoraj Observer CECO. R.B. Klingler PCD QC Supervisor CECO. EXIT MEETING 11/17/83 NAME TITLE ORGANIZATION J.L. Woldridge QA Supervisor CECO. E.L. Martin QA Supervisor CECO. R.B. Klingler PCD QC supervisor CECO. J.S. Hale Lead Auditor CECO. L.A. Simon Auditor CECO. W.E. Wolber QA Inspector CECO. M.R. Tallent Site Manager PTL D. Smith Supervisor PTL S. Pearson QA Level II JCI R.L. Byers PCD Field Engineer CECO. R.H. Bay QA/QC Manager BBC T.J. Mitoraj Observer CECO. l l l I i I N-5 l l

(0437A)

r Page 5 Audit No. 6-83-93 6 Byron Reinspection Program ATTACHMDir "B" BYRON REINSPECTION PROGRAM AUDIT #6-83-93 PERSONNEL CONTACTED DURING AUDIT Name ORGANIZATION R.B. Klingler CECO. PCD R.J. Netzel S&L R. Marshalla S&L S. Bertheau S&L S. Pearson JCI D. Smith PTL M. Tallent PTL W. Wills BBC M. Provezano S&L l l { N-6 l l (0437A) .

V- }

                                                                                           \

• l t 1 Page 6
• Audit No. 6-83-93 Byron Reinspection Program ATTACHMENT "C" BYRON REINSPECTION PROGRAM AUDIT #6-83-93 OBSERVATION #1 - JOHNSON CONTROLS INC.

Although minor, discrepancies exist between the number of subjective rejections identified by third party inspector and those given in the Interim Report. gf Discussions: b The Interim Report listed S. Pearson as having thirty-two (32) subjective rejects. A review of the documentation of third party reviews showed their concurrence on thirty-two (32) welds and twelve (12) items. At the time of the audit, it could not be determined if the items were applicable to subjective reject. Additionally, D. Lindblom was accredited with only twenty-one (21) subjective rejects: third party concurrence was received for twenty-three (23) welds. Corrective Action: JCI will review the results and make any needed correction to the numbers given by December 1, 1983. Action To Prevent Recurrence: N/A FINDING #1 - Pittsburch Testina Laboratory contrary to Stiede-Keppler letter dated February 23, 1983, during reiterations of the Reinspection Program, Pittsburgh Testing Laboratory overrode third party concurrence on some welding rejects.

      ,                                                                               I g

Discussion:

• After implementation of Interpretation 11 given in the Reinspection {

Program which changed the visual weld inspection criteria in the areas of overlap and undercut, a review was performed by PTL on reinspections performed for applicability of the interpretation. In this review. PTL changed the deficient status of some welds which were rejected for reasons other than those changed by the interpretation. The welds had already received third party concurrence for true rejectability as defined in the Stiede-Keppler letter of February, 1983. Request response providing Corrective Action and Action to prevent Recurrence. (0437A) e

l dlt J

                     ,                                                                                                I BYRON SITE QA SURVEILLANCE                                C AUDIT CLOSE OUT                         QG: 53.4 Report No. 5696                         AUDIT No. 6-83-93                            Date 1-17-84 Contractor / Organization:              Pittsburgh Testing Laboratories FINDING #1:

Contrary to the Stiede-Keppler letter dated February 23, 1983, during reiterations of the Reinspection Program, Pittsburgh Testing Laboratory overrode third party concurrence on some welding rejects. DISCUSSION: After implementation of Interpretation 11 given in the Reinspection Program which changed the visual weld inspection criteria in the areas of overlap and undercut, a review was performed by PTL on reinspections performed for applicability of the interpretation. In this review, PTL changed the deficient status of some welds which were rejected for reasons other than those changed by the interpretation. The welds had already received third party concurrence for true rejectability as defined in the Stiede-Keppler letter of February, 1983.

RESPONSE

CORRECTIVE ACTION: Pittsburgh Testing Laboratory will resubmit for concurrence by the independent third party inspector those PTL overcalls which changed the deficient status of welds rejected for reasons other than those addressed by Interpretation 11. ACTION TO PREVENT RECURRENCE: Contractors involved in using interpretations and independent third party l inspections were directed on December 12, 1983 to carefully watch the possibility of contractor second reinspection due to an interpretations without allowing the third party to concur or disagree. FOLLOW-UP ACTION: 1-17 Corrective action is not yet completed: per E. L. Martin, due to activity surrounding license denial, completien date was extended to January 22, 1984. Attachment O (1664S) _1

l

   .       Survaillt_nce R1 port No. 5696 Page 2
          -Pittsburgh Testing Laboratory      ,

DATE OF NEXT FOLLOW UP : I-%e-S b

                                              ,- (   .

I Prepared byJ 2 b. O t?'/70 Date / 7Y-[Y ., Approved by d 5-AfhDate 1 2. s,. -a 4_. p c: LAS:jc:1664S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.

;               PCD Supt.

Project Manager LAS f i' l i I i i C-2

. Surv2illcnce R; port No. 5696

  / Pige 3                                                                           1 Pittsburgh Testing Laboratory v'

FOLLOW-UP ACTION: 2-06-84. 2-07-84 and 2-13 Compared information found in the third Party Inspector's log to that information given by PTL in their reinspection package. This was performed on J. Brown's reinspection package. This revealed that several reports were missing from the reinspection package: 2457, 2494. 2517, 2521. 2491. 2506. 2489, 2378. 2387, 2521. and 2496. These reports are being located and included in the reinspection , package. Additionally a review will be performed to locate any additional reports for Brown's package and those that might be missing from other packages and to verify the packages are then complete. Additionally, concerns were raised regarding the second reinspection by the third Party Inspectors. Documentation for eight (8) reinspection reports of Brown was not available at PTL to indicate that the third Party Inspector concurred with all resubmitted reinspection reports. 2-14 A review of the aforementioned eight (8) reinspection reports of Mr. Brown verified that the third Party Inspector had reinspected the following seven (7) reinspection reports: (2493. 2470. 2490 (2). 2468. 2384. 2397 and 2432). Report 2495 could not be reinspected due to a beam removal. 2-22 A review of Mr. Brown's reinspection package verified that all of the previously missing WI reinspection reports were new in his package. Additionally a comparison was conducted of forty (40) WI reinspection reports listed in the third Party Inspector's log with those maintained in the respective reinspector's package. All items were found in the packages. All corrective actions appear to be prcperly implemented. Findinc #1 of Audit No. 6-83-93 and this surveillance are closed. F/U Action Verified }NE Date : - 11 24-F/U Action Approved a Mt e Date't/7*k'i Q. A. Superv3,sor

                     .d f LAS:jc: 1664S cc:   W.J. S d i/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.

PCD Supt. project Manager LAS O-3

  ' .o                                                                                              f Letter No. BY        10312 Date      December 30. 1983 TO:       R. B. Klingler, PCD QC Supervisor

SUBJECT:

Response to CECO. Audit #6-83-93 The Commonwealth Edison Company Quality Assurance Department has received your response dated 12-22-83 to the subject audit and find it acceptable. This i acceptance is conditional based upon satisfactory cemonstration of corrective action and preventative measures concerning the deficient items. A follow-up surveillance will be performed by site QA personnel to close all open !. deficiencies.

                                                                     . , .:. d    (.c L ad Auditor l\ . (I ,1 a. 2[M     ef. ha K. J. Hansing         ()

i QA Superintendent

                                                     ,5 (1400L)       p     /.//                u Fl u)Ny cc: W.Jv--5tnMmet/G.F. Marcus (w/co     of response)

V.I. Schlosser (w/ copy of response) G. Sorensen (w/ copy of response) Site File

;            Site Audit Designee L.A. Simon 4

1 i 0-4

C' C:mm::nw=lth Edis:n . Byron Genirs. ting Station -

 ',                              P.O. Box 8 Byren. Ilhems 61010                                                                                                                        ,

e --

                                                                                                                                                                                                            --#~"

g.. 4 1 u

                                                                                                                   *G.a.w.     . . . o. .r
                                                                                                                                               ;m
                                                                                                                                               .m,       1. *$ .:. 1
                  . v.        u. . e. a . . .a. e . . 3

-.vv. ~. ~w.... . ~ . . . p ,. s

                                                       -e                      . e. .h. e. . ..

r.... ... 5 )...

             .    . . e . ,. ~.ss na   . o. ...e. .
             .C. ".. _: s' " .* *. ..         O. . ,.:, ..
                                                        * . e a..e. a.    * . ***
                                                                            .1.      ..

g ' s. " , *. 7 O. .* ....3 , . o. d'..4e.

                                    .         d.
                                                         . . . c. a..          ... .e.. 04.+e...r..e.
                                                                                                                          . a. .c. . .d e.
                                                                                                                                                 '..g*=,...
                                                                                                                                                      . . . ....      j   . v.a. . . . e s.
               -.      ? . .e.       ' e. . e g ' (r
                                     .                        . o. e. z
                                                                      .        .e n. .ae. .. ,. . a. .. o.
                                                                                                        ..  . e. g ..
                                                                                                                         ..s..              .T * ,.m..,
                                                                                                                                                   ,         v... 2 y..e.,.
                                                                                                                                                                         ... n, , ,. .y. .. .. .. e. .e r.*. 3. g . .. .,,. .. .. . . ,     .2...
                                                                .a. .

s /

.=.

ch.z

                                                                                                                                     .  ..,.     ...e ..

w:2.e3 . a

                                                                                                                                     .e'.,......e
                                                                                                                     . . e ..
                                                                                                                             . e. wt' s. c.   ..
                                                                                                                                               ... e. .

M' s. s. . e >. .p.e.

                                       . o.

0 0.. .'.* !i..

             ..            r. .
                  .e         O.
                             .<         . y. 6. A.p. . n.
                                *.      .-4
                                            ..

• 4.,..

I Lv) \ 1 0-5 1 1 l l i l l l

o e e .

 \

r. *.".n,

                        .      '1 y. c. 41 _ 0 .4 , e.. mw.                                    .>

e.> . . . .ea +. 4A .e. . ,. '. .a. .. w p 3 . . e.f. Centrary . . t o t *.e S t 4.ia.

                                                                  .                     d a. 7 2. r . ' e - l e *. .a. . d.3 *. a. d .r a.
                                                                                                                                                                                                         ^
                                                                                                                                                                                 . " .-"s' - .-"j 3 , '. o, ..,               ; ' d. . . g-    . .

re.4.ee3 . . .. ec 4 .e.a- ss . . . e g. a. t. .e..e r e r. *. 4 a~.

                                                                             ,w

e. .. Or - tp, , D .4..~ss . * * - -. . pw- . *. e c *.. .e. s ' , w. . .e m. . . .,. . ...

C V a. * .* O d. a. 'w Y4.' .# # ".'**."j r . r."..".*'r."*.*.*.a. ". r. o' w' ~.a. 'a' a. .' d .* '. .;'

• a. ,' a. ." *. s" .

n w a. ~.~.aa.... . . e e 4 . e. .. g e6 s.g .e 4

                                          ... e'. a. n. . . o. .e. s. 34...r..                 v.r .'.e.n.g e. ea. ...,.~.4. . .9 .' .t g .4 . c. e.. . <p. ...e. a =. . a. 4.e., .- - e . 4....,.e w n w-w                                               . , 4...p . . n .- ..14 P .e e e. e.s .a. _.             . e. 4                  .. e. .
                                                                                .           a. ..e..     . ..                           a..
                                                                                                                                                          . .e. .er- e.....-

4

                                                                                                                                                                                       .e.      .c ...
                                                                                                                                                                                                   .4 . , e .43             n        .u.: . m. -ra. _ . .c -

C./ o. e.sar ae.a. . . s. e. a. a. e e . , , 3 r e. .. 4. a. ,a. ..e . v. e.. .=. s. -f ;.~.*- ns.e. w.

                           .                        .                        . ..                                                 acs e re e.r                                                                  ep
                                                                                                                                                                                                                .   .4e.s-y. ....e. .. a. .e .

o .. ec * .h a. .' *. *. a..c

                                                                                                                                                                                                                                                               ~

f v.. e. -- ..e. a. c.e 3rr a .4e,w414.~ i

                                                                             -- .. .j                       v.                          .           " " ". e *. 3 *..' ^. r. .               A' ."6 ****
                                                                                                                                                                                                      ....s            ".e".'.a.".., .:~*          ..

Ch . g- a. d. *

• a. da..'...'a".*. $ *. 3 *. '.' S C .# _w...

                     . 3 ".                    ... .                                   .
                                                                                                                                     ****              ".a....' 'a' r. .' ." ". ". a.. a a. r a. .t a. " * *. .' .'v'"
                                                                                                                                                                 .                     .           .                                       .          ".=.*...."..'.
               ,a
                . .*.e. a. e.          *..b. 3 n. . * ..                        ew.

F.e. .e n. w . . n e. . ., m .a w. , .j *... > s. d.. e. s. .r. s. v e r o.s*. = =.. 4 e. e. ..

• f.g a g .' a. .a F. - a

                                                                                                                                                                                                                            . -          n'.
                                                                                                                                                                                                                                         - . c o. .. * "e.

pa. .~ a. 4 *; g .* *+. ....e.n. ~3.*.. e. .~ e. e . . e .e p e. . e. s. d

r. ~. .e m..e.a . o. .e a. , y s. , 9 .4 .'4.. . , . u, .e a e

r . . .s. . 4:..

                                                                                                                                                                                                                               . . .e. n.               .
                 *. f. a. J' s. . a. 4 a....pr.

4

                                                            . ;' : * * ' s.. .eg.' s. e. g .e v.                e r T o.
                                                                                                                           .   . m e. s    n. .
                                                                                                                                        . .e..,              1
                                                                                                                                                             . 3,. .* n m.g e O.O. r. .O..$

Ch. .e -n .. g eb. ..e

                                               .          n%. . 6. . 4. p. .

p

               -r...,*,.e.,
                     . . ..                   g..         e....r...
                                                                                       . ,.  . . e  . .n... p. .,. .4i... r....w...
                                                                                                                                                       .- . . .              c. v, e. e. . p. e. . . e o. e. m. a.

e..

                                                                                                                                                                                                                               .;       ...e. 2 4

4.e. 4 s. e g ..e. .Ja n. e. . b. e. ..ca..

                                                                 .                 **ee..,.
                                                                                                         .d .e. e. g . m. % .c m. .e. n. .= 2
                                                                                                                                                                    . . ' . v=.g e a. g .' .' m
                                                                                                                                                                                    ..                         .e. 4

• e.

e. .ae. u* a. . . .e. s.

                           ....e...                                                                                               e. . . *=c M. a.

• 4 4 g.  % .g'.. ge g. e.g..... . g e. . ., _ e.

m 3 6. ..a w .# .s ... e. .

n. v. . e. . ..ge a. .w~g e. a o. %.... . c 3 G . .. e. . o. .a 3. 4 me.

                                                       .y        "e>3ec
                                                                 .....p.           e g e.    .
                                                                                                       ..e.     . ...

M.4 .m...e ~~'se .dr.. 6..= O. v. a. . . n. .e. ..C. a. .s.

                                                                                                                      . e e.a. e. .. . c .

C w. p. m. .e ..n a o. s ..e4 c= m e e.J

                                                    . .       4 e..w..
                                                                 .      . . ' . . s. 4  .      e  e.     .4..g                 4. .e. n. g e v a. e.
                                                                                                                                        ..p.

• 4.e.e..., g 3 .,. 4

                                                                                                                                                                                   .            d e. 4 3.p..
                                                                                                                                                                                                ..           = g e.. .. n. e. *. . w.   . .

e 4

               -s. . .

p.e*.. 4 .e. ema w y . e. b. 4 .a e. . w.g a. .p 3 4 4 .e g. e. *. 3. M. a e.

                                                                                                                                     ..        " g . ; . .m a. .e d...

7

                                                                                                                                                                             .w e        *".,$.."

w e. q.qep. .O!e. ..j

                                          *wg                                                            c N E...                     b...            m f e. .e ..     .4 w i .' .4 .. .
                                                                                                                   .c...e....e.
                                                                                                                               .d...                   d     . . c. 4 3...               p p        .
                                                                                                                                                                                       ...p     3.   .. 4  e. r. r    4 ,.. a. 6.        g.e.

4e.e. =. 3. e.m.. e. g... $. ,..4 .m e. w. a . . . .,,,

                                                                            .4
                                                                                    . . . . . .          q 4.e* 1 . .*o. 4 c. g.         e. ..., 3      e. p s . 4...e.    ..go...

r w. g aw e.. e. . . .. . . e e w.Se 44 L. ..e.a.a..

               *,*a U..               *..' r. . o. e. ,.T4. . '. i.

a

                                                                               . . '. 4 , e.e. . ' *4J .1 '. Sg

• w.w4 v.. . . . .. . 3_ . . s. 4 p .ma .

g [ d .e.J. i *i .e'. j g g .Y.- . e O-6

x Q.P. FORME: 2,. -- DATE R/4/81 Ccmmonwealth ?5s) Edison Company s QUALITY ASSURANCE MANUAL -# AUDIT REPORT '

                                                          #6-83-124                                              e I

Type Audit: / / Program Audit / / Product Inspection Point

                         /   / Records              /v /Special To:

Mr. J. T. Hill Project Pvron

                                                                , Visit DateA/?4 o /1/c2 Report Date o /4 m / 2 System _. Various                       Component Identification N/A Material Description                N/A Vendor        Hatfield Electric Co.                  Location             B'n on Subcontractor N/A                                    Location          ' N /A                  -

Contacts cae oe-e * . P.O. No. Spec. No. F-?'709 Reco= mended Inspections: 6 mos 3.mos 1 mo Other: As Scheduled Notes: Corrective actions have been agreed upon during the exit meeting. However, please respond by October 4, 1983 to indicata-J -. . the date corrective actions will be complete for the Findings; Lead Auditor _ Ne Date 9!/f 3

     ---                                                 Reviewed N d >            44u                 _Date 709/8' 3 H. A. Stanisn PTM:jc:0298A Attachment cc: thragcr          C' 2 7 -$]                            P.T. Myrda Manager Projects                                        G.F. Marcus (Byron Site)

Project Manager Eng. Manager Director CA Construction Site Construction Superintendent Site QA i Auditee Attachment P Site CA Superviser l

AUDIT CEPORT HATFIELD ELECTRIC COMPANY AUDIT NO. 6-83-124

Purpose:

To verify proper implementation of Hatfield Electric Company Quality Assurance Program as applicable to the QC inspector reinspection program committed to in NRC Report I&E Inspection Report Numbers 50-454/82-05 and 50-455/82-04. Scope: The audit included the following: Inspection Inspection. Test and operating Status Quality Assurance Records Reference Documents: 10CFR50 Appendix B. Criteria X. XIV. XVII Hatfield Procedures: 9A Entrance Meetino: August 24, 1983 P. T. Myrda QA Supervisor C.E.Co. M. V. Dellabetta QA Engineer C.E.Co. T. Maas QC Supervisor HECo. J.D. Spangler Lead Welding Inspector HECo. Exit Meetinc: September 1. 1983 J. S. Bitel Director. QA Const/Eng. C.E.Co. M. A. Stanish QA Superintendent C.E.Co. P. T. Myrda QA Supervisor C . E .Co . R. G. Gruber QA Engineer C.E.Co. R. Tuetken Assistant Project Superintendent C.E.Co. J. O Binder Project Electrical Supervisor C.E.Co. R. B. Klingler PCD QC Supervisor C.E.Co. J. T. Hill QA/QC Manager HECo. J. D. Spangler Lead Welding Inspector HECo. Personnel Contacted: HECo. T. Hill T. Wells T. Maas S. Hubler A. Koca D. McCarty J. D. Spangler P-2 (0298A)

Audit R: port No. 6-83-124 9:g2 2 Hatfield Electric Company i An entrance meeting was held on August 24, 1983 at the Hatfield Electric Company. Byron office during which the audit areas were discussed. During the audit a total of three discrepancies were identified. The discrepant items will be explain ~ea in m . m ... " . " , Another aspect associated with the concerns related to the reinspection program is the identification of deficient conditions. The issuance and processing of NCR's and DR's will be covered under a separate surveillance. ADEQUACY OF REINSPECTION This audit examined Hatfield Electric Co. 's implementation of Commonwealth Edison's reinspection commitment made to the NRC. The audit specifically examined the welding area and Hatfield's methodology of reinspection in this area. The reispection program's main thrust is to demonstrate the adequacy of quality control inspectors. Based on this. it is essential to ensure the work reinspected is actually the inspector's work and not that of someone else. During the audit. problems were identified with the method used to document cable pan hanger weld inspections (ref. Attachment "A"). As a result of these documentation problems, adec"=*= traceability back to the inspector's work was not always_ achieved. In cases where it was Indetae.minate as to wn2ch welds were inspected by the inspector, the contractor identified these welds as unretrievable and removed them from the reinspection population in accordance with the guidelines of the reinspection program. In all cases reviewed during the audit, the decisions made by the contractor during the reinspection program to remove questionable data adds to the credibility of the database thereby ensuring accurate results. The ultimate sample size used for each inspector was found to be adequatt and sufficient to determine the acceptability of his work. AUDIT DEFICIENCIES During the field verification part of the audit. it became apparent that j Hat field Elect ric Company's weld traveler cards. in certain cases. lacked ) , adequate information to determine which hanger welds or hangers corresponced l to each weld traveler. In certain cases. it is the lack of a definite ' one-to-one correspondence between the weld traveler and the component that creates a problem in determining the status of the cable pan hanger inspection. (Ref: Attachment "A", Finding #1). This audit also included field verification of combination cable pan /HVAC hanger inspection completeness. Upon reviewing the records for combination hangers. it was determined that not all welds on these hangers have been inspected. For some hangers that were inspected. the QC inspector was not identified on the weld inspection record. (Ref: Attachment "A". Finding #2) (

                                                   ~

(0298A)

7

     ..                                                                                                       1
   . Audit Report No. 6-83-124 Page 3 Hatfield Electric Company a

Also, during the field verification part of the audit. forms 9A-1 (Configuration / Dimensional Inspections) were reviewed to help establish correlation between hanger welds and weld travelers. During this review a I hanger was found to be installed. inspected and accepted to a configuration other than shown on the approved drawing. (Ref: Attachment "A" Observation #1) 1 ANALYSIS OF INSPECTION RECORDS Hatfield Electric Company is currently implementing a computerized database management system in an effort to reconcile weld travelers to cable pan hangers. This database is being created in parallel with the reinspection program. When the information from the computerized database is finalized and , ready for use. the weld travelers usad in the reinspection program will be compared to the database. This should insure that the initial hanger inspections assigned to each inspector, were correctly included in the reinspection program results. The manner in which weld inspection records were generated and maintained at Hatfield makes it difficult to readily identify the specific work which was done by welders and inspectors in past years. As a result, personnel not familiar with all aspects of the record keeping process may misunderstand the manner in which the weld traveler records were selected during the reinspection program. It is expected that these concerns will be resolved when the computerized database is completed and the identification of past work performed by welders and inspectors is readily obtainable and easily understood. l The RDRF Form (Hanger Dehang/ Rehang) which covers rework on hangces, has been used for rework performed since November 1981. Prior to November 1981. Hatfield procedures did not require the HDRF Form to be used and therefore. It

was not used in all hanger rework situations. When the computerized database 5

is completed it will provide additional means to retrieve inspection information and the HDRF Forms will no longer be the only means of tracking hanger rework. j EVALUATION The Hatfield Quality Assurance organization agreed with the problems identified during the audit and showed initiative in identifying the weld traveler problems by writing NCR 701 on August 23, 1983. The HEco. QA/QC inspectors demonstrated an excellent working knowledge of their respective areas and presented an eagerness to do an effective quality job. Overall, the HECo. QA/QC Department, as applicable to this audit, appears to be effective in the performance of their responsibilities. Hat field Electric Company Quality Assura-ce Department is adequately implementing their portion of the reinspection program as committed to in NRC Report I&E Inspection Report Number 50-454/82-05 and 50-455/82-04. The 1 deficient items identified in this report did not impact the purpose of the reinspection program but were significant deficiencies that require prompt attention. (0298A) P-4

I I Audit Report No. 6-83-824 Page 4 Hatfield Electric Company 4 ATTACHMENT "A" Find!nc #1: 10CFR50 Appendix B. Criterion XIV. states in part. " Measures shall be established to indicate, by the use of markings such as stamps tags. labels, touting cards, or other suitable means, the status of inspections and tests performed upon individual items of the nuclear plant... These measures shall provide for the identification of items which have satisfactority passed required inspections and test...." 10CFR50 Appendix B. Criterion XVII. states in part. " Sufficient records shall be maintained to furnish evidence of activities affecting quality." Contrary to the above. Hatfield weld traveler cards inadequately identify / the acceptability of the cable pan hangers. Discussion: The weld traveler cards used by Hatfield for weld inspection. in many cases, do not adequately identify the item inspected. The problem stems from the variety of ways the weld traveler cards is filled out by field personnel. Essentially. general field coordinates are used to locate the hanger (i.e. 15-N) instead of the exact coordinates. Also, there is no method of assuring hanger. all welds are inspected, especially if rework is performed on a given Additionally, the weld traveler may document one or two connections or the whole hanger. The only way to determine the exact status to which a given hanger is inspected ?.s by field verifying the weld traveler card, the hanger in the field, and the welder identification stamped on the hanger. Af ter this field analysis, the inspection status for a given hanger can be determined. In some cases, even field verification falls to adequately assure the completeness of inspection and a reinspection is necessary. Corrective Action: A correlation of weld tratoler inspection data to design drawing cable pan hanger data : fill be established using computer database management techniques to demonstrate accountaillity of inspection. This demonstration of accountability of inspection identifies the welder (s) and inspector (s) who worked on the component. l For those components which no correlation exists between component and ' inspection data, an inspection will be initiated. The acceptability of existing inspection records will be domonstrated by the adequacy of the inspection data created by those components for which no i correlation existed. If this data is insufficient in site or inconclusive. j additional components will be added to the sample. P-5 (0298A) m

l Audit Report No. 6-83-124

  ,     Page 5 Harf10ld ElSctric Company 0    Findino #2:

10CFR50 Appendix B. Criterion X. states in part. "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity." Contrary to the above, no weld travelers were written to document the work performed by Reliable Sheet Metal welders on combination hangers. Discussion: Not all combination hangers have weld traveler cards for welding performed by Reliable Sheet Metal. For some hangers that do have weld travelers the weld connection is indeterminate due to the lack of information on the traveler. Also, some weld travelers do not identify the QC inspector performing the inspection. Corrective Aetten: A review performed. of all combination hangers for adequate weld inspection will be f the welds will be those For hangers whose status is indeterminate a reinspection off performed. Commitment Date: To be established af ter scope of work is defined. Observation #1: Contrary to Hatfield Electric Company procedure 9A Revision 11. Class I Cable Pan Hanger Installation. quality control had inspected and accepted a hanger to the wrong dimensions. Discussion: QtI f rWh Hanger 15H2 on Drawing 6E-0-3033 Rev. H was inspected and accepted (HECo. Report 835) to the dimensions for hanger type 635H whose dimensions are different f rom those of a 15112. Correettve Action: Hanger 15H2 on Drawing 6E-0-3033 Rev. H is going to be reinspected and an addition sample of ten (10) hangers whose hanger type has changed will be reinspected to determine the extent of this problem. Commitment Date: October 3. 1983 P-6 (0298A)

                                                                                        }

T A BYRON SITE OA SURVEILLANCE f q/q ' p AUDIT CLOSE OUT QF: 2790.22.1 Report No. 5275 AUDIT No. 6-83-124 Date 10/21/83 Contractor / Organization: Hatfield Electric Co. FINDING 161: 10CFR50 Appendix B Criterion XIV, states in part. " Measures shall be established to indicate, by the use of markings such as stamps, tags, labels, routing cards, or other suitable means, the status of inspections and tests performed upon individual items of the nuclear plant... These measures shall provide for the identification of items which have satisfactorily passed required inspections and test...." 10CFR50 Appendix B Criterion XVII, states in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality." Contrary to the above, Hatfield weld traveler cards inadequately identify the acceptability of the cable pan hangers. Discussion: The weld traveler cards used by Hatfield for weld inspection, in many cases, do not adequately identify the item inspected. The problem stems from the variety of ways the weld traveler cards is filled out by field personnel. Essentially, general field coordinates are used to locate the hanger (i.e. 15-N) instead of the exact coordinates. Also, there is no method of assuring all welds are inspected, especially if rework is performed on a given hanger. Additionally, the weld traveler may document one or two connections or the whole hanger. The only way to determine the exact status to which a given hanger is inspected is by field verifying the weld traveler card, the hanger in the field, and the welder identification stamped on the hanger. Af ter this field analysis, the inspection st **us for a given hanger can be determined. In some m ses, even field verif; cation fails to adequately assure the completeness of inspection and a reinspection is necessary. Corrective Action: A correlation of weld traveler inspection data to design drawing cable pan hanger data will be established using computer database management techniques to demonstrate accountability of inspection. This demonstration of accountability of inspection identifies the welder (s) and inspector (s) who worked on the component. For those components which no correlation exists between component and inspection data, an inspection will be initiated.

                                                               \

s\' (1275S) Attachment 0

i \ ! , Pag? 2 Surveillance Report No. 5275 HECo. The acceptability of existing inspection records will be domonstrated by the adequacy of the inspection data created by those components for which no correlation existed. If this data is insufficient in size or inconclusive, additional components will be added to the sample. ACTION TO PREVENT RECURRENCE: New cross reference will eliminate this type of problem. FOLLOW-UP ACTION: The component correlation has been completed and 599 components have been identified as requiring inspection. Preparations for reinspection are inprocess. DATE OF NEXT FOLLOW Up : 11/2/83 Prepared by [N5'b Date /ed-5/c _? Approved by . Date AldL5 PTM:tj: 1275S cc: W.J. Shewski/J.S. Bitel Q.A. Supt./ File Contractor l Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM Q-2

i l

• [, Pag? 3 l Surveillance Report No. 5275 HECo.

FOLLOW-UP ACTION: 11-02 HEco. QC reverified the items requiring inspection. This resulted in a new total of 669 hangers to be inspected. The reinspection of 75 hangers is complete and 54 are rejectable. Hatfield is going to track the quantity of welds inspected to welds rejected in order to get a more accurate status of the actual weld rejects. FOLLOW-UP ACTION DATE: 11-16-83 F/U Action Verified NN1. Date / M F/U Action Approved .[. h Date //!4 /23 0.A. Supervi e PTM:tj:jc: 1275s cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM Q-3 l l

   ,    Page 4 Surveillance Report No. 5275 HECo.

FOLLOW-U? ACTION: 11/16/83 - To date, two hundred forty (240) support hangers have been inspected with two hundred ninty-two (292) hangers left to be inspected. One hundred eighty-three (183) hangers hav been deleted from population because the original hanger has either been deleted or changed in type. For the two hundred forty (240) supports inspected six hundred seventy-one (671) out of three thousand five hundred two (3502) welds, which is approximately 19% have been rejected on initial inspection. These totals include ccmbination hangers. DATE OF NEXT FOLLOW-UP: Lt.3 0 - e 3 F/U Action Verified MO# Date //['d/# 7 F/UActionApprovedkO.

• Date i .11 }5 '

C.A.Superqor PTM:tj: 1275S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor 0.A. Audit Staff Desg. PCD Supt. Project Manager PTM l i I l Q-4 I

• s ,( ,

r

1 Page 5 Surveillance Report No. 5275 HECo. FOLLOW-UP ACTION: 12/2/83 - To date, 373 hangers have beer' inspected out of 677 hangers. The total welds inspected are 4016. Of these, 789 are rejected which is 20.7% l ,

        /

reject rate. The totals presented =do not include combination hangers. DATE OF NEXT FOLLOW-UP: e2 e4-P3 I F/U Action Verified .!M/ Date N /.r/ D F/U Action Approved . A - Date/J//Me d.A. Supervjsor , PTM:tj: 1275S l' cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager. PTM 4 i ( k b Q-5 a i _-____-_1____,--_--_-___-______--__--

1

                         -                                                                                        l Pag) 6 Surveillance Report No. 5275                                                              )

[i s HECo. ) t- , D FOLLOW-UP ACTION: 12/16/83 - To date. 379 weld traveler supplements have been inspected out of 527 weld traveler supplements with 150 supplements deleted. Most of these deletions are due to hanger removals. The total welds inspected are 5338. Of % these, 1036 are rejected which is 19.4% reject rate. The totals presented do t not include combination hangers. ,

   ?
                    +
                      , F_OLLOW-UP ACTION DATE:          ' t- %o- 4 3
                                                               < '~7      _ ,, .

F/U Action Verified M d _I ' k " I -' k , Dat e 'l - 2 c -7 F/U Action Approved b ilkw2 1 r. Dateahe[M Of.A.Supervis6} gg PTM:tj:jc:1275S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt.

 ,d Project Manager PTM
    .) ..+

s l l 3 1: . Q-6

   . Page 7                                                                        l Surveillance Report No. 5275 HECo.

FOLLOW-UP ACTION: 12-30 83 150 weld traveler supplements are remaining to be completed. To date a total of 5358 welds have been inspected. Of this total, 997 welds were rejected by HEco. resulting in an 18.6% reject rate. Of the 997 welds rejected by HECo., 721 welds were determined to be rejected by S&L third party review which is a 13.4% reject rate. Note: these numbers reflect a decrease in total rejects. A recount to verify status numbers is currently in progress. FOLLOW.UP ACTION DATE: /- e3 - o 4' F/U Action Verified I E. Date //rv/fr 4 F/U Action Approved A . e w. Date //,. /J4

                                            'Q. A. Supd}rl visor PTM:tj:jc:12755 cc:  W.J. Shewski/G.F. Marcus Q.A. Supt./F11e Contractor 0.A. Audit Staff Desg.

PCD Supt. Project Manager PTM Q- 7 1 i l

l Pag? 8  ! Surveillance Report No. 5275 l HECo. FOLLOW-UP ACTION: 1-13 To date, 416 weld traveler supplements out of a total of 512 1 have been completed. A total of 5566 welds have been inspected with 770 welds rejected by S&L. This represents a 13.8% reject rate. This work item is 82% complete with an expected completion date of 2-4-84. FOLLOW-UP ACTION DATE: J-7 Ju

                                                            '2<rt                        .

F/U Action Verified 'A 7i Date '6 - 3 *-

                                                                      ~

F/U Action Approved ( ' 1. -W. Date t /,'1/4 4

                                                               'Q.A. Supervasor PTM:tj:jc:1275S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.

PCD Supt. Project Manager PTM Q-8

Pagt 9 Surv3111ance R: port No. 5275 HECo.

                                                                                 )

FOLLOW-UP ACTION-  ! l 2/6/84 - No change in work progress due to change in priorities. I Reinspection efforts were concentretad on the NRC Reinspection I&E Report No. 50-454/82-05 and 50-455/82-04. The reinspection has restarted today 2/6/84. NEXT FOLLOW-UP DATE: E-8# F/U Action Verified l k Date 1 - ? e e/ F/U Action Approved '/ d e a Date 2 /<r /c Q.A.SuperWJsor PTM:tj:jc:1275S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM 0-9

Pigi 10

• Surveillance Rzport No. 5275 HECo.

FOLLOW-UP ACTION: 3-09 Currently, two (2) welds remain to be inspected. Additionally, a final review and reconciliation of all previously reinspected weld travellers will be completed by 3/30/84. NEXT FOLLOW-UP DATE: 7 - 60 64 F/U Action Verified ' in E Date S -l Z. -f I-F/U Action Approved ^' ' I':- - Date O.A. Supervisor PTM:tj:jc:1275S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM Q-10 l

~ l

                                                                                           )

PIq2 11

Surveillance Report No. 5275 ,

HECo. I e, FOLLOW-UP ACTION: 4-06 Hatfield Electric Company, on March 31, 1984, completed the cable pan hanger weld inspections for which no inspection record existed. These inspections were done for those components for which no correlation of weld traveler inspection data to design drawing cable pan hanger data existed. Inspection records for cable pan hanger welds are up to date and satisfactorily reflects the current status of work. The deficiencies identified during these inspections are in process of being corrected using the contractors normal rework practices. This rework amounts to approximately h 13% of the total welds inspected and in the auditors judgement is indicative q of first time inspection. p Therefore, with the cable pan hanger weld in::pections current and inspection reports existing in the contractor's records system, the corrective action required for this audit item is considered complete. This audit item is consideted acceptable and closed. This surveillance is closed. F/U Action Verified N M . Date d h *

                                        ,./

F/U Action Approved D M " C Date f-H d Q.A. Supervisor PTM:tj:jc:12755,,g cc: W. A cb R4/G.F. Mar M Q.A. Supt./ File Contractor

                                     '    g\ \Y     f 0.A. Audit Staff Desg.

PCD Supt. Project Manager PTM l l Q-ll

g g l1h"

   ',                                        BYRON SITE OA SURVEILLANCE                              ,

Y g AUDIT CLOSE OUT QF: 2790.22.1 Report No. 5274 AUDIT No. 6-83-124 Date 10/21/83 l Contractor / Organization: Hatfield Electric Co. FINDING #2: l 10CFR50-B, Criterion X, states in part. "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions. procedures, and drawings for accomplishing the activity." Contrary to the above no weld travellers were written to document the work performed by Reliable Sheet Metal welders on combination hangers. DISCUSSION: Not all combination hangers have weld traveller cards for welding performed by Reliable Sheet Metal. For some hangers that do have weld travellers the weld connection is indeterminate due to the lack of information on the traveller. Also, some weld travellers do not identify the QC inspector performing the inspection. CORRECTIVE ACTION: A review of all combination hangers for adequate weld inspection will be performed. For those hangers whose status is indeterminate a reinspection of the welds will be performed. FOLLOW-UP ACTION: All combination hangers have been identified and seventy-one (71) require inspections. These hangers are being processed for inspection in conjunction with the hangers identified in Finding #1. DATE OF NEXT FOLLOW UP : 11/02/83 Prepared by . [<, Date fbf/$l Approved by . M Date,_/d,_K,/>3 PTM:tj: 1274S ,- V cc: W.J N ewski/J.S. Bitel Q.A. Supt./ File Contractor , M ' Q.A. Audit Staff Desg. i PCD Supt. kg Project Manager PTM Attachment R

Pag) 2 Surveillance Report 5274 HECo. FOLLOW-UP ACTION: 11-02 Field verification of combination hangers reduced total to 60 hangers. Two combination hangers currently in process of inspection. FOLLOW-UP ACTION DATE: 11-16-83 F/U Action Verified Date /'!>/M F/U Action Approved .h Date//f/M Q.A.Supervig PTM:tj:jc: 1274S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM i R-2

1

  . Pig 2 3 Surveillance Report 5274
 . HECo.                                                                                                                                       ,

1 1 l FOLLOW-UP ACTION: 1 l 11/16/83 - To date a total of ten (10) combination hangers have been inspected. See Surveillance Report No. 5275 for inspection results. DATE OF NEXT FOLLOW-UP: \1- 3o - 8 '3 F/U Action Verified. Date //[/t/#3 F/U Action Approved D Datethat/@'4 ' *

                                                                   'Q.A.Supervpr PTM:tj: 1274S cc:       W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.

PCD Supt. Project Manager PTM R-3 1 l l 1

l l Page 4 Survaillanco Rnport 5274 HECo. i FOLLOW-UP ACTION: , 1 l l 12/2/83 - To date, ten (10) hangers have been inspected out of sixty-five (65) hangers. The total welds inspected are 382. Of these, 124 are rejected which is 32% reject rate. These totals are for combination hangers only. 8 DATE OF NEXT FOLLOW-UP: /2-# M F/U Action Verified ' v_! k. Date 42/.2/'J F/U Action Approved M !.1'Ot 4 Date11/Cy'3

                                                'Q.A. Supersisor                    '

PTM:tj:1274S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM R-4

Prg) 5 Surveillance Report 5274 HECo.

        ' FOLLOW-UP ACTION:

12/16/83 - To date, twenty (20) hangers have been inspected out of 1 I sixty-five (65) hangers. The total welds inspected are 842. Of these. 197 are rejected which is 23.4% reject rate. These totals are for combination hangers only. I FOLLOW-UP ACTION DATE: 17.-3+ s3

                                                                                                           )

F/U Action Verified fh $IL Date 4/P/#1 / F/U Action Approved /)'r/ . u [w, Date 1.2/4 4 3 Q.A.Superjisor PTM:tj:jc: 1274S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM R-5

1 Page 6 Surveillance Report 5274

  .- HEco.

FOLLOW-UP ACTION: 12_30 To date, thirty-two (32) hangers hive been inspected out of sixty-five (65) hangers. Individual weld inspection totals were not available at this time. FOLLOW-UP ACTION DATE: /- e 7-p,/ F/U Action Verified [/N4! Date '/1/eV

                                              /

F/V Action Approved O d a. E w e> Date I/d /f4 Q.A.Supervis,jr PTM:tj:jc:12745 cc: W.J. Shewski/G.F. Marcus 0.A. Supt./ File Contractor 0.A. Audit Staff Desg. PCD Supt. Project Manager PTM R-6 l l

                                                                                   .)

Pagy 7 Surveillance Report 5274

    . HECo.

FOLLOW-UP ACTION: On 1/13/84 - To date, thirty-seven (37) hangers have been inspected out of sixty-four (64) hangers, with one hanger deleted. A total of 1674 welds inspected with 384 of these welds rejected by S&L. This represents a 22.9% reject rate. This work item is 58% complete with an expected completion date of 2/4/84. DATE OF NEXT FOLLOW-UP: $2 8 # F/U Action Verified M.'- Date ~ ~ 'a >W F/U Action Approved 15 b - IW6 Date l!/?[4 D.A. Superv2s,cr PTM:tj:jc:1274S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM l R-7 t i [ l l l l l

Pag? 8 Surveillance Report 5274 HECo. FOLLOW-UP ACTION: 2/6/84 - No change in work progress due to change in priorities. Reinspection efforts were concentrated on the NRC Reinspection I&E Reports No. 50-454/82-05 and 50-455/82-04. The reinspection has restarted today 2/6/84. NEXT FOLLOW-UP DATE: _7 -) - 3 '/ F/U Action Verified ~ Y '.d . Date J ~7-8'/ F/U Action Approved -

1. e.w Date ~)/,C/?4 Q.A. Superv(sy r PTM:tj:jc:1274S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.

PCD Supt. Project Manager PTM R-8

 ,      P:g? 9 -

Surveillance Report 5274 HECo. i FOLLOW-UP ACTION: 3-09 Currently, five (5) combination weld hangers remain to be inspected. Additionally, a final review and reconciliation of all previously reinspected weld travellers will be completed by 3-30-84. NEXT FOLLOW-UP DATE: 5 - l o --d 4 F/U Action Verified aA. , Date 3 -i t er e~ . .' - F/U Action Approved '

                                                        ' -a [~ .              Date Y
                                                                                       '1 -! 

Q.A. Supervisor PTM:tj:jc:1274S cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. PCD Supt. Project Manager PTM l l R-9

c , Pige 10 Surveillance Report 5274 t-HECo. F_OLLOW-UP ACTION _: h 31. 1984, completed the 4-06 Hatfield Electric Company, on Marchich no inspection record bination hangers for which no combination hanger weld inspections for wThese inspectio correlation of weld traveler inspection , hanger data existed. lds are up to date and h l Inspection records for combination The we hanger deficiencies tus of work.s of being corrected using i gatisfactorily reflects the This inspection effort encompassed \pa -these in i s current This rework staidentified during amounts to approximately h the contractors normal rework pract ce . ditors judgement is indicative 100% review of all combination hangers.14% of the total we of first time inspection. ld inspections current and Therefore, with the combination hangerrecords ' we system. the corrective inspection reports existing in the contractor idered complete.s action required for this audit item is cons T_his audit item is considered acceptable an O . This surveillance is closed. -- -- -- - - ---- - ---- ----- -- _ Date +'d // e/ _

                                - - - - - -- - - - - -- - - Y4 F/U Action Verified _' .   <

_ Date_i u-64 _ h a-D F/U Action Approved Q.A. Supervisor PTM:jc:1274SG ' *g * ,

                                               ^

v\ cc: W. N i/G.F. Q.A. Supt./ File Contractor { i kh> k Q.A. Audit Staff Desg. PCD Suot. Project Manager pTM R-10 i M

r j l g [ 2.'il "

 ?, '
  ,                                                         BYRON SITE OA SURVEILLANCE AUDIT CLOSE OUT                                     QF: 2790.22.1 Report No. 5276 R1                               AUDIT No. 6-83-124                                         Date 02/21/84 Contractor / Organization:

Hatfield Electric Co.

                        - _ _ - - - - - - - - - - - - - - - - - - - - - = = = = = - - - - - - - - - - - - = = _-    =_  -___-----------

OBSERVATION #1: Contrary to Hatfield Electric Co. Procedure 9A Revision 11. Class I Cable l Pan Hanger Installation quality control had inspected and accepted a hanger to the wrong dimensions. DISCUSSION: Hanger 15H2 on Drawing 6E-0-3033 Rev. H was inspected and accepted (HEco. Report 835) to the dimensions for hanger type 635H whose dimensions are different from those of a 15H2 CORRECTIVE ACTION: Hanger 15H2 on Drawing 6E-0-3033 Rev. H is going to be reinspected and an addition sample of ten (10) hangers whose hanger type has changed will be reinspected to determine the extent of this problem. ACTION TO PREVENT RECURRENCE: gg Not applicable: this was determined to be an isolated case. FOLLCW-UP ACTICN: All ten (10) hangers reviewed were randomly selected and were checked dimensionally against current design documents. Attachment "A" lists hangers inspected. Hanger 15H2 on Drawing 6E-0-3033 Rev. H was reinspected and accepted to the correct drawing. This item is considered closed.

           --------------------------------_ =__-_                     _

Prepared by p i Date.l7/#///# i i Approved by 1 b b(d N % u Date 3 2- n N PTM:tj:jc:1271S G At tachroent A L9' cc: W nh-Shew * " . ? . 41 t e l Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. l PCD Supt. Project Manager PTM Attachment S l l 1 1

       .. :-         5g u d+ d2]Is 3 p ' .,

Atsaeksue I

• s. 73- 4 ll1 r%su % ~7w e_ D r ~-.~ s 70HL ~

15H 'Wa.P O-scasHo3 LR

                .-            14rl                         O-s opaeos 0///                       Dh'          $w'.T          0-Goa3 bb2-
                                           %K.

3H 0-soas 80x. l31/30 13H W.s 0-scassc3

                            /4h'           S/            0-3023,p3
   /2H5                     t3H            %.L         O-seasito/
                           /2//           2w./^        O-SoRSfg
   /sWF                    /5//          b'h          0 Go3 L yo/
                        /4/f            i?.u:K       O-3032. &
                        /sH            Ru w          0-x w- Hot IR.H Y                 .u/           &zs//           0-sos.5//o3
                      /JH             hu. 7           0 ?a53ysg
   /HVa$               /HV           e<2 Y              0 3eazHoz-A02h' f             Vd.R                O .5cee- Abt s-2 l
                                                                  '                   I

c

        ,e
                ?.~ < -

1 2/-

           /4///               14//          [a4   '

O-300a.#0/ 13ll WM.M 0-soozMol , I4/!2. I41/ $2.L 0-300z.Hof ISU 01Nt D- 3cv2 h'o f

   'AH3                   /4H          0 4.            0-SeczMo/
                         /EY          heJ M
       .                                              6-3eezHo/

Idh'2. 63Ed uT o.3933gej

                        /Sh' h.c<i'. R.       O-8033 }/o t I

S-3 Y}}