ML20082D678

Preliminary Rept on Reinsp Conducted as Result of Noncompliance Item 50-454/82-05-19 & 50-455/82-04-19

ML20082D678
Person / Time
Site:	Byron
Issue date:	10/28/1983
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20082D634	List: ML20082D662 ML20082D678
References
7511N, NUDOCS 8311220503
Download: ML20082D678 (44)

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IEELIMINARY REPORT ON REINSPECTION CONDUCTED AS A RESULT OF NONCO WLIANCE ITEM 50-454/82-05-19 & 50-455/82-04-19 October 28, 1983 8311220503 831118 PDR ADOCK 05000454 G PDR 7511N

9 ) 3 CDNTENTS I SYN 00 SIS II BACKGROUlO III SCOPE IV DEPTH OF REINSPECTION PROGRAM-V REINSPECTION RESULTS VI -QUALITY ASSURANCE CONTROL OF REINSPECTION PROGRAM APPENDIX A REINSPECTION RESULTS BY TYPE / AREA 0F CERTIFICATION ,

APPENDIX B REINSPECTION RESULTS BY INSPECTOR APPEPOIX C SUR)ECTIVE INSPECTION DISCREPANCIES - EVALUATION OF SIGNIFICANCE APPENDIX D OBJECTIVE INP ECTION DISCREPANCIES - EVALUATION OF SIGNIFICANCE 7511N I

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I. 5(NOPSIS H The reinspection program conducted as a result of concerns defined in IE Inspection Report Nos. 50-454/82-05 and 50-455/82-04 associated with the qualifi- ,

cation and certification inspection personnel is nearly completed. The results demonstrate the past and present capability of the quality control / quality essurance inspection personnel to perform the measurements, interpretations, comparisons, and judgements associated with evaluation of the quality of

. installation of structures, components, and assemblies at the Byron Generating Station.

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

discrepancies ~found. The results of the Program which are discussed in greater detailinsubsequentsections,aresummarizedbeIowbycontractor.

TABLE 1.1 REINSPECTION PROGRAM SIM MRY Number of Reinspection Number of Reinspection Cbjective Results Subjective Results Contractor' Reinspections Acceptable (l) Reinspections Acceptable (2)

Blount 2,390 98.8%- 0 N/A

- Johnson Controls 7,812 99.4% 1,459 95.5%

Eunter 69,598 99.0% 3,662 96.7%

Nisco 2,792 99.6% 229 100.0%

Hatfield Electric 58,718 96.7% 21,905 94.2%

Powers-Azco-Pope 9,104 96.0% 7,646 86.1%(3)

Pittsburgh Testing 7,269 99.1% 4,973 91.3%

Peabody Testing 0 N/A 163 96.9%

Note (1): Program Acceptance Criteria is 95.0%

'(2): Program Acceptance Criteria is 90.0%

(3): 100% of accessible work was reinspected based on Program defined sample expansion. ,

. A large percentage of the deficiencies recorded in the reinspection program involved subjective attributes. Subjective attributes are those in which review of the work performed required the inspector (and reinspector) to make an item-by-item judgment of attribute quality based on visual observation, as opposed to the quan-tifiable characteristics of objective attributes. Examples of subjective attributes include weld overlap and undercut, while examples of objective attributes include component size and material type. A significant portion of the deficiencies identified upon initial reinspection involved subjective weld attributes. In August, a review of the initial reinspection effort by the NRC staff suggested that L

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1the11nspectors performing the reinspections were interpreting criteria in an

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cxcessively conservative manner. Third party review of initial reinspections of subjective weld attributes confirm the excessive conservatism-in applying criteria for the acceptability of.such attributes. Thus in many situations. attributes which were rejected upon initial reinspection were found to be acceptable upon third .

? party reinspection managed by Sargent & Lundy.. In, addition, in some situations in which attributes were rejected upon initial: third party reinspection, subsequent reinspection byta Commonwealth Edison Level III reinspector determined that the

-c,ttributes were acceptable. As discussed below, engineering analysis has demonstrated that even those~ subjective weld attributes rejected after both levels of- third party review provide an appropriate factor of safety.

Section II, BACKGROUND describes the evolution of events which lead to reinspection program and provides a brief description of the reinspection program criteria.

Section III, -SCOPE describes in brief form the quantity of features creinspected and provides a brief description of the resources required to execute the reinspection effort.

Section IV,. DEPTH OF REINSPECTION PROGRAM provides data in a format which describes the volume and extent.of the reinspection program.

.Section V - REINSPECTION RESULTS provides a summary by contractor of the results for the inspec, tors selectea ror reinspection against the threshold established by-the criteriu for demonstration'of acceptability. Only one contractor required expansion into the second and third phase of the reinspection program criteria.

Almost one hundredl percent of the' work previously performed by this contractor was

' reinspected as a part of.the reinspection program. It is important to identify and recognize that the subject contractor's installation-inspection program contained a multiphase inspection and inspection confirmation. structure which by execution of.

' planned subsequent inspections would have identified many of the discrepancies.

1 established in the reinspection program. All other contractors demonstrated

-acceptability against the threshold established by the criteria in the first phase of the program. -(Final validation of this data will be completed prior to submittal of the final report.)

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,Section VI, QUALITY ASSURANCE CONTROL OF REINSPECTION PROGRAM describes the

Quality Assurance activities performed to establish and verify that the

" reinspection program was properly implemented.

APPENDIX A, ! REINPECTION RESULTS BY TYPE / AREA 0F CERTIFICATION and APPENDIX B~, . REINPECTION RESULTS BY INSPECTOR present the detailed statistics created by the reinspection program.-

. fAPFENDIX C, SUEDECTIVE INSPECTION DISCREPANCIES - EVALUATION OF SIGNIFICANCE and APPENDIX D, OB'IECTIVE INSPECTION DISCREPANCIES - EVALUATION OF SIGNIFICANCE present a description of the types of discrepancies identified in the reinspection program, the corrective actions taken, and engineering analysis of significance of the identified discrepancies.

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II. BANGROUND An\NRCspeciallteaminspectionwasconductedatByronStationduringthe

-' period of March 29-31, April;l-2,.5-9 12-14, and May_11, 1982. During the

' inspection _several-violations were identified, one of which was an apparent

- noncompliance with the requirements for the: initial qualifications of

personnel who perform inspection, examination and. testing to verify conformance to specified requirements. - The Notice of Violation dated June 24,

.1982 identified this'as noncompliance 82-05-19/82-04-19. The noncompliance letter also requested that Commonwealth Edison assure the validity of

inspections performed by quality. control inspectors who were deemed to be

-improperly trained and qualified.

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

personnel at Byron:were inconsistent with the current NRC interpretation' of

the requirements of ANSI N45.2.6-1978. Specifically, the Inspector found deficiencies'in the contractor's evaluations of initial inspector capabili-

-ties', in documentation of initial certification, and in the criteria used to establish inspector qualification. 3,The NRC staff did not find that these

procedural deficiencies had compromised the quality of plant construction.

LHowever, in issuing the violation, they made it clear that the qualification

. programs were to be upgraded and the quality of work already completed _was to

.be verified in some manner. With the completion of the reinspection program outlined below, those' obligations have been met.

Over the years,; inspector certification practices have been-continually

_ upgraded to remain consistent with the changing interpretation of the applic-able standard, ANSI N45.2.6. Prior to this NRC inspection, Commonwealth Edison had relied largely.upon reinspections,1 audits and surveillances to assure _the effectiveness of contractor programs for certification of QC

inspectors. As a result of NRC concerns stated during the inspection, on April- 27, .1982,~ the Byron site contractors were instructed to. revise their

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certification practices to incorporate standard features and methods

. established by Commonwealth Edison. These features and methods were further upgraded on ,lJne 9,1982 based on comments from NRC inspectors. Contractor programs were all1 revised by September 30, 1982.

1In the July 30,_1982 response to the Notice of Violation, Commonwealth Edison outlined a program which would validate previous QC inspections. This was to be. accomplished by requalifying the inspector, reviewing the inspector's

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

inspector's work. _ The NRC found that this verification program did not adequately address the quality of inspections performed early in the inspector's employment over the full course of the plant construction period.

Alternate: verification programs were discussed with the NRC during several meetings. Options discussed included a " vertical slice" reinspection program Iim au u li- m'u u -

involving complete multi-disciplinary reinspection of representative plant creas. ~ Also discussed was a reevaluation of all inspectors' qualifications and experience according to a complex formula. Finally, an extensive program of reinspections was agreed upon and documented in a Commonwealth Edison ,

letter dated February 23, 1983. A program of reinspections was initiated which would verify on a contractor-by-contractor basis the adequacy of past QC inspector training and certification practices at Byron Station.

A brief summary of the reinspection program follows:

A(1) For 6 contractors, every 5th inspector selected (NRC Senior Resident Inspector added from 2 to 4 inspectors per contractor) .

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

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

C Reinspection conducted utilizing inspection criteria applicable to initial inspection period.

D(1) Inspections classified as objective require 95% agreement rate in repeat inspection.

D(2) Inspections classified as subjective require 9% agreement rate in repeat inspection.

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

E When selected inspector failed to achieve 95% agreement rate on objective inspections, or 90% agreement rate on subjective inspections; then additional three months of inspection work reinspected for the type of inspection which failed to achieve required agreement rate.

F If selected inspector failed to achieve 95% agreement rate or 93 agreement rate, as appropriate, in second three month period, than all inspections performed by the

. inspector of the type which failed would be reinspected; and the original sample size of inspectors would be increased by 50%.

In an effort to identify deficiencies in certificat' ,n programs, this reinspection program focuses on the' quality of the work perforned by QC inspectors immediately after their certification. It covers the entire period

'of a contractor's work on site and it acknowledges that all inspections are repeatable in varying degrees, depending upon the subjectivity of the feature

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being inspected. It contains ' conservative acceptance criteria. . It _also .

-provides for higher level overinspections to compensate for possible excessively conservative application of acceptance criteria by reinspectors i and provides for expansion of the reinspections when a deficiency in the i

contractor's certification. program is apparent.

In the' course of development and execution of the reinspection program, it became necessary to establish a minimum quantity off items to be reinspected by each inspector chosen in' order to create an adequate data base for cvaluation.. When the minimum quantity established was not obtained in the first-three-month' period,-Ivinspection went beyond the initial three-month period in order to achieve the minimum quantity. In those cases where a selected inspector did not function as an inspector for a three-month period

.and thus' did not have the minimum quantity in this period, the results of the reinspection wera recorded but no expansion occurred due to lack of population. ' Additionally, in the course of the development and execution of reinspection program it.was necessary to establish other such programmatic-features associated with the recreatability of inspections in order to

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complete the agreed-upon reinspection program and data analysis.

In order to assure ,that reinspection results were consistent and accurate, the program accepted by the NRC provided for a Level III third party over-inspection to review the determinations made by the initial reinspectors. The provisions for the third party review recognized the nature of judgmental reinspectionfof subjective attributes such as weld surface quality. As

previously indicated to the Region III Staff, and as documented herein, Sargent & Lundy managed initial third party review, and a Commonwealth Edison

. Level III inspector provided an additional layer of third party reivew. All

.such inspections are reported and were included in the reinspection data base. The evaluation made by the Commonwealth Edison Level III Inspector with zregard to those attributes which he examined determined the ultimate

, ccceptability of those attributes.

During .the course of execution of the reinspection activities, the NRC Region III staff conducted numerous reviews of the activities and maintained a relatively high level of involvement in the proceedings. Inspection Report Nos. 50-454/83-26, 50-454/83-37, and 50-454/83-38 summarize relevant site inspections.

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

The quantity of inspectors selected to be reinspected is presented in Table 3.1.

Table 3.1 Quantity Of Inspectors Reinspected Total Number Of Percent Of Population Of Inspectors Inspectors Contractor Inspectors Reinspected Reinspected Blount 28 8 29%

Johnson Controls 7 5 (1) 71%

Hunter 84 21 25%

NISCo 8 4 50%

Hatfield Elec. 86 22 26%

Powers-Azco-Pope 21 19 (1) 90%

Pittsburgh Testing 85 19 22%

Peabody Testing 37 6 (1) 16%

TOTAL: 356 104 29%

NOTE (1): 100% of the inspector population was reviewed for performance of the reinspection. Those inspectors not included had no reinspectable items.

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

. Table 3.2 Quantity Of Items Reinspected Number Of - Number Of Reinspected *

.(bjective Subjective Inspection

. Contractor Inspections Inspections Months-

._ Blount 2,390 0 89

@hnson Controls 7,812 1,459 18 Hunter- 69,598 3,662 62 NISCo ._

2,792- 229 -12 Hatfield Elec. 58,718 21,905 65 Powers-Azco-Pope 9,104 7,646 149

.Pittsburgh Testing ~ 7,269 4,973 100 Peabody Testing 0 163 20 sTOTAL: -157,683 40,037 515 L The reinspection effort required a significant commitment of manhours and materials to execute. LAfter February 22,.1983 it:took three weeks to search inspection records to establishL the initial volume of individual inspections

-to be reinspected. - Actual conduct of reinspection began March 14, 1983. The rainspections were-performed by quality control inspectors who were qualified and certified by. the contractors .to the methods established as. a result of. the corrective action in response to noncompliance 82-05-19/82-04-19. Through September 27, 1983 twenty-seven weeks of reinspection have been conducted with the accumulation of 1166 inspector weeks expended. In order to perform the

inspections it was necessary to erect scaffolding, remove paint, fireproofing, insulation, etc. These activities through September 27, 1983 have accumulated over 3050 man weeks of craft labor support. The reinspection' operation has b::en functioning nominally on 58 hour6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> work weeks. Through September 27, 1983 over 240,155 manhours of effort have been expended in the execution of the freinspection. program.

=* NOTE: . This is total amount of 3-month periods and any necessary expansion of original Inspector's activity.

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, . 3 IV. DEPTH'0F REINSPECTION' PROGRAM

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

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

. in Tables 4.l', 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, and 4.8.

' Table 4.1 - Blount Number Of Number Of Percent i . Area Of Inspectors Qualified Inspectors In Included In~

Qualification In Area Area Reinspected Reinspection Concrete 12 2 17%

' Masonry 6 '2 33%

Concrete Expansion Anchors .

5 2 40%

Weld Inspection / Structural 11 4 36%

. Post-Tensioning * ' 10 0 0%

Cadwelding* 4 0 0%

Calibration

• 5 0 0%

Fire-Proofing

• 3 0. 0%

R;;ceiving* 6 0' 0%-

NOTE:

• areas of' inspection which cannot be recreated for a reinspection.

Table 4.2 - Johnson Controls Number'0f- . Number Of Percent Area Of Inspectors Qualified Inspectors In Included In Qualification In Area Area Reinspected Reinspection Visual Inspection 7 5 71%

Table 4.3 - Hunter Number Of Number Of Percent

Area Of'~ Inspectors Ghalified Inspectors In Included In Qualification In Area Area Reinspected Reinspection Piping / Hangers 57 15 26%

' Piping .

6 1 17%

Piping'As-Built -21L 5 24%

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Table 4;4'- NISCo Number Of -Number Of Percent Area Of Inspectors Qualified . Inspectors In Included In Qualification In Area Area Reinspected Reinspection Visual Welding 6 4 6A Mechanical 6 4 67%

Table 4.5 - Hatfield.

Number Of Number Of Percent Area Of Inspectors Qualified Inspectors In Included In Qualification In Area Area Reinspected Reinspection Visual Welding 20' 7- 35%

Conduit Installation 21 6 29%

Cable Terminations 21 5 24%

Equipment Installation 14 2 14%

Equipment Modification 12 2 17%

Cable Pan Installation 21 1 5%

' Cable Pan Hanger 22 2 9%

Conduit As-Builts 28 8 29%

A-325 Bolting Insp. 11 1 9%

Table 4.6 - Powers-Azco-Pope Number Of Number Of Percent Area Of Inspectors Qualified Inspectors In Included In Qualification' - In Area Area Reinspected Reinspection Welding Inspector 20 19 95%

R:ceiving Inspector

• 2 0 0%

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

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Table 4.7 - Pittsburgh-Testing

. . Number Of Number Of Percent

-Area Of _ Inspectors Qualified Inspectors In Included In

, Qualification- In Area Area Reinspected Reinspection

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Concrete Expansion Anchors / Structural 43 9 21%

Visual Welding 21 10 48%

Concrete-Field / Lab / Plant

• 93 0 0%

, Soils - Field / Lab

• 29 0. 0%

Cadweld* 10 0 0%

Post-Tensioning

• 3 0 0%

Fireproofing*. - 4 0 0%

Coatings *. 2 0 0%

. Calibration

• 17 0 0%

, Electrical

• 12 0 0%

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

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

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

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-Table 4.8 - Peabody Testing

!Omber Of - Number Of Percent

. Area Of, . Inspectors Qualified Inspectors'In Included In Qualification 'In Area Area Reinspected Reinspection Visual Welding /

Structural Steel 6 '6 100%

-Concrete *. 28 0 0%

-Soils *' 20 0 0%-

Cadweld*' 8 0 0%

. Coatings * : 1- 0 '0%

Calibration

• 1 .0- 0%-

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

, In order to test'the selected population of inspectors and their corresponding volume of time reinspected to the volume of _ time of inspections accumulated, a comparison was performed. The results-of the comparison are presented in Table 4.9 TABLE 4.9 Percent of 5 Total Accumulated Reinspected Inspection Inspection-Months Inspection Months Months Reinspected Blount 424 89 21%-

Johnson Controls" ;60- 18 30%

Hunter '1,107 - ,

62 6%

NISCo 51 . 12 24%

Hatfield Elec. 628 65 10%

Powers-Azco-Pope -152 149 98%

Pittsburgh Testing .1,015. 100 10%

Peabody Testing- 181 20 11%

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3,618 515 14%

Tables 3.1 and 4.1 thru 4.8 demonstrate that the sampling basis achieved the selection of a significant portion of.the population of inspectors, and -

echieved the selection of'a significant portion of the inspector population in an _ area of certification. Tables 3.2 and 4.9 demonstrate that a significant (quantity of items and percentage of inspection activities were covered through

.this sampling basis. The. sample of one out of five on a chronological basis tras'a technique which resulted in inspections of work'of many types and of

. varied types being reinspected. Even though the percentages varied somewhat,

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

V. REINSPECTION RESULTS The results of the reinspection program are presented on a by contractor basis in Tables 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, and 5.8.

. Table 5.1 - Blount

~ Inspection Status Of:

' Type Reinspection Condition i @jective Complete All 8 inspectors who performed obje'tive e inspections, acceptable at end of first 3 month period.

f Subjective Not Applicable All inspections included in reinspection population classified as objective.

Table 5.2 - Johnson Controls Inspection Status Of Type Reinspection Condition Cbjective Complete 4 inspectors who performed objective inspections, acceptable at end of first 3 month period.

1 inspector who performed objective inspections did not have minimum quantity in first 3 month period, nor in second 3 month period, nor in total of inspections, all of his work was reinspected.

Subjective. Complete All 4 inspectors who performed

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

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1 Table ~ 5.3 - Hunter

-Inspection. Status Of Type' Reinspection Condition Objective. Complete 19 inspectors who performed objective inspections, acceptable at end of first'3 month period.

=1 inspector who performed objective inspections did not have minimum quantity in first 3 month period, nor in second 3

month period, nor in total of inspections, all of his work was reinspected.

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

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

Table 5.4 - NISCo Inspection Status Of Type' Reinspection Condition Objective Complete All 4 inspectors who performed objective inspections, acceptable at end of first 3 month period.

Subjective Complete _ All 4 inspectors who performed subjective inspections, acceptable at end of first 3 month period.

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Table 5.5 - Hatfield Electric -

Inspection Status Of Type Reinspection Condition Objective Complete All 16 inspectors who performed objective inspections, acceptable at end of first 3 month period.

Subjective Complete- All 7 inspectors who performed subjective inspections, acceptable at end of first 3 month period.

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Table 5.6 - Powers-A7co-Pope

Inspection Status Of Type Reinspection Condition Objective Complete 12 inspectors who performed objective inspections, acceptable

at end of period *.

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

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all of his work'was reinspected.

'5 : inspectors who parformed objective inspections unacceptable at~ end of period *,

all of their work was reinspected.

~ Subjective Complete 7 inspectors who performed subjective inspections, acceptable at end of period *.

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

all of their work was reinspected.

10 inspectors who performed subjective inspections

- unacceptable at end of period *,

all of their work was reinspected.

• For this contractor, the period consisted of the first six month's work; that is,1first and second three months results combined. The data generated during;the-reinspection program is not readily separable into first and second three. month periods. '

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( W] [L-Inspection . Status Of py{v9 A - Type Reinspection -

Condition

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Objective- Complete 8 inspectors who performed

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

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1 inspector who performed-objective inspections, ecceptable at end of second 3 month period.

Subjective Complete 10 inspectors who performed subjective inspections, acceptable at end of first 3 month period.

Table 5.8 - Peabody Testing Inspection Status Of-Type Reinspection Condition

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

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

3 inspectors who performed subjective inspections did not have minimum quan_tity in first 3 month period, nor in second 3 month period, nor in total of inspections, all of their work was reinspected.

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1. 3 VI. QUALITY ASSURANCE CONTROL OF REINSPECTION PROGRAM The Commonwealth Edison Quality Assurance Department has been actively involved in the re-certification of current on-site Q.C. inspectors and the monitoring of the re-inspection of work performed by Q.C. inspectors who were cn-site during the early stages of construction. In early 1982, Commonwealth Edison committed to re-certify all site Q.C. inspectors to ANSI N45.2.6-1978, in accordance with guidelines and interpretations established by Edison. The Site Quality Assurance Department and Project Construction Department each tssigned personnel to work full time with the site contractors to implement the re-certification program. The results of the re-certification program tere, in turn, audited by the Edison General Office Q.A. Department to assure compliance to the Edison guidelines. As a result, it has established that the

. site contractors have properly re-certified their Q.C. inspectors.

Audit of Re-inspection Program Implementation When the re-inspection program was established in February, 1983, and re-inspections began in late March, the Site Q.A. Department performed audits and surveillances to monitor the re-inspection activity. The first audit was performed June 21 through Jul of the re-inspection program.y 6,1983, The audit which was about

(#6-83-66) was the expected conducted by mid-point a six man

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

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

1) Re-inspection sample size

2) /% plication of inaccessibility

3) Third party review

4) Disposition of discrepancies

5) Documentation of inspection results

6) Qualifications of re-inspection personnel i

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

This was classified as a finding.

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

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

cithout evaluating if the second inspection completely superseded the earlier inspection. In another case a contractor had a Q.C. inspector who had been c rtified in several different disciplines within the first three months of his employment, but the contractor had only re-inspected the first discipline in which he was certified. In total, eight observations were identified which addressed issues, such as these, which needed clarification.

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

Special Audit of Hatfield As the re-inspection program progressed beyond the early stages, Edison Quality Assurance and Project Construction personnel bmame aware of problems ct Hatfield in determining which welds were to be incl. ' in the re-inspection. These problems were primarily due to the . 'ner in which Hatfield generated and maintained inspection records during the early years of construction. Also, the NRC advised Edison of concerns with the Hatfield inspection records. As a result, Edison Site Q.A. performed an audit to -

specifically address these concerns. The audit (#6-83-124) was conducted by a three man team during the period 8/24/83 through 9/1/83.

The scope of.the audit included the following:

1) Review documentation practices

2) Correlation of weld record cards to welders and inspectors

3) Identifying the latest weld record

4) Re-numbering hangers

5) Re-inspection - incorrect assumptions

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

'cssigned to each inspector were correct and it should provide an accurate means for identifying those hangers which do not have complete inspection records.

Qualification of Inspectors During Re-inspection In order to assure that Q.C. personnel performing re-inspections were fully qualified, Site Q.A. directed PTL to perform a surveillance to verify that their inspectors could independently arrive at the same inspection results as the contractors Q.A. inspectors who were performing the re-inspectio c . The surveillance ran from August 1,1983 to September 19, 1983. The results show a correlation ranging from 94% to 100% and it appears that the contractor's Q.C. personnel doing re-inspecticns are doing accurate and acceptable work.

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

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

2) Re-inspectors have done acceptable work.

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

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l APPENDIX A REINSPECTION RESULTS BY TYPE / AREA 0F CERTIFICATION A tabulation of inspection results by inspection type and by inspection area of certification is presented on a by contractor basis in Tables A.1, A.2, A.3, A.4, A.5, A.6, A.7, and A.8. Appendix B shows actual quantities of acceptable and rejectable results by attribute.

Table A.1 - Blount Bros.,

I. Results By Inspection Tyce Reinspection Results (Acceptable) l Level II I Independent Third l Level III Type l Reinspection l Party Review l Reinspection i l i Subjective 1 (2) l (1) I (1) l I I I Objective 1 98.8% l (1) l (1) l I I II. Results By Inspection Attribute l Initial Sample Period .I Expansion Sample Period l l l l l NJ. Of I l No. Of I l P:ople l Final % l People Final %

Attribute ~l Reinspected l Acceptable l Reinspected Acceptable l l l l

1. Weld Detail l I I l l 4 1 98.7% 1 (1) l (1) l I I I (Cbjective) l l l l 1 1 I

2. Concrete l I I l l 2 l 1005 I (1) l (1) l I i 1;

((bjective) I i l 1-l i l

3. Masonry i I l l l 2 1 99.4% l (1) l (1) l I I I (Objective) l H l l l

4. Concrete 1- 1. I Expansion l 2 l 96.1% l (1) l (1)

Ancht..e l I l l (Objective) l l- 1 l (1) Not required (2) let applicable

b . .

' . ' _o 6 Table A.2 - 3)hnson Controls 4

-I. Results By Inspection Type Reinecection'Results (Acceptable) 1 Level II -l Independant Third l Level III Type- Reinspection Party Review *- Reinspection Subjective 1 94.9% l 95.5% 1 (1) 1- (1386/1459) l (1394/1459) l I - l- I-

-@jective -l' 99.4% l .(1) I (1) l l l-II. Results By Inspection Attribute l' Initial Sample Period l Expansion Sample Period i I l l l No. Of I 'l No. Of I l People l _' Final % l People- l Final %

Attribute Reinspected -Acceptable l Reinspected i Acceptable I

.1.. Visual . I Welding l. -4 l 95.5% (1) (1)

.I I I I (Subjective)

2. Mechanical l l l l l 4' I 99.4% 1 (1) l (1) l I I I

(@jective) l l l NOTE: *Results Cummulative. 73 Rejects Were Re:.nspected.

(1) Not required

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. s Table A.3 - Hunter

.I. Results By Inspection Type, Reinspection Results (Acceptable) l Level 11 1 Independent Third l Level 111 Type l Reinspection l Party Review

• I Reinspection l I Subjective 94.3% 1 96.7% l (1)

'(3452/3662) (3544/3662) 1 Objective 99.0% l (1) l (1) l I I II. Results By Inspection Attribute l Initial Sample Period l Expansion Sample Period l . I I l l No. Of I l No. Of I l- People l Final % l People i Final %

' Attribute Reinspected l Acceptable  !

Reinspected Acceptable I

1. Visual l l l Welding i 16 l 96.8% I (1) l (1) 1,

1. I l (Subjective)

2. Documentatior.1 l l l l 20 1 98.9% l (1) l (1)

1. l l l (Objective) l I

3.' Hardware .l l .

l .l l- 17 l 99.2% l (1) l (1)

I I l l (Objective) l l l l

~ NOTE: *Results Oummulative. 210 Rejects Were Reinspected.

(1) Not required

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Table A.4 - NISCo I. Results By Inspection Type Reinspection Results (Acceptable)-

l Level II l Independent Third i Level III Type Reinspection Party Review Reinspection

-l l Subjective' , 10 0.0% _ (1) 1 (1) l Objective l 99.6% l (1) l (1) 1 -l 1 II Results By Inspection Attribute l . Initial Sample Period l Expansion Sampic Period l

l l l l 1 No. Of I l No. Of I l l People l Final % l People l Final %

l Attribute -l Reinsper.ted Acceptable Reinspected Acceptable i l 1- l l

1. Visual l I Welding l 4 -1 100.0% (1) (1) l l l l l l (Subjective) l l l I I l i

2. Mechanical l i l 1 1 4 l 99.6% l (1) 1 (1) 1 l l I

((bjective) l l 1 I (1) Not required

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• Table A.5 - Hatfield Electr{c I. Results-By Inspection Type Reinspection Results (Acceptable)

-l . Level II I Independent Third i Level III b Type Reinspection 'l- Party Review

• l Reinspection **

I I Subjective 1 88.4% 1 92.7% i 94.2%

(20253/22905) -(21226/22905) l (21576/22905) l Objective 96.7% l (1) l (1) 1 l II. Results By Inspection Attribute l Initial Sample Period i Expansion Sample Period l l l l l No. Of l l No. Of I l People l Final % l People l Final %

Attribute Reinspected Acceptable Reinspected Acceptable i l

1. Visual Weld l l l . I 7 94.2% (1) l (1)

I 1 l l 1

-2. Conduit ~l l l l l 6 l 96.9% 1 (1) 1 (1)

I r . l

3. Terminations l l l l l 5 l 99 9% l (1) l (1) l l l l

4. Equip. I 1 l l Setting l 2 l_ -100.0% 1 (1) l (1) l I

5. A325 l l 1 l Bolting i 1 l 100.0% 1 (1) l (1) l I

. 6. Equip. l- 'l l l Modification l 2 l 100.0% l (1) l (1) l I

'7. Conduit- .l l l l As-built 8 , 95.9% l (1)' l (1)

-l l I I

'(1) Not required

- 25.-

II. Results By ' Inspection - Attribute (Cont'd) l Initial Sample Period l Expansion Sample Period i l l l l l No. Of I l No. Of I l People l ' Final % l People l Final %

Attribute Reinspected Acceptable -Reinspected Acceptable l.

8. Pan 1. . l ll Hangers l 2 l 96.9% l (1) l (1)

I '

I I I I l l

9. Pan- l l l l l 1 l 100.0% l (1) l (1) l- l- 1 I NOTE: .*Results Cummulative. 2,652 Rejects Were Reinspected.

NOTE: **Results Cununulative. 422 Rejects Were Reinspected.

(1) Not required 7511N

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( Table A.6 - Powers-Azco-Pope I. Results By Inspection Type Reinspection Results-(Acceptable)-

l Level 11 1 Independent Third Level III Type- l Reinspection -l Party Review

• Reinspection l I I Subjective l _ 86.0% l 86.1% l (1)

-l (6579/7646) l (6583/7646) I i i l Objective 1 96.0% l (1) l (1) l I I II. Results By Inspection Attribute l Initial Sample Period l Expansion Sample Period i l l l No. Of i No. Of l People , Final % People Final %

Attribute Reinspected Acceptable Reinspected Acceptable

1. Pipe Material 1, 1 1.

Verification l- 19 1 98.0% l l 1 l l (1) l (1)

(Objective) l 'l l l l I I

2. Pipe Weld l l l Visual l 19 l 93.7% l 4 l 88.7%

l l l 1 (Subjective) ' I i

3. Hanger / Mount l l l l Material l 19 l 96.2% l 2 l 98.8%

Verification l l l l (Cbjective) l l

.. I I

. 4. Hanger Weld l l l l Visual l 19 l 75.0% l 7 l 83.1%

l (Subjective) l l 1 l l 5.. Final l l l l Hanger- l 10 .' 74.3% l 1 1 81.8%

l (Cbjective) I

_(1) Not required

- II. Results By Inspection Attribute l Initial Sample Period l Expansion Sample Period l I I I I No. Of I l No. Of l l People i Final % l People i Final %

Attribute l ' Reinspected Acceptable' Reinspected '

Acceptable l l l

6. Flex l l l Hose 1 7 l 100.0% l (1) l (1) l i I I (Cbjective) l l l l l

7. Pipe l l l l Bend l 9 l 95.7% l (1) l (1)

I l l l (Cbjective) 1- l- l l NOTE: *Results Cummulative. 1,067 Rejects Were Reinspected.

(1) .Not required 7511N -

L Table A.7 - Pittsburgh Testing I. Results By Inspection Type l

Reinspection Results (Acceptable) l- Level II I Independent Third 1- Level III Type Reinspection 1 Party Review

• l Reinspection **-

l l l

Subjective l 83.4% l 85.4% l 91.3%

(4147/4973) l (4249/4973) l (4543/4973) l l l Objective 1 99.1% l (1) l (1) l (7200/7269)- -l l II. Results By Inspection Attribute Initial Sample Period l Expansion Sample Period l l l 1

l No. Of l l No. Of i I People l Final % l People l Final %

Attribute Reinspected Acceptable l -Reinspected l Acceptable l I

1. Visual l l l l Welding l 10 1 91.3% l (1) l (1)

I l l l (Subjective) l l l l i 2.-Concrete l l l l 4 Expansion l 9 l 99.1% l -(1) l (1) l Anchor l l l l

- (Cbjective) l l l l  !

NOTE: *Results Cummulative. 826 Rejects Were Reinspected.

NOTE:.**Results Cummulative. 301 Rejects Were Reinspected.

(1) Not required 7511N

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Table A.8 - Peabody I. Results By Inspection Type

-Reinspection Results (Acceptable) l Level II l Indqpendent Third l Level III Type Reinspection l Party Review

• Reinspection ** -

1 l l Subjective 1 71.8% l: 74.8% l 96.9%

l (117/163) l (122/163) (158/163) l I Objective l (2) l (1) l (1) l l l

'II. Results By Inspection Attribute l Initial Sample Period 1 Expansion Sample Period l l l l l No. Of l l No. Of l-l . People- l Final % l People. I Final %

Attribute 1 Reinspected Acceptable l Reinspected Acceptable 1

1. Visual ,

H l Welding l 6 1 96.9% l (1) l (1)

I l (Subjective) l NOTE: *Results Cummulative. 46 Rejects Were Reinspected.

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

(1) Not. required (2) Not applicable

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APPENDIX B REIN 9ECTION RESULTS BY INSPECTOR A tabulation of detail inspection results by Inspector and type of inspection is presented on a by contractor basis in Tables B.1, B.2, B.3, 8.4, 8.5, B.6, 8.7, and B.8.

Table 8.1 - Blount Bros.

Detailed Inspector Results Insp. Attr. #1 Attr. #2 Attr. #3 Attr. #4 A 636/640 - - -

B -

70/70 - -

C 437/440 - - -

D 427/443 - - -

E - - 253/255 49/51 F -

75/75 - -

G 335/335 - -

25/26 H __

- 55/55 -

Totals 1835/1858 145/145 308/310 74/77 NOTE:

No expanded sampling was required.

Attribute 1 - Weld Detail Attribute 2 - Concrete Attribute 3 - Masonry Attribute 4 - Concrete Expansion Anchors 7511N

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Table B.2 - M nson Controls Detailed Inspector-Results

-Insp. -

'Attr. #1 Attr. #2 -

A - 25/28 B 222/230 3170/3178 C 628/660 2761/2781 D' 80/84 499/499 E- 464/485 1310/1326 Totals 1394/1459 7765/7812

. NOTE:

No expanded sampling was required.

Attribute 1 - Visual Welding Attribute 2 - Mechanical 7511W-J

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Table B.3 - Hunter Detailed Inspector Results Insp. Attr. #1 Attr. #2 Attr. #3 A 47/51 - -

B 14/14 134/138 -

C 33/34 1181/1185 -

D 33/33 101/102 -

E 283/301 2088/2144 61/64 F 208/214 40/41 ~258/263 G 116/12F 161/161 21/21 H 49/55 19/19 12/12 I 315/319 47/47 129/133 J - 2195/2269 7836/7893 K 333/344 280/283 186/190 L 273/273 366/366 204/206 M - 126/130 331/339 N -

289/294 903/921 0 -

415/442' 1246/1253

'P 249/263 8143/8214 925/935 Q 381/392 6303/6363 5368/5390 R 232/237 8504/8520 81/81 S 181/181 328/331 932/934 T -

1789/1804 6251/6323 U 797/822 }651/3725 8024/8060 Totals 3544/3662 36160/35578 32768/33020 NOTE:

No expanded sampling was required.

Attribute 1 - Visual Welding Attribute 2 - Documentation Attribute 3 - Hardware 7511N

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.. n Table B.4 - NISCo Oetailed Inspector Results Insp. Attr. #1- Attr. #2 A 103/103 . 930/930' B 69/69 1567/1579 C 32/32 165/165 D 25/25 118/118 TOTALS 229/229 2780/2792 NOTE:

No expanded sampling was required.

Attribute 1 - Visual Welding

. Attribute 2 - Mechanical f

f

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i Table B.5 - lutfield Electric Detailed Inspector Results Insp. Attr. #1 Attr. #2 Attr. #3- Attr. #4 Attr. #5 Attr. #6 Attr. #7 Attr. #8 Attr. #9 A 878/906 - - - - - - - -

B - - - - - - 4795/4974 - -

C 690/708 - - - - - - - -

D - 32/32 770/770 24/24 8/8 - - - -

E 10797/11762 37/38 60/60 - - - - - -

F - 137/137 132/132 - - 2/2 - - -

G 1177/1218 289/304 562/564 - - 1/1 - - -

H - - - - - - 3985/4112 - -

I 4477/4639 - - - - - - -

J - 539/561 - - - - - - -

K -

1019/1046 - - - - - - -

~L - - - - - - - 193/198 -

M - - - - - - 10952/11457 - -

N 3516/3621 - - - - - - - -

0 51/51 - - - - - - - -

-P - - - - - - 2001/2081 - -

g - - - - - - 4818/5055 - -

R - - - - - -

11734/12205 - -

.S - - - - - -

2753/2879 - -

T - - - - - -

1917/2014 - -

U - -

8201/8208 24/24 - - - - -

V -- - -- - - - - 1696/1752 80/80 Totals' 21576/22905 2053/2118 9725/9734 48/48 8/8 3/3 42955/44777 1889/1950 80/80 NOTE:_

No expanded sampling was required.

Attribute 1 - Visual Weld Attribute 2 - Conduit Attribute 3 - Terminations Attribute 4 - Equipment Setting Attribute 5'- A325 Bolting Attribute 6 - Equipment Modification Attribute 7 - Conduit Asbuilt Attribute 8 - Pan Hangers

.' Attribute.9 - Pan

, :lW ~

v

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.;. 6 Table B.6 - Powers-Azco-Pope Detailed-Inspector Results

? =Insp. 'Attr. #1 Attr. #2 Attr. #3 Attr.'#4 Attr. #5 -Attr. #6 Attr. #7 A 23/23 1V11 6/10 5/8 - - -

B- 54/54 34/35 24/34' - 11/11- -- - -

CJ 52/52- 108/117 37/48 47/74 - - -

C(exp) .-

85/93 -

33/35 - - -

D 1/1 16/18 -193/195 50/52 - - -

=E- -

47/48 275/328 111/114 87/127 - 2/2 IV12

.E(exp) - 19/21 - .- - -

F 152/155 218/272 95/97 '36/61 - - --

F(exp) - 60/72 -

23/29 - - -

.G 67/68 330/351- 62/62 ,39/54 3/3. 2/2 -

H 10/10 224/24 68/68 43/55 - - -

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

V1 J 47/59 163/178 139/142 97/112 - -

-K- . 108/108 .99/101- 262/262 68/115 7/16 - 2/2 K(exp) .- --

.- . 3/5 - - -

L 137/139 .83/83 213/221 36/40 8/18 - 5/5 M. 295/302 536/546 858/946 82/181 16/41 2/2 12/12 M(exp) - -

555/561 208/246 L18/22 - -

N 231/237 468/484 . '503/508 172/218 - - 2/2 0- 359/370 379/404 793/823 197/272 2/2 - 8/10

-0(exp)- .

- - 5/7 - - -

.P- -11/11' IV12 8/8 4/4 - - -

Q . 32V321 38V395 710/729 478/591 6/6 8/8 1/1 Q(exp)- - - - - - -- -

. .R AV46 97/102 178/184 80/101 27/35 - -1/1 R(exp) 3/4 S 176/177 113/113 175/177 __90/113 139/154 1/1 8/8 Totals Initial- - 2493/2543 3986/4255 5385/5599 2138/2852 '225/303 25/25 45/47 Expanded-- - .-173/195 558/565 286/344 18/22 - -

NOTE:

Th's "exp" designation represents th'e expansion of an inspectors

-sample period when the acceptable threshold was not met.

Attribute 1 - Pipe Material Verification Attribute 2 - Pipe Weld Visual Attribute 3 . Hanger / Mount Material Verification Attribute 4 - Hanger Weld. Visual

' Attribute 5 - Final Hanger Attribute 6 - Flex Hose Attribute .7 - Pipe Bend

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Table B.7 - Pittsburgh Tssting Detailed Ir.spector Results Insp. Attr. #1- Attr.~ #2 -

A -

1699/1875 B -

-404/445

-C - 64/68 D - 18/18 E 522/524 -

F -

357/389 G -

12/12 H -

7/7 I - 596/657 J -

1277/1389 K z 299/300 -

L -- 377/381 -

M 1057/1058 -

N 864/874 -

0 2218/2261 -

P 934/935 -

~Q 883/890 -

R 46/46 -

S - 109/113-

-Totals 7200/7269 4543/4973

-NOTE:

No expanded sampling was required.

Attribute 1 - Concrete Expansion Anchors Attribute 2 - Visual Welding 7511N i

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. s Table B.8 - Peabody Detailed Inspector Results Insp.- Attr. #1 A 26/26 B 14/14' C 19/24 0 16/16 E 41/41 F 42/42 TOTALS 158/163 NOTE:

1004 of work was reinspected for Inspector C.

Attribute 1 - Visual Welding 7511N'

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I APPENDIX C SUBJECTIVE INSPECTION DISCREPANCIES - EVALUATION OF SIGNIFICANCE The reinspection activity identified statistically 3,010 discrepancies associated with visual weld inspection. The quantities by contractor are as follows:

Blount N/A Johnson Controls 65 Hunter 118 NISCo 0 Hatfield Electric 1,329 Powers-Azco-Pope 1,063 Pittsburgh Testing 430 Peabody, Testing 5 W

As identified below, for the engineering evaluation the weld discrepancies cere categorized as:

Category A Arc Strike Convexity Spatter Category B Crater Incomplete Fusion Overlap Porosity thdercut Underrun Category C Cracks Of the 3,010 discrepancies,10 to 20 percent would fall into Category A, 80 to 90 percent would fall into Category B, and 0 percent would fall into Category C.

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i Disposition Of Discrepancies All discrepancies identified as a part of the reinspection are being corrected either by physical rework to correct the condition or by detailing condition on nonconformance reports to perform engineering analysis to determine acceptability of the condition without correction. The determina-tion as to the course of action employed to disposition the condition is a function of the estimate of the more cost effective path to resolution. That is, when it appears that the cost to physically correct condition is less than the cost 3 associated with detailing data and performing an engineering

- analysis, then physical correction is chosen, and vice versa.

Evaluation Of Sianificance In addition to the action taken to correct the individual discrepancies, a statistical sampling is being prepared and an engineering analysis is being p;rformed on the statistically selected discrepancies to establish their significance. The types of discrepancies identified are similar or identical to conditions which have previously been addressed in the history of the project and found acceptable. This data accumulation, development, and evaluation is approximately fifty percent complete. The results of this population is presented below. The balance will be included in the final report.

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. ..o ENGINEERING EVALUATION OF VISUAL ELD INSPECTION DISCREPANCIES The pumose of the engineering evaluation was to determine the design impact of weld discrepancies discovered as part of the reinspection of QC inspector work. A total of 100 welds were included in the program; 50 welds tere from the combined scope of Pittsburgh Testing Laboratory and Peabody, and 50 welds were from Hatfield Electric Company's scope of work. In order to insure a conservative engineering evaluation, the 100 welds chosen for the evaluation were those welds which the independent third party inspectors identified as the welds with the most weld quality discrepancies. The intent of this evaluation was to determine what factor of safety in weld design exists for the 100 most discrepant welds. It was demonstrated that all these welds have large factors of safety with the reserve capacity to transfer the design loads in accordance with the original design criteria committed to in the FSAR.

The project work specification requires visual weld inspection in accordance with AWS Dl.1 Structural Welding Code. To perform the engineering cvaluation of the 100 worst welds, all discrepancies which did not meet the AWS weld quality acceptance criteria for visual inspection, were indicated by the inspectors on weld maps. A weld map is a detailed sketch of the as-built weld, showing size and location of all weld discrepancies.

The weld maps were separated into one of three categories, based on the type of discrepancy reported. Weld discrepancies that were considered struc-turally acceptable because they did not reduce the load carrying capacities

. tere placed in Category A. The AWS weld quality criteria considered in Category A consist of arc strikes, convexity, and spatter. Arc strikes and spatter are cosmetic discrepancies and only have impact on weld strength when they appear in an extreme case, If the extreme case appeared, it would have been reported on the weld map and the weld discrepancy would have been re-categorized. In this evaluation, there were no discrepancies reported essociated with arc strikes or spatter. Convexity is only considered a potential prot,lem in fatigue design of welds. Fatigue is not an applicable loading condition in the design of structures / supports where AWS welding is specified.

If the reported weld discrepancy resulted in a reduction to the size, length, or capacity of a weld, it was placed in Category B. This category included all weld quality discrepancies which caused portions of a weld to be considered ineffective. The AWS. weld quality discrepancies considered in Category B includes craters, incomplete fusion, overlap porosity, undercut, and underrun. The design procedure used to evaluate welds with Category B discrepancies was to consider these portions of the weld to be totally ineffective and then calculate the section properties of the remaining teceptable weld. This is a conservative approach because discrepancies only reduce the capacity of that portion of the weld where discrepancies are located, but there is always some reserve capacity even with the presence of the weld quality discrepancy.

I

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Category 8 welds were further subdivided into Categories 81 and B2. i Category 81 welds were those welds whose capacity, after subtracting weld discrepancies from the weld length, was reduced by less that 10%. Category B2 welds had capacity reductions greater than 10% after subtracting weld discrepancies from the weld length. This subdivision was used to quantify the significance of Category 8 discrepancies.

The last category used in the weld map classification was Category C.

Welds in this category were considered to be unsuitable for load transfer and were rejected. A crack in the weld was the only AWS weld quality discrepancy considered for total weld rejection. There were no weld cracks reported in this weld reinspection program.

The results of the engineering evaluation are presented in tabular form below.

Contractor Weld Quality Category A B1 82 C PTL 13 6 31 -

HECo 1 12 37 -

Total 14 18 68 -

Based on these results, it can be seen that for the 100 worst welrs, 32%

are in Categories A and Bl. In other words, approximately 1/3 of the worst welds resulted in less than 10% weld capacity reduction. The remaining 68%

are in Category B2. For these cases the factor of safety against the original weld design criteria is greater than one. This factor of safety is calculated as the ratio of allowable stress to actual stress wherein actual stress accounts for the weld discrepancies by subtraction from length of acceptable weld.

Factor Of = Allowable Stress Safety Actual Stress > lG Therefore, types of weld quality discrepancies that were not reported by the original QC weld inspectors resulted in a minor v: eld strength reduction ano can be considered insignificant to safety.

Since the engineering evaluation of the 100 worst welds showed that all welds are acceptable and meet the original FSAR commitment without exception, it can be concluded that the types and magnitude of weld quality discrepancies which were not reported under the original QC inspection were insignificant and do not compromise the design capacity of the welds.

r ,

APPENDIX D OBJECTIVE INSPECTION DISCREPANCIES EVALUATION OF SIGNIFICANCE The reinspecticr. activity identified statistically 3,138 discrepancies associated with objective type jnspections. The quantities by contractor are as follows:

Blount 28 Johnson Controls 47 Hunter 670 NISCo 12 Hatfield Electric 1,957 Powers-Azco-Pope 355 Pittsburgh Testing 69 Peabody Testing 0 3, 13 8 Disposition Of Discispancies All discrepancies identified as a part of reinspection are being corrected either by physical rework to correct the condition or by detailing the condition on nonconformance reports to perform engineering analysis to determine acceptability of the condition without correction. The determina-tion as to the course of action employed to disposition the condition is a function of the estimate of the more cost effective path to resolution. That is, when it appears that the cost to physically correct the condition is less than the costs associated with detailing data and performing an engineering analysis, then physical correction is chosen, and vice versa.

Evaluation Of Significance In addition to the action taken to correct the individual discrepancies, a statistical sampling is being prepared and an engineering analysis is being performed on the statistically t. elected discrepancies to establish their significance. The types of discrepancies identified are similar or identical to conditions which have previously been addressed in the histon of the project and found acceptable. The results of this evaluation will be provided in the final report.

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