ML20205T469
| ML20205T469 | |
| Person / Time | |
|---|---|
| Issue date: | 08/25/1983 |
| From: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20205S388 | List: |
| References | |
| FOIA-88-344 NUDOCS 8811140264 | |
| Download: ML20205T469 (79) | |
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August 25, 1983
(
l MEMORANDUM FOR:
D. G. Eisenhut. Director Division of Licensing, NRR f
FROM:
R. L. Spessard, Director ;
Division of Engineering, Region III EUBJECI: SURVEILLANCE TESTD6C OT FIRE FUMPs 18, 1983 and April 15, 1983, subject i In my memoranda to you dated Februaryas above, we requested N -
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As a result TIA 83-19 and TIA 83-19A were issued.
Although these TIA's are still open, we have received a copy of an R. Vollme 14, 1983, which was written in response to these letter to you dated JuneWe have also received a letter from the Estional Fire Frote TIA's.
Association, NFPA, in response to our aer11er request for a formal inter-pratation of annual fire pump capacity testing requirements of NTFA-20.
I f' Turther I and members of ary staff met with marbars of the NR 1 L. August 16, 1983, ,
NFPA letters, as well as other concerns we have in the fire protection As agreed during eres. ,
In my viev, this meeting was beneficial to all parties.the mel use by the NRR staff in completing their action under these TIA's.
If we can be of further assistance, please contact Mr. W. Little of 1ry staff or me.
R. L. Spessard, Director Division of Engineering Rnclosure As Stated
! ce w/ enc 1 C. M. Solahan, NRR FoI n & 3 t/ 9 R. Fargeson, Max
' Y. Benaroya, NRR gg7 R. Weseman, WRR J. M. Taylor, II T* I* ""#I "' 8011140264 001013 f J. A. 01ohimeki, RII PDR FOIA PDR ppm 9/Q
, J. E. Cagliardo, RIT MURPHYOO-344
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BYRON SITE QA SURVEILLANCE
' s AUDIT CLOSE OUT */QF: OG 53.4 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 1 affected organizations of nonconforming items identified under the
- reinspection program.
DISCUSSICW:
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 transait reports with nonconforming conditions to the respective
( contractors through the normal transmittal system.
Action to Prevent Recurrence:
i PIL was working on the premise that reports with nonconforming conditions l would be reported to the contractors upon full completion of the reinspection l program. PTL has since been advised to transmit nonconforming reports upon 1 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:
i PTL has started tra' M itting rejectable rep' orts to BBC. The first
- transmittal was #18479 dated 7/1/83. The latest was #18828 Dated 8/19/83.
This process is ongoing. This was determined by reviewing PTL transmittal log
- and transmittal.
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- Page 2 Surveillance Report No. 4939
, PTL
( ggE,ERVATION #3: (response PTL)
FTL is not reinspecting each individual inspection performed -during the
. inspector's first three (3) months, where accessbile.
DISCVSSION:
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.
PrL is not reinspecting each individual inspection performed during the inspector's first three (3) months, where accessible.
Corrective Action Taken:
prL is now reinspecting each individual inspection performed during the
\ inspector's first three (3) months, as directed by Couronwealth Edison via the
{- Stiede-Kepplor letter 2/23/83.
Action to Prevent Recurrence:
A complete review cf selected inspectors certification package to 1 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. l Tallent, PTL Site Manager and D. Smith, Unit Concept Supervisor. The type l inspection reinspected was visual W 1d 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. ,
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- Page 3 Surveillance Report No. 4939 PTL This surveillance is closed.
This closes the PTL portion of Findinc #1 and observation #3 of Audit -
- 6-83-66. ,
a Prepared by lelEW hate 8 !h CI Approved by .
. Date $ 'Sd 8',{.
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O AJR:tj:1040S .
cc: W.J. Shewski/J.S. Bitel
- NwQ.A. Supt./ File ,
Contractor O.A. Audit Staff Desg. -
PCD Supt.
- Project Manager AJR '
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- BYRON SIT.' OA SURVEIt, LANCE 1 < AUDIT CLosF M"' NQG: 53.4 Report No. 5189 Date 10/12/83 AUDITNo.T8'346I contractor / Organization: Hunter Corp. ..;
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FIM)ING #1:
Contrary to 10CFR50-B. Criterion XV, certain contractors were not taking appropriate measures to identify, document, segregata, dispositi.a. 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 repor*s being initiated. Problems with component support 2FP12016 were documentou on Field Problem Sheet #FP109F rather than on a discrepancy report. No DR was issued for rejectable iters ,
associated with component support 2FP14056X because Hardware Removal Report ,
- 1380 has been initiated due to y 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 ;,pecified torque of 70% of the initial value when reinspected: SSX 100-23 N177, SSX 100-23 M 178. SAB 100-43 MJ23. 800 100-34 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 t$me 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 Field 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 perforced 6/7/83 and 6/8/83. The reinspection resulted in generation of Field Problem AB37580, B&1. ECN 8233, and DR no. QC-2FP14-004.
Hardware Removal Number 1380 and X ECH 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 TO PREVENT RECURRENCE:
None required. Reinspection is completed.
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(12283)
- P&ge 2 Surveillance Report No. 5189 8
- Hunter Corp.
(
DAT3 WHEN PULL COMPLIANCE WILL BE ACHIEVED:
Due to the isolated nature of the cited problem and actions taken since the actual time of the problem, we consider oursehes to be in compliance at this time. J' f. ,
FOLLOW-UP:
10/12/83 - Reviewed Hunter Corp. discrepancy report QC-2FP12-001 (Attached) and QC 2FP14-004. Hunter Corp. discrepancy Heport QC-2FP12-001 is associated with cceponent support 2FP12016. Hunter Corp. discrepancy report QC-2FF12-004 is at,sociated with component support 2FP14056X. Hunter Corp, has received direction from Ceco. PCD which enables them to consider bolt torque inspectionr, as inaccessible. See attached Hunter Corp. inquiry dated 9/15/83 and S&L letter dated 9/14/83.
This' surveillance le closed.
This closes Part "A" Findino #1 of Audit 6-83-66.
Prepared by //!' # L I Date /MIM/l ,
Approved by ,A Date //// 3 /7.3 ,
AJR:tj: 1228S Attachments cc: W.J. Shewski/J.S. Sitel W Q.A. Supt./ File
- Contractor i O.A. Audit Staff Desg.
PCD Supt.
Project Manager AJR l'
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BYRON S{,If,OA SURVEILLANCE 1
j AUDIT CLOSE OUT OF: 2834.22.2.1 l
Report No. 4948 AUDIT No.'6-83-66 Date 8/29/83 l
[
Contractor / Organization: NISCO 1
00SERVATION M:
For some inspectors, the numb r of items reinspected, though in agreement wiih the Stiede-Keppler letter, do not provide an adequate sample size.
DISCUSSION:
Observation #5 Part B (NISCO)
Commonwealth Edison's Project Department verbally directed all contractors with the exception of PTL/ Peabody to provide a minimum sample size of fifty (50) attributes.
The following inspectors were reinspected for less than. fifty (50) inspections:
R. Schultz 16 Inspections M. Weir 39 Inspectiorc T.J. Ptult; 30 Inspections The number of items per inspection cannot be determined from information provided CORRECTIVE ACTION: 1 Audit was performed prior to the completion of NISCO's reinspection
! program.
R. SHULT2 l
All items initially inspected by R. Schultz were reviewed and included the first ninety (90) day period, as well as the second ninety (90) day period
- through termination, plus six additional Process. Control Sheett which were initially overlooked
- PCS's - 221, 407-15. 407-19, 407-24, 407-8 and 407-9.
, K. Jackson performed the reinspections on these packages. PCS-221 was found to be inaccessable. PCS's - 407-15, 407-19, 407-24, 407-8 and 407-9 were acceptable. These five (5) inspections added to the sixteen (16) already perfot.aed bring the number of total items reinspected for R. Shultz to twenty-one (21). No further items are available to retrapect. No ANI. third party, inspection was done, so this is the total number of reinspection items for W. Shultz, e
(1047S)
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Page 2 .
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Surveillance Report No. 4948 N!SCO i
. M. WEIER !
l
[' only thirty nine (39) items were accessable within the first a.inety (90) ,
day period. The second ninety (90) day period to termination provided eleven
- (11) items. K. Jackson performed the reinspections and found all to be acceptable (PCS - 826. 826A. 410. 410A. 411. and 409).
j T. J. PRUITT l l
l l Only thirty (30) Atees were accessable within the first ninety (90) day 4 .
period. The second ninety (90) day period to termination provided no
> accessable items. NISCO D.J. Engolia and CSCo. B. Klingler agreed to use the '
]' ANI as the third party verification of the previous inspections. (See attached -
letter). This added an additional 28 items (PCS - 326. 324, 608) to Mr. i Pruitts previous inspections. !
- i j All items were found acceptable by the ANI. I
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An inspection item is one sign-off (Hold Point) step to a PCS regardless i of the number of attributes included with that step. j
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ACTION TO PREVu? RECURRENCE: ;
i Not Applicable !
t FOLLOW-UP ACTICW:
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l Verified that inspectors on PCS's noted above for R. Schults and M. Weier j, were documented as reviewed by reinspector. K. Jackson. All were found
- acceptable. ANI (third party) verification was noted for additional
! inspections on T. Pruitt as indicated by NISCO and ANI signatures at ANI hold l l points on respective PCS's. j This surveillance is closed and also closes Observation 95 Part is of Aud' l 06-83-66. ;
I i Prepared by e rW 884**~4 & Date F/ M/93 Approved by
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Date Ja1 8 $ 3 SAA:tj: 10475 l 4
Attachment {
) cc: W.J. Shedski/J.S. 51tel ,
j Q. A. wpt./ File !
i contractor ;
N Q.A. Audit Staff Desq.
j PC7 Supt. !
Project Manager
! SAA !
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SCO
- e 'd N i 1 ',"-
l ', , s NUCLiAR INSTALLATION SERVICES COMPANY m====n
, .- --.a.-ce -e _
OYacN, ILL. 41(.10
- s. P.O. BOX 752
< TELEPHONE (815) 234-5240 August 1 1903 1.vtter No. 300,-BYC_25S Commonwealth Edison Co.
S ta t ion Cons t risc c ion Byron, IL 61010 .
To: 5. Klingler
Subject:
QC Inspector Reinspuccions
Dear Sir:
Reinspection of fuur (4) NISCO QA/QC Fagineers were per-formed and coupleted on 7-5-83. The reinspection of two (2) HISCO QA/QC Engineers, M.Weier and T.J.Pruitt was reopened with the generation of Commonwealth Edison's cotrespondence dated 7-7-83, requiring fifty (50) items per each ins pec tor. .
NISCO, in order to comply with this requirement has re- '
evaluated the first n'inety (90) day period, and reviewed the second ninety (90) d.y period through termination.
Upor. review, it was.notoc chat a good majority of the work NISCO has performed, is now inaccessable, making reinspection of this work impossible.
This problem directly a!! ces the reinspection of items NISCO QA/QC Engineer T.J. ruitt inspected. D.Engolia, NISCO QA, brought this Jiaustion to the attention of ,
Mr. 5.Klinglet of Commenwoalth Edison's Project Construction Dept.
Both, Mr. 5.Klingler and D.Engolia agreed to use the '
A.N.I.'s third party inspection of inaccessable itens, se a reinspection, to make up the balance of fifty (50) items for T.J.Pruitt. (Raf. Attachment).
Twelve (12) additlennt i t e s. were accded to meet the required fifty (50) inspection items for T.J.Pruitt, twenty-eight (28) have been provided because they incompass three (3) P.C.S.'s.
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NISCi QA/QC Engineer M.Weier, had enough accessable items In tne second ninety (90) day period to provide the eleven (11) teinspection items required to complete the fifty (50) (tem requir6 ment.
NISCO has now completed the reinspection of all four (4) QA/QC Enr.incers, as required by the "Syron Q.C.
Inspector Reinspection Status", dated 6-6-83. If ther aro any questio.is please contact D.Engolia at Ext.408, s
. Thank you, ,,
h>2; 8rd51 dJ,Yngo i QA/QC Engineer DJE/es cc: File M
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- 1' . ' BYRON SITE OA SURVEILLANCE
( AUDIT CLOSE WT QG' 1L.i Report No. ill AUDITNo.[83M6I Date 1E12/83I Contractor / Organization: Hunter Corp.
ks'Ei$ATION#5:
withForthesome ins Stiede pectors.letter, Keppler the number of items do not provide anreinspected, adequate sample though size.in agreement DISCUSSION: observation #5 Part A Commonwealth Edison's Project Construction Department verbally directed all contractors, with the exception of PTL/ Peabody, to provide a minimura sample size of fifty (50) items.
of the five (5) Level II QC inspectors reviewed during the audit, three (3): 5. Pepitone. 5. Kilpatrick and J. ooten did not have the minimum of .
fifty (50) items reinspected.
i Hunter Corporation Response:
CORRECTIVE ACTION:
( Mr. Pepitone's dato base was expanded to include his full term of employment as an inspector with Hunter Corporation. This resultod in reinspection of fif ty-one (51) of his inspections. In relation to Mr. ooten l 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 PREVEM. sJCURRENCE:
None required. Reinspection is completed.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
l We are in full compliance at this time. ]
FOLLOW-UP ACTION: I 10/12/93 - Reviewed records of individual reinspections submitted to Ceco.
PCD by Hunter Corp. P. Pepitone. Emp. #1284. had a total of fitty-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) .
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Page 2 .
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+. Surveillance Report No. 5187
, Hunter Corp.
- s. .
This surveillance is closed.
This closes part A of observation 65 of Audit #6-83-66. . .:.. .
t 1
Reported by 7 Date ////f
- Approved by Date 4/r.7/97
/
AJR:tj:1226S Attachment cc: W.J. Showski/J.S. Bitel N QA Supt./ Site O.A. File
- Contractor PCD Supt i AJR L
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. ;.. HUNTER CORPOR ATION
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- r ;- 3000 179TH STREET HAMMCWo. INotANA'46323, Q19)445 0000 Q12)7315000e
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, , ,. j ~ H C IQA-411 , . , . ,
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. September 1, 1983 -
.cc: 't. Klingler !
-K.R.-Selman l Ccmmoriwealth Edison Company '
.C.. -
L. Hadick l 4450 North German Church Road e <- *
' '. . / ,
M.L. Somsag i Byron, Illinois 61010 *
a *
" Original to NRC i
.. Reinspection File l Attention: Project Constructiori 04' t *mt - -
Mr. R. 8. Klingler o
l Quality Control Supert / .
Subj e c t : NRC Reinspection Progran .' :.3 ,. .' . l Mr. Klingler: . .
. ,. ./ c m .
s., .
In completing our reports for the su Cect. activity it has been identified that we could not attain the minimum of 50 reinspections eact) for 3
, individuals (R. Sturgess, J. Ooten and S. Kilpatrick). The quantities of i roinspections that could be performedsfor each individual ara listed below.
l . .
R. Sturgess (#9208) 19 J ten (#1211) 28 .
S. 1 Patrick 30 e ';
(#1054)
I
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- - tm~. - - -
l 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 circunctances, I present the following inquiry. -
Is it necessary to expand the inspector population or will it be. acceptable ;
I to let the record stand as is. '
l Please indicate your response in the area pro.vided. . ;
1 . ?
, . . . 6 i Sincerely.yours, .
i .. .
I HUNTER CORPORATION * *' '
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S' M . t. .~ SonTs a g .~ ,
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- Quality Assu sne Supervisor . '
. e O Eipand Inspector population.
Ceco Response .
Record may sta'nd as is. . '
! k R.B. K12ng er z
Date bb-Ceco.Q.C. S rvisur ,
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. BYRON SITE OA SURVEILLANCE QG: pld
( ., AvoIT CLOSE OUT
. Report No. 5188 AUDIT No. 6-83-66 , Date hir12/83 contractor / Organization: Hunter Corp. y i OBSERVATION #1i; Application of the term "inacceesible" to those items which receive multiple inspections does not correspond directly to the definition of "inaccessiblo" 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:
l 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 l ( making the original inspection unrecreateable. ,
i 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, i
ACTION TO PREVENT RECURRENCE:
i j N/A ;
i DATE WHEN FUL1, COMPLIANCE WIL), BE ACHIEVED:
N/A !
l FOLLOW-UP:
10/12/83 - Per R.B. Klingler. CBCo. PCD. the Hunter Corp. application of interpretation #2 (see Attached) is correct. When subsequent inspection of ,
the same type occured, the later inspection was reinspected and the earlier l inspection is considered inaccessable. ;
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, MUNTER CO!I?GRATION .
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( INT 3R. COMPANY CC3R33 POND 3NC3 -
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O y,J n'.A om April 12,1983 jf# #
to- Bob Klingler ), L no>
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Lee E. Hadick -'
V sonef NRC 6einspection Meeting of April 11, 1983 t{
It was my understanding that we will not perform any t' urn of . . -
the nut inspections. They will be shown as inaccessable. .
If punch marks are not present on a fit-up inspection (small ' t + -
bore) the inspection will be shown as inaccessable. '
_C. .
? ,
Final torque will be serified by using a calibrated wrench. ~
We will tighten each bolt in sequer.ce, stop when the nut begins to turn, and record this data for each stud. We will not brinj the^- - -
bolt up to final torque condition. ' ' "
' % ./ Ae O ;"t el hy vcA.< . Ne rnich Paw /
, On type 3/4 inspections damage will be considered inaccessable.
( If we are verifying a type 3 inspection and a type 4 was performed, it will be shown as inaccessable. If we are verifying a type 4 inspection and another type 4 (45 day) was performed, it will be shown as inaccessable..
~
If we are verifying a type 4 inspection, we'will do it without removing the covering (inplace, intact).
l.'e will proceed in the fashion'shown unless otherwise informed.
, Q,.e: J
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IEEE.HADICA QJality Control Supervisor ,
cc: M. L. Somsag , .
LEH/pb .
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p' . o Page 2
( .
. Surveillance Report No. $188
. Hunter Corp.
This surveillance is closed. ,,
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This closes Part A of observation 81 of Audit #6-83-66. .
S Pregred by A IIJL- Date /dI AM 3 ,
Approved by N[6 Date h/t 3/15 -
/ ,
AJR:tj:1227S '
Attachment cc: W.J. Shewski/J.S. Bitel ..' .
NQ.A. Supt./ File Contractor .
0.A. Audit Staff Desg. '
PCD Supt.
Project Manager >
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BYRON SITE QA SURVIILL.hNCi) f AUDIT CLC68 OUT ,
'N QG: lid f Report No. }1M AUDIT no. M ,, Date EM~8i '
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Contracter/ organization: Blount Brot.hers Co. ,
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One inspector chosen for the reinspection program was not reviewed in all ;
areas of inspection activity during his first three (3) months of !
J certification.
i 4
] gl39USSION:
! R. H. Bay had performed masonry inspections during his first 90 days of !
certification at Blount Brothets Corporations these have not been reinspected.
3 Blount Response t'ated 8'4/83:
- J In reference to the reinspection program, the reason asc did not pe: form l j any masonry reinspections for R. H. Bay for the first 90 days of his i certification was due to a conflicting interest / inspection with another QC -
1 inspector during the initial period. ,
1l Prior to making the following decision, the problem was discussed with l 1
R. Tuotken. C.E.Co. PCD. It was mutually decided to substitute welding for i 4
( masonry in the reinspection program for R. H. Bay.
j , FOLLOW-UP: 10/12/83 ,
l a
1
' Due to the fact that sawonry inspections were often performed by more than l one inspector it was determined that the quality of Mr. say's inspections i
j i '
I could better be judged by reinspecting weld inspectic.:J he performed. This I was verified per a co.wersation with R. P. Tuotken on 10/12/83. i i
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i This surveillance is closed,
{9 This closes observation t6 of Audit 6-83-66.
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Date JIt
,pprovedby T a u . .te
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AJRijc 12315 / j
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cc: W.J. Showski/J.S. Bitel N O.A. Supt./ File l Contractor *
! Q.A. Audit Staff Desg.
i PCD supt.
j Project Manager f (
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AUDIT CLOSE OUT
( Report No. 1192 AUDITNo.,k83-66 4 Date 1b12-8I Contractor / Organization: Blount Brothers Co. .
FDEM #1 Part D:; y;. .
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: Finding,#1 part D (Blount Brothers Corporation)
At the time of this audit. Blount Brothers Corporation had not yet i generated any DR's or DRC's for rejectable items discovered as a result of the reinspection program.
Excerpt from Blount's Letter to R. B. Klingler dated 9/16/83 .
L l
BBC Tas a total of 30 tejected reinspections. Four of those rejections 1
are minor defects that can be repaired and have no significance to safety.
Three of the 30 rejections are related to concrete expansion anchors of which one has insufficient embedded length and two are not installed per detail as a result of missing embed plates. These have no significance to safety.
! The remaining 23 rejections have to do with structural welding. The ones r
that could have some safety significance would be:
- 1. missing weld !
- 2. missing plate t
- 3. wrong plate size (all smaller sizes)
BBD has initiated the following deviation reports (see attached) for
> resolution to the significance of safety by consulting engineers and to receive corrective action: 3 k
] 03-701 Q3-714 !
4 Q3-702 Q3-711 03-703 ;
FOLLOW-UP: 10/12/83 f f '
i Reviewed Blount Brothers Corporation log of D.R's to verify that follow-up l
was initiated as a result of the reinspection program. In addition to those l listed in the letter dated 10/12/83. Blount has initiated DR's 724 and 725 on 9/15/83 and 719. 715, 716 and 118 on 9/13/83, a \
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(1232s) .
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Surveillanca Repot .Jo. 5197 i
, Pm 2 l f
Blount Brothers Corporation This surveillance is closed.
This closed Part D of Findinc #1 of Audit 6-83-66. ;. ,- .
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, Ui Prepared by a A- Date A dr l 4_
Approved by Date h /3/ #-
r AJR:je:1232S cc: W.J. Showski/J.S. Bitel N Q.A. Supt./ File Contractor
- Q.A. Audit Staff Desg.
' PCD Supt. .
Project Manager
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d '.. nd BYRON SITE OA SURVEILLAk, r
i AUDIT CLOSE OUT 00: 53.4
( Report No. 5199 AUDIT No. {-83-66 f powers-Azco-Pope -
Date 10-13-83 Contractor / Organization:
- . . _ . _ . . . . . . - . . - =.... - - -__
l
%ERVATICW #4:
- The status of rejected reinspection items is not determinable.
DISCUSSION:
The reinspection sample record does not note the FIS report number which !
lu, used to disposition nonconforming installations. Without this information supplied. the status of the open items could not be determined by PAP at the 1
time of the audit nor could the auditor assure a discrepancy report had been !
, initiated for those items.
) PAP Response Dated 8/3/83 observation #4: >
As noted during the audit, and as documented in our Reinspection Instructions dated 3/15/83 (IO/QA 32-83 Rev. 1.Section III). reinspection items which are found to be unacceptable to current acceptance standards are i coded 14. the Reinspection Sample Record. This coding system does not identify
( the FIS report number due to the fact that the numbers are not available at the time of reinspection, j
We are ctlerently cross-referencing the FIS report numbers to the !
applicable reinspection reject item by including the report number on the l Reinspection Sample records. The status of a particular FIS report is i obtained via the tracking system established for discrepancy reporting per our l Procedure QC-4. l l
Anticipated completion of this cross-referencing activity is 9/5/83. !
4
.I POLLOW-UP: 10/13/83 .
Reviewed records of PAP Reinspection program which had been turned over to j C.E.Co. PCD. FIS numbers were listed on reinspection reports after i J
corresponding rejectable inspections.
l 1 l (1233S) i 1
. . t surveillanca Repor* No. $199 ,
i Page 2 ( l Powers-Azco-Pope -
observation #7
{3 '
Six (6) months as oppo&ed to three (3) months of an inspector's work was reinspected in the original sample. , ,: ; , , ,
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Discussion:
M'.f # ?y - *
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. ,,1 i -
becauseofamisunderstanding.PAPconJ1deredthesinachthfineperiodto l be the original sample failure to aset the acceptable quality level after j this time frame resulted in an additlonal 90 days of reinspection rather than ,
the entire remainder of an inspector's work as specified in the Stiede-Neppler l 1etter.
l 1
PAP Response Dated 4/03/83 l
l Observation 07:. l l As noted during the audit, your Project construction Department was well I aware of the initial sample size that was employed (6 months). A meeting was (
conducted on 6/22/83 with your R. Tuotken, at which time it was decided that j when a failure was identified during the evaluation of the initial sample results (6 months), all remaining inspection of the failed category would be [
subjocted to reinspectton. This commitment is documented in our letter
- PAP /QA 110-83 dated 6/22/83. A copy of this letter is attached for reference.
The consitment documented in the above referenced letter was implemeted. :
( where applicable, for all inspectors included in the reinspection popa41ation.
FOLLOW-UP: 10/13/83 ,
verified with R. 5. Klingler C.E.Co. FCD. that the methodology employed ;
by Powers-Asco-Pope to determine when 100% reinspection is warrented is an f acceptable method. The elimination of the second 90 day period did %t affect !
the reinspection results. (See attached PAP letter dated 6/22/83 Number i PAP /QA110-43). j This surveillance is closed.
This closes M rvation 64 and observation 97 of Audit 6-83-66.
___ - ==- _ =_- - . ~ . - - _ _ _ _ _ =-- _ . ,
Prepared by do Date 8 t/d 2 AJR:jc 12335 Approved by /A6VM
~
Det.44 des ' '
'f cet W.J. Snowski/J.S. Bitel
. Q.A. Supt./ File contractor -
0 A. Audit statt Desg.
pco supt.
l Project Manager .
A. A it
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az POWERS-AZCO-P@FE NUCLEAR INSTRUMENTATION CONTRACTOR
( '
g P. O. BOX 392 BYRON, ILLINOIS 61010 815/234 5426
\_/ .
PAP /QA 110-83 June 22o 1993 Commonwealth Edison Company Byron Station P. O. Box B sytono Illinois 61010 .
l Attentions R. P. Teutken Assistant Project Superintendent -
1 Subjects Specification P2906 .
Reinspection ProgtAm .
per our conversation on this date relative to the subject program it o was confirmed that the following action applies to expansion of a particular inspectors sneple popuistion when failure in evident from the results of the initial six (6) month snaples , ,
j !! Reinspection of first rix (6) month sample results in rejection of one or more inspection categories all remaining inspections of
( o the categories for which faijute was noted shall be reinspected. .,
Additionally, the six month sample (as currently accumulated and documented) is an acceptable basis for evaluation as to as individuals credibility. ,
[I >
As agtredo we will reinspect all remaining work (in each failed category)
! for each individual who failed to attain the required confidence level
}
within the initial six (6) months sample. The attached list indicates the personnel requiring such action along with duration of the tensining population for each. De advised that we will make every effort to corplete the seinspection by the scheduled 6/30/83 deadline.
If you have any questions please contact the undersigned.
- gl AE Robert P. latkin Quality Assurance Managet
- k. ces R. Sch51s R. Klingler Reinspection flie
. file (2)
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PAP /MA 110-83 ;
PCWER3=A2CO-PCPE ATTACHMENT 01 !
?
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RzzxsrzCTroM status TzRST SAMPLE SECOND MANt N05.
PERICD MCS. RESULTS SAMPLE MOS.
MEMATNTNC,
! r. saker 12/15 - 5/J5/82 (6) Pru 884 1
PW 734 NV 654 $/15 - 8/16 (3) 5
! G. W2ggens 12/2/80 = 5/2/81 f,6) PW 864 i ;
MW 605 $/2 ='8/2/81 (3) 3 '
Me Anderson 2/2 = 7/1/82 (6) PM Sit +
} Nw $65 rh sat 7/1 '- 7/16/82' (1) 0 l T. MacDonald 4/2/ - 9/2/81 (6) PW 874
- MV 495 * ;
F# 634 '
l l
riex21s 9/2 - 10/4/81 (1) 0 G, Cosha 1/2 = 22/2/81 (6) NW 795 12/2/81 - 3/5/82 t
FM Jet (3) 0 1
- Ao stevenson 9/30/81 - 3/30/82 (6) Mw 104 !
i FM ist 3/30 - 4/23/82 (3 ) 0 1 *A. Gillespie 11/16/78 = 4/16/80(6) NM 165 4/16/80 - 7/12/82 t'28) 0 l Re Bardell 7/2/82 = 22/2/81 (6)
~
NM 844 . . l J -
- 't Jft i j FW 235 12/2/81 = 3/2/82 (3) 4 -
i Je %challer 4/30/80 = 20/30/80(6) PM ??t ;
) -
, NM 835 .
\ MW '635 10/30/80 - 2/30/81(3) 3 ,
J, Barlow' 1/28/82 = 6/1/82 (6) KW 825 Tiex75% ..
NJ 15% 6/1/82 - 1/20/82 (1) 0 '
0 to Grosch 12/1b/80 = 4/15/81(6) PW 80%
} MV 70% 4/1$ - 7/8/81 (3) 0 '
i A. Schlegel 11/25/78 = 4/15/80(6) MM 30%
j Nw 04 4/15/80 - 7/80 (3) 0
} I l Expanded to entire population due to limited quantity of inspection sign =c"* as l DC Totertan. ,,
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AUDIT CLOSE QUT IG: }.L.i f
' Date f0-1f '8'3 j ,
Report No. ).292R1 AUDITWo.5-83-66I Contractor / organization: Hatfield Electric Co. !
l :
l FnmING G11 m
Contrary to 10CFR50 Appendix 8. Criterion XV. certain contractors were not l i taking appropriate measures to identify, document, segregate, disposition, and !
j notify affected organizations of nonconforming items identified under the !
l reinspection program.
a i DISCUSSION:
l 4
During the reinspection program, nonconforming conditions were identified which did not result in discrepancy reports being initiated. Field probles .
sheets were being taplemented to resolve reinspection items in the conduit and terminations area. The field problem sheet is not procedura11 sed. ,
! Hatfield Response Dated 8/04/43 ,
QORRECTIVE ACTIOli:
Field problem sheets were generated for conduit itous which could easily 1 i be correctec by the area foreman in a short time period. Bone items were j j
(
A corrected immediately, the balance is being checked for completion. All field problem sheets are filed to verify that all corrections were made. Field l
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 i
owner. ,
l
' NCR #674 was written to correct this problem. i E I.I N : l Instruct inspectors not to use field problem sheets.
. t FOL1,0W-Up: 10/13/43 l HEco. NCR #674 was written to disposition the deficient items discovered l l during termination inspections. This WCR was closed 8/22/83 (See attached). ]
I Discrepancies which had been identified on field problem sheets were included in the results of the reinspection program as submitted to CBCo.
j PCD. A review of the reinspction program reports submitted for E.A. Durras.
- J. Buchanan. K. Cripps. E. Getzelman. H. Holze and F. Keep revealed fiold i problem sheets to be included. The inclusion of field problem sheets with the
- reinspection progras reports enabled Caco. PCD to make a deteruination .
1 concerning the acceptability of inspections which resulted in field problem
! sheets being generated. This appears to be an isolated case which has been l adequately resolved.
- L, (12375) f
('
- Surve111anco Rey 3rt ..s. 5202R1
- Page 2 Hatfield Electric company i
(' This surveillance is closed.
This closes,_the Hetfield Dortion of Findino #1 Audit 6-83-66.
Prepared by aw- Date / 11 Approved by a. Dece/e-Jt-t3 AJR:jc: 1237S i cc: W.J. Shewski/J.S. Bitel l p 2;A. Supt./ File l
Contractor Q.A. Audit Staff Desg.
PCD Sept.
i Project Manager
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' NONCONFORPddhCE REPORT REPORT 670 --
HOLO TAG No.
/
/ -
P.O. No. M/A MRR No..N/ A MSR No _ N/A Material: Vendor - H/A '
16 & _ N G Elevation M3 Columrs _
Ora *Ing _1 4665A R w. ' '
Egulpment: -
~
1AP22E Comet. A1 -
Equipment Dextlption _
... installed in compt A1 drnving enlla fnv Nonconformance: _ The venng ngastat was
. instn11 pd .
n ?n??AN. but nan f'iirninhnd n 701?An which van Y*#~k5 Date: _
- h Otnerved By: _ #' ' N Date:_
HECO O. A. Mansper:
& *o Eb//r we .f N,e s r*a e y4
- n. Correcuv. Action:
2/ / t i
, /< h , L 4-L e J R M ".G~S*
< -t; o e, a ema/
( O Ah % );ad ,
ec:nr:nc:wMme !
a+ +~ v . /s - . u t;mne w w g u r e ec+
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Action to Prevent Recurrence: _ I Ra.Tf! ELD EgTRIC COMPAfD-1
+
nt May Prcceed With The Following Rptrictions:
av Pr W ork: May Not Proceed
,. OMO- ~
1 n5EMA" i
c
- Date:
d Approved by CECO PCD:
CECO Hold Teg No.
d CECO NCR No. -
Oste:
N * "O '
A Concurred By CECO Q. A.: --
Oste: __ 9 5 'R lit. Corrective Action Completion Verified By: _
/
e pp ,gy
%: tion To Prevent Recurrence C
~ #
^# 08t' Hold Tag Removed By-
- Date: _
NCR Close out Reviewed By: _
'~~~~^
, f (Levelllpr Hig5erl I Pope ] of ,
' E
, ,,a 8 BYROW SITE QA SURVIII,1.nl i
' ~
o AUDIT CLO3R CUT QG: iL_(
(f , Report No. 1U9, AUDIT No. @ ; Date b1'4-8d contractor / Organization: Hatfield Electric Co.
M TICW #1:'
Application of the term "inaccessible" to those steps which receive multsple inspections does not correspond diroctly to the definitson of "inaccessible
- of fered in the Stiede-Keppler letter dated February 23. 1983.
DISCUSSION: .
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 esemple 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 Itens which could not be physically reached or whore conduits and hangers
( had been changed per print revisions. FCR's or ECW'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.
IRLOW-UP: 10/14/83 The error in terminology has been resolved via the research performed by Hatfield. Inspections which cannot be recreated are properly termed "inaccessible".
CBSERVATION #6: .
Hatfield Electric could not determine if a portiots of the conduit inspection is subject to the reinspection program.
(1240s)
_ . -. ~_- - - - -
.n.
1 ga i ,o}..' surveillanca Repork ,o.
pag. 2 5210 .) ,
Hatfield Electric Company
( Discussion:
4 Torque checks in the conduit area were determined to be non-r'eproducible l j inspections despite this, bolt counts were taken durirul reinspection. The !
bolt count was included in the original conduit inspect:,on to determine the l
- proper number of torque checks to perform. Differences in bolt counts between i i
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. Hetfield Electric Company needs to (
determine if bolt counta should be a pert of the reinspection progran and. 1f f so, how to resolve these items.
Hatfiel'd Response Dated 4/25/83 , l solt counts will not be included as part of the reinspection criteria.
l Dif ferences in bolt counts on the reports cannot be investigated since both ;
the original inspector and report revleuer are no longer employed by Matfield j (
- Electric company. -
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j FOLLOO UP: 10/14/83 j The elimination of bolt counts from the reinspection program has resolved this deficiency. ,
This surveillance is closed.
This closes % rvation et of Audit 6-83-66. !
l I f, This closes Mrvation #1 Part B of Audit 6-83-66. I 1
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) cc: W.J. Showski/J.S. Bitel 3
N o.A. Supt./ rile contractor [
Q.A. Audit staff Desg. j
] sco supt.
1 Project Manager
] MR 1
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- ..*."., BYRON SITE M SURVIILLApF j
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\ 90: M f AWIf CLOSE CUT
( Report No. }]l1 AUDIT No. Y -b k Date M l
j Contractor /Organisation: Hatfield Electric Co.
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] @ TERIS21 / - ,
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Hatfield has not performed an evaluation of On/9c Memorandum #295 for its potential offeet in the reinspection program. l DISCUSSION:
Hatfield Electric Company Ok/QC Memorandtun #295 dated 9/17/82 states that .!
) i j' an acceptable weld inspection of cable pan or conduit hrangers implies >
i serification of the correct connection detail. This manner of acceptance i
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 j determination must be made as to what type of inspection, either weld or
- hanger inspection, originally included the connection detail. After this '
detersination is made. the connection detail can be inM uded as an element of the proper type of reinspection.
, T l Matfield Response Dated 8/25/83 .
(
i Fireproofing was removed on &ll items which had to be reinspected for the program. If it was the pan hanger detail itself or a weld traveler to be l reinspected, the material was removed so that the connection detail or the i j . w lds could be inspected as individual attributes. Memo #295 was not !
. considered during the reinspection. i l !
Hatfield Response Dated 8/30/83 i please be advised that connection detail verification is originally included in hanger inspection report.
l I POLLOW-VP: 10/14/83 l
l The determination tri Mattleid that the connection deta11 verification is part of the hanger inspection closes this deficiency.
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- * * .* surveillance Report . 5211 ,
Page 2 Hatfield Electric Co. l This sutveillance is closed..
%is closes r**arvation 62 of Audit 6-83-66. -
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PreparedbyM t dId M 78 2 Approved dy S E wW .mte to n-n P
AJR: jct 12413 l
cet W.J. Showski/J.5. Bitel N O.A. supt./ File contractor .
Q.A. Audit Staff Desg. .
.i .
PCD supt.
Project Manager '
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.;/ SYRON SITE QA SVRVEILLANCE ,I AUDIT CLOSE OUT d -
( mig: M Report No. )ll], AUDIT No. k B3- M Date: M1 Contractor / Organization: Powers-Azco-Pope
............................................... .. . z. ..._
G r'vitson 97:
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sit (6) months as opposed to three (3) months of an inspector's work was ,
reinspected in the original sample.
Discussion:
Because of a misurY1erstanding. PAP considered the six month time period to l
be the original samples failure to meet the acceptable quality 1cvel after this time f rame 'resulted in an edditional 90 days of reinspection rather than i .
the entire remainder of an inspector's work as specified in the Stiede-Keppler r
- letter.
PAP Response Dated 8/03/83 ,
]
obs+rvation #7:
! As noted during the audit, your Project Construction Department was well aware of the initial sample size that was employed (6 months). A seeting was conducted on 6/22/83 with your R. Tuetken, at which time it was decided that
- ( when a failure was identified during the evaluation of the initial sample results (6 months), all remaining inspection of the failed category would be subjected to reinspection. This commitment is documented in our letter j # PAP /QA 110-83 dated 6/22/83. A copy of this letter is attached for reference.
l The ccanitment documented in the above referenced letter was implemented.
l where applicable, for all inspectors included in the reinspection population.
) FOLLOW-UP: 10/13/83 i
Verified with R.B. Klingler. Ceco. PCD. that the methodology teployed by l d
Power-Azco-Pope to determine when 100% reinspection is warranted in an ;
acceptable method. The elimination of the second ninety (90) day period did
- not affect the reinspection results. As outlined in PAP letter QA 110-83 (See :
attached) the reinspection of all reasining work for individuals whom did not attain the required acceptance level in the initial sample period put PAP in .
compliance with the intent of the Stiede-Keppler letter. l 1 ;
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.* s Page 2 Surveillance Report No. 5287 PAP This surveillance is closed.
This closes observation 47 of Audit 6-83-66. ' ,
Prepared by , J v- 1 - ,
Approved by M # d #
' ^^te w - z. 4 -r s. '
AJRttjt1284S [/ .
cc W.J. Showski/J.S. Sitel pdf.A. Supt./ File Contractor ,
f Q.A. Audit Staff Desg.
- PCD Supt. * '
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Project Manager t AJR L
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' POWERS-AZCO-POPE
(
NUCt. EAR INSTRUMENTATION CONTRACTOil '
' P. O. BOX 392 BYRON, ILLINOIS 61010 -
{' 815/234 5426 .
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t-PAP /CA 110~33 June 22, 1983
.,.'*i..
Conwenwealth Edison Company ,
Byron Station ' '
. P. 0.* sox s .
Byron"; tilinois 61010 . .
l Attentions R. P. toutken Assistant Project Superintendent , ,
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Subjects . Specification T2906 Seinspection Progran
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~ ret our conversstion on this date relative to the subject progran o it 1
. was confirmed that the following action applies to expension of a '
particular inspectors sanple population when failure is evident fron l -- the results of the initial six (6) scnth sanples ,
!! Reinspection of first six (6) renth sarple results in rejection
( of one or more inspection categories, all tennining inspections of jf ,
the categories for which faijere was noted shall be reinspected. ,,
Additiona11go the six senth sample (as currently accumulated and y documented) is an acceptable basis for evaluation as to as . ,
individuals credibility. . j As agreed, we will reinspect all renalning work (in each failed category) *
- for each individual who failed to attatn the required confidence level
}
within the initial sis (6) renths sarple. The attached list indicates the ;
personnel seguiring such action along with duration of the remaining /
- population for each. Se advised that we will make every effort to complete the reinspection by th,e scheduled 6/10/85 deadline.
2f you have any questions please contact the undersigned. ,
Sokett P. Larkin Quality Assurance Managstr .
C
- ces A. Sch&ls R. Klingler <
Reinspection file
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, O.P. FoRMllL-L
., Commonwealth Edison Company Dm D/81 QUAUTY ASSUrtANCE MANUAL -
l AUDIT REPORT , , i
!)6-03-124 -
I Type Audit: U Program Audit CProduct Inspection Point
[ / Records C Special
. Tg: fir. J. T. Hill ',.
Project Byron Visit Dates /A9/1/83 Report Date o/45/A5 System various Component Identification N/A Material Description N/A Vendor Hatfield Electric Co. Lccation Byron _
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, Subcontractor _N/A Location ' N/A i '
I Contacts 9. % w+ -
1 P.O. No. Spec. No. F-2790 I
Recom. ended Inspections: 6 mos 3.mos 1 no l Other: As Scheduled !
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1 Notes: Corrective neeting. actions However, please havebybeen respond October agreed 4, upon during th l the date corrective actions will te complete for the Findingsi l
l Lead Auditor _ Nwv Date 9/ / pd7 Reviewed 47 N
- 1. A. Stanisn
- <5 Date70f/l'1 PTM: Je80298A l Attachment cci Manager CA P.T. Myrda Managar Projects G.F. Marcus (Byron Site Project Manager l Eng. Manager I Director CA Construction Site Cons +.ruction Superintendent Site QA farA.7f.Jff Auditee - I
) . Site CA Supervisor #[ Jo l l
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- AUDIT CEPORT HATFIELD C1.ECTRIC COMPANY AUDIT NO. 6-83-124 Purpose 1 To verti.
' - glomentation of Hatfield Electric Company. Quality
- Assurahce ic , a spplicable to the QC inspector reinspection program consitted tt / V octt It.E Inspection Report Numbers 50-454/82-05 and 50-455/82-L 4
Scopet The Audit included the following:
Inspect.1on Inspection, Test and Operating Status Quality Assurance Recotds Seferenge' Documents: ,
10CFR50 Appendix 5. Criteria X. XIV, XVIL Hatfield Procedurest 9A -
Entrance Meetinct August 24, 1983 P. T. Myrda QA Supervisor C.E.Co.
- M. V. De11abetta QA Engineer C.E.Co.
T. Maas QC Supervisor HEco..
J.D. Spangler 1.ead Welding Inspector HECo.
Exit Meetina: September 1, 1983 J. S. Bitel Director. QA Cor.st/Eng. C.E.Co.
M. A. Stanish QA Superintendent C.E.Co.
P. T. Myrda QA Supervisor C.E.Co.
QA Engineer C.E.Co, P. C. Cruber R. Tuetkern Assistant Project Supe intendent C.E.Co.
J. O Binder Project Electrical Supervisor C.E.Co.
R. B. Klingler PCD QC Supervisor C.E.Co.
J. T. Mill QA/QC Manager HECo.
J. D. Spangler Lead Welding Inspector HBCO.
Personnel contacted: HECo.
T. Hill T. Wells T. Maas S. Hubler j
' A. Koca D. McCarty J. D. Spangler 0
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. Audit R port No. ,
3-124 ,
- Page 2 Hatfield Electric Company 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 discrepartcies were identified.. The discrepant. items will be explained in Attachment "A". ,,'j.< g .y ,
Another aspect associated with the concerns related to the reinspection '
program is the identificat1On of deficier:t conditions. . The issuance and processing of NCR's and DR's will be covered under a separate surveillance. ,
i ADEQUACY OF REINSPECTION This audit examined Hatfield Electric Co.'s implementation of Commonwealth
- Edison's reir.Jpection cosemitment made to the NRC. The audit specifically '
examined the welding area and Hatfield's methodology of reinspection in this area. The reispection pecgram's main thrust is to. demonstrate the adequacy of' quality control inspecte.s. Based on this, it is essential to ensure the work reinspected is actually the inspector's work and not that of some.mo 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 prot,lems, adequate tracerbility back to the inspector's work was not always achieved. In cases where it was indetmerminate as to which welds were inspected by the 3rdpector, 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 er iewed during the audit. the decisions made by the contractor during the reinsp : tion program to remove questionable data adds to the credibility of the datai.ase thereby ensuring accurate results. The ultimate sample size used for each
, inspector was found to be adequate and sufficient to determine the acceptability of his work.
AUDIT DEFICIENCIES During the field verification part of the audit. it became apparent that Hatfield Electric Company's weld traveler cards. & certain cases. lacked j adequate information to determine which hanger welds or hangers corresponded ,
to each weld travelar. In certain casos. 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. (Reft Attachment "A" Finding #1).
This audat also included field verification of combination cable pon/HVAC hanger inspection completeness. Upon reviewing the records for combination i
hangers, it was determined that not all welds on these hangers have been l l inspected. For some hangers that were inspected the QC inalpector was not I
. identified on the weld inspection record. (Reft Attachment 'A" Finding #2) ,
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Audit 2: port'No. ( ,3-124 )
Page 3 .
Hatfield Electric Company Also, during the field verification part of the aud1t. forms 9A-1 (Configueation/ Dimensional Inspections) were reviewed to help establish correlation between hanger welds and weld travelers. During this review a '
hange:.was found to be installed inspected and accepted to a ' configuration other. than shown on the approved drawing. (Ref: Attachment'."A" ,- .
observation #1) ,
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.. ANALYSIS OF INSPECTION RECORDS
- H9tfield Electric Company is currently impleemnting a computerized '
'databnse management system in an effort to reconcile weld travelers to cable paa hangers. This database is being created in parallel with the reinspection prow::. a. When the information from the computerized database is finalized and ,
ready for use.;the weld travelers used in the reinspection program will be .
.l compared to the database. This should insure that the initial hanger,, !
inspections assigned to each inspector, were correctly included in the ' '- <- ' -
- ['
reinspection program results. - < 7; . .m
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The manner in which weld inspection records were generated and maintained at Hatfield makes it difficult to readily $dentify 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 misunderistand the manner in which the weld traveler records were selected during the reinspection psogram. 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 undersv.ood.
The HDRF Foem (Hangee Dehang/ Rehang) which coveea rework on hangers, 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 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.
SVALVATION ,
l The Hatfield Quality Assu nnce organization agreed with the problems identified during the audit and showed initiative in identifying the weld
, traveler problems by writing NCR ~101 on hugust 23. 1983. The HECo. QA/QC
, l inspectors desmonstrated an excellent working knowledge of their respective areas and presented an eagerness to do an offective quality job. Overall, the HsCo. QA/QC Departaent. As applicable to this audit, appears ta be effecttye
' in the performance of their responsibilities.
j Hatfield Electric Company Quality Aasurance Department is adequately l
implementing their portion of the reinspection program as committed to in NRC lj -) Report I&E Inspection Report Number 50-454/82-05 and 50-455/82-04. .The deficient items identified in this report did not impact the purpose of the ,
- -i reinspection program but were significant deficiencies that require prompt attention.
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ATTACHMENT "A"
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'6 Findinc #1 , e , ,
10dFR50 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 inspectionJ and tests
. performed upon individual items of the nuclear plant... These measures shall prov1'de for the identification of items which have satisfactorily passed i required inspections and test...." ,,.r. ,
10CFR50 Appendix B. Criterion XVII. states in part, "sufficient records shall be FAintained to furnish evidence of activities affecting quality."- .
- , contrary to the above. Hatfield weld traveler cards inadequate'ly identify the acceptability of the cable pan hangers. .f;. g4.i .
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- Discussion The weld traveler cards used by Hatfield for weld inspection. in many cases, do not adequately 14?ntify the item inspected. The problem stems from the variety of ways the weld traveler cards is filled out by field personnel.
Essentially, general field coord'nstes are used to locate the hanger (i.e. 15-N) instead of the exact coordinates. Also, there is no method of 4 assuring all welds are inspected, especially if rework is performed on a given l hanger. Additionally, the weld traveler may document one cr 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 status for a given hanger can be determined. In some cases, even field verification fails to adequately assure the completeness of inspection and a reinspection is necessary. l l
Corrective Actiont A correlation of weld traveler inspection data to design drawing cable pan hanger data will be established using computer database management techniquee .
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.
The acceptability of existing inspection records will be demons'trated 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.
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Audit R: port No. f 3-124 )
- . Page 5 Hatfield E1'ctric e Company Findinc #2:
10CFR50 Appendix 3. 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 jf.. ,- '
- 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.
Discussions .
Wol all combination hangers have weld traveler cards for welding performed '
l by Reliable Sheet Metal. For some hangers that do have weld travelers the,, ,
I weld connection is indeterminate due to the lack of information on the --
traveler. Also, some weld travelers do not identify the QC inspector .- - . j ' , _ .' -
performing the inspection. .,e: . ,[
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- Corrective Action:
'A review of a'11 combination hangers for adequate weld inspection will be performed. For those hangers whose status is Indeterminate a reinspection of the welds will be performed.
Coaseitment Datet To be established after scope of work is defined.
Qkgcevation #18' .
Contrary to Hatfield Electric Company Procedure 9A Revision 11. CIAss I Cable Pan Hanger Installation, quality control had inspected and accepted a hanger to the wrong dimensions.
Discussiont Hanger 15H2 on Dewing 6E-0-3033 Rev. H was inspected and accepted (HECo.
Report 835) to the dikeensions 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.
Qommitment Datet October 3. 1983 1
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RSINSPECTION_ PROGRAM i (ref: 82-05-19/82-04-19)
(
- 1. Background
- 2. Scope D* %d
- 3. Preliminary Results
- 4. Analysis of Discrepancies
- 5' Analysis of Inspectors Performance
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.. '. BACKGROUND f '
- l. CAT inspection March 29-31 April 1-2, 5-9,12-14. and May ll, 1982.
Apparent noncompliance with the requirements for the qualification of inspection personne1.
- 2. Noncompliance transmitted by letter dated June 24. 1982 (Norelius to Reed) and identified as noncompliance 82-05-19.
June 24. 1982 lettec contained a stipulated requirement to undertake action to assure that inspections performed by quality control inspectors that were deemed to be improperly trained and qualified were valid.
- 3. Proposed corrective action to noncompliance 82-05-19 and proposed corrective action to the stipulated requirement were transmitted by letter dated July 30. 1982. (Stiede to Keppler).
- 4. Proposed corrective action to stipulate <? requirement was found unacceptable by letter dated September 22. 1982 (Norelius to Reed) and required further action be accomplished. .
- 5. Subsequent meetings with NRC Staff yielded direction that further action required to address stipulated requirement must contain a program of reinspection.
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- 6. Revised proposed corrective action was transmitted by letter dated February 23.1983 (Stiede to Keppler) and contained commitment to execute a reinspection program.
A brief of the reinspection program is as follows:
A. (1) For 6 cot. tractors, every 5th inspector selected (NRC SRI added from 2 to 4 inspectors).
A. (2) For 2 contractors, evory 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 90% agreement rate
< in repeat inspection.
D. (3) Subjective inspections would be subject to independent third party review to establish true rejectability.
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- *. 3-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 achievo 95% agreement rate or 90%
agreement rate, as appropriate, in second three M; nth period, than all inspections performed by the inspector of rw type which failed would be reinspected: and the original sang,h oize of inspectors would be increased b/ 50%.
- 7. NRC Region III Staff have conducted numerous reviews of the reinspection activities and have maintained a relatively high level of involvement in the proceedings.
The following presents the status and results of the program to date.
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- 1. The program began February 22. 1983 by meeting with contractors which established the population of selected inspectors and began records search to establish individual inspections to be repeated.
- 2. A. Quantity of Inspectors Reinspected l
Total Number of Percent of Population of Inspectors Inspectors Inspectors Re, inspected Reinspected Blount 28 8 29%
JCI 1 5 *1 71%
Hunter 84 21 25%
Nisco 8 4 50%
- HEco 86 22 26%
PAP 21 19 *1 90%
PTL 85 19 22%
Peabody 32 6 *1 1 63 l TOTAL: 356 104 29%
- 2. B. Qu.a.ntity Of Itees Reinspected i
Number Of h' umber of Reinspected objective Subjective Inspection Inspections Inspections Months Blount 2.390 0 83 JCI 7 812 1.459 18 Hunter 69.626 3.662 62 NISco 209 *2 35 *2 12 *2
, HEco 56.495 *2 24.162 *2 54 *2 ,
PAP 8.144 6.936 149 PfL 7.269 *2 4.158 *2 49 *2 Nabody 0 108 17 TOTAL: 151.945 40.520 444
, NOTE *1 - 100% reinspected: those not included had no reinspectable items.
NOTE *2 - Reinspection data still being analyzed.
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- 2. C. Manhour Expenditure
- Reinspections began 03-14-83.
Thru 09-27-83 27 weeks. of reinspection have been conducted with the
- accumulation of 1166 inspector weeks _ expended.
With the need to erect scaffolding, remove paint, fireproofing.
insulation and the like over _3050 man weeks of craft support.
We have been functioning on nominally 58 hour6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> weeks.
Thru 09-27-83 we have expent over 240.155 manhours. = > 7 "'" *"* l i
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INSPECTOR RESULTS (Preliminary)
Inspect.*.on Status of Tvoo Reinspection Condition complete All 5 inspectors who perforned !
Blount objective objective inspections, acceptabic at end of first 3 month period.
Subjective Complete All 4 1re p tors who performed sdjective inspections, accretable ct end of fir:t 3 month period.
JCI objective Complete. 4 inspectors who performed objectite inspect $ons, acesptable
. at sixi of first 3 month period.
1 inspector who performed objective inspections did not have minista qua.ntity in first 3 month priod, nor in second 3 month period, not in total of inspections, all cf 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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Inspection Status of Type Reinspection conditign Hunter Objective Complete 17 inspectors who performed objective inspections, acceptable at end of first 3 month period.
1 inspector who performed-objective inspections did not have minimum quantity ir6 first 3 month period, not in second 3 month period, nor in total of inspections, all of his work was reinspected.
Subjecttve Complete 15 , inspectors who peeformed subjective inspections, acceptable at end of first 3 month period.
1 inspector who performed subjective inspections did not have minimmi quantity in first 3 month period. nor in second 3 month period, nor in total of inspections, all of his work was reinspected.
(
N!Sco objective Complete All 4 inspectors who performed objective inspections, accepttble at end of first 3 month period.
Subjective In progress 2 inspectors who performed subjective inspections, acceptable at end of first 3 month period. ,
1 inspector who performed subjective inspections have not had independent 3rd party review
'I completed.
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Inspection Status Of .
I Type Reinspection Condition
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HECO Objective In Progress 11 inspectors who performed objective inspections, acceptable at end of first 3 month period.
2 inspectors who performed objective inspections have not 1 yet had their first 3 month period inspections completed. ;
subjective In Progress 3 inspectors who performed subjective inspections, '
acceptable at end of first 3 month period. ,
I 4 inspectors who performed subjective inspections have not had independent 3rd party review completed.
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Inspection Status Of Tvoe Reinspection Condition PAP Objective Complete 5 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 total of inspections, all of his wek was reinspected.
8 inspectors who performed objective inspections, acceptable at end of second 3 month period.
4 inspectors who performed do f#f, Wf"fe gp (bN objective unacceptable at end o6 second 3 1.'spections de /o =onth period, all of their work was reinspected.
Subjective Complete 1 inspector who performed subjective inspections, acceptable at end of first 3 months.
4 inspectors who performed subjective inspections did not j have minimum quantity in first 3 month period, nor in second three month period, not in total of inspections, all of their work was reinspected.
1 inspector who performed subjective inspections, acceptable at end of second 3 month period.
13 inspectors who performed l
subjective inspections unacceptable at end of second 3 month period, all of their work l was reinspected. l 4
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Inspection Status of Tvoe Reinspection Condition Ii PTL Objective Complete 8 inspectors who performed objective inspections, acceptable at end of first 3 month period.
1 inspector so. performed objective inspections, acceptable at end of second 3 month period.
Subjective In Progress 5 inspectors who performed subjective inspections.
acceptable at end of first 3 month period.
5 inspectors who performed subjective inspections have not had independent 3rd party review completed.
Peabody Objective Complete None of the inspection population had any objective inspections which were accessible.
Subjective Completed 6 inspectors who performed subjective inspections did not have minimum quantity 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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- . SEPTEMBER 22, 1983 PAGE 1 0F 3 k
REINSPECTION OF OC INSPECTOR WORK ENGINEERING EVALUATION OF WELD DISCREPANCIES SCOPE PTL - 50 WELDS WITH MOST DISCREPANCIES HEC 0 - 50 WELDS WITH MOST DISCREPANCIES WELD ACCEPTANCE CRITERIA PROJECT WORK SPECIFICATION REQUIRES AWS Dl.1 STRUCTURAL WELDING CODE FOR VISUAL , WELD INSPECTION.
AWS WELD OUALITY
\
CATEGORY A ARC STRIKE CONVEXITY SPATTER CATEGORY B CRATER INCOMPLETE FUSION OVERLAP POROSITY UNDERCUT 4 UNDERRUN ,
CATEGORY C CRACKS I
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SEPTEMBER 22. 1983 PAGE 2 0F 3
(_
ENGINEERING EVALUATION OF WELD DISCREPANCIES ENGINEERING DISPOSITION OF WELD OVALITY DISCREPANCIES CATEGORY A WELD DISCREPANCY IS STRUCTIRALLY ACCEPTABLE.
WELD DISCREPANCY RESULTS IN REDUCING THE
. CATEGORY B WELD LENGTH TO PERFORM A STRENGTH CALCULATION, B1 WELD STRENGTH PROPERTIES RSilCED LESS THAN 10%
B2 WELD STRENGTH PROPERTIES RSUCED GREATER THAN 10%
CATEGORY C WELD DISCREPANCY RESULTS IN WELD REJECTION.
e 9
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SEPTEMBER 22, 1983 ?
( PAGE 3 0F 3 {
ENGINEERING EVALUATION OF WELD DISCREPANCIES i
RESULTS CONTRACTOR WELD CUALITY CATIG0RY
'A B1 B2 C T PTL , 13 6 31 -
HEC 0 1 12 37 -
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TOTAL 14 18 68 -
}
m FACTOR ALLOWABLE STRESS~ > 1.0 '
0F ACTUAL STRESS SAFETY FSAR COMMITMENT HAS ROI BEEN COMPROMISED. .
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810t0N SITE QA SURVEII. LANCE AWIT_CLO6E OUT QF: 2790.22.1 Report No. j))71 AUDIT Wo.-6-83-124 Date 10/21/83 Contractor / Organization: Hatfield Electric Co.
. FIM)ING #2:
10CFR50-B, criterion X, states in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organizatien 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.
DISCV5SION:
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:
ty.
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 . V"#/. - Date N 'S'h1 Approved by .M uAm Date / ps/JJ PrMitj:12745 V cc: W.J. Showski/J.S. Sitel Q.A. Supt./ File Contractor Q.A.AuditStaffDesq[
PCD Supt. [gT, A) . P p. I W Q? Projoct Manager PTM 3.t.
Page 2 Surveillance Report 5274 HECo.
I 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 b^ Date //!>dl F/U Action Approved b Date #MP7 Q.A.Supervingt PTM:tj:jc:1274S cc: W.J. Showski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.
PCD supt.
Project Manager PTM e
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Page 3 Surveillance Report 5274 HECa.
FOL1,0W-UP ACTION:
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 FOLIM -UP: tt-30-83 F/U Action Verified MN 1 l
- Date ////t,/42 F/U Action Approved h i- - DateadallP4 l
'Q.A.Superygt PTM:tj:1274S
. cc: W.J. Showski/G.F. Marcus 1 0.A. Supt./ File Contractor Q A. Audit Staff Desq. <
PCD Supt.
Project Manager C,s PTM l
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. *Page 4 surveillance Report 5274 ,
HEco. j v FOLLOW-UP ACTION:
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.
DATE OF WF.XT FOLLOW-UP: /2-4 JJ .
F/U Action Verified YI+ Date M /.2 3S F/U Actior. Approved hd h __ Datela/(,e#3
'Q.A. Supec91sor PU:tj:1274S cc W.J. Showski/G.F. Marcus Q.A. Supt./ File
- contractor '
Q.A. Audit Staff Desq.
PCD Supt.
(y Project Manager ,
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. *Page 5 Surveillance Report 5274 HEco.
FOLLOW-UP ACTION:
12/16/83 - To date, twenty (20) hangers have been inspected out of sixty-five (65) hangers. The total welds inspected are 842. of these,197 are rejected which is 23.4% reject rate. These to
- _ are for combination hangers only.
FOLLOW-UP ACTION DATE: 1*L-4 o-* 3 F/U Action Verified N A m b Date M/4/NJ F/U Action Approved /d utwo Date1.2/%/fS
Q.A.SupeGisor l PTM:tj:jc:1274S
, cc: W.J. Showski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Deig.
PCD Supt.
, Project Manager k?)
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h"h FOLLOW.UP ACTION:
12 30 83 To date, thirty.two (32) hangers have been inspected out of sixty.five (65) hangers. Individual weld inspection totals were not available at this time.
l FOLLOW.UP ACTION DaTE: /= / 5-J V F/U Action Verified I/#4 Date //.7/M F/V Action Approved A.f aJ(e> Date 1/6//4
(.A.Superviijr PTM:tj :j c:12745 i
cc: W.J. Shewski/G.F. Marcus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg. 7 PCD Supt. ,
Project Manager PTM ,
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Page 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 w lds !
inspected with 384 of these welds rejected by S&L. This represents a 22.9%
reject rate. This work item is 58% coeplete w%h an empsctd ccepletien dita of 2/4/84.
DATE OF NEXT FOLLOW-UP: 2*34#
i F/U Action Verified % Date /"/4 - &#
F/U Action Approved [ .o VJf%e Date_l//1//4 ,
l 2.A.Superv2)r PIM:tj:jc:1274S cc: W.J. Shcwski/G.F. Marcus Q.A. Supt./ File '
Contractor Q.A. Audit Staff Desg.
{. PCD Supt. i Project Manager PTM i
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. Page 8
.' Surveillance Report 5274 HEco.
(b.
FOLLOW-UP 4CTION:
2/6/84 - No change in work progress due to change in priorities.
Reinspection efforts were concentrated on the WRC Reinspection IEE Reports No.
50-454/82-05 and 50-455/82-04. The reinspeG ion has restarted today 2/6/84.
4 NEXT FOLLOW-UP DATE: F.2 - 8 d/
1 --.. .....................
F/U Action Verified $2 Date J J '/
F/U Action Approved ~
(U 1b Date 4 /se,[#4 Q.A.Superv@r ,
PTMitj:jc: 1274S ;
! cc: W.J. Showski/G.F. Marcus l I
Q.A, Supt./ File Contractor Q.A. Audit Staff Desg. ,
PCD Supt. .
I
( ~. f Project Manager PTM i
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. Page 9
- Surveillance Report 5274 HEco.
~
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 wil? 's completed by 3-30-84.
A
- Id 4 '
NEXT FOLLOW-UP DATE:
F/U Action Verified ')h a k=. . Date 1 -t t # f-F/U Action Approved _ b k
- . Date 3 "
- J 'i
Q.F. Supervisor 1
Pm:tj je:12745 ,
ec: W.J. Showski/G.F. Marcus Q.A. Supt./Filw Contractor ,
! Q.A. Audit Staff Desq.
ECD Supt.
Froject Manager
. PTM 4
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Page 10 ',
- Surve111anca R: port 52N -
l
. HEco.
TOL.1M-VP ACTICW:
4-06 Hatfield Electric Company, on March 31. 1984. completed the I combination hanger weld inspections for which no inspection record existed. T Thor,e inspections were done for those combination hangers for which no correlation of weld traveler inspection data to design drawing combination hanger data existed.
Inspection records for combination hanger welds are up to date and satisfactorily reflects the current status of work. The deficiencies
- identified durins these inspections are in process of being corrected using the contractors normal rework practices. This inspection effort encompassed a 100% review of all combinatiot. hangers. This rework amounts to approximately 14% of the total welds inspected and in the auditors judgement is indicative of first time inspection.
Therefore, with the combination henger weld inspections current and inspection reports existing in the contractor's records system. the corrective action required for this audit ites is considered complete.
This audit ites is considered acceptable and closed.
This surveillar,ce is closed.
F/U Action Verified %!
Date #d,h +
F/U Action Approved hay Date 4 s a -6 4-i Q.A. Supervisor PTM:jc:12"l4S
]
cc: W.J. Showski/G.F. Marcus Q.A. Supt./ File , ,
Contractor '
0.A. Audit Staff Desg.
PCD Supt.
l Project Manager l PTM l
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W BYRON SITE QA SURVEILLANCE l
AUDIT CLOSE OUT QF: 2790.22.1 l Report No. 1211 AUDIT No.j6-83 124 Date 10/21/83 l contractor /Organizationt Hatfield Electric Co.
FD0DG #1:
10CFR50 Appendix 8. 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 testa 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...."
4 10CFR50 Appendix 5. 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:
1 - The weld traveler cards used by Hatfield for weld inspection 'in many cases, do not adequately identify the iten inspected. The probles stems fro,a 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.
After this J1d analysis the inspection status for a given hanger can be determined. In some cases, even field verification fails to adequately assure the completeness of inspection and a reinspection is necessary.
Corrective Action:
i A correlation of weld traveler inspection data to design drawing cable pan I,
hanger data will be established using computer database management techniques ,
to demonstrate accountability of inspection. This demonstration of 1 accountability of inspection identifies the welder (s) and inspector (s) who worked on the, component, i
For those cceponents which no correlation exists between component and i inspection data, an inspection will be initiated. I j
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t l (1275S) l 1
l
Page 2 surveillance Report No. 5275 HECo.
h The acceptability of existing inspection records will be demonstrated by the adequacy of the inspection data created by those components for which r4 correlation existed. If this<.iata is insufficient in size or inconclusive, additional components will be added to the sample.
ACTION TO PREVDff RECURRENCE: ,
New cross reference will eliminate this type of problem.
POLLOW-UP ACTION:
The component coreelation has been completed and 599 ecaponents have been identified as requiring inspection. Preparations for reinspection are inprocess.
. DATE OF WEXT FOLLOW UP : 11/2/83 .
l Prepared by N b_ Date /o/JfM7 Approved by . nba Date s
. PTM:tj: 12755 a
v - .
i cc: W.J. Showski/J.S. Bitel
- Q.A. Supt./ File l Contractor Q.A. Audit Staff Desg.
PCD Supt.
Project Manager PTM [
l 4
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Page 3 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
- 15 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 N8hc Date [
F/U Action Approved .[ h . Date ///4/73
' ~ '
Q.A.Supervpr PTMitj:je: 1275S cc: W.J. Showski/G.F. Marcus Q.A. Supt./ File s Contractor Q.A. Audit Staff Desg.
PCD Supt.
Project Manager PTM
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Page 4 Surveillance Repott No. 5275 HECo.
b FOLLCW-UP 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 combination hangers.
DATE OF NEXT FOLLOW-Up: ( t.30 - S 3 F/U Action Verified _ d @ Date ////4[#3_
F/U Action Approved d O . b = Date tilan M Q.A.Superqor PTM:tj: 1275S cc: W.J. Shewski/G.F. Marcus l 3' , Q.A. Supt./ File l Contractor Q.A. Audit Staff Desg.
OCD Supt.
Project Manager PTM l
, . 4
' l
Nage5 -
l t'-veillance Report No. 5275 HIco.
O FOLLOW-UP ACTION:
12/2/83 - To date. 373 hangers have been inspected out of 677 hangers.
The total welds inspected are 4016. Of these. 189 are rejected which is 20. M reject rate. The totals presented do not include combination hangers.
DATE OF NEXT FOLLOW-UP: /2-/6-P3 F/U Action verified Date A#/./I'7 F/U Action Approved N.
- 4e Date14/6Mt d.A. Supervjfor Pm:tj: 1275S i
cc: W.J. Showski/G.F. Marcus i Q.A. Supt./ File I
Contractor Q.A. Audit Staff Desg.
- PCD Supt.
Project Manager PTM i
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Page 6 s Surveillance Report No. 5275 KECo. I
'. i FOLLOW-UP ACTIO4:
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 comovals. The total welds inspected are 5338. Or these 1036 are rejected which is 19.4% reject rate. The totals presented do not include combination hangers.
LOLLOW-UP ACTICW DATE:
1'-%o # 3 1
F/U Action Verifi N Date n - t c. 4 ')
! F/U Action Approved fdkm R -
Date U bc/P
- 3 Q.A.Supervis63 i PTM:tj:je: 1275S
~
cc: W.J. Showski/G.F. !*. arcus
] 'n Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.
PCD supt.
Project Manager PTM J
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'Page 7 s .'
Surveillance Report No. 5215 HECo.
F0ll0W-UP ACTION:
12-30 83 150 weld traveler supplements are remaining to be completed.
To date a total of $358 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., 121 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 l
' in total rejects. A recount to verify status numbers is currently in progress.
FOLLOW-UP ACTION DATE: /- /1-4 +'
...................................................................... e A
F/U Action Verified, N d I._ Oate //ev/t 4 F/U Action Approved A uw, Date f/o ' '
44
'Q. A. Supe {kisor PTM:tj :jc:12155 cc: W.J. Shewski/G.F. Marcus .
i Q.A. Supt./ File i Contractor j
Q.A. Audit Staff Desg.
, PCD Supt.
'~
Project Manager PTM i
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Page 8 Surveillance Report No. 5275 HECo.
b
-- FOLLOW-UP ACTION:
1-13 To date. 416 weld traveler supplements out of a total of 512 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.
4 FOLLOW-UP ACTION DATE: 2 7 fr# ;
F/U Action Verified , Y*- Date A //, -##
! F/U Action Approved, d u6v_. Date s/d4
'Q.A. Supervasor PTM:tj:je:1275S
< cc: W.J. Showski/G.F. Mercus Q.A. Supt./ File Contractor Q.A. Audit Staff Desg.
PCD Supt. !
Project Manager
(.., , PTM- l 1
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' ' ' Page 10 -
Surveillance Report No. 5275 HEC : .
b - FQLLOW-Vp 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. l NEXT FOLt.0W-UP DATE: J*k O F/U Action Verified -
1M Date 1-f L O F/U Action Ahroved NI6 Date 5 /7 y
- Q A. Supervisor ,
Pm:tj:je:1275S cc: W.J. Showski/G.F. Marcus Q.A. Supt./ File contractor Q.A. Audit Staff Desq. t PCD supt.
] Project Manager
- . PTM i
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FOL1,0W-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 13% of the total welds inspected and in the auditors judgement is indicative of first time inspection.
Therefore, with the cable pan hanger weld inspections current and inspection reports existing in the contractor's records system. the corrective action required for this audit ites is considered complete.
This audit iten is considered acceptable and closed.
This surveillance is closed.
F/U Action Verified N , Date WI./S 9' C. ,
< F/U Action Approved b M w Date f-if e .
j Q.A. Supervisor PrM:tj:jc: 1275S cc W.J. Showski/G.F. Marcus l Q.A. Supt./ File contractor t 0.A. Audit Staff Desg.
PCD Supt.
Project Manager PTM i l .
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- 6 -
/ .
/. * * ( ,
.s BYRON SITE QA SURVEILLANCE AUDIT CLOSE OUT 4F: 2790.22.1 Report No. 5276 AUDIT No.!6-83-124 Date 1D/21/83i Contractor / Organization: Hatfield Electric Co.
OBSERVATION #1:
Contrary to Hatfield Electric Co.. Procedure 9A Revision 11. Class I Cable 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 435H whose dimensions are different from those of a 15H2.
CORRECTIVE ACTION:
Hanger 15H2 on Drawing 6E-0-3033 Rev. H is going to ba r::in::pacted and an addition sample of ten (10). hangers whose hanger type has changed w111 be reinspected to determine the extent of this problem.
ACTION TO PREVENT RECURRE.CE:
No. applicable isolated case. ,
L FOLLOW-UP ACTION:
l All ten (10) hangers reviewed were randomly selected and were checked i dimensionally against current design documents. Attachment "A" lists hangers inspected. Hanger 15H2 on Drawing 6E-0-3-33 Rev. H was reinspected and f
, accepted to the correct drawing.
! This item is considered closed.
] ......................................................._ ...........
I Prepared by MN3bu Date /0 #!#.7 Approved by . 1w Date /
l PM:tj:1271S '
Attachment cc: W.J. Shewski/J.S. Bitel
, v0.A. Supt./ File contractor
, Q.A. Audit Staff Desg.
PCD Supt.
Project Manager 1
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MDDEANDON FOR: 9. S. Eisenhet, Mrector, Meisism of Licenstag, WER 1
.I FRON: R. L. ,Spessard, Mrector, Messima of hgimaaring, Ritt i
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i SURJECT: PROPOSED SIAMBARD TBCENICAL SPECIFICATI0W POR FIRE ,
{ PROTECTICW . ;
l As a resalt of our taspecties activities ta the fire protectima area out j inspectors balieve that seither existing mer proposed Standard Tochated '
i 5pecifications adequately a(dress fire protecties system testing to assure l operability. We have had many disenssions with yewr staff and appreciate i
l the effort they are arpending ta this area. Memoranda en this subject l 1 from me to yev dated February 18, April 13, and April 13, 1983, resulted l' la TIA's 83-19, 83-42, and 83-19e, respectively. Es addities a ammorandum i i frea Morelius(RIII) to Jordan (12) regarding fire deers resulted ta TIA
! 83-02. ;
I In order to help resolve some of the tasuas our taspectors have draf ted a l j
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( proposed set of Techical Specifications for your semaideration. These, along with thair caver manerandummare attached. We osalise that our pro-j pesal includes asch more detail than is seus11y feed la Technical !
t specifications, bewever, we helts,e it is moeded to aseure proper sur-l vammace testing and thereby assure operability of fire protectima systems.
I We believe that addittenal detail is needed because asey of the e' 01Scable
- fire protecties codes do not clearly address teettag requiremsat , and j even if the licensee has committed to a code auch as NFFA-20 for fire pumps,
- the eede's ambiguity makaa it dif ficalt to interpret. To obtata prepar
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testing of eystems each as the fire ogpressima watt 7 stem se believe it i is best to eencisely state the regattamente in sea e and that ta what J we have attempted to da in the psa:::' Techniaal Specifications, i
1 We would be happy to discuss this further with your staff if we aan he of r
} any farther help. Centact an er Mr. Little of eqy staf f (FTA 384-1578) if J you have any questless.
"ortstral tir..d t? R. l.. Spesurf
.R. L. spessard, Director
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