IR 05000358/1982010
| ML20214E823 | |
| Person / Time | |
|---|---|
| Site: | Zimmer, Braidwood  |
| Issue date: | 06/24/1986 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| References | |
| OL-A-049, OL-A-49, NUDOCS 8705220268 | |
| Preceding documents: |
|
| Download: ML20214E823 (26) | |
Text
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UNITED STATES o
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NUCLEAR REGULATORY COMMISSION
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RECEIVED
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Docket No. 50-358 00UhENT RQQH emummmusum Cincinnati Gas and Electric Company
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ATTN: Mr. Earl A. Borgmann Senior Vice President
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Elactric Production
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139 East Ath Street
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gm Gentlemen:
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This refers to the routine safety inspection conducted by Messrs. 2:
U V. F. Christianson, T. P. Gwynn, K. D. Ward, D. E. Keating, and J. F. SchYpker
of this office on June 7 through August 18, 1982, of activities at Vm. H. Zimmer *
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Nu' clear Power Station authorized by NRC Construction Fermit No. CPPF-88 and to i
the discussion of our findings with Mr. J. R. Schott and others at the
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conclusion of the inspection. The inspection findings were discussed with you by telephone on March 15, 1983.
The enclosed copy of our inspection report identifies areas examined during i
the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-tarviews with persennel.
During this inspection, certain of ycur activities appeared to be in ::en-cc=pliance with N'RC requirements, as specified in the enclosed Appendix.
A written response is required.
- The findings associated with maintenance of active welder qualifications i
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indicated a breakdown in your established manager.ent controls in this area.
i This breakdevn was emphasized by the inappropriate renewal of a welder qual-ification card by a responsible staff member and the failure to take adequate i
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corrective actio s even after significant conditions adverse to quality had been identified within the established corrective action system. Furthermore, tha inspection revealed that quality assurance records had been altered and
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supplemented without adequate management controls established. This finding is similar to an item of noncompliance, identified in Investigation Report No. 50-358/81-13, for which CG~zE paid a civil penalty. These findings are indicative of a continuing lack of full, understanding of quality assurance
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requirements.
Additionally, the failure to adequately control weld filler metal in the test shop, to adequately review and control Requests for Information and Evaluation
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(RFI/E) made in good faith by quality personnel, and to fully impose reporting requirements on contractors further emphasize the need for proept management
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attention to the overall quality assurance program at Zimmer.
These findings are considered to be significant and are included in the
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problems documented in Section II.B of the Commission's November 12, 1982 Order to Show Cause and Order Immediately Suspending Construction. The findings
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resulted, at least in part, in the Commission issuing that Order; therefore, a
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civil penalty is not being imposed for the Severity Level III violation.
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In addition to the requirements of the Appendix, please review each finding in detail, review any previous similar findings, and provide assurance that cor-rective actions taken (or proposed) are adequate to remedy the root or generic cause of the problems.
In accordance with 10 CTR 2.790(a), a copy of this letter and the enclosure (s)
will be placed in the SRC Public Document Room unless you netify this office, by telephene, within ten days of the date of this letter and submit written applicatien to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1).
If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s),
and your response to this letter will be placed in the Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not
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subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, FL 96-511.
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, Cincinnati Gas and Electric
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Company
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We will gladly discuss any questions you have concerning this inspection.
- Sincerely, Orl;!.111 "c'cned h*/
Jar:: ;...:.;;st James G. Keppler
,
, Regional Administrator G
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report
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No. 50-358/82-10(OSC)
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REGION III==
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Report No. 50-358/82-10(OSC)
Docket No. 50-358
License No. CPPR-88
Licensee: Cincinnati Gas and Electric Company
139 East 4th Street
N
Cincinnati, CH 43201
Facility Name:
Va. H. Zimmer Nuclear' Power Station
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Inspection At:
Wm. H. Zimmer Site, Moscow, OH
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Inspection Conducted: June 7 through August 18, 1982
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W. F. Christianso +n
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Inspectors:
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Dated
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T. P. Gwynn
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F. Schapker
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K. D. Ward
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7kD.E.Keating
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Dated
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Approved By:
D.
. H6t'er, G
Section 1, Zimmer
Dated
Inspection Summary
Inseection during the eeriod of June 7 through Autust 18, 1982 (Recort
No. 50-358/82-10(OSC))
Areas Inspected:
Routine inspection by resident and regional personnel of
previously identified items, the processing of H. J. Kaiser requests for
information, fuel receipt and storage, the Quality Confirmation Program,
review of welder qualification, site activities of interest, plant tours,
construction deficiency reports, preservice inspection program, and
structural steel expansion bolting. This inspection involved a total of
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9304070332 930325
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PCR ADCCk 030003SR
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DETAILS I'
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Prepared By:
W. F. Christianson
T. P. Gwynn
J. F. Schapker
Reviewed By:
D. R. Hunter, Chief
Section 1, Zimmer
1.
Personnel Contacted
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cincinnati Gas and Electric company
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E. A. Borgaann, Sr. Vice President
+B. R. Sylvia, Vice President for Nuclear Operations
- +H. R. Sager, Manager, Quality Assurance Department
- +B. K. Culver, Manager, Generation Construction Department
- J. R. Schott, Manager, Nuclear Production Department.
+D. J. Schulte, Director, Quality Engineering
+J. F. Shaffer, Director, Quality Confirmation
'+G. Padula, Quality Confirmation Prograa
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'M. Rhodes, Quality Confirmation Prograa
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'+J. Louden, Quality Engineering
G. Orlov, Quality Engineering
+D. Spence, Director, Quality Documentation
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F. Pfeifer, Quality Engineering
R. Vannier, Quality Engineering
a'
Henry J. Kaiser comoany
- +M. Albertin, Construction Project Manager
- +W. Hed:ik, Manager, Quality Assurance
C. Stanfield, Construction Manager
- +M. Goedecke, Welding Engineering Manager
'+M. Butterworth, Weld Engineer
- +G. Fones, Quality Records Manager
+J. Flaherty Weld Engineer
'N
Vitale, Quality Engineering Manager
W. Wagner, Welding Task Force Chairman
C. Person, Lead Document Reviewer, Welder Qualifications
R. Davis, Quality Control Manager
National Board of 3 oiler and Pressure Vessel Inspectors (NBBI)
4. Allison, Field Representative, SSSI
+M. Sullivan, NBBI Consultant
R. Holt, N33I Consultant
Hartford Steam Boiler / Authorized Nuclear Inspector
A. Clark, ANI Supervisor
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L. Burton, ANI
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S0003S08
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This is in noncompliance with 10 CFR 50, Appendix' B,
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Critetion IX and the Vm. H. Zimmer QA Manual, Paragraph 9.3,
which states in part that the CG&E QA Division audits HJK to
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assure that personnel performing special processes are
qualified in accordance with applicable codes.
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(358/82-10-01(A)).
b.
(Closed) Unresolved item (358/82-05-02):
H. J. Kaiser had no
documentation of the results of evaluations for reportability
under 10 CFR 21 and 10 CFR 50.55(e).
CG&E Corrective Action Request No. 82-36 was written to identify
and control this problem. As a result, H. J. Kaiser Procedure GQP-21,
Revision 0, " Reporting cf 10 CFR 21 or 10 CFR 50.55(e) Conditions"
was prepared and approved. Subsequently, Revision 1 to GQP-21
provides the necessary administrative controls to provide assurance
that identification, control, and documentation of reportable or
potentially reportable conditions is achieved and maintained.
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The failure of CG&E to impose the reporting requirements of
10 CFR 21 and 10 CFR 50.55(e) on its contractors is in noncompli-
ance with 10 CFR 50, Appendix B, Criterion V, 10 CFR 21.21(a),
and the Wm. H. Zimmer QA Manual Paragraph 5.1, which states ia
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part that activities which affect the quality of the facility are
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accomplished in accordance with written instructions, procedures,
or drawings which prescribe acceptable methods of carrying out
those activities.
(358/82-10-02(A))
3.
Follevup on Processing of H. J. Kaiser Raouests for Information
On July 20, 1982, a H. J. Kaiser employee brought to the attention of
the NRC a potential problem related to the processing of H. J. Kaiser
Request
for Information/ Evaluation (RFI/E) forms. In accordance with
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H. J. Kaiser Procedure GQP-9, Revision 0, dated January 27, 1982, Para-
graph 4.1.3, RFI/E's which were forwarded to the Welding Task Force
were required to be processed as follows:
"The Velding Task Force Chairman will log receipt of the RFI/E by
number and date and present the RFI/E to the welding task force
membership for response."
The inspector was presented an information copy of an RFI/E initiated
April 13,1982, requesting evaluation of a quality-related condition.
RFI/E was issued and responded to by the Valding Task Force (WTF) Chairman;
This
however, the RFI/E did not have a tracking log identifier as required by
GQP-9.
Discussion with the H. J. Kaiser quality Engineering Manager and the
H. J. Kaiser WTF Chairman revealed that the WTF Chairman did not fully
understand the procedural controls of the RFI/E procedure or the scope
of the RFI/E procedure.
The WTF Chairman indicated that his under-
standing of the RFI/E was that the RFI/E was to be used for clarification
of procedures, codes, and standards only; and he was not required to log
RFI/E's which did not represent requests for clarification.
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No. Initial Issue
Received and Reviewed
No. Dispositioned
QCP Task
and Reviewed
I
1302
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II
108
793
III
341
IV
100
Y
5
VI
311
I
VII
149
IX
290
b.
Additional Areas of Interest
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In addition to the above tasks, there have been nonconformance
reports generated by the H. J. Kaiser document review group in the
following categories which are being followed by the inspector:
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CATEGORY
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NO. OF KRS RECEIVED
Supplier
related
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Electrical Equipment Installation
196
Cadwelding
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Concrete
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Hydrostatic Testing
Leak Chase Welding
Sacrificial Shield Wall Welding
Inspection Stamp Control
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The inspectors will continue to monitor the efforts of the
H. J. Kaiser document review group and will follow the resolution
of these additional areas of interest.
Quality Confirmation Program Status
c.
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The Ifeensee reported the following status of the quality
confirmation program effective June 30, 1982.
(1) Task I: Structural Steel
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Items
. Items
% Comp 1.
Manhours
Comp 1. this
Comp 1. to
this
% Comp 1.
Expended
Manhours
Area
Month
Date
_ Month
to Date
this Month
_
Foot Cen'-
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,
nections
259
100
0
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Drywell
(less 525')
236
72
317
651
,
Reactor, Aux
Bldgs
452
782
22
2,757
17,593
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ihis task approximately 31* complete.
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(f) Estimated Completion Date
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December 1, 1982
(2) Task'II: Veld Quality
Items
Items
- Comp 1.
Manhours
Comp 1. this
Comp 1 to
this
- Comp 1.
Expended
Manhours
,
Area'
Month
Date
Month
to Date
this Month
Remainine
Struc-
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tural KE-1
Review
11,000
98
160
,
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Welding
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Procedure
Reviews-
76
92
40
,
Welder *
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Qual.
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Review
527
1,303
29
102
1,798
, ' -
Small
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Pipe
368
.
25,841
79
128
824
Large
0*
0
4,118
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- Items previously listed as complete for large bore are to be
redone under new program.
(a) Assessment /Results
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I.
92* of the inactive welding procedures have undergone
preliminary review. Approximately 5 procedures may
need to be requalified on the basis of this review.
(Amperage range exceeded, interpass temperature not
specified, rate of travel not recorded, etc.)
II.
Review of welder qualification has begun. A group of
HJK and COSE experts are working jointly to expedite
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the review (9 people). There are approximately 1800
welders (approx. 4600 records) to review. 341 NRs
have been initiated, of which 11 have been dispositioned
(7 accept-as-is, 4 rework). 1323 welder qualification
forms (for 541 welders) have been reviewed to date.
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S0004001
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- Purchase Order Review:
6,792 Purchase Orders were initially
reviewed to determine their status (essential or nonessential).
Of these approximately 4,700 were determined essential.
The
numbers given for this report are from the statistical status
plan which is in progress at this time.
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- The reasons for the change in status of the Seall Bore Piping
are as follows:
The original procedure used for the review was not
and used assumptions; our review was performed prior to the HJKin depth eno
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review during which they were, by procedure, able to salve many
NRs; and a method to tie the purchase order heat number to the
documentation and field heat number had not been satisfactorily
established.
deficiencies. A new procedure has been submitted to rectify these
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- Hours expended for information walkdown.
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(a) Summary of Scope
(IIIA)
Small Bore Piping - Perform 100% inspection
(Documentation and Field) of systems identified
on Encidsure 1 and 2 of NRC investigation Report
No. 50-358/81-13
Exhibit 17. for traceability in
accordance with ASME requirements.
(IIIB)
Large Bore Piping - Perform 100% inspection
(Documentation and Field) of all piping involved
in field modifications within the scope of
Enclosure 1 and 2 (see IIIA above) for trace-
ability in accordance with ASME requirements.
(IIIC)
Purchase Order Review - Per' form 100% review of
Purchase Orders to establish a list of acceptable
heat numbers to confirm source traceability of all
code related items within the scope of IIIA and IIIB.
(b) Assessment /Results
(IIIA)
Small Bore Piping - Field Walkdown is 98% complete.
Document review in accordance with 19-QA-12 is 88%,
however, all packages within the scope will be
re-reviewed in accordance with 19-QA-30. This is
necessary since 19-QA-12 did not address trace-
ability in the depth required to adequately
identify the problems encountered. In addition,
the documents will be reviewed after HJK, to allow
nonconformances to be identified on HJK NRs (They
will be designated as "Q" NRs).
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S0004002
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(a) Assessment /Results
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Records for 29,821 have been reviewed. We are
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re-reviewing those ISK Drawings which were on hold
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pending receipt of additional documentation.
1623
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welds pending direction for closure or additional
review.
II.
565 welds lacked evidence of disengagement and have
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been radiographed.
- III. 106 of the 565 welds appear to lack gement from
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radiograph feview.
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(b) Nonconformance Report Summary
106 Nonconformance Reports have been generated for the
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85 welds lacking proper disengagement. 72 of the 106
NRs have been dispositioned rework.
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(c) Manpower Summary
Position
Number
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Engineers
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Quality Engineers
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Inspectors
Document Reviewer
e
Clerks
TOTAL
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(d) Status
This task is approximately 98* complete.
(e) Estimated Completion Date
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August 1, 1982
(5) Task Vr Radioaraohs
Itama
Items
- Comp 1.
Manhours
Coop 1 this
Comp 1. to
this
. Comp 1.
Expended
Manhours
Area
Month
Date
Month
to Date
this Month
Remainina
Radio-
graphy
Review
100*
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Radio-
graphs
Phase II
- 0
0
0
200
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S0004003
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A.
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- Expanded scope of Task VI.
- Manh'ours required to close inspection forms, this includes
EER's, panel analysis, routing analysis and NR review.
+
- Manhours required for preliminary work packages for this ites.
(a) Assessment /Re=ults
.
I.
A total of 497 Nonconformance Reports have been written
for separation, identification and routing deficiencies.
257 dispositioned )Rs (99 rework,158 accept-as-is).
181'of the 257 dispositioned NRs have been closed.
II.
Task VI expanded to inspect all Class IE Panels with
potential separation problems. Procedure 19-QA-31
being prepared to perform this inspection. Procedure
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sent out for review and comment.
III. Awaiting 11 EER responses to close out associated cable
inspection records. Responses were due June 15, 1982.
IV.
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Awaiting S&L panel lysis to close out associated cable
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inspection records.
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(b) Manpower Summary
Position
Number
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Engineers
Quality Engineers
-
Inspectors
&
Document Reviewers
-
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Clerks
TOTAL
(c) Status
$4% complete (expanded scope)
(d) Estimated Comolecion Date
December 31, 1982 (expanded scope)
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S0004004
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V.
Task VII personnel to interface with the N-5 prograa
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data report program for turnover.
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in additional manhours for this task.This will result
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(b) Nonconformance Report Summary
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38 Nonconformance Reports have been written due to reop
of voided NRs.
Only one has been dispositioned to date
(Accept -as-is ).
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(c) Manpower Summary
Position
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Numb r
Engineers
Quality Engineers
Inspectors
Document Reviewers
Clerks
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TOTAL
2
(d) Status,
This task is approximately 61% complete.
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(e) Estimated Comotetton Date
December 31, 1982
(8) Task VIII:
Desian Control and Verification
(a) _ Steps to close out this task:
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1.
Review 81-13 information
2.
Review S&L response and procedure revisions
3.
Formulate close-out of QCP action items
Review plan and documentation at S&L
5.
Present draft close out report to NRC prior to formal
.
submittal
6.
NRC to complete review of items and complete closecut
(b) Conclusion
.
Their systes has been made more formal.No problems
(c) Maneewer Sammary
Final re
Program. port to be written by Director, Quality Confirmation
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S0004005
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PROBIE.M/ DEFICIENCY
EI.ECT
MECH
STRUCT
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1.
Missing Documentation
8
103
193
,
2.
DDC Mis-Classification
3
14
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3.
Inspection Program
Deficiencies and Misc.
25
57
- DDC Not Incorporated
in Documentation
10
222
316
1-
5.
Inspection Prior to DDC
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Being Written ("As Built") 1
0
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6.
Incomplete Inspe : tion
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Documentation
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TOTAL
196
369
621
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Note:
Reduction of probless/ deficiencies previously
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identified are due to implementation of
MCAR 82-01 and new sources of documentation.
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(b) Manpower Summary
Position
Number
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3'
Engineers
Quality Engineers
v.
Inspectors
Document Reviewers
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Clerks
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Total
(c) Status
.
This task is approximately 34% complete for Subtask I and II.
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(d) Estimated Comotetton Date
December 31, 1982
(10) Task X: Subcontractor QA Proarass
(a) Summary of Concerns
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The Bristol Project Superintendent was responsible
for both the steel erection and the erection quality
control.
The Bristol Field Inspection Program failed to document
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specific welds inspected and details of the inspection.
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Review past audits of subcontractor QA programs.
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S0004006
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(b) Assessment /Results
,
I.
296 audits have been identified, of which 207 have
,
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been reviewed.
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'II.
Preliminary evaluation indicates that most audits
were of limited scope, however collectively due to
,
the large number of audits performed, the applicable
18 criteria were covered for HJK, EOTD, NED, GCD, and
NPD.
<
There were areas not covered in audits of S&I.
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and G.E. subsequent to April 8, 1981, however, current
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audits of S&L and G.E. have covered the majority of
applicable criteria.
.
III. Proce bre for interface with the QCP Tasks to verify
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adequacy of work is being developed. Draft of this
procedure will be complete and ready for review the
week of June 28, 1982.
,
j
IV.
It is estimated that eighty-three (83) aan days will
!
l'
be required for review and evaluation.of the remaining?
audits, and for auditing missed criteria.
.
.
.3
(c) Statn
.i
.
'
,
,;
This task _is 707, complete
>
(d) Estimated Completion Date
+
- ,
October 8, 1982
i
No items of noncompliance or deviations were noted.
,
>
6.
Welder Qualification Review and Verification - OCP Task II
'
The QCP Task II requires in part that the licensee (Cincinnati Gas and
Electric Co.) verify the qualifications of welders qualified prior to
April 8, 1981.
.
.
This task is presently being accomplished by a joint
!
task group comprised of personnel representing CG&E Quality Assurance
i
Department, H. J. Kaiser Quality Assurance Department, and H. J. Kaiser
{
Welding Department.
"
.
'
Due to the relatively large number of nonconformance and corrective
action reports being generated by this task group, the NRC requested
,
l
that CG&E determine the impact of identified problems on the qualifi-
l
cations of currently active welders and report the results of their
i
'
determination in a meeting held onsite July 9,1982 (attendees at this
.
j
meeting are designated by a (+) in Paragraph 1 of this report section).
-
i
j
In the July 9 aceting, the licensee reported that a meeting had been
,
l-
held on July 8, 1982, in which all concerned parties (CG&E and HJK QA
!'
!
and Construction) had agreed to the resolution of a number of generic
issues which could affect a large number of active welders.
I
The
resolution of these generic issues and the suspension of qualifications
.
!
S0004007
-
'
!
i
i
i
- - -. - -. -
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-
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-
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.
.
, *
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,
i(
.
,-
. *(1) No. E-8654 dated June 21, 1982
.*(a) No. E-8657 dated June 22, 1982
- (n) No. E-8724 dated June 24, 1982
-
,
,
- (o) No. E-8719 dated July 6, 1982
,
(5) CG&E Condition Evaluation Request No.82-015 dated April 29, 1982
,
, 6) CG&E Field Audit 'Iteport (FAR) No. 126 dated July 8, 1977
(
(7)
H. J. Kaiser res)onse to FAR No. 126, HJK letter KC-10362-Q
.
dated August 2, 1977
(8)
H. J. Kaiser Memorandue from M. Butterworth to M. Goedecke dated
July 13,1982 (proposed corrective actions for HJK CARS No. 84,
,
85, 117, 123, 132)
.
!
(9)
H. J. Kaiser Inter-office Memorandum from M. Butterworth to M.
.
,
Goedecke as follows:
.
'
Date
Subject
$
(a)
6-30-82
Bend Test Acceptance (CAR 114)
'
I
(b)
7-01-82
Signature Authority (CAR 117)
(c)
7-01-82
Reader Sheets (CAR 84)
.
'
,
_
(d)
7-01-82
Backup Documentation (CAR 85)
- See Paragraph 6.b(8) below.
b.
Discuss ion / Observations
,,
(1) In order to verify the adequacy of licensee actions with regards
to the qualifications of active velders onsite, a random sample
,
!
of 10 welders was chosen from the H. J. Kaiser list of active
l
welders dated July 9, 1982. These welders were then reviewed
with respect to their status in the N. J. Kaiser document review
.
-
welder status summary worksheet including outstanding (open)
nonconformance and corrective action reports. Additional docu-
sentation was requested where necessary to verify or support
corrective action statements.
Preliminary results were subsequently discussed with licensee
_
and contractor personnel for clarification of the open issues.
l
Significant questions remained after these discussions due to
!
inadequate or incomplete answers for five of the welders
i
reviewed, centering around two H. J. Kaiser Corrective Action
l
Reports (No. 84 and No. 114/123).
'
,
i
-
.
S0004MS
.
.
F
-
. _ _ - _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ - _ _ _ _ _. _., _ _. - _ - - - _ _ _ _ _ _
._
_.
.
.
-
_.
.
-
-
.
-.
..
- -.
..
.
-
.
,
b -. '
.
'
's
.
(3)
CG&E = Field Audit Repoct No.126 dated July
,
.
6-8, 1977, made the
'follosing observation with respect to welder qualification
. records:
,
,
"Although proper certification forms are provided in each welder
,
file, there exists no forms for the alternate radiographic method
'
which was utilized for qualifying the welder."
,
" Discussions with Mr. A. Pallon and Mr. K. Bronder
-
after the-radiographs of the welder coupons are acc,eptable, and
revealed that
certifications granted, the radiographic documentation is then
discarded."
,
"Even though code and specifications allow the option of retain-
.
ing or discarding the actual radiographs of welder qualification,
it does not state the documentation of the radiographic tests
reflecting the actual results be discarded."
"Therefore, it is suggested that a copy of the acceptable radio-
graphic report be attached to the welder certification forms."
In their response to this audit report, H. J. Kaiser Letter
,
>
KC-10362-Q stated, " Quality Assurance is presently maintaining
.
copies of interpretation reports for welder qualifications.
addition.. Peabody Magnaflux has a complete file of these reports
In
which will be transferred to CG&E at the completion of the job."
(4)
The inspectors noted that H. J. Kaiser procedures - (SPPM 3.2)
'
required that the H. J. Kaiser certification on the Welder
.
'
Qualification Record Form KE Q-1G be by signature of a
H. J. Kaiser Veld /NDE Quality Assurance Engineer.
H. J. Kaiser CAR No. 117 identified that this procedural
requirement was repeatedly violated in that the EE Q-1G forms
were signed by individuals who could not be verified as QA
Engineers.
Those individuals included H. J. Kaiser Assistant
welding engineers, quality control inspectors, and Project / :
Senior veld engineers.
responsible for the work performance.The weld engineers were those directly
(5)
H. J. Kaiser CAR No. 85 identified that backup documentation
substantiating the welder qualification was missing from several
qualification record packages.
These backup documents included
KE-1 Weld forms and inprocess welder qualification surveillance
i
data sheets.
(6)
H. J. Kaiser CAR No. 114/123 identified that bend test informa-
tion was added to the State of Ohio Q-1G form which conflicted
with information on the KE Q-1G form.
Additionally, H. J. Kaiser
CAR No. 132 identified that several KE Q-1G forms had essential
band test information omitted.
The accompanying State of Ohio
Q-1G forms reflected the conditions stated on CAR No.114
(information had been added).
.
.
.
.
S3004009
.
s
-. - _ _
._
...
.
_ _ _ _ _ _ _, _ _ _. _. - _ _ _ _ _ _ _.. _ _ _ _.. _ _ _ _ _., _ _ _ _ - -
,
.
.
.
..
.
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.
'
, L. i. *.
-
.
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.
..
that the Project Welding Engineer was responsible for the
accur,acy and continual and timely updating of the Walder
'
, Qualification Listing. The inspector requested a copy of this
listing to verify its accuracy with respe't to welder LMF, but
e
was told that the subject listing was no longer controlled or
in use. The inspector further noted that the QAP-10 require-
ments were reflected in WCP-2, Paragraph 3.2.1, which did not
appear to be implemented. The failure of H. J. Kaiser Welding
Engineering to establish and accurately maintain a welder
. qualification listing commensurate with the requirements of
.
QAP-10 is in noncompliance with 10 CFR 50, Appendix B,
Criterion IX, which require in part that special processes,
including welding, be controlled and accomplished by qualified
personnel.
(358/82-10-01(B)).
.
(2) Review of the qualification records for welders symbol KGZ, KUE,
MBF, KGJ, and KFY indicated that there was a lack of objective
evidence that the welders qualification coupon had been radio-
graphically evaluated and found acceptable by a SNT-TC-1A
,,
,
Level II RT qualified individual. In each case, the H. J. Kaiser
document review welder status sheet indicated that CAR No. 84
was open against the individual welder's qualification. Review
of the complete log indicated that CAR No. 84 was open against.
.'
the qualification of approximately 89 welders, some of which had
multiple procedure qualifications with CAR No. 84 outstanding
,
(approximately 250 procedures).
i
)
The proposed corrective action to CAR No. 84 stated, "If there is
not a Level II signature on the welder qualification record and
there is no radiograph reader sheet for that qualification record,
.
based on the certification by the H. J. Kaiser Company these
,
records shall'be acceptable. No procedural requirements indicated
the retention of the reader sheets prior to February 15, 1982,
l
also no Level II signature was required on the welder qualifica-
L
tion record by either procedure or ASME Section IX. All current
and future welder qualification records shall be accompanied by
'
,a radiograph reader sheet with a Level II signature."
,
This proposed corrective action, which was agreed to by "all.
parties",and which was part of the basis for the determination
i
!,
of acceptability of current welders qualifications at the
'
July 9, 1982 meeting with the NRC, was not acceptable to the
inspectors hased on the observation and discussion in
[
Paragraphs 6.b(2), (3), (4), (7), (8), (9) and (10) above.
t
The inspectors stated that there was no apparent reason why the
radiographic reader sheets were not available, in light of the
'
observations of Paragraph 6.b(3) above. The licensee was unable
to provide a satisfactory explanation of the missing documentation.
.
l-
.
,
S0004310
,
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.
.
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,
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.'
.
Specifically, the inspectors questioned the acceptability
. _ -.
.
.,
of the statement in the affadavit, "In the case of welder
qualification records where as the number of bonds was
,
recorded as (1) root and (1) face was in fact, (1) set of
,
test specimens constituting (2) face and (2). root bonds...,"
,
or in other words, one equals two.
The inspectors observed that the individual who provided
the affidavit was not the person responsible for performing
the bend tests' in question, nor was there reasonable assur-
ance that that individual had observed the band tests in
question.
,
Further questioning of H. J. Kaiser document review personnel
-
indicated that attempts to establish a trend in this area
+
!
(i.e., a certain individual (s) had made the correlation 1=2
I-
over a specific time frame) had failed. These observations
left questions concerning the adequacy of corrective action
,
provided for CAR No. 123/132, however, time constraints
'
precluded a determination of compliance / noncompliance in
t
this matter. This item is unresolved pending further
review at a subsequent inspection (358/82-10-04).
.
(4) One welder (symbol KGJ) was listed on the H. J. Kaiser document
review status worksheet as having a current qualification to
,
weld procedure Specification 3.1.21, however, the H. J. Kaiser
E
list of active welders dated July 9, 1982, showed current
qualification to Specification 3.1.21 H (where th's H designates
a heavy wall thickness qualification). Review of the welders
qualification records indicated that the KE Q-1G (record) form
i
and the Ohio Q-1G form indicated the welder had qualified with
'
a 6" schedule 40 (.432 inch thick) coupon. The Ohio Q-1G form
only had subsequently been changed (by line through) to indicate
qualification on a 5" schedule 160 (.750 inch thick) coupon.
The change had not been made in accordance with the requirements
of ANSI N45.2.9-1974, Paragraph 3.2.6.
For clarification, the
,
inspectors requested that the licensee determine (1) if other
I
welders qualified to the same procedure in the same time frame
had performed their qualification on a 5" schedule 160 coupon,
and (2) if the 6" schedule 40 coupons were available in the
test shop at the time the qualification in question took place.
j
The licensee's contractor representative reported that (1) review
,
l
of welders qualifying to Specification 3.1.21 H in the same time
L
frame revealed records that had been altered similar to the
records in question, ar.d that (2) the 6" schedule 40 coupons
were available in the test shop at the time the qualification
in question took place.
- 1
!
The inspectors stated that the objective evidence in this case
indicated that a 6" schedule 40 coupon,was used in the qualifica-
tion, and that the alteration of the documentation outside the
requirements of ANSI N45.2.9-1974 placed the welders qualification
to the heavy wall procedure in doubt.- The evidence of at least
'
!
!
i
S0004011
f
~
____._.__-.__,..______u__._.,_.._.
_.... - -. _. -
.. - _ _ _ -
, -, _,.., _.
_ _,....., _, _.. _ _ _
'
- 4'
.
'
.
(b) As attested to by W. O. Puckett, the foll,owing persons shall
.
.
,be considered as acceptable. At the time of delegation of
.
.
signature authority W. O. Puckett held the position of
,
-
Project Weld Engineer.
x
.
Mark stacy (Assistant Engineer)
Mark Johnson (Assistant Engineer)
Both persons were under direct supervision of W. O. Puckett
at the time of certification."
'The inspectors observed that the person referenced in Para-
graph 6.c(5)a above was the site Weld /NDE QA Engineer, a sworn
statement attesting to his delegation of signature authority
-
(but not responsibility for review of the activities in
question) may be acceptable. However, the inspectors further
observed that the person referenced in Paragraph 6.c(5)b above
was never employed in the position of site Weld /NDE QA Engineer.
In fact, the person referenced in Paragraph 6.c(5)b above was
the person directly responsible for the implementation of site
welding activities and did not posses the independence inherent.
in the position of Weld /NDE QA Engineer. As such, the accept- -
ability of this corrective action statement requires further
,
justification and remains unresolved pending the review and
verification of corrective action by the licensee's QA
'
organization.
(358/82-10-06)
d.
Position Taken
.
As a result of this review of welder qualification records, the
following position was taken by the NRC during a licensee meeting
held July 15,1982 (personnel attending this meeting are designated
with an (*) in Paragraph 1 of this report section):
i
(1) Those KE Q-1G forms that are properly filled out in accordance
with the requirements of the ASME Code,Section IX, and that
i
include objective evidence that a SNT-TC-1A Level II RT
qualified person evaluated the radiographic test results (when
,
l
!
the alternate radiographic qualification method was employed)
-
!
and found them acceptable, are acceptable to the NRC as
objective evidence of satisfactory qualification when the
l
essential variables of the qualification (including the date
l
'of qualification) have not been altered, or when alterations
have been made in accordance with ANSI N45.2.9-1974 requirements.
(2) For those KE Q-1G forms which do not include the signature of
a SKT-TC 1A Level II RT qualified person (when the alternate
radiographic qualification method was employed) showing
evidence of acceptable RT results, an appropriately signed
l-
backup document (i.e., RT reader sheet showing acceptable RT
results) will be acceptable to the NRC as objective evidence
of satisfactory qualification, provided the other essential
items referenced above are met.
.
.
S0004012
-- _.
._
__ _
_ _ _ _ _ _.. _ _ _ _ _
__
., _
..
. _ _ _ _
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,
-
,
.
,,
(5) 9% - Incomplete installation (shiss, nuts, and pins missing)
.
~
'(6) 40% - Miscellaneous defects (alignment, curing, spalling,
- ,
dimensions,etc.)
,
,
.
Welding accounted for 40% of the IIDR's ~ as follows:
(1) 19% - Undercut welds
j
(2) :15% - Undersized welds
f
'l e
(3) 10% - Arc strikes
.
.
(4) 8% - Weld Overlap
(3) 7% - Slag
i
(6) 6% - Lack of fusion
'
,
i.
(7) 5% - Weld ositted
-
(8) 30% - Miscellaneous defects (spatter, profile, contour, convexity)
,
Anchor bolts and base plates marking and identification, and base
,
metal and documentation constituted the remainder of the defects.
I
Review of the IIDRs and system is an ongoing effort.
d.
.U.S. Department of Labor - Vane and Hour Division
The Senior Resident Inspector set with two representatives of the
.
Division of I. abor to discuss the' nature of concerns filed by a HJK
esployee. The employee lodged written concerns with the US NRC,
.
!
GAP and the Wage and Hour Division concerning intimidation. The
}
employee's concerns are part of an ongoing investigation.
!
{_
8.
Plant Tours
!-
The inspectors conducted frequent plant tours throughout the inspection
period. These tours included observation of ongoing construction acti-
,
i
vities, maintenance activities, equipment controls, cleanliness controls,
instrumentation, fire equipment, and security controls.
<
'
During a tour of the weld test shop, the inspector observed that the
i
issuance of weld filler material was not handled in accordance with the
'
site Procedure WCP-3, Revision 0, " Weld Filler Metal Control," dated
l
February 17, 1982.
In particular, the materials were issued by weight,
i
returned by weight, and no stub count was accomplished upon return.
i
The inspector verified that WCP-2 revision 0, " Welding Performance
,
i
Qualification Testing" dated February 15, 1982 Paragraph 4.1.2, required
j
that weld filler metal be " completely accounted f'r and fully traceable
o
!
from the time of aquisitica through use or other disposition
!
(Reference 2.4, WCP-3, Weld Filler Metal Control)."
'
.
S0004313
.
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DETAILS II
.
.
.
'
.
Prepared By:
K.'D. Ward
Reviewed By:
D. H. Danielson, Ch,ief
-
Materials Processes Section
Inspection period August 16, 17 and 18, 1982.
1.
Persons Contacted
.
,
e
Cincinnati Gas and Electric Company (CG&E)
f
- H. Sager, QA Manager
- R. Taylor, Quality Engineer
- J. Vannier, NDE Level III (S&L)
- W. Gibbons, Engineering Consultants (Reedy, Herbert, Gibbons, and
,
Associates) (RHG&A)
- P. Herbert, Engineering Consultant (RNG&A)
,
C. Allison, Field Representative (National Board)
-
M. Sullivan, Consultant (National Board)
>
R. Holt, Consultant (National Board)
D. Schulte, QA Engineering Director
The inspector also contacted and interviewed other licensee and contractor
technical and administrative employees.
- Denotes those attending the exit interview on August 18, 1932.
2.
Licensee Action on Previously Inspected Findinas
.
(Closed) Open Ites (358/76-05-03): Placement of penetrameters. The
inspector has reviewed many radiographs in the last four years and this
does not appear to be a problem at this time.
.
3.
Licensee Action on 10 CTR 50.55(e) Reports - Status
a.
(0 pen) 10 CFR 50.55(e) Ites (358/80-08-EE): Radiograph Review - M-22
Radiographic review rejecting welds, data reported, May 2,1980.
.
CG&E interia letter to Region III dated May 29, 1980. Results
.
of 1565 welds and 840 packages lef t to review.
C&GE second interim letter to Region III, dated July 26, 1982.
.
Difficulties with preparing final report because of lack of
documented evidence that the personnel performing the review
were qualified, lack of a documented program, no evidence that
the review of radiographs were in accordance with ASME
Section III, 1971 Edition, Summer 1973' Addenda and no evidence
that appropriate corrective action has been taken regarding
those welds rejected during this review.
_
.
S0004314
- - -......
_
_ _.
,
%
.,..
/
o
.
Radiographic deficiencies in sacrificial shield, monorail,
....
.
.and vent stack welds. Date reported May 10, 1982.
'
,
.
CG&E interim letter to Region III dated June 3,1982,
.
stating that a complete review of all sacrificial shield
a
-
weld radiographs will be performed.
The review of radiographs has not started to date. The review
'
may be completed by December 31, 1982 and a final report wilk
then be submitted to Region III.
f.
(Open) 10 CTR 50.55(e) Itse (358/82-19-EE): Radiographs in
As-built Condition - M-50
As-welded conditions may have masked rejectable defects.
.
Date reported May 20, 1982.
' i
CG&E interim letter to Region III dated July 23, 1982. All
.
,
piping field weld radiographs will be reviewed for proper
surface condtion.
,
CG&E is in the process of writing a procedure for reviewing the
.
radiographs of the welds in the as-welded condition. The review
.
'
may be completed by December 31, 1982 and then a final report will
-
be submitted to Region III.
Preservice Inspection (PSI)
The inspector was informed that no documentation on the monitoring of
the PSI by a CG&E qualified NDE person can be found, therefore, PSI may
start over again October 1,1982.
5.'
Exit Interview
The inspector met with the licensee representatives (denoted in Paragraph 1
of this report section) on August 18, 1982, and summarized the scope and
findings of the inspection activities. The licensee acknowledged the
inspector's findings.
I
l
l
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.
-
.
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.
.-. --.
.- -
.
-- -- -
. _
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- - - - -
_ _.
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'
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-
.
.
'
.
.
.3=...QCP Task I NR Review
. *
.
The inspector review revealed that conditions identified in the NRs
described in Paragraphs 2a, 2b, and 2c above were as stated. The
conditions identified in the NRs described in Paragraphs 2d and 2e
e
- '
had been revised and dispositioned " Accept-as-is" and the inspection-
I
of these two (2) items indicated that re-work had been performed
,
before QCP hold tags could be removed to allow the work to proceed.
This necessitated the revision to the original NR and subsequent
disposition of " Accept-as-is." The Resident Inspector and region
,
'
based inspector discussed this with the cognizant licenses personnel,
, '.
i.e., QCP Task I Coordinator, Director of QCP, and the QA Manager.
These persons were aware of this probles. The licensee was in the
e
i
process of revising their procedure covering hold tags to include
H. J. Kaiser hold tags. The licensee was also scheduling a meeting
the week of June 1 with H. J. Kaiser cognizant personnel to review
present procedures and necessary revisions and to establish a working
,
i
arrangement to prevent further occurrence of this situation.
'
This ites is considered unresolved pending further review during
subsequent inspections.
(358/82-10-07)
,
No itees of noncompliance or deviations were identified.
-
q
4.
Structural Steel Bolted Expansion Connections
'llte inspector reviewed the IaSalle report on structural steel bolted
expansion connections and its applicability to Zimmer with the cos-
j
nizant licensee and H. J. Kaiser (HJK) personnel.
.
j:
No re-inspections had been performed since the last reporting period
- .
because HJK was still evaluating the work and developing the necessary
packages and procedures.
This ites will be sonitored on a continuing basis during future inspections.
l
No items of noncompliance or deviations were identified.
-
5.
Exit Interview
'
The inspector met with licensee personnel associated with QCP Task I
- _
during the inspection period. A formal exit was not conducted by the
inspector during this period.
.
!
!
.
!
!,
.
'
'
.
,
i
.
'
S00010,3
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3,