ML20062M517
| ML20062M517 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/09/1981 |
| From: | Jagger R NATIONAL BOARD OF BOILER & PRESSURE VESSEL INSPECTORS |
| To: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8112170275 | |
| Download: ML20062M517 (4) | |
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Gle National Bourb of Boiler anh firessure Ecssel 3nspectors i
S. F. HARRISON, Executwe oirector COLUMBUS H O 43229 U S A.
i e Noca A ansas Phone 614 888 5120 J. J. DUFFY B L WHITLEY,1st Vice Chm.
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C H WALTERS QNNIVERSARQd Staie of Oregon D.R.GA UP, Past hastman ce December 9, 1981 h,e
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y Cincinnati Gas & Electric Company c
DEDI 619 sis 'll Attn:
Mr. Earl A. Borgmann, Senior Vice President y u.s. %
139 East 4th Street 1
*'m Cincinnati, Ohio 45202 e,
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SUBJECT:
Investigation Conducted on December 8, 1981 4(4ca by Mr. Donald Milan, Chief Inspector of State of Ohio and Mr. Richard E. Jagger; National Board of Boiler and Pressure Vessel Inspectors Zimmer Nuclear Power Plant; Moscow, Ohio
REFERENCE:
Improperly Shimmed Pullman Power Radiographs Conformation Program Socket Weld Nonconformances Improprieties Regarding Nonconformances Lack of ANI Inspections Documentation Deficiencies
Dear Mr. Borgmann:
The subject investigation was held at the request of the State of Ohio to review the referenced problems, to determine the status of items under continuing investigation, and to see if further areas or items should be subjected to future examination.
The following additional people were contacted during this =ceting:
Mr. Robert Arthur; Cincinnati Gas & Electric Company Mr. Harlan R. Sager; Q. A. Manager, Cincinnati Cas & Electric Company Mr. Rick Leiber, Level III, NES Mr. Lowell Burton, ANI, Hartford Steam Boiler Mr. John Watkins, Cincinnati Cas & Electric Company Mr. David Howari, Cincinnati Gas & Electric Company 6!l0 8112170275 811209
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Mr. Borgmann December 9,1981 ACTION TAKEN TO DATE 1.
In response to our. recommendation a. review was being made of all Pullman Power radiographs, due to questions raised by NRC.and by this investigation team.
2.
We audited the review program by checking the re-review log, and by spot checking final radiography packages to see that they had both the original and re-review "RT" reader sheets.
3.
The status of the review as.taken from the computer on this date is as follows:
TOTAL RADIOGRAPHS Accept as is 2219 Cannot Interpret 78 To be Reshot 426 Sensitivity Level I 298 Sensitivity Level 2 10401 Properly Shimmed & Accepted 4354 Sensitivity Level 4 2247 No Sensitivity 122 Total Views Revivaed 17419 The corrective action being taken to date on the radiography sensitivity problem was in compliance with our previous recomsendations.
However this must remain as an open item and none of the radiographs can be accepted until the proper control comparison radiographs have been taken and evaluated.
New Items 1.
A review of drawing ISK-D01-M427-1-D0 Revisions 1, 2, 3, 4, 5 and 6 disclosed discrepancies and unaccountability of acceptance for socket welds B1 and B2.
The welds which had originally been stamped accepted by Q. C.
on revision (1) were later cut-out.
Acceptance of the replacement welds could not be verified, and it appeared that a breakdown had occurred in the documentation of identification and inspection portions of the Quality Assurance program.
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Mr.'Borgmann December 9, 1981 2.
Evidence was obtained wherein items which were nonconformances as defined by the Kaiser Quality Ascurance Manual were improperly listed on " Surveillance Reports" in lieu of issuance of non-conformance reports as required.
3.
A review of numerous weld histories disclosed the fact that the Q. C. Inspection " Transfer Acceptance Stamps" were being used improperly. Kaiser Q. A. Procedure 15 paragraph 3.1.3 provides for use of such a stamp only when satisfactory documentation has been provided. Contrary to the requirement a search of the files failed to show that appropriate documentation had been provided.
Hence many of the welds which had been stamped acceptable under this proviso must be classified as questionable until the documentation is complete.
4.
Procedures were not being followed which would assure compliance with NCA-4134.3(c) of Section III, Div.1 ASME for the review, approval, release of documents necessitated by revisions.
5.
The obliteration of entries by Q. C. Inspectors on nonconformance reports is an apparent violation of ASME Section III Division Code requirements.
Paragraph: NCA-4134.10 and NCA-4134.15.
The improper removal of hold tags, and failure of Kaiser Quality Control to assign NR numbers and enter the nonconformance into the nonconformance system, when NR reports were submitted is also an apparent violation of the aforementioned paragraphs.
It was further determined that Kaiser reports numbered CN-5476, CN-5477, and CN-5479 were improperly voided, and copies of these reports were deleted from the NR system in difference to ASME Code requirements and the Kaiser Q. A. Manual.
6.
Information was provided which disclosed the requirements of Section III, Div.1 ASME Code paragraph NCA-4134.1 were not being followed.
Persons performing Quality Assurance program inspections were not being provided the required freedom and authority to initiate quality control functions.
7.
Contrary to ASME Section III Div. 1 paragraph NCA-4134.15 and Kaiser Procedure QACMIG-4 nonconformance reports were being improperly voided without proper evidence for voiding, (NR-E-2237) incorrectly dispositioned (NR-E-2596), voided by improper personnel (CN-5479),
and voided with inadequate justification (NR-E-2466). Various nonconformance reports which had been issued NR numbers had not been. filed or retained in the Site Documentation Center as required.
8.
The requirements of ASME Code Section III 1971 Edition Article NB-3661.5(b) were not being adhered to as required.
Further
' Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, NA-4451, NB-4230,' and NB-3661.5(b) which require inspection for fit-up and welding were'not performed properly.
It was determined that several e
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- Mr. Borgmann December 9, 1981 different methods of verifying " pull back" on socket welds were employed, some of which would prevent verification and inspection as required by Article NB-3661.5(b).
9.
It appears that a serious breakdown in both the Kaiser and Cincinnati Gas 'and Electric Quality Assurance Prograns has j
- occurred, j
10.
In. testimony taken frem.the Authorized Nuclear Inspector Mr. Lowell Burton of the Hartford Steam Boiler Inspection and Insurance Company during the course of this investigative visit, two apparent attempts of intimidation had been made.-
11.
A review of _ the Authorized Inspectors logs on site showed that for-approximately 90% of the time period under which this plant was under construction, only one ANI had been assigned. The plant' is now 97% complete.
It is impossible for one ANI to inspect to ASME requirements under normal situations, and to assume one ANI-can maintain proper inspection monitoring when the Quality Assurance-Program is not functioning properly is ludicrous.
One ANI in a nuclear plant under construction can only give cosmetic and token type inspection service.
If the ASME third party inspection philosophy is to be meaningful, we must have proper and adequate inrpection by ANI.
If five or six inspectors are needed on site to achieve this level of confidence, then we should insist on that number.
It is believed many of-the aforementioned deficiencies, errors, and omissions could have been prevented if there had been more Authorized Nuclear Inspectors on site.
Conclusions In order to verify that we have complied with the ASME Code requirements a National Board investigation is necessary and should be initiated at an early date.
The number of Authorized Nuclear Inspectors on site should be increased immediately from one to four, with an understanding that more would be provided if it was demonstrated they could be utilized.
Respectfully,
/Affj#f o*
Richard E. Jag er Assistant Director of Inspections REJ/dd cc:
D. J. Mcdonald, NB S. F. Harrison, NB D. Milan, Chief Inspector of OHj V. Stello, NRC-Washington DC v K. Ward, NRC-Glen Ellyn, IL R. Arthur, H. R. Sager, J. Watkins, D. Howard-Cincinnati Gas & Electric R. Leiber, NES R. F. Warnick, Director; Region LII-NRC-Glen Ellyn IL J. G. Keppler
, NRC-Glen Ellyn, IL