ML20080R257
| ML20080R257 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 09/23/1983 |
| From: | Williams J CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20080R252 | List: |
| References | |
| LOZ-83-0112, LOZ-83-112, NUDOCS 8310170454 | |
| Download: ML20080R257 (8) | |
Text
E THE CINCINNATI GAS & ELECTRIC COMPANY Cl.NCIN N ATI. OHIO 4 520 September.23, 1983 LOZ-83-Oll2 J. WILilAMS, JR SENIOR VICE PRESIDENT NULLEAR OPERAT10NG Docket No. 50-358 U.S. Nuclear Regulatory Commission Region IIT 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention:
Mr. J.G. Keppler Regional Administrator Gentlemen:
RE:
WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 IE INSPECTION REPORT 82-17 W.O. 57300, JOB E-5590, FILE NO. 956C, IR 82-17 This letter constitutes our response to the Notice of
~
Violation identified in the subject Inspection Report.
Based on our letter, LOZ-83-0077, dated July 11, 1983, an extension was granted until August 24, 1983 for this report.
CG&E subsequently requested, in our letter LOZ-83-0122 dated August 24, 1983 an additional 30 day extension and the extension was granted for submittal on September 24, 1983.
NRC ITEM OF NONCOMPLIANCE 358/82-17-03(A) 10CFR50.55(e) M-29 (final report) was not appropriately dispositioned.
The licensee's corrective action statements allowed post qualification of welders and procedures which is not in compliance with Section III and IX of the ASME code.
1
"(Open) 10CFR50.55(e) Report (358/81-06-EE), licensee No. M-29 Unqualified welding procedure for welds greater than 0.864 inch:
The licensee submitted a final report on March 30, 1982, addressing the corrective actions for pipe hanger lug welds.
The corrective action included the " post qualification" of welders and weld procedures.
The post qualification of welders and procedures is not in compliance with the American Society of Mechanical Engineers Code Section III and Section IX and the final 50.55(e) report statements are not in compliance (Items 1 and 2 of the M-29 final report) with the code sections.
The corrective action response for this deficiency is not adequate (358/82 03(A))."
$3k M 0
ed o
a
r 6
Mr. J.G. Keppler Regional Administrator September 23, 1983 LOZ-83-0112 Page 2 A. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
A final M-29 report was submitted on March 30, 1982.
The specific procedure problem initially addressed in M-29 was considered closed by CG&E as stated by the NRC inspector.
Subsequently, further reviews resulting from commitments made in the final M-29 report identified additional problems with welding procedures.
As a result, additional 50.55(e) M-29 reports have been initiated and interim reports submitted to NRC Region III to address the additional problems.
CG&E considers M-29 an open item due to it's expanded scope.
Welders were not " post qualified" as was proposed in the final M-29 report dated March 30, 1982.
HJK issued a stop work order and then initiated Corrective Action Request (CAR)-023 against the condition noted in M-29.
All lugs which were welded by welders who were not qualified to the proper thickness have been identified on HJK NR E-3926.
As dispositioned on the NR, these lugs will be reworked as follows:
1)
Weld metal will be removed to the qualified thickness of the welder and rewelded by a qualified welder, or 2) the lugs will be removed and replaced.
At this time corrective actions to M-29 concerning the lug rework are scheduled to be completed af ter the Show Cause Order is lifted.
Corrective actions for the procedural inadequacies are still being investigated.
Verification of the qualifications for some of the procedures may be required to ensure the adequacy of procedures which were utilized.
The verification of procedure qualification is only being used to provide assurance that the weld process defined by the procedure, while not always supported by proper documentation, was qualifiable and has been qualified.
-__--._-.y m..,,_-,,
.-..,.-.,,,,.--,.-.._,__.,..,.7._
Mr. J.G. Keppler Regional Administrator September 23, 1983 LOZ-83-Oll2
]
Page 3 i
B. CORRECTIVE ACTION TAKEN TO AVOID FURTHER NON-COMPLIANCE:
As described in the referenced interim reports to M-29, the activities involved with the review of H.J. Kaiser welding procedures and the resolution of deficiencies identified by that review are procedurally controllod by CG&E OPP 9.2 " Review of Historical HJK Welding Procedures".
Included in this procedure is the identification of hardware affected as a result of deficiency resolution and the qualification of new weld procedures for future welding at Zimmer.
This review encompasses all HJK welding procedures approved and/or effective prior to December 31, 1982.
Deficiencies identified in other welding procedures have been determined to be enveloped by 10CFR50.55(e) item M-29/M-73 and will be resolved under the same program.
C. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved in accordance with resolution of 10CFR50.55(e) M-29 and M-73.
NRC ITEM OP NONCOMPLIANCE 358/82-17-03(B) 1 10CFR50.55(e) M-35 was not appropriately dispositioned.
The licensee's corrective action statement allowed post qualification of welders and procedures which #s not in compliance with Section III and IX of the ASME code.
"(Open) 10CFR50.55(e) Report (358/82-02-EE), licensee No. M-35 - Seal Head Weld Thickness Qualifications:
the 50.55(e) i report was cancelled by the licensee.
The disposition stated, "since no rework is required to alter the as-built condition, this deficiency is not reportable under the above referenced requirement."
"This deficiency is identical to item identified in M-29.
The licensee's constructor post qualified welders and procedures to correct the qualification thickness requirement and this is not in compliance with the ASME code.
The actions taken do not resolve the deficiency, post qualification of welders and procedures.
The actions constitute inadequate corrective action.
(358/82-17-03(B))."
.---,a-
.,,-w._
---n.--,-.-,,.,-.---.,-,.-n,..,,,,_-,..
c..
Mr. J.G. Keppler Regional Administrator September 23, 1983 LOZ-83-Oll2 Page 4 A. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
The deficiency was originally identified on HJK Stop Work Order 003 and HJK CAR 048.
This condition was determined not to be a reportable condition under 10CFR50.55(e) because all welds were subject to in-process and final inspections, the welds passed all required inspections, and were found acceptable.
The acceptable inspections demonstrate the welder's abilities to satisfactorily weld the greater thickness.
The welders were qualified for all aspects of the welding except for the thickness welded and subsequently were able to qualify for the greater thickness prior to recuming work.
Since all welds were shown to be sound through inprocess and final nondestructive examination, it was evaluated that the condition did not constitute a reportable condition under the criteria of 10CFR50.55(e).
It is recognized that the code violation exists.
However, based on the evaluations conducted, the decision to accept-as-is the condition identified in M-35 was justification for adequacy.
B. CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
CG&E believes that the actions taken were sufficient but not adequately documented when the item was determined to be not reportable.
The utilization of the appropriate forms and adherence to QAP 16-QA-01 shall prevent recurrence of this condition as it requires the approval of the Quality Assurance
[
Manager prior to the closure of the item.
-e,.
r-m
~ ~ -, -
--m o
- ~ - -
.g
- ro e
g m--
- --- ~-
---g
Mr. J.G. Keppler Regional Administrator September 23, 1983 LOZ-83-Oll2 Page 5 C. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved upon completion of proper documentation for Item M-35.
This documentation will be available for NRC review by November 30, 1983.
NRC ITEM OF NONCOMPLIANCE 358/82-17-03(C)
"The completed corrective action for a previous itee of noncompliance (358/82-06-10) regarding qualifications of (weld) Engineering Assistants was not adequate in thac qualification criteria was not established for the position in order to ensure and measure the assigned individual s' qualifications."
"(Open) Item of Noncompliance (358/82-06-10):
Qualification of. Engineering Assistants.
. Engineering Assistants (who were not qualified to do the work of a Welding Engineer), employed by H.J. Kaiser, were performing functions which were described in the contractor procedures as ' Welding Engineer' functions.'"
" Procedure WCP-7, " Welding Control," has been revised to require the Project Welding Engineer to designate qualified personnel to review and approve KEI-Weld-l forms, KEI-Weld-1A forms, hanger drawings and ISK drawings."
"The above corrective action statement is inadequate without verification by the licensee that the designated qualified personnel are indeed qualified to perform safety-related engineering functions.
The reluctance and failure to initiate qualifying criteria for the performance of these functions were discussed during the exit meeting.
10 CFR 50, Appendix B, Criterion IX, requires that measures shall be established to assure that special processes, including welding, heat-treating, etc., are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, etc."
"Although as stated in the corrective action statement of the licensee response to Inspection Report No. 50-358/82-06 the a
,_n--
c,
.y
.-.,,-.w.,,.
,,..-_r,.,
Mr. J.G. Keppler Regional Administrator September 23, 1983 LOZ-83-Oll2 Page 6 welding control procedure (WCP-7) had been changed appropriately, no verification of the constructor's qualification criteria, or lack of criteria, had been made for the performance of job function nor had the qualification of those personnel assigned to this function been verified.
(358/82-17-03(C))."
A. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED This condition was initially identified as unresolved item (358/82-02-02).
The NRC determined that the corrective action taken was inadequate.
Subsequently, 82-02-02 was upgraded to an item of noncompliance (358/82-06-10) and identified again as an item of noncompliance (358/82-17-03(c)).
The following information constitutes our response to the item of noncompliance (358/82-17-03(c)) and supplements our response to the preceeding item of noncompliance (358/82-06-10).
On May 11, 1982 a Kaiser Corrective Action Report No. 106 was issued to correct the condition.
The Corrective Action Statement read:
"TCN #7-3 provides interim clarification as to delegated signature authority for Project Weld Engineer for completion of KE-1/KE-1A forms.
Inter-office memorandum of April 26, 1982 from Project Welding Engineer (PWE) provides a list of authorized signatures."
Those who were authorized to sign for the PWE in all cases held job positions of Project Welding Manager and Senior Welding Engineer.
Assistant Welding Engineers were only authorized to sign for the PWE for American Welding Society (AWS) Structural applications.
l l
l
r Mr. J.G. Keppler Regional Administrator September 23, 1983 LOZ-83-0112 Page 7 The December 1, 1982 response to the item of noncompliance (358/82-06-10) stated:
Procedure WCP-7, Welding Control', has been revised to require the Project Welding Engineer to designate certain qualified personnel to review and approve KEI-Weld-l forms, KEI-Weld-1A forms, hanger drawings and ISK drawings."
CGEE is auditing HJK welding personnel and WCP-7 to ensure that corrective actions are being implemented.
This audit is scheduled to be completed by September 23, 1983 and a Field Audit Report prepared shortly thereafter.
B. CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER NONCOMPLIANCE CG&E has directed HJK to establish minimum qualification criteria for those positions which affect the quality of special processes.
l CG&E has initiated efforts to provide assurance that personnel involved in the control of special processes are qualified for that position.
CG&E will audit HJK to ensure compliance with the criteria' established for qualification.
C. DATE WHEN FULL COMPLIANCE WILL BE' ACHIEVED Minimum qualification criteria for those positions which affect the quality of welding processes will be available for NRC review by November 3C, 1983.
Minimum qualification criteria for all other special processes will be available for NRC review by l
Decemb 9r 31, 1983.
l' rv. - -.--
r----,,n,,
,e
---,w--,-~.,-w,---
---,-------,-n,-
Mr. J.G. Keppler Regional Administrator Septeaber 23, 1983 LOZ-83-0112 Page 8 We trust that the above provides an adequate response to the items of noncompliance which were identified in Inspection Report 82-17.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY BY
(
LIAMS, JR SENIOR VICE P IDENT DJS/sfr-cc NRC Office of Inspection & Enforcement Washington, D.C.
20555 NRC Senior Resident Inspector ATTN:
W.F. Christianson NRC Zimmer Project Inspector, Region III ATTN:
E. R. Schweibinz
_. _ _.