ML20085K725
| ML20085K725 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/09/1983 |
| From: | Williams J CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20085K716 | List: |
| References | |
| LOZ-83-0042, LOZ-83-42, NUDOCS 8310210113 | |
| Download: ML20085K725 (10) | |
Text
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- ;+M THE CINCINNATI GAS & ELECTRIC COMPANY CINCINNATI OHIO 45201 June 9, 1983 LOZ-83-0042 J. WILLIAMS, JR fRIflCIPAL STAFF e<= ion v ce cae.oc,
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43 Docket No. 50-358 appt
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Attention:
Mri;J G?Ke'ppler' Regional Administrator Gentlemen:
RE:
WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 I.E. INSPECTION REPORT 82-10 W.O.
57300, JOB E-5590, FILE NO. 956C, This letter constitutes our response to the subject Inspection Report and Notice of Violation.
It is our opinion that nothing in this report is of a proprietary nature.
NRC Finding 1A Contrary to Criterion XVII of Appendix B to 10CFR50 and ANSI N45.2.9-1974, Paragraph 3.2.6, changes were made to welding qualification records without adequate procedures or controls.
A.
Corrective Action Taken and Results Achieved The example of this Noncompliance is cited as Item number 358/82-10-05A.
The alteration or supplementation to quality documentation in the welder qualification packages has i
been addressed in the Welder Qualification Review Program being developed by HJK QA.
As a part of this program, review of welder qualification packages is currently in process with provisions for the documentation of
[
deviations with regard to alterations to the quality l
records.
Since the total scope of the Welder Qualification Review Program is still being developed, definitive corrective l
action to avoid further noncompliance has not yet been l
fully addressed.
Consequently, a date for full compliance cannot be predicted at this time.
I 8310210113 031017 JUN 131983 PDR ADOCK 05000350 l
0 PM f
Mr. J.G. Keppler Regional Administrator June 9, 1983 LOZ-83-0042 Page 2 NRC Item 1B Contrary to Criterion XVII of Appendix B to 10CFR50 and ANSI N45.2.9-1974, Paragraph 3.2.6, qualification records for approximately 32 welders had been rewritten without adequate procedural control.
A.
Corrective Action Taken and Results Achieved The example of this Noncompliance is cited as Item number 358/82-10-05B in the report.
All available welder qualification related documentation has been retrieved from HJKCO Welding Engineering by means of the Site Document Retrieval program.
These documents were subsequently transmitted to Quality Records Management for review.
Quality Records Management is reviewing all welder qualification related documents transmitted to their organization.
This review will be conducted in accordance with CG&E procedure QCPP-9.21, and all deficiencies will be documented on nonconformance reports or corrective action reports as applicable.
B.
Corrective Action Taken to Avoid Further Noncompliance WCP-2, Rev.
1, Appendix B, para. 2.2 and QRM-1, Rev. 2 delineate the requirements for identification and resolution of documentation deficiencies.
C.
Date Full Compliance will be Achieved Full compliance will be achieved by September 1, 1983.
NRC Finding 2A Contrary to Criterion IX of Appendix B to 10CFR50 and the Wm.
H. Zimmer QA Manual, Paragraph 9.3, CG&E QA Division did not audit HJK to assure that personnel performing special processes are qualified in accordance with applicable codes.
Mr. J.G.
Keppler Regional Administrator June 9, 1983 LOZ-83-0042 Page 3 A.
Corrective Action Taken and Results Achieved The example of this Noncompliance is cited as Item number 358/82-10-01 (A) in the Report.
The incident identified in the above reference item 82-10-01 (A) was an isolated occurrence in which the cognizant Welding Engineer issued a new Welders Qualification Card under the following circumstances:
The Welder, symbol MGG, was qualified to Welding Procedure Number 3.1.51 on 4-23-82.
His Welder Qualification Card has an expiration date of 7-21-82.
On 7-20-82, MGG went to the Rod Issue Room to' draw rod for a weld he was planning to complete that day.
The rod room attendant would not issue rod to MGG because he had lost his Welder Qualification Card.
The rod room attendant sent MGG to see the Welding Engineer, W. Puckett.
Mr. Puckett confirmed that Welder MGG was currently qualified by examining a copy of MGG's current Welders Qualification Card maintained'in the Welding Engineer's offices.
Because MGG was scheduled to weld that day, Mr.
Puckett issued a new Welder Qualification Card with an expiration date of 10-15-82.
MGG returned t.he new Welders Qualification Card to Mr.
l Puckett at the end of the day.
The following day Mr.
Puckett issued a new Welders Qualification Card based on MGG's last welding on 5-12-82.
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4 Mr. J.G. Keppler Regional Administrator June 9, 1983
- LOZ-83-0042 Page 4 B.
Corrective Action Taken to Avoid Further Noncompliance L
It is our opinion that the Welder Qualification maintenance system detailed in WCP-2, Rev.1 is commensurate with applicable Code requirements.
C.
Date Full Compliance will be Achieved Not applicable.
NRC Finding 2B Contrary to Criterion IX of Appendix B to 10CFR50 and H. J.
Kaiser QA Manual Quality Assurance Procedure No. 10, Paragraph 3.2.3.6, H. J. Kaiser ' Welding Engineering failed to establish and accurately maintain a computerized welder qualification listing.
A.
Corrective Action-Taken and Results Achieved The example of this Noncompliance is cited as Item 358/82-10-Ol (B) in the Report.
In August 1982, a new computerized listing replaced the old computer program.
The new computer program meets the 4
requirements of QAP-10 and WCP-2.
The data being entered j
for the new listing is verified and updated weekly.
B.
Corrective Action Taken to Avoid Further Noncompliance Based on the above, no additional corrective action is needed.
C.
Date Full Compliance will be Achieved Full compliance has been achieved.
t t
Mr. J.G. Keppler Regional Administrator.
-June 9, 1983 LOZ-83-0042 Page 5 NRC Finding 3 Contrary to Criterion XVI of Appendix B to 10CFR50, The Cincinnati Gas & Electric Company Quality Assurance Department and the H. J. Kaiser Company (HJK) Quality Assurance Organization failed to take corrective action regarding the lack of evidence of radiographic acceptability for welder qualifications identified on H. J.
Kaiser Corrective Action Report No. 84.
A.
Corrective Action Taken and Results Achieved The example of this alleged nor. compliance is cited as Item 358/82-10-03.
The requirements for retention of the reader sheets were unclear in the ASME Code Section III 1971 W73 Addendum.
Kaiser QA Program historically did not require reader sheet retention.
The HJK program was reviewed and accepted by ASME and welder qualification records were available to the ANI and NRC for review.
Recent code interpretations and ASME Code editions and addenda have added additional clarification not provided by ASME Section III 1971 W73 Addendum.
ASME Sec. III and IX do require certificate holders to maintain a record
-signed by an authorized individual. -This has been complied with, using the Q-lG Form recommended by ASME Section IX.
It is the position of CG&E that the lack of reader sheets supporting otherwise acceptable welder qualification records is not a basis of rejecting the qualification test.
This problem has been previously identified by CG&E on CAR's 82-51 and 83-03.
However, a considerable number of reader sheets have been obtained from NDE contractors and are included in Quality Confirmation Program Review.
HJK and CG&E Quality Confirmation Programs are presently re-evaluating all welder qualification records.
e Mr. J.G.
Keppler Regional Administrator June 9, 1983 LOZ-83-0042 Page 6 Upon completion of the welder performance qualification review, a qualification cross-reference matrix will be generated ~ indicating the qualification status of each welder and the adequacy of the hardware he installed.
B.
Corrective Action to Avoid Further Noncompliance Reader sheets are now kept to provide further traceability of welder qualifications.
C.
Date when Full Compliance will be Achieved Full compliance has been achieved.
NRC Finding 4A Contrary to Criterion V of Appendix B to 10CFR50, activities affecting quality were not prescribed or accomplished by documented instructions or procedures, such that the licensee failed to impose the reporting requirements of 10CFR21 ar.d 10CFR50. 55 (e) on contractors in that the H. J.
Kaiser Company had neither procedural controls in place to require the evaluation and documentation of reportable or potentially reportable deficiencies, nor procedures in place to require informing the licensee of reportable or potentially reportable deficiencies.
A.
Corrective Action Taken and Results Achieved The example of this alledged Noncompliance is cited as Item 358/82-10-02 (A) in the Report.
In preparation of this response, CG&E performed a review of 10CFR21, NUREG-0302, Rev. 1, 10CFR50. 55 (e) and Criterion V of 10CFR50, Appendix B.
HJK was notified on January 4, 1978 of the then recently published requirements of 10CFR21.
Furthermore, the NRC's charge that CG&E did not impose the notification requirements is contrary to its position taken in response to NUREG-0302, Rev. 1 Section 21.31, Question 6, which states in part, "The licensee's responsibility for insuring compliance with the provisions of Part 21 by its
)
Mr. J.G.
Keppler Regional Administrator June 9, 1983 LOZ-83-0042 l
Page 7 which states in part, "The licensee's responsibility for insuring compliance with the provisions of Part 21 by its contractors, suppliers and consultants is limited to the requirement that each procurement document for a facility or basic component specifies that the provisions of 10CFR Part 21 apply, when applicable."
All existing CG&E procurement procedures adequately meet this NUREG position.
Based on this, CG&E's requirement to impose the requirements of Part 21 is limited to assuring that CG&E procurement documents include a statement to the applicability of the regulation.
10CFR50. 55 (e) does not establish requirements for licensees (i.e., permit holders) to impose notification requirements on its contractors.
The subject report cites this item as a violation of Criterion V of 10CFR50, Appendix B based on the lack of HJK establishing implementing procedures for documenting evaluations of potentially reportable conditions.
It is CG&E's contention that such procedures are not subject to criterion V requirements since the reportability of deficiencies is not a quality concern.
I.E.
Inspection Report unresolved item 50-358/82-05-02 identified that Corrective Action Requests (CAR's)were initiated by HJK and a formal documented evaluation for the reportability requirements of 10CFR21 and 10CFR50.55 (e) was not in evidence.
This finding ironically supports the position that quality is not compromised by the lack of reportability documentation as each item of concern was already addressed by the HJK Corrective Action System.
It should be further noted that CG&E has maintained this position as documented on CG&E CAR 82-82, which states that the conditions identified will be resolved through the established corrective action systems even if they are not reported.
c
,a 4.'.
Mr. J.G.
Keppler Rggional' Administrator June 9, 1983 LOZ-83-0042 Page C; B.
Corrective Action Taken to Avoid Further Noncompliance CG&E notified all. site contractors on-May 3, 1982 of the implementing procedural requirements of Owner-Project Procedure OPP-7.1, "NRC 10CFR21 and 50.55 (e) Reports."
In addition CG&E has conducted an extensive training program for personnel who are assigned responsibility for the review of contractor Nonconformance Reports, Condition Evaluation Requests, Corrective Action Reports, Engine'ering Change Requests and Audit Findings Reports.
This training indoctrinated personnel in both the identification of potentially reportable conditions and the method (OPP-7.1) for alerting appropriate company management of such conditions.
The CG&E Quality Assurance Department monitors contractor compliance with OPP-7.1 requirements.
This is evidenced by Corrective Action ' Reports which identify the lack of contractor identification of potentially reportable conditions.
C.
Date Corrective Action will be Achieved In consideration of the above mentioned actions, full compliance has been achieved.
NRC Finding 4B i
Contrary to Criterion V of Appendix B to 10CFR50 and the Wm.
H.
Zimmer QA Manual, Paragraph 5.1, the Welding Task Force (WTF)
Chairman failed to implement administrative controls for welding Requests for Information/ Evaluation (RFI/E) forms commensurate with those required by Procedure GQP-9.
A.
Corrective Action Taken and Results Achieved The example of this Noncompliance is cited as Item 358/82-10-02 (B) in the report.
GQP-9 was revised to expand and clarify ~RFI/E logging and review requirements.
A memo was sent to all Inspection
F-
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Mr. J.G. Keppler Regional Administrator June 9, 1983 LOZ-83-0042 Page 10 filler material control requirements in the Weld Test Facility.
B.
Corrective Action Taken to Avoid Further Noncompliance Based on the above corrective action, we feel that no additional corrective action is required.
C.
Date when Full Compliance will be Achieved Full compliance has been achieved.
We will address each of the Inspection Report 82-10 findings, and previous similar findings, as part of the programs implemented in response to the NRC November 12, 1982 " Order to Show cause and Order Immediately Suspending-Construction" to assure that corrective actions taken are adequate to remedy the underlying cause of the problem.
We trust the above will be found acceptable as a response to the subject Report.
Very truly_yours, THE CINCINNATI GAS & ELECTRIC COMPANY
(
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By
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l
. WILLIAMS, JR.
ENIOR VICE PRE DENT DJS/sfr i
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 l
l
n, 1
Mr. J.G. Keppler 3
Regional Administrator June 9, 1983 LOZ-83-0042 Page 9 1
1 supervisors informing them of the requirement.
Also, a memo.was transmitted to all managers requesting return of all RFI/E's to the Lead Reports Coordinator so that they could be assigned a log number for response.
B.
Corrective Action Taken to Avoid Further-Noncompliance The WTF Chairman has been made aware, by memo from his supervisor, dated 4/7/83, that procedures must be strictly adhered to, and has received additional training in GQP-9, Rev. 2.
C.
Date when Full Compliance will be Achieved Full compliance has been achieved.
tDN: Finding 4C Contrary to Criterion V of Appendix B to 10CFR50 and the Wm.
H. Zimmer QA Manual, Paragraph 5.1, H. J.
Kaiser weld test shop failed to issue weld filler material in accordance with the site procedure WCP-3, Revision O,
" Weld Filler Metal Control", dated February 17, 1982.
A.
Corrective Action Taken and Results Achieved I
The example of the Noncompliance is cited as Item 358/82-10-02(C).
In July, 1982, the issuance of weld filler material by count versus weight was implemented in the Weld Test-Facility to meet the existing requirements contained within Welding Construction Procedures (WCP) 3 " Filler Material Control".
The applicability of WCP-3's requirements for filler material control to the Weld Test Shop were ' not explicit.
WCP-3 addressed control of filler material for the fabrication and installation process but requirements for control of filler material in the Weld Test Facility were not explicitly clear.
Subsequently, in August 1982, WCP-2 titled " Welder Performance Qualification" was revised to encompass the 8
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