ML20125B951

Draft, Proposal for QA Improvement Program & Quality Confirmation Program

ML20125B951
Person / Time
Site:	Zimmer
Issue date:	05/18/1981
From:	CINCINNATI GAS & ELECTRIC CO.
To:
Shared Package
ML20125A606	List: ML20125A603 ML20125B866 ML20125B903 ML20125B911 ML20125B918 ML20125B923 ML20125B936 ML20125B943 ML20125B951 ML20125B956 ML20125B990 ML20125C036 ML20126F559 ML20126F564
References
FOIA-84-415 NUDOCS 8506110615
Download: ML20125B951 (60)

Text

_ _ _ _ _ _ .

.e THE CINCINNATI GAS & ELECTRIC COMPA.l T WM. H..ZIMMER NtfCLEAR POWER STATION UNIT 1

. DRAFT PROPOSAL FOR:

QUALITY ASSURANCE IMPROVEMENT PROGRAM AND QUALITY CONFIRMATION PROGRAM May 18, 1981 4

, f l

8506110615 850117 i

PDR - FOI A l BAUSERS4-415 PDR N -

__. A .-

. ~

I TABLE OF Coh' TENTS l

A. Introduction

z. .

B. Quality Assurance Improvement Program (April 8,1981 Immediate Action Letter)

1. QA staffing

2. Independence and Separation Between Kaiser

. Construction and Kaiser QA/QC

~

3. QC Inspection

4. QC Inspection Procedures

5. Training

6. Deviations Frc= Codes and FSAR State =ents

. 7. Voiding Nonconformance. Reports -

8. QA/QC Records

9. Conditions Adverse to Quality

'10. Audit Program C. Quality Confirmation Program (QCP)

Introduction Responses to the Following Inspection Report Items: ,

l ,

1. Bristol Structural Beam welds

2. Lack of Bristol Quality Assurance Program i 3asb. Material Traceability - Beams in Reactor and Auxiliary Building 3ced. Lack of Traceability of Materials 3e. Lack of Traceability of Materials

5. Welds Inspected after Painting 2

l l

-mwa. .-- en '+~*"wP-*- 'r- b- - - " -T-5 -~$^e-w--77

c. .

. ..e. .

TABLE OF CONTENTS (Cont'd)

6. Unacceptable Technique for Radiographs of Prefabricated Pipe, Welds

8. Design Violation Contrary to FSAP. -

Cable Separation

9. Lack of Inspection Control to verify Cable Separation -

11. Lack of CG&E Follow-up on Repetitive Problems

~

13. Deleted Design criteria

14. Non-Verified Socket-weld Fit-ups

17. Uncontrolled Design Document Changes e

e e

0 4

- A

i i

i 4

. i

. s Ih7RODUCTION:

The Cincinnati Gas & Electric Cc=pany is develeping more ce=prehensive programs directed toward assuring the quality of construction at the Wm. E. Zi==er Nuclear Pcwer Station. The stages covered by these programs are twofcid:

l. Ongoing work toward construction ec=pletion. NRC/RIII '

t has identified ten items of concern relative to the quality of ongoing constructics related activitias in their April 8, 1981 I==ediate Action Letter. These concerns are addressed in CG&E's Quality Assurance Improve =ent Program.

2. ,Past construction work. NRC/RIII has identified areas of concern (Inspection Report items) during their continuing investigation at the Zi=mer site relative to the quality of existing work. CG&E's Quality Confirmation Program is being established to validate existing construction including these areas and others. In sc=e cases, Inspection Report (IR) items are covered under specific I==ediate Action Letter items and so noted where appropriate.

The Cincinnati Gas & Electric Company has had several discussions with NRC/RIII staff in developing these programs.

The fellowing proposal represents the outline of the pregrams in their current state of development. This proposal is sub-mi~tted for RIII staff review with a recuest for as c==crtunity to discuss any questicas that may arise during the r'ei,iew.

• t i

a G

a I.

I i

l V

l i

L - ._ _ _ _ . _ . _ _ _ . . _ _ _ _ . . _ _ _

4 9

e g T

/

e 2 e o

QUALITY ASSURANCE IMPROVEMINT PROGRAM

/

e e

e e

O e

e b

ee t

.n

IAL 1. Concerning QA Staffing CG&E will increase the size and technical expertise of the CG&E QA organization by adding individuals qualified in the areas of radiography and nondestructive testing, piping supports and hangers, welding, structural design and fabrication, electrical design and construction, and

. metallurgy. We understand CG&E will utilize temporary personnel qualified in these areas until per=anent staff members have been hired.

Reseense CG&E expects to have an experienced nuclear QA Manager at the Zi=mer Site by mid-June, 1981. An offer for this

. position has been made with tentative acceptance.

Listed below are present and planned QA/QC manpower resources supporting the Zi==er project. Efforts are under-l way to retain experienced, per=anent e=picyees in this field. However, recognizing the shortage of qualified candidates in this discipline, technically qualified current and new employees are being assigned to fill some of the positions in the QA Department. Expe'rienced QA contract personnel are being melded into this group to

, assist in the present effort and to train permanent CG&E employees.

The Quality Confirmation Program is being organi:ed separately from the QA group supporting current operations in order to optimize the perfor ance in each area.

A Quality Control group,under the direction of an experienced CG&E QA engineer has been established and is functional as described under the response to Item 3 of the

. April 8, Immediate Action Letter.

I t .

e i

[ <

IAL 1. Concerning QA Staffing (Cont ' d) Page 2 Planned

. Position Present Construction omer.etien Ngr. QA/QC 1 1 1 Quality Assurance: ,

Engineers 1 8 5 Records 3 3 2 Procedures / Training 2 1 1 Auditors 2 5 3 Admin. Support 3 3 2 Quality control: -

. Supervisor 1 1 1 Inspectors ,

16 21 8 NDE/III 3 1 1 Quality confirmation:

Supervisor 1 1 -

Engineers 1 3 -

Inspectors O As Regt. ired -

Totals 34 48 24 Not included in this listing is temporary headcuarters support assigned to the QA/QC group during this recrganization which includes:

Manager of General Engineering Chief Draftsman Supervisor - GED Cleric 51 Group Civil Engineer (Previously GE)

Ad Hoc: Supervisor - GED Records Group Miscellaneous Technicians Additionally, support is provided in selected areas by the Zimmer A/E, Sargent & Lundy. ,

l l See the attached list of persons currently assigned and supporting the CGEE QA/QC organization.

l

.1

- - - - - - - - _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _. - , _ - , - - - _ _y_ , - -- -. . _ . .

. . - ~

IAL 1. Concernine OA Staffine (Cont'd) Page 3 QA ORGANIZATION 5/18/81 Job Descristien QA Manager W. W. Schwiers Quality Engineers R. P. Ehas M. F. Rulli

! D. Schulte J. H. Hoffman (6)

(1)B.Reid (1) G. Orlov Adm. Assistant H. G. Gadd , (6) .

Procedure Preparer (3) 5. E. Martin

& Indoct. Trainer Records Centrol P. L. Adkins J. B. Holland (6)

J. F. Shaffer (6)

Auditors (1)J.C. Buck ^

(2) V. Ferretti (1) E. Carlson' QC Inspection Supvr. D. C. Kramer QC Inspectors See Attached HDE Trainer (4) J. Rodriquez NDE Level III (4) R. Vannier Clerks 5) E. Carr

5) E. Carter

5) D. Smith

, 5) A. Crowder Before Name Behind Name (1 ) - SAI $ ) - Temporary CG&E (2 ) - NES (3) - Independent P.E.

(4) Sargent & Ltmdy (5) HJK Company Unumbered indicates CG4E Employee A

m_..__________ . _. -

. r IAL 2. Concernine Independence and Secaration Between Kaiser Construction and Kaiser QA/QC CGar will take action by April 15, 1981, to assure independence and separation of the QA/QC function perfor=ed '

by Kaiser from the construction function. Region III will be informed cf actions taken. .

Response <-

i In a letter dated April 7, 1981, to the President of Henry J. Kaiser Company,'CG&E outlined the steps to be taken by H. J. Kaiser in their QA/QC effort for the Zi=mer

, Project. In that letter, the Kaiser organization was directed to eliminate any domination by construction of the QA ' organization and the QC inspectors. They were further instructed to stress the independence of the QA/QC organization and to provide effective leadership to allow that independence to be maintained and for the organization to properly function. ,

Related to the above directive, but independent of it, the Henry J. Kaiser Company restructured its corporate organization April 1, 1981. The changes provide that the

' Manager 'of Corporate Quality Assurance now reports directly to the President. This change reinforces the independence and separation of QA/QC from Construction.

The Henry J. Kaiser Company Site QA/QC Organization is being restructured in accordance with the attached chart to strengthen the management and supervision of QA/QC e

activity. A Manager of Documentation position has been added to manage all quality related documents. A new QA/QC Site Manager will be supported by an-outside Quality Assurance Consultant and added headquarters QA Staff.

The CG&E Site QA/QC Staff outlined under Item 1 response to this Immediate Action Letter is being structured into an organization paralleling that of Henry J. Kaiser Company to facilitate monitoring factors such as independence and separation of the Kaiser Construction and QA/QC operations.

All QC inspection procedures currently under review in' accordance with Item 4 of the Immediate Action Letter will no longer require approval by Construction.

e

• _ , , _ _ , - - , . . , . _ . . --,_-y.e- y-_ ,,,,_,#.,y.m_m.h _ . . - . . , . _ --

3 , , , , _-,.,,,w.a 3 , ,.,, .... . , . . , , .

I I

IA7., 2.

Ccncernine Independence and Separation Between Kaiser Construction anc Kaiser QA/QC (cont'c) Page 2 l

t B

. i s~ .

-.D i y I

ge ; .

a"  : =j ':

a, h Eo .

• V

.B. f

-a:s.9 $ 13 1 733 )

M..,=w

= . .-

r -d-- - "

• a 5 J- ,

5u' e 8

M di d)l I

!!  !! T _

i d!h}d d i "i di ir  !

' i, .! s - .

isu  ;

E 1+ "

5 5

has:

[J:![ i j; Mi ll I.

- .ilte-:-: n3 w

1

-, a .:.

3 s.a.a.a s.i M.a- .-o1 s i g

(

C ..

d #, . .id . I.J

-R H e l -

.i w.i s .iE.n.. it.i.!:t k; 99 S. \ s . - . .i s-a' b.

d ' '

f c .

't : : JJJJIt,jji

. J

. 5* =

$131:1 e r y.:

a g::= a+; 4 a2 31.1 3.-w i- o a .

l i! !' .

t r

. b E

!jj2 I

.3 --

-': i :t 11 35.Mh  :

1 __

3l!

G t

.

• gl .

1[ t Ie I 13 '. @ i

( i , *.l . & 4 :12

.. -J.U a- b1

.5333-i f f dU Tj 5' - $ h h hl

. h, e:

e{,

-(

o ..g::2 lllIII e,

• u R. - b A *.

.I ' ,I ;:

] g {9 e i i L ~: 77 qH h*3.'j) l*s

. . i.

4 i 11 0 :5

. . -:  :' ny a- o 3 A --

2., " M4- a

• _t --

. I g . . -- ,

,,, f - - - - _ - _ - e-g,g I

s I

I -

, " ""* . A f us I

kW i =J $* 5*o, E

}

- i. gg ; 3 3d i: o ao a 2- 3~,

u_____ ,

l l

l

l

. l

. l IAL 3. Concerning OC Inspections Using the personnel described in Item 1 above, CG&E will conduct.100% reinspections of QC inspections conducted by Kaiser and other contractors after the date of this letter. This will continue until a revised CG&E Audit Program as described in Item 10, below, is implemented by these qualified individuals and-RIII releases this require-ment.

Response

i CG&E has established a Quality Control organization to meet the. requirements stated above. Twenty qualified i.

inspectors are currently employed and assigned as shown on the attached list. They will conduct reinspection of the inspections performed by Kaiser QC personnel on a closely monitored basis encouraging feedback of observations.

The CG&E QC program does not relieve the Henry J.

i Kaiser Company from the final responsibility for quality centrol. The CG&E reinspections will reflect agreement or

• disagreement with the results of the Kaiser inspection and will not constitute an acceptance or rejection of the work.

Construction of essential work will be allowed to pro-caed only as it may te supported by the CG&E reinspection program. This program is being implemented as the inspection procedures are re' viewed and the inspect =rs can be trained in these procedures and certified in their respective areas.

i e

e l

/

/'

,e .

IAN 3. Concerning QC Inspections (Cent'd) Page 2 TEE CINCINNATI GAS & ELECTRIC COMPANY WM. H. ZI.v_udR NUCLEAR PO*aTR STATION ~

I I

QC INSPECTORS Donald Krar.er CG&E - Supervisor Electrical .

Chuck Spinks SAI Dale Eallenbeck SAI '

Electrical Hancers Jerry Rheinhardt SAI Frank Rivera NES Ralph Powers NES Structural .

Linsey Caison SAI Alah Ashworth SAI .

NDE '

Ron Shope SAI Ralph Murphy SAI L. J. Victo.y SAI Pipe Support Rodger Taylor NIS Robert Cannen Cw&E Keith Deck CG&E

Warren Hopka NES l Eric Antinarelli NES Dave Fox S&L John Paquin NES

! Pi=ine ^

! Ron Wilson NES Warchouse -

Jim Weissenberg CG&E

~

WYGB i

l l

l l SAI NES CG&E S&L l

l 8 7 4 1 = 20 Total

IJJ. 4. Concerning QC Inspection Procedures All QC inspection procedures will be reviewed and revised (where appropriate) by qualified design engineers and QA personnel. These reviews will be conducted by

' personnel independent of the construction organisation to confirm that the procedures include appropriate inspection require =ents and applicable hold points. The construction activities controlled by' these QC inspection procedures will not be performed after the date of this letter until

, the applicable procedure has been reviewed and approved.

Response

+

A program under CG&E control has been established to review and approve all QC inspection procedures as follows:

1. All QC inspection procedures are being reviewed by qualified design engineers and QA personnel. The object of the review is to confirm that the QC inspection procedures include appropriate inspection requirements and are technically correct.

2. The reviews are being conducced by personnel who are j independent of the construction organization. -

3. Cdnstruction activities controlled by these QC inspection procedures are not performed until after the applicable procedures have been reviewed, revised (where appropriate),

' approved by CG&E, and the respective inspectors trained in any revision.

! This procedure review program has two phases:

Phase I. Initial Review. Attached is a current su= mary of the Phase I QC procedure review status.

As work and reinspections proceed on the basis of these approved procedures, feedback on potential improvements is solicited from all l

parties associated with the QC program.

Phase II. Continuing Review. . Comments for those implementing ~

the approved QC procedures, plus an ongoing re-assessment of QA/QC programs, will be the basis j

for continuing reviews of the procedures approved under Phase I.

6

~

~

. i l

l IAL 4. Ccncerninc QC Inspection Procedures (Cont'd) Pace 2 QUALITY CONTROL INSPECTION PROCEDURES Total No. of Procedures 118 Total No. of HJK Procebures 93 Total No. of HJK Deleted Procedures 26 Total No. of BJK Procedures to be Reviewed 67 Total No. of CG&E Technical Reviews 64 Total No. of CG&E QA Reviews 55 Total No. of Waldinger.-Young & Bertke

• Procedures 12 Total No. of CG&E Technical Reviews 12 Total No. of CG&E QA Reviews 12 Total No. of NES Procedures 12 Total No. of CG&E Technical Reviews 12 Total No. of CG&E QA Reviews 2 Total No. of Field Construction Procedures 1

, Total Deleted Field Construction Procedures 1

' Total No. of Issued Procedures:

Kaiser 40 WYB - 5-19-81 12 NES 0 2

D

-;- - - - - , * - - - - e,m--

5. Concerning Trainine QA/QC personnel at the Zi==er site will receive training on any new procedures and practices resulting frc= actions taken to fulfill provisions cf this letter prior to implementation of the procedures. In addition, refresher training will be given prior to June 1,1981, on (a) the identification and documentation of nonconformances, deficiencies, and problerss, (b) the procedure for resolving nonconformances , deficiencies, and problems, (c) the feedback mechanis= for informing the identifying individual of the resolution of the nonconformance, deficiency, or preble=, and (d) the avenue of appeal should the identifying individual disagree with the adequacy of the resolution.

Resoonse QA/QC personnel at the Wm. H. Zi=ner Nuclear Pcwer Station are receiving training on new procedures and practices resulting from actions taken te fulfill provisions of the immediate action letter as follows:

i

1. Both the H.J.K. and C.G.sr. training groups respcnsible for QA/OC training are notified when a new or revised procedure is approved or when specialized training needs j to.be cenducted.

2. The training groups appropriately schedule _ and cenduct a training sessien for the personnel affected. This training is performed prior to i=ple=entation .cf the

, procedure.

Refresher training on items 5.a through 5.d above is in progress. This refresher training will be co=pleted prier to June 1, 1981.

Regarding item 5.c above, various feedback systems en ncn-conformances have been evaluated. It has been decided that the report of all open nonconformances will be positioned

~

with the QC supervisor and made available to all inspectors.

Similarly, the records of dispositioned nonconformances will be available to the originating individual for review.

Indoctrination training will include detailed instructions.

in the use and availability of these nonconformance records.

1 i

l .

t 1

l l

l _

s Q

Regarding ite= 5.d abcVe, the " avenue of appeal" available

- to anycne disagreeing with the resciutien of a ncncenfc. ance report is cutlined in Kaiser April 23 Incer-office =e=ccandu:

, te all Inspecters as fellows:

i

' Interested party sends Inter-Cffice Mene tc Manager of inspection stating reason for disagreement. Manager t of inspection is chligated te review and rescive,if pcssible.

3 If net satisfied with resciutien by Manager of inspectien, the interested pa_ty sends Inter-Office Meme t ECK '

Site QA Manager for final resciutic . ECK Site CA Manager is obligated to provide the final resciutien with ec-Jies to CG&E CA Manager, KII Corporate CA Manager and KII VP - Power Division.

• '?.ese instructions will be placed in the precedure a .d included in the refresher training progra to be concluded by June 1, 1981.

t .

f s

1; .

r O

e e

D f

4 i

k W

7 v -ww< , - - , - -,. , r---S v + - *

• r- - +e-<~'- - - - + .v-i+ - - + ~- -

v l -

IAL 6. Concernine Deviations from Codes and FSAR Statements 4

Prior to May 1, 1981, the procedures governing the  !

identification; reporting, and resolution of deviations from Codes and FSAR statements will be reviewed for adequacy and revised as appropriate. The procedures will require CG&E to review and approve the reso;..cion of any such deviations. '-

Response

A. Construction Forces 1

, The DDC and NR procedures have been reviewed. Comments i have been incorporated and the revised procedures are being circulated for final approval at this ti=e.

B. QC Inspection Forces l Both the Design and QA review of QC inspectica j

j procedures have been aggressively pursued. A large percentage of these reviews have now been completed l as noted in the response to Item 4 of the I.A.L.

J '

j construction activities controlled by these QC i

procedures are being resumed only after the applicable procedure has been reviewed and approved and the QC inspectors have been trained in sny procedure changes.

C. Desien Forces Organizations responsible for design of cafety related equipment are being audited to assure that they have

] sufficient procedures an,d training to identify .

deviations from Codes and FSAA statements (Ref. IR l Item $18).

1 1

The FSAR is being re-reviewed for correctness and consistency with respect to the design by the 4

responsible system engineers. This re-review remains

) on schedule for completion by July,1981.- ,

New Project Proceduras are being drkited establishing 3

the need to submit corrections to the FSAR as changes are identified. Formal issue of FSAR changes will be made on a semi-annual basis.

I j

A new Sargent & Lundy Project Instruction has been issued to provide a requirement to identify changes i

or deviations from industry codes and standards.

This floc).

revised instruction has been issued (Ref. IR -

s t .

1

-t -r . v,. , -.r. ,_ -. -- ,. , . . - - - . . - - . _ . - - . _ . . _ , _ . _ . , , , - . , - - - , , . .--..w.

Page 2 IAL 6. Concerning Deviations from Codes and FSAR Statenents (Cont ' d )

,, C. Design Forces (Cont ' d )

i .

Sargent & Lundy is reviewing on a company generic basis the adequacy of the procedure of using design calculations to justify deviations. This review along with the identification of specific corrective actions is on schedule for June 1981 completion (Ref. IR Item floa).

Preparation of a CG&E Owners Project Procedure that will provide management directives and a summary of the implementing procedures for identifying, report-ing and resolution of deviations frem Codes and FSAR stataments is on schedule for July 1981 completion (Ref. IR Item $10b) .'

O e

+.

4 1

l i

i 1 i.

l 2

i 1

l

i IAL #7 - Concernine the Voidino of Nonconformance Re orts The procedures governing nonconformance reporting will be reviewed fer adequacy. The review will be acccmplished not later than April 10, 1981 The disposition of each nonconformance report together with appropriate justification will be documented. <-

Response

The procedures governing nonconfonnance reporting have been reviewed for adequacy and are determined to be satisfactory. In junction with these NR's that have been voided the following corrective action is beino implemented.

1. An independent qualified QA engineer has been assigned to review the approximate 740 voided NR's, which have been segregated by catego ry.

2. The category " Superceded" which included approximately 370 NR's was the start point for the CG&E review. HJK had started the same review and they were instructed to continue but to submit copies of the required documentation so that CG&E can validate each voided docu' ment. Monitoring of this activity shall Ebe conducted by the CG&E QA engineer.

3. The approximate 105 documents category "found or chanced" will be researched and the proof of validity for voiding the NR shall be requested from HJK. Each individual NR shall be analyzed and the voiding accepted or the NR will be reopened and closed as required.

4. The " reinspection" category will require individual review of each NR voided, and justification will be' required or the NR will be recoended.

5. Proedures established for the prior categories will be aoplied to the balance of the voided NR's. Those which cannot be validly voided will be reopened.

6. There will be documentation and justification for the voidinc of each NR covered by the above categories or the NR will be reopened. -

7. Completion of the above reviews will be accomplished by October 1,1981.

8. An audit of the HJK NR Log will be conducted to validate that NR's have not been voided without processing, or assignment of a number other than a control number.

O

. . - ~ - -. - _. . _ , _ _ _ . - . - - . . - - - . . . - . . - - . .

l l

l 4

IAL 8. Concernine QA/QC Records The review and alteration of existing QA and QC

. records has been stopped. These records will be controlled j

by CG&E until a program defining records control, usage, and adequacy has been prepared by CG&E and agreed to by RIII.

, .e 4 Response All Kaiser QC records were relocated on April 7, 1981

! and will be under the care, custody and control of CG&E

Quality Assurance until agreed to by Region III. This item 1

also addresses the concerns of I.R. #16.

CG&E has established a program to assure all necessary attention to effect the care, custody and control of QA/QC

! dccumentation. It is the. intention of CG&E to continue to have IJK process the records in an environment of surveillance by CG&E. In order that records are managed l' more effectively and efficiently; the following activities are being implemented:

1. Improve the physical facilities for record handling l and storage. -

1 i

• CG&E is constructing an underground record storage vault meeting ANSI N45.2.9 requirements. An office complex to process and manage these records I

will be located immediately above this vault.

i 2. Establish procedures that provide for improved j receipt, control and maintenance of QA documentation.

! CG&E has promulgated'new procedures and is planning

! additional procedures.

3. Involve CG&E and BJK interactively for improved communication, surveillance, audit and control of records.

CG&E has arranged for relocation of HJK QA and i

CG4E QA personnel to provide a better environment j

for communication and interaction. The new Construction QA Records Center will house both l RJK and CG&E personnel. HJK will process the

! records and CG&E will provide surveillance and audit. ,

i .1 e

I _ ___.,_._ .__. _ _ _- _ . _

i

. . ;.~

9 IAL 8. Concerning OA/QC Records (Cont'd) Page 2

4. Develop commitment control program to effectively "Close the loop".

The Record and Information Management Systec

at the station i.s being extended to support a " commitment cohtrol progra=". Software is in place and operating at the station for this purpose. Additional hardware is being procured to provide this capability in the QA complex.

5. Staff this activity sufficiently to allow orderly

. progress in a well controlled environment.

CG&E has a full time management amployee assigned to documentation, surveillance and audit of activities in the new Construction QA Records Center. This person-will have additional clerical support as necessary.

l s '*

4 l

.I l

i l

. l

Ite: 8 Concerning QA/0C Recores (cont'd) Page 3 Figure 1 shows the basic interface points for documentation - It is not intended to show.all docuc:ent movement options. ,

r

~

T HJK QA CONSTRUCTION DESIGN f PMITME CONTROL (s

(ONFIGURATION

. PROGRAM CONTROL 7 n CONSTR. DOCUI'ENT

,,R IMS

j QA -

CONTROL m 5 RECORD CENTER -1 CENTER A STATION VAULT

k. -

.}

FIGURE 1

• m

l IAL #9 - Concernine Conditions Adverse to Ouality CG&E will perform a 100t review of all surveillance and non-contornance reports written by contractor personnel after the date of this letter. This program will continue until RIII releases this requirement. '

Response

H. J. Kaiser Company has been instructed to issue a copy of each NR and surveillance report to C.G.& E. QA for review.

These reports are issued at time of preparation. The following

' t>

Qdescribes the method of control established by C.G.& E.

1. NR's issued by H. J. Kaiser'for C.G.& E. review shall be l controlled and filed by Control Number..

2. The'C.G.& E. File for the NR's received per (4) above will te reviewed on a monthly basis to assure that each NR has been received or a reason for their void has been provided.

If adequate reason for non issue of an NR is not provided C.G.& E.

will take appropriate corrective action to resolve this problem.

, 3. Procedure QA 15-QA-03 has been prepared and approved for review of NR's that are issued by HJK.

4. Training of those Quality Engineers responsible for review of NR's will be completed by May 26, 1981.

5. All unacceptable NR's prepared or dispositioned by HJK will 4

be returned for correction and retraining in their preparation if required. -

! 6.

i The surveillance procedure is being reviewed to assign authority for issue of surveillance reports to QA Personnel.

7. A form and method for providing-the neans of QC inspection to

' request infonnation regarding inspection criteria is in pre-paration. -

8. Documentation Deficiency Reports are prepared by QA Personnel.

These reports are related only to QA and do not involve QC inspections. ,

9. In Inspeection Report is prepared at time of receipt inspection

? and covers those items which are retruned to vendors. These reports are utilized to evaluate the performance of qualified vendors.

Note: The above also addresses concerns arpressed u Inspection

• Report Items 4 and 7.

IAL 10. Concerning the Audit Program The existing CG&E Audit Program will be reviewed and revised by June 1, 1981 to include technical audits of construction work and more ce=prehensive and effective progra==atic audits.

Ra'sponse The CG&E Quality Assurance Manual requires a comprehensive system of planned and periodic audits to verify compliance with all aspects of the quality

, assurance program.

The audit schedule has been reviewed, revised, and expanded (attached) to include hands-on field audits and audits of a technical nature at firms providing design services. . The audits will be in-depth and co=prehensive covering all applicable requirements including deviations from codes and the FSAR.

A second audit schedule is being developed that will i

address required audits for suppliers who are supplying essential materials for the Zimmer Project. .

The existing plan for the, review and revision of the audit program is as follows:

1. Review and revise the audit schedule to assure that 4 site organizations and firms supplying design services are audited to all requirements of the QA progra:

' including technical aspects. This activity is complete except for final approval.

2. Review the CG&E approved vendors list to develop an

' audit schedule for vendors actively supplying essential components to the Zimmer project. Vendors to be placed on this schedule are those which meet the following criteria:

l .

a) The components being supplied require engineering i

' and/or shop fabrication (i.e. not an off the shelf item).

b) The quality of components supplied cannot be verified by vender surveillance or source inspections.

c) The quality of components supplied cannot be i

verified _by receiving inspections or performance testing.

i g 3 -. --,vr -

r-. -

w--

-,-v , -.-. - ., --,.,-e,, ..-e.w. , , -- - , , -. - .-

J i

IAL 10. Concerning the Audit Program (Cont'd) Page 2

3. A sample of past CG&E QA audits of HJK, S&L, GE, EPD, ECTD, GED and GCD will be reviewed to determine the depth and adecuacy of these audits particularly with respect to nonconfor=ance programs. In the areas where deficiencies in the past audit program were identified and corrective action not yet verified, new audits will be scheduled as soon as practical (Ref. IR #12).

4. A formal audit of the items contained in the NRC's, April 8, 1981 Immediate Action Letter and the inspection report items is . planned for the week of June 1,1981.

The purpose of this audit will be to determine the

status of the action taken to meet these co=mitments.

9 W

l 9

e i

I

.I

• t

- + - ~- ,w.-- ,,n-e

- '~ '~A" 1C. C ::e-3-- "e A-':- =.-. . [

'*E'

• _. g ,

2::c:1= ico::': ) ~ ~~-~"*

3y I

i

"~' ***~~~ * ...........,.,........... .

2" '~~~

• L C -1 I I lGi ii! I ia: i l

~

=

l

._ m . .:*.~~ ""- ~ " LC- 1 I i i i l i i i 11 i

. . '== -M - *O'::*;:l'*J l l I i 1* I I I ; i i*I i

' m' ** " ~

• L'::": " J *I I i i i i*l l ! I I 1

• =s . :::""' ** ** :.AC.! 1. i i i 1* 1 1 I i i l*!

== C " J** A':::*'.1 11 i i I i 1. 1 I I I i ,

j j -

' =c C T: J :A':: ~.! I I* I I i i i i*i i i I  ;

~

• =< C':L* :::".*,;:':. *aC.J l* I I L i i*I I I i i i i

. . "Les  : L ~. ~ IAW ; i i* i i I i  !* I I I I i [

. ~ .- . - , I

. - - .I i i.i l i.i l i... i i g I * *

"a m=----.  :.T,J l I l*l I i i I l'i i i  !

1

'u . "AC:T.! I i i i i l'1 I i i i i

~

"- " ' " " ~ ' "  !

" A'::"'.J l I* 1 i ! i i i i i i i

- =- ".". :l***"* -#I.1 II I i*i i i i i i I i  ;

e- - ,,

-O .J4 I I I i i ! +-l~l I 1 !  !

> 'm A OJ 3 I I i 1*i i t I i l')  !  :

' wai --

.1' ." "4 Ii i 1*1 1 1  ! 1*i l l i . '= -- -A=eriiiiiii n ii i l _

• = ~lll::'::" -

• T-- fI f*l I i i I i i i I I ~,

'== ** ::l.". -

• r ".1 l~ l i I i i 11 1 ! I 1 i

== ** ' T.,.! f I i i 1.I I I ! I 1*1 i l

. 'e= 0;;:.*~*'"** *AW.!  ! I* I I I I I I*1 I i i  !

4

~

== P _m .A'::lL".]

• 1 1 I I I i i ! t i i 1 l

-a=--- 1

_ n. --~ --i g g 3 3 l t g i*g i g -

'- lll;;;.:;; -

AM.] I I i i I I i 11 I i l l

'= 'l

;;.c. ._  :.A.C.J l* l ! I i 1 !*l ! I i i  !

m-' AC.) l I l*l i I I I ll i I i

'= t;;.i,;. "  :.T.! ! I I i 1*l i I I I i *l

~

[

= " d-~

. - - .1 1 I I l*! I I I I I I i ~

+

'= *;; 1.'t=:".1 11 1* l i I I I i'l I i  !

• = O -2 =.~.1*) i I I I I I I I i l i i

'a=  :::;.f ,  :.A W .1 1I I I i*I i i i i i*I

. - f

.= .

- .1 t I. I I i i i i.i I I I i '

'== 1.A ".;.".) i i* I 1 1 I I I*I i i j ' ,

• Q-

' *~

[

j 5 .- ~;;'.  ;.Ac.) i I* I i l1 I I* 1-t*1 -

l

== 0;; ~"* -A;".f.! !I I I l I*I i i I I l l ri: O:::::'.! l* l i l*l I l* l I l' 1 I i

! - *d

. i.A ::'C'.!

• I I I i i i i I i i i i i i ! -l i I I I I i i i i i  !

I l i 1 1 I I I I I l 1 ( . , ,

I lI i I I i ! i i i I i  ;

', i11 I I i 1l I I I I ( I j

I Ii i i i i iI I i I l

+

t

c. -

-l

& e. s .e .a % s., . ,

t

..n., _ . _ . _ _ _ . - , _ _ . _ . _ -

. . l Adder.d um to 310 l

. Regarding: inspection report item #11 - Lack of C.G.& E. Follow-uc on Repetitive Problems (Indequate Corrective Action) the following shall be implemented relative to the C.G.& E. audit program.

I Responses to audit findings now require that corrective action taken to avoid further noncompliance must be supplied by the auditre.

In verification of this action, the aucitor must have assurance that this corrective action is adequate to address .any possible generic deficiency.. Also an Unresolved Deficiency Summary is issued monthly ,

from the Manager-Qualtiy Assurance to the Senior ' lice President and the Manager of any orgainzation responsible for corrective actions to deficiencies that are past due. This includes deficiencies which are delinquent past the due date and deficiencies which have exceeded the planned completion date and QA verification was not possible due to lack of, or inadequate corrective action on the part of, the audited organiza fen.

The deficiencies addressed by this procedure are those identified during audits conducted in accordance with audit and surveillance procedures.

A new procedure has been established to define the method for the

reporting of repetitive, generic, procedural, or significant concerns adverse to quality to the appropriate levels of managenent.

Conditions for which Corrective Action Reports are issued as follows:

l l 1) The condition indicates a trend of declining quality.

2) The condition is repetitive indicating current controlling l

measures are inadequate or insufficient.

,~ 3) Evaluation indicates that the condition is a result of a program deficiency.

4) The condition indicates failures to obtain required approvals for changes in procedures or documents.

I

5) Failure to resolve a deficiency in a timely manner.

6) The condition indicates negligence or disregard of document or procedural requirements.

. 7) QA follow-up review of conditions adverse to quality show

that the approved corrective action has not been taken, or

has been improperly or incompletely accomplished.

The Corrective Action Reports are distributed to the appropriate management of the organization to which the corrective action was i addressed as well as those responsible for implementation of the  ::

l I

l -

, , Addendum to #10 (cont'd) corrective action and the CG&E Senior Vice President.

CAR's must be responded to and corrective action verified i within 10 working days or a Stop Work Order is issued in ac:ordance I with the applicable 5 top Work Order Procedure.

Regarding inspection report Item #12 - CG&E has not performed any audits to verify compliance with the effectiveness of the S&L nonconformance program the following shall additional be implemented to Item f3 above concerning the Audit Program.

Inspection secort #12 -

1. Identify previous audits conducted at S&L, HJK, EOTD, EPD, GE, GCD, and GED. -

2. A matrix shall be developed for each organization which lists the 18 criteria and identifies those elements of the program audited.

3. For each organization covered by Item 1, the 18 criteria will be analyzed for applicability to that organization's program.

4. For those criteria that were not auditeo and were applicable to the

• subject organization's program, the next audit of the organization will include audit of these criteria.

~5. Based on the results of the audit covered by Item 4, an analysis will be made.to determine whether items not audited may have affected

' 'the quality of the component or service included in the organiza-tion program.

6. Items which are indeterminate will require a quality and engineering disposition to determine the corrective action necessary to validate quality miements.

I e

l

.e

i z

QUAIITY CONF RMATION PROGR.AM O e 9

e 9

O.

INTRODUCTION In order to address the concerns expressed with past ouality assurance activities at the Wm. H. Zirmer Nuclear Power Station -

Unit I, a Quality Confinnation Program (QCp) will be instituted.

The purpose of this program will be to verify the quality of past construction. '

The following items from th inspection report will be in-cludedin the program:

Item #1 - Bristol Structural Beam Welds

. Item #2 - Lack of Bristol Structural Beam Welds Item #3a & b - Material Traceability - Beams in Reactor and Auxiliary Buildings Item f 3c & d - Lack of Traceability of Paterials Item f 3e - Lack of Traceability of Materials Item f5 - Welds Inspected after Painting Item #6 - Unacceptable Technique for Radiographs of Prefabricated Pipe Welds Item #8 - Design Violation Contrary to FSAR - Cable Separation Item (9 - Lack of Inspection Control to Verify Calbe Separation Item #13 - Celeted Design Criteria Item #14 - Nonverified Socket Weld Fit-ups Item #17 - Uncontrolled Design Document Changes The remaining items from the inspection report will be addressed in the response to the Innediate Action Letter (IAL). These items are: -

Item #4 - Serveillance Reports Not Being Converted to Nonconfonnance Reports in 30 days (see IAL #9)

Item f7 - Nonconfomance Reports Are Being Voided Improperly (seeIAL#9)

Item #10 - S&L Cable Tray Loading Design Control (see IAL #6)

Item fil - Lack of C.G.8 E. Follow upon Repetitive Problems Item #12 - Audit of S&L Nonfonnance Program (see IAL #10)  ::

Item #15 - This item has been deleted Item #16 - Deviations from Codes and FSAR (see IAL #8) -

. (1) -

~- . -

w, . .

Iter #15 - Ceviati:*s f=n S es a-: FI '* * 'e Tray Mnger Weks (see IJL #5. :::f Of t*e re::

jus:tfyi ; :ne en:e::f: .ill :e sa:e avatta:'e

..- A 4&a ,

.n at:iti

• A lis: Of ite 3 *: te i*.010:e it **e . "C2 TJ s t * *.

icen*.ifies y C.3.1 E. task f: te "e* f:.* Tic (I) 2fs *.: Ce#ine

• en*iai ;* Ie anas in hti* s ;;*. *.'i n g s a s *7ar i *a ti:ns i r. .t i vt c.

naurials ;r::er;res, s r.-::; es;. :: cenents. C* :.:;-125. e::.

The lis: is as f:il:ws:

nn s. ..a.rcer r. . es

.,.. . t .me.s :s C;oer Fi;e Weits en :?4 Ref-igera:#:n Syste:

- MYA0 Mf;n 7 essure 5 0: Welds Fire Prete::f=n Fi:e Mengers - Ces*;n Feriew Essen:ial '-Ange-s N:: Affected by New L:t s 7 :; an Essential Fie:r at: Wali Fenet ati:ns as Insulle: ty *e r.s.a. .4...aia. - .....

- Weice: Atu:.*ments : . Safety :sizie: Ff:i ;.

. e_. 4

. . .... . .em.... .. . . e, s

' ~

- Eeview Of 3c:vnenuti:n f:r Q ui.nen: Liner agai$s: I-.s u l-latice Sta:ilizar Truss t

- Review Of F;ei 7 :1 Liner %:;menuti: . at: Seie::st '.e':s

~

- Review Of Ethelic; 3 ell ws ~c:.=enutten and feie:te: Vei:s

. - Review Of Pipe Whi; Restrain Oc::.ee .uti:n an: Seit::a: Wei:s

- C:nff;;rati:n Onfirsatice and Ins;e::1:n f Seit:ut kel:s On Se vice Water Ir.take Thee

- 0 ;nded Cen: ete lixit Ealls - C: ##;;rati:n For these itees act recairing ICC: rtins:e::f:. a sax ie ;ian will be esta:iisted. Tw: types of sazite; an ;1annet. ~ .

1. Cis::ve-v A:adi: 81an This :lan will be;fn hy eeteminia; : e : aiity :f : e .

occ.reetatien. This will be a:::rclis e: ty nvie=' ;

.M 3:::zer.uti:n agaf..st t.e CA/*C ;-::et;ns in .se s at *Je time *he 30C'.rea.*.s Mit ger.e ates. ~

Ye 'fy !?e 3 :.reatatien by tr_e: hie; a sme*I rare::

Semle Of t.% ucrt pe #:rnet in : a fielt.

(2}

If a proble: is fcund to exist the use of a :ncre rig cus statistical sa: pling plan will be investigatec. If no :r:-

blem is found, the work and cccu:nenta:fcn will be censicere:

acceptable.

2. Statistical Sa cline Plan This plan will begin by deter ining the samle size, the

' confidence level to be achieved, and the method of select-ing the sample population. .

Qualified inspectors will verify that pr:;er c:nstruction techniques, configuration, etc. exists and that tne equipment is pmperly installed.

The inspection plan will c:nsist of precedures detailing the si:e of the inspection teams, qualification of inspectors, ins ection methods to be used, and sarele inspecticn for :s. The tea =s will be c =:rised of C.G.& E. persennel as well as eeployees cf H. J. Kaiser, Sargent &

Lundy, and other centract persennel as required. These precedures will be prepared by C.G.1 E., Sargent & Lundy, er other c:ntract ;ers:nnel and reviewed and a:preved by C.G.& E. All ins;ectors will be trained in the ap;repriate inspection precedures.

1 A report will be generated giving the results of our investi-gations and inspections.

Cincinnati Gas and Electric has undertiken crecraes in the past 2 to 3 years to verify the quality and adequacy of varicus cc=-

penents.

The following is a list of items for which a high degree 3

cf confidence in the quality of construction and installation exists:

- large Percentage of Essential Pipe Mangers (th:se that have not been verified will be inspected as a part cf :ne CCF)

~

- Cuct Hangers

- Expansion Anchcrs - test conducted by Cecrsenwealth Edisen and C.G.& E., all non-conforming anchors have been identified

- Pre-stressing Tendens 4

1

- Quenchers ~

- MSRV Discharge Pipe and MSRY Supperts

- Leak Proof Doors 1

m. - -

---,,---v-- v, , - my 3.- v ,..

7-,, . _ .. _ . _ . . - . . _.,,y- -,,-=ar-- ,_y--.---e,

i

. INSPECTION PJI? ORT fl - 3RISTOL STRCCWRAL BIAM WILOS 4

CONCERN: Apparent lack of an adequate GA progra= cevering

,, field welding by Bristol resulting in scme un-

. acceptable structural welds.

Inspection of Br'istol structural bea= welds in

~

DISCUSSION:

the 54 6 ' elevation of 'the Auxiliary Building, Cable Spreading Roan, and RER Esat Exchanger Rcom i ,

revealed that several field welds are unacceptable to AWS weld inspection criteria.

QCP ACTION: 1. Establish a drawing review to deter =ine where Bristol Structural Steel field welding exists.

I This review will also determine the location of other vender field'. welds (i.e., ECK, FIC, WY&B).

Use S&L structural drawings marked by a)

Bristol (fra=ing plans) .

b) Superimpose added bea= drawings installed by other contractors (HJK, FIC, WY&B).

~

Identify bea=s which may have been installed i

c) '

by HJK on field work orders.

Note: This review is in progress in the Auxiliary Building with elevation 54 6' now completed and elevation 567' in progress.

i

2. Determine areas of structural steel field welds

~

i and identify same.

[ a) Uncover embedments i

{ b) Uncover one end of beam. If bolted,  ::

) assume other and is belted.

d t

c) Search Bristel DDC 's to identify Bristel 7

field welds.

d) Mark. drawings to identify locations of structu:f al steel field welds, e) Determine requirements for acceptable welds.

I Note: Identification of structural steel field welds is in progress on elevation 546' cf k

the Reactor Building.

3. Remove paint' or other material frc= the welds ,

that may preclude preper veld inspectic:t.

4.

Conduct a 100% visual inspection of Bristel

> structural steel field welds.

5. Conduct a visual inspection of other vender structural steel field welds and Bristol shop i .

welds using a 954 confidence factor that 84% of the sample is acceptable. This progra= would have the following sample and defect criteria:

I Sample Size Maximum Number of Defects 19 0 30' 1

! 39 2 48 3

! 57 4 -

66 5 If more defects are found, further inspection of

~

random samples wil1 be done.

6. Write Nonconformance Repcrts on all unacceptable i-welds and dispositics as " rework".

I i

l l

l .

t

9 e

. 7. A review of Bristol racerds, procedures, and documentation has been cend ted to deter =ine the types of welding procedures used on the job, speciaL requirements called out in these procedures, and types of weld rod specified fer field welding. A further review of Bristel weld red material receiving reports and weld rod issue slips will be conducted to determine the type of weld rod actually used.

e

• e o e e

4 4

e e

4 4

e e

4

, . . - . . - - - - , - - - . - - , -- w -- enc-,- e

9

. 1 Inspectics Repcrt 62 l concern .

.. The QA Program required only inspecticn by a non QC person.

Discussion Due to the uniqueness of.the contractual relationship between Bristol and E.J. Kaiser and the limited scope of the work, we believe that this is an isolated incident. However, as part of the QCP, we will investigate work done by other subcontractors who were on site at the same time as Bristol.

As a result of a review of the Bristol shop QA progra= and documentation, we believe that the shop QA Program was adequate.

QCP Action See Inspection Report Item i1.

O S

e e

9

.n- - . - - --. , . - - s -

l

.. . l INSPECTION RIPCRT t3a & b: MATERIA! TRACIA3 CITY - BI.AMS IN RIAC CR i AND AUX LIARY 3CII.OING

~:

CONCERN: Several hundred feet of bea=s have been received from an unapproved ve= dor, and cannot be accoun ed  !

i

. for as to where installed or other disposition.

DISCUSSION: E. J. Kaiser purchased W8X17 bea=s f cm a ncn-f approved vendor. These bea=s were placed in essential

~

steel stock on the basis that they were supplied with valid mill certificates by the vendor at ti=e of purchase.

i QCP ACTION: 1. Conduct an audit of all steel received on site

, and determine the supplier.

2. Conduct a random audit of o-Jier essential =aterial .

is piping, weld rod, fittings, cable, etc, and

. determine the suppliers of such material.

l '3. Verify that the supplier of this material is an

{ EJK or CG&E approved vendcr. ,

4. CG&E/RJK Q.A. will perform a vendor survey in j

i i

accordance with approved procedures to verify

the credibility of the mill certifications and the vendor performance to their Q.A. manual.

t i 5. If the vendor is found to be unacceptable, then

the manuf acturer of the beams will be surveyed.

4. If all surveys are unacceptable, a pregram will be initiated to identify those beams which were i

supplied by an unapproved vender.

1 '

4

^

1 i

I

7. If these atta= pts are unsatisfactcry, a rande=

-- i 3

4 sampling of beam =aterial will be made to insure i that mat 6 rial .

meets the required chemical and physical certifications.

8. A program will be established to determine the cause for release of ,"non-approved vender" material to determine if the problem is sy=pto-I matic. .

1 l

~

I .

i .

i i e 1

9

! e 1

i 1 .

4 e-l

~

i INSPECTION REPORT #3e & d - LACK OF TRACEASILITY OF MATERIALS Problem Traceability of heat numoers on small bore piping for the Diesel Genera tors.

Ko records exist to show that some of the installed pipe is ac-ceptable. The heat numbers do not appear on the H.J. Kaiser list of acceptable heat numbers.

i Discussion A review of the documentation of the small bort piping in the diesel generator system followed by a walk down of the piping revealed i

some lack of traceability in accordance with ASME Code requirements.

i An inspection program will be implemented to correct this situation, Small bore piping on other systems will also be included in the pro-gram as well as some large bore piping.

OC7 Action i

1. Conduct an inspection of 100% of the accessible field installed small bore piping on the diesel generators for traceability in accordance with ASME Code requjre-

, ments.

2. Conduct an inspection of 100% of the accessible field in-stalled small bore piping on the High Pressure Core Soray, Low Pressure Core Spray, and Low Pressure Coolant Injection i

systems for traceability in accordance with ASME Code re-quirements.

3. Selectively compare the Control Rod Drive System documenta- i i

i tion against accessible field installed small bore piping for i

• traceability in accordance with ASME Code requirements to i

. achieve a 95/95 confidence level.

4. If a 95/95 confidence level is found for steo 2 and stes 3 no further inspections are required. If a 95/95 confidence level is not achieved, a further review will be initiated  ;

of other accessible field installed small bore piping to achieve a 95/95 confidence level.  !

5. A discovery audit will be performed on large bore pipe for traceability in accordance with ASME Code requirements.

This audit will consist of a review and inspection of 6 DOC's on the Safety Relief Valve Discharge Lines and 6 DOC's on the Reactor Building Closed Cooling Water System.

6. Take appropriate corrective action for any deficiencies 3 found.

e e

, . - - - ~ ,. -.

~ . , . - - , . . , . . . , , , - - - - - . . - - - .,---n, , . . - . . - , .-.- ,. - , . _

b INSFECTION REFCRT #3e - LACK OF MATERIAL TFACEABILITY Concern: Weld red heat numbers are being transfered :: the KE-1 weld for fr = the KE-2 fr = ty individuals cther than the 00

'I Inspector who ins;ected the weld. -

Discussien: .

At the present time the quality documents are under the care, custody, and contml of C.G.1 E. H. J. Kaiser has been ordered to stop the transfer of information between the KE-1 and KE-2 for s.

OCP Action

1. Weld filler material verification will be made a held peint

2. The number of welds will be deter =ined for which KE-1 f:r:s

. do net have heat nu-sers pre;erly enteret.

3. Appre:riate c:rrective action will. te taken e

9 O

e n + - - - - . - - -

INSPECTION REPORT #4 - SURVEILLANCE REPORTS NOT SEING CONVERTED TO NONCONFORMANCE 7 REPORTS IN 30 DAYS Concern Surveillance reports not bein~g converted to nonconformance reports in 30 days.

1 Discussion -

This item will be addressed as part of Inunediate Action Letter Item #9.

9 e

9 0

p 4

4

+ > - , . , . - . . ...-.n. , . . , . - . - - , . . , , , . . ., .-. ,

[ . - .

i INSPECTION RI? ORT 4 5 - WEI.D5 INSPECTED AFTIR PAIN ING CONCERN: Structural welds were inspected after painting.

. DISCUSSION: FIC has installed structural beams and cable tray i supports and have used Galvanox and other coatings to prevent the corrosion of the welds. Although no documentation exists that verifies that these welds were inspected at that time, hanger inspection along with its associated structural steel was in-process inspected and all work was assumed to be acceptable by construction unless reported unacceptab'e .

by Quality Control inspectors.

QCP ACTION: 1. Determine those area's where weld inspection has taken place on cable tray and conduit supports and  ;

j . the welds have been accepted.

l NOTE: This portion of the program has been ccm-i plated. The inspection covered under Iten 1 will determine those structural field i welds which were painted prior te inspection. .

2. Conduct a sampling program consisting of a 95%

j confidence factor that 84% of the sample is -

acceptable. This program would have the following i sample and defect criteria:

! SAMPI.E SIZE MAXIMUM NUMBER OF DETECTS 19 0  !

30 1 39 2 '

48 3 57 4 66 5 I

L -

QCP AC !ON: If more defects are found, further inspection (Cont ' d) of random samples will be done.

3. Determine tha weld acceptance criteria per design specifications and approved inspectica r

procedures.

4. Inspect the welds using CG&E inspectors and document inspection reports.

5. All welds that are deemed unacceptable will be documented on a nonconformance report.

6. An evaluation of the sampling program shall be conducted to verify weld acceptability for those welds not inspected.

7. Any coatings found on the welds to be inspected will be removed prior to inspection.

O 4

i I .

S 6

5 4

I i

i i

[

l i

Inspection Report #6 - Unacceotable Technicues for Radiographs of Prefabricated Pioe Welds '

,- Concern Radiographic technique was inadequate on 25t of the prefab welds that the NRC Inspector reviewed. .The penetrameters were not adecuately shimmed. m.

Discussion A sample, covering a variety of pipe sizes and systems, of radiocraons rejected by the NRC Inspector has been identified. The welds identified are being reradiographed reproducing the original shop configuration as near as practicable and adding a second penetrameter shimmed to the thickness of the maximum allowable reinforcement for the pipe. The systems and pipe sizes are listed below:

3" Main Steam ,

4" Fuel Pool Cooling 6" Fuel Pool Cooling 8" Fuel . Pool Cooling 8" Scram Discharge.Volune Header 10" Main Steam 10" Recire.

18" Feedwater

~

20" Recire.

20.4" High Pressure Core Spray 23.8" Feedwater  ;

Field welds as well as shop welds will be raradiocraphed.

In addition, Pullman Power Products has radiographed a series of test coupons using no shim and a shim equal to the maximum allowable rein-forcement and several shims of intennediate thickness. The radiographs were taken on 4", 8"> and 16" pipe.

Preliminary results from both programs indicates that the original radiographs meeting the -15t/+30% density requirements are adecuate to evaluate weld quality.

2

'I t

, - , _ - - - . - - . - .-.7, - - . . . , , , . _ . _ - .

. , , , . . _ , . , , ,__m,s , -

QCP Action 1

=

1. Reradiograoh a reeresentative sample of radiograohs rejected by Mr. K. Ward (NRC) recroducing, as nearly possible, the shoe set up and also shiming a second penetrameter to the thickness of the maximum allowable reinfor:;ement for the weld to demonstrate that the radiographs rejected for technicue meetino the -15%/

+30% density requirements are adecuate to evaluate weld quality.

2. Verify to a 95/95 confidence level tnat the Pullman Power Products shop radiographs fall within the -15%+30% density requirements.

3. For those radiographs sampled that do not meet the density recuire-ments, the welds will be raradiographed with the penetrameter shirened to at least the thickness of the weld.

4 A sample of shop welds welded by vendors other than Pullman Power Products will be reviewed against the density criteria.

S. A sammle of field welds will be reviewed against the density criteria.

1 e

1 O

G e

6 e

.i

INSPECTION REPORT #7 - NONCONFOR.VNCES ARE BEING VOIDED IMPROPERLY 3 Concern Nonconfonnances am being voided improperly.

Discussion This item will be addressed as part of Immediate Action Letter Item #9. -

l f

i l

i l

l e

e l

l l

l

. INSPICTICN RIPCRT $ 8 : DESIGN V!OLATICU CONTRARY TO TSAR -  !

CA3LI SEPARATION '

CONCIRS: A 6 in. green cable tray was designed and installed

- inside a whita tray. The green tray includes green i

class II cables and the white tray contains blue / white a

l and yellow / white associated cables.

DISCUSSION: The original FSAR criteria did not stipulate separation requirements from an essential cable tray te a non-essential tray. The FSAR criteria is being clarified for separation of essantial, associated and

] non-essential cable in both cable trays and ccnduits.

! QCP ACTION: 1. Using the clarified separation criteria, CG&I will i j conduct a 10% discovery audit of associated cables will be performed. This audit will be expanded,

+

! if necessary, to arrive at a 954 confidence level l . .

j that 95% of associated and non-essantial cables are properly separated in trays and conduits.

{ 2. A'100% audit for separation will be ccnducted  :

of essential, associated, and non-essential cables i

i which are installed between the cable spreading I room and the control panels in the main control rec =.  !

3. Sargent and Lundy will perform a 100% computer i assisted analysis of associated cables to demonstrate '

that the reliability of Class LE circuits is at i acceptable levels considering the separation criteria, f

4. The green cable tray identified under ' concern" will i

be ramoved and reinstalled in accordance with FSAR l criteria.

9

INSPECTION RERPORT #8 (cent'd) 4 CG&E is prepared to conduct a technical discussien 1

i relative to associated cables as applied to the 21sumer Project with the NRC at their convenience.

e D

i .

t i

l l

} e e

0 e

e i

i A

k i

I I

b I

I l

I .

t l

., l

• INSPECTION R$hCR; #9:

LACK OF INSPECTION CCNTROL TO VERITY

~

CABLE SEPARACICS 1 l

In response to the concerns identified in Inspection Report Items 9a through 9d, CG&E has reviewed the Quality Assurance procedure governing the inspection of cable pulling (QACMI-E7) .

, This procedure has been revised in accordance with the results of the review. ' he T revision to the procedure incorporates a =ethod of verifying that 'non-safety related cables are installed in accordance with the design documents. The QC inspectors are being

• retrained in accordance with the revised procedure.

The following responses are made to each cf the specific items $d concern identified:

9a. .

CONCERU: From the end of tray points up to the control panels, two blue cables in the Cable Spreading Roo= have been pulled. into a green tray seculen leading up to the l Control Room.

i; -

DISCUSSION: CG&E investigation of this problem revealed that the blue cables were not pulled into the green tray sectien; however, the blue cables were too close and incorrectly bundled together with the green cables when the green cables were installed in a riser.

OCD ACTION: The corrective action is to remove the blue cables frc=

the green bundle and relocate for proper separation.

9b.

CONC 5RN: Yellow / white cable coming out of conduit and suspended approximately 6 in. above the cables in the blue tray (in the Cable Spreading Room).

V i

INSPICTION RI?CRT A9: I.ACK CF INSPIC* ION CONTROL 70 VIRm CA3LI SIPARACICN (cent'd)

~

DISCUSSION: If the conduit, containing the yellew/ white cables were extended to the wall penetration, ne separation deviatien would exist.

CCP ACTION: The corrective action is to extend the conduit containing the yellow / white cable to the wall penetration.

9c.

CONCIRN: In the Instrement and Relay Recm, a non-safety related white cable, Nc. DC258 (also labeled DC257) has been misrouted into a yellow tray No. 10403.

DISCUSSION: The unte. inated white cable was incorrectly installed in the yellow tray.

QCP ACTION: The corrective action is to rer.ove cable No. DC253 from the yellow tray, and install it in a white tray.

9d.

CONCIPN: Tray loading and cable separation concerns.

DISCUSSION: Cable tray loading is addressed in the response to inspection report #10. Cable separation concerns are addressed in the response to inspection report AS.

l 2

. l Inspection Recort #10 - S&L Cable Tray Leading Design Control T Concern Lack of controls to requira design verificatien calculations to be perfomed for themal loading of power sleeves and dead weight loading of all trays'.- i i

Lack of controls for deviations from the FSAR. S&L did deviate from the tray loading design basis.

Lack of internal controls to document design deviations when identified by engineers.

~ Discussion This item is being addressed as part of Imediate Action Letter Item # 6.

l .

I .

G e

e au - t- - - - - ,

=,

ye--' -'

y

Inspection Report #11 - Lack of CG3E Fellcw-up en Repetitive Preblems Ccncern Inadequate corrective action taken by CG&E in regards to repetitive problems concerning design calculations and verifications not beine performed by S&L. The problems were identified in 5 different CG&I audits. ,

The R-III Inspector identified the lack of requirements to perfom design calculations for tray leading during the investigatien.

Discussion This item is being addressed as part of Inrnediate Action Letter Item 810. e e

8 . g e

e 9

e

• , - . 4 - w ~q

4 Inspection Report *12 - Audit of S&L Nonconfomance Program Concern

~

CG&E has not perfomed any audits to verify compliance with and the effectiveness of the S&L nonconfomance program.

Discussion This item is being addressed as part of Inmediate Action Letter Item #10. -

O e

e 9

• e e

a j .

O g 9

l i

i INEPECTION REPORT $13 - DEI.ETID ~ OESITi CRITI?lA CONCIRN: Weld inspection criteria has been deleted frc=

.: the KI-1 fo= f cm 7-8 0 81.

DISCUSSICti: Weld inspection criteria has been deleted frc= the KI-l fo= for AWS. structural welding on the drywell

, steel, and other instructions added as follows:

Deleted: Item 1 on KI-1 fo= in its entirety Added: Item 1 on.KI-1 fe= " Rod slip (II-2 fc=)

to be part of package" Itam 2 on KI-1 for= except for " Verify Deleted:

Mark Numbers

• Unless the welds are full penetratien welds, this criteria need not be hold points; however, p:cper weld procedure, welders g:alification and p cpet

.. filler metal verification must be conducted prio to weld ' acceptance. (See KI-2 form)

QCP ACT!CN: 1. Ideitify dates for which criteria was deleted i

on KI-1 fees for AWS structural steel field welds.

i

2. Conduct a 100% audit of II-1 forms on structural steel field welds for the time frame established.

3. Document all full penetration structural field welds during the time frame ~and dete =ine if an'y hold points were violated.

4. Any welds so found will be documented on a i

Nonconformance Report, properly dispositioned and corrected.

5. The procedures governing the use of KI-1 fe=t will be revised to designate Item #1 on the KZ-1 form as a witness point, rather than being shewn '

. . _ ,as *N/A" asLin_the

d

. INSPICTICN REPORT 414 - NCNVERI?!IO SCCT.IT-WI'.D FIT-CPS CONCIRN: Socket weld fit-up has not been verified on i

numerous small bore pipes.

DISCUSSION: According to EJK Procedure SPPM 4.6 and the KI-l form used for the inspection of small bore piping, the fit-up of socket weld joints is res ired. ASMI Section N34427-1 requires that approxi=ately a 1/16" disengagement be met on socket velds. Numerous socket welds have been made without the p =per I

documentaticm witnessing the proper visual inspection of pipe fit-up as documer.ted on several surveillance reports. '

QCP ACTION: 1. Datezzine all small bore piping socket welds I

, for which verification for disengagement does not exist as documented on surveillance reports.

NO2: This program so far has identified 104 socket welds for which verification for disengage =ent does not exist. A sampling of these welds is j ,

presently being identified for radiography, with emphasis being placed on those in ICCS systems and in systems which are unisolable from the reactor. It is being found that some of these socket welds have been cut-out and i replaced as a result of piping modifications.

l 2. Document these welds on a Nonconformance Raport.

2:SPICTICN RIPOPO 414 (cent'd) i .

~

3. Dispositics the Nenconfor=ance Repc t such that a randc= sa=pling prcgra= is initiated to radiograph" these welds which will give a ~

95% confider. e factor that 95% of the welds are acceptable. This p =gra= would have the following sa=ple and defect criteria:

Sa=gle Size Maxi =u= N"-ker cf Oefects

~

59 0 93 1 124 2 153 3 -

181 4 208 5 A si=ilar progra= for small size lots wculd be as the following table describes:

Lot Size, Maxi =u= N -her 0 1 2 3 4 of Defects l

i 114 46 68 85 98 107

.i i

88 43 63 76 79 42 60 71 Sa==le-Size 1

3,8 3o If more defects are found, further inspection of  :

randc= sa=ples will be done.

4. During the review of the s=all here docu=ent

, packages by CA, any socket velds that de net have decr.=entation of fit-up will be docu=ented en a Nonecnfor=ance Report and a radiograph taken to -

dete: .ine if proper disengagement exists. -

_- ,ns:e::1:n .se: r i i..

n:

This it s has been deleted. '

9 9

e S

O e

9 9

O e

m

9 e -

.. Inspection Report #15 - Deviations from Codes and FSAR Concern .

The KE-2 (-Rod Issue Slip) is being'used as justification for OC inspection and verifications. The KE-2 is not a QC document and neither requires nor has QC . signatures.

Discussion This item will be addressed as part of Immediate Action Letter Item 88.

e e

i e

e

Id s .

f s INSPECTION RI?CRT &17 - t.*NCONTROLLID DESIGN CCCCIGNT CEMGES

,CCNCERN: The KII Configuration Control Center does not know the I status of DCCs written prior to late 1950. . . .When a DDC is written against ene docu=ent and subsecuent changes are made"to one or more other documents (drawing:

not referenced by the original DDC.

DISCUSSION: In accordance with Sargent and Lundy project instructicn PI-ZI-2.1, the designer is responsible for ensuring that all documents that require a revisien by a DDC are in fact, revised even though all affected drawings are not stated on the DCC. For the past year, CG&I a f i-

• S&L have been in a mode of resolving all DDC's which still appear open in the Configuration Control Center master DDC index.

i QCP ACTION: 1. Sargent and Lundy has revised their project instruction PI-ZI-2.1 requiring a cover sheet be attached to all DDC's returned to the HJK Configura:i Control Center.which would indicate all drawings

. affected by the DDC. This will permit the CCC to close out the DDC when all affected drawings are revised and issued. '

2. Sargent & Lundy has also added to their project I instruction the requirement for incorporating DCC's l

l into the next revision of the applicable engineering l l

design documents or within two months, whichever is less.

l l

1

-- - - .,----a,-.- -

2 e 'd ,'

. .e .'. -

e .

INS?ICTION PIPORT #17 - CNCONTRODLID DESIGN DOCUFINT CEANGIS (cont'd)

3. CG&E presently has nine persens working on reconciling our DDC cc=puter listing with that of Sargent and Lundy. This list, when finali:ed, will include the status of every DCC as to whether it is incorporated into the design docu=ents. It is anticipated this effort can be ccepleted in 2 or 3 months. CG&E has ordered an additional keypunch 4

machine, which will speed-up input into the ec=puter program, and certain persennel are werking overtime and en Saturdays on this effert.

4. The question raised earlier'hy Mr. Gwynn cencerning i

DDC's originating frem Waldinger-Young & 3ertka in 4

.the field referencing only one drawing, while more i than a single drawing might actually be affected 1

4 has subsequently been listed as a viciatien by Region III.

(50-358/31-07-07). A complete and thorough respense is being prepared on this item in addressing IE Inspection Report 81-07.

5. The check which exists to assure that DCC's are i

built into the plant is at time of system walkd5wn for Electrical, Mechanical and C&I DDC's, prior

. to rystem turnover.

Structural DDC's, not nor= ally

identified with a particular system are checked during a walkdown of the structure prior to area l

structural turnovers. Thismethodcoupledwit.k the computer listing provides sufficient centrol te assure i=plementation c'f DCC's.

. .- .. . _ . -- - . - -. -.