IR 05000358/1982010

Applicant Exhibit A-49,consisting of 830325 Ltr Forwarding Partially Withheld Safety Insp Rept 50-358/82-10 on 820607- 0818 (Ref 10CFR2.790) & Notice of Violation

ML20214E823
Person / Time
Site:	Braidwood, Zimmer
Issue date:	06/24/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
References
OL-A-049, OL-A-49, NUDOCS 8705220268
Download: ML20214E823 (26)

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UNITED STATES ,;

, ! , g NUCLEAR REGULATORY COMMISSION ..

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, RECEIVED

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.g APR 13 P4:50 Docket No. 50-358 emummmusum 00UhENT RQQH Cincinnati Gas and Electric Company '

ATTN: Mr. Earl A. Borgmann Senior Vice President e,s, 2 Engineering Services and E" (d

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Elactric Production

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139 East Ath Street - '

~ g "r Cincinnati, CH 45201  : u TC

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m Gentlemen: T This refers to the routine safety inspection conducted by Messrs. 2:

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V. F. Christianson, T. P. Gwynn, K. D. Ward, D. E. Keating, and J. F. SchYpker

of this office on June 7 through August 18, 1982, of activities at Vm. H. Zimmer *

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i Nu' clear Power Station authorized by NRC Construction Fermit No. CPPF-88 and to

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the discussion of our findings with Mr. J. R. Schott and others at the conclusion of the inspection. The inspection findings were discussed with you by telephone on March 15, 198 The enclosed copy of our inspection report identifies areas examined during i the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-tarviews with persenne During this inspection, certain of ycur activities appeared to be in ::en-cc=pliance with N'RC requirements, as specified in the enclosed Appendi A written response is required.

i - The findings associated with maintenance of active welder qualifications

! indicated a breakdown in your established manager.ent controls in this area.

i This breakdevn was emphasized by the inappropriate renewal of a welder qual-ification card by a responsible staff member and the failure to take adequate i

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corrective actio s even after significant conditions adverse to quality had been identified within the established corrective action system. Furthermore,

- tha inspection revealed that quality assurance records had been altered and supplemented without adequate management controls established. This finding is similar to an item of noncompliance, identified in Investigation Report No. 50-358/81-13, for which CG~zE paid a civil penalty. These findings are

- indicative of a continuing lack of full , understanding of quality assurance requirement Additionally, the failure to adequately control weld filler metal in the test

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shop, to adequately review and control Requests for Information and Evaluation (RFI/E) made in good faith by quality personnel, and to fully impose reporting

! requirements on contractors further emphasize the need for proept management attention to the overall quality assurance program at Zimmer.

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These findings are considered to be significant and are included in the problems documented in Section II.B of the Commission's November 12, 1982 Order

' to Show Cause and Order Immediately Suspending Construction. The findings "

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resulted, at least in part, in the Commission issuing that Order; therefore, a

. civil penalty is not being imposed for the Severity Level III violatio In addition to the requirements of the Appendix, please review each finding in detail, review any previous similar findings, and provide assurance that cor-rective actions taken (or proposed) are adequate to remedy the root or generic cause of the problem In accordance with 10 CTR 2.790(a), a copy of this letter and the enclosure (s)

will be placed in the SRC Public Document Room unless you netify this office, by telephene, within ten days of the date of this letter and submit written applicatien to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s),

and your response to this letter will be placed in the Public Document Room.

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The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, FL 96-511.

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, Cincinnati Gas and Electric 3 U.af. 2 5 ;33'

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We will gladly discuss any questions you have concerning this inspectio

Sincerely, Orl;!.111 "c'cned h*/

Jar:: ;...:.;;st

, James G. Keppler

, Regional Administrator G

Enclosures:

1. Appendix A, Notice of Violation

. Inspection Report No. 50-358/82-10(OSC)

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REGION III

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Report No. 50-358/82-10(OSC)

Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street N Cincinnati, CH 43201

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Facility Name: Va. H. Zimmer Nuclear' Power Station

Inspection At: Wm. H. Zimmer Site, Moscow, OH

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Inspection Conducted: June 7 through August 18, 1982 Inspectors: o&

W. F. Christianso +n gi, b .

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Dated c8

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T. P. Gwynn Dated

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J.KC:s F. Schapker

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'Il/#, /) t Dated hA 7$..L K. D. Ward 8 3

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Dated AYiMl~m *uW ~

t 7kD.E.Keating '

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Dated b

Approved By: . H6t'er, G #

Section 1, Zimmer Dated

Inspection Summary Inseection during the eeriod of June 7 through Autust 18, 1982 (Recort No. 50-358/82-10(OSC))

Areas Inspected:

Routine inspection by resident and regional personnel of previously identified items, the processing of H. J. Kaiser requests for information, fuel receipt and storage, the Quality Confirmation Program, review of welder qualification, site activities of interest, plant tours, construction deficiency reports, preservice inspection program, and structural steel expansion bolting. This inspection involved a total of

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9304070332 930325 PCR ADCCk 030003SR O S0003c ~*

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. DETAILS I'

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Prepared By: W. F. Christianson T. P. Gwynn *

J. F. Schapker Reviewed By: D. R. Hunter, Chief Section 1, Zimmer

, Personnel Contacted

cincinnati Gas and Electric company .

E. A. Borgaann, Sr. Vice President

+B. R. Sylvia, Vice President for Nuclear Operations *

• • +H. R. Sager, Manager, Quality Assurance Department

• +B. K. Culver, Manager, Generation Construction Department

• J. R. Schott, Manager, Nuclear Production Departmen +D. J. Schulte, Director, Quality Engineering

+J. F. Shaffer, Director, Quality Confirmation

'+G. Padula, Quality Confirmation Prograa

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'M. Rhodes, Quality Confirmation Prograa "

'+J. Louden, Quality Engineering G. Orlov, Quality Engineering

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+ Spence, Director, Quality Documentation F. Pfeifer, Quality Engineering R. Vannier, Quality Engineering a' Henry J. Kaiser comoany

• • +M. Albertin, Construction Project Manager

• • +W. Hed:ik, Manager, Quality Assurance C. Stanfield, Construction Manager

• • +M. Goedecke, Welding Engineering Manager

'+M. Butterworth, Weld Engineer

• +G. Fones, Quality Records Manager

+J. Flaherty Weld Engineer

'N Vitale, Quality Engineering Manager W. Wagner, Welding Task Force Chairman C. Person, Lead Document Reviewer, Welder Qualifications R. Davis, Quality Control Manager National Board of 3 oiler and Pressure Vessel Inspectors (NBBI)

4. Allison, Field Representative, SSSI

+M. Sullivan, NBBI Consultant R. Holt, N33I Consultant Hartford Steam Boiler / Authorized Nuclear Inspector A. Clark, ANI Supervisor '

L. Burton, ANI

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This is in noncompliance with 10 CFR 50, Appendix' B,

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Critetion IX and the Vm. H. Zimmer QA Manual, Paragraph 9.3, which states in part that the CG&E QA Division audits HJK to assure that personnel performing special processes are

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qualified in accordance with applicable code (358/82-10-01(A)). (Closed) Unresolved item (358/82-05-02): H. J. Kaiser had no documentation of the results of evaluations for reportability under 10 CFR 21 and 10 CFR 50.55(e).

CG&E Corrective Action Request No. 82-36 was written to identify and control this problem. As a result, H. J. Kaiser Procedure GQP-21, Revision 0, " Reporting cf 10 CFR 21 or 10 CFR 50.55(e) Conditions" was prepared and approved. Subsequently, Revision 1 to GQP-21 provides that the necessary administrative controls to provide assurance identification, control, and documentation of reportable or

- potentially reportable conditions is achieved and maintained.

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The failure of CG&E to impose the reporting requirements of 10 CFR 21 and 10 CFR 50.55(e) on its contractors is in noncompli-

. ance with 10 CFR 50, Appendix B, Criterion V, 10 CFR 21.21(a),

and the Wm. H. Zimmer QA Manual Paragraph 5.1, which states ia part that activities which affect the quality of the facility are .

accomplished in accordance with written instructions, procedures, or drawings which prescribe acceptable methods of carrying out those activities. (358/82-10-02(A)) Follevup on Processing of H. J. Kaiser Raouests for Information On July 20, 1982, a H. J. Kaiser employee brought to the attention of the NRC a potential problem related to the processing of H. J. Kaiser Request for Information/ Evaluation (RFI/E) forms. In accordance with

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H. J. Kaiser Procedure GQP-9, Revision 0, dated January 27, 1982, Para-graph 4.1.3, RFI/E's which were forwarded to the Welding Task Force were required to be processed as follows:

"The Velding Task Force Chairman will log receipt of the RFI/E by number and date and present the RFI/E to the welding task force membership for response."

The inspector April 13,1982,was presented an information copy of an RFI/E initiated requesting evaluation of a quality-related conditio This RFI/E was issued and responded to by the Valding Task Force (WTF) Chairman; however, GQP- the RFI/E did not have a tracking log identifier as required by Discussion with the H. J. Kaiser quality Engineering Manager and the H. J. Kaiser WTF Chairman revealed that the WTF Chairman did not fully understand of the RFI/E the procedural controls of the RFI/E procedure or the scope procedur The WTF Chairman indicated that his under-standing of the RFI/E was that the RFI/E was to be used for clarification of procedures, codes, and standards only; and he was not required to log RFI/E's which did not represent requests for clarification.

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i QCP Task No. Initial Issue No. Dispositioned Received and Reviewed and Reviewed I

1302 .

II 108 793 III 53 341 IV 100

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VI 311 0 I VII 91 149 IX 290

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. Additional Areas of Interest In addition to the above tasks, there have been nonconformance reports generated by the H. J. Kaiser document review group in the following categories which are being followed by the inspector:

), CATEGORY I

NO. OF KRS RECEIVED Supplier related .

Electrical Equipment Installation 196

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Cadwelding 19 Concrete 14 .

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Hydrostatic Testing 51 Leak Chase Welding 53

Sacrificial Shield Wall Welding

Inspection Stamp Control 2 i 1 The inspectors will continue to monitor the efforts of the H. J. Kaiser document review group and will follow the resolution 1 of these additional areas of interest.

, Quality Confirmation Program Status

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The Ifeensee reported the following status of the quality confirmation program effective June 30, 1982.

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(1) Task I: Structural Steel Items . Items % Comp Comp 1. this Comp 1. to Manhours Area this % Comp Month Date Expended Manhours

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Remsining

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nections 0 259 0 100 0 0 I' Drywell (less 525') 75 236 23 72 , 317 651 Reactor, Aux

& Service Water Bldgs 452 782 '

13 22 2,757 l

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ihis task approximately 31* complet (f) Estimated Completion Date *

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December 1, 1982 (2) Task'II: Veld Quality Items Items * Comp Comp 1. this Manhours Comp 1 to this * Comp ,

Area' Month Expended Manhours Date Month to Date this Month Remainine Struc- .

tural KE-1

, Review 0 11,000 4 98 0

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160 Welding '

Procedure ,

Reviews- 0 76 0 92 0 40 Welder * '

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Qua Review 527 1,303 11 29 102 1,798

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Bore Pipe 368 25,841 1 79 128

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824 Large Bore 0 0* 0 0 0

. 4,118

• Items previously listed as complete for large bore are to be redone under new progra (a) Assessment /Results

, * of the inactive welding procedures have undergone preliminary review. Approximately 5 procedures may need to be requalified on the basis of this revie (Amperage range exceeded, interpass temperature not specified, rate of travel not recorded, etc.)

I Review of welder qualification has begun. A group of i~ HJK and COSE experts are working jointly to expedite the review (9 people). There are approximately 1800 welders (approx. 4600 records) to review. 341 NRs have been initiated, of which 11 have been dispositioned (7 accept-as-is, 4 rework). 1323 welder qualification forms (for 541 welders) have been reviewed to dat .

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• Purchase Order Review:

6,792 Purchase Orders were initially reviewed Of these approximately to determine 4,700their were status determined (essential essential.orThe nonessential).

numbers given for this report are from the statistical status plan which is in progress at this tim .

• • The are asreasons follows: for the change in status of the Seall Bore Piping The original procedure used for the review was not

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and used assumptions; our review was performed prior to the HJKin depth enou review during which they were, by procedure, able to salve many NRs; and a method to tie the purchase order heat number to the documentation establishe and field heat number had not been satisfactorily deficiencies. A new procedure has been submitted to rectify these

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• • • Hours expended for information walkdown.

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(a) Summary of Scope (IIIA) Small Bore Piping - Perform 100% inspection (Documentation and Field) of systems identified *

on Encidsure 1 and 2 of NRC investigation Report No. 50-358/81-13 Exhibit 17. for traceability in accordance with ASME requirement (IIIB) Large Bore Piping - Perform 100% inspection (Documentation and Field) of all piping involved in field modifications within the scope of Enclosure 1 and 2 (see IIIA above) for trace-ability in accordance with ASME requirement (IIIC)

Purchase Order Review - Per' form 100% review of Purchase Orders to establish a list of acceptable heat numbers to confirm source traceability of all code related items within the scope of IIIA and III (b) Assessment /Results (IIIA) Small Bore Piping - Field Walkdown is 98% complet Document review in accordance with 19-QA-12 is 88%,

however, all packages within the scope will be re-reviewed in accordance with 19-QA-30. This is necessary since 19-QA-12 did not address trace-ability in the depth required to adequately identify the problems encountered. In addition, the documents will be reviewed after HJK, to allow nonconformances to be identified on HJK NRs (They will be designated as "Q" NRs).

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i (a) Assessment /Results i

' , I' . Records for 29,821 have been reviewed. We are

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re-reviewing those ISK Drawings which were on hold .

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pending receipt of additional documentation. 1623 welds pending direction for closure or additional revie .

I welds lacked evidence of disengagement and have been radiographe .

• III. 106 of the 565 welds appear to lack gement from radiograph fevie .

(b) Nonconformance Report Summary

' 106 Nonconformance Reports have been generated for the 85 welds lacking proper disengagement. 72 of the 106 NRs have been dispositioned rewor .

(c) Manpower Summary

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Position Number

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. Quality Engineers i Inspectors 0 e

Document Reviewer 0 Clerks 0 TOTAL ~l (d) Status This task is approximately 98* complet (e) Estimated Completion Date .

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August 1, 1982 (5) Task Vr Radioaraohs Itama Items * Comp Manhours Coop 1 this Comp 1. to this *

. Comp Expended Manhours Area Month Date Month to Date this Month Remainina Radio-graphy Review --- --- ---

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graphs Phase II *0 31 0 51 0 200

• Awaiting the RT of remaining welds before work can continu .

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, * Expanded scope of Task V **Manh'ours required to close inspection forms, this includes EER's, panel analysis, routing analysis and NR revie +

• • • Manhours required for preliminary work packages for this ite (a) Assessment /Re=ults

. A total of 497 Nonconformance Reports have been written for separation, identification and routing deficiencie dispositioned )Rs (99 rework,158 accept-as-is).

181'of the 257 dispositioned NRs have been close I Task VI expanded to inspect all Class IE Panels with potential separation problems. Procedure 19-QA-31 i being prepared to perform this inspection. Procedure sent out for review and commen III. Awaiting 11 EER responses to close out associated cable inspection records. Responses were due June 15, 198 .

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g Awaiting S&L panel lysis to close out associated cable inspection record .

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., (b) Manpower Summary Position Number

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Engineers

Quality Engineers -

Inspectors &

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Clerks 0 TOTAL 7 (c) Status

$4% complete (expanded scope)

(d) Estimated Comolecion Date December 31, 1982 (expanded scope)

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. ,- Task VII personnel to interface with the N-5 prograa data report program for turnove ,

i in additional manhours for this task.This will result (b) Nonconformance Report Summary .

38voided of Nonconformance NR Reports have been written due to reop

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(Accept -as-is ) . Only one has been dispositioned to date (c) Manpower Summary

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Position Numb3 r Engineers Quality Engineers 0 Inspectors 2

Document Reviewers 0 Clerks '

TOTAL 0

(d) Status,

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This task is approximately 61% complet (e) Estimated Comotetton Date December 31, 1982 (8) Task VIII:

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Desian Control and Verification

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(a) _ Steps to close out this task:

, . Review 81-13 information Review S&L response and procedure revisions

• 4 Formulate close-out of QCP action items

. Review plan and documentation at S&L Present submittal draft close out report to NRC prior to formal NRC to complete review of items and complete closecut (b) Conclusion .

Their systes has been made more formal.No problems (c) Maneewer Sammary Final re Program. port to be written by Director, Quality Confirmation

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. PROBIE.M/ DEFICIENCY EI.ECT MECH STRUCT

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, Missing Documentation 82 8 103

193

. DDC Mis-Classification 8 3

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, Inspection Program Deficiencies and Mis *

4 DDC Not Incorporated in Documentation 84 10 222 316 1-

• Inspection Prior to DDC .

Being Written ("As Built") 1 10 0 11 -

' Incomplete Inspe : tion Documentation

. TOTAL 196

56 0 E J 369 621

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Note: Reduction of probless/ deficiencies previously .

identified are due to implementation of *

MCAR 82-01 and new sources of documentatio .

<' (b) Manpower Summary

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Position Number 3' Engineers 5

Quality Engineers 0 Inspectors

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This task is approximately 34% complete for Subtask I and II.

(d) Estimated Comotetton Date December 31, 1982

(10) Task X: Subcontractor QA Proarass (a) Summary of Concerns i

The Bristol Project Superintendent was responsible for both the steel erection and the erection quality

contro The Bristol Field Inspection Program failed to document i

I specific welds inspected and details of the inspectio i

} 3 Review past audits of subcontractor QA program ,

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(b) Assessment /Results

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296 audits have been identified, of which 207 have been reviewe .

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1 Preliminary evaluation indicates that most audits were of limited scope, however collectively due to

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1 the large number of audits performed, the applicable 18 criteria were covered for HJK, EOTD, NED, GCD, and <

NPD.

There were areas not covered in audits of S&I.

, and G.E. subsequent to April 8, 1981, however, current

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audits of S&L and G.E. have covered the majority of

. applicable criteri :

I- III. Proce bre for interface with the QCP Tasks to verify adequacy of work is being developed. Draft of this *

procedure will be complete and ready for review the

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week of June 28, 1982.

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I It is estimated that eighty-three (83) aan days will l' be required for review and evaluation.of the remaining?

audits, and for auditing missed criteria.

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This task _is 707, complete

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(d) Estimated Completion Date

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i October 8, 1982

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No items of noncompliance or deviations were noted.

> Welder Qualification Review and Verification - OCP Task II '

The QCP Task II requires in part that the licensee (Cincinnati Gas and

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Electric Co.) verify the qualifications of welders qualified prior to April 8, 1981.

! This task is presently being accomplished by a joint i task group comprised of personnel representing CG&E Quality Assurance Department, H. J. Kaiser Quality Assurance Department, and H. J. Kaiser Welding Department.

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Due to the relatively large number of nonconformance and corrective l action reports being generated by this task group, the NRC requested l that CG&E determine the impact of identified problems on the qualifi-

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. cations of currently active welders and report the results of their i

determination in a meeting held onsite July 9,1982 (attendees at this j

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i meeting are designated by a (+) in Paragraph 1 of this report section). ,

j l- In the July 9 aceting, the licensee reported that a meeting had been

!' held on July 8, 1982, in which all concerned parties (CG&E and HJK QA

! and Construction) had agreed to the resolution of a number of generic I

issues which could affect a large number of active welders. The .

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resolution of these generic issues and the suspension of qualifications

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,- . *(1) No. E-8654 dated June 21, 1982

.*(a) No. E-8657 dated June 22, 1982

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, *(n) No. E-8724 dated June 24, 1982

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, *(o) No. E-8719 dated July 6, 1982

, (5) CG&E Condition Evaluation Request No.82-015 dated April 29, 1982

,( 6) CG&E Field Audit 'Iteport (FAR) No. 126 dated July 8, 1977

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(7) H. J. Kaiser res)onse to FAR No. 126, HJK letter KC-10362-Q

dated August 2, 1977

(8) H. J. Kaiser Memorandue from M. Butterworth to M. Goedecke dated

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July 13,1982 (proposed corrective actions for HJK CARS No. 84, 85, 117, 123, 132) .

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H. J. Kaiser Inter-office Memorandum from M. Butterworth to M.

Goedecke as follows

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Date Subject

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$ (a) 6-30-82 Bend Test Acceptance (CAR 114)

I (b) 7-01-82 Signature Authority (CAR 117)

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(c) 7-01-82 Reader Sheets (CAR 84)

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(d) 7-01-82 Backup Documentation (CAR 85)

• See Paragraph 6.b(8) below.

, , Discuss ion / Observations

(1) In order to verify the adequacy of licensee actions with regards

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to the qualifications of active velders onsite, a random sample l of 10 welders was chosen from the H. J. Kaiser list of active welders dated July 9, 1982. These welders were then reviewed

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with respect to their status in the N. J. Kaiser document review -

welder status summary worksheet including outstanding (open)

nonconformance and corrective action reports. Additional docu-sentation was requested where necessary to verify or support corrective action statement Preliminary results were subsequently discussed with licensee

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and contractor personnel for clarification of the open issues.

l Significant questions remained after these discussions due to

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i inadequate or incomplete answers for five of the welders reviewed, centering around two H. J. Kaiser Corrective Action l Reports (No. 84 and No. 114/123).

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(3)

CG&E = Field Audit Repoct No.126 dated July 6-8, 1977, made the

.'follosing records: observation with respect to welder qualification

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"Although proper certification forms are provided in each welder

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file, there exists no forms for the alternate radiographic method which was utilized for qualifying the welder." ,

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" Discussions with Mr. A. Pallon and Mr. K. Bronder revealed that after the- radiographs of the welder coupons are acc,eptable, and certifications granted, the radiographic documentation is then discarded." ,

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"Even though code and specifications allow the option of retain- *

ing or discarding the actual radiographs of welder qualification, it does not state the documentation of the radiographic tests reflecting the actual results be discarded."

"Therefore, it is suggested that a copy of the acceptable radio-graphic report be attached to the welder certification forms."

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In their response to this audit report, H. J. Kaiser Letter KC-10362-Q stated, " Quality Assurance is presently maintaining

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copies of interpretation reports for welder qualifications. In addition.. Peabody Magnaflux has a complete file of these reports which will be transferred to CG&E at the completion of the job."

' (4)

The inspectors noted that H. J. Kaiser procedures - (SPPM 3.2)

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required that the H. J. Kaiser certification on the Welder Qualification Record Form KE Q-1G be by signature of a H. J. Kaiser Veld /NDE Quality Assurance Enginee H. J. Kaiser CAR No. 117 identified that this procedural requirement was repeatedly violated in that the EE Q-1G forms were Engineers. signed by individuals who could not be verified as QA Those individuals included H. J. Kaiser Assistant welding Senior veld engineers, quality control inspectors, and Project / :

engineer responsible for the work performance.The weld engineers were those directly (5)

H. J. Kaiser CAR No. 85 identified that backup documentation substantiating the welder qualification was missing from several qualification record packages. These backup documents included i KE-1sheets. Weld forms and inprocess welder qualification surveillance data (6)

H. J. Kaiser CAR No. 114/123 identified that bend test informa-tion information with was added on to thethe KE State Q-1G for of Ohio Q-1G form which conflicted Additionally, H. J. Kaiser CARtest band No.information 132 identifiedomitte that several KE Q-1G forms had essential The accompanying State of Ohio Q-1G forms reflected the conditions stated on CAR No.114 (information had been added).

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25 S3004009

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.. that the Project Welding Engineer was responsible for the

' accur,acy and continual and timely updating of the Walder 4 , Qualification Listing. The inspector requested a copy of this listing to verify its accuracy with respe'teto welder LMF, but was told that the subject listing was no longer controlled or *

in use. The inspector further noted that the QAP-10 require-ments were reflected in WCP-2, Paragraph 3.2.1, which did not appear to be implemented. The failure of H. J. Kaiser Welding Engineering to establish and accurately maintain a welder .

. qualification listing commensurate with the requirements of QAP-10 is in noncompliance with 10 CFR 50, Appendix B, Criterion IX, which require in part that special processes,

• including welding, be controlled and accomplished by qualified personne (358/82-10-01(B)). .

(2) Review of the qualification records for welders symbol KGZ, KUE, MBF, KGJ, and KFY indicated that there was a lack of objective evidence that the welders qualification coupon had been radio-

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graphically evaluated and found acceptable by a SNT-TC-1A Level II RT qualified individual. In each case, the H. J. Kaiser document review welder status sheet indicated that CAR No. 84 was open against the individual welder's qualification. Review

.' of the complete log indicated that CAR No. 84 was open agains *

the qualification of approximately 89 welders, some of which had

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multiple procedure qualifications with CAR No. 84 outstanding (approximately 250 procedures).

)

i The proposed corrective action to CAR No. 84 stated, "If there is

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not a Level II signature on the welder qualification record and there is no radiograph reader sheet for that qualification record,

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based on the certification by the H. J. Kaiser Company these records shall'be acceptable. No procedural requirements indicated the retention of the reader sheets prior to February 15, 1982, l also no Level II signature was required on the welder qualifica-L tion record by either procedure or ASME Section IX. All current

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and future welder qualification records shall be accompanied by

,a radiograph reader sheet with a Level II signature." ,

This proposed corrective action, which was agreed to by "all.

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parties",and which was part of the basis for the determination

' of acceptability of current welders qualifications at the July 9, 1982 meeting with the NRC, was not acceptable to the inspectors hased on the observation and discussion in

[

t Paragraphs 6.b(2), (3), (4), (7), (8), (9) and (10) above.

The inspectors stated that there was no apparent reason why the

' radiographic reader sheets were not available, in light of the observations of Paragraph 6.b(3) above. The licensee was unable to provide a satisfactory explanation of the missing documentatio .

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S0004310 l1

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Specifically, the inspectors questioned the acceptability of the statement in the affadavit, "In the case of welder qualification records where as the number of bonds was ,

recorded as (1) root and (1) face was in fact, (1) set of ,

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test specimens constituting (2) face and (2). root bonds...,"

or in other words, one equals tw The inspectors observed that the individual who provided the affidavit was not the person responsible for performing the bend tests' in question, nor was there reasonable assur-

• ance that that individual had observed the band tests in

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questio Further questioning of H. J. Kaiser document review personnel -

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indicated that attempts to establish a trend in this area

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I-(i.e. , a certain individual (s) had made the correlation 1=2 over a specific time frame) had failed. These observations

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left questions concerning the adequacy of corrective action

' provided for CAR No. 123/132, however, time constraints precluded a determination of compliance / noncompliance in t this matter. This item is unresolved pending further review at a subsequent inspection (358/82-10-04). .

(4) One welder (symbol KGJ) was listed on the H. J. Kaiser document review status worksheet as having a current qualification to

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weld procedure Specification 3.1.21, however, the H. J. Kaiser E

list of active welders dated July 9, 1982, showed current qualification to Specification 3.1.21 H (where th's H designates a heavy wall thickness qualification). Review of the welders

qualification records indicated that the KE Q-1G (record) form i

' and the Ohio Q-1G form indicated the welder had qualified with a 6" schedule 40 (.432 inch thick) coupon. The Ohio Q-1G form only had subsequently been changed (by line through) to indicate qualification on a 5" schedule 160 (.750 inch thick) coupo The change had not been made in accordance with the requirements

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of ANSI N45.2.9-1974, Paragraph 3.2.6. For clarification, the

inspectors requested that the licensee determine (1) if other I welders qualified to the same procedure in the same time frame 3 had performed their qualification on a 5" schedule 160 coupon, and (2) if the 6" schedule 40 coupons were available in the test shop at the time the qualification in question took place.

j , The licensee's contractor representative reported that (1) review l of welders qualifying to Specification 3.1.21 H in the same time L

frame revealed records that had been altered similar to the records in question, ar.d that (2) the 6" schedule 40 coupons were available in the test shop at the time the qualification in question took place.

1

! The inspectors stated that the objective evidence in this case

indicated that a 6" schedule 40 coupon,was used in the qualifica-

tion, and that the alteration of the documentation outside the requirements of ANSI N45.2.9-1974 placed the welders qualification to the heavy wall procedure in doubt.- The evidence of at least

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S0004011

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(b) As attested to by W. O. Puckett, the foll,owing persons shall

,be considered as acceptable. At the time of delegation of

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signature authority W. O. Puckett held the position of Project Weld Enginee x

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1 Mark stacy (Assistant Engineer)

2 Mark Johnson (Assistant Engineer)

Both persons were under direct supervision of W. O. Puckett at the time of certification."

'The inspectors observed that the person referenced in Para- *

graph 6.c(5)a above was the site Weld /NDE QA Engineer, a sworn statement attesting to his delegation of signature authority -

(but not responsibility for review of the activities in question) may be acceptable. However, the inspectors further observed that the person referenced in Paragraph 6.c(5)b above was never employed in the position of site Weld /NDE QA Enginee In fact, the person referenced in Paragraph 6.c(5)b above was the person directly responsible for the implementation of site welding activities and did not posses the independence inherent .

in the position of Weld /NDE QA Engineer. As such, the accept- -

ability of this corrective action statement requires further ,

justification and remains unresolved pending the review and

' verification of corrective action by the licensee's QA organizatio (358/82-10-06) Position Taken

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As a result of this review of welder qualification records, the following held July position was taken by the NRC during a licensee meeting 15,1982 (personnel attending this meeting are designated with an (*) in Paragraph 1 of this report section):

i (1) Those KE Q-1G forms that are properly filled out in accordance with the requirements of the ASME Code,Section IX, and that i include objective evidence that a SNT-TC-1A Level II RT

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qualified person evaluated the radiographic test results (when

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the alternate radiographic qualification method was employed)

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and found them acceptable, are acceptable to the NRC as l

objective evidence of satisfactory qualification when the l

essential variables of the qualification (including the date

'of qualification) have not been altered, or when alterations have been made in accordance with ANSI N45.2.9-1974 requirement (2) For those KE Q-1G forms which do not include the signature of a SKT-TC 1A Level II RT qualified person (when the alternate radiographic qualification method was employed) showing l- evidence of acceptable RT results, an appropriately signed backup document (i.e. , RT reader sheet showing acceptable RT results) will be acceptable to the NRC as objective evidence of satisfactory qualification, provided the other essential items referenced above are me .

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S0004012

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(5) 9% - Incomplete installation (shiss, nuts, and pins missing)

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'(6) 40% - Miscellaneous defects (alignment, curing, spalling,

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, , dimensions,etc.)

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Welding accounted for 40% of the IIDR's ~ as follows:

(1) 19% - Undercut welds j

f (2) :15% - Undersized welds

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(3) 10% - Arc strikes

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(4) 8% - Weld Overlap (3) 7% - Slag

, i (6) 6% - Lack of fusion '

(7) 5% - Weld ositted -

(8) 30% - Miscellaneous defects (spatter, profile, contour, convexity) ,

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Anchor bolts and base plates marking and identification, and base metal and documentation constituted the remainder of the defects.

I Review of the IIDRs and system is an ongoing effor .U.S. Department of Labor - Vane and Hour Division

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The Senior Resident Inspector set with two representatives of the Division of I. abor to discuss the' nature of concerns filed by a HJK esployee. The employee lodged written concerns with the US NRC, .

! GAP and the Wage and Hour Division concerning intimidation. The

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employee's concerns are part of an ongoing investigatio *

{_ Plant Tours

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The inspectors conducted frequent plant tours throughout the inspection

, period. These tours included observation of ongoing construction acti-i vities, maintenance activities, equipment controls, cleanliness controls,

<

instrumentation, fire equipment, and security controls.

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During a tour of the weld test shop, the inspector observed that the i

' issuance of weld filler material was not handled in accordance with the site Procedure WCP-3, Revision 0, " Weld Filler Metal Control," dated l February 17, 1982. In particular, the materials were issued by weight, i

i returned by weight, and no stub count was accomplished upon return.

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The inspector verified that WCP-2 revision 0, " Welding Performance i Qualification Testing" dated February 15, 1982 Paragraph 4.1.2, required j that weld filler metal be " completely accounted of'r and fully traceable

! from the time of aquisitica through use or other disposition

! (Reference 2.4, WCP-3, Weld Filler Metal Control)." '

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33 S0004313

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Prepared By: K.'D. Ward Reviewed By: D. H. Danielson, Ch,ief -

Materials Processes Section Inspection period August 16, 17 and 18, 198 . Persons Contacted ,

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e Cincinnati Gas and Electric Company (CG&E)

f

• H. Sager, QA Manager

• R. Taylor, Quality Engineer

• J. Vannier, NDE Level III (S&L)

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• Gibbons, Engineering Consultants (Reedy, Herbert, Gibbons, and Associates) (RHG&A)

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• P. Herbert, Engineering Consultant (RNG&A)

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C. Allison, Field Representative (National Board)

M. Sullivan, Consultant (National Board) >

R. Holt, Consultant (National Board)

D. Schulte, QA Engineering Director The inspector also contacted and interviewed other licensee and contractor technical and administrative employee *

• Denotes those attending the exit interview on August 18, 193 . Licensee Action on Previously Inspected Findinas (Closed) Open Ites (358/76-05-03): Placement of penetrameters. The inspector has reviewed many radiographs in the last four years and this does not appear to be a problem at this tim . Licensee Action on 10 CTR 50.55(e) Reports - Status (0 pen) 10 CFR 50.55(e) Ites (358/80-08-EE): Radiograph Review - M-22

. Radiographic review rejecting welds, data reported, May 2,198 . CG&E interia letter to Region III dated May 29, 1980. Results of 1565 welds and 840 packages lef t to revie . C&GE second interim letter to Region III, dated July 26, 198 Difficulties with preparing final report because of lack of documented evidence that the personnel performing the review were qualified, lack of a documented program, no evidence that the review of radiographs were in accordance with ASME Section III, 1971 Edition, Summer 1973' Addenda and no evidence that appropriate corrective action has been taken regarding those welds rejected during this revie _

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S0004314

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.. .. . Radiographic deficiencies in sacrificial shield, monorail,

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.and vent stack welds. Date reported May 10, 198 ,

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. CG&E interim letter to Region III dated June 3,1982, a

stating that a complete review of all sacrificial shield -

weld radiographs will be performe '

The review of radiographs has not started to date. The review may be completed by December 31, 1982 and a final report wilk

then be submitted to Region II * (Open) 10 CTR 50.55(e) Itse (358/82-19-EE): Radiographs in As-built Condition - M-50 *

. As-welded conditions may have masked rejectable defect Date reported May 20, 198 'i , . CG&E interim letter to Region III dated July 23, 1982. All piping field weld radiographs will be reviewed for proper

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surface condtio CG&E is in the process of writing a procedure for reviewing the

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radiographs of the welds in the as-welded condition. The review .

may be completed by December 31, 1982 and then a final report will -

be submitted to Region II Preservice Inspection (PSI)

The inspector was informed that no documentation on the monitoring of the PSI by a CG&E qualified NDE person can be found, therefore, PSI may start over again October 1,198 .' Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1 of this report section) on August 18, 1982, and summarized the scope and findings of the inspection activities. The licensee acknowledged the inspector's findings.

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.3=.. .QCP Task I NR Review

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The inspector review revealed that conditions identified in the NRs

described in Paragraphs 2a, 2b, and 2c above were as stated. The

e conditions identified in the NRs described in Paragraphs 2d and 2e

' had been revised and dispositioned " Accept-as-is" and the inspection-

, of these two (2) items indicated that re-work had been performed I before QCP hold tags could be removed to allow the work to procee This necessitated the revision to the original NR and subsequent

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disposition of " Accept-as-is." The Resident Inspector and region based inspector discussed this with the cognizant licenses personnel,

,'. i.e., QCP Task I Coordinator, Director of QCP, and the QA Manage *

e These persons were aware of this probles. The licensee was in the i process of revising their procedure covering hold tags to include

H. J. Kaiser hold tags. The licensee was also scheduling a meeting the week of June 1 with H. J. Kaiser cognizant personnel to review

, present procedures and necessary revisions and to establish a working i arrangement to prevent further occurrence of this situatio '

This ites is considered unresolved pending further review during

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subsequent inspection (358/82-10-07)

No itees of noncompliance or deviations were identifie q Structural Steel Bolted Expansion Connections

'llte inspector reviewed the IaSalle report on structural steel bolted expansion connections and its applicability to Zimmer with the cos-j . nizant licensee and H. J. Kaiser (HJK) personnel.

j: No re-inspections had been performed since the last reporting period

. because HJK was still evaluating the work and developing the necessary packages and procedure This ites will be sonitored on a continuing basis during future inspection No items of noncompliance or deviations were identified.

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- Exit Interview

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The inspector met with licensee personnel associated with QCP Task I

_ during the inspection period. A formal exit was not conducted by the

inspector during this perio .

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j 3, S00010 ,3