ML20078C432
| ML20078C432 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 09/16/1983 |
| From: | CINCINNATI GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20078C383 | List: |
| References | |
| NUDOCS 8309270582 | |
| Download: ML20078C432 (61) | |
Text
4 NATIONAL BOARD TASKS REPORT Revision 23 l SEPTEMBER 16,1983 l
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'O ur=rassa A PDR
INDEX Task No. Description Page No.
Executive Summary ii O)
\s, 1 Generic Design Specification 1 2 Material Release by Non-Certificate Holders 2 3 Material Manufacture, certification, and Supply 5 4 CG&E Takeover of Partial Piping Sytems 15 5 Owner's ANI 19 6 Catalytic's Modifications to Piping Systems 20 7 State Acceptance of Containment Liner 21 8 Vessel Modification by HJK 23 9 Mandatory Preheat Requirements 24 10 Pumps and Valves to the 1968 Code 25 11 Shimming of Penetrameters 26
() 12 Overstress During Hydrostatic Tests 27 13 Improperly Stamped Flow Check Valves 28 14 Non-Code Components 29 15 As-Constructed Drawings 33 16 Closure of NR's Prior to Stamping 35 17 Issuance and Control of NR's 38 18 Review of Construction Procedures 39 19 Review of IIDR's 40 20 Temporary Change Notices 41 21 Qualification of NDE Personnel 42 22 Radiographic Weld Identification 49 23 Weld Procedures 50 24 Weld Filler Metal 52 25 Generic NR's 53 26 Data Reports for Piping Subassemblies 55
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l O NATIONAL BOARD TASKS REPORT REVISION 23 - EXECUTIVE
SUMMARY
l NBT-1 Generic Design Specification CLOSED NBT-2 Material Release by Non-Certificate Holders Current Status is updated; Schedule remains indefinite.
HJK is still having difficulty obtaining documentation 23 from Pullman-Kellogg and its suppliers.
NBT-3 Material Manufacture, Certification, and Supply Note under Current Status is updated to reflect re-audits being performed by HJK, however final acceptance of the 23 audits is planned after results of forthcoming ASME audit.
National Board action is pending audit results.
NBT-4 OG&E Takeover of Partial Piping Systems Schedule is extended two weeks for review of CG&E implem-! 23 enting procedures; Current Status is updated.
NBT-5 Owner's ANI CLOSED NBT-6 Catalytic's Modifications to Piping System CLOSED NBT-7 State Acceptance of Containment Liner Action Plan, Schedule and Current Status have been chang-ed to address the complete scope of the containment 23 liner.
NBT-8 Vessel Modification by HJK l
No change in status. This task cannot be completed until the NRC Stop Work Order is lif ted. Text, Action Plan, Schedule, and Current Status are deleted until that time.
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NBT-9 Mandatory Preheat Requirements
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CLOSED NBT-10 Pumps and Valves to the 1968 Code CLOSED NBT-11 Shimming of Penetrameters CLOSED NBT-12 Overstress During Hydrostatic Tests CLOSED NBT-13 Improperly Stamped Flow Check Valves No change in status. This task cannot be completed until the NRC Stop Work Order is lif ted. Text, Action Plan, Schedule, and Current Status are deleted until that time.
NBT-14 Non-Code Components
(~N g,) Current Status is updated to reflect CG&E decision to i
replace Main Turbine Oil Coolers; Schedule is awaiting 23 location of replacements.
NBT-15 As-Constructed Drawings Current Status is unchanged; resolution of NRs on gener-ic problems is still indeterminate. Resolution plan now 23 includes activities under NBT-16.
NBT-16 Closure of NR's Prior to Stamping
- Action Plan, Schedule and Current Status have been chang-ed to reflect activities on management of NR Computer 23 Data Base.
I NBT-17 Issuance and Control of NR's CLOSED NBT-18 Review of Construction Procedures CLOSED NBT-19 Review of IIDR's CLOSED
() NBT-20 Temporary Change Notices CLOSED NBT-21 Qualification of NDE Personnel Schedule is extended one week for completion of record reviews by Quality Assurance. Current Status is 23 updated.
NBT-22 Radiographic Weld Identification No change in status; awaiting National Board Audit Team action. The National Board has indicated closure will be postponed until completion of walkdowns and as-con-structed drawings.
NBT-23 Weld Procedures No change in status; awaiting HJK action.
NBT-24 Weld Filler Metal CLOSED NBT-25 Generic NR's Schedule is indeterminate; Current Status is updated to show HJK is performing the necessary procedure revi- 23 sions.
NBT-26 Data Reports for Piping Subassemblies Resolution and Schedule will be provided by HJK by 23 September 30, 1983.
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Rev. 23 -- 9/16/83 Board Task Number 1
() NATIONAL BOARD TASKS
, Task No. Description NBT-1 Generic Design Specification NATIONAL BOARD FINDINGS (Interim :.eport #1)
This task has been closed by the State of Ohio as of June 29, 1983. Refer to Revision 16 of this report for text.
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Rev. 23 -- 9/16/83 Board Task Number 2
- NATIONAL BOARD TASKS Task No. Description NBT-2 Material Release by Non-Certificate Holders NATIONAL BOARD FINDINGS (Interim Report #1)
"2.2 Cincinnati Gas and Electric Company procured piping subassemblies from M.W. Kellogg Company, ASME N-1251 NPT Certificate of Authorization number (now Pullman Power Products, Williamsport, Pennsylvania). As part of these purchase orders, M.W. Kellogg Company supplied loose material such as pipe, fittings, flanges, etc...
. The material was received by Kaiser and was accepted for release to construction based on a notification of I
release from CONAM, CG&E's source inspection Agency.
2.2.1 National Board considers this procedure for the .
release of material by Kaiser through CG&E and or CONAM, who do not hold N Certificates of Auth-orization to be in apparent nonconformance to Paragraph NA-4441, NA-4442."
SUMMARY
All material (such a s - p i pe , fittings, flanges, etc.) which was
, received by Kaiser, should have been accepted for release based on their own inspection and review, and not based on reviews by others, because Kaiser is the responsible Certificate Holder.
CG&E RESPONSE (Interim Report $1, Item 2.2)
- " T h e Henry J. Kaiser (HJK) Quality Assurance Program requires HJK to perform receipt inspection on all Code material used or installed under the HJK QA Program. HJK will review all material documentation for acceptance in accordance with their
, documented on Nonconformance Reports and properly dispositioned.
- Receipt ins pection by HJK will be performed on all incoming Code material."
STATE OF OHIO COMMENTS (Interim Report #1, Item 2.2) 2
" Documentation should be given to the National Board Audit Team in order that they may verify that it complies with the code.
Acceptable."
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Rev. 23 -- 9/16/83 ,
Board Task Number 2 l ACTION PLAN HJK: a. Review documentation to assure that all material received from M.W. Kellogg was reviewed and accepted by Kaiser based on HJK receipt inspections.
- b. Identif y any material which is determined to be unac-ceptable or of indeterminate quality . The method of identification shall be in accordance with the HJK Quality Assurance Program and acceptable to the juris-dictional and regulatory authorities.
S&L: Revise Piping Design Specification to identify mate-rial specifications of later Code Editions. and Addenda that are acceptable and reconcilable with the Design /
Stress Report.
RFR: a. Review the results of the HJK actions for items "a" and "b" above.
- b. Review revision to Piping Design Specification.
CGEE: a. Monitor the above HJK activities for items "a" and "b" above.
( b. Review and approve revision to Piping Design Specifica-
'u tion.
- c. Present the results of the above activities to the National Board and the State of Ohio.
SCHEDULE Estimated Actual l Responsibility Completion Completion HJK: a. November 11, 1982
- b. No date available from HJK S&L: March 22, 1983 RFR: a. Awaiting HJK action
,b. March 31, 1983 CG&E: a. Awaiting HJK action
- b. March 31, 1983
- c. Awaiting HJK action
. - . = _. -- _ _ -. - -. -. . -
Rev. 23 -- 9/16/83 Board Task Number 2
_4_
() CURRENT STATUS HJK: a. Completed.
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- b. Closure of CAR 416 and CAR 455 is expected in mid October. Additional documentation is still required 23 and is being sought from Pullman-Kellogg and CG&E.
S&L: Completed.
RFR: a. Awaiting HJK action.
- b. Completed.
i CG&E a. Awaiting HJK action.
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- b. Completed.
i c. Presentation of documentation review is awaiting com-pletion by HJK.
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Rev. 23 -- 9/16/83 Board Task Number 3 NATIONAL BOARD TASKS Task No. Description NBT-3 Material Manufacture, certification, and Supply NATIONAL BOARD FINDINGS (Interim Report #l)
"2.3 CGEE, in some cases, refused to allow Henry J. Kaiser Company to perform qualification surveys of material manufacturers. CGEE insisted that only they (CG&E) could approve whom Kaiser was to qualify. In some instances Kaiser was required to place material manufac-turers on the Approved Vendors List based on CG&E's
" personal experience" or by virtue of appearing on the Case Register.
2.3.1 The National Board Audit Team considers this procedure to be an apparent non-conformance to ASME Code requirements. Paragraph NA3451, Subar-ticle NA-3110 specifically states that responsi-bilities set forth in Section III relate only to Code compliance and not to contractual relations or legal liabilities. Cincinnati Gas and Elec-tric Company must cease preventing Kaiser from
( the performance of those Code activities which are required to be performed by Kaiser's Certifi-j cate of Authorization."
NATIONAL BOARD FINDINGS (Interim Report $1)
"3.2 Purchase Order 7070 225 06 (and further documented on Nonconformance Report No. #E3633RI) was released to:
LaBarge, Inc.
Tubular Division 20 South Fourth Street St. Louis, Missouri 63102 to supply 20' 2-1/2" Sch. 40 SA 106 Gr B ASME Section III Cl 1 pipe and 220" 4" Sch. 40 SA 106 Gr B ASME Sec-tion III Cl 1 pipe. HJK required: 'All material con-tained in this order shall be manufactured by J&L Steel Corporation, Aliquippa and Pittsburgh, Pennsylvania, a purchaser-approved supplier.'
3.2.1 There is no record of a J&L Steel Corporation, Pittsburgh, Pennsylvania, Vendor Survey, nor does J&L Steel C o r poration , Pittsburgh, appear O on any HJK AVL.
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Rev., 23 -- 9/16/83 Board Task Number 3 3.2.2 The J&L Steel Cor pora tion CMTR for Mill Order
- 263 556674 does not identify which plant, Aliquippa or Pittsburgh, manufactured this mate-rial.
3.2.3 20' of 2 1/2" SA 106 Gr B pipe was manufactured by Youngstown Sheet & Tube Company and not J&L Steel as required by this purchase order.
3.2.4 Material was manufactured prior to any HJK Ven-dor surveys of either Youngstown Sheet & Tube Company or J&L Steel Corporation.
3.2.5 CMTR's are not certified as meeting the special requirements of NB-2000.
3.2.6 Ultrasonic examination required by NB-3350 was performed by Industrial Testing Laboratories, Inc. for LaBarge, Inc. and would appear to be invalid in that this NDE company does not appear on any HJK AVL as a supplier of Nondestructive Examination.
3.2.7 The material reported on the CMTR for heat
- 31582 appears to have been shipped from Youngs-
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town to LaBarge on or about February 27, 1976, on truck # PIE 28114. Approximately fifteen (15) months prior to the release of.this HJK purchase order, this material does not carry any type of certification to Section III requirements, and the pipe was manufactured about three (3) months prior to Youngs town's being placed on HJK AVL.
In addition, we do not have copies of LaBarge purchase documents used to acquire this pipe.
3.3 It is the opinion of the National Board Audit Team that ,
disposition " Accept As Is" documented NR No. E3633 R1 appears invalid based on the above-listed apparent non-conformance with Section III requirements. The Nation-al Board Audit Team shall be provided with documenta-tion to assure this material was manufactured and pur-chased in accordance with Code Quality Assurance requirements, alternatively or removed. Acceptable documentation shall be in the form of the following:
3.3.1 LaBarge purchase and receiving documents for material provided on the P.O.
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Rev. 23 -- 9/16/83 Board Task Number 3 O
O 3.3.2 Certification provided by Youngstown Sheet &
Tube and J&L Steel that Section III require-ments, except UT were met.
3.3.3 The National Board Audit Team further believes that a thorough evaluation of all HJK P.O.'s to LaBarge (as a supplier of Nuclear Quality Mater-ial) shall be made.
3.4 Kaiser P.O. 7070-17688 dated June 22, 1976 for Carbon Steel SA106 GR B ASME Section III CL2 was purchased through LaBarge Tubular Division, St. Louis, Missouri.
This material was manufactured by Gulf States Tube Cor-poration, Rosenberg, Texas sometime prior to November 25, 1974 and February, 1975. Gulf States Tube Corp. is listed on HJ K's AVL, approved date September 28, 1976.
The National Board Audit Team noted the following:
3.4.1 The material reported on the CMTR for Heat #KA-2097 appears to have been shipped from Gulf S ta tes Tube Corp. on or about November 25, 1974, approximately one year and seven months prior to the release of this HJK P.O. and one year and ten months prior to this organization's being placed on the HJK AVL.
3.4.2 The material reported on the CMTR for Heat
- HA-0001 and #HA-0005 appears to have been shipped f rom Gulf States Tube Corp. on or about February, 1975, approximately one year and four months prior to the release of this HJK P.O. and one year and seven months prior to this organiza-tion's being placed on the HJK AVL.
3.4.3 This material does not carry any type of certifi-cation to Section III requirements.
3.5 The National Board Audit Team shall be provided with documentation to assure that this material was manuf ac-tured and purchased in accordan'ce with Code Quality Assurance requirements. Acceptable documentation shall he in the form of the following:
3.5.1 LaBarge purchase and receiving documents for the material provided on this P.O.
Cer tifica tion provided by Gulf Sates Tube Corp.
that Section III requirements were met.
3.6 One additional problem noted during this review was:
Material identi fied by Heat #KA2097 was shipped to s
i- Rev. 23 -- 9/16/83 Board Task Number 3 I
LaBarge Tubular Division, 121 East Koeln, St. Louis, Missouri. This supplier / warehouse facility does not appear on HJK's AVL.
3.7 The National Board Audit Team believes that similar
' problems exist in all Section III materials provided by LaBarge and possibly other suppliers. This shall be resolved by HJK."
SUMMARY
- 1. All material purchased by HJK must be received from Mate-rial Manufacturers who have been qualified by HJK as meet-ing applicable requirements of the Code.
- 2. Documentation for all material used by HJK must be reviewed to assure all Code requirements have been met.
- 3. Documentation for material purchased by HJK and any associ-ated NR's must be available for National Board review.
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- 4. Documentation of HJK's evaluations of Material Manufactur-ers shall be made available for National Board Review.
- 5. CG&E must not perf orm any Code responsibilities assigned to a Certificate Holder.
CG&E RESPONSE (Interim Report #1, Item 2.3)
" Cincinnati Gas & Electric understands that the Code respon-sibility for qualification of Material Manufacturers is a respon-sibility of the ASME Certificate Holders. HJK will assure that the Material Manufacturers for Code materials have a QA Program
- meeting the requirements of NX-2600 (Section III, Summer 1973 Addenda). CG&E will not assume the HJK responsibilities for the performance of any Code activities required by the Code to be performed under the HJK Certification of Authorization.
A special task f orce has been formed to evaluate purchases made from suppliers that were not listed on HJK's Approved Ven-dors List. The vendors are being identified and Nonconformance Reports written as part of the document review process. There is no longer a requirement for HJK to obtain CG&E approval to per-form vendor surveys. Both organizations are cooperating to clear up all deficiencies involving unapproved suppliers.
As of July 28, 1982, approximately 98% of the purchases made from vendors not listed on the AVL have been evaluated. This
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evaluation has identified 33 vendors not appearing on the AVL at the time of procurement, resulting in 62 Nonconformance Reports.
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Rev. 23 -- 9/16/83 Board Task Number 3 Final disposition and acceptance has been completed on two of the Nonconformance Reports."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #1, Item 2.3)
" Task Force should meet with the National Board Audit Team and report on progress and identify NCR's generated on this sub-ject and their disposition. Your response acceptable."
(Also see below.)
CG&E RESPONSE (Interim Report #1, Item 3.2)
"3.2.1 The material was manufactured by J&L Steel Cor-poration, Aliquippa. The Pittsburgh location should not have been listed in the HJK purchase order for this material.
3.2.2 The number 263 on the mill order is the J&L Steel Corporation identification numbe r for the plant. In addition, the Pittsburgh plant of J&L does not produce pipe material. This informa-tion is to be documented by J&L Steel Corpora-O D
tion and a copy will be available to the Nation--
al Board for review.
3.2.3 The Purchase Order has been amended to provide that the material was to be furnished by Youngs-town Sheet & Tube Company who has been on the HJK Approved Vendors List.
3.2.4 LaBarge will be requested to assure that both Youngstown Sheet & Tube Company and J&L Steel Corporation meet the requirements of NX-2600, Summer 1973 Addenda.
3.2.5 All material ordered and received on Purchase Order 7070-22506 has been reviewed and accounted for and none of the material has been used in Class I piping systems. Wherever any of this material is to be used on ASME Class 2 or 3 pip-ing systems, HJK will assure that the require-ments of NC/ND-2000 have been met for the mate-rial. This material will not be used on Class I piping systems unless the material test reports can be certified per the requirements of NB-2000.
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3.2.6 In th e event that the Industrial Testing Labora-tory cannot be qualified, then HJK will not use
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Rev. 23 -- 9/16/83 Board Task Number 3 O)
D the ma terial which had been ultrasonically exam-ined by Industrial Testing Laboratories in any ASME Class I piping system.
3.2.7 HJK has requested that LaBarge provide their purchase and receiving documents for all mate-rials provided on this purchase order and the documentation that the requir ements of Section III were met."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #1, Item 3.2)
" Meeting with National Board Audit Team should be held to review HJK procedures and progress report on the subject of mate-rial verification and certification. In addition Task Force should present to the National Board Audit Team all NCR's and their final disposition. Acceptable." (Also see below.)
CG&E RESPONSE (Interim Report il, Item 3.3)
"The Authorized Nuclear Inspector (ANI) will be provided with documentation that the material was manufactured and purchased in accordance with the requirements of Section III. The disposition will follow the National Board guidelines above."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #1, Item 3.3)
(See below.)
CG&E RESPONSE (Interim Report #1, Item 3.4)
"The material in question shall be documented on an NR and action will be taken to assure that the requirements of NX-2000 have been met."
STATE OF OHIO COMMENTS ON CG&E RESPONSE l (Interim Report #1, Item 3.4) l (See below.)
- CG&E RESPONSE (Interim Report #1, Item 3.5)
"The ANI will be provided with the documentation to assure the material was manufactured in accordance with the Code require-ments of NX-2000."
STATE OF OHIO COMMENTS ON CG&E RESPONSE
! (Interim Report #1, Item 3'.5)
! (See below.)
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Rev. 23 -- 9/16/83 Board Task Number 3 CG&E RESPONSE d (Interim Report #1, Item 3.6)
"The address given for LaBarge is the address of a shipping point for route deliveries from the Material Manufacturer and does not have an effect on HJK's review of the LaBarge tubular division."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #1, Item 3.6)
(See below.)
CG&E RESPONSE (Interim Report #1, Item 3.7)
"HJK shall assure that all materials provided by LaBarge meet the requirements of Section III, NX-2000. Also, other suppliers shall be reviewed to see if similar problems exist and the appro-priate resolutions will be addressed.
HJK ha 2 committed to perform a full scale review of all Sec-tion III Purchase Order documentation, with the first priority being LaBarge. This review has already begun, and will be comple-ted with all deficiencies resolved, p As of this date 110 ASME Purchase Orders involving 40 differ-ent companies have been identified. Nonconformance Reports have been written due to the AVL problems on ASME Purchase Orders and the HJK AVL Task Force has the primary responsibility to perform the research required t'o disposition these NR's."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #1, Item 3.7)
(See below.)
STATE OF OHIO COMMENTS (Interim Report #1, Items 2.3, 3.2, 3.3, 3.4, 3.5, 3.6, and 3.7)
"The National Board Audit team has reviewed the documentation presented and while we have agreed, with reservations , with the proposed methods of correcting these deficiencies at this time these findings cannot be closed out for the following reasons.
- 1. The National Board questions the validity of audits #17, 18, 19, 21, 22, 23 and 24. From the review of these audits it appears that the only criteria used to qualify these manufac-turers was records of calibrated tensile machines. The National Board Audit Team is of the opinion, that the manu-I facturers Q. C. system must have also provided for proce-dures for I . D. of heat traceability, during the heating and melting practice and identificatien of traceability during p\ the testing of coupons. Also the quality program should have been documented in a manual.
1
d Rev. 23 -- 9/16/83 Board Task Number 3 12-l 2. Henry J. Kaiser has stated that no material procured through j LaBarge was used in ASME Class 1 Systems. However e the
- matrix presented to the National Board Audit Team in many casas only identifies material to a system and not an indi-
- vidual ISK or PSK. The systems identified do have Class 1
- requirements (per piping line list).
1 l 3. The National Board Audit Team cannot at this time make any meaningful review of the presented documentation until it is identifiednto a specific PSK or ISK.
- 4. In addition, in many instances the matrix referenced above also identifies multiple heat numbers.
- 5. The National Board also is of the opinion that given the fact that these audits are being performed several years af ter the f act they must be comprehensive and complete inclu-ding the statement by the material manufacturer.
If the above concerns can be satisfied the National Board Audit Team will be in a position to make a further review of the
- findings and we will inf orm you as to the acceptability of the corrective action."
ACTION PLAN HJK: a. Review documentation of all material (not subassem-blies) purchased and installed by HJK.
- b. Small bore piping (2" nps and less).
- 1. Determine whether Material Manufacturers were qual-ified in accordance with the HJK QA Program.
- 2. If not on HJK AVL, assure Material Manufacturers
! met the requirements of NX-2610 Winter '75 Adden-da. t
- c. Large bore piping (over 2" nps).
- l. Determine whether Material Manufacturers were qual-ified by HJK in accordance with QA Program.
- 2. If not on HJK AVL, assure Material Manufacturers met the requirements of NX-2610, Summer '73 Adden-da.
- 3. Exempt backing rings from NX-2000 on the basis of NX-2121(e) in the Summer ' 77 Addenda and Inter pre-tations III-1-77-208 and III-1-79-69.
- - , - - - - - - - ,--.,,_--,,-,---,--,-,..-,-.,,..,,,.,,,-,_,-_-,-,.,,y--+-. ...--4, - . . , , , - , . . - , - , , - , . s-me-m --...--,-,,--r...-,-
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Rev. 23 -- 9/16/83 Board Task Number 3
,, ~13-() d. Where material does not comply with Code or applicable Code Cases, material is to be dispositioned in accor-dance with HJK QA Program, or by other methods accepta-ble to the jurisdictional and regulatory authorities.
- e. Assure documentation of all HJK material NR resolu-tions (see item (d) above) is available to the Nation-al Board.
- f. Respond to State of Ohio comments of December 8, 1982.
- g. Verify that no LaBarge material has been installed in ASME III, Class 1 systems.
S&L: Revise Design Specification to allow the use of NX-2610, Winter '75 Addenda and NX-2121(e), Summer '77 Addenda.
RFR: a. Review HJK actions "a" through "g" above,
- b. Review Design Specificatien changes.
- c. Review HJK response to State of Ohio comments.
CG&E: a. Assure that all Material Manufacturers used by HJK are also on HJK AVL.
- b. Assure all HJK material evaluations are available to the National Doard.
SCHEDULE Estimated Actual Responsibility Completion Completion HJK: a. October 15, 1982 b.1 October 15, 1982 b.2 November 4, 124?
c.1 October 15, 1982 c.2 November 4, 1982 c.3 October 25, 1982
- d. Pending
- e. January 27, 1983
- f. January 27, 1983
Rev. 23 -- 9/16/83 Board Task Number 3 3
.. 'O g. March 9, 1983 j S6L: October 25, 1982 l RPRI a. January 27, 1983
- b. December 7, 1982
- c. January 27, 1983 !
CG&E: a. Pending i
- b. January 27, 1983 CURRENT STATUS HJK: a. Completed.
. b. Completed.
- c. Completed.
) d. Final re.Olution of NR 's pending National Board and
, O State of Ohio approval of historical qualification of vendors.
l e. Awaiting National Board review.
- f. Awaiting National Board comments.
- g. Compl e ted. NR-E-10764 QD issued on single occurrence.
NR has been dispositioned for removal of the material.
SEL: Completed.
RPR: Completed.
CGEE: a. Awaiting National Board review.
- b. Completed.
Note: The National Board Audit Team has reported that no ,
action will be taken on this item at this time. HJK is !
re-auditing sixteen (16) vendors, as commited to the ASME; fourteen (14) are complete at this time. Audit reports 23
, and documentation will be reviewed by CG&E and the Nation-al Board Audit Team.
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Rev. 23 -- 9/16/83 Board Task Number 4 NATIONAL BOARD TASKS Task No. Description NBT-4 CG&E Takeover of Partial Piping Systems NATIONAL BOARD FINDINGS (Interim Report #1)
"2.4 CG&E has a procedure, ADMIN-3, Rev. O, 2/21/80, "Perfor-ming Construction on Systems / Areas under EPD Control:
( Elect rical Production Department) . This procedure has been implemented to allow CG&E to take over piping sys-tems which are still within the jurisdiction of HJK and are not completed or covered on an N-5 Data Report Form.
CG&E then directs the performance work on these systems or portions of systems , which in some instances may include the removal of or addition of welds. In some cases this work has been done with the use of HJK craft, but neither HJK QA or the ANI has been involved in the activities or review of proposed activities.
Further, there is the possibility that there have been no records kept of weld material or piping material
""' " ' " " ' " " ' ' *'" v* - t -
CD. tions.
2.4.1 It is the opinion of the National Board Audit Team that this is an unacceptable practice.
This also is in conflict with NA-3440, NA-3451, NA-3460, and the specific requirements of Inter-pretation III-1-77-159, da ted June 30, 1978.
The National Board Audit Team is of the opinion that until such time that an N-5 has been com-pleted, piping systems that are to be Code sym-bol stamped must remain in the custody of the NA Certificate Holder.
Further, any modifications or changes to these systems shall be made under the requirements of the QA program of the NA Certificate holder who is responsible for executing the N-5 Data Report.
All turnover packages and associated documents involving modified Code piping systems shall be reviewed to assure that no Code work has been performed by other than the holder of an appro-priate Certificate of Authorization and that this modification was properly reconciled with V the design speci fica tion and documented final record package."
Rev. 23 -- 9/16/83 Board Task Number 4
SUMMARY
- 1. Portions of piping systems are being turned over to others prior to the completion of a partial N-5 Data Report Form.
- 2. CGEE may be directing some additional Code work on these systems.
- 3. Possibly there are no records of welding material or pip-ing material used for these piping system modifications.
- 4. The provisions of NA-3440, NA-3451, and NA-3460 and Inter-pretation III-1-77-159 must be met.
- 5. All modifications must be performed by a Certificate Hol-der and documented on an N-5 Data Report Form.
CG&E RESPONSE (Interim Report $1, Item 2.4)
"CGEE recognizes that Code piping systems must remain in the custody of the NA Certificate Holder until an N-5 Data Report Form has been completed by the Certificate Holder. With regard to the Code piping systems at the Zimmer Station, all modifica-tions or changes shall be made under the requirements of the QA Program of HJK or another N-type Certificate Holder authorized O for the Zimmer site.
The provisions of ASME Code Interpretation III-1-77-159, dated June 30, 1978 shall be followed.
All turnover packages and associated documents involving modified Code piping systems shall be reviewed to assure that no Code work has been performed by other than the holder of an appro-priate ASME Certificate of Authorization and that modifications are properly reconciled with the Design Specification and Stress Report or calculations and documented in the final record pack-age."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report $1, Item 2.4)
"Turnbacks to remain in custody of "NA" Certificate Holder until N-5 is completed. You refute this statement by saying "or another N-type Certificate Holder." When and how will the review of all turnover packages and associated documents involving modi-fied piping systems occur, be reconciled with design specifica-tion and documented, and final records packaged? How are you monitoring this now? Acceptable provided the NB Audit Team is properly advised."
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Rev. 23 -- 9/16/83 Board Task Number 4 ACTION PLAN HJK: a. Run a pilot N-5 to determine the best system for N-5 compilation.
- b. Finalize N-S Data Report procedures ( Z APO-6, QRM-1, QRM-13, MCP-1, and MIP-1 ) .
- c. Demonstrate the N-5 Data Report procedures to assure HJK accountability for ASME III work to be certified by HJK.
d Develop procedure or revise ZAPO-6 for HJK maintaining administrative control of partially completed piping systems during CGEE pre-op testing.
CGEE: a. Determine whether CG&E or any other non-Certificate Holders performed any Code work on partially completed piping systems.
- b. Develop a procedure or revise existing procedures for performing pre-op testing on piping systems under HJK administrative control prior to completion of the N-5 Data Report.
O c. Review procedures related to control of partially com-pleted piping systems with the National Board.
- d. Documentation of work orders reviewed, review of bolt-ing material per MCP-7, and HJK documentation of review associated with N-5 procedure will assure that work performed by others is identified. Documen ta tio n of work orders reviewed and MCP-7 to be presented to the National Board.
RFR: a. Assure that the above HJK procedures comply with the requirements of the Code,
- b. Review CG&E pre-op procedure for compatibility with the Code.
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Rev. 23 -- 9/16/83 Board Task Number 4
) SCHEDULE Estimated Actual Responsibility Completion Completion HJK: a. February 21, 1983
- b. August 12, 1983
- c. June 15,1983
- d. March 4, 1983 CG&E: a. November 9, 1982
- b. March 29, 1983
- c. September 30, 1933 l 23
- d. February 23, 1983 RPR: a. August 18, 1983
- b. February 9, 1983 CURRENT STATUS HJK: a. Completed,
- b. Completed.
- c. Completed.
- d. Completed.
CG&E: a. Completed,
- b. Completed.
- c. CG&E procedure will be reviewed with National Board 23 beginning September 19, 1983.
- d. Completed.
RFR: a. Completed,
- b. Completed.
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I Rev. 23 -- 9/16/83 Board Task Number 5
.. l NATIONAL BOARD TASKS l Task No. Description i NBT-5 Owner's ANI a
l This task has been closed by the State of Ohio as of April 28, 1983. Refer to Revision 14 of this report for text, l
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Board Task Number 6 NATIONAL BOARD TASKS I Task No. Description NBT-6 Catalytic's Modifications to Piping Systems This task has been closed by the State of Ohio as of March 7, 1983. Refer to Revision 9 of this report for text.
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Rev. 23 -- 9/16/83 Board Task Number 7 1
NATIONAL BOARD TASKS l Task No. Description NBT-7 State Acceptance of Containment Liner NATIONAL BOARD FINDINGS (Interim Report #1)
"2.7 The containment vessel apparently is within the scope i of the State of Ohio Boiler and Pressure Vessel law '
regarding construction, inspection, and stamping, and there is no evidence of compliance with these require-ments.
2.7.1 It is the opinion of the National Board Audit Team that CG&E contact the Boiler Pressure Ves-sel Division of the State of Ohio for possible resolution."
SUMMARY
There is no evidence that the containment vessel meets the State of Ohio Boiler and Pressure Vessel Law.
CG&E RESPONSE (Interim Report #1, Item 2.7)
) "Mr. E. A. Borgmann has made arrangements with Chicago Bridge
& Iron Co. to provide liner Data Report Forms, nondestructive examination records, and inspection records, procedures and mater-ial documentation. These records will be available for review by the National Board at the Zimmer site."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #1, Item 2.7) l
" National Board to receive documentation for review within two weeks -- is satisfactory progress."
ACTION PLAN CB&I: Provide Data Reports, NDE records, inspection records and material documentation to CG&E.
l l RFR: Assist in presenting CB&I information to the National Board and the State of Ohio as requested by CG&E.
CGE: Present CB&I records to State of Ohio.
CGE/HJK: Resolve and complete modification package format; assemble and review documentation on balance of HJK 23 work on the containment liner.
S HJK: Resolve all NR's and deficiencies.
CGE: a. Present to National Board and State of Ohio. l 23
Rev. 23 -- 9/16/83 Board Task Number 7
/~N SCHEDULE Estimated Actual Responsibility Completion Completion CB&I: December 2, 1982 RPR: December 2, 1982 CGEE: December 2, 1982 CG&E/HJK: November 14, 1984 l 23 HJK: No schedule at this time CG&E: No schedule at this time CURRENT STATUS CB&I: This portion of this task has been closed by the State of Ohio as of April 2 8, 1983. State witnessing of primary containment pressure test is still required.
() RFR: Completed.
CG&E: Completed. CB&I portion closed by State of Ohio as of April 28, 1983. Primary containment pressure te st not scheduled.
CG&E/'.sJK: HJK review of modification packages is on schedule.
Balance of HJK work on containment liner has been ini-tially defined, to be confirmed by as-constructed in-spection. Schedule for review of balance of documenta- 23 tion has estimated completion of December 30, 1983, for HJK and January 1, 1984, for CGE.
HJK: Schedule for resolution of NRs and deficiencies on liner modifications is not available at this time.
l Complete review of all HJK containment liner work is 23 to being November 1, 1983; deficiencies in schedule for resolution not known at this time.
CG&E: Awaiting HJK completion. Review of HJK documentation will be performed as they are completed by HJK. RCI 23 i
documentation on liner pentrations for CRD system will be made available to the National Board.
Rev. 23 -- 9/16/83 Board Task Number 8
.. NATIONAL BOARD TASKS Task No. Description NBT-8 Vessel Modification by HJK
SUMMARY
Modification of the Standby Liquid Control Tank was not made as originally specified and approved. Additionally, it must be shown that the ANI inspected the modification, witnessed the hydrostatic test and completed the required Data Report Form.
Note:The text of this task has been removed from the National Board Tasks Report and will be reprinted when the NRC Stop Work Order has been lif ted and the vessel modification can resume. Refer to Revision 7 of this report for text.
Due to the Stop Work Order currently in effect at the Zimmer site the Standby Liquid Control Tank modification cannot be completed. Actions to date include finalization of neces-sary calculations, authorization by General Electric and approval by the State of Ohio. The National Board has determined that the stated concern will remain open until the vessel modification has been completed and the Data
(] Report filed.
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- i Rev. 23 -- 9/16/83 Board Task Number 9 NATIONAL BOARD TASKS ,
Task No. Description NBT-9 Mandatory Preheat Requirements i
This task has been closed by the State of Ohio as of July 22, 1983. Refer to Revision 19 of this report for text. '
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. Rev. 23 --
9 /16/83 Board Task Number 10 i NATIONAL BOARD TASKS Task No. Description NBT-10 Pumps and Valves to the 1968 Code i
This task has been closed by the State of Ohio as of March 7, 1983. Refer to Revision 9 of this report for text.
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. Rev. 23 -- 9/16/83 l Board Task Number 11 NATIONAL BOARD TASKS i
Task No. Description NBT-11 Shimming of Penetrameters 1
NATIONAL BOARD FINDINGS
- l. (Interim Report #1)
This task has been closed by the State of Ohio as of June 9, 1983. Refer to Revision 16 of this report for text.
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, . Rev. 23 -- 9/16/83 Board Task Number 12 27-i, .
l NATIONAL BOARD TASKS i Task No. Description 3 NBT-12 Overstress During Hydrostatic Tests i '
I NATIONAL BOARD FINDINGS j (Interim Report #2) 4 This task has been closed by the State of Ohio as of June 9, 1983. Refer to Revision 16 of.this report for text.
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. Rav. 23 -- 9/16/83 Board Task Number 13 NATIONAL BOARD TASKS Task No. Description NBT-13 Improperly Stamped Flow Check Valves
SUMMARY
Two ASM"Section III, Class 2 flow check valves installed in the reactor recirculation system are stamped indicating design condi-tions inadequate for that service. These valves are to be replaced and a walkdown performed to assure no similar occurren-ces.
Due to the Stop Work Order currently in effect at the Zimmer site, the replacement of the flow check valves cannot be comple-ted. The National Board has determined that the stated concern will remain open until the replacement has been completed.
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, Rev. 23 -- 9/16/83 Board Task Number 14
-~s NATIONAL BOARD TASKS Task No. Description NBT-14 Non-Code Components NATIONAL BOARD FINDINGS (Interim Report #2)
"2.4 A letter dated February 22, 1979 by S.A. Zych and D.D.
Crisp of Sargent and Lundy Engineers contains " Notes of Inspection - February 5, 1979 regarding a Steam-Jet Air Ejector Condenser William H. Zimmer Unit 1."
Apparently this steam jet air ejector condenser failed due to overpressure causing cracks on the shell side to the tube sheet and the pulling of some tubes in the outer two (2) rows of tubes. A reference in the report was made to " poor penetration" (Weld), and the Nation-al Board Audit Team became interested in a possible Code violation by the manufacturer of the pressure ves-sel. In addition, the Team wished to confirm that the vessel was replaced as recommended in the above- refer-enced " Notes of Inspection."
p 2.4.1 The Na tional Board Audit Team examined external-ly the pressure vessel ICD 03AALIA and noted a
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Wes tinghous e nameplate with information as f ol-lows:
Westinghouse 1-8A 2679-1 Steam Pressure -200 Cooling Water -7600 There was a tag as follows:
HJK PO #CG&E 2043 MR #10247 Received 7/1/74 ID ICD-03AA Location - Compound 2.4.2 There was no evidence externally on the pressure vessel that it had been constructed and stamped in accordance with the ASME Code (a State of Ohio requiree.ent for pressure vessels designed for 15 or more psi). It was also noted that the pressure vessel had apparently been repaired in the field.
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' Rev. 23 -- 9/16/83 Board Task Number 14 2.4.3 The National Board Audit Team has attempted to obtain documentation from the CG&E vault and the Henry J. Kaiser vault for this pressure vessel and any repairs that have been made to it, and none has been made available to date.
2.4.4 It is the opinion of the National Board Audit Team that documentation shall be presented to the National Board Audit Team assuring the pres-sure vessel (s) in this condensate system and repairs to pressure vessels in the system are in accordance with the requirements of the State of Ohi o. "
SUMMARY
- 1. Verify whether or not the original pressure vessel has been repaired.
- 3. Present documentation concerning the above to the National Board.
O CG&E RESPONSE (Interim Report #2, Item 2.4 )
"We recognize that some non-Code vessels were used in applica-tions for which compliance with the ASME Code may be required by the State of Ohio. We are conducting a generic evaluation to determine if other non-Code vessels have been installed in simi-lar applications. CG&E will assure that all State of Ohio regula-tions are met for each pressure vessel installed."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #2, Item 2.4)
"Your r esponse is unacceptable. Unless these vessels comply with the requirements of ASME Section VIII and the rules of the State of Ohio, they must be replaced. In addition, your generic evaluation of other vessels in the systems shall be presented to the National Board Audit Team; and, if they do not comply with the State of Ohio's requirements they shall be replaced."
Rev. 23 -- 9/16/83 Board Task Number 14 b CG&E a.
sels.
ACTION PLAN Contract with U-Stamp holder for fabrication of ves-
- b. Present U-Stamp holder fabrication plan to the Nation-al Board and the State of Ohio,
- c. Conduct generic evaluation to determine if other non-Code vessels have been installed.
- d. Present results of evaluation to National Board.
- e. As identified by the generic evaluation, resolve
, acceptability of Main Turbine oil Cooler s with State of Ohio. NR-C-NDE-0831-N documents this deficiency.
RFR: a. Review fabrication proposal.
- b. Review results of evaluation.
- c. Review Main Turbine Oil Cooler calculations and fabri-cation drawings for compliance with the design require-ments of Section VIII, and review CG&E proposed resolu-1 tion.
SCHEDULE Estimated Actual Responsibility Completion Completion CG&E: a. May 9, 1983
- b. March 10, 1983
- c. April 20, 1983
- d. April 21, 1983
- e. No date available from CG&E RFR: a. March 10, 1983
- b. April 21, 1983
- c. Awaiting action from CG&E O
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, Rev. 23 -- 9/16/83 1 Board Task Number 14 r CURRENT STATUS I CGir E : a. Completed.
- b. Completed. i j c. Completed.
- d. Completed.
- e. Main Turbine oil Coolers will be replaced. Suitable U-Stamped vessles are being sought. No Schedule for 23 replacement is available at this time. l RFR: a. Completed.
- b. Completed.
- c. Awaiting calculations, drawings, and proposed resolu-l tion.
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. Rsv. 23 -- 9/16/83 Board Tcsk Numbar 15 NATIONAL BOARD TASKS Task No. Description.
NBT-15 As-Constructed Drawings NATIONAL BOARD FINDINGS (Interim Report #2)
"3.1 During the review of various work packages for the essential service water system (WS), the National Board Audit Team requested copies of the "As Constructed" drawings for the embedded portions of the (WS) system.
The National Board Audit Team was informed that no "as-built or as-constructed" drawings exist.
3.1.1 The National Board Audit Team is of the opinion that before the (WS) system can be Code Symbol Stamped and a Code Data Report certified, Henry J. Kaiser Company shall present to the National Board Audit Team a procedure f or review that shall describe how Henry J. Kaiser will assure that the (WS) piping system is ins talled in accordance with the requirements of Design Speci-fication and drawings. In addition, all mate-rial used shall be tabulated in accordance with ASME Code requirements."
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SUMMARY
As-constructed drawings and inaterial tabulations are required for the (WS) system.
CG&E RESPONSE (Interim Report #2, Item 3.1)
"H.J. Kaiser is investigating the problem to determine and verify their compliance with ASME code requirements concerning the as-built or as-constructed condition of the embedded portions of the essential service water system. A procedure is being developed to assure reconciliation of installed systems with applicable design documents. This information will be made avail-able to the National Board for their review."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #2, Item 3.1)
"We are at this time not prepared to either accept or reject your response. Acceptance or rejection will be made after the National Board Audit Team has received and reviewed your proposed procedure. Be aware, however, that the only acceptable response n is one which shall assure compliance with all ASME Code require-Q ments."
, Rcv. 23 -- 9/16/83 Board Tcck Number 15 i
h3 ACTION PLAN V HJK: a. Prepare as-cons tructed drawing procedure (MCP-1) and material reconciliation procedure (ORM-1) .
- b. Provide change data sufficient for S&L to finalize "as-constructed" drawings.
- c. Provide material tabulations or equivalent records acceptable to the ANI and the National Board.
RFR: Review procedure and doculaents.
CG&E: Present procedure, drawings, and tabulations to the National Board.
SCHEDULE Estimated Actual Responsibility Completion Completion HJK: a. June 6, 1983
- b. Indeterminate
- c. Indeterminate RFR: Indeterminate CG&E: Indeterminate CURRENT STATUS HJK: a. Completed.
- b. Specific NRs have been dispositioned, however NRs on generic probelms remain,
- c. Awaiting completion of as-cons tructed drawings and tabulations of material.
RF_R: Procedures reviewed. Awaiting as-constructed drawings and tabulations of material. Completion cannot be 23 scheduled without NR Computer Data Base.
CG&E: Procedures reviewed. Awaiting as-constructed drawings and tabulations of material.
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, Rev. 23 -- 9/16/83 Board Task Number 16 NATIONAL BOARD TASKS Task No. Description NBT-16 Closure of NR's Prior to Stamping NATIONAL BOARD FINDINGS (Interim Report #2)
"3.2 The National Board Audit Team is also reviewing and is concerned with the Henry J. Kaiser non-conformance report system (NR). A major concern is how HJK will assure that all NR's affecting a specific system are dispositioned and closed prior to the Certification and Code symbol stamping of the completed system.
3.2.1 It has been determined by the National Board Audit Team that all NR's generated are not iden-tified to a specific system or item. As an exam-ple, there are some NR's that have been genera-ted against material, weld procedures and welder qualification records. Of particular conce rn to the National Board Audit Team is how HJK will assure that those NR's which are not identified to a system or item are closed, or do not aff ect the system or item prior to Stamping and Certifi-cation of the N-5 Data Report.
3.2.2 A meeting with HJK to discuss this concern was proposed. However, to date (July 1, 1982) this meeting has not been held."
SUMMARY
A method must be established for closing NR's on generic problems for systems or partial systems that are to be stamped or turned oV8r.
CG&E RESPONSE (Interim Report #2, Item 3.2)
"A response to the National Board Audit Team's concern rela-ting to HJK's ability to assure that all NR's affecting a speci-fic system are dispositioned and closed prior to the Certifica-tion and Code Symbol stamping of the completed system has been 4 prepared by HJK. The HJK Document Review Group will assure that all NR's are properly addressed before any system or item is stamped and certified or the N-5 Data Report is completed. Weld procedures are being reviewed by both the HJK Document Review Group and CG&E Quality Confirmation Program. No N-5 Data Reports will be prepared by HJK until assurances have been made that all weld procedores a f fecting a specific system or item are accept-7 able. The proposed program and its description in the next revi-Q
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- Rev. 23 -- 9/16/83 Board Task Number 16 p sion of QRM-1 will adequately resolve the concerns of the Nation-Q al Board Audit Team,"
STATE OF OHIO COMMENTS (Interim Report #2, Item 3.2)
"This response is similar to our answer to Item 3.1. Until the revised procedure QRM-1 is received and reviewed by the National Board Audit Team, no acceptance or rejection will be made."
ACTION PLAN HJK: a. Establish procedures to assure that NRs on generic problems do not apply or have been closed before certification and stamping.
- b. Correct and update HJK NR Computer Data Base whereby NRs are components / iso specific and may be identified 23 in Code Certification procedures.
RFR: a. Review HJK procedure, g- b. Review development of HJK NR Computer Data Base. l 23 CG&E: a. Review HJK procedure,
- b. Present procedure and demonstrate NR Computer Data 23 Base to National Board.
SCHEDULE
- Estimated Actual Responsibility Completion Completion j
HJK: a. No date available
- b. January 2, 1984 l 23 RPR: a. Awaiting procedure
- b. Indeterminate l 23 l
l CG&E: a. Indeterminate l
- b. January 2, 1984 l 23
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, Rev. 23 -- 9/16/83 Board Task Number 16 CURRENT STATUS HJK: a. Awaiting review by CG&E and S&L.
- b. Activity to being as soon as possible. l 23 RFR: a. Awaiting Revision 4 of QRM-1.
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- b. To begin with HJK activity. l 23 CG&E: a. In process.
j b. Awaiting final issuance of ORM-1 and development of NR 23 j Computer Data Base.
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Rev. 23----9/16/83 Board Task Number 17 t
i NATIONAL BOARD TASKS I Task No. Description l NBT-17 Issuance and Control of NR's
' This task has been closed by the . State of Ohio as of March 7, 1983.
. Refer to Revision 9 of this report for text. ,
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Rev. 23 -- 9/16/83 Board Task Number 18 NATIONAL BOARD TASKS O Task No. Description NBT-18 Review of Construction Procedures This task has been closed by the State of Ohio as of April 28, 1983. Refer to Kevision 14 of this report for text.
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. Rev. 23 -- 9/16/83 Board Task Number 19 NATIONAL BOARD TASKS Task No. Description NBT-19 Review of IIDR's This task has been closed by the State of Ohio as of April 28, 1983. Refer to Revision 14 of this report for text.
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Rev. 23 -- 9/16/83 Board Task Number 20 NATIONAL BOARD TASKS Task No. Description NBT-20 Temporary Change Notices This task has been closed by the State of Ohio as of July 22, 1983. Refer to revision 19 of this report for text.
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. Board Task Number 21
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I NATIONAL BOARD TASKS Task No. Description NBT-21 Qualification of NDE Personnel NATIONAL BOARD FINDINGS (Interim Report #2, Supplement 1)
"3.5 Non-Destructive Examination by the Henry J. Kaiser Com-pany's (the Installer's) Sub-Contractors.
3.5.1 Nuclear Energy Services Inc. (NES) is currently the non-destructive examination (NDE) sub-con-tractor to Henry J. Kaiser (HJK) for radiogra-phic (RT), magnetic particle (MT), non-destruc-tive examination.
3.5.2 The National Board Audit Team is reviewing and will continue to review NDE procedur e s , person-nel qualification and certification records of NDE performed for the Installer, Henry J.
Kaiser , under their ASME "NA" and "NPT" Certifi-cates.
3.5.3 NES apparently was placed on the HJK Approved O Vendor List (AVL) on May 14, 1982 as a result of a March 9, 1982 audit conducted by HJK. How-ever, a review of HJK's historical and current vendor documentation does not confirm that their NDE sub-contractor (s) had been surveyed and qual-ified by HJK prior to this date ( 3 /9 /82 ) as required by ASME Section III, 1971 Edition, Sum-mer 1973 Addenda. ASME Section III, 1971 Edi-tion, Summer 1973 Addenda requires the Installer
- (HJK) to survey and qualify the O.A. programs of suppliers of sub-contracted services , including j their NDE sub-contractors.
3.5.4 A review of NES records indicates that NES began invoicing HJK for NDE services on approximately i March 10, 1980. Prior to that time, Peabody Magnaflux Testing Laboratory was the NDE sub-con-tractor to HJK for non-destructive examination.
Peabody Magnaflux Testing Laboratory appears on HJK's Approved Vendor List f rom August 2, 1976 to 1980; however, no records of audits or sur-veys have been presented to the National Board Audit Team by HJK or CG&E that show Peabody Mag-naflux Testing Laboratory was ever surveyed or
, audited by HJK as required by the ASME Code.
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~ Rev. 23 -- 9/16/83 Board Task Number 21 3.5.5 The Nati.onal Board Audit Team, during the week
(") of July 12, 1982, requested f rom both CG&E and HJK records of Peabody Magnaflux Testing Labora-tory's NDE personnel qualification and certifica-tion records, NDE procedures used during the period on the Zimmer site, and a list of all personnel indicating time periods on site involved in NDE activities. To date these rec-ords have not been made available to the Nation-al Board Audit Team.
3.5.6 In th e opinion o'f the National Board Audit Team, ASME Section III, 1971 Edition, Summer 1973 Addenda requires survey and audit of NDE sub-con-tractors for qualification and retention of those records during the period of construction, and these records should be ava il a b l e for audit."
NATIONAL BOARD FINDINGS (Interim Report #5)
"3.1 The National Board Audit Team reviewed at random thirty (30) of the fifty (50) NDE personnel files of NDE exam-iners employed by Peabody Magnaflux (H.J.K. NDE subcon-tractor at an earlier date). This review was conducted
(]s l to determine if the review of these NDE personnel per-formed by HJK document reviewers and the HJK NDE Level III examiner, was adequate corrective action to allow HJK to confirm NDE qualification levels as being in compliance with ASME Section III (SNT-TC-1A 1968, 1975) and to close out CAR 118. CAR 118 was generated because of a previous HJK review of Peabody Magnaflux NDE personnel records that indicated deficiencies.
3.2 As a result of the National Board Audit Team review it has been determined that apparent deficiencies exist in the documentation used to support the certifications of several NDE examiners. The following are examples of these deficiencies.
A. William Baldyga
- 1. Resume contains no names or dates of employ-ment to permit verification to experience or training.
- 2. Certification s tatements are signed by per-sons of unknown status.
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Rev. 23 -- 9/16/83 Board Task Number 21 B. Russel M. Araujo
- 1. 'No resume or adequate statement of experience to support certification.
- 2. Certification statements not signed by employ-er's Level III or the employee.
C. R. Buckner
- 1. No resume or adequate statement of training or experience to support earlier certifica-tions.
- 2. Grades for RT Level I had been penciled in by unknown person with unknown basis for doing so (file copy of the examination record) in addition the examinations is neither signed nor legible. (Attachments 2-3 & 4) 3.2.1 It is the opinion of the National Board Audit Team that the review conducted of the Peabody NDE personnel files by HJK as a result of HJK Car #118 was inadequate in that NDE personnel have been certified as qualified without suf-ficient records to support the certifica tion s as required by SNT-TC-1 A and ASME Sectic.,n III and in some cases ce r ti fica tion statements are signed by persons of unknown status.
3.2.2 It is the opinion of the National Board Audit Team that HJK shall perform such audits and reviews as necess- ~r, of Peabody NDE examina-tion personnel files, to assure that the NDE examiners used at the Zimmer Nuclear Power Plant were qualified in accordance with ASME S ec t i on III and SNT-TC-1 A requirements. Also the required documentation to support their certifications are in the NDE examiners file.
If the NDE examiners cannot be properly certi-fied or qualified, the NDE performed by that NDE examiner is nonconf orming and shall be brought into conf ormance in accordance with H.J.K. QAP's. The National Board Audit Team shall be presented documentation resolving these findings."
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Rev. 23 -- 9/16/83 Board Task Number 21
SUMMARY
U l. The National Board Audit Team has questioned whether or not NDE subcontractors were qualified by the N A installer (Henry J. Kaiser) prior to performance of NDE service.
- 2. The National Board Audit Team has requested access to and has reviewed a portion of Peabody-Magnaflux NDE certi fica-tion records on file with Henry J. Kaiser to determine whether corrective actions through HJK CAR-118 were ade-quate. The National Board review indicates the Peabody-Magnaflux NDE personnel documentation is incomplete and contains apparent deficiencies despite closure of CAR-ll8.
If NDE personnel qualifications and certification cannot be properly documented as adequate, the NDE performed is nonconforming and shall be brought into conformance in accordance with HJK QAP's.
CG&E RESPONSE (Interim Report #2, Supplement 1, Item 3.5)
"We recognize the requirement for documentation of qualifica-tion and certification of NDE personnel, and f or survey, audit, and qualification of organizations to whom NDE is subcontracted.
H.J. Kaiser is currently assembling the qualification and certi-fs fication records of NDE personnel used, and is reviewing records
(') to provide evidence of the qualification of the subcontractors used. This documentation will be made available to the National Board when it becomes available to CG&E."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #2, Supplement 1, Item 3.5)
" Comments withheld until H. J. Kaiser provides the requested records to the National Board Audit Team for its review and evalu-ation.
CG&E RESPONSE (Interim Report #5, Items 3.1 and 3.2)
CG&E agrees the NDE personnel documentation is currently inade-quate and has been identified by HJK. Additional documentation has recently been acquired f rom Peabody-Magncflux and will be provided to HJK. HJK will review all NDE personnel certification records. Where such records are identified as inadequate, proper steps will be taken to assure all Code requirements are met.
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l Rev. 23 -- 9/16/83 Board Task Number 21 ACTION PLAN fS b HJK: a. Provide records of all NDE subcontractor surveys and audits to CG&E.
- b. Provide personnel qualification and certification rec-ords, NDE procedures used, and a list of personnel with dates of site work to CG&E.
- c. Review documents provided by Peabody and identify any deficiencies.
RFR: Review NDE records from (a), (b), and (c) above.
CG&E: Make records available to the National Board.
SCHEDULE Estimated Actual Responsibility Completion Completion HJK: a. October 25, 1982
- b. December 10, 1982
( c. September 23, 1983 .
l 23 RFR: September 16, 1983 l 23 CG&E: September 30, 1983 l 23 CURRENT STATUS HJK: a. Completed,
- b. Completed,
- c. Records with deficiencies will be documented on CARS.
Completed records to be reviewed by,HJK Quality Documen- 23 tation and transmitted to CG&E.
RFR: Completed. 23 CG&E: Awaiting records for review and presentation to l 23 National Board.
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Rev. 23 -- 9/16/83 Board Task Number 22 NATIONAL BOARD TASKS
.h V Task No. Description NBT-22 Radiographic Weld Identification NATIONAL BOARD FINDINGS (Interim Report'#2, Supplement 1)
"3.6 Radiographic Weld Identification 3.6.1 The National Board Audit Team requested HJK's Quality Engineering to identify procedures that address the responsibility for flagging or mark- '
ing to verif y the correct identity of field welds t'o be r a di og raphed. Quality Engineering indicated to the Audit Team that no procedures .
exist.
3.6.2 An "NDE Request Instruction" was reviewed by the National Board Audit Team. The instruction vaguely addresses the topic; however, it is an uncontrolled document which is not approved and distributed in accordance with HJK's QAP 9, Rev.
- 9. In the opinion of the National Board Audit Team, this does not meet the requirements of ASME Section III, 1971 Edition, Summer 1973 d Addenda.
3.6.3 Since HJK Quality Engineering has stated that no procedure exists, the National Board Audit Team is concerned with the possibility that personnel who are not properly trained and qualified may have been identifying and marking welds, causing a potential loss of integrity of the radiogra-phic weld identification. HJK should provide to the National Board Audit Team evidence that pro-per radiographic weld identification integrity has been maintained during the period of con-struction.
SUMMARY
There i s a concern that personnel identifying welds for NDE may not have been adequately qualified.
CG&E RESPONSE (Interim Report #2, Supplement 1, Item 3.6)
"We are evaluating this situation with H.J. Kaiser to assure
' that all field welds were properly identified and examined. The s
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Rev. 23 -- 9/16/83 Board Task Number 22 results of our evaluation will be made available to the National
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Board. In addition, document review will assure correlation of radiographs for all welds in a given system requiring radiogra-phy."
STATE OF OHIO COMMENTS ON CG&E RESPONSE (Interim Report #2, Supplement 1, Item 3.6)
" Comments withheld until H. J. Kaiser evaluation is complete and documentation is presented to the National Board Audit Team for its review and response."
ACTION PLAN HJK: a. Provide evidence that proper radiographic weld identi-fication has been maintained during construction.
- b. Per f orm sampling of RT film versus physical character-istics for weld identification, and report results.
RFR: Review HJK sampling report.
CG&E: Present results to the National Board.
) SCHEDULE .
Estimated Actual Responsibility Completion Completion HJK: a. December 15, 1982
- b. May 18, 1983 RFR: May 26, 1983 CG&E: May 27, 1983 CURRENT STATUS HJK: a. Completed.
- b. Completed.
RPR: Completed.
CG&E: Completed.
I Note: The National Board Audit Team has judged that this item
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(, will remain open until line walkdowns and as-constructed drawings have been completed, whereby it can be audited and verified.
Rev. 22 -- 9/02/83 Board Task Number 23 NATIONAL BOARD TASKS Task No. Description NBT-23 Weld Procedures NATIONAL BOARD FINDINGS (Interim Report #3)
"3.1 Henry J. Kaiser Weld Procedure SPPM 3.1.50, Rev. O.
3.1.1 This procedure'was originally qualified with impact testing. The procedure was used on pri-mary containment main steam penetration to seal head welds. The materials involved in these welds are SA350 Gr LF1 to SA516 Gr 70. The welds are identified on HJK Drawings PSK IMS 46, 48, 49 and 52. The welds are identi fied as Welds MS-M1, MS-M2, MS-M3 an d M S- M4 . The line numbers are identified as Lines IMSOA24, IMSOB24, IMSOC24 and IMSOD24, 3.1.2 ASME Section III, 1971 Edition / Summer '73 Adden-da, Para. NB 2 3 0 0 requires impact testing of materials within the thickness range of these weldments and base materials.
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i 3.1.3 ASME Section IX, 1971 Edition / Winter '73 Adden-da, states that a separate procedure qualifica-tion is required for each type and g rade of material when impact testing is a requirement.
3.1.4 ASME Section IX, 1971 Edition / Winter '73 Adden-da, lists an increase of more than 100 F in the specified maximum interpass temperature as an
. essential variable. ASME Section IX further lists as an essential variable a change in type of current (AC or DC), polarity, or specified range for amperage, voltage and speed of travel.
3.1.5 Weld Procedure Specification SPPM 3.1.50, Rev.
O, was qualified using SA106 Gr. B pipe and did not specify maximum interpass temperatures. Nor did it establich a speed of travel.
3.1.6 It is the opinion of th e National Board Audit Team that Procedure WPS SPM 3.1.50, Rev. O, shall be qualified in accordance with the requirements of ASME Section IX, 1971 Edition /
Winter '73 Addenda.
. The National Board Audit g3 Team also is of the opinion that Henry J. Kaiser (HJK) shall review other weld procedures of this
() type to assure that they comply with ASME Sec-
Rev. 22 -- 9/02/83 Board Task Number 23 tion III requirements and provide the National T Board Audit Team with documentation of this review identifying welds in the various systems where improperly qualified weld procedures were used and the proposed corrective action."
SUMMARY
Some weld procedures have not been properly qualified for all the essential variables as required by the ASME Code. Weld proce-dures should be reviewed to determine which procedures require requalification. If welds were welded with improperly qualified procedures, appropriate corrective actions should be identified to the National Board.
CG&E RESPONSE (Interim Report #3, Item 3.1)
"CG&E agrees that SPPM 3.1.50, Rev. O was not properly quali-fied in accordance with Sections III and IX. We are currently reviewing the impact of this problem on the welding which was done using this procedure. We will determine whether or not we can comply with the audit team's recommendation that this proce-dure be qualified. Regardless of whethe r or not we can comply with their recommendation, corrective action will be taken to bring the affected welds into compliance with Section III. We h) are currently reviewing other weld procedures of this type to determine the extent of this nonconf ontance."
ACTION PLAN HJK: a. Identify all welding performed on materials requiring impact testing. Determine the procedures, base materi-als, and weld filler metals used, and the heat treat-ment condition of the welds.
- b. Submit results of (a) to RFR for review,
- c. Per f orm procedure qualification testing f or the proce-dure variables identified in (a) above, using the maxi-mum possible heat input, and the appropriate base mate-rials.
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Rev. 22 -- 9/02/83 Board Task Number 23 RFR: a. Review documentation of HJK review of welding per-O formed.
- b. Review the HJK plans to qualify those procedures.
- c. Review completed procedure qualification.
CG&E: Present documentation to National Board.
SCHEDULE Estimated Actual Responsibility Completion Completion HJK: No schedule provided by HJK CURRENT STATUS HJK: In process; no results. Final results anticipated af ter complete historical review of all weld proce-dures.
RFR: Awaiting HJK action.
CG&E: Awaiting HJK action.
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1 Rev. 23 -- 9/16/83 Board Task Number 24 '
i NATIONAL BOARD TASKS
, Task No. Description NBT-24 Weld Filler Metal NATIONAL BOARD FINDINGS (Interim Report #3)
This task has been closed by the State of Ohio as of June 9, j 1983. Refer to Revision 16 of this report for text.
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Rev. 23 -- 9/16/83 Board Task Number 25 NATIONAL BOARD TASKS Task No. Description NBT-25 Generic NR's NATIONAL BOARD FINDINGS (Interim Report #7, Item 3.3)
"3.3.1 The National Board, Audit Team discussed with HJK personnel the use of the Generic NR. This entity was devised and first a ppeared in ZAPO-5, Rev. 2, TCN #5-7. The National Board does not understand either the intent of or need for a Generic NR.
3.3.2 TCN #5-7 has been reviewed and the National Board Audit Team has several questions : (1) Does each Generic NR have a corresponding Generic Disposition?
(2) Are Generic NR's dispositioned as other NR's, i.e., " accept as is", " reject", etc.? (3) If Gener-ic NR's are created and processed as any other NR, why have them? (4) How does the dispositioner know when to disposition an NR with a Generic Disposition?
(5) HJK's QA manual, QAP-16, Rev. 9, does not dis-cuss the Generic NR. Will this be revised? (6)
How does the AI get in the Generic D.i s po s i tion cycle?
3.3.3 The National Board Audit Team futher is of the opin-ion that if nonconforming conditions are such that a special NR system has to be created +.o handle them, then the proper vehicle to correct these conditions is by issuance of either a stop work order or a cor-rective action request, both of which are described in the HJK Quality Assurance Manual."
SUMMARY
The National Boa rd Audit Team has questioned the use of Generic NR's; i.e., Generic Nonconformances and Generic Dispositions.
CG&E RESPONSE (Interim Report #7, Item 3.3)
"CG&E understand the National Board Audit Team's concerns regarding the use of Generic NR's. CG&E will make. arrangements for a meeting to be held between CG&E, HJK and the National Board to discuss these concerns and identify an action plan for re solu-tion."
1 Rev. 23 -- 9/16/83 Board Task Number 25 ACTION PLAN O HJK: Revise and issue QAP-16 to incorporate Generic NR's.
SCHEDULE Estimated Actual Responsibility Completion Completion HJK Indeterminate CURRENT STATUS HJK: QAP-16 has been revised to comply with this task and other ASME activities and will be circulated for review and sig- 23 nature. Conflicting directions from CG&E are due to con-cerns not related to this task.
NOTE: The National Board Audit Team has judged that this item will remain open until the use of Generic NR's has been implemented for a sufficient period of time whereby it may be auditied and verifiable.
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Rev. 23 -- 9/16/83 Board Task Number 26 NATIONAL BOARD TASKS Task No. Description NBT-26 Data Reports for Piping Subassemblies NATIONAL BOARD FINDINGS (Interim Report #13, Item 3.1)
"3.1 The National Board Audit Team has recently been advised that HJK will not prepare NPP-1 Data Reports for field fab-ricated piping subassemblies as required by ASME Section III.
3.1.1 Piping subassemblies which have been fabricated in the on site ' fabrication shop have not been Code Sym-bol s tamped and the NPP-1 Data Report Forms _complet-ed as required by ASME Section III, 1971 Edition, Summer 1973 Addenda. Nor, apparently, was the alter-nate method as provided for by the Code used.
3.1.2 The National Board Audit Team is further of the opin-ion that identification and control of materials and parts, including par tially fabricated assemblies, shall be maintained either on the item or on records traceable to the item throughout manufacture or O installation.
3.1.3 It is the opinion of the National Board Audi t Team
, that HJK is in apparent violation of ASME Code re-quirements and HJK established procedures (Attach-ments 1 thru 12).
i 3.1.4 The National Board Audit Team shall be provided with
, HJK's proposed resolution of this aoparent Code defi-
[ ciency and documented evidence to indicate that HJK has complied with the requirements of the ASME Code.
SUMMARY
The National Board Audit Team has questioned HJK's procedure for documenting field-shop-f abricated piping subassemblie s and HJK's implementation of their procedures for such documentation.
Rev. 23 -- 9/16/83 Board Task Number 26 CG&E RESPONSE (Interim Report #13, Item 3.1)
In preparation.
ACTION PLAN In preparation.
SCHEDULE Estimated Actual Responsibility Completion Completion HJK: Not available CURRENT STATUS i HJK: HJK is reviewing National Board finding arid preparing i
response. Response will be provided to CC&E by Sept-ember 30, 1983.
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