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IGle National Bourb of Boiler anh firessure Ecssel 3nspectorsiS. F. HARRISON, Executwe oirector

COLUMBUS H O 43229 U S A.i e Noca A ansasPhone 614 888 5120 J. J. DUFFY

B L WHITLEY,1st Vice Chm. Telen 246425 State of Wisconsma.ie.ga. Hona C. oim. , , ,, ,,,,

g ygyg 62 7 I9Bi! jProvmco of Prmco Edward Island% g _w g

R K. BLO.SCH. 2nd Vice Cnm.S. t .Ca,.ui.m M C H WALTERS

QNNIVERSARQd Staie of Oregon

D.R.GA UP, Past hastman

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December 9, 1981

h,e \,g. yCincinnati Gas & Electric Company

c DEDI 619 sis 'llAttn: Mr. Earl A. Borgmann, -

Senior Vice President y u.s. %139 East 4th Street 1 ''*'m

Cincinnati, Ohio 45202 e, 7,

% 4SUBJECT: Investigation Conducted on December 8, 1981 4(4ca

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by Mr. Donald Milan, Chief Inspector of State''

of Ohio and Mr. Richard E. Jagger; NationalBoard of Boiler and Pressure Vessel InspectorsZimmer Nuclear Power Plant; Moscow, Ohio

REFERENCE: Improperly Shimmed Pullman Power RadiographsConformation ProgramSocket Weld NonconformancesImproprieties Regarding NonconformancesLack of ANI InspectionsDocumentation Deficiencies

Dear Mr. Borgmann:

The subject investigation was held at the request of the Stateof Ohio to review the referenced problems, to determine the statusof items under continuing investigation, and to see if further areasor items should be subjected to future examination.

The following additional people were contacted during this =ceting:

Mr. Robert Arthur; Cincinnati Gas & Electric CompanyMr. Harlan R. Sager; Q. A. Manager, Cincinnati Cas & Electric CompanyMr. Rick Leiber, Level III, NESMr. Lowell Burton, ANI, Hartford Steam BoilerMr. John Watkins, Cincinnati Cas & Electric CompanyMr. David Howari, Cincinnati Gas & Electric Company

6!|08112170275 811209 (PDR ADOCK 05000358s PDR- -

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ACTION TAKEN TO DATE

1. In response to our. recommendation a . review was being made ofall Pullman Power radiographs, due to questions raised byNRC.and by this investigation team.

2. We audited the review program by checking the re-review log,,

and by spot checking final radiography packages to see thatthey had both the original and re-review "RT" reader sheets.

3. The status of the review as.taken from the computer on thisdate is as follows:

TOTAL RADIOGRAPHS

Accept as is 2219Cannot Interpret 78To be Reshot 426Sensitivity Level I 298Sensitivity Level 2 10401Properly Shimmed & Accepted 4354Sensitivity Level 4 2247No Sensitivity 122

Total Views Revivaed 17419

The corrective action being taken to date on the radiography sensitivityproblem was in compliance with our previous recomsendations.

However this must remain as an open item and none of the radiographscan be accepted until the proper control comparison radiographs have beentaken and evaluated.

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New Items

* 1. A review of drawing ISK-D01-M427-1-D0-1 - Revisions 1, 2, 3, 4,5 and 6 disclosed discrepancies and unaccountability of acceptancefor socket welds B1 and B2.

The welds which had originally been stamped accepted by Q. C.on revision (1) were later cut-out. Acceptance of the replacementwelds could not be verified, and it appeared that a breakdown had

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occurred in the documentation of identification and inspection )portions of the Quality Assurance program.

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Page.(3).Mr.'BorgmannDecember 9, 1981

2. Evidence was obtained wherein items which were nonconformancesas defined by the Kaiser Quality Ascurance Manual were improperlylisted on " Surveillance Reports" in lieu of issuance of non-

conformance reports as required.

3. A review of numerous weld histories disclosed the fact that theQ. C. Inspection " Transfer Acceptance Stamps" were being usedimproperly. Kaiser Q. A. Procedure 15 paragraph 3.1.3 providesfor use of such a stamp only when satisfactory documentation hasbeen provided. Contrary to the requirement a search of the filesfailed to show that appropriate documentation had been provided.Hence many of the welds which had been stamped acceptable under-

this proviso must be classified as questionable until the documentationis complete.

4. Procedures were not being followed which would assure compliancewith NCA-4134.3(c) of Section III, Div.1 ASME for the review,,

approval, release of documents necessitated by revisions.

5. The obliteration of entries by Q. C. Inspectors on nonconformancereports is an apparent violation of ASME Section III Division Coderequirements. Paragraph: NCA-4134.10 and NCA-4134.15.

The improper removal of hold tags, and failure of Kaiser QualityControl to assign NR numbers and enter the nonconformance intothe nonconformance system, when NR reports were submitted is alsoan apparent violation of the aforementioned paragraphs. It wasfurther determined that Kaiser reports numbered CN-5476, CN-5477,and CN-5479 were improperly voided, and copies of these reportswere deleted from the NR system in difference to ASME Code requirementsand the Kaiser Q. A. Manual.

6. Information was provided which disclosed the requirements of SectionIII, Div.1 ASME Code paragraph NCA-4134.1 were not being followed.

Persons performing Quality Assurance program inspections were notbeing provided the required freedom and authority to initiatequality control functions.

7. Contrary to ASME Section III Div. 1 paragraph NCA-4134.15 andKaiser Procedure QACMIG-4 nonconformance reports were being improperlyvoided without proper evidence for voiding, (NR-E-2237) incorrectlydispositioned (NR-E-2596), voided by improper personnel (CN-5479),and voided with inadequate justification (NR-E-2466). Variousnonconformance reports which had been issued NR numbers had notbeen. filed or retained in the Site Documentation Center as required.

8. The requirements of ASME Code Section III 1971 Edition ArticleNB-3661.5(b) were not being adhered to as required. Further

' Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, NA-4451,.

NB-4230,' and NB-3661.5(b) which require inspection for fit-up andwelding were'not performed properly. It was determined that several

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Page (4):Mr. BorgmannDecember 9, 1981

different methods of verifying " pull back" on socket welds wereemployed, some of which would prevent verification and inspectionas required by Article NB-3661.5(b).

9. It appears that a serious breakdown in both the Kaiser andCincinnati Gas 'and Electric Quality Assurance Prograns has joccurred, j

10. In. testimony taken frem.the Authorized Nuclear Inspector Mr. LowellBurton of the Hartford Steam Boiler Inspection and InsuranceCompany during the course of this investigative visit, twoapparent attempts of intimidation had been made.-

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11. A review of _ the Authorized Inspectors logs on site showed thatfor-approximately 90% of the time period under which this plantwas under construction, only one ANI had been assigned. The plant'is now 97% complete. It is impossible for one ANI to inspectto ASME requirements under normal situations, and to assume oneANI- can maintain proper inspection monitoring when the QualityAssurance-Program is not functioning properly is ludicrous.

One ANI in a nuclear plant under construction can only givecosmetic and token type inspection service. If the ASME thirdparty inspection philosophy is to be meaningful, we must haveproper and adequate inrpection by ANI. If five or six inspectorsare needed on site to achieve this level of confidence, thenwe should insist on that number. It is believed many of-theaforementioned deficiencies, errors, and omissions could havebeen prevented if there had been more Authorized Nuclear Inspectorson site.

Conclusions

In order to verify that we have complied with the ASME Code requirementsa National Board investigation is necessary and should be initiated at anearly date.

The number of Authorized Nuclear Inspectors on site should be increasedimmediately from one to four, with an understanding that more would be providedif it was demonstrated they could be utilized.

Respectfully,'

/Affj#f o*,

Richard E. Jag erAssistant Director of Inspections

REJ/ddcc: D. J. Mcdonald, NB

S. F. Harrison, NBD. Milan, Chief Inspector of OHj

,' V. Stello, NRC-Washington DC v

K. Ward, NRC-Glen Ellyn, ILR. Arthur, H. R. Sager, J. Watkins, D. Howard-Cincinnati Gas & ElectricR. Leiber, NES

R. F. Warnick, Director; Region LII-NRC-Glen Ellyn ILJ. G. Keppler, NRC-Glen Ellyn, IL