IR 05000358/1979015
| ML19256B627 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/06/1979 |
| From: | Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19256B624 | List: |
| References | |
| 50-358-79-15, NUDOCS 7908150370 | |
| Download: ML19256B627 (13) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/79-15
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Docket No. 50-358 License No. CPPR-88 Licensee:
Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name: Wm 11. Zinner Nuclee r Power Station Insrection At: Wm 11. Zimmer Site, Moscow, Ohio Inspection Conducted: May 8-11 and 17-18, 1979 00 h/$C&s-Inspectors:
C. C. Williams
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C'd'9.Edn fh ^ J. J. Harrison
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Yu)U' $z Approved By:
D. H. Danielson, Chief
Engineering Support Section 2 Inspection Summary Inspection on May 8-11 and 17-18, 1979 (Reference Report No.
50-358/79-12)
Areas Inspected:
Suppression pool modification fabrication activity associated with the second actuation of main steam relief valves in response to 50.55(e) report dated January 23, 1978, and Section 1.5.0 of the closure report " Plant Modification and Resultant Improvements."
The inspection involved a total of 28 inspector-hours onsite by one inspector (May 8-11) and a total of 38 inspector hours (May 17-18)
onsite by two ir.spectors.
Results:
Six items of noncompliance involving 12 examples were identified in the area inspected, relative to control of special processes, material qualifications, procedural requirements, and documentation. As a result of these findings, an Inunediate Action Letter was issued on May 11, 1979, by the NRC, directing the licensee to stop work, perform a QA audit, resolve identified deficiencies and secure NRC concurrence prior to further suppression pool modification.
(See Details, Sections 2.d.(1)-(15).)
790815c,m
DETAILS
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Persons Contacted Cincinnati Gas and Electric Company (CG&E)
- E. A. Borgmann, Senior Vice President (May 11, 1979)
- W. W. Schwiers, Principal QA&C Engineer
- B.
K. Culver, Project Manager B. A. Gott, General Construction
- D. C. Kramer, Engineer QA&S R. L. Wood, Auditor QA&S J. F. Weissenberg, Auditor QA&S H. Brinkman, Engineer J. Herman, Engineer
- E. P. Ebas, Auditor QA&S L. D. Lundstrom, Auditor QA&S J. W. Haff, Auditor QA&S P. G. Davies, Auditor QA&S Kaiser Engineers, Incorporated (K&I)
- R.
Marshall, Construction Manager
- E. V. Knox, Corporate QA Manager
- R. E. Turner, QA Manager A. C. Pallon, QA Engineer E. Gaertner, Welding Engineer D. Dondovan, QA Inspector K. Renfro, Foreman G. Adams, Superintendent G. Jodrey, QA Inspector A. Winslow, Weldor J. Douglas, Weldor D. Rose, Superintendent E. Lehan, Boiler Maker Sargent and Lundy T. Botolini, Engineer Hartford Steam Boiler Inspection and Insurance Company (HSBI)
- A.
H. Clark, ANI L. R. Burton, ANI
- B. A. Je f f ery, ANI
- Denotes those present s'. the exit interview.
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Functional or Program-Areas Inspected 1.
Supression Pool Modification Construction Activity (May 8-11, 1979)
(Reference IE III Report No. 50-358/79-12,Section I)
As previously reported, the licensee has initiated structural modifications to the suppression pool and associated piping, to accomodate engineering concerns relative to the second actuation
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of the main steam safety valves. This matter and the licensee's
commitments relative to its resolution are as documented on
" Potential 50.55(e) Report" dated September 19, 1971, and other related documents.
The modifications in process at this time include (1) replacement of the downcomer " bull heads" with "T" Quenchers, (2) increasing the pipe diameter from 10" to 12", and (3) installation of quencher base plates on the floor of the suppression pool.
During this NRC inspection, those fabrication and QA/QC activities associated with the installation of the
"T" quencher base plates were examined.
2.
Installation of Suppression Pool Embedments
"T" Quencher Base Plates (May 8-11, 1979)
a.
Kaiser is the principal constructor for this modification and Sargent and Lundy is the architect engineer.
In addition to Kaiser's QA/QC activity, CGE QA&S group has responsibility to audit the quality of this work. This modification is directed by S&L specification H-2174 and associated design documentc. A Sargent and Lundy engineer is stationed at the site to facilitate the implementation of these requirements.
This specific activity encompassed removal of the existing suppression pool liner plate, core boring to install anchor bolts for the 13 "T" quencher base plates, and required grouting and welding activity. The base plates are 4" thick, approximately, 6' x 6' carbon steel plates, and the existing liner plate is 1/2" thick carbon steel with stainless steel cladding. The base plates are located in two concentric circles around the reactor pedestal.
b.
On May 8 and 9, f979, the inspector examined the S&L specification No. H-2174, Engineering Change Request No.
1088 governing this work. No adversities were noted.
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The inspector examined the principal drawing (S&L No.
S-460) and 16 Design Document Changes (DDCs) to this drawing. All had been properly approved. The inspector examined the welding procedures Nos. 3.1.57, 3.1.59 and 3.1.80.
The material purchase orders for plate, anchors and grout were also examined. The content of these documents was discussed with the cognizant QA engineer relative to their review cont rol and implementation.
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On May 9, 1979, the inspector reviewed all existing Noncon-formance Reporis and Design Document Changes associated with this activity. The content of those documents was discussed with the cognizant CG&E and Kaiser personnel.
Subsequently, the inspector examined Material Certification and other document requirements for the material used in thit modification.
The inspector made a topical review of the Kaiser QA program and the applicable QA and Special Process proce-dures which govern this work.
The contents and imple-mentation methods and responsibilities were discussed with the licensee and Kaiser personnel.
After reviewing the design documents, special process c.
procedures, and QA/QC requirements and responsibilities with CG&E and Kaiser QA personnel, the inspector contacted Kaiser Construction forces (Superintendent, Foreman, QC Inspectors, Weldors, and the S&L Engineer). During these contacts, all work in progress and related records within the suppression pool on both day and night shifts was observed and examined by the NRC inspector. The Filler Material Disbursement Center and associated records were also examined. Gen rally, the workmanship relative to welding and grouting appeared to be commensurate with industrial standards. However, certain noncompliances with QA/QC requirements were identified as follows; next paragraph.
d.
As a result of the above inspection activities on May 8-11, 1979, the inspector identified a significant number of unresolved issues and noncompliances to specifications and QA/QC commitments as identified in the following paragraphs:
(1) During the inspector's examination of work in progress within the suppression pool, on May 8-11, 1979, it was observed that none of the grinding and other-4-
tools wsre positively identified as required by Kaiser QACMI procedures (No. 9) to preclude contamin-ation of certain stainless steels as directed by
" suppression pool" welding procedures No. 3.1.57 among others. This is an item of noncompliance.
(See Appendix A, Paragraph 1.a.)
(358/79-15-01)
(2) During discussion with the CG&E cognizant engineer,
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the inspector questioned the adequacy of the anchor
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bolt tensioning instructions on drawing No. S-406
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relative to the need for more comprehensive procedures.
A manufacturer's instructions for the tensioning device used was presented. However, various of the personnel involved (Kaiser superintendent foreman and S&L engineer) indicated that the subject manufacturer's instruction had not been used for this work and its approval status could not be established (May 8-11, 1979). The contructor committed to immediate corrective action.
The inspector concludes that adequate and documented procedures were not available for tensioning. This conclusion is based on the confusion among site personnel as to the status of this manufacturer's instruction, the inspectors examination of the content of the manufacturer's instruction provided by S&L drawing No. S-406 including Design Document Changes.
This item is considered an item of noncompliance.
The licensee and constructor committed to immediate corrective action.
(See Appendix A, Item 1.b.).
(358/79-15-02)
(3) During the inspectors examination and observation of weld filler metal disbursement center (rod-shack) it was observed that the operability status identifica-tion and control of portable weld rod heater boxes was in apparent complete disarray and not in accor-dance with procedures. The boxes had mutiple identities, verification status dated back to 1974, and inoperable heaters were not identified as such.
The licensee initiated immediate corrective action.
This is an item of noncomplian e.
(See Appendix A, Item 1.c.)
(358/79-15-03)
(4) During the inspectors examination of the documentation required by purchase order No. 3336 for the "T"
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quenche~r base plate material (4" thick ASTM A-588) it was determined from the available records that the requirement for 100% ultrasonic examination was not accomplished for 11 of the 13 plates. The available UT reports indicated that the inspection for these places was done on a 24" grid which could mean that as little as 5% of the plate was UT examined. This material has been installed.
This is an item of
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noncompliance.
(See Appendix A, Paragraph 2.a.)
(358/79-15-04)
(5) S&L specification and drawings (S-406) requires that EMBECO-636 grout be used to anchor the base plate anchor bolts. Although this material has been purchased and used at this site for several years, a Material Certification or other competent document constituting documentary evidence of quality was not and has never been available at the site.
The licensee initiated corrective action. This is an item of noncompliance.
See Appendix A, Item 2.b.
(358/79-15-05)
(6) During the inspectors examination of the weld filler material disbursement center (rod shack) it was observed on three consecutive days that filler material and consumable inserts were maintained in heater ovens and shelves without benefit of documented trace-ability to heat / lot numbers or other controlling identification. Discussion with attendants resulted in dif fering information between night and day shif ts.
" Oven Maps" that were available were either in error or otherwise not useful. This is an item of noncom-pliance. See Appendix A, Item 3.a.
(358/79-15-06)
(7) Duriog the inspectors examination of liquid penetrant
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materials within the suppression pool, an untraceable container of liquid penetrant dye material whose contents appeared contaminated with foreign substances was identified. The lot of other identifying number for this container of LP material was not available.
This is an item of noncompliance.
See Appendix A, Paragraph 3.b.
(358/79-15-07)
(8) During the inspectors observations and examination of the filler material disbursement center (rod shack)
on May 10, 1979, a filler material heating oven (No.
57) was o';erved to contain the lunches (food) of the-6-
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rod shack attendant.
Such practices increase the risk of contaminated filler material and are prohibited by standard industrial practices. Recent audits by Kaiser QA demonstrated that this rod oven is used for Class 1 materials. The Kaiser management took immediate corrective action. This is an item of noncompliance.
See Appendix A, Paragraph 4.a.
(358/79-15-08)
(9) During the NRC inspectors observation of welding activity within the suppression pool, several weldors were observed to possess gas fired " heating" torches.
When the weldors and their foremen and superintendent were questioned as to the use of these torches, they reported, in summary, that the torches were used for prehtat or moisture control when needed. However, the Kaiser welding procedures (i.e. 3.1.57) specified that only electrical heat sources shall be used for these purposes. The Kaiser welding engineer concurred in that the WPS required the use of electrical heating to preclude contamination of stainless steels and for better control. This matter is an item of nonconformance to weld procedure requirements.
See Appendix A, I*.em No. 4.b.
(358/79-15-09)
(10) During the inspectors periodic observations over a three day period within the suppression pool and review of the available KEJ forms (weld data sheets),
it was observed that neither the weldors, their foreman nor the weld inspector verified the welding interpass temperature requirements of the procedure.
In fact, the production personnel appeared unaware of the temperature requirements. Neither the inspectors nor the weldors were equipped to make such determinations.
This is considered an item of noncomformance to special process procedural and QA requirements. See Appendix A, Paragraph 4.b.
(358/79-15-10)
(11) During the inspectors examination of the weld filler material disbursement center (rod shack) on May 9-10, 1979, day and night shifts, approximately 50 containers of apparently nonconforming weld rod were observed to be stored among reportedly conforming materials without benefit of nonconforming identification or identified segregation. Discussion with rod shack personnel on both day and night shifts disclosed discrepancies in the " understood" acceptance status of these materials. This is an item of noncompliance.
See Appendix A, Item 5.a.
(358/79-15-11)
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(12) During it
.nspectors examination of the work activity within the suppression pool, the welding fabrication records (weld data sheets - KE-1 forms) posted in the immediate vicinity of the "T" quencher base plate installations were examined.
It was observed that records for base plates IF, IM and ID did not appear to be commensurate with the status of t.
work.
Moreover, such surveillances reflecting interpass
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temperature control and " preheat" had not been filled
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out.
During discussion with licensee and Kaiser personnel, it was established that other copies of these records exist and that "the hard" copy of KE-1 form was maintained at the inspector's and foreman's office area.
In fact, the Kaiser inspectors maintained
" notebooks" on this work and the accurate fabrication records are transferred from these personnel notebooks to the hard copy of the KE-1 form. This practice is not in accordance with the governing Kaiser procedure (Special Process Procedure Manual No. 8) and instruction on the KE-1 form. The licensee committed to take immediate corrective action and is considering a procedure change to include the described practice.
This is an item of noncompliance.
See Appendix A, Item 6.a.
(358/79-15-12)
(13) Training and Indoctrination of Craft Personnel During this inspection, the NRC inspector found that certain craft superintendents, foreman, and filler material control attendants appeared to be less than comprehensively knowledgable in the areas of the assigned responsibility. This matter was brought to the attention of Kaiser and CG&E management and will be further examined during a subsequent inspection.
This is an unresolved issue.
(i;B/79-15-13)
(14) Design Review Examination of the principal S&L drawing (No. S-406, Rev. H) showed that approximately 16 Design Document Changes (DDCs) have been issued against this drawing.
The inspectors concern is that the number of chant.es in areas that immediately impact the current fabr: cation activity could possibly indicate inadequate desig1 review. The licensee is to pursue this concern with the architect engineer. This matter will be furtder examined during subsequent inspections. This issle is unresolved.
(358/79-15-14)
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(15) Disposition of Nonconformances The inspector examined all nonconformances and Design Change Documents. All of the nonconformances had been properly reviewed. However, several dispositions did not appear adequately based. Specifically:
(a)
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Nonconformance Report No. E-1762, documenting the identification of " nicked" rebar, end the resolution
of this matter, does not report the final depth of the grinding necessary for repair; the licensee is to provide additional documentation; (b) Several ncncon-formance reports (i.e. Nos. E-1765, E-1768 and E-1778)
identify material machining discrepancies. However, it is not clear what the caus-of these discrepancies were, nor is it clear that adequate torrective action to prevent recurrence was taken. The licensee is to pursue this concern. This matter will be reviewed during subsequent inspections. This issue is unresolved.
(357/79-15-15)
As is outlined in Paragraph d above, a significant number e.
of noncompliances and concerns were identified relative to this suppression pooi modification work.
It was estab-lished on May 11, 1979, that the licensee had scheduled, but had not performed a formal audit of this activity.
On May 11, 1979, the NRC inspector concluded that all suppression pool construction activity should be stopped until such time that the licensee has (1) performed a comprehensive audit of all areas of this work, and (2)
taken corrective action on all identified nonconformances and problem areas including those identified by this inspection. The inspector concluded further that the licensee should perform no further work until NRC has reviewed and concurred with their audit effort and corrective action.
During the NRC exit interview, dated May 11, 1979, the licensee's senior vice president concurred with the above
"stop work and audit" conclusions, and the necessary arrangements were discussed by the licensee's and NRC III management personnel.
Subsequently, the licensee issued stop work order No.
79-05 on May 12, 1979, which required that all work related to the MSRV modifications was to be stopped immediately.
The stop work order is attached to this report as Exibibit A.
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The NRC Region III staff issued an Immediate Action Letter transmitting NRC understanding that (1) all such work would be stopped, (2) the licensee would audit all modification fabrication activities, (3) take corrective action on all noncompliances, and (4) continue the work suspension until NRC has evaluated and concurred with the results. This document is attached to this report as Exhibit B.
"
f.
NRC Evaluation of Licensees Response to Immediate Action Letter IAL) Dated May 15, 1979 (1) On May 16, 1979, the licensee informed NRC III that their actions in response to NRC I AL dated May 15, 1979, were complete and certain corrective actions relative to their findings had been initiated.
(2) On May 17 and 18, 1979, two NRC inspectors were dispatched to the site to evaluate the licensee's audits findings and corrective actions.
(3) During this inspection, the NRC inspectors examined nine separate audit reports (Nos. 234-242) covering work associated with the suppression pool modification.
Seven of these audits identified noncompliances other than those previously identified by the NRC on May 8-11, 1979.
Corrective actions were either complete or were in process at the time of this inspection.
(4) Discussion with each of the auditors and principal production and QA personnel demonstrated, in addition to the documentation, that the licensee's corrective action efforts had been comprehensive and responsive to the NRC concern. Several of the documented audits required addenda as a result of NRC examination.
However, acceptable addenda were completed and issued during this NRC inspection.
(5) Observation of the suppression pool fabrication area demonstrated that only maintenance activity had proceeded since the issuance of the stop work order.
Examination of the weld filler material disbursment center showed that all areas now conform to the requirements.
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(6) NRC reviewed each of the nonconformances identified by the licensee and by the previous NRC inspection.
In each instance, the corrective action taken or in process, appeared appropriate. Retraining and indoc-trination of certain personnel had been accomplished.
(7) As a result of the licensee's audit of the suppression pool modification, the following QA/QC and special
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process procedural revisions have been made or are in
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process:
(a) Anchor Bolt Tensioning Procedures (b) Tool Control Procedure No. QACMI-9 (c) Weld Procedure No. SPPM-3.1.57 (d) Weld Procedure No. SPPM-3.1.59 le) Weld Procedure No. SPPM-3.1.80 (f) Electrode Control Procedure No. SPPM-3.3 Rev. 5 (g) Weld Data Form (KE-1) Control Procedure No.
SPPM-8.0, Appendix B and F (h) Design Document Control Procedure No. FCP-2.6 (B) At the conclusion of this NP.C inspection on May 18, 1979, the NRC determined that the CG&E stop work crder issued on May 12, 1979, relative to the suppres-sion pool modification work, could be conditionally rescinded. The condition is that no work may proceed in any area or with any material where procedural revision is incomplete or unresolved issues exist.
The licensee concurred with this requirement and issued a conditional suspension of stop work order No. 79-05 on May 21, 1979, which is attached here as Exhibit C.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs 2.d(13), 2.d(14) and 2.d(15).
Exit Interview At the close of each portion of this inspection, the NRC inspectors discussed results with the licensee's representatives as documented under Persons Contacted. The licensee was informed that special inspections of this modification work will continue until complete.
Attachments: Exhibits A-C
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Exhibit A, IE Report No. 50-358/79-
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STOP WORK ORDER
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B. K. Culver f; umber:
79-05 R. Marshall Date:
5-12-79
' This is notification that work is to be suspended immediately (5-11-79 Second Shift) on all construction activities related to the MSRV rodifications in the suppression pool on the Zimmer Site.
This Stop Work Order applies to all work activities in the suppression char,ber and related activities in fabrication shops on site, Dut does not apply to work perfonned by suppliers and vendors in their shops which arc covered by their QA Program.
Quencher and other suppression pool related material may be received on site, but must be placed in quarantine.
Activities which affect the future quality of work performed in the past, such as curing grout or grinding welds to remove contaminents, tool removal, safety, security, maintenance, and similar activities may continue to be performed.
.r.is Stop Work Order will remain in effect until all elements of the NPC audit Cenducted from 5-8 to 5-11-79 are resolved and acceptable to the tiRC.
Doason:
NRC Inspection conducted from 5-8-79 to 5-11-79 identified nonconforming and unresolved items with regard to suppression pool work at the Zimmer Site.
Prepared By:
. O bd
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Approved By:
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cc:
E. A. Borgmann W. D. Waymire J. R. Schott Henry J. Kaiser Co.
Attn:
R. E. Turner
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