IR 05000358/1980027

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Mgt Meeting Rept 50-358/80-27 on 801216.High Number Fo Items of Noncompliance W/Regulatory Requirements Noted.Overall Regulatory Performance Adequate.Major Areas Discussed:Nrc Systematic Assessment of Licensee Performance
ML20003B909
Person / Time
Site: Zimmer
Issue date: 02/03/1981
From: Heishman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20003B904 List:
References
50-358-80-27, NUDOCS 8102260107
Download: ML20003B909 (10)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND EhTORCEMENT

REGION III

Report No. 50-358/80-27 Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name:

W. H. Zimmer Nuclear Power Station Meeting At: Cincinnati Gas and Electric Company Corporate Office, Cincinnati, Ohio Meeting Conducted:

De_ ember 16, 1980 NRC Personnel Present:

J. G. Keppler, Director, Region III R. F. Heishman, Chief, Reactor Operations and Nuclear Support Branch R. F. Warnick, Chief, Reactor Projects Section 3 R. C. Knop, Chief, Construction Projects Section 1 I. A. Peltier, Project Manager, NRR

I. T. Yin, Reactor Inspector Approved By:

. F. Heis n, Ch Reactor Operations and Nuclear Support Branch Meeting Summary Management Meeting on November 20, 1980 (Report No. 50-305/80-27)

Areas Discussed: Management meeting held at the NRC's request to discuss the regulatory performance of the activities at the Zimmer Nuclear Power Plant as concluded in the NRC's Systematic Assessment of Licensee Perfor-mance (SALP) program.

Results: A summation of the licensee regulatory performance evaluation was presented. Although the number of items of noncompliance with regulatory requirements was relatively high, the licensee's overall regulatory performance was considered to be adequate.

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DETAILS 1.

Persons Contacted Cincinnati Gas and Electric Company

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E. A. Borgmann, Senior Vice President, Engineering Services and Electric Production K. K. Chitkara, Manager, Nuclear Fuel and Advanced Engineering Projects J. D. Flynn, Manager, Licensing and Environmental Affairs S. G. Salay, Manager, Electrical Production Department W. W. Schwiers, Manager, Quality Assurance W. D. Waymire, Manager, General Engineering Department H. C. Brinkmann, Principal Mechanical Engineer Nuclear Projects B. K. Culver, Manager, Generation Construction J. R. Schott, Plant Superintendent

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2.

Areas Discussed a.

The background of the SALP program was presented, including the development, the need for evaluation, the method of evaluation, and the purposes of the SALP program.

b.

The results of the NRC's evaluation of the licensee's performance were discussed.

(A copy of the evaluation is enclosed).

c.

An analysis of Zimmer's noncompliance data for the SALP period (October 1, 1979-September 31, 1980) was presented. Compara-tive data for the SALP period for plants under construction in Region III was presented.

3.

Licensee Comments The licensee commented during the presentation of each of the areas in paragraph 2 and discussed several matters of concern as follows:

a.

Concern was expressed over the negative aspect of the SALP evaluation. The NRC concentrated on the problem areas but said little about the areas that were satisfactory.

b.

During the discussion regarding staffing, the licensee indicated that on numerous occassions they had requested guidance from the NRC on staffing requirements. They expressed concern that the NRC was not able to define staffing requirements. The licensee indicated they have been tryic; to hire individuals with BWR experience but that of the thousands of resumes reviewed, very few have BWR experience. The licensee reported that they have increased their staff size, that numbers alone do not make an adequate staff, and that they are continuing to look for ex-perienced people to hire.

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B c.

The problems regarding pipe hangers and supports were discussed in considerable detail. The licensee described the significant effort they were making to assure conserva-tive design and construction in this area. There was a difference of opinion as to the cause of the snubber and hanger problems.

Enclosure: Zimmer Performance Appraisal Report-3-

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LICENSEE PERFORMANCE EVALUATION

CONSTRUCTION NRC REGION III facility:

W. H. Zimmer Nuclear Power Station m

Licensee: Cincinnati Gas and Electric Company Unit Identification: Docket No. 50-358 License No. CPPR-88 Date of Issuance - October 27, 1972 Reactor Information:

NSSS - General Electric MWT - 2436 Appraisal Period: October 1, 1979 through September 30, 1980 Appraisal Completion Date: October 27, 1980

  • Review Board Members:

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R. F. Heishman, Chief, Reactor Operations and Nuclear Support Branch G. Fiorelli, Chief, Reactor Construction and Engineering Support Branch R. F. Warnick, Chief, Reactor Projects Section 3 R. C. Knop, Chief, Construction Projects Section 1 C. J. Paperiello, Chief, Environmental and Special Projects Section J. F. Donahue, Chief, Physical Security Section

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I. A. Peltier, Project Manager, NRR F. T. Daniels,. Senior Resident Inspector C. M. Erb, Reactor Inspector I. T. Yin, Reactor Inspector K. D. Ward, Reactor Inspector E. J. Gallagher, Reactor Inspector J. Hughes, Reactor Inspector T. E. Vandel, Reactor Inspector

  • Either attended review board meeting on October 27, 1980 or provided written or verbal input to the evaluation.

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DETAILS 1.

Number and Nature of Noncompliance Items Noncompliance Category:

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Violations

Infractions

Deficiencies

Areas of Noncompliance:

(Points)

Operations

Construction 172 Security

Rad. Prot., Environ. Mon., Conf.

Meas., Emer. Plan.

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Total Points 264 Inspection Reports covered by this review:

No. 50-358/79-17 plus No. 50-358/79-29 through 79-39 and No. 50-358/80-01 through 80-21 Evaluation of Noncompliance Items:

Operations - During the SALP period 13 inspections were performed in this area.

Nine infractio.'s and one deficiency were identified Three infractions pertaining to inadequate corrective action have resulted in many changes to the management system for tracking problems.

A marked improvement in completion of corrective actions has been observed, although in some cases the target completion dates have not been met.

An increased awareness of commitments made and their completion is still needed by management. Two infractions pertaining to new fuel inspection have resulted in improved performance in this area. One in-fraction involved failure to maintain cable tray cleanliness to prevent damage to safety related cables. Appropriate action was taken to prevent recurrence and the cable tray cleanliness has improved. Two infractions involved system turnovers and one infraction involved revisions to docu-ments and drawings.

Although none of these items are significant by themselves and licensee i

management has been responsive to NRC ider",1fied concerns, the licensee's Quality Assurance system has not identified these same concerns. Emphasis needs to be placed on identifying and correcting deficiencies in the im-plementation of the QA program. Also, an increased management awareness of commitments made and the required completion dates is needed.

Radiation Protection - As of the last preoperational inspection in the area of radiation protection in January 1980, the licensees program for-2-

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radiation protection was progressing adequately to insure completion prior to the expected date for issuance of the Operating License.

Environmental Monitoring and Confirmatory Measurements - The licensee performance in the areas of preoperational environmental monitoring, confirmatory measurements and analytical quality assurance has been above average. No items of noncompliance have been identified.

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Emergency Planning - The scope of the routine emergency planning inspec-tions will be increased because of the revision to Appendix E of 10 CFR 50.

Security - The licensee's security plan is under review by the Office of Nuclear Material Safety and Safeguards. For the present status of plant construction, the security program including protection of new fuel 8.s being satisfactorily implemented.

Construction - During the SALP period 1(, inspections including three in-vestigations were performed by the Region III Reactor Construction and Engineering Support Branch. Seventeen infractions and one deficiency were identified. The 18 items of noncompliance were divided between ten of the eighteen criteria of Appendix B to 10 CFR 50 as follows:

Ncacompliance Criterion Subject Items II QA Program

III Design Control

V Procedures

VI Document Control

IX Special Processes

X Inspection

XI Test Control

XIII Handling & Storage

XV Nonconforming Materials

XVI Corrective Actions

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Six of above listed noncompliance were caused by failure to follow procedures, four were caused by inadequate procedures, three were attributed to design problems, one was caused by inadequate construction practice, one was caused by carelessness, and one was attributed to poor housekeeping.

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Summary - The noncompliance history is of regulatory concern. The number of items of noncompliance at Zimmer is the highest of any plant under con-struction in Region III. Although construction activities have been winding down, the numbers of noncompliaace items remain high (1979: 39 inspections -

24 infractions and six deficiencies; first ten months in 1980:

23 inspec-tions - 19 infractions and two deficiencies).

Licensee management needs to focus additional attention on the implementation of the QA program,the identification of problems,and corrective actions. Not withstanding the

above, with the exception of pipe support systems, the quality of facility construction is considered to be adequate.

2.

Number and Nature of Deficiency Reports Twelve 10 CFi 50.55(e) construction deficiency reports (CDR's) were submitted to the NRC during the evaluation period. There has been a total of thirty-five CDR's issued since the start of Zimmer construc-tion. Of the twelve items, two were considered to be under the direct control of the licensee. The remainder were attributable to Vendors, Architect Engineer and NSSS supplier. There are no significant problems known with the licensee's reporting of CDR's at this time.

3.

Escalated Enforcement Actions Civil Penalties None Orders None Immediate Action Letters An IAL was issued on September 4, 1980 confirming that the licensee's contractor, Tech-Sil Inc., had discontinued installation of certain fire barrier sealing material.

4.

Management Conferences Held During Past Twelve Months None

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5.

Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency / Scope Quality Assurance Management Increased inspection is recommended in the Quality Assurance management area due to the continued increase in items of noncompliance in spite of reduced construction activity and the lack of aggressive and effective management of the Quality Assurance organization.

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Piping and Hanger Supports Increased inspection is also recommended in the area of piping and hanger supports due to the high incidence of rejected work and continuing problems with the Quality Assurance aspects of this work.

Training

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Increased inspection frequency is warranted in this area because the training group has not been fully staffed, training procedures have not been fully implemented, no individual in the training group has BWR operational experience, and the NRC needs to verify certain TMI task action items.

Emergency Planning Increased inspection scope is warranted in this area because of the recent changes in 10 CFR 50, Appendix E.

This is applicable to the other Region III licensees.

6.

Other Observations a.

Staffing Region III is concerned about the small technical staff of the licensee and the resulting reliance on consultants.

The Technical Engineering Group of the Electrical Production Department has little involvement in the preoperational/startup program because of the small staff size. When the contract startup engineers (GE, EDS, and GPC) leave, the knowledge and experience gained during startup will be lost to Zimmer. The Training Group of the Electrical Production Department has not been fully staffed.

It appears that the designated instructors will be insufficient in both numbers and qualifications. The staff in the General Engineering Department (GED) has not been able to meet the schedule GED established for completing work on IE Bulletins and Circulars. Again, it appears that staff size is a problem.

b.

BWR Operating Experience The lack of experience in Boiling Water Reactor (BWR) operation is a Some operator candidates were receiving on-the-job train-concern.

ing at operating BWR facilities. There is some question as to whether this is sufficient, since it is being received at BWR's which are different in design to a BWR-5 system.

Consideration should be given to operator attendance at the BWR-6 simulator which more closely simulates the BWR-5 Emergency Core Cooling Systems, Recirculation-System and Electrical Lineup.

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c.

Reactor Operations With regard to the licensee's performance in the area of reactor operations (other than those aspects described in the preceeding paragraphs), overall good progress has been made toward meeting the requirements preparatory to the issuance of the operating license.

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Inspection Frequency and/or Scope

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FUNCTIONAL AREA Increase No. Change Decrease 1.

Quality Assurance, Management X

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Piping and Hangers X

3.

Maintenance X

4.

Training X

5.

Surveillance & Preop Testing X

6.

Radiation Protection X

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Environmental Protection X

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Emergency Planning X

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Fire Protection X

10.

Security & Safeguards X

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Reporting X

12.

QA Audits X

13.

Committee Activities X

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Quality Control X

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Procurement X

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Electrical Equipment X

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's. F. Heishman, Chief Reactor Operations &

Nuclear Support Bianci

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