IR 05000358/1981015
| ML20009C573 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/12/1981 |
| From: | Daniels F, Gwynn T, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20009C564 | List: |
| References | |
| 50-358-81-15, NUDOCS 8107210235 | |
| Download: ML20009C573 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Reporc No. 50-358/81-15 Docket No. 50-358 License No. CPPR-88
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Licensee:
Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Facility Name :
W. H. Zimmer Neclear Power Station Inspection At:
W. H. Zimmer, Moscow, Ohio Inspection Conducted: May 1, 4-8, 11, 18-22, and 26-29, 1981 Inspectors:
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Y L.Sd,Sl RFk) 4-T. P. Gwynn 6////p/
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I?Falaundh Approved By:
R. F. Warnick, Chief 6/M/
Reactor Projects Section 2B Inspection Summary Inspection on May 1, 4-8, 11-18-22, and 26-29, 1981 (Report No. 50-358/81-15)
Areas Inspected: Routine resident inspection of previously identified items, followup on IE Circulars, followup on Region III Immediate Action Letter, Opera-tional Staffing, followup on improper welding, fuel receipt and storage, pre-operational test program implementation controls, comparison of as-built. plant to FSAR description, and plant tours. Thfs inspection involved a total of 146 inspector-hours onsite by two NRC inspectors, including 35 inspector-hours onsite during offshifts.
Results: Of the nine areas inspected, eight were found to be in satisfactory and
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one item of noncompliance was identified in the area of preoperational test progr5m implementation controls (paragraph 8).
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PDR ADOCK 05000358 G
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DETAILS
1.
Personnel Contacted J. R. Schott, Plant Manager
. King, Assistant Plant Superintendent P.
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J. Wald, Station Quality Engineer
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W. Schweirs, Manager, Quality Assurance i
.'. C. Swain, CG&E Construction Project Manager
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- W. D. Waymire, Manager GED D. C. Kramer, CG6E QC Inspection Supervisor
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F. Rulli, CG6E Quality Engineer C. Schroeder, Kaiser Turnover Coordinator R. E. Donnellon, Maintenance Supervisor and others of the station staff.
- Denotes those present at the monthly exit interview.
2.
Licensee Action on Previously Identified Items (0 pen) Unresolved Item (50-358/81-07-01): Comprehensive QA audit similar to the requirements of the Startup Pbnual for preoperational turnover packages.
The inspector determined that an audit (QA Audit Report #351) dated April 4, 5 and 16, 1981 was conducted by CG&E.QA as committed, however, this audit did not address the Startup Manual requirements.. This was brought to the attention of the CG6E QA Manager.
In addition, the inspector reiterated that apparent conflicts between Startup Fbnual requirements and the pro-cedural requirements of the startup administrative control and project procedures were unacceptable. The inspector was informed that a revision to the Startup bbnual to resolve these conflicts is pending. This item remains unresolved.
(Open) Unresolved Item (50-358/81-12-01): Lack of timely corrective action on Noncompliance 79-39-02.
As of May 26, 1981, the licensee had yet to initiate action to complete corrective action on this item of noncompliance. When brought to his atten-tion, the CG6E QA Manager stated that the required audit would be completed in the near future.
The inspector verified that an audit plan was being prepared by a lead auditor. This item remains unresolved.
3.
IE Circular Followup For the IE Circular listed below, the inspector verified that the Circular was received by the licensee management, that a review for applicability was performed, and that if the circular was applicable to the facility,
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appropriate corrective actions were taken or were scheduled to be taken.
(Closed) IE Circular 81-01: Design Problems Involving Indicating Pushbutton Switches Manufactured By Honeywell Incorporated.
The inspector verified that these switches are not used at the Wm. H. Zimmer Nuclear Power Station.
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4.
Followup on Immediate Action Letter (I AL) Dated April 8,1981
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The inspectors reviewed the licensees progress in the implementation of the various requirements imposed by the IAL. The results of the inspection were:
a.
Item 1 - Concerning OA Staffing The CG&E QA/QC staff has been increased significantly, but is still approximately 14 individuals shors of the projected staffing level.
There appears to be a sufficient number of qualified personnel to
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accomplish tha work that is now in progress. In order to fully implement all the requirements of the IAL the additional individuals will be necessary. 15e majority of the new personnel are contract individuals end will be replaced with CG&E employees as they are acquired and become qualifieo.
b.
Item 2 - Concerning Independence and Separation Between Kaiser Construc-tion and Kaiser OA/QC.
The Henry J. Kaiser (HJK) Company has restructured its Corporate Organi-zation so that the Manager of Quality Assurance now reports directly to the President. QA/QC procedures are no longer being approved by the Construction personnel. A new QA Fbnager has been brought to the site to take charge of HJK QA Group and the Project Manager has resigned.
Also, an additional level of management has been incorporated into the HJK QA organization at the site.
These actions appear to be of suffi-cient magnitude to insure separation between HJK QA and construction groups.
c.
Item 3 - Concerning QC Inspections The inspectors reviewed the records for the twenty DC inspectors assigned to the CG&E QC reinspection group. The qualification of two inspectors as Level II visual weld inspectors was questioned and the licensee agreed to reduce their qualification to Level I until sufficient train-ing has been obtained.
The program established for the handling of nonconforming conditions or material had not been fully established, but the licensee was expedit-ing its completion and the training of personnel in the implementing procedures.
There are sufficient CG&E inspectors on site to perform required in-spections for the current on going construction activities. The staff of inspectors is scheduled to be increased by another 10 inspectors to cover the construction activities expected in the future.
d.
Item 4 - Concerning QC Inspection Procedures The inspectors verified that all QC inspection procedureu were being reviewed by CG&E and HJK for technical as well as quality aspects.
Approximately half of the procedures have undergone this review and have been issued for use by the inspection personnel.
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The Region III USNRC Technical staff will provide a further review as the procedures are completed.
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e.
Item - 5 Concerning Training The inspectors reviewed both the CG&E and the KEI programs for training QA/QC personnel. The CG&E ' program is more sophisticated and provides more management tools for controlling and monitoring the current training
. status of QA/QC personnel, however, this program was still in the devel-opmental stage and has not been fully documented or implemented. This item remains unresolved.pending a future inspection (50-358/81-15-01).
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The KEI program relies heavily on the lead inspector to ensure that all his people receive necessary training prior to performing inspection with a revised procedure. The inspectors verified that training sessions
are being conducted for all cognizant inspection personnel as inspection procedures are rewritten. The inspector noted that KEI is training its inspectors to ANSI N4%.2.6-1978 whereas CG&E is using ANSI N45.2.6-1973.
f.
Item 7 - Concerning the Voiding of Nonconformance Reports (NR's)
The inspectors reviewed the current revision of Nonconforming Material Control, QACMI No. G-4, dated 4-13-81 and found it to be a much improved procedure for the controlling of Nonconforming Material. Also the section which allowed for the voiding of NR's has been eliminated.
g.
Item 8 - Concerning QA/QC Records The CG6E Records Control / Management System was still in the conceptual
development stage at the time of this inspection. Construction of a new records storage facility on site has begun with occupancy projected for the end of July.
In the interim, a single records control procedure 06-QA-02, Kevision 0, is being utilized to control the use of QA/QC records with the exception of some in process records. The inspector monitored the implementation of this procedure and found some confusion
and/or inconsistency. This procedure will not support full scale con-struction activities. The CG6E Commitment Control Program was not documented or implemented at the time of this inspection. These items remain unresolved pending a future inspection (81-15-02).
h.
Item 9 - Concerning Conditions Adverse to cuality The inspectors verified that CG6E QA Group is now receiving a copy of all nonconformance (NR's) and surveillance (SR's) reports issued by HJK QA Group. A procedure for the review of NR's (Review of Nonconformance Reports, 05-QA-01) has been written and issued for use which provides the necessary guidelines to evaluate NR's, assure validity and ensure adequate control existe to have it properly dispositioned. Although SR's are being received by the CG&E QA Group, guidelines have not been established for their review.
This is considered to be an unresolved item (50-358/81-15-03) and will be followed in subsequent inspections.
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i. Itsm 10 - Concerning the Audit Program The inspectors reviewed the newest Revision to the CG&E OA Audit schedule t.
and found it to be totally inadequate to provide the necessary technical audits of construction work.
It provides an adequate schedule for programmatic audits, but in many cases the inspectors feel the frequency of audits should be reduced. This was discussed with the licensee and they stated that the surveillance program would provide the quality review of ongoing construction. Since this surveillance program has not been established as yet, the audits of ongoing construction activities are considered to be an unresolved item (50-358/81-15-04) and will be
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reviewed in subsequent inspections.
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Operational Staffing The inspector reviewed appropriate documents to determine that all staff positions were filled, except Vice-President of Nuclear Operations which will be filled in the near future, that the organizational structure is in accordance with the FSAR, and that personnel in those positions satisfied the minimum qualification requirements.
a.
Inspections Conducted (1) The FSAR, Appendix C was reviewed and it was determined that the licensee committed to ANSI N18.1-1971.
(2) The FSL2, Chapter 13, Figure 13.1-2 was reviewed and it was de-termined that the licensees' organizational structure as implemented is in accordance with the FSAR.
(3) The inspector reviewed training records to determine if the following personnel met the minimum qualification requirements of ANSI N18.1-1971.
(a) Plant Manager (b) Assistant Plant Superintendent (c) Operations Supervisor (d) Maintenance Supervisor (e) Technical Engineer (f) Instrument and Controls Supervisor (g) Reactor Engineer (h) Rad-Chem Engineer (i) Shift Supervisors (j) Nuclear Control Operators (k) Training Coordinator (1)
10% of the Station Technicians (4)
The FS AR, Chapter 13, figure 13.1-1 was reviewed and it was deter-mined that the technical support organization is in accordance with the FSAR, although it was not fully staffed.
(5)
In discussion with the Maintenance Supervisor it was determined that the station plans on having three maintenance technicians qualified as welders.
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(6) The FSAR, Chapter 13, figure 13.1-1 was reviewed to determine if the QA/QC organization was in accordance with the requirements.
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b. - Findings (1) The three maintenance technicians were still in the training program to become qualified welders, therefore,-the inspector was unable to determine if they were adequately qualified in accordance with ASME.
This is considered an unresolved item and will be followed up in subsequent inspections.
(50-358/81-15-05)
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The QA/QC Organization was no. in accordance with the FSAR. The
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Senior Vice-President of Electrical production and Engineering Services informed the inspector that the Manager of Quality Assur-ance has.been selected and-that after his arrival the QA/QC Organi-zation will be established as per the FSAR commitments. This is considered to be an unresolved item and will be followed up in subsequent inspections.
(50-358/81-15-06)
(3) There are no procedural requirements established which assign responsibility for someone to assure that. the minimum educational, experience, or qualification requirements will be satisfied for personnel in the various job positions at the station. This is considered to be an unresolved item and will be followed up in subsequent inspections.
(50-358/81-15-07)
No items of noncompliance or deviation were noted.
6.
Improper Welding on 4/27/81 the Senior Resident Inspector was informed that a welder had welded 10 to 15 passes of weld rod onto an H-Beam in the Auxiliary Building on the 519' level. The inspector verified this by actually observing the buildup of weld filler material on the H-Beam.
He subsequently informed the licensee and the constructor of this occurrance and they began an inves-tigation.
The licensee was unable to determine who did the unauthorized welding and a Nonconformance Report (NR #3169) was written.
No items of noncompliance or deviation were noted.
7.
Fuel Receipt and Storage The inspector verified the integrity of the security controls exercised for new fuel storage. These controls included the following:
I Entrance barrier continuity to the 627 foot elevation of the Reactor a.
Building where new fuel is stored. The inspector noted that a ventila-tion plug from the drywell to the drywell head area (Rx Vessel open)
was being used as an emergency exit from the drywell and that a dedi-cated security watch was posted to maintain access control to the refueling floor from the drywell. The inspector questioned the security watch concerning his duties and, discussed his actions in the event the emergency exit was used for non-emergeacy purposes.
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Acesas control into and out of the area.
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Fuel storage area lighting, e
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Security force awareness and knowledge of their procedures.
The inspector also verified the provisions for control of the fuel storage environment ard found the conditions of the license to be satisfied.
No' items of noncompliance or deviation were noted.
8.
Preoperational Test Program Implementation Controls
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The inspector verified that jurisdictional controls (document hold and turnback to construction) were being ebserved for the low pressure core spray and reactor core isolation cooling systems; that a schedule for preoperational testing was being maintr.ined and kept current; and that ju.risdicational controls were observed for system turnover on the control room ventilation packag? PT-V C-02. The inspector also attempted to verify that jurisdictional tagging of systems turned over for preoperational test-ing was performed in accordance with administrative controls; that main-tenance activities performed on systems turned over for preoperational testing were being performed in accordance with a technically adequate procedure by qualified personnel, and that preoperational test results had not been invalidated by maintenance activities.
a.
Documentation Reviewed (1)
SU.PRP.01, Revision 13, System Release and Turnover (2)
SU.PRP.04, Revision 05, Punchlist Item Completion and Maintenance In Turned Over and Non-Turned Over Areas.
(3)
SU.PRP.12, Revision 00, Tagging of Systems Turned Over For Preopera-tional Testing.
(4)
PT-VC-02, C itrol Room Ventilation System Turnover Package b.
Findings (1) Most jurisdictional tags checked by the inspector were in place.
However, the inspector noted that three power supplies for the reactor building ventilation supply fans were not tagged and were not included on the tag list.
In addition, the inspector found two independent tag listings had been generated for this system with tagging dates of August 29, 1980 and February 4, 1981, respectively.
The inspector noted several differences between the two tag lists and verified in the field that tags had been hung in accordance with the list dated August 29, 1980. This item remains unresolved pending a future inspection in this area.
(50-358/81-15-08)
(2) The inspector found that the tags for PT-VC-02 had been assigned to the I&C department for hanging. Upon questioaing the I&C foreman, it was apparent that he was unfamiliar with the requirements of SU.P RP.12.
In particular, he was unaware of the requirements of paragraph 6.3, which states
"A rad / chem tech or operator, as appropriate, shall hang the green tags and shall be accompanied by a TCG person who shall witness the correct tag placement."
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This is considsrad to ba in noncompliance with 10 CFR 50, Appendix B, Criterion V and the CG&E Company QA Manual which required in part that activities affecting quality be accomplished in accor-
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dance with written instructions, procedures, or drawings.
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i (3) The inspector observed the perf, - ce of major maintenance on the
' A' Diesel Generator which has... turned over for preoperational testing. This maintenance was being performed by qualified main-tenance technicians under the direction of a vendor representative.
A check of the work request for this activity revealed that no
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procedure was required, no QC requirements were specified, and no retest requirements were specified. Discussion with the senior maintenance rechnician revealed that appropriate work instructions were available and in use via the service manual.
In addition, retest was planned. This is considered to be another example of noncompliance (81-15-09), as a violation of QA. SAD.07, Revision 02, paragraph 5.2.3.A which requires that as a minimum, "Nonroutine repair and modification operations......shall be inspected to ensure a level of quality at least equivalent to that specified in original design bases and material specifications."
(4) This maintenance activity on 'A'
Diesel Generator involved a minor modi-fication to the machine but the Electric Production Department (EPD)
does not presently have a program for controlling design changes and modifications.
This item remains unresolved pending further inspection in the area of design changes and modifications (50-358/81-15-10).
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Comparison Of As Built Plant To FSAR Description
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The inspector commenced a detailed review of the Low Pressure Core Spray Syste=.
This review includes verification of the system field drawings and actual physical ecostruction to the P&ID drawings and the FSAR. This inspection is still ongoing and will be the subject of a future inspection report.
No items of noncompliance or deviation were noted.
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Plant Tours The inspectors conducted frequent plant tours throughout this inspection period. The below listed items were identified and the licensee is taking or has taken appropriate corrective action:
i a.
Electrical junction boxes and scienoid valve operators were found to be loose on the following valve operators:
1 RE 048 1 RE 052 1 RE 050A,B 1 RF 002 1 RF 008 1 RF 018B
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Th2 following sx mpics of esparation criterion violetion (refer to report #81-13 for noncompliance citation) were noted:
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Conduit for cables RI 222 (ESS Division I) and R1211, 212 (ESS Division II) werb noted to be in direct contact. These conduits had been accepted by Kaiser QC.
(2)
Conduit for cables TI 917 (associated ESS Division II) and NB 789 (ESS Division I) were noted to be in direct contact.
The status of QC inspection of these conduits was not readily
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apparent.
c.
The inspector found approximately 10 copies of DDC S-2602 in the field without a DDC register number assigned. This item remains unresolved pending further inspection.
(50-358/81-15-11)
No items of noncompliance or deviation were noted.
11.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviations. Ten unresolved items disclosed during this inspection are discussed in paragraphs 4.e, 4.g 4.h, 4.1, 5.b(1), 5.b(2), 5.b(3),
8.b(1), 8 b(3), and 10.c 12.
Management Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on May 29, 1981. The inspectors summarized the scope and findings of the inspection.
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