IR 05000358/1981028
| ML20039E097 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/21/1981 |
| From: | Christianson W, Gwynn T, Mcgregor L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20039E092 | List: |
| References | |
| 50-358-81-28, NUDOCS 8201060524 | |
| Download: ML20039E097 (8) | |
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o U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report'No. 50-358/81-28 Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name:
Wm. H. Zimmer Nuclear Power Station Inspection At:
Wm. H. Zimmer Site, Moscow, OH Inspection Conducted: October 1-2, 5-9, 12-16, 19-23, and 26-30, 1981 lOn'fbyge ht:
Inspectors:
W. F. Chr2stianson
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$971?btscvbdL:
T. P. G nn
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b 071bf Approved By:
L. G. McGregor, Acting Chief
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I Reactor Projects Section 2B Inspection Summary
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Inspection on October 1-2, 5-9, 12-16, 19-23, and 26-30, 1981 (Report No. 50-358/81-28)
Areas Inspected: Routine safety inspection of previously identified items, followup on Quality Confirmation Program, followup on Immediate Action Letter dated April 8,1981, observation of practice emergency exercise, preoperational testing quality assurance, and plant tours. This inspection involved a total of 146 inspector-hours onsite by two NRC inspectors, including 22 inspector-hours onsite during off-shifts.
Results: No items of noncompliance or deviations were noted.
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8201060524 811223 PDR ADOCK 05000358-G PDR.
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-e DETAILS 1.
Persons Contacted
- B. R.' Sylvia,.Vice President, Nuclear Operations-
'*J. R.-Schott, Plant Manager
- H. R. Sager, Quality Assurance Manager
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- S. C. Swain, ConstructionL Project Manager
- J. J. Wald, Station Quality Engineer M. F. Rulli, Quality Confirmation' Program Supervisor J. C. Buck, QA Audit Supervisor
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D. C.'Kramer,IQC Inspection Supervisor
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J. Dean,. Station Staff Engineer S.
E.- Martin, Professional Engineer D. Campbell,. Quality Confirmation Program Staff (NES)
J. Rodrigues, Quality Confirmation Program Staff (S&L)
W. 0. Puckett, H. J. Kaiser Weld Engineer (HJK) and others of the
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station staff.
- Denotes those present at the monthly. exit meeting.
2.
Licensee Action on Previous'ly Identified Items (Open) Noncompliance 81-06-07: Use of measuring and test equipment
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calibrated by vendors whose QA program had not been evaluated.
The inspector reviewed licensee action on this item and determined.
that present plans do not agree with commitments made in' letter QA-1418 dated April 30, 1981. The licensee committed to submitting a. revised response to this item of-noncompliance. The inspector reviewed MT. SAD.01, Revision 06, " Control of Measuring and Test Equipment," dated July 14, 1981, and had no comments.
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(0 pen) Noncompliance 81-18-01: Failure to identify and correct pro-cedural nonconformances related to system turnover for preoperational testing and the system index test matrix.
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The inspector verified that the required changes had been made to Procedure SU.PRP.06, " Generation and Control of the System Index Test-
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Matrix," and Procedure ADMIN-2, " Construction Coordination of System Turnover.for Preoperational Testing."
The inspector reviewed the qualification files for all CG&E audit personnel and determined that certifications to ANSI N45.2.23-1978
were available on file.
The inspector reviewed Procedure OPP-7.4, " Response to Audits,"
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Revision 0 dated April 2, 1981, and verified that sufficient manage-ment controls were available to properly address late or inadequate audit responses. The inspector noted that the-computer listing of open audit items _ is extensive and presently incomplete. This will be followed up-in a future inspection.
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.(Closed) Unresolved Item 81-15-06: CG&E QA/QC Organization was not in accordance with the FSAR.
The inspector verified that the CG&E QA/QC organization was established in accordance with FSAR Figure 17.2-1.
(Closed) Unresolved Item 81-15-01: CG&E training program for QA/QC
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personnel in the developmental stage and has not been fully documented or implemented.
The inspector reviewed Procedure 02-QA-01, " Indoctrination and Train-ing of QA/QC Personnel," Revision 04 dated August 19, 1981, and verified its implementation by spot checks of personnel training records and training summaries in the possession of the lead CG&E QC Inspector. This training program was similar to that being imple-mented by Kaiser for their QC personnel.
(Closed) Unresolved Item 81-15-08: Jurisdictional tagging of systems was observed to have some inconsistencies.
The inspector verified that jurisdictional tags have been hung for the power supplies to the reactor building ventilation supply fans. The inspector did not identify any similar problems associated with safety-related systems.
(Closed) Unresolved Item 81-15-02: Single records control Procedure 06-QA-02, Revision 0, will not support full scale construction activities.
The inspector reviewed Revision 04 to Procedure 06-QA-02, " Control of QA Documentation." Several H. J. Kaiser QA-Documentation Instructions have been issued dealing with the control of construction quality records.
Also, access to the records storage facility is under administrative controls.
In addition, CG&E Procedure 05-QA-04, Revision 03, " Response to Region III NRC Correspondence," describes the method by which CG&E controls their commitments. The inspector reviewed the current system for tracking open items, noncompliance, bulletins, and circulars. The system appeared to be functioning properly.
3.
Quality Confirmation Program - Review and Processing of Voided Nonconformance Reports The inspectors reviewed thirtysix (36) " voided" H. J. Kaiser Co.
Nonconformance Reports (NR's). These NRs were voided rather than
" superseded" by a subsequent NR (or revision to the NR). The review consisted of ensuring that information on the original voided NR had been exactly translated onto a superseding NR with a new control number.
The final approval for all actions taken on a reopened NR shall be by a review committee chaired by the CG&E QA Manager in accordance with CG&E QA Procedure 15-QA-04, " Review and Processing of Voided Noncon-formance Reports."
No items of noncompliance or deviations were noted.
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4.
Quality Confirmation Program --- Concerning Structural Steel The inspector followed the performance of a test program which the licensee intended to use to determine if visually rejectable weld defects could be observed through a thin (1-3 mil) coat of galvanox paint. The inspector observed the welding.of several test coupons, verified that the proper weld procedure was used, attempted to verify welder qualification to the procedure in use, observed several CG&E QC Inspectors independently performing visual inspection of the coupons in the unpainted condition, and obtained photographs of the test coupons in the unpainted condition. The test coupons had not been painted at the conclusion of this inspection.
a.
Documentation Reviewed (1) Memo QCP-81-6-from M. F. Rulli to H. R. Sager dated October 8, 1981.
(2)
H. J. Kaiser Weld Procedure Specification 3.1.11, Revision 2,
" Shielded Metal Arc, AWS Prequalified Carbon Steel to Carbon Steel Structural Shapes," dated May 12, 1975.
(3)
H. J. Kaiser Weld Procedure Specification 3.1.51, Revision 1,
" Shielded Metal Arc, AWS Carbon Steel to Carbon Steel Struc-tural Shapes Charpy Tested A-588 Gr. B", dated October 9, 1979.
(4) Welder Qualification Test Records for Weld Symbols MBR, 00, KMZ, and LGB.
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Findings (1) Weld qualification test record to Procedure 3.1.11 for Symbol LGB did not include a laboratory test number, although test results were reported.
(2)
10 CFR 50, Appendix B, Criterion IX requires in part that welding be accomplished by qualified personnel using quali-fied procedures in accordance with applicable codes.
The ASME Boiler and Pressure Vessel Code Section IX requires in part that qualified welders renew their qualification (1)
when a welder or welding operator has not used a specific process for a period of three months or more, or (2) when there is a specific reason to question his ability to make welds that meet the specification.
Thus, to maintain his qualification status, a welder must either exhibit satisfactory performance of welding activities within the past three months to the qualified procedure (up to six months when employed on some other welding process) or recertify by qualification test.
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The inspector attempted to verify welder qualification for the weld symbols designated in a.(4) above. The inspector was unable to identify a procedure which specifically dealt with the maintenance of welder qualification. Discussion with the H. J. Kaiser weld engineer revealed th3t a master list of all active welders was being maintained by weld en-gineering which contains information pertinent to welder qualification, such as welder symbol, name, number, process qualified, last weld date to the qualified process, and days since last weld to the qualified process. The H. J. Kaiser weld engineer stated that the last weld date data was obtained from KEI-2 forms (weld red issue forms) made out to the symbol for a weld using the qualified process. The inspector observed that the issuance of weld rod does not constitute objective evidence that the welder has satisfactorily performed to the qualified process. This was discussed with licensee personnel who stated that a similar concern had been recently identified in an H. J. Kaiser Co. internal audit of Weld Engineering.
This item is unresolved pending licensee action on the pre-viously identified audit item.
(358/81-28-01)
No items of noncompliance or deviations were noted.
5.
Followup on Immediate Action Letter (IAL) dated April 8, 1981 IAL Item 5 - Concerning Training a.
The inspectors have verified that the required initial training was carried out, and that a continuing program has been imple-mented to assure that QA/QC personnel receive training on any new or revised procedure prior to implementation of the procedure.
The inspector noted that the H. J. Kaiser training procedures are presently in draft stage. The draft Kaiser training procedures remain an open item (358/81-28-02).
IAL Item 5 remains open.
b.
IAL Item 8 - Concerning QA/QC Records The inspectors have verified that CG&E has established a program to assure care, custody and control of Kaiser QC records. An underground record storage vault has beea constructed meeting ANSI N45.2.9 requirements. The new QA Records Center houses HJK and CG&E personnel to provide the desired communication, surveillance, audit and control of records.
The records are effectively managed with the assignment of a full time manager and clerical support.
The software is in place and additional hardware is being procured to provide a more efficient indexing and retrieval system.
IAL Item 8 is closed.
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c.
IAL Item 9 - Concerning Conditions Adverse to Quality The inspectors verified that CG&E QA Group is receiving a copy of all nonconformance (NRs) and surveillance (SRs) reports issued by HJK. Procedures have been written and in use which provides assurance that controls exist to properly document deficiencies, review, resolve and verify satisfactory corrective action.
IAL Item 9 is closed.
No items of noncompliance or deviations were noted.
6.
Observation of Practice Emergency Exercise The inspectors compared the scenario for the October 29 practice emergency exercise to the scenario for the November 18 graded emergency exercise to verify that the graded scenetto was not divulged. The inspectors noted few similarities between the two scenarios.
The inspectors observed the performance of the practice drill on October 29 for information.
No items of noncompliance or deviations were noted.
7.
Preoperational Testing Quality Assurance The inspector verified that the station QA surveillance schedule was being followed, that QA surveillance of system turnover packages was being performed in accordance with an approved procedure, that correc-tive action for identified discrepancies was being taken except as noted, that new additions to the QA audit group met thr minimum education, experience, and qualification requirements, that training (both general and site-specific) was being conducted for QA audit personnel, and that the station nonconformance reporting system was functioning.
a.
Documentation Reviewed (1) Letter 81-313 dated August 31, 1981, from B. K. Culver to H. R. Sager in response to Field Audit Report (FAR) No. 357.
(2) Letter 81-221 dated July 21, 1981, from S. C. Swain to H. R. Sager in response to FAR No. 354.
(3) Letter 81-211 dated July 6, 1981, from S. C. Swain to H. R.
Sager in response to FAR No. 351.
(4) Lead Auditor Certifications for the following audit personnel:
(a)
L. Savage (b)
J. Wald (c)
P. Adkins (d)
W. Sutherland (e)
J. Buck-6-
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u (5) Station surveillance reports as follows:
(a) SU-54, " Flushing /Layup Requirements." dated September 23, 1981 (b)
IM-50, " Instrument Shop Practices," dated August 6, 1981 i
(c) EC-56, " Equipment Control," dated September 30, 1981 (6) Nonconformance reports as follows:
(a) 81-58 E (b) 81-74 E (c)81-106 E (d)81-124 N (7) Procedure QA. SAD.06, Revision 06, "Nonconformance Reporting,"
dated December 12, 1980 (8) Procedure QD.QAI.06, Revision 01, " Surveillance Inspections,"
dated September 16, 1980 b.
Findings (1) The inspector reviewed training, qualification, and certifi-cation records for CG&E QA audit personnel. The following discrepancies were noted and subsequently corrected by the licensee:
(a) There was no record of site (indoctrination) training
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for three of five lead auditors, including the audit group supervisor.
(b) One auditor who had acted in the capacity of " lead" auditor for three recent audits was not certified to ANSI-N45.2.23-1978.
(2) In accordance with Procedure QD.QAI.06, the cognizant group supervisor is required to respond to surveillance reports within 30 days, but surveillance report IM-50 dated August 6, 1981, was still open (no response) on October 30, 1981. This item is open.
(358/81-28-03)
(3) The inspector reviewed station nonconformance report (NR)
No. 81-124-N concerning pipe and valve deficiencies in the service water system (valve IWSO9B). This nonconformance report was classified as " nonessential" which allows disposi-tion by the cognizant group supervisor vice the material and station review boards, required by Procedure QA. SAD.06 for
~ " essential" nonconformance reports. The inspector noted that valve IWS09B was classified ESS Division III (essential) on the Sargent and Lundy piping and instrument detail drawing, M-30.
This classification conflicted with the classification-7-
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of thNR.
This item is unresolved pending clarificaticn by e
the licensee.
(358/81-28-04)
No items of noncompliance or deviations were noted.
8.
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:
a.
Lifted leads on instrument IPT-WR055 had EC. SAD.03 tags missing.
The missing tags were rehung.
b.
The following examples of possible cable separation criteria violations were identified:
(1)
Inside PNL IH13-P602, insulated conductors from cable RR 048 (ESS Division II) appear to come in direct contact with in-sulated conductors from cable RR 015 (ESS Division I).
(Unresolved Item 358/81-28-05)
(2) Several essential cables inside conduit and essential junction boxes (ESS Divisions I and II) located inside the Reactor. Core Isolation Cooling (RI) System pump room may exceed the FSAR Limits for conduit separation in missile areas.
(Unresolved Item 358/81-28-06)
(3) Conduit containing cable CM785 (ESS Division I) comes in direct contact with conduit for cable RI 055 (ESS Division II) at the wall penetration to the RI pump' room, in violation of the FSAR one inch minimum separation limit.
(Unresclved Item 358/81-28-07)
(4) Conduit for cable LP 023 (ESS Division I) comra in direct con-tact with conduit for cable LD 807 and LD 799 (ESS Division II)
in the RHR 'A'
heat exchanger room, in violation of the FSAR one inch minimum separation limit.
(Unresolved Item 358/81-28-08)
No items of noncompliance or deviations were noted.
9.
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. Unresolved items disclosed during this inspection are discussed in Paragraphs 4.b(2), 7.b(3) and 8.b.
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Management Exit Meeting The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on November 2, 1981. The inspectors summarized the scope and findings of the inspection.
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