IR 05000358/1981032
| ML20042C564 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 03/10/1982 |
| From: | Christianson W, Gwynn T, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20042C559 | List: |
| References | |
| 50-358-81-32, NUDOCS 8203310528 | |
| Download: ML20042C564 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-358/81-32(DPRP)
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: December 1, 7-11, 21-24, 28-30, 1981 and January 4-8, 11-15, 18-22, and 25-29, 1982 MW 3/ D/hs?-
I Inspectors:
W. F. Christianson O/62.
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R. Hunter, Wief 3/'O /87_
Approved By:
D Reactor Projects Section 2B Inspection Summary Inspection on December 1, 7-11, 21-24, 28-30, 1931 and January 4-8, 11-15, 18 -22, and 25-29, 1982 (Report No. 50-358/81-32(DPRP))
Areas Inspected: Routine resident inspection of previously identified items; followup on Immediate Action Letter (IAL) dated April 8, 1981; followup on Quality Confirmation Program; review of plant operating procedures; followup on Corrective Action Reports; and plant tours. The inspection involved a total of 444 inspector-hours onsite by two NRC resident inspectors, including 10 inspector-hours onsite during off-shifts.
Results:.No items of noncompliance or deviations were identified.
8203310528 820311 PDR ADOCK 05000358 (D PDR
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DETAILS 1.
Personnel Contacted Cincinnati Gas and Electric Company J. R. Schott, Plant Manager
- H. R. Sager, Quality Assurance Manager
- M.
F. Rulli, Supervisor, Quality Confirmation Program
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J. Schulte, Supervisor, Quality Engineering F. S. Hoover, Construction Engineer (Nuclear Energy Services)
G. Orlov, Quality Engineer (Scientific Applications, Inc.)
M. Porter, Quality Engineer R. Vannier, Quality Engineer (Sargent & Lundy)
F. Pfeifer, Quality Engineer
- J.
F. Shaffer, Director of QA Records
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E. Martin, Procedures and Training Coordinator Henry J. Kaiser Company
- D. Howard, Acting Site Quality Assurance Manager
- J. Watkins, Deputy Site Quality Assurance Manager C. Burgess, Inspection Manager M. Goedecke, Welding Manager D. Price, Quality Assurance Auditor C. Winter, Receipt Inspection Hartford Steam Boiler i
L. Burton, Authorized Nuclear Inspector Others of the station and construction project staffs were contacted during the inspection.
U.S. Nuclear Regulatory Commission
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F. Streeter, Chief, Reactor Projects Branch 2
- D.
R. Hunter, Chief, Reactor Projects Section 2B
- Denotes those present at the monthly exit meeting.
2.
Licensee Action on Previously Identified Items (Closed) Unresolved Item (80-20-02): Revision to procedure "QC Duties in Weld Tet.: Shop." The inspector reviewed H. J. Kaiser Special Process Procedure (SPPM) No. 3.2, Revision 7, dated August 28, 1981. Paragraph 13 of that procedure states, "A representative of H.J.K. QA will be present in the Test Lab Area at all times when weld tests are being performed."
Attachment 6 to SPPM No. 3.2 supplies guidelines for the QC inspector in the weld test shop.
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3.
Immediate Action Letter (IAL) dated April 8, 1981
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i IAL Item 3 - Concerning QC Inspections a.
The inspector observed the performance of H. J. Kaiser Quality
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Control (QC) inspection activities and the 100% reinspection activities of the CG&E inspectors and found that in some cases inspection results were not properly documented as required by the licensee's i.acedure QAP-11, " Inspection," Revision 6.
The inspectors mat se.ch licensee representatives concerning undocu-mented QC int wctions and were informed that the concern had been previou.'y identified in CG&E Corrective Action Request (CAR) No. 81-;i.
The inspectors will follow the resolution of
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CAR No. 81-2S to assure corrective action is taken within a reasonable time. This is an open item (358/81-31-01).
b.
The inspectors toured the H. J. Kaiser weld test shop with the H. J. Kaiser Weld Manager. During this tour, the inspectors noted that one individual (a welder) was moving in and out of weld test booths while welder qualification testing was in
progress. The H. J. Kaiser Weld Manager instructed the test
shop supervisor that, except for the instructor, only one welder is allowed in a test booth while welder qualification testing is in progress.
The inspector questioned the H. J. Kaiser QC Inspection
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Supervisor concerning the instructions and authority of the QC inspector in the weld test shop. The Inspection Supervisor
subsequently issued an interoffice memorandum dated January 7,
1982, clarifying the H. J. Kaiser policy concerning personnel in weld test booths during welder qualification testing, and defining the authority of the QC inspector to immediately reject a test coupon if other personnel are observed in the test booth.
This matter is considered an open item (358/81-31-02).
ik) items of noncompliance or deviations were identified.
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4.
Quality Confirmation Program (QCP)
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n.
Overall Administration of the QCP The inspector reviewed sevaral QCP procedures, interviewed the
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responsible task coordinators, and discussed the QCP findings with the responsible task coordinators and the QCP Supervisor.
an NRC team inspection of the implementation of the QCP'was re-quested, scheduled and performed during this inspection period.
That inspection will be the subject of a separate report.
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b.
Review of'QCP Generated Nonconformance Reports
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Several' tasks outlined in the QCP require that nonconformance reports (NRs) be written and dispositioned by CG6E,-then
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concurred in by the NRC prior to action being taken on the disposition. The first NRs to be dispositioned were transmitted by CG&E to the NRC for concurrence during this inspection period.
On December 29, 1981, the inspectors met with licensee personnel
to discuss the re-ults of the NRC review of those NRs.
Items discussed during this meeting included the following:
Some copies provided for review were illegible.
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Some reports appeared to have been closed out prior to
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NRC review (i.e., Q-QAD-81-174-E, 188-E, 203-E, 214-E).
Some corrective action statements appeared to either not
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address the entire problem or were inadequate.
In some cases, appropriate corrective action was being taken but was not noted on the NR.
Reasons for not concurring in three NRs (Q-QAD-81-09-E,
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19-E, and 196-E).
As a result of the meeting, the licensee agreed to resubmit the
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three NRs not concurred in, to provide more legible copies of NRs l
for NRC review, and to improve the completeness of corrective
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action statements on NRs for both QCP and ongoing work.
c.
QCP Task I - Concerning Structural Steel The inspector has received initial issue copies of approximately 180 NRs in this area of which one had been dispositioned by CG&E.
The NR (Q-QAD-81-220-E) was reviewed and released for work.
The NRs received to date describe a variety of deviations from structural welding code acceptance criteria. The actual impact of.these deviations from code acceptance criteria had not been evaluated by the licensee at the time of this inspection.
d.
QCP Task II -~Concerning Weld Quality
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The inspector has received initial issue copies of approximately 55 NRs in this area of which 26 had been dispositioned by CG&E.
Those 26 NRs, which are listed below, were reviewed and released for work by the inspectors.
Q-QAD-81-223-E Q-QAD-81-224-E-Q-QAD-81-225-E Q-QAD-81-226-E Q-QAD-81-235-E Q-QAD-81-242-E Q-QAD-81-244-E Q-QAD-81-250-E Q-QAD-81-251-E Q-QAD-81-252-E Q-QAD-81-256-E Q-QAD-81-258-E Q-QAD-81-259-E Q-QAD-81-260-E Q-QAD-81-261-E Q-QAD-81-267-E
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Q-QAD-81-269-E Q-QAD-81-270-E Q-QAD-81-273-E Q-QAD-81-274-E Q-QAD-81-275-E Q-QAD-81-276-E Q-QAD-81-277-E Q-QAD-81-278-E Q-QAD-81-279-E Q-QAD-81-280-E The NRs describe a variety of deviations from code acceptance criteria.
In general, the NRs released to date have been dis-positioned " rework" to bring the identified deviations into code acceptability.
e.
QCP Task III - Concerning Heat Number Traceability The inspector'has received initial issue copies of approximately 20 NRs in this area. N7ne have been dispositioned by CG&E. These NRs describe potential problems with traceability of small bore ASME code piping in the reactor recirculation and diesel generator systems.
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QCP Task V - Concerning Radiography The inspector has received one NR in the area of radiography, not directly related to QCP Task V.
This NR (Q-QAD-81-09-E)
identified an ASME code rejectable indication on a previously reviewed and accepted field radiograph for weld CY 606.
In addition, MRC Inspection Report No. 50-358/81-27(DPRP)
identified a previously reviewed and accepted radiograph for field weld HP20 in which an ASME code rejectable indication was masked on the original field radiograph by surface indications.
The corrective action to NR Q-QAD-81-09-E included a commitment to Establish a program for the rereview of a sampling of field radiographs under the direction of CGEEs NDE Level III. The inspector will follow the progress of this program to determine if the above identified problems are generic. This is an open item (358/81-31-03).
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QCP Task VI - Concerning Cable Separation The inspector has received initial issue copies of approximately 75 NRs in this area of which 30 have been dispositioned by CG&E.
Twenty-nine NRs which are listed below were reviewed and released for work by the inspectors.
Q-QAD-81-03-E Q-QAD-81-05-E
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Q-QAD-81-06-E Q-QAD-81-07-E Q-QAD-81-08-E Q-QAD-81-13-E Q-QAD-81-14-E Q-QAD-81-15-E Q-QAD-81-16-E Q-QAD-81-168-E Q-QAD-81-169-E Q-QAD-81-173-E
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Q-QAD-81-174-E Q-QAD-81-180-E Q-QAD-81-183-E Q-QAD-81-184-E Q-QAD-81-185-E Q-QAD-81-186-E Q-0.AD-81 -185 -E Q-QAD-81-190-E Q-QAD-81-192-E Q-QAD-81-194-N Q-QAD-81-195-N Q-QAD-81-197-E Q-QAD-81-202-E Q-QAD-8'-203-E Q-QAD-81-206-E Q-QAD-81-214-E Q-QAD-81-215-E The NRs describe a variety of deviations from the Final Safety Analysis Report FSAR) cable separation criteria and the Sargent and Lundy (S&L) specifications.
In general, the NRs released l
to date have been dispositioned " rework" to bring the identified
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l deviations into conformance with FSAR commitments and S&L
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specifications.
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h.
-QCP Task VII - Concerning Nonconformance Reports l
Action Item 5 requires that proposed dispositions to previously l
voided NRs be reviewed and concurred in by NRC Region III prior i
to action being taken on the nonconforming condition. NR E-2476 (previously voided) detailed a condition related to material traceability on a piping spool for the reactor building closed cooling water (WR) system. During a routine tour of the plant, I
the inspector found that this WR system piping spool had been cut from the system oaring the performance of an engineering change request (ECR-1134) prior to the disposition of NR E-2476.
This matter was brought to the attention of the CG&E QA Manager and the Supervisor of the Quality Confirmation program to ensure that items associated with voided NRs are maintained and con-(
trolled for future inspection activities. This is an open item (358/81-31-04).
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No items of noncompliance or deviations were identified.
5.
System Operating Procedures Review The inspector reviewed three general plant operating procedures for technical adequacy.
Procedure CP.0G.01, off-gas, valve checklist was incomplete in that it did not list fifteen valves shown on the PI&D; six valves shown i.
on the PI&D did not have valve numbers and were not on the checklist;
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'and four valves installed on the system are not shown on the PI&D.
In addition, instrument root valves are not consistent on the PI&Ds l
in that some root valves are designated as system valves and others l
as instrument valves.
The Residual Heat Removal System Procedure OP.RH.01 valve checklist was incomplete in that twelve valves do not appear on the checklist.
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The Reactor Core Isolation Cooling System Procedure OP.RI.01 valve
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checklist is incomplete in that ten valves do not appear on the checklist; two locked closed valves on the checklist are not noted on the PI&D, and eight locked closed valves on the PI&D are not noted as locked closed on the checklist.
The licensee is present1; review-ing the valve checklists and the large number of valves designated as
" locked closed" and " locked open" to ensure adequacy of the program controls.
The findings of the review were discussed with the Plant Manager. A comprehensive system and procedure review program by the licensee is in progress, but the completion date is indeterminate at this time.
The inspectors will perform further reviews to determine the adequacy of the licensee system and procedure review program for the " locked" valves. This is an open item (358/81-31-05).
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No items of noncompliance or deviations were identified.
6.
Corrective Action Reques;s (CARS)
During several site tours to observe ongoing construction activities, the inspector found that quality control inspectors in some cases were not documenting their inspection findings. This item of concern was brought to the attention of the CG&E QA Manager and the Vice-President for Nuclear Operations on December 21, 1981. The CG&E QA Manager stated that this concern had been previously identified on CAR No. 81-25.
The inspector confirmed that the concern had been identified and brought to the attention of CG&E management on October 31, 1981, and that the CAR had been responded to by the H. J. Kaiser Company on December 14, 1981. - The inspector noted that the response was deter-mined to be unacceptable by CG&E QAD. Furthermore, during a tour of the plant on January 5, 1982, the inspector found that some undocu-mented quality control inspections were still being performed. On January 8, 1982, the inspector met with site QA management concerning undocumented quality control inspections and timeliness of corrective action.
a.
Documentation Reviewed (1) CAR Log.
(2) CAR No. 81-25 dated November 26, 1981.
(3) Response to CAR No. 81-25 dated December 14, 1981.
(4) OPP (Owners Project Procedure) - 7.3, Revision 0,
" Corrective Action Requests," dated October 26, 1981.
(5) Quality Assurance Department Procedure 16-QA-03, Revision 2, " Corrective Action Reports," dated August 28, 1981.
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b.
Findings (1) Review of the CAR Log revealed that in some cases a signi-ficant amount of time was required to obtain an acceptable response from the responsible party. The table below represents a sample of the contents of the CAR Log:
Acceptable Response CAR No.
Issue Date Responro Date Time 81c01 04-09-81 12-04-81 8 months.
81-06 05-20-81 10-29-81 5 months 81-11 08-17-81 12-18-81 4 months 81-16 08-27-81 None To Date 5 months 81-21 10-28-81 12-23-81 2 months 81-26 11-26-81 12-03-81 1 week 81-31 12-04-81 None To Date 1 month This representative sample indicated that in some cases it took a significant amount of time to achieve an acceptable response to a CAR. The inspector noted that in some cases corrective action could not be implemented until an accept-able response was achieved.
Procedure 16-QA-03, Paragraph 6.4.2, states in part, "The CG&E QA Department shall verify that corrective actions are acceptable..." Paragraph 6.4.3 states, "All CARS not in compliance with Paragraphs 6.4.1 and 6.4.2 above, shall be sufficient cause for the initiation of a Stop Work Order for any noncompliance set forth in this procedure." The inspector noted that this was the only action provided by procedure for an unacceptable response to a CAR.
t In addition to the above, the inspector noted that CAR No. 81-12 was cancelled by the QA Department although Procedure 16-QA-03 did not provide for the cancellation of a CAR.
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Also, the inspector noted that several CARS had been revised and reissued after receipt of an unacceptable response. For example, CAR No. 81-11 was issued on August 17, 1981, was revised after an unacceptable response on December 7, 1981, and an acceptable response was received on December 18, 1981.
Additionally, CAR No. 81-15 was issued August 24, 1981, was revised on September 22, 1981 after an unacceptable response, but an acceptable response had not been received 5 months
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later at the time of this inspection. The revision and reissue of CARS was not addressed in Procedure 16-QA-03.
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This item is unresolved pending further review by the inspector (358/31-31-06).
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e (2) The inspector reviewed Procedures PP-7.3, " Corrective Action Requests," and 16-QA-03, " Corrective Action Reports,"
and found several apparent procedural deficiencies as
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follows:
(a) OPP-7.3 refered to Procedure 16-QA-01 in several places.
The correct reference should have been Procedure 16-QA-03.
(b) OPP-7.5 states in part, "The CAR is a method of docu-menting and reporting... conditions adverse to quality...
t The MCAR is a method of documenting and reporting significant conditions adverse to quality..."
OPP-7.',
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MCAR.
Procedure 16-QA-03 states in part," Corrective
i Action Reports (CARS) are used to document thcse significant (emphasis added) conditions adverse to
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quality..."
Procedure 16-QA-03 does not address the
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MCAR. Furthermore, no other procedure addressed the
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MCAR.
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The correction of these procedural deficiencies will be reviewed during a subsequent inspection. This is an open item (358/81-31-07).
(c) Procedure 16-QA 03 assigns the CG&E Manager of Quality Assurance the responsibility to determine if the subject of the CAR is reportable under 10 CFR 50.55(e)
or 10 CFR 21; however the procedure does not require
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the documentation of the performance or results of the determination. A review of. the QAD procedures for l
reporting deficiencies under 10 CFR 50.55(e) and for reporting defects and noncompliance under 10 CFR 21 revealed that neither procedure required documentation
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of the performance of the evaluation. This matter will'
be reviewed during a subsequent inspection. This is an open item (358/81-31-08).
No items of noncompliance or deviations were identified.
7.
Plant Tours
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The inspector conducted frequent plant tours throughout this inspec-tion period. The below listed items were identified and the licensee is taking or has taken appropriate corrective action:
a.
Hanger HP012HV was observed to have been damaged.
b.
The inspector found a container of alcoholic beverage, empty beer cans, an empty wine bottle, orange juice, beds, pillows, etc.,
above the turbine building ventilation system intake plenum
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(Auxiliary Building elevation 567').
This area had previously been noted by the inspector on several occasions to be littered
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with empty beer cans. This area was brought to the attention of the H. J. Kaiser Construction Project Manager who discussed the situation with the appropriate supervisors. The corrective actions concerning consumption of alcoholic beverages onsite are being followed by the inspectors. This is an unresolved itet pending further inspection (358/81-31-09),
c.
The inspector observed a piece of pipe in the field, apparently purchased under CG&E Purchase Order No. 2171, which did not meet the requirements of Specification H-2255 for preservation and identification.
In particular, the following conditions were noted:
(1). The pipe was rusty both inside and out.
The interior corrosion layer was thick, but not scaling.
(2) The applicable identifying marks (i.e., heat number, sp>ol
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number, etc.) were applied with black magic marker only.
The purchase order document (a telecopy) did not specify an alternate marking method, thus the specification requirements (i.e., four alternative indeli' ale marking methods) appear to apply and the pipe was not properly marked.
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In addition, the inspector noted that the vendor (Pullman Power Products of Williamsport, PA) had not been audited by CG&E QA since 1977. This is an unresolved item pending further review by the inspector (358/81-31-10).
No items of noncompliance or deviations were identified.
8.
Trip Report - Clinton Nuclear Power Station The resident inspectors toured the Clinte Nuclear Power Station in Dewitt, Illinois, on December 2-4, 1981. The site-tour included observati'n of ongoing and completed construction work, discussions with management concerning quality control, qualit c assurance, records management, and observation of the site do.ument control and records centers.
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Unresolved Items Unresolvea items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Four unresolved items disclosed during this inspection are discussed in Paragraphs 6.b(1), 7.b and 7.c(2).
10.
Management Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on February 13, 1982. The inspectors summarized the scope and findings of the. inspection.
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