IR 05000358/1982005

IE Insp Rept 50-358/82-05 on 820302-0407.Noncompliance Noted:Failure to Have Adequate Procedures &/Or Follow Procedures Prescribed in 16-QA-03,Revision 2 Re Acceptable Methods for Achieving Corrective Actions

ML20055A494
Person / Time
Site:	Zimmer
Issue date:	06/21/1982
From:	Christianson, Gwynn T, Hunter D, Keating D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055A488	List: IR 05000358/1982005 ML20055A487 ML20055A490
References
50-358-82-05, 50-358-82-5, NUDOCS 8207190074
Download: ML20055A494 (10)

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U.S. NUCLEAR REGULATORY COM)!ISSION

REGION III

Report No. 50-358/82-05(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: March 2-5, 8-12, 15-19, 22-26, 29-31, April 1-2, and 5-7 1982 on 2'/ <[ 2_

on Inspectors:

T. P. Gwynn 8/ [2

. t k //;i Approved By: r, L ie

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/ Reactor Projects Section 2B Inspection Summary Inspection during the period of March 2-5, 8-12, 15-19, 22-26, 29-31, April 1-2, and 5-7, 1982 (Report No. 50-358/82-05(DPRP))

Areas Inspected: Routine inspection by resident and regional personnel of previously identified items, followup on the Quality Confirmation Program, Quality Assurance Personnel certification and qualification, and plant tour This inspection involved a total of 171 inspector-hours onsite by two NRC resident inspectors and one Region III inspector, including eight inspector-hours onsite during off-shift Results: Of the four areas inspected, two items of noncompliance were identified (Paragraphs 2 and 7, Details I).

8207190074 820701 PDR ADOCK 05000358 a PDR

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DETAILS I 1. Personnel Contacted Cincinnati Gas and Electric Company

• B. R. Sylvia, Vice President, Nuclear Operations

• B. K. Culver, Manager, Generation Construction Department

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• R. Schott, Plant Manager

• H. R. Sager, QA Manager D. J. Schulte, QA Engineering Supervisor G. M. Orlov, Quality Engineer M. A. Porter, Quality Engineer J. C. Buck, Audit Supervisor Henry J. Kaiser Company W. Hedzik, Site QA Manager M. Goedecke, Weld Manager N. Vitale, Quality Engineering Manager and others of the station and construction project staff * Attended monthly exit intervie . Licensee Action on Previously Identified Items (Closed) Unresolved Item (81-32-06): Corrective Action Reporting Syste The inspector reviewed licensee actions taken to resolve problems with the functioning of the corrective action reporting system. These actions included revision of both the Owners Project Procedure (OPP-7.3)

and the Quality Assurance Procedure (16-QA-03) to more c1carly define the system function and to provide more effective control of corrective action request In addition, the licensee has provided a further mechanism for clarification of potential problem areas and for feedback of information from QA Engineering to Quality Control Inspection via the Condition Evaluation Request (CER). The licensee has delegated the authority and responsibility for providing an interface between the licensee's quality organization and the constructor's organization with two assistants to the Quality Engineering Supervisor (qualified Level III quality engineers). This organizational interface represents an authoritative mechanism by which problems identified on Corrective Action Requests may be resolved properly and expeditiously. The licensee has committed to a re-review of procedures to ensure adequate procedures have been utilized, as documented in meeting repor (50-358/82-03(DPRP))

The failure to have adequate procedures and/or to follow the pro-cedures prescribed in 16-QA-03, Revision 2, " Corrective Action Reports,"

is in noncompliance with 10 CFR 50, Appendix B, Criterion V, and the Wm. H. Zimmer QA Manual, Paragraph 5.1,.which states in part that

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" activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures, and drawings which prescribe acceptable methods of carrying out those activities." This is a violation of Severity Level (358/82-05-01)

In addition to the above, the inspector performed a spot check of the H. J. Kaiser corrective action reporting system to ensure that the similar problems identified with the CG&E system were not present in the Kaiser system. The inspector found that the Kaiser CAR system was responsive to identified deficiencies and was generally timely in obtaining corrective action. One minor deficiency noted (the QE Manager was signing where the procedure GQP-10, Corrective Action Reports, required the QA Manager's signature) was corrected immediatel The inspector questioned the H. J. Kaiser Quality Engineering Manager concerning documentation of the results of evaluations for reportability under 10 CFR 21 and 10 CFR 50.55(e) but no documentation was available at the time of the inspection. This matter is unresolved pending further inspectio (358/82-05-02)

(Closed) Open Item (358/81-32-07): Procedural deficiencies related to the correction action reporting syste The inspector reviewed a recent revision to OPP-7.3 " Corrective Action Requests" and found that the procedural deficiencies identified had been correcte (Closed) Open Item (358/81-32-08): Procedural deficiency related to the corrective action reporting syste The inspector reviewed a recent revision to Procedure 16-QA-03,

" Corrective Action Reports" and found that the procedural deficiency identified had been correcte (0 pen) Unresolved Item (358/81-32-10): Pullman Power Prodects of Williamsport, Pa., had not been audited by CG&E since 197 The inspector found that the CG&E QA Manual, Paragraph 18.3.4 allows the licensee to fulfill their audit responsibility under 10 CFR 50, Criterion XVIII, by means of audits, source inspections, or surveillance in accordance with QA procedure Although the vendor Pullman Power Products had not been audited since 1977, there had been numerous source inspections conducted in the vendors shop; in addition, an audit performed by the licensee and documented in Field Audit Report No. 82-09, dated March 1, 1982, revealed that Pullman Power Products of Williamsport, Pa., presently has an effective Q program. However, the lead auditor indicated on page 6 of the audit report, in a column headed Comments, that " Review of the Pullman Power Products QA records indicates that the records and documer.tation for the past two years appear to be more complete and correct than for the previous periods. The inspector noted that this comment was not sub-stantiated by the audit findings. However, in light of the lack of audit over-sight during the period 1977 to present, this statement was

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of concern to the inspector and clarification was requested. The licensee stated that there was no basis in the audit report for the statement made by the lead auditor, but that the past performance of the CG&E audit program was being pursued under the Quality Confirmation Program. This item remains open pending further clarification and inspection followu (358/82-05-08)

3. Review of_ Quality Confirmation Program (QCP) Generated Nonconformance Reports (NRs)

i QCP Task I - Concerning Structural Steel The inspector has received initial issue copies of approximately 950 NRs in this area of which 4 have been dispositioned by CG& The NRs received to dato described a variety of deviations from structural welding code acceptance criteria and reentrant corner profiles which do not meet the requirements of the AISC cod The impact of these deviations from code requirements was a topic of discussion between the licensee and NRC Region III management at the time of this inspectio QCP Task II - Concerning Weld Quality The inspector has received initial issue copics of approximately 420 NRs in this area, of which 33 have been dispositioned by CG6 The NRs received to date described a variety of deviations from code acceptance criteria (for ASME and AWS welding) as well as site procedural violations, QCP Task III - Concerning Heat Number Traceability The inspector has received initial issue copies of approximately 110 NRs in this area, of which none have been dispositioned by CG& The NRs received to date described potential problems with trace-ability of small and large bore piping system components in several plant system QCP Task IV - Concerning Socket Weld Fitup The inspector has received initial issue copies of approximately 50 NRs in this area, of which none have been dispositioned to dat In general, these NRs described conditions whereby neither avail-able documentation nor radiographic examination could verify socket disengagement for socket welds in small bore ASME code piping, QCP Task V - Concerning Radiography The inspector has received initial issue copies of approximately 4 NRs in this area, of which one has been dispositioned to dat .

, QCP Task VI - Concerning Electrical Cable Separation The inspector has received initial issue copies of approximately  ;

350 NRs in this area, of which 31 have been dispositioned to dat In general, these NRs described a variety of deviations from the Final Safety Analysis Report (FSAR) cable separation criteria and the Sargent and Lundy (S&L) cable installation specificatio In addition, the inspector noted that several corrective action requests have been generated by QCP Task VI for clarification of cable separation and' segregation criteria for both essential and reactor protection system cables. The disposition of these cor-rective action requests and their potential impact on QCP Task VI and ongoing construction work will be followed by the inspecto Open item (50-358/82-05-03) ,

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• QCP Task VII - Concerning Nonconformance Reports The inspector has received initial issue copies of approximately 32 NRs in this area, of which none have been dispositioned by CG& In general, these NRs reopen conditions from previously voided NRs which may-have been voided without proper justificatio . Quality Confirmation Program (QCP) Task I Concerns The inspectors were approached by ten contractor QC inspectors who expressed verbal concerns on the QCP Task I, Structural Steel, inspections. Their concerns included problems which could have a safety significance and also labor problems. Generally the concerns were:

(1) Recent termination of four contractor QC inspectors (2) Programatic inspection criteria (3) Quality versus production (4) Assignment of work schedules (5) Parent company administrative practices The concerns were reviewed with licensee representatives and the contractor personnel by the inspector with the following status noted:

(1) Four personnel were terminated by the licensee. Three persons were considered excessively vocal on parent company administrative policies and were disrutive to the task performance. The fourth inspector had demonstrated unsatis-factory job performance. The inspector was present when two of the individuals were escorted from the site. The inspector informed the individuals that the NRC was receptive to quality / safety concerns; however, neither QC inspector responde . - - . - . _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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(2) The licensee is addressing Task I inspection criteria and will issue appropriate guidanc (3) The inspector conversed with the contractor parent company management on their internal organization problems and ex- I pressed concern that quality could be affected by a lack of adequate employer / employee relations. The contractor acknowledged problems and stated he would pursue corrective actio (4) The inspectors were provided the opportunity to address the contractor personnel collectively on their concerns i and discuss the NRC role at the Zimmer sit No items of noncompliance or deviations were note . Quality Control Inspector Certification

Quality control inspectors are performing inspections upon success-

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fully completing training and the written examinations, but prior to official certification. Certification requires background checks on previous employment and due to the slow response on inquiries, may delay certification up to a month. Utilizing inspectors during this interim period appeared adequate providing all inspections performed are not considered valid until the individual receives certification with background checks. This practice was noi adequately documented, and the licensee indicated that the requirements will be inserted in Procedure 10-QA-03, " Certification of Inspection Personnel." This item is considered open pending further inspectio (358/82-05-04)

6. Plant Tours The inspectors conducted frequent plant tours throughout this in-spection period. These tours included, but were not limited to, observation of ongoing construction activities, maintenance activities, equipment controls, cleanliness control, instrumentation, fire equipment, and security controls. The below listed items were identified and the licensee is taking or has taken appropriate corrective actio Several fire extinguishers in the reactor building were found to be missing from their designated location, or depressurize This item was brought to the attention of the CG&E Safety Supervisor who rectified the noted problem During observation of weld repair activities for weld CY606, the inspector noted a potential minimum wall violation on the ganma plug associated with that weld. This item was brought to the attention of the H. J. Kaiser Weld Manager. The gamma plug was repaire ___ --

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. The motor winding heater for the high pressure core spray pump was deenergized. This was brought to the attention of a main-tenance foreman who rectified the proble The inspector noted that the control rod drive (CRD) housing support did not appear to be assembled as shown on GE drawing 761E970, Revision 7 (supplied by station document control).

The GE site operations manager noted that this was not the correct revision to that drawing for the Wm. H. Zimmer CRD housing support. This item is open pending further revie (358/82-05-05) During a plant tour it was noted that two craft personnel assigned to remove paint from structural welds for weld inspection as part of the QCP program were using slag removal hammers. The use of hammers was not specified in the procedures and could displace the weld material. Crafts involved with the QCP have been issued instructions forbidding tha use of such hammer . On March 5,1982, a member of the CG&E QAD staff initiated a

" Notification of Potentially Reportable Item" form, Attachment to OPP-7.1, dealing with qualification records for code welders on the Wm. H. Zimmer sit In accordance with OPP-7.1, Revision 1, QAD was required to perform an initial prompt review for reportability, make a determination of reportability, and either notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and log the report or identify the item as not reportable and log it as suc At the time of this inspection (April 7,1982), the QAD had no objec-tive evidence that this item had been logged, that a prompt review had been completed and documented, or that a determination as to report-ability had been made ac required by the procedur In addition, the inspector noted that two other forms were included in the file which had the same characteristic Failure to fulfill the procedural requirements of OPP-7.1 could result in the lack of records of activities affecting quality and does not provide an auditable syste In addition, the potential exists for the failure to make a required report under 10 CFR 50.55(e)

or 10 CFR 21. This failure to follow the requirements of OPP-7.1 was of minor safety significance, but is in noncompliance with 10 CFR 50, Appendix B, Criterion V and the Wm. H. Zimmer QA Manual, Paragraph which states in part that activities affecting quality are accomplished in accordance with written procedures. This is a violation of Severity Level (50-358/82-05-06)

8. Unresloved 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. One unresolved item disclosed during this inspection is discussed in Paragraph ! .

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9. Management Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on April 8, 1982. The inspectors summarized the scope and findings of the inspectio I

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DETAILS II Prepared By: D. E. Keating Reviewed By: D. H. Danielson, Chief Materials and Processes Section Inspection period March 2 through 19, 1982 Persons Contacted CGSE H. R. Sager, QA Manager B. K. Culver, Manager, Generation Construction Depar'.aent

• M. Rutli, QCP Coordinator D. J. Schulte, QA Engineering Supervisor S. Osborne, Training Coordinator

• S. DePillo, QCP Task I Coordinator

• R. Sargent, QCP Task I Lead QA Engineer J. C. Herman, Nucicar Engineering Division Foothill Electric C B. Evans, General Superintendent M. Kelly, QC Engineer Sargent and Lundy Engineers T. McKenna, Structural Project Engineer

• H. Singh, Structural Group Lead Engineer R. Vanier, NDE Level III and CWI Kaiser Engineers M. White, Electrical QC Coordinator The inspector also contacted other licensee and contractor technical and administrative personne * Denotes those attending the exit interviews during the inspectio . Review of Personnel Qualification Records The Region III inspector reviewed the qualification records of one (1) Task I Structural Inspector and two (2) Task I Structural Quality Assurance Engineers. During the inspection period questions were raised regarding the experience and qualifications of one (1) Task I Quality Assurance Enginee The licensee is in the process of re-training and re qualifying all personnel involved with the Task I portion of the Quality Conforma-tion Program. This includes the Task Coordinator, the lead engineers, and the h.spector _ _ _ _ _

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This item had been reviewed and closed out during a previous inspectio However, since this questionable qualification occurred again, this will be carried as an unresolved item and reviewed further during a future inspectio (358/82-05-07)

3. Acceptance Criteria for Dispositioning Nonconformance Reports (NRs) for Task I Structural Welds A review of several randomly selected Nonconformance Reports (NRs) was performed. Several of these were selected for field inspection including the following:

NR N Reviewed Field Inspected Q-QAD-82-257-E X X Q-QAD-82-259-E X X Q-QAD-82-297-E X X Q-QAD-82-298-E X X Q-QAD-82-381-E X X Questions have been raised regarding the veld acceptance criteria to be used to disposition these NRs. The licensee committed to AWS D1.1-1972 and AISC, 7th Edition, and defects that have been identified will not be adequately addressed in terms of code require-ments. For this reason it has been suggested to the licensee and A/E that this item be resolved before rework begins in this Quality Confirmation Program Task. The licensee agreed to review this matter furthe This will be carried as an unresolved item to be reviewed further during a future inspectio (358/82-05-08)

4. Review of Inspection Reports (irs) for Cable Tray Foot Connections A number of Inspection Reports (irs) .ere randomly selected to be field checked regarding listed nonconforming condition The areas involved were the Cable Spreading Room, the Equipment Room, the Yellow Switchgear Room, and the Blue Switchgear Room and included the following:

IR N Reviewed Field Inspected S636CDW016 X X S636CDW019 X X S636DDWO32 X S636DCWO59 X S636CDWO88 X X S636CDWO74 X X S636CDWO73 X S636CDWO29 X S636BDWO77 X X S636BDWO65 X X S636BDWO61 X X

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A review of the NRs and field checks revealed the nonconforming conditions as documented did exis In the Cable Spreading Room the inspector discovered three (3) destroyed Hold Tags from the Quality Conformation Program. These were for the Structural Beam Identifi-cation program. The licensee was appraised of this finding was investigating the situation, and will take appropriate actio This will be carried as an unresolved item to be reviewed at a future inspectio (358/82-05-09)

5. Acceptance Criteria for Dispositioning Nonconformance Reports (NRs)

for Task I Structural Welds A teleconference was requested by the licensee and his A/E regarding AWS D1.1-1972 Code requirements and methods of dispositioning NRs identifying weld discontinuitie The licensee maintains that the majority of these can be dispositioned

" accept-as-is" by calculations indicating that the net weld is sufficient for the design function. The NRC stated this appeared to be questionable approach, and that the AWS Code requirements are minimum acceptable re-quirements and must be met or exceede The licensee and A/E stated that the provisions of the FSAR allowed revision of the requirements if it can demonstrated that the alternate I method meets or exceeds the standard Futher discussions or meetings with Region III staff will be provided to resolve this ite (See unresolved item 358/82-05-08)

6. Unresolved Items Unresolved items are matters about which more information is needed in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. Four unresolved items disclosed during this inspection are discussed in Paragraphs 2, 3 and 4 of this sectio . Management Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 5 and 19, 1982. The inspector summarized the items and findings of the inspectio i k