IR 05000358/1983010
| ML20024F486 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/24/1983 |
| From: | Christianson W, Forney W, Grutatson R, Gustafson R, Scheibelhut C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024F380 | List: |
| References | |
| 50-358-83-10, NUDOCS 8309090423 | |
| Download: ML20024F486 (9) | |
Text
{{#Wiki_filter:- -. - - _ . - _ _. .. , U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No: 50-358/83-10 Docket No 50-358 License No.: CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Names Wm. H. Zimmer Nuclear Power Station Inspection At: Wm. H. Zinseer Site, Moscow, OH Inspection Conducted: June 13-17, June 27-July 1, and July 25-29, 1983 Inspectors: W.
hristianson f/.29'[f3 . { Q ' (Date) C. H Scheibelhut f/J-V/#3 g g (Date) R. N. G stafson LY!/3 . W (Date) Approved By: W. L. Forney, Chief [[O'/!f.3 Section Zimmer / 4Date) LG Lo$g Inspection Summaary-Inspection during the period of June 13-17, June 27-July 1, and July 25-29, 1983 (Report No. 50-358/83-10) Areas Inspected: Routine safety inspection by resident and regional personnel of licensee action on previously identified items, the safety-related equipment maintenance program, dispositions of electrical nonconformance reports. This inspection involved a total of 212 inspector-hours onsite by two NRC Region III inspectors.
Results: Of the three areas inspected, no items of noncompliance were identified.
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, .. Details 1.
Persons Contacted . Cincinnati Gas and Electric Company l-
- J. Williams, Jr., Sr. Vice President
- E. J. Wagner, Assistant V.P. Engr.
- J.
R. Schott, Plant Mgr.
- G. C. Picke, Lic. Mgr., NLD
- J. F. Shaffer, Dir., QCP
- C. M. Orlov, Asst. Dir., QCP
- R. E. Spence, QA Mgr. (acting)
- D. J. Chamberlain, Lic. Engr., NLD
- R. Wrucke, Lic. Engr., NLD
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- R. N. Taylor, Lic. Engr., NLD
- C. A. Brown, Lic. Engr., NLD
- D. Stephenson, Lic. Engr., NLC L
- W. P. Cooper, Dir. (I&C), NED
- D. J. Frederick, Dir. (Spec. Proj.), NED
- D. Harvey, NSSS, NED
- W. N. Tobler, Dir. Const. Engr., GCD
- J. E. Kisse11, Const. Engr., GCD
- P. Russ, Staff, GCD
- R. E. Monroe, Welding Consultant, CG&E
,
- J. D. Kloosterman, Lic. Engr., Bechtel.
' And others of the station and construction project staffs.
- Denotes those attending the exit meeting.
2.
Licensee Action on Previously Identified Items _ Closed) Open Item (50-358/79-38-03) " Responsibilities not asrigned ( a.
for establishing retention period for records."
i [ The inspector reviewed CG&E Station Administrative Directive Procedure l RM. SAD.01, Revision 01, dated January 26, 1982. Paragraph 5.1.4 requires that the quality assurance supervisor ensure that the listed
retention information is correct and sign the form. Retention time ' criteria are found in Procedure QD.QA1.20, Revision 0, dated May 13, 1983 under Section 4.2.7.
Therefore, responsibility has been assigned for establishing retention time periods for records and criteria for assigning retention time periods formulated.
. Closed) Unresolved Item (50-358/81-22-01) " Remote shutdown panel ( .. l b.
l cables NB420, NB442, NB405, NB395, NB410, and RI169 all run through a l common cabic tray in the control room in their routing path."
-Further inspection revealed that a fire in the cable tray would prevent actuation of two redundant shutdown cooling injection valves I I (IE12F053A and 1E12F0538) from the remote shutdown panels. The valves may be operated locally (manually) since they are located outside of
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/ - .. . primary containment.
10 CFR 50, Appendix R, Section IIIG, states, in part, " Fire protection features shall be provided for structures, systems, and components important to safe shutdown. These features shall be capable of limiting fire damage so that: ' b.
Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) can be repaired within 72 hours."
Since the fire protection system in the control room can be expected to limit the postulated cable tray fire to the individual tray, and the valves could be manually operated well within 72 hours, the intent of Appendix R in this case is fulfilled.
c.
(Open) Unresolved Item (50-358/81-22-03) "The P&ID drawing does not require that valves 1E12F335 and 1FCO29 be locked closed. This item is of concern since misplacement of these valves could result in LPCI flow diversion to the spent fuel pool."
The inspector reviewed licensee actions taken to resolve the item.
The review disclosed the following:
- The P&ID has not been revised to show the " locked closed" status of the valves.
- The station " locked valve" list does not show the valves.
- The station operating procedures call for the valves to be locked closed during normal operation.
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- A letter from Sargent and Lundy to CG6E (SLC-20688 dated November 24, 1981) purporting to close this item states, in part, "The P&ID's are not design documents for indicating " locked closed" or " locked
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open" valve position in that the valve position is dependent on the system mode of operation. The valve position is controlled by the system operating procedures for either the " lock closed" or " lock , i open" position."
Since Sargent and Lundy is the stated designer for this plant, they must provide documentation, either in the form of P& ids or other i means, to indicate equipment status to comply with US NRC regulations for safe operation, in this instance, to comply with containment criteria and prevent diversion of cooling water in an ECCS system.
This item remains unresolved pending further inspection.
d.
(Closed) Open Item (50-358/81-22-04) "1E12AS066A, control switch for valve 1E12F099A labeled ESS-1 on the P&ID but powered from ESS-2."
On further inspection, P&ID M51, Sheet 1, Revision AH, dated January 19, 1983 shows the control switch labeled ESS-2.
e.
(Closed) Open Item (50-358/81-22-05) "1E12AS014B-1, control switch at IPL67JB for IE12-F017B labeled ESS-1 on the P&ID, but powered from ESS-2."
On further inspection, P&ID M51, Sheet 2, Revision AJ, dated November 3, 1982'shows the control switch labeled ESS-2.
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(Closed) Open Item (50-358/81-22-06) "1B21HS023 and 1B21HS023-1, control switches for IE12F053B labeled ESS-2 on the P&ID but powered from ESS-1."
On further inspection, P&ID M51, Sheet 2, Revision AJ, dated November 3, 1982 shows the control switches labeled ESS-1.
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g.
(Closed) Open Item (50-358/81-22-07) "E1010/PG.NB23, auxiliary relay K-80 is labeled / Closed RHR head spray, suction and shutdown cooling valves." This relay actually operates only the inboard RHR shutdown l . cooling suction isolation valve.
i On further inspection, Drawing E1010/PG.NB23, Revision U, dated March i 15, 1983 shows auxiliary relay K-80 labeled, "close inboard RHR shutdown cooling isolation valve."
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(Closed) Open Item (50-358/81-22-08)."E1010/PG.NB29, auxiliary relays K29 and K30 logic includes contacts from TE31-N012A and B which are labeled / Opens on hi WTR LEV".
These contacts actually represent a hi flow rate containment isolation signal for the RHR shutdown cooling suction line.
On further inspection, Drawing E1010/PG.NB29, Revision Y, dated March 17, 1933 shows the contacts labeled, "0 PENS ON HI FLOW RATE."
i. (open) Open Item (50-358/81-28-03) " Surveillance report 1M-50 dated August 6, 1981 was still open (no response) on October 30, 1981."
t Further inspection revealed that the report was closed on November 4, 1981. However, the operations QA supervisor stated that a procedure was being written to deal with these cases of delinquent closure. The item remains open pending further investigation of the procedure.
j. (Open) Open Item (50-358/82-05-05) " 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). GE site operations manager noted that this was not the correct revision."
The inspector reviewed GE drawing 761E740, Revision 4, in the station document control room. This -item remains open pending further i inspection to determine if the drawing reflects the as-built ' condition.
[ k.
(Closed) Open Item (50-358/81-15-04) "CG&E QA audit found to be , inadequate to provide the necessary technical audits of construction work."
The inspector reviewed CG&E procedure 18-QA-03, Revision 5, dated January 20, 1983. This procedure provides instructions for performing surveillance and contains extensive surveillance checklists for construction phase activities.
Schedulina. The level and frequency of the audits depend on trending and evaluation of the effectiveness of previous audits with a minimun of 10% of any given activity. Adjustments to inspection frequency and levels of surveillance are based on reinspection results.
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. . ... - - .. -.._ - . -- ._ -__ - - - - ~ .. )_ , Surveillance. The surveillance of contractor activities provides for surveillance of the contractor, dual inspection with the contractor and/or reinspection by CG&E.
Inspection of scheduling documents currently being prepared indicated a detailed level of different activities to be audited. They appear to be adequate both in schedule frequency and depth of detail for the various activities.
' 1.. (Open) Unresolved Item (50-358/83-07-02) " Preservation and maintenance of systems following construction tests may be inadequate."
- See Section 3 of this report for an expanded review of the problem.
, (Open) Unresolved Item (50-358/83-07-04) " Calculations pertinent to
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ASME code requirements and seismic loadings were not on site."
Discussion with CG&E GCD personnel indicated that the NSSS supplier considers these calculations to be proprietary. The item remains unresolved pending further inspection.
(Open) Unresolved Item (50-358/83-07-05) "RHR pumps shaft seal coolers n.
appear to be fabricated to the incorrect section of the ASME code (Section VIII vice Section III), and have no evidence that they are seismically qualified."
The inspector reviewed General Electric letter CCE-1706 dated May 19, '; 1983. -In response to the above concern, the letter states in part that the vendor design report for the pumps references Section VIII of the code for the primary pressure boundary and was analyzed in accordance with the' pressure vessel criteria of Section VIII. The pumps were purchased in accordance with the ASME Nuclear Pump and ( . Valve Code 1968. The nuclear pump and valve code special requirements i do not apply to materials for equipment with inlet connections of 4" or less. The seal coolers are exempt as the inlets are less than 1".
The GE specification for these pumps, 21A9243, Revision 0, requires that Section IIIC of the code be used as a guide in calculating the thickness of pressure retaining components and sizing cover bolts.
, - Under Section 2.2.1 of the above specification, applicable codes and standards, the following are listed:
- ASME Boiler and Pressure Vessel Code, Section III
- USAS B31.7 Subsection 2 - Requirements for Class II Piping
- . ' ' ASME Standard Code for Pumps and Valves for Nuclear Power.
, - It is noted that the last standard was a draft later incorporated into Section III of the Code.
The letter does not address-seismic requirements for the coolers nor the shell side. The shell side is connected to the safety related ' component cooling water system.
This item remains open pending further inspection.
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.. , (Open) Unresolved Item (50-358/83-07-06) "The standby liquid control o.
system pumps does not have an "N" stamp. The date of order indicated in the FSAR would require an "N" stamp. The data available in the data package for the pumps does not indicate that the speed reducer and drive motor are seismically qualified."
, The. inspector determined that amendment 93 to the FSAR corrected the date of order of the pumps to reflect the actual order date. This re.alves the discrepency and the pumps do not require an "N" stamp.
The seismic qualification review program currently in progress will address the speed reducer and motor seismic qualifications. This item remains unresolved pending review of the seismic qualifications.
' p.
(Closed) Open Item (50-358/79-14-01) " Isolation damper bolt missing, no bolt torque requirements available, development of a checklist."
> This item is closed and the concerns upgraded to (50-358/83-07-01), an I item of noncompliance (generic).
" Installation and test of safety related equipment without quality control surveillance."
q.
(Closed) Unresolved Items (50-358/83-08-01 and 50-358/83-08-02) '
" Installation of the standby liquid control system storage tank. QC , records not available when the inspector was on site." And ' " Installation of control room HVAC supply air filter. QC records not available when the inspector was on site."
Further inspection has revealed that the above equipment was installed without quality control surveillance.
, Discussions with the HVAC contractor (WYB) and review of the WYB , j audits (see Section 4 of this report) revealed the following: I
- Open Item 50-358/79-14-01 concerned the lack of bolt torque
- requirements and the development of a checklist. WYB wrote a letter to CG&E-CDC (WYB-CGE-074-934 dated May 25, 1979) requesting installation and inspection criteria. No evidence of a formal reply could be found.
- The Waldinger corporate audit of June 13, 1979 identified the problem of installation without QC it.volvement. WYB wrote a procedure to address the problem. However, it could not be implemented without installation and inspection criteria.
- Sargent and Lundy letter 14441 dated January 14, 1980 to E. A.
, . Borgmann, CG&E Sr.
V.P., provided a comprehensive 4 page instruction / inspection form covering the installation of HVAC , equipment. There is no evidence that it was formally transmitted to WYB-for action.
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- The inspector who wrote 50-358/79-14-01 indicated in report 50-358/80-10 that the checklist mentioned in 50-358/79-14-01 was
, drafted. The draft of HVAC-6 reviewed indicated that the intent of the verification may not be accomplished.
- -Review of HVAC-6, Revision 2, the current approved procedure, does not call for QC involvement or written inspection procedures for specific equipment or classes of equipment or inspection criteria.
, ! This does not meet the intent of Criterion X of 10 CFR 50, Appendix B.
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_ _ . - - _ - - .- - _- - -..-- -._ . . _. . _ - .. , , Other discussions with CG&E-CCD staff indicated that installation of ' other safety related equipment probably was done without QC survelliance.
As a result of the above, the inspector believes that installation of an indeterminate amount of safety related equipment was accomplished without QC surveillance. Therefore, unresolved items 50-358/83-08-01 and 50-358/83-08-02 are closed and considered further examples of item i of noncompliance 50-358/83-07-01 which is upgraded to a generic problem rather than applying to the two pumps previously identified.
(0 pen) Item of Noncompliance (50-358/83-07-01) " Installation and test r.
of HPCS pump and RHR pump B without QC surveillance."
As noted above in 2q, this item is being upgraded into a generic item of noncompliance.
s.
(Closed) Unresolved Item (50-358/83-08-03) " Anchor bolts missing from one side of HVAC charcoal filter box."
J ' Further inspection revealed the DDC that changed the size of the filter box anchor bolts. The DDC appeared to be properly executed.
The anchor bolts have not been installed in this location because of the NRC stop work order.
t.
(open) Unresolved Item (50-358/83-08-05) " Documentation of analyses for QCP Task VI in some cases was noted to be in the form of personal noten."
This documentation is expected to conform to Criterion III of 10 CFR 50, Appendix B.
The item remains unresolved pending further inspection.
See Section 5 of this report for further information.
, No new items of noncompliance or deviations were noted.
' 3.
Safety Related Equipment Maintenance The licensee is currently transferring the responsibility for practically all systems to the Generation Construction Depcrtment (GCD). Previously, responsibility for some systems rested with the Nuclear Production Department (NPD) while other systems were the responsibility of GCD.
In some cases, safety related systems had a history of numerous transfers of responsibility between the two departments with a resultant loss of control of maintenance and preservation of the systems. This concern was partially expressed as an unresolved item in inspection report 50-358/83- , 07 as unresolved item 50-358/83-07-02.
' A new Owner's Project Procedure (OPP 8.2) has been drafted to cover preventive maintenance, preservative maintenance, and protective , maintenance of components, equipment and systems. Since this procedure has not b.een approved, no coussent will be made. Discussion with the ' author of the procedure revealed that the intent of the program the procedure will cover is' to inspect all safety related (and many nonsafety related) systems, equipment. and components for degradation and/or damage; and to repair, maintain, protect, and preserve the items.
i I No items of noncompliance or deviations were noted.
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a o , 4.
Audits of Waldinner-Young and Bertke (WYB) The inspector reviewed the audits made on the HVAC subcontractor, WYB.
Audits of WYB site activities were made by three groups: Cincinnati Cas and Electric, H. J. Kaiser, and the Waldinger Corporate Office.
During the period May 5, 1975 to July 29, 1982, CG&E performed sixteen audits of WYB site activities. Yearly audits of the QA Program and QC procedures were made. In addition, audits of specific activities such as the as-built condition of seismic hangers, procurement of materials, control of purchased material, welding control, compliance with ANSI 45.2.6, welder qualification and maintenance of qualification, etc., were , made. Deficiencies found by the audits appear to have been corrected in a timely manner.
H. J. Kaiser performed three audits of specific quality assurance functions.
In May, 1975 the field QA program was audited, in May, 1977 the records control function was audited, and in October,1977 specific field QC functions were audited. Deficiencies found by the audits appear to have been corrected in a timely manner.
During the period July 1975 through July 1982, the Waldinger Corporate QA Office made yearly audits of the site activities. These were comprehensive audits covering every requirement in the site QA manual.
With one exception, the deficiencies found by the audits appear to have { been corrected in a timely manner. The one exception has to do with the installation of safety related equipment without quality control involvement. This problem is discussed under item 2q above.
, No items of noncompliance or deviations were noted.
< l 5.
Review of Task VI Nonconformance Reports l._ A total of 199 additional Task VI NRs were reviewed for acceptability of dispositions. A total of 737 Task VI NRs have been reviewed to date, with l approximately 74 NRs withheld for further study. Among them are the 24 l listed in Inspection Report 50-358/83-08. Justifications and informal ! analyses presented during personal interview resolved questione on all but i 6 of these 24 NRs.
Out of 16 more NRs discussed, 4 more were selected for l more detailed analyses. Disposition analyses for these 10 NRs (the 6 plus the 4) were requested from Sargent & Lundy (S&L). These NRs are identified ast .; Q-QAD-82-4576-E
-82-2066-E l-82-3850-E-82-0805-E-82-0181-E-83-0273-E-82-0432-E ' -81-0364-E-82-0051-E ' -82-0321-E.
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,_ _ _. _ _ _ - _ _ _ _ _ _ _ _ _ _ -. _ - _ _ - _ _... _ -. _ _. _ _ _. _ - - - - _ _ - - _ _. _.. - - _ _ _... _ _ , - . , The above 10 NR analyses were received from S&L, reviewed, and discussed in a meeting with S&L aad CG&E Nuclear Engineering Department (NED).
Justifying analyses for thirteen (13) additional " accept-as-is" dispositioned NRs were requested from NED/S&L but have not been received yet.
, ! Tlie inspection had pointed out that the brevity and lack of supporting logic for many of the NR dispositions made the dispositions unsupportable. This fact and the concerns expressed in unresolved item 50-358/83-08-05 (see item 2t above) has prompted the licensee to write a Condition Evaluation Request (CER 83-195) to investigate the concerns. As a result of the investigation, a Corrective Action Request (CAR 83-73) has been written by the licensee to correct the problem. The course of this ! corrective action will be the subject of further inspection.
No items of noncompliance or deviations were noted.
6.
Exit Interview The inspectors met with the licensee representatives indicated by asterisk in Section 1 on July 29, 1983 and summarized the scope and findings of the inspection activities. The licensee acknowledged the inspectors' findings.
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