IR 05000385/1978032

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IE Insp Rept 50-385/78-32 on 781228-29.Noncompliance Noted: Inadequate Corrective Action Re Nonconforming Memoranda Re QA Procedure
ML19282B928
Person / Time
Site: Zimmer, 05000385
Issue date: 01/29/1979
From: Danielson D, Harrison J, Yin I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19282B925 List:
References
50-358-78-32, NUDOCS 7903190041
Download: ML19282B928 (6)


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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-358/78-32 Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Facility Name:

William H. Zimmer Power Station, Unit 1 Inspection At:

Zimmer 1 Site, Moscow, Ohio Inspection Conducted: December 28-29, 1978 f #lW

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/ 47 79 Inspector:

I.

T.' Yin

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Accompanying Personnel:

J. J. Harriscn J. F. Suermann

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Reviewed By:

D. H. Danielson, Chief

Engineering Support Section 2 Inspection Summary Inspection on December 28-29, 1978 (Report no. 50-358/78-32)

Areas Inspected:

Followup inspection of problem areas relative to the safety related hangers, restraints, and concrete expansion anchor bolts installed which were identified during previous Region III inspections.

The inspection involved 14 inspector-hours onsite by one NRC inspector.

Results: One apparent item of noncompliance was identified in the one area inspected (Infraction - inadequate corrective action to (1) rescinded the memorandum that deviated from an approved QA procedure, (2) indoc-trinate workers about the change, and (3) identify all otber similar nonconforming memorandums - paragraph 3).

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DETAILS Persons Contacted Principal Licensee Employees (CG&E)

  • B.

K. Culver, Project Manager

  • R. P. Ehas, QA&S Engineer
  • D. C. Kramer, QA&S Engineer
  • J. G. Weissenberg, QA&S Engineer Kaiser Engineer, Inc. (KEI) Employees
  • K.

Smith, General Superintendent

  • M. G. Franchuk, Mechanical QA Engineer
  • Denotes those presented at the exit interview.

Licensee Action on Previously Indentified Items (Closed) Noncompliance Item (50-358/78-10-01).

Inadequate specifi-cation for procuring mechanical snubbers.

Followup review was made on September 28-29, 1978, (Report No. 50-358/78-22) and was considered insufficient. During this inspection, the latest S&L Specification H-2259, Supplement 6, dated October 6, 1978, was reviewed and was considered adequate.

In regaro to snubber cold position sittings (CPS)

that should be a part of the installation drawing, the inspector reviewed CG6E Audit Report No. 78/09 of October 16-17, 1978.

In Paragraph 3 of the Details of Audit, Part I, S&L committed to include CPS in the design drawings.

(Closed) Unresolved Item (50-358/78-10-08):

Fluid leak of ITT-Grinnell snubbers in storage.

A CG6E QASS Surveillance / Inspection Report No. 40, was issued on May 31, 1978, and was closed on July 18, 1978.

Corrective actions included moving snubbers to Warehouse No. 2.

These snubbers will be checked before final inspection for lockup and bleed rate to determine acceptability, and fluid will be added as required.

The inspector observed conditions of the snubbers in Warehouse No. 2, and had no adverse comments.

(Closed) Unresolved Item (50-358/78-10-09): Missing protective covers for Bergen-Paterson (B-P) hydraulic snubber a '.umulator indicators. A CG&E QA&S Surveillance / Inspection Report, No. 41, was issued on May 31, 1978, and was closed on July 18, 1978.

The B-P snubbers were moved to Warehouse No. 2 for storage. The snubbers were inspected by the KEI QA, and all protective cover were been in place.

The inspector observed the storage condition, and had no further questions.

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(Open) Unresolved Item (50-358/78-18-05): Questionable design for some of the essential support systems.

The licensee and Sargent and Lundy, (the A&E) are putting in a lot of effort in resolving the problems identified. For details see Paragraph 2 of this report.

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(open) Noncompliance Item (50-358/78-18-02): Use of Inter-Office Memorandum (IOM) to deviated approved QA Manual.

The corrective actions stated in licensee response appeared to be inaccurate.

For details, see Paragraph 3 of this report.

(Closed) Noncompliance Item (50-358/78-18-04):

Inadequate protection for B-P snubbers. The inspector reviewed KEI QA Surveillance Report No. 1484, dated December 21, 1978, and had no adverse comments.

The Inspector also observed that the B-P hydraulic snubber accumulator fluid level indicators had been properly protected inside the reactor building.

(open) Unresolved Item (50-358/78-27-02):

Inadeluate measures for component outdoor storage. A CG&E nonconformance report No. 7229 relative to the subject problem was written on December 29, 1978, and all the essen-tial components had been moved to an indoor area.

The inspector stated that he will examine the corrective action, the mapping of the storage areas, and the control of noncomforming materials during a future inspection.

Functional or Program Areas Inspected 1.

Status of Stop Work Orders (SWO)

a.

Hydraulic Snubbers A SWO, No. 78-04, on installation of hydra,,

snubbers was written on August 18, 1978, due to the pro-.

as identified on existing snubbers installed at that time.

Since then an Inter-Department Correspondence (IDC) was written to address the deficiencies in snubber design on November 30, 1978, and stated that SWO No. 78-04 was still in effect.

The latest IDC dated December 14, 1978, discussed lifting the SWO based on acceptable reviews of design at the A&E office.

The SWO was lifted on December 14, 1978.

b.

Mechanical Snubbers A SWO, No. 78-01, on installation of mechanical snubbers was written on June 6,1978, based on inadequate specifications and ista11ation instructions. Subsequently, SWO No. 78-01, Supplement No. 1, dated June 12, 1978, was issued to clarify the intent of the SWO.

In an IDC dated November 30, 1978, discussions were made on the possibility of changing INC snubbers to Pacific Scientific snubbers. The SWO remained in effect to the date of this inspection.

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c.

General Use of Concrete Expansion Anchor Bolts A SWO, No. 78-02, on installation of embedment anchors to support essential hangers was issued on August 14, 1978, based on noncon-pliances identified relative to procedures and installation. This SWO was rescinded on September 7,1978, based on the f act that S&L has issued a new procedure No. H-2174, Section 5-4, entitled

" Concrete Expansion Anchors, Installation and Inspection Procedure,"

dated August 23, 1978, and Revision 2, dated August 31, 1978.

d.

Expansion Anchors In Hollow Block Walls A SWO. No. 78-05, on installation of subject items was issued on October 20, 1978, based on failure to meet required bolt torquing.

Noncomformance report No. E-796 R-1 was written. The dispo-sition written by S&L indicated that only through wall bolts should be used.

This in direct conflict with the S&L Specification No. H-2174, Section 5-4 (reference in the DDC, SLS-315) which specifies expansion anchor bolts be used.

Subsequently, an IDC, dated December 22, 1978, reacinded SWO No. 78-05 on conditions that installation of the field run conduit hangers should be in accordance with KEI procedures and Design Document Changes (DDCs) should be written for attachments other than conduits.

e.

Expansion Anchors Attaching Essential Components te Separate Concrete Floor Finishes (Topping Slab)

A SWO, No 78-06, on installtion of the subject items was issued on October 20, 1978, based on the conflict between S&L drawings and specifications.

The Specification No H-2174, Section 5-4 prohibited the subject installations but drawings were calling for them.

The SWO was lifted on December 19, 1978, on conditions that specific authorization be provided for installation on a case by case basis through use of DDCs.

f.

Expansion Anchors in all Block Walls in Reactor Building, Auxiliary Building and Service Water Pump Structure A SWO, No. 78-07, was issued on installations of subject items based on incomplete analysis by S&L on the capabilty of the block walls where bolts can be installed.

To the date of the inspection, the analysis had not been completed.

In the mean time, work was permitted to proceed based on an IDC, dated December 22, 1978, that specified authorization by S&L on a case by case basis must be given through use of DDCs.

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2.

Status of Hanger and Restraint Designs In August, 1978, e number of hanger, restraints and snubbers with ques-tionable design considerations were identified by the inspector and the items were discussed in Region III Report No. 50-358/78-18,Section II, Paragraph 5.

Support design upgrading due to the change of seismic criteria also caused some problems particulary those associated with supports that had already been installed. A followup CG&E audit at S&L on October 16-17, 1978, identified that most of the essential supports (safety related) were designed without backup calculations.

The condition was reported to Region III on October 18, 1978, in accordance with the 50.55(e) requirements, and an interim report was forwarded to Region III on November 20, 1978.

In discussion with CG6E hanger and QA Engineers, it was acknowledged that among the total number of seven to eight thousand essential supports to be needed at the Zimmer Plant, approximately 750 were reviewed by S&L design engineers, among which 99 were considered to have questionah'e design including overstresses and excessive structural deflections based on newly established deflection acceptance criteria.

The licensee stated that among the 750 supports reviewed, only a few anchors (HA type support) were included, and that based on a preliminary study, 90% of the 99 will require redesign.

In addition, approximatley 100 non-safety related anchors connecting to safety related pipe systems will be evaluated by S&L.

Further, it was stated that among the approximate 700 total number of directisnal restraints, the majority required re-evaluation based on incorrect restrainting directions being specified.

To the date of this inspection, S&L identified 66 essential supports inside the primary containment that will require significant redesign.

Step Work Orders were issued on these supports.

In conclusion, the licensee stated that final stress analysis for piping systems and supports will be furnished by S&L by June, 1979.

CG6E's final report on the 50.55(e) items will be forwarded for Region III evaluation after June, 1979.

3.

Inadequate Corrective Actions The inspector reviewed the CG6E QA directive " Compliance With 10 CFR 50, Appendix B" dated September 9, 1978, and the KEI IOM, dated September 15, 1978, which was written to implement this QA directive, and found neither document rescinded the KEI September 22, 1977, IOM.

This is contrary to Item 5, " Corrective Action Taken and Results Achieved" of the licensee's letter to Region III dated Novermber 3, 1978, responding to the Region III findings in Report No. 50-358/78-18 (inspections performed in August, 1978).

Further, no documentation or actions were observed by the inspector that would support the statements under " Corrective Action Taken to Avoid Further Noncom-pliance" which state, "All inspection personnel were instructed as to-5-

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the cancellation of the practice described in the September 22, 1977, IOM.", and "To prevent further noncompliances of this nature, the KEI QA Department will review the subject nature of all IOMs to assure none are issued which would cause a deviation from established approved procedures."

This is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion XVI, and Wm. H. Zimmer Unit 1, FSAR Paragraph 17.1.16 requirements.

(358/78-32-01)

Exit Interview The inspector met with licensee representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection on December 29, 1978. The inspector summarized the purpose and findings of the inspection. The licensee acknowledged the findings reported herein.

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