ML19207A931
| ML19207A931 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/20/1979 |
| From: | Knop R, Phillips H, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19207A925 | List: |
| References | |
| 50-358-79-14, NUDOCS 7908230052 | |
| Download: ML19207A931 (23) | |
See also: IR 05000358/1979014
Text
.
U.S. NUCLEAR RfG11LATORY COMMISSION
.
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/79-14
Docket No. 50-358
License No. CPPR-88
Licensee:
Cincinnati Gas and
Electric Company
139 East 4th Street
Cincinnati, OH
Facility Name:
Wm. H. Zimmer Nuclear Power Station
Inspection At:
Zimmer Site, Moscow, OH
Inspection Conducted: May 22-24, 1979
'EU~-- h
(> [F /79
.
Inspectors:
T. E. Vandel
h & ngl d- f
~H.
S. Phillips
0 [20 / 79
'
'
b Must 3:~
6[24/Jf
H. M -Nescott
.e
K. R.
aidu
//M' 2#
/
Mp. Knop, Chie[7t
6[M/7f
ut.cdl
Tt.
Approved By:
Projects Section
1.
>ction Summary
Inspection on May 22-24, 1979, (Report No. 50-358/79-14)
Areas Inspected:
Review of previously identified unresolved and non-
compliance matters, review of the licensee auditing systen, piping system
record review for primary coolant piping and other safety related piping.
The inspection involved a total of 101 inspector-hours on site by four
NRC inspectors.
Results: Of the five areas reviewed, two noncompliances were identified
in three of the areas.
(Infractions, failure to provide adequate correc-
tive action, and failure to perform audits of activities as scheduled).
7 90 82 3 00 5~A 9
'
"/8b117
.
DETAILS
.
Persons Contacted
Cincinnati Gas and Electric Company (CG&E)
- R. P. Ehas, QA&S Engineer
- J. W. Haft, QA&S Engineer
- W.
B. Murray, Construction Engineer
- J.
R. Schott, Station Superintendent
- W. W. Schwiers, Principal QA&S Engineer
- J. F. Weissenberg, QA&S Engineer
Principal Contractors
- L.
L. Aiello, QC Inspector General Electric
- E. V. Knox, Corporate Manager Quality Assurance Henry J. Kaiser Co.
(Kaiser)
- R.
Marshall, Project Manager, Kaiser
- J.
Maloney, QA Engineer, Kaiser
- R.
Turner, QA Manager, Kaiser
- Denotes those present at the exit interview.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (50-358/78-09-03); Inadequate information was
available to determine acceptance criteria for inspecting cable tray
hangers fastened to threaded Nelson Studs. During the current inspec-
tion, the inspector determined that construction inspection plan E-14 was
developed with torque testing the bolts of the threaded Nelson Studs. A
system has been established which documents adverse findings in Nonconfor-
mance Reports and includes updating the status of completed inspections.
(0 pen) Unresolved Item P G-358/78-31-01); Unavailability of shop drawings
to verify the welds e
- nt Fuel Storage Racks (SFSR).
The licensee
performed an inspect 1;n on SFSRs and documented his findings in Field
Audit Report 221 dated February 16, 1979.
The inspection involved a random sampling of welds on the (SFSR) to
verify conformance with applicable GE drawings 762E210, Quality Require-
ment 22A2553, Revision 2 and Aluminum Alloy Arc Welding Specification
21A8644 Revision 4.
Several .25" groove welds en the base structural
members were identified to be continuous instead of intermittent as shown
on the drawing 762E210. CGE requested GE to respond to the finding.
GE's reply dated March 6, 1979 informed CGE that the welding symbols on
the drawings were not clear and therefore, CGE's finding was based on
misinterpretation of the welding symbols.
-2-
786118
CGE in their letter dated March 29, 1979 informed GE that their answer
was unacceptable and requested an engineerirg evaluation of the as built
welds. CGE is still waiting f'or GE to reply.
This item remains open.
(Closed) Unresolved Item (50-358/79-12-05); Inadequate information was
available to determine whether the HVAC condensing unit installation was
inspected. During the current inspection, the RIII inspector reviewed
the inspection reports on the installation of the said equipment.
Construction Inspection Plan (ClP) IVC 02CB dated May 23 indicates that
the documents relative to the control room HVAC condensing unit installed
at elevation 567'5" in the auxiliary building were reviewed.
The KEI personnel explained that this review was performed for reassurance
that all documents were available. Release statement WR-1A dated August 9,
1978, indicates that the equipment was acceptable for turnover. Mechanical
Equipment inspection list for this equipment indicates that inspections
were performed at various stages of construction. The licensee's statement
that some hardware was removed after the completion of the final inspection
appears to be acceptable.
(Closed) Unresolved Item (50-358/79-12-06); Inadequate information was
available to determine whether the compressed air tubing installation to
the secondary containment isolation dampers was inspected. During the
current inspection, the inspector reviewed the documentation on the
installation of the Reactor BuiMing Isolation Dampers IVG03YA and IVG03YB.
CIP's dated May 23, 1979 verified that all the necessary documents including
the receipt inspection reports, release for installation and installation
were available. Duct Leakage Test Data Sheets dated May 26 indicates
-
that the leak rate of the two installed valves were tested in accordance
with procedure HVAC4 and determined acceptable. The compressed air
supply to the dampers is not required to close the damper; spring operator
closes the damper. The licensee stated that the compressed air supply is
required to open the damper and therefore not safety related and hence
was not inspected. The licensee's position is acceptable.
-3-
78G119
.
Section I
Prepared by K. R. Naidu
Reviewed by D. W. Hayes, Chief
Engineering Support
Section 1
1.
Review of Electrical Hanger Installation Activities
a.
Cable Tray Hanger Inspection
The inspector reviewed the inspection system developed by
the licensee to inspect the cable tray hangers.
Construction
Inspection Plan (CIP) E-14 established the attributes to
be inspected on Seismic Category 1 cable trrys and includes
verification of hanger location with the benefit of design
drawing, acceptability of hanger welds, sample checking of
the torque on threaded Nelson Studs, and verifying the
torque on anchor bolts. To date, 257 out of a total of
3219 hangers have been inspected. The RIII inspector
selectively verified the inspection findings on the cable
trays and hangers in the Service Water Intake structure
which have been documented in Nonconformance Reports No.
E1786 and No. E1787 and concurred with the inspeccion
findings. The inspector also concurred with the findings
at elevation 473' of the auxiliary building.
b.
Independent Inspection
During the inspection, the RIII inspector observed that
the anchor plates of hangers 1H099 and 1H090 at elevation
546' in the reactor building were fastened with two "Hilti
Quick" bolts on one end and welded on the other end.
The
licensee referred the RIII inspector to Design Document
Change (DDC) E-658.
This DDC dated Janaury 18, 1978,
approved by cognizant S&L and licensee personnel permits
the installation of the anchor plate in such a manner.
c.
Conduit Hanger Inspection
CIP E-145 has been developed to inspect conduit installation
and includes verification of conduit hanger construction,
installation of anchoring, acceptance of welds and proper
location of hanger. Out of a total of 6422 crnduit han,;ers,
-4-
786120
3654 have been inspected. The inspector selectively
reviewed the findings on the inspections performed at
elevations 475', 503' and 546 of the reactor building and
determined that they reflected the inspection plan E-145
requirements.
No items of noncompliance were identitied.
2.
Followup on Corrective Action on HVAC Hanger Installations
a.
The inspector selectively reviewed the action taken by
Waldinger, Younge and Burtke (WYB) to correct the inspection
findings identified in their Nonconformance Reports (NCRs).
The inspector also observed corrective action taken on the
following hangers identified in the respective NCRs.
NCR No. I 78
Hanger No. 2017
NCR No. I 79
Hanger No. 2016
NCR No. I 36
Hanger No. 2007
The inspector also observed work in process to correct the
findings in NCR I 36 for hanger No. 1937 and no deficiencies
were identified.
b.
WYB has established an inspection program to inspect the
equipment installed by them. This is in response to a
previous inspection finding when it was determined that a
nut was missing on the Containment Isolation Damper No.
IVG03YB. WYB documented this finding in NCR No. EI-1A
dated May 22, 1979.
Information is being sought from the
manufacturer on the torquing requirements. This item is
considered unresolved pending review of the checklist
being established for this purpose.
(50-358/79-14-01)
The floor above the switchgear room adjacent to the control
c.
room has excessive dust (like sand) on the false ceiling.
KEI verified this situation and determined that Zonolite
flooring was used in anticipation of covering with a floor
liner to use the area as an instrument room.
Walking on
the Zonolite flooring caused disintegration resulting in
the sandlike particles accumulation. The KEI construction
manager stated that the particles and Zonolite will be
removed since the instrument room has been eliminated.
Corrective action taken will be verified during a subse-
quent inspection. This item is considered unresolved.
(50-358/79-14-02)
No items of noncompliance were identified.
-5-
786121
.
.
3.
Review of Essential Filter Package Documentation
The inspector reviewed specification H-2817 for Package Filter
Units which includes the design, development, manufacture and
delivery of three Essential Filter Packages (1VC09SA, IVC 09SD,
IVC 10S). Two of the Air Filter packages are for the Control
Room and the other is for Control Room Standby Makeup.
The
inspector reviewed the documentation on the Essential Filter
package IVC 09SA. The documentation which was audited by CGE QA
personnel on June 1,
1977, includes the following:
a.
Liquid Penetrant Test Report (LPTR) on the HECA filter
frame close out welds.
b.
LPTR on the HEPA filter frame close out welds.
Housing and HEPa filter frame Leak Test Reports
c.
d.
Certificate of Conformance from ACS Industries that the
moisture separators meet MSAR-71-45 specifications.
Filter test and inspection reports froa Union Carbide
e.
Corporation, on the HEPA filters.
Certificate of Confor-
mance that the filters meet Paragraph 203.6 of specifi-
cation H-2817.
f.
Test report from Sutcliffe, Speakran and Colt on the
charcoal used in the absorbers.
-
g.
Charcoal Absorber Certificaticn
h.
Flanders Filters Incorporated's certificate of conformance
on the prefilters that they meet Paragraph 203.4 of specifi-
cation H-2817.
i.
Seismic certification on the deluge valves supplied by
Alison Control Incorporated.
j.
Review of the above item d indicates that the Certificate
of Conformance issued by ACS Industries, the supplier of
the separators, covers only Paragraph 203.2.d and not
Paragraph 203.2.c.
-6-
786122
.
(1) Paragraph 203.2.c states in part:
"The separator
shall Lave demonstrated its ability to prevent blinding
(defined as a p~ressure drop increase of over 5% of a
down stream HEPA filter at a test condition of 260 F
and two psig condition for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with steam-air
mixture containing one gallon of water droplets".
Moisture separators described in AEC Report NYO-3250-6
have not met the aforementioned conditions.
(2) Paragraph 203.2.d requires that the separator shall
have demonstrated its ability to meet qualification
requirements used in MSAR-71-45.
The licensee discussed this subject with S&L and informed
the inspector that Paragraph 203.3.c applies only for
PWRs. The licensee agreed to obtain a Design Change to
the specification. This matter is considered unresolved
pending issue and review of the Design Change.
(50-358/
79-14-03)
k.
Relative to the above item g, the inspector informed the
licensee that the available documentation did not certify
charcoal met Paragraph 203.6.b of H-2817.
The licensee
agreed to obtain additional information.
Pending receipt
of this information, this item is also considered unresolved.
(358/79-14-04)
No items of noncompliance were identified.
t
4.
Review of Installed Safety Related HVAC Systems
During observation of the installed safety related ductwork
a.
systems, the inspector identified compressed air system
lines, installed by Powers Regulator, attached to safety
related ductwork. These lines supply air for operating
nca-safety related dampers and hence were not inspected.
The inspector informed the licensee, that although these
air lines were non-safety related, they should be inspected
by the Powers Regulator to insure that their installation
had not adversly effected the safety related ductwork.
Pending development and implementation of an inspection
program, this matter is considered unresolved.
(50-358/
79-14-05)
-7-
786123
b.
The inspector verified whether the standby gas treatment
system would initiate on any of the four signals ennumerated
in Paragraph 7.3.1.1'.8 of the Zimmer Final Safety Analysis
Report. Review of S&L drawings M-714, Sheets 6 and 7,
indicate compliance to Paragraph 7.3.1.1.8.
However, it
was established that Radiation Sensors identified as RE
ID13N009B and RE ID13N019B which are to be located in the
HVAC ductwork have not been installed. These detectors
are supplied by General Electric and have not been installed
because the eounting to Seismic Category I requirements
has not been approved. Pending review of the final approved
mounting of Seismic Category 1 installation, this item is
considered unresolved.
(50-358/79-14-06)
No items of noncompliance were identified.
. _ ,
I
- 8-
d'W0.Qs'd4
Section II
Prepared by H. S. Phillips
Reviewed by R. C. Knop, Chief
Projects Section 1
1.
Introduction
A comprehensive review of the licensee's audit system was
initiated during an NRC inspection on April 24, 1979. The
preliminary inspection results were reported as unresolved in
NRC Report No. 50-358/79-12 dated June 7 1979.
Final results
and findings are summarized in the following paragraphs.
2.
U.S. Test Lab Audit of Licensee's QA&S Section
U.S. Test Lab was retained to review CG&E QA&S Section.
These
reviews were performed three times per year from 1972 to 1975.
The reviews were performed twice per year until 1978 when the
frequency was reduced in QAP No. 18 to once per year.
Procedure No. 18, Paragraph 18.2 states that management audits
will be performed at least annually. The William H. Zimmer
Nuclear Power Station FSAR Section 17.1.18 states that management
audits of QA&S are conducted by a representative of the Vice
President at least semiannually for determining the effectiveness
of the QA program. The inspector found no quality history
which would justify decreasing the frequency.
See Appendix A,
Item 2.
(358/79-14-07)
This findiu represents a noncompliance to 10 CFR 50, Appendix B,
s
Criterion XVII which states in part:
"A comprehensive system
of planned and periodic audits shall be carried out to verify
compliance with all aspects of the quality assurance program
and to determine the effectiveness of the program" and Section
17.1.18 of the FSAR which states that the effectiveness of the
QA program will be audited at least semiannually.
The inspector reviewed the 1978 U.S. Test Lab Audit and found
that findings were open from audits performed in 1976 and 1977.
Four (4) audit findings were still open af ter an extended
period.
One finding concerning inadequate documentation review
for safety related doors numbers 268, 269 and 270 was not
responded to in 1977. The 1978 U.S. Test Lab audit noted this
fact. The licensee's QA&S section response to the 1978 audit
was inadequate in that the licensee failed to respond to the
audit finding and corrective action did not assure that other
-9_
786125
packages, reviewed by the same individual, were complete.
Also, no review or audit was made to assure that other docu-
mentation packages, reviewed by other QA personnel, were complete.
See Appendix A, Item 1.
(358/79-14-08)
This findings represents a noncompliance to 10 CFR 50, Appendix B,
Criterion XVI; William H. Zimmer FSAR Section 17 and QA Manual
Section 16.
3.
CG&E/QAS Section Field Audits
Audit schedules, log., selected auditor qualifications and
audits were reviewed. The findings were satisfactory except as
follows:
Response to Audit Findings
a.
Replies to the following audits were not received within
the specified time (30 daysi.
See Appendix A, Item 2.
(358/79-14-09)
Audit No.
Reply Due
Reply Received
179
6-28-78
None as of 4-26-79
IS6
8-24-78
11-28-78
197
Before 11-22-78
None as of 4-26-79
202
11-22-78
2-79
203
11-24-78
None as of 4-26-79
215
1-11-79
None as of 4-26-79
217
Before 2-24-79
None as of 4-26-79
220
2-24-79
None as of 4-26-79
This finding represents a noncompliance to 10 CFR 50,
Appendix B. Criterion XVI; Zimmer FSAR Section 17.1.18 and
QA Manual Section 18 which states in part, " Measures shall
be established to assure conditions adverse to quality
.
. and not conformances are promptly identified and
corrected."
b.
Documentation of CG&E/QAS Audit Findings
The inspector reviewed of audit Nos. 178, 179, 180, 186,
188, 192, 197, 202, 203, 215, 217, 218, 219, 220, 221,
223, 224, 225, and 228. The review revealed that audit
findings were not clearly classified as deficiency, obser-
vation or suggestion in Audit Nos. 217 and 223, thus, were
improperly documented. See Appendix A, Item 2.
(358/79-14-10)
- 10 -
786126
This represents a noncompliance to 10 CFR 50, Appendix B,
Criterion XVIII; Zimmer FSAR Section 17.3.18 and QA Manual
Section 18.
c.
Audits of Kaiser
Sixteen (16) of eighteen (18) Kaiser Procedures were
audited in 1978. QA Procedures 4 and 17 were scheduled to
be audited in September and October, 1978, respectively.
The audits had not been performed as of April 26, 1979.
Zimmer QA Manual Section 18 required that the procedures
be audited annually.
See Appendix A, Item 2.
(358/79-14-11)
This finding represents a noncompliance to 10 CFR 50,
Appendix B, Criterion XVIII.
3.
CG&E/QAS Section Audit of Vendors
The inspector reviewed vendor audit performed in 1978.
In
several instances vendor audits appeared to be reactions to NRC
identified problems. The audit log indicated that 1974, 1975,
1976, 1977, and 1978 findings were followed up and were closed.
No items of noncompliance or deviations were identified.
4.
H. J. Kaiser Company Audits
This company performs several important functions on site. The
quality organization, composed of approximately 40 personnel,
performs audits and inspections to control mechanical and
electrical work performed under the direct control of Kaiser.
The mechanical work is performed by Kaiser construction personnel
while the electrical work is being performed by Foothill Electric
Company, a subsidiary of Kaiser. The importance of this work
necessitates comprehensive auditing of all elements of the
Kaiser and Foothill QA program.
Management of the Kaiser QA Program Audits
a.
The Kaiser QA program is described in twenty-one (21)
Quality Assurance Procedures, QAP 1-20, which impose
requirements and general procedures based on the eighteen
criteria of 10 CFR 50, Appendix B.
Implementing procedures
describing how requirements shall be executed are contained
in (1) Sixty (60) QACMI Nos. G-1 through G-17, C-1 through
C-12, M-1 through M-16, E-1, 7, 8, 10, 13, 14, 15 and 16,
R-1, 2 and 5; (2) Twenty-five (25) Special Process Procedures
plus eighty (80) individual welding procedures; and (3)
- 11 -
7861'd7
approximately eighty-two (82) Field Construction Procedures.
The total number of main procedures totals one hundred
sixty seven (167) plus an additional eighty detailed
welding procedures which total approximately two hundred
forty-seven (247) procedures.
Sufficient management controls, such as a tracking system /
matrix /index, were not established to assure that the
essentials of all procedures are audited.
Kaiser Procedure
QAP-19, Paragraph 3.4, states:
3.4 The QA engineer audits the quality element against
the requirements and procedures imposed by the Kaiser QA
Manual.
This audit consists of, but is not limited to the
following as applicable:
3.4.1
A review of the requirements of all procedures,
forms, or specifications, associated with the audit element
to determine the adequacy of the element:
3.4.2
A review of all operations associated with the
audit element to determine adherance to written procedures,
including the witnessing of operations as required.
Par. graph 3.1 established a schedule for auditing twenty
quality system elements in the twenty QA procedures.
Audit schedules were based primarily on these twenty
procedures while largely ignoring the implementing proce-
dures previously listed.
.-
At this point the inspector considered this a finding but
decided to randomly select three important elements as a
sample. Audits of the selected sample of elements were
scrutinized to determine if comprehensive audits of the
elements were performed by the site Kaiser QA organization.
If not, did CG&E/QAS Section audits identify the problem
and assure correction?
(1) Kaiser Manual; Element 11, QAP No. 10, " Control of
Special Processes." Implementing procedures pertain-
ing to this element would include but not be limited
to the following:
QACMI:
G-11, G-12, G-13, G-16, M-10
SPPM Part 1:
1.0, 2.0, 3.0, 4.0, 5.0, 7.0, 8.0, 9.0
Part 2:
Welding Procedures, 3.1.1-3.1.8
Construction Procedure:
2-111, 2-116
- 12 -
78G128
The audit log showed that in 1978 the Kaiser site QA
-
organization failed to perform any audits in the area
of special processes.
Audits of the Kaiser Site QA group were performed by
Xaiser Corporate QA as required in Kaiser QA Manual,
QAP No. 19, Paragraph 2.3, which states, " Independent
audits of the OA Program shall be conducted periodically
by the CGS 1 QA and Standards Subject, the KEI Corporate
QA Division and Hartford Steam Boilder Inspection and
Insurance Company." The inspector found that the
following audits had been performed:
1978 Audits
Organi-
Audit
zation
No.
Subject of Audit
CG&E/Q4S
173
Kaiser and Peabody /Magnaflux
CG&E/QAS
206
QAP-10, Welder qualification;
written procedures approved;
receiving inspection, QA records
of welders
CC&E/QAS
2C7
QACMI C-3, Rev. 3, Record of
Cadwelder Qualification
Kaiser
38
Two auditors on site from
-
Corporate
July 25-27, 1979.
Followup
QA Audit
performed on Audit No. 23
of Site
which included audit of QAP-10
Section 3.4, SPPM 5.0, 5.1 and
5.2 plus S&L Specification H-2256,
KE Construction Procedure No.
2-116.
All the these pertain to
heat treatment.
1977 Audits
The Site QA organization audit log showed that 1977
audit Nos. 308 (April, 1977) through 342 (December,
1977) included only one audit in the area of special
processes. The area audited was a review of welder
qua}!')tation records.
Corporate QA Audit of Site, Audit No. 23.
In 1977,
one audit of site activities was performed by two
a:ditors on May 3-6, 1977. The audit checklist
.
- 13 -
78G129
consisted of five parts:
1.0, Audit Followup; 2.0,
SPP 5.0 General Heat Treatment; 3.0, SPP 5.1 Post
Weld Heat Treatment; 4.0, SPP 5.2 Code Heat Treatment;
5.0, QAP-6, Supplier QA.
In reviewing this Kaiser audits described above, the
inspector found the following:
(a) Element 11 was not comprehensively audited
because management tuntivls were not in place to
assure that the KEI QA organization audited
elements at the frequency prescribed in KEI QA
Manual, QAP No. 19, Figure 19-1.
The frequency
for special processes was each six months whereas
KEI Site QA audited once in 1977 and none in
1978. See Appendix A, Item 2.
(358/79-14-12)
(b) Additionally, Element 11 was not comprehensively
audited because SPPM 3.0, Welding, and 4.0,
Nondestructive Examination, were not audited.
See Appendix A, Item 2.
(358/79-14-13)
(c) Followup on audit findings 1.3 and 1.5 dating
back to Audit No. 17 perfortned in September,
1976, were not maintained or documented as
closed in Audit Nos. 23 (May, 1977) nor in 38
9 July, 1978).
Also, 1977 audit finding requiring
action were not documented in the report as open
or closed as follows:
2.1, 3.2, 3.3, 3.4,
4.1.1, 4.1.2, 5.2, 5.3, and 6.2.
(358/79-14-14)
(2) Kaiser QA Manual, QAP No. 13, Element 13, " Calibration
of Measurement and Test Equipment." In addition to
QAP No. 13, supplemental implementing procedures
pertaining to this element would include but not be
limited to:
QACMI Nos. C-2, C-10, M-10 Paragraph 3.5.3, Test Plan
10-102, M-15, M-16 Paragraph 5.2(3), E-7, E-10.
SPP
3.0, 4.0, 5.0 which require use of densitometers,
heat treat equipment controls, welding control meters
etc.
1978 Audits _
Kaiser QA Manual, QAP 19, Figure 19-1 requires that
calibration Element 13 be audited every eight (8)
months. The inspector found the following:
- 14 -
786130
Organi-
Audit
zation
No.
Subject of Audit
Kaiser Site
346
ANSI N45.2.8 and ASME III;
QAP 13 except Paragraphs 2.5,
2.6, 2.7.
Paragraph 2.7 "Cali-
bration against National Stand-
ards" was added to KEI Procedure
QAP 13, Rev. 4, on May 8, 1979.
KEI Site QA
353
This audit contained results of
auditing Foothill Electric Co.
against QACMI No. E-7, Rev. 10,
" Electrical Installation Procedure
- Cable Pulling." Cable pull
dynometer calibration was
verified.
KEI Site QA
358
Actual calibration was not
audited.
The main thrust of this audit
was
Hydro Report I:eview, however,
parts
of the report pertained to
calibration.
KEI Site QA
369 Review of Calibration Procedures
Manual (Records)
Kaiser Site
360 QACHI, E-10, " Calibration of Termina-
tion Tool"
Kaiser Corp
38 Followup on calibration of Postweld
Treatment Contrcl equipment / recorders.
159
Calibration frequency and tagging
of torque wrenches, gauges, pyrometers;
identification; recall; calibration
instructions, purchase order for
calibration services.
The above audits of Element 13 were adequate except
-
as follows:
The calibration procedure did not require calibration
against certified measurement standard having a known
- 15 -
286131
relationship to National Standards.
Thus, this area
of calibration was not audited in 1978.
See Appendix A,
Item 2.
(358/79-14-15)
(3) Kaiser QA Manual, Element 16, QAP No. 16, " Control of
Nonconforming Materials, Parts, and Components" and
QACMI No. G-4 " Nonconforming Material Control."
KEI QA Manual requires audit of this element every
six months. The inspector found that the following
1978 Audits
Organi-
Audit
zation
No.
Subject of Audit
Kaiser Site None
None Periormed
Kaiser Site None
None Performed
183
QAP 9, Material Identified / Controlled
and QAP-16 Control of Nonconformances
except disposition of nonconformances
was not audited.
1977 Audits
Organi-
Audit
zation
No.
Subject of Audit
Kaiser Site
313 Audit of QAP 16 consisted of
reviewing audits to see if
nonconformances identified during
audits received proper followup.
Kaiser Site
325 Review of previous audit of QAP 16
and QACMI, 6-4, Paragraph 1.4;
75 NCR/ Inspection reports reviewed;
disposition by engineering; rework
and hold points.
The inspector found that Element 16 was properly audited during
1977, however, the element was act audited at all by Kaiser in
1978.
Additionally, in 1978 neither Kaiser nor CG&E Qa audited
nonconformance dispositioning, which is an essential part of
the element.
See Appendix A, Iten 2.
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78G132
b.
Kaiser Audit Checklists
Kaiser audit checklists were not in file for Audit Nos.
349, 351, 352, 354, 357, 360, and 369.
Seven of sixty-eight
reviewed were missing.
(358/79-14-16)
c.
Audit of Other Elements (January, 1978-April, 1979)
Superficial review of KEI Audit Schedule / Log indicated
that Elements 1, 3, 4, and 8 may have not been audited to
the required frequency.
The licensee should review this
area thoroughly and address the matter under his corrective
action in the reply to similar items of noncompliance in
this NRC report.
This matter is unresolved pending the
response to this report.
(358/79-14-17)
The findings described in Paragraph 4.a and 4.b above
represent items of noncompliance to 10 CIP 50, Appendix B,
Criterion XVIII.
5.
Inadequate Corrective Action
Kaiser QA Manual, QAP No. 16, Paragraph 3.6, states, " Corrective
action on recurring discrepancies will be reviewed and analyzed
by the Quality Assurance Engineer responsible for that discipline
in question (electrical-mechanical piping). After such analysis
is made, he will report his findings to the Quality Assurance
Manager for further action.
The inspector found no such analysis or reports had been made.
See Appendix A, Item 1.
(358/79-14-18)
The licensee QAS Section had identified problems with the audit
tracking system records. A new procedure was developed, however,
the old log which showed audit finding / followup status was not
corrected.
That is, thirty-one (31) of sixty-six (66) entries
were not made.
In nine (9) cases, the column was marked not
applicable when applicable should have been marked.
See Appendix A,
Item 1.
(358/79-14-19)
The above findings represent a noncompliance to 10 CFR 50,
Appendix B, Criterion XVI.
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786133
Section III
Prepared by H. M. Wescott
Reviewed by R. C. Knop, Chief
Projects Section
1.
Review of QA Records, Reactor Coolant Pressure Boundary Piping
The inspector reviewed reactor boundary piping quality related
records to ascertain whether these records reflect work accomplish-
ment consistent with NRC requirements and SAR commitments, as follows:
Review of the following Standard Procedure Engineering (SPE):
a.
(1) SPE-1001, Rev.
1, dated January 8,1970, " Solution Heat
Treatment for 300 Series Chromium Nickel m;ainless Steel".
(2) SPE-1005, Rev. 2, " Stainless Steel Hot Bending Procedure".
(3) SPE-1007, Rev. 3, dated June 17, 1971, " Ferrite Control of
Austenitic Steel Welds".
(4) SPE-53, Rev. 2, dated June 19, 1971, " Ultrasonic Testing
Procedure".
(5) SPE-55, Rev. 1, dated August 26, 1971, " Ultrasonic Thick-
,.
ness Gauging Procedure".
(6) SPE-121, Rev. 2, dated 6/15/71, " Liquid Penetrant Inspec-
tion".
(7) " Liquid Penetrant Examination Procedure Per Nuclear Power
Piping Code USAS B31.7 (Class 1 Piping) Rev. 3, dated
April 15, 1971.
(b) Review of QA records for the Reactor Recirculating Loop Piping
System, GE P0 No. 205-AD761, pieces marked, PC MK P26-1, and
P30-1.
These records contained as follows:
(1) Drawings of pieces.
(2) Weld Procedure Qualification Certificate of Compliance.
(3) Solution Annealing Records and Certificates of Compliance.
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786134
(4) Hydro Test Warranty and Certificates of Hydro Tests.
(5) Welder Qualification Certificates of compliance.
(6) Non-Destructive Examination Personnel Certificates of
complieuce to SNT-TC-1A.
(7) Chemical and Physical certificates and data.
(8) Heat Treatment Certificates of Compliance.
(9) Furnace strip chants of heat treatment performed.
(10) Certificate of Compliance to PO NO. AD 761
Review of beviation Disposition Request, DDR No. 5030
c.
d.
Paview of Purchase Specification 21A9318, Rev. 3, for
Recirculation Loop Piping.
(1) Purchase specification No. 21A9318 Paragraph 4.3.2.2
states that, " Materials shall be annealed by heating to a
temperature between 1900 and 2050 F and held at this
temperature for one hour per inch of thickness, but not
less than one half hour;"
Review of heat treatment oven
strip chart recording for Job No. 15095F date Approved
May 31, 1972, established that material heat treated was
held at the required temperature for approximately four
(4) minutes, in addition, one (1) loading appears to be
questionable in that the average temperature was approxi-
mately 1885 F.
Also, review of heat treatment strip chart
recording No. 58, dated March 14, 1972 for Job No. 15118
for Ells No. 19 thru 28, established that the chart was
incomplete. The portion retained for documentation pur-
poses indicates that this material was held in the oven
for four and one half (4.5) hours.
This item is unresolved pending the licensees review and
audit of the solution annealing heat treatment records Ibe
the reactor recirculating loop system to verify compliance
with applicable procedures.
(50-358/79-14-20)
(2) Deviation Disposition Request, DDR No. 5030 Reference;
Recirculation Loop Piping, dated August 24, 1971, states,
" Plate was purchased per your 21A9318 Rev. 2 which states
" Materials shall meet all the requirements of ANSI B31.7
Class 1" (REF 4.3.1).
ANSI B31.7 Class I states "Sahll
meet requirements of A-358".
A-358 defines lot as all
pipe of same material and same wall thickness.
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766135
Your 21A9318 Rev. 3 defines lot as all pipe or fittings of
the same mill heat of material wall thickness which is
heat treated in one furnace charge.
Revision 3 would require more test plates than was pur-
chased per Rev. 2.
Securing more test plates would require
using plates on hand for test plates and purchasing more
plate for pipe. Because of prolonged delivery and high
cost involved, we ask this deviation from your 21A9318,
Revision
3."
The above was approved based on A-358 definition of a " Lot" and
that the definition of " Lot" in 21A9318, Rev. 3 would apply to
Section III 1971 contracts.
Specification No. 21A9318, Rev. 3, Paragraph 4.1.3, states,
"Where the requirements of this specification are more strin-
gent than the requirements of the above codes, this specif1-
cation shall take precedence."
Test plates that are not of the same material used in fabri-
cation would not be representative samples.
This item is unresolved pending review by the licensee to es-
tablish that the above is acceptable.
(50-358/76-14-21)
(3) Specification 21A9318, Revision 3, Paragraph 4.4.7.e.
states that, "The allowable out-of-roundness of bends as
determined by the dif ference between the major and minor
.e
diameters shall not be greater than 8 percent of the
nominal diamter."
The inspector could not verify that the ovality require-
ments for the headers in the recirculating loop piping as
there was no documented measurements in the QA/QC records.
This item is unresolved pending the licensee's review to
establish that the requried measurements are documented.
(50-358/79-14-22)
(4) Certification of weld filler metal for heat Nos. 81973-65,
D2006T308, and C2006T308, did not list the physical test
results for the material in the as welded condition. This
item is unresolved pending the licensee's review of the
QA/QC records to establish that the tests were performed
on test pieces.
(50-358/79-14-23).
-2
-
786136
2.
Review of Safety Related Piping Quality Assurance Records
The inspector reviewed quality records relative to safety related
piping activities outside the reactor coolant boundary to ascertain
whether these records reflect work accomplishments and SAR commit-
ments.
Review of Seven (7) NDE Personnel qualification records to
a.
verify qualification to SNT-TC-1A requirements.
b.
Review of welder qualification records and maintenance of
qualifications.
Review of isometric drawings.
c.
d.
Review of weld material certifications.
e.
Review of weld material issue records.
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786137
Section IV
Prepardd by T. E. Vandel
Reviewed by R. C. Knop, Chief
Projects Section
Subsequest to the receipt of an affidavit regarding watertight doors at
the Zimmer hearing during the week of May 21, 1979, the inspector re-
viewed records regarding water tight doors located ie the reactor build-
ing and water pump tuuse. The following information was obtained.
1.
Employee A was on site during February and March 1978, employed by
R. V. Harty Company to install watertight doors.
2.
A Fopsi pressure test was applied by Employee A as a contractor
proof test and not a licensee quality acceptance test.
3.
Tea doors failed to hold the Fopsi due to leaking between the steel
angle door frame and the concrete placement in which they were
embedded.
4.
Subsequent to the time the R. V. Harty Company departed from the
site, the leaking door frames were repaired utilizing an epoxy
plastic material.
5.
Currently the quality acceptance tests are being performed with two
frame tests, one at 10 psi and a second at 17 psi being performed,
along with a door test at 82 psi (door seal test) also being
performed.
6.
The inspector reviewed some test results of tests that had been
successfully completed.
All door testing had not been completed at
the time of the inspection. Further review will be conducted during
future inspections.
(50-358/79-14-24)
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncom-
pliance or deviations. Unresolved items disclosed during this inspection
are discussed in Section I, Paragraphs 2b, 2c, 3j , 3k, 4a, and 4b,
Sections III, Paragraphs Ic(1), Ic(2), Ic(3) and Ic(4) and Section 4.
- 22 -
76G138
Exit Intervi_ew
The inspectors met with site staff representatives (denoted in the
Persons Contacted paragraph) at the conclusion of the inspection on
May 24, 1979. The inspectors summarized the scope and findings of
the inspection, including the apparent items of noncompliance identi-
fied in the Results Section IIof this report. The licensee acknowledged
the findings.
The licensee was also provided a punch list of items prepared by NRC
that are open items requiring followup and close out during future
inspections.
This list also included two items that notification is
requested so that the construction activities may be observed by NRC
inspectors.
s
- 23 -
%66139