ML19305C592
| ML19305C592 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 02/12/1980 |
| From: | Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19305C588 | List: |
| References | |
| 50-358-79-37, NUDOCS 8003310124 | |
| Download: ML19305C592 (8) | |
See also: IR 05000358/1979037
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/79-37
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 Power Station
Inr.pection At:
Zimmer Site, Moscow, Ohio
Inspection Conducted. December 27-28, 1979, and January 17-18, 1980
.DYllt.
Inspector:
I. T. Yin
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Accompanying Personnel:
G. Fiorelli
(January 18, 1980, only) R. C. Knop
T. E. Vandel
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Approved By:
D. H. Danielson, Chief
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,C
Engineering Support Section 2
Inspection Summary
Inspection on December 27-28, 1979 and January 17-18, 1980 (Report No.
50-358/79-37)
Areas Inspected:
Inspection of safety related hanger, restraint, and
snubber site inspection program. The inspection involved a total of 18
inspector-hours onsite by one NRC inspector.
Results:
In the one area inspected, four apparent items of noncompliance
were identified (infraction-failure to execute piping suspension system
activities
paragraph 2; infraction-failure to control work procedures -
paragraph 3; infraction-inadequate measures to protect hydraulic snubbers
from damage
paragraph 4; infraction-failure to promptly identify defici-
encies and prevent their reoccurrence - paragraph 5.)
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DETAILS
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Persons Contacted
Site Inspection on December 27-28, 1979 and January 17, 1980
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Principal Licensee (CG & E) Personnel
- B. K. Culver, Project Manager
W. W. Schwiers, QA Manager
- J. F. Weissenberg, QA 0 S Engineer
- H. P. Ehas, QA & S Ergineer
CD. C. Kramer, QA & S Engineer
- C. A. Burgen, QA & S Engineer
- J. B. Vorderbrueggen, Field Engineer
Henry J. Kaiser Company (HJK)
- S. E. Heath, QA Supervisor
- T. Daniels, Senior Resident Inspector
Management Meeting at Site on January 18, 1980
CG&E Employees
E. A. Borgmann, Vice President
B. K. Culver, Project Manager
W. W. Schwiers, QA Manager
R. P. Ehas, QA and S Engineer
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J. B. Vorderbrueggen, Field Engineer
D. Waymire, Manager of General Engineering Department
HJK Employees
R. Marshall, Project Manager
K. R. Baumgarten, QA Manager
I. T. Yin, Reactor Inspector
T. E. Vandel, Project Inspector
T. Daniels, Senior Resident Inspector
R. C. Knop, Section Chief-
G. Fiore111, Branch Chief
- Denotes those attending the exit interview of December 28, 1979.
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Licensee Action on Previously Identified Items
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(0 pen) Noncompliance Item (358/79-22-03):
Inadequate hanger and snubber
storage and nonconformance control. The inspector observed the storage
building and saw improvement in overall arrangements.
The storage areas
were divided in groups of excess material, void and deleted material, and
useable material, which were not defined in the licensee procedure No.
FCP2-138, " Hanger Componet Cleaning and Reconditioning in Hanger Storage",
Revision 0, dated September 27, 1979. The inspector requested clarifica-
tion of the requirement for restoratiou of material prior to placing in
the "usesble" areas and stated the need for better control of scattered
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scrap materials outside the storage buildings. The licensee committed
to revise procedure No. FCP2-138, and improve the handling of the scrap
material.
(Closed) Unresolved Item (358/79-22-02):
Inadequate site document control.
The licensee performed an audit in the subject area on August 27-31, 1979,
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and the findings were recorded in CG&E QA and S Audit / Surveillance Report
No. 263. While the audit was considered sufficient, the corrective action
was not considered to be adequate. This is part of the item of noncom-
pliance described in Paragraph 5.d. of this report.
Functional or Program Areas Inspected
1.
A-E Review on Safety Related Hangers and Restraints
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The status of the subject matter submitted form S&L to the licensee
was reviewed by the inspector. Among the estimated 5,100 essential
and seismic hanger items, 2,179 have been evaluated.
Among the 2,179
items, only 774 of the original design were checked and found to be
acceptable. The trend of major or minor redesign effort was increased
form 50% as reported in July 1979, (RIII Report No. 50-358/79-22) to
64% as of this report.
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2.
Inadequate Hanger and Snubber Inspection
To the date of this inspection, none of the variable and constraint
spring hangers, and the hydraulic or mechanical snubbers have been
final inspected and accepted by the licensee.
While the craft was
modifying and installing approximately 1,572 safety and non-safety
hanger items thru November 1979, HJK QA installation inspection
surveillance of hangers per procedure No. FCP 2-135, " Process Pipe
Support Installation After S&L Final Design Analysis", Revision 3,
dated July 19, 1979, has been stopped since receipt of a CG&E letter,
dated September 6,1979, stating, " Verification of configuration and
location of seismic hangers is not the responsibility of the
Henry J. Kaiser inspection forces."
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Even before September 6, 1979, the HJK QA was only performing spot
'QC hanger inspection on one out of 15 to 20 installations. The
.present problem also involves inadequate guidance in regard to the
acceptance criteria and documentation for the HJK engineering to
" visually verify all hanger installations for completeness and com-
pliance in accordance with the specifications, approved drawings,
DDC's, and the criteria stated within this procedure" as required
in HJK procedure No. FCP 2-135, Revision 3, paragraph 2.2.8.
The
problem was further compounded by the fact that there were approxi-
mately 1,000 Design Document Changes (DDC's) not finally approved
by S&L, and this meant no final QC acceptance on these installations.
Also with the limited work force under the CG&E Hanger Engineer they
could only afford to inspect the items required immediately prior to
system pre-op tests. The lack of sufficient QC inspection program
on safety related suspension system installation is considered an
item of noncompliance with 10 CFR 50, Appendix B, Criterion X, and
. William H. 7.immer, . Unit 1, FSAR Paragraph 17.1.10 requirements.
(358/79-37-01)
3.
Inadequate Procedure Control and Implementation
As stated in Paragraph 2 above, the HJK QA had stopped their hanger
inspection surveillance effort after receiving the CG&E letter dated
September 6, 1979. Although this action was apparently contrary to
procedure No. FCP 2-135, Revision 3, Paragh 2.2.10 (b) and (d) which
states that HJK QA inspection shall perform installation inspection
surveillance of hangers and perform construction inspection in ac-
cordance with QACMI M-12, a request for clarification of the letters
intent, or a revision to the FCF prior to work implementation Md
never been made.
In addition, Paragraph 2.2.2 of the HJK proce ure
No. FCP2-135, Revision 3, which states, "KEI Engineering will review
all preliminary (progress print) reissued drawings for feasibility of
installation. All changes will be concurred with by CG&E site hanger
department and returned to S&L, Chicago." This procedure had not been
changed to reflect the present arrangement to have an outside consultant,
Nuclear Power Services, performing the HJK and CG&E functions as stated
in the procedure.
The use of licensee correspontiance to document work instructions
and failure to update the controlled procedure is considered an
item of noncompliance with 10 CFR 50, Appendix B, Criterion VI,
and William H. Zimmer, Unit 1, FSAR Paragraph 17.1.6 requirements.
(358/79-37-02)
4.
Inadequate Protection for B-P Hydraulic Snubbers
During an inspection inside the containment, four B-P snubbers on
RH01B18-36 line were observed without accumulator indicator pro-
tective covers or with inadequate covers. Three similar conditions
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were observed outside the containment in the reactor building.
Furthermore, many B-P. snubbers were installed on walkways and were
covered with dust, dirt, and mud.
The requirement for B-P accumula-
tor covers to prevent entry of foreign matter into the cavity was
discussed in RIII Report No. 50-358/78-10, Paragraph 5.b.
A Noncon-
formance . Report, No. 7424 was issued by the licensee on December 27,
1979.
Failure to protect safety related component during installation is
considered an item of noncompliance with 10 CFR 50, Appendix B,
Criterion XIII and William H. Zimmer, Unit 1, FSAR Paragraph 17.1.13
requirements. (358/79-37-03).
5.
Inadequate Licensee Corrective Action
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The noncompliance items identified in this report are similar to
problems identified previously by the RIII inspector. These include:
a.
The inadequate hanger inspection program as described in Par-
agraph 2 of this report was previously cited in RIII Report
No. 50-358/78-18,Section II , Paragraph la and b.
(358/78-18-01)
b.
The use of company correspondence in lieu of an approved work
procedure as described in Paragraph 3 of this report, the lack
of control of procedures, and the failure to correct the in-
spector identified problems were previously documented in RIII
Report 50-358/78-18,Section II Paragraph 2 (358/78-18-02),
and Paragraph 3 (358/78-18-03); and RIII Report 50-358/78-32,
Pa ragraph 3 (358/78-32-01).
c.
The lack of protective mrasures for the B-P hydraulic snubbers
as described in Paragraph 3 of this report was once cited in
RIII Report 50-358/78-18,Section II, Paragraph 4 (358/78-18-04).
d.
In review of CG&E QA & S Audit / Surveillance Report No. 263,
dated August 27-31,'1979, a deficiency was identified relative
to document issuance control of the CG&E construction and test
procedures. The audit finding response by the CG&E Construct
Department through and Inter-Department Correspondence, dated
September 18, 1979, stated, ".
. addressee to return a signed
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copy of the letter as acknowledgement of the procedure." The
inspector reviewed the document file in CG&E Construction
Department and considered the corrective action inadequate, in
that (1) no approved procedure on how to handle the issuance
of work procedures including all subsequent revisison was estab-
lished-and (2) no effort was made to check all work-procedures
received by the addressee and to assure that the up-to-date
revisions were in their work location.
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This is considered an item of noncompliance with 10 CFR 50,
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Appendix B, Criterion XVI, and William H. Zimmer Unit 1, FSAR
Paragraph 17.1.16 requirements. (358/79-37-04)
6.
Followup Management Discussions
Subsequent to the December 27-28, 1979, site inspection, RIII
management held discussions with the CG&E Vice President and his
Ftaff through conference telephone calls on January 2 and 9, 1980.
Besides the concern for the repeated problems as identified in
this report, there was also a question relative to CGE allowing
field engineers to perform the quality control inspection work.
The involved CG&E field engineers not only worked under the depart-
ment that had direct control over cost and scheduling of the con-
struction activity, but also, were involved in reviewing the design
documents and supervising the system installations.
Since no resolu-
tion was reached during the conference telephone conversations, a
-management meeting was planned for January 18, 1980 at the site.
7.
Followup Program Inspection
On January 17, 1980, the inspector reviewed the revised CG&E HJK
work procedures relative to the pipe suspension system site quality
control inspection measures and determined that there were no notice-
able changes or improvements in the overall program except some
clarification was made on HJK field engineer responsiblities, and
HJK QA surveillance sampling inspection requirements. The procedures
reviewed included:
CG&E Mechanical Construction Test Procedure No. MC-5, " Pipe
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Support Final Inspection", Revision 3, dated January 16, 1980.
HJK Field Construction Procedure No. 2-135, " Process Pipe
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Support Installation After S&L Final Design Analysis", Revision
5, dated January 14, 1980.
HJK Quality Assurance - Construction Methods Instruction No.
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M-12, " Inspection Instruction for Pipe Hangers, Support, and
Restraint Installation", Revision 3, dated January 17, 1980.
8.
Summary of the Meeting
The management and staff of the NRC, CG&E, and HJK held a meeting
at the site on January 18, 1980, to discuss the pipe suspension
program adequacy. The proposed program presented by the licensee
included:
Pipe suspension systems will be installed by HJK construction
a.
personnel.
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b.
HJK QA will perform inspections during installation and will
document any problems identified in nonconformance reports
(NR's). The' inspection will include (1) 100% installation
verification of welding, and anchor bolts, and (2) 10% in-
spection of hanger and restraint system installations relative
to configuration and location.
Inspection would increase if
problems were identified.
c.
HJK field engineers will review design drawings and check
conditions prior to installation. Design Document Changes
(DDC's) will be prepared if design implementation was im-
possible, or difficult. Verification will be made after
installation.
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d.
CG & E General Construction Department (GCD) field engineers,
(called Support Group) will inspect hanger and restraint con-
figuration and location during installations.
NR's will be
prepared if problems are identified.
CG & E QA will perform audits on CG & E GCD performance.
e.
f.
HJK QA will perform audits on HJK engineering, construction,
and inspection performance.
In conclusion the NRC staff stated:
Measures provided in items a, c, e, and f were considered to
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be acceptable.
.In regard to item b,100% QC inspection on hanger and restraint
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configuration and location should be performed by an organiza-
tion that is independant of construction procedures including
the detail checklists.
In regard to item d,'the GCD Support Group can not perform QC
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inspection of hanger configuration and location inspection since
GCD is assigned the responsibility for construction scheduling-
and costs. The 200 plus safety related essential supports
inspected by the GCD Support Group are considered unacceptable
based on the above reason, the fact that the HJK QA procedure
had not been used, and'that there was no documentation to show
the depth and the detail of the inspection performed.
The licensee will inform Region III of their corrective measures
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for the items discussed'during the meeting within two weeks
including, (1) time period established for QC inspection after
hanger installation, (2) QC inspection documentation, and (3)
establishment of independance for the QC inspection personnel
away from engineering,~ supervising, cost control,'and scheduling
activities.
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7.
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, Exit Interview.
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- The inspector met with licensee representatives (denoted in the Person
Contacted paragraph) at the conclusion of the inspection on December-28,
.1979. The inspector summarized the purpose-and findings of the inspection.
' The licensee acknowledged the findings reported herein.
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