ML19338G350

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IE Insp Rept 50-358/80-16 on 800715-17 & 0814-15. Noncompliance Noted:Failure to Document Reorganization of Site Qa/Qc Operations
ML19338G350
Person / Time
Site: Zimmer
Issue date: 08/27/1980
From: Danielson D, Yin I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19338G342 List:
References
50-358-80-16, NUDOCS 8010290124
Download: ML19338G350 (5)


See also: IR 05000358/1980016

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U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

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REGION III

Report No. 50-358/80-16

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Docket No. 50-358

License No. CPPR-88

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Licensee:

Cincinnati Gas and Electric Company

139 East 4th Street

Cincinnati, OH 45201

Facility Name:

Wm. H. Zimmer Power Station

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Inspection At: Zimmer Site, Moscow, OH

Licensee Corporate Office, Cincinnati, OH

Inspection Conducted: July 15-17, and August 14, 1980 at the Site

Au6ust 15, 1980 at the Corporate Office

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Inspector:

I. T. Yin

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Accompanying Personnel:

G. Fiore11i

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(August 15, 1980 only)

R. C. Knop

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P. Barrett

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F. T. Daniels

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Approved By:

D. H. Danielson, Chief

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Engineering Support Section 2

Inspection Summary

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Inspection on July 15-17, and August 14-15, 1980 (Report No. 50-358/80-16)

Areas Inspected:

Inspection of safety related hanger, restraint, and

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snubber site construction program. The inspection involved a total of 26

inspector-hours onsite by one NRC inspector.

Results:

In the two a'reas inspected, one apparent item of noncompliance

was identified in one area (infraction - failure to document reorganization

of site QA/QC operations

paragraph 2).

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DETAILS

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Persons Contacted

Cincinnati Gas and Electric Company (CG&E)

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  • E. A. Borgmann, Senior Vice President
  • B. K. Culver, Manager of Construction
  • W. W. Schwiers, Manager of QA

R. P. Ehas, Senior QA Engineer

J. F. Weissenberg, QA Engineer

J. B. Vorderbrueggen, Construction Engineer

D. Fox, Quality Engineer

S. C. Swain, Construction Engineer

E. M. Schroeder, Quality Engineer

Henry J. Kaiser Company (HJK)

R. Marshall, Construction Manager

  • E. V. Knox, Corporate QA Manager

P. S. Gittings, Site QC Manager

R. E. Baker, Inspection Supervisor

W. O. Puckett, Welding Engineer

T. Smith, Lead Hanger Inspector

D. M. Feltner, Construction Engineer

R. Cranston, Construction Superintendent

USNRC-RIII

  • G.

Fiorelli, Branch Chief

  • R.

C. Knop, Section Chief

  • P.

Barrett, Project Inspector

  • F. T. Daniels, Senior Resident Inspector
  • I. T. Yin, Reactor Inspector
  • Denotes those attending the management exit interview on August 15, 1980

at the conclusion of the inspection.

Functional or Program Areas Inspected

1.

Status of RIII Identified Items

Items of noncompliance and unresolved matters relative to large bore

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pipe suspension systems that were not installed in accordance with

the design drawings, specifications, support component assembly designs,

and were without backup calculations were identified during RIII site

inspection in 1978.

Since then, extensive efforts to correct the problem

have been initiated and implemented in the A-E's office, and at the site.

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However, the exact status and effectiveness of the program were not

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formally assessed and documented by the licensee. At the inspector's

request, the licensee agreed to conduct a comprehensive audit of all

aspects of large bore suspension system activities, in particular (1)

present design control status, (2) effectiveness of interfaces between

organizations, (3) construction and QA/QC work status and work plans,

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and (4) expected completion dates for each of the implementation work

functions. The results are to be presented to RIII either orally or

in writing by the end of 1980.

2.

Site QA/QC Re-Organization

The licensee's decision to reorganize site QA/QC and place HJK QA and

QC personnel directly under the management of CG&E site QA organization

was made in early 1980, and placed in effect in June, 1980. During

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this site visit, the inspector determined that the FSAR, QA manuals,

and other applicable implementing work procedures had not been revised

to reflect these changes. The personnel job function, interface, and

reporting channels had not been formally defined. Furthermore, in

discussion with the QA management of CG&E and HJK on August 14, 1980,

it was noted that the HJK site QC manager was not in concurrence with

working in accordance with the new CG&E policies and reporting directly

to the CG&E site QA administration.

The lack of documentation and implementation of site QA/QC reorganiza-

tion is considered an item of noncompliance as stated in Appendix A

(358/80-16-01).

3.

Procedure Review

During the July 15-17, 1980 site visit, the inspector commented that

the QC hanger inspection procedure was deficient. On August 14, 1980,

the inspector reviewed the revised HJK, QACML, M-12, Revision 9, dated

August 4, 1980, " Inspection Instructions for Pipe Hanger, Support, ar i

Restraint Installation" and HJK FCP 2-135, Revision 9, dated July 17,

1980, " Process Pipe Support Installation After S&L Final Design Analysis

and NX Instrumentation Pipe Support Installation Criteria", and noted

the following areas should be addressed:

a.

Measures should be established for the inspection of different

categories of hanger installations, such as (1) as-found, no

change, (2) new installation, (3) modification performed, and

(4) delete, not required,

b.

The time allowed from installation completion to project checking,

to QC inspection should be specified.

c.

The time allowed for a QC inspector or engineering staff person

to write an NR

after nonconformances had been identified should

be specified.

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The above items are considered unresolved (358/80-16-02).

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4.

Personnel Qualifications

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On July 15, 1980, the inspector noticed that the licensee's recent

inspection of the Diesel generator areas had rejected all 22 previously

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QC inspected and accepted hanger installations, including welding of

structural members.

In discussion with the HJK QC staff, it was

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apparent that site practices for welder qualification control were

questionable in that:

(1) the procedure did not provide sufficient

QA/QC verification, (2) the identifi ation of test coupon: was question-

able, (3) there was an apparent lack of control in the test booth,

i.e., unauthorized personnel could be in the booth areas while test

coupons were being welded, and (4) there was an apparent lack of CG&E

or HJK observation and monitoring of test performance. The inspector

expressed the following concerns and requested immediate corrective

actions be initiated.

a.

Although the licensee is in the process of re-inspecting 100% of

all previously installed and inspected hanger installations, the

measures to control welder and QC inspection qualification needs

improvement.

In regard to the welder qualification control, the

HJK SPPM No. 3.2 was revised on July 21, 1980, Revision 4,

" Welder Performance Qualification Testing - General". The RIII

welding specialist inspected the implementation of this revised

procedure and considered the welding test area control, component

control, and contractor surveillance to be acceptable.

(Reference

RIII Report No. 50-385/80-20)

b.

In regard to the present welder and QC personnel qualifications,

the inspector requested licensee QA audits to be performed in

these areas.

On August 14, 1980, the inspector reviewed the

following field audit reports (FAR):

CG&E Field Audit Report No. 318, "QC Inspector Qualification and

Certification". Audit performed on July 24-28, 1980.

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CG&E Field Audit Report No. 319, " Welder Performance Qualification

as it Relates to Pipe Supports". Audit performed on July 24-29,

and August 6-7, 1980.

The inspector had no adverse comments on FAR No. 318. Relative to

FAR No. 319, 30 new welders were tested per SPPM 3.2, Revision 4,

requirements between the period of July 23, 1980, and August 6, 1980,

among which 17 were rejected. The inspector requested selective

sample testing of previously qualified welders to the requirements of

SPPM 3.2, Revision 4.~

The licensee agreed to the request and stated

he will document any problems identified during the requalifying test

program. This is considered an unresolved item (358/80-16-03).

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5.

CC&E Immediate Action Directives (IAD's)

It was brought to the inspector's attention by the Senior Resident

Inspector that CG&E's site QA recently issued IAD, No. 80-01, dated

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July 15, 1980.

Issue of this IAD was contrary to the FSAR and the

licensee's response to RIII noncompliance item commitments relative

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to the QA review of DDC's.

While the IAD was subsequently' cancelled

and corrections implemented, the inspector after review of the CG&E

QA and S Procedure 05-QAS-05, Revision 0, dated July 1, 1980, "IAD's",

stated that (1) the receipt acknowledge requirement was contrary to

Paragraph 6.7.1 of the Procedure 05-QAS-01, Revision 1, dated May 27,

1980, " Preparation, Approval, Control and Distribution of QA and S

Procedures", (2) there is a lack of requirements on how to file the

IAD's with the affected work procedures, and (3) there is a lack of

instruction on how to handle voided IAD's and the replacement of the

revised procedures. This is an unresolved item (358/80-16-04).

Unresolved 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. Three unresolved items disclosed during this inspection

are discussed in Paragraphs 3, 4.c, and 5.

Exit Interview

The RIII management and the responsible inspector met with the licensee

representatives (denoted under Persons Contacted) at the conclusion of the

inspection on August 15, 1980. The inspector summarized the purpose and

findings of the inspection. The licensee acknowledged the findings reported

herein.

Based on previous experiences with piping support system problems the

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following matters were stressed to the licensee (a) proper documentation of

responsibilities, (b) timely inspection of work (c) timely recording of

deviations (d) appropriate conformation of welder qualifications and

(e) proper use of IAD's.

Following discussicns on the merits of the

effort, the licensee will undertake a comprehensive audit to reconfirm

large bore piping has been installed in accordance with specifications.

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