ML19350C852
| ML19350C852 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 03/02/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19350C851 | List: |
| References | |
| 50-358-80-25, NUDOCS 8104060847 | |
| Download: ML19350C852 (8) | |
Text
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9 Appendix A NOTICE OF VIOLATION Cincinnati Gas and Electric Company Docket No. 50-358 As a result of the inspection conducted on December 2-3, and 16, 1980, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violations were identified:
1.
10 CFR 50, Appendix B, Crit.-ion III, states that, " Measures shall be established to assure that applicable... design basis...for those structures, systems, and components..are correctly translated into specifications, drawings, procedures, and instructions" The Cincinnati Gas and Electric Company, Final Safety Analysis Report, Section 17.2.3, Revision 15, dated August 1976, states that, "The use of the proceb res by CG&E personnel and/or their contractors or consultants ensures that applicable regulatory requirements, design bases, and appropriate quality standards are correctly translated into design docu-ments such as specifications, drawings, written procedures and instructions, and deviations and changes from such standards are controlled", and
" Procedures controlling design also establish criteria for the proper selection and accomplishment of design verification or checking methods such as design reviews, alternate calculations, and/or qualification testing".
The Cincinnati Gas and Electric Company, Quality Assurance Division, "W. H. Zimmer Nuclear Power Station Quality Assurance Manual", dated October 31, 1980, Section 3, states that "It is the responsibility of the designers to incorporate the design principles into applicable appropriate documents which are in accordance with the regulatory criteria, applicable operating experience, codes and standards", and
" Specifications ce prepared by the designers, which clearly translate the design principles into documents which describe acceptable structures, systems, and components."
Contrary to the above, the Sargent and Lundy Engineers (S&L) Specifica-tion H-2832 did not provide (1) necessary design and acceptance criteria far,eismic and other transient event conditions, (2) design methods to be used for combining loads and (3) the design interface for auxiliary j
steel and main structure.
This is a Severity Level IV violation (Supplement II).
Appendix A
- 2.
'10 CFR 50, Appendix B, Criterion II, states that, "The applicant shall establish at the earliest practicable time consistent with the schedule for accomplishing the activities, a quality assurance program.." and Criterion I, states that, "The applicant may delegate to others, such as contractors,
....the work of establishing and executing the quality assurance program..., but shall retain responsibility therefore"
.The Cincinnati Gas and Electric Company, Final Safety Analysis Report, Section 17.2.2, Revision 15, dated Augus.t 1976, states that, "The QA program for station operation recognizes that QA involves many organ-izations and individuals and is therefore not regarded as the sole responsibility of a single QA group.
The QA program extends to various levels in all participating organizations, from the company president to all workers whose activities may affect or influence quality.
The QA program shall apply to all activities affecting the safety related functions.of~ structures, systems, and components. These activities include design changes, purchasing, fabricating, handling, shipping, storing, cleaning,. erecting, installing, inspecting, testing, operating, maintain'ing, repairing, refueling, and modifying".
The Cincinnati Gas and-Electric Company, Quality Assurance Division, "W. H.'Zimmer Nuclear Power Station Quality Assurance Manual", dated October 31, 1980, Section 2, states that " Quality Assurance control is exercised over activities affecting the quality of essential structures, systems, and components. Control is exerciseu by:
(a) review of pro-curement documents and revisions, and (b) review of vendors' QC programs and revisions".
Contrary to the above, the RCI QA manuai did not identify and describe organizational. interfaces and personnel authorities and responsibilities.
- This'is a Severity Level IV violation (Supplement II).
- 3.
10.CFR 50,' Appendix B, Criterion V, states that, " Activities-affecting quality.shall be prescribed by documented instructions, procedures, or
- drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings" Cincinnati Gas and. Electric Company, Final Safety Analysis Report, Section
'17.2.5, Revision 15, dated August 1976, states that, " Activities affecting
.the quality of the. operation of the station shall be performed in accordance with written instructions, procedures', and drawings. These ' documents pre-scribe' acceptable methods for implementing these activities and refer to appropriate-inspections and tests. Acceptance criteria shall be established
- which are the basis for assuring that the performance of-the~ activities is in'accordance with:the instructions, procedures, and drawings.which are
? applicable to the activity".
Appendix A The Cincinnati Gas and Electric Company, Quality Assurance Division.
"W. H. Zimmer Nuclear Power Station Quality Assurance Manual", da '_ed October 31, 1980, Section 5, states that, " Construction, fabricatien.
and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures.
and drawings which prescribe acceptable methods of carrying out those activities", and "The written instructions, procedures, and drawings include acceptance criteria which comply with the requirements of the design documents and applicable codes and standards. The performance of quality and design activities are verified against these acceptance criteria".
Contrary to the above, there were incomplete procedures, instructions, and drawings for installing the CRD suspension system.
This is a Severity Level IV violation (Supplement II).
4.
10 CFR 50, Appendix B, Criterion X, states that, "A program for inspection of -activities af fecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity".
The Cincinnati Gas and Electric Company, Final Safety Analysis Report, Section 17.2.10, Revision 15, dated August 1976, states that, "Inspec-tions, examinations, measurements, or tests of material, products, or activities shall be performed -for each work operation where necessary to ensure quality. The procedures snall identify the method and extent of inspections and should be commensurate with the importance of the activity to plant safety and reliability".
The Cincinnati Gas and Electric Company, Qual ~ity Assurance Division, "W. 'H. Zimmer Nuclear Power Station Quality Assurance Manual", dated October 31, 1980, Section 10, states that, " Inspection and tests are performed in accordance with written procedures which include require-ments for checklists and other appropriate documentation of the inspections and tests' performed. QAD audits the documentation of inspections and tests to assure that established procedures are followed and test requirements are met".
Contrary to the above, the RCI QC procedures did not specify 100%
inspection of concrate anchor bolts, and QC records did not verify the-installation met suspension system procedure requirements. The
~ inadequate QC inspection of safety related suspension systems was a previous noncompliance; however, the licensee's corrective action e
was not extended to the CRD system.
This is a Severity Level IV' violation (Supplement II).
t
~n-.
- i Appendix A 5.
10 CFR 50, Appendix B, Criterion IX, states that, " Measures shall be estabil-bed to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and acco=plished by qualified personnel using qualified procedares in accordance with applicable codes, standards, specificat.ons, criteria, and other special requirements".
The Cincinnati Gas and Electric Company, Final Safety laalysis Report, Section 17.2.9, Revision 15, dated August 1976, states L.7at, "The QA program for station operation requires that special processes that affect the quality of essential structures, systems, and components be qualified and controlled in accordance with written procedures", and
" Written procedures are prepared and authorized under the supervision of the station superintendent. These procedures ensure that special processes such as welding, heat treating, and nondestructive testing and, cleaning are appropriately controlled.
Imp?amentation of these procedures ilso ensures that the process is qualified to written process sheets, procedures, and' checklists prepared in accordance with applic-able codes, standards, and specifications".
'The Cincinnati Gas and Electric Company, Quality Assurance Division, "W.-' Ai Zimmer Nuclear Power Station Quality Assurance Manual", dated 10ctober 31, 1980,_Section 9, states that " Procedures for special 1 processes such as forming, bending, welding, heat treating or non-
~ destructive examination are reviewed by S&L.
In accordance with project specification requirements, these procedures must De submitted t'o S&L and;accepte'd prior to start _ of component fabrication".
'Contraryfto'the above, there was no authorized ASr2 code welding-procedure specification ard procedure qualification records for
,the material. involved-ir
, fabrication of supports and restraints using;Unistrut P-1000.
This is a Severity Level: IV viol'ation (Supplement II).
.6..
210 CFR 50,' Appendix B,. Criterion XVIII, states that, "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 idetermine. the effectiveness of the, program";
f!(
.Tse C'incinnati Gas and Electric Company,LFinal Safety Analysis Report, L
lSection 17.2.18, Revision.15, dated August'1976,' states that, "A compre-t hensiveL system 'of-planned >and pe-iodic audits shall be carried out to
~
~
tverify. compliance with all aspects ofLthe.QA program'and the c'ontrolling
- administrative procedures. Auditsfof selected aspects of operating phase activities'sh'alli be performed with. a frequency commensurate with their
- safety significance and inesuchra1 manner _as to ensure that an audit of-allisafety related activities ~is completed within a 2-year period".
.' [
1 V'
Appeadix A TLe Cincinnati Gas and Electric Company, Quality Assurance Division, "W. ?!; Zimmer Nuclear Fower Station Quality Assurance Manual", dated October 31, 1980, Section 7, states that, "The effectiveness cf the
- control of quality by vendors is evaluated through a program of planned 4'
audits. Audits are conducted by QA personnel or by QA consultants.
The services of outside consultants and/or testing organizations may be engaged for assistance in conducting audits, at the discretion of the QA Sivision. Audits of major contractors and suppliers are con-ducted at intervals commensurate with the importance and complexity of.the item".
Contrary to the above, the licensee's system of audits of RCI in the area of CR3 suspension systems was not considered adequate tor the following reasons:
a.
There were no licensee audits of the RCI CRD design activities at the RCI corporate office.
b.
TherewerenolicenseeaudEtsoftheRCIsuspens*onsystem installation activities at the site.
There was an apparent lack of specific.CG&E program requirements c.
to perform-program 7.udits at the RCI of fice after contract award.
This-is a Severity Level V violation (Supplement II).
lb 10 CFR'50, Appendix B,-Criterion;XVI, states that, " Measures shall be established.to assure that. conditions adverse to quality, such as
- failure, malfunctions, deficiencies, deviations, defective material fand eqaipment, and nonconformances are promptly. identified and corrected.
In the caseLof significant conditions adverse to quality, the measures 3
i shall assure that the cause of the condition is determined and co'rrective action-taken to preclude repetition. The identification of-the signifi-cant condition adverseLto quality,.the cause'of the condition, and the corrective action 1taken shall be documented and reported to appropriate
- levels _of management".
The: Cincinnati _' Gas and Electric. Company, Final Safety Analysis Repert,
'Section 17.2.16, Revision 15,. dated August 1976, states that, "The QA program.shall~ provide measures to ensure that conditions adverse to plant safety including items such as failures or. malfunctions, deficiencies, E
- . deviations, defective material. and equipment, abnormal occurrences, and -
~
- y
- .nonconforr ;nces' are promptly identified and corrected. 'In the case of significant-conditions adverse'to' safety, the procedures shall: ensure-
- that the cause of (the condition is determined
- and corrective action' taken
+
lis" documented and= reported to appropriateLlevels'~of management",.and.
" Vendors; contractors,.and' suppliers are:made responsible for determining
~ ~and documenting thcicsuse of adverse. conditions ^affecting -their scopelof
~
. supply,Jtaking. corrective action'to remedy the cause, and do'cumenting the-
' action'taken".'
+
4
Appendix A The Lincinnati Gas and Electric Company, Quality Assurance Division, x
"W. H. Zimmer Nuclear Power Station Quality Assurance Manual", dated October 31, 1980, Section 16, states that, "The QA Engineers at the construction site are responsible for performing scheduled audits of the contractor's.and other site contractors' quality assurance programs.
Significant conditions adverse to quality are reported to CG&E management and to appropriate levels of the contractor's management.
Corrective action is obtained and verified where required. The QA Division of CG&E is responsible for evaluating QA program deficiencies identified by project participants. Audits shall be reviewed to assist in identifying QA non-conformances. The corrective action required to eliminate the deficiencies, assurance that corrective action'is taken and appropriately documented, and reporting such deficiencies and corrective actions to appropriate levels of. management is the responsibility of QA. Venders, contractors, and sub-contractors are required to determine cause and corrective action to prevent recurrence of errors which could result in significant conditions adverse to quality".
. Contrary to the above, in view of the continued occurrence of safety related suspension design and installation problems, and recurrence of the-same problems, the licensee's established corrective action measures are. considered to be insufficient and ineffective.
This'is a Severity Level IV violation (Supplement II).
I 8.
~10_CFR'50, Appendix B, Criterion V, states that, " Activities affecting quality _shall be prescribed byl documented instructions,. procedures, or drawings....and shal1~be accomplished in accordance with these instruc-tions, procedures,.or drawings".
~
1The Cincinnati Gas and Electric Company,-Final Safety Analysis Report, Sec' ion 117.2.5, Revision 15,1 dated-August l1976,' states that, " Activities affecting.the ~ quality;of L the operation of the station shall be performed
.in accorda'nce with written;1nstructions, procedures, and drawings. These documents prescribe acceptable methods'for implementing:these. activities and refer to appropriate inspections and tests. Acceptance _ criteria shall
-be. established which-arefthe basis for.' assuring that the performance of 1* :
'the activities is in accordance.with the instructions, procedures, and drawings which: are applicable to' the-activity".
The Cincinnati Gas-and ".lectric Company, Quality Assurance Division, "WJ H. Zimmer Nuclear Power: Station, Quality. Assurance Manual", dated.
' October 31,;1980, iSection-15, states that'"The-disposition of noncon-
' forming-itemslis based'on an authoritative. review of Nonconformance.
- Reports,. resulting 'in ' a decision to Accept-As-Is, Reject, Repair, or -
Rework the1 item 11n' question. Participation;in the review includes
. representatives of CG&E, HJK,land S&L, as appropriate".
w M
4 Y
L s
Appendix A Contrary to the above, the voiding of NRs by the HJK QC Manager was not in accordance with the HJK QCMI G-4, Revision 7, paragraph 3.6, which states that NRs can be voided only under conditions where the NRs "were initiated in error, duplicated, or the nonconforming condition has been corrected...by construction".
This is a Severity Level V violation (Supplement II).
- 9.
10 CFR 50, Appendix B, Criterion XV, states that, " Measures shall be
. established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notifi-cation to affected organizations".
The Cincinnati. Gas and Electric Company, Final Safety Analysis Report, Section 17.2.15, Revision 15, dated August 1976, states that, "The QA program-establishes measures to control materials, parts, components, services, or activities which do not conform to requirements of appropriate documents. Written administrative and quality assurance procedures shall control the identification, documentation, segregation, review, disposition, and notification to affected organizations. These measures ensure that CG&E's suppliers / contractors are responsible for establishing procedures:for controlling nonconforming items at their respective facilities to preclude shipment of deficient items to ZPS-1.
Nonconformance reports dispositioned " accept as is", repair, or rework, are made.part of the inspection records and forwarded with the hardware to the utility.
Items received, inspected, and accepted at the site are then subject 'to similar. nonconformance controls and appropriate controlled
' disposition".
The Cincinnati. Gas and Electric Company, Quality Assurance Division, "W.'H.1Zimmer Nuclear Power Station Quality Asrurance Manual", dated October 31, 1980, Section 15, states that, "PJK is responsible for
~
identifying and reporting noncotformances ir receiving inspection, construction,--or testing; activities which are delegated to HJK", and "HJK. inspectors or Quality Assurance engineers prepare a Nonconformance Report'whenever.a condition is identified which represents a deviation
~from drawings, specifications,: procedures, 'or work instructions. HJK Construction Engineering -provides the disposition ~ for ~the nonconformance, and-the:NR.isfprocessed in accordance with QA Procedure 15-QAS-01".
Contrary to the1above~,'the. voiding of NRs by' issuing DDCs is not in accordance,with HJK procedural-requirements, and;is a repeat of a similar noncompliance identified in RIII Report No. 50-358/80-05.
This'isJa Severity Level IV violation ~(Supple' ment II).
~
)
Appendix A Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written st tement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved.
L'nder the autitority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall te submitted under oath or affirmation.
3.
,9 5l Ch,,... A A'. fm.
Date J}_.cci f/ames G. Keppleil
~
Director