ML19350C855
| ML19350C855 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 02/19/1981 |
| From: | Danielson D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19350C851 | List: |
| References | |
| 50-358-80-25, NUDOCS 8104060857 | |
| Download: ML19350C855 (7) | |
See also: IR 05000358/1980025
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U.S. hTCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/80-25
Docket No. 50-358
License No. CPPR-88
Licensee:
Cincinnati Gas and Electric Company
139 East 4th Street
Cincinnati, OH 45201
Facility Name:
Vm. H. Zimmer Power Stacion
Inspection At:
Zimmer Site, Moscow, OH
Licensee Corporate Office, Cincinnati, OH
Inspection Conducted: December 2-3, 1980 at the Site
December 16, 1980 at the Corporate Of fice
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Inspector:
I. T. Yin
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Accompanying Personnel:
R. C. Knop
F. T. Daniels (December 16, 1980 only)
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b1ff,Danielson, Chief
D. H.
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Approved By:
Engineering Support Section 2
Inspection Summary
Inspection on December 2-3 and 16, 1980 (Report No. 50-358/80-25)
Areas Inspected: Safety related suspension system design and construction
program established by RCI; licensee control of nonconformances. The inspecti a
2nvolved a total of 20 inspector-hours onsite by one NRC inspector.
Results: Of the areas inspected, nine apparent violations were identified.
(Failure to establish all applicable design basis in the CRD suspension system
specification - Paragraph 1.a; Failure to identify and describe the RCI organ-
izational interfaces and personnel authorities and responsibilities - Paragraph
1.b; Failure to establish adequate procedures, instructions, and drawings for
design and iastallation of the CRD suspension system - Paragraph 1.d; Failure to
establish ASME Code qualification documentacion for Unistrut P-1000 - Paragraph
1.e; Failure to conduct comprehensive audits of RCI activities - Paragraph 2;
Failure to establish effective corrective actide-for recurring suspension system
. design and installation problems- Paragraph 3; railure to follow procedures
for the voiding of nonconformance reports - Paragraph 4.a; Failure to adequately
control nonconforming conditions - Paragraph 4.b.)
8164 0$0 S$"[
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DETAILS
Persons Contacted
-Cincit.nati' Gas and Electric Company (CG&E).
(*E.EA.'Edrgmann, Senior'Vice President
-*B. K. Culver, Manager of Construction
..*W. W. Schwiers, Manager of QA
JJ. F. Weissenberg, QA Engineer
.R..P. Ehas,. Senior QA Engineer
'J. B. Vorderb2ueggen, Construction Engineer
..
Henry'J. Kaiser Company-(HJK)'
R. Marshall, Construction Manager
.P. S. Gittings, Site QC. Manager
R..E., Baker,L nspection Supervisor
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D. Painte, Lead Hanger. Inspector
USNRC-RIII
- R._C'.; Knop, Section Chief
'*F.;T2;Daniels, Senior Resident Inspector
- I. T; Yin,' Reactor Inspector.
- Denotes those attendingLthe management exit-interview on December 16,-
c1980- at , the conclusion. of- the: inspection'.
,
Functional or Program' Areas = Inspected
1.
RCI~ Program 1for Design.and Installation of CRD System' Supports
RCI1 work'-has"been completed and RCI: personnel departed the site by.
July!1979.
The inspector,revi6wed'the; existing RCI documents including:
.
RCI1QA Manual, Revision.4,' dated' November 21', 1977..
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S&L"Spe'cification'H-2832,'" Specification for Installation of Reactor
.
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LPressure Vessel: Internals.and Control Rod Drive' Hydraulic System",
Edated~ December 20,:1973.
- RCI .jstraint'Insta11ation Procedure,-RIP-1, dated April'.15,11976.
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Miscellaneous; installation and: inspection; records.
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cisia'iresult-of'a review ofitheiabove RCI documents and discussions with.
.
- they.CG&ELQA personnel,.the4 inspector determined
- theilicensee's control'
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over the RCI design and installation of the CRD suspension systems did
not meet the CG&E FSAR commitments. This was based on:
The S&L Specification H-2832 did not provide (1) necessa- design
- a.
and acceptance criteria for seismic and other transient 2 vent condi-
tions, such as number of vibration modes, effects of nydrodynamic
loads, primary and secondary code stress acceptance levels, (2)
design methods to be used for combining loads, and (3) the design
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interface for aaxiliary steel and main structures.
This is con-
sidered an item of noncompliance. (358/80-25-01)
b.
The RCI QA Manual did not identify and describe organizational
interfaces and personnel authorities and responsibilities.
Based
on a review of CG&E audits of RCI from 1975 and 1979 there was a
lack of a contractor QA program evaluation by the licensee. This
is considered an item of noncompliance.
(358/80-25-02)
c.
There were ince.aplete procedures, instructions, and drawings for
in' stalling the CRD suspension system. The inspector noted that the
available procedures and drawings were very sketchy and did not
include, among others, instro tions for (1) installation of concrete
anchor bolts, (2) torquing of fasteners, and (3) installation and
configuration tolerances. This is considered an item of noncompliance.
(358/80-25-03)
d.
In: reviewing RCI drawings, such as ZM-2009-18, only 50% of the concrete
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expansion anchor bolts had been checked for proper torqueing.
The
licensee committed to perform ~ 100% inspection on all safety related
suspension-systems,' including concrete expansion bolts (See Reg'on III
. Report No. 50-358/80-05). The:requirment for 100% inspection of the
l hanger. work is included in H. J. Kaiser'QACHI M-15, " Concrete Expsn-
sion Anchor Post - Installation Procedure" and QACMI M-12 hinger in-
spection requirements. The records did not verify, among others,
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-torquing of fasteners and installation configuration toleranc s.
The
inadequate QC. inspection of safety related suspension systems aas a
' noncompliance identified during an August l1978 inspection by the RIII
- inspector,'however,' the licensee's corrective action was not extended
u;
to'the CRD system. This'is considered an item of noncompliance.
-(358/80-25-04)
'"
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Je.
There was no authorized ADME Code welding procedure specification and
orocedure? qualification records for the materials involved in the
fabrication of suppo'rts and restraints using Unistrut P-1000, an ASME
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Code Case 1644-8 material. This is considered;an item of noncompliance.
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. c(358/80-25-05).
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2.
Licensee Auojir of RCI Activities
The_following CG&E audit reports were presented to the inspector for his
review.
These were the only audits conducted and none of these involved
RCI CRD safety related suspension system design and field installation.
CG&E Field Audit Report (FAR) No. 55 of RCI on September 17, 1975.
Audit
areas included welding control.
CG&E FAR No. 66 of RCI on June 3, 1976. Audit areas included nonconform-
ance control.
CG&E FAR No. 107 of RCI on April 12, 1977. Audit areas included general
QA program implementation of welding and NDE.
CG&E FAR No. 200 of RCI on October 10, 1978. Audit areas included
contractor compliance of ANSI N45.2.6 requirements.
CG&E'FAR No. 222 of RCI on February 20, 1979. Audit areas included
_
. elding proc-dure qualifications.
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CG&E Audit Report No. 77/20 of RCI, Waterford, Connecticut on May 24,
1977. Audit areas. included CRD pipe fabrication.
-The -licensee's system.of audits of RCI in the area.of CRD hanger systems
was not considered adequate for the following reasons:
a.
There were'no licensee audits of RCI CRD design activities at the
RCI corporate office,
b.
There were no licensee audits of RCl suspension system installation
activities atithe site.
2-.
- c.
There was an apparent lack of specific CG&E program requirement;
. to perform program audits.at the RCI office after contract award .
Subsequent to the inspection,the CG&E.QA Manager issued a Stop Work
l Order.(SWO),-No. 80-14,_ dated December 9, 1980
< hic'
tated " Effective
immediatsly,= activities-by Reactor Controls Inc. associated with the
Wm. H. Zimmer Nuclear Power-Station shall be discontinued", and "This.
.stop work'orderiwill be: rescinded:following acceptance of'RCI-QA Prograr
and Procedures,~and.successfulicompletion of an audit'to evaluate'QA
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' Program implementation". 'The reason given forJissuing'the SWO was "The
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- current status lof RCI- QA Program implementation is judged to be indeter-
Jainate"..
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- An Immediate Action Letter was sent to the.1'icensee on December 24, 1980,.
confirming' the : step work and requiring NRC review prior roithe lif ting of
Lthe'stop' work.
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The failure of the licensee to conduct comprehensive audits to determine
the effectiveness of the RCI QA program is considered an item of noncom-
pliance. (358/80-25-06)
3.
Liceasee Corrective Action
The liceo.ee corrective action for identified suspension system installa-
tion problems had not been effective.
This cetermination was based on:
.a.
Licensee hanger and concrete expansion type anchor bolt installation
program deficiencies were first identified in August 1978. Findings
were documented in RIII Inspection Report No. 50-358/78-18.
To the
date of inspection, after more than 90% of the safety related sus-
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pension system components had been installed (more than 50% required
simple modification or extensive rework'. the QC program for the in-
- sta11ation and inspection of the suspension system has not proven to
be effective.
Items b and c below are findings that support the above
conclusions.
- b.
Repeated large bore suspension system construction and design
~ deficiencies were documented in the following RIII Inspection
. Reports:
(1)_ 50-358/78-27:
Inspection performed in November 1978.
'(2) 50-358/78-32: Inspection performed in December 1978.
-(3);-50-358/79-22: -Inspection performed in July 1979.,
.(4)'.50-358/79-37:
Inspection performed in December 1979 and
- January ~1980.
RIII--inspection of safety related'small bore process piping and
c.
" instrumentation piping' suspension system-design ~and installation at
the Zimmer site was conducted during February _ and March 1980. This
inspection' identified problems similar to those previously identified
inLlarge' bore piping systems (See RIII Report No. 50-35S/S0-05).
This clearlyfshows that the. licensee did not take-i~nitiative to improve
and control the ' suspension system design and installation program to
cover all areas of safety related work.
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d .- TThe' apparent lack of licensee review of _ implementing procedures to
ensure that reviaion' of one procedure does not c' nflict with another.
o
and does not' invalidate'the commitments to NRC or the requirements of
other departments vas-discussed during a management meeting at the
~ CG&E- corporatef office on August. 15, 1980. At the_ conclusion of the
_
meeting the Llicensee -indicated that they were aware of the problem,
yet the NRC site inspection conducted on October'1-2, 1980 (RIII.
-Repo'rt No;-50-358/80-22) identified procedural conflicts :and 'defici--
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enciestin Field-Construction Procedures (FCP) 2-115, FCP 2-134, and
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Ouality Assurance and Construction Manual Instruction (QACMI) M-12.
In fact, as of October 1980, the HJK QACMI M-12, " Inspection Instruc-
tions for Pipe Hangers and Installation Supports", Revision 1, dated
February 21, 1979, had been revised nine times and the latest revisicn
was number 10, dated Septe=ber 16, 1980.
Subsequently, the inspector
was told that QACMI was revised again to Revision 11.
The problem was
not corrected as of the inspection on December 16, 1980, where the
latest HJK nonconformance control procedure was found to be in conflict
with the latest CG&E QA procedure.
As a direct result of the RIII inspector's findings, stop work orders
were issued by the licensee in the areas of:
(1) concrete ancnor bolt
installation, (2) mechanical sr"M -
installation, (3) hydraulic snubber
installation, (4) small bore
b= 6er installation, and (5) CRD suspension
system activities.
In addi
.on, a licensee 50.55(e) report was subcitted
to RIII in area of larg_- bore pipe hanger design deficiencies.
In view of the continued occurrence of safety related suspension design
and installation problems, and recurrence of some of the same problems,
the licensee's established corrective action measures are considered to
be insufficient and ineffective. This is considered an item of noncom-
pliance.
(358/80-25-07)
4.
Licensee QC Inspection
There is an apparent lack of QC management control over the implementation
of approved procedures.
During this visit the inspector reviewed approx-
imately twenty QC inspector initiated Nonconformance Reports (NRs) in the
area' of hanger inspection during the period of October and November 1980.
Among these, many AWS welding deficiencies were identified based on the
requirements established in HJK Special Process Procedur: Manual SPPM 4.6,
" Visual Examination", Revision S, dated September 28, 1980. These NRs
were written in accordance with HJK QACMI G-4, "Nonconformance Material
Control", Revision 7, dated April 7, 1980.
In reviewing the NRs, the
inspector noted that the NRs listed below had been voided by the HJK QC
Manager. The reason given was " based on re-inspection", and was not
concurred with-by all four levels of the QC inspection work force,
i.e.,
(1) Quality Control Inspectors, (2) Lead Inspectors, (3) Inspection Super-
visor, and (4) Quality Engineer, who all had signed and approved the
contents and documentation of the NRs.
NR No. E-2796
NR No. E-2851
NR No. E-2852
NR No.'E-2853
NR No..E-2854
NR No. E-2S57
'NR No. E-2861
NR No. E-2865
-The NRs listed below are also incidences_where NRs were voided by initia?.-
ing a Design Document Control (DDC):
NR No. E-2871
NR No. E-2875
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The inspector determined the following:
a.
The voiding of the NRs by the HJK Q; 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 cor-
rected...by construction". This is considered an item of noncompliance.
(358/80-25-u8)
b.
The voiding of an NR by issuing a DDC .is not in accordance with HJK
procedural requirements, and is a repeat of a similar noncompliance
identified in R11I Report No. 50-358/80-05 (inspection conducted in
February and March 1980), paragraph 4.a(2), which stated.
" Generic
problems were identified,
i.e., the common use of DDCs to document
nonconformances instead of using NRs...".
This is considered an item
of noncompliance.
(358/80-25-09)
Subsequent to the inspection, the CG&E QA Manager issued two Stop Work
Orders (SW0s):
.
SWO No. 80-13, dated December 9, 1980 stating. ." Effective
immediately, the voiding of HJK Nonconformance Reports will stop"
The reason given was:
"HJK QA procedure governing the writing and
processing of nonconformance reports does not have sufficient
control to permit a careful review of an established nonconformance
report that is subject to being voided".
SWO No. 80-12, dated December 9, 1980 stating..." Effective
.
immediately, the preparation of DDCs on all pipe supports shall be
stopped". The reason given was:
" Contrary to procedure, DDCs
are being used to request approval for as-built conditions
which deviate from design drawings".
Exit Interview
The inspector met with the licensee representatives (denoted under Persons
Contacted) at the conclusion of the inspection on December 16, 1980. The
inspector summarized the purpose and findings of the inspection. The
licensee acknowledged the findings reported herein.
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