ML20004D332
| ML20004D332 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 05/01/1981 |
| From: | Daniels F, Gwynn T, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20004D330 | List: |
| References | |
| 50-358-81-07, 50-358-81-7, NUDOCS 8106090215 | |
| Download: ML20004D332 (14) | |
See also: IR 05000358/1981007
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U.S. NUCLEAR REGULATORY C viISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/81-07
Docket No. 50-358
License No. CPPR-88
Licensee: Cincinnati Gas & ilectric Company
139 East 4th Street
Cincinnati, OH 45201
Facility Name:
W. H. Zimmer Nuclear Power Station
Inspection At:
W. H. Zimmer, Moscow, OH
Inspection Conducted: March 2-27, 1981
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Inspectors:
. T. Daniels
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Approved By:
R. F. Warnick, Chief
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Reactor Projects Section 2B
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In pection Summary
Inspection on March 2-27, 1981 (Report No. 50-358/81-07)
Areas Inspected: Routine resident inspection of Previously Identified Items,
Preoperational Testing Quality Assurance, Fire Prevention / Protection, Quality
Assurance Program for Test and Measurement Equipment, Preoperational Test
Procedure Review, Preoperational Test Program Implementation and Plant Tours.
This inspaction involved a total of 143 inspector-hours onsite by two NRC
inspectors, including 26 inspector-hours onsite during offshifts.
Results: Of the seven areas inspected, six were found satisfactory and
one item of noncompliance was identified in the area of Preoperational Test
Program Implementation. (Parag raph 7.b. (2) . (a))
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DETAILS
1.
Personnel Contacted
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- J. R. Schott, Station Superiatendent
- P. E. King, Assistant Station Superintendent
- J. J. Wald, Station Quality Engineer
R. E. Donnellon, Maintenance Engineer
D. L. Erickson, Rad Chem Engineer
J. H. Woeste, I&C Engineer
M. B. Hill, Document Supervisor
D. Snider, Maintenance Foreman
G. A. Appel, Station Chemist
D. M. Outcault, Technical Staff Engineer
H. K. Lathrop, System Engineer
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W. W. Schweirs, CG&E QA Manager
S. C. Swain, CG&E Construction Project Manager
J. Bradford, Kaiser Document Control Supervisor
C. Schroeder, Turnover Group Supervisor
Others of the station staff
- Denotes personnel attending monthly exit meeting.
2.
Licensee Action on Previously Identified Items
(Closed) Noncompliance (50-358/80-19-01): Failure to follow SU.ACP.15,
Revision 03 in the tagging of systems turned over for preoperational
testing.
The inspector reviewed procedure SU.PRP.12, Revision 00 which has
replaced SU.ACP.15. The inspector verified that Revision 1 to PT-RH-01
had been promulgated using the appropriate form; that a field check of
the RH system tagging had been completed; and that periodic audits of
jurisdictional tagging on systems turned over for preoperational testing
have been accomplished according to a schedule.
(0 pen) Noncompliance (50-358/80-19-02): Discrepancies in System Releases.
The inspector notes that a cross-check between S&L listings and the
computerized matrix list has not been performed to date. This item remains
open pending completion of this cross-check for all systems important to
safety.
(Closed) Noncompliance (50-358/80-19-03): Discrepancies between valve
list and S&L drawings.
The inspector verified that identified errors have been corrected.
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3.
Preoperational Testing Quality Assurance
The inspector verified that the licensee's program for QA/QC surveillance
and audit of preoperational testing activities has continued to be imple-
mented as describad in previous IE inspection reports (50-358/80-14,
80-21, and 80-20).
In particular, the inspector verified that revisions
made to previously reviewed procedures conform to applicable standards
and regulatory guidance, that selected audits and surveillance ictivities
performed since the last inspection of this area were performed in accord-
ance with approved procedures as designated by surveillance schedules;
and that corrective action required by audit findings was completed in
a timely fashion.
a.
Documentation Reviewed
(1) QA. SAD.06, Nonconformance Reporting, Revision 04.
(2) QD.QAI,01, Review and Inspection of Preoperational Tes
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Revision 02.
(3) QD.QAI.02, Conduct of Station Audits, Revision 05.
(4) CG&E Electrical Production Department (EPD) QA Surveillance
Report SU-39 dated March 20, 1981.
(5) CG&E EPD QA Preoperational Surveillance Report for PO-RD-02
dated March 9, 1981.
(6) CG&E startup Manual, Revision 05 dated July 25, 1979.
(7) QA&S Field Audit Report #341 dated December 23, 1980.
b.
Findings
(1) The CG&E Startup Manual, as referenced in FSAR Section 17.2.2.7,
is prepared to " clearly and specifically identify the activities
that fall within these overlapping time periods (between con-
struction and operation) and to specify authorities and respons-
ibilities for the various construction tests, inspections,
verification, preoperational tests, and startup tests", and
" responsibilities and authorities, QA requirements
...etc.,
shall be detailed in the startup manual."
The inspector noted that several aspects of this manual appear
to be out of date with respect to current organizational structure
and practice at the site (i.e., Sections 4.2.1.2, 4.2.3.13,
4.2.3.14, organization chart, 6.3.2, 6.3.3).
Of particular concern is the revision of implementing procedures
to delete the QA requirements of Section 6.3.2 and 6.3.3 for
preoperational turnover documentation packages.
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This concern was brought to the attention of the CG&E QA Manager
who committed to performing a comprehensive audit similar to that
required by the Startup Manual for preoveracional turnover pack-
ages. This audit was to include a representative sample of both
turned over systems and systems being readied for preoperational
testing turnover, and is to be completed by April 8, 1981. This
item remains unresolved pending the completion and review of that
audit.
(50-358/81-07-01)
4.
Fire Preiention/ Protection
The inspector verified by observation and document review that the fire
protection system had been incorporated in a schedule and was being per-
formed in accordance with that schedule; that sprinkler systems were
located in areas as required by the station technical specifications; that
fire fighting equipment was in place in the control room, cable spreading
room, on the refueling floor, and in selected areas of the auxiliary build-
ing, and had been recently tested; and that the results of fire inspections
performed by the licensee and insurance inspectors were reviewed, and where
inspection findings involved fire hazards in vital areas appropriate cor-
rective action had been taken or planned.
a.
Documentation Reviewed
(1) CG&E Electric Production Department QA Audit FP-TS-02
dated October 1, 1980.
(2) American Nuclear Insurers Loss Prevention Report N-184
dated October 20, 1980.
(3) OP.FPP.27-525 AD, Fire Preplan-Diesel Generator Room A,
revision 01 d ted January 7,1981.
(4) Surveillance results for the following surveillance
procedures:
(a) ME.SFP.721, FP Diesel Weekly Battery Checks
(b) ME.SFP.722, FP Diesel Battery Quarterly Checks
(c) Fire Protection Diesel Fuel Oil Chemistry Checks
for Water and Sediment
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b.
Findings
(1) A walkthrough of OP.FPP.27-525 AB by the inspector revealed
that as installed conditions were not reflected in the fire
preplan for the ' A' Diesel Generator Room.
In particular, the
following comments apply:
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(a) Under the heading LIGHTS, there was no breaker No. 5 in
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RLC-23 and there was no breaker labeled No. 9 in ELC-43.
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(b) Under the heading FIRE SUPPRESSION, there was no dry chemical
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portable extinguisher located in the 'A' Diesel Room.
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(c) On the Diesel Room ' A' floor plan, the following comments
apply:
1.
On the north engine, the AC and DC lube oil pumps were
reversed.
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2.
On both engines, there was no pu.np located as shown
with the title Emergency Turbo-Charger Oil Pump.
3.
On both engines, the Fuel Prime Pump was not located
as shown.
4.
The fire extinquisher located inside the room was
class (BC) only, not class (ABC) as shown.
These findings are similar to those documented in IE Inspection
Report No. 80-21, as unresolved item No. 80-21-01.
This item
remains open and will be followed up in a future inspection.
(2) Required Fire Protection System surveillances were being
performed in a timely manner in accordance with a schedule.
(3) The diesel generator room CARD 0X systems were out of commission.
(4) Inspection of the control room, including the interiors of
selected control panels, revealed the following minor dis-
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crepancies:
(a) A roll of chart recorder paper was found inside panel
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IH13-P610.
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(b) An old cloth was found hanging inside panel IH 13-P654.
Control room operators removed these items as they were
discovered.
5.
QA Program (Test and Measurement Equipment)
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The inspector conducted a review to determine that the licensee had
developed and implemented a QA Program relating to the control of test
and me tsurement equipment that was in conformance with Regulatory
Requirements, commitments in the application, and industry guides and
standards.
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a.
Documentation Reviewed
(4) he
H. Zimmer FSAR, Chapter 17.2.12
(5)
MT. SAD.01, Control of Measuring and Test Equipment,
Revision 05.
(6) MT.RCA.01, Control of Rad / Chem Measuring and Test Equipment,
Revision 00.
(7)
ME. AMP.01, Control and Calibration of Maintenance Group
Reference Standards, Revision 00.
(8)
IM. SAD.01, Instrument and Control Program, Revision 02.
(9)
IC. GIP.G501, Control of Out-of-Calibration Measuring and
Test Equipment, Revision 00.
(10) Maintenance, Instrumentation and Control, and Rad / Chem
Groups listing of secondary and working reference standards.
(11) Maintenance, Instrumentation and Control, and Rad / Chem
Groups reference standards calibration program documents.
(12) CG&E approved vendors list.
b.
Program Review
(1) The inspector verified that established controls for Test and
Measurement (T&M) Equipment his accomplished the following:
(a) Criteria for assignment of the calibration / adjustment
frequency has been established.
(b) A T&M equipment inventory list or equivalent has been
prepared which identifies all T&M equipment which
will be used for any reason on safety-related structures
systems or components; a calibration / adjustment frequency
for each piece of equipment; the calibration standard to
be used for each piece of equipment; and the calibration
procedure.
(c) Formal requirements have been established for marking
the latest inspection / calibration date on each piece
of T&M equipment or otherwise identifying the status.
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(d) A preventative maintenance / surveillance program has
been established which will assure that each piece of
T&M equipment is calibrated and adjusted on the date
required.
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(e) Requirements have been established prohibiting the use
of T&M equipment which has not been calibrated within
prescribed frequency and describes controls to prevent
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inadvertent use of such equipment.
(f) Out-of-calibration controls have been established for .
T&M equipment.
(g) A system has been established to assure that new T&M
equipment will be added to the T&M equipment inventory
list and calibrated pt:ior to being used.
(2) The inspector verified that responsibilities have been
assigned to assure that the T&M equipment controls identi-
fied in the preceding paragraph have been implemented.
c.
Program Implementation
(1) The inspector conducted a review to determine that controls
for the following T&M equipment, as required under Program
Review (Paragraph 5.b), have been properly implemented.
(a) Dial Indicator Tester, A42975, Model 716
(b)
5" Standard Bar, 42976, Serial No. A-42976-5
(c) Rotameter Water, Serial No. 8005H50876
(d) Outside Micrometer, 42974
(e) Fluke Digital Multimeter, Serial No. 2608048
(f) Portable Gas Analyser, Serial No. D7899
(g) SS-3 pH Meter
(h) Teletec 6037
(i) AMS 2, Number 316
(j) PRM-6, Number 331
(k) Penn. Dodge GO-NO-GO Gauge, TGN-328
(1) L&N Precision Resistor, TRP-202
(m) Fluke Calibrator, Model 5100A, TCA-225
(n) Mansfield and Green Pneumatic Tester, TPT-345
(o) W&T Standard Bars, TSB-283
(p) Ashcroft Digi Gauge, TDG-006
(2) The inspector conducted a review to determine that the T&M
equipment listed in paragraph 5.c.(1) were properl' stored,
identified, including calibration status, that there was a
calibration procedure, that there was a schedule and it was
being followed, and that the calibration accuracy of each
piece of T&M Equipment was traceable to the NBS.
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(3) The inspector verified that only the Test and Measuring
equipment covered by the T&M program were used on safety
related structures, systems and components by:
(a) Reviewing the following instruments calibration records:
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IE22-F010
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IE22-N001B
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(b) By discussion with the following personnel:
1.
Andy Sandfoss - Rad / Chem Technician
2.
Daryl Kiphart - Junior I&C Technician
3.
Ron Wagner - Maintenance Technician
4.
Don Vance - Senior Maintenance Technician
d.
Findings
(1) Maintenance Group T&M Program
(a) Step 5.1.3 and 5.1.1.13 of ME. AMP.01 allows Maintenance
Supervisor (MS) or his designee to approve documents, but
the Station Administrative Directive, MT. SAD.01, requires
the MS only.
(b) There was no inspection or documentation review required by
the QA group on T&M equipment received by Maintenance Group.
(c) Step 5.8.3 of ME. AMP.01 requires the filing of completed
usage logs in the equipment history file, but to date this
has not been done. The MS agreed to begin filing them as
required.
(d) The calibration data sheet for Outside Micrometer, No.
42974-1 has the recalibration date of January 2,1982 and
it should be January 2,1983.
The above items, 5.d.(1)(a) through (d), are considered to be
unresolved and will be reinspected during future inspections.
(50-358/81-07-02)
(2) Rad / Chem Group T&M Program
(a) Various T&M equipment in the chemistry lab were tagged
with do not use labels, but were not placed in an uniquely
identified segregation area.
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(b) A gas partitioner was due for calibratica on January 29,
1981, but was not calibrated or marked do not use on March 5,
1981.
(c) There is no inspection or documentation review required
by the QA Group on T&M Equipment received by Rad / Chem Group.
The above items, 5.d.(2)(a) through (c) are ccnsidered to be
unresolved and will be reinspected during future inspections.
(50-358/81-07-03)
(3)
Instrument & Control T&M Program
(a) The I&C control of out-of-calibration T&M Equipment
procedure only requires " essential active" instruments
be reviewed if T&M equipment is found to be out-of-
calibration and there is no requirement to notify Shift
Supervisor if problems are found.
(b) There is no implementing procedure written to reflect how
- be requirements of MT. SAD.01 are being accomplished by the
'.&C Group.
(c) The below problem areas were noted during the record review
of the following T&M Equipment.
1.
TGN-328 - no basis for selection and no calibration
sticker attached.
2.
TRP-202 - no basis for selection and no receipt
inspection.
3.
TCA-225 - no basis for selection and no receipt
inspection.
4.
TPT-345 - manufacturer recommended yearly calibration,
but only required every three years by statioc
and no basis for selection.
5.
TSB-283 - no receipt inspection and no basis for
selection.
6.
TDG-006 - no receipt inspection and the equipment
history form did not reflect the status
,of the instrument.
(It was stored in the
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DO NOT USE locker with a tag on it, but no
records showed why).
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(d) The I&C foreman provides written permission for secondary
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standards to be used in plant vice the cognizant group
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supervisor as required by MT. SAD.01.
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(e) There is no inspection or documentation review required
by the QA Group on T&M equipment received by I&C group.
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The above items, 5.d.(3)(a) through (e), are considered to be
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unresolved and will be reinspected during future inspections.
(50-358/81-07-04)
6.
Preoperational Test Procedure Review
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Preoperational test procedure P0-LP-01 was revised one day prior to
commencement of testing. The inspector performed an initial non-technical
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review which resulted in seven comments, some of which were substantial.
These comments were transmitted to the CG&E Test Coordinator and the GE
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NSSS Test Coordinator for their resolution.
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The inspector interviewed the Technical Staff Engineer who performed the
procedure review for the station review board (SRB). The inspector
determined that this review was not an in 'ependent review and did not
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include all pages marked as being revised. No substantial comments were
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generated in the course of this technical review which was superficial.
This observation is similar to an observation made in Section 4 of IE
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Inspection Report No. 50-358/79-36. This item is considered to be
unresolved pending a complete review of this procedure revision.
(50-358/81-07-05)
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7.
Preoperational Test Program Implementation
a.
Document Control
The inspector conducted reviews to determine that drawings being
used by preoperational test personnel were current issues, and
that field changed drawings were referred to the design engineer
for review and revision.
(1) Documentation Reviewed
(a) Quality Assurance - Construction Methefs Instruction
(QACMI) No. G-5, Ee.f sion 6 dated January 2,1981.
(b) SU.ACP.13, Revision 05, Processing of Engineering Change
Requests, dated January 16, 1981.
(c) ECR No. 9 dated Nvrember 17, 1977.
(d) SU.PRP.01, Revision 13, System Release and Turnover dated
November 11, 1980.
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(e) PT-WE-01 dated November 28, 1979.
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"teld Construction Procedure 2-26, Document Control For EPD
System Turnover, Revision 05 dated June 16, 1980.
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(2) Findings
The inspector identified an Engineering Change Request (ECR-9)
which had been cancelled by the Architect Engineer (S&L) without
appropriate documentation. This cancellation effectively removed
instruments from the appropriate drawings which were required to
verify compliance with the station technical specifications for
water leakage into containment.
Neither station operations nor the cognizant system engineer were
aware of the cancellation. This item is unresolved pending an
inspection at S&L.
(50-358/81-07-06)
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Further inspection revealed that the documents changed by the
cancellation of ECR No. 9 should have been controlled under a
system freeze per SU.PRP.01 since the system was turned over
for preoperational testing (PT-WE-01), however these documents
(M-762 Sheets 2, 3 and 4) were not included in the system freeze.
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This omission has been corrected by the licensee and action has
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been taken to have the affected instruments returned to the
design documents.
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b.
Design Changes and Modifications
b
The inspector reviewed the implementation of a minor design change
by station maintenance to verify that reviews, processinj and
implementation were according to procedural controls and that the
cognizant engineer was awr ee of the change. Also, the inspector
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reviewed the program for control of jumpers, blocks, lifted leads,
and relay finger covers in an attempt to verify that these items
were installed and tracked in accordance with established administra-
tive controls. Further inspection will be required in these areas.
(1) Documentation Reviewed
(a) Modification Package for the Instrument Air System
(Station Work Request No. 00885).
(b) SU.ACP.11, Revision 02, Processing and Review of
Design Document Change Forms, dated August 8, 1978.
(c) SU.ACP.13, Revision 05, Processing of Engineering
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Change Requests, dated January 16, 1981.
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(d) GED Procedure NPP-04, Revision 00, Engineering Change
Requests, dated October 9, 1980.
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(e) GED Procedure NPP-06, Revision 00, Safety Evaluation
Reviews, dated October 8, 1980.
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(f) EC. SAD.03, Revision 05, Jumper and Lifted Wire Control,
dated October 10, 1980.
(g) E0TD Procedure EC-17, Revision 01, Controlled Temporary
Connections.
(h) EC. SAD.05, Revision 03, Work Requests, dated February 8,
1980.
(i) Field Construction Procedure 2-6, Revision 08, Design
Document Change (DDC), dated August 14, 1980.
(j) DDC VIB-563, dated November 16, 1978.
(2) Findings
(a) Piping and Instrument Detail Drawing M-86 Sheet 2 was
revised by S&L as a result of DDC WYB-563. The inspector
observed that the physical installation of dampers IVC 91Y
and IVC 92Y did not agree with drawings M-86-2, Revision E,
and M-515-2, Revision H, but did agree with M-786-38,
Revision 0.
The inspector also noted that prior to revision
E (which resulted from DDC WYB-563), M-86-2 had agreed with
M-786-38.
Review of DDC WYB-563 revealed tnat it had been
written against M-515-2, did not explicitly require changes
on any drawings, and appeared to identify a nonconforming
condition. The licensee was apprised of this situation and
subsequently determined that M-86-2 had been revised by S&L
in error. This is considered to be an example on inadequate
design review by the Architect Engineer and CG&E General
Engineering Department. This is in noncompliance with 10 CFR 50, Appendix B, Criterion III, which states in part
that measures shall be established to assure that... the
design basis...are correctly translated into specifications,
drawings , procedures , and instructions.
It is also contrary
to CG&E Contruction QA Manual, Section 3.12 which states in
part that when necessary, design changes covering structures,
systems, components, procedures and instruction, including
field changes, are subject to design control measures com-
mensurate with those applied to the original design.
(50-358/81-07-07)
(b) Of four Jumper and Lifted Wire Orders checked by the
inspector, two (81031 and 81053) were not in the file although
logged; one (80078) was found to have tags improperly filled
out and still hanging approximately nine months after installa-
tion, although the order stated that these jumpers would be
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required for approximately three days; and one (80208) appeared
to be completed properly.
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These discrepancies were discussed with the operations
supervisor and the station quality engineer, who stated
that a major revamping of the system was in progress to
alleviate these and other known problems. A prior QA
audit had also identified problems with the implements-
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of EC. SAD.03. This item is considered to be unreselved
pending revision and review of EC. SAD.03. (50-358/81-07-08)
c.
Training
The inspector interviewed two station personnel involved in
preoperational testing to verify that appropriate training had
been received and that the personnel were knowledgeable of QA/QC
requirements, administrative controls for testing, and applicable
technical training. The station training program for preopera-
tional test personnel appears to be adequate.
8.
Plant Tours
The inspector conducted frequent plant tours throughout the inspection
period. The following items were identified and the licensee has taken
appropriate corrective action.
a.
At 9:00 a.m. on March 5, the inspector was notified of a small
fire which occurred late the previous night involving some
scaffolding outside the Diesel Generator Building near the
'A'
Diesel Exhaust. The inspector viewed the area and determined
that no safety-related equipment had been affected by the fire.,
b.
Danger Tag R-64773 from switching order number 790850 was observed
lying in the bottom of panel 1H13-P631. This tag was neither located
near the affected equipment nor was it properly filled out.
c.
The access door handles for the 'A'
Diesel Ventilation intakr. duct
were found to be broken off,
d.
A broken cable conduit was observed in the 'B' Diesel Room
(leading to IFZ-VD053).
A construction worker was observed to be asleep inside cable tray
e.
No. 2080K (ESS Division II). A 2 x 10 wooden plank and assorted
padding materials were also observed in the same tray.
f.
Danger Tag # R-27812 from switching order #791504 was observed
to be improperly filled out.
g.
Loose paper trash was observed in the top of the flammable control
panel T49-P866B.
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h.
Tags identifying instruments and junction boxes on panels H22-P018
and H22-P021 were found to be in conflict with the cables supplying
them (i.e., cables *were marked ESS Division I and II, respectively,
while the panels were tagged as RPS Division IA and IIB, respectively).
9.
Un'esolved 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. Seven unresolved items disclosed during
this inspection are discussed in paragraphs 3.b, 5.d.(1), 5.d.(2),
5.d.(3), 6, 7.a.(2), and 7.b.(2)(b).
10.
Monthly Exit Interview
The inspectors met with licensee representatives (denoted in paragraph
1) at the conclusion of the inspection on March 27, 1981. The inspectors
summarized the scope and findings of the inspection.
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