ML20023D900
| ML20023D900 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 05/23/1983 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20023D897 | List: |
| References | |
| 50-358-82-13, NUDOCS 8306060132 | |
| Download: ML20023D900 (8) | |
Text
Appendix A NOTICE OF VIOLATION Cincinnati Gas and Electric Company Docket No. 50-358 As a result of the inspection conducted on August 10-12, September 7-10, 13-17, October 19 and November 2-4, 1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion II states, "The applicant shall identify...the major organizations participating in the quality assurance program, together with the designated functions of these organizations."
Contrary to the above, the Wm. H. Zimmer Quality Assurance Manual, Sections 1 and 2, " Organization" and "QA Program" did not include documented instructions and charts designating the functions of the organizations to ensure effective CG&E management control over the Catalytic, Inc. (CI) essential work activities and the CI QA program.
Neither the CG&E QA Manual nor the CI QA Manual provided an adequate description of CI's purpose and function concerning site safety related work activities.
This is a Severity Level IV violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion 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." and that
" Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design, and be approved by the organization that performed the original design unless the applicant designates another responsible organization."
The Wm. H. Zimmer Quality Assurance Manual, 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 are prepared by the designers, which clearly tra tslate the design principles into documents which describe acceptable strue.ures, systems, and components."
8306060132 830523 gDRADOCK 05000358 PDR
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Appendix A 2
Contrary to the above, (1) DDC S-4190 was not issued until August 20, 1982, and as a result, drilling of the core bore holes, including exploration holes, was performed without adequate design consideration being given to acceptable tolerances such as angularity and hole diameter deviations; and (2) RCC C-098 was issued by the field resident engineer on June 15, 1982, altering the generic bolt spacing acceptance criteria without prior docu-mented review and approval from the corporate design organizations performing the original design.
This is a Severity Level V 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 instruc-tions, procedures, or drawings."
The Wm. H. Zimmer Quality Assurance Manual, Section 5, states that,
" Construction, fabrication, 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, pro-cedures, 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, the following deficiencies were identified:
Instructions contained in Catalytic, Inc. (CI) Control Work Package a.
t (CWP) 82.007.18 were not followed. Contrary to the requirement that DDCs should be generated and approved prior to core drilling of holes, core bore holes, including a large number of small exploration holes, were drilled without Design Document Changes (DDC's) being written by l
Catalytic, Inc. (CI).
l b.
Adequate procedures had not been provided to control five of the six methods of work assignments and scope of work activities assigned to Catalytic, Inc. (CI). The methods not adequately controlled were:
(1) Master Punchlist, (2) Generation Construction Department (GCD) letters, (3) Work Requests (WRs), (4) Construction Work Authoriza-tions (CWAs), and (5) Verbal Requests.
I Work Requests (WR's) were not received by Catalytic, Inc. (CI) from c.
CG&E prior to the preparation of a Control Work Package (CWP) or Work Package (WP) as required.
Examples included:
(i) CWP FC-01-424.00, Removal of Existing Fuel Pool Heat Exchangers; (ii) CWP 82-007.21, Demolition of Existing S-12, S-13, and S-14 Supports to CRD Systems; (iii) CWP 82-028, Refurbishing Painted Welds and Fireproofing for QCP; and (iv) Removal of Fireproofing from Structural Steel.
Appendix A 3
d.
An adequate procedure was not provided to control classification of work. The removal of fireproofing material and paint to allow inspection of structural welds was not properly classified, bypassing QA requirements.
This is a Severity Level IV violation (Supplement II).
4.
10 CFR 50, Appendix B, Criterion X, states that, "A program for inspec-tion of activities affecting 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 accomp-l lishing the activity."
AWS D1.1-1972, Section 6, Inspection, requires the inspection of welding work and records (6.3).
ANSI N45.2.5 - 1972, Section 5, Inspection of Steel Construction, requires inprocess inspection of welding and repairs (5.5).
The Wm. H. Zimmer Quality Assurance Manual, Section 10, states that,
" Inspection and tests are performed in accordance with written proced-ures which include requirements for checklists and other appropriate documentation of the inspections and tests performed. QAD audits the documentetion of inspections and tests to assure that established procedurea are followed and test requirements are met."
1 Contrary to the above, the following deficiencies were identified:
a.
The CI QC surveillance program was not adequate nor effective to ensure timely identification of nonconformances. As a result of this deficiency, repetitive, rejectable core bore hole drillings were allowed to proceed unnoticed by the licensee during the implementation of Control Work Packages (CWP's) 82.007.18 and 82.007.20.
b.
Adequate program and procedures were not provided for inspection of in-process weld repair activities performed by Catalytic, Inc.
(CI) during the implementation of CWP 82-038 (NR Q-QAD-82-2222, Revision 1).
This is a Severity Level IV violation (Supplement II).
5.
10 CFR 50, Appendix B, Criterion II states that, "The QA program shall provide for indoctrination and training of personnel performing activi-ties affecting quality as necessary to ensure that suitable proficiency is achieved and maintained."
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Appendix A 4
The Wm. H. Zimmer Quality Assurance Manual, Section 2.10, states that,
" Personnel performing quality-related activities are properly trained and indoctrinated and the effectiveness of such training or indoctrina-tion is established by appropriate tests as required by recognized c les and standards...
Retesting of personnel may be required to as-certain that their proficiency is maintained."
Contrary to the above, CI did not provide a documented general or specific work training program or a documented QA training program for the craft foremen.
Specific on-the-job training was not properly documented. As a result, the lack of training may have contributed to the deficiencies such as not following CWP instructions, as evidenced by the many core bore and exploration hole drilling locations observed in the field.
This is a Severity Level V violation (Supplement II).
6.
10 CFR 50, Appendix B, Criterion VI, states that, " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality."
The Wm. H. Zimmer Quality Assurance Manual,Section VI, states that, "The QA Division is responsible for assuring that measures are in effect for the control of documents which prescribe all activities affecting quality, including changes thereto."
Contrary to the above, the following deficiencies were identified:
a.
The Catalytic, Inc. (CI) document control system was not adequate to ensure that the latest procedures (CWP 82.007.18 and CWP 82.007.20) or drawings (S&L Drawings S-680, S-686, and S-687) were being applied in the installations, b.
Catalytic, Inc. (CI) CWP No. 82.007.20 did not reference the design l
documents required to implement a work assignment (Sargent and Lundy (S&L) Drawing S-680, Revision H, and associated notes).
c.
Design Document Change (DDC's), DDC-SLS-709, Revisions A, B, and C; DDC-SLS-711; DDC-SLS-713; and DDC-SLS-737 were not properly controlled and distributed by the site document control center. The DDCs had been transmitted directly to the site QCP personnel from S&L and not through the site document control center.
d.
Adequate control measures were not established to ensure that the subsequent design document revisions and changes were evaluated to determine the impact of the change on ongoing and completed work activities.
This is a Severity Level V violation (Supplement II).
Appendix A 5
7.
10 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 determine the effectiveness of the program... followup action including reaudit of deficient areas, shall be taken where indicated."
The Wm. H. Zimmer Quality Assurance Manual, Section 7, states that, "The effectiveness of the control of quality by vendors is evaluated through a program of planned 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 con-ducting audits, at the discretion of the QA Division. Audits of major contractors and suppliers are conducted at intervals commensurate with the importance and complexity of the item."
Section 18 states that,
" Audits of vendors supplying materials or services at construction sites are also performed. QA Division re-audit deficient areas to assure implementation of corrective action..."
Contrary to the above, the following deficiencies were identified:
a.
The one CC&E audit of Catalytic, Inc. (CI) was limited in scope and identitled no CI program deficiencies. Also, the cancelled audits did not include an audit scope, approved plans, or checklists. Two I
additional scheduled audits were cancelled and the audit schedule was changed without justification, b.
Followup action of deficient areas addressing two concerns identified in Field Audit (FA) 388, dated March 1-11, 1982, had not been completed.
This is a Severity Level V violation (Supplement II).
8.
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 and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to precluds repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to the appropriate levels of management."
The Wm. H. Zimmer Quality Assurance Manual, 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 2
Appendix A 6
deficiencies identified by project participants. Audits shall be reviewed to assist in identifying QA nonconformances. The corrective action required to eliminate the deficiencies, assurance that corrective action is taken and appropriately documented, and reporting such defi-ciencies and corrective actions to appropriate levels of management is the responsibility of QA. Vendors, contractors, and subcontractors 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, the following deficiencies were identified:
a.
Many of the findings identified during this inspection were similar to or the same as those previously identified in Region III piping suspension system inspection reports. The following inspection reports were specifically discussed with licensee management and are the subject of enforcement actions.
(i)
The present lack of clearly defined licensee work inter-faces with CI and the assignment of CI responsibilities were similar to a previous Region III finding documented in the Region III Report No. 50-358/80-25, Paragraph 1.b.,
concerning Reactor Controls, Inc. (RCI). The CG&E audit did not reveal the RCI QA manual deficiencies including lack of description of organizational interfaces, personnel authorities, and responsibilities.
(ii)
The present inadequate licensee design control in the areas of CRD anchor bolt drilling tolerance and insufficient S6L design considerations were the same as a previous Region III finding documented in Region III Report No. 50-358/80-05, Paragraph 4.b., where it stated that (1) site developed small bore pipe guide and support design table was not approved by the A-E and the installation was not in I
accordance with the design table; and that (2) the design l
basis for the installed small-bore pipe restraint multiple structural assembly was not provided by the A-E.
t (iii)
The present identified noncompliance, where procedure l
requirement in CWP 82.007.18 had not been followed, was determined to be caused by the lack of procedure clarity.
i Similar findings relative to the same problems were discussed in the following Region III Reports:
(1) 50-358/80-16, Paragraph 3 - Deficient QC inspection procedure.
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Appendix A 7
(2) 50-358/80-16, Paragraph 5 - Lack of instruction for site Immediate Action Directives.
(3) 50-358/80-22, Paragraph 2 - Lack of procedural re-quirements for timely support installation inspections.
(4) 50-358/80-25, Paragraph 1.c. - Inadequate CRD installation procedure.
(5) 50-358/80-25, Paragraph 3.d. - Site procedures contained conflicting requirements.
(6) 50-358/81-17, Paragraph 3.e. - Lack of licensee timely upgrade of site work procedures.
(iv)
The present lack of QC surveillance ot core bore hole drilling activit'les was similar to a previous Region III finding documented in Region III Report No. 50-358/80-25, Paragraph 1.d.
For the CRD concrete expansion anchor bolt installation torquing, the licensee only inspected half of the 100% population required by the site hanger program.
(v)
The present lack of CG&E audit of CI was similar to a previous Region III finding documented in Regica III Report No. 50-358/80-25, Paragraph 2.
The lack of licensee audit of RCI in the areas of design, installa-tion, and overall program assessment resulted in a large number of noncompliances.
In addition to the above specific problems discussed, there had also been a number of Region Ill staff and management meetings held with CG&E in 1980 and 1981. Despite the Region III effort, the CG&E program did not show adequate improvement.
Region III emphasized its position that the licensee should perform 100% re-inspection for installed piping suspension system. This was documented in Region III Report 1
No. 50-358/80-05, Paragraph 6.
Region III management discussed with the licensee that it should conduct QC inspections in a timely manner, and should develop a comprehensive QA audit program for piping supsension system installations. This was documented in Region III Report No. 50-358/80-16, Exit Interview Section.
An enforcement meeting was held at the Region III office on January 28, 1981. Region III management expressed concern that the licensee's lack of control of RCI had resulted in numerous noncompliances. The meeting was documented in Region III Report No. 50-358/81-04.
Appendix A 8
On June 9, 1981, the Region III inspector discussed the following with CG&E management at the site:
(a) voiding of NR's by HJK QC Manager, (b) voiding NR's by issuing DDC's, (c) lack of audit of RCI by CG&E, (d) 100% re-inspection of installed supports, and (e) continued inadequate procedure review.
j b.
Quality Confirmation Program (QCP) Procedure 19-QA-13, Work Order Interface, Revision 0, dated September 16, 1981, was not properly approved. The approval was performed by the Director, Quality Engineering, rather than an individual certified as a Level III.
The procedure contained noted deficiencies, including inadequate control of nonconforming conditions, work orders, and work classification.
c.
Corrective Action Request (CAR) 82-47, initiated on June 7, 1982, concerning improper classification of work activities by the CI nraject engineer in accordance with QCP Procedure 19-QA-13 Work Order Interface, Revision 0, had not been properly dispositioned.
The work had not been stopped and the identified deficiencies controlled as of September 8, 1982. The deficiencies included the uncontrolled removal of fireproofing materials from structural steel and paint from welds to allow inspection.
4 d.
The finding identified in Audit Report No. WHZ-1, dated March 31 -
April 2, 1982, concerning the CI QA Engineer not receiving the documents required to define the scope of the CI work, had not been corrected as of September 17, 1982.
This is a Severity Level IV violation (Supplement II).
9.
10 CFR 50, Appendix B, Criterion XVII, states that, " Sufficient records shall be maintained to furnish evideace of activities affecting quality...shall include at least the following:
...results of review, inspections,..."
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The Wm. H. Zimmer Quality Assurance Manual, Section 17, states in part that, " Documentation of all performance surveillance includes... pro-i l
cedure, type observation...results..."
Contrary to the above, no documentation was provided to indicate (or reference) that Procedure 19-QA-28, Revision 0, was the acceptance criteria used by the CG&E QA inspectors during inspection of structural steel welds.
This is a Severity Level V violation (Supplement II).
MM 2 3 GB3 Dated James G. Keppler Regional Administrator
.