ML20064E283

Suppls 800819 Response to NRC Re Violations Noted in IE Insp Rept 50-358/80-14.Corrective Actions:Responses to Deficiency Audits 261 & NQA-187 Received & Responses to Infractions Will Be Reviewed by QA

ML20064E283
Person / Time
Site:	05000000, Zimmer
Issue date:	09/19/1980
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20064E073	List: ML20064E133 ML20064E148 ML20064E152 ML20064E173 ML20064E193 ML20064E217 ML20064E237 ML20064E253 ML20064E268 ML20064E283 ML20064E293 ML20064E296 ML20064E299 ML20064E307 ML20064E311 ML20064E419 ML20064E443
References
FOIA-82-206 QA-1342, NUDOCS 8301050254
Download: ML20064E283 (3)

Text

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_ i September 19, 1980 OA-1342 U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. R. F. Heishman, Chief Reactor Operations and Nuclear Support Branch RE: HM. H. ZIMMER NUCLEAR POWER STATION - UNIT I IE INSPECTION REPORT NO. 80-14. DOCKET NO.

50-358, CONSTRUCTION PERMIT CPPR-88. W.O. #

57300-957 , JOB E-5590 Gentlemen: ,

In accordance with site discussions with the NRC Senior Resident Inspector and in reviewing of our response, QA-1331, dated August 19, 1980, to your Inspection Report #80-14, we are providing the following additional response to Items 1 and 2 of Appendix "A".

In accordance with our letter, the information included under Item 1 identified the appropriate respunses to the deficiency covered by the referenced audits; however, the response did not cover the infraction covering adequacy and timeliness of correction of conditions adverse to quality.

Our supplemental response is as follows: -y.,;.  : e '.

, i. . 3 T Appendix "A", Item 1 Corrective Action Taken and the Results Achieved i Responses to the subject deficient audits were immediately requested. Responses to Audit NQA-187 were received 3

^rru norEo August 11 and August 18, 1980. The response to Audit #26f.

was received on August 15, 1980. ,

i Corrective Action to be Taken to Avoid Further Noncomoliance i A member of the duality Assurance Department has assumed responsibility for review.of.the audit log to determine those audits which are deficient in response or close-out. Once -

each month, a memorandum is circulated to the responsible.

8301050254 821116 PDR FOIA DEVINE82-206 PDR ___ ._

A.727 &$ E*N ENL 03 e

• ifr. R. F. Haishman U. S. Nuclear Regulatory Commission Region III September 19, 1980 .

QA-1342, Page 2 i

Appendix "A", Item 1 (Cont'd) auditors which identifies such deficiencies. Request for response or close-out is subsequently implemented by the auditor. The Quality Assurance Manager receives a copy of this menorandum and monitors that corrective action is implemented in a timely canner.

Date When Full Compliance Will Be Achieved Full compliance has been achieved.

Appendix "A", Item 2 Corrective Action Taken and the Results Achieved Our response to Item 1 above is also applicable to this infraction. Our letter, QA-1331, also stated the

_ corrective action taken and the plans for documenting discovery of unplugged weld rod warmers.

Corrective Action to be Taken to Avoid Further Noncompliance Responses by site organizations to infractions identified during NRC inspections shall be thoroughly reviewed by Quality Assurance to assure applicability, adequacy and .

feasibility. An instruction session shall be conducted to indoctrinate personnel responsible for providing responses and implementing corrective action to items of infraction.

The purpose of the indoctrination session shall be to -.

emphasize and clarify the necessity for adequate corrective action. Conduct of this training session is scheduled for the week of September 22, 1980.

ivi.

ATT*N NOTED s

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EnVRN TOs

a.7:r on cey :N2 cp Mr. R. F. Heishman U. S. Nuclear Regulatory Commission

. Region III September 19, 1980 .

QA-1342, Page 3 l

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i

Appendix "A", Item 2 (Cont'd)

Date When Full Compliance Will Be Achieved Full compliance will be achieved by October 1,1980.

We trust that this letter will eliminate any confusion regarding our prior response.

Very truly yours, THE CIfiCIllNATI GAS & El.ECTRIC COMPANY By E. A. BORGT4 ANN SEf!IOR VICE PRESIDENT WWS:pa cc: Resident flRC Inspector Attn: F.T.Daniels/

Henry J. Kaiser Company Attn: P. S. Gittings R. Marshall J. R. Schott H. C. Brinkmann S. C. Swain W. W. Schwiers I

ATT*N NOTED .

4 KnVRN TOs

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I August 19, 1980 QA-1331 U. S. Nuclear Regulatory Commission Region III 799 Roos::velt Road Glen Ellyn, Illinois 60137 Attention: Mr. R. F. Heishman, Chief Reactor Operations and Nuclear Support Branch

~ RE: WM. H. ZIfEER NUCLEAR POWER STATION - UNIT I IE INSPECTION REPORT NO. 80-14. DOCKET N0. . . .,

50-358, CONSTRUCTION PERMIT CPPR-88, W.0. #

57300-957, JOB E-5590 Gentlemen:

. This letter constitutes our formal reply to the subject inspection report. It is our apinion that nothing in the report or this reply is proprietary in nature. ,

Our response to the items of noncompliance, as identified in Appendix "A" of

- the report, is as follows:. .:

.. - . . . .---..--.:. ~ .

y I. (a) Cormctive Action Taken and Results Achieved ?..;,, %.-.

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l Audit Item #3, Finding #4:

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. < .. - <. w ' f * - To assure only authorized personnel sign, test data sheets and r/3 i~ -

- - release fonns, a procedure, ADMIN-6 titled " Authorized -

Signatory Personnel",is being developed which will give a listing of personnel authorized to sign various project documents.

i- Corrective Action to be Taken to Avoid Further Noncompliance ATTN QTED Audits Will be Conducted of the Generation Construction Department Tumover Group to assum their test data sheets and mlease fonns am signed by authorized personnel. ' -1 ~ .  :;

a'..

i l Date When Full Compliance Will Be Achieved Full conpliance will be achieved by October 15, 1980,'

/ .

R N TOs ,

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en, ad um sup c=

Mr. R. F. Hatshman U. S. Nuclear Regulatory Comission

. Region III August 19,1980 - QA-1331 Page 2

. Corrective Action Taken and Results Achieved Audit item #11, Finding #1:

Inspection was perfomed to the same revision of drawing

~

used by field construction to teminate Cable RH719. This was revision G of Drawing E-2417. Subsequent revisions to Drawing E-2417 did not change Cable RH719. Inspectors have been instructed to verify current revisions of drawings prior to perfoming inspection.

Corrective Action Taken to Avoid Further Noncompliance l Training class was held December 6,1979 for inspectors emphasizing importance of working to latest revision of drawings.

Date When Full Compliance Will Be Achieved Full compliance was achieved December 6,1979.

Corrective Action Taken and Results Achieved Audit Item #11, Finding #4 (EC-1 Mecoer Test): .

According to the Auditor, an EC-1 megger test was perfomed . b '

on December 28, 1978 to Drawing E-2417, Revision L. No

~ ~ ~ -

reference was made to Drawing-E-2417, ' Revision-M, because at.the time of the test, Revision M had not been issued. .

Therefore, the EC-1 megger test was performed to the latest revision available at the time of the test. The auditor should not have considered this an item of noncompliance.

. .. . . . . , - :r .w , . .

Corrective Action to be Taken to Avoid Further Noncompliance '

No corrective action is necessary. .

'Date When Full Compliance Will Be Achkved_

f

^m ao"o Not applicable. -

h Corrective Action Taken and Results Achieved .$. ,

Audit Item #11, Findinas #5 and #6: ,

The Inspector's stamp indicates that the required inspection (visual, measure, review, record) has been perfomed. Where -

the inspection method is " record" is applicable on the inspect- '

arrunw ro, ion plan, we have recorded the required infomation. Where

i.ver uu tus.cu Mr. R. F. Heishman U. S. Nuclear Regulatory Comission Region III August 19,1980 - QA-1331 Page 4 I

ga Corrective Action Taken and Results Achieved Inspection personnel have been specifically instructed to include observation of weld rod wanners in their routine daily surveillances. Situations involving unplugged warmers shall be documented.

Corrective Action to be Taken to Avoid Further Noncompliance Weld rod warmers found unplugged will be documented by the inspectors and specific corrective action taken. Recurrence involving individual welders will be reviewed by Construction fianagement and appropriate disciplinary action taken.

Date When Full Compliance Will Be Achieved .

Full compliance will be achieved by September 15, 1980. .-

We trust that this letter is an adequate response to your IE Inspectioni"f, -

Report No. 80-14.

• Very truly yours,' '

THE CINCIflNATI GAS & ELECTRIC COMPANY 3

.. By -

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. . ;,s; . -y 1; .is.by,,., , .  : .. E. A. BORGMANN , ..',

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..3.. SENIOR VICE PRESIDENT -

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Henry J. Kaiser Company .

Attn: P. S. Gittings .

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R. Marshall . -

i. J. R. Schott

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! H. C. Brinkmann

m. , I worup K. Culver .

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E W'. Schwiers -

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s.m a.s eau en1 en Mr. R. F. Haishman U. S, Nuclear Regulatory Comission Region III August 19,1980 - QA-1331 Page 3

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"mcord" is not applicable, it has been deleted by revision made November 1.1979 to the Construction Inspection Plan (CIP).

Procedure QACMI E-7 reserves the lower left-hand corner of the pull card for Quality Control's final review and acceptance.

The pull card for this cable had not been reviewed for final acceptance. We do not feel this is a noncompliance.

Corrective Action to be Taken to Avoid Further Noncompliance Where " record" is not applicable on the inspection plan, it has been deleted by revision on November 1,1979.

Date When Full Compliance Will Be Achieved This was achieved November 1,1979. ,

I. (b) Cormctive Action Taken and'Results Achieved

~

Field Audit #261 identified two (2) items which were considered , .

..'*'.- deficiencies at that time. The first of these pertained to

.9'... specific requirements extracted from the 1978 edition of ' --

Tli.@.

. ANSI N45.2.6. Further investigation revealed that the 1973 -

T edition of ANSI N45.2.6 is the one which is applicable. A .-

a comparison of these two editions of ANSI N45.2.6 revealed that .i -

' they contain different requirements and this finding is now

, .c" .,

,______,_ invalidated except.. foe.tha.requ.irement .that-training activities-l..T

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' shall be conducted. . This has been restated in Field Audit #309 f. ,

and-has been addmssed by Henry J. Kaiser Company in their

bv response to Field Audit #309. ~~ G'. -

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" ~~ " The second finding of deficiency in Field Audit #261 pertained m. ; i . y ' .. .,. .

"- ').ito,. requirements extracted from ASNT-TC-1A. The deficiency was ' '

" ~~ that certain requirements stipulated by ASNT-TC-1A had been l

waived without properly documenting the basis for such waiver -

. as required. Certifications for the individual in question are

, .J . 6. . 1 now in order. -

,, , c, Arrn i norup Cormctive Action To Be Taken To Avoid Further Noncomplian_ce An outside consultant has been contracted to' review train 13g needs, and establish a training schedule and indoctrination.

program. . ,

. .i .. , .? .

Date When Full Cohliance Will Be Achieved .

Compliance will be achieved by Octob' e r 1,1980. -

KrTURu TOs

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1. o UNITED STATES 8 'o NUCLEAR REGULATORY COMMISSION 3* A 'I ~I* REGION lli o,,

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GLEN ELLYN,ILLINOls 50137 g . .%./...f

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i ocket No. 50-358' I Cincinnati Gas and Electric 1 Company ATTN: Mr. Earl A. Borgmann s '

Senior Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnati, OH 45201 Gentlemen:

This refers to the inspection conducted by Mr.'F. T. Daniels of this office on June 2-6, 9, 10, 16-20, 23-26, 1980 of activities at the l

Wm. H. Zimmer Nuclear Power Station authorized by NRC Construction Permit

No. CPPR-88 and to the discussion of our findings with Mr. Schott at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records', observa-tions, and interviews with personnel.

l During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appen- -

dix A.

This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regu-lations. Section 2.201 requires you to submit to this office within 20 days of your receipt of this notice a written statement or explanation in i 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 compliance will *

be achieved.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part f, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document 1(oom, except as follows. If this report contains information that you or

- your contractors believe to be proprietary, you must apply in w iting to

Cincinnati Gas and Electric Company JUL 31 G801 this office, within twenty days of your receipt of this letter,;to with-hold such information from public disclosure. The application must include a full statement of the reasons for which the informatioh is con-sidered proprietary, and should be prepared so that proprietary dnforma-tion identified in the application is contained in an enclosure to the application.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, R. F. Heishman, Chief Reactor Operations and Nuclear 3upport Branch '

Enclosures:

1. Appendix A, Notice of Violation

2. IE Inspection Report No. 50-358/80-14 cc w/encls:

Mr. Schott, Plant Superintendent -

Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Harold W. Kohn, Power Siting Commission Citizens Against a Radioactive Environment Helen W. Evans, State of Ohio L

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a'n s/ cs Wayntek Hed an 7/29/80 7pogO / <)

, . . . . . . ~ . . . - - ...

Appendix A NOTICE OF VIOLATION .

Cincinnati Gas and Electric DocketNo.50l-358

- Company Based on the results of an NRC inspection conducted June 2-26, 1980, it appears that certain of your activities were not conducted in full comp-liance with NRC requirements as noted below. These items are infrac-tions.

1. 10CFR50, Appendix B, Criterion XVI requires in part:

" Measures shall be established to assure that conditions adverse to quality such as failures, malfunction, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected...."

Wm. H. Zimmer QA Manual, Section 16, Paragraph 16.4.2, " Construction Site states in part, "Significant conditions adverse to quality are, reported to ==nnaamant and appropriate levels of the contractor s management., Corrective ca tion is obtained where required."

Contrary to the above:

a. Two of the nonconformances identified in the NES Audit (NQA-187) performed in October, 1979 have not been responded to and/or adequately corrected.

b. The deficiencies identified in CG&E Field Audit Report No.261 have not been adequately responded to or corrected.

2. 10CFR50, Appendix B, Criterion XVI requires in part:

" Measures shall be established to assure that conditions adverse to quality such as failures, malfunction, deficiencies, deviations, de-fective material and equipment, and nonconformances are promptly identified and corrected..."

l Wb. H. Zimmer, FSAR, Section 17.1.16.6 states in part "When signi-ficant and/or repetitive conditions adverse to quality occur, they are reported to appropriate levels of CG&E and constructor manage-l 3 ment. Action taken to correct the cause of such conditions is also i

reported to appropriate levels of CG&E and constructor management..."

l -  :.-

Contrary to the above: )

! The corrective action taken to insure control of weld rod sed l

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for welding of safety-related components has been inadequate to meet requirements of FSAR and constructor's special process procedures manual, Section 3.3, Revision 7, dated March 11,1980 which requires weld rod warmers to be electrically plugged in at all times except during transport to and from the rod shsek.

On June 9, 1980, the inspector observed portable weld rod warmer

._ IW-2 in use, but not plugged in and the top was open.,-

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-358/80-14

.{

Docket No. 50-358 License No. CPPR-88 ,

Licensee: Cincinnati Gas and Electric Company 139 East 4th Street -

Cincinnati, OH 45201 Facility Name: W. H. Zimmer Nuclear Power Station Inspection At: W. H. Zimmer Site, Moscow, OH Inspection Conducted: June 2-6, 9, 10, 16-20, 23-26, 1980 Inspector: '//39!!D r i RF 4)&

Approved By: R. F. Warnick, Chief 7/'

J'd/J'o Projects Section 2 Inspection Summary Inspection on June 2-6, 9, 10, 16-20, 23-26, 1980 (Report No. 50-358/80-14)

Areas Inspected: Routine announced inspection of noncompliances and r unresolved items from previous inspections, Bulletin followup, Preoper-l ational Testing Quality Assurance and plant tours. The inspection j involved 96 inspector man-hours by the NRC Senior Resident Inspector.

' Results: Of the four areas inspected, two were found satisfactory and in the area of Preoperational Testing Quality Assurance two examples of noncompliance were found. (Infraction - 10 CFR 50, Appendix B, Criterion XVI - Inadequate corrective action taken on Audit findings.) In the area of Plant Tours a noncompliance was identified. (Infraction - 10 CFR50, Appendix B, Criterion XVI - Inadequate corrective action to control weld rod.)

l I .

.I

t DETAILS U

1. Personnel Contacted .

• J. Schott, Plant Superintendent i ..

• P. King, Assistant Plant Superintendent ,-

B. Culver, Construction Manager -

l ,

• W. Schwiers, Quality Assurance Manager

3. Ehas, Senior Quality Assurance Engineer N

• J. Wald, Quality Assurance Engineer G. Knox, Site Quality Control Administrator l

and others of the station staff.

L

• Denotes personnel attending monthly exit meeting.

2. Licensee Action on Previously Identified Items

-(Closed) Noncompliance Item 50-358/80-08-01

The inspector verified the second inventory conducted April 29, 1980 i included a verification of New Fuel Bundle serial numbers.

V (Closed) Noncompliance Item 50-358/80-08-02 The inspector verified that new fuel receipt inspection and inven-tory records are adequately stored and the appropriate revision has been made to NE. SAD.03, Accountability of Special Nuclear Materials.

/(Closed) Unresolved Item 50-358/80-04-01 The inspector reviewed the newest revision of EC. SAD.03, Jumper and i

Lifted Wire Control, and verified it is adequate to insure proper control of jumpers and lifted wires.

~

/(Closed) Unresolved Item 50-358/80-11-02 The inspector reviewed the newest revision of EC. SAD.05, Work Request, and verified it was adequate to control the storage and/or accumula-t'on of transient combustible material on the refueling floor.

(Closed) Unresolved Item 50-358/80-08-04 The inspector reviewed NE.RFP.01, Revision 1, Movement of Fuel in the Reactor and Spent Fuel Pool, and verified it to meet the require-ment for a refueling bridge operation procedure as delineated in NE. SAD.02, Revision 1, Fuel Handling and Core Alterations.

3. Bulletin Review F (Open) Bulletin 79-16, Vital Area Access Control

. This item remains open until appropriate response is received from the Electrical Production Department. p; i

2- ,

, - - - - -,---o-,-- -

/(Closed) Bulletin 79-24, Frozen Lines A review was performed to insure all lines exposed to outside atmos-phere were correctly and adequately heat traced or buried below the frost line. .

(Open) Bulletin 80-01 Operability of ADS Valve Pneumatic Supply

.. The inspector verified that all requirements of the bull 5tin have

been performed, except the scheduling and performance of

periodic leak tests of the ADS Accumulator System.

4. Preoperational Testing Quality Assurance Station preoperational testing quality assurance (QA) activities were observed and reviewed to ascertain the effectiveness of the licensee's QA program to provide controls over the conduct of preop-erational tecting and related activities; that the program is con-sistent with FSAR commitments and regulatory requirements and that the program is being properly implemented.

The following items were considered in this review:

. QA surveillance activities were being performed at the estab-lished frequency and in accordance with approved procedures or checklists.

. System turnover packages from construction to the preopera-tional testing group were conducted in accordance with approved procedures.

. Identified discrepancies were corrected.

. Corrective action was timely and appropriate.

. QA personnel conducting audit activity meet the minimum educa-tion and training requirements.

a. Documentation Reviewed (1) NES Audit NQA-187 of System Turnover Conducted, October 11, 1979.

Response to Audit NQA-187-B.K. Culver to W. W. Schwiers dated November 23, 1979.

3 (2) QA&S Audit / Surveillance Report No. 245 conducted June 7-8,

' 1979 of the CG&E Turnover Group.

(3) CG&EFieldAuditReport(FAR)No.261conductehSeptember4,

'1979 of Henry J. Kaiser (HJK) QA group. j l . .

Request for response to FAR No. 261 dated October 12, 1979.

Response to FAR No. 261 dated October 17, 1979. ,

Letter to Henry J. Kaiser Company from Principal 5 A&S Q

- Engineer stating response to FAR No. 261 was inadequate dated October 29, 1979.

Letter to Henry J.' Kaiser Company from Manager Quality Assurance reqvn. sting corrective action be taken to close FAR No. 261 dated January 23, 1980.

Inter-office memorandum from GC&E Auditor to HJK QA super-visor dated January 28, 1980.

Inter-office memorandum from HJK QA Supervisor to GC&E auditor dated January 30, 1980.

Letter to HJK from GC&E auditor dated January 31, 1980.

Inter-office memorandum from HJK to QA manager to CG&E QA manager dated May 1, 1980.

4. QA&S Procedure 18-QAS-01, Planning Reporting and Followup of Audits, revision 0, March 15, 1977.

5. QA&S Procedure 18-QAS-02, Qualification of Auditors, revision ), March 15, 1977.

6. HJK Quality Assurance Procedure No. 20, Indoctrination and Training, revision 3, May 2, 1979.

7. QA&S Audit No. 309 conducted April 30 thru May 2, 1980.

8. QA&S Auditors and Lead Auditors qualification records.

9. EPD QA Audit No. SU.TG.04 conducted May 1, 1979.

l

10. EPD QA Audit No. SU.TG.06 conducted June 5, 1979.

l l 11. Procedure QA. SAD.08 QA/QC Personnel Qualifications require-l ments, revision 00, May 21, 1979.

12. EPD QA Auditors qualification records, e

b. Findings i . .

l 1. NES Audit NQA-187 conducted October 11, 1979 none.onfor-l mance item #3, finding #4 concerning system turnover 1

l l

documentation review stated, "A list of personnel who are authorized to sign release forms and test data sheets was not available for review." The follow-up or corrective action response stated, " Generally, the release forms and test documents already provide signature block ,descrip-tion / requirements for the various groups or departments involved." This response was inadequate to inscre only authorized personnel sign. release forms and test data

- sheets during the release or test and the QA review of documentation.

Nonconformance item #11, findings 1, 4, 5, 6 concerning constructor QA and inspection activi ies had not been res-ponded to as of June 3, 1980.

The above are samples of inadequate responses and/or corrective action, therefore, they are considered to be in noncompliance with the requirements of 10CFR50, Appendix B, Criterion XVI, Wm. H. Zimmer FSAR and the Wm. H. Zimmer QA Manual, Section 16, Paragraph 16.4.2 which states in part that significant conditions adverse to quality are reported to management and corrective action is obtained where required. (50-358/80-14-01)

2. CG&E Field Audit Report No. 261 This audit of Henry J. Kaiser Quality Control inspection personnel was completed on September 4, 1979 and as of June 3, 1980 an adequate response and/or corrective action to solve the audit findings had not been completed.

This is considered to be in noncompliance with the require-ments of 10CFR50, Appendix B, Criterion XVI, Wm. H. Zimmer FSAR and the Wm. H. Zimmer QA Manual, Section 16, Paragraph 16.4.2 which states in part that significant conditions adverse-to quality are reported to management and correc-tive action is obtained where required. (50-358/80-14-02)

5. Plant Tours The following items were observed during the frequent tours conducted by the NRC Senior Resident Inspector. All items were acknowledged by the licensee.

[ a. Weld Rod Control

- The inspector observed a portable weld rod warmer (IW-2) in use in the drywell on June 9, 1980 which was not plugged.in and the l

1

1 l

top was removed exposing weld rod. Weld rod control has been brought to the attention of the licensee for many years and has been cited as items of noncompliance at least 10 times in the last five years, the most current being noncompliance item 50-358/80-07-01. This item is considered in noncompliance with 10CFR50, Appendix B, Criterion XVI, Wm. H. Zimmer FSAR ana

- KEI's Special Process Procedure Manual, Section 3.3 which

! requires that portable rod warmers are to be electrically plugged in at all time except during transport to and from the rod shack. (50-358/80-14-03)

b. Material in Safety-related Cable Trays

During the tour conducted on June 9, 1980, the following was i

observed in the cable trays:

1. Light bulbs

2. Metal pipe

3. Welders remote rheostat

4. Conduit support clamp

5. Wire brush

6. Concrete chips

7. Metal pipe fittings

8. Expansion anchor bolt

9. Various pieces of metal

10. Rags

11. Pieces of wood

12. Face shield

13. Paper towels used for liquid dye penetrant checks

14. Cardboard box As a result of this finding a cable tray cleaning crew has been assigned to clean all cable trays in the Reactor and Auxiliary buildings on a mcnthly rotating basis. .

I c. ABMCC 1A, compartment 12A, had 2 green tags on it from the same preoperational testing release (PT-RH-01). The tag numbers l were 7200 and 7207. Tag number 7207 was removed by licensee.

d. Partially full tube of AWS E7018 weld rod was found in compound Shelterhouse #2 June 2, 1980. The licensee destroyed the weld rod and conducted lectures for all welders concerning the

)

proper control of weld rod. Subsequent to that, item a. of l

Plant Tours was observed.

, i e. ANSUL fire bottle at NW quadrant, ground floor of turbine building, was found which has no inspection tag attached and

• was not wired to prevent inadvertant use. It was removed and replaced with a CO2 fire extinguisher.  ;

6. Monthly Exit Meeting The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on June 26, 1980. The -

inspector summarized the scope and findings of the inspection. The

.. inspector emphasized the necessity of insuring that welders are fully trained in the procedural requirements established for control of weld rod. In the area of cable tray cleanliness, the inspector noted that in latter part of the month a marked improvement could be observed and that the cable tray cleaning crews appeared to be an effective method to insure their cleanliness.

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F 3 O PERFORMANCE APPRAISALTEAM TvPE OF ACTIVITY CONDUCTED (CHECK ONE SOX ONLY) 33 34 INSPECT 80N OTHER G f O2rSAFETY 05 0 MANAGEMENT AUDIT 06 O MANAGEMENT Visit 00 0 MATL ACCT.

to O PLANT SEC.

13 C IMPORT 14 0 lNOUIRY l 15 O INVESTIGATION 03 O INCloE NT 07 O SPECI AL 11 O INVENT. VE RIF. l g F INVEST. ALs0 CMECK 04 O ENFORCEMENT 08 O VENDOR 12 O SHIPMENT / EXPORT g eLoCK s1 g INSPE CTION OR INvE578G ATtON WARNING- IPiNNOUNCED 20 UNANNOUNCED 35 ,

INSPE CTION SmF T: I g6AY SHIFT 2 COFF SHIFT 3 0 WE E KEND/HOLID AY l 36 INSPECTIONnNvESTIGATION NOTIFICATsON sCHECK ONE 80x ONLY)

J 31 10591 2 O REGIONAL OFFICE LETTER 3 0 REFERRED TO HOS FOR ACTION 4 0 REGION LETTER & HOS FOR ACTION INSPECTIONaNvf STeGATION FINDINGS fCMECK ONE 80x ONLVP

, DCLEAR 2 NCOMPLIANCE 3 0 DEVI ATION 4 0 NONCOMPLI ANCE & DEVIATION L ENFORCEMENT CONF ERENCE HELD: 1039 M NUM8E R OF NONCOMPLIANCE ITEMS IN LETTER TO LICENSEE: NcTt: CM ANot uust es sueurTTso e ON 764 wME hEvf R PntvsOUSLY CITED ITEu OF NONCouPLI ANCE N NUMBER OF DEVIATION ITEMS IN LETTER TO LICENSEE: 15 0FricsALLv paLETso Fnou TME RECOmo.

O NUMBER OF LICENSEE EVENTS 46 INSPECTION FE E 1 O NON-ROUTINE / VENDOR (No Feel 2 O ROUTINE (No Feel 3 0 ROUTINE (Feel 4 0 ROUTINE (F.e Redad)

O 47 CONTENTS 2.7900 INFORMATION O T YES ,

REGION AL OFFICE LETTER OR REPORT TR ANSMITTAL DATE FOR INSPECTION OR INVESTIGATION g 591 OR LETTER ISSUED TO LICENSEE REPORT SENT TO HOS FOR ACTION IMMEDIATE ACTIGN LETTER 48 O 54 59 60 DATE 65 lol'113ll lFlvl l IIIIII I IIIII I M M D D Y Y M M O D Y Y MM D D Y Y SUBJECT OF INVESTIGATION (CHECK ONE SOX ONLY10667 TYPE A 10 CFR 20 403 TYPES 10 CFR 20 405 MISC.

010 INTE RN AL OVE R E XPOSURE 06 0 11 D INT. OVE REXPOSURE 15 0 CRITICALITY 210 EQUIP. FAILURE 02 O EXTERNAL OVEREXPOSURE 07 0 12 O EXT. OVEREXPOSURE 18 O LOSS / THEFT 22O ALLEGATION /

S 03 O RELE ASE TO UNREST. AREA 00 0 13 0 EXCESS RAD. LEVELS 17 0 MUF COMPLAINT 04 O LOSS OF F ACILITY 09 0 14 O EXCESS CONC. LEVELS 18 0 TR ANSPORTATION 23O PUSLlC INTEREST 05 C PROPERTY CAMAGE 10 0 10 0 CONT AM/LE AKING 240 SABOTAGE SOURCE 250 ABNORMAL OCCUR.

20 0 ENVIRONMENTAL EVENT 260 OTHER 7

h ME ADOUARTER S ENTRIES y HOS ACTIONt)N INSP/ INVEST REFERRED BY REGION:

esa L Ce W 70 75 NOTE:- BLOCKS K TO N MUST BE U DATE MOS ENFORCEMENT LETTER. NOTICE. ORDER ISSUED: l l l l l ll - VERIFIED BY IE:HOS

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UNITED STATES NUCLEAR CEIULATORY COMMIS$10N INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GENER AL INSTRUCTIONS: BLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM IS TO BE COMPLETED FOR EACH.

(A) ITEM OF NONCOMPLIANCE CITED.

(B) ITEM OF NONCOMPLIANCE NOT CITED, AND, (C) DEVIATION CITED IN ENFORCEMENT CORRESPONDENCE OR LICENSE NUMBER REPORT NUMBER DOCKET NUMBER A-TYPE OF FINDINGS B-SPECIFIC N/C CODE . FUNCTeoNAL OR DEVIATION CAUSE PROCEDURE SEVERITY AREA (CHECK ONE BOX ONLY) 3 7 9 to 11 12 A NONCOMPLIANCE l l l l l l l l l C-MODULE NUMBER 13 19 1 2 B LICENSEE IDENTIFIED ITEMS C DEVIATION E-CONSEQUENCES D-HOW ITEM IDENTIFIED (CHECK ONE BOX ONLY) (CHECK ONE BOX ONLY)

A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE L LICENSEE 20 1 INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURRENCE N DID NOT HAVE POTENTIAL TO RESULT IN ACTUAL O O OTHER OCCURRENCE F -EXEMPT INFORM ATION G ADDITION AL UNITS (ENTER "M" 23 26 IN FIRST BOX FOLLOWED BY OTHER 22 S CH'ECK BOX IF EXEMPT INFORMATION IS INCLUDED IN TEXT BELOW, PER 27 .

10 CFR 2.790 H NONCOMPLI ANCE REPETITIVE OCCURRENCE (IF FIRST OCCURRENCE ENTER "1"l I-TEXT (ENTER UP TO 2400 CHARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEV NUMBER,IT WILL BE NECESSARY TO PARAPHRASE) s0 1

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(A) ITEM OF NONCOMPLIANCE CITED.

(B) ITEM OF NONCOMPLIANCE NOT CITED, AND.

(C) DEVIATION CITED IN ENFORCEMENT CORRESPONDENCE SO- MS OR LICENSE NUMBER MMN REPORT.NUMSER D ~ Ik DOCK T NUM8ER B-SPECIFIC N/C CODE pouctiowAt

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C-MODULE NUMBER 13 19 1 2 8 LICENSEE IDENTIFIED ITEMS C DEVIATION _

3 7 I l3 O E-CONSEQUE NCES D-HOW ITEM 10ENTIFIED (CHECK ONE 80X ONLY)

(CHECK ONE BOX ONLY)

A CAuSE OR CONSTITUTED ACTuAt OCCURRENCE L 0 tlCENSEE 20 1 INSPECTOR 21 P h H AD POTENTIAL TO RESULT IN ACTUAL OCCURRE N DID NOT HAVE POTENTIAL TO RESULT IN ACTUAL O OTHER OCCURRENCE F -EXEMPT INFORM ATION G ADDITIONAL UNITS (ENTER **M" 28 22 IN FIRST BOX FOLLOWED BY OTHER

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CORRESPONDENCE n . .

i

-x1 TO: Mr. F. T. Daniels DdTE: June 5,1980 80 88 FROM: B. K. Culver

SUBJECT:

Wm. H. Zimmer Nuclear Power Station Unit 1 - Your Verbal Report on Un-Controlled Weld Rod of June 2,1980__

Following up on our conference of Monday, June 2,1980, I am enclosing copies of memoranja relating to the incident as well as attendance lists of those kelders who attended training sessions conducted on June 3, 1980.

I am sure that better weld rod control will result from the ,

action taken.

&aLu B. K. Culver BKC:dw cc: W. W. Schwiers w/l l

I 1

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~. 5 THE CINCINNAT! GAS . -  % & ELECTRIC COMPAN1f .'= tThe Union 4Light,  :? ',.l~ '. Heat

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KAILi R ENGINEERS, INC,

. Job No.7070 Wm.11. Zimmer Nuclear Power Station Moscow, Ohio l KEl 182 (WRITE IT/ DON'T SAY IT)

.. . a: ...

To . 4 / J- 4 A'T 8# J c s 4 , N['-

SUBJECT e// fe, ) {c4 Yro/ DATE $te% .3, //fg d $ del Asl C#h o/ W G , /%e /x. 77*3 6/3/rs .e ~ s >- llN rd ^#:l??,$., rre -

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sea. casa c:st=2.v vo WA SIGNE

. .- . . . . . . . -. . . . .. . . .= . . u u . . . .

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DATE SIGNED

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45 474 Redifyrme

"*"''"'.,8'*'*8"""'*

.......r...

INTER. OFFICE MEMOR ANDUM 2

To Ibb liarshall oATE: June 3, 1,000

, AT~ Ibscott, Ohio FRoM : W. O. Puchett COPIES To:

. ATg }.bsecr,r, Ohio

. JoS No. 7070 suexcT: UTCOIITROLLED ROD FOUITD IN TH3 AIDC BUILDEG.

Bob: ,

I The uncontrolled rod found in the Aux building has been . destroyed and thrc.in in the trash can. The only thing I could tell by lool:ing at the rod markings, was it is 3/)2" Ihrex rod trith Hr h01J1571.

There is really no way I can tell uhen it tras dratin from the Rod Issue Room or uho it was dratin out by.

From the assortment of items in the bucket, it looks like items that the laborers may have picked up.

- ~~

~ I have irritten a letter to be issued to alI relders, ,

reiterating their responsibility where veld rod control is concerned.

~ ~~

w ___tm . c.p...n, e Worley D. Puckett Chief Ueld Digineer

_.UOP/jrt . . .- . _.

.I

. M g HJMCO189

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. 'To: B. Culver & B Mrshall DATEg Jun3 3,1980 AT: 1bacow, Ohio FRoM: W. O. Puckett CONES TO: All Superintendants .

Ocneral Forenen Crew Forenen -

AT: Moscow, Ohio All Uciders '

job NO. 7070 ,

suoJtcT: WELD ROD C0'ITP.0L.

Iately craft welders in all areas have becuce lax where weld ,

rod centrol is concerned. (SPF:: 3 3-R.3) The portable rod ovens are provided to telders to keep their unused rod in.

The stub bucket is for rod stubs, da . aged or used rod. At no time is a 1: elder to have these rods out of his working area unless in the proper container, bare red tube for un- -

coated uire and portable electrode oven for covered wire.

Welders are not to ste:r any weld rod in their tool bo:es cr any other unauthorized places.

An individual welder will have the pink copy of his weld 2 form (red slip) en or near his person at all ti.as and he -

will not have any rod that is not reflected en his red slip.

It is the welders responsibility to centrol his rod and tc return all unused rod and stubs to the P.od Shack, (P.od Issue Room). .

ANI' ELDER 701DID DT'VIOLATI0li 0F THE AE0VE E'TIONED RUL33 WILL E3 TEFl G ATED.

cQ's.P. w Worley O. Puckett

- Chief Weld Engineer wcP/jrt ,

e 6.Juco 3 gg

- dA7N!N: Session .

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Docket No. 50-358 Cincinnati Gas and Electric Company ATIN: Mr. Earl A. Borgmann Senior Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnati, OH 45201 Gentlemen:

Thank you for your letter dated October 8, 1980, informing us of the steps you have taken to correct the noncompliance which we brought to your attention in Inspection Report No. 50-358/80-19 forwarded by our letter dated September 19, 1980. We will examine these matters during a subsequent inspection.

Your cooperation with us is appreciated.

Sincerely, o

M '.

. F. Heishman, Chief Reactor Operations and Nuclear Support Branch cc: Mr. J. R. Schott, Plant Superintendent cc w/ltr dtd 10/8/80:

Central Files Reptoduction Unit NRC 20b AE0D Resident Inspector, RIII PDR Local PDR NSIC TIC Harold W. Kohn, Power Siting Commission -

Citizens Against a Radioactive -

Environment Helen W. Evans, State of Ohio RIII RII War 2 k/jp Heidhman 10/29/80 j[d n -., . , -

r ~y v i i I I gg n/

d) -

1.

THE CINCINNATI GAS & ELECTRIC COMPANY #y- CT"h tN . 4 CIN CINN ATI.OMoo d 5200

c. .ooacs*NN October 8, 1980

. . .. w e i '

QA-1350 U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. James G. Keppler Director RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I NRC INSPECTION REPORT NO. 80-19, DOCKET NO.

50-358, CONSTRUCTION PERMIT NO. CPPR-88 W.0. #57300-957, JOB E-5590 Gentlemen:

This letter constitutes our response to the subject Inspection Report. It is our opinion that nothing in the report or in this letter is of a proprietary nature.

Our response to the items of noncompliance, as cited in Appendix "A" of the report, are as follows:

1. Tagging of Systems Turned Over For Preoperational' Testing (a) Corrective Action Taken and'Results Achieved (1) The revision 1 to the Residual Heat Removal (RH) system release was promulgated via the correct fonn on August 25, 1980 and signed as complete by EPD on September 24,1980.

(2) A complete review and field check of the Residual Heat Removal (RH) System releases including replace-ment of missing and mutilated tags, was conducted and completed by the GCD Preop. Turnover Group on

- October 2, 1980.

(b) Corrective Action To Be Taken To Avoid Further Noncompliance (1) A complete review and field check of all essential systems' releases including replacement of missing and mutilated tags shall be conducted by the GCD/ Preop.

Turnover Group and be complete within 60 working days.

- ? 0 M \%U"

' Mr. james. G. Keppler, Director U. S. f;uclear Regulatory Commission Region 111 October 8,1980 - QA-1350 Page 2 (2) A GCD Adminstrative Procedure shall be generated for the conduct of periodic audits in accordance with SU.ACP.15 within 30 working days.

~

(c) Date When Full Compliance'Will Be Achieved Full compliance will be achieved by December 31, 1980.

2. System Releases (a) Corrective Action Taken and Results Achieved (1) Revision 4 of the Tagging Release for the Residual Heat Removal System was issued on September 23,1980 to resolve all discrepancies.

(2) As previously mentioned, a complete review and field check of the RH System was conducted and completed of all green tags on October 2, 1980.

(b) Corrective Action To Be Taken To Avoid Further Noncompliance The GCD Preop. Turnover Group is in the process of a system-by-system review of the matrix generation listing of components which require tagging. These components are to be listed on a new computer listing showing scope.

" tagged by", " witnessed by", date, reaudit date.

This item will be complete within 60 wor, king days.

(c) Date When Full Compliance Will Be Achieved Full compliance will be achieved by December 31, 1980.

3. Discrepancies Between Valve List and'S&L Drawings

, (a) Corrective Action Taken and Results Achieved 1

l (1) Valves 1E12F370 and lE12F371 are listed by the

' Mechanical Department Valve List as being shown

' on P&ID M-51-3 but do not appear. (M-51-3, Rev. L)

These valves are shown on M-53-1. This typographical error will be corrected on the nextRev.

issue of the Mechanical Department Valve List. 9, the next issue of the Mechanical Department Valve List, is i

scheduled to be issued by October 20, 1980.

l (2) Valve lE12F385B is mislabeled as lE12F386A on C&ID M-751-7, Rev. H.

Mr. ' James G. Keppler, Director U. 5. Nuclear Regulatory Commission Region Ill October 8,1980 - QA-1350 Page 3 This error has already been corrected on M-751-7, Rev. K1 dated August 15, 1980 as part of the regular design control review.

(3) Valves 1E12F396 and 1E12F397 are on C&ID M-751-11 but are not listed on the Mechanical Department Valve List.

Valves 1E12F396 and 1E12F397 are listed on Rev. 8 dated August 29, 1980, of the Mechanical Department Valve List.

(b) Corrective Action To Be Taken To Avoid Further Noncompliance Sargent & Lundy, as the overall designer of the plant, is in the best position to assure that all involved drawings and documents are revised when a change is made. Sargent & Lundy does have in-house procedures to assure that all such changes are identified and implemented. The fact that two of the three items questioned by the inspector were already implemented before the Inspection Report was received suggests that the system does work. It should be noted that the third item in the Inspection Report was a typographical error. The valve in question was actually shown on the proper system drawings.

It should be pointed out that the plant is still in the construction phase and many changes are being incorporated daily. While we realize our responsibilities for keeping documents current and correct, it is important to note that a single change may affect many documents, and unfortunately all documents are not revised at the same time; therefore, there will probably always be a lag in issuance between certain documents.

It should also be pointed out that the extent of GED design reviews has always been intended to spot check only. This has been clearly stated in procedures which have been audited by QA and also outside management auditors.

In summary, we believe that sufficient design review controls exist to minimize the occurrence or errors of this type and no further procedural controls need to be imposed.

(c) Date When Full Compliance Will Be Achieved .

We consider this area to be in compliance at this time.

l l

l

'Mr..damesG.Keppler, Director U. S. Nuclear Regulatory Consnission Region 111 October 8,1980 - QA-1350 Page 4

4. Weld Rod Control (Weld Rod Warmer Not Plugged In)

(a) Corrective Action Taken and Results Achieved In the particular instance cited where the inspector observed a portable rod warmer not plugged in, the observation was correct. Although the welder had withdrawn the rod for temporary supports, the HJK procedure does not distinguish between essential, nonessential, and temporary. Consequently, the welder was terminated for cause.

(b) Corrective Action To Be Taken To Avoid Further Noncompliance All welders have an indoctrination and training session prior to starting work on the project, with group training programs at periodic intervals. Henry J. Kaiser Company has on file a form which each welder signs informing him that violation of project rules holds the penalty of termination. The HJK Welding Engineer-ing Group performs audits daily and maintains a log. HJK has terminated welding personnel in the past for violation of work rules and will continue to do so in the future. .

(c) Date When Full Compliance Will Be Achieved This item is considered to be in compliance at this time.

We trust that the above will constitute an acceptable response to the subject Inspection Report.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY 6 K B >y_

E. A. BORGMANN f

' SENIOR VICE PRESIDENT JFW:ec c'c: NRC Resident Inspector

. Attn: F. T. Daniels O

,{]szu4

1. J* *%'o "

UNITED STATES

[

• 3 ,,, g NUCLEAR REGULATORY COMMISSION '

'. z REGION ill f .-

• k o, f 799 ROOSEVELT ROAD GLEN ELLYN,lLLINolS 60137 , 'g

% *'e .

• d' ,'

SEP 191980 Ng,1*

Docket No. 50-358 Cincinnati Gas and Electric Company ATTN: Mr. Earl A. Borgmann Senior Vice President Engineering Services and Electric Production 139 East 4th Street Oincinnati, OH 45201 Gentlemen:

This refers to the inspection conducted by Mr. F. T. Daniels of this office on August 1, 4-8, 12-15, 18-21, 25-29, 1980, of activities at the Wm. H. Zimmer Nuclear Power Station authorized by NRC Construction Permit No. CPPR-88 and to the discussion of our findings with Mr. J. R. Schott and others at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, an'd interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix A.

This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.

Section 2.201 requires you to submit to this office within twenty days of your receipt of this notice a written statement 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 compliance will be achieved.

Item 4 of Appendix A, which deals with the control of welding rods, is a repeat item of noncompliance. It appears that your previous corrective actions to prevent recurrence have been ineffective. You are therefore requested in your response to this letter to explain why there have been repetitive breakdowns in your quality assurance program in this area.

Your response should also address what additional steps are being taken to prevent recurrence.

S

Cincinnati Gas and ggyIggggg Electric Company In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room, except as follows. If the enclosures contain information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, James G. Keppler Director

Enclosures:

1. Appendix A, Notice of Violation

2. IE Inspection Report No. 50-358/80-19 l cc w/encls:

i Mr. J. R. Schott, Plant Superintendent Central Files Reproduction Unit NRC 20b AEOD Resident Inspector, RIII PDR Local PDR NSIC TIC Harold W. Kohn, Power i Siting Commission .,

l Citizens Against a Radioactive l

Environment Helen W. Evans, State of Ohio I

RII . RIII RI I RIII RIII gy l Da iel np Wa ick He;[a n h I s er .

9/17/80 9

Appendix A NOTICE OF VIOLATION Cincinnati Gas and Electric Company Docket No. 50-358 Based on the results of an NRC inspection conducted August 1-29, 1980, it appears that certain of your activities were not conducted in full compliance with NRC requirements as noted below. These items are infractions.

1. 10 CFR 50, Appendix B, Criterion V requires in part: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Wm. H. Zimmer FSAR, Section 17.1.5.1 states in part: " Activities affecting the quality of the facility are accomplished in accordance with written instructions, procedures, or drawings . . ."

Contrary to the above:

a. A revision to the residual heat removal (RH) system release for preoperational testing was promulgated without the use of the administratively controlled form prescribed in SU.ACP.15 revision 03.

b. Several instruments in the RH system were listed twice on the system release for preoperational testing which was not in accordance with SU.ACP.15 revision 03. .

c. Physical inspection of approximately 1/3 of the RH system and all the Reactor Protection System components green tagged by the system release for preoperational testing revealed that about 10% of the tags were either missing or mutilated although procedural controls in SU.ACP.15, revision 03 require periodic field checks to ascertain the installation status of green tags.

2. 10 CFR 50, Appendix B, Criterion XIV requires in part: " Measures shall also be established for indicating the operating status of structures, systems and components of the nuclear power plant, s6ch as by tagging valves and switches, to prevent inadvertent operation."

Wh. H. Zimmer FSAR, Sections 17.1.14.2 and 17.1.14.3 state in part:

"QA&S is responsible for ensuring that procedures are established which indicate the operating status of structures, systems and components . . ." and, "the procedures . . . are documented and are audited by QA&S to ensure their proper performance." -

l l

l I OA !A S OA Ik)

?

l

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Appendix A Contrary to the above: ,

a. Eight RH system valves were identified which had not been included in-the system release for preoperational testing.

b. Four RH system instruments were identified which had not been included in the sy' stem release for preoperational testing.

c. One RH system valve operator motor supply was identified which had not been included in the system release for preoperational testing.

d. Component green tags had been hung on adjacent piping rather than the component itself. Thus when the component was removed from the system for calibration, its tag remained.

3. 10 CFR 50, Appendix B, Criterion III, requires in part

" Measures shall be established to assure that applicable regulatory require-ments and the design basis, . . ., for those structures, systems and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions."

Wm. H. Zimmer FSAR, Sections 17.1.3 and 17.1.3.6.1 state in part:

"The design control reviews are conducted to ensure that the designs, . . ., are correctly translated into design documents such as specifications, drawings, procedures and instructions," and

" Documents which are reviewed by GED and audited for compliance by 4

QA&S consist of . . . GED design drawings and specifications . . .

S&L design drawings, and . . . S&L Specifications." ,

! Contrary to the above: .

a. Two valves listed in the Mechanical Department Valve List (MDVL) did not appear on the prescribed Sargent & Lundy (S&L) Piping and Instrument Detail drawing.

b. One valve was mislabeled on the S&L Control and Instrumentation Detail (C&ID) drawing.

c. Two valves shown on the S&L C&ID were not listed by the MDVL.

4. 10 CFR 50, Appendix B, Criterion XVI requires in part: " Measures i

shall be established to assure that conditions adverse to quality such as failures, 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 preclude repetition." _

Appendix A Wm. H. Zimmer, FSAR, Section 17.1.16.6 states in part: "When significant and/or repetitive conditions adverse to quality occur, they are reported to appropriate levels of CG&E and constructor-management. Action taken to correct the cause of such conditions is also reported to appropriate levels of CG&E and constructor management . . ."

Contrary to the above:

The corrective action taken to ensure control of weld rod used for welding of safety-related components has been inadequate to meet requirements of FSAR and constructors special process procedures manual, Section 3.3, Kevision 7, dated March 11, 1980, which requires weld rod warmers to be electrically energized at all times except during transport to and from the rod shack. On August 19, 1980, the inspector observed portable weld rod warmer IA-18, containing approximately 1/2 pound of low hydrogen weld rod, deenergized and unattended for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This item is repetitive of previously identified items of noncompliance in weld rod control and is indicative that previous corrective actions taken have been inadequate.

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U.S. NUCLEAR REGULAICRY; COMMISSION 0FFICE OF INSPECTION ANL EN?ORCEMENT * ' 1 REGION III

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Report No. 50-358/80-19 f ,

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Docket No. 50-358 l 4 License No. CPPR-88 Licensee: Cincinnati Gas & Electric Campanyt

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5 139 East 4th Street '

Cincinnati, OH 45201

• Facility Name: W. N. Zimmer Nuclear Power Station

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Inspection At: W. H. Zimmer Site, Moscow, OH Inspection Conducted: August 1, 4-8, 12.15,'18-21, 25-2?, 1980 l ti .

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Inspectors: F. T. Daniels /L fI , _ SrA /. ff- ##0_

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T. P. Gwynn (Observer) /

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Approved By: R. F. Warnick, Chief j

Projects Section 3 s ' '

Inspection Summary $ , '

Inspection on August 1, 4-8, 12-15, 18-21'i 25-29, 1980 (Report '

No. 50-358/80-19)

Areas Inspected: Routine resident inspection of previously identified items, bulletin and circular followup, fuel receipt and storage, pre-operational test program implementation controls, and plant tours._> -

This inspection involved a total of 152 inspector-hours onsite by,the NRC Senior Resident Inspector including.18 inspdctarrhours

onsite turing off-shifts. , , j Results: Of the five areas inspected, three were found, satisfactory, three noncompliances were identified in the area of preoperational test program (Infractions,10 CFR 50, Appendir B, Criterion III' inadequate!

design control - par. 6; 10 CFR 50, AppenHx.B, Criterion V'- failure to follow procedure SU.ACP.15 - par. 6; !0 CFE 50, Appendix E, ,, ~

Criterion XIV - inadequate measures to indicste status of components -

par. 6) and one noncompliance in the area of plant tours (Infraction -

10 CFR 50, Appendix B, Criterion XVI - repetitive failure of weld r:,d control par. 7). .i 1

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DETAILS

1. Personnel Contacted

• Ji R. Schott, Plant Superintendent

• P. E. King, Assistant Plant Superintendent D. L. Erickson,. Chemistry / Radiation Control Supervisor R. W. Link, Operations Supervisor

• J. J. Wald, Station Quality Engineer R. E. Donnellon, Maintenance Supervisor

• R. P. Ehas, Senior Quality Engineer W. W. Schwiers, Quality Assurance Manager A. Sandfoss, Junior Chemistry Technician A. Delisle, Senior Maintenance Technician K. Floyd, Maintenance Technician W. Puckett, Weld Engineer and others of the station staff.

• Denotes personnel attending monthly exit meeting.

2. Followup on Previous Inspection Findings (Closed) Noncompliance (50-358/80-08-03): Failure to identify and report a reportable deficiency within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The inspector verified the required training sessions were completed in accordance with the commitment given in the response to the l,

noncompliance.

No items of noncompliance or deviations were noted.

3. IE Bulletin Followup For the IE Bulletins listed below the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported, that the written response included adequate corrective

< action commitments based on information presentation in the bulle-tin and the licensee's response, that licensee management forwarded l copies of the written response to the appropriate onsite management representatives, that information discussed in the licensee's written response was accurate, and that corrective action taken by the licensee was as described in the written response.

(Closed) Bulletin 79-03A, Longitudinal Weld Defects in ASME SA-312, Type 304 Stainless Steel Pipe.

Piping of this type was not used at Wm. H. Zimmer.

No items of noncompliance or deviations were noted. ',

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4. IE Circular Followup For the IE Circulars listed below, the inspector verified that the Circular was received by the licensee management, that a review for applicability was performed, and that if the circular were applic-able to the facility, appropriate corrective actions were taken or >

were scheduled to be taken.

(Closed) Circular 80-02, Nuclear Power Plant Staff Work Hours.

The inspector verified this item is new being tracked and completed in accordance with NUREG-0694.

(Closed) Circular 80-03, Protection from Toxic Gas Hazards.

The inspector verified a review was conducted and protection systems for toxic gases at Wm. H. Zimmer plcat were found to be in accordance with applicable regulatory guides and FSAR.

No items of noncompliance or deviations were noted.

5. Fuel Receipt and Storage The inspector verified by inspection and document review that the storage, security, and environmental protection requirements of the Special Nuclear Materials (Sht) license, SNM-1823, were implemented and being followed.

a. Documentation Reviewed 2 NE. SAD.03, Accountability of Sht, Revision 3, May 2, 1980.

SE. SAD.03, Interim Access Control New Fuel Storage Area, Revision 6, June 25, 1980. .

NE.FHP.20, Special Nuclear Material Physical Inventory, Revision 1, April 28,1980.

SNM-1823, Special Nuclear Material License and Amendments, thereto,

b. Inspections Conducted l

The refueling floor of the reactor building (627' elevation) ~

was inspected to verify all SNM license requirements were implemented. In particular, the following requirements were I

verified:

(1) All water stations valved off and safety tagged.

(2) 150# dry chemical fire extinguisher in immediate area of the spent fuel pool.

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(3) No accumulation of combustibles.

The integrity of security controls exercised, including the following were verified:

(1) Wall continuity at the access point to the refueling floor. ,

(2) Access controls.

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(3) Storage area lighting.

(4) Security force awareness.

(5) Procedural compliance.

Environmental control measures for the fuel storage area, including the following were verified:

(1) Verification of dust and debris control.

. (2) Protection against flooding.

(3) Protection against physical damage.

c. Findings All SNM onsite is controlled and stored as required by the license.

A red tag on the isolation valve to fire station, IFP-25, was missing. The licensee replaced the red tag.

No items of noncompliance or deviations were noted.

6. Preoperational Test Program Implementation ControIs The inspector reviewed two turnover packages to verify that controls were observed for system turnover, that a schedule for preoperational testing was being maintained and kept current, that procedures and techniques used to collect water samples from safety related systems l

and perform maintenance on them was adequate, and that preventive maintenance or calibrations on systems turned over for preoperational testing had been incorporated into a schedule and were accomplished in accordance with that schedule.

The inspector made observations of the Residual Heat Removal (RH) and the Reactor Protection System (RP) to verify that these systems were green tagged consistent with the controls established in the turnover package; that controls were obcerved on turnover logs, records, or drawings prior to testing and subsequent to testing; that the collec- ,

tion and analysis of a water sample from the condensate storage tank for ph, conductivity, chlorides, florides, sulfites, and silica was

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performed in accordance with procedures; and that maintenance performed on the station 125VDC battery was performed by qualified personnel in accordance with existing procedures. .

a. Documentation Reviewed (1) SA. SAD.06 revision 8, Review, Approval, Issue, Revision, and Usage of Implementing Procedures.

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(2) SU.ACP.15 revision 3, Tagging of Systems Turned Over for Preoperational Testing.

(3) SU.PRP.01 revision 12, System Release and Turnover.

(4) SU.PRP.07 revision 01, Area Turnover.

(5) PT-RH-01, Jurisdiction Green Tagging for Preoperational Testing, Residual Heat Removal (RH) System dated April 26, 1979.

PT-RH-01, revision 01, dated June 30, 1980.

PT-RH-01, revision 01, dated July 28, 1980.

(6) Piping and Instrument Detail (P&ID) Drawings:

M-51, Residual Heat Removal System P&ID Sheet 1,* revision R dated August 10, 1978.

Sheet 2, revision P dated August 10, 1978.

Sheet 3, revision L dated January 6, 1978.

Sheet 4, revision M dated July 14, 1978.

M-81, Containment Monitoring System P&I,D Sheet 2, revision N dated November 2, 1979.

M-30, Service Water System P&ID Sheet 2, revision U dated September 14, 1979.

(7) Control and Instrumentation Detail (C&ID) Drawings:

M-730, Service Water System Sheet 3, revision F dated May 21, 1979.

M-751, Residual Heat Removal System Sheet 1, revision G dated December 19, 1979.

Sheet 2, revision C dated October 23, 1978..

Sheet 3, revision J dated December 19, 1979.

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Sheet 4, revision E dated December 19, 1979.

Sheet 5, revision D dated September 28, 1979.

Sheet 6, revision G dated June 13, 1979.

Sheet 7, revision H dated June 13, 1979.

Sheet 8, revision B dated January 27, 1978.

Sheet 9, revision D dated October 23, 1978.

Sheet 10, revision B dated February 2, 1976.'

Sheet 11, revision B dated September 7, 1979.

(8) QA. SAD.01, revision 02, Quality Assurance (9) QA. SAD.05, revision 00, QA Program for Preoperational Testing (10) SU.PRP.04, revision 05, Punchlist Item Completion and Maintenance in Turned Over and Non-Turned over Areas (11) SU.ACP.20, revision 00, Review of Completed Work for Impact on the Preoperational Test Program

(12) PT-RP-01, Jurisdictional Green Tagging for Preoperational Testing, Reactor Protection System (RP) dated February 12, 1979.

(13) ME. CMP.2.01, revision 01, Battery Cell Replacement (14) ME. CMP.2.15, revision 01, Battery Terminal Cleaning (15) ME. CMP.2.16," revision 02, Battery Cell Charging

b. Findings (1) An audit of the Green Tag List contained in the Residual Heat Removal (RH) System Preoperational. Test Release, PT-RH-01, and its revisions revealed the following:

(a) Two revisions to PT-RH-01, dated June 30, 1980 and July 28, 1980, were each designated revision 01.

This loss of administrative control was occasioned by the use of an Inter-Department Memorandum in the promulgation of the first revision 01 rather than the administratively controlled form required by the licensee procedure SU. ACP.15 revision 03. This loss of administrative control resulted in two green tags from the same system release being hung on each of the following valves: '

-1E12F348 (A&B)

-1E12F009

-1E12F303 -

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In addition, physical inspection of these valves revealed that both assigned tags were attached to each of the above listed valves except valve IE12F009, which had only one of two assigned tags attached. There was no record on the tag sheet as to the disposition of the missing tag.

(b) The following instruments in the RH system were listed

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twice on the system release PT-RH-01:

-FI1E12AR603Al

-HSIE12AS016B

-HS1E12AS016B1 (c) Physical inspection of approximately 1/3 of the com-ponents green tagged by PT-RH-01 revealed that the following tags were either missing or mutilated:

Missing

-00808 -07190 -07210

-00990 -07193 -07213

-07121 -07202 -07216

-07128 -07204 -07220

-07145 -07205 -07223 Mutilated

-00789 -00865 -00905

-00832 -00882 (d) The green tag (#09001) on IC71B-SI on 1H13-P610 of the RP system was missing.

These represent examples of failure to follow'W m. H. Zimmer administrative procedure SU.ACP.15 revision 03 " Tagging of Systems Turned Over For Preoperational Testing." These failures are considered to be in noncompliance with the requirement of 10 CFR 50, Appendix B, Criterion V, and Wm. H. Zimmer FSAR, Section 17.1.5.1, which states in part that activities affecting the quality of the facility are accomplished in accordance with written instructions, procedures or drawings. (50-358/80-19-01)

(2) Review of the RH System Piping and Instrument Detail (P&ID) and Control and Instrumentation Detail (C&ID) drawings with respect to the green tag list of PT-RH-01 revealed the following:

(a) The following valves, which are part of the.RH System, were not included on the system release PT-RH-01 or its revisions:

-1E12F061 -1E12F328

-1E12F062 -1E12F393

-1E12F084A -1E12F394

-1E12F104 (A&B) -1E12F395 (b) The following electrical instruments, which are part of the RH system, were not included on the . system release PT-RH-01 or its revisions:

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-HSIE12AS058B

-HSIE12AS035 (A&B)

-HSIE12AS036A (c) There was no tag issued by PT-RH-01 or its revisions for the 480 VAC supply to the motor operator for valve IE12F064A, although both the operator supplies for 1E12F064B and IE12F064C were tagged.

(d) Physical inspection of system instruments revealed that Instruments FTIE12-N015C and N007B had been removed for calibration but the green tags for these instruments, issued by PT-RH-01 (#07126 and #07159, respectively), were still hanging from an adjacent pipe.

The above demonstrates that the licensee's program for juris-dictional tagging, which identifies a systems' status with respect to operability and readiness for preoperational testing, is inadequately implemented and maintained. This program failure is considered to be noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion XIV, and the Wm. H. Zimmer FSAR, Sections 17.1.14.2 and 17.1.14.3 which state in part that procedures are established which indicate the operating status of structures, systems and components, and that these procedures are documented and audited by QA&S to ensure their proper performance.

(80-358/80-19-02)

(3) Further inspection of problems encountered during review of the RH system P&ID and C&ID drawings revealed the following:

(a) Valves IE12F370 and IE12F371 are listed by the Mechanical Department Valve List (MDVL) as being shown on P&ID M-51-3 but do not appear (M-51-3, revision L).

(b) Valve IE12F385B is mislabeled as IE12F386A on C&ID M-751-7.

(c) Valves 1E12F396 and IE12F397 are shown on C&ID M-751-11, but are not listed by the MDVL.

l These represent examples of a failure to maintain and review design documents which could affect station quality.

This failure is considered to be in noncompliance with the requirement of 10 CFR 50, Appendix B, Criterion III and the Wm. H. Zimmer FSAR, Sections 17.1.3 and 17.1.3.6.1 which state in part that design control reviews are conducted to ensure that the designs are correctly translated ~into design documents such as specifications and drawings, and that

. dccuments such as design drawings are reviewed by GED and audited for compliance by QA&S. (50-358/80-19-03)

(4) Several typographical errors were found in PT-RH-01 which could have resulted in green tags being attached to the wrong equipment, or in green tags not being hung at all.

These typographical errors include the following:

(a) PT-RH-01, revision 0, UY1E12K065A should be UY1E12K605A per the C&ID drawing.

(b) PT-RH-01, revision 0, ZIIE12R609B should be ZI1E12R608B per the C&ID drawing.

(c) PT-RH-01, revision 0, IE12F388C should be IE12F338C per the placard on 480VABMCC IE compartment 7D.

(d) PT-RE-01, revision 0, 480VABMCC IB compartment ID should be 480VABMCC IB compartment 11C per physical inspection.

(e) PT-RH-01, revision 0, 480VABMCC 1A compartment IA should be 480VABMCC 1A compartment 11A per physical inspection.

(5) Prior to performance of maintenance on the station 125VDC battery, the senior maintenance technician identified an outstanding revision to ME. CMP.2.01 which requires torquing of all bolts removed from the battery seismic restraints affected by cell replacement. Cell replacement was completed per the referenced procedures. However, in the process of reassembling the seismic restraints, the senior maintenance technician attempted to torque a restraint bolt to 96 ft-lb (value specified in a torque-wrench manufac-turers guidebook for mild SAE 2 steel) rather than the 27 ft-lb recommended by the battery manufacturers instruction book, resulting in bolt failure. This pro 61em was due to a lack of sufficient torque specifications in the maintenance procedure ME. CMP.2.01, revision 01. This is considered an unresolved item (50-358/80-19-04) and will be reviewed in subsequent inspections.

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7. Plant Tours The following items were observed during the frequent tours made by the NRC Senior Resident Inspector. All items were acknowledged by the licensee and except for item c, were corrected or will be corrected in '

the near future.

a. Six loose 3 amp /250V fuses were observed behind panel PM-03J in

- the control room,

b. Cable tray 4043B and cables installed in it were observed for fire damage received from a fire caused by temporary lighting bulb guard catching fire. Four cables appeared damaged and will be replaced. Also, the plastic light bulb guards are being replaced with metal guards.

c. Weld rod warmer IA-18 was observed on August 19, 1980, to be de-energized with weld rod (E-7018) contained in it. The weld rod issue form attached to the warmer was dated August 18, 1980, although weld rod warmer IA-18 was listed as missing by the welding engineers secretary since August 13, 1980. The release and check-in forms for IA-18 on August 18, 1980, showed that it was taken from the rod shack with one-half pound of E-7018 (Iow hydrogen) weld rod and returned with no weld rod. As of August 29, 1980, the warmer was not returned to the rod shack. Weld rod control has been brought to the attention of the licensee for many years and has been cited as items of noncompliance at least 11 times in the last five years; this noncompliance being the third this year. This item which is repetitive of previously identified items of noncompliance in weld rod control is indicative that previous corrective actions have been inadequate.

This was identified as noncompliance with 10 CFR 50, Appendix B, Criterion XVI (Corrective Action) and the Wh. H. Zimmer FSAR.

(50-358/80-19-05) .

d. Instrument ITI-WR106 meter face was observed to be broken.

e. Weld rod heeting ovens (W-38 and W-25) was observed to have weld rod in them shich was not segregated in accordance with loc,ation map on the dqor front.

f. Two green tags, one for 1SA-032A and one for ISA-083C, of the PT-SA-01 release for preoperational control were both attached to the valve handwheel for 1SA-082A. Also, the tag for 1SA-083C' was not filled in properly.

8. Monthly Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on August 29, 1980. The inspector t

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