ML19253B464

Responds to NRC 790612 Ltr Re Violations Noted in IE Insp Rept 50-358/79-28.Corrective Actions:Suppl to Spec H-228 Will Be Issued Stipulating Environ Conditions Which Must Be Met

ML19253B464
Person / Time
Site:	Zimmer
Issue date:	07/11/1979
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19253B462	List: ML19253B464 ML19253B467
References
QA-1164, NUDOCS 7910160219
Download: ML19253B464 (4)

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THE CINCINNATI GAS & ELECTRIC COMPANY arJ-CIN CIN N AT1. OHIO 4 5201 y ct Pm os se July 11,1979 QA-1164 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 IE INSPECTION REPORT NO. 79-13, DOCKET NO.

50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.0.

1. 57300-957, JOB E-55e Gentlemen:

inis letter constitutes our fonnal reply to the subject inspection report.

It is our opinion that nothing in the report or in this reply is of a proprietary nature.

The following is our response to the items of noncompliance identified in Appendix "A" of the report.

Item la. Welding Requirements As stated in your transmittal letter dated Junr: 12,1979, thi:: item requires no written response.

Item lb. Specification of Environmental Requirements for Gaskets, Sealants, etc., in HVAC Systems

1. Corrective Action Taken and Results Achieved Although the stipulation of the environmental conditions in Specification H-2298 was not explicit, it was implicit in the responsibility undertaken in both the preparation of Specification H-2298 and the evaluation of submitted bids, that the materials selected would be qualified for theii-intended use in the Zininer Station. i,  : 095 Specification H-2298 covers the gaskets, flexible connections and sealants used in conjunction with the heating, ventilating and air conditioning ductwork. The gaskets that were purchased under H-2298 are made of closed-cell neoprene rubber SCE 43 and 7%0M N g ^1 h 197D

'. Mr. James G. Keppler, Director

.U. S. Nuclear Regalatory Comm,ission Region III July'll,1979 - QA-ll64

. Page 2 are manufactured in accordance with st naard ASTM D 1056-68.

The flexible connections that were purchased under H-2298 are made of EPDM elastomer (Goodyear product E-59241-0348).

The sealant that was purchased under H-2298 is an RTV silicone elastomer General Electric product SCS 1200.

Gaskets, flexible connections and sealants are used through-out the Wm. H. Zininer Station. In the areas with the most adverse environmental conditions the materials will receive a radiation exposure of 1.8 x 107 rads and will be operating at a maximum design temperature of 1480 F. Where the materials are used in safety-related applications outside the drywell the maximum operating conditions are lower, e.g.,1 x 104 rads and 1040F. Neoprene, EPDM and silicone rubber can all operate success' ally in environments of such magnitude.

For use as a gasket materia}, neoprene can withstand radiation up to an exposure of 4 x 10 rads, based on a 40% retention of physical properties (elongation and tensile strength). Neoprene also has a high temperature range for continuous service of 1800 - 2000F. For use as a sealant, the RTV silicone can with-stand radiation up to an exposure of 2 x 107 rads, based on a 40% retention of physical properties (elongation end tensile strength). The RTV silicone elastomer has an operating tempera-ture of up to 4000F for continuous service. For use as a flex-ible connection, EPDM elastomer can withstand radiation up to an exposure of 5 x 107 rads, based on a retention of 40% of its physical properties (elongation and tensile strength). EPDM elastomer has a high temperature range of continuous service of 2500 - 3000F.

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/ materials purchased under H-2298 are thus qualified for their intended use.

2. Corrective Action to be Taken to Avoid Further Noncompliance A supplement to Specification H-2298 will be issued which will stipulate the environmental conditions which the gaskets, sealants, and flexible connections must meet.

3. Date When Full Compliance Will Be Achieved Full compliance will be achieved by August 1,1979.

Item 2 - Welding Procedure ,,

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1. Corrective Action Taken and Results Achieved The Waldinger Corporation Welding Procedure PN-33, Rev. O,

Mr. James G. Keppler, Director U. S. Nuclear Regulatory Commission Region III July 11,1979 - QA-1164 Page 3 dated May 15, 1979, was submitted to Sargent & Lundy along with the supporting Procedure Qualification Record #33 dated May 15, 1979 and Patzig Testing Laboratories Company, Inc. report for twelvt (12) reduced sections for tensile test of stainless steel to galvanized material produced by the manual, Metal-Arc welding process.

Procedure PQW-33, Rev. O, was reviewed and approved by Sargent & Lundy on June 1,1979.

The existing welds to stainless steel ductwork were made using this procedure; however, these welds have not been inspected and accepted.

2. Corrective Action to be Taken to Avoid Further Noncompliance Further noncompliance shall be avoided by the use of approved procedure PQW-33, Rev. 0, by a welder or welders qualified to the procedure in the event that additional joining of stain-less steel to galvanized material is required.

The existing welds will be inspected and any nonconforming welds will be reworked to an acceptable condition.

3. Date When Full Compliance Will Be Achieved Full compliance will be achieved when inspection has been completed and all necessary rework has been accomplished.

Item 3 - Corporate Audits

1. Corrective Action Taken and Results Achieved An audit was conducted at the site June 13-15, 1979 by represent-atives of the Waldinger Corporation Quality Assurance Department from the home office in Des Moines, Iowa. The audit report was issued on June 20, 1979 and transmitted to the WY&B Project Manager at the site. Corrective actions for the deficiencies which were identified are in process. It is estimated that corrective actions on ~the identified deficiencies will be completed by July 20, 1979.

2. _C_orrective Action to be Taken to Avoid Further Noncompliance The Waldinger Corporation Quality Assurance Department has committed to conduct annual audits of the Zimmer field operations. The next annual audit has been scheduled for the first week of June,1980.

A review of other on-site contracters reporting to CG&E will be

.en f w w qq

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Mr. James G. Keppler, Director

-V. S. Nuclear Regulatory Conr4ssion Regipn III

' July 11,1979 - QA-1164 Page 4 conducted to assure that their audit coninitments have been met.

3. Date When Full Compliance Will Be Achieved Full compliance will be achieved as of September 17, 1979.

Individual "A" We have been informed by the Waldinger Corporation that the actions requested in y ur transmittal letter of June 12, 1979 with regard to Inuividusl "A" have been completed as of July 2,1979.

We trust that the contents of this letter will serve as an acceptable response to your Inspection Report No. 79-13.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By E. A. BORGMANN VICE PRESIDENT JFW:pa 1i:: 398