ML19309F763

Responds to NRC 800215 Ltr Re Violations Noted in IE Insp Rept 50-358/79-37.Corrective Actions:Pipe Support Insp Program Revised & Generation Const Dept Requested to Prepare Procedure for Preparation,Distribution & Revision of Dept

ML19309F763
Person / Time
Site:	Zimmer
Issue date:	03/18/1980
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19309F757	List: ML19309F763
References
QA-1272, NUDOCS 8004300604
Download: ML19309F763 (1)

Text

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,O THE CINCINNATI GAS & ELECTRIC COMPANY M" A3i sE "N CINCINN AT1.OMIO 45209

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March 18,1980 QA-1272 U. S. Nuclear Regulatory Commission -

hagion III 799 Roosevelt Road

, Glen Clyn, Illinois 60137 s

Attention: Mr. Gaston Fiorelli, Chief Reactor Construction and Engineering Support Branch RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I l NRC INSPECTION rep 0RT NO. 79-37, DOCKET NO.

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

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

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

The following are our responses to the items of noncompliance identified in Appendix "A" of the subject report.

1. Pipe Support Inspection Program (a) Corrective Action Taken and Results Achieved All safety-related large bore piping support installation has been stopped until an acceptable inspection program is developed.

All work previously inspected and accepted by the CG&E Generation Construction Department Hanger Inspection Group shall be reinspected by the Henry J. Kaiser Company QC inspection organiza-tion.

-(b) Corrective Action to be Taken to Avoid Further Noncompliance The pipe support inspection program will be revised to include the MAR 241980 i

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Mr. Gaston Fiorelli U.S. Nuclear R:gulatory Consnission Region III March 18,1980 - QA-1272 Page 2 l

followino requirenents: -

. 1) Include much mort: detailed inspection instructions 1 and check sheets.  ;

2) Require inspection innediately after the work is done.

3) Be totally independent of the construction management. l This program was discussed by the CG&E Quality Assurance Manager with

- NRC representatives at the Region III Offices on March 7,1980. The i connents provided by the NRC will be included in the final edition of l the inspection program. l (c) Date When Full Compliance will be Achieved This activity will be in compliance by April 18, 1980 at which time the inspection program will be implemented.

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2. Use of Inter-0ffice Correspondence (a) Corrective Action Taken and Results Achieved  !

All site organizations which issue procedures have been contacted by letter, dated March 18, 1980, and reminded that inter-office correspondence may not be used to change work procedures. Such changes may be issued only with proper reviews and approvals.

l (b) Corrective Action to be Taken to Avoid Further Noncompliance The QA&S procedures will be revised to include a provision for issuing interim directives to implement a change in procedures when an ininediate change is required. Such changes shall be incorporated in a fonnal revision to the procedure within a prescribed period of time. Instructions have been issued to other site organizations to prepare procedures incorporating requirements for preparation, approval, revision, and control of work procedures including requirements for implementation of interim or temporary changes. l l

(c) Date When Full Compliance will be Achieved It is anticipated that full compliance will be achieved by April 30,1980.

fCAR 2 41980 l

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Mr. Gaston Fiorelli U. S. Nuclear Regulatory Comission Region III March 18,1980 - QA-1272 Page 3

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3. Inadequate /rotection for Hydraulic Snubbers l

(a) Corrective Action 73 ken and Results Achieved l All snubbers, excluding E-Systems snubbers, inside the Primary l Containment have been removed and placed in controlled storage.  !

The snubbers that were installed in other areas, but due to ,

their location may be subject to damage, have been removed and placed in controlled storage. Protective covers have been installed on all fluid indicators.

to) Corrective Action to be Taken to Avoid Further Noncompliance Instructions have been issued to Henry J. Kaiser Company construction supervisor to take notice of any missing protective l covers and have them replaced as soon as possible. CG&E Field QC personnel were instructed, on March 18, 1980, to connence immediately to conduct periodic surveillances to verify compliance.

All snubbers will be cleaned and inspected prior to release from the contmlled storage ama.

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

4. Inadequate Licensee Cormctive Action s (a) Corrective Action Taken and Results Achieved The corrective actions outlined in Items 1, 2, and 3 above are believed to be adequate to address the recurring noncompliances with regard to the pipe support inspection pmgram,. use of inter-office correspondence, and protection of hydraulic snubbers.

An inspection was conducted by the CG&E Quality Assurance Department of the Generation Construction Department files relative to the issuance and control of work procedures. It was found that:

(1) On December 28, 1979, a memorandum was issued by the Manager of Generation Construction Department to all recipients of Generation Construction Department procedures requesting them to acknowledge receipt of

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procedures issued to them and indicate any that were missing.

(2) All acknowledgements were returned with recipients indicating which pmcedures, if any, wem missing.

(3) Replacement procedures were issued on January 8,1980 to those requiring them to bring their files up-to-date.

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. Mr. Gaston Fiore111 U. S. Nucle:ar Regulatory C; mission Region III s March 18,1980 - QA-1272 Page 4 i

(b) Corrective Action to be Taken to Avoid Further Noncompliance The Generation Construction Department has been requested to pmpare a procedure for the preparation, distribution, and revision of their department procedures.

(c) Date When Full Compliance will be Achieved -

Full compliance will be achieved by April 18, 1980.

We trust that the above will constitute a satisfactory msponse to the items of noncompliance cited in your Inspection Report No. 79-37.

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