ML19320B843
| ML19320B843 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/03/1980 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19320B837 | List: |
| References | |
| QA-1303, NUDOCS 8007150108 | |
| Download: ML19320B843 (4) | |
Text
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iHE CINCINNATI GAS & ELECTk H: c:t
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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: WM. H. ZIMMER NUCLEAR POWER STATION UNIT I NRC INSPECTION REPORT NO. 80-08, DOCKET NO.
50-358, CONSTRUCTION PERMIT CPPR-88, W. O.
- 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 reply is proprietory in nature.
Our responses to the items cited in Appendix "A" of the report are as follows:
Item 1:
... The Special Nuclear Material Physical Inventory completed in March, 1980 did not include a check of new fuel bundle serial numbers."
(1) Corrective Action Taken and the Results Achieved A unit count of all new fuel assemblies was performed in March,1980, in accordance with the requirements of nuclear engineering procedure NE.FHP.20, "Special Nuclear Material Physical Inventory".
This procedure has been revised (revision 1) to require the verification of-the locations of all new fuel assemblies by serial numbers rather than by unit count. A second complete inventory of the new fuel was then conducted in accordance with the revised procedure on April 29, 1980.
No discrepancies in the inventory were observed.
(2) Corrective Action to be Taken to Avoid Further Noncompliance No further corrective action is required, iS007750)og
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L (3) Date When Full Compliance will be Achieved Full compliance has been achieved.
l Item 2:
... fuel receipt and inspection records were not properly stored in accordance with procedure RM. SAD.01, Revision 00, July 3, 1978 and a semiannual audit of special nuclear material physical inventory was not performed as required by procedure NE. SAD.03, Revision 2, June ll, 1979 step 4.1.3."
Since this infraction involves two administrative directives, the response has been so written.
RM. SAD. 0,1 (1) Corrective Action Taken and the Results Achieved All new fuel receipt inspection and inventory records were transmitted to the Document Center for microfilming.
Duplicate copies of the microfilm cartridges were sent to the 4th & Main offices of CG&E for off-site storage. Additionally, the following nuclear engineering l
procedures were revised to give more definitive instructions as'to i
the disposition of records:
NE. SAD.03
" Accountability of Special Nuclear Materials" NE.FHP.05 "New Fuel Inspection (GE 8 x 8)"
NE.FHP.07
" Inspection' Cleaning, and Movement of Unirradiated Fuel Channels" NE. FHP.10
" Post-Alteration Core Inspection and Verification" NE.FHP.20 "Special Nuclear Material Physical Inventory" (2) Corrective Action to be Taken to Avoid Further Noncompliance RM. SAD.01, " Records Management". is
.a completely revised. The revised directive will provide for more detailed guidance as to the disposition of records generated within the station. This effort is proceeding concurrent with the installation of a computerized records management system.
(3) Date When Full Compliance Will be Achieved The necessary revision to RM. SAD.01 will be completed by December,1980.
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Page 3 NE. SAD.03 It appears that the NRC inspector has interpreted the referenced section of this directive to require documentary evidence that the Nuclear Fuel-Custodian initiates audits of the SNM inventory. The inspector contends that written direction from the Nuclear Fuel Custodian was necessary to fulfill the requirement of " initiating" the audit; however, it is our position that since the audit was conducted within the six months required time frame, the Nuclear Fuel Custodian did indeed fulfill his responsibility to initiate the audit. Therefore, we believe there was no infraction since the requirements of NE. SAD.03 were not violated.
However, to eliminate this point of confusion, section 4.1.3 of NE. SAD.03 has been revised to state that the Nuclear Fuel Custodian " assures" that semiannual audits of the nuclear fuel are performed.
Item 3:
... the licensee did not identify and report to the NRC until April 18, 1980, the magnitude of the General Electric Induction Disc Relay sticking deficiency previously identified in a letter to the General Electric Company dated April 8, 1980."
(1) Corrective Action Taken and Results Achieved This deficiency was discovered during an investigation of General Electric induction disc relays for the problem described in IE Circular No. 80-01.
It was found that the GE relays of this type supplied to the Zimmer Project did have the sticking problem described in Circular 80-01. General Electric Company was notified of the problem by letter dated April 8, 1980, from the General Engineering Department, but the Quality Assurance Department did not receive a copy of the letter at that time.
A letter was written on May 1,1980 to all departments associated with the project, transmitting NRC guidance for 50.55(e) reporting and reminding them of their responsibilities for reporting such incidents under existing procedures. This was updated on flay 19, 1980 with revised NRC guidance.
(2) Corrective Action To Be Taken To Avoid Further Noncompliance An indoctrination session for all project groups will be conducted no later than June 30, 1980, covering the reporting requirements of 10CFR50.55(e).
(3) Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 30, 1980.
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We trust that the above will constitute an acceptable response to the subject inspection report.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By E. A. BORGMANN SENIOR VICE PRESIDENT JFW:ec cc: NRC Resident Inspector (Attn:
F. T. Daniels)
B. K. Culver W. D. Waymire W. W. Schwiers J. R. Schott ATT*M MOTED
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