ML19323F358

Responds to NRC 800402 Ltr Re Violation Noted in IE Insp Rept 50-358/80-05.Corrective Actions:Field Engineers Have Been Instructed Not to Deviate from Design Drawings

ML19323F358
Person / Time
Site:	Zimmer
Issue date:	05/06/1980
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19323F354	List: ML19323F358
References
QA-1292, NUDOCS 8005280842
Download: ML19323F358 (4)

Text

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i THE CINCINNATI GAS & ELECTRIC COMPANY ar;# EN CIN CIN N ATI CHio 4 5201 E A. BOROM ANN

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May 6, 1980 QA-1292 U. S. Nuclear Regulatory Comission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. Gaston Fiorelli, Chief Reactor Construction and Engineering Support Branch RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I IE INSPECTION REPORT NO. 80-05, DOCKET NO.

50-358, CONSTRUCTION PERMIT N0. CPPR-88, W.0. #57300-957, JOB E-5590 Gentlemen:

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

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

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

Item 1 - Inadcquate Design Control a) Corrective Action Taken and Results Achieved The hanger types based on the design table in DDC No. M-10744 had previously been installed per verbal approval by  ;

Sargent & Lundy field engineers. The verbal approval was followed up with written request for approval. A similar situation existed with the multiple branched restraint structures described in Sheet 5 of DDC No.10583. These DDC's are awaiting Sargent & Lundy approval. The hangers must be reanalyzed based on the new loads and at that time, the DDC's can be dispositioned.

b) Corrective Action to be Taken to Avoid Further Noncompliance Henry J. Kaiser Company field engineers and superintendents have j

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. Mr. Gaston Fiorelli U. S. Nuclear Regulatory Commission

. Region III Pay 6, 1980 - QA-1292 Page 2 c .i it- been instructed not to deviate from design drawings with-out prior written approval in the form of approved DDC's.

Quality Assurance surveillances will be conducted to verify compliance with this requirenent.

c) Date When Full Compliance Will Be Achieved This item is considered to be in compliance with regard to current DDC's. It is expected that this item will be in full compliance upon completion of the above described analysis by the Architect-Engineer.

Item 2 - Inadequate Document Control a) Corrective Action Taken and Results Achieved

Our architect-engineer, Sc. gent & Lundy, is reviewing all Design Document Changes referencing Specification H-2256 to verify that the reference is correct. A letter will be sent to CG&E by June 1,1980 identifying those DDC's which are not applicable to H-2256.

Those DDC's which are applicable and not yet incorporated will be added to the contents of H-2256. Those DDC's that are in process will be listed on a cover page to the specification :ndicating that they are still open.

With reference to the Sargent & Lundy Engineering Mechanics Division procedures, the interim action will consist of issuing a revision to Procedure EMT-ll to update the procedure and all charts, tables, checklists, etc., as necessary. It is expected that this action will be completed by June 1,1980. ,

i b) Corrective Action to be Taken to Avoid Further Noncompliance 1 Other Sargent & Lundy specifications will be reviewed in a similar manner to identify and incorporate DDC's, as required. I It is expected that this task will be completed by about I August 15, 1980. Future DDC's will be carefully reviewed to l assure that the correct reference is nade to the design document I affected by the DDC.

As a longer range program to control issuance and revision of the EMD procedures, it is planned that the Sargent & Lundy 1

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• Mr. Gaston Fiorelli l U. S. Nuclear R:gulatory Commission l Region III I May 6, 1980 - QA-1292  ;

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,..- Engineering Mechanics Division procedures will be incorpbrated in the Mechanical Department Standards.

An audit of the control of EMD procedures will be completed l by July 1,1980 by the Sargent & Lundy Quality Assurance Division.

c) Date When Full Compliance Will Be Achieved It is expected that full compliance will be achieved by August 15, 1980.

Item 3 - Inadequate Control of Nonconformances a) Corrective Action Taken and Results Achieved With regard to the problem of gaps between the pipes and the restraints, we are requesting Sargent & Lundy to perform an analysis to determine how large a gap can be tolerated. Where the gap in the actual installation exceeds this tolerance, the solution will be to install shims between the pipe and the support sleeve. Sargent & Lundy will be required to provide appropriate design guidance.

The actions to be taken under Item 1(a) above will assure that an appropriate design review is conducted on those installations identified which deviated from approved design drawings.

b) Corrective Action to be Taken to Avoid Further Noncompliance Instructions have been issued which state that DDC's are not permitted to be written to reflect an "as-built" condition.

If an "as-built" condition exists that deviates from design drawings, it will be handled in the form of a Nonconformance Report. The review of future DDC's by the QA Department will assure that they do not reflect "as-built" conditions that deviate from approved designs.

With regard to the hanger design details on Sargent & Lundy Drawing M-471, Sheet 39, Sargent & Lun jy will be requested to l

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Mr. Geston Fiore111 .-

U. S. Nuclear Regulatory Commission

_, Region III May 6, 1980 - QA-1292 Page 4

,' provide additional details to clarify the requirements for g ,

clearance between the pipe and support sleeve.

c) Date When Full Compliance Will Be Achieved It is expected that full compliance will be achieved by July 1, 1980.

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:pa I

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