ML19340E056
| ML19340E056 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/26/1980 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19340E052 | List: |
| References | |
| QA-1366, NUDOCS 8101060281 | |
| Download: ML19340E056 (4) | |
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THE CINCINNATI GAS & ELECTRIC COMI%NY srl
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cinciusm omo esaci EA BORGMANN W C **CS<DEht November 26, 1980 QA-1366
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U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. James G. Keppler, Director t
RE:
WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I NRC INSPECTION REPORT N0. 80 DOCKET NO.
50-358, CONSTRUCTION PERMIT 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.
Appendix "A" of the report identified two deviations from the commitments made in our response to Inspection Report No. 80-05.
Our response to these deviations is as follows:
4 Deviation Itcm #1: ODC No. M-10744 was not followed up with j
written request for e.oproval.
I Response: The INX qualification work was being re-defined at the time that Inspection 80-05 took place to incorporate new load combinations and IE Bulletin 79-02.
Based on the need for field verification for installed instrumentation supports and associated required engineering, Sargent & Lundy decided to subcontract the INX support design work to an outside consultant.
Subsequently, the work was released under Consultant Specifi-cations 105A and 105B Scope of Work.
Sargent and Lundy's review of DDC's written against INX hangers was held due to the anticipated scope of work.
When Consultant Specifications 105A and 105B were -
released to Nuclear Power Services and Nuclear Services Corporation, respectively, all the DDC's l
written against instrumentation piping supports DEC 8 120 8102 oso ggg u.
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1 Mr. James G. Keppler, Director
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U. S. Nuclear Regulatory Commission Region III November 26,1980 - QA-1366 Page 2 Deviation Item #1:(Cont'd) were included under their scope of work.
Subsequently, in mid October,1980, it was decided by 7he Cincinnati Gas & Electric Company to void all DDC's for instrumentation j
(INX) supports on the basis that the Consultant Specification 105A and 105E scope of..tork includes field verification of both piping and supports.
The scheduled completion of Co.nultant Specification 105A and 105B INX work is February 28, 1981.
The above schedule for INX supports is for all INX supports available for design work.
A t
snall percentage of the total number of INX supports may not be completed by February 28, l
1981 because of continuing work inside the primary containment, TMI changes, etc.
1 Any remaining INX supports will be promptly expedited at that time.
Deviation Item #2:
S&L did not provide appropriate design guidance on-installing shims on excessive restraint gaps.
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Response
Sargent & Lundy has performed an analysis to determine the maximum gap acceptable for instrumentation pipe supports. The tolerance has been issued on October 27, 1980 to both 1
Consultant 105A and 1058 Contractors for incorp-oration on a Specification 105A and 105B standard detail drawing.
This detail drawing is referenced on all applicable instrumentation piping support drawings to assure its incorporation.
In addition, Stop Work Order #80-10 was issued on October 10, 1980, stopping installation of all INX supports constructed to S&L M-471 series drawings, and all i
M-471 standard detail drawings were.put on hold based on the Consultant Specification 105A and 105B Scope of Work.
This assures that all new installed instrumentation supports shall he to i
certified Specification 105A and 105B drawings.
j Standard details on the S&L drawings will be l
deleted when covered by the individual support drawings issued under Specification 105A and 105B.
Mr. James G. Keppler, Director U. S. Nuclear Regulatory Commission Region III hovember 26,198C - QA-1366 Pa ge 3 Deviation ItemA: (Cont'd)
A Nonconformance Report 1s not required to document the nonconforming conditions relative to excessive restraint gaps because all INX supports are included in the redesign program and a Stop Work Order has been issued against all INX installations to S&L M-471 series drawings.
A re-evaluation of past Design Document Changes (DDC's) is not required because of the design review affecting all INX supports.
In addition, instructions were issued and a training session conducted relative to the proper use of DDC's and Nonconformance Reports.
The scheduled completion d6te for the INX redesign activity is February 28, 1981.
Your letter, dated October 3,1980, further requested a description of the management control systens for assuring that commitments for corrective actions are being accomplished as required.
CG&E Quality Assurance has established a control system for identifying commit-ments made in CG&E responses to NRC inspections. A listing is maintained by the QA Records Analyst which shows the inspection number and date, commitments, scheduled completion date for each committent, and an entry to indicate the completion of each commitment. A periodic report is issued to the various project organizations responsible for corrective action responses as a reminder to them to complete the required actions in a timely manner.
A tickler system is maintained by the CG&E QA Records Analyst to identify outstanding commitments resulting from Inspection Reports and items requiring responses. This is to assure that responses are provided and commitments are completed in a timely manner.
A memorandum has been issued by the Senior Vice President of CG&E to the various project organizations to remind them of the necessity for providing prompt responses and meeting scheduled commitments.
In addition, an indoctrination session was conducted to instruct project personnel in the requirements for preparation of responses to NRC Inspection Reports and the necessity for fulfilling, in a timely manner, the commitments made in these reports.
It is our opinion that these contrr'r should prevent further recurrence of
Mr. James G. Keppler, Director y
U. S. Nuclear Regulatory Comnission Region III November 26,1980 - QA-1366 Page 4 failure to reet scheduled commitments or to notify the NRC of changes in scheduled commitments.
We trust that the above will constitute an acceptable response to your Inspection Report No. 80-22.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY
- 27 By F o r-E. A. BORGMANN SENIOR VICE PRESIDENT JFW:pa cc: NRC Resident Inspector Attn:
F. T. Daniels