ML19350D318

Responds to NRC 810303 Ltr Re Violations Noted in IE Insp Rept 50-358/80-25.Corrective Actions:Revised QA Manual & QA Instruction Book to Clarify Personnel Authorities & Responsibilities.No Proprietary Info

ML19350D318
Person / Time
Site:	Zimmer
Issue date:	03/26/1981
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19350D317	List: ML19350D318
References
QA-1410, NUDOCS 8104150211
Download: ML19350D318 (8)

Text

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hl HE CINCINNATI GAS & ELECTRIC COMPANY am CINCINN AT1. OHIO 4 5201 March 26, 1981 QA-1410 C. A BORGMANN Stesson vsCE PetSiDEM U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J. G. Keppler, Director RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I IE INSPECTION REPORT NO. 80-25, DOCKET NO.

50-358, CONSTRUCTION PERMIT NO. 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 proprietary in nature.

Our responses to the items of noncompliance listed in Appendix "A", Notice of Violation, are as follows:

1. Inadequate Design Information in Sargent & Lundy Specification H-2832 (a) Corrective Action Taken and Results Achieved As a result of the inspection, Sargent & Lundy (S&L) has revised Specification H-2832, by issuance of Supplement 5, to define the loads, acceptance criteria, and methods of combining the design loads. Criteria for auxiliary steel design is included in the specification. All RCI pipe support drawings are reviewed by S&L prior to release for fabrication. This assures that the main structure steel is adequate for the applied loads.

(b) Corrective Action to be Taken to Avoid Further Noncompliance The Project Manager of S&L shall conduct a training session with the appropriate S&L design personnel to emphasize the importance of definition of design loads in specifications.

He will identify those specifications where design interface and applicable design criteria is required and have reviews conducted of applicable specifications.

810415 03M5

Mr. J. G. Kepplero Director U. S. Nuclear Regulatory Commission Region III March 26, 1981 - QA-1410 Page 2 (c) Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 1, 1981.

2. RCI QA Manual Lacks Identification and Description of Organizational Interfaces and Personnel Responsibilities (a) Corrective Action Taken and Results Achieved The Reactor Controls, Inc. Quality Assurance Manual has been revised to clarify personnel authorities and responsibilities. Personnel responsibilities are also delineated in a new Reactor Controls, Inc. QA Instruction, QAI-1, entitled " Organization". External and internal interfaces are the subject of two QA Instructions, QAI-3-1, entitled " Interfaces Between Engineering and Stress Analysis", and QAI-3-3, entitled " Design Interface with Subcontractor".

(b) Corrective Action to be Taken to Avoid Further Noncompliance It is expected that periodic review and update by RCI of the documents referenced in 2(a) will avoid further noncompliance.

All sections of the RCI QA Manual have been-reviewed by CG&E to assure compliance with Appendix "B" requirements.

(c) Date When Full Compliance Will Be Achieved Full compliance has been achieved.

3. Incom)lete Procedures, Instructions and Drawings for Installing the CRD Suspension System

, (a) Corrective Action Taken and Results Achieved l

The Reactor Controls, Inc. Quality Assurance Instruction Book has been revised and includes approved procedures covering installation and inspection of component supports.

These procedures include applicable regulatory or other requirements.

(b) Corrective Action to be Taken to Avoid Further Noncompliance

, Future construction or modification of the CRD system has been assigned to Henry J. Kaiser Company, using the Henry J. Kaiser Company approved procedures which are currently in use for the l installation of station suspension systems. Other procedures prepared by RCI have been reviewed for adequacy, and are judged to be acceptable.

i Mr. J. G. Keppler, Director U. S. Nuclear Regulatory Commission Region III March 26,1981 - QA 1410 Page 3 (c) Date When Full Comr~ lance Will Be Achieved Full compliance has been achieved.

4. Inadequate Inspection of Suspension System Components by RCI (a) Corrective Action Taken and Results Achieved RCI has been assigned responsibility for the walkdown of the CRD pipe configuration, stress analysis, and redesign if required, of all CRD supports. Therefore, all CRD supports are presently indeterminate and an NR has been written to identify the generic deficiency.

After release of the stop work order now in effect, Henry J. Kaiser Company will be directed to perform a 100%

inspection of the CRD suspension system components, using Henry J. Kaiser Company inspection procedures and acceptance criteria. Action will be taken on a case-by-case basis to correct deficiencies.

(b) Corrective Action to be Taken to Avoid Further Noncompliance Future installation on the CRD system has been assigned to Henry J. Kaiser Company.

(c) Date When Full Compliance Will Be Achieved Full compliance will be achieved after the installation of the CRD system supports.

5. RCI Lacked a Qualified Procedure for Welding Pipe Hangers Constructed of P-1000 Unistrut (a) Corrective Action Taken and Results Achieved Corrective action for this noncompliance is being controlled by Nonconfomance Report No. 7550, which is currently being processed. Processing is expected to be completed by May 1,

1981.

i RCI has rewritten its welding procedures to include this material, I and has qualified a procedure for welding P-1000 Unistrut for their applications.

l t

Mr. J. G. Keppler, Director U. S. Nuclear Regulatory Conmission

. Region III March 26, 1981 - QA-1410 Page 4 RCI has prepared a book of instructions, which includes Procedure QAI-8-2, entitled " Installation of Component Supports", dated December 4, 1980. Procedure QAI-8-2 includes reference to the ASME Boiler te Pressure Vessel Code,Section III, Subsection NF, whicn requires quali-fication of welders and welding procedures.

In addition, the RCI QA Manual, Rev. 4, Section 5, dated October 31, 1980, states "all welding shall be accomplished using qualified procedures and qualified welders or welding-operators".

Results achieved will be evaluated after NR No. 7550 has been dispositioned and approvals obtained.

(b) Corrective Action to be Taken to Avoid Further Noncompliance It is expected that RCI compliance with QA program requirements and procedures will avoid future noncompliance. It should be noted that RCI's contract with this licensee for physical construction is complete.

(c) Date When Full Compliance Will Be Achieved Full compliance is expected by May 1, 1981.

6. Inadequate Licensee Audits of RCI (a) Corrective Action Taken and Results Achieved An audit of RCI's Quality Assurance Program and procedures has been performed at the RCI Corporate office. The audit resulted in three (3) findings and seven (7) unresolved items. The unresolved items and corrective action for the audit findings will be examined to verify implementation of corrective action.

(b) Corrective Action to be Taken to Avoid Further Noncompliance Upon resumption of CRD piping reanalysis by Reactor Controls, Inc., an audit will be scheduled at the RCI Corporate head-quarters. RCI will be added to the Quality Assurance audit schedule, which shall be reviewed to assure that audits of applicable vendors are scheduled.

Mr. J. G. Keppler o Di rector U. S. Nuclear Regulatory Comission Region III March 26, 1981 - QA -1410 Page 5 (c) Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 1, 1981 upon completion of review of the audit schedule.

7. Lack of Implementation of Effective Corrective Action Measures (a) Corrective Action Taken and Results Achieved Additional QC personnel have been added to the HJK inspection organization and assigned to specific active work areas of the plant. This will assure that timely inspections of construction activities are conducted as work progresses. If generic deficiencies are identified timely corrective action will be implemented.

Documentation of the inspections shall be submitted to HJK Quality Engineering group for review as work is completed.

If deviations from inspection requirements are identified during the review, they shall be corrected imediately.

Additional training in inspection and documentation reviews will be provided which will assure a more timely and effec-tive identification of activities requiring corrective action.

Personnel of CG&E previously assigned to the HJK organization have been reassigned to the CG&E Quality Assurance Organization so that increased audits and surveillances can be performed.

(b) Corrective Action to be Taken to Avoid Further Noncompliance Additional Quality Assurance Engineers or technicians shall be employed by CG&E as part of the permanent QA Department staff, to increase the overall CG&E QA effectiveness. HJK plans to hire additional qualified personnel to reemphasize the necessity for compliance with procedures, project requirements and implemen-tation of the HJK QA program. A training session shall also be provided for cognizant personnel to reemphasize the necessity for compliance with procedures, project requirements and implementation of corrective actions.

(c) Date When Full Compliance will be Achieved Full compliance will be achieved by July 1, 1981.

8. Voiding of Nonconformance Reports (NR Not in Accordance with 0ACMI G-4, Revision 7 (a) Corrective Action Taken and Results Achieved After IE Inspection 80-25, Stop Work Order 80-13 was issued to halt the voiding of NR's. Revision 8 to QACMI G-4 was

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Mr. J. G. Keppler, Director U.S. Nuclear Regulatory Commission 6 Region III March 26, 19 81 - QA-1410 Page 6 subsequently issued to provide more precise control of this voiding of NR's. Based on an improved pro-cedural control of voiding NR's the Stop Work Order was rescinded.

The Henry J. Kaiser Company in response to a CG&E audit has initiated a complete review of voided NR's.

A report to CG&E QA on this review is expected by April 30, 1981.

(b) Corrective Action to be Taken to Avoid Further Noncompliance As part of the revision to QACMI G-4, the authority for voiding NR's has been limited to the Henry J.

Kaiser Site Quality Assurance Manager. In addition, when NR's are superceded by a later revision, they are no longer stamped " Void" but are properly marked

" Superceded" with the revision number identified.

CG&E will verify the implementation of the corrective action in response to the audit referenced in "a" above.

(c) Date When Full Compliance Will Be Achieved Full compliance will be achieved by May 15, 1981.

9. Voiding of NR by Issuance of Design Document Change (DDC)

(a) Corrective Action Taken and Results Achieved HJK QACMI G-4 has been. revised, approved and issued as referenced in previou's item 8.

Instructions have been issued to prohibit the disposition of NR's by issuance of DDC's. During the review of voided NR's , which was referenced in Item 8(a) , those which were voided by issuance of a DDC will be evaluated and appropriate action implemented.

(b) Corrective Action to be Taken to Avoid Further Noncompliance It is felt that the corrective action taken in (a) will prevent further noncompliance.

(c) Date When Full' Compliance Will Be Achieved Full compliance will be achieved by May 15, 1981.

1

Mr. J. G. Keppler, Director U. S. Nuclear Regulatory Commission Region III March 26,1981 - QA-1410 Page 7 The following information is provided in accordance with your request to identify the management actions that we have taken or plan to take to improve the effectiveness of the quality assurance program implementation with regard to small and large bore piping activities:

1. Quality assurance and construction management staffing is being increased to provide more control and surveillance over support activities. Additional pipe support Construction Engineers have already been assigned both in the Henry J. Kaiser and the Cincinnati

Gas and Electric Company construction organizations. A qualified pipe support Quality Assurance Engineer has been added to the Cincinnati Gas & Electric Quality Assurance organization. In addition, personnel are being reassigned to increase their objec-tivity, provide more expertise where needed, and to improve the management corrective action systems.

2. The documents and procedures that are used to implement the quality assurance program are being arranged and revised where necessary to create a hierarchy of procedures with a coherent pattern and consistent requirements. A review of the Cincinnati Gas and Electric Company and Henry J. Kaiser Company Quality Assurance Manuals and quality assurance procedures has already been completed and the required revisions are in process. As described in our letter dated February 2, 1981 modifications to existing procedures will be completed and approved by April 15, 1981.

3. The frequency of quality assurance audits, surveillances, and in-spections has been increased. This increased frequency will be maintained until it is determined that the quality assurance progrem

implementing procedures are adequate and that they are being adhered to.

4. Additional training is being provided. This training reemphasizes the quality assurance program requirements and covers the modifi-cations to the quality assurance manuals and procedures described in item 2 above. Tnis training will be given to the personnel responsible for implementing the program on large and small bore pipe supports and to those personnel affected by the procedural modifications. This training will be completed by May 30, 1981.

In addition, an independent qualified organization has provided training to pipe support inspectors in requirements of AWS Code Welding Inspection Techniques.

We believe that these actions are appropriate and that they will result in an effective quality assurance program.

In Appendix "A" of your letter dated March 3,1981, you reference Section 17.2 of the Wm. H. Zimmer Nuclear Power Station Final Safety Analysis Report.

We would like to bring to your attention that Section 17.2 covers the oper-ational quality assurance program and is not applicable to the small and large bore piping construction activities.

r 1 i

Mr. J. G. Keepler, Director U. S. Nuclear Regulatory Commission Region III March 26, 1981 - QA-1410 Page 8 i

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 RLW:ec cc: NRC Resident Inspector Attn: F. T. Daniels -

State of Ohio )

County of Hamilton ) ss Sworn to and subscribed before me this a24 day of March, 1981, h, b_* - SNie}Yf-Notfhy Public ,_ , "--. gryta y;n,; , , r .

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