ML20003E832

Disputes NRC Caseload Forecast Panel Projected Completion Date for Preoperational Testing.Expresses Concern Re Impact on Const Completion & OL Issuance.Requests Reassessment to Earlier Date.Electric Production Dept Viewgraphs Encl

ML20003E832
Person / Time
Site:	Zimmer
Issue date:	04/09/1981
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8104170208
Download: ML20003E832 (10)

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TIIE CINCINNATI GAS & ELECTRIC COMPANY sur-CINCINN ATI. OHIO e 5208 .

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RE: WM. II . ZIMMER NUCLEAR POWER STATI iC UNIT 1 - CASELOAD FORECAST PANEL SITE VISIT

Dear Mr. Denton:

At the exit meeting held with the NRC Caseload Forecast Panel on February 26, 19 81, our Electric Production Department representatives, who are responsible for the preoperational testing program, were unable to attend. As '

a result, I did not have available at the time sufficient details to address the Panel's conclusion that the preopera-tional test program is the critical path item to completion i of the Zimmer Station or rebut the completion date projected by the Panel. Now that I have had an opportunity to review the matter with the appropriate individuals, I wanted to l express my deep concern to you about the Forecast Panel's predicted completion date of August, 1982, which is eight months beyond the Company's present estimate and wish to point out several apparent misinterpretations of data sub-mitted to the Panel on February 24 and 25 by our Electric Production Department personnel which. led to what the Company believes is an erroneous result. This data was submitted in response to the Panel's request for information as indicated in item number 8 of the Caseload Forecast Panel Site Visit Meeting Agenda.

It appears that the Panel made their projection for preoperational testing duration solely on the basis that to date 15 of 116 tests have been completed. This Panel's apparent reasoning was that, at the rate of 6 tests per month, a 17 month period would be required to complete the other 101 tests. This was converted to an August, 19 82 completion date.

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l To: Mr. Harold Denton, Director April 9, 1981 Re: Wm. H. Zimmer Nuclear Power Station Page #2 Unit 1 - Caseload Forecast Panel Site Visit It was pointed out to the Panel on several occasions that in addition to 15 completed tests, 54 tests were in progress, over half of which are more than 80% complete. When these partially completed tests are considered, a weighted total completion average of 49% results. The Panel apparently ignored this data. This information as supplied to the Panel on February 24, 19 81, in the form of overhead viewgraphs , has been included as an attachment to this letter.

During the clarifying session held on February 25, 19 81, with the Panel, our Electric Production representatives explained and described the calculational basis for reporting preoperational testing progress. A copy of the February Monthly Status Report was presented to the Panel providing additional facts and showing how our calculations are performed.

On the average, the preoperational tests in progress are about 65% complete. This equates to the equivalent of approximately 34 additional completed tests (.65 x 54). This would leave the equivalent of 67 tests not begun. Using the NRC's assumed completion rate of 6 tests per month, a remaining 11 month test duration period is computed. If the weighted completion average of 49% were used, a 10 month duration would be required to complete the remaining tests. Again, this information and discussions centering around these calculations were held with the Panel.

It should be noted that a 10 to 11 month remaining test period as calculated above, is consistent with historical test durations. Industry averages indicate 18 month preopera-tional testing programs. Using the NRC derived number of 6 tests per month, a 19 month total test period would result for l

Zimmer (116 - 6) , with 11 months remaining for completion of l the testing program.

l During testing discussions, the Panel made reference

( to the minimal size of the testing staff. Again, in the Panel's i summary report, it was noted that the testing effort would be the most difficult effort to accelerate by increased manpower because of scheduling interferences and equipment exceptions.

In regard to test personnel, we emphasize that CG&E has now

assumed overall control of the test program. We have a CG&E coordinator responsible for radwaste testing, have integrated

six (6) CG&E engineers into the testing program, and have plans I

to use approximately six (6) additional CG&E testing engineers for preoperational testing.

To: Mr. Harold Denton April 9, 1981 Re: Wm. H. Zimmer Nuclear Power Station Page #3 Unit 1 - Caseload Forecast Panel Site Visit A final point that the Panel has completely ignored is the methods and procedures currently being implemented that provide detailed scheduling tools for construction, testing, and manpower needs. One integrated schedule is being utilized on the Zimmer pruject and the construction work schedule is based on the systens startup sequence that has been in effect for over 3 years. Recent changes and improvements in scheduling methods were explained to the Panel. Considerable time was expended in making the Panel aware of the use of schedules during both the construction and testing presentations.

In our opinion, the NRC Caseload Forecast Panel has erred in its projection of the amount of testing work remaining on the Zimmer Project. Inasmuch as the Panel's date is used for a number of different purposes within the NRC and may directly or indirectly affect the ability of CG&E to complete construction and obtain an operating license, you can understand our deep concern with what we believe is a significant error in the estimate. 3ased on the information summarized above and included in the attachment, I trust our position has been clarified and will result in the Forecast Panel's reassessment to an earlier completion date.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By E. A. BORGMANN

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EAB:mjl Enclosure cc: Charles Bechhoefer James D. Flynn M. Stanley Livingston F. T. Daniels Frank F. Hooper W. Peter Heile Troy B. Conner, Jr. James H. Feldman, Jr.

James P. Fenstermaker John D. Woliver Steven G. Smith Mary Reder William J. Moran David K. Martin J. Robert Newlin George E. Pattison William G. Porter, Jr. Andrew B. Dennison State of Ohio )

County sf Hamilton) ss l Sworn to and subscribed before me this f# day of April, 1981.

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