ML20005A855
| ML20005A855 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/19/1981 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20005A851 | List: |
| References | |
| QA-1442, NUDOCS 8107010383 | |
| Download: ML20005A855 (5) | |
Text
o THE CINCINNATI GAS & ELECTRIC COMPANY CINCINN ATI CHIO 4 52C6 June 19, 1981 QA-1442 L A. BORO M AN N SCeseC# veCg pets.0goet U. S. Nuclear Regulatory Conmission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. C. E. Norelius, Acting U1 rector Division of Engineering & Technical Inspection RE: WM H. ZIMMER NUCLEAR POWER STATION - UNIT I NRC INSPECTION REPORT N0. 81 DOCKET NO. 50-358 CONSTRUCTION PERMIT NO.
CPPR-88 W. O. 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 tnis letter is of a proprie:ary nature.
Our resconses to the items of noncomoliance citec in Acpendix "1" c' repor 31-03 are as folicws:
31-08-01 and 02 Failure to Follow Procedures (1) Corrective Action Taken and Results Achieved These two items, dealing with failure to follow procedures, are essentially those as addressed by ippendix A Notice of l
Violation, in IE Report 81-01.
These two items were written l
against the conduct of the same preoperational test, P0-RD-02, Control Rod Drive hydraulic Preoperational Test, based upon observations made during the same testing period.
Therefore, l
the corrective actions taken as a result of the Notice of Vio-lation in Report 81-01 are also applicable to items 81-08-01 and 02 and were implemented after the stated violations (81-08-01 and 02).
To summarize, as a result of these occurrences, Revision 10 to SU. ACP.05, Conduct of Preoperational Tests, was issued.
This revision gives more explicit direction, on the use of the test procedure, reverifications of prerequisites, and the methods available to document deviations from the approved test procedure When this revision was issued, a training seminar w'3s conducted by the Test Coordina+,or for all preope-rational system engineers and staff engineers in order to ensure that an understanding of and compliance with the new requirements was achieved.
Engineers are now fully indoc-trinated in the mechanics of test conductance and conduct their tests in accordance with the procedural requirements of hiUN 2 21981 8107010 333
e To:
U.S. Nuclear Regulatory Commission June 19, 1981 Re:
Wm. H. Zimmer Nuclear Power Station Page #2 Unit 1 - NRC Inspection Report No.
81-08 Docket No. 50-358 Construction Permit No. CPPR-88 W. O. 57300-956, Job E-5590 SU.ACP.05, Revision 10.
(2) Corrective Action to be Taken to Avoid Further Noncomoliance A program of increased QA surveillance of the conduct of preoperational tests in accordance with SU. ACP.05-Revision 10, will be instituted.
(3) Date When Full Compliance Will be Achieved Full compliance will be achieved by July 30, 1981.
81-08-03 Failure to have an adequate instrumentation calibration program.
(1) Corrective Action Taken and Results Achieved Incorocrated in revision 10 of SU. ACP.05, Conduct of Precoerational Testing, are the requirements of the preoperational testing instru-ment calibration program.
Section 6.4 of SU.ACP.05 reacs as follows:
"5.4 Instrumentation Identification and Calibration 6.4.1 When instrumentation is used to:
1.
Take data to verify acceptance criteria in a preoperational test covered under Appendix A of 10CFR50...
2.
Measure or control the parameters for taking the acceptance criteria above...
3.
Measure certain parameters specified in the limits and precautions section that prevent sericus damage to equipment, (these generally i
are accepted limits of operation from technical specifications or G.E. standards such as RPV heatup rates or RPV water chemistry requirements).
The system engineer shall verify proper caliaration of the instrumentation before use in the above applications.
6.4.2 The.instruraentation used in the above applications shall be either measuring and test equipment as covered under MT. SAD.01 or installed process instrumentation.
i
To:
U.S. Nuclear Regulatory Commission June 19, 1981 Re: Wm. H. Zimmer Nuclear Power Station Page #3 Unit 1 - NRC Inspection Report No.
81-08 Docket No.
50-358 Construction Permit No. CPPR-88 W.O. 57300-956, Job E-5590 6.4.3 Verification of proper calibration of the instrumentation as addressed in 6.4.1 shall consist of:
1.
For Measuring and Test Eouipment; A.
Recording with the data in the preoperational test, the instrument name, number, calibration date and calibration due date as per the calibration sticker and assuring based on those dates that the instrument is "in calibration".
2.
For Inste.' led Process Instrumentation; A.
Recording with the data in the preoperational test the instrument name, number, and calibration date.
3.
Assuring from I1C recorcs tnat the instrument or instrument locc, as a:propriate, nas been 1000 calibrated within 18 months 7 om tne cate the data is taken.
C.
Including a copy of the loop calibradon sheets in the preoperational test results package.
6.4.4 If the instrumentation addressed in 6.4.1 is not properly calibrated, the system engineer should initiate work to have the-instrumentation properly calibrated.
Preoperational Tests listed in Attachment A are considered i
to fall under Appendix A,10CFR50.
For those preoperational tests already completed, a review of the calibration status of instrument loops used per 6.4.1 of SU. ACP.05 - Revision 10, will be conducted.
If a loop calibration time exceeds the 18 month criterion, the loop calibration will be repeated and, based upon an evaluation of the "as-found" conditions, a decision will be made as to whether or not the affected portion of the preoperational test needs to be repeated. A training seminar was conducted by the Test Coordinator for all preoperational system engineers and staff engineers in order to instruct them as to the new requirements
~
' To. U.S. Nuclear Regulatory Commission June 19, 1981 Re: Wm, H. Zimmer Nuclear Power Station Page #4 Unit 1 - NRC Inspection Report No.
81-08 Docket No. 50-358 Construction Permit No. CPPR-88 W.0. 57300-956, Job E-5590 covering instrumentation. All preoperational testing is now accomplished in accordance with these requirements.
(2)
Corrective Action to be Taken to Avoid Further Noncompliance Procedure SU.ACP.05, " Conduct of Preoperational Tests" has been revised to include the requirement that applicable loop calibration data sheets be submitted with the completed preoperational test package. The station I&C department will issue a procedure addressing loop calibration requirements.
The increased QA surveillance, identified above, will specifically check for instrument calibration status.
(3)
Date When Full Compliance Will Be Achieved Full compliance will be achieved by August 28, 1981.
We trust that the above will constitute an acceptable response to the subject Inspection Report.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY ff f _
E. A. BORGMANN GM0/ds Attachment cc: NRC Resident Inspector Att:
F. 1. Daniels State of Ohio
)ss County of Hamilton
)
Sworn to and subscribed before me this
/f day of June, 1981.
()i.. ~ Q fy, $d_L Notdry Public VE31'41A P. r :
HOFER s
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Notary Pd!L 3* :e Gt Ohio 23.1982 My Commoon Expires July
l
~IMMER PREOPERATIONAL TESTS UNDER APPENDIX A 10CFR50 PO-AP-1 PO-NB-2 PO-SC-1 PO-AP PO-NR-1 PO-SI-1 PO-AP-3 PO-NR-2 PO-TP-1 PO-AP-4 PO-NR-3 PO-TV-1 PO-AP-5 PO-0G-1 PO-VA-1 PO-AR-1 PO-PC-1 PO-VC-1 PO-CM-1 PO-PC-2 PO-VC-2 PO-DC-1 PO-PR-1 PO-VD-1
.PO-DC-2 PO-PR-2 PO-VG-1 PO-DC-3 PO-PR-3 PO-VG-2 PO-DG-1 PO-PR-4 PO-VJ-1 PO-EI-1 PO-PR-5 PO-VL-2 PO-FC-1 PO-PR-6 PO-VP-1 PO-FH-1 PO-RD-1 PO-VQ-1 PO-HC PO-RD-2 PO-VQ-2 PO-HG-1 PO-RD-3 PO-VR-1 PO-HP-1 PO-RH-1 PO-VW-3 PO-IN-1 PO-RI-1 PO-VX-1 PO-LD-1 PO-RP-1 PO-VY-1 PO-LP-1 PO-RR-1 P0-WR-01 PO-MS-1 PO-RR-2 P0-WS-01 PO-NB-1 PO-RR-3 ATTACHMENT A
. - _.