ML20023C693

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Requests That Work Activities Not in Violation of 821112 Order to Show Cause & Order to Immediately Suspend Essential Const Be Allowed to Continue.Activities to Be Performed Listed
ML20023C693
Person / Time
Site: Zimmer
Issue date: 01/07/1983
From: Borgmann E
CINCINNATI GAS & ELECTRIC CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20023C690 List:
References
EAB-SOL-11, NUDOCS 8305170553
Download: ML20023C693 (5)


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THE CINCINNATI GAS & ELECTRIC COMPANY W

CINCINN ATi, OHIO 4:5201 January 7, 1983 EAB-S0L-ll E. A. SOROMANN PRif1CIPAL STA.FF 1

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U. S. NUCLEAR REGULATORY COMMISSION "Te l

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799 Roosevelt Road 5EffoT Glen Ellyn, Illinois 60137

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Mr. J. G. Keppler

-0L FILE l4/zy Regional Administrator RE:

Wm. H. Zimmer Nuclear Power Station - Unit 1 WORK REQUEST AFTER SHOW CAUSE ORDER OF NOVEMBER 12, 1982 Docket No. 50-358 Construction Permit No. CPPR-88 W. O. 57300 Job E-5590 File 956 Gentlemen:

The Cincinnati Gas & Electric Company wishes to continue certain work activities which do not violate the spirit of the November 12, 1982, Show Cause and Order of Immediate Suspension of Essential Construction.

CG&E would like NRC review and concurrence of the following items prior to their performance:

1.

OPERATIONAL PROGRAMS USED TO SUPPORT & CONTROL ACTIVITIES Station Directive SA. SAD.01 Instructions for SAD's SA. SAD.04 Station Procedures SA. SAD.06 Review, Approval, Issue &

Revision of Implementing Procedures EC. SAD.01 Equipment Control EC. SAD.02 Safety Tagging EC. SAD.03 Jumper & Lifted Wire Control EC. SAD.04 Caution Tagging EC. SAD.05 Work Requests EC. SAD.07 Cleanliness Control EC. SAD.08 Housekeeping MT. SAD.01 Control of Measuring & Test Equipment 8305170553 830506 PDR ADOCK 05000358 A

PDR m 13 1983'

Mr. J. G. Keppler EAB-50L-11 January 7, 1983

. Page 2 2.

INSTRUMENT CALIBRATION Continuing calibration of instruments, including loop calibration, set point adjustment, maintenance of recorders, etc., on turned over systems.

This activity would assure that hardware is calibratable; electrically checked from sensor to relay, recorder, or other device; power supplies are properly connected; baseline data connected; calibration procedures functionally proven and correct; set points adjusted, etc. Maintenance of instrumentation and control schemes providing a protective service (eg. low suction pressure trip on fire pump) is included under this activity.

t Previously identified directives would control this activity and, in addition, other. implementing procedures such as calibration procedures are utilized. These procedures are reviewed and approved in accordance with the previously listed directives as well.

Electronic Printed Circuit Boards (PCB's) require maintenance, trouble shooting and modification.

In some cases, removal of the PCB and replacement with a new board completes the tasks.

In other situations, the PCB is removed, faulty components replaced and the board reinstalled. Other occurrences may involve returning the PCB to the vendor for repair and upon return, reinstalling it in the logic circuit.

Again, controls for work are as per Item 1.

The Preoperational Testing Manual specifies controls for systems in preop test status.

3.

CORRECTIVE MAINTENANCE ACTIVITIES FOR PROTECTION OF EQUIPMENT Work must be performed on equipment and components to protect and/or preserve those in operation. This work is conducted under the Item 1 controls and under the surveillance of the Operations QA organization.

Examples of such work are shown per the attached copies of Work Requests (WR's) generated by plant personnel and which would normally be performed by plant maintenance personnel.

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EAB-S0L-ll January _7,1983 Page 3 I

4.

FLUSHING Flushing of non-essential systems turned over from construction and in support of the preop. program. Removal, installation, replacement, reinstallation, etc., of temporary strainers, hoses, piping, etc., is controlled thru the Work Request procedure, startup program procedures, approved flushing procedures, appropriate engineering review and supervision.

Flushing of essential systems will be handled on a case by case basis.

5.

PRE 0PERATIONAL TESTING (Case by Case basis) i Certain preoperational tests, especially those tests. involving electronic or electrical logic. Conduct of testing, including QA, is performed in accordance with the preoperational testing manual, approved procedures and operational QA.

i 6.'

EQUIPMENT OPERATION Periodic and/or routine operation of equipment to support preventative maintenance, or to support plant safety.

Examples include operation of service water, closed cooling water systems, fire pumps, valves, etc.

i 7.

SPECIAL TESTING (Case by Case basis)

Using the guidance of SU.ACP.17, "Special Tests", special tests of components, systems or partial systems would be conducted.

8.

SPECIFIC MAINTENANCE TASKS a.

Service Water Pump Modification l

A generic pump problem was identified on or about March,1979, and vendor modifications proposed and approved. Two (2) pumps have been sent to the vendor, repaired, returned, reinstalled, and tested. One pump remains at the vendor where modifications are being performed. This work was completed or begun months prior to the issuance of the Show Cause Order. An appropriate 50.55 (e), M-13, has been submitted.

When the pump is returned, the plant storeroom will receive the component. Operations QA will be involved in receipt inspection, including review of vendor documentation.

Station maintenance personnel would reinstall and test the pump in accordance with work controls outlined in Item 1 Approval is sought to perform the above upon return of the pump from the vendor. Any ASME interface work will be performed by the H. J.

Kaiser Company.

Mr. J. G. Keppler EAB-SOL-ll

January 7,1983 Page 4 8.

SPECIFIC MAINTENANCE TASKS (Continued) b.

Service Water Structure Air Compressor A new non-essential compressor has been purchased for the service water bubbling system and has been temporarily set up outside the structure.

Since the machine is not designed for outdoor, winter service, it has been moved inside the building.

The compressor is skid mounted and has not been permanently mounted to the floor. The temporary electrical feed was disconnected at the motor - not at the MCC - and reconnected at the motor, under control of the Jumper & Lifted Wire Directive.

The Work Request will be held open until all temporary connections have been removed and permanent installation will be done using approved design documents at a later date.

c.

Service Water Strainer Backwash System Work on an ASME Section III valve in the backwash line was begun prior to receipt of the Show Cause Order.

This is a flanged ball valve and exhibited erosion due to the erosive nature of the water. Proposed work includes replacement of the valve; or a design modification using another means of isolating and controlling backflush; and, repairing and replacing piping downstream of the Section III valve (non-ASME Section III piping).

Any ASME interface work will be performed by the H. J.

Kaiser Company.

9.

PUNCHLIST COMPLETION ON NONESSENTIAL SYSTEMS TURNED OVER FOR PREOP TESTING The listed systems, all turned over for preoperational testing, have outstanding punchlist (PL) work requiring completion prior to final testing being accomplished. All Punchlist work, except electrical work on associated cables, would be performed by Catalytic using their work procedures and work controls established by the Startup Manual.

The systems turned over for preoperational testing include the following:

AS-1 CP-1 OT-1 WF-3 WW-1 CB-1 CW-1 SH-1 WG-2 WX-1 CD-1 DV-1 T0-1 WG-3 WX-2 CD-2 HD-1 WE-2 WM-1 WY-1 CL-2 MC-1 WF-2 WT-1 WZ-1 CL-3 The above systems listed by turnover package, are nonessential.

We would like to work these systems for all Punchlist items, except electrical work on " associated" cables.

', ! Er. J. G. Kippler

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  • EAB-50L-ll January 7, 1983 Page 5 10.

50.55 (e) ITEMS (C,ase by Case basis)

Work associated with components and items identified by a 50.55(e) where commitment dates have been specified and material has been procured.

Final NRC review and concurrence of 50.55(e) items is requested on a case by case basis.

11. WELDER QUALIFICATION Qualify welders in accordance with the Catalytic approved program and the applicable codes and standards in support of non-safety related work.
12. WELD PROCEDURES Develop, qualify, approve and implement any additional weld procedures required to support on-going non-safety related work.

A prompt reply to this request would be appreciated.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY w <-

E. A. Borgmann Senior Vice President JCH: rem cc: NRC Office of Inspection and Enforcement Washington, D. C.

20555 NRC Senior Resident Inspector Attn:

W. F. Christianson T

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