ML20031F790

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Responds to NRC Re Violations Noted in IE Insp Rept 50-358/81-17.Corrective Actions:Technical & Quality Review Performed of Installation & Acceptance Criteria for Pipe Supports & of Field Const
ML20031F790
Person / Time
Site: Zimmer
Issue date: 09/14/1981
From: Borgmann E
CINCINNATI GAS & ELECTRIC CO.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20031F785 List:
References
QA-1486, NUDOCS 8110200428
Download: ML20031F790 (3)


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Tile CINCINNATI G AS & ELECTRIC COMI%N'Y seg N CINCINN ATI. OHIO 4 52o6 September 14, 1981 QA-1486 C. A. eORGMAN N stNiON V8CE PPtSIDtNT U~.' S. Nuclear Regulatory Commission Region Ill 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention:

Mr. C. E. Norelius, Acting Director Division of Engineering & Technical Inspection RE:

W. H. ZDIMER NUCLEAR POWER STATION - UNIT 1 NRC INSPECTION REPORT NO. 81-17, DOCKET NO. ;3-358 CONSTRUCTION PERMIT CPPR-88, W. O. #57300-957, JOB E-5590 s

l 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.

Section 2, paragraph B.1 of the subject inspection report requires CG&E to identify any significant findings resulting from the re-inspection of sixty-two (62) pipe supports, which have not been originally inspected per the revised QC program.

Our re-inspection of the sixty-two (62) pipe supports revealed that fif ty-one (51) of these supports were rejectable by the acceptance criteria of either QACMI M-12, Rev. 13. " Inspection Instructions for Pipe Hanger, Supports, and Restraints Installation" or SPPM 4.A. Rev. 9 " Visual Examination". Non-I conformance Repor*.s were initiated on the discrepant supports to affect dis-position and corrective action. Due to the excessive defect rate found on the re-inspection of the sixty-two (62) supports, a random sample of previously inspected supports was selected for re-inspection to determine the nature and cause of the deficiency and allow adequate corrective action to be determined.

As a result of the re-inspection efforts, the following actions have been taken, or are planned:

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U. S. Nuclear Regulatory Commission QA-1486 September 14, 1981 Page 2 (Item 1)

The installation and acceptance criteria for pipe supports contained in specification 11-2256 " Specification for Erection of Phase II Piping and Mechanical Equipment" has undergone a complete techninal and quality review by Sargent & Lundy and Cincinnatt Cas & Electric Company.

The revised installation and acceptance criteria has been released by Sargent & Lundy for i.uplementation.

(Item 2)

QACMI M-12 and associated field construction procedures shall be revised to comply with the latest specification acceptance criteria. Revision of these procedures is scheduled for completion no later than September 30, 1981.

(Item 3)

Following the revision of QACMI M-12, to incorporate the latest acceptance criteria, all esset, fal and seismically designed supports, which were inspectec and accepted prior to implementation of Rev. 13 of QACMI M.'2 will undergo a complete re-inspection. All essential anu seismically designed pipe supports, which were inspected and accepted by the acceptance criteria included in Rev. 13 of QACMI M-12 shall be evaluated to determine if any rework or re-inspec-tion is necessary based on the revision to the acceptance criteria. Rework and re-inspection will be performed where necessary; based on that evaluation.

It is anticipated that the rework and re-inspection of those hangers required by the modification of the acceptance criteria, will be accomplished by l

February 1, 1982.

l Section 3, items A and B of the inspection report identified two items of noncompliance, 358/80-25-08 and 358/80-25-09, regarding review of voided NR's and review of those NR's which were voided by DDC's.

Review of these NR's have now been included as part of the Quality Confirmation Program which was committed to the NRC in letter QA-1476, dated August 21, 1981. Corrective Action to be taken, and the full compliance date will be in accordance with the Quality Confirmation Program. Revision 13 to QACMI G-4 has included the pro-visions to prohibit the disposition of NR's by issuance of DDC's.

This procedure was issued effective June 11, 1981.

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U. S. Nuclear Regulatory Commission QA-1486 September 14, 1981 Page 'l Item C identified an item of noncompliance, 358/80-25-06, regarding the addition of Reactor Control, Inc. (RCI) to the QA audit schedule. Sub-sequent to the inspection, RCI was replaced by Sargent & Lundy Engineers as the contractor to perform this analysis. S&L has been placed on the CG&E audit schedule, and no further audits of RCI need to be conducted due to this change in contractors.

Item E identified two inspection reports, 50-358/80-16 and 50-358/80-25, regarding review and revision of CG&E and HJK procedures. This item is being addressed as part of CG&E activities in response to your Immediate Action Letter dated April 8, 1981. Revision of HJK QA Manual is anticipated to be complete by September 30, 1981. The Phase II review and revision of procedures as a result of the Immediate Action Letter is scheduled to be complete by January 30, 1982.

We trust the above will constitute an acceptable response to the subject inspection report.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY

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E. A. BORGMANN SENIOR VICE-PRESIDENT HRS /DJS/ms cc: NRC Reeldent Inspector Attn:

W. F. Christianson State of Ohio

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Sworn to and subscribed before me this //A day of September, 1981.

k Yi Notaggggj g g,9LUERSEN Notary Puuic, State of Ohio My Commission Espires June 7,1986