ML20058A389
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ENCLOSURE 2 NUL; LEAR REGULATORY COMMISSION
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o,..a April 8, 1981 Docket No. 50-358 C3ncinnati Gas and Electric Company ATTH: Mr. Earl A. Borgmann Senior Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnati, OH 45201 Gentlemen:
This refers to concerns identified during the ongoing. investigation at the Zirmer site which were discussed with you and members of your staff on March 27, 1981, by R. F. Warnick and nembers of the investigation team and which Mr. Warnick and I discussed with you on March 31, 1981, in the Region III office. The investigation began on January 12, 1981, and is expected to continue for several more weeks.
The results of the investi-gation will be documented in two or more investigation reports.
The NRC's concerns relating to on' going construction related activities are the subject of this Innediate Action Letter.
This letter documents the following corrective measures which we understand you have initiated or plan to take concerning the problems identified by the NRC:
1.
Concerning QA Staffing CG&E will increase the size and technical expertise of the CG&E QA
, organization by adding individuals qualified in the areas of radio-graphy and nondestructive testing, piping supports and hangers, welding, structural design and fabrication, electrical design and construction, and metallurgy.
We understand CG&E will utilize temporary personnel qualified in these areas until permanent staff merters have been hired.
2.
Concerning Independence and Separation Getween Kaiser Construction _
and Kaiser QA/QC CG&E will take action by April 15, 1981, to assure independence and separation of the QA/QC function performed by Kaiser from the con-I l
struction function.
Region III will be infonned of actions taken.
3.
Concerning QC Inspections Using the personnel described in item 1 above, CG&E will conduct 100%
reinspections of QC inspections conducted by Kaiser and other con-tractors after the date of this letter. This will continue until the XA Q*oodh
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-i-April 8, 1981 Cincinnati Gas and Electric I
Compary revised CG&E audit program as described in item 10,* below.'is imple-mented by these qualified individuals and R111 releases this require-ment.
Concerning QC Inspection procedures 4.
All QC inspection procedures will be reviewed and revised (where These appropriate) by qualified design engineers and QA personne organization to confirm that the procedures include appropriate inspec-The cons tion requirenents and applicable hold points.
controlled by these QC inspection procedures will not be performed after:
the date of this letter until th,e applicable procedure has been reviewes and approved.
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5.
Concerning Training QA/QC personnel at the Zimer site will receive training on any new procedures and practices resulting from actions taken to fulfill pro-visions of this letter prior to implementation of the procedures.
In addition. refresher training will be given prior to June 1,1981, on (a) the identification and documentation of nonconformances, deficien-cies, and problems (b) the procedure for resolving nonconformances, deficiencies, and problems. (c) the feedback mechanism for informing the identifying individual of the resolution of the nonconformance, deficiency, or problem, and (d) the avenue of appeal should the identifying individual disagree with the adequacy of the resolution.
Concerning Deviations from Codes and FSAR Statements 6.
Prior to May 1,1981, the procedures governing the identification, I
reporting, and resolution of deviations from Codes and FSAR state-The ments will be reviewed for adequacy and revised as appropriate.
procedures will require CG&E to review and approve the resolution of any such deviations, i
Concerning the Voiding of Hontonformance Reports 7.
The procedures governing nonconformance reporting will b The disposition of each nonconformance report together with appropriate adequacy.
. justification will be documented.
B.
Concerning QA/QC Records The review and alteration of existing QA and QC reco l
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,1 April C, 1981 ' Cincinnati Gas and Electric Co pany s
cont ~rol, usage, and adequacy has been prepared by CG&E and agreed to-by RIII.
Concerning londitions Adverse to Quality 9;
CGLE will perform a 100% review of all surveillance and nonconformance reports written by contractor personnel after the date of this letter.
This program will continue until Rlll releases this requirement.
Concernino the Audit Program 10.
The existing CG&E audit program will be reviewed and r wore comprehensive and effective programmatic audits.
Please inform us immediately if your understandi.ng of these items is different from that stated above.
Sincerely, Janes G. Keppler Director cc:
Mr. J. R. Schott, Plant Superintendent Central files Reproduction Unit NRC 20b AEOD Resident Inspector, RIII PDR Local POR NSIC TIC Harold W. Kohn, Power Siting Commission Citizens Against a Radioactive Environment Helen W. Evans, State of Ohio
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