ML20064D199
| ML20064D199 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/28/1982 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20064D160 | List: |
| References | |
| QA-1872, NUDOCS 8301040588 | |
| Download: ML20064D199 (6) | |
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THE CINCINNATI GAS & ELECTRIC COMPANY sE -
CINCINNATI, OHIO 45201 July 28, 1982 QA-1872 E. A. BORGM AN N SE Nion vect PRESIDENT U. S. Nuclear Pegulatory Ccmnission Pegion III 799 Roosevelt Poad Glen Ellyn, Illinois 60137 Attention: Mr. J. G. Keppler Begional Administrator RE:
WM. H. ZIMMER NUCLEAR POWER STATION UNIT I SYSTEMATIC ASSESSMENT OF LICENSEE'S PEREORMANCE (SALP), DATED JUNE 24, 1982 - DOCKEP NO. 50-358, CONSTRUCTION PEPMIT NO. CPPR-88, W.O. #57300, JOB E-5590, FILE NO. NBC-15 Gentlemen:
This letter serves to document CG&E's ccmnents concerning the subject Peport, as requested in your letter, dated June 24, 1982. CG&E is generally pleased with the Report and your recognition of the significant progress made during the assessment period. We have, however, noted the following and wish to make suggestions to improve the Report.
A.,Section IV.2.a
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NRC Finding:
This section of the Peport states that no inspection activity has specifically addressed the areas of Containment and other safety related structures since April 8, 1981.
CG&E Crnment:
Contrary to this statenent, Mr. D. Keating of the NRC performed inspections in this area on January 25-28, 1982. The results of this inspection are documented in I.E. Report 50-358/82-01, and no itms of nonempliance were noted.
B.,Section IV.3.a, Page 5 NBC Finding:
This section of the Report identifies nine (9) itms of nonempliance related to piping supports.
CG&E Coment:
Only three of the nine itms cited rm ain open, (50-358/80-25-06, 08 and 09). All will be cmpleted as part of the Zinner Quality Confirmation Program.
8301040588 821229 PDR ADOCK 05000358 pb 6 1962 G
- e Mr. J. G. Keppler Pegional Administrator July 28,1982, CA-1872 Page 2 C.,Section IV.3, Page 6, last paragraph NFC Finding:
I This section identifies two inspections which are construed to be I. E.
Inspections #50-358/81-17 and #50-358/82-04. 'Ihe implication is made that these reports identified licensee ccmmitments not being implemented in a timely manner.
OG&E Carment:
A review of these reports has found that the latter makes no re-ference to a lack of ccumitment implmentation. In fact, of previous open itms reviewed in 50-358/82-04, all were closed by the NPC Inspector.
In addition, CG&E has added a computerized control and tracking systcm to assure that NRC ccumitments are identified and imple-mented for I.E. Inpsection Reports, Bulletins, Circulars, Information Notices and reportable deficiencies. This is an indication that improvments continue to be made in our ocamitment control systs.
D.,Section IV.8.a NRC Finding:
1 The Ccmmission states that the licensee's ability to staff certain lower level positions, sems to be less than desired.
CG&E Ccument:
Capability to analyze events with a risk assessment /systms over-view approach has been under developrent since September,1981.
Efforts have primarily been in the area of developing fault-tree ccrputer models to analyze scme of the EOCS Systems. Four engineers are presently staffing the group involved in the risk l
assessment effort.
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Since the April 8,1981 Inmediate Action Ietter, CG&E, in addition to Quality Assurance Personnel improvments, has increased its l
technical staffs with additional fulltime engineering personnel.
These additions include nine (9) new engineers in the Nuclear Engineering Department, thirteen (13) on the Technical Staff of the Nuclear Production Department, and eight (8) in the Nuclear Services Department.
E.,Section IV.9.a NRC Finding:
This section states that docutentation of air monitoring equipTnt calibration and maintenance has been poor.
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Mr. J. G. Keppler Begional Administrator July 28, 1982, QA-1872 Page 3 CG&E Cm ment:
CG&E has found that this is based upon findings cited in I.E.
Inspection Report #358/81-24. In our response to this report, QA-1525 dated October 15, 1981, it was stated that the vendor of air samplers performs quarterly calibrations and maintains at its offices, doctrnentation of calibrations in accordance with their prescribed schedule. Copies of calibration data sheets were transmitted with our reply.
'Ib assure vendor ad-herence to their procedures, CG&E has increased its effectiveness in the areas of vendor audits.
F.,Section IV.12.a (2)
NBC Finding:
" Severity level III, 10CFR50, Appendix B, Criteria IVII:
Reports reviewed were false and did not furnish evidence of activities affecting quality.
(358/81-13-02)".
CG&E Cmment:
As stated in 03&E's February 24, 1982, response to the 81-13 Investigation Report, we strongly object to the use of the word " false" as there was no evidence of any willful intent to deceive. The acts of " whiting out" NR Log entry of a Control Number or deletion of NR's initiated in error, for example, were done only in good faith ccmpliance with estab-lished QA procedures and were certainly not attspts to falsify QA records.
G.,Section IV.12.a (3)
NRC Finding:
" Severity IcVel III,10CFR50, Appendix B, Criterion I:
Lack of sufficient organizational freedom for QC inspectors as a result of harrassment and intimidation".
CG&E Ca mcnt:
Again, as stated in CG&E's February 24, 1982 response to the 50-358/81-13 Investigation Peport, we object to the terms of "harrassment" and " intimidation".
Inspectors have freely l
indicated that their perception of activities such as dousings, l
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Mr. J. G. Keppler
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Begional Administrator July 28, 1982, QA-1872 Page 4 are representative only of typical horseplay found at any construction site. OG&E, the constructor, and collective bargaining units have all taken positive steps to limit such horseplay, which may be perceived as intimidation. As an example; on May 28, 1982, CG&E stopped all construction as a result of a dousing incident and did not restore construction until all craft personnel signed a written statement acknowledging their understanding of the criminal inplications of such actions.
l H.,Section IV 12.a (Pg. 14, Para. 3)
NRC Finding:
l "Further evidence is the fact that several recent reports relate to probles that occurred some time ago".
OG&E Cmment:
CG&E wishes to point out that the time a probl e occurs is not necessarily the same time in which the licensee becmes cognizant J
of the problem, as the above statment implies. 10CFR50.55(e) requires "the holder of the~ permit shall notify the Camission i
of each deficiency found....".
This indicates that the report-ing requirments are not imposed until the deficiency (problem) is discovered.
Furthermore,10CFR50.55(e) requires permit holders to notify the Camission of significant deficiencies in design and i
construction. Many conditions are not determined reportable until evaluations and reviews can make that determination.
t CG&E's Owners Project Procedure (OPP) 7.2 requires notification of "potentially reportable" itms as well, therefore, the procedural requirments are more stringent than those of the regulation.
I.,Section IV 12, Page 14 NBC Finding:
This section of the report makes reference to five recent itms of noncmoliance.
CG&E Conment:
CG&E received the Notices of Violation for these itms after receipt of the SALP Report, and therefore, will reserve any cmment until a fonnal response to each its is subnitted.
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Mr. J. G. Keppler Regional Administrator July 28,1982, QA-1872 Page 5 l
J.,Section IV 13.c NIC Finding:
s This section states that an independent verification of the QCP should be evaluated.
CG&E C&nent:
OG&E, as it has stated in response to recent Congressional hearings, maintains that an independent, third party program for quality l
confirmation, is not necessary. Since issuance of the April 8, 1981 Imediate Action Ietter, the Quality Confirmation Program has l
proven effective and independent of cost and schedule. 'Ihe aMition of an independent review would only add unnecessary cost and delay and would not provide any additional assurance of plant quality.
K.,Section V.B.1 NPC Fi2xling:
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...The licensee uses 10CFR50.55(e) reports for any Part 21 reports received...."
CX;&E Cmment:
A point of clarification should be made in that all Part 21 reports received are not necessarily reported under 10CFR50.55(e),
however, they are evaluated as potentially reportable deficiencies under our 10CFR50.55(e) program. It should be further noted that not all of the twenty (20) referenced reports are admittedly reportable. Sme are considered "potentially" reportable and may later be retracted. As an example, the Peport does not indicate that item (o) of this list was retracted by OG&E on January 20, 1982.
In addition, CG&E understands that the title " Construction Deficiency Reports (CRD)" means deficiencies which are subject to provisions of the Construction Permit. This understanding is significant in l
that several deficiencies were a result of inadequate vendor design, quality assurance or manufacture and are not representative of Zimer specific design or construction deficiencies.
If there are any questions you may have regarding these cc m ents, please X
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r-Mr. J. G. Keppler Begional Administrator July 28,1982, QA-1872 Page 6 contact Mr. H. R. Sager, Manager, Quality Assurance Department, Cincinnati Gas
& Electric C mpany.
Very truly yours, THE CINCINNATI GAS & ELBCTRIC 00.
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By E. A. BORGMANN SENIOR VICE PRESIDENT l
FKP:ec cc: NBC Site Resident Inspector Attn: Mr. W. F. Christianson NBC Office of Inspection & Enforcement Washington, D. C. 20555 Zimmer Project Inspector 4
Region III J
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