ML20071N234

Documents Util Interpretation of Requirements for Personnel Qualifications of Individuals Performing Data Collection for Seismic Analyses for as-built safety-related Piping Sys,Per IE Bulletin 79-14

ML20071N234
Person / Time
Site:	Zimmer
Issue date:	09/10/1982
From:	Borgman E, Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
IEB-79-14, QA-1940, NUDOCS 8209270407
Download: ML20071N234 (2)

Text

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=.y CINCINNN .OHto 4520t September 10, 1982 QA-1940 E. A. BQROMAN N st.sion vect Patsiot Nr U. S. Nuclear Regulatory Commission Region 111 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J. G. Keppler Regional Administrator RE: WM. H. ZIMMER NUCLEAR POWER STATION UNIT 1

1. E. BULLETIN #79 DOCKET No. 50-358 CONSTRUCTION PERMIT NO. CPPR-88, W.O.

1. 57300, JOB E-5590, FILE NO. NRC-10 Gentlemen:

The purpose of this letter is to document CG&E's interpretation of the requirements for personnel qualifications of individuals per-forming the data collection for the seismic analyses for as-built safety related piping systems in accordance with I. E.Bulletin 79-14.

I. E.Bulletin 79-14 states in part: ". . .For portions of systems which are normally accessible, inspect one system in each set of redundant systems and all nonredundant systems for conformance to the seismic analysis information set forth in design documents. . ."

The 79-14 program at Zimmer consists of a process of measurement and engineering evaluation. Individuals collecting measurement data are contracted through the NUS Company. The term " inspection", as used in the 79-14 bulletin is not taken to mean the definition stated in ANSI N45.2.10, " Quality Assurance Terms and Definitions," which defines

" Inspection" as "A phase of quality control which by means of examination, observation or measurement determines the conformance of materials, supplies, components, parts, appurtenances, systems, processes or structures to predetermined quality requirements."

B209270407 820910 g ll

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• Mr. J. G. Keppler U. S. Nuclear Regulatory Commission Region III September 10, 1982 - QA-1940 Page 2 Because the individuals collecting the data are not making a determination of "conformance. . .to predetermined quality require-ments," they are not required to be certified inspectors in accord-ance with ANSI N45.2.6, " Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants." 79-14 personnel collect the required data and forward the measurements to the architect / engineer for evaluation. This data collection effort does not require making judgement as to acceptance or rejection, therefore, this process does not involve quality assurance " Inspection."

Uc trust the above will be found as an acceptable interpretation of this terminology.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY

_ = - =

E. A. BORGMANN SENIOR VICE PRESIDENT FKP:as cc: NRC Office of Inspection & Enforcement Washington, D.C. 20555 NRC Senior Resident Inspector Attn: W. F. Christianson Zimmer Project Inspector Region III