ML20072M579
| ML20072M579 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 03/21/1983 |
| From: | Dickhoner W CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20072M539 | List: |
| References | |
| NUDOCS 8304010321 | |
| Download: ML20072M579 (11) | |
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THE CINCINNATI GAS & ELECTRIC COMPANY est- '
CINCINNATI. OHIO 45201
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JRINCIPAL STAFF March 21, 1983 Vps MF Jll!A.
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U.S. Nuclear Regulatory Commission p
Region'III s
799 Roosevelt Road 3L Glen Ellyn, Illinois 60137 bk I FlLE A Attentieru Mr. Jaa.es G. Koppler Regional Ac'ministrator Gentlemen:
Ee:
Wm. H. " dis;ner Nuclear Power Station, Unit 1, Order to Show Cause End Order Immediately Suspending Construction, Docket No. 50-358 Enr.:losed is Ttirrey Pines Technology's response to your letter to me of Marda 16, 1983 requesting additional information relative to the propocal by Torrey Pines Tech-nology to conduct the independent management review of the Zimmer project.
With regard to Question 7, our response is as follows:
The Cincinnati Gas & Electric Company has neither requested nor have there been any discussions with Torrey Pines Technology by The Cincinnati Gas & Electric Company regarding the possibility of future assignments or services on the Zimmer project in addition to the independent management review.
Yours very truly, THE CINCINNATI GAS & ELECTRIC COMPANY D~e W.
H. Dickhoner WHD:vm Enclosures 8
g8 MAR 231983 f$k4hhl O A
st" RECEIVED W.H. DICK 898El TORREY PINES TECHNOLOGY RO. Box 85608 San Diego, Califomia 92138 Telephone: (619) 455-2654 MAR 21 19831 A Dnnsson of GA Technologies Inc.
I FILE March 18, 1983 TPT:CG&E-001 Mr. W. H. Dickhoner President and Chief Erect.tive Officer Cincinnati Gas aad Electric Company 139 East Fourth Streat Cincinnati, Ohio 45202
Dear Mr. Dickhoner:
Tcreey Pines Technolo67 (TPT.) is pleased to proviale the encloses reponses to NRC's request for additional information en TFT's prepomi for inde-pendent review of Zin:mer 1 NPS Project Management.
Please contact me at (619) 455-2580 or George Wessman (619) 455.1654 if you have any questions concerning thess responses.
Sincerely,
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j A. J. Neylan Project Manager Copy:
Mr. J. G. Keppler - NRC MAR 231983
IN REPLY FEM A. J. Nwn.u REFER.TO 2474.002:03 Proj. 2474 TO Distribution DATE 3/9/83 Rev. A 3/11/83 StBJECT Project Directive No. 2 Rev. B 3/18/83 Independence of Individeals The project requires that individuals involved in this program will be free of substantive conflict of interest.
Substantive conflict of interest is defined as:
1.
For key personnel, any work experience or association with the iiilliam H. Zimmer Nuclear Power Station (Zimeer), or with the Cincinnati Gas &
Electric Company (CG&E).
2.
Current activity on any other Zimmer or CG&E work or work for any of the other participants in the Zimmer 1 project.
l 3
For personnel other than key project personnel, with past Zimer or CG&E work experience or association within the past three years, a level of effort on this project which exceeds a half time level for the duration of the project.
4.
An immediate family member who is employed by CG&E or any of the other participants in the Zimmer 1 project, 5.
A cumulative ownership and creditor interest in CG&E or any of the other part,1cipants in the Zimme.r ' project which exceeds 5% of their gross family annual income.
Support personnel including secretaries, report editors and typists, graphic artists, draf tsmen, and project schedules are not included in these restrictions since they are not in a position to influence the program review and its results.
To demonstrate compliance with the conflict of interest requirements all individuals assigned to work on this project shall fill out the attached Forms 2 and 3 All previous versions of F.orms 2 and 3 are to be discarded and replaced with the new forms attached.
The Task Leaders shall be responsible for obtaining the completed forms from the individuals and return them to my office.
There are three notary publics in the Legal Department who can notarize Form 2:
Brenda Dawson (X-2124), Lori Rogers (X2170), and Joanne Rojek (X-2124).
ms Distribution S. D. Bresnick T. R. Colandrea L. D. Johnson G. L. Wessman S. J. Brown K. Dance R. E. Vollman P. Yensuang F. D. Carpenter M. Gitterman A. A. Schwartz
FORM 1 PERSONNEL GUIDELINES FOR PROJECT 2474 In order to qualify as an independent reviewer for the Management Review of the Zimmer 1 Nuclear Plant Project (TPT Project 2474), all personnel assigned to the project must comply with the following:
1.
Key project personnel shall have no present or past work experience with the Zimmer 1 plant or with Cincinnati Gas & Electric Company (CG&E).
2.
Project personnel shall not be active on any other current CG&E plant or CG&E work, or those of any of the other participantse in the Zimmer 1 project.
3 Project personnel, other than the key perscnnel, with prior work exper-i ience relating directly to Zimmer 1 or CG&E within the past three years shal3 not participate on this project at a level of effort that exceeds a half time lepel for the duration of the project.
Q, No pecject personnel shall have nenaers of their family" who ara em-ployed by CG4E or the other participants in the dasign or construction of Zimmer 1.
S.
During the term of tnia project no project personnel shall have cumulativo ownership interest in CG&E or the other participants in Zi:nmer i vhich exceeds 5". of their grcss family annual income.
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'For these purposes, the other participants in tne Zimmer 1 project are:
Columbus & Southern Ohio Electric Company Dayton Power & Light Sargent & Lundy Kaiser Engineers General Electric Company
- For these proposes a family member is defined as one of the following:
Spouse Stepbrother Son-in-law Child Stepsister Daughter-in-law Stepchild Stepmother or, if related by Mother Stepfather blood:
Father Mother-in-law Uncle Grandparent Father-in-law Aunt Brother Brother-in-law Nephew Sis ter Sister-in-law Niece Grandchild
W FORM 2 PROJECT 2474 PERSONNEL QUESTIONNAIRE After first being duly sworn hereby deposes and sayst (print or type name) 1.
I have no work experience relating to Zimmer 1 Nuclear Power Station (Zimmer) or Cincinnati Gas & Electric Company (CG&E), or for any of the other participants' in the Zimmer 1 project except as noted an the reverse side.
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2.
No member of my family'# is presently employed by CGLE or any of the other participants engaged in the design or construction of Zimmer 1 except as identified on the reverse side.
3 I have no financial interest in CG&E or any of the other participants except as notad on the reverse side.
'For these purposes, the othee participants in the Zimmer 1 project are:
Columbus & Southern Ohio Electric Company Dayton Power & Light.
Sargent & Lundy Kaiser Engineers General Electric Ccepany
- For these purposes a family member is defined as one of the following:
Spouse Stepbrother Son-in-law Child Stepsister Daughter-in-law Stepchild Stepmother or, if related by Mother Stepfather-blood:
Father Mother-in-law Uncle Grandparent Father-in-law Aunt Brother Brother-in-law Nephew Sister Sister-in-law Niece Grandchild I hereby affirm that the above is true and correct to the best of my knowledge.
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(signature)
(date)
Subscribed and sworn to before me on this day of 1983 1
My commission expires:
Notary Public
)
FORM 3 PROJECT 2474 PERSONNEL AGREEMENT I
(print or type name) hereby agree that:
1.
I will treat all information revealed to me in the course of my work on this project as confidential and will not disclose it to others not involved in the project except as directed by the Project Manager or my task leader.
2.
I will notify the Project Manager if during the term of tb13 project I, or anj member of my family #*
acquire any financial interest in Cincinnati Gas & Electric or any of the other participEnts' in the 7.immer 1 project.
' Tor these purposes, the other participants in the Zimmer 1 project are:
Coluabus & Southern Ohio Electric Company Daytor. Focer & Light Sargent & T.endy Kataer Engineers General Electric Comfany
For tr.ese purposes a family member is defined as one of the following:
5pouse Stepbrotter Son-in-law Child Stepsister Daughter-in-law Stepchild Stepmother or, if related by Mother Stepfather blood:
Father Mother-in-law Uncle Grandparent Father-in-law Aunt Brother Brother-in-law Nephew Sister Sister-in-law Niece j
Grandchild (signature)
(date) l l
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RESPONSE TO NRC'S REQUEST FOR ADDITIONAL INFORMATION ANSWERS TO QUESTION NO. 1 The scope of work in each of the recently completed independent design and construction reviews of four nuclear plants (San Onofre, Palo Verde, Shoreham, and Waterford) is given below.
San Onofre Torrey Pines Technology (TPT), a division of GA Technologies, Inc. (GA) ws.s engaged by Southern California. Edison Company (SCE) to conduct an indepen-dent review of tne seismic desig for SCE's San Onofre Units 2 and 3, including an assessment of the effectiveness cf the quality sssurance program for design.
The pecgram was structured to verify that the dt. sign procca adequately converted the sciamic design basis specified in the Final Safety Analysis Report (PSAR) irtto the design documents that were transmitted to the con-structor or the fabricator. All proaaduree asce in the design process were reviewed to determine that the basic faocess was adequate.
A seleation of points was reviewed to ensure that the procadures were indsed implemented as they should have been.
Finally, a selection of design documenti, which are the pecducts of the design process, was t.schnically reviewed.
This entire program, taken together, gave a discerning basis on which the adecuacy of the seismic design was judged.
Two aspects of the construction process were also reviewed.
The plan for field audits and the as-built configuration of a segment of pipe were reviewed.
In this program, 40 manuals and 2100 documents were reviewed, and some 33,000 checks were made of procedural implementation.
Over a four-month period, approximately 177 man-months were applied to this program.
Palo Verde l
l TPT was engaged by Arizona Public Service Company (APS) to conduct an i
independent quality assurance evaluation of the Palo Verde Nuclear l
Generating Station (PVNGS) Units 1, 2 and 3 in the areas of organization, management, quality assurance, design, and construction activities.
i i
Response to NRC's Request for Additional Information Page Two The program was structured to evaluate whether the APS nuclear project management organization, policies and quality assurance program have been adequately and appropriately structured, organized and implemented, from project organization to fabrication and construction, to assure that the high quality standards expected of nuclear power plant design and con-struction have been met.
The review effort included technical review of selected safety-related features and physical verification of selected construction and installation details.
All work was done in accordance with a program plan which was prepared early in the program and approved by the Nuclear Regulatory Commission (NRC).
The program reviewed the activities of APS, Bechtel Power Corporation (BPC) and Cohbustion Engineering Corporation (C-E).
Over 1500 documents were reviewed, and over 15.000 checks were made of procedural implementaticn.
Over a six-month period, approximately 102 man-months of effort were i
applied to this program.
Shoreham TPT was engaged by Long Islend Lighting Company (LILCO) to conduct an independent review of the construction of LILCO's Shoreham llualea.r Power Station.
The review, conductcd May through September -1982, reviewe:I the complete construction process beginning with procurement of itams according to design requirements (the d3 sign requirements were assumed to be adequate for purposes of this review) and traced the activity through final con-struction inspection and turnover to startup. The review also included an assessment of the effectiveness cf the quality assurance (QA) program for construction (those actions taken during the construction phase to ensure a product of adequate quality).
l The program was structured to determined whether the construction process i
converted the specified design requirements into sound plant systems.
Procedures used in the construction process were reviewed to determine if the basic process was adequate.
A selection of specific components was reviewed to ensure that the procedures were indeed implemented as they i
t should have been.
Finally, a selection of hardware and systems that are the products of the construction process was physically inspected to l
determine if the product as constructed met design requirements.
The i
entire program taken together provided a discerning basis on which to judge j
the adequacy of construction.
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Response to NRC's Request for Additional Information Page Three An on-site contingent of 60 engineers and technicians applied more than 33,000 manhours to this program during a four-month period.
The program included reviewing more than 11,000 documents, inspecting more than 6000 components and structures, and checking about 150,000 documentation and hardware particulars (individual facts, points, circumstances, or details).
Waterford TPT was engaged by Louisiana Power and Light (LP&L) to conduct an indepen-dent design review of the Emergency Feedwater (EFW) System for the Water-ford 3 Sten Electric Station (Waterford 3 SES).
The program was structured to evaluate if the desig;n control process for the EFW system was adequate and properly converted the design basis specified in the FSAR into a design that meets requirements.
The review included the relection of a portion of the EFW installation to vsrify the construction conforns to the requirements of the design drawings and specifications.
The review established the associated design activities cf LP&L, Ebasco Services Incorporation (Ebasco), Combustion Engineering Corporation (CE),
Dravo and Bergen-Pate: son (B-P).
Over 660 documents were reviewed, and over 2300 checks were made of procedural implementation.
The program involved 38 man-months effort for a period of six months.
i In cddition to the foregoing recent independent reviews, GA hes direct construction project management experience with a number of types of nuclear fcilities.
As a division of GA, TPT will utilize the corporate resources developed on the projects as appropriate.
Fort St. Vrain GA was responsible for overall management of the construction of the 330 MW Fort St. Vrain nuclear power plant, provided to Public Service of Colorado en a turnkey basis.
Responsibilities included design, licensing, con-struction, A/E and constructor interfacing and control, preoperational testing, and cost and schedule control on the plant.
TRIGA Research Reacytors GA has supervised construction and initial startup of over 80 TRIGA research reactors around the world.
Response to NRC's Request for Additional Information Page Four Nuclear Fuel Fabrication Facility GA managed the design, co'nstruction, startup3 and current operation of the HTGR fuel fabrication facility on GA's San Diego site.
Personnel GA personnel have experience in various phases of design, construction, licer. sing, startup, and operation of numerous domestic and military nuclear pown facilities.
ANSWER TO QUESTION NO. 2 A quality ansurance pecgram document (QAPD) will be prepared specifically for this TPT project to dafice tne qual.f ty assurance program for the project.
It will identiPy the cr.3anizatio-al structure and key personnel i
and idsntify the interfwn between TFT and CG&E.
The QAPD arill define how the NRC-approved GA QA manual in applied for this TPT project.
Elements of the GA CA Lanual and cross references to 10CFR50 Appendix "B" will be identified.
hequiremnts for instructicns and pro-cedures, document control, audits control # noneottformance, corrective action at;d QA records will ce specitiid.
ANSWER TO QUESTION NO. 3 The proposal statement that less than $100,000 annual revenue had been received over the past two years was based on the fact that no significant revenues had been identified at the time of the proposal.
A detailed review of financial records since the proposal has shown that zero revenue was received by GA from CG&E, Columbus & Southern Ohio Electric Company, Dayton Power & Light, Sargent and Lundy, or Kaiser.
Revenues of $102,700 were received from General Electric Company in 1981 for fabrication of a demineralizer vessel that was not for the Zimmer project.
1982 revenue from General Electric was zero.
GA has not been able to identify any contacts with any companies relating to the Zimmer project over the life of the Zimmer project other than the general marketing contacts to present our engineering service capabilities that were described in the proposal.
A general presentation on radiation monitoring systems was made to S&L in the 1977 timeframe.
However, this was not specific for Zimmer, nor did it result in a request for bid on the Zimmer project.
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O Response to NRC's Request for Additional Information Page Five ANSWER TO QUESTION NO. 4 An example of the statement of independence that each individual involved on the Zimmer management review will sign is attached.
These statements will be filed under oath or affirmation.
The statements will address the additional five companies as well as CG&E, as listed on page 5 of TPT's proposal.
Work experience will be related to all six companies and not limited to the last three years.
ANSWER TO QUESTION NO. 5 All personnel, including those referred to on Fig. 2 of TPT's proposal as
" independent reviewers" will complete the independent statements in 14 above.
The responsibilities and contribution of any personnel havir4 previously performed work for CG&E viil be limited as stated in TPT's propcsal.
At this date, none of tne staff expected to be assigned to this project has any prior work experience with CG&E cr on Zimmer.
We will notify you of our intent prior to using at.y such people on this project.
Ah5W3R TO QUESTION NO. 6 We affirm that all ccomunications between TPT and CG&E uill conform to the
" Protocol Governing Cc=n:nunications Betwet:a CG&E and Independent Organi-i zations C'enducting Reviews or Audits under the Commission's Order" which was transmitted to CG&E by letter dated March 2, 1983 We confirm that TPT han separately received s copy of the Protocol from NRC.
ANSWER TO QUESTION NO. 7 CG&E has not requested TPT to perform any services on the Zimmer Project in addition to the independent management review, nor have there been any l
discussions between TPT and CG&E regarding that possibility.
Attachment i
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