ML20082H589
| ML20082H589 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/23/1983 |
| From: | Williams J CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| LOZ-83-0239, LOZ-83-239, NUDOCS 8312010217 | |
| Download: ML20082H589 (4) | |
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TIIE CINCINNATI GAS & ELECTRIC COMPANY CINCINNATI.OHto 45201 November 23, 1983 LOZ-83-0239 J. WILLIAME JR
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Attention:
Mr. J.G. Keppler Regional Administrator Gentlemen:
RE:
WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 COURSE OF ACTION W.O.
57300, JOB E-5590,~ FILE NO. 956C, Reference (a) - NRC letter f rom J.G. Keppler to W.H. Dickhoner dated November 21, 1983.
Reference (a) states that the Course of Action proposed for the verification of the quality of construction and the completion of construction cannot be approved with the Henry J.
Kaiser Company (Kaiser) performing the role of constructor as described therein.
Accordingly, we have decided to reallocate the responsibilities described in the Course of Action.
Bechtel will assume the responsibilities of the constructor under this reallocation in addition to their role as Project Director.
Kaiser will remain onsite in a limited capacity for the time required to ensure a smooth transition of specific construction responsibilities.
Kaiser's role will be limited to that absolutely necessary to provide the data they require to certify the status of the ASME Section III systems and components for which they have the Code responsibility.
This activity will be performed under the PVOC program.
The end product of the efforts in this area, which will be conducted under Bechtel's close supervision, will be:
An identification of those ASME Section III systems, portions of systems, and components that conform to ASME requirements.
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m Mr. J.G. Keppler Regional Administrator November 23, 1983 LOZ-83-0239 Page 2 An identificaticn of all systems, portions of systems and components which include nonconformances. (deficiencies to the code).
These nonconformances will be appropriately documented as a part of this process.
From this'information, Kaiser will prepare the applicable Code Data Report (NS, NPP1 or accepted equivalent) for all systems, portions of systems and components for which they have code responsibility.
Any deficiencies will be listed on the Data
. Repr t.
A code agreement for the transfer of responsibility from Kaiser to Bechtel will be developed and agreed to by Kaiser, Bechtel, their respective ANI's, CG&E and the State of Ohio.
This agreement will establish the procedures and methods to be utilized to prepare these Code Data Reports and will provide the basis for the performance of work by Bechtel including preparation of the N5_ Data Reports for the completed systems.
In managing the Kaiser activities described above, Bechtel will:
Provide one-on-one supervision of Kaiser OA/QC personnel in the conduct of visual and physical inspections of systems and components.
Manage, supervise and control' the access to and review of documents needed by Kaiser in connection with their ASME Section III related responsibilities.
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Provide the criteria and procedures for document review I
and visual and physical inspections of ASME Section III systems and components.
Kaiser will be solely responsible, under their NA and NPT Certificates, for preparing the Code Data Report for fabrication and installation work under their responsibility.
However, as a
- part of PVQC, Kaiser will make no independent decisions regarding the criteria for' conduct of reviews and inspections!or the 4
j determination of whether a system, portion of a system or component is conforming.
This task will be directed by Bechtel.
' When there is a question as to whether a system, portion of system or component is conforming, i t will be listed as nonconforming.
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E Mr. J.G. Keppler Regional Administrator November 23, 1983 LOZ-83-0239 Page 3 Bechtel will be responsible for correction of all nonconformances, completing the systems in accordance with ASME Section III requirements, and providing complete code data reports (N5).
To this and they will immediately take the neceesary steps to establish their Certificates of Authorization for the Zimmer. site. - Bechtel will prepare their Quality Manual for the performance of work under ASME Section III and will request an ASME survey to obtain the necessary site certificates.
This process will take approximately 6 months, however, work can commence under the Bechtel corporate NA and NPT Certificates of Authorization once the Quality Manual and implementing procedures are in place.
Under this approach, physical work could begin in January 1984, which is also the current scheduled date for CCP approval.
Preparation for the formal ASME survey including presurvey audits can be performed in parallel.
After 2-3 months of physical work, the formal ASME survey can be performed for the extension of the corporate NA and NPT Certificates of Authorization to the site.
The technical representative for the Department of Industrial Relations for State of Ohio (National Board of Boiler and Pressure Vessel Inspectors) will audit the turnover, as proposed, and will continue to audit the ASME Code activities until completion.
The above mentioned objectives have been submitted to the representative of the Department of Industrial Relations for the State of Ohio (National Board of Boiler and Pressure Vessel Inspectors) for further consideration.
Those other non-ASME code related functions in the Course of Action which are assigned to Kaiser will be performed by Bechtel.
During the transition period Kaiser will also be responsible for turnover of construction drawings and support information, close j'
out of open purchase orders and contracts, and the completion of necessary accounting tasks.
Construction or installation work and all related activities will be performed directly by Bechtel.
The Course of Action-currently provides for an independent audit of the PVOC.. We will expand this audit to cover the QA/QC aspects of the CCP so that all QA/QC activities through completion of the plant are subject to an independent audit.
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Mr. J.G. Keppler Regional Administrator November 23, 1983 Loz-83-0239 Page 4 4
We believe the action described above will meet the concerns of your letter, reference (a).
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY Y!!:l::=
By a
. WILLIAMS, JR. g SENIOR VICE PRES DENT GCF/sfr cc:
NRC Office of Inspection & Enforcement Washington, D.C.
20555 NRC Resident Site Supervisor ATTN:
W.M. Hill NRC Zimmer Project Inspector, Region III ATTN:
E. R. Schweibinz NRC Office of Nuclear Reactor Regulation ATTN:
D.G. Eisenhut L.L. Kintner
..