ML19280B557
| ML19280B557 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 09/17/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML19280B555 | List: |
| References | |
| NUDOCS 8112080190 | |
| Download: ML19280B557 (10) | |
See also: IR 05000358/1980009
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON D. C. 20555
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September 17, 1081
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NEMORANDUM FOR: Chairman Palladino
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FROM:
William J. Dircks
Executive Director for Operations
SUBJECT:
JULY 30, 1981 OIA REPORT, *SPECIAL INQUIRY RE: ADEQUACY
OF IE INVESTIGATION 50-358/80-9 AT THE WILLI AM a. ZIMMER
NUCLEAR POO R STATION"
Enciesed are the DIE comments relat've to the OIA investigative findings.
I
would like to specifically direct your attention to the enclosed weld chron-
ologies.
Clearly, these welds had been identified and placed in a corrective
action system prior to Applegate's involvement.
I believe the OIA report summary (page 2) best characterizes the safety issue.
"One of Arplegate's main allegations was that defective welds in
safety-related systems have been accepted, ' * * . By virtue of
prior IE inspections " ' ', it is clear that Region III was well
aware of the chronic and long history of welding problems at
Zimmer: specifically, that unacceptable welds in safety-related
systemt had for all intents and purposes been accepted by both
the contractor and, in some cases, the licensee. Based upon
these inspections, Region III required the licensee to rereview
radiographs and reports of all welds which had been accepted for
turnover prior to operation; this review started in October 1979
and portions of this review are still being studied by Region III."
It appears to be irrelevant to debate whether or not the welds had been
accepted; the pertinent fact is that the welds were in a system to obtain
corrective actio".
I am cot Gdent that the aggregate of licensee and NRC actions would have
-2 :'I' C.resalted in edestate welds prior to the operation of this plant, irrespective
of Applegate's involvement.
'7 O :: 2. P.
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Williaa J. Dircks
Executive Director for
Operations
Enclosures:
1.
Office of Inspection and Enforcement Comments
2.
Held Chronologies
cc: See Page 2
8112090190 811116
ADOCK05000g8
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Chaint.an Palladino
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cc: Comissioner Gilinsky
Commissioner Bradford
Comissioner Ahearne
Com ssioner Roberts
SECY
OPE
OIA
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Enclosure 2
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CY 6CE is a weld in the Cycled Ccndensate System. located in the tank area.
The
line'is sixteen inches in dianeter (weld is 5D.26 inches of weld metal).
Design conditions for this line are 35 psig and 140 degrees F.
Maximum
operating conditions are also 35 psig and 140 degrees F.
This line is S&L
piping Class B.
CHRONOLOGY
07/ /76
Weld fit-up.
07/ /76
Weld performed.
07/15/76
.
07/16/76
RT read, reject 0-13, 13-26, unconsumed insert.
07/16/76
Approvals on WED No. 1.
07/19/76
R1 readed, FT of grinding - accept, weld performed.
07/21/76
Approvals for WRD No. 2.
07/23/76
Ground area, PT accept, weld pe-formed.
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07/26/76
RT performed.
07/26/76
RT read, reject 0-12, 12-24, incomplete fusion.
07/27/76
Approvals for WRD labeled No. 2. ',
07/29/76
PT - accept.
08/02/76
RT for information only
reject.
08/04/76
PT reject
grind through & adjacent area, crack in weld edge.
08/09/76
RT performed.
08/03,'76
RT read, 0-12 rejected.
08/10/76
KEI approval of above RT report.
08/10/76
Approvals for WR0 labeled No. 3.
08/10/76
PT test of area - accepted.
08/11/76
08/11/76
RT read - rejection areas 0-12 (Peabody-Magnaflux Personnel).
08/12/76
P-M rejection overriden by M. Low - accept weld.
08/13/76
Gamma plugs CY606GP, 606 CPS, 606GP welded, PT accept.
- 01/13/77
S&L audit of radiography, areas 8-12 rejected for surface
indications and linear indications.
- 01/21/77
NR-E-633, documents above finding, grind out defect and reweld.
- 02/11/77
Approvals on disposition of NR-E-633
04/14/77
04/15/77
Approvals on WRD labeled 3A.
06/08/77
RT of area in 3A 0-13, 13-26 accept.
06/08/77
RT read and approved.
06/20/77
ANI review and approval of above RT.
- 06/24/77
NR-E-633 closed.
07/19/77
Gamma plug re-welded, PT accept.
- 10/10/79
NES Review Begins
- 10/12/79
NES review - technique and documentation deficiencies.
- Significant information not in 01A Chronology.
Received RIII 9/15/81 THOMP15(C)
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- 01/02/80
Applegate told acceptance of CY 606 improper.
(Daily Report)
- 03/03/80
Applegate interviewed by Phillip.
0 /07-r9/80
Phillip onsite.
"10/03/80
NR-E-5172 based on NES findings for CY-606 and several adjacent
- 10/27/80
Disposition of NR-E-5172, accept as is, A. Lanham.
"11/07-12/80
Approvals on NR-E-5172.
- 11/12/S0
NR-E-5172 closed.
- 12/17/SO
Re< Oaker notation on NES documentation review checklist form
(closecut).
- 5ignificant information not in OIA Chronology.
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WR- K- 511
WR- K- 516
(WR-K-E27)
(WR- K-916 )
(WR-K-917)
WR-K-511 and WR-K-827 were welds on the Auxiliary Building Closed Cooling
Water System.
Weld WR-K-516, on the same line, is still in existence.
WR-K-916, WR-K-917 are replacement welds.
Weld WR-K-S11 was located in the
Auxiliary Building at elevation 572'
The line is 4 inches in diameter (weld
was 12.56 inches of weld metal).
Design conditions for this line are 120 psig and 105 degrees F.
Maximum
operating conditions are 150 psig and 125 degrees F.
The line is S&L
piping Class C (final visual inspection only, not normally radiographed).
CHRONOLOGY
08/ /77
Approvals for production of WR-K-516
11/08/77
Consumable insert placement and tack weld WR-K-516.
11/09/77
WR-K-516 welded, ANI waiver an hold point.
01/29/79
WR-K-811 weld fit up.
01/30/79
WR-K-811 visual inspection of t ?nal pass-accept.
KEl-1
misplaced.
"10/ /79
Inspector Setlock assisting with documentation location and
correction.
10/11/79
NR-E-2138(RO) WR-K-811 and WR-K-516, aelieve missed ANI
holdpoint.
Disposition:
- 11/06/79
RT of weld WR-K-516 per. NR-E-2138RO.
- 11/06/79
Probable date of RT of WR-K-811, radiography not retained.
R e j ec+..
(RT done twice).
- 11/08/79
RT of WR-K-516 rejected for unconsumed insert, other defects.
- 12/03/79
NR-E-2260, RT of WR-K-811 shows adjacent weld WR-K-827 un-
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acceptable, unconsumed insert.
Disposition:
Replace pup piece, 'see related NR-2138."
12/14/79
NR-E-2238 " Voided" (actually supe, seded), .
"see Revision 1."
- 12/27/79
" Steve" tells Applegate K-811, "MSR pipe" has " insert f ault."
- 01/07/80
Speed memo, Ruiz to Pallon:
WR-K-516 no KEl-1, RT reject.
- 01/ /80
NR-E-2138 Revision 1, (see related NR-E-2260).
Dispostion:
Cut out and reweld.
01/14/80
Approvals on NR-E-2138, Revision 1 (weld WR-K-516 not mentioned).
01/16/80
Approval on KEl-1 for welds WR-K-916, WR-K-917.
01/18/80
WR-K-916 fitup and weld.
01/21/80
NR-E-2138R1 closed.
01/24/80
WR-K-916 visual inspection and acceptance.
- 01/24/80
NR-E-2260 closed.
03/03/80
Applegate interviewed by Phillip.
04/07-09/80
Phillip onsite.
- 08/ /81
RT for WR-K-516 found.
- 08/ /81
WR-K-516 Re-radiographed.
- Significant information not in OIA Chronology.
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RH-42
- _ -2 zas a veld cn line lam 01CIS in the
Ec_.m_c.
- e s t Removal systea.
-ne rela was located in t.'e reactor build:ne at eleva. tion 497'
The line
is
'.S inches in diameter (weld was 56.54 :ncnes of weld metal).
Design conditions for this line are 220 psig and 389 degrees F.
Maximum
eperating conditions are 240 psig and 358 degrees T.
The line is S&L piping
' lass B.
CHRONOLOGY
08/06/76
Weld fit-up.
08/06/76
Weld performed.
08/09/76
08/09/76
RT read by P-M, reject markers 36-48 (Notation:
re-shoot 100*;
following repair).
08/10/76
KE approval of above RT interpretation.
08/10/76
Approvals on WRD form.
08/10/76
RT of repair area.
08/10/76
RT read by P-M.
08/11/76
RT accepted by KEI.
08/11/76
Approval of repair.
09/16/76
ANI review of 8/9/76, 8/10/76 RT reports, approval.
- 10/10/79
NES review begins.
- 01/25/80
NES review, porosity at film markers 53-55.
- 02/12/80
NR-E-5056 based on NES review findings.
- 02/15/80
NR-E-5056 dispositioned to grind out and repair defect.
03/03/80
Applegate interviewed by Phillip.
03/21/80
WRD form approvals.
- 04/07-09/80
Phil-lip onsite , initistion of Applegate investigation.
04/14/80
PT of re prepped pipe ends, acceptance.
04/21/80
Approvals fer WRD for new elbow.
04/23/80
PT of c' bow end prep. accepted.
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04/30/80
' Weld fit-up breaks loose (Ref: KEIA No. 1008).
05/01/80
Re-fit-up epproved and weld started.
05/02/80
Root pass made.
05/05/80
Root pass approval.
05/06/80
05/07/80
RT approved by KII.
- 05/07/80
ANI review and approval.
- 06/16/80
NR-E-5056 closed out.
- Significant information not in OIA Chronology.
COMMENTS
The NES documentation checklist dated January 25, 1980, by R. A. Zieler,
LII RT, on page 3 notes "NR issued to repair rejectable indication" ant
" corrective action prepared by T. McCall, February 12, 1960".
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It appears that tne .decisien t o grind out and repair the defects at film
markers 53-55 was :isinterpreted to mean cut-out the entire veld.
c u r.- o u t ther: necess::.:r; a net- elbow, as fit-up could not be accomplished
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witnin spec :: cat:cns.
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Enclosure 1
REPLIES TO OIA FINDINGS
1.
DIA Findino
OIA review of investigative file disclosed inadequate documentation.
Discussion
The OIA comment on documentation (page 2) refers to the RIII investi-
cative file, rather than the investigation report itself. They noted
that no "results of interview" or copies of weld documentation reviewed
were in the file.
On page 13, it is pointed out that no identification
key was generated for the investigative file.
Neither NRC, IE, nor RIII procedures require a "results of interview"
to be generated for each interview, and all interviews are not required
to be portrayed in detail in an investigation report.
Investigation
reports should contain all pertinent information, whether obtained
through observations, records or interviews, concerning the matter in-
vestigated.
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There is no need for retention of copies of all documentation obtained
during an investigation.
If a document appears to be relevant to the
case, it is often reviewed onsite,_and no copy is obtained.
If a docu-
ment appears central to an allegation, it is then copied, and may be
made an attachment to the report, if warranted by the issue involved.
2.
OIA Findino
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IE investigative report did not identify the dates on which the welding
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rework was conducted on weld K-811.
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Discussion
Although the IE investigation report did not identify the date when weld
K-811 was removed (approximately January 16,1980), the report did
correctly identify that the weld had been removed as provided by the
disposition of NR No. E-2138R1. Thus, the weld alleged to be improper
was nonexistent, having been removed eighty-two days prior to the
investigation team's arrival at Zimmer.
Determination of the date of
rework was not necessary in our view.
3.
CIA Findino
The IE investigation report did not identify that a nonconformance report
(NR) on weld K-811 had initially been closed with the notation " accept as
is," and was later voided and reopened to order the weld cut out.
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Discussion
The finding as stated is incorrect.
The " accept as is" statement on the
NR was conditional in that it only applieti if a radiograph showed the
weld to be acceptable. Apparently the OIA investigator misunderstood
the NR.
4.
OIA Findina
The investigation did not determine that weld RH-42 had been cut out and
replaced after initiation of the investigetion.
Discussion
The finding is correct. The investigation did, nowever, properly deter-
mine that weld defects had been identified and corrective action was
pl anned .
The actual date of corrective action is not significant.
5.
OIA Findinc
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None of the welds alleged to have been deficient were inspected by the
investigation team nor was all pertinent weld documentation reviewed.
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Discussion
The finding is correct but conside.-ed irrelevant. The investigators
did not inspect the welds but did review the radiographs, which was
the correct method of evaluation. Visual examination of the weld would
not identify internal defects. The investigators did not review all
weld documentation but did review the pertinent documentation to
establish proper Weld disposition.
6.
OIA Finding
The IE investigators did not fully investigate or accurately report on
the alteration of a noncomforance report (NR) related to spool piece:
containing defective welds.
The IE report only identified an individual
as a "CG&E official" vice "QA Manager," thus obscuring that this was the
licensee's senior person responsible for the site QA program who ordered
improper voiding of a NR.
Discussion
Investigator Phillip indicates that the matter was discussed with his
supervisor, and the pursuit of who directed the lining-out was seen as
having little significance. This wat because a separate NR had been
opened, providing tracing of the nonconformance. Finally, neither OIE
nor DI A could substantiate the allegation.
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7.
01A Findina
The IE report found Applegate's allecations on defective welds was
"not substantiated" because welds had not been finally accepted.
This is a question of semantics and not consistent with the facts.
Discussion
The use of the term "not substantiated" was linked with the RIII view
of the status of the acceptance of welds.
RIII ,,as, through previous
inspection findings, well aware that nondestructive examination tech-
niques had been found to be deficient. based on the NRC findings and
related concerns, a consultant had been hired by the licensee to review
weld radiographs. That action negated any previous "acr.eptance" of
plant weld radiography. The previous inspection findings and status of
-the welds in question are correctly stated in the IE report. As such,
it should be clear that the licensee had not given final acceptance to
the welds in question and a system was in place to assure that defective
welds would be identified and corrected prior to final acceptance. As
,
shown in the chronologies, decisions to grind out and replace two of the
welds in question (WR-K-811 and RH.42) had been made prior to initiation
of the RIII investigation.
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