ML20028D491
| ML20028D491 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/30/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028B937 | List: |
| References | |
| NUDOCS 8301190189 | |
| Download: ML20028D491 (15) | |
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U.S. NUCLEAR REGULATORY COT!ISSION REGION III ZIMMER MONTHLY STATUS REPORT November 1982 9
8301190199 830112 gDRADOCK 05000358 PDR
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.. p Table of Contents A.
Executive Summary:
B.
Activity for the Month C.
NRC Zimmer Section Manpower Availability and Utilization D.
High Visibility Items I
1.
Catalytic, Inc.
2.
HJK Investigation Report E.
Quality Confirmation Program (QCP) 1.
Task I.
Structural Steel 2.
Task II. Veld Quality 3.
Task III. Heat Number Traceability 4.
Task IV.
Socket Veld Fitup 5.
Task V.
Radiographs 6.
Task VI.
Cable Separation 7.
Task VII. Nonconformances 8.
.T4sk VIII. Design Control and Verification 9.
Task IX.
Design, Document, Changes 10.
Task X.
Subcontractor QA Programs 11.
Task XI.
Audits F.
Ongoing Activities G.
Potential Plant Problems H.
FOIA Requests I.
Attachments I.
Memo to Region III files regarding November 17, 1982 meeting II.
Memo to the licensee (November 30, 1982), concerning clarification of November 12, 1982 ORDER III. Memo to Region III files regarding November 22, 1982 meeting
- IV.
Summary of the progress of the QCP task areas V..
QCP Status as of November 30, 1982 (Provided by Licensee) 2
A.
Executive Summary i
A Commission Order ~, dated November 12, 1982, was issued stopping all safety-related' construction and rework activities at Zimmer.
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safety-related work and the Quality Confirmation and verification programs are continuing. The onsite work force was reduced from about 2400 on
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November 1 to about 1500 on November 30, 1982. This order was preceeded j
by Commission meetings on November 8 and 12, 1982.
Region III met with CG&E and Bechtel on November 17, 1982 to discuss the November 12 Commission Order. A memo to file discussing these meetings is provided as Attachment I.
In letters dated November 18 and 22, 1982, the licensee requested NRC concurrence to perform certain construction related activities. The licensee's letters were not considered to be requests to relax the Commission Order, but rather a request for clarification of the scope of the activities suspended by the Order. The Region's response dated November 30, 1982 is provided as Attachment II.
A meeting was held between Region III and CGSE on November 22, 1982, to discuss the September 24, 1982 " Demand for Information" issued to ths, licensee. The licensee indicated that an extension to the December 31, 1982 completion date may be needed. A memo to file discussing the meeting is provided as Attachment III.
The licensee submitted a request to allow Bechtel to perform the inde-
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pendent management assessment required by the November 12, 1982 Order.
The Region is evaluating the submittal and comments solicited from interested parties.
A public meeting in the Cincinnati area is planned for January 5, 1983, regarding the comments.
Region III inspection efforts at the Zimmer facility during the month of November were concentrated on review of nonconformance reports, monitoring and inspection of other ongoing activities including the QCP, monitoring of the stopping of safety related construction, and responding to requests for information.
Inspection Report No. 50-358/82-06 for April and May was issued during the month.
As a direct result of the actions committed to by the licensee under their Quality Confirmation Program (QCP), the licensee has identified
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a large number of significant construction deficiencies.
The licensee submitted three new construction deficiency reports (or potential reportable matters) per 50.55(e) during November.
A total of 32 construction deficiency reports have been submitted in the first eleven months of 1982. This co= pares with 13 submitted in 1981, 16 submitted in 1980, 8 in 1979, and 8 in 1978.
Section B below enlarges on the sum =ary of activities during the month of November.
Section C contains the manhours spent by RIII on Zimmer 3
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during November (810) and for the year to date (9760). Section D has no new information.
I Section E contains' some new information, but of relatively minor significance, such as changes in the task completion dates, changes in percent completion, changes in personnel assigned, changes in some findings (Task I, structural material traceability), and changes in numbers of NR's.
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Section F indicates all safet'y related work was stopped by the Commission's Order.
Section G adds " control of records" to the list of potential plant problems RIII is following.
Section H indicates no FOIA requests
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were processed during November.
l Attachment IV summarizes the changes in the QCP Task completion status and expected completion dates.
Attachment V is CG&E's QCP status report for the month of November.
B.
Activity for the Month The Commission issued an " Order to Show Cause and Order Immediately Suspending Construction" on November 12, 1982, following meetings held on Novefaber 8 and 12,1982, to discuss the Zimmer Project, problems, and proposed enforcement actions.
A management meeting was conducted with the licensee on November 17, 1982, regarding the NRC November 12, 1982 Order. Region III memo to file discussing this meeting is provided as Attachment I.
A Region III memorandum was transmitted to the licensee en November 30, 1982, providing clarification of the November 12, 1982 Order. The memo addressed the licensee's request for concurrence to perform certain,.
activitie,. The Region III memo is provided as Attachment II.
s Region III inspection efforts at the Zimmer facility during the mcnth of November were concentrated on review of nonconformance reports, monitoring and inspection of other ongoing activities including the QCP, and the monitoring of the stopping of safety related construction.
The National Board of Boiler and Pressure Vessel Inspectors is continuing inspection efforts onsite. The National Board issued interim reports on May 12, July 1, (August 6 supplement), September 30, November 17, and November 30, 1982. The findings of the National Board are consistent with and similar to NRC findings. The lir_ensee resporded on August 4 and 30, October 20 and 29, November 17, and December 1, 1982, and plans to provide a bi-weekly status report.
In accordance with 10 CFR 50.55(e), the licensee reported the following potential construction deficiencies:
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l On November 26, 1982, the' licensee reported that the contractor (H. J. Kaiser) reviews of non-generic (non-routine, pre-written) work packages may not have been adequate in that inspection require-ments may not have been specified.
On November 9, 1982, the licensee determined that qualification data does not exist for small bore piping bending for the procedure qualification test as required by ASME,Section III, MB 4213,
" Qualification of Forming and Bending Processes."
l' On November 26, 1982, the licensee identified a lack of material traceability and control for structural steel. At least two pieces of steel have more than one heat number affix.ad on the pieces.
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Region III is continuing evaluation of the licensee's responses to the investigation report 81-13 and civil penalty, no progress was made during the month becadse of 6ther priority work.
Since the July Monthly Status Report was prepared, two petitions, both 20, 1982, have been received from the Government Accountability dated August Project (GAP). The first is for reconsideration of the Commission's Order' of July 30, 1982. The staff has considered this petition and made it's recommendations to the Commission. The second petition is to suspend con-On September 24, 1982, the RIII Regional
- 'struction of the Zimmer Station.
Administrator issued a " Demand for Information" pursuant to the Commission's authority under Section 182 of the Atomic Energy Act and 10 CFR 50.54(f) of the Commission's regulations. This " Demand for Information" requires the licensee to admit or deny each of the allegations applicable to the licensee's and its principal contractor's or subcontractor's performance l
contained in paragraphs.19 through 273 of the petition.
If the allegations are not admitted, they must explain the basis for not admitting the alle-In addition, they must identify the manner in which the Quality gations.
Confirmation Program (QCP) addresses the type of existing or potential quality assurance or construction deficiencies and problems identified in each of the above allegations.
If the QCP does not address such defici-encies or problems, CG&E must describe the manner in which they will ensure such deficiencies or problems are corrected. They have until December 31, 1982 to respond. On October 18, 1982, GAP issued a supplement to their
. August 20, 1982 petition. The staff is reviewing this-supplement. On November 22, 1982, Region III staff meet with CG&E to discuss the " Demand for Information." A Region III memo to file discussing this meeting is provided as Attachment III.
NRC Region III was advised of allegations that relevant documentation on the welders at the Zimmer site was prepared for, or reviewed at, a meeting between Cincinnati Gas and Electric Company (CG&E) and H. J. Kaiser (HJK) held on July 8, 1982, but that such documentation was not discussed with, or made available to, Region III at a meeting on this subject held on Substantial documentation July 9, 1982, between CGSE, HJK and Region III.
was made available to Region III in connection with the July 9 meeting, but additional relevant documentation was allegedly not made available.
The matter of the existence of such documentation was informally discussed 5
b4 v.84 on October 15 and 20,1982, between Messrs. B. R. Sylvia of CG&E and R. F. Warnick and D. R. Hunter of NRC Region III. Further information was required to resolve these concerns and, if these concerns were found to be valid, t,o determine whether enforcement action, including modifica-tion, suspension, or revocation of CGSE license, is warranted.
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Accordingly, pursuant to Section 182 of the Atomic Energy Act and 10 CFR 50.54(f) of the Commission's regulations, on October 27, 1982, CG&E was required by Region III to submit under oath and in writing, by November 16, 1982, a list of'all reports or other documentation prepared by CGSE's or HJK's document reviewers or other personnel in preparation for the meetings of July 8 and/or 9, 1982, or reviewed at those meetings.
Copies of any such reports were requested to be made available at the Zimmer site for inspection by the NRC. (The licensee responded to this 10 CFR 50.54(f) " Request for Information" on November 15, 1982. This response is currently being reviewed by Region III).
C.
Zimmer Section Manpower Availability and Utilization 1.
Assigned Manpower Section Chief (Assigned to Zimmer full time. Onsite part-time.)
-Project Manager (Assigned to Zimmer full-time. Onsite as needed.)
Resident Inspectors Senior Resident (Full-time onsite)
Resident Inspector (Full-time onsite)
Resident Inspector (Full-time onsite)
Investigators (Office of Investigations (OI))
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Five Investigators (Full-time) 2.
Summary of Manpower Utilization Onsite and in office professional effort from January 3,1982 through November 27, 1982 was approximately 9,759.5 manhours, with 810 of these manhours occurring between October 31 and November 27, 1982.
(These hours do not include those of OI investigators).
D.
High Visibility Issues 1.
Inspection of Catalytic, Inc. Activities Special inspection performed by Region III during weeks of August 10 and September 7 and 13, 1982, regarding the adequacy of licensee control of Catalytic, Inc. work activities and to determine if the licensee had violated the December 24, 1980 NRC Immediate Action Letter (IAL) and the December 30, 1980 CG&E Stop Work Order (SWO).
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. y Effort by Licensee Immediately prior to the inspection, the licensee notified the NRC r
that a.Stop Work Order (SWO) was initiated on August 5, 1982, regarding
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Catalytic,' Inc. work associated with the removal of Control Rod Drive (CRD) hangers and supports.
During the NRC inspection a number of corrective actions were taken I
by the licensee, including the issuance of a Limited Stop Work Order (SWO) on September 10, 1982, on miscellaneous work by Catalytic, Inc.;
and a Stop Work Order (SWO) on October 11, 1982, for all essential work activities performed by Catalytic, Inc., following the discussion of the inspection findings with Region III on October 8,1982.
1 NRC Effort / Action The NRC inspection identified a number of programmatic concerns as well as individual. findings in the field concerning the Catalytic, Inc. safety-related activities.
A management meeting was conducted at the Greater Cincinnati Airport (Open Meeting) on October 19, 1982, to discuss the inspection findings.
. Additional working meetings were held on November 2-4, 1982, to discuss the specific technical and programmatic issues in more detail.
Findings to Date The licensee and the NRC have identified a number of concerns in the areas of organizational description and interfaces, assignment of responsibilities and autho'rity, training, design control, procedures, document control, inspections, corrective action, records, and audits.
A number of concerns are considered repeat items. The inspection results indicate a breakdown in the CG&E management controls regarding Catalytic, Inc. The above items were considered prior to the issuance of the November 12, 1982 NRC ORDER.
2.
H. J. Kaiser (HJK) Internal Investigation Report f
Region III anonymously received a partial copy of a report of a HJK investigation conducted at Zimmer. The report was mailed from Cincinnati, Ohio on March 23, 1982, a,nd received by Region III on March 26, 1982. The NRC is investigating to determine the safety significance of the matters described in the investigation report and whether or not NRC reporting requirements were met.
Effort by Licensee The licensee is conducting a review of the report.
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NRC Effort / Action The NRC investigation into the HJK investigation report and its significance has been transferred to the Office of Investigations.
i Findings to Date I
I The findings will be discussed after the investigation is complete.
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E.
Quality Ccnfirmation Program'(QCP)
A summary of the progress of the QCP task areas is provided as Attachment IV. The CG&E QCP Status Report as of Ncvember 30, 1982, is included as Attachment V. This attachment includes more detail than the following summary presents.
1.
Task I, Structural Steel
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Review of structural beams, beam welds, re-entrant corners, procure-ment of beams, beam and steel plate heat number traceability, and inspection of cable tray foot connections.
Effort by Licensee
-aThe licensee is. continuing to inspect structural steel items including foot connections, drywell steel, control room steel, gallery steel, and switchgear steel.
The task involves 16 persons and is reported to be 67% complete with an estimated completion date of March 1, 1983.
NRC Effort / Action Reviewed 2,063 initial issue nonconformance reports (NRs) and'138 dispositioned NRs and inspected a selected number of those reviewed.
Resident and specialist inspectors performed field walkdowns of actual conditions and rework activities.
Findings to Date The licensee has generated 1039 NRs identifying about 9546 weld deficiencies. The majority of the 4974 deficiencies dispositioned have been dispositioned as " rework".
Four construction deficiency reports have been reported to the NRC concerning laminated angle iron, cable tray hangers / weld deficiencies, cable tray hanger " Nelson stud" deficiencies, and structural material traceability and control.
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2.
Task II, Veld Quality Review of welds performed, weld rod control, transfer of weld rod heat numbers, and deletion of weld inspection criteria.
Effort by Licensee The licensee is continuing to review the areas of structural weld cards, welding procedures, welder qualifications, small-bore piping welds, and large-bore piping welds.
The task involves 5 persons and is reported to be 70% complete with The licensee is reorgan-the completion date still to be determined.
izing the task work with both HJK and CG&E performing the reviews to improve efficiency.
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NRC Effort / Action Reviewed 706 initial issue NRs and 126 dispositioned NRs and inspected a selected number of those reviewed.
Findings to Date
' 'The licensee has identified nonconforming conditions regarding veld data sheets, heat numbers, welder qualifications, and welding proce-Discrepancies being identified include lack of objective evidence, white-outs and cross-outs, signature differences, incon-dures.
(Welder sistent data, and lack of adequate acceptance criteria.
qualifications are being reviewed by a special HJK/CGSE task group Due to the identification of the lack of adequate control of draw-ings, inadequate acceptance criteria, and restart of the review activity under a new program, the large-bore piping weld review has not progressed.
Three construction deficiency reports have been identified to the NRC I
concerning weld procedure deficiency, carbon weld rod in stainless steel weld, and lack of weld preheat or post weld heat treatment.
Task III, Heat Number Traceability 3.
Review of installed large-bore and small-bore pipe heat numbers, heat numbers on isometric drawings, incorrect or marked-up heat numbers, and purchase orders.
Effort by Licensee l
The licensee is continuing to review heat numb The task involves 5 persons and is reported to be 40% co=plete with f
the estimated completion date still to be determined.
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...f NRC Effort / Action 1
Reviewed 541 initial issue NRs and 73 dispositioned NRs.
I Findings to Date The licensee has identified a substantial number of discrepancies regarding small-bore piping, large-bore piping, and purchase orders.
The nonconforming conditions include documentation deficiencies, lack of design change control, unsigned reports, use of unapproved vendors, and upgrade of materials.
Three construction deficiencies have been identified to the NRC con-cerning 2400 ft. of SA-106 Grade B piping, some bolting material, and control of " gamma plugs."
4.
Task IV, Socket Veld Fit'up Review of socket weld fitup to ensure adequate disengagement for small bore piping.
Effort by Licensee "The task is substantially complete with 29,821 fitups reviewed of a total of 32,000: The finsi reviews of the identified discrepancies and radiographs are being made.
The task involves 3 persons, and is reported as 98% complete witL an estimated completion date of March 1, 1983.
NRC Effort / Action
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Reviewed 115 initial issue NRs and 88 dispositioned NRs and inspected a sqlected number of those reviewed.
lindings to Date The licensee identified 695 weld joints which lacked evidence of disengagement and the joints have been radiographed. Of the 695 valds 111 have been rejected for lack of disengagement.
5.
Task V, Radiographs Review the radiographs which did not meet ASME Code requirements due to inadequately shimmed penetrameters.
Effort by Licensee The licensee has completed the review of the radiographs and is preparing a code inquiry to ASME concerning the shimming of the penetrameters.
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The selected, qualifying radiographs are being reviewed to assess Of the 61 welds initially identified, 2 welds the weld conditions.
have been found to be duplicates, 1 weld had been replaced and was removed from the list, and 12 welds are inaccessible. This reduces the total to 46 welds identified. All 46 have been re-radiographed and accepted.
This activity is reported to be approximately 99% complete with a co=pletion date of January 15, 1983.
NRC Effort / Action The resident inspector reviewed 97 initial issue NRs and 30 disposi-tioned NR.
Findings to Date.
A substantial number of the M. W. Kellogg radiographs were not shimmed adequately; however, the quality and sensitivity of the radiographs appears adequate.
Two construction deficiency reports have been identified to the NRC
_ concerning radiographs.
6.
Task VI, Cable Separation Review cable separation regarding essential and associated cables.
Effort by Licensee The licensee is continuing the review and evaluation of wall penetra-tions/ sleeves, associated cables for Class IE panels, all 1E panels, and responses to engineering' evaluation requests (EERs).
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The task involves 9 persons and is reported to be 55% complete (scope expanded) with a co=pletion date of June 1, 1983 (sccpe expanded).
f NRC Effort / Action Reviewed 914 initial issue NRs and 285 dispositioned NRs and inspected a selected number of those reviewed Findings to Date f
Nonconforming conditions have been identified corcerning cable separa-i The licensee has written 869 NRs tion, identification, and routing.
and 489 NRs have been dispositioned (239 rework, 46 repair, and 204 accept-as-is) of which 218 NRs have been closed to date, with an additional 12 NRe cancelled because of duplication.
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... s Three construction deficiency reports have been identified to the NRC concerning electrical cable separation.
7.
Task VII; N neopformance Reports Review of noncomformances documented in surveillance reports, punch t
lists, and exception lists; and nonconformances not documented, not entered, and voided rather than adequately dispositioned. Review 300 closed NRs and solicit NRs not entered into the system.
i Effort by Licensee The licensee is continuing to review and evaluate nonconformances.
Approximately 200 letters to former QC inspectors soliciting non-conformances not. entered into the system return receipt requested were mailed by the licensee. The responses were limited. One report has been received from an individual identifying four potential NRs.
Additional procedures, field walkdowns, and a material impound area are being provided.
_The task involves 4 persc;a and is approximately 61% complete with an estimated completion date of March 31, 1983.
NRC Effort / Action Reviewed 367 initial issue NRs and 257 dispositioned NRs and inspected a selected number of those reviewed.
Findings to Date Fifty eight NRs have been written due to reopening of previously voided NRs. Of these NRs, 43 have been dispositioned (15 rework, 1 repair, and 27 accept-as-is).
8.
Task VIII, Design Control and Verification f
Review procedures controlling design calculation completion, S&L program for controlling deviations from FSAR, correctness and con-l sistency of FSAR, and design deviation identification and disposition.
l Effort by Licensee A programmatic audit of S&L design control was needed to complete this task. The audit was conducted on September 1-3, 1982 in Chicago.
There were no findings. The audit will not be closed until the two recommendations given by the audit team have been resolved.
The task is 99% co=plete with an estimated completion date of February 28, 1983.
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NRC Effort / Action The activity,is being monitored with a closecut inspection planned to verify. completion of the QCP Task VIII items, to identify any generic implications, and to evaluate the licensee conclusions.
Findings to Date No significant findings have been identified to date regarding the S&L work; although, the S&L system.has been made more formal.
Four construction deficiency reports have been identified to the NRC, regarding design control.
9.
Task IX, Design Document Changes (DDC)
Establish an accu ~ rate an'd complete listing of DDCs, DDC records, and associated QC inspection records.
Effort by Licensee This task was divided into five phases as follows:
-Phase I Classification of CG&E, S&L, and HJK, DDCs as essential or nonessential.
Phase IA Classification of WY&B and other site contractor DDCs as essential or nonessential.
Phase II Review inspection documentation to determine if CG&E, S&L, and HJK DDCs have been incorporated and inspected.
Phase IIA Review inspection documentation to determine if WY&B and other site contractor DDCs have been incorporated and inspected.
Phase III Electrical inspections in the control room.
The original task (Phases I and II) is 42% complete. Phases IA and IIA are 14% complete end Phase III is 17% complete.
The task involves 7 persons for Phases I, II, IA, and IIA with an estimated completion date of June 30, 1983. Phase III involves 5 persons with an estimated completion date of February 28, 1983.
NRC Effort / Action Reviewed 547 initial issue NRs and 3 dispositioned NRs and inspected a selected number of those reviewed.
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.. y Findings to Date A number of, deficiencies have been identified concerning missing documentation, misclassification of DDCs, inspection program defici-encies, f ailure to incorporate deficiencies, premature inspection, and incomplete inspection documentation.
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Task X, Subcontractor QA Programs Confirm the quality of 'he Bristol Steel work and review all subcon-t tractor QA programs or safety-related work to ensure the safety-related activities performed were acceptable.
Effort by Licensee Bristol field welds are being reviewed within Task I and 30 audits of subcontractors were identified encompassing 13 subcontractors.
All 80 audits have been reviewed.
The task involves 2 persons and is 78% complete with an estimated completion date of February 28, 1983.
NRC Effort / Action
-a None during this period..
Findings to Date f
Six subcontractor audits may require audits of subsequent activities l
for confirmation of work that cannot be verified by document review or inspection.
Many of the 80 audits reviewed do not address all applicable, criteria.
11.
Task XI Audits Review all past audits of HJK, S&L, GE, GED, EPD, E0TD, and GCD to determine depth and adequacy with respect to Appendix B to 10 CFR 50 l
and appropriate closeout of audit findings. Justify the acceptability of the areas not audited.
Effort by Licensee Review of audits, audit summaries prepared, and all of the 296 past audits have been reviewed.
The ta.h involves 2 persons and is 82% complete with estimated completion date of February 28, 1983.
NRC Effort / Action None during this period.
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u Findings to Date Coverage of the audits was not sufficient to verify adequate imple-mentation of program requirements.
F.
Ongoing Construction Activities As of Novembtr 12, 1982, all safety-related construction activities, including rework of identified deficient construction was suspended by an NRC ORDER.
G.
Potential Plant Problems The following is a list of areas or items which Region III considers as potential problems and are being monitored by the inspectors.
Rust on the stainless steel liner plate in suppression pool Containment liner leak rate channel leakage (welds)
Sacrificial shield weld inadequacies (records and actual weld conditions)
-Cable tray trapeze weld and support stud inadequacies Past personnel qualifications Past weld procedures Purchase of equipment Structural steel bolting Control panel and electrical switchgear mounting plug weld inadequacies Cable seperation inadequacies Control of records H.
Freedom of Information Act (FOIA) Requests None during this period.
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
- g REGION iii 799 ROOSEVELT ROAD
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f OLEN ELLYN, ILLINOIS 60137 kggy,5 YCe
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%aoo November 24, 1982 i
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MEMORANDUM FOR: Region III Files l
Stephen H. Lewis, Regional Counsel, Region III 1
I FROM:
MEETING OF REGION III WITH CINCINNATI l
NOVEMBER 17, 1982 GAS & ELECTRIC AND BECHTEL REGARDIN i
SUBJECT:
i ltd order suspending safety-re a e F$1kowing the Commission's November.12,1982 Gas & Electric construction at the Zicmer plant and directing Cincinnati f
Co:pany (CG&E) to undertake certain actions prior to NRC consideration November 17, resumption of safety-related construction, meetings we III, CG&E and the Bechtel Ann Arbor Power Division (AAPD).
implementation. The were to explain the order and discuss CG&E's planning her in Participants.in the mp.:ning meeting were:
the afternoon.
C,G_hi William Dickhoner, President Earl Borg ann, Vice President William Moran, General Ccansel Mark Wetterhahn, Outside Counsel N_RC, Rerion Iy.
Jaces Scppler, Regional AdministratorOffice of Special Cases
. Robert Warnick, Director,Dorwin Hunter, Section Leader, Zimmer Section Stephen Lewis, Regicnal Counsel Joining the above participants for the afternoon meeting were:
and General Manager, AAPD Heward Vahl, Vice Presidentand Deputy General Manager, AAPD Bill Henry, Vice PresidentGeorge J:nes, proposed Project Manager for A considerations Mr. Keppler opened the teeting with a discussion of tie He noted that the which led to the issuance of the Commission order.Censis i
k ior to cf the Quality Confir:ation Program (QCP) being underta en pr ccepletion of all of the relevant QCP Tasks.
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Region III Files 2
November 2.4, 1982 Mr. Dickhoner describeii steps that had been undertaken by CG&E, both before
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and after the order, with respect to Zimmer construction. He stated that personnel at the site had been further cut back, and that there were now approximately 700 people at the site, of whom 200 were craftspersohs. The QCP is, however, continuing. He advised that the CG&E Board of Directors would be meeting on November 18, 1982. He complained that CG&E has not always been provided copies of allegations sent by GAP to the NRC.
NRC participants stated that CG&E would have to receive the Regional Administrator's approval of the independent entity selected to conduct the review of CG&E's management of the Zimmer project (Paragraph IV.B(1) of the order).
CG&E advised NRC that prior to the order it had already arranged for AAPD to conduct a review of CG&E's management of the project and that AAPD had commenced its review. NRC advised CG&E that we would not prevent AAPD from continuing with this review, but that CG&E was proceeding at its own risk until the Regional Administrator has approved the selection of AAPD. That approval determination would be based upon a written submission from CG&E to the Regional Administrator setting forth:
(1) AAPD's cap-abilities.to perform the management review, (2) whether AAPD (and Bechtel, generally) has the necessary independence of CG&E (e.g., whether Bechtel has performed work, and if so of what type, for CG&E), and (3) the nature of the review that AAPD would undertake under Paragraph IV.B(1).
Paragraph IV.B(2) of the order was discussed. NRC emphasized that the quality verification plan could be submitted only after the Regional Administrator had approved the CG&E recommendations regarding management of the Zimmer project (Paragraph IV.B(1)(b))
NRC clarified that we would expect CG&E to use an outside entity ( n, AAPD) in preparing the plan for verification of plant quality. That outside entity should be free to conclude that the QCP is I
insufficient to verify the quality of construction of the plant. CGLE indicated that it was their present intention to use the services of AAPD in the preparation of the comprehensive quality verification plan (and in the construction management of the facility). The staff stated that the order did not preclude the use of the same outside party to perform the management review and to assist in the preparation of the. quality verification plan. CG&E also l
l inquired whether the order culd preclude the use of AAPD as the entity per-l forming the audit to verify the quality of construction (Paragraph IV.B(2)(a)).
The NRC stated that the order would not preclude the use of AAPD as the auditor, inasmuch as AAPD "did net perform the activities baing audited."
The NRC agreed that the review under paragraph IV.B(1) was to be focused on management of the Zimmer project including its QA program and quality verifi-cation program, and was not intended to be a review of the content pf the QCP.
The review of the content of the QCP was to be part of the preparation of the comprehensive plan under Paragraph IV.B(2)(a).
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p Region III Files 3
November 24, 1982 j
The NRC advised CG&E that the quality verification audit under Paragraph IV.B(2)(a) was not to be confused with the independent verification I
of design adequacy (typically conducted by reviewing a " vertical slice" of the plant), which would be required of CG&E at some later date prior to any l
issuance of an operating license for the facility.
t Paragraph IV.B(3) of the order was discussed. NRC stated that if CG&E l
sought to have the order " relaxed" to permit the resumption of certain i
safety-related construction activities, it would have to demonstrate to the Regional Administrator that any work sought to be permitted:
(1) is
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not related to any quality verification concerns which have been raised l
and (2) will include adequate controls.
i The NRC stated that if CG&E-should determine that the facility will not be able to meet any applicable codes and standards, it should proceed promptly to propose to the h3C alternative engineering bases for demonstrating acceptability.
Any consideration of deviations from the ASME Code would have to involve the cognizant Code Committees and the National Board of Boiler and Pressure Vessel Inspectors.
Mr. Dickhonsr requested that the NRC be prepared to act promptly on any request CGSE might file for permission to proceed with identified construction activities.
Mr. Keppler indicated that NRC would give high priority to any such request and would seek to act on it as promptly as possible.
CGLE asked for an early meeting with Region III on the September 24, 1982,
" Demand for Information" issued under 10 CFR 550.54(f) with respect to " Miami Valley Power Project's Petition to Suspend Construction of the Zimmer Station,"
dated August 20, 1982. The purpose of the meeting would be to clarify the
" Demand."
[The requested meeting was held on November 22, 1982.]
CG&E advised the NRC that it will shortly send the NRC a letter advising of certain activities which it believes are not proscribed by the order and asking.for the Regional Administrator's concurrence that CG&E may continue with those ectivities.
[A-letter was sent on November 18, 1982 and a revised letter on November 22, 1982.)
In the afternoon, AAPD joined CG&E and the NRC for discussions. The focus of the ceeting was on the following areas:
I 1.
CG&E should be sensitive to NRC's concerns with AAPD's performance at Midland and should reflect in the document submitted with respect to approval of AAPD the capabilities of AAPD to assess effectively CGLE's management.
l
i Pegion III Files 4
November 24, 1982 9
2.
The NRC advised APD that, if selected to conduct the review of CG&E management, it should feel free to discuss matters with respect to this review directly with NRC, without having to go through CG&E.
3.
The NRC emphasized that AAPD, if selected, should consult with the Authorized Nuclear Inspector, the National Board of Boiler and Pressure Vessel Inspectors and other entities involved in assessing the adequacy of construction of the Zimmer facility.
AAPD emphasized to the NRC that it would strive for open communication among itssif, NRC, and CG&E.
If AAPD is retcined to assist CG&E in management of construction of the facility, AAPD would normally, expect to discuss its
, findings with CG&E before bringing them to NRC's attention.
AAPD hopes to complete its initial assessment of CG&E's management and to make recommendations to CG&E within three weeks.
It is already on site and has begun its review.
Mr. Keppler stated that the NRC intends to hold meetings that would be open to the public at appropriate stages in the implementation of the order.
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.b Steph n H. Lewis Regional Counsel cc:
k'. Dircks, EDO H. Denton, NRR R. DeYoung, IE G. Cunningham, ELD e
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$,g oLEN ELLYN. ILLINols 60137
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9 NUV. 3. 0 $82 l
e Docket No. 50-358 Cincinnati Gas and Electric Company ATIN: Mr. Earl A. Borg= ann Senior Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnati, OH 45201 Gentlemen:
This is in response to your letter' (QA-2118) dated November 18, 1982, and revised on November 22, 1982 (copies enclosed).
Your request for NRC concurrence prior to performing the 16 activities listed in your November 18, 1982 letter is not considered to be a request to relax the order as provided for in paragraph IV.B.(3) of the November 12, 1982 Order to Show Cause and Order Immediately
. Suspending Construction. Rather, it is considered to be a request for clarification of the scope of the ' activities suspended by the order.
As discussed in the meeting with you on November 17, 1982, the NRC requested that activities which might be considered to be covered by the order be submitted to Region III for review and approval.,
During telephone conversations on November 19,.1982, RIII personnel informed CG6E' that items 9, valkdown of essential systems, and 15 document reviews, of the November 18, 1982 letter were clearly not f
CG6E's revised prohibited by the order and that they could continue.
letter dated November 22 deleted those two items.
The following activities are not considered to be safety-related construction activities suspended by the order, and they may be continued within your existing management controls and your established The item numbers listed belos correspond quality assurance programs.
to the numbers contained in your November 22, 1982 letter.
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ATTACW.ENT II l
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3 0 kB2 C ncinnati Gas end Electric Company lds, not Removal of paints.and coatings necessary_ to inspect wethe e d:the 1.
tting, etc.
verification program and not to include grinding, cu to infringe Ant lds and heat Removal of fireproofing and insulation to inspect weGrinding and cuttin 2.
number traceability.
ber Removal of hangers or parts of hangers looking for heat numgrinding, bu i i traceability, not to include cutting, ch pp ng, 3.
etc.
Essential HVAC air flew testing and balancing.
4.
lubrication, Routine maintenance of essen,tial components such as tc.
cleaning, changing filters, etc. on HVAC, motors, e 5.
r reissue Receiving of essential material; however, the issue o is nor to be of essential materials for essential applicationd the verification 8.
performed except in support of item 5 above an program.
h require Conduct evaluations of existing essential coatings whicSamples are
-e t include 9.
taking samples and cenducting tests.in size such as paint chi
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cutting steel, grinding, etc.
Hydrostatic and pneu=atic testing and NDE activities.
13.
i to permit The following items did not contain sufficient informat onWe b basis.
blanket approval.
and approved by NRC Region III on a case by case ided it does The physical movement of mechanical equipment, prov 11.
not enhance construction.
t to safety The, application of fire barriers classified as importan 12.
not listed as essential.
The following activities may not continue at, this time:
for fabrication.
Shipment of essential material offsite to vendors k
6.
for NDE examinations.
Grinding activities to prepare essential weldsGrin be a safety-related 7.
construction activity.
9
,. Cincinnati Ces and Electric gj)y, 0 bo,,c, j i
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,,y Company 10.
Electrical testing of cables and logic testing. Although testing is not specifically prohibited by this order, the proposed testing involves determinating and terminating leads which is normally considered to be a construction activity.
Region III is not prepared to issue. blanket approval for electrical testing of cables and logic testing, but will consider approval of such testing on a specific case basis.
Installation of mirror insulation on the RPV vessel is not approved 14.
since it would cover areas that may require inspection.
We will gladly discuss any questions you have concerning this matter.
Sincerely, k
Ab
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James G. Kepp e Regional, Administrator
Enclosures:
As stated cc w/1trs dtd 11/18; 11/22/82:
DM3/ Document Control Desk (RIDS)
Resident Inspector, RIII Harold W. Kohn, Power Siting Commission Citizens AEainst a Radioactive Environment Helen W. Evans, State of Ohio Robert M. Quillin, Ohio Department of Health Thomas Applegate Tho=as Devin'e, Associate Director Institute for Policy Studies Dave Martin, Office of Attorney General Park Wetterhahn, Esq.
Jerome A. Vennemann, Esq.
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- 2 T ii i. CINCIN NATI GAS Ee ELECTRIC COMPANY C"""'
Z!Ki:1. ';r:1.F.AR PU'.*ER STATION, P.O. BOX 201, MOSCOW, OH !.5153
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November IR. 1982 QA-2113
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U.S. Nuclear Regulatery Co=sission Mer, ion III 799 Roosevelt Road Glen Ellyn, Illinois 60137 s
' Attention:
Mr. J. G. Kcppler.-
Regional Administrator
~
RE:
VM. H. ZIMMER NUCLEAR POWER STATION UNIT 1
~~
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CONCURRENCE OF NON-CONSTRUCTION ITEMS UNDER SHOW CAUSE ORDER OF NOVEMBER 12, 1982 DOCKET No. 50-358, CONSTRUCTION PERMIT No.
CPPE488. W.O. 657300, JOS E-5590, FILE fNRC-3 Centlemen:
Reference is made to the meeting held in Cincinnati, Ohio Nove=ber 17, 1982 in Mr. Dicthoner's office. We wish to continue certain activities which we be-lieve do not violate the spirit of the November 12, 1982 Show Cause and Order of Irmedinte Suspension of Essential Construction. However, we wish concurrcnce on these itens prior to their performance:
1.
P,e.r. oval of paints cnd coatings necessary to inspect velds.
Repainting to protect velds.
Is this permitted?
t 2.
Renoval of fireproofing and insulation to inspect velds and heat number t rac eab il i ty.
Can this be done?
3.
nereval of hanr.cr or parts of hanger looking for heat number trace-
..h 111 t y.
Is this permitted?
4 Essential HVAC is ready for air test cnd balancing. May ve proceed?
I 5.
It is necessary to perform routine maintenance on essential co=ponents such as lubrication, c1 caning, changing filters, etc., on HVAC, c.otors, i
etc.
Vill this be per=itted?
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18, 1982 Parc 2 t
F.JK vould like to ship essential caterial off site to vendors for r.
fabrication.
7.
Crinding is required in sore cases to prepare essential velds for NDE examination.
Is this percitted?
8.
Are we prohibited from receiving and reissuing essential material to contractors on site provided they are not used in construction?
9.
Ve vould like to continue walkdown of essential systems both for engineering, inspection and traceability.
10.
Vc would like to conduct evaluations of existing essential coatings which require taking sacples and conducttng tests.
11.
Ve voGIS like to continue electrical testing of cables and logic testing.
Is this permitted?
12.
Is it pereitted to physically cove techanical equipment provided it does not enhance construction?
13.
Are ve permitted to continue application of fire barriers. classified as icpcriant to safety no't listed as essential?
t' l.
Kay^ ve proceed VIth hydrostatic, pneucatic tasting and h)E7 15.
Review ard acceptance of quality-related decucentation - cay it proceed?
.16.
Installation of cirror insulation on the RFV vessel. !isy it proceed?
A prorpt co== unique in response to our request vould be apprecisted.
Very truly yours.
TEE CINCINNATI CAS & ELECTT.IC C3.9AhT Ww 37 f
E. A. LORCMANN SENIOR VICE PRESIDENT NP r : ', a t.
'.' s '. Pffice of Inspection cc-t
- 1. i'nf err enent V..shinnten D.C. 20555 5
'Gr Senior Resident inspecter
't V. T. Christianson r., r troicet intrecter
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- n ! :W. TV-TK STATION, P.O. 50X 201, MOSCOV, OH I.5153 Noverber JS, 1982 QA-2118
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Revised Nov. 22, 1982 c
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U.S. ':ucicar Regulatory Commission i:enien Ill 79') Et.nsevelt Road Glen Ellyn Illinois 60137 Attentton:
Mr. J. C. Kcppler Pegionni Administrator WM. H. ZIMMER NUCLEAR POWER STATION, UNIT 1 RE:
CONCURRENCE OF NON-CONSTRUCTION ITEMS UNDER SHOV CAUSE ORDER OF NOVEMBER 12, 1982 DOCKET No. 50-358. CONSTRUCTION PERMIT NO.
CPPR-88 W.O. 57300, JOB E-5590, FILE NRC-3 i;cr.t i cmen:
letter is a revision to our letter QA-2118 of November 18, 1982. The
- This, rev:3.i.7n required the renoval of items No. 9 and No. 15 from the original 1cteer becacse they do not constitute physical construction as covered by your Show cause Order and therefore should not have been included.
Thls revition confires the exchange of inforcation in a telephone conversation
~
L.etwen Messrs. D. Hunter of your staf f and S. K. Culver en Novenber 19, 198,2.
Ket erence is nade to the meeting held in Cincinnati, Ohio Nove bcr 17, 1982 in We wish to continue certain activities which we believe Mr. Dickhanc r's of fice.
do not violate the spirit of the November 12, 1982 Show Cause and Order of I=cediate HovcVer, vc w*sh concurrence on these itees Suepension of Essential Construction.
pr I.T to their performance:
Renoval of paints and coatings necessary t.o inspect velds.
Repainting 1.
to protect velds.
Is this permitted?
Eenoval of fireproofing and insulation to inspect welds and heat nu=ber 2.
traceability.
Can this be donc?
Re.aval of hanger or parts of hanger Inoking for heat number traceability.
3.
is this permitted?
and balancing.
May ve proceed?
Essent tal H'.*AC is ready for air test orm routine raintenance on essential components
~
- t is necessary to pct 3.
s.wh.is lui rication, cicaning, changing filters, etc., on HVAC, motors, Vill this be permitted?
c:c.
M s A n a.e ja
'N$ ",'.;T D.. F d.1 1 10
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St.
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10K ucaid like to ship cssential caterial of f site to ver.dere. !ct 5
fabricatic...
I i
Crinding is roi;uired in rome cases to prepare essential velds fcr 7.
NDE exa=ination.
Is this per=itted?
1 Are vc prohibited from receiving and reiasuing essent.a1 =aterial to i
A.
eentractors,on site provided they are not used in construction?
Ve vould like to conduct evaluations of cr.isting essential coatings 9
which require taking sa= pics and conducting tests.
We veuld like to continue electrical testing of cables and logic 10.
t wting.
Is this per=itted?
per=itted to physically move ecchanical equipment provided it 11.
Is it does not enhance construction?
.~..
Are we permitted to continue application of fire barriers classified 12.
as i=pertant :o safety not listed as essential?
V.,y ve proceed with hydrostatic, pneucatic testing and NDE?
13.
Installation of cirror insulation on the FSV vessel. May it proceed?
I'.
ec:= unique in response to our request vould be appreciated.
r pt Ycry truly yours.
1HE CINCINNATI CAS & C.ECTF,IC COMPA.W
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E. A. EORCMANN SENIOR VICE PgESIDENT Ei't : ' a d NKC Office of Inspection & Enforce ent cc:
- 'ashincten. D.C. 20555
'C.C Senfer Resident Inspector
. F. Christianson Attn:
/ir er Preicet Inspector Eccien !!!
.