ML20033B081
| ML20033B081 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/24/1981 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20033B079 | List: |
| References | |
| EA-82-012, EA-82-12, NUDOCS 8111300350 | |
| Download: ML20033B081 (16) | |
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Aprendix A NOTICE OF VIOLATION
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AND
. PROPOSED IMPOSITION OF CIVIL PENALTIES i
Cincinnati Gas and Electric Company Docket No. 50-358 Wm. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 F
EA 82-12 l-
{
As a result of the investigation conducted at the Wm. H. Zimmer Nuclear Power.-
4 Station in Moscow, Ohio, on January 12 -.0ctober 9, 1981, the violations listed ~
below with multiple examples were identified. The 2merous examples of the 3
violations demonstrate your failure to exercise adequate oversight and control of your principal contractors, to whom you had delegated the work of estab-lishing and executing quality assurance programs,.and thereby-fulfill your responsibility of assuring the efiective execution of a quality assurance program. Your. failure manifested itself in a widespread breakdown in the implementation of ycur quality assuranc' program and caused the NRC to require an extensive quality confirmation program to provide confiddnce that safety-related structures, systems, and components will perform satisfactorily in service.. Included in the breakdown were findings we consider to be particu-larly disturbing relating to false records and harassment and intimidation of l
quality control inspectors.
Because of the significance of nu.. having complete and accurate records, not maintaining a work atmosphere where quality assurance gersonnel are not harassed or intimidated, and not assuring implementat. ion of an effective quality assurance program which identifies and correccs construction defi-ciencies, and in accordance with the Interi1: Enforcement Policy, 45 FR 66754 4
(October 7,1980), the Nuclear Regulatory Commission proposes to impose civil.
penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, l
("Act"), 42 U.S.C. 2282, and 10 CFR 2.205 in the aiaounts set forth for the violations listed below.
A.
10 CFR 50, Appendix B, Criterion.WII states, in part, " Sufficient records shall be maintained to furnis'. evidence of activities affecting quality."
i l
Contrary to the above, records were identified that did not furnish evidence of activities affecting quality in that they were false.
Examples of false records are as follows:
1.
Isometric drawings, weld inspection records, or other records did not furnish evidence of the actual piping components installed in the 11 pipelines in the diesel generator cooling water, starting air I
and fuel oil systems,-in that the heat numbers recorded on the drawings or weld inspection records did not match the heat numbers or color coding marked on the respective components. The 11 pipe-lines were:
}
8111300350RT1h4 DR ADOCK 0500 58 PDR t
Appendix A (Continued).
IDG28AB1 1DGC5AA3/4 IDG28AE1 1DG27AB1 1DGF6AA1/2 1DG25AC2 1DG01AB1 IDGC5BA3/4 IDG11AA3 IDGF2AA1/2 1DGF6BA1/2 2.
The Kaiser Nonconformance Reporting Log did not reflect all reports initiated as evidenced by the following:
The original entry for a' report (CN-4309) initiated by a QC a.
Inspector on January 7, 1981, relating to deficient weld fit-up was obliterated by the use of white correction fluid and^there was no other record of this report in the Noncompliance Report 1
(NR) system, b.
The. original entry for a report (CN-5412) initiated by a -QC Inspector on February 3, 1981, and relating to violation of a hold tag was obliterated by the use of white correction fluid and there was no other record of this report,in the NR system.
A report (h3C-0001) initiated by a QC Inspector on February 11, c.
1981, relating to excessive weld weave was not assigned a number and there was no other record of this report in the NR system.
3.
Written statements as to planned actions which were made.to justify
. voiding reports E-1661 (voided 11/11/80), E-1662 (voided 11/11/80),
and E-2466 (voided 6/30/80) were not taken.
4.
Written statements relating to the availability of records which were made to justify voiding reports E-1777 (voided 4/30/79) and E-5108 (voided 6/20/80) were false.
5.
Reports CN-5476,-CN-5477, and CN-5479 were knowingly improperly voided (2/27/81) and copies deleted from the NR system at. the direction of the Kaiser QA Manager.
This is a Severity Level III violation (Supplement II).
(Civil Penalty - $50,000).
B.
.10 CFR 50, Appendix B, Criterion I states, in part, "The persons...
performing quality assurance functions shall have sufficient... organ-izational freedom to identify quality problems... including sufficient independence from cost and schedule."
The Wm. H. Zimmer QA Manual, Section 1.2.3 describes QC Inspectors as members of QAD (Quality Assurance' Division) and Section 1.2.4 states, in part, "QAD has been assigned sufficient... organizational freedom to identify quality problems..."
Appendix A (Continued).
Contrary to tne above, QC Inspectors did not have sufficient freedom to identify quality problems and were not sufficiently independent from cost and schedule. The results of interviews indicate that some QC Inspectors were:
(a) harassed by construction workers and super-visors; (b) not always supported by QC management; and (c) intimidated.
The following are examples of-insufficient freedom of QC Inspectors, including insufficient freedom from cost and schedule, which occurred between Summer 1978 and March 11, 1981:
1.
Five QC Inspector.s interviewed executed signed sworn statements wherein they claimed they were doused with water (while engaged in the performance of inspection duties) by construction personnel.
Two other QC Inspectors made similar statements.
2.
A QC Inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were re-assigned by QC management because of complaints by construction personnel.
3.
Two QC Inspectors executed signed sworn statements wherein they claimed they had been harassed by being searched for alcohol by security personnel at the request of construction supervisory personnel. One other QC Inspector made a similar statement.
4.
A QC' Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after con-struction personnel complained he had used a magnifying glass to visually inspect a weld when in fact he was using a mirror and either device was an acceptable tool.
5.
A QC Inspector executed a signed sworn statement wherein he claimed he was struck by a stream of water from a fire extin-guisher while performing an inspection.
6.
A QC Inspector executed a signed sworn statement wherein he claimed he was threatened with bodily harm by a construction person if he did not pass a weld.
7.
A Lead QC Inspector executed a signed sworn statement wherein he claimed:
a.
He was accused by the QA Manager for holding up a concrete pour when in fact the delay was caused by the concrete trucks being late.
b.
Construction management frequently approached QC Inspectors and challenged their inspection findings and questioned their judgement.
Appendix A (Continued).
c.
The QA Manager said things like, "our job here is to accept, not reject, and we are here to get this plant built."
8.
A Lead QC Inspector executed a signed sworn statement wherein he claimed he was relieved of his inspection duties because he con-tinued to submit legitimate nonconformance reports over construc-tion management objections for deficient welds on pipe support hangers. He also stated that QA management had previously told QC Inspectors to not write anything to make Kaiser look bad.
9.
A QC Inspector executed a signed sworn statement wherein he claimed he was told by QA management to accept inspected items that were unacceptable.
This is a Severity Level III violation (Cupplement II).
(Civil Peaalty - $50,000).
C.
10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear power plants to document, by writtsn policies, pro-cedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents.
Contrary to the above, Cincinnati Gas and Electric Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as evidenced by the following examples:
1.
10 CFR 50, Appendix B, Criterion XV states, in part, "Noncon-forming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
Kaiser Procedure QACMI G-4, " Nonconforming Material Control,"
provides detailed instructions for the review and disposition of reports (Nonconformance Reports) of nonconforming items.
Contrary to the provisions of QaCII G-4, the sample of NRs reviewed indicate significant deficiencies with the nonconformance reporting system in the areas of voiding of reports, not entering reports into the system, improper dispositianing of reports, and incomplete report files. The deficiencies identified were as follows:
a.
Two NRs related to documentation deficiencies had been ir properly voided ia that records used to justify the voi fing did not provide evidence necessary for proper voicing.
(P;bE-2233 voidtd 1/24/80, NR-E-2237 voided 12/19/79)
Appendix A (Continued) b.
One NR related to nondestructive examination of a T-quencher weld had been erroneously closed (not voided) by adminis-trative error.
(NR-E-2996 closed 3/17/81) c.
Two NRs related to nondestructive examinations of service water system welds had been incorrectly dispositioned (not voided).
(NR-E-2836 closed 11/13/80, NR-E-2596 closed 4/16/80) d.
Five reports had been voided by personnel other than the QA Manager. -(CN-5122 voided 1/2/81, CN-5476 voided 2/27/81, CN-5477 voided 2/27/81, CN-5479 voided 2/27/81, CN-4389 voided 12/02/80)
In one case during revisions of the report some nonconforming e.
items were removed from a NR without adequate justification.
(NR-E-2466 voided 6/30/80) f.
The following nine reports had not been issued NR numbers and/or copies of the reports had not been reta,ined in the Site Document Center:
CN-4389 CN-4957 CN-4930 CN-4958 CN-4931 CN-4959 CN-4955 CN-5122 CN-4956 2.
10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations... and nonconformance are promptly identified and corrected."
The Wm. H. Zimmer QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformances in receiving inspection, construction, or testing activities which are delegated to HJK Quality Assurance Procedures to assure that nonconforming items are conspicuously marked to prevent their inadvertent use or installation."
AWS Code DI.1-1972, Section 3 and 8.1.5 define requirements for weld quality and address slag, weld profiles, blowholes, porosity, and undercut.
AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch minimum radius for re-entrant corners.
Contrary to the above, the following nonconforming conditions were not identified and corrected:
Based on an inspection of the 25 structural hanger support a.
beams described in Item C.4 below:
Appendix A (Continued).
(1) Several welds on nine beams did not canform with AWS D1.1-1972 requirements in that they contained unaccept-able slag, weld profiles, blowholes, porosity, and/or
~
undercut.
(2) Five' beams did not conform with AISC requirements in that the re-entrant corners were notched, creating potential stress risers, instead of being rounded with required radii.
(3) Four beams, two of which had unacceptable welds as described in Item C.2.a.(1) above, did not conform with design documents in that they were not specified on any design document.
b.
Based on an inspection of about 100 cable tray hangers in the Cable Spreading Room, four did not conform with AWS D1.1 1972 requirements in that the welds contained unaccept-able slag, weld profiles, blowholes, porosit, and/or undercut.
3.
10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations...and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
The Wm. H. Zimmer QA Manual, Section 16.5 states, in part,
" Vendors, contractors, and subcontractors a e required to determine cause and corrective action to prevent recurrence of errors which could result in significant conditions adverse to quality."
ASME Code, Section III-1971 Edition, Article NB-3661.5(b) states, in part,
...a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before welding."
ASME Code, Section III-1971 Edition, Winter 1972 Addenda, Art.icles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, NA-4451, NB-4230, and NB-3661.5(b) require, in part, in process inspections for pipe fitup, weld procedure, weld filler metal traceability, and welder qualifications...
Contrary to the above, the NRC inspectors identified the following ~
nonconforming conditions that had not been corrected and action had not been taken to preclude their repetition:
Appendix A (Continued).,,
a.
Licensee records indicate that the socket engagemeit (fitup) for more than 439 socket welds was not verified in accordance with ASME Code, Section III-1971 Edition Article NB-3661.5(b) 3 and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back'to 1979.
b.
Licensee records indicate that the 2n process inspections for more than 22 welds in the diesel generator cooling water, starting air, and fuel oil piping systems were not performed by Kaiser in~accordance with ASME Code, Section III-1971-Edition, Article NB-3661.5(b), et al., and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1978.
c.
Five licensee QA audits (audit performed 8/8-9/74 - no number, and Audit Nos. 78/07, 78/u9, 78/10, 80/04) of Sargent & Lundy identified repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications and action was not taken to preclude repetition.
4.
10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials... These measures shall assure that identification of the item is maintained..."
The Wm. H. Zimmer QA Manual, Section 8.2 states, in part, "H. J. Kaiser Company procedures provide that within the H. J. Kaiser Company jurisdiction the identification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other appropriate means. This identification may be on the item or on records traceable to the item. The identification is maintained through-out fabrication, erection, and installation. The identification is maintained and usable in the operation and maintenance program."
Contrary to the above, based on an inspection by "RC inspectors in March 1981 of approximately 25 structural hanger support beams located in the Blut Switchgear Room and the Cable Spreading Room, j
the identification of the material in nine of those beams was not l
maintained to enable verification of quality.
5.
10 CFR 50, Appendix B, Criterion III states, in part, 7!easures shall be established to assure that applicabic regulatory require-ments and the design basis...are translated into... drawings..."
The W. H. Zimmer FSAR, Section 8, provides the design basis for m
electrical cable separation that includes the followiag:
Appendix A (Continued).
Associated cables (Green / White, Blue / White, and Yellow / White) from more than one Division cannot be routed in the same raceway.
(FSAR Paragraph 8.3.1.13.2)
Vertical separation of three feet or more must be maintained between cables from different. Divisions.
(FSAR Paragraph 8.3.1.11.2.1.d)
Instrument (low-level signal) cables cannot be routed in the same raceway with power and control cables.
(FSAR Paragraph 8.3.1.12.1.3)
The Wm. H. Zimmer QA Manual, Section 3.3.2. states, " Composite...
drawings are prepared, translating the design concepts into layouts of structures, systems, and components necessary for the construction of the plant."
Contrary to the above, as of March 1981, the FSAR design basis for electrical cable separation had not been translated into drawings and this resulted in the following cable installation deficiencies in the Cable Spreading Room:
a.
Associated Cable (Yellow / White) No. RE053 for Division I was routed in the same raceway (two-inch conduit and Class IE Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2.
hiso, Associated Cable No. RE053 was routed so that in places there was only a vertical separation of four inches between it and cables in Blue Tray No. 2072C for Division 2.
b.
Instrument Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Asso-ciated Control Cables (Yellow / White and Blue / White) for-Divisions 1 and 2.
This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3029K) inside a White Control Tray (No. 4638B).
c.
Many Associated Cables from all three Divisions were routed in the same raceway (White Tray No. 4080K) including Cable (Blue / White) No. TI192, Cable (Yellow / White) No. RR781, and Cable (Green / White) No. TI816.
d.
Associated Cables (Yellow / White) No. TI942 and No. TI943 for Division 1 were routed in the same raceway (White Tray Riser No. RK4627) as Associated Cables (Blue / White) No. TI808 and No. TI760 for Division 2.
e.
Many Associated Cables (Yellow / White) for Division 1 were touted in the same raceway (White Tray Riser No. 4139) as Associated Cables (Blue / White) for Division 2.
Appendix A (Continued).
6.
10 CFR 50, Appendix B, Criterion III states, in part, " Design control measures shall be applied to...the delir~-tion of acceptance criteria for inspections and tests."
The Wm. H. Zimmer QA Manual, Section 3.13.1 states, in part,
" Design control measures also apply to delineation of acceptable criteria for inspections and tests."
Weld acceptance criteria are required by the ASME Code, Section III-1971 Edition and the AWS D1.1-1972 Code.
Contrary to the above:
The weld acceptance criteria used by H. J. Kaiser Company a.
from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were deleted.
b.
The acceptance criteria for Weld 55H (isometric drawing PSK-1WS-32) performed on Service Water System Line No.
1WS17A18 by H. J. Kaiser Company in November 1979 were not applied in that they were designated as not applicabic.
7.
10 CFR 50, Appendix B, Criterion XI states, in part, " Test results shall be evaluated to assure that test requirements have been satisfied."
The W'. H. Zimmer QA Manual, Section 11.1 states, in part, " Test m
programs to assure that essential components, systems, and struc-tures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construction site."
ASME Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..."
M. W. Kellogg Co. (pipe manufacturer and agency performing the prefabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 2o, 1972, Paragraph 4.1.8, states, "Wherever required, shims shall be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal plus the height of the crown or reinforcement."
Contrary to the above, the licensee's review of 187 radiographs did not assure that test requirements were satisfied in that the licensee failed to detect that the penetrameter shimming was insufficient to satisfy the requirements of M. W. Kellogg Procedure t
Appendix A (Continued) -
- No. ES-414 or the ASME Code. This deficiency was identified during the NRC review of approximately 800 radiographs involving 206 pre-fabricated pipe welds in such systems as main steam, feedwater, and diesel generator support systems.
8.
10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design control) shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled...The design control measures shall provide for verifying or checking the adequacy of design."
The Wm. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are specified and included in design documents."
The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled."
The Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verification reviews are performed...."
The Wm. H. Zimmer FSAR Section 8.3.3.1.1 states that cable ampacity is based on IPCEA Publication No. P-46-426.
An additional limita-tion on cable ampacity as stated in Section 8.3.3.1.3 is that "the summation of the cross-sectional areas of the cables shall not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross-sectional area in any case."
AWS DI.1-1972 Code, Section 3.6.4, states, "For building and tubular structures, undercut shall be no more than 0.01 inch deep when its direction is transverse to primary tensile stress in the part that is undercut, nor more than 1/32 inch for all other situations."
Contrary to the above:
a.
As of March 1981, design control measures had not been established to assure that deviations from design conditions (quality standards) identified by Sargent & Lundy engineers were controlled. For example, Sargent & I, undy noted on a calculation sheet dated December 27, 1979, that the design thermal loading for two power cables (VC016 and VC073) in Yellow Tray No. 1057A would allow the cables to be thermally overloaded and no program existed to control those design deviations.
Appendix A (Continued)..
b.
As of March 1981, design control measures had not been established by Sargent & Lundy to provide for verifying or checking the adequacy of the design for the thermal loading _
of power cable sleeves and the physical weight loa' ding of cable trays.
c.
As of March 1981, the cable ampacity design by Sargent &
Lundy was not based on IPCEA P-46-426 and the FSAR limit on cross-sectional area.
d.
As of March 1981, the design allowable undercut on cable' tray hanger welds was not based on AWS D1.1-1972 Code (appro-priate quality standard). The design undercut was instead based on Sargent & Lundy Specification H-2713, Supplement 7, Sargent & Lundy Standard EB-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph 5.2.9, allowed up to 1/16 inch undercut.
9.
10 CFR 50, Appendix B, Criterion X states, in parf., "A program for inspection of activities affecting quality shall be estab-lished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."
The Wm. H. Zimmer QA Manual, Section 10.1.2 states, in part,
" Inspections are performed in accordance with written procedures which include requirements for check lists and other appropriate documentation of the inspections and tests performed."
AWS D1.1-1972 Code, Section 3.10.1, requires work to be ccepleted and accepted before painting.
Contrary to the above:
a.
As of March 1981, a QC inspection program had not been estab-lished to require verification of separation of electrical cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RIl03 and CM111 that had been routed into Tray Riser (Green)
No. 3025A, which extended from Tray (Blue) No. 2077A in the Cable Spreading Room to the Control Room.
b.
The programs established for in process and final inspections of welds on 180 cable tray hangers located in the Cable Spreading Room were not executed as required in the AWS D1.1-1972 Code.
Specifically, the final weld inspections were made after the welds were painted (Galvanox).
Appendix A (Continued).
10.
10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
The Wm. H. Zimmer QA Manual, Section 5.1 states, " Construction, fabrication, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures, and drawings which prescribe acceptable methods of carrying out those activities."
The Wm. H. Zimmer QA Manual, Section 3.12 states, in part, " Design changes... including field changes, are subject to design change control measures commensurate with those applied to the original design."
Contrary to the above:
Kaiser Procedure QACMI G-14, " Surveillance Reports," (SR) was a.
not appropriate to the circumstances in that it allowed in process nonconformances which constitute field changes to be dispositioned within 30 days without being subjected to design control measures commensurate with those applied to the original design. Examples of nonconformances so dispositioned were identified in SRs F-2899, F-2903, and F-2914.
b.
Kaiser Procedure QACMI G-14 was not followed in that SRs F-2909, F-3070, F-3071, F-3072, F-3073, F-3074, F-3075, F-3076, F-3083, and F-7019 were not dispositioned within 30 days and were not transferred to Nonconformance Reports as required by Paragraph 5 of QACHI G-14.
11.
10 CFR 50, Appendix B, Criterion VII states, in part, "The effectiveness of the control. of quality by contrac' ;rs and subcontractors shall be assessed by the applicant or designee...."
The W. H. Zimmer QA hanual, Section 7.3.1 states, in part, "As m
part of the vendor selection process, SSL makes an independent evaluation of the bidders' QA programs as a part of their total bid evaluation."
Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the control of quality by vendors who had supplied structural beams. Specifically, evaluations of the vendor (U.S. Steel Supply, PBI Steel Exchange, and Frank Adams Company) quality assurance programs for control of mill certifications and structural beams were not performed.
4 a
Appendix A (Continued) <
12.
10 CFR 50, Appendix B, Criterion XVII states., in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include... monitoring of i
1 work performance, and... include closely-related data such as qualifications.of personnel, procedures, and equipment."
The Wm. H. Zimmer QA Manual, Section 17.1.4 states, in part,
" Documentation of all performance surveillance includes personnel-identification and qualification, procedure, type observation, date of performance, person or organization monitored, results and corrective action if required."
Contrary to the above, the Bristol Steel and Iron Work: Quality Control Steel Erection Report, which was a generic form for monitoring in process steel erection, did not identify closely related data such as weld procedure numbers, types of welding material, welder identification, and specific welds inspected.
J 13.
10 CFR 50, Appendix B, Criterion XVIII states, in part, "A com-prehensive system of planned and periodic audits shs11 be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."
The W'. H. Zimmer QA Manual, Section 18.1 states, in part, "QA m
Division conducts a comprehensive system of planned and periodic audits of S&L, HJK...to verify compliance with all aspects of the quality assurance program."
i i
Contrary to the above, during the past 9 years the licensee's QA Division did not perform an audit of the Sargent & Lundy
{
nonconformance program.
.i This is a Severity Level II violation (Supplement II).
1 (Civil Penalty - $100,000).
i Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric Company is hereby required to submit to this office within S0 days of the date of this Notice a written statement or explanation, including for each alleged violation:
(1) admission or denial; (2) the reasons for the vio-l lation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
Any statement or explanation may incorporate by specific reference (e.g.,
giving page and paragraph numbers) the provisions of your quality confirma-tion program and your actions in response to our Immediate Action Letter of April 8, 1981. Consideration may be given to' extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
i
Appendix A (Continued) Within the same time as provided for the response required above under 10 CFR 2.201, Cin:innati Gas and Electric Company may pay the civil penalties in tha cumulative amount of Two Hundred Thousand Dollars or may protest icposition of the civil penalties in whole or in part by a written answer.
Should Cincinnati Gas and Electric Company fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the aacunt proposed abave.
Should Cincinnati Gas and Electric Conpany elect to file an aner in acenrdance with 10 CFR 2.205 protesting the civil penalties, such answer may:
(1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this llotice; or (4) show ther reasons why the penaltics should not be im-posed.
In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
Any answer in accordance with 10 CFR 2.205 should be set forth separately from the statetent or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific rererence (e.g., giving page and paragraph numbers) to avoid repetition.
Cincinnati Gas and Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties.
Upon failure to pay any civil penalties due, which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COM11SS10N
/
Richard C. D '
ng, D ctor Office of In p ction u d Enforcement Dated at Bethesda, Maryland this 24 day of Navenber 1981
e a
Appendix B CROSS
REFERENCES:
NONCOMPLIANCES TO REPORT DETAILS Noncompliance Criterion Report Section i;
A.1 XVII 4.3.3.7 and 4.3.3.8 A.2 XVII 4.1.3 A.3 XVII 4.1.3 A.4 XVII 4.1.3 A.5 XVII 4.1.3 B.1 I
6.1.3 B.2 I
6.1.3 B.3 I
6.1.3 B.4 I
4.4.4 B.5 I
6.1.3 B.6 I
6.1.3 B.7 I
6.1.3 B.8 I
6.1.3.
B.9 I
6.1.3 C.1 XV 4.1.3 C.2.a XVI 7.1.3.2 C.2.b XVI 5.10.3.2 C.3.a XVI 4.3.3.6 C.3.b XVI 4.3.3.6 C.3.c XVI 7.3.3 C.4 VIII 7.1.3.3 C.S.a III 7.2.2 C.5.b III 7.2.2 C.5.c III 7.2.2 C.S.d III 7.2.2 C.S.e III 7.2.2 C.6.a III 6.2.2 C.6.b III 6.2.2 C.7 XI 5.8.3.10 C.8.a III 5.10.3.3.6 C.8.b III 5.10.3.3.5 C.8.c III 5.10.3.3.3 b C.8.d III 5.10.3.2 C.9.a X
7.2.2 C.9.b X
5.10.3.2 l
l
C.10.a V
6.3.1 o
C.10.b V
6.3.1 C.11 VII 7.1.4
(; C.12 XVII 7.1.5 4
C.13 XVIII 7.3.1 O,
...