ML20053E581
| ML20053E581 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/07/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8206090039 | |
| Download: ML20053E581 (94) | |
Text
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COMMISSION MEETING In the Mat:::ar cf:
PUBLIC MEETING BRIEFING ON STATUS OF ZIMMER INVESTIGATION 58-355 k
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DATE:
June 7, 1982 PAGES:
1 - 76 AT:
Washington, D'. c.
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m' REPORTING ALDR%X c
400 Vi_ginia Ave., S.W. W=*hd"gt.=:, D. C. 20024 Talaphc=a : (202) 554-2345 l
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1 UNITED STATES OF AMERICA 2
3 NUCLEAR REGULATORY COMMISSION 4
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PUBLIC MEETING H
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I E
7
_____________________._______________________x 8
BRIEFING ON STATUS OF ZIMMER INVESTIGATION 0
ci 9
I Y
10 2
Commissioners' Conference Room 5
11 Room 1137 1717 H Street, N.W.
j 12 Washington, D.C.
3 Monday, June 7,1982 j
13 a:
l 14 The Commissioners met in public session, pursuant to 2
15 notice, at 9: 39 a.m., NUNZIO PALLADINO, Chairman of the Commission i
16 presiding.
g as b'
17 COMMISSIONERS PRESENT:
18 NUNZIO PALLADINO, Chairman 2
VICTOR GILINSKY, Commissioner 19 JOHN F. AHEARNE, Commissioner a
THOMAS ROBERTS, Commissioner 20 JAMES ASSELSTINE, Commissioner 21 STAFF AND PRESENTORS SEATED AT COMMISSION TABLE:
22 S. CHILK L. BICKWIT 23,
G.
CUNNINGHM4 i
J.
KEPPLER 24l D.
HUNTER AUDIENCE SPEAKERS:
i R. W ARNICK i
h ALDERSON REPORTING COMPANY, INC.
(
DISCLAIMER This is an unofficial' transcript of a meeting of the United States fluclear Regulatory Comission held on June 7, 1982 in the Cocaission's offices at 1717 H Street, N. W., Wasnington, D. C.
The meeting was open to public. attendance and observation.
This transcript
- has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational pureoses.
As provided by 10 CFR 9.103, it is not part of the formal or infonnal record-of decision of the matters discussed. Expressions of opinion in
.this. transcript do not necessarily reflect final determinations or
- , ; beliefs.
No pleading.or other paper may be filed with the Qomission in any proceeding as the result of or addressed to any'orize.
statement or argument
(.-
contained herein, except as the Comission may auth l
(
.)
../
2-3 1
PEREE3RINEE CHAIRMAN PALLADINO:
Good morning, ladies and gentlemen.
2 The Commission meets in open session this morning, to re-3 4
ceive a briefing from the NRC staff on the Zimmer investigation, o
5 The purpose of this briefing is to provide the Commissioners with I
8 6
a discussion of the problems uncovered in the investigation, the e
f7 Region III passed and proposed actions to be taken in response, 8
and the quality confirmation program undertaken by the licensee.
de 9
Although we are meeting today in open session, some to-i h
10 pics and questions may arise that should be discussed in closed 3
5 11 session.
d 12 The staff and general counsel will advise us on this 3c d
13 matter.during the course of the briefing.
S I would like to have these questions or topics held off, E
14 U
15 so if possible, we need close the meeting only once.
16 I gather general counsel has a comment that he feels
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17 would be appropriate at this time.
18 MR. BICKWIT:
Yes, sir.
There is a motion to reopen c
l t
19 and some contentions that are relevant to the subj ect matter that i
R 20 is going to be discussed at this morning's meeting.
Because the Commission's investigatory and enforcement 21 22 jurisdiction is implicated, the separation of functions prohi-23,
bitions that might otherwise apply, do not apply.
24 There would be no problem from a separation of functions 25 standpoint with closing certain portions of the meeting, or in I
ALDERSON REPORTING COMPANY, INC.
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4 1
fact with closing the entire meeting.
CHAIRMAN PALLADINO:
I gather we can proceed with the 2
3 open items, and then you can advise us if we get into areas that 4
ought to be closed.
MR. BICKWIT:
That is right.
e 5
5 COMMISSIONER GILINSKY:
Which areas should not be dis-8 6
e m
j 7
cussed?
E 8
MR. BICKWIT:
There is no area that need not be discussed n
9 from a separation of functions standpoint.
As far as areas that z
are inappropriate to be discussed in an open session, that has C
to C
3 5
11 nothing whatever to do with the separation of functions con-d 12 st raints.
It has to do with carrying out of an investigation Z
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d 13-by an enforcement and investigatory agency.
5 COMMISSIONER GlLINSKY:
You are saying there are portions E
14 w
we cannot discuss in open session but can in a closed meeting?
15 5:
MR. BICKWIT:
That is right.
16 3
M COMMISSIONER GILINSKY:
When you said there was a motion g
j7 to reopen, where does the hearing stand?
18 5
MR. BICKWIT:
The record is closed.
The Licensing Board 19 k
20 has not yet issued its decision.
The motion before the Licensing Board to reopen the record is pending.
2j COMMISSIONER GILINSKY:
How does that motion affect this?
22 MR. BICKWIT:
If you were not discussing matters under 23,
which your enforcement jurisdiction was implicated, the fact that 24 l
a motion to reopen was pending would entail some separation of t
25 i
ALDERSON REPORTING COMPANY. INC.
5 functions consequences, with regard to the subject matter of that j
2 motion to reopen.
The basis of the motion to reopen is the licensee's 3
activities involving quality assurance and management generally 4
are d'efective.
This is now a. matter, as a result of the motion e
5 to reopen, which is in contention, in a pending proceeding.
6 e
f7 The question then erises, can a party and the ultimate decisionmaker discuss these matters in either open or closed j
8 a
dd 9
session.
The answer is yes, because the decisionmaker is also z
h 10 an enforcement agency, and needs advice from its staff with respect 2
to its enforcement functions.
I 11 COMMISSIONER AREARNE:
Is the motion based on any speci-d 12 E
fic ~ informatio.n?
13 S
MR. CUNNINGHAM:
The motion contains allegations that E
14 w
the movement has specific information, but that specific infor-2 15 5
mation is not set forth in the motion itself.
16 3
M CHAIRMAN PALLADINO:
Any other questions?
Any opening j7 b
18 remarks any Commissioner would like to make?
5 (No response. )
E 19 A
COMMISSIONER GILINSKY:
If I may ask one question.
Were 20 these issues in contention in the hearing before the record was gj closed?
22 MR. BICKWIT:
The quality assurance, matter was not an 23 issue in contention in the hearing.
Certain matters were raised 24 involving equipment, which relates to the general quality 25 j ALDERSON REPORTING COMPANY. INC.
6 i
assurance question.
COMMISSIDNER GILINSKY:
Thank you.
2 CHAIRMAN PALLADINO:
Unless any of the other Commissioners 3
have any questions, I would suggest turning the meeting over to 4
e 5
Mr. Keppler.
H MR. KEPPLER:
Thank you, Mr. Chairman.
Good morning.
A 6
e On October 27th of last year, you will recall that I 7
briefed the Commission on the results of the NRC's investigation l
8 d
into alleged quality assurance and construction problems with d
9 i
h 10 Zimmer, the steps we took to assure the quality of ongoing work E
and to confirm the adequacy of completed work, and planned enforce-I 11 d
12 ment action.
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During the past month, there has been renewed interest od 13 S
in Zimmer on the part of the intervenor organizations and by the E
14 w
2 15 congressional oversight committees chaired by Congressman Udall w
E e
16 and Congressman Ottinger.
3d Dr. Myers of Congressman Udall's staff visited the Zimmer g-17 site on May 3rd, and we gave him a briefing of almost four hours 18 on Zimmer on May 10th.
19 n
Following feedback from Dr. Myers' site visit, Chairman 20 Palladino asked me to brie f him.
After that brie fing, he sug-2j gested I arrange to give a similar briefing to the entire 22 Commission.
23,
As you know, more recently, Congressman Udall's 24 25 !
Committee has announced their intent to hold a hearing on Zimmer.
i ALDERSON REPORTING COMPANY, INC.
e 7
I believe that is established for the 10th, Thursday of this week.
)
2 With respect to your comments, Mr. Chairman, there are 3
a couple of issues that relate to the ongoing investigation effort 4
that I would like to suggest be saved until the end and possibly e
5 be brought up in a closed session.
These relate to investigation H
6 matters that are not yet resolved and for which I think there m
E 7
may be some interest on the part of the Commission.
COMMISSIONER AHEARNE:
Jim, I guess I am somewhat E
8 n
dd 9
puzzled.
The impression one could have received is back in i
h 10 October you presented us with a description on some alleged QA Z
I 11 problems and enforcement actions, and recently, there has been d
12 congressional interest.
Z cd 13 Is it not true that you also :have other items that have EF E
14 occurred?
w MR. KEPPLER:
Absolutely.
2 15 COMMISSIONER AHEARNE:
It is not merely congressional 16 i
3 l
W 17 interest as re-interest of the NRC or contined NRC interest?
g 18 MR. KEPPLER:
I can assure you, Commissioner, that we b
have been investigating problems down at Zimmer since last Novem-19 8n l
20 ber.
We have an ongoing effo.rt down there to try to confirm the 21 quality of construction.
22' I brought it up only in the context that there has been 23 renewed interest.
COMMISSIONER AHEARNE:
It just sounded like we are 24 25l interested because Congress is interested.
I i
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ALDERSON REPORTING COMPANY. INC.
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MR. KEPPLER:
I did not mean to give that implication.
/
I am sorry.
2 Could I~ have the first slide, please?
3 (SLIDE. )
4 MR. KEPPLER:
What I hope to accomplish during this 5
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h briefing today is to give you a discussion on the investigation 8
6 e
5 and the problems identified, to discuss the actions Region III a
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took in response to the problems identified.
Much of this will 8
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go over the history of what we discussed last November.
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We want to get into the quality confirmation program h
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s gj in some detail, in,cluding a status and what our concerns are at the moment, and the'n discust.<1th you future actions.
d 12 (SLIDE.)
2 13 3
MR. KEPPLER:
This is just shown to give you a chrono-14 logy of what has happened in the investigation.
I am going to 2
15 through this in some detail, so I will not keep the slide up l
16 g
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lo ng.
w 18 I want to' briefly discuss the events that led up to the 5
investigation, the actions we took, and where we are headed at 19 8
n the moment.
l 20 I
COMMISSIONER GILINSKY:
I wonder if you could say a few 21 words about what came before 1980.
One of the questions that 22 keeps coming up is how could we run into something so late this i
23,
date in the process.
24 Were there signs along the way 'of problems?
- 25f, I
ALDERSON REPORTING COMPANY. INC.
9 l
MR. KEPPLER:
I guess there are two things I could dis-1 2
cuss, Commissioner.
One would be the earlier involvement with 3
Mr. Applegate.
COMMISSIONER GILINSKY:
Did that come before 1980?
4 MR. KEPPLER:
Yes, in 1979 e
5 E
d 6
I think the question you are asking is perhaps even more e
fundamental.
You are asking why is it we find major problems 7
8 in an investigation of this type, and why did they not surface N
to us earlier.
9 i
h 10 Is that really the question you are asking?
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11 COMMISSIONER GILINSKY:
Yes.
This is not the only case d
12 of this sort that we are dealing with.
We have run into,a number 3
of.these around the country, certainly in other regions, *as well.
13 E
It is hard to tell.
Are we looking harder than we had E
14 U
k 15 in the past?
16 MR. KEPPLER:
Let me give you my personal views on the a
M 37 matter.
You will' recall that when we testified before the Udall b
18 Committee last November, this subj ect did come up, in terms of
=
U why was the NRC so late in learning about some of these problems.
j9 8n A number of reasons were advanced at t hat t ime.
20 21 I think perhaps the most fundamental reason that I have 22 come up with is the focus of our inspection programs was on 23 individual findings.
We were not able to make the connection 24 of seeing the forest for the trees, so to speak.
25 '
I think we were focusing on symptoms and not on the ALDERSON REPORTING COMPANY. INC.
O 10 root causes of problems.
j When you sit today and look at the history of Zimmer, 2
there were some very fundamental questions in my mind which should 3
have been asked right from the very beginning, and they were not.
4 COMMISSIONER AEARNE:
Such as?
5
=
3 MR. KEPPLER:
Such as why an utility only had six quality 6
o assurance inspectors right from the very beginning.
You would 7
think that would be a very fundamental question we would ask.
g N
We did not.
9 i
h 10 I think what happens, and I guess I have to digress a E
jj little, you must realize that the average effort t hat the NRC jj is putting on construction inspections is on the average of one 6
12 E
man year per year at a facility.
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13 S
You are talkids about sites that have two and three g
34 s
k 15 thousand workers.
i The basic philosophical tenet.
of our inspection program 3,
16 as is making the assumption that the utility and its constructors j7 b
18 and its architect engineers are dedicated to doing the job right.
5 In my view, we should have been asking fundamental E
19 2
t questions like, here is a brand new utility in this business,
20 and a constructor that has had virtually no commercial nuclear 21 experience before, and that should have told us something.
It 22 did not.
23,
I think what happened is as we went through our inspec-24 25 l tion program, we identified problem areas.
You can go back in i
ALDERSON REPORTING COMPANY, INC.
11 the record and find them.
We did not come away with the big pic-2 ture problem of this.
We focused on this item of non-compliance 3
and that it em o f non-compliance, and we dealt with those individual 4
symptoms and we never went after the root cause of the problem.
e 5
You can say, what is the matter with your inspectors, R
8 6
what is the matter with the supervisors.
We all share in this.
1 E
7 As you said, Commissioner, at the hearings last year, 3
8 8
back 10 or 15 years ago, we were promoting utilities of this type d
d 9
to get into this business.
I guess I see a lot of room to spread z
10 the blame.
z 5
11 The symptoms were there.
I cannot deny that.
When you o
12 go back and look at the inspection history in this plant, you z
3l 13 come away with the feeling, we should have found these problems
=
l 14 and we should have known better.
We did not.
2 15 COMMISSIONER AHEARNE:
You have given a fairly complete,
.s 16 if somewhat heated description, as to what we should have done-BW b'
17 in that plant.
There are a number of other plants under con-18 struction.
5 19 Do you have any greater confidence that we can now see 1
8 l
20 the forest in those plants?
21 MR. KEPPLER:
At this stage of the game, I cannot tell 22 you that there is not another Zimmer out there.
However, the 23, staff, in response to the commitments made by the Commission at i
24 the Udall hearings and in response to the Chairman's letter, has 25 put together a program which should be before the Commission i
ALDERSON REPORTING COMPANY, INC.
12 shortly, 'to deal with the whole issue of quality confirmation j
and quality assurance.
2 I can tell you that in Region III, what I have done, 3
and that is at least as to all the other construction sites that 4
are in a similar time period, have gone out and looked fqr the e
5 3
basic symptoms of some of the problems we readily see at Zimmer 6
i e
today, to see whether they are prevalent at some of the other g
7 sites.
8 N
CHAIRMAN PALLADINO:
Jim, maybe later in the discussion 9
i 10 it might be well to return to this question and see what lessons c
z ij we learned that might require some Commission action.
3 MR. KEPPLER:. Fine.
d 12 E
CHAIRMAN PALLADINO:
That go beyond this particular case.
13 E
COMMISSIONER GILINSKY:
That was the point I was raising.
E 14 w
b f
15 We are looking harder now and are we looking hard. enough.
n MR. KEPPLER:
If I could add another thought.
One of 16 aW d
17 the big things that already has been done, in my view, is the 18 stiffening of our enforcement posture over the last couple of-E j9 ye ars.
A 20 If you go back in time, certainly before this Commission 21 put forth its views on enforcement and the need for a stronger 22 enforcement image, you can probably count on one b9.nd the number of civil penaltias or serious sanctions that, were levied against 23,
24 constructiJn sites.
I do not mean to dismiss the type of very strong action 25 ALCERSON REPORTING COMPANY. INC.
13 I
we took at Marble Hill, for example, which I thought was very 2
meaningful.
3 When you look perhaps at the concept of civil penalties, we really did 'not issue many civil penalties at construction sites.
4 a
5 I think you are well aware that more are coming forth 2
in that area.
I think that helps a lot.
6 I believe there was always a feeling that there was not 7
a need for a sense of urgency during construction.
There was 8
not an immediate health and safety problem and if you did not 9
1:
g jo find the problem today, you would find it tomorrow or it would surface through pre-operational testing.
jj There are a lot of factors here.
It is not a simple d
12 Z
analysis.
I am.'sure:other people here could give you their views 13 5
E 14 as to what went wrong.
N
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15 When you come right down to it, whatever contributed 5
to this and to the South Texas problems and the WNPPS problems
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it-16 ej and so forth, in my view, it was the failure to see the root j7 b
18 cause of the problems and get it corrected soon.
You had the E
symptoms there.
j9 R
COMMISSIONER AHEARNE:
You have used " root cause" several 20 times.
What do you see at Zimmer as being the root cause?
21 MR. KEPPLER:
-I think the most fundamental issue in my 22 view is the fact that Cincinnati Gas and Electric did not overview 23,
the project.
They in effect relied totally on Kaiser to do the 24 i
25 l job and in effect expected a turnkey proj ect from them.
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ALDERSON REPORTING COMPANY. INC.
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COMMISSIONER AEARNE:
We have the case on the West Coast-y where the company did overview the proj ect.
They acted as their 2
own architect engineer.
3
~4R. KEPPLER:
Yes.
I would separate the two issues of 4
the design concern versus the construction quality concern.
At
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5 M
le ast in my own mind, I see a differentiat' on between those two.
i 6
e Do you want to touch on the previous Applegate infor-7 mation?
8 CHAIRMAN PALLADINO:
I will leave it to your discretion.
9
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10 MR. KEPPLER:
I might as well bring it up since I already 7
z mentioned-it.
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jj
' is Let me say before we go into these particular events d
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that led into this investigation effort, we became involved with
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g'4' a Mr. Thomas Applegate, who made allegations to us about co n-sa -
struction deficiencies in early 1980.
2 15
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Mr. Applegate's involvement with the Zimer proj ect
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1,6
!j'.37 started some time in late 1979 At that time, he was working as a private investigator for an investigation service.
18 While working on a case, he found that one of the 39 H
individuals involved was employed at Zimmer and was involved in l
20 time card cheating.
He approached his employer and Cincinnati i
21
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Gas and Electric Company with this information, and che 22 investigation service was given a thirty day contract to investi-23 l gate time card cheating at the site.'
f 24 This ef fort was completed within a couple of weeks.
15,i f
I ALDERSON REPORTING COMPANY, INC.
15 1
Mr. Applegate at that time began to pursue some rumors 2
of improper site construction.
He brought the' matter to Cin-3 einnati Gas and Electric.
They indicated they were aware of his 4
findinga and the contract was not renewed.
=
5 Our first e,ntact with Mr. Applegate occurred on February b
6 28, 1980.
We interviewed him in person on March 3rd.
He provided 7
us with a number of allegations, several of which did not relate s]
8 to activities under NRC's jurisdiction.
d d
9 We picked out those allegations that we believed to be i
h 10 matters which NRC should pursue.
We sent a letter to Mr. Apple-3 5
11 gate detailing three allegations that we intended to investigate.
d 12 We did this investigation in May and issued a report
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9 13 in the first part of July.
That finding w.as not viewed as a S
E 14 significant matter from a public health and safety viewpoint.
W 2
15 The next point of this chronology starts here, when on U
16 November 18th, a former quality control inspector at Zimmer, who 3
i d
i 17 is now working at another construction site, made allegations N
18 to our resident inspector concerning the adequacy of the quality 5
19 assurance program at Zimmer.
8n 20 He stated that the quality assurance manager for the 21 constructor, Kaiser Engineers, was improperly handling non-22 conformance reports, transferring gaality control inspectors when l
23,
they found too many problems, allowing impro.per quality control 24 inspections and not properly supporting the QC staff.
25 (SLIDE.)
i l
ALDERSON REPORTING COMPANY. INC.
1 16 MR. 'KEPPLER:
We contacted this alleger, but because 1
of scheduling difficulties with the holidays, we did not start 2
the investigation until after the 1st of the year.
3 Before that investigation of the specific allegations 4
by the ex-quality control inspector was initiated, the Government a
5 8
6 Accountability Project, the Institute of Policy Studies' GAP, e
7 sent a letter to the Merit Systems Protection Board alleging that 8
the earlier investigation we had conducted into Mr. Applegate's N
allegations was negligent and provided a number of new allegations 9
i h
10 concerning Zimmer.
E At that point in time a decision was made that the l
11 a
d 12 Office of Inspectors and Auditors would investigate the adequacy of the earlier Region III' investigation,,and that Region'III 2
13 S
g j4 would pursue the new allegations,' along with the allegations a
2 15 received from the ex-quality control inspector.
w M
16 You are familiar with the OIA investigation report, and aW g-37 I do not intend to pursue that, unless you have questions.
18 The on-site investigation commenced on January 12, 1981.
E (SLIDE.)
19 20 MR. KEPPLER:
During the course of this investigation, 21 a number of other allegations were brought forth by contractor workers and former construction workers.
22 23 i COMMISSIONER GILINSKY:
On their own initiatives?
MR. KEPPLER:
Yes.
Many people came forth.
We inter-24 i viewed on the order of 100 people during the course of this 25 i
i ALDERSON REPORTING COMPANY. INC.
17 1
investigation effort.
The investigation from January throudh March identified 2
a number of quality assurance problems and construction problems 3
4 at Zimmer.
CHAIRMAN PALL ADINO:
This was in 1981?
g 5
A s
6 MR. KEPPLER:
Yes.
e What we have done on this slide is break down the major 7
8 i problems identified into the reviews of the allegations provided d
d 9
by Mr. Applegate, and the GAP organization, the ex-quality control i
h 10 inspector, from the additional people who came forth and then 3
5 11 while our inspectors were reviewing these allegations, they came onto other things, and they are broken down into that cate5 cry.
d 12 E
COMMISSIONER AHEARNE:
Just as a comment I would guess 13 a
l 14 that is an interesting way of breaking it down, but it seems the focus is more on how did tre find out about problems rather than 2
15 s
16 what are the problems at Zimmer.
Rw d
17 I would think the important breakdown would be these 18 are the important problems, these are unimportant problems.
19 MR. KEPPLER:
I think we view these as all important.
n 20 We put on the important ones on this list.
There were others.
21 I think the intent, Commissioner, of showing it this 22 way was really to give the perception that everybody had a con-23 f tribution to make.
We got information from,a lot of sources.
24 I will not read the items but we viewed the significant 25 l problema as those related to the quality 6f records, traceability ALDERSON REPORTING COMPANY. INC.
18 of materials, handling of non-conformances, the interface between
- j construction and quality control, the structural welding work 2
and I think, most important, the licensee's overview of the ongoing 3
work.
4 CHAIRMAN PALLADINO:
Jim, you have the words " improper e
5 5
voiding of non-conformance reports."
Does that mean to imply 8
6 o
there is a proper voiding of non-conformance reports?
7 E
8 MR. KEPPLER:
Yes.
n N
CHAIRMAN PALLADINO:
Could you give a feel for when it 9
z 13 proper and when it is not?
h 10 Z
MR. KEPPLER:
Can you elaborate?
5 ij MR. HUNTER:
Any time a person in the field finds a non-d 12 3
con' forming condition, he should identify it, if he perceives the:
2 ' 13 condition as being non-conforming.
E 14 w
There normally is and should be a screening process where 2
15 u
the supervisors and the people in the field could in fact address 16 W
the items and could disposition the non-conformance report at d
17 18 level 8-5 The point we are trying to make here is~that those 19 ea dispositions would be in the records and we could review and audit 20 the disposition of those early non-conformance reports, if you 21 will.
In some cases, they may have been pulled out of the records 22 and in some cases we found the non-conformance reports were 23,
i 24 j actually not in the record system.
t COMMISSIONER AHEARNE:
They voided them by elimination?
25 l
?
I 1
ALDERSON REPORTING COMPANY, INC.
19 MR. HUNTER : You should not void any legal records by j
elimination.
2 COMMISSIONER GILINSKY:
Where did you find them?
3 MR. HUNTER: They were stored in different areas of the 4
plant, different desk drawers.
We actually had people bring in a
5 M
non-conformances where they kept copies, which in fact had been 6
o dis c arded.
These are all being pursued in the investigation.
7 COMMISSIONER GILINSKY:
They apparently were not destroyed 8
MR. HUNTER: These were copies.
The original may have 9
z h
10 been destroyed.
They keep copies of most of their work.
z!
11 MR. KEPPLER:
That finding was part of the reason we issued a separate fine for false records.
d 12
(
3 CHAIRMAN.P ALL ADINO :
A voided non-conformance report,
13
._oa not necessarily an tmproper action, but. it can be.
E 14 U
k 15 MR. HUNTER:The manner in which it was done.
1 CHAIRMAN PALLADINO:
Thank you.
16 M
MR. KEPPLER:
By the end of March,1981, we had deter-37 b
18 mined there was a serious breakdown in the controls for assuring
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39 quality at Zimmer.
We gave serious consideration at that time R
to suspending construction.
There were many people on my staff 20 who felt that was the proper course of action.
21 (SLIDE.)
22 MR. KEPPLER:
We made the decision,not to stop con-23,
struction because the majority of the problems at that time that 24 had been identified were more of the controls used to assure l
25 ;
ALDERSON REPORTING COMPANY. INC.
9 20 i
quality and we had not found at that time a significant number 2
of hardware problems.
We felt that the ongoing work would not compromise the 3
4 ability to determine what had already been done.
We felt the e
5 ongoing work could be controlled.
b We focused our attention on establishing controls to 8
6 7
assure the quality of ongoing and future work, and to define a M
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program to both confirm the quality of completed work and correct n
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any identified deficiencies.
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10 (SLIDE.)
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11 MR. KEPPLER:
This slide shows the results of a meeting d
12 we had with the utility at the end of March, to require certain 3
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act-ions to be taken for the control of ongoing ahd future work.
13 5
E 14 Basically, these were actions to correct identified quality w
2 15 assurance weaknesses and to preclude their reoccurrence.
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16 CHAIRMAN PALLADINO:
Jim, what led you to feel at the Bw l
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17 end of March in 1981 that you could control the work that would 18 be ongoing, whereas before that, it did not seem possible?
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Because basically the utility had been n
20 virtually out of the action, as far as we were concerned.
What 21 it took was to put management controls on and people into the 22 action.
23 CHAIRMAN PALLADINO:
Did we add to pur staff there?
24 l MR. KEPPLER:
From the time the investigation started, i
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I 25 we were continually adding people to the proj ect, yes.
AL.DERSON REPORTING COMPANY. INC.
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l 21 1
CHAIRMAN PALLADINO:
Are you going to cover that along 2
the way?
3 MR. KEPPLER:
Yes.
4 COMMISSIONER GILINSKY:
When did we have a resident e
5 inspector there?
b 8
6 MR. KEPPLER:
We had a resident inspector there before e
7 this period.
I would have to check as to when we first put him 8
there, but I believe around 1979 He was down there for the pur-n N
pose of following the pre-operational test program and the 9
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10 readiness for operation.
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it Back in 1979, the utility was talking about starting d
12 this plant up, to give you a feel for how this has dragged on.
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U 15 COMMISSIONER GILINSKY:
When did Zimmer get a construc-N 16 tion permit?'
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17,
MR. KEPPLER:
I believe it was in 1972 or early 1973 E
18 It was 1972.
5 COMMISSIONER AHEARNE:
Let me ask a question the Chair-19 '
20 man asked but in a slightly different way, to go back to an 21 earlier finding.
22 What you are now saying is that early in 1981, you put 23 l on a larger scale effort which started on January 12th, and at 24 '
the end of March, you met with the utility, and this flowed to 25,
all these changes?
I I
i ALDERSON REPORTING COMPANY. INC.
c 22 MR. KEPPLER:
Yes.
j COMMISSIONER AREARNE:
In South Texas, we had a similar 2
situation in which the Region had done a number of investigations 3
4 and nothing had happened, and then I&E Headquarters put on a big e
5 effort and suddenly it turned out there were very major problems 5
8 6
which led to a lot of things.
e 7
What is the trigger here?
You had done a previous 8
investigation in 1980 and the result of that 1980 investigation n
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basically was nothing really serious, and then suddenly, you have i
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11 Earlier you described the process as missing the forest.
d 12 In 1980, there was an actual investigation focused on QA problems.
3 MR. KEPPLER:
The investigation that was conducted in
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16 we did not take the concerns --
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17 COMMISSIONER AHEARNE:
Was the difference in the Spring 18 of 1981 that there were more areas to be focused on?
5 E
19 MR. KEPPLER:
In all candor, the allegations that were 5
20 brought forth by the ex-construction worker at the other site 21 really hit the biggest picture with us.
22 I mentioned he focus ~ed on how the quality control was 23 l being implemented, in a bigger picture sense,.
It seems like i
24 everything sort of steamrolled from there.
25
- Mr. Applegate had a number of allegations, which by i
l ALDERSON REPORTING COMPANY,INC.
23 themselves may not have been any big issues, but were more of j
2 the picture.
These other workers that were coming forth, just 3
the sheer volume of' allegations was turning us in every direction.
I guess when you are hit with the broad side of a board',
4 5
you see the picture a lot easier.
e 5
COMMISSIONER AHEARNE:
A 2x4 caught your attention.
8 6
e COMMISSIONER ROBERTS:
Could'you explain the relation-7 8
ship between Sergeant Lundy and Kaiser and the utility?
N MR. KEPPLER:
Sergeant Lundy is the architect engineer 9
i jo for the facility.
Kaiser was the constructor and the utility e
3 5
11 was the owner.
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12 At this point, what really happened, we in effect 3
told Cinci'nnati Gas and Electric, you have to manage this proj ect -
13 5
E 14 now, if you don' t, then we will take action to shut it down.
ab 15 We required them at that time to augment their quality 5
16 assurance staff, both in terms of numbers and technical expertise.
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18 that, re-inspection, not going along with them when they did it,
E 19 but actually re-inspecting the work of the quality control people b
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21 CHAIRMAN PALLADINO:
Who was to do that?
22 MR. KEPPLER:
CG&E.
23 ;
COMMISSIONER GILINSKY:
That is why. they needed these l
24 200 people?
l I
25 MR. KEPPLER:
They needed a lot o f t hem.
A lot of them l
i ALDERSON REPORTING COMPANY. INC.
24 was for the ongoing work and quite a few of them related to the j
2 quality confirmation program.
COMMISSIONER GILINSKY:
In terms of the sheer size of 3
their QA staff, and.certainly six is a low number, ten or so per 4
reactor is not very out of line from what I have seen in other a
5 b
d 6
utilities, two unit stations, 20 odd people or so for QA.
e COMMISSIONER AHEARNE:
During construction?
7 A
COMMISSIONER GILINSKY:
Yes.
Am I wrong?
l 8
d MR. KEPPLER:
I-think the numbers are higher.
Let me d
9 eg 10 ask.
E COMMISSIONER GILINSKY:
It seems to me it must depend 5
11 a lot more,on what these people are doing.
I have run into num-d 12 E
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14 MR. KEPPLER:
I think they are generally higher than 2
15 that.
You are talking about j ust the utility?
i:
COMMISSIONER GILINSKY:
Just the utility.
16 3
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17 MR. KEPPLER:
Marble Hill went through a lot of problems.
I believe Marble Hill's numbers for the utility are up around 70.
18 i
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19 MR. WAZNICK:
100 to 150 odd.
I 20 MR. KEPPLER:
Everybody or just the utility?
21 MR. WARNICK:
Just for the utility.
COMMISSIONER GILINSKY:
I was under the impression the t
22 l
23 ;
numbers were smaller.
Just the people who are overseeing the r
24 i other QA programs, not people doing the checking themselves.
25 MR. KEPPLER:
Does that answer your question?
I I
i l
i ALDERSON REPORTING COMPANY. INC.
25 COMMISSIONER AHEARNE:
It addresses it.
I will think i
about the answer.
2 MR. KEPPLER:
I might comment on the first bullet, the 3
4 key management changes.
I think they are significant.
There were significant changes at the site, both in terms e
5 of the construction manager, in terms of the constructor's quality 6
assurance manager and Cincinnati Gas and Electric's quality 7
'8 as surance manager.
All of those people were replaced during this N
period, or subsequent to this period.
9 i
Cincinnati Gas and Electric at that time or shortly S
10 5l jj thereafter, brought in a new vice president solely for nuclear d
12 operations and nuclear plant activities.
3 I think that has helped.
In a very general statement, 13 S
I would say to you that we have been reasonably happy with the
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2 15 utility's progress under the immediate action letter.
If we felt 5
16 they were digressing too far, we would stop work.
k2 6
17 I do not want to give you the feeling there has been 5
5 18 no problems, but generally they have been complying.
5 19 COMMISSIONER GILINSKY:
Are they still at this 100 per-X 20 cent re-inspection?
21 MR. KEPPLER:
At this point, yes.
They have asked for 22 some relief from it to drop back down to a smaller percentage.
23 We have that under review now.
24 COMMISSIONER AHEARNE:
How much of the construction was 25,
completed when this system went into place?
I ALDERSON REPORTING COMPANY,INC.
26 1
MR. KEPPLER:
This project was basically 95 plus percent 2
complete.
3 COMMISSIONE3 AHEARNE:
To say that since then we are 4
happy with the progress does not necessarily --
=
5 MR. KEPPLER:
Just on the immediate action. letter.
6 COMMISSIONER AHEARNE:
It does not necessarily address
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how satisfied we are with the overall construction.
8 MR. KEPPLER:
That is a different issue.
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COMMISSIONER AREARNE:
It probably ends up being a 10 fundamental issue.
_z 11 MR. KEPPLER:, Yes, I qualified my comments with saying j
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12 with respect to the immediate action letter.
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' 13 I think that once we have taken care of the issue of l
14 controlling ongoing and future work, we focused our attention 2
15 on coming up with a program to in effect verify the quality of 5
j 16 the completed construction work and to put together a program e
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18 CHAIRMAN PALLADINO:
'dhat does 100 percent re-inspection
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20 MR. KEPPLER:
That means --
21 CHAIRMAN PALLADINO:
Let me put my question into con-22 text.
If there is a weld that had been inspected, and let's 23 ;
assume there were adequate records to show t,here was no flaw 24 in the weld, is that how far it goes or does it go farther and 25,
say those welds have to be re-inspected?
I I
i ALDERSON REPORTING COMPANY, INC.
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e 27
.MR. KEPPLER:
We are only talking about ongoing work, 1
2 not past work.
CHAIRMAN PALLADINO:
I thought it said 100 percent re-3 4
inspection of contractor's QC inspection.
5 MR. KEPPLER:
For ongoing work.
=!
COMMISSIONER AHEARNE:
The contractor inspects it and 3
6 7
they re-inspect it.
8 MR. KEPPLER:
Yes.
N COMMISSIONER AHEARNE:
They are checking how good a job 9
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10 the contractor's QC inspectors are doing?
Z 5
11 MR. KEPPLER:
That is right.
d 12 CHAIRMAN PALLADINO:
Not verification of past work?
z MR..KEPPLER:
No.
13 S
E 14 COMMISSIONER AHEARNE:
It only addresses this roughly w
15 five percent of the work remaining, rather than the 95 percent 16 of the work already done.
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17 MR. HUNTER: Yes, sir, that is true.
To put it in context,
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18 there is a large amount of work required to be done today in terms
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20 because of changes in the requirements.
There is a large amount 21 of work going on in the immediate action program, or under the 22 immediate action letter.
23 To answer your question, Mr. Chairman, if a weld is put 24 in today to hcid up a-hanger, as an example, and Kaiser QC 25 inspectc that weld and passes that weld and accepts it, then g
0 ALDER 50N REPORTING COMPANY. INC.
28 CG&E is required to independently review that weld and agree with j
ib that.
If they reject it, that is resolybd and after the reso-2 lution, the weld is accepted.
It is 100 percent inspection of 3
every inspection, not just Kaiser QC but all contractor QC 4
activity.
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3 CHAIRMAN P ALL ADINO :
It is all ongoing work?
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MR. HUNTER: Yes, sir.
7 COMMISSIONER AHEARNE:
What kind of results are coming S
8 n
N from these double checks?
9 z
h 10 MR. HUNTER: I would say right now except in the hanger z
area, our response from the licensee and our status from the j
33 5
licensee shows the results are very good, that based on those 6
12 Z
results.they have requested to reduce the double dual inspection 13 S
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15 As I indicated, except in the area of hangers, where 5:
the results are a ritt?e higher than we think they ought to be, 16 k2 we should not have a problem with reducing the dual inspection g
37 5
M 18 program.
=
CHAIRMAN PALLADINO:
Do you want to go on?
j9 (SLIDE. )
20 t
MR. KEPPLER:
The identification of the quality l
21 assurance problems and the poor construction practices that we 22 23 found during that investigation effort, from, January through 24 March, and subsequently, cervinced us there had to be a meaning-ful program verifying the safety related systems and components 25
)
i ALDERSON REPORTING COMPANY. INC.
l
29 would perform their intended safety function.
j What we did was meet with the utility and in effect have 2
the utility establish a quality confirmation program, one that 3
the NRC would basically concur in.
They would implement this 4
pr gram and the NRC would closely follow the implementation of 5
A that program, and the NRC would do some independent measurements f its own to provide further assurances that the work has been 7
mpleted properly before any licensing action could be con-8 l
sidered.
9 2
Basically, the quality confirmation program dealt with 10 ez j
the problem areas that were identified in this next slide.
jj (SLIDE.)
d 12 3
COMMISSIONER AHEARNE:
Is this t.he retroapective?
13 S
MR. KEPPLER:
Determining the quality of completed work, E
14 a
2 15 7*8*
u f.
16 When we established this program, the one point I would 3
M like to make is we had certain problem areas that we were aware 37 a
b 18 f based upon our investigation effort, but we recognized as the
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investigation continued, that there would probably be other areas j9 this program might have to be expanded into.
20 21 We set this program up as flexible.
We are going to go into this in a little more detail.
I just wanted to get that 22 p int o ut.
23 I guess at t his point in time, I need to talk a little 24 about the effort the NRC made to try to put some perspective on 25l i
I ALDERSON REPORTING COMPANY, INC.
30 j
the investigation findings.
2 We had prepared our investigation report around the end 3
of the summer.
We were going to put it out at that time.
When 4
the report was under review by our Headquarter's staff, it was e
5 felt the report did not do a good job of addressing what the real b
8 6
problem of construction was at the site, as a result of these e
7 quality related problems, most of them at that time dealing with j
8 the controls used to assure quality.
n N
It was decided that we ought to try to put together a 9
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10 limited independent measurements program, to try to get a feel E
5 11 for whether or not the quality assurance problems represented d
12 a gross problem in construction or not, recognizing that in our E
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13 view at. this. time, we. still b.ad to g'o through a full quality con -
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14 firmation program.
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15 COMMISSIONER AHEARNE:
As I recall, at the time of the 16 briefing, a picture was presented that the plant seemed to have 3
A been built pretty well, it just did not do the job of keeping 6
17 l 5
18 records.
=
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The findings from that would suggest you n
20 could draw that conclusion, and that is a problem.
21 COMMISSIONER GILINSKY:
I had a recollection like that, 22 too.
When was that meeting?
I I
MR. KEPPLER:
That was in October.
23 I
24 (SLIDE.)
25 MR. KEPPLER:
This was the slide we showed at the i
I ALDERSON REPORTING COMPANY. INC.
31 j
meeting in October when we briefed the Conmission, to try to give 2
you a perspective on what we looked at with independent measure-ments and what we found.
3 4
The conclusion from that was we did not see a widespread e
5 construction problem.
A COMMISSIONER AHEARNE:
Looking at that straight con-6 7
clusion, one might focus on widespread and say the impression j
8 was there were a lot of construction problems.
n N
I came away from that meeting, and 'I think the transcript 9
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10 will support it that the general impression was the plant was 3
5 11 well built, a good construction manager, and very poor records.
d 12 MR. KEPPLER:
I think that view may have been expressed E
by some, but it. was.our view all along' that a quality confirmatior.
13-E E
14 program had to be carried out to establish the quality 'f this o
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2 15 plant.
.- 16 COMMISSIONER AHEARNE:
I do not intend to belocor the 3
M j7 point, but only say if the view was expressed, it was not refuted.
b 18 CHAIRMAN PALLADINO:
I remember a similar kind of n
19 l st at eme nt, t hat the construction seemed to be good but the n
20 records were not.
gi MR. KEPPLER:
Based upon the independent measurements 22 i that were done, one cou1d make that argument.
23,
I guess I feel a little defensive op the issue.
I do 24 not mean to.
Dr. Myers made the same comment, that he had the 25,
view that this slide was very misleading.
To some degree, it i
l ALDERSON REPORTING COMPANY. INC.
32 is misleading because it focuses -- that is why we redid the slide j
2 n the types of analyses conducted rather than on the actual 3
number of physical components or welds or what have you, looked at.
4 (SLIDE.)
5 e
E h
COMMISSIONER GILINSKY:
This is after we did the 6
e 7
independent measurements?
MR. KEPPLER:
This was the independent measurements we 8
9 did.
This puts it in terms of how many individual things were i
h 10 looked at.
xl jj Basically, the construction deficiencies identified, d
12 again, are not great, when compared to the total findings of qua-i
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.y.13 lity assurance.
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14 COMMISSIONER GILINSKY:
They are not great if you say t
5 15 five pipe weld deficiencies, but when you say five percent pipe E
16 weld deficiencies, that sounds like a lot.
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17 CHAIRMAN PALLADINO:
That statement may still be true.
5 M
18 MR. KEPPLER:
The quality confirmation program is going r
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5 to be the final judge as to how well this plant has or has not 19 b
20 been built.
21 COMMISSIONER GILINSKY:
Locking back on it now, when l
22 you say five potential pipe weld deficiencies, somewhere between 23 ;
five and ten out of 100, if you thought between five and ten 24 i percent of the welds were bad, that would be pretty serious.
25 '
MR. KEPPLER:
Let me have a moment.
l ALDERSON REPORTING COMPANY. INC.
33 (Whereupon, discussion was held off the record.)
1 2
CHAIRMAN PALLADINO:
Jim?
3 MR. KEPPLER:
I agree the other slide did not state it 4
the way it should be,, based on this information.
m 5
CHAIRMAN PALLADINO:
We really do not know at this point 5
in time whether that perception we had gotten in the Fall is 6
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7 correct or incorrect.
j 8
MR. KEPPLER:
I still feel we do not know yet how to n
d d
9 characterize this plant and we will not know until we get through Y
10 with this quality confirmation program.
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_l 11 COMMISSIONER AHEARNE:
The reason I put this huge stack a
y 12 cf things in front of me was not to block the view, but in case
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13 it. said we have plants in great shape, I was. going to point out, l
14 that we have a long history of information indicating there have 2
15 been a lot of problems and obviously we have to do more work g
16 before we can really say that.
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17 MR. KEPPLER:
In my view, in many ways, one of the 18 worse things we did was this independent measurements thing.
In
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20 so broad, that I was not going to be satisfied with anything less 21 than a full quality confirmation program.
22.
It turns out, even when you look today and find we 1
I examined 380 structural and hanger beam welds there, and really 23 24 did not find the problem when we did it, and yet they are 25,
tearing out a lot of walls on the site right now.
I l
I ALDERSON REPORTING COMPANY. INC.
34 If they are tearing them out because they do not co nform j
to code, one can argue whether they are good or not.
That is 2
another story.
The fact is they are being taken out, and that 3
to me implies there could be problems.
4 COMMISSIONER GILINSKY:
When they fix up the work that e
5 A
needs to be redone as a result of this re-examination, that is 6
covered by the 100 percent re-inspection?
7 CHAIRMAN PALLADINO:
The re-work.
8 MR. HUNTER: I believe it does.
It is under a separate 9
i 10 program but it is re-worked, in this case, like the control room ez j
jj structural welds are being re-worked by Catalytic, who happens to be a contractor.
That is being overviewed by CG&E.
d 12
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13 COMMISSIONER GILINSKY:
I am a little troubled.by your E
E 14
.saying you "believe."
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CHAIRMAN PALLADINO:
Could we check that?
2 15 w
MR. HUNTER: Yes.
It is, that is true.
16 3
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17 (SLIDE.)
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18 MR. KEPPLER:
This slide shows the enforcement action E
that was taken, that we chose to issue what really is an interim j9 l E5 20 investigation report, because we felt we had identified what the 21 maj or problems were.
We felt we had focused on the more sig-
[
22 nificant allegations at that time, and there was considerable public interest in the matter, and we chose to issue the 23j 24l investigation report at that time and take our enforcement action.
l COMMISSIONER ROBERTS:
Refresh my memory and tell me 25,
l ALDERSON REPORTING COMPANY, INC.
35 the severity level, y
i MR. KEPPLER:
We issued separate 2
fines for the wide variety of quality assurance deficiencies.
3 We broke out separately a fine for false records and harrassment 4
e 5
and intimidation of quality control inspectors.
R h
The licensee paid that civil penalty.
The response was 6
e 7
very voluminous, somewhat argumentative in spots.
Because of 8
f the other things, that has not received a high priority some 9
in responding to it, but we are working on it.
i h
10 COMMISSIONER AHEARNE:
I gather that the harrassment z
h~ 11 of QA inspectors in some way still continues?
3 d
12 MR. KEPPLER:
We h&d a situation down there that was
!5 13 bronght to the Commission's attention.
I,thinld we would like S
E 14 to make comments on that matter with the Commission separately.
- a 2
15 (SLIDE.)
s
?
16 MR. KEPPLER:
I just wanted to show you briefly here 3
as g
j7 the attempts we have made to focus attention on Zimmer.
18 Mr. Darwin Hunter is supervising the regional inspection Et-and surveillance efforts and investigation efforts at Zimmer.
j9 R
20 He is the Chief of the Proj ect Section 2B.
21 He has down there two resident inspectors and a third 22 resident inspector will be there shortly.
We have a full time proj ect inspector on the job and a full time investigator, and 23 ;
24 l that will be augmented with a second investigator.
I COMMISSIONER GILINSKY:
They are on site?
25,
i i
ALDERSON REPORTING COMPANY. INC.
36 MR. KEPPLER:
The resident inspectors are on site.
I 1
w uld say the others are there probably 50 percent of the time.
2 CHAIRMAN PALLADINO:
Which are there 50 percent of the 3
time, the investigator?
4 MR. KEPPLER:
The investigator and the project inspector e
5 2
and I think Mr. Hunter would attest he has probably been there 6l (7
50 plus percent of the time, too.
In addition, engineers from our engineering support 8
group and other inspectors in the regional office are being used 9
- i to assist the efforts as needed.
10 h
11 I would say right now we are probably devoting about 3
an average of eight to ten peop1*e to Zimmer, and that does not d
12 i5 include my time.
13 E
COMMISSIONER GILINSKY:
Is that enough?
E 14
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15 MR. KEPPLER:
I think the answer to that question is E
it is sufficient to stay on top of what is going on down there 16 is v5 37 and controlling it.
If we are looking for some more decisive b
18 approaches to it, it may not be.
We have some thoughts that we k
will explore with the Commission today that we are considering j9 i
now.
20 21 I guess I am of the view that we will probably have to do more.
22 CHAIRMAN PALLADINO:
There will have to be more?
23 24 MR. KEPPLER:
Yes.
25 CHAIRMAN PALLADINO:
This started in February of this l
l l
ALDERSON REPORTING COMPANY. INC.
e 37 year?
3 MR. KEPPLER:
We formed the sections.
2 CHAIRMAN PALLADINO:
What did you have before you formed 3
the sections?
Did you have this many people on it?
4 MR. KEPPLER:
Yes, but a lot of them were involved in g
5 N
other things.
What I tried to do with this effort was to recog-6 nice how big Zimmer was going to be to us organizationally.
I 7
needed to devote a dedicated group to Simmer.
8 N
COMMISSIONER AHEARNE:
Is this the only plant where you 9
i h
10 have this type of dedicated structure?
2 MR. KEPPLER:
At this moment, yes.
I 11 When we had the problems at Marble Hill, a couple or d
12 E
.three years ago,' we did not go quite to this e'xtent, but we dedi-13 E
E 14 cated some people to it.
w 2
15 I would emphasize that I have opened the channels with 16 Mr. Hunter, that he has direct access to me at any time through-Sw i
17 out this project, when he feels he is not getting the full 5
18 cooperation of the licensee or from our own organization, I am 19 committed basically to jump in on top of those problems.
5 20 CHAIRMAN PALLADINO:
Jim, before we started this 21 organization, did you have a comparable amount of dedicated staff 22 to this proj ect ?
23,
MR. KEPPLER:
To Zimmer?
No.
We w.ere probably putting 24 i about one man year of effort on it.
I 25 CHAIRMAN PALLADINO:
All the way up to February of 19827 I
ALDERSON REPORTING COMPANY. INC.
l 38 MR. KEPPLER:
No.
I would say in terms of the number j
2 of people that we had during the course of the investigation 3
initially to where we are now, it has been running fairly compa-rable.
4 e
5 CHAIRMAN PALLADINO:
During most of 1981, you had about 6
8 6
the same number of staff, but not recognized in this way?
e 7
MR. KEPPLER:
Yes, but they were focusing more on the 8
investigation findings, the major parts of the investigation, N
whereas the emphasis has shifted today to following the quality 9
- s h
10 confirmation program.
z h
11 We are still carrying out investigation efforts.
The d
12 manpower has shifted more toward the quality confirmation program.
3 COMMISSIONER AHEARNE:
You said you think you are going 13 5
E 14 to have to do more.
I gather you are going to tell us at some 15 point this morning things are worse then you had previously T
16 thought they were.
3 us j7 MR. KEPPLER:
No.
I am going to tell you about some 18 of the things that I think we ought to be considering, or we are 5
0 19 considering and perhaps ought to be doing further to confirm the A
l 20 quality of the plant.
21 I do not know what you meant by your comment.
22 t COMMISSIONER AHEARNE:
What I meant was so far, as you 23 started out the briefing in the beginning, the point I picked up 24 on was there was a heightened congressional interest, so you are 25; here to talk about it.
So far, it is a presentation of here is i
i l
ALDERSON REPORTING COMPANY. INC.
39 j
where things were going and after the March meeting, the immediate action letter, I think your quote was "we are happy with the 2
3 progress they have been making," all of that does not really 4
correspond to "we have to do more."
There must be something else.
5 e
5 d
6 MR. KEPPLER:
Perhaps things take their course for o
7 various reasons.
Had there not been heightened interest in this A
8 8
at this time, I would not be back here briefing the Commission a
dd 9
on this matter.
i h
10 COMMISSIONER AHEARNE:
You have this structure.
E 5
11 MR. KEPPLER:
I feel we have things under control the d
12 way we are doing it.
3 COMMISSIONER AHEARNE:
I thought your answer a minute 13 S
E 14 ago was that you have to do more, put more people on it.
w 2
15 MR. KEPPLER:
In terms of where we are today, we are 16 satisfied.
You start thinking about down the road and what will 3A d
17 it take or should it take for me to make a finding that this plant 5
18 has been completed, I think there are some things following the 5
19 quality confirmation program that we will want to explore.
9R 20 If I did not feel this quality confirmation program was i
21 proceeding on course, or if I do not feel the licensee was 22 controlling the work, I would take action and stop that.
23 !
I do not know whether I am answering your question.
24 The Chairman brought it up in the context of, do I have 25 l enough people.
I guess I have not put together a plan --
I l
i ALDERSON REPORTING COMPANY. INC.
40 COMMISSIONER AHEARNE:
Let me put the question different-i 2
ly.
You said you thought you would have to do more.
What is it 3
that you are not doing that you see is going to have to be done 4
that would require you to have more people?
e 5
MR. KEPPLER:
I think perhaps what we are talking about b
d 6
is some third party checks on the plant, perhaps because of the e
7 workload consumption, maybe they will want to consider consultants 8
on the mu tter, that type of thing.
n d
d 9
I am not prepared at this meeting to advance any i
h 10 recommendations or strategies.
I am just going to tell you, when E
5 11 we get down to the end, what I am considering at the moment.
d 12 CHAIRMAN PALLADINO:
Jim, are you saying this number z
13 of people you believe can accom'plish your, program of confirmation l
14 at least now?
m 2
15 MR. KEPPLER:
Yes.
When we get down to the point of 5
g'
~16 identifying how much re-work may have to be done, and what it is e
p 17 going to take to follow that re-work, that may be a different E
5 18 story and we may have to augment that, either through our own 5}
19 staffing, through consultants or third parties. -
n 20 MR. HUNTER:
As indicated in our briefing, we track the 21 status fairly closely.
We are only about 55 percent of the way 22 through to identify the problems, to confirm the quality.
We feel 23,
that after the completion of the quality conf.irmation program,'
i 24 there will be a substantial amount of re-work required, and will 25,
need additional engineering expertise, additional independent i
f I
ALDERSON REPORTING COMPANY. INC.
l
41' l
measurements to be performed by Region III and our support people.
j 2
At this time, for monitoring the program, we feel we 3
have a sufficient number of people to monitor.
We do team
+3 4
inspections routinely, so we try to keep on top of it, and wd are e
5 keeping on top of it.
U 6
Depending on the re-work, we may need more technical 7
people than I have at the present time in'the group.
8 COMMISSIONER AHEARNE:
Let me see if I can look at the d
d 9
slide and ask a couple of questions.
i 10 The completion date is the completion of the quality E
5 11 confirmation program?
d 12 MR. HUNTER:
The problem identification portion.
(
COMMISSIONER AHEARNE:
You then went on to say you would.
13 S
E 14 expect there may be some re-work required and you would need some W
.f y
2 15 additional engineering support to 'Serify that re-work.
16 MR. HUNTER:
Yes, sir.
That is true.
~
3w i,17 COMMISSIONER AHEARNE:
To put that int o' _c o nt ext, I would 5
18 imagine you could not make your finding until that re-work is P
{
19 completed, Jim, is that correct?
s a
l 20 MR. KEPPLER:
The finding of satis factory completion?
)
21 COMMISSIONER AREARNE:
Yes.
22 MR. KEPPLER:
Absolutely.
23,
COMMISSIONER AHEARNE:
Can,you make.a rough estimate l
l 24 l at the moment of when you think the plant may be completed?
25l CHAIRMAN PALLADINO:
The re-work?
!I ALDERSON REPORTING COMPANY, INC.
42 l
j MR. HUplTER:
At 55 percent, I do not think the licensee has provided us Kith enough information to make that~ determination.
2 MR. KEPPLER:
Let's bring up the next slide.
3 (SLIDE.)
4 MR. KEPPLER:
I think it might help to talk about the 5
af 6-quall*.y co firmagion program.
,This just gives the percentages of completion where they 7
j o
-8 are tod ay.
N 9
(SLIDE. )
4 4
g MR. KEPPLER:
These are the ones that we feel at t he h
10 Z.
moment ;are the more significant.
E 11 de MR. HUNTER:
We have identified out of the 11 tasks we
/ 3 'J2 n
have in the quality confinnation program and as Jim indicated d.13 o - s G
/
s_earlier, these particular areas came right out of the 81213 E
14 15 Investigation Report, the areas that we feel are questionable as amount of 16 potential problem areas that may require a significant 3e i
17 q re-work are in the area of structural steel.
w 18 At the pres ent time, the tasks have been completed 5
19 generally in the range of estimates from the licensee of 66 8n 20 percent and they had to stop the task in April and restart in the 21 latter part of April.
22 COMMISSIONER AHEARNE:
Why did they have to stop the 23 j task?
1 24 MR. HUNTER:
The task was stopped because of some e
25 questionable qualifications of people and their inspection results i
i 0
ALDERSON REPORTING COMPANY. INC.
[
43 showed some inconsistencies.
They were not getting the results i
2 they wanted or that they needed, and I mean that positively.
They were not getting good weld inspections.
They were not getting 3
4 good data.
They were inconsistent.
COMMISSIONER AHEARNE:
The inspectors?
e 5
b MR. HUNTER:
The actual inspectors themselves.
The d
6 e
{
7 licensee stopped the activity, retrained the inspectors, got some 8
8 chief weld inspectors in the field, and we have been monitoring a
d 9
this, and they restarted the activity.
z' h
10 CHAIRMAN PALLADINO:
Whose inspectors were these?
Z.
I 11 MR. HUNTER:
CG&E's inspectors in the quality confirma-d 12 tion program.
2
$ '13 COMMISSIONER AHEARNE:
Your four percent complete on S
E 14 that previous slide really addresses the fact that they had to w
i 2
15 res t art ?
16 MR. HUNTER:
They had to restart in April.
The t ask
~
3M d
17 l 1s going to run out.
Additionally, as an example, the licensee 5
18 is in the process of re-working the welds in the control room at b
19 this tine.
I think we are talking about five to ten percent that 8n 20 they are re-working.
l 21 COMMISSIONER AHEARNE:
It sounds like you are treating 22 weld quality in structural steel.
I am confused.
i MR. HUNTER:
The structural steel and the welds 23 l
24 themselves for the steel.
The next task has to do with the i
25 quality of the welds themselves, traceability, whether or not I
l l
ALDERSON REPORTING COMPANY. INC.
44 1
they used the right materials.
2 COMMISSIONER AHEARNE:
When you are talking about a non-3 conforming weld, you are lumping that into your structural steel 4
issue?
5 MR. HUNTER:
I believe that is true, yes, sir.
e U
6 JMMiddIONER AHEARNE:
I thought there was another issue R{
7 on structural steel as to whether they had the right kind of steel.
K 8
8 MR. HUNTER:
Within task one, the traceability of the ed 9
steel is in there.
I cannot give you the specific details on the N
10 individual structural steels.
El 11 COMMISSIONER AHEARNE:
You have a list that says here 3
(
12 are the problems with structural steel.
I would have thought 3
13 traceability of that steel -
l 14 MR. HUNTER:
It is in there.
I do not have a specific 2
15 impact on it as far as is the steel that is used for cable tray
~
j 16 hangers or the main structural steel, which one is the largest e
6 17 problem.
4
{
18 My understanding today is the other steel like cable P
19 tray hangers where they cut it into many pieces is the problem, n
20 which is also purchased differently from the structural steel.
21 COMMISSIONER AHEARNE:
That should actually be listed 22 under problems with structural steel?
23,
MR. HUNTER:
Yes.
Structural steel includes bolting 24 of steel, it includes a number of subcategories.
Until they get 25 i through the inspection of the structural steel, its connection i
ALDERSON REPORTING COMPANY, INC.
45 j
bolting and welding connections, beam connections, that appears 2
to be a potential problem and a significant problem.
3 The other is weld quality.
We are talking about ASME 4
and AWS which is your structural steel welds.
They have some weld a
5 procedures.
I believe the last status we had was five weld En 6
procedures were followed.
I realize that five weld procedures 7
appears to be a small number, but those weld procedures were used 8
in an enormous number and the application was very large.
d d
9 MR. KEPPLER:
What is the difference of the welds in i
h 10 one and two?
E 5
11 MR. HUNTER:
The welds in two would be the welder d
12 qualification and the procedure, where in one, it would be the 3
h.13 physical welds themselves.
E
~
E 14 MR. KEPPLER:
The same welds?
Pipe welds?
U f5 MR. HUNTER:
In two, it includes the AWS and the 16 structural steel welds both.
- W p
17 COMMISSIONER GILINSKY:
What is going to be done about 5
18 thousands of welds which might be called into question on the basis 5
C 19 of welder qualifications?
How do you cope with that?
20 MR. HUNTER:
The program is enormous.
The welds have 21 to be identified.
They have to identify who did the welds.
They 22 have to identify the weld material that was applied.
This includes 23,
structural and ASME, the type of material put.into the weld, the 24 procedure and the welder who actually applied the material, then--
25f COMMISSIONER GILINSKY:
The codes are referenced in l
l ALDERSON REPORTING COMPANY. INC.
46 1
our requirements.
2 MR. HUNTER:
The AWS specification is in the FSAR, if 3
the plant was built to that, and that is structural steel. That 4
includes control panels, control boards, main and auxiliary steel.
e 5
ASME is referenced in the FSAR and they are built to b
6 the ASME III and IX for welders and welder qualifications.
7 CHAIRMAN PALLADINO:
Are there questions about the inte-3l 8
Erity of welds in the primary system also?
d d
9 MR. HUNTER:
We have a recent 50 55(e) Report.
We have i
h 10 reviewed it.
They have indicated to us that in the range of seven E
11 welds, they have had a record problem which included the record
<m j
12 showing and in a specific case,. carbon steel weld rod had been E
13 logged into a stainless steel w' eld.
That is a specific recorde E
l 14 problem at this time and that is being reviewed by the licensee 2
15 and being monitored by us, to decide what to do with that type J.
j 16 of problem.
w g
17 i CHAIRMAN PALLADINO:
Are you sure the record is wrong?
N 5
18 Maybe the record is right.
E l
h 19,
COMMISSIONER ROBERTS:
It could not happen.
You cannot l
5 20 use a carbon weld rod on stainless.
[
21 MR. HUNTER:
Yes.
The disposition of that will be if 22 there is no method of showing carbon steel does not exist in that 23,
weld, then they will have to disposition the weld.
l 24 COMMISSIONER AHEARNE:
Disposition the weld?
25 MR. HUNTER:
Remove and cut it out, whatever is l
l ALDERSON REPORTING COMPANY, INC.
47 necessary to ensure it is stainless steel.
1 COMMISSIONER GILINSKY:
What is the history of these 2
50.55(e) Reports?
3 MR. HUNTER:
The general history is with the breakdown 4
in the quality assurance program back in the 1970 to 1981 period, e
5 An part of the breakdown includes reporting, not having good reporting d
6 e
k7 requirements, not having the reporting requirements well defined.
If you look at the trend of the 50.55(e) Reports today,
]
8 d
d 9
we are getting as many --
I h
10 COMMISSIONER GILINSKY:
Their reporting requirements z
or ours?
y; MR. HUNTER:
Their committing to our reporting require-d 12 Z
j3 ments.
Their procedures where. non-conformances and corrective E
action documents would in fact generate reported items to the NRC.
E 14 w
COMMISSIONER GILINSKY:
They were under reporting?
2 15
- z MR. HUNTER:
Yes, sir.
I believe so.
The reports out 16 3
M p
17 of the quality confirmation program and the reviews they are j
doing now, they are doing a verification program in addition to 18 5"
19 the quality confirmation program, and the reports are increasing k
20 in number.
Since the first part of 1981, we have already received 21 i
22 something like 16 or 17 reports.
COMMISSIONER GILINSKY:
Can you compare the number of 23 I
50.55(e) Reports you got from this plant over the past years 24 lI 25 compared to other plants?
l I
ALDERSON REPORTING COMPANY, INC.
48 i
MR. HUNTER:
I would say they are much less in number.
2 We would have expected more.
The quality confirmation program 3
and a verification program is being performed by the licensse and 4
by Kaiser and is causing them to report numerous findings.
e 5
COMMISSIONER GILINSKY:
Presumably that is why we dj 6
hear things that would have helped us spot the problems.
8 7
MR. HUNTER:
I would think if we compared one con-M 8
8 struction site with another, and if they are not reporting at the d
c 9
same level, it certainly would require us to look in more detail.
10 Maybe they are doing a better job or have better equip-3 I
11 ment.
d 12 C,0MMISSIONER GILINSKY:
Had the reporting reflected the E=
~
~
d 13 actuaI state of affairs.
E j
14 MR. HUNTER:
If it had, we would have caught on right 2
15 away.
5 y
16 The heat number traceability --
w g
17 MR. KEPPLER:
I do not know if I agree with that 5
18 assessment.
I feel the answer to that question is we should know 5
{
19 more if we had more given to us.
When you go back through our n
20 inspection reports, there is a lot of material there that I can 21 sit with 20/20 hindsight on today and wish I had acted on.
22 I think from an ideal perception, that is right.
You 23, have to recognize we were dealing with, during that time frame, 24 25 plants under construction, roughly, and a whole bunch under 25 '
operation.
l ALDERSON REPORTING COMPANY, INC.
49 1
I guess Zimmer did not get the priority it obviously 2
should have gotten in today's world.
3 COMMISSIONER GILINSKY:
Had the reporting reflected what 4
tne state of affairs seems to be, it would have stood out a lot e
5 more than it did, I would have thought.
8 6
MR. HUNTER:
I said I would hope that was true, I think e
7 it would.
I do not know.
8 COMMISSIONER GILINSKY:
Let me ask you about weld d
d 9
quality.
You say inability to qualify procedures and obtain 10 welder qualifications could draw in the question of quality of 3
l 11 welds.
3
~
12 What is happening to qualified procedures or obtaining c
j 13 welder qualifications?
\\
m l
14 MR. HUNTER:
There is a specific group of people at the E
2 15 site, CG&E and Kaiser, trying to establish the traceability of g
16 all of them. There have been 1,800 welders on site.
There are w
p 17 a number of welding procedures.
E 18 They are going back through to establish qualifications 5
{
19 and procedure qualifications for all of the activities pe ' formed M
20 by those people and use those procedures.
It is a very difficult 21 task.
22 COMMISSIONER GILINSKY:
Is this something they were sup-23 posed to do before, when you say some weld procedures not 24 qualified?
25 ;
MR. HUNTER:
If the quality assurance program had been ALDERSON REPORTING COMPANY, INC.
s 50 i
established up front, the first thing you do is qualify your 2
welder and certify and qualify him to a procedure so this problem 3
does not exist after the fact.
They did not do that adequately, 4
apparently, or they did not keep records adequately to show the welder was qualified or qualified to the procedure.
A N
d 6
Now, each weld that was done by those -welders or by those e
"k 7
procedures has to be looked at again.
They have some problems.
i 8
You can visualize the number of documents they have to review and dd 9
procedures to try to re-establish the fact that when a weld was i
h 10 put in, the welder and the procedure he used was qualified.
E 5
11 As an example, you have to be AWS qualified to a certain d
12 positloc, horizontal, vertical, whatever.
They have people who E=d*
welded in the field who were not qualified in that position, and 5' 13 E
14 that brings in that welding question and they will have to go back N
h 15 and look at that weld and decide what to do.
16 COMMISSIONER GILINSKY:
The welds that are not satis-3 4
6 17 factorily okayed through this procedure.till have to be looked at?
E 18 MR. HUNTER:
Yes, sir.
If they cannot show the welder 5
19 was qualified and the procedure qualified, and also weld quality Sn 20 is the material in the weld itself.
If they cannot show those 21 items, the welds will have to be dispositioned, cut out.
22 COMMISSIONER ROBERTS:
Not necessarily.
Depending 23 upon the application, you could make an exanination.
24 l COMMISSIONER GILINSKY:
You have to deal with each one.
25; MR. HUNTER:
You have to disposition as a category, I
i ALDERSON REPORTING COMPANY, INC.
51 l
group or whatever, since they have committed to the ASME code, j
then each of the deviations from the Code, they will have to go 2
to the code committee and get a deviation and we will audit them 3
for that deviation.
4 COMMISSIONER AEEARNE:
If I may take you back to a e
5 5l 6
question the Chairman asked earlier.
How much of the welds are 7
in the primary system?
E MR. HUNTER:
Something on the order of 105 welds in the 8
a dd 9
primary system.
At this time, I cannot give you a status on the 1:
h 10 condition of those welds.
The licensee has not provided us with E
5 it that status.
It is in the review stage.
d 12 They are having difficulty, being very candid, with 5
traceability o.f materials, establishing the specs thaIt app',1y to 13 S
E 14 the pipe, the spool pieces at the time the welds were put in, and w
E 2
15 as soon as they get a handle on it, they will present it to us 16 and we will know the " status" of the welds in the primary system.
t d
17,l That is the total number of welds in the system.
I do E
18 not have a status on those welds.
It is presently under review.
5 C
19 COMMISSIONER ROBERTS:
I hesitate to even ask this.
A 20 Is your investigation to date only on the site work?
What about 21 the work that was done off the site?
Those spool pieces came in 22 partially fabricated.
23 MR. HUNTER:
I can respond to that..
24 !
COMMISSIONER ROBERTS:
I would imagine there were more 4
25, welcs performed off site than on site.
i-t ALDERSON REPORTING COMPANY, INC.
4 52 1
MR. HUNTER:
There is a quality verification program 2
going on by Kaiser along with the quality confirmation program 3
being pursued by CG&E.
They are in fact reviewing the documenta-4 tion for all pre-purchased items, which includes spool pieces, e
5 motors, valves, whatever CG&E bought.
Kaiser's verification pro-U 3
6 gram is reviewing the documentation available for on site R
R 7
activities.
s l
8 We are monitoring both of these activities.
At this d
T2a d
9 time, our understanding is all the safety related equipment, if
$g 10 you will, will be verified prior to the completion of these two 3
l 11 programs.
s j
12 CHAIRMAN PALLADINO:
Before we go on, is there any 5
(
j 13 problem with going until' noon?
mj 14 (Commissioners indicated in the negative'. )
2 15 MR. HUNTER:
The last item is heat number traceabilit~y.
j 16 Heat number traceability generally has to do with ASME piping.
e p
17 As indicated, when you review the documents concerning heat E
18 number traceability, there is an enormous number of documents they
\\
=
5 19 have to review.
5 20 They are finding a significant number of documentation l
21 errors, where the documents are not showing enough data so they l
l 22 do have some questionable heat numbers on piping.
l 23,
We will observe the licensee when he decides how much 24 l piping is placed into question.
I cannot answer whether that is i
25 large, or which is small bore, the small piping.
It includes i
t ALDERSON REPORTING COMPANY, INC.
l
53.
1 all essential piping.
2 We also issued in our quality confirmation program, we 3
agreed there were some systems important to safety and they are 4
also reviewing those systems, and this type of documentation 5
problem exists generally in all the drawings they have gone through.
=!
8 6
We are talking about a drawing having one or more heat e
7 number traceability problems when we say 20 percent of 2,500.
It s
8 8
may be a small problem that can be taken care of very easily by a
d d
9 record review or it may be a substantial problem.
i h
10 COMMISSIONER GILINSKY:
What do you do if deficiencies E
I 11 were made and you do not know what the numbers are?
d 12 MR. HUNTER:
According to the ASME code and FS AR, and Ec
~
d 13 their commitmen,ts, they will have to.know the condition of the S
E 14 pipe, the type of pipe.
If they do not know, we will assume they w
2 15 will take it out and replace it with known pipe'.
16 CHAIRMAN PALLADINO:
If you are talking about large bore 32 g
17 pipes, that could be quite an understanding.
18 EiR. HUNTER:
Yes, sir.
=
h 19 COMMISSIONER GILINSKY:
Were the constructors N
. 20 unfamiliar with these requirements?
21 CHAIRMAN PALLADINO:
Do you mean Kaiser?
22 COMMISSIONER GILINSKY:
Yes.
23 MR. HUNTER:
I think in some cases,. they certainly were 24 more familiar with the problems in ASME and I think the records 25 l will reveal the problem will not be as large as it may appear up i
I f
ALDERSON REPORTING COMPANY, INC.
54 i
front today.
2 COMMISSIONER AHEARNE:
I guess at the moment I would 3
really urge you not to reach any conclusions on how things will 4
appear.
We have seen enough times where the "will appear" did not e
5 turn out that way.
5 6
MR. HUNTER:
In the structural area, there was less a
7 stringent controls applied in that area, and we do not know the M
8 8
extent at this time.
N dd 9
COMMISSIONER GILINSKY:
Those were covered by commit-Y 10 ments to comply with the code.
Were the constructors just not 3
I 11 familiar with those commitments?
d 12 MR. HUNTER:
I would have to assume that.
Sergeant 3c d
13 Lundy's specs exist.
The FSAR. existed.
At this time I could not E
l 14 answer why.
5 2
15 COMMISSIONER GILINSKY:
Was Sergeant Lundy involved in E
16 the construction beyond having provided the design?
Their 3W p
17 involvement as an AE was rather lighter than in most other cases.
N 18 MR. HUNTER:
I am not sure it was less.
The typical 5
E 19 Sergeant Lundy specification would be relevant to pumps or valves 5
l 20 or piping, then Sergeant Lundy would require procedures to 21 implement those specifications and reviewed through Sergeant Lundy 22 so they could see it was being implemented properly.
23,
That is my understanding at this time.
I 24 !
Again, it falls back on when you lose control of the f
I l
25l program, and say CG&E as the licensee did not audit that process 1
(
ALDERSON REPORTING COMPANY. INC.
55 was occurring the way it should.
The fact that the specs were j
not implemented in the field in the manner they should have been 2
was not identi fied.
3 COMMISSIONER GILINSKY:
Was Sergeant Lundy required to 4
make sure they were?
What were their obligations?
e 5
R MR. HUNTER:
They were under contract to provide the 6
e 7
specific ations, as I understand it.
It was CG&E's responsibility to see that it was done properly.
8 N
CHAIRMAN PALLADINO:
CG&E or Kaiser?
9 i
S 10 MR. HUNTER:
CG&E.
They delegated to Kaiser but they ez!
11 did not delegate the responsibility to see that it was done pro-e 12 perly.
E 13-COMMISSIONER GILINSKY:
As a practica'l matter,.they 5
E 14 delegated to Kaiser, but in fact, the responsibility is theirs.
5!
15 MR. HUNTER:
Yes, sir.
E 16 (SLIDE.)
s M
37 MR. KEPPLER:
What I have put on this slide is some b
18 things that have been done since I briefed you, Mr. Chairman, 5
19 simply I mentioned earlier I had reduced to writing the emphasis 95 20 I am giving the Zimmer proj ect with a letter to Mr. Hunter 21 informing him that I want him to bring to my attention promptly 22 any matters of concern on his part.
23 We mentioned we had hired another r,esident inspector 24 for Zi =ner.
This will be a third one.
Also, a construction 25j specialist.
I ALDERSON REPORTING COMPANY. INC.
56 1
We have taken steps to deal with the concerns raised 2
by Commissioner G111nsky's technical assistant and Dr. Myers, who 3
both viewed the site as being quite dirty and very poor in the 4
area of graffeti.
We agree with those observations.
We have taken e
5 steps to get it cleaned up.
b 8
6 CHAIRMAN PALLADINO:
Is that what this resident inspector o
7 is going to do?
8 (Laughter.)
n N
CHAIRMAN PALLADINO:
What is the resident inspector 9
i h
10 going to do?
E E
11 MR. KEPPLER:
The resident inspector will be following d
12 on the quality confirmation program, and having additional pre-E=
5-13 sence on the ' site.
g-E 14 CHAIRMAN PALLADINO:
I gather he has been brought up a
b!
15 to speed on this?
E 16 MR. KEPPLER:
He is not there yet, but he will be.
M p
17 I He is coming on June 27th.
He will be brought up to speed.
l 18 COMMISSIONER AHEARNE:
On your third item, let me
.5; 19 focus on the cleanliness aspect.
I am puzzled in the cense that n
20 your region has been inspecting and then over the last two years, l
i 21 you really have had this gradually increasing cranking up effort.
l 22 Are you saying there was a problem with respect to the 23 conditiens of the site, but in spite of having all these people 24 on site for the last two years, you did not notice it?
25l MR. KEPPLER:
I would say it in a different way.
ALDERSON REPORTING COMPANY, INC.
i
57 1
The cleanliness issue was not an issue six months ago.
2 I had Commissioner Gilinsky up at the site.
When we went through 3
a tour of the plant, it was fairly clean. -
4 Graffeti was terrible; the worse I have ever seen at e
5 that plant.
Ea j
6 The cleanliness issues today, I think, are tied to the
^n 8,
7 amount of re-work going on now.
When you are involved in focusing
'n j
8 on the re-work, I guess cleanliness does not sit as a high priority d
d 9
matter.
As it is brought to our attention, we agree it needs some 10 attention and we are taking steps.
Z 5
11 COMMISSIONER GILINSKY:
I must say that the matter of g
12 graffeti is not irrelevant.
~o y
13 COMMISSIONER'AHEARNE:
I did not say it was irrelevant.
14 COMMISSIONER GILINSKY:
I am not disputing what you are 2
15 saying.
It seemed to me at the time I went through the plant with g
16 Jim that indeed, the amount of graffeti was more than I have ever w(
17 seen anywhere.
It reflected to me that people just did not 5
18 respect their work and a management that was not prepared to take E
I 19 control of.the proj ect.
4 20 MR. KEPPLER:
The cleanliness problem, in my view, was 21 tied to the re-work going on now.
We do give an appropriate amount l
l 22 of attention to cleanliness during construction periods.
23 ;
An issue was raised about fuel load,.
The information i
24 that has been given to the Commission has on many occasions reflected a super optimistic fuel load date on the part of the 25 !
i l
ALDERSON REPORTING COMPANY. INC.
l
58 utility.
2 COMMISSIONER AHEARNE:
What is the current estimate?
3 MR. HUNTER:
December of 1982 was the last one we have.
4 COMMISSIONER GILINSKY:
It seems to me these estimates e
5 are irrelevant.
It is open ended.
b
]
6 MR. KEPPLER:
On top of all this, let 's look down the 7.
road a minute and talk about completing the quality confirmation 8
program, effecting all the repairs that will have to be made, and d
d 9
then on top of that, you have to go through the pre-operational i
h 10 test program and operational readiness --
E I
11 COMMISSIONER AHEARNE:
That is why I was asking earlier d
12 about your estimate.
E 13 M'R. KEPPLER:
We have not focused on a date.
3 E
14 COMMISSIONER AREARNE:
Clearly, the end of December of u
2 15 this year is out of the question.
16 MR. KEPFLER:
Yes.
3W d
17 We mentioned we had received anonymously a report of i
18 an investigation conducted by Kaiser relative to procurement of 5
19 materials.
That investigation is continuing.
k 20 COMMISSIONER AREARNE:
Primarily steel?
21 MR. HUNTER:
The anonymous investigation report 22 included some other areas.
It included steel but some other areas 23,
also.
I would rather not comment on that at this time.
i 24 COMMISSIONER AHEARNE:
Do you mean that you would 25; comment in a closed session?
r ALDERSON REPORTING COMPANY, INC.
t
59 i
MR. HUNTER:
Yes, sir.
2 MR. KEPPLER:
That is an ongoing investigation effort.
3 We have not resolved it to our satisfaction yet.
4 COMMISSIONER AHEARNE:
That answer would pertain to any 4
5 detailed questions on that?
k 8
6 MR. KEPPLER:
Yes.
m 7
I just wanted you to be aware that we have had an E
8 ongoing dialogue with the Department of Justice and OIA relative a
dd 9
to the activities at Zimmer.
I do not know whether the Commission i
h 10 is aware o f not, but. there was a letter that we received dated E
11 June 2nd, that indicates the Department of Justice is going to d
12 be initiating a criminal investigation of the allegations at Ec'jj 13 ZimmEr.
x E
14 This letter is a public document.
I think in terms of x
2 15 what they are going to investigate would be more appropriate for 16 the closed session.
3W d
17 COMMISSIONER AHEARNE:
All right.
5 18 COMMISSIONER GILINSKY:
I understand there is a state E
I 19 inspector who is required to inspect some of the pressure bounda-A 20 ries of the platit and has obj ected to the state of affairs?
21 COMMISSIONER AHEARNE:
National Board of Boiler and 22 Pressure Vessel Inspectors.
23,
COMMISSIONER GILINSKY:
Can you tel1 us something about 24 this?
25 j MR. KEPPLER :
We can tell you what we know.
We really l
l ALDERSON REPORTING COMPANY, INC.
l 60 have not had a lot of time to look into it.
j COMMISSIONER AHEARNE:
Do you have the report?
2 MR. KEPPLER:
Yes, we just received the report last week.
3 COMMISSIONER AHEA?NE:
It is' the State of Ohio boiler 4
de.
e 5
b MR. HUNTER:
At the end of 1981, and the first of 1982, j
6 e
the state requested the National Board to perform an inspection 7
r investigation at Zimmer.
On the 1st of March, they came on 8
nj site and started their document gathering and later on, document 9
2 g
10
- 1***
Cz j
jj I believe on May 12th, they issued their interim report.
It includes some specific findings, which we are evaluating at
,J 12 this time and I am 'sure the licensee is.also.
g 13 S
COMMISSIONER AHEARNE:
When did you get the report?
Last 9
14 ab week?
15 w
MR. HUNTER:
Yes.
We' picked it up at Headquarters.
16 B
A MR. KEPPLER:
They sent a copy to Washington but they j7 1
l 18 did not supply us with a copy.
=
MR. HUNTER:
You will notice in the interim report that j9 95 the National Board intends to maintain an inspector on site.
I 20 have not followed up on who the gentleman is.
We will follow up l
21 i
n that.
22 COMMISSIONER GILINSKY:
What were t, heir basic conclu-23,
l i
24; sions?
I MR. KEPPLER:
We got this report last week.
With the l
25 ALDERSON REPORTING COMPANY. INC.
1
61 1
activities we were following toward the end of last week down at 2
the site, we really have not focused any attention on it.
3 COMMISSIONER AHEARNE:
Is there anybody who has read 4
the report?
You sent us this note and we get daily staff notes, e
5 and there it is highlighted.
Clearly, it is an interesting key b
6 item or could be.
%y 7
Is there anyone here who can say where this interim re-7.l 8
port comes out?
What are their conclusions?
d d
9 MR. HUNTER:
Generally the conclusion is they have some 10 significant findings or potential findings, including some E
11 material traceability problems, problem with the containment g
12 vessel liner.
Ey'13 COMMISS'IONER AHEARNE:
What kind of problem?
m l
14 MR. HUNTER:
The State of ' Ohio has specific requirements s!
15 on containment vessel liners.
This is the National Board's j
16 potential problem, that the containment vessel liner apparently w
g 17 is a pressure vessel and in that light, the State of Ohio law 5
18 requires it to be built to ASME Code, which in fact, would 5
19 include an authorized nuclear inspector involvement.
20 To our knowledge, at this time, the authorized nuclear 21 inspector was not involved.
22 COMMISSIONER ROBERTS:
Who did the liner?
23,
MR. HUNTER:
CBI out of Chicago.
i 24 l COMMISSIONER AHEARNE:
Is there anyone on your staff 25 l who may be more familiar with that?
Is there anything in there i
ALDERSON REPORTING COMPANY,INC.
62 1
that leads to a type of problem that you are not aware of?
2 MR. HUNTER:
To my knowledge, at this time --
3 MR. KEPPLER:
We were not aware of the liner problem.
4 MR. EUNTER:
Except for the liner problem, I believe n
5 it is the same types of issues we have been involved with, N
6 procurement and material type problems.
i R
7 CHAIRMAN PALLADINO:
Rather than guess, I think it M
j 8
would be important to check on this point.
dd 9
MR. KEPPLER:
We really have not focused on this report 5g 10 yet.
If the Commission would like feedback on that, we would be j
11 glad to provide it.
3 g
12 CHAIRMAN PALLADINO:
I think we need to have it.
E There is a Mark II containment 13 COMMISSIONER GILINSKY:
14 program that applies to this plant.
.That is going on independent-2 15 ly?
Y g'
16 MR. HUNTER:
The re-work associated with the Mark II s
d 17 containment relative to structural steel, hangers, that type of 5
18 items, is going on now.
They are redoing an enormous amount of 5
y 19 structural steel and hangers presently.
n 20 COMMISSIONER GILINSKY:
Is this all covered by this 100 21 percent re-inspection?
22 MR. HUNTER:
Yes, sir.
23 !
COMMISSIONER GILINSKY:
Is the work. that was done i
24 previously covered by your quality confirmation program?
25 [
MR. HUNTER:
Yes, sir, it will be.
ALDERSON REPORTING COMPANY. INC.
L
m 63 (SLIDE.)
j MR. KEPPLER:
I wanted to briefly show what we are 2
3 focusing on at the moment, what we have committed to already.
That is continuing the investigation, following the on-4 going work and completing the quality confirmation program, e
5 k
including some further additional measurements that we plan to d
6 e
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7 do.
8 iSLIUE-)
N MR. KEPPLER:
I put this together in response to 9
2 h
10 considerations of what might we do or want to do, to provide
_Z further assurances that this job was done properly.
E 11 One would be to bring in an. outside consultant to take d
12 3
a look at the licensee's performance and assess it.
13 5
- COMMISSIONER ROBERTS:
Our consultant?
E 14 wH i
15 MR. KEPPLER:
Either one, theirs or ours.
5 16 COMMISSIONER AHEARNE:
When you say " licensee's per-
~
m A
formance" --
g j7 18 MR. KEPPLER:
Provide added assurance that the ongoing 5
E 19 work they are doing now is proper.
x l
5 20 COMMISSIONER AHEARNE:
I would have thought at this 21 stage your concerns about the ongoing work would be much less than 22 your concerns about the already completed work.
23,
MR. KEPPLER:
I am talking about observing the actions t
24l of the licensee in both phases.
25 !
COMMISSIONER GIIINSKY:
To what extent do we oversee l
I i
i ALDERSON REPORTING COMPANY, INC.
64 1
the ongoing work?
They are required to re-inspect 100 percent.
2 To what extent do we inspect anything?
3 Do we spot check?
4 MR. HUNTER:
Yes, but I cannot give you a percentage.
e 5
COMMISSIONER GILINSKY:
A very rough estimate?
R N
s 6
MR. HUNTER:
Very few percent, a few parts of a percent e
Rg 7
when you are dealing with that amount o f re-work.
We have had M]
8 one or two people in and out at various times looking at hanger d
d 9
work and ongoing structural steel work.
i h
10 It would be a sampling program, again.
3 5
11 We are talking about 1,800 inspections a month, that j
12 the licensee actually performs.
We would only pick up a few of 5
d 13 those activities.
E E
14 CHAIRMAN PALLADINO:
Does the licensee feel he needs a
2 15 a consultant on his performance?
You can get quite an alignment 5
y 16 of people, Kaiser, Sergeant Lundy, the licensee, the NRC, another w
6 17 consultant maybe could help, but I think censiderable thought 5
18 should be given to how that consultant is going to make a con-5
{
19 tribution.
n 20 MR. KEPPLER:
Mr. Chairman, what I wanted to do with 21 this slide is at least let you know these thoughts are somo ways 22 which might provide an added degree of assurance as to this pro-23, ject.
l 24 I am not suggesting we have concluded it is the way to 25{ go at this stage of the gene.
i-I ALDERSON REPORTING COMPANY,INC.
65 CHAIRMAN PALLADINO:
I am not saying it is improper.
1 2
I do think it is something that ought to be thought through, so 3
the consultant can be made to contribute effectively in the place 4
you think is most appropriate.
e 5
MR. KEP.PLER:
If I were to give you a personal 6
preference on my thoughts at this time, it would be the last e
eh7 three.
M]
8 As you know, right now plants that come up for an dd 9
operating license, the staff is requiring some independent design i
h 10 verification.
E s
11 My feeling or. Zimmer, in light of the past problems,
5 6
12 is we may want to expand that effort and also call for some E
13 independent construction verification.
l 14 I like the idea of bringing INPO in, and perhaps the 2
15 Performance and Appraisal. Branch at the time the plant gets closer 16 to completion.
g w
b~
17 COMMISSIONER AREARNE:
INPO is still in the development E
5 18 stage on construction.
E
{
19 MR. KEPPLER:
I understand that.
They have gone out n
20 on one inspection on a construction site.
At this point in time, 21 I would be talking about well after the quality confirmation 22 program is completed and well after corrective actions are done.
23 I would be talking about down the road.
It seems to 24l me they could provide an assessment as to the capability of the 25 utility's readiness to operate the plant.
{
i ALDERSON REPORTING COMPANY. INC.
66 1
COMMISSIONER AHEARNE:
At the moment, as far as I can 2
see, we are faced with a large amount of uncertainty on the 3
construction.
There is no way we can avoid -- we have the 4
fundamental responsibility of trying to make our own findings.
e 5
MR. KEPPLER:
I am not talking about INPO in lieu of An d
6 what we do.
I am talking about in addition to what we do.
e 7
COMMISSIONER ROBERTS:
You said the staff was requiring 3
8 8
independent design verification along near term operating a
d d
9 licenses.
Is that the policy of the staff?
i h
10 COMMISSIONER GILINSKY:
It is not strictly speaking a Ej 11 requirement.
S d
12 COMMISSIONER ROBERTS:
Are we doing it?
E 13 MR. KEPPLER:
Yes, with respect to the plants that l
14 have been under consideration since Dieblo Canyon.
b!
15 CHAIRMAN PALLADINO:
Wh'at is the middle one, W
j 16 verification of system design and construction beyond normal NRR w
d 17 requirements?
What do you mean?
18 MR. KEPPLER:
The staff has taken the position to 5
19 require the 1icensee to provide a description of the steps they i
n 20 have taken to verify the design and the construction of the plant.
21 This is a written submittal the staff receivas from each 22 lice ns ee.
I i
i i
23 COMMISSIONER AHEARNE:
We still have not put in writing i
l 24l what we require them to do.
25,
MR. KEPPLER:
It has been on a case by ca: ? basis, i
ALDERSON REPORTING COMPANY, INC.
67 1
depending upon what the utility has done.
The staff has required 2
some independent verification of it.
3 COMMISSIONER AHEARNE:
That almost sounds like you are 4
saying this is the normal NRR requirement, a
5 COMMISSIONER ROBERTS:
That is what you are saying.
U 6
MR. KEPPLER:
Yes.
I am suggesting, in the case of Zim-7 mer, we would probably go beyond what the nonnal NRR requirement M
j 8
is.
d d
9 CHAIRMAN PALLADINO:
I don't understand what you want,
i h
10 referring to "beyond normal NRR requirements. "
E 5
11 COMMISSIONER GILINSKY:
I think "recent practice" would g
12 probably be better wording.
x
~
h ~13 MR.,KEPPLER:
Let me give you an exampl.e.
14 CHAIRMAN PALLADINO:
Construction, I understand.
Do
~
2 15 you have problems on system design?
g 16 MR. KEPPLER:
We have concerns in the area of designs e
t' 17 right now at all NTOL plants, in terms of how much has been done.
18 I think when we come before the Commission on LaSalle, 5
19 for example, we will be talking about what has been done to n
20 provide added assurances that the design review has been proper 21 and the construction was proper.
22 All I am suggesting is whatever we have sought to do 23, on the other NTOL plants, that e would probably do that plus a 24 little more, depending upon a lot of things.
25 I would not bring this subj ect up for consideration ALDERSON REPORTING COMPANY. INC.
i
68 1
at this point in time until we know more.
2 CHAIRMAN PALLADINO:
Does this conclude your remarks 3
for the open part of the meeting?
12b 4
MR. KEPPLER:
Yes.
Could I submit for the record some n
'S information on quality assurance personnel at sites?
N 6
CHAIRMAN PALLADINO:
At all sites?
E_
7 MR. KEPPLER:
I can give you information on five sites
'M 8
8 in Region III, if you would like to have that information.
d
=
9 CHAIRMAN PALLADINO:
Yes.
10 MR. KEPPLER:
I will read it for the record, if that 2
5 11 is adequate.
(
12 COMMISSIONER AHEARNE:
These are utility people?
~=9 13 MRI KEPPLER:
I will give you approximate utility 3=
l 14 people. and approximate contractor people and the approximate 2
15 wo rkfo rce.
g 16 C$ AIRMAN PALLADINO:
Quality assurance?
M M
17 MR, KEPPLER:
Quality assurance and quality control both.
5 M
18 Marble Hill, approximate workforce is 2,800; approximate Y
19 licensee, QA/QC personnel,150, and approximate contractor n
20 QA/QC personnel, 170.
21 The Perry project, wo rkforce, 3,800; licensee QA/QC 22 pe"sonnel, 220 ; contractor QA/QC personnel,190.
23,
For Midland, approximate workforce.is 4,200; approximate 24 licensee QA/QC personnel,100; approximate contractor QA/QC 25 personnel, 180.
ALDERSON REPORTING COMPANY. INC.
l i
69
~i j
Clinton, apprximate workforce, 3,700; approximate l
2 licensee QA/QC personnel, 50; contractor QA/0C personnel, 220.
3 For Zimmer, approximate workforce, 2,000; app ro ximate l1[
4 licensee QA/QC personnel, 220; contractor QA/QC personnel, 290.
COMMISSIONER ARE ARNE:
Can you make a brief comment why 5
e A
N 8
6 Clinton is so different?
I i
I
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7 MR. KEPPLER:
No, but I can tell the Commission that ha we are finding some problems at Clinton also.
n dc 9
COMMISSIONER GILINSKY:
I would like to get t hos e i
h 10 numbers for all the plants at some point later.
My impression z
11 was the numbers for other plants were more like the Clinton d
12 numbers.
In fact, I thought the numbers were even less than that.
3 CHAIRMAN PALLADINO:
I did. make a note to ask the staff m
13 t
a E
14 to get numbers of the utility inspectors at ' tar'ious plants during w
h
/
15 construction.
16 COMMISSIONER GILINSKY: 'In a way, it seems odd to me 3
I i.
o, m
p 17 ; that the utility would have equal numbers of inspectors as the, E
f
'/
18 contractor.
The contractor is doing most of the hands-on 5
E 19 inspections, and the utility is mainly inspecting the contracyor's Xn
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20 QA system.
21 It seems to me it should be more like a pyramid.
I 22 would like to see the numbers for all the pinnts.
23 l CHAIRMAN PALLADINO:
We will make a, note of that and
'a.
24 i make sure we get it to the staff.
25 COMMISSIONER GILINSKY:
I have one question.
I wonder
!i ALDERSON REPORTING COMPANY. INC.
s 1
70 if you can' sum up'what the QCP. feveals about hardware problems?
/ /
y 2
How does 1,t look r,ight now?
MR. KEPPLER:
As a bottom line statement at the moment, 3
I think we feet we cannot make a strong judgment on the quality 4
of the plant at this stage of the game.
n 5
'i 9
I think we have found three areas that we think are 8
6 n
7 potentially significant problems.
One has to do with the
[
structural steel and the structural steelwelding.
You can 8
d characterize that any number of ways, depending upon who you are, d
9 i
h 10 but the bottom line 1s' wg$k is being re-done in that area, a
What did you'say it was, about ten percent of the 5
ij d
12 welding?
E
-13 MR. HUNTER:,Scmething up to that is probably a good S
E 14 general number that they are actually having to re-work.
w f.
15 MR. KEPPLER:
The utility's position has been it is Y
16 cheaper to re-work those welds than it is to disposition them.
w i
17 So be it.
. l about ten percent of the welding work N
18 The fact is that 5,
19 is being re-done.
That is a fact.
8
?
n CHAIRMAN PALLACINO:
What do you mean better to re-work 20 l
21 than disposition?
l 1
22 MR. HUNTER:
Through a detailed inspection of each weld, the condition'of the weld could be established and then through 23 24 appropriate engineering ' reviews, they could establish that the weld is or.is not sF,Uisfactory, and leave it as it is.
25 ;
i l
ALDERSON REPORTING COMPANY,INC.
f L
71 1
The statement is, as in the' control room, they are 2
re-working it at this time and my understanding is they will re-work the weld unless the weld is inaccessible, and then they 3
4 will engineer that particular weld.
e 5
CHAIRMAN PALLADINO:
When you say "re-work," does that
]
6 mean to chip out the old weld?
7 MR. HUNTER:
Bring it to the appropriate AWS speci-K j
8 fications, Sergeant Lundy drawing designs, so they do not have dd 9
to do any design review or engineering, brought to the original b
10 specifications.
2 l
11 CHAIRMAN PALLADINO:
Do you chip it out and re-weld it?
m j
12 MR. HUNTER:
Grind, chip, clean it up.
~=
13 CHAIRMAN PALLADINO:
Prepare it. for weldi'ng as it l
14 should have been.
C_
15 MR. HUNTER:
Yes, sir.
The same thing they would have 16 done had they had an inspection program adequately implemented g
e 6
17 previously.
5 18 MR. KEPPLER:
Th,at process, at least for those parti-5 3
19 cular welds, puts you in the position of not knowing whether the n
20 welds would have or would not have performed the required 21 functions.
22 The utility has chosen to put it in terms o f the 23 specifications, and that is the bottom line I got.
24 COMMISSIONER GILINSKY:
You did not have the assurance l
j 25 that it would?
i ALDERSON REPORTING COMPANY. INC.
72 MR. KEPPLER:
Absolutely none.
y COMMISSIONER GILINSKY:
That is what matters.
2 MR. KEPPLER:
That is right.
You either have to repair 3
the weld or establish it would perform its design safety function, 4
one or the other.
e 5
E h
COMMISSIONER AHEARNE:
At the present time, you are 6
o unable to make bottom line conclusions, and at least from my point 7
of view, you are wise and prudent on holding judgment on that, 8
N9 but clearly you are committed to getting all that necessary infor-i h
10 mation before you will reach a judgment.
z j
MR. KEPPLER:
Yes.
My bottom line, and I do not think jj it needs to be said, but it is I will not recommend a. license.for d
12 15 this plant until I am convinced it can perfdra its safety 13 E
functions.. In the absence of that, there is no finding.
E j4 5
CHAIRMAN PALLADINO:
Any questions?
15 COMMISSIONER AHEARNE:
With reference to the letter we 16 3e i
17 got from Mr. Udall announcing the hearing, he asked the Commission to address two points.
I think you have addressed one 18 E
19 o f t hem.
R The first was the means by which the Commission will 20 21 escablish that its regulations have been met in the face of 22 missing and falsified documents.
I think this is what you have been. talking about and 23 i
24 l the re-qualification program gets directly to that.
i i
My understanding of what you are saying is if the 25 i
ALDERSON REPORTING COMPANY,INC.
73 1
accurate documentation cannot be developed, then whatever steps.
2 were supposed to have been done will have to be redone.
3 MR. KEPPLER:
That is correct.
CO' MISSIONER AHEARNE:
The second one was plans for M
4 5
pinpointing and certifying materials were purchased from non-R 6
qualified suppliers, or in a manner in which they may not have R
7 been qualified at the time of acquisition.
M[
8 How are you cracking that?
dd 9
MR. HUNTER:
The same response applies.
The licensee, 5
h 10 CG&E, and Kaiser, have two document review groups or verification El 11 groups.
These groups are going through all purchased and pre-3 g
12 purchased material, equipment, items, to establish the validity 13 of that item and 'that will be completed.
l 14 That includes going all the way back to the purchase E
2 15 order, who it was bought from, to satisfy it was bought from an N
16 approved vendor a'nd it will provide its function.
g e
6 17 COMMISSIONER AHEARNE:
This may get into questions we E
18 will talk about later.
The statement " purchased from non-qualified i
5
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19 suppliers," was this another problem you ran into, that they M
20 were using materials that should have been qualified on purchase 21 and they were purchasing it from people who were not qualified?
l l
22 Ma. HUNTER:
In our Investigation 81-13, in the 23 '
structural steel area, it was identified as a. problem.
Part o f l
24l Task I was to identify structural steel,where it came from, 25 l that it was the proper material.
That is being done.
ALDERSON REPORTING COMPANY. INC.
L
74 1
I would not want to comment further on other items.
We 2
can comment later.
3 COMMISSIONER AHEARNE:
Would you care to comment at all 4
on the issues raised by Mr. McCarten?
5 MR. KEPPLER:
What issues did Mr. McCarten raise?
a b
8 6
COMMISSIONER AHEARNE:
I thought he essentially ba.d some e
teg 7
comments about whether he thought the investigation was going to 8
be successful because of problems of not having the investigation dd 9
being done adequately.
i h
10 COMMISSIONER GILINSKY:
Who is Mr. McCarten?
.Mr. McCarten was an investigator that was MR. KEPPLER:
g 11 3
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12 in Region III, that was the lead investigator in the initial 5
y 13.
phases of the Zimmer investigation.
He did a very fine job.
l 14 As you know, the staff is going through a rather big
~
g 15 learning curve with the Commission on investigations.
16 COMMISSIONER AHEARNE:
Both sides.
~
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17,
MR. KEPPLER:
We have not conducted investigations, at 18 leas t in terms of people wrongdoing as vigorously as the P
a 19 Commission has felt we should.
H 20 Obviously, with the reorganization of the Office of 21 Investigations and so forth, there are a lot of changes going on.
22 It is unfortunate that he left.
I think he was very 23 ; vigorous in this type of approach of exploring wrongdoings and 24 was a very good criminal type investigator, if I can use those 25,
words.
ALDERSON REPORTING COMPANY. INC.
75 1
I know~ he has some concerns about the other investigators 2
being as penetrating and vigorous in their approach as he mig at 3
have been in continuing this investigation.
All I can tell you 4
is I do not dismiss Mr. McCarten's views.
In fact, I am very 5
cognizant of them.
We are keeping a close eye on this investi-a 5
3 6
gation.
7 I think to adopt his policy, I might as well get rid 8
of the other investigators, if I cannot use them.
It 'is important d
d 9
that we bring them around to the current way of thinking within i
h 10 the organisation right now, and to get the best mileage we can Ej 11 out of them.
m j
12 If I feel that the investigators doing the work do not E
13 pursue some of these things to the degree of vigor that I feel l
14 is necessary, I will have to bri.ig somebody else in.
2 15 CHAIRMAN PALLADINO:
Any other questions?
j 16 COMMISSIONER GILINSKY:
You said there were three areas e
p 17 of problems and you started with structural steel.
Did you get 18 to the other two?
I
=
b 19 MR. KEPPLER:
I talked about that in terms of a real M
20 hardware problem right now.
The other two areas are more of a 1
21 wait and see type, the ones with the heat numbers, that if that 22 heat number issue cannot be dispositioned properly, then spools i
23,
of pipe may have to be replaced.
That determination has not been l
24 made yet.
25 The weld quality issue and the procedures.
ALDERSON REPORTING COMPANY, INC.
l
l 76 COMMISSIONER GILINSKY:
Thank you very much.
i 2
CHAIRMAN PALLADINO:
Any other items for the open 3
meeting?
4 (No response.)
5 CHAIRMAN PALLADINO:
I am going to suggest we take a e
b 6
five minute recess and we will reconvene to vote for our closed
^e.
R 7
session.
K j
8
'(Whereupon, the open session was adjourned at 11: 55 a.m.)
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24 I
25 ALDERSON REPORTING COMPANY, INC.
s A
NUCIZAR REGULATORY CO.41ISSION This is to certify that the attached proceedings before the (my)
COMMISSION MEETING in the matter of: Public Meeting - Briefing on Status of Zimmer
~'
Investigation
- Date of Proceeding:
June 7, 1982 Docket llumber:
Place of Proceeding:
Washington, D. C.
were held as he' rein appears, and that this is the original transcript thereof for the file of the Commission.,
Marilyn Nations Official Reporter (Typed) 7%
$6,hpw*%. S
~
v Official Reporter (Signature)
O O
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6 g/
l COMMISSION BRIEFING ZIMMER PROJECT PURPOSES:
1.
DISCUSS INVESTIGATION'AND PROBLEMS IDENTIFIED 2.
DISCUSS REGION III ACTIONS IN RESPONSE TO PROBLEMS IDENTIFIED 3.
DISCUSS STATUS OF QUALITY CONFIRMATION PROGRAM 4.
DISCUSS FUTURE ACTIONS
CHRONOLOGY OF SIGNIFICANT EVENTS RELATIVE TO ONG0ING ZIMMER INVESTIGATION EVENTS LEADING UP TO INVESTIGATION:
NOVEMBER 18, 1980 FOUR ALLEGATIONS FROM EX-ZIMMER EMPLOYEE DECEMBER 9, 1980 ALLEGER CONTACTED JANUARY 5, 1981 NUMEROUS ALLEGATIONS FROM GAP /APPLEGATE NRC ACTIONS:
JANUARY 12, 1981 ONSITE INVESTIGATION INITIATED-FIRST PHASE APRIL 8, 1981 IMMEDIATE ACTION LETTER ISSUED AUGUST 21, 1981 QCP SUBMITTED BY CGaE AUGUST 24 THRU NRC LIMITED INDEPENDENT MEASUREMENT PROGRAM CONDUCTED NOVEMBER 5, 1981 NOVEMBER 24, 1981 INVESTIGATION REPORT ANL ENFORCEMENT ACTION ISSUED FEBRUARY 8, 1982 RE0RGANIZATION OF REGION III PROJECTS BRANCH 2 APRIL 26, 1982 ONSITE INVESTIGATION INITIATED-SECOND PHASE n
2
I BEGINNING OF INVESTIGATION NOVEMBER 18, 1980 FOUR ALLEGATIONS FROM EX-ZIMMER EMPLOYEE DECEMBER 9, 1980 ALLEGER CONTACTED JANUARY 5, 1981 NUMEROUS ALLEGATIONS FROM GAP /APPLEGATE JANUARY 12, 1981 ONSITE INVESTIGATION INITIATED l
3
PROBLEMS IDENTIFIED AS OF END OF MARCH 1981 FROM GAP /APPLEGATE INADEQUATE RADIOGRAPHY OF PREFABRICATED PIPE WELDS INADEQUATE INSPECTION OF CABLE TRAY HANGER WELDS UNACCEPTABLE CABLE TRAY HANGER WELDS INADEQUATE A/E DESleii CONTROLS FROM EX-EMPLOYEE INADEQUATE TRACEABILITY OF PIPE _
3 IMPROPER V0IDING OF NON'CONFORMANCE REPORTS
~
x UNDESIRABLE INTERFACE BETWEEN CONSTRUCTION AND QA QUESTIONABLE QUALITY OF SMALL BORE PIPE WELDS FROM PAST AND CURRENT SITE INSPECTORS HARASSMENT OF QC INSPECTORS IMPROPERLY DELETED WELD INSPECTION CRITERIA IMPROPER USE OF SURVEILLANCE REPORTS FROM NRC INSPECTORS UNACCEPTABLE (NOTCHED) RE-ENTRANT CORNERS ON FIVE HANGER BEAMS UNACCEPTABLE WELDS ON NINE HANGER BEAMS UNSPECIFIED HANGER BEAMS (FOUR) INSTALLED TRACEABILITY OF NINE HANGER BEAMS NOT MAINTAINED VJ0LATION OF CABLE SEPARATION CRITERIA AT FOUR LOCATIONS INADEQUATE CG&E AUDITS OF SARGENT & LUNDY
\\
IMMEDIATE ACTION LETTER OF 4/8/81 PURPOSE:
CONTROL ONG0ING AND FUTURE WORK MAJOR RESULTS:
KEY MANAGEMENT CHANGES INCREASED SIZE AND TECHNICAL EXPERTISE OF CGaE QA STAFF (6 To 224) 100% REINSPECTION OF CONTRACTORS' QC INSPECTIONS-4 FULL CONTROL OF RECORDS BY LICENSEE 5
OUALITY CONFIRMATION PROGRAM SUBMITTED 8/21/81 PURPOSE:
DETERMINE THE QUALITY OF CONSTRUCTION QUALITY OF STRUCTURAL STEEL MATERIAL AND WELDS QUALITY OF WELDS TRACEABILITY OF PIPING QUALITY OF SOCKET WELD FITUP QUALITY OF PIPE RADIOGRAPHS ADEQUACY OF ELECTRICAL CABLE SEPARATION PROPER DISPOSITION OF NONCONFORMING ITEMS ADEQUACYOFA/5ELECTRICALDESIGNCONTROLS ADEQUACY OF CONTROL OF DESIGN CHANGES ADEQUACY OF SUBCONTRACTOR QA PROGRAMS ADEQUACY OF PAST AUDITS FLEXIBILITY:
TASK AREAS MAY BE EXPANDED
j LIMITED NRC INDEPENDENT MEASUREMENTS AUGUST 24 - NOVEMBER 5, 1981 PURPOSE:
PROVIDE A PERSPECTIVE AS TO WHETHER OR NOT THE QA PROGRA BREAKDOWN RESULTED IN WIDESPREAD CONSTRUCTION DEFICIENCIES TYPE OF MEASUREMENTS:
LABORATORY ANALYSIS RADIOGRAPHY ULTRASONIC DYE PENETRANT VISUAL MAGNETIC PARTICLE SCOPE:
.ns100 PIPE WELDS (ae200 EXAMINATIONS)
.=:=20 PIPES (;=160 EXAMINATIONS)
. :380 STRUCTURAL AND HANGER BEAM WELDS Ot:400 EXAMINATIONS)
. :100 STRUCTURAL AND HANGER BEAMS 0=:200 EXAMINATIONS)
HARDWARE ASSOCIATED WITH 19 IMPROPERLY VOIDED NONCONFORMANCE REPORTS SEVERAL AREAS INSPECTED FOR CABLE SEPARATION CONSTRUCTION DEFICIENCIES:
5 PIPE WELD DEFICIENCIES 5 P0TENTIAL PIPE WELD DEFICIENCIES 4 PIPE HANGERS UNACCEPTABLY INSTALLED 4 CABLE SEPARATION VIOLATIONS j
CONCLUSION:
SOME CONSTRUCTION DEFICIENCIES REQUIRING CORRECTIVE ACTIONS WERE IDENTIFIED 2 HOWEVER, THE MAJORITY OF MEASUREMENTS DID NOT POINT TO WIDESPREAD CONSTRUCTION DEFICIENCIES REVISED VIEWGRAPH 5 7
-m ee--
--e
REPORT AND ENFORCEMENT ACTION NOVEMBER 24, 1981 INVESTIGATION REPORT AND $200,000 CIVIL PENALTY ISSUED FALSE QA RECORDS - $50,000 1.
HARRASSMENT/ INTIMIDATION OF QC INSPECTORS - $50,000 INADEQUATE QA PROGRAM IMPLEMENTATION -
$100,000 FEBRUARY 24 AND 26, 1982 LICENSEE RESPONDED TO CIVIL PENALTY AND NOTICE OF VIOLATIONS - CIVIL PENALTY i
PAID IN FULL IN PROGRESS REGION III REVIEW 0F LICENSEE RESPONSE
REORGANIZATION OF REGION III PROJECTS BRANCH 2 ON FEBRUARY 8, 1982 CHIEF, PROJECTS BRANCH 2 SECTION 2A SECTION 2C 3
I CHIEF, PROJECTS SECTION 2B "6[eiNo"! SUPPORT SENIOR RESIDENT I N S pef'TO R.
I as a 9
fhhhNR INVESTIGATOR hhhPE OR p
OR ORS
OVERALL QUALITY CONFIRMATION PROGRAM STATUS AS OF MAY L 1982 1
OVERALL STATUS:
^
55% COMPLETE (PROBLEM IDENTIFICATION ONLY)
ANTICIPATED COMPLETION DATE:
DECEMBER 31, 1982 2
s 9
e 0
STATUS OF OVALITY CONFIRMATION PROGRAM (OCP) TASK AREAS AS OF 5/1/87.
EXPECTED TASK AREA
% COMPLETE COMPLETION 1.
STRUCTURAL STEEL
- 4 12/1/82 II.
WELD QUALITY
- 34 10/31/82 III.
HEAT NUMBER TRACEABILITY
- 55 10/6/82 IV.
SOCKET WELD FITUP 96 8/13/82 V.
RADIOGRAPHS 95 10/4/82 VI.
CABLE SEPARATION 49 7/30/82 VII.
NONCONFORMANCES 66 8/20/82 VIII.
DESIGN CONTROL AND VERIFICATION 90 6/1/82 IX.
DESIGN DOCUMENT CHANGES 28 12/31/82 X.
SUBCONTRACTOR QA PROGRAMS 37 7/16/82 XI.
AUDITS 45 7/16/82
- AREAS VIEWED BY REGION III AS P0TENTIALLY REQUIRING A SIGNIFICANT AMOUNT OF REWORK u
AREAS VIEWED BY REGION III AS POTENTIALLY REQUIRING A SIGNIFICANT AMOUNT OF REWORK AS OF 5/1/82 TASK AREA PROBLEMS AND COMMENTS I.
' STRUCTURAL STEEL SEVERAL THOUSANDS OF NONCONFORMING WELDS, TASK STOPPED AND RESTARTED BY LICENSEE IN 4/82 BECAUSE OF INADEQUATELY TRAINED INSPECTORS.
REINSPECTION BY TRAINED INSPECTORS MAY RESULT IN SUBSTANTIAL REDUCTION IN NUMBER OF NONCONFORMING WELDS.
II.
WELD QUALITY SOME WELD PROCEDURES AND WELDERS NOT QUALIFIED.
INABILITY TO QUALIFY PROCEDURES OR TO OBTAIN WELDER QUALIFICA-TION DATA COULD DRAW INTO QUESTION THE QUALITY OF THOUSANDS OF WELDS.
III.
HEAT NUMBER APPR0XIMATELY 20% OF 2500 DRAWINGS TRACEABILITY REVIEWED HAVE HEAT NUMBER DEFICIENCIES.
TASK AREA EXPANDED AS A RESULT OF NUMBER OF DEFICIENCIES IDENTl'FIED TO INCLUDE ADDITIONAL SYSTFMS.
a
ZIMMER UPDATE SINCE BRIEFING 0F CHAIRMAN ON MAY 10, 1982 REGIONAL ADMINISTRATOR RE-EMPHASIZED HIGHEST PRIORITY COMMITMENT OF PERSONNEL TO ZIMMER PROJECT CONSTRUCTION RESIDENT INSPECTOR ASSIGNED EFFECTIVE JUNE 27, 1982 CLEANLINESS AND GRAFFITI BEING RESOLVED BY THE PRESIDENTS OF THE LICENSEE AND CONSTRUCTOR LICENSEE REVIEWING FUEL LOAD DATE AND CONSTRUCTION STATUS REPORT (YELLOW BOOK INPUT) TO ASSURE THEY AGREE AND ACCURATELY REFLECT PROJECT STATUS INVESTIGATION CONCERNING THE "HJK INVESTIGATION REPORT ON PROCUREMENT ACTIVITIES" IS CONTINUING MEETINGS HELD BETWEEN OIA, D0J, AND REGION III ON MAY 19 AND 20, 1982, TO COORDINATE EFFORTS 4
s PLANNED FUTURE ACTIONS s'
EVALUATE LICENSEE RESPONSES TO INVESTIGATION REPORT AND CIVIL PENALTY MONITOR ONG0ING WORK AND QUALITY CONFIRMATION PROGRAM ACTIVITIES EVALUATE QUALITY CONFIRMATION PROGRAM RESULTS CONDUCT ADDITIONAL INDEPENDENT MEASUREMENTS COMPLETE PHASE 2 0F INVESTIGATION e
9
POSSIBLE FUTURE ACTIONS BEING CONSIDERED EVALUATION BY CONSULTANT OF PRESENT LICENSEE PERFORMANCE RETENTION OF CODE CONSULTANT BY LICENSEE VERIFICATION OF SYSTEM DESIGN AND CONSTRUCTION BEYOND NORMAL NRR REQUIREMENTS PAS AND/0R INP0 APPRAISALS EVALUATION BY CONSULTANT OF LICENSEE READINESS FOR OPERATION i
15
^