ML20054L999
| ML20054L999 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/08/1982 |
| From: | Bernabei L, Devine T GOVERNMENT ACCOUNTABILITY PROJECT, MIAMI VALLEY POWER PROJECT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8207090140 | |
| Download: ML20054L999 (80) | |
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- _ 97 h3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board ln the Matter of: )
)
The Cincinnati Gas & Electric )
Company, et al. ) Docket No. 50-358
)
(Wm. II . Zimmer Nuclear Power )
Plant) )
MVPP'S REPLY TO APPLICANTS' AND STAFF'S RESPONSES TO MVPP'S MOTION FOR LEAVE TO FILE NEW CONTENTIONS-j Intervenor MVPP files this reply in answer to Applicants' Opposition to its request to file new contentions and the NRC
- Staff's response in support of reopening the record in this licen-sing hearing.
While welcoming the Staff's support, MVPP must emphasize-that of the eight contentions presented, its central and most l
important contention is the one challenging the character, integrity-and technical competence of Cincinnati Gas & Electric ("CG&E") to operate a nuclear power plant.
I. INTERVENOR MVPP HAS STANDING TO INTRODUCE NEW CONTENTIONS CG&E charged in its Opposition that Intervenor MVPP was merely a " facade, used and then discarded, by succeeding self-8207090140 820708 PDR ADOCK 05000358 C PDR y ., ,
appointed groups...," Opposition at 7, and that Intervenor's motion was itself "merely a vehicle for GAP to launch another unwarranted attack against the Zimmer quality assurance program in its efforts to delay the plant," Opposition at 2. CG&E failed, however, to provide a minimal factual basis for these emotional allegations.
Instead, through rhetoric and insinuation, CG&E has tried to draw j a picture of itself encircled and beseiged by hostile forces.
The truth is that MVPP, a Cincinnati grassroots citizens' group, has been a longstanding and central intervenor in this licen-sing proceeding. It is a wholly-owned subsidiary of the Cincinnati i
Alliance for Responsible Energy (" CARE") , a local advoca'te for seri-ous examination of the construction deficiencies and quality assur-ance breakdown at Zimmer.
Nor is the Government Accountability Project of the Institute for Policy Studies (" GAP") the intervenor. MVPP has retained GAP to represent it in the licensing proceedings. GAP's primary purpose
, is to offer legal counsel to whistleblowers, to provide a legal education to law students on First Amendment and civil service issues, to bring meaningful reform to the workplace, and to expose employer actions -- whether governmental or private -- that are wasteful, illegal, or pose a threat to the health and safety of the American public.1/
-1/H. Patrick Swygert and Mary Eastwood, forner Special (bunsels of the bhrit Systems Protection Board, have praised GAP's efforts to monitor imple-nentation of whistleblower reform, as has Congresswcman Patricia Schroeder, chairwoman of the House Civil Service Subcannittee.
Since 1979 GAP has operated a Icgal Clinic with the participation of Antioch Law School students, has prcduced two films, and has organized a national' hhistleblower's Conference. GAP attorneys have frcquently testified befcre Cbngress. In addition, GAP formerly rcpresented Mr. Thomas Applegate regarding his allegations about illegalities at the Zinner site.
MVPP has retained GAP to represent it within the traditional attorney-client relationship. CG&E's attempts to mischaracterize GAP's role in this licensing proceeding must be seen as nothing more than a blatant interference with MVPP's relationship with its attor-neys. As such, this Board should resoundingly reject CG&E's argu-ments that MVPP has no standing to raise new contentions.
Applicants surely cannot complain that Intervonor has out-of-town counsel when they themselves have retained the Washington, D. C. law firm of Conner & Wetterhahn to represent them in this licensing proceeding.
II. MVPP HAS MET THE STANDARD FOR ACCEPTANCE OF NEW CONTENTIONS AND THE STANDARD FOR REOPENING THE RECORD Applicants contend that MVPP has failed to satisfy the five-criteria for filing new contentions or carried its " heavy burden" to reopen the record. The NRC Staff effectively argues that Intervenor-meets both standards and recommends reopening the proceeding for litigation of MVPP's proposed eight contentions.
MVPP has clearly met the five criteria set out in 10 C.F.R.
S 2.714 (a) (1) :
A. Good Cause MVPP filed new contentions only after it obtained numerous affidavits from Zimmer workers and internal documents substantiating the serious allegations contained in its contentions concerning the fatal deficiencies in CG&E's quality assurance ( " QA ") program, which includes the Quality Confirmation Program ("QCP"), and concerning
CG&E's lack of character and competence to operate a nuclear reactor.
Much of this information was disclosed to IMH?P only af ter workers spoke to the NRC during its investigation and determined that the NRC had not, and could not, adequately remedy the severe engineering, construction, QA and management problems the workers reported at the plant. As the exhibits to MVPP's Motion and to this Reply illustrate, MVPP has gathered significant new information demonstrating the continuing failures and structural deficiencies in CG&E's QA program.
Most disturbing is that the new documentation demonstrates that CG&E officials have made misrepresentations and misleading statements to the NRC in attempting to shun responsibility for the QA breakdown at Zimmer. For example, Earl Borgmann and other top CG&E officials told the House Subcommittee on Energy and the Environ-ment of the United States Congress and the full Nuclear Regulatory Commission that they were largely unaware of Kaiser's QA problems at Zimmer prior to November, 1980, did nothing to prevent adequate Kaiser QA staffing, and did not interfere with Kaiser inspections.
See Cincinnati Enquirer article, June 12, 1982, attached and incorporated herein as Exhibit A. Internal memoranda show these statements are false and that CG&E has been substantially involved in the QA program at Zimmer since 1973. The following document CG&E's acting policy role in QA at Zimmer:
(1) CG&E refused to provide Kaiser with a representative of the architect and engineer, Sargent & Lundy, on-site to review Kaiser drawings after a Kaiser request in January 1972. See January 14, 1972 Letter, attached and incorporated herein as
Exhibit'B.
(2) On July 18, 1973, CG&E " suggested" that Kaiser not write nonconformance reports on rejection of materials purchased for the Zimmer project and repeatedly emphasized that was CG&E's positit.n.
See July 18, 1973 Letter, attached and incorporated herein as Exhibit C.
(3) On July 19, 1973, CG&E told Kaiser that it was not necessary to perform tests on sections of stainless steel piping in full compliance with ASME standards since tests in compliance with ASME would be done later on the system as a whole. See July 19, 1973 Letter, attached and incorporated herein as Exhibit D.
(4) On March 18, 1974, CG&E directed Kaiser to stop issuing nonconformance reports on material and procedures for temporary construction. See March 18, 1974 Letter, attached and incorporated herein as Exhibit E.
i (5) CG&E and Kaiser had numerous discussions, some encom-
- passed in written correspondence, about approval of vendors
--On February 20, 1974, Kaiser QA Manager William Friedrich told CG&E that he disagreed with its disapproval of Kaiser's requests to do surveys of the Quality System Programs of Suppliers to meet AEDIE standards. See February 20, 1974 Letter, attached and incor-porated herein as Exhibit F.
l --On March 28, 1974, Kaiser asked CG&E a series of questions about the procedures Kaiser was to follow in inspecting CG&E-purchased l
equipment. See March 28, 1974 Letter, attached and incorporated herein as Exhibit G.
--On April 9, 1974, CG&E answered all the questions posed l
by Kaiser and stated that CG&E's procedures differ from those of General Electric. See April 9, 1974 Letter, attached and incor-porated herein as Exhibit H.
--On April 19, 1974, Kaiser outlined for CG&E its proposed
" receiving inspection program" and asked CG&E to amend any part of the program that was not responsive to CG&E directives. See April 19, 1974 Letter, attached and incorporated herein as Exhibit I.
In other words, Kaiser set up its entire inspection program in accordance with specific CG&E-imposed requirements.
--On September 19, 1975, CG&E clarified for Kaiser what documentation Kaiser needed to include in its " Receiving Inspection Plans." See Letter of September 19, 1975, attached and incorporated herein as Exhibit J.
(6) In a September 14, 1976 letter, Borgmann informed the NRC of changes in the management structure for the Zimmer project.
He stated explicitly that "the purpose of this reorganization wac to give the Cincinnati Gas & Electric Company a more direct and active role in all phase of the Zimmer project. . . . " See September 14, 1976 Letter, attached and incorporated herein as Exhibit K.
(7) In an October 22, 1976 letter, William Schwiers, then CG&E's principal QA engineer, informed Kaiser that the signatures of Sponsor Engineers would no longer be necessary on " essential or non-essential Nonconforming Reports with rework or reject disposi-tions." See October 22, 1976 Letter, attached and incorporated herein as Exhibit L.
(8) In an April 1, 1977 letter, Schwiers told Kaiser that l
it was "CG&E's intention to maintain a minimum of inspection in the
- non-essential area" and to delete " construction inspection plans and similar Quality Control responsibilities" from the scope of work of Kaiser's QA program. See April 1, 1977 Letter, attached and incor-porated herein as Exhibit M.
1 The press has also reported that internal correspondence i
between Kaiser and CG&E show CG&E's deep involvement in the QA program at the Zimmer site since at least 1974. The following, inter alia, j has been reported:
(1) On October 14, 1974, Friedrich told CG&E it was "abso-lutely necessary" to improve Kaiser's QA staff to satisfy federal i'
standards. Two weeks later, CG&E President William Dickhoner refused because he found "no justification" for providing more QA personnel.
(2) On January 15, 1975, in response to further requests
, by Kaiser for more QA personnel Borgmann wrote, "
Quality rather than quantity is the real answer on a project of this nature...."
l (3) Friedrich responded on February 17, 1975 that such cut-backs would make it impossible to run an adequate QA program.
(4) On March 26, 1975, Friedrich complained again that CG&E's refusal to provide more QA personnel made it impossible to do adequate inspections of the three shifts of construction work then in progress.
(5) In a March 8, 1976 letter, Borgmann approved five new QA inspectors f or Kaiser but vetoed a request for five others. See Exhibit A, supra at 4.
. The press also disclosed that an independent report conducted I
j by Kaiser in 1981 charged CG&E had insisted that up to 90 percent of
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structural materials at Zimmer be purchased as non-essential even though they were later used as essential materials. CG&E did not notify the NRC of this confidential report which documents defects and noncompliances even though NRC regulations require CG&E to report such known deficiencies that could compromise the public health and safety within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. 10 C.F.R. Part 21. CG&E could be fined up to'$25,000 per day or be subject to criminal prosecution. See
. Cincinnati Enquirer Article, June 9, 1982, attached and incorporated
- herein as Exhibit N.
4 CG&E's deliberate refusal to report such deficiencies is even more clearly shown, however, by a January 20, 1981 memorandum from CG&E QA engineer R. P. Ehas to Schwiers that describes how 30 to 40 percent of a set of "W8 X 17 beams" for supporting essential l hangers may have been purchased from non-approved vendors. Ehas :
i l tells Schwiers that this is a " potential 50-55e against the HJK Q.}..
- - program," and if true demonstrates that "we have a breakdown in the l QA program that should have been discovered by a QA audit. Frank 1
l Adams - a Cinti [ sic] scrap dealer supplied a large amount of the beams. He and the mill -- U S Steel Co. are non approved." See January 20, 1981 Ehas Memorandum, attached and incorporated herein
( as Exhibit O. Deficiencies reportable under 10 C.F.R. 50.55(e) are considered so significant that the utility is required to notify i
- the NRC of such deficiencies within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to avoid severe en-forcement sanctions.
i Not only did CG&E nct report this breakdown in vendor l
l approval procedures in January 1981, but it failed a second time to report the problem af ter Kaiser's independent report verified the
9-noncompliances. Even today, CG&E has refused to report the defici-encies in its vendor approval procedures as 10 C.F.R. 50.55(e) requires. This is a blatant violation of NRC regulations. !
B. Availability of Other Means to Protect Petitioner's Interest MVPP and its counsel GAP, which also serves as attorney to Thomas Applegate, have been the first to bring many of these quality control and " character and competence" problems to the NRC's attention.
The NRC issued two reports to respond to Mr. Applegate and other p
Zimmer workers' allegations. Report of the Office of Investigation and Enforcement ("IE"), November 25, 1981; Report of the Office of Inspector and Auditor ("OIA Report") , August 7, 1981. Contrary to Applicants' statements in their Answer, Applicants' Answer at 3
- n. 3 and 18, nearly all of Mr. Applegate's charges have been sub-stantiated. See OIA Report at 1-2 and IE Report at 3, attached as Exhibit P.
Although the NRC Reports are the best proof that the NRC substantiated most if not all of Mr. Applegate's charges, a memo-randum from Mr. Keppler to the File, dated July 8, 1981, corrobo-rates the reports. In that memorandum, Mr. Keppler states that he received a telephone call from Mr. Applegate who r i
! ... stated that Mr. Dickhoner, during a recent speaking ,
engagement, had told his audience that the NRC found Applegate's allegations to be without substance. He said that Mr. McCarten had told him earlier that many of his allegations had been substantiated and h' t
l 2_/,Ihe documents listed above, as well as others, will be incorporated in Intervenor's forthoJming Petition to Stop 03nstruction.
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d wanted to know if we were changing our story.
j I told Mr. Applegate that we. were not in a position to control Mr. Dickhoner's statements and that our Linvestigation findings had confirmed many of his allegations -- either in whole or in part.
i See Keppler Memorandum to File, July 8, 1981, attached and incor-porated herein as Exhibit Q.
.Moreover the Staff's recent' support of Intervenor's request.
to reopen the Elicensing hearing demonstrates the NRC's appreciation of Intervenor's major role'in investigating QA deficiencies at Zimmer.
i Applicants now argue that most of the information about the QA breakdown and lack of CG&E character and competence to run Zimmer is contained in the two NRC reports. MVPP disagrees. However, even the substance of these two reports would no,t now be before this Licensing Board unless Intervenor had urged the Board to give.both a close examination. As noted in MVPP's Motion, Motion at 25, the NRC Staff did no more than inform-this Board that the IE and OIA Reports were in the Commission's Public Documents Room. Moreover, f prior to - the Staff's recent shif t in };oaition, it stood in unquali-fied support of granting an operating license to CG&E. Certainly without Intervenor's motion' to reopen the record, the Intervenor's-1
- investigation of severe, perhaps fatal, CG&E QA and management problems, these issues would never have been raised before Region III, before the Commission, or before this Licensing Board.
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C. Petitioner's Assistance in Developing the Record Intervenor can clearly be expected to contribute significantly to development of a sound record on the eight contentions it has proposed. As noted above, the numerous internal memoranda and affi-davits from former and present KEI workers are critical to this Board's understanding and consideration of Applicants' QA program and management structure. CG&E's past conduct, and its present attempts to cover. up or disguise those past actions reveal its basic lack of character and competence to operate Zimmer.
D. Representation by Existing Parties It has been MVPP and GAP, representing.Mr. Applegate, who have forced Region III to re-examine the CG&E-QA program. Mr. Keppler, Director of Region III, conceded at recent hearings before the House Subcommittee on Energy and the Environment that it was GAP and not the NRC that discovered the problems at Zimmer. See Cincinnati Enquirer Article, June 11, 1982, attached and incorporated herein as Exhibit R.
E. MVPP's Participation Will Not Delay the Proceeding As Region III revealed at a June 7,1982 briefing of the Commission, the ongoing criminal investigation at Zimmer has been reopened since' June 1982.
This Licensing Board has already denied an operating license for Zimmer until CG&E fulfills certain requirements for emergency
planning.
Fur ther , Mr. Keppler has stated that he does not expect CG&E will identify all the corrective actions needed at Zimmer prior to December 1982. After that, he expects much of the corrective work will still need to be completed.
Therefore, admission and litigation of Intervenor's proposed new contentions will not in any way delay this licensing proceeding.
Although the QA and " character and competence" issues are new ones in this proceeding, they are crucially important to the Board's determination of whether Zimmer can be operated in a manner by the current Applicants to ensure the public health and safety are protected.
MVPP has additionally satisfied any burden it carries to reopen this licensing hearing. As previously explained, MVPP, after disclosure to it of numerous internal memoranda and worker affidavits, proceeded expeditiously to file new contentions. And Applicants' repeated complaints about MVPP and GAP's previous activities demon-strates that all parties to this licensing proceeding have long been put on notice of the Intervenor, its counsel, and the general public's criticism of the Applicants' QA program, the OCP and CG&E's manage-ment conduct. See CARE Shareholder Resolution, attached and incor-porated herein as Exhibit S ; GAP News Release , November 25, 1981, l and Cincinnati Enquirer Article, June 17, 1982, attached and incor-l porated herein as Exhibits T and U respectively, both demonstrating GAP's consistent criticism of CG&E's control over the Quality l
l Confirmation Program.
l l Neither the NRC nor Applicants can claim they are surprised l
l
or prejudiced by Intervenor's motion to file new contentions.3_/
MVPP has, in its contentions, put into issue CG&E's basic ability to operate a nuclear plant. MVPP questions both whether CG&E has the basic integrity to participate in self-regulation under the Atomic Energy Act and whether it possesses the technical com-potence to direct its employees and contractors to ensure sound construction according to an approved design, and an independent and adequate QA program.
Mr. Dircks, testifying on June 10, 1982, before the House Subcommittee on Energy and the Environment, stated:
If it [Zimmer] were a completely government-owned project, then the government would have full responsibility to be in there. These people [Appli-cants] are licenscos. We' trust them to operate the plant. We had trusted them to build the plant cor-rectly.... It is a difficult problem.
Difficult or not, whether CG&E has demonstrated the necessary character and competence to operate Zimmer must be the bottom-line question this Licensing Board considers.
III. MVPP'S PRIMARY CONCERN AND PRIMARY CONTENTION QUESTION WIIETHER CG&E HAS THE CHARACTER TO OPERATE A NUCLEAR REACTOR While seven of the eight contentions MVPP wishes to introduce encompass concerns about CG&E's "out-of-control" QA program, MVPP's 3/
- Intervenor's counml Mr. Devine has outlinal his critique of CG&E's quality assurance program to the Commission. See Devine Statanent, June 16, 1982, attached and incorporated herein as Ddubit V.
Ilis criticisms are specific and have ircluded examples corroborated by former wrkers, including Richard Pciter, former Kaiser docttments reviewer, and David Jones, former senior OT analyst for Yaiser.
t final and eighth contention is the most important: "CG&E lacks the necessary character and competence to operate a nuclear plant."
The Commission, in Houston Lighting and Power Company (South Texas Project, Units 1 & 2), CLI-80-32, 12 NRC 281-(1980), ruled that both abdication of responsibility for construction to a con-4 tractor or abdication of knowledge about construction activities by a prospective licensee is sufficient basis to deny an operating license, 12 NRC at 291. The Commission further said that it could not legally " ignore false statements in documents submitted to it,"
M., at 291, n. 4, since Section 186a of the Atomic Energy Act allows denial of licenses for " intentional false statements."
( MVPP outlined in its original motion, Motion at 16-18, misrepresentations made by high CG&E officials to the NRC, e CG&E shareholders, and to the press. Subsequently, CG&E Vice President l Bcrgmann testified, Intervenor believes f alsely, on June 10, 1982 to a Congressional subcommittee and on June 16, 1982 to the full Nuclear Regulatory Commission, that CG&E had never interfered with Kaiser's quality assurance program. See Exhibits A through 0, and Exhibit 9 to Intervenor's Motion.
Mr. Borgmann further testified to the Commission on June 16, 1982 that he knew of no CG&E officials who had been questioned in l connection with a criminal investigation. However, Exhibit 52 to the IE Report, Exhibit 12 to Intervenor's Motion, confirms that i
1
-4/The Cbanission suggested that even if not made intentionally but only 8
with disregard for the truth, " misrepresentations can be sufficient ground for denial of a license." Ibid; Virginia Electric & Power Carpany v. NRC, 571 F.2d 1289 (4th Cir.1978) .
CG&E QA Manager Schwiers knew of the criminal investigation and the targeting of CG&E officials. On October 27 and 28, 1981, the Com-missioners discussed ongoing law enforcement proceedings at Zimmer.
Other internal memoranda demonstrate clearly that the-NRC was con-sidering a criminal investigation for falsification of QA records and .that the investigation focused in part on CG&E officials. See Exhibit 12 to Intervenor's Motion.
Viewing the past misrepresen'tations of CG&E top officials such as Mr. Borgmann, who has been personally involved in the Zimmer project for the past decade, and his most recent misrepresentations, this Licensing Board has no choice but to examine carefully whether
-CG&E has the honesty, integrity and " character" to ensure its dili-gent compliance with the largely self-regulatory framework for NRC licensees.E Moreover, in light of the public's increasing distrust of CG&E's ability to manage Zimmer, this Licensing Board must provide
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a full airing and litigation of these issues to allay well-justified fears of the public about Zimmer's safety.
IV. CONCLUSION For the foregoing reasons, this Board should reopen the record to allow full litigation of Intervenor MVPP's eight E ntervenor I would again enphasize that contrary to the characterization of its eighth contention by the NRC Staff as one questioning CG&E's technical cmpetence, the main thrust of the contention is to put at issue CGE's basic integrity ard character to operato Zimmer safely and in accardance with NRC regulations.
suggested contentions, and set a discovery schedule as soon as possible.
Respectfully submitted,
[,f[n(, hk. 2'. (1,. s. _,[ v.-
LYNNE BERNABEI A .
- 0 ./M THOMAS DEVINE Government Accountability Project of the Institute for Policy Studies 1901 Q Street, N. W.
Washington, D. C. 20009 202/234-9382 Counsel for Intervenor DATED: July 8, 1982
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b .1D n hh_ a ,_ 1di THE ENOUMER n
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. :For Insaectors -
'#g BY DAVO SHAPIRO " THE QUESTION of CGLE's O " role in Kaiscr's quality assurance C'*# " Two weeks lat.er CGLE Presi ,
pmgram also arose dura tmer-dent W1111am Dickhoner respond- Men by MC inusugators from andBENt KAUFMAN -
ed that there was "no just!!!ca- the Outce ofImpector and Amt.
DuaJrer Recater i 11on" !or !urther quallty who wete lovktng into possible ms1Gamnw ser*e assurance manpower. "As you are i aware. we are ma ring every effort " Icah M docments at WASHINGTON-Documents ob' . m mantain the mWmum labor ggg3f,"3 N b P gk to
,* talned Csp e by Osnnett by dndnnau News GasServtce. [gg'ajcep bfe 1 1 e
of s r alon, craftlabor and inspection of quauty mutance manager fir and Electric Co. (CG&E) that it ratUmmn.QuesOlms A Cid not isterfere with the quality the work."Dicthener said. Asying that Kalser was "doint the assuranco program run by its A few days !cter* 4 Kaiser offt. Work f or a very tough client
. .ccmtractor at tha 7.!mmar nuclear cla1 V.P. McMahon,. wrote an WGW cad mat any n@tsNon D" '
P"vna
. It a1021 of r.de' qu' ate' qual. intanal memcrandu'n emem for addit!cnal manpower or str.!!.
ing grcat concern about DicEhon. ' at for QA-QO had to go through Ity r.ssurrmee thatled to the prod O Msmon. W asid. Needkas to ' the c!!ent."
le.ns that st13 pin *te 2.immer. . - say,ve cannot conduct a proper 01ttings told NRC iniest Alla]Cag. CGLE has blamed its @ rarn w1 t,the neces- tots thr.t numerous mcmos s!ga-contzsctor Katser Engtseermg. san Mgg en*
f or the gur.tlty probloms at to CG&E asking for additionni,
- As Ecker kept agitaung for- ,,
quality contrcl staff were turned Zimmer, c!al aing its only fsult more qualjty personn:1 Borg- down by the ut!!!ty-spec!fledly
- wr.s inernet closely M.tching over EtJaer, mann wrote the conttruct!cn on-D. rejected by WILiam Schwiers who The Nt;:! car Regulatory Comai.
.ft tn Won Jan. 13,1915, cdvitin3 ance ht thr.1 time was quality assur-thcWsu. emathanquanu- manaccr for CG&E -
mir.ston (NnC) necepted th t: M W s';21 zurrer on h project _ oigggn s aho told investigators 1.wnt the NRC 1:34 yesr. At that t;:ne.t cf.t!.i: rrature t.r:d you should es- ,
that quauty er.sur:nce and qccl. ' -
'its evn q"pt CGSE
/:.11tv in chcrgo ccnfirmation po.4 cijer.1effoMpst'stf to r.:c.in the hi-A* A t psa::*ble.befo*o institut-lty control 3 !ficg in the past b had not been *cdequste to Emt >
g:s.m problema to tdtntify r.t Zimmer. and correct.that ing c nWina sbout being om* :the requirements of 10 CTR Parti p.*fyrj gcRad? *
..r -
E0 Appendix B." the Code of Federal Regulations that governs EUT CCNTINUED probicms sg, : cew :-dar::mann rd!ded.*'The levt!c' t
- nucler.r power.
es att:In_-d to dats en s Z*=mer br.vc recently led to rido. ' tan ptioret makes it imnstor ( 3" sprtt.d cr.lls ior indepenCen17 1.3 ught:n tec control reins. hr>y 8 THE l'Ot. LOWING day, July 9. ,
- auditora to loch,tnto the pant.g- s iheURCinvest!gatorsinterview j dch:1:nct:1. Ja /.4.1. #f.g Rt:r.11tyas:urancoleffcitz"
- ' fully without f., j*a , td 3chwiers.
re!-mg your a.
A .Irt ten :2etN*I!!!'r'ady. b7fored @ recponu to W:r.nh
. . . . . - At 11rst, Schwiers d!:puted .
thrs Couta Inter:cqud:o:o.mntcs ! Ic:* D *~" C+ M- 2 M'M - 'Cittin';s' ass:ruons that be had .
'on-f2.ct' T Lnd the Env!rennentfs ^ turned down Kai 1
! mon unpwn.ser's requests for
'CGLE Lenior Vue Pre:! dent Een siemorandum on Jan..*3 r.n ;6 Mn Sc mtes nouncinc a "ec conscionW y . told !!nc inve:tica.cors 21.1 any, CO.*;U h*1,1 any Crect rois 1:t prograut?ts'Por?nr.nn anCasking again ouality denteitbad. [dcems a to den p:11ty contal J@'nitr/ brdorn ct21cca" ' Esurance mana: ers tJ rin*1 areas , .in:*,4c1.!ons vould have?corto.
- On vnricu or their program that could I'm . ,from COLE msn:. ement mret -
@c: .Iny r.:.mran:s o c::n:InnEo'c.h c:er.:
ur bret. 'mre.ununed. simp!!fied ce ub. poea- Ethrt:rs ident111cd tj: tr.::.
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- ",'tc.h cut'. inly cts not att:In*&O=encez py,in come cases, deleted.
of oMalen t'itn Er,11-; g..m .. m
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5.. Friedrich responded in a Feb.* %. p.,,,,,
LMirtet rmrn':t::nt t'ao overs & ; j'tmemorandum thct such cuty
.pco tun.* E.w arstd. {j.n t p ;, , .
't+ l lac."s would make lt impomble to. ,
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- 73rct7n p2 mist'f;n: .tvg ; fun t.n adequate qucilty assur- .CDNTr312D. F.R,OM ,P, .AGE JA.-1..
JhcKild have bnC
- m"ntRshould rp
- rinTr . 1 aaer program. "I solicit your help haved como.cha s.
ila cetung the personn21 neces.. -
-cotatttilei the pronam 7 ; as E Il Bor.n.'an, but he ts!d he c,w tha p~rrm m no..Ent t9 ; pry $3 do a sausfactory job.* he .
t erut e .2 ' n, could not rc: ,1111 E trmann hr.d ttened thae u= ament -
vont twas 9 3 daub:rately Cold 3 E *Friedrieb wrote another- , meetings..
Erlax to r. bort:ut Lt cr not cb.rr,y (d,ttral memo on !5r.rch 23, IS75.-
,j . D; Lehining that str months had e Schwiers teld investM2 tors he f'.11crutis fdse.' '
E.1230ever.corrt:nondenco tg p:::::tl since COhE denied his we.s under
- tremendous prtr. sera *
. tvsten CG'.4E and W9:'r-1cicd. - W.nal request for mere man. during his t:signment at Zir:.cer.
ter two letters *ta by Dorr. J power. " Construction intends ts Refusing to dczertte the prerAn e, t::."m and one dtd by CO.';d start a third shif t." he sali "We = Schwiers cut off the intarmvr by Prc:1 den LE.))llLLsXcktor.:r- .s So not even have covercge on tbc. saying he was going to limit his g
second sbitt, which is Du11dic; responses to "yes" e n d "Zio" an.
swers, talla dificrent rtory. .. S U.i bp" In many c":% It trns CCT g *
- In yat enathe' m"te*& CGl4E spokcaman Dave Afte ,
1.ht.t prevents.d Et.*ter from Cf.rry- -"M.'; M : N .':d n o t t; . .c;3 IDS out to ade* tste CU*ljty en32 'dum on CG4E tmpcs d hiring
$1mt*.s dates Aug.1.19%. Fra.*dttch Eor,*mnn fer fur;her cenment, trol FTo; Tam 6y refu3mg KAWr corDpl&inec of hsting to rely on / Pts::hte 0::';nWlened that permi:.2bn to hire enouga people ternporary summer help under a CG&l; had written letters, but to do th safd, "Our phlicsophy has been abows, e job, Lt.ze correrpondencer youtn t.ffirmative action procram
.^ m keep the Zimmer site docu. and is that v.e're lookint for mentauon cen*ar in order. competent stit';ni, ef!ktency FO'.Y.O*7ING 13 -
- 1a 3 !;*/r- d:.t M ? 'irth a ar d pm:uctW. WP.v. !*ru sym-the ccarce poncence:a :nsp!!ng of IS7G. Lorsusa.nn approveu flu ta n.'se ! c tc. m r w sra m taumrxrs into qwJaty.
e in a lette r to Borrmanrr" new quality assranu immtes dat-d Oct.14, m4. Wil: tam Pr'e . sor luuser. Dut vetoed a recaut Mr n g.y nmes ee; g, ditch, for another five hires. In s nat . could sea avre*.stre manra; vier W tc, then stid Jtquality t::surance.
aas ntsolutel,. USA Dy then s*frE1]l2r refraln. he t micht tre trht in an r.rea, se ELT*s Cry" to beef up Mctser#s. sMd. "Qur.ntity is not f.h ris th8 woujd turn tt down, if th?rc W Sur.11ty trur:.nce staff if the esirrer in g dott, re cWht questicn. If t.h r 3e cerDpsny tras u co= ply t-111 Mb' , etting sstisfactory ina . vts k genuine need for c*or.
ftderbi ine=attet redatme . --- <--*
D' DW" D d> Me M I% il h ES 3 "r.***nt.W: bb* CLIr*n* con *1-mets w wara *a~a e " :*.*
CDCD t *3 t.t W ty'tC::s 13 SW.d. -
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s O O EXHIBIT B _
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TI-IE CINCINNATI GAS & ELECTRIC COMPANY CIN CIN N ATI. OHIO 4 G204 5ranuary 14, 1972 4
Kaiser Engineers, Inc.
P.O. Box 658 Cinc,innati,. _ Ohio
. 45201 Attention: Mr. D. R. McSparrin .
/
i RE: WM. H. ZIMMER NUCLEAR POWER STATION -
COORDINATING MEETING, W.O. 57300-902, JOB E-5590 .
Gentlemen: ,
We are enclosing two copies of the minutes of the coordinating meeting held at the Sargent & Lundy offices on Thufsday,' January 6, 1972.
. Anyo,ne having corrections or clarifying comments pertaining to these minutes should advise us as soon as possible in order that appropriate action can be taken prior to the .
next meeting.
Very truly yours, THE CINCIMNATI GAS & ELECTRIC COMPANY h ,.
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By //
AER:dk A. E. ROTHENBERG, CHIEF ENGINEER, Enclosure
& Manager - General Engineering Department cc: W. H. Dickhoner W. V. van Gilse (3)
W. J . Moran R. F. Schierland ._
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..J. D. Flynn FRO:.5: DA'rE:
k/C w W . Beringhaus (2) L'.03PARRlN f f S ') L
,.n v; s Y.'TA. Borgmann (2) C D Pl2s T o:
.61.0 \. s ' Van Veen (2) 1,2 (2) v _ pg f j
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E: C. Pandorf Jpj // l r 9 'h,, W'. B. Murray DJ'.7 v
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M. Percherton (2) e' g(6 ,.gd l t,. ?" . 51 ep /M5Ir%
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1 U . U Wm. H. Zimmer Nuclear Power Station - Unit 1 Minutes of Construction Coordination .
Meeting Held In Sargent & Lundy Offices
/ On January 6, 1972 The following persons were in attendance:
The Cincinnati Gas & Electric Comnan.v .
W. V. van Gilce, A. E. Rothenberg, J. D. Flynn J. R. Schott, R. J. Van Veen, C. W. Beringhaus, and E. A. Borgmann Veiser Engineers, Inc. -
. D. Williams, D. R. McSparrin, C. Gray, and J. Uillings -
Sargent & Lundy W. Hegener, R. Heider, R. Pruski, R. Cotta, and L. Oyen I
The follouing items were discussed:
, 1. A clarification of item 8 on page 3 of the . minutes of the meeting held in Dece:5ber was requested. This item referred to an agreement regarding revised S&L design drawings and led to an extended discussion as to how
, drawing revisions and progrecc prints are to be handled.
The following procedures were finally.. agreed upon:
- a. No co-called progrecs prints of a drawing will be issued after that drawing has been once issued "For Construction".
~
b.' When~cigni#icant_ design changes are made to a drawing af ter having been issued for construction, Sargent & Lundy will
, , issue-official revicions of the drawing.
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If Sargent & Lundy drawing changes are not significant to the design nor i'f they do not affect the Constructor's offort to any degree, such changes will
' be accumulated until Sargent & Lundy
. believes an official revision to a
. drawing is justified. - -
~
- c. It will be the responsibility of Sargent
& Lundy to call to the attention of Kaiser. Engineers any design changes in progress to critical areas. This should f_
i be done in advance of any issue of -
I revised drawings.
/ ,
d .' Sargent & Lundy requested that Kaiser
! submit to them for approval any fabrication
, detail drawings made by Kaiser, both for shop and field work.
2$ In view of S&L's. request to approve Kaiser detail drawings, ,Mr. McSparrin requested a Sargent & Lundy man ,
in the field to review K-E drawings. This request had' 1 k.. previously been made of CG&E and Mr. Flynn again refused l ; this request of Kaiser's. -
j 3 The 23 Action Items resulting from the December 6, 1971 meeting were then reviewed. The following are the dispositions made of those items:
a[ Items 1,' 2, 8, 11, 14 ,' 1G, 17, 22 will be
! dropped either because they were completed or are of a continuing nature.
Items G,' 18 ,' and 21 were on the agenda of bl ,
- _. the meeting.
l . .
- l. g c. Item 7 covering the culverts under Little
[ .
! Indian Creek will be dropped since S&L
- has decided to route the cooling tower blow-off line under the creek. Therefore, -
j the present four, 36" culverts vill remain in place.
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/ d. Item 20 covering the well water storage
~
tank will be dropped inasmuch as S&L has. concluded this tank can be used for
~ construction fire protection service .
. and moved as required for permanent .
well water storage seryice.
- c. Items 3,4,5,9,1b,12,13,15,19, and 23 are in progress and will continue to
. . be carried.
4 K-E requested t' hat a meeting be set up in February to discuss testing, particularly pre-op testing. 'CG&E agreed to review the information previously submitted .
by S&L and to decide if a meeting on the subject is vorthwhile at this time. .
- 5. S&L indicated that some additional piping single line diagrams are about ready to be sent to CG&E Co. for review. ,
G. Sargent &~ Lundy has concluded that a 75,000 to 100,000 t , gallon well water tank should be utilized. S&L requested 8 ~that Kaiser construction fire protection layout bc submitted to them for review and approval. ,
/ 7. CG&E Co. indicated that they will begin logging the S&L numbered project letters in and out of the General Engineering Department mailroom. K-E indicated that they have also adopted a K-C numbering system on.all of.their project letters since the beginning of 1972. These will also be loggcd by CG&E, 8 Sargent & Lundy indicated that the project equipment list -
is being completed. A computer print-out.of this list is currently being contemplated. The mechanical list is pretty well along and the electrical and heating and
~~
, ventilating list is being worked on. Target date for list completion is March 15. -
9 Sargent'& Lundy stated that their piping line lists will Normally, S&L t, ,. cover all piping shown on their P&ID's, .
-
- will issue line lists with the release of single line piping diagrams.
4
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10 K-E cuggested that procurement identification of class I valves be done on the b' asis of valve serial nQmbers rather than on the basis of the assigned S&L valve numbers. The idea behind this suggestion was to eliminate possible documentation problems if it becomes desirable to assign identical valves to services other than those originally assigned . by the S&L valve list number. After some discussion, it was agreed that the disadvantagcc of relying on serial numbers f or valve idendification outweighed its advantages. Therefore, it was agreed that the S&L valve idendification numbers will remain the primary means of identifying valves on this project. (subseauent to the meeting, during a discussion between K-E and CG&E, it was agreed that something could be worked out with the successful valve -
vendors to allow some flexibility in installing valves.
The vendor can be asked to refrain from permanently imprinting into the valve body the S&L identification number. The identification tags affixed to the valves can be permanently affixed while still being transfer-able, if desired, through the use of screws or some
- similar type of removable fastener)
- 11. Comments on the proposed valve procurement criteria will be forwarded to S&L bp CG&E af ter some disagreements with K-E are worked out.
- 12. Sargent & Lundy indicated on drawing s-3 the new location of the service water discharge line. It is still 200 ft.
. downstream of the intake but the revised orientation of the intake moved the service water discharge line further north (downstream). It now encroaches on the proposed location for the con;; rete batch plant but K-E indicated that something will be clone to accommodate the discharge line as shown by S&L.
13[ S&L indicated that the discharge from the permanent sewage treatment plant.will enter the Ohio River via the storm
- drain just upstream of the intake structure. The location of.the sewage plant is now indicated on drawing S-3.
Mr. Van Veen will transmit the information on the sewage G
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plant discharge line to Battelle Northwest. Copies of revised drawing S-3 wil1 be transmitted to CG&E by S&L.
14 CGLE indicated that information on control points was transmitted to their Distribution Department to allow completion of the Ann Brehms property survey.
15 S&L indicated that they are formally transmitting answers to the K-E questions on. the concrete specification.
Where they are in agreement uith K-E comments the specification will be revised accordingly. The following three areas of concern were specifically discussed at the meeting: .
- a. Point of sampling for field tests. S&L will .
- still specify that all samples be taken at the point of discharge into the forms. K-E will determine in the field if this can be done in all instances from a practical utandpoint. -
- b. Time interval between batches. S&L will continue to specify 30 minutes between batches and believes that K-E planning should be on that basis. For cases where this time interval can't be met, K-E should determine the means of determining plasticity for longer time intervals between pours. .
.c .' Void ratio on cadweld splices. This was briefly discussed by S&L as to how it affects the possible number of rejected adjacent cadwelds in the vicinity of a defective cadweld. This will be covered in more detail in the S&L letter.
. 16 CG&E indicated that they believed the drawings with the proposed K-E robar bid package were not complete. K-E pointed out that robar will be bid on unit prices but
,that they did intend to include all applicab.'.e drawings t
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i available at the t'ime of bidding. S&L believed sufficient drawings are available to obtain representative unit price bids on the rebar. It was agreed that K-E will formally transmit the robar package to CG&E for review and. comments.
' 17 CG&E expressed some concern over K-E not intending to ask
.for lump sum bids on waterproofing. K-E expressed a preference for taking unit price bids on waterproofing and will transmit the . bid package to CG&E for review on that
. . basis. S&L indicated that they are formally anspering K-E questions on the waterproofing specification.
18 CG&E indicated that they .iid not wish to take bids until required by timing of work in the field. It was agreed ,
that bid packages would not be sent out until required by the latest projected construction schedule.
~
19 K-E requested some information on construction details inside the containment. They were shown the latest S&L drawings in this area and expressed satisfaction that all steel connections are bolted. . .
20 The chieldwall crection was discussed. It wa s S &L 's
/ belief that K-E intended to erect the shieldwall and that they should review the design. K-E will review the design
. for construction joints and for sequence of erection in
/
conjunction with the free standing mirror.~ insulation for the vessel. .
21.' K-E left a drawing with S&L chowing loads on the co.ntain-mont for one proposed method of placing the reactor-pressure vessel. More information is being'obtained by K-E from other erectors which they will forward to S&L for review when received.
3 .
, 22. The next meeting is scheduled for 8:30 A.M. on February 2, 1972 in the offices of CG&E, ,
. c> ,,v.,-
E. A. Borgman/n e . .
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Eb 0 CT F T ~ ~ ~ ~4 TIIE CINCINNATI GAS & ELECTRIC COM PANY . CINCINNATI OHfO 4520f July 18,1973 Mr. W. J. Friedrich
, Quality Assurance Manager ,
! Kaiser Engineers, Inc. .
- P.O. Box 658 Cincinnati, Ohio 45201 RE: WM H. ZIMMER NUCLEAR POWER STATION -
NON-CONPORMANCE REPORTS COVERING .
REJECTIONS, W.O. 57300-960, IOR E-5590
, Gentlemen:
Recently, we roccived copics of Non-conformance Reports N39 and E68, both of which covered rejections upon roccipt of materials purchased for the project. Previously, in discussions with Mr. J. W. Sutton of the AEC, he suggested that Non-conformance Reports should be used with a degree of judgment in order to minimize the total number issued. IIis main complaint however, was the more written the greater number would bo in the' non-I dispositioned status, which he felt was undesirable.
1 It is our opinion that any material which has not bacn accepted at l
the project site and has been rejected, should not be covered by a Non-l conformance Report. We feel that once the material has been roccived, is placed in storage and at a future time, is found to be deficient and is rejected, then a Non-conformance Report should be prepared. However, those materials l'
rejected on the basis of a test failure prior to roccipt or inspection at time of l- receipt should not be covered by a Non-conformance Report. If it is necessary to maintain roccrds on vendors supplying material that has been rejected, it is suggested that some means.other than a Non-conformance Report be utilized for this purpose. ,
i We further emphasize our position by citing the fact that for trucks of concrete rejected there is not a Non-conformance Report prepared.
l It is conbeded that criteria are established for their rejection and similar l
r
I s
- . [ To
- Mr. W. J. Friedrich July 10,1973 Re:' Wm. II. Zimmer NucIcar Power Station - Page #2 1
, Non conformance Reports Covering RcJoctions , -W.O. 57300-9 60, Job E-5590 J
. e critoria can be established for other materials. The concreto documentation does include record of rejections and it is suggested that other material l rejected could be documented in a similar manner.
Very truly yours, .
TIIE CINCINNATI GAS & ELECTRIC COMPANY i .
By , _, e' "A'A
- i
_DWARD C. PANDORF
{1rincipal Quality As'surance
, and Standards EngI'ncer
{ General Engineering Department .
WWS:dow l
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R' v &'
U - )N&/li ~ DaE j ") h EXIIIBIT D
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TIIE CINCINNATI GAS & ELECTRIC COMPANY C ~ ~~~ ~..
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. . July 19, 1973 . s: i 2{ C~ l
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,,g.. c Kaiser Engineers, Inc.
P. O. Box 658 i!ITd j , ,
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Cincinnati, Ohio 45201 cm . ,
se . r- ;
~ -=. s 1 s l l Attention: Mr. D. R. McSparrin - '..'- - ~T-q.; y _-
. i l
'RE: WM. II . ZIMMER NUCLEAR POWER STIiTION iT ~ _.
b !
UNIT 1 - PIIASE 1 PIPING SYSTEM ERECTION, S&L SPEC. 11-2254, 4d_M' -'
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i W.O. 57322, JOB E-5590, FILE #2400-: ,,
F i l Gentlemen:
'L -l This letter will confirin information given to you verbally by Mr. 11. .C. Brinkmann during the construction meeta.ng nela in your orra.ces on ou1y 18,; 1973.. , _
We feel it is Navisable to continue using distilled water for testing of sections' of stainless steel piping s,ince we cannot " prove" that chlorine attack would not. occur if well water were used.
It is not necessary, however, to perform these tests in full compliance with ASMC Standards since the test for ASME Standards will be done on the whole system as one piece at a later time. It further seems reasoncble that we could reuse hoses from previous tests without sending them again to laboratories for chemical analysis if we simply flush the hoses with distilled water prior to using them.
~
Please take this as our instruction to continue using distilled water for testing of stainless steel piping.
As mentioned by Mr. Brinkmann in the above meeting,
.this itemo applies to stainless steel piping. Our previous memo pertaining to stainless steel tanks which permitted use of well water in the tanks still stands. The reason for
s .
g To: Kaiser Engineers, Inc. July 19, 1973 Re: W m . II. Zimmer Nuclear Power Stati6n Page #2 Unit 1 - Phase I Piping System Erection, S&L Spec. 11-2254, W.O. 57322, Job E-5590, File #2400-1
?
permitting well water to test the tanks but not the piping
- , is that we can drain the tanks immediately after testing and thus assure no prolonged exposure, ,
Very truly yours, TIIE CINCIN17ATI GAS & ELECTRIC COMPANY 0
- By
[~)E/Cd:tc.-,de F A. E. ROTl!ENBERG, CIIIEF EN INEER,
& Manager - General Engineering Department AER:ah ,
cc: C. C. Gray E. P. Cooper ,
M. L. Evans W. E. Ilasmann J. D. Flynn E. A. Borgmann W. B. Murray W. W. Schwiers e
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. j July 24, 1973 t
Kaiser Enginecro P.O. Box 201 Moscow, Ohio Attention: Mr. D. R. McSparrin I .
RE: WM. Tf. ZIl@lER NUCLEAR POWER STATION '
UNIT 1 - ERECTION OF PHASE I PIPING SYSTEM, S&L SPEC. 11-2 2 5 4, W. O. 57322, JOB E-5590, FILE 2400-1 Gentlemen:
' ~
The purpose of this letter is.to clear up any confusion which may exist as to the requirements for residual chlorides and the domineralized water being used t.o hydrostatically ter.t stainless steel piping. Although the above mentioned Sargent & Lundy specification indicates that strained river water or deep well unter can be used to hydrostatically test, we wish to make it very clear that only domineralized water can be used for hydrostatically testing stainless steel piping. Furthermore, the domineralized water used under no conditions should contain more than one ppm residual chlorides, t
Very truly yours, i
TIIE CINCINNATI GAS & ELECTRIC COMPANY By M' A. E. ROTIIENBERG, CIIIEF ENGINEER,
& Manager - General Engineering Department AER:mj} }
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- TIIE CINCINNATI GAS & ELICCTRIC COMi%NY ~~- ~J CINCINN ATI OHto .t D2Of i March 18, 1974 3
Kaiser Engineers
, , P.O. Box 658 Cincinnati, Ohio 45201 Attention: Mr. D. -- R. McSparrin i
RE: WM. II . ZIM!!ER NUCLEAR POWER STATION - UNIT 1
' PILE - GEN. 037, W.O. 57300, JOB E-5590
[ -
Gentlemen:
This letter will confirm that "nonconformance report" No. U-96 was approved and handed to J. P. Billings ~
on March 8, 1974, by Mr. T. T. Fox. This nonconformance i report deals with material for temporary construction, and
' while uc have approved this.nonconformance report, we will l not approve such UR's in the future since we do not feel i that a quality assurance program is necessary for temporary construction. The cost of such a prograrh does not gain any benefit in terms of the completed project.
l We feel that the inspection effort should be concen-trated on the essential items and therefore are directing KEI to stop issuing NR's on material and procedures for temporary construction. .
Very truly yours, .
l TIIE CINCINNATI GAS & ELECTRIC. COMPANY I r" Q '
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- A. E. ROTIIEMBERG , CHIEP. ENGINEER,
&' Manager - General Engineerins Department l
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KAfSER Ef!Gif1EERS. INC.
NONCONFORMANCE REPORT Vi!.1.11. Zif.t!.;E R POWEll STATl0f1 fl0. _ N ' f> PAGE l 0F /
- 1. DVIG/lflSTALLAlluf1 fl0. 2. UWG/lfiSTAL LATIOfl !!Af.1E: 3. P0/C0flTR ACT !!O. 4. SUPPLIER / COT!T RACT0ft f; Ar. E:
J M/:-2 B-/02 0/L .9roncc yyy 7070 '?sM C.&_c_. /M Q 8PoR k72~D 5.INSPECTl0ft P1 AfJ NO.: 6. INSPECT OR: / 7. D ATE: 8.SPECifICAll0N f10. ASt.1E YO O .~.hfffIV_fijM kWhY /}ST/)-/}/O f YES[3 tJ0 V$
- 0. DESCRIPil03 0F N0llCONF0flf.1ANCE 10. DISPOSITION 11. DISPOSITION INSTRUCTIOf;S/ JUSTIFICATION 21:GPtRAM GA'73 '
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- 12. REVIEW BOARD (REQUIRED CN ALL ACCEPT / REPAIR DISPOSil10fJS) , fpp',,,-, p , y KEl CONSTRUCTIQ314f;GR. DATE
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S&L e CGLE SPONSOR ENGR 'DATE DATE CGSE 0.A.L S. 0AEg DAl
- 13. REPAIR /RE WO R K C0f.PLETE AND ACCEPTABLE INSPEC10R/EfjGINEER DATE I?.CAUSE , 15. C0llRECTIVE ACTION I / *
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' v N \C b EXIIIBIT F -
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l February 20, 1974
. - KC-1760-Q Mr. A. E. Rothenborg, Mant:sor .
, Ccuarc3 i*ngineering Depat tr:ent The Cincinnati Can & Electric Co.
159 Ennt Tourth Street Cincinniti, Ohio 45202 Attention: E. C. Pandori, Principal Engineer -
Subject:
Vendor Surveyc for ASME Code lhterialc Centler.cn : .
t As a nenufacturer nnd holder of an "N!' nectnp, ve nro obligated under l t.ection 1:A 3361 of Llw code for curveying cud qualifying the Quality j Sycten Proprcia of cuppliera. ,
i i
Cur Qu':lity Accurence !!cnu:.1 Q.'t? 05, Precurenant Document Control, pcregrnph 6 vaa reuritten to satisfy the Code Co:=d Ltee (!!r. Frittn).
i lic van very enphatic ot thc't ti::2 that thin porngrrph be included end cor. plied with. He sented thct this ia one itcn that in revicued by j the Code Inspector ccaigned to the project. -
At the prencnt tir.c YEI is purchasing code ncterin2a cuch as ucid rod e
- pipa, r;nd pipe fittinga. It 1.ns been our practice to perfc*rn curreya
' ct the ctopliera 1.lcut, cnd ua vich to continue cad no!. put our LSE ctatua in jeopardy.
j Recently you heve diccpproved requc:tc for such nurveyc. At the tino of i your decision it uc. discucced with no cnd I did ceruc'. llouever, sinca
- that tim I have hcd cn opportunity to revicu the code cud diccuco the
!. detallo with the F.CI pe? co:tuel involved. I cu ccav.tuced nor that you j cnd 1 crred, and I would like you to recoacider. -
l Thia acto requirc:mnt io it: posed in Appendet n of 1001730 Criterica VII,
- cad it uceld behonva you to revicu your puocedurec relative to cusential -
i hardu.yc tuad cet recordingly. .
I Very truly youra, j r/JCE: *z:Jn' r S, . :c.
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- 17. J. riicdtich
- Site Quc.hity A29urenca Icancer IUF
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__ EXIIIBIT G
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. ' P. arch 28,1974 KC-1908-Q .
Hr. A. E. Rothenberg, Mtnager *
, Cencral Engineering Departr.cnt The Cincinnati Cas & Elcetric Co.
139 East Fourth Street -
~
Cincinnati, Ohio 45202
-' Attention: E. C. Pandorf, Principal Engineer ~
I
Subject:
Receiving Inspection Centicr.cn : .-
Follouing are co ac qudstions regarding the receiving cnd inspection of CC&E purchased equipr.ent which rcquire clarification and/or resolution.
After the questions, we : ave written our understandinp, of pcst instructions fron CCSE. "c .could appreciate having you revic i the questions and our ansucts. If uc have nisunderstood CCSE's position on these points please -
advisc. * *
'1. What docu::catation should 21'1 have in the Site Docn:::ent Center *
~ files to show that CCLE vendors have been approved?
Presuacd Ansucr: No docun.entation is required in SDC files.
CC&C is responsible for naintaining records to denons trate evalu. ion cud approval of their vendors.
- 2. On CE equYprcat a nortification is attached indicating that the ite:a has been released for shipment. On other equipr: cut purchased by CC&E uhat system is' to be used to indi'cate that chiprent heu been authori::cd? .
4
, Presumed Ansucr: .CGLE to develop a release systen.' ,
. t
- 3. In KEI to develop a check lie. for doeur.cntation on cach item purchased by CGLE7 -
f recur.ed 1.as.cer: No, CGSE uill develop the uccessary doch 11ut cir.:e they vill be receiving, revieving, and appro tInc these docu:: cats. * *
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, E. C. Pcndorf T .
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March 28, 1974 Page 2 *
- 4. On CE equiprent a PQCL is forwarded to iGI to indicate that U '
all the required docur.cntation has been received and approved.
KLI releases the itec frca hold based on the PQCL. For equiptant purchased by CCSE will a docu: tent equivalent to a PQCL be prepared by CG5E?
- Preau=ed Answer: Yes, CGSE will provide a docueent equivalent
. to the PQCL to' release equipment for 'installatio.a.
- 5. What is l'EI's rocciving inspection responsibility on CGSE '
purchased equipront? '-
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~ . _ . _ ,
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y i' Presutted Ancuer: On all CGSE purchased equipment, including l CE itens, KLI is to inspect for shipping datare and identification. -
' Undariated equipt. cat r.ny be released for installation as soon as the PQCL,or CCSE's equivalent document is received.
- 6. %E the classification of an item change the KEI receiving inspection requirements?
, Precutcd I.ncycr: o, the classificat-ion vill effect the atount of documentation which CCSI t:ust review but will not effect KEI's inspection responsibility.
- 7. Is PCI to revice any of the docutentation en CCSE purchased
.' equipcent? -
Prccur.cd Ansucr: ;o, KEI is only r'esponsible for the filing of docutentation which uill previousl*, have been reviewed and
, accepted by CCSE. EEI should vcrify that all docurents have been stat ped by CCSE prior to filing and that the docutentation l
Clicek List has been signed by the cornicant CGSC QA55 Engineer.
Very truly yours ,
- o 1d* ISER C'iGI ;ZERS,1: C.
- l l
U. J. Pricc' rich '
Site Quality Assurance !!anager i
- CAS:cbei bec:
i D. P.. McSpartin -
t D. II. Williams
- V. P. Mcitahon '
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,.', -(j . "5y iijj!h EXHIBIT H
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. April 9, 1974
. QA-411 Kaisor Engineers, Itke. -
P.O. Box 201 .
Moscow, Ohio 45153 .
f Attontion: 11r. D. R. McSparrin rut UM. H . ZIMMER NUCLEAR POliER STATION - .
,.i.
l UliXT 1, RECEIVI:iG IliSPECTIO:i,
, 9.O. . 57300-957, JOB E-5590 b
7; Gentlomon: ..
I i This in in reply to your let'tcr EC-1908-0 containing b qucations relating to recciving inspection and handling of documentation. The follcuing answers portain to all equipment 7 purchaced by The Cincinnati Gan 4 Miectric Company except Lg Phase II piping acconblico, which are covered by the "Procedurc 4 for Verification cnd Handling of GA Documentation for Phase II 3 Piping Subcoactblics". ,
Your presumed ancuer" is correct.
I. 1.
- 2. The Cincinnati Gas & Electric Company docc not t ') have a formaliced relenso for chi.pacnt progrant I comparabic to that of General Electric. Moct
- componenta are relcaced by the vendor cccording
' to a prodcter:cined chip: tent achedulo. An onception c::icts in the cacc of certai:2 elec:
l . trical equipr.cnt for which CGt,E reviews test j j data and documentation prior.to rolcace for-r shipment. ,
- i. .
3.* Your " presumed annuor" in correct.
< t
' e 1
- 4. yo do not nnticipato the need for a docmaent comparable to General Electric's Product , ,
Quality Certification (which cuperceded the PCCC cffectiva .Tommry 1, 1974)- Relence for installation vill ca banca on recc.w:.ng j ,
inepcetion and 2:cccipe of required CA decu-Montn.
i
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,To Kaiscr Enginecrs, Inc. April 9, 1974 Pago 02 Ron Wm. H. Zicmcr 11uclear Potter Station -
Unit 1, Rocciving Inspection, W.O. 57300-957, Job E-5590
. 7 s
- 5. KEI's rocciving inspection responsibil y
,. includos the reporting of any observed ,
l non-confortnnco to the procurement docu-monts, including shipping damage and identification. Roccipt of OA documon-tation for casontial CGGE and KEI I
purchases is required prior to installa-b tion or ucc.
~ - -
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L 6. Your " presumed answer" is correct. Rofor to the anmtor to question S. Also, wo do not plan to conduct in-dopth reviews of ql, documentation for non-cssential components.
I
! M 7. Your " presumed ansucr" is correct insofar as OA docucents roccived from CGsE vendors is
~i concer:1cd. Howevor, KEI has responsibility i :., i for rovicu and ac'ceptance of OA documents i
F gonorated as a result of any field operntions b involving CGLE-purchased components.. Your ancucr also implion that cach document is
- $ stamped. Our practico in to stamp cach .
- P document package to indicato QA&S audit.
t Wo truct that this will clarify the concerns c:cproceed
) in letter KC-1900-0 If the::o are qucations, please lot us know. ,
l , Very truly yours, -
l4 ! THE CIHCINHATI GAS & EIJ:CTR.TC COMPANY i
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A. E. ROTHENBERG, CHIEF ENGIMCAR, l
6 Manager - General Enginocring Department '
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__ EXHIBIT I
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- _; ENGINEERE.7 4
K AIS E P E N G 4 N E E R S. IN C.
P.O.noX 201 MO L C C n. O M IO 4 515 3
/
- April 19,1974 KC-2000-Q
- p. ,
Mr. A. E. Rothenberg, Manager ,
General Ensincering Departnent' The Cincinnati Gas & Electric Co.
139 Ecst roucth Street Cincinnati, Ohio 45202 Attention: E. C. Pandorf, Principal Engineer
Subject:
Receiving Inspection Ceutict.cn :
'Your letter of April 9, clarifying our receiving inspection responsibility htw been very helpful. The following is an outline of the receiving inspection prograa ve are irplementing in response to your directives.
If vc have uisunderstood you in any point please let us know so that vc can take corrective action.
- 1. Uhen a CCLE purchased iten arrives on the job. site REI inspects for shipping damage , identification, and for. documentation. In addition the inspector vill report any obst.rved condition uhich he kncus is not in conpliance with procurecent documents. This reporting of casually observed nonconfornances does not nean that KEI is to revicu
\ opecifications, drnvings, and any other purchtse order document to
\ extract requireacnts for verification by the rccciving inspector.
7his vill have alreadv bcon ccccuplished by CCLE.
- 2. If KEI has rc2cived the CG5E docutent c' acch list indicating that all of the required docurentation has been received and approved then an undamaged iten vill ir=ediately be released for installation.
, 3. If KEL has pot received the completed CCSE document check list for an iteta, a Document Deficiency Notice (D2i) vill be prepared and a Hold tag vill be attached to the itca.
- 4. An'iten in quarantinc for Docu:ent Deficiency vill be released when:
i) The complete docure.nt chech list is received f rou CGLE, or .
- 11) The DD.'i is rctu:med by CLa. indicating that the itca is non-casential and nay be releescd without docu : station, or
.. ~[ LY5: 2:
r Mr. A. E. Rothenbert;= N
= -
., April 19,1974 Page 2 iii) ' An 11R is processed authorizing the installation of the iten prior to receipt of required docun.cntation.
/
5.
CE material vill be handled similarly, but their Product Quality Certification will be an acceptable substitute for CG6E's document check list.
- 6. The receiving inspection program for Bristol Steel shipcents has not yet been finalized.
John Hof fcan has advised that he is presently writing instructions for receiving this material. .
7.
The component classificatio'n listing would be beneficial to receiving inspection for distinguishing essential and non-essential ite s if it
'was brought up-to-date.
Very truly yours, .
KAISER ENGINEERS, INC.
7A 9 JMaw W. J. Friedrich Site Quality Assurance Manager CAS:sbc cc: U. B. !!urray bec: D. R. licSparrin '
D.11. U1111ams
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TI-IE CINCINNATI GAS & ELECTRIC COMPANY ""TE23 CIN CINN ATI.CHIO 45201
! September 19, 1975 I -
KEQ-43
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Kaiser Engineers P.O. Box 201 Moscow, Ohio 45153 Attention: Mr. W. J. Friedrich RE: WM. II . ZIMMER NUCLEAR PONER STATION ,
j i UNIT #1, RECEIVING INSPECTION PLANS
/ I W.O. 57300-957, JOB E-5590
~!
Gentlemen: -
The Sargent & Lundy Specifications for essential or
~
non-essential equipment requires a vendor to submit with ship- i ment three (3) copies of all required documentation. The vendor is instructed to mail two (2) copies to my attention and one (1) copy is to accompany the shipment. - ,
i .
i The Quality Assurance & Standards Section is responsi-ble for obtaining, reviewing for completeness, accepting and transmitting one copy to the Site Document Center using the Document Check List. -
It will not be necessary to include Documentation as an item on your Receiving Inspection Plans.
Very truly yours, Tile CINCINNATI GAS & ELECTRIC COMPANY N
,e n ) ., -
By O- '
- 15. C . PANDORF b[,
- Principal Qua'.ity Assurance ,
. & Standards Engineer I General Engineering Departme
/,
'd ?f C. Gray .
E. A. Borgmann J. 11 . Iloffman
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( _. EXHIBIT K m\
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- + -
THE CINCINNATI GAS & ELECTRIC COMPANY rM "k # ~
, September 14, 1976 C. A. Do rag M A N N m....m...............
United States Nuclear Regulatory Commission Region III 799 Roosevelt Road
. Glen Ellyn, Illinois 60137 Attention: Mr. E. L. Jordan, Acting Chief Reactor Construction and Engineering Support Branch RE: WM. H. ZIt'MER NUCLEAR POWER STATION -
- UNIT 1 - PROJECT ORGANIZATION DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300-956~, JOB E-5590 Gentlemen:
The purpose of this letter is to advise you'of recent changes in the Mn. II . Zimmer Nuclear Power Station project organization.
The position of Field Project Engineer has been eliminated and replaced by a Site construction Manager, reporting directly to Mr. B. K. Culver, Principal Construction Engineer. Gearco, Inc., represented by Mr. 11 . B. Gear, has been engaged as Site Construction Managcr. Mr. Gear has responsibility for all construction activities, including the construction activities of Kaiser Engineers, Inc., all subcontractors, and CGLE Co. field construction personnel.
Because some of Gearco's present activities were formerly performed by Kaiser Engineers, Inc., Kaiser's staff has been reorganized and reduced accordingly.
Kaiser Engineers' site Quality Assurance Organization remains independent of the construction activities, and continues under the direction of the Corporate Quality Assurance Manager in Oakland, California.
, A revised project organization chart is attached for your information.
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To: United States Nuclear
- September 14, 1976 Regulatory Commission Re: Wm. H. Zimmer Nuclear Power Stat' ion - Page (2 Unit 1 - Project Organization Docket No. 50-358, Construction Permit No. CPPR-88, W.O. 57300-956, Job E-5590
- Tl)e purpose of this reorganization was to give The Cincinnati Gas & Electric Company a more direct and active role in all phases of the Zimmer project with Kaiser Engineers remaining as the Constructor.
Effective September 1, 1976, Mr.~E. C. Pandorf, Principal Quality Assurance & Standards Engineer, retired -
from service with The Cincinnati Gas & Electric Company.
Mr. W. W. Schwiers, formerly Field Project Engineer, but who has Quality Assurance experience, has been named to replace Mr. Pandorf as Principal Quality Assurance & Standards Engineer. .
The Cincinnati Gas & Electric Company Quality Assurance & Standards Section now consists of -the Principal OA&S Engineer, one Structural Engineer, one Electrical-Engineer, and two Mechanical Engineers, one responsible for mechanical components, the other re'ponsible s f,or piping systems and reactor compon,ents. ,
The Structural CA Engineer is currently a'ssign'd e to the Zimmer Site as Field QA Engineer. We plan to reassign the remaining personnel of the Quality Assurance & Standards Section to the project site shortly after October 1, 1976.
! Also effective September 1, 1976, Mr. R.'J. Van Veen, Principal Structural Engineer, retired from service with The l
- Cincinnati Gas & Electric Company. Mr. H. .E. Crail, formerly Assistant Principal Structural Engineer, has been named to replace Mr. Van Veen as Principal Structural Engineer.
We trust that this adequately describes personnel changes which have been effected on the Zimmer project and the reasons therefor. If additional information is desired, please let us know.
a Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By 8(E # A[,8""""~~
E. A. BORGMANN EA13 :dcw cc: I. Peltier
-- TII E CI NCI N N ATI G A." & ELECTRIC COM PAN ( ' -WOMS- '-
CIN CIN N 478.Ot. *J .. ;.
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October 22, 1976
. . kt a- 9 i
. . . EXIIIBIT L
~
Kaiser Engineers, Inc.- -
P. O. Box 201 -
140 scow, 0hio 45153
. Attention: Mr. H. J. Friedrich -
RE: - HM. H. ZIMMER HUCLEAR P0'.lER STATI0il - .
UlIT I - AUTHORIZED CG&E CONSTRUCTI0tl -
EllGIllEERING SIGNATURES ON HONCONFORMANCE REPORTS 1
Ge::tler.en: -
t ,
The disposition of Rework or Reject on ilonconformance Reports does -
not change design. Because of this, the approval signatures 6f Sponsor Engineers will no longer be mandatory on essential or non-essential
.Jl. lionconforming Reports with rework or reject dispositions.
~
.~iG.t '.. .
5.$' In place of the Sponsor's signature, the approval signature of
.- CG&E Construction Engineering personnel will be acceptable. The .
imple.T.entation of this procedure is to be affective irrinediately.
- .- .~
c " '
.. , . .. ;;,. . r, . _ , .
T Very truly yours, . ,
- . e * .
Tile CIMCIt!MATI GAS & ' ELECTRIC COMPANY ~ ~ -- - -
yy: .
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By ,
J ~f) *W "
W. H. SCHNIERS '
i :?/ ' .- PRIflCIPAL QUALITY ASSURANCE AND l ' .!
STANDARDS ENGINEER l ..e W .
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,, RPE:pa ,
2.
cc: B. K. Culver ' ' ' , , ,,
i 11. B. Gear QUALITY ASSURANCE &
C.,U. Beringhaus . STANDARDS SECTION
.- R l'UIPI H. E. Crall
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TIIE CINCINNATI GAS & ELECTRIC COMPANY LiRh((N i
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, CINCINNATI. OHIO 4 52ol
. November 1, 1976 KEQ-74
, Kaiser Engineers, Inc.
P. O. Box 201 Moscow, Ohio 451.53 ,
Attention: Mr. W. J. Friedrich -
RE: WH. H. ZIMMER NUCLEAR POWER STATION -
UNIT I - AUTHORIZED SIGNATURES FOR NONCONFORMANCE REPORTS AND NON-ESSENTIAL ,
DESIGN DOCUMENT CHANGE REQUESTS Gentlemen: f My letter of October 22, 1976 stated that CG&E Construction Engineering personnel signatures.vould be accepted for Rework or Reject dispositioned Nonconformance Reports. This should also include non-essential Design Document Change Requests.
- Employees of the EDS Corporation are working under the direction of the Site Construction Manager and as such, their signatures should be accepted in those same cases uhere CGLE Construction Engineers are permitted ~to sign non-essential .
DDC's and NR's. -
Very truly yours, .
THE CINCINNATI GAS & ELECTRIC COMPANY By a).w.J L L M -
=
- W. W. SCHWIERS PRINCIPAL QUALITY ASSURANCE AND STANDARDS ENGINEER
. RPE:pa l cc: B. R. Culver -
l H .t B. Gear
- C. W. Beringhaus l- R. L. Dirr
.H. E. Crail I
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__ EXIIIBIT M
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4._. _ ". . . ..
TIJE CINCINNATI CAS & ELECTRIC _ COMPANY TiW" ~~ ## '
CitlCINN AT 8. OHIO 4 5;;Ct April 1, 1977 KEQ-120
/
c Kaiser Engineers, Inc.
P. O. Box 201 Moscow, Ohio 45153 -
Attention: Mr. R. E. Turner .
RE: WM.11. ZIMMER liUCLEAft p0',!ER STATI0i1 - .
UttIT I - QUAllTY ASSURA!!CE C0i;CERil5 -
11.0. f57300-957, JOB E-5590 Centlemen: .
In accordance with your re' quest, attached is a list of those Quality Assurance items that are of concern to CG&E. Below is listed a brief discussion concerning each item. -
Item 1 -
As previously discussed, we would like to make a combined audit schedule. At your earliest convenience, I would like to discuss the responsibilities for both KEI and CG&E j concerning this schedule, item 2 -
At the recent l'anagement liceting between KEI, CG&E and S&L concern was expressed by the KEI Construction Section j concerning the QA/QC of non-essential areas. It is CGSE's intention to maintain a minimum cf inspection in the non-essential area and therefore, construction inspection plans and similar Quality Control responsibilities should be
- deleted fro
- a KEI's Quality Assurance scope of work.
/ Item 3 -
I have previously discussed pipe hanger inspections with j/ you and a recent audit was conducted by CGEE which should
[ detail the concerns we have concerning such inspections.
Possibly te should have a rceeting to delcraine the necessity of all of the paper work which is presently being developed for such inspections. We do intend to document that the hanger complies with design docum:nts; however, we should i generate only that paper which is necessary to confirm i , installation with appropriate S&L drawings.
Itera 4 -
Concerns radiographic acceptance and this requires a dis-cussion concerning tha use of l'agnaflux-peabody and our .
independent cudit of yter acce;Mr.nce cf pip. ucids.
I l Item 5 -
Covers a definitien of the terms as listed. It is our l preference to utilize ICO: inspection only where absolutely l
l l
. _.,m. %'
REQ-120 - 4/1/77
, page 2 necessary.
/
- presently, there are inspection plar.s A ich utilize full-time inspection. These should t-e en31yzed to determine the btnefits received fror .uch it.s;cctions.
Item 6 -
Covers CG&E's review of KEI procedures.
I usuld lite to have some input into your procedure prior to the tina it becomes a workable, fully accepted procedure.
Iten 7 -
Concerns the format used in your audit reports. I do not feel that questions that are answered by a yes or no type answer fully documents that an appropriate audit has 1cen conducted. I prefer questions and anst.ers that der.onstrc te that important phases of given procedures are heing implemented with exariples of the areas that inve been '
verified to demonstrate irnpleri.entation.
Item 8 - Covers a general discussion of QACMI's and the ar:o: nt of detail incorporated into these procedures. I have frequently stated that QACMI's include too many construction activities which should be the responsibility of the Construction Group to prepare procedures as required. Quality Assurance pro-cedures should only extract fror.1 these precedures those important activities tihich generally der.anstrate corcpliance with the procedure.
Item 9 - Covers inspection plans and involves a philoscphy to assure that inspectors are perforaing the activities which are listed on the plan. I previously indicated that paper work should be minimized; Loaever, in this crea, ne r:ust detail those important activities which demonstrate an installation in accordance with design specifications.
Itco 10 -
Covers the Quality Assurance Supplier and Receiving Engineering Activities. I have ahtays felt that each individual Quality Assurance Engineer should revicw the requisitions for purchase on a discipline basis. For example, the inochanical Quality i
Assurance Engineer should verify that each procurctent document incorporates the appropriate QA requirements for the subject purchase.
ltem 11 -
Concerns personnel require: rents, both at present and future,
, including relocation of inspectors and persr.nei to a r.: ore active discipline. For example, the necessity for the number of structural QC inspectors we presently have on the project.
Item 12 - Covars t! e appron1 c' C -Mi 3 peccd.,:. .: ' 'a.
.. bccn ap;) roved by SAL. Should these !:e includ:d in our Configuration Control Center and listed on our Docu::ent Ccatrol Register Index Very truly yours ,
TEE CIGCICATI G.'. g [LEtIRIC COMPL Y
%AO y O - , .
4-1-77
- f, .
~.
QUALITY ASSURAf!CE ITEMS - KEI
- 1. Combined Audit Schedule..
- 2. QA/QC non-essential components.
3.. Pipe hanger inspe'ctions.
- 4. Radiography acceptance
- 5. Inspection, audit, surveillance.
- 6. KEI procedure reviews. -
- 7. Audit reports - format.
- 8. QACMI's - Detail. .
- 9. Inspection plans - specific vs. area.
- 10. Material purchases - Review by QA Engineer of associated discipline..
- 11. personnel Requirements.
- i. .
! 12. KEl procedures that have been approved by S&l..
f 4
4
, 'e l
g I
o g, EXIIIBIT N
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_ i a. \ 1 \ i_ i-Zimmer -s= =
SUS'GIClOH 2 7 5, P y
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EN ineer'SReport
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" COMPLIANCE TO (the Code ,
. YueStlOUS SIUfer1RIS f Federal Regulations) regardinC demonstrable procurement and )
! Commissioners were so inter-BY DAVID SHAPIRO ested in the report and its imp!1-RICHARD WHITMIRE supplier control is, conservative 1Y 'intions f or the safety of the cwair nen service. 1 ' } speaking, in doubt," the report dZimmer plant that they held a c
concluded. "It 13 important that ' ksed rneeung in Washingt9n en r.nd %NI KAUFM.AN ,;
Entscr be able to show en acqui- penday to get an update on the 37./. . bye:tigation.
,Qfj$3wd "'-
- escence to client (CG&E) de-mands mther than non-comp l.iUcyond checking facts of the A con!!dential report that recent c ance with fcderal requiations., il- ticcument, the N RC vmnts to ly ctrited in c. plain, brown en* According to other. internal 'ltnow why it received the report utope at the Nucle'.r Regntstor7 ccnstruct!on documenid obtained l anonymously-and eight rpen'.hs Comtnt don,b prototing ncu by Gr.nnatt News Service, the re , late-instead of getting it ofncial-part .;as part of a running disa- ;ly from CGt:E cr Kaiser. I doubts a bout catety-relatt.d ' '
grrement between Kaiser and the {
materials uud in the Zhnmer nu- Gannett News Service has clear power station, Ga,nnett utility over the proper procedures llcarned that NRC Invesurators for inspect!nq critical compo- 'made at least two' trips to Oak-News tervtce has learned. ; land, Calif., in recent weeks to The report was writ +.cn last nents used in Zlmmer.
July by a corporate cua.lity engi- . Documents covering ntnc l pose that question to top Kaler hcer for IIenry J. Kaber Co., c. years of construct!on show COLE ,offieluJs. They also have visited WestCoast constructionnrm that frequcntly refusing Kaiser per- 'lCir(cinnati to interview COLE La buildb'; the 0t.5 billion power mirefon to conduct more strin- g lexrcutives.
statten for Cincinnati Gas r.nd gent qua1ity inspeettons cf ..
Zimmer supp!! cts. 'f INVESTIGATORS SAY privato niectric Co.(COLE) and tro other 4yEat- the rcport cicarly should ut!!!ttes. CGLE and Itaiser executives rion denigrate the cansitive }(als- *brd been submitted to the NRC
, Tbc confidenttal repcrt charg . er report, claiming it of little sit- ' mWer Part y1 of the Code of ed that M erel Pcgulaticns.
. Up to 00% of the structum! nificance because it telles on -
"hea.r ay" evidence to rthash old materials at Zimmer were. P.t ; problema at the plant. ,'E.@se utilitics to report to the N CGCC's huhtence, purchtsed;, . _
lF;;rfy known non-compliance'er "non-exential" (f ar non-safety #
"It was not an audit or a formal ,(M.'?ct that would cause a sub-relt.ted uns) P.nd Ihter inued for InvetUt ntion to much r.s it uns cr.enUal uses. '
,cind of a 1earntng edptrience, . %,Wrs after the problem is fcu eStcel beams were cut into caid G"rc1d Charnoff, a Wrrhing- l6. fure to cornply with the teport-section:r without transferring l ton lawyer who represents Kai er.
vital heat numbers from the
- Earl Borgmann, senior COLE ;pjequirement can result in civif '
criahud beams to all the pieces,, )ttee president in chargo of the ,lp nalties.
If the charges h thc Kater re-compromising the builders' ab!!- Kimmer plant, said parts of the re-it , pert are found to be true a ste.!!!-
e the steel and prove its partic ly sec t ns a ,; ledMxpannion of the qu'ality' con.
I tion rogram at Zimmer
~
- Inferior studs and nuta used ,9pbsolutely untrue, '
to temporarily fasten critten1 components of the plant were IcfL i- ',:.;That mas:1ve effort to prove
.Z!mmer's safety was ordered bv in place instcad of being repinced '.he
) report c. , that has not been"TIIERE l th6 WRC last year WdS notiting af ter CGLE was new
~
by permanent fasteners that ,tovered either through our own , fined 2,(D0 for shoddy record-meet nucic1r build 1nt codes set .procrams or through the l keeping, questionable construc- l by the American Society of Me- I'onfirmation. program, , quality Bo rg- 'tJo.D pracdces and harce.3 ment of chantcal Enginects. ,cna2nt said.
- .The approved vendors' Iist i Dut if COLE and its builder see ' l Eunllty controlinspectors,"tRher used to identify qutt!! fled suppfl- '
, confirmation program already as > ?
ers of safety-related material was Jpo significance in the report, the uclear Regulatory Commission ,. l: cart ts virtually certain to delay } l outdated and handled in a wa) , start-up of 21mmer at least a year 4 1 that made it impossib!c to drop .J NRC) Since does.
receiving it in the mail ; f>eyond the mid-1933 target set by vendors from the Itst for poolr per- 'three months ago, NRC investiga-formance, tors from Chicago have cris' cross- l CGLE. d' The Kaiser report also could eSite records were in such ed the country seeking informa- .@e to be something of an ]
disarray that it was impo'.stble to .tfon about the 12-page document s a r a t" keep intek of letters and memos sa.llegations. ; -~.;ttrarment to the NRC st'aff. ] 1.3 that chaned the Zimmer quality control progrum over the years. -(See ZIMMER. Pacc kl'd
alsar executives refused to
. Trn '"M"ltss
'dl the report with Gannett g
be. Lal!d 7td:*s Service, referring all ques-
.tiens to attorney Charnoff, who is g
,COtrTINtJED FROM PAGE A1 Yepresenting Kaiser before the EORGMANN SAID the report NRC on the issue.
a TWO MONTits after the report must have been talking about
- . EEs written, NRC inspectors- CHARN0FF SAID the report steel that was purchased by Kaiser
- unaware of the Kaiser findings- was written by Sherr!!! Nolder, a
. conducted their own routine Katser quality engineer in Oak- mi r c ur 1 eIu d at
- lnvestigation of procurement land, who wcs sent to Zimmer by Zim. ggg mer- the steel bought was
. ptcetices at Zirnmer. David Howard, who had just be-
'. . .Although some of the same come Kaiser's director of quality bought with mill ct.rtif1 cations'"
- pr,qblems cited in the Kaiser re- assurance progams. '
he said. "When it came to upgrad-
- port wem n d ing certain parts of the steel, it It' t Charnoff said Nolder, who- was a very conscious program to the NRC conc 3uded spent six days in Cincinnati, was i
- CGhE that 'no 1 terns of noncom. upgrade some of the steel we al-asked to get a " fresh view" of
- the ready had mill certs (certifica-
.pliance with N LC req 'rements situation at Zimmer, but had, no
- were identifled. tions) for. It was checked by the e National specific instructions to conduct an - NRC and we have a letter from the l ' 'o d of oil r end Pressure Ves.
investigation of purchasing prac- NRC (written in 1975) accepting selInspectors, which is invest t. tices tha rc
{B
,ing Zimmer for the S a CG&E fo ' port is that it looks more formal honer described the recent anony-foNi g i r ccept vendors than it probably deserves," he said. mous circulation of the Kaiser re-mY the basis of CGhE's " personal The report is tit!cd,"Investiga - port as a "witchhunt."
expertence," rather than letting tionof Suppiler Quality Assurance (Kaiser) sent this gal down to
- Kaiser inspectors visit the ven- at William H. Zimmer Nuclear gg g ,
e dors' plants to make independent l audits of their quality progrunt GeneratingUtation' And its formal statement of on at the site rJtd she came bach i --Throughout the construction purpose cler.rly defines its aim as with this report that . . . was eo of 3mmer, the NRC has been ac- determining whether preint qual- fantastic and so far-fetched that l Cupi by critics of the plant-and the person who received it in the
- niso occasionally by CGer.,-of Kaiser home offices put it asicQ;"
. falium to reccgniza and coric ity procedures were followMi in he sald. .-
- the purchsas and.'up;rading of Dickhoner was l articulaNy i
- lemspot,entially serious* quality pr safety-related materials at incensed about charges that Dorwin IIunter, senior Region ' Zimmer.
- CGLE acted improperly when tt l
. HI NRC offIclat in charge of the Charnoff said Kalser never refused to allow Kaiser to malte
. Zhnmer investigation, said t le ' turned the. report over to the NRC indopcndent inspeetions of g g gj g .,m ". material suppliers approved by l ccnndential Kaiser report ra 3- and CG&U. *
. smieu's questions about the 4 g co,ntained few "y substantiated g .
"I don't think there was any-t ityStegram at the ptant. c.,., . -
. Ile said the repcrtad high inct- ' "It's an impredsfonistic report" thing sinister in telling people l ddnee of upgrading materiah who were working for us.how to he said. "It wasn't renlly intended proceed," he said. "They wece
- (rom non-essential to c
- ,sential, to be an investigation or anything tralpsing all over the country (n
. which carries far more stringent of thebrt. Nobody treated it D3
, l Inspection requirements,b rue at being n highly dign.ified or formnl junkets the.t weren't requirid.
e nuetear plants. '
They've got quallijed nuclear in-type of document. I'm sath!!ed l "It just doesn't occur," ha r.!d.. spectors in these shops. What gon1 that there was absolutely no would it have done other than to Any upgrading from non-essen- .unauthertredwithholding."
- "tial to es
- :ntial, they (COLU) will .;. . u-
' run up the cost to send anoth r i
inspector?" -
CHAl!NOFF DENIED the l addre11." ~'
S imp!! cation in the report that HE.SAID t!le apparent section- . Katser is seeking to blane CG&E i
l ing of steel the at Zimmer without for Zimmer's qualityprobieret l transferring heat numbers to rhh is a tehttrely new perron
- e,a$ piece could also cause maler .tomittdnto_KcLvf. nil t' ring .
N hy ve os traceability)' , lley, Kal er, we cuiht to protect' l Hunter said. "They tnust cerufy curselns."' Charnoff sr.id. "But %x
- the steel ^ either through find, the rentral impression of the peo- N ple 1*ve talked to at Kaiser is that N l l ing the patErrork hnrdwcre. They couldor testing hr.ve put in theit didn't refle 4q coming from.,ct where Kalscr was l
- a piece of steel that had been mis. ,
treated and didn't meet the mini. F,orgman said CG&E first saw s
' mum requirements Until you test, the report when it, was delivered N p anonymously in the mall several x ecs
- '8u
- don't know that."
l Hunter said new problems! weeks after it had already been
' posed by the Kaiser report are I bety added to the cuality confir-sent to the NRC.
k*
He said COLE immediately ex- S
' ITGion progrnm at Kaiser. pressed its displeasure to Kaiser
="="We have it under active review Ed investigation." he snid. I about not receiving a formal copy ~k of the report when it was written.
tgrt give you a date to complete Borgmann said the current It.but it shouldn't be very long un- dispute over whether the report Msit grows?
, n.With the NRC now expressing should have been sent to the NRC at the beginning"is something be-i IMt interest in the Kaiser report. tween the NRC and Kaiser. as far
- Mer and COLE are treating the - as I'm concerned?
.Immentllte n hot potato-i CGeE strongly' disputed
( charges that 90% of Zimmer's
, {3 EXIIIBIT O g (> = e
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L Gtu:o alse, d A D 7 6 4 7c!G % (w-a QA ,>e.p ..a) b ,eypncA.
A"a A /ugnw a.;4t n s~.Gau. ,, - :ar, c tti !c w< -> s A tu A A O g . jk' w u w-v h!J K Q.A /'IJ U -
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. ,Lfab,afe.ei,pi k ca.L.n c ,9~ 4 &unu , a lG pn p y n m a&ic p;L,n M % .c .A u .L w,A ,2 3, < 9 te est E> au L l%u . u. OuXC ,o crup c.C2.~ Cut qy>hd. n .h g e a s+E a ',.& ,e ,.a. a ~ sin. .c.-p r!,,. ,,JJ u.s,m d ad.
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m &ieqvi k v. ,wr.. a _ A - s lets. tbv sn # ! w.. pak,.~.L &s -rL-e n na) to A. <-,yded-
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s 1Q 9
_ EXIIIBIT P U.S. NUCLE!J: REGULATORY CO.SISSION REGION III Report No. 50-358/81-13 Docket No. 50-358 License No. CPPR-8S Licensee: Cincinnati Gas and Electric Conpany 139 East 4th Street Cincinnati, OH 45201 .
Facility: Villiac: H. Zic=er Neelear Pcwer Station Investigation I,t: Willia: H. Zi=ner Site, Mosecw, Ohio, Cincin::ati and vicinity, Sargent & Lundy, Chicago, Illinois, and Other Locations Dates of Investigation: Jenuary 12-16, 19-22, 26-30, February 9-13, 16-20, 23-27, March 2-6, 9-13, 17, 20, 23-27, April 10,
- 14-17, 20-23, 30, May 15-22, 31, June 1-5, 8-12, 17-19, 29-31, July 1-2, 6-S, 12-16, August 10, 24-28, and October 5-9, 1981 Investigation Team Menbers: /[Go,-7.2< / C /f (, /f/ ,
P. A. Barrett
~
/ Da v'e Reactor Inspector a n.
,2 orLL[,
fT }l/ /Cf/[-fP/
, F, b. McCartea " '
Date Ihvestigator Nkl .) A^ /{- ?I R. M. Burton ' Date Investigator
,tD[djat ic/ n /U L. C. ilbert / Ea/e Invess gator -
0f J.W . Foster u$ .
hl e
[ Investigator i.'
4 9111000379 a11124 paa ACCCR 0:00035G G PDR _ ,
E. b. Vard _/A,E Date
!fl Reactor Inspector C. M. Erb
/hM I?'
/ Date Reactor Inspector M
- j. ~& L h/.u/r/
J/ f. Schapker v / Date
}eactorInspector
/kS"L /O//(>!P/
F. A. Maura 'Datd i Reactor Inspector 1
- - ppfh j off1 6' i J7 J? Harrison Date Senior Resident Inspector Marble Hill
- /
V. J. Key
. i.s
- "Y y /s - O?bG Date i Reactor Inspector D .us4 r1 :1) /c[/(!S /
F. T. Daniels d Dute Senior Resident Inspector Zimer .
- ^
/df.20ff/
T. f. p.f;:n ,
Date
'ResidentEnspector '
. 2icke'r J Reviewed By: [N @e R. F. Varnick, Director -
_d 2 E/
Ecforcecent and Investigation Staff I/a te h%%i J. 7 Streeter, Cnief N-
. t0/297s1 Reactor Projects Branch 2 ~
~
- Date s ,,
~
^ ' \ ,.
% g ' ,
. s, %
s 1 3 \
2- '
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+-
.----;~._:..:.........~..... ,
N
P s a N& /llyJ'J/
A. B. Davis ' Date Deputy Regional Ad=inistrator ms
- M n~ HM /
. G. Keppler' tl () Date Regional Ad inistrator Investicatice Su. ary: Investication frem January 12 through Octeber 9, 1951 (heport No. 50-35Er61-13)
Aress invest:ra.ec: The NRC has been and_.is. continuing to investigate quality assurance ano quality control problems at the 2:ccer nuclear facility as a result of (1) allegations received o$ Nove:ber 18,1980, frect a for=er Zic::er site quality control inspector working at another construction site; (2) alle-gations received in January, 1981, frca the Govern =ent Accountability Project of the Institute for Policy Studies on behalf of Mr. Thc=as Applegate; (3) alle-gatiens received fre: numerous contractor workers and.ex-contractor workers during the course of the investigation; and (4) other concerns identified by NRC inspectors during the course of the investigation.
Results: This investigation has identified nu=erous exa=ples_of non_ compliance with twelve of the eighteen Appendix B criteria fer quality assurance. These exanples are evidence of a widespread breakdrown in the Zim=er quality assu'- r ance program The ajority of the problems identified to date focus on the in-effectiveness of contrc*ls implementad by the licensee and its contractors for assuring the quality of work performed. In that regard, numerous deficiencies fwere found concerning: false records, traceability of materials, haressment/
f inticidation of Quality Control Inspectors, handling of nonconfermances, Land the licensee's overview of ongoing work. Based on these findings, the licensee has taken significant corrective actions to assure the quality of I uture f work. Limited independent ceasurecents have been perforced by NRC in selected creas of concern in an attempt to characterize the impact of the quality assurance deficiencies on construction work already ec=pleted.
Although a few problems requiring corrective action were identified, the
. majority of the tests and examinations disclosed no hardware problems. In spite of the relatively favorable findings from the NRC's li=ited independent ceasurements, the NRC has required the licensee to establish a ce=prehensive Quality Confir:ation Prograc to deter =ine the quality of plant syste s impor-tant to nuclear safety because of the widespread quality assurance problems identified. The NRC will confirm the adequacy of the licensee's program and is caking additional independent verifications. Any deficiencies identified by these progra:s will require resolution prior to issuance of an Operating (l.icense. Approxicately 350 candays onsite were expended during this investi-gation and during the NRC independent ceasurecents.
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AEQUACY CF IE Ilh5TIGATICfl 50-353/20-9 AT THE WILU;li H. ZlltER i4CCLDR FOS STATICil DATE: AUG 7 1981
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OFFICE OF INSPECTOR & AUDITOR U. S. NUCLEAR R,EGULATORY COMMISSION O
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SUMMARY
l In December 1980, the Government Accountability Profect (CAP) made allegations on behalf of Mr. Themas Applegate to the effect that (a) potentially faulty construction existed at the Zi=ner Nuclear Pcwor Station, Moscow, Ohio, and (b) the NRC failed to prcperly investigate the faulty construction allegations when they were first brought to the NRC's attention in February 1980 by Mr. Applegate. The Office of Inspec:or and Auditor (OIA) was direc:cd to investigate GA?'s latter allegation, i.e., whether the Office of Inspection and Enforcenent (IE), Regica III adequately investigated Mr. Applegate's February 19IC allegaticus. The scopeo' f this report extends neither to the evaluatica of other Regien III actions relating to ZL=ner nor to the questica cf allegedly faulty construction at Zi==er.
During the peried Dece=ber 1980 through February 19El, pertinent current and former Region III persennel were interviewed ta identify what was done as a result of the inicial allegations =ade by Applegate. All available documentatien relating to IE regional i=vestigative procedures and copics of inspection and investigatica reports pertaining :o ihe
.Zi=cer site were reviewed.
1 Review of the =aterial furnished by GAP in, December 19-80 disclosed that only a limited number cf the GA? allegatiens had been brcught :o the attention of :he Regica III II investigative staff by Applegate in February 1980.
Based en interviews cenducted at Regica III, CIA determined that the initial inve'stigative'effer: ccndue:cd by Region !!! had assessed :he allegations, had received availabic material, and had initiated an investigation into those allegatiens tha: Region III de cr=ined :o be within the purview of :he NRC. Regional persennel advised that :he investigative effort was conducted in accordance with II procedures and that they believed tha: the repor: ther:ughly decutented discoveries surfaced during the investiga:icn.
OIA review of the investigative file disclosed inadequata documentation.
For example, the investiga:ive file centains no de: ailed docu=enta:icn reflecting the results of interview with Applegate or principal witnesses and no detailed record or copies of the welding documentatien reviewed by the investigators wi:h regard to the specific welds allaged to be defective. .
OLA review of 2'- er welding records revealed that of the three allegedly defective welds specifically identified by Applegata in his first allega:ica, two had been repaired or replaced, one (K-811) shortly before and :he other (RE-41) during :he IE investigative effort at the facili:7 The IE investigative report did not identify the dates en which :he velding rework was conducted on weld K-311 or that a nonconfor=ance report (NR) on K-811 that had ini:ially been closed with the notation " accept as is" was later voided and recpened :o crder the weld cut out. The investi;aticn also failed to decernine : hat veli RH-41 had been cut out and replaced e
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after the initiation of the IE investigation. Interviews of the investigators disclosed that they had no kncwledge that welding repair en RH-42 had ,
taken place. In fact none of the welds in question were inspected by 1, the investigative team nor was all per:inent welding docu=entation reviewed by the investigators.
j Applegate's second original allegation concerning the installatien of ,
safety-related prefabricated pipe centaining -allegedly defective welds was partially substantiated by the IE investigaticn. This allegation, I I
as it related to i= properly " closing out" an NR and installing :he pipe, resulted in the regica identifying ene 1:en of ncn-compliance and issuing the licensee an " infraction." Ecwever :he IE inves:igatica neither fully investign:cd nor ageurately reper:cd on :his aspect of the
, case. During the investigation of this allegation, infer =ation was
- received that the al
- cratien of the NR - which released the spcol pieces '
, the reader that this al: era:ica was direc:ed by the licensee's senior I official respcnsible for the i=ple entati:n of the QA pr0gr:n a Z4- er.
In addition to not reporting this fact, II did not fully inves:igate :he ;
, . circumstances surrounding the QA P.anager's order.
OIA's review of records and interviews of regional perscnnel did not develop any additicnal infor:a:1:n regardihg the third allega:1 n -
' inadequate pipe flushing procedures - that was not ide'acified in :he !E $
investigatica report.
j One of Applagete's =ain allega icas was "that defective welds in safe:7-
! related systh=s have been accepted, among thcs velds CT 606, HR 12 (sic) and I Sil." By virtue of prior 'UE inspections (Repien I!! repor:s 78-30
. and 79-17) , it is clear that Regica III was well aware of :he threnic and icng history of welding proble=s at 21==cr: specifically, :ha:
unacceptable welds in safety-related-syste=3 had for all intents and purposes been accepted by both tha centrac:cr and, in sece cases, :he licensee. 3ased upcn :hese inspec:icns, Regien III required the licensee-to rereview radiographs and reports of all welds which had been accepted l for turncver prior to cperation; this review started in Cc:cber 1079 and
- porticas of this review are s
- ill being studied by Regien :::. Nonetheless, the Regica III report found that Applegate's allegation in this regard i was "not substantiated" because the welds had not yet received " final '
l acceptance." In fact, Applegate was correct in saying that defec:ive l
! welds in safety-related syste=s had been accept'ed. To say : hat Applega:e's i allegation was not substantiated appears to be a ques icn of seman:ics i and is not consistent with :he fac:s. :n su==ary the Region !!I investigative i effort did not adequately pursue all of the allegations in sufficient
! depth or breadth and lackec adecuate docu=en:ation.
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NUCLEAR REGULATORY COMMISSION EIT Q _ b I* REGloN lli -
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JUL 8 1931 f MEMORANDUM FOR: File FROM: James G. Keppler, Director
SUBJECT:
TELEPHONE CALL FROM MR. THOMAS APPLEGATE t
On July 6,1981, Mr. Applegate called and expressed concern over a nu=ber of areas relative to the ongoing NRC investigation at Zimmer.
The specific concerns and my response to Mr. Applegate are su==arized below:
1.
Mr. Applegate stated that contrary to our early agreement, he had not been contacted recently by Mr. McCarten.
' I told Mr. Applegate that I did not know why he had not heard from Mr. McCarten, that it was our intent to keep in contact with him each trip to Cincinnati and that I would check with Mr. McCarten. I informed Mr. Applegate that I knew Mr. McCarten had been in the office the last few weeks working on his investigation report and that =ay account for why he had not heard from us recently.
2.
Mr. Applegate stated that Mr. Dickhoner, during a recent speaking engagement, had told'his audience that the NRC found Applegate's allegations to be without substance. He said that Mr. McCarten had
' told him earlier that many of his allegations had been substantiated and he wanted to know if we were changing our story.
I told Mr. Applegate that we were not in a position to control Mr. Dickhener's statements and that our investigation findings had confir=ed many of his allegations -- cither in whole or in part.
- 3. Mr. Applegate indicated that several key persons whom he had identified to NRC still had not been interviewed by NRC.
I told Mr. Applegate that we had not co=pleted our investigation and that our present effort was directed toward dealing with what we considered to be the most important concerns. I added that it was' our intent to pursue all identified leads.
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File UUb 4 Mr. Applegate stated he had Icarned that NRC investigators were doing a background check on his medical history with c=phasis on mental problems.
I told Mr. Applegate that I was certain we would not be conducting such checks, and that our interest was directed toward determining the quality of construction at Zi=ner. I centioned that I knew other investigations were being conducted simultaneously but could not assure that such inquiries,might not be made.
Mr. Applegate appeared to be relieved by my responses and thanked ce for talking with him.
James G. Reppler Director cc: J. Cunnings, OIA J. H. Snie:ck, IE D. Tho:pson, IE A. B. Davis, RIII J. F. Streeter, RIII R. F. b'arnick, RIII J. B. McCarten, RIII P. A. Barrett, RIII Zimmer Files m
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F:J AL EDITION /IJEWSSTAND PRICE 25c FCDAY, JUNE 11,19C2 -
A GANNETT NEWSPAPER t
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u\ PRC Plans Teleess, n Zimmer Hearings-
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3 t, d BY RICHARD WHITMIRE .
.* And DAVID SHAP1RO i
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'. Ident!!!sa to date . . . O thought it was am!d."We don't feelit la necessary because IIenry J. Katier Co4the construction f1rttr
.e , best to have us ta counted in the put!!c well ot the Itams broultht tp (by the request ; butiding Zimmer for CULE. chargeJ that
- ',, k : Gennett Nees SerWe '. ". . / 4. to rec l ca) s.re old items that are covered by he was demoted to a cler. cal job for aggres-
, arena,"!!effler
,"There will ra!J})',e not a recommendation .. ths ttality confirmation grograrn." sively pointing out deficiencies at the
.,. WABIIINGTONINew doubts about con. s
,/, N N , . struction defects at the Zimmlr nuclear.. by me or my st:ff thtt thta a! ant should be lcam3 frot:1The ra he uest to reopen Government the hearings.
Acccuntabilty .
plant. .
Itcen 3d until re era cons cccd tlat this eNRC officials disagreed with COf. Tis poser station trir;ered an announcement . I'roj:e a Washtngton b:ts:d crgant:ntion _
./: t shursday that the staff of the Nuclear plantis bul:t[g'4'per! ,"t'itJ I:cpp!sr. . .tha be;uta2s uou!J center' .that tr cred the 1C31 investigation into
- euggestions that its structural j
, * ;, . h . gcppg;g g J lug problems involved or.ly tninor repatra..
, Regulatory Commisaton supports rooglen* 'on1.odt,le fin.s la the quilty confirca.T l.immer's groblems. . ; ,
I at mak a he r ng reopenin ' s" W,' -I TU c l red by the NitClatt :sr .:. e At the hearing. Keppler agreed that it - eThe National Board of Botter and Pres-
' ' l* COm tm. m r. ' rte was the Octernment Accountr.b111ty Proa i ' inevitable-a major setback to Cincinnat utlHtles bulldly d.1:'3pt.: cwr, wtarasof ined
' I 4t -2J' J *~
Oas and Electric Co. (CO?.Q, which is building the rlant at t.toscow* Ohio. . . . 5aar.nentof qualitylatpoeters. . .
CC0 fcf f?.ulty soccrd-t:tping lmcar's anp;oblems.
hary _, ject, and not. the submit Pfa RC, that dbcovered.
blan out!!ntre how COLE whl ' Aure
.. In other snajor dovetchtnantiat thurs. , correct the problems discovered ty the '
l . James Keppler, director of the NRC's Tttst marcha effort to prove Z! aimer's . day's h:2rmg: 7 board * * *
.., y, Q, y,; p.. Regton111officeinChic go, told thellouse. s.afety is alter.dy teen e.s virtu .11y certaIn to . eCocuattt:s Chairmsn Morris 11dall,D '
The NRC's Atomt: Barety Licensing
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ne rs ay that fu t heartn are p'.1-!: mid-112 theg'!:r.t te p; .nnedA ogntn:: tell tieyond the.
by CC*.E ..
Aria, s2dcor.1rrnatic.nTro2 qu*.lity the NRC should have ram awaytakenfrom t.h6'fa5lastDoardyear, concidded and its staff its hasheartr.gt alreadyon recom.
Zimmer
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needed to consider recent disclosures of M1 n,sent rCom1Mprest-
,s yrioue quality eoptrol protilems at ; derat, sr.13 Lfe6 cnbOrr, ~
uttitty will continue to op 1 CO E cnd (turned it over f.nas done at'-the Diablo Canyon T ' , ,, ..
- * -l posa new hews. /,a iP. .- .C.!;f:rnia , . (See glMt11
'/ EL CCRGM ant 1 . r backof thisda]a
. CG&E vice president *WITH THE problems that har(been ' **I'54 .V fl!L Y.,disappc1 cit d,*. Ecr2mann . eA fcffatt qttlit? It.'urance analyst for _,
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A 18 TM CNONNATI ENQUstDt/Frkley, Ame It Mf o
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a,-.,r M,,1 CONTINUED OM PAGE A 1 B ann o tel
. g the committee, "The NRC and othe o TOM DEVINE, an attorney for a supp!!er they said was not 101-the Government Accountability views findings on structural steel . lowing the Kaiser qun11ty assur -
Project, told the Uds11 committee as mon significant u.an h uuu*
ance memo.
that the quality confirmauon pro. M jt "
e t d before this
. Jones said the Kaiser quauty gram at Zimmer does not cover all assurance manncer responded: *1 problems at the plant-only those ! The surprise witness at the don't want to see any more of .
Identified by the NRC in last hearing was Dave Jones, a former these types of memos. They tend -
year's report eenior quanty assurance analyst to embarrass us and cause more IUda11 also questioned the wis. . for Kaher who was recenuy de. Secusations and allegations."
dom of putting CO&E in charge of moted b.utsunworksatZimmer.. i . East May, Joncs said he was its own quality confirmauon pro . demoted to documents reviewer, gra w .
- JONES BAS filed a complaint and later found the demotten was
, , ; . gtththe UE.Departmentof Labor triggered by suspicions be wr.s an
. i f "Since quality assurance was i ehting for reinstatement to his' NRC informant. Jones sr.id his Deglected for many years by the f Jormer jolk In the complaint, he first contact with the NRC csmt same company that is now charg ' charges that no was demoted for laser the.t month. .;
ed with untangilng the results of* Insisting on proper inspections at . Borgmann said he hasn't hSd a .
Its neglect, I would have hoped Mmmar * . .-% e- ' chance to rc earch Jones'ctnr:es. -
that the NRC would have insisted ~ ~ " * *
.-But Borgmann dId aay,"IIe
- on an audit by an independent . I The tactdents Jones cited in-l 4 Jones) was always a documents
- cgncern,*pe said.
- e,lude: reviewer . . . He is mahing s'. ate-y . .J Nhc!and would likearetodoing CGaE knowto what as- the~.wrote
. i. In February',1981,}ones said he I -
5 a memo suggesung that the sqm that the Z!mmer quality con
- quantieninns of some inspectors broader than his area bf czpari~,
f1rmauon prc2 ram ts structund were suspect-and .thstr work ence and experuse."
. emthat sid11!!: ant problems can* ' ',,,*,,
aet be sviept under the rug." - mightneedreview* .s ., 'JONES, HOWEVI'E. says he' ' 4 j COhE's Borgmann instated .
'i' Jones said his boss replied'he was. working as a renter quauty tttat his company's quality confir ,.
vaan't hired to write memos. "lis- assurance analyst before b: was :
- mation pro;; ram w1111dentify and
.. ustned meif I wrote another one 11 emoted to a documents cicrt.
7.would find myrelf on Route 52 postuon last May.
- correct any safety related prob- ' (the road outsideit nmer)."
"I'To been an assistant qun11t/
31n A'ril,
p ifs 1, Jones says h assurance manager; I've been a .
. . He said the program 1s 66%. began a project to analyza how qua y contml nunm I v;as a-complete, and that while some pa!!ty assurance'6nur on ,
mom"entions are mada to the minor deficiencies have been- ' Tesetcr steam system. Af ter die- t . H W p ch broader G found,"none of . , these do!1 coverin3 problems with the pro . Nu want to ptr . . ,
glencies has proven significant gram Kaiser was using, Jones said - nes attacks the heart or
. relative to imps.cting the safe' s ensee quamy com ,
bewaspunedoff theproject. ..=
operationof thsZimmerstation. firmauon prorram the vulny nys .
.I e. M Around June of If31, Jones de ' can catch all of Zimmers prob .
k.*WE ARE very confident that elded that since CGSE ttse12 vss- lemsa ' ~
- providing materials to Kaiser, tus >
ostr actions to up;;rade our qvr.uty "I procedures at Zimmer willprov1de- . utility needed to 11ualify sa r.n ap . Emn,'he " hequa!!!y confirm said,"will !on pro-1 not verh be-complete saturance as to the safe- preved vendor-tbo's rupplicts cf
- cause there is nct the freedom t.t
. tP.and integrity of the rtmmer Zimmer to make indep?ndent' st&tions -. e* safety-related materials with ap J4 proved qur.11ty controlpre rsms. judgments.It takes an cet of cour-
- Afset npcrtinT that CC'.C wts ; . age to do your job t.',,ht ther ."
..*."The company has dincted chable to previda the nece::nry - " ~.
(Raiser) to take necessary steps to Documents for the audit, Jones.1 assum.the independence of the said he was puned off the project, quality assurance-quality control Iater, Jones said another auditor '
organizauon from construcuan was caDed in for the job. "I'he3 personnel, parucularly to'e!!mi- standards were relaxed and C0&E
- nate complaints that quality in . g =hesaid.' .s * .
spectors had been 1stimidated or . - -
9.'.
harassed h performance of their, s
( @'THAT JULY,Joned said he and '
inspecuans." s,t gwo others completed an audit 9
'I Borgmann tookissue with a rol that crtuc! zed Kaisers procam to e m hent Gannett News Service story ,.hufy and trace materials used reporting that CO&E has been ^pn the joth Jones asid no acuan s inrced to repair 5% to 10% of its was taken on the audit and th structural welds at Zimmer be f .,eudit was called."Inva!!d."
. ~, in April,I?"' Jones said he was cause the original wort was fsult.y.; . Joid that auditors should not write
..* *Tlria waa aomewhat a. memos, make recomsnendstions, mischaracteristion and an exujo turrecord otservauons. "I enlain-paration of the hardware prot > ad to him that I had no intenuon soms that are being encountered; of respecting any gag order,
a& 21m mer," he aald., , .j , , .- Jones said. -
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EXHIBIT S Cincinnati Aliiance'for Responsible Energy
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2699 Clifton Ave i
Cincinnati, Ohio 45220
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l (513) 861-3533 Milan & Marjorie Busching De com' 19, 1981 1032 Valley Lane
_ Cine'innati, Ohio 45229 Cincinnati Cas & Electric Company Chairman John Yeager 4th & Main Street Cincinnatii Ohio 45202
Dear Mr. Chairman,
Ne are chareholders of CC&E and are concerned about the recent .
NRC findinCs at the Zimmer nuclear station, and particularlyinthe role CC&E management played that led to the $200,000 fine, addition to the 100s Quality Confirmation program. CARE, Inc.,
are the ownero of 1 (one) share of CG&E common stock, and are filing the attached resolution with IJrc. Narjorie No willBusching produce who is the own-verification er of 200 charen of common stock.
of our ownership at your request.
We hereby notify you of our intention to present the attached proposal for connideration and cetionit byfor theinclusion stockholders at the in the next proxy annual meeting, and 've hereby cubmitiba-B or the rencral Rules and Rec-statement in accordance eith Rule as amended.
ulations of the Security and Exchange Act of 1934, If you should, for any rencon, desire to oppose the adoption of this proponal by the stockholders, please include in the corpora-tion's proxy material the attached statement of security the holders aforesaid cubmitted in support of the propoaal as required by rules and regulationc.
Sincerely, trM Tom Carpenter f
Cincinnati Alliance for Responsible Enercy Marjor,ieBuschingt Securities & Exchange Commission b 2 yo+< - Mu '" '
CC: d 500 N. Capitol 3treet ' --
.lachin.c ten D.C . 205h9
.; s. u . .mc..m.. a_hiw1 ~~'_. O c a m i a l m i i ~ _ ]
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m--i-Cincinnati Alliance for Responsible Energy 2699 Clifton Avenue Cincinnati, Ohio 45220 December 19, 1981 Milan & U.arjorie Busching 1032 Valley Lane Cincinnati, Ohio 45229 SHAREHOLDER RE3OLUTION iHEREA3:
-A November, 1981 Nuclear Regulatory Commission report on Zimmer ' ound improper voidi,ng and alterations of quality nsuurance non-compliance reports on a widespread basis;
-" he investiFation uncovered harassment of quality control innpect ors and dicnitsal threats for checking components too tho-rouchly, includinr examples of doucing inspectors with water;
-Congrecc recently added criminal liability t o the Atomic Energy ict for "precicely the sort of actions that occured at the Zimmer site";
-Governacnt investicators have not yet determined criminal liebility of relevant management officials : or the above misconduct.
.'HEREA S : .
-A Februnry 1981 Nac survey found more legal non-compliances at Zimmer than any other Region III plant under construction;
.\ L. arch 1961 letter f rom the Co:enission to the utility warned that " additional (quality assurance) violationc...which demonstrate ineffective management...will likely lead to escalated enf orcement";
,A hovember 1981 Commission report cited forty new itema of lcral non-compliances at Zimmer, almoat double the number un-covered in the pact two years. Simultancously, the Commission Regional Director called Zimmer's quality assurance program "to-tally out of control". he equally blamed the utility and construct-ion 'irm. ~he Commssion proposed a 3200,000 fine, the larrest ?or a plant under construction;
- hc HRC invectigation led to a quality confirmation program that "by itself, rithout factoring in any re-work...will be both costly and time consuming";
-The h'RC Chairman recently called Zimmer one of the five plants under conctruction nationally with " major problems".
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'IEEREi' ORE BE IT RE30LVED THAT S HE SHAREHOLDERS REQUEST TliE BOARD 0;- DIRECTORS:
Authorize a reviev, panel of distinruished members of the commun-ity, wholly independent and free from conflicts of interest with the utility, to investicate utility manarement responsibility for the above issues; and request Cincinnati's City !/.anarer to select the members vith the advice and concent of the City Council after public input and comment.
Respectfully' Submitted, Som Carpenter / Chairman Cincinnati Allihnce ; or Responsible Energy Karjorie Eusching CC: Securitic. c Exchange Commission 500 I:. Capitol Street fashington D.C. 20549
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SUPPOR?IllG STATEMENT The courts and the Securities & Exchange Commiccion have recornized that micmanagement, civil and criminal illegalities nre of material concern to shareholders. In light of recent developments, the scope, cauces and corrective action relevant.
to these revelations haven't been adequately dicolosed in reporta to the S.E.C.
Ihe 1cEl rovernment findinds at Zimmer have ceriouc public ,
health nnd cafety implicationc. A Congreccional committee ob-served, "the public health can be endanccred by nuclear crimes juct no curely an it can by street crimen". Thece findingc have lo :cred CCcE'c ctandinc in the community, evidenced by a recent vote of Cincinnati's Environmental Isdvicory Council to recommend suspencion c: Zimmer's conutruction permit and an independent quality accurance revieec.
'hc developten t could threaten the shareholders ' interest. The nececni ty for coctly repairs and delay means major unanticipated expencer, and prevento prudent invectment decisions.
.he utility .' ailed to diccloce long-term investment rick that resultc from chort-term coct cutting. CG&2 is charced viith a 100,: reincpection of safety components at Zimmer. T here are un-resolved concernu that managemcnt officials responsible '.or con-ceious cafety violations may be manipulating the re-tectinc profram.
Unless those respencible for previouc abuces are identified and removed from Quality Confirmation, it veill lack credibility.
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MISL1Hii3luriMCybilERS
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RELEASE DATE: NOV. 25, 1981
- FOR FURT!!ER INFORMATION PLEASE CONTACT: THOMAS DEVINE:(513) 352-2100 Room 953 leave message until 6 pm 9/25/81 FOR IMMEDIATE RELEASE OR LOUIS CLARK: (202) 966-0084 6 pm Wed. to 6 pm Sun.9/29/8 CINCINNATI -- Today the Nuclear Regulatory Commission (NRC)
. released a four inch thick report proposing a $200,000.00 finc against Cincinnati Gas & Electric (CG&E) , owners of the Zimmer Power plant under contruction outside Cincinatti, Ohio. The fine would be the largest in NRC's history against a nuclear plant under construction.
' At a press briefing, NRC Midwest Regional Director, James Keppler, explained the action: "In terms of quality assuranco I think Zimmer was totally out of control."
The report represents the first phase of the NRC's reinvestigation of Zimmer. The NRC reopened its probe after privato detectite Thomas Applegate, a former undercover agent for the utility, blew the whistle on a previous NRC investigation. He charged it was a whitewash. He went to the Government Accountability Project (GAD) of the Institute for Policy Studies (IPS), a non-partisan, public interest whistleblower support organization. GAP convinced the federal government's Office of the Special Counsel to order the NRC to reopen the case.
Last week the Commission admitted the first inves-tigation was inadequate. After today's now report was released Applegate observed, "My credibility has been reestablished. After nearly two years of frustration,' the NRC has confirmed my complaints.
This report is a good stop forward. But we have to keep walking."
GAP Legal Director Thomas Devinc commented, "The r- , case of this report is a tremendous victory for us. It proves that one determined citizen can force the federal burcacuracy to overhaul the way it oversecs public safety concerns. Unfortunately, the NRC admitted that it still cannot answer the ultimato question, will this plant be safe?"
Koppler noted that the reinvestigation is only half complete.
The report found that CG&E had violated the law in three major areas of its quality assurance program:
- 1) Falso records -- including blueprints that did not match the reality of equipment installation and voiding of internal nonconformance reports that revealed safety defects.
1901 Qoc Stnrt, N.W., Washington, D.C. 20009 202 23 HGS 2 (MO!!E)
NCWS RULUASC 11/25/81 PAGE 2
- 2) Harrassment and _ intimidation of internal quality control inspectors, including threats of dismissal and bodily harm, and
- 3) Numerous examples of failure to implement an adequate quality assuranco program, such as improper X-ray techniques for welds.
More specifically, preliminary findings from the investigation concluded that the pipes were not thick enough; a ratio of 1 of 9 randomly selected wolds were the wrong size; 10 examples of welds that woro improperly installed,: and nearly half of internal non-conformance reports were improperly voided. Devino noted the significance of the last finding. "There are approximately 800 relevant nonconformance reports at Zimmer. If the NRC ratio holds up, there may have been 350-400 cases where the utility altered the records after learning of legal violations. That approach represents an intolerabic gamble with public safety in order to cut corners on nuclear costs."
The report also confirmed allegations by GAP of inadequate X-rays for prefab pipes, inadequate inspection of cable tray welds, failure to verify-weight loads for cable trays, suspect pipes fer thermal loads, and f ailure to impleme rt redesign corrections.
Keppler conceded that he is still worried about the safety of Zimmer and that the problems at the plant are not an aberration.
He observed that, "Uc probably could find this anywhere."
Besides the S200,000.00 fine, the NRC pledged to continue an intensive series of independant hardware tests that have just begun. GAP has submitted a list of 28 areas of the plant that should be covered by the tests. The NRC also is requiring CG&E itself to rotest 100% of the components in the plant in a Quality Confirmation Program that the Commission has characterized as both
" expensive and timeconsuming even without any rework." the nature of the now CG&E tests have not yet been finalized. Ecppler emphasized that the utility will not be permitted to load fuel at the plant until the confirmation program and repairs are complete, in mid 1982 at the earliest.
Devino explained the significance of the report for the nuclear power industry and the public. ""For the industry, it is a warning that investor's must accept reality and the costs of constructing a nuclear plant. Por example, in this case, CG&E has been forced to increase the number of quality control inspectors from six to 160. The industry might as well stop chasing the rainbow of a (rfoRE)
NEWS RELCASU 11/24/01 PAGE 3 nuclear gravy train under the Reagan administration . While re .
tape, procedural delays and legal fees may decli t
oversight will intensify. ne, safety for a thorough quality control program with and delays of sending the resultiT ng cxpense 4
- the job -is donc right and the plant is safeparts back or doing w .
to spend the money initially, their investors arIf utilitics fail
$200,000.00 e liable to face fines and the financial nightmare that CG&E now faces.
"For the citizens of Cincinnati, simply do not know how dangerogs the plant is.the significance is t on the NRC's new reform program. And we cannot count on the good faith and honesty of CG&E,While extensivo, it still.rclics
'You can point the finger at Keiser. but as Mr. Keppler admitted, just as strongly.' I point the finger at CG&E reason, CG&E violated the public trust.The core of the everNRC f a wolf for a fox as guardian of the henhouseWe may just be switching .
What is needed is an independent federally licensed quality assurance pro gram,-whose I
contractors the NRC. " report directly to the NRC and can only be e fir y db I
Deputy Regional Director Berta Davis stated .
, NRC th t ifIn CG&E's records and licence inspection is are inaccurate again, suspending the constucti on
" totally appropriate."
Devine concluded, "For the general public, the significance is that Zimmer does not represent an isol t d ae exception. No one knows how many other Zimmer's are lying dormant as potential disasters fo, rwa rd . "
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EXIIIBIT V INTRODUCTORY STATEMENT For the BRIEFING OF 'fIIE NRC COMMISSIO!IERS By TIIOIIAS DININE Legal Director of the Government Accountability Project of the Institute for Policy Studies Accompanied by DAVID JONES and RICIIARD REITER Concerning the ZIMMER NUCLEAR POWER STATION June 16, 1982
Thank you for inviting our participation in this briefing.
My name is Thomas Devine. I am the Legal Director of the Government Accountability Project (" GAP") of the Institute for Policy Studies
("IPS ") . I am appearing on behalf of the Miami Valley Power Project
("MVPP"), the intervenor that recently moved to reopen licensing hearings at the Zimmer nuclear power station. I will be presenting today's prepared statement.
bessrs. David Jones and Richard Reiter have accompanied me to help respond to your questions about specific conditions in the plant.
Mr. Reiter worked at Zimmer as a Document Reviewer. Through frus-trating experience, he became an expert on design control and traceability deficiencies. Mr. Jones current]y works at Zimmer as a Documents Reviewer for the contractor, Kaiser Fngineering, Inc.
Contrary to recent public statements by Cincinnati Gas and Electric
( " CG &E ") Vice President Earl Borgmann, however, that was not always the case. Until May Mr. Jones was a Senior Quality Assurance ("QA")
Analyst, one of three advisors to the QA Manager at the top of the Kaiser organizational chart. Mr. Jones has worked as an auditor, a quality assurance engineer, a quality control manager and an assis-tant quality assurance manager. He was the man Kaiser assigned last spring to analyze whether the NRC was correct that nonconformance reports ("NR") were voided improperly. (When he agreed with the NRC, he was removed from the project.) He is particularly qualified to answer your questions on the causes and extent of the QA breakdown at Zimmer.
4 MVPP appreciates the recent staff recommendation to reopen the licensing hearings. But we agree that licensing proceedings should not delay ongoing investigations and repairs at the site.
We believe that the innues raised in the eight new proposed contentions aro too significant to wait solely for eventual resolution by the Atomic Safety and Licensing Board ( "ASLB ") . In our opinion, the issues require immediate enforcement action as well.
As a result, MVPP is preparing a petition to the Commission to-- *
- 1) suspend the construction permit at Zimmer;
- 2) replace the current Quality Confirnation Program with a comprehensive third-party reinspection program, with full authority to identify and impose corrective action on any nonconforming conditions; and
We will present affidavits and documentary evidence to support the petition. Today I would like to discuss three reasons why the current Quality Confirmation Program ( "QCP'i ) must be replaced with an alternative enforcement policy.
I. INIIERENT STRUCTURAL FLAWS IN THE QUALITY CONFfISIAT10N PROGRAM Last November NRC's Region III Administrator James Keppler concluded that the Quality Assurance Program at Zimmer was " to tally out of control. " In an April 8, 1981 Immediate Action Letter, Region III had already imposed the CG&E-administered Quality Confirmation Program as the solution to the QA breakdown. Unfortunately, the
.- e structure of this program is inherently flawed.
To summarize, the Quality Confirmation Program--
- 1) is not comprehensive. It only covers issues identified by the HRC in last November's report.
Issues missed or postponed by the NRC will be missed by the OCP.
- 2) does not address the causes of the QA breakdown.
At best the OCP deals with specific effects.
The new QCP staff is little better than a massive team of research assistants. They do not have the organizational freedom to enforce their decisions.
- 4) does not identify the standards and criteria used to evaluate the reports presented by the OCP staff. What's good enough for CGLE may be questionable to other authorities. For example, an Junerican Society of Mechanical Engineers ( " AS ME " )
team recently rejected a QCP appeal to relax ASME codes on control of radiograph quality. Similarly, at last Thursday's congressional hearing Mr. Keppler rejected CGsE's assessment that structural steel welding deficiencies were insignificant and cos-me tic . It is not surprising that by far the most common disposition for nonconforming conditions identified by the OCP has been " accept-as-is."
- 5) is still basically a paperwork review. OCP field inspectors are limited to items where the paper-work is not satisfactory. Unfortunat.cly the paperwork at Zimmer is a questionable foundation to screen out inspections. $50,000 of last Nov-ember's fine was for falso records. As a result, QCP suffers from the same lack of credibility.
- 6) is too late. For many items, such as vendor com-ponents already assembled, the utility may lose the warranty if it breaks the seal to check the quality inside. Similarly, how can CG&E determine today that a vendor had a reliable QA program when a part was purchased 8 years ago? According to internal Kaiser findings, this flaw alone involves some 42,000 purchases. How can the utility estab-
, lish traceability for beams purchased from a i
I
.- junkyard that buys and sells scrap metal; or for pipes that were cat up years ago and scattered throughout the plant without keeping track of the heat nu:abers? How can valves damaged out of the plant by overstress during inadequately con-trolled hydrostatic tests be repaired now, without a massive repurchase program? How can irreplace-able records -- such as voided NR's and proof of velder qualifications -- be replaced when the documents are irretrievably lost?
- 7) relics on decisioumakers who have a built-in conflict of interest. Every repair that CC&E approves further delays opening, increases costs, and documents the effects of deficient leadership at the site. This spring the Securities and Ex-change Commission approved, over CGLE's objections, a shareholder resolution by the Cincinnati Alliance for Responsible Energy (" CARE") to investigate alleged mismanagement that led to last November's fine. Nearly 5% of CGEE stockholders supported the resolution. It is naive, to say the Icast, to c::pect a manager to admit the full consequences of his or her own nismanagement.
II. EMPIRICIsL DETERIORATION SINCE APRIL 1981 OF THE OUALITY ASSURANCE PROGRAM There has been nearly a year to assess the work of the Quality Confirmation Program. If it had worked effectively, the structural flaws outlined above would be academic. That is not the case.
Despite the pious rhetoric, the explanation is a lack of management commitment to the GCP. Last week Mr. Jones testified that the new site construction manager publicly announced his objec-tive to return to the " pre-April 1981 mode" when Kaiser and CG&E had everything going f or them and were building one of the cheapest nuclear plants in the country. The results were predictable.
Mr. Jones suffered the bulk of his harassment after April 1981, when he challenged inadequate quality verificat2on for work on
.- items purchased from vendors ("FDI's" and "PDDR's"); CG&E's inability to meet the audit requirements necessary for inclusion on Kaiser's own Approved Vendors List; inadequate material traceability and identification; structural compromises to the Vendor Surveys / Audit and Control Procedure; an inadequate degree of independence for KTiser auditors; inadequate design controls to keep track of revisions; and serious flaus in the quality of work by the current company performing Nondestructive Examinations such as radiographs on-site.
If anything illustrates the continued deterioration of quality assurance at Zimmer, it is a new procedure introduced on June 2.
The procedure, ZAPO-5, guts the entire nonconformance reporting system and replaces NR's with something called In-Proccus Inspection Deficiency Records ("IIDR"). As Kaiser announced frankly in a May 28, 1982 construction bulletin, "The major thrust of this effort
[ development of the IIDR system] has been to provide alternative means of documenting and resolving deficiencies without using the NR process." The QCP was producing up to 50 NR's per week.
ZAPO-5 is an attempt to stifle that trend.
As ZAPO-5 explains in Sl.2, Nonconformance Reports ("NR's")
will only be written for deficiencies--
found af ter final inspection or that cannot be corrected through the In-Process Inspection Defi-ciency Record. In-Process Inspection Deficiency Records shall be written to document the correction of deficiencies identified during the HJK inspection process, up to and including final inspection.
The parallel QA procedure to ZAPO-5, QAP 16, Rev. 8, which was recently reviewed by the ASME survey team, does not mention IIDR's. The reason is simple: while IIDR's provide an alternative-to NR's, they sacrifice accountability. There is no provision on the IIDR form to verify corrective action. -
Similarly, IIDR's are prohibited from providing procedural instructions, which grants unlimited discretion for the nature of corrective action. IIDR's structurally climinate the concept of QA independence from construction. The authorized engineer, who may be responsible for the deficiency, is given authority to overrule the inspector's decision to rework a deficiency. Only limited appeal is available. In the end, final review of IIDR disposition is con-trolled almost exclusively by the Manager of Quali~ty Engineering, an individual who has been the focus of numerous allegations re-coived by GAP.
While ZAPO-5 permits NR's , it subjects them to such a bureaucra-tic gauntlet that only the most stubborn inspector would still attempt t issuo UR's under those circumstances. For instance, all NR's are
" drafts" until approved by Quality Engineering. They are then sub-ject to four levels of review by an assortment of personnel, including any "other individuals... determined by the cognizant supervisor."
If it survives those cuts, the NR only then goes to the Material Review Board. If there is a dispute over disposition, during the interim ZAPO-5 permits work to continue unless suspended by the QA Manager. And there are no time limits to resolve disputes. In short, under ZAPO-5, NR's are reduced to an exercise in futility.
This procedure represents a fundamental change in the nature of internal quality control. From this point on, the premises of QA at Zimmer requires trust in the good faith of the construction depart-ment. This OA revolution defies all the findings of last November's NRC Report on Zimmer. If the Commission accepts this neu approach at Zimmer as part of CG&E's " reform," it will signa.1 the rest of the nuclear industry tha t NR's and structural independence are no
.- longer mandatory for quality assurance programs.
As QA procedures at Zimmer have deteriorated, retaliation has
. increased. In a February 26, 1982 response to the proposed NRC fine, CGLE took credit for "a prompt and vigorous response. . . . " CG&E asserted that "the dousings subsequently ceased. " Unfortunately, the facts belied their confidence. Just three weeks ago more QC inspectors reported dousings with " dirty water." Contrary to the utility's assurances, in a June 2, 1982 Cincinnati Post news article NRC senior inspector Dorwin Hunter stated: "I'll just say it's the same type of thing going on for awhile."
Empirically, the situation at Zimmer has gotten worse rather than batter over the last year. This trend, combined with the structural flaws discussed above, renders the Quality confirmation Program a fatally-flawed regulatory policy.
III. CHARACTER AND COMPETENCE While " character and competence" is a licensing issue for the ASLB, in this forum it addresses the question of credibility.
In recent weeks, CG&E's credibility has been as weak as its Quality Confirmation Program.
The statements of Senior Vice President Earl Borgmann at last Thursday's congressional hearing are illustrative. He testified, In my opinion, the basic Quality Assurance policy for construction was Kaiser's and CGEE nad the obli-gation to assure itself that that QA Program was adequate. On various occasions, our QA manager had differences of opinion with Kaiser but certainly did not a ttempt to direct or shortcut the overall program.
In retrospect, as I indicated this morning, obviously we should have had more deeper involvement. We should have completely controlled the program. But to say
that the program was not carried out because we deliberately told Kaiser to shortcut it or to not carry it out is f alse.
That statement was directly inaccurate. It is so drastically wrong that it is hard to believe Mr. Borgmann testified in good faith when he responded to the congressional inquiry. GAP has evidence of at least 29 examples between 1971 and 1977 where CGLE directly participated in establishing QA policies. In many instances, the utility imposed QA staffing or inspection compromises over Kaiser objections.
Nor is the CGLE domination merely an historical phenomenon.
Last November's NRC report documented more than a dozen additional instances of CG&E knowledge or complicity in " Kaiser" policies investigated by Region III. A 1981 General Electric audit revealed that Kaiser had discontinued audits of work on GE purchases at CGLE's direction.
Mr. Borgmann's inaccuracy concerns a decisive premise for the reform imposed by Region III last April. The Quality Confirmation Program only makes sense if CG&E was truly unaware of the Kaiser policies. It is significant on another level, however. If CGLE officials do not testify in good faith to the Congress, there is little reason to think the utility's QCP reports to the NRC are any more reliable.
The inaccuracy was so blatant as to be insulting. Last Saturday the Cincinnati Enguirer published a March 8, 1976 letter from Mr. Borgmann to Kaiser's W. Friedrich, denying the funds for additional QA staff. The letter was published, because it directly.
contradicted Mr. Borgmann's testimony. The letter was already on
.- -9_
the public record as part of Exhibit 9 to MVPP's Motion for Leave to Pile New Contentions. When GAP submitted the Motion in May, CG&E's response was that it contained "nothing new."
Mr. Koppler's June 7 announcement that the Justice Department has reopened the criminal investigation at Zimmer should resolve any remaining doubts. When the probe was suspended last summer, NRC's Of fice of Inspector arid Auditor ( "OI A") was questioning CG&E management about criminal violations of the Atomic Energy Act.
Unless the U. S. Attorney chooses not to pursue those leads, we are now faced with a curious scenario: The same organization under active criminal investigation is charged with implementing a reform program that may have been triggered by its own deliberate misconduct.
That policy does not make sense. If a public official were under active criminal investigation, he or she often would go on leave with or without pay. In public trust in the management of a nuclear power plant any less necessary than for a government official?
l'u r th er , the NRC has not issued a comprehensive ban on destruction of records during the Quality Confirmation Program.
Although there is a " documents Certification" program, in reality GAP has receive'd rcpeated allegations of documents destruction at the site. In essence, CG&E has absolute control over the evidence that could be used to make a case against itself, criminal or otherwise. To illustrate the consequences, last year the GE auditors were only abic to obtain eight of 22 work packages requested from CG&E, and no documents requested on electrical work.
.- fir . Applegate has described Zimmer as a " crime scene" that must be secured. Last tiovember OIA concluded that !!r. Applegate was right in his critical assessment of the original NRC investi-gation of his charges. The Commission should carefully consider his advice on this issue as well.
CONCLUSION
- All parties agree that public confidence must be restored in the safety of the Zimmer plant. A reform program administered by CCLE cannot achieve that goal. Optimistic utility progress re-ports no longer are taken seriously. Under these circomstances, the Quality Confirmation Program is unfair to the utility. No matter how thorough CG&C's effort, the cloud of public distrust will remain.
Iwgion III has suggested the possible use of consultants to evaluate the OCP. The suggestion confirms the lack of credibility for the current program. But the solution is not to add another layer of bureaucratic oversight. The only viable solution is to substitute a legitimate structure for an illegitimate program. In this case, at a minimum legitimacy means placing responsibility for comprehensive reinspection and corrective action of all safety-related work with an independent organization free from conflicts of interest. i.ie public will no longer accept a program that relies on the fox to assess the strength of the henhouse.
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NUCLEAR REGULATORY. COMMISSION- . 's .
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- Judge Stanley'M. Livingston Dr.' Frank F.(Hooper s ' '~
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In the Matter of '
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g CINCINNATI' GAS"&-ELECTRIC' COMPANY, ET AL.=
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, Do cke t No . 50-'35 8 s
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(William H..ZimmerLNuclear ) APPLICATION FOR. ,
Power Station)- '
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' OPERATING LICENSE N s) s , s -
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CERTIFICATE OF; SERVICE ~
N I hereby certify that copies of the foregoing Intervenor's '
Reply to NRC and Applicants' Answer to Intervenor's Motion ~for Leavo to Pile 'New Contentions and Motion for Protective Order have been served on the following persons.by mailing copies, first class, ~
postage prepaid, this [M , day of July, 1982 to the following:
- Mr. John Frye III Mr. Troy B.
s Conner, Esquire Atomic Safety and Licensing Conner, Moore & Corber Board Panel U.S. Nuclear Regulatory Commission .1747 Washington, Pennsylvania Avenue, N.U.
Washington, D. C. 20555 -
D. : C. 20006 Dr. Frank F. Ilooper . John.D. Woliver,lEsq.
School of Natural Resources P. O. ' Box 47 University of Michigan '
550 Kilgore Street Ann Arbor, Michigan 48109 Batavia, Ohio 45103
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8 s. ~
William J. Moran, Esq.~ *Chairmhni
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General Counsel Q% ~
Cincinnati Gas ~& Electric Company Atomic'SaYety and Licensing P. O.. Box 960 ' '
Appeal Board U. S. Nuclear Regulatory Commission Cincinnati, Ohio 45201 '~ _ Washington,,D. C.
.s 10555
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i W. Peter Heile, Esq. Mary Reder-
,1 Assistant City Solicitor Box 270, Route 2 i Room 214, City Hall. . California,. Kentucky 41007 Cincinnati, Ohio 45220-David K. Martin, Esq. ,
- Stuart A..Treby, Esq. Assistant Attorney General I U. S. Nuclear Regulatory Commission ' Division of Environmental Law i Room MNBB 9604 Attorney General for the j 7735 Old Georgetown Road Commonwealth of Kentucky :
Bethesda, Maryland 20014 209 St. Clair-Street i Frankfort, Kentucky 40601 i
- Chase-Stephens 4
Docketing and Service Section, Andrew B. Dennison
' Office of the Secretary 200 Main Street qs U.S. Nuclear Regulatory Commission Batavia,-Ohio 45103 Washington, D. C. l 20555 '
George Pattison
- Richard S. Salzman, Esq. Prosecuting Attorney Chairman Clermont County Atomic Safety and Licensing 154 Main Street Appeal Board Batavia, Ohio 45103' l
U.S. Nuclear Regulatory Commission ,
, Washington, D. C. 20555 '
- Lawrence Quarles Atomic Safety and Licensing 4
Appeal Board U.S. Nuclear Regulatory Commission j Washington,.D. C. 20555 i
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- Michael C. Farrar, Esq.
' Atomic Safety & Licensing Appeal Board-U. S. Nuclear Regulatory Commission *!
l Washington, D. C. 20555 l 4
Administrative Judge M. Stanley Livingston 1005 Calle Largo )
j Santa Fe, New Mexico 87501
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/( d u c (~ h ~ K ' l LYNNE'BERNABEI Goverpment Accountability Project 1901 Q Street, N. W. -j W3shington, D. C. 20009 1 2D5/234-9382
- Served through internal NRC mail system.
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