ML20054M222
| ML20054M222 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/09/1982 |
| From: | Devine T GOVERNMENT ACCOUNTABILITY PROJECT, MIAMI VALLEY POWER PROJECT |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8207120116 | |
| Download: ML20054M222 (80) | |
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. o GOVERNMENT ACCOUNTABILITY PROJECT .- ,, ..,
Institute for Policy Studies
< r 1901 Que Street. N.W., Washington. D.C. 20009 (202)234-9382 l July 9, 1982 J/ ~
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& S The Honorable Nunzio J. Palladino Chairman kf
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U. S. Nuclear Regulatory Commission
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Dear Chairman Palladino:
se n, ,m At the June 16, 1982 briefing on the William H. Zimmer nuclear ; power station, you requested additional explanation of "what you n I get on an NR that you don't get on an IIDR." Please excuse the delay in presenting this explanation, which compares In-Process Inspection Deficiency Records ( "IIDR" ) with Nonconformance Reports ( "NR") . * , One reason for the delay was my concerns over possible material false statements by Cincinnati Gas and Electric ("CG&E") officials , who responded to questions posed by the Commission at the brief- l ing. A search of our files revealed serious inaccuracies in the responses of Messrs. Sylvia and Borgmann. As a result, the Miami Valley Power Project ("MVPP") requests an investigation by the ! Commission's Office of Investigations into possible material false statements which will be identified below. I. QUALITY DOCUMENTATION CONTAINED IN NR' S AND MISSING FROM IIDR' S 4 I 50, j IIDR's sacrifice numerous basic principles of 10 C.F.R. ; Appendix B, and the professional codes. The deletions permeate the entire system from identification through disposition: t
- 1) A Nonconformance Report identifies the cause of the l '
problem. (See Henry J. Kaiser Co. Quality Assurance Manual, Quality Assurance Procedure No. 16, Rev. 8, Figure 16-1 (March 24, 1982); attached as Exhibit 1. ) An IIDR does not. (Zimmer a
*IIDR's will be references to Zimmer Procedures Manual ZAPO-5, which was the subject of extensive debate at the June 16 briefing.
Since ZAPO-5 also rewrote and gutted the NR system (see June 16, 1982 prepared statement of Thonas Devine, at 6) unless otherwise noted, NR's will be references to ZAPO-5's predecessor, Quality Assurance -- Construction Methods Instruction ( " QACMI" ) G-4, R.15.
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The Honorable Nunzio J. Palladino July 9, 1982 Page Two Procedures Manual, Procedure No. ZAPO-5, Rev. 1, Exhibit B (June 2, 1982); attached as Exhibit 2.) This omission violates 10 C.F.R. 50, Appendix B, which requires that for significant conditions "the measures shall assure that the cause of the condition is determined. . . ."
- 2) NR's fully identify the nature of problems. IIDR's, on the other hand, barely provide for abstract reference to the deficiency.
To illustrate, the NR control log includes "[d]escription" of the problem. (Id., Exhibit C. ) The IIDR log, on the other hand, merely references to " number of the work package or the punchlist ticket that the IIDR applies to...." For any nonconforming condition, the NR form itself provides the location, name of the item, contract or purchase order number, supplier / contractor, inspection plan, speci-fication number, and status under ASME. (Exhibit 1, Figure 16-1.) An IIDR, on the other hand, does not provide for any of that infor-mation. The only common identification category between the two forms is problem "[d]escription," for which an NR has approximately twice as much space as an IIDR.*
- 3) A Nonconformance Report cannot be closed out through a Design Document Change ("DDC"). A DDC merely revises design require-ments to permit the condition. (Exhibit 2, S4.2.3 note.) The IIDR form, on the other hand, permits DDC's to " correct" the problem.
,( Icl . , S 3.2.1.) This loophole ignores previous NRC noncompliances on this practice that led in part to the April 8, 1981 Immediate Action Letter ("IAL") at Zimmer. (See, e.g., NRC IE Reports No.
50-358/80-05 and 50-358/80-25.) In other words, CG&E has responded to the NRC citation by " legalizing" the illegality.
- 4) An NR has instructions and a written justification for how to correct the problem. (Exhibit 1, Figure 16-1.) By contrast, ZAPO-5 states unequivocally: "IIDR's shall not be used to provide procedural instructions." This gag order on QC guidance for repair procedures obliterates a key premise of professional quality assurance
("QA") codes. As ANSI S16 states, "[N]onconforming items...shall be accepted, rejected, repaired or reworked in accordance with documented procedures."
*While an IIDR does not grohibit additional identifying infor-mation, that is not a significant reassurance. A blank sheet of paper does not prohibit anything, either. But neither a blank sheet nor an IIDR guarantees that when a QC inspector finds a problem it will be fully identified. In practice at Zimmer, the identifi-cation on IIDR's is as vague as the form permits.
s
The Honorable Nunzio J. Palladino July 9, 1982 Page Three
- 5) A Nonconformance Report goes to the Material Review Board if the disposition is " repair," " accept-as-is," " rework" or
" reject." (Henry J. Kaiser Co. Quality Assurance -- Construction Methods Instruction ("QACMI") G-4, R.15, S 5.6.10 (October 7, 1981);
attached as Exhibit 3.) An IIDR can never go beyond the quality engineering manager. (Exhibit 2, SS 3.3.4 and 3.3.5.) This loop-hole eliminates institutional oversight and accountability.
- 6) All Kaiser NR's must be distributed to CG&E at some point.
(Exhibit 2, at 25.) There is no similar requirement for IIDR's. The loophole belies CG&E's commitment to maintain close oversight and control of QA until Zimmer is completed.
- 7) With an NR, a QC inspector can apply a " hold tag" to stop work on a nonconforming item that needs to be isolated. (Exhibit 3, S 5.6.7.1.) Under Z APO-S , however , the inspector must permit work to continue while disputes with construction are appealed. (Exhibit 2, S 4.1.10.) This change leaves it up to construction personnel's discretion whether to comply with 10 C.F.R. 50, Appendix B, Criterion XV, which requires appropriate segregation of nonconforming items.
Further, it means that the QC position may be moot by the time any dispute is resolved. Traditionally, failure of construction per-sonnel to respect hold tags has been one of the most common QA abuses at Zimmer. Under ZAPO-5, construction no longer has to worry about hold points.
- 8) An NR dispositioned " accept-as-is" must be supported by a Registered Professional Engineer if stems analysis is required by ASME. (Exhibit 2, S 3.7.1.) There is no similar requirement for an IIDR.
- 9) An NR dealing with specified ASME items can only be cancelled with the approval of the Authorized Nuclear Inspector. (pl., S 3.8.1.)
There is no similar requirement for an IIDR.
- 10) NR's are sent to the NRC for review. (Id., Exhibit E.)
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IIDR's are not. (Id., Exhibit F.) Region III's apparent tacit acceptance of IIDRrs belies its repeated public commitments to strictly monitor ongoing work at Zimmer. Rather, IIDR's institu-tionalize Region III abdication of oversight for repair of noncon-forming c6nditions at Zimmer. In a May 21, 1982 CG&E audit, Science Applications, Inc., gave a clear example of the comparative inferiority of IIDR's to NR's for QA documentation of weld repairs: IIDR's do not provide direct traceability of welder, weld procedure and revision, weld filler material type, size and heat / lot numbers; do not verify inspection for defect removal; and do not identify acceptance inspec-tion procedure and revision used.
The Honorable Nunzio J. Palladino July 9, 1982 Page Four The audit's " recommended corrective action" flatly rejected IIDR's as acceptable QA documentation: HJK should discontinue the use of IIDR's for weld repairs and should identify all welds for which IIDR's have been used to document weld repairs. On balance, the audit rated Kaiser's IIDR QA Program Procedures as
" unsatisfactory":
HJK procedural requirements and program controls for usage, documentation, and disposition of IIDR's is [ sic] not adequate. (Relevant excerpts from Science Applications, Inc. " Semi-Annual Management Audit Report of Cincinnati Gas & Electric Company, William H. Zimmer Nuclear Power Station (Audit Report No, MA-82-1 May 21, 1982) are attached as Exhibit 4.) The controversy over IIDR's or their equivalents is not new. Even when QA was "out of control" before reform at Zimmer, Kaiser and CG&E could not agree on this issue -- either within or between their organizations. In a November 30, 1976 memorandum, Kaiser Construc-tion Executive E. V. Knox reported that CG&E's William Schwiers
" expressed his opinion on organization that inspection personnel should report to Construction Engineering for control and Quality Engineers-should audit and surveil for assurance that things are done properly. " This is precisely the subordinate QC role adopted by ZAPO-5 with IIDR's.
l In the same memorandum, Mr. Knox reported his response: "I disagree l with this type of organization and so does 10 C.F.R. 50, Appendix B." t (The November 30, 1976 memorandum from E. V. Knox to D. H. Williams
- is attached as Exhibit 5.) Surely the NRC would not approve a l practice flatly rejected by Kaiser construction management during the " pre-reform" period at Zimmer.
l Apparently Mr. Schwiers was convinced, because he reversed his l opinion. In a March 11, 1981 written exchange with Kaiser QA l Manager Phillip Gittings, Schwiers' QA liaison Robert Ehas stated l unequivocally, "In process deficiencies or outright deficiencies must go on the NR Forms. Surveillance Report Forms should be discontinued." Gittings rejected the suggestion: "I disagree with you regarding in-process deficiencies. Outright deficiencies cer-l tainly should be on an NR. I have no intention of discontinuing l S/R's...." (The March 11, 1981 exchange is attached as Exhibit 6.) Today one of the Quality Confirmation Program tasks is to review Surveillance Reports for nonconformances that should have gone on
The Honorable Nunzio J. Palladino July 9, 1982 Page Five NR's. Ironically, the same improper shortcut simultaneously has been reborn through the IIDR. The IIDR system appears to be deteriorating even further. For instance, the original version of ZAPO-5 did not permit IIDR's to be used when DDC's were required. Due to several violations, the SAI audit rated Kaiser unsatisfactory on this restriction. (Exhibit 4, supra.) Rather than stopping the abuse, ZAPO-5, Rev. 1 legalized it by permitting DDC's to respond to IIDR's. (Supra, at 2.) The above example is revealing: it recreates a oractice condemned by CG&E in Mr. Ehas' March 11, 1981 " pre-reform" position: Do not change a procedure just because people do not follow the procedure. Fred Mauri has examples where procedures are changed because something was not being done. Very bad. (Exhibit 6', supra.) Apparently CG&E's " post-reform" position has discarded this premise. At the June 16 briefing, CG&E contended that other nuclear construction sites use IIDR's, which were introduced to Zimmer by new management recruits. That position casts doubt on QA practices in the rest of the nuclear industry, as well as on the caliber of " post-reform" management recruiting. Even if IIDR's were acceptable at smoothly functioning sites, they should be out of the question for a program supposedly recovering from a total QA breakdown. At Zimmer more than anywhere else, QA documentation must be able to prove the quality of the work. IIDR's inherently cannot accomplish that goal. If the Commission accepts this device, the safety and quality of the plant will remain what it is today -- indeterminate. II. CG&E MATERIAL FALSE STATEMENTS AT THE JUNE 16, 1982 BRIEFING At the June 16 briefing CG&E Vice President of Nuclear Operations B. R. Sylvia gave detailed responses to questions on the IIDR system. CG&E Senior Vice President Earl Borgmann attempted to rebut charges that he had presented inaccurate testimony to Congress. Each gentlemen provided inaccurate responses to,the Commission. A. Mr. Sylvia Mr. Sylvia offered a number of specific distinctions for specific circumstances when IIDR's can and cannot be used. Curiously, none of these distinctions are included in ZAPO-5. As ZAPO-5, S 3.4.1 note explains:
r t The Honorable Nunzio J. Palladino July 9, 1982 Page Six 9 4 Deficiencies in construction work identified up to and including final inspection, which are doc-umented on an In-Process Inspection Deficiency i Record (IIDR) form according to approved proce-dures, or other deficiencies that are corrected in accordance with other applicable corrective action procedures, do not require identification ; on an NR. Mr. Sylvia's distinctions do not exist in practice, either, f For instance, he stated that IIDR's are only.used for new work I and are excluded from the Quality Confirmation Program with a specific exception in the drywell. Witnesses have told us, however, that IIDR's are the most common approach to record deficiencies in the Quality Confirmation Program. The wit- ; 1 nesses would like to pinpoint specific esamples with appropriate representatives of the Commissioners, after obtaining written confidentiality assurances. P Second, Mr. Sylvia asserted that IIDR's are only used for problems that do not require an engineering solution. The . assertion was inherently inaccurate, however, since IIDR's can [ i be dispositioned through DDC's. DDC's definitionally require , an engineering solution. Further, Mr. Sylvia should have ! already known that almost a month earlier the SAI audit dis- !' clo sed : "No approvals are required to accomplish weld repair ! by IIDR although QAE and Weld Engineer approvals are required r for use of KEI-Weld-1A forms." (Exhibit 4, supra.) ,
- Third, Mr. Sylvia asserted that IIDR's were not used until the
- QA Manual had been amended to reflect the practice. A look at
, the relevant dates is instructive. ZAPO-5, Revision 1 was ; issued on June 2, 1982. (Exhibit 2, supra.) At that time, the relevant QA Manual procedure, QAP 16, Rev. 7, did not mention the concept of IIDR's. The QA Manual was not changed to incorporate IIDR's until June 8,1982, af ter ZAPO-5 had i already gone through a revision. (QAP 16, Rev. 9 is enclosed i i as Exhibit 7. )
; Fourth, Mr. Sylvia claimed that IIDR's are a hold point type i of inspection. As explained earlier, however, QC no longer
- . has the authority to enforce the hold point. (Supra, at 3.) '
t Fif th, Mr. Sylvia claimed that IIDR's provide the same kind , of documentation as NR's to resolve discrepancies. A com-parison of the two forms, however, demonstrated that IIDR's ' only require a shadow of the documentation contained in an NR. (Supra, at 2-3.) I , . .a
. - - _ - - - . . , _ , _ . . . _ , . . - - , _ _-_--_.-_.-..-_.-,._m_ , - - _ _ . _ . _ _ _ _ , , . . . - -,.-- _ - _ ,.._,,7_ , , - , . . - . - . . - - . . - _ - - . - -
. a The Honorable Nunzio J. Palladino July 9, 1982 Page Seven Finally, Mr. Sylvia asserted that the same type of people resolve both IIDR's and NR's. That is categorically false.
NR's are processed by the Quality Assurance Department and can go to the Material Review Board. Disposition of IIDR's, on the other hand, is largely controlled by construction. The only contact with QA is a single appeal to the Quality Engineering Manager. IIDR's cannot go to the Material Review Board. (Supra, at 2-3.) In short, Mr. Sylvia's June 16 responses to questioning by the Commissioners was drastically inaccurate. It apppears that either he was not responding in good faith, or else did not understand the IIDR structure CG&E is theoretically monitoring. B. Mr. Borgmann At the June 16 briefing Mr. Borgmann attempted to explain that while CG&E may have overruled personnel requests, there was no attempt to direct the program or to tell Kaiser what to include in documentation. Unfortunately, that statement was not accu-rate. MVPP's July 8, 1982 Reply Brief, enclosed as Exhibit 8, noted eight examples of direct CG&E participation in Kaiser QA activities besides hiring staff. In some cases, CG&E directly instructed Kaiser what inspections to perform and what docu-mentation to include. All but one of the relevant documents to establish this point had been distributed to Mr. Borgmann when they were issued. Material false statements to the Commission on matters of public concern are serious of fenses. The inaccurate stctements of CG&E of ficials had the ef f ect of clouding, rather than clarifying, the issues. The Commission should direct its new Office of Investiga-tions to determine how and why CG&E mischaracterized its own reform program so severely. Sincerely, 3
< , i 3
! /
THOMAS DEVINE Legal Director TD/my
1
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EXHIBIT 1 l HENRV_/. KA/EER cu^Tv ^ssunAuce rsucesuRe no. 16 nEv. 8 P O. BOX 201, MOSCOW. OH30 45
- 53 EFFECTIVE DATE:
gqg pg i g 5 OUALITY ASSURANCE MANUAL
- PREPARED BY; _KK sn o" Uty Assurance f W.# h/2 Dm Pn 3 -
TiTt'E : CO!; TROL OF MONCONFORMING MATERIAL, APPROVED: mf , Cm h Dnector of 9 A'ssurance PARTS. COMDONENTS AND ACTIVITIES CONCURRED: Vice Presicent - Power Y !hf=" [N' [ [- - Date [/ 1.0 PURPOSE 1.1 To describe the procedure for controlling parts, materials, components, appurtenances, activities, recoros or procedures that are not in conformarce with specifications, drawings or purchase documents. 2.0 GENERAL RECUIREIENTS 2.1 Norconformarce Reports shall be initiated by personnel assicned to HJK . Quality Assurarce Department and processed in accordance with approved procedures. Any Cognizant HJK Personnel may identify a nonconforming condition and request the NR be initiated by the HJK QA Dept:tment. 2.2 Procedural violations that have no affect on, materials or ecuipment will be documented on a Ccrrective Action Request fQlQ. CAR's will. be written by Quality Assurance persennel ard approved $ydhe HJK Site QA Manager prior f to issue. Corrective action comiY.thi sHall be approved by the HJK Site QA Manacer. An irdex log showif.c\!MstatusofCAR'sshallbemaintained by the QA Administration rP 2.3 Nonconforming mated alga items shall be placed in a contrclied segregated area until the 'hombhfomance Report is appropriately dispos'_itioned. Where physical segregftion is impractical due to sire limitations or installed cordition, the material or items shall be pmminently identified with a Hold Tag, or Deficiercy Tag, to avoid inadvertent use or installation. 2.4 Corrective action en recurring discrepancies will be reviewed and analyzed by the HJK Quality Engineer responsible for the department i:n c.uestion. After such analysis is made, the Quality Engineer will report the findings to the HJK Quality Assurance Manager for initiation of a CAR if deemed necessary. 2.5 Records shall be retained on all narconforming items, irdicating ultimate disposition of the items. Norconformance Reports, which have been given Control Numbers ard subsequently cancelled, shall be maintai.ned as pemanent records and annotated with the reason for cancelling. HJK Site QA Manager, CGEE QA Manager, and the ANI for ASPE Secticn III, Div. I (parts, materials, components ard appurtenances) shall apprcve carcelled NR's. 2.6 Each Norconformance Report will be identified by NR Number and coded as to
.. Safety relatirn status. Esential or Safety Related Nonconformance Reports C'~ will be prefixed by an "E", and Ncnessential Nonconformance Reports will be prefixed by an "N". ASME will be marked on the NR where cpplicable.
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4 HENRY J. KAISER CO. Q.
A. PROCEDURE
No. 16 QE V. @ PAGE 2 oF 5 p L ,
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2.7 Non:enferming ASE parts, materials, co.:ponents ard app 07tenances, where , the recommended disposition is Accept-As-Is, Repair or Rework, shall be submitted to the ANI for concurrence of the disposition. 2
\ -
0 3.0 DEFINITION DF TERMS i 0
3.1 ACEPT-AS-IS
A Disposition indicating that the nonconformance does not i adversely affect safety, interchangeability, service, life, perfomance or j ASE Code requirements; and that the material can be used for its intended j purpose. t , 3.1.1 On ASE Code Accept'-As-Is Dispositions where stress analysis is required, the disposition must be supported by a statement from a Registered Professional Engineer stating, "Tnis disposition is acceptable and in accordance with Stress Report No. xxx". 3.1.2 NR's dispositioned " Accept-As-Is" must be approved by the Material Review Board. !
- t.
3.2 REWDRK
A Disposition that a Nonconformance can, through subsequent part placement, reprocessing or completion of the required operations, be brought into conformance with drawing and specification requirements. 3.2.1 NR's dispositioned " Rework" must be approved by the HJK Quality Engineer, the CGEE Sponsor. Engineer and the CG&E Quality Engineer. t 3.2.2 NR's dispositioned " Rework" written against ASME Section III, Div. I a shall be corcurred with by the ANI. E l
3.3 REPAIR
A Disposition which pemits the . reprocessing of material, appurtenances, and parts to bring into an acceptable condition, although still departing from the original design requirements. 3.3.1 Repaired ASE Section III, Div. I items must comply with code requirements and concurred with by the Authorized Nuclear Inspector. 3.3.2 NR's dispositioned " Repair" must be approved by the Material Review Board.
3.4 REJECT
A nonconforming disposition which indicated that the item is unsuitable for its intended purpose and economically or feasibly incapable of being reworked or repaired. 3.5.1 N;'s dispositioned " Reject" must be approved by HJK Quality Engineer, the CG&E Sponsor Engineer ,and the CG&E Quality Engineer. 3.5 PATERIAL REVIEW BCARD: Shall be comprised of the following to approve NR disposition. 5
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L _ . ._ . .. . _ . I x - ~ - -
HENRY J. KAISER CO. Q.
A. PROCEDURE
No. 16 osv. 8' pgag 3 o, c 1 (: 3.5.1 For Essential items, Sargent & Lundy (S&L), CG&E Nucicar Engineering Dept. (NED), CG&E Quality Assurance Dept. (OAD), HJK Cuality Engineer, ANI (if ASME Section III, Div. I related), HJK Construction Engineering and CGEE Nuclear Production Dept. (NPD) for 5000 series NR's only. , 3.5.2 For Nonessential NR's, the review board shall consu.t of a CG&E Nuclear Engineer, a CC&E Quality Assurance Engineer and a HJK Quality Engineer. (S&L. approval is not required). 3.5.3 The final disposition decision of the Material Review Board will be unanimous. 3.5.4 The HJK Quality Engineering Manager or his representative shall coordinate activities to accomplish Material Review Board Actions. 4.0 PROCEDURE 4.1 NONCONFORMANCE REPORT (FIGJRE 16-1) 4.1.1 A Nonconfomance Report (NR) shall be initiated by the HJK Inspector when material or items do not conform to drawing, i specification, purchase documents or ASME Code requirements. 4.1.1.1 The Inspector shall obtain a control number from the Administration Manager and enter the number on the NR and the applicable inspection planning Qcument. - {_. 4.1.1.2 The ta shall be reviewed by the Lead Inspector and the discipline Quality Engineer for completeness and reportability in accordance with 10CFR50, subpart 50.55(e) before further processing. 4.1.1.3 The incpector shall assure that the material or items are clearly identified as nonconforming by attaching a Hold Tag, or Deficiercy Tag and physically segregating or isolating them whenever possible. 4.1.1.4 Where nonconforming material or items are found during installation and where physical segregation is impractical, it shall be icentified with a Hold Tag. The NR and Inspection Plan shall be used to identify the norconfomarce and the location of the item. 4.1.2 The NR shall be presented to the applicable Discipline Engineer for recommending a disposition of Rework, Repair, Accept-As-Is or Reject. l l l 1 j . l L ._i,.. i:.
HENRY J. KAISER CO. Q.
A. PROCEDURE
Nr. 16 r,E v. A PAGE 4 o7
- 4.1.2.1 For Rework disposition, the Discipline Engineer determines the method of rewcrk and writes tnis method on the iP.,
signs the Nonconformance Report, and cbtains requirec approvals. 4.1.2.2 For Reject disposition, the Discipline Engineer will enter a technical justification for the disposition, sign the Nonconformance Report, and obtain required approvals. 4.1.2.3 For Accept-As-Is dispositions, the Discipline Engineer enters a technic"al justification for the recommended disposition, signs the Nonconfomance Report and obtains approvals. 4.1.2.4 For Repair disposition, the Discipline Engineer determines a repair procedure, enters the recommended repair procedure on the NR and obtains required approvals. 4.1.3 All documents associated with repair, if they involve ASME items, will be reviewed with the Authorized Nuclear Inspector so that he may establish hold points as he deems necessary. 4.1.4 Upon verification that rework or repair on the item has been accomplished as specified by the NR disposition, the NR is signed cff by the HJK Co. Inspector. . 4.1.5 The responsibility for determining the acceptability of corrective action for all nonconfomance rests with the HJK Discipline Quality Engineer; and is based on his judgment relative to the cause, seriousness and frequency of the norconfomance. The cause of the nonconformance and the corrective action to prevent the condition from recurring are entered by the Construction Engineer before the Discipline Quality Engineer signs the NR. i 4.1.5.1 Nonconfomance Reports for recurring discrepancies will be reviewed and analyzed by the Quality Engineering. After ' R such analysis is made, the Quality Engineer will report his ,5 findings to the Site Quality Assurance Manager for further action. If deemed necessary, a CAR shall be initiated. 4.1.6 Distribution of Nonconformance Reports shall be made to a distribution list by the Administration Manager /or his cesignee. The ANI shall receive copies of preliminary and final NR's. 4.1.7 A log of Norconfomance Reports, that have been initiated and the status of the NR's will be maintain'.'c by the Administration . j Manager /or his designee. l L [ -{= I 2
HENRY J. KAISER CO. Q. '
A. PROCEDURE
Ns. 16 n ev. 8' Pace 5 or ; G ~ 4.1.8 Records will be retained on all nonconformino items, indicating ultimate disposition of the items. The original copies of Norconformance Reports which have been given control numbers shall be maintained as pemanent records in the Quality Records Center. 4.2 STOP WORK ORDER (FIGJRE 16-2) R 8 4.2.1 Cognizant Henry J. Kaiser personnel are responsible for notifying l the Project Manager and the Quality Assurance Manager of any conditions which may form the basis for a Stop Work Order. 4.2.2 Stop Work Orders are used to terminate construction work activities, which, if continued, would have a serious adverse affect on the quality of a system or component, or on the Quality Assurarce Program. 4.2.3 The HJK Project Manager has the option of issuing a Stop Work Order and he shall be responsible for assuring that the condition has been adequately corrected before removing the Stop Work Order, j 4.2.4 The Quality Assurance Manager has the option of issuing a Quality , Assurance Stop Work Order that halts the activity until the condition is satisfactorily corrected. In this case, the Project Manager shall be responsible for acknowledging the Stop Work Order and for preparing the Request for Release section once the condition noted in the Stop Work Order has been adequately corrected the CA Man:ger shall verify that the conditions causing the stop work have y! g been resolved. 4.3 CORRECTIVE ACTION REPORT (FIGURE 16-3) 4.3.1 For procedural deficiencies, CAR's will be written by Quality Assurarce personnel and approved by the HJK Site Quality Assurarce Manager prior to issue. Corrective action commitment shall be approved by the HJK Site Quality Assu arce Manager. An index log showing status of CAR's shall be maintained by the QA Administration l Manager or his designee in accordarce with appropriate implementing l - procedures. [ l 4.3.2 A CAR T.ay be used to assure corrective action on a Nonconformance Report. 4.3.3 For procedural violations that result in material deficiercies, a CAR shall be issued to document the procedural violation and a Norconformance Report shall be issued to document the material deficiercy. l 5.0 ATTACHMiNTS 5.1 Figure 16 Nonconformance Report l 5.2 Figure 16 Stop Work Order
- r l
5.3 Figure 16 Corrective Action Report l i i. .'f:.' a u
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EXIIIBIT 2 HENRY 1. KA15=R ~ COMPANY ZlMMER P.D. BOX 201. MC5 COW. OHiG .:5153 PROCEDURES MANUAL [ZPM] Wf.i. H. ~7 !f.if.iER NUCt. EAR POWER STATION SECTION: II PROCEDURE 110. PAGE 1 OF 32 ZAPO-5, Rev. I
._ 1 EFFECTIVE DATE: 6-2-82 TITLE PAGE l~ PP.OCEDURE TITLE: E I IE m M N N-CONFOR M CE REPORTS GTMOE IMMER ADMINI TRATIVE PR EDURE CRGANIZATION j COMPLETE REk' RITE .
PREPARED BY: - CW, o _ _0 DATE E~ 2 E~b A QAADMIdSTRATIONMANAGER CONCURRED BY: E F '8 l DATE Title PROJECT MMAGER APPROVED BY: Title
# DATE b i
QA MANAGER h 7 l APPROVED BY: 3' ' DATE Title MANAGER GCD l This Procedure Supersedes The Following Procedures ZAPO-5, Rev. 0 OACMI G-4, TCN #1, TCN #2 1 [' Q l l l t
HENRY J. KAISER ZlMMER COMPANY P.O. BOX 201 MOSCOW, OHIO 45153 WM. H. ZIMMER NUCLEAR POWER STArlON
. ROCEDURES MANUAL:ZPM:
SECTIOrb II PROCEDURE f 40. PAGE 2 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 1.0 PURPOSE /SCOE PURPOSE 1.1 The purpose of this procedure is to provide instructions for processing and documenting deficiencies within the scope of the HJK construction responsibility and Quality Assurance Program. SCOPE 1.2 Nonconformance Reports shall be written for nonconforming material, equipment, or items identified during HJK First Line Inspection, Surveillance, or as required in Review of Documentaticn associated with HJK activities at the Wm. H. Zimmer Nuclear Power Station, that are found after final inspection or that cannot be corrected through the In-Process Inspection Deficiency 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.
2.0 REFERENCES
2.1 General Quality Procedure GQP-10, " Corrective Action Reports". 2.2 General Construction Prodcedure GCP-3, " Work Package Procedure". 2.3 Quality Assurance Procedure QAP-15, " Inspection, Test, and Operating Status". 2.4 Quality Assurance Procedure QAP-16, " Control of Nonconforming Material, Parts, Components, and Activities". 2.5 Code of Federal Regulations, Title 10: Part 21 and Subpart 50.55(e). 2.6 Quality Records Management GiM-1, " Review and Approval of Quality Documentation". 2.7 ANSI N45.2 (1974), Quality Assurance Program Requirements for Nuclear Facilities. 2.8 General Quality Procedure GQP-3, " Tracking and Trending of Quality Items". 3.0 GENERAL DESCRIPTION 3.1 DEFINITICNS 3.1.1 Responsible Organization
HENRY L KAISER 5lN NE?t COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 PROCEDURES MANUAL;ZPM WM. H. ZIMMER NUCLEAR POWER STAflON SECTION- 11 PROCEDURE N O. PAGE 3 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 The Responsible Organization is the organization with jurisdictional responsibility for the Nonconforming condition. 3.1.2 Implementing Organization The Implementing Organization is the organization (HJK, CGiE, Supplier, or Subcontractor) assigned on the NR fom the responsibility for correcting the Nonconforming condition by implementing the approved disposition. 3.1.3 Nonconformance A deficiency in characteristic, documentation, or procedure which renders the quality of an item unacceptable or indeteminate. Examples include: Physical defects, test failures, and incorrect or inaccurate documentation. 3.1.4 Nonconformance Report A form (Exhibit A, pg. 1) which c. scribes a deficiency in a characteristic or procedure which renders the quality of an item indeterminate or unacceptable. 3.1.5 Continuati.on Sheet A Continuation Sheet (Exhibit A, pg. 4) is used when additional space is r2eded for any block on a Nonconformance Report. Each sheet shall be consecutively numbered with the total number indicated on the first page of the NR (i.e. page 2 of 12). As attachments are added to the NR, the person adding the attachment shall identify the attachment on the NR, consecutively number each page of the attachment, and write the NR nurrber on the attachment. 3.1.6 Disposition Engineer - The Field Engineer, the S&L Design Engineer, or designee assigned the task of providing an NR Disposition, Disposition Instructions, Cause, and Corrective Action to be taken. 3.1.7 Originator
- Cognizant GA personnel have authority to originate NR's in accordance with this procedure.
HENRY 1. KAIEER ZlMMER COMPANY P.O. BOX 201 MOSCOV/, OHIO 45153 PROCEDURES MANUAL ZPM V/M. . H. ZIMMER NUCLEAR POV/ER STATION SECTIOrb II FHOCEDuRE NO. PAGE 4 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE- 6-2-82 3.1.8 Deficiency An item which is lacking in some necessary quality or element. 3.1.9 In-Process Inspection Deficiency Record (IIDR) A form (Exhibit B) used to document deficiencies found during the inspection of in-process work. 3.1.1D Authorized Engineers - CGiE GCD Hanger Engineers, HJK Weldirg Department Engineers, an'd 55L ' Engineers are authorized to evalt>ste a:ficienciesf within their -
~ disciplines and to provide IIDR' resolutions. ,.
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3.1.11 Final Inspection Final inspection is achieved when applicable HJK and CGiE QC
, inspections are complete and the CIP (or other similar document) is acceptance stamped and/or initialed as required, and transmitted to Quality Engineering by the QC Supervisor.
3.2 An In-Process Inspection deficiency Record shall be initiated in the following instances: 3.2.1 An In-Process Inspection Deficiency Record shall be used only to record deficiencies in construction work identified up to and
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Tncluding the finalinspectico.. Howevir, s~utijedt's may be cocumented
'o'ii'iid NR~~6f CART lind do lici have to be recorded on an IIDR. The IIDR shall reference PSDCR's, DDC's, NR's, or CAR's written as a result of the conditions identified on the IIDR. Reference to these PSDCR's, DDC's, NR's, or CAR's is acceptable to close out the IIDR.
3.2.2 IIDR's shall not be used to provide procedural instructions. 3.3 General requirements for writing and processing an IIDR. 3.3.1 There shall be only one IIDR per work package. Additional pages may be added to the IIDR, as required. The additional pages shall be numbered consecutively ar.d the total number of pages indicated on page one by the individual adcing the pages.
HENRY J. KAISER ZINNER COMPAN Y P.O. BOX 201 MOSCOW, OHIO 45153 WM. H. ZIMMER NUCLEAR POWER STArlON PROCEDURES MANUAL ZPM] SECTION- II PHOCEDURE N O. PAGE 5 OF 32 ZAP 0-5, Rev. 1 EFFECTIVE DATE: 6-2-82 3.3.2 All IIDR's shall have a unique control number for accountability and tracking purposes. The number will be issued and an IIDR I q maintained by the Quality Control Department. 3.3.3 When the construction personnel and the inspector agree that a deficiency should be corrected by reworking the condition, construction personnel shall list the corrective action on the IIDR and carry it out. A reinspection shall then be performed. The inspector shall appropriately close out the IIDR.
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3.3.4
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If the constructic'n cersonne156d'the inspector disagree that an 5
.apperent deficiency should be reucrkeo, an authorized engineer may '
provide the IIDR disposition cecision: - 3.3.4.1 Rework. 3.3.4.2 Explain why the condition is not a defect. 3.3.4.3 Explain why the deficiency may be accepted-as-is. 3.3.4.4 Initiate a DDC. NOTE: yhen the inspector does not agree with the resolution providEd by tRe' authorize @ncineer 2 ne sTiE1T notify' lica11ty engineer 1hi Th'at a disagreement exists and that the work package- irbeing processed. "ThT~GThilf~theri pe~Yfcm a71i:fely evaluation 7nd"IIDR review and take correcfivF action when r&QUlrea. 3.3.5 All IIDR's shall be reviewed. by a Quality Encineer after the work ~) package has been completed. In5-QU51~ify Engineer sEall provide l final QA disposition when necessary to assure that every IIDR is closea out and initiate required NR's. The review shall determine that the IIDR was used properly, that the entries were properly completed, and that the resolution of the IIDR complies with appropriate codes, standards , and approved procedures. 3.3.6 An IIDR trend analysis shall be performed by Quality Engineering. 3.4 A Nonconformance Report shall be initiated $n the following instances: 3.4.1 Whenever material, equipment, or construction work deviates from the specified limits of a drawing, specification, code, standard, procedure, cr an approved Inspection Plan. G
HENRY 1. KAISER ZlM M EP, COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 PROCEDURES MANUAL ZPM] WM. H. ZIMMER NUCLEAR POWER STArlON SECTION: II PHOCEDuRE N O. PAGE OF 6 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 NOTE: Deficiencies in construction work identified up to and including final inspection, which are documented on an In-Process Inspection Deficiency Record (IIDR) form according to approved procedures, or other deficiencies that are corrected in accordance with other applicable corrective action procedures, do not require identification on an NR. 3.4.2 Whenever certified test results deviate from specified requirements. 3.4.3 Whenever a process or activity places the existing plant systems or equipment in an indeterminate condition. 3.4.4 When a piece of equipment or installed material that has been accepted is damaged. 3.4.5 In cases where required documents are not available, document deficiency tracking has failed and all other means of research are not able to establish an acceptable document. 3.5 General requirements for writing and processing an NR. 3.5.1 A separate m should be written for each individual item such as a Hanger, Pipe Spool, ISO Drawing, specific piece of Equipment, etc., the intent of which is to allow each Nonconforming item addressed in the NR to be closed out in the same time frame. 3.5.2 Once an NR Control Number is issued by the Lead Reports Coordinator, the NR must be processed and may only be invalidated as part of the normal processing as outlined in this procedure. 3.5.3 Processing of an NR shall be in a timely manner. If a delay in processing is expected, the Lead Reports Coordinator should be j notified. 1 3.5.4 Nonconforming items shall be tagged, if appropriate, with a yellow
" Hold" Tag, orange " Deficiency" Tag, or white " Seismic Violation" Tag, noting the NR Number and a brief description of the nonconformance in the " Remarks" section of the tag. If the nonconforming item or condition requires that the item be segregated or further use/ installation be terminated, the Originator shall apply a yellow " Hold" Tag. If the nonconfcrming item or condition does not require segregation or that the use/installatica be terminated, the originator shall apply an orange " Deficiency" Tag.
If the nonconformance is a Seismic Violation between systems or components in Seismic Category 1 buildings (as defined in the specifications), the items in violation shall be identified witn a white " Seismic Viciation" Tag. 8
HENRY J. KAIEER ZlMMER COMPANY P.O. BOX 201 MOSCOW, OHIO 45153 PROCEDURES MANUAL ZPM: WM. H. ZIMMER NUCLEAR POWER STArlON SECTIOfb II FROC E D'.'H E N O.
' PAGE 7 OF 32 EFFECTIVE DATE: 6-2-82 NOTE: A description of the tags authorized for use by the HJK Inspection Department is found in Quality Assurance Procedure (QAP) 15. These tags are to be applied or removed only by authorized QA personnel.
3.6 The following alphanumeric system shall be used for the NR. 3.6.1 NR's written on Essential (or Non-essential / Seismic) Systems / Components shall be given an "E" prefix number. 3.6.2 NR's written on Non-Essential Systems / Components shall be given an "N" prefix number. 3.6.3 NR's written reporting a seismic violation between systems or components shall be given a 6000 series number.
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3.6.4 NR's written on a System / Subsystem / Area that has been turned over for pre-operational testing shall be given a 5000 series number. 3.6.5 NR's written within the scope of the CG5E Quality Confirmation Program shall have their number suffixed by the Letter "Q". 3.6.6 NR's written by HJK Documentation Department shall have their number suffixed by the Letter "D". NOTE: "Q" NR's which are written by the HJK Documentation
< - Department shall have their number suffixed by the letters "CD". : i t
3.7 TYPES OF NONCONFORMANCE DISPOSITIONS 3.7.1 Accept-As-Is - A disposition indicating that the nonconformance does not substantially affect the design, safety, interchangeability, service life, or performance, and that the material or equipment can be used for its intended purpose. May also be used to disposition an NR written in error. On ASE Code Accept-As-Is Dispositions where stress analysis is required, the disposition must be supported by a statement frca a Registered Professional Engineer stating, "This disposition is acceptable and i,n accordance with Stress Report No. xxx". 3.7.2 Reject - A disposition that proves that the item is unsuitable for its intended purpose and economically or feasibly incapable of being reworked and repaired.
HENRY J. KA/EER 5 INN 50 COMPANY P.O. BOX 201 MOSCOW, OHIO 45153 WM. H. ZlMMER Nt) CLEAR POWER STATION PROCEDURES MANUAL:ZPFd SECTION: 11 FROCEDUHE N O. PAGE g OF 32 ZAPO-5 Rev. 1 EFFECTIVE DATE: 6-2-82 3.7.3 Reoair - A disposition which permits the reprocessing of material to bring it into an acceptable condition, although it still departs from original design requirements. (Repairs to ASME Section III items must comply with all of the Code Requirements). 3.7.4 Rework - A disposition that a nonconformance can, through subsequent part replacement, reprocessing, or completion of the recuired operations, be brought into original conformance with drawing and specification requirements. Rework may be performed on hardware or software (i.e. documents, drawings, etc.). 3.8 REQUIREMENTS FOR SUDERSEDING OR CANCELLING AN NR OR DRAFT NR 3.8.1 There may be instances when a Nonconformance Report has been initiated in error due to interpretation or judgment of borderline conditions or duplication. In these_insta0ces, cancellation of the NR must be approved by the HJK Site Quality Assurance Manager and
'the CGE CA~Penager. NR'3Teall~ng WitfXSifSei:tlon ~ffI items also_
' require the-~ep~prova~1 of'thli ANI for cancellation. The cande11ation
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of draTt~NR+s notifosed in accordance with Para. 3.8.3.2, requires only the signature of the HJK QA Manager and those signatures required in Para. 3.8.3.5. After this approval, the NR or draft NR shall be stamped, " Cancelled". A Statement indicating the justification for being cancelled shall be recorded on the attached form (Exhibit D), signed and dated by the QA Manager. A corresponding entry shall be made next to the control number in the NR Log. The cancelled NR or draft NR and the justification form shall be distributed in accordance with Exhibit A, pg. 5. The originator of the NR shall remove the tag when the cancelled NR copy is received from distribution. (A) Personnel requesting that an NR be sLperseded or cancelled shall do so in writing, stating what is to be done including a justification, signed by the cognizant Discipline Construction /Cuality Engineer, superintendent, or manager. It shall then be forwarded to the Lead Reports Coordinator for presentation to the Material Review Ecard. (B) Blocks 1 through 9 of the NR shall not be revised unless the originator changes them and specifies in writing the reasons for the change. Blocks 10, 11, 14, ano 15 may be revised by unanimous vote of the MRS. The organization responsible for the NR shall be notified of the change as quickly as possible. 4
HENRY J. KAIEER ZlMMER COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 WM. H. ZIMMER NUCLEAR POWER STArlON PROCEDURES MANUAL ZPM] SECTION: TT FROCEDURE 14 0 . PAGE 9 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATEi 6-2-82 (C) When an NR that has been approved by the MRB is to be revised, because of change in disposition, cause, or corrective action, the NR shall be stamped " Superseded by Rev. No." and signed and dated by the Cognizant HJK Discipline Quality Engineer. The revised NR shall retain the original NR number and shall indicate the next revision number. A memo or justification stating reasons for the revision shall be attached to the NR. The previous revision of the NR becomes an attachment to the new NR. This revised NR is then processed in accordance with this procedure. 3.8.2 Until an NR has been approved by Quality Engineering, it is considered a " draft NR" which may or may not report a true nonconformance. Draft NR's will have a control number assigned to them for administrative purposes (per Para. 4.2.1 or 4.2.2). If it is necessary to halt work pending review of the draft NR, the originator shall tag the apparently nonconforming item per Para.
- 4. 2.1.
3.8.3 If review by the Quality Engineer determines that the draft NR is incomplete, is in error, or does not report a nonconforming I condition, then it shall be returned to the originator for l correction or close out with the QE's reasons entered on the NR Review Form (Exhibit G). 3.8.3.1 If the originator agrees that the draft NR is in error or is incomplete, he may supply the missing information or correct blocks 1 through 9 of the NR form by lining through, initialing, dating the error, explaining in writing the reasons for the correction, and forwartdng the NR form to the QE for further processing.per this procedure. 3.8.3.2 If the originator agrees that no nonconforming condition i exists, then he may close out the draft NR by entering his l justification in the disposition instructions section of the draft NR as follows:
"This NR was written in errqr due to the following:"
Examples Include: l l (A) Inspected to incorrect drawing and/or accept / reject criteria. 1 (B) Inspected wrong component. , \ 1 i l
HENRY J. KAISER 5lNN5R COMPANY P.O. BOX 201 MOSCOW, OHIO 45153 PROCEDURES MANUAL ZPM WM. H. ZIMMER NUCLEAR POWER STATION SECTIOtt II PROCEDURE f 40. PAGE m OF y ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 (C) Misread measuring and '.est equipment. (D) Misinterpretation of requirements. (E) For other reasons as noted on the NR Review Form.
.The orignator shall then sign the appropriate space on the NR Review Form to indicate his agreement with the CE's comments and return it to the CE for processing. An entry shall be made next to the control number in the NR Log stating that a nonconforming condition did not exist. The closed draft NR shall be distributed in accordance with Exhibit A, Pg. 5. The Originator shall also remove any tags placed on equipment because of the closed draft NR.
3.8.3.3 If the originator does not agree that the draft NR is in error or if he balleves that t ncnconforming conditiori cces exist, he shall indicate his disagreement and justification on the NR Review Form ano forward the NR Form to the CE for processing as an ta. 3.8.3.4 If the QE agrees with the originator, the NR will be processed in accordance with this procedure. 3.8.3.5 If the CE and the manager of his department do not egr5e J with the originator, they shall initiate an t,R cancellation j form (Exhibit D), enter the word Draft in the NR # slot, sign and date the form, and forward it to the CA Manager. The processing of the draft NR will then be decided by the QA Manager. l 3.8.3.6 The QA Manager may cancel the draft NR in accordance with Para. -3.8.1 or decide that the draft NR be processed as a valid NR in acuordance with Para. 4.2. 3.9 MATERIAL REVIEW BOARD 3.9.1 Membership (A) Sargent and Lundy (S&L) (B) CG&E Nuclear Engineering Department (NED) (C) CG&E Quality Assurance Department (CAD) (D) HJK OE
HENRY 1. KAISER ZlMMER COMPANY P.O. $OX 201 MOSCOW, OHIO 45153 WM. H. 21MMER NUCLEAR POWER STArlON PROCEDURES MANUAL 2PM SECTION: II PHOCsiDuHei t40. PAGE OF y i3 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 (E) KJK Constru: tion Engineering (F) CG&E Nuclear Production Dept. (NPD) for 5000 series NR's only. 3.9.2 CG&E tED and/or SiL shall review and approve NR's dispositioned
" Accept-As-Is" and/or " Repair" which document violations of the code (ASME, AWS, etc....) or S&L specification. NR's which document only violations of site procedures and not a code or S&L specification need not be reviewed and approved by S&L and/or NED.
NR's dispositioned " Rework" or " Reject" must be approved by the HJK Quality Engineer and the CG&E Quality Engineer. Whether or not to send an NR to S&L and/or NED for review shall be decided by the Quality Engineer during review. If S&L does review an NR, and finds that the nonconformance does not involve a code or specification, S&L may mark "N/A" (not applicable) in the signature block and entar initials and date. 3.9.3 S&L may review an NR and provide a preliminary approval by stamping the NR in Block 12 (Exhibit A Pgs. I and 3) and signing and dating the stamp. This approval may be provided based on engineering judgment or past experience with similar situations. This approval may be used, for example, when an S&L home office calculation or analysis may be required, but time does not permit. This preliminary approval will allow the continued processing of the NR. An NR which has S&L preliminary and all other approvals as required by this procedure except for the S'cl final approval may be worked at risk. Before final close-out, an NR which has S&L preliminary approval must have final SiL approval. If SiL has provided preliminary approval, but disapproves the NR upon. final review, appropriate action must be taken (a new NR may have to be written, or the original NR revised). 3.9.4 The MRB shall be convened as specified by CG&E and HJK project management for the purpose of reviewing and approving NR's. All MRB members shall attend scheduled MRB meetings when required.' NOTE: Members of the MRB for Rewcrh or Reject dispositions are the same as for Accept-As-Is or Repair with the exception of CG&E NED and S&L. .
us/vav_/./s./ san ZIMMER COMPA/VY P.O. BOX 201 MOSCOW,CHlO 45153 PROCEDURES MANUAL ZPM] WPA. H. ZIMMER NUCLEAR POWER STArlON SECTICN: II PROCEDURE N O. PAGE 12 OF 32 ZAPO-5, Rev. 1 6-2-82 EFFECTIVE DATE, 3.9.5 All ASME related NR's shall be reviewed and signed by the ANI. / 3.10 RESOLUTION OF DISPOSITION DISAGREEMENT 3.10.1 In the event the originator disagrees with the~apprcpriatenessi of the disposition, the channel for resolution shall be as follows: (A) The originator shall submit an inter-office memo to the department Manager stating reasons for the disagreement. (B) The originator's Manager will review and provide resolution to the Originator. (C) If the originator is not satisfied with resolution provided by the Manager, the originator may request reconsideration by submitting an inter-office memo to the HJK Site QA Manager requesting reconsideration, with a justification for the request. . (D) The HJK Site CA Manager shall provide final resolution of the request to the originator. Copies shall be forwarded to the CG1E QA Manger, HJK Director of Quality Assurance Programs, and HJK VP-Power Division. NOTE: Work may continue on the NR, during resolution cf the dispute, unless a written request to suspend work is made by a memo from the HJK QA Manager to the HJK Project Panager. 3.11 NR STATUS REPORT Records of NR status are published and distributed by the QA Administration Department, as follows: 3.11.1 Master NR Report (Monthly) - Numerical listing of all NR's. 3.11.2 Open NR Report (when specified by HJK Project Management) - Numerical listing of all open NR's. 3.12 All written entries on an NR or IIDR should be made by black ball point. The ink used should not be susceptible to water streaking or fading. 4
HENRY J. KAIEER ZlNMER ~ COMPANY e.o. ecuoi uoSCow.osio 45,sa WM. H. ZIMMER NUCLEAR POWER STAflON PROCEDURES MANUAL ZPM SECTION: II FROCEDURE N O. PAGE 13 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATEi 6-2-82 3.13 Corrections or changes shall be made by drawing a single line through the entry and intialing and dating near the correction. If sufficient space is not available to make the necessary correction, circle the block number and give the correct information on a continuation sheet. White out and correction taoe shall not be used. Personnel may only correct sections of the NR for wnicn they are responsible. 4.O PROCEDURE 4.1 The following procedure shall be used to record and correct deficiencies using the In-Process Inspection Deficiency Record. RESPONSIBLE POSITION ACTION ORIGINATING QC INSPECTOR (HJK OR CGiE)
- 1. When a deficiency is discovered, the originator shall complete blocks 1 through 5 of the IIDR Form (Exhibit B, Pg.1) following the instructions of Exhibt B, Pg. 2 and obtain an IIDR number from the QC Inspection Manager or designee and enter it in block 14 of the IIDR form. CG&E personnel using the IIDR form are required to identify their entries by placing the initials CG&E next to their name on the form so that appropriate tracking and trending may be completed. The originator shall then check the appropriate block on the Work Package Checklist (GCP-3) to indicate that an IIDR is included. The Originator shall then obtain a field review from appropriate qualifed construction personnel.
1 QUALITY CONTROL MANAGER / DESIGNEE
- 2. Provide unique control numbers for the IIDR's. Maintain a log of the IIDR numbers issued listing the number of the work package or the punchlist ticket that the IIDR applies to, the name of the inspector initiating the IIDR, and the date.
CONSTRUCTION FERSONNEL
- 3. Provide a disposition in column 6 of the IIDR and take corrective action (proceed to Paragraph 4.1.9)., If there is a disagreement concerning the deficiency, contact an authorized engineer for resolution. Work involving the deficiency shall cease until an authorized engineer is found to provide a resolution.
HENRY.J. KAl.ETER ?lMMER COMPANY P.O. BOX 201 MOSCCkOHIO 45153 PROCEDURES MANUAL II ZPM] WM.. H. ZIMMER flUCLEAR POWER STATION SECTION: PHOCEDURE 14 0 . PAGE 14 OF S2 EFFECTIVE DATE 6-2-82 AUTHORIZED ENGINEER FOR RESOLUTION
- 4. Evaluate the conditions and the IIDR and disposition in one of the following ways:
- 5. For those cases where a deficiency does exist, provide a disposition in column 6 of the IIDR.
- 6. For those cases where a deficiency does not exist, explain why the condition is r 3t a deficiency in column 6 of the IIDR.
- 7. If an acceptable discrepancy exists, describe why the condition is acceptable on the IIDR or initiate a DDC or PSDCR.
CONSTRUCTION FERSCNNEL
- 8. Take corrective action as shown on the IIDR.
INSPECTOR
- 9. Reinspect and apprcpriately close out the IIDR. When acceptance criteria is not met, reinitiate the IIDR.
- 10. Work may proceed based upon an authorized engineer's evaluation and resolution. If the inspector concurrs, proceed to Para. 4.1.12.
When the inspector does not agree with the resolution provided by the authorized engineer, the inspector shall permit the work to proceed and notify quality engineering that a disagreement exists and that the work package is being processed. (Proceed to Para. 4.1.11). QUALITY ENGINEER
- 11. When notified of conditions described in Para. 4.1.10, perform a timely evaluation and IIDR review. When required, take corrective action, for example: write NR.
INSPECTOR
- 12. Retain the IIDR in the work package.
FIELD ENGINEER
- 13. Upon completion of the work package, forward the IIDR with the work package to the CE per the Work Package Procedure (GCP-3).
L
HEh!RY L KA/EER ZINNER CDMPA/VY P.O. BOX 201 MOSCOW. OHIO 45153 PROCEDURES MANUAL ZPM] WM. H. ZIMMER NUCLEAR POWER STArlON SECTION: II PROCEDURE N O. PAGE 15 OF 32 ZAPO-5 EFFECTIVE DATE: 6-2-82 QUALITY ENGINEER
- 14. Review all IIDR's when the work package reaches the QE group.
Provide a final acceptance statement and close out open IIDR's dispositioned by an authorized engineer. When necessary, initiate nonconformance reports.
- 15. Perform trend analysis and assure that open IIDR items are tracked to completion.
- 16. Forward the IIDR with the work package to HJK Records Management.
4.2 The following procedure shall be used to initiate, process, and disposition an NR. RESPONSIBLE POSITION ACTION HJK ORIGINATOR
- 1. When a Nonconforming condition is identified, the HJK Originator shall' fill out the NR Form (Exhibit A, Pg.1) following the instructions of Exhibit A, Pgs. 2 & 3 and forward the form to the cognizcnt Discipline Lead.
NOTE: If the process or activity needs to be immediately halted, the originator shall obtain a control number from the Lead Reports Coordinator and place a Hold Tag on the nonconforming item referencing tha control number on the tag with a brief description of the nonconformance. DISCIPLINE LEAD
- 2. Upon receipt of the completed NR Form, review the ' draft NR for completeness, adequacy, and appropriateness. Identify craft NR's which fall within the scope of the Quality Confirmation Program by placing a "Q" in the Nonconformance Report No. bicek on Exhibit A, Pg. 1. Identify draft NR's written by the HJK Documentation Department by placing a "D" in the Nonccnformance Report No, block on Exhibit A, Pg. I as required by Para. 3.6.6 of this procedure.
Initial in Block 6 indicating concur:*:nce, obtain an NR control ' number from the NR Controller, and forward to the Discipline Quality Engineer.
HENRY I. KAISER EINN5R COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 PROCEDURES MANUAL ZPM WM. H. ZIMMER NUCLEAR POWER STArlON SECTION- II PROCEDuHE N O. PAGE 16 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2 82 NOTE: Other individuals may review for correctness, adequacy, ar.d appropriateness, as determined by the cognizant supervisor. DISCIPLINE QUALITY ENGINEER
- 3. Review the draft NR for technical adequacy and accuracy. Determine if the cordition noted on the NR form is potentially reportable under the requirements specified by 10CFR21 and 10CFR50.55(e) and/or if a CAR should be generated. Fill out the NR Review Form (Exhibit G). Attach it to the ta form and forward it to the Lead Reports Coordinator for processing. If the QE determines that the draft NR is in error or does not report a nonconforming condition, then the QE shall enter the reasons why it is in error or not a nonconformance on the NR Review Form and return it to the Originator for correction, closecut, or further processing per Para. 3.8.3.
NOTE: The review of ta's shall assure that ncne have been cancelled by the issuance of a Design Document Change-(DDC). ORIGINATOR
- 4. Review and process NR's returned from QE for correction and closecut per Para. 3.8.3.
LEAD REPORTS COORDINATOR i
- 5. Assign the NR a control number as required by Para. 4.2.1 or 4.2.2, I and an NR number frcm the NR Log (Exhibit C). (See Para. 3.6 for numbering system).
l
- 6. After the NR is logged, distribute copies of the NR per Exhibit A, Pg. 5 and forward the original NR to HJK Construction Engineering for dispositioning. Provide NR data for the Computer Status Report.
HJK ORIGINATOR
- 7. When the originator of the NR receives a copy from distribution, the originator shall initiats a tag per Para. 3.5.4, if appropriate.
The tag is "R" stamped and/or initialed and dated and then affixed to the material, equipment, or work in a conspicucus area. All inspection documents are to reference the NR Number and "R" Stamp. The Originator shall notify the Cognizant Superintendent for the purpose of quarantining material, as necessary. 4
4 4 HENRY J. KAl.ETER 5 INNER COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 PROCEDURES MANUAL:ZPMj l WM. H. Zl?/.MER NUCLEAR POWER STAf!ON SECTION: II PHUCEDURE N O. PAGE 17 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 DISCIPLItE CONSTRUCTICN ENGItEER
- 8. Upon receipt of the original NR, provide a Disposition (as indicated in Para. 3.7) in Block 10 of the NR Form. Additicnally, provide Disposition Instructions in Block 11 (explain how the disposition is to be implemented), Cause in Block 14 (explain what caused the nonconforming condition), and Corrective Action in Block 15 (explain what is proposed to assure the cause is not repeated or, if not applicable, put N/A and an explanation). If the NR identifies a condition which is the result of a quality or documentation requirement, the Construction Engineer may request assistance from appropriate Quality Engineers or cognizant GA personnel, who will provide information, documentation, or necessary research to aid in the disposition of the NR. The Discipline Construction Engineer should then sign and date the space provided on the form and forward the NR to the Lead Reports Coordinator.
NOTE: In some cases, S&L may be requested to provide disposition. The Discipline Construction Engineer shall indicate that S&L disposition is requested by writing "S&L disposition requested" on the top line of Block 11 of the NR Form. LEAD REPORTS COORDINATOR
- 9. Upon receipt of the NR, update the NR Log, provide data for updating the Computer Status Report, compile NR's for the MRB Meeting, and provide the NR agenda for the meeting.
NOTE: Instead of holding an MRB meeting, the Lead Reports Coordinator may circulate the NR to each member of the MRS. MRB
- 10. Meet and approve the NR Disposition, Disposition Instructions,
-~
Cause',1'and Cbrrective ActTon, and detsridiiisleportability per
~
10CFR21 ind/dMOCFR50.55(~5)~.-
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NOTE: All NR's that require additional review or research by any member of the MRB are.to be charged out to that member.
HENRY J. KA/EER 5 INN 50 COMPANY P.O. BOX 201 MOSCOW, OHIO 45153 PROCEDURES MANLIAL ZPM: WFA. H. ZIMMER NUCLEAR POWER STA riON SECTION: II PHGCEDURE N O. - PAGE 18 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82
- 11. The MRB may modify the disposition instrtctions, cause, or corrective action. These modifications must be approved (initialed and dated) by the dispositioning organization. However, QA/QC hold points may be added with initials and date by the Discipline Quality Engineers.
- 12. The Lead Reports Coordinator or designee shall coordinate review and.
approval of all ASlE Code related NR's with ANI after the MRB has approved the disposition. The ANI may also establish hold points at this time. LEAD REPORTS COORDINATOR
- 13. Update the NR Log and provide data for the Computer Status Report for all NR's acted on by the MRB.
Forward the NR per the following epplicable instructions. 14. (A) For the NR's dispositioned " Accept-As-Is", stamp " Closed" and distribute per Exhibit A, Pg. 5. (B) For those NR's dispositioned " Repair", " Rework", or
" Reject", distribute per Exhibit A, Pg. 5.
4.3 The following procedure shall be used to close an NR: i 4.3.1 Accept-As-Is NR's l RESPGNSIBLE POSITION ACTION HJK ORIGINATOR
- 1. Upon receipt of an approved Accept-As-Is dispositioned NR, remove the appropriate tag (i.e. Hold, Deficiency, Seismic) from the nonconforming item and place an Accept-As-Is tag on the item.
LEAD PEPORTS COORDINATOR
- 2. Stamp the approved Accept-As-Is NR " Closed", and forward the NR to HJK Records Management for retention as a Quality Record.
4
d HENRY.J. KAISER ZlNNER COMPANY P.O. BOX 201 MOSCOW, OHIO 45153 WM. H. ZIMMER NUCLEAR PCWER STArlON PROCEDURES MANUAL ZPM] SECTION: II PROCEDURE f 40. PAGE 19 OF 32 EFFECTIVE DATE: 6-2-82 4.3.2 Repair or Rework NR's RESPONSIBLE POSITION ACTION HJK ORIGINATOR
- 1. Upon receipt of an approved Rework or Repair dispositioned NR, place a Rework / Repair tag on the nonconforming item and notify the applicable Dispcipline Construction Engineer.
DISCIPLINE ENGINEER / DISCIPLINE SJPERINTENDENT
- 2. Upon receipt of an approved Rework or Repair dispositioned NR, perform work per applicable procedure.
- 3. Notify the HJK Originator.
HJK ORIGINATOR
- 4. When the work is performed, verify that the work was performed in accordance with the disposition instructions and the applicable requirements (i.e. - codes, drawings, specifications, procedures). When the Reworked material is acceptable, remove the tags. When the Repair is acceptable, remove the Hold tag, stamp or sign, and date, the Repair tag to indicate acceotance. The Repair tag remains on the item. Sign Block 13 of the original NRg
! retained by the Lead Reports Coordinator. LEAD REPORTS COORDINATOR
- 5. When the verifications and NR form sign-6ffs are completed, update the NR Log, stamp the original NR " Closed", make distribution (Exhibit A, Pg. 5), forward the original NR to HJK Records Management, retain a copy of the closed NR, and
, provide data to update the Computer Status Report.
4.3.3 Reject NR's t RESPONSIBLE POSITION ACTION HJK ORIGINATOR
- 1. Upon receipt of an approved Reject dispositioned NR, place a Reject Tag on the item.
HENRY.J. KAISER 2lMMER COMPAlyY P.O. BOX 201 MOSCOW, OHIO 45153 W M. H. ZIMMER NUCLEAR POWER STArlON PROCEDURES MANUAL ZPM) SECTION: II FHUCEDURE N O. PAGE 20 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82
- 2. Contact the Discipline Superintendent to have the item removed from the field.
NOTE: The disposition instructions may require more than one organization to perform or witness a Test / Inspection of an item. In this case, a signature verifying acceptance by each organization is required. If the originator of the NR is not available to perform the verifications of Paragraphs 4.3.1.1, 4.3.2.1, 4.3.2.4, 4.3.3.1, an individual within the same QA group may perform the verifications and sign the original NR. LEAD REPORTS COORDINATOR
- 3. Stamp the approved " Reject" NR " Closed" and forward the NR to the Documentation Manager for retentien as a Quality Record.
- 5.0 RETAINED DOCUMENTATIGN 5.1 Original IIDR's, NR's, and associated logs shall be stored, maintained, and filed in accordance with ANSI N45.2.9.
6.0 EXHIBITS 6.1 Exhibit A NR Form Page 21 l 6.2 Exhibit B In-Process Inspection Deficiency Record Page 26 6.3 Exhibit C NR Log Sheet Page 28 6.4 Exhibit D NR Cancellation Form Page 29 6.5 Exhibit E NR Processing Flow Chart Page 30 6.6 Exhibit F IIDR Processing Fluw Chart Page 31 6.7 Exhibit G NR Review Form Page 32 A
i 1 HENRY l. KAIEER
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- d. Il\',i N l R CDMi=A/VY P.O. BOX 201 MOSCOW, OHIO 45153 PROCEDURES MANUAL ZPE Vod. H. ZlMMER NUCLEAR FOWER STAflON SECTICN: II FRGCEDUHE No.
PAGE 21 OF 32 ZAPO-5, Rev. 1 EFFECTIVE CATE: 6-2-82 NEN RY J. KAISL A. 00. gg;;;O;jpgp,7gA;;;g ggpgg7 WM, H. ZIMVER power STATION N O. PAGE OF
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- 12. REVIEW 80AA0 (REOUIRED ON ALL AC;EPTiREPAIA CISP05l TION $1 M ire h ary A wi Saff 59 Safe o CONSiay;0CN ENGA OATE
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- 13. R EP AiRIREWO R K C vPtETE AND AC017TA8tf ORG.MA ~CA OAIE i 14.CAU3! 15. CORRECTIVE AC 10N 1
l t CAR No r:F APo'.tCABLEr (q This is a preliminary stamp that =ay be applied by S&L. FOPJ: NO.460/2-82/Rev.0 EXHIBIT A Page lof5 1
HENRY 1. KAISER 5$N N5?n COMPANY e.o.sonoi Moscowamo4s m WM. H. ZlMMER NUOLEAR POWER STAflCN PROCEDURES MANUALLZPM! SECTICN: II PROCliDURE N O. PAGE n oF n ZAPO-5, Rev. 1 EFFECTIVE CATE 6-2-82 DISTROC*ICNS FOR FILLING OUT "EZ VR FCP.*! NOTE: If applicable, the follo ing infor=ation shall be provided. BLOCK 1
. Enter drawing /installatios number and the identifying nu=ber of the noaconfo ning iten. This may be the equipnent nu=ber, serial nu=ber, lift nu=ber, etc.
ELOCK 2 Enter drawind installation nas.a (self explanatory). BLOCK 3 - To be cocpleted on all purchased r.ater!. tis or sabcontracted work. Not applicable on U K site work. StoCI /. Enter supplier centractor nane (self explanatory). 2 LOCI 5 Enter inspec tion plan nu=ber (as applicable). BLOCK $ Enter laspector's name (self explanatory). . BLOCI 7 Enter date. 3 LOCI S Enter specificatioh nu=ber f ot* applicable job. Designate ASME Material Yes No. BLOCK 9 Vrite description of the nonconformance. The description of the nonconfor:ance is the nest i=portant aspect of the NR. The following guidelines shall apply l 1. The description of the noncenfer:ance shall begin with the location (building and elevation).
- 2. Enter the systen identification (D). Norr.sily tvo letters l 1.e. ES, RI, VS, MS, etc.
- 3. Require =ent. In describing the requirenent, the Inspector shall reference the specification number (or site procedure nu=ber). paragraph and require ent (or drawing nu=ber),
dinensica and tolerance.
- 4. The nonconfo ming condition shall be described in sufficient detail to allow the reviewer'to understand the condition reported. The dese:1ption of the discrepancy shall folicv the ,-
referenced requiree.ent. The Inspecter shall' vrite leg 1My l .. vith good technical style in describing ths defect. Weu l necessary for clarity, a photograph or free-hand sketch l should be referenced on an attach =ent to the NR. (See Page I for exa=ple of the NR Fort) BLOCK 10 Disposition:, The Engineer _ associated with the discipline shall enter the 2*ds "Accaptag-Is. Repair, Rework or Reject". f
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HENRY L KA/EER ZlNNER COMPANY P.O. BOX 201 MOSCOW,CHIO 4S153 Vnd. H. ZlMMER NUCLEAR POWER STAR!ON PROCEDURES MANUAL:ZPif. SECTION: II _ FHOCEDURE f40. ' PAG:. 23 OF 32 ZAPO-5, Rev. 1 EFFECTIVE CATE, 6-2-82 INS *RUCTICNS TCR F71LI?'C OU* YR FORM (Continued) l ELOCK 11 The Engineer associated with the discipline shall enter the specific instruction. Exa-ole A - Rework: Co=ponett to be forwarded to Cincinnati K111cron. Inc. f or drilling per GI letter of instruction date 3-22-72. Exzeole 3 - Acceet-As-Is: Flushing operations will provide acequate cican11 ness. Exv= ole C - Reoair: Add vent valves as specified by S&L Design f.ngt.neer. 3.CCK 12 The Material Review Board shall signify concurrence. SLL may provide preliminary approval by stamping then signing and dating their sta=p. BLOCK 13 If a new nonconferr.ance is detected at the time of the reinspection, the Inspector shall enter the new NR Number in this block and "R" stamp above the signature line. The original NR can be closed if the original condition has been corrected. If a new condition is found to be in noncompliance at the ti e of close-out, a new NR must be generated. BLOCK !!. Enter typical "cause" state:ent such as " supplier oversight" or
" grounded conductor", etc.
l l BLOCK 15 Enter a descriptive action which should be taken to prevent recurrence of the original discrepancy, not to be confused with the disposition statement in Stock 11. Typical corrective action statement for the above cause may be "This problem was coserved by the concrete pour foreman. Shift reassignments were =ade to balance the number of experienced concrete workers on off-shifts". 1 1 1 1 1 mem a ~~-c.c, m - - v
HENRY.J. KAISER 2INMER COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 WM. H. ZIMMER NUCLEAR POWER STAflOf4 PROCEDURES MANUAL:ZPM SECTION: II PROCEDURE 14 0 . PAGE 2t. OF 32 ZAPo-5, Rev. 1 EFFECTIVE 0;TE: 6-2-82
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HENRY.J. KAl.GER 2lMMER COMPA/VY P.O. BOX 201 MOSCCW.CHIO 45153 PROCEDURES MANUAL [ZPiW WP.8 H. Z!MMER NUCLEAR POWER STArlON SECTION: II FHCCEDURE N O. rAGc- 25 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE 6-2-82 R DISTRI3i' TION PRELIMI':ARY COPIES Originator Kil GCD Turnover Coordination Group Leads Report Coordinator CC&E QA Manager A??PnvED pn*CRX/REJEC* DISPOSITIONS Same as " Pre 11:inary Copies" plus the cognizant HJK Discipline Construction Engineer APPROVED ACCCPT/RE? AIR DISPOS!T!ONS Same as "Preli=inarf Copies *
- CC&E Manaaer Cenaration Construction Department (CCD). CC&E Manager Nuclear Production Department. CC&E Sponsor Engineer (NED) S&L Project Manager, and Cognizant HJK Discipline Construction Engineer (insert in work package).
t 5000 SERIES l l Same as " Preliminary Copies" Cognizant CC&E Discipline Constructica Engineer (CCD). DISTRISL*TICN ANER CLOS!0/cArcrttt3 Same as " Accept / Repair" l e i l \ l FORM NO. TFl.60/5-32/Rev. 1 E:GIIBIT A Page 5 C,f 5
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HENRY 1. KAISER ZlNMER COMPANY P.O. BOX 201 MOSCOW. OHIO 45153 PROCEDURES MANUAL ZPas! WM. H. ZIMrdER NUCLEAR POWER STArlON SECTION: II PRCCEDURE N O. PAGE 26 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82 IN-PROCESS S INSPECTION DEFICIENCY R E COFtD WORK PACKAGE
- CONTROL NO b OtSCIPUNE , b) fu TICIF' ICY DIsr0SITION '
( N9't t.T IM It g' DESCALFTION CORPECTIVE ACTION TARD8 ' ' * [, h', ACCCr1 W CJFIl ST DATE CO*NDth 5 8 5 6 6 5 8 5 5 E E
,, N FORM NO. TF466/5-82/Rev. 4 EXHIBIT B Page 1 Of 2
HENRY J. KAlfETER 2lMMER CDMPANY P.O. SOX 201 MOSCOW. OHIO .15153 WM. H. ZIMutER NUCLEAR POWER STA riCN PROCEDURES MANUAL ZPiW sg;7 ton: II PRCCEDURE f 40. PAGE 27 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE: 6-2-82
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- 1. QA Inspector Enter identification number of the apolicable worn package.
- 2. lQA Inspector Enter e nane of the Craf t (or
' other apptcpriate identification responsible for performing the work.
- 3. 0A Inspector Enter date that [he particular inspection was performed (pass or fail).
- 4. lQAInspector Enter name of the individual (Inspector) wno has detected the deficiency.
- 5. 0A Inspector Describe the deficiency.
- 6. l Construction Personnelor Describe the corrective Authorized Engineer action (s) taken to resolve / correct the deficiency.
Include as much information as possible.
- 7. 4 Construction Personnel or The individual who performs Authorized Engineer the correctise action vill enter signature here.
- 8. Construction Personnel or Enter date the corrective Authorized Engineer action was performed.
- 9. QA Inspector Enter approval stamp if correc-tive action (s) renders action acceptable.
- 10. ,
QA Inspector Enter reject stamp if correc-t tive action (s) do not satis-factorily resolve deficiency. NOTE: Re-initiate identificatien of in-process deficiency at Block 3 if unacceptable condition remains. I
- 11. s QA Inspector The QA Inspector uno has l
entered the accept or reject sta=p will enter signature here.
- 12. I QA Inspector Enter hte the deficiency correction inspection was per-forred.
- 13. qA Inspector Enter any cce ents vnich ray be approcriste or informative.
14 QA Inspector Enter the IIDR Centrol ?;urber FORM NO. TF466/5-82/Rev. 3 EXHIBIT 3 Page 2 of 2 l
HENRY J. KAINER ZlMMER COMPANY P.O. SCX 201 MOSCCW,CHIO 45153 PROCEDURES MANUAL ZPii.'
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WM. H. ZIMMER NUCLEAR POWER STAflON SECTION:II PROCEDURE N O. PAGE 28 OF 32 EFFECTIVE DATE: 6-2-82 Nn Loa CH o ..a NR 4 Description ospe= kr. S&L ANI
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- PROCESS PER WORK PACFAGE PRCCEDURE GC?-3 FORM No. TF519/5-S2/ REY. 0 E:GII3IT F
HENRY J. KA152P ZlMMER COMPANY 9.o. Eox 20, ucscow. chic 45,52 WM. H. :'!MMER NUC:,. EAR PCWER STMION ' PROCEDURES MANUALZPUi! SECT!CNi II FRCCliDunc N o. PAGE 32 OF 32 ZAPO-5, Rev. 1 EFFECTIVE DATE, 6-2-82 Beory J. Kaiser Co. Quality Eneineering n Review Draf t n Centrol i Date of Q.E. Review ( Io oc completec by tne Qualaty ingineer J- ine attacnes crat: .u r.as :een reviewed as required by procedure, and the following deter:1 nations have been cadet
- 1. ACCIPTA3LE NR DRA C O A. Requires the f olleving clarification or infor=ation frca the originator trior to processing.
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D. Potentially reportable under 10CTR21 or 10C7R50.53(e). (I.P.R.C. # criginated).
- 2. L'NACO.'.?TAELI NR DRA C This draft NR does not identify a nonconforming condition ,or is writeta in error because:
Reco end that this draf t NR be closed by the origisator. Q.E. Go be cc=pleted oy tne origtsator vnen NR dee:a1 unacceptasle by Q.E.) Agree to close draft NR as neced on NR form. Disagree that NR is unacceptaole because: I i l l Criginat:r Oate l Ford! ho. TF530/5-82/Rev. 0 EXii131T G
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_ ._ G- l. . R. 15 Idfective Dane: 3 ___ 10-7-51 . Prepz. red By: Eric ' chroeder
Title:
Lead Recor:s C rdinXfn? -7 [
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, Q, COMPLETE REWRITE 1.0 PURPOSE .
1.1 This I;onconfo ring Katerial Control Procedure is to provide instructions
.for the detailed i plementation of Quality Assurance Procedure No.16. It describes the systen for processing the Ronconformance Report fron the point of inception until it is closed. It further describes the sys. ten of reporting which provides project status of Nonconfor:ance Repcrts (1:R's).
2.0 SCOPE 2.1 Nonconforcing iters, caterial, and equip ent under the control of HJK (i.e., during Receipt Incpection, Construe ics, or after Turnover but prior to fuel load) are controlled by this procedure and by the use of the EJK lionconformance Report (NR). NE's are generated for nonconforning Material, Equipment, or itens identified during HJK First Line Inspection, Surveillance and Review of Docurentation associated with that ac-ivity. CAR's are covered in QACKI G-26. . r>
. .O P.: v.e w...., ~v S 31 QACMI G-26, " Corrective Action Reports".
32 QACMI G-29, "QA Review of Construction 'Jork Packages". 33 QAP 16, " Control of Nonconforcing Xaterial, Part, and Conponents". 34 QAP 15, " Inspection, Test, and Operating status". 40 RESPONSIBILITIES .
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4.1 The Quality Engineering Manager is responsible for the review of N5's to determine if the nonconformance requires corrective action and to determine if the condition noted on the 3. is potentially reportable under the require:ents specified by 10CFF.21 and/or 10CFR50 55e. He is also responsible for determining the adequacy of dispositions, cause, corrective actions, and establishing the inspection requirenents for NR's. i 4.2 All HJK personnel are responsible for reporting possible Nonconforcing l conditions to Quality Assurance Persennel. Quality Assurance Personnel are responsible for preparing all NR'c within the secpe of this procedure. NR's are written for either essential or nonessential itens, caterial, parts, cnd cceponents. 43 The Cognicant Discipline Construction Engineer is responsible for assuring that NR's are dispecitioned in a tisely canner and are technically acceptable.
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INSTRUCTION (gACy.I) Precared bv: QACF.I 1;o.
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. ? ace 2 cfl0 Eric Schroeder. G-4, R. 15 44 The Lead Reports Coordinator is responsible for controlling the flow, distributing End =aintaining traceability of "R's during processing and c1 seout.
45 The Inspection "anager is responsible for reviewing NR's for correctness, co pleteness, and to assure the NR is forwarded to the Lead Reports Cocrdinator in a timely =anner; normally, this is within 24 hours of the issuance of the control number. He is also responsible for identifying those N3's which fall within the scope of the Quality Confirmation Progra by placing a "Q" in the NR Number Eleck of the NR Fors prior to submittal to the Lead Reports Coordinator for processing. 50 PROCEDURE
- 5. 1 DEFINITIONS .
5 1.1 Responsible organization The Resp nsible Organization is the organization with jurisdictional responsibility for the Nonconforming condition. 5 1.2 Inplenenting organization The Inple enting Organization is the organization (HJK, CG&E,
' Supplier or Subcontractor) assigned on the NR form the responsibility for correcting the Nonconforming condition by implementing the approved disposition.
513 Nonconfor:ance A deficiency in characteristic, documentation or procedure which renders the quality of an ites unacceptable or indeterminate. Era ples include: Physical Defects, Test Failures, Incorrect or Inaccurate Documentation. 514 Nonconfnrnance Report A docu:ent which describes a deficiency in a characteristic or I pro'cedure which renders the quality of an ite indeterminate or unacceptable. 515 continuation Sheet fO V81 D I,IAd MD 8 T,/ [\ li(v 04~ l V E V v 'the4 O 8kI ! '! V3 A Continuation Sheet (Exhibit 3) is used when additional space is needed for any block on a Nonconformance Report. Note: Each block that is continued shall be started on a separate sheet with the exception of approval signature blocks which cay be documented on the continuation sheet containing the infor:ation being provided. , 5 1.6 Disposition Engineer The Field Engineer or Quality Engineer assigned the task of providing an NR Disposition, Disposition Instructions, Cause cnd
, Corrective Action.
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- EE!.*RY J . KAISER CO. "
QUA* ITY AESURA1 CI - CO::STRUC IC:: ..ITHOOE [,e7.s. . H. 2*.!'.MIR NUC' EAR PO'CR STATION I! STRUC~2 N (QAOMI) l Prepared by: L;.CMI No. Face 3 cf 10 l Eric Schroeder. T-4, R.15 i l 5 2 GENERAL P.EQUIREKISTS i 5 2.1 NR's should be written on individual ite:s such as a Manger, Pipe Spool, ISO Drawing, specific piece of Eqnipnent, etc., the intent of which is to allow each Nonconforming ite: addressed in the NR to be closed out in the same tine frame. 5 2.2 Once an UR control Number is issued by tia Lead Reports coordinator, the NR nust be processed and may only be invalidated as part of the nor=al processing as outlined in this procedure. 523 All written entries on an NR shall be in slack ink. The ink used shall not be succeptible to water streakiss or fading. 524 corrections,or changes shall be made by frawing a single line through the entry and initialing and dating near the correction. If sufficient space is not available to make the necessary correction, circle the block number and give the correct information on a continuation sheet. k'hite out and correntien tape shall not be used. Personnel =ay only correct sections of the NR for which they are responsible. 525 Processing of an NR shall be in a timely manner. If a delay in processing is expected, the Lead Reports Coordinator should be notified. 53 NONCONFORMANCE DISPOSITIONS y .!
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[ 531 Accept-As-Is - A disposition indicating that the noncenformance does not substantially affect the design, safety, interchangeability, service life, or performance, and that he caterial or equipment can be used for its intended purpose. May also be used to disposition an NR written in error. 532 Reject - A disposition that proves that the ites is unsuitable for its intended purpose and economically or feasibly incapable of being l reworked and repaired. 533 Repa ir - A disposition which permits the reprocessing of raterial to bring it into an acceptable condition, although it still departs from original design requirenents. (Repairs to ASKE Section III ! items nust co ply with all of the Code Requirenents.) 534 Rework A disposition that a nonconfor:ance can, through subsequent part. replacement, reprocessing, or completion of the required operations, be brought into original ecnformance with drawing and specification requirenents. NOTE: Only " Accept-As-Is" and " Rework" dispositions are l appropriate for documentation NE's. t 54 AS!G SECTION III CODE ITEMS, KATERIAL AND EQUIFKENT 541 For Ucnconforming iters, naterial and equiptent' designed and fabricated in accordance with the requirenents of the ASME 3siler
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- the items, caterial, or equip ent inte conformance with Code l require ents.
The Quality Ad inistratien Manager or his designee shall coordinate the review and approval of " Accept-As-Is" and
" Repair" dispositions for reconciliatien s-ith the Design Specification and cc pliance with the Code. All Code related NR's shall be reviewed / approved by the ANI after dispesition. The ANI cay also establish and identify Hold points at this time.
55 INITIATION OF THE NR 551 A Nonconformance Report shall be initiated in the following instances: 5 5 1.1 Wh,enever a plant material, piece of equip:ent or portion of construction work deviates frc: the specified technical limits of a drawing, specification, code, standard, procedure or an approved Inspection Plan. 5 5 1.2 Whenever certified test results deviate from specified requirements. 5513 Whenever a process or activity places existing plant systems or equipment in an indeterminate condition. 5514 When a piece of equipment or installed =aterial has been damaged. 5515 In cases where required documents are not available and a Document Deficiency has failed. 5 5 1.6 In the absence of a clearly specified Accept / Reject standard, whenever an observed conditien of a plant caterial, piece of equipment or portion of construction work is a substantial deviation from what is considered the Industry Standard for Acceptance. 5517 CG&E Quality Assurance or Engineering Personnel may direct the initiation of a Nonconfor:ance Report by identifying the Nonconformance to an HJK QA Inspector. The HJK Inspector shall initiate the N2 as indicated in Exhibit 1. Under description, the HJK Inspector shall start with "as noted by (give name), of CCdE" and then continue with the Konconformance description. The KR shall be processed as per this procedure with the exception that the requesting CG&E Inspector / Engineer shall be placed on distribution by the Lead Reports Coordinator. 56 PROCESSING NR's e 5 6.1 When a Nonconfor:ing condition is identified, the HJK Inspector shall fill out the NR Form (Erhibit 2) following the instructions of Erhibit 1.
t . HI:.7.Y J . }~.A;SER CO. QUA I.rY ASSURANCE - CONSTRU~~IO!: .uI7dCDs } W.. M. :'Lu. MEA NUC~EM PO'CR STATION INSTRUCTION (QACMI) Pre.c?_ red by : gACMI No. Page 5 ef 10 Eric Schroeder . G-4, R. 15 5 6.1.1 If the process or activity needs to be i=cediately halted,
' the inspector shall obtain a control number frc: the Lead Reports Coordinator and place a Hold Tag on the nonconfor:ing ite: referencing the control number on the tag with a brief description of the nonconfor:ance.
5 6.1.2. NR's written on Essential Systems /Co:ponents shall be given an "E" prefir number. 5 6.1 3 NR's written on Non-Essential Systers/Co=ponents shall be given an "N" prefix number. 5 6.1 4 NR's written reporting a seismic violation between systems or components shall be ~given a' 6000 series number. 5.6.1 5 NR's written on.Syste:/Subsyste:/ Area that has been turned over for pre-operational testing shall be given a 5000 series number. - 5 6.1.6 All CGiB NR's are processed in accordance with CG&E procedures. Those 7000 series NR's already in the HJK NR System shall remain so until closed. 5 6.1 7 NR's written as a result of the CG&E Quality Confirmation Program shall have their nusber suffixed by the Letter "Q". 5 6.1.8 There cay'be instances where a Nonconformance Report has been initiated in error due to interpretation or judgment of borderline conditions, duplication, or where a nonconforming condition has been corrected by the Construction Department after a verbal or written consunication from the Quality Assurance Department. In these instances, cancellation of the NR sust be approved by the HJK Site Quality Assurance Manager and the CG&E QA Manager. After'this approval, the NR shall be stamped,
" Cancelled". A statement indicating the justification for being cancelled shall be recorded on the' attached form (Exhibit 6), signed and dated by the QA Managers. 'A corresponding entry shall be made next to the control number in the NR Log. The cancelled NR and the justification for shall be distributed in accordance with (IAk') Erhibit 4 The originator of the NR shall remove the tag when the cancelled NR copy is received fro d***"i""** =-
70R MFORMATION ONLY (A) Personnel recuesting an NR be superseded or cancelled shall do so in writing, stating what is to be done including a justification, signed by the cognizant superintendent or canager and forwarded to the Lead Reports Coordinator. 5 6.1 9 If the originator of an NR determines the NR was written in error, prior to the NR being dispositioned,.he/she may ,I
- initiate closure of the NR as follows:
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HI::~;.Y J . KAISIR CO. QUA'.I- y ASSUR'.! CE - CO: STRUZ.* O ; ." .TdO'.:S W. . M. 2:_u.v.IR 1;*JO.* IAR PoiiIR STATION I!?STRUC-';O!: (CACMI) Frepared by: CAOM2 I;0- Pe?e 6 of 10 Eric Schroeder G-4, R. 15 s (A) Enter justification for closing NR in the disposition instrue: ions section of the UR as follows:
"This NR was written in error due to the following:"
Exa ples Include: , (1) Inspected to incorrect drawing and/or accept / reject criteri'a. (2) Inspected wrong conponent. (3) Misread neasuring and test equipnent. (4) Eisinterpretation of requirenents.
"Reco cend this NR be dispositioned Accept-As-Is".
(B) Sign and date the for= for the above entry - this cust - be the originatcr - any other persennel shall process an KR to be cancelled per para. 5 6.1.8 of this procedure. (C) Obtain concurring signatures for closing the :<R as indicated in para. 5 6.2 thru 5 6 5 (D) The NR is then forwarded to the Lead Reports Coordinator for nornal processing per this procedure. 5 6.1.10 nen a KR is to be revised, because of change in . disposition cause or corrective action, the NR shall be stamped " Superseded by Rev. Ko.",.and signed and dated by the cognizan: EJZ Discipline Quality Engineer. The superseding NR shall retain the original N?. number and shall indicate the next revision number. 5.6.2 nen the inspector conpletes the KR forn, the inspector shall present the form to the cognizant Lead Discipline Inspector who shall review the NR for conpleteness, adequacy, and appropriateness. The Lead Inspector shall initial in block 6 indicating his concurrence. 563 Other individuals may perfe.m a review for correctness, adequacy and appropriateness as deternined by the Cognizant Lead Discipline Inspector. 564 nen the reviews are conpleted, the NR shall be forwarded to the cognizant Discipline Quality Engineer (D.Q.E.) to review the NR for technical adequacy and accuracy. The Q.E. - shnll also indicate his approval by initialing block 6 of the NR. 565 n en the 0.E. review is conplete, the Q.E. shall fo., card the NR to the Lead Reports Coordinator for proceccing. FOR IMPORMATION ORLY
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Precared b.v: QAO".1 No. Eric Schroeder - G-4, R. Pa9e- 7 of_10 15 5 6.6 Nhen the Lead Reports Coordinator receives the NR, he shall assign the NR a control nu ber (if not already assigned fro: para. 5 6.1.1) and an NR number from the NR Log (Erhibit 3). 567 After the NR is logged, the Lead Reports Coordinator shall distribute copies of the NR per Exhibit 4 and forward the original HR to HJK Construction Engineering for dispositioning. The Lead Reports Coordinator shall also etter the NR on the Computer Status Report. 5 6.7.1 When the originator of the NR receives his/her copy fron distribution, the originator shall initiate a yellow " Hold" Tag, orange " Deficiency" Tag, or white " Seismic Violation" Tag noting the NR Number and a brief description of the nonconformance in the remarks section of the tag. If the nosconforcing iten or condition requires that the iten be segregated or further use/ installation be terminated, then the Inspector shall apply a yellow " Hold" Tag. If the nonconforcing ite or condition does not require segregation or that the use/ installation be terminated, then the Inspector shall apply an orange " Deficiency" Tag. If the nonconformance is a Seis=ic Violation between systens or components in Seismic Category 1 building's as defined in the specifications, the itens in violation shall
- be identified with a white " Seismic Violation" Tag. The Tag is "R" stamped and then affixed to the material, equipment, or work in a conspicuous area. All inspection documents are to reference the NR Number and "R" Stamp.
The Inspector notifies the Cognizant Superintendent for the purpose of quarantining =aterial as necessary.
- UOTE: A description of the tags authorized for use by the HJK Inspection Depart ent is found in Quality Assurance Procedure (QA?) 15 These tags are to be applied o'r removed only by HJK QA.
5 6.8 When Construction Engineering receives the original NR, they provide a Disposition (as indicated in Section 5 3 of this procedure) in block 10 of the HR For:. Additionally, Construction Engineering provides Disposition Instructions in block 11 (explains how the disposition is to be implemented), Cause in block 14 (explains what caused the nonconforcing condition), e.nd Corrective Action in block 15 (explains what is proposed to assure the cause is not repeated). The Construction Engineer signs and dates the space provided on the for . The Censtruction Engineer then forwards the KR back to the Lead Reports Coordinator. 569 The Lead Reports Coordinator shall, upon receipt of the NR, update the NR Log and the Co puter Status Report. 5 6.10 In the corning of each working day, the Lead Reports Coordinator shall forward copies of NR's dispositioned the previous day to members of the Material Review Roard (ER3). _ _ _ . .. ?OR !WOQOM OM
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Pre.nared h.v: QACMI NC-Eric Schroeder Pa9e- 6 cf _10 G-4, R. 15 8 5 6.10.1 Kenbers of :he ER3 for Repair or Accept-As-Is dispositions
. are:
(A) Sargent and Lundy (SEL) (3) CG&E Huclear Enginesring Department (NED) (C) CG&E QA - (D) HJK QE (E) AMI (if code related) (F) HJK Construction Engineering (G) CG&E Ruclear production Dept. (NPD) For 5000 series HR's only. 5 6.10.2 Members of the ER3 for Rework or Reject dispositions are the sane as for Accept-As-Is or Repair with the exception of CG&E NED and.S&L. 5 6.11 In the afternoon of each working day, a meeting consisting.of the nesbers of the ER3 nay be convened by discipline for the purpose of
' approving the Disposition, Dispositien Instructions, Cause, Corrective Action, and cetermination of reportability per 10CFR21 and/or 100FR55e. The Lead Reports Coordinator shall forward the original UR's dispositioned the previous day (and those not approved in the previous days meeting), by discipline, to the cognicant Discipline Quality Engineer attending the meeting.
5 6.11 1 For those NR's recuiring ccrrective actions which need to be verified, the cognizant Eiscipline Quality Engineer shall initiate a Corrective Ac. tion Report (CAR) per QACKI G-26. 5 6.12 When the neeting is adjourned, the Q.E. shall return the original ER's to the Lead Reports Coordinator. 5 6.13 The Lead Reports Coordinator shall update the NR Log and foraard those ER's written as a result of the Quality Confirmation Progran (Q) to the URO for their review. i 5 6.14 When the "Q" NR's are returned to the Lead Reports Coordinator by th'e NRC, the coordinator shall update the KR Lcg and make distribution of the NR's (including those NE's which were no "Q"). (See Exhibit 4) Distribution shall not be performed until the NRC concurs with the Disposition (see Flow Chart, Exhibit 7). 57 CLOSE-0UT OF KR's COR INFORMATION ONW 571 For approved Accept-As-Is dispcsitioned HR's, the originator shall remove the appropriate tag (i.e. Hold, Deficiency, Seisnic) frc: the nonconferning ites and place an Accep -As-Is tag on the iten after r- - - -- . ,.. . _
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w.is 3.Onen- .e m. - - , Oh, - .nw S . . . v,, . .. O.o- . nu - m .- Procared b.v: 9' O.". No. Pace 9 cf -10 cric Schroec.er G-4, R. 15 s the KR is received froc distribution. The Lead Reports Coordinator shall sta:p the approved Accept-As-Is .'iR " Closed" and forward the NR to the Documentation Manager for retention as a Quality p.ecord. 572 For approved Repair or Rework dispositioned NR's, when the origina:cr receives the distributed NR, the inspector shall place a Rework / Repair tag on the nonconforming iten. When the work is perfor:ed, the inspector shall verify the work was performed IAW the dispositioned instructions and the applicable.requirenents (i.e. - codes, drawings, specifications, procedures) and, when acceptable, the originator shall rencve the tags and sign the block 13 of the original KR retained by the Lead Reports Coordinator. 573 For approved Reject dispositioned NR's the originator shall place a Reject tag on the item. 574 The disposition instructions may require nore than one organization to perform or witness a Test / Inspection of an iten. In this' case, a signature verifying acceptance by each organization is required. NOTE: In the case the originator of the HR is not available to perfor the verifications of para's. 5 7 1, 5 7.2, 5 7 3, an individual within the cane QA group =ay perform the verifications and sign the original NR.
'5 7 5 When the verifications and NR form rign-offs are completed fron para's. 5 7 1, 5 7.2, 5 7 3, the Lead Reports Coordinator shall update the NR Log, stamp the original NR " Closed", =ake distribution (See Erhitit 4), forward the original ER to the Site Document Center, retain a copy of the closed NR and update the Computer Status Report.
55 DISP 0SI"' ION DISAORIEMEICS E02 NOM,GON ONI.Y 5 8.1 In the event the originat'or disagrees with the appropriateness of the disposition or cancellation, the channel for, resolution shall be as follows: 5 8'.1.1 The originator submits an inter-office neto to the Inspection Manager stating reasons for the disagree:ent. 5 8.1.2 The Inspection Kanager will review and provide resolution to the inspector. 5 8.1 3 If the originator is not satisfied with resolution provided by the Inspection Manager, the originator may request reconsideration by subsitting an inter-office ne=o to the HJK Site QA Manager requesting reconsideration, with a justification for the request. 5 8.1 4 The HJK Site QA Manager shall provide final resolution of the request to the originator. Copies shall be forwarded to the CGiB QA Manager, HJK Director of. Quality Assurance
, Progra:s, and HJK Yp-power Division.
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p e .,ar e d m' .' . 9EC".I 1;o . tage 10 cf 10 ) Eric Schroeder G-4, R. 15 t 59 NR STATUS REo0RT 591 Records of ::3 status are retained by the Lead Reports Coordinator and a tabulation published and distributed weekly and conthly. The NR Report includes the following information: 5 9 1.1 F. aster NR Report - Numerical listing of all ::R's. May be sorted by systen. - 5 9 1.2 Open NR Report - Numerical listing of all open NR's. F.a7 be sorted by systen or disposition code. 5 10 QUALITY ENGINEERING REVIL7 5 10.1 Quality Engineering, in their review of NR's, shall assure ths.t they have not been cancelled or closed by the issuance of a Design Document Change (DDC). 6.0 EIRIBITS 6.1 Exhibit 1 - Instructions for Filling Out the NR Fors (2 pages) 6.2 Exhibit 2 - KR Fort . 63 Exhibit 3 - NR Continuation Sheet 64 Exhibit 4 - NR Distribution 65 Exhibit 5 - NR Log 6.6 Exhibit 6 - NR Cancellation Forn 6.7 Exhibit 7 - NR Processing Flow Chart E0g1MFORag10M m OME
. EXHIBIT 4 _
Audit Report No. MA-82-1 FOR !!GORf!!ATION ONLY 1 SD1I-ANNUAL MANAGEMENT AUDIT REPORT OF CINCINNATI" GAS & ELECTRIC COMPANY l 4 WM. H. ZIMMER NUCLEAR POWER STATION
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Audit Conducted: April 19-26, 1982 7 Audit Report Submitted: May 21, 1982 l i
- Prepared By
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?OR ",M?ORMATION OMDI TABLE OF CONTENTS PAGE/SEC Audit Dates . . . . . . . ...................... 1 Auditors. . . . . . .. .. ..................... 1 Individuals Contacted . . ...................... 1 Introduction. . . . .. . ...................... 2/1.0 Audit Surnary . . . . .. ...................... 3/2.0 Audit Details . . . .. . ...................... 5/3.0 Attachments: Appendix A - Audit Finding Reports (AFRs)
Appendix B - Completed Checklist Questions i i 1 1
( THE cINC1taaTI GAS & ELECTRIC CC.T.PANY AUDIT FitoIN3 REPmT c/ AuDi 0A, Sly 4ATURE/ I rc i v i ouAL/ ORGAN I ZAT I CN CONTACTED AFR NUMSG AUDIT CAT
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i / %1. ' RECOMdCED CCF.RECTivE ACTICS ff 7K, s/taff dgdg;d,ttd. At 4,R of l.D n4ain ca~d sLdd LWy ad wdds (bc dkb EEb21 &% uad1i cbea. w k a id gala. SCHEDULE RESFCNSE DATE RESPONSIBLE FCR CORRECTIVE ACTICN (1) CCRRECTIVE ACTION TAKEN Ato RESULTS ACHIEVED ( 6 F011[E0ilfMT!ON ONI.Y i M
i l
/ 1 THE CINCINNATl GAS & ELECTRIC CCMPANY AUDIT FINDING REPCRT i (2) CCARECTIVE ACTION TAKEN TO AVOID FURTHER NC?CCMPLI A?CE
? -
1 l 1 l (3) DATE W EN rLLL CCMPLIA?CE WILL BE ACHIEVE 3 SUBMI 6 4 c.3 EY DATE MANAGEMENT AF RCVAL DATE AFR VERIFICATION l i N .. 1 s - N kl n t 3 i . FOR INFORMATLON ONLY
?
I 6 RESFCNSE YES AUDITCR DATE M:Ju.GEMENT AFFROVAL DATE
' ACC EPTA BLE 4
O NO PAGE 2 Cr 2
THE C INC itituTI GAS & ELECTR IC CCHPANY AUDIT Fl? DING REPST
~jfA AUD I T D'1 S I Gt4ATlfiE/ I PQ l V I DUAL /OR G AH l ZAT I CN C ONTACTED AFR tc,HScR AUDIT CATE ATt INITIAts I f.E8d'~(k.lEE8 E.P.hlCMot/N7,it s? 6 +/' b3lJa aerERE.:E 6y' rg i:n.eadwa. zMe )
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M,d-4~ A ,M sj r6/a 1.u . ud RECOM.EtCED CCF.RECTivE ACTION //78 .-.* I'M Mwd f e /' /b f u ,u-p sf z r P 2 k 6 s a-/ .z~rDia L ' a,A k W* shab 'nsay}m m um ~Qbodh. M . d-J /w M 2
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_tu!- w,,c asD2v Ll<d- l, SCHEDULE R$5FONSE DATE RESPONSISLE FCR CGERECTIVE (SCTICN. re. M m EN A, I (1) CCRRECTIVE ACTICN TAKEN APO RESULTS ACHIEVED 1 i l i l U l FOR IMFORMAIl0N ONLY ! (PAGE 1 CF 2
c _- THE CINCINNATI GAS & ELECTRIC C0KPAtif AUDIT FINDING REPGT i I, (2) CORRECTIVE ACTION TAKEN TO AVOID FURTHER NO.'CCMPLI ANCE h i (3) DATE whEN FULL CCMPLIA?CE WILL BE ACHIEVE 3 DATE MANAGEP.ENT APFROVAL DATE SUBMITTED BY AFR VER IFICATICN
~
s '
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! ?OR NFORMATION ONLY i
DATE PMGOENTAMUM M RESFCNCE YES AUDITCR
' ACCEPTABLE . 5_ . __ _ ___ _ _ ?_ __1 . :
QUALITY ASSUllANCE AUDIT CllECKLIST CINCINNATI CAS & ELECTRIC COMPANY AUDIT NO. MA-82-01 PAGE 26 OF 4G ITEM REFERENCE COMMENf [g h
- 44. Review Task Force Communiques and determine Reviewed Task Force Communiques and verified X extent and authorization for usage where QA that in almost all cases these communiques Program Procedures are affected, are being used for their intended purposes and are not al tering QA procedural require-ments.
'5.
+ Review IlJK and CC&E IIDR documentation and Reviewed llJK Procedure ZAPO-5, Rev. O, for determine extent and authorization for requirements relative to use, document'ation, usage where QA Program Procedures are and disposition of IIDRs. Section 3.2.1 affected. (2nd paragraph) refers to IIDRs and usage.
. States that IIDRs are applic'able to
" deficiencies that are corrected in accor-dance with approved procedures."
IlJK IIDR 2041 (llangars), Deficiencies 4 and X 6 required revision of DDCs to correct drawing for acceptable corrective action, which violates system for IIDR usage. IlJK procedural requirements and program X - controls for usage, documentation, and disposition of IIDRs is not adequate. As many as 6 and 7 deficiencies were being FOR INFORMATION ONLY 21swd -aer eeeu ton nemuer eo the some form. See APR No. 82-1-6.
~ ' '
( ( EXHIBIT 5 . l
.- ~
l 4
-q n. - . l D: H. Villiams .
Nove:.ber 30,197f> 1s3 16 -
- l C, .
. E. V. Enox YB 16 ~
. . +
Telethene Conversatien with Bill Schwiers en 11 /29/70 .
. + ,
. Bill Sci aiers of CGC enlled ce this cornin:; and it was ot vious from the questions and concerns that he expressed that he was trying to determine ny degree of cupport for Bill Friedrich. Mr. Schwiers '
concerns were: e
- 1) N?.C nuilt ite*3 vhich found " Installation inspetica pocedures had not been estchlished which would verify confernance to pro-visions established in design doct=ents". This pertained to conduit hangers and bonding to the station grounding systs=.
Mr. Schwiers was also concerned that l~siser Engineere was perfor=- . ing design calculations to deter =ine vbich was the peper hanger to use.
~
- 2) Cher.: es in cus11tv issu-ance Tersennel. Even though Mr. Schviers h
' adnitted to being infor=ed of the chen;;ec (Kaser and MacI. cur,hlin) he indiccted he had not given his specific appoval. He slao .
~
> coe=ented that the Zi:=er job was not a place to put people that ca:e and go to other pojects or c=ployers.
- 3) X-Pav of 'Jronr Weld in Centnin=ent. I do not kn:2 the full ctory .
on his but Schwiers indicated that the cistche was c. aught. Because of this, he suspcets other veld x-rays. He has requested that CGS be put en distribution for all x-ray render-sheets and stated that an indepndent review was going to be made by CGE or their repre-nentative. h) Accert-ns-is decicions on veld . defects. 16. Schwiers cade the statc=ent that Kaiser Quality personnel alone vcs taking "cceept-es-is" decisiens en veld defects and in so..e cases was ovorriding
" reject" decisions cade by the x-ray lab Nrsonnel. Accept-as-is .
decisions are controlled by proceduro, QAP #16. It requires a MRB det:ision by th6 CGS QA Engineer, KII QA Engineer, CGC sponsor Engineer, and when required the SM, Engineer, s < ..
- 5) Anni =:.ent of Civil Inst-tors. Mr Schviers expressed cencern over Kaiser .'agineers still having 3 civil inswetors accicned to the job. !!c felt thic could be reduced to one, and the othr:r i
tvo replaced by techanical or electrical ins p etors.
, I* =
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4
*? .
, . p,n, willic=s Nov. 30, 1976 C '
6) Loente Yaiser & CG E Quality perronnel torether. Schviers ' cc==ent was that since CG?.2 had the final re p:nsibility for the quality of the plant and the fact that CGE and Kaiser should be striving towards a ec==on goal of building the plant to the drawings and specifications, it see=ed to hi= that a benefit could be achieved by being physically located together
' making it easier for he and his people to be kept infor=ed of
- day to day activities.
- 7) Have Insrecticn Persennel Retort to'Censtruction. hir.Schwiers expressed his opinica en organization that inspection perscnnel should report to Construction Engineering for centrol and Quality
, . Engineers should audit and surveil for assurance that things are
.donc properly. ,
My cc==ents regarding the above were: ,
- 1) NRC Audit Ite=. This will be looked into to deter =ine the '
reason for not having an inspection plan during the' hanger ,- installation.
- 2) Chances in OA Personnel. I feel we have the* responsibility to
( staff the job a required and unless we previously had agreed ~ to obtain CGE approval when changes in personnel occur, I see
- no reason.to obtain their approval for changes in personnel at
- this level.
- 3) X-Ray Wrene Weld. This one error was caught. (There are =any checks and balances in the QA cyste=). We should not =ake the .
whole velding operation suspect because of it. This is vitch hunting at its worst and can only hurt CGE's Zi==cr plant in the eyes of URC, anti-nuclear personnel, etc. - 1)6 Accert-as-is decisions. I doubt very much that we are violating the IGB procedure 'as outlined in QAP #16, but I would be interested in Bill Friedrich's ce==ent. -
, 5) Assicnzent of civil increctors. Another case of CG E trying to tell Kaiser Engineers how to canage the job. .,
- 6) Kaiser and CCE OA Perconnel located tocether. This vill not work and I told Mr. Schwiers it wouldn't. My argu=ent va that Kaiser Cuality rerconnel would not know who was callin- the shots, that there would be confu ion as to ancien =en; c: reston:-
ibilities a.qd_tnat there A ule ce a great tendency and verv N:7
~ '
for CGE personnel to direct Bill ffic'dFiEIPs. peTp3e to do unscF.c~?.uled' activitics that do no: cuppbE'YtGT~pFEdE. Esc hedule. ( - e .. e
- e d
( .
~
.' . (
.s D.11. Willic=s . -3
.- Nov. 30,1976
( .* 7) Inr.rection rerertir.g to Cenetructich. I di: agree'vith this type of an organi:stion and so doe: ICCFR50, Appendix B. . I acrced to have a meeting on Decer.ber 9th with Bil'1 Schwiers to
, further discuss his concerns about our Quality Assurance program.
This hcs since been changed with our phone conversation with Don . Sahlberg and Bill Friedrich. - EVK/dsr ., . . , l (
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- 70R INFORMATiON ONil pbf2%
'EXIIIBIT 6 -
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r.1 EXHIBIT 7
,i ...yc.w n.
( ,d h j W b.,r.tq (n.. 2m uu y st.U..N. eu HENRY _f. KA/5ER outun 4:susAuer Pacerouas no. 16 arv. 9 COMPANY , . -
~^.I P.O. BOX 201. t/.OSCOW. CHIO 4515'?, - '
6-18-E2 PAGE l CF 6 QUALITY ASSURANCE f/.ANUAL PRIPARED BY: . -
"2 ,,
d[hh m sa y. g . n-q.
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m ._ g . CCN 7.0L OF NONCCNTO?CNG W- ~ *.'.L. ,,p p,ov g y f(, / p g g gg;
'Diree.dct cw iny Assurance <
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CON 0uRRED; / g7' / / # ,9-
. V. / o te Pres.oem - Pef er i
1.0 PURo0SE , 1.1 To de' scribe the p ocedu e for cont elling pa-ts, materials, components. appurtena ces, activities, records er p=cedures that are not in conic mance with specificaticns, crawings cr purchase cocuments. 2.0 GENERAL REQUIREMENTS' 2.1 No conic ma ce Reports shall be initiated by perscnnel assigned to HJK Cuality Assurame Department and p= cessed in a Oc dance with aspreved procedu es. Any C :nizant HJK Persennel may identify a nom:nferming co-tition and recuest the NR be initiated by the HJK QA Department. 2.2 An In-Prc ess Inspection Deficiency Re:Ord (IIDR) shall be used only to p recc:d deficiencies in const uction wc:k identified up to and including the a j
' final inspectica. IIDR's shall be prc essed as a par,t of the wc k package 9 in acec-came with a:p;cved procecures. ~
2.3 Procede al violations that have no affect en materials c: equipment will be cccumented en a C ::ective Action Request-(CAR). CAR's will be written by Quality Asse a ce personnel and approved by the HJK Site QA Manager prior to issue. Ccr e tive action commitment shall be app cved by the HJK Site l CA Manager. An in ex leg showing the status of CAR's shall be maintained l b.v the CA A:minist Etion Manager.
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..u..e.n.1y. _<ce_.. _.. <,4.. . w.4.h. c-Holc Tag, c: Deficie cy Tag, to av id inacve-tent use or installation.
25 Cer e:tive a::icn' cn recurring cistre amies will be reviewed and analyzed by the HJK Cuality Engineer responsible fcr the department in cuestion. Af ter such analysis is nace, the Cuality Engineer will re?: the fi.cings to the HJK O',.:ality Assu ance Manacer fcr initiatica ci a CAR if ceemed necessarv. . . we
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A. PROCEDURE
No. 16 9 2 op_ 6 REv. Pact .
.. i
._ n 9./ r.- . h t.' . ~ . .'. c -....- .. ~~ .a. Ra., ~-.' w_i _' _. ' ha. _i 'w' ..= ~.'. 4 '. _4 = c bv , ts'.:. t.' . ..." . . = .- c .7d. c ~. . a.d .o a s *u o safety relatica status. Essential er Safety Rela ed N;ntonic man:e Rep :ts will be prefixec by an "E", and NOnesse .tial N Z nfC mance Reports will be prefixed by an "N". ASME will be marked cn the NR where applicable.
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disposition. . 9 3.D DEFINITION C TED.uS
3.1 ACEPT_AS_lS
A Disposition indicating that the nonconforma.ce does not acversely affect safety, interchanceability, service life, peric::an:e c: ASE Code recuirements; and that the material can be used fc: its intended p' trpose. 3.1.1 Dn ASE ' Code Accr;bt-As-Is Dispositiens where stress analysis is
- requi ed, the disposition must be supported by a statement frc a l Recistered Professional Engineer stating, "This dispcsition is 4 c , .=,s'.cb_1. - e c- . ."e _' ,. c. --. c . wc ~. ..- a wi'h .c.. ass P.a~-. .gv Nc. xxx". l 3.1.2 ta's cispositionec "A::ept-As-Is" must be app oved by the Material.
. Review Eca-d.
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placement, reprc:essing er completion of the receirec. cpe aticas, be brought into conforma ce with drawing and specificatica receirements. 3.2.1 ta's dis siticned "Rewcrk" must be a proved by the MJK Cuality & Engineer, the CGEE Quality Engineer, and the HJK Dispositiening 9 Engineer. -
3.3 REPAIR
A Dispositica which pe mits the repr0:essin; cf material, c.,.,.r,.. .. . o.c. .~.. a. s , -c.~w pc--*= **
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run solueiliDhi DNLY l 1 HENRY J. KAISER CO. Q.
A. PROCEDURE
No. 16 nev. 9 pact 3 cr 6 i
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3.5.2 -CGE NED a.-d/or S&L shall review and approve NR's cispositiened i "A::ept-As-Is" and/or " Repair" which cc:ument violations of the cede l (ASME, AWS. etc...) or S&L specificatica. NR's which cc ument only ' violations of site procedures and -not a code c: S&L specification
, need not be reviewed ano approved by S&L and/or NED.
. 3.5.3 The fina1 disposition decision of the Material Review E ard shall be Unanimous.
3.5.4 The HJK QA Acminist:stion Manager or his representative shall
, coordinate activities to at:cmplish Material Review Ecard Actions. f.
3.5.5 All ASME related tC-l's shall be reviewed ard signed by the ANI.
~
3.6 FINAL INS?ECTICN: Achieved when applicable HJk and CGEE QC inspections are complete and the CIP (or 'other similar document) is steeptance stamped and/c: initialed as required, and transmitted to Quality Engineering by the QC Supervisor. L.0 PROCEDURE , 4.1 NONCONFORMANZ REPORT (FIGU:.E 16-1) .
'~~
4.1.1 A Nonconic =Ence Rep :t (NR) shall be initiated by.the HOK
'- Originate: when material or items do not conic:m to d: Ewing, lp6 specification, purchase documents or ASME Code' requirements.
4.1.1.1 The Inspect : shall obtain a control number from the Administration kanager and enter the number on the NR and the applicable inspection planning cocument. 4.1.1.2 The NR shall be reviewed by the Lead Inspectc and the discipline Quality Engineer fc: completeness and reportability in accc: dance with 10CFR50.55(e) and 10CFR21 $ before further p ccessing. ( 4.1.1.3 The ihspector shall assure that the mater' i al c items are t cles:1y identifiec as acn:cnfermin by atta:hin; a Hold Tag, c: Deficiency Tag and physically segrecating c: isolatin; them whenever possible. 4.1.1.4 Where n:ne:nferming material c: items are found during installation and where physical se;:egati:n is impractical, it shall be icentified with a Hold Tao. The NR and l Int?e : ion Flan shall be used to iceniify the j nonconformance and the location of the item. 4.1.2 The NR shall be presented to the applicable Discipline Engines: c l . SiL Desien Entineer'fc recommendin: a dis;0sition of Rewc:k,
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CIE Repair, Ecce:i-As-Is c: Reject. If the NR ide..tifies a 0:ncitica l which HOK's Quality Assurance Departmen: is resp:nsitie fc: N cc:::::in; (f:: example, pers:nnel cualifications, purchases fr:m e j ' fa a l_ .1 ' i a:p::ve:/dna::::vec ven:::s, e::.), than the NR may be cispositioned ' li-
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k_ - ty an :-CK'Ciscipline Cuality En;ineer.
FOR RFORMATION ONLY . HENRY J. KAISER CO. Q.
A. PROCEDURE
No. 16 ngv. 9 pucg 4 or 6 g _a . 4.1.2.1 For Rew: k dispositien, the Dispositionin: Enginee: lh' ceremines the metnod of rew :k and writes this method on the NR, signs the N nconferrame Report, and obtains recuired app:cvn1s. 4.1.2.2 For Reject disposition, c .spesitioning Enginee will R lg
. enter a technical justification fc: the disposition, sign the N nconforma". e Report, and cbtain required app ovals. , ,
4.1.2.3 For Accept-As-Is dispositions, the Dispositiening Engines: k enters a technical justifica:ica fe the ree nmended- l9 dispositien, signs the Nomonic=arce Report and obtains approvals.
~~
4.1.2.4 .For Repair dispositica, the Dispositioning Engineer
~
.S determines a repair p ccess, enters the rece:me-ded repal: 9 process on the NR and obtains required approvals. .
4.1.3 All documents associated with rewc k c: repair, if they involve ASME % items, will be reviewed with the Authorized Nuclea- Inspectc so that he may establish hold points as he deems necessary. 4.1.4 Upon verificatica that the rework, repai or reject dispositions of ft the item have been ECO : lished as specified by thi NR dispositica, q
'- the NR is signed off by the HOK Originate:. : ;
4.1.5 The resp:nsibility fc: dete=inin; the a :eptability cf cc::ective a tica fc: all nemonic mam e rests with the HJK Discipline Quality Engineer; and is ba' sed en his judgment relative to the cause, sericusness and frepuency of the ncrconformance. The cause of the non:cnic mance and the cc:rective action to prevent the cc-dition from recu rino are entered by the Dispositioning Encines: and N reviewed an: a:p:cvec by th:se reviewing and approving the o dispositicn. I 4.1.5.1 Nerconformance Rept:ts fc: recu ring discrepancies will be revie~wec and analyzed by Quality E .;inee-ing. After such analysis is mace, the Quality Engineer will rep::t his
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P.-.--=.'4.. 'e u '65e-acticn. If ceemed necessa y, a CAR shall be initiated. 4.1.6 Distribution of N monft mame Rep ::s shall be ma e to a cistributica list by the A minist:Erien Mana;=r/ : his cesignee.' The ANI shall receive copies ci p eliminary and final NR's. 3.3./ n
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A. PROCEDURE
Nc. 16 arv. a 5 op 6 HENRY J. KAISER CO., PAGE
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y -*. 4.1.B. Records will be retained en all nonconferming items, indicating ultimate disposition of the items. The original copies of Nonconfermance Reports wnich have been given centrol numbers shall be maintained as permanent records.in'.the Quality Records Center. 4.2 Iri-Process Inspect.icn Deficiency Record (Figure 16-2) 4.2.1 An In-P'r'ocess Inspection Deficiency Record (IIDR) shall be initiated by the cognizant QC Inspecter when a deficiency in cons.truction werk is discovered up to and including the, final inspection. 4.2.2 The inspector shall obtain a control number for the IIDP, frem the QC Manager, or his designee who shall be responsible for maintaining a log of IIDP, Centrol Numbers. _. 4.2.3 The IIDPJ'shall be ' processed as part of the work package in accordance with approved precedures. . . 4.3 STOP WORK ORDER (FIGURE 16-2)
- 4. 3. 1 Cognizant Henry J. Kaiser. persennel pe responsible for notifying the Project Manager and the Quality Assurance Manager of any conditions which may form the basis for a Stop Work Order. -
' 4.3.2 Step Work Orders are used to terminate construction werk activities, which, if continued, would have a serious adve'rse affect on the quality of a system er component, or on the Quality Assurance Program. -
4.3.3 The HJK Project Manager has the option of issuing a Stop Werk Order and he shall be responsible for assuring that the condition has been , adequately corrected before removing the Stop Work Order. 4.3.4 The Quality Assurance Manager has the option cf issuing a Quality Assurance Step Work Order that halts the activity until the condition is satisfactorily corrected. In this. case, the Project Manager shall 'be responsible for acknowledging th'e Step Work Order and for preparing the Request for Release section once the condition noted in the Step Werk Order has been adequately ccrrected the QA Manager shall verify that the conditions causing the stop werk have been resolved. 4.4 CORRECTIVE ACTION REPORT (FIGURE 16-3) , 4.4.1 Fer significant ' procedural deficiencies, CAR's will be written by 1 Quality Assurance personnel and approved by the HJK Site Quality j Assurance Manager prict to issue. Corrective ac icn ccmmitment shall be approved by the HJK Site Quality Assurance Manager. An __. index log showing status cf CAR's shall be maintained by the QA
=
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Administra:icn Manager er his designee in accordance with appropriate implementing procedures. HJK QE's shall review CAR's to i de: ermine pc ential repertability under 10C R50.55(e) cr 10CFR21.
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FOR (NFORMATION ON!.Y
- l 1
HENRY J. KAISER CO. Q.
A. PROCEDURE
No. 16 R E V. O PAGE b op_ 6 ! i.
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4.4.2 A CAR may be used to assu e cc::ective a tica en a N:n:cnic mance Rep 0 :. , 4.4.3 Fc:' procedural violaticas that result in material deficiemies, a CAR shall be issued to cc:ument the p;c:edu al viciation and a Non:cnic maxe Repc shall be issued
' to cc ument the material deficiexy.
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5.1 Figu e 16 No confermaxe Report 5.2 Figure 16-2 .In-PI cess Inspectica Deficiemy Recc:d 5.3 Fig"tre 16 Stcp Work Order i 5.4 Figure 16 Cc :ective A:tica Report ' i I ' mmm e e
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4 _ EXHIBIT 8 i UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COIMISSION Before the Atomic Safety and Licensing Board .,
j In the Matter of: )
)
The Cincinnati Gas & Electric ) Company, et al. ) Docket No. 50-358
)
(Wm. H. Zimmer Nuclear Power ) - Plant) ) MVPP'S REPLY TO APPLICANTS' AND STAFF'S RESPONSES TO MVPP'S MOTION FOR LEAVE TO FILE NEW CONTENTIONS i
)
i Tntervonor MVPP files this reply in answer to Applicants' 1 l 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. i i
- While uclcoming the Staff's support, MVPP must emphasize that of the eight contentions presented, its central and most 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 INTHODUCE i NEW CONTENTIONS CG&E charged in its Opposition that Intervonor MVPP was i merely a " facade, used and then discarded, by succeeding self-
l 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 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 intervonor in this licen-sing proceeding. It is a wholly-owned subsidiary of the Cincinnati Alliance for Responsible Energy (" CARE") , a local advocate 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 intervonor. MVPP has retained GAP to represent it in the licensing proceedings. GAP's primary purpose in 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 privato_-- that are ! wasteful, illegal, or pose a threat to the health and safety of the American public.1/ - i 1/ i
- H. Patrick SWygert arrl Shry Eastwood, forner Special (bunsels of the -
hhrit Syste .s Protection Board, have praised CAP's efforts to nonitor irple-ncntation of whistleblower Icform, as has Congresshunan Patricia Schroeder, i chairkunan of the House Civil Service Sub:cmnittee. l Sinoa 1979 GAP has operated a Icgal Clinic with the participation of Antioch Law School students, has produced t.o fil s, and has organized a national l M1istleblce.cr's Conference. GAP attorneys have frequently testified before l Cbngress. In addition, GTP forncrly representcd Fr. Tnomas L7plegate regarding his allegations about illegalities at the Zinner site. ! = i
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 scen 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. I II. MVPP HAS MET THE STANDARD FOR ACCEPTANCE OF UEW CONTENTIONS IdiD TliE STANDARD FOR REOPENING THE i RECORD
\
i 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 i
meets both standards and recommends reopening the proceeding for litigation of MVPP's proposed eight contentions. l' 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 af ter it obtained numerous affidavits from Zimmer workers and internal documents substantiating l the serious allegations contained in its contentions concerning the l fatal deficiencies in CG&E's quality assurance ( " QA " ) program, which l includes the Quality Confirmation Program ("QCP"), and concerning l l l t
_4_ CG&E's lack of character and competence to operate a nuclear reactor. Much of this information was disclosed to MVPP only a 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 breakdoun at Zimmer. For example, Earl Borgmann and other , top CG&E of ficials 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: l (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 1 4
Exhibit B. j (2) On July 10, 1973, CG&E " suggested" that Kaiser not write nonconformance reports on rej'o* ion of materials purchased for the Zimmer project and repeatedly emphasized that was CG6E's position. 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. l (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. (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
'ASME standards. See February 20, 1974 Letter, attached and incor-porated herein as Exhibit F.
--On March 28, 1974, Kaiser asked CG&E a series of questions about the procedures Kaiser was to follow' in inspecting CG&E-purchased equipment. See March 28, 1974 Letter, attached and incorporated herein as Exhibit G.
--On April 9, 1974, CG&E ansuered all the questions posed
l by Kaiser and stat'ed that CG&E's procedures differ from those of General Electric. See April 9, 1974 Letter, attached and incor-porated herein as Exhibit !!.
--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 l NRC of changes in the management structure for the Zimmer project. Ile stated explicitly that "the purpose of this reorganization was 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 it was "CG&E's intention to maintain a minimum of inspection in the 4
l . non-essential arca" and to delete " construction inspection plans and i 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. l The press has also reported that internal correspondence 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, has been reported: (1) On October 14, 1974, Friedrich told CG&E it was "abso-i lutely necessary" to improve Kaiser's QA staff to satisfy federal standards. Two weeks later, CG&E President William Dickhonor refused because he found "no justification" for providing more QA personnel. (2) On January 15, 1975, in response to further requests by raiser for more QA personnel Borgmann wrote, " Quality rather j than quantity is the real answer on a project of this nature...." (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 4 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 for Kaiser but vetoed a request for five others. See 1
- i Exhibit A, supra at 4.
, The press also disclosed that an independent report conducted z by Kaiser in 1981 charged CG&E had insisted that up to 90 percent of
( i
4 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 hours. 10 C.F.R. Part 21. CG&E could be fined up to $25,000 por day or be subject to criminal prosecution. See i
Cincinnati Enquirer Article, June 9, 1982, attached and incorporated herein as Exhibit N. CG&E's deliberate refusal to report such deficiencies is i 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
- hangers may have been purchased from non-approved vendors. Ehas i
tells Schwiers that this is a " potential 50-55e against the HJK OA program," and if true demonstrates that "we have a breakdown in the QA program that should have been discovered by a QA audit. Fra:tk 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 i 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 def'iciencies within 24 hours to avoid severe en-1 forcement sanctions. Not only did CG&E not report this breakdown in vendor approval procedures in January 1981, but it failed a second time to report the problem af ter Kaiser's independent report verified the l l
. . , - - - . - - , - - . . , - - - - - - _ - . - ~ - - . - - , , , . , . , - - . ~
n'oncompliances. Even today, CGEE has refused to report the defici-encies in its vendor approval procedures as 10 C.F.R. 50.55(e) 3 requires. This is a blatant violation of NRC regulations ! i 4 B. Availability of Other.Means to Protect j 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. a-The NRC issued two reports to respond to Mr. Applegate and other 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 i substantiated most if not all of Mr. Applegate's charges, a memo-t 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 l
... stated that Mr. Dickhoner, during a recent speaking engagement, had told his audience that the NRC found Applegate's allegations to be witI.out substance. He said that Mr. McCarten had told him earlier that many of his allegations had boon substantiated and he E'1he doctnents listed abre, as wall as others, will be incorporated in Intervenor's forthcoming Petition to Stop (brstruction.
\
,w - - - , - --, ,---,e - - - - . - - - _ , -..-ca --, ,~ ----:- - - , - - . -
wanted to know if we were changing our story. I- told Mr. Applegate that we were not in a position to control fir. Dickhoner's statements and that our investigation findings had confirmed many of his allegations -- either in whole or in part. See Keppler Memorandum to File, July 8, 1981, attached and incor-porated herein as Exhibit O.
~
Moreover the Staff's recent support of Intervenor's request to reopen the licensing hearing demonstrates the NRC's appreciation of Intervenor's major role in investigating QA deficiencies at Zimmer. 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 not 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, prior to the Staff's recent shift in position, 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 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. l l a l _ _
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 t.he 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. Further, Mr. Keppler has stated that he does not expect CGLE 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 QCP 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, and Cincinnati Enquirer Article, June 17, 1982, attached and incor-porated herein as Exhibits T and U respectively, both demonstrating GAP's consistent criticism of CG&E's control over the Quality Confirmation Program. Neither the NRC nor Applicants can claim they are surprised
- , . ~.
W or prejudiced by Intervenor's motion to file new contentions. ! MVPP has, in its contentions, put into issue CG&E's basic ability to operate a nuclear plant. MVPP questions both whether CGLE has the basic integrity to participate in self-regulation ~under the Atomic Energy Act and whether it possesses the technical com-petence 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 licensees. We trust them to operate the plant. He 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. 4 :s ar III. MVPP'S PRIMARY CONCERN AND PRIMARY CONTENTION QUESTION Wi! ETHER CGLE HAS THE CHARACTER TO OPERATE A NUCLEAR REACTOR While seven of the eight contentions MVPP wishes to introduce encompas,s concerns about CG&E's "out-of-control" QA program, MVPP's i
-3/Intervenor's counsal Mr. Devine has outlincd his critique of CG&E's quality assurance program to the 03=ission. See Devine Statcr ent, June 16, 1982, attached and incorp3 rated herein as Exhibit V.
His criticisms are specific and have included exa:rples corroborated by former wrkers, including Richard Reiter, former Kaiser docu: Tents revie*ur, and David Jones, fomer senior m cnalyst for Kaiser. s Ms
%.e
1 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-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," id., at 291, n. 4, since Section 186a of the Atomic Energy Act allows denial of licenses for " intentional false statements."I! MVPP outlined in its original motion, Motion at 16-18, misrepresentations made by high CG&E officials to the NRC, to CG&E shareholders, and to the press. Subsequently, CG&E Vice President Borgmann 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 connection with a c'riminal investigation. However, Exhib. 52 to the IE Report, Exhibit 12 to Intervenor's Motion, confirms that
-4/The Co=tission suggested that even if not made intentionally but only with disregard for the truth, " misrepresentations can be sufficient ground for denial of a license." roid; Virginia Electric & PO zer Comany v. NRC, 571 F.2d 1289 (4th Cir.1978) .
i
- 4 l
CGLE 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 misrepresentations 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.5/ Moreover, in light of the public's increasing distrust of CG&E's ability to manage Zimmer, this Licensing Board must provide a full airing and litigation of those 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 i
-5/Intervenor would again enphasize that cantrary to the characterization of its eighth contention by the NRC Staff as one questioning CG&E's technical coapotence, the main thrust of the contention is to put at issue CG5E's basic integrity and character to operate Zimer safely and in accordance with NFC regulations.
suggested contentions, and set a discovery schedule as soon as possible. Respectfully submitted, r
.f/.hfL 2 % e _[As LYNN BERNABEI J >rv.43Oi lg TilOMAS DEVINE
/*f J Government Accountability Project of the Institute for Policy Studios 1901 Q Street, N. W.
Washington, D. C. 20009 202/234-9382 Counsel for Intervenor DATED: July 8, 1982
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