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October 30, 1981 g
30-558 MEMORANDUM POR:
C. E. Norelius, Director, Division of Engineering
& Technical Inspection R. L. Spessard, Director, Division of Resident
& Project Inspection R. F. Warnick, Director Division of Enforcement
& Investigation Staff TROM:
James C. Keppler Director
SUBJECT:
ZIMMER - REACTOR CONSTRUCTION INSPECTION PROGRAM EVALUATION The attached memorandum from Mr. Sniezek to Mr. Blackwood concerns an evaluation of the implementation of the reactor construction inspection program at Zimmer. This evaluation is being conducted at my request.
Please take steps to assure full cooperation by involved Region III personnel in making this evaluation as meaningful as possible -- we want to learn everything we can from this experience to preclude similar problems in the future.
James C. Keppler Director
Attachment:
Memo dated 10/27/81 cc w/o attachment:
J. H. Sniezek. IE l
A. B. Davis, RIII 1
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NUCLEAR REGULATORY CCMMISSION y *,A I I
RE GION 111
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cLEN ELLys, stumois som January 12, 1981 MEMORANDUM FOR: Victor Stello, Jr., Director, Of fice of Inspection and Enforcement TROM:
James G. Keppler, Director
SUBJECT:
ZIMMER'- GOVERNMENT ACCOUNTABILIIY PROJECT REQUEST FOR INVESTICATION BY MERIT SYSTEMS PROTECTION BOARD CONCERNING NRC'S HANDLING OF APPLEGATE ALLEGATIONS In followup to our earlier telephone conversation, Region III has reviewed the subject package to determine a recoc=nended course of action for NRC. As we see it, three major issues need to be addressed. These involve:
- 1) the adequacy of Region III's earlier investigation into allegations provided by Mr. Applegate; 2) the significance of what appear to be.new allegations contained in rhe. par:kage; and 3) the need for further inspection ef forts in light of the gross lack of control alleged. Our recoe:mendations with respect to these issues are as follows:
1.
Adequacy of Region III's Earlier Investigation OIA will be conducting an investigation, at the direction,of Chaiman Ahearne, into Region's handling of the original Applegate allegations.
l We concu'r.,with this approach and will cooperate fully with the OIA investigation (scheduled to commence January 13, 1981).
i 2.
Significance of Apparent New Allegations Region III has reviewed the 19 allegations contained in the package submitted by the Government Accountability Project. A summary of this review is provided as an enblosure. Overall, we believe we know the bases of some of the allegations, whereas others appear to be new allegations.
In any event, the lack of specificity of the charges will require additional contact with Mr. Applegate to determine whether' r
further NRC investigative efiorts are warranted. Because Region III's
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handling of the earlier investigai. ion is the focal point of the l
requested investigation by MSPB and these new allegations are intertwined with the previous investigation, we recommend that pursuit of these I
allegations be performed independently by another Region.
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1/12/81 Victor Stello, Jr.
Need for Further Inspection Ef forts 3.
the construction inspection program It is Pegion III's assessment that at Zimmer has been comparable to the inspection program at other Region III construction sites and, while a f airly high noncom been identified, we believe the quality of actual construction is basically sound -- with the exception of pipe support systems (a matter being pursued by Region III).
Notwithstanding, in consideration of the shabby image portrayed by the Government Accountability Project's package, the number of allegations raised during the project, and the relatively large number of quality related issues identified by our inspection program, we believe d
In this regard, on evaluating the completed construction work.
han we would suggest establishing a team headed up by a Region other t focus The Region responsible for the inspection should have access The team inspection Region III.
to inspectors from the re=aining Regions, as needed.should util If you direction of the Division of Program Development and Appraisal.
approve of this approach, the timing of this inspection needs your in concerning priorities.
do two team inspections simultaneously, and we are scheduled to co=mence a team quality assurance inspection at Clinton in early February.
Mr. Taylor would prefer to have the Clinton inspection per Since Zimmer is essentially complete, the timing of that Further-critical from a status of construction aspect.
April).
more, should the new investigation disclose significant pr inspection is not that we should proceed with the However, my reaction it Zimmer Team Inspection as a priority because of the visibility being at Zimmer.
given to this matter.
We will be ready to discuss our recommendations further with you at your l
l convenience.
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James C. Keppler Director I
Enclosure:
As stated l
cc w/ enc 1:
R. C. DeYoung, IE J. H. Sniezek, IE i
N. C. Moseley, IE D. Thompson, IE i
L Review of the Government Accountability Project request to the Merit Systems
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Protection Board to identify new information to consider for possible investigation at Zimmer.
Pete 13.
L "1.
KIl knowingly installed and ripped out unsuitable main steam relief piping, at an estimated labor cost of $320,000."
1 This may refer to the pipes involved in Allegation 2 in the investigation.
Applegate was of the opinion these pipes, or at least the welds, were replaced between the time of the two visits to the site during the investigation.
"2.
2000 pound fittings were insialled in 1979 on residue head valves, although 5000 pound fittings are required."
This appears to be a new allegation.
"3.
A radioactive waste drain is clogged with concrete which carelessly was poured into the drain."
This appears to be a new allegation.
The following excerpt from Page 8 of Inspection Report No. 80-02 may
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pertain to the above item.
" Testing of the auxiliary building ventilation (Procedure fA' '
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including air integrated system test had been completed. 5 However, the test package is being held for another integrated system test after control of the area is relinquished by the construction department. The inspector observed that obvious penetrations to the charcoal bedroom had been plugged; be also observed a plugged floor drain in the room and questioned its effect I
on an integrated systems test. The systems engineer stated that the drain had been cleared for the previous test and would be again for the final test.
The need for this was discussed at the exit interview."
- 4.
A residue heat valve broke when a pipefitter bumped into it, raising new questions about the quality of metal used for valves."
This appears to be a new allegation.
- 5.
Sensitive parts on velding rods are possibly damaged through storage at improper temperatures, and possibly lost through failure to follow proper paperwork and labeling requirements."
The following is an excerpt from Page 10 of Inspection Report No. 80-19 which relates ta the above.
" Weld rod warmer IA-18 was observed on August 19, 1980, to be deenergized with weld rod (E-7018) contained in it.
The weld rod issue form attached l
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to the warmer was dated August 18, 1980, although veld rod wa rmer I A-18 i
August 13, II was listed as missing by the welding engineers secretary s nce18, 1980, showed The release and check-in forms for IA-18 on August 0 8 (Iow that it was taken from the rod shack with one-half pound of E-71 1980.
As of August 29, 1980, bydrogen) weld rod and returned with no weld rod. Veld rod control has been the_ warmer was not returned to the rod shack.
brought to the attention of the licensee for many years and has been cited 7
least 11 times in the last five years; this as items of noncompliance at This item which is repetitive of noncompliance being the third this year.
i previously identified items of noncompliance in weld rod control is ind ca-This was tive that previous corrective actions have been inadequate. ident (Corrective Action) and the Wm. H. Zimmer FSAR."
Argon gas valves for flushing oxygen from pipes routinely are left opencrew to "6.
by the day crew, causing the night about which CG&E Safety Director Cummings expressed disinterest."
This appears to be a new allegation.
Prefabricated piping received in 1977 bas defective welds, but construction (sic) made supervisors told crews not to repair them because the welds avere "7.
off-site."
This was mentioned by Applegate in the context of Allegation 2 in theThe five dropped investigation except that the year was 1979 not 1977.
pipes were determined to have acceptable welds.
The instruction by construction supervisors to crews is new.
At least three sources contacted by Applegate confirmed that an estimated 20% of the plant's prefabricated welds are defective."
- B.
See comments on No. 7 above.
Engineering " designs" routinely are drawn, af ter the fact to conform with
9.
piping that already bad been installed."
The following is a pertinent excerpt from Pages 2 and 3 of Inspection Report No. 80-16.
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" Status of RIII Identified items Items of noncompliance and unresolved matters relative to large bore pipe suspension systems that were not installed in accordance with the design drawings, specifications, support component assembly designs, and were tion in without backup calculations were identified during RIII site ins t
initiated and implemented in the A-E's office, and at the site.
1978..
However, the exact status and effectiveness of the program were not formally f
At the inspector's request, the essessed and documented by the licensee.
licensee agreed to conduct a comprehensive audit of all aspects of large bore suspension system activities, in particular (1) present design control status, (2) ef fectiveness of interfaces between organizations, (3),construc-tica and QA/QC work status and work plans, and (4) expected completion dates The results are to be pre-for each of the implementation work functions.
sented to R111 either orally or in writing by the end of 1980."
"10. Shock-absorbing electrical tray hangers previously found unsatisfactory are still unsafe due to faulty welds, and electrical cable trays remain dangerously full."
As indicated, there have been problems with This is a new allegation. The basis for alleging they are still unsafe electrical tray hangers.
e is not knoVn.
Regarding the loading of cable trays, this matter was an allegation See Investigation Report No. 79-19 I
investigated in July 1979.
i Page 14.
"11. Sand and mud choke the feedwater pumps and intake flues carrying makeup water to the cooling tower, because of a flaw in the plant's design.
Pumps used to rectify the flaw quickly burn out."
CG&E submitted a letter to the NRC identify-20, 1979, By letter dated June ing a silting condition which had been discovered in the river pump house This matter has been followed by NRC intake flume and intake structure.
since that time.
- 12. A design flaw in the beat exchanger control panel permitted an operator mistakenly to force 1200 pounds of pressure through pipes l
spray of water that would have been radioactive had the plant been in operation."
The following is a pertinent excerpt from Inspection Report No. 79-29.
"10 CFR SO Section 50.55(e) Reportable Deficiencies (Closed) Over pressurization of the steam jet air ejector heat exchanger (tube side).
NR number 7247R1, dated February 21, 1979, stated that over pressure to 1200 psi of the LPCS piping system occured (sic) in addition The A-E (Sargent and Lundy) analyzed the piping system and l
to others.
valves with dispositions as follows:
Carbon steel piping 3/4" up to 12" acceptable since stress was well 1.
below yield point.
The one stainless steel 3/4" pipe is likewise o.k.
- 2. -
3.
Six hundred pound valves are acceptable with the pressure experienced only being a repeat hydro test.
4.
Three hundred pound and 150 pound valves the manufacturer should be consulted.
5.
The relief valve causing the problem should be retested and reset.
Further information available (Construction Engineering Report dated April 14, 1979) stated that the valve manufacturers recommended a seat leakage test be conducted on the valves and that this test was performed without any leaks being detected and it further stated that the relief valve had been removed, tested and reset of set points done. The NR sa.,
signed as completed on October 25, 1979. The inspector indicated that he had no further questions regarding this item."
"13. There have been periods when there were no security surveillance cameras during nuclear fuel deliveries to the site, and perimeter security consis-ted for an extended period of only a four foot chickenwire fence."
Security surveillance cameras are not required for nuclear fuel deliveries.
Fencing is not part of the security protection of the fuel being stored at the plant site.
- 14. A lax attitude toward employee behavior was evidenced by complete disregard of drinking and drug use on the site, and routine hiring of temporary laborers prone to violence."
This is a new allegation.
"15. Employees fired for time cheating had been cheating with the express l
approval of management, and the only time cheaters fired were vocal and knowledgeable critics of plant QA and safety."
I The allegation that the only cheaters who were fired were those who were vocal and knowledgeable critics of plant QA and safety is new.
l "16. CG&E had warned PM management to silence the radiographers at Zimmer, who were criticizing CG&E's consistent approval of welds rejected by PM."
This allegation is new unless it refers to the taped telephone conversations between Applegate and Peabody Magnaflux personnel.
If it is these conversa-l tions, we have a copy of the tape.
l Regarding CG&E's approval of welds rejected by Peabody, this matter was examined during the investigation of Applegate's allegations.
It should l
also be noted that Peabody does not approve or reject welds. They performed the radiography and made a preliminary evaluaton but final responsibility for acceptance of welds rests with Kaiser Engineers, Inc.
1 "17. Union pipefitters and PM employees have been intimidated by fear of utility and industrywide reprisals should they complain about QA practices."
l i.
i The basis for this statement is not known unless it refers to the taped I
conversations referred to under Item 16.
Intimidation of pipefitters is a new item.
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"28. A KEI employee has kept a detailed journal of safety hazards and, incidents at Zimmer."
l Applegate provided the name of such an individual.
An effort was made to contact the individual but we were informed no one with that name was i
employed at the site. Having no additional information concerning the purpose or content of such a journal, the matter was not pursued further.
"19. A common " joke" among pipefitters at Zimmer is that they will be hundreds of miles away when the plant goes on line, due to their predictions of a disastrous accident."
This item requires no comment.
Page 18.
...P.M. rejected approximately 39% of the Zimmer welds, or three times the industry average.
(Hertsgaard Interview)."
This allegation is new and we have not seen the Hertsgaard interview.
"... employees charged that records might be unreliable because KEI pressured the radiographers to rush the x-rays and perform the tests under imperfect conditions.
The ' pressure to produce' was likely to produce low quality radiography."
This allegation is new. As indicated in the investigation report, we had identified problems relating to radiography during inspections conducted in 1978 and 1979.
Page 19.
I Applegate "... passed along the employees' estimate that about 20% of the pre-febricated piping contains defective welds.
(Affidavit at 8.) Further, he reported that KEI policy forbids repairing these defects even after radiographic i
detection.
(Hertsgaard Interview)."
The investigation of Allegation 2 involving five prefabricated pipes included o determination that the welds in these pipes were not defective either because of improper handling upon receipt or the quality of work by the supplier.
If
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cny of these welds had been determined to be defective, the matter would have bren investigated further.
Prefabricated piping is accompanied by certifications and documented evidence that the welds have been examined and meet specifications. The policy, which l
is acceptable to NRC, is that such pipe is not normally subjected to NDE at l
the site.
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