ML20058E582
| ML20058E582 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 03/09/1981 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058A387 | List:
|
| References | |
| FOIA-82-206 NUDOCS 8207300105 | |
| Download: ML20058E582 (7) | |
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i R. F. Heishman, Director, Division of Resident and MEMORANDUM FOR:
Project Inspection A. Bert Davis,. Deputy Director FROM:
COMMENTS ON APPLEGATE ALLEGATION
SUBJECT:
Enclosed are my comments on the first Applegate allegation writeup.
I will be happy to discuss them with you.
O. fe%VLM A. Bert Davis Deputy Director
Enclosure:
as stated cc w nelosure:
E. Norelius J. F. Streeter R. F. Warnick P. Barrett J. McCarten l
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COMMENTS ON ALI.ECATION NO. 1 General Comment I recommend the format should be as stated in my mecarandum of February 9, 1981.
Specifically per 1.b. of that memorandum we should The pull together in a paragraph all information specified in 1.b.
same applies for 1.c.
In addition the following specific comments apply.
1.*
See comments included on your writeup.
Is it fair to say:
This sentence is not very clear to me.
2.
CG&E decided to proceed with installation of the originally designed main steam relief piping, realizing that some rework The basis would be necessary due to the required redesign.
for the decision...
Can you make a statement as to how you knew the radiographs 3.
you looked at were not faked?
State whether the review of the radiographs showed the welds to 4.
be OK or not.
5.
Add the following:
The NRC made no attempt to corroborate these costs or the licensee's claim that it was cheaper to proceed with an installation which was known before installation to require rework.
The NRC's concern is the adequacy of This the design and installation of the final product.
adequacy has been confirmed.
- Numbers correspond to those shown on the writeup in circles.
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o FORWARD The following allegations (numbering 1-19) came to the NRC from the Of fice of Special Counsel of the Merit Systems Protection Board (M.S.P.B.) in a documented Request for an Investigation Pursuant to 5 USC 1206 (b) (7).
The Request was submitted to the M.S.P.B. on behalf _of Mr. Thomas W. Applegate by the Government Accountability Project (GAP) of the Institute for Policy Studies (IPS).
It is noted that GAP and IPS are not agencies of, nor af filiated with, the United States Government.
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NRC Investigation of Activities Pursuant to the Request Submitted to the M.S.P.B.
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1.
KEI knowingly installed and ripped out unsuitable main steam relief piping at an estimated Labor cost of 5320,000.
During the period of 2/9-13/81 and 2/23-27/81, the RIII inspector discussed and reviewed pertinent information and documentation concerning the allegation.
Discussions with Mr. H. C. Brinkman, Principle Mechanical Engineer, CGEE, indicated that in 1975, a nuclear power plant in Germany discovered the need to redesign the relief system based on new discharge loads.
Therefore, several utilities, including CG&E, decided on a modification to replace the already installed rams head safety relief valve (SRV) discharge devices with quenchers.
CGEE decided to start the modification, knowing that rework on main 9 k steam relief piping would be necessary, even though the piping had j
not been instatted.
The basis for the decision was that approximately 95% of the original design would be acceptable and therefore only 5%
would be subject to rework.
CGLE's decision concluded that it would be less costly to go ahead in 1975 with the installation activities rather than to delay the construction schedule until the modification design was complete. To date, the modification design is not complete.
The NRC has been aware of the modification activities as described in the Mark II Design Assessment Report, Chapter 2.0 - Zimmer Empirical L.oads, IPS-1. The RIII inspector observed that the latest documentatioa received f rom the NRC Licensing Branch No. 2 at t site concerning the
1, titled, modification activities, was NUREG-0487, supplement k' Mark 11 Containment Lead Plant, Program Load Evaluation and Accep It should be noted that there may be more changes in the Crfteria."
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future due to additional load definitions.
i The modification has required the replacement of 10 inch schedule 40 pipe with other 10 inch schedule pipe of dif ferent configurations 10 inch extra strong pipe, and 12 inch extra strong pipe.
During this investigation the licensee provided cost figures for and the The total Labor cost was '5823,780.00 modification to date.
total material plus labor cost wa.s $1,183,690.00.
i The RIII inspector reviewed all revisions to the KEI isometric draw ng PSK-1MS, Sheets 21 and 21 A, which were pertinent to the main steam No additional changes of the magnitude addressed in relief piping.
The revisions identified the following the attegation were identified.
changes:
9/8/76 Redrawn -- original configuration replaced Rev. O 1
3/31/77 Hangers added Rev. 1 1/10/78 Eight Lugs added Rev. 2 5/5/78 Hanger changed Rev. 3 4/3/79 New spool pieces added, welds MS212 and Rev. 4 MS195 voided per S&L 6/18/79 Piping tee section added Rev. 5 10/1/79 Weld MS160 and a 4 inch dimension added Rev. 6 I
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i Rev. 7 Field marked (redline) updates added 1/9/80 Rev. 8 Welds K-461 and K-463 changed; 9/27/80 weld K-592 changed to K-593 per NR-2499; hanger detait section D-D added Rev. 9 Weld K-592 changed to K-461; and weld K-593 9/4/80 changed to K-594 Att of the above revisions pertained to the aforementioned modification.
The RIII inspector reviewed the QC documentation for the following main steam relief piping field welds:
Nos.160,160A, 267A, 2678, 267C, 2670, 2688, 268C, 268D, 459, 460, and 4g docurne nivh Osindicated that the welds had been accomplished in accordanc The ::ctd l
with ASME Section III 1971, Summer 1973 Addenda.
The RIII inspector interpreted the radiographs for the following main steam relief piping field welds:
Nos.160A, 459, 460, 461, 462, and 594.
is noted that there are approximately five to seven radiographs for It each of the above welds.
The varying number of radiographs are necessary to cover the entire 360 degrees of each pipe weld.
The radiography was performed in accordance with ASME Section III 1971, Summer 1973 Addenda.
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The above discussions and reviews indicate that t e a KEI QA program.
were performed in accordance with the ified.
No items of noncompliance or deviations were ident 4
Additional information:
F. J. Ottz, Records Supervisor Also contacted:
R. L. Wood, QA Engineer d into this write-up.
Previous reports have not yet been incorporate G
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- q6, March 17, 1981 Victor Stello, Jr., Director, Office of Inspection
_ MEMORANDUM FOR:
and Enforcement e
James G. Keppler, Director FROM:
INVESTIGATION OF APPLEGATE ALLEGATIONS RELATED
SUBJECT:
his The purpose of this memorandum is to update you on the status of t i
investigation and inform you of our future course of act on.
9 allegations We expect to co=plete next week our investigation of the first 1 Project (GAP).
received from Mr. Applegate via the Government AccountabilityEither the allegations hav findings to date.
is no safety There have been no significant not been substantiated or, for those substantiated, there significance.
been As a result of our investigations into the 19 allegations there have We are now in the process about twice that many additional matters uncovered.
Some of the more of investigating these and many appear to be significant.
l ided significant ones involve bad welds on structural steel, improper y vo l materials, improper nonconformance reports, lack of traceability of structura d
te radiographs socket weld fitups, improper veld inspection criteria, ina equai Gas & Electric on many vendor supplied welds, and inadequate CincinnatWe anticipate about two Company (CG&E) quality assurance implementation.
i f these additional more weeks of on-site investigation to complete our rev ew o items.
i eople Of the original 19 allegations our findings from interview ople.
In this regard, we intend to request a meeting with the CAP attorneyWe have app assigned to this case and resolve the discrepancies. Depar i
Attorney
- Unit, assigned to Ohio and the Chief, Special Processing OJ has all information of our investigation ef forts and have confirmed that DDOJ informed us t ion standpoint. We will keep provided to us by GAP.
to be without merit f rom a DOJ criminal investigat here we believe DOJ inf ormed of our investigation progress, especially in areas w criminal findings may develop.
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There is some evidence of alcohol and drug use at the Zimmer site in that empty beer containers and marijuana cigarette butta have been found.
However, no one has stated that the use was extensive or that such use We are attempting to identify work which af fected construction quality.
may have been performed by persons under the influence of drugs or alcohol.
We are still considering the best way to address this allegation.
We plan to meet with CG&E within the next two weeks to discuss our findings At that time we will as of that time and obtain their resolution of them.
decide whether any stop work order should be issued.
If you have any questions or advice regarding the information presented above, we would appreciate hearing from you.
James G. Keppler Director R. C. DeYoung, IE cc:
J. H. Sniezek, IE D. Thompson, IE J. J. Cummings, OIA bec:
R. F. lieishman C. E. Norelius J. F. Streeter R. F. Warnick P. A. Barrett J. B. McCarten 9-o,naY...
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