ML20058E750
| ML20058E750 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/28/1981 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Barrett P, Daniels F, Danielson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058A387 | List:
|
| References | |
| FOIA-82-206 NUDOCS 8207300173 | |
| Download: ML20058E750 (3) | |
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Y a 8 ic6,(0 NUCLEAR REGULATORY COMMIS$10N
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UNITEo STATES
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REGloN til
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g 799 MOOSE VELT mo Ao oLEN ELLYN, SLLINonS 60137 E
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f AUG 2 81981 P. A. 3arrett, Region III MD10RANDUM FOR:
F. T. Daniels, Region III g
D. H. Danielson, Region III T. L. Harpster, PDB, IE J. B. hsaderson, RPRIB, IE s
T. T. Martin, Region I J. H. Sniezek, Director, DRRRI, IE L. E. Tripp, Region I
~ K.irnick, Region III R. F A. Bert Davis, Deputy Director, Region III FROM:
EXTENDED INDEPENDENT VERIFICATION
SUBJECT:
PROGRAM AT ZIMIER h is to be Enclosed is the Independent Verification Program whic 8-to September 25, 1981.
conducted at in:cer during the period of SeptenberIf l ase contact Z
i l on, or tae.
either Bob Warnick, Paul Barrett, Duane Dan e s I in this effort.
We appreciate the assistance being provided by Region Ce MUM A. Bert Davis Deputy Director s
as stated
Enclosure:
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6207300173 820609 DEVINE82-206 PDR W 33 PDR FDIA
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EXTENDED INDEPENDENT VERIFICATION PROGRAM AT ZIMMER I,
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Introduction The RI NDE Van augmented by an NDE contractor and Franklin Research Cdnter (if needed) v111 be used in this program.
For all NDE performed NRC will use the same technique that was used by the contractor unless the appropriate code or' design called for a more stringent technique than was used by the contractor.
We will assume that the RI Van is available for three to four weeks.
Our goal will be to maximize the number of independent verifications during this period.
In selection of ite=s to be independently verified, select as many'as possible which have been finally accepted by Kaiser QC, and select as many as possible which are suspect.
RIII will provide three inspectors who will select sa=ples to be independently verified and one inspector who will perform visual NDE.
RI will perform NDE using Van equip =ent, and will. help make sample selection. Parameters, Inc. will assist in performing NDE, as requested by Region I or Region'III.
Indcoendent Verification Program 1.
RT ten pipe welds which have been identified as having incorrect penetrameter shimming. Select the worst ten presently kncwn.
e 2.
Identify as many pipe (small bore) welds as possible for'which paper work does not establish weld adequacy.
Perform the appropriate NDE on them.
This does not apply to socket welds.
3.
Select 20 pipe welds which were accepted by the licensee based on 10: or PT.
Re-do these examinations.
Note: For Items 2 an~d 3 determine material composition and hardness.
4.
Select two ECCS.
Select 20 welds on each system and perform appropriate NDE. Examine adequacy of material traceability for pipes adjacent to ucids selected.
For problem areas determine material composition (non-destructively, if possible).
5.
Identify several complicated geometries where UT was done because RT was inappropriate.
Include the Quencher system for which there was an allegation.
Re-do the UT on these.
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6.
Inspect structural beams in three additional areas.
Dete mine adequacy of welds and fit ups. Also determine hardness.
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7.
For beams already determined to lack material traceability, determine l=
material composition and hardness.
Select three samples to send to Franklin Research Center for material composition, hardness and metallography.
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V September 3, 1981 l
MEMORANDUM FOR: James G. Keppler, Director, Region III FROM:
James E. Foster, Investigator
SUBJECT:
OIA REPORT " ADEQUACY OF I&E INVESTIGATION 50-358/80-09 AT THE WILLIAM H. ZIMMER NUCLEAR POWER STATION" I am very concerned about the adequacy and conclusions of the subject OIA report. From my review it appears that the report does not deal with all questioned areas, significantly mischaracterizes statements made by Region III personnel, does not document interviews conducted, contains statenents not supported by fact, and reaches inaccurate conclusions.
It also appears that the investigative effort neither included interviews of pertinent licensee and contractor personnel, reviews of appropriate Region III investigative procedures, nor developed crucial information.
Lack of attention to detail is evident in many areas.
Three of the conclusions reached by OIA regarding the I&E investigation are:
l 1.
The investigation failed to properly document the results of investiga-l tion both as to interviews and material reviewed.
2.
The investigation failed to determine the correct status and history of several welds.
3.
The overall investigative effort was neither vigorous nor sufficiently broad in scope.
These conclusions are unsupported, but do apply to the OIA review. The remaining OIA conclusion (use of the phrase "not substantiated") has some merit, but would not alter the conclusions of the I&E investigative report.
In summary, the OIA effort appears totally deficient.
Specifically:
The OIA report (Page 3 Paragraph 2, Page 4 Paragraph 3, Page 5 Paragraph 9) 1.
indicates that the matter reviewed is the agency handling of allegations by Thomas Applegate. These were:
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l September 3, 1981 James G. Keppler Welds CY606, K811, HR42 have been rejected by Peabody-Magnaflux s.
personnel but accepted by Kaiser.
b.
System flushing procedures were improper.
c.
Welds on Main Steam Relief pipe spools are defective but were accepted by Kaiser.
The OIA report only contains a review of the handling of the first allega-tion. No detailed review of the other two allegations was performed or documented.
2.
Although William Ward (Chief, I&E Investigations Branch) played a sub-stantial part in the handling of this case by I&E (his name appears 20 times in the OIA report, Pages 5, 10, 14, 20, 35, 36, and 38), he was not interviewed.
3.
Several statements by RIII personnel (G. Phillip, K. Ward) were signifi-cantly mischaracterized or misunderstood.
I under. stand they are responding separately.
4.
I&E Inspection Reports Nos. 50-358/78-39 and 50-358/79-17 are signifi-cantly mischaracterized as indicating a " chronic and long history of welding problems at Zimmer" (OIA report Page 2). These reports deal with radiographic technique, not welding problems.
5.
One of the OIA report attachments is a manual chapter from the Fundamentals of Inspection course meant as a training aid (written by Gerald Phillip).
This is not an I&E or RIII procedure. RIII does have procedures covering i
report format, statements, etc. pertaining to investigations.
No reference is made to these procedures.
6.
For the three welds, CY606, WR-K811, HR42, significant information was not obtained by OIA.
Lack of this information (weld chronologies are attached) led to inaccurate conclusions. Relevant Nonconformance Reports were not reviewed, and cognizant personnel were apparently not interviewed. No l
technically knowledgeable personnel assisted in the review. Attention to l
detail was lacking, as was understanding of construction practices.
As the report focuses considerable attention on a nonconformance report (NR E-2138) related to weld WR-K-811, it is evident that the circumstances surrounding this document were not understood due to lack of complete information.
7.
Unsupported statements are characterized as fact. On pages 2,12, and 35, the conclusion is propounded that CG&E QA&S Manager William Schwiers ordered Floyd Oltz to "line out" a Nonconformance Report.
The basis for l
the conclusion is apparently the interview of Gerald Phillip, who noted that Schweirs denied the action.
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September 3, 1981 Jcmes G. Keppler -
A subsequent interview with Oltz indicated that Mr. Turner, then Kaiser QA Manager, his supervisor, advised him to line out one Nonconformance Report, knowing that another was in existence to track the nonconform-Schwiers was characterized as being present for this ing condition.
exchange, but did not direct Oltz. This information was corroborated by a Mr. Deerwester, who indicated that he was present during the exchange.
No information is presented in the OIA report to support the conclusion that this action was directed by Schwiers.
On Page 40, no support is similarly given for the statement that Thomas Applegate brought information to CG&E officials.
Several comments in the OIA report pertain to the investigative case 8.
l file maintained by RIII. These OIA criticisms are from a criminal investigation viewpoint rather than an I&E viewpoint. The one very minor discrepancy, the lack of an Identifier Key for the sole alleger in the I&E report (Thomas Applegate), was easily rectified.
One criticism (lack of "results of interview" documentation) is for an item not required and not believed necessary.
Portions of the presentations of interviews are unrelated to discussion 9.
of the adequacy of the I&E investigation, and add nothing to the report.
l Examples of this are the mechanics of meeting with Applegate, what he j
was wearing, xerox machine difficulties, etc.
Several of the report attachments are of little or no significance, and 10.
Several attachments some (weld rod issue slips) are totally unreadable.
add nothing to the report but size and weight.
The report does not explain the thirteen day delay by OIA Director 11.
Cummings, but only states that "the Chairman was aware of that aspect of the case".
The bandling of Applegate's allegations by OIA is very much a part of the agency response, and should be adequately detailed and explained.
While no interviews of licensee or contractor personnel are presented 12.
in the OIA report, I am personally aware that a site QC inspector was interviewed on June 10, 1981. The OIA report alludes to interviews of a QC inspector and a former supervisor of Document Control, but docu-I An outline of the OIA report is attached, ments neither interview.
indicating documented interviews and time frames.
The last documented action The report took 7.83 months to produce.
in the report took place March 5, 1981 (interview of E. L. Williamson),
13.
5.'.6 months prior to report finalization.
The style and detailed content of the reports of interviews with I&E 14.
p *rsonnel strongly suggest that these interviews were tape recorded.
Interviewees were not advised of such recording.
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James G. Keppler September 3, 1981 15.
While probably not of significance, the OIA report lacks signatures by the investigators or a Personnel Contacted listing.
J. E. Foster Investigator Attachments:
As stated l
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OIA REPORT Number Heading Date Page(s) of Pages Summary 1-2
2 Background
3
)
Details l
Review of GAP material 3-4 1
Meeting with Region III personnel 1/13/81 4-5 1
Interview of Gerald Phillip 1/14-15/81 5-16 11 Interview of Kavin Ward 1/27-28/81 17-19 2
Interview of Charles Norelius 1/26/81 19-22 3
Interview of Caston Fiore11i 1/26/81 22-23 1
Interview of Duane Danielson 1/28/81 23-24 1
Interview of Richard Knop 1/23/81 24-25 1
Interview of James Donahue 1/15/81 25-26 1
Interview of James Keppler 1/29/81 26-28 2
Interview of Thomas Vandel 2/18/81 28-33 5
Reinterview of G. Phillip and K. Ward 2/19/81 33-35 2
Interview of Len Williamson 3/5/81 35-38 3
Review of Welding records 39-40 2
CY-606 40-41 2
RR-42 42 1
WR-K-811 43 1
List of Attachments 1.
Memo from Ahearne to Cummings 12/15/80 1
2.
Letter from Eastwood (Special Counsel) to Ahearne 12/29/80 2
3.
GAP Petition (Request for Investigation) undated 24 l
4.
Letter from Keppler to CG&E, trans-miiting IE Report No. 50-358/80-09 (includes report) 7/2/80 53 5.
Weld Package for RH-42/RH-K-262 19 7.
Weld Package for WR-K-811/WR-K-936 9
8.
Nonconformance Report No. E-2138, l
Revision 1 (typed version) 1 9.
Nonconformance Report No. E-2138 (handwritten version) 2 l
10.
IE Inspectors Manual, Chapter 8 31 i
(Total Attachments ;34) l
O CY 606 CY 606 is a weld in the Cycled Condensate System, located in the ground in the tank farm area, under a concrete slab. The line is sixteen inches in diameter (weld is 50.26 inches of weld metal).
Maximum Design conditions for this line are 35 psig and 140 degrees F.
This line is S&L operating conditions are also 35 psig and 140 degrees F.
piping Class B.
CHRONOLOGY 07/ /76 Weld fit-up.
07/ /76 Weld performed.
07/16/76 RT read, reject 0-13, 13-26, unconsumed insert.
Approvals on WRD No. 1.
07/16/76 R1 readed, PT of grinding - accept, weld performed.
07/19/76 07/21/76 Approvals for WRD No. 2.
07/23/76 Ground area, PT accept, weld performed.
07/26/76 RT performed.
07/26/76 RT read, reject 0-12, 12-24, incomplete fusion.
07/27/76 Approvals for WRD labeled No. 2.
07/29/76 PT - accept.
RT for information only - reject.
08/02/76 PT reject - grind through & adjacent area, crack in weld edge.
08/04/76 08/09/76 RT performed.
08/09/76 RT read, 0-12 rejected.
08/10/76 KE1 approval of above RT report.
08/10/76 Approvals for WRD labeled No. 3.
08/10/76 PT test of area - accepted.
08/11/76 RT read - rejection areas 0-12 (Peabody-Magnaflux Personnel).
08/11/76 P-M rejection overriden by M. Low - accept veld.
08/12/76 Gamma plugs CY606GP, 606 GPS, 606GP welded, PT accept.
08/13/76 S&L audit of radiography, areas 8-12 rejected for surface
- 01/13/77 indications and linear indications.
NR-E-633, documents above finding, grind out defect and reveld.
- 01/21/77 l
04/15/77 Approvals on WRD labeled 3A.
06/08/77 RT of area in 3A 0-13, 13-26 accept.
06/08/77 RT read and approved.
06/20/77 ANI review and approval of above RT.
- 06/24/77 NR-E-633 closed.
07/19/77 Gamma plug re-welded, PT accept.
NES Review Begins
- 10/10/79 NES review - technique and documentation deficiencies.
- 10/12/79
- Significant information not in OIA Chronology.
(Daily Report)
Applegate told acceptance of CY 606 improper.
- 01/02/80 Applegate interviewed by Phillip.
003/03/80 Phillip onsite.
NR-E-5172 based on NES findings for CY-606 and several adjacent I
04/07-09/80 c10/03/80 velds.
Disposition of NR-E-5172, accept as is, A. Lanham.
- 10/27/80
- 11/07-12/80 Approvals on NR-E-5172.
NR-E-5172 closed.
Rex Baker notation on NES documentation review checklist form
- 11/12/80
- 12/17/80 (closcout).
- Significant information not in 01A Chronology.
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WR-K-811 WR-K-516 I'
(WR-K-827)
(WR-K-916)
(WR-K-917)
Cooling WR-K-811 and WR-K-827 were welds on the Auxiliary Bu Welds Water System.
WR-K-936, WR-K-937 are replacement welds.The line is 4 inches in diameter (weld I
Auxiliary Building at elevation 572'.
was 12.56 inches of weld metal).
Maximum Dasign conditions for this line are 120 psig and 105 degrees F.
The line is S&L cperating conditions are 150 psig and 125 degrees F.
lly radiographed).
piping Class C (final visual inspection only, not norma CHRONOLOGY Approvals for production of WR-K-516. Consumable inser 08/ /77 11/08/77 WR-K-516 welded, ANI waiver on hold point.
11/09/77 WR-K-811 weld fit-up.
KEl-1 01/29/79 WR-K-811 visual inspect' ion of final pass-accept.
01/30/79 Inspector Setlock assisting with documentation location and misplaced.
- 10/
/79 NR-E-2138(RO) WR-K-811 and WR-K-516, believe missed ANI correction.
10/11/79 holdpoint.
Disposition:
RT of weld WR-K-516 per NR-E-2138RO. Probable date o
- 11/06/79
- 11/06/79 Reject.
(RT done twice).
RT of WR-K-516 rejected for unconsumed insert, other defects.
NR-E-2260, RT of WR-K-811 shows adjacent weld WR-K-827 un-
- 11/08/79
- 12/03/79 acceptable, unconsumed insert. Replace pup piece, "see related N NR-E-2138 " Voided" (actually superseded),..."see Revision 1."
Disposition:
" Steve" tells Applegate K-811 "MSR pipe" has " insert fault."
12/14/79 WR-K-516 no KEl-1, RT reject.
- 12/27/79 Speed memo, Ruiz to Pallon:NR-E-2138 Revision 1, (see related l
- 01/07/B0 l
- 01/ /80 Cut out and reweld.
d).
Approvals on NR-E-2138, Revision 1 (weld WR-K-516 not men Dispostion:
Approval on KEl-1 for welds WR-K-916, WR-K-917.
01/14/80 01/16/80 WR-K-916 fitup and weld.
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01/18/80 NR-E-2138R1 closed.
l 01/21/80 WR-K-916 visual inspection and acceptance.
01/24/80 NR-E-2260 closed.
- 01/24/80 Applegate interviewed by Phillip.
03/03/80 04/07-09/80 Phillip onsite.
RT for WR-K-516 found.
- 08/ /81 WR-K-516 Re-raditgraphed.
- 08/ /81
- Significant information not in 01A Chronology. ---
COMMENTS According to QC Inspector Setlock, Floyd Oltz asked him to locate the KEI-1 I
He could not locate weld history forms for welds WR-K-811 and WR-K-516.
them, and found that the ANI had listed hold points on the fit-up for welds The ANI had no log notation to indicate that he had waived the en the line.
holdpoints for these welds. NR-E-2138 was written to document missing the
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boldpoints.
I Sctiock was not aware that the ANI had waived the hold point on fit-up
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inspection for WR-K-516.
He indicated that he first learned of this I
information on approximately August 15, 1981, when he was shown the KEI-1 He indicated that the form and ANI waiver are form for weld WR-K-516.
(It appears that at some time the KEI-1 form for WR-K-516 was genuine.
found, and the ANI waiver discovered.)
He also stated that he was not aware of NR-E-2260 nor of Revision 1 to NR-E-He does feel t
2138 (RO) but does not see anything wrong with actions taken.
that he should have been advised of the revision of NR E-2138, and that the dates of the original and revision might have been shown to better document I
actions taken.
l RT of WR-K-Bil could not be found, and RT of removed welds need not be re-It is very possible that WR-K-811 had a partially consumed insert, tained.
This would explain why es WR-K-827 had, and WR-K-516 has this condition.
" Steve" (Allen Sellars) told Applegate of an " insert fault" in weld "K-811" as detailed in Applegate's daily report dated December 27, 1979. WR-K-811 cnd the other welds had been accepted, and would not experience further review, as RT or other examination would not normally take place on these welds.
f If a weld is not subject to RT, certain defects are considered acceptable,
'The licensee has indicated that removal of cod must be assumed to exist.
WR-K-516 is planned, based on unacceptable RT of the weld.
Both the original NR-E-2138(RO) and the subsequent Revision 1 incorrectly indicate that weld WR-K-811 was welded on November 9, 1977 and weld WR-K-516 30, 1979. Apparently, this date transposition (WR-K-811 j
was welded on January l
and WR-K-516) was an error that was made by QC Inspector Setlock when The error was carried to the subsequent revision, and NR-E-2138 was drafted.
read by RIII Inspector K. Ward during weld documentation review.
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RH-42 RH-42 was a weld on line IRH01C18 in the Residual Heat Removal system.
The line The weld was located in the reactor building at elevation 497'.
is 18 inches in diameter (weld was 56.54 inches of weld metal).
Maximum Design conditions for this line are 220 psig and 389 degrees F.
The line is SEL piping cperating conditions are 240 psig and 358 degrees F.
Class B.
CHRONOLOGY 08/06/76 Weld fit-up.
08/06/76 Weld performed.
re-shoot 100%
08/09/76 RT read by P-M, reject markers 36-48 (Notation:
following repair).
08/10/76 KE approval of above RT interpretation.
08/10/76 Approvals on WRD form.
08/10/76 RT of repair area.
08/10/76 RT read by P-M.
08/11/76 RT accepted by KEI.
08/11/76 Approval of repair.
09/16/76 ANI review of 8/9/76, 8/10/76 RT reports, approval.
NES review begins.
- 10/10/79 NES review, porosity at film markers 53-55.
- 01/25/80 NR-E-5056 based on NES review findings.
- 02/12/80 NR-E-5056 dispositioned to grind out and repair defect.
- 02/15/80 03/03/80 Applegate interviewed by Phillip.
WRD form approvals.
l 03/21/80 Phillip onsite, initiation of Applegate investigation.
- 04/07-09/80 04/14/80 PT of re-prepped pipe ends, acceptance.
04/21/80 Approvals for WRD for new elbow.
04/23/80 PT of elbow end prep. accepted.
04/30/80 Weld fit-up breaks loose (Ref: KEIA No. 1008).
05/01/80 Re-fit-up approved and weld started.
05/02/80 Root pass made.
05/05/80 Root pass approval.
05/07/80 RT approved by KEI.
- 05/07/80 ANI review and approval.
- 06/16/80 NR-E-5056 closed out.
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- Significant information not in OIA Chronclogy.
l COMMENTS l
25, 1980, by R. A. Zieler, The NES documentation checklist dated January LII RT, on page 3 notes "NR issued to repair rejectable indication" and 12, 1980".
" corrective action prepared by T. McCall, February 1 1 l
It appears that the decision to grind out and repair the defects at film Weld sarkers 53-55 was misinterpreted to mean cut-out the entire weld.
cut-out then necessitated a new elbow, as fit-up could not be accomplished within specifications.
From a review of the weld chronology, and of statements made by Applegate, be was in contact with Peabody-Magnaflux personnel after he left the site.
Otherwise, he would not know of the NES review as noted on page 6 (Alle-gotion 1) of report 50-358/80-09.
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