ML20063A494

Petition for Reconsideration of 820730 Order Directing ASLB to Dismiss Miami Valley Power Project Eight Contentions Admitted Sua Sponte.Contentions Relate to Adequacy of QA & Util Character & Competence.Certificate of Svc Encl

ML20063A494
Person / Time
Site:	Zimmer
Issue date:	08/23/1982
From:	Bernabei L, Devine T GOVERNMENT ACCOUNTABILITY PROJECT, MIAMI VALLEY POWER PROJECT
To:	NRC COMMISSION (OCM)
References
NUDOCS 8208240362
Download: ML20063A494 (7)

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• t RC UNITED STATES OF AMERICA "' '

NUCLEAR REGULATORY COMMISSION ..3' M'" 23 A9:152 i ,

Before the Nuclear Regulatory Commfssi@4UING & SERV BRANCH In the Matter of: )

)

THE CINCINNATI GAS & ELECTRIC )

COMPANY, et al. ) Docket No. 50-358

)

(Wm. H. Zimmer Nuclear Power )

Station) )

MIAMI VALLEY POWER PROJECT'S PETITION FOR RECONSIDERATION OF THE COMMISSION'S ORDER OF JULY 30, 1982 On July 30, 1982, the Nuclear Regulatory Commission issued an order directing the Atomic Safety and Licensing Board (" Licensing Board") to dismiss eight contentions proposed by Intervenor-Petitioner Miami Valley Power Project ("MVPP") and admitted by the Board under its sua sponte authority. 10 C.F.R. S 2.760a.

MVPP petitions the Commission to reconsider its decision and allow reopening of the record in this licensing proceeding to permit consideration of these contentions concerning the adequacy of quality assurance at Zimmer and the character and competence of Cincinnati Gas & Electric Company ("CG&E") to operate the plant safely.

Petitioner MVPP also files today a petition to stop construc-tion, and by this reference incorporates that petition into this Petition for Reconsideration, n

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6 I. BACKGROUND This petition is brought by the Miami Valley Power Project

("MVPP"). MVPP is represented by the Government Accountability Project (" GAP") of the Institute for Policy Studies.

Applicant Cincinnati Gas and Electric ("CG&E")has construction

and operating responsibilities for the Zimmer station, which is 40 percent owned by CG&E. The other joint applicants are golumbus g

and Southern Ohio Electric Company and Dayton Power and Light Company. The principal contractor at the site-is the Henry J.

Kaiser Company (" Kaiser"). The architect / engineer is Sargent

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and Lundy ("S&L").

During 1981 Zimmer was the subject of extensive NRC investigations. In 1981, the Office of Investigation and Enforcement ("IE") began a massive re-investigation of alleged safety problems at the Zimmer plant. On April 8, 1981, the NRC issued an Immediate Action Letter ("IAL") which imposed a

{ Quality Confirmation Project, as well as management reorganization

[ on CG&E. CG&E was also forced drastically to increase its staff l

for the Quality Assurance ("QA") program on site. The thrust of the IAL was to require CG&E to assume a more direct, active role in the QA program.

During the summer of 1981 the Office of Inspector and Auditor ("OIA") conducted a criminal investigation into intentional violations of 10 C.F.R. Part 50, Appendix B, the NRC QA regulations.

Among the issues investigated were alleged falsification of QA documents and intentional failure to conduct quality control inspections. The investigation was suspended due to alleged difficulties of coordinating multiple NRC inquiries at once. ,

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In response to a GAP disclosure on behalf of Thomas Applegate during 1981, OIA also examined a previous IE investigation into Mr. Applegate's allegations about safety problems at Zimmer. On August 7,1981, OIA completed its report: Special Inquiry re:

Adequacy of IE Investigation 50-358/80-9 at the William H.

Zimmer Nuclear Power Plant, Office of Inspector and Auditor, U.S.

Nuclear Regulatory Commission (August 7,1981) ("OIA Reporg").

The OIA Report found that the Region III investigation was unsatisfactory and had wrongly rejected Mr. Applegate's allegations of unacceptable welds at Zimmer.

During the Spring of 1982 MVPP learned that the IE Report identified only a small portion of the deficiencies in the Zimmer QA Program.

On May 18, 1982, MVPP moved for leave to file eight new contentions related to the QA breakdown. The proposed contentions are: 1) CG&E has failed to ensure that the as-built condition of l the plant reflects the final accepted design; 2) CG&E has failed to maintain adequate material traceability to identify and document the history of all material, parts, components and welds;

3) CG&E has failed to maintain an adequate QA program for vendor purchases; 4) CG&E has failed to maintain an adequate quality assurance program to identify and correct construction deficiencies;

5) CG&E has failed to maintain adequate controls to process and respond to internal Nonconformance Reports ("NR's") ; 6) CG&E has failed to prevent illegal retaliation against QA/QC personnel who diligently attempted to perform their duties or who disclosed problems to the NRC; 7) CG&E's Quality Confirmation Program

fails to address or assure adequate corrective action to remedy the QA breakdown; and 8) CG&E does not have the necessary character and competence to operate a nuclear power plant. On July 8, 1982 MVPP submitted additional do.cumentation in support of its proposed contentions.

On June 10, 1982 the House Subcommittee on Energy and the Environment of the Committee on Interior and Insular Affairs held hearings on the QA breakdown at Zimmer. Witnesses included rep-resentatives from the NRC, CG&E, the State of Ohio, the National

~ . Board ~ of Boiler Inspectors, and the QA workforce at the site.

On June 16, 1982 representatives from CG&E and MVPP briefed the Commission on their views of the QA break.down at Zimmer.

On July 15, 1902 the ASLB, sua sponte, reopened the licensing hearings and admitted MVPP's proposed eight contentions for litigation.

On July 30, 1982, the Commission issued an Order holding that the Board had improperly exercised its sua sponte authority to reopen the licensing hearings and admit MVPP's proposed eight conentions, and directed the Board to dismiss the contentions.

The Commission stated that it believed the NRC Staff could adequately monitor the applicants' Quality Confirmation Program and the issues raised by the contentions would be resolved in l the Staff's ongoing investigation.

e II. THE COMMISSION HAS ABUSED ITS DISCRETION BY IMPROPERLY RESTRICTING THE LICENSING BOARD'S CONSIDERATION OF SERIOUS SAFETY PROBLEMS AT ZIMMER.

The Board raised these eight contentions sua sponte after finding that the total QA breakdown at Zimmer had created an extraordinary situation:

The Staff has identified Zimmer as a plant with a serious quality assurance breakdown. Fines have been imposed by Staff and paid with respect to this breakdown. The Commissioners were re-cently briefed on this situation by Applicants and MVPP, indicating the continuing concern about the matter.

Board Order, at 7.

Under 10 C.F.R. S 2.760a, licensing boards possess the authority to raise issues sua sponte upon making a finding that 1

"a serious safety, environmental, or common defense and security matter exists." Texas Utilities Generating Company (Comanche Peak Steam Electric Station, Units 1 & 2), CLI-81-24, 14 NRC 614 (1981).

Licensing boards clearly have responsibilities independent from those of the Commission staff. Judicial decisions have held that it is not only the responsibility, but the affirmative duty of licensing boards to explore in public hearings safety issues of concern. Recently the Licensing Appeal Board for Diablo Canyon held that the Licensing Board was required to look carefully at the applicants' security plan, since it was a matter of concern to inter-venor and staff. The fact that the parties to the proceeding wanted it to be litigated was an important reason that the Appeal Board found it needed public airing. The Appeal Board found a full on-the-record hearing required by due process, as well as by the

6-Administrative Procedure Act. Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2) , ALAB-580, 11 NRC 227, 230 (1980). See also, Northern States Power Company (Monticello Nuclear

' Generating Station, Unit 1) , ALAB-611,12 NRC 301 (1980), in which an Appeals Board held that in light of the controversy surrounding the issue of anticipated transients without scram, the Board was not only authorized, but " obligated" to examine the issue.

Commissioner Gilinsky, in his separate opinion, recognized the importance of a public hearing when he wrote, "(a]1th'ough this

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is not the most efficient means of handling this matter, it will be needed until the Commission and the NRC staff deal with quality assurance more effectively." CLI-82-20, slip gg.

The sua sponte authority of Atomic Safety and Licensing Boards has been continuously expanded in recent times, in recognition of the important role they play in the licensing process. Prior to 1974, they could exercise this ' authority only in " extraordinary cir-cumstances," and only af ter overcoming the presumption that the parties had adequately shaped the issues that needed to be heard, and the regulatory staff and the Advisory Committee on Reactor Safeguards ("ACRS") in their reviews had adequately addressed the issues. However, the Commission held in Consolidated Edison Company of New York (Indian Point Nuclear Generating Station, Unit 3), CLI 28, 8 AEC 78 (1974), that licensing boards should not be restricted j in exercise of their sua sponte authority. It stated explicitly that licensing boards, as "the agency's primary fact-finding tribunal

( in the hearing process" must be allowed to explore issues that it considers important. To compel the Boards to refer safety matters l to the staff for resolution would be insulting to their " stature and I

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re spo nsibility. " Ibid. The Commission also emphasized that each Board was expressly composed of two technical experts and a lawyer to make decisions on technical issues, and that these decisions should be made openly, on the record, af ter giving the parties an opportunity to be heard. Id., at 8-9. See also, Northern States Power Company (Prairie Island Nuclear Generating Plant, Units 1 & 2),

ALAB-419, 6 NRC 3, 6 (1977), in which the Appeal Board held that a licensing board's judgment as to what is in controversy in a pro-ceeding is entitled to great respect.

In order to ensure that the scope of the Board's powers was not unduly restricted, the Commission subsequently deleted the

" extraordinary circumstances" criterion of 10 C.F.R. S 2.760a, effective November 30, 1979, and stated explicitly that the amended rule would thereby " eliminate an apparent restriction on boards as well ao more accurately reflect current NRC adjudicatory board practice." 44 Fed. Reg. 67088 (November 23, 1979).

The July 30, 1982 Order of the Commission can be seen as an unwarranted attempt to return to the old rule that unduly restricted licensing board's authority to consider safety issues they considered important. Moreover, simply because MVPP, an intervenor, originally proposed the eight contentions, the Board should not be barred from l raising these same issues sua sponte. As any adjudicatory body, the Licensing Board must depend in large part on the facts, information, and issues brought to its attention by the parties. It should not i

l be constrained in the exercise of its authority merely because as any adjudicatory body it does not have the resources, nor is it its

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role, to investigate overall QA problems at Zimmer. Further, as i

argued in MVPP's Motion for Leave to File 5ew Contentions, the NRC Staff consistently failed to inform the Board about these matters.

The Staff merely told the Board that the IE and OIA Reports, des-cribing in part the major QA breakdown at Zimmer, were located in the Public Documents Room, but provided no further information.

Contrary to the implicit argument by the Commission that the Licensing Board and the NRC Staff would perform identical monitoring functions in overseeing the QCP and CG&E's corrective actions, the roles of the Board and of the Staff are decidedly different. A Licensing Board is authorized to conduct a public, independent review of the Staff's work, on all issues properly raised by the parties or by the Board itself. As a technical body, the Board is authori::ed to resolve issues raised about whether the plant as constructed is safe, and whether it is cost-beneficial, according to the balancing mandated by the National Environmental Policy Act. W The NRC Staff is a party in the licensing proceeding, in part as a representative of the public interest. The Staff also, however, has a dominant role in assessing the radiological health and safety aspects of nuclear reactors pursuant to 10 C.F.R. Part 2, Appendix A,W and making a recommendation as to whether the utility-applicant should receive a license to operate the plant. The staff makes an

- Its sua sconte authority has been called "a residual power to delve into any serious matters which it uncovers, even if no party has put then into issue."

Cbnslidated Edison Ccruparr/ of New York (Indian Point, Units 1, 2 & 3), ALAB-319, 3 NRC 188 (1976).

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- At the construction permit stage, Miere an adjudicatory hearire is marrhtory, Boards are authorized to rely on the Staff or ICRS reviews if their conclusions are not controverted by any other party. 10 C.F.R. Part 2, App. A, SS V(f) (1), V(f) (2) .

independent recommendation as to the licensing of the plant on all matters not brought into issue by an intervenor or the Board itself.

10 C.F.R. SS2.760a, 2.105(e), 50.57. See, South Carolina Electric &

Gas Company (Virgil C. Sumner Nuclear Station, Unit 1), ALAB-663, 14 NRC 1140, 1156 (1981).

However, the Licensing Board's authority to raise safety and environmental issues sua sponte, regardless of the Staff's position, has been uniformly upheld. Consumers Power Company (Midland Plant, Units 1 & 2) , ALAB-132, 6 AEC 431 (1973) (adequacy of quality assu-rance program); Southern California Edison Company (San Onofre Nuclear Generating Station, Units 2 & 3) , ALAB-268, 1 NRC 383, 399 '

(1975) (acceptability of exclusion area); Pacific Gas & Electric .

Company, supra, at 230 (adequacy of security plant) ; Texas Utilities -

Generating Company, supra, at 615 (quality assurance program).

The Board in this case has especially good reason to exercise its authority to ensure public litigation of these QA and " character and competence" issues. Zimmer may be the most troubled plant in the country. In releasing the IE Report, Region III Administrator James '

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Keppler characterized the QA program at Zimmer as " totally out of control." See, Cincinnati Enquirer. Article, November 26, 1981, -

attached and incorporated herein as Attachment 1. When asked by the Commission at a briefing on June 7, 1982 why Zimmer's problems I

were not detected earlier, Keppler stated it was a problem of not seeing the forest for the trees, not understanding that the indi-vidual nonconformances, harassment of QC inspectors and improper QA records were symptoms of a structural failure of the program.

Briefing, June 7, 1982, Tr. at 9. The Board, in raising these QA

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and " character and competence" contentions sua sponte has embraced Mr. Keppler's recently-found wisdom, and determined that such serious issues unarguably must be resolved publicly. _

It is instruc-tive that Mr. Keppler and the NRC Staff supported reopening the licensing proceedings.

Public adjudicatory hearings benefit the public in many ways.

The Board recognized the necessity of hearings in this case when it found:

(Wie believe that a full public airing of this --

matter will not only contribute to public con- _

fidence , but will also strengthen the QA.. pro-- --

gram. Subjecting the program to the scrutiny of the Commission's adjudicatory process can only ~ - - - ~ ~ ' ~~~

contribute, not detract, to reasonable assurance that the public health and safety will be pro-tected.

l Board Order at 7-8.

l In March 31, 1981 testimony before the Subcommittee on Nuclear

! Regulation of the Senate Commission on Environmental and Public Wo rks, former Commissioner Bradford pointed out that--

[W]e look to public hearings to serve two purposes.

They should provide a strong and skeptical inde-pendent check on the NRC'~s internal reviews, and they provide the only avenue for. citizens to re-solve concerns about a new and serious hazard being introduced into their communities.

For example, the Licensing Board de'nied applicants a ful -' - - --- '

power operating license on the basis of deficiencies in the emergency planning program. See Initial Decision, June 21,:1982. The Staff, on the other hand, found applicants' overall performance in the i full-scale emergency exorcises satisfactory while listing some weaknesses in the program. See, Systematic Appraisal of Licensee Performance ("SALP") Report, June 1982, at 9. The Licensing Board's

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• insistence that the applicants improve their emergency planning program will serve to enhance Zimmer's safety in the event of an accident and increase the public's confidence.

MVPP argues strongly in Part II, infra, that a " strong and skeptical independent check" is precisely what is needed in this case, considering the NRC Staff's long-term failure to monitor the QA program sufficiently to assure the public that Zimmer is being constructed and will be operated safely.

Focusing, however, on Commissioner Bradford's second factor, MVPP believes the Commission must realize the urgency of public hearings on potential safety problems at Zimmer. Both the Cin-cinnati and national press have examined intensely the QA failures and hardware problems at Zimmer. The House Subcommittee on Energy and the Environment held a hearing on June 10, 1982 on Zimmer, and will hold a second one on September 14. The Commission itself, on June 16, 1982, held an unusual session in which it asked both CG&E and MVPP representatives to discuss the problems at the plant. In November 1981, the NRC issued a massive report on the QA breakdown, and levied an unprecedented $200,000 fine against CG&E for falsifi-cation of records, harassment of QA inspectors, and improper QA/QC '

procedures. The, Staff continues its investigation into allegations of safety problems. A criminal investigation focusing on CG&E's possible involvement in falsification of records was reactivated this past June. See Keppler Briefing, June 7, 1982, at 59.

Mr. Keppler now admits publicly that there are " hardware problems" l

at Zimmer. In response to a request from Congressman Udall about the status of the QCP, Mr. Keppler recently wrote that the following i

. e.

hardware problems have been found at Zimmer:

(1) Of 259 cable tray foot connections inspected, 253 were nonconforming in some manner. Associated with the 253 nonconforming connections were 975 deficiencies.

(2) Of 161 drywell steel beams inspected, 93 were nonconforming in some manner. About 369 deficiencies were associated with the 93 nonconforming beams. -

(3) Of 106 beams inspected of gallery steel in the control rod drive area, 39 were nonconforming in some manner. _

(4) About 150 of the 208 structural steel beams inspected in the control room were found to be nonconforming in some manner.

About 1835 deficiencies were associated with these nonconforming beams.

Mr. Keppler also reported substantial documentation problems:

(1) A review of 2354 small-bore piping drawing; disclosed heat number discrepancies on about 20 percent of the drawings.

(2) Review of over 1900 purchase orders for piping disclosed heat number discrepancies on about 20 percent.

i l (3) Of 3206 purchase order reviewed, the Program found some unapproved vendors, some upgrading of non-essential material to essential, and unsigned certified material test reports.

l The Staff also questions CG&E's preliminary assessment that all welders presently working on site are qualified, and that all material presently being installed has been purchased from qualified vendors. See Keppler Response, attached and incorporated herein as Attachment 2.

Region III has found that the QCP has disproved, rather than

I confirmed, the quality of construction. Moreover , the number of workers willing to come forward and risk retaliation to disclose what they believe are potentially serious safety problems at the plant continues. Under these circumstances, the Commission cannot foreclose hearings on the QA issues without denying the public its opportunity to " resolve" their concerns about whether or not Zimmer has been constructed, and will be operated, safely.

Intervenor's due process rights are also implicated in the Commission's reversal of the Licensing Board's decision. MVPP sub-mitted only as much documentation as it believed was required as basis for its proposed eight contentions. Subsequently, the Board raised the eight contentions sua sponte, and MVPP was not required to submit all the documentation and affidavits it had collected to support the contentions. Attached today in support of this Petition for Reconsideration and MVPP's companion Petition to Stop Construc-tion, MVPP has included new information that surely provides sufficient basis for the eight contentions. The Commission cannot now deny MV2P's Petition for Reconsideration on the ground that MVPP failed to provide this evidence at a prior time to the Licen-l sing Board. Relying on the Licensing Board's adoption of its proposed contentions, MVPP was not required to submit all of its evidence. To deny MVPP's petition at this point on the ground it did not originally provide enough information would deny it its due process rights to a fair and rational adjudicatory process.

In the last three months, the public 's concern about the integrity and character of CG&E has grown as statements CG&E l

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of ficials made to the Commission and Congress have been refuted by internal CG&E and Kaiser memoranda. Contrary to CG&E's claims that it did not interfere with Kaiser's QA program, or deny Kaiser ade-quate staffing, these documents demonstrate that CG&E has closely monitored and usually controlled the Kaiser QA program since 1973.

Moreover, Kaiser requests for more staffing were repeatedly denied since that time. See, MVPP Petition to Stop Construction, Part IV.

The applicant additionally has misrepresented to the Commission the details of the current QCP, including, for example, the In-Process Inspection Deficiency Record ("IIDR") system. See, Devine Letter, July 9, 1982, attached and incorporated herein as Attach-ment 3.

These statements by CG&E officials have been questioned publicly by MVPP, GAP, Congress and numerous media representatives.

There can be little doubt that the public is concerned, with good reason, about the integrity of CG&E and its ability to comply voluntarily with NRC regulations.

The Chief Administrative Judge to the Atomic Safety and Licensing Board Panel, B. Paul Cotter, Jr., has listed additional benefits of the Board hearing not considered by the Commission in its July 30, 1982 order:

1) Staff and applicant reports subject to public examination are performed with greater care;

2) preparation for public examination of issues frequently creates a new perspective and causes the parties to re-examine or rethink some or all of the questions presented;

3) the quality of 3taff judgments is improved by a hearing process which requires experts to state their views in writing and then permits oral examination in detail; and

4) Staff work benefits from two decades of hearings and Board decisions on the almost limitless number of technical judgments that must be made in any given licensing application.

Memorandum from ASLB Chief ALJ B. Paul Cotter, Jr., to Commissioner i

Ahearne on the NRC Hearing Process, May 1, 1981, at 8.

In this case the NRC Staff at Zimmer is making important policy decisions about the extent to which applicants must re-examine and certify the quality of completed construction, and ,

about whether CG&E, as lead applicant, has the character and com-petence to operate Zimmer safely and in compliance with NRC regu-lations, when' CG&E officials may be questioned in connection with a criminal investigation for f alsification of QA records and intentional violations of the Atomic Energy Act. The NRC Staff should be accountable to the public for these decisions, especially l when there are deep differences of opinion within the agency itself.

Mr. Keppler, the NRC Staff and Licensing Board advocated reopening the proceeding for consideration of MVPP's eight contentions.

Other NRC Staff are known to oppose hearings. Under these cir-l cumstances, the Commission must choose a public airing of the con-troversy to dispel the public's doubt about the Commission's commitment to make Zimmer safe. As discussed in Part III, infra, the NRC Staff had serious differences of opinion about the final form of the IE Report. Mr. Kappler also d.sagreed with his investigative staff about whether or not to stop construction at Zimmer pending some progress on the mass of QA problems at the l

plant uncovered by April 1981. See, Part IV, infra.

The QCP and the needed corrective actions by CG&E are part of a lengthy process. Certainly the record built at adjudicatory hearings will aid the Staf f in determining the quality of construc-tion at Zimmer. As Judge Cotter noted, The NRC hearing process builds permanent records in an organized fashion on a host of managerial and scientific issues for future reference. There is little, if any, merit to the argument that some other system, such as informal meetings or dis-cussions, could replace the completeness, con-tinuity, and consistency that the present system has built over the last two decades and permanently records in licensing and Appeal Board decisions.

Id., at 17--18. !

It is only through public participation in the licensing process that those who live in the vicinity of Zimmer will accept the plant or recognize legitimacy for the NRC's authority to grant or deny CG&E an operating license.

The public's contribution to the licensing process has already been recognized by the NRC Staff. MVPP, as intervenor, and its counsel GAP disclosed to the NRC many of the original allegations 1

that forced Region III to re-examine the CG&E QA program. Mr. Keppler recognized in testimony before the House Subcommittee on Energy and j the Environment that it was GAP and not his own investigators who first uncovered Zimmer's problems. See, Cincinnati Encuirer Article, June 11, 1982, attached and incorporated herein as Attachment 4.

In this licensing proceeding, as in many others, intervenors can i make a substantial contribution to the airing of important safety issues.

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- ?a Keeny Camission, and the NBC's interral (.:becvin) iruestigation in the aftamath of the 2MI-2 accident recamenisi greater public participation.

D.e Joint Cmmittee en Atanic Enercy recognized long aco that t's boards

'aculd provide a "nore searching, more authcritative evaluation of safety factors than is pssible under the aptenate court type of reviea.. . ." 5. Rep. No. 1677, 37th Cong. , 2d Sess. (1962) , at 75.

III. THE NRC STAFF HAS DEMONSTRATED IT IS NOT CAPABLE OF ADEQUATELY MONITORING APPLICANTS' QUALITY ASSURANCE .

PROGRAM BY ITSELF.

i The NRC Staff has failed to assure the public that on its own

it is capable of monitoring CG&E's conduct to ensure that Zimmer is and has been constructed so as to protect public health and safety.

1 In 1981 the Office of Inspector and Auditor ("OIA") and the Office of Investigation and Enforcement ("IE") conducted major investiga- .

tions of Zimmeg Nonetheless, their reports have not adequately addressed the scope of the QA breakdown or the causes of serious _

safety problems. Moreover, their reforms do not address the root

causes of the breakdown or the most serious problems. OIA found l that the original IE investigation on Thomas Applegate's allega-tions (IE Report 50-358/80-09) failed to observe fundamentals basic to all government investigations. See, Memorandum from OIA Director l

Cummings to Chairman Palladino, October 8, 1981, at 2. The OIA Report found also that Region III had improperly rejected allegations of unacceptable welds brought forward by Mr. Applegate.A/ A second Region III Report on interim findings of a " reinvestigation" of

' dimmer, IE Report 50-358/81-13, issued on November 21, 1981, iden-tified 40 new noncompliances. Yet, as will be discussed below, this report was severely censored and its conclusions are subject to question.

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In a navenber 16, 1981 letter to Congressuan IEall, Chairman Palladino agreed with OIA's assessment. See Palladino Letter, November 16, 1981, attached ard iwa1. prated herein as Attachnent 5.

The Commission must reestablish its credibility in the eyes of the public, and its commitment to ensuring a thorough investiga-tion of the quality assurance and construction problems at Zimmer.

A. Since 1977 the NRC has failed to monitor adequately CG&E, even after NRC inspectors discovered severe, fundamental deficiencies in Zimmer's QA Program and CG&E's management structure.

Terry Harpster, an IE reactor preoperations specialist, worked at Zimmer from October 1977 until March 1979, as a preopera-tions start-up inspector. Harpster informed his superiors at the NRC of the following, according to an interview that was obtained by GAP under the Freedom of Information Act:

1) CG&E had no understanding of the resources needed for a-nuclear plant and barely met staffing criteria required under ANSI Standard 18.1. CG&E personnel in important positions were, not properly trained.

2) When Harpster lef t in 1979, one of Zimmer's major problems was that there was no quality assurance program for operations.

3) CG&E had minimal involvement with the construction of Zimmer and therefore no CG&E staff had the expertise necessary to operate the plant af ter turnover from Kaiser.

4) Harpster characterized Zimmer as "out of control" due to the problems that CG&E and Kaiser employees could not handle.

5) William Schwiers, CG&E QA Manager, was a friend of Earl Borgmann and appeared to be assigned to keep the plant manager Schott under control; Schwiers had tried to have IE Reports changed.

6) One assistant plant manager told Harpster that he was l ._.

afraid to tour the plant because of the convicted felons who worked on the. site.

7) Pressure was put on inspectors not to find deficiencies because of the tight schedule for construction and the licensing l l

process. Because of the high financial stakes, they usually did what they were told.

, 8) CG&E plant manager James Schott misrepresented certain f acts to the ACRS and agreed to correctthe misimpression; instead

Schott made the misrepresentation even worse, and more misleading. i l

See Harpster Interview, attached and incorporated herein as Attach-ment 6.

Harpster, in this six-page interview, neatly summarizes the problems Region III investigations were to find de novo in 1980 and 1981. Mr. Keppler, questioned by Commissioner Gilinsky during the June 7, 1982 briefing about why the NRC was discovering these prob-i lems so late in the licensing process was told, "We were not able to make connections of seeing the forest for the trees.... I think we were focusing on symptoms and not on the root causes of problems."

Transcript at 9. Mr. Keppler also suggested that Applegate's allegations, forwarded to the NRC in 1979, were the first inkling he had of any problem. Yet Harpster spoke to Mr. Keppler and others at Region III about the QA breakdown at Zimmer fully two years before.

Some NRC inspectors agree with MVPP that the problems at Zimmer should have been detected three to four years ago. Reactor inspector Fred Maura, in a memorandum to Robert Warnick dated April 22, 1981, concluded , af ter writing up his investigation of Zhmner diesel generator subsystems:

The NRC shall determine why it failed so miserably during its routine inspection pro-gram in identifying and correcting the prob-lems now surf acing at the Zimmer site. These are problems which should have been detected or corrected two or three years ago. Either our inspection program, the inspectors, our management, or a combination of all three allowed these problems to exist for so long. . . .

! Our findings raise the question shether Zbmner's l problems are an isolated case or whether our program has allowed similar problems to develop in other plants within our region.

See Maura Memorandum, April 22, 1981, attached and incorporated herein as Attachment 7.

B. The NRC's Comprehensive IE Investigation of ZLnmer Issued in November 1981 Was Severely Censored and Its Conclusions Changed Af ter Internal Policy Debate Within the Staff.

On November 21, 1981, Region III issued an interim report on a massive investigation of Zimmer, IE Report No. 50-358/81-13 ("IE Report"). The IE Report identified noncompliances that violated i

12 of the 18 criteria that define the requirements for an adequate quality assurance program. 10 C.F.R. Part 50, Appendix B.

The NRC also proposed a $200,000 fine, the largest in history for a nuclear plant under construction. The fine was levied for the following reasons:

(1) $50,000 for falsified quality assurance records; (2) $50,000 for harassment of and retaliation against QC inspectors; and (3) $100,000 for failure adequately to document and implement the QA program.

On July 26, 1982, CG&E paid the fine.

A criminal investigation to look into possible criminal violations concerning intentional f alsification of QA records and

T violations of the Atomic Energy Act was begun. At least one top CG&E official, Mr. Schwiers, was questioned in connection with this criminal investigation. IE Report, at Exhibit 52.

During the Spring of 1982 MVPP discovered that the IE Report identified only a small portion of the deficiencies at Zimmer and did not include some of the most significant af fidavits and state-ments that were taken by investigators. One of the excluded affi-davits is of a former Butler employee, attached to unis petition as Attachment 11. Another is the affidavit of an unidentified witness, attached to this petition as Attachment 10.

More importantly, MVPP learned that the final IE Report had changed significantly from an earlier draf t and its basic. conclu-t I

sions were changed to justify less drastic action by the NRC. against CG&E. MVPP learned of these deficiencies through discussions with confidential sources within the NRC, official inquiries,and infor-mation disclosed to MVPP by former and present Zinmer employees concerned about Zhmner's safety. Counsel for MVPP also made numerous FOIA requests to obtain the underlying documentation to the OIA and IE Reports.

In short, although the utility was subjected to apparently i severe sanctions, the NRC investigations and the unexpurgated reports contained information much more damaging to CG&E. They originally documented more serious deficiencies at Zimmer with greater specificity; began to probe the causes of the QA breakdown; l

suggested knowledge and involvement of CG&E in possibly criminal activities, including intentional violations of the Atomic Energy Act and falsification of QA records; and stated that some hardware l

problems had been found at the plant. MVPP will detail some of

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l l these differences between the draft and final versions of the Report. However, the differences in the two can be seen in capsu-lized form by comparing the introductory summary of facts of the draf t version with the summary of the final Report:

I DRAFT:

The current investigation has identified a number of quality-related problems at the Zimmer site.... Al-though some actual construction deficiencies have been identified, the majority of the problems iden-tified to date focus on the ineffectiveness of con-trols Luplemented by the licensee and its contractors for assuring the quality of work performed. In addi-tion, ... numerous problems have been identified with respect to the accuracy of quality-related records.

This matter is being reviewed by the NRC Office of w n and Auditor for possible criminal con-Inspect' siderations. Draft IE Report, at 6-7.

FINAL REPORT:

The impact of the identified quality assurance deficiencies on the actual construction has yet to i be determined. ...Although a few problems requiring

! corrective action were identified, the majority of the tests and exmninations disclosed no hardware problems.

Recognizing the significant quality assurance problems identified during the investigation, the NRC has required the licensee to establish a com-prehensive Quality Confirmation Program to deter-mine the quality of the system's importance to safety. The NRC will confirm the adequacy of the licensee's program. ... Deficiencies...will require resolution prior to issuance of an operating License.

IE Report, at 7.

Overall the final IE Report omitted some of the most damaging interviews that explained how CG&E had great control over Kaiser's QA program and QA staffing. Mor eover, the final report did not mention the criminal investigation of CG&E officials for falsifi-cation of QA records; it suggested that there were no hardware l problems, although the latest reports to Congress indicate that

the QCP has found numerous hardware problems; and tried to discredit GAP and Mr. Applegate. It did not quantify deficiencies, did not attempt to determine the root cause of noncompliances, and did not follow up on leads. Numerous employee interviews were edited or rewritten to weaken their statements that indicated CG&E knew of, and were involved in, violations of NRC regulations.

1. CG&E had a dominant role in the QA Program at Zimmer A major conclusion of the IE Report was that CG&E did not know about the Kaiser QA practices. Mr. Keppler told the CommissionL__

as late as June 7, 1982, that he believed the root cause was CG&E's lack of oversight and abdication of responsibility to Kaiser at the site. ,

Yet the following deleted portions of the Draf t IE Report directly contradict that conclusion:

(a) A July 8, 1981 interview of Phillip Gittings, former Kaiser QA Manager, conducted by OIA and sent to Region III, but excluded from the Final IE Report, indicates CG&E denied Kaiser adequate QA/QC staffing even though the utility knew Kaiser could not comply with 10 C.F.R. Part 50, Appendix B. See Gittings l Interview, attached and incorporated herein as Attachment 8.

Gittings told the investigators that prior to his tenure at Kaiser the company's QA/QC organization had failed to comply with NRC regulations. He also stated that Schwiers had refused his prede-cessor Robert Dramr's frequent requests for additional QC personnel.

Gittings also suggested that he had dif ficulties obtaining adequate personnel for Kaiser QA because of CG&E's control over staffing.

He said Kaiser was "doing the work for a very tough client" who had

to approve all additional manpower requests. Although Gittings was not afraid of Kaiser's site construction manager Schwiers, he stated that his top priority on the job was to get along with Mr. Schwiers.

An interview the next day with William Schwiers, included as Exhibit 52 to the IE Report, confirmed Gittings' statements in i

part. Schwiers said if documentation established that CG&E re-fused Turner's requests for additional QA staff, these CG&E decisions would have been made at CG&E management meetings. Schwiers further said that in attendance besides himself were Project Manager Barney Culver, and supervisors for the Generation and Construction Depart-ments. Schwiers said he did not remaMxr if Vice President Earl l

Borgmann, to whom he reported, attended these meetings.

Both these interviews were forwarded to IE under cover of a November 18, 1981 memorandum from OIA Director James J. Cummings that explained these inte:: views were taken in connection with an OIA investigation of potential falsification of QA records. Also included under cover of this memorandum was a November 7, 1981 joint memorandum signed by three CG&E officials and one Kaiser repre-sentative that instructed Kaiser to eliminate the requirement that all QA documentation be reviewed prior to release of systems from the construction department to the Electric Production Department for preoperational testing. See Cummings Memorandum and Joint Memorandum, attached and incorporated herein as Attachment 9.

The Cummings' cover memorandum, Gittings' interview, and the CG&E-Kaiser memorandum all demonstrate CG&E's refusal to allow l

Kaiser to staff its QA program adequately to meet NRC requirements.

l All directly contradicted the Report's conclusions that CG&E had

l abdicated control for the QA program to its contractor.

(b) Improper voiding of nonconformance reports ("NR's")

occurred even after NRC inspectors met on December 2-3, 1980 with CG&E and the Kaiser QA Manager and told them that improper voiding of NR's was a violation of NRC regulations, including 10 C.F.R. Part 50, Appendix B, Criterion V.

The QA Manager on three occasions after that meeting directed NR's to be voided (CN 4309, NRC 0001 and CN 5412) and did not enter l one other NR into the Kaiser NR Reporting System.

The draf t report concluded that CG&E had failed to take corrective action to prevent recurrence of improper voiding of l 11R's or failure to record NR's even af ter the December 1980 NRC 1

investigation.

(c) An affidavit by an unidentified, former Kaiser l Assistant QC Manager stated definitively that in November 1976, Kaiser QA Manager William Friedrich was replaced due to longstanding disputes with CG&E QA Manager Schwiers. 'Friedrich, according to this affidavit, insisted on hiring more inspectors and wished to I conduct the QA program in accordance with accepted standards of l

( the nuclear industry. Schwiers, on the other hand, did not want l to increase QA staffing because he did not believe CG&E should l

spend the money. According to the af fidavit, Friedrich's replace-ment Robert Turner also had the same problems at the site. The af fiant claims that Zbmmer only had 25 in-process line inspectors at the site whereas other plants had 300 to 350 inspectors; Zimmer

! had eight or nine QA engineers, whereas other plants had from 30 to 50. He also said that CG&E management was unwilling to commit

itself to a QA program meeting nuclear industry standards as shown by the following:

(1) Receipt inspections were inadequate; (2) In-process inspection was inadequate and documentation was poor; (3) Source inspection was inadequate; (4) Vendor audits were inadequate; (5) As-built designs were not available to craf t personnel; and (6) Vendor-supplied items had poor quality welds.

See Affidavit, attached and incorporated herein as Attachment 10.

The final Report included strong evidence in the interviews accompanying the Report of CG&E's directive role in Kaiser's QA program. However, some portions of these interviews were never mentioned in the text of the IE Report. For example, Stewart Tulk gave investigators specific examples in which Kaiser Construction Superintendent Robert Marshall and Schwiers ordered a " hold tag" to be changed to a " rework tag" in the cable room so construction would not be stopped. Tulk said he reinspected this room 18 months later and found the same nonconforming conditions. IE Report at 134-35.

2. Retaliation and harassment were not adequately investigated.

NRC investigators uncovered intriguing leads on the physical harassment of QA/QC personnel at the Zimmer site, and evidence of I

retaliation by Kaiser management against conscientious QA/QC inspectors. Yet this significant information was either omitted from the final Report or its importance denied.

(

l (a) Kaiser had contracted with Butler Services Group, Inc. (" Butler") for personnel to staff the QA program.

The contract was terminated in November 1980, and Kaiser itself hired 17 of the Butler inspectors for its own QA organization.

Gittings, in the interview excluded from the final Report, stated that the reason for eliminating 34 Butler inspectors

[ was at least in part " cost cutting" and " eliminating 'over inspecting'." The Butler employees who were not rehired by Kaiser and left Zhamer claim that Kaiser was attempting to exert control over the QA program to ensure QC inspectors did not delay construction. Affidavits from all former Butler employees except one were included in the final IE Report, but the text of the Report did not mentioned these Kaiser actions.

l l See Butler Affidavits, attached and incorporated herein as Attachments ll-A through ll-F. Moreover, eliminated from the l

final IE Report was a statement by Rex Baker, former Kaiser Engineer, that concluded inspectors hired from Butler Services were fired because they were critical of Kaiser's QA inspection procedures and techniques. After terminating the contract, Kaiser offered jobs to those who were not critical and would go along with Kaiser procedures, Baker added, in a statement included in the draft report.

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(b) At least three Zimmer employees gave NRC investiga- 1 l

tors nicknames of construction workers suspected of dousing QA personnel. The investigators evidently never followed up to inter-view these construction workers. See Tyree, Price and Hamm, Sr.

Interviews, IE Report, at 127-29.

Three other inspectors said they had been harassed by searches by security personnel. See Pallon, Jr., Miller and Sullivan Inter-views, IE Report, at 126-27.

The investigators apparently never interviewed the security guards who did these searches.

Inspector David Hang said a pipefitter threatened him with bodily harm if he did not pass a weld. IE Report, at 133. No evidence is offered that the NRC interviewed that pipefitter.

Finally, Jesse Ruiz said Robert Marshall told his workers i

that anyone throwing water on a QC inspector would be fired, but l

l none of these incidents were ever in'vestigated by management. IE Report, at 129.

(c) Retaliation by Kaiser management against conscientious inspectors was ignored or buried in the final IE Report. The Report l

l quotes Gittings' suggestion that Baker transfer QC inspectors James 1

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Ruiz, L. Q. Hendley and P. S. Wimbish for, among other things, nit-picking inspections. IE Report, at 130. Included in the draft report was a clearer explanation for Gittings' actions, explained by Rex Baker. Baker states simply, in the draft, that Gittings suggested that he reassign QC inspectors Ruiz, Hendley and Wimbish because they were " nit-picking" during their inspections and writing up too many nonconformance reports. Baker disagreed, and said

that he believed that the three inspectors were writing valid nonconformance reports and following Kaiser procedures. Baker said he did move Ruiz and Hendley from weld inspections in the reactor building to inspections in the fabrication shop.

The final Report suggests that Gittings wanted the three to be moved to avoid " future foreseen problems" and that Hendley was moved to the pipe support fabrication shop because of his proven ability in this area. IE Report, at 130. .

3. Understating the extent of the problem.

The final IE Report failed to quantify many of the noncom-pliances investigators found, or to explain the significance of the noncompliances.

(a) CG&E procedures required that surveillance reports

("SR's") be transferred to nonconformance reports within 30 days if the nonconforming condition were not satisfied. Although the re-cording of nonconforming conditions solely on SR's was a major problem at Zimmer and included in the QCP, the . final IE Report gives no indication in quantitative terms of the severity of the problem.

It states merely that "[t]wo examples of one item of noncompliance were identified." IE Report, at 140-42.

Nor did the Report quantify the number of DDC's for which QA inspection may be inadequate. It merely states that the problem will be addressed in the QCP. Id,. , at 145.

The final IE Report identified a large number of problems with electrical cable trays, including inadequate separation of

cables and misrouted cables. IE Report, at 147-51. Yet the Report concluded that it had found only "six examples of three noncompliances." Id., at 8g.

(b) The final Report states that several thousand feet of structural hangar beams were purchased from vendors not on the approved vendor list and therefore in violation of 10 C.F.R. Part ,

50, Appendix B, Criterion VII. IE Report, at 146. It includes little other information about CG&E or Kaiser's problems with inadequate "approv6d vendor lists." However, the QCP contains a specific item that requires CG&E to survey all vendors for nclusion on approved vendor lists, and therefore indicates the NRC's focus on the deficiency. IE Report, Exhibit 17 at 13.

A memorandum from investigator James E. Foster dated July 28, 1981 demonstrates that the NRC understood that it was understating deficiencies in the IE Report, but did so deliberately. Foster notes that the NRC formerly had approved the practice of purchases

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l from " unapproved vendors" and upgrading of materials from Class I to Class II in 1976 and 1977. Therefore, Foster wrote that the NRC should prepare an answer to explain the inconsistent philosophies.

See Foster Memorandum, attached and incorporated herein as Attach-ment 12.

The Nolder Report, an independent investigation con-ducted by Kaiser Corporate Supplier QA Engineer Sherrill S. Nolder in July 1981, concluded that perhaps the NRC and CG&E had agreed that Kaiser's failure to comply with vendor survey require-ments would not be found in violation of 10 C.F.R. Part 50, Appendix l

B. See Nolder Report, at 12, attached and incorporated herein as Attachment 13.

(c) The final Report mentioned that 1,500 NR's had been voided or superseded. IE Report, at 8-A. Yet the Report does not examine the number of NR's which were reported missing, or placed in drawers under other names and may have been irretrievably lost l

from the system. At least some Zimmer employees also told investi-gators they maintained copies of voided or " accept-as-is" NR's to protect themselves. IE Report, Exhibits 5 and 39.

4. Failure to explain investigative and reporting methods The NRC Staff gives no explanation in the IE Report for including particular interviews and excluding others.' Investi-i gators interviewed about 128 witnesses. Id., at 9-12. Only 38 l

interviews were included as exhibits to the final Report. In some l cases one witness was interviewed up to six times. No explanation I

was given for inclusion of particular interviews or only portions of interviews. In at least 30 instances references were made in the text to witness interviews that were not included in the final Report.

The interview techniques of the NRC investigators were often sloppy. For example, Victor Griffin said investigator James l Foster spoke to him for only two hours, compiled no formal state-l ment, and spent a large part of the interview arguing with him about the nuclear industry. See Griffin Affidavit, attached and incorporated herein as Attachment 14.

Richard Reiter said that only a small portion of the infor-

a mation he gave NRC investigators was included in the final IE Report. In illustration, he stated that only . two of the 200 to 300 NR's he wrote during his tenure at Zimmer were covered in the IE Report. Although Mr. Reiter agreed to talk to the Federal Bureau of Investigation about possibic criminal activity at Zimmer, he was never contacted. He also stated he was never asked whether he had information about CG&E's knowledge of improper QA practices.

See Reiter Affidavit.

5. Failure to uncover the root causes of problems at Zimmer ; split in the Staf f on policy grounds.

The IE Report does not indicate whether individual, unquantified noncompliances have affected the quality of construction at Zimmer.

Nor does it give the public any idea about the number or significance of individual examples of noncompliances. In part this is due to the Staff 's failure publicly to report on the root or structural causes i

for the problems.

Comparison of the draf t IE Report with the final version also demonstrates the deep policy dif ferences that existed within the NRC. The draf t documents more serious deficiencies and examines CG&E's deep involvement in the QA program, as well as the ongoing criminal investigation of CG&E officials in connection with falsi-l fication of QA records. Further, it states that some hardware problems have been found.

The final Report, as described above, eliminates key references to CG&E's role in the Zimmer QA program and retaliation by Kaiser QA management against QA/QC personnel who are seen as hindering

. a construction.

The final version also states that the QCP will resolve the problems and that CG&E is capable of reforming itself. Only the

' final and not the draf t of the Report could permit Region III Administrator Keppler to tell the Commission on June 7, 1982 that the reason for the QA breakdoun at Zimmer was CG&E's abdication of responsibility to its contractor.

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.- .a IV. REGION III FAILED TO STOP CONSTRUCTION AT ZIMMER IN APRIL 1981 EVEN THOUGH ALL NRC INVESTIGATORS RECOM-MENDED THAT ACTION.

On March 26, 1981, an exit interview was held among middle and senior management of Region III about the IE investigation. On l

l March 27, 1981, Good Friday, NRC investigators met with Region III Administrator Keppler to report to him their findings. The investi-gators and inspectors overwhelmingly recommended to Keppler that the NRC halt construction at Zimmer.

On March 31, 1981, Keppler and Robert Warnick, then Chief of the Reactor Projects Section, met with CG&E Vice President Earl Borgmann. Af ter that mee'cing, Keppler announced that an Immediate Action Letter ("IAL") would be sent to CG&E detailing required cor-rective measures, but the NRC would not order that construction at i ZLnmer be stopped. IE Report, at 158-59.

On May 11, 1981, GAP petitioned Region III to stop construc-tion at Zimmer in order that past construction problems could be examined and corrected, and so that future work would not be com-p promised. On May 14, 1982, in a memorandum to the file, NRC Deputy i

l Director A. Bert Davis noted that Tom Daniels, Zimmer's resident i

inspector, believed construction should be suspended pending cor-rection of all the problems. See Davis Memorandum, attached and

! incorporated herein as Attachment 15. The NRC denied GAP's request.

D.espite the strong recommendation of his staff, 21r. Keppler agreed to allow construction to proceed at Zimmer in the Spring of 1981. He later denied GAP's request to suspend construction l

even though the NRC's resident inspector believed this action was l

o necessary. It is clear that the decision to suspend construction at Zimmer was a major NRC policy decision whi h was made in closed-door meetings with NRC officials and CG&E executives.

In a case where the NRC Staff itself is deeply divided over the corrective action that should be imposed to ensure the future safe construction and operation of Zimmer, public input and over-sight are of critical importance.

Licensing hearings will develop a sound public record on the problem and the corrective actions to be taken at Zimmer. Moreover, from recent information about problems with the QCP at Zimmer, Region III's decision to place CG&E in charge of the program should be re-examined publicly. It is appropriate that the public oversee what progress, if any, CG&E has made to determine the quality of construction of Zimmer and reform its QA program. It may be that the licensing hearings will lead to modification of the QCP or conditions placed on any operating license issued to CG&E.

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. . a V. DELAYS IN THE NRC'S REINVESTIGATION OF ZIMMER AND THE CRIMINAL INVESTIGATION OF FALSIFICATION OF QA RECORDS CAST DOUBTS ON THE STAFF'S ABILITY TO MONITOR CG&E'S REFORMS.

In the Summer of 1982, the NRC conducted interviews that were intended to gather evidence on potential criminal of fenses concerning falsification of QA records. The investigation was suspended until June of this year. On February 25, 1982, investigator James McCarten urged the Director of Enforcement and Investigation Staff, Rober t Warnick, to guarantee that NRC personnel with adequate training were brought into the investigation to conduct the criminal portion, instead of ceding control to the comparatively unqualified Staff of Region III. See McCarten Memorandum, attached and incorporated herein as Attachment 16.

However, on March 19, 1982, it appeared little progress had j

been made when the United States Attorney for the Southern District of Ohio, Christopher K. Barnes, issued a press release stating that the NRC would complete its civil investigation prior to restarting its criminal investigation. See Barnes' Press Release, attached and incorporated herein as Attachment 17. Since then Mr. Keppler announced at the June 7 briefing that the criminal investigation was re-opened in June.

The NRC therefore ef fectively suspended its investigation into possible criminal conduct on the part of an applicant and its contractor, for at least eleven months, a time frame in which the utility had control of nearly all the evidence that could eventually be used to prosecute it .

• - .e Region TII also suspended its investigation into the large number of unresolved allegations about construction and QA defici-encies at Zimmer. At least 100 allegations remained to be investi-gated when the IE Report was issued last November. Nine months later, as construction proceeds at Zimmer, the NRC has yet to complete this reinvestigation, and the backlog of allegations has expanded to 200.

The NRC also has difficulty keeping adequately informed about the QCP. A month af ter asking for information f rom Region III about the status of the QCP, Congressman Udall had to renew his request.

! See July 12, 1982 Udall Letter, attached and incorporated herein as i

Attachment 18.

The commission cannot, therefore, claim that the Staff is d capable of both monitoring corrective action at Zimmer and con-tinuing the reinvestigation into the numerous allegations that remain unresolved at Zimmer. Each day construction proceeds at Zimmer, the NRC Staff's job becomes more dif ficult, since prior construction work is covered over with new construction work.

MVPP also petitions the Commission today to stop construction at Zimmer pending a complete investigation of all outstanding alle-l I gations. Given the deep divisions within the Staff about the proper course for ensuring that Zimmer is constructed safely, and given the inability of the NRC to complete its criminal and civil in-vestigations expeditiously, all construction should be stopped pending an evaluation of the QCP and the ef fect of corrective

! actions taken by CG&E thus far under the IAL.

I MVPP believes a portion of the re-evaluation of Zimmer's progress should be public. Licensing hearings, in which the public can question CG&E about its compliance with NRC directives, are now the only way the public can be convinced that CG&E will operate Zimmer safely and the NRC has a commitment to ensure enforcement of its regulations to protect the public health and safety.

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. . 4 VI. NRC STAFF ENFORCEMENT AND INCONSISTENCIES DEMONSTRATE SUSCEPTIBILITY TO CG&E PRESSURES THAT MAY COMPROMISE THE PUBLIC HEALTH AND SAFETY.

In the Spring of 1981 Region III imposed on CG&E the Quality Confirmation Program ("QCP"), a reinspection and review effort i

l intended to determine the quality of existing construction work at l Zimmer, which is theoretically 97 percent complete.

The QCP is labeled a realistic way to determine the plant's safety. Yet CG&E has successfully pressured the NRC to weaken the program since its inception. On June 2,1981, CG&E and Region III representatives met to discuss a draft of the QCP. Mutual agree-ment was reached to make certain changes. CG&E's W. D. Waymire went further, however, and made more handwritten changes. The final version of the Plan incorporated substantial CG&E modifications.

See Waymire Memorandum and Draft, attached and incorporated herein as Attachment .

For example, while the original June 2 QCP required CG&E to l

l make 100-percent visual reinspection of structural steel welds, the final version requires 100-percent reinspection of accessible structure steel welds unless CG&E can " justify less."

Although the QCP is uncovering significant hardware problems, l

the scope of the QCP has been recently reduced by the NRC. Region III authorized a 50-percent reduction of the 100-percent reinspection program,for constructor and subcontractor QC inspections. According to the NRC, CG&E requested this reduction based on its own, Kaiser's and contractors' " revised quality assurance program [s)." See

. , a Preliminary Notification of Event or Unusual Occurrence, PNO-III-82-72, August 3,1982, attached and incorporated herein as Attach-ment 20. The 50-percent reduction was allowed because " Region III

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is satisfied with the licensee's effort thus far." Ibid.

Moreover, MVPP has discovered that the NRC and CG&E, over the last nine years, have come to an accommodation about certain practices that appear to violate NRC regulations. For example, as described in Part III, supra, the NRC and CG&E apparently have agreed between themselves that purchase of materials from vendors not on the approved vendor list and upgrading of materials to essential would be deemed permissible, in spite of 10 C.F.R. Part 50, Appendix B.

Similarly, the current IIDR system is being used to violate requirements about recording nonconforming conditions on NR's, and circumvents the post-IAL commitment to implement a working NR re-porting system. Although MVPP brought the inadequacy of the IIDR system to the Commission and Staf f 's attention, and documented misrepresentations made by CG&E officials about IIDR's to the Commission, there has been no response. See, Attachment 3.

MVPP counsel has also sent an emergency letter to Mr. Keppler about the NR Action Plan, which appears to be another CG&E attempt to reduce NR's, and retaliate against those who issue them. The letter also enclosed an affidavit describing a collective decision by top 'CG&E and Kaiser management to deceive the NRC about welder qualification records. Region III has not yet answered counsel's letter. See July 15, 1982 letter, attached and incorporated herein as Attachment 21.

. , s Further, NRC investigators have leaked information about their findings to CG&E of ficials, even though their investigations were intended to be confidential. For example, CG&E received suf-ficient information about the original IE investigation to make informal repairs while the investigation was being pursued. The OIA Report found that copies of welding records documented that rework on weld RH-42 was being conducted shortly af ter the NRC reviewed and found a nonconforming condition in the vendor sheet for weld RH-42. OIA Report, at 34-35.

CG&E can, in this way, discredit the final conclusions of the NRC Staf f and stifle an investigation of greater scope that could expose serious deficiencies.

Although the NRC promised confidentiality to witnesses during its investigations, it was clear that the identities of at least some witnesses were disclosed to Kaiser and CO&E. In some cases these disclosures led directly to retaliatory personnel actions against duse employees.

For example, Rex Baker, former Kaiser Inspection Supervisor of all QC inspectors, told OIA that in January 1981 he spoke to Region III investigators about allegations of improper voiding of NR's, reassignment of QC inspectors due to pressure by Kaisel construction, and changes in OC inspection procedures. The day after the interview Baker said he was with Marshall and R. P. Ehas, CG&E QA Engineer, when they were reviewing a list of employees the NRC intended to interview. FMrshall, after reading the list, asked why Baker's name did not appear. Ehas replied, according to Baker ,

"They don't need him. He went down there yesterday .and spilled his

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- s guts to them. " Baker was soon reassigned to the position of Supervisor for Nondestructive Examination. Shortly after, when the President of Kaiser Company was touring the plant with Marshall, Marshall introduced Baker by saying, "llere's Rex Baker, the source of all my problems." See Baker Interview, at 3, attached and incorporated herein as Attachment 22 Finally, it is absolutely clear that CG&E receives secret reports on the current IC reinvestigation. To substantiate their claim that harassment and retaliation were not a major problem at the Zimmer site, CG&E officials wrote Congressman Udall that Region III's most recent findings disclosed no significant evidence of intimidation. Congressman Udall wrote to the NRC asking, in essence, how CG&E found out about NRC findings before Congress did, and be-fore a final report had been issued. See CG&E Letter of July 21, 1982, and Udall Letter of August 3,1982, attached and incorporated herein as Attachments 23 and 24, respectively.

The long delays and the gaps in the current reinvestigation, as well as in the prior NRC investigations, are further evidence that the NRC is simply unable to monitor adequately the applicants' progress in assuring the quality of the plant's construction or in remedying problems for the small percentage of ongoing new con-struction work.

Mr. Warnick has admitted to the Public Utilities Commission of Ohio ("PUCO") that Zimmer is the " biggest problem" of all nuclear plants Region III oversees. See PUCO Hearings, July 14, 1982, Vol. XI, Tr. at 51. Therefore, it seems not only sensible but necessary that the Commission open itself to suggestions from the

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I public, including MVPP in open licensing hearings, about how to l-ensure that Zimmer is constructed safely after nearly ten years of mismanagement and poor construction and QA practices.

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VII. THE NRC'S ARBITRARY AND CAPRICIOUS REFUSAL TO IDENTIFY, AND EITHER DISCLOSE OR WITHHOLD UNDER AN EXEMPTION, NRC DOCUMENTS REQUESTED UNDER THE FREEDOM OF INFORMATION ACT BARS PUBLIC EXAMINATION OF NRC DECISIONS.

On June 30, 1982, MVPP's counsel brought suit against the NRC to obtain documents it had requested under the Freedom of Informa-tion Act, 5 U.S.C. S 552, et seq. On November 23, 1981, MVPP re-quested copies of all " notes, memoranda', telephone logs, tapes, diaries and/or other records prepared by U. S. government employees in connection with the August 7, 1981 OIA Report entitled 'Special Inquiry re: Adequacy of IE Investigation 50-358/80-9, at the William H. Zimmer Nuclear Power Station,'" or the investigation leading up to the Report. The request specifically included early drafts or proposed supplements to the OIA Report. None were pro-duced; nor was there even an admission of their existence. At no time was the Harpster interview, Attachment 6, identified by the NRC. Only after MVPP filed suit against the NRC was the Harpster interview produced as an interview prepared in connection with the OIA Report. See August 10, 1982 Letter of Richard Parrish, attached and incorporated herein as Attachment 25 MVPP and its counsel believe the NRC arbitrarily and capriciously refused to identify documents clearly responsive to a proper request under FOIA.

This conduct illustrates further why the NRC should not be allowed- to monitor the reinvestigation and QCP at Zimmer without public input. The Freedom of Information Act ("FOIA" or "Act")

was enacted explicitly to allow citizens access to information about government processes. The NRC apparently is unable to

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comply with the basic principles of open government encompassed in the Act. As the government agency responsible for regulating nuclear power plants, it should .t conduct its regulatory activities in secret. The NRC's recent refusal to identify the Harpster interview simply shows that it has made policy decisions in secret for too long a period.

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a VIII. MVPP HAS MET THE LEGAL STANDARD TO REOPEN THE LICENSING PROCEEDINGS FOR CONSIDERATION OF ITS PROPOSED CONTEN-TIONS ON QUALITY ASSURANCE AND APPLICANTS' CHARACTER AND COMPETENCE TO OPERATE ZIMMER.

The Licensing Board held that MVPP did not carry its burden to reopen the licensing hearings for admission of its eight pro-posed contentions. See Board Order at 6. The Commission concurred, finding that "MVPP did not in its motion to the Board or elsewhere sufficiently identify new information, its source, or say when it became available." Commission Order at 3.

MVPP did not submit to the Licensing Board all the evidence it had collected to support its proposed contentions. It did not believe it was needed, given the substantial amount of information on the public record in support of the contentions and given that the information on the public record had never been considered by the Licensing Board. As noted above, the Staff did little more than mention to the Board that the OIA and IE Reports were in the Public Documents Room.

In addition, the major focus of MVPP's contention is the structural failings of applicants' QA program, the continuing i

I structural failings of the QCP, and CG&E's demonstrated lack of l

ho nesty , integrity, character and technical competence to operate a nuclear power plant.

In many instances, MVPP interpreted the evidence in the IE Report in a dif ferent way than the NRC staff, in light of other internal Kaiser and CG&E records MVPP obtained, and af fidavits MVPP took from former and current Zimmer employees. Morecever,

i

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a l

l MVPP did submit a substantial number of Kaiser and CG&E internal memoranda that demonstrated CG&E executives' dominant role in the QA program at Zimmer since 1973, which directly contradicts the public statements of CG&E management and the premise of the Staf f's current enforcement effort. Both the ASLB and the Commission have l

totally ignored the new evidence and its import to the " character and competence" contention, while calling for more evidence on the other contentions.

It is not reasonable to expect an intervenor to authenticate all documents through a sponsoring witness, when it first brings the information to the Board's or the commission's attention. The Commission's rules provide that contentions are merely issues sup-ported by some evidence deemed sufficiently significant by the Licensing Board to be admitted for litigation. 10 C.F.R. S 2.714.

Af ter contentions are admitted, all parties are allowed a period of discovery in which to prepare their case, and determine their position on the contentions. 10 C.F.R. SS 2.740-2.744. The l

l " source" of any documentation by MVPP in support of its contentions l

l is simply irrelevant at this stage. Unless there is a serious i

i doubt raised by a party that the documentation or affidavits have been fabricated, the Commission's concern about the " source" of the evidence is misplaced. MVPP notes that neither CG&E nor the NRC Staff has ever challenged the authenticity of the internal memoranda l

l submitted by it in this proceeding. In fact, it appears CG&E is l

concerned about finding out the source of the documents for reasons other than to verify the information contained in them.

. a Today, in its Petition to Stop Construction, MVPP submits extensive new documentation and new affidavits providing basis for its proposed eight contentions.-5/

The Commission, af ter examination of these new documents and af fidavits, simply cannot seriously conclude that MVPP has provide insufficient basis for its proposed contentions.

A. MVPP Has Met the Standard for Reopening the Record.

MVPP meets the standard for reopening the record, most recently enunciated by the Commission in the Diablo Canyon case.

In that case the Commission said the record may be reopened only upon a showing, by the moving party, of significant new evidence not included in the record which would materially affect the decision. Pacific Gas & Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 & 2), CLI-81-5, 13 NRC 361 (1981), citing with app'1, Kansas Gas & Electric Company (Wolf Creek Generating i

! Station, Unit No. 1), ALAB-462, 7 NRC 320 (1978).

l As can be seen from the extensive documentation and numerous af fidavits submitted in support of this petition and MVPP's Petition to Stop Construction, MVPP has provided signi-1 ficant new information which demonstrates the longstanding, '

structural problems in Zimmer's QA program since 1973, and i

CG&E's direct responsibility for these failures. Most of this evid_ence is not on the public record, and it will affect the Licensing Board's decision about whether or not to grant CG&E an operating license.

l b hese T documents and affidavits have been incorporated by reference into this Petition for Reconsideration.

o B. MVPP lias Met the Standard for Admission of New Contentions.

The Licensing Board and the Commission both determined that MVPP did not meet the standard for admission of late contentions.

MVPP, however, disagrees and would point out the following re-garding the five criteria of 10 C.F.R. S 2.714 for admission of late-filed contentions:

1. Good cause for failure'to file on time: MVPP moved to reopen the licensing proceeding only af ter it decided that the NRC staff could not adequately monitor CG&E's progress in remedying the serious deficiencies at Zimmer. Counsel thorough-ly studied the IE Report, identifying discrepancies between the text and exhibits, as well as significant data in the exhibits not discussed at all in the text. Cot.isel shared concerns with the NRC Staff that the report did not address the causes or full scope of the issues. There was no commitment to correct these flaws. Through congressional hearings and FOIA appeals counsel confirmed that a criminal investigation had been stalled.

Throughout this period, witnesses contacted MVPP to complain confidentially or, on the record, about NRC f ailure to act on their evidence, or about the lack of substantive reform at Zimmer. These witnesses taught counsel what has occurred since the IAL.

- Throughout this period, the NRC Staff showed no indication of addressing these structural problems. Therefore, MVPP con-ducted its own investigation, the results of which are largely encompassed in its Petition to Stop Construction. The NRC Staff

took almost a year to make " interim findings" in its reinvestiga-tion. MVPP cannot be faulted for spending six months from release of the IE Report to file its motion to reopen. MVPP began its in-vestigation only af ter realizing that the NRC was not capable alone of monitoring Zimmer, conceded to be the worst plant in Region III.

2. Availability of other means to protect petitioner's interests: MVPP moved to reopen the licensing hearing only after it concluded the NRC Staff could not adequately protect the public interest and ensure the saf e construction and operation of Zimmer.

As explained above, the IE Report did not examine the root causes for the QA breakdown; the QCP is not an adequate way to determine the quality of construction at Zimmer; and current staff efforts to investigate outstanding allegations of safety problems and possible criminal f alsification of QA records have f allen behind.

Traditionally Staff decisions on Zimmer have been the subject of sharp internal debate, to which the public is not privy. For these reasons, there are no means other than full participation in licensing hearings to protect MVPP and the general public's interest in resolving questions about Zimmer's safety.

3. Petitioner's assistance in developing the record and the extent to which petitioner's interest will be repre-sented by existing parties: MVPP and its counsel are in a unique position to develop a sound record on QA practices at Zimmer and CC&E's character and competence to operate the plant.

The evidence in the attached Petition to Stop Construction

1

- a contributes significantly to the public record.

Finally, none of the other parties has a similar interest or expertise in these issues. Numerous Zimmer employees who have worked with counsel confidentially will testify at a hearing but will not commit themselves solely to an NRC investigation, in light of the Staff's previous breaches of pronico to conduct thorough investigation

4. The extent to which reopening will broaden the issues or delay the proceeding: MVPP believes that although reopening the licensing proceeding for consideration of its eight contentions will broaden the issues before the Licensing ,

Board, it will not unduly delay the proceeding. Mr. Keppler has stated repeatedly that he does not believe the QCP will identify all the outstanding problems with construction at Zimmer until January 1983. Af ter that, CG&E must undertake corrective actions necessary to remedy those problems, and it is generally conceded that the plant cannot possibly open until late 1983 or early 1984. Current NRC reports on the status of the QCP show significant hardware and documentation problems at Zimmer that will require extensive rework and repairs. See Attachment 26. Therefore, it is unlikely that reopened licens-ing hearings will delay the licensing of Zimmer beyond the delay CG&E will undoubtedly encounter in complying with URC-mandated repairs.

,- s IX. CONCLUSION For the above reasons, MVPP respectfully requests the Commission to reconsider its Order of July 30, 1982, and allow reopening of the licensing proceedings in this case for con-sideration and litigation of MVPP's proposed eight contentions concerning the adequacy of quality assurance at Zimmer and CG&E's character and competence to operate a nuclear plant.

Respectfully submitted,

/fita, e > > - , M .

LYN "BERNABEI

_I TIlOMAS DEVINE Counsel for Intervenor -Petitioner Government Accountability Project of the Institute for Policy Studies 1901 Que Street, N. W.

Washington, D. C. 20009 202/234-9382 x. 54 DATED: August 20, 1982

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CERTIFICATE OF SERVICE , ,, , , . 9 I hereby certify that copies of the foregoing n nor MVPP'sPetitionforReconsiderationandPetition.toSuspend.

struction have been served upon the following by'ma' p g OT H g class postage prepaid, Con-[.

this 20th day of August,198J LKEUyjjgg 7 _f u.

• Chairman Nunzio J. Palladino Dr. Stanley M. Livingston,,

U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555

,a 1005 Calle Largo Sante Fe, New Mexico 87501

• Commissioner John F. Ahearne U.S. Nuclear Regulatory Commission Washington, DC 20555

• Chairman, Atomic Safety and

' Licensing Appeal Board Panel

• Commissioner James K. Asselstine U.S. Nuclear Regulatory Commission Washington, DC 20555 U.S. Nuclear Regulatory Commission

, Washington, DC 20555

• Chairman, Atomic Safety and

• Commissioner Thomas M. Roberts Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC Washing ton , DC 20555 20555

• Commissioner Victor Gilinsky Robert F. Warnick U.S. Nuclear Regulatory Commission Director, Enforcement and Washington, DC Investigation 20555 NRC Region III

• Leonard Bickwit, Esquire 799 Roosevelt Road General Counsel Glen Ellyn, IL 60137 U.S. Nuclear Regulatory Commission Deborah Faber Webb, Esquire Washington, DC 20555 7967 Alexandria Pike

• Judge John H. Frye, III Alexandria, KY 41001 Chairman, Atomic Safety and Licensing Andrew B. Dennison, Esquire Board Attorney at Law U.S. Nuclear Regulatory Commission 200 Main Street Washington, DC 20555 Batavia, Ohio 45103

• Charles A. Barth, Esquire Troy B. Conner, Esquire Counsel for the NRC Staff Conner and Wetterhahn Office of the Executive Legal Director 1747 Pennsylvania Ave. NW U.S. Nuclear Regulatory Commission Washington, DC Washington, DC 20555 20006

'Ihr . Frank F. Hooper John D. Woliver, Esquire Sierra Nevada Aquatic Research Clermont County Community Council Box 181 Laboratory Batavia, Ohio Rou te 1 45103 Box 198 Mammoth Lakes, CA 93546

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July 15. 1982 Cf Ain.'. TAN The Honorable Morris K. Udall Chairman, Subcomittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives -

Washington, D.C. 20515 -

Dear Mr. Chairman:

As you requested in your June 14 and July 12, 1982 letters, the information relating to the Zimmer Quality Confirmation Program is enclosed. This infor-mation is current as of May 30, 1982.

I hope this inforation is responsive to your request. Additional details of the Quality Confirmation Program results are contained in the licensee's May 30, 1982 status report which we provided to Dr. Henry Myers of your staff on June 16, 1982. If you have further questions on this matter, please do not hesitate to contact me.

Sincerely, Q 00 , s

/ 'WDQ.{G? C >,W Nunzio J. alladino

Enclosure:

As Stated cc: Rep. Manuel Lujan

l .

• ' RESPONSES TO INFORMATION REQUESTED SY REPRESENTATIVE MORRIS K. UDALL

1. The number of structural steel welds' inspected to date, the number of structural steel welds known not to conform to the Commission's requirements, and the current estimate of the quantity and quality of work necessary to bring ,these welds into conformance with '

requirements. -

Response

• Quality Confi[mation Program (QCP) Task I, " Structural Steel," includes "

the inspection of structural steel "weldments" and " connections." The "weldments" and " connections" generally involve more than one weld.

The emphasis of the licensee and the NRC is being placed on the number of weld deficiencies indentified with those "weldments" and " connections" rather than on the number of deficient welds. One weld could have multiple deficiencies (e.g., undercut, lack of fusion, undersize, profile) due to nonconformance with different aspects of the applicable specifications. Although we are concentrating on the number of weld deficiencies rather than the number of deficient welds, we have estimated the number of welds affected to be responsive to your request.

~

The licensee committed in the Preliminary Safety Analysis Report (PSAR) and Final Safety Analysis Report (FSAR) to the American Institute of

. Steel _ Construction Specification (AISCS), " Specification for the Design, Fabrication and Erection of Structural Steels for Buildings" - 1969, and

! Structural Weld Code," AWS D1-1-1972. The Sargent and Lundy specifica-tions, which meet or exceed the PSAR and FSAR commitmants, establish the requirements for "weldments" and " connections" including the structural welds. Failure to meet the PSAR and FSAR commitments is considered to be noncompliance with the Commission's requirements. Failure to meet the Sargent and Lundy specifications without an appropriate evaluation and review is also considered to be noncompliance. ,

The licensee must resolve identified noncompliances by determining if the deficiencies are acceptable as is based on engineering evaluations or by reworking the welds. Where possible, the licensee has decided to resolve deficiencies with the "weldments" and " connections" by rework to bring them into confornance with the specifications rather than attempt to

. disposition the nonconforming conditions through engineering evaluations.

" Rework" as used in this report means physical effort to correct -

deficiencies.

The QCP Task I, " Structural Steel," is approximately 53 percent complete (May 30,1982) with an estimated completion date of December 1,1982.

The task includes the following sub-tasks: -

a. Cable Tray Foot Connections The inspection of the cable tray foot connections is complete with 259 connections inspected. 253 of those connections were noncon-forming in some manner. Each of the connections involves a number -

of welds (2 to 6). Based on an average of 4, we estimate that 1000 welds were involved.

975 deficiencies associated with the 253 nonconforcing connections i were identified. 242 of those deficiencies have been dispositioned. '

103 of the dispositioned def!ciencies are to be reworked as necessary -

to correct the nonconforming conditions and the rework is in progress.

The other 139 dispositioned deficiencies were determined by the licensee to be acceptable as is.

The NRC is reviewing the licenseei s evaluations of the deficiencies.

b. Drywell Steel -

4 The inspection of the drywell steel (excluding the 525' elevation) is 49 percent complete with 161 beams inspected. 93 of those beams were nonconforming in some manner. Each of the beams involves a nunber of welds (8 to 16). Based on the average of 12, we estimate that 1900 welds were inspected.  !

369 deficiencies associated with the 93 nonconforming beams were identified. 181 of those deficiencies are to be reworked as necessary

- to correct the nonconforming conditions and the rework is in progress.

The other 9 dispositioned deficiencies were determined by the licensee to be acceptable as is.

The NRC is reviewing the licensee's evaluations of the deficiencies.

The beam connections in the 525' elevation of the drywell are being cleaned of paint to allow inspection of the welds.

c.' Gallery Steel The inspection of the gallery steel (control rod drive area) is com-plete with 106 beams inspected. 39 of those beams were nonconforming in some manner. Each of the beams involves a numbar of welds (8 to 16). Based on the average of 12, we estimate that 1200 welds were inspected.

t 126 deficiencies associated with the 39 nonconforWng beams were identified. All of those deficiencies have been dispositioned. 108 of the dispositioned deficiencies are to be rework;d as necessary to correct the nonconforming conditions and the rewori is in progress.

The other 18 dispositioned deficiencies were deterained by the licensee to be acceptable as is.

The NRC is reviewing the licensee's evaluations of the deficiencies.

.- -. = . _ - _

d. Centrol Rcon Structural Steel -

The inspection of the control room structural steel is partially complete with 208 beams inspected. Approximately 150 of those beans  ;

were nonconforming in some manner. Each of the beams involves a

~

number of welds (8 to 16). Based on an average of 12, we estimate that 2500 welds were inspected.

i 1835 deficiencies associated with the ' nonconforming beams were identified. All of those deficiencies have been dispositione.d. .,

1818 of the dispositioned deficiencies are to be reworked as "

necessary to correct the nonconforming conditions and the rework is in progress. The other 17 dispositioned deficiencies were determined by the licensee to be acceptable as is. ,

The NRC.is reviewing the licensee's evaluations of the deficiencies.

The inspection of activities regarding the control room structural steel have recently been expanded to include auxiliary steel and hangers.

With respect to the quantity of work necessary to bring deficient welds into conformance with the requirements, the amount of rework which will be performed is considered by the NRC to be significant. An indication

, of the' amount of rework involved is that an average of 32 person-hours has been required to bring a nonconforming beam into conformance.

Based on this average, 9000 person-hours will be necessary to correct

, the beams alone. However, neither the licensee nor NRC knows the total impact the rework will have on the project completion date. This impact will not be known until the full magnitude of the rework is determined by the completion of the QCP.

With respect to the quality of the work necessary to bring deficient l welds into conformance with requirements, the rework activities are being performed under the conditions established b-/ the April 8, 1981 Immediate Action Letter (IAL} including 100 percen. reinspection of all

- contractor inspection activities at this time. Thi NRC's Reofon III Office is monitoring the rework activities. Althoi.3h some problems have been encountered, no significant concerns havt been indentified with the rework activities.

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2. A quantite.tive stctcment concarning finding; regt.rding cac t. scc:M!ity of piping and the implications of such findings.

Response

Quality Confirmation Program (QCP) Task III, " Heat Number Traceability,"

is approximately 55 percent complete and includes review of drawings and field installation of small-bore and large-bore piping, heat number log, and purchase orders. -

A large number of problems have been identified during the reviews of piping documentation, installed conditions, heat number records, and purchase orders. The problems are:

(

a. Review of 2354 small-bore piping drawings and comparison with installed piping revealed heat number discrepancies on approximately 20 percent of the drawings.

b. Review of over 1900 purchase orders and associated certified material test reports for piping revealed heat number discrepancies on approximately 20 percent of the documents.

c. A number of the 3206 purchase orders reviewed have unsigned certified

. material test reports, some vendors were unapproved, and some non-essential material was upgraded to essential.

d. For large-bore piping, drawings have not been kept current and indications suggest field modifications of spool pieces have been made without proper documentation.

A determination as to whether piping of unacceptable or unknown cuality was installed has not yet been made by either the licensee or the NRC. That determination will be made after QCP Task III is completed.

The potential impact of the loss of traceable piping is that a substantial amount of piping may have to be replaced. As noted above, a quantitative determination as to the amount of such piping will be made following completion of QCP Task III.

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_ ______.______ _ ._ a

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3. The NRC staff assessment of the findings of the review of welder quali.'!;:ticr. records and the implications of such findings.

Response

Quality Confirmation Program (QCp) Task II, " Weld Quality," is approximately 58 percent complete and includes the review of welder qualifications for 1800 welder _s (approximately 4600 records).

A large number of problems have been identified during the review of welder -

qualification records. Of the 942 records reviewed to date for 391 welders, -

deficiencies have been identified including the use of correction fluid, '

improper performance of qualification tests, and lack of objective evidence for test specimens. The licensee stated, based on a preliminary' assessment, that these problems do not render the qualifications of the welders indeterminate and that all welders presently working on site are qualified.

As the NRC has questions as to the validity of this licensee determination, this matter will be pursued on a priority basis. ,

The NRC staff has not yet made an assessment of the findings of the review of welder qualifications.

licensee completes a reviewThe staffmatter.

of the will make such an assessment after the The potential impact of the welder qualification records is that a substantial number of welds may have to be replaced. A quantitative determination as to the number of such welds will be made by the staff after completi n of licensee review efforts.

9 l l

4. The NRC staff assessment as to the extent and significance sf problems rer.11tinn from materials having been purchased from unctalified vcrd:rs.

Response

Quality Confirmation Program (QCP') Task I, " Structural Steel," and Test III, "Haat Number Traceability," include the review of material purchases concerning structural steel and ASME piping systems. Thesc ttsks will be expanded to include the' review of purchases from unapproved vendors in other areas.

A problem has been indentified within the above QCP taskt and als'o by a separate H. J. Kaiser Company document review group related to nonessentill material purchased from unapproved vendors being upgraded to essential ma:erial without appropriate documentation. The licensee has determined that all material presently being installed has been purchased from qualified venders. As the NRC has questions as to the validity of this licensee determination, this matter will be pursued on a priority basis.

The NRC staff has not yet made an assessment of the findings of the review of material purchases from unqualified vendors. The staff will make such an assessment after the licensee completes a review of the matter.

The potential impact of the material purchases is that installed msterials -

may have to be replaced. A quantitative determination as to the amount of such material will be made by the NRC staff after ccmpletion of licensee revicy.e f forts .

O 8

7-

5. Tne fiRC staff assessment of the findings that have emerged from the review of fionconformance Reports.

k Response -

Quality Confirmation Program (QCP) Task VII, "Nonconformances," is approximately 60 percent complete.

Voided Nonconformances (flRs) ,,

A large number of problems have been identified with approximately 400 of the 1031 voided firs reviewed to date. These approxinately 400 voided flRs will require additional investigation to resolve questions as to acceptablity of conditions. The investigation

. efforts are in progress. -

Comoleted ?!onconformances The licensee's review of 290 of a random sample of 300 ?!Rs has revealed problems with 10 flRs and may result in the reopening of those 10 previously closed flRs. ,

Punchlist ,

m The licensee maintains a "punchlist" which is a list of unfinished items with systems. The licensee's review of the "punchlist"

. revealed 100 items which may be issued as firs.

The~1icensee activities are being monitored by the flRC. An assessment by the f!RC staff of the findings has not yet been made. The staff will make such an assessment after completion of QCP Task VII.

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dOVERNMENT ACCOUNTABlUTY PROJECT

. Institu:efor Policy Studies 1901 Que Street. N.W.. Washington. D.C. 20009 (202) 2N 9362 July 9, 1982 The Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Chairman Palladino:

At the June 16, 1902 briefing on the William H. Zimmer nuclear power station, you requested additional explanation of "what you 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 falso statements by Cincinnati Gas and Electric ( "CG &E ") officials who responded to questions posed by the Commission at the brief-ing. A search of our files revealed serious inaccuracies in the responses of Messrs. Sylvia and Borgmann. As a result, the Iliami Valley Power Project ( "MVPP ") requests an investigation by thc 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 IIDR's sacrifice numerous basic principles of 10 C.F.R. 50, Appendix B, and the professional codes. The deletions permeate 4

the entire system from identification through disposition:

1) A Nonconformance Report identifies the cause of the 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

• 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 Thomas Devine, at 6) unless otherwise noted, NR's will be references to ZAPO-5's predecessor, Quality Assurance -- Construction Methods Instruction ("GACMI") G-4, R.15.

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The Honorablo Nunzio J. Palladino July 9, 1982 Page Two Procedures Manual, Procedurc 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 de termined. . . . "

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 /contrac tor, 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 per51t the condition. (Exhibit 2, S4.2.3 note.) The IIDR form, on the other hand, permits DDC's to " correct" the probicm.

(Id., 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 otheE 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 prohibit additional identifying infor-mation, that is not a significant reassurance. A blank shoot 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.

The Honorable Nunzio J. Palladino

- July 9, 1982 Page Threc

5) A Nonconformance Report goes to the Material Review Board if the disposition is " repair," " accept-as-is," " rework" or "rcicct." (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 managor. (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 insocctor 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 ZAPO-5, 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 ASME.

Prof essional Engineer if stress analysis is required by (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 Autnorized Nuclear Inspector. ( Ijl . , S 3.8.T.)

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 i strictly monitor ongoing work at Zimmor. Rather, IIDR's institu-tionalize Region III abdication of oversight for repair of noncon-forming conditions at Zir..me r .

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, i size and heat / lot numbers; do not verify inspection for

! defect removal; and do not identify acceptance inspec-l tion procedure and revision used.

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. The Honorablo Nunzio J. Palladino July 9, 1982 Pago 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 wcld 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-S with IIDR's.

In the same memorandum, Mr. Knox reported his response: "I disagrec with this type of organization and so does 10 C.F.R. 50, Appendi:: B."

l (The November 30, 1975 memorandum from E. V. Knox to D. H. Williams is attached as Exhibit 5.) Surely the NRC would not approve a practice flatly rejected by Kaiser construction management during the " pre-reform" period at Zimmer.

Apparently Mr. Schwiers was convinced, because he reversed his opinion. In a March 11, 1981 written exchange with Kaiser QA Manager Phillip Gittings, Schwiers' QA liaison Robert Ehas stated 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 cor-tainly should be on an NR. I have no intention of discontinuing S/R' s . . . . " (The March 11, 1981 cxchangc 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 l

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 practice 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, suora.) Apparently CG&E's " post-reform" position har, discarded this premise.

I 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. CGSE MATERIAL FALSE STATEMENTS AT THE JUNE 16, 1982 BRIEFING f 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.

t Curiously, none of these distinctions are included in ZAPO-5. As ZAPO-5, S 3.4.1 note explains:

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The Honorable Nunzio J. Palladino July '9, 1982 Page Six Deficiencics in construction work identified up to and including final inspection, which are doc-umented on an In-Process Inspection Deficiency Record (IIDR) form according to approved procc-dures, or other deficiencies that are corrected in accordance with other applicabic corrective action procedures, do not require identification on an NR.

Mr. Sylvia's distinctions do not exist in practice, either.

For instance, he stated that IIDR's are only used for new work 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-nesses would like to pinp~oint specific esamples with appropriate representatives of the Commissioners, after obtaining written confidentiality assurances. '

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 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-closed: "No approvals are required to accomplis.h weld repair by IIDR although QAE and Weld Engineer approvals are required 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 practi'ce. 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 GA 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, after ZAPO-5 had already gone through a revision. (QAP 16, Rev. 9 is enclosed as Exhibit 7. )

Fourth, Mr. Sylvia claimed that IIDR's are a hold point type of inspection. As explained earlier, however, QC no longer has the authority to enforce the hold point. (Supra, at 3.)

Fifth, 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 , hcwever, demonstrated that IIDR's only require a shadow of the documentation contained in an NR. (Supra, at 2-3.)

. 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 UR'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 l

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 CGLE is theoretically monitoring.

B. Mr. Borgmann At the June 16 briefing bk. 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 U, 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 offenses. The inaccurate statements 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,

,, ) .  ;

kc w ) >J THOMAS DEVINE Legal Director TD/my

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ATTACllHENT 4 l

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1 THE CINCIHATIENQURER FINAL EDITION / NEWSSTAND PRICE 254 FRIDAY, JUNE 11,1982 A GANNETT NEW$ PAPER

'L T M, RC Plans ToReopen ZimmerHearings 4 4 y f

..l BYRIOlAROVneTMNtE And DAVD 5ilAPIRO Gewutt Nees serwke WASIIINGTON-New doubts about con-identitled to date . . . we thought is, was said. *We don *L teel it is necessary because llenry J. Kaiser Co the countruction firan best to have us be counted in the putatic all of the items brought up (by the request building Elmmer for CULE Charged that arena," Keppler salJ. to reopen) are old items that are covered by he was demoted to a clerical pub for oggres.

"There will not be a recommendation the quality confirmation program."

tant ahuuld be The request to reopen the heartngs plant.

steely pointing out deficiencies at the atruction defects at the Zimmer nuclear bylicensed me or my staff that this until we are conv fnced that this came from the Government Accountablity .N HC officials disagreed w!Lh COLE's wer station trtsgered an announcement Project, a Washington-based organization j . .;y ursday that the staff of the Nuclear plant isKeppler buttt properl said the,* earings said Keppler' would center that triggered the 1981 Investigation *nto suggestions that its structural steel wend-Ing prot,tems involved only mh>ur repairs r'.i

, * ', ]. , i ,. j . ,

, Regulatory Commission supports reopen- on possible flaws in the quality confirma. 7.immer's problems.

At the hadng Keppler agued that it O Lion mam WeM h the NRC las ear eThe National ltoard uf lloller and Pres-1 . I hatmak a a hear ng r opening efter CO&E, the manaatng partner of tree was the Government Accountability Pro- sure vessel Operators called for CG&E to

% *? v* laevitable-a major setback to Cincinnati uLlittles building Elmmer, was fined ct, and not the !!HC, that discovered submit a lan outlining how COLE mtil i l 5 ., O Gas and Electric Co. (CG&E), which is D

1' 4 a s e p er a c o1 e NRC's t us na c r That massive affort to prove Elmmer's day's hearing-I o em dmlopments at Tlaun- [

E

' Ij Region 118 office in Chicago, told the llouse safety La already seen as virtually certain to . Committee Chairman Morris Udall, D* The NRC's Atemtc Safety IJcensing

.'8subcommittee on energy and the enetron- push the plant's opening wen t,eyond the Ariz, sand the NRC shouki have taken the Board concluded its hearin s un Zimmer I- '

b"/* '

,,t} ment Thursday "

that furtherd hearings ,

are""Oiis'*q'ntiy"o"U eudtters.as fo*lfie"ln' was done at the M Ecanyonsaid "e"nt Diablo E'd"d'd>%n" t se ut!!!!y !20.'J'"'

wi1I continue "***' to op-E='EU'EE

" Elmmer- pose new hearings. . plantinCattfornia. (see 211818l'R.

EARL BORGM Af4f4 **l'ti VERY disappolated." Borgmann .A former quality assurance analyst for boet of this serties)

.CG&E vice president "WITil Tile protalems that have been a4.=.- - sm _

k 4

A-18 THE ONONNAT1 ENCulRER/ Friday, June IL 1982 1

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CONTINUED FROM PAGE A-1 i

But the NRC's Keppler dis-puted Borgmann's assertion, tell- Later that spring Jones said he and others completed an audit of l TOM DEVINE, an attorney for ing the committee, "The NRC views findings on structural steel' a supplier they said was not fol-the Government Accountability lowing the Kaiser quality assur-Project, told the Udall committee as more significant than the utill-ance memo.

that the quality confirmation pro- ty has up gram at Zimmer does not cover all commh,[esented before this Jones said the Kaiser quality l assurance manager responded:"I problems at the plant-only those The surprise witness at the don't want to see any more of identified by the NRC in last hearing was Dave Jones, a former ) these types of memos. They tend year's report. senior quality assurance analyst to embarrass us and cause more j Udall .tiso questioned the wis- for Kaiser who was recently de- accusations and allegations."

moted, but still works at Zimmer. Last May, Jones said he was dom of putting CG&E in charge of its own quality confirmation pro- demoted to documents reviewer, gram. JONES HAS filed a complaint and later found the demotion was with the U.S. Department of Labor triggered by suspicions he was an "Since quality assurance was asking for reinstatement to his NRC informant. Jones said his neglected for many years by the former job. In the complaint, he first contact with the NRC came-l same company that is now charg- charges that he was demoted for later that month.

j ed with untangling the results of- insisting on proper inspections at Borgmann said he hasn't had a .

Its neglect, I would have hoped Zimmer. chance to research Jones' charges.

that the NRC would have insisted Bu t Borgmann did say, "He on an audit by an independent The incidents Jones cited in- (Jones) was always a documents concern," he said. clude: reviewer . . . He is making state-

• "I would like to know what the In February,1981, Jones said he NRC and CG&E are doing to as- wrote a memo suggesting that the sure that the Zimmer quality con- l qualifications of some inspectors broader than his area of experid firmation program is structured were suspect-and their work eue and expertist so that significant problems can* ' might need review-not be swept under the rug." JONES, HOWEVER, says he i

. CG&E's Borgmann insisted Jones said his boss replied'he was working as a senior quality l

that his company's quality confir- wasn't hired to write memos. "He assurance analyst before he was warned me !!I wrote another one demoted to a documents clerk mation program will identify and I would find myself on Route 52 position iast May, correct any safety-related prob- (the road outside Zimmer)." - "I've been an assistant quality In April

• 1981, Jones says he assurance manager; I've been a He said the program 13 66% began a p oject to analyze how qua y contml manager. I was a complete, and that while some modifications are made to the quall y assurance engineer on ,

minor deficiencies have been reactor steam system. Af ter dis- "8 U" found,"none of . . these def t- y u want to get?,m, uch bmader do ciencies has proven significant, covering problems with the pro-gram Kaiser was using, Jones said J nes attacks the heart of ~

relative to impacting the safe he was pulled off the project. CG&E s defense-the quality con- !

operation of the Zimmer station. firmation program the utillt' /says <

Around June of 1981, Jones de- can catch all of Zimmer's prob.

"WE ARE very confident that cided that since COLE ltself was lems.

( our actions to upgrade our quality providing materials to Kaiser, the "The quality confirmation pro-

procedures at Zimmer will provide utility needed to qualify as an ap- gram," he said,"w111 not work be-complete assurance cs to the safe- proved vendor-those suppliers of cause there is not the freedom at ty and integrity of the Zimmer safety-related materials with ap- Zimmer to make independent station. proved quality control programs. Judgments. It takes an act of cour-After reporting that COLE was age to do your job right there." -

"The company has directed unable to provide the necessary I 1 (Kaiser) to take necessary steps to documents ior the audit, Jones

! assure the independence of the said he was pulled off the project.

quality assurance-quallty control Later, Jones said another auditor organization from construction was called in for the job. "The personnel, particularly to elimi- standards were relaxed and CG&E nate complaints that quality in- passed," he said.

spectors had been intimidated or

! harassed in performance of their THAT JULY, Jones said he and l Inspections." two others completed an audit I

Borgmann took issue with a re- that criticized Kaiser's program to l cent Gannett News Service story identify and trace materials used l reporting that CGLE has been on the job. Jones said no action l forced to repair 5% to 10% of its was taken on the audit, ar.d the structural welds at Zimmer be- audit was called " invalid."

cause the original work was faulty. In April,1982, Jones said he was told that auditors should not write "This was somewhat a memos, make recommendations, mischaracterization and an exag - or record observations. "I explain-geration of the hardware prob- ed to him that I had no intention lems that are being encountered of respecting any gag order,"

at Zimmer," he said. Jones said.

o, UNITE D S T A T CS w L.,,...,,e . .

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, <8 'hI' D f .c ' oi NUCLE AR REGULATORY CL.

ATTACHMENP 5 g g %f,,4 WASHINGTON, D. C. 205 h.lf._$~ ..

CHAIRMAN

• The Honorable' Morris X. Udall Chainnan Subcomittee on Energy and the Environment .

Committee on Interior and. Insular Affairs United States House of Representatives-.

Washington, D. C. 20515

Dear Mr. Chairman:

You recently inquired about the adequacy of the investication by our Office of Inspection ano Enforcement (0IE) into quality assurance / quality control problems at the William H. Zimer tiuclear Power Station. The OIE investigative effort at Zimmer is not yet comolete. However, a recent re:: ort of our Office of Inspector and Auditor (OIA) was critical of an earlier OIE investigation. My own inquiry into this matter convinces me 'that, while there are inadequacies in the initial OIE investigation of Zimmer and in its investigatory program generally, the findings presented to the Commission to date do not incicate that these probl ation,e'ms at the na.ve plan:.con:ri::uced The pertinent to an documents adverse oublic health and safety situ-are enclosed.

Early last year, OIE investigated and reported on allegations of impro-prieties in quality assurance / quality control activities at the Zirr.:er plant. CIA was askee :o evaluate the adecuacy of that OIE investiga:ior..

In its report of August 7,1981, DIA concluded that the OIE investigaticn was unsatisfactcry. OIA's fundamental criticis: s were that O!E failec to adequately cocument its investigation and failec to follow through cr.

significan: isads. I requested interactive co ren:s from CIA and GIE and, thereafter, met with the main participants on October 9, 1981. My conclusions are as follows:

l. I agree with 0IA's finding that OIE's original investigation should have been more comorenensive. The Commission is c sidering the necessary internal reforms.

I believe we need criteria to detennine the instances which recuire such full-scale ir.vestigations. ~.ne fiRC does not have the resources to conduct ir.-c e r :r inves:i;nions in all instances, and such in-depth investig ni:ns are no: called for by the circumstances of every case. However, wnen a full investigation is called for, as for example in the case of possible criminal conduct, NRC needs to conduct that i nves:ignion consistent with funcamental standards

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ti:a t go .ti .. -

w.cs tiga tions by any agency. I have requested the r"+

Executive Director for Operations to develop guidelines for deter- cS gg mining when to conduct investigations, and to establish more formal investigative standards and procedures for such investigations .

2.

I am satisfied with the steps we are taking at the Zimr.er Nuclear Power Plant to protect public health and safety. A follow-up OIE -

investigation is ricarly ccmplete.

available shortly. OIE's final report should be In addition, I note that the licensee has problems that have been found at the 'Zimmer plant.recen In sunnary, reveal a generic shortcomings probler.. in the earlier 0IE investigation of Zimmer In addition, CIE will snortly release its final report on the ZimmerStep plant.

The Co,cmission will look closely at that, report. Finally, the licensee is cc=mitted to a verification program to provice further assurances to puolic health and safety.

sions set fcrth in :his letter.The Commissioners have been informed and i

If you have contact me. further questions on this matter, please do not hesitate to

. Sincerely, gey ' 42.d gC- t- t,+wc' i

• l .

Nunzio d. Palladino-

Enclosures:

i 1. Memo fm Jares J. Cummings, IA, to l Commission ctd August 7,1981 trans-l mittinc CIA recort: "Adecua:y of IE l Investigation 50-255/80-9 at tne William H. Zimmer Nuclear Power Station"

2. Memo fa William J. Circks, EDO, to the Commission dtd September 17. 1981 3.

Memo fm William J. Dircks, EDO, to the Commission atd Seotem.ber 17,19Si 4

Mem: fn James J. Cummings , IA, to the Commissicn dtd Cctober 3,1981 cc: Representative Manuel Lujan 1

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ATTACHMENT 6

- Interview of Terrv- Harnster-IE, on detail as a Terry Harpster, Reactor Preoperations Specialist.

Natural Resources, Gove.. ent Operations Co-4 tree, Representatives, was interviewed on March 6,1981, by Investigators David Camble and John Sinclair, DIA.

He.

Harpster said he worked ir Region III of NEC fro = 19 Region III. He later became a project c:anager for particular plants:  !

first for DC Cook Unit 2, then Monticello, then both Ziz=ner and Monticel Harpster said he began his inspection activities He saidat at the same. time.

Zimmer in October 1977 as a preoperations start-up inspector.

he was assigned to this position until he left Region III in September 1979; however, he had no real involvement with Zi=mer Harpster aftera the said that pre-Three Mile Island (TMI) accident in March 1979. h operations inspector picks up a plant shen construction is far enoug c

along, i.e., about 60 percent completed, to review certain programs, Harpster inspector.

the quality control progra:r. for preoperational work.'said e.g.,

Vandel had. inspected Zimmer prior to Harpster's arrival but there was aHar period of overlap when they both worked there. i worked with him as a preoperations inspector who he was train ng.

Harpster program said that Menning "took one look" job.

and i

left th was that he saw how little support the inspectors got on the Harpster understood that. Menning left to attend. the University of Arizo vhere he is, working on.his. Ph.D in. metallurgy.

l Harpster said that when he picked up Zimmer the He said. they barely met ANSI Standard 18.1 which needed for the plant Harpster explained that even this standard is the criteria for staffing. Harpster said that one of is a . loose one which has since been upgraded.

- his jobs was to show the plant management what was require plant off the ground. Harpster said that, for example, the employee of proble=s at Zi=cer. l had about who was being placed in charge of the start up operation on yHe explained that the three conths of actual experience in the plant.

licensee counted as nuclear experience the amount ofAnother time operations exs=ple employees were onsite during the construction of Zin=er.once the parts was his impression that the plant personnel felt that, from their were bought for the plant, they did not need any supportpersonnel felt a He also believed that many plant corporate offices.

nuclear plant s.-as similar to thechain operation to Vice President of a fos including going up through the licensee managenent Earl Hors = ann, but with no luck.

l . -

Harpster said he was successful in getting a meeting set up in Bethesda to discuss apparent ueaknesses vf_th. Licensee.'s organization and staffing.

He said this meeting was held. en July 13, 1978, only after he " screamed" .

at licensing officials in Bethesda, particularly Irv Peltier who was then project manager in NRR. respossible for issuing the safety evaluation report (SER). Harpster said that. he presented his ccacerns at that meeting and the utility agreed to upgrade their program. He recalled that the. specific response was to "buT" an engineer from General Electric to assist them. .

Harpster said that the ra' J. problen was that NRC.'s licensing process-was rolling c:uch faster than he could " ratchet" improvements at the He plant end. Harpster said that NRC's requirements were a " joke."

- said that .NRR was about to issue the SER and they set up a meeting of the Advisory Co=mittee on Reactor Safeguards (ACRS) to utich, he. was, not, invited.

Harpster said. he ven up the Region IIT. manage =ent chai:t and presented ~

his. concerns. He said he attended the ACKS meeting anyway. He recalled that when licensee. officials. vere questioned by ACES Chair =an Bender, they said several things that were not- true. Harpster noted that not only did h feel they were not true, but Menning also believed they ver+

not true. Harpster said he presented this conflict to his boss, Robert Warnick, when he returned to the regional office. He said that he and Manning .

later talked with one of the licensee officials she hadDuring testified to the their ACES (Ji= Schott sho was the plant manager of Zit:mer).

conversation, Harpster had Warnick read. Schott's .testi=ony to Schott over the phone. He said that Schott then agreed that the testimony did not convey the correct impression. Although Schott assured Harpster and Menning that ,he vould clarify this at. the next. ACRS meeting, he did not.

Harpster believed that Schott.'s subsequent. testimony evencaggravated. his.

earlier statements.

Harpster said he briefed his management on this natter. 'He recalled that his Regional Director, James Keppler, sent a letter to the ACRS informing then of the situation. Harpster understood that this letter was later fava'rded to the Atomic Safety and Licensing Board (ASLB) .

Harpster explained that, after the ACRS meeting, he also informed Peltier (in Menning's presence) of his concerns. He said that Peltier later claimed that he did not recall Harpster's expressing his concerns to him. Harpster explained that Peltier is a " pro-nuclear" " pro-licensing" e=ployee. He also explained that during a start-up of a nuclear plant, NRR is on a very tight schedule; the IE inspector is often viewed by rnK as an adversary when he uncovers deficie:cies stich NRR has already

" blessed." .

Peltier told Harpster that he hadinfor=ed the licensee about an IE investigation undervsy on the subject. of the licensee's testimony before the ACKS. Peltier also inf ormed Harpster that Charles Earth (attorney with the Office of the Executive Legal Director) had called James Yore (Chairman of the ASLB Panel) and told Yore to throw away Keppler's letter describing ~

the discrepancies. Harpster pointed out tha t these latter two matters were the subject of a.recent investigation by CIA. Rarpster said rnR in su mary that this was a situation uhere the system broke down:

viewed IE as the " bad guys" trying to hold up plant licensing.

• Harpster said that Borg= ann was also putting the heat on him by, exa=ple, sending a letter to Keppler.

Chairman of the licensee sent a letter ta President Carter and ot Hatyster said that it was about this ti=e that the 'DiI accident occurred.

He said he was assigned to 1HI and he has not'been back to Zi==er since.A princ Harpster one was that, said that, when he. left, Zi=mer still had proble=s.as a He said that all Zimmer had was one person the jobassigned required. to this function and that person could not possibly do all that Harpster said that realistically the IE codular inspection program does not deal sith the things you have to focus on early in a plant's life.

He said that an inspector must deal with the proble=s he icious areHarpster said, i=portant and then deal. vith other problems in addition. i He that he had to deal sith the construction people. so=ewhat at Z mmer.

said that the licensee everything had minical was controlled involvement by its contractor. He saidwiththat tthe construc his Zi=mer:

is a probles because, after the plant is built and the contractor He saidleaves, the' licensee would not have any expertise to handle the plant. taff for that for exa=ple there was no one on the licensee's corporate sHarpster felt that th reactor instrumentation and control syste=s. -

licensee was "in over its head." ,

i He said that an inspector can deal with some of the Harpster said that someti=es so many things are so=e which he cannot. "Zimmer are wrong that a planti is out of control. Harpster concluded th (by, e.g. , the was out of control."

l get money for the construction of a nuclear powerl plantsa He said that this results in a situation there the. construction personne Harpster l

attempt to turn things over as completed before they a He said shen the licensee finds prepared or trained, to handle them. What they

' things that are wrong, they cannot fix or test them properly. d must..de is give the proble=s back to censtruction to be remedie .

l Harpster not work.

said this is indicative of a construction QC prog He said that one exa=ple of this was that the licensee tries to head off. According to Harpster the time required had not ordered any spare parts. equipment is so long it causes a to obtain additional or replace =ent back-up equipment.

major problem to licensees trying to resupply or obtain sometimes plant management puts so much pressure on Harpster said that get things done. He said that their personnel that the personnel cannot lish the same inspector these things:

personnel then sometimes use NRC inspectors to ac -

found the deficiency rather than the plant personnel. Harpster said that, frca what he could see, it appeared that the construction program l

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had def ects and he was about to inherit thc=. Harpster explained that he was not directly f a=iliar with the . construction activities but he sau

- the results - including the QA proble=s. Harpster said that inspector Fred Maura has docu=ented cuch of these proble=s frc= the operations side.

Harpster said that both the site construction canager, Mr. Cear (phonetic)

E and the site QA =anager Mr. Schweirs were friends of Vice President E=rg=an=.,

Harpster bel:.eved that Schweirs uss assigned by the licensee to keep the plant canager (Schott) undei control. Harpster said Schweirs even called the regional office to try to get some of the IE inspection reports changed. Harpster said Schweirs also asked hi= to send IE inspection- reports to hi= (Schweirs) so he could. decide. which catters would be sent on to Schott.

Harpster said part of the problem was thak; NRC. does. not have explicit regulations to inspect against. He said; that the preoperations inspector is faced with the task of trying to get control of the site and helping the lice =see to solve its problems. He said that the inspector only docu-ments a s=all percentage of this " helping work." Harpster said the licensee. had. no people involved vi.th preoperations and test acceptance.

He said that everything was bought under contract so the contractor was able to do whatever it wanted. Harpster said the licensee then. had. no one who knew how to handle the proble=s that were " built-in."

Harpster said he tried to get the plant managers out to take tours of the plant. He said that one assistant plant manager said he was scared to tour the plant because of the convicted felons working out there.

Harpster said that sometimes the licensee's own security force could not handle disturbances and they had to call the local sheriff's office.

Harpster explained that there is some drinking of alcohol en all nuclear construction sites. However, the licensee at Zic=er did not have much control of tifings. Harpster said there were a lot of " tough guys" votking at the plant and the situation got verse when they were drinking Harpster said that there are many allegations at any nuclear power plant; however, usually only a certain nu=ber are true. Harpster said that one could tell that there were a large number of problems at Zimmer because so many allegations were coming up.

Harpster said there was a lot of pressure on individual IE inspectors Harpster because of the nementum generated by the NRC licensing process.

said that pressure is also created on construction personnel by the contractor's veld production schedules. He explained that the construction

=anager has to have a certain number of velds ce=pleted to keep the piping installation on schedule. He said that proble=s arise when the construction personnel are pushed. Harpster said that for a QC inspector to stop construction for any deficiencies, he wuld have to hold up many phases of the construction of a $1 billion plant; so the QC inspectors nomally do what they are told.

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Harpster said that nuclear pruar plants e= ploy pt sonnal specifically

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designated to serve as their liaison with NRC. He said that this is helpful because it overco=es the problen II inspectors face in trying to find their way through the great amouse of paperwork at the plant,

• Harpster said, however, this liaison person also " steers" the inspectors' activities. Harpster said that dealing with this liaison person does allow the inspector to get through Npf's modular inspectio:t progran very well. Harpster noted that there is no real internal audi.: of the NRC's inspection progrs=. .

Harpster described the " helping activities" that an IE preoperations inspector engages in as a process of getting all the procedures and two controls in place. He -caid that this activity constitutes only about lines in the IE procedures, but it is the largest part of a preoperations inspector's tiz:e.

Harpster estimated that the interest cost alone in holding up construction of,a nuclear power plant for one day vould be several hundred thousand dollars. He observed that, with the increased pressure on NRC to license power plants, he vould expect even more pressure to be placed on IE inspectors. He said that pressures on the licensee personnel to make exceptions to the acceptance criteria in the preoperations tests are very real . He said it is difficult for an IE inspector to tell whether He the licensee's exceptions are based on valid engineering analyses.

said that all inspectors cannot possibly be experts in all areas.

Harpster said the inspectors must rely en the licensee's people to review the exceptione Harpster said 'that this represents a flaw in the NRC's system becaus a .he licensee's reviewers are under the sa=e pressure to approve exceptio s. Harpster pointed out that the licensee, because it is a utility company, cannot pass on the amorti=ation costs to the the.

ratepayers until the plant reaches the point of completion, i.e.

stage of ccamercial. operations G

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ATTACHMENT 7 UNITEo STATES

. ' /gusCg'o, NUCLEAR REGULATORY COMMISSION jg *

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• • • • • April 22, 1981 MEMORANDUM FOR: R. F. Warnick, Chief, Reactor Projects Section 2B THRU: '

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• I'. N. Jackiv, Acting Chief, Test Program Section F. Maura, Reactor Inspector

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FROM:

SUBJECT:

RESULTS OF ZIMMER INVESTIGATION On April 17, 1981 I completed my write-up of the investigation of the Zi=mer diesel generator subsystems and gave a copy to Paul Barrett. The purpose of this memo is to give you my recommendations on what actions are required to correct the problems noted.

Small Bore Pioint Veld Fit-up Verification The licensee shall be required to tabulate all small bore piping in syste=s important to safety where the QA inspector failed to verify proper fit-up prior to welding. The tabulation should be by system, drawing number and line number. Initially our position should be that all those welds be radiographed to verify that approximately a 1/16" gap was maintained prior to velding. Our fall-back position should be that IE:RIII will determine which welds the licensee shall radiograph. Our selection shall be based on system function, type of service the system is subjected to (design pressure, te=perature, etc.) caterials used, etc. For example, all safety related syste=s shall require 100% verification by radiography.

Lack of Adequate Material Heat Number Traceability The licensee shall be required to walk down all systems important to safety, using the latest as-built drawings, and record the heat number of all pipes, fittings, etc. If the heat number can not be found on the component, it shall be marked on the drawing as " unknown". Next, the licensee shall verify that the installed heat numbers are acceptable (=aterial certifications are available at the site and meet the ASTM Specifications).

All material with unacceptable heat numbers shall be replaced. With recards to material of unknown heat number (not stamped on pipe) our initial po,sition should be that it be replaced. Our fall-back position should be for IE:RIII to review each item and based on system function, type of service, environment, etc. make a determination of which components shall be replaced and which to accept.

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.. Y.*Wnrnick Weld Rod Issue Records (KE-2)

Alterations of Weld Records (KE-1) Based on forms to correct ,g Thz licensee shall discontinue using the material issuefurther d the deterioration of the QA records. To prevent to remove the " corrections" already made, insteafied using Construction chmil not attempt licensee shall tabulate all QA records which were modiFor turnover pu Dapertment acespt records.from Kaiser the records as they now exist. ll be to perform the work a now cxist are unacceptable, the only solution sha ovsr again,

! NRC's Performance its routine The NRC shall determine why it failed so miserably, duringble=s now surf acing inspection program in identifying and correcting the proThese are problems at the Zimmer site. Either our inspection program, end corrected two or three years ago. bination of all three allowed the'se the inspectors, our management, or a comCorrective action must be taken to prevent problems to exist for so long.Our findings raise the question d similar problems to whether Zim=er's probl recurrence. To answer en isolated case or whether our program has allowethat question RIII ction develop in other plants within our region.similar team inspections at other RIII must conduct ns.soon as possible.

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F. Maura, Reactor Inspector l

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ATTACHMENT 8 s .

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PHILLIP GITTINGS g

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. Kaiser EngineeringDeputy Quality Assuran t-d' William H. Zimmer Nuclear,ConstructioIncorpora n Project ted h- - -

Mr. Phillip Gittings, former Quality A e Incorporated (KEI), assignedssurance to the Willi Manager, Kaiser Engineering Project was interviewed on July 8 Site.

am H. Zimmer Construction k je g,, John Sinclair identified ,1981, themselves at the ZimmeraPrior

, Messrs. Albert Puglia and Construction to any ques g present during the interview s Investigators, was OfficeJamesof Inspector M Can wgf.:

Inspection and Enforcement (IE) ommission (NRC). Also

.'14 ib provided the opportunity ,toRevicn review III.c arten, Investigator, Office of app Mr. Gittings was also

& that the purpose of the OIA investi ropriate credentials and advised

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(NonConformance Reports, gation was toKaiser determineEngineof his knowledgealte T.:

f.:.

ontrol (QC) documentation

? Mr.

KaiserGittings Corporation. began the interview by d ering Inspection forms-KE1 for approx Gittings explained that he had worked fescribing h Assurance QA) (imately Manager 41/2 at the years-and Zin.r.tr Site had for or held Kaiser the position about a

(i . stated th't he assumed the position in July year.1980ser Quaone li ty M reassigned as the Deputy QA Managerand and wrecently Gittings to another Kaiser project in the nea had been M

r future.as scheduled to be transferred

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Nonconformance Reports (NR's) Investigator McCarte

-2.; Floyd Oltz.most " voiding" of Gittings HR's was stated done that by prior the Stongs as to his know ig%,j of the Supervisor,. Document ControlGittings responded to ques

( the validity of NR's or, the anda authoritstating his authority to " void" qualifications to as that NR's Oltz byern did lg y to disposition the NR's as "sess void."

s.;,

,Gittings for a technical statedevaluation that the proper of the info procedures for processi ng an NR called

. determine the the that NR couldwhether or notrmation be dispositioned the as " void deficie contained

" on the NR to ncy described was valid, and if not Manager. only person who had the authority to void an NR wGitt

" voiding" was the topic of discussiGittings ouldalso be theadvised QA that the 111,'(1. Yin) in the fall of 198 with NR's and their concerning NR's written by a , 0. on with an NRC inspector from Region gt were " voided" by Gittings, inspector he (Gittings) by the name of Ruiz, whichI i the NR's but could not recall wh y he had voided them, acknowledged tha t he had " v

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, " {' ., Phillip Gittings 2 Gittings stated thet during an inspection of the site, Yin discovered the problems of " voiding" NR's in the Document Control section. Gittings stated that the discovery of the problem had been discussed during an exit meeting between the NRC inspector, representatives of Cincinnati Gas and Electric (CG&E) and Kaiser. Gittings further stated that he attended the meeting and recalled that Yin questioned the voiding procedurese and the process whereby the Document Control Supervisor was exercising the authority to void NR's. According to Gittings, Kaiser advised the NRC that there would be no more voiding of NR's by the Document Control Supervisor.

When questioned about QA heing intimidated by the Construction Manager (Robert Marshall), Gittings replied that he was not intimidated by Marshall or construction's challenges to the findings of QC inspectors.

Gittings stated that Marshall has a strong personality, but he, Gittings, would not change QC findings based solely on Marshall's objections. ,

Gittings added, however, that there were some instances where he, Gittings, agreed with Marshall's position and subsequently overrode the findings of the QC inspector. . .

Gittings continued by stating that when he arrived at the Zimmer site he found what he believed to be inadequate QA Management. At that point he began to hire additional QC inspectors from other construction sites.

This, Gittings stated, also caused some difficulty because some of the

( inspectors came from projects which were inspecting to other code requirements than the AWS (American Welding Society) that was in effect at Zimmer.

Gittings explained that the differences resulted in Kaiser instructing the QC inspectors that the standards and requirements at Zimmer were those incorporated in the AWS code.

Gittings responded to questions regarding the placing of HR's in a separate file titled the Inspection Report File by stating that he was

[

not involved in directing or placing NR's in places other than where -

they were supposed to be. Gittings stated that he had never instructed anyone to place documents (NR's) in files other than the NR system.

Gittings was then advised that between January and February 1980 " Inspection

, Report" stamps began to be placed in NR log books in order to remove or l recategorize the original NR as an inspection repor t and remove it from l the NR system. Gittings explained that the practice at the site was for the QC inspector to call in from the field to get a control number and af ter the number was issued write up and submit the NR. This, according to Gittings, is compatible with the Quality Arsurance Control Manual Instructions (OACMI) procedure which states that QC inspectors can initiate an NR "that is correct." Gittings added that once the NR has beep reviewed by a QC supervisor or himself and determined to be valid, then it was entered into the NR file.

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C C I d. ..Phillip Gittings 3

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Gittings continued by stating that after a second visit by NRC, Kaiser began an audit of NR's to completely review and make determinations concerning " problems" with individual NR's. Gittings repeated that he did not system.

Report" order or direct anyone to place existing NR's in the "Inspecticr.

Gittings also stated that he did not order or direct that any changes be made to recording NR's in the NR log. '

Gittings responded to questioning pertaining to a Kaiser management meeting conducted in early 1980 by stating the folicwing. Gittings explained that he believed that the subject of the meeting had to do with the inspection of pipe support hangers. Gittings added that there c4 were people from Kaiser QA construction and licensee personnel in attenc According to Gittings, Gene Knox (QA Kaiser Corporate), Rex Baker (Kaist QC Supervisor), Bob Marshall (Kaiser Construction Supervisor) and Scott 4' - Swain (CGLE),Ralong with some others were present in the meeting.

" Gittings stated that there was an ong,oing problem of writing up and accumulating NR's on pipe hanger deficiencies. Gittings stated there had been a problem with NR's on the hanger area. Gittings stated that c decision was reached as a result of the meeting to stop writing NR's and to " void" existing NR's. This decision was based upon the fact that Sargent and Lundy (S&L), architect engineer for the project, was to do a reevaluation of the design of the hangers and inspections would be conducted according to design modifications. A second consideration was that QC inspections of vendor hangers (Patterson) were not to be conduc.e:.

( The instructions purchased were that QC inspectors were "not to inspect hangers outside."

Gittings continued by explaining that the previous fall (1979), there

- was continued " turmoil" concerning hanger inspections. Gittings explaina there was pressure to get hangers installed and QA was "getting beat up" concerning inspections. Gittings stated that in one instance where 60 hangers were identified as having deficiencies and were written up on g' one NR, he had made'the decision to separate the deficiencies and place one hanger on one NR. This, according to Gittings, was not intended to overrule the QC inspectors. Gittings also stated that he was not involu s and had not instructed anyone to set up any " secret files" regarding QA

• documentation.

Gittings responded that construction has not ordered him to move QC staff around in order to stop critical inspections. Gittings did state, however, " people have been reassigned to other systems."

At this juncture, Investigator McCarten lef t the interview and it conti:

in the presence of Investigators Puglia and Sinclair.

t ' Gittings began a discussion pertaining to the Kaiser QA organization and who has responsibility for the QA program at the site by stating it is Kaiser's responsibility. Gittings continued, however, and explained that Kaiser was "doing *M , d fcr t. very t%h t i i c n ; ( (.02. _ ; fod Ludi

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Phillip Gittings 4 any requisition for addi+ional manpower or staffing for QA/QC had to go through the client." Gittings added that he had to report everything through Bill Schwiers, QA Manag'er for CG&E.

Gittings stated in response to questioning that the QA organization for e

, Kaiser is currently staffed at a "substantially higher level" than at his time of arrival or initial assignment at the site. Gittings added that he was centinuing to recruit QC personnel for Kaiser employment.

Gittings admitted, however, that the staffing of the QA/QC organization in the past has not been '! adequate to meet the requiements of 10 CFR (Part 50, Appendix B). Gittings added that the client (CG&E) "did not have an adequate QA/QC staff" and "some (personnel) individuals should not have been,in the system."

Gittings continued by denying that he h'ad instructed anyone to " white out" NR entries in the NR log. He (Gittings) stated that, in fact, his instructions were to make no changes in the recordings in the NR log b,oo k. .

Gittings responded to questions concerning the utilization of " punch lists" to record deficiencies rather than NR's by stating that punch lists were used to rectify problems instead of NR's.

Gittings was questioned as to the circumstances which led to the tennination

(~ of the contract with the Butler quality control inspectors. Gi.ttings stated that the contract was terminated after discussions with Kaiser corporate management and a meeting which took place in which the decision was made to " eliminate the shoppers" (stop the contract with Butler).

Gittings admitted-that although Kaiser had been having difficulty in staffing QA/QC, the decision was made that Kaiser would have its cwn QC _

inspectors. As Gittings recalls, offers were made to approximately 21 of Butler inspectors of which 17 accepted. Gittings added that 34 QC inspectors left for other employment. Gittings also stated that the piping area was reduced from 10 QC inspectors to three inspectors partially because the work slowed down. Gittings stated, however, that the corporate decision to drop the " job shoppers" also played a part. Gittings concluded his comments on the contract issue by stating that he believes some of the reasons for eliminating the Butler people were that Kaiser could cut down on paperwork and establish a cadre for Kaiser's own QA organization.

Other factors, according to Gittings related to cutting costs, eliminating "over inspecting" and the Butler inspectors had "no loyal ty" to Kaiser.

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. .[Phillip Gittings 5

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Gittings further stated there were some difficulties or problems in working with Bob Marshall because he was loud and aggressive, but it did not effect his (Gittings) position or his independence as Kaiser QA Manager. Gittings did stated that one problem that did effect his ability to carry out his job was his relationship with the CG&E QA '

. Manager, Bill Schwiers. In fact, Gittings stated "my primary goal was to get along with him" (Schwiers). Gittings added that Kaiser lost the previous QA Manager (Turner) because he was unable to get along with Schwiers. Gittings explained that there were numerous requests in the form of memoranda which were sent by Turner to CG&E asking for additional QC staffing which were turned down or denied by Schwiers. Gittings was requested by OIA to contact Kaiser corporate and advise them that NRC requests copies of the memoranda which indicate that additional QC

' staffing was necessary to meet the requirements of 10 GFR. Gittings stated he would contact corporate and advise them of the request. Gittings .

could not furnish any additional information regarding problems with the QA program.

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ATTACHMENT 9

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UtJITED STATES NUCLEAR REGULATORY COMMISSION g,y g

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iNOV 1 8 1981 g

MEMORANDUM FOR: Bert Davis, Deputy Director, Region III Office of Inspection and Enforcement 4 .*

FROM: James J. Cummings, Director -

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Office of I,nspector and Auditol DMd ( M"#"% -

SUBJECT:

~

ZI!EER ItiTERVIEWS AND CORPORATE' CORRESPONDENCE .

' Attached for your review and any action deemed appropriate are the in.terviews conducted by Office of Inspector and Auditor (OIA) investigators, regarding potential falsification of records at the William H. Zimmer Nuclear Power Station. Also included is correspondence transmitted between the Henry J. Kaiser (HJK) company and Cincinnati Gar and Electric (CG&E) describing attempts.by Kaiser to staff the Quality Control (QC)

Appendix 8. in order to meet the requirements set forth in 10 CFR 50, organization The requests which were sent to CG&E for authorization were officially disapproved by CG&E. Copies of the stipulated correspondence is furnished as an attachment. OIA has also provided a copy of a CG&E

{ internal memorandum dated Hovember 7, 1980, instructing Kaiser to " eliminate" the HJK requirement for system certification (revicu of Quality Assurance (QA) documentation) prior to the release of systems frcm constrUcticn to the Electric Production Department for preoperational testing. GIA had briefed personnel at IE-Headquarters regarding the described documentation I and attached interviews on September 16, 1981, in order to assist in the identification of any unresolved health and safety issues. As a result of the meeting it was concluded that none of the information presented -

any question concernings health and safety. IIe are, however, providing this documentation at this time to assure that no issues remain unresolved and that IE is aware of the information obtained by OIA.

If there are any questions pertaining to the material please feel free to contact me or Arthur Schnebelen, Acting Assistant Director for Investigations.

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i Attachments:

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( UU\]L,dauu Lu e u u u u u uu ut__.u u u CORRESP tu(DENCE

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DATE: il0

. To: SIGl1ATORIES FROM: W. W. SCHWIERS S'UBJECT: WM. H. ZIMMER ftUCLEAR POWER STATIO:t U!!IT I - TURiiOVER OF SYSTEMS FOR PREOPERATIOtAL TESTI!1G - W.O. #57300-957, JOB E-5590 1

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Attached, for your information, is a copy of sheet t;

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" Turnover of Systems for Preoperational Testing". This sht shall serve as interim approval for elimination of Henry J.

certification prior to system release f,or preoperational tt If you have any questions, please call.

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wwh2A W. W. SCHWIERS WWS:pa

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Enclosure "

cc: E. A. Borgmann

' Signatories: S. C. Swain J. R. Schott L  ; W. W. Schwiers Henry J. Kaiser Co.

Attn: P. S. Gittings l

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Tlir. c t::c t:m ATI G..'.S !. El E CT *'!C C C M r ',H'i The Union Ur;ht, tient and ro-cr Co:.i; eny

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llovember 7, 190 TURF;0VER OF SYSTEPS FOR PREOPERAT10:lA Effective riovember 7,1980, release of systems from ll Con. :ctic te Electric Production Departcent for preoperational require certification by Henry J. Kaiser Company that aAlllatpro l

< QA documentation requirement shallhas bebeen revised reviewed.

as expeditiously as po I 14, 1980.

than f(ovembershall continue on a scheduled basis for each system.

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I, do hereby =ake the following voluntary state ent to Mr. J. 3. McCarten, who had identified hic self to me as an nvestigator with a

the U.S. Nuclear Regulator / Commission. I oake this statement freely with no threats or premises of reward having been made to me. ,

Free August. 1973 until November,1975 I was eeployed by Kaiser Inc. as a Lead Electrical Quality Engineer and after November, 1976 as Assistant Quality 6 Manager at the :i==er Nuclear Power Statien currently under censt uction in Chio.

While employed at the Zi==er site, I worked for Bill Friedrich the Quality Centrol e Manager for Kaiser Engrs. Inr.. Bill was replaced in Nove..ber of 1976 at the re-quest of Willias Schwiers of C;&E due to a disagreement he had wi e Schwiers over the operation of the Quality Control Prograd at Zim=er. Bill Triedrich kept no secrets on the reasons for [his replacement. Friedrich wanted to hire mere inspectors, and wanted to conduct the :imer QA progra: according to Nuclear Standards. Friedrich had extensive exper.ience in the Nuclear indust:/ and was atte:pting to implem ent the KII QA Progris and industry standa.-ds on this site.

Bill Schwiers was the COCI QA and Stds. ingineer (i.e. Quality w.gr.) on site and did not want to hire the Inspectors Bill requested. Schwiers did r.ct have any previous nuclear experience and had an Acco :nting background, was cost conscir.,us .

and not co:mittsd to imple=enting KII's QA Pr:gra:s at the :i=cr site. Schwier's did not back Triedrich's request for more inspectors en the site when work at the site was underway at a faster pace and more inspectors were needed to get the jcb done. Schwier's d.id not want to spend the money on inspectors, refused Friedrich's requests and eventually replaced Friedrich, or had Kaiser replace him on the site.

Friedrich's replacement, Scb Tur'ner, ran into the sa e problem with Schwiers, agsin '

Turner , wanted to hire more inspectors and Schwiers refused Tumer approval to hire them. The inspection program at Zinmer was less than adequate due to the sheer lack of Inspection -ar-ever en the siae. Ter eva-ale, fi .9er had e .ly cp; rex!::*.cly 8%

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2n.;ro:ess line inspectors at the site, whereas o*.5er site: have 3CO-353 Ot i .;r :::: lir.e inspectcr:. Oir. e had appr:xi-ately 3-1 Quality Inges. P s cry

.2 : f:rty. Other site: hr.w :;;r ximatelj 00-5; Qus tity I.9gineers.

In my opinian the Management of CCCI was net cc =itted to a Nuclear Quality Assurar.ce program. This was evidenced by the following conditions:

1. Receipt inspection was less than adequate.

, 2. In-process inspection was less than adequate, and docu=entatien of in-process inspection was poor.

3. Scurce inspection was less than adequate.

4 Vendor audits were"less than adequate.

S. As built drawings were not available to craft personnel due to frequent revisica to the drawings. Mar.f as built installations were not docu-mented.

6. Revisions were =ade to the ele (trical specifications which.resulted in the voiding of confor ances that had been identified by Q inspectors.

7. t*endor supplied items had poor quality welds on them.

At one ti=e Schwier* s objected to my preposal to put an inspector with every safety related cable pulling crew. He felt 100% inspection of safety related cable pulls was unnecessary, although this was standard for the nuclear industry.

After I left the site I heard things got worse. A revision was made to a speci-fication which allowed for the pulli.9g of cables in raceways where the hangers and supports had not been co=pletely installed, also cables were pulled and im-properly trained. A nonconformance report was written on it, and subsequently

'the specification was revised to allow for the impreper training of cables in cable runs.

Also after I left I heard that Bob Marshall, Construction Superintendent walked into the. Quality Control Office one day and shouted to everyone present,

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. again".  ! also heard that n:ncenfer ance reports issued by the irspectors identify:.; d:serep:.-cies in the plant were being voided withcut reason.

I have given Mr. McCarten = ore specific infor=ation regarding my concerns over ty  ;

the Quality Program at :ir.mer, this state =ent i s a brief su=.:ar/ oC-my ' con-l cerns in general.

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. I have read the above state =ent, made the necessar/ corrections, initialed ,

mistakes and it is true and correct, i

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Schscribed to before =e er. this 29th day of Januarp at Per

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. ATTACHMENT 11 STATEMENT -

I , Teh.,n R., Enn r H , hereby make the following voluntary statement to &ln wJ c - c,n tt e;- r who has identified himself to me as an Investigator witn the U. S. fluclear Regulatory Connission. I make this statement freely with no threats or promises of reward having been made to me. Inves tigator G i t.B ER.T is writing /fri-'4 this statement for me at my request.

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i I have read the foregoing statement cor.sisting of @ handwritten /W pages.

I have made and initialed any necessary corrections and have signed my name in in the margin of each page. This state ent is true to the best of my knowledce and belief.

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I:lTERVIEWEE: 4 Name:"Tohn R, EcoT tt 1981, a t H E, v } . da Subscribed and sworn to me the lo d day of Fely . , _

INVESTIGATOR: Celte.d C. M h d~

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I, "M E. . T Y R, E E. . hereby CE*xe the following voluntary state er.:

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/ typing this statement for me at ny request. -

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l I have read the fere; ing statement cor.sisting of S hand,:ri tten/W pages.

l .L I have r.ade and initialed any necessary correctic s an: have siened ey na e in 4 in the car;in cf eacn page. Inis statement is tr.,e to the best cf my kncasedce and belief.

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l I;1TERVIEWEE: /[YIS I iVE -

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- s STATEP.ENT O 1, Q s) R . P R.t c E , hereby m!'<e the follcwing voluntary statement to r,L - J c c.ic u : r who has idantified himself to me as an Investiga :r wi n tne U. 5. tiu: lear Regulatory Ccx.issien. I make this statement freely with no threats er pr:=ises of reward having been cade to me. Invesyigator Gii. t s ;tT is writing.,-f ; this statement for me at r.y request. .

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I have mace and initialed any necessary correctiers anc have signed ry na e in ir. :.e cargin of each page. This state:er.: is true to the best of my kr.c.,ied;e and belief.

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% Name: C'. c ha r) g P R i t. E I h subscribed and sworn to me the a day of A L 19_fl 2 H d U^,

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• is , writing / ; ' ;_ this state an; for me at r.y request.

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STATEMENT I , _ Ja M E S l. R A M S EY , hereby make the following voluntary statement to P r e n. E'. Bac! who has ide..tified himself to me as an Investigat:-

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U V J G cf I have read the foregoing state en c:nsis:'n 6 V .

! I have made and initialed any ne:essary correc;tions anc have siene in the margin cf each page.

and belief. This statement is true to the test of my kn:wledge 1.

4 kI!TERVIEWEE: M O , - r_.;/ 8 Ma , !'ed' f Nfe: QAmzS L. N~i 'A MSEf }

Subscribed and s -- :: ce tha 7'M d y of 7~5 3 ,1971,, at P//,/e.een th INVESTIGATOR: s d .: _ , , 'N C<. ' Ff BM k

, na b ? E T c rs.

C~'Bec/

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!h4 WITNESS: Ed _ -) C Nd>_Y ~7 : 79 4.n , . -a 1 na=e: nw e re c. G/tw/tr- '9 /

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m m,.- an . ..-.~.-,..-,.- n t ,

ATTACHMENT 12 -

Barrett, Streeter, Warnick, Davis f ~

POSITION ON " UNAPPROVED VENDORS" Attached are relevant sections of investigation reports dealing with concerns

l. expressed by Mr. Victor Griffin in 1976. One of his concerns dealt with

' materials purchased from " unapproved vendors". Investigation indicated that so=e materials (not co=ponents) had been purchased to class II requirements, although documentation sufficient to meet Class I requirements was also provided. In some instances, these Class II materials were upgraded to Class I and utilized in the plant. The findings of reports 76-02 and 77-03 indicate that we considered this an acceptable practice, and the media (and public) were advised of our position.

It appears that the item of noncompliance issued in Section 7.1 of report 80-13 may represent a different conclusion on a similar situation, unless a beam is considered as a " component" rather than a material. ,

I believe that Mr. Griffin, and others,'may question this apparent difference, and we should have an answer developed.

James E. Foster O

t

• ' h -- - -+

. , , ; _ p g, c n f. . t,...c , _s -

y ._

. ATTACHMENT 13

, , Investigation of Supplier Quality Accurance at V,1,llian H. Zitner Nuclear Genera tir.g Station s .

Purpoce -

The inv,cctigation was conducted at the Um. H. Zimmer Nucicar Cencrating Station construction site to deternine the status of the following:

i o Uhether structural constructicn tatorials purchased as Non-Ecdontial I

cnd subsequently upgraded to Essential adequately acct procurement require =cnts for Essential catorials. V o Uhat types of ite=s and enterials other than structural caterials were procured Non-Essential and issued Ecscntial.

o The extent to which upgrading of items and. materials has occurred.

o Whether a similar upgradin; has occurred with ASME Code co=ponents and i

materials. .

o How su'ppliers of Essential and ASME Code ite=s and natcrials are scl-4 ccted and controlled.

o The adequacy of rccciving inspection and supplier docu=entation revicus.

l o , 'The cdequacy of cupplier quality record collection, control and retricv-l ability.

1 l .

. Scope

,The primary focus of this investigation was on the methods u' sed to procure Non-Essential, Essential and ASME Code compenents end tatorials used by Henry J. Kaiser Conpany (~EI) and what controls have historichily beca and are currently in effect. Insofar as Foothill Electric Cc=pany and Cincinnati Ca's and Electric Company have procured =aterials on KE1 purchase order forms, these procurencnts have also come into consideration. Activitics invecti-gdted include cite Quality Engineering reviews of purchase requisitiene and purchase orderc; generatien, application and storage ci Scurce Inspectica l Plans, Receiving Inspcetion Plans; qualificatien of supplicrs;- =aintenance l of the Approved Vendors List; cupplic qualification records centrol.

1 .

Supplier Quality Assurance activities not considered within the scope cf this investigatica ara, in general, those activitica which occur prior to the Quality Engineering approval of the purchase requisitten and those .

uhich occur cubsequent to the reccipt of the caterial. Anong the activi-tics not incledcd are t':c incin.iir : f tre:f f h r.:f r r ' /-- " ' "Muir0-nents in purchace requisitica generation, the generat ion and closc-cut cf

'i Fate 1 of 12

_, - , . - . . , . - - - - - - - , - , . - - . - , - . - ~, .-.n

}lonconfor:ance Ecperts and Document Deficiency 1 oticcc, control of tater-ial issuance fron the varchcuce and control of field installation.

General At the request of David L. Howard, Director of Quality Assurance Programs.

Taiser Engineers, Inc., Sherrill J. !! older, Supplier Quality Engineer of

)*aiser Engineerc, Inc. 's Corporate Quality Accurance Division conducted an investigation at Um. H. Zi=cr Nuclear Ccncrating Station to:

o Dctc'mine what catorials have been upgraded from Non-Essential to -

Essential. .

o' How much upgrading has occurred. .

o o What significant quality differences exist between upgraded and Essen-tial catcrials.

o Detemine the adequacy of the site. procurement document control. .

o Access vendor evaluation, approval, control and the. level of documen-tation. .

! o Detemine the adequacy of supplier docu=cntation review and storage, o Deternine hictorical and current ccthods of procurc=cnt control. ,

o "Detomine procurement ecmpliance with the requirements of the governing documents including liJK's Zi=cer Quality Assurance Procedures (QAP's),

HJK's Quality Assurance Methode Instructions (QACMI's),10CFK50 - Appendix B, ASME Code (Su=cr 1973 Addenda), as applicabic.

The investigation consicted of interviews and docu=ent revicus conducted at the site on July 21 - 24, 1981 and July 28 - 31, 1981. There were no statistical samplings of docu=cnts performed; this investigation does not I

constitute an audit. Contact was cade with the following site personnel: ~

s Paul Kyncr -------- Sito QA Manager, HJK John Unthins ------ Assistant Site QA l'anager/Ac' ting QE Manager, HJK

, Jerry Chase - - Supervisor of Docurent Evaluation HJK

~ Chuck Bur'gess -- - l'anager, Inspection, HJK ,

Jack Decrucster ---- QE/QA Lead Receiving Inspector, HJK Charlie Winters ----- Eccciving Incpector, HJK '

Bill Ferree -------- Warcheuse Manager, HJK Dave O'Keef e ------- - - Precurencnt Manaccr, HJK Ken Shinkle ---- -- QE Structural / Civil, HJK Terry Coburn - Uork Package Control, HJK l Floyd Olt z ----- Lead, Procedurcs, Cc=itecnts/ Trending, HJK t

Bill Tobin -------- Structural / Civil Documentatien Evaluation, HJK '

Jach !!crris -------- Assistant I'. na,qer, Reverification.Tn k Force, 1*AC ,

i Bob D'Arcy ------- Censultant, J.1 i

l l

Page ,,]._ of 12 .

Tinc could be cavid by confining the initial campling to high volume and/

or extremely critical purchase orders.

A sample of purelace ordere for electrical and ASIC Code n:terials and componente crc'ere ' en D. icer ferra uhnuM 1..3 revimd te detcrain . if pro--

curement, design; quality and Ccde requirc=cnts were net. If Kaiser it to stamp off Code inctallations, docucentation packages revicued by CGLE nuat also be revicred by Kaiser for compliance to the requirencnts of the 1973 Sucm,cr Addenda to the ASIS Code. If CCLE accunes the Code responci-bility, the QAP's .cust be codified to delete Knicer's responsibility.

One of the nost crucial tasks at this ti=c is to collect cud compile the applicable ~ntnorande=s, letters and notec, uhich have codified cite pro-cedure fr.ple=entation, into a usable ref erence file. An evaluation of ocsc of this correnpendence could result in a reduction of*Kaiscr's re-sponsibility for the procurc=cnt/s,upplier functions.

! The current Approved Vendors' Lict should be revicued and revised to re-ficct the current status of vendora. If the Sargent & Lundy and CGLE AVL's are to' be used for purchase order approval, they should be nade available to the reviewing QE. There =ay be a CC&E requirc=ent for vendors to be resurveyed cvery three years; if so, currently used vendors uith expired surveys should be resurveyed. It is reco= mended that Jcck Decruccter, the QE/ Lead Inspector, be assigned thc responsibility for hceping the AVL cur-rent since his work, revicaing purchase orders, is most dependent on a current AVL and he has b~een evaluating the sup' pliers cince 1973 (and for-varding the infor=ation for publication) . .

In the opccific ecac of studs and nuts in the warehouac, it is reccomended that purchase requisiticus, design docutants and dravings be reviewed to establish where their studs and nuts belong and a plcut inspcetion be con-ducted to establish vint ana installed in their place.

t the fitting supplicr, Cincinnati Valve, is in the process of being sur-l vcyed for additica to the AVL. Either the manufacture Crauford (Svagelok) t should be curveyed and sc=plings of fittings taken for hydrostatij and de:tructive testing or the Sargent & Lundy specifications shtnld be modi-fied.

The QAP's should be revised to eliminate enbiguitics, reficct ASIC Code requirencnts, reflect CGLE agrec=cnts uith the NRC and CG6E directives to

. Kaiser, and to clkninate overly stringent requirencntc. An additional aspect whic.h is cut of the scope of this report but cheuld be, considered is the effcet of agrec ents betvcen CG6E and the NRC such that a direct application of 10CFR50 cay not be totally approprinte.

d

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l 1

Page 12 of 12

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ATTACHMENT 14 AFFIDAVIT STATE OF OHIO )

) ss COUNTY OF CLERMONT)

Victor C. Griffin, being first duly cautioned and sworn states as follows:

On April 27, 1982, I met with Jim Foster of the NRC, at his request. This meeting took place at the Riverview Restaurant, Route 52, near New Richmond, Ohio. Mr. Foster stated that he wanted to review my concerns about the safety of the Zimmer Nuclear Plant.

In the course of our conversation, I detailed my concerns, which I had in previous meetings, already told him about. Basically, these concerns involved the-lack of independent quality verification by CG&E of the critical components purchased directly by the Utility from various manfacturers around the country for installation at Zimmer. I also pointed out specific " essential" components which had the potential for causing a safety hazzard at Zimmer.

Mr. Foster took notes, but made no comments of agreement or disagreement with my concern about the aforementioned conditions.

However, his entire attitude was protective of the Utility and the Nuclear Industry, generally. I accused him a a strong pro-Nuclear and pro-Utility policy to which he replied that it did not matter because his job was safe in any event. At that point, I told Mr.

Foster that, historically, anyone connected with the NRC or the Nuclear i

Industry who expressed a negative concern about the Nuclear Technology, either lost their jobs or were pressured into resigning. I referenced

Doctors Tamplin and Goffman as examples of this situation. Mr. Foster expressed contempt for the views and opinions of these eminent scientists.

I also made reference to a new book, " Nuclear Witness, Insiders Speak Out", by Leslie J. Freeman, that documents the concerns of former nuclear workers who became disenchanted with the nuclear tech-nology, as practiced, and the cover-ups by the Atomic Energy Commission and its successor, the NRC. Mr. Foster said he had read the book and, again, expressed contempt for the book and its author, saying he was surprised that anyone would read beyond the first chapter.

As our conversation proceeded, it became increasingly an-tagonistic, as it became obvious to me that Mr. Foster was merely trying to get information from me so the NRC and the Utility attorneys would have an opportunity, from a time standpoint, to whitewash my allegations, as they did over six years ago. We, therefore, terminated the meeting, after about two hours.

l In a phone conversation initiated by me on August 18, 1982, l

Mr. Foster indicated to me that no resolution of my concerns had been made, and indicated that the NRC was trying to downgrade an Easential Component of my concern to Non-essential, as a way to overcome the problem with the "Nash Condenser".

l' / Df Victor C. Griffin

) heu

//

l Sworn to before me and subscribed in my presence this A

/C ' day of //U C (' W , 1982.

3 Os C LL D/QL E. LILLICH IS:::y Pt0:,5:::: Of 03b l

I [*/ C:: h:::Q::::s Jm I,1737 i

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[ '

( f, UNITED STATES

[% ATTACHMENT 15 3-

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~-

hvCLEAR REGULATORY C-

1. .I REGION lli oY $C 8

• I 799 ROOSEVELT RO AD

. gg *g CLEN ELtVN,ILLINol5 60137

...,e May 14, 1981 MDiORANDUM FOR: Zimer File (Deputy Director's Office)

FROM: A. Bert Davis, Deputy Director SUB.TECT: DISCUSSION WITH TOM DANIELS, SRI, ZIMMER During the Resident Inspector's Social Hour last night (5/13/81) I had a lengthy discussion with Tom concerning Zimmer. Tom stated that his position with respect to Zimer is that it should be shut down until all their problems are corrected. He had previously taken this position at my visit to Zic=er a couple of months ago. As near as I could tell Tom's reasons were primarily based on the fact that personnel at the site who have made past errors and involved in past problems are in the most part still there. Therefore, continued errors could occur.

I discussed with Tom the Immediate Action Letter and attempted to get him to be specific as to whether or not future work is adequately controlled l

' by the IAL. As I attempted to become specific with respect to his concerns, it anoeared that his position was primarily based on a gut feel and a mistrust of the Kaiser and CG&E organization and people. The only specific i .

he could come up with with respect to whether or not future work not being i properly controlled was a preliminary finding that a number of noncomformance reports were being piled up rather than being promptly reviewed. He based this on a statement made to him by a Mr. Haas. When he pursued it with Mr. Schwiers, he was told that the noncomfor=ance reports were being reviewed and that the ones in question were planned to be reviewed that night by Mr. Schwiers. Tom indicated that before he made this a finding, he wanted to pursue it further. I asked him to do that and provide the infer =stion to i me.

l Based on Tom's feeling, I believe it is necessary to oursue it to get details, l so that we can determine whether or not there is a basis for shutting down the l project.

A. Bert Davis Denuty *)irector iK

~

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(

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ATTACHMENT 16 s

UNITEo STATES

• /~' p' c ,,b, NUCLEAR REGULATORY COMMISSION [,

.' * \*' ^r*

• [ ~.

• ftEGloN til h ' **

t 799 RooSEVE LT meAo o .. k [ CLEN E LLYN, ILLINOIS 60137 e

nf ,

February 25, 1932 NIMORANDUM FOR: Robert F. Warnick, Director, Enforcement and Investigation Staff l FROM: J. B. McCarten. Investigator I -

SUBJECT:

ZIMMER DOCUMENT ASD INVESTIGATION LEADS Reference your February 2 letter regarding this subject. The following records which were not already in the Region III EIS files were turned over to the EIS Section.

1. My notes from eighty-four field interviews conducted between January 14, 1981 and August 13, 1981.

2. My interview notes and copies of all statements related to the investigation of the Applegate and QC Inspector allegations. This includes transcripts of all taped interviews.

3. Copies of all documentation relating to the investigation of the Kaiser Nonconfor=ance Reporting System. e NOTE: The original pages of the NR Log Book, and Nonconformance Reports found in the Inspection Report have been turned over to OIA for custody.

4. Due to my assign =ent to the Zion investigation team I was unable to review or augment the computerized li'st of allegations so that all leads are tracked. I have, however, provided Investigator Foster

. with all the statements taken by me and copies of all my interview

, notes so that he can perform this much needed task.

5. .On three occasions during the Zi==er investigation the Region III Enforcement and Investigation Staff has informed OIA and DOJ that Region III would pursue all issues which may constitute violations of criminal law. The investigators currently assigned to this case have no training of any kind frem a federally recognized Criminal Law Enforcement Training Center, or any experience in the investiga- .

tion or enforcement of criminal law. The Region is not fu11 filling its commitment to OIA and DOJ without assuring personnel with the requisite training and experience are assigned to this case. I recom=end an individual from the IE:HQ staff with the proper experience be assigned and be given the proper authority independent of the Region III staff to conduct this investigation.

<# s. - ti

I -

February 25, 1982 ,

,.* . Robert F. L'arnick , .

' I It is my recommendation that at a minimum these records for various evidentiary purposes in either a criminal or civil case should be maintained e until all civil or criminal litigation is complete. This includes final licensing of the plant and the conclusion of any private or government civil action.

In my opinion, these records should be maintained in the Ragion III Files for the life of the plant. t

..;4 f3 Y.k James B. McCarten Investigator cc: Region III Files James Cummings, OIA Roger Fortuna I&E J

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U.S. De--

ATTACHMENT 17

.'<:: y s.wy]4 United States Attorney

• Southern District of Ohio 220 t!nited States Post Office & Courthouse (FTS/313) 684 3711 100 East Fifth Streer 634 27 3 Cincinnatt. Chlo 43202 684 3961 March 19, 1982 PRESS RELEASE I

Christopher K. Barnes, United States Attorney for the Southern District of Ohio The Nuclear Regulatory Commission (NRC) has advised this. office that its Office of Inspections and Enforcement (I&E) is conducting an investigation into allegations of non-compliance j of NRC safety regulatio.ns at the Zimmer Nuclear Power Plant 1

i at Moscow, Ohio. -

a I&E is the agency responsible for ensuring that the Zimmer plant is being constructed in compliance with NRC safety regulations. I&E has been and still is inspecting the con-struction of the Zimmer plant. A draft preliminary report was issued by I&E on August 15, 1981. Their final report however has not yet been completed.

The primary concern of the NRC and the Justice Department is the safety of the plant and the community. As

such, top priority has been accorded the I&E's civil investi-1 l

l

e e

gation. When I&E completes its investigation and report and is assured that the plant is in compliance with NRC regula-tions, any criminal allegations will be' reviewed by the NRC Office of Inspector and Auditor and forwarded to the .Tustice Department for consideration.

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• " COMMITTEE ON INTERIOR AND INSULAR AFFAIRS anO cOueescL

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July 12, 1982 The Honorable Nunzio Palladino Chairman United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Chairman:

At our June 10 hearing, NRC staff were unable to answer basic questions as to the state of progress in the Zimmer Quality Confirmation Program. Moreover, there has been an inordinate delay in responding to my letter of June 14 asking for information that was not provided at the' hearing.

I fear the inability to answer questions and the delay in responding to my letter support the conclusion that Region III staff are insufficiently aware of the status of the Zimmer project.

I would appreciate a response to my June 14 letter by

! July 16.

i Thank you for your cooperation.

~

erely,

~

S Chairman s

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Attached are the eighteen inspection report items identified by N!(C/III on March 27, 1981. Corrective action proposed by CG&E in the May 18, 1981 draft has been modified by NRC/III and revietied and further modified with CCLE in a.mcoting June 2, 1981. These modifications have becr1 made on the attached and indicated by lines in the right margin.

This is a preliminary working issue for inforn tion.

l W. D. Waymire The Cincinnat.i Gas & Electric Compa:1y e

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• Apparent lack of an adequate QA program covering

. field velding resulting in some unacceptabic structural welds (Ref. Item 5).

O DISCUSSION:

Inspection of structural beam welds in Q'.a 4 g

the 54 6 ' clavation of the Auxiliary Euilding,

,Cnble Spreading Room, and RilR Heat Exchanger Room .

revealed that several ficld welds are unacceptabic to AWS wcld inspectio'n critoria.

fog.fp?gg7g*t)ll&;f;Qc:3&,')?fpllz.]) ///667hfk* kC/Aff/).hdrGZf.c

-- .' q QCP ACTIC3: 1. Establish a drawing review to determine whcre fff Bristol Structural Steci field welding c::ists.

This review will also determine the location of other vendor field welds (i.c., HJK, FEC, WYLB).

a) Uso S&L structural drhtwings rccrked by

~

Bristol' (framing plans) . -

b) Superimpose added beam drawings installed

~

by other contractors (HJK, FEC, WYLB) .

Identify beams which may have been installed' c) ,

4- by HJK on field work orders.

d) Comparc drawings against plant as-built condition.

Determine acceptability of design and .

• construction JM /) spi),'rio;)'s h>faripjgj).

2. Determine arcas of structural steel field ucids . . ,

l han,uidQj))f, and identiEy samc $ ' h/lSS&l~ f/IIO'I' 0l ,$ 0 bdWLb f6s tM6SS/?L.6/lt 6o / A"H7'sy f /dj.. :

f)P,t;&jf,;j)3 Uncover embedments l

- a)

• • Ab bd),%)N s

b) Uncover one end of beam. If bolted, and drawing shows wclded, do not assun.: other end is bolted.

Uncover other end also, c) //>'sc=st 'W "r'/:n.&t Sdtoto. _

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' a i c) Search Bristol DDC's to identify Dristol

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g._, \ fic1d u.23ds.

j'/I.0 E N IIN , a) na ry c ; ,;5 a.;.. to iden t.ity loc:.L * - ~ ^"

\

. structural steel field welds, e) Octorminc requirements for acceptable welds.

3. Remove paint from the wc30s that may preclude proper wcld inspectionA Quantify the ,numhTr 7fy ,ge W//dAf,&

co MS M .CdAfdyRL */:LC'Al O):

of Mou-tec ' welds,\and review w.ith NRC.

a)iLL t.M6/-f' d4f T D?fA !*./3. /ToA's t,'"6 ) g,c yk(?,

4. "'- l.##4 Conduct a 1005 visual inspection of

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Astructural stcol field welds o #, d'<sT/,d. /d:fd.

5. ConductCAO& v.i.sua-1 -inopectfon~oG~oth:

/

, Ecc<!inrible-vendor-c'cructur-cl -stee-1-faidmhis. .

Q:Q. pct.i fy- lesse Conduct 1000 visual inspection of accccsibic Dristol shop. welds or justify less.l

\

G. Writo Nonconformance Reports on all unacceptable FA Yo \

welds -end zQ,:stG r v.My- disposition, ho'ud.igNRC/III

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7. Review records, procedurcs, and documentation

       '.                                                                                                           ////D t.tidLDS.LGf/Ad.)/ BAT /.;c to determine the types of welding proceduresAused l                                                          on the job, special requirements called out in these l                                                          procedurcs, and types of weld rod specifed for field' welding.                 Arfurt-he r-rea.-i-cu--efwc44 -r-cd'                          gg,,d6)
    -          -                                                                                                                                        8 466 mattr-ihecc1Edg-~fM5tyr-t-e- and ve-1& rod- cauc>g &g                                               .

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0. Perform 100?. inspection of[re-entrar t cornor e//

t~ beams which could affect safety related

                                                                              /VA.'.//*d 4/pjj bpt/A W Min /N d systemsorl equipment. SocumerA on t' / 9 a nd-f.df0/STA'O// A'6C 41///IGC&/17AdiCG 26*d/llX/2//J' "Iwoj>erly -d'i-sposit-j o:t,e inclutli_n(t'ljfC/J,JJ- rovie+P dOlb//GJLS, f/30,0C'S6 D/S w o r- + n el',s. pose.-t-r.on<          /

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Concern - P ... - -. Q,j'hes--av.9 Dr3 stol_p,LL

                                - gC perjon,.rcq    apdram        _ etion
                                                             .inspc   unfuj.uitdgsgua      ;

tq3onha cd' suas not implani.cnted. 19:-..., in:ipec -- . M,J 3 y s - Discussion j l Duc to the uniqueness!,of the contractual relationship between Bra.stol we believe andthat

                                    !!.J.-Kaiser and the limited ccope of the work, part of the QCP, this is nn isolated incident. !!owever, as we will investigate work done by other subcontractors who were on site at the same timo as Bristol.

OCP Action .

                  *1. Identify other subcontractors.

2.

       .                 Provide assurance that GA programs of other subcontracto: 3 were acceptable or that work was and is acceptabic.

9 4 I e O I e e G e

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0 e m se 9 e e G e 9 e ge 9 e a e 4 p e..

AND AUXILIAP.Y DUILDji;G a co?;C;;n::: Several hundred feet of beams have been received from a:: unapproved vendor, and cannot be accounted for as to where installed or utner disposition.

                                                                                              ,                                    9 H. J. Kaiser purchased W8X17 beams from a nonb                              O DISCUSSION:

approved vendor. These beams were placed in essential steel stock on the basis that they were supplicd with valid mill certificated by the vendor at tJ.mc of

                                                                                          ~

i purchasc. '

                                         &C $i~Mtcrud? AL Sfd6t, adW.2// fa%/)fAS6CI".;Wiff N W WE j/                                            ' '

QCP ACTION: 1. uct an audit _of alltst M received on site RClD PN/ cN/.'.cdo :'t?.'.Gl. f%/; TEA /m S/W:nj?/LAif51jQ f- 'Y,'

                                                         % ct.d determine the supp12er.                             -

2. Verify that the supplier of this material is an *'

IIJK or CG&E approved vendor.

                                     .              3.      CG&E/HJK Q.A. will perform a vendor survey in accordance with approved'p'rocedures to verify the credibility of the mill certifications and the vendor performance to their Q.A. manual.

4. If the vendor is found to be unccceptable, then the manufacturer of the steel will be surveyed.

! 5. If all surveys described in 2, 3, and 4, above are unaccep, tabic, a program will be initiated to identify the stcci which wan supplied by an

                                                                                                          ~

unapproved vendor. e 0 e e 8"9+.*.a e gae genyg gg _ _ ese e apeG ep _ _ N - gue N euBWD

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                                                                                                                              ---M-leau--than--l-0%.

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ef--cli ether essential material, ic: piping;

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   .[..n[. o' ,,p . # },, e Ucld rod, fittings; Cable, etc. c4///t 86/Ae'/'/.5 //80 737 fi."P/we'Os se,p)wds'.s.

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• 3 IfiSPi.CTIO:1 RLPOR1,13c & d - LACK.0F IPACEACILITY CF 11ATERIALS per.blem Traccability of heat nunters on srall bore piping for the Diesel Ccncrators. .

ffo records exist to show that some of the installed pipe is ac-ceptable. The heat numbers da not appear on the ll.J. raiser list of acceptable he_at numbers. . Discussion - A review of the documentation of the small bore piping in the diesel generator system followed by a walk down of the piping revealed some lack of traceability in accordance with. ASME Code requirements. An inspection program will be implemented to correct this situation. Small bore piping on other systems will also be included in the pro-gram as well as some large bore piping. OCP Action

3. . Conduct an inspection of 100t of the accessible field g

                         . installed small borc piping in all safety related systems for traccability in accordance with ASME Code require-ments.                                       .  ...,

For all systems inportant to safety,) bcomparefy..s dxist?)/k docu-

2. 1 mentation against accessibic field installed small bore '

piping for traceability in accordance with applicabic code requirements to achieve a 95/95 confidence level.

3. Provide justification for acceptability of inaccessible small bore piping.

          .'       4.       For    largo bore pi;ing in all sa{cty related systems (t)and all systems important to safety.)

a. Identify all field modifications

b. Walkdcwn 100% of the large borc piping involved in the field modifications. Ccmparc documentation against the installed large boro piping for traccability in accordance with ASoin requirements.

5. If heat number traceability on ASME work can onl-y be established by the KEI-1 form, then it will be necessary to cctablish the credability of heat number on the KEI-l forms.

6. Dotcumem:--a1-l~3e C-ielene-ie c.-an._1:/.PhanJ-prone ely -d+ twi-tio win c l u d i n.J-N nc/I-I-I_re v i cu__. p r i c r -tc- d i spe rit-i on- .

alas 76 Usddo//t%cptxtr'.S c f&/Lzc17 CH HLL '/d^ # 'W'  %

                            . pc t' sci 6/K/SS .'OttNA, /~M/%o .s 6 .9).sf.

S'J~/N h //d, l/E N/l i

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                                        ~
                                                                                                                                                             ~
                                                                                                                               .a If;5PECT,10 PITOP.i #3e - LACK Of !O!E!il AL T!:M.EASILITY Concern: Ucid rod heat nunters are :icinij tre:.ier t t: to tiie i C-1 v eid                                                                                   ~
                                                                                        ~ ~ ~

form from the KE-2 from by individuals other than the QC Inspector who int.pected the wcld. . Discussion: , At the present tire the quality documents are under the care, custody, and control of C.G.t. E. 11. J. Kais6r has been ordered to stop the transfer of inforretion between the KC-1 and KE-2 forms. . Qr.P Action '

                                                                                                                                                         $NPPsAl"                          od

1. For all structu:al/guelds suppor-t+.rghclass 1, 2 and 3 systems, identify all welds for which a credibic heat Th-ieir. cit ++ t-here-number has not been maintained.

                                                                                                                            .4cr-whi ch-431- 1f       - orm--warraitored,                                                                               .

2. -(s.Wher .Oescribe corrective actionc 'that will be' taken or else indicate that findings will be provided to the NRC and correctivo actions will be proposed to the NRC for approval.p e

o e 9 e e e 9 98 ' e es _ _ _ _ _ _ . _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - -- . . a

                                                                                                                         , - - - - - - - - - - -       ~-

__ _ _____ ________. ; . . . ~. -

                       ; !.1;i 0;.T ji i - S t i:a' t . i i .: .A::t'l: i:i ..*Wa':.        t h > I 111::::;; co;;'.'t;1ri!:',

a T O !!O::c o::i'u:.::7.::.:1; Itt::'o!rr", IU 30 IJAYS

                 .o                   .

Nonconformances docum:.nted o,n surveillance reports. ~

           .l'2oj9_n__

Review all surveillance reports and identi fy all that should have been nonconformance reports. Review OA p'rc-op turnover punchlists and c):coption lists to identify any items.that should have been documented on' DonConformance repCrts. Process-those-i-dent _ find thrcmjh- the nonconformar.ce-r.epor-tr sy .d cr.r-f-o rgop e.r._d i c po s i t-i-on. - 4t),ei78 JV:/>'&pf,@/."./:JNHc'd 26/-V<::T.S fo.;t-GAc// 5NGH

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 .' S C US S ION :                                                                                                                                                                                            I PEC has installed structural bea:nc and cable tray                                                                                                  ,

9 supports and have used Galvanox and other coatings to prevent the corrosien of the velds. Although n'o documentation exists that verifies that t,h e se wolds were inspected at that time, hanger inspection along with,its. associated structural steel was in-process inspected and all work was assumed to be acceptable by construction unless reported unacceptable by Quality Control inspectors. P ACTION: *

1. Determine those areas where weld inspection of A 6 0 i ,

4)f/P.5 od suspension systems , incl 6d.ing pipe supports, has , taken place after the uc1d was painted.

2. (d For safety related. systems, conduct 100% visual sLs'usDr~cf l6 *f. ;

inspection of welds. identified in 1 above/, , For all systems important 60 conduct a sar.pling grytug.ijft, lor 5~/2fs d.'.u~f/C/dA' Tup tolea6 s a fe5 ty 72,, /W%'7/Cf)Cn' ' id ';&iffr[

                                                                                                                                                                                                     / ,,

program een-si-a-cing of a 95., con fidence f acf.or that i 95% of the sample is acceptabic. Th W rrafrn= TJbuld tavc_.t-hofo.l.lowingcamplemnd.xicrypteer-ia : ab5'F of k&d5in__Jeveple_ SIcvsRinum_N693rsaf%f.ccr..c 1 T < i, 1, - P 4 r7 4

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3. Determine the wcId a'cceptance criterin per. design ,

M specifications and approved inspection procedurcs.

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Station %/ U~ - N " Notification of Unusual Eventi.E!' W

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    >jor.t: .iE LICENSEEJAUTHORIZED TO REDUCE :100% REINSPFCTION PROGRAM /C * *                                                                                              'W 'F ~ .' " ' #&~9. .'
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                                   -- m As of ; August 1g:1982,..the .!icensee has .been ' authorized by Region fIII Lo reduce its 100 percen-reinspection program ofi constructor.and subcontractor, Quality Control' inspections. The . r r. r..

Licensee was required to; perform 100 percent reinspections in an Immediate Action t etter d' '.- (TAl.) on April 8, do81. :The IAL was -in response to numerous instances of GA/QC deficiencies . at t.he Zi mner plant. , The Licensee has asked that' thin 100- percent reinspection program be ' reduced.: It bases its i renun.sl:on itst revised quality assurance program and the revised QA programs of its -

• constructor, Kaiser Engineering,. and contractors. Region III is satisfied with the. licensee' efforts thus far,.and has approved the licensee's request, allowing a reduction to 50 percent of reinspections plus a surveillance program. The Leveln of inspection and surveillance wiLL be adjusted monthly, depending on findings. The constructor, Kaiser Engineering, and subcontractore wiLL continue their futt inspection programs. -

(

    .N            andia . interest is anticipated.                               Region III (Chicago) does not plan a press release.

at this time, but .Witt respond to inquiries. The State of Ohio wiLL hs. notified. - This information is current as of 1 p.m. (CDT) on August 3,1982. _.

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c Attachm nt 21 GOVERNMENT ACCOUNTADILITY PROJECT Institute for Pohcy Studies 1001 Ove 5tmet. N W.. Washington. D.C. 20009 (202) TW 182

                                                                                               ~

July iS, 198P, Mr. Jamec Ecppler 14cional Administrator Rc61on III U.S. Nuclear Regulatory Commiccion 799 Roocovelt Road - Glen Ellyn, Illinoic 60137 ,

Dear iir. Keppler:

Enclosed are two documents for your urgent concideration. The first document is an affidavit signiTicant for your current invectigation.into welder qualificationc at Zimmer. The af fidavit suumarizes a July 8,1982 joint CGLE/Kaicer management meeting.. In my opinion, the affidavit deceribec a decision to intentionally coverup a fundamental breakdown of welder qualificationc documentation. I muct emphacice that the scope of this affidavit does -- not represent the extent of this witnocc' knowledge of welding deficiencies. He is prepared to discuss how thic in only. the latect exauple of a uuch wider, even more fundamental ' pattern - that existed cince the early 1970'c. . The witnecc already hac cpoken with HRC invectichtorc before and obtained confidentiality protection. I wil1 check with your office to confirp that the , previous commitment still applica. The cecond document, Exhibit E of' a -liny 24, 1982'" Henry - J. Kaicer Co. Analycic Report for Zimmer Project," may' repre-cent an even more brazen attempt at illegality. Thic ex reprecents the "UR Action Plan" and has one "Arcac (cic-)hibit to~ Consider" - " Fewer UR's". Fagq two lista five different waya ' to reduce UR's and another technique to allow invalidation of HR's. Based on the initialc next to each technique, Mecarc. Hedzick and Sager were directly involved in the plan. The methods include incroaced use of In-Procesc Inspection Deficiency Recrods (IIDR'c) and Corrective Action Reports for, inter nlin, non-hardware and Approved Vendora List (AVL) violations. Ac should be obvious from the document, CGLE and Kaiser are repeating almost exactly the came offences that led to the Quality Confirmation Program and last November's record fine. The document also helpc explain why your office hac' received oc uany allecationc of haracceent. Itec three on page two calla for "licart-to-Heart" talka . tith I'R origina:oro and review:rc. Item 7 provides the most chillinc exauple MM

e of why CCLE and Kaiser are not fit to administer the Quality Assurance ("QA") program at Zimmer. It identifies " habitual

          }l1 writers ano def.iciency tienerat.crs" as a ,ucwa problen.
          "'ho - prc pc -   r. u <.mnse in t'e ":1. vela n trent.r.. ". ':" writers and deia. clone.r Generavors' by J une 15, 1962.

• use pwnieu renui t,c'- --

          " Identify individuals for corrective action."                       Based on the              D initials, Mensrs. liede.ich and Sager appear to have been involVecN.P O with the scheue as well.

Quite clearly, the tra'ditional CGP<E/ Kaiser management philosophy remains deeply imbedded: those who identify - problems at.q the problem, and one which must be corrected. Under this premise, retaliation is inevitabic, and the QA pro 6rau at Ziramer has no legitimacy. . Last November you assured me that if CGflE. engaged in any future deception, you would not hesj. tate to shut down the plant. If the plans described in these documentic were carried out, that deception has occurred. I will look forward to discussing these issues with you. .

                                                                ' Sincerely,                           -

Thomas Devine ' Legal Director'

• 8 8 .,

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                               .                                                         .        T O

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                     ..      .                                                                           l l

Rex E. Baker Supervisor, Nondestructive Examination Henry J. Kaiser Company William H. Zimer Nuclear Construction Project Mr. Rex E. Baker, Supervisor, Nondestructive Examinati'on Group, Kaiser Engineering, Incorporated (KEI), was interviewed on June 11, 1981, by John R. Sinclair, Investigator, Office of Inspector and Auditor (0IA), U.S. Nuclear Regulatory Commission (NRC). Prior to any questioning, Mr. Baker was provided the opportunity of reviewing appropriate credentials and advised that the issues being investigated pertained to alleged . falsification of quality control inspection documentation and improperly

                        " voiding" and removing Nonconformance Reports (NR) from the Quality Assurance (QA) Record System.

Mr. Baker began by furnishing a brief description of his nuclear-related work experience and association with the Zimmer Nuclear Construction Project. Baker stated that he had retired from the U.S. Navy after completing a career in inspection and testing piping and components utilized in nuclear propulsion systems for naval ships. Baker further stated that he had joined Kaiser Engineering, Incorporated in April 1980 in the area of Nondestructive Examination (NDE) as a Quality Assurance Engineer. He (Baker) stated that he held this position until approximately July 1980 when he was reassigned and took the position of Inspection ( Supervisor in charge of all Quality Control (QC) Inspectors. Baker stated he held that position until recently (approximately May 1981) when he was again reassigned. Baker further stated that he'is now the Supervisor of the NDE group and as a practical matter with little or no supervisory responsibilities. Baker explained that there were two incidences which occurred almost at the same time and which immediately preceded his reassignment. According to Baker the NRC office in Chicago (Inspection and Enforcement) began an investigation concerning allegations - that NR's were being voided without proper justification. Baker stated that the problem with NR's began with the pipe hanger inspection program. Baker claimed that an individual by the name of l I Sila's Heath had preceded him as Inspection Supervisor and during that time the inspectors were finding problems with the hangers and writing up the discrepancies. The deficiencies were being recorded on NR's and as a result there were regular meetings with the QC Manager, Phil Gittings. According to Baker, Silas Heath quit the job due to lack of support from CA management and the fact that not only would QA management overrule QC inspectors findings, but they (management) contracted a consulting firm to review many of the inspections which had resulted in the writing of a

                               . C                                  (

Rex E. Baker 2 NR on deficiencies discovered in piping hangers. Baker explained that many deficiencies relating to hangers were identiifed by a gruop of QC . inspectors and as a result, these deficiencies (124) were all recorded on one NR. Baker continued by stating that there had been an ongoing

       .        problem with hangers. Specifically, the QC inspectors had been instructed

! not to inspect hangers supplied by vendors. This, according to Baker, l was because the hangers should have already been inspected by the vendor's l own QA Program. Baker stated that Kaiser informed the QA personnel that l all welds painted red would be censidered vendor welds and would not be I inspected by QC inspectors at the site. Baker then stated this would l have been an adequate procedure for identifying vendor welds if the l vendor had pajr.ted the hanger or the Kaiser receiving department had painted them prior to installation. However, Baker said that his inspectors had problems with the inspections in the field regarding the red vendor hangers. This was the result of discovering that not only were red hangers observed, but also red colored concrete adjacent to the h, anger. Baker stated that it was obvious that the hangers were being painted after installation. Baker further stated that he did not concur with this decision about not inspecting hangers which were red and forwarded a memorandum docurr.enting his position. Baker continued by stating that the problem with hangers was one of the things that resulted in contracting the consultants (Gladstone). Baker C then explained that Gladstone was a father and son company who came to the site initially because of the conflict in hanger inspections. As a result of Gladstone's work they wrote a report which stated that the QC inspections were not being conducted properly. After the report was l completed Gladstone then began to give classes (instructions) to the QC inspectors on conducting inspections. Baker said he attended two of the classes to ensure that-all of the inspectors were receiving the same , instruction. Baker also stated that it was his impression that Gladstone was not teaching the " code requirements"as much as they were conveying their interpretation of what the code requirements meant. Baker stated he questioned the credentials and " certification" cf Gladstone, however, he was advised by the QA Manager, Phil Gittings, that they (Gladstone) had over 30 years experience. Gittings responded to Baker's questions concerning certification of Gladstone personnel by stating that Gladstone personnel were "not certified AWS" ( American Welding Society). Baker stated that he had some difficulty in understanding how a company could be contracted to do a review of QC inspections i relating to " hanger" inspections that did not have any employees certified under AWS. Baker stated that he believed that Gladstone had been contracted by Kaiser and specifically, the Construction Department, on at least two occasions. He, Baker, believed that the second time Gladstone was l

C C

              < . n ,,                          ,

Rex E. Baker 3 contrected was to come in and review the NR's that were being written by the QC inspectors. Baker added that even though Gittings stated that Gladstone had not been certified to AWS, Marshall used to justify construction' f position by claiming that "our certified level III from Gladstone" supported construction. Following the discussion of pipe hanger inspections and the contracting with Gladstone, Baker stated that he had been interviewed by NRC personnel from Region III (January 1981) concerning allegations of NR's being improperly voided, reassignment of QC inspectors because of pressure from Kaiser construction and charges in QC inspection procedures in general. Baker further stated that he recalled being interviewed for several hours'concerning the allegations,. Subsequent to the interview (possibly the next day). Baker calimed that he was in the presence of Ehas (CG&E) and Marshall (Kaiser Construction Supervisor) when a new list of interviewees had been requested by the NRC investigator. As Baker recalled, Marshall stated after reviewing the list.."how come Baker isn't on the list?" Baker stated that'Ehas repli.ed to Marshall by stating "they don't need him ;;he went'down there yesterday and spilled his guts to'them" (NRC). Baker stated that shortly after this he was told by Gene Knox (Kaiser ( Corporation) that he was being reassigned during a reorganization to the position of NDE Supervisor. Knox explained to Baker that Kaiser was doing this because Baker was the only qualified " Level III." Knox also explained that Kaiser thought there was a conflict in Baker being the Supervisor of the piping inspectors and also the certiifed Level III and most experienced in radiography. Knox also indicated that as lead piping inspectors. the emphasis should be on " helping construction" and not strictly checking constructions work as in the case of radiography. ' Baker stated that he believed the change in assignment was related to talking to the NRC and not the reason portrayed by Knox. Baker continued by stating that at approximately the same period, the President of Kaiser Corporation in Oakland had come to the site and was touring the different areas accompanied by the Construction Supervisor, Bob Marshall. According to Baker, when Marshall and the President arrived at this (Baker's) office, Marshall stated something to the effect "Here's Rex Baker, the source of all my problems." Baker did not recall if there was any response on the part of the Kaiser President. Baker continued by explaining that he had discussions with Region 111 inspector Kavin Ward regarding radiograph problems. He (Baker) stated that in discussions with Ward they agreed there were radiograph technique problems which resulted in the radiographs not meeting ASME ( American Society of Mechanical Engineers) Code Standards. Baker stated that Ward k O

( ( Rex E. Baker 4 was concerned that the radiography being conducted was not done properly and, therefore, was not sufficient to meet the Code requirements. Baker then responded to questions as to whether that was the only difficulty in the radiographs. Baker stated that there was a period during early 1980 when the radiographs reflected more than technique problems. Baker claimed that af ter radiographing welds during the stipulated period it was discovered that many welJs were rejectable. Baker recalled that the figure for rejection was approximately 67 percent. Baker reaffimed that it was actual weld conditions that were identified and not radiograph-techniques. Baker then added that he believed as a result of this radiography, the described welds were " reworked" and subsequently re-radiographed. Baker further stated that many of the welds should not have even been scheduled for radiography.because in his opinion visual inspections would have identified the conditions and the required rework. Baker concluded by stating that as a result of all of the nonconforming conditions identified during the first " walk down" of the Reactor Pressure Vessel (RPV-1) are extensive NR was written combining everything identified by the QC inspectors. This NR was subsequently signed off by Baker. Baker then stated that a second walk down, RPV-2, was initiated at a later date and originally had 10 QC inspectors assigned to work on the walk down af ter normal working hours (overtime). Baker stated that they were assigned to work in " groups of twos" (pairs). During the RPV-2 (- work down, Baker claims that each QC inspector turned in approximately 1-2 pages of discrepancies per night. These items, according to Baker, were listed on punch lists rather than NR's. Baker then stated that af ter they (QC) had completed about 10 days work, the walk down was stopped. The reason that was given to Baker was that there was "no more overtime." Baker could not provide any additional infomation concerning the falsification or a.lteration of QC records. ..

 *                                                                                                                                                              . .W. 9  1 h CE $r

• 4 _a 9 - 99 .

Attachment 23 ag '

                                                                                                                                                                                         ^

THE CINCINNATI GAS & ELECTRIC COMPANY st ~ j CINCINN ATI.OHao 4 5201 S R SYLVIA sewC Esaoptmat as July 21, 1982 I

        . The Honorable Morris Udall Chairman                                                                                                                      -

l House Interior and Insular Affairs - i United States House of Representatives Washington, D.C. Attention: Dr. Henry Myers We appreciate the opportunity to respond to the charges made ' by Mr. David Jones to your committee. Essentially the charges are so vague and general as well as lacking any corroborating facts or documents, as to make them difficult to provide a comprehensive answer. It is also difficult to respond in great detail in that we have not seen a copy of the hearing transcript. For this reas,on we can only respond on the basis of our notes taken at the hearing, and the written statement passed out at the hearing. At the outset it is important to emphasize that contrary to his statement, Mr. Jones was not one of the " top management officials" in the Kaiser Quality Assurance Department. According to Kaiser his job title was Sr. QA Analyst and that position is not part of-management, nor has Mr. Jones ever been a part of Kaiser management. Most of the allegations made before the Sub Committee by Mr. Jones were the subject of a complaint which he filed with the Department of Labor. However, after the Labor Department investi-gation had commenced, Mr. Jones withdrew his complaint against Kaiser. Mr. Jones' next complaint is that his supervisors at Kaiser j did not respond favorably to his complaints. It is clear that no organization can function if each subordinate can insist upon things being done only his way even though his supervisors in the Quality Assurance Group found that the matters had been corrected in accordance with procedures. Mr. Jones' also complained about his failure to qualify as a Kaiser lead auditor. According to Kaiser, a new program for training and certifying lead auditors was initiated and Mr. Jones was not that deemed suitable by Kaiser for such program. His allegation this action was in some way retaliatory is unsubstantiated by any documentation from Mr. Jones.

                                                                                                                               % umumwarmu,

se s . , To: The Honorable Morris Udall July 21, 1982 Page 2 Many of Mr. Jones' cther generalized complaints made at the hearing, such as that related to material from approved vendors, are/or were being reviewed as part of the licensee's document review program and the Nuclear Regulatory Commission is aware of the associated deficiencies. Finally, it should be pointed out that Henry J. Kaiser and CGGE have recently been advised, preliminarly, by the NRC officials that a random interview of approximately fifty CGSE and HJK site QA/QC personnel did not disclose signi,ficant evidence of intimi-dation or harassment of inspection personnel. This finding does not support Mr. Jones' charges regarding harassment and intimidation at the Zimmer Project. We have a copy of the transcript of testimony given by Mr. Jo'nes at a meeting with the Nuclear Regulatory Commission on June 16, 1982. We are in the process of preparing a written response to Chairman Palladino relative to the charges made by Mr. Jones regarding the Zimmer Project. This response will clearly show that Mr. Jones misrepresented the facts and the overall situation at Zimmer. Very truly yours, .

                     .                                                 THE CINCINNATI GAS S ELECTRIC COMPANY By: Jh' B.R. Syl ia, Vice-President Nuclear Operations BRS/dfb                                            .

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August 3, 1982 The Honorable Nunzio Palladino Chairman United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Chairman:

The attached letter from the Cincinnati Gas & Electric Company (CG&E) states that ".... Henry J. Kaiser and CG&E have recently been advised, preliminarily, by the NRC officials that a random interview of approximately fifty CG&E and HJK site QA/QC personnel did not disclose significant evidence of intimidation or harassment of inspection personnel." I have not been informed of any such finding. A finding of this nature would be of considerable interest in view of allegations of harassment made to the Subcommittee. I would appreciate, therefore, your informing me as to the staf f's findings with regard to the question of harassment and intimidation of QA/QC personnel by their supervisors. I would also like to be informed as to what CG&E and HJK of ficials were told with regard to harassment and intimidation and the manner in which these officials were informed. This is a matter I expect to discuss at the August 16 hearing. Y e y, d MORRIS K. UDALL Chairman

fa c a ri,(, httachment 25 6 h# UNITED STATES E' h NUCLEAR REGULATORY COMMISSION W ASHINGTON, D. C. 20555 {s-,y , ,, /.e l S., ,

                         +                                                                                                                       August 10, 1982 Lynne Bernabei, Esq.

Government Accountability Project 1901 Q Street, N.W. Washington, D.C. 20009

    .                                                                                    Re:                                              Applegate v. NRC, Civ. No. 82-1829 (D.C.D.C.)

Dear Ms. Bernabei:

In light of your recent attachment of this document to a motion before the Atomic Safety and Licensing Board in the operating license proceeding for the Wm. H. Zimmer Nuclear Power Station, the Nuclear Regulatory Commission hereby releases for public inspection the record of the Office of Inspector and Auditor's interview of Mr. Terry Harpster. In response to your informal request, we are also releasing that portion of a July 26, 1982 memorandum to the Commissioners from the General Counsel regarding the July 19, 1982 Director's Decision on two petitions concerning LaSalle County Nuclear Generating Station. This portion of an otherwise confidential legal analysis was discussed by the Commission during a July 27, 1982 public meeting on LaSalle. Sincerely, l Richard A. Parrish Attorney Office of the General Counsel

Enclosures:

As stated m- . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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g-:w- a=, 4 p Attachment 26 1 p .

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NRC Official Sayst  : CINCINNATI Zimmer's Startup - .

                                                                                                                                                                                    " July 15, Unlikely For '83 7                                                                                      --

BY JACKIE JADRNAK has been collecting about $18 mii-c nn,%%, I tion annually from its customers for Zimrner and wants to add COLUMBUS-It's unlikely that about another $50 million to that the Zimmer nuclear power plant- amount. , will be able to go into commercial operation anytime next year, an WARNICK W AS unable, how-official with the Nuclear Regula- ever, to give the PUCO a specific tory Commission said Wednesday. date by whtch he expeeted Rdbert F Warnick, director of Zimmer to be in operation. That the enforcement and investiga- date would depend on a number i tion staff for the NRC's Region of inspections and investigations III, said necessary inspections at being conducted at Zimmer, a t the plant wouldn't be finished by plant he termed the " biggest I the end of this year. Cincinnati problem" of the 10 to 15 under Oas & Electric Co., the utility construction in his eight-state re.- managing plant construction and gion. '- operation, had set this December l The NRC also ts considering as the target date for fuelloading, calling for an independent audit with mid-1983 as the start-up date of construction quality. at tit'e for the nuclear power plant. plant. Warnick said a final dect-But asked if he thought it un- ston has not been made.on that

                                              'likely Zimmer would be in com- 1ssue, but pointed out that the
                                             ! mercial operation during 1983, NRC has been requiring th'e Warnick said, "Yes, I agree with third-party audits for every plant that."                                                    that has been !! censed since prob-lems were uncovered at Callf6r-                        '

WARNICE WAS in Columbus nia's Diabolo Canyon plant. ~ ' '

                                             ' to testify before the Public Utill-Problems at Zimmer erupted
                                             , ties Commission of Ohio (PUCO), because CO&E did not keep a j which is considering a $100 mil- large enough staff to check cons
                                             . Ilon rate request from Columbus struction quality, Warnick said.

and Southern Ohio Electric Co, Because many documents needed , owner of a 2tL5%' interest in the to substantiate the qualityof the i nuclear facility. About half of work were missing or inacc. urate, -s l that rate increase is attributable and beeause some work wa 5 ., < l to Zimmer construction costs. found to be inadequate, the NRC ' PUCO Chairman Jon Kelly ordered a new quality confirma-had written to NRC officials, par- tion program. . tla!!y at the request of the Office of Consumers' Counsel, asking IN OTHER words, inspectors i them to send a witness to help had to go back over work already them determine when Zimmer done and confirm that it was would be in operstion. done properly, with any inade- t Kelly said he was concerned quate construction redone. because the start-up date for In making that decision, the Zimmer-first set for 11rl5-has NRC has not been concerned with .: progressively been pushed back the cost of the plant, Warnick. later and later. In the meantime, said."The question 1s:'Has it been, the commission has been allow- built properly and can it be oper-Ing utilities to recover costs for ated safelyT" he said. ' Zimmer on the basis of start-up The NRC has yet to be con- -, ,^ dates which have not been met, vinced that the answer to that C&SOE, for example, already question is "yes," he added. ~. 1 n., Q_ __

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