ML20064E148

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Forwards Ltr to Mccarten Expressing Appreciation for J Keppler Participation in 810226 Meeting Re T Applegate Disclosure Concerning Facility.Meeting Transcript Not Yet Received.W/O Ltr.Related Info Encl
ML20064E148
Person / Time
Site: 05000000, Zimmer
Issue date: 03/15/1981
From: Devine T
GOVERNMENT ACCOUNTABILITY PROJECT
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20064E073 List:
References
FOIA-82-206 NUDOCS 8301050119
Download: ML20064E148 (66)
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Text

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GOVERNMENT ACCOUNTABILITY PROJECT

.. Institute for Policy Studies 1901 Que Street. N.W.. Washington. D.C. 20009 (202)234-9382 March 15, 1981 Mr. James Keppler t Director, Region III

{ United States Nuclear

  • l Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

9 Enclosed is a copy of a letter I am sending today to Mr.

McCarten. This note is to express my appreciation again for the generous amount of time you made available on February 26, 1981 to discuss Mr. Applegate's disclosure. I also appreciated your courtesy in promptly informing me of the " identity crisis" that occurred shortly after the meeting. I explained to Mr.

Applegate that your call was helpful and an exercise of your responsibility, rather than a form of harassment. Mr. Applegate understood and since has reported favorably on his first weekly briefing by NRC investigators.

Additionally, there are several brief issues to discuss.

First, lo have not yet received a transcript for our meeting in Chicago. Mr. Streeter informed me that it would be available in a few days. Could you please check on this item?

On a more general level, I reviewed the Federal Register notice and Region III Manual for " Conduct of Investigations."

After my review, I agree with your observation that the investigative guidelines could be tightened up. I would gladly work with you to develop a set of investigative guidelines designed to prevent

future disputes such.as the criticisms of NRC oversight at Zimmer.

l Our organization has engaged in this type of cooperative project before. We do not accept any compensation from government agencies, but I would need reimbursement for travel expenses if we met in Chicago. If you are interested in this suggestion, please contact me.

Finally, I remain available to assist in interviewing reluctant witnesses or resolving inconsistent versions from Zimmer witnesses who speak both with GAP and the NRC. Your suggestion for this procedure was excellent and will help to guarantee the legi-

, timacy of evidentiary references in the upcoming report, if you follow through on it. I will look forward.to hearing from you.

Sincerely,

. n 12 ,: ...,a' Thomas Devine Associate Director cc: Mr. Thomas Applegate MAR 18 6M 8301050119 e21116 PDR FOIA DEVINE82-206 PDR

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08. CLOSEOUT ACTION 09. M A N- 10. C LOSE- 11. CLCSEOUT D ATE 12. R EQUEST HOURS OUT CODE MoNN Da* vta" ACKNOWLEDGED J. Streeter --

, Please review the attached letter from Mr. Thomas Devine, Government Accountability i

( Project, and provide" draft response to J. G. Keppler by 3/25/81. Thank you.

Jean .

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REGION III DAILY ACTIVITY REPORT - FEBRUARY 26, 1981 A. Visito rs

'; Mr. T. Applegate and his attorney, Mr. Devine, and Messrs. J. Cummings, OIA, and R. Gilbert, IE:HQ, to meet with Mr. James G. Keppler and members of his

staff. (See Significant Meetings) l, B. Significant Meetings i

Mr. James G. Keppler and members of the Region III staf f; Mr. J. Cummings, Of fice of Inspector and Auditor; and Mr. R. Gilbert, IE Headquarters; will meet with Mr. Applegate and his attorney, Mr. Devine, to discuss the Zimmer investigation.

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. , ZIMMER/4-B DRAFT 11/13/81 Ns Cincinnati Gas and Electric Company ATTN: Mr. W. H. Dickhoner

President 139 East 4th Street i Cincinnati, OH 45201 1

Gentlemen:

This refers to the investigation conducted by Regioe. III during the period January 12 to October 9,1981, of construction mivities at the Wm. H. Zimmer Nuclear Power Station. The investigation 5:4s initiated as a result of alle-gations made to the NRC by a Quality Control Inspector who formerly worked at the Zimmer site and by the Government Accountability Project of the Institute for Policy Studies (a non-governmental agency) on behalf of Mr. Thomas Applegate.

The results of the continuing investigation reveal a widespread breakdown of your quality assurance program as evidenced by numerous examples of noncompliance with twelve of the eighteen different criteria for a quality assurance program as set forth in 10 CFR 50, Appendix B. The cause of the breakdown was your failure to exercise adequate oversight and control of your principal contractors to whom you had delegated the work of estab-lishing and executing quality assurance programs. You thereby failed to fulfill your vital responsibility as described in Criterion I of 10 CFR 50, Appendix B, to assure the execution of a quality assurance program.

The potential safety concern of your quality assurance program breakdown was discussed during an enforcement conference at our Region III office in Glen Ellyn, Illinois, on August 5, 1981, attended by you and members of your staff and the NRC Region III staff.

Two of the violations (Items A and B of Appendix A of this letter) are of particular concern to us because of the very essential role they play in the execution of an effective quality assurance program. These two viola-tions relate to false records and to harassment / intimidation of quality control inspectors.

With regard to false records, the examples we identified raise serious questions as to the accuracy of quality records at the site. Our concern in this area served as a major factor in requiring the conduct of a con-firmation program to be completed by you to furnish evidence of plant quality. Because the NRC inspection program is a sampling program, the importance of accurate quality records cannot be overemphasized. Accord-ingly, we have addressed this matter as a separate violation and assessed a separate civil penalty for it.

Withregardtoharassment/intimidationofguality/ontrol/nspectors,we have also addressed this matter as a separate violation and assessed a separate civil penalty for it. We determined that,your construction contractor took some action to stop the water dousing of Quality Control Inspectors; however, those actions did not stop the activity. Harassment /

intimidation of quality control inspectors is clearly a barrier to effective implementation of a quality assurance program and results in loss of the organizational indelendence described in Criterion I of 10 CFR 50, Appendix B. The importance of this matter is reflected in the recent amendment

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'. , ZIMMER/4-B DRAFT 11/13/81 Cincinnati Gas and Electric Company i

(Public Law 96-295, June 30, 1980) to the Atomic Energy Act of 1954, which i

added Section 235 relating to protection of nuclear inspectors such as your .

/'uality/ontrol/'nspectors .

The impact of the identified quality assurance deficiencies on the actual construction has yet to be determined. Limited independent measurements were performed by the NRC in selected areas of concern in an attempt to characterize the actual safety significance of these deficiencies. Al-though a few problems requiring corrective action were identified (i.e. ,

four unacceptably installed pipe hangers), the majority of the NRC inde-pendent measurements did not disclose hardware problems. However, recog-nizing that significant construction deficiencies could have resulted from the quality assurance problems identified during this investigation, the NRC has required the establishment of a comprehensive Quality Confirmation Program to determine the quality of plant systems important to nuclear safety. The NRC will confirm the adequacy of the program and may make additional independent verifications. Deficiencies identified by these programs will require resolution prior to issuance of an Operating License.

Notwithstanding the fact that serious construction deficiencies have not been identified, in order to emphasize the need for licensees to have com-plete and accurate records, to maintain a work atmosphere where quality assurance personnel are not harassed or intimidated, and to assure imple-mentations of an effective quality assurance program which identifies and corrects construction deficiencies, we propose to impose civil penalties in the cumulative amount of Two Hundred Thousand Dollars for the matters in the Notice of Violation. LA .gs W A W Pt t Some of the examples in the Notice of Violation occurred subsequent to the issurance of the revised enforcement policy and some prior to that time.

In arriving at the amount of the proposed civil penalties we have exercised discretion and considered changes in the enforcement policy and considered

, the amount of the civil penalties that have been issued to licensees of other i

plants under construction as well as the number of examples found of each violation and when they occurred. ": 5 11-. '--

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. ^f^ r will result in an adequate deterrent against f uture similar violations v vou and other licensees of plants under construction.I We have for con-venience and clarity categorized the items in the Notice of Violation at the Severity Levels described in accordance with the Interim Enforcement l

Policy published in the Federal Register, 45 FR 66754 (October 7, 1980).

l The results of this investigation and our review o,f your 10 CFR 50, Appendix B, noncompliance history reveal an additional matter which is of significant concern to usfrelated to inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979 with thirteen of the eighteen different criteria 10 CFR 50, of Appendix B. During I

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ZIMMER/4-B DRAFT 11/13/81 Cincinnati Gas and Electric Company i

t cur Systematic Assessment of Licensee Performance review on December 16, 1980, we expressed concern with your relatively poor performance in this area. This poor history of compliance with 10 CFR 50, Appendix B, when considered with the recent findings of the investigation indicates that your corrective actions only addressed individual problems and not under-lying programmatic causal factors. Consequently, we request that you review your history of noncompliance with 10 CFR 50, Appendix B, for the i past two years and in your response to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors related to the noncompliances.

You are required to respond to the Notice of Violation and in preparing your response you should follow the instructions in Appendix A. You should give particular attention to those actions designed to assure continuing compliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce-ment action is appropriate.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the en-closure will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Appendix A are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Richard C. DeYoung, Director Office of Inspection and Enforcement

Enclosures:

Appendix A, Notice of Violation and P.roposed Imposition ofCivilPenalt/"andAppendixB, Cross

References:

Noncompliances to Report Details cc w/ encl:

l E. A. Borgmann, Senior Vice President, Engineering Services ,

and Electric Production J. R. Schott, Plant l Superintendent j DMB/ Document Control Desk (RIDS) l t

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ZIMMER/4-L' DRAFT 11/13/81 '

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' i i Cincinnati Gas and Electric i Company 4 ti i )

4 Resident Inspector, RIII -

Harold W. Kohn, Power Siting Commission Citizens Against a Radioactive Environment i

Helen W. Evans, State of Ohio 3 i

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l Appendix A i NOTICE OF VIOLATION f

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t j PROPOSED IMPOSITION OF CIVIL PENALTIES I

. Cincinnati Gas and Electric Company Docket No. 50-358 .

l Wm. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 EA No. 82-12 1

I As a result of the investigation conducted at the W' .sH. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - October 9, 1981, the vio-lations listed below with multiple examples were identified. The numerous examples of the violations demonstrate your failure to exercise adequate oversight and control of your principal contractors, to whom you had delegated the work of establishing and executing quality assurance programs, and thereby fulfill your responsibility of assuring the effective execution of a quality assurance program. Your failure manifested itself in a wide-spread breakdown in the implementation of your quality assurance program and caused the NRC to require an extensive quality confirmation program to provide confidence that safety-related structures, systems, and compon-ents will perform satisfactorily in service. Included in the breakdown were findings we consider to be particularly disturbing relating to false records and harassment and intimidation of quality control inspectors.

Because of the significance of not having complete and accurate records, not maintaining a work atmosphere where quality assurance personnel are not harassed or intimidated, and not assuring implementation of an effec-tive quality assurance program which identifies and corrects construction deficienciesZ(inaccordancewiththeInterimEnforcementPolicy,45FR66754 (October 7, 1980), the Nuclear Regulatory Commission propoces to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, and 10 CFR 2.205 in the amounts set forth for the violations listed below.

A. 10 CFR 30, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality."

Contrary to the above, records were identifie,d that did not furnish evidence of activities affecting quality in that they were false.

Eximples of false records are as follows:

.A % M r 7 other %

1. Isometric drawingsnor records did not furnish evidence of theactualpiping?seponentsinstalledintheh{pipelinesin 6  %

ZIMM/1C DRAFT 11/13/81 Appendix A oc 4 'g , M j the diesel generator cooling water, starting air and fuel oil j systems, in that the heat numbers recorded on the drawings id i

notmatchtheheatnumbers4markedontherespectivecomponents.

The pipelines were: ,4

. IDG28AB1 1DGC5AA3/4 ADGl%AA'&

IDG27AB1 1DGF6AA1/2 1DG01AB1 1DGC5BA3/4 1DGF2AA1/2 IDGF6BA1/2 1DG28AE1 1DG25AC2

2. The Kaiser Nonconformance Reporting Log did not reflect all reports initiated as evidenced by the following:
a. The original entry for a report (CN-4309) initiated by a g J' QCInspecg,r,gnJanuary7,1981,relatingtodeficientweld 4 ,y fit-up wase .....x:::? by " It .. i' S record of this report in theM M&ndsystem.there was no other /

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b. The original entry for a report (CN-5412) initiated by a g QC Inspector on February 3,1981, and relating to violation \

of a hold tag waT [iT E ::: 3 by ".itin; atpad there was -

C no other record of this report in the NR system. ,

c. A report (NRC-0001) initiated by a QC Inspector on Februarf 11, 1981, relating to excessive weld weave was not assigned a number and there was no other record of this report in the NR system.
3. Written statements as to planned actions which were made to justify voiding reports E-1661 (voided 11/11/80), E-1662 (voided 11/11/80),

and E-2466 (voided 6/30/80) were not taken.

4. Written statements relating to the availability of records which were made to justify voiding reports E-1777 3 and E-510gere false.
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S. Repor g,,Cg476, CN-5477, and CN-5479 were knowingly crnaccurlye s nA voide rand copies deleted from the NR system at the direction of the Kaiser QA Manager.

This is a Severity Level III violation (Supplement II).

, (Civil Penalty - $50,000) ,

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ZIMM/IC DRAFT 11/13/81 Appendix A i i

I B. 10 CFR 50, Appendix B, Criterien I states, in part, "The persons...

performing quality assurance functions shall have sufficient...organi-zational freedom to identify quality problems... including sufficient independence from cost and schedule."

The Wm. H. Zimmer QA Manual, Section 1.2.3 describes QC Inspectors as members of QAD (Quality Assurance Division) and Section 1.2.4 states, in part, "QAD has been assigned sufficient... organizational

! freedom to identify quality problems..."

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! Contrary to the above, QC Inspectors did not have sufficient freedom

! to identify quality problems and were not sufficiently independent from cost and schedule. The results of interviews indicate that some l QC Inspectors were: (a) harassed by construction workers and superv-isors; (b) not always supported by QC management; and (c) intimidated.

The following are examples of insufficient freedom of QC Inspectors, including insufficient freedom from cost and schedule, which occurred between41978 and March 11, 1981:

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1. Five QC Inspectors interviewed executed signed sworn statements ~

wherein they claimed they were doused with water (while engaged in the performance of inspection duties) by construction personnel.

Two other QC Inspectors made similar statements.

2. A QC Inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were re-assigned by QC management because of complaints by construction personnel.
3. Two QC Inspectors executed signed sworn statements wherein they claimed they had been harassed by being searched for alcohol by security personnel at the request of construction supervisory personnel. One other QC Inspector made a similar statement.

l 4. A QC Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after con-t struction personnel complained he had used a magnifying glass

! to visually inspect a weld when in fact he was using a mirror l and either device was an acceptable tool.

l l S. A QC Inspector executed a signed sworn statement wherein he claimed he was struck by a stream of water from a fire extin-l guisher while performing an inspection.

l 6. A QC Inspector executed a signed sworn s'tatement wherein he l claimed he was threatened with bodily harm by a construction person if he did not pass a weld.

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ZIMM/1C DRAFT 11/13/81 Appendix A 7. A Lead QC Inspector executed a signed sworn statement wherein he claimed:

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a. he was accused by the QA Manager for holding up a concrete pour when in fact the delay was caused by the concrete I trucks'being late.
b. construction management frequently approached QC Inspectors and challenged their inspection findings and questioned their j judgement.
c. the QA Manager said things like "our job here is to accept, not reject, and we are here to get this plant built."
8. A Lead QC Inspector executed a signed sworn statement wherein he claimed he was relieved of his inspection duties because he con-tinued to submit legitimate nonconformance reports over construc-tion management objections for deficient welds on pipe support hangers. He also stated that QA management had previously told QC Inspectors to not write anything to make Kaiser look bad.
9. A QC Inspector executed a signed sworn statement wherein he claimed he was told by QA management to accept inspected items that were unacceptable.

This is a Severity Level III violation (Supplement II).

(Civil Penalty - $50,000)

C. 10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear powerplants to document, by written policies, pro-cedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents.

Contrary to the above, Cincinnati Gas and Electric Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as evidenced by the following examples:

1. 10 CFR 50, Appendix B, Criterion XV states, in part, "Noncon-forming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documente,d procedures."

Kaiser Procedure QACMI G-4, " Nonconforming Material Control,"

provides detailed instructions for the review and disposition of reports (Nonconformance Reports) of nonconforming items.

ZIMM/1C DRAFT 11/13/81

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Contrary to the provisions of QACMI G-4, the sample of NRs reviewed indicate significant deficiencies with the nonconformance reporting system in the areas of voiding of reports, not entering j reports into the system, improper dispositioning of reports, and l t incomplete report files. The deficiencies identified were as l follows:

a. Feve4NRs related to documentation deficiencies had been improperly voided in thai ^e
. _ - - % ...- .>M-i riz L. J. . . .2% (Z 1777 . .dd '/20/70, NR-E-2191 voided 2/22/80, NR-E-2233 voided 1/24/80, NR-E-2237 voided 12/19/79 f". '  ::C: m L C/20/*^)

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b. One NR reiated'to' nonde'structive examination of a T-quencher weld had been erroneously closed (not voided) by adminis-m trative error. (NR-E-2996 closed 3/17/81) r d 5r. kewe reports had been voided by personnel other than the QA Manager. (CN-5122 voided 1/2/81, CN-5476 voided 2/27/81, CN-5477 voided 2/27/81, CN-5479 voided 2/27/81

, c u- *iett o M wad) 4/. In one case during revisions of the report some nonconformidg items were removed from a NR without adequate justification.

(NR-E-2466 voided 6/30/80) fyt. The following nine reports had not been issued NR numbers and/or copies of the reports had not been retained in the Site Document Center:

CN-4389 CN-4957 CN-4930 CN-4958 CN-4931 CN-4959 CN-4955 CN-5122 CN-4956

2. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations... and nonconformance are promptly identified and corrected."

The Wm. H. Zimmer QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformances in receiving inspection, construction, or testing activities which are delegated to HJK Quality Assurance P,rocedures to assure that nonconforming items are conspicuously marked to prevent their inadvertent use or installation."

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ZIMM/IC DRAFT 11/13/81 Appendix A .

AWS Code DI.1-1972, Section 3 and 8.1.5 define requirements for weld quality and address slag, weld profiles, blowholes, porosity, and undercut.

1 AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch minimum radius for re-entrant corners.

{; Contrary to the above, the following nonconforming conditions were not identified and corrected:

a. Based on an inspection of the 25 structural hanger support beams described in Item C.4 below, (1) jieveral welds on nine beams did not conform with AWS.N d (D1.1-197) requirements in that they contained unaccept-able slag, weld profiles, blowholes, porosity, and/or undercut.

(2) Five beams did not conform with AISC requirements in that the re-entrant corners were notched, creating potential stress risers, instead of being rounded with required radii.

(3) Four beams, two of which had unacceptable welds as described in Item C.2.a.(1) above, did not conform with design documents in that they were not specified on any design document,

b. Based on an inspection of about 100 cable tray hangers in e the Cable Spreading Room, four did not conform with AWSag D CDI.1-1972) requireme'iits in that EeTefds containW~una'ccept-able slag, weld profiles, blowholes, porosity, and/or undercut.
3. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as. . . deviations. . .and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition l is determined and corrective action taken to preclude repetition."

The Wm. H. Zimmer QA Manual, Section 16.5 states, in part,

" Vendors, contractors, and subcontractors are required to determine cause and corrective action to prevent recurrence of errors which could result in significant conditions a,dverse to quality."

ff ASME Code, Section III-1971 Edition, Article NB-3661.5(b) states, in part, "...a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before welding."

ZIMM/1C DRAFT 11/13/81 Appendix A  !

ASME Code, Section III-1971 Edition , Winter 1972 Addenda,

Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, l NA-4451, NB-4230, and NB-3661.5(b) require, in part, in-process 4 inspections for pipe fitup, weld procedure, weld filler metal

{ traceability, and welder qualifications...

f I Contrary to the above, the NRC inspectors identified the following l' nonconforming conditions that had not been corrected and action had not been taken to preclude their repetition:

a. Licensee records indicate that the socket engagement (fitup) for more than 439 socket welds was not verified in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b) and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1979.
b. Licensee records indicate that the in process inspections for more than 22 welds in the Diesel Generator cooling water, starting air, and fuel oil piping systems were not performed by Kaiser in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b), et. al., and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1978.
c. Five licensee QA audits (audit performed 8/8-9/74 - no number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of Sargent & Lundy identified repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications and action was not taken to preclude repetition.
4. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of l materials... These measures shall assure that identification of

! the item is maintained..."

i l The Wm. H. Zimmer QA Manual, Section 8.2 states, in part, l "H. J. Kaiser Company procedures provide that within the l H. J. Kaiser Company jurisdiction the identification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other appropriate means. This identification may be on th.e item or on records traceable to the item. The identification is maintained through-out fabrication, erection, and installation. The identification is maintained and usable in the operation and maintenance program."

ZIMM/1C DRAFT 11/13/81 Appendix A Contrary to the above, based on an inspection by NRC inspectors in March 1981 of approximately 25 structural hanger support beams located in the Blue Switchgear Room and the Cable Spreading Room, the identification of the material in nine of those beams was not l maintained to enable verification of quality.

I

5. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory require-ments and the design basis...are translated into... drawings..."

The Wm. H. Zimmer FSAR, Section 8, provides the design basis for electrical cable separation that includes the following:

Associated cables (Green / White, Blue / White, and Yellow / White) from more than one Division cannot be routed in the same raceway. (FSAR Paragraph 8.3.1.13.2)

Vertical separation of three feet or more must be maintained between cables from different Divisions. (FSAR Paragraph 8.3.1.11.2.1.d)

Instrument (low-level signal) cables cannot be routed in the same raceway with power and control cables. (FSAR Paragraph 8.3.1.12.1.3)

The Wm. H. Zimmer QA Manual, Section 3.3.2. states, " Composite...

drawings are prepared, translating the design concepts into layouts of structures, systems, and components necessary for the construction of the plant."

Contrary to the above, as of March 1981, the FSAR design basis for electrical cable separation had not been translated into drawings and this resulted in the following cable installation deficiencies in the Cable Spreading Room:

l

a. Associated Cable (Yellow / White) No. RE053 for Division 1

( was routed in the same raceway (two-inch conduit and Class IE l Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for l Division 2. Also, Associated Cable No. RE053 was routed so that in places there was only a vertical separation of four

, inches between it and cables in Blue Tray No. 2072C for l Division 2.

t

b. Instrument Cable (Green) No. WS714 .and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Asso-ciated Control Cables (Yellow / White and Blue / White) for Divisions 1 and 2. This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3029K) inside a White Control Tray (No. 4638B).

l ZIMM/1C DRAFT 11/13/81 )

Appendix A -

9-

c. Many Associated Cables from all three Divisions were routed in the same raceway (White Tray No. 4080K) including Cable (Blue / White) No. TI192, Cable (Yellow / White) No. RR781, and Cable (Green / White) No. TI816.
d. Associated Cables (Yellow / White) No. TI942 and No. TI943 for l Division 1 were routed in the same raceway (White Tray Riser No. RK4627) as Associated Cables (Blue / White) No. TI808 and No. TI760 for Division 2.

l

e. Many Associated Cables (Yellow / White) for Division 1 were routed in the same raceway (White Tray Riser No. 4139) as Associated Cables (Blue / White) for Division 2.
6. 10 CFR 50, Appendix B, Criterion III states, in part, " Design control measures shall be applied to...the delineation of acceptance criteria for inspections and tests."

The Wm. H. Zimmer QA Manual, Section 3.13.1 states, in part,

" Design control measures also apply to delineation of acceptable criteria for inspections and tests."

Weld acceptance criteria are required by the ASME Code, Section III-1971 Edition and AWS DI.1-1972 Code.

Contrary to the above:

a. The weld acceptance criteria used by H. J. Kaiser Company from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were deleted.
b. The acceptance criteria for Weld SSH (isometric drawing PSK-1WS-32) performed on Service Water System Line No.

1WS17A18 by H. J. Kaiser Company in November 1979 were not applied in that they were designated as not applicable.

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7. 10 CFR 50, Appendix B, Criterion XI states, in part, "Tm.- y.---

.m; '.11 includ; y. .. . .._ f. .:_ ' ; *'-* 1' 7-^ ^;

'-#+--

m 13 ; _ ;; _; m n -- wmm- .

._ " Test results shall be

, evaluated to assure that test requirements have been satisfied."

The Wm. H. Zimmer QA Manual, Section 11.1 states, in part, " Test l

programs to assure that essential components, systems, and struc-tures will perform satisfactorily in service are planned and i

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, ZIMM/1C DRAFT 11/13/81 Appendix A ,

performed in accordance with written procedures and instructions i at vendor shops and at the construction site."

M. W. Kellogg Co. (pipe manufacturer and agency performing the prefabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, statesc "Wherever required, shims shall be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal plus the height of the crown or l reinforcement."

f i

ASHI Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, l

Paragraph IX-3334.4 states, in part, "The shim thickness shall be Iselected so that the total thickness being radiographed under the l

penetrameter is the same as the total weld thickness..."

6 C t i J, 1: th: Ch:J , th; "EC in:p: '^r -^"#^'^A

' p p " ^ " # - ' * ^ ' 'f 00 ::li:; :;5- i;;;l;i;; 20C ;12. ,__2 lm m .m. l ;L_; 107 E

, r 'ir; :ph: did ::t :::;1; ith 'he 'c"r Ord in *'-* +'---

p- ":: '- 2ffici::t :hi;;ing af the y:nct....ct .. Th; . dl... yh. i

12: .. : r: p::f;hri e:ted pip: .::I d: in :::h cy te : :: fer!":'er,

>#^

21 ;:::::t r ::pp::t :p:t:rr, -> - r*^--

8. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design control] shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled...The design control measures shall provide for verifying or checking the adequacy of design."

The Wm. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are specified and included in design documents."

The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled."

The W m . H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verification reviews are performed...."

The Wm. H. Zimmer FSAR Section 8.3.3.1.1 states that cable ampacity is based on IPCEA Publication No. P-46-426. An additional limita-

a._ -- -... a 4. cae+4aa R.3.3.1.3 is that "the f

- ZIMM/IC DRAFT 11/13/81 Appendix A AWS D1.1-1972 Code, Section 3.6.4, states, "For building and

. tubular structures, undercut shall be no more than 0.01 inch deep when its direction is transverse to primary tensile stress

, in the part that is undercut, nor more than 1/32 inch for all other situations."

f Contrary to the above:

I a. As of March 1981, design control measures had not been i established to assure that deviations from design conditions l (quality standards) identified by Sargent & Lundy engineers

were controlled. For example, Sargent & Lundy noted on a calculation sheet dated December 27, 1979, that the design thermal loading for two power cables (VC016 and VC073) in 4

Yellow Tray No. 1057A would allow the cables to be thermally overloaded and no program existed to control those design deviations.

t

b. As of March 1981, design control measures had not been established by Sargent & Lundy to provide for verifying or checking the adequacy of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays.
c. As of March 1981, the cable ampacity design by Sargent &

Lundy was not based on IPCEA P-46-426 and the FSAR limit on cross'-sectional area.

d. As of March 1981, the design allowable undercut on cable tray hanger welds was not based on AWS D1.1-1972 Code (appro-priate quality standard). The design undercut wac instead based on Sargent & Lundy Specification H-2713, Supplement 7, Sargent & Lundy Standard EB-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph 5.2.9, allowed up to 1/16 inch undercut.

i

, 9. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be estab-lished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

The Wm. H. Zimmer QA Manual, Section 10.1.2 states, in part,

" Inspections are performed in accordance with written procedures which include requirements for check lists and other appropriate documentation of the inspections and tests performed."

ZIMM/lc DRAFT 11/13/81 Appendix A AWS D1.1-1972 Code, Section 3.10.1, requires work to be completed and accepted before painting.

Contrary to the above:

a. As of March 1981, a QC inspection program had not been estab-lished to require verification of separation of electrical cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RIl03 and CM111 that had been routed into Tray Riser (Green)

I No. 3025A, which extended from Tray (Blue) No. 2077A in the Cable Spreading Room to the Control Room.

b. The programs established for in-process and final inspections of welds on 180 cable tray hangers located in the Cable Spreading Room were not executed as required in the AWS i D1.1-1972 Code. Specifically, the final weld inspections were made after the welds were painted (Galvanox).
10. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

The Wm. H. Zimmer QA Manual, Section 5.1 states, " Construction, fabrication, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures, and drawings which prescribe acceptable methods of carrying out those activities."

The W m . H. Zimmer QA Manual, Section 3.12 states, in part, " Design changes... including field changes, are subject to design change control measures commensurate with those applied to the original

design."

l Contrary to the above:

l

a. Kaiser Procedure QACMI G-14, " Surveillance Reports," was not appropriate to the circumstances in that it allowed in process nonconformances which constitute field changes to be dispositioned within 30 days without being subjected to design control measures commensurate with those applied to the original design. Examples of nonconformances so dispositioned were identified in SRs F-2899, F-2903, and F-2914.

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, , ZIMM/1C DRAFT 11/13/81 I

Appendix A ,

, b. Kaiser Procedure QACMI G-14 was not followed in that SRs F-2909, F-3070, F-3071, F-3072, F-3073, F-3074, F-3075,

,' F-3076, F-3083, and F-7019 were not dispositioned within

, 30 days and were not transferred to Nonconformance Reports j

as required by Paragraph 5 of QACMI G-14.

1 I

i 11. 10 CFR 50, Appendix B, Criterion VII states, in part, "The i

effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee...."

-1 ui The Wm. H. Zimmer QA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process, S&L makes an independent 1' evaluation of the bidders' QA programs as a part of their total bid evaluation."

.- Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness i

of the control of quality by vendors who had supplied structural beams. Specifically, evaluations of the vendor (U.S. Steel Supply, PBI Steel Exchange, and Frank Adams Company) quality assurance programs for control of mill certifications and

, structural beams were not performed.

, 12. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient

! records shall be maintained to furnish evidence of activities affecting quality. The records shall include... monitoring of work performance, and. . . include closely-related data such as qualifications of personnel, procedures, and equipment."

The W s . H. Zimmer QA Manual, Section 17.1.4 states, in part,

" Documentation of all performance surveillance includes personnel i

' identification and qualification, procedure, type observation, date of performance, person or organization monitored, results

, and corrective action if required."

! i Contrary to the above, the Bristol Steel and Iron Works Quality i _! Control Steel Erection Report, which was a generic form for monitoring in-process steel erection, did not identify closely i

related data such as weld procedure numbers, types of welding material, welder identification, and specific welds inspected.

13. 10 CFR 50, Appendix B, Criterion XVIII states, in part, "A com-prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."

The Wm. H. Zimmer QA Manual, Section 18.1 states, in part, "QA Division conducts a comprehensive system of planned and periodic audits of S&L, HJK...to verify compliance with all aspects of

, the quality assurance program."

i i

. ZIMM/IC DRAFT 11/13/81 Appendix A Contrary to the above, during the past 9 years the licensee's QA Division did not perform an audit of the Sargent & Lundy nonconformance program.

This is a Severity Level II violation (Supplement II).

(Civil Penalty - $100,000) 3 Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric Company is hereby required to submit to this office within 30 days of the l date of this Notice a written statement or explanation, including for each alleged violation: (1) tdmission or denial; (2) the reasons for the vio-lation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Any statement or explanation may incorporate by specific reference (e.g.,

giving page and paragraph numbers) the provisions of your Quality Confirma-

' tion Program and your actions in response to our Immediate Action Letter of April 8, 1981. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Cincinnati Gas and Electric Company may pay the civil penalties in the cumulative amount of.Two Hundred Thousand Dollars or may protest imposition of the civil penalties in whole or in part by a written answer. Should Cincinnati Gas and Electric Company fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above. Should Cincinnati Gas and Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in

this Notice; or (4) show other reasons why the penalty should not be im-l posed. In addition to protesting the civil penalties in whole or in part,

! such answer may request remission or mitigation of the penalties. Any

answer in accordance with 10 CFR 2.205 should be set forth separately frora l the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. Cincinnati Gas and Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

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- ZIMM/1C DRAFT 11/13/81 i

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i Appendix A '

4

FOR THE NUCLEAR REGULATORY COMMISSION 1

i Richard C. DeYoung, Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of , 1981 i.

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-- - r--, y

COMMISSION BRIEFING ZIMER INVESTIGATION .

1, DISCUSS INVESTIGATION AND FINDINGS 2i DISCUSS PROPOSED ENFORCEENT ACTION ,

3. DISCUSS PLANS FOR RELEASING REPORT 11 , DISCUSS FUTURE ACTIONS .

8

&-, . . %-.., y...- . . + . .- -e

CHRON0 LOGY FEBRUARY 28, 1980 INITIALAPPLEGATEALLEGATIONSRECEIVED JULY 2, 1980 INVESTIGATION REPORT ISSUED NOVEMBER 18,1980- ALEGATIONS FROM EX-ZIMER ETLOYEE RECEIVED DECEMBER 9,1980 ALLEGERCONTACTED ,

JANUARY 5, 1981 ALLEGATIONS FROM GAP /APPLEGATE AND REQUEST FROM GAP FOR MSPB TO INVESTIGATE NRC RECEIVED JANUARY 12,1981 ONSITE INVESTIGATION INITIATED

. APRIL 8,1981 Ift1EDIATE ACTION LETTER ISSUED AUGUST 21,1981 LICENSEE QCP FORMALLY SUBMITTED AUGUST 24,1981 NRC INDEPENDENT VERIFICATION PROGRAM INITIATED e

O

PROBLEMS IDENTIFIED FROM GAP /APPLEGATE INADEQUATE RADIOGRAPHY OF PREFABRICATED PIPE WELDS INADEQUATE INSPECTION OF CABLE TRAY HANGER WELDS UNACCEPTABLE CABLE TRAY HANGER WELDS INADEQUATE A/E DESIGN CONTROLS CR)

FROM EX-EMPLOYEE INADEQUATE TRACEABILITY OF PIPE (R)

IMPROPER VOIDING OF NRs (R)

UNDESIRABLE INTERFACE BETWEEN CONSTRUCTION AND QA QUESTIONABLE QUALITY OF SMALL BORE PIPE WELDS FROM PAST AND CURRENT SITE INSPECTORS HARASSMENT OF QC INSPECTORS IMPROPERLY DELETED WELD INSPECTION CRITERIA (R) ,

IMPROPER USE OF SURVEILLANCE REPORTS (R)

FROM NRC INSPECTORS -

UNACCEPTABLE WELDS ON NINE HANGER BEAMS l .

UNACCEPTABLE (NOTCHED) RE-ENTRANT CORNERS ON FIVE H UNSPECIFIED HANGER BEAMS (FOUR) INSTALLED TRACEABILITY OF NINE HANGER BEAMS NOT MAINTAINED (R i x .

VIOLATION OF CABLE SEPARATION CRITERIA AT.FOUR LOCA  !

INADEQUATE CGaE AUDITS OF SARGENT & LUNDY i 1

i e

IPfEDIATE ACTION LETTER PURPOSE:

., CONTROLONG0lNGANDFUTUREWORK MAJOR LICENSEE ACTIONS:

, CHANGED KEY MANAGEENT i

, 1NCREASEDSIZEANDTECHNICALEXPERTISEOFLICENSEEQASThFF(6TO135) 100% DUPLICATION OF CONTRACTOR QC INSPECTIONS FULL CONTROL OF RECORDS BY LICENSEE NRC FOLLOWUP FINDINGS:

,f00ALITYOFONG0INGW0liKISACCEPTABLE

. LICENSEE COMMITENTS BEING MET i

QUALITY CONFIRMATION PROGRAM

  • PURPOSE DETERMINE THE QUALITY OF PAST CONSTRUCTION BY CONFIRMING:

. QUALITY OF PIPE MATERIAL

. PROPERDISPOSITIONOFNONCONFORNINGITEMS

. QUALITY OF PIPE WELDS l

QUALITYOFSTRUCTURALSTEELMATERIALANDWELDS

. ADEQUACYOFELECTRICALCABLESEPARATION ADEQUACYOFA/EELECTRICALDESIGNCONTROLS

. ADEQUACY OF CONTROL OF DESIGN CHANGES

. ADEQUACY OF SUBCONTRACTOR QA PROGRAMS

. ADEQUACY OF PAST AUDITS THIS PROGRAM WILL BE EXPANDED SHOULD THE LICENSEE IDENTIFY SIGNIFICANT PROB DURING CONDUCT OF THE QCP OR SHOULD THE NRC IDENTIFY PROBLEMS IN THE RE INVESTIGATION AND INSPECTION EFFORTS.

.l.

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flRC INDEPENDENT VERIFICATION PURPOSE: .

PROVIDE CONFIDEhCE Iti PLANT QUALITY PROVIDE PERSPECTIVE OF GA BREAKDOWN f

VERIFICATI0ilS PERFOR.'iED

f .

INSPECTED HARDWARE RELATED TO 24 VOIDED NRs PERFORiED METALLURGICAL ANALYSES OF SIX WELDS PERFOR:1ED METALLURGICAL ANALYSES OF SIX PIPES PERFORMED LABORATORY ANALYSES OF TWO MISMATCHED WELD

_~

TESTED 70 PIPE WELDS FOR HARDNESS AND THICKNESS VISUALLY EXAMINED E9 PIPE WELDS

. RADIOGRAPHED 60 PIPE WELDS DYE PENETRANT TESTED 42 PIPE WELDS ULTRASONICALLY EXAMINED 21 PIPE WELDS TESTED 53 BEAMS FOR HARDNESS A!!D FITUP VISUALLY II:SPECTED 380 BEAM WELDS INSPECTED ADDITIONAL AREAS FOR CABLE SEPARATION l NRC FINDINGS:

10 CASES OF WELD DEFECTS AND DIMENSIONAL PROBLEMS 4 HANGERS UilACCEPTABLY INSTALLED 4 CABLE SEPARATION PROBLEliS POSSIBLE PROBLE!1 WITH '.iELDS OF .'11SMATCHED PIPE PRELIMINARY CONCLUSION: -

NO WIDESPREAD CONSTRUCTI0ti PROBLEMS i

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FUTURE' ACTIONS .

COMPLETE INVESTIGATION

' EVALUATE RESULTS OF LICENSEE'S QUALITY l CONFIRMATION PROGRAM EVALUATE NEED FOR MORE NRC INDEPENDENT l

l MEASUREMENTS i

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e

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a* '.

i

SUMMARY

OF NONCOMPLIANCES A. MISREPRESENTATIVE RECORDS B. IMPROPER PROCESSING 0F NONCONFORMANCE REPORTS C. FAILURE TO CONTROL NONCONFORMING CONDITIONS D. FAILURE TO CORRECT CONTROLLED NONCONFORMING CONDITIONS E. LACK 0F TRACEABILITY OF MATERIALS F. IMPROPER ROUTING 0F ELECTRICAL CABLES G. LACK 0F WELD INSPECTION ACCEPTANCE CRITERIA H. IMPROPER RADIOGRAPHY TECHNIQUES I. LACK OF ARCHITECT - ENGINEER DESIGN CONTROL MEASURES J. LACK 0F INSPECTION PROGRAMS ,

K. LACK OF AND FAILURE TO FOLLOW PROCEDURES L. FAILURE TO ASSESS EFFECTIVENESS OF VENDOR QA PROGRAMS

, M. INADEQUATE SURVEILLANCE RECORDS N. FAILURE TO AUDIT ARCHITECT - ENGINEER NONCONFORMANCE PROGRAM

0. INSPECTOR HARASSMENT 4

_ _. = _ , -- .- _- . ..

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'l REGIONAL EFFORT INDIVIDUALS INTERVIEWED 90 MANDAYS ONSITE -

265 EVALUATION / DOCUMENTATION MANDAYS 600 i

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d d

I.

IMPACT ON LICENSEE SCHEDULE l

NRC ESTIMATE -- SIX MONTHS DELAY COST TO LICENSEE LOSS OF PRODUCTIVITY -- $2M PER MONTH INCREASED QA PERSONNEL -- $1M PER MONTH INTEREST FROM DELAY -- $12M PER MONTH i

EX-ZIMMER EMPLOYEE ALLEGATIONS

1. KAISER QC MANAGER VOIDING NONCONFORMANCE REPORTS WITHOUT JUSTIFICATION.
2. BOLT HOLES FOR LARGE BORE PIPE SUPPORT HANGERS BEING MADE BY BURNING RATHER THAN DRILLING.
3. TWO DOCUMENT REVIEWERS RECORDING DISCREPANCIES ON EXCEPTION LIST RATHER THAN NONCONFORMANCE REPORT. THEY ARE CATCHING FLACK FOR IDENTIFYING DISCREPANCIES IN DOCUMENTATION.
4. KAISER THREATENED TO FIRE QC INSPECTOR FOR REFUSING TO ACCEPT A WELD. -

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APPLEGATE/ GAP ALLEGATIONS

1. MAIN STEAM RELIEF PIPING REPLACED - COSTING $320,000
2. 2000 LB. FITTINGS USED IN PLACE OF 5000 LB FITTINGS
3. RADI0 ACTIVE WASTE DRAIN CLOGGED WITH CONCRETE
4. VALVE BROKEN WHEN BUMPED BY PIPEFITTER
5. WELD R0D CONTROL (TEMPERATURE AND ACCOUNTABILITY)
6. CRAFTS OVERCOME BY ARGON GAS
7. DEFECTIVE WELDS IN PIPE THAT WAS DROPPED FROM TRUCK
8. 20% OF THE PREFABRICATED WELDS ARE BAD
9. PIPING INSTALLED THEN DESIGNED
10. CABLE TRAYS (FAULTY HANGER WELDS ARE DANGEROUSLY FULL)
11. RIVER INTAKE PUMPS FAIL BECAUSE OF PLANT DESIGN 12, 300 PSIG PIPES OVERPRESSURIZED WITH 1200 PSIG
13. FUELSECURITY(N0SURVEILLANCECAMEk!$ANDCHICKENWIRE FENCE)
14. DRINKING, DRUGS, AND VIOLENCE
15. EMPLOYEES FIRED FOR TIME-CHEATING AND CRITICIZING QA
16. CGaE CONSISTENT APPROVAL OF WELDS REJECTED BY PM. PM REPRIMANDED FOR CRITICIZING l
17. PIPEFITTERS AND PM INTIMIDATED
18. DETAILED JOURNAL OF SAFETY HAZARDS
19. PIPEFITTERS "J0KE" TO BE FAR AWAY WHEN PLANT STARTS UP l

1

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4.1 -

s x.,

s f y ALLEGATION: NONCONFORMANCE REPORTS (NRs) IMPROPERLY '

VOIDED t

FINDINGS: NRs WERE IMPROPERLY VOIDED 24 VOIDED NRs EXAMINED BY NRC NINE IMPROPERLY VOIDED g

INDEPENDENT MEASUREMENTS:

s FIELD REVIEWED COMPONENTS / SYSTEMS COVERED

^

BY 24 NRs .

FOUR PIPE HANGERS UNACCEPTABLY INSTALLED

^

LICENSEE ACTIONS: -

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Rhg toiG-REVIEW ALL VOIDED NRs ~15c o*ste =

REVIEW DISPOSITION OF 300 ADDITIONAL NRs

~.

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ALLEGATION: HANGER BOLT HOLES BURNED AND NOT INSPECTED FINDINGS: BOLTS WERE BURNED AND REAMED -- EVALUATING ACCEPTABILITY H0LE INSPECTION ACCEPTABLY PERFORMED

. x INDEPENDENT MEASUREMENTS

NONE

~

LICENSEE ACTIONS:

NONE

.3, 4

ALLEGATION: DOCUMENTATION DISCREPANCIES RECORDED ON EXCEPTION LISTS, (NOT NRs) AND ENGINEERS CRITICIZED FOR IDENTIFYING DISCREPANCIES FINDINGS: DOCUMENTATION ON EXCEPTION LISTS WAS ACCEPTABLE NO EVIDENCE INDICATED ENGINEERS WERE CRITICIZED OTHER FIllDIliGS MADE WHILE PURSUING THIS ALLEGATION:

DISCREPANCIES IN SMALL BORE PIPE TRACEABILITY RECORDS IN-PROCESS INSPECTION RECORDS IMPROPERLY MODIFIED PIPE SOCKET ENGAGEMENT NOT VERIFIED IN-PROCESS PIPE WELD INSPECTIONS NOT PERFORMED INDEPENDENT MEASUREMENTS:

i SEVEN SOCKET WELDS RADIOGRAPHED -- ENGAGEMENTS ACCEPTABLE i

SIX PIPE SECTIONS ANALYZED -- PIPES ACCEPTABLE LICENSEE ACTIONS:

DEMONSTRATE ACCEPTABILITY OF:

1 PIPE QUALITY WELD QUALITY WELD SOCKET ENGAGEMENT

4.4-1 ALLEGATION: THREATENED FIRING 0F WELD INSPECTOR FOR USING MAGNIFYING GLASS FINDINGS:

  • INSPECTOR WAS THREATENED WITH FIRING INSPECTOR NOT FIRED BUT WAS REASSIGNED INDEPENDENT MEASUREMENT:

NONE LICENSEE ACTION:

NONE

51.

ALLEGATION: UNSUITABLE PIPING KNOWINGLY INSTALLED AND REPLACED FINDINGS: PIPING FOR ORIGINAL MSR SYSTEM DESIGN

~

INSTALLED KNOWING 3 TO 10% WOULD BE REPLACED WITH SUBSEQUENT PIPING DESIGN ECONOMIC DECISION BY LICENSEE TO PROCEED WITH ORIGINAL DESIGN MODIFICATION PROPERLY INSTALLED INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTIONS: ,

. NONE i

5.2 .

f ALLEGATION: . IMPROPER FITTINGS INSTALLED FINDINGS: . DESIGNED RATING OF FITTINGS CHANGED TO LOWER PRESSURE LOWER PRESSURE FITTINGS ADEQUATE FOR DESIGNED FUNCTION INDEPENDENT MEASUREMENTS:

. NONE LICENSEE ACTIONS:

. NONE l

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5. 3. .

ALLEGATION: . RADWATE FLOOR DRAINS CLOGGED llITH CONCRETE FINDINGS: SOME DRAINS CLOGGED AT ONE TIME WITH UNSPECIFIED DEBRIS

. DRAINS CONTROLLED BY LICENSEE 152 OUT OF 169 DRAINS ALREADY FLUSHED

-17 DRAINS TO BE FLUSHED PRIOR TO OPERATION INDEPENDENT MEASUREMENTS:

. NONE LICENSEE ACTIONS:

. NONE

5.4 ALLEGATION: . WEAK VALVE MATERIAL -- BROKEN WHEN BUMPED FINDINGS: HYDRAULIC ACTUATOR DRAIN ADAPTER BROKEN BY ADJACENT CONSTRUCTION ACTIVITIES ADAPT 0R REPLACED WITH STRONGER DESIGN BECAUSE PRONE TO DAMAGE BOTH ORIGINAL AND STRONGER DESIGNS ADEQUATE FOR DESIGNED FUNCTION

. HYDRAULIC SYSTEMS PRESSURE TESTED --

ALL COMPONENTS ACCEPTABLE INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTIONS:

NONE

5.5 ,

ALLEGATION: IMPROPER WELD R0D TEMPERATURE CONTROL AND DOCUMENTATION FINDINGS: ALLEGED PROBLEMS NOT FOUND DURING INVESTIGATION PREVIOUS NRC INSPECTION FINDINGS:

WELD RODS STORED AT IMPROPER TEMPERATURE WELD RODS LYING UNCONTROLLED IN CONSTRUCTION AREA INDEPENDENT MEASUREMENTS:

RADIOGRAPHS AND B0AT SAMPLES OF SIX WELDS -

N0 WELD PROBLEMS AND N0 MATERIALS PROBLEMS LICENSEE ACTIONS:

DEMONSTRATE WELD QUALITY

5.6. ALLEGATION

. PERSONNEL OVERCOME BY ARGON GAS SAFETY DIRECTOR DISINTERESTED FINDINGS: . ARGON GAS HOSES CRIMPED AND WIRED CLOSED RATHER THAN CLOSING VALVE

. NO PERSONNEL OVERCOME WITH ARGON

. OSHA INSPECTION FOUND ADEQUATE SAFETY CONTROLS AND PROCEDURES IN PLACE

. NO EVIDENCE THAT SAFETY DIRECTOR DISINTERESTED INDEPENDENT MEASUREMENTS:

. NONE LICENSEE ACTIONS:

. NONE

. 5. 7.

l ALLEGATION: SPOOL PIECES DROPPED FROM TRUCK HAVE DEFECTIVE WELDS FINDINGS: NO DEFECTIVE WELDS NRC PREVIOUSLY INVESTIGATED INDEPENDENT MEASUREMENTS:

NRC ULTRASONICALLY EXAMINED THREE WELDS ON EACH OF THE F!VE SPOOL PIECES -- ALL WELDS ACCEPTABLE j LICENSEE ACTIONS:

NONE r

__r , - . . _ _ , . _ _ _ .

5.8.

1 ALLEGATION: 20% OF PREFABRICATED PIPE WELDS DEFECTIVE FINDINGS: . WELDS ACCEPTABLE BASED ON REVIEW 0F MORE THAN 800 RADIOGRAPHS OTHER FINDINGS MADE WHILE PURSUING THIS ALLEGATION:

187 RADIOGRAPHS WITH UNACCEPTABLE TECHNIQUE INDEPENDENT MEASUREMENTS:

. RADIOGRAPHED SEVEN WELDS (0F OR SIMILAR TO THE 187) - WELDS ACCEPTABLE LICENSEE ACTIONS:

. DEMONSTRATE RADIOGRAPHS (SIMILAR TO THE 187)

ARE ACCEPTABLE

5. 9.

ALLEGATIONS: PIPE DESIGNS DRAWN AFTER INSTALLATION FINDINGS: . PREVIOUS NRC INSPECTIONS HAVE IDENTIFIED MANY PIPE AND PIPE SUSPENSION DESIGN PROBLEMS PROBLEMS RESULTED IN NONCOMPLIANCES, MANAGEMENT MEETINGS, LICENSEE STOP WORK ORDERS, AND AN IMMEDIATE ACTION LETTER RESOLUTIONS NOT COMPLETE -- FOLLOWED BY INSPECTION PROGRAM INDEPENDENT MEASUREMENTS:

. NONE l LICENSEE ACTIONS:

. NONE

5.10 ALLEGATION: . CABLE TRAY HANGERS HAVE FAULTY WELDS

. CABLE TRAY WELDS FAULTY

. CABLE TRAYS DANGEROUSLY FULL FINDINGS: . >130 CABLE TRAY HANGER WELDS EXAMINED -

FOUR WELDS UNACCEPTABLE

. PREVIOUS INVESTIGATION FOUND TRAY WELDS ACCEPTABLE

. CABLE LOADING (THERMAL) DESIGN BASIS DIFFERENT THAN FSAR

. THERMAL LOADIN3 0F POWER SLEEVES NOT VERIFIED

. WEIGHT LOADING 0F TRAYS NOT VERIFIED ENGINEER IDENTIFIED DESIGN DEVIATIONS NOT CONTROLLED ,

OTHER FINDINGS MADE WHILE PURSUING THIS ALLEGATION:

. IN-PROCESS INSPECTION OF HANGER WELDS NOT PERFORMED

. FINAL WELD INSPECTIONS PERFORMED AFTER PAINTING

. WELD INSPECTION CRITERIA DEVIATED FROM CODE REQUIREMENTS LICENSEE ACTIONS:

. DEMONSTRATE WELD QUALITY

. ASSURE ALL DISCIPLINE DESIGNS ARE VERIFIED l

. ASSURE DESIGN DEVIATIONS ARE CONTROLLED

5.11 ALLEGATION: . SERVICE WATER INTATE FROM RIVER KEEP CHOKING PUMPS, PUMPS QUICKLY BURN OUT.

FINDINGS: SILTING CONDITION REPORTED PER 10 CFR 50.55(E)

IN JUNE, 1979 ACCELERATED PUMP WEAR REPORTED PER 10 CFR 50.55(E) IN AUGUST, 1979 SILTING AND PUMP WEAR CONCERNS OPEN NRC ISSUES PENDING COMPLETION OF f10DIFICATIONS INDEPENDENT MEASUREMENTS:

. NONE LICENSEE ACTIONS:

NDNE

5.12, ALLEGATION: . DESIGN FLAW CAUSED PIPES TO RUPTURE --

SPRAYING WATER THAT WOULD HAVE BEEN RADI0 ACTIVE FINDING: . PIPE OVERPRESSURIZATION REPORTED PER 10 CFR 50.55(E) IN MARCH, 1979

. CAUSED BY OPERATOR ERRORS --

TWO VALVES LEFT OPEN

. WATER COULD HAVE BEEN CONTAMINATED IF OPERATING

. ACTIONS TAKEN TO ASSURE QUALITY OF PIPING AND COMPONENTS AND TO PREVENT RECURRENCE FOUND ACCEPTABLE BY NRC PRIOR TO ALLEGATION l

INDEPENDENT MEASUREMENTS:

. NONE l

l LICENSEE ACTIONS:

. NONE

, 5,13, ALLEGATION: . N0 SECURITY SURVEILLANCE CAMERAS DURING FUEL RECEIPT AND PERIMETER FENCE OF FOUR FOOT CHICKENWIRE FENCE FINDINGS: . ALLEGATIONS IRRELEVANT CAMERAS NOT REQUIRED AT TIME OF FUEL RECEIPT PERIMETER FENCE NOT REQUIRED AT TIME OF FUEL RECEIPT INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTIONS

. NONE

)

1 ALLEGATION: . ALCOHOL AND DRUG USE FINDINGS: SOME EVIDENCE OF ALC0 HCL AND DRUG USE INDETERMINATE EFFECT ON PLANT QUALITY INDEPENDENT MEASUREMENTS:

60 WELDS RADIOGRAPHED:

IDENTIFIED 0FFSET IN PIPE BUTT-WELDS EVALUATION IN PROGRESS INDETERMINATE RELATION TO ALC0HOL AND DRUG USE LICENSEE ACTIONS:

. QUALITY OF PLANT TO BE VERIFIED BY QUALITY CONFIRMATION PROGRAM l

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5.15 .

ALLEGATION: EMPLOYEES FIRED FOR TIME CARD CHEATING --

CHEATING WITH APPROVAL OF MANAGEMENT CHEATERS WERE CRITICS OF QA AND SAFETY FINDINGS: FIVE INDIVIDUALS WERE FIRED FOR TIME CARD CHEATING. NO INDICATION OF APPROVAL BY MANAGEMENT. OTHER CRITICS OF SAFETY WERE NOT FIRED.

INDEPENDENT MEASUREMENTS:

. NONE LICENSEE ACTIONS:

. NONE 1

5.16 ALLEGATION: . CGaE WARNED PEAB0DY MAGNAFLUX (PM) TO SILENCE RADIOGRAPHERS

. CGaE APPROVING WELDS REJECTED BY PM

. PM TRAILER BROKEN INTO AND RECORDS OF OVERRIDDEN WELD REJECTION REMOVED FINDINGS: . SEVEN PM EMPLOYEES DENIED THE SILENCING ALLEGATION

. RADIOGRAPHERS, CGaE, AND PM MANAGEMENT DENY ANY ATTEMPTS WERE MADE TO OVERRIDE WELD DETERMINATIONS

. PM TRAILER BROKEN INTO -- FIVE RECORDS OF GOOD WELDS f11SSING INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTIONS:

NONE 1 . - . _ .

5.17, 4

ALLEGATION: . UNION PIPEFITTERS AND PEABODY MAGNAFLUX EMPLOYEES INTIMIDATED FINDINGS: . TWO FIRED UNION PIPEFITTERS AND SEVEN PM EMPLOYEES DENIED ALLEGATION INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTIONS:

NONE

5.18 ALLEGATION: FORMER KAISER EMPLOYEE HAS A DETAILED JOURNAL 0F SAFETY DEFECTS FINDINGS: INDIVIDUAL KEPT FIELD INSPECTION NOTEBOOK.

HE BELIEVES ALL DEFICIENCIES WERE CORRECTED.

INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTIONS:

NONE I

1

5.19 ALLEGATION: . PIPEFITTERS SAID THEY WILL BE FAR AWAY AT STARTUP DUE TO PREDICTED ACCIDENT FINDINGS: -

ALLEGED STATEMENT MADE INDEPENDENT MEASUREMENTS:

NONE LICENSEE ACTION:

NONE i

6.1 ALLEGATION: - QC INSPECTOR HARRASSMENT FINDINGS: INSPECTOR HARASSED BY CRAFT PERSONNEL WATER DOUSING SPRAYED WITH FIRE EXTINGUISHER DIRECTED PERSONNEL SEARCH PERFORMED BY SECURITY INSPECTORS REASSIGNED BECAUSE OF CONSTRUCTION MANAGEMENT CRITICISM LOSS OF INSPECTOR INDEPENDENCE NOT EVIDENT PREVIOUS LICENSEE ACTIONS:

ATTEMPTS TO IDENTIFY AND DISCIPLINE HARASSERS WAS INEFFECTIVE LICENSEE ACTIONS:

ESTABLISH MEASURES TO STOP HARASSMENT

._._ . . . _ . _ . . _ _ . _ _ . _ _ _ . . . _ . _ _ _ - . _ - - - __ .~. -

, 6.2.

ALLEGATION: WELD INSPECTION CRITERIA DELETED FINDINGS: CRITERIA DELETED FOR IN-PROCESS INSPECTIONS OF DRYWELL WELDING ACTIVITIES FROM JULY, 1980 THROUGH JANUARY, 1981 CRITERIA DESIGNATED NOT APPLICABLE FOR ONE WELD IN NOVEMBER, 1979 LICENSEE ACTION: .

DEMONSTRATE WELD QUALITY INDEPENDENT MEASUREMENTS:

NONE l

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,6. 3 ; . .

ALLEGATION: SURVEILLANCE REPORTS NOT CONVERTED TO NONCONFORMANCE REPORTS IN 30 DAYS FINDINGS: . PROCEDURE REQUIRED CONVERSION IM 30 DAYS PROCEDURE INADEQUATE - SURVEILLANCE REPORTS DID NOT RECEIVE ENGINEERING REVIEW WHEN IDENTIFYING NONCONFORMANCES

. SRs WERE NOT ALWAYS CONVERTED IN 30 DAYS LICENSEE ACTION:

. REVIEW ALL SRs TO IDENTIFY NONCONFORMANCES --

PROPERLY DISPOSITION NONCONFORMANCES INDEPENDENT f1EASUREMENTS:

NONE l

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7.1 INSPECTION: HANGER BEAMS AND WELDS FINDINGS: 25 BEAMS EXAMINED

-NINE BEAMS HAD UNACCEPTABLE WELDS

-FIVE BEAMS HAD UNACCEPTABLE RE-ENTRANT CORNERS

-FOUR BEAMS INSTALLED WERE NOT SPECIFIED BY DESIGN

-NINE BEAMS WERE NOT TRACEABLE THREE BEAM VENDORS NOT EVALUATED STEEL ERECTION DETAILS NOT DOCUMENTED INDEPENDENT MEASUREMENTS:

53 ADDITIONAL STRUCTURAL MEMBERS EXAMINED

-HARDNESS TESTS ACCEPTABLE I -380 WELDS INSPECTED -- ALL ACCEPTABLE LICENSEE ACTIONS:

COMPARE BEAM DRAWINGS TO ACTUAL PLANT DEMONSTRATE BEAM QUALITY DEMONSTRATE WELD QUALITY

J.2 . .

INSPECTION: CABLE SEPARATION FINDINGS: . CABLE SEPARATION VIOLATIONS AT FOUR LOCATIONS

. NO INSPECTION PROGRAM TO VERIFY SEPARATION IN SPREADING ROOM

~ LICENSEE ACTIONS:

REROUTE CABLES REVIEW DESIGN CONTROL OF CABLE SEPARATION

. INSPECT ALL LOCATIONS OF POTENTIAL SEPARATION VIOLATIONS INDEPENDENT MEASUREMENTS:

. ADDITIONAL SEPARATION VIOLATIONS IDENTIFIED BY RESIDENT INSPECTOR

7.3 '.

INSPECTION: CG&E AUDITS OF SARGENT & LUNDY (AE)

FINDINGS: S&L NONCONFORMANCE PROGRAM NEVER AUDITED VARIOUS AUDITS IDENTIFIED RECURRING PROB INVOLVING DESIGN CALCULATIONS AND REVI CAUSE OF PROBLEM NOT DETERMINED CORRECTIVE ACTION NOT TAKEN 'T0 PRECLUD REPETITION LICENSEE ACTIONS:

. REVIEW ALL PAST CG8E AUDITS'0F sal, G.E.

KEI, AND FOUR INTERNAL DEPARTMENTS DETERMINE DEPTH AND ADEQUACY OF AUDITS

. DETERMINE ACCEPTABILITY OF AREAS NOT AUI i

INDEPENDENT MEASUREMENTS:

NONE e

- - - - p

QUALITY CONFIRMATION PROGRAM

  • l PilR20SE DETERMINE THE QtJALITY OF PAST CONSTRUCTION BY CONFIRMING:

.. QUALITY OF PIPE MATERIAL PROPER DISPOSITION OF NONCONFORMING ITEMS

. QUALITY OF PIPE WELDS

! . QUALITYOFSTRUCTURALSTEELMATERIALANDWELDS 4

ADEQUACYOFELECTRICALCABLESEPARATION ADEQUACY OF AN ELECTRICAL DESIGN CONTROLS ADEQUACY OF CONTROL 0F DESIGN CHANGES ADEQUACY OF SUBCONTRACTOR QA PROGRAMS ADEQUACY OF PAST AUDITS Tills PROGRAM WILL BE EXPANDED SHOULD THE LICENSEE IDENTIFY SIGNIFICANT PROBLEMS DURING CONDUCT OF THE QCP OR SHOULD THE NRC IDENTIFY PROBLEMS IN THE REMAININ INVESTIGATION AND INSPECTION EFFORTS.'

-.--..-,..e__ .

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