ML20064E299
| ML20064E299 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Zimmer |
| Issue date: | 12/31/1979 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20064E073 | List: |
| References | |
| FOIA-82-206 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8301050284 | |
| Download: ML20064E299 (1) | |
Text
{{#Wiki_filter:' s. THE CINCINNATI GAS & ELECTRIC COMPANY as F cmemum.omo 4smoi
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December 31, 1979 i QA-1239 U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. James G. Keppler, Director RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I 10CFR 50:55(e) EVENT NO. .ti-13_.- SERVICE WATER PUMPS - DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. #57300-957, JOB E-5590 Gentlemen: This letter constitutes an interim report on the status of the investigation of the operational problems experienced with the Zimmer service water pumps under low flow conditions. A previous interim report was submitted to your office on September 6, 1979. Bingham-Willamette, the pump manufacturer, has developed a new impeller design. A new impeller is currently in the process of i fabrication, and Bingham-Willamette is planning to conduct a test of the new design in their factory in approximately 6 weeks. Concurrently, CG&E is investingating several alternative methods to achieve flow control under minimum flow conditions. The decision as to which of these alternatives will be used is awaiting the results of the test. We trust that this letter will serve as an acceptable interim
. report on this item.
I Very truly yours, THE CINCINNATI GAS 8. ELECTRIC COMPANY
' ~~
By E. A. BORGMANN SENIOR VICE PRESIDENT JFW:ec \960 8301050284 821116 PDR FOIA DEVINE82-206 PDR
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3 L = er; THE CINCINNATI GAS & ELECTRIC COMPANY I' m
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. December 17, 1980 c.4 .e oua=N QA-1371
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i U.S. Nuclear Regulatory Commission ! Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. James G. Keppler Director RE: WM. H. 77M"r3 NUCLEAR POWER STATION - UNIT 1 - 50.55(e) ITEM M SERVICE WATER PUMP ACCELERATED WEAR - DOCKET NO. 50-358, CONSTRUCTION PERMIT CPPR-88, W.O. 57300-957, JOB E-5590 Gentlemen: We previously reported a potential 50.55(e) item (M-13) involving accelerated wear of service water pump impellers. This letter will advise you that after detailed investigations we have concluded this matter is definitely reportable under 50.55(e). A detailed report of our investigations, conclusions and system modifications required is being included in an FSAR revision which will be forwarded to you shortly. The matter can be summarized as-follows: The service water pumps were designed to accommodate maximum service water flows associated with worst case LOCA situations. Service water flows during normal non-accident condition's are less than that required to prevent internal recirculation in the pumps. The original design made no provision to assure that internal recirculation would not occur and we believe it did occur during initial pump operation. The accelerated impeller wear is attributed to internal recirculation. Flow elements and minimum flow control valves are being added to the service water system to assure the situation will h n-pe W DEC 2 21980
U.S. Nuclear Regulatory Commission Dec, ember 17, 1980
, To:
I Zimmer Nuclear Power Station - 'Page #2
- Re: Wm. H.
l Unit 1 - 50.55(e) Item M Service Water Pump Accelerated Wear i i, not recur. Redesigned pump impellers of more rugged construction with lower minimum flow capability are also being installed. We trust that the above explanation provides an accept-able interim status report on this item. Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By s E. A. BORGMANN [O *- Senior Vice President JFW: dew cc: NRC Resident Inspector Attn: F. T. Daniels NRC Office of Inspection & Enforcement Washington, D.C. e W e i 4 e bem - im m
i UI INV002/0 DRAFT /jp
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c\t' %/k ' Ss 5.11.1 Allegation
" Sand and mud choke the feedwater pumps and intake flues carrying makeup
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water to the cooling tower, because of a flaw in the plant's design. Pumps used to rectify the flow quickly burn out." ' During an interview with Thomas papplegate and GAP representatives, it was clarified that this allegation pertained to the river intake structure. The river intake provides service water, not feedwater. 5.11.2 Background Information 10 CFR 50.55(e) requires licensees to report to NRC major defects found during construction or operation of power reactors. These reports are public documents and are maintained in NRC files and Public Document Rooms. 5.11.3 Investication tr The, licensee orted silting conditions in CG&E letters QA-1148 dated
/~ f June 20,1979 QA-1168 dated July 23, 1979, and~ service water pump p(
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r' wear conditions in letters QA-1196 dated September 16, 1979, c v 'g l 4 f,,f ; QA-1239 dated December 31, 1979, and QA-1371 datea vecember 17, 1980, d'. that were sent to NRC Region III pursuant to the requirements of 10 CFR i 50.55(e). Copies of these letters are attached as Exhibits . i
, s. INV002/0 DRAFT /jp The silting and pump impeller wear conditions, along with the measures to correct these conditions, are described in Appendix J of the Wm. H. Zimmer FSAR, Revision 69, dated December 1980, attached as Exhibit .- The corrective measures to be taken, as described in the excerpts, have been reviewed and accepted in Subsection 9.2.1 of the " Safety Evaluation Report (SER) Related to the Operation of W m. H. Zimmer Nuclear Power Station, Unit 1," Supplement 1 issued in June 1981 by the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. The implementation of these corrective measures is unresolved pending notification by the licensee of the completion of the corrective measures described in the Wm. H. Zimmer FSAR, Appendix J, Revision 69, dated December 1980, (50-358/81-13-31). 5.11.4 Findings The statement that sand and mud choke the feedwater pumps and intake flues is correct in that the licensee reported a silting condition concerning the service water intake structure to NRC Region III by telephone on June 18, ___s 1979 and by letters QA-1148 o une 10, 1979-dad QA-1168 dated July 23,
- {
1979 pursuant to the requirements of 10 CFR 50.55(e). . The statement that choking of the feedwater pumps was caused by a flaw t
; j in the plant design is correct in that the plant design and operating i procedures had to be modified to control the silting condition. . '
-2
_ INV002/0 DRAFT /jp The statement that pumps used to rectify the flaw quickly burn out does not appear to be correct. However, accelerated service water pump impeller wear was reported by the licensee by telephone on August 10,1979;andby letters QA-1196 dated September 6, 1979, QA-1239 dated December 31, 1979, and QA-1371 dated December 17, 1980 pursuant to the requirements of 10 CFR 50.55(e). The silting and pump impeller wear concerns are unresolved pending notifi-cation to NRC Region III by the licensee of the completion of the corrective measures described in the Wm. H. Zimmer Final Safety Analysis Report (FSAR), Appendix J, Revision 69 dated December,1980 (including a sedimentation monitoring program and plant modifications). The implementation of these corrective measures will be reviewed during a subsequent inspection. ( 36'3/SI- 13 __ ) 5.11.5 Items of Noncompliance No items of noncompliance were identified. f i k f i ! ! 1 l J: 1 5 A W l - l t (
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- l. KEI-l knowingly installed and ripped out unsuitable main stream relief piping at an estimated labor cost of $320,000.
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~ ! Findin as This allegation was substantiated but there were no uncontrolled nuclear safety concerns.
Basis for Findings Discussions with the CG&E Principal Mechanical Engineer confirmed that MSR piping was installed with foresight that part of the pipe would later be replaced. The MSR piping was already being installed for the second time in order to replace the rams head discharge devices with quenchers. This second design resulted after discovery of new discharge loada at a plant in Germany in 1975. The NRC has been aware of the design modifi-cation as indicated by the Zimmer Mark II Design Assessment Feport and NUREG-0487. ZnJe CG&E decided to start the; modification in 1975, knowing that approxi-mately 5% of the piping that would be going in would have to be replaced. The design modification was incomplete and and changes
~
vould be dontinuing. To date (1981), the design modification is still not complete. The decision to start installing the modification in 1975 was an economic one, based on not delaying the construction schedule. The total labor cost to date is $1,183,690.00. e _ _ , . , _ , _ . _ , ..,,,._-.,--.c. _ . _ _ . - - . __. -- _. -- --
i The RIII inspector reviewed all revisions to the applicable' isometric drawing for the MSR piping. All revisions indicated changes based on the above design modification. Therefore, there have beed no other j activities pertaining to the MSR piping of the monetary magnitude l that was alleged. The RIII inspector reviewed the QC documentation for 12 velds in the piping. The RIII inspector interpreted the radiographs for six welds in the piping. The records indicate the design modification has been properly controlled. e e a wP e 9 l .
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.s The RIII inspectors reviewed approximately 180 Construction Inspection Plans (CIP), inspection records, for the hangers in the cable spreading room (elevation 536 feet in the north section of the auxiliary building). The records indicated that all of the field welds were inspected and accepted in December,1980 and Janua ry, 1981.
r'df Y 9 Discussions with the pertinent QC management and inspection personnel revealed that the welds had been inspected after being painted., No records were available to indicate that in process inspections were V made to'berify N proper fitLer metal, weld procedure, welder's avalification, surface conditions, etc., as required by the AWS D1.1-1972 code, section 6. d Oss eun.a s . . - ~ ~ ~ ~ - - - _ - - ~ pe:ded . The Licensee stated that the visual examinations of the tray hanger welds were based on H. J. Kaiser Company Procedure No. SPPM 4.6, ( Revision 8, dated August 29, 1980, paragrp<aph 5.1.3 which states,
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and free f rom slag, rust, arc burf s, paint, dirt, or other contaminants : i that would interfere with the x< examination." The Licensee stated 0 4 ~ V that paint (falvafox) that was applied to the hanger welds did not ! interfere with the visual examination and in some cases actually highflighteddiscontinuities. AWS D1.1-1972 code, section 3.10.1 states. ". . . Welded joints shall not be painted until after the l t r i
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work has been completed and accepted. . ." The apparent lack of in process inspections and inadequate visual e< inspections of the above hanger welds is contrary to 10 CFR 50 Appendix B, Criterion X and the Wm. H. Zimmer QA Manual, Section 10.1.2 as described in the Appendix A to the report transmittal letter. 10 (358/81-13-04) The RIII inspector requested the design acceptance criteria which was used by QC to evaluate the undercut on hanger No.15H2FEC175. The Licensee provided S&L Specification H-2713 Supplement 7, Standard EB-117 and J<H. J. Kaiser p< Procedure No. SPPM 4.6, foregrefk JC L.1 Revision 83 which allows up to 1/16 inch undercut on the cable tray hanger welds. The 1/16 inch criteria does not comply with t AWS D1.1 1972 Section 3.6.4 which states "For building; and tubular structures, undercut shaLL be no more than 0.01 inch deep when it's i< direction is transverse to primary tne<<tensite stress in the i . . part that is undercut, nor more than ,5/32 inch for all other g aes ( situations 17heseTh44 deviationj from the AWS code he contrary to I" f 10 CFR 50, Appendix B, Criterion III,and the Wm. H. Zimmer.e* F54% 7kble 3.8. L , an d s seu Ws of. 4 :m m er Q A ' Ibff ,af dt , Manual, Section 3.3 as described in the Appendix A to the report
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I transmittal Letter. (358/81-13-1N) ,
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(16) No. 5H3(12) - no unacceptable weld discontinuities (17) No. SH2(12) - no unacceptable weld discontinuities - (18) No. 5H25 - no unacceptable weld discontinuities; foot connect-ion covered with fireproofing
- c. ElevationSS473SSFeetSSAuxiliarySSBuilding5SHangersSU (1) No. 5H009 (drawing E-91) no unacceptable weld discontinuities '
(2) No. 4H3 %[ drawing E-14) no unacceptable weld discontinuities (3) No. 2H1 (drawing E-14) no unacceptable weld discontinuities (4) No. 5H010 (drawing E-91) no unacceptable weld discontinuities (5) No. SH012 (drawing E-91) no unacceptable weld discontinuities (6) No. 6H1 (2) (drawing E-14) no unacceptable weld dsi<< discontinuities (7) No. 6H1 (1) (drawing E-14) no unacceptable weld discontinuities Four to six weeks wer<<< , ah. Four to six welds were inspected on each.of-the above hangers. gSeveral of the tray hanger foot connections (where the hangers are ! i I attached to the structural beams) were covered with fireproofing g / and could not be inspected. Therefore, the RIII inspector requested QC inspection documentation to assure tht<at the welds, l covered by fireproofing, were acceptable. The Licenses provided a copy of Surveillance Report No. 2893 dated Jaj<nuary 8,1981 ;
h ft k which id-
- ';re that 94 of 179 cable tray hangers,in the cable
. spreading room y wh+eh have one or both foot connections covered with fireproofing. The SR requested clarification as to what QC should do since the foot connections had not been inspected. 7;; .' -.
c-- e:*42- i: _ h; r: -'- h- -- -++--k-- +- +'- :: ... ..., ,,___ As of March 27, 1981, the SR had no dispoisi<< disposition. 1 This item is unresolved pending the resolution of the hangers identified in SR No. 2893 and any other hanger connections throughout the plant that were covered before being inspected. 2 (358/81-13-1/) f t I e i I i f a
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- 1. RIII inspection of large bore piping and pipe suspension system design and installation was initiated in May,1978. During the
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latter part of 1978, RIII tn : ' - - u ,- - - that rrer-e of the existing installations were not in accordance with the design. The causes of the situation were primarily dDtf M
- a. the updating of GE design criteria that invalidated the previous engineering considerations, and
- b. the continuous NRC adverse findings on the site installations and QC inspection program that had determined that most of the design requirenents had not been met. S&L declared that all installations weeld were considered preliminary, and that final calculation + 44 be 4f rade prior to system test and accept 3nce. p + ^ " e c # ~ "-" w c.a s 4 .. . ._-'
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- W Applegate 9 It is aIleged that engineering designs are
- 1. Reviewa records, routinely drawn after the fact to conform on piping and electric.a1 ,
with piping that already has been installed. designs. 0 7 y
fe,-f:% de&s Another alleger stated that electrical engineering design drawings are also drawn p Jg ,N ,, nl*c.s en f after the fact.
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s.a., m . .s . o . . , .. a. o a. u m e n u y - ~ - - - - - -- .. g FIELD C':lSTRUCTION PROCl!Duilt 24
. Ni. l{. Z!!?'r.R !!tCLEAR POe,5R PIPING
- DRAWINGS ,
S1ATIC:1 - UllT 1,lOSCO',1, Cili 0 ' - THIS COPY ISSUED FOR PAGE 1 0F 3 - SEO 4 /TE, 6/9/81 i . stwCCT: Piping Drawings NOT TO DE USED FCR
,, . . w . n n cnmem en nnr.i
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l l AUTICRI :Q: ' I ffs4lA
- Projern : tan /aer h E> W/' n Gen. Suoerintendent Constructi6n Ma'ager
, {, (
n Construction Eng._ - QA STATUS: QA PROCEDURE REQUIRED W YES / AL' / 0
, p tD \ -% P<
, . $WW QACMI G-13 QA Manager ' 1.0 GENERAL Establish the criteria by which piping drawings wil'1 be prepared and utilized to transmit piping design criteria for construction. 1.1.0 Responsibility . . 1.1.1 The Chief Piping Engineer is responsible for originating all construction aid piping drawings and revisions due to design changes. 1.1.2 The Document Control responsibility will be as outlined in Field Construction Prodedure #2-5 and QACMI #G-1. 1.1.3 'The responsibility for small bor~e pipe data sheets that are generated from 2" and under piping drawings will be as out-lined in QACMI #G-13. . 1.1.4 The QA Department, under the supervision of the QA'fianager, shall monitor and inspect the work to maintain credibility and traceability. 1.2.0 Object and Purpose b 1.2.1 Obtain, interpret, clarify and transmit the A/E's design information to the construction forces in a more convenient ' manner (construction did).
' 1.2.2 Supply QA with the current approved configuration to perform inspection and prepare quality documentation con-sistent with latest configuration. \
HEliP.Y J. KAISER C0:1PAf!Y FIELD C0tiSTRUCTION PROCEDURES 24
'e kH. H. ZIM:4ER !!UCLEAR POWER STATI0ft U;11T tiO. 1 MGSCOW, OHIO Page 2 of 3 Revision 4 Date 6/9/81 1.3.0 Scope 1.3.1 Piping Classes Record inspection drawings are required of all piping i designated as pipe class A, B, C or D+ and shall indicate weld locations and weld numbers.
2.0 OPERATIO:IS 1 j i 2.1.0 Original Preparation of Piping that Requires Record Inspection
, Drawings as Outlined in Section 1.3.0 (Scope) 2.1.1 The Piping Engineering Department will prepare the piping isometric drawings. The content is covered by Field ,
Construction Procedure 2-22. The Chief Piping Engineer - will approve all drawings. A transmitt'al slip will be prepared for all original tracings that leave the Piping Department Document Control Clerk. , 2.1.2 The original tracing will be passed to the Welding Depart-ment. The Welding Engineer will add and approve the proper weld procedure information for all welds that are shown. 2.1.3 The original tracing is then pas' sed to the QA Department. The QA Engineer will review and approve the proper weld information and indicate the appropriate inspections to be performed for all the welds shown. 2.1.4 The origin:.1 tracing will be available to the authorized Nuclear Inspector who at his discretion will review weld data and indicate hold points as required. 2.1.5 The original tracing is then passed.back to the Piping Department Document Contr61' Clerk to be distributed per Field Construction Procedure 2-5 and QACMI #G-1. 2.1.6 In cases where 2" and under piping in Pipe Class A, B, C or D+ requires " Field" changes due to interferences, the Piping Field Engineers shall modify the pipe routing and the change will be documented as follows:
- 1. The Piping Field Engineers will mark up a copy of the applicable isometric, clearly showing the routing change and any weld indentification for additional welds and any additional materials and/or pipe fi,ttings. '
- 2. When the Field Piping Engineer is sure of the field modifications, he shall submit his final marked up isometric to the HJK Piping Engineering Department.
l
O HEllRY J. KflISER COMPAtlY
-; o-FIELD CONSTRUCTION PROCEDURES 24 WM. H. ZilEER flVCLEAR POWER STATION UNIT fiO. 1. MOSCOW, OHIO Page 3 of 3 Revision 4 Date 6/9/81 i
2.1.6 3. The HJK Piping Engineering Department will make final
' revisions to the " Original" isometric and issue said isometric as a final drawing for installation and in-spection.
i
- 4. The QA Inspection Department will perform all in process i inspections to the final isometric drawing and indicate final acceptance on the " Record Document" as objective evidence of accaptability and traceability of materials and weldments.
2.2.0 Original Preparation of Piping or Hangers that Do Not Require
, Record Inspection Drawinas as Outlined in Section 1.3.0 (Scope) 2.2.1 The Piping Engineering Department will prepare the piping isometrics drawings. The content is covered by Field Construction Procedure 2-22.
2.2.2 Only piping that lends itself to pre-installation fabri-
- cation will be drawn before installation. These drawings will be designated construction aids and will have no inspection purpose.
2.2.3 The original tracing is then pas, sed to the Piping Department Document Control Clerk to be distributed per Field Construc-tion Procedure 2-5. 2.2.4 There wi11 be no revishis on these drawings during erection unless requested by the piping Superintendent for clarity. 2.2.5 Piping Class D with non-essential hanger Class of C, D or N that is not detailed and located on the consulting engineer's S&L drawings shall be placed or revised on record drawings after installation, if deemed necessary by CG&E. 3.0 FCP REFERENCES 3.1.0 FCP 2-5 Configuration Doc 0 ment Control r ' FCP 2-14 Piping Engineering' FCP 2-22 Drawing Preparation FCP 2-27 S&L Review of KEI Drawings t l g I - l
c.h lo'Huwall 1 Whi
' ' an ext een el;r1.cw opini i
placed mora blame en the utility, Di sier display ed was jt st" burning money"on of Kaiser. In general he ought' Kaiser descri bec at Zimmer to build up co,st overruns. He with the the work site as employees " standing around all the time," - result being exorbitant waste and costs. He explained that KaiserwMnagement gave busywork assignments while ign prob being,lems. ' He reedlled that it got to the point where pipine was s desi ninstalled firstwithand then_ had Kaiser already wou1~d draw the engineerin 6 Y to~ conform what been installed . routinely drawn after the tact to evusu.- - . - -
- with pi Ping thac already has been installed. designs. *
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Another alleger stated that electrical j g engineering design drawings are also drawn l
- after the fact. -
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, FIELD CONSTRUCTION PROCEDURE 2 - 24 3
, W.H. ZIMMER NUCLEAR PCWER
! STATION-UNIT 1, MOSCOW, OHIO l Pact i OF 3 REVISION 3 DATE November 15, 1979 l -
SUBJECT:
' 2" AND UNDER l PIPING AND HANGER DRAWINGS -
- THIS COPY !SSUED7FOR .--.
. AU OR12ED: ' IIll'Il[O'l[, j j hh , I f,
t I P JECT MANAGER KEI Gell SUPT l
) f .w. <m1 .kAJ..d CONST.iENGIllEER4CJIEF;glPING ENGINEER l
QA STATUS: QA PROCIDURE REQUIRf5 2 bbfCAW) {pggQ ;. L.L NO \ ; f/ 0A4// &/3 - 1.0 GENERAL ' Establish the criteria by which the 2".and under piping and hanger . drawings will be prepared and utilized to ' transmit piping and ! hanger design criteria for construction. - 1.1.0 Resoons~ibility I, R!
'1.1.1 The Chief Piping Engineer is responsible for originating !
all drawings and for incorporating all revisions in ', 2 order to maintain the credibility of all erection. ' l ' I i 1.1.2 The Document Control responsibility will be as out- ! lined in Field Construction Procedure #2-5 and QAct1I !
#G-1.
l 1.1.3 The responsibility for small bore pipe data sheets that ; are generated from 2" and under piping and hanger draw-ings will be as outlined in QACMI #G-13. ' 1 . 1.1.4 The QA Department, under the supervision of the QA ! Manager, shall monitor and inspect the work to main- ! I tain credibility and traceability. 1.2.0 Object and Purcose I
- 1. 2.1 Obtain, interpret, clarify and transmit the A/E's design information to the erection forces in a more convenient manner (construction aid).
I
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1.2.2 Supply OA with the current approved configuration to l perform inspection and prepare quality documentation l consistent with latest configuration.
4!SIRENG8NEERS.INC. FIELD CONSTRUCTION PROCE00RES 2-24 iTE0 ,I OH 2" AND UNDER PIPING AND HANGER DWGS.
,Page 2 of 3 Revision 3 Date November 15, 1979 1.3.0 Scope 1.3.1 Hanger Classes j Record inspection drawings are required of all piping
- designated as pipe Class A, B, C or D (with essential l hanger / seismic Class A, B and S)and shall indicate i hanger loutions and types.
Record inspection drawings are required of all hanger details designated essential (hanger / seismic Class A, B and S).
- 1.3.2 Piping Classes Record inspection drawings are required of all piping designated as pipe class A, B, C or D+ and shall in-dicate weld locations and weld numbers. ,
2.0 OPERATION 2.1.0 Original Pre,aaration of Piping and Hangers that Require Record Insoection Drawings as Outlined in Section T.3.0 (Scope) 2.1.1 The Piping Engineering Department will prepare the piping isometrics and hanger drawings. The content is covered by Field Construction Procedure 2-22. The Chief Piping Engineer R will approve all drawings. A transmittal slip will be prepared for ill original tracings'that leave the Piping Department . Document Control Clerk. 2.1.2 The original tracing will be passed to the Welding Department. The Welding Engineer will add and. approve the proper weld procedure information for all welds that are shown. 2.1.3 The original tracing is then passed to the QA Department. The QA Engineer will review and approve the proper weld information and indicate the appropriate inspections to be perfomed for all the welds shown. 2.1.4 The original tracing will be available to the authorized Nuclear Inspector who at his discretion will review weld data and indicate hold points as required. 2.1.5 The original tracing is then passed back to the Piping Dept. Document Control Clerk to be distributed per Field Construction Procedure 2-5 and QACMI #G-1. 2.1.6 In cases where 2" and under piping in. Pipe Class A, B, C or D+ requires " Field" changes due to interferences, the Piping Field Engineers snall modify the pipe routing and the change will be documented as follows:
KA!3ER ENGINEERS, INC. FIELD CONSTRUCTION PROCEOURES 2-24
. : W. H. ZIP.uER 'tUCLEAR POWER STATION UNIT NO. 1. M05C W. OHIO 2" AND UNDER PIPING'AND HANGER DWGS.
Page 3 of 3 Revision 3, Date November 15, 1979
- 1. The Piping Field Eng'ineers will mark up a copy of the applicable isometric, clearly showing the routing change 4
and any weld indentification for additional welds and any additional materials and/or pipe fittings.
- 2. When the Field Piping Engineer is sure of the field
, modifications, he shall submit his final marked up i
isometric to the KEI Piping Engineering Department.
- 3. The KEI Piping Engineering Department will make final revisions to the " Original" isometric and issue said isometric as a final drawing for installation and in-spection.
- 4. The QA Inspection Department will perform all in process inspections to the final isometric drawing and indicate final acceptance on the " Record Document" as objective evidence of acceptability and traceability of material.s and weldments.
2.2.0 Original Preparation of Piping or Hangers that Do Not Require Record Inspection Drawings as Outlined in Section 1.3.0 (Scope) 2.2.1 The Piping Engineering Department will prepare the piping R isometrics and hanger drawings. The content is covered by Field Construction Procedure 2-22. 2.2.2 Only piping that lends itself to pre-installation fabri-cation will be drawn before installation. These drawings will be designated construction aids and will have no inspection purpose. 2.2.3 The original tracing is then passed to the Piping Department , Document Control Clerk to be distributed per Field Construc-j tion Procedure 2-5. 2.2.4 There will be no revisions on these drawings during erection unless requested by the piping Superintendent for clarity. 2.2.5 Piping Class D with non-essential hanger Class of C, D or N that is not detailed and located on the consulting engineer's S&L drawings shall be placed or revised on record drawings after installation, if deemed necessary by CG&E. 3.0 FCP References , 3.1.0 FCP 2-5 Configuration Document Control FCP 2-17 Piping Engineering . FCP 2-22 Drawing Preparation \ FCP .2-27 S&L Review of KEI Drawings
N W.:4. 7!/.19 ?. F4UCLIA't PC%'iA FIELD CONSTRUCTION PROCIDURS 2 - 24 sTM!o.s-temi i, trcscow, c:co 2" AND UNDER PIPING AND HANGER DRAllINGS r.M2 1 or 5 Revis:ct: 2 et.ri May 4, 1978 SUG E CT: USE OF 2" AND UNDER I PIPING AND HANGER DRAWINGS l I,UTHCR!Z ED: _/ ! 1 / // - Sc C PROJECT "A3AGER KEI GEli SUPT. _ 00ilSf. ENGINEER CHIEF PIPING ENGINEER , QA suTuS: cAhecoun isoumn !h-c ^ # ~~ E LM L.W e T.Mi&; COPY g.,:_Cg ;< _ g g j
-- --_ __.__. ; f n i r-_ r.iciaji,A -"in.ru n.a_u u !
'1891 U lif fril : U l'j Uj j i., l,.7 . _ . _ ,, j 1.0 GENERAL.
NOT TO BE USED FOR Establish the criteria by whic the 2" and under oicing and hange r drawings will be used to comply with 10 FR-JF@@ppjxgQ3)ggg[or iuclear Power Plants. 1.1.0 Rdsoonsibility ,
~
l 1.1.1 The Construction Engineer has designated the Chief Piping . Engineer as responsible for originating all drawings and for ' incorporating all revisions in order to maintain the credita-bility of all erection covered by Section 1.3.0 (Scope). i l 1.1.2 The Document Control responsibility will be as outlined in ' Field Construction Procedure #2-5 and QACMI #G-1.
' 1.1.3 The responsibility for small bore pipe data sheets that are generated from 2" and under piping and hanger drawings will be as outlined in QAC'11 #G-13.
1.1.4 The QA Department, under the supervision of the QA itanager, shall monitor and insoect the work (including any field g, revisions) to maintain credibility and traceability. 1.2.0 Object and Purpose 1.2.10 Hangers Classes 1.2.11 Record inspection drawings are required of all piping designated as pipe Class A, B, C, or D (with essential hanger / seismic ' Class A or B) and shall indicate hanger locations and types. , i 1.2.12 Record inspection drawings are required of all hanger details ; designated (essential hanger / seismic Class A or B). ' l
KAI5ER ENGINEERS, INC. FIELD C0flSTRUCTI0ft PROCEDURES 2 -24
. .WM. H. ZI!'14ER NUCLEAR POWEP. STATION tJNIT NO.1 MOSCCW, OHIO 2" AND UNDER PIPING AND HANGER DWGS.
Page 2 of 5 Revision 2 Date 5/4/78 1.2.20 Piping Classes 1.2.21 Record inspection drawings are required of all piping designated as pipe Class A, B, C, or 0+ i and shall indicate weld locations and weld numbers. In cases where 2" and under piping in pipe Class A, B, C, or D+ requires " Field" changes due to interferences, the PipingTi'ETd Engineers shall modify the pipe routing and the change will be documented as follows: 1.- The Piping Field Engineers will mark up a copy of the applicable isometric, clearly showing the routing change and any weld identification for additional welds and any additional materials and/or pipe fittings.
- 2. A copy of these marke'd up isometrics will be made available to the Field QA Inspectors to allow time to inspect and monitor the changes.
- 3. When the Field Piping Engineer is sure that all field modifications ,for any one isometric is final, he shall submit his final marked up isometric to the KEI Piping Engineering Department.
- 4. The KEI Piping Engineering Department will make final revisions to the " Original" isometric and issue said isometric as a final, drawing.
- 5. The QA Inspection Department will then correlate all in process inspection documents to the final isometric drawing issue and make final acceptance on the " Record Document" as objective evidence of credibility and traceability of materials and weldments.
1.2.22 Drawings are required of all field routed piping Class D not detailed and located on the consulting engineer's drawings. i 1.3.0 Scope 1.3.1 All 2" and under piping and field fabricated (INX) hangers having a hanger / seismic class of A or B will be drawn directly off the S&L Design Spec. 2256, must be approved by S&L with a Design Document Change (DDC) as outlined in Field Construction Procedure 2-6 and QACMI #G-5.
\
KAISER ENGINEERS, INC. FIELD CONSTRUCTION PROCEDURES 2 - 24 WM. H. ZIPEER l;UCLEAR POWER STATION
- UNIT NO.1, FOSCOW, CHIO 2" AND UNDER PIPING AND HANGER DWGS.
Page 3 of 5 Revision 2 Date 5/4/78 Definition: Essential Piping i Piping Class Hanger or Seismic Class i A- A or B-l Record Inspection Drawing Record Inspection B- , Required with Weld Loca- A or B- Drawing Required with ( tions and Weld Numbers " Hanger Locations j C- , A or B - and Types
~
0+ A or B - 1.3.2 All remaining piping and hangers will be drawn from S&L Design Schematics, S&L Design Spec. 2256, composite overlays and good piping practice. Any revisions to this piping and these hangers will have to comply with S&L Design Spec. 2256 and Good Piping Practice. - Definition: Non-Essential Piping Piping Class Hanger or Seismic Class D-No Inspection Dwgs. Required A or B Record Inspections Drawings Required with Hanger Types and Location Piping Class Hanger or Non-Seismic Class A- C, D, or N - Record Inspection Drawing B-, Required with Weld Loca- C , D , or -N -- tions and Weld Numbers No Inspection k C- C, D, or N-" Drawings Required l D+- D No Inspection Drawings C, D, or N-Required , , 2.0 OPERATION 1 - l 2.1.0 Original Preparation of Piping or Hangers that Recuire Record Insoection Drawings as Outlined in Section 1.3.0 (Scoce) 2.1.1 The Piping Engineering Department will prepare the piping isometrics and hanger drawings. The content is covered by Field Construction Procedure 2-22. The Chief Piping Engineer will approve all drawings. A transmittal slip, see attached
KAISER ENGINEERS, INC. FIELD CONSTRUCTION PROCEDURES 2 - 24' , W. H. ZIP 14ER NUCLEAR POWER STATION
'; ONIT NO. 1, P.0 SCOW, OHIO 2" AND UNDER PIPING AND HANGER DWGS.
Page 4 of 5 Revision 2 Date 5/4/78 example, will be prepared for all original tracings that leave the Piping Department Document Control Clerk. 2.1.2 The original tracing will be passed to the Welding Department. The Welding Enginer will add and approve the proper weld procedure information for all welds that are shown. This I step may be delegated by the Construction Engineer to the
- Chief Piping Engineer.
I - 2.1.3 The original tracing is then passed to the QA Department. The QA Engineer will. review and approve all weld information and indicate the appropriate inspections to be: performed for all the welds shown. 2.1.4 The original tracing will be available to the authorized Nuclear
- Inspector who at his discretion will review weld date and i
indicate hold points as required.
, 2.1.5 The original tracing is then passed back to the Piping Dept.
Document Control Clerk to be distributed per Field Construction c~ Procedure 2-5 and QACMI #G-1. 2.1.6 The requirements for field revisions will be initiated by Field Superintendents or Field Engineers. Field revisions to 2" and under Pipe Class A, B, C or D< Piping shall be handled as outlined in Section 1.2.21 herein. 2.1.7 Final isometric drawings for Pipe Class A, B, C and D+ will be forwarded to S&L for further handling. 2.2.0 Original Preparation of Piping or Hangers that Do Not Reouire ! Record Insoection Drawings as Outlined in Section 1.3.0 (5coce) i 2.2.1 The Piping Engineering Department will prepare the piping isometrics and hanger drawings. The content is covered by Field Construction Procedure 2-22. The Construction Engineer will approve all drawings. . 2.2.2 Only piping that lends itself to pre-installation fabrication will be drawn before installation. These drawings will be designated construction aids and will have no inspection i purpose. , 2.2.3 The original tracing is then passed to the Piping Department Document. Control Clerk to be distributed per Field Construc-tion Procedure 2-5. 2.2.4 There will be no revisions on these drawings during erection unless requested by the Piping Superintendent for clarity.
4 - XAITER ENGINEERS, INC. FIELD CONSTRUCTI0ff PROCEDURES 2 - 2c kL H. IIP 14ER NUCLEAR POWER STATION i GNIT NO. 1, P.0SCCW, OHIO 2" AND UNDER PIPING AND HANGER DWGS. Page 5 of 5 Revision 2 Date 5/4/78
~
i 2.2.5 Piping Class D with non-essential hanger Class of C, D or N that is not detailed and located on the consulting
! engineer's S&L drawings shall be placed or revised on record drawings after installation, if deemed necessary by CG&E.
1
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i . c l 4 O e l 1 l l g l t
INV002/J DRAFT /np a [ 5.15.1 Allegation
" Employees fired for time [ card] cheating had been cheating with the express approval of management, and only time cheaters fired were vocal and knowledgeable critics of plant QA and safety."
5.15.2 Background Information i Investigation by Thomas Applegate revealed that several individuals were involved in " timecard cheating" by being absent from site work but recorded as at work. Those individuals involved were terminated. 5.15.3 Investigation 5.15.3.1 Interview of Individual A On February 24, 1981, Individual A, who was previously interviewed by ' representatives of GAP, was interviewed by NRC. Individual A stated Kaiser terminated his employment in January 1980 after Thomas Applegate uncovered irregularities in his timecard. He said he was not fired for his criticism l; of plant safety and it was not until after he was terminated that he pro- ' vided any information to GAP. Individual A said that, although he had i serious concerns about construction work at the plant, he was not fired by Kaiser for the reasons alleged by GAP. ; On April 24, 1981, Individual A provided a written statement attesting to the preceding information; however, he requested the statement not be attached to this report.
y INV002/J DRAFT /np 5.15.3.2 Interview of Individual B On April 14, 1981, Individual B, who was previously interviewed by representatives of GAP, was interviewed by NRC. Individual B stated that he would not characterize himself as a " vocal critic" of plant safety. He stated be had concerns about the QC program at Zimmer that he related to the RIII Investigator. However, he said he was fired for irregularities , in his timecard and not for his concerns about the QC program. I On April 22, 1981, Individul B provided a written statement attesting to the preceding information; however, he requested the statement not be attached to this report. 5.15.3.3 Interview of William Murray On April 14, 1981, William Hurray, Senior Engineer, CGE, was interviewed by NRC. He stated that from December 10, 1980 to January 4, 1981 , Thomas Applegate [ Confidential Service (CS)] was hired by CG&E to investi- ! gate alleged timecard irregularities at Zimmer. He stated CS entered into the contract with CG&E after Applegate told them he had uncovered evidence ; of employee timecard cheating. Murray stated the investigation was initially l contracted for a 30-day period. During that period, Applegate identified two guards and three construction personnel who were involved in timecard t cheating. Murray indicated that all five of the individuals Applegate ident-ifie'd had been terminated. He denied that the only individuals terminated were those who were vocal and knowledgeable critics of plant safety, and stated f emphatically that the individuals fired were fired solely for irregularities in their timecards. 2-
l
. . INV002/J DRAFT /np Murray also stated that Major W. Cox, Director of CS, felt that the.
investigation was compromised when Murray left Applegate's reports unattended in his desk. Murray said at that point the contract was endicg and he and Cox concurred.that timecard cheating was not widespread, Both ' agreed that, because of the questions about the security of the operation, the contract should be terminated. However, Murray said Applegate stated that he was concerned about the QA problems he had identified and wanted to continue. Murray said the concerns Applegate raised had already been identified by the QA group of CG&E and be saw no reason to continue the investigation. He said Applegate was adamant in hic insistence to continue the investigation, so he referred him to William Schweirs, Quality Assurance Manager. Schweirs agreed there was no need to investigate these matters further and advised Applegate of his conclusion. Murray said the contract was terminated with Cox's approval, but over Applegate's objections. Murray provided a letter from CS regarding the contract termination which is dated January 4,1980, and is appended to this report as Exhibit . 5.15.3.4 Interview of Major W. Cox _ On April 30, 1981, Major W. Cox, Director of CS, was interviewed by NRC. , i Cox stated he employed Thomas Applegate as a private investigatcr for CS. He indicated that in November 1979 when Applegate was investigating another matter, Applegate came across evidence of employee timecard cheating at Zimm'e'r . Cox stated he was reluctant to pursue the matter, but on s'everal' occasions Applegate approached both him and CG&E about this matter. Cox , s
s INV002/J DRAFT /np said Applegate continued to pursue the matter and CGLE formally requested CS to investigate the matter. Cox stated the investigation was initially contracted to last 30 days during which Applegate would work as an under-cover person onsite with the primary task of investigating employee timecard cheating. Cox said the CS investigation began on December 10, 1979 and ended on January 6,1980, and identified several employees who were involved in timecard cheating. Cox said the operation ran its course and was terminated at the end of the original 30-day contract period. Cox stated, that during the last weeks of the investigation, Applegate had said he found evide.ce of irregularities in pipe welds and in the plant QA program. Cox told William Murray about this and Murray said CG&E was already aware of the problems Applegate had identified and did not want to pursue them further. Cox recalled that Applegate had learned there was a disagreement between Peabody Magnaflux (PM) employees and CG&E over the interpretation of X-rays taken of some pipes on site. , i a Cox said there was no attempt by CG&E to cover up any of Applegate's dis-closures. Cox said it appeared to him that CG&E was already aware of the , _ problems Applegate identified and Applegate was not providing them with ' i _any new information. Cox stated that after the 30-day contract period both i i he and CG&E decided to terminate the contract. Cox stated Applegate dis- l agreed with this decision and wanted the investigation to continue so be
' f l
could pursue irregularities he had identified in the QA program. Cox said CGSf~ denied Applegate's request. l l .
.=
INV002/J DRAFT /np
- o. .s Cox said that, in his opinion Applegate held a grudge against CG&E for ending the investigation over his objections. Cox said that since January 1980 he has had no further contact with Applegate regarding the Zimmer investigation, and Applegate has taken custody of all of the tape recordings and' copies of reports he made during the investigation.
5.15.3.5 Record Reviews The Confidential Service memorandum dated January 4, 1980 authored by ' Major W. Cox, Director of CS, was reviewed by the investigator. The first paragraph of the letter addresses Cox's concerns about the security of CS confidential reports. The letter does not indicate that Cox objected to terminating the investigation. 5.15.4 Findings I j The employees interviewed by GAP were contacted by NRC. They denied they i - had been fired for any criticism of plant QA and safety, but rather had been fired for timecard cheating. - There was no indication that timecard cheating had management approval. ; Hiring of a private investigator to investigate condoned timecard cheating [ appeared unlikely. i i P t '
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5.15;5 Items of Noncompliance i t i No items of noncompliance were identified. i
Zimmer/np INV001/C e . i 5.10.1 Allegation
" Shock-absorbing electrical tray hangers previously found unsatisfactory i -
are still unsafe due to faulty welds, and electrical cable trays remain dangerously full." 5.10.2 Background Information 1 5.10.3 Investigation i l 5.10.3.1 Investigation of Previous Allegations 5.10.3.2 Observations and Reviews Concerning Cable Tray Hanger Welds The RIII inspectors made visual inspections of both vendor and field welds on the following cable tray hangers in the cable spreading room and blue switchgear room, and at an elevation of 473-ft. in the auxiliary building. The following data was noted for the cable spreading room: , 1. No. 14H11FECIA3--no unacceptable weld discontinuities D
- 2. No. 14H11FEC147--no unacceptable weld discontinuities
- 3. No. 4H2FEC193--no unacceptable weld discontinuities; foot connection covered with fireproofing
Zimmer/np INV001/C i
- 4. No. 15HIFEC160--covered with fireproofing
!. 5. No. 15HIFEC160--co unacceptable weld discontinuities; toot connection ; covered with fireproofing
- 6. No. 70HFEC165 (cross brace member No. 23HV5FEC294)--welds had irregular f
profile, porosity, and undercut i
- 7. No. 15H2FEC175 (second horizontal member from the top)--weld has undercut
- 8. No. 14H11FEC146 (cross member)--an apparent vendor weld has undercut and slag
- 9. No. 16 1FEC156 (weld marked rejected)--weld has spatter and undercut D
All of these welds were painted; therefore, the RIII inspector inspected for relatively large discontinuities only. The unacceptable welds identified on hangers 70HFEC165, 15H2FEC175, 14H11FEC146, and 16H1FEC156 were not controlled in any QA document. This is contrary to 10 CFR 50, Appendix B, Criterion XV, and the Wm. H. Zimmer QA Manual, Section 15, as described in Appendix A to the report transmittal
. letter (50-348/81-13-09).
The RIII inspectors reviewed approximately 180 construction inspection plans (CIPs) and inspection records for the hangers in the cable spreading Zimm:r/np INV001/C i
, room (elevation 536 ft. in the north section of the auxi'11ary building).
The licensee stated that the inspections documented on the CIPs also included the vendor welds, even though the records only reflected. field l welds. The vendor welds were inspected because repairs were necessary to close the 10 CFR 50.55(e) report (#E-5) telephoned to NRC on July 17, 1978. The 10 CFR 50.55(e) report indicated that vendor welds on the cable f tray hangers, which were used only in the cable spreading room, did not
! meet the visual requirements of AWS D1.1-1972. The CIP records and the 10 CFR 50.55(e) report indicated that all of the final field and vendor welds were reinspected after repairs were made to welds on more than half of the 141 hangers and accepted in December 1980 and January 1981.
No inspection records were available to indicate that in process inspections of either the field or the vendor welds were made to verify proper filler metal, weld procedure, welder's qualifications, surface conditions, etc., as required by the AWS DI.1-1972 code, Section 6. Certificates had been supplied by the vendor stating that the vendor material met the purchase specification requirements. The RIII inspector requested the licensee to obtain the in-process and field weld inspection records for the hanger l welds made by the vendor (Superstrut). A letter dated May 1, 1981 from Midland-Ross Corporation to CG&E was provided to the RIII inspector on June 1, 1981. The letter indicated that Superstrut was acquired by i Midland-Ross Corporation in January 1978, and that no records could be 1 l . located with respect to inspection reporting for the hangers supplied to Zimdbr. G l Zimmer/np IhV001/C i
., Discussions with the pertinent QC management and inspection personnel revealed that the welds documented on the above CIPs had been inspected f after having been painted. The licensee stated that the field visual examinations of the tray hanger welds were based on H. J. Kaiser Company Procedure No. SPPM 4.6, Revision 8, dated August 29, 1980, in Paragraph 5.1.3 which states, " Surface condition--joint surfaces to be examined shall be cleaned and free from slag, rust, are burns, paint, dirt, or other contaminants that would interfere with the examination." The licensee stated that paint (galvanox) applied to the hanger welds did not interfere with the visual examination and, in some cases, actually highlighted discontinuities. AWS D1.1-1972 code, Section 3.10.1 states,
" .. Welded joints shall not be painted until after the work has been completed and accepted...." ,
The apparent lack of in process and adequate visual inspections of the ' above field and vendor hanger welds is contrary to 10 CFR 50, Appendix B, Criterion X, and the Wm. H. Zimmer QA Manual, Section 10.1.2, as described in Appendix A to the inspection report transmittal letter (50-358/81-13-10). The RIII inspector requested the design acceptance criteria that was used by QC to evaluate the undercut on hanger 15H2FEC175. The licensee provided S&L Specification H-2713 Supplement 7, Standard EB-117 and H. J. Kaiser Procedure No. SPPM 4.6, Revision 8, Paragraph 5.2.9, which allows up to
.1/16-in. undercut on the cable tray hangers welds. The 1/16-in. criteria doesnot comply with AWS D1.1-1972, Section 3.6.4, which states, "for buildings and tubular structures, undercut shall be no more than b.01 inch
' Zimmer/np INV001/C
, 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."
Further review of Procedure No. SPPM 4.6, Paragraph 5.2, revealed other noted exceptions to the AWS DI.1-1972 code. These exceptions included fillet weld size and weld convexity. On March 5, 1981, S&L provided a documented investigation program of fillet weld size for P-W Industries cable pan hangers, purchase order No. 7070-25102. This program was performed by Gladstone Laboratory of Cincinnati to substantiate the design adequacy of the undersized fillet welds at the flare bevel joints of the cable pan hangers. The study was based on a sample of 95 welds cut from P-W cable tray hangers. The 95 welds were sectioned and etched to determine actual weld size and relative weld quality. Only one weld was identified as rejectable due to a lack of fusion. Although this study may justify that the weld size was adequate, where the weld penetration was not measurable by normal visual techniques, no justification was pro-vided to substantiate the exceptions to the AWS DI.1-1972 code requirements concerning weld convexity and undercut. These deviations from the AWS code are contrary to 10 CFR 50, Appendix B, Criterion III, the Wm. H. Zimmer FSAR, Table 3.8.2, and the Wm. H. Zimmer ! QA Manual, Section 3.3, as described in Appendix A to the inspection transmittal letter (50-348/81-13-11). The "following data was noted for the blue switchgear room hangers (eleva-tion 525 ft. and drawing E-96: -
Zimmer/np INV001/C j- : i l
- 1. No. 1H029--no unacceptable weld discontinuities i
- 2. No. SH25--foot connection covered with fireproofing; no visible
! unacceptable weld discontinuities
- 3. No. 5H30 (2)--no unacceptable weld discontinuities i
I l 4. No. 1H077--no unacceptable weld discontinuities e i i i
- 5. No. 1H079--no unacceptable weld discontinuities I
, 6. No. 1H133--no unacceptable weld discontinuities
- 7. 2 Nos. 5H19--no unacceptable weld discontinuities
- 8. No. 109HV4 (east and west sides)--had unacceptable weld discontinuities that were controlled on construction inspection plans (records)
- 9. No. 1H28-2--no unacceptable weld discontinuities l
- 10. No. 1H28-1--no unacceptable weld discontinuities l
l l
- 11. No. 1H29--no unacceptable weld discontinuities i
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l 12.* No. SH30--no unacceptable weld discontinuities [
- 13. No. 1H077--no unacceptable weld discontinuities l
Zimmer/np INV001/C 1
- 14. No. 1H133--no unacceptable weld discontinuities
- 15. No. SH19 (4)--no unacceptable weld discontinuities -
i
- 16. No. 5H3(12)--no unacceptable weld discontinuities
! 17. No. 5H2(12)--no unacceptable weld discontinuities
- 18. No. 5H25--No unacceptable weld discontinuities; foot connection
, covered with fireproofing. The following data was noted for elevation 473 ft auxiliary building hangers:
- 1. No. 5H009 (drawing E-91)--no unacceptable weld discontinuities
- 2. No. 4H3 (drawing E-14)--no unacceptable weld discontinuities
- 3. No. 2H1 (drawing E-14)--no unacceptable weld disc,ontinuities
- 4. No. 5H010 (drawing E-91)--no unacceptable weld discontinuities
- 5. No. 5H012 (drawing E-91)--no unacceptable weld discontinuities
- 6.
- No. 6H1 (2) (drawing E-14)--no unacceptaole weld discontinuities
- 7. No. 6H1 (1) (drawing E-14)--no unacceptable weld discontinuities
Zimmer/np INV001/C 4 Four to six welds were inspected on each of the above hangers. f Several of the tray hanger foot connections (where the hangers are attached
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to the structural beams) were covered with fireproofing and could not be i inspected. Therefore, the RIII inspector requested QC inspection documen-tation to assure that the weid:, covered by fireproofing, were acceptable. l The licensee provided a copy of Surveillance Report (SR) No. 2893 dated
- January 8, 1981, which stated that 94 of 179 cable tray hangers.in the cable spreading room have one or both foot connections covered with i
fireproofing. The SR requested clarification as to what QC should do ~ i since the foot connections had not been inspected. As of March 27, 1981, the SR had no disposition. This item is unresolved pending the resolution of the hangers identified in SR No. 2893 and any.other hanger connections throughout the plant that were covered before they were inspected (50-358/81-13-12). 5.10.3.3 Observations Reviews, and Interviews Concerning Cable Tray Loading The RIII inspector made field observations, reviewed and discussed site control measures, and reviewed and discussed the desing basis and verifica-tions regarding cable tray loading. Tray loading was considered in three aspects: cable ampacity or thermal loading; physical weight loading; and
,the commitments in the Zimmer FSAR Section 8.3.3.1.
- 1. The following cable tray routing points (nodes) were selected for the reviews and discussions:
Zimmer/np INV001/C 1 + i
- a. 10571- yellow division / power tray--selected because of the high design index, D.I. #1.44 (see paragraph 3 of this report section f for explanation of Design Index). .
l
- b. 2025A--blue division / power tray--selected because of the high D.I. #1.46.
i
- c. 2023A--blue division / power tray--selected for verification of D.I. # accuracy (D.I. #1.18).
, d. 2038A--blue division / power tray--selected because of the high
- D.I. #1.44.
- e. 2039A--blue division / power tray--selected during field observa-tions because of the appearance of being highly filled.
- f. 1073A--yellow division / power tray--selected for verification of the number of cables installed.
- g. 2086B--blue division / control tray--selected during field observa-tions because of the appearance of being highly filled.
- h. 1104B- yellow division / control tray--selected because of the high D.I. #1.54.
e e a- _- _.v.
Zimmer/np INV001/C
- 2. The RIII inspector and a licensee representative counted the cables in the following tray nodes and compared the counts with the number of cables listed in the S&L Cable Pan Loading Report, dated February 2,
, 1981:
l 1 Node Field Count Report Count 4 l j a. 1057A 27 27
; b. 2025A 24 23 i c. 2039A 39 39
- d. 1073A 32 33 The Cable Pan Loading Report is a computerized periodical that gives the design status of the cable tray loads. The Report identifies the individual cable numbers that have been specified to be routed through the segmented tray points (nodes).
The RIII inspector reviewed the H. J. Kaiser Cable Monitoring Report dated February 5,1981 and some cable pull (installation cards) to ( verify that the cables specified for tray nodes 1057A, 2025A, and 1073A in the Loading Report had actually been installed. For tray node 2025A, cable No. LL145 was found to be two individual conductors and, for tray node 1073A, the records indicated that cable No. VP210 had not been installed yet, which accounted for the discrepancies
*'between the above field and report counts. No other discrepancies were identified in either the design or installation reports and records for tray nodes 1057A, 2025A, 2023A, 2039A, and 1073A. Thus, the design and 1
Zimmer/np INV001/C installation records appeared to match the numbers of cables actually installed in the plant. 4 i -
- 3. The RIII inspector inquired how the computerized design index program correlated to the Zimmer FSAR Section 8.3.3.1 (dealing with ampacity) and Section 3.10.1.2.3.c (dealing with physical weight limitations).
I f
- a. FSAR Section 8.3.3.1 states the following:
8.3.3.1.1 In Trays 7 All power cables to be used in ZPS-1 are assigned in accordance with Table 8.3-18. The tables for power cable loading are absed on IPCEA Publication No. P-46-426. 8.3.3.1.2 Not In Trays The thermal ampacity of power and control cables with no part of their length in solid-bottom tray are in accordance with IPCEA P-46-426, with appro-priate rating factors applied for ambient, shields, and direct-current service. e
- e. .
e e
Zimmer/np INV001/C d
, 8.3.3.1.3 Fill l The summation of the cross-sectional areas of the .
cables shall not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the i cross-sectional area in any case. Conduit is sized in accordance with Sargent & Lundy j Standard EDSB-10, Electrical Drafting Reference for 4 Determining Conduit and Pipe Sizes, which limits i 4 conduit fill to the percentages established by the l National Electric Code. FSAR Section 3.10.1.2.3.c states, " Cable tray loading of 40 psf (pounds per square foot) is used throughout."
- b. On March 17, 1981 and March 19, 1981, the S&L Assistant Manager of Electrical Engineering described the correlation between the FSAR and the design index program as follows:
The power cable ampacity loading is based not on IPCEA P-46-426 1962, but on IEEE Paper 70TP557-PWR (by J. Stolpe) printed in 1970, IPCEA Publication P-54-440 1975, which was based on Stolpe's
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Paper, and S&L Standard ESA-104a (revised November 1,1972). e 4 l --- - _. . -
Zimmer/np INV001/C The Stolpe method bases ampacity on the depth-of-fill design of cables in the tray rather than on the percentage fill. S&L uses a 2-in. depth-of-fill as the basis for selecting a cable for a particular ampere load. I (1) The 2-in. depth-of-fill design results in a major conservatism because of the following: (a) Load diversity--many cables carry current only intermit-tently (e.g., valve operators, sump pumps, etc.). (b) Cable size granularity--only a few cable types and sizes are purchased, resulting in selection of over-sized cables for most services. This means many cables would be capable of carrying larger currents (rated) than those actually carried. (c) Design ampere margin--the design ampere loads used to select cables before the final equipment design data is known are necessarily conservative (high). (2) Because of the above conservatisms, the S&L design practices are as follows: (a) Cables are routed into trays without limiting 5ill. (b) The resulting fill is monitored as the design proceeds.
Zimmer/np INV001/C (c) When the fill reaches a target level, the actual heat load is calculated and, if the heat load exceeds the allowable amount, sufficient cables are removed from f the affected trays. i I To accomplish steps (2)(b) and (2)(c), S&L uses the design index program. The design index is a measure of tray fill and is expressed mathematically as follows: The sum of the (cable diameters)2 Design Index = Useable area of the tray where useable area (UA) equals tray width times design depth-of-fill (design depth-of-fill is based on square cables) and 50% of the tray cross-sectional area. For 24 in. x 4 in. power trays the total area equals 96 sq in. and useable area equals 24 in. x 2 in. equals 48 sq in. DI = (d2 ) UA where E = summation and l
- d = cable diameter This equation is consistent with the Stolpe method. " Percent Fill" is
-r.ot consistent with the Stolpe method because the depth of the tray is used rather than the depth of the cables in the tray. Percent fill is also based on the actual cable cross-sectional area rather than i
Zimmer/np LWOO1/C the square cable that is assumed in the Stolpe method. Expressed mathematically, Sum f cable cross-sectional areas x 100-Percent Fill = Total Cross-sectional tray area where the sum of cable cross-sectional areas equals E(pi x r2) 4
- with r = radius of the cable and pi = 3.1416.
l Thus, 2
+
Percent Fill = E (pi x r ) x 100 total area See Attachment A for DI and percent fill calculated for tray 2025A. The relation between design index and percent fill is therefore ' 2 E(pi x r ) x 100 Percent Fill , total area Design Index 2 E(d ) useable area Since the total area (TA) equals 2 times the useable area (UA) and d = 2 x r. 2 pg
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E[pi x ( ) ] x 100 2 4 E (d ) x 100 PF = 2(UA) _ 2
*- 2 2 -
E(d ) E(d ) . UA -
=fx100=39.3*.perDI
Zimmer/np INV001/C Thus, for a 4-in. deep tray: 39.3% Actual Fill = 1.0 Design Index = 2-in. design depth of fill (square cables) I, l 50% Actual Fill = 1.27 Design Index = 2.54-in. design depth-of-fill (square cables) 60% Actual Fill = 1.52 Design Index = 3.04-in. design depth-of-fill (square cables) and for a 6-in. deep tray: 39.3% Actual Fill = 1.0 Design Index = 3-in. design depth-of fill (square cables) Based on the preceding relationships between design index and depth of square cables, and the fact that S&L has used n 2-in. depth-of-fill as the basis of selecting cables for particular ampere loads, the cables in tray nodes with a DI over 1.0 would have to be re-evaluated considering the increased depths. This item is unresolved pending the completion of the re-evaluations (50-358/81-13-15). The above design bases for cable ampacity was a deviation from the FSAR
that was not identified on any control document. This deviat, ion is contrary to 10 CFR 50, Appendix B, Criterion III, and the Wm.' H. Zimmer QA Manual, Section 3.6 as described in Appendix A to the report trans-mittal letter (50-358/81-13-16) .
Zimmer/np INV001/C .i On March 17, 1981, the S&L Assistant Manager of Electrical Engineering stated that appropriate modifications to the FSAR would be submitted
,' to NRR. Also, specific consideration would be given to the differing i -
j J types of cable insulations, addressed in the publications (standards), when compared with the cable insulations used in Zimmer. i j 4. The RIII inspector reviewed S&L Instruction No. PI-ZI-10.1, Revision 0, i t dated February 6,1978, Paragraph 4.5 which states, "The Senior Elec-
; trical Project Engineer chall assign an electrical engineer to run j thermal loading calculations for all power tray routing points with ; a design index exceeding 1.25. He shall compare these loadings, in watts per feet, with the watts per feet limits established for the design indexes involved."
The RIII inspector requested the thermal calculations for tra'y nodes 2025A, 1057A, 2038A, and 2927A that had dis in excess of 1.25. S&L provided calculations for nodes 2025A, 1057A, and 2027A. These calculations that were performed in 1978 and 1979, had not been reviewed or approved. S&L described these as interim calculations, which would have to be redone after all of the final electrical loads in the plant were established and defined. Thermal calcu-lations had not been performed for tray node 2038A. S&L provided a controlled list (Attachment D) dated February 24, 1981
of 37 routing points (nodes) with design indexes over 1.25 for the Zimmer plant. Thirty-four of these tray points exceed for 56% tray fill requirement specified in the FSAR, Section 8.3.3.1. Tray nodes
Zimmer/rp INV001/C
\
. 1104B and 2025B also exceed 60% fill. The S&L Assistant Manager stated that thermal calculations (both allowable and actual) will be performed in the near future for all power trays .with a DI over 1.25, including those on Attachment D. These calculations will be provided to the NRC, Region III. This item is unresolved (50-358/81-13-17).
- 5. Niether S&L Instruction No. PI-ZI-10.1, Revision 0, nor any other document established controls to verify the thermal loading power cable (penetration) sleeves and the physical (dead weight) loading of trays (power, control, and instrument).
- a. The Cable Pan Loading Report included the design indexes of sleeves. Sleev #SL111 had a reported DI of 1.29 and sleeve
#SL105 had a reported DI of 1.26. A controlled list of powers sleeves with a DI over 1.25 was not maintained.
- b. S&L stated that a design index of 1.25 would be used as the factor to determine when calculations would be performed for physical (dead weight) loading. .
The lack of design control measures to verify the adequacy of the l thermal loading of power sleeves and the physical loading of trays is l _ contrary to 10 CFR 50, Appendix B, Criterion III, and the W m. H. Zimmer QA Manual, Section 3.11.2, as described in Appendix A to the report
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l transmittal letter (50-358/81-13-18). . i . i l _ _
Zimmer/np INV001/C i . S&L revised Instruction PI-ZI-10.1, Revision 1, Sections 4.5, 4.6, and 4.7, on March 18, 1981 include requirements to verify and control the thermal loading of power sleeves and the physical loading of.all trays I (power, control, and instrument) that have a design index over 1.25. 1 S&L stated that calculations for the physical 1 cads of all power, control, and instrument trays, and for thermal loads of all power sleeves, with a design index over 1.25, will be performed in the near j future. These calculations will be provided to NRC in Region III. i 4 The RIII inspector requested the justification for using the design index program for the determining factor for physical loads since the design index program had absolutely no technical relation to physical weight. The RIII inspector also requested justification for using the design index of 1.25 as the determining limit for performing design calculations. S&L stated that both of the justifications would be provided to NRC in Region III. This item remains unresolved (50-358/81-13-19). l _
- 6. The RIII inspector observed a note on the bottom of the thermal calcu-lation sheet dated December 27, 1979 for cable tray #1057A. The note l
indicated that two cables "#VC016 and VC073 are overloaded." The noted j , overloaded cables were not identified on any control document that i would have required appropriate evaluation and disposition. The S&L
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personnel stated that a control program did not exist for such design deviations. This is contrary to 10 CFR 50, Appendix B, Criterion III, and the Wm. H. Zimmer QA Manual, Section 3.6, as described in Appendix A to the report transmittal letter (50-358/81-13-20). Zimmar/np INV001/C e
- 7. The RIII inspector performed the following physical weight tabulation of yellow division control tray #1104B.
t . Table A. Weight Tabulation Cable Cable Cable Weight Cable Cable Cable Weight i No. Weight (Ib/ft) No. Weight (Ib/ft) i i AP079 12126 .622 PC013 07126 .342 AP080 12126 .622 RE055 02126 .146 AP081 12126 .622 RF128 02126 .146 AP166 12126 .622 VA018 10126 .583
. APIC7 04106 .316 VA019 02126 .146 AP168 04106 .316 VA020 02126 .146 AP170 12126 .622 VA024 02126 .146 AP171 04106 .316 VC023 07126 .342 AP172 04106 .316 VCO24 07126 .342 AP482 12126 .622 VC025 07126 .342 AP504 04106 .316 VC062 10126 .583 AP505 04106 .316 VC119 10126 .583 AP508 04106 .316 VC120 10126 .583 AP540 04106 .316 VC121 10126 .583
AP541 04106 .316 VC122 07126 .342 AP542 04106 .316 VC123 07126 .3b2
is Zinsner/np INV001/C Table A (continued) Cable Cable Cable Weight Cable Cable Cable-Weight
; No. Weight Weight (lb/ft) No. (1b/ft) ' I.
AP762 04106 .316 VC127 02126 .146 CM011 10126 .583 VC230 04126 .245 DG022 12126 .622 VC265 07126 .342 DG028 12126 .622 VD014 12126 .622 DG084 12126 .622 VG020 12126 .622 DG185 07126 .342 VG028 10126 .583 INO32 12126 .622 VG032 10126 .583 IN035 12126 .622 VG081 10126 .583 INO38 12126 .622 VG082 12126 .622 LC011 10126 .583 VG084 10126 .583 LC015 12126 .622 VG085 10126 .583 LC019 12126 .622 VG152 04126 .245 LCO22 12126 .622 VG170 04126 .245 LCO25 12126 .622 VG171 04126 .245 LC029 12126 .622 VH030 12126 .622 LC033 12126 .622 VH040 04126 .245 LC036 12126 .622- VP022 12126 .622 LC040 12126 .622 VP030 12126 .622
*I.C044 12126 .622 VP050 12126 .622' LC047 12126 .622 VP057 02126 .146
Zimmer/np INV001/C Table A (continued) Cable Cable Cable Weight Cable Cable Cable Weight i i No. Weight (1b/ft) No. Weight (lb/ft) i LC051 12126 .622 VP132 12126 .622 i R LC055 12126 .622 VP136 12126 .622 LC057 07126 .342 VP144 12126 .622 LC060 07126 .342 VP148 12126 .622 LC062 07126 .342 VQO14 10126 .583 LC064 07126 .342 VQO22 02126 .146 LL192 02126 .146 VQO30 12126 _ .622 NB200 04126 .245 VQO31 12126 .622 NB202 04126 .245 VQ082 07126 .342 NB210 04126 .245 VQ083 07126 .342 NB228 04126 .245 VQ084 07126 .342 NB229 04126 .245 VR030 12126 .622 NB230 04126 .245 VR058 07126 .342 i NB231 04126 .245 VX019 12126 .622 . NB232 04126 .245 VX051 07126 .342 i NB233 04126 .245 VX052 07126 .342 NB234 04126 .245 VX072 04126 .245 l NB235 04126 .245 VX128 02126 .146
NB236 04126 .245 VX156 02126 .146 NB237 04126 .245 VX130 02126 .146
u d' Zimmer/np INV001/C
, Table A (continued)
Cable Cable Cable Weight Cable' Cable Cable. Weight No. Weight (1b/ft) No. Weight (lb/ft) i NB238 04126 .245 VYO14 07126 .342 NB239 04126 .245 VY015 07126 .342 NB254 04126 .245 VY019 12126 .622 NB258 04126 .245 VYO27 12126 .622 NB261 04126 .245 VYO39 04126 .245 l l NB265 04126 .245 VYO43 04126 .245 NB269 04126 .245 VY056 07126 .342 NB271 04126 .245 VYO57 07126 .342 NB272 04126 .245 WR011 12126 .622 NB273 04126 .245 WR013 12126 .622 NB275 04126 .245 WR016 12126 .622 NB276 04126 .245 WR019 12126 .622 l NB277 04126 .245 WR022 12126 .622 NB279 04126 .245 WR025 12126 .622 NB285 04126 .245 WR028 12126 .622 NB286 04126 .245 WR048 02126 .146 NB287 04126 .245 WR070 04106 .316 NB288 04126 .245 WR071 04106 .316 l l
- NB289 04126 .245 WR077 02126 .146 NB290 04126 .245 WR082 02126 .I46 I
23 -
Zimer/np INV001/C Table A (continued) l Cable Cable Cable Weight Cable Cable Cable Weight j No. Weight (Ib/ft) No. Weignt (Ib[fft) I 1 1 'l
, NB291 04126 . 245 WR087 02126 .146 ND292 04126 . 245 WR127 07126 .342 NB297 04126 . 245 WR129 10126 .583 NB299 04126 . 245 WS140 04106 .316 NB301 04126 . 245 WS141 12126 .622 NB302 04126 . 245 WS142 07126 .342 NB303 04126 . 245 WS143 02126 .146 NB304 04126 . 245 WS144 07126 .342 NB305 04126 . 245 WS145 02126 .146 NB306 04126 .245 WS210 12126 .622 NB307 04126 .245 WS212 12126 .622 NB308 04126 .245 WS213 12126 .622 NB309 04126 .245 WS215 12126 .622 NB310 04126 .245 WS216 04126 .245 NB316 04126 .245 WS217 04126 .245 NB317 04126 .245 WS218 04126 .245 NB318 04126 .245 WS222 04126 .245 NB319 04126 .245 WS313 03091 .326
NB334 04126 .245 WS316 07126 .342 TOTAL 73.06
- ~ -
Zimmer/np INV001/C e Since tray 1104B is 2 ft x 6-in., then the total weight of the cables for tray 1104B is i 1 73.06
= 36.53 lb/ft2 i
1 1 4 l Therefore, tray 1104B (DI 1.54) is in compliance with the FSAR, Section 3.10.1.2.3, which allows up to 40 lb/ft2, l I
*The RIII inspector verified the cable weights for type 03091, 04106, I and 12126 with the following manufacturer's data:
i 03091--Okonite Proposal Data for S&L specification 2160B dated December 21, 1973 04106--0konite Bid Quotation dated October 23, 1973 12126--Okonite Proposal Data for S&L specification H-2161 dated + May 22, 1974. 5.10.4 Findings The allegation that electrical tray hangers are unsafe due to faulty welds is unresolved pending (1) additional inspections of hanger welds, which will
.be made after paint and fireproofing have been removed, and (2) establishment of the weld quality of those welds for which in process inspections were not performed and for which inspection criteria deviated from the AWS Code requirements.
[ .
+, -
I
', s Ziscer/np INV001/C
,. o ; '
~
I
- l. ,
t
. Theallegationthatelectricalcabletraysassaindanierouslyfullis unresolved pending the completion and review of tray-16eding i
calculations
.i . ,
for several tray-routing points; reevaluatkcas of; cable f. elections; estab-lishment of the actual design basis and verification measures for cable. ' j tray loading; establishment of design messiires to rerify the thermal loading f of power sleeves and the physical lording of trays; and establishment' of' s
- measures to control design deviations. '
/
Six items of noncompliance were identified. j , h 5.10.5 Items of Noncompliance d i . i
- I
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.t No items of noncompliance were observed. ','
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1 -. I Allegation 12 "A design flaw in the heat exchanger control panel permitted an operator
, mistakerly to force 1200 pounds of pressure through pipes only meant ./ . '
to handle 300 pounds, ripping the pipe and soaking electricians with [ a .' i a haid spray of water that would have been radioactive had the plant 4
' 1
'been in operation."
,/
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, I,I finding <
hit'(h.ome.
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./ ,
t JII Investigation A. . Background Information i 4/'i/ W B. Personnel Interviews t Interview with Individual "A" i i i
~ .
.On April 22, 1981, Individual "A" who was previously interviewed I by representatives of GAP was interviewed. Individual "A" stated he recalled an incident when the heat exchanger control panel was ,
1, pressurized with 1200 pounds of pressurized water when it was only ne j M +
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DRAFT /db meant to handle 300 pounds. He said he learned that high pressure water entered the low pressure system and ruptured pipes in the low pressure system. He said two electricians in the area were doused with water when the pipes ruptured. He also said other plant employees said this incident occurred because an operator apparently failed to turn off a valve which allowed high pressure water to enter the low pressure system. On April 22, 1981, Individual "A" provided a written statement attesting to the aforementioned information; however, he requested the statement not be attached to this report. Interview with Individual "B" On April'14, 1981, Individual "B" who was previously interviewed by representatives of GAP was interviewed. Individual "B" stated alrA4 I he recalled an incident when the a4fe air injector condenser on j the ground floor of the turbine building was injected with high i pressure water instead of low pressure water and the pipes in l the condenser ruptured. He said other workers in the plant told him this occurred because an operator failed to close the high ; i i pressure valve and the high pressure water entered the low pres-
.. sure system which ruptured the lines. !
On April 24, 1981, Individual "B" provided a written statement f attesting to the aforementioned information; however, he re- ! quested the statement not be attached to this report. i ( ' l - i
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- 7. Plant Tour , s .
The inspectors condu ted tours of vari us areas of t e plant to obse ve activities in progress, genera housekeeping and clean- ' lines , and equipment aution safety an or green preoperational ,- testin tagging. The t urs revealed tha : J-a
- a. The enclosed area o the spare and 1 125VDC batter chargers, ~
whic have been turn over for preope ational testing, was ' clutt red with debris. Brooms, general trash, metal grating, , hard h ts and a weldin oven (PL-5) sur unded the IB attery ' charger within the wood . barricade.
- b. The spare 125VDC battery arger had one o its side pane s missing. ieces of insula on and concrete chips and hea' -
dust deposi s had settled o o the internals of the spare ' charger. It was noted by th licensee's staf that the panel had beeg missing at lea since the char ers had been turned over fo preoperational esting in Octob r 1978. N Startup Manual proce ure SU.'ACP.16 "E ipment and Buil ing Cleanlin ss" m requires in Section 5 2 that all safet related equipm t shall be maintained free of xcessive oil, va r or other mat ial which c'ould prevent the equipment from p rforming its in ended , safety function. The li ensee has failed to follow the S rtup Manual prohedure SU.ACP.1 . This failure follow proced res is contrary to he requiremen V, and is con dered to be of 10 CFR 50 A endixB,Critefon example of an em of noncompli nee (358/79-06-06A of the in action level. '
- 8. Overpressurization of Low Pressure Core Spray and Condensate Systems Piping l The inspector reviewed the event of January' 19~, 1979, during
! which high pressure core spray (HPCS) water entered the conden-i sate (CD) and low pressure core spray (LPCS) systems because I
I valves 1E22-F003 and F031 had been lef t open causing a rupture of the steam jet air ejector condenser l A. ' The review consisted of , interviews with testing and operating personnel and a review of the licensee's final report on his investigation of the event. dP - The review showed that:
- a. Procedure OP.HP.01-4, Revision 0 was used to lineup, fill i and vent the HPCS system.
f l b. At the completion of the fill and vent operation the operator I never completed Step 5.1.5 which required him to close l valves lE22-F003 and F-31. With these two valves open the CD and HPCS systems became crosstied thru the cycled condensate j (CY) system. The operator claims he informed the Shift l i
* ~
h k _ 5
- 5- .
.. 4 V:$i G. 5 O 9 j i fr.
1 Supervisor that he had left the two valves open while the latter does not recall being told. This failure to follow $;': procedures is contrary to 10 CFR Part 50, Appendix B, Criterion ,
.Cj V and is considered to be an example of an item of noncompliance (,.
- 9. .
(358/79-06-06B) of the infraction level. 5".
- c. For some unknown reason, valve IE21-F025 which had been Q safety tagged closed under Switching Order No. 781317, dated h November 16, 1978, was in the open position. This completed t .;-
the cross connection of the LPCS and HPCS systems. Violation u of Switching Order No. 781317 is contrary to 10 CFR 50, .$ Appendix B, Criterion V and is considered an example of an 9 item of noncompliance (358-79-06-06C) of the infraction l level. The switching order was cleared on January 24, 1979. " .T The corrective action which the licensee is currently taking j; regarding a previous noncompliance with the safety tagging _j procedure (358-19-01-01) is also applicable to this event, y therefore the inspector stated no response to this item of noncompliance is required. Paragraph 13.0 of Safety Tagging Procedure EC. SAD.02, Revision 'p-d. 00 allows for the operation of equipment for test purposes ~ d without the removal of the safety tags. It is possible that valve 1E21-F025 was operated for test purposes thru tags and , subsequently left open by error. The inspectors have objected e to Paragraph 13.0 of the Safety Tagging Procedure. - Od March 21, 1979, the licensee issued operating memo 79-2, - Revision 9, which specifically requires that "Do Not Operate" tags must be removed before energizing electrical equipment i or opening valves. An exception is made in the case of
- electrical testing conducted by EOTD in which case only the ,
EOTD master tag will be lef t in place. ,
- e. On December 12, 1977, a General Electric system engineer '
recommended that a check valve be installed on line 1HP18A3 Jownstream of valve 1E22-F031 because a similar overpres-surization of a small section (up to valve 1CY013) of low I . pressure piping had occurred. The recommendation was re-jected because the licensee thought that two valves (1E22-F003
- and F031) plus adminstrative controls were sufficient to prevent recurrence. The licensee stated the check valve will be installed. All other ECCS systems have check valves
- in the line from the CY system. ,
The inspector stated his concern regarding repeatable occur-rences where a lack of communication or understanding between ' f parties have resulted in damage to equipment. It is our !
- intention to closely monitor the licensce's performance during the preoperational test program to determine the 9.-
L 'Y&iOI :.,WlliiK@?N.V$5'ki'f
$2f
-39&@E41-h $=h h%Q.QhCQQb $$f,y-Q(p*?Lil5D.UEF"YS??S~W C:p p p -
the adequac'y of plant staffing and training as fuel load I da:.e approaches.
- 9. F1'ooding of LPCS/RHR-A Pump' Room Event Th inspectors reviewed the event whi h occurred on March 17, 197 , involving the LPC [RHR-A pump ro m. The inspectors nter-viewdconstructionandgperationspersknnelinvolvedinthy '
event and reviewed the o rations and su ft engineering logs. The re iew revealed that: L
- a. On March 17, 1979, fl shing was being conducted on the f el -
poo cooling and clean p system. The icensee normally ., flus es to the suppres ion pool. The s ppression pool va unav- ilable due to modi ications. This lush was to the clean up phase separato tank which was 1 ned up to the I react building equipme t drain tank for overflow.
- b. At lunc time the engineer in charge of the ~ lush told the -
pipe fit ers working unde him to close the alves to secure flushing nd break for lun h. The valves we e not closed to stop the lush. Water ove lowed from the re ctor building equipment rain tank and in o the corner room hich contained the RHR-A, PCS and jockey p mps and its assoc ated instruments and valves or the LPCS syst m as well as the R-A system. The configu tion of the corn r room is such tha it will act as a poo up to approxima ely five feet. Wh water was I discovered fl wing out of this corner room into t e annular area at the b e of the wetwell the uncontrolled f ush was, terminated by losure of the va ves from the conde ate : storage tank su ply. The sump p mps in the RHR-A a d LPCS pump room had,b en out of servic due to maintenance LPCS ' i I system has been urned over for p eoperational testi . i l Trie licensee indi ated that all in trumentation invol d in he flood of the IR-A/LPCS pump to m would be dried, leaned inspected and reca brated. Restor tion of the instrum n-tahion had already egun while the i spectors were on s te. < The licensee also in icated that the ethod of using ava lable l l sto ge tanks for de osition of flush ng waters would no be ; l cont ued due to the roblems experie ced. The licensee id ; not, owever, indicate what methods wo ld be used during t e [
~
time t at the suppress n pool was not vallable. This eve t, as well as o hers experience by the licerisee in recentmothsareconsideedtobeexampisofpoorcommunica\ ions ,
\
l experience during operati n of systems fo testing and flushing. he inspectors i dicated to the icensee that a ! need for dev loping better c p unications ex sted. This is
^
considered to be an unresolved
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['~ (0 pen) 10 CTR 50.55e Report:
/
ejector heat exchanger (tube side).Overpressurization of the steam The inspector established jetaair that
- check2,valve March 1979has been installed as stated in the licensee's report dated (QA-1106).
( by NRC RIII Operations Branch,This item remains open pending further review ' E d fs/sr f i
~~B- 2 R pc.pe-r Y a**$5 i .f (Closed)
(tube side).Over pressurization of the steam jet air ejector h NR number 7247R1, dated February eat exchanger 21, 1979, stated that over The A-E (Sargent dispositions as follows: and Lundy) analyzed g the on topiping others. system valves with 1. below yield point. Carbon steel piping 3/4" up to 12" acceptable since str ess was well 2. The one stainless steel 3/4" pipe is likewise o .k. ' 3. Six hundred only being apound repeatvalves hydroare acceptable with the pressure experienced test. , 4. Three bundred pound and 150 pound valves the manufacturer should be consulted. 5. n The relief valve causing the problem should be retested and reset. Turther information available (Construction Engineering Report dated April 14, , 1979) stated that the valve manufacturers recommended a seat leakage test be conducted on the valves and that this test wasi performed without any leaks being detected and it further stated that the relief valve had been removed, tested and October 25, reset 1979.of set points done. The NR was signed as completed on regarding this item.The inspector indicated that he had no further questions . i gy;< T A .#& X. Py * *
.- (Closed) Noncompliance (50-358/79-06b). Failure to follow OP.HP.01-4 ,
i valve lineup. (Not closing valves IE22-F003 and IE22-F031.) The '
, inspector reviewed the licensee's action to prevent further non-adherence to procedures and found them acceptable. ~
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ZIMM/IC DRAFT /np 8/13/81 i
, Appendix , NOTICE OF VIOLATION
- AND l
PROPOSED IMPOSITION OF CIVIL PENALTY l Cincinnati Gas and Electric Company Docket No. 50-358 W. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 I EA No. 81-As a result of the investigation conducted at the W. H. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - July 14,1981, the violation listed below with multiple examples was identified. g numerous examples of the violation demonstrate a significant deficiency u t ay l ed __t o d e t e r t3 in the implementation of your quality assurance program Th'a's breakdown ofyour,fqual(tp and'f f'ds6 assurance program was widespread ' pd .d;-tcd u .. ..y c..,... 6 co'firmation n program
+heO;; ;'hiu'ne'e2'.foc-th'e u .. 'eidien'si{egu'al'ity *itWsafety-related faitdet,ed-by-y*odTo)YoYdeconfidenc structures, systems, and components will perform satisfactorily in service.
Because of the safety significance of this quality assurance program breakdown, in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the Nuclear Regulatory Commissica proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-;95, and 10 CFR 2.205 in the amount set forth for the violation listed below. Based vu a.4cepc,tivu ,f--appco timate.1r2; .,imet el Lc.u.. maied - -- th me-Swi.t.chgeer--Reem snd ihMable-Spreading-Room, ;he itenuih a uivu J-tha. ~ meter 4a4 -ia O mf these-betim; -o. uct me uiained Lu c.able verdimanen-es
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9x me\ ear pegbh 10 CFR 50, Appendix B, Criterion II requires holders of construction permitsA to document, by written policies, procedures, or instructions, end a quality assurance programtwhich complies with the requirements of Appendix B\and to implement that program in accorcance with those documents. Contrary to the above, the licensee and Kaiser Engineers, Incorporated, did not adequately document and implement a quality assurance program which com-plied with the requirements of Appendix B as evidenced by numerous examples of,(' noncompliance as follows: i hc< , ,t-, c.n rA .Ly _r...s.. 9 g O, t , u. , s .
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, ZIMM/1C DRAFT /np 8/13/81 e
Appendix a
! A. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall i be established for the identification and control of materials....
These measures shall assure that identification of the item is
.. maintained.... These identification and control measures shall be designed to prevent the use of incorrect or defective materials, parts,
]
, components."
l l The Wm. H. Zimmer QA Manual', Section 8.2 states, in part, "Identifica-l tion and control measures are established to prevent the use of incorrect i or defective materials. ..H. J. Kaiser Company procedures provide that i within the H. J. Kaiser Company jurisdiction the identification of i items will be maintained by the method specified on the drawings, such l as heat number, part number, serial number, or other appropriate means. i This identification may be on the item or on records traceable to the item. The identification is maintained throughout fabrication, erection, and installation. The identification is maintained and usable in the operation and maintenance program."
- 1. Based on an inspection of approximately 25 structural beams located in the Blue Switchgear Room and the Cable Spreading Room, the identification of the material in 9 of those beams was not maintained to enable verification of quality.
- 2. Based on an inspection of the supporting systems (i.e., cooling water, starting air, and fuel oil) for Diesel. Generators A and C, the identification of the material of 12. pipe pieces in those systems was not maintained to enable verification of quality.
(The Diesel Generator supporting eystems were selected for review because they were part of the only ASME Code Data Package which had been final accepted by Kaiser Quality Assurance. The discrepancies identified by the inspector were not identified by the final Kaiser QA review.) B. 10 CFR 50, Appendix B, Criterton XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as
~
failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and cor-rected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." The Wm. H. Zimmer QA Manual, Section 15.2.2 states, "HJK is respon-sible for identifying and reporting nonconformance in. . . construction. . . activities which are delegated to HJK."
~
The Wm. H. Zimmer QA Manual, Section 16.5 states, in part, " Vendors, ,
contractors, and subcontractors are required to determine cpuse and corrective action to prevent recurrence of errors which could result in significant conditions adverse to quality."
, , ZIMM/IC DRAFT /np 8/13/81 Appendix ,
l AWS Code DI.1-1972, Sections 3 and 3.1.5 define 7 requirements for -
! P weld quality and addressee slag, weld profiles, blowholes, porosity, and undercut. -
AISC, Seventh Edition (1969), Page 4.113, requires 1/2 inch minimum radius for re-entrant corners. SQ' f Contrary to the above, the NRC inspectors identified the following i F . nonconforming conditions that either had not been identified and corrected by the licensee or action to preclude repetition had not i been taken: I
- 1. Based on an inspection of the 25 structural beams described in Item Adabove,
- a. c e:s.
Of approximately 75 beam welds inspected, welds in oneAareac on each of 9 beams did not conform to AWS D1.1-1972 require-ments in that they contained unacceptable slag, weld profiles, blowholes, porosity, and/or undercut.
- b. Five beams did not conform to AISC requirements in that they had notches for re-entrant corners instead of radii.
- c. Four beams, 2 of which had unacceptable welds as described in Item B.I.a above, did not conform to design documents in that they were not specified on any design document. There were no QA records related to the 2 beams which appeared to have acceptable welds. .
- 2. Based on an inspection of about 100 cable tray hangers in the CableSpreadingRoom,$didnotconformtoAWSDI.1-1972 requirements in that they contained unacceptable slag, weld profiles, blowholes, porosity, and/or undercut.
- 3. Five licensee QA audits (audit performeil 8I8-9/79 - no number, and Audit Nos. 78/07, 78/09,,7Qf,1 Q 0/04) of Sargent & Lundy identified repetitive problems 4 rekted te S&L not performing i
certain design calculations, reviews, and verifications and action was not taken to preclude repetition.
- 4. The licensee identified that the socket engagement for more than
' 400 socket welds was not verified in accordance with ASME Code, Section III-1971 E.Tdjtion, Article NB-3661.5(b) and the condition was not corrected in that the corrective action was not commen-surate with the ASME Code. The corrective action was to radiograph 20 of the socket engagements and then accept the remaining 380 based on those radiographs. The welds dated back to 1979. '
ZIMM/IC DRAFT /np 8/13/81 Appendix j S. The licensee identified that the inprocess inspections.for more than 24 welds in the Diesel Generator cooling water, starting air, and fuel oil piping systems were not performed by Kaiser in l accordance with ASME Code, Section III-1971 Edition, Article j NB-3661.S(b), et. al., and the condition was not corrected. 1 I C. 10 CFR 50, Appendix B, Criterion XV states, in part, " Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked l in accordance with documented procedures." Kaiser Procedure QACMI G-4, " Nonconforming Material Control," provides detailed instructions for the review and disposition of reports (Noncon-formance Reports) of nonconforming items. Procedure QACMI G-4 contains the following requirements: l Paragraph 3.3 - Requires QA Site Document Center NR Controller to log NRs generated by QC Inspectors or Quality Assurance Engineers in the Site Document Log and assign NRs a KEI Control Number (CN). Paragraph 3.6 - Restricts voiding of NRs to those initiated in error or those relating to nonconforming conditions which have been corrected by the Construction Department after verbal or i written communication from the QA Department. Requires an explanatory entry for voided NRs be made next to the CN in the Site Document Log. Requires a copy of voided NRs be retained in the Site Document Center. Paragraph 4.1.2 - Requires the di position of NRs be categorized as " Rework" when the NRs require reprocessing to bring the non-conformance into conformance with specification requirements. Paragraph 4.3 - Requires Material Review Board action for NRs dispositioned " Accept-As-Is." Contrary to the above, of the approximately 100 NRs reviewed, the following deficiencies in the review of nonconforming items were identified:
- 1. An NR initiated by a QC Inspector February 3,1981, regarding the violation of a QC " Hold" tag attached to a suppression pool liner plate did not have a KEI CN assigned. CN-5412 was initially assigned to this NR but CN-5412 was subsequently reassigned to another unrelated NR without the NR originally assigned CN-5412 being assigned a replacement CN. References in the Site Document Log to the original NR assigned CN-5412 were covered over with "Wite-Out", a copy was not retained in the Site Document Center, and the NR was deleted from the NR control system. The NR had not been stamped " Void." (The copy of the NR reviewed by the investigator was provided by an alleger.)
n I {
ZIMM/IC DRAFT /np 8/13/81 Appendix i i
! 2. An NR initiated by a QC Inspector February 11, 1981, regarding i
' excessive weave in a primary containment structural steel weld did not have a KEI CN assigned nor was it entered in the Site Document Log. The NR was simply never entered into the NR control system. (The copy of the NR reviewed by the investigator was provided by an alleger.)
- 3. The following NRs were voided yet they had not been initiated
, in error nor did they relate to nonconforming conditions which j had been corrected by the Construction Department: i ! E-1661 E-2233 i E-1662 E-2466 I E-1777 CN-4389 i E-2191 E-5108 CN-2196 CN-5122 1
- 4. Copies of the following NRs were not retained in the Site Document Center:
CN-4930 CN-4958 CN-4931 CN-4959 CN-4955 CN-5476 CN-4956 CN-5477 CN-4957 CN-5479 o (The copies of the NRs reviewed by the investigator ware provided by en alleger.) ,
- 5. NR E-2996, Revision 1, which was categorized as " Accept-As-Is" was closed out March 17, 1981, without Material Review Board approval in that final disposition action (UT of T-Quencher No. 007) which was part of the basis for conditional approval by the Material Review Board was not takens
- 6. NR E-2836 was incorrectly categorized by the KEI Construction Engineer as " Accept-As-Is" when sufficient information had been provided by the KEI QA Engineer to clearly indicate the NR should have been categorized as " Rework" in that reprocessing (radiography of the final weld) was required to bring the weld into conformance with the requirement of ASME Section III and Kaiser Specification H-2256.
This matter is repetitive of similar violations identified in Inspection
.. Reports 50-358/80-05 and 50 358/80-25. (The improper action on CN-5412, CN-5476, CN-5477, CN-5479, E-2996, and the NR identified in. Item 2 above occurred after corrective action (Stop Work Order 80-13 and revision of Procedure QACMI G-4) was taken in response togInspection No. 50-358/80-35.)
TE
DRAFT /np 8/13/81 ZIMM/IC Appendix , i D. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis...are translated into... drawings..." i j The Wm. H. Zimmer FSAR, Section 8, provides the design basis for electrical cable separation which includes the following: i Associated cables (Green /khite, Blue /khite, and Yellow /khite) from more than one Division can not be routed in the came 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) nstrument 4]same raceway with(low-level signal) power and cables control cannot cables. be routed in the (FSAR Paragraph l8.3.1.23.1.3) 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 as--acteT e above for electrical cable separation had not been translated into the drawings which governed the following cable installation deficiencies in the Cable Spreading Room:
- 1. Associated Cable (Yellow / White) No. RE053 for Division I was routed in the same raceway (two inch conduit and Class IE Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2.]
iated Cable RE053 for Division I was routed such that there was only a vertical separation of four inches between it and cables (Blue) in Tray No. 2072C for Division 2.
- 3. Instrument Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Associated Control Cables (Blue / White and, Yellow / White) for Divisions 2 and 1. (ThEie deficiencyesifari.fatiy EEulted-from a design which specified the installation of a Green tray inside a khite tray.)
- 4. Associated Cables for 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.
,i
l', ZIMM/IC DRAFT /np 8/13/81
!' Appendix The above installation deficiencies were noted during brief, tours of the Cable Spreading Room while pursuing other unrelated matters.
1 E. 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 j inspections and tests." l Weld acceptance criteria are required by the ASME, Section III-1971 l and AWS DI.1-1972 Codes. Contrary to the above:
- 1. 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.
Y Vg 2. The acceptance criteria for a weld performed on Service Water pf j System Line No. 1WS71A18 by H. J. Kaiser Company in November a( 1979 were not applied in that the acceptance criteria were designated as not applicable. F. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test procedures shall include provisions for assuring . hat all prerequisites for the given test have been met... 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 programs to assure that essential components, systems, and structures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construction site." - H. W. Kellogg Co. (pipe manufacturer and agency performing the pre-
- fabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "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 reinforcement."
- ASME Section III-1971 Edition, Winter 1972 Addenda, Appendix'IX, Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness. . ."
I ., , ZIMM/lc DRAFT /np 8/13/81 Appendix " l' Contrary to the above, the NRC inspectors reviewed 700 radiographs involving 206 welds and determined that 187 of the radiograp.hs did not comply with the ASME 6eetL.. III-19M Code,-Whit;c M72 f.ddad%
.) in that there was insufficient shimming of the penetrameter. The radiographed welds were prefabricated pipe welds in such systems as feedwater, diesel generator, and main steam. ! G. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures i
[ design control] shall include provisions to assure that appropriate
; quality standards are specified...and that deviations from such standards
- are controlled."
The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are estab-lished to assure that any deviations from the applicable standards are controlled." Contrary to the above, as of March 1981, design control measures had i not been established to assure that deviations from design conditions identified by Sargent & Iundy engineers (quality standards) were controlled. For example, Sargent & Lundy noted on a calculatirn sheet dated December 27, 1979 g that the design thermal loading for two power cables (VC016 and VC073h Yellow Tray No. 1057A would allow the cables to be thermally overloaded and no program existed to control those design deviations. H. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization pe forming 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, "Inspec-tions are performed in accordance with written procedures which include requirements for check lists and other appropriate documentation of the inspections and tests performed." AWS DI.1-1972 Code, Section 3.10.1, requires work to be completed and accepted before painting. Contrary to the above:
- 1. As of March 1981, a QC inspection program had not been established 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 two Blue Cables RIl03 and CM111 that had.been routed into Green Tray Ris'@T.'
e 3025A, which extended from he TrayNAM No. 2077A in the Cable Spreading Room .to the Control Room. _R- hh M 3 untra ry-te-the-above, the program.: established' for inprocess. gin- p spections of welds on 180 cable tray hangers located in the Cable gl Spreading Room were not executed as required in the AWS DI.1-1972 l l Code. Specifically,thefinalweldinspectionshad-bee (m7deafter }s l ythee-than-49efore the welds were painted (Talvanox). M G-
ZIMM/1C DRAFT /np 8/13/81 Appendix ; I. 10 CFR 50, Appendix B, Criterion III states, in part, "The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing progras." 4 The Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, i design verification reviews are performed...." Contrary to the above, as of March 1981 design control measures had l not been established by Sargent & Lundy to provide for verifying or checking the adequacy of the design for the thermal loading of power i cable sleeves and the physical weight loading of cable trays. J. 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..." The Wm. H. Zimmer QA Manual, Section 3.4 states, in part, " Design i' reviews are conducted to assure that the appropriate quality standards are specified and included in design documents." The Wm. H. Zimmer FSAR states that cable ampacity is based on IPCEA Publication No. P-46-426. Also regarding cable ampacity, the FSAR states the summation of the cross-sectional areas of the cables shall
' not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross-sectional area in any case." ,
AWS DI.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." t Contrary to the above:
- 1. As of March 1981, the cable ampacity design by Sargent & Lundy i
was not based on IPCEA P-46-426. The cable ampacity was instead based on IEEE Paper 70TP557-PWR (1970), IPCEA P-54-440, and Sargent & Lundy Standard ESA-114a.
. 2. As of March 1981, the design control measures did not include provisions to assure that appropriate quality standards (allow-able undercut on cable tray hanger welds) were specified in that 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 on cable tray hanger welds.
ZIMM/1C DRAFT /np 8/13/81 Appendix K. 10 CFR , Appendix B, Criterion V states, in part, "Activi. ties af fect'ng quality.. . hall be accomplished in accordance with. . . pro- , cedur s...." , J Th Wm. H. Zimme QA Manual, ection 5.1 states', " Construction, /
/
I abri-c tion, and man'ufacturing ac'tivities which affect the quality the acility are accomplished n accordance with written instrue ons, procedures and drawings which prescribe cceptable methods of carrying
- out those activities."
l The H. J. Kaiser Pr edure SPPM No. .3, Revision 6, P ragraph 6.4, ' \.) 4 state , "The Weld od Clerk shall bas sue all filler m erial on a weight He shall ecord on the KE Weld 2 form the eight of all bare g' ro and covered lectrodes issue ." j "He shall als , record on the I Weld 2 form t e heat number and/or j lot number r bare rods, co sumable inserts d backing rings, and
, the heat ber and lot n er for covered e ectrodes prior to use Contrary to the above, w d rod was issue and information was fy recorded on weld rod is ue slips (KEI We d 2 forms) by someo other thanjthe Weld Rod Clerks assigned on t second shift duri September and October 1979. Sfecifically,for lds made on the s pression poo'1 wall plate (a)' 25 weld rod issu slips showed rep sentations of the-initials of Wld Rod Clerks whg were not assigne as Weld Rod Clerks on the days indfcated on the weld rod issue slips, ad (b) one weld rod issue slip did not show a Weld Rod Clerk signatu or initials.
L. 10 CFR 50, Appendix B, Criterion VII s ates, in part, "The effective-ness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee...." 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 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 of the con-trol of quality by vendors who supplied structural beams. Specifically, evaluations of the vendors' (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. M. 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."
ZIMM/IC DRAFT /np 8/13/81 Appendix - II - The Wm. H. Zimmer QA Manual, Section 17.1.4 states, in part*, "Documen-tation of all performance surveillance includes personnel identification and qualification, procedure, type observation, date of performance,
'I i person or organization monitored, results and corrective action if -
required." Contrary to the above, the Bristol Steel and Iron Works Quality Con-trol Steel Erection Report, which was a generic boilerplate form for
! monitoring inprocess steel erection, did not identify closely related ' data such as weld procedure numbers, types of welding material, welder identification, and specific welds. inspected.
N. 10 CFR 50, Appendix B, Criterion XVIII states, in part, "A compre-hensive 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 progam." The Wm.a comprehensive H. Zimmer QA Manual, Section "QA inDivision conducts system of planned and 18.1 states, periodic au part,dits of S&L 4 HJK end-GEato verify compliance with all aspects of the quality assurance program." '" Contrarytothe(,bove,duringthepast9yearstheCG&EQADivisiondid
, not perform an audit of the Sargent & Lundy nonconformance program.
This is a Severity Level II violation (Supplement II). (Civil Penalty - $250,000) . Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric l Company is hereby required to submit to this office within 30 days of the date of this Notice a written statement or explanation, including for each l example of the alleged violation: (1) admission or denial; (2) the reasons I for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to l 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 Con-firmation 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 13 CFR 2.101, Cincinnati Gas and Electric Company may pay the civil penalty in the amount of Two Hundred and Fifty Thousand Dollars or may protest imposition of the civil penalty 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 penalty in the amount proposed above.
Should Cincinnati Gas and Electric Company elect to file an answer in accordance
, , , , ZIMM/IC DRAFT /np 8/13/81 Appendix with 10 CFR 2.205 protesting the civil penalty, such answer may:, (1) deny the violation 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 imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty. Any answer in accordance with 10 CFR 2.205 I
should be set forth separately from the statement or explanation in reply j 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 i 10 CFR 2.205, regarding the procedure fo.r 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, as/ be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. The responses directed by this Notice are not subject to the clearance pro-cedures of the Office of Management and Beiget as required by the Paperwork Reduction Act of 1980, PL 96-511. FOR THE NUCLEAR REGULATORY COMMISSION Victor J,Stello, Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of , 1981 9 D, e a4
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i 3 l . I. Allegation $SNo.SS3SU "A radioactive waste drain is clogged with concrete which i carelessly was poured into the drain." i II. Findings $U 1 y elleyA 4-'44 The portion of the allegation that ::d .t~; a radioactive g waste drain was clogged, was substantiated in that interviews with two pertinent personnel indicated that some drains had been clogged with unspecified debris. alleyeA The portion of the allegation that .~'k;;;d 05;; concrete clogged the drain was not substantiated. Flushing records dated
*/ a tetel fefe<ftal toe (toest:sa waste in 1979 indicated that 152 outg of 169 of the4drains, aLL of which are nonsafety related, were cleared of all restricting debris.
/ ~! wl.ule remain b s*ll*sAdd are AM-ef Me/69 drainsj weee identified Wycontrolled flushing on f4e rens procedureg as 7%c 152, wh44 4*ve Jecer -/7 s444. RZZT wt// e/c/e<, .we#
fle (fa /e.s el fit remain * /7 dratoss f reer h planf eprof.ba. ( 35 8lS/- /3 ~ ) No items Of noncompliance or safety concerns were identified.
- III. Investigation $U A. Background $SInformationSU I3
- yaeswafyeae~/;cep*fu Slu.rk $rn/*
- WMT sv**let jrr**r op a r.ti.., to a.< fi<~ ni da Aras are a lea- a /
j H <esf<:u43 de Jr:s . l t
pe The radwaste drains, which are nonsafety related, wiLL not handle radioactive material until such material is generated following commencement of Lant operations.
$ 7ke terms radwests .4s s red;*eet ve w e h Y/*:n2 ed
- ,a/sdam w.de dww are, .ryenny meus & rKis e //sy, sten .
B. PersonnetSSInterviewsSU fn % v:e w e / Za d M ds*si / On February 24, 1981, Individual "A" who was previously interviewed by representatives of GAP was interviewed. Individual "A" stated that while concrete finishing work was underway in the radioactive waste disposal system he suggested to Kaiser Construt<ction personnel that a pipefitter be assigned to the concrete finishing crew to assure concrete did not enter and clog the drains. However, they disagreed with t<his suggestion and instead directed the floor drains to be covered with duct taep<< tape to prevent concrete from entering and clogging the drains. Individual "A" stated that concrete did enter the Lines and clogged the l radiation waste drains. I On April 22, 1981, Individual "A" provided a written statement attesting to the aforementioned information; however, t<he requested the statement not be attached to this report. a
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I e 3,ga,,,;<w ol 2nktb~I *3 l l Individual "B" stated that he worked as a pipefitter in 5-1976-1977 in the drain flushing crew for the radiation waste disposal system. Individual "B" stated that during this I period, he observed drains in the system that were clogged i l with concrete, which he and others unsuccessfully tried to f g remove. F'ip' w C. RecordSSReviewSSandSS0nsite$S0bservationSU The Senior Resident Inspector reviewed CG&E Flushing Procedure No. DR, Rev. O, approved 9/23/77, for the Drain System. The purpose of this procedure was stated as follows: "This docuen<< document details the procedure for cleaning the liquid radwaste L< floor drain and equipment drain piping to the various plant sumps and drain tanks. The floor drain and equipment drain piping shall be flushed until they flow freely and aLL Large particulate-matter is removed." The Radwaste Building Floor Drain Tank, <<<< Appendices to the Flushing Procedure, indicated that 152
,.f . f. t. ( potentsel e.dso.stus wastar outgof 169 of thegdrains related to thn<e Radwaste Building Floor Drain Tank, the Floor Drain Studge Tank, the Radwaste Floor Drain Sump, the Floor Drain Collector Tank, and the Ce<<
Chemical Waste Tank has been flushed and verified in accordance with the procedure. The Appendices indicated
i-that the verifications had been made in 1979. The Licensee stated that the flushing activities were stiLL continuing. l j The Senior Resident <<<<
.r. tere:ew *+ rae ces.,.r. ea d .rter t.s fo y
- W-p Telephone interviews were conducted by the Senior Resident
[6"\ 4 Inspector on 2/12/81 wih<th the Test Coordinator responsible g(s [g e . for the radwaste building drain flushing activities and on i [ j (e \ 2/13/81 with the Startup Engineer responsible for Drain Y System flushes. Both individuals inc<dicated that some
\.
drains were found to be plugged with unspecified debris. _: 0-In aLL of those cases the drains were cleared and flow was verified. The Senior Resident Inspector made visual inspections of aLL of the accessible radwaste drain ports identified on Sargent
*<& Lundy drawings A-533 Rev. F, A-534 Rev. F, and A-515 Rev. N. These drawings identified the drains in the radwaste building (elevations 496 feet, 527 feet, 513 feet and 511
- feet) and in the auxiliary building (elevations 567 feet,
{ 5 inches, and 546 feet). None of the observed drain ports were visibly plugged. fe f es*I A " Neither the flushing records, the personnel interviews, nor the Resident Inspector observations confirmed or denir<ed that the drains had been clogged with concrete. These activities did confirm that the drains, which had been flushed, would allow flow on the dates of the verifications.
No items of noncompliance or deviations were identified. l A e f O b
i, - . t
- 7. Prefabricated piping, received in 1977 has defective welds, but construction supervisors told crews not to repair them because
! the welds were made offsite.
. Findings $U 5 , This allegation was not substantiated. Summary $U i The RIII investigator's discussions with the alleger's source for this allegation revealed that the piping involved was five spool pieces delivered from Kellogs Company to the site. Upon arrival at the site on July 3, 1979, the pieces were dropped off the delivery truck. The RIII inspectors reviewed the QC documentation relevant to the pieces being dropped. The documentation indicated that adiographs of the welds on the pipe pieces were taken to identify any defects that would have resulted when the pieces were dropped. The documentation indicated that, when indications were identified
. . on three of the five pieces, instructions were given by Kaiser personnel to disregard radiographs.
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I Allegation 1 i
"KEI knowingly installed and ripped out unsuitable main steam relief ! piping, at an estimated labor cost of $320,000."
l II Findings I None. III Investigation A. Background Information None. B. Personnel Interviews On February 24, 1981, Individual "A" who was previously inter-i l viewed by representatives of GAP was interviewed. Individual "A" stated Kaiser installed a large portion of the MSR piping knowing sections of it would later have to be removed. He recalled that two years after its installation Kaiser removed large sections of the piping at anibelow the 525' level of the
~
,, reactor containment building but left the pipe sections.above that level in place.
- l. DRAFT /db i.
On April 22, 1981 Individual "A" provided a written statement attesting to the aforementioned information, however, he re-quested the statement not be attached to this report. On April 14 and 16, 1981, Individuals "B" and "C" respectively, who allegedly provided information regarding this allegation to representatives of GAP were interviewed. These individuals i stated they had no information conerning this allegation. t C. Record Reviews f None. D. Field Observations None. E. Acceptance Criteria None. I {
s j s 1 DRAFT /db i . I Allegation No. 3 f
] "A radioactive waste drain is clogged with concrete which carelessly was poured into the drain."
1 II Findings-
}
i
, None.
I i 1 III Investigation s
! A. Background Information None.
B. Personnel Interviews l On February 24, 1981, Individual "A" who was previously inter-viewed by representatives of GAP was int'erviewed. Individual "A" stated that while concrete finishing work was underway in the radioactive waste disposal system he suggested to Kaiser Construction personnel that a pipefitter be assigned to the concrete finishing crew to assure concrete did not enter and
,, clog the drains. However, they disagreed with his sugge,stion and instead directed the floor drains to be covered with duct tape to prevent concrete from entering and clogging the drains.
5- , s
DRAFT /db i On April 22, 1981, Individual "A" prrevided a written statement '
, attesting to the aforementioned information; however, he request-ed the statement not be attached to this report.
( D. Field Observations
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I
; None.
l t
, E. Acceptance Criteria I
i L i E s I s . O g b
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i: DRAIT/db I I Allegation.j ., s
" Sensitive parts on welding rods are possibly damaged through st'orage at improper temperatures, and possibly lost through failure to follow proper paperwork and labelling requirements." '
l i II Findings , e 1 None. '
% v III Investigation a
\
A. Background Information None. 3 Personnel Interviews Interview with Individual "A" - On February 24, 1981, Individual "A" who was previously interview-I ed by representatives of GAP was interviewed. Individual "A" stated he observed weld rod which was not accounted for (weld rod without accompanying KE-2 weld control forms) onsite and has seen weld rod warming ovens unplugged and not being main-tained at the proper temperature. Individual "A" also stated 9-
f
, DRAFT /db 1.
i - there was no one assigned on the night shift to the weld rod issue point onsite and during a two-month period in 1979 weld i rod was left out unattended with a weld rod issue slip.available j for night shift personnel to sign when drawing weld rod. On April 22, 1981, Individual "A" provided a written statement { attesting to the aforementioned information; however, he request-i l the statement not be attached to this report. l i
, Interview with Individual "B" On April 14, 1981, Individual "B" who was previously interviewed by representatives of GAP was interviewed. Individual "B" stated Kaiser required weld rod ovens be maintained at the proper temper-atures at all times. He said he could not insure that every welder maintained his oven at the right temperature, but he insured the
! men he supervised did. He stated that on occasion weld rod issue slips (KE-2 Forms) were lost and in those cases it was a common practice onsite for welders at the time ,of. fabrication to get a blank issue form, falsify it, and present it to the Kaiser Quality Control Inspectors in order for the weld to pass inspection. He said frequently this was done months after the fact by Kaiser
. construction supervisors who falsified weld rod issue forms to complete weld documentation packages. He said by doing this they did not have to cut out and rework welds.
l
l
;, DRAFT /db l..
- l On April 14, 1981, Individual "B" provided a written statement attesting to the aforementioned information; however, he re-i i quested the statement not be attached to this report. -
i
- C. Record Reviews i i l None.
l i f 4 D. Field Observations i l None. E. Acceptance Criteria None. W D i t
.~. . - , . _ . _ . - . _ -
I , Allegation 8 "At least three sources contacted by Applegate confirmed that an esti-mated 20% of the plants prefabricated welds are defective." II Findings None III Investigation A. Background Information None B. Personnel Interviews j Interview with Individual "A" , , On April 24, 1981, Individual "A" who was previously interviewed by representatives of GAP was interviewed. Individual "A" stated ; I he worked with employees of Peabody Magnaflux (PM), the firm f. I responsible for radiographic examination of pipe welds onsite. He said in his opinion 20% of the prefabricated pipe welds manu- l factured by Kellog are defective. He said the basis for his l
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a o - SummarySU During the RIII inspector's discussion with one of the alleger's sources for this allegation, the source stated that the 20% estimate was based on: (1) thesourcesfirsthandknowledg[eoffouroccasionsinwhich
.: eld radiographs, taken in 1976 of 44tted welds in the residual heat removat system, overlapped vendor welds. The source ,
stated that he had no additional knowledge concerning the fourth occasion. (2) The radiographs of the three spool pieces that were dropped off the truck on July 3,1979. (3) An affirmative acknowledgement given by the KEI project manager was the source stated that 20% of the pregabricated pipe welds were defective. - 3. (4) A conversation the source had with an ex employee of a pre- ; fabricated pipe supplier. r t No additional information was provided from any of the other sources. ,
- r
JP I Allegation 7
" Prefabricated piping received in 1977 has defective welds,'but construction supervisors told crews not to repair them because the welds were made off-site."
II Findings This allegation was substantiated in part. The piping pieces in question were identified as the Main Steam Relief (MSR) spool pieces which were delivered to the site on June 29, 1979. A nonconformance report was written after the spool pieces had been delivered to the site. Region III Investigation Report No. 50-358/80-09 found that Kaiser had released the MSR spool pieces for installation before their acceptability had-been established. For this, the licensee was found in noncompliance with 10 CFR 50, Appendix B, Criterion XV, and Kaiser Quality Assurance Procedure No. 16. However, the allegation that the welds on the aforementioned spool pieces were defective is unsubstantiated. The spool pieces were ultrasoni- , cally examined on April 25, 1980, and found acceptable. One item of l noncompliance with NRC requirements was identified release of material from segregation and failure to use hold tags, for which the licensee . I had been previously cited in Region III Investigation Report No.
.. 50-358/80-09.
e
- o.
- i
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III Investigation A. Background Information On June 29, 1979, Pullman Power Products of Williamsport, Pennsylvania, also known as M. W. Kellogg Company, delivered five prefabricated pipe spool pieces to the site for installa-tion in the Main Steam Relief System, a safety-related system. The spool pieces were received on June 3, 1979, and a noncon-formance report was written on June 5, 1979, stating the spools had " rolled off the truck onto the ground and struck other spools." The nonconformance report had the effect of placing the spool pieces in a hold status in the Kaiser warehouse. The five spool pieces were radiographed and defective welds were found on three of the five spool pieces. However, on September 18-28, 1979, despite the issuance of the nonconformance report, the spool i pieces were released to construction and installed. In l Region III Investigation Report No. 50-358/80-09 it was found l that the licensee was in noncompliance with NRC requirements i for the release of the spool pieces. However, during April 1980 the spool pieces were ultrasonically examined and welds i on them were found to be acceptable.
~
B. Personnel Interviews t Interview with Individual "A"
~
i i 4
On April 24, 1981, Individual "A", who was previously interviewed by representatives of GAP was interviewed. Individual "A" stated he had provided information to GAP regarding this', allegation. He stated that when he spoke to GAP about this allegation he was referring to five prefabricat-d pipe spool pieces manufac-tured by Kellogg which fell off a truck during their delivery to the site. He stated a nonconformance report was then written on the spool pieces. He said Peabody Magnaflux (PM) radiogra-phers examined the pieces and found defective welds on some of them. He said construction installed the spoo: pieces in the plant disregarding PM's finding on the welds. On April 22, 1981, Individual "A" provided a written statement attesting to the aforementioned information; however, he re-quested the statement not be attached to this report. l l Interview with David Hang b On February 24, 1981, David Hang, former Level II Radiographer, PM, was interviewed. He stated in August 1979 Anthony Pallon, KEI Welding Engineer, asked him to radiograph MSR spool pieces l which had fallen off the truck upon delivery to the site. Hang l said the exam was to determine if any of the welds on the pieces had cracked during the fall. Hang stated on three of the five spool pieces he examined he found welds to have un, acceptable indications. He said he reported this in his Report of Radio- [, l 1 I t
graphic Examination to Pallon and told Pallon at that time that radiography was the wrong technique to use to examine welds in this configuration. Hang said he told Pallon an sltrasonic examination should be performed in this case. Hang also stated that in April 1980 the spool pieces were ultrasonically examined and the welds were found acceptable. C. Record Reviews On February 24, 1981, Kavin Ward, NRC Inspector, reviewed ultrasonic examination reports for the prefabricated spool pieces numbered IMS11B12-7BH, IMS10BA12-ICH and IMS08BB12-6B. These reports reflect that Pullman Kellogg, Inc. examined the aforementioned pieces on April 28, 1980, and found the welds acceptable. In addition, on April 25-18, 1980, PM also ultrasonically examined the same spool pieces and found the welds acceptable. Ward also stated in April of 1980, that he i reviewed the radiographs for these spool pieces and found that the geometric confriguration of the weld distorted the view _. a-
~~
of the weld on the radiograph. This resulted in unacceptable , V-indications appearing on the film; however, radiography was _ l-i the wrong nondestructive testing and he concurred the spool g. pieces should instead be ultrasonically examined. I t i l
D. Field Observations None . E. Acceptance Criteria None i d l i t I i
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plus the height of the crown or reinforcement. Shims shall be of a radio-graphically similar material to the weld metal." . W The insufficient shimming ofjpenetrameter in regards to the radiographs of the above welds is contrary to 10 CFR 50, Appendix B, Criterion XI and the Wm. H. Zimmer QA Manual, Section 11.2 as described in the Appendix A to the i report transmittal Letter. (358/81-13-13) The above citation does not imply that the respective welds are unacceptable. The citation implies that the radiographs were not of sufficient quality for interpretation to determine if the welds were acceptable or not. The RIII inspectors also verified that the following welds matched the respective radiographs by comparing t h; . .J .w3. .- sw s..e s ', J .,- a .rkets.h (ontes sk *n) & W!N defuYed in AC resf esYa'.t (d.'oy r~h
.;,,. p a la d. .sy wcWr:
Pipe $SLineSSNo.SU WeldSSNo.$U , 1FC36CA621 B , 1MS20B3169 A 1FCO2AB818 B 1MS20B3169 0
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1 s- . fol.fo% Radiographs for 206 welds were reviewed per ASME Section III 197p Winter 1972 Addenda and M. W. Kellogg Co. Procedures ES-414, ES-415, and ES-416. No unacceptable RT technique deficiencies were identified in 517 of the radiographs and no unacceptable indications were identified in the respec-w ere. tive welds, % 183 of the radiographs 3:;; .... b made without c.c.-,: . . . -
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required shims under the pei 4 ,,./,,/M. LM Me d*J) , N* made with insuff-
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f.,9t'7 A r--.a A- ,y.s-Sre4a 5 % ;/' k **f lt 'y fa cra step c=) /kb d'* f, 4 [ f/,,r [ <e/ J N "'" The essential hole of the pi g eg graph has been sufficientlyi 8. #' 7 por for ). nonconformance with the ASME penetrameter is necessary to trameter is the same as the t we .. . . . . . . . w i en n y reference for identifying Wl'$ shimmed penetrameter wetrW give K false assurance that she weld had received any sufficient exposure to reveal unacceptable.we4d 3 indications ja /Ac-o/ /4e se// /4*"/~ tJ 74ss Aer fA.aer 7%e siw:sv nie7e /,
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III E4/d**t ASME Section .EGE-1971j with Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, "The shim thickness shaLL be selected so that the total thickness being radiographed under the penetrameter is the same as the l total weld thickness ..." , M. W. Kellogg Co. (the manufacturer of the pipe and performing agency of the l t above RT) Radiographic Procedure No. ES-414 dated 9/26/72, Paragraph 4.1.8, l I states "Wherever required, shims shaLL be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal
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ORd l' TheinsufficientGAindp<ependencegtheinadequaterecords;and+he-
..w.7, taken cumulatively comprise a
. .. . . . ..~...r _ m QA program that is contrary to 10 CFR 50, Appendix B, criterion II and /y the Wm. H. Zimmer QA Manual, Section 2 as described in the Appendix A
/'
to the report transmittal letter. (358/81-13-05) i. I i I i e 9 O G e
I Further review of Procedure fJo. SPPM 4.6 paragraph 5.2 revealed
! other noted exceptions to the AWS D1.1-1972 code. These exceptions l
! included fillet weld size and weld x< convexity. On March 5, 1981,
.S&L provided a documented investigation program of fillet weld size for P-W Industires cable pan hangers, purchase order No. 7070-25102.
This program was performed by Gladstone Laboratory of Cincinnati to substantiate the design adequacy of the undersized fillet welds' at the flare bevel joints of the cable pan hangers. Thelstudywas based on a sample of 95 welds cut from P-W cable tray hangers. The 95 welds were sectioned and etched to determine actual weld size and relative weld quality. Only one weld was identified as rejectable, due to a lack of fusion. Though this study may justify that the weld size was adequate, where the weld pee <netration was not measurable by normal visual techniques, no justification was rp<<provided to sut<< substantiate the exceptions to the AWS D1.1-1972 code requirements concerning weld convec<xity and undercut.
- These deviations from the AWS code are contrary to 10 CFR 50, Appendix 0, Criterion III, the Wm. H. Zimmer FSAR, Table 3.8.2, and O f the Wm. H. Zimmer QA Manual, Section 3.3 as described in the Appendix A to the report transmittal letter. (358/81-13-119
.. _ = f. _. ....
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. f;. _ . .
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~
Based on the above relationships between design index and depth of cades
; squargr, and the fact that S & L has used a 2-inch depth-of-fill as the I e i basis of selecting cables for particular amppre loads, the cables in I
tray nodes with a 0.I. over 1.0 would have to be re-evaluated considering the increased depths. This item is unresolved pending the completion of the re-evaluations (358/81-13-15). f f The above design bases for cable ampacity was a deviation from the FSAR which was not identified on any control document. This deviation is 1 25 contrary to 10 CFR 50 Appendix B, Criterion III and the Wm. H. Zimmer (o QA Manual Section 3.6 as described in the Appendix A to the report trans-mittal letter. (358/81-13-16) On 3/17/81, the S & L Assistant Manager of Electrical Engineers stated that appropriate modifications to the FSAR would be submitted to NRR. Also specific consideration would be given to the differing types of cable insulations, addressed in the publications (standards), when compared to the cable insulations used in Zimmer. l l 64 )dQ"(TheRIIIinspectorreviewedS&LInstructionNo.PI-II-10.1 Rev. O dated 2/6/78, paragraph 4.5 which states, "The Senior
! Electrical Project Engineer shall assign an electrical engineer to Ck i run thermal loading calculations for all power tray routing points with a design index exceeding 1.25. He shall compare these i
loadings, in watts per feet, with the watts per feet limits esta-(blishedforthedesignindexesinvolved." l l y , ,-
. - e, ,
. {. , 7 , ,, -
% ., % % ./* w . - ; c _. w M g r";;,,,_w,* . , , , ,
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E The RIII inspector requested the justification for using the design
~~ '
index program for the determining factor for physical loads since i i the design index program had absolutely no technical relation to
/ physical weight. The RIII inspector also requested justification for using the design index of 1.25 as the determining limit for I performing design calculations. S & L stated that both of the justifications would be provided to the NRC, Region III. This item i
is unresolved. (358/81-13-19) l 4 6
, % The RIII inspector observed a note on the bottom of the thermal calcu-Lation sheet dated 12/27/79 for cable tray #1057A.y The notetu
- s. g.,f,/ indicated Inos uIN~f~ ^
- The noted uverloaded that two cables "#VC016 and VC073 are overloaded".^/,,
w e M A*><. b 6s. iasfu.e s.k n f.nJ s./e.1a. t t a, i1 e p 4. r s .4.rg ,,,.. a /. cables were not identified on any control document which would have w L . s c. se.,.t.t y.la r:/, t u m an fo.J 4.y., a..J n a. ./. >,m .4, . required appropriate evaluation and disposition. yTh we S & L personnel did ;*~.., a.a. .,.y m < wd .ta .~.t (/ stated that a control program Jee+ not exist See such design deviations
.j,, ., n.a a,ep.vp..re ent sf a-a a.d as.y,:r. a . [
j This is contrary to 10 CFR 50, App. 8, Criterion III and the Wm. H. t ' Zimmer QA Manual Section 3.6 as described in the Appendix A to the report transmittal letter. (358/81-13-20) 1 1
- f. The RIII inspector performed the following physical weight tabulation of yellow division control tray #11048:
... - -- Cable Weight f +
Cable #5U Cable Type 5U *(lbs./ft)$U l l 1. l s , .s , . ,
.:u : .; . . J . . , ;; .y c .
v ~ . ...; ; +.;. . :,% : .. ,,w: . },.:L; . .
routed through tray #4157A, but not tray 10408. Since cable #DC258 was a nonsafety related cable there were no QC i inspection requirements to verify the routing. C 1, . . . , s. I ;h; T A , 6ue m...vusww v.w6. .....w6 56....i. w . w . . . . . u-k; ____ .
, , ' - - 'h s-.-
J . (6) With the exception of the green tray riser identified in para-graph b(3) above, the RIII inspector did not observe any other risers (chutes) installed in the cable spreading room. The Licensee stated that only 8 chutes had been designed 4ec anel installed in the spreading room and that alternate methods for achieving cable separation were being considered. S&L drawing #E-98-FB Rev. D Note 4 required that the portions of
, cables in the cable spreading room which were not enclosed or protected by steel chutes, be coated with a 1/8 inch (after dry) application of fireproofing material. During a phone conversation on 5/7/81 the Licensee stated tnat the design identified on drawing #E-98-FB was being reconsidered for alterations.
- c. (1) The conditions identified in paragraphs b(1), b(2), b(4), and b(6) above apparently resulted f rom designs which de. .aui /?N*I' -
from the FSAR. These deviations are contrary to 10 CFR 50, ty/ Appendix B, Criterion III and the Wm. H. Zimmer QA Manual, Section 3.1 and 3.6 as described in the Appendix A to the report transmittal letter. (358/81-13-21) [ = = _ - _ _ _ . _ _ _ _
i i (k) Section 6.5.4 - "The inspector shall, at suitable intervals, i' observe the technique and performance of each welder, welding operator, and tacker to make certain that the applicable requirements of Section 4 are met." t j i c. Tiie weld inspection criteria which was deleted or designated as not i applicable is contrary to 10 CFR 50 Appendix B, criterion III and the jr l5 Wm. H. Zimmer QA Manual, Section 3.3 and 3.13.1 as described in the Appendix A to the report transmittal letter. (358/81-13-26)
a
- a. The Cable Pan Loading Report included the design indexes of reporte d Ised e , *f*d sleeves. Steeve #SL111 hadj a D.I. of 1.29 and sleeve #SL105 had-s #
q ..-? & t ', n . D.I. of 1.26. A controtted list of powers sleeves with a D.I. over 1.25 was not meintained. l
- b. S & L stated that design index of 1.25 would be used as the deter-mining factor as to when c,atculations would be performed for l physical (dead weight) toading.
I The lack of design control measures to verify the adequacy of the thermat loading of power sleeves and the physical loading of trays e is contrary to 10 CFR 50 Appendix B Crit rion III and the Wm. H. 7 Zimmer QA Manual, Section 3.11.2 as desc ibed in the Appendix A to 1
- the report transmittal letter. (358/81-13-18)
S & L revised Instruction PI-ZI-10.1 Rev. 1, Section 4.5, 4.6, and 4.7 on 3/13/81 to include requirements to verify and control the thermal loading of power sleeves and the physical loading of aLL t-- trays (power, control, and instrument) which have a design index over 1.25. S & L stated that calculations for the physical loads of aLL power, control, and instrument trays, and for thermal loads of att power sleeves, with a design index over 1.25, will be performed in the near future. These calculations wiLL be provided to the NRC, Region III.
=. -
e.' . ~. . e%.A h ' % ' **" 4 *9 wM t Mmpabesy b.3888W..d ,"A g1h '$$ ' ,e ",** **g *
~he'ay.,'.7pg p Q g (gy, 4f.,*L.....,,.e.,,' ., k! . .* .Ag, e'*** g , a *, ,
t i i P.O. No.10275 - PBI Steel Exchange - 2400 feet P.O. No. 12868 - U.S. Steel Supply - 1500 feet i P.O. No.16321 - Frank Adams Co. - 1012 f eet
? d
! P.O. No.10009 - Frank Afems Co. - 1024 feet P.O. No. 9761 - Frank Adams Co. - 1472 feet
, P.O. No. 9628 - Frank Adams Co. - 450 feet P.O. No. 9872 - U.S. SteeltSupply - 300 feet The<ese beams were not controlled to prevent their use in safety related systems. MILL certifications were available for these. beams. On April 10, 1981 the Licensee stated that these ba<eams had been made available for installation in safety related systems based on the mill certifications and without regard to the vendor not beir.g approved. Te<he Licensee also stated that the credibility f<of the mill certifications would be established. Failure to assure that the beams were purcpased from a veridor tht<at had been
/ approved is contrary to 10 CFR 50, Appendix B, Criterion II /
and the Wm. H. Zimmer QA Manual, Section 2 as descd<ribed in the Appendix A to tne report transmittal letter. G58/81-13-06)
===- _
NNNd
.y
e - I The beams for which the traceability of the heat numbers was not main-( tained is contrary to 10 CFR 50 Appendix B, Crt<iterion VIII and the Wm. H. Zimmer QA Manual, Section 8.2 as described in the Appendix A to , the report transmittal letter. (358/81-13404) 1 h c.;>
tna$ttinl'YfeLt*bNlY gf, Failure to maintain '::: . . . .. L - . .J-.....',w. . - for the above. ar<< i Traway pipingA -e LJ r;d is contrary to 10 CFR 50, Appendix B, $ f b* Criterion VIII and the Wm. H. Zimmer QA Manual, Section 8 as described in the Appendix A to the report transmittal letter. (358/81-13-07) o e 4
--------N .,"---'-- , {,,g,NL . _- *
\
The Licensee stated that the following actions would be taken I with regards to the conditions identified in paragraphs b(1),
; b(2), b(4), and b(6): Either the field installations would be 4, the F.5A k ' ,l changed to comply with the FSAR or appropriate changes 4 with t f engineering justifications t: i .- M , would be submitted to 4e . NRR. 3 Y
f s (2) The condition / identified in paragraphs b(3) :nd '.37 above 0
^$
apparently res
.n d fromd' constructjon activities for whi- * "- V )'
yth---
- - :- WC inspectien b";,d ----- ..-ry;pe d Lack ytjayoNQp j ,
, 4, j Tkb
\
- ! _ J _ : Catedarvtw O spectionp=4d ---- )g_for the condition in paragraph b(3)- y - is-n p.* f-~
,o contrary to 10 CFR 50 Appendix B, criterion X, and the 0
( Wm. H. Zimmer QA Manual, Section 12.1.2 as described in the Appendix A to the report transmittal letter (358/81-13-22) (s) rh e nsa 4 J c Jh ;d J:f:ad ;, ,, ,, ,g g ,) c- ab. 7%. ,,4:<.fras f., appan. fly eesa Meal A~ wbcs4 -ths fsd K J er not rey .ve a e i.sp. f.a.
- hl!- a% , IAa-a vc,-
- Led:. . 14e-,.n r zt <*
e ,1}s seye re.f: a. a,*/ 'Yry /~=_]'= p s/--1A w.yL!-s- A As a,ap y tdy-A.y *.r:h 4 *~- w i g u m v:e J & ~ 7 y ' 'j r ~ f 4^*==' P
- 1kis iteer 1 + - .. , . a u v e .< p en = y i ~ ~ -
A n ,. ,g c 35@l 8/ -/ 3-1 3) g, f u - .1)- 7 N'
paragraph 5.1.3 which states, " Surf ace condition - joint surfaces
~
to be examined shall be cleaned and free from slag, rust, are burns,
! paint, dirt, or other contaminants that would interfere with the I
t
, examination." The Licensee stated that paint (galvanox) that was applied to the hanger welds did not interfere with the visual examination and in some cases actually highlighted discontinuities. AWS Q1.1-1972 code,
{ I
- section 3.10.1 states, ". . . Welded joints t<shall not be painted until after the work has been completed and accepted. . ."
l i e The apparent lack of in process '-::::t' :_and 4madequate visual
.$: eld end vende j inspections of the aboveAhanger welds is contrary to 10 CFR 50
</
l O Appendix B, Criterion X and the Wm. H. Zimmer QA Manual, Section 10.1.2
/}L as described in the Appendix A to the report transmittal letter.
(358/81-13-10) dgTheRIIIinspectarrequestedthedesignacceptancecriteriawhichwas used by QC to evaluate the undercut on hanger No.15H2FEC175. The Licensee provided S&L Specification H-2713 Supplement 7, Standard EB-117 and /I kH._ )Kaiser Procedure No. SPPM 4.6, Revision 8, Paragraph 5.2.9 which allows up to 1/16 inch undercut on the cable tray hanger welds. The 1/16 inch criteria does not comply with AWS D1.1 1972 Section 3.6.4 which states, "For buildings and tubular structures, undercut shaLL be no more than 0.01 inch deep when it's direction is transverse to primary tensile stress in the part that is undercut, nor more than 1/32 inch for all other situations. L,f
- ,' vY. , *j ; . $$' J y [** .,
l[ = " - a*h . , , , [.1 ,
^ '{ , , y _
t
~N N
M. W. Kellogg Co. (the manufacturer of the pipe and performing agency of the N '
; above RT) Radiographic Procedure No. ES-414 dated 9/26/72, Paragraph 4.1.8, states "Wherever required, shims shall be used to produce a total thickness I
s under the penetrameter equal to the nominal thickness of the base metal plus theshtight of the crown or reinforcement. Shims shall be of a radiographically similar material to the weld metal." i s , / .(:.M and
! Theg insufficient shimming of the penetrameter in regards to the radiographs of i
the above welds is contrary to 10 CFR 50, Appendix B, Criterion XI and the
, 75 Wm. H. Zimmer QA Manual, Section 11. P as described in the Appendix A to the i
report transmittal letter. (358/81-13-13) i The above citation does not imply that the respective welds are unacceptable. The citation implies that the radiographs were not of sufficient quality for interpretation to determine if the welds were acceptable or not. The RIII inspectors also verified that the following welds matched the respec-tive radiographs by comparing a sketch (onionskin), made by the RIII inspectors, of the welds depicted in the respective radiographs for the following welds: Pipe $Sline$SNo.SU Weld $SNo.SU 1FC36CA621 B 1MS20B3169 A 1FC02AB818 8 gY*
Note: Some of the welds inspected by the RIII inspectors were painted. Therefore, the inspections were for relatively large deficiec<ncies only. The unacceptable welds identified above are contrary to 10 CFR 50 Appendix 8, Criterion and the Wm. H. Zimmer QA Manual, Sec. I} I \ as described in the Appendix A to the report transmittal letter. (353/81-13-01)
' S For the beams addressed in paragraphs 1.a. (1) and 1.b.(f) above, no -
measures exsi<< existed for DDCs which would identify to QA, k< installations ,, and work that wa.t done by contruction before receiving S&L approval. g Thus no measures existed to assure that all of the required QA inspections l ' (e.g. welder qualification, proper filler metal, traceability of materials, etc.) related to DDCs would be accomplished. u This condition was previously identified in IE Report Item No. 80-15-04. I The corrective actions, taken in regard to Item No. 80-15-04, did not include the DDCs written prior to the implementation of the corrective actions, and the DDCs that are and have been implemented prior to receiving the S&L approvals. T ams with unacceptable re entrant corners s e ceams that were installed :nd identified as . uirement on any design document are contrat<ry to 10 Appendix B, Criterion XV and the Wm. H. Zimmer QA ual, Section 15.2. i described in the Appendix A to the report transmittal letter. (358/81-13-03) 1 7
"M 'I9 %%W v (" ' e4 4 . my
- The unacceptable welds identified on hangere 70HFEC165, 15H2FEC175, i
i 14H11FEC146, and 16H1FEC156 were not controlled on any QA document. This is contrary to 10 CFR 50, Appendix B, criterion XV and the b Wm. H. Zimmer QA Manual, Section 15 as described in the Appendix /f, A to the report transmittal letter. (358/81-13-09) The RIII inspectors reviewed approximately 180 Construction Inspection Plans (CIP), inspection records, for the hangers in + the cable spreading room (elevation 536 feet in the north section of the auxiliary building). The licensee stated that the inspec-tions documented on the CIPs also included the vendor welds, even though the records only reflected field welds. The vendor welds were inspected because repairs were necessary in order to close the 10 CFR 50.55Ce) report (#E-5) telephoned to the NRC on i 7/17/78. The 10 CFR 50.55(e) report indicated that vendor welds on the cable tray hangers, used only in the cable spreading room,
.D did not meet the visual requirements of AWS-/1.1-1972. The CIP records and the 10 CFR 50.55(e) report indicated that all of the final field and vendor welds were reinspected af ter repairs were made to welds on more than half of the 141 hangers and accepted in December, 1980 and January, 1981.
l No inspection records were available to indicate that in process impections of either the field or the vendor welds were made to verify proper filler metal, weld procedure, welder's qualifica-tion, surface conditions, etc., as required by the AWS D1-1-1972 2
.w : .x n ..
- s. .; ..:. -
. ; n; N l '; L r u % k ;)
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; .;.;g- Q ^.,):^f +:
- a? Lib.),,$5. ,3;?. . ,:
. 'iy b .
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t These inadequate corrective actions are contrary to 10 CFR 50 Appendix , / B Criterion XVI and the Wm. H. Zimmer QA Manual, s<Section 16.5 as described in the Appendix A to the report transmittal letter. b758[E/* /#' #= } The beams with unacceptable re entrant corners and the b eams that were installed and not identified as a requirement onesign anydocumentd l are contrary to 10 CFR 50, Appendix B, Criterion XV and . H. the Wm sY Zimmer QA Manual, Section 15.2.2 as described in the A report transmittal letter. ccendix A to the (358/81-13-03) n-
None of the audits, which identified the above calculation concerns, addressed the apparent generid and programmatic cause of design calcu-Lations and verifications not being performed. The corrective actions that were taken did not assure that the cause was determined to pre-cLude repetition. Failure to determine the cause and to take corrective
$$ action to preclude repetition is contrary to 10 CFR 50, Appendix B, 7
3 Criterion XVI and the Wm. H. Zimmer QA Manual, Section 16.5 as , l described in the Appendix A to the report transmittal letter. l (358/81-13-24) l G e l l l
formXNo. 118920)( which indicates welder LJP may 4 have worked on A-7 on April 6, 1978. 4 f (b) The KEI-1 form, for weld A-20 on Line 1DGD2AB-1/2, I i indicated final weld inspection was performed by QA inspector No. 81 on April 10, 1978. The dats I was crossed out and changed to April 11, 1978 on January 27, 1981 because of g weld rod issue form
)No.123834XwhichindicateswelderLJPmayhave worked on A-20 on April 11,1978.
4 The Licensee was previously cited in IE Inspection Report 50-358/79-15-12 for transferring
- f. ~
information from KEI QC inspector's noteboks to KEI-1
\ forms.
E
- d. No apparent act4 ens were taken to assure that tne proper wetd j V 2 procedure was used on any ofj unverified in process weld 7
activities, 4.<- M <.e.
y.. _
Failure to takejeorrective actions whengwd u prou Jures, e . -< - -- not verified and f ail ure to-take adequate : rrec-t4ve--actions-
'[ U ,u...I p. vJ.~e sef ta.l-./') when*
proper pipe fit-up, weld filler metal (traceability), and geleef;f:ed as are welder qualification wereg not verified, Je contrary to
/0
( j l 10 CFR 50, Appendix B, Criterion XVI and the Wm. H. Zimmer QA A Manual, Section 16.1 as described in the Appendix to the report transmittal letter. psT/51-is-as)
~
Z Audit 77/24 indicated that S&L Project Procedure #PIfI-8.1, Revision 0, had been prepared to describe responsibilities and instructions, and to i j require a log and a file of nonconformance reports. The RIII inspector did not observe any other portions in any of the daal auditswhichwouldhaverepresentedcomprehensive)(plannedy and I meal
;;...... audits of the nonconformance program. Comprehensivej planned ! :-d ;: 'id': audits are required to verify compliance with the QA program and determine the effectiveness of the nonconformance program.
The audits of the nonconformance program should address such things as implementation, design reviews, identification of acceptance or rejec-t tion, disposition control, and notification cf affected organizations. be The audits generally appeared to$preactive in nature, in that specific problems, which had been previously identified, were audited. The audits did not appear , be progressive and programmatic, which may have identified new and generic problems. Failure by CGSE to perform a comprehensiv,e audit of the S&L nonconfor- [ mance program during the past nine years is contrary to 10 CFR 50 Appendix B Criterion XVIII and the Wm. H. Zimmer QA Manual, Section 18.1 07 0 as described in the Appendix A to the report transmittal letter. (358/81-13-23) N 27
,m._ _,_ , , , _ _
4 . I i
~
7 . No. F-3099 dated March 2f,1981 - bolt deficiencies No. F-7000 dated March 30, 1981 - weld deficiencies; missing braces; etc. i l No. F-7006 dated April 1,1981 weld deficiencies,V 4m' .; br::: : :_ l No. F-7019 dated M< April 6,1981 weld deficiencies; -f::i ; H:::; :::. 4 Per QACMI G-14, Revision 3, page 2, paragraph 5, a surveillance report, which identifies an in proe< cess nonconformance, wiLL be transferred \ nenCostherM*%) to an NR when the n:n;;;;'_1#; condition has not been acceptably f corrected within 30 days. A L c,.tw.,, .u a : Awp ~ .c s y-
- c/syy
- wl.or ,cuf./ -as -;a Measures were not established to assure that La<<all in process deficiency M disposis<tions are reviewed and approved by appropriate design and l
QA engineers. Thisiscontraryto10CFR50,AppendixB,criterionM d and the Wm. H. Zimmer QA Manual, Section 15.9 as described in the l Appendix A to the report transmittal Letter. (358/81-13-08) l . l
I INV002/L DRAFT /jp f7l9 y
/0 t
j 5.3.1 Allegation i i t
"A radioactive waste drain is clogged with concrete which carelessly was poured into the drain."
- 5.3.2 Background Information ff,,f pi,na.l ns e tj~ "
W y b -
.%. .I yracticr-is to-44trstr drains with water prior to plant operation to I M confirm that the drains are clear of all restricting debris. _ The radwaste
~
floor drains, which are nonsafety-related (not necessary for safe operation and shutdown of the reactor), will not handle any radioactive liquid until such material is generated following the start of plant operations. (
, ad fy IsN*"' , f,5. d /s The terms radwaste drains and radioactive waste drains,are synonymous terms for floor drains, which normally drain small amounts of radioactive water that can leak from such items as valve packings. The drains are designed to carry potentially radioactively contaminated water to the waste treatment facility.
5.3.3 Investigation 5.3.3.1 Interview of Individual A On February 24, 1981, Individual A, who was previously interviewed by representatives of GAP, was interviewed by NRC. Individual A stated
INV002/L DRAFT /jp i
?
that, whilte concrete finishing work was under way in the radioactive waste disposal area, he suggested to Kaiser construction personnel that a pipefitter be assigned to the concrete finishing crew to assure. concrete did not enter and clog the floor drains. However, they disagreed with ' this suggestion and, instead, directed the floor drains to be covered with duct tape to prevent concrete from entering and clogging the drains. i Individual A stated that concrete did enter the lines and clog the radio-I i active waste drains. On April 22, 1981, Individual A provided a written statement attesting to the preceeding information; however, he requested that the statement not be attached to this report. 5.3.3.2 Interview of Individual B Individual B stated that he worled as a pipefitter during 1976-1977, and worked with the drain flushing crew for the radwaste system. Individual B stated that during this period he observed floor drains in the system that were clogged with concrete, which he and others unsuccessfully tried to remove. 5.3.3.3 Interview of Test Coordinator and Startup Engineer Telephone interviews were conducted by the Senior Resident Inspector on February 12, 1981 with the Test Coordinator, who was responsible for the radwaste building drain flushing activities, and on February 13, 1981 with INV002/L DRAFT /jp
, the Startup Engineer, who was responsible for drain system flushes. Both individuals indicated that some drains were found to be plugged with unspecified debris. In all of those cases, the drains were cleared and j flow was verified.
5.3.3.4 Record Review and Onsite Observation ', The Senior Resident Inspector reviewed CG&E Flushing Procedure No. DR, Rev. O, for the drain system approved on September 23, 1977. The purpose of this procedure was stated as follows: "This document details the pro-cedure for cleaning the liquid radwaste floor drain and equipment drain piping to the various plant sumps and drain tanks. The floor drain and equipment drain piping shall be flushed until they flow freely and all large particulate matter is removed." Appendices to the Flushing Procedure indicated that 152 of a total of 169 of the potential radioactive waste drains related to the radwaste building floor drain tank, the floor drain sludge tank, the radwaste floor drain sump, the floor drain collector tank, and the chemical waste tank had been flushed and verified in accordance with the procedure. The appendices indicated that the verifications had been made in 1979. The licensee stated that the flushing activities were continuing. The Senior Resident Inspector made visual inspections of all of the accessible radwaste drain ports identified on Sargent & Lundy drawings A-533 Rev. F, A-534 Rev. F, and A-515 Rev. N. These drawings identified
B INV002/L DRAFT /jp
- i. .
, the drains in the radwaste building (elevations 496 ft, 527 ft, 513 ft, and 511 ft) and in the auxiliary building (elevations 567 ft-5 in. , and i 547 ft). None of the observed drain ports was visibly plugged. The 1
fo,11owing floor drains were covered with tape at the time of the inspec-tion and were therefore not inspected:
- 1. Radwaste Building--elev + ion 527 ft
~
(a) Drain Y-20
- -~ (b) Drain Y-17
- 2. Auxiliary Building--elevation 567 ft (a) Drain L-26 (b) Drain G-26 (elevation 562 ft-5 1/4 in.)
(c) Drain G-22 (d) Drain G-20 (e) Drain G/H-20 (elevation 562 ft-6 3/4 in.) (f) Drain H-22 (elevation 562 ft-7 5/8 in.) (g) Drain H/J-24 (h) Drin G/H-22 Neither the flushing records, nor the personnel interview} nor the Resident Inspector's observations confirmed or denied that the drains had been clogged with concrete. However, these activities did confirm that the drains, which had been flushed, would allow flow on the dates of the verifications. 4-
INV002/L DRAFT /jp
. 5.3.4 Findings NRC interviews with site personnel indicated that some drains had.been clogged with unspecified debris.
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- 5. ,,, yo ugh not considered to be related to this allegation, two items of
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.[ RIII investigation of allegations P-2/13 and P-2/16. These are addressed f in section (pages ) of this Investigation Report. -
1 4 l 5.5.5 Items of Noncompliance t
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5.5.1 Allegation
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" Sensitive parts on welding rods are possibly damaged through storage at iniproper temperatures and possibly lost through failure to follow proper paperwork and labeling requirements."
This allegation addresses two weld rod concerns: 1. AL f f Weld rods,were,possibly absorbing moisture by improperly controlling rod temperatures prior to consumption, which resulted in unacceptable welds.
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- 2. Weld rods,were not controlled because the paperwork and labeling requirements were not being properly followed. Therefore, welds may have been made with incorrect weld rods.
5.5.2 Background Information h For pressure boundary (pipe) welds, the ASME Code, Section IIIg 1971, , ! Article NB-2440 states, " Suitable storage and handling of electrodes, ! l ! l flux and other welding materials shall be maintained. Precautions j shall be taken to minimize absorption of moisture by fluxes and cored, fabricated and coated electrodes." ASMECode,SectionIIIf1971,ArticleNA-4460 states,"Measuresshall ; I be established to provide work and examination instructions for handling, ! storage, shipping and preservation of materials, parts, components, and - I i
ZIMMER/000 DRAFT /np appurtenances to prevent damage or deterioration. When necessary for particular products, special protective environments, such as inert gas atmospheres, specific moisture content levels and temperatures, shall be pr.ovided and their existence verified," For structural welds, the AWS DI.1-1972 Code, Section 4.9.2 states, "All electrodes having low-hydrogen coverings conforming to AWS A5.1 shall be purchased in hermetically-sealed containers or shall be dried at least one ' hour at temperatures between 700*F and 800*F before being used. Electrodes ' shall be dried prior to use if the hermetically-sealed container shows evidence of damage. Imm*diately after removal from hermetically-sealed containers or from drying ovens, electrodes shall be stored in ovens held at a temperature of at least 250*F. E70XX electrodes that are not used within four hours, E80XX within two hours, E90XX within one hour, and E100XX and E110XX within one-half hour af ter removal from hermetically-sealed containers or removal from a drying or storage oven shall be redried before use. Electrodes which have been wet shall not be used." i The purpose of the low-hydrogen weld rods is to keep hydrogen out of the [f' t weld. Hydrogen could cause underbead cracking. Thus, the above code a' requirements are intended to minimize moisture, which contains hydrogen, jak gg , i from being absorbed by the low-hydrogen wcld rods. C"e t I Kaiser Procedure SPPM No. 3.3, Revision 6, dated June 25, 1979 and effective [ during September and October 1979, states the following: [ t
ZIMMER/000 DRAFT /np "6.4 The Weld Rod Clerk shall issue all filler material on a weight basis. He shall record on the KEI Weld 2 form the weight of all bare rod and covered electrodes issued.
"He shall also, record on the KEI Weld 2 form the heat number and/or lot number for bare rods, consumable inserts and backing rings, and the heat number and lot number for covered electrodes prior to use. "7.3 The Weld Rod Clerk shall weigh all bare rod and covered electrodes '
returned to Central Storage and record the weight on the KEI Weld 2 form. A new KEI Weld 2 form will be made out for each new issue of electrodes to and for each welder." 5.5.3 Investigation 5.5.3.1 Interview with Individual A On February 24, 1981, Individual A, who was previously interviewed by .. representatives of GAP, was interviewed by NRC. He stated that he observed unaccounted for weld rods (weld rods without accompanying KEI-2 weld rod issue forms) onsite and has seen weld rod warming ovens unplugged and not being maintained at the proper temperature. [ I Individual A also stated that during September and October 1979 a pipe- l I fitter was not assigned to the weld rod issue point during the evening ~ i shift to account for weld rods. He stated that weld rod and weld issue , t slips were left out unattended for anyone to pick up and use.
ZI. TIER /000 DRAFT /np On April 22, 1981, Individual A provided a written statement attesting to the preceding information; however, he requested the statement not be attached to this report. 5.5.3.2 Interview with Individual B On April 14, 1981, Individual B, who was previously interviewed by representatives of GAP, was interviewed by NRC. He stated that Kaiser required weld rod ovens be maintained at the proper temperatures at all times. He said he could not state that every welder maintained his oven at the right temperature, but as a supervisor he assured his own men did. He stated that weld rod issue forms (KEI-2) were occasionally lost and, in those cases, it was a common practice onsite for welders at the time of fabrication to get a blank issue form, falsify it, and present it to the Kaiser Quality Control Inspectors in order for the weld to pass inspection. He said this was frequently done months after the fact by Kaiser construction supervisors who falsified weld rod issue forms to complete weld documentation packages. He said by doing this they did not i have to cut out and rework welds. (Note: Statements alleging falsifica-tion have been forwarded to the NRC Office of Inspection and Auditing for ;. investigation.) I i On April 14, 1981, Individual B provided a written statement attesting to the preceding information; however, he requested the statement not i i be attached to this report. j ZIMMER/000 DRAFT /np 5.5.3.3 Record Review and Inspection During this investigation, the Resident Inspector reviewed the receipt documentation for E7018 (low hydrogen) weld rods purchased on orders No. 34356, 35720, 37587, 39075, 39382, 39556, 39971, and 40318. The receipt documentation indicated that the E7018 rod had been received in sealed moisture-proof containers. The Resident Inspector also verified that low-hydrogen electrodes (rods) I that had not been issued to the field were clearly identified and stored in a clean, limited access, and dry area. In addition, in the field issue rooms (rod shacks), the low-hydrogen rods were either in sealed containers or in holding ovens at temperatures above 250*F. The licensee provides portable rod warmers to be used near the work activities to maintain the weld rods in a dry condition until used. KEI Welding Filler Materials Control Procedure No. SPPM 3.3, Revision 7, paragraphs 3.5.4.2 and 3.5.4.3, respectively, state: '-
"When covered electrodes are removed from a holding oven to be issued to welders they shall be placed in a portable rod warmer. !
Only one classification and heat or lot of electrodes shall be : I stored in each individual portable rod warmer. Each portable rod warmer shall be uniquely marked for identification purposes i and shall be checked on a monthly basis to assure that each rod j warmer maintains a correct temperature between 175'F and 400*F." .
. . ZIMMER/000 DRAFT /np "All covered electrodes exposed to ambient conditions for more than four hours without coming in direct contact with water shall be returned to central storage for rebaking . .. The Resident Inspector reviewed the December 1980 record for the Daily Temperature Check of holding ovens W50, W27, W38, W25, W39, W19, Wil, and W26. The record indicates that oven W50 was 5'F under the specified 250*F on 3 of the 22 days checked; oven W25 was 5'F under the specified 250*F 1 of the 22 days; oven W39 was 15'F under the specified 250*F on I day out of 22; and even W26 was 10*F under the specified 250 F on 1 day out of 22. The Resident Inspector reviewed the record for the monthly check of partable rod ovens (warmers). The record indicated that the temperatures of 209 warmers were checked on January 3,1981 and that all were within the required range of 175* to 400*F. The Resident Inspector also observed that unacceptable rod warmers in i the field issue rooms were properly tagged to preclude their use and were segregated in a clearly marked area. A review of reports of past NRC inspections disclosed the following items of noncompliance regarding weld rod temperature control and storage. t e i t 6
. . ZIMMER/000 DRAFT /np Table 1. Noncompliances Found at Zimmer Inspection Corrective-Rept. No. Noncompliance Action 75-05 Holding oven contained both The stainless steel rod e
stainless steel and low-hydrogen was placed immediately N *.LJ 3.j(4 carbon steel rod. I i* 8 in a separate oven. s 76-07 (1) Portable electrode (warmer) Procedure requires ,) oven was not plugged in and rebaking rods if out \i g I approximately 10 electrodes of oven for 4 hours. I were not in the warmer. . (2) Two 50-lb cans of low-hydrogen Both cans of weld rod ,,
)f (7018) electrodes had holes in were quarantined and ?
O them and several cans were later rebaked. l l damaged. (3) Documentation for temperature Calibration had been veri-i j calibration for three weld rod fied daily by temperature yI , holding ovens was not available. < indicating crayons and the v , 5 ! results were documented in )
- i' the Daily Weld Log. The NRC inspector did not see the log at the time the non-compliance was identified.
~
ZItefER/000 DRAFT /np Table 1 (continued) Inspection Corrective' Rept. No. Noncompliance Action 76-11 Partially burned and unburned weld Additional instructions ( rod was found lying outside con- and retraining were given. ( I/ tainers or ovens in several locations f (f $ g .'/ f, at the plant. y o' 7s - J ,} gj
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77-02 Holding oven contained both stain- The two types of rods 6 4 less steel and low-hydrogen elec- were_placed in different k*7 g trodes. ovens. av l . 7 79-Of (1) Approximately three dozen Unused weld rod and stubs ,gf
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- g. r partial, damaged, or unused I weregatheredanddisposed.(YI*;9 electrodes were found lying Additional training was * ) .' .*
A+ ' \ } on the floor, scaffolding, _ given. I and in a cable tray. (2) Three rod ovens were not pro- These ovens were removed b g i vided with thermometers for from service. t F directly measuring oven tem-I peratures. Stickers stated [ the ovens had been calibrated 4 4 months earlier.
. . ZIMMER/000 DRAFT /np Table 1 (continued)
/
Inspection Corrective' Rept. No. Noncompliance Action
/
/
(3) Calibration of two rod ovens Both ovens were recali-was past due. brated while inspector Uf e' was on site. 4 79-12* Portable oven found unplugged but
,, l'4 warm and weld rod / stubs not in .KW ';
y/ bucket. k 79-15 1 (1) Could not tell operability Portable rod warmers were status of portable weld rod numbered, checked for p heater boxes. proper temperature, and
#ff noncomplying warmers V/ -
l 1 k I removed to repair area. ' (2) Filler material and consumable Weld rod location and N t inserts maintained in ovens A' l identification map now (/ I l' and on shelves without trace- maintained for each oven. ' ability to heat / lot numbers.
*Not cited as item of noncompliance.
l l
ZIMMER/000 DRAFT /np Table 1 (continued) Inspection Corrective Rept. No. Noncompliance Action (3) Filler material heating ovens Personnel instructed that used to heat lunches. cooking food in weld rod ovens was grounds for dismissal. (4) 50 containers of nonconforming Quarantine zone within the weld rod were not identified rod issue area was estab-as nonconforming and were not lished; 50 containers were segregated from conforming placed in the quarantine material, area until they could be rebaked. 80-07 Two portable warmers were not Additional signs were plugged in. posted and additional instructions were given. , 80-14 One portable rod warmer was not Additional instructions P l ugged in, were given. Inspection " personnel will include observation of weld rod warmers in their daily surveillances .
ZIMMER/000 DRAFT /np Table 1 (continued) Inspection Corrective, Rept. No. Noncompliance Action 80-19 One portable rod warmer was not Welder was dismissed for plugged in. failure to follow proper procedure. The citations concerning portable rod warmers not being plugged in and holding ovens containing different types of rods were violations of site procedures, not the ASME or AWS Codes.
\ \ \
5.5.3.4 Weld Rod Paperwork sad-Lebelice-RequiYements s s s ~ x 1 The paperwork used to account for weld rod is the weld rod issue form (KEI-2). The weld rod issue fcrm requires signatures from the welder, the welder's foreman, and the weld rod issuer, which permitted the welder to obtain weld rods for a specific weld from the rod shack (field storeroom). ; 5.5.3.4.1 Review of Time Cards ! I' I-The RIII inspectors reviewed KEI Daily Time Cards (personnel time records) i for 21 different days and some respective weld rod issue forms (KEI-2 forms) [ to determine if a weld rod clerk was assigned to the field and rod shack
.. . ZIMMER/000 DRAFT /np during the second shift for September and October 1979. The time cards indicated that two individuals (E. Kern and G. Jones) had worked overtime (after 4:00 p.m.) in the rod shack for 1 to 4 1/2 hr on 20 of the'21 days (1 hr for 10 days,1.3 hr for 2 days, 2 hr for 3 days, 2.5 hr for 2 days, 3.5 hr for 2 days, and 4.5 hr for 1 day). The following inconsistencies were identified between the time cards and the weld rod issue forms:
- 1. On September 5, 1979, only Kern was assigned to the rod shack for I hr during the second shift, but the signature mark on weld form 200379 did not appear to resemble Kern's signature mark and there was no signature mark for the rod clerk on weld form 200380.
- 2. On September 10, 1979, no one was assigned to the rod shack during the second shift, but weld rod issue forms 200431 and 200432 has scribbled marks indicating a rod clerk's signature.
9
- 3. On September 11,14,18,and28,197$,Kernwastheonlyoneassigned to the rod shack for I hr during the second shift, but the signature on form 200485, 200486, 200458, 185618 185617, 185732, 185745, and 185733 appeared to be representations of Jonehinitials.
l
- 4. On September 17 and October 18, 1979, only Jones was assigned to the !
rod shack for 1 hr during the second shift, but the scribbled signa- l ture on forms 200487, 185614, and 184744 appeared to be representations of Kern's signature.
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assigned weld rod clerk. Thus,the*-u,,.f;.) r::Sility of the weld rodpas not )(*8 v g-n.w<tds.J<tark. ^,,._x ,,j 7,,, n . , j. g;,, e maintainedg as requiredg 6.< ' " * --~' _, , j ,
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n :s Y 'thaf 5.5.3.5 h_a M ;'~ h_a ,iews Wey g.) LMy k e # >~ ~ tc _ f Neither the personnel interviews, nor the record reviews, nor the obser-vation of activities related to weld rod control identified any specific meaning of the alleged concern about " labeling requirements."
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; 4. The RIII inspectors reviewed the H. J. Kaiser Company Procedure No.
QACMI G-14, Revision 3 for initiating and documenting QA Surveillance
- ReportsjSR,Page 1, paragraph 2 sa<tates that surveillance reports wiLL be used to identify an in process nonconformance which can be corrected without processing a Nonconformance Report (NR). The QA Surveillance C he s k p o m '$ N I NtM Yf Report form provides a :b"4 #4rt Sn if-in process deficienc(gitJ,
{ 3 f,1$tti Tl QA rveiLL nce Repo ts do not r quire review an approvk by the ferse ne/ app opria S&L, GSE ;:- - mai a - , "'E ? " *"; or , s requ' red on ncon rmance R orts. I Per QACMI G-14, Revision 3, page 2, paragraph 5, a surveillance report, which identifies an in process nonconformance,wiLL be transferred to an NR when the noncomplying condition has not been acceptably corrected within 30 days. wetC no? y
, h feasures3established to assure that all in process deficiency end dispositions are reviewed and approved by appr.opr,iate design and QA engineers. This is contrary to 10 CFR 50, Appendix B, Criterion XV and the Wm. H. Zimmer QA Manual, Section 15.9 as described in the Appendix A to the report transmittal Letter. (358/81-13-08) e
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- 3. The RIII inspectors made visual examinations of the installed materials and reviewed pertinent documentai< tion to determine if structural
- beams, piping, and weld rod were traceable to mill certifications.
- a. StructuralSSBeamsSU (1) The traceability of the W8X17 bearr.s, installed by the Bristol Steel Company in the blue switchgear, was property maintained by recording the respective material heat numbers on the applicable drawing and/or the beams themselves.
W (2) The traceability of some l8X17 beams, installed by H. J. Kaiser, Company, was not maintained. No records were documented to identify heat numbers. Some beams were makred with heat C numbers. The beams, in<dentified by the symbol **m> on Attachment to this report, did not have any traceability maintained. These beams were located in the auxiliary bu4 ding blue switchgear room at elevation 546 feet. F ther- re, se eral hun red et of W8X1 bea. we pur ased n P.O.- an rece'ved rom i ho wa not ap oved er ,or.
'hsefYN These beams were not controlled to prevent their use in f.
safety related systems. MILL certifications were available f < for these beams. On April 10, 1981 the Licensee stated that thest beams had been made available for installation in safety I 2.
.. )
4 feS*' - _ fu e 'fb er ostwt , Jev'evul housaeY lref ol W?X /7 Ae.e,;.3 m Were pa, S+ sed .r ' fZ<- lbw.- A y- d u osusu $ov) lnse aw t/c rebn w4 red wwt st r y w .n k 1 7 0. /02?S - 78E 3 9'9 2 (ec f' Jreel E~e e de s). E - e 3%,2 u s- a. .r. ms sy ,i, - is:: .
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related systems based on the mill certifications and without regard to the vendor not being approved. The Licensee also stated that the credibility of the mill ertifications would be established. Failure to assure that the beams were purchased from a vendor that had been approved is contrary to 10 CFR 50, Appendix B, Criterion II and the Wm. H. Zimmer QA Mn<anual, Section 2 as describd<ed in the Appendix A to the report transmittal letter. (358/81-13-06) e i p--- ---- ; l
i i iA C. RecordsSSReviews5U l The RIII inspector reviewed Revision 2 dated May 4,1978 and i j Revision 3 dated November 15, 1979 to Kaiser Field Construction I l Procedure No. 2-24 concerning two inch and under piping and hanger drawings. Essentially, these procedural revisions i defined how isometric drawings " construction aids" were drawin<< , drawn at the site by Kaiser Engineers, Inc. based on Sargent & Lundy's design criteria. S&L's design criteria were specified in specifications, drawings, instructions, etc., in the form of general requirements for various classes, types, and i configurations of piping and hanger systems. The procedure indicated that the isometric drawings were drawn to translate the S&L general design criteria into details <ed specifications for individual piping and hanger systems. 4 When field changes se6 the designs on the original isometric svare n eces sary drawingsAd ue to interferences with other plant installations, the procedure provided controls by which changes to pipe and l hanger configurations and Locations,g could be made in the field by marking the applicable isometric drawings.' The n< marked changes could also include additional material, welds, and/or fittings. e
l.- The marked isometric drawings changes required review and approval by the KEI Piping Enge<ineering Department. 4 I 1 Procedure No. 2-24 also stipulated requirements in<<and I interfaces (including QC procedures) to assure that quality assurance inspections,,< relevant to the installation of the i piping and hangers, would be performed and documented. 1 i i l The pro <actice of installing and modifying small bore (two inch and under) piping and hangers in accordance with adequately controlled designed and quality assurance requirements vo-I c^---- th...wh;; - ^^'- rt:-t '-f;::c, ;..f violates no NRC requirements. The NRC has identified problems with the installation of pipe w4.44 wen t hangers and the quality assurance inspection programpfgalluded to in Procedure No C These problems were documented in Region III Inspection
. -~ _ _ - . .
( Nepo rt s No. 79-37, . The corrective measures to resolve these problems have been and l are being closely monitored by Region III. The corrective l l measures involve additional redesign, drawing changes, and l field modifications. e l 1-- -- -
i
. Later documentations indicate that ultrasonic and visual examinations were made of the welds on the three questionable pieces. '
1 . The UT and visual examination records indicate that the welds
, were acceptable.
I i 4 l ALL five pieces were installed in the main steam release system. During this section, the RIII inspector made visual examination of the welds on the spool pieces. He identified no unacceptable indications. He also concluded that space on the thickness and configuration of all the pieces, radiographyywould not be a credible volumetric technique of examination. The RIII inspector stated that ultrasonic and visual examinations were the proper NDE techniques for these pieces. The RIII inspector reviewed and stated that the UT results appeared proper and were acceptable.
- 8. At least three sources contacted by Applegate confirmed that l an estimated 20% of the plant's prefabricated welds are defective.
i Findings $U t l } l This allegation was not substantiated. e l i l l
. o .
i ' l FORWARD i The following allegations (numbering 1-19) came to the NRC from the Office of Special Counsel of the Merit Systems Protection Board (M.S.P.B.) in a - documented Reyw.st for :n Investigation Pursuant to 5 USC 1206 (b) (7). '
. The Request was submitted to the M.S.P.B. on behalf of Mr. Thomas W. Applegate by the Government Accountability Project (GAP) of the Institute for Policy Studies (IPS). It is noted that GAP and IPS are not agencies of, nor affiliated with, the United States Government.
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t 1 . , The RIII inspectors reviewed approximately 180 Construction
< i l Inspection Plans (CIP), inspection records, for the hangers in '
i
! - the cable spreading room (elevation 536 feet in the north section j ggp and fkk 10CfetJA SSle) kf S < ; of the auxiliary building) Theprecords g indicated that ALL of the 8:aa[
8 me:t:d and accepted in December,1980 and 5 field and /vender welds were{reigded efter reps:rs wets oe ede .fo yefofs f, b [' January,1981. ,,, ,,.g fA,,, f,// ../ f4e fy/ f. ,,, ,e The unacceptable welds identified on hangers 70HFEC165,15H2FEC175, l 9
$ j 14H11FEC146, and 16H1FEC156 were not controlled on any QA document.
kW .) ' l This is contrary to 10 CFR 50, Appendix B, criterion XV and the
$4M*
Wm. H. Zimmer QA Manual, Section 15 as described in the Appendix A -
'f-i to the report transmittal letter. (358/81-13509)
\
_I :LSj InspedI88 $ l NoArecords were available to indicate that in process inspections 7d J ! t
.1e:n- 1se s.u .- a. ~ .eu.
weremadetoverifyproperfiltermetal,weldprocedure, welder's'$S;yyg an qualification, surface conditions, etc., as required by the 4 ** g f e< r u ; e /. ens e s ,d f AWS D1-1-1972 code, section 6 ' V **E f % %.&f Q&$. '*e< .. " b ? !lL n.h. j.
$ Discussions with the pertinent QC management and inspection desumenfed on 11.s .4We czPs personnel revealed that the weldsj ad h been n< inspected after being painted. The licensee stated that the visual examinations of the tray hanger welds were bs<ased on H. J. Kaiser Company Procedure No. SPPM 4.6, Revision 8, dated August 29, 1980, e
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I AllegationSS151L MEI "Kei;;gknowinglyinstalledandrippedoutunsuitable[ain/teamfelief I
-4MGM- piping, at ,an estimated Labor cost of ': :: "c-dr:d :-d T ...;
'A; ::..~ %;;; ; 320,00 i
4 II FindingsSLL !
+ .
The allegation was substantiated in that an economic decision was made to installpiping,ofwhichap/ *de.h proximately nsfun */ 3-10percentwouldhavetobe removed, due to continuing,jchanges in design loads. No attempt was made to substantiate the estimated Labor cost for the portion of pipe that was
-k olsfc
;r;;j .
installed and removed. ,w c.o., ;;;t: :; f! dt: 1., iiir h g tet;i d:r'; 7:difi;;ti:n r:1: r * +^ + " ^ 4- c+::: ":'4d **n4 9 0
'5:
s44Y "III ' :;::t r id;...:'IsJ No items of noncompliance orAconcerns 4%rt= i j were ohai'4 c-t t , yd'tg - R. ;t .;t i;,. u' il.s F,0R-pg..,g'*b 7
- f 6 I i l !
III Investigation $U_ - l A. __ BacLaround$UInformatinniu i The llegati a % w h ncer asg-te.g.ss w so o with e tary [a . costs o onstructi the Main eam Re S'ystem piping. \No ) l in .ation s received o indicate acceptab s quallt{ of t e se l related construct" n activit1 . I
- l
B. Personnel $SInterviewsSU_ .
- Lherv',m s9 LL*kd ?
On February 24,1981, Individual "A", who was previously interviewed by representatives of GA L&.ved'A" was interviewed,emd stated Kaiser instal-A Led a large portion of the MSR piping, knowing sections of it would later have to be removed after installation. He recalled that two years after its installation Kaiser removed large sections of the
& A btke piping h the A 525' Level of the reacto containment building chmn-Nk u: 4 .- 4 Left the pipe sections above that level in place.
On April 22, 1981, Individual "A" provided a written statement
- nform.:non.; y kewe.<r:
attesting to the aforementioned int _ ...' r r x r, he requested the statement not be attached to this report. g g, g ,g M /eb d 5 d On April 14 and 16,1981, Individuals "B" and "C", respectively, who allegedly provided information regarding this allegation to f representatives of GAP were interviewed.enefgstated
%V they had no j information concerning this allegation.
L,4 N'.*aa.a of M .C..*5 e'..bv. _ [4 During the period of 2/9-13/81 and 2/23-27/81, discussions with Mr. H. C. Brinkman, Principal Mechanical Engineer, CGSE, indicated ;
~
I that in 1975 a nuclear power plant in Germany discovered the need newly Menta+5ed [i to redesign the relief system based og e w= discharge loads. There- , l fore,severalutilities,includingCG&E,decidedonamodificationg i l l
l to replace the already installed rams head safety relief valve (SRV)
- discharge devices with quenchers.
DNB3NNNh In 1975 CG8E. decided to start the quencher modification, knowing 4,a he y that part of the pipin9r C s- installechfwould later have to be Jue to the dent;/;.J; n ./ rrtw dus 4 ye loads. y removedp The basis for the decision was that approximately 90A97% of the original quencher modification would be acceptable and there-4. fore only 3A10% would be subject to rework. CGEEN i d ..~ con-cluded that it would be less costly to go ahead in 1975 with the installation activities rather than 4e delay the construction schedule until the quencher modification design was complete. To date, the modification design is not complete. The NRC has been aware of the modification activities as described
/( \f I in the Mark II Design Assessment Report, Chapter 2.0 -- Zimmer Empirical Loads, ZPS-1. The RIII inspector observed that the latest
,g l documentation received from the NRC Licensing Branch No. 2 at the y site concerning the modification activities as NUREG-0487, Supple-OJ -
"\ ment 1, titled, " Mark II (bntainment Lead Plant Program Load !
0)~ Evaluation and Acceptance Criteria." It should be noted that there I may be more changes in the future due to additional load definitions. C.. _ e eM ed M M_bk M 1w . The modification has required the replacement of 10 inch Schedule
~
f 40 pipe with other 10 inchSchedut pipeofdifferentconfigurations(kh 10 inch extra strong pipe, and 12 inch extra strong pipe.
r b [ During this investig ion the License provided co + figures for TAC , [ . modifica *on to date. e total Labor c t was $823,7 .00 a he\ / e \ \ ,' k Y' +otal mater L plus Labor ost was $1,183, 0.00. The NR made no
'N
- O'
[s. at empt to cor oborate these osts or the Lie see's claim \ that it '\ ' was eaper to p ceed with an 'nstallation whic was known, be re instal ion, to re ire rework. The RIII inspector reviewed all revisions to the KEI isometric drawing PSK-1MS, Sheets 21 and 21 A, which were pertinent to the main steam relief piping. No additional changes of the magnitude addressed in the allegation were identified. The revisions identi-fied the following changes: Rev. O Redrawn - original configuration replaced 9/8/76 Rev. 1 Hangers added 3/31 /77 1 Rev. 2 Eight Lugs added 1/10/78 ' Rev. 3 Hanger changed - 5/5/78 i Rev. 4 New spool pieces added, welds MS212 and 4/3/79 , MS195 voided per S&L l l Rev. 5 Piping tee section added 6/18/79 l l . Rev. 6 Weld MS160 and a 4 inch dimension added 10/1/79 ; l I Rev. 7 Field marked (re? tine) updates added 1/9/80 i ( t
O
- Rev. 8 Welds K-461 and K-463 changed; weld K-592 - 9/27/80 changed to K-593 per NR-2499; hanger detail section D-D added Rev. 9 We.Ld K-592 changed to K-461; and weld 9/4/80 K-593 changed to K-594 AtL of the above revisions pertained to the aforementioned quencher modification.
The RIII inspector reviewed the QC documentation for the following main steam relief piping field welds: Nos. 160, 160A, 267A, 2678, 267C, 2670, 268B, 268C, 2680, 459, 460, and 461. The records indi-cated that the welds had been accomplished in accordance with ASME Section III 1971, Summer 1973 Addenda. i The RIII inspector interpreted the radiographs for the following l main steam relief piping field welds: .Nos.160A, 459, 460, 461, 462, and 594. 6 { j It is noted that there are approximately five to seven radiographs for each of the above welds. The varying number of radiographs are ; necessary to cover the entire 360 degrees of each pipe weld. The l-radiography was performed in accordance with ASME Section III 1971, [ Summer 1973 Addenda. The RIII inspector identified no unacceptable l weld indications on the radiographs.
w i i 4 The above discussions and reviews indicate that the alleged activi-
. ties were performed in accordance with the KEI QA program.
{ No items of noncompliance or deviations were identified. i 1 I 2 i I a O I i l 5 i f r i
. 1 e
O i b
. 4 i.
1 e' k
INV002/Q DRAFT /jp 77_ W ThefIIIinspectorsobservedthatweldinspectioncriteriato verify weld procedur,e, welder qualification, filler material,. joint cleanliness, bevels, and damage had been deletedIor
~
K designated as not appliacble, N/A, on the following DEI-I forms
\
j (weld inspection records '# System or ISO. Beam or Other i Component Dwg. No. Mark # Information (1) Drywell Support Steel S398B 29 Detail E of S-437 (2) Drywell Support Steel S398B 2 stiffners Line No. MKC 1/2 x 6- 17S493 3/4 x 25-1/8 (3) Drywell Support Steel S398A 125 Line No. EL-535 191* (4) Drywell Support Steel S398B 67* Detail 13 or 493 t Detail 2 of 447 l (5) Drywell Support Steel S398A C-63 Bottom Plate (W8 x 10) i (6) Drywell Support Steel S398A W8 x 17 ' Cum Lugs N a
fgV~g ,,/ j__..--._....-........_..___,_,, ,_ INV002/Q DRAFT /.jp (7) Service Water System PSK1WS32 55H Line No. 9 IWS17A18 i t The records for the Drywell Support Steel indicated that the deleted i criteria existed at least from July, 1980 to January, 1981. The 4 record for the Service Water System indicated the criteria was designated as not applicable in November, 1979. The inspection criteria to verify proper fit-up and tack welds was also designated N/A for the above weld activities on the Service Water System. i- - ,b.C The licensee could not readily determine if the AS!fE Code Section III-1971 or if the AWS D1.1-1972 Code inspection criteria governed so'me of the above activities. Regardless d
, y kS/A E Codc &M .'
s n e {, J 1')4,NA-4I30fa7 - "As used in this Section of the Code, Quality Assurance comprises all those planned and systematic actions necessary to provide adequate confidence that all components, parts, or appurtenances are manufactured and/or installed (as applicable) in accordance with the rules of this Section." f
, <h .,b.
b,/(G-b' (b)l,; NA-4420 --hThe manufacturer and/or Installer shall maintain
/
lE, t a written description of the procedures used by his organiza-tion for control of quality and examinations, shgwing in detail the implementation of the quality assurance require-ments of this Section of the Code."
-2
INV002/Q DRAFT /jp
!* h[.
(c NA-4510 - "Inprocess and final examinations and tests shall be established to assure conformance with documented instruc-i I tions, procedures, and drawings." ' i h',(d7f. NA-4442.1 - " Welding and brazing materials for all classes j of construction shall be controlled in accordance with
- NB-4122...."
j NB-4122 - " Welding and brazing materials shall be identified
~
and controlled so that they can be traced to ach component and/or installation of a piping system, or else a control procedure shall be employed which ensures that the specified materials are used." J f '(e7 NA-4451 - "... Measures shall be established to assure that processes including welding and heat-treating are controlled in accordance with the rules of this Section of the Code and are accomplished by qualified personnel using qualified procedures." - p .
,'{ *,(f) NB-4230 -- identifies specific requirements for fitting and I
l aligning of weld joints which must be verified. I l
/[,-(2) The AWS DI.1-1972 Code states:
/
i
-3 .
1
INV002/Q DRAFT /jp t i j a.441 Section 3.1.1. - "All applicable paragraphs of this section I shall be observed in the production and inspection of welded f assemblies and structures produced by any of the ' processes acceptable under this Code." { p.Jb) Section 3.2.1 - " Surfaces and edges to be welded shall be i smooth, uniform, and free from fins, tears, cracks, or other i defects which would adversely affect the quality of strength of the weld. Surfaces to be welded and surfaces adjacent to a weld shall also be free from loose or thick scale, slag, rust, moisture, grease, or other foreign material that will
; prevent proper welding . . . ."
g.(c) Section 3.3.1 - "The parts to be joined by fillet welds shall be brought into as close contact as practicable. The gap between parts shall normally not exceed 3/16 inch .... [.(d) Section 3.3.7 -- addresses tack weld requirements which must be verified. - g--(N Section 6.1.1 - "The inspector designated by the Engineer shall ascertain that all fabrication by welding is performed in accordance with the requirements of this Code. C*,(f') Section 6.1.3 - "He" (the inspector) "shall be motified, in 1 advance, of the start of any welding operations."' I l l l l
INV002/Q DRAFT /jp (,, fg) Section 6.2 - "The Inspector shall make certain that only (* materials conforming to the requirements of this Code are used."
-f .
.I 1
~
, jh) Section 6.4.1 - "The inspector shall permit welding to be performed only by welders, welding operators, and tackers
, who are qualified in accordance with the requirements of I
5.2." d
. ,411 Section 6.5.2 - "The Inspector shall make certain that only welding procedures that meet the provisions of 5.1 and 5.2 are employed."
, Section 6.5.3 - "The Inspector shall make certain that electrodes are used only in the positions and with the type of welding current and polarity for which'they are classified."
/
h(k) Section 6.5.4 - "The inspector shall, at suitable intervals, observe the technique and performance'of each welder, welding operator, and tacker to make certain that the applicable requirements of Section 4 are met."
'3 . m M M c TTW
'y. ,c'. The weld inspection criteria which was deleted or designated as not applicable is contrary to 10 CFR 50 Appendix B, Criterion III and the Wm. H. Zimmer QA Manual, Section 3.3 and 3.13.1 as described in the Appendix A to the report transmittal letter. (358/81-i3-26)
O1 rt'. Zimmer/np INV001/A
, 7, } ViiJ 6,wd ca.h a ot St-rudw a.I SM ha~ s W DV T III inspectors made visual examinations of structural steel f beams in the blue switchgear and cable spreading rooms.
l 6ew Owd b !
,{ .i. w Yc/ Zimmer/np INV001/A 3, L jtllf L h% & wa G%.frkfypt S4 * **' )
The spector reviewed the Bristol Steel and Iron Works QA Manual, Appendix B, Section 1. tied " Erection Quality Control.". t z Paragraph 1.1 states that "The Erection Quality Control . .',. is
, ' s
~
4 the responsibility of the Project Saperintendent, who reports to 1 the Project Manager." i Both the Project Superintendent and the Project Manager had cost 74 a is co fr ey and scheduling responsibilities.g 10 CFR 50, Appendix B, Criterion I
;. ' [g w . -! : . - ~ 'M M t s dese.r.%e./ i 11.e A pfee A x ,4 fe 14a seguires sufficient +dependcuse L um must end schedula eeyse t f< -r trM/ /e1te's. (35S/s1- n ~fi)
The RIII inspector reviewed the Bristol Quality Control Steel ErectionReportfQ-7 nspection repor ) dated July 14, 1975 for theinspectionofthebeamsinstalledonelevation546ftfbetween f column rows 15-22 and F-L.
.tht The report was a boilerplate .whi+tr did not identify any of the following specifics: weld procedure numbers, welding materials (types), welder identifications, bolting procedure j numbers, or beam heat numbers. The report only indicated acceptance l
l (by signature) of general categories including those listed above and others. tG CFR 5&;-Appendiv % iterion-VIh requi ar de c-umetr-fr.s .s e n % .. f f, _ -
~~
f/' t-acy awidence p'Yf 50: AA JNS h/ to-edentify-the_speci-fie--requhnt. H ?
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e
/"spe,9riteribn XVII raq"4 re 2c recorde.tc includs da i. s u a = =7 T
qualification-of- personnel prD'CWdurespand Equipacui. - 7hD rs '* Tr~='y 1* ie <- F K 4 4, 4 G tee." 4 v-'.L ,J % t J... d2r.= a 4 Ma. .J, .ru t!h i 7 / / <.s dewa.7yr~f.x 3, se./ ,:. na. ,4p p /.,, ,4 r, 74 y r n >~.ff i
/* rte.e. ( 25 2;/ !!J'sa )
/
The insu -ficEent QA independ'ence;-t-he unspecifie -requi-respbuts] tid
,t, h inad ' nata recor s. taken cumulati ely, compr se a QA y rogra
\ 1 *
\ \ \
that-is- centrary to 1Q-CFR 30, Appendi -B;-Criteribn Ihand the
\ \ \ J \
Win..JL- Zimmer-QA-Manuai;-Section pas-described-in\ th e Append s \ so- \ ' totherepo\rt transmittal letterf_ (y58/81-13-05)g\ 1
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INV002/H DRAFT /jp
.3' ,
1,T,_M 5M " ["?C'_.h6*?E y The spectors reviewed the H. J. Kaiser Company Procedure No. d J.Jrt .
"/p _, QACMI G-14,, Revision 3afor initiating and documenting QA Surveillance f(' ) !
GA< Mi C-l'/f y W Reports Sl}I f j ge 1, paragraph 2 states that surveillance r'e ports will f
\ M beusedtoidentifyinprocessnonconhmanceswhichcanbecorrected 2 without pro' cessing a Nonconformance Report (NR). The QA Surveillance Report form provides a checkpoint to identify in process deficiencies.
.7he following QA Surveillance Reports have been initiated to identify
, deficiencies or nonconforming items:
No. 2899 dated December 18,1980-{bolttorqueverificationmissed No. 2903 dated January 14,1981--[weldverifications=issed No. F-2909~ dated Janaury 16,1981-3oltsmissingorloose n r No.2914datedJanauh 15,1981- ,,NDE hold points bypassed #-
- No. F-2941' dated January 28,1981--[ broken flex bolts fail to torque, etc.
- 1 No. F-3070. dated March 24,1981--[boltinstallationnotverified No. F-3071 dated March 24,1981--[ elongated holes in baseplate No. F-3072 dated March 24,1981--[ elongated holes in baseplate No. F-3073 dated March 24,1981--[ bolts do .not meet torque requirements e f
No. F-3074 dated March 24,1981--[ bolts stripped i No. F-3075 dated March 24,1981--[ bolt holes elongated l i No. F-3076 dated March 24,1981-3angerneedsshimmingandspallingrepair , 4 No. F-3082 dated March 25,1981--[ cable is too short I No. F-3083 dated March 26,1981--[unacceptablewelds No. F-3099 dated March 27,1981--Soltdeficiencies - No. F-7000 dated March 30,1981--[welddeficiencies[missingbracesktc. x 9
n . INV002/H DRAFT /jp
& C No. F-7049 dated April 1,1981--[ weld deficiencies i No. F-7019 dated April 6,1981-,-" weld deficiencies
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p,yg; .rt~a d'lre vi % -1 f sic e in geQACMIG-14, Revision 3,page2, paragraph 5,asurveillancereport[ v i
-which identif t n in process nonconformance, will be transferred to .,,
an NR when the nonconforming condition.has not been acceptably. t, s * \ ' s Nonconforming items wculd f in[effectj represent changes to the original h'
~2 /
design, when acceptable at is. .Scrveillance reports that identified ,7 .
, E nonconformingitemsandwerepottransferredtoanNR[didnotrequire / '
reviews by appropriate engineers. , Therefore,' measures were not estab-lished to assure that all in process deficiency dispositions are re-viewed and approved by apprcpriatri design and QA enhinee'rs. This is i s
, t .
contrary to 10 CFR 50, Appendix B, Criterion Xgand th's Wm. H. Zimmer QA Manual, Section 15.9xas described in JILppendixAtot$ereport AED-x
' zw transmittalletter7g58/81-13-08)g
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i f. s g i f e e r-2- ' s I
j , INV002/I DRAFT /jp l', 7g O .i. 7 2 f E c- w r,.]iY , y I* rSo hr The RIII inspectors observed six installed conditions which- did not
' m comply with one or more of the following F S,A,R, criteria concerning PrYr
! cable separation: ;
\ /.-m /
& ,6
(. .a . (-1-)- IEEI Std. 38 -1974 defines Class IE: "The safety classification A 4
! of the electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling and containment, and reactor heat removal or otherwise are essential in preventing significant release of radioactive material to the environment."
- p. '
, " Class IE cable d
~. p,f2)- The Zimmer FSAR, Section S.3.1.12.2 )g states f*./
is assigned to a division according to Table B.3-19." [ The divisions are comprised of the systems addressed in the class IE definitions.
"A Class IE cable is routed only in its division tray conduit, etc."
l I l "Each non-Class IE cable which has any part of its length in a
, division tray, conduit, etc. , or which connects to a Class IE power system is a division-associated cable and is not routed in tray, conduit, etc. of another division."
The terms division-associated,%ssociated,' hon-Class IE,"' balance-of-plant,"' nonessential,"and'non-ESF (non-engineered safety features)~are all used interchangeably. 4 4 4
INV002/I DRAFT /jp j . .
.s (
, 3, .63I Ihe FSAR Section 8.3.1.13 states:
i
?
l I .2"... Balance-of plant cables not associated with reactor protection or engineered safety features systems, when I assigned to a tray section with a Class IE segregation code, are routed only in trays with that segregation code." i
.3"... Cables will have either green, yellow, or blue identi-i fication for ESF cable; orange for reactor protection system cable; white for balance-of-plant cables; and white with i another color for associated cables."
fhy gg - ,f4) Ihe FSAR Table 8.3-16 states."A nonessential cable may be run
/
,/
in nonessential or ESF tray, but stall not occupy more than
-tray one @ system."
r'em p/ . f" jf, ,(5) The FSAR Section 8.3.1.11.2.1.d. states,"In the cable spread-
/
ing room, cable tray risers (chutes) are used to route the j/ cables into the bottom of control panels located in the control room above. Here a 1-foot horizontal, 3-foot vertical separ-ation is maintained."
/- m ,
/ m f f fe . / (6)'.The'FSARSection 8.3.1.12.1.3p uhich addresses Instrument Cables s states.," Low-level signal cables are run in trays and/or conduits
?
separate from all power and control cables." e
. INV002/I DRt.FT/jp
!. bC- The six installed conditions were as follows:
4 c. pr - I
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I i / I ( Contrary to the above F M/' criterig) [atles No. E053 red RE058 were rsuted in the raxe raceway and cable IIo. RE053 3 4'6 ' was not installed a minimt.m of three-feet above tray 2072C. [7 7 .uf 4 1 9 l Contrary to the FSAR criteri41 [hegreet and green / white cables
- v.uv i were essense installed in the white tray; the green, green / white, l
blue / white and yellow / white cables were not separated by a I 4+ l minimum of 4-foot-horizontally; and the green tray whigeon- \ _ _ _ _ _ _. _ _ _ - - _ - - . - - - -
INV002/I DRAFT /jp
+
tain instrument cables was not separate from the white tray
/
whict}containsNontrolcables.
/* . s s f
3fgNearthestairwellatthecenterofthecablespreadingrooy
! two blue cablesj No. RIl03 and CM111j were routed from blue i
tray No. 2077A into green tray riser No. 3025A, which extended up to the control room. Green cables No. HP073 and HP096 were i among the cables installed in riser 3025A. Contrary to the FSAR criteria
/hebluecableswererouted in the green division riser and were not horizontally i
I f5 q separated from the green cables by at least.1-foot. po. The licensee documented blue cables 7RIl03 and CM111 on Non-conformance Report No. 7'549., dated March 18, 1981, as a result
')
of the NRC finding. No QC inspection requirements existed to verify separation criteria for cables extending up and out of raceway located inthecablespreadingroom[tothecontrolroom. rs, % hllc41 I b5 "'Wed ff, ,(4)/7nthecablespreadingroom: e
e -sema-INV002/I DRAFT /jp
. b. .fbd White tray riser No. RK4627 contained yellow / white cables No. TI942 and No. TI943, and blue / white cables No. TI808 l , and TI760. -
4 CW . _(cT White tray riser No. 4139 contained many blue / white and I l yellow / white cables. i r-l The routing of blue / white, yellow / white, and/or green / white cables together in white treya appeared to be a widespread i design practice. This design is contrary to 3he FSAR Section fresa?. s f. ' 8.3.1.13.2 asstateppaboves O - J53 In the instrument-relay xc om',yellew/ white conduit No. RR199 extended from white tray No. 4157A to yellow tray No. 1040B. The conduit and trafs contained yellow / white cable No. RR199
;:.Ilout-y and wh'ite cable No. DC258 (also mislabelled DC257). P,er the cable installation (pull) card, cable No. DC258 was designed to be routed through tray No. 4157A, but not tray 1040B.
Since cable No. DC258 was a nonsafety-related cable there were ,* A no QC inspection requirements to verify the routing. O w
- 2
L
" INV002/I DRAFT /jp l,
nat.e-eathodshchieving caole separation wErhing7on-M sidciud. S 4 L drawing No. E-98-FB Revision g Note 4j required
! that the portions of cables in the cable spreading room wMch'-
l I were not enclosed or protected by steel chutes [be coated with i a 1/8'%yench- (after dry) application of fireproofing material. V p During a one conversation @ May 7, 1981, the licensee stated t y that the design identified on drawing No..E-98-FB was being nmens a i '** * '" reconsidered pn. 's. a p.. ~n for ,salte$tiocs. y e. r' .r., k 770nh~-a
/ '"'MCn [of s* d
_, s [40 f' sn3 0'") 2- f 8- t'd t, 2; Ys g f
- a. 54- Thegconditions identified in paragraphs b(-13W23;-tr(4-) and
.pLe.V
'b(S)/above a,pparently resulted from designs whi-ch deviate from the FSAR, These deviations are contrary to 10 CFR 50, Appendix B, Criterien III andp the Wg H. Zimmer QA Manual, f Section 3.1 and 3.6p as described in t,h( Ajper(lix A to the I
co-reporttransmittalletter/'p58/81-13-21)g I f f The licensee stated that the following actions would be taken
'l W f'dI O / L, 4 with regardf to thefconditions identified in paragraphsM-1-)r ,
'b b( nd-tr(6-): Either the field. installations would be i
changed to comply with the FSAR or appropriate changes to the FSAR with engineering justifications [would be submitted to 3 v o
- cO'Y
, g J
J2) Thepcondition identified in paragraph h(33 above apparently i resulted from construction activities for which required QC l inspection verifications had not been translated into an
- o. . . INV002/I DRAFT /jp
' inspection procedure. The lack of QC inspection for the in M l d ) condition in paragraph b,f-3-) is contrary to 10 CFR 50jAppendix B, Criterion X, and the Wm. H. Ziinner QA Manual, Section 10.1.g as described in tp Appendix A to the report transmittal letter i 50-58/81-13-22) y g g & hshJteJ udk l f) The misrouted cable identified in paragraph +(p apparently I
i resulted from contruction activities for which the FSAR does i not require QC inspection verification. The misrouted cable doesinfluencecableseparationandtrayloadingandptherefore, will have to be appropriately dispositioned. This item will so-bereviewedduringasubsequentinspectionf( 58/81-13-23)g t e l 7-
%l h6 INV002/K DRAFT /jp
~f. $ (G G & -l u.d.l . &
. 3o l-PMn W,C. TheJtIII inspector requested for review all of the CG&E audits of
/ S&L. The following audits were provided and reviewed to determine if CG&E was assessing the effectiveness of the S&L nonconformance and to determine the general nature of the audits.
Audit Dates Audit Number When Noted (1) 2/15-16/72 (2) 8/6-9/74 (3) 8/7-8/75 (4) 7/28-19/76 (5) 11/14-15/77 77/24 (6) 9/6-7/78 78/07 (7) 10/16-17/78 78/09 (8) il/27-30/78 78- 0 7 (9) 1/30-31/79 79/01 (10) 12/18-19/79 79/07 (11) 3/5-6/80 80/01 - (12) 10/21-22/80 80-04 l h ! The RIII inspector observed only two items (deficiencies) in all of l C~q f w A wT
- the above audits, covering a nine4 yea.r period, which addressed the S&L nonconformance program. These deficiencies, which addressed dis-
[ tribution and logging of nonconformance reports, were closed in Audit . 77/24.
.., .I
INV002/K DRAFT /jp Audit 77/24 indicated that S&L Project Procedure #PIZI-8.1, Revision 0, had been prepared to describe responsibilities and instructions, and to require a log and a file of nonconformance reports. The RIII inspector did not observe any other portions in any-of-the
.dkT~
audits uhich would have represented comprehensive and planned audits of the nonconformance program. Comprehensive and planned audits are required to verify compliance with the QA program and determine the effectiveness of the nonconformarce program. The audits of the non-conformance program should address such things as implementation, design reviews, identification of acceptance or rejection, dispcsition control, and notification of affected organizations. The audits generally appeared to be rhactive in nature in that specific problems, which had been previously identified, were audited. The audits usi;ra-cJ ?, did not appear to be progressive and programmatic, which may have identi- , fied new and generic problems. Failure by CG&E to perform a comprehensive audit of the S&L nonconfor-q 60+ mance program during the past eing years is contrary to 10 CFR,' Appendix B,4 Criterion XVIIIjand the Wh. H. Zimmer QA Manual, Section 18.1pas i describedinth*$'kppendixAtothereporttransmittalletterf'
- o. .
T358/81-13-23)g) I it ' r f
- :us INV002/P LRAFT/jp f'
g,Q
~
he are+c *t E Pr oble v ~aarty _^D e,cp Cala l x Q l p . - - , g, n,
!o j27 During the review of the CG&E audits of S&L, the III inspector noted sco, ;
'6 '
~*
l i that the audits were identifying a recurring problem. Thg problem was design calculation and verifications were not performed. The specific
. problem in each audit is as follows:
MDate or No. _ Problems
~
4 t.
.a . 8/8-9/74 a:
, ,(1) ITE Imperial drawings of essential equipment had not been signed and ~
bore no evidence of a design review.
- g. yew"
,,(2)j/nadequaciesindocumentingdesignreviews. s C. s
' -(3) Structural design calculation were not in accordance with new procedures.
).(4)' No direct evidence was available of the S&L review of vendor design calculations.
?.. cc .
-b7 75 07 ,(1)' S&L had not maintained a record of support design calculations.
r b,
,(2) DDC #2973 was approved without review by EMD even though a major support location change was clearly identified- on the DDC.
1 1 .
. INV002/P -
DRAFT /jp YY y r C ,5 s? , .. .. (This item was identified in the details of the audit report, but was not cited l and had no apparent followup on subsequent audits.) l u. [J- 78/09 J.lf Very little data was available to justify the embedment criteria of 4.5 times the normal diameter of concrete expansion anchors. h.
,(2) Calculations could not be locate.d 5.hich would verify that a structured review was performed to show that no reinforcement was needed for a 24 x 68 radial beam which was cut at both flanges.
d- O. 7 d 78/10 ( Calculations were not available for all
,1) walls to substantiate the statement that block walls were " judged to be Old,h l l .r .
(2) Calculations were not available to back l up design signatures which indicated design verification for five design changes approving core bores. l I _ _ _ . - , _ _ , - _ . . - . . . . _ _ _ _ _ __ . . . _ . . - _ _ . - _ _ _ _ _ .
, ,8 . . _ _ _ _ . . - - - - - - --- -- - - - - - - - . . INV0 0 2/P . DRAFT /jp
} w% 7- _-
' '~
M hky- D.'
)3) No approval signatures were found on any calculations for Structural Steel Modifi-
; cations (including Beam #86) due to Pool Hydrodynamic loads. The modification had been released for construction.
\
4') Audit finding was closed based on calcula-tions which were in progress but not yet complete. The calculaticas were for beams (embedded plates) in the primary contain-ment to verify that the plates can support additional loads. 6 A-(o 4, . 80/04 1) f The calculation required to evaluate the clamp deflection on a pipe support was not performed. Also, the weld calculation was not l performed'on'the most critical weld. Is;
,(2) Calculations performed by NPS were incomplete in that the deflection due l to torsional rotation of the beam was not included.
1 - C,' . l fc3) Calculations performed by NPS were not l in reasonable order, which made them difficult to follow. l
a j/ , INV002/P DRAFT /jp 5
- 4 .
None of the audits, which identified the above. calculation concerns, addressed the apparent generic and programmatic cause of design calcu-lations and verifications not being performed. The corrective actions that were taken did not assure that the cause was determined to pre-clude repetition. Failure to determine the cause and to take corrective action to preclude repetition is contrary to 10 CFR 50, Appendix B, j 1 Criterion XVI, sand the Wm. H. Zimmer QA Manual, Section 16.Sfas described i in the Appendix A to the report transmittal letter,358/81-13-24g fo-i __ l f l .I e l 1 ( 4'- '
DE Radiographs for 206 welds were reviewed per ASME Section III 197p Winter 1972 Addenda and M. W. Kellogg Co. Procedures ES-414, ES-415, and ES-416. No unacceptable RT technique deficiencies were identified in 517 of the radiographs and no unacceptable indications were identified in the respec- I wara tive welds wft$ 183 of the radiographsg:: nc;c;'p made without any of the required shims aander the penetrameters. Four of the radiographs were ,
.aep: ent's made with insufficient shims under the penetrameter. j The essential hole of the penetrameter 15 used to determine if the radio-graph has beer sufficiently exposed to show held indications that are in nonconformancewithtneASMESectionIII[ede. Sufficient shimming of the penetrameter is necessery to assure th;t the total thickness under the pene-trameter is the same as the total weld thickness, thus establishing a valid reference for identifying weld indications. Exposure of an insufficiently M
shimmed penetrameter meetit give K false assurance that the weld had received asy sufficient exposure to revealgunacceptable .we+d indications /s (Ae ge d.% o .tC /kt weW M Tto thsakeo~ flan TLe do.se ne*7ef.
.nr Y ASME Section EEf-197( with Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, "The shim thickness shalL be selected so that the total ;
I thickness being radiographed under the penetrameter is the same as the total weld thickness ..." M. W. Kellogg Co. (the manufacturer of the pipe and performing. agency of the above RT) Radiographic Procedure No. ES-414 dated 9/26/72, Paragraph 4.1.8, l states "Wherever required, shims shaLL be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal
f 1,- I, . t Appendix A , I t I 4 .i NOTICE OF VIO'.ATIO: t
; ARD i
t FROICSEL D*POSITIC:: CF CIVIL PEN;ITIES
, Cineir.nati Gas and Electric Co=pany Decket No. 50-359 As a result of the investigation eenducted at the Cincinnati Gas and Electric Company Wn. E. Zimmer Nuclear ?o.rer Station on January 12 -
July 14, 1981, and in accordance with the Interim Enferee=ent Policy, L5 FR 66754 (october 7, 1980), section 23L of the Ato=ie Energy act of 1954, as amended, ("Act"), h2 U.S.C. 2282, FL %-295, and 10 CFR 2.203, the Nuclear Regulatory Commission proposes to impose ci.il penalties in
~ ~
the a: cunts set forth belev for the following viclations. es* e
l
. /. ioc.rx so, h pr. h 3, Cr %.u r .rf.7k , ,2 p~ C tL.r pnu , s J sy ; ea 1'L., ,,,ak,.:.,y , /,-r y ar-<. ac J. ~ f:4., > a4 // ey t + a ~f /we/ saJ ra. r
, a ., .,
. rys
<e/".,e/ a 72 . tY -
/ ,/, ... eat *E./ 1:ea. 4.,'
f $ & $* ,N & $h Y fW bY6 f $$ Y$ w L., y,s.n</ t. .r 49
<c,.,.
A %;,,,, ae y,,v. u%'
' C ,n..<., <A ra a e J.,vs , m p c,d, fy a
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c/ 3 .. m / 3 h e f c,. ./ A u s t u , o ec A. L- n A.
/.e ne e e, /sef a.f prw./s a l/ a..u7' 4d'ap.,.fr-a o / m.
M .rh H /,.- cas t a,,/ . %eb.44. . n.a ,s . Se.<er,& 4 e. -/ v/ .i. / n ., (s,yA , .,.1.E) e-
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3 .. 10 CFR 50, Appendix B. Criterion III states, in part, that measures I i shall include provisions to assure that appropriate quality standards
! .are specified and included in design documents and that deviations fres
- ! such standards are controlled.
f The Wm. E. Zimmer QA Manual, Section 3.t$ states measures are establistei j to assure that any deviation frc: the applicable standards are controlled. Centrary to the above:
- a. Th veld inspection criteria, specified by Sargent & Lundy fcr
- structural velding, deviated frem the AWS Dl.1-1972 code and FSAh require:ents.
- b. The Sargent & Lundy design bases for thermal loading of cable trays (cable a:pacity) deviated frc: the design bases defined in the Citrer FSAR.
- c. The Sargent & Lundy desi 6 n for fcur different cable installations deviated fro: the cable separation criteria defined in the Zi==er FSAR. The cable were installed per the design.
- d. Sartent & Lundy had determined, as noted on a calculation sheet dated Dece:ter 27, 1979, thnt the design for two cables would allow these two cables to be thermally overleaded. No program existed in which the Sargent & Lundy engineers could control such design deviatio:s when identified to assure appropriate evaluation and dispg'sition.
This is a Severity Level violation (SupplementII) (Civil Penalty - )
^ --
t .- I 10 CFTt 50, Appendix B, Criterion III states, in part, that measures shall
! include delineation of acceptance criteria for inspections and tests.
i ' i j - i The Wm. H. Zim:ser QA Manual, Section 313.1 states, in part, that design t j control measures also apply to delineation of acceptable criteria for in-spections and tests. i j Contrary to the above, H. J. Kaiser Co. deleted veld inspection criteria which vere required by codes fro::: July 1930 to January 1981 and desigr.ated the criteris 6s not applicable fer a weld performed in November 1979 L i This is e Severity level violation (Supplement II) (Civil Penalty - )
~
l i I 4 9 e s
--,-- ,- - -. - ,- ..,n.,.n, . ---.,--n.-- - - -----
a i.- l 10 CFR 50, Appendix B, Criterion III states, in part, that the design control measures shall provide for verifying or checking the adequacy of a
. design.
The k'n. E. Zim:ser QA Manual, Section 3.11.2 states, in part, that at Sargent & Lundy, design verification reviews are performed by qualified personnel. Centrary to the above, measu es had not been established by Sargent & Lundy to verigy the adequsey of the design for the the. al loading of powr esble sleeves and the physiccl veight loading of cable trays. This is a Severity Level violation (SupplenentII) (Civil Penalty - ) 9 O e 4 e
10 CFR 50, Appendix B, Criterion III states, in part, that design changes,
, including field changes shall be subject to design control measures con- ! mensurate with those applied to the original design. The design control i
measures shall provide for verifying or checking the adequacy of design. The k's. E. Zim=er QA Manual, Section 3.12 states, in part, design changes,
, including field chan6es, sre subject to design control nenures co=ensa:ste vith those a;Ilied to the c;!ginal designe i
Centrer;* to *.ne abcve, at hut nineteen surveillacce reports vere written in .seceriance with a t.ita prendure to identify nonconferning conditions; however, this procedure did net ;rovide requirenents for a design reviev which is co=enturate with the criginal design. This is a Severity Level violation ( Supplenent ) (Civil Fenalty - ) e 9 Y e n--
~
10 CFR 50, Appendix E, Criterion V states, in part, that instructions, procedures, or drawings shall include appropriate quantitative'or quali-tative acceptance criteria for determining that important activities have l t been satisfactorily acco:plished. The Wm. H. Zimmer QA Manual, Section 5 3[ states that the written instruc-tions, procedures, and drawings include acceptance criteria which ec ply with the requirements of the design documente ani ap;13 cable codes and , standards . TM yerfcr=ance of quality c.nd design activities are verifici , against these acceptc.nce criterin. 1 ANSI Standx-d No. Ek5.2-1971, SectionIQstater,inpart,thatwherea sample is used to verify acceptability of a group of items, the sam;1e
. procedure shall be based on recognized prac*. ices and shall provide adequate justification for the sample size and selection process.
Contrary to the above, the inspection criteria defined in the E. J. Kaiser Instruction No. M-12, for bolt hole sizes, was not based on a recognized standard practice which vould have provided justifi~ cation for the secple size and the selection process, o This is a Severity Level violation (Supplement II)
-(Civil Penalty - )
4W8 e r
10 CTR 50, Appendix 3, Criterion VII states, in part, that the effectiveners
~
l of the control of quality by contractors and subcontractors sha11 be assessed
~
i by the applicant er designee. 4 The k'=. E. Zi=ner G Manual, Section 7 31 states that as art of the vender 4 selection process, Sargent & Lundy make an independent evaluation of the [ bidders' G programs as a part of their total bid evaluation. Centrary to the ato re. 615S t'eet of structural . beams ve:e rechased fro: ven rs fer which evaluati:ns cf the resphetive quality assurance ;regrans had not been performed.
"his de a Severity Level violation (Supplement !!)
~
(017f1 Fens 2ty - ) M e
10 CF3 50, Appendix B, criterion VIII states, in part, that =easures she.ll assure that identification of the ite: is maintained by heat nu=ter, ; art number, serial nu=ber, or othar appropriate = cans, either on the ite= or I on records traceable to the ite=, as required throuEh out fabrication, erection, installation, and use of the ite=. The W:. E. Zi==er O Man.:al, Section 8.2 states, in prt, that E. ~. Kaiser l Co. procedures provide thct within the E. J. Kaiser Co. fu-indictica the
, identifier. tion cf ite=s vill te =aintained by the =eth 2 s;e:;ifief en th:
, d a rings, such as hect nu=ter, prt nu:Ler, serir.1 number, er cther ap;r:- priate =etns. This identification =ay be en the ite= or on record trtee-atic to th: ite=. The identifiestion ic =aintained th-cuchout fatricatic:., erection, and installation. The identification ic =aintained and usable in the c;eration and =sintenance progra=. C:ntra.", to the above:
- a. the traceability of at least nine structural bea=s and twelve ;i;e lines was not =sintained.
- t. The traceability of velding roi was not =aints.ined as required by site
;recedure du-ing the seceni shift of Septe=ter and October 1070 Speci-fically, so=e of the veld red issue slips ec=;1eted during this perici chevei signatures (initials) of individuals who were not assigned tc ucrk.
. lThisisaSeverityLeve' *iolation (Su;;1e=ent II)
(Civil Penalty - )
=c*m
10 CFF, 50, Appendix B, C-iterion X states, in part, that a program for ins;ection of activities affecting quality shall be established and executedtoverifyconformancewiththedocumentedinstructionsI, procedures, i i 'and drawinCs. 1
-4 The Wm. E. Zimmer QA Manual, Section 10.1.2 states, in part, that inspections , are performed in accordance with written procedures which include requirener.ts for checklists and other apprt;riate dccumentation of the inspections.
Contrary to the above:
- s. No q': inspecticn program was establishei to require verification of cable separatien for cables extending from raceways located in the '
cable spreadinE roc = to the centrol room. T.o cables of the blue division had been routed into a green division tray riser, which extended up to the control room, in violation of the site cr.tle separaticn criteria. l
- b. Ho documented evidence could be provided to verify that in-process and adequate final veld inspections had been performed as requirei in the A'JS Dl.1-1972 code, for the velds on 180 cable tray hangers I
located in the cable spreading room. The final veld inspection hai been made after the velds were painted (galvanox). This is a Severity Level violation (Supple =ent II) (Civil Fenalty - ) I l
10 CFR 50, Appendix B, Witerion XI states, in part, that test results shall be evaluated to assure that test requirements have been satisfied. l ~ The Wm. E. Zimmer QA Manual, Section 11.1 states, in part, that test progra=s to assure that essential components, systems, and structures vill perfcrm satisfactorily in service are planned and performed in accordance with vritten procedu os and instructions at vendor shops and at the construction site. ~ Contrary to the above, at least 187 radiographs, taken to attest the quality of prefstrics.ted pipe velds, were made with a technique that did not ec=.ly vith the ASE Section III-1971 Code, Winter 1972 Addenda. The unacceptatie technique involved the lack of or insufficient shimming of the penetra=eter, which reflects the quality of the radiograph. This is a Severity Level vio'lation (Supplement II) (Civil Fenalty - ) e e* e
10 CFR 50, Appendix 3, Criterion XV states, in part, that measures shall be
, established to control materials, parts, or components which do not conform
- to requirements in order to prevent their inadvertent use or installation.
1 The Wm. H. Zimer GA Manual, Section 15.2.2 states, in part, that E. J. Kaiser Co. is responsible for identifying and reporting nonconfor:Ances in receiving inspection, construction, or testing activities which are , delege.ted to H. J. Kaiser Co. A tagging system is establithed in the I. J. Kaiser Co Quality Assu-atee Procedures to usre that nonconforcing items s are conspicuously marked to prevent tl.eir inadverte .t use or insta.llation. ' Contrary te the above: ' s
- a. Welds on at least nine structural beams and four cable tray hangers which contained unacceptable slag, veld profiles, blevholes, porosity, and/or undercut were identified,
- b. At least five structural bea=s were identified which had unacceptable notches for re-entrant corners instead of the required radii.
- c. At least four structural beans which were not specified on any design docu=ent were installed in the au::iliary building svitchgear roc =.
This is a Severity Level violation (Supple =entII)
'(Civil penalty -
)
M l l l l [ _ . - - .
j .
} e*
10 CPR 50, Appendix B, Criterion XVI states, in part, that measures shall assure that the cause of a condition adverse to quality is determined and corrective action is taken to preclude repetition.
)
I i The W:. H. Zi==er QA Manual, Section 16.5 statee, in pert, that vend:rs, 1 contracters, and subcontracters are required to determine cause and cor-rective action to prevent recurrence of errors which could result ir. eignificant conditions adverse to quality. ' i-Contrary to the above:
- a. The corrective actions taken in regard te a previous NRC finding, cen-concernin6 measures to assure Design Document Changes are implemented and verified by QC was not adequate. The corrective actions taken in response to previous NRC findin6s did not include Design Document Changes written prior to the imple=entation of the corrective actions and the Design Document Changes that are and have been implemented prior to receiving Sargent & Landy approvals.
- b. Five Cincinnati Gas & Electric C0=pany QA audits of Sargent & 1, undy i
identified a recurrin6 problem in which design calculations and veri-I t fications were not performed. The NRC identified, during this investi-l gation, that controls were not established to assure design verification calculations of the thermal loadin6 of power cable sleeves and the physical veight loading of cable trays. The Cincinnati Gas & 'lectric Co spany audits did not address the generic and programmatic cause, of the design calculations and verifications not being perfor=ed, to preclude repetition.
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- c. The licensee failed to verify the' socket en6agement on at least 439 -
velds; however, the corrective adion involved radiographing only twenty of the 439 velds.
] -
- d. '
The licensee used information from veld rod issue slips instead of i perfor=ing the required!in process insiections for at least twenty-four ' s \ velde.
- i
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This is a Severity Level 4- s violation '(Supplement II) i, -
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1 .. 10 CFR 50, Appendix E, criterion xvIII states, in part, that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to deter:iine the i . y effectivenes's of the program. 1
] The Wm. H. Zi:n=er QA Manual, Section 18.1 states, in part, that the QA Division conducts a comprehensive system of planned and periodic audits of Sargent & Lundy to verify co;;11ance with all aspects of the quality assurnnee progam.
Aos neut/ Centrar/ to above, the Cincinnati Gas & Elee ric Co=pany 4 Division fi: .. J b.l,<, f defere.'s M e e a.1 r,rch;..e_.c audit,of f.'v w s i a '-M,ar the Sargent & Lundy nonconfor=ance pro pas during the past nine years g This is a Severity Level violation (Supplement II) (Civil Penalty - ) e W i l i i 1 { l
. . - . . . ~.
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Pufsuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electrie Company is hereby required to submit to this office within 30. cays cf
, the date of this Kotice a written statement or explanation, including for -1 i each allegci violation: (1) ad=ission or denial of the alleged viols. tier.;
(2) the reasor.s for the violation if ad=itted: (3) the correcti<e sters t vhich have been taken and the results achieved; (L) the ecrre:tice sters which vill te taken to atoid fu-ther riolations; and (5) the date when full ec=;11ance vill be achierel. Consideration c:ay be gicer. to c::tendir.; y n response time fer go M eause shovn. Ur.de. the authority of Sectic:. 192 ef the Act, h2 U.S.C. 2232, this respense shall be submitted under es.th er affi-=ation.
' ithin the sa=e time as protided fcr the res;cnse required ateve under 10 CFR 2.201', Cincinnnti Gas and Electric Cc=;any cay pay the civil penalties in the :::r.:lative a=ount cf cr =sy pr test i=; sitio: of the civil ;enalties in whole er in part by a written answer.
Sheuld Cincinnati Gas and Electric Coc;any fail to answer within the time specified, this effice vill issue an Order i=;osing the civil penalties i..
~
the a=0 nt proposed above. Should Cincinnati Gas and Electric C::;any 1 elect to file an ansver in accordance with 10 CE 2.2',5 protesting the l civil penalties, such answer may: (1) deny the violations listed in this I; tice in whole or in part; (2) demonstrate extenuating circumstances; I -(3) shev errer in this Ketice; er (h) show other reasons why the renalties
- .should not be impesed. In additien to protesting the civil penalties in whole or in part, such answer may request remission or mitigatien of the
~
penalties. Any answer in accordance with 10 CE 2.205 should b'e set forth i
se;arately from the statement or explanation in reply pursuant to 10 CFP. 2.201~, but may incorporate by specific reference (e.5., giving page a.2d paragraph nunbers) to avoid repetition. Cincinnati Gas and Electric Co= ny's i i attention is directed to the other provisions of 10 CFR 2.205, regarding the l procedu e for imposing a civil penalty. Upon failure to pay any civil penalties due, which have 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 pensities, unless co=prc ised, re=itted, or mitigated, may be colllected by civil action pursuant to Section 23hc of the Act, 42 U.S.C. 2282. FOR TEE ::UTEAR REGU:.ATOR'l COG .~ISSIO': Victor Stello, Jr., Director Office of Inspection and Enforcement ' Icted at Bethesda, Ksrylani this day of , 1981 I e
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INV/003/I DRAFT /jp Appendix NOTICE OF VIOLATION ..
"1 .
. AND PROPOSED IMPOSITION OF CIVIL PENALTIES Cincinnati Gas and Electric Company Docket No. 50-358 Wm. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 EA No. 81-As a result of the investigation conducted at the L's. H. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - July 14,1981, the violations listed below were identified. These violations are evidence of a major breakdown of the quality assurance program in several areas to the extent that an extensive quality confirmation program must be conducted to provide confidence that safety-related structures, systems, and components will perform satisfactory in service. Because of the safety significance of this quality assurance program breakdown and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, i
and 10 CFR 2.205 in the amounts set forth below for the violations listed below. ' A. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials... , These measures shall assure that identification of the item is maintained... These identification and control measures shall be designed to prevent i the use of incorrect or defective materials, parts, components." i The W m . H. Zimmer QA Manual, Section 8.2 s~ta'tes', in part, "Identifica- ! tion and control measures are established to prevent the use of incorrect or defective materials. ..H. J. Kaiser Company procedures provide that within the H. J. Kaiser Company jurisdiction the ident-
- ification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other l j
appropriate means. This identification may be on the item or on ' records traceable to the item. The identification is maintained i throughout fabrication, erection, and installation. The identifica- i tion is maintained and usable in the operatica and maintenance program." t i
- ,- - - - - - -- - y ,_ ._ , - . . .. - . , . _ _ _ . , - __.
INV/003/I DRAFT /jp Appendix [ Contrary to the above, as of Mar h I 81, the material identification (traceability) of nine structura b aus in suchfareas as the Blue ) - Switchgear Room and the Cable Spr:a ing Room and twelve pip'e lines in the diesel generator cooling water starting air, and fuel oil systems was not maintained. This is a Severity Level II violation (Supplement II). (Civil Penalty - $ 000) B. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall - be established to assure that conditions adverse to quality such as. . .nonconformances are promptly identified and corrected." . The W'. m H. Zimmer QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformance in... construction... activities l which are delegated to HJK." 4 Contrary to the above, the NRC inspectors indentified the following nonconforming conditions which had not been identified by the licensee or designee:
- 1. Welds on nine structural beams in such areas as the Blue Switchgear Rocm and the Cable Spreading Room and four cable tray hangers in the Cable Spreading Room did not conform to requirements in that they contained unacceptable slag, weld profiles, blowholes,
, porosity, and/or undercut. , 4
- 2. Five structural beams in the Blue Switchgear Room did not conform to requirements in that they had notches for reentrant corners :
instcad of radii. '
- 3. Four structural beams installed in the Blue Switchgear Room did not conform to requirements in that'they were not specified on any design document.
i i This is a Severity Level II violation (Supplement II). (Civil Penalty - $ 000) j C. 10 CFR 50, Appendix B, Criterion XV states, in part, " Nonconforming r
, items shall be reviewed and accepted, rejected, repaired or reworked f
, in accordance with documented procedures." -
[- Kaiser Procedure QACHI G-4, " Nonconforming Material Control," , l provides detailed instructions for the review and disposition of , reports (Nonconformance Reports) of nonconforming items. Procedure QACMI G-4 contains the following requirements: ' i I ' -~
,,-r, - . . . , , , , , . . - . , , . - , - - - , - + - ...-- ---, . . . - - - - -- - ~a--- - ,--, -,-- - - . --. - - - - . - - - - - - - . - - - - , - - - -
INV/003/I DRAFT /jp Appendix /I' . Paragraph 3.3 - Requires QA Site Document Center NR Controller to log NRs generated by QC Inspectors 'or Quality Assurance Engineers in the Site Document Log and assign NRs a KEI Control Number (CN). Paragraph 3.6 - Restricts voiding of NRs to those initiated in error or those relating to nonconforming conditions which have been corrected by the Construction Department after verbal or written communication from the QA Department. Requires voided NRs to be stamped " Void." Requires an explanatory entry for voided NRs be made next to the CN in the Site Document Log. Requires a copy of voided NRs be retained in the Site Document Center. Paragraph 4.1.2 - Requires the disposition of NRs be categorized as " Rework" when the NRs require reprocessing to bring the non-conformance into conformance with specification requirements. Paragraph 4.3 - Requires Material Review Board action for NRs dispositioned " Accept-As-Is." Contrary to the above:
- 1. An NR initiated by a QC Inspector February 3,1981, regarding the violation of a QC " Hold" tag attached to a suppression pool liner plate did not have a KEI CN assigned. CN 5412 was initially assigned to this NR but CN 5412 was subsequently reassigned to another unrelated NR without the NR originally assigned CN 5412 being assigned a replacement CN. References l in the Site Document Log to the original NR assigned CN 5412 were covered over with "Wite-Out", a copy was not retained in ,
the Site Document Center, and the NR was deleted from the NR i control system. The NR had not been stamped " Void." (The copy of the NR reviewed by the investigator was provided by an alleger.) ~
- 2. An NR initiated by a QC Inspector February II,1981, regarding -
excessive weave in a primary containment structural steel weld i did not have a KEI CN assigned nor was it entered in the Site Document Log. The NR was simply never entered into the NR f control system. (The copy of the NR reviewed by the investigator ; was provided by an alleger.) i
. i
- 3. The following NRs were voided yet they had not been initiated
- in error nor did they relate to nonconforming conditions which had been corrected by the Construction Department: ,
E-1661 E-2233 ; E-1652 E-2466 ' E-1777 CN-4389 E-2191 E-5108 CN-2196 CN-5122 1
INV/003/I DRAFT /jp s/ Appendix A 4. Copies of the following NRs were not retained in the Site Document Center: Y
~
CN-4930* CN-4958* CN-4931* CN-4959* CN-4955* CN-5476 CN-4956* CN-5477 CN-4957* CN-5479 (The copies of the NRs reviewed by the investigator were i provided by an alleger. The copies marked with an asterisk ' were not stamped " Void" although there was a notation on each NR indicating it was voided and not issued.) I
- 5. NR E-2996, Revision 1, which was categorized as " Accept-As-Is" was closed out March 17, 1981, without Material Review Board approval in that final disposition action (UT of T-Quencher No. 007) which was part of the basis for conditional approval by the Material Review Board was not taken.
- 6. NR E-2836 was incorrectly categorized by the KEI Construction Engineer as " Accept-As-Is" when sufficient information had been provided by the KEI QA Engineer to clearly , indicate the NR should have been categorized as " Rework" in that reprocessing (radiography of the final weld) was required to bring the weld into conformance with the requirement of ASME Section III and Kaiser Specification H-2256.
This violation is a repeat of similar violations identified in Inspection Report Nos. 50-358/80-05 and 50-358/80-25. (The improper action on CN-5412, CN-5476, CN-5477, CN-5479, E-2996, and the NR , identified in Item 2 above occurred after corrective action (Stop Work Order 80-13 and revision of QACMI G-4) taken in response to Inspection No. 50-358/80-35.) - This is a Severity Level II violation (Supplement II). i (Civil Penalty - $ 000) D. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory requirements and i the design basis. . .are translated into. . . drawings. . ." ( The Wm . H. Zimmer FSAR, Section 8, provides the design basis for ; electrical cable separation which includes the following: , i
- Associated cables (Green / White,' Blue / White, and Yellow / White) from i more than one Division can not be routed in the same racewat.
~
INV/003/I DRAFT /jp Appendix
- Vertical separation of three feet or more must. be maintained between cables from different Divisions. 'f 1
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 in drawings related to the following cable installation deficiencies in the Cable Spreading Room: 1. Associated Cable (Yellow / White) No. RE053 for Division I was routed in the same raceway (two inch conduit and Class IE Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2.
- 2. Associated Cable RE053 for Division I was routed such that there was only a vertical separation of four inches between it and cables (Blue) 2 in Tray No. 2072C for Division.
- 3. Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as A,ssociated Cables (Blue / White and Yellow / White) for Divisions 2 and 1.
- 4. One raceway (White Tray No. 4080K) contained Associated
- Cables from all three Divisions including Cable (Blue / White) -
No. TI192, Cable (Yellow / White) No. RR781, and Cable , (Green / White) No. TI816. ' This is a Severity Level IV violation (Supplement II). l i (Civil Penalty - $
~ 000) !
E. _ 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, Section III-1971' L l and AWS D1.1-1972 Codes, b Contrary to the above: -
' I
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i
- 1. The weld acceptance criteria used by H. J. Kaiser Comphny from July 1980 to January 1981 were not applied for weld inspections in that the weld acceptance criteria for such items as the drywell support steel were deleted.
i
INV/003/I DRAFT /jp v Appendix A 2. The acceptance criteria for a weld performed on Service Water System Line No. 1WS71A18 by H. J. Kaiser Company in November 1979 were not applied in that the acceptance criteria were designated as not applicable. This is a Severity Level IV violation (Supplement II). (Civil Penalty - $ ,000) F. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test procedures ., shall include provisions for assuring that all prerequisites for the given test have been met... , 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 programs to assure that essential components, systems, and structures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construction site." M. W. Kellogg Co. (pipe manufacturer and agency performing the pre-fabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "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 reinforcement." ' ASMI Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, ; Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..." Contrary to the above, the NRC inspectors identified 187 radiographs l of prefabricated pipe welds in such systems as feedwater, diesel ' generator, and main steam which did not comply with the ASME Section f III-1971 Code, Winter 1972 Addenda, in that there was insufficient ' i shimming of the penetrameter. t t t This is a Severity Level IV violation (Supplement II). ! (Civil Penalty $ 000) Gf 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective-material and equipment, and nonconformances are promptly identified'and corrected. ' In the case of significant conditions adverse to quality, the measures i shall assure that the cause of the condition is determined and correc- I tive action taken to preclude repetition." O
i INV/003/I DRAFT /jp Appendix A 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 adverse to quality." Contrary to the above:
- 1. As of March 1981 Sargent and Lundy was not performing design cal-culations, reviews, and verifications and action was not taken to
. g3g. 8 ,7,g7fied correct This was identi-as athe condition repetitive and to in problem preclude repetition.
five licensee QA audits (audit per-formed 8/8-9/79 - no number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of Sargent & Lundy. i
- 2. As of March 1981 the socket engagement for more than 400 socket welds in such systems as the diesel generator cooling water, starting air, and fuel oil systems was not verified by Kaiser in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b) and the condition was not corrected. The welds dated back to 1979.
- 3. As of March 1981 the inprocess inspections for more than 24 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.
This is a Severity Level IV violation (Supplement II). ' (Civil Penalty - $ ,000) H. 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 that deviations from such standards are controlled." The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are ! established to assure that any deviations from the applicable i standards are controlled." ! I Contrary to the above, as of March 1981 design control measures had i , . not been established to assure that deviations from design conditions 1.
. (quality standards) were controlled. For example, Sargent & Lundy- I determined, as noted on a calculation sheet dated December 27, 1979, f that the design thermal loading for two power cables (VC016 and (
VC073) in Yellow Tray No.1057A would allow the cables to-be thermally i overloaded and no program existed to control those design d,eviations. i This is a Severity Level IV violation (Supplement II). (Civil Penalty - $ 000) . j
INV/003/I DRAFT /jp l Appendix [ - 8-
- I. 10 CFR 50, Appeidix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be established 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, "Inspec-tions are performed in accordance with written procedures which include requirements for check lists and other appropriate documentation of the inspections and tests performed." Contrary to the above, as of March 1981 a QC inspection program had not been established to require verification of separation of electrical cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition which should have been identified by such a program was two cables (RIl03 and CM111) of the Blue Division which had been routed into Green Division Tray Riser No. 3025A which extended from Blue Tray No. 2077A in the Cable Spreading Room to the Control Room. i '. This is a Severity Level V violation (Supplement II). Civil Penalty - $ , 000) J. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be established 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 Wh. H. Zimmer QA Manual, Section 10.1.2 states, in part, "Inspec-tions are performed in accordance with written procedures which include l requirements for check lists and other appropriate documentation of the __ inspections and tests performed." - Contrary to the above, the program established for inprocess in- '~ - - - spections of welds on 180 cable tray hangers located in the Cable - Spreading Room were not executed as required in the AWS D1.1-1972 - l Code. Specifically, the final weld inspections had been made after rather than before the welds were painted (galvanox). I t This is a Severity Level V violation (Supplement II).
~
(Civil Penalty - $ . 000) K. 10 CFR 50, Appendix B, Criterion III states, in part, "Thefdesign control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the perform-ance of a suitable testing program." i y -- 7 - - - - - - -- e eg g ,wg , .- -- - - - e , , -y- --7, -----.i-___------.
INV/003/I DRAFT /jp Appendix hf ' The Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part;, "At S&L, design verification reviews are performed.. ." 'f Contrary to the above, 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. This is a Severity Level V violation (Supplement II). (Civil Penalty - $ 000) I l j l a I e , l
INV/003/I DRAFT /jp Appendix ff ' - 10 - Contrary to the above, as of March 1981 the cable ampacity design by Sargent & Lundy was not based on IPCEA P-46-426. The cable ampacity was instead based on IEEE Paper 70TP557-PWR (1970)~, IPCEA P-54-440, and Sargent & Lundy Standard ESA-114a. This is a Severity Level VI violation (Supplement II). (Civil Penalty - $ ,000) N. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design contro1} shall include provisions to assure that appropriate quality standards are specified and included in design documents..." , The Wm. H. Zinmer 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." AWS DI.1-1972 Code, Section 3.6.4, states, "For building and tubular stractures, 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." Contrary to the above, as of March 1981, the design control measures did not include provisions to assure that appropriate quality standards (allowable undercut on cable tray hanger welds) were specified in that 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 on cable tray hanger welds. This is a Severity Level V violation (Supplement II). (Civil Penalty - $ ,000) . 9 I i
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INV/003/I DRAFT /jp AppendixfI# '
"He shall also, record on the KII Weld 2 form the heat number and/or
- lot number for bare rods, consumable inserts and backing rings, and the heat number and lot number for covered electrodes prior to use."
Contrary to the above, weld rod was issued and information was recorded on weld rod issue slips (KEI Weld 2 forms) by someone other than the Weld Rod Clerks assigned during the second shift during September and October 1979. Specifically, for welds made on the suppression pool wall plate (a) twenty-five weld rod issue slips showed representations of the initials of Weld Rod Clerks who were not assigned as Weld Rod Clerks on the days indicated on the weld rod issue slips, and (b) one weld rod issue slip did not show a Weld Rod Clerk signature or initials. This is a Severity Level V violation (Supplement II). (Civil Penalty -$ ,000) P. 10 CFR 50, Appendix B, Criterion VII states, in part, "The effective-ness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee. .." 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 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 of the control of quality by vendors who supplied structural beams. Specifically, evaluations of the vendors' (U.S. Steel Supply, PBI Steel Exchange, and Frank Adams Company) quality assurance programs for control of mill certifications and structural beams were not perf o rmed. This is a Severity Level V violation (Supplement II). ' (Civil Penalty - $ 000). Q. 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 m . H. Zimmer QA Manual, Section 17.1.4 states, in part, "Documenta-tion of all performance surveillance includes personnel identification [
and qualification, procedure, type observation, date of performance, person or organization monitored, results and corrective action if required." ' y
INV/003/I DRAFT /jp Appendix f Contrary to the above, the Bristol Steel and Iron Works Quality Control Steel Erection Report, which was a gener~ic boilerplate form for monitoring inprocess steel erection, did not identify closely-telated data such as weld procedure numbers, types of welding material, welder identification, aed specific welds inspected j o.J/u 3 This is a Severity Level VI violation (Supplement II). (Civil Penalty - $ 000) 10 CFR 50, Appendiit B, Criterion II states, i'ngart, "The applicant shall establish...a quality assurance program which complies with the requirements of this appendix." \, 1 CTR s 50, Appendix B, Criterion I requires persons and organizations perYorming quality assurance functions to be provided sufficient inde-pende'nce from cost and schedule when opposed to safety considerations. Contrary o the above, the quality assurance program of the company (Bristol St el and Iron Works) contracted by the licensee to install the structura steel of the plant did not provide sufficienti epend-ence of certain embers the QA staff from cost and schedule. Specifically, the ristol Steel and Iron Works QA Manual, Append x B, Section 1.0, Paragr'aph 1.1, states "The Erection Quality Control. ..is the responsibility ofMe Project Superintendent, who reports to the Project Manager." Both %e Project Superintendent and the Project Manager had cost and schedQling responsibilities. x This is a Severity Level VI v ation (Supplement II). (Civil Fenalty - $ 000) 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 date of this Notice a written statement or explanation, including for ' each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps ! which have been taken and the results achieved; (4) the corrective steps I which will be taken to avoid further violations; and (5) the date when ! full compliance will be achieved. Consideration may be given to extending - the response time for good cause shown. Under the authority of Section i. 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath l 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 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 .
INV/003/I DRAFT /jp AppendixMI' elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the viola'tions liste.d 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 penalties should not be imposed. 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 from 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 penalties dues, which have 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 penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. The responses directed by this Notice 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. FOR THE NUCLEAR REGULATORY COMMISSION l Victor Stello, Jr., Director Office of Inspection and Enforcement . , Dated at Bethesda, Maryland ( this day of , 1981 t t j- , i- {. l-e 1. B l
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t'.j,Gyr.G 10Jh k - i. I'" Appendix AN
,I h0TICE OF VIOLATIQ i
l
; R0 POSED IMPOSITION OF CIVIL PFJ M Cincinnati Gas and Electric Company Docket No. 50-358 I
As a result of the investigation conducted at the Cincinnati Gas and c) Electric Company Wm.Efi. Zimmer Nuclear Power Station on January 12- July 14, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), Section 234 of the Atomic Energy Act of 1954,*as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the Nuclear Regulatory Commission proposes to impose civil penalties in the amounts set forth below for the following violations. l 1 l
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d l . _ . - - - - _ - .
%4i-pi-face _
10 CFR 50, Appendix B, criterion I states, in part, "The persons and organi-
?
zations performing quality assurance functions shaLL have sufficient authori-ty and organizational freedom to identify quality problems; to initiate i recommend, or provide solutions; and to verify implementation of solutions. f Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organi-zational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided." Contrary to the above, the quality assurance program of Bristol Steel and Iron Works, a contractor to the Licensee, did not provide independence of the QA staff from cost and schedule. This is a Severity Level violation (Supplement II) . (Civil Penalty - ) i - 4 . I
. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shaLL be .
I l established to assure that applicable regulatory requirements and the
, depign basis ... are correctly translated into specifications, drawings, i
procedures and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled." t The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled." Contrary to the above:
- a. The weld inspection criteria, specified by Sargent & Lundy for struc-tural welding, deviated from the AWS D1.1-1972 Code and FSAR require-ments and the deviation was not controlled.
- b. The Sargent & Lundy design bases for thermal loading of cable trays (cable ampacity) deviated from the design bases defined in the Zim- ;;;
mer FSAR and the deviation was not controlled.
- c. The Sargent & Lundy design for four different cable installations deviated from the cable separation criteria defined in th? Zimmer i FSAR. The cables were installed per the design and the deviation was not controlled. ,.
- d. Sargent & Lundy had determined, as noted on a calculation sheet dated December 27, 1979, that the design for two cables would allow
I-I- - i, , these two cables to be thermally overloaded. No program existed wherein the Sargent & Lundy engineers could control such design deviations when identified to assure appropriate evaluation and disposition. ' e
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This is a Severity Level violaiton (Supplement II) I l (Civil Penalty - ) v l ! i I E
. e 9
9
f
, 30 CFR 50, Appendix B, criterion III states, in part, "The design control measures shall provide for verifying or checking the adequacy of design, ; such as by the performance of design reviews, by the use of alter'nate or simplified calculational methods, or by the performance of a suitable i
testing program." The Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, i design verification reviews are performed by' qualified personnet ..." Contrary to the above, design control measures had not been established by Sargent & Lundy 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. This is a Severity Level violation (Supplement II) (Civil Penalty - ) e
.10 CFR 50, Appendix B, criterion III states, in part, " Design changes, includ-
! ing field changes, shall be subject to design control measures commensurate
; with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another i
responsible organization." TheWm.H.ZimmerQAManual,Section3.12statesinpart,"Whennecessary, 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, at least nineteen surveillance reports were written in accordance with a site procedure to identify nonconforming conditions; however, this procedure allowed disposition of a nonconforming condition without design reviews which were commensurate with the original design.
Specifically, the procedure atLowed disposition of the identified noncon-forming condition without a design review if the disposition occurred within i 30 days. This is a Severity Level violation (Supplement II) I f l (Civil Penalty - ) { d e _ , , _ .. __ , _ _ , m--- m-- ----- ,-
i
.10 CFR 50, Appendix B, criterion III states, in part, " Design control I
measures shall be applied to items such as ... and the delineation of'
- l' a,cceptance criteria for inspections and tests."
, The Wm. H. Zir.mer QA Manual, Section 3.13.1 states, in part, " Design i control measures also apply to delineation of acceptable criteria for , inspections and tests."
i j Contrary to the above:
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! a. H. J. Kaiser Co. deleted weld acceptance criteria from July 1980 to January 1981.
- b. The acceptance criteria for a weld performed in November 1979 was delineated as not applicable.
These acceptance criterial were required by codes. 8 This is a Severity Level violation (Supplement II) (Civil Penalty - ) W
- l
- 10 CFR 50, Appendix B, criterion V states, in part, " Activities affectin,g quality shall be prescribed by documented instructions, procedures or draw-ings ... Insturcitons, procedures, or drawsing shall include appropriate quantitative or qualitative acceptance criteria for determining that im-portant activities have been satisfactorily accomplished."
l The Wm. H. Zimmer QA Manual, Section 5.3 states, "The written instructions, procedures, and drawings include acceptance criteria which ocmply with the ~ requirements of the design documdnts and applicable codes and standards.
,The performance of' quality and design activities are verified against these acceptance criteria."
ANSI Standard No. N45.2-1971, Section 11 states, in part, "Where a sample is used to ve.-ify acceptability of a group of items, the sample procedure shall be based on recognized standard practices and shaLL provide adequate justification for the sample size and selection process." Contrary to the above, the inspection criteria for. bolt hole sizes, as i defined in the H. J. Kaiser Co. Instruction No. M-12, was not based on a j recognized standard practice which would have provided justification for the sample size and the selection process. This is a Severity Level ' violation (Supplement II) (Civil Penalty - )
.10 CFR 50, Appendix B, criterion VII states, in part, "The effectiveness . of the control of quality by contractors and subcontractors shall.be assess-ed by the applicant or designee ... "
The Wm. H. Zimmer CA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process, S & L makes an independent evaluation of i the bidders' QA programs as a part of their total bid evaluation." Contrary to the above, 8,158 feet of structural beams were purchased from
, venders; however, evaluations of the respective vendor's quality assurance programs had not been performed by Sargent & Lundy to assure credibility of the.mitL certifications supplied by the vendor.
This is a Severity Level violation (Supplement II) (Civil Penalty - 3'
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9
s
.10 CFR 50, Appendix B, Criterion X states, in part, "A program for incoee-tion of activities affecting quality shaLL be established and executed by or for the organization performing the activity to verify conformance with
4 ] the documented instructions, procedures, and drawings for accomplishing the t activity." The Wm. H. Zimmer QA Manual, Section 10.1.2 states, in part, " Inspections are performed in accordance with written procedures which include require- ' ments for check lists and other appropriate documentation of the inspec- '
,tions and test performed."
Contrary to the above:
, 1 19 ,
,' ' 1 .
- a. No QC inspection program was established to require verificatiin of i
\
separation of cables routed from the cable spreading room to the cin- ,
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trol room. Specifically, two cables of the blue division had been . routed into a green dividion tray riser which entended up to the con-trol room, in violation of the site cable reparation criteria.
- b. The in process and final weld inspectins were not performed as re-quired in the AWS D1.1 - 1972 Code, for the welds on 180 cable tray s
hangers located in the cable spreading room. Specifically, the final weld inspection had been made after the welds were painted (galvanox). T ' This is a Severity Level violation (Supplement II) . (Civil Penalty - ) k i
l
.10 CFR 50, Appendix B, criterion XI states, in part, " Test procedures shalL i
4 include provisions for assuring that att prerequisites for the given test j have been met ... Test results shaLL be evaluated to assure that test re-quirements have been satisfied." l The Wm. H. Zimmer QA Manual, Section 11.1 states, in part, " Test programs I to assure that essential components, systems, and structures will perform satisfactorily in service are planned and performed in accordance with written procedures a.n d in'structions at vendor shops and at the construc-
, tion site. The procedures are specific with regard to intent, method, operating requirements and acceptance criteria for each test, and include-blank data sheets for recording test parameters."
ASME Section III - 1971 Edition, Winter 1972 Addenda, Appendix IX, paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..." Contrary to the above, at least 187 radiographs, taken to assure the quality x of prefabricated pipe welds, were made using a technique that did not com-i ply with the ASME Section III - 1971 Code, Winter 1972 Addenda. Specifically, the unacceptable technique involved the lack of or insufficient shimming of
- th'e penetrameter, which reflects the quality of the radiograph.
This is a Severity Level violation (Supplement II) - (Civil Penalty )
.10 CFR 50, Appendix B, criterion XV states, in part, " Measures'shalL be .
established to control materials, parts or components which do not conform t to requirements in order to prevent their inadvertent use or installation." ) The Wm. H, Zimmer QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformance in receiving inspection, construction, or testing activities which are delegated to HJK. A tag-ging system is established in the HJK Quality Assurance Procedures to assure that nonconforming items are conspicously marked to prevent their inadver-
,tnet use or installation."
Contrary to the above:
- a. Welds on at least nine structural beams and at least four cable tray hangers which contained unacceptable slag, weld profiles, blowholes, porosity, and/o'r undercut were not identified by H. J. Kaiser Co.
- b. At least five structural beams which had unacceptable notches for re-entrant corners instead of the required radii were not identified by H. J. Kaiser Co.
- c. At least four structural beams which were not specified on any design document were installed in the auxiliary building switchgear room.
This is a Severity Level violation (Supplement II) (Civil Penalty - ) _.c . _ -
i 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shaLL be i established to assure that conditions adverse to quality, such as' f ailures, i malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of siginificant conditions adverse to quality, the measures shaLL assure that the cause of the condition is determined and corrective action taken to i - preclude repetition." i 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 reccurrence of errors which could result in significant conditions adverse to quality."
Contrary to the above: 4
- a. The corrective actions taken in regard to a previous NRC finding, con-cerning measures to assure Design Document Changes are implementd and verified by QC was not adequate. The corrective hetions taken in response to previous NRC findings did not include Design Document Changes written prior to the implementation of the corrective actions and the Design Document Changes that were and had been implemented prior to receiving Sargent & Lundy approvals.
- b. Five Cincinnati Gas and Electric Company QA audits of Sargent'& Lundy identified a recurring problem in which design calculations and veri-fications were not performed. The NRC identified, during this investi-gation, that controls were not established to assure design verifica-
tion calculations of the thermal loading of power cable sleeves and the physical weight loading of cable trays. The Cincinnati Gas I; Electric Company audits did not address the' generic and programmatic cause of the design calculations and verifications not being performed nor was corrective action taken to preclude repetition.
- c. The licensee failed to verify the socket engagement for at least 439 welds, however, the corrective action involved radiographing only twenty of the 439 welds.
- d. The licensee used information from weld rod issue slips instead of performing the required in process inspections for at least twenty-four welds.
This is a Severity Level violation (Supplement II) (Civil Penalty - ) 9 e
; .10 CFR 50, Appendix B, Criterion XVIII states, in part, A comprehensive ; system of planned and periodic audits shaLL be carried out to ver.ify com-p.Liance 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 con-ducts a comprehensive system of planned and periodic audits of S & L, HJK and GE to verify compliance with aLL aspects of the quality assurance program." Contrary to the above, during the past nine years, the Cincinnati Gas & Electric Company QA Division did not perform a comprehensive audit of the Sargent & Lundy nonconformance program. This is a Severity Level violaiton (Supplement II) (Civil Penalty - ) 4 W' i
6
! . Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric - ! Company is hereby required to submit to this office within 30 day's of l the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps I
j which have been taken and the results achieved; (4) the corrective steps i j which wiLL be taken to avoid further violations; and (5) the date when full compliance wiLL be achieved. Consideration may be fiven to extending , l your response time for good cause shown. Under the authority of Section t 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under j 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 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 ht'e 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 penalties
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should not be imposed. 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 .hould be set
,forth separately from the statement or explanation in reply pursuant to
e i 3
,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 l procedure for imposing a civil penalty. f Upon failure to pay any civil penalties dues, which have 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 penalties, unless compromised, remitted, or mitigated, may be collected by civil
, action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
i
- FOR THE NUCLEAR REGULATORY COMMISSION Victor Stello, Jr., Director Office of Inspection and Enforcement i . .
; Dated at Bethesda, Maryland this day of , 1981 9
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e. s Docket No. 50-358 -
/
Cincinnati Gas and Electric Company ATTN: Mr. Earl A. Borgmann Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnat'i, OH 45201 Gentlemen: This Letter confirms the phone en<onversation of April 16, 1981 between Y Mr.W.W.SchweirsandMr.W.D.WapireofyourstaffandMr.R.F.Warnick, Mr. K. D. Ward, and Mr. P. A. Barrett of this office. During the conversation, this of fice's interpretation of two nondestructive exm5 amination (NDE) concerns relating to the April 8,1981 Immediate Action Letter, was stated as follows: t (1) CG&E is required to perform an additional review, after April 8, . f 1981, of all QC procedures which includeY NDE procedures.
' This$ rop 1 I additionalreviewwiLLbeperformedb'ytA'As1/SLO 06 personnel an {
organization other than the organization responsible for:the I activities covered by the procedures.
1 J, (2) CG&E or CGSE's NDE contractor is required to provide only one ["!,* 4l ; 4
ed individual to verify the set up 4.
and/Wgf"-- 4 r:t . . . --h vs I- . w. "dirgr: hy. This may be the same individual who performs the
/ se e.aa in ae.i...ded radiography. CGEE is required to provide a% reditiv.. Lg interpretation of aLL radiographs made during f ective period of the ---* 4--
y
' 1Al requirement :1 th: I ". . Y
-": ;ba m
. . t i . y . m s u '. i v. . Je m a . ~ i o pp'. ; 'O 2 y rth r "' : y. u-m ab If you have any questions regarding these matters, please feel free to call me.
Sincerely, m . James G. Keppler Director ; I cc: W $ 4 h f 1 1- l[~ ' <puk {ty k % ess ; & ld WiiL,~f3.:d M .aM r -- Y
ye
. I Allegation $S1$U i -
" Kaiser knowingly installed and ripped out unsuitable Main Steam Relief 1
3 i (MSR) piping, at an estimated labor cost of Three Hundred and Twenty Thousand Dollars ($320,000)". f II Findings $U , The allegation was substantiated in that an economic decision was made to install piping, of which approximately 3-10 percent would have to be removed, due to continuing changes in design loads. No attempt was made to substantiate the estimated labor cost for thr portion of pipe that was
, installed and removed. However, costs figures were available for the total design modification relevant to the Main Steam Relief piping.
The RIII inspector identified no items of noncompliance or concerns that were significant to quality construction of the MSR piping. III Investigation $U A. Background $UInformation5U The allegation was interpreted to be concerned with the monetary costs of constructing the Main Steam Relief System piping. No information was received to indicate unacceptable quality of the related construction activities. 1
t i B. PersonnetSSInterviewsSU - t l On February 24, 1981, Individual "A", who was previously interviewed f by representatives of GAP, was interviewed and stated Kaiser instal-Led a large portion of the MSR piping, knowing sections of it would later have to be removed after installation. He recalled that two years after its installation Kaiser removed large sections of the piping from the 525' Level of the reactor containment building down-ward, and left the pipe sections above that level in place.
- On April 22, 1981 Individual "A" provided a written statement attestingtotheaforementionedinformation;}.owever,herequested the statement not be attached to this report.
On April 14 and 16,1981, Individuals "B" and "C", respectively, who allegedly provided information regarding this atlegation to representatives of GAP were interviewed.and stated they had no information concerning this allegation. C. During the period of 2/9-13/81 and 2/23-27/81, discussions with Mr. H. C. Brinkman, Principal Mechanical Engineer, CG&E, indicated that in 1975 a nuclear power plant in Germany discovered the need to redesign the relief system based on new discharge Lo_, ads. There-fore,severalutilities,includingCG&E,decidedonamodificationg s1
to replace the already installed rams head safety relief valve (SRV)
- discharge devices with quenchers.
1 l In 1975 CG&E decided to start the quencher modification, knowing that part of the piping, not yet installed, would Later have to be removed. The basis for the decision was that approximately 90-97% of the original quencher modification would be acceptable and there-fore only 3-10% would be subject to rework. CGSE's decision con-cluded that it would be less costly to go ahead in 1975 with the installation activities rather than to delay the construction schedule until the quencher modification design was complete. To date, the modification design is not complete. l The NRC has been aware of the modification activities as described in the Mark II Design Assessment Report, Chapter 2.0 -- Zimmer Empirical Loads, ZPS-1. The RIII inspector observed that the latest documentation received from the NRC Licensing Branch No. 2 at the site concerning the modification activities, was NUREG-0487, Supple-l -
, ment 1, titled, " Mark II Gbntainment Lead Plant Program Load Evaluation and Acceptance Criteria." It should be noted that there may be more changes in the future due to additional Load definitions.
The modification has required the replacement of 10 inch schedule 40 pipe with other 10 inch schedule pipe of different co'nfigurations, 10 inch extra strong pipe, and 12 inch extra strong pipe. i l l i
. .. . 1 i
l 1 e k i During this investigation the Licensee provided cost figures for
+ t ! . modification to date. The total Labor cost was $823,780.00 and the +
total material plus Labor cost was $1,183,690.00. The NRC made no attempt to corroborate these costs or the Licensee's claim that it was cheaper to proceed with an installation which was known, before installation, to require rework. The RIII inspector reviewed all revisions to the KEI isometric drawing PSK-1MS, Sheets 21 and 21A, which were pertinent to the main steam relief piping. No additional changes of the magnitude addressed in the allegation were identified. The revisions identi-fied the following changes: Rev. O Redrawn -- original configuration replaced 9/8/76 Rev. 1 Hangers added 3/31/77 Rev. 2 Eight Lugs added 1/10/78 Rev. 3 Hanger changed . 5/5/78 Rev. 4 New spool pieces added, welds MS212 and 4/3/79 MS195 voided per S&L Rev. 5 Piping tee section added 6/18/79 Rev. 6 Weld MS160 and a 4 inch dimension added 10/1/79 i Rev. 7 Field marked (redline) updates added 1/9/80
.i ,
io Rev. 8 Welds K-461 and K-463 changed; weld K-592 . 9/27/80
. changed to K-593 per NR-2499; hanger detail
~
I section D-D added l
; Rev. 9 Weld K-592 changed to K-461; and weld 9/4/80 '
4 i K-593 changed to K-594 i
! ALL of the above revisions pertained to the aforementioned quencher modification.
The RIII inspector reviewed the QC documentation for the following main steam relief piping field welds: Nos. 160, 160A, 267A, 2679, 267C, 2670, 2688, 268C, 2680, 459, 460, and 461. The records indi-cated that the welds had been accomplished in accordance with ASME Section III 1971, Summer 1973 Addenda. The RIII inspector interpreted the radiographs for the following main steam relief piping field welds: Nos. 160A, 459, 460, 461, 462, and 594. l It is noted that there are approximately five to seven radiographs l for each of the above welds. The varying number of radiographs are necessary to cover the entire 360 degrees of each pipe weld. The radiography was performed in accordance with ASME Section III 1971, Summer 1973 Addenda. The RIII inspector identified no unacceptable weld indications on the radiographs. [
=-
O e , The above discussions and reviews indicate that the alleged activi-ties were performed in accordance with the KEI QA program. l No items of noncompliance or deviations were identified. I l l. t 4 1
=
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e
J Allegation No. 3 "A radioactive waste drain is clogged with concrete which carelessly was poured into the drain." II Findings I g ,
$f --16 III Investigation _
A. Background Information f I sesfe . B. Personnel Interviews Interview with Individual "A" - On February 24, 1981, Individual "A" who was previously inter-o viewed by representatives of GAP was intrrviewed and stated ' while concrete finishing work was underway in the radioactive waste disposal system he suggested to Kaiser Construction personnel that a pipefitter should be assigned to ihe concrete [ finishing crew to assure concrete did not enter andIclog the drains. However, they disagreed with his suggestion and instead directed the floor drains to be covered up with duct
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I Allegation $SNo.SS3SU j "A radioactive waste drain is clogged with concrete which carelessly was poured into the drain." II findings $U
-f'f g pobom el fle M allegation A /was substantiated in that interviews with pertinent
-rkat laol:cend 6at a redseeche wests donts was stayyed personnel indicated that some drains had been clogged with unspecified deie:s.
d r 7Ae peef:*n o} 14 a/foyaf:*< de7.:.o/sc.7eJ dat eoaerete a toyed ik u g Ceo .c:s -a .;t ;.t;;;,:-;;;d : 5 05: di..;. Flushing dra:a was o ef sele */ of.' ' fed. .theseqdra:a4wlisk were. records dated in 1979 indicated that[/4+regnonsafety-related, % were e.ts sets dA at/ cleared of all restricting debris. fe, v a draters ;/e='8N*4 474 c ea$e //*/ proerdure, Juad notyeW }etor sllusAes/.
, dely cas,< e<<.s No 1,. . : T:. :;n::- : r items of noncompliancegwere identified.
III Investigation $U l l A. Background $SInformationSU vu !! - 1y ,,,j,,,h
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af p l-<t oper.r":. s. c rned that he ra wast dr 'ns re i por ant o tl'e spfe operat' of he p ant nd th t the dra'ns m y be una le t o pc rfo rm ;hdir func ion ecause thes had beer clo ed 3 i th concrete. B. Personnel Interviews i l l l l _
$rhw, ~ m khA% ,
l On February 24, 1981, Individual "A" who was previously interviewed i L M v' A w a\
- W
- i byrepresentativesofGAPwasinterviewed.endgstatedJwileconcrete finishing work was underway in the radioactive waste disposal system he suggested to Kaiser Construction personnel that a pipefitter e'.; iJ be assigned to the concrete finishing crew to assure concrete did not enter and clog the drains. However, they disagreed with his suggestion and instead directed the floor drains to be covered er with duct tape to prevent concrete from entering and clogging the
+**
drains. Individual A stated that concrete did enter the Lines and g, clogged the radiation waste drains. On April 22, 19813Individual "A" provided a written statement attesting to the aforementioned information; however, he requested i the statement not be attached to this report. 53 y%
$ In ivi al st *ed at th rob k it Log b d % s h
/ , occu ed 'n 76 a-d 1 7. O v c. % 4 ,. m a a e ss ~ u ~ ,
4 The-9ti+ Senior Resident Inspector reviewed CG&E Flushing Procedure ab No. DR Rev. O, approvn t u 9/23/77, for the Drain System. The 3 purpose of this procedure was stated as follows: This document details the procedure for cleaning the liquid radwaste floor drain and equipnent drain piping to the various plant sumos and drain
I tanks. The floor drain and equipment drain piping shall be flushed l until they flow freely and all large particulate matter is removed."
.I
. 4 Appendiges to the Flushing Procedure, r_ L...., 00 ,_m . . .
f _ , .- :- p:- < e m s-,1-e -m
-,r. indicated 3
- 1 *f /U .4 o* ret.4 A s '
~ ! ist.
j that ::- ~ ' , _ . . ef J,s
.... M drainsjhad been flushed and i
verified in accordance with the procedure. The Appendices indicated that the verifications had been made in 1979. The licensee stated that the flushing activities were still continuing.
)V I Telephone interviews were conducted by the Senior Residert Inspector fLs e s/es/8/ with,gTest Coordinator responsible for the radwaste building drain 2 en 2/t3/6/ with flushing activities on.J.l.2244 and jthe Startup Engineer responsible for Drain System flushes = 2/ C/^A. Both individuals indicated that some drains were found to be plugged with unspecified debris.
Inallofthosecasesthedrainswereclearedandflowwasverified.f'
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ar ~~ y ,T.. , -- - The Senior Resident Inspector made visual inspections of all of the accessible radwaste drain ports identified on Sargent & Lundy drawings A-533 Rev. F, A-534 Rev. F, and A-515 Rev. N. These j drawings identified the drains in the radwaste building (elevations 496 feet, 527 *eet, 513 feet and 511 feet) and in the auxiliary building (elevations 567 feet, 5 inches, and 546 feet). None of
~
l the observed drain ports were visibly plugged. 1 1 p- g - - - , , - -- - - - - , , -
Neither the flushing records, the personnel interviews, nor the Resident Inspector observations confirmed or denied that the drains
! had been clogged with concrete. These activities did confirm that '1 fuf Led dern -flurbef j the drains 3would allow flow on the dates of the verifications.
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I I AllegationSSNo.SS3SU
! "A radioactive waste drain is clogged with concrete which carelessly was poured into the drain." _
s j II FindingsSU This allegation was substantiated in that interviews with pertinent ~ personnel indicated that some drains had been clogged with unspecified l debris. Concrete was not substantiated to be the debris. Flushing records dated in 1979 indicated that the nonsafety related drains were
' cleared of aLL restricting debris.
No significant concerns or items of' noncompliance were identified. III Investigation $U i s, . A. Background $SInformationSU
*, (
This allegation was interpreted to state that the alleger was con-cerned that the radwaste drains were important to the safe operatien of the plant and that the drsins may be unable.t'o perform their .
. . , c. . s . ,
function because they had been clogged with concrete. - t i l
~ ' .
i B. - Personnel Interviews . l
\
g4 l 5 t. 3['u, d , ,
> . .e : ~
l, * , I l Interview with Individual "A" l On February 24, 1981, Individual "A" who was previously interviewed by representatives of GAP was interviewed and stated while concrete finishing work was underway in the radioactive waste disposal system he suggested to Kaiser Construction personnel that a pipefitter should be assigned to the concrete finishirg crew to assure concrete s
! did not enter and clog the drains. However, they disagreed with his suggestion and instead directed the floor drains to be covered up with duct tape to prevent concrete from entering and clogging the drains. Individual A stated that concrete did enter the lines and clogged the radiation waste drains.
On April 22, 1981 Individual "A" provided a written statement attesting to the aforementioned information; however, he requested the statement not be attached to this report.
; Individual B stated that the problem with the clogged drains occurred in 1976 and 1977.
C. The RIII Senior Resident Inspector reviewed CG&E Flushing Procedure No. DR Rev. O, approval date 9/23/77, for the Drain System. The purpose of this procedure was stated as follows: This document 4 details the procedure for cleaning the liquid radwaste floor drain and equipment drain piping to the various plant sumps and drain
~
! tanks. The floor drain and equipment drain piping shall be flushed until they flow freely and aLL Large particulate matter is removed."
1
,'1 l C j Appendifes to the Flushing Procedure, numbering 81 pages with approximately 15 equipment and/or floor drains per page, indicated that essentially all of the included drains had been flushed and j verified in accordance with the procedure. The Appendices indicated that the verifications had been made in 1979 The Licensee stated that the flushing activities were stiLL continuing.
Telephone interviews were conducted by the Senior Resident Inspector with Test Coordinator responsible for the radwaste building drain flushing activities on 2/12/81 and the Startup Engineer responsible - for Drain System flushes on 2/13/81. Both individuals indicated that some drains were found to be plugged with unspecified debris. In aLL of those cases the drains were cleared and flow was verified.
? The Senior Resident Inspector made visual inspections of all of the , accessible radwaste drain ports identified on Sargent & Lundy drawings A-533 Rev. F, A-534 Rev. F, and A-515 Rev. N. These
( drawings identified the drains in the radwaste building (elevations l 496 feet, 527 feet, 513 feet and 511 feet) and in the auxiliary building (elevations 567 feet, 5 inches, and 546 feet). None of the observed drain ports were visibly plugged. . l l
t
; Neither the flushing records, the personnel interviews, nor the i
i Resident Inspector observations confirmed or denied that the drains had been clogged with concrete. These activities did confirm that i j the drains would allow flow on the dates of the verifications. l The Resident Inspector also determined that the radwaste drains are nonsafety related.
*U "" I '
y }fesj o h ogene.come)*b* "
- W Y' VI*
e l l . . I e
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e
, I. At t ega t ionSSNo.SS3SU "A radioactive waste drain is clogged with concrete which carelessly was poured into the drain."
II. Findings $U p*
,g4 [ The portion of the allegation that
- d a d :.'. m3 q0 d a radioactive 4 ,
N' waste drain was clogged [was substantiated in that interviews b .** r.S
,J', ;d' ,4. g .awi+4t' k * :r ;:-t : .;c.; ;:-e^-
9 h Wh$t pye e'dindicated that some drains had been [tp. ' l s,
.,,g clogged with unspecified debris.
ffy.N
\t 'W L\\tgeh
/ *r / The portion of the allegation that E dico;;d G,4 toncrete m %e ht%4 %Y g,-%w m
^^
>FMse/
*j actossed the drain was not substantiated.YF' lushing. record (dated
.a bh\ dy. <
a&Mn wash)
,,((*)
in 1979 indicated that 152 out ofg169 ef e:Adreirts; all of which eWr,.. 8 are nonsafety related,--:r: h4 b:9.e: 2: _pys'm..A_- r::t-:.;... m :.,- r1 .A 4,ce ,.41% 4. he p* M hr4
'u e13eA469 drains)were identified try iricontrolLed flushing eu h meme procedureg ** he 15 2. whack, kg k
%.h .h6%r. w'M AeW%'as
%= sWs shM Pro A*- ?* h Th\~y* M .
cegkna. g No items of noncompliance or safety concerns were identified. - l III. Investigation $U ' A. Background $SInformationSU i l l A A __ A
- 1 ^ v v .
A VWV w- vy v w p,0 con =4\ TN F" < L4- w A.ty ,2.e.4 p Mst 4 e.g.r~ 4kn U eMe.eA araba see b ah- ep mMwn. re4,ich M
&abM.% _A n
% v_ __ _m - y m
- - f
I
, o t-de wM
= I The -'d artendrains, which are nonsafety related, wiLL not handle radioactive material until such material is generated following commencement of plant operations.
B. Personnel $SInterviewsSU hw .5 Lt/M *A** On February 24, 1981, Individual "A" who was previously interviewed by representatives of GAP was interviewed. Individual "A" stated that while concrete finishing work was underway in the radioactive waste disposal system he suggested to Kaiser Construt<ction personnel that a pipefitter be assigned to the concrete finishing crew to assure concrete did not enter and clog the drains. However, they disagreed with t<his suggestion and instead directed the floor drains to be covered with duct taep<< tape to prevent concrete from entering and clogging the drains. Individual "A" ! stated that concrete did enter the lines and cloggeek the I c%A*,n - eed4=+4aa4 waste drains. - on April 22, 1981, Individual "A" provided a written statement f attesting to the aforementioned information; however, t<he : requested the statement not be attached to this report. i 9 I i e O b
.IcheM w e.T. InhiAna\ Y 8 r
Individual "B" stated that he worked as a pipefitter in
. 1976-1977 in the drain flushing crew for the radiation waste disposal system. Individust "B" stated that during this period, he observed drains in the system that were clogged with concrete, which he and others unsuccessfully tried to g remove.
C. RecordSSReviewSSandSS0nsiteSS0bservationSU i The Senior Resident Inspector reviewed CGEE Flushing Procedure No. DR, Rev. O, approved 9/23/77, for the Drain System. The, purpose of this procedure was stated as follows: "This docuen<< document details the procedure for cleaning the liquid radwaste t< floor drain and equipment drain piping to the various plant sumps and drain tanks. The floor drain and equipment drain piping shaLL be ftushed untit they flow freely and att large particulate matter is removed." i The Radwaste Building Floor Drain Tank, <<<< , Appendices to the Flushing Procedure, indicated that 152 l i out of 169 of the drains related to thn<e Radwaste Building j Floor Drain Tank, the Floor Drain Studge Tank, the Radwaste Floor Drain Sump, the Floor Drain Collector Tank, and the Ce<< h av'e i Chemical Waste Tank.has been flushed and verifiedJn accordance with the procedure. The Appendices indicated v
that the verifications had been made in 1979. The licensee stated that the flushing activities were still continuing.
.The Sanine Resident <<<<
gr,w,4. :.v.Teec.a..e e a w % W a*w
. ; ;p ; r ;'; : 7- :ond_:::d b :h; R in ". L'-t 4 t.;;;;;; r- 2/'2/S? !'MTe Test Coordinator responsible g6)v- e for the radwaste building drain flushing activities and w k' -2/~.3/0".
.uc the Startup Engineer ~ responsible u
- e .w.. > ~, ,, for Drain ~e
(*' , System flushesA Both individuals inc<dicated that some i drains were found to be plugged with unspecified debris. In att of those cases the drains were cleared and flow was verified. The Senior Resident Inspector made visual inspections of att of the accessible radwaste drain ports identified on Sargent
*<& Lundy drawings A-533 Rev. F, A-534 Rev. F, and A-515 Rev. N. These drawings identified the drains in the radwaste building (elevations 496 feet, 527 feet, 513 feet and 511 !
feet) and in the auxiliary building (elevations 567 feet, i 5 inches, and 546 feet). None of the observed drain ports l were visibly plugged. , l l Neither the flushing records, the personnet interviews, nor l the Resident nspector observations confirmed or denir<ed that the drains had been clogged with concrete. These l activities did confirm that the drains, which had been flushed, would allow flow on the dates of the verifications. q0
m. No items of noncompliance or deviations were identified. 6 e l
- d 1
I et D
4 Thus, the aLL er's sou e did n t know i the wel rod s e<being roperly eturned d acco ted for KEI-2 orms. Th: ".::: ...+s.w4 .s.. . m _. . , _ .a . ;L.,.., Z: : . . . . . . . - Tc K:: fe a i: : :: . t r. ; ; i er. ': -- ' ^ 4 - b 4ndi"* r: _;LJ .ve g6f* L Y =fle Wt$$tfb 4 - - b';..,. The3 form require / the welder's,, foreman,and the glf- L d weld rod issuer's signt<ature. The.formaf requireino QC 7se Kzit .ye.:f.u.reeirwaf ; signaturej. pproximately 15 KEI-2 forms for the September - f October 1979 period and approximately 20 additional KEI-2 : forms dated in 1978 ee-- r 2:=i ALL of the records indicated that the respective welding rods had been properly accour. ed.% 3+ e F~ .t d b ; 7,;; g + k o eg_e + km vet > e; r .
.,m, , =
A 11ertfors r#^^rtL :, t'; #^-- isnotacred1pleQCrecord. j '[b #" perm.fs fke wel e f> olha.shde /er a spes:Ns. weW $ rom 4
- ted rAc.e k (.(;e/Jg#er**~ ).
gr p , L \ ' Q: --:e; ', d L: eted h .;t seld rod verification by QC is not i z ~_ -- 3.w l j alleged. However, the RIII inspectors have identified programmatic l l l problems concerning weld rod verification. These problems were I i identified while pursuing a spinoff allegation. The specific l i problem is that the inspection requirement for QC is verified l I the use of proper fillers (weld rod) was improperly deleted 1 for the period between July 1980 and February 1981. The deletion # l is contrary to the Code requirements. This wiLL be an item of [ 1 i noncompliance. i
<m,a==.w* - . - . m.,--ww*.-+ --- ., - --
e o l-I AllegationSS1$U f
?
" Kaiser knowingly installed and ripped out unsuitable Main Steam Relief (MSR) piping, at an estimated Labor cost of Three Hundred and Twenty Thousand Dollars ($320,000)".
II FindingsSU i
, The allegation was substantiated in that an economic decision was made to install piping, of which approximately 3-10 percent would have to be removed, due to continuing changes in design loads. No attempt was made to substantiate the estimated Labor cost for the portion of pipe that was
, installed and removed. However, costs figures were available for the total design modification relevant to the Main Steam Relief piping.
The RIII inspector identified no items of noncompliance or concerns that were significant to quality construction of the MSR piping. , III Investigation $U t A. Background $UInformationSU The allegation was interpreted to be concerned with the menetary costs of constructing the Main Steam Relief System piping. No information was received to indicate unacceptable quality of the related construction activities. I
5
; 8. Personnel $SInterviewsSU On February 24, 1981, Individual "A", who was previously interviewed I
i by representatives of GAP, was interviewed and stated Kaiser instal-Led a large portion of the MSR piping, knowing sections of it would l Later have to be removed after installation. He recalled that two l years after its installation Kaiser removed large sections of the piping from the 525' Level of the reactor containment building down-ward, and left the pipe sections above that level in place. On April 22, 1981 Individual "A" provided a written statement attestingtotheaforementionedinformationg.owever,herequested the statement not be attached to this report. On April 14 and 16,1981, Individuals "B" and "C", respectively, who allegedly provided information regarding this allegation to representatives of GAP were interviewed and stated they had no information concerning this allegation. C. During the period of 2/9-13/81 and 2/23-27/81, discussions with Mr. H. C. Brinkman, Principal Mechanical Engineer, CG8E, indicated that in 1975 a nuclear power plant in Germany discovered the need to redesign the relief system based on new discharge loads. There-fore,severalutilities,includingCG&E,decidedonamodificationg
i to replace the already installed rams head safety relief valve (SRV)
! discharge devices with quenchers.
e 1 4 1
! In 1975 CG&E decided to start the quencher modification, knowing that part of the piping, not yet installed, would later have to be f removed. The basis for the decision was that approximately 90-97%
of the original quencher modification would be acceptable and there-fore only 3-10% would be subject to rework. CG&E's decision con-i cluded that it would be less costly to go ahead in 1975 with the installation activities rather than to delay the construction schedule until the quencher modification design was complete. To date, the modification design is not complete. The NRC has been aware of the modification activities as described in the Mark II Design Assessment Report, Chapter 2.0 -- Zimmer Empirical Loads, ZPS-1. The RIII inspector observed that the latest
, documentation received from the NRC Licensing Branch No. 2 at the site concerning the modification activities, was NUREG-0487, Supple-
~
I
- ment 1, titled, " Mark II (bntainment Lead Plant Program Load l Evaluation and Acceptance Criteria." It should be noted that there may be more changes in the future due to additional load definitions.
I The modification has required the replacement of 10 inch schedule
- 40 pipe with other 10 inch schedule pipe of different configurations, 10 inch extra strong pipe, and 12 inch extra strong pipe.
T l 1 . l l During this investigation the licensee provided cost figures for i j modification to date. The total Labor cost was $823,780.00 and the j total material plus Labor cost was $1,183,690.00. The NRC made no j attempt to corroborate these costs or the Licensee's claim that it was cheaper to proceed with an installation which was known, before installation, to require rework. The RIII inspector reviewed all revisions to the KEI isometric drawing PSK-1MS, Sheets 21 and 21A, which were pertinent to the main steam relief piping. No additional changes of the magnitude addressed in the allegation were identified. The revisions identi-fied the following changes: Rev. O Redrawn -- original configuration replaced 9/8/76 Rev. 1 Hangers cdded 3/31/77 Rev. 2 Eight lugs added 1/10/78 Rev. 3 Hanger changed , . S/5/78 Rev. 4 New spool pieces added, welds MS212 and 4/3/79 l MS195 voided per S&L Rev. 5 Piping tee section added 6/18/79 ! Rev. 6 Weld MS160 and a 4 inch dimension added 10/1/79 Rev. 7 Field marked (redline) updates added 1/9/80 i
1 9 I 4 Rev. 8 Welds K-461 and K-463 changed; weld K-592 9/27/80 i changed to K-593 per NR-2499; hanger detail section D-D added Rev. 9 Weld K-592 changed to K-461; and weld 9/4/80
, K-593 changed to K-594 i
ALL of the above revisions pertained to the aforementioned quencher modification. The RIII inspector reviewed the QC documentation for the following main steam relief piping field welds: Nos. 160, 160A, 267A, 2678, 267C, 2670, 2688, 268C, 268D, 459, 460, and 461. The records indi-cated that the welds had been accomplished in accordance with ASME Section III 1971, Summer 1973 Addenda. The RIII inspector interpreted the radiographs for the following main steam relief piping field welds: Nos. 160A, 459, 460, 461, 462, and 594. 1 l It is noted that there are approximately five to seven radiographs for each of the above welds. The varying number of radiographs are necessary to cover the entire 360 degrees of each pipe weld. The radiography was performed in accordance with ASME Section III 1971, Summer 1973 Addenda. The RIII inspector identified no unacceptable weld indications on the radiographs.
1 1 s. j .
)
i 1 l s i i The above discussions and reviews indicate that the alleged activi-8; ties were performed in accordance with the KEI QA program. No items of noncompliance or deviations were identified. f h 5
4
,. o.
- 1. The RIII inspectors made visual examinations of structural steel beams in the blue switchgear and cable spreading rooms.
- a. The area observed in the blue switchgear room (elevation 546 ft.)
was 8 feet 3 inches west of workline G,16 feet 6 inches east of workline H and between columns 22 and 54 of SEL drawing #S-546
, l t
Rev. AB. i The following discrepancies were identified:
, (1) The W8 x 17 beam (8 feet 3 inches in length) positioned east to west and located 1 foot 9 inches south of column 24 and 10 inches below elevation 546, was not specified on any perti-nent design drawing. 74c d e. 4 et t'^- A! Esb p . y a a ,.a s n u s e f a m ~ ,c . ny < W a k . % e R I 9 d 14e bea 4 e e t <<e<e.dee we s m t m a > f .o. teel.
I Af ter extensive and unsue:essful retrieval efforts by QA ! personnel, construction personnel were requested to identify [ JT ! any document that would control the unspecified beamj. The [ t construction personnel provided Design Document Change, DDC, I
#S-2050, dated 5-29-80. The DDC only had the signatures of two site construction engineers, who were identifying some !
of the additional W8 x 17 beams in the area covered by S&L drawing S-546. The DDC had no S&L architectural engineering, AE, signatures of app,roval as of 3/27/81. The DDC did not an Specifsc identify et+y-ei O ;ddi t i:n:t beams.
)/#
e The Licensee identified S&L drawing E-189, Sheet 3, Rev. H, Note #17 which allows W8 x 17 beams to be installed and then be submitted on a DDC for S&L approval. dike beam was n,t idenh4cd on *7 " '"'f' No prog am existed for DDC whi c'h
._- . - - - . "u n
_u,L+L g idr t i f !; J to QAj inst Lla-tions an work tha ore rec iving ' wasdo1eby onstruction be1 S&L appr val. Thus no program ex stedi to' assure \ that a L of i t elder q\ t ; the requi ed QC insp ctions (e.g. ualification, proper fit er metal, raceab tity o \ materials, e\c.) related \ r to the DDC ould be ac ompli hed. oQCdo\cumentation tild co\ f \ \ \ be located f r the spec fic bgam idegtified 9y the RIII { inspector. ' (2) The W8 x 17 beam (6 feet 3 inches in length) positioned north to south and located 13 feet 8 inches west of workline G and one inch below elevation 546, was not specified on any per-tinent design drawing; not documented on any QC record; and , had unacceptable welds. t t (3) The W8 x 17 beam (5 feet 5 inches in length) positioned east to west and Located 8 feet 10 inches south of column 24 and { one inch below elevation 546, was not specified on any per-tinent design drawing; not documented on any QC record; and . had unacceptable welds. - i. t
(4) The W8 x 17 beam (2 fee': 8 inches in length) positioned north to south, located 9 feet 6 inches west of workline G, and attached to the beam addressed in paragraph 1.a.(1)(c) and extending north, was not specified on any pertinent design drawing and not documented on any QC record. (5) Two W8 x 17 beams (8 feet 3 inches in length) positioned east ' to west, one located 5 feet 3 3/8 inches and the other loca-ted 9 feet 7 7/8 inches south of column 24, are only tack, welded in place; display no identification or heat numbers; and are not documented on a KEI-1 form (weld record) or any other QC control document. The beams were identified on DDC-2087 which was incorporated into S&L drawing S-546 Rev. AB. DDCs and S&L drawings by themselves do not assure QC 17
~
ve ri fi cation. j I l (6) The location of additional unacceptable welds are identified on Attachment A to this report and noted by (6). l t I l 1, gep - The welds identified in above paragraphs (2), (3), and (6) do
,gp__., not comply with AWS-D1.1 1972 for one or more of the fotLow-
,g _. ing reasons: slag not removed { weld profiles having excessive
.c gh=_-. convexity concavity, blcwholes, porosity and/er undercut.
i i
e . (7) Re-ent rant corners of several W8 x 17 beams had notches instead of the 1/2 inch minimum radius required by AISC seventti~ edition (1969) page 4.113. The locations of these unacceptable beam corners are identified on Attachment A to this report and noted by (7).
- b. The inspectors identified the following discrepancies in the cable spreading rooms:
MMI'l N (1) #4?geam#F2500/8-66B4hafaweldthat b contains gross pordsity. Wel This beam 4 directly above cable tray hanger No. 4HV8FEC231, Wa3 Wat which 4 attached. The beam se located approximately eleven feet south of the north wall at the stairwell. 3 (f) A weld on the five inch channel beam which supports HVAC hanger #2071 had excessive irregular weld profile, excessive undercut, porosity, and craters that are not filled. The channel beam is located two feet north and one foot west of j t cable t ray hanger #13H2FEC008. 'fh t W~ Y D A*!)**'b f
, tere d
/ss/d* inousshof .ts,y .th e web / was e teep c.4/e.
u ( Two W1 beams, loca ed at the op osite end of the sp ading room fr the above inch channe , were on y tack-wel ed nto plac were not m rked with h at number for trace bility; g- __ . . . . we e not sp ified on an design doc ments; ad were not iden-tif1 d on any C record wh'ch would in icate th ir status. [
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K Note: Some of the welds inspected by the RIII inspectors were painted. telst.vtly lu y Therefore, the inspections were forp deficiencies only. The unacceptable welds identified above are contrary to 10 CFR 50 Appendix B Criterion IX and the Wm. H. Zimmer QA Manual, Sec. 9.2 as described in the Appendix A to the report transmittal letter. (353/81-13-01) g Gr8h . k
- The la k of measur s to assure th t all QC inspe\ctions^ \
regards to DDCs whi h might be app oved after th installation activi-performed
. ties hav been perfor ed, is cont re to 10 CFR 50 Appendix B Criterion and the Wm. H. Zimmer QA anual, Secti n 10.1.2 as es c ri-bed in the A pendix A to the report tr nsmittal letter.
(358/81-13-02)' The beams with unacceptable re-entrant corners and the beams that were N installed and not identified as a requirement on any design _ g document _i are contrary to 10 CFR 50 Appendix B Criterion XV and the Wm. H. -
~
Zimmer QA Manual, Section 15.2.2 as described in the Appendix A to the _ report transmittal Letter. (358/81-13-03) i The beams for which the traceability of the heat numbers was not main- [ tained is contrary to 10 CFR 50 Appendix B Criterion VIII and the Wm. H. Zimmer QA Manual, Section 8.2 as described in the Appendix A to the l F report t ransmittal letter. (358/81-13-04) i e m e
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, INV/003/I DRAFT /jp i'
Appendix { NOTICE OF VIOLATION AND i PROPOSED IMPOSITION OF CIVIL PENALTIES I
, Cincinnati Gas and Electric Company Docket No. 50-358
- Wm. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88
! EA No. 81-As a result of the investigation conducted at the W . mH. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - July 14,1981, the violations listed below were identified. In accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205 in the amounts set forth below for the violations listed below.
A. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly 1 *entified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition 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 adverse to quality.", Contrary to the above: i e 6 l
INV/003/I DRAFT /jp
. Appendix A i ; 3. The in process inspections for more than 24 velds in the diesel generator cooling water, starting air, and fuel oil piping systems i
were not performed in accordance with ASME Code, Section III -
. 1971 Edition, Article NB-3661.5(b) and other articles and the condition was not corrected.
I l This is a Severity Level violation (Jupplement II). (Civil Penalty - $ 000) B. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality...shall be accomplished in accordance with... procedures..." The W m . H. Zimmer QA Manual, Section 5.1 states, " Construction, fabrica-tion, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, pro-cedures, and drawings which prescribe acceptable methods of carrying out those activities." The H. J. Kaiser Procedure SPPM No. 3.3, Revision 6, Paragraph 6.4 states, "The Weld Rod Clerk shall issue all filler material on a weight basis. He shall record on the KEI Weld 2 form the weight of all bare rod and covered electrodes issued. He shall also, record on the KEI Weld 2 form the heat number and/or lot number for bare rods, consumable inserts and backing rings, and the heat number and lot number for covered electrodes prict to use." Contrary to the above, the control of weld rod was not maintained as required by H. J. Kaiser procedure No. SPPM No. 3.3,during the second shift during September and October 1979. Specific' 11y, (a) twenty-five weld rod issue slips (KEI weld 2 forms) showed representations of initials of weld rod clerks who were not assigned as weld rod clerks on the days indicated on the weld rod issue slips, and (b) one weld rod issue slip did not show a weld rod clerk signature or initials. l This is a Severity Level violation (Supplement II). (Civil Penalty -$ ,000) I C. 10 CFR 50, Appendix B, Criteria III states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis...are translated into... drawings..." The Wm. !I. Zimmer FSAR, Section 8, provides the design babis for electrical cable separation. .- i
i INV/003/I DRAFT /jp
,- Appendix A The Wm. H. Zimmer QA Manual, Section 3.3.2. states, " Composite...' drawings I
are prepared, translating the" design concepts into layouti of structures, systems, and components necessary for the construction of the plant." Contrary to the above, measures were not established to assure that the design basis for electrical cable separation as set forth in 'the FSAR was translated into drawings in that: ' {
- 1. .
On the east side of- the Cable Spreading Room, at approximately 1 I VL 26, yellow / white (associated) cable No. RE033 extends from i a 2-in. conduit (which also contains blue / white cable No. RE058), ) j t passes approximately 4 inches vertically above the blue Class IE cables contained in tray No. 2072C, and enters blue / white sleeve No. 79. The FSAR design basis prohibits routing blue / white cables in the same raceway and prohibits less than a 3 ft. vertical separation between yellow / white cable No. RE053 and the blue cables l in tray No. 2072C in the Cable Spreading Room.
- 2. On the south side of the Cable Spreading R'oom, green instrument tray No. 3029K, which was 6 inches wide and approxinsately 50 ft.
long, was installed inside white control tray No. 4633E. The installation was in accordance with S&L drawings E-223, Revision G, and E-224, Revision F. Green cable No. WS724, green / white cable No. TI725, Revision F. Green cable No. WS714, green / white cable j No. T1725, and other cables were installed in the green tray. Blue / tray. white white and yellow / white cables were installed in the remaining The FSAR design basis prohibits routing green, green / white, blue / white, and yellow / white cables in the same raceway. 3. On the west side of the Cable Spreading Room, white instrument tray No. 4080K contained many different division-associated cables including blue / white cable No. TI192, yellow / white cable No. RR781, and green / white cable No. TIB16. The FSAR design basis prohibits routing green, green / white, blue / white, at.d yellow / white cables in the same raceway. - This is a Severity Level violation (Supplement II). (Civi? F w lty - $ 000) D. It' t TS
. : , , u r,
' 0, Appendix B, Criterion III states, in part, " Design control shall be applied to...the delineation of acceptance criteria 2:a 3 .cuions and tests."
The Wm. H. Zi m er QA Manual, Section 3.13.1 states, in part, " Design control inspections measures also apply to delineation of acceptable criteria for and tests." e
. g. INV/003/I DRAFT /jp 1
-1
,' s Appendix A i l Contrary to the above:
, a 1. The weld acceptance criteria used by H. J. Kaiser Company from
+ -
July 1980 to January 1981 was not delineated for inspections in j that the weld acceptance criteria was deleted.
}
- 2. The acceptance criteria for a weld performed by H. J. Kaiser Com-pany in November 1979 was not delineated in that the acceptance criteria was designated as not applicable.
i These acceptance criteria were required by ASME, Section III - 1971, and AWS D1.1 - 1972 Codes. This is a Severity Level violation (Supplement II). (Civil Penalty - $
~
,000) t E. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall i
be established to assure that applicable regulatory requirements...are correctly translated into... procedures..." Criterion III, an applicable regulatory requirement, further states, in part, " Design changes, in-cluding field changes, shall be subject to design control measures commensurate with those applied to the original design..." The Wm. 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." Contrary to the above, measures were not established to assure that in-process nonconformances (which constitute field changes) documented in Surveillance Report s were subject to design control measures commensurate with those applied to the original design. Specifically, H. J. Kaiser
' Company Procedure No. QACMI, G-14, Revision 3, allowed such in process nonconformances to be dispositioned without design control measures com-
, mensurate with those applied to the original design if the nonconformances were dispositioned within 30 days.
This is a Severity Level violation (Supplement II). (Civil Penalty - $ ,000) F. 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..."
The Wh. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are speci-fied and included in design documents." -
, INV/003/I DRAFT /jp !
l i i Appendix A ' AWS DI.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 di-rection is transverse to primary tensile stress in the part that is under-
. cut, nor more than 1/32 inch for all other situations."
t Contrary to the above, the design control measures did not include provi-sions to assure that appropriate quality standards were specified in that Sargent & Lundy Specification H-2713, Supplement 7, Standard EB-117,
; and H. J. Kaiser Procedure No. SPPM - 4.6, Revision 8, Paragraph 5.2.9 allowed up to 1/16 inch undercut on the cable tray hanger welds.
This is a Severity Level violation (Supplement II). (Civil Penalty - $ ,000) G. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials...These measures shall assure that identification of the item is maintained... These identification and control measures shall be designed to prevent the use of incorrect or defective materials, parts, components." The W m . H. Zimmer QA Manual, Section 8.2 states, in part, " Identification and control measures are established to prevent the use of incorrect or defective materials...H. J. Kaiser Company preocedures provide that within the 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 identifica-tion may be on the item or on records traceable to the item. The iuenti-fication is maintained throughout fabrication, erection, and installation. The identification is maintained and usable in the operation and mainten-ance program." Contrary to the above the material identification (traceability) of at least nine structural beams and twelve pipe. lines was not maintained. This is a Severity Level violation (Supplement II). (Civil Penalty - $ ,000) H. 10 CFR 50, Appendix B, Criterion II states, in part, "The applicant shall establish...a quality assurance program which complies with the requirements of this appendix " Contrary to the above, the quality assurance program of Bristol Steel and Iron Works, a contractor to the licensee, did not comply with the requirements of 10 CFR 50, Appendix B, Criterion I in that it did not provide independence of certain members the QA staff from cost and
INV/003/I DRAFT /jp i
,' Appendix A ;
schedule. Specifically, the Bristol Steel and Irna Works QA Manual, Appendix B, Section 1.0, Paragraph 1.1 states, "The Erection Quality Control...is the responsibility of the Project Superintendent, who reports to the Project Manager." Both the Project Superintendent and j - the Project Manager had cost and scheduling responsibilities. I j This is a Severity Level violation (Supplement II). i (Civil Penalty - $ 000) I. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures 1 [ design control] shall include provisions to assure that appropriate
} quality standards are specified...and that deviations from such standards are controlled."
The Wm. H. Zimmer QA' Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled." Ccntrary to the above, design control measures had not been established
' to assure that deviations from design conditions (quality standards) are controlled. For example, Sargent & Lundy determined, as noted on a cal-culation sheet dated December 27, 1979, that the design loading for two cables would allow the cables to be thermally overloaded and no program existed to control such desigr. deviations.
This is a Severity Level violation (Supple' .. II). (Civil Penalty - $ 000) J. 10 CFR 50, Appendix B, Criterion III states, in part, "The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program." The Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L , design verification reviews are performed..." Contrary to the above, design control measures had not been established i by Sargent & Lundy to provide for verifying or checking the adequacy I of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays. This is a Severity Level violation (Supplemen II). (Civil Penalty - $ 000) e
___ _~ 1 INV/003/I DRAFT /jp I.
. Appendix A -7 i
K. 10 CFR 50, Appendix B, Criterion VII states, in part, "The effectiveness 1 of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee..." ' 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 evaluation of the bidders' QA programs as a part of their total bid evaluaiton." Contrary to the above, neither the licensee nor designee (Sargent & Lundy) i assessed the effectiveness of the control of quality by vendors who sup-plied structural beams. Specifically, evaluations of the vendors' quality [ assurance programs for control of mill certifications and structural
, beams were not performed.
l This is a Severity Level violation (Supplement II). (Civil Penalty - $ 000). L. 10 CFR 50, Appendix B, Criterion XV states, in part, " Measures shall be established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation." The Wm. H. Ziesner QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformance in receiving inspection, construction, or testing activities which are delegated to HJK. A tag-ging system is established in the HJK Quality Assurance Procedures to assure that nonconforming items are conspicously marked to prevent their inadvertent use or installation." i Centrary to the above, the NRC inspectors indentified:
- 1. Welds on nine structural beams and at least four cable tray hangers which did not conform to requirements in that they contained unaccept-able slag, weld profiles, blowholes, porosity, and/or undercut and these welds were not identified and controlled by H. J. Kaiser Co.
- 2. Five structural beams which did not conform to requirements in that they had notches for reentrant corners instead of radii and these l notches were not identified and controlled by H. J. Kaiser Co.
- 3. Four structural beams installed in the Auxiliary Building Switchgear Room which did not conform to requirements in that they were not specified on any design document and these beams were not identified and controlled by H. J. Kaiser Co.
This is a Severity Level violation (Supplement II). (Civil Penalty - $ 000) l
i . INV/003/I DRAFT /jp
)
Appendix A M. 10 CFR 50, Appendix B, criterion XI states, in part, " Test procedures shall include provisions for assuring that all prerequisites for the
~
given test have been met... Test results shall be evaluated to assure that test requirements have been satisfied." The Wh. H. Zimmer QA Manual, Section 11.1 states, in part, " Test programs 3
' to assure that essential components, systems, and structures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construc-tion site."
ASME Section III - 1971 Edition, Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the-total weld thickness..." Contrary to the above, the NRC inspectors identified 187 radiographs, taken to assure the quality of prefabricated pipe welds, which were made using a radiographic technique that did not comply with the ASME Section III - 1971 Code, Winter 1972 Addenda. Specifically, the unacceptable technique involved the lack of or insufficient shimming of the penetrameter. This is a Severity Level violation (Supplement II). (Civil Penalty $ 000) N. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be established 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 require-l ments for check lists and other appropriate documentation of the inspec-j tions and tests performed." Contrary to the above:
- 1. No QC inspection program was established to require verification of separation of cables routed from the Cable Spreading Room to the Control Room. Specifically, two cables (RI 103 and CM 111) of the blue division had been routed into a green division tray
, riser which extended up to the Control Room, in violation of the site cable separation criteria. e
INV/003/I DRAFT /jp 1-Appendix A l l 2. The programs for the in-process and final weld inspections were . not executed as required in the AWS DI.1 - 1972 Code, for the welds l' on 180 cable tray hangers located in the Cable Spreading Room. Specifically, the final weld inspection had been made after the welds were painted (galvanox). This is a Severity Level violation (Supplement II). (Civil Penalty - $ 000)
.l 0. 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 Wm. H. Zimmer QA Manual, Section 17.1.4 states, in part, "Documenta-tion of all performance surveillance includes personnel identification and qualification, procedure, type observation, date of performance, person or organization monitored, results and corrective action if required." Contrary to the above, the Bristol Steel and Iron Works Quality Control Steel Erection Report, which was a generic boilerplate form for monitor-ing in-process steel erection, did not identify closely-related data such as weld procedure numbers, types of welding material, welder identi-fication, and specific welds inspected. This is a Severity Level VI violation (Supplement II). (Civil Penalty - None) l P. 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..." 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 FSAR states that cable ampacity is based on IPCEA Pub-lication No. P-46-426. Also regarding cable ampacity, the FSAR states the summation of the cross-sectional areas of the cables shall not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross-sectional area in any case." -
INV/003/I ERAFT/jp Appendix A , Contrary to the above, the cable ampacity was not based on IPCEA P-46-426.
' The cable ampacity was instead based on IEEE Paper 70TP557-PWR (1970),
IPCEA P-54-440, and Sargent & Lundy Standard ESA-114a. This is a Severity Level VI violation (Supplement II). (Civil Penalty - None) 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 date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation 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. 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 j 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 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 penalties should not be imposed. 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 from 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 penalties dues, which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, r this matter may be referred to the Attorney General, and the penalties, { unless compromised, remitted, or mitigated, may be collected by civil action i pursuant to Section 234c of the Act, 42 U.S.C. 2282.
~
Appendix A - II - - l l i f
INV/003/I DRAFT /jp Appendix A .; The responses directed by this Notice 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. t FOR THE NUCLEAR REGULATORY COMMISSION i Victor Stello, Jr., Director Office of Inspection and Enforcement Dated at Bethesda, Maryland - this day of , 1981 . l l l l e
e *
,y -
;' ? -
.I Allegation 1
" Kaiser knowingly installed and ripped out unsuitable Main Steam Relief (MSR) piping, at an estimated labor cost of Three Hundred and Twenty Thousand Dottars (5320,000)".
II Findings L None i III Investigation A. ack ound Information l l 0 g-B. Personnel Interviews ( On February 24, 1981, Individual "A,'j wasjpreviouslyinter- l viewed by representatives of GAP, was interviewed and stated i Kaiser installed a large portion of the MSR piping, knowing { t sections of it would later have to be removed after instal-Lation. He recalled that two years after its installation Kaiser removed large sections of the piping from the 525' Level of the reactor containment building downard , and t left the pipe sections above that levet in place. e
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s ,y.< n x . n . J 7 f -[$5ae ,, <.-een.r, a w: N' da.se * ' 7% 4e i n~ s.ie.0/, ,f e ;& c .>. f~., ~.iy l:: , eA <.s , ;< Ary i A.:afr'. & J, aff. yr was er .lc 6 3. d.s/Mr fL- 7 G c s G s . $ . / /e 6.:- c . Y t 8.- YZ t je.. h n , /p,, e 12 r w c. ., ,,sy;&L/a..,fsus,i.e,A W ;.a e e.t, & ccs7s~ ~l . c' s whe o va . '/n Ne 4< Z* ?Is'c 1.u s,,., ,s. 4x- . J<~t 9 is r:c 5., Sta<.- r & e / p.;<,.y .
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(b b'" On April 22, 1981 Individual "A" provided a written statement attesting to the aforementioned information, however he request-
- ed the statement not be attached to this report.
t D d . e 5 a 4 k i I
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. On April 14 and 16,1981, Individuals "B" and "C" respectivet p ggSGf,06,Y gg(,AACJWb fhr$ A&lGUkN*g who prev 4cesty provided informationfpo representatives of GAP [
were interviewefbedvtder:ss'ie'NN ink. ..... .w. rega ra mir tw . a,. - u, a no swco yhdr hno ive ikPon*'"D'^' g/ Copogghkb This Msgriek, C Record Reviews ne i D. Field bservations None E.__ ceptance riteria _
/ None J
I i 1 4 9 M i I I
r NRC Investigati f to fIe Reque of Ac ivities P suant Submi e to the M.S.P.B.
- 1. KE knowin y insta ed and ri ed out suita e main steam relief
, ping a't an esti ated Labor cost of , 20,0 uring the period z
c of 2/9-13/81 and 2/23-27/81, the RIII inspector d*::u:::d :nd r:.i:w:d nor+4--- 4-fer-n4m- mes an ri,,nt e inn em-e - ::,; g ; % ;y,,, [fiscussionswithMr.H.C.Brinkman,PrincipleMechanicalDigineer,
~
CGEE, indicated that in 1975, a nuclear power plant in Germany , discovered the need to redesign the relief system based on new discharge loads. Therefore, several utilities, including CG&E, decided on a modification to replace the already installed rams head safety relief valve (SRV) discharge devices with quenchers. f,,t975 fd**' p ir Y Y ef /*'h]j j CGEE decided to start thejmodification, knowing that g e:re.-k ; ::i .
,, ,7 n;;, yefe44 sr.,st.//c.f sast /st' nininn unn /ab
,4 b; /r.,ve to 6e, vers, s at,
- ces : y, e.;e- th:;;h :h; pipi,; hr4_
not Lien innelled.- The basis for the decision was that approximately i gs.enI,eee.oJ.$.s.7s ' p-y/7, Ai2 of the original deH;- j would be acceptable and therefore only #% J-/2'2' ; would be subject to rework. CGEE's decision concluded that it would ! be Less costly to go ahead in 1975 with the installation activities p s.es l<e r rather than to delay the construction schedule until thejmodification { Q sign was complete. To date, the modification design is not complete. g The NRC has been aware of the modification activities as described j in the Mark II Design Assessment Report, Chapter 2.0 - iimmer Empirical
- Loads, ZPS-1. The RIII inspector observed that the Latest ' documentation !
received from the NRC Licensing Branch No. 2 at t site concerning the
. i l
1
+
modification activities, was NUREG-0487, Supplement 1, titled, I' Mark II Containment Lead Plant Program Load Evaluation and Acceptance Criteria." It should be noted that there may be more changes in the future due to additional load definitions. The modification has required the replacement of 10 inch schedule 40 pipe with other 10 inch schedule pipe of different configurations, 10 inch extra strong pipe, and 12 inch extra strong pipe. During this investigation the Licensee provided cost figures for
- modification to date. The total Labor cost was~5823,780.00 and the total material plus Labor cost was $1,183,690.00. 74e /JAC m a d * * ' /' '
-/m c.c r* 6:. ta YLesu c.n b :.~ & ne. s,<. 's e / . , 14r ; r wss e 4 eye.- 17
- p. . Ad 11. *** o;.sret/ f. o., s.,/,.14 s ss k.ro , bdsrs seds tf=.n .y & .*efuert sw.*h.
The RIII inspector reviewed all revisions to the KEI isometric drawing PSK-1MS, Sheets 21 and 21A, which were pertinent to the main steam l relief piping. No additional changes of the magnitude addressed in the allegation were identified. The revisions identified the following changes: i Rev. O Redrawn - original configuration replaced 9/8/76 1, i Rev. 1 Hangers added 3/31/77 l Rev. 2 Eight Lugs added 1/10/78 l t Rev. 3 Hanger changed 5/5/78 Rev. 4 New spool pieces added, welds MS212 and 4/3/79 _ MS195 voided per SSL , i i e Rev. 5 Piping tee section added 6/18/79 ! Rev. 6 Weld MS160 and a 4 inch dimension added 10/1/79 t 9
Rev. 7 Field marked (redline) updates added 1/9/80 Rev. 8 Welds K-461'and K-463 changed; 9/27/80 weld K-592 changed to K-593 per NR-2499; hanger detait section D-D added Rev. 9 Weld K-592 changed to K-461; and weld K-593 9/4/80 changed to K-594 l a esad t .* -) ALL of the above revisions pertained to the aforementione jmodification. The RIII inspector reviewed the QC documentation for the following main steam relief piping field welds: Nos. 160,160A, 267A, 2678, 267C, 2670, 2688, 268C, 268D, 459, 460, and 461.
/ ,
The records indicated that the welds had been accomplished in accordance k
\
with ASME Section III 1971, Summer 197) Addenda. (
\
l \ The RIII inspector interpreted the radiographs for the following main steam relief piping field welds: Nos.160A, 459, 460, 461, 462, and , 594. ! It is noted that there are approximately five to seven radiographs for each of the above welds. The varying number of radiographs are necessary ; i to cover the entire 360 degrees of each pipe weld. The, radiography was performed in accordance with ASME Section III 1971, S'ummer 1973 i Addenda. M e" ~
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i The above discussions and reviews indicate that the alleged activities were performed in accordance with the KEI QA program. No items of noncompliance or deviations were identified. Addit nal infor'mation: Also co
- acted: J. Oltz Records Su ervisor .
R. . Wood, Engineer \s t
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[ coene6ve oe<r%.r. o e e ___ _ _ . . , 7,_____. _ . , , , _ , _ _ _ _ , - _ _ . , _ , _ . - _ _ . -. _ _ . _ . , . , . - . . _ _ - _ _ . _ , . _ . . _ _ _
r
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..- . , , , - , , , . - - - ..,..--,Q---.--,- r , , , . , . - - . - . . , - - - - - - - - - - - -
SPINOFF INSPECTION ASSISTANCE ! ALLEGATIONS RESULTS REQUIRED
~
Applegate 1 ' Applegata alleged that KEI knowit} gly installa d 1. Verify that this and ripped out unsuitable main steam relief was done according to
; piping at an estimated labor cost of QA program.
P
- $320,000.
- 2. Why was it replacei ?
- 3. Was it controlled?
I I e l l e f e 4 i e
=
l . 1 1 1
o
. SPINOFF INSPECTION ASSISTANCE -
ALLEGATIONS RESULTS REQUIRED Applegate 2 2000 pound' fittings were installed in 1979 1., Interview alleger. on residue head valves, although 5000 2. ~ Find the specific.
~
pounds fittings are required. fittings. gRs
- 3. Check speeffications Os. s and/w ^ ~ t....
O G e 9 e e e e e 6 e k e 9 w a 9 4 e a W* e
SPINOFF INSPECTION, ASSISTANCE ALLEGATIONS RESULTS REQUIRED -. Applegate 3 L radion,etive waste drain'is clogged with Review Tom Daniels'
- oncrete which carelessly was poured into findijgs.
- he drain. .
Get flushing , record. >
~
Get report on repairs. IdentifyJhepipe. [g ha .'eb VMY
,,.7,x.- ge .
e 9 I l io ; - I 4 i l .
SPINOFF INSPECTION ASSISTANCE l ALLEGATIONS RESULTS REQUIRED l Applegate 4 A residbe heat valve broke when a pipefitter 1. Intervihw alleger.
.t tumped into it, raising new questions about 2 .* Identify valve. . .
% the quality of metal used for valves. 3. Is it common problem' ,
L ^ :h :p:21fic :imrs< G e 4 e O O 9 e e t O e
~
l e 0 - G l l a y 9
SPINOFF INSPECT 100t ASSISTANCE - ALLEGATIONS RESULTS REQUIRED Applegate 5 Sensitive parts on welding rods a,re possible 1. eview Tom Daniels' damaged through storage at improper temper- . r_eport.
- l
{ atures, and possibly lost through failure to ,
'. follow proper paper work and labelling requirements.
e G 5 e e e 0 e e N l e o - t e l
. =
e e
SPINOFF INSPECTION ASSISTANCE ALLECATIONS RESULTS REQUIRED
,. } % $ es l f.
Applegate 6 Argon gas valves left open.
- Send letter to OSHA.
.t 4 e M O e
% y 8
O e G 4 e e e O O O O e l f O . O e g 9 e e
1 SPINOFF INSPECII0ll ASSISTANCE . ALLECATIONS RESULTS REQUIRED l Applegate 7 Prefabricated piping received in 1977 has 1. Identify pipe.
.t defective welds, but construction supervisors 2. . Review radiographs ,
. told crews not to repair them because the of the pipe.
- s I 3 8'v'* * "'
welds were made off-site.. WEs .
. , a .. , { l .'. .i G v : ..
6 i t e 0 o 4 9 g O
SPINOFF INSPECTION , ASSISTANCE ALLEGATIONS RESULTS REQUIRED Applegate 8 At least three sources con'tacted by Applegate 1. Interview allegers.
.rl ie <aa.~
confirmdd that an estimated 20% of the plant' s2., hview radiogprakhs
. prefabricated welds are defective. af Kellog welds.
P I 3. Inspect piping. sf Au:ew *yl^ *
- pt s.
b ' LY, L=
. a i
e e e e e 9 e i . l 't - O 6 4 9 # e
f'
~
1
\
. . 1 SPINOFF INSPECIION ASSISTANCE -
l i ALLEGATIONS RESULTS REQUIRED
,.,,pafm '
Applegate 9 It is arleged that engineering designs are 1. Ryview4 records,
. J -
routinely drawn after the fact to conform on piping and electrical , _' with piping that already has been installed. designs. [* 7 " , Another alleger stated that electrical 'a f aaf:% /t$ s engineering design drawings are also drawn p je,I, )*c AY
- Ata. <
after the fact. 9 0 e . I O t e g e e O .- . 4 l e g 9 G
SPINOFF INSPECT 10ll ASSISTANCE ALLECATIONS RESULTS REQUIRED Applegate 10 It was alleged that shock-absorbing electrica_1. Addressed in an
.t .
- tray hangers previously found unsatisfactory .nspec' tion 7919. , ,
a re still unsafe due to faulty welds, and 2. Review recent NR's P on electrical cable leectrical cable trays remain dange'rously full. trays to determine if
- problem fessssssentsag,-
- 3. 7a. ke. west us.e Tl Ah'* f y wl4 3$ A*
,,,w.f. - ve<. y, adeyw<f A'9" 4 u , ,/.- - e ~ '
- y d r<iy n -
e g ,. . ,. . ... ... . . > a g e O . O e - g 9 e e
. . - - - - - - , . - - . - - - . . . . . , - - . - - . - - . - - . - - - - . , . . . - . . , . , - - . - , - . ~ . . , -
SPINOFF INSPECT 10ll ASSISTANCE ALLEGATIONS RESULTS REQUIRED h/lf RyY Applegate 11 Sand and mud choke the fdedwater pumps and 1. Sj55Eisalready I i ; intake flues carrying makeup water to the been issued on this it.em ,
; cooling tower, because of a flaw in the No further work needed. p Pl ant's design. Pumps used to rectify the f1 tw quickly burn out.
e e s e a e e ( !o .- . 8 9 I e 4
SPINOFF INSPECT 1031 ASSISTANCE l ALLEGATIONS RESULTS REQUIRED Applegate 12 A desgin flaw in the heat exchanger control 1. Rfviewinspection i- 88. panel permitted an operator mistakenly to fori e report 7929. , , 1200 pounds of the pipe pressure through 2. Interview witnesses pipes only maant to handle 300 pounds, rippini . of the incident. l the pipe and soaking electricians with a hard 3. Review incident to spray of water that would have been radioactis e determine what caused Tad the plant beeti in operation. the particular
. incident.
. g i s / A e's O .
( /*/ ads. 4 p,.a :4 /* y"'* can cens ~ O e e O ~ e 0 e 9
e SPINOFF INSPECTION , ASSISTANCE ALLEGATIONS RESULTS REQUIRED App 3egate13 There have been periods w' hen there were no 1. S'ecurity staff will security surveillance cameras during nuc1&ar address this allegation, , fuel deliveries to the site, and perimeter to. see what require-P ) security consisted for an extended period ments apply. of only a four foot chickenwire fence. , ,-
../.- .?,
e , G e me , 9 e e e O e 9 e e e l -
- o -
G e e 9 9 e e
SPINOFF INSPECTION , ASSISTANCE ALLECATIONS RESULTS REQUIRED Applegate.14 A lax attitude toward employees behavior was 1. Interviirs allegers d evidence by complete disregard of drinking an ifor sphcifics. , , 2. drug use on the site, and routine hiring of Interview craft temporary laborers prone to violence. personnel. e G O O e 4 0 0 0 0 O O e e e e G e O e 0 e 9 e
-o SPINOFF INSPECTION, ASSISTANCE ALLEGATIONS RESULTS REQUIRED
. fce.*7p=.<x0 de (*
Applegate 15 Employees fired for time' cheating had been 1./4 -Interview Bill
' ~-!
cheating with the expnessed approval Morray on this inciden,t.
' ~
of management, and the only time cheaters 2. Review Applegate's , fired were vocal and knowledgeable critics reports on this of plant QA and safety, incident.
. A.
i . 9
,tve l *, <-
e , d e e o e O .- . I e g O e
~
SPINOFF INSPECIION , ASSISTANCE alt.EGATIONS RESULTS REQUIRED Applegate 16 CG&E had warned PM management to silence the 1. Idterview PM
.- radiographers at Zimmer, who were criticizing manag~ement personnel., ,
CG&E's consistent approval of welds rejected 2. Review Applegate's , by PM. tape with ?M official.
- 3. Determine if PM personnel had responsi-bility to read these
- radiographs or just shooi these radiographs. -
If. I-Ten.' W.'e' 'f' NS pyr ~//,g % 1 e g e 6 O .* . 0 l -
, e
SPINOFF ALLEGATIONS INSPECIION RESULTS
, ASSISTANCE REQUIRED l
Applegate 17 Union pfpefitters and PM employees have been 1. Interview PM
; intimated by fear of utility and industrywide emplojees on and off , ,
reprisals should they complain about QA pract Lees. ' site.
- 2. Interview a representative sample of pipefitters on this issue.
O O O e e 4 0 e g O en e e g e O 4
, 9 4
~
SPINOFF INSPECTIOli ASSISTANCE ALLEGATIONS RESULTS gg Applegate 18 A KEI employee has kept a detailed journal of 1. Locate and interview safety hazards and incidents at Zinner.' this employee. 2 0504 $ , MCL C NS** l t l . i 1 e I i l l i l d g e e O ., - l 1
\
l l l - t -
, e I
i I l I I I l
SPINOFF INSPECTION ASSISTANCE ALLEGATIONS RESULTS REQUIRED Applegate 19 A commoh " joke" among pipefitters at Zimmer . :5PHegum ., is that they will be hundreds of miles away J. .Zdu v.w c rs r
*{ l1,7esbrS b* ' '
when the plant goes on line, due to their ,.f., g , predictions of a disastrous accident. **/ Y , yy y, 0* gf / l 1 I . l
- t l
e i . l g . e i t b - . l l e I r l *
=
l w - ----
( - l FORWARD . l l The following allegations (numbering 1-19) came to the NRC from the Office of Special Counsel of the Merit Systems Protection Board (M.S.P.B.) in a documented Request for an Investigation Pursuant to 5 USC 1206 (b) (7). , The Request was submitted to the M.S.P.B. on behalf of Mr. Thomas W. Applegate by the Government Accountability Project (GAP) of the Institute for Policy Studies (IPS). It is noted that GAP and IPS are not agencies of, nor affiliated with, the United States Government. m
NRC Investigation of Activities Pursuant to the Request Submitted to the M.S.P.B. e -
-1. KEI knowingly installed and ripped out unsuitable main st'eam relief
// .
piping at an estimated Labor cost of $320,000. During the period
, r.
.z.o.
of 2/9-13/81 and 2/23-27/81, .the RIII inspector di5:EN, g ed,and reviewed, a.J d 'icu :4 pt.cinent information and documentation concerning the allegation. Discussions with Mr. H. C. Brinkman, Principle Mechanical Engineer, CG&E, indicated that in 1975, a nuclear power plant in Germany n . . ., ga , . ., ,?' , -:i ,*- I , ' * ' c x, , , discoveredtheneedtoredesignthereliefsystembasedonne(, 3 discharge loads. Therefore, several utilities, including CG&E, decided on a
,?
modification to replace the (already installed rams head safety relief s u valve (SRV) discharge devices with quenchersy aJ rc c e.. . . . e . . ? -) L<
& u e ir s. .-4-e,,.n. . ; .-- k, s .ujp/ic.,-(S....,,/l.'.e',--{ . '.
,,.,p.i',+::.r .; !!.c , . .
p;ch CG&E decided to start the =di44 cat-wme,xknowing that'2ework ed-mein-
- scene.e n -h 9 e ~ . . !. e , w e 'r'n . ~ . : ,
- t e;.T. relief .,igi..g would be necessarye ever, thw;;h the piping had W;c.. innsL4+d, The basis for the decision was that approximately 95% of the original design would be acceptable and therefore only 5%
frettEl would be subject to rework. CGSE's decision g concluded that it would be less costly to go ahead in 1975 with the installation activities n,a ,.L ':1 y :a. . . .': , . rather than to delay the construction schedule until thefp6dificatio' n
*: *g k de ;sn was complete. To date, the modification design',is not complete. 3 The NRC has been aware of the modification activities as described in the Mark II Design Assessment Report, Chapter 2.0 - Zimmer Empirical Loads, ZPS-1. The RIII inspector observed that the latest documentation received from the NRC Licensing Branch No. 2 at t site concerning the
modification activitiesg was NUREG-0487, Supplement 1, titled,
" Mark II Containment Lead Plant Program Load Evaluation and Acceptance Crjteria." It should be noted that there may be more changes in the
_- future due to additional load definitions. The modification has required the replacement of 10 inch schedule
.' '/
40 pipe with other 10 inch schedule 3 pipe of different configurations, . l 10 inch extra strong pipe, and 12 inch extra strong pipe. T hc. k:perff a : ke % c:1,*,n ,M
-Dur-ing-tMs- kvest4gation)-the g Licensee provide % cost fi p;,. .c ..c-.n> a:s+" s,4 %
modification to date. The4 total Labor cost was $823,780,db,'and the totalmaterialplusLaborcostwas$1,183,690,.j'! l The RIII inspector reviewed all revisions to the KEI isometric drawing PSK-1MS, Sheets 21 and 21A, which were pertinent to the main steam ( relief piping. No additional changes of the magnitude addressed in the allegation were identified. The revisions identified the following changes: l Rev. O Redrawn - original configuration replaced 9/8/76 1 Rev. 1 Hangers added 3/31/77 1 Rev. 2 Eight lugs added 1/10/78 l Rev. 3 Hanger changed 5/5/78 Rev. 4 New spool pieces added, welds MS212 and 4/3/79 MS195 voided per S&L , Rev. 5 Piping tee section added 6/18/79 Rev. 6 Weld MS160 and a 4 inch dimension added 10/1/79
o Rev. 7 Field marked Credline) updates added 1/9/80 Rev. 8 Welds K-461 and K-463 changed; 9/27/80 weld K-592 changed tu K-593 per ~i
; NR-2499; hanger detait section D-D .
~
added Rev. 9 , Weld K-592 changed to K-461; and weld K-593 9/4/80 changed to K-594 ALL of the above revisions pertained to the aforementioned modification. The RIII inspector reviewed the QC documentation for the following main steam relief piping field welds: Nos.160,160A, 267A, 267e, 267C, 2670, 2688, 268C, 2680, 459, 460, and 461. The records indicated that the welds had been accomplished in accordance with ASME Section III 1971, Summer 1973 Addenda. The RIII inspector interpreted the radiographs for the following main steam relief piping field welds: Nos.160A, 459, 460, 461, 462, and 594. It is noted that there are approximately five to seven radiographs for
.; each of the above welds. The varying number of radiographs are necessary to cover the entire 360 degrees of each pipe weld. The radiography was performed in accordance with ASME Section III 1971, Summer 1973 Addenda. .
i
- s. .
The above discussions and reviews indicate that the alleged activities were performed in accordance with the KEI QA program.
~:
[ No items of noncompliance or deviations were identified. Additional information: ,
.i Also contacted: F. J. Ottz, Records Supervisor -
R. L. Wood, QA Engineer Previous reports have not yet been incorporated into this write up.
- P)~
.1..
l I i e 6 9 I
. J- T& M W C L7 y- & c.,)ff ges/g /fM4m J /te/z7 M fo Wov$ CSA frNY N V /d F/,
1 1
. The following specif1 etions will be take after the co etion of ammatic measures, wit
- the pr ards to the resp ive items o noncompliance:
Cc.ncerning
), $ 4A Unacceotable Structur 8eam didsf Or-lS eveb PaM4 uhIl be. 5 I *
% 4 emoveMfte
# f rom all of the Agreetarewebt!Meptgge welds.M =AE/,
. Ctc. w4 do w+em/yd %
,,, Ivupecdtt n.: will be- fVrbrmed SW- #4i.tvisupid5ftt@pe of all of the outree welds in accordance with AWS D1.1-1972.
- c. a:.'d i,e mila.
W NNecessary repairs in accordance3 with AWS D1.1-1972.
<\ . ,.s eb l @ Document#}the above activities / al.// he c. cmp /ebd, ce
$ The welds will not be repainted until after the NRC is satisfied with the corrective actions.
l C on cun; ng h% A Traceability of Paterialsp l l 1. W #7 3 spectionsof all accessible structural beams in the f , reactor and auxiliary buildings will be made to verify AND Ar$ams:2:1em> heat numbers. ( 1 ' - A W An inspection will be made of the unapproved supplier of the
k N
%w 5, C 4 %
.i s N
Ej structural beams which have not been accounted. An a % 7 , .-Q 4 ' evaluation wiLL be made to determine the credibility of the dS 3: % 3 k mill certifications received from the unapproved supplier. b l ( \ At Inspectiers wilL be made to verify ept heat numbers on adri ff aj J*l 1 j (q , a g -, 4pi>J!>f;cs&wi&re s
,g,9 components included in the diesel 32 4jS4%
Y generator systems,aed ett-ettr*T+rstwMSdi-the R '% -
.A D 6
E i .4n V o % S 7-,. al.. W 91- &
%% n I~ e.
W Those materials, parts, M components which are not M gg d { g traceable will be identified and egethumeek agroprbb/y' clE5f'J' 9 .,
't;
' W)2 n f *E p,
4W N ?f D D~ W For those KEI-1 forms (weld records) and all other records
+ which have been altered, based on the inappropriate KEI-2
,, d forms (weld rod issue forms) and all other inappropriate l h 4 information, the specific alterations will be identified I
( h %g k
-{ >h and appropriate corrective actions wiLL be taken.
g a v -b
$ bsolutely o additi l al alterat' ns will made t KEI-for. or any her record o correct he alter ions or for 1
any oth reason. Concern.9
.3 sgu 9
WeldsInsoected$ftercaintinoe . A .
painting and for those welds which cannot be determined as to whether inspections were performed before or after [ painting, the paint wiLL be removed and new inspections wiLL be performed in accordance with AWS D1.1-1972. ALL unacceptable welds identified by the inspection wiLL be repaired or replaced in accordance with AWS D1.1-1972. c. 6 The welds wiLL not be repainted until after the NRC is satisfied with the corrective actions. Yk& Cc..reeening h ' Unacceptable Technique W Radiographt d bef abricated boe Yet dem 4 c14 W A review will be performed of all radiographs of prefabri-cated pipe welds to identify those radiographs taken with inadequate shimming of the penetrameteregel $nyother technique inadequac . b. p A program wiLL be defined which wiLL provide assurance that the welds, relative to the unacceptable radiographic techniques, are acceptable. Ce a c erning h's Tenrocerty Voided Nonconformance Peoortsa - m
- M A review of aLL voided nonconformance reports will be per-i l formed, by appropriately authorized and qualified personnel
gn) :yyrepriafely d Erfn.l5 in accordance with the QA program, to identify M 4 P '*usly inappropriate actionsj taken.
~
- ~
' b '
, % $9757f Wo alterations wiLL be made to the voided nor$conformance reports. ALL additional information w //
will be documented on separate records which zum be attached to the original reports, W et+= l -14%-1te a-d. . C ng M Corrective measures for (25(VN inappropriate kn+dN) davlag riu. n,;w actions will be explicitly defined and documented. 3 [, p Cable separ.alinnJ
;t.,, er!abi'rist rea;h .urarseve H,n-I W Measures will be ds*3 Matt which will N cable separation violations, see 'l d,/<M e d c o meted l
Corrective measu s for all of he separation v lation
'll be explicitly de
- ed and wiLL clude justif1 tion of ho the separations are intained in ordance to e FSAR.
I 2f Deleted Inspection Criteria: 3- o - W Measures will be defined which will identify M 2p the Impeclus welds entsOptt': met'tf54P9hropyrgr, EEMfor which the eriteria
has been improperly lined out, noted as not applicable, or I otherwise deleted. b W The identified welds and criteria wiLL be documented. s b {orr etive measures;hm'r;:-t ;c-
-the-4deicJ + .a% wiLL be defined and documented.
[. Nonverified Socket-Weld fit-uns-a. W Measures wiLL be defined which wiLL identify 432Waff the socket welds which were made without visual verification of pipe fit up. l b.
*2h The identified socket welds will be documented.
C. Qi> The corrective measures for the nonverified pipe fit ups e.rfxb h's h d io a.rsure c m Ider-c. w.M ik. ceda. wiLLbebeeR-"--d"--
' - ' ' -Aht -de-e e
a 1
. i Q$ Concerngg Lack of an Adequate QA Program by Bristol M I
i s.tfe& rtlchnl 2, Inspections of 3tutt work completed by Bristol wiLL be performed to assure com7tiance with applicable codes, FSAR commitments, and design specifi cations. w
@. Concerning Design and As-Built Conditions Which Are Contraty.Jo the FSAR M Sf M Q M d, Measures wiLL be est&blished to identify either design or as-built conditions which dif fer f rom commitments or statements made in the FSAR. @ 3entified dif ferences wiLL be satisf actori Ly resolved.
(Either meet or exceed the FSAR commitment or justify acceptance of less conservative design.) f[, @ Concerning Cable Tray , Loading Design, Cont.r.ptg%' E, S & L wiL L perform desion verification. calculations for thermal loading of power sleeves and dea'd weight loading of 40 power, cont rol, and inst rument t rays. P h, Proposed action to resolve M cable t rayipoints that exceed the
. FSAR tray fill Limit of 50% will be d+ find 6. '
3 1 .
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C, Measures will be taken to assure J@ required design Yerifications
~
are performed.
& L wil rovide stificatio of the des' n c s cak t ray oading. /
/), Concerning Inadequate Corrective Actions Taken By .CG&E In Regards .tp Repetitive Problemsg y d s A n ir n trsli?a p te ( d a H s aax M rancn,he/
CG&E will J;.;e6;.ifyJ,bM;7 thei3 r QA program 6 documentation, resolution or corrective action, and followup reaudits of problems identified by CG&E audits. CG&E p ill r< 5e w N f W W f W S W e a . ... W G G W C to m a k n w re- 1,ue besn past audits g M repetit ve problems w identifie g and i hi<* that action has beenpfsWHl2%:M to resolve the problems. If i ini/-54 d 4- d corrective action has not been, completed CG&E will follow each l repetitive problem to satisf actory resolution.
,,[gnJanling .fai re_To. Conduct Audi of Suf fi.cient De th Scope,
, r Frequency _to Id ti_fy Problems in e Q A P rog ra ms, o. _ Ve.ndo_rs,
' (v l g hSu tiers,,,A/E,.or_Cgn_ tystora . M '
l l ('"/f fi f( CGEE will review their Audit rogram to identif weaknesses in he
- ~
M'!f I present prog m, inadequacies of st audits and an corrective i 1 l
ac 'ons, and change to improve the esent progr o rect i tified deficiencie .
;g ggp Concern Desijn Document Chanjes_Not Being Cont rolled CGSE will provide assurances that all Design Document Changes are implemented and verified by QC.
;g, -
r each of e problem ar s identified b the NRC, is r un rstanding tha CGSE will r iew each prob m area and enti the ca es and the g eric applica 'lity of the pr lems to the entire Zi er project inc ing past, p sent, and fut re activities. l l [ I 1 I
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- 1. 'What is the attegation? : ";
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4 i KEI knowlingly instn1]cd and ripped out unsuitable - ~
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main
$320,000. steam relief piping,[at an estimated cost- !of---1.6
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._ . 2.- from where or whom did ,w'e get' the. allegation? (Including additional,
,. , , 7 information). -
0 .. ' _~ . - -- *
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t _ . . _ v., ./ , APPbECATE 'c'ontacted the_,KRC by, t,elephone d cade allegations. - regarding
.,. th..-e Um.
.. H. Zinmer Nucicar. tPower Stition.i.: .--
.- ~ ~ " -
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- 3. When did we get the attegation? -
4., Followin[the receipt of a'llegatio'ns by telephone on February 28, 1980,' arrange =ents were made to ~ interview the alleger to obtain inore detailed informatidn,. During an interview on March 3,1980, the individual made ~ several allegations.- -- - - "- -- *- - --
- 4. How do we know' that we are addressing the allegation? ,
l 4., - A ~<%y F-We
- 5. Identify the manner in which the attegation was reviewed. List the documents and revisions reviewed, the individuals and dates with whom discussions were held, and direct observations made. .
, for facts determined by conversations with individuals, document
[ . the areas discussed and the information obtained. e
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- 6. State the acceptance / rejection criteria used to base all conclusions.;_____ _ ,. .._,
Identify the code, standard, etc., plus any applicable addenda.
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- 7. Clearly state the conclusion. 'If'the attegation is deterinined to I .
_. be non-safety related -- still substantiate if the attegation i- -_ .- ..
; is true or not. .
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- 8. L'hether safety related or not, make sure that both the specific
. and generic (safety related) concerns have been addressed for
~
cach attegation. , , a.att - i ./~ m . .
- - = ___ - __s _*_--------:------- -
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- 9. Identify the status (controtted, ' accepted, or rejected) that the ! -I e
, licensee's QA program indicates 'for the attegation, where possible. .
. , w $
. . . . . _ . . .r&* YM . _ . - - . . . . _ .
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-. 10. Address all previous _ , ,
NRC inspections and investigations that are
. . relevant to the allegations. I
. . - . - . . _ . . - ~ . . . -. = * ~ .
- 11. Obtain and address any information that shows if another government agency (OSHA, ete".) and[dr the ' licensee has dealt with the allegation.!
- 12. Sworn statements will be obtained from those attegers who presented - -
information to Mr. Apptegate, , Statements obtained from other
" ~
persons such as QA/QC inspectors will not be sworn statements unless the investigator believes this is appropriate.
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- 13. Since independent tests or radiographs,sare not intended, please . .
assure that a determination is made that test results and radiographs ...._. . . ,
-- I are not fraudulent and report the basis for this determin'ation. -
'I- - - .- -.-
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- 14. Since it has been stated that management statements may not be I._.___
t.
- .. accurate because they have a vested interest in the site, verify at least a percentage of management statement's by such means as , ,--
~ . ._ .
' - ~ ~ - ~
records or direct observation to assure their accuracy. Ar WY NO f& A ' .' A l l 9
_.j_ yrj gy pep- i ve cravs rir
-- - --- -- - - - - - - - - - - - - ~
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- 1. The RIII inspectors made visual examinations of structural steel beams in 'the blue switchgear and cable spreading rooms. .i
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- a. The area observed in the blue switchgear room (elevation 546 ft.)
was 8 feet 3 inches west of workline G,16 feet 6 inches east of workline H and between columns 22 and 54 of S&L drawing #S-546 Rev. AB. The following discrepancies were identified: (1) The W8 x 17 beam (8 feet 3 inches in length) positioned east to west and located 1 foot 9 inches south of column 24 and 10 inches below elevation 546, was not specified on any perti- , nent design drawing. - Af ter extensive and unsuccessful retrieval efforts by QA personnel, construction personnel were requested to identify any document that would control the unspecified bearrj. The construction personnel provided Design Document Change, DDC,
#S-2050, dated 5-29-80. The DDC only had the signatures of two site construction engineers, who were identifying some
; of the additional W8 x 17 beams in the. area covered by S&L
- drawing S-546. The DDC had no S&L architectural engineering, AE, signatures of approvat as of 3/27/81. TheIDDC did not ]
identify all of the additional beams. 1 y;
, a? -
The Licensee identified S&L drawing E-189, Sheet 3, Rev. H,-
~
Note #17 which 3Ltows W8 x 17 beams'to be insta) Led and then
, be submitted on a DDC for S&L approval. _
weeld uded:/y,. No program existed for DDCs which 4 ich t:cd to Q$installa-tions and work that vas done by construction.before receiving S&L approval. Thus no program existed to assure that all of 1 the required QC inspections (e.g. welder qualification, proper filter metal, traceability of materials, etc.) related dL - to the DDC would be accomplished.' No QC documentation could be located for the specific beam identified by the RIII inspector. (2) The W8 x 17 beam (6 feet 3 inches in length) positioned north to south and Located 13 feet 8 inches west of workline G and one inch below elevation 546, was not specified on any per-tinent design drawing; not documented on any QC record; and had unacceptable welds. (3) The W8 x 17 beam (5 feet 5 inches in length) positioned east to west and Located 8 feet 10 inches south of column 24 and one inch below elevation 546, was not specified on any per-
. tinent design drawing; not documented on any QC record; and had unacceptable welds.
l
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(4) The W8 x 17 beam (2 feet 8 inches in length) pos'itioned c. I north to south, located 9 feet 6 inches west of 'workline G, and attached to the beam addressed in paragraph 1.a.(1)(c) and extending north, was not specified on any pertinent design drawing and not documented on any QC record. (5) Two W8 x 17 beams (8 feet 3 inches in length) positioned east to west, one located 5 feet 3 3/8 inches and the other loca-ted 9 feet 7 7/8 inches south of column 24, are only tack - welded in place; display no identification or heat numbers; ,, and are not documented on a KEI-1 form (weld record) or any - other QC control document. The beams were identified on [, DDC-2087 which was incorporated into S&L drawing S-546 Rev. AB. DDCs and S&L drawings by themselves do not assure QC ve ri fi cation. (6) The location of additional ugacceptable welds are identified on Attachment A to this report and noted by (6). The welds identified in above paragraphs (2), (3), and (6) do not comply with AWS-D1.1 1972 for one or more of the follow-ing reasons: slag not removed jweld profiles having excessive et convexity concavity, blowholes, porosity and/or, undercut. e
t (7) Re-entrant corners of several W8 x 17 beams had notches instead of the'1/2 inch minimum radius required by AISC seventh edition (1969) page 4.113. The locations of these unacceptable beam corners are identified on Attachment A to this report and noted by (7).
- b. The inspectors identified the following discrepancies in the cable spreading rooms:
d . (1) W12 beam #F2500/8-6694 haf a weld that contains' gross porosity. M/4# This beam 44r directly above cable tray hanger No. 4HV8FEC231, We3 Wa8 which der attached. The beam se located approximately eleven feet south of the north wall at the stairwell. . (2) A weld on the five inch channel beam which supports HVAC hanger #2071 had excessive irregular weld profile, excessive undercut, porosity, and craters that are not fitled. The i channel beam is located two feet north and one foot west of cable t ray hanger #13H2FEC008. l (3) Two W12 beams, located at the opposite end of the spreading room f rom the above 5-inch channel, were only tack-welded into place; were not marked with heat numbers for traceability; were not specified on any design documents; and$were not iden-tified on any QC record which would indicate their status. LJ J
/
l .
, .o . .
Jh( Note: Some of the welds inspected by the RIII inspectors were painted. Therefore, the inspections were for gross deficiencies ontiy.' '
~
The unacceptable welds identified above are contrary to 10 CFR 50 Appendix B Criterion IXqand the Wm. H. Zimmer QA Manual, Sec. 9.2 as described in the Appendix A to the report transmittal letter. I (353/81-13-01)
'Cf6 The lack of measures to assure that all QC inspections performed, in 4
regards to DDCs which might be approved after the installation activi-I: . 1 ties.have been performed, is contrary to 10 CFR 50 Appendix B Criterion X.and the Wm. H. Zimmer QA Manual, Section 10.1.2 as descri-bed in the Appendix A to the report transmittal letter. (358/81-13-02) l The beams with uracceptable re-entrant corners and the beams that were l installed and not identified as a requirement on any design document l are contrary to 10 CFR 50 Appendix B Criterion XV and the Wm. H. Zimmer QA Manual, Section 15.2.2 as described in the Appendix A to the report t ransmittal letter. (358/81-13-03) , The beams for which the traceability of the heat . numbers was not main-l tained is contrary to 10 CFR 50 Appendix B Criterion VIII and the Wm. l - H. Zimmer QA Manual, Section 8.2 as described in the Appendix A to the report t ransmittal letter. (358/81-13-04) 4P'
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- 3. The RIII inspectors made visual examinations of the installed materials and reviewed per,tinent documentai< tion to determine if structural
- beams, piping, and weld rod were traceable to mill certifications.
- a. StructuraLSSBeamsSU (1) The traceability of the W8X17 beams, installed by the Bristol
! n,.-
SteelCompanyintheblueswitchgea{,,wasproperlymaintained by recording the respective material heat numbers on the applicable drawing and/or the beams themselves. W (2) The traceability of some l8X17 beams, installed by H. J. Kaiser Company, was not maintained. No records were documented to identify heat numbers. Some beams were m d with heat numbers. The beams, in<dentified by the symbol *** on Attachment B to this report, did not have any traceability maintained. These beams were located in the auxiliary building blue switchgear room at elevation 546 feet. l Furthermore, several hundred feet of W8X17 beams were purchased on P.O. # and received from
- ..~.t <e,.
who was not afyapproved vendor. <-
' These beams were not controlled to prevent their use in l
safety related systems. MILL certifications were available for these beams. On April 10, 1981 the Licensee stated that these beams had been made available for installation in safety
related systems based on the mill certifications and without regard to the vendor not being approved. The Licensee also stated that the credibility of the mill certif.ic,ations
. would be established. Failure to assure that the bsams were purchased f rom a vendor that had been approved is contrary to 10 CFR 50, Appendix B, Criterion II and the Wm. H. Zimmer QA Mn<anual, Section 2 as describd<ed in the Appendix A to the report transmittal letter. (358/81-13-06)
- b. PipingSU The traceability of some of the piping components comprising the lines in the diesel generator cootpg) water, starting air, and fuel oil systems was not maintained. The discrepancies were as follows:
Sent (1) Yhp heat numbers recorded on thsiso<<the isometric drawings did not match the heat numbers on the installed components. These piping components are documented on Attachment C to this report. 3eme (2) 74; heat nyhqqrs recorded on the isometric drawings dh<<had been marked or whited out and then an incorrect heat number recorded. For example, ISK M-242-2-DG-53 was apparently changed to 0 indicate heat N< number HA-q[1 for the 3/4 inch and 1/2 inch installed piping. Based on the records for accepted heat numbers, number HA-001 represented 1 1/4 inch piping. d
(3) Three heat numbers (HA-0170, TW 24402, and 502891) found on the installed piping, do not appear on the records of accepted heat numbers. In many instances, heat numbers could not be found on the installed component. Therefore, a comparison could not be made to the number recorded on the drawings.
- c. WeldSSRodSU W
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- 3. Failure to maintain heat number , identification for the above aru beams, piping, and weld rod is contrary to 10 CFR 50, Appendix B, Criterion VIII and the Wm. H. Zirraer QA Manual, Section 8 as described in the Appendix A to the report transmittal letter. (358/81-13-07)
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ATTACHMENT C Di s c r e pan c i e s $ SB et w e en SSIn st a l l ed SSPi pi n g SSand S ST ra c ea bi l i t yS SRec o rd s SU for?
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Isometric Drawing ' Line No. Heat Nur.ber o dentification No. l' Item In Number Question h According'Actually Installed
. i . to Drawing i
l 1 ISKM-428-6-DG-19 1DG28 AB1 6 90 ells M276 M267 Tee M315 M274 Pipe HE 6247 8464 ISKM-428-6-DG-103 1DG28AB1 l Flange RVA CB8 2. 1DG27AB1 Pipe HE6247 16E4 lSKM-428-6-DG-16 1602 l ISKM-428-8-DG-68 1DG01 AB1 Pipe HE6247 3416 ISKM-767-4-DG-113 1DGF2AA'1/2 90 ells M395 M252 1DGF2BA 1/2 ISKM-428-6-DG-24 1DG27AE1 1DG28AE1 Pipe HD7123 TW24402 ISKM-428-6-DG-105 1DG28AE1 Flange RD2Y CB8 ISKM-242-2-DG-53 1DG-CSAA 3/4 Pipe HA001 JE9922 l 90 ELL M262 M87 1DGF/AA 1/2 Pipe HA001 HA0170 l 1DGC5BA 3/4 Pipe HA001 JE9922 l 90 ELL M262 M87
=
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Par $ Isometric Drawing Line No. Item In Heat Number or dentification No. Number. Question % According' Actually Installed to Drawing 6 1DGhA 1/2 Pipe HA001 HA0171 ISKM-428-6-DG-26 1DG25AC2 Pipe 516405 502891
. 415007 90 ell M287 M273 ISKM-428-6-DG-27 1DG25AC2 Pipe 516405 502891
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- 4. The RIII inspectors reviewed the H. J. Kaiser Company Procedure No.
QACMI G-14, Revision 3 for initiating and documenting QA Surveillance Report s,, Sg Page 1,. paragraph 2 sa<tates that surveillance reports wiLL be used to identify an in process nonconformance which can be corrected without processing a Nonconformance Report (NR). The QA Surveillance chec.k om*f f6 We<fiff Report form provides g.a :p':-"": *';c -ci-in process deficienc(\ I t.,F, The QA Surveillance Reports do not require review and approval by the f ersonn t/
appropriate S&L, CGSE ;: :: ; r. ; i . . . . , "C'E 0'!!7 or KEI GAG, as required on Nonconformance Reports.
Per QACMI G-14, Revision 3, page 2, paragraph 5, a surveillance report, which identifies an in process nonconformance wiLL j be transferred to an NR when the noncomplying condition has not been acceptably corrected within 30 days.
Were ne$ y
)q feasures4established to assure that aLL in process deficiengtee end dispositions are reviewed and approved by appropriate design and QA engineers. This is contrary to 10 CFR 50, Appendix B, Criterion XV and the Wm. H. Zimmer QA Manual, Section 15.9 as described in the Appendix A to the report transmittal Letter. (358/81-13-08) i 9
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- 5. The RIII n< inspectors made visual inspections of both vendor.and field welds on the following cable tray hangers in the cable spreading room, blue switchgear room, and elevation 473 feet auxiliary building.
- a. Cable $SSpreadingSSRoomSSHangersSU (1) No.14H11FEC145 no unacceptable weld discontinuities (2) No.14H11FEC147 no unacceptable weld discontinuities (3) No. 4H2FEC193 no unacceptable weld discontinuities; foot connect-ion covered with fireprr<oofing (4) No.15H1FEC160 covered with fireproofing <<<
(4) No.15H1FEC160 no Unacceptable wel'd discontinuities;-
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foot connectica covered with fireprr<oofing (5) No. 70HFE 165 (cross brace member No. 23HV5FEC294) - welds had irregular profile, porosity, and undercut (6) No.15H2FEC175 (second horizontal member from the top) -
weld has undercut.
(7) No.14H11FEC146 (cross member) an appaedgf vendor weld has undercut and slag (8) No.16H1FEC156 (weld marked rejected) - weld has spatter and undercut ALL of these welds were painted, therefore, the welds were inspected for rou<<relatively large discontinuities only.
A_.___._.__ _ _
The RIII inspectors reviewed approximately 180 Construction Inspection Plans (CIP), inspection records, for the hangers in the
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cable spreading room (elevation 536 feet in the north section of the auxiliary building). The records indicated that all of the field welds were inspected and accepted in December,1980 and Janua ry, 1981.
Discussions with the pertinent GC management and inspection personnel revealed that the welds ha'd been inspected after being painted. No records were available to indicate that in process inspections were
. V .
made to'herify proper filter metal, weld procedure, welder's qualification, surface conditions, etc., as required by the AWS D1.1-1972 code, section 6.
The Licensee stated that the visual examinations of the tray hanger welds were based on H. J. Kaiser Company Procedure No. SPPM 4.6, Revision 8, dated August 29, 1980, paragrp<aph 5.1.3 which states, i
" Surface condition - joint surfaces to be examined shall be cleaned R
and free from slag, rust, arc burf s, paint, dirt, or other contaminants that would interfere with the x< examination." The Licensee stated 8 4 that paint (falvayox)thatwasappliedtothehangerweldsdidnot l interfere with the visual examination and in some cases actually l highflighteddiscontinuities. AWS D1.1-1972 code, section 3.10.1 l
states, ". . . Welded joints shaLL not be painted until after the l
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work has been completed and accepted. . ."
The apparent lack of in process inspections and inadequate visual e< inspections of the above hanger welds is contrary to 10 CFR 50 Appendix B, Criterion X and the Wm. H. Zimmer QA Manual, Section 10.1.2 as described in the Appendix A to the report transmittal letter.
(358/81-13-09) .
The RIII inspector requested the design acceptance criteria which was used by QC to evaluate the undercut on hanger No.15H2FEC175.
The Licensee provided S&L Specification H-2713 Supplement 7, Standard EB-117 and J<H. J. Kaiser p< Procedure No. SPPM 4.6, Revision 8 which allows up to 1/16 inch undercut on the cable tray hanger welds. The 1/16 inch criteria does not comply with e
AWS 01.1 1972 Section 3.6.4 which states "For building;and tubular structures, undercut shaLL be no more than 0.01 inch deep when it's i< direction is transverse to primary tne<<tensite stress in the i
part that is undercut, nor more than ,5/32 inch for all other situations." This deviation from the AWS code is contrary to 10 CFR 50, Appendix B, criterion III and the Wm. H. Zimmer QA Manual, Section 3.3 as described in the Appendix A to the report transmittal letter. (358/81-13-10)
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- b. B L,ue SS Swi t c h g e a r $ S Roo mS S Ha n g e r s S S ( El e va t i on SS525 S S F e e t S Sand SU L = 16 Drawing $SNo.SSE$96)$U no unacceptable e< weld discontinuities
(1) No.1H029 (2) No. 5H25 - foot connection covered with fireprr<oofing; no visible unacceptable weld discontinuities (3) No. 5H30 (2) no unacceptable weld discontinuities (4) No.1H077 no unacceptable weld discontinuities i
, (5) No.1H079 no unacceptable weld discontinuities I '
(6) No.1H133 no unacceptable weld discontinuities (7) 2 Nos. 5H19 no unacceptable weld discontinuities 8
(8) No.109HV4 (east and west side))- had unacceptable weld discontinuities which were en<ontrolled on construction l l
inspection plans (records) ,
(9) No.1H28-2 no unacceptable weld discontinuities (10) No.1H28-1-no unacceptable weld discontinuities (11) No.1H29 no unacceptable weld discontinuities (12) No. 5H30 (2) no unacceptable weld discontinuities (13) No.1H077 no unacceptable weld discontinuities (14) No.1H133 no unacceptable weld discontinuities (15) No. 5H19 (4) no unacceptable weld discontinuities l
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2 (16) No. 5H3(12) no unacceptable weld discontinuities (17) No. 5H2(12) no unacceptable wild discontinuities [
(18) No. 5H25'- no unacceptable weld discortinuities; foot cor.nect-il ion covered with fireproofir.g
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- c. El eva t i on S S473 S S F e e t S SAux i l i a r y S SBu i l'd i ngf SHa n g e r s 5U (1) No. 5H009 (drawing E-91) '- no unacceptable weld discontindities .
(2) No. 4H3 f[ drawing E-14) n3 unacceptable weld discontinuities (3) No. 2H1 (drawing E-14) nd unacceptable welv discontinuities (4) No. 5H010 (drawing E-91) no unacceptable weld di,scontinuities ;
(5) No. 5H012 (drawing E-91) no unacceptable weld discontinuities (6) No. 6H1 (2) (drawing E-14) no unacceptable weld dsi<<
discontinuities (7) No. 6H1 (1) (drawing E-14) no unacceptable wetd discontinuities Four to six weeks wer<<<
who Four to six welds were inspected on esch,of the above hangers. ,
l l
gSeveral of the tray hanger . foot connection 3 (where the hangers are >
attached to the structural teams) were covered with fireproofing-and could not be inspected. Therefore, the RIII inspectcr>
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requested QC inspection documentation ~ to assur'e tht<at the welds, covered by fireproofing, were acceptable. The Licensee provided a copy of Surveillance Report No. 2393 dated Jaj<auary 8,1981 l . . _
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( which itr; .':W that 94 of 179 cable tray hangersjin the cable spreading room j whic+r have one or both foot connections' covered with fireproofing. The SR requested clarification as to what GC should do since the foot connections had not been inspected. 'M .'wo r m -.9 ;; 2; .L. u..,,,. -..,,.w.e .- .u- n ,,,,,, _
As of March 27, 1981, the SR had no dispoisi<< disposition.
This item is unresolved pending the resolution of the hangers identified in SR No. 2893 and any other hanger connections throughout 3
the plant that were covered before being ' inspected. (358/81-13-11) e p
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(.STATUSOFRII NVESTIGATIONh hPALLEGATION)
- ALLEGATION NO. 1 KEI knowingly installed and ripped out unsuitable main stean relief piping at at estimated Labor cost of $320,000.
FINDINGS This allegation was substantiated but there were no uncontrolled nuclear safety concerns.
BASIS FOR FINDINGS Discussions with the CG&E Principal Mechanical Engineer confirmed that (MSR) Main Steam Relief piping was installed with foresight that part of the piping would later be replaced. The MSR piping was already being installed for the second time in order to replace the rams head discharge devices with quenchers. This second design resulted after discovery of new discharge loads at a plant in Germany in 1975. The NRC has been aware of the design modification as indicated by the Zimmer Mark II Design Assessment Report and NUREG-0487.
CGEE decided to start the modification in 1975 knowing that approximately 5% of the piping would have to be replaced. The design modification iv
W-3-ors pas incomplete and changes would be continuing. To date, the design modi-fication in 1975 was an economic one, based on not delaying the construction schedule. The total Labor cost to date is $1,183,690.00.
The RIII inspector reviewed atL revisions to the applicable isometric drawing for the MSR piping. ALL revisions indicated changes based on the above design modi fication. Therefore, there have been no other activities pertaining to the MSR piping of the monetary magnitude that was alleged.
The RIII inspector reviewed the QC documentation for 12 welds in the piping and interpreted the radiographs for six welds in the piping. The records indicate the design modification has been properly controlled.
- ALLEGATION NO. 2 l
l Two thousand pound fittings were installed in 1979 on residue head valves, although 5,000 pound fittings are required.
~
i 1
l FINDINGS l
l This allegation was substantiated but there were no uncontrolled nu: Lear 1
safety concerns.
_ BASIS FOR FINDINGS 1
1 The RIII investigators' discussions with the alleger's source for this al-Legation revealed that components involved were not residue head valves but A
h M jef-dY#e/Md /2 Q b->c-ji rather the actuators for the hydraulic control lines to the flow control valves at the discharge of the recirculation pumps.
The RIII inspector verified that, though the flow control valves serve as a safety related pressure boundary, the hydraulic actuator has no safety related function.
A design document change written on 8/23/78 and approved by the designer (Sargent 8 Lundy) indicated ~that 3,000 pound fittings were approved for use on the actuators in place of 6,000 pound fittings.
The RIII Senior Resident Inspector at Zimmer said that based on his reviews of the plant systems, there are no other actuators, like the ones addressed above, used anywhere else in the plant.
l In addition, the RIII inspectors interviewed approximately 16 pipefitters (the alleger's source was a pipefitter) who stated that they had no knowledge which would support this attegation.
_* ALLEGATION No. 3 i
l A radioactive waste drain is clogged with concrete which carelessly was poured into the drain.
FINDINGS l
This allegation was substantiated, and there were no uncontrotted nuclear I
3
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. safety concerns.
BASIS FOR FINDINGS The RIII investigators discussions with the alleger's source for this allega-tion revealed that the drains were clogged in 1976 and 1977.
The RIII Senior Resident Inspector at Zimmer stated that, based on his reviews of the plant systems, the alleged drains are non-safety related. Further, the resident inspector's interviews with the personnel responsible for flus /ing the drains indicated that some drains were at one time plugged with debris. However, the personnel interviewed and the flushing records commen-cing in 1979, indicate that the drains have been cleaned out and flow has been verified. The RIII Resident Inspector also verified that all accessible Rad Waste Building and Auxiliary Building Ventilation Room drains were not visually plugged at the ports.
- ALLEGATION NO. 4 A residue heat valve broke when a pipefitter bumpted into it, raising new questions about the quality of metal used for valves.
FINDINGS This allegation was not substantiated and there were no uncontrolled nuclear safety concerns.
kCW- ~1 M &ck S g-v BASIS FOR FINDING The RIII investigators discussions with the alleger's source for this allegation revealed that the component involved was not a residue heat valve but rather an actuator for the hydraulic control !ines to a flow control valve at the discharge of a recirculation pump.
The RIII inspector verified that though the flow control valve serves as a safety related pressure boundary, the hydraulic actuator has no safety related function. The RIII inspector researched the applicable General Electric records for the flow control valves and questioned the G.E.
Control and Instrument Engineer responsible for these valves. The RIII inspector did not find evidence that indicated that the valves, the actuator, or fittings had been broken. The RIII inspector inspected the valves, the hydraulic Lines to the actuators, the actuators, and the recirculation pumps. ALL of these components were intact and appeared satisfactory. The hydraulics of the system had been satisfactority st6rked.
In addition, the RIII inspectors interviewed approximately 16 pipefitters (the alleger's source was a pipefitter) who stated that they had gknow-ledge that would support this allegation.
- ALLEGATION No. 5 Sensitive parts on welding rods are possibly damaged through storage at irr' roper temperatures and possibly lost through failure to follow proper gaper work and labeling requirements.
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. FINDINGS (1) The first part of this allegation (improper temperature) has been sub-stantiated and had nuclear safety concerns.
(2) The second part of this attegation (failure to fotlow proper paperwork anc labeling requirements) was not substantiated and has no uncontrolled nuclear safety concerns.
BASIS FOR FINDINGS (1) The Licensee has been cited on numerous occasions (nine IE reports) by the NRC for inadequate control of weld rods which require temperature control. Currently, the Licensee's corrective actions to the citations and program to control rod temperatures appears adequate.
(2) Discussions with the alleger's source for this allegation revealed that this concern was that during September and October 1979 there l was no pipefitter assigned to the weld rod shack during the evening shift to account for weld rods. Thus, the alleger's source did not know if the weld rod was being properly returned and accounted for on KEI-2 forms.
- The RIII inspector reviewed weld rod issue slips, KEI-2 forms. The KEI l
form is a construction form which indicates weld rod capability. The form l
requires the welder's foreman and the weld rod issuer's signature. The
! , forms require no QC signatures. Approximately 15 KEI-2 forms for the
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. September - October 1979 period and approximately 20 additional KEI-2 forms dated in 1978 were reviewed. ALL of the records indicated that the respective welding rods had been properly acounted for.
It should be noted that since the KEI-2 form requires no QC signature the form is not a credible QC record.
I It should be noted that while weld rod verification by QC is not alleged, the RIII inspectors have identified programmatic problems concerning weld rod verification. These problems were identified while pursuing a spinoff atlegation. The specific problem is that the inspection requirement for GC is verified the use of proper filters (weld rod) was inproperly deleted for the period between July 1980 and February 1981. The deletion is contrary to the Code requirements. This wiLL be an item of noncompliance.
- ALLEGATION NO. 6 Argon gas valves for flushing oxygen from pipes routinely are left open by the day crew, causing the night crew to be overcome by gas, a problem about which CGSE Safety Director Cummings expressed disinterest. In addition, on February 24, 1981, GAP representatives in a meeting with Region III stated that John Bedinghouse's son James, former Security Officer, was almost overcome by argon gas while making his rounds in the containment building. In addition, in an af fidavit supplied by James Huwel, Huwel states that day shif t workers at Zimmer crimped and wired argon hoses (rather than close the gas valves at the source) resulting in argon gas leaks which caused the night workers
,to suffer f rom dizziness.
l #7
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, FINDINGS This allegation has been partially substantiated; however, it is stiLL under investigation.
[, _'
T BASIS FOR FINDINGS A KEI safety inspector confirmed that there had been instances where he had discovered argon gas hoses crimped and wired closed, although he stated to his knowledge there were never any instances of workers being overcome by argon gas. On instance was reported where a former security officer experienced illness as a result of map gas inhalation. John Bedinghouse was interviewed and stated that he was never overcome by argon gas and knew of no one who was. In addition, inspectors from the Occupational Safety and Health Admini-stration inspected the area where the alleged argon gas accumulations affected worker safety and found no instances of argon gas settlement. OSHA did state, l however, that the containment suppression pool area in its opinion fits the definition of a confined space as spelled out in ANSI Z117.1-1977, Safety Require-ments for Working In Tanks In Confined Spaces. OSHA stated that with the number of welding, cutting, and grinding operations that are being performed ,
there, there is definitely a lack of natural ventitation and this can create safety problems. OSHA recommends "that Kaiser supply and implement the use of portable exhaust fans when welding / cutting in galvanized or stainless b I
steel in order to insure that air is circulating continuously." -'
- ALLEGATION NO. ,
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1235-9, 7gd We4
.* ALLEGATION NO. 7 Prefabricated piping, received in 1977 wea defective welds, but construction supervisors told crews not to repair them because the welds were made offsite.
FINDINGS This allegation was not substantiated.
BASIS FOR FINDINGS The RIII investigator's discussions with the alleger's source for this allegation revealed that the piping involved was five spool pieces delivered from Kellog Company to the site. Upon arrival at the site on July 3,1979, the pieces were dropped off the delivery truck.
The RIII inspectors reviewed the QC documentation relevant to the pieces being dropped. The documentation indicated that radiographs of the welds on the pipe pieces were taken to identify any defects that would have resulted when the pieces were dropped. The documentaiton indicated that, when indica-l tions were identified on three of the five pieces, instructions were given by Kaiser personnel to disregard radiographs.
Laterdocumentjt,ijn'sindicatethatultrasonicandvisualexaminations were made of the welds on the three questionable pieces.
The UT and visual examination records indicate that the welds were
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- acceptable.
All five pieces were installed in the main steam relief system.
During this $ection, the RIII inspector made visual examination of the welds on the spool pieces. He identified no unacceptable indications. He also u :
concluded that space on the thickness and configuration of all the pieces, radiography would not be a credible volumetric technique of examination. The RIII inspector stated that ultrasonic and visual examinations were the proper NDE techniques for these pieces. The RIII inspector reviewed and stated that the UT results appeared proper and were acceptable.
- ALLEGATION NO. 8 ,
At least three sources contacted by Mr. Applegate confirmed that an estimated l
20% of the plant's prefabricated welds are defective.
JINDINGS This allegation was not substantiated.
_ BASIS FOR FINDINGS During the RIII inspector's discussion with one of the alleger's sources for this allegation, the source stated that the 20% estimate was bised on:
l l the sources firsthand knowledge of four occasions in which radiographs,
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. taken in 1976 of filled welds in the residual heat removal system, overlapped vendor welds. The source stated that he had no additional knowledge concerning the fourth occasion.
(2) The radiographs of the three spool pieces that were dropped off the truck on July 3,1979.
(3) An affirmative acknowledgement given by the KEI project manager was the source stated that 20% of the prefabricated pipe welds were defective.
(4) A conversation the source had with an ex-employee of a pref abricated pipe supplier.
No additional information was provided from any of the other sources.
The RIII inspector reviewed approximately 200 radiographs taken in 1976 of field welds in the residual heat removal system. No overlaps with vendor welds were identified.
l Radiography was not a credible NDE technique for the three spool pieces that were dropped of f the truck.
l l
l l The RIII inspectors also interpreted over 600 radiographs involving over 200 prefabricated pipe welds. The inspectors identified radiographic technique l
problems with about 25% of the radiographs. Of the remaining 75%, the welds appeared very good.
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PALLEGATION NO. 9 l
l Engineering " designs" routinely are drawn after the fact to conform with piping that already had been installed.
l l FINDINGS l This allegation was not substantiated.
BASIS FOR FINDINGS i
The RIII inspector selected and reviewed the isometric drawings for piping design in the (1) main steam release system, (2) Low pressure core spray system, (3) feedwater system, and (4) reactor isolation system. The i
l review of drawings, includes design date, and installation date indicated that the piping in alL four of the above systems designed were drawn before the installation of respective piping.
The first three designs identified above were large bore (two inch and over) systems. The fourth design was a small bore system.
- ALLEGATION NO.10 l
Shock absorbing electrical usually found unsatisfactory are stiLL unsafe e
l due to faulty welds and electrical cable trays remain dangerously full.
l FINDINGS
(
i BW.
heee+er-(w/ed #f*A J .rc- e Jhis allegation is unresolved.
BASIS FOR FINDINGS (1) Faulty Welds
.j The RIII inspector inspected both vendor and filled welds on tray hangers in three different locations in the plant. The locations were the blue switchgear room, the cable spreading room, and an unidentified re area.
The inspector included more than 25 hangers with four to ten welds per hanger. Since the welds were already painted, the inspection was incon-clusive. Only one weld by a cross member of a hanger in the cable spreading room appeared unacceptable. The RIII inspector discussed the defective vendor welds reported to the NRC pursuant to 10 CFR 50.55(e). Discussions revealed that these vendor welds and numerous other field welds had been accepted based on visual examination of painted welds. This is contrary to the AWS Code. Based on these noncredible inspections performed by the Licensee, the RIII inspectors could not determine if there were additional unacceptable welds.
(2) pangerously Full Cable Trays (Cable Tray Loading) l l
Ca) The designer (S&L) has deviated from the FSAR.
(b) Measures were not established to verify the tray loading design
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. for the dead weight and cable loading of our cable sleeve.
(c) At least 30 identifieu and controlled trays exceed the FSAR Limit of 50% fitt.
(d) Calculations have not been performed to verify whether or not trays have been overloaded. (Both thermally and dead weight).
(e) Cable selection must be reevaluated because of increased cable depths.
There are two noncompliances and four unresolved items identified regarding cable tray loading.
- ALLEGATION NO. 11, Sand and mud choke the feedwater pump and intake flues carrying make-ups for water to the cooling tower, because of a flaw in the plant design. Pumps used to rectify the flaw quickly burn out.
FINDINGS I
This atlegation was substantiated, but there were no uncontrolled nuclear safety concerns.
BASIS FOR FTNhTNrA
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.This allegation was substantiated, but there were no uncontrolled nuclear safety concerns.
BASIS FOR FINDINGS This item was previously reported to the NRC pursuant to 10 CFR 50.55(e).
The report is still open and the item is stiLL unresolved. "T;,
7
./
- ALLEGATION No. 12 The design flaw in the heat exchanger control panel permitted an operator to mistakenly force 1200 pounds of pressure through pipes only meant to handle 300 pounds, ripping the pipe and soaking electricians with a hard spray of water that would have been radioactive had the plant been in operation.
FINDINGS This allegation was substantiated, but there were no uncontrolled nuclear safety concerns.
BASIS FOR FINDINGS The RIII inspector reviewed the sequence of events before and held a discussion with the operations quality engineer concerning the alleged deterrent. The review and discussion substantiated deterrent, but indicates a different cause.
,The cause appeared to be a breakdown in communication. Two valves connecting
hWf" &
Ve>&l the low pressure core spray system to the high pressure core spray system, were incorrectly lef t open during the start of the flushing activities of the HPCS. The pre-flushing checklist was signed incorrectly, verifying valve line-up. On the subsequent day the HPCS pump was started with 1200 psig pressure in the discharge piping. After approximately three minutes, a water hammer occurred which cracked the water box on the steam jet air ejector and allowed water to spry att over the immediate area. The incident was reported to the NRC pursuant to 10 CFR 50.55(e).
The folLowing corrective actions were taken:
(1) A swing check valve was added downstream, to minimize the effect of the two isolation valves, connecting the LPCS to the HPCS, being inadvertently left open.
(2) The valve line-up verification now requires two signatures instead of one.
(3) A stress analysis and pipe minimum wall thickness measurement (ultrasonic test) were made which indicate that there was no damage to the valve and piping hangers in the HPCS, LPCS, and CD (non-safety related) systems.
- ALLEGATION NO. 13 There have been periods where there were no security suveillance cameras during nuclear fuel deliveries to the site and perimeter security consisted l
for an extended period of only a four foot chicken wire fence.
D 0 W" fN m Y f 3-#r-17 IINDINGS BASIS FOR FINDINGS Part 1 - Security Surveillance Cameras The RIII inspector serviced to an interview with the site plant protection analyst, representing the Physical Security Licensing Branch of NMSS and a review of the following documents that the licensee does not require to provide CCPV surveillance during either delivery or storage of unirradiated fuel at the Zimmer site.
(a) NRC Materials License SNM-1823, dated June 26, 1978.
(b) 10 CFR 73.67(f)
(c) Station administrative directives, interim access control - new fuel storage area, Procedure No. SE SAD.03, Revision 1, dated August 10 1979.
(d) Appendix F - Interim access controls - new fuel storage area, Revisio's 1U, dated July 3,1980. Appendix F became effective November 14, 1980.
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. July 3,1980. Appendix F became effective November 14, 1980.
The RIII inspector also determined f rom reviewing two Region III security inspection reports that the Licensee is not utilizing CCTV to provide surveit-Lance to the new fuel storage area; but is utilizing watchmen and barriers l to detect unauthorized penetration.
Part 2 - Perimeter Security FINDINGS This allegation was not substantiated.
BASIS FOR FINDINGS The RIII Resident Inspector at Zimmer determined that f rom approximately December 3, 1979, to the present, the Licensee has utilized an eight foot plywood barrier on the floor elevation containing the new fuel storage area.
This utilization was also verified during two separate security inspections.
(September 25, 1979 and January 22-23, 1981) by RIII personnel.
An interview with the plant protection analyst representing the Physical Security Licensing Branch of NMSS stated that the utilization of a four foot chicken wire fence to control access to the new fuel temporary storage area would not conflict with the requirements stated in 10 CFR 73.67(f) and Part 2, Section 1.1 of Regulatory Guide 5.55, dated January 1980, if moni-toring of the area was also conducted.
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The monitoring is conducted by a watchman who is continuously stationed at the access point to the new fuel storage area.
- ALLEGATION NO. 13 There have been periods when there were no security surveillance cameras during nuclear fuel deliveries to the site, and perimeter security consisted for an extended period of only a four foot chicken wire fence.
FINDINGS This allegation is substantiated; however, it is not contrary to any regulatory requi rement.
BASIS FOR FINDINGS Interviews of Licensee security representatives indicated that there were no surveillance cameras during nuclear fuel deliveries to the site and that for a short period of time the building where the fuel was stored had a four foot fence around it. The licensee advised they are committed only to posting a watchman to guard the fuel twenty-four hours a day. RIII Safeguards Section, DETI, advise this program has been implemented and is acceptable. Therefore, the concerns expressed by GAP may have occurred but are not contrary to any regulatory requirement.
- ALLEGATION NO. 14
W @$ h 3 n.i A tax attitude toward employee behavior was evidenced by complete disregard of drinking and drug use on the site, and routine hiring of temporary Labors prone to violence.
FINDINGS This atlegation is unsubstantiated.
BASIS FOR FINDINGS Forty-five Quality Control Inspectors, seven former security of ficers, and ten craft personnel were interviewed regarding the use of alcolhol and drugs on the site. In almost every instance these personnel commented that they had observed evidence of drinking (discarded beer cans and liquor bottles) on the site and had seen evidence of some marijuana use (discovery of mari-juana cigarette butts). However, in each instance the QC Inspectors and craft personnel contacted said they did not observe individuals intoxicated on the job, or instances where drug or alcohol intoxicated personnel were ,
woriing on a specific system in the plant. The security officers questioned on this issue said they reported the apparent presence of alcohol and drug abuse to CG&E security management. The security of ficers stated however, they did not characterize the problem as a major security problem onsite and none substantiated that the Licensee had a " Lax attitude" regarding drug or alcohol abuse onsite. In regards to the GAP comment regarding the routine hiring of temporary employees prone to violence, the security officers interviewed reported no patter of significant acts of violence (fights, shootins, stabbings, etc.) among employees onsite.
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- ALLEGATION NO. 15 Employees fired for time cheating had been cheating with express approval of management. The only time-cheaters fired were vocal and knowledgeable critics of plant GA and safety.
FINDINGS This allegation is unsubstantiated.
BASIS FOR FINDINGS On March 12, 1981, William Murray, Employee Relations, CG&E was interviewed and stated in December 1975 Mr. Thomas Applegate was hired by CGSE as an under-cover security of ficer, ostensibly to uncover instances of employee time card cheating at the plant. Murray stated Mr. Applegate's investigation conducted between December 10, 1979, and January 3,1980, resulted in the dismissal of three Kaiser employees for time card cheating. Murray stated one of these em-
, ployees was later reinstated.. One of these employees was interviewed and l
stated that he was fired from the site for time card cheating and not for i
any comments he made about safety problems at the plant. We intend to inter-view the remaining two employees during the upcoming week.
l
- ALLEGATION NO. 16 l
l CG&E had warned Peabody Magnaflux management to silence the radiographers pt Zimmer who were criticizing CG&E's consistent approval of welds rejected ,
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,by Peabody Magnaflux. In addition, on February 26, 1981, GAP representativet in furtherance of this comment stated four local police officials in the Cin-cinnati area had information regarding a burglary of the Peabody Magnaflux trailer onsite and the thef t of records criticizing CGSE's consistent approval of welds rejected by Peabody Magnaflux were stolen during this alleged breakin.
The NRC insp; ier s . ; .i c ;d 250 r ediew. ph . .wm ehme , fm. '7 .mLJe. :~ , ,,
of the re; der th:::: 2 ndi;;;;d ;;;;stan;; b, XCI of;;r r;;;;;ica b, ^; L .,
Magneftww.
FINDINGS This allegation is currently under investigation. However, the statement about the burglary of the Peabody Magnaflux trailer onsite and the theft of records is unsubstantiated.
BASIS FOR FINDINGS i
l l
Five out of nine Peabody Magnaflux employees have been interviewed regarding l this allegation. They have denied any intimidation by Peabody Magnaflux regarding their weld determinations at Zimmer. Three of the five employees interviewed are radiographers who der.ied CGSE was consistently overriding their decision on the acceptability of welds. NRC inspectors have reviewed Reports of Radiographic Examination and have not identified any pattern of CGSE over-riding Peabody Magnaflux's findings; in fact the contrary is true. Frequently l Peabody Magnaflux approved welds which CG&E later said were not acceptable.
l The NRC inspectors reviewed 250 radiograph reader sheets for 49 welds. None of the reader sheets indicated acceptance by KEI after rejection by Peabody
( - f'A J e-p Magnaflux.
It should be noted that GAP has taped conversations with two Peabody Magna-flux employees regarding this allegation. We plan to review these tapes and interview these individuals to resolve any discrepancies or inconsistencies in any statements they have made to GAP of the NRC.
Regarding the alleged breaking and entering of the Peabody Magnaflux trailer and the thef t of records f rom this trailer, six local police officers, including four named by GAP representatives as having information regarding this breakin were contacted end denied having any knowledge of a breaking or entering or the theft of records from the Peabody Magnaflux trailer at the Zimmer site in January 1980. ,
_* ALLEGATION NO.17 l
Union pipefitters and Peabody Magnaflux employees have been intimidated by fear of utility and industry-wide reprisals should they complain about the QA practice.
JINDINGS Thiw atlegation is unsubstantiated.
BASIS FOR FINDINGS.
The Peabody Magnaflux employees and the union pipefitters who GAP states were b3
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. intimidated by fear of utility and industry wide reprisats were interviewed and stated they had not been intimidated for any cirticisms of QA practices at the Zimmer site. In the case of the fired union pipefitter he state that he was fired for time card cheating and not for complaining of Quality Assurance problems at the site. The Peabody Magnaflux employees inte; viewed stated they were asked to leave the site due to production problems and readily admitted that the quantity and quality of work generated just before their dismissal was of poor quality. They attributed this to oroblems with their film processing and film developing machine onsite which frequently malfunctioned, necessitating reshootings of many radiographs which affected p roduct ion. They also stated the antiquated machine affected the quality of their final product, and radiographs were unacceptable due to poor. film quality when submitted to other Level III reviewers for examination.
- ALLEGATION NO.18 A Kaiser employee has kept a detailed journal of safety hazards and incidents at Zimmer.
FINDINGS This allegation is unsubstantiated.
BASIS FOR FINDINGS On March 5, 1981, Yohan Reiter, former Radiation Chemistry Technician, was e,ontacted via telephone in Ankara, Brazil. Reiter stated he recalled having
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$dB e conversation with Thomas Applegate in December 1979 in which Reiter refer-red to his field notebook as his " paper brain". Reiter denied stating to Applegate that the notebook was a detailed journal of safety problems as characterized by the Government Accountability Project affidavit presented to the Special Counsel Merit Systems Protection Board. Reiter stated the notebook contained his field inspection notes, which insured deficiencies he identified during his preoperational inspecitons of the radwaste system, a non safety related system in the plant were repaired. Reiter stated in each instance the problems he identified were corrected by Kaiser. Reiter added he had no concerns with the safe operation of the plant and added he would have reported these concerns to the NAL if had then.
/
- ALLEGATION NO.19 A common " joke" among pipefitters at Zimmer is that they wilL be hundreds of miles away when the plant goes on Line, due to their predictions of a disastrous accident.
FINDINGS This atlegation has not substantiated.
( BASIS FOR FINDINGS l
l l
l The RIII inspectors interviewed approximately 16 pipefitters. None of them l
l had knowledge of any specific hardware problems.
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It),M P lhdelsendenr.e end sep.u olion le twee;n Kaiset forcott uctico Ond Kaiser Otyf4C RF% POW 4 kaiser fraineers Inc. (R.in Co.) ht.s restructured its Lorpra.\ter Organir.ntion 85. of 4/1/81, (Sec a.tleched chart). A Significant change is that the M-2 nager of Corporate Quality Assurance now reports directly t.o the Presir.fent.. this charge reinfoicitr. the lh:lepchdr;rnt,c and separati0h Of Qh/QC f rtF CODStructiott.
lne site Qf./QC organ hatfon is i.eirrl: vestructured it, ao:nrdan u with the atteclcdi chart to strengthen the canaarycnt and suru.tr.
vision of QA/QC activities. A Manage.r of doctrhenration pasir. inn haf. herrn acided to manage all quality related dorter5 fat?.. He will bc supported by 3 Docisunt Erv/ inters in (hv d(clpline arws, each of these. en;iineers will bo <.or,;varted by a staff of engineert, technicians cod cierts as required to.revic4 adequacy and .xcor icy of past documents and assembic required docirna.~.ts to confirn that the actual tristallatfors of equitvnint and ruatorialt. s.or form to the engineert. dr,wrioc,15 and spercif tCatiorv. and K?C regnier.onts.
The bcutent Engineers will also be reqponsibic for rev(ew and adequacy of documents covering.cnyotrre r construction act.ivitiet prito to entry into the central dW;ument ceriter.
- lhe l%/ QC Site Manager will be sutritat ted by an our. side canaqmr-mt l
cotisultant specialized in OA/DC.
l QA/QC teroc e< fores are preently being revi(.*d to ensuse tisar. Q;/th, require +ats ate cicarly indicer.ed. All (FCP) Field <lonste5.iction Procedisres presently included in (OAGti) Obality Assurance-Construction W.ethods Inst.ruct ion ar e feeing rmcwd aruf strecific. QA/QC requirments are bein9 50hstituted for these F(Ps.
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