ML20065M748

Suppl to Miami Valley Power Project 820820 Petition to Suspend Facility Const,Including Addl Bases for Immediate Suspension of Const & Requested Remedy.Certificate of Svc Encl

ML20065M748
Person / Time
Site:	Zimmer
Issue date:	10/18/1982
From:	Devine T GOVERNMENT ACCOUNTABILITY PROJECT, MIAMI VALLEY POWER PROJECT
To:	NRC COMMISSION (OCM)
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ML20065M737	List: ML20065M736 ML20065M748
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NUDOCS 8210210400
Download: ML20065M748 (30)

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. UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION

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In the Matter of: )

)

CINCINNATI GAS AND ELECTRIC )

COMPANY, _et al.

_ ) Docket No. 50-358 (William H. Zimmer Nuclear )

Power Station) )

)

SUPPLEMENT TO MVPP AUGUST 20 PETITION TO SUSPEND CONSTRUCTION OF THE ZIMMER STATION I. INTRODUCTION

1. Or. August 20, 1982 the Miami Valley Power Project ("MVPP")

petitioned the Nuclear Regulatory Commission (94RC" or " Commission")

to Suspend Construction of the Zimmer Station (" August 20 Petition").

MVPP also requested that the Commission remove Cincinnati Gas and Electric ("CG&E") from responsibility for reinspection of construc-tion work where the quality is indeterminate; and a management audit of both CG&E and its contractor, the Henry J. Kaiser Company

( " HJK" or " Kaiser"). In support of its petition, MVPP -presented 205 attachments, consisting of affidavits, documents and news articles. The issues in the August 20 Petition were identical to eight contentions originally proposed by MVPP on May 18, 1982 as the basis for reopened licensing hearings on t'he = Zimmer quality egjo21040082101e 'e -

.o ADOCK 05000358 PDR L. .__ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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assurance br'eakdown. On July 15, 1982 the Atomic Safety and Licensing Board ("ASLB") ordered renewed hearings on the eighh proposed contentions. On July 30, 1982 the Commission reversed the ASLB. On August 20 MVPP petitioned the Commission to recon-sider its July 30 order.

2. On September 24, 1982 the Commission ordered CG&E to respond by December 31, 1982 to each allegation in the August 20 Petition. The Commission required this action through a formal Demand for Information issued by the Office of Inspection and Enforcement. (Attachment 1.) The responses must admit or deny each allegation, and explain the basis of each denial. The responses must also identify how the Quality Confirmation Program

("QCP"), established to determine the effect of previous quality assurance ("QA") deficiencies, addresses the potential consequences of each allegation. The responses are to be submitted by Decem-ber 31, 1982.

3. Since August 20 there have been a' series of significant developments concerning the issues raised in the petition. MVPP, through counsel the Government Accountability Project (" GAP") of the Institute for Policy Studies, has continued to receive-alle-f gations and evidence from current and former employees at the i

i Zimmer station. In addition, on August 27, 1982 CG&E responded to a July 9, 1982 letter from MVPP to Chairman Palladino. The.

July 9' letter described the comparative abilities of Nonconformance Reports ("NRs") and In-Process Inspection Deficiency Reports

("IIDRs") to verify quality and corrective action

• when QA viola-

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tions are identified. In the July 9 letter, MVPP also requested 1

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an investiga' tion into possible material false statements by two CG&E representatives at a June 16, 1982 briefing of the commission.

On September 14, 1982 the House Interior and Insular Affairs Sub-committee on Energy and the Environment held hearings to consider, inter alia, whether the Quality Confirmation Program should be re-placed with a third-party effort. Throughout September the Envir-onmental Advisory Council ("EAC") to the Cincinnati City Council l

held hearings on quality assurance at Zimmer and other issues of public concern.

4. MVPP believes that the issues raised by these developments should be placed on the public record.to supplement the August 20 Petition. At a minimum, the September 24 Demand for Information should be updated so that CG&E's eventual response will be current.

The additional evidence obtained by MVPP demonstrates that QA violations have intensified this summer. If that pattern continues during the rest of 1982, CG&E's December 31 response may be dated and fail to address ongoing significant developments. As long as there are no licensing hearings on the eight quality assurance contentions covered in the August 20 Petition, MVPP will continue to supplement the record as significant, credible new allegations and evidence are received.

5. The new evidence and public statements also demonstrate the need for immediate action on the remedies requested in the August 20 Petition. By granting CG&E at least until-December 31, i

1982 to respond, the Commission is postponing its own decisions on suspension of work and CG&E's competence until* early 1983, possibly six months or longer af ter MVPP submitted the evidence. '

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The evidence obtained since the August 20 Petition indicates that e

CG&E or its contractors may take advantage of this six-month

" grace period" to cover up information relevant to the Auqust 20 allegations, through destruction and/or falsification of relevant records, as well as through undocumented repairs.

II. ADDITIONAL BASES FOR IMMEDIATE SUSPENSION OF CONSTRUCTION

6. Since submitting the August 20 Petition, MVPP has received four affidavits or signed statements from three current and former Zimmer employees, as well as additional documentary evidence. All evidence was obtained under conditions of confidentiality, except for information generally available at Zimmer which could not be traced back to a witness. MVPP has disclosed the witness state-ments and other documentary evidence covered by the confidentiality pledge to representatives of the Commission's Office of Investi-gations and the Department of Justice ("MVPP disclosure"). The following additional grounds for relief are drawn from the evidence already submitted to law enforcement and NRC staff representatives, as well as from additional evidence which MVPP is at liberty to submit for the public record. These further bases to suspend construction are organized according to the relevant quality assurance contentions in the August 20 Petition.

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A. Failure to Maintain Adequate Material Traceability to identify and Document

• the liistory ot All Material, Parts, Components and Special Processes

7. The response to missing material traceability records has been to accept inadequate substitutes. The MVPP disclosure reports a policy on-site that the item number on the bill of materials can be used to establish traceability. But since each item number on a bill of materials can refer to thousands of items in the plant, traceability has not been established.

B. Failure to Maintain an Adequate Quality

, Assurance Program to Identif y and Correc t Construction Jeticiencies

8. ' A fundamental requirement of 10 C.F.R. 50, Appendix B, Criterion I is that "[t]he persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions." Further, one of the basic causes for the QA breakdown at Zimmer has been the lack of independence and authority for quality assurance personnel to carry out their duties. This policy of nonindependence for QA personnel not only persists, it has intensified. An August 18, 1982 Kaiser memorandum from R. A. Davis to all quality control ("QC") inspectors (Attachment 2) declared,

{'ECIFIC DIRECTION TO QC INSPECTION Direction received from the Owner (CG&E) , the Engineer (S&L) or HJK (Site Management Committee, Quality Engineering) will be followed to the '

letter. This direction is given from a level e

which provides evaluation for all conditions on this project. This direction is not the QC

• Department's responsibility to question.

(1)' Responses to RFI/E's, DDC's issued by S&L, and specific direction from CG&E or Site Management Committee will be followed by all QC Inspection personnel.

(2) In the case of a disagreement of the dis-position on an NR, ZAPO-5 identifies how this will be handled. In no case, how-ever, will work be stopped because of the ,

disagreement. .

[ Emphasis in original.] Unthinking obedience, rather than legally-mandated authority and independence, is the policy outlined in the August 18 memorandum for inspectors at Zimmer. This policy violates 10 C.P.,R. 50, Appendix B, Criterion I. It also raises questions about the reliability of all favorable QC inspection findings and verification of corrective action.

10. The August 18 memorandum illustrates another illegal trend at Zimmer -- verbal instructions as a substitute for approved, written QA procedures. This practice is in violation of 10 C.F.R. 50, Appendix B, Criterion II, which states', "This [ quality assu-rance] program shall be documented by written policies, procedures-or instructions which shall be carried out throughout the plant life in accordance with those policies, procedures or instructions."

11. Another basic requirement of 10 C.F.R. 50, Appendix B, -

Criterion I is that any QA employee must have access to the highest levels of management to report violations. At Zimmer, however, inspection supervisory personnel can effectively screen out QC inspection reports. An August 20, 1982 memorandum (Attach-ment 3) imposed an immediate requirement that the inspection .

supervisor m'ust initial all significant reports that leave the i

department for processing.

12. Quality control inspections for all safety-related work are required under 10 C.F.R. 50, Appendix B, Criterion X. UnforI tunately, the practice ot nonexistent mandatory inspections con-tinued this summer at Zimmer. MVPP has submitted evidence of QC l

inspection and/or surveillance work that was halted after internal disclosure of significant QA violations. In other cases, internal construction notes reveal that QC inspectors failed to conduct assigned inspections on rework in the Quality Confirmation Program due to time pressures, t

13. Even when inspections did occur, they were not always comprehensive, even for the specific work operation under scrutiny.

To illustrate, in an October 4,1981 statement a QC inspector stated that Quality Confirmation Program reinspections'are being done merely to check whether specific, informal punch list work assign-ments were donc properly, instead of full reinspections.

14. A Zimmer employce's October 4 signed statement disclosed that the reason for incompletu QCP inspections is incomplete or nonexistent construction work records. The phenomenon of missing records has intensified over the last four months. MVPP has-sub-mitted evidence, for Ovample, that one QC inspector was unable to conduct any inspections over a two-week period, due to the . total absence of any assigned work packages in the vault, on the com-puter, or at Document Control. ' 98 0

15. Rather than squarely confront the problem of missing records, management has declared it irrelevant for QC inspectors. '

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For example,' in an October 4 signed statement a witness reported that the lead ,0C inspector--

issued a memorandum saying not to refuse to accept document packages because of missing documentation. Instead, the O.C. inspectors I are supposed to pass along the packages to  !

Document Control. This makes it very diffi-cult to accept the packages.

CG&E has offered two excuse [s] for ac-cepting packages without complete records:

.) Document Control will certify the records and 2) The records are in the vault. But Document Review employees told me that they can't Certify [ sic] the packages when the records are missing. As seen above, they are often not in the vault.

16. The effect of missing records and failure to conduct QC inspections is to circumvent the quality assurance program through undocumented repairs. To illustrate, at September 14, 1982 Con-grossional hearings, Ohio's Chief Boiler Inspector Donald Milan testified that a steam jet air condensor was so badly damaged it had a gash 7/8th inches wide. Construction crews then repaired it without the participation of the audorized nuclear inspector, as required. Mr. Milan said "they can kiss it good-bye too, because it is going out. " Mr. Milan's written testimony is en-closed as Attachment 4. The full extent of work that should be kissed good-bye due to undocumented repairs remains a mystery.

17. MVPP's August 20 Petition documented a practice of uncontrolled, overpressurized hydrostatic tests which can severely weaken or damage piping and components. The undocumented repairs in the steam jet air condensor were the outgrowth of improperly-conducted hydrostatic tests. In his September 14' testimony,

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Mr. Milan explained, "They forgot to close...some isolation valve'

and; overpressurized a vessel, a jet air condensor, and they e

ruptured that vessel. . . . " Mr. Milan's September 14 testimony i

also reported that at least two portions of safety-related piping --

in the Low Pressure Core Spray and the Residual Heat Removal Systems -- were overstressed. In each case the piping received 1

almost twice the maximum allowable pressure. (Attachment 4, at 2-3.)

18. The combination of undocumented construction work, the absence of mandatory inspections,and sloppy tests inevitably leads i

to unreported violations of professional codes. For example, in an October 4 statement a witness reported that there are many instances of code violations such as clamps on Nuclear Steam Supply ~ System line welds.

Welds

19. As documented in the August 20 Petition, the quality breakdown of welding at Zimmer is the best model to illustrate the overall breakdown of the QA program. The trend to circumvent sound QA principles has intensified this summer, as c'idenced v by witness statements and construction work notes concerning the weld recer-4 tification program and weld repairs from the Quality Confirmation Program.

20. Initially, the QC oversight of weld recertification

tests were compromised by inspectors with questionable qualifications.

The MVPP disclosure reports three examples where the QC inspectors in the program had never before participated in welder qualification tests. Their lack of experience may explain why the inspectors 98' permitted the extensive cheating described below in the recerti-fication tests.

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21. The modus operandi for cheating on the welder recerti- I fication tests was to issue verbal instructions that were contrary to approved procedures. As one example, the MVPP disclosure evi-dences special welder recertification tests with built-in handi-caps for those who couldn't pass the normal examinations in certain difficult weld procedures.

22. Another improper verbal policy allowed welders taking their recertification tests to grind the welds repeatedly, accor-ding to an October 4 signed statement. This technique violates the usual test procedure and cosmetically improves the appearance of the weld during visual inspection.

23. As with other areas, deliberate falsification of records may have complemented illegal verbal policies in the welder recer-tification tests. A September 24, 1982 affidavit reports that certain welders this summer who had been welding to the wrong procedure had their recertification cards collected. They then roccived new certification cards for the correct welding procedure, without having taken the recertification t'est.

24. The weld repair pro' gram for certain structural steel deficiencies identified by the Quality Confirmation Program repre-sents a comprehensive quality assurance breakdown. An October 3, 1982 Cleveland Plain Dealer article confirmed that some_8,000 welding deficiencies in the structural steel are being reworked.

(Attachment 5. ) Initially, certain supervisors for the weld repairs did not receive any training for this sensitive QCP assignment, according to affidavits submitted in-the MVPP dis-closure. One witness had to learn how to weld by watching the' .

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men he supervised.

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25. Cd&E has repeatedly contended that the deficient welds are basically sound but suffer from petty cosmetic problems that only require superficial polishing up. As a result, the QC over-sight program has been limited to visual inspections after the rework is completed. Unfortunately that premise is false, ac-cording to affidavits and construction work notes filed in the MVPP disclosure. Major repairs have occurred on welds with a

-complete absence of QC oversight, until inspectors came to visually check what they thought was surface-level grinding. ~ In facc, welds were completely cut out and replaced, or ground down so far that in one case a channel beam sprang loose. Many of the welds were reworked several times in this fashion, according to a September 24 affidavit.

26. The MVPP disclosure reports that not only were these weld repairs conducted without QC oversight, but the construction crews were working to the wrong work package and generating i oc-curate work records. In short, the paperwork does not accurately reflect the weld repairs that occurred.

l 27. Even when quality control inspectors conducted visual inspections, the ensuing QC reports were of questionable relia-bility. For example, construction work notes submitted in the MVPP disclosure evidence repeated frustration by repair crews when QC inspectors turned in reports that failed to specify whether the welds had passed or failed. . .

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28.

• As with welding recertification, evidence of deliberate f

records falsification accompanies QA circumvention of weld repairs.

One of the practices that most facilitates criminal falsification is to change entries on records without initials or explanation.

MVPP has submitted evidence that the weld repair records contain anonymous, unexplained changes.

29. In other cases, there is evidence that the records for accepted work are inaccurate. To illustrate, construction work notes in the MVPP disclosure report that repairs on items were accepted on paper, when the work had not yet occurred. In another case, repair work was processed when the QC inspections had not yet occurred.

30. Even when the substance of records refers to more than fictional activity, some reports are deliberately inaccurate.. For I instance, MVPP has submitted evidence that some weld rod slips were knowingly falsified to reflect different rods than those actually used, due to the ease of covering up use of the wrong rods in the first place.

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31. While the bulk of the new evidence on welding involves QCP repairs and recertification, there are further indications of widescale welding deficiencies that remain undiscovered due to previous spotty QA coverage. To illustrate, in an October 4 signed statement a QC inspector reported serious welding defi-i ciencies in two-thirds of the sacrificial shield wall,'which had i

not been covered in the previous quality control x-ray sample, ge s?

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I C. Failure to Maintain Adequate Controls ,

to Process and Respond to Internal Nonconformance Reports

32. Since MVPP's August 20 Petition, press accounts have confirmed the wide scope of the breakdown in Nonconformance reports ("NRs") -- which are supposed to serve as the primary record to assure that QA violations have been identified and corrected. For instance, an October 3 press account quoted NRC official Dorwin Hunter's estimate that 1,700 NRs have been voided at Zimmer. (Attachment 5, supra.) Further, a September 19, 1982 Dayton Daily News press account (Attachment 6) reported that hundreds of NRs are missing from the system. The August 20 Petition explained how they were lost: the NRs were effectively expunged from the system by voiding them as "Not Issued" and then returning them to the original QC inspector. These hundreds of lost records may represent hundreds of QA violations, in light of the finding in last November's IE Report that 25 out of 26 voided NRs carefully investigated by the NRC were cancelled improperly.

The lost NRs are not even available to review, leaving the potential violations a mystery.

33. After a nonconforming item has been identified, " hold tags" are necessary to assure that construction crews do not continue work until the proper corrective action has been deter-mined. Otherwise, the QC inspector's findings may become moot, or else the work will have to be redone a third time. Respect gg ra for hold tags is a basic requirement of 10 C.F.R. 50, Appendix B, Criterion X. The August 20 Petition disclosed evidence that hold

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tags have been traditionally violated at Zimmer. The tradition has continued this summer. The MVPP disclosure evidenced the continuing trend through construction notes and witness state-ments. For example, a witness reported in a September 24 affi-davit that hold tags were violated for weld repairs in the QCP.

As with other QA violations, the uncontrolled work resulted from verbal orders. The witness stated, "From my own direct experience, this occurred on three occasions. Other employees had the same experience."

34 Respect for hold tags is only meaningful if the NR leads to ef fective corrective action.- Unfortunately, new evidence casts further doubt upon the reliability of QA " solutions" to problems identified on NR's over the years. A witness explained in an October 4 statement: "The old NR's are particularly bad....

[Recently] I was out tagging old N.R.'s. They had dispositions like 'If it looks good to you, accept-it.'"

35. In a June 16, 1982 briefing of the Commission, MVPP i

counsel challenged a trend at Zimmer to substitute In Process

• l Inspection Deficiency Reports ("IIDR") for'NRs. On July 9 counsel submitted further analysis and evidence demonstrating the inferi-i ority of the IIDR substitute (" July 9 letter"). MVPP also re-quested, inter alia, that the Commission's Office of Investiga-tions check whether CG&E Vice President of Nuclear-Operations i B. R. Sylvia made material false statements to the Commissioners i

at the June 16 briefing,concerning_the nature and scope of the IIDR program. On August 27, 1982 CG&E responded (" August 27 ,

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response"). Unfortunately, the analysis in.the CG&E response

cannot withstand careful scrutiny. Counsel will rebut CG&E's e

August 27 pol' icy analysis in a separate response.

36. Evidence in the MVPP disclosure indicates that CG&E's -

position in the August 27 response may be as inaccurate as at the June 16 briefing. The factual dispute between MVPP and CG&E concerns the scope of the IIDR program. CG&E contends that since 873 NRs were written between June 1 and August 1, 1982, IIDRs have not " gutted" or otherwise significantly replaced the NR system. (August 27 response, Attachment A, at 2.) Critically, however, the utility did not report the number of IIDRs issued during the same time frame. As a result, it is impossible from CG&E's' response to compare the relative frequency of IIDRs and NRs under ZAPO-5. CG&E's reticence is understanable. A QC inspector revealed in an August 26, 1982 affidavit--

IIDR's are the most common approach to record deficiencies in the Quality Confirmation Progran and throughout the plant. Under the ZAPO-5 pro-cedure, IIDR's have replaced Nonconformance Re-ports as the main quality record. There are hundreds of IIDR's to every Nonconformance Report. . .

They are used all the time for welds throughout the plant. Anyone who says otherwise either is deliberately misrepresenting the IIDR program or obviously has too little information for an informed opinion.

D. Retaliation Against Quality Assurance and Quality Control Personnel Who Attempt to Diligently Perform Their Responsibilities or Report Violations to the NRC

37. CGr.E insists that retaliation at Zimmer-is'at' ~

most a historical phenomenon. But GAP has continued to receive evidence that it still takes an act of courage for a quality -

l assurance employee to do his or her job. In an August 26, 1982 affidavit, a QC inspector explained the retaliatory consequences of lack of independence for the QA department:

One of the basic causes of the problems there quickly became apparent to me--lack of independence for quality control personnel in violation pf 10 CFR 50, Appendix B, through harassment and intimidation.

If the inspector questions how the work and/or pro-cedures are being performed, he is either neutralized or "Zimmertized." The former refers to being trans-ferred or dismissed. "Zimmertized" refers to an expression on-site that means to put aside professional ethics and go along, in order to avoid going on down the road. Every day at Zimmer, career decisions are made by those who must choose between their professional ethics and their paychecks.

In short, at Zimmer the historical policy--those who expose problems are the problem--is still in effect.

38. The MVPP disclosure evidenced several new examples to

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illustrate how employees are "Zimmertized." In one case, an em-ployee who persisted in his dissent was offered the alternative futures of being promoted or being laid off. The choice would depend on whether he persisted in his diss.ent. The employee per-3 sisted and was laid off. All witnesses have told GAP that mass layoffs have occurred this summer among QA' personnel. Frequently

the employees who lost their jobs either were internal critics or experienced enough to recognize QA violations.

39. Frequently retaliation against QC inspectors is not the result of high-level management decisions. Rather, the origina can be with crews who are resentful of long delays waiting for m QC inspector who finally arrives and writes up a Nonconformance Report rejecting.their work. 'In a more specific context, the MVPP a

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disclosure included construction notes explaining how the precise phenomenon described continues among construction supervisory personnel.

E. Inherent api Empirical Failure of the Quality

) Confirmation Program as the Final Solution to the Zimmer Quality Assurance Breakdown

40. In the August 20 Petition, MVPP charged tum* empirically the NRC reform program initiated through an April 8, 19L1 Immed-iate Action Letter has not worked. The evidence in the MVPP dis-closure further support that conclusion. To put the failure in perspective, 34 of 42 allegations raised in this supplemental petition concern issues that have occurred since April 8, 1981; all 34 took place since May 1982.

41.- The primary structural flaw in the QCP is conflict-of-interest. As Congressman Udall stated while he chaired the Septem-ber 14 congressional hearings, it is unrealistic for Congress or the public to have confidence "that the company that neglected quality assurance for so many years will,'on its own, fully uncover deficiencies resulting from its own neglect." ,

Despite this increasing loss of legitimacy, the NRC staff has responded to evidence of misconduct by increasing CG&E's responsibility to investigate the issues concerning~its own conflicts-of-interest.

The vehicle to intensify CG&E control through self-investigation has been the Quality Confirmation Program, which in the absence of licensing hearings is the final solution to the Zimmer QA breakdown. To illustrate the trend, at September 16, 1982 hearings of Cincinnati's Environmental Advisory Council,NRC Region

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III Administrator Keppler stated that CG&E would review the o

suspect qualifications of the 2400 previous welders at Zimmer,

through the QCP. GAP had already shared evidence with Region III that CG&E agreed to present false information to the NRC about the qualifications of past and current welders, because the only other alternative would be "to lock the gates."

42. At the same September 16 hearings Mr. Keppler stated that CG&E would investigate Kaiser official Sherrill Nolder's charges of vendor QA abuses,through the QCP. More specifically, Mr.

Keppler stated that CG&E would prepare a list of material pur-chased from approved vendors. The point of the Nolder Report was that CG&E was directly responsible for the deterioration of the Approved vendors List ( " AVL") through policies of questionable legality that were implemented over Kaiser's protests. Similarly, in June 10 congressional testimony former QA analyst David Jones testified that last year CG&E refused to cooperate with a Kaiser audit that was about to reject the utility from Kaiser's own ,

AVL. One of the key flaws identified by Kaiser auditors had been CG&E's inability to provide a comprehensive, reliable AVL.

The NRC staff policy instit tionalizes u conflict-of-interest at Zimmer.

43. There is also serious questions about organizational

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responsibility for the QCP. The premise of the reform theory was that CG&E needed to assume its responsibilities and take over from its errant contractor to verify the quality of past Kaiser work. As CG&E admitted in its August 26 letter to Chairman Palladino, however, Kaiser reviews all the NR's dealing with

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the American Society of Mechanical Engineers ( " ASME ") code.

Kaiser must assume this responsibility because it is the ASME Certificate Holder. The August 26 letter does not specify, but presumably Kaiser must be able to enforce its review findings if they conflict with CG&E's. Otherwise, the ASME Certificate

! would be meaningless. In effect, the QCP may not have even succeeded in removing CG&E's scapegoat Kaiser from legal control of the quality verification reforms.

44. At the September 16 EAC hearings Commissioner Asselstine explained that to have an effective QA program there must be a strong management commitment to quality, as well as a struc-turally sound verification program. Recent public statements by CG&E Vice President Earl Borgman indicate that the utility's primary goal for the QCP is to complete it in a hurry, rather than to fully address the backlog of serious quality violations.

At September 14 congressional hearings, Mr. Borgman testified that the QCP is 63% complete and should be, finished by next spring. At the same hearing Mr. Keppler respondel to the estimate:

"I don't know how you can make a projection' on a rework job until you know what the problems are." At the September 16 EAC hearings Mr. Keppler expanded his rebuttal, dismissing the CG&E projection as " wild speculation." He explained that he couldn't estimate when the QCP will be completed, because "I don't prejudge what the program will show." He added that it would only be possible to. state a time frame for completing the QCP "(i]f you presume the program won't find a / thing wrong" ,

and that no rework will be necesary. CG&E 's haanagement commitment is exactly the opposite of what's needed to complete Zimmer safely.

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45. Tiere has also been a negative commitment by some e

managers in the field to effective quality solutions through the QCP, when the solutions could slow production or require work to be done over. All of the affiants in the MVPP disclosure first attempted to work through supervisory personnel on-site to restore sound quality policies. In each case, they were cut off with warnings or given vague reassurances that management was already aware of the problem and had taken care of it.

46. There are strong reasons not even to trust the commit-ments CG&E does make to improve Zimmer's quality. To illustrate, at a September 8 plant tour CG&E Vice President Borgman stated that a' basic lesson the utility had learned was the necessity of thorough training. He pledged that if CG&E could do it over, there would be a " pretty massive retraining program."

In fact, CG&E has to do it over through repair work arising from the Quality Confirmation Program. Yet, MVPP has submitted affidavits from supervisory personnel for QCP weld repairs who were not trained and had not worked previously as welders at a nuclear plant. (Supra, at 10-11.)

47. CG&E's on-balance assessment of QCP results is as suspect as its predictions for completing the program. In congressional testimony, public statements and editions of its "O-K News',' CG&E continues to insist that the QCP has not uncovered any significant quality violations but rather has confirmed the basic quality of workmanship at Zimmer. At the September 16 EAC hearings Mr. Keppler rejected this assessment.

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much of the plant is already in the ground the quality of the work must now be considered indeterminate.

48. CG&E's self-exoneration on specific issues has been as suspect'as its overall judgment of QCP results. Since MVPP's August 20 Petition, more objective authorities continue to reject CG&E's QCP conclusions. To illustrate, in his September 14, 1982 congressional testimony Mr. Milan disclosed that QC inspectors at Zimmer had already identified and written Nonconformance Reports on the overpressurized hydrostatic tests.

(Supra, at 8-9.) But CG&E's Architec't/ Engineer Sargent and Lundy had dispositioned the NR " accept-as-is." Mr. Milan and

, v the National Board of Boiler and Pressure Vessel Inpectors Audit Team rejected S&L's action, because the test pressures were nearly twice the maximum permitted by the ASME code.

(Attachment 4,at 2-3). CG&E's QCP status reports, by contrast, consistently have found "no problems" with S&L's design and engineering judgments. It is unclear how many erroneous S&L design and engineering judgments compromise the safety of Zimmer.

But it is clear that the Quality Confirmation Program will not provide the answer.

49. The NRC findings on the adequacy of audits at Zimmer also contradict CG&E's conclusions. A September 1, 1982 NRC staff report concluded: " Coverage of (all previous Zimmer]

ts G audits was not sufficient to verify implementation of program requirements." (September 1,1982 memorandum from William J.- .

Dircks to Chairman Palladino, at 16.) By contrast, CG&E's e

June 30, 1982- QCP status report found that all necessary pro-edures and criteria had been covered collectively, if not individually, by previous audits. (Ijl. , Attachment II.)

50. These suspect individual conclusions raise questions about CG&E's disposition of NR's already written in the QCP.

To illustrate, CG&E has only found that 38'out of 300 voided NR's should be reopened after a second look. (Id., at 13.)

l CG&E graded itself much more leniently than did the NRC, which last November rejected the decisions to void NR's in 25 out of 26 cases studied. Similarly, out of 257 NR's on cable tray separation, CG&E has dispositioned 158 " accept-as-is" and the other 99 " rework," the most superficial possible options. (Id.)

In short, CG&E is.cnforcing in the field its policy not to accept reality and repair defective workmanship. Under these conditions, the QCP is merely going to repeat history by pro-ducing more unreliable paperwork.

51. Even if the QCP results were accurate as far as they went, the program may have missed the lion's share of deficiencies for areas covered. A September 24 affidavit from a former l

supervisor for QCP weld repairs stated that "only 30-40% of the defects were identified by the original QCP inspectors."

The basis for his conclusion was that welds accepted by QCP 3

inspectors "were much worse than the ones we were told to rework."

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52. On balance, the Quality Confirmation Program continues to fail as a viable solution to the extraordinary problem that Zimmer represents. As Congressman Udall stated at the September 14 congressional hearings, public confidence cannot be restored

" simply because the company itself says we made an investigation and everything is lovely."

F. CG&E Failure to Achieve the Necessary Character and Competence to operate a Nuclear Power Plant

53. CG&E's sinking public credibility is not only relevant for licensing hearir.gs. It should also be applied to disqualify I

the utility from further responsiblity for the QCP. To illustrate, Mr. Borgman has publicly explained that no one ever warned the top utility management of the consequences of its OA policies.

At the September 16 EAC hearings, Mr. Keppler finally put that

rationalization to bed when he testified there was no question 4

of CG&E misunderstanding its responsibilities. The NRC met with CG&E officials in 1973 and 1974 to fully explain the utility

obligations.

54. Intentiona'l false statements are' relevant to a utility's

" character and competence." (August 20 Petition, at 113.) This submission has summarized six additional examples of possible intentional falsification to add to the 30 cases disclosed in

! the August 20 Petition. (Id. , at 117.)

55. At the September 14 congressional hearings, Congressman Udall disclosed another six examples suggesting intentional falsification. In each case, the records showed that different

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weld procedures achieved the exact same results on stress tests, although the variances in position and the nature of the weld procedures made that outcome virtually impossible. Congressman Udall rejected Group Vice President Donald Iselin's explanation that the inaccuracies were the innocent result of machine error.

56. Finally, evidence submitted to the NRC further supports MVPP's charge tnat Mr. Sylvia made false statements to the NRC at the June 16 briefing. At the June 16 briefing Mr. Sylvia asserted that IIDR's are only used for problems that do not require an. engineering solution. In reality,nccording to an August 26, 1982 affidavit, IIDR's are used routinely for de-ficiencies that require engineering solutions." In sum, the Quality Confirmation Program is only as valuable as CG&E's word.

But CG&E has repeatedly devalued its opinions due to deficiencies in character and competence.

III. REQUESTED REMEDY _

57. Although the NRC staff has upgraded its regulatory program, the response has been too little and too late. To illustrate, on September 14 and 16 Mr. Keppler announced that the NRC would require an independent audit at Zimmer, but not until CG&E had a better opportunity to define the issues through the QCP. This again reinforces conflict-of-interest, since the NRC program will give CG&E the chance to define the scope of the " independent" review. The third party should' establish the scope and effects of the QA breakdown, not CG&E. Further,

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the NRC program is not an extraordinary remedy. Rather, it is merely glorified language to describe what is little more thin routine NRC policy. At the September 16 hearing Commissioner Asselstine reported that the Commission is now requiring third party audits at most plants near the completion of construction.

5 8. - One of NRC's primary justifications for waiting to bring in a third party is to give CG&E more experience. The NRC needs to gain confidence in CG&E's work, according to Mr.

Keppler. This policy is totally inappropriate. CG&E has had a decade to gain experience. The NRC's primary goal now should be to assure completion of a plant that will not threaten public. health and safety, rather than to provide CG&E with on-the-job training.

5 9 .' The scope of the NRC reform is also inherently flawed. -

An after-the-fact audit is ne substitute for a comprehensive reinspection program. NRC officials repeatedly have emphasized

the limitions of their own enforcement program, precisely because it is basically an audit effort. An audit can only catch a small percentage of total defects if the day-to-day decisions were based on the wrong premises, such as cost-cutting and speeded-up production instead of quality. The solution to Zimmer's QA breakdown is to replace CG&E-and Kaiser with an independent organization that has nothing to lose by identifying and correcting all illegalities through a comprehensive rein-spection.

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60. At its best, the NRC audit plan is comparatively e

inefficient and could further delay opening the plant. If 1 MVPP's charges are only partially accurate and outside auditors discover significant inaccuracies in QCP findings, the NRC program will force CG&E to go back and do the job over a third' time. The pattern could continue indefinitely. In terms of cost and delay, the NRC should impose a reform policy that assures the necessary repairs will be properly completed the j second time through a QCP removed from CG&E's control.-Twice i

is enough.

61. Before any auditors come in', it is necessary to suspend

, constrtiction. Mr. Keppler has publicly explained that he chose to let construction continue last April because stopping work would not have accomplished anything beyond punishing the utility.

The flaws that underlined last April's decision still apply.

First, final solution is premature until the full extent of damage is determined. For example, the NRC conceded at the

Udall hearings that last year's backlog of 100 pending allegations has now mushroomed to 300. They are arriving " faster than we can put them to bed," according to Mr. Keppler's public i

~

explanations. These pending issues may significantly-effect the scope and decisions in the QCP. In short, the problem should be fully identified before choosing a solution. It still isn't.

62. The NRC also should have suspended construction last 1

year in order to break the " business as usual" routine at Zimmer--

an undertrained, intimidated QA staff barely tolerated by con- .

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struction management. The net effect of the NRC's April 1981 reform was to. formalize CG&E control of the QA program and increase the number of inspectors. Now there are simply more QA employees frustrated at their inability to do their jobs.

The same philosophy persists as before the April 8, 1981 Immediate Action Letter.

63. Finally, it is difficult to understand why the NRC staff is trying so hard to avoid " punitive" measures at Zimmer. CG&E should be liable for its misconduct the same as private citizens. Stopping work at Zimmer until all the QA violations are identified would contribute more than a com-prehensive asssessment. This strong sanction could serve as a deterrent for other utilities not to violate the Atomic Energy Act, and'for CG&E to stop violating it. Instead, the NRC staff continues to sacrifice accountability by refusing to suspend construction.

64. The contrast between CG&E's and the NRC's respective positions create a dilemma. If Mr. Borgman is correct and the QCP indeed is 63% complete, there is no~need to further delay a third party audit. CG&E has defined the topics for an audit to its own satisfaction. If CG&E is wrong, then after 1.5 years the QCP is still too undeveloped to even frame the-issues, the utility has demonstrated its inability to continue running the program. *

• At a minimum the NRC should require a more prompt response to MVPP's August'20 Petition than the current December 3; tentative deadline. That time frame gives the utility almost as long to an-swer the charges as it took GAP to investigate them. The evidence in the August 20 Petition required an emergency response, not a drawn-out debate. -

. o IV. CONCLUSION o

65. At the September 16 EAC hearing Mr. Keppler stated that there is a serious question whether CD&E can complete the Zimmer job properly. To maintain public credibility, the NRC must answer that question before relying on CG&E any further to provide the answers to the alarming questions about Zimmer's safety. For all of the above reasons, MVPP requests that the Commission immediately order the remedies requested in the August 20 Petition.

Respectfully submitted, j e W Q r

, ThomasDevin(e Legal Director g October 18, 1982 i /

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b eNo CERTIFICATE OF SERVICE I hereby certify that the forefoging MVPP's Supplement to-MVPP August 20 Petition to Suspend Construction of the Zimmer Sation have been served by mailing copies first class postage prepaid, this 18th day of October, 1982.

• Chairman Nunzio J. Palladino Dr. St'anley M. Livingston U.S. Muclear Regulatory Commission Administrative Judge Washington, DC 20555 1005 Calle Largo Sante Fe, New Mexico 87501

• Commissioner John F. Ahearne U.S. Nuclear Regulatory Commission

• Chairman, Atomic Safety and Washington, DC 20555 ' Licensing Appel Board Pat:cl U.S. Nuclear Regulatory Comn i ssion

• Commissioner James K. Asselstinc , Washington, DC 20555 U.S. Nuclear Regulatory Commission Wa shing ton , DC 20555

• Chairman, Atomic Safety and Licensing Appeal Board Pan 3.1

• Commissioner Thomas M. Roberts U.S. Nuclear Regulatory Coma ssior.

U.S. Nuclear Regulatory Commission Washington, DC Wa shing ton , DC 20555 20555 ,

Robert P. Warnick

• Commissioner Victor Gilinsky Director, Enforcement and U.S. Nuclear Regulatory Commission Investigation Washington, DC 20555 NRC Region III 799 Roosevelt Road

• Leonard Bichuit, Esquire Glen Ellyn, IL 60137 -

General Counsel U.S. Nuclear Regulatory Conrnission Deborah Faber Webb, Esquire.

Washington, DC 20555 7967 Alexandria Pike Alexandria, KY 41001

• Judge Jc'hn H. Fryo, III '

Chairman, Atomic Safety and Licensing Andrew"B. Dennison, Esquire Board Attorney at Law U.S. Nuclear Regulatory Commission

• 200 Main Street -

Wa shing ton , DC 20555 Batavia, Ohio 45103 .

• Charlos A. Barth, Esquire Troy B. Conner, Esquire Counsel for the NRC Staf f Conner and uctterhah'n Office of the Executive Legal Director 1747 Pennsylvania Ave. NW U.S. Nuclear Regulatory Commission Washington, DC 20006 Washington, DC. 20555 _

John D. Woliver, Esquire Dr. Frank F. Hooper -

Clermont County Community Co:ncil Administrative Judge Box 181 School of Natural Resources Batavia, Ohi6 45103

• University of Michigan .

Ann Arbor, Michigan 48109 *

• Dolivered through NRC internal mails. '

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Brian Cassidy, Esquire Regional Counsel ,

Federal Emergency llanagement Agency - Region I John W. McCormack POCH Boston, Mass. 02109 George E. Pa tti so n , Esquire Prosecuting Attorney of Clermont County, Ohio 462 Main Street '

Datavia, Ohio 45103

• Docheting and Service Branch Office of the Secretary U.S. Nuclear Regulatory Connaission Washington, DC 20555 David K. Martin, Esquire Accistant Attorney General Acting Director, Division of Environuental Law 209 St. Clair Street Frankfort, KY 40601 William J. Moran, Esquirc Vice President and General Counsel The Cincinnati Gas and Electric Company PO Box 960 .

Cincinna ti , Ohio 45201 Lyrine Bernabei-

• Delivered through NRC Internal Mails.

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[ g ,",, "g NUCLEAR REGUL ATORY COMMISSION ' ATTACHv1ENT 1

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Docket No. 50-338 Construction Permit No. CPPR-88 Cincinnati Gas and Elect ric Cortpany ATTN: Mr. Earl A. Borgmann Senior Vice President Engineering Services and Electric Production 139 East 4th Strret Cincinnati, Oil !$:01

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Enclosed for your <:sisonse is a "th::nmd for Information" issued pursuant to the Comuission's' authority under section 162 of the Atomic Energy Act and 10 CFR 50.54(f) of the Ccmmission's regulations. The " Demand for Inforraation" makes reference to and requires a response to certain aspects of the Miami' Valley Power Project's Pet ition to Sunr an Construction of the Zim:ner Station dated August 20, 1962. It ir, o 2 u;>derstanding that Cincinnati Gas and Elect ric Corr.pany or its represt at ives have a copy of the petition within its possession. If this underttanding is' incorrect, we will provide you a copy of the petition. You will note that the petition has been referred to the SRC staff for consideration under 10 CFR 2.206.

A response to the " Demand for Information" is required by December 31, 1982, though an extenslen of tirae for response may be requested for ~ good cause. Your response to the " Demand for Information".will be used in i deterroining whether Construction Perrait No. CPPR-86 should be nodified, I

suspended, or revoked.

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If you have any questions concerning this tatter, please contact R. F k'arnick (312-932-2500) .

Sincerely, p -) \

G s' ubi * ) s' hek J.nes G. IGppler I?egion<1 Administrator Encicsure: Derr.and for I n f orr.'s t i on l cc w/cael:

J. R. Schott, Plant Superintendent It!B/Docure.ent. Control Desk (I: IDS) hesident Inspector, RIII liarold W. Kchn, l'wo r S i t. i ng Cocmist. ion Cit i;: ens Against a Radicactive Envi ronr.'un t

• Helen W. Evans, State of Chio Robert M. Quillin, Ohio Depar tr.:e nt of llealth Thoacs Applegate Thorr.as Devine , Associate Director, Institute for Policy Studies Dave hartin, Office of Attorney General R. DeYoung, IE S. Richardsen, IE (HQ) ~,

S. Burns, ELD G. Dick, NRR Troy Conner, Esq.

I,ouis Clark i

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UNITED STATES OF A!! ERICA

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. NUCLEAR REGULATORY CO.T!!SSION In the Matter of )

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CINCINNATI GAS & ELECTRIC CO.'lPANY ) Docket No. 50-358

) Construction Permit No. CPPR-88 (William }{. Zimmer Nuclear )

Power Station) )

DEMAND FOR INFOR.'!ATION 4

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1 Cincinnati Gas and Electric Company (CGSE) holds Construction Permit No. CPPR-88 which authorizes construction of the William 11. Zimmer Nuclear Power Station in Moscow, Ohio. Over the past two years, significant defi-ciencies have been identified in the quality assurance and quality control' program for the Zi.naer project. These deficiencies raise serious questions about the adequacy )f the constructed 7,Immer station. In April'1981, NRC.

Region III had issued an Immediate Action Letter to confirm CG&E' commitments -

i to initiate corrective measures to ensure adherence to quality assurance ' W 8:

requirements. CG&E has also developed a Quality Confirmation Program-intended to address deficiencies in the quality assurance program and to

• 2 o

ensure adequate corrective action for construction deficiencies. On the basis of an NRC-Region III investigation in 1981, the NRC imposed civil penalties in the amount of $200,000 for violations of the Commission's quality assurance requirements in 10 CFR Part 50, Appendix B.

II On August 20, 1982, the Miami Valley Power Project, an intervenor in the Zimmer operating license proceeding that is represented by the Government Accountability Project, filed a petition with the Nuclear Regulatory Commission. The petitioner requests that the Commission immeliately suspend construction of the Zimmer stat. ion, replace the Quality Confirma-tion Program with a third party reinspection program, and require an independent audit of CG&E's and the principal contractor's (Henry J. Kaiser Company) management. The petition has been referred to the Director of.the Office of Inspection and Enforcement for appropriate action in accordance; with 10-CTR 2.206. The petition contains numerous allegations of quality.

assurance and construction deficiencies and further-alleges that CGSE's Quality Confirmation Program is inadequate to correct such deficiencies.

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i In order for the Commission to determine whether the Zimmer station'.has been constructed in accordance with applicable' requirements'and'to deter- ..

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mine whether tho'Zirnmer 26astruction permit should be modified, suspended, '

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or revoked, the NRC requires additional information concerning the extent .. y j and significance of q'uality assurance and construction deficiencies at the

} Zimmer stat ion and the adequacy of CCEF's Qaality Confirmation Program.

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4. Accordingly, in order to determine whether Construction Permit -

i No. CPPR-SS should be modified, suspruded, or revoked, Cincinnat.i Gas and j Electric Company is hereby required to subreit to the Regional Administrator, i

NRC Region III, the following Jr. formation in writing and under oath or affirmation pursuant to section 182 of the Atomic Energy Act.of 1954, as

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amended, and 10 CFR 50.54(f) of the Co:unission's regulations: ,

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(1) Admitordenyeachoftheallegationsapplicabictothelicensce's and its principa1' contractor's or subcontractor's performance --

contained in Paragraphs 19 through 273 of the Miami Valley Pcwor -

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Project 's Petition to Sur. pend Construction of the Zimmer Stat on.

s If the allegations are not admitted, explain the basis for not-i admitting the allegations; I

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(2) Identify the manner in which the Quality Confirmation Program 1

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addresses the type of existing or potential quality assure ce or n

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construction deficiencies and problems identified:in each of the.  : .:

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' 4 above allegations. If the Quality Confirmation Program does not address such deficiencies or problems, describe the manner in which CG&E will ensure such deficiencies or problems are corrected; The information requ: sted above shall be submitted by December 31, 1982.

Extension of time for response - ay be granted for good cause.

FOR TiiE Nt' CLEAR kEGUI.ATORY COMMISSION O

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-fgJanesG.Keppler

",egional Administrator NRC Regio =1 III 1 .

l l Dated at Glen Ellyn, Illinois this M.h~ day of September 1982 l

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. . INTEll OFFICE MEMOflANDUM ATTACIIMENT 2 To- ALL filSPECTI0ff SUPERVISORS onyt 8-18-82 Ar Moscow, Ohio .

rnou R A. Dapis comts To G. Hill All Inspectors C. Melton P. Norman lloscow. hio AT W. Smith .

R. Prewitt ,ou no. 7'70 0

suaatcr SPECIFIC DIRECTION TO QC IliSPECTION Direction received from the Owner (CG&E), the Engineer (S&L) or HJK (Site Management Committee,, Quality Engineering) will be followed to the letter.

This direction is given from a level which provides evaluation for all conditions on this project. This direction is not the QC Department's re-sponsibility to question.

(1) Responses to RFI/E's, DDC's issued by S&L, and specific

. direction from CG&E or Site Management Committee will be followed by all QC Inspection personnel.

(2) In the case of a disagreement of the disposition on an IIR, 2AP0-5 identifies how this will be handled. In no case, however, will work be stopped because of.the disagreement. .

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INTER OFFICE MEMORANDUM ATTACH:!ENT'3

. To _IllSPECTI0ft SUPERVISORS DATE 8-20-82 .

AT Moscow, Ohio '

FROM R.A.Da)ris ,

R. Prewitt .All Inspectors '*

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W. Smith C. Itciton P. florman it. Vitale Ar

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G. Hil1 aos no. 7070 -

SUBJECT Effective immediately, all flRs, CARS, RFI/Es, and Surveillance Reports '

issued from the Quality Control Department will be reviewdd and initialed by the inspection supervisors before being forwarded to any other depart-ment for processing.

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ATTACID1ENT 4 September 13, 1982 l

U. S. House of Representatives Committee on Interior and Insular Affairs Subcommittee on Energy and Environment Hearing on Quality Assurance for The Zimmer Nuclear Power Station on Tuesday, September 14, 1982 Testimony By: Donald M. Milan Chief Inspector, State of Ohio Mr. Chairman, and members of the Committee.

It is once again my pleasure and privilege to be permitted to appear before this distinguished committee.

I would like to thank you on behalf of the citizens of Ohio for allowing ot'r views on this vital subject to be expressed at a forum of such a high level.

The reports that I receive on a regular basis from the National Board of Boiler and Pressure vessel Inspectors, along with my personal visits have lead me to the following conclusions:

1. The work being performed by The National Board of Boiler and Pressure vessel Inspectors Audit Team is vital to providing the Stnte of Ohio the necessary assurances that the Zimmer Nuclear Power Station is being constructed in a safe manner and in accordance with our laws and regulations.

2. The work being performed by The Nuclear Regulatory Commission Inspectors under the present N.R.C. program appears to be effective and extremely important.

3. I have seen evidence that the N.R.C. and The National Board are working in close cooperation with each other to the mutual benefit of all concerned. I believe it is extremely important that these two organizations work together as they are doing at Zimmer. If we would have had both organiza-tions auditing in close liaison with each other as we now have,  !

the problems we are faced with at this plant could have been 98 averted. .

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This'could have saved the owners of this plant huge amounts of money, time and frustrations. I am of the opinion that The National Board Audit Team activity should be written into the federal Regulations, since it would enhance assurances of safety and compliance with all regulations in each and every Nuclear Power Plant in this great country.

4. One of the problems of the past relates to the number of N.R.C. personnel on site to the number of workmen or craft personnel. Many of these sites have over 2,000 construction workers on site. The size, scope, and magnitude of this activity is such that three or four inspectors regardless of how highly trained or capable they might be, they cannot keep pace with the activity. I hasten to point out that this is no reflection upon the quality or dedication of all N.R.C. personnel, because I can assure you these people are truly professionals performing their duties in a highly commendabic manner. There is just a need for more personnel, and we fully comprehend the budgetary restrictions which prevent more inspectors or auditors from being assigned to 4 overy nuclear site.

5. At Zimmer, by utilizing a National Board Audit Team, we have increased the number of audit personnel on site from three to six since we presently have three National Board Auditors on site. Whenever you double the number of personnel it only stands to reason that you will have a greater opportunity to achieve the necessary levels of safety.

6. The second Interim Report sent to me by the National Board of Boiler and Pressure Vessel Inspectors identifies many additional violations.

Listed below are a few of thess violations listed in the second Interim Report dated July 1, 1982.

2.0 CINCINNATI GAS AND ELECTRIC COMPANY 2.1 The National Board Audit Team in reviewing CG&E generated NCR's, noted that at least two (2) portions of piping systems had been overstressed during hydrostatic tests. Involved were Low Pressure Core Spray (LP) and the Residual Heat Removal (RH)

Systems.

t 2.1.1 The LP piping system involved was 12 inch diameter 98 designed for 475 psi at 202 P and includes lines ILPl7A3, ILPO2Al2 between valves lE21Foc5 and lE21r309, ILP14A2, ILPOSAl2 to valve lE21F012; lines lLPO303A3 and ILPO902 -

between valves lE21FO34 and lE21FOO4 and ILP32AA314, ILP32AB314, '

1LP30A3I4 and ILP31A314. The maximum hydrostatic test pressure permissible was 629 psi (475 x 1.25 x 1.060)'. The actual test YN"

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Page (3) pressure applied was 1200 psi according to a nonconformance e report issued (Re: NR-7247 R-1). The system is classified as ASME Section III, Class 2.

2.1.2 The RH piping overstressed was a section of 8 inch diameter piping having a design pressure of 1125 psi at 575 F.

The maximum hydrostatic test pressure permissable (based on DP x (1.25 x 1.06) 'was 1490 psi. The actual test pressure applied was 2700 psi according to a Nonconformance Report (Re: NR-7258). The system is classified ASME Section III, Class 2.

2.1.3 The above-referenced NR's (NR-7247, R-1 and NR-7258) were reviewed by the Owner's A.E., Sargent and Lundy Engineers, and dispositioned by the S&L engineer " Accept-As-Is". This disposition was based on the A.E.'s reviewing the yields as shown on the CMTR's for the material used, using the actual thickness of the material as determined by UT and recalculating the design pressure using actual thickness as measured and actual yield strength as indicated on the CMTR's and not using the stress values as listed in Table 1.7.1, Appendix I, ASME Section III. The piping material used in both systems is SA-106 Grade B.

, 2.1.4 It is the National Board Audit Team's opinion that disposition of the above overpressurization and " Accept-As-Is" is not permitted by the rules of ASME Section III since maximum allowable stress values for material are established in the Appenaix I tables; and in NC-3600 the definition of "S" states "the value of "S" shall not exceed that given in Tables 1.7.1, 1.7.2 and 1.7.3".

NATIOFAL BOARD FINDINGS 2.3 In the National Board Audit Team's Interim Report No. 1, concern was expressed regarding the scope of the work that was to be performed by Catalytic, Inc. (Item 2.6)

The National Board Audit Team has been advised that Catalytic, Inc. has been assigned by CG&E the implementation of ECR-623, which involves the cutting out and replacing of Code piping installed by Henry J. Kaiser that has not been Code symbol stamped or covered on a N-5 Data Report.

2.3.1 Again the National Board Audit Team is of the opinion that such construction shall be in accordance with Code requirements and shall be acceptable to all parties involved; CG&E (Owner), the Authorized Inspection Agency (A.I.A.), and the State of Ohio. .

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. NATIONAL BOARD FINDING i

2.4 A letter dated February 22, 1979, by S. A. Zych and D. D.

Crisp of Sargent and Lundy Engincers contains " Notes of Inspection -

February 5, 1979, regarding a Steam-Jet Air Ejector Condenser, William H. Zimmer Unit 1".

Apparently this steam jet air ejector condenser failed due to overpressure causing cracks on the shcIl side to the tube sheet and the pulling of some tubes in the outer two (2) rows of tubes.

A reference in the report was made to " poor penetration" (Weld),

and the National Board Audit Team became int $)ested in a possible Code violation by the manufacturer of the pressure vessel. In addition, the Team wished to confirm that the vescol was replaced as recommended in the above-referenced " Notes of Inspection".

2.4.1 The National Board Audit Team examined externally the pressure vessel ICDO3AALIA and noted a Westinghouse nameplate with information as follows:

Westinghouse 1-8A 2679-1 Steam Pressure -200 Cooling Water ~7600 There was a tag as follows:

HJK P.O.# CG&E 2043 MR #10247 Roccived 7/1/74 ID ICD-03AA Location - Compound 2.4.2 There was no evidence externally on the pressure vessel that it had been constructed and stamped in accordance with the ASME Code (a State of Ohio requiremont for pressure vesecis designed for 15 or more psi) . It was also noted that the pressure vessel had apparently been repaired in the field.

2.4.3 The National Board Audit Team has attempted to obtain documentation from the CG&E vault ana th'e Henry J. Kaiser vault for this pressure vessel and any repairs that have been made to it, and none has been. mace available to date.

2.4.4 It is the opinion of '.he National Board Audit Team that documentation shall be prerented to the National Board Audit Team assuring the pressure vessel (s) in this condensate system and repairs to pressure vessels in the system are in accordance with the requirements of the State of Ohio. 98 '.

7. There are many conformance programs in effect to correct these violations at the "immer site. The National Board is Monitoring '

and will continue to monitor these programs.

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I We are getting good cooperation from the Cincinnati Gas and

• Electric Company at this time.

8. With a joint effort by the N.R.C. and The National Board of Boiler and Pressure vessel Inspectors and The Jurisdiction, I believe we can bring this plant into conformance with the code and State of Ohio rules and standards or the equivalent.

By: ) pv=sb a _ )>f,. )?f h~m

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Boiler Div. Chief, Stato of Ohio e

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. OHIO'S LARGEST NEWSPAPER *

• CLEVELAND, SUNDAY, OCTOBER 3, P"7o 9 9 , 19S2 s .

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By James Lawless -

over the project and recognize the prob! cms E

The NRC has ordered CG&E to un<!ertake The Zimmer nuclear power station near a massiv qu lity confirmatica program to .Keppler said should have been obvious. He Cincinnati is the worst nuclear construction roexamine and in some cases reconstruct the .snid inspectors looked at specific prob!cm3

'while ignor ng the more basic issues, and Ict

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ProJcct in the Midwest and, perhaps, m the records of the project. The work is mt nearly done, according to Keppler. Until the records , construction difficultics slide.

. country. in the opinion of federal regulators. .

are complete and the safety of the plant as- .- 4 g iser En;'incers failed to 'o Construction began in IN2 at a projceted cost of $240 million, with a target comp!ction sured. Keppler said the plant would not be : prcper quality assurance program, perate a partially date of IM6. permitted to start operating. ;because CG&E would not pay for sufficient

. A decade later thanks to incompetence

• CG&E and its centractor, Kaiser Engi '

• neers Inc., centend most of the problems in- -

Billie Garde, a GAP investigator, argues en the part of the utility the builders and the j regulators, bureaucratic bungling and endless 0 volve only poor recordkeeping, and that there Tha't CG&E failed to respect the dangers and delay, and after the expenditure of $1.7 bil- are few actual co str"ctinn problems. c mp!cxity of nuc! car power.

f lion, no one knows when, or if, the plant will h.eppler and other NRC officials said there "Every point that should have been a f.ver open. warning was ignored," she said.

Wa5 a lot more than paper work involved, The Cincinnati Gas & Electric Co., which i point,ng to the improper welds as one exam-Keppler said the utility had the ultimate is building the plant at Moscow, O. is redoing ple. h,eppler last week demanded that CG&E responsibility for constructing the plant o

' 70'J' of the thousaads of structural welds. Nu- answer several hundred allegations made by properly, but he admitted NRC failed in its clear Regulatory Gommission officials worry' .one of the principal critics of the project - investigations. He said the agency everlooked that more such problems may be found, fore- ,the Washingten-based Government Account-nine years of evidence that things were going ing even more rework.mg of a plant wh,:ch is .- .

. ability I reject (GAP)-

I wrong at Zimmer.

supposed to be 9Fi, complete.

! "Somebody should have said, 'Here's Cin-CG&E, polumbus & Southern Ohio Elec. The Plain Dealer examined thousands of jrecords and interviewed scorcs of peop!c to cinnati Gas & 'Elcetric, a small utility, rever find cut what went wrong at Zimmer- been in this business before, and here's Kais-tric Co. and Dayton Power & Light are part- . ,,

ners in the plant. '

g who's never constructed a ecmmercial nu-er ,

8 The NRC's fearis. that mecham al pr

• CG&E faild to ta'e control of the should have inspired all kinds of thought."

lems could cause the plant to uring project aM was too tight-fisted with Kaiser. O Ecppler said. "The symptoms were all fhcre 3 cperation, possibly causing a ra ton During much of the project..CG&E had caly in the records."

> The construction records at Zimmer are six quality assurance inspectors. Under NRC y Kepp!cr admitted that NRC.did not have 8

, in shamb!cs. Without the proper paper work,. pressure to prove the safety of the plant, it enough manpower, in effect using one man to

. there is no way to know the extent of now has 211. u review the , work of 2,000 werkers. Keppler

. Zimmer's problems, said James G. Kepp cr,

• The NRC fai!d to keep close watd said ;he was embarrassed that, for several NHC regional directorG Chicago. years. FRC did not notice that the utility had

-. , ciy m gant

i j

f5 L c7 O y (pl11R $ @T8$

13 rRO'.i flR3T PAGE QTG]8 M ,

Ouality control prob! cms in the record- Borgmann argucd the plant was safe and

. I.eeping nere uncovered by Nnr ir.spectors that the massive quahty confirmation pro-in .',farch 1981, but Kepp!cr opted to allow gram. ordered by NRC was primarily one of the project to continue because he said thcre rebuilding the pa;)er trail which proves how were no actual construction problems t the plant was L;lt.

argce for n shutdown. The resident inspectcrs Bagmnn ' aid CG&E had been forced wantcd the project halted to give them time to spend hundreds of mi!! ions of dollars on to get cor trol of the project. dcs.

n and constructica changes ordered by Last November, NRC fined CG&E 5200'- .

000 and ordcred the major re-examination of .

Critics have said that CG&E constantly constructicn practices. NRC described the mterfered with the quality assurance pro-quality control program as "out of control." gram by refus,ng to aHow Kaiser tg hire peo-

~The tiility clso was fined for falsifying qual- EIe neeN to do the werk and by mterfering ity control <'oeuments and for haraising and with inspection procedures.

intimidatin;; quality control workers.

Kaiser's internal memos, and corre-CG&E denied most of these allegations' sp ndence between Kaiser and CG&E in 1974 but paid the fine in libruary. and 1975, show CG&E holding a tight fist The reprt said workers were doused with water and threatened with by.bly harm. When over Kaiser's quality assurance program.

other workers were doused m June, heppler In Oct.14,1974, William J. Friedrich, went to the construction rite ar.d raised hell. Kaiscr's quality assurance manager, wrete to COLE: "It is becoming virtually impossib'e The NRC's Office of Inspections and the to m unue Justice Department are continuinc the inves- pmsent naU.,yoWag in an awas wM h tigation of possib!c criminal violations in the intimidation of quality control inspectors and But CG&E President W.ll. Dichhoner re-fused to allow Kaiser to hire additional qual-falsification of records. But the NRC has notsty assurance staff.

provided an of the personnel needed to inves-tigate. , Dorwin R. Hunter, who heads the NRC In late August,' the Miami Valley Power re-efcamination program, said, " Quality assurance is cheap up front, but very expen-Project, a Cincinnati anti nuclear group, sive after the fact."

asked the NRC to stop construction and re-open safety t' earings on the plant. Hunter said, "They screwed up horribly."

He said many reports which identified con-Even though Kcppler, the NRC staff and the Atomic Rfety and Licensing 130ard want. structica mistakes were missing, some were ed the hearings reopened, the commission re. whited out" and others were just never.

fused. issued. '

Thomas Devine, a lawyer for GAP which Hunter ticked off a series of mec? cal-and paper work problems that had been represents the anti-nuclear group, s, aid he found:

wis concerncd that if the hearings were not reopened the full story of Zimmer's problems

• Structural beams and the welds con-would not be uncovered. necting them. IIunter said CG&E had chosen to rework about 70% of these, rather than

Before NRC reforms in 1981, the utility contest their. potential faults. He said about End its contractor were ignoring the prob. 8,000 deficiencies had been discovered.

lems at Zimmer; now they are actively cover- g, ing them up," he said-

• Piping and welds involved throughout q,3-the plant. Hunter said that while only 40% of Whatever weaknesses existed within the this re-examinatiori had been completed.

NRC inspection programs, the more central issue is why CG&E did not find the prob! cms. there were wida-ranging problems of docu-mentation. Inspcetors have not been able to ,

Earl A. Borgmann, CG&E senior vice establish where materials came from, wheth-president, said the company relied too heavi- er the right materials were installed and ly on Kaiser to assure the quality of the con-whether they were mstalledproperly.

struction work. He said CG&E would take ,

direct control over construction, if it were '

building Zimmer again-

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• Weldcr qualifications. Among the 450 welders working at Zimmer now.100 were An nerial view cf the found not qualified by NHC standards and Zimmer nucicer had to be retc.sted. Pour of them could not Critics of Zimmer, including Rep. Morris p ant.

pass the tests. Other welders who have lut 3

l'. Udall. D Ariz. have questioned whether the site will also have to be rechecked. It is CG&E cou!d be trusted to re-examine prob-possible their work v.ill have to be redone. '

, lems it ignored in the past. Keppler said he would order an independent audit 10 check o Records of 1.700 work or procedural CG&E's work.

problems were voided. This was reported to be one of the major abuses of written records Are there other Zimmers around the at Zimmer. Ilunter said he had found the country, and does the NRC have the manpow-i ' roblems p reflected in some of these reports er to find them?

still had not been corrected. John it. Sinclair. another NRC inspector, ,

Beyond NRC. inspectors from the National said problems at Zimmer were similar to Board of Boiler ano Pressure Vessel are those found at another plant in Bay City, checking violations of state and national Mich.

st mdards. Violations range from welding on Keppler said. "We should be applyini gi the containment vessel to problems in the more manpower at sites under construction.

steam ejector, which must be replaced. As a result of Zimmer. we have used.two f Victor Griffin. a former quality assurance inspection teams to lock for fund.smental worker. said the problems at Zimmer de. problems. We have found serious problems at .

ve.oped because of CG&E's arrogance and Clinton (Ill.); Clinton has been shut down for -

Ignorance. ,

about six months."

i "They were not stupid, but ignorant of "There probably a're some other Zimmers critical areas and wouldn't listen to anyone out there," he said.

..else," he said. , , , . . . . . , _ . ,, ,

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[ - P,.::*e ',* * *

n Dayton, Ohio, Sundaye Septen>ber 19,1982 266 Pages 754 o y. .

$ h,3eileVIRP -

< o -

T-w-

CAD' g By A:C1FW AIZZA.MDES

'No-shot' campaigners cite many reasons for running n ewine

. that gave ble the appearance of a crued

&c'er evik.

.O p . \,- a3 The ese time host of a lucat reIIstous televi. cr1w.faal record might hurt Grit!:a's *3and p/ -4 WASHDeOTON - As he 3.!&o h:a wbers. his la the ses John W. Crtff'a, edf-as, alon show. Brraher James has mare raseat;y chance? E 5, ,

I' A

[f s

come le public atteaba by pleadleg g@ ta ,, '

Crit!!a sgreed bla chaaces see goo & "I lag auto down laatsome contryWtary end'eas county lafro to couadras union ha3a, runda everfrom asredRep.

gth District sadhwa ccmndeal H. tralWas He cas !ality laste 1433 to Itsudalen:ly obt. Nag federal job eeaHy ^ believe.

, I la gpolitica you con erle (f funds and for a cuerAracy and you're la the r*ght place at t>, right time.

be Quixote Dca keks and forW;1ty a:t Iae.ma the woral la anarchf,La saf atas ensture l' epi.htkaa of has K aJacas, eyes by though the four. term Masul. emtduitment conviction that asse year la There are those who dee bt I cas do ti. I twice thrashad Garf:a lf .

WM.g - .'

the tap;ad dream, connect:ue Mta 3H.000 worth of biesketa know? ,

k18"I mars aa. .

for the hutgoamery Comary Commuatty Ac. [^ (

He le Johs W. OrtMa, somedme farmer * , l thsch rye gas a bestar chance th:a t!as tion Agency. He was rulused frca prian full-time raadidate. He is the haewr - by land. h Fva ever had before,"sa.14 Grt!f.a 31 of after aWa3 M oceths Rare an alao those who thiah John GrUfla has a reality problem.

A

~ ?*

• EsJui.rg.

i f e aMes - of three consecutive coagreedvaal elac:loe& And he la runa!ng agala.

FOR T1:0:;5 WHO de act f4sw the is.

• 'I M m m e e My h FOR IN THis sophist!catei pot:tical age said meea4 a.msh h ha4 sed te ema" when emey la hJad and larumbents are hard

'"\'

j But there ls nametalo3 C[fferest skla tima- trigue of oth Congrensfanal Distact saan. 'I"I 3 about a lae to eethrone, a virtually peaatiens cand;4 ate /[

' i, ,

' M-

~ ' * - ' d , .'j.'> . , , , ' ,fi peigas, until th!a pod week Gdtt:a*a chief *I8'I.Pm not sI!ke Joha Gat!!a sso'L evea a lor.3 shot - he's Wh #* '

Gcee la the perullar 1.!acotsess,e stovepipe ae shet.

s baL Seura la the Icas 34ach hair sad board poE4.at eJviser was Enrold J. Wrtght, aNo knowa ss

• Brother Jamag-But Bla week he unespectacy bowed stat e .

el na campaign, leanag pubkatam of his see PE2Ds% Fage ly A.

3M 6MIR,CaMic Mmaptas ,

i Errors ,

World leaders >?

hauntm. .a py %m_e&st.xm e "e ' .

o ,n ,

m2-exuress 1 outraEe.;i .

Zu, nmer over massacre a

The Wihm Af. Zimmer Acanar ,

BEIRLTT, Letanoe (AP)--Ortstias phaer Plear. has menar piss:s else, h,on'..]7 l < ',gr -_. mthamna raided the Chaul:a and q ;p g j.3 y g K' where around tse sous:ri, taany le a Sabra l'eleet:staa refugee caanps as s

W $12 '~ 's %

p!,pued by unstructue f:aas reef ( lv Q west Beht. Msg mea, women and ,(gg. p o m9:&+ g < ,gN everrbas sad delays Staff wr!!ere pi 6){'

childres la a massacre that begas Was NJils and DstwLe $asar s,sref

. more thaa a ano4th esanua!ng shoe.

t

. ' Nay aMlastad uatilaar!y $aturday. I' FV *= h **

e anada of pages of darumcats and coe. b *< The laternativaal Red Cross le Ceneva sa#4 hundreds of women, ch14 $*$ *, 7M

• ductico aumemos laterywws to fled . .. '

.- dres, adolescents aad old men were

, j+--

y~] J , " ' c/

out what west wrong and wha:Jr wIif 3 . kalled, whue the Pakattoe IJberntsee '

mana for warunersn Today's starser areIAeIIrarisaarri.na -

"W , + ? .* s *; (% ^%

Orgaalzarlos assertse the death toll s

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waa te the thouanace.  ;%

Sy WE5 HILg.$

-+ ;$ .

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Mhj ne laraell Forelgs huatatry amid the Chand:a attack was carried out by 8

g,

• g b',y. g,td3an,'- j,swT ' 8/ n # eJe'[, cp.M' M '&

• C and DARWIN 3ATC2 Star! Wrtiare E*

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M.(' M

• guamen byalle the Pta:anse Party of '- --

The year was 196A and a Wap. '

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' U meg g , ,.d* ** 4*,tEmJ,* .- h ;% ~4~ddC* - qM*T ,i Presidrot elect Bashir Gemayet, stata Tuesday !a a bomb attack, it asle gs C(

hometa maa named Net! A. Armstrong ,

laraels troops fired as the maraudert

.,,, p j g.g;,

S had just takes the historic first giant M.' .es. -"-4,,,, r '

{q

%--.e d g y#"*.y,f and weed "all posalble messe and

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step for manMod es the maps. Astert.  ;

WjeM Na -, V,N g meamares" to stop the Millag. AP N A

ca's tachaoiogical capatailsges seemed -

a ]4-

,/'#Z ('

Ear.ILese.

• M]M ;, ' % Rt# y/,,

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-76. f But the PLO blamed Israel for the maneacres and appea:ed for laterna- e W ad

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. ' ' d g**4 - ./ esonas latervension it claimed the al* bye 10EtneSSW,'!

. tlames eteugheered "every maa.

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lloincowner saw future clearly, got woodburner T 7F7~7C.p~ 2 ***^.1 s : {1e

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• t's dirty. Neuhard e knowtaif2*J of l

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3 3, v,u tra.13 aslcr nemas teraad D?&Us decialos is . f ='y. -4 ,g),, g gf statt Wrtter ' IW 13 Fele with two ocer (Elo wtait!ra is hta wo<mrnar. D's act cle.a r.ke e'estnc ~ -

q: *i j f

When Emery Nathar(a doctrts bills bui;c;sg the wta. ara R Zimrner Nudear adsa-r.d io ,e an um a m.ma iv. ee.v rau yud have a wt of wwk clearJag out i

s "p":""1.{

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is., ne-Corroihg energy cosa has bue a Efe-

• ' ' --] C"'[ y.si t

~~ years a3+ be cad what an uttaan.d nearly Neshard aakt be obtaana the 15 cc.-4a sit .d

• sh < be

. 5 suha other Americans han aans. , t:me harta in Nedard. who uia N besan nura , ,,,,,,,.

P.a tought a wood:p.rs:ng siave La best EAoress woud for hfe Pareata is Pea.myl- .evoc4 he ,,barr,a

,y,3,g ,94 g7,,, eseh.w, tater Mfrom

,4 , ,,g,g,, ,3, acla ' , , , ,

eu ra his nome.

varJe when he was on.y 4 yurs old Wha he purnaamd h:s lh-sary. three-w W m ad y5 ,. - ~) d a b] {! % f-_) . '. 8 t Naurd. 63 of 8:3 Liede Yack yt, sam 'E3 g, , / 8 ,N {Sp .,s g "p * * ,

- sel < aA et -

the aret!.!y 1stla la his ali4actr.c hcme barcom home r.ers 27 yura ago. Nevrard u.d me nat Lawd n .ua u un res.a < my myar.) weens tm pa,,a F J g is m

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av r stu 6:o a me.a sa eww.m a e. we not aw :n yua

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4 .aune.e.

g,Njr.,3 > g )- (<g, a me wtm, o u n. e y g,g_ , , , , ' i ssa wowsm.r.

som awuoer premour.: chupand a.aaw u wow. ne :4. t- a n o.= ew.<c autat. Nea.rd swttaa. ,,,,,,,,,,,mm,,, .e i,neaard

-. p.wisau -su u.n: a --u vas .a.e

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s

• • =us -u aa , u.r r..w. Naar. aa r.arie nen .- ..ai i. mis w da., , % u.,, ,,

~ % .4 ceu. t+t hared Leum.ata. wnw == .uaty tems. ta.Me my DP&L cuumrs , ,,. h _.d. ,.- _ .

• g; ,,,p 3:2 ano Dance..mn.s e = naos ,;y- 9 . "M i ,,, ,,4,,

y.na tw ass his swhy w* ster ==tr.a who uve turr.d &>=e nar tLunntats te / *

.ny D.yu. pusn ud upt c.'s two. a swertusss = rosinLasdayeu ad . " *" " ~ ,,'u.

cure ta a. n as ne uw. .w was soarw rram aw sisa te sno.

icuado, r us au um. ne na-r4 ss degre.e a swii.wunard ma se kept i DML but showed Neuhard wisdaart d. beating with woor! ',',j !'

~ ~e=a -a una.t se. eccessc. a. isnew.u Thu Sn==ss ..ma i >= deta: a ni.y a sem- k a hme u a mum 90egrus nut whur. -

Erfoss koni earl.1. in_ construction haun. t Zimmers,4,,,, n * , . , .*.

, muss.

.. 4 DF&L Priadant Robert E. Fraamaan,, 4 dLagrud via tu inap. car a cinpa,, ,,

c . 8 2 vum Page s.A. '

' - . .TW">

% p I" n.7

. . that a zsamr pism . porg , ,,, '

wue r dregawy 6::ome by Ins ts, erst rg , ,

< ad a cCam= ,

.e on.

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widupuu srunew. a tse . . , _ .

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ar. .s TxNs ws. ass.aen was d=n na e au s ceu,t.

4.aisa.

ramn s,umy.u u nce proc.m .ver.:4c. n red maswro 4 /- a. wrtasEQ , . 4laarpoweron r trial

• r~. y anacney erstes ) .ns ;i,i.

-[-CG&l* l - S'03 M3UCN everymWs. Frunma , w. } .

c.=,uw-ao. riawe to use er tu p m e w.cy sy- i.

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. . . 3.m. en Bae la 1979 and ha g t Soane crit:c oud .e.. .e o.f the plant agg R

...d* o-, - *' --  :

, cause of posar.calanfen prwe'ma, '* DPFa.e PEAK LOADS 3LT3:m NRCreparis angs st echerwise. ae s. am; ta October 8384, a esdge risw *gd .aoc AN EKTE!t4IVE review et the

' l Zimmer probes by Daytes Nae > VZl'ON ,

31.5 %

W km mhansw mue omt aseneir- g

"' 'Msa m-e red ca -y et as sure problers today are a resJt of mI> nwn *  %

.[_DPALl

- sas.sunnoN .

pesada p"re"ssure*thmug"h of resat ta handle esty 300 pounds.rtg,,

ptpts,,,,, {

a takes and es maiculadca. by CG&E

_ and the NRO dae:.3 ted to the earty f ,,, '

eg --

ping the pipe and masklog electridag p ,

' , f~Qn

• wta esta. The were wou:d hert u spos. g ,

toes radioactiu had um plaat 6.se, N,, , . d.

Tne preims wue maru!ned by ' '5**8 " th* NRC "M""*- .s soortas tar a.e sa c.maisuce.e ea,s , s 23.5 %

aed uthier federal regi. lad.nA espe = ,1i e As a Nece d um NBC"a na.u ,g,, med-l _CASOE ! tags. coaa wis ria.d 550.03o ter ,iat ,

. ca*Jy rotiewing me nauwa worn se cle.r plant accideoit is blan.h 19*9 at

g. ..,

'I, i

6

• p

.,ry[S434.5

r. f. vp w MERCNg/ edfhyM' a y %'ye falmitt.d ginatity-asurance racerds, dT

$50.000 for haramarment and inuedda.. [qe the Three nt.le ts.and Nweisar power :N jf J

I ' ^' .

,1

- toe ot inopectors and $100.000 for fanV8*8 '

• F!am la Pe asylvr.nla. k. .

C3dCN AI.COliT erg to adequately everage the qual!ryl t4A ,

Cimaumers stre4Jy feeling from  !' 'fYf ' '.."

• MMM usurance pts.grm. 't **d' .

rapidly esca; sung electric sata ta. .

creues erCl be paytre for decades far i N h CG&E, DFal. AND the CohaahdI" '" .

.wt out wr a um . 2. -- .

1 /- -

.,a-an, s.ioumr.

coe- eu. n oh.m u.cuic ca du wiOO H D.,m . ,.p ea.-- - .e e,,, ,a ,,,,em, ,, ,,,m,,e ,,e , ,

Jl,"e-",a"/.~,*.:",*lg' . i' x* .y ~ -= = ~ -o-~~-'~- e l.k

""'.".'!'.::a"d Llr'fe='*".

waahts.gton. CA:caga. Ctacteasd and -<s ,, . Perhape P f e.-more egnificant thaa the nues kie ad as Se god f43 W 6

EEPPLER SAID the NRC InfGalty ,e riggs me fias gw,weg . ' '**' k

. , _ . other hacal:oca to reconstruct what . . r g. ,.

happms.

} .

,. ',[g y qg  ; e, ( gaal"d

, ,,Piogmn.,g honnrg , su th muu.y compsale M suchar poww O.K.

~ ~ -*** au.t NRC.a ,< we -en-n.ot - . go as e-to. conte . I[ 4, e ed r ma, me ,ma. .u,e ,#,,.4 ga- - pa,wy* := **e., .. 1.i, g A m ,u.

e s..., i. t g. m ,u . W, *

.p .,r.e a me w .ema "y'*,",",;,,,,,,,,,,,,,,,,,,,,,, ,

,es u, e. .~... . _ , . . . m 7. . ., e ,r a r T,e ,,e w ,.,,. i e ._.d t.

-, .u-a. - wed. s a d.d.,ar.

t...,e,t o,,,s ._. . .a w ,a

,Na, e. .et -, at c .

...n.... . . .

cewe ima. N Ghp and atter crNka AhtONG THE f;odtaga:

f ~ that a he plant un't he ecpstred ne.

"*""*""'"W""*"""*"'#"*

P'* ** 8# * **#'I * *""I* *8 UK. NitC *' 'N 888 86*as to sus **t ..

thel L't's get together and solve anyog ,g.

cause of the misanng eacumentauon Proheems you've sat and let'a set theg Mr

• f a!er to esmplete the plant sa mumaW ethmtowu mena operateg." penser no64 ,, w ,

qu6chiy as pwsthee, conuactors Ial- prohleut

• as I a gger prob.ee . . . but we kat The fine maa small compared to th&.ar tia!by d+scouraged q atty <ostrolla-

• Beams, bolts, welds er ; p' ping spectora from utg2 roussy esforcin8 buried sa tona of concrete may bow, *

• conta amauc6sted mth the re laspectke,,,,,

• Pf*4 ram erdered try the NRC. ,,, .g a stikt federal constructtes g4lddines. g .

g never been inspected, canaut te , ,g f accaraing to F *tC taveaugat.se traced, and mast remala a myatery imp scattorie f rom a btgger prob eva N #* '"

• d*W g .

• The NRC and CC&E faled repeat. USt.C IVR122 USAM PCR D:5&T. '*""

month n aWuh!ngton,

'"*#8d " 8'84 ** *m lot ow brwdemas our gg g gg, Keppler sat 9 aa 'm'D"*"

M to swet th#eamlag

** @* H* t,*

400 to $43.000 a year, accorsing to edly to asegantely respond to #aly We aa:d to ourse:wes. should we 8 rate 4acrease.te<suest teettmany he.q mam6ags of coestrurjos pre,b: ems As dategits curstmt&Ja. dwumentamia has spaased a meann aw sned m ne Dn.mw sue from W the pubtsc Unlides Commission or aarly as 1974. C04E rejeded reqers's *1f there's as hope that faalley ulli stop the Ab or shouie m e let la go cap W d me paWe inspeiwa to W. W W tavMgat.ta la Ohio. "***"

for improvementa la the gaa#y. amer

• operate somedaf. t*ie MC le song tes Keppfer aa&d who ever morned at Zimmer Investo 1984 about how be had repeatedly asce staff at the plant, NRC do:n- hate IJ be centisced . . . that the plaat They are re-laspectlag old weet.ti,o THE IW51tGATIGN was Incone gators hoge it.cy might be able to re. tried to rootve quauty. control pret.

a.eata lvl. me- haa bees bu;t prt,perty,* a ad Keppier. plete, he saA sad the full ratent of satt every defect they ever reported la lema st the ptant.*but with no luck? etuneeles new maamence sat,,, u

• Last year, after sa tavest;gaWe search 6ag for lust paperwork at tLe uw plant, Keppkr md. ansfMR WAS aut of controt." atte. "#'86 flaany was andert sen, several NRC M ANY htCLZJLR power plaats constatnon perms wasa.g gnwa "We desWed that at this pdnt la "The la6ue of the 14R (noscoctorta- Harpater sold L.a a report to the hAC. THE NOtEIR OF NRC laspecterb'%d lavetugators afg.ned that cor.atrucWe around the cowuy have faced prob.

prob ema at the pisot were so aerms ha, seck.:aa e aa.naces f aure at timetw. .. it maid be a ,penit;te n atter ance) reports ated whetaer er not the lie add the h>C's requirements were at the alte was lacreased from ese tDhe A taat it aNeid tw shut down tastead. Ge Davta Besse p aat osar put Cita- aaut me plant dows, wh ele klatory (of t k e plant's a- e." eight. Amorig the leapectors are flee 1 ***'

tr,e NRC decided to flee the eempany taa. 04.1o,6a 1877 and a 1975 fire la Also, Keppler said. *1f you ski.t it conhfuctica)can be reconstr%ted la a He cited the pressure qua!!ty. control who are checking inte aume 300 eaa. dr*

a*d requ!re a tsajor re.taspection sag the Brem a's Ferry, Als , plant. dcwa pteraturely, you muld have serious quema," kepplet said. perrampel were under to approve work getsuna of baresolved quelltyeontree tite reser program u.at :a st111 ander way. But Zimmer ta the inoat trat; bid ad- lost a valuab'e soutce of y.or wwkers Fe;pler said many al'eged deretta at the plant. problems,includsag senous tsasea thaa no e-i

.

• Dupna the re lasperuos ptr. gram. clear plaat now iseder cosettwdue. wbe migM act te tr.c!!aed to cate may me longer be actem#e to physF "To stop cor.atructk.a for any deft, could affect the safety er the pient. mena.e there remais questacan whetser att the Keryler saad. "I cas't scenpare tt, a.y. back on tbe job that m as that Iar cat inapecetua. Without the auwag clencies. he (se inspector) would have Keppler asid he also *futty lateservismo defects at Zimmer can be located ang w.th what a going se at Three kile la- along. paperwork.It may never be poonbie to to t,uto ap many pasta W the co- m oulia" a third party, ladepmseen, d repa: red, accordir.g to James G. Erp- land. but certainly, fu a cosa.ruction Warnkt agreed. Pe sa d he an4 k's aswre ll.e public that every defect la structica of a 34 bilitos p!aat, sa the amtit by a quattfled company not es.neme.

Pier, r,rsctor of the NEC heglos C sue.thare 3dag to lw tme? tatesagative team was is full accord the plant has ken lasted and cor- QC mspectors uo what they are teld.* omtated with ettber the coatsacier er..*ene ett;ce, At the Zimmer plaat, the NRC with tae redaspection progra rected. he d be saad. C6&E te re-laspect work an the ptantesee 1

• Whea 7;mmer flaatty goes fato reported defective wekts, wirlag and "When we meat late the meetirig *WHAT tot; DO know la that'at's itsrpster esumated that the laterest while paperwork may be the runt af 4' art opersuca. DP&L*s 315 percent share other deficleacles atlla mest be with IlcrAmana, we kaew what we getest. ally a big problem bec 6,ae of cost ahme la h.4d.r3 up cometruct;oe many of the problema et Zimmer, thab ase att lacrease the stity*a rate baan - repelred. manted to lay se IJ.a ar.d we did," the pnor effurts nat were Involved la of a awlear plant for une day could be problema are certalaty est Bratted eenles the ta!ee of eiectric generet;cg and potentially tauch amre serlot,s are Warmkk sa:4. quality assurance." Keppler said. eeveral hundred thounaad deliara, paper. w.A ga distr!buuse equipment esos ta caku. bundreda of mist.ing sceut formance The re.4r.apertion pregram and Ik.rgmana, however. said be docan't He also motse that a udlity caa*t Frederiet Christlasone, the sealm te lattag feare electria bitta -by KJrs reports - reporta pat were nrnties s bsequent 3200.000 flae levied beLese ttere are defects out there besta to recover its investment to a resident laspector for NRC at Zimmer#ent taan as!f. over the years by goniity natrolla- aga.est CG&g " mere two of the mak- turklag la the womaa" because of nuclear power plant from its custom. teria of bresalag through 20 feet d emers' e Ongstes lavrat:34ticas and bear- 8Pectors ahestag delecta la some est stuona ever asdr.st any Izrenase is documemados "somebody threw ers satil"the p; ant reached the point concrete and d rt ta repair a p6pe wM ,dt ,

Ings before coegreestneal cemcalt.e , safetyda:ed s)stemale the p!artt. the who;t cous.ry," Warnkh said. seay I dual belfsve that for one of complettaa "la Oblo, a sullty can't at the plant. . ,43 g,..

could f arther delay Go p'aa's epew BMGRdANN SAID CG4E ltaeff pro- 4te .acL" beg's Lo recover these costa until a IN A AtJLT 88 report lelley. Mort'aissea A 3368 EIFCET el the kpC's or.go.

Officials for Kalser Tag!neers lac, plant !s 7Spercent complete. K. Udall. IAArts, chairmas of thegmas e llos eed W Ibers mh of hs' Ing la estigation at the Zimmer plant peaed a re-laspectica program to tfie toits cosL ' hased some such tepons were 1mptop- hKC. but it was act of the broad scope the pmaary contractor 64 Ae project, HARPSRR'S contentlose regard:ag Ibuse subcommittN Ge esergy sesgygg

'Evea lf prescat cnst estimmes a*e erly voasea while othere w ere ordered by Keppler. deckaed repeated requests for sa the rwa ta huabl11mmer arv arhoed te environmer.t. the N RC repened bee w.a accurate. the average DP&L teadsa- fais f;<d. Some other rewed.s were We recciamended one of a scope latervles ,

a swara statement provided to tas drede of def6caeacles le the plant'8 ausa g a ,,,

llel customer will pay at least sa steen.the report Beid , ". where we didal ge and kma at The NkC read.fy aca.its to beving NRC by Draais Dueovaa, as tcapcciar hardware.

M&tional 3124 12 each year for 33 The r$cddy construrtloe work and every parucular item." llorgmann been port of Zimmer's prot 4 eat. By the at the Zimmer ste. For eumple, of 259 connectsons as an=*

years - Zimmer's espected lifee:ias ums lst documents were considered se said. "We ended up kavtag to go to a time the hRC brgan a aertoi.a revww *% e are here to get mas plant built." elecitical cable traya las,ected. thert e.g

- for coasmuca of ne plaal That serious by Keppler's 13-meer.ber laves- ISS.perceat easpHag la certala el constraction la leie 4960, the build. Domesa amid tw was 1e14 by a tul!!y. NRC reponed "233 of those connes,a Dub 8*et toclude the sost of manica ne tiga;ka team headed by Itobert F. area,y ers of Zimmer reporte4 the plant was a.atrol mauser at the plaat whea tions were aceconfermang la some,ing.

II*et. . %artick ttat many of them pressed to The 134 percent r aepectica was 5> percent comp; eta. , Donovas eapnaaed concern ever a maane" Tiwee : lad! age will be daacussed la t. ave constiscuos at the plaat sigped recently redoced,by the NRC to a a For a an.mber of years,the NRC arst lack of support of the laspect:os pre- SZmitarty, hundreds of other def 6 0:s and subsequest articles. la March 1941. grara.*We are not bu:1 sing a CadL;ac, clencies were found la the plast's steel Ihnmer has appeared ready la go *We bad a meetMg right after they we are bisillas a Ford Don't be sat. beams, welda sad other liema lata operatica for near!y four years, ca.ne bask and it (stopp;ng conuruc. pkk.cg la voar .nspectiot.a? , "The bottom l6ne here." I;dau re-Its Saetofy cool;ag tower is la tlog) certalaiy was ihe in! lal feel!ng I"'"" "9 *'# #""I '* * **** 9*N*

f.sfunatens cl the cost of the Emtre p'. ant and prtplactioria Of sacr"tf6ced te get the plant g"u"schly late assarance breakdown has occur" red at

p. ace, as are virtas;ty a;t other corapo- of Mr. Warakh. who was heading the

• when 40 woLdd be placed into cornmerCaol operatk,n' the rate tant er to avuld lacreaslag 24mmer?

sents. The nuclear fact is ready to be (laventiga:Aus) team, and it was the lunded. WieW GI sBany of the memtsers" Kep- costa. s it now appears it wtn take leagw to vei me ao 1.sm conarmuo. 5"'- "*' 8 8 " *' ****c'a=*!r '==$ 'a ***

Keppler said he rett sh attlag dows COST IN SERVICE enortcht any qta!!Iy or any ccreera"

"P' *8 the coastnoction at Zimmer8 8""a' (1979 'as' workers and 434 Inspectors report dally to the p;a: L Zimmer tsal es. the plant would be two harsh. Burgmane said. 4934) than it was supposed se have 0 **"'""*"I'P"" KEPFliR SAID he met wRh CC&E GAP MM chargM Gat $e M # M MW M M k, 54 M $3 rdaca IMU ' omissies d Harpstn's ausgatkas M g se, lor yg e presigent rart g, gag. fresa a R$31 NitC report citles the CG4F predicted the re4sspedica, ZDthil'E'S ESTIMATZD cost soared mana on March 31. 1331 tour days M in On an. I Inadequacy of an eartier commasstes program wlli he completed la IS74 from 3231 mill 6on la 1969 to 317 bah after Ina investiga:1ve team called fur

• Bos today. CG4E has stated that ear.h Zlmmer to be shut down. CGAE was I'"

197S $LO2 m'than IM concent damag.ng la!wmatlos about Thrureatsg funhw delays am est shmth it is delayed adda 315 mi:Iloa to ordered to undertaae the largest re te- the P;aat. going iBl and NRC invesusadone, as its custa. spectica program in the hkCa luatory. 1977 $fn3 mdon len. l## D James Comtalags dirvoor of the weu as further pubilt heartogs hetere

!! the 317 billion cost est:m.te The Goverament Acc.matability NRCs Offase of Inspectar and Aud. tor the NltC. congreselonel commet eos holes. DP&L's 315 percent stare of Pro;ect - a aos profit. watchaug 1979 $80innon Jan IMI that reperted en the eerher. lande. and ethers. .

j .e Zamneer will cost 35J5 5 mt;hea. co:n. group based la Washangtes - has 4uste intest:gsuoa, angruy dested Fraser a:amlamed any suggestion that.

pared to the original eaua.aie of 366 8 charged that the NRC covered up same 19M $1 Maon Wrch 1982 Zimmer, hhe Three Mde taleed, could GAP"a alwgatsoe.

m.tlaos. of its most critaced findiass at Z6mmer A bigger gusuos than cost, how. CAP aM sa4gessed the cectasua to IMI SI25 Mion Ian F#G Cun.mir.gs saad liarpster's allega- pose a na'ety reak.

uons am pan d a nguing lawsuga- "As f af es Fm concnud. Gare etw. may tw when the p6 ant un begf a pnad casuutuva to move was 1962 gg.7 gion F*L 1% tion at Zimma by me aewir created ndiculut h, mad. mecame er me

• productas power - or if at can tie Port of a deal between Keppler and N R C Off.ce et investigaL6es la quahty-assurance progree, at is peoh-used et sa - in Inght of ne quanty. CG'F- Washington. stdy the besthat penet se me ==p==

assurance breakdowa the NRC found kePpler denied G AP's allegauena. _

p_ _ -_ - . g