ML20081B765
| ML20081B765 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/29/1982 |
| From: | Wahl H BECHTEL GROUP, INC. |
| To: | Dickhoner W CINCINNATI GAS & ELECTRIC CO. |
| Shared Package | |
| ML20081B738 | List: |
| References | |
| FOIA-83-77, FOIA-83-A-13 NUDOCS 8310280229 | |
| Download: ML20081B765 (6) | |
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Bechtel Power Corporation 777 East Eisenhower Parkway Ann Arbor, Michigan
- u. nee =ss: P.O. Box 1000 Ann Aroor. Michigan 48t06
- "" 'E r RECEIVED< remu .
. I.I.MCIEDIEt December 29, 19 E2
, JAM 3 1953l 1
Mr. William H. Dickboner, President nd -
Cincinnati Cas & Electric Company gggu gg 139 East Fourth Street -
Cincinnati, Ohio 45202
Dear Mr. Dickhoner:
Bechtel vishes to provide the following supple =ent to our letter' proposal of Nove=ber 23, 1982 in response to the request of Ja=es C. Keppler, Regional <
Ad=inistrator U.S. NRC Region III, by his letter of December 28, 1982,-
direr:ted to Cincinnati Cas and Electric Co=pany. Our responses are numbered to match questions directed to Bechtel within the NRC letter.
Item B Questions Directed to Bechtel Power Corporation.
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Item B.1 Paragraph E of the Bechtel Nove=ber 23, 1982 Revised Proposal listed key people to be interviewed. This list was intended to ,, _
be a mini =al listing or starting point regarding the personnel to be interviewed. Therefore, a end paragraph to add, "In the conduct of'a review of the Zimmer project to determine measures
- needed to ensure that construction of the Zimmer plant can be completed in confor=ance with the Co==ission's regulations and construction permits, it is Bechtel's intent to interview NRC personnel directly involved in the Zimmer project. We vill also interview National Board of Boiler and Pressure Vessel Inspectors to identify existing procedural or construction deficiencies j which must be rerolved by management. Other(oEjetent; individuals who may have direct knowledge or insighi into
. management, organizational, quality assurance, or construe, tion activities, vill be sought out to provide background infor=ation for assessing reco= mended corrective actions".
Paragraph C.1 of the Bechtel Revised Proposal dated November 23,'
1982 revised to include item (h) "wherein the review team vill review identified construction and quality assurance deficiencies to deter =ine if they are attributable to or related tg -
management".
Item B.2 The team's " management review" report will be first critiqued by the functional management located in the Bechtel Ann Arbor office. In the Bechtel method of operation, the management 8310280229 830824 PDR FOIA DEVINE83-A-13 PDR ,
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a Bechtel Power Corporation Mr. William H. Dickhoner ,
December 29, 1982 '
Page Two review team works independently of the functi'onal management in Ann Arbor and therefore, this would be an objective review bringing to bear.a vide range of nuclear engineering, construction and quality assurance experience.
In addition, the; report would be reviewed by the Bechtel Power Management (BPM). This group is independent of the various divisions and reports directly to the President of Bechtel Power Corporation. This is a very significant review in that the '
reviewers are experienced, senior people and vill have the background of similar work being done by all the Bechtel Power divisions. This final review should indicate any areas of the report needing additional e=phasis and support, its general applicability and validity. -
Item B.3 Affidavits are being assembled personnel have been contacted
, and vill sign.
Item B.4 The following is provided as further information on the role of - .
Mr. Soderholm during his direct involvement with the Midland Project:
a) March 1980 to February 1981 - Mr. Soderhol= joined the Ann Arbor Power Division as field cost scheduling supervisor.
As stated in his resume, he was responsible for all planning, scheduling and cost control programs at the Midland site. He held no responsibilities in activities covered by 10CFR50 Appendix B. In this, capacity there were no construction or quality assurance related deficiencies identified in his area of responsibility.
b) February 1981 to September 1982 - Mr. Soderholm was promoted l - in February 1981 to the position of project superintendent -
s ervices. In this position he managed such non-safety related activities as cost an> scheduling, office services, finance and accounting, construction saf ety, and personnel.
He also managed three safety related areas covered by quality assurance progra=s: ,
- 1) Subcontract Administration - This area included administration of 'the contractual bonds between the ,
Midland Project and such subcontractors as B&W, Zack, and U.S. Testing.
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- 7 Bechtel Power Corporation r=
, Mr. William H. Dickhoner
- December 29, 1982 . .
Page Three
- a. In this time frame, B&W, and U.S. Testing have had' a minimum of quality assurance related deficiencies, none of which were attributable to .
Mr. Soderholm's subcontract administratien. QA controls of these subcontractors are provided by the utility (CPCo).
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- b. Zack had had problems in the past which eventually resulted in a Civil Penalty assessed against CPCo. Mr. Soderholm was given his assignment approxi=ately one month after the Civil Penalty and was instrumental in establishing more.
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. effective control of EVAC activities which included the licensee taking responsibility for all QA/QC activities about mid-1981. This area has since been related as a Category I in the NRC Region SALP Report issued in April 1982.,
- 2) Field Procurement - This area included routine field procure =ents of materials not controlled through the
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normal Midland Project procure =ent operation in Ann Arbor, performance of receipt inspections for count and damage (not quality control inspection) and management
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of storage areas. No major proble=s were identified in areas under Mr. Soderholm's responsibility. NRC Region III Reports 50-329 and 330/81-08 describe several storage conditions but these areas were under control of construction maintenance engineers rather than field
. procurement. A July 1982 special meno from Resident Inspector R. J. Cook to R. F. Warnick again described storage condition proble=s but without identification of examples. It is believed that the 1981 report was the primary reference.
- 3) Document Control - Mr. Soderholm was also responsible for administrative services which included control and issuance of design docu=ents from a central document control center. This area was established with a continual self-auditing function to monitor'its activities which resulted in excellent control and identification of.only minor deficiencies during his tenure. An NRC inspection performed in the last several months is expected to note one deficiency but the report has yet to be received.
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,-~ - . , . - - Bechtel Power Corporation e Mr. William H. Dickhoner ' December 29, 1982 Page Four e) September 1982 to date - Mr. Soderholm was transferred from the Midland Site to Ann Arbor vbere he assumed responsibilities as the. Technical Services Manager - Projects, s. division position providing technical guidance and salary administration for Nddland Project Cost and Schedule Engineers. No Construction or Quality Assurance functions 'are related to this position. Item C.1 Bechtel.vas contacted by CG&E prior to the Order to Show Cause to perform an assessment of.the project and to subsequently assume a management role'to assist the licensee in the management of'the Zimmer project. As a result of this contact, an agreement was reached and Be~chtel asse= bled an experienced team from throughout the Bechtel organization. The purpose of this team was to establish the conditions that exist"in the various discipline areas, i.e., QA, engineering, construction, at this stage of the construction. Spec'ific emphasis vould be placed on the ) identified quality problem areas, programs in place to resolve _ these areas and their impact on planning for the ce=pletion of
, the project. In addition, the relationships between the various -
subcontractors was to be looked into. This degree of involvement
, was considered vital before Bechtel could commit to a course of action either as the independent reviewer or to assu=e the follow-on role in assisting in managing the project. This was explained in some detail in W. H. Dickhoner's (CG&E) letter of Nove=ber 10, 1982.
.The Bechtel team arrived to perform this function on the first working day af ter the Order ves effective. It was a mutual CG&E/Bechtel' decision at that time that the proposed Bechtel review included all of the essential elements contained in the -
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Orde.r and should continue. The,Bechtel site presence was diminished when it was considered that they had sufficient information to complete the initial assessment of the project and to recommend a course of action. In as much as CG&E and Bechtel
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had independent 17 and voluntarily agreed to a review si=ilar to that set forth in the Order, we do not believe that Bechtel's objectivity has or vill be affected. W. H. Dickhener.'s - (CG&E)
. letter of November 26, 1982 to Region III supports this position in greater detail.
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3<.. Bechtel Power Corporation t Mr. William H. Dickhoner December 29, 1982 . Page Five-Bechtel's independence an'd objectivity is further ensured by the . fact that we are a national engineer / constructor involved in all phases of nuclear power plant design and construction. The . extent of our involvement is shown in Appendix C of Bechtel's submittal of November 23, 1982 and represents 90 plants. Bechtel's corporate QA program and supporting work procedures have been subject to the scrutiny of the NRC, many utility organizations and applicable national and state code boards. Of equal importance is our established reputation for maintaining high ethical standards. Bechtel's recommendations vill be based on the facts discovered and on our professional integrity and
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experience in the nuclear industry. In addition, the approved
. action plan vill be subject to continuing review and approval of the NRC. The matter of independence was also covered in detail in the Bechtel proposal of Nove=ber 23, 1982 submitted to CC&E.
4 Sincerely yours, , (*[ .
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Howard W. Wahl
. Vice President & General Manager INW/cf 9
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- ' ATTACHMENT 10
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3 -a,, w. .- THE CINCINNATI GAS & ELECTRIC COMPANY sEL
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?..i. i P :-- .!,. . .:._ .t Attention: Mr. James G. Keppler 'd- t f _ _!. _
jl Regional Administrator OL l F l!.E ;- Gentlemen: '
'Re: Nm. H. Zimmer Nuclear Power Station, Unit 1 Order to Show Cause and Order Immediately Suspending Construction, Docket No. 50-358, -
Construction Permit No. CPPR-88, W.O. 57300, Job E-5590 - Supplemental Information - Recuested Bv Your Letter of December 28, 1982 ! This is in response to your letter of December 28, 1982 requesting supplemental information to my letter of November 26, ' 1982, in which we requested the approval of the Bechtel Power Corporation (Bechtel) to conduct the independent review of the management of the Zimmer Project. We would like to provide the requested information in the same general order and format, as follows: A .' l . The only document we have related to our plans to utilize Bechtel as outlined in my letter of November 10, 1982 to the NRC Commissioners, is a proposal submitted by Bechtel with a transmittal letter dated November 8, 1982.. A copy of this original submittal, less contract terms and conditions which we and Bechtel deem proprietary, as well as a copy of the transmittal letter is enclosed. You g ** 'will note that the original proposal is essentially tiie one submitted with my letter to you dated November 26, 1982. Also enclosed is a tabulation of the meetings held between CG&E and Bechtel as well as a tabulation of the l site visits by Bechtel employees to date. ,- Your request under this'particular item also included some I discussion of any oral understandings that we might have l relative to utilizing Bechtel as outlined in my November 10, 1982 letter to the Commissioners. As I indicated in my letter of November 26, 1982 to you, we had concluded prior-to the issuance of the Show Cause Order that additional project management expertise should be brought to the
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U. S. Nuclear Rcgulatory Commission Attn: Mr. James G. Keppler Page 2 . . January 3, 1983 Er, C-Zimmer. Project.' On November 2, 1982 we contacted, by ,
, telephone, three firms, one being Bechtel, relative to making h presentation as to their capabilities to N., , '
conduct an assessmen't of the Zimmer Project management. A fourth company was considered but not contacted since they had just recently done work for us. Bechtel made , an initial presentation to us on November 5, 1982 and submitted a formal proposal to us outlining a proposed ~ ~ - ~ ~ " program on Novemb'er 8, 1982. As indicated above, a copy of this initial proposal is enclosed. This proposal was subsequently revised by letter dated November 23, 1982
, which was attached to my letter to you dated November 26, 1982. - -
By November 10, 1982,. we had concluded that Bechtel was , the most qualified of Ehe companies interviewed to fulfill our needs. We indicated verbally to Bechtel that we were going to submit a letter to the Commission indicat.ing a proposed program utilizing their services. l In the interim, the Commission issued the Show Cause Order on November 12, 1982, shutting down safety-related con-struction at the site. Since the assessment portion of
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, the program outlined in my November 10,'1982 letter to The Commission was essentially the same independent review of management requirement outlined in the Show Cause Order,
, the decision was made to allow Bechtel to proceed with i
preliminary work. It was indicated by us to Bechtel that they would now be proceeding on the basis that approval from the NRC would have to be forthcoming before any definitive contract was signed and a total scope of work defined. This situation was discussed with you at our meeting on November 17, 1982. At that time it was understood that any work done by Bechtel prior to NRC approval was being - ,
, done at risk.
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, It should .be emphasized that there is no signed agreement -
nor formal purchase order issued to the 3echtel Power Corporation for their efforts to date. Our verbal under-standing with them is that if they receive approval to do the management assessment from the NRC, a formal agreement
- , will be signed covering those' services and commercial terms
! negotiated for any additional scope of work beyond the
- initial assessment phase. In the event that for some unknown reason Bechtel would be disapproved, we have i
verbally agreed that at that point in time Bechtel would be reinbursed for work completed on the basis of their standard . consulting rates for comparable, services. e
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. U. S. Nuclear Ragulatory' Commission Attn: Mr. James G. Keppler Page 3 January 3, 1983 ,
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We believe that this should clarify our relationship - with Bechtel and should indicate that any work done
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by Bechtel to date has not in any way. compromised the 5pgf NRC's approval process. 3.1. Refer to the attached letter d'ated December 29, 1982 from Bechtel for their response to this item. -
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Note: For clarification, refer to Appendix A of Bechtel's proposal for Paragraphs E and C.1 which they have now revised. C.l. CG&E's Response to Item C.1: In this question you asked why any Bechtel continuing role on the project beyond IV B (1) (a) of the Order would not affect their objectivity in performing the management assessment. . We would first like to indicate that the objective of the program proposed in my letter of November 10, 1982 and the steps outlined in the Commission's Show Cause Order of November 12, ,1982, are essentially the same; namely, to complete the Zimmer Project in full compliance with all applicable requirements to ensure a safe operating plant. The' cornerstone of my - November 10 letter and the Show Cause Order is to bring sufficient management, quality assurance, and construction expertise to the project to implement the Quality Confirma-tion Program and the project completion program. The first step in both programs was to detemmine what must be done to the management of the project to ensure that the project can be completed in conformance with applicable regulations and the Construction Permit. As indicated in my letter of November 26, 1982, CG&E believes that Bechtel has expertise in all required areas
. and firmly believes that Bechtel has the professional integrity and character to recommend a management structure that would be the best possib1'e one to meet the unique requirements of the Zimmer Project, regardless of the-77 '- organization utilized for its implementation. We further believe that Bechtel is the best qualified through its experience and depth of personnel to be the implementing organization, independent of any assignment to assess project management.
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Our objective is to complete.this plant in such a manner that it meets all applicable requirements. With this in -
- M; . mind, the party we believeimplementing the best' a program course of. action be the same is to have party pro-l posing the courses of action to be taken. Undivided responsibility would be placed on one party, focusing accountability, thereby best ensuring the integrity of.
the completed plant. This would have the best chance of
' success by not placing a second entity in the role of ' ' trying to implement a program that they had no responsi-bility for formulating. -
To scumarize, we believe that Bechtel has superior quali-fications in all the required areas involved in completing Zimmer. We believe that their professional integrity, as well as their ' vested interest in the nuclear industry,
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. would not allow them to compromise a management assessment of what they might perceive Ebeir downstream role.,on the project to be. Finally, it is the logical decision to have the same party accept the responsibility of implement-ing a program they created, particularly when they have the total expertise of the Bechtel Power Corpor ation.
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You also requested a discussion as to whether Bechtel's' - - j activities at the site to date affected thei.r objectivity in making the management assessment. As indicated in several places, Bechtel's assignment relative to my letter of November 10, 1982 and the Show Cause Order is the same relative to the management assessment. Bechtel has not been compromised in any respect in their activities to - date nor have they been given any preconceived ideas or direction. They have been directed by myself to make a management assessment of the project with no reservations and to make an honest, unbiased, and comprehensive report based on the facts as they exist. I want the facts as much as the NRC and I can state categorically that CG&E has taken ~
, no actions that would affect the independence relative to
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Bechtel's activities to date that should have any affect on pp Bechtel's objectivity. Furthermore, at no time has anyone "from CG&E discussed with any member of the Bechtel organi-zation any of their findings or made any attempt to -
' influence such findings.
C.l. Refer to the attached letter dated December 29, 1982 from Bechtel for their response to this item. 1 9
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Nuclear Rcgulatory' Commission Attna Mr. James G. Kcppler Page 5 . January 3, 1983 b - I'believe'the above has satisfac,torily answe. red your " supplemental request and should allow the NRC to formally approve Bechtel to conduct an independent management assessment of the Zim:5prJroj ect. Whether Bechtel was selected just prior to the Show cause Order or immediately'following the Order does not place the test of independence in jeopardy as defined in Chairman Palladino's letter to Congressmen Dingell and Ottinger. Yours very truly, THE CINCINNATI' GAS & ELECTRIC COMPANY " By W. E. Dickhoner WED:vm Enclosures - Bechtel proposal dated November 8, 1982 List of CG&E - Bechtel Off-Site Meetings , List of Site Visits by Bechtel Personnel . Bechtel's Response to Questions B and C dated .s December 29, 1982 e 1
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