ML20082B558
| ML20082B558 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 10/26/1983 |
| From: | Williams J CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| LOZ-83-0202, LOZ-83-202, NUDOCS 8311210239 | |
| Download: ML20082B558 (51) | |
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TIIE CINCINNATI GAS & ELECTRIC COMPANY CINCINNATB,OMIO 45201 October 26, 1983 LOZ-83-0202 1
J. WILU AMS, JR SENIOR vtCE PRESIDENT NUCLE AR OPERAftONS
~ PRitKUPAL STAFF Docket No. 50-358 v RA
.duPRP U.S. Nuclear Regulatory Commission
. D/RA DE l gypA cr+1sF Region III RO DPdA 799 Roosevelt Road
- AO SCS
~se, f3 Glen Ellyn, Illinois 60137 NA ML 1 ENF Fno Attention:
Mr. J.G. Keppler Regional Administrator s
Gentlemen:
i RE:
WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 l
INDEPENDENT DESIGN REVIEW (IDR)
W.O. 57300, JOB E-5590, FILE NO. 956C, r
j This letter requests your concurrence in the approach being taken by CG&E in the conduct of an Independent Design Review
.(IDR) of the Zimmer Station.
t In the Course of Action (COA) document submitted'to the NRC October 5, 1983, CG&E proposed to conduct an IDR.of the Zimmer i
Station.
The IDR is described under COA Item -10, on' Page 59.
j CG&E advised that requests for proposals for the IDR had already been sent to seven (7) qualified firms.
Copies of the request for proposal, dated September 9, 1983, were submitted to NRC Region III and to other NRC offices. is a copy of the request for proposal and includes the list of prospective contractors. ' Proposals were received October 14, 1983.
CG&E is proceeding to evaluate the proposals..The evaluation is being performed by CG&E personnel and'outside consultants:who have had no prior responsibility'for-the design of the'Zimmer Station.
Award of a contract will be deferred pending receipt of your response. to this letter.
l CG&E intends that the results of the IDR augment'the'results of the Program to Verify the Quality of Construction (PVQC) and the results of plant.startup testing to provide a basis for; i
assuring that the Zimmer' plant' meets its licensing requirements.-
l CGEE~also intends that this IDR satisfy any NRC1 requirement forz an IDR~or-other independent' design' verification. We,;therefore, consider it necessaryJto hav ~your: concurrence.in our-approach to
.the IDR before we award a coracact.
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8311210239 831026
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PDR ADDCK 05000358 A
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Mr. J.G. Keppler Regional Administrator October 26, 1983 LOZ-83-0202 Page 2 Upon completion of our selection of a contractor, we propose to proceed as follows:
A)
Advise NRC Region III and Office of Nuclear Reactor Regulation of the identify of the selected contractor and the basis for the selection.
B)
Follow the protocol document imposed in relation to the November 12, 1982 "Show Cause Order".
Although this protocol was not specifically imposed on an IDR, the protocol appears suitable to cover - the conduct of the IDR.
C)
Submit to the NRC Region ~III-and Office.of Nuclear Reactor' Regulation for your review,' the contractors plan for the IDR.
It will be submitted about 6 weeks after selection of the contractor.
These proposed actions are~ consistent with the Course of Action submitted October 5, 1983.
Your early response to this proposed approach is requested to en ible us to proceed with an IDR that concurrently meets,our and.
ap/ NRC requirements.
Should you have any questions, please call D'. K.K. Chitkara (513) 632-2681 of my_ staff.
Very truly yours, THE CINCINNATI GAS E ELECTRIC COMPANY ^
By
_r_7:n d'
. WILLIAMS, JR. /
SENIOR' VICE PRESI ENT JW/EJW/sfr
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i Mr. J.G. Keppler Regional Administrator October 26, 1983 LOZ-83-0202 Page 3 cc:
NRC Office of Inspection & Enforcement Washington, D.C.
20555 ATTN:
R.C. DeYoung, Director NRC Resident Site Supervisor ATTN:
W.M. Hill NRC Zimmer Project Inspector, Region III ATTN:
E. R. Schweibinz NRC Office of Nuclear Reactor Regulation Washington, D.C.
20555 ATTN:
L.L. Kintner l
T
o INDEPENDENT DESIGN REVIEW BIDDERS LIST 1.
Cygna Energy Services 101 California St.
Suite 1000 San Francisco, Cal 94111 Attn:
Larry L.
Kammerzell (415) 397-5600 2.
Ebasco Services, Inc.
Two World Trade Center
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88th Floor j
New York, N.
Y.
10048 Attn:
Ben Tenzer 4
(212) 839-2944 k
3.
E.
G. & G.
Services
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O.
Box 2266 idaho Falls, Idaho 83403 Attn:
Bob Schultz (208) 529-8700 4.
Gilbert / Commonwealth P.
O.
Box 1498 Reading, Pa. 19603 Attn:
William Sailer
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(215) 775-2600 Ext. 7543 5.
H.
P.
R.
Assoc., Inc.
1050 Conne'cticut Ave.
N.W.
liashington, D.C.
20036 Attn:
Theodore Rockwell (202) 659-2320 6.
Teledyne Engine ~cring Services Division of Teledyne, Inc.
130 Second Avenue Waltham, Mass.
02254 Attn:
G. A.
Carpenter (617) 890-3350 7.
Technical Audit Associates Inc.
-589 Oencke Ridge New Canaan, Ct 06840
~ Attn: Frank B. Jewett, Jr.
(203) 966-0383
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TIIE CINCINNATI GAS & ELECTRIC COMPJGT cf CINCINNATI.QHIO 45201 J. WILUAME JR 1
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September 9, 1983 c
JW-SC-00899 i
l Req. No. 828 l
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Technical Audit Associates Inc.
589 Oenoke' Ridge New Canaan, Ct.
06840 Attention:
Mr. Frank B. Jewett, Jr.
Dear Mr. Jewett:
4 This is a request for proposal (RFP) for performing l
certain engineering functions in connection with a Cincinnati Gas &
i Electric Co. 's (CG&E) program to review the qualicy of design of the-William H. Zimmer Nuclear Power Station ("Zimmer").
This review
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will supplement additional efforts being made to verify the quality of construction under a separate CG&E program for the NRC.
The results of these two reviews combined with the results of pre-startup plant tests will provide a basis to assure that the "as buil t" Zimmer Plant meets its licensing requirements.
Background
On November 12, 1982, the NRC issued an " Order to Show Cause and Order Immediately Suspending Construction" (SCO) which has the effect of suspending all safety-related construction at Zimmer.
A copy of the SCO is enclosed for your information.
Construction may be resumed only after certain evaluations are completed, among them a plan to verify the quality of construction (PVQC).
(See section IV.B (2) (a) of the SCO).
The PVQC will be performed as a separate operation.
The results of the PVQC will provide a basis to address the adequacy of the quality of construction of the Zimmer Plant.
Although not required by the SCO, CG&E considers that these evaluations should be extended to include design considerations as well as the construction element.
This request is to solicit your interest in performing this independent design review which will be used in conjunction with PVQC to provide added l
assurance that the Zimmer Plant has been designed and constructed in-
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accordance with approved criteria to meet applicable:NRC'
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To:
Frank B. Jewett, Jr.
f September 9, 1983 i
Page 2 I
scope The elements of the design review have been identified and are outlined in Attachment I.
It should be understood that Attachment I may be modified as a result of on-going activities under the SCO and action thereon by the NRC.
Independence The selected organization must address the independence criteria set forth in Attachment II.
In discussing your independence, please be mindful of the fact that the Zimmer project is owned by The Cincinnati Gas & Electric Company, (CG&E), The Dayton Power and Light Company and Columbus and Southern Ohio j
Electric Company, a subsidiary of the American Electric Power Co.
The architect-engineer is Sargent & Lundy and the constructor is H.
4 J. Kaiser.
Bechtel Power Corporation has tentatively been selected to manage the development of the PVQC and its implementation and to i
direct completion of construction of Zimmer.
Prior associations j
with any of these organizations on the part of your company and/or your employees should be addressed in a section of your proposal
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dealing with the independence of your company.
Limitation The contractor selected to perform the PVQC audit will not be eligible for the Independent Design Review discussed in this RFP.
Content of Proposal Your proposal should cover at the least the following:
(1)
Relevant prior. experience of your company and employees (2)
Persons who will be assigned to this job and their resumes (3)
Your approach to performing the werk described in Attachment I (4)
Your commerical terms (including hourly rates)
(5)
Your independence from the Zimmer project.
(6)
Proposed schedule
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To:
Frank B. Jewett, Jr.
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September 9, 1983 Page 3 Four copies of your proposal should be addressed as follows:
(1 copy)
(3 copies)
Mr. D. C. Funke Mr. E. J. Wagner Materials Management Department Zimmer Nuclear Power Station P.O. Box 960 U.S. Route 52 Cincinnati, Ohio 45201 R. R. #1 Box 2023 Moscow, Ohio 45153 and should be received at the office of The Cincinnati Gas &
Electric Company not later than October 14, 1983.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By:
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JW/ dab Enclosure A Order to Show Cause and Order Immediately suspending Construction Attachment I Elements of the Design Review Program Attachment II Independence Criteria NRC Region III Regional Administrator, cc:
ATTN:
J. G. Keppler NRC Office of Inspection & Enforcement Washington, D.C.
20555 NRC Zimmer Senior Resident Inspector NRC Zimmer Project Inspector, Region III ATTN:
E. R. Schweibin:
J
To Frcnk B. Jewstt, Jr.
Septcmbar 9,1983
",lPaga'4 l
bcc:
E.J. Wagner
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G.F. Cole H.C. Brinkman B.K. Culver J.R. Schott J.F. Shaffer K.K. Chitkara D.R. Hyster J.A. Vennemann G.C. Ficke Bechtel Power Corporation Attn:
G.B. Jones General Electric Company Attn:
I.L. Gray T.E. Bloom l
Sargent & Lundy Engineers Attn:
R.J. Pruski L.M. Gordon T.J. Daley Henry J. Kaiser Company Attn:
M.E. Noffsinger Basic Energy Technology Associates, Inc.
Rosslyn Center
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Suite 825 L
1700 N. Moore Street Arlington, VA 22209 Attn:
W. Wegner Pickard, Lowe & Garrick, Inc.
Suite 612 1200 - 18th Street NW Washington, D.C.
20036 Attn: W. W. Lowe Lowenstein, Newman, Reis & Axelrad, P.C.
1025 Connecticut Suite 1214 Washington, D.C.
20036 Attn:
J. R. Newman, Esq.
Conner and Wetterhahn~
Suite 1050 1747 Pennsylvania Avenue,.NW Washington, D.C.
20006 w...,,,
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i Attachmant I 1
Elements of the Program to Review the Quality of Design f
I.
The Project and its Current Status William H. Zimmer Unit 1 is an 810 MW nuclear power i
station, incorporating a Boiling Water Reactor BWR 5, Mark II containment, and related facilities ("Zimmer" or " Project").
Construction of the Project is estimated to be approximately 85%
complete.
The Project is located in the state of Ohio near the town of Moscow, approximately 25 miles Southeast of Cincinnati, i
The Proj'ect is owned by The Cincinnati Gas &' Electric Company (CG&E), Dayton Power and Light Company, and Columbus and Southern Ohio Electric Company, a subsidiary of the American Electric Power Co., (hereinaf ter referred to as " Owners").
CG&E is the Project Manager.
The architect-engineer is Sargent & Lundy (S &L).
The constructor is H. J. Kaiser Co. (Kaiser).
The Project Director of the PVQC and the Continuation of Construction Plan (CCP) has tentatively been selected as Bechtel Power Corporation.
II.
Show Cause Order On November 12, 1982, the Nuclear Regulatory Commission
("NRC" or " Commission") issued an " Order to Show'Cause and Order Immediately Suspending Construction" ("SCO") regarding the Project.
The SCO was followed by a NRC evaluation, NUREG-0969, which identified both discrepancies in design and construction of the
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zimmer project.
In addition to immediately suspending all safety-related construction at Zimmer, the SCO directed that CG&E undertake the following actions prior to commencing any additional safety-l related construction activities:
(1)
Retain an independent organization to review the management of the Project to consider as a minimum alternative management-structures described in the SCO, and to recommend measures to ensure that construction of Zimmer can be completed in conformance with the Commission's regulations and the construction permit.
This was completed by submission of the Torrey Pines Technology Report GA-C17173 of August 1983.
l (2)
Submit for approval a recommended course of action on the basis of the independent organization's review (Torrey Pines Technology) and a schedule for implementing the' recommendations.
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Submit for approval a comprehensive plan to verify
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the quality of construction (PVQC) of Zimmer, i
(4)
Submit for approval a comprehensive plan for the continuation of construction (CCP) based upon the results of the PVQC.
CG&E has decided to extend the above SCO actions to include an Independent Design Review (IDR).
The IDR, the PVQC and the pre-operational plant test program will provide a sound basis for determining that the Zimmer Plant meets applicable NRC l
requirements and regulations.
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III.
Purpose The results of this IDR, the PVQC and the pre-operational plant test program will be used to enable CG&E to determine whether the Zimmer Nuclear Power Station has been designed and built in accordance with its licensing bases.
The IDR is to be of sufficient scope to permit the reviewer to conclude that the design features under review meet the license application requirements or to
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identify the specifics of the design that are exceptions to the requirements.
This IDR will consider the existance of the PVQC and the f
pre-operational plant test program.
Hence matters relating to
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construction QA and design elements that will be confirmed by the pre-operational plant test program will not be included in the IDR.
This IDR will be a multi discipline review.
Emphasis will be placed on design, design QA, and design construction interfaces.
Attention will be directed to subcontracted design efforts.
The level of detail must be sufficient to achieve the above stated objectives.
Depending on the results of the IDR it may be necessary to expand the scope of the review to resolve items.with potential generic impact.
IV.,
Scope of the Independent Design Review This IDR will consist of two segments; a review of the QA program for design and a review of' design of specific elements of a safety-related systems.
The review of design will be used to determine if the design is consistent with the bases and-criteria i
specified in the licensing application (all docketed information) and meets the functional licensing requirements of the system.
The review will be of the. Residual Heat Removal (RHR) System design parameters delineated in Section V.
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The following criteria must be used as the basis for development of the proposal for the IDR.-
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- 1. -
The IDR is to ba structured cuch that the reviewer can make objective conclusions concerning the adequacy of the design elements identified.
In-depth reviews of the C
identified elements of this system are to be performed rather than a sampling technique based upon a statistical approach.
2.
The IDR is to be limited to the scope of design details listed in Section V.
Design analysis,. calculations, construction implementation, etc., of the specific features listed are to be reviewed.
1 (a)
Design Technical Review - Review the design for selected areas (systems, components, structures, and interfaces) for compliance with requir,ed licensing bases and criteria.
The scope of this work must be carefully identified; procedures and evaluation i
criteria must be developed to guide this review.
(b)
Field Implementation Review - Review the as-built I
configuration in the field in the selected areas to l
verify the validity of design assumptions, i
j 3.
The interfaces wit'h NSSS vendor (GE) and between design j
and construction are to be reviewed.
l 4.
The review is to utili=e the bases and criteria contained in the licensing application as "given" information.
The
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adequacy of the criteria and bases of the licensing application will not be evaluated.
5.
The review mcchanism must recognize and consider the vintage of design and of the acceptable licensing criteria in evaluating the degree of compliance (e.g., a feature i
designed in the 1970's may have different codes and i
standards applicable than a similar feature designed in 1982).
6.
A mechanism for identifying and resolving potential findings (items that may be deficient) during.the review is to be established.
A determination.of the implications of each finding is to be conducted.
7.
The entire independent review is to be conducted under a quality assurance program in compliance with 10CFR50, appendix B and must meet the repor, ting requirements of 10CFR21 and 10CFR50.55 (e)
The reviewer organization i
will submit its QA program for CG&E review and approval prior to start of the: review.
8.
A scoping document is.to be prepared that identifies'all
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steps in the review process, the' detailed scope of the l
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~4-independent review, the procedures controlling the review, and the evaluation criteria for evaluating compliance and (1-presented to CG&E for concurrence.
for evaluating potential findings.
This program is to be 9.
A final report is to be prepared with.a presentation of the findings, and a statement that the. features meet the
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license application requirements or meets the license application requirements with identified exceptions.
10.
The IDR should include an evaluation of the pre-operational test program as it applies to the areas under review.
This is to assure those elements of the design that can be confirmed by testing are included in the test program and that acceptance criteria are correctly identified.
V.
The Review Elements 1.
This IDR will have two segments.
The first segment will consist of a review of the QA program for design.
This effort will require familiarization with CG&E's and Sargent &'Lundy's design control programs and a determination whether they were correctly implemented and provide an adequate basis for assuring a satisf&ctory design.
To the maximum extent possible, the Residual Heat Removal (RHR) System review discussed below should be used
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as a basis to determine the adequacy of the design Q.A.
program.
For those elements of the program not covered by the RHR System review, the contractor will have to expand the review to assure all elements have been included.
2.
The second segment of the IDR will consist of a review of.
the design of the Residual Heat Remo' val System.
Sections of the system are identified for the review.
The objective of the selection is to assure the review includes:
1.
Major Engineering Disciplines 2.
A Major Design Category I Structure 3.
A Major Class I Valve Supplier 4.
A Major Class I Pump Supplier Specifically the review will inclu'de the following elements of the RHR System.
Review Pipe Stress Analyses A
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-S-s For in-containment shutdown cooling system suction piping Review Pipe Support Design For Class I:
In-Containment RHR Cooling System Suction Piping For Clasc C RHR Complex Piping Element:
in-reactor building section of the service water piping' to RHR heat exchanger a
Review Structural Design Service water structure foundation Review Electrical Power Supply and Control Circuit Design F
Service water loop "A" pumps Review Equipment (Seismic) Qualification Class I MOV containment isolation valves
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Class I service water pumps Review of the adequacy to convey and control details g
of construction Perform Plant Walkdown
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Design assumptions vs as-built conditions The reviews will include the following elements:
Design Input Documents L
j Design Analysis Control Drawing Control 7
E-Procurement Control g
5 Design QA t
Internal / External Interface Control:
Design Verification
-F Document Control E
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l Decign Changa Control Corrective Action Internal / External Audits and Surveillance Test Program VI Schedule The schedule for completion of this IDR is to be based upon a maximum peried of 8 months from the signing of the contract to completeness of the final report.
The contractor is to provide a schedule for all contractor activities including the proposed start of the review, completion of the review, issuance of conclusions on all potential findings, and issuance of the final report.
Q'#Jwe BY M. A. REVIEW DATF 9b'/P P
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Attachmcnt II f
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Indapandance Criteria o
CG&E will utilize the answers to the following questions C
to evaluate the independence of the company which will conduct the Independent Design Review and the individuals which the company will utilize in the review.
Minimal or insignificant contacts will not necessarily disqualify candidates for the independent review.
(1)
Has the company or individuals involved had any previous involvement with the Zimmer Project?
If yes, please provide details.
(2)
Has the company or individuals involved been previously hired by any of the owners, Sargent &
Lundy (S&L), H. J. Kasier Co. (Kaiser), or Bechtel Power Corporation (Bechtel) to perform similar audit work?
If yes, please provide details.
(3)
Has any individual involved been previously employed by any of the Owners, S&L, Kaiser, or Bechtel?
If yes, please provide details.
(4)
Does the company or any individual involved own or control stock *of any of the Owners, S&L, Kaiser, or Bechtel?
If yes, please provide details.
(5)
Is any member of the present household of any individual involved employed by any of the owners,
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S&L, Kaiser, or Bechtel?
If yes, please provide details.
(6)
Is any relative of any individual involved employed by any of the owners, S&L, Kaiser, or Bechtel?
If yes, please provide details.
(7)
Has the company or any individuals involved been offered-future employment by any of the Owners, S&L, Kaiser, or Bechtel?
If yes, please provide details.
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.NUCU55RREGblET6RECEFEI5510N
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' COMMISSIONERS:
Nunzio J. Palladino,. Chairman
- E2 h5'112 P4 :*0 y
Victor Gilinsky 4
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John'F. Ahearne Thomas M. Roberts James K. Ass,elstine C ' ' ~ - 'i c F
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3 2 8 !!0 V 1 2 1S S 2 In the Matter or
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CINCINNATI GAS & ELECTRIC COMPANY
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Docket No. 50-253 Construction Permit No. CPPR-82 (William H. Zimmer Nuclear EA 82-129 Power Station) s
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ORDER TO SHOW CAUSE AND ORDER IMMEDIATELY SUSPENDING CONSTRUCTION (CLI-82-33) -
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Tha Cincinnati G,as and Electric Company (CG&E) holds Construction Permit No. CPPR-88 which was issued by-the Ccmission in 1972.
The permit
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authorizes the construction of the William H. Zimr.er Nuclear Power Station Unit 1, a boiling water reactor to be used for the ccmarcial generation of electric power. The Zicner plant is located on the licansee's site in Moscow, Ohio.
II.
E.
Initial Identification of OA Problems In early 1981 the NRC conducted an investigation into allegations made by
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present and former Zic=er site employees and by the Govern =ent Accounta-.
1 bility Project. The NRC investigation revealed a widespread breakdown in
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C3&s's management of the Zi=er project as evidenced by' numerous examplas of non ce=cliance with twelve of the eighteen quality assurance Crigri.a of-qd4 h g %q
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g Appendix B to 10 CFR Part 50.
Ccnsequcntly, CG&E paid a civil penalty of
$200,000 for the failure to implement an accaptable quality assurance program,
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false quality assurance documents, and intimidation and harassment of quality centrol inspectors.
(See Nctice of Violation and Proposed Imposition of Civil Penalties, dated November 24, 1981 and Investigation Report No.
50-353/81-13.)
In addition CG&E agreed to take actions to correct ident(fied QA failures and prevent their recurrence and to detemine quality of ccepleted construction work.
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Actions to Correct Identified OA Failures and prevent Recurrence A meeting was cenducted by Regio,n III on March 31, 1981, and the utility agreed to implement te.n acticns to, correct quality' assurance failures identified during the January - March 1981 investigation and to preclude
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their recurrence. These actions included:
(1) increasing the size and technical expertise of the CG&E QA organi:ation; (2) taking action to' assure independence and separation of,the QA/QC function performed by Kaiser frcm the construction function; (3) conducting 100% reinspections of the quality centrol (QC) inspections perfomed after that data by Xaiser and other con-tracters; (4) reviewing for adequacy, and revisi,ng as appropria.te, all QC inspectica procedures; (5) training "A/QC personne'l on new and revised procedures; (6) reviewing for adequacy, and revising as appropriate, the precedures governing the identification, reporting, and resolution of
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deviaticns from codes and Final. Safety Analysis Report (FSAR) statements; (7' reviewing for adequacy the precedures governing ncncenfermance re;crting and justifying the_ disposition of each voided ncncenfermance
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, repert; (3) establishing an adequate program for c:ntrol of QA and QC records; (9) perfoming a -100% review of all future surveillance and non-
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conformanc! rescrts written by contractor personnel; and (10) reviewing and revising the CG&E audit program so that it included technical audits of c:nstruction work and more cc..:prehensive and effective program.atic audi ts. These cemitments were confirmed in an Icc:ediate Action i.etter to the licensee en April 8,1951.
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ac:1cns to Determine Ouality of Comoleted Construction Work 4
Follcwing the identification in 1981 of significant quality assurance problems and related management breakdcwns, CGaE agreed to establish a ecm-prehensive program to,, determine the quality of the cc=pleted construction work.
The Quality Confirmatien Program (QCP) was submitted to the NRC by the licensee cii August 21, 1981'.
b The QCP addressed prcblems identified by the investigation in the follcwing areas:
(1) structural stael; (2) weld quality; (3) trace-ability of heat numbers en piping; (4) socket weld fitup; (5) radiographs; (S) electrical cable separation; (7) noncenformance reports; (8) design control and verification; (9) design document changes; (10) subcentractor QA programs; and (11) audits.
3.
hsults of Actions Taken bv' the 1.icensee to Determine the Quality of
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Comcleted Construction Work Many construction deficiencies 'have been identified by the licensee during he cencuct of the QCP and other quality reviews and repcrted to i
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, ~ the NRC pursuant to 10 CFR 50.55(e) which could have been prevented or identified in a timely manner by the licensee and its contractors had there
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been a prop'erly managed QA program. Major construction deficiencies identified to da'te by the quality reviews are listed in order of identification and include the following:
Selds perfor=ed using an unqualified welding precedure for welds greater i
1L than 0.854 inches.
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L Unauth'eri:ed stampir.g of fittings and use of "high-stress" stamps.
ASME structural weld and welder qualification deficiencies.
Welds performed and welders not qualified for weld thickness range per ASME requirements.
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Approx,imately 2400 feet of small bore piping identified with questionable heat treatment.
Welder qualifications with a substantial number of documentation discrepancies.
Carson steel weld red may have been used for a portion of several stainless steel recirculation line welds.
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Electrical cable tray installation and inspection d2ficiencies.
Hangehs installed for the control rod drive system are of indeter=inate quality.
Both weld and radiograph quality deficiencies for sacrificial shield welds and radiograph deficiencies identified for the containment monorail and the ventilation stack.
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Deficiencies in the H. J. Xaiser procurement program for structural stetl and other materials.
Inadequate design control by Sargent & Lundy (architect engineer) for electrical separation,
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Inadequate weld preparation prior to radiography (ripples not removed)
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which caused masking of discontinuities in some welds.
Reactor control, reactor protection, and neutron monitoring panels, including field installed wiring do not, in some cases, conform to design drawings with regard to cable separation.
Inadequate engagement of "gama plugs" in large-bore piping and lack of heat number traceabil'ity of the "gama plugs."
(During radiography of a pipe weld, a gamma so'urce is sometimes inserted through a small L
hole in the sida of the pipe. After radicgraphy the hole is plugg:d
...i to provide a pressure. boundary.)
a Inadequate inspection program and installation precedures for "Nelsen stud" installation for cable tray hangers.
Concrete and steel coating program not in accordance with the QA Program and the Sargent & Lundy specification requirements.
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Design changes made to the Fire Protection System piping in the cable
, spreading rocm in 1979 were inadequately centrolled.
i The Sargent & Lundy (architect engineer) dynamic stress analysis of small
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bore piping is questionable.
l Cable separation problem with regard to divisien separation between ncn-essential cables being bundled with essential cables of different-divisions.
Pipe support installation precedures did not.contain seismic. clearance criteria between pipe supports and cable trays or conduit and associated supports as required by the specification.
These deficiencies represent 'those which the staff censiders most significant.
There were additional 10 CFR 50.55(e) reports made by the licensee and the licenses has identified a large number of l
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' none nfor=anc:s (which could reficct constructicn or other typ;s of deficiencies).
As of September 30, 1922 the licensee's c:ntinuing quality
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c nfir=aticn pr: gram reviews had identified approximately 4,200 none:nformances of which about 8'00 have been "dispositiened", i.e., the licenses had made a determination as to resolution.
(InspecTicn Report !!o. 50-353/82-12, report pen' ding.) The large nu=ber of noncemfor=ance reports and the significance of the matters being identified corr barate the staff's 1981 finding of significant breakdown in the licensee's quality assurance program.
B.
Findines Subsecuent to Licensee Actiens Taken to Correct 0A Failures and Prevent Recurrence Since the Immediate Action-Letter was issued on April 8,1921 and quality
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assurance and management deficiencies were brcught to the attentien of the licensee, hardware and pr grammatic QA/QC problems have been identified i
by the NRC and the National Board of Boiler and Pressure Yessel Inspecters.
These problems are discussed in the following paragraphs and indicate the licensee and the constructor are still having difficulty implementing satisfactory QA/QC programs:
During an inspection c:nd'ucted the latter part of 1981 and the early part of 1982 (Inspection Report No. 50-358/82-01, issued on June 24, 1982) three items of nonccmpliance were identified.
The findings con-
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carned (1) the failure to clearly establish and document the authorities l
l and duties of all QA Department persennel, (2) the failure to pr: vide
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acequate certification of qualifications of all QA Depart =ent personnel, and (3) the failure to provide adequate procedures.
Tne licensee failed to adequately address the provisions of Regulatory Guide 1.53 (ANSI-N45.2.5-1973) concerning personnel in the QA Department.
Additionally, inadaquately qualified personnel were reviewing and approving quality j
procedures controlling electrical activities, which contained deficiencies.
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Furthermore, as a result of the licensee reviews it was revealed that sc=e weld inspectors involved in the QCP Task I, Structural Steel, were not adequately certified and the task was stopped.
The task was restarted following upgrade of the inspectors through training provided by additional
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certified ' weld ' inspectors.
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During an inspection conducted in March and April 1982* (Inspection Report No. 50-25S/82-05, issued on July 1,1982) two ite=s of noncompliance were
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identified.
The findings concerned the lack of implementation and timelf-j ness of corrective actions add the failure to adequately review and document potentially reportable matters.
i During an inspection conducted in April, May, and June of 1982 (kspection J
Report No. 50-358/82-06, issued on November 2,1982) two items cf noncom-pliance were identified. The findings concerned (1) the performance of j
quality activities required.of the welding engineers by inadequately cualified clerks and. (2) the failure to perform required calibrations 1
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1 during a critical. quality activity, Induction Heating Stress Improvement (IHSI) program.
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s A recent inspection conducted during June and July of 1982 (Inspection Repor: No. 50-25S/82-10, report pending) identified a number of sign-ficant concerns.
These concerns were discussed with the licensee on 1
July 9, July 15, August 15, and October 19, 1982.
Foursignificantit5Ns of concern (potential items of noncompliance) were identified:
(1) tne inadequate control and documentation of welder qualifications; (2) the failure to take corrective actions following the identification of inadequata records to support welder qualifications; (3) the unauthori:ed correction, supplementation, and alteration of quality records; and (4) the failure to follow procedures controlling weld filler metal control, logging and control of requests for information/ evaluation, and imposition of r
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reporting requirements en contractors.
The NRC findings concerning
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welder qualifications resulted in the requalification of approximately 100 active onsite welders and the need for the licensee to develop a t.
program to evaluate the previous work of the welders whose qualifications were not adequately documented.
~ An inspection was conducted following notification of the Region III Office that a CG&E Stop Work Order (SWO) had been initiated on August 5, 1982, pertaining to Catalytic, Inc. (CI) activities in the area of the contr'el red drive system hangers and supports.
C! is a contractor of the licensee performing construction work l
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including rework activities identified by the QCP program.
During this inspection conducted during August and September of 1982 (Ir.spection Report No. 50-353/82-13, report pending), significant c:ncern's were identified regarding the implementatien of CG&E's quality assurance program and its management program established to control and monitor the activities of Catalytic, Inc. (CI).
The c:ncerns involved the areas of (1) the description of organi:atien i
and functional interfaces, (2) training of CI personnel, (3) design I..
centrol measures, (4) precedure content and imple=entation, (5) dccument centrol, (6) inspection and surveillance activities, (7) nonconforming conditions (8) corrective actions, (9) rec:rds, and (10) audits.
The findings, were discussed with the licensee on August 12, September 10 and,17, and Oct:ber 19, 1982.
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As a result of the inspection findings and subsequent discussions with the licensee, Step Work Orders were issued by the licensee, stopping all
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essential work by CI en ' October 11, 1982, pending resolution of the pr:grammatic problems identified by the NRC and licensee reviews.
The licensee has initiated Stop Work Orders in addition to those
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affecting CI due to inadequate quality assurance in the areas of
. application of coatings (Oct:bar 12,1982), electrical cable installa-tion (October 12,1982), and special process procedures (November 1, 1982). The Stop Work Orders involve ongoing ~ activities. The Novem-ber 1,1982 Step' Work Order involved precedures not meeting require-ments notwithstanding that the procedures had been specifically
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reviewed by CGLE for adequacy subsequent to the issuance of the April 8,1981 Immediate Acticn Letter.
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Additionally, during the week of October 10, 1952, the Authorized Nuclear Inspector (ANI) for the N-sta..p holder (H. J. Kaiser) recalled ASME work pac'kages then being used in the field because of the per-for:.ance of ASME code work (hanger attach =ent remeval and piping cutcuts) was outside the approved QA Program precedures. The ASME
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cede work was being centrolled and perfor=ed utilizing an H. J.
Kaiser administrative memo which bypassed the ANI's required involve-ment in the code activities.
The NRC was apprised of the required ccrrective actions during a meeting involving CGiE and H. 'J. Kaiser on October 15, 1932. The corrective actions taken and planned were censidered acceptable;by the Authori:ed Nuclear Inspecter.
t-The National Board of Boiler and Pressure Vessel Inspectors, at th'e
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request of the State of 0hio, have been ensite since March 1,1982.
The National Board has issued three interim reports documenting findings regarding ASME code activities.
The National Board findings include deficiencies in the following areas regarding on-going ASME
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code activities:
design control, procurement, procedures, special processes, nonconfaming conditions, and corrective actions.
The findings are generally censistent with past and present NRC findings.
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Rework Activitics.
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a As a result of the infomation obtained frem the licensee's reviews of
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plant quality, the licensee is proceeding, prior to cc=pletion of the relevant QCP tasks, to initiate rework activities.
A major example of rework activities is the area of structural steel welding. The feinspecticn and rework of structural steel welds located in a number iof areas of the plant have been in process for a number of menths.
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' Approximately 70 percent of the structural welds are being reworked to make the welds acceptable.
In the case of these welds, rework is being
. undertaken prior to the c:=pletion of the quality reviews to detemine,
the acceptability of all st,ructural steel welds and beam / hanger materials.
The rework of these welds prematurely may result in the addition of new weld material over unacceptable weld material or
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beam / hanger materials.
Follcwing c:mpletion of the quality reviews unac-captable areas may require additicnal rework activities.
This approach
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to rework activities indicates a lack of a comprehensive management program to address rework activities and the safety impact of those activities on the facility.
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III.
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The foregoing information indicates that:
- 1) the Zimer facility has l
been constructed without an adequate quality assurance (QA) program to govern construction and to mo'nitor its quality, resulting in the l
censtruction of a facility which currently is of indeteminate quality; l
- 2) substantial efforts are underway to detemine the quality of past c:nstruction activities and numerous construction deficiencies have been t
c, identified and are centinuing to be identified such that both reena?ysis and rework will be required 2c bring the facility inte ccnfomance with the apalication and regulatory standards on the basis of which the construction permit was originally issued; and 3) rework of deficiencies identified by the Quality Confirmation Prcgram (QCF) has been undertaken prior to ecmpletion of other relevant QCP tasks and other reviews, resulting in the potential for additional reworking of the same item if further deficiencies are fcund, as has been the case, by the quality reviews.
Consequent.y. the NRC presently lacks ' reasonable assurance that the Zi=er plant is being constructed in conformance with the ter=s 1
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1 of its ecnstruction permit and 10 CFR Part 50, Appendix 3, and that there is adequate management centrol over the Zi=er prcject te ensure that NRC requirements are being met.
The verificat' ion of the facility's quality and apprcpriate actions U
te ccrrect deficiencies in ccastruction are of utmest importance to the-(
public health and safety should the licensee receive a license to operate the facilit:.. Moreover, the licensee must be in a position to assure that its construction activities have been properly carried out in accordance with Ccmission requirements, as the Cemission inspecters
' are not able to personally verify every individual aspect of construction that may impact on safety.
In view of the importance to safety of construction verification and corrective actions and the past pattern of quality assurance d'eficiencies, the Comission has cencluded that safety-related construction, including rework activities, should be suspended until there is reascnable assurance that future'ccnstruction activities will be apprcpriately managed to assure that rework activities and all other ccnstructicn activities will be ccnductad in a
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acccedance with 10 CFR Part 50, Appendix B, and ether Ccemi:sion requirements. The Comission has further determined that in light of the foregoing "censiderations the public health, safety and interest require suspension of construction, effective imediately pending fyrther autheri:atien.
IV.
.e Acccrdingly, pursuant to sections 103, 1511, 182 and 185 of the Atemic Energy Act of 1954, as amended, and the Cemission's regulattens
.in 10.CFR Parts 2 and 50, IT IS HERE3Y ORDERED THAT:
A.
Effective imediately, safety-related constmetion activities, including rework of identified deficient ccnstruction, shall be suspended.
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B.
The licensee shall shew cause why safety-related'constructicn activities, including reworking activities, should not remain suspended until the'l_icensee:
(1) Has obtained an independent-review of its management of the Zimer project including its quality assurance program and its quality verification program, to detennine measures needed to ensure that construction of the Zimer plant can be ccmpleted in conformance with the Cc mission's regulaticns and construction pennit.
(a) The independent organi:ation. conducting this review shall be kncwledgeable in QA/QC matters and nuclear plant I
construction and shall be acceptable to the Regicnal Ad=inistrater.
The independent crgani:atica shall make
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recommendations to the licensee regarding necessary staps g
to ensure that the construction of the facility can be ccmpleted in conformance with the Ccmission's regulations and the construction permit.
A copy of the independent organization's rec:::rnendations and all exchanges of correspondence, including drafts, between the independent organization and CGLE shall be submitted to the Regional Administrator at the same time as they are submitted to the licensee.
In' making recomendations, the independent organi:ation shall consider at a minimum' the following alternatives for maiiagement of the Zimer project and shall weigh the advantages and disadvantages of each alternative:
k 1.
Strengthening the present CG1E organi:stion.
2.
Creation of an organi:ational structure where the construction management of the project is c:nducted by an experienced outside organi:ation reporting to the chief executive officer of CG&E.
3.
Creation of an organizational structure where the quality assurance program is conducted by an experienced outside organi:ation reporting to the chief executive officer of CG&E.
4..
Creation of an organi:ational structure with bcth quality assurance and c:nstruction project management c:nducted by an experienced cu: side
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organization reporting to the chief executive s
officer of CG&E.
(b) The licensee shall submit to the Regional Administrator the licensee's recor= ended course of action on the basis of this independent review.
In evaluating the f
T recomendations of the independent organization, the g,
licensee shall address why it selected particular alternatives and rejected others. The 1icensee's recomendations and its schedule for implementation of those recomendations shall be subject to approval by the RegionalAd.kinistrator.
(2)
Followiiig the Regional Administrator's approval in accordance withsectionIVB(1)(b),
(a) Has submitted to the Regional Administrator an updated comprehensive plan to verify the, quality of construction e(
of the Zimrfer facility and the Regional Administrator of NRC Region III has approved such plan.
In preparing this updated comprehensive plan, the licensee s' hall review the ongoing Quality Confirmation Program to determine whether its scope and depth should be expanded in light of the
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hardware and programatic problems identified to date.
The updated plan shall include an audit by a qualified outside organization, which'did not perform the act.ivities being audited, to verify the adequacy of the quality of construction; and o
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(b)
Has submitted to the Regional Administrator a ecmprehen-sive plan, based on the results of the verification prcgram, for the ccntinuation of construction, including reworking activities, and the Regional Acministrater has confir=ed in writing that there is reasonable assurance t'
that construction will proceed in an orderly manner and will be conducted in accordance with the requirements of the Cc=nission's regulations and be Constructicn Permit No. CPPR-88.
(3)
The RegTonal Administrator m:y relax all or part of the
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conditions of section IV.B fsr resumption of specified construction activities, pro ided such activities can be conducted in accordance with the Ccm.ission's regulations and the provisions 6f the construction permit.
V.
Within 25 days of the date of this order, the licensee may show cause why the actions r'acribed in section IV should not'be ordered by filing a written answer under oath or affirmation that sets forth the matters of fact and law on which the licensee relies.
As provided in 10 C.R 2.202(d)..
the licensee may answer by consenting tc the order preposed in secticn IV.
of this order to show cause.
Upon the licensee's consent, the ter=s of
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.r sectico IV.3 of this order will become effective.
A1:ernatively, the licensee, may request a hearing on this order within 25 days after the issuance of this order.
Any request for a hearing or. answer to this order shall be submitted to the Secretary, U.S. Nuclear Regulat:ry Cemission, Washington, D.C.
20555.
A copy of the request or answer
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ihall also be sent to the Director, Office of Inspection and
, Enforcement, and to the Executive 1.egal Direct:r at the same address, a.
and to the Regional Administrator, NRC Regien III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137.
A request for a hearing shall no: stay the im=ediate effectiveness of section IV.A of this Order.
If the licensee c'e' quests a hearing on this order, the Cemissicn will issue an order designating the time and place of hearing.
If a~ hearing is held, the issues to be censidered at such a hearing shall be whether
- r the facts set forth in sections II and III of this order are true and L.
whether this order shculd ie sustained.
Ccmissioners Ahearne and Roberts dissent frem this decision.
Their dissenting views are attached.
It is so ORDERED.
For the Cc: mission
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g~JennC.Mcyie Acting Secretary of the Cc:=ission
- J Da:ad at Washing::n, D.C.
this 12:n day of November,1982.
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D'I S S z21 T ! :G W r J S O F C O F_M I S S I O N I ?. A " U.:TI
...c I agree with both the substance and the direction for change I
described'in this c dar.
Ecwever, I would have si= ply issued a Show'Cause Order and would not have made it d -a-diatelv. effective.
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DISSENTING VIEW OF COMMISSIONER ROBERT 3
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I disagree with the action taken by the Cc=ission majcrity en several grounds.
First, I believe the Cc=nission's acticn in ic=:ediately suspending construction at the Zimer facility is precipitous.
Earlier this year, Cincinnati Gas and Electric Ccmpany (CG&E) made substantial changes in its management structure in order to manage more effectively construction activities and to monitor more carefully quality assurance pro, gram:.
Despite the fact that this new organi:ational structure is relatively' untested, the Cc=ission is new suspending effective immediately all constraction and corrective actions at the site.
Addi-tionally, the NRC Staff admits that CG&E's enhanced Quality Confirmation Program (OCP) and large quality control staff is effectively identifying existing construction' problems.
Morecver, to the extent that actual censtruction deficiencies have been found, CG&E's management has damen-strated its willingness to take strong remedial acticns by' issuing step work orders in these areas where censtruction deficiencies have been i
- fcund.
In'a plant that is approximately 98 percent ecmplete, the Ccemission is recuiring the relatively few remaining construction activities and the ongoing corrective actions necessitated by the QC? to step ic:nediately while additional organi:ational changes are imple-mented.
Second, I believe the Ccanission's action does not ccepert wi'th its cwn practice.
In Licensees Authoriced to Possess... Scecial Nuclear Materials, CLI-77-3, 5 NRC 15, 20 (1977), the Cem=ission said that
"[a]vailable infor=atien must demenstrate the need for (such] emergency
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I'acticns and the insufficicncy of less drastic meesures" (em;:hasis added).
See aise Consumers Power Co. (Midland Plant, Units 1 & 2),
C!.I-73-38i 6 AEC 1082, 1082 (1973).
I believe that, in this case, scme of the less. drastic alternatives proposed by the Staff would be adequate resclve the problems at this faci,lity.
For example, the Cc. mission t:
cculd send CG1E a letter indicating that at this time the Cemission dces not have sufficient information to conclude that Zir=er has been i
c nstructed in substantial c:nformance with the c:nstructicn permit.
T E O=issicn eculd recuest the provisien of infor=ation on the part of 4
CG&E which, if available, would provide the Ccmiss{an with the neces-sary assurance.
See 10 CFR 50.54(f).
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Third, in the absence of willfulness, the Commission may suspend c:n-stmetien effective li:=ediately in accordance with Secticn 9b cf the
{D Ac.:inistrative Precedures Act and the Cc. mission's regulations only if the Cc=issien finds that the public health, safety, or interest re,-
r, quires such acticn.
I do not believe that the concerns listed in -the Ccmmission's Order shew that'the public health and safety requires imme-diate suspensien of all construction and corrective actions at the Zimer site.
Indeed, Mr. James Keppler, the Region III Adninistrator, has stated that CG&E's OCP has been successful in identifying existing construction problems.
Transcript of Public Meeting on the Status of Zir:.er, October 28, 1982 at'5.
Additionally, most of the NRC inspecticn findings arising cut of the QCP point to administrative or precedural deficiencies, rather.than to actual material or construction errors.
While the NRC's level of confidence in the adecuacy of the plant L
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- *!.ccnetruction has been reduced, it has not bnen shewn by the NRC that problems exist which require i=ediate resolution to protect the public h
health and safety. Moreover, I do not believe this actien is in the public interest.,
I am also cencerned that the Order has been approved without considera-tion fer the Applicant's pr posal to correct management and construction f
problems.
That proposal, outlined in a letter to the Cc=issioners l
dat,ed November 10, 1982, centained all of the essential elements approved by this Order.
Specifically, the proposal calls for cbtaining new project management, stopping all rework on quality confir::ation matters, and an independent third party review to confirm the acceptability of seier:ed safety systems.
In view of the voluntary agreement by CG&E to such drastic measures, I feel that this Order is primarily punitive in and does littke to correct problems in the interest of public
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natur) h'ealt1 and safety.
Finally, I disagree with the Ic=ission's Order because of the potential for delay inherent in this procedure.
CG&E has an absolute right to a hearing en the Cc=ission's Order.
If CG&E avails itself of this right, then other " interested persons will be entitled to de :and a hearing.
Once started, the hearing would be difficult to bring to an expedit'.cus close.
Even if the Staff and CG&E were to reach agreement on the corrective actions to be taken, litigation of the requirements imposed by the Cc=.ission Order would continue.
Censume-s Pcwer Co. Utidiand-l Plant, Units 1 & 2), ALAB-315, 3 NP.C 101 (1976); Dai-vland Pcwer C:e:erativa (Lacrosse Soiling Water.teactor), L3P-El-7,13 NRC 257,
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l 25a-65 (195.i.
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