ML20082E814
| ML20082E814 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/18/1983 |
| From: | Williams J CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082E801 | List: |
| References | |
| LOZ-83-0233, LOZ-83-233, NUDOCS 8311280329 | |
| Download: ML20082E814 (70) | |
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THE CINCINNATI GAS & ELECTliIC COMPANY d2 CINCINN A.TI.CMIO 452ot J. WtLU AM S, JR
... . es ...ocar November 18, 1983 -
vetc....... .. .
10Z 0233 Docket No. 50-358 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J.G. Keppler Regional Administrator Gentlemen:
RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 COURSE OF ACTION W.O. 57300, JOB E-5590, FILE NO. 956C, During the November 1, 1983 public meeting on the Zimmer Course of Action, th e' NRC raised several questions with respect to the scope of the Plan to Verify the Quality of Construction (PVQC) of Zimmer and the extent of the inspections of hardware under the PVQC. This letter is to provide you with additional information with respect to these matters.
The scope of the PVQC will encompass all safety-related structures, systems, and components (SSCs). Sargent & Lundy (S&L) is preparing lists which classify all such SSCs. Additionally, where CC&E FSAR commitments have made other SSCs subject to a formal quality program, these additional items will be evaluated within PVQC. Such items include compon ints that are non-safety related but are required to be Seismic 1 (e.g., nonsafety cocponents routed on tr, of safety-related components) and portions of the fire protection system.
The acceptance criteria for evaluating these installations will be provided by '
S&L.
The PVQC will consist of four main inspection and documentation review activities, which may be conducted concurrently or in sequence, depending on the SSC to be verified. These activities are (1) visual insoections of as-constructed SSCs, (2) physical inspections of as-constructed SSCs, (3) reviews of documents associated with the purchase and supply of fabricated or manufactured materials and equipment, and (4) reviews of documents associated with the site fabrication and installation of SSCs. Following these activities, the individual SSC's will be statused as conforming, nonconf orming _
or incomplete. Then, on a sampling basis, confirmatory physical inspections of confor ning SSCs will be performed.
8311280329 831121 DR ADOCK 05000358 PDR
s-Page 2' Visual inspections will be conducted on the accessible portions of each SSC.
These visual inspections will identify and record existing identification
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numbers on material and equipment, dimensions, configuration, and other attributes required by design drawings and' specifications that can be observed
-without special tests or equipment. Visual inspections will provide data which will be used to identify SSCs that are conforming, nonconf orming, or incomplete ,with respect to visual attributes.
The type of visual inspections to be conducted will vary depending upon the type' of SSC being inspected. - Examples of typical visual inspection activities are included in Attachment 1. . These visual inspections will be defined and controlled by quality _. verification instructions and checklists. - For example, visual inspections will include, but will not be limited to, the followirg:
o Piping / mechanical - Visual inspection will be performed on piping ,
valves, welds, pumps, supports, snubbers, restraints, and hangers, o Electrical - Visual inspections will be performed on exposed conduit, trays and wiraways, supports, welds, junction boxes, penetrations, busses, cables, panel boards, motors, and motor control centers, o Civil : Visual inspections will be performed on concrete structures, penetrations, soils, anchor bolts, embedments, and painting.
o - Structural - Visual inspections will be performed on steel structures; galleries, ladders and stairs; equipment supports; bolting; welding;'and special doors'.
o HVAC - Visual inspections will be performed on ducts, vents, and dampers; supports; and fans and blowers.
o Instrumentation - Visual inspections will be performed on tubirg, supports, and instrumentation.
Physical inspections of SSCs will be performed as necessary. and appropriate to inspect nonvisual attribute requirements of design drawings and -
specifications. In general, these attributes can only be confirmed by using special tests and equipment performed by specially trained and qualified inspectors. The type and number of examinations will be based on engineering
-judgement and analysis of the severity of possible deficiencies and will focus on SSC's without adequate supporting docismentation and areas where potential-
' problems have been identified. The engineering judgements and analyses will be documented in accordance with project procedures. Areas to be physically inspected include:
(1) Items identified in the Report of the NRC Evaluation Team on the Quality of Construction at the Zimmer Nuclear Power Station, NUREG
- 0969.
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(2) Items identified in the reports of the National Board of Bsiler .
and Pressure Vessel Inspectors, NRC inspection reports and items in public allegations now on file.
(3) Areas that have been the subject of extensive or significant nonconformances identified by the quality confirmation program and in 10CRF 50.55(e) reports.
(4) Those portions of the SSCs where documentation reviews identify the absence or inadequacy of a required inspection.
(5) Those portions of the SSCs known to be inaccessible.
(6) Confirmatory physical inspections on conforming accessible SSCs.
(This physical inspection is performed af ter the statusing activity discussed below.)
Physical inspections will provide data which will be used to identify items that are conforming or nonconforming. The type of physical inspections to be conducted will vary depending upon the type of SSC being inspected. An overall program to identify and evaluate physical testing methods has been developed for the project. Bechtel, as consultant to CG&E, is currently evaluating several advanced non-destructive inspection methods for their applicability to Zimmer. The results of these evaluations will be available to the NRC as progress is made. Physical inspections will be defined and controlled by quality verification instructions and checklists. Examples of typical physical inspection activities are included in Attachment 2, with additional detail for ASME embedded or buried pipe, concrete structures, and electrical equipment given in Attachment 3. For example, physical inspections will include, but will not be limited to, the following:
o Bolting will be physically inspected for tension and torque, o Welding (Piping) will be physically inspected by means of nondestructive examination, destructive examinations, mechanical
, tests, and chemical analysis.
o Material Traceability (Piping) will be physically inspected by means of physical analysis and chemical analysis, o Cable and Terminations will be physically inspected by means of megger tests, hi pot tests, and resistence tests, o Motors will be physically inspected by means of megger tests and polarization index tests.
o Concrete will be physically inspected by strength tests on core samples and destructive testing at selected locations.
Paga 4 In addition to visual and physical inspections, a review will be made of documentation for material and equipment and of construction installation documentation for each SSC. This review will identify documents that are deficient, missing, or which otherwise do not conform with requirements for use in verifying the quality of construction. Documents which are acceptable will be reviewed to provide data used to identify it' ems conforming, nonconforming, or incomplete.
The data generated by the visual and physical inspections and documentation reviews will be evaluated by Bechtel PVQC personnel. This evaluation will identify and status each SSC as:
o Conforming items - A conformance will exist only if the documentation review indicates that the item conforms, and if the visual inspection for each accessible item indicates that the item conforms, and if any physical inspection for the item indicates that the item conforms, o Nonconforming items - A nonconformance will exist if the documentation review indicates that the item does not conform, 39; if the visual inspection for an accessible item indicates that the item does not conform, jg; if any physical inspection for the item indicates that the item does not conform. .
1 o Incomplete items - An item will be incomplete if an analysis of the documentation review and the visual inspection indicates tha t required construction or inspection activities have not yet been performed.
Sampling will be utilized to perform confirmatory physical inspections on conforming SSCs. These inspections will be perfonned as outlined above and I' will be of sufficient numbers and types, based upon statistical analysis to -
provide confidence that the relevant items are, in fact, conforming as indicated in the documents.
Procedures will be developed under the PVQC which will govern the sampling plan for confirmatory physical inspections. In general, the sampling plan will rely upon industry-accepted techniques and will vary depending upon the type of items being inspected. For items that are accessible or require ,
nondestructive testing, the sampling plan will provide for inspection by attributes, using predetermined acceptance quality levels and lot tolerance i
percent nonconformance for control of acceptance or rejection of a lot. For items that are inaccessible or require destructive examination, the sampling plan will provide for inspection by variables, utilizing results of physical ,
inspection on accessible items or performing random sampling and using ,
engineering evaluations and judgement regarding severity to establish the confidence level for the remainder of the lot. Based on the results of the ;
inspection results, lot sizes may be expanded.
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It may be noted that statistically-based sampling has been employed in various '
verification programs fer other nuclear projects and is a valid verification technique. The confirmatory physical inspection program will not constitute the first-line verification of the quality of an SSC, but instead is intended to provide added confidence that the quality of an SSC is accurately indicated by existing documentation. It is not necessary to conduct 100% reinspections to provide a sufficient level of confidence that the existirs documentation correctly identifies the quality of construction.
In summary, the PVQC will include visual inspections to determine the as-constructed status of each accessible SSCs'; reviews of documents associated with the materials and ccustruction installation of each SSC; and a program of physical inspections based upon statistical analysis. Toge ther, these activities comprise a comprehensive plan designed to verify the quality of construction and identify conformances, nonconformance, and incomplete work.
I trust that the above description of the PVQC will provide suf ficient information to complete your review of the Course of Action. The verification program will be described in much detail in the PVQC Program which will be 2
e submitted to the NRC for review and approval.
Very truly yours, t
THE CINCINNATI GAS & ELECTRIC COMPANY I
. IOR VICE PRESIDEN t
ec: NRC Office of Inspection & Enforcement Washington, D.C. 20555
, NRC Resident Site Supervisor i ATTN: W.M. Hill NRC Zimmer Project Inspector, Region III ATTN: E.R. Schweibinz NRC Office of Nuclear Reactor Regulation Division of Licensing
. ATTN: D.G. Eisenhut L.L. Kintner my G
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Prie 1 of 14-ATTACHMENT 1 ,
TYPICAL VISUAL INSPECTION' ACTIVITIES SSCs identified on the approved Q-list will be subject to visual.
inepections. The visual inspections will be performed on accessible SSCs. The essential attributes will be defined by the responsible designer. The following are typical' visual inspection attributes.
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Piping / mechanical Large bore piping Elevation, size, slope, heat numbers, welding, welders identification, line/ spool identification, code data nameplate identification (when required), visual damage
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Visual / measurement Small bore piping Elevation, size, slope, heat numbers, welding, welder identification, line/ spool ,
identification, code data nameplate identification (when required), visual damage Visual / measurement
. Valves and operators, Elevation, size, position indicators location, valve type, flow direction, bolts (if ilanged), gaskets, welding (if welded),
welder identification, heat numbers, manufacturer, position indicator (open/ closed) .
packing, alignment, .
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Page 2 of 14 ATTACIOiENT 1 (Continued)
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC operator manufacturer and type, operator stem orientation, nameplates, tag number Visual / measurement Pumps, gear b' oxes, Elevation, size, and couplings location, type, direction of rotation, manufacturer, heat numbers, motor manufacturer and type, welding (if welded),
bolting, gaskets, alignment, nameplates, gear box type, gear box
( manufacturer,' gear box lubrication, coupling type and fit, tag numbers Visual / measurement Hangers Elevation, size, location, type, welding, welder identification, shims, bolting, thread engagement, identification, spring loading (as applicable) pipe clearance, clamping to pipe Visual / measurement
Page 3 of 14 ATTACHMENT 1 (Continued)
Attributes and Characteristics Subject to Visual inspection Plant Area SSC Within Each Area Under PVQC Supports Size, location, elevation, welding, velder identification, anchor boit type, anchor bolt size, c2amping, thread engagement, heat numbers, identification Visual / measurement Snubbers Size, location, elevation, type, manufacturer, setting, bolting, welding, welder identification, leakage, fluid levels, identification Visual / measurement Restraints Size, location, elevation, welding, welder indentification, placement, fit, bolting, thread engagement, identification Visual / measurement NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented.
Page 4 of 14 ATTACHMENT 1 (Continued)
Attributes and Characteristics Subject _
to Visual Inspection Plant Area SSC Within Each Area Under PVQC Electrical Exposed conduit Size, material type, visible damage, routing, bend radius, smoothness, number of bends, distance between pull points, ground connection, fittings, bushings, Seismic II/I criteria, identification, end seal af ter cable installation, channel separation Visual / measurement Trays and wireways Size, material, type and
(' construction, identification, routing, proper fittings, grounding, dropouts and spillovers, covers and mounting, splice types, and visible damage
- Visual /measu,rement Supports Type and configuration, spacing or location, material type, welding, f
welder identification (when required),
concrete expansion anchors and connections, identification (when required), and visible damage Visual / measurement d
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Page 5 of 14 (N' ATTACHMENT 1 (Continued)
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Junction boxes Size and type, location, orientation, identification (when required), mounting, i connection to conduit, and visible damage Visual / measurement Penetrations Identified and installed at correct location and elevation, proper bolting and thread engagement, protection of machined surfaces (if not closed), proper orientation, and visible
() damage.
Visual / measurement Busses Identification, proper support, routing, ,
configuration, connections made, no oxide grease used (when required), boots, clearance to conduct,1ve materialisaintained, and visible damage Visual / measurement Cables Type, scheme identification, correct termination point, routing, channel separation, clamping, bundling, proper lugs and connectors used, -
- conductor insertion into lug, preper crimp, r-
Pege 6 of 34 7, ATTACHMENT 1 (Continued) --
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Attributes and Characteristics Subject to Visual Inspection -
Plant Area SSC Within Each Area Under PVQC conductor and insulation undamaged, bend radius, support, insulation or stress cone installed, termination tight .
Visual / measurement Panel boards Identification, location, mounting, grounding, shipping
, splits properly joined, internal interconnections completed, expansion anchors, welded attachments, and visible damage.
Visual / measurement Motor control centers Identification, location, mounting, '
grounding, shipping splits properly joined, interconnecting junpers installed, bus bars connected, welded attachments, concrete expansion anchors, and visible damage Visual / measurement
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{_ ATTACHMENT 1 (Continued) -'
Attributes and Characteristics Subject to Visual Inspection.
Plant Area SSC Within Each Area Under PVQC Motors Mounting, identification, location, shaft rotation and lubrication, and visible damage -
Visual / measurement O
NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented.-
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ATTACEMENT I (Continued) -
Attributes and
- Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area ' Under PVQC Civil Concrete structures Location (line and grade), voids,
, honeycombs, embedded debris, form mismatch, surface irregularity, exposed rebar, column size and location Visual / measurement Penetrations Location, azimuth and elevation, envelope i
dimensions, identification j (mechanical), visible damage, welder identification, weld
(]) . number, weld quality, material type, displacement / distortion, and concrete Visual / measurement Soils Type, estimated sieve analysis for gradation, organic and inorganic debris, moisture content, grade Visual / sample Anchor bolts Size, grade, type material, orientation, location, identification, visible damage, full thread
} engagement , grouting i
- Visual / measurement l
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Page 9 of 14
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("N ATTACHMENT 1 (Continued) '
Attributes and Characteristics Subject
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to Visual Inspection Plant Area SSC Within Each Area Under PVQC Embedments Elevation, location, orientation, identification, bolt hole locations (when bolted), grouting, -
envelope dimensions, visible damage Visual / measurement Painting / preservation Dry film thickness (spot check) on steel, holidays, runs, sags, pinholes, crazing, texture, color match, coating material
() Visual / measurement I
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l l NOTE: The above-listed attributes / characteristics are typical of those l to be reviewed / evaluated. The listing is not intended to be complete, '
and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented.
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Page 10 of 14
( ATTACHMENT 1 (Continued)
Attributes and .
Characteristics Subject .
to Visual Inspection Plant Area SSC Within Each Area Under PVQC l Structural Steel structures Size, type, location, l welding, velder ,
l identification, bolting, thread engagement, hole location, copes, length, heat numbers (when applicable), visible damage l
Visual / measurement
- Galleries, ladders, stairs Size, type, location, l fabrication, bolting type, size and thread engagement, velding, configuration, material, grouting (when
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required), mark numbers l
(when applicable), and visible damage Visual / measurement
, Equipment supports Size, type, location,
! bolting type, size and l thread engagement, velding, welder identification (when required), support contact, grouting (when required) l identification, visible damage l
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Visual / measurement 1( o
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Pegs 11 of 14
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ATTACHMENT 1 (Continued)- -
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Bolting Location, diameter and length, type, proper thread engagement, washers, hole size, number of bolts, visible damage, configuration Visual / measurement Welding Location, size, type, weld and welder identification (when required), code acceptability, visible damage Visual / measurement (h j Special doors Location, size, type, hinges, locks, assembly, identification, visible damage, freedom of operation Visual / measurement NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, sud/or substitutions necessary as the PVQC is implemented.
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( '- ATTACHMENT 1 (Continued)
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Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC HVAC Ducts, vents, and dampers Size, location, elevation, routing, identification, joint configuration, type, gasketing, visible-damage, coating (as applicable), envelope dimensions Visual / measurement
. Supports Size, location, method of attachment (weld size and type, code weld
' acceptance, bolting size and type, thread engagement), clearances,
( f- coating application (when applicable) -
visible damage Visual / measurement Fans and blowers Size and type, mounting, location, connection to ducting, tag number identification, rotational freedom and direction, protection, visible damage, motor size and rating Visual / measurement NOTE: The above-listed attributes / characteristics are' typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there Lay be additions, deletions, and/or substitutions necessary as the PVQC is implemented. -
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Page 13 of 14 ATTACID.'ENT 1 (Continued)
Attributes and Characteristics Subject to Visual Inspection Plant-Area SSC Within Each Area Under PVQC Insulation Structural Location, material thickness, adhesion Visual / measurement Equipment / components Location, identification, material' type and thickness, adhesion, protective covering (when required)
Visual / measurement Piping Location, size, pipe identification, type and thickness, adhesion, protective covering
) (when required)
Visual / measurement l
l l
l NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not incended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented h
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- Pzga 14 cf 14 f' ATTACHMENT 1 (Continued) -
. Attributes and Characteristics Subject to' Visual Inspection Plant Area SSC Within Each Area Under PVQC Instrumentation Tubing Size, type, material d type, routing, radii, connections (nuts
- fitting, velds), line marking, smooth bends (no flat spots), and -
visible damage Visual /measursment Supports Type, size, mounting type and location, inserts, fit to tubing / welding, and/or bolting acceptable, and visible damage Visual / measurement
(])
Instrumentation, recorders, Location, indicators, alarms, etc. type, recorders, identification, connection to tubing / supports, '
mounting, flow directions, visible damage, and protection Visual / measurement NOTE: The above-listed attributes / characteristics are typical of those to be reviewed'/ evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented.
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Page 1 of 3 ATTACHMENT 2 -
EXAMPLES OF CONFIRMATORY PHYSICAL INSPECTIONS I
AREA / DISCIPLINE -l ATTRIBUTES AND CHARACTERISTICS I
I I
I I. Bolting / Concrete Expansion l 1. Tension (Pull) Test Anchor Bolts l l A) Verify proper installation I of installed bolt l
l B) Verify proper tensioning and I integrity of bolt l
l 2. Torque Test l
l A) Verify nut installation with l required torque applied '
I II. Welding / Piping i 1. Testing of weld deposited filler l material (production welds) l l A) Perform NDE I
l -Radiography l -Dye penetrant testing 1 -Ultrasonic testing ,
l -Magnetic Particle testing l -Material sampling l -Fiber optics and TV camera l inspections l -Plastic impressions of l questionable areas for I outside analysis l
l B) Mechanical tests I
l -Tensile test l -Bend test l . -Charpy V-notch l -Etc l
l C) Chemical (spectrographic)
) . analysis I
l D) Hydrostatic testing of I piping systens
Page 2 of 3 .
ATTACHMENT 2 (Continued) l -
AREA / DISCIPLINE l ATTRIBUTES AND CHARACTERISTICS l
l l
l III. Material Traceability / Piping l 1. Testing Installed Pipe l
l A) Physical analysis l
l -Tensile test
! -Bend test
'l -Charpy V notch l -Etc l
l B) Chemical (spectrographic)
I analysis l
IV. Cable & Terminations / Electrical l 1. Megger Test 1
l A) Verify cable insulation I integrity l
l 2. Hi-Pot Test l
A) Confirm insulation characteristics by ,
I measuring leakage current l
l l B) Verify proper
, I construction / installation .
I of stresscones I
l 3. ' Resistance Test l
A) Verify continuity of circuits l 4 Signal tracing to determine I cable routing
- 5. Time domain reflectometers to
. I identify discontinuities _
l l 1. Megger Test V. Motors / Electrical l l A) Verify winding insulation I integrity l
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Page 3 of 3
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ATTACHMEN'i 2 (Continued) l AREA / DISCIPLINE l ATTRIBUTES AND CHARACTERISTICS -
1 I
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l 2. Polarization Index Test I
l A) Verifies acceptable i moisture level in motor
.I windings l
l 3. Conductivity and chemi. cal l residue testing for break-I down of internal components l
VI. Concrete / Civil l 1. Strength Test l
l A) Rebar mapping of area with l sonic or rader units to l determine appropriate area I to obtain samples l
l B) Core drill to obtain. sample I for compression test to l verify adequate concrete I strength I ,
I C) Schmidt Hammer and Windsor l Probe test to verify I concrete strength I
, 1 D) Hammer testing to check
, I concrete for voids I
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NOTE: The above is a typical listing of physical inspections; it is not intended to be a complete list of examples. There may be additions and/or substitutions necessary as the PVQC is implemented.
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ATTACHMENT 3 ,
SPECIFIC EIAMPLES OF PHYSICAL TESTING METHODS The following are examples of' methods that can be explored to determine -
the acceptability of inaccessible material or material surfaces that are not exposed for visual examination. Threeicases were considered (1)
ASME III buried or embedded pipe. (2) concrete structures, and (3) electrical equipment.
- 1) ASME III Buried or Embedded Pipe Available methods for visual internal pipe examination of inaccessible installations range from fiber optic units to T V.
cameras. These methods provide visual two dimension inspection.
For large diameter pipe visual internal examination may be performed by placing inspection personnel in the pipe (limited by physical conditions, pipe configuration and safety regulations) Personnel visual inspection can be enhanced while in the pipe by use of a T.V.
camera that allows more qualified personnel visual access from outside and produces tape record of the evaulation process and use of plastic impressions of questionable areas that can be processed as negatives to produce a positive replicas for outside evaluation and future reference.
Physical inspections such as liquid penetrant, magnetic particle.
eddy current. in-place metallography. ultrasonic examination (would require developement of unique procedures), and field metal analysis equipment (portable mass spectrometer) can be used to evaulate material grade and' acceptability. In addition some destructive examination such as scrappings and small diameter plugs can be ,
removed for chemical analysis. Larger pipe wall material samples, above 2"; r 2". ' can be removed for mechanical property testing.
These methods would require engineering evaluation of the extent to which applicable codes or standards permit repairs and modifications (e.g. may require an ASME code case).
Different methods of gaining access to the pipe such as through valves (disassemble the valve allowing access through valve), small or identical branch connections (access through an accessible branch), limited excavation, and open ended lines will be utilized.
Our preliminary analysis of embedded and buried safety related pipe indicates a total of 3678 linear feet and 845 welds in the service water.' cycled condensate and fuel pool cooling and cleanup systems.
In total this represents less than .4% of the total piping on the project. Of this total less than 500 linear feet are embedded in concrete. All of this piping is for low pressure service with a design pressure less than 200 psig. A progra= to perform an early docu=entation review of this inaccessible pipe is being developed so that the condition of weld and material traceability and quality is known at an early date. We will keep you advised of progress in this area.
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ATTACHMENT 3.(Continued) ,,
2)- Concrete Structures:
Available physical verification techniques are: 1) ham =er testing to locate prior consolidation areas, hollow / voids and poor repair work; 2) concrete strength tests such as schmidt ham =er, winsdor ~
prode. or selected core samples (e g. 2" aize which is destructive but' can be repaired easily); 3) rebar location by use of sonic and/or radar units (not suitable for use in congested rebar r.reas), some of these units may distinquish between different size bars such as a #8 or #11 but not necessarily between a #10 and #11 bars; 4) some' radiographic methods could be developed that would have . limited application at providing a definable rebar pattern.
Application limits are based on source size. concrete thickness, and accessibility.
- 3) Electrical Equipment:
Available physical verification techniques are: 1) Meger testing for motors and electrical cable 2) use of time domain reflectometer to identify discontinuity 3) signal tracing to determine cable routing 4) high POT testing for capacity testing of equipment such as transformers: and 5) oil test (s) of electrical equipment oil reservoirs for conductivity and chemical residue that may indicate a breakdown of internal components.
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=m Questions & Comments on the Course of Action (COA) - . .
Enclosure 1 Page 2
- 2. There is a need for CGEE to have a formalized methodology to _
determine validity of documents which may be used to justify adequacy of.SSCs. Describe the key elements of your methodology.
The details of a formalized methodology to determine validity of purchase order, installation and other quality inspection documents which may be used to justify adequacy of SSCs is described in implementing procedures and instructions he .g .
PVOC Procedures and Quality Verification Instructions). In summary this methodology consists of identifying the quality documents and reviewing their function or purpose. The validity of the document is established based on the applicable design specification or code criteria. A check is also made of the conformance to the procedures governing the completion of the document and the qualifications of the personnel performing the work and performing the inspection noted on the document. Finally, the document is compared to the as-constructed condition through visual and, as appropriate, physical inspections, as described in the COA.
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Questions & Comments on the Course of Action (COA)
Page 3
- 3. Please describe what is meant by physical testing for different structures, systems, and components (e .g. , describe test what would be considered to be an adequate meaningful for a pipe weld, an electrical cable, a piece of pipe, etc.).
This subject is discussed in detail in CG&E Letter LOZ 0233, dated November 18, 1983, a copy of which is attached with our response to Question 1.
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Questions & Comments on the Course of Action (COA) ,
Enclosure 1 Page 4
- 4. It is our understanding that CG&E's proposed independent .
audit of the PVOC will involve an independent assessment of the adequacy of the PVQC procedures and programs and observation of the implementation of the rVOC to determine the acceptability of the licensee's and contractor's performance.- After performance is shown to be acceptable, and when approved by the NRC, the scope of the independent inspection effort can be reduced to a conventional audit.
The auditor should meet the competence and independence criteria outlined in the February 1, 1982, letter from the NRC to Congressmen Ottinger and Dingell (provided to you previously). The auditor should be approved by the NRC. Any communications between the independent overviewer or auditor of the PVQC and CGEE are subject to the " Protocol Governing Communications Between CGEE and Independent Organizations Conducting Reviews or Audits Under the Commission's Order" sent to you by letter dated March 2, 1983. Additionally, please maintain in a location accessible for NRC review all records of your contacts with candidates for the assignment as independent overviewer.
CG&E. willi comply with this comment. ,
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Questions & Comments on the Course of Action (COA) '
Enclosure 1 Page 5
- 5. The selection of the contractor to perform the IDR must be -
approved by the NRC. The contractor must meet the competence and independence criteria outlined in the Commission's letter to Congressmen Ottinger and Dingell. Records of your contacts with candidates for the assignment to conduct the IDR'should be maintained in a location accessible for NRC review.
The selection of IDR contractor will be provided to Region
- III for their approval as directed by this question. The criteria for independence of the contractor was stated in the request for proposal for the IDR, which was supplied to Region III and other NRC offices on September 9, 1983 and on October 26, 1983. Criteria defining independence are responsive to the Commission's letter to Congressmen Ottinger and Dingell. CG&E's submittal to the NRC on October 26, 1983 proposed methods for conduct of the IDR and suggested a protocol to be followed. The protocol addressed the control ofscommunications and records.
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e Questions & Comments on the Course of Action (COA) '
Enclosure 1-Page 6
- 6. It is our understanding that CG&E will be involved in -
reviewing all disciplinary. actions,' including dismissal, regardless of organization, prior to the actions being taken and that. exit meetings will be held with all site employees prior to leaving the project, regardless of the organization.
Furthermore, we understand CGEE will monitor each of these meetings when a QC inspector is involved and one out of every five when other employees are involved. If this understanding is not correct, what is CG&E doing to provide assurance that employees are not being improperly disciplined for being concerned about safety and quality matters.
CG&E will not be involved in reviewing all disciplinary actions regardless of organization. CG&E will monitor exit interviews being conducted in other than group exit situations, regardless of the organization, and will conduct the exit interviews for CG&E employees. Copies of all exit interviews (including group interviews) will be forwarded to Mr. Cruden, Assistant Vice President for Nuclear Operations, for review.
Until further notice Mr. Joe Williams, Jr., Senior Vice President for Nuclear Operations, will speak to no less than approximately 20% of those leaving the Zimmer work site in other than a group exit situation.
The on-site NRC office has requested to talk to all QA/QC and records review personnel after their exit interview and prior _
to leaving the site, in other than a group exit situation.
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a ao Questions & Comments on the Course of Action (COA) ~
Enclosure 1 Page 7 The current directive on Exit Interviews is attached for -
clarification and is the vehicle being used to provide assurance that employees are not being improperly disciplined for being concerned about safety and quality matters.
4 O
1 .
TO: Distribution DATE: November 4, 1983 DSC-0057 .-
FROM: D. S. Cruden
SUBJECT:
- E::it Interviews -
Effective immediately, all personnel terminating, or being terminated in other than group exits, will be given exit interviews by their on-site employer with a.CG&E representative present. The CG&E representative will act strictly as a witness / monitor.
Schedules of exit interviews should be forwarded to Mr. D. S. Cruden, Assistant Vice President, Nuclear Operations, as much in advance as practical. Telephone calls to Mr. Cruden's secretary with this information is satisfactory when' timing warrants. Mr. Cruden will supply names of CG&E representatives in advance as feasible.
Copies'of all exit interviews (including group exits) will be sent to Mr. Cruden when completed. CG&E' representatives will report to Mr. Cruden personally immediately after the completion of their exit interview assignments. All allegations, if any, are to be documented '
together with the names of the interviewees. Subsequent followup reports and corrective action or closing out statements for all allega-tions will be forwarded to Mr. Cruden by the on-site employer within thirty (30) days.
Until further notice, Mr. Joe Williams, Jr., Senior Vice President for Nuclear Operations, will be given the opportunity to interview selected interviewees at random prior ~ to their departure.
All those personnel who desire to speak with him will be accommodated and others should be selected by the on-site employer. In any case, Mr. Williams desires to speak to no less than approximately 20% of those leaving the'Zimmer work site in other than a group exit situation.
The on-site NRC office (.Mr. William Hill) also desires to talk to all QA/QC and records review personnel after their exit inter-views and prior to leaving the site, in other than a group exit situa-tion. The on-site employer will arrange these meetings with the NRC.
D. S. Cruden
e November 4, 1983 ,_
DSC-0057 Page 2 4
~
/tc Distribution: J. Williams, Jr.
G. F. Cole B. B. Scott E. J. Wagner J. R. Schott C. G. Foster, Jr. -
G. C. Ficke D. L. Erickson H. C. Brinkmann K. K. Chitkara O. J. Mavro D. R. Hyster j B. K. Culver W. N. Tobler J. F. Pearson G. Jonds '(5echtel)
M. Noffsinger (HJK)
T. Bloom (GE)
T. Daley (S&L)
W. Hill (NRC)
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 8
- 7. At the November 1, 1983 meeting, it vas stated that the ZOC advisory staff will consist of a minimum of six individuals including a representative of Dayton Power and Light, a representative of Columbus & Southern Ohio Electric Company, a respected representative from the community leaders of Cincinnati, and at least three representatives with technical expertise. We believe the advisory staff should be expanded to include at least three respected members of the community including at least one elected official. CG&E might consider having a respected representative from the community served by each of the three utilities (CG&E, DP&L, and C&SOE) on the ZOC advisory staff. Furthermore, we believe one of the technical members should be an individual who has substantial experience in managing a nuclear construction project.
CG&E has no objections to expandin'g the Zimmer Oversight Committee advisory staff to include at least three respected members of the community and will accept a member from each
- of the communities serviced by Dayton Power and Light and Columbus & Southern Ohio Electric if those organizations can obtain suitable persons who are willing to serve. If necessary, CG&E will obtain the additional two members from the area served by CG&E, again provided suitable persons can be found who are willing to serve.
CG&E is amenable to including one elected official, or someone who has been an elected official, as one of the three community leaders provided a suitable official can be found who is agreeable to serve.
J~
Questions & Comments on the Course of Action (COA) - - -
- Enclosure 1
. Page 9 As stated in our letter of November 9, 1983, members selected from the community will not have taken a public position on the Zimmer issue or be associated in any way with an organization that has taken a public position.
One of the technical members will be an individual who has substantial experience in managing a nuclear construction project.
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Questions & Comments on the Course of Action (COA) ,
Enclosure 1 Page 10
- 8. The NRC (RIII) should receive a copy.of the ZOC advisory staff reports. If any portions of the reports are deemed by CG&E to be exempt from public disclosure, those portions should be identified and segregated from the remainder of the reports. RIII will make advisory staf f reports public except for matters which the staff treats as exempt from public disclosure .
CG&E will provide the ZOC advisory staff reports to the NRC Region III with the limitations set forth above.
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I Questions & Comments on the Course of Action (COA) --
Enclosure 1 Page 11
- 9. During the meeting on November 1, 1983, the role, makeup, and functioning of the Zimmer Oversight Committee (ZOC) was described in considerably greater detail than the description provided in the COA. .Please confirm these matters in writing and explain the proposed makeup and functioning of the o advisory staff to the ZOC. The description should include .
the amount of effort on a monthly basis that each advisory staff member will be expected to spend on the staff.
In response to questions contained in the October 28, 1983 NRC letter concerning the Zimmer Oversight Committee, CG&E provided information relating to the role, makeup and functioning of the ZOC and its advisory staff to the extent that the information had been developed. Work on further defining these areas continues and will be provided to the i
PRC as it is developed. Insofar as the amount of' effort each
+
member of the ZOC advisory staff will spend on this work, it is expected that the Senior Technical Advisor will devote approximately two days per month whereas the Technical Advisors will each spend upwards of two weeks per month.
There will be no limit placed on the amount of time the members of the advisory staff can devote to this effort.
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4 Questions & Comments on the Course of Action (COA) ..
Enclosure 1 Page 12 i
- 10. The materials provided with the Course of Action (COA) do not _
provide a clear indication of the commitment of the Board of Directors to the COA. Describe this commitment. l I
l On November 17, 1983 The Cincinnati Gas & Electric Company's Board of Directors adopted the amplification of the Policy Statement which was provided with the Course of Action document dated September 30, 1983. ,
l "Provided it is the decision of the Owners to proceed with the completion of the Wm. H. Zimmer Nuclear Power Station, the Board of Directors of The Cincinnati Gas &
1 Electric Company is fully committed to accomplishing the i
Verification of Quality and Completion of Construction described in the Course of Action document dated September 30, 1983."
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I Questions & Comments on the Course of Action (COA) . . .
Enclosure 1
- Page 13
- 11. Confira CGEE's intentions to have on the Board of Directors a .
nationally recognized individual who has broad experience in j the commercial nuclear power industry from a business viewpoint, from a management viewpoint, and from a QA viewpoint.
CG&E will have on the~ Board of Directors an individual such as described above, l
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Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 14
- 12. TPT recommended that an independent third party periodically review the adequacy and effectiveness of the overall design control system. How will this be accomplished?
The Torrey Pines recommendation for periodic third party review of the design control system is being responded to by two actions:
a) The planned Independent Design Review (IDR) by a third party specifically includes a segment in which the design control system is reviewed. The IDR is expected to be conducted during a substantial period, now defined as eight months. .
b) An independent audit of the QA Program will be performed by an outside organization (This audit is addressed in question 13). This audit will inelude the elements of the QA program that comprise the design control system.
We believe these audits Mill accomplish the recommendation of Torrey Pines.
_ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ . _ ._______a
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Questions & Comments on the Course of Action (00A) ..
Enclosure 1
- Page 15
- 13. According to the COA (p.21) an independent audit will be -
performed at least annually by an outside organization to assess the .ef fectiveness of the Zimmer Project QA Program.
Is a similar type audit planned to assess CG&E management affectiveness (such as the TPT review)?
The audit. referred to does include an assessment of
> management in relation to the QA/QC functions. It does not assess other aspects of management nor does CGEE consider that such an audit is required since the Zimmer Oversight Committee will provide a continuing review of all aspects of project management.
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Questions & Comments on the Course of Action (COA) .
Enclosure 1 Page 16
- 14. TPT recommended that CG&E prepare a master plan of audits. .
Discuss the differences between past, present, and planned actions in this regard.
A Master Audit Schedule for the 12-month period ending August, 1984 has been prepared. This schedule is currently being revised and improved to reflect all the audit activities planned to be undertaken for.on-site and off-site audits. On-site audits will cover the activities of HJK, S&L, CG&E departments including QAD, Bechtel and other site contractors.
Off-site audits will include vendor audits and contractor's OA activities impacting on their site responsibilities.
.In summary, the audit schedule will identify each applicable criteria of Appendix B to 10CFR50 to assure auditing at least annually or during the life of the activity, whichever is shorter. Emphasis will be given to 9,uditing of training, I document control, inspection, regulatory commitment program and corrective actions and audits will be scheduled early in the life of an important activity when the need is more critical. Flexibility will be provided in the audit schedule to allow for unscheduled audits that will cover identified _
problems.
l l
Questions & Comments on the course of Action (coa) --
Enclosure 1 Page 17 The audit section which was very small in 1981 will expand to 20 persons during PVQC and CCP to assure comprehensive audit coverage.
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Questions & Comments on the Course of Action (COA)' -
Enclosure 1 -
Page 18
- 15. Has the Director of the Audit Group been hired by CG&E7 If so, provide his name and credentials.
CG&E is in.the process of screening potential candidates for the position of Director of QA Audits. It is expected that one will be issued an appointment before the end of the year.
The position is temporarily occupied by a qualified person employed by CG&E under contract arrangement. In addition, two Deputy Quality Assurance Managers, both employed by CG&E under contract arrangement, have been assigned. The Director of Audits reports to a Deputy Quality Assurance Manager.
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-Questions & Comments on the Course of Action (COA) .
Enclosure 1 Page 19 l
- 16. Mr. Dickhoner's COA transmittal letter states approval of a .
substantial increase, approximately doubling the staffing, in the number of CGEE people assigned to the accomplishment of the work which lies ahead. Provide an organization chart which indicates where the old and new CG&E personnel are or will be assigned. (DSC)
The response to this question is being compiled and will be provided in a subsequent submittal.
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Questions & Comments on the course of Action (COA) . . .
Enclosure 1 Page 20 t
i
- 17. Provide'information indicating which present and former _
managers.and supervisors of CGEE, HJK, S&L and GE in place at the time of the Show Cause Order will still be in responsible positions under the organization described in the COA, If such managers or supervisors will be in positions different from positions occupied prior to the Show Cause Order (SCO),
identify both the old and new positions. How and to what extent has CGEE assured itself that these individuals can be relied upon to identify and correct problems at the site?
The response to this question is being compiled and will be provided in a subsequent submittal.
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Questions-& Comments on the Course of Action (COA) --
Enclosure 12 Page 21
- 18. To what extent has CG&E reviewed the management attitude and -
functioning of supporting organizations (i .e . HJK, S&L, GE, !
etc.) to assure that past problems are known and that the l remedies proposed in the COA adequately address these problems?
i CGEE has made extensive reviews of the management attitude and functioning of the various organizations supporting the Zimmer project and is confident that the actions as identified in the COA in this regard will provide adequate assurance against recurrence of past problems. A continuing j assessment of the attitude and functioning of the management of all supporting organizations will be conducted and prompt remedial actions taken, where necessary.
The weekly staff meeting of the Senior Vice President brings together the upper levels of the management of all organizations. This serves to vividly illuminate attitudes and performance.
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, i Questions & Comments on the Course of Action (COA) -
Enclosure 1 Page 22
- 19. The report by Torrey Pines Technology (TPT) describes an .
adversary relationship between CG&E and Henry J. Kaiser (RJK). How will this relationship be changed so as to obtain teamwork at-the site? Describe any proposed training and
- indoctrination to be provided to first line supervisors of EJK, or other means proposed to change previous attitudes and performance.
A significant restructuring of the project has been completed and employee awareness of previous project problems has been heightened through indoctrination and through a formal program of evaluating past problems in the procedure development program.
Bechtel, in their role as Project Director is aware of the concerns over adversary conditions and will develop working relationships among the various organizations that fosters better teamwork. The causem of past problems have been analyzed and organizational solutions have been developed f where appropriate. CG&E will manage the Project Director, Bechtel, from an oversite role and Bechtel will manage and direct all activities of HJK.
CGEE and Bechtel are committed to interview key HJK personnel, and emphasis on the importance of a good working relationship and teamwork will be discussed. These ideas will be communicated to the first line supervisors. All site
. employees are undergoing indoctrination and training,
Questions & Comments on the Course of Action (COA) ...
Enclosure'l Page 23 attitudes are changing and cooperation and teamwork will be .
achieved.
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. l Questions & Comments on the Course of Action (COA) --
Enclosure 1 Page 24
- 20. In the meeting with the NRC staff on November 1, 1983, CG&E stated that each contractor would emphasize its policy of maintaining a work environment that is free of harassment of quality assurance and quality control personnel. Policy i statements to employees which have been issued by H.J. Kaiser !
Company and which were provided to NRC staff following the '
meeting are:
- a. " Harassment in the Work Place", by Mr. M.E. Noffsinger, i BTE Project Director, no date.
- b. " Policy Statement, Henry J. Kaiser's Quality Assurance Program for the Wm. H. Zimmer Nuclear Power Station" by Mr. M.E. Noffsinger, RKE Project Director, no date.
- c. " Commitment to Quality and ProfessionalExcellence" and attached " Statement of Policy Pertaining to the Quality Assurance Program for the William H. Zimmer Nuclear Power Station".by Mr. Donald G. Iselin, Chairman of the Board, Henry J. Kaiser Company, dated October 28, 1983.
Provide a copy of these H.J. Kaiser policy statements as a part of the COA documentation. Provide any similar polic statements issued by CG&E, Bechtel, Sargent & Lundy, and/y or General Electric.
Describe how these notices have been or will be furnished to the employees. Notices should include the names and telephone number of NRC personnel on site to whom reports may be made (Bill Hill or Pat Gwynn, 553-2052 or 2053).
The requested notices are attached. The CG&E policy statements have been provided to all employees on-site. In addition, the principal contractors have supplied their individual policy statements to their employees. None of the statements mention the NRC personnel by name, but the CG&E statements (provided to all on-site personnel) have the NRC resident office telephone number as do some of the contractors' statements.
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- THE CINCINNATI GAS & ELECTRIC COMPANY GP ' " " -
cmeisneri.csio .e saoi w.i oicxwouca STATEMENT.0F POLICY -
PERTAINING TO THE QUALITY ASSURANCE PROGRAM FOR THE WM. H. ZIMMER NUCLEAR POWER STATION It is the policy of The Cincinnati Gas & Electric Company (CG&E):
A. To design, construct, and operate the Wm. H. Zimmer Nuclear Power Station (Zimmer) in accordance with all applicable laws, regulations, ccdes, and standards.
B. To obtain a high degree of quality, integrity, and reliability in the design and construction to ensure that operation of Zimmer will be safe and reliable.
C. To control the quality of the design, construction, and operation of Zimmer by means of a planned and documented Quality Assurance Program.
D. To provide a work environment for all persons working on Zimme r to,a c' encourages the achievement of high quality and facilitates the communication of any quality concerns to the proper levels of management for action.
CG&E recognizes the importance of assuring that the design, construction, and operation of Zimme r complies with all applicable laws, regulations, codes, and standards by means of a planned and documented Quality Assurance Program.
Audits, including surveillances and document verifications, shall be used to ensure that activities at Zimmer comply with the policies and requirements of the -Quality Assurance Program to
. identify procedural deficiencies and non-compliances and to secure effective and timely corrective actions.
I, as the Company Pres'ident, have the ultimate responsibility for implementation of the Quality Assurance Program for Zimmer. I have delegated the responsibility for the implementation of this Program to the Senior Vice President, Nuclear Operations. He is responsible for interpreting this Policy and for making necessary changes to this Policy.
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Page 2 -
Re: Statement of Policy Pertaining to the Quality Assurance Program for the Wm. H. Zimmer Nuclear Power Station The Assistant Vice President for Quality Assurance, under the direction of the Senior Vice President, Nuclear Ope rations, has been delegated the responsibility for establishing and maintaining effective quality assurance and quality control programs for Zimmer.
Every employee or organization that performs nuclear safety-related activities for Zimmer is responsible for implementing the policies and requirements of the Quality Assurance Program that are applicable to their respective a reas of responsibility. All persons at Zimmer involved in nuclear safety-related activities are required to f amiliarize themselves with and comply with the applicable requirements of the Quality Assurance Program.
Any person who believes (1) that the policies and re quirements set forth in the Quality Assurance Program are not being fully complied with, or (2) that the implementing procedures for said Program are not being fully complied with, or (3) that he or she is being harassed or intimidated because of reporting possible infractions is obliged and encouraged to inform his or her supervisor, cognizant QA Depar tment personnel, the CG&E Manager, Quality Assurance Depar tment, or the Assistant Vice President for Quality Assurance of his or her concerns. If such person's concerns are not resolved, he or she should inform successively higher levels of management, including the Senior Vice President, Nuclear Ope rations (553-2994), or myself (632-3444). Intimidation or harassment will not be tolera ted .
You should also feel free to bring any such matter to the attention of the NRC or its Resident Inspector (55 3-20 21 ext. 376).
CG&E will treat these concerns confidentially and give them urgent and careful conside ration. The re will be no reprisals, penalties, or discriminatory action toward any individual for bringing for th such conce rns to CG&E or the NRC.
This Policy shall be carried out in consonance with other CG&E Policies contained in the Company Policy Manual. Should any conflict exist be tween this Policy and other CG&E Policies, this Policy takes precedence for all matters concerning nuclear safety-related work on Zimmer.
/
W. H. DICKHONER, P RESIDENT THE CINCINNATI GAS & ELECTRIC COMPANY _
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THE CINCINNATI GAS & ELECTRIC COMPANY # ~
CINCINN ATI.oMio 45201 l
,, October 14, 1983
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POLICY STATEMENT ON HARASSMENT AT THE ZIMMER SITE POLICY
- Harassment of personnel in the performance of their duties at the Zimmer site will not be tolerated. ,,
DISCUSSION Every employee at the Zimmer site is responsible to perform work in a professional manner in accordance with approved procedures, standards or requirements. It is essential that each and every employee thus engaged be able to work in an environment that is frea from any form of intimidation or harassment. This document establishes the policy on harassment and the procedures to be followed in the event any indication or sign of such is encountered or suspected.
PROCEDURE
- 1. Any employee who believes that he or she is the victim of harassment has the obligation to report such harassment to their immediate supervisor unless that immediate supervisor is, or is suspected of being, the source of the harassment.
In such cases the employee shall report such harassment to a higher level of management within that organization.
- 2. If for any reason the employee feels his or her concerns in this regard are not being adequately addressed or resolved as the result of action taken in paragraph 1 above, he or she has the right to report these concerns directly by telephone to the CG&E Assistant Vice President of Nuclear Operations on 553-6346. This number is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven _
days a week specifically reserved for this purpose. By calling this number, the employee can request and will be provided confidentiality to the extent he or she may desire.
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- 3. This policy and the procedures outlined herein apply to all employees at the Zimmer site regardless of the organization they work for. In this regard, each contractor or subcontractor working at the Zimmer site shall issue, in writing, to each of their employees a policy statement.and procedures relating ~
to harassment which are in agreement with this document.
- 4. Any cases of known or suspected harassment reported to a contractor or subcontractor working at the Zimmer site shall be reported immediately to the CG&E Assistant Vice President of Nuclear Operations (553-6346).
- 5. Any employee at the Zimmer site has the further freedom, ,
if he or she desires, to report possible cases of harassment to any one or all of the following:
- a. CG&E Senior Vice President - Nuclear Operations (553-2994)
- b. CG&E President (632-3444)
- c. NRC Resident Inspector (553-2021 Ext 376)
- 6. Penalties up to and including discharge will be imposed on any person (s) found guilty of harassment. Cases where it has been determined that criminal law has been violated will be referred to appropriate law enforcement agencies.
This policy statement will be incorporated into the Zimmer Organization and Policy Manual.
THE CINCINNATI GAS & ELECTRIC COMPANY l ):::' : , _
J. Williams, Jr. I ,
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. . l f , Bechtel Power Cor[) oration 777 East Eisenhower Parkway ,
Ann Arbor. Michigan l adedAseess: P.O. Box 1000, Ann Arcor, Michigan 46106 STATEMENT OF POLICY
- PERTAINING TO THE QUALITY ASSURANCE PROGRAM FOR THE WM. H. ZIMMER NUCLEAR POWER STATION It is the policy of the Bechtel Power Corporation:
A. To assist in the completion of design and construction of the Wm.
H. Zimmer Nuclear Power Station (Zimmer) in.accordance with all applicable laws, regulations, codes, and standards.
i B. To obtain a high degree of quality, integrity, and reliability in/
the design and construction to ensure that operation of Zimmer -i will-be safe and reliable.
. . . i C. To control the quality of the design, construction, and operation of Zimmer 'oy means of a planned and documented Quality Assurance Program.
}- '
, D. To provide a' work environment for all persons working on Zimmer t that encourages the achievement of high quality and facilitates -
the' communications of any quality concerns to the proper levels of
. management for action.
Bechtel recognizes the importance of demonstrating that the design, construction, and operation of Zimmer complies with all applicable law, regulations, codes, and standards by means of a planned and documented Quality Assuran::e Program. '
l Audits, including surveillance and document verifications shall be used to verify that activities of Zimmer comply with the policies and requirements of the Quality Assurance Program to identify procedural deficiencies and non-compliances and to secure effective and timely q corrective actions. .
Every employee and organization that performs nuclear safety-related activities for Zimmer is responsible for implementing the policies and requirements of.the Quality Assurance Program that are applicable to -
their. respective' areas of responsibility. All persons at Zimmer,
. involved in nuclear safety-related activities, are responsible to
- familiarize themselves with and comply with the applicable requirements ,
, of the Quality Assurance Program. 3[
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4 Bechtel Power Corporation Page Two Any person having concerns regarding the quality of the Zimmer plant, compliance with quality procedures or other project procedures is encouraged to contact LLs or her supervisor; any person in the quality assurance organization (including the Manager of Quality) or my office (313-994-7201). . It is of particular importance to me that any person who experiences harassment or intimidation in the attempting to perform ,
his/her job, report any such incident or pattern of conduct in accordance with this policy. Intimidation or harassment of any project employee will not be tolerat'ed. Anyone feeling that concerns are not being addressed should inform successively higher levels of management, including my office.
/
You should also feel free to bring any such matter to the att'ention of CG&E, NRC or the NRC Resident Inspector (553-2021, Ext. 376).
Bechtel will treat these concerns confidentially, and give them urgent and careful consideration. There will be no reprisals, penalties, or discriminatory action toward any. individual for bringing forth such
( _. concerns to Bechtel, CG&E or the NRC.
This Policy shall be carried out in consonance with other Bechtel Policies contained in Company Policy Manuals. Should any conflict exist between this Policy and other Bechtel Policies, this Policy takes precedence for all matters concerning nuclear safety-related work on Zimmsr.
Howard W. Wahl Vice President and General Manager m
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October 28, 1983 _ To: All HJKCo Employees Zimmer. Nuclear Power Station
Subject:
Commitment to Quality and Professional Excellence , It is the policy of Henry J. Kaiser Company to successfully complete the construction of the William H. Zimmer Nuclear Station, while providing the documentation which will verify the quality of.the plant in such a mar.ner that will enable CG&E to complete licensing requirements,and ultimately become one of the nations most reliable nuclear plants in tmns of sa.fety, perfonnance and public confidence. Henry J. Kaiser Company is commi,tted to assist CG&E in obtaining this goal. We can only achieve this goal'through a total team effort which expresses each individual's personal professional dedication and commitment to this
-project. Our goal is that each employee do each job right the first time.
Henry J. Kaiser Company depends on the personal responsibility of each employee to meet its overall goal of commitment to quality and professional excellence. Our primary responsibility to the William H. Zimmer Nuclear Power Station is the same as CG&E's: "to ensure that the station is designed and constructed such that future operation can be conducted so safely and so efficiently... and thus so free of criticism...that there will be created a climate of acceptance for nuclear energy in general pnd of the Zimmer Station in parti-cular." , I have reviewed CG&E's Statement of Policy pertaining to the quality assurance program for the Zimmer Nuclear Station, and I am integrating it as part of the Henry J. Kaiser Company's Statement of Policy. Attached to this memo is a copy of our policy which is similar to CG&E's, and which re-quires the adherence of every employee working for HJKCo on this project. I am convinced that each of you has the desire and professional pride to see
.that this policy is implemented throughout the successful completion of the Zimmer Station.
Dona d G. Iselin Chairman of the Board Henry J. Kaiser Company
.H2iVRY J. XA2==
C.011/D=4NY - P.O. BOX 201. MOSCOW, OHIO 45153 October 28, 1983 STATEMENT OF POLICY PERTAINING TO THE QUALITY ASSURANCE PROGRAM FOR THE WILLIAM H. ZIMMER NUCLEAR POWER STATION It is the policy of the Henry J. Kaiser Company: To complete the construction of the William H. Zimmer Nuclear Power Station, while insuring that the facility complies with all pertinent federal, state and local laws, rules, regulations, codes and standards. To obtain a high degree of quality, integrity and reliability in the design and construction to ensure that operation of Zimmer will be safe and reliable. To control the quality of the construction of Zimmer by means of a planned and documented quality assurance program. To conduct regular audits of both the quality assurance and construction programs to assurc that all work being performed: a) complies with the requirements established in the site quality assurance programs, b) iden-tify procedural deficiencies which hinder our ability to construct, and c) to identify areas of non-compliance and to effect means of bringing such areas back into compliance with published programs. To provide a working environment that encourages the achievement of high quality, and in which all employees feel free to voice their concerns regarding the quality of our construction efforts to either their higher management or the quality assurance department at the site. If it is felt that these levels of authority are not responsive to employees concerns, then they are encouraged and obliged to register their comments, observa-tions, etc. , either with my office (415-271-4210) or with Dwight Tolley (415-271-5838). Similarly, such concerns may also be called directly to the attention of CG&E, Bechtel or the NRC Resident Inspector (553-2021, extension 376). All Henry J. Kaiser Company personnel shall treat these concerns confidentially and give them the utmost and thoughtful consideration. No employee will suffer any reprisals, penalties or discriminatory action for expressing their concerns regarding the integrity of our construction program. Intimidation or harassment will not be tolerated. A a Amcw mT== .u:oNu. covoa
- Statement of Policy October 28, 1983 Page 2 Every employee and organization that performs nuclear safety-related activities for Zimmer is responsible for implementing the policies and requirements of the quality assurance program that are applicable to their respective areas of responsibility. All persons at Zimmer, involved in nuclear safety-related activities, are responsible to familiarize them- -
selves with and comply with the applicable requirements of the quality assurance program. The above-stated program shall be published and followed by HJKCo employees employed at the William H. Zimmer Nuclear Power Station. Should any con- - flict arise between this policy and any other company policy, this policy takes precedence for all matters concerning nuclear safety-related work on the project.
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Y' - Donal G. Iselin Chairman of the Board' Henry J. Kaiser Company _ e o e I e er- - .- - - ,-r - - -- yo - 7--- _.+---_,,---_.n.__. - - _ - - - - - - -- y,, . - - - - - - -
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e, , POLICY STATEMENT HENRY J. KAISER'S OUALITY ASSURA',CE PROG 2.AM . FOR THE WM. H. ZIMMER NUCLEAc. POWER STATION Henry J. Kaiser Company is ccm.itted to construct the Wm. H. Zir.mer Nuclear Power Station in accordance with all applicable laws, regulations, codes and standards. This will be accomplished through a planned, implemented and documented Quality Assurance Program. This comitment to quality transcends the highest level of corporate manage- . ment, and includes a,ll, individuals performing work activities at Zirrer. Each individual is responsible for imolementin; and adherina to the policies and requirerents of tnis Program. The Quality Assurance Program provides for periodic audits, surveillances, and prograr evaluations. These reviews will be used by appropriate managea nt personnel to assure the adequacy of the H. J. Kaiser Q. A. program. / Procedural difictencies and material non-compliances are to be quickly identified and corrective action taken in a timely canner. All items of non-corpliance are to be'correcteo in such a manner that the cause of the condition is clearly identified, and that corrective action to preclude recurrence is implemented. H. J. Kaiser's 0.A. Program further provides for the evaluation of all deficiencies and non-co: oliance for the deterrination of rescrtability in accordance with 10CFR50.55(e) and Part 21. To assure that all deficiencies and non-coroliance are approcriately resolved, both the Site C.A. Manager and the Project Manager are charged with the authority and responsibility to stop wor., if necessary. Any Derson having concerns regarding the irplementation ef, or cocaliacca with, the Q.A. Program is required to contact his/her supervisor so that ' concerns are adequately addressed. Anyone feeling that their concerns are not being adequately addressed has both the authority and the responsibility to inform successively higher levels of management, including tne R d Project Director - Mr. M. E. Noffsinger, 553-6740. Individuals should also feel free to take any such matters to the attention of CG&E, the NRC or the NRC Resident Inspector (553-2011. Extension 376). Posted throughout the site are reporting documents which identify additional contact agencies and phone numbers, which individuals should feel free to use in these matters. hmu m u ng mu
I J. , Henry J. Kaiser will handle these concerns confidentially, and give them
, urgent and careful consideration. There will be no reprisals, penalties, or discriminatory action taken toward any individual for bringing f. orth such concerns to HJK, CGLE or the N C. -
This policy shall be carried out in accordance with Henry J. Kaiser's Co ;any :olicy and Quality Assurance manuals. Should any conflict exist between this policy and other H. J. Kaiser policies, this policy takes precedence for all matters concerning nuclear safety-related work on the project. .
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l4 .C /b for _ M. E. hoffsinger /, / } . RKE Project Director. ' e t 4 b F
D.S.C9UDUI 'd # . , n; -. Raymond Kaiser Engineers OcT 281983
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D 5: isYn%m :..- TO: ALL HJK EPPLOYEES HARASSMENT IN THE W'):t OLACE .. As ecoloyees at the Wm. H. Zimrer Nuclear Power Station, we have an obligatier. - to exercise our' "best efforts" in the performance of work assignments. Strict adherence to federal, state and local laws, jobsite policies and work proce -
'dures is mandatory.
It is the responsibility of management to assure that the performance of work assignments can be accomplished in an environment that is free of - intimidation and harassnant. The Henry J. Kaiser Comcany will ng tolerate intimidation or harassment of
- employees at Zirn er. If, at any time, you feel that pressure is being exerted to violate federal, state and local laws, or jobsite policies or procedures, you should irrediately contact your sucervisor. Should your supervision be unavailable, non-responsive or a party to your concern, you should proceed to the next higher level of management.
In the event you feel that your concern has not been sufficiently addressed, immediately contact one of the following managers - Mr. Keith Dempsey, Project Manacer - 553-2163, Mr. Dick Davis, Quality Assurance Manager - 553-3636 or Mr. Mike Noffsinger, Project Director - 553-6740. I can assure you that all concerns will bf. addressed and the aporopriate action taken'to resolve all concerns. , As you are' aware Raymond International and the Kaiser family of companies are Equal Ecoloynent Opportunity employers. As such, we are bound by
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-all laws and reculations that address this com.itment. Should an emoloyee believe that they are being discrininated against or harassed in a manner
_ governed by Equal'Employnent Opportunity laws, they should contact our Industrial Relations Department. Mr. Steve Armknecnt. Industrial Relatior.s Manager - 553-4963.
- Procedures are currently being developed to reflect the above policy. They will be presented in our Employee Greivance Procedure No. V-9, which will be issued in the near futtire.
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S5 EAST MONAOE STREET
, CHICAGO, ILLINot5 60e03 n cs %Crr, ce) T & LUNDy
( 3:2 ) 269-2000 ' 312-263 39?] -
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October 19, 1983
~STATEME'T OF POLICY BY SARGENT & LUNDY ON THE SUBJECT OF HARASSMENT ~
FOR THE WM. H. ZIMMER NUCLEAR PGWER PLAMT' ~ J
- _. It is'the policy of Sargent & Lundy that any person havina ~
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concerns regarding the quality of the Zimmer plant design ~
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compliance with quality procedures, or other project . proceaures ce encouraged to ccntact his or her supervisor,
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the Head, Quality Assurance Division, or my of fice withou'- - fear of harassment. _ Sargent & Lundy has continually recognized and emphasized the importance c f quali y-related design and encouraged employee participation i. the identification'of items requiring corrective action. Furthe more, the Sargent & L ti n d '.- Quality Assurance Manual establishes procedures for the identi- ' fication of design deficiencies end their corrective action tor nuclear safety-related activiti_es. Although there has been no evidence of arassment and Intimidation by Sargent & Lundy staff on the Zimmer project, . it is of particular importance to me that any person who - experiences harassme.nt or intimidation in attemeting to perform his/her joc, report any such incident in accordance .- with this policy. Intimidation er harassment of any project
= employea will not be tolerated. Employees feeling that thev
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are belr.g harassed should inform their Sucervisor; and if '.
- their concerns are not handled to their satisfaction, higher
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r levels of management, including my office (312/269-3970), saould be contacted. Sargent & Lundy will treat these concerns confidentially and give them urgent and careful consideration. I SARGE"T & Lt":D Y
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GENERAL ELICTRIC N U C L E,A R E N E R G Y. BUSINESS GROUP GENERAL ELECTRIC COMPANY, P 0. BOX 177, NEW RICHMOND, OHt0 45157 Phone (513) 553-2011. Ext. 244/376
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nrn' RECEIVED o,s.cauotrL_. d
) TEBZ-113-83
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November 10, 1983 NOV111933 F:LE: l HETURM TC: i D. S. Cruden Assistant Vice President Nuclear Operations Cincinnati Gas & Electric Co. Zimmer 1 Site Moscow, Ohio 45153
SUBJECT:
CONFIRMATION OF HARASSMENT POLICY STATEMENT !
REFERENCE:
Letter /D. S. Cruden * ' ~ to Distribution, DSC-0060 of 11-4-83, Same Subject;
Dear Mr. Cruden:
This letter is in response to your referenced letter. This confirms that all~on-site General Electric Company (GE) personnel ana their immediate reporting sub-contractors (secretaries) have received a copy of Mr. J. Williams, Jr. policy statement on harassment dated October 14, 1983. - The statements were handed to the GE (and secretarial) personnel with the oral statement that GE endorses this policy. New GE (and secretarial) employees will similarly be handed a copy of the CG&E p)licy statement on harassment by the GE Startup Test and Operations manager, o; 'ay me, as appropriate. Yours very truly,
'M T. E. Bloom Resident Site Manager Zimmer 1 Site TEB/md cc: H.C. Brinkmann I.L. Gray _
G.B. Jones J.A. Steininger E.J. Wagner file
G E N E R Al. $ ELECTRIC [p.] Mg ~ 1 0 NUCLEAR FO%IR SYSTEMS oMstON Q( 1N GENERAL ELECTRIC CCMPANY
- 17s CURTNER AVENUE
- SAN JCSE, CAUFCRNIA 9512s ..
MC 394, (408) 925-3307 October 26,.1983 RESP 0tlDS T0: Reference
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CGE-1791 bec: E. Bloom, w/atts. Mr. G. 8. Jones, Project Manager J. A.'Steininger w/atts. Bechtel Power Corporation S. W. Coulter, w/atts. P. 0. Box 113 File 29, w/atts. Moscow, OH 45153
Dear Mr. Jones:
SUBJECT:
Wm. H. ZIPJ4ER flVCLEAR POWER STATI0tl UtlIT 1 POLICY STATEMEilTS
Reference:
Letter G. B. Jones (Bechtel) to T. E. Bloom (GE) of Octcber 4, 1983, same subject This responds to your letter of October 4,1983. The CG&E and Bechtel policy statements attached to your letter have been distributed to. appropriate personnel. Appropriate future personnel will likewise receive such a distribution. The General Electric Company has long had a dedication to quality. fionetheless, the two attached documents and the referenced quality assurance program description have been distributed to the appropriate personnel. Appropriate future personnel will likewise receive such a distribution. Ccmpany Policy Statement 20.1 is a proprietary document, one that is r:ot ordinarily made available to those outside General Electric Company. Because of CG&E's singular need for and awareness of the document, we have chosen to show it to you. We request that you limit its availability on "a need to know" basis. Very truly yours, I. L. Gray . Project Manager Ziceer 1 ILG: pes /108S Attachments: 1. Ccmpany Policy Statement 20.1
- 2. Statement of Policy and Authority (NE00-11209)
, ,. m i vi i G E N E R A l. h) E L E CT R I C .
E ', ORGANIZATION AND POLICY GUIDE IW J 2.____.- TA3: Company policy St.itenwnts - Issued by: Corporate Esecutise Office FJUI'8ER: 20.1-IESUED: 9/1/81 SUPERSEDES: old Policy 20.9 (10/16n8) COMPANY-WIDE QUALITY OBJECTIVE STATEMENT OF POLICY lt is the objective of the General Electric Company to . It is the policy of General E!cetric. in offering products perform all activities with dedication to quality: the and sersices that fill a wide range of customers' needs quality of the Company's products; the quality of its (i.e., in all that it does), to pursue and deserve a repu-
- services; the quality of its communications to various tation for quality leadership, and to merit customer trust audiences; and the quality o f its fulfillment of citizenship because full value is being received.
responsibilities. In support of this objective, the Com- It is the policy of General Electric, in fulfilling its pany encourages the achievement of Indisidual excel- social responsibi'ities and in every aspect ofits relation-lenca on the part of every employee in every job. ships both outside and inside the Company, to demon-a Company wide Quality, as a corporate objective, strate total dedication to the attr.inme/nt of quality rncans attaining a level o f overall per formance and at-I r4' titude that makes General Electric the natural choice
;.i?LEMENTATION AND ?.iEAGUllET.iENT cf customers and earns the respect of all thpse af.
fected by the Company's activities. Responsibility for imp!ementation and measurement j under this Policy is assigned to the Sector Executives and e n Company-wide Quality, as an individualobjective,is cosporate Senior Vice Presidents, who will conduct the achiesed by employees who aspire to be better than efrairs of their respectise components in accordance the best. General E!cctric is committed to as,isting with this and rel.ited policies. cmp'oyees in their pursuit of exce!!cnce by providing The Officers notal above shall make regular repoits sh:m vdth the Icadership, cooperative climate, train- to the Corporate Executive Office on fulfillment of ing, facilities, and materials consistent with the oser. Company. wide Quality objectives by their ccmponents, all Company quest for quality. In measuring .ind rewarding both individual and man-agerial effort at all echelons, the highest value will be placed on quality performance that refleets exec:!cnce, crcatisity, productivity, and pride in accomplishment.
- MJO 112Ci -
12 31 82 GENERAL ELECTRIC COI,IPANY
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175 Curtner Avenue -
. San Jose, California 05125 December 31,1982 ~
STATEMENT OF POLICY AND AUTHORITY . It is the policy of the Noelear Energy Butiness Operations to attain quality leadership, and to achieve and maintain ~high quality in products and services through timely and effective compliance with all quality requirements. This document describes the BWR Quality Assuranco Program which is to be used by the Nuclear Energy Cusiness Operations to fulfill this policy. All nunngers
) within the Nuclear Energy Business Operations with quality-related recponsibilities have full authority to implement the program within their respective areas of responsibility. Development of procedures to implement the Quality Assurance Pcogram is a basic respcacibility of each of the organ!/.ations within the Nuclear Energy Business Operations. ,
The implementation of the Quality Assurance Procrum for the Boiling Water Reactor business has the unqualified endorsement and support of General Electric management. A/A'W ' 'A' Mb W. H. Bruggeman Vice President and General Manager Nuclear Energy Business Operations G xvhvi
Questions & Comments on the Course of Action (COA) -
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Enclosure 1 Page 25
- 21. For the Regulatory Commitment Program, (Page 7, Appendix C, Volume I), describe the means for identifying, listing and tracking written commitments made to the NRC regarding equipment and plant procedures as identified in the NRR staff's letters and .tes Safety Evaluation Report (NUREG-0528) and Supplements, and as documented in CG&E letters and in its Final Safety Analysis Report and J.mendments. Describe how assurance is obtained that commitments have indeed been fullfilled, (i.e., result in equipment changes, procedure changes, or organization changes, as applicable.) The CG&E Plan of Action to respond to findings and recommendations in various reports (Attachment 2, Volume II) should also address NUREG-0528.
All correspondence sent to NRC is issued through the Nuclear Licensing Department (NLD) and is reviewed by the NLD commitment tracking group. Commitments contained in this correspondence are identified and entered into a computer data base for distribution to the responsible department manager and/or Assistant Vice President. NLD requires that the responsible individual respond in writing to verify the implementation of commitments distributed. The commitment tracking group reviews these responses to ensure that implementation can be verified through the review of controlled documentation. Controlled documentation includes drawings, procedures, design - specifications, engineering change requests, etc. Periodicaudits will be performed of the implementing _ documentatic:.- to verify commitment closure.
i Questions & Comments on the Course of Action (COA) . . .
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-Enclosure 1 Page 26 Documents issued to CG&E by the NRC are not specifically _
reviewed by the NLD commitment tracking group and included in the commitment data base. The rationale for this is twofold. First, documents received from NRC (including NUREG-0528 and similar documents) which require a response are tracked on a day-to-day basis at the working level by NLD in order to prepare the CG&E response. Second, the resulting response and any commitments contained therein are reviewed by the commitment tracking group and entered into the data base. In this manner, the system established fulfills its intended function of assuring that all written commitments to NRC are implemented.
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. Questions & Comments on the Course of Action (COA) --
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Enclosure 1
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- 22. It is not apparent who will perform the work required .for _ ,
, FSAR changes. Provide a description of CG&E or contractor organization units and procedures for making FSAR changes to bring the descriptions in the FSAR into agreement 'with as-built or as-designed structures, systems, and components and for determining whether such changes require a change to
- safety analyses reported in the FSAR. (Page 12, Table 3, Volume I)
CG&E processes FSAR changes in accordance with approved i procedures. The Manager - Nuclear Licensing Department (NLD) is responsible-for-coordinating FSAR changes. The Architect / Engineer (A/E) reviews the FSAR 'to assure that it reflects the actual design and/or installation, and initiates appropriate FSAR changes at least every six (6) months, in accordance with their approved internal procedures. > L l Proposed FSAR changes, as identified by CG&E departments, the A/E, the NSSS Supplier and other outside organizations, are forwarded to the Manager - NLD for processing. NLD engineers coordinate review of the proposed changes. NLD distributes the proposed changes to appropriate CG&E Assistant Vice l Presidents, department managers and other organizations for review. Proposed changes are reviewed by CG&E management and other experienced engineers for technical accuracy, content, and compliance with codes, standards, and other regulatory commitments. _ ._ _ ~__ . _ . , . .__ _ _ . _ _ , . . _ _ . _ _ _ ___ _._ __ _ _ _ . _ . _ _ _ _ _ . _ . _ . . _ . __.
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Questions & Comments on the Course of Action (COA) ,_ Enclosure 1 Page 28 NLD is responsible for resolving all reviewer comments. Upon , resolution of comments, NLD transmits the approved FSAR
-changes to the A/E for final processing as a revision and transmittal to the NRC.
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