ML20082H780
| ML20082H780 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/21/1983 |
| From: | Williams J CINCINNATI GAS & ELECTRIC CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| LOZ-83-0234, LOZ-83-234, NUDOCS 8312010284 | |
| Download: ML20082H780 (3) | |
Text
. . _ .-
waM4. (
TIIE CINCINNATI GAS & ELECTRIC COMPANY CINCINN ATI, OHIO 45201
( November 21, 1983 LOZ-83-0234 J. WILLIAMS, JR schoon wet enassesNt NUCLEAR OPEManONS l PRINCIPAL STAFF Docket No. 50-358 L Rn LMCW 7/RA JE _
U.S. Nuclear Regulatory Commission A/RF **
Region III RC MA <- y 799 Roosevelt Road jp0 50 1 l#dN Glen Ellyn, Illinois 60137 %^ I #
ENF File,,hMe Attention: Mr. J.G. Keppler Regional Administrator i
Gentlemen RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 COURSE OF ACTION W.O. 57300, JOB E-5590, FILE NO. 956C, Attached are responses to NRC questions contained in Enclosure 1 of your letter dated November 15,- 1983. Responses to Enclosure 2 will be supplied with submittal of the Plan for the Verification of the Quality of construction (PVOC) and the
, Continuation of Construction Plan (CCP ) .
t Very truly yours, f THE CINCINNATI GAS & ELECTRIC COMPANY i
l
. I , 91t SENIOR VICE PRESIDENT l
GCF/sfr l
i l
Novgg gg3 8312010284 8 PDR ADOCK 0 PDR A
st)l
'I - ..
Mr. J.G. Keppler Regional Administrator November 21, 1983 LOZ-83-0234 Page 2 cc: NRC Office of Inspection & Enforcement Washington, D.C. 20555 NRC Resident Site Supervisor ATTN: W.M. Hill NRC Zimmer Project Inspector, Region III ATTN: E. R. Schweibinz NRC Office of Nuclear Reactor Regulations Division of Licensing ATTN: D.G. Eisenhut L.L. Kintner 1
t I
(
l l
,m _
l
-1 l
ENCLOSURE 1 Questions & Comments on the Course of Action (COA)
- 1. With regard to-the TVQC inspection program, certain elements of your program are still not clear to us. We believe your i
, program of reinspection of accessible work must contain the following:
- a. A 100% visual' inspection of all accessible structures, .
systems, and components. This inspection should be sufficiently comprehensive to assure that attributes that can be seen visually are in conformance with applicable drawings and specifications, codes and standards, and quality records.
! b. Physical inspections (nondestructive and destructive)
- for those cases where the quality records have been que=tioned.
- c. Additionally, sampling physical inspections (as proposed i in your October.5, 1983 COA) of structures, systems, and I components where the quality records have not been questioned.
Please provide clarification of your intentions with respect 4
to the above three items.
Our intent is as you have stated in your comment. The details will be included in the PVOC. See also the i
discussion of physical inspections in our letter (LOZ 0233) to Mr. Keppler dated November 18, 1983 (copy attached).
.. - . . - _ - -. - - . - . _ . . . . . . . - - . - . . . . - . - . . , - . - . ~ . . . . . - , , . . . _
LM%
97 [ 7
~"
T11E CINCINNATI GAS & ELECTRIC COM PANY c2f - --
CINCINN AT1. OHIO 452OI J. WILLI AM S. J R
.... vica..... ~r November 18, 1983 ovecc.. ...o=* -
IDZ 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, the 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, system s, and components (SSCs). Sargent & Lundy (S&L) is preparing lists which classify all such SSCs. Addf tionally, where CG&E FSAR commitments have made other SSCs subject to a forn.'l quality program, these additional items will be evaluated withir PVQC. Such ita include components that are non-safety related but are required to be Seiscic 1 (e.g., nonsafety components routed on top of safety-related components) and portions of the fire protection system.
, The acceptance criteria for evaluating these installations will be provided by l S&L.
The PVOC 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 inspections of l 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 l with the site fabrication and installation of SSCs. Followirn these
! activities, or incomplete. the Then, individual on a SSC'ssampling willbasis, be statused as conforming, confirmatory nonconf orning ['
physical inspections, of conforming SSCs will be performed. -
-/ /
h l / . j (
I
Pgs2 Visual inspections will be conducted on the accessible portions of each SSC.
These visual inspections will identify and record existing identification 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, nonconfocaing, 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 following:
o Piping / mechanical - Visual inspection will be performed on piping ,
valves, welde, pumps, supports, snubbers, restraints, and hang er s, o Electrical - Visual inspections will be performed on exposed conduit, trays and wireways, supports, welds, junc tion 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; equipnent supports; bolting; welding; and special doors.
o HVAC - Visual inspections vill 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 documentation and areas where potential-problems have been identified. The engineering judgements and analyses will l
be documented in accordance with project p roced ure s. Areas to be physically l 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.
l l
l i
Page 3 .
(2) Items identified in the reports of the National Board of Boiler 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 10CRP 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 inaccesaible.
(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 CC&E, is currently evaluating several advanced non-destructive inspection methods for thei*
applicability to Zimmer. The results of these evaluations will be av able 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 ASF!E embedded or buried pipe, concre te structure s, and electrical equipment given in Attachment 3. For example, physical inspections will include, but will not be limited to, the following :
o Bolting will Le 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.
Prgs 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 ctherwise 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 items conformirg, 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, cn; if the visual inspection for an accessible item indicates that the item does not conform, cg; if any physical inspection for the item indicates that the item does not conform.
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 confo rming . SSCs. Thest inspections will be performed as outlined above and will be of sufficient numbers and types, based upon statistical analysis to provide confidence that the relevant items are, in fact, co nf orming 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 4tnd 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 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.
I
P:ga 5 ~
It may be noted that statistically-based sampling has been employed in various '
verification programs for 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 suf ficient level of confidence that the existing 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 construction 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. Ihe verification program will be described in much detail in the PVQC Program which will be submitted to the NRC for review and approval.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By M ,
J. LLIAMS, JR.
TgNIOR VICE PRESIDENT cc: NRC Office of, Inspection & Enforcement Washington, D.C. 20555 NRC Resident Site Supervisor
- 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 m
w
l Pags 1 of 14 ATTACHMENT 1 ,
TYPICAL' VISUAL INSPECTION ACTIVITIEi SSCs identified on the approved Q-list will be subject to visual inspe ctions . 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 FVQC Piping / mechanical Large bore piping Elevation, size, slope, heat numbers, welding, welders identification, line/ spool identification, code data nameplate identification (when required), visual damage
[ 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 flanged), gaskets, welding (if welded),
welder identification, heat numbers, manufacturer, position indicator (open/ closed),
packing, alignment, 4
- _ _ _ . . . _ . _ - - - . . . _ . . . _ _ - _ . . . -___.-.=__.-..._....--m., -, _
Pega 2 of 14
?
ATTACIDIENT 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),
1 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 4
Visual / measurement 9
,w- - . _r---r--- ,.,,,,.---% ., -.~e. ~ ,,--y -.e, , m ,,----.,m r,+-r4--w- e-- r-r, e-
Pogs 3 of 14 ATTACIDfENT 1 (Continuad)
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Supports Size, location, elevation, welding, velder identification, anchor bolt type, anchor bolt size, clamping, thread engagement, heat numbers, identification Visual / measurement Snubbers Size, location, elevation, type, manufacturer, setting, bolting, velding, welder identification, leakage, fluid levels, identification Visual / measurement Restraints Size, location, elevation, welding, welder indentification, placement, fit, bolting, thread engagement,
- identification Visual /maasurement l
l 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 additione, deletions, and/or substitutions necessary as the PVQC is implemented.
Pegs 4 of 14 ATTACHMENT 1 (Continued)
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Elec trical Exposed conduit Size, material type, visible damage, routing, bend radius, smoothness, number of bends, distance between poll points, ground connection, fittings, bushings, Seismic II/I criteria, identification, end seal after 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 / measurement Supports Type and configuration, spacing or location, material type, welding, velder identification (when required),
concrete expansion anchors and connections, identification (when required), and visible damage Visual / measurement
Pcg2 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, 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 conductive material ~ maintained, and visible damage Visual / measurement Cables Type, scheme.
identification, correct termination point, routing, channel separation, clamping, bundling, proper lugs and connectors used, I conductor insertion into lug, proper crimp,
I Pega 6 of 14
,g, ATTACHMENT 1 (Continued)
\.
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 O d 8-Visual / measurement Motor control centers Identification, location, mounting, grounding, shipping splits properly joined, interconnecting jumpers installed, bus bars connected, welded attachments, concrete expansion anchors, and visible damage Visual / measurement I
- , , , - . , ~ , _ - , . - - - - - - - - - , -
. - - , - , , - ~ - - - e -
Pego 7 cf 14 ATTACIIMENT 1 (Continued) l{
Attributes and Characteristics Subject ,
to Visual Inspection 1 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.
, - - , , -.. ,. , - . . - ,- , . , . -,. ,.n ...c., . . , , , . , . , ,
r Pags 8 of 14 e
{% ATTACHMENT 1 (Continued)
I 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, c surface irregularity, exposed rebar, column size and location Visual / measurement Penetrations Location, azimuth and elevation, envelope dimensions, identification (mechanical), visible damage, welder identification, weld
(]) . number, weld quality, material type, displacement / distortion, and concrete
, i Visual / measurement Soils Type, estimated sieve analysis for gradation, organic and inorganic debris, moisture content, grade b' Visual / sample Anchor bolts Size, grade, type material, orientation, ,
location, .i identification, visible damage, full thread engagement, grouting ,
Visual / measurement 1- ,
/
I
- . _ _ _ _ _ - - - - - _ _ . c 1
Pege 9 cf 14
( ATTACHMENT 1 (Continued)
Attributes and Characteristics Subject 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 (h' 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, y, and it is recognized that there may be additions, deletions, and/or
- ) substitutions necessary as the PVQC is implemented.
Pags 10 of 14
'( ATTACHMENT 1 (Continued)
Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Structural Steel structures Size, type, location, welding, welder ,
identification, bolting, thread engagement, hole location, copes, length, heat numbers (when applicable), visible damage Visual / measurement Galleries, ladders, stairs Size, type, location, fabrication, bolting type, size and thread engagement, welding, configuratien, material, grouting (when
(') required), mark numbers (when applicable), and visible damage Visual / measurement Equipment supports Size, type, location, bolting type, size and thread engagement, welding, welder identification (when ,
required), support contact, grouting (when required) identification, visible damage Visual /ceasurement
Pegs 11 of 14
!( \ , ,
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 b ? i 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 ir. tended to be complete, and it is recognized that' there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented.
- ?'
V
Pcgs 12 of 14 ATTACIDIENT 1 (Continued)
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,
,(]h 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 may be additions, deletions, and/or substitutions necessary as the PVQC is implemented, i
'V
. _ _ _ _ . - . _ - -- - - - ~ _ . _ . - . . . _ . _ _ _ - .
Prgs 13 of 14 A.
ATTACHMENT 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 i thickness, adhesion, protective covering
), (when required)
)
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
,~
Paga 14 of 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, welds), line marking, smooth bends (no flat spots), and -
visible damage Visual / measurement Supports Type, size, mounting type and location, inserts, fit to tubing / welding, and/or bolting acceptable, and visible damage l( ) 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 recognic.ed that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented, r-U t
i
Paga 1 of 3 ATTACHMENT 2 EXAMPLES OF CONFIRMATORY PHYSICAL INSPECTIONS l
AREA / DISCIPLINE I ATTRIBUTES AND CHARACTERISTICS I
i 1
1 I. Bolting / Concrete Expansion l 1. Tension (Pull) Test
.hchor Bolts l l A) Verify proper installation I of installed bolt I
I B) ' Verify proper tensioning and l integrity of bolt l
l 2. Torque Test i
I A) Verify nut installation with l required torque applied i
II. Welding / Piping l 1. Testing of weld deposited filler I material (production velds) l l A) Perform NDE I
l -Radiography l -Dye penetrant testing l -Ultrasonic testing ,
1 -Magnetic Particle testing I -Material sampling 1 -Fiber optics and TV camera l inspections l -Plastic impressions of l questionable areas for l outside analysis I
l B) Mechanical tests l
l -Tensile test I -Bend test l . -Charpy V-notch l -Etc 1
l C) Chemical (spectrographic) l . analysis l
l D) Hydrostatic testing of l piping systems
Page 2 of 3 ATTACHMENT 2 (Continued)
I AREA / DISCIPLINE l ATTRIBUTES AND CHARACTERISTICS l
l l
l III. Material Traceability / Piping l 1. Testing Installed Pipe A) Physical analysis l
l -Tensile test I -Bend test I -Charpy V notch l -Etc l
l B) Chemical (spectrographic) l analysis l
IV. Cable & Terminations / Electrical l 1. Megger Test l
l A) Verify cable insulation l 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 .
l of stresscones l
l 3. Resistance Test l
l A) Verify continuity of I circuits l
l 4 Signal tracing to determine l cable routing
- 5. Time domain reflectemeters to l identify discontinuities l
l 1. Megger Test V. Motors / Electrical l l A) Verify winding insulation I integrity I
[ _
Paga 3 of 3 ATTACHMENT 2'(Continued)
I AREA / DISCIPLINE l ATTRIBUTES AND CHARACTERISTICS l
l l
1 l 2. Polarization Index Test l
l A) Verifies acceptable l moisture level in motor l windings l
l 3. Conductivity and chemical I residue testing for break-l down of internal components i
VI. Concrete / Civil l 1. Strength Test i
l A) Rebar mapping of area with I sonic or radar units to l determine appropriate area l to obtain samples l
l B) Core drill to obtain sample I for compression test to l verify adequate concrete I strength 1 .
l C) Schmidt Hammer and k'indsor 1 Probe test to verify I concrete strength I
, l D) Hammer testing to check
' l concrete for voids I
i l l l 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.
I l
f l
.- Page 1 og 2 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. Three cases 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" x 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 e= bedded in concrete. All of this piping is for low pressure service with a design pressure less than 200 psig. A program to perform an early documen:ation 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. Ve will keep you advised of progress in this area.
1
. . , . - . _ ,_ . , . , , ..x. , - _ _ , _ . - - . . . - , . . - . _ . . - , , -
.. Page 2 of 2 ATTACHMENT 3 (Continued)
- 2) Concrete Structures:
Available physical verification techniques are: 1) hammer testing to locate prior consolidation areas, hollow / voids. and poor repair
. work; 2) concrete strength tests such as schmidt hammer, winsdor prode. or selected core samples (e g. 2" size 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 areas), 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 .
O e
0
, - ~ , - - , , , . , , - , ,- , -~---r , - - ---n
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 2
- 2. There is a need for CG&E 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 (e .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.
1
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 3 3.. Please describe what is meant by physical testing for different structures, systems, and components (e .g. , describe what would be considered to be an adequate meaningful test 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.
e e -,e v. - --- ,,%- - - - - + , ,-ww-e.-,,-.r- w,_ - - - -e.,. # ,,, y--,-- ,,7 n - - , , , --- - - -, y ,wey, -- --,,,,,,--,,,---y y-w, verr-m- ,, --c.,,-. , - - - -
-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 PVOC procedures and programs and observation of'the implementation of the PVQC 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 CG&E 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 will comply with this comment.
6 e
4 e
Ouestions & 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 or 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 of communications and records.
I
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 CG&E 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/OC and records review personnel after their exit interview and prior to leaving the site, in other than a group exit situation.
i Questions & Comments on the Course of Action (COA)
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.
s TO: Distribution DATE: November 4, 1983 DSC-0057 FROM: D. S. Cruden
SUBJECT:
Exit 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.
Copica 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 f
-- - --- - 7 m --,-~m- - , , a g, --
r e - , , - - - , .,
~' . .
e-
' November 4, 1983~
DSC-0057 Page 2,
/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 '($echtel)
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 was 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 expanding 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 T
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.
)
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.
1 o
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 staff 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.
l l
i l
l l
l l
l l
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 11 l
- 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 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 1
defining these areas continues and will be provided to the NRC 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.
l f
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 12
- 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.
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.
"Provided it is the decision of the Owners to proceed l
with the completion of the Wm. H. Zimmer Nuclear Power Station, the Board of Directors of The Cincinnati Gas &
Electric Company is fully committed to accomplishing the
- Verification of Quality and Completion of Construction described in the Course of Action document dated l
September 30, 1983."
l
, . _ _ . _ , , - . _ . , _ _ _ . . _ - , - . - ~ , _ , . . _ , . _ _ _ _ . . _ _ _ _ _ _ _ . . . . _ _ _ _ _ _ _ _ . , _ _ , , . . _ , . , -
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 13
- 11. Confirm CG&E's intentions to have on the Board of Directors a nationally recognized individual who has broad experience in the commercial nuclear power industry from a business viewpoint, from.a management viewpoint, and from a OA viewpoint.
CG&E will have on the Board of Directors an individual-such as described above.
i l
l l
Questions & Comments on the course of Action (coa)
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 include the elements of the QA program that comprise the design control system.
We believe these audits will accomplish the recommendation of Torrey Pines.
Questions & Comments on the Course of Action (COA)
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 effectiveness of the Zimmer Project QA Program.
Is a similar type audit planned to assess CG&E management effectiveness (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 CG&E consider that such an audit is required since the Zimmer Oversight Committee will provide a continuing review of all aspects of project management.
i l
l
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 16 0
a
- 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 QA 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 auditing of training, document control, inspection, regulatory commitment program and corrective actions and audits will be scheduled early in l the life of an important, activity when the need is more critical. Flexibility will be provided in the audit schedule t
l to allow for unscheduled audits that will cover identified
~ 'l ,
problems. .
I e
.a e t
N
!s 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 PVOC and CCP to assure comprehensive audit coverage.
Questions & Comments on the Course of Action (COA)
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.
Questions & Comments on the Course of Action (COA)
Page 19
- 16. Mr. Dickhoner's COA transmittal letter states approval of a substantial increase, approximately doubling the staffing, in the number of CG&E people assigned to the accomplishment of the work which lies ahead. Provide an organization chart which indicates where the old and new CGEE personnel are or will be assigned. (DSC)
The response to this question is being compiled and will be provided in a subsequent submittal.
3 Questions & Comments on the Course of Action (COA)
Enclosure 1
, Page 20 l
- 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.
j 9
i i
t l
l
. - . - , , _ . . . - ~ . ~ . _ _ . _ _ . . . . . . . _ . _ _ . _ _ . . . , . - . ,
- . . .. _ . ~ . -.- -. .. _- - -
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 21 l
- 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 remedies proposed in the COA adequately address these
, problems?
CG&E 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 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.
t i
Questions & Comments on the Course of Action (COA)
Page 22
- 19. The report by Torrey Pines Technology (TPT) describes an adversary relationship between CGEE and Henry J. Kaiser (HJK). 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 significar 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 causes of past problems have been analyzed and organizational solutions have been developed where appropriate. CG&E will manage the Project Director, Bechtel, from an oversite role and Bechtel will manage and direct all activities of HJK.
CG&E and Bechtel are committed to interview key HJK personnel, and emphasis on the importance of a good working relationship and teamvork will be discussed. These ideas will be communicated to the first line supervisors. All site employees are undergoing indoctrination and training,
i ,
4 1
, . Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 23 attitudes are changing and cooperation and teamwork will be achieved. ;
4 i
i h
i 8
a I
1 4
1
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 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, 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 policy statements issued by CG&E, Bechtel, Sargent & Lundy, and/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 i
statements have been provided to all employees on-site. In addi tion, the principal contractors have aupplied 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.
i I _
=- .
- ~
s.
j f-
- -THE CINCINNATI GAS & ELECTRIC COMPANY d(Ic.T "~
CINC NN ATI.CHIO 45201 W. H. DICMHONCR
""'*~
STATEMENT OF 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, codes, and standards.
B. To obtain a high degree of quality, integr ity, 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 Zimmer tha t 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 Zimmer 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.
Pcgo 2
~
. Ras Statem:nt of Policy Portaining 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 f or 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 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 requirements set forth in the Quality Assurance Program are not being fully complied with, or (2) that the impleme.3 ting procedures for said Program are not being f ully 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 a re no t resolved, he or she should inform successively higher levels of management, including the Senior Vice President, Nuclear Ope ra tions (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 (553-20 21 ext. 376).
CG&E will treat these concerns confidentially and give them urgen t a nd ca ref ul 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 between this Policy and other CG&E Policies, this Policy takes precedence for all matters conce rning nuclear safety-related work on Zimmer.
./F M W. H. DICKHONER, PRESIDENT THE CINCINNATI GAS & ELECTRIC COMPANY 7/so/n DbTE /
m -
,, g+ n -
- g.c -
- nl l ,-
TH E CINCINNATI GAS & ELECTRIC COMPANY dT CtNCIN N ATI. OHIO 4 5201 J. WILLIAME J80 October 14, 1983 samsom vect Patssota, oc6 t. . ..t .. . ..
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. j 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 free 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 spec fically 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.
. e *
- 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
. Y % .
. Williams, Jr. I
~
( ,
Bechtel Power Corporation i 777 East Eisenhower Parkway )
Ann Arbor, Michigan '
Meet Amess. P.O. Box 1000. Ann Arbor, Michigan 48106 l
STATEMENT OF POLICY l PERTAINING TO THE QUALITY ASSURANCE PROGRAM FOR THE WM. H. ZIMMER NUCLEAR POWER STATION !
l 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.
B. To obtain a high degree of quality, integrity, and reliability ine' the design and construction to ensure that operation of Zimmer will be safe and reliable. .
1 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 Zimmer 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 Assurance Program.
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 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, s
r
(- 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 his 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 tolerated. 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 Zimmer.
Howard W. Wahl Vice President and General Manager i
O I(
i l
f Nj.5;\}RY 5 l0 ll235 C.~'?iidR4.hiY
, s an e.e, w, rr em A*' '! C, C a t_ l SiOJf A Nul:
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 manner that will enable CG&E to complete licensing requirements,and ultimately become one of the nations most reliable nuclear plants in. terms of sa.fety, perfonnance and public confidence.
e Henry J. Kaiser Company is committed 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 cmployee to meet its overall goal of coninitment 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 and 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.
. t Dona d G. Iselin Chainnan of the Board Henry J. Kaiser Company
1-/ENRY /. eYA/EER CDMR4NY 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 complier 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 '.be quality assurance and construction programs to assure that all work ueing performed: a) complies with the requirements established in tk.e site quality assurance programs, b) iden-tify procedural deficiencica 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 A v'P.t0*.O INTEPN ATIOP. A L cot.'PANY
. .. . . . - , , . . - . . - , - _ ~ - - - . - , , , . , - , . , . . . . , .. . - - . . . . . -
\ . -
Q Statement of Policy October 28, 1983 Page 2 Every employee and organization that performs nuclear safety-related activitie; 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.
/
/J.
Donal
. Jke G. Iselin Chairman of the Board Henry J. Kaiser Company t
1
- - ~-. , . . - , . . . . . . - , , , - . . , - - - , . - . , , , - . - , - , - , - - . . . - . , - - - - , , . - -
., Hi ' V ': .! K A !E~l .*
-w.., ue. .
POLICY STATEME*r HENRY J. KAISER'S CUALITY ASSURANCE PROGRAM FOR THE WP. H. ZIMMER NUCLEAc. POWER STATION henry J. Kaiser Company is committed to construct the Wm.. H. Zimmer 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 commitment to quality transcends the highest level of corporate manage- ,
ment, and includes all individuals performing work activities at Z1mmer.
Each individual is responsible for imolerentine and adnering to the policies and requirements of tnis Program.
Tre Quality Assurance Program provides for periodic audits, surveillances, and prograr evaluations. These reviews will be used by appropriate management personnel to assure the adequacy of the H. J. Kaiser Q. A. program. /
Procedural deficiencies and material non-compliances are to be quickly identified and corrective action taken in a timely manner. All items of non-comoliance are to be 'corre'cted in such a manner that the cause of tre condition is clearly identified, and that corrective action to preclude recurrence is implemented.
H. J. Maiser's 0.A. Program further provides for the evaluation of all deficiencies and non-compliance for the determination of repcrtability in accordance with 10CFR50.55(e) and Part 21. To assure that all deficiencies and non-comoliance are approcriately resolved, both the Site C.A. Man 3;se and the Project Manacer are charged with the authority and responsibility to stop work if necessary.
Any cerson having concerns regarding the irplementation cf. or compliance with, the 0. 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 higner levels of management, including the RAE Project Director - Mr. M. E. Noffsinger, 553-6740.
Individuals should also feel free to take any such matters to the attention of CGLE, the NRC or the NRC Resident Inspector (553-2011. Extension 37c).
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.
I i
l 1
L ..
)*
Henry J. Kaiser will handle these concerns confidentially, and give ther.
, urgent and careful consideration. There will be no reorisals, penalties, or discriminatory action taken toward any individual for bringing forth such concerns to HJK, CGLE or the NO.C.
This policy shall be carried out in accordance with Henry J. Kaiser's Co pany Colicy and Quality Assurance ranuals. 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.
7 $ .{ % y -
M.E.fioffsin'ger/,(} .
RKE Project DirectcN '
n.s.cauan, y;;;; -
Raymond Kaiser Engineers ._ _' W 2 8 E
, - . nu:
-t *: - '
n:y.;,n s in.
=
.. .. s a: . .
TO: ALL HJK EMPLOYEES PARASSMENT IN THE WO:t OLACE As emoloyees at the Wm. H. Zimmer Nuclear Power Station, we have an obligation to exercise our "best efforts" in the performance of work assignments. Strict adnerence to federal, state and local laws, jobsite policies and work proce-dures is mandatory.
It is the responsibility of nanagement to assure that the performance of work assignments can be accorplished in an environment that is free of inticioation and harassnant.
The Henry J. Kaiser Company will not tolerate intimidation or harassrent of eroloyees at Zimmer. If, at any t'me, you feel that pressure is being exerted to violate federal, state and local laws, or jobsite policies or procedures, you should inmediately contact your suoervisor. Should your supervision be unavailable, non-responsive or a party to your concern, you should croceed tc the next higher level of nanagement.
In the event you feel that your concern has not been sufficiently addressed.
inmediately contact one of the following managers - Mr. Keith Derpsey, Froject Manager - 553-2163. Mr. Dick Davis, Quality Assurance Manager -
E53-3635 or Mr. Mike Noffsinger, Project Director - 553-6740. I can assure ycu that all concerns will be addressed and the aporcoriate acticn taken to resolve all concerns.
As you are aware, Rayr.ond International and the Kaiser family of cercanies are Equal Ecoloyment Opportunity employers. As such, we are bound by all laws and regulations that address this commitment. Should an emoloyea believe that they are being discrininated acainst or harassed in a manner governed by Equal Employnent 0poortunity laws, they should contact our Industrial Relations Department, Mr. Steve Armxnecnt. Industrial Relatior.s Manager - 553-4963.
Procedures are currently being developed to reflect the above policy. They will be presented in our Enployee Greivance Procedure No. V-9 which will be issued in the near future.
M c.Lb fm . m--)
M. E. hoffsinger l' RKE Project Dirlector 1
i 1
1 1
,, n _u
,nn_ _
~
,*13,~ y- 9 y ~*r*yra --
l
. .u.s3 ,
~
e ., .O g
- e.. ##- ... .
.. . ,, , .s " ..*
-~ ". .
s nann &Lu, m -,
- . - w . . .. .. . . - . . .
.m&..-.d..5c.:.w$.. (Y?D. & w .,:
- ENMNNEW j' -l
,o_....
O' c
- $*ws:lIM*'.: '.w.. y.
- v. :... . Q 0 y. a. . .o .I Ip
..y . . u... a ...y. .
7
- q. 3 9 ., p .x n ;;; ..- .;y..,
. su., .,
...casr%ownot svncer :
,,,_. w.
.: u.: ^ . j. . :L . : r: m :y .y. i. t:. ... .,
', i
- h D.QQkl && "Q'g{,0f(ff'f )!ff.yjfShf. *
- 2. g n::..e. , . m e. s ...,
.p. l .q, ',{ .
.nbm.m.sm
.s.
. .. ... ,..e p d- . w.. y-
.e w ....:....v.-
.t 4 g.
e . '.?.s .yl. .a. .. ,,-.y~ , ;y-un:, ..
w October,< . .- . . .
- .. ~:
, A. .9-::: 8 x.3..:.1;: .
. . ;. .w. . ...: . - ::.-. a . . . ~..: ;.....;;,'19
. . ~ .
!;p.'..:': ; ,
,...-v .s.
. m..
- = .
- .: sA. ;.:.:,2,.:m., ,2,.
- n. a ..w m : :,:~. . : - M
~ u a .:>.w:,
w.
.n.,,w. q ..av. 4,:;.
- p. ..r.1: m. (jm,:
- e. .
. s.... .
. . .. x: 4..s. ~..,'. .
Y: ..
. . ': ,.; c .. ~
< "o
" p L, .' q
. . , ..?,. W-
./ - ;
.- STATEMENT OF POLICY BY SARGENT &~ LUNDY f.3.< ,h v..,
ON THE SUBJECT OF. HARASSMENT ., 5-p py. ./.l.f,M 43 W..R. MM. .',lE
..[*,.;. "' j FOR THE WM. 's
[.N.y ! .: l
- H.
. ; r- ' :<; ,: . ,
.L.:h,. . n: f. .~x.. ,. a.
ZIM!iER NUCLEAR POWER PLANT/.MN. .. M. . .sM N .
, . . ,; .h . ;a. y.: h. ., ; ;.:.: ..s.
M!%.l.V..:.4.. h
. :. , . ~ .a .
- .-. .&. :m. "y: ,:y.7.?.W :.
.- n~
- .. j ,3.: . . . .
- .'. .:. ,-- , . .... n -,. -.2 3
, y ,.:,a. x.
..e ~. ..e .w,% .p: ;y.u..v. 9W u.
.. p; . . '
3 .,::g: 33..y.. g ;.Q.Q3.w:. 49. ,p __
-s
. . ; . w. .
j.{ 'Vf .
'It'li,s th'e policy. of Sargent & ;Lundy. that' any' person :having C5'Xg,'.
A' 1' O - concernsc ' regarding the quality of. the Zimmer plant , design .' , Mi .
n/.-
{complian'e with quality procedures',' orfother. pro'je'et M.d7;. '
iO :)
' procedures.be encouraged to contact'his or h'er. supervisor, 'h cy~j;'b.e'- :.1'
$ .6'~--
. '.the fear Head,' Quality Assurance Division,'or{my officeYwithout j g,E![
of harassment.
--. .:W ' . . - ;
. * ,.,' : . n . w:: 6, ..,. .
. . , .I; ..* , , .,#. , J '. : ** ,~ . ..,.
.* . ['. . ' 'q.,g1.j;,p* ,-g. ,. . % ....H . ^
Sargent s'Lundy h'as continually recognized and emphasized the importance of quality-related design and encouraged; f.
~
empl'oyce participation. in the identification"of fitems QfS- . T.4 requiring corrective action'. - Furthermoie, ':thh 'Sargeht WLdddy *%
Quality Assurance Manual'establishe's procedures for the identi- c: .
fication of design. deficiencies land..their corrective action. .
for nuclear safety-related activities. ".^ .e
- S '. . f.. vy '. ."; ' '-
..~ . . .
...n
' Althotigh there has been no evidence. of' harassment and . r ., ;.,, .~,
. . . ~ . . .-
9
-~ intimidation by Sargent & Lundy staff on the Zimmer' project, %..
e .
,, . nexperiences'harassm.
.,ii.t...is .of particular .impo.rt. an,ce to. me .~ t. h.a t ,a.n.y . pe. ~ . . r.s. on .
~ . . , .
v
' .m'. ; ;;.
- Tiperform his/her . job,- report any]sdch incide~ht -in.ac'cordanbe' f(, $' .',-
,:.' & lwith.this policy. . Intimidation or'harassmentlof.any'. project.J..; y .
.1 employee will'not be tolerated.l. Employees' feeling that they,and.if '/4
, ,(,are being'. harassed should inform their_ Supervisor; ~~.. . ci.
g.
.o *
3 - 2" their concerns arc ~n'ot handled to their satisfaction,' higher '
s l^.
~ !. levels' of-ma'nage~ ment, -includiniy my office ' (312/269 ~.1970) ,' .-
1.~,.. 1 u. d.O[, a...s.S W... .~.'. T .. . .
. : s,h o. u.l d b. e. '.c o n t a c t e d .
c.
e .
. '... :n / . . . - ~~ -
- . . . p . ..
. .. .. v: +
'.w.
- ' Sargenti Jg'ive..them '6" Lundy urgentwil.l and. careful treat these consideration. concerns confidentially, *and . ,.v.
.: ~ --
~
' . . 3:; 1. - C ".#.'
. . . - .. L SARGENT & LUNDY
- . 4 .
r w is4 ~' -
R. c' . Scheibel -
,. 9 .
4 .
~
GENERAL ELECTRIC N U CLE AR EN ER GY BUSINESS GROUP GENERAt ELECTRIC COMPANY, P.O. BOX 177, NEW RICHMOND, OHIO 45157 Phone (513) 553 2011 Ext. 244/376 nrn '
~ RECEIVED D. S. C9tlD[fi i' I'"h TEBZ-113-83 November 10, 1983
._ J NOV111933 F:ti:
- TiiuT O C
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 and 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 policy statement on harassment by the GE Startup Test and Operations manager, or by me, as appropriate.
Yours very truly, f .~
T. E. Bloom Resident Site Manager Zimmer 1 Site TEB/md cc: d.C. Brinkmann I.L. Gray G.B. Jones J.A. Steininger E.J. Wagner file i
i I
.' GENERAL h ELECTRIC [gl. u $
m NuCLEM FO%iR SYSTEMS oMslON g}$1 GENERAL ELECimC CO.YPANY
- 175 (URTNER AVENUE o SAN JCSE. CAL:FCRNtA 95195 ftC 394, (408) 925-3307 October 26, 1983 RESP 0?lDS T0:' Reference CGE-1791 l /
bec:t T. E. Bloom, w/atts.
i Mr. G. B. Jones, Project Manager J. A. Steininger w/atts.
Bechtel Power Corporation S. W. Coulter, w/atts.
P. O. Box 113 File 29, w/d tts.
Moscow, OH 45153
Dear Mr. Jones:
SUBJECT:
Wm. H. ZIt@tER NUCLEAR POWER STATI0ft UtlIT 1 POLICY STATEitErlTS
Reference:
Letter G. B. Jones (80chtel) to T. E. Bloom (GE) of October 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, tionetheless, 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 not ordinarily made available to those outside General Electric Co.mpany, i 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 l Zirrer 1 ILG: pes /108S Attachments: 1. Ccmpany Policy Statement 20.1
- 2. Statement of Policy and Authority (NE00-11709)
L
..iv..
GENER AL h ELECTRIC -
r ORGANIZAflON AND POLICY GUIDE I>dJ
.--a. -
Issued by: Corporate Esecutne Of0cc T,*.B: Company Pcticy Stater.'.:nts gg g7,,.8 ER: 20.I' If SUED: 9/1/81 SUPERSEDES: old Policy 20.9 (10/i6n8)
COMPANY-WIDE QUALITY OBJECTIVE STATEMENT OF POLICY It is the objectise of the General Electric Company to it is the policy of General Electric. in offering prcducts perform all activities with dedication to quality: the and sersices that Gil 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 ration for quality leadership, and to mesit customer trust '
audiences; and the quality ofits fulGilment of citizenship because full value is being received.
responsibilities. In support of this objectise, the Com-
- It is the policy of General Electr c, in fuln!!ing its pany encourages the achievement of indisidual excel- social responsibilities and ih every aspect ofits retstion-lence 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 attninmen,t of qua!ity Icadership. '
r .c.ms attaining a level of overa!! per form ance and at-titude that makes General Electric the natural choice
- ./.PLEMENTAY!CN AND MEAGUllEMENT cf customers and earns the respect of a!! thpse.af.
fected by the Company's actisities. Responsibility for implementation and measurement j under this Policyis assigned to the Sector Executives and
< n Company wide Quality, as an individual objectise,is coiporate Senior Vice Presidents, who will conduct the achiesed by employees who aspire to be better than ; ffairs of their respectise components in accordance the best. General E!cetric is committed to assisting with this and related potieies.
employces in their pursuit of excellence by providing The Officers notM alose shall make regular repoits th:m with the leadership, cooperative climate, train- to the Corporate Exceutive OfGce on fulGilment of ing, faciliti.s, and materials consistent with the mer-Company wide Quality objectives by their ccmponents, a:1 Company quest for quality. In measuring and rewarding both indis idual and man-agerial effort at all echelons, the highest value will be placed en qua!!ty perform.mee that reflects exce!!:nce, crcatisity, prcJuctivity, ar.d pride in accomplishrnent.
i
N dDO 112C3 4
12 31 02 GENERAL ELECTRIC COMPANY 175 Curtner Avenue San Jose, California 95125 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 Assurance Program which is to be used by the Nuclear Energy Dusiness Operations to fulfill this policy. All ownngers
) within the Nuclear Energy Business Operations with quality related responsibilities have full authority to implement the program within their respective areas of rcaponsibility. Development of procedures to implement the Quality Assurance Program is a basic responcibility of each of the organimtions 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 E!cctric management.
A8 '
AWin W. II. Bruggeman Vice President and General Manager Nuclear Energy Business Operations XV[M VI
Questions & Comments on the course of Action. (coa)
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 its Safety Evaluation Report (NUREG-0528) and Supplements, and as documented in CGEE letters and in its Final Safety Analysis Report and Amendments. Describe how 3 assurance is obtained that commitments have indeed been fullfilled, (i.e., result in equipment changes, procedure changes, or organization changes, as applicable.) The CGEE 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 j data base for distribution to the responsible department l
manager and/or Assistant Vice President.
NLD requires that the responsible individual respond in l 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 documentation to verify commitment closure.
i e
1 1
! /
-_-.,_,m . . - _ , , . . m.,- . , ,, ._._m-_ .,,,,_,,,,,.y,., ,.,,_-..w.,,.,,._,,_m,.,. o . __ .,,,,.,_m ,.- ,% __a'.,_..__.m. -
Questions & Comments on the Course of Action (COA)
Page 26 Documents issued to CGEE 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.
h
~
p Questions & Comments on the Course of Action (COA)
Enclosure L '
Page 27
/
- 22. It is not apparent who will Ifa form 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) s CG&E processes FSAR changes in accordance with approved procedures. The Manager - Nuclear' Licensing Department (NLE) is responsible for coordinating FSAR changes. The Architeht/ 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 t
accordance with their approved internal procedures.
A Proposed FSAR_ changes,-as identified by CG&E departments, the
+ '
, , ,c A/E, the NSSS Suppliar~and other outside organizations, are forwarded to the Manager - NLD for processing. NLD engineers L coordinate review of the proposed changes. NLD distributes l
the proposed changes to appropriate CG&E Assistant Vice Presidents, department managers and other organizations for review. ProposedchangesafereviewedbyCG&Emanagementand i
other experienced engineers for technical accuracy, content, c
, z v .-
and compliance with codes, standards, and other regulatory V'
commitments.
s
/
Questions & Comments oa the Course of Action (coa)
Enclosure 1 Page 28 NLD is responsible for resolving all reviewer comments. Upon resolution of comments, NLD transmits t.he approved FSAR changes to the A/E for final processing as a revision and transmittal to the NRC.
(
) k' s
--.,r ,, . - , , -n, ,
. ,, -.,,, ,,-,,..e n,--v-,. r---.-,- ,-e,.--,-- .r- ,---,w,
Ouestions & comments on the course of Action (coa)
Enclosure 1 Page 29
- 23. Has the Master Training Plan been developed? If it has not, when do you expect it to be completed?
The Master Training Plan is being developed. It -is expected to be completed in December.
1 4
2 i
9
Questions & Comments on the Course of Action (COA)
Enclosure 1 Page 30
- 24. Define the terms " project direction", " administrative direction", and " access", as used in- Figures 1 and 2, Volume 1 of'the COA.
The Project Manager'provides " project direction" through the establishment of policies, procedures, project objectives and daily communication with key staff members and contractor management. Project direction indicates the individuals or functions with direct line responsibility for implementation of organizational and departmental activities consistent with the direction of the Project Manager.
" Administrative direction" indicates the individuals with key communication interfaces required on a day-to-day basis to ensure that the Project Manager's directions are carried out and activities are coordinated and consistent with project objectives.
Where it was considered advantageous for individual positions or functions to advise, review, recommend or otherwise communicate outside the conventional direct line authority on matters important to the construction and operation of the Zimmer Project, a formal direct " access" path was identified for such communications. Changes in policy or direction as a result of such communication will be directed in accordance with established policies and procedures by the individuals
Qaestions & Comments on the Course of Action' (COA)
Enclosure 1 Page 31 with direct line responsibility for construction or operation of the project.
.. - . - - . ., . --. . . . _ . - - . . - - _ _ . , - , . . - - . .