ML20128E416
| ML20128E416 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/27/1984 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Bauser D SHAW, PITTMAN, POTTS & TROWBRIDGE |
| Shared Package | |
| ML20127A137 | List:
|
| References | |
| FOIA-84-415 NUDOCS 8505290381 | |
| Download: ML20128E416 (22) | |
Text
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r q
k QQVOlb UNITED STATES 8
g NUCLEAR REGULATORY COMMISSION D
j WASHINGTON, D. C. 20555 1
g,.....j DEC 2 71984 Deborah B. Bauser, Esq.
Shaw, Pittman, Potts & Tr wbridge 1800 M Street NW.
Washington, DC 20036
Subject:
Dear Ms. Bauser:
This is an interim response to your letter of May 22, 1984 requesting, pursuant to the Freedom of Information Act (F0IA), copies of all agency documents relating to the October 1983 report by Judge Helen Hoyt and Sebastian Alcot on NRC investigations at the Zimmer Nuclear Power Station.
In responding, we have construed your request to encompass only those documents generated or reviewed by the investigation team.
A listing of the responsive documents is attached. The following are being released in their entirety in connection with this interim response:
1-10, 19, 39, 42-43, 45, 47, 57, 62, 66, 74, 80a, 81, 82, 88, 95-98, 100, 110-111, 114, 119, 126, 128-29, 132, 138, 140, 141, 144a, b and c. 146, 148, 151, 162-163, 172, 210-213, 216-228, 230-231, 233-237, 241-248, 251-255, 258-261, and 270-275.
In addition, the following documents are being released in part and withheld in part:
130, 149, 164, 167, and 170. The portions of the above documents being withheld in part at this time contain information the release of which could, in the agency's judgment:
(1) cause an invasion of privacy of individuals who assisted in NRC investigations (Exemptions 6 and 7(C));
(2) interfere with ongoing investigations or enforcement matters (Exemption 7(A)); or (3) reveal a confidential source of information (Exemption 7(D)).
5 U.S.C. 552(b)(6) and (7) and 10 CFR 9.5(a)(6) and (7). The agency is unable to identify a countervailing public interest in disclosure which, in its judgment, outweighs the agency's or individuals' interests in confiden-tiality under Exemptions 6 # d 7 of the F0IA. The documents or portions identified above as being released at this time are being placed in folder F01A-84-415 under your name in the NRC Public Document Room (PDR),1717 H Street, NW, Washington, DC 20555.
In addition, copies of these documents, l
at a cost to you of seven cents (7c)a page, are enclosed with this interim response.
The following documents are being withheld in their entirety under Exemption l
5 of the F0IA (5 U.S.C. 552(b)(5), 10 CFR 9.5(a)(5)):
145, 229 and 232.
These documents are drafts of document number 237 (released in its entirety l-in connection with this interim response.) Because the documents reflect the deliberative process between the Chairman and the investigation team, the documents are exempt from mandatory disclosure pursuant to Exemption 5 8505290381 841227 PDR FOIA i
BAUSER84-415 PDR d
I
[).<
Deborah B. Bauser 2
I of the F0IA, 5 U.S.C. 552(b)(5), and the Commission regulations, 10 CFR 9.5(a)(5).
Release of these documents would tend to inhibit the open and frank exchange of ideas essential to the deliberative process. Mr. C.
Sebastian Aloot, Office of the General Counsel, is the withholding official with respect to the documents or portions thereof identified in this and the preceding paragraph.
In addition, the following documents are tapes, typing diskettes or indices of diskettes containing interviewee statements which were reduced to writing and are subject to your request in that form:
172-209. The indices identi-fied in documents 191-201 and 206-208 are being released in connection with this response.
Since the information contained in the tapes or diskettes is in written form, the agency can identify no overriding need to separately release these tapes or typing diskettes.
However, should you desire to refer to the tapes or diskettes, please contact Carol Ann Reed at (301) 492-7246 to obtain access to these documents.
This denial may be appealed to the NRC within 30 days from the receipt of this letter. Any such appeal must be in writing, addressed to the Secretary of the Commission, U. S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial F0IA Decision."
Due to the possible impact on matters unrelated to the October 1983 report, the remaining documents require the review of the originating agency offices to determine whether: (1) the withholding of any portion of a document is warranted under F0IA; and (2) whether the public interest requires the release of such portions notwithstanding the existence of a relevant exemp-tion under the F0IA. These reviews should be completed in the near future.
Once they are completed, a final response to your May 22, 1984 request will be provided.
Si rely.
J M. Felton, Director Division of Rules and Records Office of Administration Attachments: As stated
p -
LIST OF RESPONSIVE DOCUMENTS 1.
Ltr. to. Earl A. Borgmann, Cincinnati Gas & Electric,
.fr. James G.-Keppler, Director, Region III (2/1/79) with Notice of Violation &_I&E Inspection Rt; rt No.
50-358/78-3C 2.
Ltr. to-Earl A..Borgmann, Cincinnati Gas & Electric, fr. G. Fiorelli, Engineering Support Eranch, Region III (3/26/79) with Ltr. fr. Cincinnati Gas & Electric dated 3/2/79 re:
Corrective Actions Taken 3.
Ltr. to Earl A.-Borgmann, Cincinnati Gas & Electric fr.
G. Fiorelli, Engineering Support Branch, Region III (1/7/80) re Inspection of K. D. Ward on 9/18-20 and 12/11'& 12779 -
Enclosure:
I&E Inspection Report No.
50-358/79-17 4.
Memo to V. Stello, Director, I&E fr. William J. Ward, Senior Investigator, I&E - (4/30/80) Subj:
Discussion of Interrelationship of I&E Investigative Program with that of OIA 5.
Ltr to Earl A. Borgmann, Cincinnati Gas-& Elec., fr s
James G._Keppler, Dir., Reg III (7/2/80) 331 Zimmer Investigation by Phillips, Ward & Vandel on 7/2/80 4/7-9 and 4/30, 5/1-2 and 5/20, 1980 with Notice of Violation & I&E Inspection Report No. 50-358/80-09 6.
I&E Inspection Report No. 50-358/80-09 (7/3/80) re inspection conducted April 7-9 and 30, May 1-2 and 20, 1980 7.
Ltr. to James G. Keppler, Director, Region III fr. Earl A. Borgmann, Cincinnati 3as & Electric, (8/4/80) re Corrective Action Taken in Response to Notice of --
Violation, I&E Inspection Report No. 80-09 8.
Memo to James Cummings, OIA fr. Commissioner Ahearne (12/15/80) 33t Thomas W. Applegate Allegations 9.
Ltr. to Commissioner Ahearne (12/29/80) fr. Mary Eastwood, Office of Special Counsel - Transmitting Thomas Applegate & GAP Allegations re Zimmer (annotated)
- 10. ' Memo to Commissioner Ahearne fr. James Cummings, OIA (1/5/81) re Thomas A. Applegate Allegations
4-4.;
2 11.
Memo to V. Stello, Director, I&E fr. James G.
- Keppler, Director, Region III, (1/12/81) 'Subj. :
Zimmer - GAP
. Request for Investigation by Merit System Protection Board Concerning NRC's Handling of Applegate Allegations
- 12. - John Sinclair - Handwritten draft of Report of Interview with Gary Phillip, Region III Senior Investigator (12 pages) (1/13-15/81) 13.
John Sinclair - Handwritten draft of Report of (Interview with Gaston Fiorelli, Engineering Support Branch, Region II (1/26/81) (3 pages) 14.
John Sinclair - Handwritten draft of Report of Interview with Charles Norelius, Chief (Assistant to the Director), Region III ~(1/26/81) (4 pages)
.15.
Memo to Norman Moseley, I&E fr. David Gamble, OIA 1/25/81 - Subj:
I&E Investigation into Information Flow Concerning the TMI Accident (with Moseley 2/2/81 response to Gamble) 16.
John Sinclair - Handwritten draft of Report of Interview with Kavin Ward, Inspector Region III (3 pages) (1/27/81) 17.
John Sinclair - Handwritten draft of Report of Interview with James G. Keppler, Director, Region III (6 pages) (1/29/81) 18.
John Sinclair - Handwritten dratt of Report of Interview with Gerald A. Phillips, Senior Inspector, Region III (22 pages) (2/3/81) 19.
Ltr. to Louis Clark, Director, GAP fr. James J.
Cummings (2/4/81) - Discuss Arrangements of Confidentiality Made at January 7, 1981 Meeting with Cummings, Devine, Sinclair and Schnebelen 20.
Memo to File fr. John Sinclair, OIA (2/5/81) - Subj:
Investigation of I&E Efforts Pertaining to Investigations of Alleged Construction Deficiencies at the Zimmer Nuclear Facility (Applegate) 21.
Memo to C. E. Corelius and R.
F. Heishman, Region III fr. Bert Davis, Region III (5/9/81) - Subj:
requesting
. documentation of areas investigated relating to Applegate allegations)
f.
3 22.
Memo to V. Stello, Director, I&E, fr. James Cummings, CIA (2/10/81)
Subj:
Transfer of Documentation Provided by GAP (2/9/81)
- 23.. John Sinclair - Handwritten notes re contact with Thomas Devine, GAP (2/13/81) 24 John Sinclair - Handwritten draft of Report of Interview with Thomas Vandel, Resident Inspector - with interview notes attached (2/18/81) (14 pages) 25.
' John Sinclair - Handwritten notes re Interview of FBI, Special Agents, Chicago Field 6ffice (R. Buckley &
William Dyson) (2/19/81) (1 page) 26.
John Sinclair - Handwritten draft of Report of Interview with David Ward, Region III Inspector 33!
Applegate allegations 2/23/81 (8 pages)
'27.
Memo to File fr. Bert Davis, Region III (2/23/81)
Subj:
Telephone Call fr. Thomas Applegate, February 19,.1981 28.
Memo to File fr. Bert Davis, Region III (2/25/81)
Subj:
Telephone Call with Thomas Applegate, February 23, 1981 29.-
Memo for File fr. Bert Davis, Region III (3/5/81)
Subj:
Telephone Call with Ira-Rosen, "60 Minutes"
'3 0.
Memo for R. F. Heishman, Director, Resident Project Inspector, Region III fr. Bert Davis, Region III (3/9/81) - Subj:
Comments on first Applegate allegation drafts & M.S.P.B. Request for Investigation of Allegations 1-19) 31.
Memo to File fr. Arthur Schnebelen, OIA (3/9/81)
Subj:
Telephone call from Thomas Applegate 32.
Memo to File fr Arthur Schnebelen, OIA - (3/9/81) Subj:
Telephone conversation between Schnebelen, OIA, and Bert Davis, Reg. III re Applegate identifying himself as undercover NRC investigator.
33.
John Sinclair - Handwritten draft of Report of Interview with Duane H. Danielson, Chief, Materials &
Process Section Region III (3/11/81) (4 pages)
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- 34. -John Sinclair - handwritten draft of Report of Interview with Richard C. Knop, Chief, Project Section, Region III (3/11/81 (3 pages) 35.
Transcript of 2/26/81 mtg. between Region III personnel, T. Applegate, and representatives of GAP (131 pages).
- 36., Memo for V.
Stallo, Director, I&E fr. James G. Keppler, Region III (3/17/81) - Subj: Investigation of Applegate Allegations Related to Zimmer 37.
Ltr. to Jim Cummings, OIA fr Julian Greenspun, DOJ (3/17/81) - discusses problems related to civil and criminal proceedings, willingness to expedite joint cases.
Attached -3/14/81 note to Dudley Thompson forwarding DOJ Letter.
33.
List of items (3/17/81) transferred to I&E fr. John Sinclair, OIA, (with note of receipt of-items by T.
Devine, GAP 5/5/81) 39.
Note'to Art Schnebelen, OIA, fr Dave Gamble, OIA (3/24/81) re breakdown of GAP /Applegate Allegations between IE and OIA.
40.
J.
Sinclair - handwritten draft of Report of Interview Interview with Thomas E. Vandel, Inspector - Wolf Creek. (4/1/81) (12 pages) 41.
J. Sinclair - handwritten draft of Report Section
" Review of. Welding Records." (4/1/81) (3 pages) 42.
Note to Commissioners fr. James Cummings, OIA (4 / 9/81)
Forwarding Draft GAO Report on OIA, without Report.
43.
Memo to Multiple Addressees fr. James Cummings (4/10/81) Forwarding Draft GAO Report on OIA without Report 44.
Draft of agenda and briefing documents prepared for 4/10/81: Headquarters / Region III Discussions - Zimmer Nuclear: Power Station, Unit 1 with attached background documents 45.
Memo to Chairman Hendrie fr. James Cummings, OIA -
(4/14/81) Subj:
Forwards GAO ltr. transmitting their draft on OIA to NRC w/o ltr.
I
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7
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5
- 46. -Memo to File 80A-36-fr.;Tracy Wiest, Auditor, OIA (4/22/81) -' on clarification of certain questions in GAO Draft Report on OIA) r 147.
Ltr.,to Honorable Milton J. Socolar, Acting Comptroller General, GAO, fr. Chairman Hendrie, NRCJ(5/1/81) requesting extension of time in providing comments on Draft,GAO Report on Improvements needed in the NRC's Officeiof-Inspector and Auditor 48._
Memo'to Dudley-Thompson, I&E, fr. James Cummings,_OIA 5/5/81) - Subj:
I&E-Manual, TI' 1250/02, Rev. 1 "I&E Investigative Program" 4 9.. Memo to file-fr. Sinclair (5/5/81) on meeting with U.S.
.. Attorney's Office'in' Cincinnati on April 22, 1981.
50.
Memo for R. F. Heishman & C. E. Norelius, Region III
~fr. James Keppler, Region III (5/6/81)- - Subj :
Evaluation of-Problems Identified - Zimmer.
Investigation (Enclosure - list -of problems identified
& evaluation of those problems)
- 51. -GAP Letter to Keppler, Reg. III (5/11/81), regarding supervision of Zimmer construction activities.
52.
Memo.to File fr. Arthur Schnebelen, OIA (5/15/81) Subj:
Redelegation-of Authority to John Sinclair to Administer Oaths & Affirmations to'be Used in Matter of Allegations re Zimmer 53.
Ltr. fr.-Earl A. Borgmann, Cincinati Gas & Elec to James Keppler, Director, Reg. III (5/18/81) re postponement of May 18, 1981' meeting on QA Problems attaching draft CG&E proposal'for QA Improvement' Program and QC program.
54.
Ltr to Cummings,-OIA, fr.-Greenspun, DOJ, (5/26 / 81) : re problems presented by parallel investigations and ways to minimize those' problems.
- 55.. Note to Schnebelen fr. Gamble (5/29/81) setting out major. issues-in Zimmer investigation.
- 5 6.. Memo to V. Stello, I&E, fr. James Cummings, OIA (6/1/81) - Subj: -Transmiting DOJ guidance resulting from questions raised in connection with Zimmer - w/o guidance attached l
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-57.- Memo'toIR.C.-DeYoung,~IE,-fr. James Keppler, Reg. III (6/12/81) -fSubj:Rforwarding summary of Zimmer status
~
.w/ attachment 58".,: Memo'to' File fr.-David Gamblefand Albert Puglia, OIA-J(6/15/81)'- Subj: - Information relating.to review of
~ Kaiser Engineering QA Nonconforming Material Report
.[
~ Logs.
59.
JohnLSinclair - Handwritten notes of 7/7/81 re contact-with Pat Gwinn, Region ILZimmer:on locating weld-
- records
~
60.
Sinclair' handwritten draft _ of report section on weld records :(unf.ated)
' 61 '.
~
Ltr. to M. J. Socolar, Acting Comptroller General,-fr.
James'Cummings, OIA (7/14/81) concerning unfair manner
'in which agency. comments on draft GAO Report were evaluated and/or admitted)
': 6 2.
-Note [to'Cummings/Schnebelen, OIA,.fr. John Sinclair,-
OIA_(7/16/81). attaching for review draft Report re
~~
section on -Weld Records w/ attachment 631 Ltr..for J. Cummings, OIA, fr. Tracey, USA (7/20/81),
advising of the assignment to Zimmer investigation.'
64.
Memo to Streeter,' Warnick, and Davis Davis fr. J.E.
Foster, Investigator, Region III: - (8/4/81) listing investigative concerns re content of draft report 65.
John Sinclair - Handwritten notes (8/6/81) on various contacts re weld information and notes re Applegate ~(4:
_pages).
- 66.. Memo to Commissioners fr. James Cummings, OIA 8/6/81 -
- responding to-Applegate allegations
- 67. = Memo'to Commissioner fr. James Cummings, OIA (8/7/81)
' transmitting'OIA Report on Adequacy of IEE w-Investigation 50-358/80-09 at the William H. Zimmer Power Station w/ attachment.
-(2'different annotated versions:fr. Region-III files)
'68.
Memo to James Keppler, Region III, fr. James Cummings, OIA (8/10/81) advising R III to allow OIA time to review' report before release due to possible subsequent
~
l criminal action)
(-.
- 41. (
7 69.
SECY-81-480 (8/12/81) discussing Final GAO Report entitled " Improvements Needed in the Nuclear Regulatory Commission's Office of Inspection" enclosing 1 page of.
recommended response.
70.
. Note fr. J. Sinclair to D. Gamble (8/10/81) ~~
re insertion-of asterisks into OIA. report 71.
Ltr.HTo Ann Marie Tracey, Assistant U.S. Attorney, Southern District of Ohio fr._ James Cummings, OIA -
(8/17/81) Forwarding copy of OIA Report of Investigation-Pertaining to April 1980 Investigation by I&E at Zimmer w/o attachment 72.
Ltr. to Ann Marie Tracey, Assistant U.S. Attorney, Southern District of Ohio, fr. James Cummings (8/18/81) forwarding copy of Draft OIA Report on I&E Investigation at Zimmer w/o attachment 73.
Ltr to Cong. M. Udall fr. N. Palladino, NRC (9/23/81) transmitting NRC response to GAO report on OIA w/ attachment 74.
Note to Dudley Thompson fr. Schnebelen, OIA (8/19/81) forwarding copy of OIA's report of investigation into Applegate allegation w/o attachment 75.
Letter to Ann Marie Tracey, USA, fr. J. Cummings, OIA (8/26/81) transmitting list of exhibits to IE draft report w/o attachments.
76.
Memo for James G. Keppler, Director, Region III, fr.
James E. Foster,' Investigator, Region III (9/3/81) commenting on OIA report on adequacy of 50/358/80-09 77.
Memo for R. F. Warnick, Region III fr. Bert Davis, Region III (9/4/81) - Subj:
Zimmer Investigation,-Weld CY-516 78.
Memo for J. Keppler, Region III fr. G. A.
- Phillip, Investigator, Region III (9/8/81) re Comments on OIA Report on I&E Investigation 502358780-09 (Zimmer) 79.
Letter to Cummings, OIA, fr. Patrick Hanley, USA (9/9/81) recommending criminal investigations be held in abeyance pending completion of IE Investigations.
80.
Handwritten note to John Sinclair fr. Dave Gamble (9/16/81) re Confidentiality of FBI Agents Nam.es
+
e' 8
a.
sanitized version b
unsanitized version
- 81. ' Memo to Chairman Palladino fr. William.Dircks, EDO (9/17/81).- - Subj :
Comments on OIA Report on I&E
^'
Investigation 50-358/80-09 (Zimmer) 82.
Memo to Chairman ~Palladino fr. William Dircks, EDO
'(9 /17/ 81) OIA Report 1x1 I&E Investigation - expressing
'his' con'cerns with findings of OIA Report on IE' 50-358/80-09 183.-
Ltr.-to Pat Hanley, Chief, Special Prosecutions Unit,
-Southern District.of Ohio fr. James Cummings, OIA -
(9/17/81)-Discusses Information.fr. DOJ. relative to
~ Question of Parallel Proceedings w/o attachment 84.
Memo to-James Cummings, OIA, fr. Bert-Davis, Region'III
~
(9/30/81) - Confirming phone conversation rji Sargent &-
Lundy Audit at Zimmer R8 5.
Memo to Dudley Thompson, I&E fr. James Keppler,. Region III (10/1/81) discusseing I&E problems OIA Philosophy regarding I&E's conduct of investigations
~
86.
Memo to James Cummings, OIA, fr. Chairman Palladino
.(10/2/81) requesting OIA Comments on EDO Memo of 9/17/811& Requesting OIA Not to Release Report to Public 87.
Memo to Chairman Palladino fr. James Cummings, OIA
-(10/8/81). transmitting OIA's comments on EDO's 9/17/81 memo.
Region III annotated version a.
b.
Clean copy jB.-
SECY-81-588 10/3/81)
" Investigative Jurisdiction of 8
the Office of Inspection.& Enforcement 89..
Memo.to Region III Files fr. J. F. Streeter, Region III (10/8/81) - Subj:
Telephone Call with Thomas Applegate 90.
Memo to Commissioners fr. James Cummings, OIA (10/26/81) - Forwarding OIA Comments on SECY-81-588 u
- 91.. Annotated staff briefing documents for use at 10/27/81 Commission mtg. on Zimmer w/ copies of slides used at
~ briefing 9
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9
- 92. -Memo toLV. Stello, I&E fr. James Keppler,' Region III -
'(10/28/81) Subj:
Zimmer Commission--Meeting - October 27,1 1981 -
~ 93. - Ltr.fto Cong. Morris Udall fr. Chairman Palladino -
(11/16/81)-answering' questions concerning adequacy of I&E Investigation of'Zimmer (Incoming Udall ltr of
~
8/20/81 attached) a.
annotated version b.
cleanfconcurrence copy
- 94.. Memo to Bert. Davis, Region III, fr. James Cummings, OIA (11/18/81) - transmitting Zimmer interviews and corporate: documents w/ attachments.
9 5.-
Cincinnati Enquirer newspaper article (11/18/81)5-Zimmer Plant Probe 96.
Ltr. to Douglas Lowenstein, Cox Newspaper, fr. J. W.
Felton, ~ NRC. -(11/20/ 81) re FOIA 81-376 Request for OIA Report.on Zimmer Investigation w/ enclosure 97.
Memo to Robert Carlson, et al., Directors, EIS,.
Regional Offices fr. Dudley Thompson, I&E (11/23/81)
Subj:
Investigative Guidance Memoranda w/ enclosure-98.
Ltr to Director, NRC fr. Thomas Devine (11/23/81)
(FOIA-81-488) - All FOIA Office Documents.Related to Processing Request and.2/3/82 FOIA response to Tom Devine, GAP, fr. John Carr, Chief,--FOIA Branch' (attached)-
~
99.
Memo to James Keppler, Region III, fr..J. F. Streeter, Region III (11/23/81)'- Subj:
Investigation of Inspector Signatures on Final Zimmer Investigation Report 50-358/81-13 100. Cincinnati' Enquirer Article (11/30/81)
" Area _NRC Worker Hit.Back at Critique" 101.'Ltr. to' Ann Marie Tracey, Assistant U.S. Attorney, Southern ~ District of Ohio, fr. James Cummings,~OIA -
(12/3/81) w/o enclosures 102A. Memo to File fr. David Gamble, OIA, (12/10/81) - Subj:
Zimmer Nuclear Power Station w/ list of enclosures and enclosures
T
.+
10 102B. Annotated copy'of document 102A w/o list of enclosures or enclosures 103. Memo to Commissioners fr. James Cummings, OIA (12/14/81) - Subj:
OIA Review of NRC's QA/QC Activities for Nuclear Power Reactors Construction attaching 10/30/81 Memo to Dircks fr. Cummings re OIA Survey of NRC's QA/QC Program 104. Ltr. fr. : A. Tracey, USA, to J. Cummings, OIA, (2/24/82) 33t Cincinnati Gas & Electric Company /Zimmer plant.
105. Memo to R.
F. Warnick, Region III, fr..J. B. McCarten, Investigator, (2/25/82) - Subj:
Zimmer Document and Investigation Leads 106. Ltr to R.F. Warnick, Reg. III, fr. Barnes, USA (3/19/82), re Zimmer Nuclear Power Plant 107. Memo to J. Cummings, OIA, fr. Keppler, Region III (3/22/82) re coordination of Zimmer effort 108. Ltr. to C. Barnes, USA, fr. R. Warnick, Reg. III (3/24/82), advising status of Reg. III Zimmer investigation w/ document 106 above.
109. Note.to Bill Dircks, EDO fr. James Keppler, Region III (4/20/82) transmitting draft memo on transmittal of Zimmer investigation material to Udall committee.
110. Memo to Tom Combs, SECY, fr. George Messenger, OIA (5/3/82) Subj:
Responses to Questions fr. Congressman Ottinger w/o attachment 111. Memo to Richard DeYoung, I&E, fr. James Cummings, OIA (5/6/82) -- Subj :
OIA Input to Congressman Ottinger's Request w/o attachments.
112. Note to File fr Sinclair thru Cummings (5/15/82) placing Reg. III computer listing of Zimmer allegations into file 113. Ltr. to T. Devine, GAP, fr. Keppler, Reg. III, (5/14/82) providing information 114. Ltr. to Cong. Richard Ottinger fr. Chairman Palladino (5/14/82) providing summary of Zimmer investigation
f~
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- 115. Ltr. to J..Cummings, OIA, fr. A. Tracey,-USA, (5/28/82), w/ enclosure 116. Memo for Zimmer File fr A. Bert Davis, Reg. III (6/1/82) - Subj: Meeting with US Atty, Cincinati, OH on May 20, 1982 -
117. Memo for Region III Files fr D.R. Hunter, Reg. III (6/1/82) Subj: Zimmer Briefing for Chm Palladino - May 10, 1982 118. Ltr. to James Cummings, OIA, fr. Christopher Barnes, U.S. Attorney, Southern District of Ohio (6/2/82) re
~
Zimmer 119. Memo to Joe Felton, DRR, fr. James Cummings, OIA (6/3/82)'- Subj:
Disclosure Determination FOIA -
82-206
-120. Ltr. to James Keppler, Region III, fr. Christopher Barnes, U.S. Attorney, Southern District of Ohio - re~~
Zimmer Nuclear Power-Plant (6/4/82) 121. Note to Commission fr. James Cummings, OIA (6/4/82)
Forwarding 6/2/82 ltr. fr. C. Baines, U.S. Attorney w/o attachments 122. Memo to Chairman Palladino fr. James Cummings, OIA -
6/17/82) Subj:
Zimmer w/ attachment 123. Memo to Alphonse Gauthier, OIA, fr. James Cummings 6/23/82) Subj:
Zimmer 124. Memo to Bert Davis, Region III, fr. James Cummings, OIA (6/24/82) - Subj:
Zimmer Nuclear Plant w/ attachment 125. Memo to Commissioners fr. Carl Kammerer, OCA (6/29/82)-
Subj:
Concerns of Dr. Meyers Regarding Zimmer 126. Complaint filed in.- Thomas Applegate v. NRC U.S.D.C.,D.C. No.'82-1829 (6/30/82) 127. Transmittal Slip'to Rick Parrish, OGC, fr. Ron Smith, OIA (7/1/82) forwarding OIA documents 128. Ltr. to James Cummings, OIA, fr. Gerald Charnoff, Shaw, Pitman, Potts & Trowbridge (7/2/82).
Requesting tape of Interview with Floyd Oltz J
m-
Ne.
12 s
129.-Memo'to Cummings, OIA, fr. Lil, OCM (Ahearne's Office)
(7/12/82) forwarding 7/9/82 memo to Commissioners fr.
Zimmer-Investigation-
-w/ attachments 130. Memo to. Commissioners fr. Carl Kammerer, OCA (7/12/82).- Subj: Request for' Interview re Zimmer and
- attaching document 124, above.
131.cMemo to William Dircks, EDO, fr. James Cummings, OIA (7/15/82) Subj:
Zimmer Allegations of Harassment-by
- NRC: Inspectors w/6/15/82 annotated memo.fr. Keppler to
.Cummings attached 131a.Applegate ltr. to Palladino (8/16/82) rji staff deception.
132.-Ltr. to T. Applegate fr. James Cummings, OIA (9/20/82)-
'in response to 7/16/82 ltr. to Chairman fr. Applegate 133.;Ltr. to Ann-Marie Tracey,-Assistant U.S. Attorney, Southern District of Ohio, fr. James Cummings,~OIA (9/23/82) Confirms Issues Discussed in September 8,.
1982 Meeting 133a. Memo to file from N. Haller (9/23/82) 33t Applegate telephone call of 9/23/82 134. Ltr. to Cong.-Udall fr. D.. Gamble (10/20/82) noting in OIA 1981 investigation w/ list of attachments but no attachments
- 135. Memo to Gilinsky, Ahearne, Roberts & Asselstine fr.
Chairman Palladino (11/2/82) - Subj:
Request fr. Mr.
Applegate
- 136. Note to G. Schuetze fm Malsch, OGC, (11/12/82) re
~-
telephone call fr. Applegate 137. Memo to Commissioners fr. James Cummings, OIA (11/10/82)- Subj: Zimmer w/o attachments 138. Ltr. fr. Cong. Morris Udall to Chairman Palladino (12/7/82) re removal of document fr. Zimmer
-Investigation File 139. Ltr. to Cummings, OIA, fr. A. Tracey, USA (12/10/82) ~~re Zimmer investigation
s..
^;.
13 140. News Release 12/10/82 Cincinnati Enquirer titled
" Congressman Accuses NRC of Zimmer cover-up? w/ article based on release.
141. " Notice of Disclosure" (12/27/82) filed in Applegate v.
NRC,~U.S.D.C., D.C. No. 83-1829.
142. Memo for J._Keppler, A. Davis, D. Dougherty, and R.
Warnick fr. Pearl Smidt, Region III (2/22/83) - Subj:
FOIA Request -'488 - Zimmer w/ attachment (2/22/83) 143. Memo to Ben Hayes, Director, OI fr. S. Chilk (3/4/83)
'Subj:
OI Policies w/OI policy statements and Investigative Procedures Memoranda 82-01 through 015.
_144.A.
Painsville Telegraph news article titled " Private Eye Blasts NRC" (3/16/83)
B.
Cleveland Plain Dealer news article titled "NRC Chief in hot seat on Zimmer documents" (12/16/82)
C.
Cincinati Post news article titled "Zimmer problems hidden" (12/10/82).
145. Draft Memo to Judge Hoyt and Sebastian Alcot fr.
Chairman Palladino 4/13/82 - Subj: Thomas W. Applegate Allegations 146. Memo to Commissioners fr. James Cummings, OIA (4/15/83)
- Subj: Response to T. Applegate Concerns w/ attachment 147. Memo to file from Hoyt (6/30/83) re,6/30/83 Cummings telephone call 148. Transcript of.5/11/83 interview of Roger A. Fortuna, Jr.
149. Typed Miller notes of 5/11/83 interview of David Gamble
.(undated) 150. Transcript of 6/13/83 interview of David Gamble.
151. Memo to file fr. C. Alcot, OGC (5/19/83) re, telephone conversation with David Gamble.
152. Transcript of 5/12/83 interview of John Sinclair.
153. Transcript of 5/24/83 interview of John Sinclair.
]
14' i
154. Transcript of 5/12/83 interview of Arthur Schneblen.
155. Transcript of 5/16/83 interview of Kavin D. Ward.
156. Transcript of 5/16/83 interview of Gerald Phillip.
157. Transcript of 5/17/83 interview of Charles F. Norelius.
158. Transcript of 5/17/83 interview of James Donahue.
159. Transcript of 5/17/83 interview of Daniel H. Danielson.
~
160. Transcript of 5/17/83 interview of James Keppler.
161. Transcript of 5/26/83 interview of James J. Cummings.
162. Memo to file fr. Hoyt (6/2/83) re Cummings telephone call.
163. Memo to file fr. Hoyt (6/30/83) 33L Cummings telephone call.
164. Memo to file fr. Miller 331 interview of Applegate landlord.
165. Transcript of 6/2/83 interview of Bert Davis 166. Memo to file fr. Miller 331 6/3/83 telephone interview of James McCarten.
167. Transcript of 6/7/83 interview of James McCarten 168. Transcript of 6/6/83 interview of Dudley Thompson 169. Transcript of 6/8/83 interview of Thomas Devine.
170. Transcript of 6/8/83 interview of Ann Marie Tracey.
171. Transcript of 6/15/83 iaterview of Victor Stello, Jr.
172. Memo to files fr C. Alcot (6/27/83) 331 telephone conversation with Ann Bowden.
173. Tape (1) of 5/24/83 Sinclair interview.
174.
Tapes (2) of 5/11/83 Fortuna interview.
175. Tapes (3) of 5/12/83 Sinclair interview.
J
F:
15 176. Court Reporter tapes (8) of 6/13/83 Gamble interview.
177. Tapes (5) of 5/26/83 Cummings interview.
178. _ Tapes -(2) of 6/2/83 Davis interview.
179. Tape (1) of 5/17 Norelous interview.
180. Tapes (2) of 6/8/83 Devine interview.
181. Tapes (3) of 5/12/83 Schneblin interview.
182. Tape of Miller notes on 5/11/83 Gamble interview.
183. Tapes (2) of 5/17/83 Ward interview.
184. Tapes (2) of 5/17/83 Keppler interview.
185. Tape (1) of 6/6/83 Thompson interview.
186. Tape, (1) of 6/8/83 Tracey interview.
187. Court Reporter tapes (4) of 6/15/83 Stello interview.
188. Tapes (2) of 5/16/83 Phillip interview.
~
189. Court Reporter tapes (6) and handwritten notes (4 pages) of 6/7/83 McCarten interview.
190. Court Reporter steno tape of 6/15/83 Bernabei interview.
191. Indexes of IBM diskettes (4) containing final Hoyt/Alcot Report w/ diskettes.
192. Index of IBM diskette (1) containing Fortuna transcript w/ diskette.
193. Index of IBM diskette (1) containing Gamble transcript w/ diskette.
194. Indexes of IBM diskettes (3) containing Sinclair transcript with diskette.
195. Index of IBM diskette (1) containing Danielson transcript with diskette 196. Indexes of IBM diskettes (2) containing Cummings transcript with diskette.
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.~~
2 16 4
197.-Index of IBM diskette (1)~containing Ward transcript
- w/ diskette.
198. Index of-IB diskette (1) containing Tracy transcript w/ diskette
' 199. Index of IBM' diskette (1) containing Devine transcript' w/ diskette.
200. Index'of. IBM diskette (1) containing Phillip transcript w/ diskette.
~
201. Index of IBM diskette (1) containing Phillip transcript with diskette.
202. IBM diskette identified as Tracy interview.
203. IBM diskette identified as Schneblen #4, 5/12/83 204. IBM diskette identified as "TOMSO"/"Thopson",
- apparently containing Thompson transcript.
205. IBM diskette identified as "Schnebelen, Tape 1, side 1/2", apparently containing Schnebelen transcript..
206. Index of IBM diskette (1) containing Keppler transcript with diskette.
207. Index of IBM diskette (1) containing Davis transcript w/ diskette.
-208. Indexes of IB diskette (2) containing Cummings transcript w/ diskettes.
209. IBMEdiskette identified as "Index", apparently containing indexes to final-Hoyt/Alcot report.
210. Indexesoto IBM diskettes (11) used during Hoyt/Alcot inquiry w/o diskettes.
211. Undated draft of Exhibit C to final Hoyt/Alcot report.
212.-Undated draft of Exhibit C to final Hoyt/Alcot report.
i
- 213. Selected pages fr Bowden telephone log maintained for J. Cummings.
-214. Transcript of 6/15/183 interview of Lynne Bernabei.
L' J
17 215. Undated Miller annotation of draft transcript of 5/12/83 Schebelen transcrip.t.
216.1 Undated draft of Exhibit C to Hoyt/Alcot Report.
217. Memolof. telephone message fr.J. Cummings to Hoyt (6/13/83) 218. Memo of telephone-message fr. J. Cummings to Hoyt
~(6/13/83).
'219. Memo of telephone message fr J. Cummings to Hoyt
_(6/2/83)~with handwritten draft of document 162 above.
220. Handwritten' note to file (7/15/83) re telephone conversation between T. Conner and Hoyt concerning
' request for McCarten transcript.
221. Handwritten Miller notes of 5/12/83 Schnebelen interview.
222. Handwritten Miller notes of 5/11/83 Gamble interview.
223. Undated, annotated Hoyt notes prepared in anticipation of Cummings interview.
224. Memo to file fr C. Aloot (5/10/83) re Gamble interview.
225. Memo to file fr C. Alcot (5/10/83) re Fortuna interview.
226. Final draft memo to file fr C. Alcot (5/10/83) --~
re Sinclair interview.
227. Final draft memo to file fr C. Aloot (5/10/83) --'
re Schnebelen interview.
228. Handwritten Alcot notes of Schnebelen interview.
229. Draft investigation charter (undated) titled " Review of Allegations Against NRC Employee" 230. Memo _to file fr C. Alcot (5/10/83) re Applegate Inquiry i
231. Note fr S. Eilperin to C. Aloot (4/13/83) transmitting draft chronology w/ chronology.
232. Draft of memo fr Chairman Palladino to S. Eilperin/C.
Alcot (4/13/83) re Thomas W. Applegate Allegations.
l J
e 18 233. Annotated copy of memo fr M. Malsch to Chm Palladino (11/16/82) re interview with Thomas Applegate w/ attachments.
234.- Ltr. to H. Hoyt fr. J. McCarten (6/29/83) requesting that-transcript of McCarten interview be provided to Commission.
235. Undated draft of Exhibit C to Hoyt/Aloot Report.
236. Undated draft of Exhbiit E to Hoyt/Alcot Report.
237.. Memo fr. Chairman Palladino to H. Hoyt/C. Alcot (5/6/83) re_ Thomas W.-Applegate Allegations.
238. Memo fr. Chm. Palladino to W. Dircks, J. Cummings, V.
Stello, and J.Keppler (8/4/83) transmitting Hoyt/Alcot report 239. Telephone log of G. Phillip on "Zimmer-welding allegations" 240. Index to OIA file No. 81-39 (5/11/81-11/10/82).
241. Memo to file fr C. Alcot (7/13/83) -~re transmittal of investigative report to Commission.
242. Ltr. fr C. Alcot to S. Lewis, Region III (1/18/84) transmitting copies of interview transcripts.
243. Handwritten Alcot notes of Cummings interview.
244. Memo fr. C. Alcot to J. Keppler, Region III (8/23/83) transmitting Devine and McCarten transcripts.
245. Memo fr. C. Alcot to V. Stello, EDO, (8/5/83) transmitting Stello, McCarten and Norelius interviews.
246. A Memo fr. C. Aloot to F. Herr, OIA (8/9/83) transmitting Cummings interview.
B Memo fr. C. Alcot to F. Herr, OIA 247. Ltr. fr. C. Alcot to B. Davis, Region III (8/26/83) transmitting page 72 of McCarten transcript w/ enclosure.
248. Draft of-document 236, above.
r a.;
19 249. Highlighted copy of document 35, above.
250. Memo fr. J. Cummings, OIA, to Chm. Palladino (9/8/83) commenting on Hoyt/Alcot report w/ enclosures A.
clean copy B.
annotated version
.251. Ltr. fr. L. Bernabei to Hoyt/Alcot, NRC (7/24/83) transmitting corrections to Bernabei transcript.
252. Ltr. fr. T.
Devine, GAP to H. Hoyt 8/10/83) transmitting corrections to Devine transcript.
253. Memo fr. J. Cummings, OIA to H. Hoyt (8/26/83) requesting interview notes.
254. Memo fr. H. Hoyt to J. Cummings, OIA (8/29/83) transmitting selected inquiry documents.
255. Miscellaneous drafts of OIA report 256. Preliminary McCarten draft of 1981 Region III report 257. Unsigned final draft of 1981 Region III report.
258. Ltr. fr.
R. DeYoung, IE, to W. Dickhoner (11/24/81) re
~~
results of IE Report 50-358/81-13 w/ Notice of Violation and Proposed Imposition of Civil Penalty 259. Ltr. fr. J. Keppler, Region III, to W. Dickhoner (11/24/81) transmitting IE Report 50-358/81-13 w/ report 260 Deposition of James Cummings (3/8-9/83) taken in Amplegate v. NRC, U.S.D.C.,
D.C. No. 82-1829 w/ errata
- s. leet 261 OIA Repor?. Oftled "Special Inquiry Re: Adequacy of IE Investigation 50-358/80-9 at the William H. Zimmer Nuclear Power Station (8/7/81) w/ attachments.
262 Note fr.
J.
Sinclair, OIA, to J. Blaha (11/9/81) transmitting Zimmer inquiry documents 263 Record of telephone conversation between D. Gamble and P. Gwynn (7/10/81) re Zimmer 264 Memo to file fr. D. Gamble and A. Puglia, OIA (6/19/81) i
v-n m..;
20 re. etching-of_ heat numbers on pipes at Zimmer
.265 l Memo fr. J. Cummings,-OIA, to J. Fitzgerald, OI
'(8/2/82) re Zimmer investigation-266' Memo'fr.-J.-Cummings, OIA, to W. Dircks EDO (10/30/81)
.pe OIA survey of NRC's-QA/QC programs 267~ Undated, unsigned briefing package for. 10/27/81 Commission mtg. on Zimmer, 268 Misc.. documents from personal Zimmer file maintained by.
"G.-Foster, Reg.-III-269 Index to OIA file 81-18 270 Deposition of John Sinclair (3/9/83) taken in Applegate
-v.
NRC, U.S.D.C.,.D.C. No. 82-1829
'271 Deposition of Arthur Schebelen (3/7/83) taken in Applegate v. NRC, U.S.D.C., D.C. No.-82-1829 w/ errata sheet.
272. Deposition of Ron Smith (3/4/83) taken in Applegate v.
.NRC,'U.S.D.C., D.C. No. 82 - 1829 w/ errata sheet.
273 Deposition of David Gamble (3/3/83) taken in Applegate
- v. NRC, U.S.D.C.,
D.C.'No. 82-1829 274 GAO Report _EMO-81-72 (July 9, 1981) titled
" Improvements Needed in the Nuclear Regulatory
' Commission's Office.of_ Inspector and Auditor,"
pp..
24-35.-
275' Memorandum to the Chairman and the Commissioners fr. V.
.Gilinsky,-Commissioner (8/26/83) concerning "NRC Investigation" I
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M 01 79 1
Docket No. 30.-338 'd e,
Cincinnati Cas and Electric
~'
i Company r
ATTN: Mr. Earl A. Borgmann Vice President j
r=p e ring Services I
and Electric Production 139 East 4th Street Cinetanati, OH 45201 Gentlemen:
This refers to the inspection conductad by Mr. E. D. Ward j
of this office on November 8-9 and December 12-13, 1978, of i
activities ac U. H. Zinarer Nuclear Power Plant authorised by NRC Construction Permit-No. CPPR-88 and to the discussion of our findings with Mr. W. W. Schwiers and others at the conclusion of che inspection.
l The enclosed copy of our inspeccion report identifies areas j
examined during the inspection. Within these areas, the inspection cousisted of a selective ar=minmeion of procedures
,,,.i and representative records, observatione, and interviews vich
.E4M personnel.
During this inspection, certain of your activities appeared to be in noncocipliance with NBC requirements, as ettscribed in tha enclosed Appendix A.
I This notice is sent to you pursusce to,the provisions of Sectica 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office within thirty days of your receipt i
of this notice a written statement or explanation in reply, including for each item of noncompliance (1) corrnetive action taken and the results achievsd: (2) corrective action to be taken to avoid further noncocpliance; a:ui (3) the date i
when full compliance will be achieved.
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v EES 01 gg Cincinnati c u==4 slectric Company I
In addition to the need fo'r corrective action regarding these specific items of noncompHana a, we arai1 concerned about the implementation of your quality assurance program that permitted their occurrence. Conse-quantly in your reply, you should describe in particular, those actions taken or planned to improve the effectiveness of your quality assurance program.
es,,
. ~.
In accordance with Section 2.790 of the 'NRC's " Rules of Practice," Part 2, Title 10. Code of Pederal Regulations, a copy of this letter, the enclosures, and your response to this latter will be placed in the NRC's Public Document Room, except as follove. If the enclosures contain information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure.
The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, James.G. Kappler
- 4s#!c Director
Enclosures:
1.
Appendix A, Notice z
of Violation 2.
IE Inspection Rpt No. 50-358/78-30 cc w/enels:
~-
J. R. Schott, Plant Superintendent Central Files Reproduction Unit NRC 20b PDR Local PDR HSIC
}o' TIC y'
U. Young Park, Power Siting Cosmaission
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Appendix A NOTICE OF VIOLATION Cincinnati Gas and Electric Company Docket No. 50-358 l
. Based on the inspection conducted on November 8-9, December 12-17, 1978, it appears that certain of your activities were in noncompliance with_,.
NEC requirements, as noted below. These items are infractions.
1.
Contrary to 10 CFR 50, Appendix B, Criterion III and the h=ar Niu lane Power Station FSAR Chaptar 17 Paragraph 17.1.12, states in part that, "Maasures shall be established to assure that.
instruments and other measuring and testing devices'used in acti-vities affecting quality are properly... calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
On November 8, 1978. Emiser Engineers, Incorporated and Peabody Magnaflux Corporation radiographic film densitometer i
readings were compared against each other and found to have a wide variance.
2.
Contrary to 10 CFR 50, Appendix B, Criterion II of the Zimmer Nuclear Power Station FSAR, Chapter 17, Paragraph 17.1.9.2, states in part that, "Heasures shall be established to assure that special processes, including... nondestructive testing, are controlled, and accomplished by qualified personnel using qualified procedures in accordance with applicable codes... specifications, criteria and other special requirements.
'On November 8, and December 12, 1978, forty radiographs s.
were reviewed including reports. Sixteen diserapencies were observed in the reports or the fins.
b.
In reviewing the above forty radiographs, several of the welds were less than 0.25 inches thick and were radio-graphed with a Iridium 192 source without a separate procedure
~O being performed and proven by actual demonstration as required by ASHE Section III,1971 Edition,1972 Addenda.
[/--,/& L)=* D J
U.S. NUCLEAR RECULATORY CCMMISSIO!!
N-
-0FFICE OF INSPECTION AND ENFORCEXERI.
REGION III
. p.a Report No. 50-358/78-30 Docket No. 50-358 License No. CPPR M Licensee: Cincir.nati Gas and Electric Company 138 East 4th Street Cincinnati, OH 45201 Facility Name: William H. Zimmer Nuclear Power Plant Inspection At:
'W. H. Zimmer Site, Moscow, Ohio Inspection Conducted: November 8-9, December 12-13, 1978 NY h~
/ !8(/
Inspector:
..D.
Ward 7[
G-d !"/ T
- anNon, iW
/
Approved By: D Engineering Support Section 2.
/
/
Inspection Summary Inspection on November 8-9 and December 12-13, 1978 (Report No. 50-358/78-30)
Ee.e Areas Inspected: Observation of preservice inspection (PSI) of vessel and review of nondestructive examinations (NDE) reports. Review of radio-graphs and reports in the HP, LP, and Core Spray systems. The inspection involved 24 inspection-hours onsite by one NRC inspector.
Results: Of the four areas inspected, no apparent-items of noncom-pliance were identified in three areas; two apparent items of noncompliance were identified in one area'(infraction - failure to calibrate and maintain, instruments within necessary limits
- paragraph 5.a; infraction - failure to follow established pro-cedures to comply with applicable Codes - paragraph 5.d).
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DETAILS
?'
Persons Contacted
- Cincinnati Gas and Electric Comoany (CG&E)
- B. K. Culver, Project Manage' "
r
- *W. W. Schwiers, Principal QA and Standard Engineer
- R, L. Wood, QA and Standard Engineer J. R. Weissenburg QA Engineer Kaiser Enaineers. Incorporated (KEI)
- R. Turner, QA Manager.
W. Puckett, Lead Mechanical Inspector A. Pallon, Weld /NDE QA Engineer Nuclear Eneray Servicss. Incorporated (NES)
- J. Marinelli, Electronic Technician R. Trank, Mechanic Technician The inspector also contacted and interviewed other licensee and contractor employees.
- Denotes those present at the exit interview.
Functional or Pronram Areas Inspected 1.
Preservice Inspection - General Information Nuclear Energy Services, Incorporated (NES) developed the a.
M"-
Preservice Inspection Program and is performing the preservice examination in accordance with ASME Section XI, 1974 Edition with no Addenda.
b.
Preservice inspection is being performalt intermittently and is to be completed in the Sunsmer of 1979.
The automated ultrasonic examination will take approximately -
c.
six to eight weeks to perform, working two shifts six days
~ :"
a week.
2.
Observation of Work and Nondestructive Examination Activities
- ~
The inspector observed and had discussions with NES personnel during the set-up of the automated ultrasonic is e
0 94
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C instruments and equipment and during the nondestructive examina-tions. 'These observations included the setting up of the Reflecto -
scope ultrasonic instruments, the transponding ultrasonic calibration tinit, the Computer X and Y tape recorder for the automated ultra-sonic examination of the vessel, and the automated ultrasonic 4
examination of nossia weld 3 in accordance with Procedure 80A1174 Revision 0, dated February 15, 1978.-
No items of noncompliance or deviations were identified within the areas observed.
3.
Data Review and Evaluation The data review for the following syste-- demonstrated that the h
QA/QC commitment had been complied with.
Feedwater to reactor Racirculation Jet pump nomsle safe end and instrument nozzle RCIC to reactor RCIC from tlain Steam Core Spray Stena separator Feedwater sprager Shroud head RPV closure head nozzles, supports and pads No items of noncampliance or deviations were identified within the areas reviewed.
s 4.
NDE Personnel Certification Review
".. k.
The inspector reviewed the following NDE personnel certifications
"* M in accordance with SNT-TC-1A,1968 Edition. The personnel were certified by NES.
Name Level Machods 4
J. Wolf II UT, PT K. Dufel II UT No items of noncompliance or deviations were identified within the areas reviewed.
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. _ _. _,... ~ _ -,.. _ _. _.-
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5.
Independent Inspection Radiographs and reports were reviewed of the following welds in accordance with ASME Section III, 1971 Edition,vich Sutuner 1972 Addenda and the a'pplicable procedures that were used.
Line Wald Diameter Thickness Date 1HP03C10 HP32 10" 0.593" 9/22/76 1HP03C10 HP33 10" 0.593" 9/30/76
'9 1HP06C4 HP34 4"
0.237" 9/30/76 1HP06C4 HP35.
4" 0.237" 2/18/76 1HPO4A8 HP41 8"
0.593" 9/2/76 1HP18A8 HP49 3"
0.438" 1/10/77 ILP17A3 LP47 3"
0.216" 4/20/77 ILP17A3
%,P48 3"
0.216" 6/17/77 ILPO484 (P49 4"
0.237" 8/12/76 1HP21A4 HPK1 3"
0.237" 4/28/77 1HP21A2 HPK2 4"
0.237" 3/11/77' 1HP17A3 HPK10 3"
0.216" 2/6/78 1HP06B4 HP17 3"
0.237" 9/28/76 1HP08C3 HPK17 3"
0.438" 8/7/78 1HP03C10 HP27 10" 0.593" 8/16/76 1HP03C10 HP30 10" 0.59'4" 9/20/76 1HP06C4 36HP 4"
0.237" 1/27/76 1HP01A20 HP1B 20" 0.375" 2/17/77 1HP01A20 HP1 20" 0.375" 7/26/76 1HP01A20-1 HP1 20" 0.375" 7/26/76 1HP01516 HP67B 16" 0.375" 5/2/77 1HP01A20 9HP 20" 0.375" 7/2/76 1HP03A14 HP20 14" 0.937" 9/3/76 1HP03C10 HP28 10".
0.775" 7/20/76
!Z.e 1HP01A20 HP2 20" 0.375" 8/9/76 1LP05A12 LP24 12" 0.375" 4/27/77 1LP22A6 LP62 6"
0.280" 9/28/76 ILP22A6 LP63 4"
- 0. 2W" 9/30/76 ILPO4B4 LP51 4"
0.237" 10/5/76 1LPO4B4 LP50 4"
0.237" 8/30/76 1LP14C4 LPK25 4"
0.237" 8/28/78 ILP14B3 LPK9 3"
0.226" 6/23/78 1LP02B10 LP7 10" 0.600" 4/30/76 1LP02B10 LP1 10" 0.593" 7/8/76 ILP02B10 LP2 10" 0.593"-
6/23/76 ILP12A16 LPK4 16" 0.375" 10/3/77 4
.. w4
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1LP02A12 LP10 10" 0.365" 5/14/77 ILP02A12 LP11 12" 0.365" 7/12/77 1LP02A12 LP23A 12" 0.375" 4/18/77 ILP05A12-18 LP23B 12" 0.375" 4/18/77 a.
On November 8, 1978, the inspector requested to use Kaiser Engineers, Incorporated (KEI) densitometer in reviewing the above radiographs. The KEI personnel informed the inspector that the densitometer was not always actuate and that the Peabody Magnaflux Corporation (PMC) densitometer was more MG actuate and should be used when densities are to be taken of radiographs. A density reading was taken,. by the inspector, from a designated radiographic area using the PMC densitometer and compared to a reading from that same area using the KEI densitometer. The readings were found to have a wide variance. The inspector was unable to detar-mine which, if either, of the densitometers was correct.
Both densitometers have National Bureau of Standards (NBS) calibrated density radiographic step vedges. The KEI densitometer is a Macbeth T0-504, No. 34210 and the PMC densitometer is a Macbeth - Quanota Log No. 7859. When the inspector returned to the site December 12, 1978, it was determined that the densitometers were in the same condi-tion as they were on November 8,1978. This is identified as an item of noncompliance in Appendix A.
(358/78-30-01) b.
On November 8, 1978, the inspector reviewed the first nine radiographs listed in Paragraph 4 above. These radiographs had been reviewed by Peabody Magnaflux Corporation, Kaiser Engineers, Incorporated and the Authorized Inspector. The following discrepancias were found in reviewing the reports
-; gig and radiographs.
-(1) Line No. 1HP03C10, Weld No. HP33; two mistakes in the report. Area 0-14 ehould be area'7;gl4 and the diameter is stated as 16" and is actually a 10" pipe weld.
.(2) Line No. 1HP06C4, Weld No. HP34; mistake in the re-port. One area of interest was 3 1/4" - 7" and the y
next area of interest was stated as 7 1/2" - 11".
The report is incomplete since all of the weld must be interpreted.
(3) Line No. 1HP06C4, Weld No. HP35; there is a missing report. The original radiograph showed an unacceptable
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area in the weld. The weld was repaired. There was a report and radiograph stating a second repair was made.
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There.was no record or radiograph of the first repair.
(4) Line No. 1LP17A3, Wald No. LP47;.the repair film did not hava a R1 tg,show that it was repair one, and the technique was unacceptable because the penetrameters were not shimed to the total thickness being radiographed.
(5) Line No.1HP03C10, Wald No. HP32; the film density '
gpgyg through three of the diagnostic areas varied by more than minus 15 percent from the density through the p enetrameter.
c.
On December 12, 1978, the inspector requested to review radiographs and reports that had been final reviewed for turn-over prior to operation. The radiographs selected for examination had been reviewed by Peabo<'y Magnaflux Corp...
Kaiser Engineers, Inc., and.the Authorized Inspector. In.
addition, several radiographs had been reviewed by CONAM.
The following discrepancies were found in reviewing the reports and' radiographs:
(1) Line No. 1HP21A4, Wald No. HPK1; wrong diameters stated on reports. The original report states 3" diameter pipe size and the two repair reports R1 and R2 state 4" diameter pipe sizes.
-(2) Line No'.1HP17A3, Wald No. HPK10; repair film does not have a R1 on the film. Records state a repair one was made.
(3) Line No. 1HP0684, Wald No. HP17; the technique was
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unacceptable because the penetrameters were not shimed to the total thickness being radiographed.
J (4) Line No.1HP08C3, Wald No. HPK17; 'dclead letter "F"
was not place adjacent to the penetrameter. The report stated that film-side penetrameters were used to radio-graph the weld.
(5) Line No. 1HP03C10, Wald No. HP30; mistake in the report. One area of interest was 3k" - 7" and the next area of interest was stated as 7h" - 11".
The repor't is incomplete since all of the weld must be interpreted.
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-(6) Line No. 1HP01A20, Weld No. HPIB; no orginal report, two extra reports, one stating R1 and another R2, and one extra film stating repair two (R2). The weld was
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first radiographed having one film with antifacts. The area with the fila antifacts was radiographed twice, first without the R2, which was acceptable and then another
.of the same area with a R2.
The weld did not show any defects on the original radiograph, therefore was not repaired.
Sa m (7) Line No. 1HP01A20, Weld No. HPl; no repair film or re-port and penetrameters not shimed. The film and report states unacceptable porosity in the weld. -There is not a report or film indicating that the weld was repaired.
(8) Line No'. 1HP01A20-1, Weld No. HPl; the penetrameters are not shimed, a black felt. ink pen was used to mark the identification (ID) on one film and the line No. was ihcomplete leaving the -1 off.
(9) Line No. 12P02B10 Weld No. LP1; mistake in the report.
One area of interest was 3k" - 7" and the next area of interest was stated as 7 " - 11".
The report is incom-plate since all of the weld must be interpreted.
'(10) Line No. 1HP03C10 Weld No. HP28; the report states that this pipe weld is 10 inch diameter, but the radio-graph shows that it is 71" around the pipe. Prior to leaving the site the inspe cor was informed that the weld was 22" in diameter.
k (11) Line No. ILP02B10, Weld No. LP1; the ID was lef t of f s) -;.
when radiographed, and then written with a black ink felt pen on the final radiograph. An acceptable area was raradiographed as a repair but there was no repair. This is a panoramaic radiographic and in apje of the areas where the film overlapped the dens'ity varies by more than minus 15_ percent from the density through the penetrameter.
d.
The inspector observed that radiography was performed on several welds using an IR 192 source on material less chan 0.25" without a separate procedure being prepared and proven by actual demonstration, as required by ASME Section III, 1971 Edition, with Summer 1972 Addenda. Peabody has cachnique radiographed shots of a 0.257" wall 4" diameter, a 0.280" wall 21/2" diameter and a 0.218" wall 2" diameter.
The thinnest material reviewed was 0.216".
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c Items in Paragraphs b, c, and d, are noncompliances identified in Appendix A, (358/78-30-02).
' Except as noted.. no items of noncompliance or deviations were identified within the' areas observed.
- Exit Interviews The' inspector met with site representatives (denoted in the. Person,s Contacted Paragraph) at the conclusion of the inspection and summarized
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Yy3 Docket No. 50-358 r.&
Cincinnati Cas and Electric Company ATIN: Mr. Earl A. Borgmana Vice President
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Engineering Services and Electric Production 139 East 4th Street Cincin==ti, OH 45201 Gentlemen:
Thank you for your letter dated March 2, 1979, informing us of the stepa you have entran to correct the noncompliance identified in our letter dated February 1, 1979.
During a telephone conversation, on March 14, 1979, between R. L. Wood of CG&Eco and K. D. Ward of this office, Mr. Wood stated that their original respw se to item 5b(4) was in
- error and that the weld would be re-radiographed using the l
appropriate shim thickness.. We will av==ina your correceive action during a future inspection.
Your cooperation with us is appreciated.
, Sincerely, r.2:5 f
G. Fiore111.,_ Chief Reactor Cor.acTruction and Engineering Support Branch ec:
J. R. Schott, Plant
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Superintendent i
ec w/ite dtd 3/2/79:
i Central Files J '
Reproduction Unit NRC 20b PDR Local PDR NSIC TIC U. Young Park, Power
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3/20/79 NAC Form 318A (R *K) ($-76) NRCM O2040
- U. S. GOVERNMENT PRINTING QFFICEa 1978-2$3414 D
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ma%ggg THE CINCINNATI GAS & ELECTRIC COMPANY CK CIN CIN N AT).CMIC 4 5201
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March 2,1979 QA-1107 U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J. G. Keppler, Director RE: WM.H.ZIM1ERNUCL$ARPOWER' STATION-UNITI IE INSPECTION REPORT 50-358/78-30, CONSTRUCTION PERMIT NO. CPPR-88, DOCKET.NO. 50-358, W.0. #57300-957, JOB E-5590 Gentlemen:
This letter constitutes our fonnal reply to the subject Inspection Report.
It is our opinion that nothing in the report or in this reply is proprietary in nature.
Our re:Iponse to the items of noncompliance identified in Appendix "A" of the -
report follows. Please note that the item numbers are those used in the body of the report rather than those used in Appendix "A".
Corrective Action Taken and Results Achieved
~
Item 5a The Henry J. Kaiser Company (HJK) densitometer, Macbeth T0-504, No.' 34210, was removed from service on February 12,1979, and returned to the manufacturer for rework and recalibration. Upon its return, it will be placed on regular recalibration schedule.
Item 5b (1) The report sheet for weld no. HP-33 has been corrected, initialed, and dated.
J (2) Review of film for weld no. HP-34 showed that the entire weld had been interpreted. The clerical mistake in the report has been corrected, initialed, and dated.
(3) The record and film for the first r'epair of weld HP-35 has
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%S. Nuclear RJgulator( Comission I
Region III March 2,* 1979 - QA-1107 Page 2 l
been located and added to the records.
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(4) The repair film for weld LP.-47 has been so irarked, initialed, and dated. The technique used for this radiograph has been reviewed and is felt to be acceptable.
(5) It has been agreed that weld HP-32 will be re-radiographed to correct film density after the system is turned back to construction by the Electric Production Department.
Item Sc (1) The reports for weld HPX1 have been corrected, initialed, and dated.
(2) Repair film for weld No. HPK10 has been noted as Rl. Report has been annotated, initialed, and dated.
(3) Weld HP-17 has been removed and replaced by weld HPX20.
(4) It has been agreed that weld HPK17 is to be re-radiographed
- after the system is turned back to construction by the Electric Production Department.
(5) A review of the film for weld No. HP-30 shows that the weld was completely interpreted. The report has been corrected, initialed, and dated.
(6) The original film for weld HPlB, which showed that repair was required, has been lost. However, a copy of the report has been placed -in the film pack. The repair was made..and re-radiographed as R1 and the weld was again rejected. The second repair was then re-radiographed as R2 and accegted.
(7)&(8) Weld No, HPl has been remoYed and replaced. This removal and replacement is otherwise documented, (9) Review of.the film for weld No. LPl shows that the film was completely interpreted. The report has been corrected, initialed, and dated.
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(10) The report for weld No. HP-28 has been corrected, initialed,
- and dated.
(11) A portion of weld No. LPl was re-radiographed for technical
. reasons, and it was determined that no repair was required.
The film was mistakenly designated Rl. The records have been 1
corrected to identify this film as a "reshoot".
The density variations at the film overlaps are not within the area.? c' !*terpretation, and are 1 normal consequence of the
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U. S. Nuclear RIgulatof. Compission i
Regioff III March 2,1979. QA-1107 Page 3 panoramic radiographic technique.
Item 5d Peabody Magnaflux will prepare a radiographic inspection procedure based on IR-192 source for material less than 0.25" wall thickness.
Although this procedure had not been prepared at the time of the
' inspection, the technique had been qualified, and documentation of the qualification was presented.
Because of the number of inspection findings, an audit of 20 addit-ional radiographic packages was performed. This audit included various systems and covered the same radiographing time period as the inspected radiographs. The audit confirmed that the inspection findings were typical. As a result, it has been agreed that each.
radiograph package would be reviewed prior to system turnover, and that necessary corrections or clarifications would be made at that time.
Corrective Action to be Taken to Avoid Further Noncompliance It should be noted that all findings from this inspection were clerical or technical mistakes,.which would be expected to have a rninimal effect en plant safety. Of the 40 radiographs reviewed, no rejectable welds were identified.
In order to minimize future noncompliances resulting from mistakes of this nature, a cognizant engineer from the licensee's Quality Assurance & Standards Section will be assigned to conduct an additional review of each radiograph package prior to filing with the quality assurance records.
As previously noted, existing radiograph packages will be reviewed critically prior zo system turnover, and corrections.er clarifica-tions ir.ade at that f.ime.
Date Nhen Full Compliance will be Achieved Clerical mistakes identified during the inspection have been. corrected and are now in compliance. Welds HP-32, Item Sb (5) and weld HPK17, Item Sc(4), require re-radiography after the system is turned back to Construction. Full compliance is expected by May 1,1979. The Peabody Magnaflux radiographk procedure for materials less than 0,25" wall thickness, Item 5d, is expected to be completed and qualified by May 1, 1979. The HJK ' densitometer is expected to be returned to service by June 1,1979.
The responsibility for performance of special processes, including non-2 destructive examination, and associated quality assurance has been assigned to HJK, with licensee personnel performing an audit function, It is now cur feeling that the effectiveness of this phase of our
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' U. S. Nuclear Regulato{' " omission
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'.. March 2,.1979 - QA-1107 Page 4-
' quality assurance program would be improved by direct participation of CG8E Quality Assurance personnel in the review process.of HJK NDE activities.
We trust that this letter. is an adequate response to your IE Inspection. Report 178-30.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By
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E. A. BORGMANN Vice President Engineering Services and Electric Production RLW:pa 1
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VAN 7 1980
' DocketNo.50-358~h
,j Cincinnati Gas and Electric Company ATTN: Mr. Earl A. Borgmann Senior Vice President Engineering Seivices and Electric Production 139 East 4th Street Cincincati, OH 45201 Gentlemen:
This refers to the inspection conducted by K. D. Ward of this office on September 18-20 and December 11&l2,1979, of activities at W. H. Zimmer Nuclear Power Plant authorized by NRC Construction Permit No. CPPR-88 and to the discussion of our findings with Mr. W. W. Schwiers and others at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection ccasisted of.
a.; elective examination of* procedures and representative records, obser-vations, and interviews with personnel.
No items cf noncompliance with NRC requirements were identified during the course of this inspectioc.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,: Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you or your contractors believe to be proprietary, you must aiTply in writing to this office, within twenty days of your receipt of this letter, to with-hold such information from public disclosure. The application must in-clude a full statement of the reasons for which the information is con-aidered proprietary, and should be prepared so that proprietary informa-tion identified in the application is contained in an enclosure to the application.
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NEN 7 19 ' O Cincinnati Gas and Eledtric Company O
We will gladly discuss any questions you have concerning this inspection.-
Si.ncerely, G. Fiorelli, Chief Reactor Construction and Engineering Support Branch E' closure: IE Inspection Rpt.
n No. 50-358/79-17 cc w/ enc 1:
'J. R. Schott, Plant Superintendent Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Harold W. Kohn, Ohio Power Siting Commission Citizens Against a Radioactive Environment Helen W. Evans, Director, Division of Power Generation t
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III Report No. 50'358/79-17 Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas & Electric Company 139 East 4th Street
. Cincinnati, OH 45201 Facility Name:
W. H. Zimmer Nuclear Power Station Inspection At:
W. H. Zimmer Site, Moscow, Ohio
. Inspection Conducted: September 18 - 20, and December 11 - 12, 1979 inspector:
//,,2./fd sra Q u Approved By:
D. H. Danielson, Chief
//G 80 Engineering Support Section 2 Inspection Summary Inspection on September 18 - 21, and December 11 - 12, 1979 (Report No.
50-358/7)
Areas Inspected: Review of procedures, nondestructive examination (NDE) data reports, personnel certifications, and radiographs of various systems. The inspection involved a total of 25 inspection hours onsite by one NRC inspector.
Results: No items of noncompliance or deviations were identified.
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DETAILS Persons Contacted
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Cincinnati Gas & Electric Company (CG & E)
- W. Schwiers, Principal Q' and Standards Engineer A
- R. Woods,aQA and Standards Engineer *
~W. Murray, Engineer R. Ehas, Lead QA Engineer Kaiser Enaineers, Incorporated (KEI)
- K. Baumgarten, Acting QA Manager A. P,allon, Welding /NDE QA Engineer Peabody T'esting Magnaflux Corporation (PTM)
A. Sellars, NDE Superviose Nuclear Enerry Services, Incorporated (NES)
R. Bott, NDE Superviose R. Ziebar, Level II Radiographer Hartford Steam Boiler Engineering and Insurance Company (HSB)
T. McCox, Authorized Nuclear Inservice Inspector (ANII)
The inspector also contracted and interviewed other licensee and contractor employees.
- Denotes those present at the last exit interview on December 12, 1979.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (358/78-30-01): Densitometer calibration. The densitometer was returned to the manufacturer for rework and recalibration.
It was returned to the site and is now in storage not being used.
(Open)'Noncospliance (358/78-30-02): Of the. seventeen discrepancies found on this one noncompliance, the following three items remain open.
Item Sb (5): The weld HP-32 has not been reradiographed. The film density is unacceptable.
Item Sc (4): The weld HPK-17 has not been reradiographed. The lead letter "F" was not on the film adjacent to the penetrameter.
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Item Sc_(8): The weld HP-1 has not been reradiographed. The penetrameters have not been shined.
The licensee stated that they should be closed out the first part of 1980.
Functional or Program Areas Inspected t
1.
General Information r&.
Reference.a. NRC Report No. 50-358/78-19 b.
NRC Report No. 50-358/78-23 c.
NRC Report No. 50-358/78-30 d.
Letter QA-1107, dated March 2, 1979, to Mr. J. G. Keppler from Mr. E. A. Borgaann. (Formal response to the items of noncompliance).
4 Preservice inspection (PSI) is to be completed approximately January, 1980.
2.
Review of Revised and New Preservice Inspection Procedures The inspector reviewed the following NES procedures.
Ultrasonic Examination Procedure for Closure Head Welds,.
a.
No. 80A1171 Revision 0, January 19, 1979.
b.
Ultrasonic Examination Procedure for Closure Head and Recircula-tion Pump and Valve Studs and Nuts, No. 80A1175, Revision 1, December 27 1978.
c.
Automated Ultrasonic Examination Procedures for Reactor Vessel Nozzle Inner Radius No. 80A1176, Revision 0, December 27, 1978.
d.
Manual Ultrasonic Examination Procedures for Nozzle Inner Radius Areas, No. 80A1177, Revision 0.
General' Magnetic Particle Examination, No. 85f1591, Revision 1 e.
January 12, 1979.
f.
Ultrasonic Examination Procedures for Control Rod Drive Housing
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Welds, No. 80A1184, Revision 0, January 3, 1979.
No items of noncompliance or deviations were identified.
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Review of Data and Audit Reports
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The inspector reviewed the following:
a.
In'formatibn available for the PSI activities to date.
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b.
Audit of NES by Sargent & Lundy (S & L) c.
. Audit of NES by CG & E.
No items of noncompliance or deviations were identified.
'4.
NDE Personnel Certificates The following NES NDE personnel certifications were reviewed and
,found to be in accordance with SNT-TC-1A, 1975 Edition.
NAME E
PI E
dI R. Barnes II II R. Bott II II D. Burrelli II
.K. Defel
-I J. Jensen II II S. Neeach II II J.- Robinson II II G. Sechler II II J. Wolf II II
'K.
Dew II II II M. Shallis II II No items of noncompliance or deviations were idertified.
5.
Independent Inspection The inspector interpreted the radiographs and reviewed the reports of the following' welds.in accordance with ASME Section III, 1971 Edition, Summer 1972 Addenda and the applicable procedures that uere used.
(Reference item of noncompliance identified as 354478-30-02)
'Line Weld Diameter Thickness Date RT
.1HP06C4 HP17A 4"
0.237" 10/10/77 1HP01A20 10HP 28" 0.625" 3/12/76 IWR44B6 WR-1 6"
0.280" 11/22/76 IWRS2A6 WR-2 6"
0.280"-
11/23/76 IWR52A6 WR-3 6
O.280" 2/16/77 IWR44DA2 WR-19 4"
0.237" 11/23/76 1RT01AA4 RT-K-99 4"
0.337" 6/1/78
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Line Weld-Diameter Thickness
0.337" 1/13/77 1RT08A4
~RT-140:
4" 0.337" 1/12/77 1HP08C3 HP-19B 3"
0.438" 10/19/77 1HP08C3 HP-19C 3"
0.438" 10/11/77 1HP08C3-HP-19D 3"
0.438" 11/2/77 1HP08C3
'HP-19E*
3" 0.531" 10/7/77 1HP08CA14 HP-19F YF 0.438" 10/21/77 1HP080C3 HP-19G 3"
0.438" 10/13/77 11EP08C3 HP-19H 3"
0.438" 10/31/77 1HP06AA HP-19K 3"
0.438"
,12/20/78 ILP02B-10 LP-6 10" 0.593" 8/12/78 IFC01312 FC-9 12" 0.375" 3/28/77 ILP04B4 Lp49 4"
0.237" 8/12/76 IFC02ABB FC23
. 8".
0.322" 12/17/76 ILP04B4 LP55 4"
0.237" 3/3/77 ILC19AA2 LC-26D-1 2"
0.218" 4/26/79 ILC05A-3
.LC-7 3"
0.216" 7/21/78 ILP14C4 LP66 4"
0.237" 10/22/76 ILP09C3 LP41 3"
0.216" 4/7/77 ILP22A-6.
LP-X1 6"
0.280" 3/11/77 1DG18AA8
.DG-K-31 8"
0.322" 10/3/77
'1CY50AA2 1/2 CYK-79 2 1/2" 0.203" 9/30/77 1DG18AA8-
.DG-K-33 8"
0.322" 10/17/77 1FC39CA6 FC34A 6"
0.280" 11/29/77 IFC32 ABS FCK-74 8"
0.322" 6/12/78 IFC14ABD.
FCK101 8"
0.322" 3/10/78 1HP08C3 HPS2 3"
0.438" 10/31/77 11N01A3 INK 49 3"
0.216" 11/19/78 11N09B-3 INK 50 3"
0.216" 11/19/78 1LP02A12.
LP19 14" 0.375" 6/01/76 1HP21A4 HP53 4"
0.237" 9/21/76 II.P01A20-22 LP29B 20" 0.375" 2/11/77-ILP02B10 LP4 10" 0.593" 5/24/76 1HP21A4 HP-54 4"
0.237" 9/8/76 1HP17A3 HP-56C 3"
0.216" 9/12/77 ILC10A-4 LC-4 4"
0.237" 7/05/78 1FWC2EA1843 FW52A 18.43" 1.3542 4/05/77 ILC0A-3 LC-5 3"
0.216" 7/13/78 1FW02GA18 FW-59 12" 1"
4/11/76 1MS26AB10 MS61 10" 0.594" 10/29/76 IMS24AB3 MSK5 3"
0.300" 6/28/77 e
IMS24AA3 MSK6 3"
0.300" 9/ 15/77 IMS24AC3 MSK8 3"
0.300" 10/3/77 1MS24F4 MSK10 3"
0.300" 9/8/77 1R12086 RI-9 6"
0.432" 2/28/77 1R101B4 RIK29 4"
0.438" 6/14/78 1RR02CK10 RRB21 10" 0.594" 6/2/76
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Line Weld Diameter Thickness Date RT 1RR02AA20 RRA33 10" 0.594" 9/7/76 1RH11C4 RH228 4"
0.237" 1/6/77 1RR02AA20 RRA8 20" 1/030" 8/12/76 1RH12CBS RH195 3"
0.438" 3/22/77 1RH12A8 RH196 3"
0.438" 3/25/77 1RH12A8 RH196A 8"
-0.500" 3/24/77 1RH12A8-RH196B 8 "'
O.500" 4/4/77 1RH12A8 RH196C 8"
0.500" 4/14/77 1RH12A8 RH196D 8"
0.500" 4/13/77 IMS26AB10 MS60.
10" 0.594" 11/1/76 IFC22A6 FC136 6"
0.280" 4/12/77 ILP22A-6 LP-K-26 6"
0.280" 3/28/79 1HP03A14 HP37 10" 0.718" 7/13/76 1HPOSA10 38HP 10" 0.718" 6/11/76 1HP03A14 HP-25 14" 0.938" 2/11/77 1DG-10AA-28.
DG-6 28" 0.437" 6/17/77 IDG-09BB-24 DG-2 24" 0.375" 5/23/77 1FC034 FCK-24 12" 0.375" 11/9/77 The above welds were selected as being the final radiographic and report review for turnover prior to operation. As of September 1979, the following reviews had been made. The September 9,1979, inspec-tion by the NRC inspector still found' discrepancies. The licensee then hired NES to re-review all reports for accuracy and radiographs for techniques only. As of December 91979, NES had reviewed 812
, radiographic welds and found 509 unacceptable because of inaccurate reports or unacceptable radiographic techniques. There are approxi-mately 60 welds to be radiographed because of unacceptable techniques.
NES has approximately 2500 more radiographs to review and this will consist of interpreting the radiographs for weld quality and techniques and reviewing the reports for accu' acy.
r The radiographic film packages reviewed by the RIII. inspector had been subjected to one or all of the following reviews:
Peabody Magnaf1'ux Corporation a.
A Level I or Level II radigographer performed all the radiography and a. Level II interpreted the radiographs for weld quality and techniques and completed'the reports.
b.
Kaiser Engineers, Inc.
A radiographic film interpreter Level II interpreted the radio-graphs for weld quality and techniques and reviewed the reports for accuracy.
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The Authorized Nuclear Inspector The ANII interpreted several radiographs for weld quality and
- technique and reviewed the reports for accuracy.
d.
OCONAM A Level II radiographe*r was contracted to interpret several '
radiographs for weld quality and techniques and review the reports for accuracy.
e.
The Cincinnati Gas & Electric Company As of.a -result of the NRC noncompliance. in December 1978, a
~
cognizant engineer from the licensee's Quality Assurance Standards Section received each radiograph package prior to filing with the quality assurance records in accordance with the CG & E letter QA-1107. This consisted of a unqualified' radiographer checking the reports for completeness and varifying that there were radiographs in the packages.
f.
Kaiser Engineers, Inc.
A radiographic film interpreter Level II, in some cases was the same individual that interpreted the radiographs months / years before, reviewed the radiograph packages critically prior to system. turnover in accordance with the CG & E letter QA-1107.
This consisted of checking accuracy of the report and verifying that there were radiographs in the packages.
No items of noncompliance or deviations were identified.
Exit Interview The inspector met with site representatives at the conclusion of the in-spection. The inspector summarized the scope and findings of the inspec-tion noted in this report.
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ADR 3 1950 MEMORANDUM FOR:
Victor Stello, Director Office of Inspection and Enforcement FROM:
William J. Ward, Senior Investigator Office of Inspection and Enforcement THROUGH:
Dudley Thompson, Executive of ficer for operations support Office of Inspection a-d Enforcement 508 JECT:
O!$CUSSION OF THE INTERRELATIONSHIP OF THE IE INVESTIGAT!vE PROGRAM WITH THAT OF THE OFFICE OF INSPECTOR. AUDITOR (OIA)
Recent discussions between IE and CIA have tended to focus attention upon the IE Investigative Program in general, and its relationship to 01A investigative responsibilities in particular. During these discussions, DIA essentially has maintained tnat although IE has both the responsibility and authority to
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conduct " health and safety" investigations, any instances of criminality 5
associated with these IE investigations become the investigative responsibility of CIA. The IE investigation staff asserts that the essential distinction between the responsibilities of the two offices does not involve the question of potential cristnality; rather, the difference lies in whether a particular matter is internal or external. gy internal, we mean an investigation involving an NRC esployee or contractor; by external, we mean an investigation concerning the licensed industry er a matter of MAC regulatory interes'.. We feel that the issue of actual or potential criminality is at best a subset of the larger issue of internal versus external investigative authority.
The purpose of this memorandum is twofold. First we wish to acquaint you with what we believe the IE investigations program should encompass if it is to be of greatest benefit. Secondly, we hope.to convince you that the apparent impasse between IE and CIA in this matter is no sinor " turf fight".
- Rather, it is a major issue that must be resolved in view of its impact upon the future of the IE Investigation Program. '
In support of their c16fe of external criminal investigative authority, DIA l
alludes to such factors as legislative intent, the Inspector General Bill, (Public Law 95-452 which does not apply to the NRC), and their belief that DIA is the Ifneal successor to the AEC Division of Inspection. They also note that the Commission has designated Mr. Cummings as the NRC point of contact for matters of fraud in response to a letter sent to all agencies by the
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President on Oecember 13, 1978.
(This letter, which is appended as Enclosure (1) clearly deals with program fraud, i.e. fraud involving public funds such as CETA or MEDICARE).
Lastly, DIA believes that their criminal referral responsibility i
laplies investigative authority, and that their charge to conduct investigations j
concerning, "... the integrity of all NRC operations" should be construed to
)
confer external investigative authority because criminality by a Itcens.ee affects the integrity of our inspection and enforcement program.
Our rebuttal to 0!A's claims rests upon two premises.
The first is that the official expression of authority for either office is the current NRC Manual l
Chapter pertaining to that Office in concert with any Delegations of Authority issued subsequent to the pubitcation of the Manual Chapter. Consequently, any discussion of current authority should be based upon the contents of the NRC Manual Chapters.
Manual Chapter 0113 sets forth the functions of CIA. To us, the clear thrust of the chapter is to establish OIA as an internal investigative and audit organization. We see no evidence in MC 0113 of CIA authority to conduct external investigations. A copy of MC 0113 (without appendix) is Enclosure (2).
In contrast, the IE Manual Chapter,, Manual Chapter 0127 gives IE a broad external investigative sandate. We have responsibility to investigate
.(
Ifcensees, their contractors and suppliers, applicants, persons, individuals, snd any organization subject to NRC jurisdiction. MC 0127 describes the purpose of these investigations as being, "to ascertain the status of compliance with NRC requirements," and to, " identify conditions... that say adversely affect the public health and-safety, the conson defense and security, the environment, or the safeguarding of nuclear materials and facilities."
Additionally,IC 0127 specifically charges IE to, " Investigate incidents, accidents, allegations, and other unusual circumstances involving satters in the nuclear industry which any be subject to NRC jurisdiction...."
No mention is made in either manual chapter of criminsk investigations. A copy of MC 0127 (without appendfx) is Enclosure (3).
The subsidiary issue of potential criminality has become unduly controversial, in our view, primarily because it is usually discussed in the abstract rather than in relation to the NRC's regulatory responsibilities. For instance, criminality, be it actual or suspected, can be considered as falling into two categories. The first would be that encountered during investigations or inspections (or being brought to the attention of the NRC in some other fashion) which is only periphere) to NRC's interest or responsibilities.
Examples of this category would include evidence of larceny of private property, embezzle-ment of licensee funds, vandalism of construction equipment, or violations of federal laws such as smuggling, counterfaiting, or income tax evasion. L'pon learning of such offenses, the NRC has a clear responsibility to make the r-information available to the appropriate federal, state, or local law enforce 4, S
ment agency; however, NRC would certainly have neither the authority nor the desire to investigate such matters.
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3 The second category would be cases which are clearly interrelated with matters within the jurisdiction of the NRC. The vast majority of these would involve either vlotations of the Atomic Energy Act, or the Ge_eral Fraud _Against the n
1 Governmen' w as.
Examples of the fomer eight involve willful violations of various NRC regulations made criminal by statute, unlicensed ' possession of -
nuclear material, or theft of SW1. Records falsification, lying to an inspector er investigator, or attempts to deceive NRC to obtain a Itcense are v'iolations which might involve fraud.
In each of these examples the elements of potential criminality and NRC's regulatory interest are inextricably intertwined. Although there say be a number of options open to the NRC when such a situation is encountered, it is
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sur belief that the appropriate response would be to continue (or initiate) the IE investigation and to collect all information pertinent to NRC's interest.
Such a course of action would not foreclose a future decision to pursue criminal prosecution. In those rare cases where prompt field response by the i
FBI might be warranted such as theft of SM4 or sabotage, the NRC investigators could either assist the FBI or conduct a parallel investigation in coordination with the FBI as was done in the recent case of the misa11gned ECCS valves at i
QuadCities.
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In this connection, it is interesting to note that MC 0113 (not 0127) explicitly notes IE's obligation to make prompt and direct referrals to the.
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Fl! (see M: 0113-026).
. _1 Such an approach would not affect the way in which the IE investigation should be conducted. idhether or not criminality is involved, IE investigators realize the need to collect sufficient information to support successful enforcement actions. They routinely identify and collect copies of all records that are pertinent to the matter being investigated.
Porsc,ns who can provide sestantive information are identified, interviewed, and when warranted by the nature of the case, signed and/or sworn statements are obtained from them.
i Such investigative interviews are conducted in the same manner regardless of whether criminality is involved. Thus, statements etained by IE during these f aterviews could be used for prosecutive as well as civil enforcement purposes.
5 Each IE field investigation results in a report of investigation which can be referred, as appropriate, to the Department of Justice (or state or local authorities) through OIA, if desired, for prosecutive determination. A Properly conducted, well documented IE report of investigation should be i
sufficient for determinations of either civil or cristnal enforcement action.
j ide submit that this approach offers a reasonable and viable approach for the i
conduct of IE investigations.
It allows the NRC to fulfill its regulatory responsibilities while ensuring that the Department of Justice receives suffi-cient information upon which to base a prosecutive decision. Note that i
L inasmuch as mest of the offenses in question are not seeking gun" cases, prosecutions for cases involving potential fraud or willful violations of NRC e
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regulations can be successfully prosecuted upon completion of IE field efforts as long as NRC enforcement action is held in abeyance.
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3gh We are not proposing that IE or anyone else in NRC undertake criminal investigations, per se. We share the view of CELD that neither IE nor CIA possesses such authority and that legislative changes would be needed to obtain it.. Rather, we submit that matters of NRC regulatory interest should be pursued by IE regardless of whether they also appear to involve criminalf ty.
Our focus is upon the relationship of the matter to our regulatory authority and the issue of any possible included criminality is subsidiary'to it for purposes of the investigation.
(We recognize that the role of criminal penal-ties in relation to the NRC enforcement program is a separate, albeit closely related issuc.)
To summarize our first proelse, we believe that IE currently has the authority and sole responsibility for all external investigations.
By the same tokeri, we believe that DIA presently lacks either the authority or responsibility for such investigations. Consequently, the IE Investigative Program should encom-pass all external investigations needed by the NRC without regard to whether they may additionally involve actual or suspected criminality.
Our second premise is that regardless of how one interprets the existing authorities, the conduct of external investigations is a function that logically belongs within IE in its role as the primary operational am of the NRC. As a line office under the Executive Director for operations, IE has assumed the predominant responsibility for operational matters involving fie1J coordination with the nuclear industry. There appears to be a clear trend towards increasing this operational role. We suggest that the evolution of the Incident Response Progras and the Rogovin recommendation regarding transfer
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of certain 00R functions to IE is evidence of this perception of the IE opera-tional role. As the conduct of external investigations is clearly an opera-tional activity, it is consistent to place responsibility for them within IE.
In recognition of this growing responsibility, we have increased investigator staffing levels both quantitatively and qualitatively. As reflected in 4
Enclosure (4) which summarizes investigator staffing, we have a total of 21 investigators within the IE Investigations Program..Jf these,18 have prio~r investigative experience. More significantly. 11 of the 12 IE investigators hired over the past two years have at least five years of criminal investiga-tive experience. Additionally, there are recruitment requests for three additional positions.
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When we examine the foregoing evidence, the argument for IE conducting all external NRC investigations boils down to the following three points: (1) IE has the authority to conduct such investigatinns; (2) the conduct of such investigations is consistent with the operational role of IE; and (3) IE has j
the capability to conduct such investigations.
s Conversely, there appear to be several cogent arguments 'against DIA assuming this function. The first is that it would involve a Commission Staff office in a matter normally under the cognizance of the E00.
It has been the polity of the Commission to place operational activiites under the EDO.
This most 5
assuredly would represent a deviation from that,9ractice'.
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staff of 21). Thus it would be necessary to expand CIA's staffing level by a significant facter at a time of government-wide austerity or to transfer. some resources free IE. It is unlikely that either action could survive a rigorous '
cost-beneftt analysis.
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We believe that if 0!A were to be given responsibility for external investigations, enforcement coordination would become a grave probles.
To i
data, NRC has experienced difficulty in coordinating the actions of any two offices in any operational matter and this does not promise to be any easier.
j The problem would be exacerbated by the fact that potential criminality exists j
in most It investigattens. The spectar of willful noncompliance is present in many investigations as is the possibility of violations of 18 USC 1001 in east l
investigations conducted in response to allegations of record falsification.
OIA would need to be privy te virtually every IE investigation which in,itself i
would place a heavy reporting burden upon both the Regions and IE:HQ.
There are other einer issues associated with the present conflict such as confusion among Ifconsees and fapact spon the morale of the IE investigators who feel quita capable of performing this important function. The bottos line, however, is that assimption of this responsibility by OIA not only would j
have a significant ispect en the IE Investigations Program, but upon our entire inspection and enforcement effort. We feel that the result would be to delay enforcement proceedings and to create an additional drain upon IE Note, for examp e, the current problems with MPI, Marble Hill, resources.
American X-Ray, $7P and others. ~..,...
Needless to say, it is our strong recommendation that the issue be resolved as soon as possible, hopefully by establishing clearly the authority of IE to conduct all external NRC investigattens. It appears that your personal involve-
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ment is needed. As we indicated earlfer, this is a vitat issue which must be resolved so that we can get en with our business.' As your senior investigator, I would appreciate the opportunity to participate in any staff negotiations pertaining to this asttar in view of its obvious tapact upon the program for which you held me responsible. -
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NUCLEAR REGULATORY COMMISSION
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Docket Fo. 50-358 l
Cincinnati Gas and Electric
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M Company ATTN: Mr. Earl A. Borgmann Vice President, Engineering Services and Electric Production
-139 East 4th Street Cincinnati, 08. 45201
. Gentlemen:
This refers to the investigation conducted by Messrs. G. A. Phillip, K. D. Ward and T. E. Vandel of this office on April 7-9 and 30, May 1-2 and 20, 1980, of activities at the Wm. H. Zimmer Nuclear Power Station authorized by Construction Permit No. CPPR-88 and to the dis-cussion of our findings with Mr. B. K. Culver and others at the conclu-sion of the onsite portion of the investigation on May 2,1980.
This investigation related to allegations concerning installed safety-related piping. The enclosed copy of our investigation report identi-fies areas examined during the investigation. Within these areas, the investigation consisted of an examination of pertinent records and procedures, independent evaluations and interviews with personnel.
During this investigation, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the attached Appendix A.
This notice is sent to you pursuant to.the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office within thirty days of your receipt of this notice a written statement or expla-nation in reply, including for each item of noncomp1.iance:
(1) corree-tive action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance vill be achieved.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter vill be placed in the NRC's Public Document Room, except as follows. If the enclosures contain -
information that you or your contractors believe to be proprietary, you must apply in writing to this office, within five days of your receipt of this letter, to withhold auch information from public disclosure.
The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identificd in the application is contained I.
in an enclosure to the application.
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Ciasianeti Gas and Electric Rlt 2 seg Coupesy We will gladly discuss any p sion yee have soecarming this.
{ sapestisation.
.S'incerely,
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James C. Empylar Director Baclosures A, Estias
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II Inspectism Import Bo. 30-358/alN PJ es w/emels:
Mr. J. L schott, Flaat Superintendant Central Files Emproduction Unit REC 20b FDR 1aeal FDR E1C TIC Enrold W. Iobs, Power Sitias Caumission Citisens Assiast a Radioactive Enviremment Belas W. Evans, Stata of h
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n Appendix A NOTICE OF VIOLATION j
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Cinci.nnan Gas a:sd Electric Docket No.'50-358 p
Company Based on the results of the NRC Investigation conducted on April 7-9 and h, May 1-2 and 20,1980, it appears that certain of your activities were.:ot conducted in full complianca with NRC requirements as noted '
below, This iten is an infraction.
d 10.CFR Part 50, l'pendix B Criterion IV, states in part that "Heasures shall be est.ab bened to control materials, parts, or components which do' not confor:s to requirements in order to prevent their inadvertent use.or installation."
The Henry J. Kaiser Co. Zimmer Quality Assurance Manual in Quality a.
Assurance Procedure (QAP) No.16 requires in part that "All non-
- L' conforming' items will be segregated, where possible, from accept-able items, clearly identified with the applicable Hold or Defi-ciency Tag and ~ documented on the Nonconformance Report." It y
additionally requires that "Upon Verification that all work on the g,
item is complete and acceptable, the nonconformanes report (NR) is signed off in Section 13 by the Inspector."
t Contrary to the above 5 piping spools identified by NRE-1911 h';
Rev. 2 were released from segregation even though the Inspector had r
I signed off section 13 with a notat2.on of specific exceptions to I
acceptability of the material by identifying another NR controlling I,.i.-
the material. This release was achieved through unauthorized removal of the noted exceptions on the NR.
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The Henry J. Kaiser Co. Zimmer Quality Assurance Manual in Quality Assurance Procedure (QAP) No.16 requires in part that ".
material is clearly identified as nonconforming and is segregated, f
I when possible. Due to size limitations physical segregation may be impractical. In such instances tagging, marking or other means of identificatiot. is acceptable." Additionally QAP 15 requires that "A ' Hold' tag is placed on the item.
It is used in con-junction with a 'Nonconformance Report'."
Contrary to the above, 3 piping spools identified in NR E-2020 as nonconforming and required to be cleared by additional tests, not only had been released from the warehouse, but in addition had been installed without any " hold" tag being placed on the material.
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U.S. NUCLEAR REGULATORY COW.ISSION OTTICE OF INSPECTION AND ENTORCDiENT r
REGION III L
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0, Report No. 50-358/80-09 p
Docket No. 50-358 License No. CPPR-88 Licens'ee: Cincinnati Cas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Tacility:
Wm. H. Zinuser Nuclear Power Station Investigation At: Moscow, OH Chicago, IL Dates of Investigation: April 7-9 and 30, May 1-2 and 20, 1980
[2 Invest 15ators: _
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' CT A. Phillip 7[.S M 7/?/ro it. D. Wa.rd
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7 YJ Reviewed By:
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Date E. Norelius Assistant to the Director R. C. Knop, Chief j0ati Construction Projects Section 1 Investigation Susanary: Investigation on April 7-9 and 30. May 1-2 and I
- 20. 1980 (Report No. 50-358/80-09)
Areas Investigated: Because of allegations made primarily relating to the adequacy of piping velds, performed a review of records and procedures.
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s o-ande independent evaluations and conducted interviews of personnel.
The investination involved 94 investigation hours by three investinators.
Esisults:. Of four allesations. one, which related to the installation of pre-f abricated einina havina defective velds, was cartially substantiated in that the eines were installed before cuestions renardina their accent-ability were resolved. One item of noncomoliance an infractfion was b
identified:.(1) 10 CFR 50. Anoendix B. Criterion IV, releasi ef material g from searesation and' failure to use hold taas.
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REASON FOR INVESTIGATION an individual who contacted the NRC by telephone
-on February 28, 1980, One made allegations regarding the Wm. H. Zinumer Nuclear Fover Station.
of these allegations was that piping having def ective velds had been c
installed in a safety-related system.
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SUMMARY
OF FACTS 28, 1980, Following the receipt of allegations by telephone on February arrangements were made to interview the allager to obtain more detailed During an interview on March 3,1980, the individual made
'information.
several allegations, three of which involved matters under the juris-diction of the NRC. By letter dated March 11, 1980, the alleger was advised that an investigation would be conducted regarding those allega-tions which were as follows:
Defective velds in safety-related systems have been accepted, among 1.
them were welds CY606, RR42 and K811.
Five defective velds were identified in prefabriacted piping but the 2.
pipes were accepted and installed in a safety-related system inadequate and a acheduled six-week flush was reduced to two weeks.
3.
Allegation No. I was not substantiated.
Allegation No. 2 was partially substantiated in that three of five identi-fied pipes had been installed in the main steam relief system before ques-Two items o tions as to their acceptability had b'een resolved.It was also determined that at the t were identified in this regard.
d open the investigation a nonconforming report requiring disposition remaine During the investigation concerning the acceptability of the three pipes.
additional examinations were made of the pipes and they were determined to be acceptable.
Regarding Allegation No. 3, it was determined through contact with the primary scurce of the information upon which.the allegation was based, that he had lefe the site in November 1978 and problems in this area had been identified and resolved through NRC inspections conducted between November 1978 and the receipt of the allegations in March 1980.
Following completion of the investigation at the Zimmer site, the alleger contacted Region III and alleged he had evidence of a criminal 1
conspiracy and that the velds on the three above-mentioned pipes had been cut out and repaired during the course of the investigation and this The basis for these allegations.
information was withheld from the NRC.
b which consisted of recordings of three telephone conversatioas, was o -
No in-tained from the allager during an interview on May 8, 1980.
formation or evidence was obtained to confirm these allegatichs during I
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One ites of noncompliance, an infraction, was identified during this d
investigation.
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DETAILS 1.
Persons Contacted Cincinnati Cas and Electric Company (CC&Ef
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- g. K. Culver, Project Manager P
- W. W. Schwiers, QA Manager
- R. L. Wood, QA Engineer
- D. C. Kramer, QA and S Engineer S. Swain, Construction Manager
- J. F. Weissenber's, QA and S Engineer Kaiser Enaineers. Inc. (KEI)
- R. Marshall, Project Superintendent
R. M. Dorr, Construction Engineer A. Fallon, Welding /NDE QA Engineer-F. Oltz, Analysis and Procedures Supervisor, QA J. Deervester, Supplier QA D. Haag, QA Inspector Peabody Testina Services (Peabodv)
Ernest A1 dredge, President Charles Wood, Manas,er, Cincinnati Office (via telephone)
Wayne Draffon, Supervisor.(via telephone)
Alan Sellars. Field Supervisor D. Burdsal, Level II Inspector Nuclear Enerzy Services. Inc. (NES)
R. Bott, NDE Supervisor R. A. Zimber, NDE Inspector 2.
Introduction
?x on February 28,.1980, the Office of Inspection and Inforcement NRC Headquarters advised Region III of a telephone conversation with an individual who made allegations concerning activitiu at the Um. H. Zimmer Nuclear Power Plant Construction site, and requested that the individual be contacted. Later the same day during a tele-phone conversation with Region III, and during an interview on March 3,1980, the individual made several allegations.
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The individual stated that he had been esployed by a private detective agency, and the licensee, CG&E, through his employer, had engaged him to work under cover at the Zimmer site to investigate time card padding by site personnel. His investigation effort began on December [
T 10, 1979 and ended on January 4,1980. In addition to information regarding worker time card padding, he obtained information regarding i
other activities which was the basis for several allegatfbns, some of which related to matters under the jurisdiction of the NRC.
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a The individual stated he had earlier brought his information to the FBI. He indicated he was uncertain as to what action, if any, would i
be taken by that agency.
The individual stated he had documentation relating to his allegations in the form of weekly reports he had prepared and tapes of several of
.his conversations with site personnel. During the interview on March 3,1980, the individual played those parts of the tapes which he said contained pertinent information and made available copies of his reports.
3.
A11esstions Based on the information obtained through the interview with the allager, a review of the taped conversations and his ' investigative reports, three allegations involving activities under NRC jurisdiction were developed.
By letter dated March 11, 1980, the alleger was advised that an investi-gation of these allegations would be conducted. A copy of this. letter with the alleger's identification deleted is attached to this report as Exhibit A.
These allegations and information regarding' them obtained during the investigation are set forth below.
A11esation 1: Defective welds in safety-related systems have been accepted, among them were welds CY606, ER42 and K811.
t The identification of the specific welds in this allegation was ob-1 l
tained from a review of the tape th's alleger had made surreptitiously of his conversations with site personnel. According to the informa-tion obtained by the alleger, veld CY606 was buried in concrete 4
He between the Radvasta Building and the Containment, Building.
said it was his understanding that they dug it uf to repair it, but be was uncertain whether this was done.
Regarding veld RR42, the alleger said that he had informed CG&E that this weld was defective. He said he had heard that another testing firm had been hired as a consultant, and this firm had confirmed the weld was defective. He also said it was his understanding that this def ect was reported to the NRC.
I Regarding veld K811, the alleger said he was informed that this veld had "an insert f ault" and that KZ1 had ordered that it be accepted.
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The alleger stated that Peabody Ta' sting Services (Peabody), also referred to as Magnailux, personnel had informed him that some welds that Peabody, the nondestructive testing contractor, had rejected as faulty were subsequently accepted by KII, the site construction management contractor. He said that a Peabody en-ployee had records identifying the welds rejected by Peabody which were subsequently accepted by KEI. He indicated that by (ay of
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explanation CG&E had info'emad him that the interpretation of the
~
,7 film obtained through radiographic examinations of welds is a judgment call. The appearance of an item on a radiographic film may be judged to be a def ect by one individual and not by another and KEI could overrule Peabody.
Pindina:
On April 7,1980, the Peabody field supervisor was interviewed.
He stated that he had no records showing the welds Peabody had initially He rejected which were subsequently declared acceptable by KEI.
indicated that, although he was aware tSat this had occurred, he did not know how often and he.could not provide any specific instances.
He also stated that the results of radiographic examinations are recorded on reader-sheets. The radiographic film and the original-reader sheets are turned over to KEI. He said Peabody only had carbon copies of the reader sheets.
As a means of further evaluating whether KEI was accepting velds identified as defective by Peabody, a safety-related system, the High Presrtre Core Spray Systam, was selected and all reader sheets pertaining to it were reviewed. Of 99 welds in the system which were radiographed, two instances were noted in which Peabody had checked the reject column and KEI had lined that check out and had checked the accept column. The radiographs of these two velds were reviewed by an NRC inspector who is a certified NDE Level III.
He concurred that the velds were acceptable. Conversely, it was noted that in several instances, b.etween five and ten, the original accept check mark entered by Peabody had been lined through and a reject check had been entered by KEI.
Regar' ding the subject of welds and radiographs Af them, an NRC inspection conducted on November 8-9, and Decesfer 12-13, 1978 (Report No. 50-358/78-30) identified several discrepancies in radiographic techniques and reports. During a subsequent inspection on September 18-20, and December 11-12,1979 (Report No. 50-358/79-17) -
several more discrepancias were identified. CG&E then hired NES to rareview radiographs and reports of all velds which had been accepted for turnover prior to operation. This review began in October 1979 and was completed'in early April 1980. The review included 2.390 radiographed welds. Of those, 958 had report discrepancies, 543 had some technique problems and 14 velds were found to be.unaccept-able because of defects.
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l The KE1 Project Superintendent advised on May 1,1980, the 14 velds were being re-examined and resolution regarding them had not been coseleted. He stated that one of the 14 welds found to be unaccept-able s.= the subject of a nonconformance report and, therefore, had not been accepted for turnover. This weld, he said, should not have been included in the NES review. Another wald had.been cut out of the pipe for examination and it was determined that, although I,
it appeared to have a defect on the radiographic film, i't was, in P
f act, an acceptable veld.
- egarding weld No.1811, a review of records showed it was velded Ron November 9,1977, but because an Authorized Nuclear Inspector 7
ho1d,oint was.issed at the fitu,, the ve1d was cut out and re,1 aced by weld No. K916. The missed hold point was documented by Noncon-cc9 formance Report (NR) No. E-2138R1. This NR indicates that-the disposition was to cut out and replace the veld. It was determined that veld No.1916 had not yet received final acceptance.
Regarding veld No. RH42, records indicated this weld was ff est radiographed on August 9,1976, and found to have unacceptable porosity and slag in the areas of 36-48. The areas were repaired and a raradiograph performed on August 10, 1976 found it to be acceptable. A review was made of the radiographs for veld quality, techniques, and report accuracy by an NES Level II radiographer on January 25, 1980 as part of the above-mentioned re-review initiated after the 1978-79 NRC inspections. The NES Level II radiographer found some discrepancias which have not been rasolved, and the veld has not been given final acceptance.
4 r Regarding veld No. CY606, a review of records showed this veld was first radiographed on July *15,1976 and found to have incompleta The areas fusion and penetration in the areas of 0-13 and 13-16.
were repaired and the wel re-radiographed on June 8, 1977 and found to be accepenbla. A review was made of the radiographs for weld quality, technique ad report accuracy by an NES Level III radiographer on October 12, 1979,as a result of the NRC inspection conducted in 1978.l The Level III found some discrepancies which l
have not been resolved and the weld has not received final accept-i ance.
A11eastion 2: The manner in which safety-related installed piping was flushed was inadequate and a scheduled six-week flush was reduced to two weeks.
The alleger provided information that a site employee informed him on December 27, 1979, that another individual who had been employed as a general foreman at the site had objected to the flushing pra-cedures used. He had also objected when a particular flush th~
- should have taken six weeks was cut to two weeks. On one occasion the individual had demonstrated the flushing was inadequate by pounding on a pipe which released sediment and slag during the flush. The identity of the former general foreman was provided by.I the alleger.
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On April 7,1980,' the former general foreman was contacted Findinz:
and interviewed. This individual said he had worked at the Zimmer site from June 1973 until November 1978. In 1978 he was the general foreman of the flush group.
Regarding the six-week.versus two-week flush, the indivf)usi indicated it had been anticipated si,x weeks would be needed to prepare for and g
si flush one of the systema. He, hesever, was able to accomplish a satisfactory fluish in two weeEs'. He indicated that the shorter
~
time did not mean the flush was not done according to the require-Rather, it was a case of he and his men being able to accom-ments.
plish a job in less time than expected.
This individual stated that in his opinion the welding done on the critical systems, such as the main steam lines and in the reactor building, was good. He said, however, that several problems were encountered in the flushing activities while he was at the site but he was unable to provide information regarding any specific require-ments that were not met.
NRC inspections conducted subsequent to the departure of this indivi-i dual from the site included an examination of flushing activities -
and some specific problems were identified. On the basis of one of these inspections, conducted January 3-6 and 8,1979 (Report No.
50-358/.79-01), one ites of noncompliance and one deviation were identified. The noncompliance related t'o a failure to close a valve during a flush and an inadequate procedure to assure boundary valves are closed. The deviation was that the procedure did not require tagging of boundary valves. A second inspection conducted yebruary 27-28, March 1-2, 19-23, and April 9-11,1979 (Report No. 50-358/79-06) resulted in one item of noncompliance regarding flushing activities.
This related to a failure to maintain control of flushing waters re-sulting in the flooding of equipment in a system which had been turned l
over for preoperational testing.
The individual. indicated a matter of concern to him was that a hydrotest of the reactor containment was successfully performed, but af ter the test some instrument lines were cut out which invalidated He indicated he was uncertain at to whether CG4E would the hydrotest.
attempt to use this test as meeting test requirements or whether the NRC was aware the test had been invalidated by the subsequent modifi-cations.
On April 8,1980, the NRC Resident Inspector advised that he as well as CG&E vere aware that the initial hydrotest was not valid because He stated that of the subsequent modification of the instrument lines.
another hydrotest' was tentatively scheduled to be performed during 3-the sussser of 1980.
In view of the above, further investigation at the site in the area of flushing activities was not pursued.
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A11esstion 3: Five defective welds were identified in pref abricated piping, but the pipe was accepted and installed in a safety-related system.
Through a review of reports written by the alleger and the tapes of conversations with site personnel as well as informatiod supplied 1
through interview on March 3,1980, the following information was
[g obtained regarding this allegation.
During the NRC hearings in November 1979, a question was raised concerning an accident which involved the dropping of fuel rods.
A former site employee had provided information to attorneys,who,
were opposed to the licensing of the plant which was the basis for raising this question. A miscommunication between the former en-playee end the attorneys occurred, however. The question about an accident should have referred to piping being dropped from a tractor trailer rather than fuel being dropped.
The alleger advised that in about October 1979, a trailer load of pipes fabricated at the Kellogg Company, located in Pennsylvania, arrived at the site in the middle of the night. Since personnel and proper equipment were not available to unload it prcperly a member of CG&E management issued instructions to push the pipe from the truck onto the ground.
When the pipes were found on the ground the following day, it was decided that the pipes would have to be inspected by x-ray to determine whether they had been damaged. Peabody was instructed to x-ray (radiograph) the pipes and 5 to 8' faulty welds were identified.
Since Peabody had been instructed to check the pipes but not the velds, and since the welds had been tested and found to be acceptable before shipment by Kellogg, the pipes were approved by KEI Quality These pipes were installed in the Main S. team Relief Assurance.
System, a safety-related system.
Findinz: A bill of lading dated June 29, 1979 showed that Pullaan Power Products, a division of Pullman, Inc., Williamsport, Pennsylvania, formerly known as M. W. Kellogg Company, released to the Daily Express Company five pieces of pipe assembly I/S, weighi,pg 6,700 pounds,' for delivery to the CG&E Zinner site on Monday, July 2,1979. A packing
- slip accompanying the shipment listed the following pieces:
INS 08BB12-6B IMSO9BA12-1AH IMS08BA12-5BH IMS11B12-73H IMS10BA12-ICH A KII receiving stamp shows it was received on July 3,1979. Copies of the bill of lading and the packing slip were obtained and are attached to the report as Exhibits B and C. respectively.
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Each of these pipes (spool pieces) were for the Main Stesa Safety Relief Valve discharge and were carbon steel pipe assemblies ap-proximately 15' 7 5/8" long,12 3/4" in diameter and having a vall
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thickness of.687".
On hand at the Zimmer site were QA documentatioti packagek for each of these 5 spool pieces received from Fullaan. A copy or one g,
package was obtained. and is attached to this report as Exhibit D.
si e.;
On July 5,1979, Nonconformance Report (NR) No. E-1911 was prepared indicating " Spools were rolled off of truck onto ground and striking The other spools" and listing the above identification numbers.
issuance of this NR had the offeet of placing these pipe spools in a hold status in the KEI warehouse. On July 10, 1979, the KEI Construction Engineer entered the following disposition on this NR (1) Perform liquid penetrant test on all welds; (2) perform
" Rework.
Accept on basis of inspection
' visual inspection of weld and preps.
Should any pipe spool f ail due to inspections (1) and i
(1) and (2).
A KZI QA engineer (2) a separate Nonconfotaance vill be issued."
concurred in this disposition on the same date. A copy of NR E-1911 is attached to this report as Exhibit E.
NR E-1911 was voided and superseded by NR E-1911 Rev.1 on the same KEI and CG&E personnel advised that the dis-date, July 10, 1979.
position shown on NR E-1911 was reconsidered because they wished to
,1 avoid removing the paint from the welds which would be necessary NR E-1911 before a liquid penetrant examination could be performed.
"Perf ora
- RT I changed the first ites of the disposition to:
examination of all welds." A copy of NR E-1911 Rev. 1 is attached Rev.
to this report as Exhibit F.
23, 1979, addressed to a CG&E QA A QA Surveillance Report dated July engineer signed by the KEI NDE QA engineer, showed that on three spool pieces, veld X4 had rejectable indications, and requested to be advised concerning the dispositioning of these rejections.
' The CG&E QA engineer stated that to the best of his recollection, he did nothing in response to this request and could not recall A copy of this Surveillance having discussed the matter with anyone.
Report is attached to this report as Exhibit G g
l CG&E and KEI personnel stated all five spool pieces were radiographed on an "information only" basis but only the films for those three The X4 veld is.
Referred to in the Surveillance Report were retained.
Radio-a weld which joins a solid cap to one and of the spool piece.
-staphy is not the appropriate technique employed to examine a weld of this kind since the samma rays ause pass through the cap (about The KEI Construction Engineer 12' of metal) as' well as the weld.
said the radiographs were done with the thought that they sight show surf ace damage, even though it was recognized the quality of the f
film would not be good and it was recognized that the film would l
not meet any code standards.
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y1 g-1911 Rev.1 was voided and superseded by NR E-1911 Rev. 2 on July 31, 1979. The disposition shown on the latter was to perform RT examinations of all " butt-welds" and to perform visual-examinations of all " fillet-welds."
' A QA Surveillance Report dated August 8,1979 showed that,all five spool pieces were visually examined and were found acceptable.
A a
0' copy of this Surveillance Report is attached to this report as M,
Exhibit H.
Since two spool pieces had shown no indication of damage through radiographic examination and visual====4 nation another NR, No. E-1997, dated August 9,1979, was prepared as a mechanism to remove 'those
- two spool pieces from a hold condition but to retain an open NA on the other three.' NR E-1911 Rev. 2 was closed by KEI QA on August
. 9.1979, with the notation " Exceptions on ---) See NR E-1997."
A copy of the NR E-1911 Rev. 2 is attached as Exhibit I.
NR I-1997 showed that the spool pieces IMIO9BA12-1AH and IMS08BA12-5BH were acceptable.. On August 13, 1979 the RZI Construction Engineer placed a notation on NR E-1997 "CG&E to dispcsition." The KEI Construction Engineer stated that this was appropriate since CG&E has responsibility for off-site vetdor supplied items. On August 19, 1979 the CG&E Construction Engineer added the disposition " Accept-As-Is" and described the reasons for this disposition. A copy of NR E-1997 is attached to this report as Exhibit J.
Quality Assurance Instruction, QACHI No. G-4, Nonconforming Material e
Control, requires that NRs di4 positioned " Accept-As-Is be signed d
NR E-1977 by the Material Review Board before they are closed out.
was closed out on Cetober 17, 1979 with a comment added by the Sargent
& Lundy (S&L) board member to the eff ect that " Welds rejected by radiograph are covered by NCR E-2020."
A copy of the closed NR '-1997 is attached to this report as Exhibit K.
NR E-2020 showed the same information as NR E-1997, but at the time l
of the investigation, E-2020 had not been closed out. A copy of NR E-2020 is attached to this report as Exhibit L.
A review of records at the varahouse showed tha2*the three spool
. pieces, which were the subject of the open NR had been released to construction for installation as follows:
Issue Date 1
Item Ins 11512-788 9/18/79 l
Ins 101A12-ICH 9/24/79 IxsoanB12-6B 9/28/79 l
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On April 8,1980, it was established that these spool pieces had been installed and no " Hold" tag or " Deficiency" tag had been placed on them. This is in noncompliance 10 CFR 50, Appendix B,
, 7; Criterion KV, and KEI Quality Assurance Procedure No.15, It was ascertained that the spool pieces had been released from the c
warehouse on the basis of' a later version of NR E-1911 Rav. 2 on el which the above-mentioned nota' tion. ref erencing NR E-1997 had been lined through on September 14, 1979. A copy of this version of NR E,1911 Rev. 2 is attached to this report as Exhibit M.
It was determined that the QA Decument Control Supervisor had lined.
out the notation. He indicated that he had heard that NR E-1997 was being voided so he felt there was no point in it being cross-referenced any longer on NR E-1911-Rev. 2.
The supplier QA man in the warehouse indicated to him that some pressure was being felt from construction to get the spool pieces released. The Document Control Supervisor informed the warehouse that NR E-1911 Rev. 2 had been closed out and it was all right to release the spool pieces.
He said this was done~on the assumption that what was considered to 4
be a paper problem would be cleared up.
The Document Control Supervisor as well as other site personnel indicated the accept-ability of the spool pieces was regarded as a paper problem rather than a real problem. It was indicated that the probability of actual damage to pipes of that size and wall thickness due to i
mishandling uten delivery was extremely remote.
The supplier QA man advised that the spool pieces were released from the warehouse on the basis of the version of NR E-1911 Rev. 2 which had the reference to NR E-1977 lined through (Exhibit M).
He indicated that the Document Control Supervisor was~ instructed to line through the notation by a CC&E official. The latter indivi-dual, however, denied any recollection of having given that instruc-tion. The improper close out of NR E-1911 Rev. 2, which resulted in the release of spool pieces for installation before their accept-i ability had been established is in noncompliance with 10 CFR 50, Appendix B, Criterion XV, and KEI Quality Assurance Procedure No.
16.
ng On April 73, 1980 Deficiency Tags were placed on the spool pieces and during the period April 25-28, 1980 Feabody personnel performed magnetic particle and ultrasonic inspections of the welds in question.~
The reports of these inspections were reviewed and the Peabody in-spectors cerforming these examinations were interviewed on May 1, 1980. The issbedy personnel stated that they had concluded on the basis of these examinations that the spool pieces were acceptable.
It was also ascertained that on April 28, 1980, Pullman personnel visited the Zimmer site and also performed ultrasonic inspections of the welds. On the basis of these azaminations, Fullman provided a statement to CC&E that these welds were acceptable. Feabody personnel advised that they had observed the examinations performed by Fullaan and they agreed with the results.
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Additional A11eascions During telephone contacts with the NRC on May 5 and 7, 1980, the J
-alleger stated that he had evidence of criminal actions, relating to the spool-pieces which were the subject of Allegation No. 3 above.
He stated that he had evidence that between the two visf}s to the Zimmer site by the NRC investigations team on April 7-9 end April This he
[2 30-May 1-2, the velds had been cut out and/or repaired.
alleged, was the reason that the velds were judged to be acceptable during the second visit. He also stated he had evidence that pressure was exerted upon Peabody personnel to withhold information from the NRC in connection with the investigation.
On May 8,1980, the alleger was interviewed jointly by NRC and FBI personnel. Durf ug this interview the alleger provided for review a 4
tape recording of three telephone conversations he had had with Peabody personnel. Af ter listening to the three conversations, the FBI representative indicated that they did not appear to him to be evidence of criminality. The tape was furnished to the NRC for further review and follow up.
The first conversation, according to the alleger, took place on May 5,1980 with a supervisor in the Peabody, Cincinnati office. At one point during this conversation the supervisor said: "They cut some of those welds out."
The alleger responded: "You mean since the NRC had begun their investigation?" The supervisor then said:
"Oh, yes, they did that the next Monday." Later in the conversa-tion, the supervisor said:
"I do kac
- they started repairing some welds."
On May 20, 1980, the supervisor who had made the above statements, was interviewed by telephone. He stated that he had no first-hand knowledge of activities at the Zimmer site and that his' comments to the alleger were based upon his conversations with another Peabody employee. This second individual visits the Zimmer site and may have acquired the information himself, or through conversations He with another Peabody individual who does work at the site.
stated he did not know whether the information he received con-carning the repairs of welds related to the three spool pieces or to some other pipes.
f The second Peabody maployee was also interviewed by telephone on May 20, 1980. He advised that the welds that were repaired were He some which had been identified as bad during the NES audit.
said to his knowledge no repairs had been made on any 12" pipe l
He added that he had reviewed the results of the ultrasonic l
araminations performed on the 12" pipes and he had concluded the l
welds are acceptable.
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The third Peabody individual, who is employed at the Zimmer site, was also interviewed by telephone on May 20.
This individual stated that the paint had been removed from the welds on the 12"
'He'said this was pipes so that the tests could be made of them.
done with wire wheels and there were no repairs or even grinding done on the velds.
4
- I The second taped conversation took place on May 5,1980 fetween the alleger and a radiographer'empicyed by Feabody. This radiographer h2 had been identified by the alleger as being one of the individuals who had been involved in performing the radiography on the spool pieces in July 1979. -During thg conversation the alleger asked the radiographer whether the pipes were bad. The radiographer responded "I can' t really say."
The alleger then stated he had been informed the welds were cut out and repaired. The radiographer responded:
"I don't know." The allager again raised the question as to whether the velds were defective and the radiographer responded:
"I didn't l
read the film. I was a Level I and not qualified to interpret the film." The radiographer then identified the Peabody employee who had read the film. The latter individual had been interviewed on May 2,1980. He had stated that all five epool pieces that had been dropped from the truck had been examine'd and no indications of defects had been found except the three which were documented by an NR.
The third taped conversation took place on May 6,1980 between the alleger and the president of Faabody. The primary topic of conver-sation was the action taken by CG&E in early April 1980 in trans-ferring the radiography work from Peabody to another contracter, The President stated that he did not dispute the action taken NES.
because it would have a detrimental effect on his fira"s position in the industry, and adversely af fect their efforts to obtain future contracts.
s on May 20, 1980, the President of Peabody was interviewed con-carning this conversation. He stated that the action taken by CG&E, and his posture regarding it, had nothing to do with the He said that, to his know-quality of work at the Zimmer site.
i l
ledge, no Peabody employees had been pressured to accept or approve He stated that Peabody's contract provides for defective welds.
their performing the radiography and that the a2Eeptance er re-jection of a weld rested with KEI. Peabody had no responsibility in this regard and, therefore, an allegation that they were forced or All film and original pressured to approve bad work was meaningless.
records relating to radiography amaninations were turned over to He indicated that it KEI according to the terms of the contract.
was his understanding the NRC required that these materials be retained at the site and available for inspection.
5.
Mananement Discussion on May 2,1980, the results of the investigation were discussed with CG&E and KEI personnel identified by an asterisk (*) in the g
Persons Contacted section of this report.
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Exhibits A through M' Attachments:
List of Exhibits A - Ler ded'3/11/80 NRC to A11eger 3
-R - Bill of Lading
.Q 1 C - Fackins List T D - QA Documentation Package M E - NR E-1911 F - NR E-1911 Rev. 1
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G - Surveillance Report dtd 7/23/79 R - Surveillance Report dtd 8/8/79 I - NR E-1911 Rev. 2 J - NR E-1997 K - NR E-1997 (closed)
L - NR E-2020 M
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f Daar This refers to the meeting between yes, Mr. L. Winfanson of the IRC Eaadquarters Office, and ma en hrch 3,1980.
On the basis of the informatima you yzwvided we ytan to conduct an investi5ation at the 9m. E. Eisenar Boclear Power 71 ant regarding the fallerias ausged martars Defective walds in safety-ralated s.vstens base been asempted.
1.
. among them vart walds Cf 606. ER 42 and X Sil.,
2.
Five defective welds were identified is pre-fabricated pipiar but the pipe was acompted and instanad fa a safety-related systas.
3.
The manner in which safety-related f as.anad piping was flashad was taadagnate and a achmenled ? 9 flush was redocad to 2 wes* s.
a You vin be infoband of ear findiass Ionowfug som;:lat.;ma of ear investigatian.
Sincerely,
.=
C. A. Phillip
" m tigatiso specialist
.1 Exhibit A Fage 1 of 1
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VISUAL lh5PCCT!QN FINAL IN5pCCT*CN CHECKLIST e
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piCCC NO. IM Sot Balk LQ DI7 COWWENTS F. SHEET NO.
CHECK PDINTS YC5.NO N.A.
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gj Palos s' Pen &TioWS MAVE sttu e
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L fearemutoAmoAPPeevtsAnoSISmte eFr em TMC TaAVELta.
sPECirles mattetALS MAvt otta imSTALLED in TMC PIPim6 $US. ASSEMBLY.
j SISPLavt3 Sm TME PIPint ALL.STAwPiw8 Sue *SStu9Lf IS ACCURaft AmD CeantS.
P94Bd WITH TMC INFOAWAften PREltmTtt om TMt FAtelCatlow SMttT.
final elutullemAL Esaulmafgem NAS w.
Site PERFSAMED Amt TMt 91MEm$lemAL INFORWATISM MAS GEta RECORDES em TMC FacRICATipe Suttf.
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CLEANimS MAS Stta PERF0 AWE 9 la ACCeas.
AmCE WITH TMt steulaturmf 8 er TME SOVE#mine SPECIFICAflem.
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WELDER SYWSOLS AMO #49108AAPMIC g
Pelmf LOC ATiem8 M AVE Sttu ACCUR ATELY APPLitS AND AEL COMPLETE.
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CouTOUR.Flellm.AMD MilSMT OF WELO CROWN COMPLit5 WITM TMt RC4UIRtutmTS of TME Settemim6*SPECIFICATies.
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'Pipine Sue.ASStueLY IS Fatt Faev SAwast, we taCESSlyt PITTimS, Ant Um ACCEPTAGLE SUeFACE DEFECTS.
ASSEW9LY MAS SEEm imSPECTED Amt APPASVl0 SY fpt AUTMeAlIES InSPGCTee 	/08.TMC CUSTeut#8 SU,RVtlLLAmCE REPAESinTATIVE.
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NONCONTORMANCE REPORT
- ', w:.' il rat!".t r. f ortER ST ATIOrd N O. E-1911 Rev 2 PACE OF
,,c,rMT At I t.550N t;0.
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- 10. 0 TSP 05fTl0N tl. DISPOSITION INST RUCTIONS / JUSTIFICATION
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DATE_
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E- / f f 7 INSPECTOR /ENGIN EER j0Ai
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- 16. CORRECTIVE ACTION Pipe spools were dropped from terriers truck bed to grpund.
No sorrective action required.
This occurred after regular working hours and as the result of a mis-Interpretation of instructions given to truck drivers Eshibit 1 - pese 1 of 1
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'NO..E 1997 PAGE I
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- 10. DISPOSITIOfJ
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3.P0/CONTilACT N0.
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7.DATE:
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- 10. 0iSPOSITl0N
- 11. 0ISPOSifl0N INST,R UCTIONS/ JUSTIFICATION p
RholHRDENT: Material unloaded with e o d s-w* n.s m.c.-r.
u
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ft.%.h.e E. n.9.
t Fmtit: Spools were rolled off cruck Acc ed.a s. *1 l1)JJ.
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on to ground and striking other roools d
r en.kled E b'
f n#m as per E-1911 Rev.2 u j a n i b,) b is o..,
y es,%
Disposition 2 all fillet welds M. N
'f o o [ U U rr %
'b[
vicually inspected accepted as per m) sy g 6,,,, k Q,, Q SR 2251 6/
yn4e6 sk n Q,s; w
Disposition 1 completed all Qru3 E b.st1
, b, re,#,
butt radiocrashed (1M5 0853 12-63 had eh' tim)r blfs ke.'
,o rajsttable surface indication-open)
Q,(j g_[ J,[,%p Le_.J.,_
s (Ins 11312 73H had rejectable lack of "I' w, h e.,/
NEf Q.,,,,,,j l
fusion-open) (LMS 101A12 2CN had reject..
T I
i
, ablo lack of fusion-open)(1HS092A-12
.1AN-Acceptable Butt & Filets-Closed) fi
% M, I
(1MS083A-12 SSH-Acceptable Butt & F11*e :-
l F
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- 12. AtVitW 00ARO IREQUIREO ON ALL ACCEPT /RIPAIR Ol8P08til0N8FF " "
,,g, g,,j,g
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Eli C0ff57RUCT10N ENGRIDATE
.s 1
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Exhibit i1 U.S. NUCLEAR REGULATOP.Y C010d.ISSION 0FFICE OF INSPECTION AND ENFORCEMENT REGION III f
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! Report No. 50-358/80-09
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Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Cas and Electric Company 139 East 4th Street
, Cincinnati, OH 45201 Facility:
Wm. H. Zimmer Nuclear Power Station Investigation At: Moscow, OH Chicago, IL Dates of Investigation: April 7-9 and 30, May 1-2 and 20, 1980 Investigators:
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' G7 A. Phillip
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28N M T. E."'Vandel
'Date Reviewed By: - -
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7 4"W E.'Norelius
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Date Assistant to *the Director
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R. C. Knop, Chief j0at4 Construction Projects Section 1-.
7, Investination Summary:
Investication.on April 7-9 and 30, May 1-2 and
- 20. 1980 (Report No. 50-358/80-09)._,
Areas Investimated: Becausg of allegations made primarily ' relating to the adequacy of piping welds.. performed a review of records and procedures, - --
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made indeoendent evaluations and conducted interviews.cf personnel.
The investimation involved 94 investigation hours by three investinators.
Results: Of four $11esations one, which related to the installation of ore-f abricated nioint havina def ective velds, was nartially substantiated in that the sions vera installed before cuestions resardina c'nair accent-ability were resolved. One item of noncomoliance an infracfion. was' 3
10 CTR 50. Accendix 3. Criterion XV. releas{ of material identified:
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from searesation and failure to use hold taas.
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REASON FOR INVESTICATION On February 28, 1980, an individual who contacted the NRC,by telephone made allegations regarding the Wm. H. Zimmer Nuclear Power Stgtion. One of these allegations weg that piping having def ective welds,Ra'd been installed in a safety-related system.
SUMMARY
OF FACTS Following tha receipt of allegations by telephone on February 28, 1980, arrangements were made to inte-view the alleger to obtain more detailed information. During an interview on March 3,1980, the individual made several allegations, three of which involved matters under the juris-diction of the NRC. By letter dated March 11, 1980, the allager was advised that an investigation would be conducted regarding those allega-tions which were as follows:
1.
Defective welds in safety-related systema have been accepted, among, them were welds CY506, HR42 and K811.
2.
Five defective welds were identified in prefabriacted piping but the pipes were accepted and installed in a safety-related system.
3.
The manner in which safety-related installed piping was flushed was inadequate and a ac.heduled six-week flush was reduced to two weeks.
Allegation No. 1 was not substantiated.
Allegation No. 2 was partially substantiated in that three of five identi-fied pipes had been installed in the main steam relief system before ques-tions as to their acceptability had been resolved. Two items of noncompliance were identified in this. regard.. I.c was also determined that at the time of the investigation a nonconforming report requiring disposition remained open concerning the acceptability of the th'ree pipes,. During tha_ investigation __. _.
additional examinations weta made.of_the. pipes _and.they verardatermined to be accep table.
2.
4 tf.vas decepnined_ thro [g(contact.-with.the--.- _._.: _-
Regarding A11egation_No. 5 1
primary source of -the information upon which the allegation _was.; based.
thae he had lef t the site in November 1978 and probteme-in-this area had been identified and resolved through.NRC inspections conducted between Nev mber 1978 and.the receipt of the allegations in March 1980. --
i Following ecapletion of the investigstion at the Zimmer site, the i
allager contacted Region III and alleged he had evidence of a criminal i
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nd that the velds on the three above-mentioned pipes had been f
conspiracand repaired during the course of the investigation and this information was withheld from the NRC. The basis for these allegations,
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cut ou which consisted of recordings of three telephone conversations, was ob-p g._,
8 No in-tained from the.elleger during an interview on May 8, 1980.
formation.or evidence was obtained to confirm these allegati#ns during 3
the interview or during subsequent investigation.
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One item of noncompliance, an infraction, was identified during this
-3 investigation.
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DETAI2.S e-t 1.
Persons Contacted r
'4 Cincinnati Cas and Electric Comsany (CG&E) 2
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- B. K. Culver, Project Manager
- W. W. Schwiers, QA Manager
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- R. L. Wood, QA E.?gineer
- D. C. Kramer, QA and S Engihter S. Swain, Construction Manager
- J. F. Weissenberg, QA and S Engineer Kaiser Ensineers. Inc. (KEI)
- R. Marshall, Project Superintendent
- E. V. Knox, QA Manager K. R. Raumgarten, QA Hanager R. M. Dorr, Construction Engineer A. Pallon, Welding /NDE QA Engineer F. Oltz, Analysis and Procedures Supervisor, QA J. Deervester, Supplier QA D. Haag, QA Inspector Peabody ' Testing Services (Peabody)
Ernest A1 dredge, President Charles Wood, Manager, Cincinnati Office (via telephone)
Wayne Draffen, Supervisor (via telephone) i Alan Sellars, Field Supervisor i
D. Burdsal, Level II Inspector Nuclear Enerry Services. Inc. (NES)
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- 1. Bott, NDE 1upervisor R. A. Zimber;-NDE Inspector --
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Introduction..__.
on February 28, 1980, the Office of Inspection and Enforcement NRCh.
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Headquarters advised Region-III:of-a telephone conversation.with an..
individual who made allegations concerning. activities _st..the l
Es. H. Zinumer Nuclear Power Plant Construction site. and. requested.--....._
l that the individual be contacted. Later the sane day during a tele-phone conversation with* Region III, and during an interview on
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March 3, 1980, the individual made several allegations. 7.~t,
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The individual stated that he had been employed by a private dotsetivo agency, and the licensee, CG&E, through his employer, had engaged him to work under cover at the Zimmer site to investigate time card
. padding by site personnel. His investigation ef fort began on December 10, 1979 and ended on January.4, 1980.
In addition to irrformation regarding worker time card padding, he obtained informa'tton regarding
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d other activities which was the basis for several allegat2ons, some of which related to matters under the jurisdiction of the.EltC.
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The individual stated he had earlier brought his information to theH D,
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be taken by that agency.
The individual stated he had documentation relating to his allegations in the form of weekly reports he had prepared and tapes of several of his conversations with site personnel. During the interview on March 3, 1980, the individual played those parts of the tapes which he said contained pertinent information and made available copies of
.his reports.
3.
Allegations Based on the information obtained through the interview with the alleger, a review of the taped conversations and his investinative reports, three allegations involving activities under NRC jurisdiction were developedL By letter dated March 11, 1980, the alleger was advised that an investi-sation of these allegations would be' conducted.
A copy of this letter i
with the alleger's identification deleted is attached to this report These allegations and infer =ation regarding them obtained as Exhibit A.
during the investigation are set forth below.
/a Allegation 1: / afmerive velds _in safety-related systems have been
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, ace g, among them were velds CY606 HR42 and KSIA.
The identification of the specific welds.in this allegation was ob-tained from a review of the -tape. the alleger had made surreptitiously -. -
of his conversations with site' personnel.. According to_the_informay _.__.
tion obtained by; the_ alleger, veld CY606 was -buried in concrete..__.
H e ~ _.-.=__c between the Radvaste Building..apd the. Containment Building.
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said it was his _ understanding tha.tc.ch.ey dug 13 up,cogepair.4c.bu.c a he was uncertain whether-this-vas done.
Regarding veld HR42 - the alleger 'said that be.had informed CG&E. chat -
f g this veld was defective.. He said-he had heard that-another -testin pfirm had been hired as a consultant,. and this firm had. confirmed.
_ m yk.:4W He also said it was his understanding that M".3, the veld was defective.
this defect was reported to the NRC.
Regarding veld K811, the" allegar said he was informed that.this, veld had "an insert f ault" and that XIl_had ordered that -it-be accep ted.... ___.
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The alleger stated that Peabody Testing Services (Peabody), also referred to as {tagnaflux, personnel had informed him that some velds.that' Peabody, the nondestructive testing contractor, had rejected as faulty were subsequently accepted by KEI, the site
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construction management contractor.
He said that a Peabody em-ployee had records identifying the welds rejected by Pea 6edy which
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d were subsequently accepted by KEI. He indicated that by ' fin of the eay of explanation,.CG&E had informed him that the interpretati 2
film obtained through radiographic examinations of, veld's is a judgment call. The appearance of an item on a radiographic film may be judged to be a defect'6y one individual and not by another and KEI could overrule Peabody.
Finding:
y C&hM on April 7,1980, the Peabody field superv sor was interviewed. He stated that he had no records showing the welds Peabody had initially r
rejected which were subsequently declared acceptable by KEI. He indicated that, although he was aware that this had occurred, he did not know how of ten and he could not provide any specific instances.
He also stated that the results of radiographic examinations are recorded on reader sheets. The radiographic film and tae original reader sheets are turned over to KII. He said Peabody only had-carbon copies of the reader sheets.
N As a means of further evaluating whether KEI was accepting welds
.g identified as defective by Peabody, a safety-related system, the g /,
\\ High Pressure Core Spray System, w%ted and all reader sheets.'
pertaining to it were reviewed.,AI 9 elds in the systa= which' were radiographed, two instances e
,ote in which Peabody had
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checked the reject colu=n and KZ had h d that check out and I
\\ $ had checked the'accepc c'olumn.
iographs of these two welIs J
were reviewed by an NRC:ibspector who is a certified NDE Level III.
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He concurred that the welds were acceptable..Conv'ersely, it was noted that in several instances,4etween five and. ten, the' original-accept check mark entered by Peabody.;had.been-lined through and a l -
rej ect. check had been entered by KEI.- = =--- - --
g Regarding the subject o.f welds and radiographstof-them,-an ERC :
.ed
-f inspection conducted.on. November _8-9._.ansLD_e_ce6ber 12-13 31978 - --
- =w (Report No.'50-358/78-30) identified several-discrepTn~cies-in -
radiographic. techniques and reports.. During.a subsequent inspection on September 18-20, and December 11-12, 1979.- (Repor t -Noi. 50-358/79-17) several more discrepancies were identified. ' CG&E then hired NES to --
rereview radiographs and reports of all welds which had been accepted for turnover prior to operation. This aview began in October 197-95 and was completed in early April 1980. The review included 2,390 -
i radiographed. welds.. 0f those, 958. had report discrepanciesi-5'43 ;
had some technique-proble,ms-and -14 welds were found to be unaccept-I able because of defects.
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2 The KEI Project Superintendent advised on May 1,1980, the 14 velds were being re. xamined and resolution regarding them had not been Sg e
completed.
He stated that one of the 14 velds found to be unacces_t-Qle was the subject of a nonconformance report and, therefore, had not been accepted for turnover.
This veld, he said, should not have been included in the NES review. Another veld had been cut
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,d out of the pipe for examination and it was determined that, although 4
it appeared to have a defect on the radiographic fi1=,J t was, in 5
fact, an acceptable veld.
[ Regarding veld No. K811, a review of records showed it was velded on November 9,1977, but because an Authorized Nuclear Inspector hold point was missed at the ficup, the veld was cut out and replaced by veld No. K916. The missed hold point was documented by Noncon-formance Reporr (NR) No. E-2138RI. This NR indicates that the disposition was to cut out and replace the veld.
It was deter =ined-that veld No. K916 had not yet received final acceptance.
Regarding veld No. RH42, records indicated this veld was first radiographed on August 9,1976, and found to hava unacceptable porosity and slag in the areas of 36-48.
The areas were repaired and a raradiograph performed on August 10, 1976 fcund it to be
. acceptable. A review was made of the radiographs for veld c,uality, techniques, and report accuracy by an NES Level II radiographer on January 25, 1980 as part of the above-mentioned re-reviav initiated after the 1978-79 NRC inspections. Ihe NES Level II radiographer found some discrepancies which have not been resolved, and the veld j
has not been given final acceptance.
./Regarding veld No. CY606, a review of records showed tiiis veld was first radiographed on July 15, 1976 and found to have incomplete fusion and penetration in the areas of 0-13 and 13-16. The areas were repaired and the veld re-radiographed on June 8,1977 and found to be acceptable. A review was made of the radiographs for veld quality,. techniques and. report accuracy by an NES Level III...
l radiographer on October 12,1979.as a result of the NRC inspection conducted in 1978.-:.Ihe Level III found some discrepancies which have.not been resolved-and the veld has not received final accept-ance.
Allegation 2r-. The manner. in which safetty-related. installed.pioing.
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- vas flushed Was inadequate and a scheduled six-veek flush.was _
reduced to two weeks.
The alleger provided infor=ation that a site employee informed him _
on December 27, 1979, that anot individual who had been a= ployed as a general foreman at the sit ad obineted to the fluthing pro-5 cedures used,---He had also acted when a.particular flush _that_..
s as cut to er.ra u==1,=
- On one-occasion-should have taken x wee t
l the individual h astrated-the-flushing was inadequate-bv voimmena mediment and slat during th e pounding on a pipe which gu,gh,.
The identity of the former general foreman was provided by,
the alleger.
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Tinding: On April 7, 1980, the former general foreman was contacted and intervieve4 This individual said he had worked at the Zi==er i-site from June 1973 until November 19781 In 1978 he was the general
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foreman of the flush group.
4' Regarding the six-veek versus two-week flush, the indiv[ dual indicat'ed
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i it h'ad been anticipated six weeks would be needed to pt$ pare for and 7
flush one of.the systems.
He, however, was'able to ace 6cplish a 3
satisfactory flush in two weeks. He indicated that the shorter time did not mean the flush,vas not done according to the require-ments.
Rather, it was a case of he and his men being able to accom-plish a job in less time than expected.
This individual stated that in his opinion the velding done on the k
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I critical systems, such,as the main steam lines and in the reactor j building, was good. He said, however. that several problems were f
V encountered in the flushing activities while he was at the site but He was unnhia en evide information regarding any specific require-ments that were not met.
~
NRC inspections conducted subsequent to the departure of this indivi-dual from the site included an examination of flushing activities and some snacific problems were identified. On the basis of one of these inspections, conducted January 3-6 and 8, 1979 (Report No.
50-358/,79-01), one item of noncompliance and one deviation were identified. The noncompliance related to a failure to close a valve during a flush and an inadequate procedure to assure boundary valves are closed. The deviation was that the procedure did not require tagging, of boundary valves. A second inspection conducted February
- 27-28, March 1-2, 19-23, and April 9-11, 1979 (Report No. 50-358/79-06) resulted in one item of noncompliance regarding flushing activities.
This related to a failure to maintain control of flushing waters re- /
sulting in the flooding of equipment in a system which had been turned 8g over for prosperational testing.
The individual-indicated _a matter _of_ concern to him was that a hydrocest of.the reactor containment.was_successfully3 erformed, but af ter the test--some -instrument lines wereL. cut out.which.-invalda.ted _.
the hydrocestk. He. indicated he was-uncertaings.co.whethez.CG&I.xo.uls!- A===
attempt to use this test.as meeting test requirements or whether the -- -
NRC was aware the test-had been invalidated by the subsequengmodif_i cations.
On April 8,1980, the NRC Resident Inspector advised that he as well as CG&E vere aware that the initial hydrotest was not valid because----
c of the subsequent modification of the instrument lines.
He stated that -
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another hydrocest was tentatively scheduled to be performed during - -
the summer of 1980..
In view of the above, further. investigation at the site (in the area - _.._
of flushing activities was not pursued.
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A11esarion 3: Tive defective velds were identified in prefabricated
. piping, but the pipe was accepted and installed in a saf ety-related system.
Through a review of reports written by the alleger and the tapes of conversations with site personnel as well as.informationf supplied d
thro (igh interview on March 3, 1980; the following infortiktion was..
~~
3i obtained regarding this allegation.
E*
3 I,
' During the NRC hearings in November 1979, a question was raised concerning an accident which involved the dropping of fuel rods.
A former site employee had provided information to attorneys who were opposed to the licensing of the plant which was the basis for raising this question. A miscom=unication between the former em-playes and the attorneys occurred, however. The question about an accident should have referred to piping being dropped from a tractor trailer rather than fuel being dropped.
The alleger advised that in about October 1979, a trailer load of pipes fabricated at the Kellogg Company, located in Pennsylvania, arrived at the site in the middle of thm night. Since personnel and proper equipment were not available to unload it properly a 1
member of CG&E management issued instructions to push the pipe from the truck onto the ground.
~~
When th's pipes were found on the ground the following day, it was decided that the pipes would have to be inspected by x-ray to deter =ine whether they had been damaged. Peabody was instructed to x-ray (radiograph) the pipes and 5 to 8 faulty velds were identified Since Paabody had been instructed to check the pipes but not the
[
velds, and since the velds had been tested and found to be acceptable i
before shipment by Kellogg, the pipes were approved by KEI Quality Assurance. These pipes were installed in the Main Steam Relief System, a safety-related system..
Finding: A bi-11-of. lading dated June 29, 1979 showed that Pullman Power ProducesJa.111 vision of:Pu11matir-Inc.n,1111amspore, Pennsylvania, W
c formerly known :as; M. W:.Kellogg1Coctpany, + released._t_o. the.&aily,Exprass.m -
Company five p.te.ces. of pipe; assembly.1/Si veighing.4,700_ pounds...for _----
delivery to the CG&E Zimmer site on Monday-.-July 2,1979.---A packiWg' slip accompanying the shipment listed the following. pies.as:
IM508BB12 --
1 IMSO9BA12-1AH. --~
- IMSO8BA12-5BH ' -
L IMS11312-7BN 5
IMS10BA12-ICH r
l-y A KEI receiving stamp-shows.it was received on. July 3,.197.9, _ Copies,.
of the bill of lading and the-packing slip -vere obtained and2are fr -
-,-n setached to the report as Exhibits B and C, respectively.
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E Each of these pipes. (spool pieces) were for the Main Steam Saf ety Relief Valve discharge and were carbon steel pipe assemblies ap-proximately 15' 7 5/8 long,12 3/4" in diameter and having a wall thickness of 687".
f On hand at the Zimmer> site were-QA documentation packag@dh fo
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of these 5 spool pieces received from Pullman. A copy: 7 one package was obtained and is attached to this report as* Exhibit D.
5s, on July 5,1979, Nonconformknee Report (NR) No. E-1911 was prepared indicating " Spools were rolled off of truck onto ground and striking other spools" and listing the above identification numbers.
The issuance of this NR had the effect of placing these pipe spools in a hold status in the.KEI varehouse. On July 10, 1979, the KEI Construction Engineer entered the following disposition on this NR
" Rework.
(1) Perform liquid penetrant test on all velds; (2) perform visual inspection of weld and preps. Accept on basis of inspection (1) and (2).
Should any pipe spool fail due to inspections (1) and (2) a separate Nonconfor ance vill be issued." A KII QA engineer concurred in this disposition on the same date.
A copy of NR E-1911 is attached to this report as Exhibit E.
N1 E-1911 was voided and superseded by NK E-1911 Rev.1 on the same date, July 10, 1979. KEI and CG&E personnel advised that the dis-positiop shown on NR E-1911 was reconsidered because they wished to avoid removing the paint from the welds which would be necessary before a liquid penetrant examination could be performed. NR E-1911 Rev.1 changed the first item of the disposition to:
" Perform RT examination of all welds." A copy of NR E-1911 Rev.1 is attached to this report as Exhibit T.
A QA Surveillance Report dated July 23, 1979, addressed to a CG&E QA engineer signed by the. KEI NDE QA engineer, showed that on three spool pieces,. weld X4 had rejectable indications, and requested j
to be advised concerning-the.dispositioning of.th'ese rejections.
l The CG&E QA engineer stated that-to rha best of his recollection, he did nothing in response to this request and.could-not recall having discussed __the.- maeter vith. anyone.. A copy of this Surveillapee n.. -
Report is attached to this report.as Exhibit'5.
CG&E and KEI personnel. stated all-five spool pieces were radiographed rari-on an "informa.tio.n.only" basis but. only the films for_those three l
Ref erred to in the Surveillance Report were retained. --The.X4 weld is _ --..
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a weld which joins a solid cap to one end of the spool piece.. Radio-graphy is not the appropriate technique employed to examine a weld of this kind since the gamma rays must pass through the cap (about-..
12' of metal)- as well-as the weld.. The.KEI. Construction Engineer.
said the radiographs were.done.vith the thought;that they.might show surface damage - even though it was recognized the qualipy..of_ the --
film would not be good and it was recognized that the film would not meet any code standards.
i.
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-. ~ - - - -_
NR E-1911 Rev. I wn5 voidad end suparsedsd by NR E-1911 Rcv. 2 on July 31, 1979.
The disposition shown on the latter was to perform RT examinations of all " butt-veld,s" and to perform visual examinations of all " fillet-velds."
AQASurveillanceReportdatedAugust.8.1979showedchar$allfive i
spoolipieces.were v,isually examined-and were found accepidablev A 4
copy 6f this'.flurveillance Repor: is attached to 'this repT;p-t ass Exhibit H.
3 Since two spool pieces had shown no indication of damage through radiographic examination and visual examination another NR, No. E-1997, dated August 9,1979, was prepared as a mechanism to remove those
- .vo spool pieces from a hold condition but to retain an open NR on the other three. NR E-1911 Rev. 2 was closed by KII QA on Aug6st 9,1979, with the notation " Exceptions on
) See NR E-1997." A copy of the NR E-1911 Rev. 2 is attached as _Ex_hibit I.
' NR E-1997 showed that the spool pieces IMSO9BA12-1AH and IM508BA12-5BH were acceptable. On August 13, 1979 the KII Construction Engineer placed a notation on NR E-1997 "CG&E to disposition." The KEI Construction Engineer stated that this was appropriate since CC&E has responsibility for off-site vendor supplied items. On August 19, 1979 the CG&E Construction Engineer added the disposition " Accept-As-Is" and described the reasons for this disposition. A copy of NR E-1997 is attached to this report as Exhibit J.
Quality Assurance Instruction, QACMI No. G-4, Nonconferning Material-Control, requires that NRs dispositioned " Accept-As-Is" be signed by the Material Review Board before they are closed out.-
NR E-1977 was closed out on October 17, 1979 with a comment added by the Sargent
& Lundy (S&L) board member to the eff ect that " Welds rejected by radiograph are covered by NCR E-2020." A copy of the closed NR E-1997 is attached to this report as Exhibit K.
NR E-2020 showed the same information as NR E-1997', but at the time -
of the investigation, E-2020 had dot been closed out.
--A copy of NR E-2020 is. attached to this. report as Exhibit L.
~
A review of reenrds.ac..the;varehouse:showed thas. the thren. spook.
pieces, which_were,the subject of the open-NR:had-been released-to cons true tion.-for dna talla tion.-es-fellows t- --
Item Issue Date IM511812-73H 9/18/79 IM510BA12-ICH 9/24/79 I
IMS08BB12-6B 9/28/79
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On April 8,1980, it was established that these spool pieces had been installed.and no " Hold" tag or "Def,1ciency" tag had been placed on them.,This is in noncompliance 10 CFR 50, Appendix B, Criterion IV,, and KEI Quality Assurance Procedure No.13, J
ji It was ascert'ained that the spbel pieces h.a.d be;eh released from the _.
- vareliouse on :the basis af a later'. version' of NR E-1911,.Ev. 2^ on':-. ; -
3 which the above-mentioned notation referencing NR E-1997 had been lined through on September 14, 1979. A copy of this version of NR i
E-1911-Rev. 2 is attached t.o this report as Exhibit M.
e It was determined that the QA Document Control Supervisor had lined out the notation.- He indicated that he had heard that NR E-1997 was being voided so he felt there was no point in it being cross-referenced any longer on NR E-1911 Rev. 2.
The supplier QA man in the warehouse indicated to him that some pressure was being f elt
-from construction to get the spool pieces released.
The Document Control Supervisor informed the warehouse that NR E-1911 Rev. 2 had been closed out and it was all right to release the spool pieces.
He said this was done on the assumption that what was considered to be a paper problem would be cleared up.
The Document Control Supervisor as well as other site personnel indicated the accept-ability of the spool pieces was regarded as a paper problem rather than a real problem. It was indicated that the probability of actual damage to pipes of that size and wall thickness due to mishandling upon delivery was extremely remote.
The supplier QA man advised that the spool pieces were released from the warehouse on the basis of the version of NR E-1911 Rev. 2 which had ths reference to NR E-1977 lined through (Exhibit M).
He indicated that the Document Control Supervisor was instructed to line through the notation by a CG&E official.
The latter indivi-dual, however, denied any recollection of having given that instruc-tion. The improper close out of NR E-1911 Rev.
,2, which resulted in the release of spool pieces for installation before their accept-ability h'ad been established is.In_soncompliance_vith.10 CFR 50, __
Appendix 3, Criterion XV,. and KEI Quality Assurance Procedure No.
~ ~.
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On April 23 1980, Deficiency Tags vere placed on-the spool pieces and during the period Apr11 25-28..1980, Peabody Tersonnel 7erform.a 4
magnetic particle-and ultrasonic inspections-of--the velds in question.
=
The reports of these inspections verf" reviewed and the. Pea ~tody in spectors perfor=ing these examinations were interviewed on May 1, 1980. The Peabody personnel stated that they had concluded ;n the basis of these examinations that the spool pieces were acceptable.
It was also ascertained that. on April 28, 1980, Pullman personnel visited the Zimmer site and also performed _ ultrasonic inspections _, _
of the welds,. On-the basis-of.these examinations, Pu11 men.provided _ _ _
a statement to CC&E that these velds were acceptable.- P,eabody personnel advised that they had observed the examinations performed by Pullman and they agreed with the results.
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Additional A11esations J
4 During telephon contacts with the NRC on May 5 and 7, 1980, the alleger _ stated that he had evidence of criminal actions relating to the spool pieces which were the subj ect of Allegation No[. 3 above.
He ststed that-he had evidence that between the two visfts.co the.
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'd ZinsEr site by::rhe. NRC inv.estigations team.on April 7-9 hnd April?
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30-May 1-2, the velds had.been cut.out and/or repaired. ' This he l
alleged, was the reason that the velds were judged to be acceptable during the second visit. He,elso stated he had evidence that pressure was exerted upon Peabody personnel to withhold information from the NRC in connection with the investigation.
On May 8,1980, the allager was interviewed jointly by N1(C and* FBI personnel. During this interview the alleger provided for review a cape recording of three telephone conversations he had had with
, Peabody personnel. Af ter listening to the three conversations, the FBI representative indicated that they did not appear to him to be evidence of criminality. The tape was furnished to the NRC for further review and follow up.-
The first conversation, according to the alleger, took place on May i
5, 1980 with a supervisor in the Peabody, Cincinnati office. At one i
point during this conversation the supervisor said:
They cut some of those welds out."
The allegar responded: "You mean since the i
NRC had begun their investigation?" The supervisor then said:
"Oh, yes, they did that the next Monday." Later in the conversa-tion, the supervisor said:
"I do know they started repairing some welds."
4 On May 20, 1980, the supervisor who had made the above statements, was interviewed by telephone. He stated that he had no first-hand knowledge of activities at the Zimmer site and that his comments to the alleger were based upon his conversations.with another Peabody employee. This second individual visits-the.Ziimer site and may have acquired the.information himselfi or through conversations i
with another Peabody individual who does work at. the site He_..
i
~
carning the repairs-of welds related.co.the.thrp spool _piecss.or-stated he did not.know whether -the:-information:he_:receivtd con __
to some other. pipes. ~6-:4-.-..
The second Peabody employee was also interviewed by telephone on 2
May 20,1980.- --He advised that the welds that-vere repaired were--.
some which had been identified as bad during the NES audit. He said to his knowledge no repairs had been made on any 12" pipe welds. He added that he had reviewed the results of the-ultrasonic i
examinations performed on the.12" pipes and he had concluded the welds are acceptable.
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- s Thi third Pachody individuel, who is caployed at the Zin=2r site, was also interviewed by telephene on May 20.
This individual stated that the paint had been removed from the we'lds on the 12" pipes so that.the tests could be made of* them. He said this was
~
done with wire wheels and there were no repairs or even grinding r
done on-the velds.
4 7
db The second taped.conversatio'n took. place on May _5',1980:5etween the
{
allager and a radiographer employed by Peabody. This (Ediographer had been identified by the alleger as being one of the individuals who had been involved in performing the radiography on the spool.
pieces in July 1979. During the conversation the alleger asked the radiographer whether the pipes were bad. The radiographer responded:
"I can't really say."
The allager then stated he had been inforned the welds were cut out and repaired.
The radiographer responded:
"I don't know."
The alleger again raised the question as to whether the welds were defective and the radiographer responded:
"I didn't read the film. I was a Level I and not qualified to interpret-the film." The radiographer then identified the Peabody employee who had read the film. The latter individual had been interviewed on May 2,1980. He had stated that all five spool pieces that had been dropped from the truck had been examined and no indications of defects had been found except the three which were documented by an NR.
The third taped conversation took place on May 6,1980 between the allager'and the president of Peabody. The primary topic of conver-sation was the action taken by CG&E in early April 1980 in trans-ferring the radiography work from Peabody to another contractor, NES.
The President stated that he did not dispute the action taken because it would have a detrimental effect on his firm's position in the industry, and adversely affect their ef forts to obtain future contracts.
on May 20,,1980,.the President of Peabody was interviewed con--
4 l
carning this conversation...He. stated _thet..the. action taken by --- --
CG&E, and his pos ture regarding it.. had nothing. to do.with. the __....,
i quality of work.ac.the Zimmer site.-He said -that, to.his kncv -. -
ledge, no Peabody employees had-been pretsured-to acc.ept.or app. rove.
defective welds.. He stated. that. Peabody's cogtract,provides for their performing--the radiography-and thag.:the accep cance_.or. re - - a_ ; - _
2 jection of a weld rested with KEI P.eabcdy.had no.r.asponsibility._in i
this regard and, therefore..an allega. tion _that they_ vere-forced or pressured to approve had work"was meaningless. -All film and original records relating to radiography examinations were turned over to KEI according to the terms of the contract. He indicated that it i
vas his understanding the NRC required that these materials be retained at the site and.available for inspection.
t i
s i
5.
Manasement Discussion On May 2,1980, the results of the investigation were discussed with CG&E and KEI personnel identified by an asterisk (*) in the i-Persons Contacted section of this report.
15 -
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Attachsezts: Exhibits A thrcugh M List of Exhibits A - Ler dtd 3/11/80 NRC to Alleger B - Bill of Lading.
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.ii. C - i. eking List ra. t o;..i.- r Ja I
C D - QA Documentatiod Package
% E - NR E-1911 7 F - NR E-1911 Rev. 1
- G - Surveillance Report dtd 7/23/79 R - Surveillance Report dtd 8/8/79 I - NR E-1911 Rev. 2 J - NR E-1997 K - NR E-1997 (closed)
L - NR E-2020 M - NR E-1911 Rev. 2 (closed)
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l THE CINCINNATJ GAS & ELECTRIC COMPANY C
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,3 August 4,1980 QA-1325,
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U. S. Nuclear R,egulatory Comission Region III 799 Roosevelt Road Glen E". lyn Illinois 60137 Attention: Mr. James G. Keppler.
Director RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT I HRC" INSPECTION REPORT NO. 80 DOCKET NO.
50-358, CONSTRUCTION PERMIT CPPR-88, W.O.J
~
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- '57300-957, JOB E-3590 '
Gentlemen:
This letter constitutes our fonnal reply to the subject inspection report.
It is our opinion that nothing in the report or in this reply is proprietary ~
in nature.
Dur responses to the items of noncompliance
- cited in Appendix "A" of the report are as follows:
Item 1
' Release of Material 'with'Open R
(a) Corrective Action *Taken *and
- Rests 1ts Achieved All materials delivered to the Zimer Site pass through a receiving inspection process to determine if the item weets procurement requirements.
Nonconfonning items are documented, tagged and quarantined pending disposition of the nonconfonn-ing condition.
Henry J. Kaiser Conpany had not developed a procedure which allowed release from the warehouse in a controlled manner of material with nonconforir.ing conditions.
A random review of those nonconfonnance reports prepared and applicable to 3
receiving inspection, indicates that release of the five (5) spool pieces for installation was a unique and unusual circum-s l
stance which occurrwd as the result of a conrnunication break-down and subsequent s:isunderstanding as to the status of the outstanding nonconformance.
The review of these receiving non-i conformances indicates that present procedures have been adequate and that each open nonconformance serves as a supplenental reans of control of nonconfonnin,g material.
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hr. "Janis G., Keppler, Director U.S. Nuclear P.egulatory Comission Region III August 4,1980 - QA-1325 Page 2 (b) Corrective Action'Taken'to Avoid Further Noncompliance Henry '. Kaiser Procedure QAP-16. Control of Honconforming J
. Materiale", shall be revised to provide for release of i
setarial from a nonconfoming or hold status only with the e
approval of both the Cincinnati Gas & Electric Conpany and Henry J. Kaiser,Conpany Quality Assurance Managers or their des,ignated alternates.
(c) Date When Full Compliance Will Be Achieved The issue of a revision to QAP-16 will be coupleted by August 29.* 1980.
Item 2 - Open NR Material Installed Without Hold' Tag Placed on Items (a) Corrective Actioni and Results Achieved
' Henry J. Kaiser Procedure QACMI G-4 nquires that nonconfom-
'i
,ing components be identified with an appropriate hold tag.
When it became apparent that the five (5) spools, which were covered by an unresolved nonconfomance report, no longer had 1
i hold tags attached, new tags were prepared and attached to f
the components. This action assured compliance with the appn.priate requirements of QACMI G-4.
(b) ' Corrective ~ Action'to be 'Taken to Avoid Further Noncompliance
. Training sessions were conducted on April 9,1980 and June 16, 1980 for personnel responsible for preparing nonconfonnance Teports, anphasizing the necessity for attachment of hold tags
- to nonconfoming conponents.
In addition, a review of a random sanple of open nonconfomance reports will be conducted to assure
~~
-that hold tags are in place in accordance with procedures...
(c) Date When Full Coupliance Will Be Achieved We expect to be in' full conp11ance by August 29, 1980.
We trust that the above will constitute an acceptable response to the subject inspection report.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPhNY E. A. BORGMANN SENIOR VICE PRESIDENT e n e...'
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- Appendix A HOTICE OF VI0I.ATION r
Cinein1=ti Gas and Electric Docket No. 50-358 Company
)i
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Based on the results of the NRC Investigation conducted on April 7-9 and 30. Hay 1-2 and 20, 1980, it appears that cartain of your activities were not conducted in full compliance with NRC requirements as noted-below. This item is.an infraction.
10 CFR Part 50, Appendix 3 Criterion IV, states in part that " Measures shall be established to control materials, parts, or components which do i
not conform to requirements in order to prevent thair inadvertant use or l
installation."
- a.. The Henry J. Isiser Co. Zimmar Quality Assurance Hasual in Quality Assurance Procedure (QAP) No.16 requires in part 'that' "All non,
conforming items will be segregated, where possib*v, from accept-
. able items, clearly identified with the applicable Bold or Defi-
'ciency Tag and documented on the Nonconformance Report." ' I t * "--
additionmily requires that "Upon Yerification that all work on the item is complete and acceptable, the nonconformance report (NR) is signed off in Sect. ion 13 by the Inspector."
Contrary to the above, 5 piping spools identified by 'NRE-1911 Rev. 2 were released from segregation even though the Inspecter had signed off section 13 with a notation of specific exceptions to acceptability of the material by identifying another.NR*contrciling the material. This release was achieved through unauthorized removal of ths.noted exceptions on the NR.
e:
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The Henry J. Emitear Co. Zimmer Quality Assurance Manual in Quality Assurance Procedure (QAP) No.16 requires in part that ".
asterial is clearly identified as nonconforming,,and is segregated.
when possible. Due to size limitations physica"1 segregation may be impractical. In such instances tagging, marking, or other means of identification is acceptable." Additionally QAP 15 requires that "A ' Hold' tag is placed on the item...
It is used in con-junction with a 'Nonconformance Report'."
Contrary to the above, 3 piping spools identified in NR I-2020 as nonconforming and required to be cleared by additional tests, not only had been released from the warehouse, but in addition had been installed without any " hold" tag being placed on the material.
I oprics) suenausyY
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=ac rem nse v= gr a n. si ancu enso ev.s.cowamuusmr paintino onracs. isas.nes sar
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H December 15, 1980 I;
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James J. W ngs, ' Dire.ct, CIA i
MrJCRANDUM FOR:
John T. Ahearne FRCM "3.*P " 17.CNS TsoMAS W. AP 1
susJEc :
h the I request that oIA conduct an investigatica ints whet er office of Inspection and Enforcement c=nducted an adequata in i
tigation of the allegations presented ta Power station.
regarding activities at the william E. I1meer Nuclear 50-358/80/S (Jul i
The IEE findings are set forth in I&E Report No.
igatica 1380).
of the safety issues raised at pages 13 and 14 of l ading t of the Instituta for j
which the Government Ac=cuntability -Pro ecPolicies studie Protectica
)3 scard.
victor stello, Ir ces I
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8 AT AC4 MENT 1_mm EXHIBIT 1 OM M
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k T-mmi Office of the Special Counsel
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1717 H Street, N.W.
b 2 O NO Washington, D.C.20419 Honorable John Aheene Qiairman tk2 clear Regulatory Com:Lssion 1717 H Street, N.W.
Washington, D.C.
20419
Dear Mr. Ahearme:
he enclosed information is transmitted pursuant to the provisions of 5 U.S.C.1206(b)(2). As you are awe, that provision of law requires the Special Counsel to transmit to the appropriate agency head inforation received by the Office which the discloser rawn=kly believes evidences a violation of law, rule, or regulation, or mLansnagement, a gross unste of funds, an abuse of authority, or a substantial and spum danger to public health or safety.
It is alleged by the orfainal source of the information,
&. Romas W. Applegate, and Ms representative, the Gov-t Accountability Project, that the information concerning the conduct and results of an investigation by the thiclear Regulatory rmmhsion at the Zimmer Nuclear Power Facility at Itscow.Chio in May and June 1980 and other information concerning activities and incidents at the Facility construction site disclosed to this Office constitute all of the types of information required to be tracismitted under 5 U.S.C.1206(b)(2).
Sm ifically, it is alleged that:
(1) the NRC chose to exclude from tae scope of the investigation serious issues brought to its attention which t,ha NRC had a statutory responsibility'to investigate; (2) the issues
- accepted for investigation unre not investigated thoroughly or in keeping with sound investigative procedures or techniques; and (3) l the investigative conclusions unre inaccurate and incocplete. It is I
further alleged that, because the investigation was conducted in a l
shallow and :.fmited manner, it allowed the continuation of rnznerous wangful situations and activities at the Zinmer facility, including, others:
(1) serious faults in key safety systems; (2) an 9nef ective quality assurance program, due in part to malfeasance by i
the utility conpany and its contractor (3) inadequate fire detection and extinguishing systems; (4) poor security masasures; (5) ':cesence of ille6al firearms; (6) drunkenness amcrig enployees; and (7) tuft of meerials; which takan together may pose a substantial danger to public health or safety.
We recognize that all of the matters disclosed to this Office may not be within the jurisdiction of the NRC. Nevertheless, we are I
transnitting all of the information received in order to provide the full context of the allegations which apper to be within the pucview of the NRC.
l
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I request that your report be transmitted to this Office pursuant to 5 U.S.C.1206(b)(7) no later than sixty days from the date of your receipt of this letter. Please cite control nunbar 10-1-70041. We -
note, it is our procedure to maintain a public file of agency reports received smder 5 U.S.C.1206(b)(7). 'Iherefore, unless you provide some reasca day your report er parts thereof should not be released, we will include the report in full in the public file. For further information m uing this matter, please call me er James Sa My telephone nunbar is 653-7107, and W. Sugiyama'giyama of my staff.
s is 633-7140.
Sincerely, wary
<w g.
Acting Special Counsel Ehclosure 4
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