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December 6, 1982 AOf.7 $< ~,
t MEMORANDUM FOR: William J. Dircks, Executive Director for Operations FROM:
James G. Keppler. Regional Administrator, Region III R. C. DeYoung, Director, Office of Inspection and Enforcement
SUBJECT:
ZIMMER - RECOMMENDED PLAN OF ACTION FOR IMPLEMENTING COMMISSION ORDER Enclosed for your consideration is our reconunended plan of action for implementirs the Zimmer Order.
Recognizing that some Public Interest Groups have petitioned the Comission to require specific initiatives with respect to the selection of independent parties at Zimmer, we are leaving to your judgment the best way to com:nunicate this plan to the Connaission.
1 James G. Repp e Regional Administrator C D ng Director, Office of Inspection and Enforcement
Enclosure:
As stated cc w/ enclosures V. Stello. Jr., DEDROGR If. Denton, NRR G. Cunningham, ELD e508150396 050703
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ZIMMER PLAN OF ACTION l
1 Issue Plan of Action Special Comments 521ection of Independent Licensee wf11 submit written report to The licennee's submittal will be assessed Orgrnization to Perform NRC recommending organization to perform principally from the standpoint of Management Review of required review and provide the bases organization independence and technical Zimmer Project for this recommendation.
(Order and managerial competency. The criteria Requirement IV.B(1)(a)).
governing the relationship between the i
Ifeensee and the consultant will parallel Region III will provide copies of this that used for the Diablo Canyon review.
report to NRR, IE. ELD, and interested parties in the Zimmer case for their Since this phase is only preliminary to comments. Written comments must be the licensee's presentation of received in Region III within two weeks recommendations regarding future manage-of the date the report was mailed from ment of the project, lengthy procedures Region III.
for public participation are not considered necessary. Therefore, a public Region III will thoroughly review the meeting is not planned at this stage.
l Itcensee's submittal and evaluate all comments from interested parties.
. Region III will respond in writing to CC&E's proposed action.
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Icone Plan of Action Special Coments Recoussend Course of
- Licensee will submit written report to None Action by Licensee Based NRC recowe:ending course of action on Independent Review following receipt of the report of the independent review.
(Order Requirement IV.S. (1) (b). ) A copy of the report of the independent review will have been provided directly to Region III by the independent reviewer. However, the licensee's report of its recoussended course of action should have appended to it the report of the independent reviewer.
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. Copies of this report will be provided to NRR, IE, ELD and interested parties in the Zinamer case for coseent. Written connents from interested parties must be received in Region III within two weeks of the date the report was mailed from I
Region III.
+ A meeting among the NRC. the licensee, and the independent reviewer will be held in Cincinnati to discuss the report.
Public participation will be permitted.
l Subsequent meetings, if needed, will be j
held by the involved NRC 0ffices to_
develop an WRC position with respect to j
the proposed course of action.
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Issue Plan of Action Special Comments Rec M ed Course of
- A proposed response to the utility will Action by Licensee Essed be prepared by Region III with input
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from the responsible program offices.
(continued)
The Commission will be advised in writing i
of the staff's position prior to responding to the licensee.
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. Region III will respond in writing to l
CG&E's reconnended course of action.
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Issue Pisn of Action Special Coments Submittal of Updated Licensee will submit plan to NRC None Congrehensive Plan to (Order Requirement IV.B.(2)(a).)
Verify Quality of
{ Construction
- Copies of this plan will be provided to NRR. IE, ELD and interested parties in the Zimer case. Written coments from interested parties must be received in Region III within two weeks of the date the plan was mailed from Region III.,
A meeting among the NRC, the licensee and the independent reviewers will be held in Cincinnati to discuss the plan.
Public participation will be permitted.
Subsequent meetings, if needed, will be i
held by the involved NRC Offices to develop an NRC position with respect to the proposed plan.
- A proposed response to the utility plan will be prepared by Region III with input from the responsible program offices. The Commission will be advised in writing of the staff's j
position prior to responding to.the licensee.
Region III will respond in writing to CC&E's proposed plan.
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Issue Pian of Action Special Conraents Subsittoi of Cogrehenette Licensee will submit plan to NRC Plan for Continuation of (Order Requirement IV.B.(2)(b).)
Construction Copies of this plan will be provided to NRR. IE, ELD, and interested parties in the Zimer case for consent.
Written cosenents frou. interested parties must be received in Region III within two weeks of the date the report was mailed from Region III.
A meeting among NRC the licensee, and the independent reviewers will be held in Cincinnati to discues the plan.
Public participation will be permitted.
Subsequent meetings, if needed, will be held by the involved NRC Offices to develop an NRC position with respect to the proposed plan.
. A proposed response to the utility plan will be prepared by Region III with input from the responsible offices.
. A briefing of the Commission will-be provided concerning developments since issuance of the Order.
. Region III will respond in writing to CC&E's proposed plan.
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Issue Plan of Action Special Comments l
Relazation of All or Licensee will submit request for Pcre of the Order relaxation of all or parts of the Order in writing.
(Order Requirement IV.B.
(3).)
Copies of each request will be provided to NRR, IE, ELD, for comment and to interested parties in the Zimmer case for information.
. NRC Offices vill be consulted to obtain f
connents, as appropriate.
. The Cossaission will be advised of the more significant relaxation requests before relaxation is granted.
Region III will respond in writing to the relaxation requests.
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. prriens to get so near completion.
Another
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. ;6 is : ting duplicated at the 60 other nuclear plants c
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t -e mtinues,"...the fact is that the NRC was getting
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.:: s u.;e " e -id-1970s about problems at Zirmer.
However, those fe ;m c;7 aints by plant workers to some of the Commission's own 1
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- 'on rgrts--went largely unheeded until one Thomas Applegate r: r.
W u.i n v e scene."
A nuder of 4 erating nuclear power plants may have " undiscovered defects because of falsified Federal safety-inspection reports," according to an article in the Wall Street Journal.
" Documents obtained under the Freedom of Information Act from the NRC indicate t".at in the early 1970s Federal inspection reports were written for inspections that weren't ever made on nuclear power plants under construction...The documents also show that despite evidcnce of falsified reports, NRC officials made little effort to determine..hether unsafe plants had been allowed to operate." 12/15.
WASHINGTON--The House, by a 217-196 vote, cut off funding for the Clinch River breeder reactor.
A sir.ilar cffort to delete money for the reactor is expected in the Senate unless Scrate "3jority Leader Howard Baker can revive support for the funding.
The Department of Energy's Gordon Chipman said the " vote does not deauthorize the project...
the law requires that until Congress deauthorizes the project, all monies appropriated must be spent tmiard its original objective." He said enough fiscal 1982 money remains to keep work raving ahead until the new Congress convenes in January.
Washington Post, New York Tires, '.:.'all Street Journal,12/15.
Edi torihily, the '.lall Straet.1nurnal today said, ' Ire:cer technology isn't likely to be eccnr.ic until the yiar 204U or latsr, and
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now the House has decided to close this sinkhole for taxpayers' dollars."
If the Suprere Ccurt follows a course laid out in several recent opinions, write l Felicity Barringer and Fred Barbash in the Washing _t_on Post, Congress and the courts The most immdiate l would have less authority to review Federal agency decisions.
beneficiaries if the high court continues to restrict judicial review of agency decisions, they write, would be the Nuclear Regulatory Cormission and the nuclear power indus try.
This term, the Supreme Court will take up an appeals court ruling that the NRC rast consider potential psychological stress on local residents of Three Mile Island in evaluating the environmental impact of restarting TMI-1.12/15.
COLU"305, Onio--The slowdown in electricity-use growth over the last decade has hurt many utilities, but for years American Electric Power, which operates a nuclear plant in Bridgman, "I, had a safety net by selling to other utilities, writes Paul Ingrassia in the Wall Street Journal.
This year the Midaest's deep recession has caused area utilitieTto sharply reduce outside power purchases and that is hurting AEP.
12/15.
KN0XVILLE, TN--The Tennessee Valley Authority expects to hold its rate increases to the rate of inflation through the mid-1930s, Chairman Charles Dean, Jr., said. He noted that several major construction projects have been deferred, although they would be resuwd "if demand turns around." Wal.l. Street Journal, 12/15.
Fo r A -t+ 493 L/71
G 24At Lj JUL 2 21983 MEMORANDUM FOR:
Chairman Palladino Commissioner Gilinsky
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' ~ Comissioner Roberts
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Commissioner Asselstine FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
ZIMMER QUARTERLY STATUS REPORT Enclosed for your information is the firs ~t Zimmer quarterly status report.
The next quarterly status report will be issued about October 1,1983.
Eecause this is the first status report, we would appreciate your coments concerning the content and level of detail in the report.
Infomation about investigations has no_t been included in the status report.
That information is being reported separately by the Office of Investigations.
(54ne0 Eliam l.Dksks William J. Dircks Executive Director for Operations
Enclosure:
Zirxner Status Report Distribution:
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J. Keppler, R-III Resident Inspection R-III T
D. Hunter, R-III E. Schueibinz, R-III rCW R. Warnick, R-III Paul Ryder, OH Gov. Office OIA R. DeYoung, IE 01 J. Snizek, IE OCA H. Denton, NRR
.C R J. Taylor, IE W. Dircks, EDC R. Heishman, IE J. Roe, OEDO J. Stone, IE T. Rehm, OED0 IE File V. Stello, OEDO RCPB R/F
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c ZIMMER QUARTER.LY STATUS REPORT A.
Actions Reouired by Order
'1.
Indeoendent Management Review [Section IV.B.(1).(a)] - Torrey Pines
.. Techno. logy (IP,T) was approved _by the Region III Administrator on April 15,1983 as the independent orgart12ation to review Cincinnati ~~
Gas'and Electric's (CG&E) management of the Zimer project. TPT started the onsite management review on May 2,1983, following the public meeting held in the. Cincinnati area on April 25, 1983. TPT expects to issue the final report by July 29, 1983.,
In the process of reviewing and approving the organization to perform the independent management review, the following meetings, open to the public, were held in the Cincinnati area:
January 5, 1983.
Meeting participants were R-III, IE,f1RR, and the public. The purpose was to discuss comments received on the CG&E proposal to use Bechtel to perform the independent management review.
On February 23, 1983, based on input from the Comission, R-III informed CG&E that Bechtel could be the construction completion manager or perform the ir. dependent management review but not both.
CG&E then proposed Torrey Pines Technology to perform the independent management review.
April 25, 1983 -
Meeting participants were R-III, IE,fiRR, and
'TPT.
The purpose was to discuss TPT's plan for performing the independent management review. At the conclusion, the flRC authorized TPT to start the management review.
f1RC also requested another public meeting to be held after TPT's initial survey of CG&E's management of Zimer.
Following the meeting, the fiRC staff responded to questions from the public.
May 26, 1983 -
Meeting participants were R-III, IE, fiRR and TPT.
The purpose was to discuss changes to the plan proposed by TpT after their initial survey of CG&E's management of Zimmer including discus-sions with interested parties.
Following the meeting, the fiRC staff responded to questions from the public.
2.
CG&E's Recomended Course of Action [Section IV.B.(1).(b)] - Awaiting completion of the independent managemant review (item A.I. above).
Following receipt of the TPT report CG&E expects to issue their recomendations to Region III by August 19, 1983.
Region III intends to hold a public meeting about September 9, 1983 to discuss CG&E's recomended. course of action.
Region III expects to complete the O
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I review of CG&E's proposal and inform the Commission of the results by September 30, 1983.
3.
Updated Comprehensive Plan to Verify Construction Quality [Section IV.B.(2).(a)J - Awaiting completion of the independent management review and subscquent approval of the proposed changes by the Region II.I Administra, tor. A date has not been established for the comple- ~
tion of'this item.
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Construction Continuation Plan [Section IV.B.(2).(b).] - Awaiting completion of the independent management review, the subsequent approval of the proposed changes by the Region MI Administrator, and, updating the comprehensive plan to verify construction quality. A date has not bden established for the completion of this item.
E.
Other Activities 1.
Cincinnati Gas and Electric All safety-related work has been suspended in compliance with the
-flovember 12, 1982 Stop Work Order, except for work under verificatien programs including the Quality Confirmation Program (QCP).
The QCP
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was developed by CG&E in 1981 to confirm the quality of construction at Zimmer that had been completed before April 1981.
Eleven tasks were originally defined and each task was designed to expand or contract based on the finding in that particular area.
Based on.the a
results of the NRC Evaluation Team (NET) report, NUREG-0969, the QCP will be realigned to address:
a.
Masonry Wall Construction b.
Seismic Column c.
Boltings The QCP was scheduled to be completed in February 1984. The addi-tion of the above items may cause the ccmpletion to slip.
In addi-tion, the Stop Work Order,Section IV.B.(2)(a), requires the QCP to be reviewed and revised in scope and depth, as necessary, based on the hardware and program problems identified to date.
Effective April 21,1983, Mr. J.1:illiams, Jr. becarre the Senior Vice President of Nuclear Operations and is responsible for all CG&E nuclear activities.
Reporting to Mr. Williams are the managers of the following departments:
Nuclear Engineering, Nuclear Services, Quality Assurance, and Nuclear Production. Mr. E. A. Borgmann is new the Senior Vice President, Engineering Services and Electric Produc-tion.
Reporting to Mr. Borgmann are the managers of the following departments:
Generation Construction, Licensing and. Environmental Affairs, Electric Production, and General Engineering. The Genera-tion Construction and the Licensing and Environmental Affairs Depart-ments will continue to provide support, and will take direction from Mr. Williams in matters concerning the Zimmer project.
E 2.
Recion III In mid-1982, Region III became concerned about welder qualifications at Zinner. During the week of July 12, 1982, a random sample of ten active welders was chosen for detailed review.
Five of the ten welders were considered unacceptable by the R-III inspectors because
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of documentation deficiencies.
(DetailsareinIEInspectionReport Nci. 50-35P/82-10). The licensee tKen performed a detailed review of-the documentation for active welders' qualification. About half of.
the active welders' qualifications were considered indeterminate because of discrepancies. identified by the NRC.
In order to continue construction activities,103 welders were required to requalify.
At the request of Dr. H. R. Meyers, Science Advisor, Subcommittee on Energy and the Environment, Committee on Interior and Insular Affairs, U.S. House of Representatives, a comprehensive review of the qualifications of welders that were active at Zimmer during the period of July 9 through October 18, 1982, was performed by Region III during March-April,.1983.
The review of the records for 535 welders that were active during the selected period required over 500 inspection hours by five R-III inspectors.
This review provided additional assurance that the information provided to R-III by the licensee in July 1982 was accurate and the welder requalification requirements were conservative.
At the request of the Region III Administrator, a broad baseline evaluation has been performed at Zimmer by a multidisciplined team.
The results of that evaluation was published in NUREG-0969, Report of the NRC Evaluation Team on the Quality of Construction at the Zimmer Nuclear Power Station, dated April 1983.
Since the Stop Work Order was issued in November 1982, the Region III inspection activity has concentrated on review of nonconformance reports issued by the licensee, monitoring and inspecting ongoing activities including the Quality Confirmation Program, and monitoring the stopping of safety related construction activities.
Region III has assigned three full-time Resident Inspectors to Zimmer.
3.
National Board of Boiler and Presscre Vessel Inspectors In 1981, following completion of an investigation by Region III of quality assurance activities at Zi..T.er, the State of Ohio requested tne National Board to conduct an audit of the American Society of Mechanical Engineers (ASME) Code compliance at Zimmer.
The National Board made an initial audit on December 8,1981.
Based on that audit, the National Board recommended that a detailed investigation be conducted and the number of authorized nuclear inspectors be increased at Zimmer. On March 1,1982, a National Board team was assigned to the Zimer site to conduct a detailed investigation.
That investigation is continuing. Their concerns to.date include welder qualifications, weld procedures, weld records, quality assur-ance audits and material traceability. The findings of the National Board inspectors have generally been consistent with Region III findings. The number of authorized nuclear inspectors has been increased as recomended by the National Board.
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