ML20064E152

Submits List of Components to Be Included in Region 3 Upcoming Independent Tests at Facility.Related Info Encl

ML20064E152
Person / Time
Site:	05000000, Zimmer
Issue date:	07/22/1981
From:	Devine T GOVERNMENT ACCOUNTABILITY PROJECT
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20064E073	List: ML20064E133 ML20064E148 ML20064E152 ML20064E173 ML20064E193 ML20064E217 ML20064E237 ML20064E253 ML20064E268 ML20064E283 ML20064E293 ML20064E296 ML20064E299 ML20064E307 ML20064E311 ML20064E419 ML20064E443
References
FOIA-82-206 NUDOCS 8301050125
Download: ML20064E152 (203)

Text

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, -GOVERNMENT ACCOUNTABILITY PROJECT 8+Md Instituto for Policy Studies 1901 Que Street. N.W.. Washington. D.C. 20009 (202)234 9382 July 22, 1981 MIN IPAI, SEAFI LM "

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Mr. James Keppler &Nef Nt-do 3 - g Director, Reg . on III - A /3 125LO Nuclear Regulatory Commission 799 Roosevelt Road geMM;pr V Glen Ellyn, Illinois 60137 ggg DESTI >

Dear Mr. Keppler:

s DEP&OS rile [

, [s Thank you for this op'portunity to assist in your investi-gation of the Zimmer nuclear power plant by submitting a list of components to be included in your upcoming independent tests of the plant. I realize that you are taking a relatively rare step by extending the investigation to include these tests, in-stead of the normal " walking tour and paperwork review" approach.

Your initiative demonstrates that Mr. Applegate was right when he predicted that his charges represent only the tip of the ice-berg of safety problems at Zimmer. ,

Please also excuse my delay in responding. GAP has had pressing deadlines on a series of cases, and Mr. Streator in-formed me last month that there would be a time lag before the tests began.

You may find it helpful to understand the background for these recommendations. When Mr. Streator invited GAP's assistance, I contacted all of the previous witnesses and groups who have helped our probe. I asked their assistance in making their cri-ticisms specific enough so that you could conduct outside tests on individual components. I also asked that each source offer to pass along evidence from other workers who may be nervous about speaking with me directly.

I am pleased to report that your offer of working with GAP produced a surprising amount of new information. Many workers at Zimmer are reluctant to speak out because of cynicism and fear of retaliation. As one former Zimmer employee explained, the day he made disclosures to NRC inspectors he was relieved of all duties.

l He was fired within a few days. His sacrifice produced a " walk-through" by inspectors who did not appear to understand the

technical nature of hi.1 charges. Nothing was accomplished, and

! the utility threatened to sue him after he was fired. Every public whistleblower at Zimmer has been attacked viciously by the utility at CG&E, so workers are afraid to talk. They responded to your creative initiative, however, and several new witnesses agreed to speak with your investigators on an anonymous basis.

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BUL 2 1 19Bf 8301050125 821116 PDR FOIA DEVINE82-206 PDR

Mr. Keppler- July 22, 1981 The witnesses provided the data to prepare a list of 28 parts of the plant that should be tested. In several instances, the information was still too gener'al to identify specifics, so I contacted scientific and engineering experts to identify the most vulnerable components that the generalized allegations could be describing. The results follow with as much specific

.information as I received:

I. CONCRETE

1) Reinforcement bars and concrete in the lining of the plant's suppression pool.

2) Concrete and foundation for the cooling tower support structure, to test for sinking.

3) Quality of the concrete, specifically for three pours made during January and February,1981, and generally through spot checks for post-1977 pours. The January and February, 1981 powers were approximately 300-400 yard jobs with holes 2 feet by 3 feet. Witnesses can describe where to locate the rele-vant records for the following problems --

a) The pours needed to be done within an hour after leaving.the mixing plant to maintain acceptable strength. But due to transportation difficulties, it took up to four hours before the pours were completed.

b) Large quantitics of water wers added to i concrete to stretch it and help it to flow due to i

hardening during_ the long time lags.

t c) Due to leaky valves on the trucks in the January and February runs, still more water may have mixed l

with the concrete inadvertently.

l d) The chutes were not clean on the trucks.

i j e) During a labor dispute the concrete company l hired 48 new employees off the street, many whom were not l experienced mixer-drivers. Some had never even driven

! a truck before. As a result, they might mistakenly mix

! an improper amount of water into the concrete, or obey an order not to record extra water added improperly. ,

f) The Kaiser inspector would only look at th e

. first load and then leave the inspection ticket for one . , ,

of the mixer-drivers to complete.

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, Mr. Keppler July 22, 1981

11. WELDS

4) Prefabricated welds on the Residue Heat system.

The relevant witness will share more specifics with your in-spectors. *

5) Prefabricated welds on the large bore piping.

6) Welds done on the C level of the plant's suppression pool. The vertical and overhead welds are especially suspect.

The source also discussed the failure to inspect these welds before they were grounded. He explained how unqualified welders who couldn't pass the tests were falsely certified on the basis of test coupons performed by others. He can identify specific welders and has drawings and photographs demonstrating how iden-tificatien markings for welds were altered on test plates to accomplish the coupon-switching scheme.*

7) Prefabricated welds in the main steam relief system piping.

. III. CONTAINMENT

8) Leak tightness of the wetwell/drywell vacuum breakers in the primary containment system. The vacuum breakers

. prevent fluid from getting into the drywell of the containment.

9) Downcomers that discharge water into the uetwall .

of the containment system.

10) Lining o'f the containment suppression pool for bowing of the plates and quality of the metal.

11) Vibrations around the suppression pool. There should be tests for pressure vessel pedestal acceleration to insure that pressure waves from the suppression pool do not lead

,

• This source added a tip for future NRC investigators. He stated that whenever NRC inspectors entered the premises for unannounced inspections , the front guards would communicate that the NRC was in the plant. Hurried efforts followed to give the plant a ship-shape appearance for the walking tour inspections.

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Mr. Keppler July 22, 1981 to unsafe vibrations above the seismic design basis at Zimmer for vessel pedestal support. The tests can be conducted by mounting accelerometers during a test run and opening the safety relief valves to measure how the blowdown affects vibra-tions.

IV. ELECTRICAL SYSTEM

12) Sealants at the grids where electrical cables pene-trate walls. The witness claimed that excessive cables have pre-vented proper installation of sealant at grids where cables penetrate the walls, resulting in damaged cables and installation.

13) Electrical penetration seals around conductor rods and nozzles for electrical power and instrumentation cables which breach the plant's containment. The significance is that inadequate epoxy sealant results in gross leakage paths and in-adequate electrical insulation of the penetrations. As a result, the containment could be breached and control cables shorted out.

Experts have described this flaw as the weak link in Mark II containment systems.

14) Power drawers at supervisory locations for the electrical system.

15) Vertical cable trays from the top of the plant down to the containment area. The trays should be tested for questionable manual welds and overloading. The witness, Mr.

- Ed Hofstadter, has a diagram to assist whomever conducts the tests.

I V. CONTROL RODS, PUMPS AND VALVES

16) Environmental qualifications of heat exchangers to see if the tubes can withstand accident conditions.

I

17) Rod worth tests to check whether boron has been lost from control rods.

18) Safeguards against control rod drop accidents (where the rod becomes disconnected and remains stuck in the inserted position af ter the control rod drive is withdrawn) .

In particular, the incpectors should test whether Zimmer has Rod sequence Control as a patch.

19) Control rod drive pump.

20) Primary recirculation pumps.

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Mr. Keppler July 22, 1981

21) Environmental qualifications test under accident conditions for both valves and load minimizers on safety relief valves. These components control pressure vessel pedestal ac-celeration (see #11, supra), and stuck valves can lead to. blow-downs into the suppression pool.

22) Tne Nash Condensor used on the Terry Turbine.

Full tests should be conducted for core shifts that weaken its ability to withstand accidents. If the condensor cracks during the stress of an accident,- the safe shutdown of the reactor would be threatened. The witness for this item, Mr. Vic Griffin, has drawings and photographs to illustrate the targets for the tests.

VI. PIPING

23) Feedwater spargers -- the large, heavy-walled pipes designed to distribute fluid uniformly through vessels.

24) Vessel safe ends and attachments to large and small bore piping systems.

VII. MISCELLANEOUS COMPONENTS

25) Plates on the seventh floor fuel pool, to test whether they are stainless steel or cheap carbon steel plates

-covered with a thin layer of stainless steel.

26) Steel plates, shapes, I-beams and channels pur-chased from outside vendors for critical areas. Tests should be conducted on parts that have been identified in Inspection Reports but not in NRC Nonconformance Reports. The witness, Mr. Vic Griffin, can tell NRC representatives how to locate the suspect components.

27) Seismic hangars in the spreader room, as well as redundant conduit systems on hangars.

28) Instrument panels at 570 foot elevation. The witness stated that the panels have inadequate drains, which should be checked. The panels themselves also should be tested and calibrated.

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. Mr. Keppler July 22, 1981 i '.

It is important to emphasize that this list is illustra-tive, rather than exhaustive, of the Zimmer components that should be tested. Witnesses told GAP that even more employees complain about safety defects at Zimmer than are willing to cooperate with your current investigation.

Further, the NRC inspection reports cited in GAP's May 11, 1981 petition identified numerous repeat noncompliances on safety components. Those items are particularly ripe for testing.

It is hard to underestimate the potential extent of poor work- '

manship at Zimmer. For example, NRC inspectors recently have found the debris from a drinking session and in another case a sleeping worker, littering up the cable trays at the nuclear plant!

In light of this contruction sloppiness and your own pre-liminary oral confirmation for some of Mr. Applegate'.s. original charges, I am disturbed at several aspects of the current in-vestigation. Since you have told Mr. Applegate that the first 3 NRC report on his charges may be released at the end.of July, l I am especially concerned that the groundrules we established

.in February will be respected.

First, several witnesses Mr. Applegate referred to you report that NRC investigators still have not contacted them.

At the February meeting, you explicitly promised to meet with all witnesses referred by Mr. Applegate. In my opinion, the witnesses involved should be the starting point for your investi-gation, rather than apparently forgotten just a few" weeks before release of your first report. For example, Mr. Vic Griffin was of invaluable assistance in helping to prepare this, list and he can identify the records that will permit your investigators to expand greatly on GAP's suggestions. Mr. Tom Martinfs detailed disclosures on problems with the control rods prophesized eventual Stop Work orders and Immediate Action letters this year. He remains willing to speak with the NRC. We at GAP do not under-stand why your team has overlooked these witnesses.

Second, your investigators reported to me that kr. Aldredge, the President of Peabody Magnaflux, now claims that Mr. Apple-gate's literal transcription of th2ir conversation is accurate.

But Aldredge goes on to state that Applegate misunderstood. That explanation is hard to swallow, since Mr. Applegate did most of the talking and Aldredge responded, "Well, you're right."- It is also hard to explain how Applegate could have misunderstcod Aldredge's explanation why he couldn't admit the retaliatory dismissal publicly: "When you work for a closed industry, it is very tight. . . . I'll be off every major fabricator within 30 days. The computer all of a sudden won't have us in the bidding bank."

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1 Mr. Keppler July 22, 1981 Further, your staff suggested that I reread the Aldredge transcript from the perspective that Applegate was a friendly Cincinnati Gas and Electric ( "CG EE") representative contacting the leader of a company thrown off the job for poor work.

Quite frankly, that suggestion raised questions whether your staff understood the context of the call. Mr. Applegate had long been released from CG&E's service when he called Aldredge.

Mr. Applegate made it clear during the conversation that he was investigating the utility, not representing them.

The Aldredge tapes are a key aspect to Mr. Applegate's

' charges that the utility has covered up safety problems and even engaged in institutional retaliation against PM, the radio-graph company which " blew the whistle" by doing its job and reporting x-ray results. The A1 dredge transcript has been examined from every possible angle, but none of the twisting has been able to explain away the obvious: He agreed with Mr.

Applegate's charges in private but could not admit to that posi-tion publicly due to fear of blackballing. If your staff dis-agrees with this conclusion, I urge you to consider my offer to jointly interview Mr. Aldredge with an NRC representative. I will be in Houston soon and could participate without expense to the NRC. .

Finally, I was concerned that your staff was reassured that foul play may not have occurred in the PM trailer break-in, which they confirmed occurred. They explained that the PM trailer i

was broken into frequently, since it had the only toilet on that part of the construction site.

1 The explanation is considerably more shocking than the

. original charge. This explanation confirms that -- for want of an outdoor portable toilet -- there is virtually no security for key safety records. NRC reports have blasted the licensee (and PM indirectly) for x-ray discrepancies and missing radiographs.

It is not surprising that the x-ray records were a mess, if

' workers frequently broke into the PM trailer "to go to the bathroom."

These criticisms and suggestions are offered in the spirit of cooperation you have observed throughout the renewed Zimmer inves tigation. Both GAP and Mr. .Applegate wish that your reports will resolve the lingering mystery about safety problems at Zimmer, rather than sparking a new conflict about the NRC inves-tigation. As a result, it is important to share these concerns with you before your reports begin to be released.

I tentatively plan to be in Chicago on Friday, July 24 and ,would be glad to meet with you or a representative. At that time, I can answer questions you may have on our list of suggested i

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, Mr. Keppler July 22, 1981 I

components for testing, discuss the above concerns, and turn

- in the paperwork for my earlier trip to Chicago.

Sincerely, Thomas De ine Associate Director

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s N-m sne ZIMMER MAJOR ISSUES Radiographs of shop welds - 187 of about 700 radiographs reviewed (about 27%)

did not conform to ASME Code requirements. The quality of the radiographic image was not good enough to tell whether or not the welds contained unaccep-table areas.

Structural beams - Structural beams had been installed without design drawings or material traceability records. It is not known whether they are adequate for the intended purpose or of acceptable material quality.

Material traceability - Other areas where material traceability has broken down are welding electrode control and small-bore piping material control.

Voiding of nonconformance reports - Many nonconformance reports, properly issued, were arbitrarily voided without valid supportive reasons.

ALLEGATIONS Section 4 -

4 allegations made 3 valid 1 questionable Section 5 (Applegate) -

19 alleghtions made 10 valid 8 nits or no safety problem

- 2 major issues 9 not valid or not safety issue Section 6 -

Allegations received during the investigation 3 all valid 2 safety, but not major '

Seceion 5 19 The allegation appears to be correct, but the implication of wrong doing Y on the part of the licensee is clearly not confirmed. The event was ,b f~ t promptly and properly identified and reported, consistent with NRC requirements.

Section 5.13 3 g 1.

Par 5.13.2 - Is "2%" CL c:;n.w cgrrect?

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2. Page 6 - referenc to " 3 " should be explained.

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Seems like over[1115 Section 5.14 , ,

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1. Overh11, bh generally correct.

2. Par. 5.14.4 page

(\ 19). 'The statement-that "The NRC's independent veriff-cation program w'11Vassure (that) construction defects have been identified "

V' is an overstatement.

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' N What s'the basis for the statenent that "there was evidence that drug use mig have occurred"? In any case, with the qualifier "might have " what significance does this have?

Section 5.15 Should this be introduced by a disclaimer that the sub. ject has no relevance to NRC safety responsibilities?

h 4A,fr. Un/Cl [y 3ection 4.1 should be written to emphasize that Wfproper voiding of NR s continued after the situation was identified in IE inspection report No.

50-238/80-25. Examples of improper NR disposition prior to December,1980 or N

Q can be dispositioned as yes, we are aware.a Continuing improper NR disposition should be the thrust of the investigation.

_Section 4.2 Kaiser Instruction M-12 explicitly prohibits burning bolt holes for large ,[

bore pipe support hangers. The report talks all around the subject, but does not address the question of whether bolt holes were actually being burned (Without subsequent Yeaki e ,'t The question of sample size is a mHW. If a support has 12 bolts, one would be an 8-l/3% sample (pretty big). M * # b N/r/1 WO N d d W h J+s .

Section 4.3 It appears that everyone is missing the real problem. Who, if anyone, has the ype Code Authority action? What about the ANI and the Authorized Nuclear

[h Inspection Agency? Didn't Marble Hill teach Region III anything? _

NOTE: Diesel Generator tarting air fuel oil piping are not covered Section III;Section III requirements may be invoked by contract, but SBE'and M ANI will not be invo D.G. Cooling water piping could be ASME III Class ND, M

but 1971 Edition hade rules for ND. / ' C- b  !

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I don't': understand the discussion in Section 4. . 0 o pte alf

'An SIS Report."

Section 4.4 dug out. It's This seems like a whole lot of finger pointing, not very well g hard to tell much without the specific statements. 0V qw M. Perhaps there was inspector intimidation It basically does nothf 6g A ~

and harassment.

i tion, but The investigation (as reported) is not sufficient to support l a c ta if the chargehare M(and it appears that they may be) there is a c ear .

violation of Appendix B.

Section 5 (Generall t ting provided a written statement at es The statement re:urs " individual t nott g to the preceding information; however he requested that the statemen be attached to this report".

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1. What use is the statenent when se conditioned? Mc ,

2.

How can anyone accept the accuracy of the paraphrase in the report 6

Section 5._1 l sion that changes g With recommended changes, the section seemsUnderstandably to support achanges conc u made are consistent with revised NRC safety requirements.

involved added cost.

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.This is a very confused text, but seems to describe a rather routine identiff-

[M cation of a detail problem, and consequent design change "A nit "

. Over 11

_S ection 5.3 w

A nit .

More attention that it deserves.

Section 5.4 See 5.2 Section 5.5 Text needs editing. Have Collins review for chnical accuracy.

I Substantive - not a nit, but of relatively low significance. Is " Individual A" I a credible witness ? l i

l Did the investigators properly explore the validity of allegations?

With an inspection history of non-conformances dating back to 1975, where was Region III?

N I don't understned the relevance of the statenent at the bottom of Page ll.

The findings on page 15 (Par 5.5.41 seem ambivalent.

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The safety. concern about W9 ed fe*xposure is real, as evidenecd by docu-p mentation of several fatalities at nuclear power plants, gNe NRC's prior deferral to OSHA strikes a sour note. Parlier's attitude (Par. 5.6.3, page 4) should not be accepted at face value.

5.7 Allegations talk about 1977 time frame. Data appears to talk to 1979. Is this a typo?

Move statement (2nd par.- Sec. 5.7.4J to 5.7.17 1

_LL Check validity of statements in paragraph 5.8,2 Y

Section LR A2 (2nd par,)

gr e What was Ind1Yidual B's involYement at Zimmer?

Section 5.8.3.5 (pg 6)

I din't understand reference to " Schedule 844" "3-1/2 inch wall thickness with welds 1-1/2" wide". 1' I don't understped the reference to "radiographing . . . thoragh laminations",

i Section 5.8.3.10 (pag.13) 2nd par, l "Whose inspectors"?

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NOTE:

Lack of proper shkning of penetrameters raises serious questions on the quality of the resultant radiographs to show whether welds are truly good or bad.

Detail in Table 5.10 seems to be ove 11.

Section 5.9 Par. 5.9.2 For " goodness" sake tell what report 50-358/78-19 contained.

If this is a repeat of a previous allegation does it refer to things that appeared in 1978 or later? There is a difference. Where does the reference to RIV (on page 6) come from? What significance is there to the concluding statenent in par. 5.9.3 (page 517 What does the conclusionary statement in par. 5.9.4 mean?

Section 5.10 The significance of the identiffed non-conformances is not clear.

Section 5.l'0 _

Although the language of the allegation is not too clear, it appears that the problems alleged (and apparently confirmed) do not represent a significant L

safety concern. Thes should be more directly addressed.

Section 5.16 Th'e introduct4ee paragraph to 5.16.2 does not appear ralevant.

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The coy references to " Individual A" etc., lend nothing but confusion to the report. This section leaves me confused.

It would help tor provide a sumary analysis of the results of the variods interviews.

Sections 5.17, 5.18 _

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Gives me no problems except that par. 5.17 & 5.18/5 should include "or safety significance".

Section 5.19 Section 5.19.4 - The conclusionary sentence "will enable this detemination to be made" is too positive. . )

This

_Section 6.1 should tie back to and be consistent with Section 4.4.

may be over) 11. Perhaps signficant substance of Sec. 6.1 should be in-cluded in 4.4 and simple referge be made to 4.4. (NOT the other way around.)

Section 6.2_

f This should not scramble ASME & AWS requirements. There my be a grey area as to whether either ASME or AWS has legal jurisdiction.

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Wt In my opinion AWS does not specifically lay claim to jurisdiction either but in practice, the criteria and requirements of AWS D1.1 were generally invoked by designers. In the absence of any other specifically identified require-ments it is reasonable to assume that AWS D1.1 y o Vh 5 The text of this section does appear to be incomplete. -

Section 7_

This jumps around too much to understand, in its partial state. It appears to need an introduction which describes what the section is about.

Section 8 The text needs editing.

. Section 10 It should be clearer that these are interim rather than final findings and l proposed corrective actions.

I Section 10 makes me think that all the " interim" ." working level" meetings are t

designed to help the licensee respond in a manner that RI!! can find acceptable

?whether or not the responses represent a valid corrective action" l This is a totally subjective opinion.

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'It i's not clear whether all tha comreitmtnts described in Section 11 are being e<N" 3 m. -pot enere i, so.e eviaence twet 13ey are not.

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1. _ HEAT NUMBERS FOR WELD ROD AND PIPING

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A. Discuss with Maura. Gwyn B. Discuss with Oltz.

1. How system was supposed to work.

2. What procedure covered actions to be taken. ,

3. What went wrong.

4. How corrections were made.

5. Were heat numbers placed on pipes or just documents (" corrections").

C. Review difference between ISK and PSK documents.

D. Interview Peiter.

1. How were heat numbers he placed determined (generic).

2. Who would be contacted to gather the information.

3. Ena e documents would be utilized.

4. Specifics on RHR 4-in pup piece (who, what, why, when, wherA,how).

E. Review Reiter personnel file.

F. Obtain information on material certification in file for RHR pup piece.

1. When pipe was received on site.

2. When pipe was issued from warehouse.

3. When pipe was cut.

G. Inspe ct pup piece.

H. To be determined. (Further actions).

2. LP TEST REPORT FALSIFICATION A. Review LP test documentation procedure.

- B. Review LP test documentation.

C. Review personnel file for inspector in question.

D. Trace and interview inspector via telephone (?) (if possible).

E. Interview inspectors presently performing LP tests.

F. RE-contact alleger as necessary to discuss information developed.

3. RPV " PUNCH LIST" DISCREPANCIES

a. Obtain RPV punch list, review, re-contact alleger, further work as appropriate.

ROUTING AND TRANSMllTAL SUP p TO: {Name office symbol, room number, initials Date pullt. ig, Agency / Post)

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Action File Note and Retum Approval For Clearance Por Conversate As Requested For Correction Prepare Reply *

• Circulate For Your information See Me

,X Comment investigste Signature

' lOoordinetton Justify REMARKS fk Gw r>^ ^ =-

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DO NOT use this form as a RECORD of approvals, concurrences, disposals.

, clearances, and similar actions ,

l l FROM: (Name, org. symbol, Agency / Post) Room No.-Bldg.

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( N/d sosa-act OPTIONAL FORM 41 (Rev. 7-76)

. . . . . . . , ~ . . . . Nca7/cE'!*e-ium

MEMORA!OUM FOR: J. F. Streeter, Acting Director, Enforcement and Investigation Staff i

R. .. Meishman, Acting Director, Division of Resident and Pro', 3 ct Inspection FROM: A. Bert Davis,' Deputy Director

SUBJECT:

INDEPENDENT VERIFICATIONS TO SUPPORT ZDMER I!NESTIGATION This memorandum establishes the independent verifications program which RIII will perform to support the Zimmer Investigation. If future investigation findings indicate that the information given below should be modified, please discuss it with me. This program is as follows:

1. The licensee is committed to visually inspect structural beam welds performed by Bristol Corporation. RIII inspectors will visually inspect a sample of the welds. Sample size will be sufficient to satisfy the criteria of 95% reliability with a 95% confidence factor. This independent verification will address the question of inadequate structural beam welds.

2. To provide confidence that field and shop welds are satisfactory a sample will be verified. Sample size will be sufficient to satisfv the criteria of 95% reliability with a 95% confidence factor based on the total of field

, plus shop welds. Verification will include making an " onion skin" tracing of

. . each weld's radiograph, comparing this tracing with the installed weld, P

assuring radiograph quality is satisfactory, and assuring all weld records 2

' are satisfactory. This independent verification will address the questions

\1 of whether weld quality was adversely affected by site activities such as

, , drinking. It will also partially address whether veld records are reliable.

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3. Equipment from the RI NDE Van will be reviewed to determine if it can reliably identify material co= position. If it can, the equipment will be e

I used to independently verify material traceability findings made by the licensee in structural steel and piping materials and welds. You will define the scope of this verification effort and submit it to the Director's Office for concurrence.

4. We will rely on the licensee to determine proper fit up of socket welds.

RIII inspectors will directly observe in the field a sample of the licensee's fit up determinations. You will define the scope of these field verifications and submit it to the Director's Office for concurrence.

5. The above verifications will not be performed until af ter the licensee has completed his work and verifications in these areas. This will assure we are looking at the licensee's final product.

If you have any questions, I am available to discuss them.

A. Bert Davis Deputy Director

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. DRAFT 8/15/81 transfer in-process nonconformances identified on Surveillance Reports to Nonconformance Reports in 30 days).

7.0 Independent NRC Inspection Findings During the course of the investigation, RIII inspectors performed independent inspections of various plant areas during allegation reviews. In those areas where deficient conditions were observed, further inspection undertaken to determine the extent of the deficient conditions.

,/ , 7.1 Control of Structural Steel Beams and Beam Welds j ,%pl During the investigation of the allegations addressed in Sections 4 and 5, Gh>[?v 6

the RIII inspector identified a beam with an unacceptable weld and two beams that were only tack welded into place. Therefore, the RIII inspector decided to make a more in-depth inspection and review the controls of structural beams and beam welds. The inspections and reviews included visual examinations of approximately twenty-five structural steel beams in the blue switchgear and cable spreading rooms, and reviews of related documentation.

7.1.1 Beans 0bserved in Blue Switchgear Room The area observed in the blue switchgear room (elevation 546 ft) was 8 ft 3 in, west of workline G,16 f t 6 in. east of workline H and between columns 22 and 54 of S&L drawing No. S-546, Revision AB.

The following(sg discrepancies were identified:

1. 5 W8 x 17 beam (8 ft 3 in long), positioned east to west and located 1 ft 9 in. south of column 24 and 10 in. below elevation 546 f t, was not specified on any pertinent design drawing. The beam appeared to be t-m permanently installed and traceability of the beam heat number was not

];'y * , , maintained. After extensive and unsuccessful efforts by QA personnel,

• ~ ~ construction personnel were requested to identify any document that ,

would control the unspecified beam. Construction personnel provided Design Document Change (DDC) No. S-2050, dated May 29, 1980, containing k, 7'ln '

only the signatures of two site construction engineers, who were ,

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identifying some of the additional W8 x 17 beams in the area covered c by S&L drawing No. S-546. TheDDChadnoS&Larchitecturalengineering.f5' t.g signatures of approval as of March 27, 1981. The DDC did not identify, .

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any specific beams. ( g'N1 The licensee identified S&L drawing E-189, Sheet 3, Revision H, Note No. 17, which allows W8 x 17 beams to be installed and then be submitted on a DDC for S&L approval.

2. A W8 x 17 beam (6 ft 3 in. long), positioned north to south and located hg 13 ft 8 in. west of workline G and 1 in. below elevation 546 ft, was not

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specified on any pertinent design drawing, was not documented on any_QC_

"- record, and had unacceptable welds.

159-

DRAFT 8/15/81

'd W8 x 17 beam (5 ft 5 in. long), positioned east to west and located 3.

_Q { 8 ft 10 in. south of column 24 and 1 in. below elevation 546 ft, wa_s 3 r 13 . not specified on anV pertinent design drawing, was not documented on any QC record, and had unacceptable welds.

., 4. ri W8 x 17 beam (2 ft 8 in. long), positioned north to south and located J" M ,. ;

9 ft 6 in, west of workline G and attached to the beam addressed in paragraph 7.1.1.3 and extending north, was not specified on any perti-nent design drawing and was not documented on any QC record.

, 5. tow 8x17 beams (8ft3in.long),positionedeasttowest,withone 1% located 5 ft 3 3/8 in. and the other located 9 ft 7 7/8 in, south of column 24, were_only tack welded in place. They displayed no identi-

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1. *' M fication or heat numbers and were not documented on any QC record which indicated in-process weld inspections were not performed. The beams were identified on DDC-2087, which was incorporated into S&L drawing No. S-546, Revision AB. DDCs and S&L drawings by themselves do not assure QC verification. 1 6'

6. Re-entrant corners on W8 x 17 beams had notches instead of the 1/2 in, minimum radius reouired by the American Institute of Steel Con-struction (AISC), seventh edition (1969), page 4.113. The locations of these unacceptable beam corners are shown in Figure 7.1 of this section ph ,.3 and are noted by (7) in Figure 7.1.

The location of the above discrepancies, additional unacceptable welds, unacceptable re-entrant corners, and nontraceable beams are shown in Figure 7.1 of this section.

The welds identified in the preceding paragraphs as unacceptable do not comply with the requirements of the AWS D1.1-1972 Code for one or more of the following reasons: slag was not removed; weld profiles had excessive convexity or concavity, blowholes, porosity and/or undercut.

7.1.2 Beams Observed in Cable Spreading Rooms The inspectors identified the following discrepancies in the cable spreading rooms:

1. A'W12 X14 beam No. F2500/8-66B4 had a weld that was incomplete. This u t beam was directly a' ove cable tray hanger No. 4HV8FEC231, which was attached. The beam was located approximately 11 ft south of the north wall at the stairwell.

3, ,, y 2. The traceability of the heat numbers was not maintained for two W8 x 17 beams, located south of and parallel to beam No. F2500/8-66B4~(above).

The first beam was located immediately adjacent to beam F2500/8-66B4.

The second beam was the fourth beam south of beam F2500/8-66B4. The first beam was installed flush to the ceiling of the cable spreading room. S&L drawing No. S-546, Revision AB, specifies the first beam to be installed 1 in. below the ceiling.

- 160-

DRAFT 8/15/81 3' . I A weld on the 5 in. channel beam that was supporting HVAC hanger No. 2071 had irregular weld profile, excessive undercut. porosity, and t-* craters that were not filled. The channel beam was located 2 ft north and I ft west of the cable tray hanger No. 13H2FEC008. The Waldinger, Young and Bertke (W-Y and B) Inspection Report, dated February 19, 1980, indicated that the weld was acceptable.

4. Two W8 x 17 beams, located in the northeast corner (north of WL-16 3-,* and east of WL-K), were only tack-welded into place. The beams were rh . . . g u

specified on DDC No. E-3834 dated October 20, 1978.y,J1DC E-3834, which affected eight drawings, was posted on, but had noybeen incorporated into, S&L drawing No. S-546, Revision AB, dated October 22, 1980.

Heat No. 72161 (purchase order No. 31134) was marked on the southern beam. The traceability of the heat number of the northern beam was not maintained.

The_ beams were not identified on any 0A inspection record, which would  ;;

have indicated their status. In-process inspections were not performed on the tack welds.

[ INSPECTOR NOTE: Some of the welds inspected by the RIII inspectors were painted. Therefore, the inspections were for relatively large deficiencies.)

7.1.3 Installation Deficiencies

1. For the beams identified on DDCs and addressed in paragraphs 7.1.1, items 1 and 5, and 7.1.2, item 4 above, no measures existed that would identify to QA the installations and work that was done by construction before the DDC was incorporated into the drawings. Thus, no measures existed to assure that all of the required QA inspections related to DDCs (e.g., welder qualification, proper filler metal, traceability of materials, etc.) would be performed. This condition was previously identified in IE Report Item No. 358/80-15-04. The corrective actions taken, which had not yet been reviewed by the NRC, with regard to Item No. 358/80-15-04 did not include the DDCs written prior to the implementation of those corrective actions and did not include the DDCs that are and have been implemented prior to receiving the S&L approvals.

This item is unresolved pending the complete resolution of IE Item No. 358/80-15-04 (358/81-13-63).

2. Failure to control unaccep_ table welds (addressed in Sections 7.1.1 and 7.1.2), the five beams with unacceptable re-entrant corners, and the four beams that were installed and not identified as a requirement on any design document is contrary to 10 CFR 50, Appendix B, Criterion XCE and the Wm. H. Zimmer QA Manual, Section 15.2.2 (50-358/81-13-03).

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addressed in Section 7.1.1 and 7.1.2, is contrary to 10 CFR 50, Appen-dix B, Criterion VIII, and the Wm. H. Zimmer QA Manual, Section 8.2, (50-358/81-13-04).

- 161-

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- of an applied " hold" tag. The NR states " Hold tag was applied while Wall Plate 10D was in process of being tensioned. Once hold tag was applied tensioning was continued until tensioning was completed."

4.1.4.2 Investigation a w =Aer on s \.W yI 4.1.4.2.1 Interview of Walter Dumford ' ' *.*h* w k ek @=

On February 11, 1981, Walter C. D'umford, Kaiser QC Inspector, was interviewed by NRC. He stated that on pool." ri-+ r :,n!/8Ulic ebythat gua45)(J b t 2",1981, he was inspectingfsuppression

pl:t: was not perpendicular to the plate *t T Iaid construction pYtsonnel were preparing to tension the plate when he told them he was going to place a hold tag on it, to which they one responded "try en #stop % "

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Dumford said he left the area to discuss the Matter with his supervisor, Dennis Donovan, who told him to initiate an NR for the nonconforming bolt and to place a hold tag to preclude tensioning of the plate. He said he returned to the suppression pool, placed a hold tag on the plate, and construction personnel ceased tensioning the plate. He said, however, as he left the area, he heard the tensioning machine reactivate and observed that the tensioning crew had ignored his hold tag.

Dumford stated he advised Donovan of the occurrence and Donovin told him to write an NR documenting continuation of tensioning after a hold tag had been

/

applied. Dumford called the NR Controller, was issued CN-5412, and locir mented the violation of the hold tag. He said that a few days late. ne was called into the Kaiser QA Manager's office and was told by the QA Manager, Phillip Gittings ,that the NR should not have been written since it was "a sof tware (procedural) problem and not a hardware problem." He said Gittings then said, "I'm going to void this NR because we do not need this kind of paperwork floating around because this is the kind of stuff that causes investigations." Dumford stated that Rex Baker and Dennis Donovan, who were also present at the meeting, disagreed with Gittings conclusion and advised Gittings that they felt it was a valid NR.

Dumford indicated that Dennis Donovan called the NR clerk : fr- hj: later x and was told CN-5412 had been reassigned to another NR (the original report had not been entered into the NR system). Dumford provided a copy of the original NR CN-5412, which is included as Exhibit 3.

4%e uq9er Dumford said this incident was ant ,picd exaple of4Ne+sar QA management 4 not supporting +he QA pr^;;r- ^- cite and being'finfluenced by construction.-een-a d c _ .. ., " .. L _:,_J i i, i '.i yIrinn, th: L _ QA ._ , . ::-

n-flu ::cd , , ..;tru;;ien and QA was not independent at Zimmer.

On February 11, 1981, Dumford provided a written sworn statement attesting to the preceding information, a copy of which is included as Exhibit 4.

4.1.4.2.2 Interview of Dennis Donovan On February 13, 1981, Dennis Donovan, Kaiser QC Inspector, was interviewed by NRC. He stated that on February 3,1981, Walter C. Dumford contacted him 19 -

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urveillance Report written against --ri::in; cfAbol4# on sgsuppres-about sion poo a (lgpIate.-r:themiQl. ::.- 6v, Donovdn# said he called Ken Shinkle, the QA Engineer responsible for th: _u;-___ ..m ymmi . -- J; r d _ d . ; :: d h&m-ef-tb 4"-id--* He said Shinkle told him It: --;tc-an NR3 Dp_nyo an stated he wrote the NR and instructed Dumford to place a hold tag on"tTe*pIate7 DonJvan said Dumford later returned to the trailer and told him that he had placed a hold tag on the plate, but craft personnel had ignored the tag and continued tensioning the plate. Donovan said he told Dumford to write a second NR against the continuation of work after a hold tag had been applied. Donovan stated he initialed the second report and called the NR clerk who assigned it CN 5412. The NR was forwarded directly to Inspection Supervisor Rex Baker for review.

Donovan said that on February 4, 1981, he, Baker, and Dumford were called into Phillip Gittings' office and Baker gave the original copy of the NR to Gittings. Donovan related that Gittings said, "This report is going to be voided because this is the kind of thing that starts investigations."

Donovan said that Gittings commented that inspectors should only write NRs against hardware problems and not against software problems, and ignoring a hold tag was a procedural (software) violation.

Donovan said he and Dumford explained that construction had ignored the hold tag, to which Gittings replied, "If I was in their position I would have done the same thing." Donovan said he responded that a hold tag was the strongest Q/. control mechanism on site and, if one was ignored, an NR should be written. Donovan said he and Baker told Gittings they disagreed with him and the meeting ended.

Donovan said that a few days later he called the NR controller concerning the disposition of CN-5412 and found that the number had been reissued to anatner NR. Donovan indicated that in his opinion, thi:  ::: :: :: - 7 11 :f Zo oce QA managemen not supportsag the inspection program at Zimmer. gg On February 13, 1981, Dennis Donovan provided a written sworn statement

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a copy of which is included as Exhibit 5.

4.1.4.2.3 Interview of Kenneth Shinkle On February 18, 1981, Kenneth Shinkle, Kaiser QA Engineer, was interviewed by NRC. He stated that on February 2, 1981 he received a telephone call from Dennis Donovan regarding a bent bolt on a suppression pool plate. Shinkle stated he told Donovan this should be documented on an NR and a hold tag should be placed on the plate to prevent tensioning. Shinkle stated he later that learned an NR was written and Walter C. Dumford had affixed a hold tag to the plate. Construction personnel subsequently ignored the

. tag. Shinkle said he also learned that a second NR was written by Dumford for violation of the hold tag which he initialed and forwarded to Rex Baker, Inspection Supervisor.

. DRAFT 8/15/81

,_ Shinkle stated he later that learned Phillip Gittings, after discussions with Dumford, Donovan, and Baker, did not enter the NR into the system. Shinkle said the report had been assigned a CN and the inspectors' supervisor had concurred it was a valid NR. Nevertheless, Gittings told Shinkle it was not going to be processed because "The whole thing has been blown out of proportion."

Shinkle stated in his opinion that Kaiser management does not support the QC program at Zimmer, construction dominates activity at the site, and QA is not independent of construction influence.

On February 18, 1981, Kenneth Shinkle provided a written sworn statement attesting to the preceding information, a copy of which is included as Exhibit 6.

4.1.4.2.4 Interview of Rex Baker On March 3, 1981, Rex Baker, Kaiser Inspection Supervisor, was interviewed by NRC. He stated that in early February 1981 he attended a meeting in Gittings' office with Dennis Donovan and Walter C. Dumford. He stated that during this meeting Dumford said construction had continued to tension a suppression pool plate after he had placed a hold tag on it. Baker stated he agreed Dumford was correct in writing the NR for the hold tag violation.

He said Gittings disagreed and stated in his opinion construction was right to continue tensioning the plate after a hold tag had been affixed to it.

Baker stated he did not know the disposition of the NR and that it was in Gittings' possession the last time he saw it.

4.1.4.2.5 Record Reviews On February 11, 1981, the NR Log was reviewed. The log indicated CN-5412 (E-2996, Revision 1) was written on February 2, 1981, for welds having lack of penetration. This entry does not reflect that CN-5412 had been assigned to another report written by inspector Dumford on February 3,1981, for violation of a hold tag. The Equipment Name or Process Entry column in the NR Log and the Specification column showed evidence that " white-out" was used to cover previous entries in the log. A copy of the NR Log page and 3 l NR E-2996, Revision 1, 4sAi ncluded as Exhibit 7.

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4.1.4.3 Findings and Conclusions e

Based on record reviews and interviews of personnel, it was established that CN-5412 was not entered into the Kaiser nonconformance reporting system.

4.1.5 Disposition of Nonconformance Report E-5108 4.1.5.1 Background Information On May 19, 1980, NR E-5108 was issued identifying a 4-in.-long pipe piece installed per DDC M-1108 in the residual heat removal (RHR) system for which material traceability could not be established. The NR also reports that Weld 80 located near this pipe piece was inside of a wall penetration N (M-13), in violation of licensee specifications. The NR was stamped " void" 1 -

. . DRAFT 8/15/81 other NRs) for the voiding was not fully implemented. It was also established that vendor welds were omitted from the NR without engineering justification.

4.1.9 Disposition of Nonconformance Report E-2836 4.1.9.1 Background Information On June 22, 1980, NR E-2836 was written by Inspection Supervisor Rex Baker after an audit by Nuclear Energy Services, Inc., indicated there was no final weld radiograph for Weld WS737 (service water system). There was a comment in the " Description of Nonconformance" section of the NR stating that the only radiograph available was an "information shot of the root layer" of the weld b.x L a f = f re M ? . The NR was dispositioned " accept as is" on October 24, 1980, because the weld data form (KEI-1) reported that the final weld had been radiographed and accepted by Kaiser personnel on April 5,1976.

This form indicated review and approval of the final radiograph by the Authorized Nuclear Inspector (ANI) on April 15, 1976. The " accept as is" disposition of NR E-2836 Vas initially rejected by the ANI on November 7, 1980; however, he approved the disposition on November 11, 1980, based on the KEI-I form entry showing that a final review of the film was performed by the ANI. The NR E-2836 was voided on November 10, 1980, with a comment "see Revision 1 for new disposition." There is a comment on the original NR which says " Void stamp in error - Rev. I cancelled when ANI accepted disposition on 11/11/80." NR E-2836, Revision 1, shows the same nonconform-ing item with the disposition to " accept as is" and the NR is signed by the appropriate members of the Material Review Board. Both the original NR and Revision 1 were closed on Novecher 13, 1980. Copies of NR E-2836 and E-2836, Revision 1, are included as Exhibit 20.

4.1.9.2 Investigation 4.1.9.2.1 Interview of Rex Baker On June 4,1981, Rex Baker, Kaiser Inspection Supervisor, was interviewed by NRC. He stated that on October 22, 1980, he initiated NR E-2836 after an audit found that there was no radiograph of completed Weld WS737. Baker stated he forwarded the NR to Arch Lanham, Kaiser Construction Department, who dispositioned the NR as " accept as is" based on an entry on the weld data form. The form indicates a final radiograph of this weld was performed on April 5, 1976, and was accepted by both a Kaiser welding engineer and the ANI on April 15, 1976. Baker said the NR was returned to him and he told

( Lanham the disposition of " accept as is" was contrary to ASME Code require-ments because there was no final radiograph of the weld. Baker said he told Lanham that an entry in a KEI-1 form was insufficient evidence that the weld had been radiographed.

Baker stated he is a qualified Level III Radiographer and that he had previously reviewed the Kaiser radiographic report and the accompanying film dated April 17, 1976. He said he told Lanham the film was an "information shot" of

! the root layer pass and not a radiograph of the final weld. Baker said Lanham l indicated the disposition was correct because the radiograph review block on i the KEI-1 form was checked and if QA did not have the film he could care less.

T

. . DRAFT 8/15/81 4.1.18.2.6 Record Reviews On June 6, 1981, Regina Rudd, Kaiser NR Controller, was contacted and asked to retrieve NRs CN-5476, CN-5477, and CN-5479 from the Kaiser Site Document Control Center. Rudd stated that she conducted a search of the open, closed, and voided nonconformance report files and could not locate the nonconformance reports assigned these numbers. Rudd provided a copy of the NR Log page reflecting that on February 27, 1981, NRs CN-5476, CN-5477, and CN-5479 were voided with a comment " Void-NR not issued." A copy of the NR Log page is included as Exhibit 33.

4.1.18.3 Findings and Conclusions Based on record review nd interviews of personnel it was established the NRs CN-5476, CN-5477 and N-5479 were not entered into the Kaiser nonconformance reporting system.

4.1.19 Summary Findings and Conclusions All of the allegations made by the QC inspectors were found to be correct.

It was found there were widespread irregularities in the system. Kaiser procedures permit voiding of a NR only if the NR was " written in error, duplicated, or the nonconforming conditions has been corrected. . .by con-struction." A computerized listing provided in July 1980 indicated that 1,031 NRs were voided, between January 1 and March 31, 1981, including those that were actually superseded rather than voided. Some were

, voided by the QA Manager, some by the QA Engineer-Records, and some by a clerk. A chronological breakdown of the number of voided NRs per month is included as Exhibit 34. The dispositions of a selected group of about 20 reports, either voided or alleged not to be in the reporting system, were reviewed and it was found that in 15 cases the NRs were either voided improperly, improperly dispositioned, closed in error, or the disposition was not fully implemented. In several cases, the justification used for voiding the NR was erroneous (e.g., it was found the QA Manager was voiding NRs which were not written in error). In some cases, the NRs had been reviewed by a Constru_ction Engineer and "reunrk" was ordered. vet the NR <

was later " voided "_[It was found that some of this activity occurred after _'

[_anNRCinspectiononDecember 2-3, 1980, in which the licensee and the Kaiser I _OA Manager were told that this activity was contrary to NRC reauiremants.

It was also established that, following the NRC inspection, the Kaiser QA '

lManagerhadonthreeoccasionsnotenteredNRs(CN-430 into the Kaiser nonconformance reporting system.

• This investigation also disclosed that an NR was improperly dispositioned as " accept as is" when " rework" was appropriate. In one case (NR E-2836),

the " accept as is" disposition was contrary to ASME Code requirements.

NRs that identified multiple nonconforming conditions were voided improperly with a comment that the NR was being " revised" or that "each deficiency would be issued on a separate NR" or items would be " reinspected." It was determined that nonconforming items were not reissued on separate NRs and were not re-inspected as stated on the NR at the time of voiding. It was also found that during " revisions" some nonconforming items were removed from NRs without justification.

- w --

DRAFT 8/15/81 T'e h procedure requires inspection of the baseplate bolt hole location, bolt G hole sizes, tolerances, eccentricity, and location of baseplate based on a single sample per plate. The CG&E QA Manager indicated in a telephone conversation that all bolt holes were being inspected and that the procedure was being revised to require inspection of all bolt holes. The licensee's past inspection program for examining bolt holes was consistent with the sample size used in IE Bulletin 79-02, " Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts."

4.2.2.2 FSAR Requirements The Zinuner FSAR, Table 3.8.2, commits to ANSI N45.2.5-1972 (Draft),

" Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construc-tion Phase of Nuclear Power Plants." Paragraph 5.3 of ANSI N45.2.5 states, in part, that burning of bolt holes is not permitted.

4.2.2.3 Licensee Position During a telephone conversation on July 23, 1981, the licensee stated that the materials affected by Instruction M-12 were not structural steel as defined by the American Institute of Steel Construction (AISC) Manual, Seventh Edition. Therefore, the licensee's position was that the require- \g ment not permitting burning of bolt holes does not apply. Y 4&

In a subsequent telephone conversation the CG&E QA Manager indicated that NRC appeared to be taking the no-burning requirement out of context. He indicated the paragraph containing the no-burning requirement refers to the condition of contact surfaces of friction types of connections, bolt hole alignment, and the correction of fabrication errors. ,

Thisisanunreshveditemandwillbereviewedduringasubsequent inspection (50-358/81 ).

4.2.4 Findings and Conclusions The acceptability of torch cutting bolt holes (the applicability of ANSI Standard N 45.2.5 prohibiting burning of bolt holes) is unresolved and will be reviewed during a subsequent inspection. The licensee's past inspection 02, program for examining

" Pipe Support Base Plantbolt holesUsing Designs was Concrete consistent with IE Bulletin Expansion 79(lts."

Anchor Bo The licensee is currently inspecting all bolt holes.

4.2.5 Items of Noncompliance No items of noncompliance were identified.

4.3 ASME Code Data Package Discrepancies 4.3.1 Allegation It was alleged that during system turnover, Quality Assurance Engineers, (QAEs) Wood and David Fox were reviewing documentation in ASME Code Data DRAFT 8/15/81 An SIS Report dated November 14, 1979, authored by the Authorized Nuclear Inspector (ANI) (Hartford Steam Boiler Inspection and Insurance Company) and the H. J. Kaiser response letter dated December 4, 1979, which responded to the audit, said an agreement was made that 20 of the un-verified socket welds would be selected at random to be radiographed to verify proper fitup. One of the 39 welds identified on Surveillance Report Nos. 2367, 2370, 2380, and 2412 was chosen to be radiographed.

No engineering justification was given to allow acceptance of all of the socket welds based on the sample of the 20 that were radiographed.

A second SIS Report from the ANI dated February 11, 1981 reported that additional welds were made after December 4, 1979 without verification of fitup. The ANI indicated that all the welds, for which the fitup was not verified after December 4,1979, should be radiographed.

The Region III inspector found no engineering justification for acceptance of the 400 questioned socket welds based on a radiographic examination of only 20 of the socket welds. The licensee had not implemented in process inspections to verify proper socket weld fitups during subsequent inspec-tions. This reflects the licensee took inadequate corrective action.

2. Data packages for the diesel generator system indicated that there was final visual inspection of all applicable welds.

3. A review of KEI-1 forms (weld data records) indicated that personnel - f

~

had transferred information written on KEI-2 forms (weld rod issue slipsf' / '(

to KEI-1 forms in order to u gt* g weld rod traceability, date of welding, -

and welder qualificatioka he Ef-2 form is a construction document used by the welders to obtain weld rods from the weld rod issue point.

There is no QC significance for the KEI-2 form, yet QC inspectors and document reviewers were allowed to transfer weld rod heat numbers entered on the KEI-2 form by the storage personnel to the KEI-1 form (QC weld record). This can only be done at the time and place of the weld activity.

Therefore, any information transferred from the KEI-2 form to any QC document after the time of or away from the weld activity would not be creditable QC verification.

In addition, Region III inspectors noted a considerable number of dis-crepancies between the weld data records (KEI-1 forms) and the weld rod issue forms (KEI-2 forms). The records showed discrepancies between the heat numbers for the weld rod used, identification of the welder performing the particular weld, and dates the welds were made. It was found that document reviewers were resolving these discrepancies by altering KEI-1 forms to match the KEI-2 forms. In effect, the QC records, I which supposedly provide independent verification, were being changed to conform with Construction Department records. Alterations appeared to be arbitrary in that some of the documentation for welds within a certain line changed, but no changes were made for other welds of identical circumstances. The following are examples of the altered records:

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B oI+ v of' p erp e..d a a l w - T e .,0 p s e rn), . M- c/ LP CN - 5 Y/2 ye5fccred

z. E.-5/68 QureeW Ri 4 " lno sj2c pt cc ,JDC Al- //e 8 is', .MMY - m 9,a,-?is/

+n ce.g,LiiG

? vJeM 20 in:ik L w H p i s d J A . 0 v - 1 3) (o :, < . a / e . o / c Q ca 'tsef 8 Oct a ,c', J  %:()ea, ze i n y up - :ey ,. aid ,,,o c p, % 9 4 ~

at w . n . . !< , e .J Mo

y:/ca..

& cu' 99 sr- Y9 57, 4920, 99xt 6xes) su, .

B:

v)c 0. d.c[ic le>>cle r m pij e re. ppedt i, i D/S & A.

UMd3 h zvc hav re,c uti c) ?

( S. E -2466 DNiels R2 12 y pupe, h>,,g.en /  :. :c M .-) aclicij ac/::

Q E- 2 734. RW ,TPG, GS A

% $4.I rz2ispr2p). Sn- Weld !J)T 737 Ra};o  : . . !..

Ne!)gw7 a,k hm 4. Jc./

wef ,ns:

@ L= -/ 777 w  ?. Z?

', kid en. psyz f f %l Wf w/o G/? h co ine s. .-b.:>:

No weM n) irra e r/p ,',- larld I'/_rA2

_ g. c n- g/ 2 2 ( e u.mg) Ba,,.ef p. -

Flex *b!c. euley ceA:g d e n,daH ii, Cnd.,Sug .,c&f7

& E-&E 33 f E--2237 ,) My!

au) P.2 Wald v)5 (,2 6P h Ic. fi/u,a ,a;p, m W>yiir/, f*

udc l. I MeerbNf dwi:,,ac .h /6 -

S ~ t;,. e d!~ w Id Q Nxc - 600 / (He. k'E2 'n.m Le-r) gw R%

N n ,c e. {< r >. o's y u U r m d<y //r6/,a pri corr!

EIech o Le. ta=va exm4/ap yy"

@ E - I&4 / f' E -/6 /s2 rw /? ?

N w c .m f e ~ <:>; a.eiA r er,. p >lc- r u ,pi>. , ~ A ,., ~ ,.s b, +!+ d . q*u~e)l pm oa >n die ryr yon, l .

& E-2 794 RfD, TPG, G G, PA 6 T- Q v.c >.ehcv 0 0 7 - e o & G , o n *cs h / ,?<)

/E3 r

13 CN - y399 Barret 23 H ~ cmk >. . %; e Jechke/ c Lic , 6 syr,,c=h.7ers ,'., ,$e<x 2.',6

@ E-219/ glo,TPG, GG /B 3 Cm:wm Lk le ire ri? si a>eklll)R-r?2 pofkreerUc tr. C//- S974 J CY77J CY?f ..  : -

.R 3

//c)er:>tl ro.oo, o c e'>s difthe or ru u ho-U! Y .Y : C / fe'l [b. .

W el b & .7 , [3', f' 3 n d yac.- ppE //w}.v' &A c': : .. - -

(1)ellr wen. cd of sad te we/h).

- 7: Do - Wu i

sy y /. 4 pipe we!.dr o~ ide,,lifid one riciioyrapAc)

(

G-vs c.

ba.a h ox rifles R. 4 ppu o- iden/h)

Don cuVoul

3. (, :ocke} welds v,,,. ide,Mid v-e rzJio;,n,a4cd

% A 'n. e.c,,,lc , , ~,, c Rapadz /m secM %/

n c *II.I.4 Key, RFID, Pa0 N*

Ilef a ha<danoc prelle.n.

+ h..u*41s ep.s (taek.ab) r< ca.t>:t;/,. ,,/ ,,, pga en

• 4. I . t. Kay,er:v,at is careehl by.lic enrea ,

rn 44.1.7 us .de!:  ?

N. p .L!.. r. Lice.g. h.rs cer > <.,'-! p - . .

T w on 41.0 Dwiel: HM 4h'u)u we j> reb'er.

x, .x, -s <,,,, ,1 Ja h.  ? "d *,:r=",~ ~ , "

.~.

• 4. l . 7 snqe,Fr:0,6+ (deh.- aa) M'l radby v.ud e,p w'

- a+) . /Mr u 'c f 9 4 .1.10 Pal p.,s (I.:U u :..h S.-kd A ~ >~rI'l .< p y < t. s A - = '

t- @ 4.1,1l e n, r-4 11e :N// een r'. . LIA% -+ n :.</a.'c re< unCca .,

$ o,. 6 4.l.12. P+ t!* .= ~.. .~ Ly j u :.

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11)cid: cu! ouis a .. re tec!.Js.) .

Do - r.e y/r/

/. 4 pipe aieh].c o.- ide,,/i(;d one radiops,:>4c)

I D ,, c. dio.< b : *. /.: /cJ R. d f(oe:

v: iden.M_ ./

un.c- c w 4 ou+ .

3. 4 . roc A / as/d.r o,- idenWid . . . -

we o dio , w p / d s m . c c, .,G, , ~ . y . c. n , s L s . c n 4. /

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' U.S. !:r' IT.AR REGill.ATORY COT 1TSSION REGION 11I UtilGOING TRA!;S!!!SSION SERVICE REQD.57

'tc .3-R97y_ r:nr i.c, or rages _] .

T. E ALsLw s < N ,o __

f ~' : ___

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gd __ __ k i dy, o 2fm er j aq qh j , .h, k -

D"cripe. ion _

g d i kc6_c YWQ t t *Ihr h. SW._. _..

FOR D/,C USE F/W Triwers .

Rapifax ,

11 St rect '

311 &XT tr ,_,,_. _

12;DB FIS l'hilli ps ,,

i Coimne rt i al c.ilver Springs

(*rlills t e i 1.amlua Time Started /[M O Time Completed ,,,

Renien I _

't rans. Time ker. inn 11 ~ '( Act.u.s1 tiln.)

Operator ,_

Region l \' _ , , _

Region V _

Hef.ident at _

Other (De .i gnat e - inc tide f ax number. )

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1. XV. Bed Welds - Bristol /KEI

2. II. Bristol QA Program Not Independent

3. VIII. Bristol /KEI traceability

4. V. KEI 30-day SR

5. IX. KEI painted welds

6. V. Kellogg/KEI - Radiography

7. XV. KEI - void NRs

8. III. Cable Separation

9. X. Cable Separation

10. III. S&L Cable Tray Loading

11. XVI. CG&E Inadequate Corrective Action - CG&E Audits - S&L Calculations

12. XVIII. CG&E No audits of S&L NR.

13. III. KEI - KEI-1 deletions

14. X. KEI - Socket weld & (trap?)

15. XV. KEI - I Beams Installed /Not designed

16. X. KEI - KEI-2 being used

17. VI. S&L - DOC document control

18. III. S&L FSAR deviation in weld ?

4 i

O o U.S. N1' CLEAR REGULATORY COTilSSION REGION III OUTGOING TRANSHISSION SERVICE PIQUEST StrsH To R.F. N eim Ad AsA P lk,_.

Date ff

,$ l'f .g j,,._ Nunber of Pages Sheet I

T t' (';ar'H : .bobe&T NesShMAAL,... ._

F re: T6AA dol ELS_ [,okwT (dMtAHCK f be bemek I

De:,o ription ____hp.EPts eF Cbasce.n.31 iA3 ~ M As. M. T i M Aff R. 144770A).

E/W Towers FOR D/C USE 11 St reet MariiTax

• ';nn 3M EXT fr .

Phillipr. ITS . _ _.

Silver Springs Comrcer cial ,,

0illste) 1.andue Time Started ,

Recion 1 , _ _ , , ,, _ _

Time Completed ,,,, ,

Region 11 Trans. Time

(. Actual Hin.)

Rgteu .TET ' /.- - -

Region IV ,, , ,

Operator ,_

Hegion Y _

[lenident at - . . . .

Other (Designate - include fix nuIr.5Tr.')

TEDRUARY 19R1

_m: it e q -!, n;n v --%,. u e n a w =.a c w,. - ..y a n g,i;;;g: , gam. . .;;.yp r: .,z,.: g;; m m

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1 j tascos ursplayen unose. cur,iu g %nn i.ac.co f profit _vy gross penostrY.

J' bra.a 3 h App. B , C,iler..o jE (Aleoe drh g Adenu) i i

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pn 'Paograw skas.t. provice, coureet, eve.r

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0). Tracea b e li of .) NEAT Nkm h(S fd SkrucYn rat. be4M5 bMS M87 bECM MdioTAt o ED.

b') beau. huudred fe,A of beams has beca m ~== p <ee.eived f, e e,o un4ppreited  ; ,

vecoot Aco can por be aceeimfed Ear i  ?

o.s +o tobexe sosi-a u.s o on. etbr dispos,bd. l

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near cumbecs oo~ sea o c) 77 ace.abih 43of

%e p, p r ae., &r +ke. b ie s e ,_ Q e o e ra.6 e e.s. t i

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H .J. Ko.r s e.< list- of accephtble' heat a;a.<bers. l e7 b] t.o ved heat. numb.<s , be.ca.use hea.+  !

pum bees axe be.iu3 tmesfered fo fke-KE.1-1 For m fram ker - 2. 's b 3 IMdiveduat s ofkex hp +ke. Qd. Lspee.rog-tako inspee_ fed the teeto.

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r i I g; A L c uc.h grem e We h3 m was de.st4cto '

t.ohrfe M$

{ aoo aosrsu_so t g s t o e. A Soc.tude.s greco Class 1E cables The.

l gree.u  %.3

& tahtte_ 4vng couraios h e./r.c h t + e-ll1 aco ago gelle,ta[ nobife e o.ssocirreb cates.

i; Cwrug fu iocm.so, AMixB, Cri4eriau IE (Desiso Courmat) s.kau. amune %e elesa.,o 6ses a.re.

L h mures f-

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g Freu. ne. eud hg patrTs u.p bikt-coorn.os_ SAusi v. . Ttao blue cabb sa fle_

caw. Wi$ room have been pulled toro E. a c3reco 4mg r.ecxion leadiu3 u.p +o Re_ s coornet Rese.

b) Yellbiof tohtb cable c.am4 tog our ei condu.tk aoo s=pendeel oya ti-de.t 3 .,,uekes f abee

h. cab \es no a We b3. (Io cakte spendt$

u.eQ 4 ro u ,osweis ao % =(Atso meno am%*oczm) mtded whde eaw

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d) h we cable er.pael.ie>c concerns. e I

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?1 4 Lacx. of actecuat cournei.s to decawer destr.id j1

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s Docket No. 50-358 Construction Permit No. CPPR-88 EA 82-12 Cincinnati Gas and Electric Company ATTN: Mr. W. H. Dickhoner President 139 East 4th Street Cincinnati, OH 45201 Gentlemen: This refers to the investigation conducted by Region III during the period January 12 to October 9,1981, of construction activities at the Wm. H. Zimmer Nuclear Power Station. The details of that investigation are described in Region III investigation report No. 50-358/81-13. The violations described in Appendix A to this letter are cross-referenced to that report in accordance with Appendix E to this letter. The investigation was initiated as a result of allegations made to the NRC by a Quality Control Inspector who formerly worked at the Zimmer site and by the Government Accountability Project of the Institute for Policy Studies (a non-governmental agency) on behalf of Mr. Thomas Applegate. The results of the continuing investigation reveal a widespread breakdown of your quality assurance program as evidenced by numerous examples of noncompliance with twelve of the eighteen different criteria for a quality assurance program as set forth in 10 CFR 50, Appendix B. The cause of the breakdown was your failure to exercise adequate oversight and control of your principal contractors to whom you had delegated the work of establishing and executing quality assurance programs. You thereby failed to fulfill your vital responsibility as described in Criterion I of 10 CFR 50, Appendix B, to assure the execution of a quality assurance program. The potential safety concern of your quality assurance program breakdown was discussed during an enforcement conference at our Region III office in Glen Ellyn, Illinois, on August 5, 1981, attended by you and members of your staff and the NRC Region III staff. Two of the violations (Items A and B of Appendix A of this letter) are of particular concern to us because of the very essential role they play in the execution of an effective quality assurance program. These two violations relate to false records and to harassment / intimidation of quality control inspectors. With regard to false records, the examples we identified raise serious questions as to the accuracy of quality records at the site. Our concern in this area served as a major factor in requiring the conduct of a confirmation program to be completed by you to furnish evidence of plant quality. CERTIFIED MAIL RETURN RECEIPT REQUESTEP

9

   .         Cincinnati Gas and Electric                             Company Because the NRC inspection program is a sampling program, the importance of accurate quality records cannot be overemphasized. Accordingly, we have addressed this matter as a separate violation and assessed a separate civil penalty for it.

With regard to harassment / intimidation of quality control inspectors, we have also addressed this matter as a separate violation and assessed a separate civil penalty for it. We determined that your construction contractor took some action to stop the water dousing of quality control ~ inspectors; however, those actions did not stop the activity. Harassment / intimidation of quality control inspectors is clearly a barrier to effective implementation of a quality assurance program and results in loss of the organizational independence described in Criterion I of 10 CFR 50, Appendix B. The importance of this matter is reflected in the recent amendment (Public Law 96-295, June 30, 1980) to the Atomic Energy Act of 1954, which added Section 235 relating to protection of nuclear inspectors such as your quality control inspectors. The impact of the identified quality assurance deficiencies on the actual construction has yet to be determined. Limited independent measurements were performed by the NRC in selected areas of concern in an attempt to characterize the actual safety significance of these deficiencies. Although a few problems 'z) requiring corrective action were identified (i.e., four unacceptably installed pipe hangers), the majority of the NRC independent measurements did not dis-close hardware problems. However, recognizing that significant construction deficiencies could have resulted from the quality assurance problems identified. during this investigation, the NRC has required the establishment of a compre-hensive quality confirmation program to determine the quality of plant systems important to nuclear safety. The NRC will confirm the adequacy of the program and may make additional independent verifications. Deficiencies identified by these programs will require resolution prior to issuance of an Operating License. Notwithstanding the fact that serious construction deficiencies have not been identified, in order to emphasize the need for licensees to have complete and accurate records, to maintain a work atmosphere where quality assurance personnel are not harassed or intimidated, and to assure implementation of an effective quality assurance program which identifies and corrects construction deficiencies, we propose to impose civil penalties in the cumulative amount of Two Hundred Thousand Dollars for the matters in the Notice of Violation. We expect that this penalty will result in an adequate deterrent against future siatlar violations by you and other licensees of plants under construction. Some of the examples in the Notice of Violation occurred subsequent to the issuance of the revised enforcement policy and some prior to that time. In arriving at the amount of the proposed civil penalties we have exercised dis-cretion, considered changes in the enforcement policy and considered the amount of the civil penalties that have been issued to licensees of other plants under construction as well as the number of examples found of each violation and when they occurred. We have for convenience and clarity categorized the items in the Notice of Violation at the Severity Levels described in accordance with the Interim Enforcement Policy published in the Federal Register, 45 FR 66754 (October 7, 1980).

 ,       Cincinnati Gas and Electric                        Company             ,

The results of this investigation and our review of your 10 CFR 50, Appendix B, noncompliance history reveal an additional matter which is of significant concern to us. This matter concerns inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979 with thirteen of the eighteen different criteria of Appendix B to 10 CFR 50. During our Systematic Assessment of Licensee Performance review on December 16, 1980, we expressed concern with your relatively poor performance in this area. This poor history of compliance with 10 CFR 50, Appendix B, when considered with the recent findings of the investigation indicates that your corrective actions only addressed individual problems and not underlying programmatic causal factors. Consequently, we request that you review your history of noncompliance with 10 CFR 50, Appendix B, for the past two years and in your response to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors related to the noncompliances. You are required to respond to the Notice of Violation and in preparing your response you should follow the instructions in Appendix A. You should give particular attention to those actions designed to assure continuing compliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce-ment action is appropriate. 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 enclosure will be placed in the NRC Public Document Room. The responses directed by this letter and the enclosed Appendix A are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, Richard C. DeYoung, Director Office of Inspection and Enforcement

Enclosures:

1. Appendix A - Notice of Violation and Proposed Imposition of Civil Penalties

2. Appendix B - Cross

References:

Noncompliances to Report Details cc: See next page

   '       Cincinnati Gas and Electric                           Company 1

cc w/ encl: E. A. Borgmann, Senior Vice President, Engineering Services and Electric Production J. R. Schott, Plant Superintendent DNB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Power Siting Commission Citizens Against a Radioactive Environment Helen W. Evans, State of Ohio Thomas Applegate Louis Clark, Director, GAP Institute for Policy Studies 4 1 -

                                               .o         -

  ,                                                Appendix A NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Cincinnati Gas and Electric Company                    Docket No. 50-358 Wh. H. Zimmer Nuclear Power Station                    Construction Permit No. CPPR-88 i

EA 82-12 As a result of the investigation conducted at the Wm. H. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - October 9, 1981, the violations listed below with multiple examples were identified. The numerous examples of the violations demonstrate your failure to exercise adequate oversight and control of your principal contractors, to whom you had delegated the work of estab-lishing and executing quality assurance programs, and thereby fulfill your responsibility of assuring the effective execution of a quality assurance program. Your failure manifested itself in a widespread breakdown in the implementation of your quality assurance program and caused the NRC to require an extensive quality confirmation program to provide confidence that safety-related structures, systems, and components will perform satisfactorily in service. Included in the breakdown were findings we consider to be particu-larly disturbing relating to false records and harassment and intimidation of quality control inspectors. Because of the significance of not having complete and accurate records, not maintaining a work atmosphere where quality assurance personnel are not harassed or intimidated, and not assuring implementation of an effective quality assurance program which identifies and corrects construction defi-ciencies, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, and 10 CFR 2.205 in the amounts set forth for the violations listed below. A. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records i shall be maintained to furnish evidence of activities affecting quality." Contrary to the above, records were identified that did not furnish evidence of activities affecting quality in that they were false. Examples of false records are as follows:

1. Isometric drawings, weld inspection records, or other records did not furnish evidence of the actual piping components installed in the 11 pipelines in the diesel generator cooling water, starting air and fuel oil systems, in that the heat numbers recorded on the drawings or weld inspection records did not match the heat numbers or color coding marked on the respective components. The 11 pipe-lines were:

      . Appendix A (Continued)                                           IDG28AB1              1DGC5AA3/4           IDG28AE1 IDG27AB1              1DGF6AA1/2           1DG25AC2 IDG01AB1              1DGC5BA3/4           IDG11AA3 IDGF2AA1/2            1DGF6BA1/2

2. The Kaiser Nonconformance Reporting Log did not reflect all reports initiated as evidenced by the following:

a. The original entry for a report (CN-4309) initiated by a QC Inspector on January 7,1981, relating to deficient weld fit-up was obliterated by the use of white correction fluid and there was no other record of this report in the Noncompliance Report (NR) system.

b. The original entry for a report (CN-5412) initiated by a QC Inspector on February 3,1981, and relating to violation of a hold tag was obliterated by the use of white correction fluid and there was no other record of this report in the NR system.

c. A report (NRC-0001) initiated by a QC Inspector on February 11, 1981, relating to excessive weld weave was not assigned a number and there was no other record of this report in the NR system.

3. Written statements as to planned actions which were made to justify voiding reports E-1661 (voided 11/11/80), E-1662 (voided 11/11/80),

and E-2466 (voided 6/30/80) were not taken. '

4. Written statements relating to the availability of records which were made to just'ify voiding reports E-1777 (voided 4/30/79) and E-5108 (voided 6/20/80) were false.

5. Reports CN-5476, CN-5477, and CN-5479 were knowingly improperly voided (2/27/81) and copies deleted from the NR system at the direction of the Kaiser QA Manager.

l This is a Severity Level III violation (Supplement II). l , (Civil Penalty - $50,000). l l B. 10 CFR 50, Appendix B, Criterion I states, in part, "The persons... j performing quality assurance functions shall have sufficient. . . organ-izational freedom to identify quality problems... including sufficient independence from cost and schedule." The Wm. H. Zimmer QA Manual, Section 1.2.3 describes QC Inspectors as members of QAD (Quality Assurance Division) and Section 1.2.4 l states, in part, "QAD has been assigned sufficient... organizational freedom to identify quality problems..." l I

Appendix A (Continued) Contrary to the above, QC Inspectors did not have sufficient freedom to identify quality problems and were not sufficiently independent from cost and schedule. The results of interviews indicate that some QC Inspectors were: (a) harassed by construction workers and super-visors; (b) not always supported by QC management; and (c) intimidated. The following are examples of insufficient freedom of QC Inspectors, including insufficient freedom from cost and schedule, which occurred between Summer 1978 and March 11, 1981:

1. Five QC Inspectors interviewed executed signed sworn statements wherein they claimed they were doused with water (while engaged in the performance of inspection duties) by construction personnel.

Two other QC Inspectors made similar statements.

2. A QC Inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were re-assigned by QC management because of complaints by construction personnel.

3. Two QC Inspectors executed signed sworn statements wherein they claimed they had been harassed by being searched for alcohcl by security personnel at the request of construction supervisory personnel. One other QC Inspector made a similar statement.

4. A QC Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after con-struction personnel complained he had used a magnifying glass to visually inspect a weld when in fact he was using a mirror and either device was an acceptable tool.

5. A QC Inspector executed a signed sworn statement wherein he claimed he was struck by a stream of water from a fire extin-guisher while performing an inspection.

6. A QC Inspector executed a signed sworn statement wherein he claimed he was threatened with bodily harm by a construction person if he did not pass a weld.

7. A Lead QC Inspector executed a signed swcra statement wherein he claimed:

a. He was accused by the QA Manager for holding up a concrete pour when in fact the delay was caused by the concrete trucks being late.

b. Construction management frequently approached QC Inspectors and challenged their inspection findings and questioned their judgement.

Appendix A (Continued) c. The QA Hanager said things like, "our job here is to accept, not reject, and we are here to get this plant built."

8. A Lead QC Inspector executed a signed sworn statement wherein he claimed he was relieved of his inspection duties because he con-tinued to submit legitimate nonconformance reports over construc-tion management objections for deficient welds on pipe support hangers. He also stated that QA management had previously told QC Inspectors to not write anything to make Kaiser look bad.

9. A QC Inspector executed a signed sworn statement wherein he claimed he was told by QA management to accept inspected items that were unacceptable.

This is a Severity Level III violation (Supplement II). (Civil Penalty - $50,000). C. 10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear power plants to document, by written policies, pro-cedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents. Centrary to the above, Cincinnati Gas and Electric Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as l evidenced by the following examples: I i

1. 10 CFR 50, Appendix B, Criterion XV states, in part, "Noncon-forming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."

Kaiser Procedure QACMI G-4, " Nonconforming Material Control," provides detailed instructions for the review and disposition of reports (Nonconformance Reports) of nonconforming items. I Contrary to the provisions of QACMI G-4, the sample of NRs reviewed indicate significant deficiencies with the nonconformance reporting system in the areas of voiding of reports, not entering reports into the system, improper dispositionio.g of reports, and incomplete report files. The deficiencies identified were as follows:

a. Three NRs related to documentation deficiencies had been improperly voided in that records used to justify the voiding did not provide evidence necessary for proper voiding.

l (NR-E-2191 voided 2/22/80, NR-E-2233 voided 1/24/80, NR-E-2237 voided 12/19/79)

                            ~'

Appendix A (Continued) b. One NR related to nondestructive examination of a T-quencher weld had been erroneously closed (not voided) by adminis-trative error. (NR-E-2996 closed 3/17/81)

c. Two NRs related to nondestructive examinations of service water system welds had been incorrectly dispositioned (not voided).

(NR-E-2836 closed 11/13/80, NR-E-2596 closed 4/16/80)

d. Five reports had been voided by personnel other than the QA Manager. (CN-5122 voided 1/2/81, CN-5476 voided 2/27/81, CN-5477 voided 2/27/81, CN-5479 voided 2/27/81, CN-4389 voided 12/12/80)

e. In one case during revisions of the report some nonconforming items were removed from a NR without adequate justification.

(NR-E-2466 voided 6/30/80)

f. The following nine reports had not been issued NR numbers and/or copies of the reports had not been retained in the Site Document Center:

CN-4389 CN-4957 CN-4930 CN-4958 CN-4931 CN-4959 CN-4955 CN-5122 CN-4956

2. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations... and nonconformance are promptly identified and corrected."

The Wm. H. Zimmer QA Manual, Section.15.2.2 states, "HJK is responsible for identifying and reporting nonconformances in receiving inspection, construction, or testing activities which are delegated to HJK Quality Assurance Procedures to assure that nonconforming items are conspicuously marked to prevent their inadvertent use or installation." AWS Code D1.1-1972, Section 3 and 8.1.5 define requirements for weld quality and address slag, weld profiles, blowholes, porosity, and undercut. AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch minimum radius for re-entrant corners. Contrary to the above, the following nonconforming conditions were not identified and corrected:

a. Based on an inspection of the 25 structural hanger support beams described in Item C.4 below:

Appendix A (Continued) (1) Several welds on nine beams did not conform with AWS D1.1-1972 requirements in that they contained unaccept-able slag, weld profiles, blowholes, porosity, and/or undercut. (2) Five beams did not conform with AISC requirements in that the re-entrant corners were notched, creating potential stress risers, instead of being rounded with required radii. (3) Four beams, two of which had unacceptable welds as described in Item C.2.a.(1) above, did not conform with design documents in that they were not specified on any design document.

b. Based on an inspection of about 100 cable tray hangers in the Cable Spreading Room, four did not conform with AWS DI.1 1972 requirements in that the welds contained unaccept-able slag, weld profiles, blowholes, porosity, and/or undercut.

3. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations...and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."

The Wm. H. Zimmer QA Manual, Section 16.5 states, in part,

            " Vendors, contractors, and subcontractors are required to determine cause and corrective action to prevent recurrence of errors which could result in significant conditions adverse to quality."

ASME Code, Section III-1971 Edition, Article NB-3661.5(b) states, in part, ". . .a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before welding." ASME Code, Section III-1971 Edition , Winter 1972 Addenda, Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, NA-4451, NB-4230, and NB-3661.5(b) require, in part, in process inspections for pipe fitup, weld procedure, weld filler metal traceability, and welder qualifications... Contrary to the above, the NRC inspectors identified the following nonconforming conditions that had not been corrected and action had not been taken to preclude their repetition: l

Appendix A (Continued) a. Licensee records indicate that the socket engagement (fitup) for more than 439 socket welds was not verified in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b) and the condition was not corrected in that the corrective acticn was not commensurate with the ASME Code. The welds date back to 1979.

b. Licensee records indicate that the in-process inspections for more than 22 welds in the diesel generator cooling water, starting air, and fuel oil piping systems were not performed by Kaiser in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b), et al., and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1978.

c. Five licensee QA audits (audit performed 8/8-9/74 - no number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of Sargent & Lundy identified repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications and action was not taken to preclude repetition.

4. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials... These measures shall assure that identification of the item is maintained..."

The W m . H. Zimmer QA Manual, Section 8.2 states, in part, "H. J. Kaiser Company procedures provide that within the H. J. Kaiser Company jurisdiction the identification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other appropriate means. This identification may be on the item or on records traceable to the item. The identification is maintained through-i out fabrication, erection, and installation. The identification is maintained and usable in the operation and maintenance program." Contrary to the above, based on an inspection by NRC inspectors

in March 1981 of approximately 25 structural hanger support beams located in the Blue Switchgear Room and the Cable Spreading Room, the identification of the material in nine of those beams was not maintained to enable verification of quality.

5. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory require-ments and the design basis...are translated into... drawings..."

The Wm. H. Zimmer FSAR, Section 8, provides the design basis for electrical cable separation that includes the following:

Appendix A (Continued) Associated cables (Green / White, Blue / White, and Yellow / White) from more than one Division cannot be routed in the same raceway. (FSAR Paragraph 8.3.1.13.2) Vertical separation of three feet or more must be maintained between cables from different Divisions. (FSAR Paragraph 8.3.1.11.2.1.d) Instrument (low-level signal) cables cannot be routed in the same raceway with power and control cables. (FSAR Paragraph 8.3.1.12.1.3) The W m . H. Zimmer QA Manual, Section 3.3.2. states, " Composite... drawings are prepared, translating the design concepts into layouts of structures, systems, and components necessary for the construction of the plant." Contrary to the above, as of March 1981, the FSAR design basis for electrical cable separation had not been translated into drawings and this resulted in the following cable installation deficiencies in the Cable Spreading Room:

a. Associated Cable (Yellow / White) No. RE053 for Division 1 was routed in the same raceway (two-inch conduit and Class IE Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2. Also, Associated Cable No. RE053 was routed so that in places there was only a vertical separation of four inches between it and cables in Blue Tray No. 2072C for Division 2.

b. Instrument Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Asso-

' ciated Control Cables (Yellow / White and Blue / White) for Divisions 1 and 2. This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3029K) inside a White Control Tray (No. 4638B).

c. Many Associated Cables from all three Divisions were routed in the same raceway (White Tray No. 4080K) including Cable (Blue / White) No. TI192, Cable (Yellow / White) No. RR781, and Cable (Green / White) No. TI816.

d. Associated Cables (Yellow / White) No. TI942 and No. TI943 for Division I were routed in the same raceway (White Tray Riser No. RK4627) as Associated Cables (Blue / White) No. TI808 and No. TI760 for Division 2.

e. Many Associated Cables (Yellow / White) for Division I were routed in the same raceway (White Tray Riser No. 4139) as Associated Caoles (Blue / White) for Division 2.

Appendix A (Continued) - 9-1

6. 10 CFR 50, Appendix B, Criterion III states, in part, " Design control measures shall be applied to...the delineation of acceptance criteria for inspections and tests."

The W'.s H. Zimmer QA Manual, Section 3.13.1 states, in part,

                                 " Design control acasures.also apply to delineation of acceptable criteria for inspections and tests."

Weld acceptance criteria are required by the ASME Code, Section III-1971 Edition and the AWS DI.1-1972 Code. Contrary to the above:

a. The weld acceptance criteria used by H. J. Kaiser Company from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were deleted.

i

b. The acceptance criteria for Weld 55H (isometric drawing PSK-1WS-32) performed on Service Water System Line No.

1WS17A18 by H. J. Kaiser Company in November 1979 were not applied in that they were designated as not applicable.

7. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test results shall be evaluated to assure that test requirements have been satisfied."

The Wm. H. Zimmer QA Manual, Section 11.1 states, in part, " Test programs to assare that essential components, systems, and struc-tures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construction site." ASME Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness. . ." M. W. Kellogg Co. (pipe manufacturer and agency performing the prefabricated pipe weld radiography in question) Radiographic I Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "Wherever required, shims shall be used to produce a total thickness under t,he penetrameter equal to the nominal thickness of the base metal plus the height of the crown or reinforcement." i Contrary to the above, the licensee's review of 187 radiographs did not assure that test requirements were satisfied in that the licensee failed to detect that the penetrameter shimming was insufficient to satisfy the requirements of M. W. Kellogg Procedure

  - - - ,     y ---

pe- - -

Appendix A (Continued) No. ES-414 or the ASME Code. This deficiency was identified during the NRC review of approximately 800 radiographs involving 206 pre-fabricated pipe welds in such systems as main team, feedwater, and diesel generator support systems.

8. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design control] shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.. .The design control measures shall provide for verifying or checking the adequacy of design."

The Wm. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are specified and included in design documents." The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled." The W m . H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verificat.on reviews are performed. . . ." The Wm. H. Zimmer FSAR Section 8.3.3.1.1 states that cable ampacity is based on IPCEA Publication No. P-46-426. An additional limita-tion on cable ampacity as stated in Section 8.3.3.1.3 is that "the summation of the cross-sectional areas of the cables shall not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross-sectional area in any case." AWS D1.1-1972 Code, Section 3.6.4, states, "For building and tubular structures, undercut shall be no more than 0.01 inch deep when its direction is transverse to primary tensile stress in the part that is undercut, nor more than 1/32 inch for all other situations." 1 Contrary to the above:

a. As of March 1981, design control measures had not been l established to assure that deviations from design conditions (quality standards) identified by Sargent & Lundy engineers were controlled. For example, Sargent & Lundy noted on a

[ calculation sheet dated December 27, 1979, that the design thermal loading for two power cables (VC016 and VC073) in Yellow Tray No. 1057A tould allow the cables to be thermally ( overloaded and no program existed to control those design l deviations. l l l { l

i i . 1 Appendix A (Continued) b. As of March 1981, design control measures had not been l established by Sargent & Lundy to provide for verifying or i checking the adequacy of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays. l

c. As of March 1981, the cable ampacity design by Sargent &

Lundy was not based on IPCEA P-46-426 and the FSAR limit on cross-sectional area.

d. As of March 1981, the design allowable undercut on cable tray hanger welds was not based on AWS D1.1-1972 Code (appro-priate quality standard). The design undercut was instead based on Sargent & Lundy Specification H-2713, Supplement 7, Sargent & Lundy Standard EB-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph 5.2.9, allowed up to 1/16 inch undercut.

9. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be estab-lished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

l The W'. m H. Zimmer QA Manual, Section 10.1.2 states, in part,

                                   " Inspections are performed in accordance with written procedures which include requirements for check 'ists and o'ther appropriate documentation of the inspections and tests performed."

AWS D1.1-1972 Code, Section 3.10.1, requires work to be completed and accepted before painting. i Contrary to the above: ! a. As of March 1981, a QC inspection program had not been estab-l lished to require verification of separation of electrical r cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RIl03 and CM111 that had been routed into Tray Riser (Green) No. 3025A, which extended from Tray (Blue) No. 2077A in the Cable Spreading Room to the Control Room.

b. The programs established for in process and final inspections of welds on 180 cable tray hangers located in the Cable Spreading Room were not executed as required in the AWS D1.1-1972 Code. Specifically, the final weld inspections were made after the welds were painted (Galvanox).

                                                                                             .e p                       ,m     e, -.           - - - - -

Appendix A (Continued) 10. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." The Wm. H. Zimmer QA Manual, Section 5.1 states, " Construction, fabrication, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures, and drawings which prescribe acceptable methods of carrying out those activities." The W'. m H. Zimmer QA Manual, Section 3.12 states, in part, " Design changes... including field changes, are subject to design change control measures commensurate with those applied to the original design." Contrary to the above:

a. Kaiser Procedure QACMI G-14, " Surveillance Reports," (SR) was not appropriate to the circumstances in that it allowed in-process nonconformances which constitute field changes to be dispositioned within 30 days without being subjected to design control measures commensurate with those applied to the original design. Examples of nonconformances so dispositioned were identified in SRs F-2899, F-2903, and F-2914.

b. Kaiser Procedure QACMI G-14 was not followed in that SRs F-2909, F-3070, F-3071, F-3072, F-3073, F-3074, F-3075, F-3076, F-3083, and F-7019 were not dispositioned within 30 days and were not transferred to Nonconformance Reports as required by Paragraph 5 of QACMI G-14.

l l 11. 10 CFR 50, Appendix B, Criterion VII states, in part, "The j effectiveness of the control of quality by contractors and I subcontractors shall be assessed by the applicant or designee...." The Wm. H. Zimmer QA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process, S&L makes an independent evaluation of the bidders' QA programs as a part of their total bid evaluation." Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the control of quality by vendors who had supplied structural beams. Specifically, evaluations of the vendor (U.S. Steel Supply, PBI Steel Exchange, and Frank Adams Company) quality assurance programs for control of mill certifications and structural beams were not performed.

Appendix A (Continued) 12. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include... monitoring of work performance, and... include closely-related data such as qualifications of personnel, procedures, and equipment." The Wm. H. Zimmer QA Manual, Section 17.1.4 states, in part,

                " Documentation of all performance surveillance includes personnel identification and qualification, procedure, type observation, date of performance, person or organization monitored, results and corrective action if required."

Contrary to the above, the Bristol Steel and Iron Works Quality Control Steel Erection Report, which was a generic form for monitoring in process steel erection, did not identify closely related data such as weld procedure numbers, types of welding material, welder identification, and specific welds inspected.

13. 10 CFR 50, Appendix B, Criterion XVIII states, in part, "A com-prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."

The W'. m H. Zimmer QA Manual, Section 18.1 states, in part, "QA Division conducts a comprehensive system of planned and periodic audits of S&L, HJK...to verify compliance with all aspects of the quality assurance program." Contrary to the above, during the past 9 years the licensee's QA Division did not perform an audit of the Sargent & Lundy nonconformance program. This is a Severity Level II violation (Supplement II). (Civil Penalty - $100,000). Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric Company is hereby required to submit to this office within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial; (2) the reasons for the vio-lation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Any statement or explanation may incorporate by specific reference (e.g. , giving page and paragraph numbers) the provisions of your quality confirma-tion program and your actions in response to our Immediate Action Letter of April 8, 1981. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation. o

Appendix A (Continued) Within the same time as provided for the response required above under 10 CFR 2.201, Cincinnati Gas and Electric Company may pay the civil penalties in the cumulative amount of Two Hundred Thousand Dollars or may protest imposition of the civil penalties in whole or in part by a written answer. Should Cincinnati Gas and Electric Company fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above. Should Cincinnati Gas and Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalties should not be im-posed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penaltier.. Any answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. Cincinnati Gas and Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties. Upon failure to pay any civil penalties due, which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. FOR THE NUCLEAR REGULATORY COMMISSION Richard C. DeYoung, Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of November 1981

Appendix B l I

Appendix B (Continued) . 1 i l l 1 i. I t

s Cincinnati Gas and Electric Company The results of this investigation and our review of your 10 CFR 50, Appendix B, noncompliance history reveal an additional matter which is of significant concern to us. This matter concerns inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979

 ,           with thirteen of the eighteen different criteria of Appendix B to 10 CFR 50.

During our Systematic Assessment of Licensee Performance review on December 16, 1980, we expressed concern with your relatively poor performance in this area. This poor history of compliance with 10 CFR 50, Appendix B, when considered with the recent findings of the investigation indicates that your corrective actions only addressed indiYidual problems and not underlying programmatic causal factors. Consequently, we request that you review your history of noncompliance with 10 CFR 50, Appendix B, for the past two years and in your response to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors related to the noncompliances. You are required to respond to the Notice of Violation and in preparing your response you should follow the instructions in Appendix A. You should give particular attention to those actions designed to assure continuing compliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce- ' ment action is appropriate. 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 enclosure will be placed in the NRC Public Document Room. The responses directed by this letter and the enclosed Appendix A are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, l Richard C. DeYoung, Director Office of Inspection and Enforcement

Enclosures:

1. Appendix A - Notice of Violation and Proposed Imposition of Civil Penalties

2. Appendix B - Cross

References:

Noncompliances to Report Details cc: i See next page l WPU:JD EI:IE EI:IE ELD D:EI:IE D:IE

11/16/81 GBarber RWessman JLieberman DThompson RCDeYoung l 5520 11/ /81 11/ /81 11/ /81 11/ /81 11/ /81 l

I i U

Docket No. 50-358 Construction Permit No. CPPR-88 EA 82-12 Cincinnati Gas and Electric Company ATTN: Mr. W. H. Dickhoner President 139 East 4th Street Cincinnati, OH 45201 Gentlemen: This refers to the investigation conducted by Region III during the period January 12 to October 9, 1981, of construction activities at the W'. m H. Zimmer Nuclear Power Station. The details of that investigation are described in Region III investigation report No. 50-358/81-13. The violations described in Appendix A to this letter are cross-referenced to that report in accordance with Appendix B to this letter. The investigation was initiated.as a result of allegations made to the NRC by a Quality Control Inspector who formerly worked at the Zimmer site and by the Government Accountability Project of the Institute for Policy Studies (a non-governmental agency) on behalf of Mr. Thomas Applegate. The results of the continuing investigation reveal a widespread breakdown of your quality assurance program as evidenced by numerous examples of noncompliance with twelve of the eighteen different criteria for a quality assurance program as set forth in 10 CFR 50, Appendix B. The cause of the breakdown was your failure to exercise adequate oversight and control of your principal contractors to whom you had delegated the work of establishing and executing quality assurance programs. You thereby failed to fulfill your vital responsibility as described in Criterion I of 10 CFR 50, Appendix B, to assure the execution of a quality assurance program. The potential safety concern of your quality assurance program breakdown was discussed during an enforcement conference at our Region III office in Glen Ellyn, Illinois, on August 5, 1981, attended by you and members of your staff and the NRC Region III staff. Two of the violations (Items A and B of Appendix A of this letter) are of particular concern to us because of the very essential role they play in the execution of an effective quality assurance program. These two violations relate to false records and to harassment / intimidation of quality control inspectors. With regard to false records, the examples we identified raise serious questions as to the accuracy of quality records at the site. Our concern in this area served as a major factor in requiring the conduct of a confirmation program to be completed by you to furnish evidence of plant quality. CERTIFIED MAIL RETURN RECEIPT REQUESTED

Cincinnati Gas and Electric Company cc w/ encl: E. A. Borgmann, Senior Vice President, Engineering Services and Electric Production J. R. Schott, Plant Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Power Siting Commission 3 Citizens Against a Radioactive Environment Helen W. Evans, State of Ohio Thomas Applegate Louis Clark, Director, GAP Institute for Policy Studies Distribution PDR LPDR NSIC TIC ACRS SECY CA VStello, DEDROGR RCDeYoung, IE JHSniezek, IE HRDenton, NRR IPeltier, NRR RTedesco, NRR FIngram, PA JPMurray, ELD JLieberman, ELD JCummings, OIA JCrooks, AEOD Director, EI Staff, RI, RII, RIII, RIV, RV RWessman, IE TWBrockett, IE IE Files Central Files CP Book CON EI Reading File EDO Reading File

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and explained be did not have a magnifying glass with him when observed:and' that the tool Marshall had seen was a mirror. He also added that, even if x E he had been using a magnifying glass, both the AWS Code LI.1, Section 6.5.5, and Kaiser Procedure SPPM 4.6 ,(Revision 8 recognized and approved the 'u~se of a magnifying glass for weld inspection. - ' 3:~, ~ Individual I stated that he demanded Baker and Gittings dc,cument the ruson ' for his proposed termination and he advised Baker he would consult with his  % attorney and fight the termination. Individual I provided a sworn statement, a copy'of which is included as Exhibit .

                                                            ,                                                           / )(

4.4.3.6 Interview of Jesse Ruiz " On February 18 and 20, 1981, Jesse Ruiz, former Kaiser QC Inspector, was . interviewed by NRC. He stated that QC Inspectors at Zimmer were being harrassed and intimidated by Kaiser construction personnel. Ruiz said that , Individual I had been threatened with the loss of hisc job by,Geralo' Adams, -  ; KEI Structural Superintendent, if he did not accept an item inspected, and - for allegedly using a magnifying glass to inspect a weld when he was~actually g / using a mirror, a common weld inspection tool. - On February 20, 1981, Ruiz provided a sworn statement, a copy of which 2s ' included as Exhibit .

                                                                                                                            )c ,

4.4.4 Findings and Conclusions [- A QC Inspector. was threatened with dismissal by the QA & nager after t the Construction Superintendent advised him (incorrectly) that the QC Inspector , used a magnifying glass to visually inspect weld surfaces. The QC Inspector protested the planned dismissal and was not dismissed; however, he was ye-assigned to another area of inspection. 4.4.5 Items of Noncompliance ' '

                                                                                                ~

No items of noncompliance were identified. - '

                                       ~

5. Applegate/ GAP Allegations s

v On January 5,1981, the Government Accountability, Project (GAP) requested an investigation into the conduct of an earlier RIII investigation of concerns provided by Thorcas Applegate. In addition to this request, they povided a - list of nineteen allegations, some of which appeared to contain-inforastion known to NRC, and some of which were new information. A commitaent was M de to review the nineteen allegations even if they appeared to pertain to kncwn ' situations.

                                                                                                 '                                                            ~

To clarify the allegations, a meeting was held between Applegate, ' ' Thomas Devine (GAP representative), and RIII personnel on February 26,c1931. The meeting was recorded, and a transcript was produced. , l . 1 h

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14 s - DRAFT 2 10/8/81 4 W t Some of the allegations concern issues that do not fall under the jurisdie-tion of the NRC, and have been brought to the attention of the appropriate agencies ivr action as they consider appropriate. Other allegations were provided during this meeting and in correspondence from GAP, some of which are not addressed in this report but will be reviewed and documented in Tsubs,equent v reports. previewo g gutstanding allegations indicates that -

                  ' their investigation ga,med not,c, ange the conclusions reached in this report.                        y\

Ja a July 22, 1981, letter. GAI: provided RIII with additional information , on allegations of improper coastructicn. GAP subsequently offered to amplify and provide more specific information related to the matter in the letter. This information will be ' considered by'RIII prior to completion of the RIII independent measurement activities.

                                                                                                                --- J 35 1        Unsuitable Piping Installation 5.1.1       Allegation _
                        "KEI knewingly installed and ripped out unsuitable main steam relief piping, at an estinated laborscost of $320,000."
                                                    ?    .

5.1.2 Background Information

                      $heZinnerfacilitynisspGeneralElectricboilingwaterreactor(BWR)

Itark II containment system desigg, which includes a pressure suppression

                     .poo2 :n tbe lower l,vels  e    of ,the cont.ainment building. Based on actual Mark 1 ope' rating expeyiences rel        3  ted to safety relief valve actuations and large-scale testing.of'the acre recently designed Mark III containment de3i gn system,' nev. suppression pool hydrodynamic loads associated with
                    ;ppstulated loss-of-coo}ent accidents (LOCA) were identified that had not
                                                                      ~

s, been explicitly considered in the criginal design of the Mark II containment sys t;en. These newly identified Icads result from the dynamic effects of drywell a r ind steam bei9g rapidly forced into the suppression pool during a postulated LOCA or safety. relief valve actuation. When this possible pro-blem was fit:t identified, General Electric and NRC and its consultants per-formed an in-ocpth review of the General Electric Mark II containment system design. Utilities owning facilities that would use the Mark II containment

      '               system also formed an owners' group to share calculations, evaluations, and l                      acceptable modifications to the Mark II containments.

t i The NEC 'ef f rt in reviewing the.new dynamic loads was divided into two programs; a short-term evaluation program for the lead plants (Zimmer,

                     .La Salle, Shotcham), and a long-term program for final detailed evaluation of the adequacy of modifications. ' The description of the NRC evaluation e

is available in NUREG-0487, " Mark II Containment Lead Plant Program Load Evaluation and Acceptance Criteria," published in November 1978.* This l document indicates that'the lead plants, those first to use the Mark II containment system, would be reviewed by NRC to determine the acceptability of modif,ications made in their design to accommodate the identified loads. c - o

                     *These documents are available for inspection at NRC public document rooms or fo.: purchase from the NRC/GPO sales program, Washington, DC 20555.

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Cincinnati Gas and Electric Company ATTN: Mr. W. H. Dickhoner President 139 East 4th Street Cincinnati, OH 45201 Gentlemen: This refers to the investigation conducted by Region III during the period January 12 to October 9,1981, of construction activities at the Zimmer site. The investigation was initiated as a result of allegations made to the NRC by a Quality Control Inspector who formerly worked at the Zimmer site and by the Government Accountability Project of the Institute for Policy Studies (a non-governmental agency) on behalf of Mr. Thomas Applegate. reven The results of the continuing investigationA L .J.. tc a widespread breakdown of the implementation of your quality assurance program as evidenced by e\ eve numerous examples of noncompliance with +en of the eighteen different cri-teria for a quality assurance program as set forth in 10 CFR 50, Appendix ---' -- ~'-t:f t; _. . + x::tzti. .x .l; B. -L. l J o ... th: _ d whi.L .... . n ri xr  ;"--+f - :: t; ;L x : r-~; -f 111 ;x 11., . x r -

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.uc .uu . ..:: rr : :-j u L..... .a twuutus L. x furt -f+'- 11., Cvuurmauvu Fiv6... .. L.. .;t : !?: rf ;1_;.t g li b . The Q sa'fety concern of your quality assurance program breakdown was discussed during an by you and members of your staff and the NRC Region III sta enforcement conference at our Region III office in Glen Ellyn, Illinois, on August 5, 1981 h d r p r e u e. .wh ~% e ewe .y b b.=ua - .5 . Wr emersi h MnA -y y.- yma \ e.$r.he wes,wb- y C h ** eV wh answe. e* P. *2 ==43Vishg -ty.M,Amath g.st;'u~*=Iar .4eic s% _ Mhw% ._y e aa.Aumb.w$& p hGy c. . ~ uur.e 4-ym..._ _ __ .3 ,.y g ,,a w ep j_, - Cincinnati Gas and Electric Company The. impact of the identified quality assurance deficiencies on the actual construction has yet to be determined. Limited independent measurements were performed by the NRC in selected areas of concern in an attempt to characterize the actual safety significance of these deficiencies. Al-G.e. pw- u:=g%# %sM f %e~*3*!*) though a few problems requiring correctiv,e action were identifieg he majority of the tests and examinations did not disclose hardware problems. Recognizing the significant quality assurance problems identified during this investigation, the NRC has required the establishment of a compre-hensive Quality Confirmation Program to determine the quality of plant systems important to nuclear safety. The NRC will confirm the adequacy of the program and is making additional independent verifications. Deficiencies identified by these programs will require resolution prior to issuance of an Operating License. Notwithstanding the fact that serious construction deficiencies have not been identified, in order to emphasize the significance NRC attaches to breakdowns of quality assurance programs such as the breakdown that occurred at Zirmer that have a high potential for serious construction deficiencies, les T=== we propose to impose e civil penalty in the cumulative amount of ese Hundred and Fifty Thousand Dollars for the matten in the Notice of Violation. Some t b % NeVee 4. V;4mh of the examples,goccurred under the revised enforcement policy and some prior to that time. l Cincinnati Gas and Electric - 3-Company of In this regard we have exercised discretion in arriving at the amount of ics the proposed civil penalty which is less than allowed by either the old or new enforcement policies or a combination of the two. In arriving at ws the amount of the proposed civil penalty we considered th; ;.h.t._t;;L Ilm.;;.a1 ::ic;; rc;;1 ting f. m ihm Q.11:3 C;;firretier Pre;;;_ umios, r;.f_ t;d, +b= '!L;13 ::; tructic: ::hrdule imp::: ;f tha. y.v3.._,  ;;d the amount of the civil penalties that have been issued to licensees of ga h Ay b %e egnete d pbin . other plants under constructionf We believe our proposed amount :f ti ri i? ;:::11, provides assurance that you will fully appreciate the signi-ficance of the violationsand will result in an adequate deterrent against future similar violations by you and other licensees of plants under con-struction. We have for convenience and clarity categorized the itemsin the Notice of Violation at the Severity Levelsdescribed in accordance with the Interim Enforcement Policy published in the Federal Register, 45 FR 66754 (October 7, 1980). The results of this investigation and our review of your 10 CFR 50, Appen-w t2 dix B, noncompliance history reveal % m, additional matterf which a m of mMeA % ! significant concern to us r Ihi 1- i;2125;ninadequate corrective actions.

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l l l o Cincinnati Gas and Electric Company "t; fir:t :::::: ef :::::r_ 1: o. . ,. . ;; CZE ;;, nyycua. 2, ;:::: - 7?f--- 'imiviy ...d 1_ h ef Jms.. m suitmu ..:  ::*i^ WThe results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979 with thirteen of the eighteen different criteria of Appendix B. You will ret.11 that we expressed concern with your relatively poor per-formance in this area during our Systematic Assessment of Licensee Per-formance review on December 16, 1980. This poor history of compliance with Appendix B when considered with the recent findings of the investi-gation indicates that your corrective actions really only addressed individual problems and not the underlying programmatic causal factors. Consequently, we request that you review your history of noncompliance with Appendix B for the past two years and in your response to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors related to the noncompliances. The cond matter rela es to harassmen and intimidat n of Quall y Contro Inspecto . The investig ion revealed b assment and i imidation id occur; howeve we were unabl to establish at these acti ' ties resu ed i loss of inspe r independene as defined in riterien I of 0 CFR 50, l Appen 'x B. We dete 'ned that you d your contra tors apparent _ did l i l Cincinnati Gas and Electric Company not adone these ac 'vities that e clearly t conducive o effect ve implemen ation of your ality assura ce program; owever, cor etive actions had ot been effect've in stoppi them. Th efore, we r quest n your respons to this lette that you in lude measur s you have t ken an intend to take o assure hara sment and i imidation o( Quality Co rol Inspec ors by any mean and by any p rsons is st ed. You are required to respond to the Notice of Violation and in preparing your response you should follow the instructions in Appendix A. You should give particular attention to those actions' designed to assure continuing compliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce-ment action is appropriate. 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 en-closure will be placed in the NRC Public Document Room. Sincerely, j ~' Victor Stello, Jr., Director Office of Inspectica and Enforcement Cincinnati Gas and Electric - 6-Company

Enclosure:

Appendix A, Notice of - Violation and Proposed Imposition of Civil Penalty and Appendix B, Cross

References:

Noncompliance to Report Details cc w/ encl: E. A. Borgmann, Senior Vice President, Engineering Services and Electric Production J. R. Schott, Plant Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Power Siting Commission Citizens Against a Radioactive Environment i Helen W. Evans, State of Ohio f I i agemelu+DN45 **e eG*" #+9 =a* sueGee-a s e e WM A "*N* * * * * ** e e e. ee +==

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,, , ZIMM/ID DRAFT 10/8/81 Appendix B

                - CROSS 

REFERENCES:

NONCOMPLIANCE TO REPORT DETAILS Noncompliance Criterion Report Section A.1 XVII 4.3.3.7 4 L 4.1.3 p,g9 m J B.1 4.1.3 a AM4 A B.2 XV 4.1.3 B.3 XV 4.1.3 a B.4 XV 4.1.3 - B.5 XV 4.1.3

• M C .2.8 XV 7.1.1, 7.1.2 and Figure 7.1 Jkf C.2.b XV 5.10.3.2 M C .3 4 XVI 4.3.3.6.1

           .JWI C.~3.b                                            XVI              4.3.3.6.3 JVJ C . 3.c                                           XVI              7.3.3 Yd4                                                   VIII             7.1.1, 7.1.2 and Figure 7.1 J<f C. 5. a                                             III             7.2.2.1 Prf c . 5. h                                           III             7,2.2.2 M c.5.c.                                               III             7.2.2.4 EA* C.5.4                                              III             7.2.2.4 E 8 C. 5.e                                             III             7.2.2.4 M C.G .a                                              III              6.2.1 fed C.G.h                                             III              6.2.1 JV     C . ~7                                         XI               5.8.3.10 I4 C.8 4                                              III              5.10.3.3.6 Ld C.9.be                                             III              5.10.3.3.5 J./f C,. 8.c 4                                        III              5.10.3.3.3.b L<<    c. 8.6                                         III              5.10.3.2
            .Id' C. 9. 4                                          X                7.2.2.3 14 C.9.b                                             X                5.10.3.2 JRT      C.lo.4                                       V                6.3.1 K g C.lo.b                                            V                6.3.1 Y         C.ll                                         VII              7.1.4          _
           /          C .12                                       XVII             7.1.5
           .W'        OO                                          XVIII            7.3.1
                   ~ . . . . . - . . .                        . - - . .

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D~pr Y )prbA ZIMM/1C DRAFT 10/15/81 ( '" huda u b b mp% WM. 9 y.WP"T" 6:a i - +ps A wsay i.s Appendix A (h bAeA . h 6%~

                            .                   NOTICE OF VIOLATION wm g g     yk %g a pg    w h-e
                                                                                            .h y.h emM n\

A g % ww & 4 I AND h%)b w g.< , cy_ p,q eJrch ah Its PROPOSED IMPOSITION OF CIVIL PENALTY Cincinnati Gas and Electric Company Docket No. 50-358 Wm. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 EA No. 81-I  !

              !    As a result of the investigation conducted at the Wm. H. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - October 9, 1981, the violations listed below with multiple examples % C identified. Th numerous examples

( of the violations demonstrates widespread defici .!Ein fiIe implementation of your quality assurance program and caused the NRC to require an exten- / sive quality confirmation program to provide confidence that safety-related / structures, systems,andcomponen,t,swg sati Because of the safety significance ok..,__ pgg:_ p _ _y ,_,sfa_ct,ogin service.7 tu Lan.., in accordance with the Interim Enforcement Policy, 45 FR 66754 , (October 7,1980), the Nuclear Regulatory Commission proposes to impose e-civil penalty" pursuant to Section 234 of the A'tomic Edergy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205 in the amounts set forth for the violationslisted below. [C.10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear powerplant to document, by written policies, procedures, or in-k structions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related j structures, systems, and components and to implement that program in accordance

         )        with those documents.

4 Contrary to the above, Cincinnati Gas and Electric Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as evidenced by numerous examples of that ( noncompliance as follows: A. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality." Contrary to the above, numerous examples of records were identified that did ngfurnish evidence of activities affecting quality-in that they werk.. m . - - m . Examples of ri_.y. - ..: C cgrecords are as follows: fast

I

        '9     ~K, _ W ,. . H , Lw-      Qh Nd 526 LLa Merrb @ " Ins sw.:

3 ,, 3 7 eA.es q QND{Qwhg 6%ce 'DonM .wh %b ) 2 ,4 . g. 3 ,m g QAb% b- asn . . orpaA\ gr L A hg Jh pw,-,,c...yAcWeM

      ,                                                                                                l 3

I Appendix A 3 Jir. 10 CFR 50, Appendix B, Criterion I states, in part. "The persons... performing quality assurance functions shall have sufficient... organizational freedom to identify quality problems... including sufficient independence from cost and schedule." Contrary to the above, QC Inspectors did not have sufficient freedom to identify quality problems and were not sufficiently independent from cost and schedule. The results of interviews indicate that some QC Inspectors were: (a) harassed by construction workers and supervisors; (b) not always supported by QC management, and (c) intimidated. Although there was no evidence to suggest that these activities resulted in the acceptance by the inspectors of substandard conditions, they were not conducive to the effective an effective quality assurance program. L implementationogdddiur,eofinsufficientfreedomofQCInspectors,ylu'iint follo d HEE ffA including insufficient freedom from cost and schedule.

1. Five QC Inspectors interviewed executed signed sworn statements wherein they claimed they were doused with water (while engaged in the performance of inspection duties) by construction personnel.

2. A QC inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were reassigned by QC management because of complaints by construction person el. (In some cases, nonconformance reports initiated by these inspectors were improperly voided after the inspectors were reassigned.)

3. Three QC Inspectors executed signed sworn statements wherein they claimed they had been harassed by being searched by security personnel at the request of construction supervisory

personnel.

l

4. A QC Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after construction personnel complained he had used a magnifying glass to visually inspect a weld when in fact he was using a mirror and either device was an acceptable tool,

g. 9 g %4 QQ 1 vieN b.( b gM *

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l \ . . . ZIMM/IC DRAFT 10/15/81 Appendix A 1. Isometric drawings or other records did not furnish evidence of the actual piping components installed in the 10 pipelines in the diesel generator cooling water, starting air and fuel oi1 systems, in that the heat numbers recorded on the drawings did n'ot match the heat numbers marked on the respective components. The 10 pipe-lines were: IDG28ABI IDGC5AA3/4 IDG27AB1 1DGF6AA1/2 IDG01AB1 1DGC5BA3/4 IDGF2AA1/2 IDGF6BA1/2 IDG28AE1 1DG25AC2

2. The Kaiser Nonconformance Reporting Log did not reflect all reports initiated as evidenced by the following:

(a) The original entry for a report assigned the number CN-4309 relating to deficient weld fit-up was eliminated by whiting-out and there was no other record of this report in the NR system. (b,) The original entry for a report assigned the number CN-5412 relating to violation of a hold tag was eliminated by whiting-out and there was no other record of this report in the NR system. (MRC- coo D (c,) A reportAinitiated by a QC Inspector on February 11, 1981, relating to excessive weld weave assigned a number and there was no other record of this report in the NR system.

3. Written statements ag tog lanned actions were made to justify voiding reports E-166 E-1662, and E-2466 and those actions were N

gg ypwdL*Wedk fMM- t 10 CFR 50, App ix B, Criterion XV states, in part, " Nonconforming h items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures." Kaiser Procedure QACHI G-4, " Nonconforming Material Control," provides detailed instructions for the review and disposition of reports (Non-conformance Reports) of nonconforming items. Contrary to the provisions of QACMI G-4, the sample of NRs reviewed indicate significant deficiencies with the nonconformance reporting system in the areas of voiding of reports, not entering reports into the system, improper dispositioning of reports, and incomplete report files. The deficiencies identified in the sample reviewed were as follows:

 -.       ......        ..~ ..              -.       ... - ....- .

ZIMM/IC DRAET 10/15/81 Appendix A 3 Gre. ' E. Tour NRs related to documentation deficiencies had been improperly voided in that there was no adequate justification for the voiding. (NR-E-1777,NR-E-)P ,,ddd y mw(19 7$le 191,NR-E-2233,NR-E-)gu108) 1)@ q;/ . o2-E-223, "

g. One NR related to nondestructive examination of a T quencher weld had been erroneously closed (not voided) by administrative error.

(NR-E-2996). e  % frt/sI

y. Four reports had been voided by personnel other than the QA Manager (CN-5122,CN-5476,CN-5477,CN-54{9).

                                                    +/pfd A          f/7/st                             Wie            $h

4. In one case during " revisions" some nonconforming items were removed from a NR without adequate justification. (NR-E-2466).

e v/3alf

f. The following eleven reports had not been issued NR numbers and copies of the reports had not been retained in the Site Document Center:

CN-4930 CN-4958 CN-4931 CN-4959 CN-4955 CN-5122 CN-4956 CN-5476 CN-4957 CN-5477 CN-5479 (The copies of the NRs reviewed by the investigator were provided by an alleger. g.2 10 CFR 50, Appendix B, Criterion XV states, in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation." The Wm. H. Zimmer QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformances in receiving inspection, construction, or testing activities which are delegated to HJK Quality Assurance Procedures to assure that nonconforming items are conspicuously marked to prevent their inadvertent use or installation. AWS Code D1.1-1972, Section 3 and 8.1.5 define requirements for weld quality and address slag, weld profiles, blowholes, porosity, and undercut. AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch minimum radius for re-entrant corners. Contrary to the above:

', ZIMM/IC DRAFT 10/15/81 Appendix A a

t. , Based on an inspection of the 25 structural hanger support beams described in Item below, (p) Several welds on 9 beams did not conform with AWS DI.1-1972 requirements in that they contained unacceptable slag, weld profiles, blowholes, porosity, and/or undercut.

1 (J/) Five beams did not conform with AISC requirements in that the re-entrant corners were notched, creating potential stress risers, instead of being rounded with required radii. (f) Four beams, (o,f wgd, ch had unacceptable welds as described in Item 4,+-e3Eb8v did not conform with design documents in that they were not specified on any design document, b J. Based on an inspection of about 100 cable tray hangers in the Cable Spreading Room, 4 did not conform with AWS D1.1-1972 require-ments in that the welds contained unacceptable slag, weld profiles, blowholes, porosity, and/or undercut. The nonconforming conditions were not controlled in that they were not conspicuously marked to prevent their inadvertent use. 3 E. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations...and nonconformances are promptly identified and corrected. , In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." The Wm. H. Zimmer QA Manual, Section 16.5 states, in part, " Vendors, contractors, and subcontractors are required to determine cause and corrective action to prevent recurrence of errors which could result in significant conditions adverse to quality." ASME Code, Section III-1971 Edition, Article NB-3661.5(b) states, in part, "...a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before welding." ASME Code, Section III-1971 Edition , Winter 1972 Addenda, Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, NA-4451, NB-4230, and NB-3661.5(b) require, in part, in-process inspections for pipe fitup, weld procedure, weld filler metal traceability, and welder qualifications... Contrary to the above, the NRC inspectors identified the following nonconforming conditions that had not been corrected and action had not been taken to preclude their repetition:

ZIMM/IC DRAFT 10/15/81 Appendix A b J'. The licensee identified that the socket engagement (fitup) fr,r more

                                   'than 439 socket welds was not verified in accordance with AcdE Code, Section III-1971 Edition, Article NB-3661.5(b) and the condition was not corrected in that the corrective action was not commen-surate with the ASME Code. The welds dated back to 1979.

k

4. The licensee was aware that the in process inspections for more than 22 welds in the Diesel Generator cooling water, starting air, and fuel oil piping systems were not performed by Kaiser in accordance with ASME Code, Se.ction III-1971 Edition, Article NB-3661.5(b), et. al., and the condition was not corrected in that the corrective action was not commensurate with the ASME Code.

c J. Five licensee QA audits (audit performed 8/8-9/74 - no number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of Sargent & Lundy identified repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications and action was not taken to preclude repetition. Jr. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials... These measures shall assure that identification of the item is maintained..." The Wm. H. Zimmer QA Manual, Section 8.2 states, in part, "H. J. Kaiser Company procedures provide that within the H. J. Kaiser Company juris-diction the identification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other appropriate means. This identification may be on the item or on records traceable to the item. The identification is main-tained throughout fabrication, erection, and installation. The identi-fication is maintained and usable in the operation and maintenance program." Contrary to the above, based on an inspection of approximately 25 hanger support beams located in the Blue Switchgear Room and the Cable Spreading Room, the identification of the material in 9 of those beams was not maintained to enable verification of quality. The above examples raise questions about the adequacy of the quality of installed materials as well as the obvious paperwork deficiencies. > G df .' 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis...are translated into... drawings..." The Wm. H. Zimmer FSAR, Section 8, provides the design basis-for electrical cable separation that includes the following:

     . . . . . .   -..     . _ . _ . . . _ _ _ . _ _ . . . ~ . _ _ . _ _ . . .

ZIMM/1C DRAFT 10/15/81 Appendix A

• Associated cables (Green / White, Blue / White, and Yellow / White) from more than one Division cannot be routed in the same raceway.

(FSAR Paragraph 8.3.1.13.2) Vertical separation of three feet or more must be maintained between cables from different Divisions. (FSAR Paragraph 8.3.1.11.2.1.d) Instrument (low-level signal) cables cannot be routed in the same raceway with power and control cables. (FSAR Paragraph 8.3.1.12.1.3) The W m . H. Zimmer QA Manual, Section 3.3.2. states, " Composite... drawings are prepared, translating the design concepts into layouts of structures, systems, and components necessary for the construction of the plant." Contrary to the above, as of March 1981, the FSAR design basis for electrical cable separation had not been translated into the drawings which governed the following cable installation deficiencies in the Cable Spreading Room: 6 J. Associated Cable (Yellow / White) No. RE053 for Division I was routed in the same raceway (two-inch conduit and Class IE Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2. Also, Associated Cable No. RE053 was routed so that in places there was only a vertical separation of four inches between it and cables in Blue Tray No. 2072C for Division 2. b 2P. Instrument Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Associated Control Cables (Yellow / White and Blue / White) for Divisions 1 and 2. This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3029K) inside a White Control Tray (No. 4638B). C 4F. Many Associated Cables from all three Divisions were routed in the same raceway (White Tray No. 4080K) including Cable (Blue / White) No. TI192, Cable (Yellow / White) No. RR781, and Cable (Green / White) No. TI816. d A'. Associated Cables (Yellow / White) No. TI942 and No. TI943 for Division I were routed in the same raceway (White Tray Riser No. RK4627) as Associated Cables (Blue / White) No. TI808 and No. TI760 for Division 2. e K. Many Associated Cables (Yellow / White) for Division I were routed in the same raceway (White Tray Riser No. 4139) as Associated Cables (Blue / White) for Division 2.

 ~

ZIM'!/IC DRAFT 10/15/81 Appendix A The.above installation deficiencies were noted during brief tours of the Cable Spreading Room while pursuing other unrelated matters. Le

f. 10 CFR 50, Appendix B, Criterion III states, in part, "Desig~n control measures shall be applied to...the delineation of acceptance criteria for inspections and tests."

The W . H. Zimmer QA Manual, Section 3.13.1 states, in part, " Design control measures also apply to delineation of acceptable criteria for ! inspections and tests." Weld acceptance criteria are required by the ASME Code, Se.ction III-1971 Edition and AWS D1.1-1972 Code. Contrary to the above: a (. The weld acceptance criteria used by H. J. Kaiser Company from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were deleted. k E. The acceptance criteria for Weld 55H (isometric drawing PSK-1WS-32) performed on Service Water System Line No. 1WS17A18 by H. J. Kaiser Company in November 1979 were not applied in that they were designated as not applicable. 7 . X. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test procedures shall include provisions for assuring that all prerequisites for the given test have been met... Test results shall be evaluated to assure that test requirements have been satisfied." The W. H. Zimmer QA Manual, Section 11.1 states, in part, " Test programs to assure that essential componeni.s, systems, and structures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construction site." M. W. Kellogg Co. (pipe manufacturer and agency performing the pre-fabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "Wherever required, shims shall be used to produce a total thickness under the penetrameter equal to the nominal thicknes.t of the base metal plus the height of the crown or reinforcement." ASME Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..."

ZIMM/1C DRAFT 10/15/61 Appendix A Contrary to the above, the NRC inspectors reviewed approximately 800 radiographs involving 206 welds and determined that 187 of the radio-graphs did not comply with the ASME Code in that there was in. sufficient shimming of the penetrameter. The radiographed welds were prefabricated pipe welds in such systems as feedwater, diesel generator support systems, and main steam. B Z. 10 CFR 50, Appendix E, Criterion III states, in part, "These measures [ design control] shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled...The design control measures shall provide for verifying or checking the adequacy of design." The Wb. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are specified and included in design documents." The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are estab-lished to assure that any deviations from the applicable standards are controlled." Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verification reviews are performed...." The Wm. H. Zimmer FSAR states that cable ampacity is based on IPCEA Publication No. P-46-426. Also regarding cable ampacity, the FSAR states "the summation of the cross-sectional areas of the cables shall not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross-sectional area in any case." AWS DI.1-1972 Code, Section 3.6.4, states, "For building and tubular structures, undercut shall be no more than 0.01 inch deep when its ) direction is transverse to primary tensile stress in the part that is undercut, nor more than 1/32 inch for all other situations." Contrary to the above: a. I. As of March 1981, design control measures had not been established to assure that deviations from design conditions (quality standards) identified by Sargent & Lundy engineers were controlled. For example, Sargent & Lundy noted on a calculation sheet dated December 27, 1979, that the design thermal loading for two power cables (VC016 and VC073) in Yellow Tray No. 1057A would allow the cables to be thermally over-loaded and no program existed to control those design deviations. b Jf. As of March 1981, design control measures had not been established by Sargent & Lundy to provide for verifying or checking the adequacy of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays.

                                                                                -m--y---    - - - - - - - - -          ----         -"        "

ZIml/IC DRAFT 10/15/81 Appendix A c K. As of March 1981, the cable ampacity design by Sargent & Lundy was not based on IPCEA P-46-426 (appropriate quality standard). The cable ampacity was instead based on IEEE Paper 70TP557-PWR (1970), IPCEA P-54-440, and Sargent & Lundy Standard ESA-114a.

4. As of March 1981, the design allowable undercut on cable tray hanger velds was not based on AWS D1.1-1972 Code (appropriate quality standard). The design undercut was instead based on Sargent & Lundy Specification H-2713, Supplement 7, Sargent & Lundy Standard EB-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph S.2.9, allowed up to 1/16 inch undercut.

1

8. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

The Mn. H. Zimmer QA Manual, Section 10.1.2 states, in part, "Inspec-tions are performed in accordance with written procedures which include requirements for check lists and other appropriate documentation of the inspections and tests performed." AWS D1.1-1972 Code, Section 3.10.1, requires work to bc completed and accepted before painting. Contrary to the above: a J. As of March 1981, a QC inspection program had not been established to require verification of separation of electrical cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RI1O3 and CM111 that had been routed into Tray Riser (Green) No. 3025A, which extended from Tray (Blue) No. 2077A in the Cable Spreading Room to the Control Room. b 2'. The programs established for in-process and final inspections of welds on 180 cable tray hangers located in the Cable Spreading Room were not executed as required in the AWS D1.1-1972 Code. Specifically, the final weld inspections were made after the welds were painted (Galvanox). 10-, Y. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

                                                    . ~ _        _-._

ZIMM/1C DRAFT 10/15/81 Appendix A The'Wh. H. Zimmer QA Manual, Section 5.1 states, " Construction, fabri-cation, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instrucpions, procedures, and drawings which prescribe acceptable methods of carrying 1 out those activities." The Wh. H. Zimmer QA Manual, Section 3.12 states, in part, " Design changes... including field changes, are subject to design change control measures commensurate with those applied to the original design." Contrary to the above: e E. Kaiser Procedure QACMI G-14, " Surveillance Reports," was not appropriate to the circumstances in that it allowed in process nonconformances which constitute field changes to be disposi-tiened within 30 days without being subjected to design control measures commensurate with those applied tc the original design. Examples of nonconformances so dispositioned were identified in SRs F-2899, F-2903, and F-2914. b 2f. Kaiser Procedure QACMI G-14 was not followed in that SRs F-2909, F-3070, F-3071, F-3072, F-3073, F-3074, F-3075, F-3076, F-3083, and F-7019 were not dispositioned within 30 days and were not transferred to Nonconformance Reports as required by Paragraph 5 of QACMI G-14. p - Jf. 10 CFR 50, Appendix B, Criterion VII states, in part, "The effective-ness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee...." The Wm. H. Zimmer QA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process, S&L makes an independent evaluation of the bidders' QA programs as a part of their total bid evaluation." Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the con-trol of quality by vendors who had supplied structural beams. Speci-fically, evaluations of the vendor (U.S. Steel Supply, PBI Steel Exchange, and Frank Adams Company) quality assurance programs for control of mill certifications and structural beams were not performed. 12-ff., 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of actitities affecting quality. The records shall include... monitoring of work performance, and.. . include closely-related data such as qualifications of personnel, procedures, and equipment." - I i

ZIMM/1C DRAFT 10/15/81 Appendix A f The Wm. H. Zimmer QA Manual, Section 17.1.4 states, in part, "Documen-tation of all performance surveillance includes personnel identification and qualification, procedure, type observation, date of performance, person or organization monitored, results and corrective action if required." C:ntrary to the above, the Bristol Steel and Iron Works Quality I Control Steel Erection Report, which was a generic form for monitoring in process steel erection, did not identify closely related data such as weld procedure numbers, types of welding material, welder identi-fication, and specific welds inspected. G Jr. 10 CFR 50, Appendix B, Criterica XVIII states, in part, "A compre-hensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program." The Wm. H. Zimmer QA Manual, Section 18.1 states, in part, "QA Division conducts a comprehensive system of planned and periodic audits of S&L, HJK...to verify compliance with all aspects of the quality assurance program." Contrary to the above, during the past 9 years the licensee's QA Division did not perform an audit of the Sargent & Lundy nonconformance program. This is a Severity Level II violation (Supplement II). o (Civil Penalty - $L30,000) Some of the examples of the violationscontinued during a period that spanned both the old and new enforcement policies. Application of either policy or a combination of both allows a large civil penalty. However, after weighing this matter relative to other civil penalties that have been issued to licenseesofplantsunderconstructionand7:EM A~%W N E; :t

3 tLm y. ..i;;l s.. ;;::i:: cr'-1 1: irr -+ ar +ha Q"-li , Co..f:.-__ tic;.

T ;;:: , we believe a civil penalty in the amount proposed to be appropriate. We believe this exercise of discretion in determining the amount of the civil penalty will result in assurance that the licensee fully appreciates the significance of the violation and will result in an adequate deterrent against future similar violations by licensees of plants under construction. Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric Company is hereby required to submit to this office within 30 days of the date of this Notice a written statement or explanation, including for each r ::il: ;f ihm alleged violation: (1) admission or denial; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Any statement or explanation may incorporate by specific reference

ZIMM/1C DRAFT 10/15/81 Appendix A (e.g... giving page and paragraph numbers) the provisions of your Quality Confirmation Program and your actions in response to our Immediate Action Letter of April 8,1981. Consideration may be given to extending the response time for good cause shown. Under t.he authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation. Within the same time as provided for the response required above uter d 10 CFR 2.201, Cincinnati Gas and Electric Company may pay the civil penalt7 in the euppdd6't amountof42%fkundredandFiftyThousandDollarsormayprotestimpositionof thecivilpenalty*inwholeorinpartbyawrittenanswer. Should Cincinnati Gas and Electric Company fail to answer within the time specified, this office willissueanOrderimposingthecivilpenaltP'intheamountproposedabove. Should Cincinnati Gas and Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violation >1isted in this Notice in whole or in part; (2) demonstrate extenuating circur. stances; (3) show error in this Notice; or (4) show other reasons why the genalty should not be imposed. In addition to protesting the civil penalty *in whole or in part, such answer may request remission ormitigationofthepenalty.' Any answer in accordance with 10 CFR 2.205 should be set forth separately from the statement er explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., Riving page and paranraoh numbers) to avoid repetition. Cincinnati Gas and Electric company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty. Upon failure to pay any civil penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. l The responses directed by this Notice are not subject to the clearance pro-cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. FOR THE NUCLEAR REGULATORY COMMISSION Victor Stello, Jr. , Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of , 1981 __

  *?/      -

ZIMMER/4-B DRAFT 11/3/81 Cincinnati Gas and Electric Company ATTN: Mr. W. H. Dickhoner President 139 East 4th Street Cincinnati, OH 45201 Gentlemen: This refers to the investigation conducted by Region III during the period January 12 to Octeber 9,1981, of construction activities at the Zimmer site. The investiration was initiated as a result of allegations made to the NRC by a Quality Control Inspector who formerly worked at the Zimmer site and by the Government Accountability Project of the Institute for Policy Studies (a non-governmental agency) on behalf of Mr. Thomas Applegate. The results of the continuing investigation reveal a widespread breakdown cf th; i ;1:- t tirr of your quality assurance program as evidenced by numerous examples of noncompliance with eleven of the eighteen different criteria for a quality assurance program as set forth in 10 CFR 50, Appendix B. The cause of the breakdown was your failure to exercise ade-quate oversight and control of your principal contractors to whom you had delegated the work of establishing and executing quality assurance programs. You thereby failed to fulfill your vital responsibility as described in Criterion I of Appendix B to assure the execution of a quality assurance program. The safety concern of your quality assurance program breakdown was discussed during an enforcement conference at our Region III office o in Glen Ellyn, Illinois, on August 5, 1981, attended by you and members of your staff and the NRC Region III staff. Two of the violations (Items A and B) are of particular concern to us because of the very essential role they play in the execution of an effective quality assurance program. These two violations relate to false records and to harassment / intimidation of quality control inspectors. With regard to false records, the examples we identified raise serious questions as to the accuracy of e4+ quality records at the site. Our concern in this area served as a major factor in requiring the conduct of a confirmation program to be completed by you to furnish evidence of plant quality. Because the NRC inspection program is a sampling program that relies hcavily on licensee records, the importance of accurate records cannot be overemphasized. Accordingly, we have addressed this matter as a separate violation and assessed a substantial civil penalty for it. Withregardtoharassment/intimidationofQualityGontrolInspectors,we have also addressed this matter as a separate violation and assessed a substantial civil penalty for it. Harassment / intimidation of quality control inspectors is clearly a barrier to effective implementation of a quality assurance program and results in loss of the organizational independence described in Criterion I of Appendix B. The importance of this matter is reflected in the recent amendment (Public Law 96-295, June 30, 1980) to the Atomic Energy Act of 1954, which added Section

ZIMMER/4-B DRAFT 11/3/81 Cincinnati Gas and Electric Company 235relatingtoprotectionofnuclearinspectorssuchasyourQuality Eontrol Inspectors. The impact of the identified quality assurance deficiencies on the actual ' construction has yet to be determined. Limited independent measurements were performed by the NRC in selected areas of concern in an attempt to characterize the actual safety significance of these deficiencies. Al-though a few problems requiring corrective action were identified (i.e., four unacceptably installed pipe hangers), the majority of the tests and examinations did not disclose hardware problems. Recognizing the signifi-cant quality assurance problems identified during this investigation, the NRC has required the establishment of a comprehensive Quality Confirmation Program to determine the quality of plant systems important to nuclear safety. The NRC will confirm the adequacy of the program and is making additional independent verifications. Deficiencies identified by these programs will require resolution prior to issuance of an Operating License. Notwithstanding the fact that serious construction deficiencies have not been identified, in order to emphasize the significance NRC attaches to breakdowns of quality assurance programs such as the breakdown that occurred at Zimmer that have a high potential for serious construction deficiencies, we propose to impose civil penalties in the cumulative amount of Two Hundred and Fifty Thousand Dollars for the matters in the Notice of Violation. Some of the examples in the Notice of Violation occurred under the revised enforcement policy and some prior to that time. In this regard we have exercised discretion in arriving at the-amount of the proposed civil penalties which is less than allowed by either the old or new enforcement policies or a combination of the two. In arriving at the amount of the proposed civil penalties we considered the amount of the civil penalties that have been issued to licensees of other plants under construction and the changes in the enforcement policies. We believe our proposed amount provides assurance that you will fully appreciate the significance of the violations and will result in an adequate deterrent against future similar violations by you and other licensees of plants under construction. We have for convenience and clarity categorized the items in the Notice of Violation at the Severity Levels described in accordance with the Interim Enforcement Policy published in the Federal Register, 45 FR 66754 (October 7, 1980). The results of this investigation and our review of your 10 CFR 50, Appendix . B, noncompliance history reveal an additional matter which is of significant concern to us related to inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979 with thirteen of the eighteen different criteria of Appendix B. You will recall that we expressed concern with your relatively poor performance in this area during our Systematic Assessment of Licensee Performance review on i

ZIMMER/4-B DRAFT 11/3/81 Cincinnati Gas and Electric Company December 16, 1980. This poor history of compliance with Appendix B when considered with the recent findings of the investigation indicates that your corrective actions really only addressed individual problems and not the underlying programmatic causal factors. Consequently, we request that you review your history of noncompliance with Appendix B for the past two years and in your response to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors related to the noncompliances. You are required to respond to the Notice of Violation and in preparing your response you should follow the instructions in Appendix A. You should give particular attertion to those actions designed to assure continuing compliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce-ment action is appropriate. 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 en-closure will be placed in the NRC Public Document Room. Sincerely, Richard

                                                 '/ A . 1 11;C.hb
                                                              , J. 3., Director f

Office of Inspection and Enforcement

Enclosure:

Appendix A, Notice of Violation and Proposed Imposition of Civil Penalty and Appendix B, Cross

References:

Noncompliance l to Report Details

cc w/ encl

1 E. A. Borgmann, Senior Vice ! President, Engineering Services and Electric Production J. R. Schott, Plant Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Power Siting Commission l Citizens Against a Radioactive ! Environment Helen W. Evans, State of Ohio lW \eH-e nJ % erAwh hwJr k k The responses directed by this L'.haare not subject to the clearance pro-l cedures of the Office of Management and Budget as required by the Paperwork

Reduction Act of 1980, PL 96-511.

i ZIMM/1C DRAFT 11/3/81 Appendix A NOTICE OF VIOLATION PROPOSED IMPOSITION OF CIVIL PENALTIES Cincinnati Gas and Electric Company Docket No. 50-358 Wm. H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 EA No. 81-As a result of the investigation conducted at the Wm. H. Zimmer Nuclear Pcwer Station in Moscow, Ohio, on January 12 - October 9,1981, the vio-lations listed below with multiple examples were identified. The numerous examples of the violations demonstrate your failure to exercise adequate oversight and control of your principal contractors, tC$you had delegated the work of establishing and executing quality assurance programs, and thereby fulfill your responcibility of assuring the effective execution of a quality assurance program. Your failure manifested itself in a widespread breakdown in the implementation of your quality assurance program and caused the NRC to require an extensive quality confirmation program to provide confidence that safety-related structures, systems, and components will perform satisfactorily in service. Included in the breakdown were findings we consider to be particularly disturbing relating to false records and harassment and intimidation of quality control inspectcrs. Because of the safety significance of the quality assurance program breakdown, in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205 in the amounts set forth for the violations listed below. - A. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality." Contrary to the above, numerous examples of records were identified that did not furnish evidence of activities affecting quality in that they were false. Examples of false records are as follows:

1. Isometric drawings or other records did not furnish evidence of the actual piping components installed in the 10 pipelines in the diesel generator cooling water, starting air and fuel oil systems, in that the heat numbers recorded on the drawings did not match the heat numbers marked on the respective components.

The 10 pipelines were:

                                                          ..    ~.~     .           -
                                                                                                                   ~

O ZIMM/1C DRAFT 11/3/81 Appendix A - 2-IDG28ABI IDGCSAA3/4 IDG27ABI IDGF6AA1/2 IDG01ABI IDGC5BA3/4 IDGF2AA1/2 1DGF6BA1/2 IDG28AE1 IDG25AC2

2. The Kaiser Nonconformance Reporting Log did not reflect all reports initiated as evidenced by the following:

a. (eu-wif);W4JW .h.rw L-@>M d The original entry for a repory .. - - d;. C5 'O' relating to deficient weld fit-up was eliminated by whiting-out and there was no other record of this report in the NR system. b. ((ew-a,1H A S.A % > CC % e% c-The original entry for a repor W;;;i;;;d :.L. _L.. G ,,2 G%mY \$ relating to violation of a hold tag was eliminated by whiting-out and there was no other record of this report in the NR ry-

                                        .JC -CcO D

c. A ..,,ortAinitiated by a QC Inspectorgon February 11, 1981, relating to excessive weld weav wasnootherrecordofthisrep(rtintheNRsystem.lssigned o a number and

3. Written statements as to planned actions were made to justify voiding reports E-166 E-1662,, and E-2466g and those actions were not taken. he  %/A (4 w Sfp) 6.M wo/cic,)

his is a Severity Level II violation (Supplement II). (C.ivil Penalty - $75,000) B. 10 MFR 50, Appendix B, Criterion I states, in part, "The persons... perfosaing quality assurance functions shall have sufficient...organi-zational freedom to identify quality problems..! including sufficient independence from cost and schedule." l l ' The Wm. H. Zimmer QA Manual, Section 1.2.3 describes QC Inspectors as members of QAD (Quality Assurance Division) and Section 1.2.4 i states, in part, "QAD has been assigned sufficient... organizational freedom to identify quality problems..." l Contrary to the above, QC Inspectors did not have sufficient freedom to identify quality problems and were not sufficiently independent

*- from some cost and schedule.

QC Inspectors were: The results of interviews indicate tihat (a) harassed by construction workers and l supervisors; (b) not always supported by QC management; and (c) intim-t ' idated. Although there waWFeVi'deE to suggest that these activities resulted in the acceptance by the inspectors of substandard conditions,

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ZIMM/1C DRAFT 11/3/81 l Appendix A they were not conducive to the rf'--*f 1 implementation of an effective quality assurance program. The following are examples of insufficient freedom of QC Inspectors, including insufficient freedom from cost and schedule:

1. Five QC Inspectors interviewed executed signed sworn statements wherein they claimed they were doused with water (while engaged in the %e ge_. performance A of insp#ection

                                         ..+       %.

duties) by construction personnel.7;x c.4 e -

2. A QC Inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were re- .

assigned by QC management because of complaints by constructionA5476,cu.9(rt, personnel. O n some casesg nonconformance reports initiated by ""~597T) these inspectors were improperly voided after the inspectors were reassigned.]

                         "La

3. EhcogsQC Inspectors executed signed sworn statements wherein theyclaimedtheyhadbeenharassedbybeingsearchf8kb'y*fecurity gersonnel at the request of construction supervisory personnel. C)~. b-z y :ya.% - A. n waw .w-w .

4. A QC Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after con-struction personnel complained he had used a magnifying glass to visually inspect a weld when in fact he was using a mirror "DNT and either device was an acceptable tool.

>tTh~~ #

           '" This is a Severity Level II violation (Supplement II).

(Civil Penalty - $75,000) C. 10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear powerplantsto document, by written policies, pro-cedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents. Contrary to the above, Cincinnati Gas and Electric Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as evidenced by numerous examples of that noncompliance as follows:

1. 10 CFR 50, Appendix B, Criterion XV states, in part, "Noncon-forming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."

Kaiser Procedure QACMI G-4, " Nonconforming Material Control," provides detailed instructions for the review and disposition of reports (Nonconformance Reports) of nonconforming items.

ZIMM/IC DRAFT 11/3/81 Appendix A . l Contrary to the provisions of QACHI G-4, the sample of NRs reviewed indicate significant deficiencies with the nonconformance reporting system in the areas of voiding of reports, not entering reports into the system, improper dispositioning of reports, and incomplete report files. The deficiencies identified in '- -Te g :- ': d were as follows: w u"' a #s. Four NRs related to documentation deficiencies had been improperly voided in that there was no adequate justifi-cation fo the voiding. (NR-E-1777, 3 NR-E-2191,g NR-E-2233,hR 4 E- N w M ,, NR-E-510 , .4,4 %./, A 4 gfg v.4*h '/t'/c= ,

                                              . a.4 6/s /au g

( b e'#. One NR related to nondestructive examination of a T quencher

    }                                weld had been erroneously closed (not voided) by adminis-trative error.          (NR-E-299Q eks.A 24 ,f,g c d t.                Fout reports had been voided by personnel other than the QA Manager.

(CN-5122,, CN-5474,

                                                                  '.3e4 Va/m CN-5477,,

4e6 %w, CN-5479)M e.ind%5/es ve Wr/88 4 4. In one case during " revisions" some nonconforming items J

     )                               were removed from a NR without adequate justification.

(NR-E-246Q a.h W4

   !           e gt.                 The following i            .f-ihrts had not been issued NR numbers anS/*e
                                    .med copies of the reports had not been retained in the Site Document Center:
    )                                   '
                                        -4 3

• CN-495 CN-4931 CN-4959 CN-4955 CN-4956 CN-512b CN-5476 cu-sm2

 /
 )                                   CN_4957 ,                            CN-5477 CN-5479 MRCooot (The copies of the NRs reviewed by the investigator were provided by an alleger.)

2. 10 CFR 50, Appendix B, Criterion XV states, in part, " Measures

   /                   shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their
   )                    inadvertent use or installation."

The W. H. Zimmer QA Manual, Section 15.2.2 states, "HJK is responsible for identifying and reporting nonconformances in receiving inspection, construction, or testing activities which

 /N                   are delegated to HJK Quality Assurance Procedures to assure that nonconforming items are conspicuously marked to prevent their inadvertent use or installation.

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ZIMM/IC DRAFT 11/3/81 ! Appendix A i 4 AWS Code D1.1-1972, Section 3 and 8.1.5 define requirements for weld quality and address slag, weld profiles, blowholes, porosity, j and undercut. AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch minimum radius for re-entrant corners. Contrary ta the above:

a. Based on an inspection f the 25 structural hanger support beams described in It below,

' (1) Several welds on 9 beams did not conform with AWS D1.1-1972 requirements in that they contained unaccept-

able slag, weld profiles, bAowholes, porosity, and/or undercut.

l (2) Five beams did not conform with AISC requirements in that the re-entrant corners were notched, creating potential stress risers, instead of being rounded with '. required radii. (3) Four beams, 2 of which had unacceptable welds as described in Item C.2.a.(1) above, did not conform with design documents in that they were not specified on any design document.

b. Based on an inspection of about 100 cable tray hangers in the Cable Spreading Room, 4 did not conform with AWS D1.1-1972 requirements in that the welds contained unacceptable slag, weld profiles, blowholes, porosity, and/or undercut.

The nonconforming conditions were not controlled in that they were not conspicuously marked to prevent their inadvertent use.

3. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deviations...and nonconformances are promptly identified

and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."

The Wh. H. Zimmer QA Manual, Section 16.5 states, in part,

                       " Vendors, contractors, and subcontractors are required to determine cause and corrective action to prevent recurrence of errors which could result in significant conditions adverse to quality."

a

    -  _-.                                  _ _ _ . _ _        _     ~ . - _

l ZIMM/1C DRAFT 11/3/81 Appendix A i J i ASME Code, Section III-1971 Edition, Article NB-3661.5(b) states, in part, "...a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before welding." ASME Code, Section III-1971 Edition , Winter 1972 Addenda, Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, a NA-4451, NB-4230, and NB-3661.5(b) require, in part, in process inspections for pipe fitup, weld procedure, weld filler metal traceability, and welder qualifications... Contrary to the above, the NRC inspectors identified the following nonconforming conditions that had not been corrected and action , had not been taken to preclude their repetition:

a. The licensee identified that the socket engagement (fitup) for more than 439 socket welds was not verified in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b) i and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds dategbackto1979.

b. The licensee was aware that the in-process inspections for more than 22 welds in the Diesel Generator cooling water, starting air, and-fuel oil piping systems were not performed by Kaiser in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b), et. al., and the condition was not corrected in that the corrective action was not

commensurate with the ASME Code.% woes W \ee. A M -

c. Five licensee QA audits (audit performed 8/8-9/74 - no

number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of l Sargent & Lundy identified repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications and action was not taken to preclude repetition.

4. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of l materials... These measures shall assure that identification of j the item is maintained..."

l The Wm. H. Zimmer QA Manual, Section 8.2 states, in part, "H. J. Kaiser Company procedures provide that within the H. J. Kaiser Company jurisdiction the identification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other appropriate l means. This identification may be on the item or on records l l t l l l

ZIMM/1C DRAFT 11/3/81 Appendix A traceable to the item. The identification is maintained through-out fabrication, erection, and installation. The identification is maintained and usable in the operation and maintenance program." W wtc i.epen. w M nat Cogtr r to the above, based on an inspectionAof approximately 25a ang,v,ger support beams located in the Blue Switchgear Room and

,              the Cable Spreading Room, the identification of the material in 9 of those beams was not maintained to enable verification of quality.

The above examples raise questions about the adequacy of the quality of installed materials as well as the obvious paperwork deficiencies.

5. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory require-ments and the design basis...are translated into... drawings..."

The Wm. H. Zimmer FSAR, Section 8, provides the design basis for electrical cable separation that includes the following: Associated cables (Green / White, Blue / White, and Yellow / White) , from more than one Division cannot be routed in the same raceway. (FSAR Paragraph 8.3.1.13.2) Vertical separation of three feet or more must be maintained between cables from different Divisions. (FSAR Paragraph 8.3.1.11.2.1.d) Instrument (low-level signal) cables cannot be routed in the same raceway with power and control cables. (FSAR Paragraph 8.3.1.12.1.3) The Wm. H. Zimmer QA Manual, Section 3.3.2. states, " Composite... drawings are prepared, translating the design concepts into layouts of structures, systems, and components necessary for the construction of the plant." Contrary to the above, as of March 1981, the FSAR design basis i for electrical cable separation had not been translated into the drawings which governed the following cable installation defi-ciencies in the Cable Spreading Room:

a. Associated Cable (Yellow / White) No. RE053 for Division I was routed in the same raceway (two-inch conduit and Class IE Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2. Also, Associated Cable No. RE053 was routed so that in places there was only a vertical separation of four inches between it and cables in Blue Tray No. 2072C for Division 2.

ZIMM/1C DRAFT 11/3/81 Appendix A b. Instrument Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Asso-ciated Control Cables (Yellow / White and Blue / White) for Divisions 1 and 2. This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3029K) inside a White Control Tray (No. 4638B).

c. Many Associated Cables from all three Divisions were routed in the same raceway (White Tray No. 4080K) including Cable (Blue / White) No. TI192, Cable (Yellow / White) No. RR781, and Cable (Green / White) No. TI816.

d. Associated Cables (Yellow / White) No. TI942 and No. TI943 for Division 1 were routed in the same raceway (White Tray Riser No. RK4627) as Associated Cables (Blue / White) No. TI808 and No. TI760 for Division 2. ,

e. Many Associated Cables (Yellow / White) for Division 1 were routed in the same raceway (White Tray Riser No. 4139) as Associated Cables (Blue / White) for Division 2.

The above installation deficiencies were noted during brief tours of the Cable Spreading Room while pursuing other uncelated matters.

6. 10 CFR 50, Appendix B, Criterion III states, in part, " Design control measures shall be applied to...the delineation of acceptance criteria for inspections and tests."

The Wm. H. Zimmer QA Manual, Section 3.13.1 states, in part,

             " Design control measures also apply to delineation of acceptable criteria for inspections and tests."

Weld acceptance criteria are required by the ASME Code, Section III-1971 Edition and AWS Dl.1-1972 Code. Contrary to the above:

a. The weld acceptance criteria used by H. J. Kaiser Company from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were deleted.

b. The acceptance criteria for Weld 55H (isometric drawing PSK-1WS-32) performed on Service Water System Line No.

1WS17A18 by H. J. Kaiser Company in November 1979 were not applied in that they were designated as not applicable.

ZIMM/1C DRAFT 11/3/81 Appendix A 7. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test proce-dures shall include provisions for assuring that all prerequisites for the given test have been met... Test results shall be evaluated to assure that test requirements have been satisfied." The Wm. H. Zimmer QA Manual, Section 11.1 states, in part, " Test programs to assure that essential components, systems, and struc-tures will perform satisfactorily in service are planned and performed in accordance with written procedures and instructions at vendor shops and at the construction site." M. W. Kellogg Co. (pipe manufacturer and agency performing the prefabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "Wherever required, shims shall be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal plus the height of the crown or reinforcement." ASME Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..." Contrary to the above, the NRC inspectors reviewed approximately 800 radiographs involving 206 welds and determined that 187 of the radiographs did not comply with the ASME Code in that there was insufficient shimming of the penetrameter. The radiographed welds were prefabricated pipe welds in such systems as feedwater, diesel generator support systems, and main steam.

8. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design control] shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled...The design control measures shall provide for verifying or checking the adequacy of design."

The W. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are specified and included in design documents." The W. H. Zimmer QA Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled." Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verification reviews are performed...."

ZIMM/1C DRAFT 11/3/81 Appendix A The Wm. H. Zimmer FSAR states that cable ampacity is based on IPCEA Publication No. P-46-426. Also regarding cable ampacity, the FSAR states "the summation of the cross-sectional areas of the cables shall not exceed 50% of the tray usable cross-sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross-sectional area in any case." AWS D1.1-1972 Code, Section 3.6.4, states, "For building and tubular structures, undercut shall be no more than 0.01 inch deep when its direction is transverse to primary tensile stress in the part that is undercut, nor more than 1/32 inch for all other situations." Contrary to the above:

a. As of March 1981, design control measures had not been established to assure that deviations from design conditions (quality standards) identified by Sargent & Lundy engineers were controlled. For example, Sargent & Lundy noted on a calculation sheet dated December 27, 1979, that the design thermal loading for two power cables (VC016 and VC073) in Yellow Tray No. 1057A would allow the cables to be thermally overloaded and no program existed to control those design deviations. '

b. As of March 1981, design control measures had not been established by Sargent & Lundy to provide for verifying or checking the adequacy of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays.

c. As of March 1981, the cable ampacity design by Sargent &

Lundy was not based on IPCEA P-46-426 (appropriate quality standard). The cable ampacity was instead based on IEEE Paper 70TP557-PWR (1970), IPCEA P-54-440, and Sargent & Lundy Standard ESA-114a.

d. As of March 1981, the design allowable undercut on cable .

tray hanger welds was not based on AWS D1.1-1972 Code (appro-priate quality standard). The design undercut was instead based on Sargent & Lundy Specification H-2713, Supplement 7, Scrgent & Lundy Standard EB-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph 5.2.9, allowed up to 1/16 inch undercut.

9. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be estab-lished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

ZIMM/1C DRAFT 11/3/81 Appendix A The Wm. H. Zimmer QA Manual, Section 10.1.2 states, in part,

                     " Inspections are performed in accordance with written procedures i

which include requirements for check lists and other appropriate documentation of the inspections and tests performed." AWS D1.1-1972 Code, Section 3.10.1, requires work to be completed and accepted before painting. Contrary to the above:

a. As of March 1981, a QC inspection program had not been estab-lished to require verification of separation of electrical cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RIl03 1 and CM111 that had been routed into Tray Riser (Green)

No. 3025A, which extended from Tray (Blue) No. 2077A in the Cable Spreading Room to the Control Room,

b. The programs established for in process and final inspections of welds on~180 cable tray hangers located in the Cable Spreading Room were not executed as required in the AWS DI.1-1972 Code. Specifically, the final weld inspections were made after the welds were painted (Galvanox).

10. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

The Wm. H. Zimmer QA Manual, Section 5.1 states, " Construction, fabrication, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures, and drawings which prescribe acceptable methods of carrying out those activities." The W s . H. Zimmer QA Manual, Section 3.12 states, in part, " Design changes... including field changes, are subject to design change control measures commensurate with those applied to the original design." Contrary to the above:

a. Kaiser Procedure QACMI G-14, " Surveillance Reports," was not appropriate to the circumstances in that it allowed in process nonconformances which constitute field changes to be dispositioned within 30 days without being subjected to design control measures commensurate with those applied i

        . _ _ _ _ _                . _ _ . _ _ , . _ _ . - , . . _ , . _ __ . _ _ ,    ._.   ,m-,    - -_   .

ZIMM/IC DRAFT 11/3/81 Appendix A to the original design. Examples of nonconformances so dispositioned were identified in SRs F-2899, F-2903, and F-2914.

b. Kaiser Procedure QACMI G-14 was not followed in that SRs F-2909, F-3070, F-3071, F-3072, F-3073, F-3074, F-3075, F-3076, F-3083, and F-7019 were not dispositioned within 30 days and were not transferred to Nonconformance Reports as required by Paragraph 5 of QACMI G-14.

11. 10 CFR 50, Appendix B, Criterion VII states, in part, "The effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee...."

The Wm. H. Zimmer QA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process, S&L makes an independent evaluation of the bidders' QA programs as a part of their total bid evaluation." Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the control of quality by vendors who had supplied structural beams. Specifically, evaluations of the vendor (U.S. Steel Supply, PBI Steel Exchange, and Frank Adams Company) quality assurance programs for control of mill certifications and structural beams were not performed.

12. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records r. hall include... monitoring of work performance, and... include closely-related data such as qualifications of personnel, procedures, and equipment."

The Wm. H. Zimmer QA Manual, Section 17.1.4 states, in part,

           " Documentation of all performance surveillance includes personnel identification and qualification, procedure, type observation, date of perforuance, person or organization monitored, results and corrective action if required."

Contrary to the above, the Bristol Steel and Iron Works Quality Control Steel Erection Report, which was a generic form for monitoring in-process steel erection, did not identify closely related data such as weld procedure numbers, types of welding material, welder identification, and specific welds inspected.

13. 10 CFR 50, Appendix B, Criterion XVIII states, in part, "A com-prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."

                                                       -                            ~

ZIMM/IC DRAFT 11/3/81 Appendir A The Wm. H. Zimmer QA Manual, Section 18.1 states, in part, "QA Division conducts a comprehensive system of planned and periodic audits of S&L, HJK...to verify compliance with all aspects of the quality assurance program." Contrary to the above, during the past 9 years the licensee's QA Division did not perform an audit of the Sargent & Lundy nonconformance program. This is a Severity Level II violation (Supplement II). (Civil Penalty - $100,000) E-;~ of the a._...,1x of ik . el_ _ a ntin;;d durin; _ px . d th;t :p::: d StL th c id .md m. mmfm _a y lima . /.yyli nt an ;f cith:r policy :: 2 'i stier of b th 211: : Ix ;; cicil p x: ty. " u .cz, afix n i;hing thi; ..ttcr alati;m te othcr cccil p x1 tic; th:t ha;; h x I :urd it linn n ,f p!--t; under : nctrertie 2nd th: ch: ; : in :nfer ::xt ;:lic';,

          'li_ : _ cicil pr= Ity in th: _...,_at p npx:2 t: 5: :ppnprint:       W E^'!- ^ t'!: excrei:: ef dircretir- in A + --inig th: r xx* cf+'^"           il pc- 'b uill rc:xit i 22 uren : th:t the lixn :: fully pprecirte: *he ci;;ni fi-^ :: cf th: cic1sti n ud will ru ult in x ade,in t d tcz. ut ;2irr$

fem m ilo. . clation by licx:::: cf pl:nt: und:: ::::tructi:2. Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric Company is hereby required to submit to this office within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial; (2) the reasons for the vio-lation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Any statement or explanation may incorporate by specific reference (e.g., giving page and paragraph numbers) the provisions of your Quality Confirma-tion Program and your actions in response to our Immediate Action Letter of l April 8, 1981. Consideration may be given to extending the response time

for good cause shown. Under the authority of Section 182 of the Act,

42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Cincinnati Gas and Electric Company may pay the civil penalties in the cumulative amount of Two Hundred and Fifty Thousand Dollars or may protest imposition of the civil penalties in whole or in pa-t by a written answer. Should Cincinnati Gas and Electric Company fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above. Should Cincinnati Gas and Electric Company elect to filg an answer in accordance with 10 CFR 2.205 protesting the civil penalty,' such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalties in whole or in part,

ZIMM/1C DRAFT 11/3/81 Appendix A such answer may request remission or mitigation of the penalties. Any answer in accordance with 10 CFR 2.205 shoula be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. Cincinnati Gas and Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty. Upon failure to pay any civil penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. T' m :;;;;;;  ::t: ' '; thi. "-tir: ::: n;t ;;tj; ; : th; ;I;_ ;;:: p_

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FOR THE NUCLEAR REGULATORY COMMISSION Richard C. DeYoung, Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of , 1981 1 t l l l l

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 .,_ J-WM. H. ZIMMER NUCLEAR POWER STATION UNIT 1 NRC/ REGION III DISCUSSIONS APRIL 10, 1981 j.,,            ,       . .
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e PROPOSED AGENDA FOR MEETING FRIDAY, APRIL 10, 1981

1. Opening Remarks by Mr. Keppler.

2. Discuss Program for Confirming Quality of Completed Work. CG&E to Provide Specific Plan for Accomplishing This.

1

3. Discuss Immediate Action Letter (Both by NRC and CG&E). CG&E to Provide Approach and Plans for Implementation.

4. Concluding Remarks by Mr. Keppler.

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     .'                          PROGRAMMATIC MEAS!!RES FOR CONFIRMING QUALITY OF COMPLETED WORK
                                                                                     ~

Problem: The following programmatic measures will be taken with regard to each of the identified problem areas:

a. A program will be established to define the potential scope of each problem area. The scope shall include but not be limited to identifying, structures, com-ponents, materials, the affected organizations and disciplines, the organizations responsible, and the responsibilities of the affected organizations and disciplines. The program shall explicitly identify and distinguish the completed (past) activities and the incomplete (present and future) activities.

b. A program will be established to define the causes of each' problem. 'This program will consider organi-zation, QA program, design control, traceability of materials, welding controls, control of noncontor-mances, corrective action, and audits.

Case: The quality concerns identified by the NRC involve a variety of structures, components, systems and organizations. An overall review to evaluate their significance is appropriate. Corrective Plant walkdown and inspections are being conducted to Action: address the structural steel, piping and electrical items identified by the NRC. The results of these walkdowns are being monitored to scope and prioritize potential problem areas. Since such walkdowns by necessity, are limited to access-ible areas and deviations which can be visually identified additional efforts are also being implemented. These

efforts fall into three basic categories 1) Procedure Review 2) Documentation Review 3) Corrective Actions.

1. Procedure Review As detailed elsewhere a review of all QC inspection procedures is being conducted by both Design and Q/A personnel. This review will address all of the areas of concern identified by the NRC as well as various Code, Standard and FSAR requirements. No construction work will proceed untiI the controlling procedure has been reviewed, revised as necessary and personnel have been retrained.

Construction procedures covering deviation from design documents and non-conformances are also being reviewed. Again personnel will be retrained if changes are identified. m e -- - _ _ -_

Page 2 of 3

  . y.I ' ' -

.sl* Corrective 1. Procedure Review (Continued) Action: Design procedures are also being reviewed to assure that all appropriate codes, standards and FSAR state-ments are addressed. Design control procedures are also being revised to assure any deviations are identified, CGGE is involved in approving the reso-lution and that such approved deviations are documen-ted in the FSAR. We believe the above will greatly improve proj ect performance and will assure full compliance on all future work. To help scope and identify any problems which may have occurred in the past, we will be also reviewing prior revisions of procedures. This review will help identify potential deviations which might have occurred during the time period when that revision was in effect. This will help focus on areas of greatest potential for deviations.

2. Documentation Review:

In conjunction with the above review of procedures which control or controlled the design, construction and inspection of the work, an audit of the QA/QC documentation will be conducted. This documentation audit will help establish the extent of potential deviations from codes, standards and FSAR statements. Typical documentation audits would include cable pull records, hydrotest records, and radiographs. Records of work performed both at site or in vendor shops will be audited as required.

3. Corrective Actions If the above procedure and record review identifies potential deviations to Codes, Standards or FSAR statements which cannot be justified, physical testing, requalification, or replacement will be used to assure compliance.

Testing might involve various NDT methods or s' elective destructive testing of coupons removed from potentially devient areas. Requalification might involve testing prototypes or if many duplicates are installed in the plant a test unit might be removed and tested. _s

l page 3 of 3

     '3t3p.

ig-In addition to the above efforts the Q/C inspectors will be advised, as part of their re-training, to ~ _ bring concerns directly to the CGGE management when-ever they feel such action is appropriate. CGGE management will see that any such concerns are in-vestigated promptly and that corrective measure are taken. In all the above efforts CGGE staff and management as well as the staff and management of all other involved organizations are being alerted to look for repeat items which might typify a generic problem. 4 i e

       ,'i 1

l AREAS OF CONCERN FOR WM. H. ZIMMER NUCLEAR POWER STATION INVESTIGATION 1 i l l

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INSPECTION REPORT #1 - BRISTOL STRUCTURAL BEAM WELDS PROBLEM: Apparent lack of an adequate QA program covering field welding by Bristol resulting in some un-acceptable structural welds. CASE:

                                         $+f Inspection of Bristol structural beam welds in the 546' elevation of the Auxiliary Building, Cable Spreading Room, and RHR Heat Exchanger Room revealed that several field welds are unacceptable to AWS weld inspection criteria.

CORRECTIVE ACTION: Inspections o a ccessible, essential g welds will be performed to ensure compliance with applicable codes. Those welds found to be unaccept-able will be documented and repaired as required. Iocumentation D on the balance of field work will be reviewed for validation. If there are problems with the documentation, sufficient inspections will be made to ensure a satisfactory level of confidence (fortheserviceinvolved. sib itg..

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INSPECTION REPORT #2: LACK OF BRISTOL QUALITY ASSURANCE PROGRAM PROBLEM: The Quality Assurance Program required only inspection by a non-QC person. CASE: Structural welds did not receive adequate independent inspection. Bristol Steel & Iron was responsible for furnish-ing, fabricating, delivering, and erecting structural steel at the Zimmer Site. Bristol Steel & Iron (BS&I) was relieved of their responsibility for erecting structural steel in some areas of the project; i.e., drywell and SWPS, because of scheduling conflicts with Henry J. Kaiser Company. In these areas, Henry J. Kaiser Company erected the structural steel. BS&I had their own Quality Assurance Program for field erection and shop fabrication work. The " Erection Quality Control" section of their Quality Assurance Manual sums up the areas of responsibility of their field QC work:

                               . Unloading Inspection

! . Verify anchor bolt location

                               . Verifying proper location of erected materials
                               . Verifying proper erection practice is followed Verifying that high-strength bolting is performed to AISC's " turn of the nut" method
                               . Performing visual inspection of welds Reporting nonconforming items to proper authorities.

Bristol Steel had a Project Manager or Superintendent j who handled both the bridge erection for I-471 and the

r

   .       INSPECTION REPORT #2:    LACK OF BRISTOL QUALITY ASSURANCE PRCGRAM (Cont'd)    Page #2 CASE:       Zimmer Project concurrently.      Approximately 60%

(Cont'd) of his time was spent at the Zimmer Project. Another individual was designated as responsible for CC activities acted as Superintendent in absence of the Superintendent. Reports were prepared by Bristol Steel as the job progressed which indicate that visual inspection of applicable welds was performed for those welds included in the area covered by the report. Henry J. Kaiser Company was delegated responsibility for conduct of audits and assurance that quality require-ments for structural steel were acceptable. It appears that the Bristol reports are inadequate and insufficient independent weld inspection was performed. Henry J. Kaiser Quality Assurance inspectors were responsible for all bolting inspection of structural steel erected by both Henry J. Kaiser Company and Bristol Steel & Iron. The requirement for bolting inspection is specified in Henry J. Kaiser QACMI C-ll and the results of the bolting inspection is documented on the " Daily Bolting Inspection Report" from the BS&I erected work. The implementation of the shop QA/QC fabrication program was verified by CG&E audits. There~are no apparent deficiencies in the total program other than in structural welding. CORRECTIVE ACTION: See Inspection Report #1 - Bristol Structural Beam Welds.

               <3 ..

4 INSPECTION REPORT #3a & b: MATERIAL TRACEABILITY - BEAMS IN REACTOR AND AUXILIARY BUILDING PROBLEM: Several hundred feet of beams have been received from an unapproved vendor, and cannot be accounted for as to where installed or other disposition. CASE: H. J. Kaiser purchased W8X17 beams from a non-approved vendor. These beams were placed in essential steel stock on the basis that they were supplied with valid mill certificates by the vendor at time of purchase. CORRECTIVE ACTION: An investigation will be made of the unapproved supplier of the structural beams. An evaluation will be made to determine the credibility.of the mill certifications from the unapproved supplier and/or the supplier's supplier.

,, 4.

              \

INSPECTION REPORT #3c & d: LACK OF TRACEABILITY OF MATERIALS PROBLEMi Traceability of heat numbers on small bore piping

                   . for the diesel generators.

CASE: A review of the documentation of the small bore piping in the diesel generator system followed by a walkdown of the piping revealed some lack of trace-ability'in accordance with ASME Code requirements. CORRECTIVE ACTION: Reinspect the diesel generator small bore piping and take corrective action where traceability is found deficient. With regards to the other small bore piping systems, a comparison of documentation to the actual field installation will be made on respreseneariua systemsz _ If a satisfactory level of traceability - and confidence level is indicated, the review of the balance of the small bore systems would be confined to an audit of document verification. l[ oV

  .,    40 INSPECTION REPORT #3e:   LACK OF TRACEABILITY PROBLEM:         Weld rod heat numbers, because heat numbers are being transferred to KEI-l form from KEI-2 by individuals other than QC inspector who inspected the welds.

CASE: Investigation confirmed that the transfer of information was occurring on the documents performed by inappropriate personnel. CORRECTIVE ACTION: Henry J. Kaiser Company has been directed to stop any additional alterations of KEI-l forms. Reference attached April 2 letter from Borgmann to Gittings on this subject.

                                                             ~    .r- w

 ,       s. ,         RE:        INSPECTION REPORT - ITEM 33.

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THE CINCINNATI GAS & ELECTRIC COMPANY. d1 # ~' "' CINCINN ATI.QHIO 45201 April 2,1981 KEF-642 L A. BORGMAN N StoesCe v'CC Pets 60Coef Henry J. Kaiser Company P.O. Box 201 Moscow, Ohio 45153 ATTENTI0ft: Mr. P. S. Gittings Site Quality Assurance Manager RE: Wm. H. Zimmer Nuclear Power Station Unit 1 - Alterations to Quality Records W.0. 57300, Job E-5590 Gentlemen: As a result of the Nuclear Regulatory Commission's concerns expressed in the exit meeting held at the site on Thursday, March 26, 1981, you are requested to implement the following directives imediately:

1. Absolutely no additional alterations wi11 be made to KEI-l forms or any other record to correct the alter-ations or for any other reason.

2. Absolutely no alterations will be made to the voided nonconformance reports. All additional information will be documented on separate records which can be attached to the original records after review by NRC personnel.

Please contact me personally if you have any questions regarding this matter. Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By E. A. Borgmann [ Senior Vice President EAB:dw cc: W. W. Scnwiers J. P. Coyle B. K. Culver W. D. Waymire

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e INSPECTION REPORT #4: SURVEILLANCE REPORTS NOT BEING CONVERTED TO NON-CONFORMANCE REPORTS IN 30 DAYS This item is covered under Item 9 of the Immediate Action Letter. t t

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INSPECTION REPORT #5 - WELDS INSPECTED AFTER PAINTING h &

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PROBLEM: Structural welds were inspected after painting. .,7 CASE: FEC has installed structural beams and cable tray supports and have used Galvanox and other coatings to prevent the corrosion of the welds. Although no documentation exists that verifies that these welds were inspected at that time, hanger inspection along with its associated structural steel was in-process inspected and all work was assumed to be acceptable by construction unless reported unacceptable by Quality Control inspectors. CORRECTIVE ACTION: A sampling program will be established to verify w that the FEC structural beams and cable tray support welds which have been coated have acceptable welds by removing the coating and reinspecting. H. J. Kaiser has been instructed to revise their procedures to add a hold point on painting until final acceptance of the weld and NRC concurrence. (See attached April 3, 1981 letter Schwiers to Gittings) 4A AS v l

RE.: INSPECTION REPORT #5 --- ,- - - - KQ -, rqg} i THE CINCINNATI GAS & ELECTRIC COMPANY T '" ~~ ~ CINCINNATS. OHIO 45201 April 3,1981 KEQ-550 Henry J. Kaiser Company P. O. Box 201 Moscow, Ohio 45153 Attention: Mr. P. S. Gittings RE: WM. H. ZD'RER NUCLEAR POWER STATION UNIT I - WELD IllSPECTION - W.0. # 57300-957, JOB E-5590 Gentlemen: Effective,immediately, all welds requiring visual inspection shall be inspected prior to covering with Galvanox or other applicable paints. To accomplish this, hold points must be established to assure that these required inspections are completed. -If the weld inspection has not been completed and the component is painted, it shall require removal of the paint prior to conduct of the visual inspection and QC inspection documenta tion. By copy of this letter, Waldinger-Young & Bertke is requested to comply with the above project requirements. If you have any questions regarding the above, please call. Very truly yours, THE CINCINNATI GAS & ELECTRIC C0fdPANY By W. W. SCHNIERS j MANAGER, QUALITY ASSURANCE WWS:pa l cc: Henry J. Kaiser Company i Attn: R. Marshall Waldinger-Young & Bertke Attn: D. Martin S. C. Swain l

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INSPECTION REPORT #6: UNACCEPTABLE TECHNIQUE FOR RADIOGRAPHS OF PREFABRICATED PIPE WELDS PROBLEM: Radiograph technioue was inadequate on 25% of the prefab welds that NRC Inspector reviewed (approximately 180 of 600). The penetrometers were not adequately shimmed. CASE: Region III reviewed approximately 600 radiographs and cited approximately 25% as being in violation of ASME Section III Code requirements for radiographic _techniaue. According to Region III interpretation of the Code, shimming of the penetrometer is required to assure that total thickness being radiographed under the penetrometer is the same as the total weld thicknes,s, regardless of whether or not the Code film density and quality requirements were achieved. CORRECTIVE ACTION: It is the intent of the Code to see that radiography is performed with a technique of sufficient sensitivity to display the penetrometer image and the specified hole. For welds the thickness is based on the nominal single wall thickness plus the reinforcement permitted by the l Code. If the reinforcement where permitted is not removed then shims may become necessary to meet Code density requirements of -15% +30%. On the other hand, ( if a weld is blended smooth or nearly smooth into the base material to possibly meet pre-service ultrasonic i requirements, the use of shim (s) may cause the l

        , .                                                                     - o     _ _ _ _

INSPECTION REPORT #6: UNACCEPTABLE TECHNIQUE FOR RADIOGRAPHS OF PREFABRICATED PIPE WELDS (Cont'd) Page 2 CORRECTIVE ACTION: (Cont'd) penetrometer to exceed density requirements and will be cause for a rejectable radiograph. It is not a shim (s) itself that is mandatory by Code, but shims are a mechanism that may or may not be used to meet density which is a Code requirement. Within the present state of the radiographic art, this practice is acceptable to all processes and techniques. Pullman Power Products is an ASME Certificate Holder subject to audit and review by ASME and NRC. Further-more, the Authorized Nuclear Inspector has not rejected Pullman radiographs for inadequate shimming. CG&E will recheck the 180 radiographs in question to verify that the film density meets the ASME Code requirements. If above actions are rejected by the NRC, a formal ASME Code Interpretation will be requested.

Inspection Report #7. NR's are being voided improperly. This concern is addressed in Item 7 of the Immediate Action Letter. 1

. ,o 9 INSPECTION REPORT #8: DESIGN VIOLATION CONTRARY TO FSAR - CABLE SEPARATION PROBLEM: 'A _6 in. creen cable tray was designed and installed inside a white tray. The green tray includes green Class lE cables and the white tray contains blue / white an_d yellow / white associated cables. CASE: The white tray is classified as "non-essential"; the green tray is 'bssential" . Separation criteria does not require a specific difference between " essential" and "non-essential" trays. The blue / white and yellow / white associated cables in the white tray does not make the tray " essential". The design basis for electrical separation on the Wm. H. Zimmer Nuclear Power Station includes three essential electrical divisions: yellow, blue, and green. In addition, there is a white division which includes non-essential cables. As a design basis, there are cases where non-essential cables are placed in trays dedicated to a specific essential division and there are cases where non-essential cables are connected to a bus to which essential cables are also connected. By definition in the FSAR (8.3.1.12.2.3), these are called " associated cables" and are called blue / white, green / white, or yellow / white depending on the interfacing divisions.

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INSPECTION REPORT #8: DESIGN VIOLATION CONTRARY TO FSAR - CABLE SEPARATION (Cont'd) Page #2 CASE: This design basis, which is different from the (Cont'd) current requirements of Reg. Guide 1.75, was acce*'ed by NRR in the Zimmer Safety Evaluation Report, NUREG-0528 of January, 1979, Section 7.1.2(2) which says:

                             " Institute of Electrical and Electronic Engineers Standard 384 and Reg. Guide 1.75,
                             " Physical Independence of Electrical Systems,"

did not exist when the construction permit was issued. However, with the exceptions as indicated in Sections 7 and 8 of this report, the Zimmer Station meets the requirements of these latter criteria." In November, 1979, Mr. J. F. Stolz of NRR requested an audit of separation of electrical equipment and systems at Zimmer Station. In response to this request, CG&E conducted an audit of 16% of the essential cables in the plant which resulted in the identification of one (1) finding which was subsequently rectified. Based on this audit, CG&E has a high confidence level in electrical separation at this plant. As a result of the recent investigations by RIII, specifically this item being discussed, CG&E reviewed this matter again. It was found that the audit failed to address non-essential cables in essential

n INSPECTION REPORT #8: DESIGN VIOLATION CONTRARY TO FSAR - CABLE SEPARATION (Cont'd) Page #3 CASE: trays and non-essential cables connected to essential (Cont'd) buses, which by definition are associated cables. CORRECTIVE ACTION: CG&E has initiated the following corrective action regarding concerns of electrical separation:

1. Sargent & Lundy will clarify the criteria for associated cables. The appropriate section of the FSAR will be modified to include the clarifying criteria.

2. Sargent & Lundy will perform a 100% analysis on associated cables and demonstrate that Class lE circuits are not degraded below acceptable levels.

3. Utilizing the clarified criteria and results of the analysis, an audit team consisting of CG&E Engineer-ing, Construction, and Quality Assurance representatives will conduct a 10% audit of associated cables.

  ,   e

• INSPECTION REPORT #9: LACK OF INSPECTION CONTROL TO VERIFY -

CABLE SEPARATION This report is divided into four parts, each of which will be addressed separately below: 9a. PFOBLEM: From the end of tray points up to the control panels, two blue cables in the cable spreading room have been pulled into a green tray section leading up to the control room. CASE: CG&E investigation of this problem revealed that the blue cables were not pulled into the green tray section; however, their proximity did not meet separation criteria. The blue cables were improperly bundled together when the bundle was installed in a riser. CORRECTIVE ACTION: The corrective action is to properly secure the blue cables in the riser. 9b. PROBLEM: Yellow / white cable coming out of conduit and suspended approximately 6 in. above the cables in the blue tray (in the cable spreading room). CASE: If the conduit, containing the yellow / white cable were extended to the wall penetration, no separation deviation would exist.

1

          ~.

4 INSPECTION REPORT #9: LACK OF INSPECTION CONTROL TO VERIFY CABLE SEPARATION (Cont'd) Page 2 9b. (Cont'd) CORRECTIVE ACTION: The corrective action is to extend the conduit containing the yellow / white cable to the wall penetration. 9c. PROBLEM: In the instrument and relay room, a non-safety related white cable, No. DC258 (also labeled DC257) has been misrouted into a yellow tray No. 1040B. CASE: The unterminated white cable was routed correctly but installed incorrectly in the yellow tray. CORRECTIVE ACTION: The corrective action is to remove cable No. DC258 from the yellow tray, and install it in a white tray. 9d. PROBLEM: Tray loading and cable separation concerns. CASE: Cable tray loading'is addressed in the response to inspection report #10. Cable separation concerns are addressed in the response to inspection report #8. t

                    .-e-- - - -                      -   .- --        ,                  --

4 3 INSPECTION REPORT #10: S&L CABLE TRAY LOADING DESIGN CONTROL PROBLEM: The Region III inspection report under this item lists three specific areas indicating lack of design controls on the part of Sargent & Lundy. In addit, ion, four unresolved items regarding S&L's design are listed. CASE: Attached is a draft of responses to the specific items of non-compliance and the unresolved items listed under this problem. However, CG&E recognizes that these are examples of deficiencies in exercising design control. Specifically, CG&E must reassess the programs utilized by design organizations working on the Zimmer Project. Generic problems stemming from these inspection examples include:

a. The FSAR did not reflect the actual reference used in the design.

b. Procedures were not in place requiring calculations exceeding design index.

c. Lack of formal procedure to control deviations from design.

CORRECTIVE ACTION: CG&E will issue specific instructions to all design organizations presently active on the Zimmer Project to review and/cr implement formal, disciplined design controls. CG&E will develop a program to audit the policies, procedures and methods utilized by the design organizations to meet this requirement. )

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ATTACHMENT TO RESPONSE FOR INSPECTION REPORT #10

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DitAPT - PENDING RECEIPT OP_ FORMAL NRC AUDIT REPORT - POSSIBLE NONCOMPLIANCE NO, 1 ~ Finding Thc finding was that the reference in the FSAR, Section G.3.3.1, for cable at:pacity in trays did not reflect the actual *ref-sr' enc $ used for design. The FSAR staten that."The. tables for,. power cable loading are basoc. on IPCF.A Publichtion No. P-W-426 # Response. . The FSAR Section B.3.3.1.1 Will be..reviched and revisod to-reference IETE Paper 7CTP557 MIR rather..than IPCEA Publ:Ecat:icn No, 9-46-426. Table 8,3-18-was revided..in GQu.s 1976.to. . t iredicate thc.actu w c.sta used'fdr.dssis.S,9however, the..rederence-was oeerlooked in the revision.. This rovicion .will be radG to thh *FSAR .by Uttnta 1981. . . I l l l l

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P0901nu nonccMPLI2rcs no. 2 Pinding The finding was that procedures were not in place requiring final weight calculations for cable trays cxccading a dosion index of 1.25 and thernel check calculations for pgwar sleevea. Respcnse Pro-jset Procedure PI-12-10.1, Revision 0, datcd February 6, .1978, provider 3 the requirements for.perfort:inry final thaml' loading calculations for those cable tray sections exceeding.ca. design . index of 1.25. The project instruction did not explii:titl? . state-that final weight checks are also to- he performed as swell.'as - tharnal checks of power slhaves: . Although the precedure was deficients " worst case".' calculations that were actually performed' included a wcight checksto contirm-cespliance with the tray, design criteria . Final;caldulatlona hnG not been perfon.ed since the cable issues hava not>been cc pleted. Final calculations.are being initiated.in.rseponse to unresolved item below. l Project Instruction PI-ZI-10.1, Revision 1, dated M*.rchi 15, 1981, hos been revised to address the specific findihda: *This'a6 tion

• han therefore been completed, h are presently reviewing if there are any further asce:ts of cable tray fill that have r.ot been adoquately addressod.by the Project inchruction.

This revicti will . be corplete by- hp il 30 4 1901. If additional itens are identified, revisions: to. t he-project instruction will be initiated.: s

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POSSIBLE'.'NONCOMPLIANCUI.MO. ?.

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Finding This' finding,waa.n concern;on'.the lack of a forr.a1 proceduYe

                   "- --to control" deviations froc de migri'.:"'~~"" ""~~""~"~~" ' ~~"-"                         '-         -    -

11esponse- - - Deviations from design or procedure are controlled hy.Sagent & Lundy.CA.Proceduraa CC-10.01 and GO-16.01.. The devia'tidns are 3 dent.ified as nonconforrances per GQ-18.01 und correctiw. acti6n report.s generated per GO-16.01. It was observed thnt, while chocking- th's therral'loadi5p;of/ the-cable traya;.the design ampere loading of..hvo cables:were.found: to excced the design Ar.pacity, Tho control of this dem. ate.on. was taintained by the control ofdthe.dd. sign:calculitidsfdi - thene cables. The design calculation vbich specificallyeweted - l the deviation was not approved'by;the. responsible dce4:b9n9 1nect' l due to the exceedence of'ths-cabls'ampereicriterieT .aesol.6 tics of thene cable proble=3 was awaiting actual en:psrei.lb.nihF1 data of the electrical device--for reenlculation: Withholdd:ty. approval of the design calculation assured 'foLloV-up to corrc:rt.:the deviation. The final ampere loading data has been received and the.two cables have been recalculated and found accept.able. .The calcularion

       ..                 has been.revioved and signed approved per sargent e Land /

l Procedurn GQ-3.08. Thin action in therefore complete.: l 1 s 1

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.                                                                                       I In addition to the corrective actions sumr:arized under each of the specific posr;ibl6 noncompliances 4dentified above, the following action will be taken to asseas the project generic aspects and their corrective act3on.to provent recurrences
                  .. Pro' ject Generic Aspecta of Moncon:pliance le 1.

The PSAR will be re-rovicved for correctness 2and..' consistency with ' respect to the design by the responsible.systen:nngineers. This review will be co=plete by July 1981. 2.- A new project proceduro uill' he written estahlistilA@the'.- naed to submit corrections .to the, PSAR as changes:arov . - identified by the . design engineersg. Formal issue;.of the: - FStJL changea will be mado on a semi-annual-basism-- This action vill be imple=ented.by. -nay .30,1981; .

3. The project instruction noted in.Pa'ra' graph-2 wil1 include.e requirement to identify changos .or.< deviations ftcut infustry codes and standardat i;e . . ASMt . AWS , ANS't, etc ;; .when.>

                         ~~~Eppli'eT 'c'nhiig6rien11y in the desi gn .. .

Prodect Generic Aupects of Noncompliance.2 are addressed rin the-continuing. procedural roview of cable tray fill'addfessed under Nonconpliance-2. . ,, Project Generic Aapocts of Noncompliance.32 1. SEL is reviewing within the office on a company generic basis the adequacy of.the procedure of uning design ca.iculations to control dnviations. SLL will review the existing procedures, including CQ proceduren, project .instructionsf.genm al.- w O

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drafting standards and department standards to determine-if additional controls are requirca. The review ulil be completed along with identification of specific corrective actiona by June 1, 1981. As further clarification, generic aspects of the adequacy of procedural control will bo applica on tho zirmer.Froject. o O 4 9

i DRAPT - PENDING RECEIPT OF POR!IAL MRC AUn1T . REPORT UKRESOLVED. ITEM 1 iter 1 Mr. Barrett would like further explanation of the justification for calculating weight and thermal loading of only.those. trays with design index greater than.l.25.

Response

Sargent .& Lundy- Will prepare a -justification de:nonstrating. adequate .therral and. weight dcsign for those cabl6..t2:ay.4aectionc , with a de' sign index less than 1.25.: 'Thd dustification..w M V be. provided to The. Cincinnati Gas.& -El'ectric Co:npany...(CGsEPerd to Mr. Barrett by June 1, 1981. DMRESOLVED ITEM 2 Iter. Sergent & Lundy will perform final.therr.al and weigi;cicaldulations for All power trays %ith design index. greater than l.2571 final-therani calculations for power aleeves with~ design:ind o granter than 1,.25, and final weight calculationn.for control and.*idstrument trays-with design index greater than 1.25~. Respenso Thene calculations or justification will be provided. to. CGsE and to Mr. Barrett by July 1, 19Hl. DNRESOLVED ITai 3 I to. t

                  'i Barrott Uculd like further annuran.::e that cableMrayn excraeding 50% fill (design index 1.25) arEadequately analyced.-- .

a L.. .. . I. l Responso e

                         , The FSAR will bc ravised for the ncxt scheduled revinien to add' a..atatewf,nt to. the cRtoct .that, .when the design epoint ir, exceedede the adequacy is checked by analysis,                                          T is will clarify that.a21 cables in traya excceding the design. index -

of 1,25 v111.ha.va...c.alculations .porfo ned to justify .thh dshign. Project Instruction -PI-21-10.1 requires final.calcTaiettons for.allfcabisrt. ray.sectionsexceedihy.adcsignh.ndo cf d.25e. UNRESOLVED dTan 4

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Mr. B4rrett..would like further clarification-on the. relet:1caship; - of. percent tray: fill and dssign,$nder ;. noupona.. The rotationship of. 50f. tray fill and 1.25.. design- indscwas - sum:arized and a copy, was given* to-Mr.i ;EarYctt and4GE2 ion March 20,1981 Ahile in our office fet: tha exit : interview - i

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          . INSPECTION REPORT #11: LACK OF CG&E FOLLOW-UP ON REPETITIVE PROBLEMS (INADEQUATE CORRECTIVEACTION)

PROBLEM: Repetitive problem regarding design calculations and verifications not being performed by Sargent & Lundy. CASE: Five audits by CG&E identified this problem. CORRECTIVE ACTION: Responses to audit findings now require that corrective action taken to avoid further noncompliance must be supplied by the auditee. In verification of this action, the auditor must have assurance that this corrective action is adequate to address any possible generic deficiency. Also an Unresolved Deficiency Su mary is issued monthly from the Manager-Quality Assurance to the Senior Vice President and the Manager of any organization responsible for corrective actions to deficiencies that are past due. This ' includes deficiencies which are delinquent past the due date and deficiencies which have exceeded the planned completion date and QA verification was not possible due to lack of, or inadequate corrective action on the part of, the audited organization. The deficiencies addressed by this procedure are those identified during audits conducted in accordance with audit and surveillance procedures. A new procedure has been established to define the method for the reporting of repetitive, generic, procedural, or significant concerns adverse to quality to the appropriate levels of management. Conditions for which Corrective Action Reports are issued as follows:

1) The condition indicates a trend of declining quality.

n ,. 's - CORRECTIVE ACTION (CONT'D.)

2) The condition is repetitive indicating current controlling measures are inadequate or insufficient.

3) Evaluation indicates that the condition is a result of a program deficiency.

4) The condition indicates failures to obtain required approvals for changes in procedures or documents.

5) Failure to resolve a deficiency in a timely manner.

6) The condition indicates negligence or disregard of document or procedural requirements.

7) QA follow-up review of conditions adverse to quality show that the approved corrective action has not been taken, or has been improperly or incompletely accomplished.

The Corrective Action Reports are distributed to the appropriate management of the organization to which the corrective action.was addressed as well as those responsible for implementation of the corrective action and the CG&E Senior Vice President. l ,

                       - CAR's must be responded to and corrective action verified within 10 working days or a Stop Work Order is issued in accordance with the applicable Stop Work Order Procedure.

D

Inspection Report #12. Problem: CG6E has not performed any audits to verify compliance with and the effectiveness of the SQL non-conformance program. Case

• The response to this concern .is covered in Item 10 of the Immediate Action Letter.

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INSPECTION REPORT #13 - DELETED DESfGil CRITERIA PROBLEM: Weld inspection criteria has been deleted from the KE-1 form 4 from 7/80 - 2/81. CASE: Weld inspection criteria has been deleted from the KE-1 form for AWS structural welding on the drywell steel, and other instructions added as follows: Deleted: Item 1 on KE-1 form in its entirety Added: Item 1 on KE-1 form " Rod slip (KE-2 form) to be part of package" Deleted: Item 2 on KE-1 form except for " Verify Mark Numbers" i Unless the welds are full penetration welds, this criteria need not be hold points; however, proper weld procedure, welders qualification and proper filler netal verification must be conducted prior to weld acceptance. (See KE-2 form) CORRECTIVE ACTION: All AWS structural steel KE-1 forms from 7/80 - 2/81 will be

,                                                           checked to ensure that no hold points were violated for full penetration welds. Any welds so found will be documented on a nonconformance report and properly dispositioned and corrected. A sampling of the structural welds that had weld inspection criteria " improperly lined out, noted as not l                                                            applicable, or otherwise deleted" will be conducted to verify from the record that the weld inspection criteria required by

, AWS can be verified. If required inspection criteria cannot be verified, then those welds will be documented with a non-l J conformance and corrective action defined and documented.

;                                                           This action was initiated to eliminate an overcommitment.

9

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INSPECT 10N REPORT #14: NONVERIFIED SOCKET-WELD FIT-UPS PROBLEM: Socket weld fit-up has not been verified on numerous small bore pipes. CASE: According to HJK Procedure SPPM 4.6 and the KE-1 form used for the inspection of small bore piping,~ the fit-up of socket weld joints is required. ASME Section NB4427-1 requires that approximately a 1/16" disengagement be met on socket welds. Numerous _ socket welds have been made without the proper documentation witnessing the proper visual inspection of pipe fit-up as documented on several surveillance reports. CORRECTIVE ACTION: A review of the completed document packages for small bore piping will be conducted to determine those - socket welds for which a verification was not made for disengagement. Any joints so identified will be documented on a nonconformance report, with a disposition to radiograph in sufficient quantity to develop a level of confidence that the fit-ups are acceptable.

4 , 4 INSPECTION REPORT #15: DELETED INSPECTION REPORT #16- . Response covered in Item 8 of the Immediate Action Letter. i t es i 1 4 i 1 . I i i i i l I. i t 4 l 7 s . f f

                                                                                                                                   - ._-. - . = .-.. , . ... . - ..

INSPECTION REPORT #17 - UNCONTROLLED DESIGN DOCUMENT CHANGES a PROBLEM: The KEI Configuration Control Center does not know the status of DDCs written prior to late 1980 . . . . When a DDC is written against one document and subsequent changes are made to one or more other documents (drawings) not referenced by the original DDC. CASE: In accordance with Sargent and Lundy project instruction PI-ZI-2.1, the designer is responsible for ensuring that all documents that require a revision by a DDC are in fact, revised even though all affected drawings are not stated on the DDC. For the past year, CG&E and S&L have been in a mode of resolving all DDCs which still appear open in the Configuration Control - Center master DDC index. CORRECTIVE ACTION: With the issuance of CG&E's GCD ADMIN-5 procedure on DDCs, S&L is going to revise their project instruction PI-ZI-2.1 requir-ing that a cover sheet be attached to the DDC indicating all drawings affected by the DDC and forwarded to the HJK Configur-ation Control Center. This will allow the CCC to close out the DDC when all affected drawings are revised and issued. l Sargent and Lundy has already revised their project instruction which states " Essential DDCs shall be incorporated into the next revision of the engineering design documents but shall not be carried beyond two revisions of the document, or two months, whichever is less." When this procedure is fully implemented by S&L, there will be very few open DDCs and HJK CCC will be able to accurately monitor all open DDCs. e

                                                                                                   .O

INSPECTION REPORT #17 - UNCONTROLLED DESIGN DOCUMENT CHANGES - cont'd.

 .                                                                                       .s Page 2 CG&E through the HJK CCC will continue to review all open DDCs and reconcile the open listing with the S&L status listing. Upon completion of the reconciliation, this program will be maintained to ensure that outstanding DDCs as shown in the HJK CCC are in accordance with the S&L DDC completion.

O e

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                                                                                                     )
          ~

l INSPECTION REPORT #18: PROBLEM: H. J. Kaiser Procedure SPPM 4.6, Rev. 8 and S&L Specification H-2173, Supplement 7, (Standard EB-ll7 for cable tray hanger welds) takes exception to A.W.S. D1.1-1972 inspection acceptance criteria for undercut. The FSAR does not stipulate these exceptions. CASE: Sargent & Lundy approved this exception and had not as yet modified the FSAR. CORRECTIVE ACTION: The FSAR will be modified to include this exception. A generic response on Design Control Criteria is given in Item 6 of the Immediate Action Letter. e w w-w- ---- - -

    -9                          - - - -

7-.,-n-, _,,_m,. ,,i--

_,._s_ -t_. . RESPONSES TO APRIL 8, 1981 IMMEDIATE ACTION LETTER

1_ 7,.. a IA[. 1. Concerning QA Staffing The following corrective actions shall be implemented to increase and improve the CG&E Quality Assurance staff. A. Quality Assurance Engineering Six (6) Quality Assurance Engineers shall be added from a contract organization on a temporary basis. Such personnel will have experience in metallurgy, welding, documentation and procedure reviews and similar Quality Engineering expertise. They will have varied discipline capabilities and should start to arrive on site May 4, 1981. It is anticipated that they will supplement the Quality ssurance staff for one year or for however long required. Additional requisitions have been approved for permanent CG&E staff Quality Assurance positions for the following:

1) Metallurgical and Weld Quality Assurance Enineer (1)

2) Electrical Quaiity Assurance Engineer (1)

3) Structural Quality Assurance Engineer (1)

CG&E Electric Production Department personnel with Quality Assurance experience shall be incorporated into Corporate -Quality Assurance Organization. These personnel have experience in structural, chemical and operations expertise. These personnel will be utilized to supplement the present auditing staff and shall be certified to N45.2.23. Some of those personnel presently in the Quality Assurance organization shall be reassigned outside of the Quality Assurance organization or j replaced. B. Quality Control (Inspection) Ten (10) qualified inspectors (45.2.6) shall be assigned from an outside contractor for a minimum of one year or however long required. These

           ,e                                        -2
   ;V . ' ,
                                ~

B) Cont'd. - personnel shall have experience and qualifications in varied areas of inspection requirements. One individual capable of being designated as a Level III NDE Technician will be included in this group. The other will also be qualified in PT, MT, RT, UT or visual inspection of welds as required by their assignment. present personnel in the Quality Assurance organization will be reassigned or assigned as follows: D. C. Kramer - Lead Quality Cofitrol Inspection Supervisor R. N. Taylor - Pipe Support and Inspection D. C. Fox - Pipe Support and Inspection W. Hopka - Pipe Support and Inspection Two inspection technicians, qualified to N45.2.6 shall be reassigned from the Electric production Department to assist in the resinspection l verification. A requisition for a technician with inspector's expertise in NDE, capable of certification to Level II of ASNT TC-1A, with eventual certification to Level III has been approved and search is in progress to locate and hire this individual. . C) Miscellaneous Quality Assurance / Quality Control Contract personnel have been employed on a temporary basis to - review procedures, correct inconsistencies or errors, and prepare new procedures as required. These personnel shall also assist in preparation and coordination of training schedules. Summary of Additions Temporary Personnel * - Temporary 6 Quality Assurance Engineers 10 Quality Control Inspectors 2 Misc. QA/QC 18

              ,             #,.                                                                                                   y:.

1

CG&E Staff Additions i

! 4 Transfers from EPD j 1 NDE Technician 3 Quality Assurance Engineers 8 Existing CG&E QA Staff ! 4 Engineers ~ l 4 Contract Personnel

1 QA Technician 1 QA Manager

Y 1

• As permanent CG&E personnel are added these may be ' reduced.

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      . - . - - . , . _ . . - - - . . , . . . _ - - - , _ . - . - - - - - - . , - . , . . - . , , - . . .                                        -_-,,,-.-,...a.

IAL 2. Concerning independence and separation between Kaiser construction and Kaiser QA/QC In a letter dated April 7, 19 81, to the President of Henry J. Kaiser Company, CG&E outlined the steps to be taken by H. J. Kaiser in their QA/QC effort for the Zimmer project. In that letter the Kaiser organization was directed to eliminate any domination by construction of the QA organization and the QC inspectors. They were further instructed to stress the independence of the QA/QC organization and to provide effective leadership to allow that independence to be maintained and for the organization to properly function. We are also committing to revise the Kaiser QA procedures such that they no longer will require approval by construction personnel. i a N

                ,_ . - . , - ~ - - -           -.    -

p. .

                                         .'                    ..                                                                                                                                                                          t/p6 THE CINCINrJ ATI C A G te Ct.I:"CTT !~. cotAr*Ar;v April 7, 1981 1

Mr. James F. McCloud President Henry J. Kaiser Company 300 Lakeside Drive r.r s Oakland, California 94G23 nU j

Dear Mr. McCloud:

iij. V As you are aware, the Zimmer Project's QA/QC program has been the subject of an extensive NRC investigation over the past few months. Both the H. J. Kaiser program and the CG&E

                                . . ,                      program have been reviewed as the result of several allegations made to the NRC by unidentified personnel connected with the l'i
                        ,                I                 project.

i

'                       !.k ll                                                                                 The NRC has now called to our attention several def1-C                               ciencies in the execution of our mutual programs which surfaced as the result of its investigations and which must be corrected in p            i a timely fashion. My purpose in writing is to outline the minimum

! i steps to be taken by H. J. Kaiser if they are to remain as the 1 Is QA/QC entity for the Zimmer construction effort. These are as q y follows: l' d 1. Eliminate any domination by construction of the H. J. Kaiser Quality Assurance organi=at. ion as well l as the CC inspectors. I I g/ 2. Stress the independence of the QA/QC organization from construction and provide effective leadership i ( t. for that organization, both in the field and in u the corporate office.

3. Add 6 degreed discipline engineers with nuclear site l

experience to review acceptability of data packages. l 4. Construction will keep both the H. J. Kaiser and the I CG&E Co. QA organizations fully informed on all activity affectin7 essential systems. 1 l 5. Stop the voiding of any non-conformance reports and i the transferring of documentation from the KE-2 form i to the KE-1 form. i

   . _ , _ . . _ _ _ _ . _ _ _ _ . _ _ , . _ ~ , _ . . _ _ , , , , , , _ , , , _ , , _ _ _ . . - _ _ _ _ _ _ _                                          -m_.r__r_--_._,__,y..y-       ,, ... _   ,yc...,. ,__. . _ _ __ __-_ . - . . , , ,

i THC CINCIN JATI GAG 0 CLCCTRIO COMPANY Mr. James P. McCloud Page 2 April 7, 1981-

6. Restore n disciplined and rigorous at;proach to the QA/QC program through surveillnnee and comprehensive in depth QA nudits of the Oc activities.

It's disappointing to me to have to write this letter. Since the beginning of construction on the Zimmer project, we have placed our faith in the Kaiser QA/QC program for construction

      'Q and have limited our own QA involvement to an auditing function.

! d I now find that some of our confidence has been mis placed, not in the basic program, but in its implementation.

   ." _n I still have every confidence in the cuality of construc-
'                   tion, but it has become apparent that CG&E must taks steps to take control and become completely involved on a day to day basis in the QA function.       It is our intention to exercise a level of surveillance y@I               over the H. J. Kaiser effort to the extent that Kaiser QA/QC performs
    >    ,1 on a continuous basis to our and the NRC's high standard.
    ;! !                        On a project of this duration, it is not surprising that d
    "               morale and discipline slide from time to time. At this point, however, we cannot allow it to continue nor to reoccur before we                           -

finally achieve our mutual goal of placing Zimmer into successful , .m operation. I still am confident that with the dedicated cooperation l 1! of both our organizations we can complete the Zimmer project with

  'Is pride in a plant that will bring credit to us all in the future.
  ;i

, Yours very truly, '

                                                                           !: M1
       /                                                     W. H. Dickhoner W

! WEDavm i) bcc: E. A. Borgmann J. Coyle B. K. Culver W. W. Schwiers W. D. Waymire

t r IAL 3. Concerning QC Inspections. CG&E will conduct 100% reinspection of QC inspections conducted by Kaiser and other contractors by utilizing additional personnel described in Item 1 above, and qualified personnel already on site. This effort will continue until the CG&E audit program is revised, as outlined in Item 10 below, and accepted by Region III. It is requested that Region III regularly monitor CG&E's progress in developing this program so that prompt reduction in the 100% reinspection requirement can be made consistent with the implementation of the revised audit program. Consideration of stepped reductions in reinspections to 50%, then 20%, and then a continuing surveillance by CG&E qualified inspectors is proposed. b

o

    . Ipa;  4. Concerning Q.C. Inspection Procedures i

All QC inspection procedures are being reviewed by qualified design engineers and QA personnel who are independent of the construction organization. The object of this review is to confirm that the procedures include appropriate inspection requirements and applicab,le hold points. This review is being performed in accordance with an approved procedure that specifies the reviewers qualifications and training, provides instructions for performing the review, and establishes review documentation requirements. Construction activities controlled by these Q C inspection procedures will not be performed until the applicable procedures have been reviewed, 4 comments as the result of this review resolved, and the procedures 1 --approved. d l > I l 4 l l ,i 1 I i

b 9 IAL 5. Concerning Training. , Training on any new procedure or practice resulting from the actions taken to fulfill the provisions of this letter will be given to QA/QC personnel at the Zimraer site prior to implementation of the procedures. Refresher training in quality procedures is underway and will include the four specific areas mentioned under this IAL item. The " feedback mechanism" for informing the identifying individual of the resolution of an item, and the " avenue of appeal" regarding the resolution, as described in the IAL are being developed. All refresher training will be accomplished by June 1, 1981. k i i I 1 e e

                                                 . , . . - -     - - - - ,-     - -          w

                            * /

e i . IAL 6. Concerning-Deviations from Codes and FSAR A. Construction Forces e Project Procedures such as DDC and NR procedures have been in effect continuously throughout construction. These procedures have adequate provisions to assure that deviations to codes or design documents are , identified and dispositioned by responsible design engineers. Prior to May 1, 1981, a formal review of ' ! these procedures will be conducted. I B. QC Inspection Forces

All QC inspection procedures are being reviewed by

, both Design and QA Personnel now. A part of this review is to assure that any deviations from Codes and FSAR , statements are identified and that CG&E reviews and i approves the resolution of such deviations. All 4 construction activities controlled by these QC inspection procedures have been stopped until the applicable procedure has been reviewed and approved. I QC Inspectors will receive training in any procedure i changes which are required. C. Design Forces l i organizations responsible for design of safety- ! related equipment will be audited to assure that i ! they have sufficient procedures and training to identify deviations from codes and FSAR statements. All such l organizations will be required to advise CG&E of any i j such deviations. CG&E will review and approve the 5 resolution. tv'y-y ,-wwe .w4ay-----M+ -- --,,gr- -- *--w-i ,m,y,--------m--e-vg, -,--- 9,m - --- iy-g ----ww-y--a--,-, m---- -r- w- -w ,mep--, -w--t -^--1viu--

IAL 6. Concerning Deviations from Codes and FSAR D. Other Actions by S&L In addition to the corrective actions identified above, the following actions will be taken to assess the project generic aspects and their corrective action to prevent recurrences:

1. The FSAR will be re-reviewed for correctness and consistency with respect to the design by the responsible system engineers. This review will be complete by July, 1981.

2. A new project procedure will be written establish-ing the need to submit corrections to the FSAR as changes are identified. Formal issue of the FSAR changes will be made on a semi-annual basis.

3. The project instructions will be revised to include a requirement to identify changes or deviations from industry codes and standards, i.e. ASME, AWS, ANSI, etc. when applied categorically in the design.

4. S&L is reviewing on a company generic basis the adequacy of the procedure of using design calculations to control deviations. S&L will review the existing procedures, including GC procedures, project instructions, general drafting standards and department standards to determine if additional controls are required. The review will be com-pleted along with identification of specific corrective actions by June 1, 1981.

                                              ,   _ ,-s    > ._y

          .                                                                                                                 l
   .e IAL 7. Concerning the Voiding of Nonconformance Reports The Cincinnati Gas & Electric Company is presently awaiting the response from Henry J. Kaiser on an audit conducted ay CG&E of a sampling of the voided NR's.          The audit requested a 100% review of the voided NR's.

and justification for the voiding or lack of disposition of each NR. A letter has been submitted to the Senior Resident _NRC_ Inspector _commitk

                   .to a 100% independent review of the voided NR's. This review will be performed by a qualified CG&E Quality Engineer. The original copies of the voided NR's are under the control of NRC personnel. Upon their release by the NRC, the independent review will be performed. While copies of each voided NR are available, CG&E has been informed by the NRC that the original copies are more indicative of a representation of the NRC's concerns.                                     .

QACMI G-4, which covers Nonconforming Material Control was reviewed on April 8,1981. The review generated numerous comments mainly in the area of increasing the clarity of the procedure. Examples of some of the coments are as follows:

1. A statement should be added to indicate that only a member of the Quality Assurance organization is permitted to remove any tag that applies to an NR.

2. Under no circumstances should an NR be stamped " void". A separate form should be initiated to cancel the NR with

  ~

sufficient personnel reviews including CG&E.

3. Clarification should be provided regarding the Material Review Board including a statement that CG&E must be in the review cycle regardless of disposition.

                                - -~   m - . -                    ,   ---     --_,

         .           s t

IAL 8. Concerning QA/QC Records All Kaiser QC records were moved to a protected, centralized location at the Zimmer Site on April 7, 1981. (See attached memorandum, Borgmann to Gittings 4/7/81) These records will remain under the care, custody and control of CG&E Quality Assurance Department until agreed to by Region III. Procedures are being developed to implement records handling under this arrangement. Programs for review of the adequacy of these records are being investigated. e h I 4

                       .,.r...~      ., -         - - . . .-- -,     . - , - - . . , - - - - - - - _ . . . -

. CORRESPONDENCE TO: MR. P. S. GITTINGS DATE: April 7, 1981 . FROM: E. A. BORGMANN

SUBJECT:

WM. H. ZIMMER NUCLEAR POWER STATION UNIT 1 - QA/QC RECORDS In order to exercise better control over the QA/QC records, we have decided that these records should be placed in a central location immediately. By the close of business on April 7, it is our intention to have these records moved from various locations around the site into the trailer complex formerly occupied by Foothill Electric personnel. Having these records in a central location will allow us to control the records until a more definitive program with regards to their control and usage has been finali::ed and accepted by the NRC. For some tine we have been concerned about the lack of fire protection for these records and having them in a central location will allow us to install one fire protegtion system for their protection. It is our f urther intention to assign a CG&E individual as custodian of the QA/QC records until further notice. All removal or i'nsertion of records into the files will be under the jurisdiction of our assigned personnel. Your cooperation in effecting an efficient and timely transfer of these records as outlined above is requested. EAB:mjl f$ hr%se- // cc: J. Coyle R. Marshall B. K. Culver W. D. Waymire W. W. Schwiers THE CINCINNATI GAS & ELECTRIC COMPANY - The Union Light, Heat and Power Company

i. IAL #9 - Concerning Conditions Adverse to Quality On April 7,1981, a letter was transmitted to the Henry J. Kaiser Company directing them to submit to CG&E a copy of each new Nonconformance Report or Surveillance Report prepared. A method evaluating these reports will i be developed by CG&E to assure that the validity and adequate control exists regarding these reports. This procedure will be completed May 1,1981 and implemented May 15, 1981. O e i

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TI-IE CINCINNATI GAS & ELECTIllC CO.N!!"ANY CINCINN ATI.Otteo d 520t April 7,1981 KEQ-551 Henry J. Kaiser Company P. O. Box 201 Moscow, Ohio 45153 Attention: Mr. P. S. Gittings , RE: WM. H. ZIleER t!UCLEAR POWER STATIO:: UNIT I - SURVEILLAt:CES AND NR's - W.0. #57300-957, JOB E-5590 Gentlemen: - Effective immediately, one (1) copy of each new or' revised noncon-formance report and surveillance report shall be submitted to CG&E QA. Submittal of these reports shall be made at the time of preparation; for example, if a Nonconformance Report is pre;:ared by an inspector, reviewed by the Lead Inspector, and concurred with by the Supervisor of Inspections, and a control number assigned, a copy of the report shall concurrently be submitted to CG&E for review. If you have any questions regarding this request, please let me know. Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By C %o W. W. SCH;lIEP.S MANAGER, QUALITY ASSURANCE WWS:pa 6 0

e IAL 10. Concerning the Audit Program Additional auditing personnel, as covered under Item 1 above, "QA Staffing" will be added to implement the CG&E audit program. The existing audit schedule will be completely reviewed and expanded to include technical hands-on type audits and audits of a technical nature at all firms providing design services. Personnel from the General Engineering Department will provide assistance in the conduct of these audits. The audits will be in-depth and comprehensive as to the activity being audited. 4

 .                                                             ZIMMER/4-B DRAFT 11/3/81 A
 <         Cincinnati Gas and Electric Company AriN:    Mr. W. H. Dickhoner President 139 East 4th Street Cincinnati, OH 45201 Gentlemen:

ThisreferstotheinvestigationconductedbyRegionIIIduring;tjeperiod p January 12 to October 9, 1981, of construction activities at theAZimmer h b _N

• M eteeg The investigation was initiated as a result of allegations made to the NRC by a Quality Control Inspector who formerly worked at the Zimmer site and by the Government Accountability Project of the Institute for Policy Studies (a non governmental agency) on behalf of Mr. Thomas Applegate.

The results of the continuing investigation reveal a widespread breakdown of your quality assurance program as evidenced by numerous examples of noncompliance with cl:c;rAof the eighteen different criteria for a quality assurance program as set forth in 10 CFR 50, Appendix B. The crus of the breakdown was your failure to exercise adequate oversight and control of your principal contractors to whom you had delegated the work of estab-lishing and executing quality assurance programs. Youtherebyfa(kggypo fulfill your vital responsibility as described in Criterion I ofjAppend'ix B to assure the execution of a quality assurance program. The potential safety concern of your quality assurance program breakdown was discussed during an enforcement conference at our Region III office in Glen Ellyn, Illinois, on August 5,1981, attended by you and members of your staff and the NRC Region III staff. ep h y % kg % \-V~- Two of the violations (Items A and q are of particular concern to us because of the very essential role they play in the execution of an effective quality assurance program. These two violations relate to false records and to harassment / intimidation of quality control inspectors. With regard to false records, the examples we identified raise scrious questions as to the accuracy of quality records at the site. Our concern in this area served as a major factor in requiring the conduct of a con-firmation program to be completed by you to furnish evidence of plant quality. Because the NRC inspection program is a sampling program, the importance of accurate quality records cannot be overemphasized. Accord-ingly, we have addressed this matter as a separate violation and assessed a separate civil penalty for it. With regard to harassment / intimidation of Quality Control Inspectors, we have also addressed this matter as a separate violation and assessed a separate civil penalty for it. We determined that your construction contractor took some action to stop the water dousing of Quality Control Inspectors; however, those actions did not stop the activity. Harassment / intimidation of quality control inspectors is clearly a barrier to effective implementation of a quality assurance program and results loss of the organizational independence described in Criterion I ot}dp,p{n, en dixTheB. importance of this matter is reflected in the recent amendment (Public Law 96-295, June 30, 1980) to the Atomic Energy Act of 1954, which added Section

ZIMMER/4-B DRAFLI.1]3/81

                             '                                                                                  M w.pu.&-Awhb A.y& un ronS~
      .                    Cincinnati Gas and Electric                      -

2- T Company 235 relating to protection of uuclear inspectors such as your Quality

    /                     Control Inspectors.
 / tv, <

t 6 , N ,; , The impact of the identified quality assurance deficiencies on the actual 2- -! construction has yet to be determined. Limited independent measurements h N $ were performed by the NRC in selected areas of concern in an attempt to

     , 35 R.              characterize the actual safety significance of these deficiencies. Al-
          ,71            though a few problems requiring corrective action were identified (i.e.,

q *I % ' four unacceptabg, installed pipe hangers), the majority of the tc._ : ;;d 4

   'C-                                             l f ,y .emem+a+44fdydid not disclose hardware problemE.{ Ncognizing(the nig;;fI
          ,11            e quality assurance problems identified during this investigation, the
      'i                 NRC has required the establishment of a comprehensive Quality Confirmation

[ [j b; Program to determine the quality of plant systems important to nuclear

  ,;      E g ,,. safety. The NRC will confirm the adequacy of the program andEil 2 h. g vaake-J 7 .;l additional independent verifications. Deficiencies identified by these
      ,y M <j>j gl        q programs will require resolution prior to issuance of an Operating License.

1 2 - j 4 Notwithstanding the fact that serious construction deficiencies have not M !. r I been identified, in order to emphasize tha_- ' M m - -- ty t'- - ::.__, ' - - -- + ' i = : l i ; ; c J. 1. , _ m m 9{'~9-4l1:r ?I j'_. , .i b .: y- ' ' + '; - r--- ,. ,..

                                                                                         .L_ h. ; ii;i ;;nc.:1-'
  ,e } },Q               L       . . . .      . .. . . .     . . Z A . . m. , we propose to impose civil penal-iE"" J ) h2         ties  in   the    cumulative        amount   of Two Hundred Thousand Dollars for the matters in the Notice of Violation.

4 Qi,A k % nwn 07) Some of the examples in the Notice of Violation occurred end G ithe revised

    ,      i            enforcement policy and some prior to that time.                      I.. hi: - ;ri c h_ -

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ri ' ; " + " r un t :' 'h: ;r r^- ' -i il ;---11 _

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                             -  " ^-

- -. In arriving at the amount of the proposed civil af penaltiesnwe4 considered the amount of the civil penalties that have been l iv, issued to licensees of other plants under construction - ' ^ -'^^^^- '

if i  :: '^- - --

                                                     ;-liri- A We believe our proposed amount provides $ssurance Q; f             r that you will tuily appreciate the significance of the violations and will

- result in an adequate deterrent against future similar violations by you i !- and other licensees of plants under construction. We have for convenience and clarity categorized the items in the Notice of Violation at the Severity

' Levels described in accordance with the Interim Enforcement Policy published in the Federal Register, 45 FR 66754 (October 7, 1980). C{ A*I h '( The results of this investigation and our review of your 10 CFR 50, Appendix

   .M                   B, noncompliance history. reveal an additional matter which is of significant
  #D 4,

concern to us related to inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate

        < l. -:l!       you were found in noncompliance forty-four times _since December 1979 with
 -$j *:                 thirteenoftheeighteendifferentcriteriaoY~'p$d6dixB.               AA                 During our
           ,            Systematic Assessment of Licensee Performance review on December 16, 1980,
          .4l           we expressed concern with your relatively poor performance in this area.

l ZIMMER/6-B DRAFT 11/3/81 l

  .            Cincinnati Gas and Electric                             Company ic *.FR %,.

This poor history of compliance with Tconsidered with the recent findin~gs-)ofAppendix the investB,whenA

                                                                       ~i~gation indicates that your corrective actions rerily only addressed individual problems and not 44e. underlying programmatic causal factors.,o Cogg.equently, we request that you review your history of noncompliance with Appe,hdix B6 for the past two years and in your response to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors related to the noncompliances.

You are required to respond to the Notice of Violation and in preparing your response you should follow the instructions in Appendix A. You should give particular attention to those actions designed to assure continuing compliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce-ment action is appropriate. 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 en-closure will be placed in the NRC Public Document Room. The responses directed by this letter and the enclosed Appendix A are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, Richard C. DeYoung, Director Office of Inspection and Enforcement s Enclosureg Appendix A, Notice of Violation and Proposed Imposition of Civil Penalty and Appendix B, Cross

References:

Noncompliance l to Report Details i cc w/ encl: ! E. A. Borgmann, Senior Vice President, Engineering Services and Electric Production J. R. Schott, Plant Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Power Siting Commission

ZIMMER/4-B DRAFT 11/3/81 . Cincinnati Gas and Electric . Company Citizens Against a Radioactive Environment Helen W. Evans, State of Ohio

ZIMM/IC DRAFT 11/4/81 Appendix A NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Cincinnati Gas and Electric Company Docket No. 50-358 Wm . H. Zimmer Nuclear Power Station Construction Permit No. CPPR-88 EA No . 82'- ljL 2 As a result of the investigation conducted at the Wm. H. Zimmer Nuclear Power Station in Moscow, Ohio, on January 12 - October 9, 1981, the vio-lations listed below with multiple examples were identified. The numerous examples of the violations demonstrate your failure to exercise adequate oversight and control of your principal contractors, to wh2a'you had delegated the work of establishing and executing quality assurance prog, rams, and thereby fulfill your responsibility of assuring the effective execution of a quality assurance program. Your failure manifested itself in a wide-spread breakdown in the implementation of your quality assurance program and caused the NRC to require an extensive quality confirmation program to provide confidence that safety-related structures, systems, and compon-ents will perform satisfactorily in service. Included in the breakdown were findings we consider to be'particularly disturbing relating to false records and harassment and intimidation of quality control inspectors. jfBecaust of the_a_ f:( ';i-..._ : ' " ;;:l l , ______.:: ;-^;--- ' : _ _ .. eewn, in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, FL ; ;1g and 10 CFR 2.205 in the amounts set forth for the violations listed below. 4 A. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient t records shall be maintained to furnish evidence of activities affecting quality." Contra ry to the above , _-----"  :- -

                                                                              ;1:: ;f records were identified that did not furnish evidence of activities affecting quality in that they were false. Examples of false records are as follows:

1. Isometric drawings or other records did not furnish evidence of the actual piping components installed in the 10 pipelines in the diesel generator cooling water, starting air and fuel oil systems, in that the heat numbers recorded on the drawings did not match the heat numbers marked on the respective components.

The 10 pipelines were:

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ZIMM/IC DRAFT 11/4/81 I Appendix A IDG28AB1 1DGC5AA3/4 1DG27AB1 1DGF6AA1/2 IDG01AB1 1DGC5BA3/4 IDGF2AA1/2 1DGF6BA1/2 1DG28AE1 IDG25AC2

2. The Kaiser Nonconformance Reporting Log did not reflect all reports initiated as evidenced by the following:

a. The original entry for a report (CN-4309) initiated by a QC Inspector on JanA),/ 7, 1981, relating to deficient weld fit-up was eliminated by whiting-out and there was no other record of this report in the NR system. 2

b. The original entry for a report (CN-5412) initiated by a QC Inspector on February 3, 1981, and relating to violation of a hold tag was eliminated by whiting-out and there was no other record of this report in the NR system.

c. A report (NRC-0001) initiated by a QC Inspector on February 11, 1981, relating to excessive weld weave was not assigned a number and there was no other record of this report in the NR system.

3.

                                                                           .A=k Written statements as to planned actionsAwere made to justify voiding reports E-1661 (voided 11/11/80), E-1662 (voided 11/11/80),

and E-2466 (voided 6/30/80) . . m.. . . . . . . . were not taken.

4. Written stage, gents relating to the availability of records which were a E-1777 A E-5108 r O: :'.75, Cl! I'?7, :! C'7" were false.

(.ma- tu p:% nA.~t g g; This is a Severity Level ~III violation (Supplement II). , I (Civil Penalty - $50,000) ,

   !   B. 10 CFR 50, Appendix B, Criterion I states, in part, "The persons...

performing quality assurance functions shall have sufficient...organi-l zational freedom to identify quality problems... including sufficient ! independence from cost and schedule." l The Wm. H. Zimmer QA Manual, Section 1.2.3 describes QC Inspectors as members of QAD (Quality Assurance Division) and Section 1.2.4 states, in part, "QAD has been assigned sufficient... organizational freedom to identify quality problems..." Contrary to the above, QC Inspectors did not have sufficient freedom to identify quality problems and were not sufficiently independent from cost and schedule. The results of interviews indicate that

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ZIMM/1C DRAFT 11/4/81 Appendix A some QC Inspectors were: (a) harassed by construction workers and supervisors; (b) not always supported by QC management; and (c) intim-idated. .1_L-_,i --- "__-- -^ -t ti::_ ::ti iti:: ___.3.  ; ,,

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                                                  ' 7 1:   :-t_t;... .     .o  miicuuivo   31.7-
     ---"--- _       y._,__.-     The following are examples of insufficient freedom of  QC    Inspectors,      inclu bem   ding     insufficient freedom from cost and schedulef' i.Wah eomer*4 he                   ti Te a 4 h e.k u,itel:

1. Five QC Inspectors interviewed executed signed sworn statements wherein they claimed they were doused with water (while engaged in the performance of inspection duties) by construction personnel.

Two other QC Inspectors made similar statements.

2. A QC Inspectiou supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were re-assigned by QC management because of complaints by construction personnel. [I: - : --- '"' I'70, C ;'77, ^S '70', .__ :-

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3. Two QC Inspectors executed signed sworn statements wherein they claimed they had been harassed by being searched for alcohol by security personnel at the request of construction supervisory personnel. One other QC Inspector made a similar statement.

4. A QC Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after con-struction personnel complained he had used a magnifying glass to visually inspect a weld when in fact he was using a mirror and either device was an acceptable tool.

5. A QC Inspector executed a signed sworn statement wherein he ,

claimed he was struck by a stream of water from a fire extin-guisher while performing an inspection. -

6. A QC Inspector executed a signed sworn statement 4herein he claimed he was threatened with bodily harm by a construction -

person if he did not pass a weld. ,

7. A Lead QC Incpector executed a signed sworn statement wherein he claimed:

a. he was accused by the QA Manager for holding up a concrete pour when in fact the delay was caused by the concrete trucks being late.

b. construction management frequently approached QC Inspectors and challenged their inspection findings and questioned their judgement.

ZIMM/1C DRAFT 11/4/81 . Appendix A c. the QA Manager said things like "our job here is to accept, not reject 3and we are here to get this plant built."

8. A Lead QC Inspector executed a signed sworn statement wherein he claimed he was relieved of his inspection duties because he con-tinued to submit legitimate nonconformance reports over construc-tion management objections for deficient welds on pipe support hangers. He also stated that QA management had previously told QC Inspectors to not write anything to make Kaiser look bad.

9. A QC Inspector executed a signed sworn statement wherein he claimed be was told by QA managemeg to accept inspected items that werep 12-_: --_;: din acuarykhw..

This is a Severity Level III violation (Supplement II). (Civil Penalty - $50,000) C. 10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear powerplants to document, by written policies, pro-cedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents. Contrary to the above, Cincinnati Gas and Electric Company and its contractors did not adequately document and implement a quality with the requirements of Appendix B as assurance evidencedprogram t4cong,Ns: d :.'... ..-..:x;11__ ~ Lila by - ^ [xamp .

1. 10 CFR 50, Appendix B, Criterion XV states, in part, "Noncon-forming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."

Kaiser Procedure QACHI G-4, " Nonconforming Material Control," provides detailed instructions for the review and disposition of reports (Nonconformance Reports) of nonconforming items. Contrary to the provisions of QACMI G-4, the sample of NRs reviewed indicate significant deficiencies with the nonconformance i reporting system in the areas of voiding of reports, not entering reports into the system, improper dispositioning of reports, and incomplete report files. The deficiencies identified were as follows: Eyg

s.  % we.,NRs related to documentation deficiencies had been improperly voided in that there was no adequate justifi-cation for the voiding. (NR-E-1777 voided 4/30/79, NR-E-2191 voided 2/22/80, NR-E-2233 voided 1/24/80, NR-E-2237 voided 12/19/79, NR-E-5108 voided 6/20/80)

ZIMM/IC DRAFT 11/4/81 Appendix A b. One NR related to nondestructive examination of a T quencher weld had been erroneously closed (not voided) by adminis-trative error. (NR-E-2996 closed 3/17/81)

c. Four reports had been voided by personnel other than the QA Manager. (CN-5122 voided 1/2/81, CN-5476 voided 2/27/81, CN-5477 voided 2/27/81, CN-5479 voided 2/27/81) d.

J,og We rep *k In one case during y rev isions Tsome nonconforming items were removed from a NR without adequate justification. (NR-E-2466 voided 6/30/80) sMee c'ere

e. The followinggfift :: reports had not been issued NR numbers and/or copies of the reports had not been retained in the Site Document Center:

C:: '.20 1 CN-4959 CN-4389 CN-5122 CN-4930 C:; ;' R CN-4931 C:: C '.75 CN-4955 C^! 5'77-CN-4956 0:: ' 7 CN-4957 "': ^^21 CN-4958

                                                            ; f :..  . . ._ _ f ij .:.           inn ::ii;,::: .         -'
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s

2. 10 CFR 50, Appendix B, Criterion X\Istates, in part, " Measures shall be established to n -'- ' n':_. l , ,_. ., . : _ ...r : - -

• W- *A ^A

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     /             (

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                 ./          The Wm. H. Zimmer QA Manual, Section 15.2.2 states, "HJK is h           responsible for identifying and reporting nonconformances in y               receiving inspection, construction, or testing activities which 4              are delegated to HJK Quality Assurance Procedures to assure that nonconforming items are conspicu,o,usly marked to prevent their i             inadvertent use or installation.

b &- j [M AWS Code D1.1-1972, Section 3 and 8.1.5 define requirements for weld quality and address slag, weld profiles, blowholes, porosity, 5./ V 7 and undercut. aQ[g ' I, AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch minimum 9 radius for re-entrant corners. q 'j3.1 0 I' l e .1; Lf.3 f4 vf l

ZIMM/IC DRAFT 11/4/81 Appendix A - 6-Contrarytotheabove[W J Jy,;3 exceryg cu4be cm ed' uwg o- -

a. Based on an inspection of the 25 structural hanger support beams described in Item C.4 below, n\ m

1) Several welds on j/ beams did not conform with AWS

                  ,               'D1.1-1972 requirements in that they contained unaccept-L able slag, weld profiles, blowholes, porosity, and/or N             undercut.

(2) Five beams did not conform with AISC requirements in that the re-entrant corners were notched, creating potential stress risers, instead of being rounded with required radii. 6 (3) Four beams, / of which had unacceptable welds as described in Item C.2.a.(1) above, did not conform with design documents in that they were not specified on any design document.

b. Based on an inspection of abog 100 cable tray hangers in theCableSpreadingRoom,/ElidnotconformwithAWSD1.1-1972 requirements in that the welds contained unacceptable slag, weld profiles, blowholes, porosity, and/or undercut.

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3. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures

shall be established to assure that conditions adverse to quality, l

such as... deviations...and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." The Wm. H. Zimmer QA Manual, Section 16.5 states, in part, g.Q .\ " Vendors, contractors, and subcontractors are required to determine l c 4' g cause and corrective action to prevent recurrence of errors which I

 '?                  _could result in significant conditions adverse to quality."

ASME Code, Section III-1971 Edition, Article NB-3661.5(b) states, g in part, ". . .a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before Jelding." I ASME Code, Section III-1971 Edition , Winter 1972 Addenda, Articles NA-4130(a), NA-4420, NA-4510, NA-4442.1, NB-4122, NA-4451, NB-4230, and NB-3661.5(b) require, in part, in-process inspections for pipe fitup, weld procedure, weld filler metal raceability, and welder qualifications... i 1

ZIMM/IC DRAFT 11/4/81 Appendix A . Contrary to the above, the NRC inspectors identified the following nonconforming conditions that had not been corrected and action had not been taken to preclude their repetition: reme4s Qneelte

a. 4Mnr LicenseeAil-- ifima that the socket engagement (fitup) for more than 439 socket welds was not verified in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b) and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1979.

                                             &         *,n W.a h

b. 3he licensee #.__ ____ that the in process inspections for more than 22 welds in the Diesel Generator cooling water, starting air, and fuel oil piping systems were not performed by Kaiser in accordance with ASME Code, Section III-1971 Edition, Article NB-3661.5(b), et. al., and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1978.

c. Five licensee QA audits (audit performed 8/8-9/74 - no number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of Sargent & Lundy identified repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications and action was not taken to preclude repetition.

4. 10 CFR 50, Appendix B, Criterion VIII states, in part, " Measures shall be established for the identification and control of materials... These measures shall assure that identification of the item is maintained..."

The Wm. H. Zimmer QA Manual, Section 8.2 states, in part, "H. J. Kaiser Company procedures provide that within the H. J. Kaiser Company jurisdiction the identification of items will be maintained by the method specified on the drawings, such as heat number, part number, serial number, or other appropriate means. This identification may be on the item or on records traceable to the item. The identification is maintained through-out fabrication, erection, and installation. The identification is maintained and usable in the operation and maintenance program." Contrary to the above, based on an inspection by NRC inspectors in March 1981 of approximately 25 structural hanger support beams located in the Blue Switchgear Room and the Cable Spreading Room, theidentificationofthematerialin#$61thosebeamswasnot maintained to enable verification of quality.

ZIMM/IC DRAFT 11/4/81 Appendix A - 8-71m ou..m c.omylco .. m 3 m . . .. . .1-_t ti; c f; ,__ y . I mm

                         ;= lit; :f ___..llmo     . . i 1    o.   -mil _; tt: ^5-irr: ; ,---"^-E er!i_!:- :--

5. 10 CFR 50, Appendix B, Criterion III states, in part, " Measures shall be established to assure that applicable regulatory require-ments and the design basis...are translated into... drawings..."

The Wm. H. Zimmer FSAR, Section 8, provides the design basis for electrical cable separation that includes the following: Associated cables (Green / White, Blue / White, and Yellow / White) from more than one Division cannot be routed in the same raceway. (FSAR Paragraph 8.3.1.13.2) Vertical separation of three feet or more must be maintained between cables from different Divisions. (FSAR Paragraph 8.3.1.11.2.1.d) Instrument (low-level signal) cables cannot be routed in the same raceway with power and control cables. (FSAR Paragraph 8.3.1.12.1.3) The Wm. H. Zinger QA Manual, Section 3.3.2. states, " Composite...

                       . drawings are prepared, translating the design concepts into layouts of structures, systems, and components necessary for the construction of the plant."

Contrary to the above, as of March 1981, the FSAR design basis for electrical cable separation _had not been translated into 44ne (3..\ A. m d F)

   '      . ~           drawingst d. :h  y.__  r *he fol'l'owing cable installation defi-cienciesintheCableSpIII3ingRoom:

a. Associated Cable (Yellow / White) No. RE053 for Division 1 l was routed in the same raceway (two-inch conduit and Class IE l

Sleeve No. 79) as Associated Cable (Blue / White) No. RE058 for Division 2. Also, Associated Cable No. RE053 was routed so that in places there was only a vertical separation of four inches between it and cables in Blue Tray No. 2072C for Division 2.

b. Instrument Cable (Green) No. WS714 and others for Division 3 were routed in the same raceway (Tray No. 4638B) as Asso-ciated Control Cables (Yellow / White and Blue / White) for Divisions 1 and 2. This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3029K) inside a White Control Tray (No. 4638B).

i l l l l l _~

ZIMM/IC DRAFT 11/4/81 Appendir A c. Many Associated Cables from all three Divisions were routed in the same raceway (White Tray No. 4080K) including Cable (Blue / White) No. TI192, Cable (Yellow / White) No. RR781, and Cable (Green / White) No. TI816.

d. Associated Cables (Yellow / White) No. TI942 and No. TI943 for Division 1 were routed in the same raceway (White Tray Riser No. RK4627) as Associated Cables (Blue / White) No. TI808 and No. TI760 for Division 2.

e. Many Associated Cables (Yellow / White) for Division I were routed in the same raceway (White Tray Riser No. 4139) as Associated Cables (Blue / White) for Division 2.

Th; :5::: ... ..l. .... J fim mmm m. .cic m . J J... . viici m _.. c f : " : ?;r::'ir; ":;; 1.il: p_. ..m. c.i : _... l.. f :ti.._,

6. 10 CFR 50, Appendix B, Criterion III states, in part, " Design control measures shall be applied to...the delineation of acceptance criteria for inspections and tests."

The W m . H. Zimmer QA Manual, Section 3.13.1 states, in part,

                     " Design control measures also apply to delineation of acceptable criteria for inspections and tests."

q

 /f 5
         }dh         Weld acceptance criteria are required by the ASME Code, Section         ,

III-1971 Edition and AWS D1.1-1972 Code. Contrary to the above:

a. The weld acceptance criteria used by H. J. Kaiser Company from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were i deleted.

l l b. The acceptance criteria for Weld 55H (isometric drawing l l PSK-1WS-32) performed on Service Water System Line No. IWS17A18 by H. J. Kaiser Company in November 1979 were not applied in that they were designated as not applicable. l 7. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test proce-l dures shall include provisions for assuring that all prerequisites l for the given test have been met... Test results shall be evaluated to assure that test requirements have been satisfied." l The Wm. H. Zimmer QA Manual, Section 11.1 states, in part, " Test ! programs to assure that essential components, systems, and struc-tures will perform satisfactorily in service are planned and l l

           ~

ZIMM/IC DRAFT 11/4/81 Appendix A performed in accordance with written procedures and instructions at vendor shops and at the construction site." M. W. Kellogg Co. (pipe manufacturer and agency performing the prefabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "Wherever required, shims shall be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal plus the height of the crown or reinforcement." I ASME Section III-1971 Edition, Winter 1972 Addenda, Appendix IX, h Paragraph IX-3334.4 states, in part, "The shim thickness shall be selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..." Contrary to the above, the NRC inspectors reviewed approximately 800 radiographs involving 206 welds and determined that 187 of the radiographs did not comply with the ASME Code in that there was insufficient shimming of the penetrameter. The radiographed welds were prefabricated pipe welds in such systems as feedwater, diesel generator support systems, and main steam.

8. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design control] shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled...The design control measures shall provide for verifying or checking the adequacy of design."

The Wm. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate quality standards are specified and included in design documents." The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are establisned to assure that any deviations from the applicable standards are controlled."

                     ~1%e AWm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verification reviews are performed...."
                                                %.w,_ a. 3.0.i i TheWm.H.ZimmerFSA4statesthatcableampacityisbasedon IPCEA Publication No. P-46-426. ' U Z ?? .'..Q c3 1e ampacity g M 4 n J

( %.. h ^y'..L M O SAR M "the summation of the cross-sectional areas of l k ***b' the cables shall not exceed 50% of the tray usable cross-sectional , area or two layers of cables, whichever is larger, but not to l exceed 60% of the cross-sectional area in any case."

ZIMM/IC DRAFT 11/4/81 i

  -     Appendix A                                                --

AWS DI.1-1972 Code, Section 3.6.4, states, "For building and l M',il tubular structures, undercut shall be no more than 0.01 inch deep when its direction is transverse to primary tensile stress in the part that is undercut, nor more than 1/32 inch for all Q ther situations." Contrary to the above:

a. As of March 1981, design control measures had not been established to assure that deviations from design conditions (quality standards) identified by Sargent & Lundy engineers were controlled. For example, Sargent & Lundy noted on a calculation sheet dated December 27, 1979, that the design thermal loading for two power cables (VC016 and VC073) in Yellow Tray No. 1057A would allow the cables to be thermally overloaded and no program existed to control those design deviations.

b. As of March 1981, design control measures had not been established by Sargent & Lundy to provide for wrifying or checking the adequacy of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays. g%dd i a .-

c. As of March 1981 the cable ampacity desion hv SarRent & " *-5 O*A #*

Lundy n _ .. ' _ . Owas

                                          not M ed on IPCEA P-46-426 % L m
                                             " 1:  , _ . . . - M t::d y.._
                                                                       . vu liii

eu l G:2 7 :*.' C.^:C , ::::. c-an-si , _J*~7*'

L.~', 2 _..'.._' Z.". Q

d. As of March 1981, the design allowable undercut on cable tray hanger welds was not based on AWS DI.1-1972 Code (appro-priate quality standard). The design undercut was instead based on Sargent & Lundy Specification H-2713, Supplement 7, Sargent & Lundy Standard EE-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph 5.2.9, allowed up to 1/16 inch undercut.

9. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be estab-lished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

The Wm. H. Zimmer QA Manual, Section 10.1.2 states, in part,

                   " Inspections are performed in accordance with written procedures which include requirements for check lists and other appropriate documentation of the inspections and tests performed."

      ~ '

ZIMM/IC DRAFT 11/4/81 Appen6t4 A - 12 - V

                     .;         AWS DI.1-1972 Code, Sectica 3.10.1, requires work to be completed 1 %       and accepted before painting.

r Contrary to the above:

a. As of March 1981, a QC inspection program had not been estab-lished to require verification of separation of electrical cables routed from the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RIl03 and CM111 that had been routed into Tray Riser (Green)

No. 3025A, which extended from Tray (Blue) No. 2077A in the Cable Spreading Room to the Control Room.

b. The programs established for in process and final inspections of welds on 180 cable tray hangers located in the Cable Spreading Room were not executed as required in the AWS D1.1-1972 Code. Specifically, the final weld inspections were made after the welds were painted (Galvanox).

10. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, 1 procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions,

procedures, or drawings." .

The Wm. H. Zimmer QA Manual, Section 5.1 states, " Construction, fabrication, and manufacturing activities which affect the quality of the facility are accomplished in accordance with written instructions, procedures, and drawings which prescribe acceptable methods of carrying out those activities." The W'. m H. Zimmer QA Manual, Section 3.12 states, in part, " Design changes... including field changes, are subject to design change control measures commensurate with those applied to the original design." Contrary to the above:

a. Kaiser Procedure QACMI G-14, " Surveillance Reports," was not appropriate to the circumstances in that it allowed i in process nonconformances which constitute field changes to be dispositioned within 30 days without being subjected t

to design control measures commensurate with those applied to the original design. Examples of nonconformances so dispositioned were identified in SRs F-2899, F-2903, and F-2914.

   -w     v   --y-          -e.                 w. .m---   -                --.- - .

   ~               -

ZIMM/IC DRAFT 11/4/81 4 - Appendix A - 13 - 4

b. Kaiser Procedure QACMI G-14 was not followed in that SRs F-2909, F-3070, F-3071, F-3072, F-3073, F-3074, F-3075, F-3076, F-3083, and F-7019 were not dispositioned within 30 days and were not transferred to Nonconformance Reports as required by Paragraph 5 of QACHI G-14.

11. 10 CFR 50, Appendix B, Criterion VII states, in part, "The

                                                                                                                         ~

effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee...." The Wm. H. Zimmer QA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process, S&L makes an independent evaluation of the bidders' QA programs as a part of their total bid evaluation." 1 Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the control of quality by vendors who had supplied structural beams. Specifically, evaluations of the vendor (U.S. Steel l Supply, PBI Steel Exchange, and Frank Adams Company) quality i assurance programs for control of mill certifications and structural beams were not performed. 1

12. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include... monitoring of work performance, and... include closely-related data such as qualifications of personnel, procedures, and equipment."

The W m . H. Zimmer QA Manual, Section 17.1.4 states, in part,

,                                                " Documentation of all performance surveillance includes personnel j

identification and qualification, procedure, type observation, date of performance, person or organization monitored, results i and corrective action if required." Contrary to the above, the Bristol Steel and Iron Works Quality Control Steel Erection Report, which was a generic form for

monitoring in process steel erection, did not identify closely related data such as weld procedure numbers, types of welding material, welder identification, and specific welds inspected.

13. 10 CFR 50, Appendix B, Criterion XVIII states, in part, "A com-l prehensive system of planned and periodic audits shall be carried

out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."

The W'm. H. Zimmer QA Manual, Section 18.1 states, in part, "QA i Division conducts a comprehensive system of planned and periodic ( audits of S&L, HJK...to verify compliance with all aspects of 1 i the quality assurance program." ' l i l I

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ZIMM/IC DRAFT 11/4/81 Appendix A Contrary to the above, during the past 9 years the licensee's QA Division did not perform an audit of the Sargent & Lundy nonconformance program. This is a Severity Level II violation (Supplement II). (Civil Penalty - $100,000) Pursuant to the provisions of 10 CFR 2.201, Cincinnati Gas and Electric Company is hereby required to submit to this office within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial; (2) the reasons for the vio-lation if admitted; (3) the corrective steps which have been taken and the 4 results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Any statement or explanation may incorporate by specific reference (e.g. , giving page and paragraph numbers) the provisions of your Quality Confirma-tion Program and your actions in response to our Immediate Action Letter of April 8, 1981. Consideration may be given to extending the response time l for good cause shown. Under the authority of Section 182 of the Act,

42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Cincinnati Gas and Electric Company may pay the civil penalties in the cumulative amount of Two Hundred Thousand Dollars or may protest imposition of the civil penalties in whole or in part by a written answer. Should Cincinnati Gas and Electric Company fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above. Should Cincinnati Gas and Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in-this Notice; or (4) show other reasons why the penalty should not be im-posed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties. Any answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. Cincinnati Gas and Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty. Upon failure to ppy any civil penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Sectica 234c of the Act, 42 U.S.C. 2282.

    ,                                                                                                                                                           ZIMM/IC DRAFT 11/4/81 d                                                 Appendix A                                                                                                                                         FOR THE NUCLEAR REGULATORY COMMISSION Richard C. DeYoung, Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this     day of                       , 1981 O

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