ML20087D113

Forwards Natl Board of Boiler & Pressure Vessel Inspectors 840229 Ltr to State of Oh Re Util Abandonment of Facility as Nuclear Unit & Board Willingness to Provide Support Should Plant Be Reinstated

ML20087D113
Person / Time
Site:	Zimmer
Issue date:	03/05/1984
From:	Harrison S NATIONAL BOARD OF BOILER & PRESSURE VESSEL INSPECTORS
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
NUDOCS 8403130288
Download: ML20087D113 (17)

Text

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GIje~ National Bourb of Bailec and (Jressure Ilessel iluspectors S. F. HARRISON, Executive Directar 10 CRUPPER AVENUf WILLIAM CIMINO 80ARD OF TRUSTEES COLUM8US. OHIO 43229 U S A. State of Colorado B L Virein f , Cra'rma* ne 6 4 8320 y , 0 W. COLE Rafeigh. Nwth Carnhna Provirce of Briftsh Columbia fl K. BLOSCH.1st vece Chm . . .

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v Mr. William Dircks, Executive Director ENF File h yj U.S. Nuclear Regulatory Commissiors 7/35 Old Georgetown Road Bethesda, to 20014

SUBJECT:

National Board Audit of the ASME Code Related Construction of the !11111am II. Zimmer Nuclear Power Plant - Moscow, Ohio

Dear Mr. Dircks:

Enclosed is a copy of our, letter of February 29, 1984 to Mr. Ralph Yost informing the State of Ohio that,,as a result of Cincinnati Cas 6 Electric

~ Company's abandonment of the Zimmer plant as a nuclear unit, the National Board would be willing to furnich whatever' support deemed necessary should it be reinstated.

Very truly yours',

, i S. F. Harrison Executivt Director SFil/j sb Enclosure cc: Victor Stello, NRC - Bethesda, MD James Keppler, NRC - Glen Ellyn, IL Wm. L. Forney, NRC - Glen Ellyn, IL P. P. Gwynn, NRC - Zimmer Site, Moscow, 0 11 MAR 8 jggy 8403130280 0 8 PDR ADOCK 0 PDR y

Gl}e National Ocarb of Coiler anh TJressure liessel 3nspectors S. F. HARRISON. Executive Director 5 CRUNER AVENW WILLIAM ClwNO BOARD OF TRUSTEE!. COWMBUS, OHIO 43229 U S A. State of Cetorado

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J. J. DUFFY C H WALTERS. 2nd Vice Chm.

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• 1979 64th 19B3[ >  :,

' J. T. CROSBY, Past Chawman

%" ANNIVERSARY Lattle Rock, Arkansas February 29, 1984 Mr. Ralph Yost, Acting Division Chief Department of Industrial Relations ivi"i " '" * "" 'nspection 0 2323 West Fifth Avenue P.O. Box 825 Q Columbus, Ohio 43216 O

Subject:

Zimmer Nuclear Power Plant Moscow, Ohio

Dear Mr. Yost:

As you are aware, The Cincinnati Gas & Electric Company announced on January 21, 1984 that all nuclear construction on the William H. Zimmer Nuclear Power Station was to be immediately halted. As part of that announcemcat, CG&E also stated that should the Zimmer plant be completed, it could be as a coal fired plant.

As requested by the State of Ohio, The National Board of Boiler and Prescare Vessel Inspectors had been conducting an audit of the construction activities at the Zimmer Nuclear Power Plant. This audit was being performed on The Cincinnati Gas & Electric Company and its various subcontractors on the Zimmer site.

The purpose of this letter is to inform your office that, because of the January 21, 1984 announcement, the National Board has determined that our continuing the audit serves m purpose. The National Board ceased all site activities on January 27, 1984.

During the period that the National Board maintained an office on the Zimmer site, there were twenty-six (26) instances identified where CG&E or their subcontractors had performed activities that were not within the requirements of the rules of the State of Ohio or the ASME Boiler and Pressure Vessel Code.

After the National Board's arrival on the Zimmer site on March 1, 1982, a close-working relationship was developed between the State of Ohio, the National Board, and OG&E in an effort to correct the previous violations that had occurred and also to close the National Board's identified findings.

As stated earlier, the National Board had identified findings 'in 26 specific areas.

At the time of our departure from the Zimmer site, the National Board had recom-mended to the State of Ohio that 12 findings be closed. Progress was being made in the closure of other findings. It must be recognized that many 'F the proposed corrective actions to close findings could not be implenented because of the stop-work order imposed on CG6E by the U.S. Nuclear Regulatory Commission.

'Page 2 Mr. Ralph Yost February 29, 1984 The Cincinnati Gas & Electric Company was making every ef fort to correct past

. practices and deficiencies. At the timr of the January 21, 1984 announcement,

..the National Board had just completed a review of CG&E's plan to have the Bechtel

. Power Corporation take over and complete the constructior af the Zimmer plant.

The National Board is sad that the proposed plan for Bechtel takeover was not implemented and completed. We feel that completion of the Zimmer plant would have been in the best interests of the Cincinnati Gas & Electric Company and E the citizens of the State cf Ohio.

As always, the' National Board offers our assistance to your office whenever needed. Should the climate and attitudes change, and should Zimmer be rein-stated as a nuclear unit, we of course are at your service.

Very truly yours,

. /'

. F. orri on Executive Director SFH/jsb

• Attachments (4)

• Attachment #1 - Letter of' December 9,1981 from Donald M. Milan, State of Ohio to Earl A. Borgmann, CG&E.

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• Attachment #2 - Letter of January 20, 1984 from S. F. Harrison, National Board to G. F. Cole, CG5E.

• Attachment #3 - Letter of September 14, 1983 from James W. Harris, State of Ohio to S. F. Harrison, National Board.

• Attachment #4 - HJK/Bechtel Plan for Completing ASME Section III Piping Systems at Wm. H. Zimmer. Nuclear Station - Unit 1.

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, . , DEPARTMENT OF INDUSTRIAL RELATIONS

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Omsson of BN;r inspectan 2323 West Fifth A<enue

• P.O. Box B25 HELEN W. EVANS Director Coiumbus, Ohio 43216 p STEPPEN C. t.ANDERMAil g (614)466 2743 Assistant Director JAMES A. RHODES DONALD M. MILAN Governor 3 *

Chief of Dmsion December 9, 1931 !7 ,

i R t C S VEd' Earl A. Borgmann, Senior Vice President .f .I OEC 1119Cj [

Ciacinnati Gas & Electric 13? E. Fourth Street f THE NATIONAL DOARD -

Cincinnati, Ohio 45202

• BOfLER&pagSSUREEgk I.'l3P"C7  !

Subject:

Zimmer Iluelcar Power Plant , IIoscow,1)hi'o'-- -- . _07' ' ----__l .

Dear fir. Borcmann:

As a direct result of recent allecations by the Iluelear.3cculatory

. Commission and a preliminary investigation conducted by fir. I(i E. Jagger, Assistant Direc1.or of Inspections of The !!ational Board of Boiler and Pressure Vessel Inspectors and !Wacif, serious questions regarding the safety and compliance of this plant to State of Ohio rules and standards have arisen.

In order to alleviate our concerns and assure the safety of the people.

of The State of Ohio, I have requested that The :Tational Board of Boiler and Pressure Vessel Inspectors conduct a comprehensive and complete independent investigatf.on into the A.S.T1.E. code related portions of the subject plant and the Authoriced fluelcar Inspector's activitics which comes under the scope of our jurisdiction. This investigatien should be initiated as soon as possible, and will continue in effect as required until said plant becomes operational or coes commercial.

In order for you to initiate and comply with this request, it will be nec.essary for you to make ir. mediate and direct contact with I'r. S. F. Itarrison, Executive Director of The !!ational Board or I r. D. J. f-IcDonald, Director of Inspections who are located at 1055 Crupper Avenue, Columbus, Ohio 43229, Telephone Ifumber 61h-888-8320. They will be able to answer any questions you may have redardir; the investication, and give you approximate estimates of the costs involved, which must be borno in Ll.eir ent.irety by your company.

The benefits and assurances offered by thic investigation are apparent, and your usual fine cooperation is anticipated.

Very truly yours,

/ wl k*hl4 Donald !!. Ililan dig Chief of Boiler Division State of Ohio ec: !!clen " vans - Director of In htstrial Relations S. F. IIarrison - :!ational Board ATTACIDtENT #1_

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' 1979 64 th 1983I > -i J.T.CA 8Y, it harman Peruvio. or. coa ~. _ ANNIVERS ARY ...

January 20, 1984 Mr. G. F. Cole Ass't. V.P. - Nuclear Projects

The Cincinnati Gas & Electric Company Wm. H. Zimmer Fuclear Power Stat:.on U.S.' Route 52 '

P.O. Box 2023 Moscow, Ohio 45153

Subject:

Preliminary Plan for the Completion of'the Installation of ASME Section III Piping Systems at Zimmer (CGSE Letter GFC-84-0023 dated January 16, 1984)-

Dear Mr. Cole:

The National Board has reviewed the subject letter, it.cluding the technical requirements as addressed in Parts I and II, and has comments on both as follows: .

It is regrettable that the Nuclear Regulatory Commission rejected CG&E's proposed Couree of Actica ud.th H.J. Kaiser continuing as the Constructor for the Construction Completion Plan, particularly in view of the plan for Bechtel's participation in. monitoring management and the PVQC program.

>It iP agreed that the subject' plan presented provides a practical method of completing the ASME Section III piping systems. Iloweve r , it should be understood that the referenced agreement is not within ASME Code rules in certhin areas.

The areas specifically referred'to are: a) weld repairs and b) non-conformances. -

There are no Code rules that we are aware of which would allow one Certificate i

Holder to make repairs or correct non-conforming conditions on the work of

another Certificate IIolder, and then allow the second Certificate lloider to l assume responsibility for all the work.

The logical and probably the correct way to approach the situation that exists at Zimmer to date is for IIJK to complete and execute Data Reports for all work performed by llJK. This would include correcting any known deficiencies, com-pleting any partially completed welds, and making all required weld repairs prior to certification of Data Reports by llJK and its Authorized Nuclear Inspector.

Given the situation existing at the Zimmer station today, i.e., the Nuclear

, Regulatory Connission's refusal to allev HJK to perform any construction

activity, the National Board feels that the following conditions must be met

ATTACIDIENT #2

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6. . , ..

q-Page 2 -

J - ' Mr. G. F. Cole. -

Wm. H. Zimmer Nuclear. Power Station ,

3 January 70,.1964 ,. .

1* Require HJK to prepare, execute and certify Data Reports for all work which can be.shown to meet Code requiremet.ts at the present time, or,be brought into Code compliance, within the NRC's imposed , restraints, including certification of the approp-riate Data Reports by their Authorized Nuclear Inspector (ANI).

- 2. Where HJK cannot or shall not be allowed to make the required ,

. corrections, Bechtel will assume the responsibility for com-

, pletion of.these, activities and assume Code responsibility for the total weld, providing all related Code requirements are met.

- -This 'is .to say, where Bechtel . completes . Code work started by HJK,

- "- -i ,

Bechtel assumes all responsibility including as applicable pro-curement, materials, welding, PWHT, NDE, and correction of-deficiencies as documented by HJK and Bechtel on the Transfer

, . Document.. . .

2 '

3. . Prior t'o' implementation of this agreement, both Bechtel and HJK i' -

must have the procedures and instructions which will implement this agreement in place. -

4.- The Nuclear Regulatory Commission should review and accept this course of action.

If the above conditions are satisfied and all outstanding comments on the subject plan can be resolved by all participants to the agreement, the

, National Board will recommend acceptance of this plan to the State of Ohio.

However, it should be understood that the final acceptance is subject to approval by the State of Ohio (Enforcement Agency) and the - Nuclear Regula-tory Commission (Regulatory Authority).

We have eneJosed a marked-up copy of the plan for your consideration.

Very truly yours, p/ -

/

1 . . Harrison Executive Director SFH/jsb Enclosure bec: James W. Harris, State of Ohio kalph Yost, State of Ohio i

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, (**n 'j ' DEPARTMENT OF INDUSTRIAL PELATIONS 2323 West Fifth Avenue P.O. Box 825

'.,,,, Columbus. Ohio 43216 RICHARD F. CELESTE -

JAMES W. HARRIS Governor '

Director

, September 14, 1983 Mr. S. F. Harrison, Executive Director Natior.al Boa'r d of Boiler and Pressure -

Vessel Inspectors

, 1055 Crupper Avenue Columbus, Ohio ^ 43229

Dear Mr. HarriLon:

In confimation of'a discussio'n which I had with your Mr. R. Jagger on June 27,1983,.please accept this letter as our request to continue the

' National Board fulfilling our jurisdictional representation on all nu-clear and boiler / pressure vessel reviews, audits ar.d surveys.

It is our understanding that the National Board will not comit the State of Ohio to anything nor will you make any attempt to enforce the laws or rules of the State of Ohio. Further, we understand that you will report to us any violation or deviations as they might apply to our laws or rules.

We wish to retain the privilege of visitation and observation of the aforementioned activities with the understanding that we need to be kept fully informed.

Thank you in advance for your assistance as we look forward to continued

, cooperation between the State of Ohio and the National Board.

Sincerely, SNiH // 11/1

/ James W. Harris Director JWH:c -

cc: Mr. Hugh McComack, Deputy Director cc: Mr. Ralph Yost, Acting Chief j p- y p p [ p g l

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SEP 151983 j 7:lC !!AT!D!:A'. cC.'J3 c7 1 cC!LE1 T. Erstr.1;!n" '/23sEL q __ IHCF cic.I'1 _J ATTACIC17NT #3

1/12/84 Draft VI HJK/BECHTEL PLAN FOR COMPLETING ASME SECTION III FIPING SYSTEMS AT WM. 5. ZIKMER NUCLEAR STATION - UNIT 1 SCOPE:

The purpose of this' document is to identify the responsibilities of H. J.

Kaiser (HJK) and Bechtel for completing the installation of ASME Section III piping lsys ems at Zimmer.

In the description below, it is necessary to

' understand that 3echtel will be acting on behalf of the Owner (CG&E) as Project Director when approving HJK Code activities and as a NA Certificate Holder when performing Bechtel Code activities. CG&E retains overall responsibility for the piping system and has assigned design responsibility to Sargent and Lundy (S&L).

PART I Basic'Pregises A. HJK shall not perform any additional ASME Section III installation work subsequent to.the date of execution of this Plan. .

B. HJK shall maintain a sufficient organization at the jobsite to perform the following activities:

Page 1 of 10 ATTACID'ENT #4,

. sg 11 c

1. Perform field verification, inspections, and quality documentation

' review and approve the results of tests and examinations performed

- under the auspices of PVQC on portions of the piping system which HJK retains Code responsibility. To the extent possible, the results will be utilized by PVQC.

- 2. Complete and validate the quality verification documentation for the

• precaestion and certification of NPP-1 and N-5 Code Reports and The other information Transfer Documents described in this Plan.

3 Prepare "as-constructed" Code responsibility drawings reflecting

'those portions of the piping system completed oy HJK and for which HJK retains Code responsibility for ,the installation. ,

C. Bechtel shall obtain the services of Hartford Steam Boiler Inspection and Insurance Company to perform the Code required inspections.for the

-completion of installation of the ASME III piping systems by Bechtel.

D. Bechtel, as Project Director, shall manage the performance of the PVQC

-Program - a program to-independently verify the quality of past

' construction. As Project Director, Bechtel shall also, as directed by CC&E, monitor the remaining HJK Code activities including verification, documentation reviews and the preparation of Code Data Reports.

E. When Bechtel completes a Code weld or item that, was previously the i responsibility of HJK, Bechtn1 assumes Code responsibility for that weld , _

or item. The portion of the piping system that is completed and repaired will be identified on the Bechtel N-S Code Data Report.

Page 2 of 10 4

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- Y' a F. Upon completion of PVQC, welds and otner Code _ activities within the piping system shall be grouped into the categories of " complete, "jycomplete" and " nonconforming" for which responsibility for Code compliance _and completion of installation shall te described below:

1. Complete Welds aad other Code activities which are complete to the point of 3

installation,' including an acceptable postweld heat treatment, which conform to the requirements of ASME Section III and for which HJK retains Code responsibility for the installation.

Eramples:

a) . Welds that are complete and conforming and for which the

- required NDS has been performed and accepted by HJK and the ANI.

b) Welds that are conplete and conforming, but for which the required NDE has not been performed for acceptance. The NDE Jubcontractor shall perform the required NDE to procedures approved by HJK and Bechtel, with the reeults being reviewed and approved by HJK and their ANI, and accepted by Bechtel as

- the Project Direcott and their ANI.

c) Welds that are complete, but for which the required NDE shows an unneceptable surface indication or the radiograph is not acceptable due to film quality, shooting technique, density or weld surface roughness that may mask an unacceptable indication. Bechtel shs11 perform the grinling to remove the unacceptable surface indication or condition. The NDE Subcontractor shall perform he required fin.a1 ersmination to procedures approved by HJK and 3echtel with the results being reviewed and approved by HJK and tneir AN!. snt accepted by Bechtel as the Project Director and their ANI. HJK shall verify weld acceptability.

Pace 3 of 10

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2. Incomplete Welds and other Code activities that are incomplete, but which can be completed to meet the, requirements of ASME Secticn III. HJK is respensible for the work and its documentation to the point of HJK completion. Bechtel is responsible for compistion of the weld. The c

responsibility for Code complie,ce of the completed weld or item is transferred from HJK to Bechtel (See Exhibit A)

Er?.mples:

a) -Welds that.are incomplete, but gonforming to that stage of completion where additional welding is required.

b) Flange connection complete, bolting and '.arque not verified.

3 N_onconforming Welds and other Code activities that are nonconforming and require repair, rework or cutout / replacement. HJ.< is responsible for the work aad its documentation to the point of HJK completion. Bechtel is responsible for completing any work and has tne responsibility for Code compliance of the completed weld or item. The responsibility for Code compliance of the completed weld or item started by HJK and completed by Bechtel is transferred to Bechtel (3ee Exhibit A).

Examples:

a) Welds that are complete, but for which the Welding Procedure and Welder 4 alifiestion egnn:t be substsr.tisted and hence the NCR isidispositioned " cutout".

Page 4 cf 10

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b) Welds that are complete, but for which the piping material is

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.not traceable to.the Quality Verification documentation and hence the NCR is dispositioned " cutout".

c) Welds that are complete, but for which the required NDE shows an unacceptable indication which requires repair by welding and hence the NCR is disposition-d " repair".

PART II

, Code Responsibilities For t

Code Data Reporting and Gymbol Stamping A. Welds and other Code activities within the port!.on of the piping system for which HJK has Code responsibility for installation and which as a result of PYQC and HJK verification are detsemined to be complete and confor=ing to the requirements of ASME Section III, shall be processed as follows:

1. Responsibilities for " Completed" Work a) HJK shall:

1) Prepare and sign an N-5 Code Data Report and assigr e-Natinual Board Registration numbars for completed systems that meet the requirements of A34E Section III. Where applicable, for hydrostatic test pressure, HJK shall 4 - indicate "Hydrotest by Others" cn the N-5 when not performed by HJK.

Page 5 of 10 l

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2) Prepare and sign NPP-1 Code Data Reports for field fabricated piping subsssemblies which have not been installed and for which they retain Code respansibility and which meet the requirements of ASME Section III.

3) HJK shall not be required t,o submit an N-5 Data Report prior to Bachtel beginning system completion work for the portions of systems to be Bechtel's responsibility.

However, the Code responsibility drawing for the syste_

which identifies responsibility for Code compliance shall be completed. prior to the work commencing.

4) HJK shall apply the "NA" C' ode Stamp (indicating' responsibility and Code compliance) for the installation of completed piping systems by HJK and that meet all of the requirements of ASME Section III, with the exception of the finsi system hydrostatic test.

5) FJK shall apply the NPT Code Stamp for HJK fabriested piping subssse-blies for which NPP-1 Code Data Reports have been prepared and which cre not included on an HJK N-5 Code Data Report.

b) Bechtel shall:

1) Prepare and sign N-5 Code Data Report (s) and assign Natinal Board Registration Number (s) for each piping system that is completed by Bechtel. The N-5 Data Report shall include the N-5 Data Reports for completed piping systems by HJK and the applicsble Code Data Reports for other components (pumps, vslves, vessels, piping subassemblies, etc.).

Pe ;e 6 of 10 i

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0) When required for modificatin and repairs Bechtel shall b

amend the NPP-1 Code Data Reports for piping subsssem lies fabricated by HJK or others. Bechtel 3hs11 clearly inicate on the back of Form NPP-1 which modifications or repairs were performed by Bechtel. Those ite=s listed on the MJK Data Report, which are then modified or repaired by Bechtel af ter the N-5 Data Report has been completed by HJK shall be shown on the Bechtel N-5 Data Report.

3) Bechtel shall, if required, perform a p~ essure test of the completed and installed piping system as defined in the Design Specification. This pressure test shall include piping systems installed by HJK, indentified on the HJK N-5 Code Data Report, and not previously pressure tested.

4) Bechte: shall apply the "NA" Code Stamp (indicating

• responsibility and Code complinnee) for installation of '

piping systems that were started by MJ:~ nni completed by Bechtel.

5) If modifications or repsirs are required to t nade by Bechtel before receiving the N-5 Data Report far HJE.

Bechtel shall:

O Coordinate with HJK to modify the Code responsibility drawings, indicating that Code responsibility for that work has been transferred.

- The drawings shall be controlled by written and approved procedures with defined nethods of 7 revision approved by HJK and Bechtel.

1

- The S&L Design drawings shall be revised or n a shil bs t;;rovei appropriate enang+  :: . .-

prior to start of .- . . ? re . - -s i l

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o Assume Code responsibility for the weld or item requiring modifications or repsirs.

o Document on the Bechtel N-5 Data Report af ter completion of the modifications or repairs.

M -

B.. Welds and other Coce activities within the portion of the piping systes for which HJK -has Code responsibility for installation which are determined to be incomplete, but which can be completed to meet the requirements of ASME Section III, shall be processed as follows:

1. Responsibilities for " Incomplete" Work:

a) HJK shall:

1) Identify those operations that were completed and conferu to ASME Section III, and those that are incomplete on a Transfer Document (See Exhibit A), signed by HJK and their ANI. The Transfer Document, and supporting Quality Verification documentation, aertifies to the degree of conformance those operatiors performed to the requirements of ASME Section III.

2) The Transfer Document shall include HJK's ASME Certificate of Authorization Number and the expiration date. The signature of the HJK ANI on the Transfer Document shall

, indicate his concurrence with the correctness and accuracy of the Transfcr Document.

l

?sre 3 of 10

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• b) Bechtel shalls'

1) Afford the Bechtel ANI the opportunity to review the HJK Transfer Document and appropriate Quality Verification documentation transmitted to Bechtel. Bechtel shall review the Quality Verification documentation for

' completeness and conformance to HJK procedures, project specifications, and the requirements of ASME Section III.

2i Prior to performing Code work Bechtel shall coordinste the responsibility change with HJK.

3) When Bechtel completes Cole work that was previously the responsibility of HJK, Bechtel is responsible for that Code work. The portion of the piping system that was completed and repsired is identifici on the Bechtel N-5 Code Data Report.

9 C. Welds and other Cole activities within the portion of the piping systes for which ,HJE had initial Code responsibility for installation thst are determine 1 t,o have a nonconforming condition shs11 be processed as follows:

1. Responsibilities for "None,o,nfornin_g" Work:

4 m) HJK shall:

1) Prepsre ionconfocusnee Reports and recommenlei dispositions as spproprista.

Page 9 of 10 L

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2) On " repair"/" replace" disposition, indicate - on Code responsibility drawings as Bechtel responsibility and prepare Transfer Document per Part II. 3.1.a).

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3) On "accepta as is" disposition, indicate on Code .

- responsibility drawing as HJK responsibility.

1 b) Bechtel shalli .

1) Approve disposition of nonconformances. ,

2) Coordinate the transfer of responsibility in accordance with Part II. B.1.b).

3) When Bechtel repairs or rcplaces a portion of the piping system that was previously the responsibility of HJK, Bechtel assumes Ccde responsibility for that work and identifies the work on the Bechtel-prepared N-5 Data Report.

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Page 10 of 10 6

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