ML20053E103
| ML20053E103 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 02/26/1982 |
| From: | Dickhoner W CINCINNATI GAS & ELECTRIC CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20053E100 | List: |
| References | |
| QA-1645, NUDOCS 8206070608 | |
| Download: ML20053E103 (2) | |
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THE CINCINNATI GAS & ELECTRIC COMPANY;q ia h - z" N 1.. CINCIN N ATI OMIC 4 5201 W M. DICRMON ER C
February 26, i:1982 : .o QA-1645 Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Richard C. DeYoung, Director RE: WM. H. ZIMMER NUCLEAR POWER STATION-UNIT 1 NRC NOTICE OF VIOIATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300, JOB E-5590, FILE NO. NRC-1 Gentlemen: -
This letter forwards the complete response to the Notice of violation anc Proposed Imposition of Civil Penalties as stated in our February 24, 1982 letter.
Enclosed are the following:
(1) A ccpy of our response letter of February 24, 1982.
(2) Attachment A, which outlines our review of past items l of noncompliance with 10 CFR 50, Appendix B, and L
steps which have been taken to address underlying
- i. causal factors.
(3) Attachment B, which contains our 10 CFR 2.201 response to your letter of November 24, 1981.
Attachment B consists of a section for each Alleged Violation A, B, and C; a discussion relative to denial or admission of each item within each of the alleged violations; and the corrective action taken and results achieved for each item, along with the action taken to prevent recurrence. The date for achieving full compliance is included in our February 24, 1982 letter.
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g Office of Inspection and Enforcement February 26, 1982 U.S. Nuclear Regulatory Comission Page 2 RE: WM. H. ZIMMER NUCLEAR POWER STATION-UNIT 1 NRC NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300, JOB E-5590, FILE NO. NRC-1 We trust this will constitute an acceptable' response to the subject Proposed Imposition of Civil Penalties, Notice of Violation, and Investigauion Report. ~
very truly yours, THE CINCINNATI GAS & ELECTRIC COMPAN'l g, , ]p , . ., .
W. H. Dickhoner, President
Enclosures:
Three cc: James G.' Keppler, NRC Region III NRC Resident Inspector at Zim er Attn: W. F. Christianson '
Zimmer Project Inspector Region III, NRC 4
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?S THE CINCINNATI GAS & ELECTRIC COMPANY ciscinuci.owo4smol
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February 24, 1982
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Office of Inspection and Enforcement i
U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 I
Attention: Mr. Richard C. DeYoung, Director RE: WM. H. ZIMMER NUCLEAR POWER STATION-UNIT 1 NRC NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED i
NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300, JOB E-5590, FILE NO. NRC-1 Gentlemen:
This letter constitutes our response in accordance with 10 CFR 2.205, relative to the subject Proposed Imposition of Civil Penalties, and our response in accordance with 10 CFR 2.201, relative to the Notice of Violation and Investigation Report.
We have concluded an investigation of each of the allega-tions set out in App.endix A to your' letter dated November 24, 1981.
Our review has been informative and useful in proving the quality of the Zimmer construction. With our Quality Confirmation Program, our enhanced Quality Assurance staff, and our overall- Quality Assurance Improvement Program, additional insight into the quality of the Zimmer Nuclear Project has been provided. All of this will
, provide additional assurance as to the safety of the Wm. H. Zimmer Nuclear Power Station.
, The results of this investigation lead us to the follow-l ing conclusions:
l l a) Although some records examined by the NRC were incomplete or inaccurate, we do not believe any of these records are " false" with regard to either the commonly understood or legal meaning of the word.
b) Even though there were some dousing and water spraying incidents, we found no evidence that QC inspectors were selectively doused and
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Offico of Inspcctich and Enforcemont February 24, 1982 U.S. Nuclear Regulatory Commission Page 2 RE: WM. H. ZIMMER NUCLEAR POWER STATION-UNIT 1 NRC NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300, JOB E-5590, FILE NO. NRC-1 thereby " harassed." In any event, prompt and vigorous corrective action was taken to prevent any potential influence on QC inspector performance. . .
c) Reassignment of inspection personnel .was based on management assessment of project needs and not the result of construction complaints.
d) Threats of firing, searches, and the single threat of bodily harm all appear to lack sub-stance when evaluated in light of the total circumstances.
e) QA Management communications with QC inspectors may not have sufficiently addressed and resolved quality concerns raised by QC inspectors, but this did not cause QC inspectors to be relieved from duties, nor were QC inspectors encouraged to accept unacceptable work.
f) Prior to Ehe d'evelopment of the Quality Confirma-tion Program, our quality documentatic n program l
was not sufficiently implemented, nor was retrievability sufficient, to preclude the existence of some inaccurate records or to provide l the total documentation for a given component or system in every case.
g) Until recently, the Quality Assurance Program was not sufficiently understood by some quality perssanil, which led to misunderstandings and CLT.1- us ans by the NRC Investigators which differ bx x .e cwn.
h) The work in process relating to hanger weld, beam weld, and socket weld inspections was not accurately documented or controlled in all instances, but not all items of noncompliance listed in violation C are well founded.
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e Offico of Inspcction'and Enforcement Pcbruary 24, 1982 U.S. Nuclear Regulatory Commission Page 3 i RE: WM. H. ZIMMER NUCLEAR PCMER STATION-UNIT 1 NRC NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-350,'
CONSTRUCTION PERMIT NO. CPPR-88, 910, 57300, JOB E-5590, FILE NO. NRC-1 ,
While in the Applicants' opinion there is nothing in the Investigation Report to support the allegation of " false" records, the existence of~ inaccurate and incomplete documents is acknowledged. Although some misunderstanding may have existed as to the Applicants' position at the time of the NRC's review, it is our view that such documents had not received final acceptance approval by E. J. Kaiser Company and were not, therefore, quality "re<ords" within the meaning of Reg. Guide 1.88.
We do not agree that the statements made by the con-triiotor's inspectors, when taken in the context of the events, constitute harassment, intimidation, or ai lack of effective QA mar 4agement support. However, the basic facts describing these events are more or less accurate. We do not agree that all of the facts show noncompliance with the specific criteria of 10 CFR 50, Appendix B. +
We do agree, 'as previou's ly stated, that deficiencies existed with the implementation of our Quality,nasurance Program and in exercising sufficient control over our principal construction contractor, but we believe that our overall Quality Assurance Improvement Program has fully corrected these deficiencies.
We are sincerely interested in assuring the continued quality of construction and moving forward with our Quality Con-firmation Program and the completion of the plant. This has been demonstrated by the prompt implementation of our Quality Assurance Improvement Program in response to the Immediate Action Letter of April 8, 1981 and our progress on the Quality Confirmation Program.
Our conclusions do not agree with your findings in every aspect. In our opinion, your investigation mischaracterized our Quality Assurance effort in several instances, as noted above.
In view of our ultimate decision, we have elected not to raise certain ?egal objections to the Notice of Violation and to the Investigation Report. Rather than dwell on our differences at this point we believe it is important that we be free to devote our full resources and attention toward the positive goal of completing the Wm. H. Zimmer Nuclear Power Station in a quality manner.
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Offico of Inspcction and Enforccmcnt Fchruary 24, 1982 U.S. Nuclear Regulatory Commission Page 4 i RE: WM. H. ZIMMER NUCLEAR POWER STATION-UNIT 1 NRC NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED
~ NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300, JOB E-5590, FILE NO. NRC-1 l With this view in mind, and recognizing at the same time the need for improving the implemencation of our Quality Assurance
, Program in several areas, we will submit to the assessment of the l civil penalties for violations A, B, and C as set forth in .
l Appendix A to your November 24, 1981 letter. A check in the amount
- of $200,000 is enclosed as payment for the assessed penalties.
i Your letter also requested a review of the history of i
noncomoliance with 10 CFR 50, Appendix B for the past two years, and a statement of the steps taken to address and correct the underlying programmatic causal factors related to the noncompli-ance. The specific history and actions taken are provided as i Attachment A of this response to be forwarded under separate cover.
A general overview indicates that Ehe action taken to correct the programmatic causal factors related to the noncompliance was provided in our May 18, 1981 response to the Inmediate Action Letter of April 8, 1981.
Our response to the specific items included in the three violations cited in Appendix A to your letter of November 24, 1981, is provided as Attachment B of this response to be forwarded under separate cover. Included in Attachment B as part of our specific response for Violations A, B, and C are the histories of the-l alleged items of noncompliance including the basis for our agree-l ment or disagreement with the items, the apparent reason for the violation, the specific corrective steps taken and results achieved, and the corrective steps to avoid further nonc=mpliance.
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We believe the corrective action stated in our response to the Immediate Action Letter of April 8, 1981 is sufficient to preclude further noncompliance, particularly in light of our Quality Confirmation Program. The data when full compliance will be achieved is tied to completion of that program, currently i scheduled for July, 1982. Full compliance will occur shortly thereafter and, in any r. vent, prior to fuel load.
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l Offico of Inspcction and Enforcement Fcbrucry 24, 1982 U.S. Nuclear Regulatory Commission Page 5 RE: WM. H. ZIMMER NUCLEAR POWER STATION-UNIT 1 NRC NOTICE OF VIOLATION AND PROPOSED
, IMPOSITION OF CIVIL PENALTIES DATED NOVEMBER 24, 1981. NRC INVESTIGATION REPORT 81 DOCKET NO. 50-358, CONSTRUCTION PERMIT NO. CPPR-88, W.O. 57300, JOB E-5590, FILE NO. NRC-1 We trust the above will constitute an acceptable response to the subject Proposed Imposition of Civil Penalties, Notice of Violation, and Investigation Report.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By / o Enclosure W. H. Dickhoner, President cc: James G. Keppler, NRC Region III NRC Resident Inspector at Zimmer Aten: W. F. Christianson Zimmer Project Inspector NRC Region III
. State of Ohio ) ss.
. County of Hamilton)
.\/ *
/.,.// .,. ,.;. Sworn to and subscribed before me this M/ day of Phbrbary, 1982.
j h h &/??^l'!dw '
s' ', # 4 Notary Public I .g '
..' ylRGINIA P. MUHLHOFER mary Podii:. s:ste W #
My Comsmssion Espires MY28*1932 CERTIFIED MAIL RETURN RECEIPT REQUESTED
CROSS REFERENCE TO ATTACHMENT B TO WM . H. ZIMMER NUCLEAR POWER STATION NOV RESPONSE DATED FEBRUARY 24, 1982 Investigation Report Item Page Item Number A.1 A-2 81-13-06A, 81-13-06B A.2 A-6 81-13-02 A.2.a. A-7 81-13-02 A.2.b. A-8 81-13-02 A.2.c. A-9 81-13-02 l
A.3 A-10 81-13-02 l -
A.4 A-12 81-13-02 A.5 A-15 81-13-02 -
B.1 B-3 81-13-38B B.2 B-7 81-13-38B B.3 B-11 81-13-38B B.4 B-13 81-13-38A, 81-13-383 B.5 B-15 81-13-38B B.6 B-16 81-13-38B B.7 B-18 81-13-38B B.7.a. B-19 81-13-38B B.7.b. B-20 81-13-38B B.7.c. B-21 81-13-38B B.8 B-22 81-13-38B B.9 B-26 81-13-383 C.1 C-1 81-13-01 C.l.a. C-2 81-13-01 C.l.b. C-4 81-13-01 C.l.c. C-5 81-13-01 C.1.d. C-7 81-13-01 l
C.l.e. C-9 . 81-13-01 C.l.f. C-9 81-13-01 C.2 C-11 81-13-27 C.2.a. C-11 81-13-27, 81-13-28 l C.2.b. C-13 81-13-12 C.3 C-14 c.3.a. C-15 81-13-05 C.3.b. C-16 81-13-05 l C.3.c. C-17 81-13-35 C.4 C-27 81-13-28 i C.5 C-29 81-13-31 l
C.6 C-31 81-13-23 C.6.a. C-32 81-13-23 C.6.b. C-33 81-13-23 C.7 C-34 81-13-11
CROSS REFERENCE TO ATTACHMENT B TO WM. H. ZLv31ER NUCLEAR POWER STATION NOV RESPONSE DATED FEBRUARY 24, 1982 4
Pace 2 Investigation Report Item Pace Item Number C.8 C-35 C.8.a. C-36 81-13-21 C.8.b. C-38 81-13-19 C.8.c. C-39 81-13-17 C.8.d. C-40 81-13-14 C.9 C-42 C.9.a. C-42 81-13-32 C.9.b. C-43 81-13-13 C.lO C-44 C.10.a. C-45 81-13-24 C.10.b. C-46 81-13-25 C.ll C-48 81-13-29 C.12 C-51 81-13-30 C.13 C-52 81-13-35 I
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C Attachment A TO WM. H. ZIMMER NUCLEAR POWER STATION RESPONSE DATED FESRUARY 24, 1982 HISTORY OF NONCOMPLIANCE WITH 10CFR50, APPENDIX 3 Introduction .
The November 24, 1981 cover letter to the Investigation Report identified inadequate corrective actions taken by the Applicant in response to forty-four noncompliances cited in I.E. Inspection Rsports since December, 1979. It was stated that only individual problems were addressed and not the underlying causal factors related to these noncompliances. The Applicant was consequently requested to parform a review of all items of noncompliance with 10CFR50, Apptndix B for the past two years and provide the steps taken to address and correct the underlying causal factors related to the noncompliances.
Applicant's review of past noncompliances has been completed and is contained herein. This report delineates those items of noncompliance categorized under each Criterion of 10CFR50, Appandix B. An explanation of the cause and corrective action is provided which addresses the underlying causal factors that generated the items of noncompliance.
WHZ 2/24/82 -.tachment A Pcge 2 It should be noted that the upgrading of the Quclity Assurance Program has shown a marked reduction in the number of items of noncompliance cited by the Commission. of the forty-four noncompliances cited in the past two years, thirty-four occurred during 1980, while only ten occurred in 1981 (excluding the three cited in I.E. Investigation Report 50-358/81-13 which, for the most part, occurred pr.ior to 1981 as well).
This improvement is a clear reflection of the measures taken by the Applicant to correct the underlying deficiencies associated with these items of noncompliance and the effectiveness of the results achieved.
Through actions taken by the Applicant in response to the Immediate Action Letter (IAL) of April 8, 1981, and the establishment o f the Quality Confirmation Program (OCP) , it is evident that various steps have been implemented to assure that corrective measures are being taken and to verify the adequacy of the construction of the Zimmer plant.
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.s WHZ 2/24/82 AttachmOnt A Pago 3 <
CRITERION II
" Quality Assurance Program" Noncompliances:
80-16-01 (Open) FSAR, Corporate Quality Assurance Manual and implementing procedures do not identify reorganized QA/QC group.
80-25-02 (Closed) Reactor Controls Incorporated's Quality Assurance Manual did not identify organizational interfaces or personnel authorities and responsibilities.
CRITERICN III
" Design Control" Noncompliances:
80-05-06 (Open) Inadequate design control for safety related small bore piping suspension system.
80-13-01 (Closed) Design of connecting bolts for two whip restraints was inadequate in that bolt dimensions and configurat.on were not specified for construction. (NRC Inspector
WHZ 2/24/82 Attachment A Page 4 verified in I.E. Report 00-22 that this noncompliance was written in error.)
80-19-03 (Clos ed ) Design documents were not in agreement with the Mechanical Department Valve List.
8'0-25-01 (Closed) S&L specification H-2832 did not provide: (a)
Necessary design and acceptance criteria for seismic and transients, (b) Design methods for combining Joads, and (c)
Desi;.7 interface for auxiliary steel and main structure.
81-07-07 (Open) Inadequate design review of Design Document Change WYB-563.
CRITERION V
" Instructions, Procedures, and Drawings" Noncomoliances:
80-07-07 (Closed) QACMI E-16 was inadequate for installation of thru bolts in block walls.
80-08-02 (Closed) Fuel receipt and storage records were not properly stered.
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WHZ 2/24/82 , .achment A Pcgo 5 <
80-19-01 (Closed) Failure to follow SU.ACP.15, Rev. 3; tagging of systems turned over for preoperational testing.
80-25-03 (Closed) There were incomplete procedures, instructions, and drawings for installing the CRD suspersion system.
80-25-08 (Open) Voiding of Nonconformance Reports by the Kaiser Site Quality Assurance Manager was not in accordance with QACMI G-4.
81-08-01 (Open) Failure to follow P0.RD.02 test procedure step 5.2.2.11.
81-15-09 (Clo sed) Failure to follow procedures SU.PRP.12, Rev. O and QA. SAD.07, Rev. 2. .
t CRITERION VI
" Document Control" Noncompliances:
79-37-02 (open) Use of licensee correspondence to document work instructions and failure to update the applicable controlled procedure.
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WHZ 2/24/82 Attachment A Page 6 80-05-01 (Open) No control document for piping erection specification H-2256 to identify applicable Design Document Changes (DDC s) , and Sargent & Lundy design work instructions revised without review and approval by responsible individuals.
CRITERION VII
" Control of Purchased Material, Equipment, and Services" Noncomoliance: ,
81-06-07 (Open) Two rotameters used for containment leak-rate testing had calibration certification from unapproved vendors.
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I CRITERION IX i
" Control of Special Processes" Noncomoliances:
80-07-01 (Closed) Portable weld rod warmers were not plugged in while in use in the field.
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WHZ 2/24/02 AttachmGnt A pago 7 -
80-20-03 (Closed) NDE procedure 4. 5, Rev. 2 does not specify experience requirements for Level II personnel for MT, UT, and RT inspection.
80-25-01 (Closed) There were no authorized ASME welding procedure specification and qualification records for the materials involved in the fabrication of supports and restraints using Unistrut P-1000.
81-03-01 (Closed) Unacceptable radiographic techniques and discrepancies HJK RT reports were observed in four (4) of twenty (20) field weld documentation packages reviewed.
81-21-01 (Open) Failure to comply with ASME code requirements during radiograph examination.
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CRITERION X
" Inspection" l
Noncompliances:
l 79-37-01 (open) Ineffective piping suspension inspection program.
79-39-02 (Open) Modifications are being performed by the electrical test group and not reinspected by individuals other than those who performed the work.
s WH2 2/24/82 Attachmant A Pcge 8 80-15-04 (Open) Program not established to assure'that activities identified on structural design changes (DDC 's ) are implemented in the field and verified by inspection as required by the QA program.
80-25-04 (Closed) Inadequate inspection of the.CRD suspension system by RCI to verify concrete expansion anchor installations or compliance with installation configuration tolerances.
CRITERION XI
, " Test Control" Noncompliances:
80-03-01 (Open) Containment Structural Integrity Test procedure PRP-05 was approved by General Engineering and Quality
! Assurance as of April 5, 1979, but the procedure did not l
. incorporate applicable requirements of the FSAR, ASME Section III code, and Regulatory Guides.
81-01-02 (Closed) Failure to follow requirements of test procedure -
PO.RD.02, Control Rod Drive Hydraulic Preoperational Test.
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WHZ 2/24/82 Attachment A Page 9 <
CRITERION XII
" Control of Measuring and Test Equipment" Noncompliance:
81-08-03 (0 pen) Lack of periodic loop calibrations of essential test equipment.
CRITERION XIII
" Handling, Storage, and Shipping" r Noncompliances:
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79-37-03 (open) Improper storage of Bergen-Patterson snubbers.
l 79-39-01 (Closed) Excessive dirt accumulated on electrical pene t ra ti on terminal block assemblies.
80-08-01 (Closed) Special Nuclear Material Physical Inventory did not include a check of'new fuel' bundle serial numbers.
l 80-12-01 (Closed) Material detrimental to saf ety related cables was i found in cable trays.
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MHZ 2/24/82 Attachment A Pogo 10 CRITERION XV
" Nonconforming Materials, Parts, or Components" Noncompliances:
80-05-05 (Open) Small Bore Piping and restraint nonconformances were not documented as such on Nonconformance Reports but rather addressed through Design Document Changes.
80-09-01 (Open) Nonconforming material was not properly segregated.
80-25-09 (open) Design Document Changes were written to void Nonconformance Reports.
CRITERION XVI
" Corrective Action" Noncompliances: ,
1 79-37-04 (Open) Other noncompliances cited in I.E. Report 50-358/79-37 are repetitive and licensee has not taken measures to correct them.
80-14-01 (Closed) Nonconformances cited in audit report not I
adequately responded to or corrected.
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WHZ 2/24/82 'ttachment A Pego 11 00-14-02 (Closed) Noncon f o rma nc es cited in audit report not adequately responded to or corrected. ,
80-14-03 (Closed) Corrective actions taken to assure weld rod control per FSAR and applicable project procedures have been inadequate. (Portable weld rod oven not plugged in.)
80-19-05 (Closed) Corrective actions taken to assure weld rod control has been inadequate. (Portable weld rod oven not plugged in.)
80-25-07 (Closed) Corrective actions taken ta assure design and installation problems for pipe supports were inadequate.
80-26-02 (Closed) Failure to adequately verify corrective action committed to in Applicant audit report #307.
81-18-01 (open) Failure to take action to identify and correct t
i procedural noncompliances related to System Turnover for preoperational testing.
( CRITERION XVIII i
l " Audits" Noncompliance:
i 80-25-06 (open) Lack of auditing of Reactor Controls, Inc.
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'WHZ 2/24/82 Attachment A Pago 12 UNDERLYING CAUSAL FACTORS FOR HISTORY OF NONCOMPLIANCE WITH 10CFR50 APPENDIX B The Applicant delegated the responsibility for performing the quality assurance function to its constructor. However, the Applicant did not have sufficient personnel in its own Quality Assurance Department to adequately implement the quality assurance program of the constructor.
CORRECTIVE ACTION TAKEN The corrective actio.' taken to assure continued compliance with the requirements of the 10CFR20 Appendix B criteria has been addressed in the Applicant's May 18, 1981 response to the IAL dated April 8, 1981, and through the establishn.ent of the QCP. These measures are being implemented to verify the adequacy of the construction of the Zimmer Station as prescribed in the Final Safety Analysis Report (FSAR) and applicable codes. These actions will further help to assure the integrity of all structures, systems, and components necessary to prevent or mitigate the consequences of nuclear accidents.
Since >sril 8, 1981, the Applicant has completely reorganized the Quality Assurance Department to address the underlying causal factors leading to the issuance of the IAL. The size of the quality assurance staff has been increased to over 200 quality assurance engineers, specialists, document reviewers, and inspectors.
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WHZ 2/24/82 At achmsnt A Pcgo 13 c All quality assurance and quality control procedures have been reviewed for clarity, accuracy, and technical content. The deficiencies identified have been addressed through procedure i
revisions and, where required, new procedures have been implemented.
Individuals working to applicable procedures are appropriately trained to cssure the requirements specified are clearly understood. Each timo a procedure is revised, personnel working to the particular procedure are trained to the changes incorporated in the revision. An improved inspector certification program has recently been implemented l'
and is providing additional confidence that personnel performing quality related functions are adequately trained and qualified in the areas of their assigned tasks. In addition, the qualifications of non-inspection personnel performing a quality function are currently being reviewed.
The Applicant has assumed the complete management function of quality records. A new permanent site facility has been construc'ted for the handling, storage, and protection of such records.
l A Documentation Verification Group has been established to review l essential records for completeness and accuracy. Procedu.es have been implemented to provide improved receipt, control, and maintenance of the aforementioned documentation.
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Assurance that the eighteen criteria of 10CFR50, Appendix B are being implemented by all organizations performing quality related work is provided through an upgraded audit program. The revised audit schedule has been reviewed to assure all organizations performing quality related functions are audited on a regular basis. To enhance
WHZ 2/24/02 Attachment A Pogo 14 the quality of the Applicant's audits of contractors and support '
organizations, the audit group staff has been increased with. qualified personnel. Comprehensive and detailed audits covering a range of topics from program commitments to construction work activities are being per f o rmed. The vendor audit schedule has been reviewed for appropriate inclusion of essential equipment suppliers, and a system has been developed to assure more timely follow-up of audit findings.
Furthermore, a system of tracking and assuring , proper closure of commitments, Nonconformance Reports, and audit findings has been established.
Verification of the ef fectiveness of the constructor's quality control inspection program is being conducted through the 100%
reinspection of ongoing construction work by Applicant personnel and a program to perform a 100% review by an Applicant Quality Engineer of all contractors' Surveillance and Nonconformance Reports. The effectiveness of the constructor's quality inspection program has further been assured by the implementation of new and revised inspection procedures, comprehensive training, and intensified
. programmatic audits. A revised surveillance program is being developed to observe construction activities affecting the quality of the plant. Successful implementation of this program is expected to reduce the requirement of 100% reinspection of constructor's work.
In addition to the above actions, a OCP has been established within the Quality Assurance Department to confi rm the quality of construction work completed prior to April 8, 1981. This program is addressing the following areas of concern:
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WHZ 2/24/82 attachment A Page'15 "
I Structural Steel II Weld Quality III Heat Traceability IV Socket Weld Disengagement V Radiographs VI Cable Separation VII No nconf o rmances VIII Design Control and Verification IX Design Document Changes X Sub-contractor QA Programs XI Audits The QCP is approximately 5b% complete at this time.
Although minor deficiencies have been identified in each area of concern, none has yet been significant to the safe operations of the
. plant during its expected lifetime.
As a result of the above actions, the Applicant has increased the overall effectiveness of the quality organization and has made all personnel associated with the Zimmer Project more quality conscious.
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Attachment B TO WM. H. ZIMMER NUCLEAR POWER STATION RESPONSE DATED FEBRUARY 24, 1982 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES This attachment sets forth the results of our investigation a'nd specific actions for each item listed in Appendix A, NOV Proposed Imposi. tion of Civil Penalties and identified in the subject Investigation Report 50-358/81-13.
7.LLEGED VIOLATION A
"... records were identified that did not furnish evidence of .
activities affecting quality in that they were false."
General Discussion:
f This item in the NOV sets forth five examples which allegedly
. demonstrate that " records" identified by the NRC in its revi'ew "did not furnish evidence of activities affecting quality" as required by j 10CFR50, Appendix B,' Criterion XVII, in that the records were " false."
l The Investigation Report 81-13 identifies these examples as NRC items 81-13-06A, 81-13-06B, and 81-13-02. Each example will be
- addressed independently.
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WHZ 2/24/82 Att"7hmGnt B Pcgo A-2 ITEM A.1
... records did not furnish evidence of the actual piping components installed...in that heat numbers did not match...."
Discussion This item states that in 11 instances, isometric drawings, weld inspaction records, and other records did not furnish evidence of the actual piping components installed in the diesel generator cooling water, starting air, and fuel oil systems, since the heat numbers recorded on the drawings did not match the heat numbers or color coding marked on the respective components. The Investigation Report states that the alleged discrepancies were discovered by review of the Diesel Generator System ASME Code Data package, which had " passed all inspnctions and had received final approval by Kaiser Quality Assurance."_1/ To the contrary, no such final documentation review of dioscl generator piping had been completed by Kaiser with that cdditional opportunity to identify such discrepancies. The OA program provisions for document review for final System Turnover proscribed in HJK procedures have not been completed as of this date.
1 The following observations are made as to the specific examples of discrepancies. First, several revisions exist for the referenced lisomotric drawing with respect to each of the alleged discrepancies in
' Table 4.3-1 on page 28 of the Investigation Report. It is not possible to identify from the information provided in the 1
' Investigation Report which revisions were reviewed. In order to i
1
'WHZ 2/24/82 A. achmsnt B Pcge A-3 verify the correct heat number on a component, it has proven to be necessary to review all cumulative revisions to the par,ticular isometric drawing.
Second, under the requirements of ASME Code Section III and 10CFR50, Appendix B, Criterion VIII for identification and control of materials, parts, and components, identification may be established either by the component or records traceable to the component. For each component, the matching heat number may be found either on the l pipa or records traceable to the pipe. It need not be found on the pipo itself, as the Investigation Report implies.
Third, of the is specific inconsistencies in the 10 isometric drawings identif2ed in Table 4.3-1, the following discrepancies have been identified:
The NRC Investigators apparently read the wrong number on the installed piping in two instances and the correct heat number 1
does conform to the isometric drawing.
In_six other instances, the heat numbers on the drawings do appear on the installed piping, although additional heat numbers appear on other portions of piping. Thus, Table 4.3-1 of the Investigation Report contains the following incomplete or j inaccurate statements.
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WHZ 2/24/82 Att hment B Pcge A-4 ' '
(1) ISK M-428 Neither M276 nor M267 is a heat DG-19 . number or part number. They are code numbers which, in this instance, represent the same heat number, 4425840.
Additionally, heat number HE 6247, shown on the drawing, in fact, does appear on the installed piping. No heat number 8464 has been found to exist on the piping.
l (2) ISK M-428 Heat number HE 6247, shown on DG-16 the drawing, does appear on the installed piping. (Numbers listed by NRC appear to be weld identifi-cation numbers.) No heat numbers 16E4 or 16D2 exist.
- (3) ISK M-428 Heat number HE 6247, shown on DG-68 the drawing, does appear on the installed piping.
(4) ISK M-767 Heat code number M395, shown on DG-113 that drawing, does appear on the installed piping.
UHZ.2/24/82 At achmant B Pcgo A-5 (5) ISK M-428 Heat numbers HE 6247 and HD 7123 DG-24 both appear on the drawing and on the installed piping.
(6) ISK M-428 Heat number 516405, shown on DG-26 the drawing, does appear on the installed piping.
(7) ISK M-428 Heat number 516405, shown on DG-27 the drawing, does appear on the installed piping.
As a separate matter, the NOV and the Investigation Report also refer to a heat number for line 1 DG-11-AA-3. The Investigation
. Report asserts that the heat number of the relevant KEI-1 form was i
assigned to Class C pipe, which is color-coded orange, while the pipe actually installed was color-coded yellow for Class D grade material.
I While it cannot be determined how the installed pipe was improperly color-coded, test results from Metcut Laboratories indicate that the pipa meets the safety grade material requirement for Class C pipe.
The official'KEI-l stamp listing the heat number, with the QC inspector's stamp, verifies that the material is proper and that adoquate traceability exists. It is also worth noting, as a general comment, that the NRC's own Independent Evaluation Program (IE Report 81-27) has shown, by component sample testing that the components installed were the correct material and grade for the line's specified requirements. Therefore, the material was traceable, proper, and not
'a " false" record.
ITEM A.2
. . .Nonconformance Reporting Log did not reflect all reports...."
Discussion This item states the Kaiser NR Log did not reflect all reports initiated. Three specific items taken from the testimony of three QC inspectors are presented.
The alleged noncompliance indicates that records of activities affecting quality were " false" since the NR Log did not reflect the initiation, by QC inspectors, of the three cited reports (CN-4309, CN-5412, and NRC-0001).
The requirement in Kaiser Procedure QACMI G-4 stated that all NR'c initiated by QC inspectors were to be reviewed by the Inspection Suparvisor or the Cognizant Quality Assurance Engineer who initials his concurrence and forwards to the Site Document Center (SDC) NR Controller for issuance of an NR Control Number. This procedural requirement provided a level of supervisory review and control
- necessary to effectively implement the NR system. This practice was also required to assure that NR's were initiated adequately and explicitly to describe the item of noncompliance and the specific requirement with which the item was in noncompliance. This requirement was consistent with the QA Program procedure QAP-16 for control of nonconforming material, parts, and components.
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WHZ 2/24/82 Atwechment B Pago A-7 The initiation of an NR by a QC inspector and the assignment by the NR Controller of the KEI Control Number does not make the NR Log a
" record." The NR report (after it has been completed) is the quality record. The NR Log and the NR computer status reports are merely '
administrative devices for maintaining the status of valid NRs.
A.2.c.
For this specific item, QC Inspector McCoy identified a deficiency during the in-process fitup inspection of a weld joint.
Acceptable QA practice by the industry is to correct the fitup to be in compliance with the weld crocess control procedure and not to initiate an NR. { Kaiser QA Manual QAP-16 Section 2.2 states
" Procedural violations. . .will be documented on Corrective Action Requests (CAR's)." McCoy had acknowledged his understanding of this requirement through his review of required reading for mechanical inspectors.} An NR was not warranted for this deficiency. It should clso be noted that no " Hold Tag" or " Deficiency Tag" was placed on the fitup and the correct action was taken by construction personnel to correct the fitup deficiency. Thus the need for an NR did not exist land the deletion of the Control Number entry was proper.
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The Investigation Report and the Notice of Violation make the l following inaccurate statements:
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l (a). NOV A.2.a states that CN-4309 was initiated by a QC i inspector on January 7, 1981. This CN-4309 is dated January 9, 1980.
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WHZ 2/24/82 At. hmGnt B POgo A-8 * -
(b). Attachment A to the Investigation Report identifies Dumford as the QC inspector initiating CN-4309 instead of McCoy.
(c). Part 11 of Attachment A to the Investigation Report states under Background Information that on January 7, 1981, McCoy obtained CH-4309. Under Investigation, the Investigation Report states he initiated a report on January 7, 1980. Our records show QC inspector McCoy initiated CN-4309 on January 9,1980.
A.2.b This item describes a similar alleged false record for an NR assigned CN-5412. Again, an NR was not the correct mechanism to
- document this alleged procedural violation, a CAR should have been used. Therefore, the inappropriate NR was not entered in the log.
QACMI G-4 required the initiation of the NR, then the tagging to control nonconforming material. Exhibit 51 of the Investigation Roport clearly states that it was not definite that a nonconforming condition existed and S&L was to be consulted. The Inspection Suparvisor and the site QA Manager discussed this condition and their l -
. determination that it did not constitute an NR was correct.
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WHZ 2/24/82 Atwcchmont B Pago A-9
/
A.2.c For this item, NRC-0001 involves an alleged nonconformance report for excessive weld weave. Again, a CAR was the appropriate document to rocord this procedure violation. The weld inspection procedure, SPPM 4.6, does not have accept / reject criteria for weld weave. The wold process procedure, SPPM 3.1.51 states that weaves should not excocd 3/4 of an inch. Here it is important to differentiate between the product (weld) acceptance requirements, which the QC inspector unos in determining conformance of the weld to specified requirements, and the process (welding) procedure which tells the welder how to parform the welding operation and'usually does not contain accept or rojoct criteria. The weld in question is an acceptable weld in that it meets all the welding requirements.
The HJK QC inspector, Ruiz, wac also aware of QAP-16 requirements and should have documented this condition on a CAR if further evaluation was warranted.
J' The weld in question was acceptable to all welding requirements to which QC Inspector Ruiz should have inspected under SPPM 4.6. Any question as to the weld weave, a procedural matter, should have been documented by a CAR or SR if further evaluation was warranted. In fact, Construction Engineering had already loo.ked at this particular problem and obtained a Design Document Change ("DDC") for width groater than 3/4 inch on the weld bead. After a discussion between tho QC inspector and his supervisors, the item was designated " accept
,as is" and rewritten as SR.3004 (copy attached). SR 3004, which is filed in th'e SDC and is part of the Zimmer Quality Assurance Records Systsm. Accordingly, there is no reason why this question concerning L
WHZ 2/24/82 ,
Atti Cont B Pcgo A-10 .
wold proceduro roquircmonts for weld weave should have been documented and reviewed by way of an NR.
ITEM A.3
. . . planned actions. . .made to j ustify voiding reports. . . were not taken.'
Discussion This item states that written statements as to planned actions which were made to justify voiding NR's E-1661 (voided November 11, 1980), E-1662 (voided November 11, 1980), and E-2466 (voided June 30, 1980) were not taken. The NRC's implied noncompliance is that the statsments made on these records (voided NR E-1661, E-1662, and E-2466) were " false".
The NRC Notice of Violation incorrectly states that NR E-1662 was voided on December 5, 1980-it was voided on November 11, 1980. The hangers reported on NR's E-1661 and E-1662 are located in the containment drywell and involved supports for the drywell pneumatic system. Subsequent to the initiation of these NR's, reanalysis of all loads in the containment building was required. This reanalysis showad that design modifications would be required of both the drywell auxiliary steel and pipe hangers to accommodate the new loads. On September 9, 1980, DDC M-5059 was written which involved modification i of the drywell pneumatic system (as well as other systems) to i
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WHZ 2/24/82 Attcchment B Pcgo A-11 i
eliminate the need for hangers which would require excessive auxiliary i
l stos1. .
This DDC has been superseded by ECR 1190 Rev. 1. The result of theco changes has been to delete the requirement for the hangers >
identified on these NR's. The stated reasons for voiding these NR's, "will be reinspected after design review" and " hangers will be reinspected after design review" for E-1661 and E-1662 respectively, woro correct. Accordingly, the justification for voiding these NR's was accurate.
The other nonconformance report in this item, NR E-2466, was ,
i voided so that each of the 124 nonconforming pipe support hangers could be written on a separate NR. As noted above, several design changes have been made involving safety-related hangers as a result of new seismic criteria. Revisions to the Sargent & Lundy h' anger detail drawing N-403 have required extensive reinspection of hangers. The requirement to reevaluate and reinspect all previously installed hangers became known after the. voiding of this NR. Therefore,-the i
c planned action to reissue separate NR's for each nonconforming hanger i
, was delayed until after the seismic criteria review and possible modifications required by system redesign. The reinspection of all safety-related hangers, including those listed on NR E-2466, is now underway. The QACMI M-12 criteria to which the pipe hanger welds will i
be reinspected are significantly core stringent than the old criteria i
by which the nonconformances were cited in NR E-2466.
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WHZ 2/24/82 Attt acnt B Pogo A Accordingly, nach henger listed in NR E-2466 will be or has been reinspected, and new NR's will be issued as appropriate. The statcment justifying the voiding of NR E-2466, therefore, is correct incsmuch as the reinspection and issuance of separate NR's is proceeding as planned. The current status is as follows: 85 hangers have been reinspected and accepted or new NR's have been issued; 28 hangers are being reviewed by the hanger field verification and design group and will be subsequently modified and reinspected; 5 hangers are being modified and reinspected at this time; the remaining hangers were supplied by vendors and are being reviewed for modification and rainspection.
ITEM A.4
"... statements relating to the availability of records...'to justify voiding reports were false."
Discussion This item alleges that NR E-1777 and NR E-5108 were voided on the basis of " false" statements as to the availability of quality records which justified voiding these reports. NR E-1777 was voided with the l statcment that "(w) eld rod slips had been located." The documentation packas for Isometric Drawings RI-195 shows that contrary to the allegation, the voiding statement correctly indicated that weld rod issue slip documentation for the weld existed.
The documentation package for RI-195 which was available to the
' NRC investigators (this package was in a file cabinet drawer marked
WHZ 2/24/82 -
Att.chmont B Pago A-13 I
" Hold for NRC") establishes this fact. A revision to RI-195 shows that the weld in question is 195A2._2/ At the. time the NR was voided, a review was made of the weld rod issue slips for all of the welds in the package RI-195. From the KEI-l stamp for weld 195A2, it was determined that the welder's initials were KOW. There were four separate weld rod issue slips (KEI-2 forms) issued to welder KOW for pipa line RI-195. None of the four issue slips specifically specified welds. However, weld filler metal heat numbers and fitup were I
verified on the KEI-l stamp on the back of the Isometric Drawing for RI-195 by the QC inspector for all but one of the four welds. By deduction, the weld filler metal heat number on the weld rod issue slip, which was the same for all four welds performed by welder KOW on RI-195, had to go with the remaining weld performed by welder KOW.
This review of the KEI-2 forms in RI-195 package is summarized in the following table.
Rod Issue Weld ID On Rod Welder Heat No.
- Slip No. Issue Slip ID For Rod 111515 RI-195 KOW C17875 126960 RI-195 KOW C17875 126963 RI-195 KOW C17875
, 126964 RI-195 KOW C17875 171534 RI-195 Cl LMB 2252
! 171535 RI-195 C2 LBM 33528 I l
l Accordingly, the statement voiding NR E-1777 that " rod slips had been locatod" was correct and the information available provided material traceability.
WHZ 2/24/82 Atta mont B Pago A-14 The other allegation in this item pertains to NR E-5108, which cited a lack of material traceability for a four-inch " pup piece,"
i.e., a short piece of pipe. This NR was voided by the Site Document Control Supervisor with the notation " acceptable documentation found."
ASME Boiler and Pressure Vessel Code, Subsection NB-4122 states:
" Materials for pressure-retaining parts shall carry identification markings which will remain distinguishable until the component is assembled or installed." A review of the documentation of the welds mado at each end of the pup piece shows the heat number was verified and recorded on the KEI-1 form for the first weld of the pup piece (wald RH82A) .
At that time, the heat number was recorded on the KEI-1 form for wald RH82A. By comparing the weld number and the line number from the KEI-1 form, the pup piece can be traced to the Isometric Drawing. The drawing in turn identifies the Certified Material Test Report
("CMTR"), which includes the pipe heat number. Accordingly, material
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traceability for the pup piece was established on the KEI-1 form for weld RH82A and the copy of the CMTR kept in the document package for the weld. Availability of records was, therefore, a valid justification for voiding the NR. The fact that Document Reviewer i
Reiter wrote the heat number on the other KEI-1 form for weld RH82 is irrelevant. The KEI-1 form for weld RH82A would provide material traceability recardless of what was copied on the second weld form.
WHZ 2/24/82 Attachmont B Ptgo A-15 ITEM A.5
" Reports were knowingly improperly voided...at the direction of the Kaiser QA Manager."
Discussion:
This item states that reports CN-5476, CH-5477, and CN-5479 were knowingly improperly voided (February 27, 1981) and copies deleted from the NR system at the direction of the Kaiser Site QA Manager.
All three of the re'ferenced reports refer to beams located in the drywell. Kaiser appendices of procedure SPPM 8.0, and procedure SPPM 3.1.12 detail the repair requirements for welds which are made in accordance with KEI-l Weld Data Form requirements. These procedures require an NR is to be ~ issued after 3 attempted weld repairs (documented on KEI-1A Weld Repair Form) have been made and do not
- correct the weld deficiency. The welding procedures in effect clearly j show that these CN's were inappropriately initiated by the QC l
inspector involved.
CN-5476 was written against beam #63 at elevation 551' in the drywall area. The KEI-1A form for this beam is clearly marked " Void -
l this' beam will be replaced." CN-5479 was written against beam #3 at olevation 551' in the drywell area. Again, the KEI-1A form was marked t
that the beam was to be replaced. CN-5477 was written against beam
- 58 at elevation 551' in the drywell area. The KEI-1A form states, "this weld removed."
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WHZ 2/24/82 ( Attemont B PEgo A-16 ."
All throo beams addressed in this roport waro roplacGd or reworked, have been reinspected under the Quality Confirmation Program (QCP) , and no nonconforming conditions exist.
Generic Corrective Action taken and Results Achieved
,for Alleced Violation A Documents, such as those identifed i'n the Investigation Report, will be reviewed prior to final approval and acceptance as official quality records. The Applicant admits that several records reviewed by the NRC were indeed incomplete; however, they were not considered by the Applicant to be completet quality records in that the specified documents had not received final review and acceptance prior to final System Turnover.
Furthermore, it appears that the NRC has chosen to describe the alleged discrepancies or omissions as " false" records rather than simply alleging that certain documents were erroneous or inaccurate.
Since Criterion XVII of 10CFR50, Appendix B does not define " false records," the clear intent of the Commission in citing the Applicant 4
with not " furnishing evidence of activities...in that they were false," is not understood.
i The allegations made by the Commission, even if correct, at most show that some documentation was inaccurate and/or incomplete.
However, there is nothing in the Investigation Report to support the characterization of such discrepancies as evidence of falsity, and the Applicant ardently maintains this pcsition. In particular, the acts l
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WHZ 2/24/82 Attechm0nt'B Pcgo A-17 of " whiting out" an NR Log entry of a Control Number or deletion of NR's initiated in error, for example, were done only in good faith compliance with established QA procedures and were certainly not attempts to falsify QA records.
In implementing corrective action, the Applicant has assumed only that inaccurate and incomplete records exist'," Document verification and the (QCP) have been established as part of the overall Quality Assurance Improvement Program to review all documentation to verify adequacy and completeness. The QCP is taking measures to validate the documentation of construction activities completed prior to April 8, 1981. This program'has been initiated and defined in detail and reviewed by NRC-RIII. The QCP activities include reviewing the adequacy of Weld Data Sheets, material traceability and documentation of nonconforming conditions. The Applicant and Kaiser Document Verification Groups are reviewing and assembling all documentation for final System Turnover and resolving documentation deficiencies identified during this review.
l Corrective Action Taken to Prevent Recurrence i
l In the May 18, 1981, response to the NRC Immediate Action Letter
! (IAL), dated April 8, 1981, the Applicant committed to take various l
ctops to alleviate future deficiencies in Quality Records, namely, the assumption of direct management of the documentation program. The l
l construction of the permanent site vault is complete and a revised program for documentation verification and maintenance has been octablished. The addition of more qualified personnel in both the
N Atta-kment B Pago A-18 Applicant and Kaiser QA orgarizations parmits more thorough reviews of essential. documentation for completeness and accuracy. Furthermore, applicable document and nonconformance control procedures have been revised to provide more concise directions for documenting-material identification and processing essential documentation.
I I
, , - - - . , -- . - - - - . - . , . . ..- -- .- . - -- . . . . . - - - - . - . - . - - . . . ~ - - , - - - - ---
^
Footnotes Referenced in Response to Allaced Violation A 1 -/ Investigation Report 81-13, p.27.
i 2/ The weld was removed after review by the NRC.
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Attachment B TO WM. H. ZIMMER NUCLEAR POWER STATION RESPONSE DATED FEBRUARY 24, 1982 ALLEGED VIOLATION B
...QC Inspectors were: (a) harassed by construction workers and supervisors; (b) not always supported by QC management; and (c) intimidated."
i
- Ganaral Discussion
Nine items are identified under Alleged Violation B which allegedly demonstrate that QC inspectors did not have sufficient freedom to identify quality problems as required by 10CFR50, Appandix B, Criterion I. These items are all identified in IE Investigation Report 50-358/81-13 as items 358/81-13-38A and 358/81-13-38B.
I These items were identified from selected interviews with QC inspectors. The Investigation Report alleges that water dousing, reassignment because of construction personnel complaints, search by security personnel, threats of firing, one physical threat, and questioning concerning delays and inspection findings intimidated or otherwise impared the QC inspectors' ability to satisfactorily perform their inspection functions.
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WHZ 2/24/82 AttachmSnt B Pago B-2 There is no allegation or ghowing that QA or construction management in any way condoned or tolerated reported incidents cited in Alleged Violation B. To the contrary, the Investigation Report itself confirms that the Applicant and Kaiser management immediately investigated all reports of employee misconduct and strongly warned that employees responsible would be terminated immediately. (See Investigation Repo rt Section 6.14.)
Do using incidents, for example, are assumed to be harassment, cvon though they would appear to be acts of employee horseplay. There is no evidence whatsoever that the dousings were intended to deter QC inspectors from performing their function properly. As discussed below, the responsiblity for dousings was undetermined, and it is, therefore, impossible to ascribe culpability, let alone motive, for those incidents.
The determination that " intimidation" occurred stems from the
, fact that craft workers and QC inspectors disagreed wit'h each other as to whether a particular weld was acceptable. Some disagreements involved QC inspectors and their superiors. While some of the
, individuals involved may have been unusually sensitive to criticism l
l and did not wish to have their judgment questioned, it seems unlikely i
l that any seasoned construction site worker would be " intimidated" by tho arguments that routinely occur in construction work._1/ Strong language and such routine give-and-take discussion by construction 1
workers certainly cannot consititue " harassment" or " intimidation" under 10CFR50, Appendix B. While white-collar professionals would
~
parhaps treat their colleagues with greater deference and diplomacy,
I WHZ 2/24/82 At hmGnt B Pago B-3 such is not the way operations run at construction sites or in many other aspects of the real world.
ITEM B.1 "Five QC inspectors... claimed they were doused with water. . .by construction personnel...."
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Discussion:
This item states that five QC inspectors claimed to have been d(used with water by construction personnel in the course of performing inspections. The interviewee statements relied upon as a basis.for this charge, do not support a finding that water was thrown by construction personnel or any other particular persons. Fo r example, QC Inspector Janice Mulkey explicitly disclaimed any such knowledge, stating that "I have no idea who threw the water since I
- ncvor saw anyone in the vicinity of where the water came from. Also, 1'
j I never heard any noise and no one ever laughed when it happened" (Mulkey Exh. 3 2 at p. 2) . Similarly, QC Inspector Mack White stated that at the time both he and a craftworker were doused with water, "the culpable individual ran away...and none of us saw who it was" (White Exh. 4 2 at p.1) . The statements of David Hang, Anthony Pallon, and John McCoy, as well as the hearsay statements of other QC
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psrsonnel, likewise fail to identify a single construction worker as responsible for any dousing. No basis is shown for attributing these aporadic incidents to craft personnel except by pure speculation.
WHZ 2/24/82 AttachmGnt B Pcgo B-4 .
Even if craft personnel were to be held accountable, there is cortainly no evidence that QC inspectors felt " harassed" or "initmidated" by these isolated occurrences. QC Inspector Pallon stated th'at he "did not care about these incidents that much" until he heard an unrelated rumor (Pallon Exh. 33 at p. 1). It is clear that he did not feel intimidated by the dousings or let it affect the quality of his work (Pallon Exh. 3 3 at p.1) . Similarly, QC Inspector McCoy stated that he " thought nothing of it except that it was kind of funny that it missed us" (McCoy Exh. 34).
Another QC inspector stated that "I don't know why it was done" inasmuch as he believed he has "had a good working relationship with craft personnel and I (wa s) aware of no conflicts or disagreements which would have resulted in this incident" (White Exh. 4 2 at p. 2) .
The only reference to " harassment and intimidation" in the statements regarding dousing, in fact, apparently resulted from the choice of words used by the NRC investigator in leading into that line of questioning (Hang Exh. 14 at p. 1) .
One QC inspector put the dousings in perspective when she acknowledged that she "was not necessarily ' singled out' to have water thrown on. . . . In some respects . . . I think it's just a game for the craft personnel to wet the new inspectors." More importantly, she reported that " craft personnel used to regularly squirt each other." (Mulkey Exh. 32 at pp. 4-5). This certainly refutes any charge that dousing -
was a specific form of harassment against CC inspectors or perceived by QC inspectors as an attempt at intimidation. Applicant's own investigation into the facts confirms that dousing among construction
s WHZ 2/24/82 Attechmont 3 Pago B-5 workers occurred. It is unclear why this fact was overlooked in the Investigation Report or why dousings involving QC inspectors were thought to have particular significance.
Even attributing these r_andom occurrences of QC inspector dousing to construction workers, does not demonstrate that "QC inspectors did not have sufficient freedom to identify quality problems and were not sufficiently independent from cost and .
schedule," in violation of the requirements of 10CFR50, Appendix B, Criterion I. The organizational structure at Zimmer does assure that the lines of authority are clearly separated, so that construction may i not interfere with or impede the QA function.
This is not to say that dousing would ever be condoned or left uninvestigated or undisciplined. However, a total of up to 2,'000 workers have been employed at the Zimmer wo rk site at any given time.
No contractor or utility can guarantee that normal disputes or disagreements will never arise in the daily interaction between construction and QA personnel and nothing in Criterion I of Appendix B imposes such a requirement. As a practical matter, the normal tensions resulting from QA oversight of construction will inevitably
(
load to incidents of one sort or another. Such tension demonstrates that the QA program is in fact providing stringent review. While neither the Applicant nor Kaiser condones such incidents or l
" horseplay" even among craf tworkers (see " Basic Project Rules" from Zimmer Employee Handbook) , their occurrence on an infrequent basis is -
hardly surprising.
WHZ 2/24/02 ,
Attachmont B Pago B-6 Finally, there is no pattern or practice of any magnitude that would suggest management's toleration of or indifference to the dousings. The last reported incident occurred on March 11, 1981. In each case in which Kaiser management was informed, a prompt and vigorous response followed and the dousings subsequently ceased.
Thus, Kaiser Construction Site Manager Robert Marshall warned craft suparintendents, union stewards, and certain craft workers that water-throwing must cease or responsible wo rkers would be fired._2/ In response to a dousing reported to him, Construction Superintendent Gerald Adams personally investigated the matter (Exh. 45 at p. 2; White Exh . 4 2 a t p. 2) . Although management was not informed of each incident, Kaiser Site QA Manager Phillip Gittings informed QC Inspection Supervisor Rex Baker that, as to any dousing suspect, "if he could be identified, he would be fired."_3/ (see also Memorandum
' of October 2, 1980, stating that employees found water dousing other amployees will be "immediately terminated.") -
The lack of culpability on the part of Kaiser or Applicant's management is expressly acknowledged in the Investigation Report (p. 137) which found no evidence that dousing was condoned, but
- rather, that action was taken to " identify and discipline" those l
responsible. In sum, the few instances of " dousing" described in the report were not intended to intimidate QC inspectors and did not have that effect. When Kaiser QA and construction management personnel wore apprised of dousings, they made every reasonable ef fort to stop them and to identify and discipline the guilty party.
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WHZ 2/24/82 Att hmGnt B PEgo B-7 ITEM B.2
...QC inspectors... reassigned by QC management because of complaints by construction personnel."
Discussion:
This item states that a QC Inspection Supervisor (Rex Baker) .
claimed that, over.his objections, qualified QC inspectors doing thorough jobs were being reassigned by QC management (Site QA Manager Gittings) because of construction personnel complaints. Neither the transcript of the statement by Baker nor our subsequent discussion of tho facts with him shows any basis for this charge. Also, the Investigation Report incorrectly states Gittings' explanation at the interview and did not, 'n i the Applicant's v'iew adequetely probe the facts from the perspective of management._4/ As a basis for this cha rg e , the NRC appears to have relied on hearsay and speculation by Load Inspector Dennis Conovan, the immediate supervisor of James Ruiz, I
l one of three transferred workers apparently involved in this item. _/ 5 i
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In none of these instances, however, is there factual support l for the implied allegation that the reassignment was an effort to interfere with QC inspections or in retaliation for " tough" inspections by the reassigned QC inspectors.
Prior to his reassignment, QC Inspector James Rui: h,ad been working in the Suppression Pool of the Containment area. At that timo, inspection manpower requirements were winding down in that area l .
WHZ 2/24/82 Attachment B Pago B-8 c and increasing in the Fabrication Shop, where an additional QC inspector was needed. Gittings and Baker discussed Lii: as a possible candidate for reassignment. Each thought that he was a good QC inspector. Contrary to the conjecture by Donovan, Baker did not object to the transfer and in fact personally implemented the transfer. Baker has further emphasized to us that the Rui: transfer was neither intended to nor likely to adversely affect QC inspections of pipe hangers. He notes that QC Inspector McCoy, who in Baker's estimation is a superior QC inspector to Rui: and wrote as many NR's, was not reassigned out of the pipe hanger area; nor was McCoy suggested for reassignment. McCoy also had a rapport and manner of dealing with craft personnel which resulted in a more harmonious and productive atmosphere.
In this regard, Ruiz did not have a good working relationship with craftworkers in the drywell area because of a personality conflict with Gerald Adams, a construction supervisor. At one po int ,
wa understand, Rui: refused to answer a call from Adams and insulted him with obscene language in the background. A meeting was subsequently held among Ruiz, Adams, a supervisor, and Gittings to discuss the situation.
While the personality conflict between Rui: and Adams was considered in the reassignment, the desire of QA management to reduce unnecessary friction is certainly reasonable. It is not inappropriate for management to take into account personality problems between QA personnel and craft workers. Certainly, Criterion I of Appendix B does not require management to be deaf to justified complaints or'to
WHZ 2/24/82 Att_Jhment B Page B-9 ignore personality disputes which interfere with smooth operations.
It is common knowledge that many QC inspectors change work assignments routinely, even on a weekl'y basis, in order to adjust to shifting workloads. Therefore, a QC inspector could not reasonably infer any attempt to interfere with QC inspections merely from a reassignment which involved a demonstrated manpower need elsewhere.
The Investigation Report's conclusion apparently relies almost .
exclusively upon the statement by Lead Inspector Donovan,_6/ who discussed his belief that Adams had complained about possible " nit-picking" by Ruiz. Our discussion with Donovan confirms that he actually had no information concerning the reassignment and had speculated incorrectly that Baker disapproved of the transfer, when in fact he concurred. Donovan stated to us that he had no knowledge of the need for an additional QC inspecto7 in the Fabrication Shop, and tha t there was no reason why Bakar or Gittings would have discussed the situation with him. He agrees that Ruiz would be suitably assigned for Fabrication Shop inspections.
As to disagreements between craft and QC personnel, Donovan l
ccknowledged to us that weld inspection standards are very subjective and may be interpreted differently by two QC inspectors to accept or rajcet the same weld. He stated that Adams did not ask that defective walds be passed and that his complaints about " nit-pick" inspections could resonably be construed as applying to welds per specifications with minor flaws. ]/. He also stated that it is proper and helpful for a craft supervisor to point out a QC inspector's high rejection rate in order that supervisors can evaluate the performance of welders._8/
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WHZ 2/24/02 Attachment B Pago B-10 Moreover, Donovan has provided additional information regarding Ruiz's successor, QC Inspector Kitchen, which supports the fact that the reassignment of Ruiz did not adversely affect the inspection of pipe hangers. Do novan informs us that he would grade Kitchen as a superior inspector to Rui: because he has more welding inspection experience and more adequately documents his inspections. Donovan also believes Adams has a good regard for quality and notes that the parsonality conflict with Rui: was the only one Adams had with any QC .
inspector.
The reassignment of QC Inspector Hendley was also the result of a legitimate staf fing need and was not an effort to remove a conscientious QC inspector. ~ Baker told the NRC (Tr. pp. 3, 5) that he "made the move (of Hendley) personally" because of staffing needs and because Hendley was a " damned good inspector," and that "(i)f I aadn't nocded L. Q. (Hendley) in the Fabrication Shop, L. Q.' would still be I working with us (in the field)." This account of the events, which Bakor has confirmed with us, is inconsistent with any allegation of an improper motive to impair QC review._9/
It is also significant that the third QC inspector (P.E.
Wimbish) whose reassignment was suggested by Gittings was not reassigned by Baker, because in his judgment the appropriate place for Wimbish at tha- time was in pipe hanger inspection. Baker has stated to us that no criticism or pressure was directed at him because of 1
this decision, which confirms that the transfer decisions concerning Rui and Hendly were based on the legitimate considerations discussed 1
above.
WHZ 2/24/82 Atta . cont B Pago B-ll ITEM B.3_
...QC inspectors harassed by being searched. . .at the request o f construction supe rviso ry pe rsonnel . . . ."
Discussion:
This item is based on a claim by two QC inspectors that they ,
ware " harassed" by a gate search for alcoholic beverages by site accurity personnel, allegedly initiated at the suggestion of a craft supervisor. A review of the basic facts including site security moasures omitted from the Investigation Report shows that no harassment at all occurred. ,
QC Inspector Anthony Pallon (Pallon Exh. 33) appears to state that there was a general search being conducted of all persons entoring by a particular gate, and that a construction supervisor named Douglas Hauff was directing Nho should be searched. Pallon does l not state that Hauff personally directed that he be searched, only that he gave general directions and stood nearby as Pallon's lunch bag wac searched. On the other hand, the Investigation Report indicates that Pallon claimed that Hauf f directed the search not only of himself 1
buc also of QC Inspector Mills, who accompanied him. The Investigation Report also states that Mills also claimed he had been saceched.10/
The description of the incident in the Investigation Report electly implies that a search of both Pallon's and Mills' persons was
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WHZ 2/24/82 Attachmont B Pcge B-12 ~
mado. However, Mills' statement (Mills Exh. 50) makes no reference whatsoever to the incident. Another interviewee, John Sullivan (Sullivan Exh. 35), claims that two construction supervisors, Hauff and Stanley, directed the security guard to search a bag containing a can of soda pop that Pallon was carrying. Again, no mention is made of any personal search. Pallon stated without elaboration only that he was " searched by the guard" (Pallon Exh. 33 at p. 2) . Whether Pallon told the NRC that more than his lunch bag was searched is ,
unclear. None of the interviews, nonetheless, support the Investigation Report's account that Mills was searched.
As a general matter, the Wm. H. Zimmer Nuclear Power Station Employee Handbook prohibits possession of alcoholic beverages, illegal drugs, or cameras on the project and, in enforcing that provision, sscurity forces employed by Applicant have conducted searches of employees and their vehicles entering and leaving the site (see " Basic Project Rules" attached hereto). All employees, including management, are subject to these procedures. Site QA Manager Gittings, for i
example, advised that his car and lunchpail were checked periodically l
by security, and that lunch boxes are routinely checked at the craft gato. QC Inspection Supervisor Rex Baker also informed us that such searches are routinely made of management and craft personnel alike.
l Nonetheless, the Investigation Report apparently accepts at face value l
1 the claim by Pallon that, because he is " management" (Pallon Exh. 33 at p. 2) , "being searched with the craftsmen...was an affront to me."
l This particular search occurred during the second shift lunch bronk, when all employees use the craf t gate. It is believed that all
WHZ 2/24/02 Attu .iment B Pago B-13 cmployees entering the gate that evening were searched and that Pallon was pointed out because he was trying to circumvent the search. The fact that all employees, whether craft or QA/QC, entered through the ccme gate and were searched alike is not contained in the Investigation Report, nor does the Report provide a basis for finding that Pallon would have (or should have) been able to elude the routine gate inspection but for Hauff's remark. Thero is no claim, let alone proof, that Pallon or QC inspectors generally were being singled out .
for unwarranted or discriminatory treatment. The peculiar sensitivity shown by Mr. Pallon to this routine entry search scarcely shows a lack of QA independence at Zimmer. .
ITEM B.4 "A QC inspector... claimed the QA Manager had threatened to fire him after construction personnel complained...."
Discussion:
This item states a QC inspector claimed that Site QA Manager Gittings threatened to fire him after construction personnel
, erroneously, but in good faith, reported that the QC inspector had 1
l boon using a magnifying glass to inspect a weld. As the facts l
l developed, Gittings learned that the QC inspector, Individual I, had boon using a mirror, which is obviously a necessary inspection tool.
Thor _e is no dispute, however, that Gittings was initially misinformed.
i
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WHZ 2/24/82 AttEchmcnt B Page B-14 f
It is clear that Gittings' threat of dismissal was made privately to QC Inspection Supervisor Rex Baker, who was to check out the facts, not to the QC inspector. Significantly, Gittings rescinded his statement immediately after Baker informed him that the QC inspector had been using a mirror. Gittings does not recall speaking with the QC inspector personally on the matter and, contrary to the l Investigation Report, believes he dealt with the QC inspector only l
through Baker. There was certainly'no attempt by Gittings to ,
intimidate the QC inspector since he never threatened him personally with termination and immediately reversed his position once the facts were known. It was apparently Baker who had passed Gittings' initial reaction on to the QC inspector. Baker, of course, had stood up for the QC inspector and certainly was not engaged in any " intimidation."
Gittings' initial reaction involves an interpretation of the AWS Code concerning the use of magnification. Baker states that he was told by Gittings to fire Individual I for using a magnifying
( glass, but that he pointed out that the AWS Code permits use of a magnifying glass "to look at a weld." -(Bake r Exh . 4 a t p. 1) l (cmphasis added). Gittings states that he was informed by the Applicant's Site Construction Manager, in a meeting with a number of other persons, that a QC inspector was using a magnifying glass to
- inspect welds. It is Gittings' professional view of AWS Code standards that weld defects must be detected upon initial inspection by unaided visual examination. If a defect is found, magnification I can be used to evaluate the existence of a discontinuity. However, magnification cannot then be used in accepting or rejecting the weld.
Baker's interpretation of the Code is to the same effect. The
WHZ 2/24/82 Atta.4nsnt B Pago B-15 applicable Pr,ocedure SPPM 4.6, which comports with this interpretation, states in part:
Visual examination shall be performed in adequate illuminated area, 35 foot candles minimum, measured at the surface of the item under examination unless otherwise specified. Evaluations of indications .
shall be performed without the aid of magnification except as noted in the project specifications. optical magni-fication may be used to assist in locating and identifying the nature of indications but not in the evaluation of indications.
Thus3 upon hearing that Individual I was using magnification to inspect welds, Gittings naturally reacted as he did. While in this instance there was a temporary misunderstanding of the facts, the Site QA Manager immediately corrected his position once it was ascertained that no basis existed for disciplinary action against the QC inspector. In fact, none was taken. Th'ere was surely no attempt to
" intimidate" the inspector in the brief exchange between Gittings and Baker which quickly resolved the initial misunderstanding.
ITEM B.5 "A CC inspector...was struck by a stream of water...while '
performing an inspection."
l l .
WHZ 2/24/82 Attachment B Pege B-16 '
Discussion:
This item states that a QC inspector he had been doused by water from a fire extinguisher and is indistinguishable from the other incidents discussed in Item B.1, supra, and probably even less consequential. Few details of the allegation are provided. Whether the reference is to an incident involving Dennis Taylor or Anthony Pallon,11/ no claim or showing is made that the purpose of the spraying was to intimidate the QC inspector or that it had that offect. Moreover, there is no evidence to indicate who did the spraying or even that it was a construction worker.
It is hard to appreciate what distinguishes this particular cliegation from similar Item B.1 incidents or why the NRC has singled it out for separate treatment. The matter was apparently unknown and unroported to management and is certainly not attributable to any action or inaction on its part.
l ITEM B.6 "A QC inspector... claimed he was threatened with bodily harm...if he did not pass a weld."
i Discussion:
This item states, QC Inspector David Hang claims that in the summer of 1978, an unidentified pipefitter threatened him with bodily harm for rejecting a weld (Hang Exh. 14 at p. 1) . Hang states that he
WHZ 2/24/02 Att. .mont B Pago B-17 did not report the threat to his supervisors. Although he felt "intimid'ated" by the threat, he states that "it did not effect (s ic) my inspection activities."
Inasmuch as Hang has declined to identify the pipefitter who allegedly made this statement and acknowledges that he never reported I
the incident, it is not possible to respond the the-charge on a factual basis. To the best of Applicant's knowledge, management did not know of this particular alleged incident. The Investigation Report contains no evidence of any other incident of physical violence being threatened.
- Independent of the Investigation Report, Applicant has no i knowledge of any such incident. Site QA Manager Gittings and QC Supervisor Rex Baker never heard of any threats of physical intimidation at Zimmer. Dennis Donovan, whose statement the NRC investigators relied on substantially, has been at the site since 1973 and an inspector in the field since 1974, but cannot recall any incident involving physical intimidation. In any event, this isolated occurrence more than three years ago is at best a very stale allegation. The lack of a contemporaneous report of this very dated allegation makes it nearly impossible to disprove or clarify. It is unfair and unreasonable to place that burden on Applicant. Mo r eove r ,
the fact that Hang never spoke to his own supervisors, craft supervisors, or apparently anyone with authority to take action, largely refutes any claim that he felt intimidated.
Even accepting Hang's version as basically true, he ,
acknowledges that the construction worker's threat was an isolated
sv WHZ 2/24/82 Attachment B Pago B-18 r
. comment and that he "did not have any more problems'with these men on site" (Hang Exh. at p. 1) . ,No pattern of intimidation has been alleged or shown. In Applicant's view, a single instance of throatening language by a pipefitter to a QC inspector does not even approach a violation of Criterion I of 10CFR50, Appendix B. As discussed above, remarks of this nature are practically inevit'able at a construction site and: there is no way any contractor can coalistically assure tNat such~ remarks will never be made. All that can be expected, and all that Criterion I of Appendix B requires, is t that the organization has independence and stature such that it can
' assure the proper performance of the QA function. Had Hang chosen to notify his' superiors of the 7 threat,, Applicant has no doub*. that prompt, effective action would have been taken.
ITEM B.7 l
...QC Inspector clained. . .he was accused of holding up a
, i concrete pour . . . (and) . . . construction management. . .challenc ed
- their-inspection fi dings...." r <
l l
W l
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WHZ 2/24/82 Att. .mcnt B Page B-19 Discussion:
This item, involving Lead Inspector Donovan, is an example of how facts can be misinterpreted and not reflect the interviewee's true porceptions. This problem is evident in cetain key words and phrases in the Investigation Report and Donovan's statement.
B.7.a. ,
i In this item the Investigation Report in two instances states that Donovan was " accused" by Site QA Manager Gittings of holding up a concrete pour,12/ while Donovan's statement refers to his being
" challenged" on the matter (Donovan E.xh. at p. 6). In the context of the NRC's concern about possible intimidation, the difference between being wrongly " accused" and " challenged" as to one's actions is significant. It was certainly important to Donovan, who now states that Gittings merely " questioned" him about the delay. Conovan also states that this conversation occurred at a meeting attended solely by QA/QC personnel. No construction personnel were present. Mo r eo ve r ,
the Investigation Report implies that Gittings was accusing Donovan personally of the delay. Donovan informs us that he understood "why did you hold up a concrete pour yesterday" (Donovan Exh. 31 at p. 6) as a reference to QC in general, not himself personally. Donovan tells us that he regards the matter as insignificant and certainly did not infer any attempt to intimidate, harass, or impair his performance of QC duties.
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l WHZ . 2/24/02 Attachmont B Pcgo B-20 ,
As noted previously, this i~s apparently a situation in which a now supervisor has become acclimated to his new responsibilities, including answering to higher management without undue sensitivity.13/
In any event, the fact that the Site QA Manager asked one of his am:noyees about work delays during a QA/QC staff meeting does not constitute a violation of Appendix B, Criterion I. Donovan did not then and does not now claim that he was intimidated by the question,
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but apparently believed at the time that he should be free from direct questioning by his superiors even in internal QA/QC staff meetings.
Such a view is simply not supported by anything in Criterion I of Appendix B.
B.7.b.
This item concerns construction management's questioning QC inspectors about rejections, also appears to involve the matter of personal sensitivities. It is hardly surprising that craft professionals taking pride in their work will ask questions of inspectors about their reasons for writing up NR's. A request for such an explanation should not be intimidating to a QC. inspector of normal temperament in the ordinary give-and-take that can be expected at a construction site. Further, a review of the QC inspectors' statements indicates no allegation that craf t wo rkers or management asked that items below specifications be accepted. There is no evidence that craft workers or management questioned the QC inspectors for any reason other than professional disagreement and a desire for clarification. There is also no evidence that any discussion led QC inspectors to abandon valid NR's or resulted in any loss of
WHZ 2/24/82 Att mcnt B P go B-21 indopendence on the part of the QC inspectors in performing their duties.
Lead QC Inspector Donovan, for example, stated in discussing this with us that it is entirely proper for QC inspectors to communicate with construction workers to discuss NR's so that the inspection process is not simply a one-way street. Donovan believes, at least now after more experience, that such discussion is helpful to
! both the craft worker and the QC inspector and helps to avoid future problems. Donovan also told us that he is not aware of any incident in which QA management did not back up QA/QC personnel in any.
disagreement with construction personnel.
B.7.c.
This item relates to a comment attributed to Gittings by Donovan (Donovan Exh. 31 at p.~5), which was apparently made at a l meeting held approximately in December, 1980. After the decision had l
l bGen made to terminate the contract with Butler Service Group.Inc., a series of meetings was held in an effort to improve the morale of those QC inspectors who were hired from Butler to work for Kaiser.
! Gittings concedes that he probably made a comment like the one attributed to him at one such meeting, but states that in the context, he did not suggest that QC inspectors should ignore any defects that l
l waro found. The crucial problem under discussion at the meeting was l
the disparate standards being applied by some QC inspectors, chiefly i the fo rmer Butler employees, according to individual preferences l rather than Code requirements. The gist of Gittings' statement in
- , ,o - . ,_-
WHZ 2/24/82 Attachment B Pcg,o B-22 context was that quality assurance as a verification program could not function if different and unnecessarily stringent standards were being utilized. Gittings advises that he also said at the meet'.g, for example, that when any QC inspector sees something wrong, "you never close your eyes."
- Baker has confirmed Gittings' recollection. He agrees that while a statement.of the type attributed to Gittings was made, it .
occurred within the context of statements discussing the need to identify and report nonconformances by uniform standards. Donovan himself has confirmed that Gittings has never said that QC inspectors .
should blind themselves to nonconformances, nor has he ever stated that QC inspectors should accept defective welds. Thus, the Investigation Report's discussion of'this comment fails to put it in the proper perspective. Gittings' explanation, as confirmed by others, refutes any inference that independence from cost and schedule considerations was ever jeopardized.
( ITEM B.8 of... duties because he
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( "QC inspector claimed he was relieved l
continued to submit legitimate nonconformance reports over construction management 'bjectives...."
o l
t i
l 1
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WHZ 2/24/82 Att .msnt B Page B-23 ,
Discussion:
This item per.tains to a former QC lead inspector's belief that' he was relieved of his inspection duties for pipe hangers because he submitted valid NR's over construction management objections. The allegation is based on the QC inspector's incorrect inferences regarding the reasons for his job reassignment.
As noted in the discussion of Item B.2, supra, the reassignment of inspectors to meet normal changes in workload is quite routine. In this instance, Lead QC Inspector Shinkle simply misunderstood or was unaware of the circumstances surrounding the reallocation of responsibilities which took place in February, 1980. At that time, Shinkle was lead QC inspector for civil / structural and hanger
(
disciplines. According to the Site QA Manager at that time, Kenneth l
l Baumgarten, there was in early 1980 a need to better utilize inspection personnel and to improve inspection of rework / repair actions identified in system walkdowns for hydro testing. The l structural activity was also increasing significantly in the Drywell -
and Suppression Pool.14/ In order to allow Shinkle and his group' to give higher priority to these matters, it was decided to reassign the pips hanger portion of his work to another lead QC inspector.
Thus, the reallocation of responsibilities was not a disciplinary move. Rather, it was a routine management reaction to shif ting wo rkload requirements and wholly appropriate to the circumstances. This particular reallocation of supervisory duties was l _ _ .
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WHZ 2/24/82 Attachmont 3 Pcgo B-24 part of an overall program of organizational changes relating to quality assurance engineering and inspection.15/
The Investigation Report does not reflect input from management personnel regarding specific statements attributed to them or their views on Shinkle's basic assertions. For example, Donald Sahlberg 16/
does not even remember Shinkle or the remark Shinkle claims he made, i .e. , "Do you understand who you wo rk for now?" Further, Shinkle now states to us that the remark attributed to Sahlberg (if made at all) could very well have been in the context of a discussion of requests to Shinkle made by William Schwiers, Applicant's QA Manager. If so, the statement could merely have expressed concern regarding proper organizational channels of communication. Also,, Kaiser Corporate QA Manager Eugene Knox denies making the statement attributed to him.
With regard to the meeting with management in February, 1980 that provided the basis for Shinkle's concern over his reassignment, Shinkle now acknowledges that the 95% rejection rate by his inspection I
l group was a legitimate managerial concern appropriate for discussion among himself and his superiors. Shinkle stated to us that he was not surprised that'the issue was brought up, but-merely by the number of management officials present at the~ meeting. Again, this appears to be an instance in which any feeling of " intimidation" resulted from personal sensitivities rather than overt actions on the part of management.
Shinkle also told us that there may have been a legitimate dissgreement at the February, 1980 meeting, following his earlier
WHZ 2/24/82 Att6 amtnt B Page B-25 moating witn Schwiers and Baumgarten, about the extent of Kaiser's commitment to reinspect welds that had been previously inspected and approved in accordance with applicable codes, standa rd s , and specifications. He further acknowledges that no one at the meeting told him that codes, standards, or specifications should be violated or that nonconfo rming items in the pipe hanger inspection plan should ba accepted. The focus of the meeting, therefore, centered on the items to be inspected rather than the standards to be applied. .
Nothing has been shown here to prove any loss of independence by QA in performing its inspection functions. Finally, it is altogether unclear why Shinkle believed that his promotion tc QA Engineering would involve inspections.
The. statement by Shinkle in the Investigation Report,1]/ that ,
Gittings discussed Shinkle's new responsibilities in QA Enginee'. ing for civil / structural activities wrongly implies that Gittings focused on Shinkle's personal duties as opposed to the generic requirements of the job. kn fact, Gittings merely corrected Shinkle's misimpression that the job ordinarily would entail responsibility for inspecting pipe support hangers. Gittings stated that, at that time, responsibility for pipe support hanger activities would have fallen within the jurisdiction of QA Engineering, mechanical or piping. He did not, however, state that QA Engineering would in any circumstances have inspection responsibilities.
Obviously, there is some confusion in the assumption by Shinkle as discussed in the Investigation Report regarding the l
responsibilities of QA Engineering which, of course, reviews the
WHZ 2/24/02 , Attachment B Page B-26 codes, standards, and specifications requirements to translate these requirements into acceptance criteria, that are incorporated in inspection procedures used by QC inspectors. QA Engineering itself would not perform '.he inspection function. This is confirmed by the Kaiser Personnel Requisition (August 29, 1980) and the Salaried Position Description, which describes the responsibilities and functions to be performed by a Civil / Structural Associate Eng inee r .
Thore was certainly no reason for Shinkle to believe that his promotion to QA Engineering would involve inspection activities.
ITEM B.9 "A QC inspector... claimed he was told by QA management to accept inspected items that were unacceptable."
Discussion:
[ This item pertains to an alleged comment by Kaiser Corporate QA Manager Eugene Knox to QC Inspector Rui: upon his rehiring by Kaiser in December, 1980. According to Ruiz, Knox said , "We are starting a l
program to get 'everyone thinking the same way, we want you to buy l
stuff that is almost acceptable."18/ Ruiz allegedly responded that he would inspect to the procedures and meet their requirements, but took Knox's comment as a "suttle (sic) suggestion to accept border line unacceptable welds."lo/
l Both Knox and Gittings deny having made or heard the other make l
this statement. It is very significant that not a single other QC I
WHZ 2/24/82 Atti acnt B Pago B-27 ,
inspector or supervisor interviewed by the NRC stated that he had been told, subtly or otherwise, to accept nonconforming items. Several allegations expressing concern with craft and QA management complaints about overly stringent inspections were exhaustively investigated by the NRC, but no statement like Ruiz's was discovered. It is inconceivable that top QA management would single out a newly hired QC inspector for a comment such as this which is inconsistent with every other statement given by QA/QC personnel to the NRC.
Ruiz's statement is noncontemporaneous with the alleged comment (more than a year later) and, while he purports to quote Knox, the key phrase (wanting inspectors to " buy stuff") uses syntax more suggestive o f a QC inspector than top management. The allegation is lacking in ersdibility and corroborating facts. ,
It is possible that Ruiz misconstrued what he quoted Knox as saying, i.e., that "we are starting a program to get everyone thinking j the same way." It was about that time that an effort was being made '
l by Kaiser to instruct the QC inspectors in proper inspection l
- techniques under the 1972 AWS Code, applicable to Zimmer, in part i
because some of the QC inspectors had, on other job sites, followed the procedures and standards of the more stringent ASME Code. 'Wh e th e r it was in this context that a remark was made which Ruiz misunderstood can only be speculated, since both Gittings and Knox deny that the
' comment Ruiz attributed to Knox was ever made. Nonetheless, not a single shred of evidence exists in the voluminous Investigation Report to corroborate Ruiz's claim that QC inspectors were asked to approve walds below code requirements and specifications.
l l -
WHZ 2/24/02 ,
Attachment B Pcgo B-28
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Generic Corrective Action Taken and Results Achieved For Alleged Violation B The Applicant's investigation has determined that the allegations, as stated in the Investigation Report, are not totally correct. While certain cited actions can be verified, the Applicant does not construe such actions to constitute harassment, intimidation, or inadequate management support, .
Statements from QC inspectors indicate that dousing, for example, is representative only of common horseplay typically found at any construction site. Although the Applicant recognized these conditions as typical behavior for a construction site, prompt action was taken to inform the Constructor that such action would not be condoned at Zimmer. Through actions taken by the constructor, construction personnel were, and will continue to be, admonished for any horseplay which, of course, is not conducive to good workmanship and could be perceived as harassment or intimidation. Th ese reprimands are issued by both construction supervisory personnel-and I the leaders of appropriate collective bargaining units.
The results of our investigation into reassignment of inspectors, accusations of responsibility for construction delays, and l
l questioning inspection results by QA management indicates that the QC inspectors involved do not consider these activities to have affected their ability to perform their inspection functions. The Applicant strongly believes that the NRC factual findings do not demonstrate harassment or intimidation of QC inspectors.
WHZ 2/24/82 Atta amant B Pago B-29 Corrective Action Taken to Prevent Recurrence While the Applicant does not agree that intimidation or harassment as alleged by the NRC occurred, we do recognize the need for improved communications and better managed organizational structures.
The Applicant and Constructor have expanded their respective .
Quality Engineering staffs and revised Quality procedures to better accommodate the needs and questions raised by inspection personnel.
Both the Applicant and Constructor have incorporated significant changes in their respective corporate structures to better assure the independence of the quality organizations. Team building and ' improved communication techniques are being developed to assure resolution of differences between construction and inspection personnel.
All of these actions are being taken in accordance with the May 18, 1981 response to the Immediate Action Letter (IAL).
i
WHZ 2/24/02 Attachment B Pcgo B-30 .
FOOTNOTES
_l,/ In this respect, a lead inspector whose statements were principally relied upon by the NRC has expressed second thoughts as to the validity of his prior statements, and now acknowledges the propriety of discussing his QC reviews with craft personnel and management in order that everyone understands the precise Code specifications and standards which should be utilized. See response to Item B.7.b.
2/ Some of management's response is described in the Investigation Report at page 125.
3/ The statement in the Investigation Report at page 124 is not
- Mr. Gittings' recollection of what he told the NRC l
investigator. Except for the White and Mulkey incidents, these dousings were not even reported to management, e.g . , Gittings and Baker. Again, this reflects the general perception by QC l
l inspectors that the dousings were simply humorless pranks.
_4/ See Report Section 6.1.2.1. The entire restatement of this portion of the interview is only three sentences.
1 l
l _5/ See Report Section 6.1.2.2 l
l _/6 See Donovan Exh. 31; Section 6.1.2.2 l
WHZ 2/24/82 Atte..:mont 3 Pcgo 3-31
_7/ Reviewing his statement, Donovan believer that his reference to
" nit-pick" and "too strict" inspections should have been clarified as stated above. He also believes that he spoke loosely in saying that inspectors had been " involuntarily reassigned" (Donovan Exh. 31 at p. 1), that Ruiz' reassignment "(p) ro fessionally. . .does not make sense," (Donovan Exh. 31 at p. 2) , and that Kaiser management felt that transfers would " kill four birds with one stone" (Donovan Exh. .
31 at p. 3) . Donovan states that he regrets having mad,e these statenents.
_/
8 It should be noted that, at the time of his interview, Do novan had but five months experience as a lead QC inspector. Ano the r year of experience in the practicalities of the job has, we submit, broadened his perspective.
_9/ Site QA Manager Gittings told us that he censidered Hendley to i
be a good inspector. He believed that Hendley's transfer to the Fabrication Shop, which would still involve inspection of pipe hangers under the same lead inspecto r, would help to eliminate any pipe hanger defects prior to reinspection after installation. Gittings regarded Hendley as a tougher inspector because he was more familiar with the' stricter ASME Code standards than the AWS Code applicable to Zimmer and.therefore desired to have Hendley work in the Fabrication Shop.
10/ See Report Sections 6.1.2.4 and 6.1.2.5.
T
- -m WHZ 2/24/82 Attachment B Page B-32 11,/ See Report Sections 6.1.2.4 and 6.1.2.13 12/.
See Sections 6.1.2.2 and 6.1.3.6 13/ The comment at issue was so unremarkable that Gittings cannot even recall the conversation.
14/ These changing manpower requirements were discussed in monthly project meetings.
15/ See Memorandum from K. R. Baumgarten to QA Personnel, dated February 21, 1980 (copy attached).
16/ See Shinkle Exh. 41 at p. 2; Sahlberg is identified as a
" Kaiser official" in Report Section 6.1.2.17.
17/ Investigation Report Section 6.1.2.17.
18
__/ Ruiz Exh. 43 at p. 4. At Report Section 6.1.2.19, this alleged statement is for some reason attributed to Site QA Manager Gittings as well.
19/ Rui z Ex h . 4 3 a t p . 4.
i e
"i MTER-O{PRCE mEMORANOum ..
re : Quality Ascuranen ?arsc==al cars : Fchruary 21,19CO Ar wse:w.cHiu
- Fncu: K.R. 3au=garta= ,
cr.2.. vo : I. Marshall C.G.4Z.': 3.K. Culve- -h w -- Q;
. I.7. Knex W.W. Schwie:s .
J.?. Coyle AT Cc=st:te:1 = Seperi=:endouts JCB NO. 7C70
. suanc:: ORGANIZ.*C ICN
?"'- dva X:= day, February IS,1980 i= c da: :o p;cvida =cra effectire n-d' d-neic= of persc==al, plus direc: the quali:7 effc:: c= kay areas of the projec:,.and c== inua to d -ale ==== a=d affec:17e quality pr=grs=,
the fol.L..id=g erg =
- ari== cha=ges will be i=p' a - 3d.
Mr. W.y. Ray =cids ud'7 assu=e the responsibility of Quality Assurance I=-
g1=eer1=g Superviser. v .'J. Ki= hell is assig=ed as Quality Engines: for I=st :=me=:2:1c= a=d Civd1/ Structural. Er. M.G. 7:a=chuk has bea= assig=ed cf Quali:7 Activi das d.: supper: ef the om27m d effi=a.-
to Supplia In the d-= pectic = ac:171:7, Mr. I.T. Shd-k's vd'7'be desighated as the Civil /Scru===ral lead I=spac:or wi h prd=ary respcusibd7dties for acrir-ities 1= the Suppressics ? col a=d Drywell. Er. T.J. S=1th vd " cc= d ce
'as the I=str-a-eati==/Mac'n d -si Lead I= spec:or, hcwever, is addi-d n a piping, vd77 assu=e the respcusibdid =y for pipi=g suppor /'.. angers. It is l , p'*--ed that the total activity v d'7 be perfor=ed on a= elevati =/ area
! c== cept to provide f== the =cs: effactive ut d ' d:stics of perset=al plus effec:ive c==c:cis duri=g cens===ctics ac dvi:das. Mr. W. Siehla ce=~d nes as Z1ec:ric=1 land Inspector and vd77 also assu=a responsibill:7 for chl-c= lated cenduit ha=gers. Mr. J. Se:1cck ce=~d cas as the lead I=spector for the Hydro /h:=cvar activi:ias. ,
Tour c==~d ned--supper:-and coopern d~- d- " a i=p'a-=":2:1cn of as effective Quality ?rogra= is appreciated. .
. 8 l .
K23/a=
w . n 3 . . . .
1 BASIC PROJEC RULES SASIC PRCJECT RULES (Cont.)
(not a!! in=lusive) -
- 12. Unauthori:ed fires. (No caen fires will be The following are among vie!ations for wnich employees . permitted en : se projec. .)
tre r:bje:: to discharge:
- 14. Abuse er cest uction cf :ompany materials, tools
- 1. Violation of safety regulations. Failure to use or . or ecuipment. -
Mar safety equipment. .
- 2. Int =xication.
- 3. Possession of alecholic beverages, illegal drugs or cameras on :ne projec:.
- 4. Theft.
E. F*sghting.
E. Gambling.
- 7. Falsifying any reports or records including pe-sonnel, absen:: . sickness or terminanon.
E. Faiseiy stating or making efaims of injury.
- 9. Laaving work pla:s without supervisor's .
authori:stion. - ) *
- 10. Leaving company premises without authon:stion.
~
3
- 11. Insubordination or refusal to follow foruman's oroers. -
i 12. Horseplay.
,. . . . . . . . - . . . . . . . ~ . . . . . .
.. .', c. -
~
l l
l l
G
N.
Attachment B
{
l TO WM. H. ZIMMER NUCLEAR POWER STATION RESPONSE DATED FEBRUARY 24, 1982 ALLEGED VIOLATION C
"...The Cincinnati Gas & Electric Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B...."
General Discussion:
This alleged violation includes several items of alleged noncompliance with various criteria of 10CFR50, Appendix B. Each item will be addressed individually.
l ITEM C.1
- a. ... improperly voided (NR's)...."
t
- b. "One NR... improperly closed...."
- c. "Two NR's... improperly dispositioned...."
- d. ...NR's voided by personnel other than OA manager."
- e. ... nonconforming items were removed from NR without
- justification."
- f. ... reports had not been issued NR numbers...."
l i
WHZ 2/24/82
~
At .chment B Pcge C-2 Discussion:
Investigation Report 50-358/81-13 identifies item C.1 as 358/81-13-01 and consists of six parts, a through f.
This item pertains to allegations that certain NR's were veided, not entered into the Quality Assurance Records system and improperly dispositioned or incomplete, contrary to the instructions contained in QACMI G-4, " Nonconforming Material Control." The specific matters d'scussed are alleged to show violations of 10CFR50, Appendix 3, Criterion XV.
C.l.a.
NR-2233 and NR-2237 relate to deletion of weld process holdpoint for fitup inspections and verification of welder qualification and material identification which were not performed as required by KEI-l form 12554 for Weld WS62GP on line 1WS17A18 denoted ion drawing PSK-1WS32 and as required by KEI-l form iA18391 for weld WR218GP line 1WR01AA12 denoted on drawing PSK-LWR-26. The NRC alleges these NR's were. improperly voided.
The inspection holdpoints on the KEI-1 form are marked for applicability by the Welding NDE Quality Assurance engineer by placing an X in the " Required Block" for those items which are required to be verified by the QC inspector. The applicable KEI-l forms for the walds above had the "X" marked over with "NA" in the first three blocks.
WHZ 2/24/82 Att ~'hment B Pcgo C These blocks had been marked as inspection holdpoints by the Weld NDE QA Engineer. Subsequently, the Supervisor, Site Document Center, superimposed "NA" over the two blocks for verifying weld procedure (necessary to show welded qualifications and proper filler material) and proper fitup. This was based on the concurrence of
~
Welding NDE QA Engineer Anthony Pallon to use the weld rod issue slips (KEI-2 forms) as documentation of welder qualifications and filler metal heat number. Since the fitup inspection of the threaded plug prior to seal welding is not essential to assure that the plug, once welded, will perform its function, the initial marking of the block for a hold point inspection had been made in error. The correctness of this judgment has been reconfirmed by discussions with Welding Engineers and Welding NDE QA Engineers.
The Supervisor, Site Document Center, was able to furnish the information missing from the KEI-1 form for welder qualifications and wald filler material heat number from the KEI-2 forms for these welds.
Haat number information for the gamma plugs was readily apparent on the gamma plugs after welding. For large bore piping, only one KEI-1 form is used to perform a specific weld, such as WS-62GP, and weld rod issua slips (KEI-2 forms) specifically state the weld number for which the rod is being issued. Therefore, a one-to-one correlation exists for KEI-1 forms and rod issue slips. Accordingly, the KEI-l forms ware directly traceable to the rod issue slips with the missing information for those welds.
While the voiding of the NR could have been stated more clearly such that the concurrence by the Welding NDE QA Engineer was
WE2 1/24/82 ^
A. chmont 3 Page C-4 specified, the action in voiding the NR was itself propor for the reasons discussed above. Nonetheless, these specific NR's are being reviewed under the Quality Confirmation Program (QCP) Task 7. Further inspections and engineering evaluations will be performed as necessary to assure that the appropriate quality requirements for gamma plug welds have been applied. Moreover, the review of all quality records for final System Turnover, discussed in response to Alleged Violation .
A, will assure that any similar deficiencies either do not exist or have been corrected.
C.l.b.
NR E-2996, was initiated on February 2, 1981, because the requirement of ASME Section III, Subsection NF-5321, had not been met.
Radiography (RT) showed the full penetration welds on the T-Quenchers to have a lack of penetration at the backing ring. On February 24, 1981, Ultrasonic Testing (U/T) results for all the welds in question waro sent to sargent & Lundy for evaluation. On March 5, 1981, S&L 1
l approved the accept-as-is disposition for all welds except S/N 007 for review. This NR was incorrectly stamped " closed" on March 17, 1981, for all welds although the closed NR notes that S/N 007 required more data. This administrative error made by a document records clerk was corrected en May 11, 1981 immediately after being identified to the Wald NDE QA Engineer. NR E-3172 was initiated to assure proper disposition of the T-Quencher Weld S/N 007. This condition is being reviewed by S&L Quality Control personnel to evaluate the acceptability of the weld for T-Quencher S/N 007.
( , . .
WHZ 2/24/82 Att..nment B Pcgo C-5 The discussion in the Investigation Report at Appendix A, pages 17-18, regarding the issuance and disposition of NR E-2996, makes it clear that the closing of the NR prior to the disposition of each of the separate items listed therein was, at most, simply a clerical error.
To date the Applicant review of NR's has found this type of error to.be an isolated case and, therefore, further specific corrective action does not appear to be warranted. Should our continuing review reveal other similar cases additional corrective cetion will be taken.
C.l.c The two NR's in this item relate to radiography requirements for ASME Class C piping. NR E-2836 was initiated on October 22, 1980, by Rex Baker because the NES field radiographic film audit showed that i final radiographs for weld WS-737 on drawing SPK WS-61 were not available. The only film available in the files for this weld was an i
-information radiograph of the root pass.
NR E-2596 was initiated on March 19, 1980, by Floyd Oltz baccuse the radiographic film and reader sheet for weld WS-739 were l lost. This weld is also identified on PSK WS-61.
t l
The NRC alleges that both of these NR's were incorrectly dispositioned. The disposition for both of the NR's is accept-as-is.
l The justification for this disposition.is based on the existence of i
WHZ 2/24/82 ~ '
At chmant 3 Pago C-6 .
l KEI-l forms which are signed off by both the QC inspector and the ANI l rhowing the final x-rays of the welds as being acceptable. This disposition was reviewed and accepted by the S&L Mechanical Engineer, by the Applicant's Mechanical and QA Engineers, by Kaiser Construction Engineers, and by the ANI. Since these welds are in ASME Class C lines, they are not specifically required to be radiographed by the ASME Code Section III Subsection ND-5220. They were required to be
'radiographed by the'S&L piping specification H-2256. However, the acceptance by the Engineer (S&L) indicates, that contrary to the NRC contention, these NR's were properly dispositioned as an acceptable deviation f rom the Engineer's (S&L) specifications by the Engineer (S&L). This disposition was also in accordance with the requirements of QACMI G-4.
While the Applicant ~ contends that these NR's were not improperly voided, these NR's have been reopened as NR-0-QAD-82-370-E
.& NR-Q-QAC-Sl-ll in accordance with the QCP Task 7, since the final
, radiographs have not been retained. To provide further assurance of I
tthis acceptability, these welds will be re-radiographed or examined by Lother NDE techniques to provide permanent records of NDE results. To ldcto the Applicant's review of NR's and radiographs has not found any l recurrence of this type of problem. Review of records for final System Turnover will provide additional assurance that final radiographs for all welds are obtained or similarly justified.
I 1
l i
<~-
WHZ 2/24/02 !,
, Att'"Imant B Pcge C-7 C.1.d. l This item alleges that five reports identified only by CN-5122, CN-4389, CN-5476, CN-5477, and CN-5479 have been voided by personnel other than the Site QA Manager.
l As addressed in our response to Item A.5, three of these CN's l
l namely, CN-5476, CN-5477, and CN-5479 were not required to correct weld deficiencies for welds performed using the KEI-l form, since procedures required KEI-1A forms to be initiated to make weld repairs.
Each of the beams involved was known to require replacement as a consequence of the "new loads" in the Drywell resulting from reanalysis of the containment. This was so identified on the KEI-1A forms. There was no point in pursuing repair or rework on an NR for an item normally controlled via the KEI-1A form and for which a design
- change was known to require replacement or rework. The voiding is considered justified.
l The fact that these three CN's were all inappropriately i
Linitiated explains why the mere request by a QC inspector for a CN jdoes not automatically create an NR under QACMI G-4 and that the QC l
inspector's supervisors may properly decline to concur in the initiation of an NR. As noted, these CN's were clearly initiated in
, error and promptly corrected by the Site QA Manager personally after
!ho discussed the matter with the QC inspector's supervisors. 1/
i t
CN-4389 and CN-5122 were annotated as Inspection Reports. The voiding of CN 5122 occurred on January 2, 1981 by an individual with l
~
WHZ 2/24/82 At chment B Page C-8 initials that appear to be PSG. The voiding of CN-4389 by C. A.
Burgess occurred on December 2, 1980 prior to revising QACMI G-4 to allow only the Site QA Manager to void NR's.
CN-5122, related to a condition of minor significance (splitting of flexible outer coating in certain ' conduit) not requiring
'QA Engineering consideration, and was properly noted and dispositioned on UR-2800, which was signed by Site QA Manager Gittings. As the Investigation Report acknowledges, SR-2800 was initiated and closed
. prior to CN-5122 being written. The initials "PSG" which appear on stamp on CN-5122, are almost certainly those of the Site QA Manager
- Gittings. The fact that the QC inspector initiating CN-5122 did not
. understand the procedure for SR's or believed that duplicative
- reporting was proper does not render the site QA Manager's action invalid, since his action was taken to avoid unnecessary duplication.
Similarly, nonconcurrence in CN-4389 by QC Supervisor Burgess because all the hangers would require reinspection was a valid means to avoid duplication of documentation. The nonconcurrence was proper under the provisions of QAC.}I M-12, Paragraph 7.1 (Rev. 8), which
^roquires that an NR contain no more than one support. Accordingly, i
sho 33-page listing of numerous alleged nonconformances could not have been dispositioned properly as written on CN-4389. Utilizing CN-4389 as a reference, reinspection and reexamination is occurring and new MR's are being written up as appropriate for nonconformances detected.
s WHZ 2/24/02 Att-.hment B Pago C-9 C.l.a. ,
As stated in Item A.3, NR E-2466 involved numerous hangers in the Diesel Generator Rooms which were considered to contain defective welds. Fifteen of these hangers were crossed out with the notation that they were vendor supplied hangers. The Investigation Report states that this occurred during a revision to the report and without adequate justification. No annotations exist on NR E-2466 to dotormine who placed the "X" over these 15 hangers. If these were deleted by the initator, then no engineering justification was required since this was allowed by QACMI G-4.
In any event, the design changes and acceptance criteria changes for hangers had necessitated rework and reinspection of previously installed hangers. All hangers noted on the NR have been or are being reviewed for modification and reinspection as previously stated in Item A.3. Additionally, there is no evidence of a
" Revision" to this NR in the files. (This would have been noted by a Rev. No. next to the NR No.)
C.1.f.
l This item alleges that nine reports had not been issued NR
- numbers, copies of the reports had not been retained in the Site i
! Document Center, and compliance with the provisions of 10CFR50, Appandix B, Criterion XV for control of nonconforming items had not been attained. OACMI G-4, Nonconforming Material Control, makes provisions for annotating NR's as " Inspection Reports" and CN-4389 and
WHZ 2/24/82 Att .hment 3 Page C-10 CN-5122 were so annotated. Those two " Inspection Reports" were available in the Site Document Center file for inspection reports.
While properly filed as such, these particular CN's should not have !
boon prepared as " Inspection Reports." These CN's will be reviewed 1
)
under the QCP Task VIII and the hanger welds reinspected under QCP Taks 1 to assure proper inspection of the electrical hangers and prepar dispositioning of any nonconformances identified.
l The remaining CN's involve pipe support hangers in the Diesel Generator Rooms, which were previously listed on NR E-2466. As
-discussed in response to Item A.3, it was known that all hangers in this area would undergo reinspection following load reanalysis and
- possible design modifications. Reinspection is now in progress under significantly more stringent criteria than those which were utilized in citing nonconformances listed in NR E-2466 and all subsequent NR's will be appropriately dispositioned.
Soncific Corrective Action Taken For Item Col I
l In accordance with the Immediate Action Letter (IAL), Applicara has reviewed and. required revision of the Contractors' QC procedures to assure that instructions for entering, controlling, processing, and dispositioning of nonconformances is in accordance with QA program requirements. Furthermore, personnel have been indoctrinated in the application of these procedures through the upgraded QA/QC training program. To assure proper disposition and close out, all contractor MR's are being reviewed by a qualified QA Engineer. NR's may be sancelled only if they were written in error and with the approval of
WHZ 2/24/82
Attcckmont B Pago C-11 , ,,
the initiator end the Applicant'a Quality Accuranco Dapartmont Mancger.
I I
ITEM C.2 s
- a. ... nonconforming conditions were not identified and corrected : . . . (1) . . . welds. . . . (2) . . .re-entrant corners. . . . (3) beams not specified on any design documement."
- b. "
... cable tray hangers" Discussion:
Item C.2 alleges that nonconforming conditions were not idontified and corrected in accordance with the requirements of 10CFR50, Appendix B, Criterion XVI. Three specific parts are doccribed. Investigation Report 50-358/81-13 identifies these sub-itama as 358/81-13-27.
C.2.a.
Part (1) of this item alleges that NRC inspection on nine alcetrical structural hanger support beams identified unacceptable walde. The auxiliary steel beam welds in the Blue Switchgear Room are baing inspected as part of QCP Task 1. Some of these beams were inctalled without the required weld inspections being performed. /
WHZ~2/24/82 Att chmont B Pogo C-12 Part ('2 ) o f th_i s item alleges that five beams did not conform, t l with American Institute of Steel Construction ( AISC) requirements for the minimum radius of re-entrant corners. The auxiliary beams aircady ,
installed in the Blue switchgear Room are being inspected as part of tho.QCP Task i for re-er.trant corners. This inspection will assure that other weld and re-entrant corner deficiencies are identified and c .
corrected.
Corrective acylon measures to assure proper fabrication and installation of structural beams include indoctrination of const'ruction structural superintendents, foremen, and field angineers in the requirements for acceptable AWS structural steel welds and prcpor AISC re-entrant cornerp. 'Co rrective measures implemented to ,
cscure proper inspection of alA structural beams being installed include the preparation of work packages for all work which will statIe inspaction requirements necessary to assure that all work is performed ,
and inspected to project requirements. In addition, all essential l structural steel work being inspected under the requirements of the 1 -
IAL is by dual inspection.
Part (3) of this item alleges that four beams were not cpocified on any design documents. S&L Drawing E-189 F.'u ^ 3 Rev. E, Note 17 allows auxiliary steel electrical structural hangsc support boams to be installed and documented on a DDC for S&L approval. The-four beams identified by the NRC were shown on'the DDC S-2050 Sepia drawing maintained by Foothill Electric Company. The allegation that those beams were r.ct specified on design documents is incorrect. The .
onsite S&L engineer approved this DDC on october 15, 1980 in f
WHZ 2/24/82 ^ -
AttonhaOnt B PCgo C-13
- cecordanco with the alte procedures for control of DDC's. Final approval of this DDC by S&L occurred on August 6, 1981 with the incorporation of this DDC into Drawing S-546 occurring on August 16, 1981. The condition alleged to be a violation of design documents was in feet controlled as prescribed by the design documents and performed in cecordance with the design control requirements. It appears the NRC was regarding work-in-progress as final accepted construction.
C.2.b.
This item alleges that contrary to the requirements of 10CFR50, Appandix B, Criterion XVI, Corrective Action, cable tray hangers in the Cable Spreading Room (CSR) did not conform with AWS Dl.1 welding requirements for weld quality in that these nonconformances were not promptly identified anc' corrected. Investigation Report 50-358/81-13 identifies this item as 358/81-13-12.
As described in the Investigation Report, certificates supplied by the vendor stated these hangers meet the purchase specification requirements, which included welding requirements. However, no documentation of inspection records for hanger welds were available from the vendor. Site inspections performed after installation of hangers supplied by the vendor were not performed in accordance with AWS requirements, since the coating was not removed. Under QCP Task II, these hangers will be reinspected after the coating has been rcmoved. Any weld deficiencies identified will be documented on NR's and corrected in accordance with the OA Program requirements for NR's.
~
WHZ 2/24/82 Att ,hmont B Pago C-14 Soccific Corroctive Action Taken for Item C.2 Task l of the QCP has been implemented to identify and correct any olectrical hanger support beam weld or drawing deficiencies as wall as electrical cable tray hanger weld deficiencies. The general corrective action for item C contains steps taken to correct the underlying causal factors identified in each of these alleged deficiencies.
ITEM C.3
- a. "... socket engagement...was not verified...."
- b. "...in-process inspections... net performed...."
- c. "Five licensee audits of Sargent & Lundy identified repetitive t
problems...and action was not taken to preclude repetition."
DISCUSSION:
Item C.3 alleges that nonconforming conditions were identified by RC investigators that had not been corrected and for which actions cd not been taken to preclude recurrence. The Investigation Raport sdontified C.3.a and C.3.b. as 81-13-05 and C.3.c. as S1-13-35.
WHZ 2/24/82
~
Atto-kaOnt B Pcgo C-15 ,
C.3.c.
This item alleges that records indicate that socket disengagement for more than 439 welds were not verified in accordance with ASME Section III-1971, Subsection NB-3661.5b, and that the failure to verify this condition was not corrected in that the corrective action raken was not commensurate with the ASME Code.
Correspondence from the Site Authorized Nuclear Inspector (ANI) to Kaiser dated November 14, 1979, titled, " SIS Report" documents this lack of verification of socket weld fitup. A December 4, 1979 Kaiser lottor to the site ANI describes this lack of documented verification of socket weld fitup as chiefly a result of lost documentation and not the bypassing of holdpoints as assumed by the NRC. The Investigation Report acknowledges that the ANI had approved a 5% sampling of the socket welds as an acceptable means "to verify the integrity of the .
joint as well as the gap clearance." 2/ This 5% sample would be radiographed and, if acceptable, all 400 socket welds would be considered acceptable since verification is not required on a 100%
basis.
The radiographs for the 20 sample welds showed proper disengagement. Therefore, the ANI, as the enforcer of the Code, datormined, contrary to the NRC's allegation, that the corrective action was commensurate with the Code requirements.
Had any radiographs showed improper disengagement, radiography of l
the remaining socket welds, or at least a significant increase in the l
WHZ 2/24/82 .
Ati .hmont B Pago C-16 sample, would havo been required. However, no improper fitups or any other defects were found.
Additionally, NR E-1604 and NR E-2024 show the required engineering review and accept one of the fitup and cleanliness holdpoints being bypassed for the RT and NB system lines.
This item is being verified as part of QCP Task 4. Furthermore, documentation reviews for final System Turnover will assure that any other deficiencies sre identified and corrected.
C.3.b.
This item allges that records indicated that in-process inspactions for more than 22 welds in Diesel Generator Room piping systems were not performed and the condition was not corrected commansurate with the ASME Code. This is in essence the same
,allogation as item C.3.a in that fitup inspections were not performed.
The Investigation Report acknowledges that welds specified in this allegation as well as other welds within the Diesel Generator Room l piping systems which had been performed without QC verification for fitup were in fact documented on numerous SR's.
i 1
Many of the SR's and the welds listed therein were part of the total review conducted by the ANI as described in C.3.a. As such, worification of proper disengagement for these welds was part of the loverall sampling methodology authorized by the ANI. As noted, no
wurray75uywa '
r Atte-hmsnt B Pago C-17', ,
impropar fitups waro found in the radiographed armplac and the corrective action was, therefore, commensurate with ASME Code requirements.
C.3.c This item alleges that five licensee QA audits of Sargent & Lundy (S&L) identified repetitive problems in which S&L had not performed design calculations, reviews, and verifications, and that the corrective action taken did not preclude repetition.
The problems identified in the audit reports in question did not identify " repetitive problems concerning S&L not performing certain design calculations, reviews, and verifications" 3 / and action was taken to preclude repetition. Additionally, several of the problems raised in the afore. mentioned audit reports appear to have been taken out of context from the audit documents or were defined by the Applicant's auditor as audit findings or audit comments, which were in fact "in-progress" design activities in varying stages of completion.
Responses and resolutions to the indicated problems as well as a summary of the resolution to each problem are as follows:
l AUDIT DATED 8/8/74 PROBLEM (a) -
"ITE Imperial drawings of essential equipment had not been signed and bore no evidence of a design review."
L
was z<yzpJnts ~
. Att hment 3 Pago C-18 RESPONSE - This problem was resolved by Lottor SLC-4455, ptge 2, itcm 2, dated March 28, 1975, and accepted by Applicant in ,
letter SLQ-25, dated April 30, 1975. It is believed that this proble= was taken out of context. The drawing -
referred to in problem (a) had just been received by S&L for review and comment at the time of the Applicant's Audit. This drawing was subsequently reviewed and sent to the vendor with the comment to provide the~ proper' signature in accordance with QA Procedures.
PROBLEM (b) "There were inadequacies in documenting design reviews."
RESPONSE - ihis problem was resolved by Letter SLC-4455, page 3, item 5, dated March 28, 1975, and accepted by Applicant in LetterSLd-25, dated April 30, 1975. Specification B-2164, which was reviewed by Applicant's auditors was a bid specification. No fabrication or final design was based on the bid specification. Review and signoff of Addendum 1 of l this specification was made after the Applicant's audit utilizing the required standard forms.
PROBLEM (c) " Structural Design Calculations were not in accordance with new procedures."
RESPONSj - The reference made to "backfitting" calculations in the conclusion of audit item 2 of the S&L Structural Department on August 8 & 9, 1974 was only a suggestion made by the .
Applicant's auditor to update S&L calculations. This was
NHZ 2/24/82 (~ Att[imont B Page C ,
considered to be an open audit item for Zimmer 2, but not for Zimmer 1. S&L's practice has always been to review and approve all calculations in accordance with applicable S&L QA procedures in effect at the time of review. Old calculations that have already been reviewed and approved were not "backfitted" to conform with new procedures.
Plans for the construction of Zimmer 2 have been cancelled.
PROBLEM (d) "No direct evidence was available of the S&L review of vendor design calculations."
REPSONSE - S&L's review of vendor calculations was confirmed by Applicant's Auditors per page 12 of the August 8& 9, 1974 audit. The problem found by Applicant's Auditors was the lack of a vendor calculation log. The calculations log problem was resolved by Letter SLC-4455, page 5, item 11, dated March 28, 1974 which stated the vendor's letter of transmittal is being used as the calculation log.
Applicant concluded that the resolution to this problem was unsatisfactory in Letter SLQ-25, dated April 30, 1975; however, this conclusion was a difference of opinion between Applicant's QA Department and S&L as to the method used for logging calculations and not a finding that S&L was not reviewing vendor design calculations.
AUDIT 78/07 PROBLEM (a) "S&L had not maintained a record of support design calculations."
'~~
NH2 2/24/82 Att .hmont B Page C-20 RESPONSE - This probicm was resolved by letter SLC-12,066, dated January 26, 1979.* This letter stated that a project .
instruction, PI-21-13.1, dated October 10, 1978 was issued to S&L personnel on the Zimmer Project. This project instruction required the preparation, review, approval, and retention of support design calculations. It has always t
been S&L's position that a final verification of support .
l design with final design ioads would be performed prior to fuel loading. The results summarized in SLC-12,066 confirmed that this was an acceptable approach and minimal redesign would be required for the loading known at that time.
(Letter SLC-12,066 also references S&L letter SLC-11,387 and SLC-11,561)
PROBLEM (b) "DDC f2973 was approved without review by EMD even though a major support location change was clearly 4dentified on the DDC. (This item was identified in the details of the audit report, but was not identified as a i finding and had no apparent followup on the subsequent l
audits) . "
l l RESPONSE - This problem was resolved by letter SLC-12,067, dated l
January 26, 1979 (page 3) Project Procedure PI-II-2.1, Rev.
6 did not require an EMD Signature on the DDC because i
1 verbal approval of the support relocation was acceptable.
Since the issue of procedure PI-II-2.1 Rev. 7 on September i
I L
WHZ 2/24/82 '
Attr imont B Pogo C-21 .
20, 1978 this practice has been discontinued. This was verified during the 78/09 Audit (item 1B (b)) where it was indicated DDC M-2973 was disapproved and subsequently the audit finding closed.
AUDIT 78/09 i
PROBLEM (a) -
"Very little data was available to justify the embedment criteria of 4.5 times the normal diameter of concrete expansion anchors."
RESPONSE - This problem has recently been clarified by S&L in letter SLC-20,971, dated December 23, 1981. S&L indicated that expansion anchor vendor data was utilized for expansion and installation of anchors. Subsequent inspections and test were conducted to verify the data embedment criteria previously provided by vendors for design purposes. During the inspection process of expanrion anchors, the torque in
, the installed anchors was checked for a torque value which is less than the original installation torque. This reduced torque value is used to account for torque relaxation or preload relaxation of the anchor. Expansion anchors are torqued to a high torque value initially to assure that the wedge has been adequately engaged in concrete. The testing torque values were established from torque relaxation testing which was performed at an independent testing laboratory. It has also been substantiated through the independent testing laboratory
WHZ 2/24/82 Att shmont 'B Pogo C-22 that the main maximum load of an anchor appears to be insignificant 1y affected by a variation of the preloading on the anchor. Therefore, the testing torque values do not affect the ultimate capacity of the expansion anchors.
PROBLEM (b) -
" Calculations could not be located which would verify that a structured review was performed to show that no reinforcement was needed for a 24 X 68 radial beam which was cut at both flanges."
RESPONSE - This problem was resolved by Telex from S&L to Applicant dated November 20, 1978, which transmitted copies of the calculation sheets which verified the adequacy of field cuts to the subject beam. These calculations were in turn reviewed by Applicant (RE: Memo Crail to Schwiers dated January 9, 1979) and 've rified to be consistent with proper engineering design. This audit finding was subsegeuntly closed out in the 79/01 Audit during January 30-31, 1979 (reference item 2G). This item was also reviewed on December 17, 1981 by D. Chamberlain, NRC Region IV Reviewer.
i l
l AUDIT 78/10 PROBLEM (a) -
" Calculations were not available for all walls to substantiate the statement that block walls were ' judged to be OK'."
l l
l l
WHZ 2/24/E2 Att 'hment B Pege C-23 RESPCNSE - This problem was partially resolved by S&L's Letter SLC-11783 which transmitted sample block wall. calculations to Applicant for review. These calculations were reviewed and verified by Applicant (RE: Memos Crail to Schwiers dated January 9, 1979, and February 13, 1979) and found to be consistent with proper engineering design (design criteria for block walls at time of review) . The remainder of the problem regarding calculations for all block walls is covered by the response in S&L Letter SLC-20,971.
PROBLEM (b) " Calculations were not available to back up design signatures which indicated design verification for five design changes approving core bores."
RESPONSE - This problem was not listed as an open audit item in Audit 78/10. The Applicant's Auditor noted that since no calculations were available to substantiate the structural i
adequacy of concrete structures with core bores, S&L should then respond to this item by indicating the methodology used to assure that core bored holes do not compromise the integrity and original design of concrete structures. This audit i*.em was then considered to be open until the following were accomplished:
l
- 1) S&L initiates a method of flagging DDC's which are in ,
l l effect applicable documents, l
i
' WHZ 2/24/82 "
Att ,hmont B J
, Pago C-24 2)
S&L documents the methodology they use for assuring that core bored holes do not compromise the integrity and structural adecuacy of concrete structures.
- 3) The violation to Paragraph 3.3a of S&L Project Instruction PI-ZI-2.1 is corrected.
The above open items were recently addressed by S&L in Letter SLC-20971, dated December 23, 1981, Items 4 (b) 1),
2), and 3) respectively.
PROBLEM (c) -
"No approval signatures were found on any calculations for structural steel modifications due to Pool C Bydrodynamic loads.
The modification had been released for construction."
FESPONSE
- The problem was resolved by S&L Letter SLC-12, 553, dated April 6, 1979. Per this letter, approval signatures were not recuired for each calculation sheet, but only for the entire calculation volume. This signoff was accomplished
/
after..the subject audit in November, 1978 (approval at this time was based on original design loads) . Per S&L Letter SLC-20971, final Pool Hydrodynamic loads were incorporated in the calculations by December, 1979. These calculations were reviewed and approved which allowed structural steel modifications shown on drawings to be released for construction. S&L's curent procedure is to approve all l
WHZ 2/24/82 I' Att
~
iment B Pcgo C-25 '
design calculations for structural modifications prior to
, issuing drawings for construction.
PROBLEM (d) -
" Audit finding was closed based on calculations which were in progress, but not yet complete. The calculations were for beams (embedded plates) in the i
Primary Containment to verify that the plates can support additional loads."
RESPONSE - This problem was resolved by S&L Letter SLC-20971, dated December 23, 1981.
(See attached letter item 4 (d)) .
AUDIT 80/04 i PROBLEM (a) (1) - "The calculation required to evaluate the clamp deflection on a pipe support was not performed."
RCSPONSE - This problem was resolved by Letter SLC-17380, dated January 9, 1981. The deflection calculation was inadvertently omitted and was corrected October 27, 1980.
There.was no affect on the hardware.
' PROBLEM (a) (2) -
"Also, the weld calculation was not performed on the most critical weld."
! RESPONSE -
This problem was resolved by Letter SLC-17380, dated January 9, 1981. The weld calculation was inadvertently
WHZ 2/24/82 ~
Att .hment B P&go C-26 omitted and was corrected October 27, 1980. There was no affect o'n the hardware.
PROBLEM (b) " Calculations performed by NPS were incomplete in that the deflection due to torsional rotations of the beam was not i ncl ud ed . '"
RESPONSE - This problem was resolved by Letter SLC-17380, dated January 9, 1981.
Deflection due to torsion was not judged to be critical and was not originally included. Based on Applicant's audit finding, the torsion deflection was added to the calculation on October 27, 1980. No changes to the design resulted from this revision to the calculation.
PROBLEM (c) -
" Calculations performed were not in reasonable order, which made them difficult to follow."
RESPONSE - Applicant is believed that the NRC Investigator's problem is based upon the Applicant's auditor's personal comment in the text of the audit report. This item was not listed as a finding in Applicant's Audit 80/04. The statement that '
calculations were not perfer=cd in a reasonable order is subjective and was raised based on the auditor's personal opinion that the calculation sheets were not stapled in the correct order.
WHZ 2/24/82 ( Att' imont B Pago C-27'
Soccific Corrective Action Taken For Item C.3.
Socket weld fit up and irprocess inspection are being reviewed as part of Task IV of the QCP.
Task XI of the QCP is committed to review Applicant's past internal audits and audits of H. J. Kaiser, Sargent & Lundy, and General Electric to determine their depth and accuracy, particularly with respect to the 18 criteria of 10'CFR50, Appendix B, and to assure the proper close out of audit findings. Furthermore, the acceptability of areas not audited will be justified and any past deficiencies will be identified.
Item C.4
...of approximately 25 structural hanger support beams in the Blue Switchgear Room and the Cable
- Spreading Room, the identification of material in nine of those beams was not maintained to enable verification of quality."
Discussion:
This item alleges that, contrary to the requirements of 10CFR50, Appendix B, Criterion VIII, measures were not established to
, assure the identification and verification of quality of the material in nine of the twenty-five structural steel hanger support beams inspected by NRC Investigators in March, 1981.
i
6 ~~
At :hmont B Pago C-28 Investigation Report 50-358/81-13, idontified this item as 358/81-13-28.
The H. J. Kaiser Company QA Manual Section 8.2, as quoted in the Investigation Report, provides the measures imposed to maintain material identification. In the case of the structural steel hanger support beams, the material identification requirements of Sargent &
Lundy (S&L) Specification H-2174, only require assurance that the proper type of material is used.
A review of all purchase orders for W8x17 beams was performed.
All W8x17 beams were received with Certified Material Test Reports
("CMTR's") for each heat of steel. With CMTR's for all W8x17's, the prepar material usage can be verified. Accordingly, although the specific material identification on the beams has not been maintained, it can thus be verified that no improper material has been installed.
Criterion VIII does not require traceability in place. If all material received is verified correct during receipt inspection by comparison with the CMTR's, the requirements of Criterion VIII are met as wall as the requirements of B-2174.
' Soecific Corrective Action Taken for Item C.4 t
' Task 1 of the QCP is reviewing beam material to assure that approved boca material was used in correct locations, i
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WBZ 2/24/82 Att' 1msnt B Page C-29 '
Item C.5
"...FSAR design basis for electrical cable separation had not been translated into drawings and this resulted in. . . cable installation deficiencies in the cable spreading room."
Discussion:
This item alleges that the FSAR design basis for electrical cable separation had not been translated inco crawings and this resulted in five instances of cable installation deficiencies in the Cable Spreading Room.
Investigation Report 50-358/81-13 identifies this item as 81-13-31.
The Applicant does not agree that associated cables (g rocn/whi te , blue / white, and yellow / white) from more than one division cannot be routed in the same raceway (FSAR Rev. 77 Paragraph
, 8.3.1.13.2).
The routing criteria for associated cables was specified in paragraph E2 on Page 2-46 of specification H-2173, supplement 4 dated 6/9/77 as follows: "A non-eise.tial cable may be run in non-
- essential or Engineered Safety Fehtare (ESF) trays, but shall not occupy more than one ESF division tray system." FSAR paragraphs 8.3.1.12.2.3 (Rev. 76) and 8.3.1.13.2 (Rev. 77) contain revisions
'which were made to clarify this routing criteria for associated cables. (The NRC reviewed FSAR paragraph 8.3.1.13.2, Rev. 12).
l l
l
Wh2 2/36/82 Att ' hmont B Pago C-30 In Applicent's view, thoso requirements were properly translated into drawings detailing cable separation such that the installation described in itcas (a), (c), (d), and (e) meets the FSAR requirements.
Nevertheless, as a result of discussions with the NRC, FSAR Paragraphs 8.3.1.12.2.3 (Rev. 76) and 8.3.1.13.2 (Rev. 77) were .
adopted as revisions to clarify the routing criteria for associated cablos. It appears that the NRC investigation team reviewed cable ,
installation at Zimmer in light of an earlier version, FSAR Paragraph B.3.1.12.2.3 (Rev. 12) (June, 1976), which did not state the separation requirements as clearly as the subsequent revisions.
In addition, as a result of a review of the drawing for Sleeve No. 79, specified in item (a), it was determined that it had been incorrectly identified as blue (essential). Sleeve No. 79 was retagged as white (non-essential) in accordance with drawing E-279 Rev. A. Separation between cable No. RE053 (yellow associated) and blua tray no. '2072C was documented on NR Q-QAD-81-249-E for further cnalysis to determine that this exception to the separation criteria is consistent with the FSAR requirements, and does not degrade the safety of the plant. This approach is authorized by FSAR Paragraph 8.3.1.12.3.1 (Rev. 73) and Section 4.5 of IEEE 384-1974.
By letter dated May 18, 1981 to J.G. Keppler of NRC Region III, Applicant committed to remove the green instrument tray f rom the white control tray specified in item (b) in order to resolve a disagreement with the NRC. d*owever, no noncompliance as such existed.
^
( , .
WHZ 2/24/82 % ,..tochment B PcgG C-31 Specific Corrective Action Taken For Item C.S.
Under Task VI of the OCP, Applicant is reviewing cable separation in designated areas of the plant. Applicant's response to the IAL has initiated programs to include technical audits of construction work and more comprehensive and effective programmatic cudits in the areas of design control. The revised audit schedule is accompanied by the expansion of the Applicant's Quality Assurance Department staff to better conduct such detailed audits. In addition, the Applicant review of contractors' inspection procedures and the dual inspection program assure that the design bases stated in the FSAR are adequately implemented.
Item C.6 l a. "The weld acceptance criteria used. . .f rom July,1980 to January, 1981, were not applied to weld inspectio ns . . . in that weld acceptance criteria...were deleted."
- b. "The acceptance criteria for weld 55H...were not applied...."
l Discussion:
l l This item alleges two instances occurred in which weld l
l acceptance criteria were not specified as required by ASME and AWS Codes and 10 CFR50, Appendix P, Criterion III. Investigation Report No. 50-358/81-13, identifies Item 358/81-13-23 as applying to this
... ~
WHZ 2/24/02 Attachmsnt 3 Pcgo C-32 item of insufficient design control measures to assure the delineation of acceptance criteria for inspections and tests.
C.6.a This Item alleges that, during the period from July, 1980 to January, 1981, weld inspection criteria were deleted for items such as drywell support steel. The inadvertant deletion of weld acceptance criteria from KEI-1 forms was in f a ct discovered by Kaiser QA prior to its notation by the NRC and appropriate corrective action had been taken. The deletion occurred because a new Weld NDE QA Engineer, intending to delete the requirement for fitup inspection deleted additional requirements as well.
A review of the AWS Code requirements confirms that the only inspection criteria applicable to all drywell support steel fillet walds are verification of weld procedure, welder qualif'ication, filler material identification, and final visual inspection. The weld NDE QA i
Engineer selects additional inspection criteria deemed necessary to provide further assurance of quality. Since the KEI-1 form is designed explicity to comply with all ASME weld inspection criteria, the use of this form for AWS welds may necessitate designating some of the inspeccion criteria on the KEI-1 form, as "not applicable."
However, these weld inspection criteria were also inadvertently deleted from KEI-1 forms relating to full penetration welds.
i
T
("~ r . .'
WH2 2/24/02 1
..tachmant B Pago C-33 C. 6.b' , .
This Item alleges that 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. After an extensive review of weld number logs, we cannot identify weld 55H.
There is no weld 55H on PSK-1WS32. There is no weld 55H in Line No.
1WS17A18. It appears that this number was incorrectly identified by the NRC.
Specific Corrective Action Taken For Item C.6.
OCP Task II requires a review of all AWS Structural Steel weld' data sheets from July, 1980 to Februar', y 1981, to assure that no required AWS inspection criteria have been deleted. To assure that properly qualified welders performed structural steel welds, QCP Task II also includes a review of welder qualification. A determination that the welders performing AWS Structural Steel welding were qualified to the AWS welding procedures will assure the acceptability of those welds f or whi ch this inspection requirement was not specified as applicable.
Other corrective action taken is detailed in the IAL response.
4 WP.I 2/24/82 Attachmant 3 Pago C-34 Item C.7 -
...the licensee failed to detect that the penetrameter shimming was insufficient to satisfy the requirements of M.W.
Kellogg Procedure...or the ASME Code."
Discussion:
This item states that contra ry to the requirements of 10CFR50, Appendix 3, Criterion XI, the review and evaluation of 187 radiographs did not assure that test requirements were satisfied in that the Applicant did not detect the fact that M.W. Kellogg Co., the large bore pipe supplier, failed to sufficiently shim the penetrameter to the requirements of the Kellogg Procedure ES No. 414 or the" ASME Code.
l Investigation Report 50-35P/81-13 identifies this item as 358/81-13-11. This item resulted from a difference of opinion in the interpretation of the ASME Code Requirements for radiography. It is significant that the Investigation Report acknowleges that "no unacceptable welds were identified" by the NRC investigators. Of particular significance is the fact that an NRC contractor independently radiographed 7 welds similar to the 187 welds in question and "no rejectable indications were identified in the new radiographs."
, Radiography is considered to be a special process. Under the-quality requirements of 10CFR50, Appendix 3 this would f all unde r
WHZ 2/24/82 ,..techment B Pcge C-35 Criterion IX. There does not appear to be any explanation for considering this an item of noncompliance under Criterion XI.
Soecific Corrective Action Taken For Item C.7. ,
In accordance with Task V of the QCP, NDE personnel have l
rev iewed the M. W. Kellogg weld radiographs and identified those radiographs which are either unshimmed or under shimmed. For each ,
pipe size and wall thickness those radiographs of the poorest quality have been identified. From this group, one weld of each pipe size and wall thickness will be radiographed using the original technique as nearly as possible, but with both an unshimmed penetrameter and a penetrameter shimmed an amount equal to the total weld reinforcement.
If the essential hole or slit in the penetrameter is visible, indicating acceptable' quality of the film for interpretation, then all radiographs for that pipe size and thickness will be acceptable. This verification program has the concurrence of the National Board of Boiler and Pressure Vessel Inspectors and the State of Ohio. In addition, a code inquiry will be prepared, requesting an interpretation of the ASME requirements.
ITEM C.8
- a. "As o f Ma rch, 1981, design control measures had not been established to assure that deviations from design conditions (quality standards) identified by Sargent &
Lundy Engineers were controlled."
WHZ 2/24/82 Attachment 3 Page C-35
- b. ... design control measures...not established to provide for verifying or checking the adequacy of design for... thermal loading...and the physical weight loading...."
- c. ... cable ampacity design by Sargent & Lundy was not based on IPCEA P-46-426 and the FSAR limit on cross-sectional area."
d.. ... design allowable undercut on cable tray hanger welds was not based on AWS D.1-1971 Code. . . . "
Discussion:
This item alleges that four instances were identified in which the design control measures for assuring appropriate quality standards are specified and included in design documents , for controlling deviations f rom such standards, and for verifying or checking the adequacy of design, were ,et established or based on FSAR commitments as required by 10CFR50, Appendix B, Criterion III.
C.S.a.
This item identified in Investigation Report 50-358/80-13 as Item 358 /81-13-21 states that as of March, 1981, design control measures had not been established to assure the control of deviations from design conditions (quality standa rds) identified by Sargent &
Lundy (S&L) engineers. A S&L Calculation Sheet dated December 27,
p-WHZ 2/24/82 m.rachment B Pago C-37 1979, contained a note on the bottom of the thermal calculation sheet f or Yellow Cable Tray #1057A,_ indicating that the design thermal loads for two power cables (VC016 and VC073) exceeded the design limits.
The NRC investigator alleges that the overloaded cables were not identified on any control document that would have required appropriate evaluation and disposition. He further states that S&L personnel stated they did not have a control program for such design deviations when identified by S&L engineers.
Contrary to the NRC's allegation, design control measures had been established and were effective in assuring that deviations from design requirements were controlled. S&L's General Quality Assurance Procedures GQ16.02, provide the methods for documenting, evaluating, and dispositioning design deviations identified by S&L employees. S&L QA Program Topical Report SL1-TR-1A,.Section 16.00, Corrective Action, states, " Procedures assigning responsibility for identifying and promptly correcting nonconformances are included in the OA Manual.
l These procedures require any person who detects an apparent l nonconformance to notify the Head, Quality Assurance Division." These nonconformances may be detected during the review process by other means.
The design calculation identified by the NRC Investigator l concerned Power Cables VC016 and VC073. This calculation was in the process of being reviewed by the S&L Senior Electrical Project l Engineer and was on his desk awaiting the verification of motor nameplate data from Zimmer. This motor nameplate information had been requested. This design calculation and review process was as l
L
j WHZ 2/24/02 Attachmont S Pago C-38 I
l described and controlled by S&L General Quality Assurance Procedure -
I 1
GQ3. 08 Design Calculations. l This calculation 'was an in-process document being controlled under the review process to preclude final acceptance pending completion of the design calculation review. The nameplate data showed the cables were not overloaded as the note had stated..
Under the S&L QA Program, had the nameplate da ta shown the cables to be overloaded, then the control measures for deviations from design conditions in GQ16. 01 and GQ16. 02 wo uld have been initiated.
- '- e C.8.b.
This item (b) identified in Investigation Report 50-358/81-13 as Item 358/80-13-19, states, " As o f Ma r ch,, 1981, design control measures had not been established by S&L to provide for verifying or checking the adecuacy of the design for the thermal loading of power cable sleeves and the physical weight loading of cable trays."
+
The Investigation Report Section 5.10.3.3.5 on page 81, states that neithe r PIZ I-10.1 Rev. O nor any other document establishes controls to verify the thermal loading of power cable sleeves and physical loading 'ef trays. Contrary to this statement, the thermal loading of power sleeves and the physical weight loading of cable trays was systematically being monitore'd by the computer Ca ble Indexing System-3 (CIS-3) cable report. Data from each cable pull
, card or cable tab concerning cable size and type, and route points is e
,r' _r- .
WHZ 2/24/82 Attachmont B Page C-39 input in.to the CIS-3 program. This program monitors each tray segment agafnst the design index of 1.25. Any tray segment (mode) with a design index over 1.25 is subjected to both thermal and physical load ca lc ula t ions .
Although not explicitly stated in project pro cedure PI-Z I-10.~1, Rev. O, therinal power sleeve and cable tray weight calculations were being performed. Rev. 1 to PI-ZI-1.01 was implemented in Ma rch , 1981 at the verbal request of the NRC investigator to state explicitly that each of these calculations were to be performed. This request is doc umented in the Investigation Report, page 8 2. The measures beinh implemented to control thermal & physical loads were ade ~2 ate and were being implemented in compliance with 10CFR50, Appendix B, Criterion
?
III since interim calculations for tray segments with design indices exceeding 1.25 were in the process of being completed and were controlled by maintaining a list of all " modes" exceeding 1. 25 to assure that the required calculations were performed.
t C.8.c.
This item identified in Investigation Report 50-358/81-13 as Item 358/81-13-17, states that as of March, 1981, the cable ampacity design in use by S&L was not based on the IPCEA P-46-426 standard identified in the FSAR, and was not based on the FSAR limit on cross-sectional area.
The limits on cross-sectional area for cable ampacity have been t
clarified in Rev. 72 of the FSAR. This change also reflects the i
.a -
s.
WHZ 2/24/82 Attachment 3 Pogo C-40
, s i
Stolpe method of determining ampacity for cables in trays. The FSAR limit on cross-sectional area for cable ampacity continues to be implemented in the design process by using the same design index numbe r o f 1. 25. ~ ~ "
_C.8.d.
This item identified in Investigation Report 50-358/81-13 as Item 358/81-13-14, states that as of March, 1981, the design allowable undercut of 1/16" on cable tray hanger welds as specified in S&L Specification H-2713 and H. J. Kaiser Procedure SPPM-4.6 was nott based I
on the AWS D1,1-1972 Code.
s When docketed in September, 1975, the Zimmer FSAR was '
consistent with other plants filed during approximately this same.
time. The S&L Design Control Summary and Design Verification NOEE
~ ~
000Z documented the calculations necessary to justify change from y
1/32" to 1/16" a11owa ble . unde rcut on cable tray hangers.
As was customary with other FSAR ' commitments on plants under construction, modifications, and specific standard criteria supported by.eigineering i -
evaluations jusiifying such modifications, were not rcutinely required by the NRC to be processed as f ormal FSAR amendments' prior to implementation. 4/
As requested by the NRC, revision 77 to the FSAR states that deviations from specific requirements of AWS D1.1 1972, may be made on the basis of design calculations and investigations.
- f WHZ 2/24/82 Attachment 3 Page C-41 Soecific Corrective Action Taken For Item C.8.
In response to the April 8,1981, IAL item concerning the control of deviations f rom FSAR commitments, a S&L Project Instruction and an Owners Proj ect Procedure has been implemented to identify deviations from codes, standards, and FSAR commitments.
Implementation of these procedures assure continued compliance with the requirements to control design deviations from standards and FSAR commi tme n ts .
Applicant has taken steps to strengthen control of the architect / engineer's design control program through the establishment of the revised Applicant audit program to include technical audits of construction work and more comprehensive and effective programmatic audits.
The Applicant's Nuclear Engineering Department has been formed and has expanded its staff with qualified personnel to better augment the Applicant's Quality Assurance Department',s audits for review and control of the design control program of the architect / engineer.
f l
Task VIII of the OCP include determining that all final design calculations , verifications , and reviews are completed, and assuring the adequacy and correctness of design change control system and FSAR deviations prior to April 8, 1981.
e I
WHZ 2/24/82 Attachmont B Pega C-42 ITEM C.9
- a. "...QC Program not established to require verification of cable separation...."
- b. "The programs established for in-process and final inspecting of welds. . .not executed as required in the AWS D.1-1972 Code."
Discussion:
This item alleges that contrary to the requirements of 10CFR50, Appendix B, Criterion X, Inspection, a program for inspection of activities affecting quality had not been established for verification ,
of separation of electrical cables from the Cable Spreading Room (CSR) to the Control Room and the program established for in-process and final inspection of welds on 180 cable tray nagers located in the l Cable Spreading Room was not executed in accordance with the l
requirements in the AWS D1.1 code.
C.9.a.
This item is i dentified in Investigation Report (5 0-3 58/81-13 a s
! Item 358/81-13-32 and specifically named two Slue Cables RI 103 & CM 111 that had been bundled into Tray Risers (G r ee n) No. 3025A which extended from Tray (Slue) No. 2077A in the CSR to the Control Room.
9
WHZ 2/24/82 AuccchmGnt B Pega C-a3 The QC Inspection Procedure, OACMI E-7, under the Responsibilities section, requires the DC inspector to understand the separation criteria contained in specification H-2173 pages 2.43 to 2.45a. A review of'the Pull Cards and Construction Inspection Plans l
f or Ca bles RI 103 & CM 111 show these cables were installed in l l
cecordance with the separation criteria of H-2173 and the Cable Tab j design documents.
Subsequent to the completion of the cable pulling, these cables were incorrectly bundled into the Green Tray Riser.
While the above clearly shows that the required inspection program had been established, the specific conditions which allowed
~
the incorrect bundling of these cables to occur will be reviewed by Foothill Electric Company (FEC) and action taken to preclude recurrence.
C.9.b.
This item is identified in Investigation Report 5 0-3 58/81-13 a s Item 358/81-13-13. This item and specific corrective action is addressed in response to C.2.b. The reason for performing the CSR cable tray hanger inspections through pain [ appears to be an inadequate understanding of the AWS D1.1 requirements by the QC inspectors.
l I
l
WHZ 2/24/82 Attachmont 3 Page C-44 Soecific Corrective Action Taken For Item C.9 Actions taken to address noncompliance C.9a, above, have been previously discussed under noncompliance C.5 as measures established under Task VI of the QCP.
QCP Task VI, includes measures to verify that no additional separation violations exist between the CSR and the Control Room.
The response to the IAL addresses procedure reviews and training to preclude recurrence of items of this nature.
ITEM C.10
- a. "...QACMI G-14, " Surveillance Reports," (SR) was not apprcpriate...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...."
- b. "...QACMI G-14 was not followed in that SR's...were not dispositioned within 30 days and were not transferred to NR's...."
l t
l .
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r .
,e ,
WHZ 2/24/82 '
As ccchmont B Pago C-45 Discussion:
This item alleges that contrary to the requirements of 10CFR50, Appendix B, Criterion V, surveillance activities reported in accordance with OACMI G-14, Surveillance Reports, were not prescribed by instructions appropriate to the circumstances and were not accomplished in accordance with these written instructions.
C.10.a.
Investigation Report 50-358/80-13 identified this item as 358/81-13-24 and states that OACMI G-14 was not appropriate to the ci rc ums tances in that it allowed in-process nonconformances which constitute field changes to be dispositioned within 30 days without design control measurements commensurate with those applied to the original design.
The three surveillance reports (SR's) F-2P99, F-2903, and F-2914 specified in this item each identify' inspections which were not performed. SR-2899 concerned verification of torque on conduit straps and non-engineered hangers. The inspection frequency requirements for verifying torque were imposed by the constructor's Quality Engineer (OE) and not by Sargent & Lundy, the Design Engineer. Thus, the disposition by the Constructor's OE was commensurate with those applied by the original design since the original design did not
. impose 100% inspection requirements for verifying this torque, but allowed this level of inspection to be determined by the Constructor.
(- --
WHZ 2/24/82 Attachment 3 Pago C-46 Similarly, SR-2914 concerned a butt-up weld for an end brace.
Again, inspection requirements for this type of weld are not expressly imposed by the Design Engineer but left to the Constructor. Thus, the disposition was commensurate with original design.
Only th'ese SR's which were dispositioned to be accepted-as-is wo uld require evaluation to determine if a review and approval commensurate with the original design requirement is necessary since r ewo r k items are dispositioned by the field engineer alone. For SR-2914 and SR-2899, QACMI G-14 was followed since neither condition required the in-process deficiency identified to be corrected using an NR. These SR's did_not require the use of an NR because they did not require approval of the disposition at a level beyond the Constructor's QE who imposed the requirement for inspection in the first place.
For SR F-2903, the ASME Code required inspection hold points were l
l bypassed and, therefore, review by Design Engineers who reviewed the original design was required. The corrective action for this deviation was reviewed and signed by the ANI, indicating his '
concurrence with bypassing those hold points.
I C.10.b i
Investigation Report 50-358/81-13 identifies this item as 358/80-l 13-25 and states that G-14 was not followed in that SR's were not dispositioned within the prescribed time period and were not transferred to NR's as required by QACMI G-14.
. ~ . _ - _ _ ,
e s-WHZ 2/24/82 At t.' ' ment B Pcgs C-47 This item appears to have been created by the Applicant taking corrective action to control records as required by the IAL of April j 8, 1981. The action of removing QA records from Kaiser's custody also removed many in-process records which could not, therefore, be dispositioned by Kaiser within 30 days since they did not initially have access to the records. The understanding of how SR records were to be handled after the IAL was not clearly defined until August 5, 1981, when the QCP was agreed upon. Th e fact that the SR's we re still not dispositioned by August 12, 1981, appears to be quite understandable. The dispositioning and close-out of all SR's written prior to April 8, 1981, is now described by the QCP Task VII.
A spot check of other SR's written within 30 days of the IAL, shows that those SR's not properly dispositioned prior to April 8, 1981, are still not closed because of the QCP requirements for review and close-out.
Only one of these SR's, SR-2909, was initiated prior to the 30 days before the IAL. This was January 16, 1981. This SR states that a copy of the SR was not sent to Foothill Electric at the time of initiation and the items were transferred t'o SR-2990 for close-out on February 19, 1981. A review of SR-2990 shows that these items were all closed within 30 days. This exception is well explained and as a single case is not indicative of a problem in resolving SR's as required by G-14. -
WH2 2/24/02 Attachment 3 Page C-40 Specific Corrective Action Ta ken For Item C.10.
In accordance with the IAL, QACMI G-14 procedure has been revised, and all SR's are submitted to the Applicant for review and approval of dispositions to assure these SR's do not identify nonconforming conditions. This review is performed by a qualified QA engineer.
In addition, all NR's are being reviewed under Task VII of the OCP to assure that any NR conditions identified are dispositioned and reviewed commensurate with the origina.' design.
ITEM C.11
"...neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the control of quality by vendors who had supplied structural beams...."
Discussion:
t l This item alleges that contrary to the requirements of 10CFR50, Appendix S Criterion VII neither the Applicant nor his designee, Sargent & Lundy, has assessed the effectiveness of the control of l quality by the vendors who supplied structural steel beams.
Specifically evaluations of the Quality ,\ssurance Programs for U.S.
Steel Supply, P3 I Steel Exchange, and Frank Adams Company were not performed to assure control of mill certifications for structural l stoel beams.
l l
WHZ 2/24/82
('
? .
A-ccchmont B Pago C-49 Investigation Report 50-358/80-13 identifies this item as 358/80-13-29.
l The NRC Investigators have incorrectly assumed that the i Applicant's designee is Sargent & Lundy. Page 146 of the Investigation Report identifies seven purchase order numbers for the three companies whose quality programs had not been evaluated. These purchase orders were issued during the period February, 1974, through March, 1976. The OA Program commitments in the Preliminary Safety Analysis Report (PSAR) in effect during this period, place the responsibility for evaluating the quality assurance programs of essential suppliers with the Constructor, who also initiated the purchase orders (P.O.). There was also no requirement in effect to evaluate the quality programs of nonessential material suppliers. All seven P.O.'s did require the mill test reports to accompany shi'pment of the material and that the material be ASTM A-36 grade steel. Since the material possessed mill test reports, proper assurance as to the material type for the W8x17 auxiliary structural steel hanger support beams was documented; therefore, these beams were upgraded as essential on the warehouse material issue slips designating the end use, heat number, and P.O. for each W8x17 auxiliary steel beam issued i
by the warehouse. Each material issue slip was signed by the responsible QA Engineer.
This practice was acceptable to the NRC and is documented in IE Inspection Report 358/76-02, dated March 12, 1976. It is important to note that all these P.O.'s were issued before this March 12, 1976 date. In Inspection Report 358/76-02 under Management Interview part
WH2 2/24/82 At .hmont B Pcg o C-5 0 B.1 on Page 3, the IE Region III investigators expressed their concern regarding misec11aneous structural steel purchased as Class II material and installed in Class I areas.
The report states on Page 4 part B.3, "The (NRC) Engineer Inspector stated that a review was conducted of records relative to... utilizing miscellaneous structural steel purchased as Class II (non-essential) such as plate, I-beams, anchor bolts, etc., in Class I (essential) areas. The inspector established that Class II materials are properly documented and traceable and met applicable requirements .
for installation in Class I areas." Page 5 of this report specifically identifies material reviewed by the NRC as W8x17 beams purchases on P.O. numbers 12868 from U.S. Steel Supply and as identified by heat number H09075.
Therefore, this practice was explicitly reviewed by the NRC Investigations in Region III and found to be acceptable and meeting
" applicable requirements for installation in Class I areas."
i Soecific Corrective Action Taken For Item Cell.
QCP Task I is reviewing all field purchased steel plate and structural shapes received on-site and for the purpose of identifying potentially deficient material. Appropriate action will be taken to resolve such deficiencies. .
WHZ 2/24/82 [ Atti, ' ' ~ mant B Page C ITEM C.12 "The Bristol Steel and Iron Works Quality Control Steel Erection Report...did not identify closely related data such as weld procedures numbers, types of welding material, welder identification,.and specific welds inspected."
l l
Discussion:
This example states that contrary to the requirements of 10CFR50, Appendix B, Criterion XVII, sufficient records for monitoring in-process steel erection were not maintained by Bristol Steel and Iron Wc ks to furnish evidence of activities affecting quality in that the generic forms used did not identify weld procedure numbers, types of wald material, welder identification, and specific welds inspected.
Investigation Report 358/81-13 identified this Item as 358/81 30. A review of Bristol Steel documentation to date, shows that all the required weld process data was not documented during their
. inspection of structural steel erection. This review and corrective
- action required.is being included under the QCP Task II. Since much i
l of the work was performed very early in the project, (circa. 1973-74) the inspection documentation deemed necessary that time to show compliance with specified requirements was less than the documentation expected today.
WHZ 2/24/02 Attachment 3 Page C-52 Specific Corrective Action Ta ken For Item C.12.
Specific corrective action to be taken for the lack of weld quality documentation will be identified after the total QCP review has been completed for Task II and deficient welds will be identified on nonconformance reports.
ITEM C.13
"...during the past 9 years , the licensee. QA Division did not perform an audit of the Sargent & Lundy nonconformance program. "
Discussion:
This item alleges that contrary to the requirements of 10CFR50 Appendix E, Criterion XVIII,'a comprehensive system of planned and periodic audits was not carried out by the Applicant's to verify compliance with all aspects of the QA program and to determine the offectiveness of the program since they did not perform an audit of the S&L nonconformance program during the past 9 yea rs.
t Investigation Report 50-358/81-13 identified this item as 358/81-13-35.
i l
As the Architect-Engineer (AE) providing design services, S&L does not provide any materials, parts, or components recuiring a nonconformance control program. The S&L QA Program Topical Report SL-TR-1A, which has been approved by the NRC's Office of Nuclear Reactor l
o <
WHZ 2/24/82 Attachment B Pago C-53 Regulation, states in Section 15.00, Nonconforming Materials, Parts and Components, that, "S&L does not engage in direct activities which require a quality assurance program for nonconforming material parts or components...." The appropriate S&L engineering division reviews do c umen t instances of nonconforming parts and components where such nonconformance affect design, and the Project Manager p'rovides the Client with a written evaluation of such effects. Recommendations are made in accordance with specification and design requirements."
As identified by the Investigation Report, page 152, S&L Project Instruction PI-ZI-8.1, the responsibilities and instructions for reviewing nonconformance reports (NR ' s ) initiated by other organizations are described within the OA program for document control (Criterion VI), design control (Criterion III), corrective action (Criterion XVI), and quality records (Criterion XVII).
While the Applicant's audit record did ndt show a review of activities performed by S&L under Criterion XV for nonconformance i control, the audit records do show consistent periodic reviews of the activities performed in accordance with the four Appendix B criteria l mpplicable to the review and processing of NR's from the Zimmer l Project. Since t"e results of these reviews are documented on the l
NR's when they are returned from S&L (see NR-E-2996, page 17, Attachment A c f the Investiga tion Report) , sufficient evidence is available to show that the specific design deviation evaluation l process and documentation of the justification for such deviations from design preclude the necessity of performing frequent audits l
l covering the S&L processing of Zimmer NR's.
3 # J ,,y4 J ,e - . e-e-e ~
WHZ 2/24/82 Atta chment B Pago C-54 Nonetheless, the Applicant performed an audit of the implementation of PI-ZI-8.1 on September la thru October 2, 1981 (Vendo r Audit Repor t # 81-10) . Specific note was made of the control of design changes resulting f rom Zimmer NR's and no deficiencies in this program were identified relating to the design change control requirements and documents reviewed during this audit.
Specific Corrective Action Taken For Item C.13.
Although the Applicant feels that this item is not a noncompliance, past audits could have been more comprehensive. Ta s k XI of the OCP is in the process of reviewing past a udi t reports and identifying deficiencies.
As previously stated, the revised audit program will enable more comprehensive audits and assure contractors' adherence to the applicable criteria of 10CFR50, Appendix 3.
l .
!. Generic Corrective Action Taken and Results Achieved For A11eced Violation C The corrective action taken to assure continued compliance with i
the requirements of the criteria of 10CFR50 cited in this Attachment, has been addressed in the Applicant's May 18, 1981 response to the IA L dated April 8, 1981, and through the establishment of the QCP. These measures are being implemented to veri #y the adequacy of the construction of the Zimmer Station as prescribed in the Final Safety Annlysis Report (FSAR) and applicable codes. These actions will
r f- , .
WH2 2/24/82 Actachment B Pago C-55 further help to assure the integrity of all structures, systems, and components necessary to prevent or mitigate the consequences of nuclear accidents.
Since April 8, 1981, .ne Applicant has completely reorganized the Quality Assurance Department to address the underlying causal factors loading to the issuance of the IAL. The size of the quality assurance staff has been increased to over 200 quality assurance engineers, specialists , document reviewers, and inspectors. All quality assurance and quality control procedures have been reviewed for clarity, accuracy, and technical content. The deficiencies identified have been addressed through procedure revisions and, where required, new procedures have been implemented. Individuals wo rking to applicable procedures are appropriately trained to assure the requirements specified are clearly understood. Each time a procedure is revised, personnel working to the particular procedure are trained to the changes incorporated in the revision. An improved inspector certification program has recently been implemented and is providing additional confidence that personnel performing quality related functions are adequately trained and qualified in the areas of their assigned tasks. In addition, the qualifications of non-inspection parsonnel performing a quality function are currently being reviewed.
The Applicant has assumed the complete management function of quality records. A new permanent site facility has been constructed for the handling, storage, and protection of such records. A Documentation Verification Group has been established te sview essential records for completeness and accuracy. Procedures have been
WHZ 2/24/02 Attachment B Page C-56 I
implemented to provide improved receipt, control, and maintenanca of !
the aforementioned documentation.
Assurance that the eighteen criteria of 10CFR50, Appendix B are being implemented.by all organizations performing qual!.ty related work is provided through an upgraded audit , program. The revised audit l schedule has been reviewed to assure all organizations performing quality related funetions are audited on a regular basis. To enhance the quality of the Applicant's audits of contractors and support organizations, the audit group staff has been increased with qualified personnel. Comprehensive and detailed audits covering a range of topics from program commitments to construction work activities are bning performed. The vendor audit schedule has been reviewed for appropriate inclusion of essential equipment suppliers, and a system has been developed to assure more timely follow-up of audit findings.
Furthermore, a system of tracking and assuring proper closure of c ommi tme nts , Nonconfo rmance Repo rts , and audit fi.1 dings has been l
l ostablished.
l Verification of the effectiveness of the Constructor's quality l control inspection program is being conducted through the 100%
l reinspection of ongoir.g construction wo rk by Applicant personnel and a program to per f o rm a 100 % review by an Applicant Quality Engineer of all contractors' Surveillance and Nonconformance Reports. The effectiveness of the Constructor's quality inspection program has l f urther been assured by the implementation of new and revised l
l inspection procedures, comprehensive training, and intensified programmatic audits. A revised surveillance program is being
? - -
r r .
WHZ 2/24/82 s.:cchment B Page C-57 developed to observe construction activities affecting the quality of the plant. Successful implementation ~of this program is expected to reduce the requirement of 100% reinspection of constructor's work.
In addition to the above actions, a QCP has been established within the Quality Assurance Department to confirm the quality of construction work completed prior to April 8, 1981. This program is l
addressing the following areas of concern:
I Structural Steel II Wcld Quality III Heat Traceability IV Socket Weld Disengagement V Radiographs VI Cable Separation VII Nonconformances VIII Design Control and Verification IX Design Document Changes X Sub-contractor QA Programs XI Audits The OCP is approximately 50% complete at this time. Al thoug h minor deficiencies have been identified in each area of concern, none has yet been significant to the safe operations of the plant during its expected lifetime.
, - ~ -
WBZ 2/24/82 Attachment 3 Pago C-58 As a result of the above actions, the Applicant has inc~reased the overall effectiveness of the quality organization and has made all personnel associated with the Zimmer Project more quality conscious.
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WHZ 2/24/02 Att6 .mant B Page C-59 Footnotes Referenced in Response,to Alleged Violation A 1 / See Investigation Report, A, p. 26. While the voiding statement is signed by Rex Baker, it was therefore at the direction of the Site QA Manager. It is rated that this particular allegation charges that these " reports" were voided by personnel other than the QA Manager, while three of the same " reports" are alleged to have been " deleted from the NR system at the direction of the Kaiser QA Manager" in Item A.S. Obviously, the two theories in these allegations are inconsistent.
2 / Memo from ANI Lowell Burton to H. J. Kaiser, Co. (November 14, 1979). See NRC Report Section 4.3.3.6. While the NRC Report asserts a lack of " engineering justification" for the sampling procedure, Sargent & Lundy stated that no justificat!on or approval was necessary by their engineer since verification of the socket disengagement was a Kaiser procedural requirement.
j The Reports states no basis for challenging the sampling method or asserting a need for engineering justification to approve the sampling methodology. Accordingly, the corrective action of 5%
j sampling was commensurate with ASME Code Section III.
3 / Investigation Report Section 4.3.3.6.
i 4 / Applicant's calculations justifying the change were shown to Region III. The NRC inspectors made no suggestion of any problem and have not done so in the intervening years until now. Had any l
i problem been noted, Applicant would have, of course, sought
. - p.,
WHZ 2/24/82 Attachment 3 Pago C-60 specific approval from the Office of Nbelear Reactor Regulation.
i Given the NRC's long acceptance of this change, Applicant does not understand why the matter is now thought to demonstrate a weakness in its QA program.
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'- * '. ' a1 5.4 y~ S.o'. e.v. * . a . . .<
u ...J..g 5..%. .
f e it..$$ [ W : T..
.:.e ,J.fM.- '
m E.J.<a g.u.w . =a [ 9,. f .m. .y 7 . .4 rMQ"C.**:c : et.m . v t & N,. Qg d,. 4.
- w. %.w a ygday e p..n.3 h g g*=* .
tr=N D .I'.M N The t:5 ting torqu$ Value$ Ve:S esta.bliEh0d frd U N .*i i it**: ? ; G 3 h ?[
MNW laxation testing which vas porkr ed at as: bi6phdenEE-TfJ AM
-@2h%t.$ testing itberat=ry . It has ahe been schstanti:EED ishNViG
~
%C the independent te st.iti.' h. heratorv. that the mean;fn .E . .
W :3 4&y.,M, cr . . -
ancher typer.:s to .he beignificanbly ~
e af d.1 fe,,i,s,Ee...
AuN W@W [F . lead ef e.:by a variatien of tha prelcad'is ':t.eiefore?.theQB3
&q,, the escherc
- [g; m a.c:s the e va=4 yhn v m ... kL.,shf'...r. .
testing'terque c . m . p *: k. e . values g
.m. e'p._ww. . c.. v. ..-.c.~, .. o .:.s. ..
. ., -. m~. . -:
. .a.,. ,
).) On Th ::da.. yi.w.tece=b>e.r .17.;9.1. 31, the WO.k heie.-:,,...wn.- a -.n. -':r . .n,$#
- n. 4i. re.n i. e.vetM. v
.Mb.
art % .
1 .e J. J a *T.e.em;n.n.h.1
-=
= =I m6 C*~**Cbm.a.r.s.e.4 m .- " N - (;
. =..,L.
g t- W .4 ghu h,
- - N= pen--- - A +J gn . ..g.s. .. n ee l iseeV 0=in w .is a. e wie . rf ;r.2.
the C*.*.t . in thD' 133 25"Cf the .W 4 X M . Mdi'A 1.'s6dNil'
- 3. ~fsb 'at Ileva.tih 535b10" in;the dryvell. .The E:f._ .
.- ; $8, given.ceptesdef: theJDc?s'which.ayerofa' the edttisqfef::the.MI.Q N.d$t.M,hg lkD es E3d alIO I Oh ;C tha Chlet hi n5 Ohidhi Se r. dd .toi the';,'5h utJ.
.p-[Q 8 % reduced :eet bn c,A lus in tha es: fore, this sc,itsris .dds'sidse *
.~
., . n'c '.fsa f r =~r?:y =".w.7.l{2 T y.- ' .. . s... . i .;, ? ,:'!a.
'.&ky',,.'.* .p,
- .:'.: $:%..".:.. ~. s 7,:;:
w .- -. . ,..: :. .? y..c. .. : ,. .q. y.:,::.%y, s
.mzg, e . . . , .
...'.,..c.s... .y ,w.....,. p n
~
d, 7 . ,
e.
y .:.o .
e . . . . .
q.a,g.
- y. * :
..a.- v. ..,. . -
..:.- ...s . ; ';".. y . wn 9. 4. .a ~-p
._ w, , calesistica..::... . , . .. ;y:s vera
. z, _ . . . . .
.... .. m. fe:..,=*4.C,,
rgse per h r:,ee..d r r.uenry fo. valls H- , )p;i loads onlyi The valls.initialli teere clusified
%a. h.a- a s se~'" i a' . ' 4 ' ta.
, e,.s .
af aty r.-- . *rtiafid
. j e. e~s Ite?itOM'y M. a. e'q~u.". eM. a ..W.x. ,
'.-e:c..t s . .' ~
6 s.. i use of the ~'wsils 'as a suppert h:fi t calenlations 9dre revised to acce
?? E as well as the pool hyi!!odynamic leads. ., - " 4.. W.~_m.U:N.m
- .e . -
M.
_........:, .:p ... 4. m Fd fa M In July 1991, The r20 lasued revind c:iterit Nr.edEsten effv;,. :
Ct;_
- 8. . :._. masonry wa. lls which a,giin
~
7 re ched a reriaics Me(o.J. L 65.1.
2 M:e c,u#.
.W. . a~w. @n$.g.5
. :: _.';..,s..-
rF g ,
, p.;h ...
.m m
T.h
.a .2:aticesv ...: .7:w. .
. .~ u.,p m . -
,w '
M)
- All ef the ebs= iga =U$i~.y va11s h'sve been .'ri6555ff'?i
'$n. hginearb; Branch Interin Criteria S: Saf ety:Relind9tas55:f j Tf.:
Mall Evalustien, Rivhisa 1, dated July 1981.~.All.caletik- N -
T
" tices a.=d substantiittt5:s of the ability of thit..i:ssenii' yallic. e to. support the pocWir6 dyna.ie leads as veill is"the otheM5 dyw4 and nt static'l ddi 5 Luz%-4.,6,,.o.3,4. - . is sv.bsta.ntiated ;isz..calculat'i.
. , :. : 7 r . :: t :.. w..... .
m y nt Sa..: % - - . ..a :.'.
I;;;o.3.a a -- . . . - ,,.".-
,.,s v - w .-..
. v.: . -
P. . 5.;7
. .v -:
M: . ,.;.:
DiQddit :itC2 Ci."'.'.',5fty1.pCf thtt4 PErts !"
- - e
.(b)
5'.5 & ?.Q;
. :;. ' - fU.%. ' ?.3,. h.2
~
M. t i M , . . ..M Status 'hE[rDiI.r.ahtabed which iSys' *Nd6cuiM 1)$3Tnts seainst GIcEthe C*t, 's are writtas. 'SafcW .
29!ksprovi5g a ec E h: E b a stru=tural element, thif. .@@
($
s! check the report to s'e'whether e a:Y '",
E's..t:setural
- e$TE
- ,Med OOre engbeer.f.,3Vc 6070s tot yet been. inc0rp3:&te_d c3 ~ ' Jk
.f J ,,U.IAWing Stf0000!al s1 M at.x- - .. . ' . .h
- q b* , ,- in 'thS ,,sa34. ..4.
.,n. .vi.r . Mg=t* = . = . . .
s.
? ;_ w -
- * . - .. (
' - _ _ . _ . . . . . _ 12.htm.mmm 5 .* . --
N 14 n { 6 -.= . r -S .m
-. b _._(.9,:y.g.
a f p espcase k 4.35. ta.tute u
..g .. A .
.:. : . u.s.n
- :...m n a. ..r.: .;. y
., x;&.:.9 u:. T.. ~.
-%n,6cu,atien nepert . : .. -
-:: iC.
q '. f..':. W[AM@*lx A, .1tez c.1.c '- . .
3.n. a.21 ; W'
- -w .-,A..
. .:* 4 ;., W .
- r e-
. g . s .- .
'. . s .... M ; :N.g;.'
- d. ..-
.. .,L* . L . .
1
~ . ; . -G ::.::y.. .~. 6 w>
- v. . .:.- -
Audit Raoort S/S;9N;q;;.;N}. T :. . h._' M;. j ; ',;;;p;:. a ~....m
- i 1. n ,..ps .s.
1.f ; .
j.y ,w@.*.
e -. e .. .. . . . . ~ .~ ;~.s . .. . . - #... :v.g ..$@ .
,r... ...,g,esponded 'tiriW. r,9f.' f.::<
(a) This ite. . m.u v .fm was taken cu......tof.....eentext P.. As .
SLC 4 .~ . . 5 . o f .75,.
4..g.~5 ur e c a nd '.e.vi 3nce.o 42 8;f.. .de.design. ..- the .review ci. .tedwas d rawing , . noti. ng i.sh_ ..ci.f.
m ea) ..ust're
- e. .
.c s . . v.. si was .in. house for tevie'w 'an. d cc:...,ent. The drawingce v.ed m.2.m.
waseJ: &e ,g retdrned accordance with: kith the QA cWent.:te procedures.. novide prop. .6: '
,C .signiturefikp~.1:M,9
. .m.;:.W+E..Me p. E . .%n 8n.:;.9.
^
- ~. -
. :, ? . . .:- :.
.. . . . . . :,- s.' 3 .~.e .- w-~
=r .c,-
Spec. H-2164', Addendu:s l' - vas' a bid spec. and no fabriY~li 4M (b) ,
cation'or final design was based en,.this ipect p
~
{.
. . .% v
- ~
... .j.c.. . , n'
,.% *' . ~ . . . .*;.:'. ;:$% '. . . Q.Mj]t
.. . : -:a A' (c)
AllM1culaticas hadbees'ieNeve. d ind iNiddeU:-li r l;das6s.with d M:ir M{. th tinspThs older cdiculationi have.ncit 66est*bWfftked." 'Nh
~
Wg:e
' to iiolit.x%. es fo@chenti.?'.; .,-H %.:m%.* .. :- .m. n.,JR i
g.-$...$.m:
y.R,Mg.
c .,..ff&~.-g&. ?NM
. ..., .::tmr*..e.l'
.M N.; i.: 5 _u.-
. t .w. r. .: 'e
. .M.
.s .- ..G PerithsGaudit repe: "T S . .:.~ :. .:V:a.M-T(pge-312T of t/S ;9/74 phbe :.rev.i,
~: (d) prg.ig
.-'~ vdMTealduletidns %ias confirhed. .The pridii1R:!6Vihr;by CH2g Mof a .lo~
. van tha @EElk: sfveWr's' gU .5W s response. . ,. :.. .
of ELCE4415'deduMented .
- ,3. . . . .d'.ht.
y ;> ; . ; .g. . . .. .h :. R. ;;.:
.- ; y. ~ ~%.:. v wy .. :Q..*'{P. ;' '2mN
.. ,._.-.a- . .
~
,x*::
. . . . -~ c . . a
- : a
.e -- . - :
c .v. .
Audit 78/07 p,m..e . . _. :..y. ?g... u. . , y - ;- m g,;r; n . r )w.
- 2. a .. .
. . / S . g ., .q ,
(a) Tha
~
ki 5 f uN h.
culshiQJpayre iipend e d ."inyc- 11, 5617. 10;2}-7 s fn..T6g.$Q.f %
requidsrctention of design ceaLcuat.t.on,; a. protectyir.st.ruc ..%
tiond.X REI;13.1,'10-10-78bsis-issued onithe ji6366 R h i. M, "I.
BecausSiefithe loadsg%Enas always chadiiniunderstd44 ? loa'd definthion' that .afi:545c1?dynElE
~
.fisihWilfidit.fedIoWM*M theder3Mwith!inaldesign'Loadsveuldbede!ofedji4i-i to fuieME.2'ha :asuita su= arlisd inAff-1* ,TPWf fs c ; -/-ly$ M
.thisTW W dee
$ W~N ~ qcifiE@fhr;ptabis' apprucFEd.:iiET=c.l .d haMi e- rc ?
'..'.6%
w2u. :e the.. .m loadini'En5&M . . . . rmp .tha 'tisein .QM.WE. '-m. e v.n.:a rd
. . .. by e.ir 2 " .m..-;;.+:ed
.~.u 6 DDc 973 was verbalir acce,pl:.
DtD thd shbse6.sest10
/So'I(b)[.~.. 'apprp aot g @e 4 :Lf'e'ttD sisnaturit off3 hit BDC.
The p cject prB64 dire PI-tI-2.1, ReK6, di'd ' ' .$6 W,j mN .- y..
?;. .
v.
.% m:
40 n
.&;.Q
. .w-
- .n.w.r%.;.,3.$.-
e 9.2. .~.5m'.
- n. ._.. . :2 .;s 3, . M. .qw%. . '. .'. ' . . . a. .
WS%
~ '
a.:,. e' .@..y M .S:Q 9 .- ..- cc,.w,
. +y.7
. . .r q. .
.htp~ ?g. - . .e..
- A.
'h.w) m r.ye~z ., .l.1a Niedof.QLa6a was ocCandToffihsti11s used .for e
% v.tf5ne P.SM
-WMIS.u.
'mg bseicent tests were codd.iic%...,$ '...'ve~ riff. ~tEs.i. dita.W&.. .ibb:sfp(1 -
ided.by venders.for.de s1
. .ym:n +,g.1
. n.p P w. 4.y v a.n.
i,. -
- g. n9 27N<. . :- .: ~9 <:.c c..p . . . .m. . .. :.s W.h,- .. .
1 T4me pgthe inspection pr. ocen A sh, ...expa. M.; .'anc~
" .nsion. .hd;rs,othe!'-=. . : mVe ;
lEi$rw.m o . in the installed M. . -s _,..cheMad .a . .
ior~i'. torque' @~N .v a rw ,. ... .a a
,(
ge
,r'
. m.pf.;;.r..m- &9 T..,.r. ,,J
. . " i$r'5. a;;,
we *
- - 7 a.
. .. *c . >- &
..'w.. V ...c c.S.j a, .e. C. ** -
s.
- Ny'
- y M,b, p k_g . .: .
- q. . "
. s .
p nk. vg - . .~
.,e 9 m.pem %. ...
. . . . , . . W. W H. -- 4 " '
. s. . ; ,, . . , , . . .. ..; g- .
hb 'h ' hh h .- - $ k" . .?.i
.c-M,.
3--. SAh,, TNT k .WNDY- 7.
ev v%. .-
.- 3
, . up. 2y. cw,, - .-
. c. ' ; ...
e.m ggg3ggga3 ,. .
W *, &.<
, y -
.7.3'.....,..-
<.. g
.4 -; '
. - - .c . .* gausac.e .
- r:. };if.c * .. L'iG
'..g[.L.QAr&.~ : w .: .
.,e y. ,. .. . vc ., . ; -s;;,r.
&*q%* % ; P, -'
,,:..*g..g&...'g j* .y;. tl . :, .
- ^<.
-w =.-i ? .- . e n ,.
,g p}.
p=~ M:.~
.f.e . # ha--
- =***
.** e-.
t
- ~ -. -
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f ,\
-t
- e. ., . . s . ,-**. ,;< .
. W,. r, - .p
~
.4,* -
~ -
+
c.."s' 5"aa
.-r --
-w.n .u. .m,,--.:2)~.t:4- 'w ,. n. e ec a bw, . o'.t.,.. s a.1c..se u n . . ..,s... e .t. s s..
r.... s. vn e- Sa . . ,
.W".n.%w.w.c;. Lundy D"..v.' ..~, 5- 3 5 0 ( c t'..ao ."d) . ". .$. 8 3 p cw'- N.ev.a~.i es..4 . . . . . .
s.p w$ 4X W ths !clieving state =ent to appear en a 00c pri=r to i .dQ, :
J
. ..::6.. P
.S. N a.M D'J..E d. rilling cf core bered heles:
._p. K . .. Jt'. . -
.:.....- . wa,... e s..-
..= , . . . . . -
... ..._ . 2.w. t
.u.n.-
e:n.-- . . .
.. r .. .
m .
. . . . .., .. - .. see. e cc S >ss a e . - .y . a s. ,,. 15 5 .. t 4
s.e.T.. _s a. ~ a 1.:
. .. ...,.,w-.,
.'.'.;~w,aq,.m.
.W M':q]3 k X9 p .,. . u. Late . ,.,{(:Lty .4. ,not . -atte:1.sd . = ; .', ~
. ; m . ..: - p -Wik
.x F-.
...a
. . . ' I.r- :.. , .M..'.*W-.: - 3.
. . .. r..G.r
- a l L.UMg.ny@6%ij4
- 29. .
Denta in cc:::pliance vjth. ,s.:.g. PMI-2.1.:. f r;c . QLY -:...Q3
. .... ...a. . . - -u..
.,e.
- ...
- : ,..;.. .ys.. .,. . 4,. m::p>
. g. + ._ ... . . , .
. .:g-;. .7 .-
..v y.
- g-( w). --
. . l. '. : . - 9,. e .@. n. n..t .
- .;.n '4em. =d .e thep6el hydredv. : = #en. c...the loads e. riginal' wer..ede. . n=t si n21.iadsWrior.;3..v'M..A finaliz.ed.. aC .T.,i.s,'tiz..
- N. design n s based
&. ~G.M. l loads. 71611 hydfodynimi': Icids Vere :iEFde751.biud's7.th
~
~
- --J " LE;1DD.tpJ.
& Dece=ber 1979,; en'd ):6:ste3 t5 ths mW142'%79..?.Q5
-: 2 '.
.. ' .,r. 73..NM.e...s.e=tatien.
.e . . ~. ~ t,;.. .< . ?.. .,,. ; ni, e-D. :..::.. :.c.:.- .N.:.'.
- ,...... . . 2..;..4,. . ..-w. .,9. .l. e.<
- ., : ....m... .. : .: -=..-,.: -
difiestie. n.m:v. s kn. e :. l.-s m.n m. .
.A .n..n._
. ~
. .r. s ..:: W pf .1 1 app,.,t.be stru=tural een rev.:. eve'd ~...B.: c
?e. m.MGM ~
-steci
- wgn ro nd for the
- m. .-. .a ,.'.inal . - r.
. m .
ecol hydrodyn W e'1bsdf. 7.f Q:neQM e .~.u. . .n. . . ze. .
. , a. s . a, . ang . .., w. 2,.o,.m .,.. .- .s
-J i" ..' W E W icr.Y.pt,.a a1eaainj .u .a fc . ecas tit:tioni. .Y-@;. -v. .@d.-jinMME6M
' .:w.m.
- . .? ...; :u;- u.
W.- .m.:.ygw: .v. ..wn.y.
v,_. &..o.
w ,.
. ; m. a . y :,% v. m-.. .. , . .... a m, - . ::
.s..
.n.s.u-5
,s - ~ .
- m. .w ~ . . . - ... . ,
. >.: c... .w .
- ?.H
-(d)l. g he; .
fc =an..
ee dcalt! vith n. ..y ot. :,:, perfe.. r= -c:.in_.-p.m~ gftg .-.
.a - :. ..,s=
. mc: .y .
.=w; 9A dss.1_ #G. ., gisalet.nencon.. . ..pla. tns ii 'tha. ,i. f..i.s. hit'i..i. e .5
..j. . . . ::
m c.,a ~g<sp~kleciatich.sf c .a .t n. . . ..e...a er. bed:ent s.
1 . a.s. on.s m. w.a1-s e..e . .s. . =. s. .u. ~
.... m . . .~.
e c= bed =ents. ~~ The 'nencenfer:ance vis .-s. el~essdib
~ '
' .. 54f5Pto4b.ov.s
!.$d1InfMicatien thiit the plates eduld acec=:;aodata th516adsJ.'.M@
d ejd@n:~n u
m ,y .WM'. c: .. embed =4nt plates have been checked ... .. .
- .,..c.,.. der ths..:.fi.dal .
. . .sle .
s..x 54 gj:g, .. "
. 5 ..~ A'y.4 e c g .AudiGEmm: 80/04 ^
'. . N...
. wzm.+tm :.t .'.
=.w[3*K9sYli6cti'en,and
" (i E ' Weld eties were inadvartently ==itted and.JO!
~..L .D.. i.'.9n.s.5., !:s. ;1. .n cted.10-27-80. There was no affeet on the hard :f ?,?.
.gw:rspt:1& Lgs audit responsa vai provided g.s EU:-17 3 8 0, : 1-9-81. t. .c.
.t?.6.&e .
=y M W,p w
m.q;.
- n. W.
r ,was judced not to be critical and was not originally ".
J W..ipit'il (bf M ots6, P.ased en CG&E's finding, the tersion deflection
$ /, M iss V C o the cale en 10-27-B0. No chssges to the desig=. ~
U = ~,.J a s 2.-w
.:\ ,.%. ge.,~., 9G'.ailtu.v.:.:from
'M a.
- c. .s this :eviaion. .
A. ~~fyp. .4 :.sg.
. t... .
.N is This item was net a finding. :
&M,(cWTh.n.w!GC.ce==ent yMhfCGE3.'1 audit 80/04,butapersensiec= ment. The judgement is unjustified.
.E Q @ M t Eiles vore not perfor=ed in reasonable ceder are sub-gf$
- .; pcu s M mqe_;;w.,
@C ,,,JL,,.c,,..g A tie.-.e. n.e' tive_.:'and bissch .baacd en
- . .wthe individ;al auditing'.t
.. 7.
. .-.>U -.. 3 ...<....s. M .,' ..
. ,;., -. e ,.W.;
.u. ....< <.2 , .4.s. ;,: ... f e.4S. w,..;
.c. - ._5..>..........y . ' . .h - @. . . . . - , ,. g.M.
'M.m,..
t.-
e o @ M .W .. ".- u. .<
- c. .5. . ; .
...c. . .c . ' ,: '.O
. 5. . ' ...:.-?~
. . . .:- "-.M , . - . ./ _. .: .. C&,. .-<&
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-+ m.-, q@.,m,
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i
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