ML20125B990
| ML20125B990 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/01/1982 |
| From: | Rich Smith NRC |
| To: | Parrish R NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20125A606 | List: |
| References | |
| FOIA-84-415 NUDOCS 8506110629 | |
| Download: ML20125B990 (182) | |
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- l. Allegation On December 9, 1980, J. Harrison, NRC Resident inspector, ITarble Hill, Nuclear Power Station, was contacted by an alleger who iden-tified himself as a former Quality Control (QC) inspector at Zimmer.
The alleger stated that Phillip Gittings, Quality Assurance (QA)
Hanager, Kaiser had been voiding nonconformance reports (NR) based on his personal reinspection oig%fnonconforming items that were pre-viously identified by field inspectors.
Additional Information Concerning Allegation Between January 13, 1981, and July 4, 1981, thirty-one current and former Kaiser QC inspectors.and Quality Assurance Engineers (QAE) were interviewed regarding the Kaiser nonconformance reporting system. 5:xteen of these individuals alleged widespread irregu-larities in the .m .=fermance r-epor-tir.g system. They'specifically alleged:
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- a. According to Kaiser procedures, the QA Hanager,-Phillip Gittings, has the authority to void a NR if the inspector wrote the report in error. Inspectors alleged that Gittings was arbitrarily
.. voiding NRs which were not written in error by the inspector.
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DRAFT That Gittings was diverting NRs and not entering them into the Kaiser nonconformance reporting system. -
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- c. Contrary to Kaiser procedures NRs were being voided and transfered
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to surveillance reports (SR) a lesser threshhold reporting system
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for indentification of nonconforming items.
- d. That NRs were bting improperly dispositioned by the QA Manager and members of the Kaiser, Material Review Board (MRB) who frequently dispositioned reports as " accept as is" when " repair"
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or " rework" was appropriate. Inspectors' alleged the MRB approved dispositions which were contrary to Kaiser specifications and industry codes and standards.
- e. . Inspectors alleged det NRs were voided with' the justification
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being "to be* inspected after redesign" or "muhip h deficiencies would be rewritten on separate NRs." The inspectors alleged reports were voided; however, the nonconforming conditions were i
not reinspected after redesign, nor were they written on separate NRs as stated when the NR was voided.
, (g. ' Inspectors alleged NRs were voided by the QA Manager at the
%. request of the construction. department to avoid rework and schedule delays.
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' a.. % ~l DRATT/db 0 -h. Inspectors alleged during revisions of,I NR, nonconforming items were arbitrarily removed by the QA Manager. Inspect ~ ors cited an example where the QA Manager directed that any wel8 that had .
been previously inspected by another inspector, or was a vendor supplied item which had been inspected by the vendor's QC inspectors, would not be entered on an NR;although the conditions (pipe support hanger welds) were nonconforming.
II. Findijn s During this investigationx a review of the Kaiser Nonconformance Reporting System was conducted. It was found there were wide-spread irregularities in the system. -Kaiser procedures permit voiding of a NR if the NR was " written in error, duplicated, or-the nonconforming conditions has been corrected . . . . by construction." It was found that between January 1,1978 and March 31, 1981, 1,031 NRs were voided. Some were voided by the Quality Assurance (QA) Manager
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DR by the QA Engineer, Records,$ in some instances NRs vere voided by a clerk.
A cronological breakdown of the number of voided NRs per month is appended to this report as EXHIBIT (!). The disposition of a selected group of 20 voided NRs was audited and it was found in 15 of 20 caser, the NRs were voided inproperly by either the QA manager ,
..o'r another individual. All of the allegations made by the QC inspectors
,yere substantiated with the exception of the allegation that the QA manager,had voided NRs at the request of construction this matter is
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still under investigation. In five cases the justification used for u u.-
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voiding the NR by O.: Q?. rm; : was erroneous, it was found the QA manager was arbitrarily voiding NRs which were not written in error.
. -by h pectorts. InsomecasestheNRhadbeenreviewe$bya Construction Engineer and " rework" was ordered yet the NR was later
" voided." It was also found that some of this activity occured after a NRC inspection on December 2-3, 1980, in which the licensee and the Kaiser QA manager were told that this activity was contrary p .,*
toNRCrequirementsandginnoncompliancewith10CFR50,AppendixB Criterion V. It was also established that following the December 2-3, 1980, NRC inspection the QA manager on three occasions diverted NRs na cwt . wt ;
(CN 4309, GN-4954-!i9 f45-30 2
- 31) and did not enter them into the Kaiser Konconformance Reporting System.
This investigation also disclosed that NRs were improperly disposit.ioned -
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as " accept as is" when " rework" was appropriate; in one case (NR E-2836) the " accept as is" disposition of a nonconforming condition
( was contrary to ASME code requirements.
l The allegation that NRs which identified multiple nonconforming l
conditions were voided improperly with a comment that the NR was e
being " Revised" or that "each deficiency would be issued on a seperate l
NR" cr items would be " reinspected" was substantiated. It was determined l
" ..that nonconforming iter.s were not reissued on seperate NRs, and were pot reinspected as stated on the NR at the time of voiding. Also, r . it was found that during " revision" nonconforming items were removed from NRs without justification.
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The allegat4uu tun Lue Kaiser QA manager voided KRs at the request l of the construction department is under investigation b~y the NRds, Office of Inspector Auditor. **
- . J This investigation established that ow +++es nonconforming conditions which had been identified by Quality Control Inspectors were identified yet not controlled due to the. manipulation of the Kaiser $ nconformance Reporting System by Xaiser QA management. It was also established that the licensee failed to take effective corrective action following the December 1980 NRC inspection.
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ITEM OF NONCOMPLIANCE D R A M.y. .
10 CFR 50, Appendix B, Criterion XV, states that, " Measures shall be
' established to control materials', parts, or componets which do not conform to requirements in order to prevent their icidvertent use or installation.
These measures shall include, as appropriate, procedures for identification, y g;-
. documentation, Nerg(. :, v disposition, and modification to affected ation, organizations,".
The Cincinnati Gas and Electric Company, Final Safety Analysis Report, Section 17.2.15, Revision 15, dated August 1976, states that, "The QA program establishes measures to control materials, parts, components, services, or activities which do .not conform to requirements of appropriate -
documents. Written administrative and quality assurance procedures shall control the identification, documentation, segregation, review, disposition, and notification to affected organizations. The measures ensure that CG&E's Suppliers / Contractors are responsible for establishing procedures for controlling nonconforming items at their respected facilities to include shipment of deficient items to ZPS-1. Nonconformance reports dispositioned "except as is," repair, or rework, are made part of the r,,x.... ,
inspection records and folded with the hardware to the utility. Items retelved, inspected, and elcepted at the site are *
'to similar nonconformance controls and approriate control' hisposition3 ",
M Cincinnati Gas'and Electric Company, Quality Assurance Division, "W.H.
Zimmer Nuclear Power Station Quality Assurance Manual" dated October 31, 1980, Section 15, states that, "HJK is repsonible for identifying and 7- P .w" h.,3 M. [~iH!t t ..
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. repva 64ng s.vutunformances amL receiving inspection, construction, or testing activities which are delegated to HR ,"; and "HJK inspectors or Quality Assurance Yngineers prepare a Nonconformance Report whepever 'a co'nditon. 4.
auentified which represents a deviation from drawings, p.v.r's: n.v .ry. w$
sprecifications, procedures, or work construction. HE Construction Engineering provides the disposition for the nor.conformance, and the KR is processed in accordance with QA Procedure 15-QAS-01g".
Contrary to the above, nonconformance reports were initiated by an inspector and not entered into the HK nonconformance reporting system, nonconformance reports were erroneously voided tyfor at the direction of,the HJK QA manager,qigd ponconforming conditions identified on nonconformance reports were improperly dispositioned as " h as is" when " rework" was required.
nr;o!o.:t:ir:r.EQ The arri~ri:;NITok actions were not in accordance with HJK procedural require-li ments, and ar a repeat of similar noncompliances identified in Region III Reports No. 50-358/80-05 and No. 50-358/80-25.
This is a Severity Level II violation (Supplement II).
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The Kaiser Nonconfernan:e Re:ortin; Syster was established te provide control of ncnconforain; material. Kaiser Guality Assurance-Construction Methods Instru: tion (GACMI) G-4, Rev. 9 which was in effect at the initiation of this investigatien states: The GA Department cr Field Engineering may initiate AN a Et when netters identify nen:coferning sa:erial, e ui;eent, constru: tion work, er deviatien f ree a s:e:ified re:vire:ent.
ine Ins;e:ter cr OAE initiates the NE notifyin; the Site *::u-een: Cente:L (S.O.C.) NE Centretter wh: te;s in the Ni and Ti. '
assi;nsaKE!JCCentrolN.mber(CNgandthenta;sthenn-conferring iten er cendition. The NR is revie.ed by the
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. -Ins:ector's su=erviser er ce;.izan: GAE an: is -f er. arced te the 5'C n=. Centrcller who issues an NR Cc .tret ha :gr and enters it inte the Kaiser N:n:: .ferran:e Fe::rtir; Syster.
NRs whien re :rt nencenferrin; cenditic-s en cateriat< at _ite
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receivin; inspection will be dis:esitioned "ref e:t" aa.d the Ni f ers will be staeced "Insce:tien Reacrt". Ntr written en Essential Systens/ Cec cnents will be given an "E" prefia and Nenessentiat Systens witt be given a "N" prefix nunter. The
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-: , , crocedure states in instan:es wherej R has been initiated in erect, dae to interpretatico or- judgement cf torderline, cce-
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citions, c.:Olicaticns, er where a non:enferra .:e cendit'en has been corrected,' the Ccnstru:tien Ce:ar:ntn: after a verbal -
written c0anunication f ran the G1 te arteent can te voiced by the $ite GA Manager. The prc edare states in these cases
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DRAFT the NR will be stamped " Void" with a brief statem.ent indicating justification for the voiding. A copy of the voided NR wiLL be retained in the SDC and a copy returned to the initiator, for-his'
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-4nf o rmat ion'.
QACMI G-4, Rev. 9 states (bd NRs may be dispositioned b Con-struction Engineer or as designee as tifhei accept-as-is, re-
,w gr_k, repair, or re_jm. The Construction Engineer reviews and approves att dispositions;and accept-As_is and repair dis-positions GiE E require review by the Material Review Board which consists of the KEI Construction Engineer, CGSE QA En-gineer, Kaiser QA Engineer, CGEE sponsoring engineer, and the Sargent and Lundy Design Engineer (for essential material or th II easipment only). Iry, case of an ASME Section 5 Nuclear Code nonconformance..the Authorized Nuclear Insure- nspector must be t
included on all accept g is and.repa_ir dispositiod. NRs which are diraesitioned as accept-as _is will be closed af ter MRB review.
NRs disposition is _tey_or,k,, or repair wiLL be closed af ter the Inspector or QAE signs the NR verifying that the repair or rework was completed. Records of all open and closed NRs are retained by the SDC NR Controller.
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! A.i, Background Interviews -
( Interview of CG&E Qaulity Assurance Manager On January 16, February 14, and March 22, 1981, William Schwiers, CGE Site QA Manager was interviewed and stated on December 3, 1981, NRC inspector, Isa Yin, audited the Kaiser k'nonconformance Reporting System and found the Kaiser Quality Assurance manager, Phillip Gittings, was improperly voiding NRs. Schwiers stated
, Yin requested that CGE audit the nonconformance reporting i
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system to insure the voiding was proper and in accordance with
' Kaiser Procedure QACMI/G-4. Between December 15-19, 1980, and on January 5,1981, Lon Ludwig, Consultant Nuclear Energy
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s 9., , I Services, In! audited the Kaiser X$nconformance Ieporting B'ystem. Schwiers stated in an exit meeting on January 6, 1980, Eugene Knox, Kaiser Corporate QA Manager and Phillip <tings, were informed th:t lue:i;; Sund that Kaiser was improperly voidingNRs,$1ddirectedKaisertoauditallthepreviously voided NRs and present the results of this audit to CG&E by February 16, 1981. Schwiers stated be also directed Gittings to cease improperly voiding NRs. Schwiers provided a copy of a memo to Gittings dated January 14, 1981, which requests Kaiser respond to Field Audit Report No. 340 concerning the voiding NRs. A copy of the correspondence and Field Audit Report 340 is appended to this report as EXHIBIT (2).
(InvectigatorsNote: }heKaiserQualityAssuranceManager, Phillip Gittings contin,ued to voi NRs, and also diverted NRs fromtheKaiser'jnconfortIingSystemfollowingtheJanuary5, h
1981, meeting with Schwiers. Examples are NRs No. (CN 5412),
G%- . ,.. n t No. p(j ),
- i and No. ( ).
Interview of NES Consultant On January 14, 1981, Lon Ludwig, Manager, Quality Engineering,
". Nuclear Energy Services, Inc. was interviewed and stated in
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December and January, k980 he audited the Kaiser honconformance Neporting System after the NRC had identified that NRs were being improperly voided. Ludwig stated his audit showed there DRAFT
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were about 500 voidei NRs aid between 1/3 to 1/2 were voided but were superceded and written on other NRs. He sai_d some his which identified A numerous nonconforming conditions v6re, not sepa rated"g*'eissued r on individual NRs. He stated, about 1/3 of
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the NRs were voided as " written in error." .Y[thnoadequate explaination @ to justify this comment. . Ludwig stated he recommended Kaiser audit all the voided NRs to provide a better explaination as to why each was voided.
IS Ludwig stated genetaily t4r+t there see an excess of 500 voided NRs which cover all areas of plant operation and construction, dating from 1974 to the present date.
Interview of Kaiser Quality Assurance Manager On January 13, 1981, Phillip Gittings, Kaiser, Quality Assurance Manager, was interviewed and stated in October 1980 he voided seven NRs that were written by QC in:pectors who were in training.
I He said he reinspected the welds identified in the seven NRs 1
and in his opinion the welds meet American Welding Society Code Tp .~.p (ANS) so h3 voided tue.f NRs. He stated during an NRC inspection in December 1980 NRC Inspector, Isa Yin took exception to this C
practice and found the licensee in noncompliance with NRC
~ ~
requirements for the voiding of these NRs. He said following
.~
this inspection the welds identified on the seven his were
~ '
reinspected by Gladstone Laboratories, Inc. who found that 31t n ., s ,. e- y 7 -
M i
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. s{ 1
~ ' * * * * * * - - . .
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2-_._.___._ . _ _ _ _ . . _ . _ _ .c _. ~ u n z:12- ~~E ~:;- ---__ Z . :E E-205FT DRATT/db DR AFT four of the seven NRs were voade8 pYoperly and the7 questioned
/.wi welds conformed to a AXS code. He said the three other NRs had minor weH decrepancies which Gladstone said were violations'of A$Scode.
Gittings g;;;rdly stated 500 NRs had been voided by Kaiser at the Zissner project. Frequently these NRs were voided and then
=t revised and put on another NR, or were voideo after it is found 1dset they duplicatef a previously reported nonconforming condition.
He stated the only NRs he hos veided for being, " written in error" were the sevenneLe in October and November 1950 that inspector Yin examined during his December 2-3, 1980, inspection.
Gittings stated during the past six month's' Kaiser Ihw-fred pr414em: n 2 ::: d-i+s QC inspectors over inspecting. He stated that contract inspectors hired from Butler Services, Inc. frequently objected to Kaiser management's S -i f: r-ebeet s4.+ implementation of the QA progra=, and were critical of Kaiser inspection procedures and techniques. He stated to rectify this situation Kaiser terminated all contract inspectors, and offered some of them jobs in the Kaiser QA organization at
,,s re w' Zimmer. Gittings related that many of thejinspectors some who were retained, and some who were not, were critical of the
" Nonconformance Reporting System, and of weld inspection criteria for pipe support hangers and structural steel. He said;IW ,
there were differences of opinion In various code interpretations, .
which is common in any weld inspection program.
DQ t.A vu A PT 1
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- s-
-aw- . w eeurew .w-_.. .. .--
305FF DRAFT /db
. Interview of Kathy Faybion s ,
On February 13, 1981, Kathy Faubion, NR Controller, Kajser das interviewed and stated Kaiser procedures permit an inspectorTc call for a NR Control Number, she then issues the individual a j),e TI: i-inspector the control number (CN.L, Gdfmakes an entry in the Kaiser Log of Nonconforming Material f Tescribingthenoncon-forming itemy and the initials of the inspector calling for the numberdhe stated she has never whited out an entry for a control number in the Log. She also stated, the QA manager stamps all voided NRs with the red " void" stamp, she then gets the copy of the NR, and makes a red ink entry through the control number entry for the JR in the Log which identifies it
! as a voided NR. She stated frequently inspectors call for control. numbers and after a few weeks she does not receive the NR. She said in these cases she makes the saca void entry in the NR Log. She also stated prior to December 1980 Floyd Oltz, QAEj Records, Kaiser also had the authority to void his; however, the CGSE QA manager, William Schwiers-directed that this authority be solely vested in the Kaiser QA manager and since that date Oltz has not voided any NRs.
C.
J.1L Investigation of Disposition of Nonconformance Report Control No. 5412 vgAR 9
. _ . _ . _ _ _ . . e . _ _ _ _ _ . - .. _.. ., l 205FF DRAFT /db A A. Backr gd Information l
On December 29, 1980, Chris Dumford, QC Inspector, Kaiser, '
initiated Surveillance Report No. (SR) 2886, after suppression
~
pool liner plates were tensioned before a QC inspector arrived to verify the initial tensioning. Thecorrectiveactionresol[ing this condition was for an inspector to be present during the seven day, and thrity day tension checks to verify that the plate was being tensioned properly. On February II, 1981, Wayne D. Kitchen, QC Inspector, Kaiser, wrote NR No P3022
~
stating on February 4, 1981, during a tensioning inspection he observed that the anchor bolt on Suppression Pool Liner Plate d
No. 23E was installed at a slight angle and did not permit the full bearing surface of the nut to contact the flat washerl -
This deficiency was'found on the same liner. plate that had been tensioned without QA coverage as reported in SR No. 2886. On February 3,1981, Dumfori initiated a NR which was assigned Control No. (CN) 5412 which also reports that suppression pool liner plates were being tensioned without QA coverage. The NR states " hold tag was applied while a wall plate 10b was'in process of being tensioned." Once b'ald tag was applied tensioning was continued until tensioning was completed."
)B. personnel Interviews g
b 'h sd L 10 -
~- e
- e.mame on. ~
. . _ ~ . _.._ ...- _ _ _. .
305FT DPJJT/db Interview of Walter C. Du= ford ,
On February ll,1981, Walter C. Dumford, Quality Contsol In'spector, KEI, was interviewed and stated on February 3,1981, he was
~
inspecting suppression pool wall plates and noticed on a bolt on a plate g was bent at an angle not perpendillar to the plate. He said personnel were preparing to tension the plate in question when he told them he was going to place hold tag on it;and they responded, "try and stop me." Du= ford said be left the area to discuss the catter with Dennis Donovin, his supervisor
~
who told him to initiate a NR for the nonconforcing plate and toplaceaholdtago{T which would preclude tensioning of the plate. Dumford stated be returned to the suppression pool, placed a hold tag on the plate jand construction ceased tensioning the plate. Du= ford sai,d bowever, as he left the area he heard the tensioning machine reactivate the crew ignored his hold tag.
1 Du= ford stated he told Donovin and be told him to write a NR for the continuation of tensioning after a hold tag had been applied. Dumford called the NR Controller, was issued a NR CN 5412 and wrote a NR for the violation of the hold tag. He said A
,. a few days later he was called in-to Mr. Phillip Gittings,
, office and was told the NR should not have been written because it was a " software problem and not a hardware problem." He said Gittings then told him "I'm going to void this NR because
. ,, . DRAF~
. _ _ _ _ _ . _ . .- .. .. - - . . . ~ -
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.g j i we do not need this kind of paperwork floating around because this is the kind of stuff that causes investigations." Dumford stated Rex Baker, Inspection Supervisor and Dennis Dodovin who were also present at the meeting disagreed with Gittings and said it was a valid NR.
Dumford related a few days later Dennis Donovin called the NR clerk and was told CN 5412 had been reassigned to another NR and had never been entered into the NR system. Dumford provided Tc a copy of the NR CN 5412 which is attached yp ,j;d n'apty. as
.~h.1 l *I. I' ~
EXHIBIT (2).
Dumford said th n incident is an example of Kaiser, QA management not supporting the QA program on site, and being overly iufluenced -;
by construction. Dumford said in his opinion QA Managers were influenced by construction, and QA was not independent at Zirr ne r.
On February 11, 1981, Dumford provided a written statement attesting to the aforementioned information, a copy of which is attached as EXHIBIT (4).
".. Interview of Dennis Donovan On,Tebruary 13, 1981, Dennis Donovan, QC Inspector, Kaiser was interviewed and stated on February 3, 1981, Chris Dumford
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20$TT ^ DPNT/db contacted him regarding a SR written against tensioning of bolts on suppression pool liner plates without QA coverage.
Donovan said he called Ken Shinkle, the Quality Assurace Engineer (QAE) responsible for the suppression pool area who
~
told him to write a NR on this. Donovan stated he wrote a NR and instructed Dunford to go down and place a hold tag on the plate. Donovan stated Dumford returned to the trailer and told !
him that he had placed a hold tag on the plate, yet craft L personnel had ignored the tag, and continued tensioning the
- plate. Donovan stated be then told Dumford to writt another NR for the continuation of work after a hold tag had been applied.
i Donovan stated Dumford wrote the NR, he initialed it, and L
called the NR clerk who assigned it NR CN 5412. The NR ae4--or l
was forwarded directly ,to Rex Baker, Inspectica Supervisor for J
review.
Donovan stated on February 4,1981, he, Rex isker, and Dumford were called into Phillip Gittings office and at that time Baker i j i had the orgical copy of the NR which he gave to Gittings. He i
said Gittings said "This report is going to be voided because l
' t
, this is the kind of thing that starts investigations." Donovan !
% said that Gittings commented that inspectors would not write.
NRs against scitware problems, but or.ly against hardware problems, and that ignoring a hold tag was a procedural (sof tware) violation.
9 UKAH 13 -
x.. - . ~ . - - - - . , z .. - .- -_ ~ ~ . . - - . . .- . . - . -
305FT DRAFT /db Donovan said he and Dumford explained that construction had ignored the a hold tag, and Gittings replied "If I was in their position I would have done the same thing." Donovan responded and said a hold tag is the strongest QA control mechanism on site and if one is ignored a NR should be written. Donovan said be and Baker told Gittings they disagreed, and the meeting ended.
A few days later Donovan said he called the NR controller G n' concerning the disposition of conttol-No. 5412 and found that the number had been reissued to another NR.
Donovan stated in his opinion this is an example of Kaiser, QA Management not supporting the inspection program at Zimmer. -
On February 13, 1981, Dennis Donovan provided a written statement attestingtotheafore[mentionedinformationacopyofwhichis attached as D3IBIT (3).
Interview of Kenneth Shinkle On February 18, 1981, Kenneth Shinkle, Quality Assurance Engineer, A
Kaiser, was interviewed and stated on February 2, 1981, he received
~
- a phone call from Dennis Donovan regarding a bent bolt on a sup-
, pression pool liner plate. Shinkle stated he told Donovan this
~
s'hould be documented on a NR and a hold tag should be placed on I
s[ I -
14 -
l . . - . . . _ . . - . . - . -
..,..: . .~ - - - . - . --- --- .
205FT DRATT/db the plate in questionet, to prevent tensioning. Shinkle stated he later learned a NR was written jand Chris Dumford..had affixed a hold tag to the plate whichj was ignored by construcinion, who tensioned the plate. Shinkle said he also learned a second NR waswrittenbyDumfordforv$ilationoftheholdtag,whichhe later initialed and forwared to Rex Baker, Inspection Supervisor.
Shinkle stated be later learned Phillip Gittings, after discussions with Dumford, Donovan, and Baker did not enter the NR into the system. Shinkle said in this case the report had been assigned a control number, and the inspectors N e N 'skor d concurred it was a valid NRj yet,by Gittings told him this particular report was not going to be processed, and stated, "The whole thing has been blown out of proportion."
Shinkle stated in his opinion Kaiser management does not support the QC program at Zimmer, construction dominates activity at the site, and QA is not independent of construction influence. On February 18, 1981, Kenneth Shinkle provided a written statement attesting to the aforementioned information a copy of which is attached as EXHIBIT (6).
A(, Interview of Rex Baker On March 3,1981, Rex Baker, Inspection Supervisor, Kaiser, was interviewed and stated in early February 1981 he attended a meeting l
gi
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205FF DRAFT /db s it /-t in Mr. Gittings office with Dennis Donovan and Chris Dumford.
He stated during this meeting Dumford said construction had continued to tension a suppression pool liner plate aftpr, he' had placed a hold tag on it. Baker stated he agreed'Dumford
~
vas correct in writing an NR for this violation. He said Gittings disagreed and stated in his opinion construction was right to continue tensioning the plate af ter a hold tag had is Baker stated ge.did not know the disposition been affixed to it.
of the NR, but the last time saw the it, Gitting's had it.
"c. Record Reviews 9
On February 11, 1981, the Kaiser Log of Nonconforming Material reports was reviewed; the log reflects fontrol No. 5412,NR -
No. 2996; Revision I was written on February 2, 1981, for welds having the lack of penetration. This entry does not reflect that Control No. 5412 had been assigned to inspector Dumford on February 3, 1981, fet violation of a hold tag. The corporate name or process entry columns in the log and the specification entry showed evidence that white out ink was used to cover .
writing that had been made previously in the log. A copy of the log page and actual NR issued is appended to this report as
",. EXHIBITS (7), (7).
~
fico.f.
J D. Fuel Observations None.
R FT 16 -
. - . . .n, .s,
. . - - , . . . . - . . . u_ - :- .- - --. - . . - - . ~ . . . ..
205FF DRAFT /db eE. Acceptance Criteria Kaiser Procedure QAUMI G-4 Revision dated Jaunuary 14 , 1.981'.
. Investigation of Disposition of Nonconformance Report E-5108 d Background Information On May 19, 1980, NR No. E-5108 was issued identifying a noncon-forming four inch long pipe piece installed for DDC M-1108 in a Residual Heat Removal System (RHR) for which no material trace-ability could be found. The NR also reports that a weld located near this pipe piece was inside of a penetration in violation of licensee specifications. The NR was stamped void on June 20, 1980, by Floyd Oltz, QA, Engineer, who stated it was voided because " acceptable documentation found'which' established material traceability for the pipe piece'. A. copy on NR E-5108 is appended to this report as EXHIBIT (T).
t B. Personnel Interviews T
Interview of NRC Inspector i
On June 11, 1981, Jerry Shapker, Inspector, Nuclear Regulatory Commission was interviewed and stated he walked down the RHR
~
stem in the area addressed in NR No.f 5108, and specifically r .,. . .. %
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l 37
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examined the four foot section of pipe between welds 82 and 82a identified on the NR and on isometric drawing PSK-RH-15. Shapker stated he saw no heat or identification number on the* pipe piece in question. He also stated be reviewed the XE-1 weld data sheets for welds RH-82 and RH-82a which joined the pipe piece to the RHR system. Both forms had a notations identifying the beat number for the pipe piece as Heat No. 232661 which was initialed and dated "RLR 6/19/80." Shapker stated the weld records show the pipe piece was welded to the RHR system on June 15, 1976, for weld RH-82a, and on October 14, 1976, for weld RH-82, which was four years before the heat number of the piece was noted on the weld data records.
Shapker reviewed the isometeric drawing and construction piping inspection plan along with other related documentation for the pipe-and weld and found no reliable documentation to justify the adding q the questioned heat number to the the weld data ibra.' Shapker stated this appeared to be an intentional fraudvNS.-t entry on n
the form to'NvAr the tracablity of the heat number of the pipe piece.
4 On Mary'ch 25,198, Richard L. Reiter, former Document Reviewer, Kaiser was interviewed and stated he was employed at the Zimmer from November, 1978 to November, 1980. He stated he reviewed
.. isometric drawing to insure drawings and related documentation,
, such as weld data records met ASME Code Requirements, and T' drawings were correct as to the as-built condition of the plate.
Duriing his reviews he found discrepencies in the drawings and n)o%YfT
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~ - . ~ . . . . - . . . . . . . . __. . _ . , _
205FF DRAFT /db associated documentation w Rch PAFT not match conditions in the plant. Reiter stated specifically numbers for pipe._ sections, and weld data records did not match. Hestatedtd'kas. concerned about this and on October 28, 1980, wrote Surveillance Report (SR) 2819 to Floyd Oltz, his immediate supervisor, stating'khen reviewing isometric drawings he is making assumptions which he felt compromised his integrity',' and asked for a written directive telling him to make these assumptions, or for Kaiser to reevaluate all small bore isometrics to insure that there is documentation to insure traceability of the material. He stated in the SR he also questioned the disposition of NR's dealing with lack of material traceability.
Reiter stated Oltz responded and said 'all the procedures are approved and are adequa,te to meet regulatory and ASME Code requirements. He wrote that he is to continue using the approved procedures and practices in effect. Reiter stated he disagreed with the disposition of the SR and shortly thereafter terminated j his employment with Kaiser, because he felt he was being forced i
- to compromise his integrity. A copy of the SR authored by Reiter on October 28, 1980 is appended to this report as EXHIBIT (le).
" g. C . Record Reviews During the week of June 8-12, 1981, Inspector Shapker reviewed the
~
[ollowingrecordsinresolutionofthedispositionofthisNR.
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205FT DRATT/db NR E-5108, dated May- 19, 1980 ; . i, "s y p Kaiser Engineers, Weld Data Sheet No. 4826, dated January 21, 1976
'?
Kaiser Engineers, Weld Data Sheet No. 1852 * .
Construction Piping' Inspection Plan for Residual Heat Removal
~
Sy:: tem Inspection Plan No. RH-15 dated June 16, 1976 r
JII. Field Observation The field observations made by spector Shapker are reported in'the preceeding paragraphs. Based on the record reviews and
, field observations of NRC inspectors in was established this NR
,, was improperly voided, acceptable documentation was not found to justify th'e voiding of NR'.5108.
. s __
( E. Acceptance Critcryia ,
None.
SG.
I M . Investigation of Disposition of Nonconformance Report Control No. 4309 e, A . Background Information l -
i R
' ,. On Janurary 7, 1980, Inspector Micheal McCoy wrote a.NR Control
', No. 4309 which identified deficient weld fitup on a one and three quarterscover plate to beam W32X260 located on the reactor a .
pedistal supp/rt structure. McCoy stated in the NR the that IM h f\ Qi l[A L P%.
- . ~ . -
l 205FF DRAIT/db parts to be fillet welded brought were not brought in as closer" contact as practicle and were separated by more than,3/16 of an inch. A copy of NR with Control No. 4309 is attached to .this report as EXHIBIT ( ).
t B. Personnel Interviews Interview of Michael McCoy On February 11, 1981, Michael McCoy, Quality Control Inspector, Kainer was interviewed and stated on January 7,1980, he wrote NR Control No. 4309 for welds on the reactor pedistal suppor-structure that did not meet cope requirements.on-+-reactor-pedistal. McCoy stated in this case he initiated the NR, his supervisors concurred i,n the initiation of it, and he received a control nux.ber from the NR controller. He said after he wrote the NR it was returned to him with no disposition. McCoy stated in addition to voiding this NR, frequently NRs were inadequately dispositioned. He attributed this to a QA manager's lack of support for the Inspectorsyor the QC program at- Zimmer.
On February 11, 1981, Michael McCoy provided a written statement
".. attesting to the aforementioned information, a copy of which is attached as EXHIBIT (AD.
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205FT DRAFT /db
~
C. Record Reviews v
ke . - .
Review of Nonconformance Reporting I.og ,,
On February ll, 1981, the Kaiser NR log was reviewed and it was found Control No. 4309 was assigned to NR No/-2417 which identified deficiences in electrical installation of coipuit bracing in the control room. A copy of thiiNR is attached to this report as EXHIBIT (@ . During this review it was noted there was evidence of white out in the specification, and equipment nane or process section of the NR log. A copy of the NR log page is appended to this report as D3ISIT (19 D. Field Observations .- m Based on -a review of the NR in question, the NR log and the interviews of personnel it was deter =ined that lespector McCey's NR was never entered into the Kaiser coneonfor=ance reporting system.
eE. Acceptance Criteria Kaiser Procedure, Nonconforming Material Control QACMI G-4,
~
Revision 8, dated December 11, 1980.
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. I A J k <l 22 - ,
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205FI DPAFT/db
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1I'. Investigation (A. Background Information bI .
On July 22, 1980, and on July 9, 1980, seven NRs assigned Control Numbers 4955-59, and CN 4930 and 31 were written by inspectors Joseph Mills and G. McCann. The NRs identified weld deficiences onpipesupportsin8ieseldenerator(DG)RoomA. The orginals of these seven NRs were given by. Inspector Joseph Mills to NRC Inspector Thomas Daniels in March 1981. The seven NRs have been assigned control numbers, but no NR number. The copies of the seven reports are appended to this report as EXHIBIT (!-7 LB. Personnel Interviews Interview of Joseph Mills On June 2, 1981, Joseph Mills, Quality Control Inspector, Kaiser was interviewed and stated in July and August of 1980 he w+s identified nonconforming welds while inspecting pipe support hangers in G Room A. /hesaidbeidentifiedthe~weldonNRs which were assigned with rentrol nue$ers 4955 to 4959. Mills..
,M
.. stated he had the authority to initiate, a,NR call the NR con-
, troller for a NR control number which was affixed to the bottom of the NR. He said in this instance he initiated the NRs.and his supe' r visor, Rex Baker, concurred they were valid. Mills stated s ..5 ~3 $;- C 7,l k {'4gj sk
. ~ _..-
- w. - . . - - ~ .-- a-- . -, . . . . ..
+ - -- - - - . - -
205FF DRATI/db D.e-> 9 AFT u 4.
in August 1980 he was reassigned from pipe support hanger inspectiontostructuralweldinginspection,'[ia week a_fter the ..
reassignment the five NRs he had written in July 1980 gere '
returned to his desk without being processing. Mill's stated at the same time two other NRs written by Inspector G. McCann were also returned to him.
Mills stated in March 1981 he learned of an NRC investigation
!):
into the NR System and turned in k h d-McCann's seven unproc-cessed NRs to the NRC. He explained to NRC Inspector Thomas Daniels that they had never been entered into the NR system. He said Daniels asked him to reexamine the welds in DG Room A to see if the nonconforming welds he identified earlier were still in this condition. Mills. stated he reinspected the same areas in -.
DG Room A and in each case the condition that he had previously identified had been repaired and j the welds were now acceptable.
Mills stated apparently someone had used the information on the NRs to correct the nonconforming conditions. He said, however, this was not done via-the Kaiser NR system since the original NRs and all the copies of them had'been returned to him and McCann unprocessed.
1
= (, On June 2, 1981, Joseph Mills provided a written statement attesting to the' aforementioned information, a copy of which is l attached as EXHIBIT (16.
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205FF DRAFT /db h.
Interview of Floyd Oltz thM $ \ s B On June 19, 1981, Floyd Oltz, QAE, Records, Kaiser, wh inter-viewed and stated be reviewed the Kaiser NR Log and found that NRs assigned Con el-No. 4955 to 4959 and 4930 and 4931 were voided with the comment "MR not issued." Oltz ststed in these instances Kaiser did not retain a copy of the NR in the voided NR filej 8111 ,rhAN because these reports that are voided as Not Issed are returned 1
to the inspector, and in-these-eases Kaiser does not maintain a copy of the NR in the voided NR file.
Interview of Lynn Anderson l
l On June 9, 1981, Lynn Anderson, Inspector, CG&E, was interviewed and stated that he is employged by Nuclear Energy Services Inc.
at Zimmer and is contracted to work as a Quality Control Engineer for CG&E, Anderson stated currently je is conducting an audit of the Kaiser Nonconformance Reporting System. Anderson said on June 4, 1981, he checked the disposition of NRs assigned l
l CN 4955 and 4959. Anderson stated he reviewed the NR log and i
found that those CN had been assigned and the reports had been voided on September 30, 1980. Anderson said he checked all of l ,. the Kaiser and CG&E NR files and could not locate these NRs.
Anderson concluded that these reports although a hed CN been issued had never been entered into the active or voided NR l - .
-files.
l ,
h7'\itjGN}\ II C wl
. -. .a . . . . . . - - - . . ~- :- - - - ----- - -
205TF DRATI/db
~
- f. C. Record Reviews a
On June 10, 1981, theKaiserNRlogwasreviewedandIt"was found the CN 4955 to 4959 were entered into the NR system; however, the entry had been lined through with the comment, "VOIDNRnotissued"anybited9/30/80." A review of the NR log for he entries og CN 4930-31 found that they had also been entered into the NR system; however, the comment " VOID NR not a; *n , : s' Ti:(
is su ed,. and dated September 30, 1980 was lin;e-d-tiirough-the-log
- book page for each entry. Copies of the NR Log Book pages are appended to this report as EXHIBITS C)) and 03).
g D. Field Observations On June 2, 1981, NRC_II1spector, Jerome Schapker, inspected the areas in DG Room A identified on NR CN 5955-59, 4930, and 49
- 31. Schapker stated in two of the seven instances it appeared
.~
that the welds had been reworked, for the other five this could t.
not be determined. However, thel conditions identified on the NRs were no-there-for the welds he inspected.
Pased on the af ter-mentioned interviews, record reviews and
.. field observations by NRC personnelfit was determined that
, s.
,. ' although these six NRs were voided, a copy of the reports was
, . . . ?. 4' never mantained in the voided NR file. All four copies of the reports had been returned to the inspector. , ,, ,, y
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205FF DRAFT /db E. Acceptance Criteria 9
Kaiser Procedure QACHI G-4 Revision 7 dated April 7, 7980 Kaiser Procedure QACMI-M-12 R.7 Sargent & Lundy Specification H-2256
(,
11-I.. Investigation of Disposition of Nonconformance Report E-2466
- e. A,. Background Information On January 3, 1980, Kaiser Quality Control Inspectors inspected large bore pipe hangers in Diesel Generator (DG) Rooms A, B, and C. They inspected welds on pipe support hangers concrete enbedment bolts, and for configuration and location of the pipe ,
.supporthangers.Thein,spectorsidentifiednonconformingKalser f
and vendor welds fivE onbangers, and improperly embeded bolts.
They identified a total of 124 nonconforming pipe support hangers, and intiated NRE-2466 to document this condition. On June 30, 1980, the NR E-2466 was voided with the comment, "each hanger listed will be issued on a separate NR." A copy of the first five pages of this 31 page NR is attached to this report as EXHIBIT (!$. , . .-(*
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l l
27 -
. . . -. . . . ~ ~~' ' ~~ '~
.__ _;_c - - ; _. _ . _ - w _ _ . _ . _- _ _
205FF DPATT/db f E.
Personnel Interviews On February 12, 1981, Thomas Daniels, Inspector, Nuclear, Reg'ulatory Commission was interviewed and stated during the week of February 9-11, 1981, he reviewed the Kaiser, Log of Nonconforming Material to ascertain if the hangers identified on NR No. E-2466 had been issued on seperate NRs as stated in the void stamp on the NR.
Daniels found that of the 124 pipe support hangers in which nonconforming weld or embedment bolts were identified only 25 had been redispositioned on other NRs. Of these 25, 8 had been
~
reworked,7hadbeenvoided,andther$isnodispositionfor the remaining 10. Daniels stated as of this date 99 of the 124 hangers identified on NK'2466 had not been reissued as stated on' June 3, 1980. - --
Interview of Rex Baker On March 3,1981, Lex Baker, Inspection Supervisor, Kaiser was interviewed and stated t' hat he was aware that various NRs which identified nonconforming conditions on pipe support hangers were voided with the stipulation that they would be " reinspected after redesign." Baker stated he directed a 100% reinspection
= ,, of all pipe support hangers be conducted as stated in the
~
earlier committment. However, QA managers', Phillip Gittings and Kenneth Bumgartner, directed that pipe support hangers
'~ ~
which had been previously inspected and not redesigned, would DRAFT W
. . - -. . - . . ....--- . ....-- - _ . 2. = -
205FF DRAFT /db
~
not to be reinspected as stated earlier. Baker stated to the best of his knowledge the NRs which were voided on this basis were not redispositioned or reopened jr.To repair the senconforming conditions previously identified. Baker stated in his opinion
~
this was not done to avoid reworking the welds, but was an administrative oversight by the QA managers.
C. Record Reviews On February 12, 1981, NR E-2466 was revived and it was noted there was a comment on page two of the NR which states that an asterisk identifies "what appears to be vendor supplied welds" on pipe support hangers. In reviewing the thirty-one page NR it was found that 15 of 124 pipe hangers identified on it have an asterisk identifying,them as vendor supplied hangers. These '
15 entries on NR E-2466 were crossed out. Examples of the ommission of these items from NR E-2466 are included in EXHIBIT ( D.
D. Field Observation Based on the interviews and record reviews it was found that NR E-2466 was not properly voided and that the justification for
"' .. the voiding was never fully implemented. ~
i e s.. g C.",h f W' l
1\I I
m.m.. .__u.._.-- 1 ._ u 2 . _ _ - -m- 2. 2.1 205FF DRAFT /db E. Acceptance Criteria j Kaiser Procedures QACMI-M-12, QACMI-M-15, SPPM-4.6 .,
Kaiser Procedure QACHI-6-4, Revision 7 dated April 7, 1980 III. Investigation of Disposition of Nonconformance Report E-2836 A. Background Information On June 22,1980, NR E-2836 was written by Rex Baker, Inspection Supervisor after an audit by Nuclear Energy Service Audit which found there was no radiograph of the final weld for weld WS737
.fi n the plants service water system. There was a comment in the description of, nonconformance section of the NR which stated :
the only radiograph available was an "information shot of the root layer" for the weld and subject weld is buried underground.
The NR was dispositioned as " accept as is" on October 24, 1980, because the KE1 (weld data form) reports the final weld was radiographed and accepted by Kaiser on April 5,1976, the disposition was reviewed by the Authorized Nuclear Insurer (ANI) on April 15, 1976. The " accept as is" was disposition i
i intially rejected by the Authorized Nuclear Insurer (ANI) on i ;
- ,, November 7,1980; however, thi approved the disposition on
~ '
-November 11, 1980, based on the entry in the weld data form i
l showing that a final review of the film was made. The NR was l - .
voided on November 10, 1980, with a comment "see Revision I for
,=38 L ' h j-"s 1 30 -
I
20577 DRATT/db ,
' it'is new disposition." There is a another comment on the NANIR-y..-
which says, " VOID stamp in error - Rev. 1 cancelled when an t.'-
accepted disposition on 11/11/80." A review of NR E2 8..6',
Revision 1, shows the same nonconforming item is identified jthe disposition is to " accept as is," and the NR is signed by the appropriate members of the material review board. The NR was closed on November 13, 1980. There is third typed copy of E2836, Revision 1, date November 11, 1980, which has the comment " VOID written in error - NR resolved on original issue." The Kaiser NR
.-:1 -
Log ReportSthat NR2836, Rev. 1, was closed on Nove=ber 11, 1980.
..J.... ,.3 A copy on NR'836,'ANDE-2836 2 Rev. 1 is attat'ched to this report as i
EDiIBIT' (r,) and @D .
B. Personnel Interviews Interview of Rex Baker On June 4,1981, Rex Baker, Inspection Supervisor, Kaiser, was interviewed and stated on October 22, 1980, he initiated NR E-2836 after an audit found that there was no radiograph of the finaltekenweldpassfopeldWS737. Baker stated he forwarded the NR to Arch Lanham, Construction Department, Kaiser, who
.. dispositioned the NR as " accept as is" based on an entry on the
, KE1 form which reports a final radiograph of this weld was taken on April 5, 1976, and was accepted by a Kaiser welding engineer, and by the ANI on April 15, 1976. Baker said the NR 31 -
DRAF"1"
- . ~ . . .- -- ~ , -- . .. . - ~.
205TT DPRTTjdb was returned to him, and be told Lanham the disposition " accept f
as is" was contrary to ASME code requirements, iiBecause there was n'ot final radiograph of the questioned weld. He tokd ,Lanham to rely on a entry in a KE1 form to prove that at on'e time a
~
final weld was radiographed.,was not sufficient evidence that the weld had been radiographed.
Baker also stated at this time he reviewed the Kaiser radio-graphic exam report and the accompanying film, dated April 17, 1976. Baker stated he is a Level III Radiographer who is qualified to read and interpret ilk. He reviewed the film and told Lanham the film was an information shot of the. root layer for the weld, and was not radiograph.. of the final weld pass.
Baker said Lanham responded and said the disposition is correct -
, because the block on the.KE1 is checked, and that if QA does..
not have the film he could care less about it. Baker stated be told Lanham that construction would have to dig the weld up to
- radiograph it, to which Lanham replied, " Bob Marshall would never let us dig it up." Baker stated Lanham dispositioned the NR as " accept as is" yet he knew there was no final radiograph for the weld.
l 1
' Baker also stated on November 7,1980, the site ANI, Lowell Burton,
~ '
i ANI rejected the disposition on NR E2836 but later rescended
( the rejection,and agreed with the " accept as is" disposition
- i _ ,-
based on the entry on the KE1 form that reported a final review 32 -
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~
of the film had been made by a previous ANI in 1976. Baker said the NR was eventually dispositioned as " accept as is," and he refused to concur in the disposition because it wal contrary to ASHE code requirements.
Interview of Lowell Burton On June 5,1981, Lowell Burton, Authorized Nuclear Insurer, Hartford Steam Boiler Team Inspection and Insurance Company was interviewed and stated after reviewing NR E2836 he was in error in accepting the disposition of this NR on November II,1980.
Burton he reviewed the film packet for weld WS737, and found there is no radiograph of the final weld pass in the file. Ee stated be has directed the licensee to reopen the NR to reflect.
this nonconforming condition. Burton stated he based his' acceptance on a review of the KE1 Form and his personal notes which showed that on April 15, 1976, he reviewed the radiograph of the weld and found it to be acceptable. Burton stated during this period be reviewed up to 100 radiographs a day and could
. . f, . . : , . . . . m . w.J .
have possibly encred.,in his notebook or on the KE1 Form which
,,, : . u-showed that he had seen the radiograph of the final weld, when in fact he had only seen a radiograph of the root layer of the
- i. weld.
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205FT DRAFT /db l
Interview of Jerome Schapker, NES On June 12, 1981, Jerry Schapker, Inspector, NRC was Daterviewed and stated he reviewed the NR E-2836 and associated documentation which included the Kaiser Report of Radiographic Examination and accompanying film. Schapker stated that NR E-2836 was improperly voided because there was no final radiograph for veld 737 in Kaiser files. Schapker noted that the radiograph referenced as accepted by the ANI on April 15, 1976 is actually a radiograph of a partially completed weld. The radiograph of the incomplete weld is dated March 31, 1976, and was reviewed by the ANI on April 15, 1976. Schapker stated apparently the radiograph of the rootpass was misstaken by the ANI to be a final radiograph of the weld andf: accepted it as such when in J fact no' final radiograph of the weld exists. Schapker stated the proper disposition for this NR would have been " rework" which would include the conduct of nondestructive examinations - ~
required by ASME code;and licesee specifications.
. C. Record Reviews Between June 2-5, 1981, the following records were reviewed by 1
,. inspector Schapker.
I
. I Kaiser Engineers for KE1 Form weld VS737, dated April 10, 1976. t DRAF
. . ~ - - . . - - a. . .: . - __ . ..._ .-
205FF DRAFT /db Kaiser Engineers Radiographic Examination Report dated April 15, 1976 (and accompanying radiographic film packet). --
a e .
NRs E-2836 and E-2836, Revision 1.
D. Field Observation Based on the preceeding interviews, and record reviews, along 4
i with the examination of the radiographic film for veld WS 737 conducted by Inspector Schapker it was determined NR E-2836 was improperly dispositioned as " accept as is" and closed on November 13, 1980.
E. Acceptance Criteria l
Sargent and /lundy Specification H-2256, Fern--410 Kaiser Procedure QACMI G-4, Revision 7 dated April 7,1980 J.,JII.InvestigationofDispositionofNonconformanceReportE-1777 l
l
'A . Background Information
",. .On April 3, 1979, Inspector Terry Dakin wrote NR E-1777 stating
, that weld A2 on isometerie drawing RI-195 on a a pipe support hanger in the primary containment area, was made without QA documentation. Also, Dakin performed a post weld inspection D_.9A,FT m t f
1
. . - ~ . . - -- 4
205FF DRAFT /db
~
DnAFT and found the weld acceptable; however, no rod slip was found to ensure that the proper filler metal was used in the weld.
The disposition of this NR was to " rework" and cutout "the veld because no acceptable documentation was available to verify the proper filler metal was used. This NR was voided on April 30,
-1979, with the comment " rod slip located." A copy on NR E-1777 is appended to this report as EXHIBIT (24
- f. B . Personnel Interviews Interview of Vincent Feretti On June 4, 1981, Vicent Feretti, Level III, Quality Assurance Engineer, (QAE) Nuclear Energy Services Inc. was interviewed -
and stated he conducted an audit of the Kaiser nonconformance reporting system fo'r the licensee and reviewed NR No. E1777 y Ahd the associated isometric drawings identified on the NR.
Frerretti stated the drawing shows four hangers with six field welds for all of the hangers. The isometric drawing and attached weld rod issue slips show as stated in the NR that there is no 4
weld rod issue slip for weld No. 195A2. Frerretti stated the weld rod slips attached to the drawing should identify what
~~
. particular filler metal was used for each weld but in this cas
, he was unable to ascertain by looking at the rod slips what filler metal went into each of the welds . Frerretti stated the
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205FF DRAFT /db DR AFT decrepancy identified in the NR was correct and he directed the NR be reopened and redispositioned. Frerretti stated, in his opinion, this NR was improperly voided. ..
Interview of Floyd Oltz On June 4, 1981 Floyd Oltz, QAE, Records j Kaiser, was interviewed and stated he reviewed NR E-1777 the weld data sheets and weld rod issue slips. He said that in this instance this NR was 1
improperly voided. Oltz stated the disposition " rod slip located" was improper, because the rod slip used to justify the voiding of NR does not specifically identify the weld in which the weld rod was used. Oltz concluded he found nothing in the records asso'ciated with this weld to justify the voiding of
. this NR. .
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On June 4, 1981, Jerry Schapker, Inspector, NRC was interviewed and stated af ter a review of NR E-1777, the weld data records, and weld rod issue forms, that he also found no justification forthedispositionofvoidingthisNRbecausetherewasnorod issue slip in the weld data package for weld A2.
l l
-cC.
Record Reviews l
On June 4, 1981, Inspector Schapker reviewed the following-records while resolving this allegation.
-. , . .h ..
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7 "
- _. ..- ~.. -.
l:-.- - - . . . , _ _ _ . . . . . - . . . - . . .
205F RAFT /db
. W Nonconformance Report E-1777 bD Isometric Drawing No. N4713 RI-195 for the Reactor Isolation System in the primary containment building a .
Kaiser weld rod issue form Nos. 111515, 139801, 126964, 126963, 126960, 174535, and 174534 D. Field Observations Based on the interviews, record reviews, and review of associated documentation it was determined that NR E-1777 was improperly
~
voided, and no rod slip was located for weld A2 as alledged in the comment written within the void stamp on the NR.
E. Acceptance Criteria .-
Kaiser Proedure QACMI G-4, Revision 6 dated November 14, 1979.
' ~
.~ III. Investigation - /'es T ~ ~ "
A. Background Information On October 16, 1980, QC Inspector Mark Priebe, Kaiser, wrote NR
- ,, Control No. (CN) 5122 which was written following the initiation
~ ~
l of surveillance report (SR) 2800 which reports that the flexible outer coating of conduit installed in the containment building
! ~ "
l is splitting for an unknown reason. This NR was not assigned a n"
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sn.= - = . . - a.-.- -. - . - - . - .
l DRAFT /db l Dw. e' T205FF ;
NR number yet it was voided on January 2, 1981, with the comment in the void stamp block "see attached surveillance report No. 2800." i
. Surveillance report 2800 was the report used to issue 1.he NR. A ,
copy of the NR CN 5122 is appended to this report as EXHIBIT C1).
J B. Personnel Interviews Interview of Steven Burke On June 11, 1981, Steven Burke, QC Inspector, W91ectrical, Kaiser, was interviewed following his inspection of the areas identified on NR CN 5122. Burke stated the nonconforming items listed in the NR on October 16, 1980, " covering spliting and separating from electrical cables in the containment building" are still apparent on t,he conduit he' inspected. Burk' stated he concurred with Priebe's report that this problem was serious; and warranted reporting via the Kaiser nonconformance reporting system. Burk concluded that Priebe's NR was not written in error JR because he found the same problem with the outer it flexible material seperating from the conduit to the same 1
('p laces identified by Priebe on'the NR.
-- c C' . Record Reviews On, June 11, 1981, Kaiser, Quaility Assurance, Surveillance Report (SR) No. 2800 was reviewed. reports that on October 9, 1
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~
DA l*R 5 F
e
. DRAFP 1980, the outer coating of flexible conduit used in the con-tainment area was spliting for some unknown reason. -The
,c: a corrective action statement the report states this deficiency could be serious enough to warrant formal reporting to the NRC.
~
Also in the corrective action section of the report are comments that NRs CN 5122 and CN 5196 are voided in lieu of this SR. -
The " corrective action verified",.by'section of the SR is stamped i:s :c iti, rid .
nonapplicable and dated October 14,1980./Weemoattachedto \
the SR from Robert P. Ehas, CG&E, to Phillip Gtitings, QA Manager, Kaiser dated October 35r-1980, reports that in Ebas's
. i n T'-
opinion this'does not warrant reporting to the NRC. A copy of
. SR 2800 and attachments is appended to this report as EXHIBIT (.'i),
i I
d D ~. Field Observations ..
~
s Based on aforementioned interviews,' record reviews, and field observations by licensee inspectors it was determined that NR CN 5122 was improperly voided. It appears that the SR used to initiate the NR was later used as justification to void the NR.
The nonconforming material identified in the NR was not corrected by the licensee,and was never introduced into the Kaiser noncon-formance -reporting systems Also the Kaiser nonconformance r
,, reporting procedure was not followed, this report was found misfiled in the " inspection report" file, but infact wasf'" voided" lNR. It also appears that NR CN S196 was dispositioned in the t _ ,-
same' manner.
1
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205FF DPJ07/db
~
c E. Acceptance Criteria a
Kaiser Procedure QACHI G-4, Revision 9, Dated Decembef' 11, 1980.
/g,U-L. Investigation of Disposition of Nonconformance Report E-2233
. A, Background Investigation On November 21, 1979, QC Inspector L. Wood initiated NR No. E-2233 documenting a nonconforcing condition for veld WS62GP in the reactor building service water system. The weld was welded to completion without evidence of fitup inspectio:.,
welder qualification, and material traceability; however, a final visual inspection,of the weld was made and the weld -
acceptance. On December 21, 1979, M. Feltner, QA, Engineer dispositioned the NR and directed it to be " reworked".and cut out. On January 24, 1980, the NR was voided with the cenment "KE1 form corrected." And was initialed by Floyd Oltz Q E ,
Records. A copy of NR E-2233 is appended to this report as .,,
EXHIBIT (:J) . . . .
" ;' '13. Personnel Interviews
. gA _ ;t.
Interview of Jerry Schapker l
- - - - - ~ ~ - -
205FF DRAFT /db On February 13, 1981, Jerry Schapker, Inspector, NRC, was interviewed and stated on February 13, 1981, he reviewed NR No. E-2233 and related documentation. Schapker stated athis R y ,.)
was voided after the weld data record was (KE-1) form," corrected."
Schapker said the correction was actually a deletion of previous stipulated hold points and said there is no documentation supporting the engineering bases for deleting the hold points.
In addition, he interviewed Floyd Oltz who advised him he had i
deleted the hold points from the KE-1 Form; however, no signature or date of deletion was noted on the form. Schapker said the KE-1 Form wirith is appended to this report as EXHIBIT GF) was initially anotated to reflect that weld procedure, weld quali-fications, heat numbers, and fit up, would be verified by the QC inspector during in process inspection of this weld. The -
form was anotated with a "NA" superimposed over the "x" mark in the blocks, which had been made previously by a Welding Engineer.
Schapker said the notation "NA" was made by Oltz, and constituted a deletion of a previous stipulated hold points for the weld.
He said NR E-2233 was improperly voided because previously stipulated hold points were deleted by a document reviewer without engineering justification.
l t
I
=
Schapker advised while investigating the disposition of NR E-2233 he found that KE-1 forms 2552, 2553, and 2560 also did not have material traceability for the gamma plugs welded to
~ '
the piping that was installed in the service water system.
l
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Schapker said the KE1 Forms identify the mark numbers for the pipes, but not the heat numbers for the gamma plugs velded to these pipes. He added the gamma plugs in question whEn " examined in the field were stamped with a heat number, however, this heat number is not entered on the KE-1 Form.
Schapker also advised NR No. E2237, dated November 23, 1979, also for the closed cooling water System, reports the same nonconforming condition on another weld which is identical to the condition identified in NR E-2233 (IE lack of weld trace-ability and welders qualification). Schapker stated the dis-position for this report was " rework," however, it was also voided by on December 19, 1979, by Floyd Oltz with a comment V:
" void rod slip found". Schapker advised this NRs disposition was identica1to of-Repo,rt E-2233, and previously stipulated hold points were deleted without engineering concurrence.
,:: c:... i 'i ! '~j: 7 5 p.';. j ' , i ,., ' T: -r .
l- ~,s , ~ '? r ! _,
, C .' Record Reviews
+
During the course of this investigation the following records were reviewed in resolving the disposition of this NR.
.- .h' Nonconformance Report E-2237.
Nonconformance Report No. E-2233. .
O DRAM
._s . ,% . - - - . ""
- m. ~. . . - . = - . :w - -. u.. : 2 .
. . 2. ::. . - . - . . . = = .
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./
k' eld Data Sheet (EE-1) No. 18391 and associated weld-rod issue forms. --
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=.
i Kaiser veld data sheets (KE-1) No. 2554, 2552 and 2560.
D. Field Observations Based on the aforementioned interviews and record reviews it was determined that NR Nos.~ 2237 and 2233 were improperly 4
voided.
E. Acceptance Criteria Sargent and Lundy Specification H-2256 Kaiser Procedure QACMI G-4, Revision 6, Dated November 14, 1979
,'. IIL Investigation into Disposition of Inspector Ruiz Nonconformance Report Dated February II, 1981 a A. Background Information On February 11, 1981, QC Inspector James Ruiz initiated a NR, * ,
~
x .. cn I)
~',. identifying nonconforming welds on drywell steel in the Primary Containment building. Ruiz described the nonconforming condition as an electrode weave on a weld exceeding 3/4 inch. The NR in question was not assigned a control number and was not issued a DRAFT I
j' . . _ . _ . . ._ -~~
SntTv P.01T'T # A
~~
~
DRMT NR number but had a comment written in the disposition section which states, "sent back with no reply. This particular NR
- n. .- -
was provided to the NRC by Inspectcr Ruiz. A copy of"the NRjis appended to this report as EXEIBIT (M .
t E. Persennel Interviews Interview of James Ruiz On February 25, 1981 Janes Ruiz, QC Inspector, Kaiser, was interviewed and stated on February II,1951 he performed an inspection of a beam located in a primary centainment building and noted a noncenforzing condition en a weld. Ruiz stated he p ; ; .',-
vrote a NR on thist and submitted it te his . supervisor, Dennis e
~
Donovan, who concurred ,in it and forvarded it to Rex Eaker, Inspectics Supervisor, who also concurred. Rui: stated the next day Eaker stated the QA Manager, Phillip Gittings had returned the repert to him and said inspectorivere net to write a report against a procedur^ violation of a specificatica. The NR was then returned to him, it had not been assigned a ecutrol-cumber or entered into the Kaiser nonconformance reporting system. Rui: stated _he took exception to Gittings' decision
, . prohibiting inspectors from writing reports against procedural violations; he said the velding procedures deliciated the -
welding specifications, parameters, dimensions,'and other 4
inspection criteria for judging whether a weld is acceptable er
- t. . . ~
L M, A N
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. ----... ,. ... . : ,. - ~ ~ . -
-^^
^
- - - - - - - - - = - - - - - - ---
DRATT/db l's A F.s. I ,
unacceptable. Ruiz provided a sworn statement attesting to the '
aforementioned information, a copy of which is attached as EXHIBIT C').
Interview of Jerry Shapker On June 3,1981, Jerry Shapker, Inspector, NRC was interviewed and stated be made a visual examination of the weld inspected by Ruiz on drywell steel beam 81, located in the Primary Containment Building. Shapker stated on the beam he observed a weld with an electrode weave in excess of 3/4 inch. A photograph of the questioned weld was taken and is appended to this report as EXHIBIT C:). Shapker said in this instance the weld is not necessarily defective,-however it did exceed specifications as. --
stated by Ruiz in the NR.
- f. .,. .
-l , ,: -
On June 3, 1981 Phillip Norman, QC Inspector, Kaiser, was interviewed and stated on this date he accompanied Inspector Shapker to the Primary Containment Building during Shapker's inspection of drywell steel beam No. 81. Norman stated he concurred that the electrode weave on a weld to beam No. 81 exceeded 3/4 inch as stated by Ruiz in his NR. .
.=..
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l
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205FF DRAFT /db
~
t C. Record Reviews On June 30, 1981 the Kaiser NR log was reviewed along*with all Kaiser NRs initiated between February 11, 1981 to February 20, 1981. The NR written by Ruiz on February 11, 1981 was not entered into the Kaiser nonconformance reporting system.
d D. Field Observations As stated in the previous interview with Inspector Shapker, the
, questioned weld on beam 81 in the Primary Containment drywell area was visually inspected by Shapker and the deficiency identified by Ruiz and reported in the )m was also identified by Shapker.
l Based on the interviews, record reviews, and field observations by NRC personnel, it was determined that the NR written by Ruiz was never entered into the Kaiser nonconformance reporting system. The nonconforming condition identified in the NR was l
not identified and corrected.
E.
Acceptance Criteria l
l _=-
l
( . .
l _, Kaiser Procedure QACMI G-4, Revision 9 dated January 14, 1981 l,. r- _ . _ _ _ _ . _ - . - _
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. III. Investigation
\ ,- (4 Background Information *'
I On February 8,1979, Inspector David Painter initiated NR's i
No. E-1661 and E-1662 which report nonconforming conditions in welds on pipe support hangers in the drywell pneumatic system 1
of the Primary Containment Building. Both of the NR's were i dispositioned as " rework" on May 2,1979. On November 11, I i
)
1980, the NR's were voided by Floyd Oltz with a comment that j the nonconforming hangers will be reinspected after design analysis. A copy of NR's No. E-1661 and E-1662 are appended to this report as Exhibits O!) and (27).
f B.'
Personnel Interviews ,
Interview of David Painter
~
On January 14, 1981, and on June 4, 1981, David Painter, QC Inspector, Kaiser, was interviewed and stated as a lead inspector he supervises three other inspectors involved in the anspection of pipe support hangers at Zimmer. Painter stated inspectors wrote a group of NRs identifying. nonconforming conditions in
,. pipe support hangers which have been dispositioned as " VOID -
, will be reinspected after design analysis." Painter stated when this commitment was made, a 100% reinspection was planned
)
48 - ! '
+ _ ~ _ . . . - . .
- - . . - ~
-- _. -- _. - --. .~. . . - . . - - -
205FF DRAF7/db for all pipe support hangers. This was rescinded and hangers aj: i are now being inspected according to a M-12 checklisljand only - .
for configuration and location of the hanger after ite is redesigned. Painter stated the QA Manager said any hangers that inspectors previously accepted prior to the design changes and which were" effected by the design changes were not to be reinspected. Painter said this negated the earlier commitment used as justification for originally voiding the NR's, , and now inspectors were finding nonconforming welds on hangers that had previously been inspected and accepted. Painter stated Gittings was told about this and said again if a pipe support hanger had been previously inspected and accepted and his inspectors were questioning the acceptability, he was not initiating a NR on it. --
(C. Record Reviews The following records were reviewed during the resolution of this NR:
NR's No. E-1661, E-1662
.- Kaiser Isometric Drawing for Line No. RYIB2BA34 Kaiser Isometric Drawing for Line Nc. IIN61AC34 (Drywell Pneumatic System Reactor Containment)
DRAFT L
205FT DRAFT /db J II. Field Observations
=.
Based on the aforementioned record reviews and interviews of .
personnel it was determined that NR's E-1661 and E-1662 were improperly voided and resulted in the loss of control of pre-viously identified nonconforming items.
. E. Acceptance Criteria Kaiser Procedure QACM1 M-12 Taiser Procedure QACMI 6-4, Revision 7, dated April 7, 1980 III. Investigation -
_e_: . . . ' -
A. Background Information On February 2, 1981, Rex Baker, Inspection Supervisor, Kaiser .
initiated NR E-2996, Rev. 1, which reported that full penetration welds on T-Quenchers, Serial Nos. N001, N003, N007, N0011, and N0012 were found to have a lack of penetration at the backing ring (IE: Split Baking Ring). However, the rest of the weld was acceptable. The nonconforming T-Quenchers are located in
,. the Suppression Pool Main Steam Relief System. The NR was
, dispositioned on February 9, 1981 as " accept as is" by Arch I.anhamKI5ConstructionDepartment. Lanham's justifiad' tion for DRAFT
. .- - - . . . ~ - - - .-..
- - -. .._ . _ _ . _ . m . _ _ .. _ ___ ___
205FF DRAFT /db acceptance was that the split backing ring does not effect the integrity of the veld. The licensee's architecture' engineer, Sargent and Lundy, (S&L) Engineers, took exception to tliis disposition and directed that the T-Quenchers be ultrasonically examined (UT). On February 24, 1981, all the T-Quenchers were ultrasonically examined and found acceptable with the exception of Quencher No. 007. S&L's dispositioned the NR as acceptable, with the exception of No. 007 and said additional data is required to resolve 007 because it was not ultrasonically tested as directed. The Kaiser Material Review Board (MRB) agreed with S&L's disposition and granted conditional approval of the disposition of the NR,IN:$ arch of 1981. NR E2996, Rev.
1, was dispositioned as closed on March 17, 1981. This h7 was closed without any evidence that the required additional exam-ination,of T-Quencher N,o. 007 had been completed. A' copy of NR E-2996, Rev.1 is appended to this report as EXHIBIT (").
I B. Personnel Interviews l
Interview of Rex Baker i
On June 3, 1981, Rex Baker, Inspection Supervisor, was inter-
".. viewed and stated he wrote NR E2996, Rev.1, on February 2, l . . . . . . ,
l i
,. 1981, audit was improperly closed on March 17, 1981. Baker stated that T-Quencher No. 007 was not ultrasonically examined as directed by the licensee's Architect Engineer, Sargent and
a.m_.-_--..- .. ~ - -.
205FF DRAFT /db Lundy. Baker said the NR was closed improperly by a clerk in the Doument Control of fice mistakenly closed the NR-on March 17, 1981. Baker related when he learned E-2996 Rev. I wal closed he initiated NR E-3172 which references E-2996 and address the
- r. . ,
. p. s' .
issuez,the T-Quencher No. 007 was not adequately dispositioned 6n the earlier NR.
Interview of Floyd Oltz On June 3, 1981, Floyd Oltz, QA, Engineer, Records, Kaiser,was interviewed and stated NR E-2996, Rev. I was initiated by Baker on February 2,1981, for nonconforming welds on in T-Quenchers.
Oltz stated that the architect engineer directed the 7-Quenchers
, be ultrasonically examined to establish their acceptability. _
He said apparently, T-Quencer No. 007 could not be ultrasonically examined so S&L dispositioned the report as acceptable, with the exception of T-Quencher No. 007. Oltz stated he gave the NR to Cathy Faubion, NR Clerk, who read the initial disposition of l " accept as is" on the NR, a.nd did not read the exceptions I
l i
placed in the rest of the disposition column by the architect engineer. Oltz said she mistakenly closed the NR because she assumed the condition was " accept as is" when in fact the i
architect engineer had only granted partial acceptance. Oltz concluded this NR was improperly closed, due to a clerical error.
DRAFT
205FF DRAFT /db Interview of Cathy Faubion a
- 1. e .
On June 4, 1981, athy Faubion, NR Controller, Kaiser,was ,
i en i interviewed and stated she closed NR E-2996, Rev. 1, on May 17, 1981, because the top of the disposition block on the NR had the comment " accept as is." Faubion said she closed the NR but did not read the additional comments in the disposition column which said this was a conditional acceptance because T-Quencher No. 007 was not ultrasonically tested. Faubion stated in May of 1981, Rex Baker told her she had improperly closed this NR.
She said Baker initiated NR No. E-3172, which documented the nonconforming condition for T-Quencher No. 007.
- ...,. ,
- Vi i ,. - <' t..si . .:,
' .L . -
On June 4,1981, Jerry Shapker, Inspector, NRC was interviewed and stated be reviewed , document'ation and radiographs associated with NR No'. 2996, Rev. 1. Shapker stated the deficiency, (IE:
a split Backing Ring,) is permissible under ASHI Codes for Class C welds and the original issue was not nonconforming.
However, in order to verify that the split was in the Backing Ringj and was not a split in the weld a UT exam was performed to verify the location of the split. Shapker stated his review l showed on February 24, 1981, the questioned T-Quenchers were UT
.- and found to be acceptable with the exception of Quencher .
,. No. 007 which was not examined. The licensee's architect engineer, Sargent and Lundy, said the nonconforming conditiens j were acceptable with the exception of Quencher No. 007. Shapker l
l DRAM
. . . . ....m
a n . ~ ..-- - . . .- ..- : - - -. ... . . --- -..
205FF DRAFT /db stated a further UT or other nondestructive examination should -
have been conducted on Quencer No. 007; however, NR E-2997, Rev. 1, was mistakenly closed on March 17, 1981 with db exam-ination of Quencer No. 007.
C. Record Reviews During the course of this investigation the following records were reviewed in resolution of this NR:
~
Nonconformance Report No. R-2996, Rev. I Nuclear Energy Services, Report of Ultrasonic Examination, dated February 14, 1981 --
Esrgent and Lundy, Engineers, memo dated March 5, 1981 i
Nonconformance Report No. E-3172, dated May II,1981 Kaiser weld data sheets (NE-1 Form) for T-Quenchers 011, 003, i
( 007, 009, 011, and 012 l
l l
[ ;j D. Field Observations
( . .
Based on the aforementioned interviews and record reviews along
( - .
with'the review of the radiographs by Inspector Shapker, it was l determined that this NR was improperly closed on March 17, 1981.
I W
205FF DRAFT /db l
l (E. Acceptance Criteria
, KaiserProcedureQACHI6-4, Revision 9,datedJanuary 14," 1981
~
. Os 111. Investigation .s- ll : n ' - 6 l " 0 "' ' ' ' ' ' ' ~ ' " ' #" ' b ' * . . '.
q A. Background Information On January 3,1980, D. J. Luttmann, QC Inspector, Kaiser initiated a 33 page NR which was assigned Conrol No. 4389.
This NR reported various nonconforming conditions in electrical cable,, trays and hangers in the Auxillary Building.
j The NR was voided by Kyle Burgess on December 2, 1980, because the "NR was initiated just prior to inspector leaving the job. Alot of the items listed were accep, table in this area. Some items needed reinspection." Thir particular NR was recovered from the Site Document Control Vault on Jt.ne 4,1980, and apparently was misfiled with " Inspection Reports" which identify nonconforming tr.aterial found during receipt inspections at the Kaiser warehouse.
Although the NR was " voided" it was stamed " Inspection Report" in the block reserved for the assignment of the NR number, and it had been placed in the " Inspection Report" file. A copy of the first five pages of NRC N4389 is appended to this report as
. EXHIBIT (9).
DRAFI
~. - -
- - ~ ~ ~ -
205FT DRAFT /dt-
~
b B. Personne) Interviews o
Interview of Kyle Burgess *-
On June 18, 1980, Kyle Burgess, Inspection Supervisor, Kaiser was interviewed and stated he voided the NR assigned Conrol No. 4389 on December 2, 1980. Kyle stated that inspector D. J. Luttmann was an electrical inspector at the time and had reported various conconforming conditions in the electrical area. Burgess said he voided this NR because in the interim, Luttmann had left the site and some of the items were not deficiences; however, some were valid nonconforming conditions.
Burgess could give no apparent reason why the voided NR had been placed in the Inspection Report file. --
4 Interview of Jerome Schapker On June 22, 1981, Jerome Schapker, Inspector, NRC was interviewed and stated he reviewed the NR CN 4389 and found no sufficient reason to justify the it's voiding. Schapker concluded that the NR CN 4389 was improperly voided by Burgess on December 12, 1980.
- p. Record Reviews
. ~
During the course of this investigation the following records were reviewed in resolution of this NR. ]
, . . - _ . . - e-
= e --Me p * . , "
e . . _ _ . _ _ _ _ . - _ _ _ _ . _ _ _ . . _.
20517 DRATT/db Naiser Log of Nonconforming Material NR CN 4389 dated January 23, 1980.
a b .
d D. Field Observations None.
6 E. Acceptance Criteria Naiser Procedure QACMI G-4, Revision 7 datedIA ril 7, 1980
'^
/'III. Investigation _ ! "
,/ *
.A. Background Information On November 2, 1979, NR No. E-2191 was initiated by Richard L. Reiter, which reported that the consumable insert on a weld'the Closed Cooling Water System was not traceable. Reiter said there was no heat number on the weld rod slip for the consumeable insert on weld K253 on drawing PSKVR9. Reiter coment 'in the text of the NR that he confirmed this by looking at the original copy of the weld rod issue slip. The intial disposition of this report was " accept as is" with the reason being that all consumeable
. inserts are purchased as Class I (safety related) traceable n.aterials. The NR was closed on November 8,1979, and was reopened after the Authorized uclar Insurer (ANI) rejected DRAN
205FF DRAFT /db this disposition on January 7, 1980. On February 19, 1980, NR E-2191 was voided with the comment that it was redispositioned on )R No. E-2191, Rev. 1. Nonconformance Report No. f-2191, Rev. I was voided on February 22, 1980, by Floyd Oltz QAE, Records with a comment that the weld rod issue slip had been found. There was no engineering or Material Review Board concurrences on this disposition. A copy of NR E-2191 and E-2191, Rev.1 is attached to this report as EXHIBIT GD.
B. Personnel Interviews Interview of Richard L. Reiter On March 25, 1981, Richard L. Reiter, former Document Reviewer, e Kaiser, was interviewed and stated on November 2,' 1981, he -
initiated NR No. E-2191 af ter he observed that the Kaiser weld data form (KEI) No. 23037 for weld k'RK-523 did not have a entry fo(aheatnumberoftheconsumgableinsertusedfortheweld.
Reiter stated" checked the weld rod issue form attached to the (KEI). He also checked the Kaiser warehouse and identical copies of the same weld rod issue forms in the Kaiser warehouse and found the weld rod issue form did not record the heat
.. number for the consumeable insert. Reiter stated he then initiated NR E-2191 and commented that he confirmed but there were no heat number of the original rod slip. Reiter stated if an entry was made on any of the'SE weld rod issue forms, they c -
.. - 2- -- . - - . - . . . --- : -
--a ~ -
205FF DRAFT /db
, ..rc are f alse and were saf ter November 2,1979; because he confirmed
.i there were no beat numbers for the consumeable inseri on the rod slips that he reviewed in November of 1979. Reiter elso stated he hEquently suspected that Arch Lanhm, onconformance Report expediter for the Construction Department falsified records in order to resolve NRs rather than have the Construction Department repair or rework the nonconforming item. Reiter provided a written statement attesting to the aforementioned information, a copy of which is attached as EXHIBIT CG.
On February 25, 1981, Floyd Oltz, QA Engineer, Record (, Kaiser, was interviewed and stated that NR.No'. E-2191 was written by Reiter when he found no heat number for the consumeable insert onweldNo.K-523iheNRwasdispositionedbyLouisBoetger with a disposition of ", accept as is" based because all consumeable inserts are purchased as nuclear trade material. Oltz stated that Allan Clark the ANI for Hartfor!Stean and Boiler, Inc.
disapproved this disposition on January 7, 1980. This NR was voided on February 19, 1960, and was redispositioned on h3 E-2191, Rev. 1. Oltz stated that NR E-2191, Rev. I was voided by him on February 22, 1980 with a comment that the weld rod
! issue slip with a heat number for the consumeable insert was
.. found. Oltz stated that Arch Lanham, NR Expediter for con-
, struction found a rod slip for the weld with a heat number for the insert on it, so he voided the h7 since it was originaly
~
written in errosby Reiter on November 2, 1979.
l DRAM =
. .n u . . ~ . . _. - - _ . . _-
_.~ .. - _ _ .. ~
205FF DRAFT /db
~
Interview of Arch Lanham On March 25, 1981, Arch Lanham, Senior Engineer, Kaiser ~was .
interviewed and stated he disposition { NRs for the Kaseer.
~
constructionNepartmentatZimmer. Lanham states frequently he
..i a.
searches for lostdocumentation, such as rod slips wbtch resolving NRs in which a lack of adequate documenptation was cited as the nonconforming condition. He stated in the case of NR E-2191 the nonconforming condition was no heat number for the con-
,, c#
sumeable insert for weld K-523, ge n the KE1 weld data form,or on the rods slips which accompanied the form. Lanham provided his copy of NR No! E-2191 with field notes he wrote when dispositioning the NR. Lanham stated the original disposition of the NRwas re
. 'acceptasis'ihoweveronDecember 17, 1979 he noted: Floyd Oltz -
ha$ the original copy of the NR and he noted on his copy "could there be more than one rod slip for insert?" Lanham stated there is also the notation that on January 22, 1980 the NR was I
still not back from the architect engineer. Lanham stated after reviewing his notes that it appears he reviewed the KE1 data form and original rod slip and found that he had inspected weld No. WR523 on October 17, 1977.- He stated there was no heat number for the consumeable insert on the KE-1 form, however he looked at the weld rod issue form No. 97957 and found a heat
. '.;J.
,. number for the consumeable insert on it. Lanham said on the gold copy of form 97957 and the heat number for the consumeable insert was marked in ink on the carbon form and-it was circled y.---s
.j 3 . . .
E
- rm _m =-,.m.__.__. . - _ - 2 ___-.
2057F L:AIT/db
~
i red with his i itials. Lachas stated he recalls,$this instance that-he made 2is entry c: the geld ccpy of the ferz-i: Octcher p:v' e -
of 1977 whicle doi:g the field inspectic=g He said he,-ees med L
in this case there was no heat maber c= the veld red issue
~
form, and called the veld rod issue shack to obtai a pr:per l
heat number for the ec=sumeable insert. La has said he did =st make the e try en the form during the Xcvember 1979 through February 1950 time fraa[ vhile dispositie isg this NE.
C. Record Reviews l
0: . March 2I., 1951, Kaiser isenetric drawing for the c1csed cooling water syster PSK-1W.-9 was reviewed for line No. IVE17AE 2-1/2, veld Ec. EP.523. The Kaiser IE-1 Tcre shows a =ctatic that the heat ==mber fer the cens:meable insert is Nc. 6059.91. Veld red issue slip Nc. 97557 (geld ecpy) shrvs that the heat N :ber 6059151 is written it ici c a ctervise carbes fer=. Two other cepics cf Kaiser veld issue
~.' -i fer No. 97959, the stite cepy and the gold ecpy were reviewed.
l These ferns dc : t have the entry'Ebat the heat number. A ecpy cf the veld data sheet and acceepa:ying veld issue feras are attached to this report as EriIEITS (:-), G.3, (:-), (:.').
g .
i (1=vestigaters Note: During resciutie: cf this NK the state =ent by Arch Lathan 'is' ince:siste=t with the stateze:1 sade by p, .
Richard Reitery W is also ince=siste=t with Reiter's entry c=
. 61 --
DRAFT L .
._:._... _ _ . . . . . - - ~~ ~ - - - - - - - - " ' * " ~ ~ -
205FF DRAFT /db NR Report E-2191 which states he confirmed there was no heat number for the consumeable insert by looking at the original copy (gold copy) of the rod slip on November 2,1979.7-
~
D. Field Observations Based on the aforementioned interviews and record reviews it was found that NR E-2191, Rev. I was improperly dispositioned with d'*'
review of the disposition by members of the Kaiser Materials Review Board.
E. Acceptance Criteria Kaiser Procedure QACHI.G-4 Revision 6 dated No,vember 14, 1979 _.
4 6
ge e
1s >
0
-- - . - - - - - - ~. ~ - - - . . . - - ...- -... - .- .
T II-I. INVESTICATION t' ' ' '" # " ' # '
4 rg A. Background levest.iration Information *-
- ~
On February 23,1981, .'$nspector James R$he's, initiated three NR's which were assigned Control Nos. 5476, 5477, 5479 these NR'swese'reportednonconformingconditionsonkryweld. Support
- . o . -
$ teel in the Primary Containment Building. Louise stated the-welds on-the Nos. 63, 58, and 3 were full penetration welds which required 100% coverage by nondestructive examination e ther radiography, magnetic particle testing, or 3,1trasonic testing. He also found that on all three beams there was no documentation of heat numbers for the backing strip,or filler metal used to make the weld.and no evidence of welder quali-
~
fications or welding procedure used. The Ki::er NR Log shows that NR Nos. 5477, and 5479, were voided as "NR 1Anissued" on February 27, 1981. No copy of these NR's was retained in the ie e.
Keiser STC files. A copy of NR's CN 5476, 5477, and 5479 are apperided to this report as exhibit (3i ),('. ) , ( */ *. ).
i.B. Personal Interviews t' .-
,. On February 25, 1981, James Reyes, QC Inspector, Keiser, was o o, s.. . . .
, interviewed and stated the Keiser QA Manager was arbortraly voiding NR'c and he had no assurance that NR's he initiated would'be entered into the Keiser nonconformance reporting system and nonconforming conditions he identified on these I ~
NR's would be corrected. Louise provided the NRC with NR's 9
k
. ._ m u , :_ _ ..__; ._._.___.:._ a __...___._._.. _ . - ~ - _ . - - -
Ih'V000 - T DRATT/so CN 547T6, 5477, and 5479 and stated these had been initiated Y
I l by him on February 23, 1981, but he did not think it-would ~
be processed properly in the nonconformance reporting System.
.L6,uise provided a written statement attesting to th'e informa-
~
tion, a copy of which is attached as Exhibit ( '// ).
j; _, ..
On June 10, 1981, DennisDonovan,QCInspector,X$iser,was
- f. ti interviewed and stated that he reviewed nonconformance report-( g. ,$ p .. , .:
Nos. 5476, 5477, and 5479 and concurred the inspector Reyes
' I . . ' .'
initiation of this NR'i Donovan stated Reyes errored in his identification of one deficency on these NR's, because appar-ently a Design Document Change (DDC) had been written by the licensee's architect engineer Sargent and Lundy, Inc. which is-
- t.. ..
elimated the NDE. coverage on these beams. Donovan whoever, __
questioned S&L's waSer of this requirement and said it was contrary to S&L's Specification H2174 which' requires 100%
nondestructive examination coverage on all Class 1 welds) and these particular welds were identified on the drawing >
- a Class I welds. Donovan stated, he reviewed the DDC in
! question and found out that S&L waved the nondestruction r .-
examination coverage who are " ease of construction." He said in his opinion this was not adequate justification to
~
waver the NDE coverage. on these beaos. Donovan advised that Keiser construction department is partly repairing these and other kenleaver beams in the primary contaniment building.
e ,e On June 10, 1981, Rex Baker, Inspection Supervisor, Keiser, was interviewed and stated thet on February 23,1981,. Inspector
~
- ~ ~
DRAN -- .
. ..- -- - .- - ...-. =- - - - - ~ ~ ~~
IhT000 - T DRATT/so
- I. .c- t ,1,. ~.*..~s',
r James Reyes, identified nonconforming welds on some kenleaver beams located in the primary containment building. -Baker I
I. s o -
- stated 4teyel initiated and he concurred in the initiation of i
- . ;o:
NR Nos. 5476, 5477, and 5479. Baker stated Louise documented nonconforming conditions such as no nondestructive examination
. ..> I of whole pentrations welds,and lack of material traceabilty and
. ,.- ){. , , i ~ , v.
welder qualifications. Baker stated that- on February 27, 1981, he voided these NR's with the comment "N3 no issued." He stated
.,, ff,; . so r.; , . . : I he voided these NR's after a meeting with Phillip Gittings in 1
' February- 1984, in which he, Gittings, Kenneth Shinkle, QACli, and Robert Marshall,. construction manager discussed the nonconform-
~
ingconditionsidentifiedbyLouiN[*andMarshallstatedthat ,
i.N. '! . i*r: -
the welds on these kenleaver beams were to be cut out by Keiser r- ,.
so this days nonconformance report should be voided. Baker statchlonGittingsinstructionshevoidedtheseNR'sandgave all four of the original copies of the NR's to Phillip Gittings.
i l
l l
[
d.
h y * - . . -
_ .... ~... _ . _. _ . . _ _ . . . _ _ _ . _ . -__ . _ _
IhT000 - F DRAFT /so
.., . . N !!
_ _ . , . _ . . ._, l On June II, 1981, Kenneth Shinkle, Mechanical Civil Structual,
.~
Qualt-iy Engineer, Ke,iser, was interviewed and stated-on February 23 f' *
. : C it .. <
QC inspector James Reyes, initiated NR control-Nos. 4956, 467, and 4959. Shinkle stated he reviewed these nonconformance NR's I.
and found that inspector Louise had errored in identification 7: . . ,
of one nonconforming condition on the'NR's. He stated that a DDC had been issued by licensee's architect engineers Sargent c.P is.)
and Lundy, Inc. which waved NDE requirements for the noncon-
/- /.1.
forming beams identified by Louise. Shinkle stated whoever, that he questionthe justification for this DDC becaused' the
. ;. ..p-text of the DDC said "for use:of construction," NDE is waved.
Shinkle said that-theser the welds, identified do the NR's are Class I welds because they are 'iiabeded to the containment liner i:.u.
plateandnormallyS&LspecificationsandAS8ENuclearCode .,
requirements require 100% NDE for any Class I welds. Shinkle
- 1. ' . . :
stated Louise errored in identifying this one condition; however, the remaining nonconforming conditions such as lack of material traceability.and welder qualifications for these welds was
' /.
correct and L' oui 1se for the most part was not in error in this
.i. . n! ,
NR. Shinkle advised that the kenleaver beams in question, hold up walkways, pipe support hanger, and heating and ventiliation ducts in the primary containment building.
~ * .: . > -
Shinkle stated in February 1981, he attended:with Rex Baker, PhillipGittings,andRobertMarshall,' construction $uperintendent,
~ .
reguarding Louise NR's. Shinkle stated that Marshall wanted to repair the beams on a case-by-case basis jand merely wanted to do a visiualinspectionoftheweldtosee'ifitw -
OR -
. _ _ _ _ ..I ._ -- --- --
' ~ '"
IhT000 - F DRAFT /so stated that the QA manager, Phillip Gittings, agreed with this and told him to work with the construction department and
,.. .... , r . r. j, ; ,
rework the welds using KE-1 repair cards < and also told Rex Baker not to process the NR's written by# ray'es . Shinkle stated to the best of knowledge the n,.2. onconformances written by Reyes were
- u. ,?. ~2 never entered into the Kiiser nonconformance reporting system,
'he stated this was specially significant in light of the fact
- e'
-in February 1981, there was an NRC investigation onsite into the-irregularies in the Ke#iser nonconformance reporting system.
Shinkle stated after Gittings directed him to resolve the is r. 's.
issues'.in Louises NR he conducted an inspection of all the
(, . .
kenleaver beams located at the 572' elevation of the primary containment building. Shinkle stated that he found that of the 27 beams there was no final QC inspection on any of them3and four of the 27 beams had no evidence of any fitup inspection.
Shinkle stated he also found the same nonconforming conditions, lack of material traceability for weld filler metal,.and backing strips, and'1ack of evidence of any welder qualifications of '*{
these selds. In addition Shinkle stated he conducted a vislual examination of the welds and although they were painted over in many cases.the welds did not appear to meet code standards.
Shinkle stated he advised Robert Marshall of this situtation
,, and Marshall stated he did not want to repair the nonconforming conditions because sinc +-4he elde had first been a de addifica-tions'had been made to the beams in which **- plates had been added ttrthe side and these plates would have to be reinoved in order to conduct Nspections of.the welds. Shinkle advised F "4.>
5- ,
, , , _ , ,__ ,.m .
mw= c* ' * * - ~~~
IhT000 - T DRATT/so that at this time the construction department is in the process of removing the questioned beams from the primary containment o
building. *-
~
- c. Record Reviews On June 6, 1981, Regina Rudd, Keiser NR Controler, was contacted and asked to retrieve NR, CN 5476, 5477, and 5479 from the Kaiser Site Document Control Center. Rudd stated that she conducted a file search of the open, closed, and voided nonconformance reports and could not locate the nonconformance reports assigned these numbers. Rudd provided a copy of the NR log page which reflects that on February 27, 1981, NR's 5477, 5478, and 5479 were voided with a comment "NR not issued.'.' A copy of the NR log page is appended to _.
this report as a exhibit (42).
- d. Field Observatiens NR's CN 5477, 5478 and 5479 were not entered into the Kaiser nonconformance reporting system.
- e. Acceptance Criteria Kaiser Procedure QACMI G-4, Revision dated 1981.
m
. :_ a.. - --
. ~ < . ~
(f@)Q $t)){D
- CHRONOLOGICAL INDEX OF KEI NR .-
VOIDED BY MONTH AND YEAR e.
1978 1979 1980 1981 3anuary 17 46 49 8 February 14 27 46 5 March 12- 27 41 4 Aprii 11 30 19 May 26 19 27 June 19 19 13 July' 16 38 22 August 27 52 9 September 47 29 19 October 46 . 18 20 November 31 73 25 December 21 62 7 i
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GOOD AFTERNGON FIRST SLIDE -- WHAT I PLAN TO COVER If; THIS PRESEiTATION IS A SU:ii%RY DISCUSSION OF THE OVERALL INVESTIGATION TO DATE AND THE INVESTIGATI0i; FINDINGS, OUR PLA!!S FOR ENFORCEMEllT ACTION, 00R PLANS FOR RELEASIt:5 THE INVESTIGATION REPORT: AND OUR PLA!; lied FUTURE ACTIONS, BEFORE M3 VINS AHEAD, I'D LIKE TO GIVE YOU A QUICK CAPSULE LOOK OF O'JR P;SITIO: ON THE FIRST TWO 0F THESE ITE:iS S0 THAT YOU'LL KNOW THE DIf,ECTIO:' WE'RE C0.'ilNG FROM.
- 1. WITH RESPECT TO THE INVESTIGATION,'THIS HAS BEEN A liAJOR EFFORT; 0::I THAT IS STILL ONG0ING: AND HAS INVOLVED CONSILERAELE RESOURCES, tie BOTT0il LINE OF THE INVESTIGATI0fl IS THAT THEFE 1lET,E luJOR PR3LLEIS l!ITH THE OVERALL QUALITY ASSURANCE PROGRA'i, ACTIO!1 HAS BEE!; TAKEN TO CORRECT THESE PROBLEMS AND PRECLUDE THEIi RECL'RREl;CE,
' LIMITE] INDEPENDENT !1EASUREFENTS CCllDUCTED BY NRC SUGGEST WIDESPREAD HARDWARE PROBLEMS MAY NOT HAVE OCCURRED AS A P.I THE QUALITY ASS'JRANCE PROGRAi BREAKDOWN. HOWEVER, BEC/,J^E 3 THE HATg'RE OF THE PROGRAMTMTIC DEFICIENCIES IDENTIFIED, WE .
REQUIPJM All EXTENSIVE QUALITY CONFIR:% TION PROGRAM TO DI CONDUCTED BY THE LICEtiSEE TO ESTADLISI: THE QUALITY OF SYSTEM AND COMPONE!!TS IfiPORTANT TO SAFETY.
_ L .- .- . . . . - .-. . -
2 p IN DISCUSSING THIS INVESTIGATION, I'D LIKE TO TIE IN SOME PERTINENT BACKGROUND INFORMATION. iiR. APPLEGATE'S INVOLVEMENT WITH THE ZIMER PROJECT STARTED BACK IN LATE 1979. AT THAT TI'I, MR. APPLEGATE WAS WORKING AS A PRIVATE INVESTIGATOR'FOR AN INVESTIGATION SERVICE.
WHILE WORKING ON A DIV0RCE CASE, HE FOUND THAT ONE OF THE INDIVIDUALS WAS EMPLOYED AT Zli1MER AND WAS INVOLVED IN TI?ICARD CHEATING. HE APPROACHED HIS EMPLOYER AND CINCINNATI GAS AND ELECTRIC COMPANY WITH THIS INFORMATION AND THE INVESTIGATION SERVI,CE WAS AWARDED A 30 DAY CONTRACT TO INVESTIGATE TIMECARD CHEATING AT THE SITE. THIS EFFORT WAS COMPLETED WITHIN A COUPLE OF WEEKS AND APPLEGATE BEGAN TO PURSUE RUMORS OF IMPROPER SITE CONSTRUCTION. CG3E, WHEN TOLD OF THE INF0F01ATI0h GATHERED BY APPLEGATE, I!CICATED THEY WERE AWARE OF HIS FINDINGS, alt 6
0UR FIRST CONTACT, WITH MR APPLEGATE OCCURRED ON FEBRUARY 23, 1980, AND WE INTERVIEWED HIM IN PERSON Ofl MARCH 3. HE PROVIDED A NUMBER OF ALLEGATI0flS, SEVERAL OF WHICH DID NOT RELATE TO ACTIVITIES WITHIN NRC JURISDICTION. A LETTER WAS SENT TO APPLEGATE ON MARCH 11 DETAILING THREE ALLEGATIONS TilAT WERE CONSIDERED APPROPRIATE FOR INVESTIGATION BY f!RC AND THE INVESTIGATI0ti 0F THESE ALLEGATIONS TOOK PLACE IN APRIL AND'MAY OF 1930 AND THE INVESTIGATION PIPORT WAS ISSUED ON JULY 2, 1980.
THE INVESTIGATION FINDD'GS WERE NOT VIEWED AS SIGilIFICANT FRO.'1 A l PUELIC HEALTH AND SAFETY STANDPCINT.
THE tiEXT KEY POINT IN THE CHRONOLOGY OCCURRED ON NOVEMBER 13, 1900, WHEN A FORF.ER QC INSPECTOR AT ZIM,'1ER, WORKliiG AT ANOTHER CONSTRUCTION SITE, MADE ALLEGATIONS TO OUR RESIDENT INSPECTOR CONCERNIf!G THE ADEQUACY-
- _m _ _ . _ _ . . _ . . __ . _ _ . _ . .
-3 0F THE QUALITY ASSURANCE PROGRAM AT ZIliliER. HE STATED THAT THE 0A MANAGER FOR THE CONSTRUCTOR, KAISER ENGINEERS,WAS IMPROPERLY HANDLING NONCONFORMANCE REPORTS, TRANSFERRING QC INSPECTORS WHEN THEY FOUND T00 MANY PROBLEMS, ALLOWING IMPROPER QC INSPECTIONS, AND NOT PROPERLY SUPPORTING THE QC STAFF. WE CONTACTED THE ALLEGER BY TELEPHONE ON
-DECEMBER 9, DUT BECAUSE OF SCHEDULING CONFLICTS, THE ONSITE INVESTICATION WAS NOT STARTED UNTIL AFTER THE HOLIDAY SEASON.
g 4974.nf INVESTIGATION WAS INITIATED, THE GOVERNMENT ACCOUNTA-BEFORE IM-BILITY PROJECT SENT A LETTER TO THE MERIT SYSTEMS PROTECTI0i! BOARD ALLEGING THAT THE EARLIER IfiVESTIGATION OF APPLEGATE'S ALLEGATI0fS BY NRC WAS NEGLIGENT AliD PROVIDED A NUMBER OF NEW ALLEGATIONS C0tlCERNING ZIMMER. IT WAS DECIDED THAT OIA WOULD INVESTIGATE THE ADEQUACY OF THE EARLIER REGION III INVESTIGATION AND THAT REGION III WOULD PURSUE THE NEW ALLEGATI0ils ALONG WITH THE OTHER ALLEGATIONS THAT HAD BEEN RECEIVED.
THE ONSITE INVESTIGATI0f! COMMENCED ON JANUARY 12, 1981'. DURING THE COURSE OF THIS INVESTIGATION, A NUM3ER OF OTHER ALLEGATIONS WERE BROUGHT FORTH BY CONTRACTOR WORKERS AND FORMER C0t!STRUCTION WORKERS.
THEINVESTIGATIONEFFORT!WHICHISSTILLONG0ING,HASTHUSFARRESUiTED
- IN THE EXPENDITURE OF APPR0XIMATELY 350 NRC INSPECTOR A!!D CONSULTAtiT I MANDAYS ONSITE,' INTERVIEWS OF OVER 90 INDIVIDUALS, AND BETTER THAN l 700 MANDAYS OF NRC INSPECTOR AND SUPERVISORY TIME I!! Tile EVALUATION AND DOCUMENTATION OF THIS INVESTIGATION, BECAUSE OF THE CRITICISM LEVIED AGAINST THE FIRST INVESTIGATION, MANY OF THE ALLEGATIONS HAVING
4 LITTLE OR NO SAFETY SIGNIFICANCE WERE EXPLORED IN DETAIL RATHER THAf!
BEING DISMISSED DUE TO LACK OF SAFETY SIGlilFICANCE. ALTHOUGH SOME ALLEGATIONS REIMIN TO BE INVESTIGATED, WE'VE CHOSEN TO ISSUE A REPORT AT THIS TIME BECAUSE OF THE CONTINUING PUBLIC IllTEREST IN THE MATTER AND BECAUSE WE FEEL WE'VE IDENTIFIED AND DEALT WITH THE MORE SIGilIFI-CAtlT FROBLEM AREAS.
THE INVESTIGATION EFFORT DURING JAtlUARY THROUGH flARCH IDENTIFIED A NUMBER OF QUALITY ASSURANCE PROBLEMS AT ZIt' DER. THE MAJORITY OF THE PROBLEMS FOCUSSED 03 THE INEFFECTIVENESS OF C0f;TROLS IMPLEMENTED BY THELICEl{SEgA,NDITSCONTRACTORSFORASSURINGTHEQUALITYOFWORK PERFORMED.' Ifi THAT REGARD, fluMEROUS DEFICIENCIES WERE FOUND CONCERNIN3 QUALITY RECORDS: TRACEABILITY OF MATERIALS: HANDLING 0F N0tCONFORNANCES:
INTERFACE BETWEEN CONSTRUCTI0fl AND QUALITY CONTROL: AND THE LICENSEE'S OVERVIEW 0F ONG0ING WORK. ALTHOUGH MANY OF THE ALLEGATIONS MACE BY APPLEGATE WERE SUBSTANTIATED, THE MAJORITY OF THE SIGNIFICAflT GUALITY ASSURANCE DEFICIENCIES WERE IDENTIFIED AS A RESULT OF THE ALLEGATIONS MADE BY THE EX-0C IflSPECTOR, ALLEGATIONS MADE BY OTHER WORKERS AND EX-WORKERS CONTACTED DURING THE COURSE OF THE INVESTIGATION AND OUR PURSUIT OF THESE ALLEGATIONS.
BASEDONTHEIllVESTIGATIONFIllDIlg SIDERA Oil WAS GIVEN TO THE )
! HOWEVER, RECOGNIZING THAT
[ftE5DTOSUSPENDCONSTRUCTIONACTIVITIES.
! ' THE PROJECT WAS BETTER THAN 95: COMPLETE AND THAT THE NATURE OF THE i ! .,
i REMAINING WORK WOULD NOT COMPROMISE THE ABILITY TO DETERMINE THE huALITY OF COMPLETED WORK, IT WAS CONC.LUDED THAT T .
DIDNOTMERITHALTINGCONSTRUCTI0tl(RATHERyATTENTIONWASPLACEDON 1
1
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ESTABLISHIN3 CONTROLS TO ASSURE THE QUALITY OF ONGOING AND FUTURE WORK AND TO DEFINE A PROGRA'1 TO BOTH CONFIPJ1 THE QUALITY OF COMPLETED WORK
! AND CORRECT ANY IDENTIFIED DEFICIENCIES.
s&" .
FOLLOWING A MEETING WITH US ON MARCH 31, 1981, THE UTILITY IMPLE1 ENTE:
SEVERAL ACTIONS TO CORRECT IDENTIFIED QUALITY ASSURANCE WEAKNESSES AND TO PRECLUDE THEIR RECURRENCE. THESE ACTIONS RESULTED Ifi KEY f, 11ANAGERIAL CHANGES IN THE LICENSEE'S AND KAISER'S ORGANIZATIONS; AN j INCREASE OF FROM 6 TO 135 PERSONS ON CG&E'S QUALITY ASSURANCE STAFF; A 100.1 DUPLICATION OF CONTRACTOR QC INSPECTIONS BY CGSE; AND A fluMBER OF OTHER IMPROVEMENTS IN PROCEDURES AND TRAINING. FURTHER, ACTIONS WERE TAKEN BY'CGSE TO ASSURE COMPLETE' CONTROL OF ALL QUALITY RECORDS,
~
i THESE PROGRAM IMPROVEMENTS WERE CONFIR:1ED IN AN I:1:1EDIATE ACTI0il LETTER DATED APRIL 8,1981, AND SUDSEQUEliT f!RC INSPECTIONS HAVE SHOWll l THAT THE CORRECTIVE ACTIONS ARE BEING I:1PLEMENTED SATISFACTORILY.
ALTHOUGH OUR INVESTIGATION EFFORT FAILED TO IDENTIFY MAJOR HARDUARE PROBLEMS, THE IDENTIFICATION OF P00R CONST.".UCTIOil PRACTICES AND AN ?
INEFFECTIVE QUALITY ASSURANCE PROGRA'1 !1ADE IT tlECESSARY, IN OUR VIEW, THAT A MEANINGFUL QUALITY C0tlFIRMATION PROGRAM BE CONDUCTED TO VERIFY THAT SAFETY RELATED SYSTE!1S AND COMPONENTS WILL PERFORM THEIR INTENDE0 SAFETY FUNCTION. OUR VIEW AT THAT TIME WAS TO HAVE THE LICENSEE ESTABLISH A QUALITY CONFIRMATION PROGRAll THAT WE WOULD CONCUR IN, THAT I THE NRC WOULD CLOSELY FOLLOW THE I!!PLE!1ENTATIOl! 0F THAT PROGRAM, AND i
THAT THE NRC WOULD MAKE SOME INDEPENDENT MEASUREMENTS ON ITS OWN TO j PROVIDE FURTHER ASSURANCES AS TO THE QUALITY OF THE COMPLETED WORK.
i l
l 6 !
WE PROCEEDED IN Tills DIRECTION AND AT THE SAME TIl1E PROCEEDED WITH THE'DOCUi4ENTATION OF THE INVESTIGATION.
l A NUilBER OF MEETINGS TOOK PLACE BETWEEN THE NRC AND LICENSEE DURIf1G p THE NEXT COUPLE OF MONTHS IN DEVELOPING THE QUALITY CONFIPJMTION PROGRAM AND THE LICENSEE FORMALLY SUBMITTED THIS PROGRA!i ON AUGUST 21, 1981. THIS PROGRAM, WHICH FOCUSES ON THE CONCERNS IDENTIFIED BY OUR SM # INVESTIGATION, IS A MJOR EFFORT At!D IS ESTIMATED TO TAKE SEVERAL MONTHS.
IN TliE MEANTIME, AFTER SEEING A DRAFT OF OUR INVESTIGATION REPORT, MR STELLO FELT THAT SOME EFFORT SHOULD BE iMDE TO CHARACTERIZE THE SIGNIFICANCE OF THE IDENTIFIED QUALITY ASSURANCE DEFICIENCIES ON THE ACTUAL HARDWARE OF THE PLANT BEFORE RELEASING OUR REPORT. AS A RESULT, BEGINNING AUGUST 24 TilROUGH OCTOBER 5,1981, THE NRC AND ITS CONSULTANTS MADE INDEPEtiDENT MEASURE'iEf!TS IN THOSE AREAS WHERE QUALITY ASSURANCE WEAKNESSES WERE IDENTIFIED.] VERIFICATION P AND RESULTS ARE SHOWN ON THE NEXT SLIDE. THIS LIMITED PROGRAM 0F MEASUREMENTS SUGGESTS THAT WIDESPREAD CONSTRUCTION PROBLEMS DID NOT RESULT FROM THE WIDESPREAD QA PROGRAM BREAKDOWN.
ITH RESPECT TO ENFORCEMENT ACTI0f!S) AS I MENTIONED E CONSIDERATION WAS GIVEN TO THE NEED TO SUSPEND CONSTRUCTION ACTIVITIES:
7
- i. HOWEVER, WE CONCLUDED TIMT SUSPEt'SION WAS NOT APPROPRIATE AND THAT CIVIL PENALTY ACTION WAS THE BEST ENFORCEMENT ACTION._ IN ARRIVING ATs THISCONCLUSI0tf0'URTHINKINGWASTHATTHECOMMISSION'SREGULATIONS 4ROVIDE FOR PLANNED AND SYSTEfMTIC ACTIONS TO PROVIDE ADEQUATE CONFIDENCE THAT SAFETY-RELATED STRUCTURES, SYSTEMS, AND COMPONENTS WILL PERFORM
- l. . - _ _ - - - -
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I 7
SATISFACTORILY IN SERVICE. THE WIDESPREAD CA PROGRAM BREAKDOWN AT ZIMER RESULTED IN AN ABSENCE OF CONFIDENCE EVEN THOUGH SERIOUS CONSTRUCTION DEFICIENCIES HAVE NOT BEEli IDENTIFIED. IN ORDER TO EMPHASIZE THE SIGNIFICAllCE NRC ATTACHES TO SUCH BREAKDOWNS OF 9A PROGRAMS THAT HAVE A HIGH POTENTIAL FOR SERIOUS CONSTRUCTIO!! DEFIC NCIES, WE RECO.tEllD T0 HS'S A LARGE CIVIL PENALTY BE ISSUED. THIS MTTER IS PRESENTLY UNDER REVIEW BY IE:HQ'S AND ELD.
WHILE THE ENFORCEMENT ACTION IS STILL UNDER REVIEW, ONE AREA I WANT TO HIGHLIGHT TO THE COMISSION THAT OUR DRAFT PACKAGE FAI THEFACTTHATTHEFINDINGOFMISREPRESENTATIV(REC SUBSTANTIAL INCREASE I!i THE REC 0 MENDED FINE;Esi,HN THE ISSU -
WILL EMPHASIZE THIS POINT. ORIGINALLY, WE WERE NOT PLANNIlls TO TAKE CIVIL PENALTY ACTION FOR THE MISREPRESENTATIVE RECORDS BECA MATTER WAS BEING INDEPENDENTLY PURSUED BY OIA FOR POSSIBLE R ,
TO THE DEPARTMENT OF JUSTICE FOR CRIMINAL CONSIDERATI0il. HOWEVER, :
BASED ON DISCUSS 10flS WITH D0J, THEY DO NOT PLAN TO IfilTIATE ANY ACTION ON THIS CASE BEFORE WE COMPLETE OUR TOTAL INVESGITATI RELATED ENFORCEMENT ACTION. I AND THEY HAVE TOLD US THAT WHAT ACTIONS WE TAKE WILL NOT COMPROMISE ACTIONS TAKEN BY THEM.
ONE OTHER POINT I SHOULD MENTION IS THAT THE MANAGEf',ENT PEOPLE THAT CONDONED THE MISREPRESENTED RECORDS HAVE BEEN REMOVED A REORGANIZTION TO IMPROVE QA ACTIVITIES.
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C0ft11SSION BRIEFING ZIffER INVESTIGATION ;
- 1. DISCUSS INVESTIGATION AND FINDINGS 2i DISCUSS PROPOSED ENFORCEENT ACTION ;
3 DISCUSS PLANS FOR RELEASING REPORT -
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- 4. DISCUSS FUTURE ACTIONS t
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~
CHRONOLOGY FEBRUARY 28,1980 !'
INITIALAPPLEGATEALLEGATIONSRECEIVED
.l JULY 2, 1980 INVESTIGATION REPORT ISSUED i
NOVEMBER 18,1980- ALLEGATIONS FROM EX-ZittER EPPLOYEE RECEIVED ,
DECEMBER 9,1980 ALLEGER CONTACTED i-JANUARY 5, 1981 ALLEGATIONS FROM GAP /APPLEGATE AND REQUEST FROM GAP FOR ,4 MSPB TO INVESTIGATE NRC RECEIVED t r,
. JANUARY 12,1981 DNSITEINVESTIGATION~ INITIATED
. APRIL 8, 1981 IlfEDIATE ACTION LETTER ISSIED ll AUGUST 21,1981 LICENSEEQCPF5RMALLYSUBMITTED d t j AUGUST 2'i, 1981 NRC INDEPENDENT VERIFICATION PROGRAM INITIATED ll
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PROEIFMS IDENTIFIED FROM GAP /APPLEGATE M
INADEQUATE RADIOGRAPHY OF PREFABRICATED PIPE WELDS.J INADEQUATE INSPECTION OF CABE TRAY HAf!GER W UNACCEPTABLE CABLE TRAY HANGER WELDS VA q
. AM INADEQUATE AR DESIGN CONTROLS (R) 4# >J W
FROM EX-EMPLOYEE INADEQUATE TRACEABILITY OF PIPE (R) P*
. IMPROPER VOIDING OF NRs (R)
UNDESIRABLE INTERFACE BETWEEN CONSTRUCTIO #
QUESTIONABLE QUALITY OF SMALL BORE PIPE WELDS 3#
FROM PAST AND CURRENT SITE INSPECTORS l
l HARASSMENT OF QC INSPECTORS fM
- i#j;d IMPROPERLY DELETED WELD INSPECTION CRITERIA (R)
IMPROPER USE OF SURVEILLANCE REPORTS (R) LJ#'
V is FROM NRC INSPECTORS UNACCEPTABLE WELDS ON NINE HANGER BEAMS kj/ y I
UNACCEPTABLE (NOTCHED) RE-ENTRANT CORNERS ON FIVE UNSPECIFIED HANGER BEAliS (FOUR) INSTALLED -E TRACEABILITY OF NINE HANGER BEAMS NOT MAINTAINED -
VIOLATION OF CABLE SEPARATION CRITERIA AT.FOUR LO INADEQUATE CGaE AUDITS OF SARGENT & LUNDY .
O
- e s .os ..+ e em - re+eem e mo sm_ = o -*.e -u -w ~ m
-l i; . IffEDIATE ACTION LETTER ,
PURPOSE: 4 4 ,
. . , CONTROLONGOING.ANDFUTUREWORK
- d. .
itAJOR-LICENSEE ACTIONS:
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"p,emMq
, CHANGED KEY MANAGEfENT -
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~
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INCREASED SIZE AND TECHNICAL EXPERTISE OF LICENSEE QA STAFF (6 TO 135)
, 100% DUPLICATION OF CONTRACTOR QC INSPECTIONS
, FULL CONTROL OF RECORDS BY LICENSEE
,. j u NRC FOLLOWUP FINDINGS:
tj ' ' "
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, iOUALITY OF ONGolNG WORK IS ACCEPTABLE -
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. LICENSEE ComITENTS BEING ET u
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- QUALITY CONFIRHATION PROGRAM * -
- PURPOSE
~
DETERMINE THE QUALITY OF PAST CONSTRUCTION BY CONFIRMING.
QUALITY 0F.PIPEMATERIAL
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PROPER DISPOSITION OF NONCONFORMING ITEMS j
p,
. QUALITY OF PIPE WELDS I-
. QUAllTY OF STRUCTURAL STEEL MATERIAL AND WELDS
.; 4
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l
. ADEQUACY'0F ELECTRICAL CABLE SEPARATION
. ADEQUACY OF A N ELECTRICAL DESIGN CONTROLS ADEQUACY OF CONTROL OF DESIGN CHANGES ,
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ADEQUACY OF SUBCONTRACTOR QA PROGRAMS -
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ADEQUACY OF PAST AUDITS g
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- THIS PROGRAM WILL BE EXPANDED SHOULD THE LICENSEE IDENTIFY SIGNIFICANT PROBLEMS jj DURING CONDUCT OF THE QCP OR SHOULD THE NRC IDENTIFY PROBEMS IN THE REMAININ W INVESTIGATION AND INSPECTION EFFORTS.
i - _ . . . __ . - - - _ _ _ _ _ _ _ _
~~ ~
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URC INDEPEi4 DENT VERIFICATION P'JRPOSE: . PROVIDE C3iiFIDEilCE II; PLA:!T QUALITY
, PROVIDE PERSPECTIVE OF CA BREAKDOWl; VERIFICATI0ilS PERF0PJiED:
IflSPECTED HARDWARE RELATED TO 24 VOIDED NRs PERF0?J1ED l1ETALLURGICAL AMALYSES OF SIX WELDS PERFOR'1ED METALLURGICAL AllALYSES OF SIX PIPES PERFORMED LABORATORY ANALYSES OF TWO MISMATCHED WELDS TESTED 70 PIPE WELDS FOR HARDNESS AllD THICKNESS VISUALLY EXAlilNED E9 PIPE WELDS 7 RADIOGRAPHED 60. PIPE WELDS
. DYE PENETRANT TESTED 42 PIPE WELDS ULTRASONICALLY EXAMINED 21 PIPE WELD L TESTED 53 BEAMS FOR HARDNESS A!!D FITUP VISUALLY IIlSPECTED 380 EEA*1 WELDS I!!SPECTED ADDITIONAL AREAS FOR CABLE SEPARATI0l1 flRC FINDINGS: -
10 CASES OF WELD DEFECTS AND DIMENSIONAL PROBLEMS ~"
& ,co ,~Mug4 HANGERS UNACCEPTABLY INSTALLED
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4 g g. .
4 CABLE SEPARATION PROBLEllS
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POSSIBLE PROBLE!1 WITH '. ELDS OF l11SMATCHED PIPE PRElli11 NARY C0t'CLUSION:
NO WIDESPREAD C0!iSTRUCTI0li PROBLEMS e o r= 'g l O A L = 02~~-
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- l r ,
, PLANS FOR RElFASING REPORT __ -
1
. ON DAY BEFORE RELEASE ,- '
a
!i . PROVIDE REPORT T xLICENS '
l O . \ I f,
. PROVIDE REPORT TO O SIGHT COMMITTEES 1
., PROVIDE REPORT TO ENATOR GLENN AND ETZENBAUM u ,. PROVIDE REPORT TO D0J j
. ON DAY OF RELEASE / - -
9 .
!! ,' EET WITH LICENSEE
!! , BRIEF GAP ii
)! . HOLD PRESS CONFERENCE t
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4 FUTURE ACTIONS .
COMPLETE INVESTIGATION EVALUATE RESULTS OF LICENSEE'S QUALITY CONFIRMATION PROGRAM EVALUATE N *si FOR MORE NRC INDEPENDENT
, MEASUREMENTS i
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- \ UNITED STATES fj-[j NUCLEAR REGULATORY COMMISSION
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5.....# October 28,1981
)
l MEMORANDUM FOR: Victor Stello, Jr. , Director '
Office of Inspection and Enforcement FROM: James G. Keppler, Director Region III SJBJECT: ZIm ER COMMISSION MEETING - OCTOBER 27, 1981 At yesterday's Comission meeting, Comissioner Ahearne questioned why the Region III investigation of the Zimmer allegations did not include taking a signed statement from Mr. Gittings, fomer Kaiser QA Manager. We were unable to answer the question at the meeting and we indicated we would get back to Comissioner Ahearne with an answer on this matter. Pertinent infomation obtained from our Investigator, Mr. McCarten, is provided below:
- 1. From the beginning of the investigation there was a fairly close working
. relationship between Region III and OIA because of the alleged falsification of records. In IE's investigation, the decision not to interview senior Kaiser and licensee personnel who may have been connected with these records, let alone obtain signed statements from them, was based on l instructions received from OIA (Messrs Puglia and Gamble). This decision applied to Messrs Marshall, Oltz, and Schwiers---as well as Mr. Gittings.
l 2. Following discussions with the U. S. Attorney who was interested in the case, OIA representatives (Sinclair and Puglia), in the conduct of their investigation of potential criminal issues, interviewed Messrs Oltz and Gittings in June and July 1981. Mr. McCarten participated in the inter-views. The interview with Mr. Oltz was taped; however, the interview with Mr. Gittings was not taped (a decision made by OIA).
- 3. As far as we know, OIA interviews with Messrs Marshall and Schwiers have not yet been conducted.
. Qf , ^e -
James G. Kepp9 e , Director '
Region III l
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Chronologv OIA Involvement in Zimmer Inven !gation 1/12/81 Start Investigation Onsite 3/12-16/S1 McCarten and Schapker Onsite
~
1/13/81 Interviewed Gittings and Schwiers 1/14/81 Interviewed Oltz .
1/15/81 Interviewed Marshall and Gittings 1/16/81 Interviewed Schwiers 1/26-30/81 McCarcen to Marble Hill and Perry - Interview seven former QC inspectors Barrett at Zimmer 2/3/81 Davis, Streeter, Warnick, McCarten Barrett phone call with Bernard Gilday, Assistant U. S. Attorney in Cincinnati - Applegate allegation about Drunks, etc. and jurisdiction, interest by FBI and Attorney's Office.
2/9-13/81 Onsite investigation - Region III Team 2/13/81 Discussion with Schwiers on NR improvement 2/17-20/81 Onsite investigation - Region III Team 2/17/81 Cu=mings in Region III to talk about Applegate investigation 2/23-27/81 Onsite investigation - Region III Team 2/25/81 Interviewed Oltz Telephone call - Davis with Dave Everett on Applegate meeting of 26th.
Pre-Applegate meeting with RIII staff and Art Schnebelen l
l 2/26/81 Meeting in Region III with GAP /Applegate, Art Schnebelen
- (OIA), Gilbert (HQ), Region III people.
, Informal discussions by McCarten with Schnebelen about l voided NRs and NR log.
3/3/81 Davis called David Everett, DOJ, giving him results of l GAP /Applegate meeting, t
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3/9-13/81 Onsite investigation - Region III Team ,
3/23/81 Discussion with Schwiers on NR improvement ",
3'/23-27/81 Region III Team Onsite 3/25/81 Gittings interviewed on QA staffing Week of 3/30/81 Sinclair and Camble in Region III to discuss current
' investigation. They expressed concern to Keppler .
that some of the team members were not sufficiently sensitive to falsification of records.
i McCarten believes 3/30/81 is the date he discussed i
parallel proceedings with Gamble and he was instructed to not interview Oltz, Schwiers, Gittings, and Marshall.
4/9/81 Sniazek, Lieber=an, Henderson in Region III to be briefed on investigation findings.
4/17/81, Brief David Upchurch (FBI - Cincinnati Office) on Applegate Issues. Told we are investigating falsification and CIA would be doing it.
l 4/22/81 Meeting in Cincinnati with B. Cilday D. Everett, J. Sinclair, and J. McCarten to discuss falsification issues (NRs, material traceability). Sinclair indicated he would discuss outcome of meeting with Cummings. Everett proposed joint investigation by II and OIA. Everett wanted to be briefed on results of investigation. Sinclair didn't think we would do joint investigation.
I April - May Conference calls between Cummings office, D. Everett, and representatives of U. S. Attorney's Office in Cincinnati.
5/5/81 Cn==ings called B. Davis to discuss parallel proceedings.
(Same subject as April - May conference calls above.)
Cummings said he was not directing Region III in any way about this issue of what to tell the licensee.
(Whether or not we will use incriminal proceedings the information obtained during the investigaion.)
Cummings offered assistance but felt IE:BQ would decline offer. -
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- Art .nnebelen called Davis and said A would participate 5/6/S1 s in criminal aspects of investigation. ,
5/15/81 Cummings called Davis about parallel proceedings 5/20/81 Joint 01A (Sinclair) and IE (Ted Gilbert) interview of Ricky Cantrell in San Onofre, California.
5/22/81 Stello in RIII to be briefed on investigation findings.
Gamble also in RIII.
5/26/81 Memo from DOJ:HQ to Cummings resolving parallel proceedings issue. If they ask, we should tell them but we don't have to volunteer the information.
5/26-28/81 OIA in Region III to interview Region III personnel about current Zimmer investigation.
6/1/81 Memo from Cummings to Stello advising of DOJ position on parallel proceedings. .
6/2-5/81 Barrett, McCarten. Schapker, Gamble and Puglia are onsite at Zimmer.
6/4/81 Interviewed Oltz and taped - Gamble. Puglia, and McCarten.
l 6/8-9/81 Cummings, Sinclair, Gamble, Puglia interviewed McCarten l about the investigation findings at Holiday Inn in Florence, Kentucky.
6/10/81 Cummings, Sinclair, Gamble, Puglia, and McCarten onsite at Zimmer.
OIA interviewed Setlock about facts of Phillip investigation of Applegate allegations (WR-K-811) 6/11/81 Sinclair, Gamble, Puglia onsite.
6/15/81 Cummings called Bert Davis and discussed recent OIA interviews and matters CIA considers significant relative to Zimmer investigation.
6/19/81 OIA sends transcript of Oltz interview of 6/4/81.
7/7-8/81 Sinclair, Puglia, and McCarten onsite. Sinclair directed interview not taped. Neither 01A nor IE took statements (each investigator independently decided not to take a statement).
7/8/81 Sinclair, Puglia, and McCarten interviewed Gittings. L Interview led by Sinclair.
7/17/81 Aherne in RIII and was briefed on investigation findfngs. -
1 8/4/81 Foster meno on report content and lack of statements by i Marshall, Schwiers, and Gittings. Memo was discussed I
with Keppler and Davis.
i
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ar-s-eaa WR-K-516
',. (WR-K-82 7)
(WR-K-917) i WR-K-811' and WR-K-827 were welds on the Auxiliary Building Closed Cooling Water syste:.
- Weld WR-K-516 on the same line, is still in existance. Weld K-811 was located in the I
g Auxiliary building at elevation 572". The line is 4 inches. in diameter (weld was 12.56 inches of weld metal)
Design conditions for this 'line are 120 osie and 105 degrees F. Maximum operating conditio-are 150 psig and 125 degrees F. The line is S&L piping class C (final visual inspection only, not normally radiographed).
CHRONOLOGY 8/77 approvals for WR-K-516
- 11/8/77 consumable insert placement & tack weld WR-K-516
- 11/9/77 WR-K-516 welded, ANI waiver on hold point 1/29/80 K-811 weld fitup 1/30/79 K-811 visual inspection of final pass -accept.
10/79 inspector Setlock assisting with documentation location & correction 10/11/79 NR-E-2138(RO) K-811 and K-516, believe missed ANI holdpoint disposition: RT, Accept if RT acceptable.
11/6/79 RT of weld K-516 per NR -F-2138 11/6/79 probable date of RT of K-811, radiography not retained. Reject. (RT done twice).
11/8/79 RT of K-516 rejected for unconsumed insert, other defects.
12/3/79 NR-E-2260, RT of K-811 shows adjacent veld K-827 unacceptable, unconsumed inser:
i disposition: replace pup piece,"see related NR-2138".
12/14/79 NR-E-2138 " voided"(actually superceded),. ."see rev 1". Probable,date, Rev1.
12/27/79 Steve tells Applegate K-811,"MSR pipe" has " insert fault".
1/7/89 speed memo, Ruiz to Pallon: K-516 no KEI-1, RT reject.
1/7 /89 NR-E-2138 Rev 1, (see related NR-E-2260).
1/14/8D approvals on NR-E-2138 Rev 1 (weld K-516 not mentioned).
1/16/8 9 approval on KEI-1 for velds K-916, K-917.
1/18/80 K-916 fitup and weld 1/24/80 K-916 visual inspection and acceptance.
1/22/80 NR-E-2138R1 closed.
1/24/80 NR-E-2260 closed.
3/3*/80 Applegate interviewed by Phillip 4/7-9/80 Phillip on site, i
CCMMENTS According to Inspector Seg1cek, Floyd Oltz asked him to locate the KEI-1 forms for K-511 and K-516. He could not igate them, and found that the ANI had listed hold points on i the fit-up for welds on the line. The Ani had no notation to indicate that he had vaived the holdpoints for these welds. NR-E-2138 was written to document missing the holdpoints.
Setlock was not aware that the IEI-1 form for K-516 had been located, or that the ANI had 1
waived the hold point' on fit-up inspection for K0516. He indicated that he first learned of this information on approximately 8/15/81 when he was shown the KEI-1 form. He indicati <
that the form and ANI gaiver are genuine.
- He also stated that he was not aware of NR-E-2260 nor of Revision 1 to NR-E-2138. He now understands the sequence of events (new disposition needed for NR-E-2138RO) and does not see anything wrong with actions taken. He does feel that he should have been advised of the revision to NR E-2138, and that the dates of the origional and revision might have been shown. ,
It appears that at some tica the KEI-1 form for WR-K-516 was found, and the ANI waiver j discovered.
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RT of K-811 coutu we6 v. found, and RT of re=oved welds need not be retained. It is ver/
' *< possible that K-811 had a partially consumed insert, as K-827 had, and K-516 has this condition. This would explain why " Steve" cold Applegate of an " insert fault" in weld K-811. K-811 and the other welds had been accepted, and would not esperde ace further revies
, as RT or RT review would not normally take place on these welds.
If a weld is not snarcs. 6u RT, certain defects are considered acceptable, and must be assumed to exist. It is illigical to have a single veld meeting ASME III in the midst of a system when the other velds are not of this quality. The licensee has indicated that removal of K-516 is planned, based on the unacceptable RT of the veld. This decision must be viewed as at their decision, as there is no Code requirement for this action.
1 Both the origional NR-E-2138(RO) and the subsequent revision 1 indicate d that weld K-811 was velded on 11/9/77. Apparently, this date transposition (K-811 and K-516) was an error that was made by inspector Seticek when NR-8-2138 was draf ted. The error was carried to the subsequent revision, and read by RIII inspector K. Ward during veld documentation review.
The RT reader sheet for veld K-516 indicated interpretation by Allen Sellars. The signature for Anthony C. Pallon appears peculiar. It appears that this radiograph was made in the same timeframe as via n the P_-M employees learned that their organization would be replaced by NES..
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4 CY 606 -
i CY 606 is a weld in the Cycled Condensate System. The weld is located in the ground in the tank farm area, under a concrete slab. The line is 16 inches in diameter (weld is
_ 50.26 inches of weld metal).
g Design conditions for this line are 35 psig and 140 degrees F. Maximum operating conditic:
are also 35 psig and 140 degrees F. This line is S&L piping class B.
7/7776 weld fit-up 7/77/76 weld performed ,
7/16/76 RT read, rejee 0-13, 13-26, unconsumed insert.
7/16/76 approvals on 97- T 7/19/76 R1 readed, PT of grinding -accept, weld performed?
'7/21/76 approvals for WRD #2 7/23/76 ground area, PT accept, weld performed?
7/26/76 RT performed 7/26/76 RT read, reject 0-12, 12-24, incomplete fusion.
7/27/76 approvals for WRD labled #2 7/29/76 PT-accept 8/2/76 2T for information only - reject.
8/4/76 PT reject- grind through & adjacent area, crack in veld edge, i
8/9/76 RT performed 8/9/76 RT read, 0-12 rejected.
3/10/76 KEI approval of above RT report.
8/10/76 approvals for WRD labled #3 8/10/76 PT test of area - accept *
, 8 /11/76 i
8/11/76^ RT RTread of weld -rejection sr 8/12/76 P-M rejection overridden by M. Low - accept veld, 8/13/76 gamma plugs CY606CP, 606 GPS, 606GP welded, PT accept.
1/ /77 S&L audit of radiography, areas 8-12 rejected for surface indications and linear indications.
1/21/77 NR-E-633, documents above finding, grind out defect and reveld.
2/11/77 approvals on disposition of NR-E-633 4/14/77 ANI approval of 8/11/76 RT.
I 4 /15/76 approvals on WRB labled 3A.
4/29/77 PT test ?
6/8/77 RT of area in 3A 0-13,13-26 accept.
6/8/77 RT read and approved.
! 6/20/77 ANI review and approval of above RT.
i 6/24/77 NR-E-633 closed.
l 7/19/77- samma plug re-welded, PT accept.
i 10/12/79 NES review - technique and documentation deficiencies l 10/3/80 NR-E-5172 based on NES findings for CY-606_ and several adjacent welds.
i 10/27/80 11/7-12/80 approvals on NR-E-5172 disposition of NR-E-5172 , accept as7is ,g 1,anhg 4 ,-
11/12/80 NR-E-5172 closed Paqsus _2,_ggf;, 7 12/17/80 Rex Baker notation on-NES documentation review checklistform (close-out).
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RH 42 was Rh 42 a weld on line IRHGli.40 u. .5.. Residual Heat Removal (RHR) system. Tha weld was
~
located in the reactor building at elevation 497'. Th line is 18 inches in diameter.
(weld was 56.5(nches of weld metal).
Design conditions for this line are 220 psig and 389 degrees F. Maximum operating conditio:
are 240 psig and 358 degrees F. The line is S&L piping class B.
CHRONOLOGY 8/6/76 weld fit-up 8/6/76 weld performed 8/9/76 RT of weld 8/9/76 RT read by P-M, reject tarkers 36-48 (notation: re-shoot 1007 following repair) 8/10/76 KE approval of above RT interpretation 8/10/76 approvals on WRD form 8/10/76 RT of repair area 8/10/76 RT read by P-M 8/11/76 RT accepted by KEI 8/11/76 approval of repair 9/16/76 ANI review of 8/9/76, 8/10/76 RT reports, approval.
1/25/80 NES review - porosity at markers 53-55 2/12/80 NR-E-5056 based on NES review findings 2/15/80 NR-E-5056 dispositioned to grind out and repair defect.
3/21/80 WRD form approvals 4/7-9/80 Phillip on site, initiation of Applegate investigation.
4/14/80 PT of re-prepped pipe ends, acceptance.
4/21/80 approvals for WRD for new elbow, 4/23/80 PT of elbow end prep. accepted 4/30/80 weld fit-up breaks loose ( ref KEIA i 1008).
5/1/80 re-fit-up approved & weld started.
, 5/7/80 RT approved by III l 5/7/80 ANI review and approval i 6/16/80 NR-E-5056 closed out I
CCMtElffS i
documentation checklist dated 1/25/80 by R.A. Zieler, LII RT '
Pf3 of checklist notes NR issued to repair rejectable indication
, Pf3 of checklist also notes corrective action prepared by T. McCal? , 2/12/80 1
It appears that the decision to grind out and repair the rejectable defects at markers 53-55 misinterpreted to mean cut-out entire weld. Weld cut-out then necessirated a new elbow, as fit-up could not be accomplished within specifications.
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's CHRONOLOGY
' FEBRUARY 28, 1980 FIRST APPLEGATE ALLEGATIONS RECEIVED JULY 2, 1980 FIRST INVESTIGATION REPORT ISSUED NOVEMBER 18, 1980 FOUR ALLEGATIONS FROM EX-ZIMMER EMPLOYEE DECEMBER 9, 1980 ALLEGER CONTACTED JANUARY 5, 1981 ALLEGATIONS FROM GAP /APPLEGATE GAP REQUESTS MSPB TO INVESTIGATE NRC JANUARY 12, 1981 ONSITE INVESTIGATION INITIATED APRIL 8, 1981 IMMEDIATE ACTION LETTER ISSUED AUGUST 21, 1981 QCP FORMALLY SUBMITTED BY LICENSEE AUGUST 24, 1981 NRC INDEPENDENT VERIFICATION PROGRAM INITIATED
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COMMISSION BRIEFING ZIMPER INVESTIGATION PURPOSE
- 1. BRIEFLY DISCUSS INVESTIGATION AND FINDINGS
- 2. DISCUSS PROPOSED ENFORCEPENT ACTION
- 3. DISCUSS PLANS FOR RELEASING REPORT
- 4. DISCUSS FUTURE ACTIONS p
, , , _ _ _ ,emo-*- _ - ~ ~ - a ~
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l ENFORCEMENT OPTIONS CONSIDERED:
- SUSPENSION ORDER CIVIL PENALTY O
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4 SUSPENSION ORDER REASONS FOR NOT PROPOSING SUSPENSION ORDER FINDINGS LARGELY PROGRAMMATIC
. IMMEDIATE ACTION LETTER ASSURED QUALITY OF ONGOING WORK i- . ONGOING WORK WOULD NOT HIDE DEFECTS IN COMPLETED WORK i
I . QUALITY CONFIRMATION PROGRAM t
ESTABLISHED TO -DETERMINE QUALITY OF COMPLETED WORK f
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CIVIL PENALTY REASON FOR PROPOSING CIVIL PENALTY WIDESPREAD BREAKDOWN IN QA PROGRAM IMPLEMENTATION PROPOSED CIVIL PENALTY AMOUNT
. $150,000 BASES FOR CIVIL PENALTY AMOUNT 14 ITEMS OF NONCOMPLIANCE WITH 10 CFR 50 APPENDIX B, INCLUDING MISREPRESENTATIVE QUALITY RECORDS
. CONSISTENT WITH PAST ACTIONS AT CONSTRUCTION SITES
. FINANCIAL IMPACT OF QUALITY CONFIRMATION PROGRAM FINANCIAL IMPACT OF CONSTRUCTION DELAY
4
+
i i -
C0fftISSION BRIEFING !
ZIMER INVESTIGATION _
t-i, 1, DISCUSS INVESTIGATION AND FINDINGS 2i DISCUSS PROPOSED ENFORCEENT ACTION 3.. DISCUSS Pl.ANS FOR RELEASING REPORT !
- , ., 4, DISCUSS FUTURE ACTIONS U' ..
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o CHBON0LQft1 FEBRUARY 28,1980 INITIALAPPLEGATEALLEGATIONSRECEIVED JULY 2, 1980 INVESTIGATION REPORT ISSUED 1
NOVEtBER 18,1980 ALLEGATIONS FROM EX-ZIMER EPPLOYEE RECEIVED ..
t DECEMBER 9,1980 ALLEGER CONTACTED JANUARY 5, 1981 ALLEGATIONS FROM GAP /APPLEGATE AND REQUEST FROM GAP FOR MSPB TO INVESTIGATE NRC RECEIVED v
- .. JANUARY 12,1981 DNS!TEINVESTIGATIONINITIATED
. APRIL 8, 1981 4
litEDIATE ACTION LETTER ISSUED -
i AUGUST 21,1981 '
LICENSEEQCPFbRMALLYSUBMITTED AUGUST 281, 1981 NRC INDEPENDENT VERIFICATION PROGRAM INITIATED I? .
li .
I t :
PROElFMS IDENTIFIED i
FROM GAP /APPLEGATE l
INADEQUATE RADIOGRAPHY OF PREFABRICATED PIPE WELDS INADEQUATE INSPECTION OF CABLE TRAY HANGER WELDS l .
UNACCEPTABLE CABLE TRAY HANGER WELDS INADEQUATE Aa DESIGN CONTROLS (R)
FROMEX-EvLgEE j y 1
INADEQUATE TRACEABILITY OF PIPE (R)
IMPROPER VOIDING OF NRs (R)
- UNDESIRABLE INTERFACE BETWEEN CONSTRUCTION AND Q QUESTIONABLE QUALITY OF SMALL BORE PIPE WELDS f-//4/;4)
FROM PAST AND CURRENT SITE INSPECTORS HARASSENT OF QC INSPECTORS IMPROPERLY DELETED WELD INSPECTIO CRITERIA (R)
IMPROPER USE OF SURVEILLANCE REPORTS (R)
FROM NRC INSPECTORS -
.. UNACCEPTABLE WELDS ON NINE HANGER BEAMS UNACCEPTABLE (NOTCHED) RE-ENTRANT CORNERS UNSPECIFIED ' HANGER BEAMS (FOUR) INSTALLED TRACEABILITY OF NINE HANGER BEAMS NOT MAIN l s .
VIOLATION OF CABLE SEPARATION CRITERIA AT
. INADEQUATE CG&E AUDITS OF SARGENT & LUNDY O
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. I M DIATE' ACTION LETTER ,
1 PullPOSE:
.:,. CONTROL ONGolNG AND FUTURE WORK ,'
flAJORLICENSEEACTIONS: ,
4 .
, CHANGED KEY MANAGEENT .
q ,
, INCREASED SIZE AND TECHNICAL EXPERTISE OF LICENSEE QA STAFF (6 TO 135)
, 100% DIPLICATION OF CONTRACTOR QC INSPECTIONS I
4 Y' , FULL CONTROL OF RECORDS BY LICENSEE
- , t l
NRC FDLLOWUP FINDINGS:
.. i
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, iGUALITY OF ONGolNG WORK IS ACCEPTABLE .
ii '
. LICENSEE COMMITENTS BEING ET l-j.
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i QUALITY CONFIRMATION PROGRAM
- PilRPOSE DETERMINE THE QUALITY OF PAST CONSTRUCTION BY CONFIRMING:
. QUALITY OF PIPE MATERIAL
( . PROPER DISPOSITION OF NONCONFORNING ITEMS I
! . QUALITY OF PIPE WELDS
, i I
F . QUALITY OF STRUCTURAL STEEL MATERIAL AND WELDS
. ADEQUACY'0FELECTRICALCABLESEPARATION ADEQUACY OF A N ELECTRICAL DESIGN CONTROLS
. ADEQUACY OF CONTROL OF DESIGN CHANGES
-_ l
- . ADEQUACYOFSUBCONTRACTORQAPROGRAMS
. ADEQUACY OF PAST AUDITS
- THIS PROGRAM WILL BE EXPANDED Sil00LD Tile LICEtlSEE IDENTIFY SIGNIFICANT PROBLEMS DURING CONDUCT OF THE QCP OR Sil00LD THE NRC IDENTIFY PROBLEliS IN THE REMAINING
- INVESTIGATION AND INSPECTION EFFORTS.
'4
i flRC INDEPENDENT VERIFICATI0!!
i
' PURPOSE: . PROVIDE C0fiFIDEllCE It; PLANT QUALITY PROVIDE PERSPECTIVE OF GA BREAKDOWi' VERIFICATI0ils PERFOR.1ED:
INSPECTED HARDWARE RELATED TO 24 VOIDED NRs PERFOR:1ED i1ETALLURGICAL ANALYSES OF SIX WELDS PERFOR.'1ED METALLURGICAL AliALYSES OF SIX PIPES PERFORMED LABORATORY ANALYSES OF TWO MISMATCHED WELDS TESTED 70 PIPE WELDS FOR HARDNESS AfD THICKNESS
. VISUALLY EXAMINED E9 PIPE WELDS RADIOGRAPHED G0 PIPE WELDS DYE PENETRANT TESTED 42' PIPE WELDS ULTRASONICALLY EXAMINED 21 PIPE WELDS TESTED 53 BEAMS FOR HARDNESS A!'D FITUP t VISUALLY I!lSPECTED 380 BEAM WELDS I!!SPECTED ADDITIONAL AREAS FOR CABLE SEPARATION NRC FINDINGS:
10 CASES OF WELD DEFECTS AND DIMENSIONAL PROBLEMS 4 HANGERS UNACCEPTABLY INSTALLED l . 4 CABLE SEPARATION PROBLElls POSSIBLE PROBLEl1 WITH '. ELDS OF .11S.31ATCHED PIPE PRELIi11 NARY C0tlCLUSION:
NO WIDESPREAD CONSTRUCTION PROBLEMS l
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4 FUTURE ACTIONS COMPLETE INVESTIGATION EVALUATE RESULTS OF LICENSEE'S QUALITY CONFIRMATION PROGRAM EVALUATE NEED FOR MORE NRC INDEPENDENT MEASUREMENTS l
8 9
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CHRONOLOGY FEBRUARY 28, 1980 FIRST APPLEGATE ALLEGATIONS RECEIVED JULY 2,1980 FIRST INVESTIGATION-REPORT ISSUED NOVEMBER 18, 1980 FOUR ALLEGATIONS FROM EX-ZIMMER EMPLOYEE DECEMBER 9, 1980 ALLEGER CONTACTED JANUARY 5, 1981 ALLEGATIONS FROM GAP /APPLEGATE GAP REQUESTS MSPB TO INVESTIGATE NRC JANUARY 12, 1981 ONSITE INVESTIGATION INITIATED APRIL 8, 1981 IMMEDIATE ACTION LETTER ISSUED l
l AUGUST 21, 1981 QCP FORMALLY SUBMITTED BY LICENSEE
- AUGUST 24, 1981 NRC INDEPENDENT VERIFICATION PROGRAM INITIATED i
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4 COMMISSION BRIEFING ZIMMER INVESTIGATION PURPOSE
- 1. BRIEFLY DISCUSS INVESTIGATION AND FINDINGS
- 2. DISCUSS PROPOSED ENFORCEMENT ACTION
- 3. DISCUSS PLANS FOR RELEASING REPORT
- 4. DISCUSS FUTURE ACTIONS I
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ENFORCEMENT OPTIONS CONSIDERED:
SUSPENSION ORDER
' CIVIL PENALTY
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SUSPENSION ORDER REASONS FOR NOT PROPOSING SUSPENSION ORDER FINDINGSLARGEi.YPROGRAMMATIC
. IMMEDIATE ACTION LETTER ASSURED QUALITY OF ONGOING WORK ONGOING WORK WOULD NOT HIDE DEFECTS IN COMPLETED. WORK
. QUALITY CONFIRMATION PROGRAM ESTABLISHED TO DETERMINE QUALITY OF COMPLETED WORK i
_. _. .~ ._....~ ~ . . . . _ _. - - - - . . , _ _ . . . . - . . . _ _ . , _ _ _ . . __ _ ; ..
CIVIL PENALTY REASON FOR PROPOSING CIVIL PENALTY
. WIDESPREAD BREAKDOWN IN QA PROGRAM IMPLEMENTATION PROPOSED CIVIL PENALTY AMOUNT
. $150,000 BASES FOR CIVIL PENALTY AMOUNT 14 ITEMS OF NONCOMPLIANCE WITH 10 CFR 50 APPENDIX B, INCLUDING MISREPRESENTATIVE QUALITY RECORDS
. CONSISTENT WITH PAST ACTIONS AT
, CONSTRUCTION SITES
. FINANCIAL IMPACT OF QUALITY CONFIRMATION PROGRAM FINANCIAL IMPACT OF CONSTRUCTION DELAY
.n - --- - ~ -
_ ,, , . . . - - ~ * * " ' *~" *" '
i +
MAJOR PROBLEMS IDENTIFIED FROM EX-EMPLOYEE ALLEGATIONS '
IMPROPER VOIDING OF NRs TRACEABILITY OF PIPE NOT MAINTAINED SMALL BORE PIPE WELD QUALITY NOT VERIFIED FROM GAP /APPLEGATE ALLEGATIONS INADEQUATE RADIOGRAPHY OF PREFABRICATED l PIPE WELDS INADEQUATE INSPECTION OF CABLE TRAY HANGER WELDS FAILURE TO VERIFY THERMAL LOADING OF POWER CABLE SLEEVES i
FAILURE TO VERIFY WEIGHT LOADING OF CABLE TRAYS FAILURE TO CONTROL DESIGN DEVIATIONS IDENTIFIED l BY ENGINEERS i
FROM CURRENT SITE INSPECTORS i
HARASSMENT OF QC INSPECTORS
- WELD INSPECTION CRITERIA IMPROPERLY DELETED j IMPROPER CONTROL 0F NONCONFORMANCES DOCUMENTED IN SURVEILLANCE REPORTS l
l l
u . - . _ . .. ..... - . - - . = - - - - - ~ .-- :-- - e-- -
- = - ..
e NRC FINDINGS UNACCEPTABLE WELDS ON HANGER BEAMS UNACCEPTABLE (NOTCHED) RE-ENTRANT CORNERS ON HANGER BEAMS HANGER BEAMS INSTALLED BUT NOT SPECIFIED BY DESIGN TRACEABILITY OF HANGER BEAMS NOT MAINTAINED CABLE SEPARATION CRITERIA VIOLATED CG&E AUDITS OF SARGENT & LUNDY WERE INADEQUATE O
,- w w .ca -me m* w e~e *-***'*-=aw"*+*
sw %. -
, %we , m -
- ye w W* .
- " * * * * * + ' '
" " * ' ' ' ' * ' * " " *
- N
IMMEDIATE ACTION LETTER i
PURPOSE:
. TO CONTROL ONGOING AND FUTURE WORK MAJOR RESULTS:
KEY MANAGEMENT CHANGED INCREASED SIZE AND TECHNICAL EXPERTISE
, 0F CG&E QA STAFF ( 6 TO 135) 100% REINSPECTION ,
OF CONTRACTORS QC INSPECTIONS NRC INSPECTIONS SHOW QUALITY OF ONGOING WORK IS ACCEPTABLE
.g , . .w.,v wh=.sL en r .- w eEP ***M**^-- **h" * * *
'**#7 d# ## "'*
- 4'*"'*' * -'M F 99 t.%
- ._ - - - . . .-- - . . ~ - - .. .--. - - - - -
QUALITY CONFIRMATION PROGRAM PURPOSE DETERMINE THE QUALITY OF PAST CONSTRUCTION BY CONFIRMING:
- QUALITY OF STRUCTURAL STEEL MATERIAL AND WELDS
- QUALITY OF PIPE WELDS MATERIAL AND RADIOGRAPHS ADEQUACY ~ 0F ELECTRICAL CABLE SEPARATION PROPER DISPOSITION OF NONCONFORMING ITEMS ADEQUACY OF A/E ELECTRICAL DESIGN CONTROLS
. ADEQUACY OF SUBCONTRACTOR QA PROGRAMS
. ADEQUACY OF PAST AUDITS i ' ADEQUACY OF CONTROL OF DESIGN CHANGES t
_-. v
1 NRC INDEPENDENT VERIFICATION PURPOSE: . PROVIDE CONFIDENCE IN PLANT QUALITY
. PROVIDE PERSPECTIVE OF QA BREAKDOWN j VERIFICATIONS PERFORMED:
. INSPECTED HARDWARE RELATED TO 24 VOIDED NRs '
. METALLURGICAL ANALYSES OF SIX WELDS
. METALLURGICAL ANALYSES OF'SIX PIPES LABORATORY ANALYSIS OF TWO 0FFSET WELDS
. TESTED 70 PIPE WELDS FOR HARDNESS AND THICKNESS l
. VISUALLY EXAMINED 69 PIPE WELDS l RADIOGRAPHED 60. PIPE WELDS
. DYE PENETRANT TESTED 42 PIPE WELDS
. ULTRASONICALLY EXAMINED 21 PIPE WELDS l TESTED 53 BEAMS FOR HARDNESS AND FITUP
. VISUALLY INSPECTED 380 BEAM WELDS
{
l . ADDITIONAL INSPECTIONS FOR CABLE SEPARATION NRC FINDINGS:
i i
. QA PROGRAM BREAKDOWN DID NOT RESULT IN WIDESPREAD CONSTRUCTION PROBLEMS
. POSSIBLE PROBLEM WITH OFFSET IN PIPE BUTT WELDS
. SOME HANGERS UNACCEPTABLY INSTALLED
. SOME CABLE SEPARATION PROBLEMS l . ISOLATED CASES OF MINOR WELD DEFECTS AND DIMENSIONAL PROBLEMS l
.-r~.- . =- . . - - - . . . . - - . . . , . . - . - , ,
e 1
I PLANS FOR RELEASING REPORT
. ADVANCE COPY TO CONGRESSMAN M0FFETT'S STAFF THREE DAYS BEFORE RELEASE ON DAY OF RELEASE
. MEET WITH LICENSEE
. BRIEF GAP
' HOLD PRESS CONFERENCE
. PROVIDE COPY-T0 OTHER INTERESTED CONGRESSMEN 4
4 4
- p., e m as-s -me--< -e= w . m -
gep-$- .
,ap, g ,,,,
i
_ . . . _ ._. _ ~
e 4
FUTURE ACTIONS
- COMPLETE INVESTIGATION EVALUATE RESULTS OF LICENSEE'S QUALITY CONFI.RMATION PROGRAM i
EVALUATE NEED FOR MORE NRC INDEPENDENT MEASUREMENTS S
i I
. - - - _ . . . . - . , - .~.. .. . - . , _ _ _
SUMMARY
OF NONCOMPLIANCES
, A. MISREPRESENTATIVE RECORDS B. IMPROPER PROCESSING OF NONCONFORMANCE REPORTS C. FAILURE TO CONTROL NONCONFORMING CONDITIONS D. FAILURE TO CORRECT CONTROLLED NONCONFORMING CONDITIONS-E. LACK OF TRACEABILITY OF MATERIALS F. IMPROPER ROUTING OF ELECTRICAL CABLES G. LACK OF WELD INSPECTION ACCEPTANCE CRITERIA H. IMPROPER RADIOGRAPHY TECHNIQUES
- 1. LACK OF ARCHITECT - ENGINEER DESIGN CONTROL MEASUR$S J. LACK OF INSPECTION PROGRAMS K. LACK OF AND FAILURE TO FOLLOW PROCEDURES
, L. FAILURE TO ASSESS EFFECTIVENESS OF VENDOR QA PROGRAMS
- M. INADEQUATE SURVEILLANCE RECORDS
! N. FAILURE TO AUDIT ARCHITECT - ENGINEER NONCONFORMANCE PROGRAM
- 0. INSPECTOR HARASSMENT-l
- a. m,.h s. er- ,eMe *' eems _ *-'g6=4e -
e%h 6 '+-*" "
- N A N M *t'N-
= -
~ * - - -- - - - - - ._-
4 I
i l
5 5
1 REGIONAL EFFORT 1
INDIVIDUALS INTERVIEWED 90 l
MANDAYS ONSITE 265 i-EVALUATION / DOCUMENTATION MANDAYS 600 1
i i
' e
_Em._ aham_ - giMh_ ,maA._a .e n g__ __m_ u_s
.. . - . . _ . _ ._~.J_!1 _ . _ . _ . _ . --
4 e
IMPACT ON LICENSEE SCHEDULE NRC ESTIMATE -- SIX MONTHS DELAY COST TO LICENSEE LOSS OF PRODUCTIVITY -- $2M PER MONTH INCREASED QA PERSONNEL -- $1M PER MONTH INTEREST FROM DELAY -- $12M PER MONTH i
i b
4-* ,, - . .4& T 4
d i
e EX-ZIMMER EMPLOYEE ALLEGATIONS
- 1. KAISERQCMANkGERV0IDINGNONCONFORMANCEREPORTS WITHOUT JUSTIFICATION.
- 2. BOLT H0LES FOR LARGE BORE PIPE SUPPORT HANGERS
-BEINGMADEBYBURNINGRATHERTHAN$ RILLING.
- 3. TWO DOCUMENT REVIEWERS RECORDING DISCREPANCIES
- ON EXCEPTION LIST RATHER THAN NONCONFORMANCE REPORT. THEY ARE CATCHING FLACK FOR IDENTIFYING DISCREPANCIES IN DOCUMENTATION.
i
~
_i._~
APPLEGATE/ GAP ALLEGATIONS
- 1. MAIN STEAM RELIEF PIPING REPLACED - COSTING $320,000 2, 2000 LB. FITTINGS USED IN PLACE OF 5000 LB. FITTINGS
- 3. RADI0 ACTIVE WASTE DRAIN CLOGGED WITH CONCRETE
- 4. VALVE BROKEN WHEN BUMPED BY PIPEFITTER
- 5. WELD R0D CONTROL (TEMPERATURE AND ACCOUNTABILITY)
, 6. CRAF' OVERCOME BY ARGON GAS
! 7. dei _ /E WELDS IN PIPE THAT WAS DROPPED FROM TRUCK
- 8. 20% OF THE PREFABRICATED WELDS ARE BAD
- 9. PIPING INSTALLED THEN DESIGNED
! 10. CABLE TRAYS (FAULTY HANGER WELDS ARE DANGEROUSLY FULL)
- 11. RIVER INTAKE PUMPS FAIL BECAUSE OF PLANT DESIGN
, 12. 300 PSIG PIPES OVERPRESSURIZED WITH 1200 PSIG
- 13. FUEL SECURITY (N0 SURVEILLANCE CAMERAS AND CHICKENWIRE FENCE)
- 14. DRINKING, DRUGS, AND VIOLENCE
- 15. EMPLOYEES FIRED FOR TIME-CHEATING AND CRITICIZING QA
- 17. PIPEFITTERS AND PM INTIMIDATED
- 18. DETAILED JOURNAL OF SAFETY HAZARDS
- 19. PIPEFITTERS "J0KE" TO BE FAR AWAY WHEN PLANT STARTS UP L-- --_
4.1 1
ALLEGATION: . NONCONFORMANCE REPORTS (NRs) IMPROPERLY VOIDED FINDINGS: -
NRs WERE IMPROPERLY V0IDED 24 VOIDED NRs EXAMINED BY NRC NINE IMPROPERLY VOIDED INDEPENDENT MEASUREMENTS:
FIELD REVIEWED COMPONENTS / SYSTEMS, COVERED BY 24 NRs FOUR PIPE HANGERS UNACCEPTABLY INSTALLED l
l LICENSEE ACTIONS:
i REVIEW ALL VOIDED NRs l -
REVIEW DISPOSITION OF 300 ADDITIONAL NRs l
l l
i
. . . ..,.<-.m--a- -
- r*=s****'> ' " * ' " ' ~ ~ ' * " * * ** ~
14 . 2 ALLEGATION: ' HANGER BOLT HOLES BURNED AND NOT INSPECTED FINDINGS: BOLTS WERE BljRNEE AND REAMED -- EVALUATING ACCEPTABILITY
. HOLE INSPECTI0fl ACCEPTABLY PERFORMED INDEPENDENT MEASUREMENTS:
NONE r
LICENSEE ACTIONS:
NONE l
u - . . - . _ . . . - - . - - - . - . . - .. -_- _-_
=_
4.3 .
f ALLEGATION: DOCUMENTATION DISCREPANCIES RECORDED ON EXCEPTION LISTS, (NOT NRs) AND ENGINEERS CRITICIZED FOR IDENTIFYING DISCREPANCIES FINDINGS: . DOCUMENTATION ON EXCEPTION LISTS WAS ACCEPTABLE
! ' NO EVIDENCE INDICATED ENGINEERS WERE CRITICIZED 4
- OTHER FINDINGS MADE WHILE PURSUING THIS ALLEGATION
. DISCREPANCIES IN SMALL BORE PIPE TRACEABILITY RECORDS
- , . IN-PROCESS INSPECTION RECORDS IMPROPERLY MODIFIED j PIPE SOCKET ENGAGEMENT NOT VERIFIED i
. IN-PROCESS PIPE WELD INSPECTIONS NOT PERFORMED .
INDEPENDENT MEASUREMENTS:
i
. SEVEN SOCKET WELDS RADIOGRAPHED -- ENGAGEMENTS I ACCEPTABLE l
i
' SIX PIPE SECTIONS ANALYZED -- PIPES ACCEPTABLE LICENSEE ACTIONS:
l
- DEMONSTRATE ACCEPTABILITY OF:
. PIPE QUALITY
. WELD QUALITY '
l . WELD SOCKET ENGAGEMENT i
=-- . . - . - - . . - . - . _ . - . . - . = - . . . . - . - . - - - . , . . _ .
. . . - . -- =:.- . . . - . ..
4.4 4
ALLEGATION: . THREATENED FIRING OF WELD INSPECTOR FOR USING MAGNIFYING GLASS i
FINDINGS:
- INSPECTOR WAS THREATENED WITH FIRING
. INSPECTOR NOT FIRED BUT WAS REASSIGNED i INDEPENDENT MEASUREMENT:
NONE LICENSEE ACTION:
NONE i
I l
l.
_ _, -7.
5.1 ALLEGATION: . UNSUITABLE PIPING KNOWINGLY INSTALLED AND REPLACED ,
FINDINGS: . PIPING FOR ORIGINAL MSR SYSTEM DESIGN INSTALLED KNOWING 3 TO 10% WOULD BE REPLACED WITH SUBSEQUENT PIPING DESIGN i
ECONOMIC DECISION BY LICENSEE TO PROCEED WITH ORIGINAL DESIGN
. MODIFICATION PROPERLY INSTALLED INDEPENDENT MEASUREMENTS:.
NONE i
LICENSEE ACTIONS:
. NONE 1
. , . . _ . . _ . . - .~.
5.2 ALLEGATION: . IMPROPER FITTINGS INSTALLED FINDINGS: .
' DESIGNED RATING 0F FITTINGS CHANGED TO LOWER PRESSURE LOWER PRESSURE FITTINGS ADEQUATE FOR DESIGNED FUNCTION INDEPENDENT MEASUREMENTS:
NONE LICENSEE ACTIONS:
. NONE e
a 4 ,.r .w ..e+w.&- +-' * - - c om.w .m - * +-e -e
= . , , +- -~~ ,
-. :, 3 ALLEGATION: . RADWATE FLOOR DRAINS CLOGGED llITH CONCRETE FINDINGS: . SOME DRAINS CLOGGED AT ONE TIME WITH UNSPECIFIED DEBRIS DRAINS CONTROLLED BY LICENSEE
. 152 OUT OF 169 DRAINS ALREADY FLUSHED
-17 DRAINS TO'BE' FLUSHED PRIOR TO OPERATION INDEPENDENT MEASUREMENTS:
. NONE LICENSEE ACTIONS:
. NONE 4
9 e f . g i e ?' 9 ** <*. 'MEMW MW'e e swgW m = ? "
- mw &*4
- 4 -ehe d**"^=*--- ='==-- -
54 ALLEGATION:
WEAK VALVE MATERIAL -- BROKEN WHEN BUMPED FINDINGS: -
HYDRAULIC ACTUATOR DRAIN ADAPTER BROKEN BY ADJACENT CONSTRUCTION ACTIVITIES ADAPTOR REPLACED WITH STRONGER DESIGN BECAUSE PRONE TO DAMAGE BOTH ORIGINAL AND STRONGER DESIGNS ADEQUATE FOR DESIGNED FUNCTION HYDRAULIC SYSTEMS PRESSURE TESTED --
ALL COMPONENTS ACCEPTABLE INDEPENDENT MEASUREMENTS:
NONE
'I LICENSEE ACTIONS:
NONE i
1 l
i l
t k ,. .-
,m,,~.. - - - - - -
___1_____.__
_ _ . om._
_. ._ - - . ~ . . -
p l
I
\
I ALLEGATION: . IMPROPER WELD ROD TEMPERATURE CONTROL ;
AND DOCUMENTATION FINDINGS: . ALLEGED PROBLEMS NOT FOUND DURING INVESTIGATION
{
PREVIOUS NRC INSPECTION FINDINGS:
. WELD RODS STORED AT IMPROPER TEMPERATURE WELD RODS LYING UNCONTROLLED IN CONSTRUCTION '
AREA INDEPENDENT MEASUREMENTS: -
. RADIOGRAPHS AND BOAT SAMPLES OF SIX WELDS -
NO WELD PROBLEMS AND NO MATERIALS PROBLEMS LICENSEE ACTIONS:
. DEMONSTRATE WELD QUALITY l
1
- - - - ~
5.6 ALLEGATION: . PERSONNEL OVERCOME BY ARGON GAS SAFETY-DIRECTOR DISINTERESTED FINDINGS: . ARGON GAS HOSES CRIMPED AND WIRED CLOSED RATHER T}iAN CLOSING VALVE
. NO PERSONNEL OVERCOME WITH ARGON
. OSHA INSPECTION FOUND ADEQUATE SAFETY -
CONTROLS AND PROCEDURES IN PLACE
. NO EVIDENCE THAT SAFETY DIRECTOR DISINTERESTED INDEPENDENT MEASUREMENTS:
j . NONE LICENSEE ACTIONS:
. NONE
,m ., em et. 4 *** ': -vb v'e* -* am e4 me no e ae- *
- e me *~- e p- ...y ,
~
1._______.. __ - -
=
5.7 ALLEGATION: . SPOOL PIECES DROPPED FROM TRUCK HAVE DEFECTIVE WELDS FINDINGS: NO DEFECTIVE WELDS NRC PREVIOUSLY INVESTIGATED INDEPENDENT MEASUREMENTS:
. NRC ULTRASONICALLY EXAMINED THREE WELDS ON EACH OF THE FIVE SPOOL PIECES -- ALL
' WELDS ACCEPTABLE n
LICENSEE ACTIONS:
NONE
,- a+ --q- - t -
% --g .
- e----
5,8 F
w.
ALLEGATION: 20% OF PREFABRICATED PIPE WELDS DEFECTIVE FINDINGS: WELDS ACCEPTABLE BASED ON REVIEW 0F MORE THAN 800 RADIOGRAPHS OTHEitFINDINGSMADEWHILEPURSUINGTHISALLEGATION:
187 RADIOGRAPHS WITH UNACCEPTABLE TECHNIQUE INDEPENDENTMEASUREMsNTS:
. RADIOGRAPHED SEVEN WELDS (0F OR SIMILAR TO THE 187) - WELDS ACCEPTABLE i
LICENSEE ACTIONS:
. DEMONSTRATE RADIOGRAPHS (SIMILAR TO THE 187)
ARE ACCEPTABLE t
~
5.9 ALLEGATIONS:- PIPE DESIGNS DRAWN AFTER INSTALLAT. ION FINDINGS: . PREVIOUS NRC INSPECTIONS HAVE IDENTIFIED MANY PIPE AND PIPE SUSPENSION DESIGN PROBLEMS '
. PROBLEMS RESULTED IN NONCOMPLIANCES, MANAGEMENT MEETINGS, LICENSEE STOP WORK ORDERS, AND AN IMMEDIATE ACTION LETTER RESOLUTIONS NOT COMPLETE -- FOLLOWED BY INSPECTION PROGRAM INDEPENDENT MEASUREMENTS:
. NONE LICENSEE ACTIONS:
. NONE
2.10 _
ALLEGATION: . CABLE TRAY HANGERS HAVE FAULTY WELDS
) . CABLE TRAY WELDS FAULTY
. CABLE TRAYS DANGEROUSLY FULL
~
FINDINGS: . >130 CABLE TRAY HANGER WELDS EXAMINED -
FOUR WELDS UNACCEPTABLE
. PREVIOUS INVESTIGATION FOUND TRAY WELDS ACCEPTABLE
. CABLE LOADING (THERMAL) DESIGN BASIS DIFFERENT 4
THAN FSAR 2
. THERMAL LOADING OF POWER SLEEVES NOT VERIFIED
.W5IGHTLOADINGOFTRAYSNOTVERIFIED
. ENGINEER IDENTIFIED DESIGN DEVIATIONS NOT CONTROLLED OTHER FINDINGS MADE WHILE PURSUING THIS ALLEGATION:
. IN-PROCESS INSPECTION OF HANGER WELDS NOT PERFORMED
. FINAL WELD INSPECTIONS PERFORMED AFTER PAINTING
. WELD INSPECTION CRITERIA DEVIATED FROM CODE REQUIREMENTS LICENSEE ACTIONS:
, . DEMONSTRATE WEU) QUALITY
. ASSURE ALL DISCIPLINE DESIGNS ARE VERIFIED
. ASSURE DESIGN DEVIATIONS ARE CONTROLLED
1 .._.- 2.__ ~~- _ ._ ..
5.11 ALLEGATION: . SERVICE WATER INTATE FROM RIVER KEEP CH0 KING PUMPS. PUMPS QUICKLY BURN OUT.
FINDINGS: - SILTING CONDITION REPORTED PER 10 CFR 50.55(E)
IN JUNE, 1979 ACCELERATED PUMP WEAR REPORTED PER 10 CFR 50.55(E) IN AUGUST, 1979 SILTING AND PUMP WEAR CONCERNS OPEN NRC ISSUES PENDING COMPLETION OF MODIFICATIONS INDEFENDENT MEASUREMENTS:
. NONE LICENSEE ACTIONS:
. tDNE
5.12 L
i-i ALLEGATION: . DESIGN FLAW CAUSED PIPES TO RUPTURE --
SPRAYING WATER THAT WOULD HAVE BEEN RADI0 ACTIVE FINDING: . PIPE OVERPRESSURIZATION REPORTED PER j 10 CFR 50.55(E) IN MARCH, 1979
. CAUSED BY OPERATOR ERRORS --
TWO VALVES LEFT OPEN
. WATER COULD HAVE BEEN CONTAMINATED IF OPERATING
. ACTIONS TAKEN TO ASSURE QUALITY OF PIPING AND COMPONENTS AND TO PREVENT RECURRENCE FOUND ACCEPTABLE BY NRC PRIOR TO ALLEGATION INDEPENDENT SUREMENTS:
LICENSEE ACTIONS:
. NONE
.i
..--._~..%. . , . . . . _.- , - .__._..___.________._._,_.w___
r' M - em' e- .w4, ro w ,,
5013 ALLEGATION: . NO SECURITY SURVEILLANCE CAMERAS DURING FUEL RECEIPT AND PERIMETER FENCE OF FOUR FOOT CHICKENWIRE FENCE FINDINGS: . ALLEGATIONS IRRELEVANT CAMERAS NOT REQUIRED AT TIME OF FUEL RECEIPT PERIMETER FENCE NOT REQUIRED AT TIME OF FUEL RECEIPT INDEPENDENT MEASUREMENTS:
. NONE LICENSEE ACTIONS
. NONE
5.14 ALLEGATION: .
ALC0HOL AND DRUG USE FINDINGS: . SOME EVIDENCE OF ALC0HOL AND DRUG USE
. INDETERMINATE EFFECT ON PLANT QUALITY l
INDEPENDENT MEASUREMENTS:
- 60 WELDS RADIOGRAPHED
. IDENTIFIED OFFSET IN PIPE BUTT-WELDS
. EVALUATION IN PROGRESS
. INDETERMINATE RELATION TO ALCOHOL AND DRUG USE LICENSEE ACTIONS:
. QUALITY OF PLANT TO BE VERIFIED BY QUALITY CONFIRMATION PROGRAM O
e viv. ,+ , s , v- ,-z--- ,
m u e a , a_ . _ _. . . , _ _ _ _ _ . . ._ . _ . . _ . _
5.15 ALLEGATION: . EMPLOYEES FIRED FOR TIME CARD CHEATING --
l l CHEATING WITH APPROVAL OF MANAGEMENT CHEATERS WERE CRITICS OF GA AND SAFETY l
FINDINGS: . FIVE INDIVIDUALS WERE FIRED FOR TIME CARD CHEATING. NO INDICATION OF APPROVAL BY MANAGEMENT. OTHER CRITICS OF SAFETY WERE NOT* FIRED. .
INDEPENDENT MEASUREMENTS:
. NONE l
LICENSEE ACTIONS:
. NONE i
l l
l l
5.16 ALLEGATION: . CGaE WARNED PEAB0DY MAGNAFLUX (PM) TO SILENCE RADIOGRAPHERS
. CGSE APPROVING WELDS REJECTED BY PM
. PM TRAILER BROKEN INTO AND RECORDS OF
, 0VERRIDDEN WELD REJECTION REMOVED FINDINGS: . SEVEN PM EMPLOYEES DENIED THE SILENCING ,
ALLEGATION RADIOGRAPHERS, CG4E, AND PM MANAGEMENT DENY ANY ATTEMPTS WERE MADE TO OVERRIDE WELD DETERMINATIONS
. PM TRAILER BROKEN INTO -- FIVE RECORDS OF GOOD WELDS HISSING INDEPENDENT MEASUREMENTS:
NGNE LICENSEE ACTIONS:
NONE -
4 e
.c . . . . . , .e-. -.mf.* e ee. ars * .- = ..,<.a=nump.. ._._ . , - . . + . _ _ _ _ _ _ . _ _ . , , _ _ _ _ . . _ . . _ . . _ . . _ _
l 5.17 1
ALLEGATION: . UNION PIPEFITTERS AND PEABODY MAGNAFLUX EMPLOYEES INTIMIDATED FINDINGS: . TWO FIRED UNION PIPEFITTERS AND SEVEN PM EMPLOYEES DENIED ALLEGATION
- l. INDEPENDENT MEASUREMENTS:
I
, NONE 4
LICENSEE ACTIONS:
NONE f
I
(
. . _ . ~ . . . ... . . . .
5.18
^
4 ALLEGATION: . FORMER KAISER EMPLOYEE HAS A DETAILED
. JOURNAL OF SAFETY DEFECTS l FINDINGS: . INDIVIDUAL KEPT FIELD INSPECTION NOTEBOOK.
HEBELIEVESALLDEFICIENCl$SWERE ,
CORRECTED.
INDEPENDENT MEASUREMENTS:
NONE i
LICENSEE ACTIONS:
l NONE i
. a
4
. 5.19 '
i
! ALLEGATION: . PIPEFITTERS SAID THEY WILL BE FAR AWAY
, AT STARTUP DUE TO PREDICTED ACCIDENT l
FINDINGS: . ALLEGED STATEMENT MADE INDEPENDENT MEASUREMENTS:
NONE -
LICENSEE ACTION:
NONE l
l l
t l
6.1 ALLEGATION: . QC INSPECTOR HARRASSMENT FINDINGS: . INSPECTOR HARASSED BY CRAFT PERSONNEL
. WATER DOUSING
. SPRAYED WITH FIRE EXTINGUISHER DIRECTED PERSONNEL SEARCH PERFORMED BY SECURITY
. INSPECTORS REASSIGNED BECAUSE OF CONSTRUCTION MANAGEMENT CRITICISM LOSS OF INSPECTOR INDEPENDENCE NOT EVIDENT PREVIOUS LICENSEE ACTIONS:
. ATTEMPTS TO IDENTIFY AND DISCIPLINE HARASSERS WAS INEFFECTIVE LICENSEE ACTIONS:
. ESTABLISH MEASURES TO STOP HARASSMENT
-*--e r . , e.M sm. 6e** en uw q ae4
(
6.2 -
l l .
l i
ALLEGATION: . WELD INSPECTION CRITERIA DELETED FINDINGS: CRITERIA DELETED FOR IN-PROCESS INSPECTIONS OF DRYWELL WELDING ACTIVITIES FROM JULY, 1980 THROUGH JANUARY, 1981 !
. CRITERIA DESIGNATED NOT APPLICABLE FOR ONE '
WELD IN NOVEMBER,.1979 '
LICENSEE ACTION: !
. DEMONSTRATE WELD QUALITY INDEPENDENT MEASUREMENTS:
NONE 4
y l :
l .
., ~ _ _ _ . _ _ . . . _ _ __.
l 6.3 :
l l
I I
t i
ALLEGATION: . SURVE!LLANCE REPORTS NOT CONVERTS TO l NONCONFORMANCE REPORTS IN 30 DAYS i
i FINDINGS: . PROCDURE REQUIRE CONVERSION IN 30 DAYS
. PROCDURE INADEQUATE - SURVEILLANCE REPORTS DID l
' t NOT RECE!VE ENGINEERING REVIEW WHEN i i
IDENT!FYING NONCONFORMANCES
\
. SRs WERE NOT ALWAYS CONVERTED IN 30. DAYS l
t!CENSEE ACTION:
. REVIEW ALL SRs TO IDENTIFY NONCONFORMANCES --
PROFERLY DISPOSITION NONCONFORMANCES l l l
l INDEPENDENT (1EASUREMENTS:
NONE i I l i 1
I l
(- .
i :
f l
t a e
' : _' ~ ' .-_: ~ r_~: T:: - - _*:.__ ~ tv L __:_~:rr_~::2 m ~ ~ vn"
. .._ _ . . _ . . _ _ _ .. .- _ . . -_ u- . .
7.1 ,
INSPECTION: . HANGER BEAMS AND WELDS E
- FINDINGS
- . 25 BEAMS EXAMINED
-NINE BEAMS HAD UNACCEPTABLE WELDS
-FIVE BEAMS HAD UNACCEPTABLE RE-ENTRANT l CORNERS
-FOUR BEAMS INSTALLED WERE NOT SPECIFIED l
BY DESIGN 4
-NINE BEAMS WERE NOT TRACEABLE
. THREE BEAM VENDORS NOT EVALUATED
. STEEL ERECTION DETAILS NOT DOCUMENTED INDEPENDENT MEASUREMENTS:
. 53 ADDITIONAL STRUCTURAL MEMBERS EXAMINED
-HARDNESS TESTS ACCEPTABLE
-380 WELDS INSPECTED -- ALL ACCEPTABLE LICENSEE ACTIONS:
. COMPARE BEAM DRAWINGS TO ACTUAL PLANT
. DEMONSTRATE BEAM QUALITY
. DEMONSTRATE WELD QUALITY 0
4
- - == -
~
~
i l 7.2 -
1 i
INSPECTION: . CABLE SEPARATION i l
FINDINGS: .
CABLE SEPARATION VIOLATIONS AT FOUR LOCATIONS NO INSPECTION PROGRAM TO VERIFY SEPARATION ,
IN SPREADING ROOM i LICENSEE ACTIONS:
. REROUTE CABLES REVIEW DESIGN CONTROL OF CABLE SEPARATION INSPECT ALL LOCATIONS OF POTENTIAL SEPARATION VIOLATIONS INDEPENDENT MEASUREMENTS:
ADDITIONAL SEPARATION VIOLATIONS IDENTIFIED BY RESIDENT INSPECTOR 4 i
l
__t___ , gw ge -e =
- ese @@ype i '=f **+6e= <- Otz -e s + s. s .%.
~~
. . - -2 ._. . . - . _
7.3 INSPECTION: . CGaE AUDITS OF SARGENT 4 LUNDY (AE) i l FINDINGS:
- SSL NONCONFORMANCE PROGRAM NEVER AUDITED
. VARIOUS AUDITS IDENTIFIED RECURRING PROBLEM INVOLVING DESIGN CALCULATIONS AND REVIEWS '
CAUSE OF PROBLEM NOT DETERMINED CORRECTIVE ACTION NOT TAKEN TO PRECLUDE REPETITION LICENSEE ACTIONS:
. REVIEW ALL PAST CG4E AUDITS OF Sal, G.E.,
KE!, AND FOUR INTERNAL DEPARTMENTS
. DETERMINE DEPTH AND ADEQUACY OF AUDITS
. DETERMINE ACCEPTABILITY OF AREAS NOT AUDITED INDEPENDENT MEASUREMENTS:
NONE 1
l l
' ' ' " " * * ' ' " ~ " * " ' ' ~'
____._______r..__
i WM. H. ZIMMER QUALITY CONFIRMATION PROGRAM
SUMMARY
OF TASKS .
- 1. STRUCTURAL STEEL
- 2. WELD QUALITY -
l l 3. TRACEABILITY OF HEAT NUMBERS ON PIPING l 4. SOCKET WELD FIT-UP l ;
- 5. RADIOGRAPHS
- 6. CABLE SEPARATION
- 7. NONCONFORMANCES
- 8. DESIGN CONTROL AND VERIFICATION -
- 9. DESIGN DOCUMENT CHANGES .
- 10. SUBCONTRACTOR QA PROGRAMS
- 11. AUDITS l
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l TASK 1: STRUCTURAL STEEL l
.. FRonLEM: -L7 ACCEPTABLE WELDS RAVE BEEN IDENTIFIED l
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-SCME STRUCTURAL WELD PAINTED BETORE TRET I
WERE INSFECTED i
-SCME BEAMS NAVE UNACCEPTABLE RE-ENTRANT CORNERS [
-BEAMS WERE RECEIVED FRCH AN UNAFFROVED VENDOR i AND CAhT07 DE ACCOUNTED FOR AS TO WHERE INSTALLED l
01 DISPOS! TION
-MEAT NUMBER TRACEA3!LITT MAS NOT BEEN MAINTAINED FOR SOME BEAMS AND STEtt FIATE t
-CABLE TRAY FOOT CohTECTIONS MAYE NOT SEEN INSPECTED ;
AND ARE CCVERED WITH FIREPROOFINC n
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I TASK 1 CO.NT'D ACTION: -COMPARE STRUCTURAL STEEL DRAVINGS AGAINST PLANT AS BUILT CONDITION
-!NSPECT 100* OT STRUCTURAL STEEL TIELD k' ELDS.
TI*LD CUT RE-ENTRA:iT CORNERS, BEAM ESD CON!:ECTIONS, AND BRISTOL SHOP kTLDS (MAY JUSTITT LES$)
-DETERMINE THE ACCEPTABILITY OT hTLD PROCEDURIS, kTLDER QUALITICATIONS, SPECIAL REQUIREMENTS AND k"ZLDS RCD TYPE SPECITIED TOR TIELD L'ELDING
-DETEPEINE THE ACCEPTABILITY QT ALL TIELD FURCHASED STRUCTURAL STEEL PLATE AND SMAPES. ALSO DETERMINE THE ACCEPTABILITY OT OTHER T!!LD PROCURED ESSENTIAL l'.ATERIAL
'.Al:F 0%~ P. i it?tt IL STR'.'CTURAL QUALITY AS$VRANCE INCINEERS
- =3 CLERXS 12-24 QUALITY C02: TROL INSFECTORS (QUALITIID IN Ak'S k'tLD INSFECTION) t G 0
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. . f STATUS: -WORXMANSHIP SAMPLES FOR INSPECTING THROUGX FAINT AND C0ATINGS COMPLETE. REPORT Dt,*E r WOVEMBER 13, 1931 {
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-FIREPRo0FING, FAINT, A;fD CALV0X0X SEING REMOVID -
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.* TO FACILITATE INSPECTION E i
-!NIFICTION VCRX FACKAGES SEING CINERATED !
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TASK 2: kTLD QUALITY I
PR03t!M: II.* PROCESS INSPECTIONS kT E NOT PERTORMED TOR SOME kTLDS '
1 TERE ARI QUESTIONS REGARDING CONTROL OF WELD TILLER MATERIAL I
kTLD RCD REAT NL*MBERS HAVE BEEN TPANSTERRED TO kTLD DATA SHEETS BY OTERS THAN TE QC i INSPECTOR kHO INSPECTED ThZ kTLD .
/ ,
kTLD INSPECTION CRITERIA WERI DELETED TROM TXZ kTLD DATA SHIETS RESTEN JULY 1980 AND TE3RUARY 1981 ACTION: IDENTITY CODE WELDS FOR WHICH TRACEABILITY OT WELD RCD MEAT NUMBER WAS LEQUIRED BUT NOT
'!A!NTAINED
,. 10 ENTITY Att WELD DATA SHIETS TRAT HAVE l!!N ALTIRED BY TRANSCR!l!NG INTCUtATION TROM THE k'tLD 2 TCMt3 (ROD !$$UE SLIPS)
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4 TASK 2 CONT'D t
EVIEW WELD DATA SMEETS WITH CRITERIA DELETED VNICH SHOULD NOT HAVE BEEN AND VERIFT No N0LD POINTS HAVE BEEN MISSED P.ANP0VIR: LEVtt 11 STRUCTURAL QUALITT ASSURANCE ENGINEER ,(FROM TASK 1)
LEVEL II MECMANICAL QUALITY ASSURANCE ENGINEER (FROM TASK 3) 2-4 CLERKS (FROM TASK 8 1 & 3)
STAT *.*S t WILD DATA SMEETS IN QUE". TION MAVE SIEN IDENTITIID ,
WELD DATA SMEETS AM SEING MVIEWED M-1A WLD MFAIR CARDS ARE ALSO 5 TING MVIEVID
TASK 3: CONCERNING TRACEABILITY OF REAT NUMBERS ON PIPING
. PROBLDi: IMPROPER HEAT NUMBERS ON ISOMETRIC DRAWINGS -
AND PIPE BEAT NUMBERS CANNOT BE FOUND ON SOME INSTALLED SMALL BORE PIPING SOME HEAT NUMBERS ON ISOMETRIC DRAWINGS DO NOT MATCH THE HEAT NUMBERS ON INSTALLED PIPING ACTION: CONDUCT 100%~ INSPECTION OF ACCESSIBLE FIELD INSTALLED SMALL BORE PIPING TOR SYSTD'.S SHOWN ON ENCLOSURE 1 FOR STSIDiS ON ENCLOSURE 2 DEMONSTRATE THAT ACCESSIBLE INSTALLED SMALL BORE PIPING MEETS ASME CODE REQUIREMENTS FOR TRACEABILITY FOR FIELD MODIFIED LARGE BORE PIPING THAT IS ON ENCLOSURE 1 OR ENCLOSURE 2. COMPARE l
DOCD:ENTATION WITH PIPING TO DEMONSTRATE TRACEABILITY IN'ACCORDANCE WITH ASME CODE REQUIRE.M'TS c
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TASK 3 C057'D JUSTIPT ACCEPTABILITY OF INACCESIBLE PIPING MAN?OVER: 1 LEVEL III }ECHANICAL QUALITY ASSURANCE ENGINEER 2 LEVEL II MECHANICAL QUALITY ASSURANCE ENGINEER 2-4 QUALITY CONTROL INSPECTORS 5-7 DOCUMENT REVIEWERS
.-2 CIIRYJi STATUS: PILOT PROGRAM COMPLETED IN DIESEL GENERATOR ROOMS A,1,&C NONCONFORMANCE REPORTS HAVE BEEN WRITTEN INCLOSURE 1 SYSTEM DOCU1ENTATION BEING REVIEWED ENCLOSL'RE 2 SYSTEM DOCUMENTATION BEING REVIEkTQ. {
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AND SAMPLE PLAN BEING GENERATED 1 l
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TASK 4: CONCERNING SOCKET LTLD FIT-UP PROSLEM: DOCLHENTATION FOR VERIFICATION OF PIPE DISENGAGEMENT FROM SOCKET DOES NOT EXIST FOR ALL SOCKET L' ELDS ACTION: IDENTITY SOCKET LTLDS FOR kTICH DOCLHENTATION FOR DISENGAGEMENT DOES NOT EXIST
-APPROXIMATELY 200 HAVE BEEN IDENTIFIED OLT OF 7000 REVIEkTD 1
RADIOGRAPH THOSE SOCKET kTLDS FOR L'HICH DOCLHENTATION FOR DISENGAGEMENT DOES NOT ,
EXIST MANPOk'IR: LTILIZING TASK 3 & 5 PERSONNEL STATUS: RADIOGRAPHIC TECHNIQUE HAS BEEN REFINED SOCKET LTLDS ARE BEING IDENTIFIED AND RADIOGRAPHED TO DATE ONLY 12 SOCKET kTLDS HAVE BEEN REJECTED
TASK 5: CONCEPSING PJ.DIOGRAPHY PROBLEM: IMPROPER RADIOGRAPHIC TECHNIQUE (PENETRAMETER
,, NOT SHIMMED OR INADEQUATELY SHIMMED)
ACTION: RIVIEW RADIOGRAPHIC FILM FOR ALL M.W. KELLOG SHOP (PULUfAN POWER PRODUCTS)
MANPOWER: 1 - ASNT-TC-1A LEVEL III RADIOGRAPHERS
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1-2 ASNT-TC-IA LEVEL I RADIOGRAPHER (S) 1 CLERKS STA!sS: FIDI HAS BEEN REVIEWED I
DATA BEING ENTERED INTO COMPUTER COMPLTER PROGRAM NEARING COMPLETION 'QUALITYING' RADIOGRAPHS WILL BE SELECTED AFTER ALL DATA IS I';TERED A.N~d VERIFIED NATIONAL BOARD CONCURRENCE WITH PROGRAM HAS BEEN OBTAINED
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5 TASK 6: CONCIANING CABLE SEPARATION i
PROBLEM: SIX EXAMPLES OF FAILURE TO MIET CABLE SEPARATION CRITERIA i
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, ACTION: CORRECT THE SIX FAILURES CONDUCT A 100% INSPECTION FOR SEPARATION ESSENTIAL AND ASSOCIATED CABLES:
3 -BITWEEN THE CABLE SPREADING ROOM AND THE MAIN CONTROL ROOM PANELS
-AT ALL WALL AND FLOOR PENETRATIONS '
PERFORM A 100% COMPUTER ASSISTED ANALYSIS OF ASSOCIATED CABLES TO DEMONSTRATE THAT THE RELIABILITY OF CLASS II CIRCUITS IS AT ACCEPTABLE LEVELS CONSIDERING THE SE?ARAIION CRITERIA CONDUCT AN INSPECTION OF* ASSOCIATED CABLES TO ARRIVE AT THE 95/95 CONTIDENCE INTERVAL
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THAT ASSOCIATED CABLES ARE SEPARATED PROPtRLY IN TRAYS AND CONDUITS d
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I TASK 6 CONT'D MANPOWER: S&L ELECTRICAL ENGLNEERLNG GROUP 2 - CG&E ELECTRICAL ENGLNEERS
. 2 - DP&L ENGINEERS 7 - ELECTRICAL INSPECTORS STAIL*S: CO:GL7ER ASSISTED ANALYSIS UNDERWAY PROCEDURE BEING REVISED
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I TASK 7: CONCERNING NONCONFORMANCES PR03 TEM: NONCONFOR".ANCES HAVE BEEN
-VOIDED RATHER THAN DISPOSITIONED
-DOCUMENTED ON SURVEILLANCE REPORTS
-DOCUMENTED ON PUNCELISTS ,
-DOCUMENTED ON EXCEPTION LISTS
-NOT DOCLHENTED ACTION: REVIEW THE A30VE DOCLTINTS FOR THE PROBLEv.S INDICATED 1500 VOIDED NONCONFORMANCE REPORTS .
3400 SURVEILI.ANCE REPORTS 24,000 PUNCELIST ITEMS BY LETTER, SOLICIT NONCONFORMANCES FROM ALL PAST AND PRESENT QC INSPECTORS REVIEW AT LEAST 300 DISPOSITIONED NONCONFORMANCE REPORTS FOR PROPER DISPOSITION
- M.CP0~.iER: 6 QUALITY ASSURANCE ENGINEERS / AUDITORS 1 CLERK-l
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s TASK 7 CONT'D STATUS: REVIEW OF VOIDED NONCONFORMANCE REPORTS UNDERWAY REVIEW OF SURVEILLANCE REPORTS NEARING COMPLETION .
PROC 3 URE BEING GENERATED FOR REVIEW OF PUNCELIST ITEMS LETTER BEING GENERATED SOLICTING NONCONTORFECE REPORTS FROM PAST INSPECTIONS 4
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TASK 8: CONCERNING DESIGN CONTROL AND VERIFICATION PR03 LIM: S&L HAD NO FORMAL PROCEDURE REQUIRING VERIFICATION DESIGN CALCULATIONS FOR THERMAL LOADING OF POL'ER SLEEVES AND DEAD k'EIGHT LOADING OF ALL TRAYS 3 EXAMPLES k'ERE IDENTIFIED IN k'HICH S&L DESIGN DEVIATED TOILM THE FSAR S&L HAD NO F0lWAL PROCEDURE FOR DOCUMENTING DESIGN DEVIATIONS k' HEN IDENTIFIED BY ENGINEERS ACTION: DETERMINE THAT PROCEDURES EXIST REQUIRING DESIGN CALCL'LATIONS FOR THOSE ITEMS REQUIRING A FINAL l
VIRITICATION AFTER FA3RICATION AND/OR INSTALLATION REVIEW FSAR FOR CORRECTNESS AND CONSISTENCY WITH RESPECT TO THE DESIGN DESIGNIRS REVIEW FILES TO IDENTIFY ALL DESIGN DEVIATIONS 9 8 4
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TASK 8 CONT'D 4
CG&E REVIEW THE ADEQUACY OF S&L'S PROGRAM
. FOR CONTRCLLING DEVIATIONS FROM THE FSAR .
f MANPOWER: S&L AS REQUIRED CG&E VENDOR AUDIT GROUP l STATUS: ALL S&L EFFORTS COHPLETE CG4E AUDIT HAS BEEN CONDUCTED ITEM TO BE CLOSED OUT AS SOON AS AUDIT IINDING REPORT IS ISSUED l
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- TASK 9: CONCERNING DESIGN DOCUMENT CHANGES PK03 TIM: SOME DESIGN DOCUEST CHANGES (DDC) HAVE NOT
, BEEN ADEQUATELY CONTROLLED THROUGH DISTRIBUTION AND INSPECTION ACTICL , ESTABLISH AN ACCURATE A!!D COMPLETE COMPUTER LISTING OF DDC'S REVIEW OF EACH ESSENTIAL DDC AND' APPLICABLE QC RECORDS TO DETERMINE IT ALL IN-PROCESS a
AND FINAL INSPECTIONS HAVE BEIN PERFOR.E (JUSTIIT LESS THAN 100%) - ,
4 E'G0kTR: 5 OEGREED ENGINEERS WIIH QA EXPERIENCE STATUS: EFFORT UNDERWAY TO CLASSIFY DDC'S AS 2
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ESSENTIAL OR NONESSENTIAL i
REVIIV 0F QC RECORDS TO BEGIN WHEN ALL DDC'S HAVE BEEN CLASSIFIED f
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TASK 10: CONCERNING SU3 CONTRACTOR QA PROGRAMS PROBLEM: LACK OF CONTROL OVER SUBCONTRACTOR QA PROGRA*.S
, , ACTION: FOR ALL SAFITY RELATED ACTIVITIES PERFOR.M BY OTHER THAN H.J. KAISER OR GENERAL ELICTRIC, PROVIDE ASSURANCE THAT QA PROGRAMS kTRE ADEQUATE OR *JORK IS ADEQUATE MANP0kT.R: CG&E VENDOR AUDIT GROUP STATUS: SU3 CONTRACTORS HAVE BEIN IDENTIFIED, AUDIT FINDINGS BEING EVALUATED a-4._9 a e, g ' '~
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l TASK 11: ALTITS PROBLEM: PAST AUDITS HAVE IDENTIFIED REPETITIVE PROBLEMS REGARDING DESIGN CALCULATIONS Ah'D VERIFICATIONS NOT BEING FERIOR.M .
- CORRECTIVE ACTION S&L AND FOLLOVUP BY CG&E HAS NOT BEEN ADEQUATE ACTION: REVIEW PAST AUDITS OF H.J. KAISER, S&L, GE, EPD, EDTD, GED & GCD TO DETERMINE THE DEPTH AND ADEQUACY OF.THE AUDITS WITH RESPECT TO THE 18 CRITERIA 0F APPENDIX B 0F 10 CFR 50 ASSURE CLOSE OUT OF AUDIT FINDINGS JUSTIFY ACCEPTABILITY OF AREAS NOT AUDITED MANPOVIR: CG&E VENDOR AUDIT GROUP STAT"S: PAST AUDITS HAVE BEEN REVIEWED l
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EVA*.UATIONS BEING MADE l
ENCLOSURE 1
- 1. CY-01 Cycle Cendensate System - Essential Portiens
- 2. 03-01 Diesel Generators
. 3. 00-01 Diesel Fuel 011 systems
- 4. RD-02 Centrol Rod Drive Hydraulic System
- 5. RH-01 Residual Heat Removal System - Essential Portions
- 6. RI-01 Reactor Core Isolatien Cooling System
- 7. SC-01 Stand-by Liquid Centrol System
- 8. Containment Isolation - Valves and Connecting Piping 9 HG-01 Pridary Centainment C :bustible Gas Centrol System
- 10. HP-01 High Pressure Core Spray System
- 11. LP-01 Lew Pressure Core Spray System ,
- 12. MS-01 Main Steam System to See:nd Isolation Valve ,
- 13. N3-02 Nuclear Boiler System - Autematic Depressurization 14 N3-04 Nuclear Boiler Syste - Reactor Pressure Vessel
- 15. VY-02 C re Stand-by Coeling - Ecuipment C oling South
- 15. VY-03 Core Stand-by Ccoling - Equip =ent Cooling North
- 17. WR-01 Reactor Building Closed Cooling Water System
- 18. WR-02 Reacter Water Closed Cooling Water System (Inside Centainment)
- 19. WS-01 Service Water System - Essential Portions
- 20. Stand-by Gas Treatment
- 21. Feedwater - Essential Portiens
- 22. Piping that ceres in c:ntact with Primary Coolant up to the first .
Isolatten 'laive Outside Centainment 6.
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, ENCLOSURE 2
- 1. CM-01 Contain. ent Monitoring System (Possible Code Requirements)
- 2. FC-01 Fuel Fool Cooling and Clean-up System
- 3. PR-04 Liquid Process Radiation Monitoring System 4 PR-05 Off Gas Post Treatment Radwaste Monitoring System
. 5. RR-03 Reactor Recirculation Pumping System .
- 6. RT-01 Reactor Water Clean-up System
. 7. IN-01 Dry Well Pneumatic System
- 8. LC-01 Leakage Control System
- 9. NS-01 Nuclear Boiler System - Jet Pump Instrumentation
- 10. 0G-01 Off Gas Processing System
- 11. YR-02 Reactor Building Ventilation System
- 12. Reactor Building Equipment Drain .
- 13. Dry Well Floor and Equipment Drains 11 Reactor Water Sample l'. Radwaste Collaction
- 16. Recirculation Pump Seals System
- 17. Fire Protection
- 18. VP Primary Containment Ventilation li. VC Control P.com Ventilation
- 20. VX Switchgear Acoms Ventialtion
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.1/2/79 Ltr Keppler fm Soremanr. re femal rorly ir.spection report
,)I l'J/5/79 Ltr Cox im Altemuehle-CG&E checking miseenduct re Zimer 1 2/10/80 FBI report re Construction at Zimmer-Corruption of public officials j 2/28/80 Chron record of Invest re Welding Allegations a 4/21/80 PN-Allegations of Defective Welds-Zimmer
} 7/S/80 Transcript of Telecen on 5/6/80 furnished by T. Applegate t 7/8/SO Transcript of telecen on 5/5/80 furnished by T. Applegate 1 8/30/50 Ltr Borgmann fm Keppler-steps taken to correct noncompliance I 12/1/80 Memo Phillips,etc fm Norelius-Investigation reports 1 12 i un/10/80 Note to Comission fm JC re recent ltr submitted to special Councildtd-rest f/ invest i 1/81 - Interviews: G. Phillip; K. Ward; C. Norelius; G. Fiorelli; D. Danielson; R. Kncp; J. Donan~ue; J. Keppler; T. Vandel; G.Phillip & K. Ward; E. Uilliamson; T. Harpster_
}
j 12/15/80 !'emo Reg. III files fm Phillio-Zimmer Plant Allegations ,
j 12/15/80 Memo Cummings fm Aherane-T. Applegate Allegations j 1/5/81 Memo Ahearne fm Cunmings- T. Applegate Allegations i .
i 1/7/81 Memo Cummings fm Ahearne-Special Counsel ltr 12/29/80-rost report March.
1/12/81 Memo Stella fm Keppler-Rqst for Invest. by Merit Systems Protection Bd re.
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NRC Handling Applegate Allegations
.i 1/16/81 Memo Phillip fm Stello-Merit System Pntection Board-Charges by IPS <
/3I Memo Keppler fm fortuna--Confid. & restriction info forwarded by OIA '
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- N!$g$$c5$$mW&.+ fps =69-i.h-Eh -;?$$$:5[r.:.w4,g,. te,i$$$.
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- 2 /51 Ltr Clark fm Cummings-meeting w/ gap & OIA
'j 2/5/81 Memo File fm Sinclair-Investigation IE Efforts re Zimmer .
2/10/81 Memo Stello fm Cumings-Transfer Documts provided by GAP e
] .2/11/El Memo Clark fm Devine-Sumary telecen interview w/V. Griffin
,1 3/9/81 Mamo File fm Schnebelen-re telecen fm Applegate-re Keppler acusing Applegate of pesir.;
as uncercover NRC investigator.
"} 3/9/S1 Memo File fm Schnebelen-telecen fm Applegate re slander by Keppler e
3/17/81 Memo Stello fm Keppler-Investigation Applegate allegations re Zimer .
j 3/18/81 Memo Commission fm Fitzgerlad-Jurisdiction of Merit Systems Protection Board re Applegate allegations e} 7/20/81 Ltr Cumings fm Tracey-advise AUSA of status of Zimmer I 8/6/81 Memo Comission.fm Cumings-0IA Special Inquirey re Adequacy IE Investigation re Zi:- e i 3/7/81 Memo Comission fm Cummings-Adequacy IE Investigation-Final Recort of Investication J 0/17/81 Ltr Tracey fm Cumings-encl /cy OIA report of Investigation ,
[ 8/19/81 Note Thompson fm Schnebelen-enci copy OIA report of Invest.
3 9/4/81 Memo Dircks fm Palladino-0IA report of Inyst. Provide co=ents of OIA's findings #
j 9/17/B1 Memo Palladino fm Dircks-!E comments re OIA investigative findings
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) 9/17/81 9/29/81 Ltr Memo Palladino Kaufman fm Dircks-01A fm Cummings-NRC reportFOIA considering re Zimer rqst I j 9/30/81 Memo File fm Sinclair-!E Investigation re Zimmer i 10/2/81 Mamo Cummings fm Palladino-0!A Rpt of Investigation re Zimer , !
j 10/8/81 Memo Palladino fm Cumings-0!A Repott of Investigation-re EDO comments 1
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- 11.'1!/81 rc o Dircks fm Pal.* adino - OIA Ppt of Investi, s Y f 11/16/3'. ltr to Udall fm Palladino re IE inxst.
1 11/20/81 ltr to Io.enstein re partial respc .se re IVIA reg ,
] 11/27/81 lt to Sinclair fm Tracey transa neas clippings re ZL rer , ,
12/10/81 re o to file fm Ga. ble re interv of Harpster
, T-1 2/25/82 memo to Warnick fm Rhen re Zirmer doc & invest. leads <
. 4/21/S2 ltr to JC fm CBarnes re disp:sition. of invest.
l 6/24/82 me o to B0 avis fm JC transm Harpster interv 6/30/82 lt: to chilk fm Devine re appeal re ICIA 7/16/82 ltr to Palladino fm Applegate afvsg no further cooperatien fm him re subj rattar 9/5/32 ltr to Palladino fm Udall re mtg on ZLmer for 9/14 i
8/17/82 ltr to Palladino fm Devine re DJenes doesn't wish to be contacted by US Govt re
-i experiences at ZLmer plant' 1 8/22/82 r.ewspaper article re US laxity charged in nucl probe
} S/23/82 re:o to Cerission fm Kannerer - B&PV inspectors findings of centinuing audit cf ASME: ocde related construction at ZLmer 3
.: 8/31/82 note to Ccrmission fm Chilk re proposa! ltr to Udall re IGC findings at Zi.rur -
{ 9/1/82 reno to Pa.5rn fm Ea. merer re Interior Ccem. rev of test fo=s at ZL re:
} 9/7/82 re o to C= mission fm Karrerer re dft testirony f/Udall Cmm. hearing en Zi. rur j 9/13/92 re.o to Ccnission fm Earmerer re final testirony f/t'dall C=m. hearing on Zirrur F
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10/25/82 inferral note to George fm A n re survey of 9/20/82 lt note to Gilinsky fm JC re CIA survey of distributio :
11/2/82 n re 9/20/92 Applegate le 11/10/82 ltr fm C3arnes to JC re Zirrer investigation i rene to Ccrmission transm cys of l 10/19 & 11/2 ltrs fm Bames to JC 1
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