IR 05000461/1978006

IE Inspec Rept 50-461/78-06 on 780913-14 & 1005-06 During Which 3 Items of Noncompliance Were Noted:Failure to Control Special Processes (Welding),Failure to Provide Procedures & Lack of Calibr Control.W/Encl Ltrs Re Welding

ML20148A768
Person / Time
Site:	Clinton
Issue date:	12/11/1978
From:	Foster J, Vandel T, Wescott H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148A758	List: IR 05000461/1978006 ML20148A754 ML20148A760
References
50-461-78-06, 50-461-78-6, NUDOCS 7812290247
Download: ML20148A768 (24)

Text

a

{~~')

%)

'

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-461/78-06 Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Investigation At: Clinton Site, Clin' ton, IL, Husky Products Incorporated, Florence, KY, and St. Louis Testing Company, St. Louis, MO Investigation Conducted: September 13-14, 29 and October 5-6, 1978 b b~"

.?

._ )[)pf/

,.

Inspectors: T Vandelp n . , .'. $e t __J2].! hi

? d 2,63;~

J. E. Fost _/ M _2b 4 .,

Approved By/ yProjects a C eP" _ Jg/k[.2 Section 1

, ,-h , CUI' ,

.E. Norelius /2[/1[78 l Assistant to the Director I

l

_Inv e_s_t i,ga t ion Summarv

.I n v_e s t i ga t_i,o n s_ _o_n _S eft,e mb_e r ,13__14 ,_29__and October 5-6, 1978 (Repor_t_

NO _ .5,0 4_6_1/_7,8_ _0,61 Ar_e a_s _I n s p_ec t ed : Observed trays, located at the Clinton site, review of records at various locations, observations of tray fabrication at manu-facturers plant, and witness of independent testing of tray materials at a test laborator The investigation involved a total of 48 inspec-tor-hours by three NRC inspector OJu/7

.

.

I Re_sults: Three items of noncompliance (Infractions) regarding: (1)

failure to control special processes, (2) f ailure to provide procedures, and (3) lack of calibration control. (See Report Details,Section III)

,

l i-2-l l

l

.

,

.

INTRODUCTION The Clinton Nuclear Power Station, licensed to the Illinois Power Company, is under construction at a site near Clinton. Illinois. Sargent 6 Lundy is the Architect-Engineering firm for the plant, which is being constructed by Baldwin Associate The facility will utilize a Boiling Water Reactor (BWR) designed by the General Electric Compan The Husky Products Division (Husky) of the Burndy Corporation is supplying electrical cable trays for the Clinton plan These cable trays are utilized to route both safety-related and nonsafety-related electrical and instrumentation cable REASON FOR INVESTIGATION On August 31, 1978, a copy of a letter written by Individual "A" was )

received at the NRC Region III (RIII) office (Exhibit I). This letter l expressed concerns relative to the quality of electrical cable trays j and fittings, produced by Husky for use in the Clinton and Zimmer nuclear power plants, and alleged the use of weak materials and improper welding in cable trays and fitting An NRC investigation was initiated into these allegation S_UMMARJ OF FACTS Individual "A" was contacted by RIII personnel on September 8, 1978, and his concerns were discussed in genera These concerns related to the use of low strength materials and improper welding as contained in the letter attached as Exhibit During September 18-20, R1II inspectors visually inspected electrical cable trays at the Clinton site, and reviewed site records pertaining to the cable trays. Site personnel agreed to have samples of the cable I tray materials tested for material strength, and random samples of l straight and curved sections of cable trays were selected for testing by the license Cable tray samples were tested, with the tests witnessed by an RIII inspecto All of the samples tested exceeded the specified yielo poin Inspections at the Clinton site indicated that some straight sections of cable trays had been damaged in handlin Inspection of these pieces-3-

.

.

.

appeared to indicate that some of the resistance welds on straight tray sections were not sound. In addition, some trays were found to be inadequately protected and showed signs of rus Individual "A" was critical of the welding performed by Husky welders, e and the welding certification program conducted by Husky. He indicated that the Husky welders had difficulty passing the qualification tests, and welded differently during the teste than in production welding. He stated that the welders had not performed production welding any dif-ferently following the certification test Individual "A" further indicated that cable tray " fittings" (curved sections of cable tray)

were Metal Inert Gas (MIG) welded, which he believed to be imprope In addition, comments were made relative to low strength material useage and improper welding which pertained to the Zimmer plant. This will be covered in a separate report (see IE Report No. 50-358/78-21).

RIII personnel made two visits to the Husky facility in Florence, Kentuck During plant visits, the manufacturing areas were toured, work in progress was observed, pertinent records were reviewed, and interviews were held with Husky personne It was fr t the materials for the Clinton plant were pre-galvanized, as rege te cable tray specificatio Due to problems with the uti G-steel filler wire, an aluminum-bronze filler wire had been in the MIG process welding of this material. No record of qua of this MIG-Aluminum Bronze welding procedure, as requirev .ne American Society of Mechanical Engineers Code for Boiler and Preso te Vessels,Section IX, could be found. Husky personnel indi-cated that the procedure had not been qualified, and therefore their welders had not been qualified to the procedur Husky personnel indicated that the welding procedure would be qualified as required, and their welders qualified to the procedure, to demonstrate that the welding already performed was of acceptable qualit In addition, no we1 Jing procedure specification had been developed for the automatic resistance welding utilized to manufacture straight sections of cable tray, and instruments on the equipment had not been calibrate Clinton site personnel indicated that all cable trays had been placed on

" hold" status, and no further cable tray installation at the site would be performed until the acceptability of the manual MIG and automatic resistance welding of the cable pans was determine l

.

$

C0_NCLUSIONS 1. Materials in cable trays at Clinton were tested and found to be acceptabl . Site visual inspections indicate that some resistance welds on straight sections of cable pan are questionabl . The procedure utilized for the manual MIG welding of cable tray fittings had not been qualified as required by the ASME Code,Section I . Welders performing manual MIG welding had not been qualified to the procedure utilize . The procedure for resistance welding had not been qualified, nor had instruments on the resistance welding equipment been cali-brate . Husky-supplied cable pans are on " hold" status at the Clinton plant, pending a determination of the acceptability of the welding on the pan l l

l l

l-5-l

.

.

.

DETAILS Section I Prepared by J. E. Foster Reviewed by C. E. Norelius, Assistant to the Director Personnel Contacted Illinois Power Comp _any B. L. Blackburn, Assistant Manager, Power Production G. M. Brashear, Manager, Clinton Site R. Cantfield, Supervisor, Construction E. Connor, Assistant Supervisor, Construction J. Geier, Manager, Generation Engineering J. Hampton, QA Supervisor, Clinton Site J. King, Supervisor, Elec trical Construction L. Koch, Vice President J. McHood, Vice President J. Spencer, Supervisor, Field Engineering R. Unks, Supervisor of Quality Assurance Ba l d w i n _A,s s o c,i a, t e_s, I n_c o r po r a t e d Hilding, QA Manager F. Lineham, QC Supervisor Muelhausen, QC Manager H. Thorwegan, Project Engineer Pinca, QC Engineer Selva, Quality and Testing Services Manager S. Simpson, Project Manager F. Walker, Quality Controls W. G. Woolery, Technical Services Q._S ._T_e_s t,in g _Co mp an2 C. McDonnel, Engineer S t_.,_L_o u i s_Te_s t,in g _Co mp_ag

.

C. Trowbridge, President R. Kemlage, Shop Supervisor-6-l I

.

Husky Products F. L. Banta, Engineering R&D Manage D. Dietrich, Tool Engineer C. F. Duncan, Quality Control Manager C. Johnson, Production Foreman Pratt, Industrial Engineer Rigley, Welding Operator Ring, President Schuster, Utilities Market Manager Sa r_ gen t 6 Lund,v, M. E. Schuster, Supervisor, Project Section, Quality Control Division l

Individuals Individuals "A" through "D" Cincinnati Post-Enquirer j l

D. Starr, Staff Reporter ,

l S,co_pe and Chrono 1 m

This investigation centered on the allegations provided by Individual "A" l relative to improper welding by Husky. This report covers those alle-gations and inspections which pertain to the Clinton plant. Allegations which pertain to the Zimmer Unit 1 plant are reported in a separate repor l On August 31, 1978, a copy of a letter by Individual "A" was received at RlI On September 8, 1978, Individual "A" was contacted by RIII personne During September 18-20, inspections were made at Clinton and Zimme On September 20, 1978, Individual "A" was interviewed by RIII personne During September 20-22, 1978, RIII personnel visited the Husky facilit On September 25, 1978, a second letter from Individual "A" was received at RII On September 27, 1978, Individual "A" was re-interviewed by RIII personne During September 27-29, 1978, RIII personnel visited the Husky facilit . _ _ _ _ _ _ _ _ _ _ _ _

-

<

Initial Contact with Individual "A"

' On September 8, 1978, RIII personnel contacted Individual "A" by telephon Individual "A" indicated that he had been the Manager of Industrial Engineering for the Husky Products Company, a Division of the Burndy Corporation, but was no longer with the company. He stated that he had worked for the company approximately five years, and was laid off on August 4, 197 Individual "A"s concerns, as delineated in his letter of August 18, 1978 (see Exhibit I) were discussed in general term . Interview of Individual "A" On September 20, 1978, Individual "A" was interviewed by RIII per-sonnel. He indicated that his allegation concerning the use of low strength materials related to a one-time materials mixup which occurred during manufacture of cable pans for the Zimmer plant. No allegation was made that a sindlar situation existed during manu-facture of cable pans for the Clinton plan Individual "A" stated that the manual welds used to manufacture fittings (curved sections of cable pan) were poorly done, and that the welder certification program at Husky was a " farce." He stated that welders who took the tests often required many attempts before successfully passing the tests. He indicated that the welders did not perform their production welding any differently after passing the welder certification tes Individual "A" indicated that several knowledgeable people had been critical of the welding performed by Husky welders, including Indi-vidual "B" (uhose report is attached as part of Exhibit I). Indi-vidual "A" stated that Individual "B" would have no part of training ,

Husky welders unless they attended the full training course that his I welding school provide . In_ye_s t iga t i_o_n ,a t__Hu s_ky Pr odu c t s During September 20-22, 1978 RIII personnel visited the Husky Products f acility in Florence, Kentucky, RIII personnel toured i the Husky facility, observed the fabrication of sections of l electrical cable pan, and inspected equipment utilized in the forming and welding processes. Storage and receipt inspection procedures were also reviewe R111 personnel reviewed welding procedure and welder qualification documentation, and the various procedures utilized by Husky. It was found that manual welding for the Clinton cable pans had been-8-l l

<

.

performed using a Metal Inert Gas (MIG) procedure, and aluminum-bronze filler material, using semi-automatic equipmen On this type of equipment, welding parameters are set on the welding machine, and the welder positions the welding gun and pulls a trigger. The equipment then operates automatically, controlling shielding gas flow, electric current, filler wire feed rate, and time of the wel This procedure is allowed by the Clinton cable pan specificatio No qualification record for this particular procedure co' u be found. Husky personnel indicated that this procedure, using aluminum-bronze filler material, and argon shielding gas had not been qualified. This is contrary to the requirements of the American Society of Mechanical Engineers Code for Boiler and Pressure Vessels,Section IX, which was imposed on Husky by reference in their Quality Assurance Manual and the Clinton cable pan specificatio . Contact with Individual "B" Individual "B", of the Technichron School of Welding, was contacted by the RIII Investigator on September 27, 197 Individual "B" indicated that his school utilized Gladstone Labo-ratories to certify his welders, and that when Husky welders had (

difficulty passing weld certification tests, Gladstone had recom-mended him to Husk Individual "B" indicated that he did not recall all of the details of his review of Husky, but he recalled that most, but not all of their problems involved the welding of aluminum. He stated that he had fewer concerns relative to steel welding. He indicated that he had looked at Husky from the viewpoint of a consultant, I

'

with a view towards training their welders at his schoo Individual "B" indicated that he had not refused to train welders from Husky, but that he wanted the welders to take the entire training course which his school offered. He stated that Husky management only wanted their welders to be schooled in the two manual weld procedures (MIG and TIG) which they utilized. Indi-vidu,% "B" indicated that he did have some reservations that the oldo X;ky wt 4ers would not benefit from training at his schoo During the discussion, Individual "B" indicated that he was not aware that his report had been attached to Individual "A"s lette He indicated that Individual "A" had not contacted him, and that he had not been in contact with Husky management since the date of his report (Oc tobe r , 1974 ) .

- 9_

~ .

-.

,

.

. 7. ,C,o n,t a c_t _wi t h I n d i vi d u al "C'_'

Individual "C", an employee of Hobart Welding who had acted as a consultant to Husky on welding and welding certification, was con-tacted on September 29, 197 Individual "C" indicated that his first contact with Husky was approximately five years ago, and that Individual "D", a Husky Products engineer, had been trained at the Hobart schoo He stated that Husky had long been involved in welder qualification and in upgrading their welding. Individual "C" advised that five or six years ago, the Husky welders did have some welding problems, and that they did acceptable welding on the production line, but made poor qualification test piece Individual "C" stated that he believed that Husky had a good program for welding qualification testing, and had used the program to " weed out" the poorer welder . Discussions with Individual "A" Several telephone discussions were held with Individual "A" concerning the findings of the investigatio Individual "A" expressed dissatis-faction with some of the finding Individual "A" indicated that he felt that the Pusky weld had been required to be of pressure vessel qualit He was advised that the specification had not required welds of pressure vessel qualit Welds of pressure vessel quality require non-destructive exarination (fe; magnetic particle, radiographic, liquid penetrant or ultrasonic testing) as a verification of their qualit No such inspections were required by the designer for the cable tray weld _ _ _ _ _

.

- Section II

,

Prepared by E. Vandel Reviewed by D. W. Hayes, Chief Projects Section Licensee A Program _Contr_ol_ o_f_Supp_1iers A review was conducted at the site of the licensee representatives activities regarding the Quality Assurance Program for source selection and evaluation, in plant surveillance inspections, and QA audit Following are the results of that review: Source Selection and Evaluation The Baldwin Associates QA Procedures Manual and Procurement Manual provide the requirements for source selection and evaluation, source QA manual review and surveys, approved t,idders lists and frequency of QA audit It was learned that Baldwin procedures had been satisfied by a QA manual i review being performe The results indicated Husky QA manual Revision 3 as acceptable; a source survey was satisfactorily completed on August 2, 1977; and the vendor was placed on the approved supplier list on August 11, 1977. At the time of this inspection the NRC inspector was notified that the required annual QA audit of the vendor was due but had not yet been performed because of the licensee special audit of the vendor regarding the allegation Subsequent to this inspection it was learned that the annual QA audit had been completed, however, no details regarding results of the audit were availabl . Vendor Plant Surveillance Insp_ections The Baldwin Associates Quality Control Instructions were being complied with regarding surveillance inspections with a total of five inspections having been completed regarding Husky Products Incorporated, and Superstrut Incorporated (a hanger subcontract supplier). Results of the inspections, follow up of findings and planned further inspections of problem areas are ongoin Ma t_e r i_a_1 s_ ,Te_s t i n g _b,v_I n_d eye n d en t Te s t i n g. Lab o r a t o r y In view of.the allegations that were made regarding understrength material used in cable tray fabrication, CPS QA management decided i

I l

- 11 -

_ _ _ _ _ ____ _ _ _ _ _ _

.-__ _ . - - _

.

.

to randomly select representative test samples of cable tray to confirm that the correct material had been use On Friday, September 29, 1978, the NRC inspector witnessed the tensile testing of material from cable trays and fittings located at the Clinton sit Following are the results of that inspection activity: A review was conducted of the testing machine, Riehle model FA-120, its certification of calibration, the traceability to national standards of the calibrating apparatus. It was learned that the machine was accurate within 1/2 of 1 percent throughout its entire range of 0 - 120,000 pounds. That the calibration proving rings had all (total of four rings) been calibrated during 1978 by dead weight testing with the dead weights standardized by the National Bureau of Standard It was further established that the testing was performed in accordance with the requirements of the ASTM standard A-370, and that the testing operator was properly qualifie . Tensile Test Results A total of 36 tensile test specimens were tested with all testing  ;

results being in excess of the specified minimum yield strength, of 30,000 psi, by at least 25 percent. The selected specimen test samples came from straight sections of tray as well as from fittings and were relatable to six different heat numbers received on site by three separate receiving inspection reports  ;

'

(RIR) . The results of testing are tabulated in the following table:

,

Laboratory Heat Longitudinal RIR Yield Percent j Numb,er_Say le Number or Tranverse Number Point Tensile Elongation i

78P293A 42228 L S-3502 55,310 58,316 1 P293A 42228 T S-3502 46,449 59,611 1 P293B 42228 L S-3502 56,511 59,011 1 P293B 42228 T S-3502 49,719 60,292 1 P293C 42228 L S-3502 53,223 58,144 1 P293C 42228 T S-3502 48,969 60,674 1 P293Al 42402 L S-3502 50,505 57,736 2 P 2 9 3.*,1 42402 T S-3502 42,668 55,427 1 P293B1 42402 L S-3502 50,585 57,346 2 P293B1 42402 T S-3502 40,042 55,401 2 P293D 42402 L S-3502 55,951 60,408 2 P293D 42402 T S-3502 -* 61,133 1 P293E 55762 L S-3784 46,309 54,796 3 P293E 55762 T S-37S4 52,823 55,844 30.0

' -

12 -

.

78P293P 55762 L S-3784 46,020 54,953 3 P293P 55762 T S-3784 49,410 55,825 3 P293G 55762 L S-3784 39,408 50,806 3 P293G - 55762 T S-3784 43,013 50,279 3 P293H 738355 L S-3784 38,536 50,731 3 P293H 738355 T S-3784 43,067 50,737 3 P293J 738355 L S-3784 42,064 50,438 3 P293J 738355 T S-3784 46,535 50,943 3 P293K 738355 L S-3784 45,224 55,067 3 ,

78P293K 738355 T S-3784 49,396 55,009 2 l

78P293L 70432 L S-2285 42,370 49,080 3 P293L 70432 T S-2285 44,483 50,944 3 P293M 70432 L S-2285 39,924 50,087 3 i 78P293M 70432 T S-2285 47,823 50,101 3 l 78P293N 70432 L S-2285 39,512 49,329 3 P293N 70432 T S-2285 41,779 50,135 3 P2930 70766 L S-2285 40,378 49,705 3 P2930 70766 T S-2285 43,648 50,269 3 P293P 70766 L S-2285 39,795 49,650 3 i 78P293P 70766 T S-2285 44,254 50,207 3 !

78P293Q 70766 L S-2285 40,706 49,974 3 (

78P293Q 70766 T S-2285 44,280 50f553 3 l l

• Yield point determination of this sample was considered to be invalid, however, the tensile strength was a valid tes l l

1

1 i

- 13 -

-

. - - _ - _ - _ - _ - - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _

.

.

Section III Prepared by M. M. Wescott Reviewed by D. W. Hayes, Chief Projects Section 1. ,Rev_d ew o_f_Ca bl e_ Tray s an d Fi t t i n gs a t the Clinton, Site

,

The inspector made observations and reviewed selected welding procedures, design specifications, and documentation of safety related cable tray and fittings at the Clinton site as follows: Review of Specification No. K-2980, dated July 13, 1977, Amendment 1, dated June 21, 1978, to establish the fabri-cation requirement Review of "Recieving Inspection Report" Forms JV-152 (September 1977). Review of " Documentation Checklist" Forms JV-146, Revised April 197 Review of Nonconformance Report No. 101 Review of Baldwin Associates Preliminary review of the ,

I Husky Products Incorporated, Quality Assurance Manual (Ref. K-2980) dated December 3, 197 Review of Sargent and Lundy, Engineering change notice !

Nos. 584 and 61 ;

1 Review of chemical and physical test certifications for I cable tray materials, Discussions with QA/QC personne . Review of Husky Products Incorporated, Certificates of l Complianc Observations made of cable tray and fittings stored in

"the laydown area." i Observations made of straight sections of cable trays at the Clinton site "laydown area" established that the pre-galvanizing had been destroyed at each of the resistance spot welds and had

- 14 -

__ _ _ _ _ _ _ _ _ _ _______ _ ___

!

.

'

not been protected allowing further deterioration at the weldments due to oxidatio Further visual examination of a section of straight cable tray that had inadvertently been damaged in handling (the side rail had been partially pulled away from the tray bottom) demonstrated evidence of unsound resistance welding in that every alternate weld was ineffective. The sound weldments tore away portions of the base metal while the ineffective welds appeared crystalized and did not tear, but rather broke, pulling a nugget from the thinner sheet metal tray botto In addition, another straight tray was observed with one side rail completely detached, showing no evidence of fusio During the exit meeting Clinton management stated that this situation would be evaluate This is considered to be an unresolved ite (461/78-06-01)

2. Review of Cable Tra_y_s_ and Fit,ti_n_gs at the Burndy/ Husky Faci.11ty l l

The inspector made observations and reviewsd selected welding pro- I cedures, welder qualifications and documentation of safety related cable trays and fittings at Husky Products In orporated, as follows: Review of the Burndy/ Husky Products Incorporated Quality Assurance Manual, dated December 18, 1974, Revision 2, dated February 5, 197 Review of all welder qualification reccrd Review of QAP 104 " Procedure for Inspection of Resistance Spot Welding", effective date August 18, 1974, Revision No. 0 This procedure did not cover the operation of the automatic welding uni Discussion with QA personnel established that there were no procedures for the proper operation of the unit used for fabrication of straight cable tra This condition is contrary to 10 CFR 50, Appendix B, Criterion V and paragraph 17.1.5.1 of the CPS PSA (461/78-06-02) Observations made in the shop area of cable tray fabrication in progress established that calibration of instruments and gauges used on the automatic resistance welding unit were not being performe This condition is contrary to 10 CFR 50, Appendix B, Criterion XII and paragraph 17.1.12.1 of the CPS PSAR in that no measures

- 15 -

.

'

had been established to assure the proper calibration of gauges, and instruments used with the automatic welding uni (461/78-06-03) Review of production inspection record Discussion with management and shop personne Review of welding procedure specification QAP-107 Welding Pro-cedure No. 2 " Manual Gas _ Metal Arc Welding Process" dated October 18, 1974, Revision 1, and review of QAP (not numbered)

" Procedure Specification for Semi Automatic Gas Metal Arc Fillet Welding of Mill Calvanized Carbon Steel per Section IX ASME" prepared September 18, 1978, with corresponding " Fillet Weld Procedure Qualification" dated September 25, 197 The ASME Boiler and Pressure Vessel Code Section IX, subarticle QW-201 states in part, that a Welding Procedure Specification (WPS)

and a Procedure Qualification Record (PQR) are required for weldments built in accordance with the code, and that essential variables are to be listed in the WP It further requires that requalification be performed when any of the essential variables are changed. The WPS was changed in that the weld filler material used was changed from a mild steel filler to a bronzc-aluminum (non ferrous) filler, a change in an essential variable, without requalification of the WPS and welders before utilizing the changed welding procedure in manufacture of cable tray The ASME Boiler and Pressure Vessel Code,Section IX, subarticle QB-492, defines Resistance Brazing as, "A brazing process wherein coalescence is produced by the heat obtained from resistance to the flow of electric current in a circuit of which the work is a part and by using a non-f errous filler metal having a melting point above 800 F (427C) but below that of the base metals. The filler metal is distributed in the joint by capillary attraction."

Section IX, subarticle QW-492 also defines a Weld as, "A localized coalescence of metal wherein coalescence is produced by heating to suitable temperatures with or without the application of pressure, and with or without the use of filler meta The filler metal has a melting point approximately the same as the base metals."

Husky Products Incorporated, prepared a QAP (not numbered) dated September 18, 1978, titled " Procedure Specification for Semi Automatic Gas Metal Arc Fillet Welding of Mill Galvanized Carbon Steel per ASME Section IX" which was qualified on September 25, 1978, as a welding procedure. The melting points of the metals involved in this joining process are as follows: 1

- 16 -

.

'

Base metal,Section IX ASME Group 'P', Number 1, group 1 (mild steel)

- Approximately 2700 Mill Galvanizing (Zinc) - Approximately 800 Filler metal, Ak'S A5.6-76 (Bronze Aluminum) - Approximately 1700 The ASME Code,Section IX defines welding and brazing as different processes based on the melting points of the filler metal and metals being joined (base metal). Therefore, it appears that the QAP (not numbered) qualified on September 25, 1978 as a welding procedure should appropriately be qualified as a brazing procedure and tested as suc The above identified instances of nonconformances with the ASME Section IX code are considered to be a noncompliance item of 10 CFR Part 50, Appendix B, Criterion I (461/78-06-04)

VfEeSR_yed,_

1 Items ,

Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations. One unresolved item is discussed in Section III, paragraph 1.j .

Ex_it_ Interview The inspectors and the Chief, Reactor Construction and Engineering Support Branch met with Clinton Management (noted under Persons Contacted, DetailsSection I) at the conclusion of the investigation on October 6, 197 The inspectors summarized the findings which were acknowledged by Clinton per-sonne Attachment: Exhibit I l

.

l l

l l

l

- 17 -

l

,

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

.< .e

.

.

_

August 18, 1978 Public Interest Research Group 2000 P Street N. Washington, D. C. 20036 Attention: It. John Abbotts Dent !&. Abbotto:

I am vriting this as a former employee of Ibsky Products Inc. of Florence, Kentucky to repert serious and deliberate non-ocnferaance to 10 CFR 50 Nuc] ear Requireients and Engineering Specificaticns based on the e.bove require: tents. Te mtke it even verse they eend eut note.rized Certificates of Compliance with the full knowledge they are fals In May of this year I had occasien te visit the Ziaier Nuclear Containment

-

area and to see the ssrlous control areas and in particular to see Hasky cable trays in pesition and anny filled with the cable Since thie visit I have been disturbed by two aspects of R2 sky's neo-con formance, particularly as they relate to the etfe opsratico cf this plant after completion of constructio These two 1aportant aspects are as fellevs:

1. Use of inferier and weak caterial completely out of specification . Traye velded by incompetent velders with every type veld defoot present in overy tray. assembl Tne follcaing illustratee thess two sspects in nore detail. Thsy are related to the Ziamer Jeb specifically which was the original job with the 10 CFR 50 requirements. On this job flagrant and serioue non-confor2-ance occurred and with this ne a pattern it has occurred en all subsequent job MATERIAL:

All tray is damigned vtth a lcma capacity whieb iricludes a cafety facte The tensile d angth of the side rails largely determines this capacit On the ZLmmer job the tensile strength of the side rail naterial was to be in excess of 35,000 pourds. Ibsky received and tested material as lov cs j8,000 pounds and a considerable R2ount in the range of 20 te 23,000 pound Some vas rejected, sois accepted en the basis it would be ured for fittings where strength is not as critical.

l Exhibit I Page 1 of 7 l

l

_ _ _ _ _ _

w ..

Page 2.

'

Instead the material was not kept saprate and thus many very weak sida l rails wore made up into long straight assemblies. After finding out that i coaton till steel varied se videly in tensile strength no more testing vne done so that they could remain " unaware" of this condition. Incidentally some testing of T-6 aluminus was alee performed and a vide range of tensile i strength was aise found. This was also ignored as above. What this aeds upts l 1s that Nsky has built tray that vill not carry the rated lead even with eafety facter include j l

WELDING:

The Zinmer jeb was the first job requiring the use of Certified welders in ordar to insure goed velds. msky centrseted with Gladstone Laborateries of Cincinnati to set up a welder certifiestien progru. They did this and then tested all the velders. Without exception they failed the tests micerabl Wsky then called in various velding Engineers and W. Ind "J" ef Tech-nicron Scheel of Welding in Cincinnati who submitted a written report of findings. A copy of his report is attached. In general all the veld Engineers

. concurred with Mr. Ind."J"s repert. Mr. Ind ,"J" vas asked if he could er veuld train the veldere. He refused, stating that it la very difficult, if not nearly inpcesible to untrain people first, then try to retrain, than it is to start fresh with a pereen having ne prier velding knavledge

. or experience, msky then proceeded te work on their own in crash programs in which the veldore finally velded one piece which vould pass a bend test. This velder then becue " Certified" by msky. However., what is critically important is that nething eccurred to the quality of the production velds! In fact it remains te date in the sue sad state as Mr. Ind. "J" findings dated Octeber 33, 1974. Just a few voeks age one velder was " tested" over 60 times before he finally nade a test piece which was only narginally l acceptable. Now he is a leky " Certified" veldor!

Starting in July and continuing this month a new type of nsn-conferaanee -

,

is presently in process on the Clinten jeb. Fittings are being Mig spot l velded contrary to specific Engineering requireients. In addition Aluminum l Bronze filler rod le being used with full knowledge that aluminum is not permitted in the centain,ent area. Even verse the position of the spot '

le in ouch a manner the veld is less than 35% offective!

Substantiation of all these charges can be eccezrliehed thru examination of Esky docu1ents in relation to Material and to the Welders by tha records, visual examination of the velds and by ratesting the so called " Certified" welders by a ca rpetent Welding Engineer. Visual inspection of the Clinten fittings vill substantiate the charges outline Exhibit I Page 2 of 7

- ,,.

.

.

.

.

Paga What distufts me even more than the actual incidente described is the fact se many top . management people see nothing wrong in all these action So little real concern is shewn to producing a truly quality product within the specifications. This sheuld becese even more particularly so when nuclear safety is directly intelve ,

Yours truly, Individual "A" Distribution as follows:

EngineerinE Companies that may er may not be concerne Ebasco -

United Engineers and Constructere Bechtol Cor Brown & Root 1

- Brad;i? h m E M l Sargent & Lundy Stons & k'eboter Black & Veatch Tale may not be complete, however to the best of my knowledge it i l Governaent Agancies:

Nuclear Regulatory Coxiission Congressional Joint Atoxic Energy Comiittee Private Group:

Public Interest Research Group Exhibit 1 Page 3 of 7

.

*

g . . , ,. .

.

l 0%

4./

Report of the pindings at Husky products Incorporated on October 30, 1974

,

Submitted by: ..

Technichron Inc., school of Welding

.

It was generally found that the reason your company has had difficulty l in certifying your weldors is due to the fact that while some of your men are qualified we] dors, they suf f er f rom the ills of an employee that in offering an incentive progra In order for an employee of your company to meet his required production,icvel, plus benefit by the incentive program it was found that their welding machines were set at maxiumum output allowabic, which ic just below the l

' point,of blowing holes in the parent metal. This condition creates improper

- welding' methods, and instead of establishing good welding, you have a situation of b)nsting the metal togethe These extreme emperage settings g

also make it necessary to use higher gas flow in order to control the

,, arc. Thic has to be er.tremely costly to your compan ;

because of the conditions that exist (welding machine settings and gar flows) it was observed that improper welding is a common oce6rance at llucky products. The welds are not structurally soun l Aluminum Welding:

_

A11 the* welds have craters and it was observed that most of these craters chow the common condition known as " crater cracking". It was

-

furt her observed that there were many welds that had both cracking conditions in the wcld as well as the crater. These conditions are primarily caused by the extremely high nmperagen und gas coverag Your weldors are running extremely hot welds due to speed and thus you have rapid cooling conditions and cracking. The high gas flows (while costly) olso causes rapid cooling and thus crackin ,

Generally it was observed'lhat the weldors in your aluminum welding  ;

arons had good welding techniques however Inck knowledge in setting l up thc. proper welding conditions.before weldin (

.

s Exhibit I Page 4 of 7 l

.

- - . - .. . .- - .-. . . - -

.o , * .

.

'

1s

,

w -2-These een lacked the following knowledget Setting the welding machine

' Setting the proper gas f' low lialling the tungsten rather then pointing it Controlling the weld to prevent craters Cleaning the parent metal before velding Steel Woldjsg: .

Tour men were obr.crved in tLe stec) weldint, creas. One man had the knowledr,e of proper rnachine and gas flow settings however he lacked

,,

the welding iethniquen. This man was one of your oldest welder The other three men had very little knowledr,e about proper settings and one of the three lacked the proper welding techniques. This man una your oldest employee in your welding department. Again it was

, apparcot that all conditions exfsted to turn out maximum productio An Jony, as ynu have ther.c ennditionn you will find that certif ying weldor:. )

is [pator, t o be ext remely dif ficult. When observing several of t he tent l couponn run by yout veldors it was found that the follo. ting conditions exl ct ed t

, Crystal 11zations of the veld Porosity renettation that exceeded 100% Undercut Weakiny, of pat ent ructal in t he heat ,

cf f eet ed *(nie All the (undittuns are created directly by running too high of emperageu, too high of roc flows, und dirty meta Exhibit I Page 5 of 7

..

es#

e

---

._ _ _ _ _ _. _

, , ,

,

. -

.

.

,

3 , ./ .

Other Observations: The using of fans in the velding areas is common practice. This condition causes

the gas shield to be blevn away, thus esusing porosity in the welds. This is another reason for the high gas flow pressures which is costly

,

since larger volumes of gas,are used then necessar . It was noted that Argon /CO mix was being used in your H.I.G. welding operations on steel. This again is costly because CO2 yould be edequate for your operatio StgaightC0 costs about 1/6 of what 75/25 Argon /co mix cost . Many of your employees do not use eye protection <

or face protection. I'm certain you must have frequently absentecism due to cyc flash injurie * b'o use of saf ety glasses in the entire plan Walders most wear safety ginnnes under their welding hoo (An OSilA Standard).

-- The plant is not in complinnce with OSilA Standard This could cause extreme hardship in the future especially if you have a severe injury of one of your employee Suggetion:

llucky* Products Inc., should consider a training program for thoses individuals employed in their welding department. This program should einphasize welding methods as well as welding technique Any success arising f rom this training program is highly questionable, since proper welding methods and techniques would cut production. The

!

present attitude in your welding department is quantity not qualit ;

Sound certified quality welds will definitely reduce quantity, however -

l the savings in cost of materials will most likely improve or equalize profit Exhibit 1 Page 6 of 7 l

L .

J

.

... ,- - .- - - - - -

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

. . . :

.- - .

,

.

.

j 0 . I, -

l 1 em submitting this report with the intension of creating many {

constructive suggestions and have no intension to sound like I am j being critical. You realized you had some concerns or you would 1 have never contncted Technichron in the first place. Therefore, l 1 silicerc2y hope that I have been of. service to your company and  !

that we tr.cy cerve you again in the futur Thank yo Respectively Submitted Individual "J" ,

Technichton School of Welding

.

..,

.

I Exhibit 1 Page 7 of 7

.

l-t

!

.

l l

l

'

I s - . . .

e -- - .--- - y yw-re e 'w'*- -