ML19241A944

Intervenor Miami Valley Power Project Answers to NRC 790420 Interrogatories

ML19241A944
Person / Time
Site:	Zimmer
Issue date:	05/09/1979
From:	Kosik L KOSIK, L. S.
To:
Shared Package
ML19241A935	List: ML19241A934 ML19241A944 ML19241A951 ML19241A957 ML19241A964
References
NUDOCS 7907110456
Download: ML19241A944 (7)

Text

REL.tra ce.r,

-v.m. . .myce L?'ITED S"AT S CF X, ERICA

'TC'JJ.R EEGULAZE'i CCt."dISSICN ei i s- .cf In the 5'atter of ) S ' ;\.

/ s.s, e- , .\

e The Cincinnati Ga.s L Electric )

,V ' -o 7 :,D d-Ca=any, et al. ) Docket No. 5Cw35E -

Q' ba Ws^v I 4 ev C.6 H. Zi:rer Nuclear Pcwer Station ) 9 e cQ.b y E

MIA"I VF mi PCVEP. FFT . _T ' S A'GE 4 E SFf S~AF7'S IN1?.ECGAXRIES 4

1. Identify and descrite the inadequac the welds upcn the electric cable trays.

The welds lack fu.cicn therefore they do not have the necessa /

streng.h-

2. Identify and describe w. wtat wny the weIds f ail to meet NFf specifica:icn.

MVPP caly kncus of specifica:icns accepted in the welding trade and that they were not ca plied wich as required by the centract.

3. Identify and desc-ihe in what way the welds fail to meet AS:,E specifica:icn.

The welders who welded the vertical fittings were unable to make a weld with fusicn there:cre the welds they made lack fusicn-

4. Identi'y and set fcrth the NFC and AS'E specifica:icn which apply Ic welds upon electric cable trays.

AS'.E secticn 9; NFC srecificaricns iccun.

5. Is the =:egrity of the cable m ys a necessa / safety functicn cf plant cperaticn. 4, i .

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y,es s , - --

l 7907110 (N t' /

6. Set forth the basis for ycur answer to interrcgatcrv no. 5.

Cable trays are stacked three en tcp of each cther. Cne level ccntains the prunary s/ sten, the other two levels ccntain the backup syst es. If one level breaks it will, due to added weirht, very lj'<el:. break the trays cn the other levels which cculd cause icss of electrical power for teth primar;; and back-up safety systes.

7. Does Cincinnati Cas and Electric Ca pany (CGEE) apply standards to welding the cable trays different than those required by :E.C?

Unknown.

8. Identify and descrite the qualifications required of welders in order to weld upcn the cable trays.

pass test set out in AS',E section 9 and then perfe m production welds with the sa:ne quality as the test welds.

9. Identify and descrite the lack of such qualificaitcns by welders-setting forth the time period that such alleged unqualified welders welded and identify the trays upcn which they are alleged to have welded.

The welders could never pass the test in ASE sectica 9. Rey never had foral welding training. The entire time during which the:;

welded the vertical fittings on the cable trays. All vertical fittings cn all cable trays.

10. What is a " certified welder pursuant to .Wf regulaticns (see Saul Rigter; filing dated April 2,19~9, page 8, line 5)?

Sis refers to a welder wtc is cen ified pursuant to AS'.2 secticn 9. h A

N

-h)b$ 2-6]

_3_

11. Identify and descrite una*. is a prcper test of a weld uccn a cable tra)

Tes the welder to see that be is qualified to m..tke a weld wn h fusicn, then inspect to sea that prcduction welds are perfomed in the sre manner as test welds.

12. Identify and descrite what tests were made by CGdZ cf the welds upcn the cable trays.

Tore welds apan. Ne vertical fit:=gs were tested.

13. Identify by nre and address all expert witnesses which ',nTP intends to use at the hearings to substantiate centention 14.

Unkncun at the present time.

14. Sur.arine the testimcny of all exper witnesses whir" 1STP intends ic use at the hearing to substantiate its centention 14.

Cbject

15. Set forth the qualifica:icns of all expert witnesses which the ISTP intends to use to substantiate its cententicn 14.

See answer to interrcgatory 13.

16. Identify all ganhic materials used by, or in the pcssessicn of,

.\nTP cr any of its meters or censultants which tend to suppcr cententicn 14.

Ncne.

17. Will ETP make the gaphic materials identified in respcnse tc intercga: Cr>

no.15 volun:rilj available to .'EC Staff fcr exnminaticn and ccpyrg during nc=al busmess hcurs in the peater Cincinnati metrcpolitan rea?

Yes, if any ccr.e mio .\nTP's pcssessicn-

,r . .*

le. !dentify and describe what aspect of :he manufacturing prccess was inade:;nte.

Cr):ncwn 27 db WV

19.  ;&at prt of a ccntro'. red was inadequate 1:. manuf actured' The t. lades

20. Tnat is the inadequac; of the control rcd resultinc frtn the allend inadequate manufacture?

The blades re arcarently too large.

21. ' mat spec 4'ic part of the centrol rod is affected by imprcper i

.innufacture ar.c how does this effect the perfor.ance of the ccntrol rcd?

Cversined rcds may not move as freely as necessa f

22. '# hat is the sine specification for the centrol red which is not met te ause of i.~prcper manufacture?

.250 inches

23. How is the c< atrol rcd measured to deter.ine wtether it ccn#ce.s to the sine specification?

A "go or no gd' gauge is used.

24. Identify by name and address all expert witnesses which '..Gp intends to use at the hearing to substantiate Centention 15.

Unkncun at present time.

25. Sur.arize the testi:nony of all expert witnesses stich .'.fipP intends to use at the hearing to substantiate its Cententicn 15.

Cbjecticn.

..s ,,r-Set fcrth the cualificaticns cf all expert n tnesses %nic.. ts.e

26. .

intends to se to substantiate its Cententicn 15.

N See answer to interrccatory 24.

w, .

t. i i

-o-27, Identify all g aphic materials used by , or in the pcssessicrc of, SnTP cr an- , of its certers or censultants stich tend to e uppcrt Cententicn 15.

Ncne

28. Will .\STP re.e the g-aphic materials identified in respcnse to interrcgator'/ 27 vcluntarily available to NF.C Staff for examinaticn and ccpyi .g during nc=al business hct s in the greater Cincinnati T.etro-politan area?

Yes, if any cane into SSTP's possessicn.

29. Identify ar.d descrite with prticularity the seal.s .uleged not to meet minirun specifications, including a descripticn of where they are located upcn the centrol rcd.

Seals are lccated at cne end of the con:rcl rod.

30. Ecw many centrol rods have defective seals?

Crlmcun.

31. Identify and describe the "minican specifications for smoc:hness" for all seals identified in response to interrcgatorf 29.

A rcugn su-face gauge was used to cc=re the surface trcuthness/

rcughness to specificaticns.

32. What is the raterial cf which the seals are cc=csed?

Unkncwn.

32. 2escribe the manufacturing prccess by wnich the seals re made srcc:h Url=cnn-

34. "escrite the testi .g prccedure used to deter.ine wtether the rcc:hness of the seals meets the mindran specifica:icns identi'ied i". respcnse to

=remga cr/ 31 atcve.

s s

See arh.ver Ic questicn 3'. a D

-O.I

35. What is the water leakage rate per each alleged defective seal?

UrG=cun

36. Eces CCE have any provisicns for collecticn of unter due to the alleceu defective seals?

Unkncun

37. Describe the creraticnal rnode when the seals would be cperable and what activities lead to their beirg needed.

Unkra.m

35. Are defective seals new installed at *.he Zir.er facilit.*

Apparently

39. Has TE been informed that it has installed defective centrol rod seals at the Zir.er site?

.1pparently

40. What acticns has CCE taken to remedy the installation of defective seals, if the respense to interrcgatory 38 is yes?

Unkncim

41. Identify by nr.e and address all expert witnesses who .mTP intend to use at the hearing to substantiate its Cententicn 16.

Unkncu- at present time.

42. Sur.rine the testing of a'l e per* t nesses which m7P intends to use at the hearing to substantiate .ts Cententien 16.

Cbjection b

n. '

,,b

_7_

43. Set fcnh the qualificaticns of all expert witnesses which 'A7D intends to use to substantiate its Contenticn 16.

See arsaer to interrcgatcrf 41.

44 Identify all graphic materials used by, or in the possessicn of, EPr mr any of its me:bers or censultants Ahich tend to suppcrt Ccntenticn 16.

None

45. Will ETP make the graphic ::ateri.11 identified in respcnse to interrcgatcr/ 40 voluntarily availabl.3 to the SP.C Staff for exa:nination and ccpying during ncIral business hcurs in the greater Cincinnati

netrcpolitan area?

Yes, if any ccrne into ETP's possessicn.

')

Dated: 1hy 9, lW9

- pk Leah S. Kosik Attorney for 57P

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