ML19241A957

Intervenor Miami Valley Power Project Answer to Cincinnati Gas & Electric 790420 Fifth Set of Interrogatories

ML19241A957
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 7907110468
Download: ML19241A957 (5)

Text

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.NUCI.ZAR REGCIAKEY CT.!!SSIO.'i />

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In the Matter of ) ..d%

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The Cincinnati Gas & Electric ) c ,

p Cc parc., et al. ) rocket No. 50-358 N .t !'i d

('.t H. Zim2r Nuclea.r Pcwer Staticn )

MIAMI VAllzi FOER PP2 JECT'S KGE K; APPLICAN'IS FIFI'H SET CF I.VIIFKCA~ CRIES

1. Descrite in detail what leads the Project asserts are carried by vertical segnents of cable trr 3 under all leading conbinaticns.

The vertical segments are carr/ing greatcr loads than are allowtd by the specifications.

2. If the vertical welds carried no lead would the Project assert they were

" critical."

Yes.

3. Describe in detail which vertical welds Mr. Hofstadter inspected, against which specification he inspected, and, for each weld which was asserted to be defective, the precise way or wnys the vertical welds did not meet these specificaricns.

The welds cn the three piece ccnstraction lack fusicn. Mr. Hofstadter kncws that the welders wto made these welds were not certified and unable to make a weld with fusion. Specificaticns AS,E secticn 9.

4. D3scrite in detail the cable tra*/s or segnents therecf which the Prcject asse" s are evericaded.

Ever/ cable tray that has cables alrve the criginal sides of the tray

5. Fcr each cable tray identified in respctse to Interrxatcr/ 4, state :. dern i the basis for the asse-ticn that such cable tn/ is everlcaded, describing i .

detail any speci'icaiten er dcc =entaticn utilized by it er relied upcn.

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5. an:ner Necal and custctnary practice is to fill the trays no more than 7T full.

6. Describe in detail any heri2cntal caole trays which the Proj+xt asserts :s defective, state the location and basis for each such deficienc:, asserted by th+

Project.

Ncne

7. State in detail the basis fcr the assertion that, as a rale welders were pennitted to make welds en cable trays for which they were not certified. Ident if:,

all involvcd individuals and welds.

Welders cculd never pass the certification test. Mr. Hofstadter had the jcb of evaluatira the test pieces the welders made; he inspected the test results and fcund than not qualified to pass the test. Welders involved:

1hrvin Brock, Junior Allen. Welds involved: all vertical fittings with three piece ccnstruction.

8. State stether the Project is asserting that a welder must te certified cn all welds pricr to being pennitted to make a weld for which he is certified.

No.

9. State in detail the reascns why the Deccler 4,1M8 letter to Mr. Edwin Hofstadter as it applies to the Zi:aner Station is not dispcsitive of the allegations regarding cable trays.

See atacted letter fran l'r, Hofstadter to .tr. ?:ept ler, dated Ee cter 22, 1978

10. State in detail the basis for the asserticn that for vertical fitt ncs, "the enti e weight of the cables depends wtcily -lCO percent- cn the welds.

If the weign: cf the cables is tco g eat fcr the welds the cable trays n il break apart. Laws of physics.

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11. With recard to the cable trays, state specifically wtat pcrticns cf the /~'r Eciler and Pressre Vessel Codes. including all addenda and cod es, the Project asserts are applicable and explain n deta 1 the basis for ycur respcnse.

ASE section 9, dealing with welding of Eciler and Pressre Vessels, states minimun welding standards and states the test for certificaticn of welders to make welds. This test is the 1cuest allowable standard in the welding trade.

12. State of the Project is asserting that The Welding Handbock is part of the ASE Eciler and Pressure Vessel Code er that :.: has any legal binding effect. Identify the auth:r and publisher of The Welding Handtcck.

Yes, because tid which wns accepted for the welding jcb included a requirenent of meeting ASE section 9 standards.

Author and publisher: !cerican Society of Mectnnical En;;ineers.

13. State if the P:tject is asserting that a Zi:rer Statica cable tny is a pressure vessel or bioler and the basis for such assertion.

A cable tray is neither a pressure vessel ncr a boile .

14. Eescribe any written ccrrespondence or dcc' rent related to this centention in the pcssession of the Project act already sent by the NFf Staff to all pan ies in this proceeding.

Ncne.

15. State the educaticn and trailing cf Str. Tan Manin which enables him to evaluate the acceptance speci'icaricts fcr ccntrol rods.

Jcurnepan millwright since Novei.:r, 1973.

16. Identify the Other two millwrights who l'r. Ean in claims werf '

layed (sic) cff." -

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Ke;u;7'Camntell, Everett Ccyle.

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17, State in detail the basis fcr the asse/ticn that Mr. '.'artin and the tsc other callwrights were "laycd (sic) of f" tecause of ccncerns exprcesed ab,ut lack of cmpliance wath specificaticns.

Ctjecticn

15. D2scrite in detail stat sp+rificaticns the Prcjwt allcges were not teing emplicd with in regard to ccntrol rod acceptance.

Ecughness of seals; size of rodis.

19. Identify with particularity the individuals Mr. Martin ccntactcd, the date of centract, whether such centract was in writing cr recordtd and the substance of Mr. Martin's allegations and the dispositicn of such allegation.

Scott Swnin, inspector at Zimer, Bud Crane, superviscr for PfI; Mr. May, James Foster, S?f. Dates and modes of ccntact unkncun.

20. Respcnd to Interrcgatcr-/ 19 for the other two millwrights.

Unknown

21. Identify the individual by name, position, and c plcyers who infon:xd Mr. Martin of the acceptability of the procedure because "wnter p.cssure will adjus the diameter to specifications."

Bud Crane, supervisor at PCI

22. D3scrite any written ccrres;rndence or dCCJnent relatcd to their ct.ntentica in the possessicn of the Project not already sent ty the STf Sta'f to all parties in this prcceeding.

Ncne

23. Eest' rite in detail the n=ter and 1ccatice of all seals stich tr.e Project allcges do not axet specificaticns.

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