ML19248D326

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Direct Joint Testimony in Opposition to Contention 14 Raised by Miami Valley Power Project Alleging That Cable Trays Were Not Properly Welded
ML19248D326
Person / Time
Site: Zimmer
Issue date: 06/04/1979
From: Vandel T, Wescott H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19248D324 List:
References
NUDOCS 7908150606
Download: ML19248D326 (12)


Text

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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY LICENSING BOARD In' the Matter of

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Docket No. 50-358 CINCIN'!ATI CAS AND ELECTRIC COMPANY

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(W=. H. Zi==er Nuclear Power Plant)

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DIRECT TESTIMOTi 0F THOMAS VANDEL AND HARVEY WESCOTT REGARDING COhiENTION 14, CABLE TRAY WELDING State of Illinois

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County of DuPage

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Tho=as Vandel, having first been duly sworn, hereby states as follows:

I a= e= ployed by the NRC and as the assigned Project Inspector for the construction phase of the W:. H. Zi==er nuclear power plant for the Region III office of Inspection and Enforce =ent.

I have held this assign =ent since April 25, 1975, along with other such project assign =ents.

Education I a= a graduate engineer with a Bachelor of Science in Electrical Engineering degree awarded by the University of Nebraska on June 5,1950.

In addition, I have taken courses in Mathematics and Physics at the University of Idaho, Idaho Falls extension during =y work assign =ent at the Reactor Testing Station located near Idaho Falls, Idaho.

NRC Training I have satisfactorily co=pleted tha following training courses required by NRC.

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Boiling Water Reactors October 1975 Pressurized Water Reactors November 1977 Concrete Technology June 1978 Non-Destructive Testing January 1975 Fundamentals of Inspection June 1978 Experience I have been e= ployed by the NRC (Nuclear Regulatory Coc=ission) and before that with the AEC in the Region III office as a Reactor Inspector since December 1970 and have had a number of different facility inspection assign =ents.

From June 1969 to Dece=ber 1970, I was the Qualit-; Assurance Manager for Peter Kiewit Sons Company, the Mechanical Contractor for the construction of the Fort Calhoun Nuclear Plant located near Blair, Nebraska.

I prepared the Quality Assurance Progra: Manual for the project and was responsible for adequate quality of all material and components as well as for their installation. From May 1957 to June 1969, I was e= ployed by Phillips Petroleum Company having had several assign =ents at dif f erent locations. Those pertinent include the assign =ent at Grants, New Mexico fro: June 1953 through March 1963 as Maintena..ce St ?arintendent of the uranium =ining and tilling f acility located in the Ambrosia Lake area of New Mexico; and frc: April 1963 to June 1969 I performed assign =ents 2s the Plant Engineering Supervisor for the Test Reactor Area (TRA) and tue Qualit:.

Control Engineering Superv.sor for the LJFT (Loss of Fluid Test; and PBF (Power Burst Facility) safety testing programs at the reactor testing station near

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. Idaho Falls, Idaho.

I am a rkgistered Professional Engineer in Quality Engineering with the State of California and as a member of the American So'ciety for Quality Control (ASQC. as well as a cember of their Energy Division.

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Harvey M. Wescott, having beeh duly sworn, hereby states as follovs:

I a= e= ployed by the NRC as a Reactor Inspector in the Office of Inspection and Enforc ement, U.S. Nuclear Regulatory Co==ission, Region III, '

Glen Ellyn, IL.

I have been assigned to Region III since April 7, 1978.

Prior to that I was a member of the NRC Region IV office in Arlington, TX as a Vendor Contractor Inspector. My educational and professional qualifications are set forth below.

Education and Training High School Graduate Westport, MA 1946 Electrical Power Generation Ft. Gordan, GA 1951 Carbon Dioxide Generation Ft. Belvoir, VA 1957 Nuclear Power Plant Operators Course Ft. Belvoir, VA 1958 Auto =atic Combustion Control Philadelphia, PA 1959 Industrial Radiography Watertown, MA 1966 hetals In1pection Watertown, MA 1966 Mcgnetic Particle and Liquid Watertown, MA 1966 Pentetrant Inspection Weld.ing Inspeccion Watertown, MA 1966 I= pact Testing Watertown, MA 1966 Ultrasonic Inspection Watertown, MA 1966 Radio'ogical Safety Inspection Ft. McClellan, AL 1970 Welding Technology and Codes Course Ohio State University 1976 Boiling Water Reactor Course Bethesda, MD 1976 Quality Assurance Glen Ellyn, IL 1978

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. I have hcd formal courses in nuclear engineering, thermodynamics, radiological safety, health physics, welding, electrical engineering,

=e'chanical engineering, =athe=atics and pneu=atics as stated above.

Experience My present assign =ent with the NRC, Region III dates from June 1978 and includes responsibilities related to reactor inspection.

I a= responsible for inspection of nuclear power plants in the construction phase, inspecting mechanical syste=s, welding and quality assurance syste=s and records to verify compliance with NRC requirements and licensee co==itments.

My assign 2ent with NRC Region IV dates fro: April 1975 where I formulated inspection plans and executed the inspection of vendor f acilities supplying components to the nuclear industry.

From 1972 to 1975 I was a high school teacher at George Stevens Academy, Blue Hill, Maine.

Fro: 1969 to 1972 I was the Plant Superintendent of the SM-1A, a pressuri:cd water reactor located at Ft. Greely, Alaska. My responsibilities included administration of plant operations, electrical and mechanical maintenance, refueling of the reactor, shipment of spent fuel and radioacttve waste and inspection of =aintenance welding and plant modifications.

I was also responsible for saf ety of plant operations and prevention of health hazards to the surrounding population.

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, From 1966 to 1969 I was the c'perations supervisor of the SM-1, a pressurized water reactor located at Ft. Belvoir, Virginia. My responsibilities include safe operation of the plant, training of operators in plant startup, normal and e=crgency operat as, and shutdown, development of operating procedures, investigation and reporting of plant =alfunctions, perfor=ing refueling operacions.

From 1959 to 1966 I was assigned to the gas turbine test f acility testing gas turbines for the ML-1 project, a portable nitrogen cooled reactor and gas turbine driven generator. My dueles consisted of construction of the test asse=bly, electrical and mechanical maintenance, and operations.

I was further assigned to the National Reactor Testing Station in Idaho and qualified as operator and shift supervisor of the gas cooled reactor exper iment, a swi==ing pool reactor.

I was further assigned to Aerojet General Nucleonics in A: usa, California as the liaison officer and perfor=ed operational duties of a gas driven turbine generator to be u ed in the ML-1 project.

I was reassigned to Idaho where I qualified as an ML-1 operator and shift supervisor and also assisted in the initial fueling of the M1-1 reactor.

Frc= 1958 to 1959 I was a student with the U.S. Army Corp. of Engineers Reacter Groep in the Nuclear Power Plant Operaters Course at Ft. Belvoir, Virginia.

I a= a registered Prof essional Nuclear Engineer in the State of California.

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- The Miami Valley Power Project has raised the following Contention:

Contention Number 14, Cable Tray Welding Cable trays containing electrical wires have been inadequately welded by i= properly qualified welders, contrary to NRC regulations. More specifically, three piece verticals and

two piece channels were welded by people not fully ASMI certified. These welders were not consistently able to produce a quality veld with good fusion, a situation aggravated by Husky Product's incentive syste= which induced quick blasting techniques to be e= ployed. Furt.her disregarding standard procedures production welding techniques and test welding techniques were not identical. Any meaningful inspection of the crucial three piece vertical welds is inpossible because the trays have been galvanized. Therefore, the existing syste=

of cable trays must be dismantled and a new set welded by fully certified welders and installed.

Our testimony addresses this contention Cable trays used in the Zi==er. -C_ity were =anufactured by Burndy-Husky incorporated of Florence, Kentucky and consist of three types of trays:

(1) three piece straight tray used horizontally normally 10 feet long having two side channels and a corrugated botto: plate (solid) welded together by resistance spots welds by an automatic resistance spot weld

=achine, (2) three piece vertical tray utilized in straight vertical runs also having two side channels but with a flat plate for the back of the tray.

These trays are also welded with the same automatic resistance spot veld =achine, and (3) fittings that provide the transition trays frc=

hori:ontal to vertical, changes in directicn horizentally er vertically or T-sections. These transition trays =ay have either single piece side channels or 3 piece side channels fabricated fro = three separate pieces by welding. This velding being done by a =anual Tungsten Inert Gas (TIG) process by a p:alified welder. The tack welds arc approximatelf one inch i :. t> : n

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long and are spaced every twoI to three inches along the welded joint.

These side channels are then spot welded to a corrugated solid botto pfate. This welding is done by either a resistance spot weld =achine or by se=iauto=atic metal inert gas (MIG) process as necessary.

These trays when installed in the Zi==er facility are supported by seis=ically designed hanger with support spacing of straight runs not to exceed 9 feet in length. Fittings are supported on both ends by seis=ically designed hangers. The designer, Sargent and Lundy Engineers, (S&L) specified that the cable raceway syste for Zi==er (both conduits as well as cable trays) will be designed adequately to sustain a seis=ic event by reliance on the support hanger syste: not the trays themselves.

The trays, themselves, provide little cr no support for the electrical wires, basically being used only to separate and direct the wires.

Almost all of the support for the wires comes from the seis=ically designed hangers anchored in the structures themselves. The electrical cables would therefore re=ain in place on the supports even in the unlikely event that the cable trays disappeared.

The investigati, the cable tray allegation was performed by two NRC RIII inspectors anc une investigator with a total of 143 inspector hours being devoted to inspections at the ZL 2er site and at the Burndy-Husky plant. The RIII inspection chronology is as follows:

S/31/78 Original allegation letter received in Region III office (forwarded by Michael Bancroft).

9/20-22/78 Investigation at Husky and Zi==er sites.

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9/27-29/78

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Investigation continuea at Husky and tests of =aterial and welds were witnessed.

12/21/78 NRC Regica III issued the report (50-358/78-21) covering the results of the investigation, a copy of which is attached.

S&L Specification H-2199, indicates that welding performed during f abrication cf cable trays was to be "in accordance with codern shop practice for welded ccnstruction". The vendor chose to include in his Quality Control Manual a require =ent for procedures and welders to be qualified in accordance with the A=erican Society of Mechanical Engineers (ASME)

Section IX Cede.

The ASME Section IX code requires, for MIG or TIG welding, that welders cust de=enstrate an ability to perform satisf actory velding in the welding process and positions thet they will be utilizing when they perfor= =anual welding. Af ter these tests are satisf actorily passed the welders are then certified for the process and position used. There is no requirement that they =ust pass qualificaticn for all processes in all positiens before they beccme fully certified, and it is recognized that several atte= pts at qualifying =ay be required.

In the case of automatic resistance spot wel ting, while no welder qualifications are required, it cust be de=custrated periodically through weld performance testing (tear test) that r.he welding procedure is adequate to produce sound welds.

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. The automatic resistance spo$ welding unit serial nu=ber 160396 =anufactured by Precision tooling, Cincinnati, that was used on the Zi==er vertical an'd horizontal straight cable trays is a co=plately auto =atic procets which dces not.tse weld filler caterial. The tray parts are atito=atically fhd between two pairs of electrodes, these electrodes are =echanically controlled and synchronized with the feed =echanis= to produce welds at pre-set intervals. The spot fusion is produced by passing current fro =

the electrode through the two pieces to be joined. The flow of current causes the tray caterial to =elt and fuse together. The electrode current and pressure are adjusted to provide an acceptable weld in accordance with a qualified procedure specification.

The NRC inspector reviewed Husky Products welding procedt re specifications, welding procedures, procedure qualification records, welder perfor=ance qualifications along with other welding procedure related records. No concerns were identified as a result of this progra==atic review. However, two ite=s were identified curing review of the manufacturer's welding activities and records.

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It was learned that for a period of approximately two weeks in Nove=ber 197', the sFielding gas =ixture for the =anual TIG welds was varied fror 100 carben dicxide to 75% argon and 25% carbon dioxide and also that the.035" filler =aterial specified had been changed to.04 5" filler =aterial. These are changes in essential variables established by the ASMI Section 17 code for which the code requires W5014

procedure requalification. The NRC inspector deter =ined that this had not been done.

It was further learned by the inspector, during an inspection at the site on February 20-22, 1979, that the manufacturer has since performed a requalification of the weld procedure using the changed variables and that the results of qua.ification weld testing were signed by the testing laboratory as being acceptable by bend tests on January 18, 1979.

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The NRC inspectors were infor=ed by Husky Products personnel that two welders had perfer=ed welding on f curteen short radius three piece siderail channels for fittings, prior to qualification but that both welders successfully ccepleted their qualification at a later date.

The NRC verified that all velders had successfully completed qualification.

The above t'ro iters were cited as two exa=ples of a single noncompliance to 10 CFR 50, Appendix 3 Criterion IX (Control of Special Processes) in an NRC letter to the licensee dated Dece=ber 21,1978 (See Appendix A of the attached report). The licensee's corrective action was reviewed and found acceptable by the NRC inspecter during an inspecticn en February 20-22, 1979.

During the investigation, rando=1y selected sa=ples of cable tray and fittings from the 21==er site were destructively tested at the F&S Machining Company, Moscow, Ohio, on Septe=ber 28, 1976. These tests were designed to pull resistance spot velds and Metal Iner: Gas spot we.ds on straight tray and fittings apart to deter =ine the quality of the welding. All of the

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. welds so tested were determired to be accep able (See Section II paragraph 2.b of the attached report). Additionally, visual inspectic is were perfor=ed by NRC inspectors of TIG welds on three piece siderails of fittings installed at the site. This visual inspection by the NRC inspectors indicated that these velds appeared sound and suitable for their function. Documents reviewed at the vendor plant verified that vendor QC personnel visually inspected such welds prior to the galvanizing of fittings installed at the site.

We concluded that the cable trays and fittings installed at the Zi=er f acility are adequately fabricated and installed to provide assurance for the safe operation cf the Zinmer facility.

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hu Thomas E. Vandel

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s' Harvey P scott Subscribed and Swcrn to before

=e this h/ day of June 1979.

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]V My Coc=ission expires: / M_ 6[

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