ML19269E428
| ML19269E428 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 05/14/1979 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | |
| References | |
| NUDOCS 7906280258 | |
| Download: ML19269E428 (70) | |
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UNITED STATES OF AMERICA k,,&<CNd NUCLEAR REGULATORY COMMISSION In the Matter of )
)
ME CINCINNATI GAS & ELECTRIC )
)
(Wm. H. Zi:mner Nuclear Power )
Station) )
APPLICANT'S RESPONSES TO "INTERVENOR MIAMI VALLEY POWER PROJECT'S TEIRD SET OF INTERROGATORIES TO APPLICANT" P00R ORML May 14, 1979 1906280p,..g
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2172 037
t QUESTION 1: Do quality assurance standards applicable to the Zimmer Station require that the wrJders be certified according to Section 9 of the American Society of Mechanical Engineers (ASME) Welding Handbook?
QUESTION 2: Were the welders emplo} bj 'Isky Products, Inc.,
who welded the cahJa trays ca cified according to Section 9 of the circ!E Nelding Handbook?
MSWER: Cable tray welder! re qualified in accordance with Section IX of the ASME code. See also the attached USNRC Office of Inspection and Enforcement - Region III Report No. 50-358/78-21, Page 24.
P00R LRIGINAL 2172 038
. t QUESTION 3: On what dates were those welders ::ertified?
ANSWER: Welders became qualified at various times during the period November,1974 through March,1976.
See also answer to Questicas 1-2.
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QUESTION 4: On what dates were the welds on the cable trays made?
ANSWER: The work on the Zimmer cable trays began in December, 1974 and continued for approximately 2 years.
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QUESTION 5: Who performed the certification tests on the welders?
ANSWER: The qualification tests were, c" r,.7urse, performed by the welders. In accordance with ASME Section IX (Part QW, Article 1, Paragraph QW-103) , Husky Products, Inc. certified the accuracy of the welder qualification test records.
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e t QUESTION 6: How many tests was a welder required to pass in order to be certified?
ANSWERS A welder is qualified for a particular type of weld when he has passed the test applicable to that weld.
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QUESTION 7: Did every welder who welded the cable trays at Zimmer pass all. required tests? Docrant your answer.
ANSWER: See answer to Questions 1-2. It should be noted that no cable trays were welded by employees of Husky Products, Inc. at the Zimmer site.
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9 4 QUESTION 9: Were test welding techniques identical to repro-duction welding techniques in every case on every cable tray weld?
ANSWER: See attached Report No. 50-358/78-21, page 10, paragraph 5.
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QUESTION 10: Describe all quality assurance proceduros and quality control procedures required in the manufacture of the cable trays. .
ANSWER: The Burndy/ Husky QA Manual and QC Procedures are proprietary information. These documents are available for your inspection during normal businsss hours through prearrangement with counsel and after agreement to abide by an appropriate protective order.
4 2172 045
4 s QUESTION 11: Describe in detail and document every test performed on cable trays, including the total number of welds tested, how many of those welds tested were on vertical fittings, and the results of the tests.
ANSWER: See attached Report No. 50-358/78-21, pages 19-23.
e 2172 046
QUESTION 12: What is the strength of the welds on the cable trays (each type of wld on them)? How was this information obtained?
ANSWER: See attached Report No. 50-358/78-21, page 21.
2172 047
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QUESTION 13: Describe the stresses and vibrations that will occur due to the operation of any machinery and due to surges of power through the cables.
ANSWER: The operation of machinery will not affect cables in trays. We see no way how " surges of power through the cables" will create stresses or vibrations.
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QUESTION 16: Describe the original design load for the cable trays and for the cable tray fittings.
ANSWER: The original cable tray design load is described in Section 3.10 of the FSAR.
w 2172 049
QUESTION 17: What is the composite section modulus and moment of inertia of cable tray straight sections and cable tray fittings?
ANSWER: The section modulus and momemt of inertia (both vertical and horizontal) for the 4" and 6" cable tray straight sections and fittings are as follows:
Section Modulus (in3) Moment of Inertia (in )
4 4" tray vertical .934 1.86 horizontal 3.95 47.4 6" tray vertical 1.71 2.13 horizsntal 5.5 66. ,
2172 Oc3 -
QUESTION 18: Furnish specifications for steel used in cable trays.
ANSWER: Steel used in cable trays is AISI C-1010. Tests on samples from the coils verified that the material yield strength had a minimun value of 30,000 psi.
2172 051
CUESTION 19: What:was the original maximum stress predicted for cable tray parts?
ANSWER: The ==v4 mum calculated bending strass is 23,700 psi for the 4* trays and 13,600 psi for the 6" trays.
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QUESTION 29: Describe in terms of quantity and weight load of cables originally expected to be held in the cable trays.
ANSWER: The limit established in the design of tray system for loading of cables in trays is 41 lbs. per square foot as described in Section 3.10 in ths FSAR.
Quantities of cables will vary depending on their diameter and weight for each individual cable.
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QUESTION 21: Describe the resulting difference in stress due to the greater load of cables in the cable trays.
ANSWER: Because the tray lo/.d design is not exceeded, there are no stresses greater than the design value.
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QUESTION 22: Describe any additional load of cables planned or expected to be added to the cable trays prior to or any time during operations.
ANSWER: Additional cables would only be added to the cable trays if the design limits of the tray system were not exceeded.
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QUESTION 23: Describe the resulting difference in stress due to the expected additional load.
ANSWER: See answer to Question 22.
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QUESTICN 24: Describe all modifications to original cable tray designs.
ANSWER: Some side rail extensions were added to cable trays at T sections or crossing points because cables were above the original tray rails at these points.
O 2172 057
QUESTION 25: Describe additional parts or materials added to the cable trays as a result of any modified design.
ANSWER: See answer to Question 24.
e 2172 058
QUESTION 26: Describe the method of attachment of additional parts or materials to the cable trays.
ANSWER: Bolted splice plates were used for attachment of side rail extensions.
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QUESTION.27: What is the new section modulus and moment of inertia of the cable trays resulting from the additions.
ANSWER: Addition of side plates at the intersection does not change the support requirements as the design load is still less than 40 pounds per square foot. .
No credit is taken for the stif" ness of the side plate extensions. Therefore, the cal-culated section modulus and moment of inertia do not change.
2172 040
QUESTION 28: Describe how the cable tray supports were modified as a result of design modifica*. ion of the cable trays and/or of the additional load of cables.
ANSWER: Becauce the tray load design is not exceeded, cable tray supports were not modified.
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QUESTION 29: What are the anticipated stresses in the cable trays and cable tray supports due to an earthquake of design magnitude.
ANSWER: See answer to Question 19.
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QUESTION 30: Were the cable trays and cable tray supports tested under proposed operating conditions? If so describe in detail the tests and results.
ANSWER: There have been no tests made under normal operating conditions. Cable trays were tested as described in the attached Report No. 50-358/78-21, pages 19-21.
b 2172 063
QUESTION 31: Describe in detail any tests conducted to determine the effect of additional heat and taight on the cable trays and cable tray supports.
ANSWER: There were no tests conducted to determine the effect of additional heat and weight on the cable trays and cable tray supports since the thermal limit or the weight limit of the design is not exceeded.
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QUESTION 32: If no such tests were conducted, describe how the effects were determined.
M M R: See answer to Question 31.
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QUESTION 33: Describe in detail how many conductors each run of cable trays was designed to hold.
ANSWER: See answer to Question 20.
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QUESTION 34: Describe in detail how many and what type of additional conductors have been added to each run of cable trays. Give reasons for additions.
ANSWER
- Any additions to tray sections are checked to assure that weight limits are not exceeded. Cable additions are made as a result of design changes in system and components.
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1 2172 067
QUESTION 35: Describe in detail the effects on cable tray welds of additional heat and weight due to the addition of fire insulation and additional con-ductors.
ANSWL(: There are no effects on cable tray welds from additional heat due to the addition of fire insulation and additional conductors since the ~
design limits are not-exceeded.
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QUESTION 36: Relate these effects to the original design capacity for the cable trays and cable tray supports.
ANSWER: See answer to Question 35.
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QUESTION 37: Describe in detail the " piggyback" system of cable trays, including how many cable trays are stacked up, and whether any of these cable trays contain backup safety systems.
ANSWER: Cable tray criteria are described in detail in Section 8.3.1 of the FSAR.
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QUESTION 38: What is the anticipated build up of heat in the cable trays, considering the fire insulation blanket?
ANSWER: There is no temperature rise for trays with control cables. For cable trays including power cables, the temperature rise duo to insulation will not exceed 200F.
QUESTION 39: What is the thermal conductivity of the fire insulation blanket wrapped around the cable trays?
ANSWER: The thermal conductivity of the fire insulation blanket is 0.133 Btu /hr 0F - ft.2 Q\]S ew+ ,
QUESTION 40:
What ther2nal expansion is expected due to heat build-up?
ANSWER: The calculated hharma1 expansion of the cable trays is 0.C3 inches.
03 2172
t QUESTION 42: What is the anticipated maximum stress in the cable trays at the welds, taking into consideration any and all alterations to cable tray design, additions of parts and materials, additions of conductors, thermal stresses and stress due to earthquakes.
ANSWER: See answer to Question 19.
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_Ql!ESTION 46: Identify by name all components in the control rod assembly.
ANSWER: The names of all the components in the control rod assembly are documented in the. FSAR Paragraph 4.2.3.1.2
~and Figures 4.2-11,12,13 and 14.
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2172 075
QUESTION 47: Describe the functions, configuration, composition and operation of control rods and control rod assemblies.
ANSWER: The functions, configuration, composition and operation of control rods and control rod assemblies are defined in the FSAR Paragraph 4.2.3.1.
d 2172 076
QNESTION48: Identify by name parts and assemblies contiguous to control rods during operation of reactor.
ANSWER: The following are the names of the parts and assemblies contiguous to the control rods during reactor operation:
fuel channel, lower tie plate, orificed fuel support, control rod guide tube and control rod drive.
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9 2172 077
QUESTION 49: Furnish all specification for control rods and control rod drives.
ANSWER: The requested design specifications for the control rods and control rod drives are proprietary infonnation in the possession of General Electric Company. Review of these documents may be made at GE San Jose offices after an agreement to abide by a protective order.
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QUESTION 50: Furnish all inspection procedures, inspection documents and criteria for control rods, control rod drives and control rod seals.
ANSWER: a) The requested General Electric Company inspection procedue.as, inspection documents and criteria for control rods, control rod drives and control rod seals cre proprietary- information in the possession of General Electric Cozcpany. Review of these documents may be made at GE Manufacturing Facility, Wilmington, N.C., after agreement to abide by a protective order.
b) All inspection procedures, inspection documents and criteria of Reactor Controls Inc. for control rods, control rod drives and control rod seals are av=4Tahla for inspection during normal business hours at the offices of CG&E through prearrange-ment with counsel.
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QUESTION 51: Describe all none.onformities to specification found in control rods and control rod parts, MSER: Field changes and disposition of deviations are described in the documents provided in answer (b) to Question 50.
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QUESTION S2: Describe procedures used to correct these nonconformities ANSWER: See the documents provided in answer (b) to Question 50.
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QUESTION 5?. Furnish all specifications and quality assurance criteria and standards that justify the use of clamps to meet con-trol rod measurement specifications.
ANSWER: A 40-lb. clamp is provided as part of the inspection tools used at the site to check for any shipping or handling damage. The clamp is used to detemine if any out of envelope condition, which may be found during inspection, is due to nomal sheath waviness. The 40-lb Toad was selected such that the nomal waviness of the sheath will be removed but will not pemanently deform the sheath. A mechanical problem is reason for rejection but nomal waviness, which is easily overcome by the clamp is accept-able. The control rod is designed to operate withc.-J
. substantial rubbing friction between the control rod and the fuel bundles when the maximun acceptable misalign-ment exists. Friction several times tha 40 lbs. is within the nomai operating range of the control rod and it has been demonstrated that there is no detectable change in scram times due to these friction forces. Therefore, the 40-lb. inspection clamp load will have no effect on safety or nomal operation.
2172 GB2
QUESTION 54: Describe .ality assurances procedures used in construction of control rods.
ANSWER: Wilmington manufacturing's quality assurance program is defined in the FSAR, Paragraph 4.2.3.2.4.2 and the QA Manual for General Electric's Wilmington, N.C. facility. The manual is proprietary information and review of it may be made in Wilmington, N.C. after an agreement to abide by a protective order.
' QUESTION 55: Describe quality assurance procedures used in installation of control rods and control rod assemblies.
ANSWER: The control rods were installed in accordance with criteria established in General Electric Company specifications (see answer to Question 50).
Quality Assurance precedures were implemented to assure compliance with these specification requirements.
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QUESTION 56: Furnish specifications for all parts contiguous to control rods and control rod drives.
ANSWER: The design specifications requested for all parts contiguous to control rods and control rod drives are proprietary in-fomat1on in the possession of General Electric Company.
These may be reviewed at the GE San Jose offices after an agreement to abide by a protective order.
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QUESTION 57: What is the anticipated increase in size control rods and contiguous parts resulting from increased temperature during operation of the reactor?
ANSWER: The increase in size due to increased temperature is unifonn throughout the parts. Reference FSAR Paragraph 4.2.3.1.3.
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QUESTION 58: What are the anticipated changes in shape and size of the control rods and contiguous parts due to pressure during each phase of operation and during a shutdown?
MSWER:
The control rods do not change shape due to reactor pressure. Effects of pressure variations on control rod to channel clearances are addressed in FSAR Paragraph 4.2.1.3.6.
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QUESTION 59: How many pounds of pressure were exerted by the clamps used to bring the control rods to the required measure-ments?
ANSWER: The inspection clamp used at the site to evaluate possible shipping or handling damage is spring loaded to 40 lb.
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QUESTION 60: Was any grinding done on any part of the control rods and if so for what purpose?
ANSWER: Grinding is done on the control rods at the Wilmington Manufacturing Facility to deburr sharp edges and remove nicks, raised metal and any excess weld crowns.
In accordance with requirements of GE field inspection procedures (see Answer (b) to Question 50), chamfering using a high speed burr was performed to comply with the speci-fication requiramants.
ww-- w QUESTION 61: Describe the function, composition and operation of the tube rollers in relation to the control rods.
ANSWER: The " tube rollers" referred to in this question are assumed to be the rollers in the handle at the top of the control rod. These rollers are made of stellite, and their purpose is to reduce the friction between the control rod and the fuel channels.
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QUESTION 62: Describe procedures used to remove metal shavings from inside the control rod sleeves.
ANSWER: The control rods were thoroughly visually inspected to identify areas which could contain foreign materials. They were then vacuum cleaned and blown down with clean, dry, oil free instrument air.
The control rods were aga u inspected and vacuumed as necessary. Each control red was then wiped down with an acetong-solution and then controlled in accordance with claan11 ness requirements.
QUESTION 63: Are these procedures justified by quality assurance criteria? Document your answer.
ANSWER: Yes, the procedures used were approved by General Electric Company prior to use.
CUESTION 64: What follow-up procedures were used to insure that the shape and size of the control rods met the specifications after the clamping process and the procedures to remove metal shavings:
ANSWER: A reinspection of the control rods was conducted to assure that deformation had not occured during clamping and removal of metal shavings. It was det= mine that the control rods were acceptable in accordance with GE design requirements. With respect to the chamfering of the control rods, standard quality assurance proce-dures were followed to eliminate any possibility of metal shavings affecting the control rod.
Q\]S
QUESTION 67: Describe design modifications for control rods used for some of the control rods at the Zimmer Station?
ANSWER: A small ledge exists in the corner of control rod wings at the top of the velocity limiter.
Under mvi um material tolerance conditions this ledge can nick the corner of a fuel channel.
This nicking does not affect fuel channel or control red life or reactor safety but this condition was not consistent with previously tested geometrics. Therefore, the ledge was chamfered to eliminate the possibilities of nicking. The methods used are available for inspection during normal business hours at the offices of CG&E through prearrangement with counsel.
O 2V2
QUESTION 68: Describe why s<me control rods et Zimer Station were modified in design and others at Z1nL::r Station were left unmodified.
ANSWER: As mentioned in the response to Question 67, the ledge nicked the fuel channel only at maximum material tolerance conditions. Therefore, a functional gage was furnished +A the site which duplicated the fuel channel corner. If the gage hit the ledge the ledge was chamfered. if the gage did not hit the ledge no action was taken. is result was that all corners had to pass the gage before the con-trol rod was acceptable.
G 20'
QUESTION 69: Describe the materials used for the seals on the control rods.
ANS'A R: It is assumed that the ' scal" being referred to is the velocity limiter to guide tube backseat. The seating surface on the control red velocity limiter is AISI Type 304 stainless steel.
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QUESTION 70: Describe in detail the function of the seals on the control reds.
ANSWER: < At the time when maintenance is to be performed on a control rod <i:ive, the control rod is fully withdrawn.
This action places a spherical surface on the control rod velocity limiter in contact with a conical surface on the guide tube. The purpose of this seating or " seal" function is to limit tne amount of water which may drain from the reactor vessel during the period when a control rod drive is removed from the vessel for maintenance.
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QUESTION 71: Describe the quality assurance criteria for the seals, particularly in tenns of the required smoothness.
ANSWER: The control rod velocity limiter spherical surface is inspected for a 63 RMS finish.
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QUESTION 72: Describe the effects of seals which are rougher than required.
ANSWER Roughness which is outside the cor. tact area or is parallel to the "line of contact" has no measurable effect on drain-age. Roughness which cro:ses the contact area may increase the drainage slightly.
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QUESTION 73: Describe in detail the effects resulting from the improper setting of the seals when the control reds are installed and the reactor is operating.
ANSWER: The installation of the control rod into the reactor has no effect on proper seating of the " seals", and the " seals" da not function during reactor operation.
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QUESTION 74: Describe all quality assurr.nce procedures used to measure the smoothness of the seals.
ANSWER: The procedure used for inspecting the smoothness of the seals consisted of a visual inspection of the surfaces for any anomalies and comparison of the surface to a Standard Surface Comparator.
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QUESTION 75: Describe, account for, and furnish copies of inspection sheets of Applicants and of Reactor controls, Inc. , which are not identical.
ANSWER: The Applicant has developed no independent record of control rod inspections.
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CUESTION 77: Describe in terms of quantity and weight the present load of cables being held in the cable trays.
ANSWER: See answer to Question 20.
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VERIFICATION State of Ohio )
County of Hamilton ) ss Earl A. Borgmann, being first duly sworn, states that he is Senior "/ ice President for The Cincinnati Gas &
Electric Company; that he has been duly authorized to execute, verify and file the foregoing document " Applicant's Responses to 'Intervenor Miami Valley Power Project's Third Set of Interrogatories to Applicant'"; that he has read the contents of same and that the statements contained therein are true and correct to his best information, knowledge and belief.
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Earl A.~ Borgmatth Subscribe'd and sworn to before me this /il day of May, 1979.
AM d ~
fW Q Notary Public MARGARET C. HUBER Matary Public. State Of Ohio My Commission Expires Aug.1A 1983 b
2172 104
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
THE CINCINNATI GAS & ELECTRIC )
COMPANY, ET AL. ) Docket tro.40-358
)
(Wm. H. Zimmer Nuclear Power )
Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Responses to Intervenor Miami Valley Power Project's Third Set of Interrogatories to Applicant", dated May 14, 1979, in the captioned matter, were served upon the following by deposit in the United States mail this 14th day of May,1979.
Charles Bechhoefer, Esq. Dr. Lawrence R. Quarles Chairman, Atomic Safety Atomic Safety and Licensing and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear. Regulatory Commission Commission Washington, D.C. 20555' Washington, D.C. 20555 Dr. Frank F. Hooper, Member Michael C. Farrar, Es.[.
Atomic Safety and Liecnsing Atomic Safety and Licensing Board Appeal Board School of Natural Resources U.S. Nuclear Regulatory University of Michigan Commission Ann Arbor, Michigan 48109 Washington, D.C. 20555 Mr. Glenn O. Bright, Member Chaiman, Atomic Safety and Atomic Safety and Licensing Licensing Board Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Frwmission Commission Washington, D.C. 20555 Washington, D.C. 20555 Richard S. Salman, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Panel Licensing Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Ccmmission Commission Washington, D.C. 20555 Washington, D.C. 20555 2172 105
Charles A. Barth, Esq. William Peter Heile, Esq.
Counsel for the NRC Staff Assistant City Solicitor Office of the Executive City of Cincinnati Legal Director Box 214 U.S. Nuclear Regulatory Cincinnati, Ohio 45202 Commission Washington, D.C. 20555 Trov B. Conner, Jr., Esq. Leah S. Kosik, Esq.
Counsel for The Cincinnati Attorney at Law Gas & Electric Company 3454 Cornell Place Conner, Moore & Corber Cincinnati, Ohio 45220 Suite 1050 1747 Pennsylvania Avenue N.W.
Washington, D.C. 20006 Mr. Chase R. Stephens John D. Woliver, Esq.
Docketing and Service Section Clermont County Community Office of the Secretary Council U.S. Nuclear Regulatory Box 181 Commission 3atavia, Ohio 45103 Washington, D.C. 20555
/ TAME ).8%w/k killiam J.
2172 106
9
.. . - 7 U.S. NUCIIAR REGULATORY COMMISSION OFFICC OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-358/78-21 Docket No. 50-358 License No. CPPR-88 I.icensee: Cincinnati Gas and Electric Cor:pany 139 East 4th Street Cincinnati, OH 45201 -
, Facility Name: Wm H. Zimmer Nuclear Power Plant Investigation At: Zimoer site, Moscow, Ohio and Husky Products, Inc.,
Florence, Kentucky Investigation Conducted: September 18-22, and 28-29, .t78 ,
~
Investigator: . , ro. a t_ 7 9 cb-Inspectors: T. E. Vand '
E-M(( '
0' db k--
H.hi.Wescott / M- M- 7 Reviewed by: k."Haye- "'
f b~~ IE lE '/ 7 ~
ojects Section
. u 12 Al 'IP Assistant to the Director Investigation Su= mary Investigations on September 18-22 and September 28-29, 1978 (Recort No.
50-358/78-21)
Areas Inspected: Review of cable trays, pans and fittings located at the Zimmer site and at the Husky Products. Inc. plant;revir e of activities at thp Husky Products, Inc. plant; and observation of testing activity at independent test labs. The investigations involved 143 inspector-hours by three NRC inspectors.
Results: One item of noncompliance (a deficiency) was identified in the control of special processes (welding). Details,Section III.
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INTRODUCTION The Zi=mer Unit I nuclear power plant, licensed to the' Cincinnati Gas and Electric Company, is under construction near Moscow, Ohio.
Sargent and Lundy is the Architect-Engineering firm for the plant, which is being constructed by '<aiser Engineering. The facility will utilize a Boiling Water Reactor (BWR) designed by General Electric Company.
The Husky Products Division (Husky) of the Burndy Corporation has supplied electrical cabia pans for the Zimmer plant. These cable -
pans are utilized to route both safety-related and nonsafety-related electrical cables. .
REASON FOR INVESTIGATION On August 31, 1978, a copy of a letter written by Individual "A",
a former Husky employee, was received at the NRC Region III (RIII) office (Exhibit I). This letter expressed concerns relative to the quality of electrical cable pans produced by Husky for use in the Zimmer and Clinton nuclear power plants, and alleged the use of ,
weak materials and improper welding in cable pan construction. An NRC investigation was initiated into these allegations.
SUMMARY
OF FACTS Individaul "A" was contacted by RIII personnel on September 8, 1978, and his concerns were discussed in general. These concerns related to the use of low strength materials and improper velding as contained in the letter attached as Exhibit I.
During September 18-20, 1978, RIII inspector visually inspected electrical cable pans at the Zimmer site, and found the welding of the pans to be acceptable. Site personnel agreed to have samples of the cable pan materials tested for material strength, and to have sections of cable pan destructively tested to determine the strength of the welds. Cable pans to be tested were then selected at random (by URC and Utility representatives).
Cable tray samples selected were tensile tested, with the tests witnessed 1 by an RIII inspector. All of'the samples tested were found to exceed
- the specified yield point (test results attached as Exhibit V) .
Destructive testing of welds was performed on a sample of the cable pans at the Zi=mer site, also witnessed by RIII personnel. These tests indicated that the welds were of acceptable strength and size according
, to American Welding Society criteria.
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_2-
Individual "A" was interviewed by RIII personnel. He indicated that the use of low strength material was a one-time occurrence which took place during the manufacture of cable pans for the Zimmer plant.
Individa21 "A" stated that a shipment of steel was found to be of
, low strength, and the decision was made to use the shipment for
" fittings" (curved sections of cable pan) only, but the shipment was not properly segregated. The shipment was inadvertantly used in the production of straight sections of cable pan, he indicated.
Individual "A" was critical of the manual welding performed by Husky welders, and the welding certification program conducted by Husky., He indicated that the Husky welders had difficulty in passing the certifi-
- cation tests, and welded differently during the test than in production. -
. welding.
In addition, comments were received which related to work at the Clinton plant, and are covered in a separate report (IE report No. 50-461/78-06).
RIII personnel made two visits to the Husky facility in Florence, Kentucky. During plant visits, the manufacturing areas were toured, work in progress was observed, pertinent records were reviewed, and interviews were held with Husky personnel. .
Records reviewed, and interviews held with Husky personnel indicated that Husky welders had been qualified as required by the American Society of Mechanical Engineers Code for Boilers and Pressure vessels,Section II (ASME Section II). No information relative to the use cf low strength materials could be developed.
On September 22, 1978, RIII personnel visited the Uniou Testing and Research Laboratory, where material samples had been tested for Husky during production of cable pans for the Z1=mer plant. Records relating to all tests of material for Husky for the years 1974-1976 inclusive were reviewed. None of the test reports reflected that materials to be used in the Zi=mer plant cable pans did not meet the specified yield strength requirements.
During a second visit to the Husky facility, signed statements were obtained from three Husky employees. The personnel interviewed indicated that they had no knowledge of any low strength material, being used in construction of cable pans for the Zimmer site. (See Exhibits II, III and IV).
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During document review, it was found that the shisiding gas and diameter of the filler material utilized for the welding process differed from the qualified welding procedure for a period of approximately four
~~
weeks'. This is in noncomformance with ASE Section IX in that a variable of the welding process was changed without subsequent requali-fication of the welding procedure and welders.
Husky personnel stated that they would have their welding procedure ,
qualified with the alternate shielding gas and filler material, to demonstrate that the quality of the welds was not affected by the changes in veld procedure. Later contacts with Husky personnel' .
indicated that some manual welding had been performer psior to
~
procedure qualification.
CONCLUSIONS
- 1. No evidence was developed that low strength material had been utilized in fabrication of electrical cable pans for the Zi=mer plant.
- 2. Macarials and welding for cab 12 pans supplied by Husky to the Zimmer plant were tested and found to be acceptable.
- 3. Welder certification had been performed as required by Section IX of the ASME Boiler and Pressure Vessel Code.
- 4. Welding wire and shield gas were not as sp2cified in the qualified welding procedure for a period in 1974. In addition, two welders performed welding without benefit of prior qualification. This is in nonconformance with 10 CFR 50, Appendix B, Criterion II and Section IX of the ASE code. (See DetailsSection III).
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B
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DETAILS Section I Prepared by J. E. Foster Reviewed by C. E. Norelius Assistant to the Director
- 1. , Personnel Contacted Cincinnati Gas and Electric Cot:many ,
E. A. Borgnan, Vice Presiden*
B. K. Culver, Project Manager R. P. Ehas Quality Assurance and Standards Engineer D. C. Kraner, Q:.ality Assurance and Standards Engineer J. R. Schott, Station Superintendent W. W. Schweirs, Principal Quality Assurattce and Standards Engineer W. D. Waysire, General Engineering Department Kaiser Engineers Inc.
R. Turner, Quality Assurance Manager Huskv Products Fred L. Santa, Engineering R&D Manager Don Dietrich, Tool Engineer Clare F. Duncan, Quality Control Manager Ronald C. Johnson, Production Forenen Randy Pratt, Industrial Engineer Ken Rigley, Welding Operator Duane Ring, President Barry Schuster, Utilities Market Manager The William Powell Co. (Union Testing and Research Laboratorv)
Steven L. Fogle, Assistant Manager of Laboratory Edwin E. Winterfelde, Corp. Manager of Quality Assurance Individuals lj Individuals "A" through "J" 2172 111
Sergent,and Lundy M. E. Schuster Cincinnati Post-Encuirer Douglas Starr, Staff Reporter Metcutt Research Associates
-L. J. Fritz, Materir.! Testing Supervisor R. E. Duvall, Testing Tachnician -
F&S Machining Services, Inc.
J. Foster, President
- 2. SCOPE and CHRONOLOGY This investigation centered on the allegations provided by Individual "A", relative to the use of low strength materials and i= proper welding by Husky. This report covers those allegations and inspections which pertain to the Zimmer Unit 1 plant. Allegations made which pertain to the Clinton 2 plant will be reported in a separate report.
On August 31, 1978, a copy of a letter by Individual "A" was received at RIII.
On September 8,1978, Individual "A" was contacted by RIII personnel.
During September 19-20, 1978, inspections were made at Clinton and Zimmer.
On September 20, 1978, Individual "A" was interviewed by RIII personnel.
During September 20-22, 27-29, 1978, RIII personnel visited the Husky facility.
On September 21,'1978,' Individual "A" was contacted by telephone.
On September 22, 1978, RIII personnel visited the Union Test Lab.
On September 25, 1978, a second letter from Individual "A" was received at RIII (Exhibit VII).
2172 112 e
On September 27, 1978 Individual "A" was re-interviewed by RIII personnel.
During September 27-29. RIII personnel visited the Husky facility.
On September 28, 1978, tests were performed on cable pans from the Z1:mner site.
On September 29, 1978, RIII personnel visited Modern Welding and Sheet Metal. .
- 3. Initial Contact with Individual "A" ,
On September 8,1978, RIII personnel contacted"-Individual "A" by telephone. Individual "A" indicated that he had been the Manager of Industrial Engineering for the Husky Products Company. He stated that he had worked for the company approximately five years, but was laid off on August 4, 1978.
Individual "A"'s concerns, as delineated in his letter of August 18, 1978, were discussed in general tatus.
- 4. Interview of Individual "A" On September 20, 1978, Individual "A" was interviewed by RIII personnel. Individual "A" indicated that the order for cable pans for the Zimmer plant was the first contract for which Susky had to meet nuclear requirements. He stated that these requirements included a special design requiring wrap-around splice plates, and pan side rails made from material with a minimum f: ensile strength of 35,000 pounds per square inch.
Individual "A" scaced that for the Zimmer project, Eusky procured steel from the Central Steel Company or J&L stee.1, purchasing commercial quality steel, and then testing the steel to see that it met the minimum strength requirements. The steel supplier would take a " master" coil, and slit it into six (on the average) production coils for Husky usage. Samples would be taken from the steel when it arrived at Husky, and the shipment would be placed on hold until the results of the tests were received.
Individual "A" indicated that these material tests had been per-formed by the Powell Valve Company test lab in Cincinnati (The Union Testing and Research Laboratory). ))b
Individual "A" stated that it was found that commercial quality steel varied in strength, and that one shipment was found to be of low tensile strength steel. He stated that Individual "B" made the decision to use this low strength steel in " fittings" or curved sections of cable pan, where strength is not crucial, and that a memo to this effect had been written. Individual "A" stated that on approximately February 10, 1976, he found that the low tensile strength material mentioned had not been properly segregated,
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and had inadvertently been made into straight sections of electricil cable pan. Individual "A" indicated that he had informed Individual "D" that the low strength material had been used to manufacture cable pan, ~ and produced a handwritten note (see Exhibit VI) which he indicated had been given to Individual "D". He also indicated that he had inf ormed Individuals "B", "C", "G", and "I" that this had happened. He stated that this one-time occurrence had been the subject of discussion among Husky personnel for several years. Individual "A" stated that the manual welds used to manufacture fittings were poorly done, and that the welder certification program was a " farce". He stated that welders who were to work on cable pans for the Zimmer contract were required to pass a qualification test as required by Section IX of the ASME Code. When initially tested by Gladstone Laboratories, he said, the welders could not pass the qualification test, and generally succeeded in passing the test after multiple attempts. Individual "A" stated that the welders did not perform their production welding any differently after passing the welder certification t es t. Individual "A" indicated that several knowledgable people had been critical of the welding performed by Husky welders, including Individual "J" (whose report is attached as part of Exhibit I). Individual "A" indicated that Individual "J" would have no part of training Husky welders unless they attended the full training course that his welding school provided. RIII personnel advised Individual "A" that the technical specifi-cation for the cable pans to be used in the Zimmer plant (specifi-cation B-2199, Division 2, Section 202.1) required that the materials be of a minimum yield strength of 30,000 pounds per square inch (yield strength is usually less than tensile strength). The comment 2172 I14
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Y regarding 35,000 lb/ square inch tensile strength is incorrect. Individual "A" was also advised that the specification would not allow the use of low strength material for cable pan fittings.
- 5. Investigation at Husky Products During September 20-22, 1978, RIII personnel visited the Husky Products facility in Florence, Kentucky.
Discussion with Husky personnel indicated that, due to the spe~cial
- design of cable pans for the Zimmer contract, steel rolls utilized .
in their construction were of unique size (7.7 and 5.7 inch wide rolls) not used for any other contract. As such, it was indicated, the 14 and 22 gauge material for the Zimmer contract could be easily traced through the receipt, testing, and manufacturing process, and such documentation could be identified by Husky Order No. 3995. RIII personnel toured the Husky facility, observed the fabrication of sections of electrical cable pan, and inspected equipment utilized in the forming and welding processes. Storage and receipt inspection procedures were also reviewed. Husky perso nel indicated that they had no knowledge of any low strength steel being , calved or utilized by Husky for any contract. It was indicated tha' r'.oring 1974-1976, Husky purchased commercial quality steel, and ' .un took samples from the material, which would be placed on hold ut $1 testing indicated that it met the contract requirements. Husky f u nnel. stated that they had experienced some problems with low strength aluminum,' and some steel had been returned to the vendor for roll flaws, but no 14 or 22 gauge steel had been found to be of low yield strength. Husky personnel stated that no decision had been made to use low strength material on cable pan fittings on the Zimmer contract or any other contracts. Husky personnel did indicate that half of one shipment of coiled steel had been returned to the vendor for coil defects known as
" coil breaks". They stated that the coil breaks do not affect the strength of the material, but cause problems during manufacture, and detract from the visual appearance of finished products. Two Husky officials noted that it was possible that it was decided to use rolls with coil breaks for fittings, as the coil breaks could be cut out during the manufacturing process. However, none of the individuals interviewed recalled such a decision.
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A review of the Zimmer contract file indicated that part of a shipment of 14 gauge steel for the Zi=ner contract had been returned to the vendor for having " bad waves" (improper winding of the steel which would cause manufacturing problems) Additionally, a steel shipment received on February 10, 1976, was found to be .002 inches too thick, and was accepted. RIII personnel reviewed documents relative to receipt of materials, shipment of materials to the Zimmer site, production records covering Zimmer cable pans manuf actured during 1976, returned shipments of roll steel, correspondence with steel vendors concerning coil breaks, discrepancy reports, and internal memoranda. None of the - documents reviewed indicated that unacceptable materials had been utilized by Husky. . RIII personnel also reviewed welding procedure and welder qualification documentation. It was found that manual welding for the Zimmer plant was performed using a Metal Inert Gas (MIG) procedure, and steel filler wire, using semi-automatic equipment. On this type of equipment, velding para-meters are set on the welding machine, and the velder 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 veld. Manual welding was.. performed on " fittings" (curved sections of cable pan) only, with the bulk of cable pan being straight sections welded by automatic resistance velding equipment. Welding records reviewed met the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section IX (ASME Section IX), which was imposed on Husky by its inclusion in their Quality Assurance Manual. ASME Section IX prescribes methods and procedures to be followed in welding procedure and welder qualification. Individaul "A"'s comment that the Husky welders did not qualify in the same manner as they produced welds is correct, but is in conformance with ASME require-ments. Qualification was performed to a butt veld procedure, per the requirements of ASME Section II, and production velds were spot welds.
- 6. Visit to Union Testing and Research Laboratorv On September 12, 1978, RIII representatives visited the Union Testing and Research Laboratory, a division of the William Powell Company 2)12 \\b .
Powell personnel indicated that they had performed material tests for Husky during the years 1974-1976, and followed the procedure of calling the company and informing them of the test results from handwritten forms, then typing the test forms and sending a copy to Husky for their records. RIII personnel reviewed Powell files for Husky covering 1974-1976. All test reports reviewed indicated 14 and 22 gauge steel was - tested and found to be in excess of 30,000 pounds per square inch
-yield strength. Typical values for such material ranged from 35,000 to 40,000 pounds per square inch. Records for the years -
1975 and 1.'76 indicated one test of 16 gauge .' steel was tested and to have 29,400 lbs/ square inch yield, and one sample of aluminun was tested and found to have 15,650 lbs/ square inch yield strength. Powell personnnel stated that they did not recall any 14 or 22 gauge steel which they had tested which did not exceed 30,000 lbs/ square inch yield strength. They indicated that this was typical of 14 and 22 gauge steel, and that steel vendors have no difficulty producing such material.
- 7. Contact with Individual "A" Individual "A" was contacted by telephone by the RIII investigator on September 21, 1978, and asked to provide additional detail re-garding his alleged discovery of the use of low strength material.
Individual "A" stated that he had been aware of the existence of low strength material through receipt of inspection reports which had been routed through his office. He stated that some of the material was marked " return to vender", and some of it was marked "use for fittings only - segregate". He indicated that he was in the Husky material storage area on February 10, 1976, and aaked a worker where the Zi=mer icw strength material was stored. The worker did not know what he was talking about, Individual "A" said, and he asked the worker's supervisor the same question, with similar results. Individual "A" stated that he then advised Individual "B" of the occurrence, and wrote the note attached as Exhibit VI to Individual "D". He indicated that Individual "D" went to look into the matter, and later returned the note with a verbal comment to " forget it". Individual "A" commented that he had not actually read the written specification for the Zi=mer cable pans, but he understood that
- the specification required material with a min 4 m tensile strength of 35,000 lbs. - square inch. He was again advised of the actual specifican on requirements.
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- 8. Contact with Individual "J" Individual "J", of the Technicron School of Welding, was contacted by the RIII investigator on September 7, 1978.
Individual "J" indicated that his school utilized Gladstone Labora-tories (Gladstone) to certify his welders, and that when Husky welders had difficulty passing weld certification tests, Gladstone had reco= mended him to Husky.
. Individual "J" stated that he did not resember 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 indicated that he had ~
fewer concerns relative to steel welding. He stated that he had looked at Husky from the viewpoint of a consultant, with a view towards training their welders at his school. Individual "J" indicated that he had not refused to train welders from Husky, but he had wanted the welders to take the entire training course which his school offerred. He stated that Husky management only wanted their welders to be schooled in the two weld procedures * (MIG and TIG) which they utilized. Individual "J" indicated that he did have some reservations that the older Husky welders would not benefit from training at his school. During the discussion Individual "J" indicated that he was not aware that his report had been attached to Individual "A"'s letter. He indicated that Individual "A" had not contacted him, and that he had not been in contact with the Husky company since the date of his report.
- 9. Interview with Individual "A" on September 27, 1978 Individual "A" was interviewed on September 27, 1978, and discussions were held on the progress of the NRC investigation.
Individual "A" was advised that no evidence of low strength material had been davsloped, and was requested to provide any additional information which would aid in the investigation. Individual "A" indicated that in early 1975 prior to the shipment of low strength steel which was inadvertently used for cable pans, another shipment had been tested, found to be of low strength material, and was properly returned to the vendor. He stated that he believed that the 2172 118
shipment which was improperly utilized was a small shipment, possibly of six coils of steel, which was delivered during the months of December 1975 or January 1976. Individual "A" indicated that he had also recalled an occurrence in Hovember 1975, when Husky sent Zimmer material to Modern Welding and Sheet Metal (Modern), a specialty welding firm which did not have welders qualified to ASME Section II at the time. Individual "A" stated that this was done because the Husky plant was on strike, and the company felt that they had to meet their contract to supply the cable pans. He stated that the order comprised over 100 pieces of equipment, of three-piece construction. He indicated his. understanding that the welders for Modern were not qualified *.o ASME Section IX until sometime in 1976. - Individual "A" provided the RIII investigators with the name and telephone number of a former Husky employee who, it was indicated, might have some recollection of the alleged us.: of low strength material during manufacture of equipment for the Zimmer plant.
- 10. Contact with Individual "D" -
Individual "D" was contacted by the RIII investigator on September 29, 1978. Individual "D" was questioned as to his knowledge of the use of low strength materials in the fabrication of cable pans for the Zimmer plant. He stated that he did not recall the use of any low strength material on any of the Husky nuclear contracts. He indicated that he did not believe that anyone at Husky would knowingly allow such an occurrence, especially those in the Quality Control department. The scenario of the discovery of the use of the low strength material as described by Individual "A" was discussed with Individual "D", and the note allegedly sent to him was read. Individual "D" stated that he had no recollection of any such note, and indicated that it would be unusual for him to return such a note without some kind of written comment, as he disliked verbal communications. Individual "D" recalled occurrences where shipments of steel were found to have various problems such as excessiva oil, roll problems such as ripples or twists, or were rejected because of steel thickness variations. He indicated that he also recalled the incidence of some 2172 119
low strength aluminum, and steel pre-galvanized with an aluminum-zine coating which was banned from inclusion in the Zimmer equipment. He stated that the aluminum-zine coated material (Galvalume) was to be made into cable pan covers, but Husky perse'nel n recognized that the 1.6% aluminum content of the coating was undesirable due to its large surface area, and a program was set up to insure that no Glavalume pan covers were shipped to the Zimmer site. Individual "D" indicated that on at least one occasion, covers were inadvertently fabricated of this material, were identified, and had to be_re-fabricated
- 11. Visit to Husky Products during September 27-29, 1978 -
RIII personnel visited the Husky facility during September 27-29, 1978. During this visit, documentation related to velder qualification test-ing, production records, material tests, deficiency reports, internal memoranda of the Industrial Engineering section, and weld procedure qualifications were reviewed. Interviews were held with Husky personnel, and three signed statements were obtained. (See exhibits II, III and IV). None of the documents reviewed, ar.d ncne of the statements received during interviews indicated that Iow strength materials had been utilized during manufacture of the Zincer plant cable pans. Welding certification was reviewed as pertaining to velding procedure and welder qualification to Section IX of the ASNE Boiler and Pressure Vessel Code. Welder qualification records and welder qualification test pieces (stored at Husky) were considered acceptable. Records indicated that welders had made several qualification atte= pts in many cases. This is acceptable under ASME Section IX. During document reviews at Husky, it was found that the velding procedure for manual welding on Zi:mner equipment had been qualified using carbon dioxide shielding gas and .035 inch diameter filler material, but a mixture of shielding gas and .045 inch diameter filler material had been utilized for the period of November 14 - December 3, 1974. The is in nonconfotaance with ASME Section IX, which required requalification of the welding procedure when these variables were changed.
- 12. Interview with Individual "E" Individual "E", Husky Purchasing Agent, was interviewed by RIII pc.rsonnel on September 28, 1978, at Husky.
t 2172 120 Individual "E" stated that to his knowledge, Husky had not received nor returned any steel which did not meet the cppropriate yiel,d strength requirements. He stated that since the steel that was purchased during the manufacture of the Zimmer equipment was purchased to co=mercial steel specifications, and then tested, it would not have been returned if it did not meet the minimum strength require-ments. No minimum strength requirements are imposed on the steel vendor when commercial grade steel is purchased.
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Indiv1 dual "E" stated that flat stock steel was purchased and con-trolled in the same fashion as roll stock 1.e., to commmerical grade requirements, and then tested to insure that it met the minimum
. strength req
- _ents. _
Individual "E" stated that the Central Steel Company had supplied all of the 14 gauge steel utilized for the Zimmer cable pans.
- 13. Visit to Modern Welding and Sheet Metal On Septemeber 29, 1978, RIII representatives visited the Modern Welding and Sheet Metal Company.
Discussions were held with Individual "F", one of the managers for the firm. Individual "F" indicated that the majority of the work that his firm does for Husky is specialty welding of seperators, junction boxes, cable bus, and aluminum welding. He indicated that to the best of his knowledge, his firm had not performed any welding on cable pans for Husky at any time. Individual "F" was requested to review his-files for work performed for Husky for the years 1975 and 1976, with attention to any work on electrict:. cable pans. Individual "F" stated that he could not find any orders concerning electrical cable pans, and the Husky identification number (3995) for the Zi=mer project was not found in his review of his files. On October 12, 1978, the RIII investigator contacted Individual "F" and requested that he again review his files, and provide the NRC with information as to any products manufactured for Husky during November, 1975. Individual "F" provided this information, which indicated that tap boxes and cable separators had been fabricated by his firm for Husky, but no work had been done on cable pans, and none of the Eusky tags applied to the work had referenced the Zi=mer identification number. 2172 12i
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- 14. Contact with Individual "G" -
Individual "A" had advised RIII personnel that Individual "G" might have information concerning the use of low strength material in the Zimmer equipment. This individual was contacted by the RIII investi-gator on October 5, 1978. Individual "G" stated that ha had been in the hospital during time
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period of the alleged use of low strength materials. He indicated that he had no knowledge of such an occurrence, and that he had not heard anyone at the Husky plant discuss such an occurrehce while he was employed there (his employment terminated in February,1978).-
- 15. D atact with Individual "H" -
Individual "H", an employee of Hobart Welding who had acted as a consultant to Husky on welding and welding qualification, was contacted on September 29, 1978. Individual "H", indicated that his first contact with Husky was - approximately five years ago, and that Individual "I" had been trained in the Hobart school. He stated that Husky had long been involved in welder qualification and in upgrading their welding. Individual "H" 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 pieces. Individual "H" stated that he believed that Husky had a good program for welding qualification testing, and had used the program to
" weed out" the poorer welders.
- 16. Discussions with Individual "A" Several telephone discussions were held with Individual "A" concerning the findings of the investigation. Individual "A" expressed dis-satisfaction with the findings of the investigation, and provided additional allegations concerning Husky.
Individual "A" stated that the Husky velders had not qualified on both the vertical and horizontal welding positions, and had performed vertical welding during cable pan manufacture. Individual "A" indicated that he felt that the Husky welds had been required to be of pressure vessel quality. He was advised that the specification had not required welds of pressure vessel quality. Welds of pressure vessel quality require non-destructive examination 2172 122
. such as magnetic particle, radiographic, liquid penetrant, or
, ultrasonic testing, as a verification of their quality, and no such inspections were required.
Individual "A" also indicated that he felt that the company had not met all of the requirements of Code of Federal Regulations, Title 10, Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants (a copy of this regulation had been provided to him by RIII personnel). RIII personnel explained that all of the requirements of this regulation were imposed on utilities, but the provisions
- of the Eusky Quality Assurance Manual were the requirement- imposed
-on Husky af ter approval of the manual by utility representatives.
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- 17. Contact with Huskv Personnel Telephone contacts with Husky personnel indicated that some cable channels had been fabricated by Modern, with the order being proces-sed during November,1975, and completed in later months. Husky personnel indicated that this material was for another nuclear power plant, and was fabricated prior to the particluar utility's imposition of a requirement for work done by welders qualified to -
Section IX of the ASE Code. Husky personnel also indicated that virtually all of their welding was done in the horizontal welding position, and they did not recall any pieces for the Zimmer contract which necessitated vertical welding. A review of Husky welder certifications for the horizontal and vertical positions indicated that one Husky welder was not gaalified in the MIG procedure vertical (3G) welding position. Welders previously indicated by Husky personnel as having produced the majority of the Manual MIG welding for the Zimmer project (at work center 35) were recorded as having been qualified in both horizontal (2G) and vertical (3G) pocitions. Qualification to the "3G" vertical position also qualified a welder to perform flat (lG) welding per ASE Section II.
- 18. Contacts wi:h Husky Personnel Telephone discussions with Husky personnel on October 24, and 29, 1978, provided additional information on low strength aluminum materials.
Husky personnel indicated that aluminum materials were ordered to 6063T6 requirements, which include a "4n4~_= 30,000 lbs. per square inch yield strength (as shown by mill certificates). They stated that a shipment of the material was thought to be of low 2172 123 strength, and sampic test piece's sent to their test lab confirmed that the material was below requirements. Husky personnel indicated that as a result of this, the entire lot of material was returned to the vendor, and the balance of their orders with the vendor were cancelled. Husky personnel stated that the rejections of this material occurred in October and November 1977, with the original discrepancy report being-generated in September of 1977. They stated that in January 1978, representatives of the vendor visited the Husky facility and
. discussed the problem. -
O O 2172 124 18 -
Section II Prepared by T. E. Vandel Reviewed by D. W. Hayes, Chief Projects Section
- 1. Site Review Activities The following Zinner site activities were performed by the inspector relative to the allegations regarding inadequate material and welding of Husky Products, Inc. (Husky) cable trays, pans and fittings:
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- a. A review was conducted of the licensee source evaluation, surveillance and auditing activities performed regarding
- Husky. It was established that the licensee program for vendor evaluation and auditing had been ecccmplished in that the Husky Quality Assurance program and Welding.
procedures had been reviewed and approved by licensee representatives. Additionally, an audit by the licensee was performed of the implementation of the program at the Husky plant prior to start of fabrication. In response to questitming, the inspector was informed that no source inspection of material was done prior to shipment since the material was readily =manable to inspection upon receipt at the site. It was added that the material was considered so standard and unsophisticated as to not warrant shop inspection.
- b. In review of the cable trays, pans and fittings on site, it was established that essentially all of the material has been installed and indeed have been filled with cables.
During visual inspection of the installed trays no faulty or inadequate trays were identified. In discussions with the licensee representatives regarding the difficulty of visual inspection of welds now covered by galvanizing, it was concluded that testing of selected random samples of material would be a more ===ningful test. Therefore, the following list of samples, randomly selected by the licensee representative and the NRC inspectors, was picked for testing by either tension pull teste (yield strength) or by weld tear testing or both. Type P.O. Number Stock Number Tests Comoonents Straight tray 18" 7070-27655 55M1-18-144 Two yields, one tear Straight tray 24" 7070-27303 55M1-24-144 One yield, tw 217 2 123 tear Fitting 7070-27223 55N1-12-H30 One yield, one tear Straight tray 24" Route #1276K 55H1-24-144 One yield, (from control room) (P.O. unknown) one tear Fitting 7070-27655 55N1-24-VI90 -12 One yield one tear Fitting 7070-28009 55N1-24-VI30 -12 Que yield *
*No tear test was considered necessary since the fitting had- .
inadvertently been torn during handling and the'results of those weld tears showed adequate welding. It was further agreed that the yield strength tasting would be done by an independent testing laboratory in accordance to ASTM standard E-8 Tension Testing of Metallic Materials and that the "4"4 mum strength acceptance criteria vill be the S&L specification H-2199 requirement of paragraph 202.1; i.e., yield strength to ~ be a minimum of 30,000 psi. In addition, the weld tear tests would also be done by an independent facility and that the acceptability of the welds would be judged as outlined in ' AWS standard C-1.1.
- 2. Witness of Testing The inspector witnessed the following testing at independent labora-tories of the samples previously selected at the site.
- a. Yield strength testing was conducted on September 28, 1978, at Metcut Research Associates facility. The inspector reviewed the qualifications of the operator, the calibration and adequacy of the testing machine and the QA program standards of the facility and considered them to be acceptable for the test. It was further learned that the tensile specimens had been prepared in accordance with the ASTM E-8. The results of the tests are s.s follows.
Metent Site Sample *Tield Strength Ultimate Percent Number Number Pounds per Strength Elongation Square inch T-2 1162 1276K 40,700 48,100 34.9 T-2 1163 55N112-H30 42,600 47,800 30.7 T-2 1164 55H247I90-12 43,100 48,900 28.3 T-2 1165 55H1-24VI30-12 42,400 47,600 32.6 T-2 1166 55M1-24-144 42,100 44,700 33.0 T-2 1167 55M1-18-144(No. 1) 42,200 44,900 30.4 T-2 1168 55M1-18-144(No. 2) 41,400 44,800 33.7 2172 126 As can be noted from the table above, the yield strength values were well above the minimum yield value of' 30,000 psi and there-fore all test samples were deemed acceptable.
- b. Also on September 28, 1978, the weld tear tests of the resistance spot velds, were witnessed by the NRC inspector at the F&S Machine Company, located in Moscow, Ohio.
A test rig had been assembled whereby the test assembly was anchored to the floor and by use of a fork lift truck the assembly was pulled apart at the welds (side panels to tray bottom, welds). The test method performed adequately with the following results established. - Site Simple Number Number of Welds in Results of Tear Test Testinn 55M1-24-144 (No. 1) five Acceptable welds 55M1-24-144 (No. 2) three Acceptable welds 55M1-24-144 (Note 1) three Acceptable welds 1GC 1276K 55M1-24-144 three Acceptable welds 55N1-12-H30 fitting seveg One weld had a reduced spot section, see Note 2 55dl-24VI90 -12 fitting eigh Two welds had a reduced spot, see Note 2 55M1-18-144 three Acceptable welds Note 1: An additional test assembly, available for test in addition to the two planned to be tested, was also tested for a total of seven test assemblies tested. Note 2: The reduced spot section welds were subsequently measured and found to be adequate per the ninim"" size specified in AWS C-1.1. A total of seven test assemblies were tested with a total of 32 welds being tested. All welds were determined to be adequate with three spots being evaluated as being acceptable to AWS C-1.1. 2172 127
Section III Prepared by H. M. Wescott Reviewed by D. W. Hayes, Chief Projects Branch
- 1. Review of_ Welding Recuirements and Observation of Installed Cable Trav The inspector reviewed selected documents and made observations of' safety related cable tray and. fittings, as follows:
- a. ' Review of Sargent and Lundy specification H-2199, dated March 16, 1973, Revised July 17, 1973, titled, " Specification for Cable Pans".
- b. Review of NDIA Standard vel-1971 used in conjunction with the specification.
- c. Review of the Husky Products, Inc. Quality Control Manual, Section IX " Control of Special Processes", issue date December 18, 1974, revised January 15, 1975.
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- d. Review of Wa H. Zimmer Unit 1 " Documentation Check Lists" (Form QAS-106) .
- e. Review of certificates of compliance.
- f. Review of Galvanizing Inspection reports.
- g. Review of Wm H. Zimmer receiving inspection plans (KEI Form No. QA-8).
- h. Observations made of cable tray installed and in storage area.
- 1. Participated in selection of randomly selected cable tray and fittings to be tested for minimum yield strength and weldment strength tests.
- 2. Review of Welding Procedures, Qualifications and Observations at Burndv/ Husky The inspector reviewed welding procedure ' specifications, procedure qualifications records, welder perfor=ance qualifications, and selected documents pertaining to safety related cable tray and fittings, as follows:
2172 128
- a. Review of all welder qualifications.
- b. Review of Welding Procedure specification QAP-107. Welding Procedure No. 2 " Manual Gas Metal Arc Welding Process,"
effec:ive date October 18, 1974, Revision No. 01.
- c. Review of QAP 104 " Procedure for Inspection of Resistance Spot Welding", ef fective date August 18, 1974, Revision No. 01.
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- d. Review of inter-office correspondence concerning welding,
' that indicated QAP-107 should be requalified to reflect
, changes in essential variables.
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- e. Discussion with management and shop personnel.
- f. Observations made .in the shop area of fabrication in progress.
- g. Review of in process inspection records.
2172 129 Review of a Burndy/ Husky memorandum from the Husky welding engineer dated November 14, 1974, Subject " Welder Perfomance Qualification" indicated that a 75% argon and 25 carbon dioxide shielding gas mixture and .045 filler material was substituted for the welding grade carbon dioxide shielding gas and 0.35 filler material that was specified in QAP-107 " Manual Gas Metal Arc Welding Process", dated October 18, 1974, Revision No. 01. The memo further stated that, "The ASME Section says that if this occurs, the procedure must be requalified along with the performance tests.. (Section QW 281.2, QW 281.3 and QW 281.4)". An Inter-Office letter dated December 3,1974, stated that the argon / carb.on dioxide gas mixture would be used until the supply was exhausted
. at which time the velding grade carbon dioxide would be used.
The argon / carbon dioxide shielding gas mixture was used for approximately four weeks with no requalification of the welding procedure specification and welders. Husky management personnel indicated that QAP-107 would be requalified using the 75% argon and 25" gas mixture using the .045 filler material. This is considered to be an item of noncompliance to 10 CFR, Part 50, Appendix B, Criterion IX. (50-258/78-21-02) Subsequent to the investigation telephone contacts with Husky personnel by the investigation specialist established that steel TIG welding had been perfomed on cable tray prior to qualification of the velding procedure specificat' ion by two welders that had not qualified for the process. Husky personnel were requested to review the qualification records of the personnel who had performed the welding and infom RIII of the results of their review. Husky personnel informed RIII of the review by telephone, and followed with written notification dated November 10, 1978. The Husky review indicated that the two welders had performed TIG welding on equipment for the Zimmer plant prior to the welding procedure qualification for the TIG process. The steel TIG welding procedure was qualified on August 26, 1975, by one of the two welders. The second welder was qualified to the pro-cedure on March 10, 1976. Both welders had made several steel TIG welds prior to being qualified. 2172 130 These conditions were contrary to 10 CFR 50, Appendix B, Criterion IX of the ASME Code. (358/78-21-01) Exit Interview The inspectors and the Chief, Reactor Construction and Engineering Support Branch, met with licensee representatives noted in Details, Section I, under Personnel Contacted, at CG&E Co. on September 22, 1978. The ' inspectors summarized the scope and findings of the investigation and the licensee acknowledges the findings.
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. Attachments: Exhibits ~
I through VII i 1
.5 17?L.
e e
.e r August 18, 1978 Public Interest Research Group ,
2000 P Street _N. W. - -- Washington, D. C. 20036 Attention: th. John Abbotts .
Dear 11. Abbotts:
I am vriting this as a former employee of Risky Preducts Inc. of Florence, Kentucky to report serious and deliberate non-cenfermance to 10 CTR 50 Nuclear Requirements and Engineering Specifications based on the above requirements. To make it even verse they send out notarized Certificates of Cenpliance with the full knsuledge they are false. . In May of this year I had occasien te visit the Zimmer Nucles.r Centainment area and to see theTsrious control areas and in particular to see Risky cable trays in position and many filled with the cables. Since this visit I have been disturbed by two aspects of E2 sky's non-cen formance, particularly as they relate to the safe operation of this plant after completion of construction. These two important aspects are as follevs:
- 1. Use of inferier and weak material completely out of specificatiens.
- 2. Trays velded by incompetent velders with every type veld defect present in every tray. assembly.
The folleving illustrates these two aspects in more detail. Ihey are related to the Zimmer job specifically which was the original job with the 10 CTA 50 requirements. On this job flagrant and serious non-centern-ance securred and with this as a pattern it has occurred en all subsequent jobs. MATIRIAL: All tray is designed vtth a loma capacity which includes a safety facter.
. The tensile stength of the side rails largely determines this capacity.
On the Zimmer job the tensile strength of the side rail material was te be in excess of 35,000 peneds. Hisky received and tested anterial as lov as AB,000 pounds and a censiderable amount in the range of 20 to 23,000 pounds. Seae was rejected, some accepted en the basis it would be used for fittings where strength is not as critical. LL Exhibit I Page 1 of 7
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Page 2. lastead the material was not kept separate and thus many ven weak eid-rails wore made up inte long straight assemblies. After finding out that coanon a;111 steel varied se videly in tensile strength no more testing was done se that they could remain " unaware" of this candition. Incidentally some testing of T-6 aluminum was also performed and a vide range of tensile strength was e?.se found. This was also ignored as above. What this adds up+4 is that & sky has built tray that vill not carry the rated lead even with safety facter included.
~ ~. .
VELDING:
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The Zimmer job was the first job requiring the use of Certified velders in ordar to insure goed velds msky centra.cted with Gladstene Iaborateries of Cincinnati te set up a welder certification program. They did this and then tasted all the velders. Without exception they failed the tests miserably. Esky then called in various velding Ingineers and W. Ind "J9- of Tech-nieren 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 &. Ind. "J" repsrt. &. Ind. "J" was asked if he could er veuld train the velders. He refused, stating that it is very difficult, if not nearly impossible to untrain people first, then try to retrain, .
than it is te start fresh with a persen having ne prior velding knowledge .. or experience. , Esk;y then proceeded te verk en their evn in crash progra=s in which the velders finally velded one piece which veuld pass a bend test. This vsidor then became " Certified" by & sky. Eevever., what is critically important is that nething wecurred to the quality of the production velds! In fact it remains to date in the same sad state as W. Ind. "J"s' findings dated October 30, 1974. Just a few weeks age one volder was " tested" over 60 times before he finally made a test piees vhinh was only marginally acceptable. New he is a Esky " Certified" welder! Starting in July and continuing this month a nov type of non-centersance - is presently in process en the Clinten job. Fittings are being Mig spot velded centrary to specific Engineering requirements. In addition Aluminum Bronze filler red is being used with fitll knowledge that aluminum is not permitted in the containment area. Even verse the position of the spot is in cuch a manner the veld is less than 355 effective! Substantiation of all these charges can be acce=plished thru examination of Esky documents in relation to Material and to the Welders by thn recerie. visual ernintion of the velds and by rotesting the se called "Certifi.d" velders by a competent Welding Engineer. Visual inspection of the Clinten fittings vill substantiate the charges outlined. , 2172 133 Exhibit I i
Page 3. What disturts me even more than the actual incidents described is the fact se many top management people see nothing vreng in all these actions. Se little real concern is shown to producing a truly quality product within the specifications. This should become even aero particularly so when nuclear safety is directly involved. Yours truly, . s ~~- Individual "A" - - Distribution as follows: Ingineering Companies that may er may not be concerned. Ibasco - United Engineers and Constructors , Bechtal Corp. Brown & Root
.. N Sargent & Lundy Stone & Webster Black & Veatch This may not be complete, however to the best of my knowledge it is.
Government Agsneies: Nuclear Regulatory Cessission Congressional Joint Atomic Energy Consittee Private Group Public Interest Research Group j Exhibit i Page 3 of 7 e 2172 134
J Report of the Findings at - Husky Products incorporated on October 30, 1974
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Submitted by: . . Technichron Inc., $ch'ool'of Welding It was generally found that the resson your company has had difficulty - in certifying your veldors is due to the f act that while some of your meu are qualiffed weldors, they suffer from the ills of an employee that is offering an incentive program. In order for an employee of your company to meet his required production, level, plus benefit by the incentive program it was found that their wclding machines were set at maxiumum output allowable, which is just below the
' point of blowing holes in the parent metal. This condition creates improper - welding methods, and instead of establishing good welding, you have a situat$on of b)nsting the metal together. These extreme amperage settings g also make it necessary to use higher gas flow in order to control the ,, src. Tht: hs: to be er.tremely costly to your company.
Beeause of the conditions that exist (weldin~g machine settinc.s and gne flows) it was obacrved that improper velding is a enamon occurance at llucky Products. The welds are not. structurally sound. Aluminum WeldJnr.: A11the' welds have craters and it was observed that most of these cratcra show the common condition know'n as " crater cracking". It was - further observed that there were many welds that had both erscking conditions in the weld as well as the crater. These conditions are primarily caused by the extremely high ampcragen and gas covernr,e. Your wcldors are running extremely hot velda due to speed and thus you have rapid cooling conditions and cracking. The high gas flows (while costly) niso causes rapij cooling and thus cracking. , Generally it was observed that the wcldors in your aluminum welding arnas had good welding techniques however lack knowledge in setting up the proper welding conditions before welding .
; POORORBIOL Exhibit I Page 4 of 7
-. . . . . o
.6 .,
'l ,
u . _These men lacked the following knowledAe:
- 1. Setting the welding machine
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- 2. Set ting the proper gis flow
- 3. Balling the tungsten rather then
- pointing it
- 4. Controlling the weld to prevent craters -
- 5. c1 caning the parent metal before welding Stect Welding: .
Tour men were observed in the stec3 veldinr, areas. One man had the knowledr.e of proper machine and gas flow settings however he lacked the welding techniques. This man uns one of your oldest voldors. The other three men had very little knnwledr.c about proper settings and one of the three lacked the proper aciding techniques. This man
.. vaa your olde.ut employee in your welding department. Again Jt was
, apparent that all conditions existed. to turn out maxian:a production.
An Jon;', as you have these enndittnan you will find that certifying velitorn is cotnr. to be extremely difficult. When observing several of the tent coupons run by your veldors it was found that the following conditions existed:
- 1. Crystal 11:4tions of the weld
- 2. Porosity
- 3. Penceratinn that exceeded 100%
4 Undcrcut
- 5. Weaking of parent metal in the heat ,
effceted zone All the conditions are created directly by running te- high of amperages, too high of gas flows, and dirty metal. 2172 136 Exhibit I [ ** ' *' '
)
} hik h lx t
. ; .. ms . Other Observations:
- 1. The using of fans in the welding areas is common practice. This condition causes the gas shield to be blown away, thus causing porosity in the welds. This is another reason
-for the high gas'ilou'prescures which is costly '
since larger volumes of gas,are used then necessary.
- 2. 2 -
^ It was noted that Argon /CO mix was being used in your M.I.G. welding operations on steel. This again is costly because CO2 youldbeadequatefor your operation. St3aightCD costs about 1/6 of what 75/25 Argen/C0 mix costs.
- 3. Many of your emplevees do not use eye protection -
or face protectica. I'm certain you must have frequently absenteeism due to eye flash injuries. ~
- 4. No use of safety glasses in the entire plant.
Weldors must wear safety glannes under their welding hood. (An OS!!A Standard). 5 .' The plant is not in complinnee with OSHA Standards. This could cause extreme hardship in the future especially if you have a severe injury of one of your c=ployees. Suggetion: Ilusky Products Inc., should consider a training program for thoses individuals employed in their welding department. This program should emphasize velding methods as well as welding techniques. Any success arising from this training program is highly questionable, since proper velding methods and techniques would cut production. The present attitude in your welding department is quantity not quality. Sound certified quality welds will definitely reduce quantity, however . the savings in cost of materials will most likely improve or equalize profits. Exhibit I Page 6 of 7
] I 2172 I37
C.
-4 I am submitting this report with the intension of creating many constructive suggestions and have no intension to sound like I am being critical. You realized you had some concerns or you would have never contacted Technichron in the first place. Therefore, I sideercly hope that I have been if service to your company and .
that vc m:y serve you again in the future. Thani you. . Respectively Subaitted Individual ".T" , Technichron School of Welding . w . P00R ORRINM Exhibit I Page 7 of 7 2172 08
1, Individual "B" , make the following written voluntary statement to James Foster who has identified himself
.to me as an investigation specialist of the Nuclear Regulator-* Conmission. I understand that I do not have to make a statement and.that any statement I do make may be used in legal proceedings.
I have no knowledge of low yield strerigth steel, below - 30,000 lbs. per square inch, having been p~ resent at the Husky Products Plant nor of such material having been utilized in the production of cable pans for the Zimmer Nuclear Power Plant. I have read the preceding statement consisting o. one page and made corrections where necessary. It is ! a true representation. , Signed Individual "B" onte 9 -A l- 72 Witness @', <sb4 Won;d' f.y., Witness bw d f/ 7g
/
300RORGM Exhibit II 2172 139
I, Individual "C" , make the following written voluntary statement to James Foster who has identified himself to me as an investigation specialist of the. Nuclear Regulatory Commission. I understand that.I do not have to make a statement and that any statement I do make may be used in legal. proceedings. I have no knowledge,of low yield strength steel, below 30,000 lbs. per square inch, having ,been present at the Husky Products Plant nor of such material having been utilized in the production of cable pans for the Zimmer Nuclear Power Plant. I have read the preceding statement consisting of one page and made corrections where necessary. It is a true representation.
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Signed Individual "C" Date f~A$~ l8 Witness s [28 9 4 i Mitne v /,ui h/ Yb
/ ,s
/ -y; . ge
.-/
L' 2172 140 Exhibit III
I, Individual "I" make the following voluntary written statement to James E. Foster, who has identified himself to me as an Investigation Specialist of the Nuclear Regulatory Commission. I understand that I do not have to make a statement, and any statement that I do make may be used in legal proceedings. I am presently employed by Husky Products (as) an Industrial Engineer. To the best of my knowledge, no low yield point material has ever been utilized in the manufacture of equipment for the Zi=mer Nuclear Power Plant, Unit 1. I have been directly involved with the in-house welder certification program since its inception. This program has been properly conducted, and follows the provisions of ASME Section IX for welder certification.' I did not object to my participation in this program, but had to become knowledgeable in welding before becoming centrally involved in the program. I feel that welder certification has been honestly condu:ted. Welding procedures and welders have not been re-qualified when veld shield gas or gas mixtures have been changed. I pointed out to Individual "A" that this had not been done. After 3-4 weeks, Husky started using CO2 gas strictly as the procedure calls for. Exhibit IV 2172 14I page 1 of 2
Individual "I" . . . . . I was aware" that the Aluminum-Bronze MIG spot veld process had not ~ been qualified as to process or welders. I felt that these qualifications were n'to necessary, as the process is similar to resistance welding in that it is semi-automatic. The welding parameters are set, and the welder only aims the welding gun. I have re.ad this voluntary statement, consisting of two (2) pages, and made corrections where necessary. It is a true representation. Witness: T-.. r vn . e . ,- o/9A/7A Signed Individual "I" Harvey M. Wescott 9/28/78 Date 9/28/78 Exhibit IV Page 2 of 2 2172 142
Report No. d> V -d 7 / C. 3 - / Tensile Testing of ( 7) Pecimens Maed- -eto S t
. M; a. D us wwNo. ,%,,, h:_ A [ (*649 Nominal Gage Section: 0.0 '<O.5
/J.O*
Temperature: 'R . T . _ @ Strain Rate through 0. 2% Yield: O.OOI in. /in. / min. Head Rate thence to Failure: O .O[ in. / min.
. 02% ?/isco MRAI Spec. -
U. T. S. Y. Fb, ar- Elong. ., No. No. (ksi) (k - (ksi) (%) ,,
-r- . 2f;67 Ssmi -is-IW 4'f.9 ( v 7. a so. V N m- -Jtle 7 Ss M 1 - le -id 44.8 \ '/ / . V 3.37 /
v J I66 ssM i ly y' W.7 / %7,/ 35.0 N n a t(Gr 35m 1 - a Y -t 44-l> 7(, V- 48.I ( 40.9 .54.9 / p .a i le>3 ss n/1 -is -H 30 # 7. 8 \ W.G 30.7 .(
-1 2IIuY SS N.1 - A H \ I I .2
/
1/8.9 ) 43. / 28.3 )
'T ra ll65 SS N L ~ c24 b'I l? 4 7<G ( 0.2. Y' .3 2, lo f
) (
( h
\ /
/ (
(
)
/ 1
( I ) Notes: , l f,
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2172 143 Page I b of / Project Engineer Laboratory Technician
e P00R ORSNA. J'-/d ff 4,,a, yri.s,Jr 4,'w.ci s - g p p , ,. 9 e s's x . x M
,t ys [f-}"8 b $/ *' S p,*gg& t*l)? { dt '$ C'*r hy. $,99;g)?f*S f
;..g.fic><ci:.f"'d6
fe/j'f',9 e I .Y'8 " - f,p, j:@iyASEV'
;-/p ?&
Text: Individual "D": 2-10-76 1.ov tensile Zinsner stringers mixed in stores and g now being used for straights! Individual "A" 2 4k Returned with verbal reply to " forget it" 2-10-76. Exhibit VI
,'..., Sheet 1 of 2 September 22, 1978 Bisky mamfactures Cable Trays teEMA Standards as per a catalog as a consercial specials toitem. It aise manufactures a customers modifientions of Standard items :e.d specifications.
Zimmers were special in 4 important ways as follows.:
- 1. They required special vrap around splice plates with different bolt holes to strengthen tne joints where 'l trays come together.
- 2. They specified side rail material to have a min 4== tensile strength of 35,000 pounds.
3., kieldibg was to be Mig Welded in accordance with ASE Section 9 and te be performed by certified velders. ,
- 4. All pertinent records relative to Quality are to be retained on
, long term retention basis.
In respect to the velding this meant that the velds were to have a quality level equal to that required for boilers and pressure vessels. These were to be top quality velds wit.h good fusion, structurally sound and with m4* = ~ of defects. These were to be velded by qualified velders certified.as such thru testing as called nut in Section 9 ef ASME. - Bisky velders are competent te produce commercial type velds for an ordinary commercial product where def'ects and lack of fusion is acceptable. This is ' the type of weld done daily en our cessnercial verk. We have Incentive Standarde en this verk and our velders earn from 160 to 200% day in andJay out. This-is the type velding described in Mr. Ind. "J"s report. Testing of our velders established their in2empetence te preduce quality velds _. at pressure vessel' standards. Bishy verked with the veldors until they made one good piece which would pass a bend test. The velder is then certified and then goes right back to production madng commercial type velds for Incentive
;sich is the only type veld ever made. Outside of mairing this one tent piece they have no production experience in this. type veld. Based on their difficulty in passing the test they need considerably mere training, folloved with actual production type experience, before they can be ecmpetent to produce a high quality of veld.
Qualitf velding would greatly increase ti2e mamfacturing cost, particularly if we ch 'ged all velding to beaeme quality type. A second alternative would be to produce quality velds vben required on nuclear verk and commercial quality en all other verk. Bisky's decision was to certify the voldors but produce only the normal nemmercial type welds en all verk. W .veuld tell people we veld to Section 9 of ASME vith certified velders. This has never changed. We have never made any effort to produce pressure vessel quality velds.
} gdl d. i
@@h[Qf _.
Exhibit VII Page 1 of 2 l 2172 14.5 SEP 251978
'~ ,.1,.' Shset 2 of 2 t This was done en the Zimmer job ans vas incorporated into the Quality CentreIl Manual that Esky Velding is in confermance with AS?S sect!en 9 and the velds are made by certified welders. This is misleading in that people think that they will get quality velds. Instead everybody gets ceswrcial quality velds made by a welder vhe ence made one quality veld piece. Cn this basis & sky has secured additional nuclear verk. The top knagers of Ihsky are en a bonus setup. Anything that adds cost subtracts from profit which in turn reduces their bonus. To produce rplity would be very expensive and would reduce their bonus. It is entirely possible the decision not to produce the specified quality velds was based entirely - un the cost required te de so. The reason given to me and my people was, "that it is completely unnecessary. . Individual "A" September 22, 1978
?DDR OlBINAl.
Exhibit VII Page 2 of 2 2172 146
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