ML19303A910
| ML19303A910 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/15/1982 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML19303A908 | List: |
| References | |
| NUDOCS 8206130070 | |
| Download: ML19303A910 (8) | |
Text
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p* *c uq'c4 UNITED S'
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NUCLEAR REEULAbRY COMM4.ON C
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{g WASHINGTON, D. C. 20555
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3D-258 cumurN July 15,1982
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The Honorable Morris K. Udall Chairman, Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D.C.
20515 m
Dear Mr. Chainan:
As you requested in your June 14 and July 12, 1982 letters, the information relating tc the Zimmer Quality Confirmation Program is enclosed. This infor-mation is current as of May 30, 1982.
I hope this information is responsive to your request.
Additional details of the ruality Confirmation Program results are contained in the licensee's e
May 30, 1982 status report which we provided to Dr. Henry Myers of your scaff on June 16, 1982.
If you have further questions on this matt.r.
please do not hesitate to contact me.
Sincerely.
s Original signed by Nunzio J. Palladino Nunzio J. Palladino i'n closure:
Distribution:
As Stated WJDircks TARehm cc: Rep. Manuel Lujan VStello RDeYoung HDenten GCunningham Cleared with all Cmrs' Offices by SFCY C/R.
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-RESPONSES TO INFORMATION REQUESTED BY REPRESENTATIVE MORRIS rs. UDALL 1.
The number of structural steel weld.s inspected to date, the number of structural steel welds known not to conform to the Comission's requirements, and the current estimate of the quantity and quality of work necessary to bring these welds into conformance with requirements.
Response
Quality Confirmation Program (QCP) Task I, " Structural Steel." includes the inspection of structural steel "weldments" and " connections." The "weldments" and " connections" generally involve more than one weld.
The emphasis of the licensee and the NRC is being placed on the number of weld deficiencies indentified with those "weldments" and " connections" rather than on the number of deficient welds. One weld could have multiple deficiencies (e.g., undercut, lack of fusion, undersize, profile) due to nonconformance with different aspects of the applicable specifications.
Although we are concentrating on the number of weld deficiencies rather than the number of deficient weld, we have estimated the number of welds affected to be responsive to your request.
~
The licensee committed in the Preliminary Safety Analysis Repor (PSAR) and Final Safety Analysis Report (FSAR) to the American Insti+"+e of
. Steel Construction Specification (AISCS), " Specification for.... Design, Fabrication and Erection of Structural Steels for Buildings" - 1969, snd
!' Structural Weld Code," AWS D1-1-1972.
The Sargent and Lundy specifica-tions, which meet or exceed the PSAR and FSAR comitments, establish the
? equirements for "weldments" and " connections" including the structural welds.
Failure to meet the PSAR and FSAR comitments is considered to be noncompliance with the Comission's. requirements.
Failure to meet the Sargent and Lundy specifications without an appropriate evaluation and review is also considered to be noncompliance.
The licensee must resolve identified noncompliances by determining if the deficiencies are acceptable as is based on engineering' evaluations or by reworking the welds.
Where possible, the licensee has decided to resolve deficiencies with the "weldments" and " connections" by rework to bring them into conformance with the specifications rather than attempt to
. disposition the nonconforming conditions through engineering evaluations.
i
" Rework" as used in this report means physical effort to correct
~
deficiencies.
The QCP Task I, " Structural Steel," is approximately 53 percent complete (May 30,1982) with an estimated completion date of December 1,1982.
The task includes the following sub-tasks:
i I
. a.
Cable Tray Foot _ Connections The inspection of the cable tray foot connections is complete with -
259 connections inspected.
253 of those connections were noncon-forming in some manner.
Each of the connections involves a number of welds (2 to 6).
Based on an average of 4, we estimate that 1000
' welds were involved.
975 deficiencies associated with the 253 nonconforming connections l
were identified.
242 of those deficiencies have been dispositioned.
103 of the dispositioned deficiencies are to be reworked as necessary to correct the nonconforming conditions and the rework is in progress.
The other 139 dispositioned deficiencies were determined by the licensee to be acceptable as is.
The NRC is reviewing the licensee's evaluations of the deficiencies.
b.
Drywell Steel The inspection of the drywell steel (excluding the 525' elevation) is 49 percent complete with 161 beams inspected.
93 of those beams were nonconfonning in some manner.
Each of the beams involves a number of welds (8 to 16).
Based on the average of 12, we estimate that 1900 welds were inspected.
369 deficiencies associated with the 93 nonconforming beams were identified.
181 of those deficiencies are to be reworked as necessary to correct the nonconforming conditions and the rework is in progress.
The other 9 dispositioned deficiencies were determined by the licensee to be acceptable as is.
The NRC is reviewing the licensee's evaluations of the deficiencies.
The beam connections in the 525' elevation of the drywell are being I
cleaned of paint to allow inspection of the welds.
c.
Gallery Steel The inspection of the gallery steel (control rod drive area) is com-plete with 106 beams inspected.
39 of those beams were nonconforming j
in some manner.
Each of the beams involves a number of welds (8 to 16). Based on the average of 12, we estimate that 1200 welds were inspected.
126 deficiencies associated with the 39 nonconforming beams were identified. All of those deficiencies have been dispositioned.
108 of the dispositioned deficiencies are to be reworked as necessary to correct the nonconforming conditions and the rework is in progress.
The other 18 dispositioned deficiencies were determined by the licensee to be acceptable as is.
The NRC is reviewing the licensee's evaluations of the defichncies.
d.
Control Room Structural Steel The inspection of the control room structural steel is partially complete with 208 beams inspected. Approximately 150 of those beams were nonconforming in some manner.
Each of the beams involves a number of welds (8 to 16).
Based on an average of 12, we estimate that 2500 welds were inspected.
1835 deficiencies associated with the nonconforming beams were identified.
All of those deficiencies have been dispositioned.
1818 of the dispositioned deficiencies are to be reworked as necessary to correct the nonconforming conditions and the rework is in progress. The other 17 dispositioned deficiencies were determined by the licensee to be acceptable as is.
The NRC is reviewing the licensee's evaluations of the deficiencies.
The inspection of activities regarding the control room structural steel have recently been expanded to include auxiliary steel and hangers.
With respect to the quantity of work necessary to bring deficient welds into conformance with the requirements, the amount of rework which will be performed is considered by the NRC to be significant.
An indication of the amount of rework involved is that an average of 32 person-hours has been required to bring a nonconforming beam into conformance Based on this average, 9000 person-hours will be necessary to correct the beams alone.
However, neither the licensee nor NRC knows the total impact the rework will have on the project completion date.
This impact will not be known until the full magnitude of the rework is determined by the completion of the QCP.
With respect to the quality of the work necessary to bring deficient welds into cenformance with requirements, the rework activities are being' performed.under the conditions established by the April 8, 1981 Imediate Action Letter (IAL) including 100 percent reinspection of all contractor inspection activities at this time. The' NRC's Reoion III Office is monitoring the rework activities.
Although some problems have been encountered, no significant concerns have been indentified with the rework activities.
4
~ 2.
A quantitative statement concerning findings regarding the t~aceability of piping and the implications of'such findings.
~
Response
Quality Confirmation Program (QCP) Ta'sk III, " Heat Number Traceability,"
is approximately 55 percent complete and includes review of drawings and field installation of small-bore and large-bore piping, heat number log,.
and purchase orders.
A large number of problems have been identified during the reviews of piping documentation, installed conditions, heat number records, and purchase orders. The problems are:
Review of 2354 small-bore piping drawings and comparison with installed a.
piping revealed heat number discrepancies on approximately 20 percent of the drawings.
b.
Review of over 1900 purchase orders and associated certified material test reports for piping revealed heat number discrepancies on approximately 20 percent of the documents.
A number of the 3206 purchase orders reviewed have unsigned certified c.
material test reports, some vendors were unapproved, and some non-essential material was upgraded to essential.
d.
For large-bore piping, drawings have not been kept current and indications suggest field modifications of spool pieces have been made without proper documentation.
A determination as to whether piping of unacceptable or unknown cuality was installed has not yet been rade by either the licensee or the NRC. That determination will be made after QCP Task III is completed.
The potential impact of the loss of traceable piping is that a substantial amount of piping may have to be replaced. As noted above, a quantitative determination as to the amount of such piping will be made following completion of QCP Task III.
t 6
3.
The NRC staff assessment of the findings of the review of welder qualification records and the implications of such findings.
Response
Quality Confirmation Program (QCP) Task II, " Weld Quality," is approximately 58 percent complete and _ includes the review of welder qualifications for 1800 welders.(approximately 4600 records).
A large number of problems have been identified during the review of welder qualification records. Of the 942 records reviewed to date for 391 welders, deficiencies have been identified including the use of correction fluid, improper performance of qualification tests, and lack of objective evidence for test specimens. The licensee stated, based on a preliminary assessment, that these problems do not render the qualifications of the welders indeterminate and that all welders presently working on site are qualified.
As the NRC has questions as to the validity of this licensee determination, this matter will be pursued on a priority basis.
The NRC staff has not yet made an assessment of the. findings of the review of welder qualifications. The staff will make such an assessment after the licensee completes a review of the matter.
The potential impact of the welder qualification records is that a substantial number of welds may have to be replaced.
A quantitative determination as to the number of such welds will be made by the staff after completion of licensee review efforts.
W
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4
6-4.
The NRC staff assessment as to the extent and significance of problems
.resulting from materials having been purchased from unqualified vendors.
t
Response
Quality Confirmation Program (QCP) Task I, " Structural Steel," and Test II.
" Heat Number Traceability," include the review of material purchases concerning structural stgel and ASME piping systems. These tasks will be expanded to include the review of purchases from unapproved vendors in other areas.
A problem has been indentified witnin the above QCP tasks snd also by a separate H. J. Kaiser Company document review group related to nonessential material purchased from unapproved vendors being upgraded to essential material without appropriate documentation. The licensee has determined that all material As the presently being installed has been purchased from qualified vendors.
NRC has questions as to the validity of this licensee determination, this matter will be pursued on a priority basis.
The NRC staff has not yet made an assessment of the findings of the review of material purchases fron unqualified vendors.
The staff will make such an assessment after the licensee completes a review of the matter.
The potential impact of the material purchases is that installed materials may have to be replaced. A quantitative determination as to the amount of such material will be made by the NRC staff after completion of licensee review efforts.
6 4.
e '
5.
The NRC staff assessment of the findings that have emerged from the review of Nonconformance Reports.
Response
Quality Confirmation Program (QCP) Task VII, "Nonconformances," is approximate 1f 60 percent complete.
Voided Nonconformances (NRs)
A large number of problems have been identified with approximately 400 of the 1031 voided NRs reviewed to date.
These approximately 400 voided NRs will require additional investigation'to resolve questions as to acceptablity of conditions. The investigation efforts are in progress.
Completed Nonconformances The licensee's review of 290 of a random sample of 300 NRs has revealed problems with 10 NRs and may result in the reopening of those 10 previously closed NRs.
Punchlist The licensee maintains a "punchlist" which is a list of unfinished items with systems.
The licensee's review of the "punchlist" revealed 100 items which may be issued as NRs.
The licensee activities are being monitored by the NRC. An assessment by the NRC staff of the findings has not yet been made.
The staff will make such an assessment after completion of QCP Task VII.
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The Honorable Morris K.
dall Chairman, SuDcommittee o Energy and the Environmerit Committee on Interior and sular Affairs United States House of Repre'entatives Washington, D.C.
20515 e
Dear Mr. Chairman:
As requested in your June 14,198, letter to me, the following informa-tion relating to the Zimmer Qualit Confirmation Program is provided. This l
information is current as of May 3 1982.
l 1.
Information Requested The number of structural steel we ds inspected to date, the number of structural steel welds known no to conform to the Commission's requirements, and the current esti te of the quantity and quality of r
work necessary to bring these welds into conformance with requirements.
Response
i Quality Confirmation Program (QCP) Tas I, " Structural Steel," includes the inspection of structural steel "we ments" and " connections." The "weldments" and " connections" generally involve more than one weld.
The emphasis of the licensee and the NR is being placed on the number of weld deficiencies identified with tho e "weldments" and "connec-tions" rather than on the number of defic'ent welds. One weld could i
have multiple deficiencies (e.g., undercu1, lack of fusion, undersize, profile) due to nonconformance with differ nt aspects of the applicable specifications. Although we are concentra ing on the number of weld deficiencies rather than the number of defi ient welds, we have made i
an attempt to estimate the number of welds be responsive to your request.
b t
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The Honorable Mor is K. Udall l The licensee co.. 'tted in the PSAR and FSAR to the American Institute of Steel Construc 'on Specification (AISCS), " Specification for the Design, Fabricatio and Erection of Structural Steel for Buildings" -
1969, and "Structura Weld Code," AWS D1-1-1972. The Sargent and Lundy specifications, which meet or exceed the PSAR and FSAR commitments, establish the requirerr nts for "weldments" and " connections" including the structural welds.
ilure to meet the PSAR and FSAR commitments is considered to be in n compliance with the Commission requirements.
Failure to meet the S&L sp cifications without an appropriate evaluation and review is also consider to be in noncompliance.
l Identified noncompliances (i.e, deficiencies) with specifications must be dispositioned by the li nsee to determine if the deficiencies are acceptable-as-is based on en 'neering evaluations or if the defi-ciencies must be rectified by some ianner of rework.
Where possible, the licensee has decided to resolve eficiencies with the "weldments" and " connections" by rework to bring em into conformance with the specifications rather than attempt to
'sposition the nonconforming conditions through engineering evaluatio
" Rework" as used in this letter means physical effort to correct d iciencies.
The QCP Task I, " Structural Steel," is appro imately 53% complete (May 30, 1982) with an estimated completion d
.e of December 1, 3982.
The task includes the following sub-tasks:
a.
Cabie Tray Foot Connections The inspection of the cable tray foot connectic is complete with 259 connections inspected.
253 of those to ections were nonconforming in some manner.
Each.of the connett'ons involves a number of welds (2 to 6). Based on an average of
, we estimate 1000 welds were inspected.
975 deficiencies associated with the 253 nonconforming c ec-tions were identified.
242 of those deficiencies have been dispositioned.
103 of the dispositioned deficiencies are to be reworked as necessary to correct the nonconforming conditions and the rework is in progress. The other 139 dispositioned defi-ciencies were determined by the licensee to be acceptable-as-is.
The NRC is reviewing the licensee's evaluations of the deficiencies.
b.
Drywell Steel The inspection of the drywell steel (excluding the 525' eleva-tion) is 49 percent complete with 161 beams inspected.
93 of those beams were nonconforming in some manner.
Each of the beams involves a number of welds (8 to 16). Based on an average of 12, we estimate 1900 welds were inspected.
s The Honorable Morris K. Udall 369 deficienc'es associated with the 93 nonconforming i.?ams were identified.
I 1 of those deficiencies have been disposit1or.:d.
172 of the disp itioned deficiencies are to be reworked as necessary to cor et the nonconforming conditions and the rework is in progress.
e other 9 dispositioned deficiencies were determined by the icensee to be acceptable-as-is.
The NRC is reviewin the licensee's evaluations of the deficiencies.
~
The beam connections 'n the 525' elevation of the drywell are being cleaned of pain to allow inspection of the welds.
c.
Gallery Steel The inspection of the ga ery steel (control rod drive area) is complete with 106 beam inspected.
39 of those beams were nonconforming in some mann Each of the beams involves a number of welds (8 to 16).
ased on an average of 12, we estimate 1200 welds were ins ected.
126 deficiencies associated wi the 39 nonconform'ing beams were identified. All of those defic ncies"have been dispositioned.
108 of the dispositioned deficie ies are to be reworked as necessary to correct the nonconfo ing conditions and the rework is in progress. The r,ther 18 dispo itioned deficiencies were determined by the 1 Nensee to be acc table-as-is.
The NRC is reviewing the licensee's eval tions of the deficiencies.
d.
Control Room Structural Steel The inspection of the control room structural steel is partially complete with 208 beams inspected.
Approximately 150 of those beams were nonconforming in some manner.
Each of the beams involves a number of welds (8 to 16). Based on an average of 12, we estimate 2500 welds were inspected.
1835 deficiencies associated with the nonconforming beams were identified. All of those deficiencies have been.dispositioned.
1818 of the dispositioned deficiencies are to be reworked as necessary to correct the nonconforming conditions and the rework is in progress.
The other 17 di. positioned deficiencies were determined by the licensee to be acceptable-as-is.
The NRC is reviewing the licensee's evaluations of the deficiencies.
The inspection activities regarding the control room structural steel have recently been expanded to include auxiliary steel and hangers.
The Honorable Morris K.
dall i With respect to the qu ntity of work necessary to bring deficient welds into conformance.ith requirements, the amount of rework which will be performed is co sidered by the NRC to be significant. An indication of the amoun of rework involved is that an average of 32 man-hours has been re ired to bring a nonconforming beam into conformance.
Based on th s average, 9000* man-hours will be necessary to correct the beams alone However, neitner the licensee nor NRC knows the total impact the ework will have on the project completion date. This impact will not e known until the full magnitude of the rework is determined by comp 1 tion of the QCP.
With respect to the quality of rk necessary to bring deficient welds into conformance with requ ements, the rework activities are being performed under the conditio s established by the April 8, 1981, Immediate Action Letter (IAL) including 100% reinspection of all contractor inspection activities t this time. Region III is routinely monitoring the rework activ ties. Although some problems have been encountered, no significant oncerns have been identified with the rework activities.
2.
Information Requested A quantitative statement concerning finding regarding the traceability of piping and the implications of such findi s.
Response
Quality Confirmation Program (QCP) Task III, "Hea dumber Traceability,"
is approximately 55% complete and includes review o rawings and field installation of small-bore and large-bore piping, heat log, and
-a purchase orders.
A large number of problems have been identified during the reviews of piping documentation, installed conditions, heat number records, and purchase orders. The problems are:
(1) Review of 2354 small-bore piping drawings and comparison with installed piping revealed heat number discrepancies on approxi-mately 20% of the drawings.
(2) Review of over 1900 purchase orders and associated certified
~
material test reports for piping revealed heat number discrep-ancies on approximately 20% of the documents.
(3) A number of 3206 purchase orders reviewed have unsigned certified material test reports, some vendors were unapproved, and some nonessential material was up;r:ded to essential.
)
(4) For large-bore piping, drawings have not been maintained current and indications suggest field modifications of spool pieces have been made without proper documentation.
j
The Honorable Morris K. Udall A determinatio as to whether piping of unacceptable or unknown quality was ins alled has not yet been made by either the licensee or NRC. That de ermination will be made after QCP Task III is completed.
The potential impa t of the loss of tracability of piping is that a substantial amoun of piping may have to be replaced. As noted above, a quantitati determination as to the amount of such piping will be made followi g completion of QCP Task III.
3.
Information Requested The NRC staff assessmen of thc findings of the review of welder qualification records an the implications of such findings.
Response
Quality Confirmation Program CP) Task II, " Weld Quality," is approxi-mately 58% complete and includ the review of welder qualifications for 1800 welders (approximately 460 records).
A large number of problems have bee identified during the review of welder qualification records. Of th 942 records reviewed to date for 391 welders, deficiencies have bee identified including use of white-out, improper performance of quali ication tests, and lack of objective evidence for test specimens.
Th licensee has determined that all welders presently working on site ar lified.
The NRC staff has not yet made an assessment of the findings of the review of welder qualifications. The staff will make such an assess-ment after the licensee completes his review of the matter.
J The potential impact of the welder qualification records is that a i
substantial number of welds may have to be replaced.
A quantitative determination as to the number of such welds will be made by the staff after completion of licensee review efforts.
4.
Information Requested The NRC staff assessment as to the extent and significance of problems resulting from materials having been purchased from unqualified vendors.
Response
j Quality Confirmation Program (QCP) Task I, " Structural Steel " and Task III, " Heat Number Traceability," include the review of material purchases concerning structural steel and ASME piping systems.
These tasks will be expanded to include the review of purchases from unapproved vendors in other areas.
i
The Honorable Morris K. Udall A problem \\' as been identified within, the above,QCP ta by a separ te H. J. Kaiser document review group related to non-essential m erial purchased from unapproved vendors being upgraded to essential aterial without appropriate documentation. The licensee has determine that all material presently being installed has been purchased from alified vendors.
The NRC staff has ot yet made an assessment of the findings of the review of material urchases from unqualified vendors. The staff
~
will make such an as essment after the licensee completes his review of the matter.
The potential impact o the material purchases is that installed materials may have to be replaced. A quantitative determination as to the amount of such aterial will be made by the staff after completion of licensee rev'ew efforts.
5.
Information Requested The NRC staff assessment of the findings that have emerged from the review of Nonconformance Reports.
Response
Quality Confirmation Program (QCP) Tas VII, "Nonconformances," is approximately 61% complete.
Voided Nonconformances (NRs)
A large number of problems have been identi with approximately 400 of the 1031 vnided NRs reviewed to date. T a proximately 400 voided NRs will require sdditional investigation to esolve questions as to acceptability of conditions. The investigation efforts are in progress.
Completed Nonconformances The licensee's review of 290 of a random sample of 300 NRs has revealed problems tith 10 NRs and may result in the reopening of those 10 previous lv closed NRs.
Punchlist The licensee's review of the "nunchlist" revealed approximately 100 items which ray be issued as NRs.
]
The licensee activities are being monitored by the NRC. An assessment by the NRC staff of the findings has not yet been made. The staff will make such an assessment after completion of QCP Task VII.
j I
y-e The Honorable orris K. Udall ;
i I hope this info tion is responsive to your r uest. Additional details of the Quality Conf nnation Program results ar contained in the licensee's May 30, 1982, status report which we provide to Dr. Henry Meyers of your staff on June 16, 198.
If you have furth questions on this matter,
~
please do not hesitate to contact me.
- ncerely, Nunzio J. Palladino Chairman Distribution:
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June 14, 1982
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The Honorable Nunzio Palladino Chairman Untted States Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Chairman:
The Subcommittee's June 10 hearing, Quality Assurance at the Zimmer Nuclear Station, addressed the status of the Cincinnati Gas & Electric (CG&E) Quality Confirmation Program (OCP).
NRC staff stated that as of May 1, 1982, the OCP was "55% complete with an anticipated completion [date) of December 31, 1982."
NRC witnesses, however, did not present detailed information concerning the QCP findings to date.
Accordingly, I would appreciate your directing the staf f to provide the Subcommit tee the following information.
The number of structural steel welds inspected to date, the number of structural steel welds known not to conform to the Commission's requirements, and the current estimate of the quantity and 1
quality of work necessary to bring these welds into conformance with requirements.
A quantitative statement concerning findings regarding the traceability of piping and the implications of such findings, The NRC staff assessment of the findings of the review of welder qualification records and the i
implications of such findings.
The NRC staf f assessment as to the extent and significance of problems resulting f rom materials having been purchased from unqualified vendors.
The NRC staff assessment of the findings that have emerged from the review of Nonconformance Reports.
Thank you for your assistance.
Q(p DD s
MORRIS K.
UDALL B206mOOgy Chairmar
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July 15,1982 CHAIRMAN
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6 The Honorable Morris K. Udall Chairman, Subcommittee on Energy
'and the Environment Committee on Interior and Insular Affairs United States House of Representatives k'ashington, D.C.
20515
Dear Mr. Chairman:
As you requested in your June 14 and July 12, 1982 letters, the information relating to the Zimmer Quality Confirmation Program is enclosed. This infor-mation is current as of May 30, 1982.
I hope this information is responsive to your request.
Additional details of the Quality Confirmation Program results are contained in the licensee's May 30, 1982 status report which we provided to Dr. Henry Myers of your staff on June 16, 1982.
If you have further questions on this matter, please do not hesitate to contact me.
Sincerely,
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Nunzio J.
alladino
Enclosure:
As Stated cc: Rep. Manuel Lujan f
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