ML20087N609
| ML20087N609 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 02/22/1984 |
| From: | Mullinax T DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20087N559 | List: |
| References | |
| FOIA-84-48 NUDOCS 8404040079 | |
| Download: ML20087N609 (141) | |
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UNITED STATES OF AMERICA "' 7 NUCLEAR REGULATORY COMMISSION '
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-ce i ' BEFORI'THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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DUKE POWER COMPANY, et al. ) Docket Nos. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
TESTIMONY OF THOMAS H. MULLINAX CONCERNING MR. LANGLEY'S ALLEGATIONS PERTAINING TO ALLEGED HARRASSMENT OF WELDING INSPECTORS 1 Q. STATE YOUR NAME AND BUSINESS ADDRESS.
2 A. Thomas H. Mullinax, Duke Power Company, Catawba Nuclear 3 Station, P.O. Box 223, Clover, South Carolina, 29710. ,
4
$ Q. STATE YOUR PRESENT JOB POSITION WITH DUKE POWER 6 COMPANY AND DESCRIBE THE NATURE OF YOUR JOB.
7 A. I am a Steelworker Foreman. I supervise a crew of 14 - 20 men 8 involved in erecting structural steel, fabrication and installing 9 miscellaneous steel, and rigging and setting equipment. This work 10 includes erecting and fitting containment shell plate.
11 i
12 Q. WHAT OTHER JOBS HAVE YOU HELD WITH DUKE POWER?
13 A. I started working for Duke Power in 1956 as a steelworker. I left 14 the Company in 1968 for four years and returned in 1972 as a 15 steelworker. I became a foreman in 1973, 16
} 17 Q. ARE'YOU FAMILIAR WITH THE ALLEGATIONS OF MR. -LANGLEY 18 THAT HE AND ANOTHER INSPECTOR WERE INTIMIDATED BY THE
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j 19 CRAFT FOREMAN WORKING ON THE PERSONNEL AIR LOCKS?
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_ aH any im*5ent that a Mr. Langley was involved in.
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.,qftQk 2 M8r s%e- CinWlved in an incident with Lindsay Harris, another welding
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4 5 Q. DESCRIBE THE INCIDENT WITH LINDSAY HARRIS.
6 A. The men under my supervision engaged in fitting-up the personnel 7 air lock to the containment shell plate came to me and infonned me 8 that an NCI was going to be written on the work, they were 9 performing. I asked why, and to the best of my knowledge the 10 men informed me that the inspector (Lindsay Harris) said that they 11 had welded on the plate without preheating it. My crew claimed 12 that they had preheated it; had told the inspector they ha'd 13 preheated; that the inspector had called them a liar; they were not 14 going to take that and would knock his teeth down his throat if he 15 did it again, or worris to that effect.
16 17 I talked with Lindsay Harris, and to the best of my recollection, 18 he told me that the men had welded without preheating and that the 19 men had called him a liar first. Lindsay and I argued about the 20 incident. I cannot recall what was said during the argument, but 21 I believe it centered on who was right and who' was wrong about 22 whether the preheat had been made. The inspector and I agreed to i
23 go see each of our supervisors. We were walking to the offices 2'4 when I conveyed 'o Lindsay the feelings of the men about being 25 called a liar and told him, as best as I can recall, that if l 26 he continued to call the men liars that he would get his teeth 27 knocked in. We continued to our respective supervisors' offices, l
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1 and I infomed my supervisor, Mr. W. K. Henry, of the incident" , -
lJ 2 and ;rielated to him what had taken place. Mr. Henry and I went -
'l 3 to the job superintendent's office and and to the best of my '
4 recollection, informed Mr. Ralph Morrison cf the events up to 5 that point.
6 7 As best se I can recall, we were told to come back the first thing 8 next morning due to the lateness of the hour. As best as I can 9 recall, Mr. Henry and I and one or both of the. crew members 5' 10 involved went to the superintendent's office the next morning to 11 discuss the incident. We related what had happened to the people 12 at the meeting, but I don't recall who was there. As best as 7 13 can recall the incident was discussed but I can't recall exactly 14 what was said.
15 16 I belle.ve it was the next day, I can't recall exactly, that I was 17 called to Mr. Cecil Wall's office. He was the Job Superintendent.
18 I was asked by him what had happened and I told him I can't 19 recall whether Mr. Henry was wit 51 me at that meeting or not, but 20 Mr . S. O. Shelby, the Steelworker craft superintendent, was on 21 vacation. Mr. Wall had Mr. Shelby called to come in from vacation.
22 Mr. Wall, Mr. Shelby , and I met, but I can't recall who else was 23 there at the meeting. I don't recall exactly what Mr. Wall and 24 Mr.' Shelby said to me, but the message I got from the meeting wa::
25 that is was a very serious matter to attempt to intimidate or to 26 threaten an inspector and that such things would not be tolerated.
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G l' I told Mr. Wall that I was not threatening or trying to inthaidate c tan 2 im /.lC t$eJinspector but was advising him of the way some of my men felt
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. 3 about- being called a liar. I informed my men that any questions 4 arising during the course of an inspection were to be brouglit to i
5 me immediately and that there should be no arguing by the 6 craftsmen with the inspectors. I don't recall exactly when, but 7 later I informed the crew that arguments with inspectors were to ;
8 be avoided; that no threats or intimidation would be tolerated, 9 that all questions should be brought to me. I do not remember i
10 whether I talked to the two craftsmen separately or with the 11 whole crew, but this message was give to them.
12 13 Q. WHAT INSTRUCTIONS HAVE YOU BEEN GIVEN CONCERNING THE 14 CRAFT'S RELATIONSHIP WITH INSPECTORS?
15 A. I have been instructed on numerous occasions that there was to be ;
16 no arguing with the inspectors. That any threats or intimidations 17 would be considered very serious and dealt with accordingly. That 18 any questions arising that could not be solved without arguing were 19 to be taken to higher management to be resolved.
20 21 I have been instructed to maintain an attitude of cooperation with 22 the inspectors as well as the other Crafts. I have been instructed 23 to work with and assist inspectors in performing their duties and 24 to perform rdwork if necessary to bring the work into compliance 25 with the inspection requirements.
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1 ,Q . , HAY %-M SAME INSTRUCTIONS BEEN GIVEN TO YOUR CREW 7
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instructions have been given to the crew members.
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l U. S. DEPT. OF LABOR .'
WAGE-HOUR DMSION FEDERAL BUllDING ROOM 1072 p w ee 76 w s1 1835 ASSEMBLY STREET COLUMMA, S.C. 29201 l l l
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ur. Neuend s. Numa, Jr.
c/o No. 31111e Garde Government Aseessatability project lastitute for Policy Studies 1901 Qus Street, M. W.
Washington, BC 20009 subjest: Neuerd S. Nues, Jr. vs. Duke Feuer Compeer Bear Mr. Numme his letter is to antify you of the results of our complianos actions in the above case. A previous letter from this afflee advised yee y ;
that your complaint was received on November 22, 1983, and enslosed ,. ..,,, ,
a copy of Regulatieas, 29 CFR Part 24 and a copy of the pertimaat .5 of the Energy Reorganisation Act. g *j l our initial efforts to conciliate the matter revealed that the parthd s would not at that time reacia a mutually agreeable settlement. Aa
,, investigation was then conducted. Our lavestigation did not verify d that discrimination was a factor in the actions comprising your semplaint.
j Conversely, it is our conclusion that your allegations are unprovable j for the following reasons:
I he investigation disclosed that you were terminated by Duke Feuer Company for excessive absenteeism. The basic company policy specifies a limit of 17 occurrences over a period of 12 consecutive months.
The records show you had 18 occurrences during the period from 11/10/82 to 10/14/43. In addition, our investigation did not substantiate that you were in any way, harassed er intimidated by your supervisor or the company.
- 1 p his letter will motify you that if yee wish to appeal the above findings you have a, rt$t to-a formal hearing en the record. To exercise this
. ri$g yee'ausg6 withis five (S) calendar days of receipt of this letter, l
]; file year sept.Ser a hearing by teleares to i; ^ ~ Se Chief Waistrative Law Judge p U. S. Department of Labor
- I Suite 700, Vanguard Building
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j Washington, DC 20036
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hises a telegsam seguess is rese13ed by the mist W=letsetive Law l day poeted, this meties of w h ae== will of the Seeretary of Labor diamissing your this letter I an advistas Behe Pomer Company of this sees and the right to a hearing. A sepy of boom samt to the mist histrative Law ist. If you decide to regnest a hearing it will be ===mamany to send espise of the telegros to Bohe Power Campany and l to en og g. 8. Bsportment of Labor. Ungs user Divisin,1835 Assembly Street Federal Desidies, Rasm 1972. Colnehta, SC 29301: AC.803/765-S981.
After I reestve the sepy of your regenst, appropriate proposetiens for the hearing saa he made. If yee have any questless de met hesitate to
- sall me.
l It should be made clear to all parties that the role of the Departeset of Labor is not te represent the parties la any hearig. Se Department emeld be mostral in soth a heerlag which is staply part of the fast. .
develepasst process, and only alleue the parties an opportunity to t presamt evidence for the record. If there is a hearing, am Order of I the secretary shall he bened spee the record made at said hearing, and ,
shall either provide appropriate relief er deny the complaint. -;,
I Jerry L. Stuckey Area Director cc Mr. Warren Owen Vice President for Cesstruction & Engineering Duke Feuer Company P.O. Box 33189 Charlotte, NC 28242 uclear Regulatory Cammission
, 101 Marietta Street, Suite 3100 Atlanta, CA 30303 The Chief Administrative Law Judge U. S. Department of Labor Suitq;%W'-@
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, Penelty for Private Use. $300 Nuclear Regulatory Coannission 101 Marietta Street, Suite 3100 Atlanta, GA 30303 1
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Number Copies Received ROUTING ADDRESSEE INITIALS DATE COPMENTS
/ REGIONAL ADMINISTRATOR /VM Secy. to Regional A hinistrator DEPUTY REGIONAL ADMINISTRATOR Secy. to Deputy Reg. A &inistrator n ASST. TO THE REGIONAL ADMINISTRATOR ,
(( M ) REGIONAL COUNSEL M."
'3-DIRECTOR, PRP DIRECTOR. E0P !
DIRECTOR EPMSP DIRECTOR, RMA e DIRECTOR, PROGRAM SUPPORT STAFF - -
DIRECTOR, PUBLIC AFFAIRS STAFF DIRECTOR, STATE & GOVT. AFFAIRS STAFF ,
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! l COLLATERAL ASSIGNMENTS l EED COUNSELOR EMERGENCY PLANNING COORDINATOR EMPLOYEE DEVELOPMENT SPECIALIST FEDERAL WOMEN'S PROG. COORDINATOR HEALTH & SAFETY OFFICER NTED VICE-PRESIDENT l l SECURITY OFFICER l FINAL DISPOSITION:
Form RII-A-18 0i b l2'D D'~'d 2
. . ., U. S. DEPT. 0F V3OR WAGE-HOUR DIVISION FEDERAL BUILDING ROOM 1072Phone: 765-5981 1835 ASSEMBLY STREF, C01;UM,8,13,,S.g. 29201
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November 22, 1983 Mr. Howard S. Nunn, Jr.
c/o Ms. Billie Carde Covernment Accountability Project Institute for Policy Studies 1901 Que Street, N. W.
Washington, DC 20009
Dear Mr. Nunn:
This will acknowledge receipt of your complaint against Duke Power Co.
alleging violations of the Atomic Energy Act (Ene rgy Reorganisation Act) 42 U.S.C. 5851. Your complaint was received in this office on November 22, 1983.
The Act requires the Secretary of Labor to notify the person named in the complaint of its filing and to conduct an lavestigation into the alleged violations. Consequently, we are providing Duka Power Co. with a copy of your complaint and advising of the Wage and Hour Divisica's responsibilities under this law. We have enclosed a copy of the pertinent section of the Act, and a copy of Regulations, 29 CFR Part 24 for your information.
This case has been assigned to Compliance Officer Carol Merchant '
whose first action will be to try and achieve a mutually agreeable settlement through conciliation. If this is not attainable as in.
vestigation will be conducted as soon as possible. If you have further evidence, please give it to our representative wbe will contact you
. on this matter. If you have any questfees do not hesitate to call me or our representative at~ (403) 765-5981.
Jerry I.'Stuchay Area Director Inclosure fcNuclear Regulatory Commission 101 Marietta Street, suite 3100 .
Atlanta, GA 30303 -
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WAGE HOUR DMSION i FEDERAL BUILDING ROOMPhones 1072 765-5981 1835 ASSEMBLY STREET COLUMBIA, S.C. 29201 November 22, 1983 Mr. Warrea Owen Vice President for Construction & Engineering Duke Power Company i P.O. Box 33189. '
Charlotte, NC 28242 Dear Mr. Owen This will notify you that the Wege and Hour Division of the U. S. i Department of Labor has received a complaint from Mr. Howard 5. Nunn, Jr.
alleging discriminatory employment practices la violation of the Atomic Energy Act (Energy Reorganisation Act) 42 U.S.C. 5851. This charge was received by our office om November 22, 1983. We have enclosed a copy of the comp 1sist, a copy of Regulations, 29 CFR '
Part 24. and a copy of the pertinent section of the Act.
The Act requires the Secretary of Labor to conduct an investigation into the violations alleged. This case has been assigned to Compliance Officer Carol Merchant whose first action will be to try and achieve a mutually agreeable settlement through conciliation. If this is not attainable, the law requires that an investigation be conducted as soon as possible. You are encouraged, and will be given every opportunity, to present any relevant information or evidence to our representative.
Thank you for your cooperation in this matter.
Jerry L. Stuckey Area Director Enclosures c
Nuclear Regulatory Commission 101 Marietta Street, Suite 3100
- Atlanta, GA 30303 l
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. i November 18, 1983 OV 4k b y The Honorable Raymond Donovan ,y ' kfNygrg }j l Secretary of Labor l4 NOV 22 8g3 U.S. Department of Labor :)) eg ,,,, Z Washington, D.C. i va gfg4 m N' t~ Colung g Attention: Wage and Hour Division s IS t
Dear Secretary Donovan:
Pursuant to the Atomic Energy Act as amended, 4 2 U.S.C.
g 5851, and 29 C.F.R. Part 24, I hereby file this comp- ,
laint with the Secretary of Labor. I allege that on
- - < - '- October 20, s1983 I was discriminated against by my termi- -
nation, and prior to that by the restrictions, conditions and terms of my* employment as a welder for _ Duke Power Comoany (Duke) on the Catawba Nuclear Power Plant under construction in Clover, South Carolina.
On October 20, 1983 I was informed that I had been teraninated.
Five days previous, on October 14, 1983 I was informad that I was being suspended pending an "in house" investigation of my allegations of harassment and intimidation by my supervisors and by the Duke Power Company Employee Relations Depa r tmen t, and a review of safety and hardware concerns I had been raising for some time. Specifically I allege that my termination on October 20, 19 83 was a direct result of my exposing my concerns to the Nuclear Regulatory Commission on October 14, 1983, and that my suspension initiated on the same day resulted from my rejection of the Employee Relations Department's institutionalized violation of my rights. I was informed that I was being terminated for violating Duke's attendance policy.
These acts of discrimination were in retaliation for my dis-closures to my foremen, general foremen, and on one occaision to the site ANI inspector about laminations in the vendor conponents used in the reactor containment vessel, and the lack of adeguate correction procedures to correct the problem; I also dissented against:
- 1. the use of " bad" TIG wire and welding rods which the welders were reg'uired to use to weld and do correction work,
- 2. the authority of construction foremen to " override" workers who were attempting to f.ollow NRC approved construction procedures, and
- 3. other incidents and examples I have disclosed to the Nuclear Regulatory Commission (NRC).
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- Th3 H:no~rablo R ycond Donovcn Novemb2r 18, 1983
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Pursuant to the provisions cited on page o,. ne~..of this
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letter I request both compensatory and punitive damages. Specifically, I seek reinstatement to my former position as a top paid welder for Duke Power Company with commensurate duties and responsibilities; the removal from my work record of all negative comments resulting from my dissent; a removal from my personnel record of all absences incurred as a result of the harassment and intimidation, and back pay and benefits from the time of my dismissal and for any time missed as a result of this incident.
Fin ally, I am concerned that I may suffer- additional- -
. . .. retaliation, through,.the. doctoring. of. my personneln . .v
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. records which I have requested but not received from.
Duke, as a result from filing this complaint to the Department of Labor. I reserve the right to add items to this complaint as I become aware of them. .
Out of concern for my safety and the safety of my family I have not included my address and phone number and request that I be contacted through Ms. Billie Garde of the Government Accountability Project of the Institute for Policy Studies, at 1901 Que Street, N.W., Washington,D.C.
20009, phone number (202) 234-9382.
I look forward to your immediate response.
Sincerely, .
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x HOWARD S. NUN'N , JR.
cc: GAP /IPS NRC, RII l
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, I . S. N'.'Ot U r: ;I:'.'u,7cy .-~ ~esiog OFFICE .7 ILTUC F';:?
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g Fr::c'< u rt c. 4 13C 'rHE CHARIDITE OBSERVER Thursday, November 10,1 .,
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V "Do you question the~ safety of Catawba 7" McGarry asked _Cau-then, seated in the jury box at the i Orde"re"'
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federalcourtroomin Rock Hill:
Cauthen paused, then said: "I can wonder and speculate, but eld In's' pe' ct*ons i what I welded and checked, I'm -
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M q'=,a Under Citawba Plant Gund, ey for e mne.tu.
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By JACE HORAN
-c power Palmetto Alliance.
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- =s wrew- uthen recounted lastances of ROCK HILL - A Duke Power what he termed harassment from Co. welding laspector testified fellow inspectors for finding de- i Wednesday his boases told him he fects in welds they had inspected. I was overinspecting and ordered "I had reason to believe .they him to " stack up" reinspection of didn't do a good job " Cavthen welds at the Catawba nuclear .The . -"a Am.aWchal-
/ j power plant.
lenging the licensing of Catawl)a, Boyce Cauthen, th4 fifth of a l l
poestole 31 inspectors subpoenaed 19 miles southwest of downtown '
to testify in the federal licensing Charlotte in York County, S.C., i hearings, told a Nuclear Regula- primarily on the grounds the plant I tory Commission (NRC) p may contain faulty workmanship t his job to conduc and may not be safe to operate, I in- Two years ago, Cauthen and s == of ninina ems la the uncompleted nuclear plant.
other welding inspectors com-plained to top Duke management Panel member Paul Purdom that middle managers often over-
- asked Cauthen how he understood rode the inspectors' citations, the meaning of '" slack up" -In-structions, which Cauthen said pressured them to approve faulty
.were relayed to him by supervisor work and didn't support them in disputes with construction crews.
G.E. " Beau" Ross.
"They said it meant to look for
- Duke concedes its investiga-tions found procedural violations construction damage (to the and poor communications but no pipes),".Cauthen replied, and not faulty welds, to reinspect welds that had al-ready been checked by other in- After Cauthen's testimony, the three member panel met in a sec-spectors.
Then, Duke lawyer Mike Mc. ond secret session with an uniden.
Garry, trying ta show such in- tified present or former Catawba structions had no significance on worker, who took up the panel's I safety, asked Cauthen whether he invitation to convey safety related concerns in private.
approved any faulty welding
, work as a consequence.
Cauthen, a former welder, an-swered that ha didn't. He also clarified a stetement in written testimony submitted earlier that none of the welds he checked were defective. His original state-ment said "I don't know if the p,lant is constructed safely." -
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.a 1 CatawbaInspectorSays' Welds S ,
By JACK HORAN attorney f/r the anti. nucle'a r dized." .
,. sme w eer RC Inspectors would visit "the power Palmetto Alilance, Rock , Panel Chairman James Kel 4 +'
i plant. a charge leveled last month '
O ROCK HILL '- A six year vet- nott conceded he could only say asked Rockholt how
's eran frequ tly by a former Catawba work weldlas laspector at the Cao. with authority that the welds he Duke supervisors verbally ver- Yes, Rockholt replied. "You'd a -fled tawba nuclear Tuesdayilt waspower vigliande plant testi-a checked were safe and couldn't rode. Inspectors
- deficiency Ita- just hear the NRC by speak g } , the welding laspectors that. en-. In other t whether flaws exist tions. "Should l worry about at? here in force " he said.
5 j of the uncompleted Is that a big deal or a small dea ."
, "'.. sured agalast faulty welds in the. Plant.' In an interview, NRC official y Rockholt said the total of 30 3 F face of a' deteriorating.
A controlprogramia 1981. '- quggity ,' Tlie Palnietto Alliance Is at- deficiency citations that were a ack Bryant swd some inspections 3 tem g,la part through the tes- volded, a fraction of those ap- that rearranged with the utility
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,h, . . "There was a possibility.... thnony of as many as 31 Duke proved, dida t bear on . plant 95%
clear pla are unannounceo. nt. "(B 1
.;, there could have been prot #ms," laspectors, to show there was.a safMy. uns is a 1
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John PMWt. told a breakdown in the quality-control h' strict thing " he said.
gn p e n to bre k ' 3 The NRC panel planned to meet
,. .- I (MRC)'l$ censing pane Bu e, $ do Duke i dQ I",gj th
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.h > t$at, believe t9 work rs or or r I, p(doourjob. Yaulyw manshipln he proper for supervisors to overrule ' workers who wanted to relay
- g Catawbaprill be safe." '. , . ' h. billion plant 19 miles south- the inspectors.
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- safeWelaW concerns aW W W ..:Rocisholt, the fourth ~ laspector ,. or downtown Charlotte. Then panel member Paul Pur- plant in confidence. Kelley would g( .
{;,to testify as the Econsing hearings- Rockholt said unless the weld- dom asked Rockholt whether only say the panel would meet
. hagan their sixth week, sakt he lag laspectors had failed to bring workers knew in advance when with them this week.
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- 3.engsted set his duties despite low ' procedural violations to'the atten-is or.ie and s.oke out despite the tion of top Duke management, I
, h i h threat of. retaliation from: his Duke "the situation possibly could have
- PWeer Co. bosses. i
/.1,9st under questioning from an deteriorated to the point where safety could have been jeopar-a l3 i 's .
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DO NOT DISCLOSE Contains identity of Confidential Source
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, AFFIDAVIT My name is Howard Samuel Nunn, Jr. I am making this statement freely and without threat or promise of material reward to Billie Gards and Emily Ansell, who have identified themselves to me, respectively, as Director of the Citizens Clinic and investigato with the Government Accountability Project, and to Phil .uttli "
who has identified himself to me as assisting the Government Accountability Project,niY. Si;; i; iter; ice.
I am making this statement because I am concerned about the quality of the Catawba Nuclear Power Station being built in Clover, South Carolina. I believe that as 4 result of my being a conscien .
tious employee at the plant Duke Power Company (DPC or Duke) waged a campaign to get rid of me. This campaign negatively affected my economic future, my health and wellbeing, and my family relation-ships.
In 1961 I graduated from Hanes High School in Winston-Salem, After that, I attended college for one year. In North Carolina.
addition to this, in the spring of 1978 I received certification as a welder from the dFroehling any cdon
~ and Robertson cAe<\ u.eMin3,Testing pWie. etLaboratoryk pipa any u ue.'in pt i2;c ucrh pipe ucrh, c2d en eteel = 9 ,
This certified me to ww un;kd 6kk.s %cA tw.efg do@d %h c.e<4d,h4 ion. dy and plate cciding in :__ peritirn:. g4, s
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I worked as a welder for Duke Power Company at the Catawba plant from November 1980 until October 20, 1983, when I was fired ,
for, I believe, being a conscientious employee who raised concerns over the quality of the plant. Prior to my job at Catawba I worked i
for Duke frcxn September 1978 to November 1980, as a welder at their ,
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. i McGuire Nuclear Plant on Lake Norman in North Carolina. Before that, from 1976 to September 1978,I worked ~as a welder, doing bridge and highway work, for Crowder Construction in Charlotte, N.C. At Crowder I worked myself up to a position of responsibility, where I was frequently called upon to be a troubleshooter. Although I had j
! to do a lot of travelling for the company, I enjoyed my work and the trust they had in me.
I From 1974-1976 I worked for the Blythe Bros., construction I
contractors, Charlotte, North Carolina, as a field service welder doing bridge work and hi hway work. Before that, from sunnier 1973 M d4ADa welder with Dresser Engineering in to about January '.777,$I 'was i
Charlotte, North Carolina. I also worked as a barge welder, for about one year - from 1972 to 1973, for Paducah Marine Ways in Paducah, Kentucky.
Before becoming a welder I played saxaphone in a band that travelled throughout the United States. This was during the period of 1965 to March 1972. In early 1973 my father had a stroke and .I decided to leave my band and return home. For a short time between welding jobs, I went back to playing with the band, approximately between March 1973 and August 1973.
I was hired by Duke in September 1978. In order for me to be 5300' a welder at McGuire I had to pass a certification test, the %'W procedure",which I passed the first time I took it. I was there-af ter a low paid welder, working in the Auxiliary -Building at the
- 750 elevation. My job duties included helping TIG welders by finishing up their welds with stick rod. On my cwn time, I i
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A practiced doing TIG work. At the end of my first 90 days at McGuire my foreman, C. E. Allison, told me that I was an exceptional welder.
After seven months I became a middle-pay welder, and another seven months later I became a top-pay welder.
While at Duke I became certified in numerous welding procedures, all of which added to my qualifications as a welder.
Af ter a year of welding on hangers and some piping in the Auxiliary Building at McGuire I was very satisfied with my job. My foreman, C. E. Allison, was also well satisfied with me. In fact,
! Mr. Allison beg pp count on three of us in our crew to work over-AEeY C' Soce iM.h\fr '
time: Dick -Aese ' " Junior" Johnson, 'and me. 4teet of the overtime work and weekend work was high-priority safety work. For example, "6umphone.5 "
there were recessed areasA i n the floors that contained enormous amounts of piping which required that the welding work be done in close quarters and in extremely difficult positions. This_ work'was often done on weekends by the three of us because of its difficulty.
e.u,tnetr MgM In about C;pt- ' r 1980 Duke Mgan to ask for volunteers to go OR\4- @ i.spfY to Catawba. In irt: C;;;te. :: :nr'-; November 1980 I transferred to Catawba,-but I was sad to leave Mc Guire. At McGuire, I had a tremendous foreman, with whom I had a good working relationship; I had a good reputation there; also, I had heard a lot of things about Catawba that I did not particularly like such as no adequate rest room facilitics and no canteen to provide cokes or coffee. I was
! even more concerned about_ the comments I heard about the Catawba l \
management. Going to Catawba was considered by many workers as being sentenced to Siberia, but jobs were hard to find -- so I went.
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I had some expectations of what my job was going to be like at Catawba. The week before we were supposed to go down there Bill
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Rogers, who was welding superintendent of Catawba, came to McGuire and was going to meet with the welders who were going down to Catawba. He was going to tell us if there was any difference be-tween the welding operation at McGuire and the one at Catawba and what we could anticipate. If we could not make that meeting we could send a designee to that meeting for us. Unfortunately, my ex-wife had me in court on that day for increased child support.
I asked my foreman to go to that meeting for me. He asked Bill ,
Rogers if there were any openings in' the pipe fabrication (" f ab")
shop. Because I'm a large person it is hard for me to get into some of the tight places that welders have to get into. My foreman realized that I could do good x-ray quality work, and he thought it would be advantageous to everybody if I was put in the pipe fab shop where I could be out in the open and get to the pieces I was work-ing on with relative ease. I was able to do the good, high quality work that was needed in that area.
Mr. Rogers promised my foreman that that was where I would be put when I arrived at Catawba. Naturally, when I went down to Catawba in November 1980, I had every expectation of being put to work in the pipe fab shop. That did not turn out to be the case.
y Instead, I was assigned to Larry Rudasill's crew (Bobby Hoyle was-k o the foreman when I arrived) . I knew that the pipe fab foreman was
'Depcon
'WWUUn Jones and I asked the woman in the office if there had been a mistake, but she told me there had been no mistake.
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Larry Rudasill's crew's primary work area was the refueling canal and the annulus in Reactor Building Number 2. I was first
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assigned to work in the bottom of the refueling canal in close proximity to the reactor putting stainless steel liner plates onto the angle iron embedded in the concrete wall. This was safety-related work; all of the metals had to have non-destructive tests PT)doneonthem. ,
4 4' I could not believe management's attitude toward workers at h
Catawba. Whereas at McGuire if there was a problem with a work assignment you went to your foreman and talked about it, as reason-able people, at Catawba it was much different. For example, because' I was expecting the pipe fab job and got a different assignment, I asked for a meeting to iscuss it. About two weeks after I arrived at Catawba Bobby :% _ foreman, Billy Smith, my general foreman, and I finally had the meeting I requested. I just wanted to clear the air and find out why I was being placed where I was, rather than in the pipe fab shop.
Billy Smith commenced to tell me first off "I would work where I was assigned to work and if I didn't like that I could hit the road."
He pulled out my calendar from McGuire and then said that I had an awful attendance record for the previous year, that I had been out 19 times. I told him that was ridiculous, that there was no way I had been out y 19 times. He pointed to my attendance on the calen-epto6mench dar. There wer 12 Fridays that were marked that I was out. I was astounded by Mr. Smith's naivete. Those days were "early outs!" It wasnormalpolicythatifaworkerwasgoingtoworkSatur
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l Sunday, he could get off early on Friday, around 3:00 or 3:30 to .
get his check cashed. That way he was clear to come in on Saturday
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and Sunday. That's what happen n a dozen of those nineteen
, d m m q % is peged absences. The other absences - :: r _ t-: j_11 r..i J -- were either illness or court dates resolving conflicts with my ex-wife.
I tried to explain that this was normal practice, called an "early out." My foreman at McGuire was told by the Duke personnel depart-ment that if a man,did not work a full day just to shade it in, light blue. But it was not anything detrimental to a worker, and in my case he would find that I ha yorked from eight to ten or' onl twelve hours on the Saturdays /or u days af ter the "early out." , W I attempted to clarify this 4 '01 ith Oil-. I told them about k,
ad and or ak b coming to work on Saturdays Sundays and that I was one of three A
people on my crew who did this. I told them that if they did not believe me to just call my foreman at McGuire and he would verify that what I was saying was true. Billy Smith responded by telling me that it was not the way they did things at Catawba; that any part of the day that you do not work goes against your record. I terminated the meeting pretty quickly when I saw that I was not going to get anywhere with them.
I went back to wcrk in the refueling canal. For approximately f three months I"Tigged'the plates on the containment wall. ,
l Larry Rudasill took the crew over from Bobby Hoyle soon af ter I started. He found out that I was efficient in making repairs i
and soon I was doing nothing but making repairs.
As soon as I became a repairman I identified a serious problem l l
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with laminated metal used for piping on the containment wall in the Unit J Reactor.
The containment wall is, to the best of my i knowledge, three-quarters of an inch thick and it runs ntheree ti g t.
height of the building and across it. g It is put in in sections ' jy and solidly welded and installed. ;
All this work was done prior ;
to my getting there.
These sections are formed together to make a big barrel; this is the containment.
There are holes cut at specific places and there are st@s of pipe that are already weld e d in there. These are vendor welds.
) I was told that these were done by another company who supplied the steel.
It was to these that ye welded bellows to allow the wall to expand under pressure .
We had one weld on the second course. It was on the NI system.
I do not know how long it had been welded prior to my e gngttithere, but it had x-rayed as a bad weld several times Shortly after my assignment there, a fitter was down there working with a torch . He was cutting the bellows off the stub of pipe that came throughe th wall in order to do some repair.
I was aware at that time that they wanted to do something different than usual in fix ing it.
, The bellows had x-rayed as bad so many times that they decid e , I guess, d
to just cut it off the wall and try again. I was doing repairs in
! the various parts of the annulus when they prepped the surface up again to put the bellows back on, This was on the NI system and, to the best of my knowle'dge, it was 24-inch diameter pip e. This was one of the first times I became aware of a lamination problem in the steel stubs of piping there.,
I believe the weld was either 2NI-16-2 or 2NI-16-22.
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I also noticed problems with. the stiffeners on the wall. I asked some of the people down there why on these stiffeners that went around the containment wall had places been ground out so deeply beside the welds or ground as if they were removing some sort of defect. I was told that there were literally not inches but feet of lamination thatad been found in the metal itself.
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ocebe. MSM fr-/4 ff A lamination 4s- an extremely dangerous flaw. It had been explained to me, by several people more knowledgeable than I am, how steel factories work; that in order to make sheet steel, molten metal goes through a press and is heated and pressurized, then it is rolled through again. Sometimes in the rolling process some of this steel bunches up and it starts rolling back under and it actually does not fuse. It is red hot but it does not fuse with the other steel. So, there are layers of steel, like layers of formica. The area that is not fused together is called a lami-nation. Several people down there told me that several places on the containment wall had been ground and rewelded, and ground and rewelded, in order to take care of laminations. f
. The a procedure that Duke Power had, called CP-88. CP- --
induhewda4y\t?, 88 211cu;d- dorkers to grind three-eights of an inch deep into a 4l g ) N lamination when it was found. Once the welder achieved the proper 6uppc6eA4e b. %54' d- I d 3 [ l
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. geometry, 4.. -el.1 cleen it , 2 it wasgsigned off by a QC ,
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i inspector. The he could fill this back up er _IC n ;tel-Nk $ w, the,s d ece(t h e.hj DAW.a.MC, m 4 m pechen b g 4 c- en grind it inch Off,gthen 4e an NDE test .en-- l ca :S. tea 1 s M bOC ) ko r'M oe. b pcN , I became a little bit suspicious that perhaps this stub of
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_g. metal that had baan vendor welded in was perhaps just a rotten piece
%5 of steel and had too many 1- ' rti_
$in it. I asked some of the fellows who had worked on that pipe before, and who had repaired it before, what type of dei cts had shown up and they had all been similar linear defects.V On the r ::a th r: ;;;12 i; ; a;12 ...i.3 l l
c '-- 1;h t 2n d i t x:21 f 515; ; 11..e tir-~;' To me that would indicate, perhaps, a lamination. I did not believe that so many welders could have welded badly for that long. So, rather than the normal magnetic particle test, I suggested to Mr. Rudasill that maybe we could get a penetrant dye
. ~ l test done on it. I knew that if it did not " shoot good" the nexu ;
time,. the repair was going to come back on me since I was the re-pairman. For the penetrant test the steel is cleaned off and dy.e put on for a certain amount of time. Then it is cleaned off again, the dye si ts , and then a developer is put on it. If there is the slight-est crack, even a ten thousandth of an inch, it will start bleeding . through and red lines will appear. That will indicate that there is something wrong with the metal. Mr. Rudasill agreed that even though this was carbon steel, and magnetic tests were normally done on carbon steel, perhaps the penetrant test would be the best way to go on this pipe. I was working down in about the same area when the PT tester, MTT) named Ke1tl, came down to do the penetrant test on this new surface. It had been bevelled at a 37.5 degree angle and it looked good to the naked eye. l
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l This first test showed up, if I am not mistaken, with 30-some ; laminations in this piece of pipe. That would be roughly six feet '
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in length and the prepped prface would be about two inches wide. Some were as long as an inch an inch and a half and some were as short as one-eighth of an inch. Unfortunately, my theory had come true. It was, in f act, just a rotten piece of pipe. Were it my plant, I would have taken that piece of ipe out of there.
+.4 CP-88 was the procedure I was rig; ___ o use to try to fix those laminations. However, CP-88 had nothing to do with the stubs of pipe that were welded in the containment wall. CP-88 was only
- for the metal that the containment waill was built out of. -
i I know how bad the lamination problem was because I would ask the PT man how the testing was going. Once he put the developer on the pipe and the bleedthrough started showing up, he called me and a told me he wanted me to look at the wall. He told me he had never seen anything like it in his life, and I agreed. I thought quite probably that Tech Support woeld say we were going to cut a piece out of the containment w 11, do away with this stub, weld a stub of good pipe into a g put this back into the containment wall, then make a 100 percent x-ray weld and that would be the end of it. But that is not what happened. l Instead, the foreman decided to just keep fixing it. Although I did not actually work on getting these laminations out, I know j ) that CP-88 was used, and several welders I . knew worked to get these l laminations removed. I would ask the workers, Roy Brady, for in-l stance, at the end of the day, how it went that day and he would 1 i
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1g\ \ tell me things like, "today we started out with 28 laminations and now we have got it down to 25." There was not a new NCI written for every repair on that piece to N.he.tk ofmy kanu%cky p of pipe A Although I was not aub,5$ e, I believe that the correct. pro eoch wdeca4iOO . Q-cedure was to have documents for every repair on '! " r rA r '.d. But the PT guy would just come back and check it. If we had im-proved anything, fine; if not, we still had areas to continue to repair. It took two, perhaps three weeks, to finally get that surface to where nothing bled through. Although I am not a metallurgist, I wondered all the time how all this repair work resolved the probs lem of the piece of pipe itself being bad. Doing spot repairs by grinding 3/8ths of an inch deep and filling it up with metal and smoothing iti back over does not eliminate the lamination in the pipe. There is no way to know how far into the pipe the lamination goes. h._ . _.I_83_ g Cal <k d y Ocj,I gf_'d , , , , _ _ u:3 th:: ;h th pip . Of course, this was supposed to be none of my concern; I was the worker and not in supervision. Finally, somebody got to weld the bellows back on. Once again it shot bad. There were approximately five bad indications and they were linear type indications, as they had been before. As knew it would, the repairs finally dropped in my lap. tooik on %e. separ k. 4. tens Instea f1_i..;g :: litti: I just opened up two ence<ngsMn3 h w MgNep'g:%- te; ther, long areas A The long areas couEd be described as being clockwise from 12 o' clock down to almost 3 o' clock, and another area that k picked up at 4 o' clock and went on around to about 7 o' clock, b i e___
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-12 To Q\n 4hr.Te. pts gin this area I took the arc air and very carefully cut the weld metal out. Af ter I ground and buffed these two areas, they looked like new joints to be welded. I almost went all the way through the pipei (i.e. removed all old weld metal) . Then we called PT back and the laminations showed up again. I was told by Mr. Rudasill to take the M-4A form for the repair "up the hill" for resolution. We were going to use CP-88 again on it.
There were four people who had to sign off on any resolution. One was quality control, one was quality assurance, one was techni- . cal support; the final signatpre that had to go in a box on the v form was from the ANI D rr s_ VN'5p c- ' F"~2r r ' r"' ' inspector. I understand this man was from Aetna, the insurance company on Catawba. It had been my experience that their word was law, and whatever they said was final. The process of getting the signatures took me about half a day.
'[1 I finally got everybody's signature that was needed on the form k ex t the ANI signature. Then I went down to their office. A Mr.
h' MM(N Cosgrove was there. I had heard before out on the job site that he was the top ANI man, or the most knowledgeable person on the site. I asked Mr. Cosgrove for his signature so I could proceed on repair-ing this weld that had shot bad again. He wanted to know the de-tails behind it. He asked me what CP-88 was. I told him it is the procedure used to repair laminations in the containment wall. He commented that this was not dealing with the containment wall, that it was dealing with a piece of pipe and with that pipe weld. I con-firmed that but told 'him that I had been told to use CP-88. He got l l 1
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his book of construction procedures down and he looked up CP-88. He , hit the ceiiing. He started pacing up and down the office and he said he could not believe it. He said he did not even know that a CP-88 existed. He asked me if CP-88 had actually been used on the containment wall. I told him that I had not seen it used myself, but I understood that was what .the procedure was created for, to oliminate the laminations as they showed up. He told me that did not " eliminate a damn thing." He said all that CP-88 did was to cover over something but that the problem was still there. He told me that he was concerned that this procedure directly affected - the safety of the Catawba plant. He told me to give him the paper-work. So I turned the paperwork over to him. He said dhat he was going to have to take the paperwork home with him to think on it, and he reiterated that as far as he was concerned it directly affec-ted the safetp of the plant. He even said that he may have to " shut the place down. " Then it was out of my hands. I went back and reported to my foreman about what had happened but he did not seem too concerned with it. He just told me to do two more repairs that had shot bad. The word got out that Mr. Cosgrove was pretty mad, but I did i not hear any more about the welding. I went ahead and taped over i the two cuts that I had made with yellow tape and went on about my business making the next repairs as Mr. Rudasill had instructed me. , In about two weeks' time the paperwork came back to Mr.
~.I Rudasill and he turned it back over to me. +hr started working on l
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" butter up" a " prop" surface to achieve proper geometry. Rather than grind 3/8ths of an inch deep, I went ahead and really opened some nice grooves where these laminations had shown up. I went about 3/4ths of an inch deep. I wanted to make sure if there was anything there that I was going to try to get everything out that was bad. As I always did, I would blend the ends and sides out so there would not be any abrupt starts or stops. Once I gouged these places out and cleaned them up, I had an inspector look at them and, okay me to continue to do the repair.
Through my extra effort the welds shot good the first time, at least in that weld area. This really concerned me because the re-pairs still did not solve the problem of multiple laminations. For example, although I did not see it firsthand, I had seen these welds on the stiffeners. The workers had taken grinders and ground too much metal away from the weld. There is not very much grinding involved when a good welder does a weld. I worried then,and I worry to this day about how much metal in that containment wall is lamina-ted and could perhaps somewhere along the way cause a safety problem. l If something blows in that plant and there is a little crack and the pressure starts opening it up, it could cause a rip and tear that could possibly splinter the containment wall. If the containment I wall goes, I doanot know how much radiation could get out of it, and I do not know how many people could be hurt, but I do know I am con-corned about it.
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l I was and still am convinced that the vendor who supplied the steel and, Dyke fell down on their responsibility to insure that the materials used in the construction of Catawba were of the quality needed to build err as safe as possible nuclear facility. I often wonder if the department that was supposed to inspect materials received on the site actually checked out the reactor containment plates. On several of the pieces of steel I saw the words " Deliver to Doug Beam in care of Duke Power Company." I wonder if the fact that the materials being shipped to the project manager, by name, exempted them in some way from complete receiving inspections. Even if that ha pened, I think Duke fell short in (ts respon-st%\L sibility when I pol cut thi; - in Auendet E.;\h- 'c'; that I ;; sp;.hi;g of, 3/8ths of an inch epsi I pointed i t to an inspector, I pointed it out to my foreman and asked them how in the world we could ignore something like that. To the best of my knowledge, nobody made any effort to file a report on it, or to put an NCI on it, or to do any-thing about it. To the best of my knowledge, CP-88 was created to "cov6r up" the problems. But according to Mr. Cosgrove, and my own suspicions, it does nothing but disguise the real problem. It does not elimi-nate the problem. I questionef the possibility that if there was one lamination four feet long, couldn't there be 50 that have not been found. I believe that the incident with the laminations and the CP-88 procedure put my Catawba supervisors on notice that I was not going to "look the other way" at construction flaws. Because of my l
conscientiousness in this incident, as well.as others described f below, I believe that Duke used my later health problem 7 as an h excuse to get rid of mehch Mhet-
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- Another example of poor quality work on the containment vessel itself was the venhr welds. These welds, which were done prior to the installation of the containment plates at Catawba, had numerous E flaws. These included porosity, lack of fusion, holes, and were I
generally just shoddy work. The vendor welds were located act one. s b h the entire contair. ment wall. In one vendor weld I found (p holef 3/8 of an inch deep,MM IM ""d M 8* #% - The containment wall is only 3/4 of an inch thick. A 3/8" hole is 1/2 of that thickness, or 1/2 of the strength of the containment vessel at that one point. I do not know how this poor quality work actually happened, but I pointed this up to one of the QC inspectors, I believe it was Harold Eubanks. I also pointed it up to Larry Rudasill and asked him why we welders had to be so perfect with our welds when the vendors could get away with junk like I have described above. He told me it was because the vendors are the ones that are responsible for the welds, 'not us. I asked him what about an acci-dont on the site, such as Three Mile Island. I told him.that people are not going to know or care who made that bad weld.- all they are - going to know is that Duke Power had an accident at Catawba. To the best of my knowledge, bad vendor welds were never touched. As it was told to me, that was not our responsibility. (The weld with the hole in it was located approximately in the fifth course in the Reactor Building Number 2 annulus. )
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l Yet another deep concern of mine, whi6h came to light when I ,
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1 ' ' was a repairman, was the inaccurate identification of problems by , the x-ray department. When I worked with~ uthei-companies,, the , p ! x-ray departments were top quality. 'I r$ aber one job in parti-cular up in Williamsburg," Virgin'ia, where I had done 148 feeE of
! weld. I had one half inch of weld that was rejectable, and.Gian the x-ray man told me it was bad and in what particular plac'e, the flaw was exactly where he called it. At McGuire, also, the x-ray department was pretty accurate. If ' x-ray called a " bad sp t? some- ""
. r' where and a worker cut into the metal, pretty soon'he'wotild start ,.
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finding what they had called. If they called porosity,'the worker . ,, s.. , would start seeing a few dots of porosity. If they called'alag, #1
-f he would start seeing some slag and with lack of fugion it was, the same way. ~. '
At Catawba, however, I did not find this to be 'the case. For - 1 p , l instance, the x-ray department would call a half an ,. inch'of lack of fusion on the weld and it would appear to be in the'cen r f the " sW ~ weld. I would start cutting there lightly with my arc'an . . s rt gouging deeper and deeper. The deeper the cut, t'ne,lfhger ihe s f- . elongation to facilitate smooth trsnsitions.' , f At Catawba I consistently found that rather than the defect',) - w, being where x-ray said it was, it woulh be senewhere else. Often/; - . . - , I would be almost all the way through the pipa, and no defect sculd be there. I could tell by the color of the mdtal that- I was almost ' W' through the pipe and, in fact, sometimes I'did go all the way through it and never found the flai[I(That is allowable to do, to
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rook open it up and to run a new soube pass in, but it certainly is not m Also:, work (\N desirable ~ t5 have repairmen doing ,_ infix; just to find flaws that do not exist.) What was even more upsetting, however, was when I would find a f1mw that x-ray had not identified, somewhere else in the pipe. I would be digging into a pipe at the location x-ray identified, and I would , find, for example, a patch of porosity the size of a silver dellar . Wh- cd- ,Y five inches from where x-ray had identified one-half inch of pfusion. The practice of the x-ray department to identify incorrect problems in the wrong locations concerned me greatly. I wondered how many - problems remain unidentified. Msny ti brought these concerns to the attention of Mr. Rudasill jand _ __ r inspectors jor anybody who would listen. I just could not understand it. My foreman would try to explain it away, saying it was just from the angle that they shot it, but I did not believe it. It happened too many times. This led me to wonder how many were good that were called bad, but more important, how many were bad that had been called good. l 1 Usually I would go ahead and dig the area out that I found as ! bad and then roweld it. Af ter it was re-x-rayed it would show a new i ) t l defect where there previously had been none. There was no consis- 1 tency. To elaborate on this a little, when I was on Henry Best's crew in the Number 2 RBS area in April 1982, one of Henry's better welders had an experience with the x-ray department, which he told me about. 1
. I
; I was standing beside Number 2 RBS one day and Mike Tridemore came i
in raising %holy dickens."
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He ' told me that a weld he had made about a year and a half ago had just been called bad. He said that the x-ray department had already accepted it, and sent it to QC and [ QA, and the approved finished forms were locked away in the vault. p (That meant the work was finished and accepted, . ready for systems turnover.) Then a design change required that a valve be added ihto this line. So they made a cut and, I believe, John Bryant looked up in the pipe and could see the weld. It was maybe two feet down from him and had already x-rayed "100 percent good." He
- saw drop-through, unconsumed filler material, and a bunch of things inside on the root pass that would have made the weld absolutely rejectable. That was in the Unit 1 Reactor Building. This weld was in fact then " red-tagged" by Bryant, or one of the inspectors, and Mike Pridemore was charged with so many inches of bad weld on his record. That weld had to be redone. This is just one example where the x-ray department had approved something that later had to be repaired.
.s While I was on Mr. Rudasill's crew other people on the crew would come to me from time to time and discuss problems with me -
that maybe they ought to have been discussing with the foreman.
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Maybe I was a little more outspoken about problems and working .
.- q\b conditions. In any event, once in late- spring 1981 we had a batch of bad carbon TIG wire. When a worker is using the TIG process, s he holds a TIG torch in one hand which has a nonconsumable tungsten
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that extends out from it. He starts with his arc and it heats the
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metal. This is never supposed to touch the metal, so the torch is held with the right hand, and with the lef t hand a piece of filler is added in. The TIG wire we had sparkled like a Fourth of July sparkler. We would be running along on a weld and it would sparkle, flake, and get all over the tungsten. Good welding procedures require stopping at that point to identify the problem. If the deposited material had porosity it had to be removed. In this case, welders were' definitely having problems with the wire. l 4 Carbon TIG wire comes with a copper coating on it as a pro- , tactive device to keep it from rusting. M ble started sanding it off we would find an area like a seam he it would be roiled
@nd cnA Mihe. pwh e, w- M gg over and down A In that seam there was filts and trash. All of the fellows on Larry Rudasill's crew de ed me to be the person M oreman and tell him what to go up and present the bad wireAt o was going on, which I did. I am not sure whether Mr. Rudasill or his " lead man," Danny Wallace, was running the crew that day. - I explained the problem and gave him the little bundle of TIG wire from all the welders. I told him that~each welder had given me two or three stubs and I had a whole piece to show him. I sanded it off and showed him how bad it was. I told him that somebody D needed to know about this and that maybe we needed to scrap this batch. Either the lead man or Mr. Rudasill carried the problem
- back "up the hill" to his superior, Billy Smith, who was our _
1 general foreman. I i s I
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The word came back to me that I was% paid to weld and to weld with what'I was given to weld with.# I was told that that wire had
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been.sent to the test shop and a couple of tests had been run on it. I was told that there was not a thing wrong with it, and for us to go ahead and work with what we were given to work with. Billy Smith, through Rudasill, also said that our crew was the only one that complained. The message for us to keep working and not worry about quality was very clear. The wire continued to be bad until that lot of wire was used up; and when the next lot of wire was we purchased, we did not have that problem anymore%. g - g Wehadsimilarproblemswiththef2stickrods. 3 There would g be a period as long as a month "here not just my crew, but every ?- D welder on the job seemed to be having the same problems with the stick rods. We were picking up mainly porosity. For example, I would look at the rod and halfway down it there would be a split in the flux. Flux must be bonded to the rod properly, or it will just drop off, creating porosity. Af ter a welder has this problem so many times he gets pretty disgusted. I know that the attitude i of many welders toward bad rods was,:o just keep welding. Then. ) l the porosity would get covered up. I am concerned that the bad l wire and rods have left an undetermined number of bad welds at the site. Although I raised these problems many times no one in supervision wanted to hear them. Their attitude was to get as nany welds done ae quickly as possible. There are other examples of these problems -- laminations, bad l l l l m
q ; . l welding rods and wires, and situations where the x-ray department failed to 18cntify flaws in pipes or welds. Those that I have described, however, are illustrative of the type of activities that were a daily occurrence at Catawba. During these months I got .along well with my co-workers. Even though I was troubled about the quality of construction, I was not too worried about retailiation or harassment from my supervisors, although it appears now I should have been. In the fall of 1981 the Catawba workforce went through a major shake-up. Although I never knew the details or the cause of the - e shake-up there were major changes during the f&ll. Rumor on the site was that Catawba had done very badly on some NRC inspections. There was a marked change in the attitude of the craft supervisors to QC inspectors who found hardware problems, and to the construc-tion workers like myself who were known to argue with foremen over bad construction practices. I sensed that I was on the " list" of people who were to be gotten. rid of because of the CP-88 and TIG wire incident. It was a mistake on my part that gave Duke the first of many opportunities to make my life as a Duke employee miserable. l During November 1981 on one of my repairs I skipped a ." hold poin t. " I had ground odt what I felt was the bad part of the weld I was working on and had started putting the new metal back in it. { I was first to have gone and gotten a QC inspector to look at it to make sure it was clean. He would check the paperwork and sign
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g ik g it off. I just got in a hurry and forgot to get him to sign the clean up off and went on ahead and started putting new metal back i in it. Soon I realized my mistake, and immediately went to get the inspector. He wrote.an NCI or a rework on it. In the past, having an NCI written on your work was a profes-sional embarrassment. The paperwork that you were working with was taken from you my the inspector and it was sent "up the hill" for resolution. Then it was sent back to you. Workers were verbally reprimanded by ti.eir foreman to be careful and not to let it happen again; they knew you skipped up on a#poin t." Normally, what I would have to do to rework the weld would be
+
to take out all that metal that I had put in after skipping the hold point, let the inspector sign off what he was supposed to, then finish -the weld. That did not happen. I got a verbal reprimand and was told that more than likely this was going co result in an "A"iiiolation," which was a disciplinary measure. I screamed to high heaven, "How in the world can this be? This is the first one I've had like this and I've been making all the repairs. I've had ten times the paperwork on me that anybody else does." Not only had I not heard of this happening before, it also was not f air. As a repairman I had to go back and redo work that others had messed up and therefore had many more hold points than others would have. I was the first one that I had known to have gotten an "A" violation over something so insignificant. Others had had similar things happen to them and they had gotten only a verbal reprimand. My "A" violation came about two weeks after the skipped hold-1 l point incident occurred. I was called up to the office. My fore-
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l man and Billy Smith were there. I was told that the NRC had men-
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tioned tlutt;,,so many NCI's were happening on the job that DPC decided a reprimand was not going to be enough.any more. They said they I were going to have to take stricter and sterner measures to prevent this from happening. This was going to be the new policy. I did not bel it. I told Billy Smith and Rudasill both l that I would k is violation, but I had better not find out i that anybody else on the job was being " red-tagged" (NCI' d) on any of their work and was not getting an "A" violation or I would be back up there screaming. I went back to work. Shortly thereaf ter I was trans'ferred to the night shif t. Larry Rudasill just came up on a Friday afternoon and told me that I would be going on the night shift on Monday. I took this as a clear message that I was being punished. It was common knowledge that Billy Smith used transfers to the night shift, or places like the cooling tower, as punishment. This transfer caused me hardship. I had bought a new car to get back and forth to work and was running a car pool with other workers from my area. This shift transfer just destroyed it. I was counting on the riders that I had on the day shift to help make the payments on that car. It was a pretty low blow. On the night shift I worked on Unit 1. Once again I was doin repairs. My new foreman, Arlon Moore (Billy Smith 's brcScr-i.. -l__) u -m +, told me after a month or so that I was aboup s best welder. He o ee toen told me that he really hated te de t..poded ic, but s something that l i
Billy Smith was making him do. In fact, he told me that he heard ma nsntion-
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ed for a " lead man" position and that he was going to try, to help me somewhere down the way. I worked the night shif t for about three months although I was scheduled to work it six months. J. R. Wilson took over the night shift around December, soon after I started. He told us that he just wanted us to try to work within the Code and if we got a
" red tag" or something he was not going to jump down our throats about it. He told us he just wanted us to try to hold our mistakes to a minimum. I raised my hand and asked if this was his policy or' i
! Duke's policy. He told us it was just kind of the way he thinks about it. Af ter the meeting I explained to him what had happened and asked him to get me an answer on my mandatory "A" violation, received back in November. The answer he came back to me with was that at the start of November the NRC. had made it a rule that any-body who got a red tag would get an "A" violation and they had dropped that rule at the end of November. I never heard such a bunch of hog wash in my life. That rule was in ef fect just for the month that I got mine. So I dropped the matter. In February 1982 I asked for a hardship transfer back to the shift. This was important to me because my little girl was day beginning to have nightmares and becoming fearful as a result of not seeing me at home. That is, would have to leave for work before she came home from $ 1 y wife and I could see a signi-ficant change.in her personality The hardship transfer was l approved.
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M,
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I came back to work on the day shift for Henry Best. This was , about February or March 1982. Henry Best's crew worked the Number 2 RBS' area. That is just outside the reactor vessel itself, on the other side of the wall. It is a very important area, almost every-l thing in it is safety related. Therefore, almost everything is stainless steel piping. Henry ,Best supposedly had theN cream of the crop +of wclders down there. It had a reputation as being one of the most important crews on the job. Henry was a tough foreman. He had to " test" you for himself for a long time. When I started I just did little menial things like tacking a hanger or a - temporary hanger, first one thing, then the other. In other words, I had to prove myself to Henry. I tried to do that, but to no avail. Even on Best's crew there were serious problems that affected the quality of construction on the Catawba site. (I described one 6 pj incident on page 18. ) Another of these was the problem of fore-
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men overriding the craft people in order to meet construction dead-lines. For welders this had a very personal impact. Each welder had a stencil number. Mine was P19. It was pretty much up to the welder when he was given a weld to stay within the code, to know how to do that weld, and not to exceed the interpass temperature. Then, when he gets through with the weld, if it is thicker than a quarter of an inch, he takes the hammer and knocks the stencil number on it. It is like a signature and it is going to be there for as long as the plant is there. A lot of people take pride in
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that, and a lot of people'do not. I always have, but it puts a lot - If something breaks later on, the ' of pressure on a person too.
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welder's stencil number is on it, and everyone knows who the man is who did it. I was never overridden too much personally in the way I would weld something. Mr. Rudasill did override me a couple of times to make something look more uniform, specifically on a cold bell on the wall. But in a case of a welder who has not had years'of ex-perience, when a foreman overrides him it implies that he is doing something wrong. When I first went to Catawba, A man named Malcolm Young had an, experience with this situation. Some crew cut into a line that Malcolm welded on two years previously, a Class G weld (We were told that Class G should be welded like Class A.), and Malcolm lost his stencil because of it. He was on night Malcolm told me he well remembered that weld. They shif t at that time, and the fitters made a sloppy fit on it. They slopped it did not put- the proper bevel or proper land on it. I do not together. He went to his foreman and told him about it. know who his foreman was, but Malcolm told him the fit was" stove-piped.' The foreman told him it was just Class G and to go ahead and weld it out. But it gapped open in one place and was slammed together at another; it did not have the proper gap or proper land. Malcolm has about the same number of years of experience that I do, He came very c3.ose to but he lost his stencil and had to ratest. quitting. What happened to him was known all over the job.
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. &s .
r If a man is going to be given a stencil and given a responsi- - bility, then certainly a foreman should stand back and let a welder ! do it to the best of his ability. If he does not have the ability, then he should not have had the stencil to start with. Another example of overriding occurred when I worked for Rudasill. I was set up on the floor above us in the Reactor Building Number 2 to work with Ed McKenzie's crew. They cut up one-foot isngths of stainless steel pip.e that was to be joined to 90-degree couplings. They wanted me to tack them in and said the paperwork would follow. But I refused to tack the.n in until I had gotten the ~ paperwork and my foreman got on me about not tacking them. He said the paperwork was coming. I told him that I did not have it yet and that I was not going to do it. I was very concerned about this practice when the pressure to gat the plant done increased. It is so easy for a welder to, for example, have a groove that is a half-inch deep and then fill it up with root metal and put a nice cap on it. A QC inspector or fore-o man could look at it and think it was all fine but there would be no way to know it was a weak weld unless it was x-rayed properly. Because QC inspectors did not come to inspect until welds were completed, the workers could do any quality of work they wanted. Bncause the foremen actually were " inspecting" work, they had the l authority to make on-the-spot changes that would never be detected by QC inspectors. Foremen on the site knew which workers would put up with the pressure and which ones would not; it was a con-i otant struggle to try and do the job the way it was supposed to be l done. _ _ _ _ _ _ _ _ _ _ -_ . . _, -- . - . . . - , . , _ yy_., , .-m.,
Many times I was told by my foreman to do work "his way" --
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there was a'saying on the site: "There is the Duke way and there is the highway." This meant, of course, .that a worker would be fired if he did 'not do it the way his supervisor said. Another saying that foremen used was: "You do what I told you to do, not what you know how to do." In the Duke Code of Conduct, violation A 11 reads, " Failure to follow instructions, either written or oral" will-result in an "A" violation. If a worker gets three "A" violations he can lose his job. So workers were of ten in the difficult position of choosing between following the foreman's instruction or following proper procedures; that is, violating the laws governing nuclear power plant construction or risk losing their jobs. In other words, you were " damned if you did, and damned if you didn't." This was particularly bad on Henry Best's crew. As I said before, Mr. Best had one of the best crews on the site. . He also . had three workers, one of them myself, who were dumped there to teach us a lesson or try to get rid of us. Best's crew was re-sponsible for welding the cooling loops for il and #2 reactor with a special welding process called the heavy wall TIG prgces . None of. the three of us, myself, Woody .! it;;;.{yAnke PQ y% or Jerry Wilkinson, were allowed to do the heavy TIG welding. In fact, we l were only allowed to do menial labor, like cable tray supports. f Once; Woody got so fed up with things harassing him that he hit the ceiling. I heard him tell Henry that he was " sick and tired of l doing garbage-shit work," that Henry _ hadn't given him any decent l
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work to do for months. Woody told him that wanted a transfer to another ocaw or a check. ": ; n . .-..f.. erry was also ve y{@ N OkQtdfe S frustrated, he was & 13-year, well-liked welder from <!herwhee He decided to put up with it, put in his time and draw his check. I . kept trying to have Henry give me some work -- finally he let me - take the heavy metal TIG test. . I passed the first time.
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However, two weeks later, Henry came and told me that the ANI man had pulled my test weld and rejected it. He didn't offer any , proof, and I didn't believe him - I knew I passed. I just took it as another kick in the teeth for try.ing too hard to get back to - decent work. l i 9 l
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l m - l l .
h I felt continually under pressure at the Catawba site. I
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wanted to do high quality work. In fact,'I took an extreme amount of pride in the welding repairs that I did at the site. My repu-tation as an excellent worker was very important to me. However, it was becoming increasingly apparent to me that the Catawba manage- go D ment did not want high quality work, they just wanted to get the Nd plant finished as quickly as possible. It seemed that every prob-lem that was identified, every " red tag" that a welder got caused supervision to get meaner and meaner with the work force or the wo rker. Because I had earned a reputation as being a worker who identified problems and was not afraid to bring them up to super- - vision, the pressure on me was getting intense. I felt as if the only reward I was getting for being a conscientious employee was 1 a " kick in the teeth. " The pressure at work eventually began to affect my health and
.ny home life. I was also receiving an extreme amount of pressure from my ex-wife for more and more child support. The arguments at work over construction and the arguments at home over money, and the arguments with my ex-wife over child support threw me into a l depression. Everywhere I went there was more and more pressure, and I felt there, was no one to support me.
In April 1982 I began seeing a private physician'concerning-this problem. He recommended that I begin taking a " mood elevator" to relieve my depression from the numerous pressures I was under. I had been under a " cloud of depression" for some months. l 1 ___,____._I
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Unfortunately the doctors and my family underestimated the " tail-spin" tha) I was in. In July 1982 I had to be hospitalized for i eight days for a period of deep depression. Following the hospitalization I returned to work. The doctors who were treating me attempted to find a " mood elevating" drug which would lif t my spirits and bring me out of the state of mind I had fallen into. Although th'ay sincerely tried to help me I believe that they made matters worse--switching medications frequently and paying little attention to the physical side-effects of the various drugs. Besides that, things at work continued to degenerate. Af ter ' I con-my hospitalization I felt more isolated from my co-workers. fided in my foreman about my problems, and he seemed sympathetic but it did not change the situation. The work atmosphere was still the same -- pressure to get jobs done in a hurry with no attention to quality. The morale of~the entire workforce seemed to be at an all-time low. Many of the workers who did talk to me sympathized with how dif ficult it was to come to work and do work that we knew would just be ripped out on the evening crew and have to be done over again the next day. The tension at the site was terrible. t -1
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g i 33 In November 1982, after checking upBro.is out, I had a grand mal stisure on the job. I had just started to check my rods 4 out and soon after 10 o' clock I woke up in York Hospital and my head was being sewed up. I had fallen down and had kept attempt-ing to get up, and get up, and my head had gone underneath a little shed they had there with sheet metal to the bottom of it and j every
- time I would get up I was hitting my head on the sheet metal. I i
was out of wor f r eigh days. !
>>d 6hVST I hadg a previon seizure in 1968 after I had gone through five or six days of extreme, heavy work. , The cause of either of these -
seizures was never pinpointed. I returned to work after this medical absence. I was assigned t,o Herschel Brewer's crew doing very menial jobs such as welding hand rails, etc. , on ground level. I was welding for the steel-riggers. As stated before, I had volunteered earlier to work in the pipe fab shop. Having the good x-ray record that I had and the experience I had, I felt I could pass that on to the company. Be-cause I was now required to do ground level wofk I volunteered for the pipe fab shop again. I was still told that I wou no ' be put there. I was going to be put on hard mM 16 welding fri r:lfr, R or the steel riggers. This was a slap in the face. I had been a good i worker for Duke Power, and was highly qualified. My personal prob-lema did not make me a bad welder. For years the workforce had known that some of the top level management on the site were aloo-l holics, and diey still were allowed to supervise construction of a
-- ,-,,arv.,, rue, ,- - - - - - - , en v v e -,, gr
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nuclear plant. l
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During the spring of 1983 the job situation was painful. It is almost impossible to describe the effect that having nothing to do and no one to talk to for eight hours a day, five days a week , I has on a person. Although I knew, pragmatically, that all of these actions were ! being taken to get rid of me I was determined to keep my job. I was then, and still am, a good welder. I continually asked for work but it was of no use - the message for me to quit was very clear. For days on end I would be given nothing to do. Then if I , was given some work, it was meanin ess. If I as ever caught S s % g G6us sleeping on the job, it was a f" ," iolation - a _ _ _ 151: offense, so I did not even dare to sit down. There were many, many days of this just " marking time." The work situation was also affecting my health. It was more and more difficult to go to work, I would actually get sick on the way to work at times. During March and April I took about a half dozen vacation and sick leave days. Each of those sick days counted as an occurrence.1/ I do not know why my absences mattered. There was nothing for me to do at work anyway. About the third week of April 1983 my supervisor suggested
- 1. I was told that an " occurrence" is' any day that you did not work the full day, even if you were missing only one hour. Any day that you were tardy, or that you left early, that you were sick,
- had a doctor's appointment, or.you called and said that your house was on fire and you woul $e late, or you called and said 1 l
that your child had been .huc+g fand you had to leave, all of this, any of these statements would count as an " occurrence." i l
4 h , that I talk to Employee Relations about going to the Employee ' Guidance Pr.ogram in Char &otte. I welcomed the opportunity to do that. I 3 ult wanted things in my life to go back to normal.
'The Duke Power Employee Relations Department was a maze. In retrospect I can see that the Employee Relations Department was really a trap. Ms. Williamson at the Employee Relations Office I think Mr.
apparently knew something about my personal problems. Brewer shared this information with her but I did not mind because she seemed really interested and concerned. I trusted her. She explained to me that none of the times that I would see doctors or psychologists at or through the Employee Guidance Program -- be it , one time, four times, twenty times -- would count as an " occurrence. The next morning I had an appointment with Eddie Young of the Employee Relations Department. He identified himself to me as a certified or registered psychologist who worked for Duke. He also told me that he had been an engineer at McGuire and h'ad done all the cable tray drawings for the Auxiliary Building there. Then he asked me about my problems. I explained to him that all I wanted was to do a full day's work for a full day's pay, but that the job l situation was intolerable. I explained that I wanted to reduce l down to nothing the varfous medications that I had been prescribed for nerves, pain, and my seizures. He referred me to a private clinic in, downtown Charlotte,- where But instead of helping ! I had to e@ lain my problems all over again. ' l i me, the doctors at the Eastover Clinic just made things worse - l l instead of taking me off medication they just prescribed something
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l oise for depression. I tried to explain that I just wanted to I work and life my life without medication, and that the latest medication made me physically ill. > Unfortunately, because the Duke Employee Relations Department ; had sent me to this clinic, I was stuck with it. While I went to f this clinic, the doctors' visits and related absences would not count as an occurrence (s), whereas if I went to a non-Duke referred doctor each visit would count as a separate occurrence, unless Duke set up an approved medical absence program, me with them. If S .g
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they did this, these visits would tint as o ly one occurrence. should also point out that seeing Dr. Humphrey and Dr. Williams - puoWat4Hne.b m M .
,was costing me out-of-pocket $37.50 per visitA Not only could I not af ford this, they were not helping me either.
Finally in mid-May I had had it with the Duke-referred doctors, , I the Duke-referred psychologists, the Duke-referred psychiatrists, the Employee Guidance program, and the Employee Relations Department. I tried to switch to a personal physician, and in fact took three more " occurrences" (partial-day absences) to see him, but working , with a doctor who did not dnderstand all the various and. ridiculous Duke programs was futile. It did not matter that the doctor was l helping me, he could not take the additional time to send all the letters and supply all the required Duke forms. I felt trapped and I felt I had no choice but to stay in l- Duke's trap -- my health, my paycheck, my future, and, most impor-l l tant, the wellbeing of my family required that I stay within the Duke family circle.# I had requested a meeting with J. R. Wilson and Herschel
" ' ' ~ ' ' ^ ' ' ' , - - - - - . , _ , _ _
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- g. j' in \A g M85 I told them that the previous week 3rewe r 2 :"_ ._ "._, , L, 17, 1092.
I had not been given one piece of work to do and that I couldn't work with nothing to do. I said that I was tired of being harassed
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and intimidated. I went back to my original problems when I was brought over to Catawba dnd laid all of my concerns on the table - these included both the harassment and intimidation, as well as the hardware flaws. I told them that the Employee Guidance Program was just a management tool used to play games with the workers. Af ter I had my say Mr. Wilson very calmly told me that if I wanted to keep my job I would learn to do things"the Duke way. g\ Neither J. R. Wilton nor Hershel Bre'wer nor anyone else at Duke ever told me that I could go to the NRC if I had concerns about construction problems. My understanding was that only top Duke management personnel could go to the NRC. I was also not told about the Department of Labor provisions, 42 U.S.C. 85851, which provide for protection of nuclear employees who are being harassed and intimidated for trying to do their jobs. If I had been aware of these protections I would have gone to both government agencies. Faced with losing my job or trying to keep the one I had I went back to the Duke " family circle." The Employee Relations people and the doctor told me that even though I had broken off l relations with them and had gone to see a private doctor it was all l due to my not being on the right medication! I felt as if " Big Brother" was* forgiving"me. They told me they were going to get together with my supervisor, talk it out, and lump 'all of my doctor's I
f visit occurrences (seven) into just one occurrence. Unfortunately, J. R. % Nil ~ son at the site did not go along with this agreement. Evi-dently, there was a big argument between the supervisors on the site i and the Employee Relations Department. Then I was told that I had accumulated 15 occurrences. Despite these problems, in early June 1983 I was sent by my foreman to be racertified for the TIG 200 - welding process. Racertification'is required every 90 days. When I got to the office that maintains the certification printouts I was both surprised and distressed to see my name on the list as t qualified. The roster said that I had "recertified" on April 11, 1983. Of course that was impossible. I had not racertified in either April or January. In fact, I had done no TIG welding since November 1982 when I had my seizure. I believe that someone falsified my certification. Perhaps 1 this was done inadvertently, but I am 99% sure that it was done deliberately. There are two reasons why this concerned me. First, the falsification of my certification indicated that perhaps others who were not certified or qualified to do TIG welding were also being racertified through this mysterious " pencil whipping." Second, I was outraged that serious violations such as this went unnoticed, uninvestigated, and unpunished and that other minor mistakes by craf t were used as tocls to get rid of them. After I discovered the fal d certification documents I , Teemedv . reported it to Eddie-Penstee- uality Control. I asked him if
. .. -. . i, 7 h 'l q
he could possibly give me the name of the person who had falsified . it, but he could not.
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What is incredible to me is that Duke plac'ed such monumental cephasis on something as minor as my absences for doctor's appoint-ments or taking off one hour early for a funeral while they ignored the unconscionable and really dangerous practice of their own falsi-fication of welder racertifications. . On Sunday, June 12, 1983 a close family friend died. His wife called and asked me to help arrange the funeral and be there to support har. I called my supervisor at home and asked if there was any possible way I could be off one hour early the day of the funeral. He told me no, I could not take it as an excused absence. If I took the time off it would have count abmy sixteenth occurence. (On the sixteenth occurence you got written up for disciplinary action.)
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I went to the funeral. h0:: :: I was given the sixteenth My supervisor got real mad,i occurrence as a typewritten letter saying that I had violated I refused to sign it. management policy related to " occurrences. " I told them that I did not acknowledge their " occurrence procedure" I bscause I had never beengiven any written material on it to guide me or even to explain it to me. Over the next several days a number of incidentr, occurred which 1sd me to believe that my car and lunch box had been tampered with, i l During this entire time period, they would not give me any work to do whatever, not even handrailing work. Just days and days and ~ days with nothing to do, just sitting around. i Finally, I called Joe Coulter, the head of Employee Relations,
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A and asked him if he could guarantee me that I could go into work and ' not be harassed. I just wanted to go in and do my job. Joe told me that there was no way he could guarantee that. He told me that there was an employee recourse procedure to use, if I wanted to. 1 l On Monday morning I called Employee Guidance and asked them again for a guarantee that I would not be harassed if I went in to work, but they would not give me that guarantee; so I did not go into work on Monday. The same thing happened on Tuesday. On Wednesday morning my foreman called me and told me not to come in, that I had been put on* temporary medical leave of absence.' I had never heard of such a leave and did not know how this affected my job status. I called downtown to try and find out who had placed f me on this " temporary leave of absence," what it was all about, i whose decision it was, and who was going to determine when I could go back to work. During those next two or three weeks while I was not allowed to go to work I talked to Eddie Young and the clinic people who gave me the tremendous run around that got me into this mess in the first place. Eddie Young, Joe Coulter, Faye Fowler, John Humphrey, and Wade Williams all told me to " hang tight"; but they were the same people who told me they were going to get my seven-occurrences from May lumped into only one occurrence so I didn't have much confidence that anything would be straightened out. I still did not know what my job status was. When I again asked them for help in this harassment situation where I was not receiving any work to do and being isolated they
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\yq told me they could not help me. They told me that I had to go through normal employee recourse procedures. Of course, going through this procedure meant that I had to complain through the very people who were harassing me, and up the uame chain of com-mand that had made my life miserable for almost three years.
I sincerely believe that Duke was using my health problems as a ploy to get rid of me. They steered me into their Employee i Guidance Program and then manipulated me round and round, back and forth - they had me bouncing around in a " catch 22" situation. , On or about July 8, 1983, N. T. Lawing called me to report back to work on the following Monday, July 12. I did so. My fellow employees were very surprised. They had been told I was fired. I was still on Brewer's crew. J. R. Wilson then assigned me as a welder on loan to Avery Drake, a powerhouse mechanic fore-man. The work I was given was to weld construction hangers. I began by collecting my tools and some equipment to set up a " turn-table," a work jig to facilitate welding hangers of the same size. No sooner did I return to the crew th n I was told by Hershel's 6cAh MD lead man Wayne Garvin that Ed Seepe, Drake's lead man, was already reporting to Brewer about me.. He evidently told Brewer that I was
" screwing off." It was then clear to me that I was being watched and that it would only be a matter of time before I was once again forced off the job and out of work.
l I just resolved to keep my mouth shut and do the best job I l l l
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w s fired. After a few days my co-workers accepted me, but my cupervisors never let up on me. Even though I kept my mouth shut I still saw problems. F6r example, I previously described the practice of foreman overriding the craft workers who were trying to follow the correct procedures ~ that dealt with construction , hangers. Constructi h era were not necessarily safety related; however, the3 proc wdAi befor working on construction hangers were ures cpecified and depending on where they were inctalled they may be - eafety related. Instead of the construction procedures being followed, however, I saw both Mr. Brewer and another supervisor, Mr. Fulgam overriding q, (# their employees in order to get the construction hangers finished. Foremen and workers were writing "VI ok" or "Vis OK" (meaning visually ok'd) on the hanger itself with a black' pen. I do not know the exact location where the improperly f abricated hangers were installed, but I know that the fitters were working in Unit #2. One fitter told me the hangers were being used to support low pressure lines all over Unit 2 -- in the " dog house" and the reactor. - For another example, Toot" Hackle a welder on Mr. Fulgam's crew who worked with me, was a whole lot newer welder than myself j cnd was trying to make a mark for himself. He would thrive on
- getting ten welds to my five. That did not matter to me because I was going to do five correctly; if he wanted to do ten incorrectly that was his business. Toot asked me to look at his work Several l
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\ L l 1 k.k l times I went over there with my welding gange after he finished a ;
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weld that would call for a quarter of an inch weld and that had already been signed off. I would slide the gauge up, and it would not have a quarter inch weld on it, it would have 3/16ths or less, and sometimes it would have too much. (It is okay to overwald some, but it is not okay to underweld.) In addition I found poro-sity , undercut, arc-strikes, and all other rejectable weld problems. I saw this happen many times over the past fe a s. I - og thought about bringing this to the attention of my ervisor but , I knew he would just tell me to min'd my own business. In another case, a welder, D. A. Henry (" Buck"), was loaned over to a welder foreman on Number 1 side by the name of Tim Hollingsworth. It was a " Friday afternoon special." The welding machin e that Buck was using was defective. Many of the machines are in bad shape. This one did not have enough power to push a 1/8 rod. He had a welding job there on the table, a paperwork hanger, and it ga ed for a partial penetration weld. The metal vadde %% had to be preer:_ hn(h Ts far as it could possibly go. About 3 He told Tim o' clock he was out of the smaller ]f32 rods. Hollingsworth that he was going out to the rod shack and pick up another po thd of }$2 rods, and Hollingsworth told him not to, that the job had to be done right away. He told him to go ahead and t use the 1/8. Buck told him that the machine would not push a 1/8.
- As Buck told me, Tim said, "I am the foreman, and I'm telling you what to do, and you go ahead and use the 1/8."' .Well, Buck did the i
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r. 1 l best he could, and he made a mess out of it. Then, somebody over the weekend, a QC, QA man, I do not know who saw it, but somebody saw it, and Monday morning Buck was called on the carpet. He tried to explain his side of the story, but nobody wanted to listen. They pulled his stencil, took his qualification away from him, made him go back out to the test shack and retest. Had he not passed his test, he would have been demoted back to a helper, when all the (A while in my opinion Mr. Hollingsworth was the one to 'b gug\Aj M gunEk
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We had been told before: s -ti_j, ::t ,2: lit 7 . a had been i told safety first, but neither was often the case. Every time construction needed to meet a deadline the construction procedures , and safety got thrown out the window. There had also been a problem with the inconsistency of Duke's welding symbols with the universal (AWS) welding symbols. This resulted in constant confusion, particularly for new welders who were trying to read the instructions on field blueprints. This could have resulted in many serious problems. One example, in September of this year in eUngt2 Reactor,demonstratedthat probleta. I w&d ubM M g W(fitters a crew of who could not figure out cockshQ .M ' how topinstal a stiffener by reading the blueprints. Although I am not an engineer, I know that there are seismic graphs done by computer and studies have been made on how much b thage.,Ibe\ieot. h Vt 'l U,[ t strain and stress something will take.- L the intention was ch ed led _ WWhr.s cF mW aned to put a stiffener o'very foot apartppnd someMerew either could not read it or just for the sake of speed, followed a flawed procedure then there may be innumerable installation deficiencies. f
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d t h .o u s t.a c sc in M \ N h g h If the fitt:r: rid ^d according to their interpretation an one ,g could come along and kick it and it woiild break. The M N wk , I
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20 pound hammer pounding all day would not break it. i In September I received another 16th occurrence.M This was
. l because I missed work to respond to an urgent regites'c from my doctor e to check my Dilantin level. In fact, the 6 heck revealed that the .
dosage I had been taking since my seizure was 2'S% too lo.w., ,
, h On October 3rd, although I started out for work, I was forced to return home due to nervous exhaustion ind fatigue -- the degenera-ting work situation was getting the best'If me. Thw m my Ste- .D MCeM oCcuotelt.
on o urm- \6 1 taas q u,A 4e , m3d oc6 $ain , on Oc e < M I. ceb n<4 4o too(K . _r was 's menediabh Md I cons S '"5 k h" ' b b' 5 e mo*d km m mt< > o< ma4 to,- A tea oc.c w /au.. I <e p r _se, u gn a , p.q ,, tecem$ *ou.wc.ege. a gyg, y he acknokg h \gcd% of Dub '
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- 2. On June 17th, two days after I received my 16th occurrence, it~
dropped off.
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The situation at work had not changed;although my c workers sympathized with me for the pressure I was under, it was impossible i I for them to do anything. Many of them told me that they knew that Brewer and J. R. Wilson were determined to get rid of me. I have many friends at the Catawba plant, and if they can provide infiarma-tion, confidentially, to support what happened to me I believe that they will. Although my experiences as a Duke employee at Catawba were ex-tremely costly to me - personally, financially, .and emotionally) y'b,h [edh I could not walk away from the problems I was aware of with-h' out trying to insure that something be done to correct them. That-is why I contacted GAP. The message came across to me loud and clear that Duke was trying to get rid of me. Sadly, they never understood that one, , I was just trying to do an honest day's work for an honest day's pay, and two, that I was just trying to build Catawba as safely as I possib o . O _m n HowardSamuQNunn %C Signed and sworn to before me this / day of November, 1983.
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'. . 7 REGIGal 14 Ant 4A . . . .
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lO IDfSPAPER:{hu t a-w 6 he er-LocArc0 On pact # IATE PUBLISHED: l l - W R*A LOCAT10N ON PAGE-TOP HALF _ 00TTOP. HA d . i Duke officists repeatedly IGfge , NQ(IQQ[ ' Insisted their investigaOWn ., showed procedarsi violadons but , no faulty welds'. They dented ha- , rasslag workers and Llamed poor
- PIggf communications try managers for the problems rather than any in- ,
tent to shortc% safety. -
"There's an enormous amount . D. _.
g PTOb6 of smoke out thert.** said an NRC offleial ie Bethesda. Md., last , 4% - week. He asked not to be klentf . . g, - nad ~t Pumatum to u if Ittrruiries Reach
'I there.s a forest fire out there.,7 To determine whether Catawba *
- 31, U PP" "g8 is esguired in meaningiess smoke or serious flames, the NRC has BHHe Garde:"The implica-By JACK HORAN been forted to launch three other tions at Catawba are really
- serious. What happened at U tll last p the biggest '"hng g in a with Catawba has not been toler-news about the Catawba nuclear the licensing proceedings are: ateo at other piants - at pk.nt was that Duke Power.Co. " '
had moved the 1984 completion (01 psobe o e shn$ which case Catawba has a - t a p ant ahead h he dling of welding inspectors' com- mess on its hands " plaints in violation of federal g, g Then the and. nuclear Palmetto
- 8-Alliance dropped a bombabell by uncovered.
e An Inspection and Enforce- The trapetus for the investiga-disclosing complaints by Duke rnent (l&E) division inquiry into welding inspectors that questjon .t come from the NRC an activist group s petiuon ar.kirig but from an aggressive Washing-workmanship practices. for the agmcy to do a ve d cal The two year-old charges now ton-based group aimed at helping have reached the highest levels of slice of , Catawba s safety sys- insiders in government and indus-tem s. basically an mdependent try who want to blow the whistle the Nuclear Regulatory Commis. sion (NRC), which has four sepa- spot. check. on internal problems. rate loquiries under way into inc!- e An Office of Inspector and That. group is the Government 'i dents the Atlanta regional of fice Auditor (OIA) internal probe into Accountability Project. De prime finished lavestJgating last Fetrru- whether regional NRC inspectors mover behind the Catawba loves. i I ary. Improperly turned over draft re* tigations is Billie Garde. a pro}ect D3 safety related charges al- view documents to Duke officials director who has etrnost single-and compromised the confidenti- handedly pushed the issue.' solicit- '[ tes:ty have been the focus of an > NRC ticensing bearing to a Rock ality of workers who complained ing workerr with safety concerns. Hill federal courtroom, proceed- to the NRC. pressing NRC officials to assurs. ligs due to enter their alghth **We don't feel the alkgations their confidentiality and lobbying week on Monday. have substana." NRC spokesman congressional committees for ac-
' The usually now-key hearings Ken Clark la the Atlanta regional uon.
h;ve been marked by secusacons office said of the latter charges. This is the first time in which b; that Duke Power Co. threatened The NRC investigations - an 01 investigation is the sub}ect getalistkm agalnst Catawba work- which have found nothing wrong of an NRC licensina board (pro-ars, secret testsmony from three at Catawba so far - ironically ceeding).** Garde said. 'It's abso- ; workers and, in one instance ac- are aimed at a plant built by one ~ lutely unique." ' cusations of cheating by welding of the most proficient uullties in -Garde sees Catawba as another inspectors on certification tests. the nation. Duke is highly re- 5'Zlmmer, where the NRC halted The last came from an ex.laspec- garded as one of the most compe- work last~ November after her for who walked la's the hearings tent nuclear operators not only by group prodded the agency to int off the street. the lodustry but by the NRC tt- .vestigate.1 ast week. the NRC re-At the core of the charges are 3,jg, fused to let work resume at the th2 welding inspectors com- Asked if the fact Duke la the gt it-hillion Zimmer plant. tike C2-plaints that supervisors pressured target of workmanship investiga* tawba's Unit No.1. already 97'6 them to accept poor work, of ten i one surprises NRC officials, the complete. '- volded inspection citat ons and or- official replied: -Not vet but it
- 5. -
dered them to approve welds the 9 damn well will if several of these wo kers found unneceptable. allegations register a cause of con- ,;-..,, cern MIEldTS: others, however. see the pat- '
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tern as similar to that found at the , Zimmer nurtear plant at Ohio and . , others, where falsificapon and ,_ ,..,.
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' 4~ OFFICE OF PUBLIC AFFAIRS "The Impelcations at Catawba loadin and startup testing. REG 10N il-AILANTA ,
are rea& serious. What happened $3.9 b6 ion. two unit plant is at Catawba has not bwn intersted sites southwest of downsown at other plants ... at which case -- tawho has a mess on its hands.* .lott.e in York County.5.C.- ~ ~~
,, re talking in terma .of ' - - - -
As" saw an Wesuga M None of 31 Catawba welding Office of Investigations. laspectors who submitted written five
..- _ testimony toJhehearint,%say Ihey. ,, , r :.:h reports directly to~ . the commissioners. , .
t know of any defective , welds.. In ... .. t&E. Investigators are gath. ... . essence lh
- say it w.ntheir vigi. if ,+ . .'<ginforination to ,act < ois ; ' I;,',o,p ',,2,;d
lance and mentation - they - . .-
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e.s SeptemW petillom fM a .._'ict _- kept detailed notes that kept . Ibe plant safe. .
*' vertical slice"Inspectios. .
Two former workers. Nolan "What she's saying is there is Hoopingsraer and Ros McArce, too much doubt." said Robert
- i. testified for the Palmette Alliance Helshman, branch chief for reac. *
. that they observed shoddy work. tor constructios programs.
manship. Breth Duke and NRC of. Whether l&E willorder ao inspec-ficials coenter ihmt the men either tion will depend on whether there ' J misinterpreted erhat they saw or are "enough questions there that , 7 .that Duke
- fixed safety.related we have to 30 back and do some- .
Problems they saw. such as the thing." he said. . flooding of two emergency gener- The seven month laternal probe - - - - - - - alors durteg a lS79 rainstorm. by OIA is "still goisg on. Wheo - liut Catawbs opponents take a
- broader view of the incidents, ar. it's gol'ng to be Eompleted. I don't ,
going procedural vin!ations un. know." NRC spokesman Frank covered in the quality assurance Ingram sald last week. prpgram suggest a tip+f an Ice. Meanwhile. Duke li conducting . berg preliminary tests and . finishing flaws. potential for widespread work on piping supports at Ca. That's basically what the NRC tawba, according to spokes. must resolve in inquiries Ihat may woman Mary Cartwright, well stretch beyond May,1984 the month. that Duke says Ca' Cartwright said Duke doesn't lawbe Unit No. I will be ready for. know whether the lavestigations will hold tap Catawba's license. l
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, e this proceeding or any further proceedings in this case dealing with quality assurance _ and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected infonnation in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding I shall account to the Licensing Board or to a Connission employee designated by that Board for all the papers or other materials contai.ning protected information in my
- possession and deliver them as provided herein. When I have finished using the protected infonnation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
LLA ~ $ bY)al.lud Subscribed and sworn to before me this / 9i/vday of dnou2m 198Tr. V fis % 2d bnlm i Notarf Public
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r - [.s t this proceeding or any further proceedings in this case dealing with quality assurance. and quality control issues, and for no other purpose.
- 7. I will avoid disclosure c'/ protected infomation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that l investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected infomation in my
- possession, including any copies of that information made by or for me.
J At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials contai.ning protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they cor.tain, but in no event later than the conclusion of tMs proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board, blu-o 2$ &Y2 Subscribed and sworn to before me 6 : this M ay of 8n m213 w 1983. f flEAn }t f As . Jho n l NotarfPublic [c mYsfd6EEcTs $IN'
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- this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of
, my ability. However, it must be recognized that in the course of , conducting investigations in connection with this proceeding, certain protected infor1 nation may be independently discarned incident to that investigation which might result in the ina:vertent disclosure of
~
protected information.
- . 8. I shall keep a record of all protected information in my ,
i possession, including any copies of that information made by or for me. .l At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the i papers or other materials contai.ning protected information in my possession and deliver them as provided herein. When I have finished ) using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board. or kw Subscribed and sworn to before me this _fMy of b mu nw 198F. f . fL1xtL $ kn;ls , I NotargPublic
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,/ 3-this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course cf conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all th~e papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected infomation for safekeeping until further order of the Board. l'1 A . hd ,, a v
/
Subscribed and sworn to before me this / 91/ day of b,,m 198).'/- - {}U%}& , . Yi i>, , s ) ' NotarfPublic Netary Pubsc. Cas.Ti t. SLn: at Large My Commission Excircs Sept.17,1984 I
- y. , , .
~
this proceeding or any further proceedings in this case dealing with
- quality-assurance. and quality control issues, and for no other purpose.
l 7. I will avoid disclos're u of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceedinh certain protected information may be independently discerned incident to that l investigation which might result in the inadvertent disclosure of l protected infomation.
- 8. I shall keep a record of all protected information in my possession, including any copies.of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the ' papers or other materials containing protected information in my possession and deliver them' as provided herein. When I have finished using the protected information they contain, but in no event later than , th.e conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping unt.il further order of the Board. t/h "
/
Subscribed and sworn to before me - this // day of b 19 . .
~
Notary L// Public/'L)
--1..-e - .-- ,, , ,,,- , - y .-. , - - . . --. < ~.-
{ this proceeding or any further proceedings in this case dealing with quality-assurance. and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infomation to the best of my ability. However, it must be recognized that in the coe-se of conducting investigations in connection with this pr,oceeding, certain protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected infomation in my ,
possession, including any copies of that infomation made by or for me.
~
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected infomation in my possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than th.e conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with ell notes and data which contain protected infomation for safekeeping until further order of the Board. [ (1A40 MT , y Subscribed and sworn to before me - l this day of b 19 . Y . Notary Publici " Mu ' I
v.. q ; r
/ . > .
3-this proceeding or any further proceedings in this case dealing with quality assurance. and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my abil dy. However, it must be recognized that in the course of a
conducting investigations in connection with this pro'ceeding, certain 4 protected infonnation may be independently discerned incident to that - investigation which might result in the inadvertet disclosure of I protected information.
- 8. I shall keep a record of all protected infonnation in my -
possession, including any copies of that information made by or for me. At the conclusion of this proceeding. I shall account to the Licensing Board or to a Commission employee designated by that Boar.d for all the papers or other materials contai.ning protected infonnation in my possession and deliver them as provided herein. When I have finished using the protected infonnation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
) .
Y k)
- Subscribed and sworn to before me this / 9 r A. day of /, - -,. 1983.$f -
l / [ i, s , ar/ A b; ,, , e Notary Public it,tcry Pi.G ., o..g :., :.*.; et !. aria My Comemssaan Empires Sept.17,19fe4 n- - , .-- , --
_ _ _ _ _ .T__ z this proceeding or ary further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infomation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proc *eeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected information in my -
possession, including any copies of that infomation made by or for me. At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until furthe order of the Board.
. m
- v. J
<- I -)[ hit > 5, b J'f'f
. 3 Subscribed and sworn to before me this !i day of lo / + ,, - t 1983' 4 -
fll% l + f i h. .a Notary Public
- e.-rf ' .: ....u
- t. - c Cr . ' '
- L 17. M
this proceeding or any further proceedings in this case dealing with , quality assurance. and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infonnation.
- 8. I shall keep a record of all protected information in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Commission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
- 6. %,
i N s Subscribed and sworn to before me this M sday of b e 1985.Y .
)>ttl .
NotaryfPublic
... e.. . r. '.v .
( l,; O .i t ri
- t UNI *I 1 '
1
this proceeding or any further proceedings in this case dealing with quality assurance. and quality control issues, and for no other purpose. l
- 7. I will avoid disclosure of protected information to the best of my ability. However,itmustberec5gnizedthatinthecourseof !
conducting investigations in connection with this proteeding, certain 1 protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that infomation made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other material's contai.ning protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board. i
'(. -
l f, , b.n
/0%9ubyt./ ;
l Subrcribed and sworn to before me this / day of omt.te4 19 - M%Jaclo 'N >b'$mlJ i l NotarfPublic !lotarf ut!!::, P Gecrgit, StNo at Lar:t ! My Commission Expires Sept. 17,1984
-]
Q O this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infomation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation. ,
- 8. I shall keep a record of all protected infortnation in my possession, including any copies.of that infortnation made by or for me.'
At the concTusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
/ /$ S k didH )
Subscribed and sworn to before me
~
this 9 i A, day of da ..,a -,.1987. Y N1 no /, r p Y l..I NotaryjPublic
% M'ie, cr r;i,, :ec % ,,,
W Ccmmssen beca Sc;t 17 1h O
l [ , i this proceeding or any further proceedings in this case dealing with quality-assurance. and quality control issues, and for no other purpose.
- 7. I will avoid disclosisre of protected information to the best of *
\
my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that . investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of.all protected information in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing' Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comis.sion employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board. Subscribed and sworn to before me .
~
^
this 84d day of au 19%./ fuY b-Notary Public ,, , , , po;c, osersi. sie. . taro.
, wu noir ka. s.19st e* * * * ++===*a e e==-ee , , , . . , , , , .,
f R l l l this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infomation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
1
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that infomation made by or for met At the conclusion of this proceeding I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than th.e conclusion of this proceeding, I shall deliver those papers and materials to the licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Eaard.
k & Subscribed and sworn to before me , l this 6 tju day of g eo d v 1983. UNM]<t]aCb.lkhus ' NotaryfPublic Notary N,blic. GdP. ?'Me at L - k y cuarni55 ) dk MIAffKl l
this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
, 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected infonnation in my possessicn, including any copies.of that information made by or for me.'
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as prodded herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission raployce designated by the Board), together with all notes and data which contain protected , information for safekeeping until further order of the Board. Ykof r///
~
Subscribed and sworn to before me
~
this 6 f1 day of /Ti% /,w1983. U:mleb d ki Notary fublic
; hetary M,., c..__:.,, , u .
i u , cs .. .a ...-~ ~ - at l%. .- f
. s e_._; .
Q.; ; *, ..... 1- - f this proceeding or any further proceedings in this case dealing with j quality assurance. and quality control issues, and for no'other purpose. !
- 7. I will avoid disclosure of protected infonnation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infonnation mey be independently discerned incident to that -
investigation which might result in the inadvertent disclosure of , protected information.
- 8. I shall keep a record of all protected infonnation in my possession, including any copies of that infonnation made by or for me. '
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comunission employee designated by that Board for all the papers or other materials contai.ning protected infonnation in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Consnission employee designated by the Board), together with all notes and data which contain protected infonnation for safekeeping until further order of the Board, f Subscribed and sworn to befora me l this M day of hm/Q983. [}i% lxt_I . d k lms n NotargPublic
= ne. . o . . _. ..
My Commisu co:res Sool 17,1944
,i I
l this proceeding or any further proceedings in this case dealing with l quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that l investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that information made by or for .ne.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Commission employee designated by that Board for all the papers or other materials contai.ning protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than the conclusion of this proceeding. I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), togethericith all notes and data which contain protected information for safekeeping until further order of the Board. Subscribed and sworn to before me 0// this Afflvday of 82m4 /1983. 05M ist lu Y. }k ,%is NotapyPublic m e,y , , v. . .a. v.s u, wm.1> . :s Scot 11.1%
this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infonnation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infonnation.
- 8. I shall keep a record of all protected information in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Commission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected infonnation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information fcr safekeeping until further order of the Board. 1 Subscribed and sworn to before me this 2,9 E day of 983. Yh0c QLb1 Y- h e tJ NotafyPublic Notary Puts. OsCEi e. State at Lty My Csreniss:ca Expires Sept.17,1934
this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infomation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected inforn tion.
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that infomation made by or for meI At the conclusion of this proceeding,1 shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
/
i
/ g' r Subscribed and sworn to before me this / day of , A c,,,_a tJ983.
?lO% Ad W bnlme .
l Notarf Public Ndary P 00. C:; ;st, Su.a at LaTc My Comrumon Empires SM 17,1984 I I 1
. . . k~2idj . .
l this proceeding or any further proceedings in this case dealing with J quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that 0..+.....,c , investigation which might resolt in the . inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected infomation in my ,
possession, including any copies of that information made by or for me. At the conclusion of this proceeding, I shcil account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected infomation for safekeeping until further order of the Board.
$ 11 Subscribed and sworn to before me this / EI day of Brem/fet/1983.
fl M Mt ), & _ hlvu N i Notarf Public Notary Public. Gec ge, fae et Larce My hssum Empres sept. 17.1984 ;
,.)
this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected information in my possession, including any copies of that information made by or for me. '
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Commission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board. Subscribed and sworn to before me this .U dvday of O h -
- l. J 1983.
(il m 41 L. C$ %k lm x Nota,ry Public
.~ : . -
i.h s. A:.s: D. g S. ct j ;, p.
. r v
this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infonnation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected information in my possession, including any cooies of that infomation r.ade by or for me.
*t the conclusion of this per eeding, I shall account to the Licensing Eoarc or to a Comission emi.cyee designated by that Board for all the
; apers or other materials cc.taining protected information ir, try rossession and deliver ther as provided herein. When I have fir.isnet using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and
.aterials to the Licensing E:ard (or to a Comission employee designated ty the Board), together witt all notes and data which contair. protectec information for safekeeping until further order of the Board.
nJL t. M /
.% bscribed and sworn to before me this At 2 day of 'U-o.w i . 1983.
i 1, 2 - ssri X ?k.~ hotary Public
)
e . . ) this proceeding or any further proceedings in this case dealing with quality assurance. and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course nf conducting investigations in connection with this proceeding, certain protected infomation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected information in my possession, including any copies of that infomation made by or for me. '
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected infomation they cor.tain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further o der of the Board. ADlM Subscribed and sworn to before me this ,4 day of ba.m/4d983. {&st As $ EloiNus) NotarfPublic uau,rs F.% CWS g os w.Qs. he l
AFFIDAVIT OF NON-CISCLOSURE I, 6E56dA'9' 4. NA3 , being duly sworn, state:
- 1. As used in this Affidavit of Non-Disclosure, (a) " protected infonnation" is (1) information revealed in connection with h camera hearings in the Catawba operating license proceeding, including particularly the names of and identifying facts about in camera witnesses, and any other related information, particularly documents, specifically designated by the Licensing Board; or (2) any information obtained by virtue of these proceedings which is-not otherwise a matter of public record and which deals with the 3 camera hearings.
(b) An " authorized person" is a person who, at the invitation of the Atomic Safety and Licensing Board (" Licensing Board"), has executed a copy of this Affidavit.
- 2. I shall not disclose protected information to anyone except an authorized person, unless that information has previously been disclosed in the public record of this proceeding. I will safeguard protected information in written fann (including any portions of transcripts of h camera hearings, filed testimony or any other documents that contain such infonnation), so that it remains at all times under the control of l
an authorized person and is not disclosed to anyone else.
- 3. I will not reproduce any protected information by any means without the Licensing Board's express approval or direction. So long as l
! I possess protected infonnation, I shall continue to take these
s) l precautions until further order of the Licensing Board. 4
- 4. I shall similarly safeguard and hold in confidence any data, ,
notes, or copies of protected information and all other papers which contain any protected information by means of the following: f I (a) My use of the protected information will be made at a place approved by the Board. (b) I will keep and safeguard all such material in a locked facility approved by the Board. (c) Any secretarial work performed at my request or under my , 4 supervision will be performed at the'above location by one secretary of my designation. I shall furnish the Board and parties an appropriate resume of the secretary's background and experience. (d) All mailings by me involving protected information shall be f made by me directly to the United States Postal Service or by personal
- delivery.
' ~
- 5. If I prepare papers containing protected information in order to participate in further proceedings in this case, I will assure that any secretary or other individual who must receive protected information in order to help me prepare those papers has executed an affidavit like this one and has agreed to abide by its terms. Copies of any such i
affidavit will be filled with and accepted by the Licensing Board before I reveal any protected information to any such person.
- 6. I shall use protected information only for the purpose of ,
preparation, including any investigations which may be necessary, for r . _- -. . ___
r) this proceeding or any further proceedings in this case dealing with l quality assurance and quality control issues, and for no other purpose. l
- 7. I will avoid disclosure of protected infonnation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certsin ,
protected infonnation may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected information in my possession, including any copies of that information made by or for me. '
.At the conclusion of this proceeding I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than th.e conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until furth order of he Board.
7
/ \
/ \ \
Subscribed and sworn to before K J this / 4 day of O2 m /c )983. I O A % lw t At d $ ku'm >sa Notarf Public
-l
. . ~ . , , * \
l this proceeding or any further proceedings in this case dealing with quality-assurance, and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain ,
protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that infomation made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my-possession and deliver them as provided herein.. When I have finished using the protected infomation they contain, but in no event later than 4 the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data .which contain protected infomation for safekeeping until further order of the Board. CO Subscribed and sworn to before me ~ .
~
this 7 f j , day of [j /m, em 1983.4
. . J b!he ' rEj Y. ? DN O Nota p Public l
- .:n , t . ..
% Ce ny _,, ,,
f ,'_
hi
- . b ( '
n.c . . ~ . {g . - 3-( this proceeding or any further proceedings in this case dealing with 1 quality-assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected infomation to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected infomation.
- 8. I shall keep a record of all protected infomation in my possession, including any copies.of that infomation made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected infomation in my-possession and deliver them as provided herein. When I have finished using the protected infomation they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected infomation for safekeeping until further order of the Board. Y,WW2 s 1 Subscribed and sworn to before me - this 7,t/v day. of b/w -,,198r. Y ~ [$ km i.dE) Q15 SnO v j Notary Public noter, r uu :. c .t. v i 1. .;< g comv e .c < ^ - . ".nt 17. l'.G f [
- k. . _ . . _ .
'o .
's AFFIDAVIT OF NON-CISCLOSURE ,
, being duly sworn, state:
i I, JAMES P. O'REILLY
- 1. As used in this Affidavit of Non-Disclosure, (a) " protected information" is (1) information revealed in
.! connection with in, camera hearings in the Catawba cperating license proceeding, including particularly the names of and identifying facts about irl camera witnesses, and any other related it. formation, particularly documents, specifically designated by the Licensing Board; or (2) any information obtained by virtue of these proceedings which is - not otherwise a matter of public record and which deals with the ijl
,' camera hearings.
(b) An " authorized person" is a person who, at the invitation i of the Atomic Safety and Licensing Board (" Licensing Board"), has executed a copy of this Affidavit. .
- 2. I shall not disclose protected information to anyone except an authorized person, unless that information has previously been disclosed j in the public record of this proceeding. I will safeguard protected information in written form (including any portions of transcripts of in, camera hearings, filed testimony or any other documents that contain such information), so that it remains at al? cimes under the control of an authorized person and is not disclosed to anyone else.
- 3. I will not reproduce any protected information by any means without the Licensing Board's express approval or direction. So long as I possess protected information, I shall continue to take these
precautions until further order of the Licensing Board.
- 4. I shall similarly safeguard and hold in gonfidence any data, .
notes, or copies of protected information and all other part. contain any protected information by means of the following. (a) My use of the protected information will be made at a place approved by the Board. 1 (b) I will keep and safeguard all such material in a locked facility approved by the Board. (c) Any secretarial work performed at my request or under my
~
supervision will be performed at the above location by one secretary of my designation. I shall furnish the Board and parties an appropriate resume of the secretary's background and experience. (d) All mailings by me involving protected information shall be made by me directly to the United States Postal Service or by personal delive ry. If I prepare papers containing protected information in order
~
5. to participate in further proceedings in this case, I will assure that any secretary or other individual who must receive protected information in order to help me prepare those papers has executed an affidavit like this one and has agreed to abide by its terms. Copies of any such affidavit will be filled with and accepted by the Licensing Board before I reveal any protected infonmation to any such person. I
- 6. I shall use protected information only for the purpose of preparation, including any investigations which may be necessary, for
+ -
,f. ,
this proceeding or any further proceedings in this case dealing with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected infomation in my possession, including any copies of that information made by or for me.'
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than th.e conclusion of this proceeding, I shall . deliver those papers and materials to the Licensing Board (or to a Comission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
. CL^ok 0 Subscribed and sworn to before this . f f,t/@y of /)//nen,fxd983.
flw k L d. &ni,,n NotafyPub'ic l e/n . e. ....<. 1 My Ct4M.A e 1.; <3 geg g y, gg
p-SPECIFICATION NO.: CNS-1244.09-00-0001 Formerly CNS-1144.09-01 Fornerly CNS-1131.00-01 DATE: January 11, 1974 l Page 3 of 13 REVISION: 6 August 24, 1982 l b. Base liner plate and formed embedded anchors. I Penetration reinforcement plates and sleeves. c.
- d. Plate and penetration sleeve weld preparation.
l
- e. Shop welding.
- f. Leak chase channels and/or angles that require being rolled to a specified radius as shown on the drawings.
; 4.1.2 The following will be furnished by others:
- a. Erection. '
t .. .- N b. Anchor bolts and sleeves embedded in concrete. a
- c. Leak chase channels, except as noted in 4.1.1(f).
- d. Field unloading and storage.
- e. Field welding.
- f. Field painting.
- g. Personnel locks and equipment hatch.
- h. Foundatica pads for equipment as shown on drawing CN-1042-4.
- 5. GENERAL DESIGN AND MATERIAL REQtJIREMENTS 5.1 GENERAL i
5.1.1 The design drawings indicate the extent and general arrangement of work. If any departures from these drawings and/or Specification are deemed necessary, detailed drawings of such departures and the reasons therefor shall be submitted to the Owner for approval. No such departures shall be made without prior approval. 5.1.2 Materials covered by this Specification are subject to the referenced attachments to these technical provisions. The Contractor shall be responsible for and shall be governed by all requirements therein. 5.2 -Jgf3MtRE 5.2.1 Materials shall meet the following specifications:
- a. el plate for Containment Vessel, including the base liner I ate, shell plate, and ring stiffeners, shall be SA-516, Grade -
. In addition, it shall also meet gterial requirements
- -- r -- -w
SPECIFICATION NO.: CNS-1144.09-00-0001 Formerly CNS-1144.09-01 Formerly CNS-1131.00-01 DATE: January 11, 1974 Page 4 of 13 REVISION: 6, August 24, 1982 l g of Subsection NE of ASME Boiler and Pressure Vessel Code, 7 I Section III. The vertical stiffeners shall be ASME SA-36 Mod. flat bar. 1, 3 Boiler and Pressure Vessel Code, Section III.
- c. Shapes for the base liner plate shall be ASME SA-36, including the channel at E1. 550+0.
Leak chase channels for the knuckle plate shall be Sk-479, Type f
- d. 1
" 304, and shall meet material requirements of Subsection NE of ASME Boiler and Pressure Vessel Code, Section III. Angles and channels other than the knuckle plate shall be SA-36.
- e. All material, except the base liner plate and its embedments, 1.5,6 e shall meet the impact requirements of Paragraph NE-2350 "Charpy
- U V-Notch Tests", at or below -20*F for a service metal temperature
# of +10*F.
- f. Embedded plates used to transfer loads through the thickness of the plate, as noted on drawing CN-1042-4, shall be ultrasonically examined and repaired in accordance with Paragraph NB-2500 of 3 Section III of the ASME Code.
No parts , materials or equipment shall be of manufacture outside the p United States without prior approval of Owner. 5.3 FABRICATION 5.3.1 The Containment Vessel shell plate and accessory steel shall be fabri-cated in accordance with the requirements of Subsection NE, " Class MC Components" of ASME Boiler and Pressure Vessel Code, Section III,
" Nuclear Power Plant Components." Accessory steel shall be defined as l
all permanent attachments to the Containment Vessel excluding the base 3* 3 liner plates and its embedments. An "N" Code Stamp is not required on
.i the products furnished.
1 The final dimensions of the cylindrical plates shall meet the tolerances shown on the drawings. Plate length and width tolerance shall be i 1/16" and plate diagonal measurements shall be t 3/32". Above measurements are to be taken with plate flat prior to rolling. Diagonal measurement is to insure a true rectangular plate with j stated tolerances. Fabrication tolerances for the done plate are to be specified on the shop drawings by the Contractor and shall be approved by the Owner. The diagonals of the done plates shall bt2sttWal within a maxian 3* 4 difference of 3/16". ~ ff
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SPECIFICATION NO.: CN5-1144.09-00-0001 Formerly CNS-1144.09-01 Formerly CNS-1131.00-01 , DATE: January 11, 1974 l Page 5 of 13 REVISION: 6, August 24, 1982 , The weld detail used for the penetration sleeve to the.shell plate or / r reinforcement plate weld shall be in accordance with Detail "g" or ' h "h", Figure NE-3359.1(c)-1 of Subsection NE of the ASME Code. The fillet weld as defined by t shall e be provided on both sides of the weld. l ' Fabrication shall be in accordance with approved Shop Drawings. Plate weld preparation shall be as shown on the drawings. Bevel preparations shall be by mechanical means or flame or arc 3 cutting as approved by the Owner. :l l 5.4 WELDING 5.4.1 All welding shall be done only by welders qualified with the actual essential variables employed in accordance with Part A, Section IX, ASME Code. All welding procedures shall be qualified under provisions of Part A, Section IX, ASME Code and shall also meet the ASME Code j requirements for ductility. Welding procedures and procedu e 3 qualification tag results shall be submitted to the Owner for approval before welding is started. Performance qualification test l results for each welder and welding operator shall be made available l .g-- for Owner's review and approval. 5.4.2 All welds shall be full penetration groove welds unless otherwise
) approved by the Owner. Welding procedure identifications or designations l shall be shown on the Contractor's drawings for each weld.
F 5.4.3 Prior to welding operations, the Contractor shall submit to the Owner for approval three (3) copies of each of the folicwing: 5.4.3.1 The qualified welding procedure specification. I 5.4.3.2 The report of the welding procedure qualifications for nach type weld. The Owner shall require any welder or welding operator to repeat 3 any qualification tests when, in his opinion, the work indicates a reasonabl e doubt of the welder's or welding operator's competance and proficiency. 5.4.4 All surfaces to be welded shall be free free protective coatings, and from scale, rust, and grease for a distance of two inches back from the edge of the welding zone, and shall be carefully inspected after completion of edge preparation for laminations, shear cracks, or other injurious defects. Permissible repairs, as approved by the a Owner shall be inspected by X-ray, ultrasonic, or magnetic particle J l ' methods as directed by the Owner. Material not designated as reparable by the Owner shall be replaced. g, i :~~ . . . g . .
.I nny
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a SPECIFICATION NO.: CNS-1144. 09-00-0001 Formerly CNS-1144.09-01 Formerly CNS-1131.00-01 DATE: January 11, 1974 Page 6 of 13 REVISION: 6, August 24, 1982
- 5.4.5 Each layer of weld shall be thoroughly cleaned and the slag removed before subsequent layers are deposited. Upon completion, each weld shall be thoroughly cleaned and wire brushed, and extraneous nodules of weld metal and crust removed by chipping or other adequate means.
- 5.4.6 The back side of all welding grooves shall be are gouged, back 3 chipped or ground to sound and clean metal. 5.4.7 In shielded metal arc -welding the electrodes shall be of the low hydrogen type. All welding filler metal shall have mechanical properties which are similar to the base metal and meet ASME specifications.
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5.4.8 _ ~~ unamemade. 5.5 PREPARATION FOR SHIPMENT , !. 5.5.1 The finished components shall be shipped in a manner to assure safe arrival at the-site. 5.5.2 All weld preparation, flanged faces, other machined surfaces and ( protruding parts shall be adequately protected against acr.idental damage and corrosion during transit. Shipping damage shall be repaired at the Contractor s expense. 5.5.3 The Contractor shall cociplete the attached Form 301.4 for each shipment and obtain Dwner's approval prior to shipment.
- 6. SPECIAL REQUIREMENTS All metal components shall be stamped with both the heat number and piece mark using a low-stress metal stamp. Containment shell plate stampings shall be on the lower right-hand corner of the outside face of the plate At the Contractor's option, the Quality Control identification numbers may be stamped on the plates in lieu of the heat numbers as long as those Q.C. numbers 1 are traceable to heat numbers and associated Mill Test Reports.
- 7. QUALITY ASSURANCE REQUIREMENTS AND DOCUMENTATION 7.1 QUALITY ASSURANCE These Specifications cover structures and materials important to nuclear j safety; and it is essential that they meet the quality standards of these specifications and referenced codes, standards and guides; and that this
(- quality be proven by full documentation. With the proposal, each Bidder shall submit a description of the quality assurance procges,,p proposes to use; OR ^? m.p
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CNS (. r
\ 3.8.2 STEEL CONTAINMENT 3.8.2.1 Description of the Containment lhe containment vessel is a freestanding welded steel structure consisting of a vertical cylinder with a hemispherical dome and a flat circular base. The cylinder is stiffened by circumferential ring girders and vertical stringers welded to the exterior of the vessel. The containment shell is anchored to the Reactor Building foundation by means of anchor bolts around the perimeter of the cylinder base. The flat base of the containment is a 1/4 in liner plate encased in concrete and anchored to the. Reactor Building foundation.
The base liner plate functions only as a leak-tight membrane and is not de-signed for structural capabilities. The containment vessel has a diameter of 115 ft and overall height of 171 ft 3 in. Further details of the contain-ment geometry and Reactor Building general arrangements are shown in Figures 3.8.1-1 and 1.2.2-8 through 1.2.2-16. Additional containment vessel details, including plate thicknesses and vertical and circumferential stiffener loca-tions, are shown in Figures 3.8.2-1, 3.8.2-4 and 3.8.2-5. Containment vessel anchorage details are shown in Fi_gure 3.8.1-5. Several penetrations are_ required through the containment vessel for personnel and equipment access, fuel transfer and various piping systems. The contain-ment penetrations are:. (1) EQUIPMENT HATCH The equipment hatch is composed of a 20 foot cylindrical sleeve in the contain-ment shell and a dished head with mating, bolted flanges. The flanged joint has double compressible seals with an annular space for pressurization and testing. The equipment hatch is designed, fabricated and tested in accordance with Section III, Subsection NE, of the ASME Boiler and Pressure Vessel Code. Details of the equipment hatch are shown on Figure 3.8.2-2. (2) PERSONNEL LOCKS Two personnel lo'cks are provided for each unit. Each lock consists of a cylin-drical sleeve with a bulkhead at each end. Each bulkhead has double gasketed doors with an interlocking system to prevent both doors from being opened sim-ultaneously. Instrumentation is provided to indicate the position of each door. Double, inflatable seals are provided on each door. Automatic leak l testing equipment is piped to the annular space between seals for periodic l testing as required by the Technical Specifications. The use of double in- l flatable seals allows testing of the annular space without the use of external i strong-backs or other remote devices. l The personnel locks are designed, fabricated, tested and stamped in accordance
, with Section III, Subsection NE of the 1971 ASME Code, including all addenda up to the Summer of 1972. The personnel locks are installed as a unit with
(' -
.. accompanying reinforcing collars. Details of the personnel locks are shown on Figure 3.8.2-2.
3.8-9 Rev. 6
CNS
/ l i
~
Basis Accident. Existing test data and analysis on electrical penetration l types may be used for this verification if the particular environmental condi- ! tions of the test are equal to or exceed those for Catawba. . j l (8) MECHANICAL PENETRATIONS ) Typical mechanical penetrations are shown on Figure 3.8.2-3. l l Mechanical penetration functional requirements, code considerations, analysis and design criteria are defined in Section 3.9. l A comprehensive list of all penetrations is given in Figure 3.8.2-6. 3.8.2.2 Applicable Codes, Standards and Specifications 1 Tkwg+g$w: X L999res n;;m:
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m w= Subsection NE, SectiorLIII, does not make provisions for stamping pressure vessels of this geometr , and therefore the c m -_-n Lt a- ' c + cggstransfL-codestap The h "+=Han _ Hald a-ar+1aa_. y - desifwetwe~mr c _ + - - M=-w ~ '., r - - - - ---
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. _ - . ___ _... _ - b g feur code.
Regulatory Guide 1.19 is used for nondestructive testing of the Containment bottom liner with the following additions or exceptions:
- a. C.1.b - Add liquid penetrant method as an acceptable means of testing liner seal welds.
Liquid penetrant is used more successfully in detecting circular defects.
- b. Delete C.1.c.
Non-destructive testing as required in C.1.b and leak chase pressure testing i.c neak containment pressure as required in C.1.d have been successful in detecting leaks in seal welds. Vacuum box tests run at l five psi do not necessarily detect leaks that might occur at peak contain-l ment pressure. In addition to the pressure test required in C.1.d an additional ten minute peak containment pressure leak chase pressure test is performed prior to and after placing concrete over the leak chase system. These tests are performed to detect leaks created during construction activi-ties after the completion of the initial leak chase pressure test and during placing of concrete around the chase system.
- c. In C.1.d where leak chase system channels are installed over liner l
e welds, the system is tested for leak tightness by pressurizing to peak > containment pressure. If any leak is indicated in a 30-minute period, the leak is repaired and the system retested. t 3.8-11 Rev. 6 l
CNS s - r I s' The material, fabrication (except for weld details) and allowable stresses for the transition torus meet the requirements of Subsection NE, Section III of the ASME Code, 1971 Edition including all addenda through the Summer of 1972. The welds and test channels on the torus are as shown in Figure 3.8.2-7. The torus is considered part of the bottom liner plate and all welds are tested as specified in Section 3.8.2.7. [ m,uiV4's c JHFistitiiceMy4estid in accordance with Subpara-7aiih'RF2531C1 or secticn III of the ASME Code to insure that there are no aminations that could result in a failure to transmit loads normal to the iner plate such as would occur in the region of B-series Cadweld Splices.
'M3.8.2.3 Loads and Loading Combinations The containment vessel steel shell is designed for the following loads:
- a. Dead loads and construction loads.
. Thermal loads.
- c. Seismic loads.
- d. External pressure. __
- e. Design basis accident,
- f. Localized loads.
Dead load and Construction Loads The dead load includes the weight of the containment shell and all permanent attachments. Construction loads include all loads imposed on the containment shell during construction. Thermal Loads The containment shell is subject to thermal loads duri,ng normal operation of the unit. The operating temperatures are between 75 F and 110 F in the upper containment compartment and between 80 F and 120 F in the lower con-tainment compartment. Seismic Loads The seismic loads are derived from horizontal and vertical ground response spectra. The horizontal ground motion is represented by OBE (.08g) and SSE (.15g) spectra. The spectrum used for the vertical d.irection is equal to two-thirds of the horizontal spectrum. The ground motions are taken to act in one of two perpendicular horizontal directions simultaneously with the l vertical direction. For further details on seism'ic loads see Section 3.7, l " Seismic Design." l .- 1
\
s. 3.8-12 Rev. 6 Entire Page Revised
CNS' I s The external pressure load is due to the internal vacuum created by an acci-dental trip of a portion of the Containment Spray System during normal unit operation. T . For details of the design vacuum pressure conditions refer to Section 7.6. nocy w :2:s,3 Loads for the Design Basis Accident are the result of a rupture in the pristary coolant system up to and including a double-ended rupture of the largest pipe or a main steam line break. The following loads are associated with the DEA: (1) TE E -';c ._... , c ::_r " " =ig. This pressure is applied as_a static' load case. (2) The containment shell n.1st also be designed for the short-term pressure transient immediately following a LOCA or MSL break. This is a dynamic load of an asymmetric nature (i.e. , the pressure varies around the cir-cumference of the-shell) due to the geometric layout of an ice condenser containment. ( (3) The containment atmosphere temperatures after a LOCA or MSL break are - described in Section 6.2.1. (4) The containment shell experiences hydrostatic loads at the base due to post-LOCA flooding. See Chapter 6 for further details of the Containment Design Basis Accident. Localized Loads Penetration loads, piping loads and jet impingement loads are all localized loads applied to the containment vessel. Penetration and piping loads are due to dead load or pipe reactions at penetrations and pipe supports welded to the shell. Jet impingement loads are due to high pressure fluid jets caused by the rupture of small diameter piping adjacent to the containment vessel. Load Combinations The loads aprilied to the containment vessel are combined in accordance with These cot-procedures given in the Standard Review Plan (see Reference 5). binations are summarized in Table 3.8.2-1. The nomenclature used in this table is defined in Table 3.8.1-2. 3.8.2.4 Design and Analysis Procedures ( The containment shell is designed based on the loads and loading combinations s of Section 3.8.2.3 using the codes, standards and specficiations defined in Section 3.8.2.2. 3.8-13 Rev. 6 Entire Page Revised
CNS 3.8.2.4.1 Design Bases The containment vessel is designed to assure that an acceptable upper limit of leakage of radioactive material is not to be exceeded under design basis . accident conditions. The containment vessel utilizes the ice condenser concept for energy absorp-tion during a loss-of-coolant accident. This rapid energy absorption cap-ability maintains the containment vessel design pressure at a low level as well as reducing the peak duration. See Section 6.7 for details and des-cription of the ice condenser design and function.
.The use of the condenser requires that the containment vessel be divided into three ma ar volumes. The lower volume houses the Reactor Coolant System, the intermediate volume houses the ice condenser energy absorption system, and
} through the upper volume contains the air after passing from the lower volume the ice condenser. Compartments have been designed for peak dif-ferential pressures due to a severance of the largest pipe within the en-closure or flow into the compartment from a break in an adjacent compartment.
The containment vessel is d_esigned to accommodate all calculated external pressures. Vacuum breakers are not required. The containment shell plate (cylinder and dome) is not exposed to ground water and is protected by the Reactor Building. The containment bottom liner plate is anchored to the Reactor Building foun-dation which is constructed of reinforced concrete with waterstop in all construction joints. No waterproofing is provided. The containment bottom liner plate is designed to function as a leak-tight membrane and is not required to function as a structural component. The ; liner plate is 1/4 inch thick carbon steel with the total thickness avail- , able for corrosion allowance. Liner plate details are shown on Figure 3.8.2-7.' l 3.8.2.4.2 Design Per ASME Code Thu.a uwsBMV4MALWeeq4aisat,ttrydhe-reqweseme- - u godazgraras pasmsam9AC1IE-3324. These sections of the code describe the procedures to be followed in sizing the various parts of the containment i shell under external pressure loading and internal pressure loading, res-pectively. l T"'" = -me ym m - --- m u 2 -- _- n -- - l_- --
---= ; A systematic numerical procedure is set up in order to i
Inalyze smati penetration reinforcement in accordance with the ASME Code re-l quirements. The numerical procedure provides detailed requirements for re-inforcing the shell around an opening. Separate analysis and design are performed on the equipment hatch and personnel air lock penetrations. 1 1 l 3.8-14 Rev. 7 l
CNS ,
\
3.8.2.4.3 Static and Seismic Load Analysis The containment vessel is analyzed to determine all membrane forces, moments and shears as a result of all specified static and seismic loadings. The vessel is idealized as a thin shell of revolution. The stresses and deflec-tions produced in the shell under the applied loads are calculated by a com-puter program written by Professor A. Kalnins of Lehigh University (Reference 1). The computer mathematical model used to represent the containment shell is shown in Figure 3.8.2-9. See Section 3.7.2 for further details of the seismic analysis. 3.8.2.4.4 Analysis of Local Areas The overall analysis of the containment vessel as described in Section 3.8.2.4.3 does not examine localized stresses around the equipment hatch and personnel locks since these large penetrations cannot be accurately repre-sented in an axisymmetric model. A more detailed analysis of this region of the shell is required. A three-dimensional finite element model of the containment was analyzed ysing the STARDYNE computer code to obtain results around the equipment hatc[and airlocks (see Reference 3). The finite ele-ment model used for this analysis is shown in Figure 3.8.2-10. Concentrated forces and moments are applied locally to the containment vessel by welded attachments, penetrations and jet impingement. These loads are analyzed as equivalent static loads using finite element models with the STRUDL computer code (see Reference 4). The stresses resulting from the localized loads are combined with the general membrane stresses to determine the total stress state in the shell. 3.8.2.4.5 Analysis of Design Basis Accident The loadings on the containment vessel due to the design Basis Accident are described in Secticn 3.8.2.3. All of the loads except the short term pres-sure transient are considered as r,tatic loads and are analyzed as described in Section 3.8.2.4.3. The stress resultants and displacements of the contain-ment shell dce to an asymmetric transient dynamic pressure associated with a loss-of-coolant accident are determined by performing a dynamic analysis as follows:
- 1. Design Considerations:
fTherapidenergyabsorptioncapabilityofthecontainment,duetotheuse of the ice condenser concept, maintains the containment vessel design pres-sure at a low level as well as reducing the peak pressure duration. This reduction in peak pressure results in a shell thickness below the stress-relieving requirements of the ASME Boiler and Pressure Vessel Code.
~
,- 2. Loss-0f-Coolant Accident:
(.- A LOCA is a hypothetical double-ended rupture of a reactor coolant pipe in which the pressurized water flashes immediately into steam causing a pressure transient build-up in the containment compartments. o 3.8-15 Rev. 6 Entire Page ;
~
I 1 CNS l
~
A time history of dynamic forces at each node is developed for each specified break location. Since the load varies around the circum-ference, it is resolved into Fourier components. Both symmetrical and asymmetrical terms are used in the final Fourier representation of the pressure transient. Thirteen Fourier components (6 sin, 6 cos, 1 con-stant) were employed in the representation since convergence was found satisfactory. A typical comparison of the actual pressure distribution for a given time step is shown in Figure 3TF16. 3.8.2.4.6 Buckling Analysis The stability analysis of the containment vessel is performed by the methods defined in Code Case N-284 of the~ASME Code (see Reference 6). The buckling capacity of the shell is based on linear bifurcation (classical) analysis. Capacity reduction factors are applied to account for the effects of imper-fections and nonlinearity in geometry and boundary conditions. Plasticity reduction factors are applied to account for nonlinearity in material pro-perties if elastic limits are reached. Overall stability, panel buckling and stiffener buckling are evaluated using bifurcation analysis of an axisym-metric shell of revolutTDn with the B050R 4 computer code (see Reference 7). Local buckling capacity of the region surrounding the equipment hatch and personnel lock is based on a bifurcation analysis of a three-dimensional finite element model with the NASTRAN computer code (see Reference 8). The i B050R and NASTRAN computer mathematical models used for the bucking analysis are shown in Figures 3.8.2-17 and 3.8.2-18, respectively. The containment l vessel buckling capacity is evaluated for the load combinations defined in Table 3.8.2-1 as well as the transient dynamic pressure load due to LOCA. 3.8.2.4.7 Ultimate Capacity Analysis The ultimate capacity of the containment vessel due to overpressurization is evaluated by a large displacement elastic plastic analysis. The contain-ment vessel is represented by an axisymmetric shell finite element model with the MARC computer code (see Referenr.e 9). Ww-i- 1 -
- -- M 32EMMWalatnatWm.wisiiht'5trpm152EEIC5 nim'tII56pmEEEmpWe s.u u uu m .. Wrgt 4(B.hBh~ug(s.
, f - r_-7w et at t et w,n n we s e we uew h T W+>g n7 m ure 1.8.2-19 shows the finite element model used for this analysis. The criteria used in determining the collapse load is given in the 1980 ASME Code, Section
.III, Appendix II, Article 1430. The ultimate capacity of localized areas such as the equipment hatch, personnel lock and other penetrations is also evaluated.
3.8.2.4.8 Computer Program Description
~
(1) Kalnin's shell program (Reference 1) uses the finite difference methop to solve the differential equations for a thin shell of revolution de-rived by E. Reissner (Reference 10). The equations are based on the linear theory of elasticity and consider both membrane and bending action
- in the shell. This method of analysis (Reference 11) has been widely used in the analysis of thin axisymmetric shells.
l l 3.8-16 Rev. 7 l
CNS .(. safety for overall stability and local buckling for the critical load combina-tions are shown in Table 3.8.2-7. The results presented in this table show that the containment vessel has a buckling factor of safety greater than 3.0 0220.41 for normal loads and a minieum factor of safety of 2.0 for all cases involving the Design Basis Accident. 3.8.2.5.3 Containment Ultimate Capacity T,JLe containment. vessel has been analyzed to determine the maximum internal pressure to which it can be subjected without failure. Based upon linear Q220. 42 elastic analysis, the requiretnents of the ASME Code, Division 1, paragraph NE-3220, Service Level t Limit, tare met for a combination of dead load and f aninternalpressureoF45psiy.~JBaseduponnonlinearanalysis,theloser bound for the containmqnt ultjmirte capacity is calculated to be 72 psig. Failureoccursduetothehrojragationofplasticityfromtheshellpanels into the circumferential stiffeners. Localized areas have been analyzed to insure that they do not control the containment capacity. A summary of the results of these analyses is presented in Table 3.8.2-9.
\ Materialst Quality Control, and Special Construction Techniques 3.8.2.6
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Gaugons -K-_-- =_'74_2heggjode. The interior steel surface of the containment vessel and penetrations are cleaned and coated with materials meeting ANSI N101.2-1972, Section 1.4.2.2, Design Basis Accident Environmental Conditions for PWR's. The environmental conditions for the containment are listed in Section 6.2.1.1 for normal operating condi-tions and Section 6.2.1.2 for DBA conditions. The integrated radiation dose is 3 x 107 Rads during normal operating conditions and 2 x 10s Rads for DBA conditions. The coating systems, surface preparation, type of coating, required thickness, limiting temperatures, humidity conditions, acceptance criteria and quality assurance methods are tabulated on Table 3.8.2-3.
- All exterior surfaces of the containment vessel and penetrations are coated with a suitable system for outdoor exposure.
3.8-17 Rev. 7
CNS ' ( No unique or untried construction techniques are used in fabricating the con-tainment vessel. The same construction procedures are used that have been successfully employed at McGuire Nuclear Station which is identical in shape and size. 3.8.2.7 Testing and Inservice Inspection Requirements 3.8.2.7.1 Preoperational Testing and Inspection (A) Structural Testing T , ptititecaspimilawwidrethiecksd-iGMdm;n""w '-W ' t __. ,_- L -vdgngeM%m,s5ME050DeT'iU!!I'?,rE55%3ddicde.,gj - . 22-5 - Penetrations are pressu~re test'ed as required f6r~c' lass NCTn ac-
~ ~~ ~
N. cWdance with Section III of the 1974 ASME Code including addenda through the Summer of 1974. (B) Leakage Rate Tests Bottom Liner Plate: The-bottom liner plate welds are inspected, prior to placing fill concrete, in accordance with the following:
- 1. Dye penetrant examinations are performed in accordance with Section V of the ASME Boiler and Pressure Vessel Code.
(
- 2. Upon completion of the dye penetrant test, the weld seams are covered with test channels and pressure tested. All detected leaks are repaired
_ __d and retested. The leak test channel layout is shown in Figure 3.8.2-8. Personnel Air Locks and Equipment Hatch: The personnel air locks are pres-surized and a Type B leak rate test is performed as described in Section 6.2.1.4. The double o-ring compression seals in the equipment hatch are tested for leak-age as specified in Section 6.2.1.6. Containment Leakage Rate Test: Upon completion erection including all penetra-tions, personnel air locks, eqeipment hatch, bottom liner plate and structural testing, a leakage rate test is performed on the containment as described in Section 6.2.1.6. 3.8.2.7.2 Operational Surveillance 3.8.2.7.2.1 Structural Integrity The containment shell is protected by the Reactor Building from adverse environ-mental conditions.
. is therefore con emplate hat additional structural testing of the containment shell other ! l than the initial structural test is not necessary.
l 3.8-18 Rev. 6
Table 3.8.2-4 [ Containment Materials Material Location Material Specification Base Liners SA 516, Grade 60
. Base Liner Embedments SA 516, Grade 60 and/or ASTM A36 Xnuckle Plate SA 516, Grade 60 te SA 516, Grade 60 SA 333, Grade B and/or Ms (Piping and Electrical) SA 516, Grade 60 _
q
-J Personnel Locks SA 516, Grade 70 l
SA 516, Grade 60 N . Equipment Hatch SA 516, Grade 60 and/or Grade 70 Anchor Bolts SA 320-L43 Anchor Bolts Anchor Plates SA 516, Grade 60 I i s Rev. 1
- e^. . ,,
[' \ TABLE 3.6.2-8 STATISTICAL CONTAINMENT MATERIAL PROPERTIES BASED ON MILL TEST REPORTS UNIT 1 Unit 2 , Standard Standard Mean Variance Deviation Mean Variance Deviation e = 3d Yield Strength 50.132 3.629 1.905 50.04 4.062 2.014 (KSI) ,l Co Ultimate Strength 69.598 2.979 1.726 69.37 3.246 1.802 (KSI)
% Elongation 29.322 1.854 1.362 29.115 3.034 1.742 Rev. 6
- - - _ - - _ L
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TABLE 3.8.2-9 ULTIMATE CONTAINMENT. CAPACITY . ANALYSIS
SUMMARY
Ultimate Internal Location Pressure (PSI) Criterion
~
- 1. Containment Shell 72 Nonlinear Axisymmetric Analysis
- 2. Base Anchorage 81 Concrete Shear
- 3. Penetrations i l
- a. Personnel Air Lock 79 Plastic Moment in Bulkhead
- b. Equipment Hatch 94 Tensile Failure of Hatch Cover Flange
- c. Spare Penetrations 127S Yield of Pipe Cap a d. Electrical Penetrations > 72 Connector Module Leakage
- e. F; allows Assemblies > 72 Manufacturer's Recommendation
- f. Purge Panetrations > 72 Specified to Manufacturer Rev. 6 New Page
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au'stf , PHOENIX ';T CEL conPOR ATION CLAYMONT DELAWAnr 1.51E SA 516 GR 60 N ormalf red, Long V-Notch Impacts .*t Hlqus May 20, 1975 fECIFICATION37-OerFm-t.E'2350terIII -1973-r,-rddenda)-to Neet rt. LbCL AvnONT. DEL. l Average Si11 con Quellty 5 tee 1 5024-A -7 CHEVICAL AND PHYSfCAL TESTS OF _ C'JSTOMEn's ORDER NO. Newport tJews Industrial Corp. 23624-05 -
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1 b d s 9 2 SPECIFICATION FOR CARBON STEEL PLATES FOR PRESSURE VESSELS FOR MODERATE AND LOWER TEMPERATURE SERVICE s f ) -- (Identical wnh ASTM SpeciGcation A 516-73) s I. Scop' l.1 This specification cosers carbon steel- - - 8 3 E- PN 1E ' r
- d[-
- quired on plates to this specification, the plates shall be normalized. '{ '
5.4 If approved by purchaser, cooling !' putes iniended primarily for service in welded , t -- rates faster than still air cooling are permis- l ! prenure senels where improsed notch touFh-nen is imp riant 3.3 in addition to the basic requirements of sible for improvement of the toughness [ [ l 2 Plates under this specifiction are asail-this specification, certain su piementars re- Provided the plates are subsequently tem- j{ Q
- ~
quirements are available when ditiMal con- pered in the range 1100 to 1300*F(590 to aNc in four grades hasinF 6fferent strength t testing or currintion is required to 700 C). 1; y meet endsse requirements. These include. 6. Ocmical Requirements Tennie sirectih. i c,.Je 6u(MPa 3.3.1 Vacuum treatment, 6.1 The steel shall conform to the chemical [ n 9 e tu ,44,3 3.3.2 Add;tional or special tension testinf. requirements shown in Table i except as in
*o to U (414 4%i % 3.3.3 Impact testing. and ' '
6.2. . -
*f y [j 3.3.4 Nondestructise examination. 6.2 Grade 60 plates 0.50 in. (12.7 mm) and ,
I 3 The maximum thickness of plates is 3.4 The purchaser is referred to the listed under in thickness mas be specified to base . limited only by the capacity of the composi- supplementary requirements in this specifica- 0.85-1.20 percent mTn~ganese on heat anal3 . ' tion and to the detailed requirements in Speci- sis, and 0.80-l.25 percent manganese on twn to meet the specified mechanical property fication A 20. product anal) sis. I requirements, howeser, current practice nor- k 3.5 If the requirements of this specification t r raa113 hmits the masimum thickness of plates """**' are in conflict with the requirements of Speci. formthed under this specification as follows: i Maumum Thdness. fication A 20, the requirements of this specifi-cation shall presail. 7 """" ZMCR8"NM l
- 4. Manufacture 8 Mechanical Requirements 60 S tW) 4.1 Sorrimaking Pracrice-The steel shall 8.1 Tension Test Requirements-The ma- 1.
$ l be made to a fine.erain mmim terial as represcnted by the tension-test speci- ,
mens shall conform to the requirements
%n-The salues staied in U.S customary , .
- 5. Ileat Treatment taits are to be regarded as the standard shown in Table 2. ] ,
5.1 Plates 1.50 in. (38 mm) and under in 8.2 Bend Test Requirements-The bend- 1,
- 2. Applicable Documents thickness are normally supplied in the as- test specimen shall uithstand being bent cold 2 i ASTM Srandards: rolled cor.dition. The plates may be ordered through 180 deg. without cracLing on the out-A 20 Specification for General Require. ~ normalized or s'ress relieved. or both. side of the bent portion, around a pin the [{,-
ment for Delisery' of Steel Plates for 5.2 Plates over 1.50 in. in thickness shall be diameter of which shall hase a relation to the Pressure vessels' normaliied. thickness of the specimen prescribed in Table L G4mertl Requirements and Basis of \ 5.3 When notch-toughness tests are re- 3. I"'Ch SUPPLEMENTARY REQUIREMENTS i 3 I Material supplied to this method speci- Supplementary requirements shall not apply unless specified in the order. ' I fution shill conform to the current issue of A list of standardized supplementary requirements for use at the option of the pur- l Spcofication A 20. These requirements out- chaser are included in ASTM Specification A 20. Those which are considered suitable j., i hne the testinF and retesting methods and for use with this specification are listed below by title. -
'l l procedures. permissibic variations in dimen- St. Vacuum Treatment. S$. Charpy V Netch Impact Test, l wns and mass quality and repair of defects. S2. Product Analyss S6. Drop Weight Test, rnar king. lordinF. ctc. S3. Simulated Post Weld Heat Treatment S7. High-Tem;mture Tension Test. ', '
l of MechanicalTest Coupons. SS Ultrasonic Eumination and 8 l
- 4m r sua or.4srw sch* rm 4 S4.1 Additional Tension Test. 59. MaFnetic Particle Eumination l
h! 477 ' e ____ Lw
7Pi l l 54-516 SECTION 11, PART A M ATERI AL SPECIFIC ATIONS t
/ $
I' 5 b d3 TABLE I Chemical Compeerno. [.I y Compostimon, percent Ekmcats Grade SS Grade 60 Grade 65 Grade 70 Carbon mas
% is. U2 7 mmt and ender 0.18 0.21 0 24 0.27 Over itin. to 2 in (50 i mmt inct 0.20 0.23 0.26 0.28 C O er 2 in. to 4 in 00i 6 mmL inct 0.22 0.25 0 28 0 30 O er 4 to 8 se. (203 mmt inct 0.24 0.27 0.29 0.31 0.cr 8 in. 0 26 0.27 0 29 0.31 Manganew
% in (12 7 ment and ender-Heai anal)s s 0 WO 90 060-090* 085 1.20 085 120 ,t Prodect anahsis 0.56-0 94 0.56 0.94* 0 80-1.25 080 115 Over % in Heas snaisses 0 60-1.20 0.85 1.20 0 85-1.20 0 85- 120 C Pradect seahun 0 56-I.25 0 80-1.25 0 80-1.25 0 80-3.25 Phosphoras. ma a 0 035 0.035 0.035 0 035 Sulfur. man 0 04 0 04 0 04 0 04 Season Heat anahs s 015-030 0.15030 015-030 0 15-0 %
Product anahsn 0 13-0.33 013-033 0.13 033 013 033
- See 6 2 =
TABLE 2 TeenDe Requiremruts Grade 55 Grade er Grade 65 Grade M ew - Tensk strentin. n s. (M Pas 55 0 65 0 (379 448) 60 0 72 0 1414-496) 65 0 77,0(448 531) 700 85 0 t443 5861 Yacid pomt. ku tMPai 30 0(207) 32 0 (223) Elongation in 8 en or 200 23* 35 0 (241) 38 012t2s + 21* 19' I ?* mm. min. percret Elongation * ? in or 50 27 25 23 21 mm. min. prrcrnt
*See Specificaten 4 20
- TABLE 3 Bend Diameters *I Ratio of Pin Diameter to '
Thakness of . Specimen Thickness
- Material. ,
en tmm) Grade Grade Grade Grade 55 60 65 70 1 (25 di and innder % I i% 2 Over t eo 2 (50 8t inct 1 I% 2 2 Over 2 o 4 (10161. inct IS 2 2 2% .- O*er 4 to 8 (203L inct 2 2% 25 3 :E O*er 8 2% 25 2% 3 By pubharion of this standard no position is taken wrth respect to the solidity of any parent eghts in connection therewsth. and The American Socsery of Meehanical Engineers does not arndertake to visure anyone satiksang the standard against Isabilityfor snfhngement of any Letters Patent nor assume an3 such lia bskry. s e 478 4- ' r a 7 1 -
l
~ 1 l
il l l j , GENER AL RE(irlREstENTS FOR STEEL PIATES FOR PRESSURE VESSELS S4 20 f1 ( {~ ( 4.1.3 Name of material (plates, carbon steel. plates. alloy stect).
- 7. Ocsiical Analyses 7.1 # car Analysis of each heat shall be '-
7 4.1.4 ASTM designation (including type, made by the manufacturer to determine the
; class, and grade as applicabic). percentage of elements specified in the indi- r 5 4.I.5 Condition (as-rolled, normalized. vidual material specification. This analysis ('
& quenched and tempered.etc. If heat treatment shall be made from a test specimen preferably of material is to be performed by the fabrica- taken during the pouring of the heat. The 3
tor, this must be so stated. Also. if purchaser chemical composition thus determined shall k specifies a heat-treatment cycle. it must be be reported to the purchaser, or his represent-O stated l- atise, and shall conform to the heat analysis o 4.1.6 Impact test requirements. if any (Sec- requirements of the applicable specification. tion 12). (For Charp3 V-notch test, include 7.2 produci Anahsis representing each
, specimen orientation, testing temperature, plate as-rolled may be made by the purchawr and acceptance criteria. For drop-weight test from a broken tension test specimen or from give testing temperat: re), a sample taken from the same relatise loca-4.1.7 Supplementary requirements, if an) tion as that from which the tension test spec-j (test specimen heat treatment, special impact irr en was obtained. The chemical composition g test requirements. cte.), and thus determined, as to elements required or
- 4.1.8 Additional requirements,if any. restricted. shall conform to the product anal-3 sis requirements specified in the applicable
- 5. Manufacture specification.
5.1 Unless otherwise specified in the mate-7.3 Referte Analy sis-For referee pu r-poses. Methods E 30 or E 350 shall be used. rial specification the steel may be made by any of the followinF processes: open-hearth.
< basic-os3 gen, electric-furna_ce, sacuum are 8. Metallurgical Structure remelt (VAR). or electrostag remelt (ESR). 8.1 When a coarse austenitic Frain size is u 5 2 The steel may be cast in inFots or may specified, the steel shall have a carburized be strand cast. Only the Product of a single austenitic Frain size number of I to 5 as de-heat may be strand cast at one time. termined by the McQuaid-Ehn test. Determi-l' 5.3 The ratio of reduction of thickness nation shall be in accordance with Methods E from a strand-cast slab to plate shall be a I12. Plate IV. by carburizing for 8 h at 1700 minimum of 3 to I. F (927 C). Conformance to this grain size of 70 percent of the Frains in the area esamined
- 6. Heat Treatment shall constitute the basis of acceptance. One test per heat shall be made.
i 6.1 W hen material is required to be heat E.2 % hen a fine austenitic grain size is treated. the heat treatment may be performed specified. ti either by the manufacturer or by the fabn-T - - . m Are cator unless otherwise specified in the mate- u -- rial specification. ma e 6.2 When heat treatment is required and is to be performed b3 the fabricator, the order shall so state. 9 D*Iil) [ 6.3 When heat treatment is to be per- 9.I Gracral-Plates furnished under this . formed by the manufacturer, the material specification shall be free from injurious de-3 shall be heat treated as specified in the mate- fects and shall have a workmanlike finish. ) rial specification. The purchaser may specif> the heat treatment to be used provided it is 9.2 Surfact Imperfections: 9.2.1 All injurious surface imperfections not in conflict with the requirements of the shall be remosed by the manufacturer. material specification. 9.2.2 Shallow imperfections shall be , 6.4 When normalizing is to be performed ground to sound metal, the ground area shall ). by the fabricator. it may be accomplished by be well faired and the thickness of the ground heatinF uniform!) for hot forming. The tem- plate shall not be reduced below the mmimum {; i perature to which the plates are heated for thickness permitted in Section 14. j hot forming shall not significantly escced the 9.2.3 All surface imperfections the re-E normalizinF temperature. mosal of which will reduce the plate thickneu , d 6.5 When no heat treatment is required, below this minimum, shall be cause for rejec-the manufacturer at his option may heat treat tion of the plate; howeser, by aFreement with the plates by normahnng. stress reticung, or the purchaser. the metal so remosed may be j[N normalizinF and then stress reliesing to meet replaced with weld meial as provided in 9 4. K ! the material spccification Repair b3 WeldinF- ) 29
l l 6 *
.i SA.20 SECT 10N il. PART 4 \l'ATERITI. SPECIFIC 4TIOM
/
[ 3 E(er e mperfe[tions and plate material and shall be reported to 9.3.1 Laminar-type discontinuities I in. the purchaser.
; 25 mm) and less in length visible to the un. 9.4.6 If the plate material is subjected to Ci 4 aided eye on the edges of a plate as prepared normahzing, quenching and tempering, hot J # for shipment by the manufacturer are ac. forming, or post-= eld heat treating, the certable and do not require exploration. welding procedure quahfication test plates 9.32 All larger discontinuities shall be ex. and the weld repaired plate shall be subjected piored to determine their depth and estent. to the thermal heat treatment as specified by Discontinuities shall be considered contmuous the purchaser.
uhen located in the sarne plane within 5 per- 9.4.7 in addition, repair welds shall meet the requirements of the construction code l' ' cent of tae plate thickness and separated by a specified by the purchaser. j j distance less than the lenFth of tbc smaller of
, two adjacent discontinuities.
9.3.3 Indications visible to the unaided eye E ' ' fil on the cut edges of a plate as prepared for 10.1 All tests shall be conducted in accord-shipment by the manufacturer shall not es- ance with Methods and Definitions A 370. lL ceed the limits given in Columns I and 2 of l Table 15. II. Tension sad Bend Tests g 9.3.4 LarFer indications shall be removed 11.1 Number of Tests-One tension and
,. by the manufacturer by grinding provided the one bend test shall be taken from each plate 4 resultant cavity does not es ced the limits as-rolled, except that on plates quenched and k
Fnen in Columns 3 and 4 of Table 15. tempered by the manufacturer, two tension 9.3.5 indications of greater magnitude shall tests and one bend test shall be taken from each [ be cause for rej_ection of a plate; however, by plate as heat treated. When plates are fur-agreement with 7he purchaser. the defects nished in the unheat treated condition and mas be removed and replaced with *cid qualified by heat treated test specimens, one
-k me'al t as prouded in 9.4. tension and one bend test shall be taken from
!; 9.3.6 Indications on the edges of a plate each plate as. rolled.
' cut dunng the fabrication shall be cause for 13.2 Orienrasion of Tests-The longitu-rejection of the plate at the discretion of the 6nal amis cf the tension and bend test speci-purchaser when the magnitude exceeds the mens shall be transserse to the final rolling 4 I mits gisen in Columns 5 and 6 of Table 15. direction of the plate _
The defects may be removed and replaced 11.3 Location of Tests: with meld metal as provided in 9.4. 11.3.1 The tension test specimen shall be 9 4 Repair by Weldinr taken from a corner of the plate. The bend 94i Repair welding ~shall be permitted test specimen shall be taken from the rniddle of oni.s with the approsal of the purchaser. a plate end. For quenched and tempered 9.4.2 Preparation for repair welding shall plates, the tension test specimens shall be taken include inspection to assure complete removal from a corner of the plate at both ends of the of the defect. plate. 9.4.3 Repairs shall te made utilizing 11.4 Testsfrom Hear-Terated Plates: weldirig procedures quahfied in accordance l1.4.1 When heat treatment is performed with Section IX of the ASME Code and re- by the manufacturer. the test specimens shall pair welding shall be done by welders or be taken from the plate in the heat-treated weldmg operators meeting the qualification condition or from full-thickness coupons si-requirements of ASME Sectie i IX. multaneously heat treated with the plate.
; 9.4.4 The weld metal shall have the A- 11.4.2 When heat treatrnent is to be per-number analysis correspondmg to the equiva- formed by the fabricator. the plates shall be I lent ASME P number of the plate material accepted on the basis of mill tests rnade on cacept that A 1 or A-2 analysis weld metal specimens taken from full thickness coupons may be employed for P-1 materials. Other heat treated in accordance with the require-i weld metals may be employed that are com- ments specified in the material <pecification
$ patible with the base material being repaired. or on the order. If the heat treatment temper.
l when so approved by the purchaser. Such weld stures are not specified, the manufacturer
} metals must be qualified in accordance with shall heat treat the coupons under conditions J d the requirements of Section IX of the A3ME he considers appropriate. The purchaser shall Code. be inforrned of the procedure followed in heat
[ 9.4.5 If Charpy impact tests are required treating the specimens at the mill. on the plate material, the welding procedure II.4.3 When the pbte is heat treated with
' qualification tests shall also include Charpy a cooling rate faster than still-air cooling impact tests of the weld, heat affected zone, from the austenitizing temperature, one of the Y h _ __
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_ m p , 1.l , S A.435 ARTICLI 23 ULTR ASONir ST ANDARDS , l
% j Method and Specifcationfor LONGITUDINAL WAVE ULTRASONIC INSPECTION OF STEEL PLATES FOR PRESSURE VESSELS SA-435 Odentical with ASTM A435-73 except that Section V. Article 1, General Requirements, also applies. May be used when ultrasonic examination of plates is required by a referencing Code Section and as source material in "f
,y preparation of detailed procedures.)
h :
- 1. Scope reference back reflection from the oppo-g site side of the plate at least 50 per cent Y 1.1 This method covers the examina.
of fu!Iscale during scanning. j tion procedure and acceptance standards 3 3 The surface of plates inspected by for the pulse-echo ultrasonic inspection of f,' rolled carbon and alloy steel plates, ! in. this method may be expected to contain a residue of oil or rust or both. .by speci-(19.05 mm) in thicknesnand over, of 4 6ed identification which is removed when t fully killed pressure vessel quality. It was developed to assure delivery of steel grinding to achieve proper surface ft free from gross internal discontinuities smoothness shall be restored. such as pipe, ruptures or laminations and 4. Procedure
'.: is to be used whenever the inquiry, con-tract, order or specification states that 4 I U "I'55 therwise specified, ultra-M it the plates are to be subjected to ultra-s nic inspect. ion shall be made on either major surface after final treatment and 'A sonic inspection.
prior to shipment. Non-ne va.%es stated in U. S. eust mary 4.2 A nominal test frequency of 2}- units am to,be regarded as the standard. The AfHz is recommended. Thickness, grain size or microstructure of the material and h!c in t may be Eat nature of the equipment or method may o
- 2. Apparatus require a higher or lower test frequency.
- A clear, easily interpreted trace pattern 2.1 The manufacturer shall furnish should be produced during the inspec-suitable ultrasonic equipment and quali.
fied personnel necessary for performing tion. g 4.3 The inspection shall be conducted the test. The equipment shall be of the with a test frequency and instrument ad-pulse-echo longitudinal beam type. The justment that will produce a minimum l
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transducer shall be 1 to 11-in. (25.4 to 50 to a maximum 75 per cent of full scale J , 28.6-mm) diameter or 1-in. (25.4-mm) reference back reflection from the oppo-square. The test shall be performed by site side of a sound area of the plate. 7 one of the following methods: direct con. 4.4 Scanning shall be continuous along tact, immersion, or liquid column cou. perpendicular grid lines on ncminal g pling, 9-in. (23-cm) centers, using a suitable i 3. Test Conditions 3.1 The inspection shall be conducted couplant such as water, soluble oil, or glycerin. ~- f in an area free from operations that inter- 4.5 Grid lines shall be measured from fere with proper functioning of the equip- the center or one corner of the plate ment. with an additional path within 2 in. (5 cm) of all edges of the phte on the [f 3.2 The phte surface shall be suffi-ciently clean and smooth to maintain a searching surface.
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, s S A.435 SECTION V - NONDESTRl:CTIVE EXAMINATION 4.6 Where complete loss of back re ' half of the plate thiciness, whichever is lflection is detected along a given grid greater, is unacceptab:e.
ine, the enie surface area of the squares 5.2 The manufac:u er reserves the adjacent to :his indication shall be con-l right to discuss rejecuble ul: asonically t,nuously scanned.-The boundaries of tested plates with the purch.tser with areas where complete loss of back re- the object of possible repair of the ultra-Bection is detected shall be established. sonically indicated defect before rejec-t
- 5. Acceptance Standards tion of the plate.
{ 5.3 More restrictht standards of [ 5.1 Any discontinuity indication caus- acceptance will be subject to agreements ing a total loss of back reflection which between the purchaser and the supplier. cannot be contained within a circle, the 5.4 The purchaser's representative
' diameter of shich is 3 in. (7.6 cm) or one pay witness the test.
{' SUPPLEMENTARY REQUIREMENTS This requirement shall apply only if specified in the order. ({. St. A <mnmng procedure other than agreed upon between manufacturer and
, that specified in 4.3 and 4.4 shall be as purchaser.
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~.. UNITE 3 STATkS Mooq' o,, NUCLEAR RE!ULATORY COMMISSION 4 h o REGION il 3 $ 101 MARIETTA STREET, N.W.
*
- ATLANTA, GEORGI A 30303
'+ ,. . . . . ,o JA N 201984 Duke Power Company ATTN: Albert V. Carr, Esq.
422 South Church Street Charlotte, NC 28242 l ! Gentlemen: '
SUBJECT:
REPORT NOS. 50-413/84-03 AND 50-414/84-03 On January 3-6 and 11-13,1984, NRC inspected activities associated with your application for an NRC Construction Permit Nos. CPPR-116 and CPPR-117 for the Catawba facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report. Areas examined during the inspection 'are identified in the report. Within chese areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress. l Within the scope of the inspection, no violations or deviations were identified. Your attention is invited to unresolved items identified in the inspection report. These matters will be pursued during future inspections. Due to the restricted distribution of this report pursuant to the Catawba Licensing Board's November 1, 1983 protective order, the NRC has been informed by Duke Power company that proprietary review of this document has been waived in order to assure prompt distribution to the parties in the Catawba Licensing proceeding. Prior to any public release of this report, Duke Power Company will be given an opportunity to indicate whether proprietary information is contained in the report, if they have not previously so indicated. Should you have any questions concerning this letter, please contact us. Sincerely, W Hugh C. Dance, Chief Project Branch 2 Division of Project and Resident Programs
Enclosure:
Inspection Report Nos. 50-413/84-03 and 50-414/84-03 r o I' ] !
, ,
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MToq' UNITED STATES
, o,, NUCLEAR REGULATORY COMMIS$10N I CEilON il
$ p$ 101 MARIETTA STREET, N W.
ATLANTA. GEORGIA 30303
%,...../
Report Nos.: 50-413/84-03 and 50-414/84-03 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: CPPR-116 and CPPR-117 Facility Name: Catawba 1 and 2 Inspection at Catawba site near Rock Hill, South Carolina Inspector: N. Economo~ e /JO [ fate Kgned Approved/ tiy:
/L k
J. J. Blake, Section Chief
/4) 20 8 ate Signed Engineering Program Branch Division of Engineering and Operational Programs
SUMMARY
Inspection on January 3-6 and 11-13, 1984 Areas Inspected This special unannounced inspection involved 41 inspector-hours on site in the-areas of containment spray-welding, welding material control, and radiographic examination. Results No violations or deviations were identified. A I
^'
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b . REPORT DETAILS
- 1. Persons Contacted Licensee Employees
*J. C. Rogers, Project Manager
*R. L. Dick, Vice President-Construction
*W. O. Henry, QA Manager-Technical Service
*R. A. Morgan, Senior QA Engineer
*S. W. Dressler, Construction Engineer
*L. R. Davison, QA Project Manager
*J. C. Shropshire, QA Engineer Mechanical Welding, NDE D. H. Llewellyn, Group Leader, Technical Support-Welding B. Gillespie, QA Welding NDE J. E. Cavender, NDE Examiner - Level III Other licensee employees contacted included construction craftsmen, technicians, and office personnel.
NRC Resident Inspectors P. K. VanDoorn P. Skinner
- Attended exit interview
- 2. Exit Interview The inspection scope and findings were summarized on January 6, 1984, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed the inspection findings listed below.
Inspector Followup 413/84-03-01 Incorrectly dated radiographs weld INS-136-2, paragraph 5. Unresolved Item 413/84-03-02 Apparent lack of penetration indication weld ICF-029-07, paragraph 6.
- 3. Licensee Action on Previous Enforcement Matters l Not inspected.
- 4. Unresolved Items Uhresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items. identified during this_ inspection are discussed l in paragraph 6.
I
2
- 5. Containment Spray Piping - Observation of Completed Work; Review and Evaluation of Quality Records - Unit 1 This work effort was performed in order to ascertain by direct observation, interviews, and independent evaluation of work performance and completed work as applicable whether activities relative to the containment spray (NS) system were accomplished in accordance with NRC/ Code requirements and FSAR commitments. The NS system was designed, fabricated and tested as a Quality Class B system in accordance with Section III of the ASME Boiler and Pressure Vessel Code,1974 Edition including summer 1974 addenda. Design considerations including its description, function and design evaluation are addressed in Section 6.2.2 and Tables 3.2.2-2 and 3.2.2-3 of the Catawba Nuclear Station FSAR. Additional design parameters are delineated in FSAR Figure 6.2.2-1, Flow Diagram of Containment Spray System. Note 13 of this figure specifies that schedule 40 piping be used for all lines in the reactor building for stress analysis purposes. All NS piping in contact with borated water is required to be made of austenitic stainless steel material. Specifically, piping was required to be produced from ASME, SA-312-74 Section III Class 2 material which required hydrostatic testing and ultrasonic examination. Elbow fittings were required to be produced from ASME, SA-403 Section III (74S74) material. All welding was specified to be performed by welding procedures a~nd welders qualified under the requirements of Section IX of the ASME Boiler and Pressure Vessel Code.
At the time of this inspection all welding activity on this system was complete. Work activity on this system was observed earlier under the requirements of Manual Chapter 2512 - LWR Inspection Program - Construction Phase. This effort was documented in reports 50-413/79-02, 50-413/80-02, 50-413/80-10 and 50-413/80-18. Therefore, in lieu of observing in process pipe welding and/or pipe installation activities, to confirm compliance with applicable code and QA procedural requirements the inspector observed: (1) randomly selected completed welds; (2) reviewed respective wald process control sheets, certified material test reports for pipe and weld materials, welder and weld procedure qualifications and radiographs; (3) interviewed craft directly involved in the aforementioned activities. Completed welds selected for observation included: WELD SIZE DWG# INS-92-13 8" sch. 40 CN-1491-NS009 Rev. 2
-17 8" sch. 40 CN-1491-NS022 Rev. 3
-18 8" sch. 40 CN-1491-NS022 Rev. 3
-19 8" sch. 40 CN-1491-NS022 Rev. 3
-20 8" sch. 40 CN-1491-NS022 Rev. 3 1NS-77-12 8" sch. 40 CN-1491-NS009 Rev. 2
~
3 I WELD SIZE DWG# INS-95-1 8" sch. 40 CN-1491-NS019 Rev. 3
-2 8" sch. 40 CN-1491-NS019 Rev. 3
-2A 8" sch. 40 CN-1491-NS019 Rev. 3
-3 8" sch. 40 CN-1491-NS019 Rev. 3
-4 8" sch. 40 CN-1491-NS019 Rev. 3 These joints were observed for weld appearance including surface condition amount of reinforcement, undercut, slag, porosity, arc strikes and transi-tion as applicable.
RADIOGRAPHY - The inspector requested and the licensee retrieved radiograph packages for the following welds for review. General Radiograph Procedure NDE-10A/6, written to comply with AMSE Section V Boiler and Pressure Vessel Code (80W82) Articles 1 and 2, was used to radiograph these welds. WELD SIZE FABRICATION HISTORY INS-98-02 8" sch. 40 (.322") Single repair for each of fusion (LOF) accepted on 9-10-80 1NS-98-03 8" sch. 40 (.322") Single repair for LOF, accepted on 11-25-80 INS-106-2 8" sch. 40 (.322") No repairs, accepted on 8-21-80 INS-106-3 8" sch. 40 (.322") No repairs, accepted on 6-11-80 1NS-115-2 8" sch. 40 (.322") No repairs, accepted on 9-12-80 INS-115-3 8" sch. 40 (.322") No repairs, accepted 6-30-80 INS-125-3 8" sch. 40 (.322") No repairs, accepted on 6-11-80 INS-125-2 8" sch. 40 (.322") Seven (7) repairs LOF, accepted on 9-30-80 INS-136-2 8" sch. 40 (.322") No repairs, accepted on 7-27-80 INS-136-3 8" sch. 40 (.322") No repairs, accepted on 6-7-80
~
INS-148-2 8" sch. 40 (.322") No repairs, accepted on 7-27-80 INS-148-3 8" sch. 40 (.322") No repairs, accepted on 6-7-80 INS-95-1 8" sch. 40 (.322")- No repairs, accepted on 1-7-80 INS-95-2A 8" sch. 40 (.322") Six repairs, accepted on 7-16-81
4 , l Radiographs for each of these welds were reviewed for compliance with applicable code and procedural requirements including technique, weld coverage, density, penetrameter size and location, artifacts, documentation of findings and accuracy. Within these areas, the irspector noted that the radiographs for weld 1NS-136-2, positions 0-1 and 1-2 had been dated 7-12-80 instead of 7-27-80 the correct date. This matter was brought to the licensee's attention for corrective action. The radiographs were nonconformed and the item was identified as inspector followup item 413/84-03-01, Incorrectly dated radiographs. QUALITY RECORDS - Piping adjoining the aforementioned welds were manu-factured from stainless steel material produced from heat numbers 8041936, 28569, 281002 and RW152947. For these heats of material the inspector reviewed certified material test reports to ascertain whether the reported properties, including chemical analysis, thermal treatment and mechanical properties, were consistent with the aforementioned material specification. Similarly, quality records for welding materials used to fabricate the aforementioned welds were reviewed for compliance with applicable code requirements. These welding materials included the following: TYPE SIZE HEAT ER308 1/16"d 04184 i ER308 3/32"d C3064 ER308 1/8"d 06393 Weld Process Control Sheets or Form M-4A along with Detailed Process Control Sheets or Form F-98, used to control and document the fabrication history of field welds, were reviewed for completeness and documentation accuracy. Areas of specific interest included inspection hold points, repairs, welding materials used, welders and weld procedures. WELDER PERFORMANCE QUALIFICATIONS - Of the welders used to fabricate the aforementioned welds, the inspector selected a random sample to review their performance qualification records and thereby ascertain whether their qualification met ASME Code Section IX requirements. Performance records were selected for welders with the following stencil numbers: N-94, H-03, 571, E-48, P-30, P-99, A-05 and 248. , FINDINGS - In addition to this review, certain welders were interviewed in the privacy of the NRC resident inspectors office. The interviews focused nn the methods used to erect and fabricate the NS system. Topics l of specific- interest ircluded the possible use of excessive force (cold i spring) to attain weld fit-up, omission of inspection points, adherence to procedural requirements and harassment by field supervision (foreman I
5 override) in order to expedite work. Although these interviews are discussed in detail in the attached appendix to the report, the inspector found no evidence of code / procedural deviations in the fabrication of the NS piping system. Under the subject of foreman override, the inspector found that while some individuals may have held their foremen in relatively low esteem in terms of qualification and ability to manage the crew this was not pervasive and may have been a personality problem. The vast majority of the craft interviewed spoke very favorably of their past and present field supervisors (foreman).
- 6. Welding Material Control Control of welding material is checked periodically by the NRC under the requirements of the LWR Construction Inspection Program. The licensee's weld material control program is implemented through approved procedures H-3 Identification and Control of Welding Material and, CP-39 Reconditioning of Low-Hydrogen Coated Electrodes and Loading Electrode Ovens. The inspector's most recent work effort in this area was documented in report numbers ,
413/83-36, 414/83-31 dated November 15, 1983. The present work effort was ! performed in response to a concern over the quality of certain TIG wire i filler metal ER70S-2 classification. Specifically the concern was that inferior quality TIG wire was used on safety-related welds. The material - was said to have a black streak, possibly scale, gouged into the surface of the wire. The condition appeared as a black streak which was visible to the j naked eye, after the protective coating was removed. Allegedly when used to l weld, the material caused turbulence in the weld puddle, excessive slag and ) sparkling. Allegedly the material was difficult to use and resulted in poor ' weld quality, high rejection rates and a lowering of welder morale. The l material in question was produced from heat number 97405 and manufactured to ' the requirements of material specification SFA5.18 and of Paragraph NB-2400 of the ASME Code,1977 Edition with latest addendum. A review of quality records disclosed that the material was received, inspected per procedure P-1A, revision 13 requirements on February 18, 1980, and released by QA on [ February 20, 1980. The certificate of compliance on file, was reviewed to ascertain whether chemical analysis and mechanical properties met minimum code requirements and found to be satisfactory. Weld process control sheets (M-4As) and radiographs of randomly selected safety-related welds, showing that the material was used in the fabrication process, were reviewed to determine whether there was any relationship between the material in question and the type and frequency of rejectable ' indications e.g., excessive porosity revealed by radiography. Welds selected for this review were as follows: AUXILIARY FEEDWATER SIZE COMMENTS 1CA-069-13 6" x .432" Porosity in one station near root - acceptable ICA-069-18 -4" x .337" Portion of weld made with Ht #97405' acceptable i I- *
.s 6
AUXILIARY FEEDWATER SIZE COMMENTS Reactor Coolant Magnetic Particle inspection INC-116-006 2" x .168" acceptable Diesel Generator Magnetic Particle inspection Cooling Water System 6" x .280" acceptable ' 1KD-023-005 ISM-038-002 34" x 1.426" Root of weld made with Ht #97405 filler metal acceptable. One indication near weld crown detected by liquid penetrant. ISM-088-010 34" x 1.426" No repairs ISM-034-002 34" x 1.451" Original weld rejected and cut-out. Four repairs resulting from lack of fusion, slag and porosity in weld portion made from other weld metal. ISM-032-001 34" x 2.00" No repairs ISM-024-01 34" x 1.45" Root of weld made with Ht #97405 acceptable. Thee repairs resulting from lack of fusion, slag and porosity made with other weld material. ISM-024-02 34" x 1.45" No repairs Feedwater System ICF-029-07 18" x .938" Apparent indication of lack of penetration between station 1-2 of the accepted radiograph. ICF-034-07 18" x .938" No repairs Safety Injection Penetration Sleeves 2NI-15-01 32" x 1.34" Root of original joint welded in part with Ht #97405 filler metal, rejected for lack of fusion. Rewelded and repaired three times prior to acceptance - Ht #97405 not used for repairs. 4 g- , , .
7 I AUXILIARY FEEDWATER SIZE COPMENTS 2NI-16-01 32" x 1.34" Root of joint welded with Ht #97405 filler metal acceptable. Joint repaired five times before acceptance. Ht #97405 filler metal used on second and third repairs, rejected because of lack of fusion,. slag and porosity. Of the 14 welds selected for review radiography, where applicable, showed that the root portion of the joints where this material was used exhibited some evidence of porosity and/or slag, however, the amounts were no more than what normally appears-in welds of this size and type. However, in all cases these indications met minimum code requirements. In addition, during the interviews, welders who the records showed had used this material were asked if they had encountered similar problems. In response, some stated that they recalled using the material and finding the condition described, however they stated that upon discovery defective material was returned to the issuing station or discarded. _0thers stated that they were not aware of this particular problem but that 'as a general-rule the protective coating on this type of filler metal was removed with sand paper available for this purpose at the issuing station. Of-the eighteen welders interviewed no one indicated that his foremen pressured him in any way to use defective / faulty material to fabricate safety-related welds. Details of these interviews are attached as an appendix to- this report. In reference to weld 1CF-029-07, and the apparent lack of penetra-tion indication identified during this review, the inspector discussed the
~
matter with the licensee's Level III examiner who argreed'to investigate the matter further _ and report on a future -inspection. This matter was identified as unresolved item 413/84-03-02, Apparent Lack of Penetration Indication, Weld No. ICF-029-07. FINDINGS - Results of this work effort would indicate the material in question met minimum chemical and mechanical properties required by the applicable ' code. This material was not- used beyond February of 1981. Randomly selected welds fabricated with this material were of sound-quality as evidence' by their respective radiographs. The amount.of nonmetallic-inclusions- found in the -welds were consistent with this' type of material, weld thickness and ' process. Welders interviewed:were knowledgeable of problems related to this type -material and ' took appropriate corrective measures whdri necessary. The- contention that welders.were pressured into' using defective material on safety-related welds could not be substantiated. Therefore, on the basis of this work effort it would appear. that although a certain portion of this material was defective, there wasino evidence to
. substantiate that:the defective pieces were used to fabricate safety-related -
welds. Instead, the evidence would indicate' that.upon discovery it was - discarded. On the' basis of these' findings the staff feels ~that further work-
- effort-into this matter is unwarranted.
i [. g
- 7. Radiography This work effort was performed in response to a concern that film overlays used to locate weld metal defects rejected by radiography were not reliable because the indications depicted on the overlays could not be located by the usual grinding methods. Allegedly this situation raised questions among the craft, about the reliability of these overlays and the competency of the radiographers/ interpreters involved in this activity.
The applicable code and approved Duke procedure used for radiography for safety related welds was discussed earlier in paragraphs 5 and 6 of this report. The work effort described in paragraphs 5 and 6 included the review of radiograph packages of approximately 26 safety-related pipe welds with diameters ranging from 4" to 34" and thickness from 0.33" to 2.00." The radiographic reader-sheets used by film interpreters to document their findings were reviewed and evaluated for evidence of possible errors in identifying defects, their location and code compliance. In addition, eighteen welders selected at rant'om were interviewed on various aspects of , their work including their assessaent of the accuracy / reliability of film l overlays to detect weld defects identified by radiography. In response, most welders recalled isolated instances where, upon repairing an indication identified on th.e overlay, the radiograph of the repair would show an indication not shown on the previous overlay. However, in most cases, they were quick to explain that it was their understanding that this was possible because of different angle shots and techniques used to radiograph these welds. The vast majority of welders interviewed ~ expressed confidence in the i competence of radiographers and in the accuracy of t.iic overlays. Details of these interviews are attached as an appendix of this report. FINDINGS - This work effort disclosed that in certain instances weld overlays may not depicted accurately all the indications within a certain area of the weld. This may be attributed in part, to technique, angle of exposure, type of indication and its location / orientation. The alleged pervasive lack of confidence in the radiographers/ interpreters could not be substantiated. Moreover, this work effort would indicate that the location of weld defects as depicted on the overlays were reasonably accurate as evidence by the testimony of welders interviewed. The inspector's review of-the aforementioned radiographs showed no evidence of discrepancies in interpretation, documentation and/or code violations. Therefore, on the basis of these findings the staff feels that further work effort into this matter is unwarranted.
. UNIT ED ST ATES
.
- Ef Cg%,, NU.,: LEAR REGULATORY COMMISS;ON *
[ ; l' o REGION il
'E s E 101 MARIETTA STREET N.W.
# ATL ANTA, GEORGIA 30303 o
%*...+/ DEC 211983 Duke Power Company ATTN: Mr. H. B. Tucker, Vice President Nuclear Production Department ?
422 South Church Street Charlotte, NC 28242 - Gentlemen: _
SUBJECT:
REPORT NOS. 50-413/83-53 AND 50-414/83-40 On December 6-9, 1983, NRC inspected activities authorized by NRC Construction Permit Nos. CPPR-116 and CPPR-117 for your Catawba facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report. Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress. Within the scope of the inspection, no violations or deviations were identified. In accordance with 10 CFR 2.790(a), a copy of. this letter, its enclosures, and your reply will be placed in NRC's Public Document Room upon completion of our evaluation of the reply. If you wish to withhold information contained therein, please notify this office by telephone and include a written application to withhold information in your response. Such application must be consistent with the requirements of 2.790(b)(1). - Should you have any questions concerning this letter, please contact us. Sincerely, j
~
*\ (n
- Hugh C. Dance, Chief Project Branch 2 Division of Project and Resident Programs
Enclosure:
Inspection Report Nos. 50_413/83-53 and 50-414/83-40 cc w/ encl: J._ W. Hampton, Station Manager J. C. Rogers, Project Manager 1 W'? ? O f .9 ' (y ' ' g
.. o UNITED STATES
==, (j>S E8c q'o NUCLEAR REGULATORY COMMISslON g ') ,, g R EGION 11
.- .t 101 MARIETTA STRE ET, N.W.
o # ATI.ANTA. GEORGI A 30303
%...../
Report Nos.: 50-413/83-53 and 50-414/83-40 - Licensee: Duke Power Company 422 South Church Street
- Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: CPPR-116 and CPPR-117 Facility Name: Catawba 1 and 2 Inspection at Catawba i near Rock H' , outh Carolin Inspector: 7 j , s y 7 yyj; lcf e 3 / d N. Economos' / Date pgned Approved ^: M / 3 J. J. Blake, Section Chief D6te Signed Engineering Program Branch Division of Engineering and Operational Programs
SUMMARY
Inspection on December 6-9, 1983 Areas Inspected This routine, unannounced inspection involved 36 inspector-hours on site in the areas of Containment (Penetrations) - Observation of Work activities and Review , and Evaluation of Quality Records.- _. Results No violations or deviations were identified. r ~ dIb , . [ './\Jl \ u v - l
?.
REPORT DETAILS
- 1. Persons Contacted -
Licensee Employees
*J. C. Rogers, Project Manager
*L. E. Vincent, Office Engineer L. R. Davison, Project QA Manager J. C. Shropshire, QA Engineer Mechanical Welding, NDE
*T. B. Bright, Field Engineer R. A. Morgan, Sr. , QA Engineer D. H. Llewellyn, Group Leader, Technical Support - Welding B. Gillespie, QA Welding, NDE Other licensee employees contacted included construction craftsmen, technicians and office personnel.
NRC Resident Inspectors P. K. VanDoorn P. Skinner
- Attended exit interview
- 2. Exit Interview The inspection scope and findings were summarized on December 9,1983, with those persons indicated in paragraph 1 above.
- 3. Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item 413/83-44-02, Reactor Vessel Internals Deviation _I Notice 01838. The licensee provided the inspector the aforementioned deviation notice for review and evaluation. The document was added to the Reactor Vessel Internals Data Package.
- 4. Unresolved Items Unresolved items were not identified during this inspection.
- 5. Containment (Penetrations) - Observation of Work Activities; Review and Evaluation of Quality Records - Unit 2 This work effort was performed in order to ascertain by direct observation and independent evaluation of work performance, work in progress and com-pleted work, whether activities relative to containment vessel shell plates and penetration sleeves were being accomplished in accordance with NRC/ Code- ,
requirements and FSAR commitments. The containment vessel was designed, l fabricated, constructed and tested in accordance with Subsection NE, Section - j l l
_ _ __ _ . _ _ ._ _ - .. _ _ _ _ _ .~. ._ _ ...._ 2 i e I III of the ASME Boiler and Pressure Vessel Code,1971 Edition, including all i addenda through the summer of 1972. Design consideration including loads . and loading combinations, design and analysis procedure, materials, quality - control, and special construction techniques are addressed in -paragraphs 7 L 3.8.2.3, 3.8.2.4, 3.8.2.5 and 3.8.2.6 of the Catawba Nuclear Station FSAR. 1 Containmant vessel shell plate and penetration sleeves'were fabricated. by Newport News Industrial Corporation under DPC Specification No. CN.S-1144.- i 09-00-0001 with revisions 1 through 6 as applicable. . Under requirements of i ~ this specification the containment vessel shell plate material was produced - from SA-516 Grade 60 material. Penetration sleeves were required to be produced from seamless SA-333 Grade 6 and/or SA-516 Grade 60 material. These materials were specified to meet the requirements of Subsection NE of i ASNE Boiler and Pressure Vessel Code, Section III. Material for the i vertical stiffeners was specified as SA-36 modified flat bar stock.
! Section 3 of Specification SA-516 Grade 60, stipulates that material supplied to the specification is required to conform to SA-20, which out-lines testing requirements, permissible variations in quality and repair of
- defects. Section 9.3.1'of SA-20 states in part that laminar type discon-l tinuities one inch and less in length visible to the unaided eye on the j edges of the plate as prepared for shipment by the manufacturer.are accept-i able and do not require exploration.
Impact test requirements of paragraph NE-2350 of Code subsection NE'were y. required for all material, except the base liner plate and its embedments. j All welding was specified to be performed by welding procedures and welders f qualified under the requirements of S.ection IX ' of the ASME Boiler. and - l Pressure Vessel Code. All vendor welds were required to be full penetration groove welds unless otherwise. approved by the owner. Containment shell plate thickness varies according to elevation. -Between elevation 550' and 564', plate thickness is approximately one inch and from 554' to 663'-9" plate thickness is approximately 0.75. inches. ' The hemi- ; spherical dome is approximately 0.688 inches thick, j Within these areas the inspector reviewed randomly selected certified mill test reports in order to' ascertain whether material thickness, and chemical and mechanical properties- met minimum requirements of ~ the aforementioned ASME Specifications SA-516.and SA-20; and whether the~ impact test. require- .- ments of Section III of the ASME Boiler and Pressure ~ Vessel ' Code were met.
~
t Other documents reviewed for reasons stated earlier included -vendor weld-history records, magnetic particle test results and repair records.- Two 2
- installed penetrations, 2M-406 and 2M-407, were selected for review of field
- weld process control records. Theireview focused .on welds 2NI-16-1 and 2NI-15-1, which joined each of the above penetrations to the. appropriate 32" j
- diameter containment penetration sleeve. These penetrations were
- situated.
- parallel to each ~other at the 557 elevation, ~1n containment shell plate -
l 2-2-6. I i 4 y . .., . - , * , ...y,+e. , w v - - - - . - . - ,me., .e y m' 7 In.--wv--m,,ey-+, e ,--r-- , e~., .ww+,,-O+.y.E,- T--e ,w%+r c -ww + gr e-
3 The record review of the weld process control records'(M-4A) indicated that laminar type indications were found on the weld prepped surface of both containment penetration sleeves. This condition was more prevelant in the case of weld joint 2NI-15-1 and therefore, required additional effort to - identify, remove and repair the weld prepped surface to an acceptable condition. Also, the review revealed that following several repairs for fabrication type defects and laminar type discontinuities, both joints were radiographed and found acceptable per ASME Code requirements. Other penetration sleeves designated as spares by the licensee were observed by the. NRC inspector for evidence of laminar discontiniuties. These sleeves were made of 12" diameter schedule 100 material and were identified as follows: Penetration Stage of Fabrication 2 POE-227 Tacked 2 P0E-239 Tacked 2 POE-241 Complete 2 POE-242 Tacked 2 P0E-251 Weld prepped only The inspector requested and the licensee agreed to perform a negnetic particle inspection on penetration sleeve 2 POE-251 for laminar type indi-cations on the weld prepped surface of the sleeve and none were found. This inspection effort found that laminar type indications have been identified in the containment vessel shell penetration sleeves. These discontinuities are addressed in the applicable ASME specification which places no minimum requirements / acceptance criteria on their size and/or population except when they appear at the edge of the plate. When this condition appeared the licensee identified it and took appropriate steps to correct the condition, thereby complying with code requirements.
~
Laminar discontinuities are common in rolled plate material. These discontinuities or laminations are non-metallic inclusions made-up primarily of residues from additions which are made to liquid steel to improve the product by reducing the oxygen content and refining the grain structure. They are progressively elongated longitudinally and spread laterally parallel to the rolled surface to varying degrees, depending on the method of rolling, as the material is rolled into plate or shape. The rolling process used to shape structural steels produces the greatest strength and ductility in the longitudinal and transverse directions which are of utmost importance to structures. However, laminar discontinuities usually reduce ductility of the material in the thru-thickness direction. Therefore, in that existing and anticipated loads on the Catawba containment produce stresses in the plate, which are parallel to the surface of these discontinuities, their presence would not be expected to compromise the integrity of the containment vessel or endanger the health and safety of the general public. No deviations or violations were identified.
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