century industries p.o. box 17084, bristol, virginia 24209

43
, Century Industries P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-1864/276-628-7553 July 20, 20 II u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject: Reply to a Notice of Violation dated June 23, 2011 Century Industries (CI) appreciates the time and attention the NRC Inspection Team and staff has extended to us to complete the inspection and assessment ofCI's NRC-approved Quality Assurance (QA) Program, starting with the July 20-23, 2010 inspection and ending with an April 19-21,2011 inspection. CI remains committed to meeting all requirements of 10 CFR 71 Subpart H, and provides the following response to the Notice of Violation. With regard to the six items included in CI's violation of 10 CFR 71.111, we respond as requested: 1. CI's QA Manager is absent the majority of the time from the ongoing activities and CI's program has no description of delegation for the QA Manager's responsibilities or actions. The QA Manager is only present at the CI facility one or two days per month Reason for the violation - CI hired an interim QA Manager in April 20 lOin response to USNRC Inspection Report No. 71-0947/2010-201 and the Inspection Team's conclusion that quality assurance independence was lacking in the Century Industries QA program. However, the interim QA Manager was not able to be at the facility on a full-time basis, therefore resulting in the delegation of responsibilities and actions, which had not been properly documented. CPs Corrective Action and Results - As submitted in an April 30, 2011 response (attached) to the April 19-21 , 20 II inspection, a full-time QA Manager was hired. An April 30, 2011 letter announcing this action and summarizing qualifications, including a resume, is part of the response's attachments. CPs Action to Avoid Recurrence - A full-time QA Manager will always be a part of the Century Industries QA Program. Fun Compliance Achieved - April 30, 2011 2. CI's weigh scale used to weigh packages was found to be out of calibration for approximately 3 weeks. Reason for the violation - The platform scale used for weighing finished packages was purchased from Carlton Scale in December 2010 and had not been placed on the calibration calendar.

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Page 1: Century Industries P.O. Box 17084, Bristol, Virginia 24209

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Century Industries P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-1864/276-628-7553

July 20, 20 II

u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject: Reply to a Notice of Violation dated June 23, 2011

Century Industries (CI) appreciates the time and attention the NRC Inspection Team and staff has extended to us to complete the inspection and assessment ofCI's NRC-approved Quality Assurance (QA) Program, starting with the July 20-23, 2010 inspection and ending with an April 19-21,2011 inspection. CI remains committed to meeting all requirements of 10 CFR 71 Subpart H, and provides the following response to the Notice of Violation.

With regard to the six items included in CI's violation of 10 CFR 71.111, we respond as requested:

1. CI's QA Manager is absent the majority of the time from the ongoing activities and CI's program has no description of delegation for the QA Manager's responsibilities or actions. The QA Manager is only present at the CI facility one or two days per month

Reason for the violation - CI hired an interim QA Manager in April 20 lOin response to USNRC Inspection Report No. 71-0947/2010-201 and the Inspection Team's conclusion that quality assurance independence was lacking in the Century Industries QA program. However, the interim QA Manager was not able to be at the facility on a full-time basis, therefore resulting in the delegation of responsibilities and actions, which had not been properly documented.

CPs Corrective Action and Results - As submitted in an April 30, 2011 response (attached) to the April 19-21 , 20 II inspection, a full-time QA Manager was hired. An April 30, 2011 letter announcing this action and summarizing qualifications, including a resume, is part of the response's attachments.

CPs Action to Avoid Recurrence - A full-time QA Manager will always be a part of the Century Industries QA Program.

Fun Compliance Achieved - April 30, 2011

2. CI's weigh scale used to weigh packages was found to be out of calibration for approximately 3 weeks.

Reason for the violation - The platform scale used for weighing finished packages was purchased from Carlton Scale in December 2010 and had not been placed on the calibration calendar.

Page 2: Century Industries P.O. Box 17084, Bristol, Virginia 24209

CPs Corrective Action and Results - As submitted in an April 30, 20 II response (attached) to the April 19-21,2011 inspection, a nonconformance report (NR 0016) was initiated. The scale was removed from service, sent to calibration, and found to be without need for adjustment. No further action was required, since the scale was in calibration, and it was returned to service. The NR, Discrepant Equipment Report, and calibration results are included in the attachments of the April 30, 2011 response.

CPs Action to Avoid Recurrence - The scale was added to QC' s calibration calendar.

Full Compliance Achieved - April 25, 2011

3a. Receiving inspection records of various components (tubing and flat bar) did not conform to a purchase order requirement. Specifically, ASTM AIDII material was supplied instead of ASTM A36.

Reason for the violation - There was a lack of attention by QC receiving to the details required by the purchase order and review of the specified documentation received.

CPs Corrective Action and Results - As submitted in an October 11,2010 response to the September 28-30,2010 inspection, a nonconformance report and corrective action report (NR 0012 and CAR 0019 - both attached) were initiated. An internal review of the material was completed and found that the ASTM A I 0 II material was identical in material and chemical properties with ASTM A36 material. A dual certification of this material was obtained from the rolling mill through the supplier, and the product was accepted for continued use.

Cl's Action to Avoid Recurrence - Additional training was provided to QC Receiving and Purchasing personnel to stress the importance of adherence to all purchase order and material requirements, and the addition to future purchase orders that no material substitutions are allowed.

Full Compliance Achieved - September 30,2010

3b. CI's manufacturer of polyurethane closed cell foam failed to record the correct lotlbatch numbers of materials used in production and record production data on a correct version of a form (UF-I Revision I vs. Revision 5).

Reason for the violation - A lack of communication to the manufacturer and a lack of training to QC Receiving was found to be the cause in receipt of the polyurethane closed cell foam with incorrect and insufficient data.

CPs Corrective Action and Results - As submitted in a May 9, 2011 update (attached) to the April 19-21, 2011 inspection, a corrective action report (CAR 0025 - attached) was initiated. A review of all receiving reports for the foam was completed and any incorrect and/or incomplete records updated, as necessary, to include documentation required by Century Industries. In addition, CI has developed a checklist (attached) to be used as an aide in the receipt of future foam deliveries for the Versa-Pac.

Cl's Action to Avoid Recurrence - The Versa-Pac Foam Receipt Inspection checklist was developed and additional instruction was given to QC receiving to ensure that there is a full understanding of the requirements.

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Page 3: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Full Compliance Achieved - May 6, 2011

4. CI welders were not qualified to American Welding Society (AWS) DI.3. This primarily had impact upon the 16 gauge sheet metal used as the liners for the product.

Reason for the violation - The welders were not qualified to A WS Dl.3, Structural Metal Code­Sheet Metal, although there is a sheet metal component in the Versa-Pac, due to an oversight by CI.

CPs Corrective Action and Results - As submitted in an April 30, 2011 response (attached) to the April 19-21, 2011 inspection, a nonconformance report and corrective action report (NR 0013 and CAR 0021 A - both attached) were initiated. Welders were qualified to A WS D 1.3 to meet this requirement.

CPs Action to Avoid Recurrence - Quality Assurance will provide additional reviews of all contract requirements to assure that welding is conducted in accordance with the applicable specification and that all welders are qualified in accordance with the necessary standards.

Full Compliance Achieved - April 25, 2011

S. CI failed to conduct a Welding Procedure Qualification test and generate Weld Procedure Specification (WPS) for dissimilar metals. Specifically, the welding of the Versa-Pac nameplate to the drum of the finished package.

Reason for the violation - The nameplate on the Versa-Pac is stainless steel, while the rest of the package is carbon steel. This was an oversight by CI.

CPs Corrective Action and Results - As submitted in an April 30, 2011 response (attached) to the April 19-21, 20 II inspection, a nonconformance report and corrective action report (NR 0014 and CAR 0022 - both attached) were initiated. A Welding Procedure Qualification Test was conducted for welding dissimilar metals, a WPS was written, and a welder was qualified to the WPS.

CPs Action to Avoid Recurrence - As part of the Quality Assurance review of future projects, welding requirements will be reviewed to assure compliance with the product specification.

Full Compliance Achieved - April 25, 20 II

6. Voltage of a GTA W process on production components deviated from a WPS. The voltage was observed to be 10 and 13 volts on contact, contrary to the WPS which states the bottom range of the WPS as 13.5.

Reason for the violation - The voltage of a GT A W process was out of the range specified in the WPS due to the difference in arc length and contact distance of the equipment currently in use versus the equipment used to create the WPS.

CPs Corrective Action and Results - As submitted in an April 30, 20 II update (attached) to the April 19-21,2011 inspection, a nonconformance report (NR 0015 - attached) was initiated. A WS Dl.I Section 3.6 allows for revision of the WPS to address variables within the procedure including voltage. The WPS was revised to provide an acceptable range for the equipment currently in use.

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Page 4: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Cl's Action to Avoid Recurrence - A memo was issued to both QAJQC and Production providing additional instruction on the importance of checking all welding parameters as a matter of practice in order to prevent recurrence.

Full Compliance Achieved - April 25, 20 II

Respectfully submitted,

Heather N. Little Quality Assurance Manager

Reviewed By:

William M. (Mike) Arnold President

Cc: Mr. Eric 1. Benner, Chief Rules, Inspections and Operations Branch Licensing and Inspection Directorate Division of Spent Fuel Storage and Transportation Office of Nuclear Safety and Safeguards

QA File

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Page 5: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries

April 30, 2011

u.s. Nuclear Regulatory Commission Mr. Earl Love, Safety Inspector Rules, Inspections and Operations Branch Licensing and Inspection Directorate Division of Spent Fuel Storage and Transportation Office of Nuclear Safety and Safeguards Washington, D.C. 20555-0001

P.O. Box 17084, Bristol, Virginia 24209. Phone: 423-646-18641276-628-7553

RE: USNRC Inspection of Century Industries QA Program

Century Industries Statement

Dear Mr. Love,

Century Industries is pleased to provide this update of actions taken regarding the inspection of Century Indnstries facility in Johnson City, TN. and our QA Program. This infOlmation is provided based upon the post audit meeting and comments made during the inspection. We hope that this information will show the efforts being made to address your concerns and continue to improve our overall program.

1. As discussed, we understand the concerns of a long distance, interim QA Manager and have taken immediate actions to rectifY the situation. We have promoted to full time Quality Assurance Manager, Ms. Heather Little effective immediately. See our attached letter.

2. Welder qualification for AWS Dl.3 Sheet Metal-NR # 0013 was written to reflect that CI welders were not properly qualified in accordance with A WS 01.3. This primarily had impact upon the 16 gauge sheet metal used as the liners for the product. Welders were given sheet metal qualification tests and results found acceptable. The results, NR and justification for acceptance will be sent in a separate e-mail on Monday for your review.

3. Weld Materials- NR # 0018 - As noted during our post audit we have previously purchased welding materials as shop supplies in an open agreement with our supplier. These materials were maintained within our lock tool room and accessed by the production worker through welding chits and our Production Superintendent. All welding materials for the Versa-Pac, although not required, are being maintained as traceable through the use of heat number verification and recorded upon the Fabrication Control Record as you have verified. We have now instituted the process of directly purchasing the welding materials and have performed a vendor survey of the welding supplier and place them on our A VL. The results, NR and justification for acceptance will be sent in a separate e­mail on Monday for your review.

4. Drawing revision - During the inspection it was discussed that tack welds being applied to the Bar BF to Sheet PA were not detailed properly, in that the detail on the fabrication drawing showed a 118" weld along the bottom edge of bar BF and noted that welds were to be "Tack Weld" with no · minimum size or minimum quantity noted in the welding symbol. These drawings are currently being revised to reflect the appropriate detail requirements. We are also incorporating some additional

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Page 6: Century Industries P.O. Box 17084, Bristol, Virginia 24209

comments such as removing the AiR (As-Required) from weld details regarding the grinding requirements for certain weld joints. Drawing revisions will be sent later in the week for your record.

5. Y-12 Vendor Survey Report- As part of the follow-up to previous inspection activities it was requested that we provide a copy of an inspection report from one of our customers, in particular Y -12. As noted during the inspection although we have supplied 50 packages, the customer does not leave any QAlQC Inspection report due to their internal policies regarding these reports. We did provide a copy of an E-mail from the inspection group during your visit and as reported, a copy of the report can be obtained from YI2 through direct channels. A Copy will be sent on Monday.

6. Carlton Scale - A VL - NR # 0017 - An NR was written to report that the provider of calibration services for the floor scale was not listed on the A VL. Carlton Scale provides calibration services for CIon the floor scale. Since the inspection Carlton scale has been evaluated and placed on the A VL. The acceptance was based upon their history providing these services, traceability to NIST and conversation with their corporate QA personnel. Carlton Scale is accredited by the Laboratory Accreditation Bureau under ISOIIEC 17025 :2005 Certificate Number: L II 05-1. The results, CAR, Certificate, NR and justification for acceptance will be sent in a separate e-mail on Monday for your reVIew.

7. Updated Schedule - A copy of the update production schedule was provided during your visit showing the 50 nits were provided to B&W Y-12 and that an additional 50 units were still to be delivered by the end of May. 10 of those units are on the floor ready for inspection this coming week and 10 more are scheduled for completion by weeks end A copy of the update will be sent in the Monday E- mail.

8. Out of Calibration Scale - NR # 0016 - During the inspection the floor scale calibration date was found to be out of date by approximately 3 weeks. The scale was used to weigh 10 packages previously shipped, the scale was removed from service and sent to calibration and found to be in calibration without need for adjustment. Investigation of this oversight was due to the scale not being placed on the calibration calendar. It was a new purchase in December and was up for its' initial recalibration service. Because the scale was found in calibration no fwther action was required The scale has since been returned to service. The results, Discrepant Equipment Report, Calibration Record, NR and justification for acceptance will be sent in a separate e-mail on Monday for your reVIew.

9. Certificate of Compliance for Steel Purchase Orders - As suggested, we are instituting a practice that requires the suppliers of our steel components (plate, Sheet & Shapes) to provide a Certificate of Compliance listing the requirements of our PO to include compliance with Part 21, Compliance to the PO, compliance to the latest copy of their QA program and revision and that no repairs have been made to the materials provided. This will help close the loop between the material manufacturer, the distributor and CI in the review ofMTR's and overall compliance of the order.

10. BMG Metals PO missing a Signature - The copy of the PO reviewed during the inspection was found to be the shop copy used for receipt and does not bear the signature or costs. We have included a copy of the signed PO for your reference and review. This copy was located in the file and had the appropriate signatures in place. Copy will be sent with Monday's E-mail.

11. Chemical Foam Self Life Foam - A copy of the technical data sheet from NCFE Polyurethanes provided by American Foam for the resin used in the fabrication of the Versa-Pac foam products shows the resin shelf life is 6 months. All products provided were fabricated within the self life of the product. A copy will be sent with the Monday E-mail.

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Page 7: Century Industries P.O. Box 17084, Bristol, Virginia 24209

12. WPS Out Range Voltage - NR # 0015 - During the inspection is was discovered that the voltage of the GT A W process being utilized to make welds on blind nut components to their flanges was out of the range listed on the WPS. Voltage is partially a control of arc distance to welding surface and equipment used in the process. The voltage was found to be between 10 and 13 volts on contact. AWS Dl.I provides a 25% tolerance for the GTAW voltage without revision to the procedure, the bottom range of the WPS was 13.5. In order to comply with the specification the WPS was revised to provide an acceptable range for the equipment being used. A WS Dl.1 Section 3.6 allows for the revision of the WPS to address variables within the procedure including voltage. The correction was made to the applicable WPS. All packages were inspected and found acceptable and the results recorded on the FCR's. The results, Memo, NR and justification for acceptance will be sent in a separate e-mail on Monday for your review.

13. A VL - The A VL was updated to include the addition of both Carlton Scale and Holston Gases. The form revision was mistakenly changed from I to 2 during other updates to the A VL. It has been corrected in additioD- The new A VL will be sent with the Monday E-mail.

14. SOP 9.9 - Previously Inspected - As an outstanding item to verify from the past inspection the requirements of 10CFR 75 were added to the SOP, It has been suggested that we add additional detail to the requirements within the body of the SOP to better describe the requirements. This will be addressed by Ms. Little during her review and revisions to the QA Program. A copy will be forwarded once completed.

15. SOP - SAMPLE FORMS - During the inspection a review of sample forms attached to the original SOP's it was noted that the Watermark or the word Sample n top of the form was not fully legible on the form reviewed. We have reviewed all SOP' s in the original file and made adjustments. We located I or 2 additional forms with watermarks partial obscured, other than those indicated during the inspectioD- Both revision and attachments will be part of Ms. Little's review process. A letter will be sent to your office once completed.

16. SOP 5.0 - We are in the process of adding specific AWS specification numbers to the welding series of SOP's, as suggested and also providing additional information for the welder to the general welding specification in SOP 5.0. A letter will be sent to your office once completed.

17. DissirnilarMetal Welding Procedure Missing - NR # 0014 - The Versa-Pac nameplate is attached to the outer skin of the finished package by spot welding the comers of the stainless nameplate to the outer surface of the carbon steel drum. Century Industries failed to conduct a Welding Procedure Qualification Test and subsequent WPS for the dissimilar metals prior to conducting the operation. This has no impact to the end product usage or design of the package. Since the inspection Century Industries has conducted a procedure qualification test, written the WPS, and qualified the welder making the nameplate spot welds using the WPQR as his weld test. The results, CAR, WPQR, WPS NR and justification for acceptance will be sent in a separate e-mail on Monday for your review.

As the team indicated during the inspection we have worked diligently to steadily improve our workmanship and have a quality product. We are as committed to meeting the requirements and expectations of our Quality Assurance Program as producing a quality end product.

NOTE: AIl backup documents will be scanned into a pdf file and sent by a separate E-mail on Monday.

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Page 8: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Respectfully submitted,

William M. (Mike) Arnold President Phone: 423~6-8164 E-mail: CenturvlndWMA(@.aoLcom

File Cc: QA File Mr. Jim Pearson - Sr. Transportation Inspector Mr. Clyde Morell - Transportation Inspector Mr. Pierre Saverot - Project Manager Ms. Heather Little - Century Industries QA Manager

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Page 9: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries

April 30, 2011

u.s. Nuclear Regulatory Commission Mr. Earl Love, Safety Inspector Rules, Inspections and Operations Branch Licensing and lnspection Directorate Division of Spent Fuel Storage and Transportation Office of Nuclear Safety and Safeguards Washington, D.C. 20555-0001

P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-18641276-628-7553

RE: Century Industries Quality Assurance Manager Appointment

Dear Mr. Love,

Century Industries is pleased to announce the promotion of Ms Heather Little to the position of Quality Assurance Manager. Ms Little has accepted the position which will be effective immediately. She takes over the position, which has been held by the interim manager, in !l full time capacity.

Ms Little brings to the position a substantial resume, which includes history as a waste management specialist for Nuclear Fuel Services in Erwin, Tennessee and a Regulation Specialist for Eco-Pak Specialty Packaging and Nuclear Containers in Elizabethton, Tennessee. She has a B.S. Degree in Environmental Health from East Tennessee State University and has been involved on several committees within the industry. She has also completed several additional courses in associated industry training. Ms Little worked directly for me at both Nuclear Containers and Eco-Pak where she became familiar with all aspects of the QA Program through direct daily involvement. In recent years she has worked as both a contractor for Century Industries and previously as Purchasing Manager.

As full time Quality Assurance Manager, Ms. Little will have the full support of Century Industries management.

William M. (Mike) Arnold President Phone: 423-646-8164 E-mail: [email protected]

Attachment: Heather Little Resume'

File Cc::QA File

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Page 10: Century Industries P.O. Box 17084, Bristol, Virginia 24209

OBJECTIVE

Heather N. LiHle 107 Meadow View Farms Drive

Jonesborough, TN 37659 Telephone: (423) 612-6015/ Email: [email protected]

Career specializing in the interpretation, implementation and compliance of the U.S. Code of Federal Regulations, including the transportation, energy, environment and labor regulations.

EXPERIENCE REGULATIONS SPECIALIST May 2008-Self-Employed Contractor to Century Industries March 2010 Report to William M. Arnold - Assisted with testing the 55-Gallon Versa-Pak and writing its Safety Analysis Report. - Assisted with the operational startup for manufacture of the Versa-Pak: through review and revision of the Standard Operating Procedures.

WASTE MANAGEMENT SPECIALIST September 1999-Nuclear Fuel Services, Inc., Erwin, TN February 2005 Report to Dennis Seagroves, Waste Programs Administrator and Joseph W. Pugh, Transportation and Waste Manager - Responsibilities include: Assure compliance with the Envirocare of Utah and Hanford Disposal Site Waste Acceptance Criteria through Bldg. 234 Decommissioning Operations support and training, authoring procedures, LOAs, SWls and the Class C Waste Certification Program Plan, obtaining waste profile approvals, and completing and maintaining all paperwork required for Class A and Class C waste shipments. - Interface with KAPL and SNR representatives for Class C and Transuranic (Greater than Class C) waste issues. - NFS technical contact for Hanford Disposal Site for Class C waste and WIPP/SRS for Transuranic waste, which includes coordinating and assuring successful verification of waste destined for Hanford and compiling the Transuranic Waste Baseline Inventory Report for WIPP. - Performed evaluations for waste packaging, transportation and disposal options for all Building 234 waste, which includes the packaging, transportation and waste profile approval for disposal of the DVRF Shear Baler, a 40-ton piece of equipment. - Submitted RFQs and PCRs for packaging and disposal. - Completed mixed mercury waste shipments and assisted with other hazardous waste shipments. - Headed and served on TapRoot investigations. - Maintain MBA 9 as a custodian representative for MC&A.

REGULATIONS SPECIALIST Eco-Pak Specialty Packaging, Elizabethton, TN A Division or The Columbiana Boller Company, Columbiana, OH

May 1997-

September 1999

Self-employed Colftractor to The Columbiana Boiler Company (ApriJ-September 1999) Report to Mr. William M. Arnold, ESP President - Responsibilities include: U.S. Department of Transportation & Nuclear Regulatory Commission Regulations Specialist,

Page I 00

Page 11: Century Industries P.O. Box 17084, Bristol, Virginia 24209

EDUCATION

ACTIVITIES <:areer-llelate<i

Heather N. Little 107 Meadow View Farms Drive

Jonesborough, TN 37659 Telephone: (423) 612-6015/ Email: [email protected]

Environmental Health and Safety Manager, Nuclear Package Licensing, Package Research & Development, Divisional Worker's Compensation Manager and Drawing Controller. - Regulatory and Technical Advisor for colleagues and customers regarding the patented Eco-Pak® PG-I exempt portable tank for the transport of Packing Group 1 and PIH (Toxic) liquids, as well as other hazardous material packaging. - Completely modified the exemption (DOT-E 11167) in 1998 to increase the working pressure, add a new design, and include Packing Group I materials from five new classes. - Develop test programs, test and submit safety analysis reports for hazardous material, including radioactive, packaging designs. - Correspond and meet with U.S. Department of Transportation and U.S. Nuclear Regulatory Commission officials. - Established a written safety program and organized the necessary safety training. - Responsible for all Hazardous Waste Disposal and maintain all Air Pollution, Hazardous Waste and Solid Waste Permits. - Editor of a quarterly technical newsletter, ESP NEWS. - Trained to assemble bid proposals for packaging.

OSHA & REGULATIONS SPECIALIST Nuclear Containers, Inc., Elizabethton, TN Report to Mr. William M. Arnold, Operations Manager - Responsibilities include: Same as above.

B.S., ENVIRONMENTAL HEALTH Emphasis: Occupational Health & Safety East Tennessee State University, Johnson City, TN

DOE/ORO Advanced Radioactive Materials Packaging and Transportation, Oak Ridge, TN McCoy RCRA Course, Erwin, TN Most Recent RCRA Refresber, February 2004 Waste Designation Training, Washington State Dangerous Waste RegUlations FrontPage 2000, New Horizons Computer Learning Center ISOCS Equipment/Software, Canberra Industries 40-Hour HAZWOPER Most Recent 8-Hour HAZWOPER Refresher, March 2003

May 1994-

May 1997

May 1994

August 2004

April 2002

November 2000

July 2000

May 2000

November 1999

HMAC MEMBER, Hazardous Materials Advisory Council March 1995-

UN Interet Committee, Focuses on international organizations, such as the IMO, UN Recommendations, ICAO and lATA NARLA Com mitt"", Focuses on North American Hazardous Materials Regulations

HM-181, HM-215A & HM-126F COURSE Environmental Resour<e Center, Myrtle Beach, SC

Page 2 of3

Sept. 1999

January 1996

Page 12: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Heather N. Little 107 Meadow View Farms Drive

Jonesborough, TN 37659 Telephone: (423) 612-6015/ Email: [email protected]

URANIUM HEXAFLUORIDE CONFERENCE: Processing, Handling, Packaging, Transporting Institute of Nuclear Materials Management (INMM), Paducah, KY

DESIGN GUIDE PACKAGING WORKSHOP u.s. Department of Energy National Defense Programs, Pigeon Farge, TN TENNESSEE SAFETY CONGRESS American Society of Safety Engineers, Nashville, TN

Page 3 of3

November 1995

October 1995

July 1995

Page 13: Century Industries P.O. Box 17084, Bristol, Virginia 24209

(

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". ~Y"p~' ' " ., "';.''' '_7; ., 'I,':;' ' ~ .• ~ Ji~' ~

Nonconformance Report- D21 .+:: ~

_1J'Rl Rev. 1

Nonconformance Report (NRI JI:_-'OO=1::..;:6 ______ _

Contract· 10·0007 8&W Y-12

Century Industries

Date'

P.o. Box 17084 Bmtol. VA 24209

423·646-1864

04-20-11

Compon~t: 55 gallon Versa-Pac Customer P.O.: 4300075777

Part: Finished Package

Dwg. No.: SSvp·OOI Rev. 3 Piece Mk.: 10576 thru 10625

Other:

DESCRIPTIO!f OJ' NONCONFORMANCE: (attachment., _ Describe nonconfonnance in detail using sketches, drawings. etc. as reqUired;

The scale used for weighing the finished package was found to-out of eallbration. The due date was 03-22-11-

and was utilized to weigh 10 packages shipped to the end user.

Have scale calibrated by the appropriate vendor, if scale is still in calibration accept as is. 1.-J

t .:r;l\~~ ~~ If.:l.O-I' ~~r1- Lt- ~/) I - " U Ittoo y nate -anager Date A'Uil: r7~)7lt

Recommended disposition & basis for acceptance and corrective action taken to prevent recurrence. ,.u>PROVED DISPOSITION: (,Attachments: ~r ' k l)-.,,~. 'i&-'t- ~;t 1'>1 1\,

0 Repair" CAR Required: VesO No)( CAR No. 0 Scrap 0 Use as is·

SCAQ: 'h _If VesO No )( Part 21 Applicable: Ye.O No)(

X Accept as is ~ I r4jLKrI.~t QA Manager Approval: a k!2 I ,,", If Date: ~·o<.Z -

~,~, \ I,dot. -:-: >oJ. ~ ..... , 'rf-z../f II -CUstomer Approval (as ~ired': Date:

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tc-~~"'- . ~ ~ ~ . - ......;,;tL~ ~ ~ .. ~ (}~- ·j-~t- ~L~

Approved By: ~~ . ~ ____ Date: 4-- -:A5· I I Implementation Completed:

v),-/r Verified By: C-/t.(L Date: /

Page 14: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries P.O. Box 17084. Bristol. Virginia 24209 Phone: 423-646-1864/276-628-7553

Additional Technical Justification For

NR# 0016

Nonconformance Report Nwnber 0016 was written to report that the Floor Scale used for weighing the final product was found to be out of calibration by approximately 3 weeks. During this period 10 units were shipped to the customer. Once identified the scale was removed from service and immediately taken to the provider for recalibration. Upon inspection and calibration the scale was found not to require any adjustment and in calibration.

The investigation into the cause was determined to be failure to place the scale on the calendar for calibration. The scale had been purchased new in December of 20 1 0 and was due for its initial recalibration.

This non-compliance had no impact upon the end product results.

William M. (Mike) Arnold President

Page 15: Century Industries P.O. Box 17084, Bristol, Virginia 24209

,

Century Industries

D1SCREPABT CONDITION:

P.o. Box 17084 llriatol. VA 24209

423·646·1864

Identify equipment, describe discrepancies. identify any known material or fabricated products affected by the discrepancy (indicate none if such is the case), include recommendations if any for correction of the uiscrepancy and I or correction of material or fabricated products alIected by the discrepancy.

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;-I S-S- "t!::l ",act~ .K:C'J"J Jy .Q:a,!~ -</1- AfALei ~~ . ;;<II( .. I

-1-0/",.1 ;z>~~.s1 l''''''''~'' ,S.,.'/NI N",,_h,.s I () (.I?<I - L<> ~ IS- , eN ;If(. HtJo/b By: ~~ LtL rL~h"L/

Sign.uurc/TIt.1c oJte Send to QA Manager for Disposition - Remove Equipment from service and identify to prevent use until dispositioned.

D1SPOSlTIOI'I OF DISCREPANT EQUlJ'JllEIIT:

./i. .fl.'11 rfH ... 6 ... .1) :bc..c-4 ~~~~ Lv~ ,~O!. d.~ ~::!L. c....cnr~ ........... ~~AU~~ ~~\

:t.-~.bA~U By: l I u:= ~~\ tI:- 4- -1..../ - / J SlgnalU~ ITIUe Dole

D1SPOSlTIOH OF AFJ'ECTED I\IATERIAI.S

00:: ,,<<\~ ,~ I"'- " ~~\.C~ ~ ~~1

By: e-Id) "J" 0'1· ~. JI '12.. - .J.' \ I "'fLtu"'I.~A.7;!:fI ~'O, J>, . .4 ,..J • :r:? .... / II n.t.~...,~

\} • I

DlSCREPABT EQUlPMEl'fT BACK IN 8ERVIC~

.2?c",k ll.. - Gc-L.1,",A"~ ~ /tr- Al.~ By: 4- ~t;. , /

Signature DlHt:

APPROVED DISPOSITION 0,. AFFECTED I\IATERlALS IMPLEMENTED

Page 16: Century Industries P.O. Box 17084, Bristol, Virginia 24209

C' . RI- TON .....-A II.

SCALEW oJO; I:;l flIAL ~CALE ~ALE;; AND SEAVlCE

"I.I :~.: U Jllkf": 80311 ·" FN TJI f.: V fNO(JSTRIE S c· ,n. RO X 17084 gRI S TOL, VA 242D9

WORK TI CKET PRINT CARLTON GROUP, INC,

CARLTON SCALE - KNG WHSE 2041 BROOKSIDE LANE

KINGSPORT, TN 37660 PH 423-246-6853 FAX: 246-1289

Location: 1 CENTURY INDUSTRIES 19182 STERLING DRIVE ABINGDON, VA 24211

NO, V9 l S 19

Pag€" 1

ul. / ~ ·1 i 1 I

!ORDEREO !REOUESTEO!SLSP!TERMS !WH IFREIGHT!SHIP VIA

,oS ] I'l AR NOLD !04/21/11!04/21/11 1081 !NET 30 DAYS 108 !PREPAID!OUR TRUCK

Co n tact : MIKE ARNOLD phone n: 423-646-1864

••• IN S HO P CALIBRATION *** 1(0 / ".,<,," I e· Tf' : Equip!t' 28086 Lac 1&2:

" ,,,k· l l[' ,·, ,:c: SCALE/GENERIC - NEED ACTUAL MOOEL II <I N l a 2 : LI S T MODEL & SiN /

/ status: CAL

Tech: 081 Symptom : e.RO

.. _--- ----- -- --------------- ---- -- - - ----- - - - ---- - -- - ----- - ------ - - - - -- -l·'f 0tJ \ell! Oes cr'iption:

CAL I BRATE AND STICKER _._ ----- - ------------------------------------------------------ - - - - -

Oeser' -j pt i on Or'der'ed Pr-;ce Tota 1 UM Lo c

- - - --- - - ------- - - - - ----------------------------------------------- - .-I,I!' )'" k ~·· (·:· for · rn€_d

t e ::h

i~\S:: \' '''-,.~ c.. - \ \\,.

~<;J, '\\'\. '<;- c::.~e. ~L c.. 0,(' e <!. "-

;,/UU p)d:J-~ ~ >V75T-t~

- ---- - ----- - - ----- ------- -- -------------- -------Begin End IIHr's

----------- - --------Rate/Hr' Total D a t e Mileage Rate/Mi Total

--V ~ l' i ' -- .. - -- -- -- --------- -- -·- - - - ------------- - -------~~;~~l;-~:-~~ - -- .. -- _.

"i~ Vi fWE[\ ~ v :OAfE: CUSTOMER SIGNATURE'

PRINTED SIGNATURE:

Page 17: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Nonconformance Report (NR) It: 1012

Century Industries P.o. Box 17084

Bristol, VA 24209 423-646-1864

--------------------

Contract: 10-0003 & 0007 Date: 09-29-10

Component: Flat Bar Customer P.O.:

Part: Stiffening Ring FA & Top Band FB

Dwg. No. : CI -SSVP-003 Rev. 4 Piece Mk. :

Other: All 3/16" x 2 & 8" flat bar ordered under PO# 103009 supplied by Sisken Steel, Chattanooga, Tn.

~ESCRIPTION OF NONCONFORMANCE: (Attachments) !Describe nonconformance in detail using sketches, drawings, etc. as required.

[rhe material provided under PO#103009 & 103013, as applicable, were required to be supplied as A36, the Imaterial was supplied as A101l. The product was received, reviewed and used to produce components FA & FB, ,,"S noted above. The non-conformance revolves around the lack of effective review of the PO requirements upon !receipt and the failure of CI personnel to properly handle the non-conforming material supplied.

~~.~ '1 - 'J,'<1 - 1 ~ O--k fL f~ t/Lo Submitted By Date QA Manager Date

~ecommended disposition & basis for acceptance and corrective action taken to prevent recurrence. iAPPROVED DISPOSITION: Attachments: See technical justification below & Prevention action on CAR 0019)

0 Repair- CAR Required: Yes.tf NoD CAR No. 0019 0 Scrap 0 Use as is* SCAQ: Yes 0 Noi!1 Part 21 Applicable: Yes 0 No.1 z' Accept as is

c<-- t,(L 7[:,. t L """ QA Manager ApproVal: Date:

i**Customer Approval (as required): ..v k\- Date:

rrechnical Justification: The technical justification for the Accept As Is disposition if based upon the material phemical content and physical properties, which are identical in their requirements. Most importantly, this poncurrence has been validated by the producing mill providing a new certification with the material being dual pertified as the required A36 product required by the PO. A copy of the new certification MTR is attached.

Completed By: ~ 12~1~~> ~ Date: q - ~q - , C>

~mplementation Completed:

Verified By: a I<.[L Date: 'l/J'/w NR Closed By: C--k(L Date: 1/J~/'"

i

Page 18: Century Industries P.O. Box 17084, Bristol, Virginia 24209

}

·.

Century Industries

Corrective Action Report (CAR) # _-'0"'0"-1"'9<---___ _

Contract: 10-0003 & 0007

Dwg. No.: CI-55VP-003 Rev. 4 Pc. Mk:

Date:

P.o. Box 17084 Bristol, VA 24209

423-646-1864

09-29-10

NR Ref. No.: 1012

Description of condition, responsible job function, and probable cause: SCAQ: oYes !/('No

Material required on PO was A36. received. accepted and produced components with AIOII Material. Failure to properly identified wrong material grade stated on PO. The responsible job function is QC receiving. Lack of attention to the details required by the PO and review of the MTR received.

Recommendation for correction: Conduct an internal technical review of the material specifications as found in the applicable ASTM Specifications to determine potential evaluation method. Conduct additional training of inspection & purchasing personnel to emphasize the importance of a complete and through review & compliance with the PO in addition to other receiving requirements. Notify the steel supplier and discuss the importance of strict adherence to the PO requirements. Request a review by the steel mill to evaluate the materials for dual or re-certification of the product to the appropriate specification in accordance with the PO.

QA Manager: G-- ~n. Date: '1 /1- "r 1<-0

Specified corrective action: 1. Conduct internal review of material for evaluation to reconcile A1011 to A36 acceptability. 2. Conduct additional training of QC and Purchasing PersonneL 3. Notify the Steel supplier that no substitutions are allowed . 4. Obtain dual certification from the steel producer thru the supplier. 5. Method to prevent recurrence is to require statement on future PO's that no substitutions are allowed

& that purChasing will check for receipt completeness .

Specified By: Iv)j"; ,>--~ • MA Date: 9 [?..q L / u

QA Mgr. Review: G-. {t;.{L Date: 9/" 'f L>-<>

ctions Taken: Completed the internal review and found that the material would meet the requirements of A36 . addition to the A I 0 II . QA meeting with QC & Purchasing Personnel was held to address the need for

dditional attention to all details of receiving and reviewed enhancement in the receiving process. Contacted the steel supplier (Sisken Steel). addressed the problem. now requiring that no material substitutions are allowed

d strict compliance with the PO is a necessity. Obtained & reviewed the new MTR which was able to be dual ertified. Material dual certification found to be acceptable by producing mill. new MTR supplied. Product ccepted for continued use.

ate Implementation Completed: 0.. -'3 0 - 1 b Verified By: -:-l..~==-",k-":LCL--,=,=:--=----,-:-_ _ -:-__ ethod Employed To Prevent Recurrence: Provide additional training to the QAjQC Receiving and

chasing personnel to stress the importance of adherence to all PO and material requirements & the addition o future PO's that no material SUbstitutions are allowed. Also. purchasing will check for receipt completeness.

Completed By: C-l<..rL

Page 19: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-1864/276-628-7553

MEMO

September 29, 2010

TO: Quality Assurance (Andy Ross), Heather Little (Purchasing) and Quality Control (Drew Sallee)

Subject: Internal Material Evaluation of ASTM A36 and A 10 11

During the review of MTR' s by the NRC it was found that a particular material supplied by Sisken Steel of Chattanooga, TN. was received and process as A36, but was in fact certified by the Collier Metals (The rolling mill) as AlOll Flat Bar.

We have reviewed the specifications of both A36 and AIOII and found that the materials are chemically identical and physically have the same requirements for tensile and yield strength.

We have requested that the supplier (Sisken Steel) request that the heat number in question 1099261, be dual certified as A36 and AlOl!.

This memo is also to serve as notice that addition training in of the requirements of material review and receipt be made and documented.

Material must be reviewed to assure that the material received meets the requirements of material ordered, in addition to the other items conducted in the review and acceptance of materials for use in products.

These items include, but are not limited to: 1. Material specification (Type) 2. Size 3. Quantity 4. Documentation 5. Chemical & Physical Analysis 6. compliance with the PO

Any materials found not meeting the requirements of the PO shall be placed on hold until proper resolution can be determined.

William M. Arnold President

Page 20: Century Industries P.O. Box 17084, Bristol, Virginia 24209

CoWe,. MetalsLLC 793 11'indsor So'eet, SW At/cmta, GA 30:P5

6/29/2010

Certificate of Conformance _________ ...J

Customer: Siskin

PO# C 52867-8 [tern Code

eM Master 146804 Gauge 3/16" Size 2.000 x 240.000

Description AlOll-07 - Type B Grade A-36 Heat# 1909261

Tensile 57,700 Yield 39,400 Elongation 21%

C Mn P 0 .05 0.84 0.024

Mo AI N (LOt 0.026 0.006

Chemical Analysis

S Si 0.001. 0.25

V !'ih 0.004 0 .002

Cu ;n o. 0.005

Ti

iq d :S

0.< 0.001

Ni 0.04

Ca 0.002.

The above stated information is a copy of test repOlts provided by our snpplier or independent labot'ator)' and is contained in our permanent records, or that the absence of same; the steel listed above was purchased by us to comply with the above stated .

Approved . b-.... ~.

___ rrz=:: ....

Cr o.oa

Page 21: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Collier Metals LLC 793 Windsor' Street, SW , It/unta, GA 30315

Certificate of Conformance _________ -'

Custoiner: 8isldn

PO# C 52787-8 Item Code

CM Master Gauge

146785 3/16"

Size 8.000 x 240.000

Description AWll-07 - Type B Grade A-36

Heat#

C 0.05

iVlo 0.01

Tensile ' Yield Elongation

1099261

Mn

AI

0.84

0.026

57,700 39AOO

21%

P 0.024

N 0.006

Chemical Analysis

S Si Cu So Ni Cr 0.001 0.25 0.11 0.005 0.04

V Nb Ti B Ca 0.0014 0.002 O.OOl 0 0.002

The above stated information is a copy of test reports provided by our supplier or independent labo ratory and is contained in our permanent records, or that the absent e of same; the steel listed above was purchased by us to comply with the above stated.

Approved .. ~-dr

o.o:!

Page 22: Century Industries P.O. Box 17084, Bristol, Virginia 24209

" .

Century Industries

May 9, 2011

u.s. Nuclear Regulatory Commission Mr. Earl Love, Safety Inspector Rules, Inspections and Operations Branch Licensing and Inspection Directorate Division of Spent Fuel Storage and Transportation Office of Nuclear Safety and Safeguards Washington, D.C. 20555-0001

RE: Inspection Update

Dear Mr. Love,

P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-1864/276-628-7553

Century Industries is pleased to provide this continuing update on the status of items discussed in the exit meeting and by additional correspondence since that meeting.

36

I have attached a copy of Heather's letter which addresses her review of document control including those items discussed during your inspection and the re-opening of CAR 1016 from a previous inspection fro your record and review.

I am enclosing a copy of CAR 0026 which was written to address the overall general inspection process and the items identified during the inspection. This also details actions taken to prevent re.currence and documentation of additional training given to the receiving inspector.

I notice that it is listed in your latest e-mail that the foam is a Category A component, the foam is categorized under the graded approach for the Versa-Pac as a Category B. We audit American Foam Technologies as a class A supplier for other reasons.

I am attaching a copy of CAR 0025 which addresses the polyurethane foam receiving issues. I am enclosing a copy of the updated receiving report which includes: PO, Receiving Report R2, AFT-CoC, AFT CoA, NCFI CoC for Components, Asland Chemical CoA for Flame Retardant, UF-I Production Records and the UF -I Density Record, We are waiting on updated records from the chemical suppliers showing the shelf life and the starting point for that time frame, I hope to have this information shortly.

Please find a copy of the Intertek Report receiving letter to complete the review of the qualification testing for the foam as noted in the exit meeting.

William M. (Mike) Arnold President Phone: 423-646-8164 E-mail: [email protected]

File Cc: QA File

Page 23: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Corrective Action Report (CAR) #: __ ----'O'-'O~2=-5=--___ _

Contract:'-'-______ ~G~e~n~e~r~al~F~o~a~m~R~e~c~e~w~in~gL_ ______________ __

Century Industries P.O. Box 17084

Bristol, VA 24209 423-646-1864

Date: 05-04-10

Dwg. No.: CI-VP-0004 Rev. Pc. Mk.: IB. IC & IG NR Ref. No.: N/A

Description of condition, responsible job fnnction, and probable cause: SCAQ: DYes DNo The foam components used in the manufacture of the Versa-Pac Shipping Containers were found to be in an unacceptable condition upon inspection. Although the CoC and CoA were correctly incorporated into the report the wrong production records were place in the file no anticipated density record req. by the SOP were found . QC/QA is responsible to ensure that the appropriate documents are received, inspected and approved prior to acceptance. The cause was found to be incomplete training for receipt of the foam.

Recommendation for correction:

iA complete review of all receiving reports for the foam components to ensure that the applicable and complete !ctocumentation is incorporated within the receiving report.

!\ dj . ---1,. I

QA Manager: ----;:::J-'-i -l'J.,-,,,,,,,.~-'...:.:=-!...rJ=--. _~#""",~Q:...,-=~ _____ _ Date: May 4. 2011

Specified corrective action:

!Review all receiving records for foam delivered to Century Industries by American Foam Technologies \and correct any incomplete records. Ensure that the Log/Batch Number Fabrication Records are correct land match the CoA numbers listed for each delivery. Incorporate the anticipated Panel Foam Density Irecord as required by the SOP and develop a checklist to utilize during the receiving of future orders.

Specified By: \. J.!....:\!\ . 'f\ .. '\. . ~\ Date: May04,20 11

QA Mgr. Review: __ -::-n4R:...Jo.,,-'-tL~"'A~J::r0::...:... "";£-I='~t+=:J;f,,I.& ____________ Date: May 04.2011

Actions Taken: All receiving reports for American Foam have been reviewed and updated as found inecessary, to include additional documentation required by the SOP, including the Panel Foam Density ~ecord, the Foam Fabrication Record, & Chemical Manufacturing CoC listing the product date to ensure lUlat end products were fabricated prior to the end of the shelf life of 6 months.

G,n addition Century Industries has developed a checklist to be used as an aide in the receipt of future oam deliveries for the Versa-Pac. This checklist and Receiving Record R2, is to be reviewed after

linspection receipt by the QA Manager or designee and co-signed with the receiving inspector.

Date Implementation Completed: May 5, 2011 Verified By: l.:4L\' ~, W Method Employed To Prevent Recurrence: Additional instruction has been given to receiving personnel

~o ensure that a full understanding of the requirements is incorporated into the pr;cess.

Date CAR Closed: May6.2011 Completed By: \\ (jd.~ " "J . ----t.ti 0<

Page 24: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries

Versa-Pac Foam Receipt Inspection Checklist

This checklist should be utilized to aide in the completion of the Standard Inspection Receiving Form R2

R ecelVlD1!: D ate: PON 0.: Item Descriotion Yes Incomplete

1 Is Certificate of Compliance in accordance with Purchase Order?

2 Is Certificate of Authority properly completed?

3 Do Bun numbers match the match the production foam record?

4 Are the production foam records attached?

4 Is the foam density record attached?

5 Do polyurethane certificates indicate shelf life dates that are within the 6 month widow for use in fabrication of

the foam on the production foam record?

QC Receipt Inspector: _______________ Date: _____ _

QA Review By: _________________ Date: _____ _

"

Page 25: Century Industries P.O. Box 17084, Bristol, Virginia 24209

~ ...... _ _ l' .... p--.~"" ,-,<- ,, ' .~ .. ,,,.....(,,, • • ~ ";'~.1''' <,'"':. . , '.-' -__ ,,~.,""~~~

JfonconfO':FDJanCe' Report :"1>21"< UiR~ Rev. 1 Nonconformance Report INR) #:_-=00=1:.:3=--_____ _

Contract: 10·0007 B&W Y·12

Century Industries P.o. Box 17084

BrilStol, VA 24209 , 423·646.1864

04-'1!Hl

Component: 55 gallon Versa· Pac Customer P.O.,-: __ -,4",3",OOO=7!.:.5",,7~7~7,-__

Part: Liners FC & SA, Lid Camp. SB & SC

, Dwg, No.: 55VP·001 & 003 Rev. 7 81; 6 Piece Mk.: 10562 tbru 10571 81; 10576 thru 10625

Other:

inESClUPTIOli OP lfOlfCOlOl'ORJlAKCE: (attachmeDiB' , , Describe nonconformance in detail using sk<!tches. diawings, etc. as required.

The welder qualificatinns are not in accordance with AWS 01.3. All welders were qnaljfje(l.in accordance

!with AWS 0.1.1 whicb provide" qualification down to l/S" in thickness. The components in que:stjon are 16 j

\gauge sheet and should be welded by personn,,1 qualified with the appropriate apeci/ication. . A \l..y2. ~ 1'-,/1 r

l.1ilL", b.\ 1 ~ 4--1 q - I I .Ii .ill.. fp;J t; ;;;;;rA/"'/' I

SUbmitted By Date QA Manager Dote

iRecommended disposition & basis for acceptance and corrective action taken to prevent recurrence. !APPROVED DISPOSITIOlf: .IAttaohmellU: I

D Repair" CAR Required: Yes X NoD CAR No. 00214, D Scrap

D Use as is* .fr, iSC;AQ1:'.~ Yes D X Accept as j. , { t f'L' . ';. r,./,.., ...

loA Manager Approval: I . ... ' _' , V. U''<:' h.*' U"/< ~evi~' 'I ' ;;\. !;/2..f /I

!"'eustomer Approval (as ' d): '

NoX Part 21 Applicable: Yes a No X

Date: ____ '.:,://._,_'i_1_=_1I _ _ _ _

Date:

[rechnlcal JustiflcatiOIl: The components __ .. aid usmc,the appt'O]>ri&t:eAWS Dl.3, WPS IUld went made iby w .. 1d ..... properly quaUfted In aOOO1'd_ .... tILAWS Dl.1. All welda ... ~' made u~ the appropriate Ipr.,.,edanoe uul .... thin the applicable peramet .... TIIf!o baa DO efleet OD, the original design requin:mente /iht.d Ii. the lIAR' as the same parameter. were ...... m the telSt seri •• p" ...... , ....... hlch we ... used to /develop the SAR. '

fro p"'"ellt reetlnenee all .. elder .. shaH he 'laallfled ba accordanc ..... th AWS Dl.3 Sheet liIetail'rior to \making ILII.J' farther addiUonal welda Oil the product.

\Also IlOtUlcatJOIl Ie ~o~ JIlAde to all p" ...... a:e .......... of previously shipped product. Approved By: tjl.~ ~ .Q \ Date: _4~-... l .... o<..·..JI..L' ____ _

,- '\

lIm'l ...... ntatJon Completed: Co j.( ~ 'i,h.!> /1 /

.

Page 26: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries P.O. Box 17084. Bristol. Virginia 24209 Phone: 423-646-18641276-628-7553

Additional Technical Justification For

NR # 0013

Nonconfonnance Report Nwnber 0013 was written to report that Welder Qualification tests were not perfonned in accordance with AWS D1.3 Sheet Metal Specification. The welds made were perfonned in accordance with the applicable Welding Procedures for sheet metal in accordance with A WS D 1.3 and the employees who perfonned the welding were qualified in accordance with A WS Dl.l which has a lower limit of 118" thick.

All welders have been given and successfully paSsed the sheet metal welding qualification test in accordance with A WS D 1.3, a copy of those results are attached to the NR as evidence of successful completion.

Although a total of 50 units have been shipped and 10 additional units are ready for inspection, this non­compliance with the specification has no impact upon the end product. All packages were welded using the appropriate welding procedures and found to be acceptable during the inspection process.

William M (Mike) Arnold President

.

Page 27: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Centmy Industries P.o. Box 17084

Brilrtol, VA 24209 4ZJ-64.6-1S64

Corrective' Action Report (CAR) #: 0021"-----~~---------

Contract: 10-0007 B&WY-12 Date:, 04-19-11

Dwg.N~ __ ~N~/~A~ ____________ __ R~. ______ ~N~/~A ____ __ Piece Mkc __ ......:N:.J./..:.:A:...... _______ _

Other: QA Program . Fabrication Control.

DESClUPTIOK: Describe need for corrective action and recommended disposition:

Welder qualification for .heet metallesa than I/S" was not conducted in accordance with AWS 01.3 as needed

For the outer and inner sheet metal liners and for the lid· plug enclosure. The recommended disposition is to

Conduct the sheet metal qualification test in accordance with AWS 01.3.

\.u.PROVED DISPOSITION: Conduct weld.". qualification testing in accordance with AWS 01.3 in order to clear he issue.

AldL rI~,Jr , Date: 04-19-11 ~

' . j &: . ;,r- -r;.t. ...... QA Manager Appro~aJ: 'LW _ /e-'f ,.(-"'/: ~

jZ.Q.II1t..>QiI' ~ ... ~ ~/""/II Customer Approval (as r.qu edl: . Date: ------------------------- --------------------DlPLEMBKTATIOft: Approved Disposition Implemented:

Conducted the welder quaJification tests for all welders.

See. NRIt 0013

Page 28: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Tndll~ui~ ~s ,); jHt. "~1~O) ... j~r. 1\1.~n:.~ "jDr .. " ... C f .lI.

~~ "-';; , P.O. Box 17084

f r •. ~: :t'1'i')r.i1."'lI'r; ¥fl~'I"l.i '.".~~>~ Bristol, VA 24209

, ';, I'>; f!"\\'tb7 . ~'r.,,"'··;'~,d';J'~;:'i:.,;:~"t ,;",!,j 423-646-1864 ,-",

Welder's Name: Joe Dorton Clock No: Stamp No:

Welding Process: GMAW Type: Manu!!!

In accordance with Welding Procedure Specification (WPS):

Backing: N/A Material Spec: AlOll to AlOl!

Test Plate Thickness: 10 gao Thickness Range: 16 gao to 7 gao Dia. Range: NJA

Filler Metal Spec. No.: AS.IS F. No.: ,

i Weld Classification: ER 70S-6 Position: 3G Progression: Un i

I I

Electrical Characteristics Current: DC Polarity: Ne.g. I

FOR l'W' . ONLY Flux for Submerged Arc or Gas for Inert Gas "'h'_tA.

Filler Metal Diameter and Trade Name: Arc: NJA 0.035" ESAB

, ."'" ,'I}J>e ~d I<'i<ntrp No Rp~111t~ Type and r1!>UH; No. I

i AWS 01.3 Root 4.30 ",-'-"vtable - I iOo

, ,

Radiographic Results: For alternative qualification of groove welds by radiography in accordance with:

N/A

By::_ r-. . T ~u .. a.v.:r Test No. : ,

Test Conducted I

.e;,v!~C( "'" AWSn" ~<-/--'/';Cl?ff:'" ""- , ,

TACK/FILLET WELD TES1' RR"'lII.-#S "QC1 EXP 511/2012 I I. Fractured Surface: AlIA D Satisfactory D Unsatisfactory I

2. Weld Appearance: Nh D Satisfactory D Unsatisfactory

3. Macroech Test (Fillet Weld Test Only): NI A- D Satisfactory D Unsatisfactory

We certify that the statements in this record are correct and that the test welds were prepared; welded ane tested in accordance with the requirements of AWS Code D1.3 .

Customer Witness: N)f>. Date:

Certified By: t J.JA...--~-~ Date: '-1- ~6 - I I

,

Page 29: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Welder's Name: _Sammy Dockery Clock No: _____ _

Welding Process: GMAW Type:

Century ......... _'w.u P.O. Box 17084

Briatol, VA 24209 423-646-1864

Stamp No:. ______ _

Manual

In accordance with Welding Procedure Specification (WPS): _________________ _

Bac~ng:--~Nu/~A~ _____ _ Material Spec: _.£A,-,I",O,-,I""I~ ___ to _~Q..!:\L!.L-______ + Test Plate Thickness: __ l'-'O<....Qg"'a~. __ Thickness Range: 16 gao to 7 ga. ____ Dia. Range: _ ---'!L!:!.-_--I>_

Filler Metal Spec. No.:_--!..A"'5'-'-."'18"--___________ F. No.: _____________ _

Weld Classification: __ --'=E"'R .... 7'-'0"'S=-6"-_____ Position: ___ -"3~G!-__ Progression: _ ....l.!.I!... __ --!I-

Electrical Characteristics Current: ___ _ ~D"'C"-_______ Polarity: ___ ....£=~ ____ --I>

FOR INFORMATION ONLY Flux for Submerged Arc or Gas for Inert Gas Shiel(le;~

Filler Metal Diameter and Trade Name: 0.035" ESAB

Radiographic Results: For alternative qualification of groove welds by radiography in accordance with:

Test Conducted By::_ Q!;-'W!!DL.!!!!lJ~:rutL-+- Laboratory Test No.: ___________ _

1.

2.

3.

CWI 82050743

Fractured Surface:t-II~ Qel EXP. 5/rt1~tlsfactory

Weld Appearance: ~/". 0 Satisfactory

Macroech Test (Fillet Weld Test Only)YI~ 0 Satisfactory

o Unsatisfactory

o Unsatisfactory

o Unsatisfactory

We certify that the statements in this record are correct and that the test welds were prepared; welded tested in accordance with the requirements of AWS Code 01.3.

Customer Witness: __ r-J_l..'lt..~"""'"'-----------------l.).(-lh.-"- fh -~ Date:

Date: -------t--

Certified By:

Page 30: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Welders Name: Robbie Mathis Clock No: _____ _

Welding Process: GMAW Type:

Century .&..L&'\.&.u,,,,,

P.O. Box 17084 Bristol, VA 24209

423-646-1864

Stamp No:. ______ _

Manual

In accordance with Welding Procedure Specification (WPS): _ _________________ __

Bachlng: __ ~N~/A~ ______ __ Material Spec: _..!A,",l",O!.!l,-,l~ ___ to __ "'-''''-'''"''--______ + Test Plate Thickness: _--,l",Owg ... a",. __ Thickness Range: 16 gao to 7 ga. ____ Dia. Range: _ -""ll.!:!.-_-+_

Filler Metal Spec. NO.:_-!lAod5"".1!..!82--___________ F. No.: _____________ _

Weld Classification: __ ~EC<R"-!7-'0"'S"'-"'6 ____ _ Position: ___ .,3"'G"-__ Progression: ----''->'-----J-

Electrical Characteristics Current: _____ !eD~C"-_______ Polarity: _ __ ....!=~ _____ +

Arc or Gas for Inert Gas Shiel(l~ Filler Metal Diameter and Trade Name:

0.035" ESAB

Radiographic Results: For alternative qua1ification of groove welds by radiography in accOl;dance with:

Test Conducted By::_ Q;!ilil¥.!!!<!ll!!:ill:i~--- Laboratory Test No.: ___________ _

1.

2.

3.

Fractured Surface: A1 I .. Weld Appearance: J-.I If'

CI'II 82050743

act EXP 5/1 /9Cl3.fusfactory

o Satisfactory

Macroech Test (Fillet Weld Test OnlY):NIA 0 Satisfactory

o Unsatisfactory

o Unsatisfactory

o Unsatisfactory

We certify that the statements in this record are correct and that the test welds were prepared; welded tested in accordance with the requirements of AWS Code 01.3.

Customer Witness: ___ N--'J'-'A"-_________________ _

Certified By: --,-l -AJ.')...L; iM~=~_~",--~-U~""'~'I--_____ _ Date: _______ -4r-

Date: --'_ ...... ><---=-.J..---'--, _+_

Page 31: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Welder's Name: Travis Arnold Clock No: _____ _

Welding Process: GMAW Type:

Century ......... u.\,&U P.o. Box 17084

Bristol, VA 24209 423·646-1864

Stamp No: ______ _

Manual

In accordance with Welcting Procedure Specification (WPS): __________________ _

BackIDg: __ ~N~/~AL_ _____ __ Material Spec: _.!.A~Ib10L!I...Jl~ ___ to __ o..!!L!..L. ______ + Test Plate Thickness: _..!I~OLcg5!a",. __ Thickness Range: 16 gao to 7 ga. ____ Dia. Range: --.!W~-1--

Filler Metal Spec. No.::_~A&l.5,J.1J;8'_ ___________ F. No.: ____________ _

Weld Classification: __ ~E<tR>..7!Jd.Ol:!S:::!-62._ _____ Position: ___ ..,;3",G!-__ Progression: --'=-----!f-

Electrical Characteristics Current: _____ .bD!.!.C"-_______ Polarity: ___ --J=~ _____ _II_

FOR INFORMATION ONLY Flux for Submerged Arc or Gas for Inert Gas ShLield~d

Filler Metal Diameter and Trade Name: 0.035" ESAB

Radiographic Results: For alternative qualification of groove welds by radiography in accordance with:

/,Ii.a.boI"llltolC'{ Test No.: ____ ______ _

1.

2.

3.

Fractured Surface: ,v IA Weld Appearance: IJ IA.

CWI 82050743

QC1 EXP. !ill /201 2 u Satisfactory

o Satisfactory

Macroech Test (Fillet Weld Test Only):N III o Satisfactory

o Unsatisfactory

o Unsatisfactory

o Unsatisfactory

We certify that the statements in this record are correct and that the test welds were prepared; welded tested in accordance with the requirements of AWS Code 01.3.

Customer Witness: _...:N~/:J5ISL-_______________ _

Certified By: _ {u.,;...1ill!.l.-!Y.~-&lc.&Ic_(hJ.....Ll!.1' A.:'L,<'l..L.JJ.JL--______ __

Date: - ------4--

Date: ......:'-f_-...:d..=6_-.L..:,' __ -l--

Page 32: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Welder's Name: Mark Osborne

Welding Process: GMAW

Clock No:: _____ _

Century .l..LLU\.LiIi;J ....... __

P.O. BOll 170 84 Bristol, VA 24209

423-646-1864

Stamp No: ______ _

Type:_~M~an~u~W~ ________ _

In accordance with Welding Procedure Specification (WPS) : ___ ____ ____ ________ __

Backmg: ___ N~/A~ ______ __ MateriW Spec: _2A!..I~0!.JlulL-___ to __ l!..t!L!.!-______ + Test Plate Thickness: _..!I~O!.Jg!>!a;!,.. _ _ Thickness Range: 16 gao to 7 ga . ____ Dia. Range: - ---'!.L!!.---t--

Filler MetW Spec. NO.::_.J.A\i;5t,..1!IBtL-___ _ _______ F·. No.: _____________ _

Weld Classification: __ ....!lE~R ... 7J.:0~SQ::!-6,!..------ Position: _ __ ..,;3!.!,G<-. __ Progression: -~=---f-

ElectricW Characteristics Current: _____ b!D~C'--_ ______ Polarity: ---....!~;,....------1f-

FOR INFORMATION ONLY Flux for Submerged Arc or Gas for Inert Gas ::;rLlel,Ofo

Filler Metal Diameter and Trade Name: 0.035" ESAB

AWS DI.3 Root 4 .30

Radiographic Result,,: For alterrl<.tive qualification of groove welds by radiography in accordance with:

Test Conducted By::_ Century Industries T ... hOl."t,nrv Test No.: -----------1

1.

2 .

3.

Fractured Surface:).Jj:t.

Weld Appearance: /11/'11

Anthony H McGee CWI 82050743 ~Cj "xpctR~~~~actory

o Sa tisfactory

Macroech Test (Fillet Weld Test Oniy):N/A 0 Satisfa ctory

o Unsatisfactory

o Unsatisfactory

o Unsatisfactory

We certifY that the statements in this record are correct and that the test welds were prepared; welded tested in accordance with the requirements of AWS Code D1.3.

Customer Witness: ___ N..:IC!I\:L. _________ _________ _

Certified By: LJ. 111. '- ..fv\. W Date: _______ -11 __

Date: ---'---'''''-'''--L.c'-il--

Page 33: Century Industries P.O. Box 17084, Bristol, Virginia 24209

,

I

Century Industries P.O • .Box 17084

Brlatol, VA ~4209 423-646-1864

Recertification is base upon continu ed sail h 1 6 actary Work DunnA: t east mont h 'oct oen

Name Stamp/Ko Procellll Potdti_ Tack Only

\\\\\\\\\\\\\\\\\\\\ \\\\\\\\\ \\\\\\\\\ 1-G 2-

3-G \\\\\\\\\ G Original Certified

Travis Arnold A OMAW 3 -F Dates Original Date: March, 2007 -

Recetification Based Recertified February, 2009 A GMAW 3F Upon Continued

Satisfactory Work Travis Arnold DLl GMAW 30 March 25, 20 II

D1.3 3F April 26 2011 Freddy Brickey OMAW 3F May 2 6, 2010

~ -Freddy Brickey GTAW 3F May 26. 2010

Drew Sallee GMAW 3F April 23,2010

Drew SaUee OTAW 3F April 23,2010

Mark Osborne GMAW 3F April 23,2010

Zachary Sallee GMAW 3F April 23,2010

Joe Osborne GMAW 3F April 23,2010

Mark Osborne DJ.I OMAW 30 Augu'lt II, 2010 01.3 April 26 2011

Zachary SaUee GMAW 30 August 11,2010

Joe Osborne GMAW 3G August 11,2010

Freddy Brickey GMAW 30 August 11,2010

Robbie Mathis 01.1 GMAW 30 August II, 2010 DI.3 3F April 26 2011

Drew SaUee OMAW 30 August 11,2010

Freddy Brickey OTAW 3G November 19,2010

Freddy Brickey CTAW 3F November 30, 2010

Joe Dorton GTAW 3F Septembe r 23 2010

Joe Dorton 01.1 OMAW 3G September 22, 2010 01.3 3F April 26 2011

Joe Dorton SIS to CIS GMAW 3F April 26, 2011 Sheet Metal

: Sammy Dockery CHAW 3F September 16, 2010

sammy Docke!')" DU GMAW ~ 1--

i 3G Septemher 16,2010 01.3 I 3F April 26 2011

r::.-l<fL E<Q!lli!I:X II. ;JQ II Augy~l I I. 20~ Qu~a;e~%&:clt., Sh.lll Date Du .. Oat ..

~, ~ -----

Page 34: Century Industries P.O. Box 17084, Bristol, Virginia 24209

"J.,'~~,- _,.t:;;. .... _='~""-4 ... • '-" ,.,-~-,.~-,-:. -. .... ~ •• ~~.,.,~ _ .0-._

'Wonconformance:Report· ~ D21''';-. . JNRl Rev. 1

Century Industries

Nonconformance Report INR) #: _..:OOc::..::l:.;4~ _____ _

ContraCt'·· 10-0007 B&W Y-12 Date·

Component; 55 ~on Ve-rss-Pac Customer P.O.:

Part:

P.O._170M Briatol, VA 24209

423-646-1864

04-19-11

4300075777

Nameelate to Outer Drum Dwg. No.: 55VP·OOID Rev. 3 Piece Mk.: 10562 thru 10571 & 10576 thm 10625

Other:

DEJIClUPTIOlf OF IfOlfCOKJ'OJUIAlICE: (atb!-ohmeatw) . Describe nonconformance in detail using sketches, drawings. etc. a" req~.

Nameplate" were welded to the outer drum of the finished prQduet witI10ut an approved weldiitg procedure.

This is a non-conformance due to the dissimilar metals i~olved. The ~)ate is made of 300 ~ries stainless

steel and the drum io made of carbon oteel. A.\(.,L Y!J.pr ~..J;,;~.~ 4-1 II-I} .UAV -'. ~ . f.dt. ,.rTtJ.:i:.r. ~~/~IJ

- U ffiltt Y Cate ,~ V'll'. an.ger

Recommended disposition & basis for acceptance and corrective action taken to prevent recurrence. APPROVED DISPOSmOlf: IAttachmenU! Attach the apPrOprfate WPS )

0 Repait'* CAR Required: Yes 0 NoX CAR No. QQ22 0 Scrap o Use as is* SCAQ; Yes [J No X Part 21 Applicable: Yes 0 NoX X I\ccept as Is ~\ ~ l.l /,,.. --r~I<_

Date: 'i/f'tl-" QA Manager Appr!'val: ' ~ Lk· fc"- /fitt. Uv.e.v!lJ:..!l .:J.~ 5/ .... /'1

I-Customer A pprovaJ (as required): Date:

TechD!cal '''-t;l6c,at!oll: The _plat" .... attached to the outer dnm by two math ..... 1" by weldhlg at he _ .. and 2-" by cI.rilUnff tJje (our cono ........ pluc .... ldlng tbrD the nameplate to the drUm. The ... lDeth~ have DO fm~ thO desfgJa or uaac" of the pubce and ..... th .... ro ... acoeptabla for .... aa Is. t\~.-).~ . ' fro ,... .... nt recurn_ an4 meet the apeolflo.t!oD .equIft .... Dtw a CAR ohaU be _ed·to quaUfy both WPS land ",e1der to attach.~ .the _Dame PlatwlUe prOduct.

Approved By: . l 1>11. _ '(\--:. Date: 4-- ;;lS-' /

Itmpl.meDlatJoll Completed:

, Ve rified By: :..:;..-. I<-IL Da.te: Lf-~:25 -/1

Page 35: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-18641276-628-7553

Additional Technical JUlitification For

NR#0014

Nonconformance Report Number 0014 was written to report that the nameplates were attached to the outer drum without a qualified WPS for dissimilar metal (Stainless and Carbon). A Welding Procedure Qualification (WPQR) was conducted to develop the necessary WPS. Three different tests were conducted as part of the WPQR, a standard fillet weld, a lap joint, and a plug weld. The materials were stainless to carbon steel sheet metals with a stainless filler material. The welding tests were completed as required and found to be acceptable. The WPS was written and the welder was qualified by the WPQR results.

The nameplates were attached to previously completed containers by the same methods quaIified. Because the spot weld used to attach the nameplates pose no potential safety issues and pose no issue with the safe use of the package, they are acceptable in the as is condition.

William M. (Mike) Arnold President

Page 36: Century Industries P.O. Box 17084, Bristol, Virginia 24209

"

Century Industries P.o. Box 17084

Bristol, VA :14209 423-M6-1864

Corrective Action Report (CAR) it: _002--'--'-2'--____ _

. , . . . . 1(t-0007''~W.y·12~';' .'< -.- -- .

···.'i: . » Date: o+ig.:u ··

Dwg. No. N/A Rev. NlA Piece Mk. NlA

Other: QA Program - Fabrication Controls

DBSCRJPTJOB: Describe nc;ed for corrective action and recommended diaposition:

....• Weldin! erocedure for dissimilar metals is not in I?!ace to make weld 01 the. naIDel!le:te to GIller ~, : ..

Qualify both weld procedure and welder as required to properly make weld.

~ .\'..U~fI 'f\.-,. \..ll .. . . 4-lg-11

~_OVED DJ8POS1TIOJil': Conduct welding procedure qualification and welder qualification test in accordance vith AWS DJ. in order to clear the issue.

pA Manager Approval: a.-..o- /L. f2.- 1-' 41L-' 'fIt.<!' Date: 04-t<J-1l

J2.t.,. ,LosU( : t,W+e:,.J. ~ ?/2....f II Date: • ~ustomer Approval (as requir :

Innn '"IIB!n'ATJOlf: Approved Disposition Implemented: ,

Conducted the weld procedure !jualilication tests for <lissim.ilar metals and QUllIiiIed welder usinfl: the .

procedure qualification test.

By: ~~.~ Date: lj..'l,. 5 -II

Page 37: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries

WELDING PROCEDURE SPECIFICATION (WPS)Yes 0 PREQUALIFIED OUALIFIED BY TESTING ../

OR PROCEDURE QUALIFICATION RECORDS (PQR) Yes 0

Identification #: WP8-19 (AWS) D1.3:1999 Revision: 0 ~: ~I111 J3y: WMA Authorized by; \...) .Jl 'l l\ Date: 04125/11

Company Name: CenturY Industrig Type- Manual 0 Semi-Automatic &' Welding Process(es): GMAW Machine 0 Automatic C Supporting PQR No.(s): WPQR9

JOINT DESIGN USED POSITION Type: Fillet or PI!,!g Position of Groove: N/A Fillet: 3F Single It'! Double Weld 0 Vertica1 Progression: Baclriog: Yes It'! No 0

UpO Down It'!

Backing Material: ELECTRICAL CHARACTERISTICS Root Opeoing N/A Root Face Dimension N/A Groove Angle: N/A Radius (J-U) NlA Transfer Mode (GMA W) Short-Circuiting It'! Back Gouging: Yes 0 N00 Method Globular 0 Spray 0

Current: AC 0 DCEPO DCENIt'! PuIsed 0 BASE METALS Other Material Spec. ASTM Tungsten Electrode (GTA W) Type or Grade AIOll to AJ04 Size: -Thickness: Groove N/A Fillet 20 Ga. to 16 Ga Type: -Diameter (Pipe) -

TECHNIQUE FILLER METALS Stringer or Weave Bead: Strinl!er A WS Specification A5.9 Multi-pass or Single Pass (per side) Single A WS Classification ER308L Number of Electrodes 1

Electrode Spacing Longitudinal -SHIELDING Lateral -Flux N/A Gas HElARlC02 Angle -

Composition 'i!ln.5l2.5 Electrode-Flux (Class) Flow Rate 2040 CFH Contact Tube to Wark Distance 3/8 - 3/4

i CUPSize 3/8-314 Peening N/A Interpass Cleaning: Brush or Grind as needed

.

PREHEAT I Preheat Temp., Min ~Qof POSTWELD HEAT TREATMENT

Interpass Temp., Min NlA I Max N/A Temp. NlA Time N/A

WELDING PROCEDURE Filler Metals Current

Pass or Amps or Weld Type & Wire Feed Travel

Layer(s) Process Class Diam. Polarity Soeed Volts Speed Joint Details

1 GMAW ER308L .035 DCRP 150-285 14-24 10-20 IMP ~ (

~ ~

1 ®

Page 38: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries

No.: 9

Welding Procedure Specification No,-,-.=--: __ ---C!1'"'9~ ________ _

P.O. Box 17084 Bristol, VA 24209

423-646-1864

Date: ___ -"0c::'4~-2"'_lo.:-~I~I ____ _

Welding Process(es.,,):'-__ --'G::.M=A.:.;W"---________ Type(s):_--,~S::!:e~m~i-::..A~u~t~o~m~a~t~ic~=.,_,=.,...,.===-(Automatic, Manual, Machine, Semi-Automatic)

JOINTS (QW·402)

~/ Fillet

BASE METALS (QW-403)

Lap Groove Design Used

Plug

\ ,

Material Spec.: ASTM A304 to ASTM A lO 11 Type or Grade: A304 to, __ ~A-=-lO~IOcI,---__

P No.: ______ Grp.:. ______ To ____ P No.: ______ Grp.: _______ _

Thickness: 20 Gauge to 16 Gauge Diameter: N/A Other: N/A

FILLER METALS (QW-404)

Weld Metal Analysis A-No.=--: _______ Electrode Size: 0.035" Filler Metal F No. _______ _

SFA Specification: A5.9 AWS Classification: ER 308L Other: N/A

POSITION (QW-40S)

Position of Groove~: _-'Fil-'·"'1"'et"---"3"'F'--_______ Weld Progression'-.: ____ ~D'=""o"'wn~hil~·"l~c_=------(Uphill, Downhill)

Other:

PREHEAT (QW-406)

Preheat Temp: 50°F lnterpass Temp:

POSTWELD HEAT TREATMENT (QW-407)

Temperature: N / A Time:

GAS (QW-408)

N/A Other: N/A

N/A Other: N/A

Type of Gas(es).,--· -,T",n.!.·-",M",lX",· '--____ Composition of Gas Mixture: 90%Helium, 7.5% Argon, 2 .5% C02

ELECTRICAL CHARACTERISTICS (QW-409)

Current:'-_~D'--C~ _______ Polarity: __ ~R~e~v~er~s~e'_ __________________ _

Amps/Wire Speed: 235 Volts: 18 Other: N/A

Page 39: Century Industries P.O. Box 17084, Bristol, Virginia 24209

t ,\l.'l!1lrt_ '~('[Oi~.m>('"Ii..'.lm·HJ i~ ~~.,f S f;;T;;·"·.f."." .. ~~:::.

TECHNIQUE (QW-41O)

String or Weave Bead: S tring Oscilla tion:

Multi or Single Pass: Single Single or Multiple Electrode: Single (Per Side)

Travel Speed : 10-20 IMP Other : NjA

TENSION TESTS (QW-lSO) N/A Dimensions

Type Area Ultimate Ult imate Character and S'Decimen No. Specimen Width Thickness Sq. In . Load Lba. Stress-Psi Location or FaUure

GUIDED BEND TESTS (QW-160) N/A No. fvoe Fll<W'e Result No. Type Figure Result

NOTCH TOUGHNESS TESTS (QW-170) N/A Charpy V Notch Impact Tests Drop Weight

Specimen No. Location Temp. Ft. /Lb. Avg.o£3 Lat. Exp. % Shear Break No. Break

Type of Test: Nj A Deposit Analysis: NjA

Other : NjA

FILLET WELD TEST (QW- l SO)

RESULT: Satisfactory: ;r;es ONo Penetration into Parent Metal: ~es o No

MACRO Results: Acceptable

Welder's NalID'e: ___ ~~Q.<.>~~_--;-_ _ -A~_ Clock No. : _______ --CStamp No. : _ _____ _

(L .... II!!!J1I*..i:on.to,ryTest No.=-: ___________ _

We certify that the test welds were prepared, welded and tested in ASME Code.

QA Approval.:_ --':...\A+.i.\.&'~':!:f~::::::.. __ ---:-________ Date: /t- - '';' 1... - \ \

Cen tury \. ,,) • U ; ..:f\ .'-. . ~< ....A2J Date: 4- - J.. <.. - \ \

I

Page 40: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Welder's Name: Joe Dorton

Welding Process: GMAW

Clock No: ______ _

Centu~Indusbcies P.O. Box 17084

Bristol, VA 24209 423-646-1864

Stamp No: _______ _

Type:_~M~a~n~u~al~ _________ _

In accordance with Welding Procedure Specification (WPS): ___________________ _

Bachlng: ___ ~N~/A~ ____________ __ Material Spec: _-L.A,-!I,-,O,-,I,-,I~ _____ to ___ ,-,A""I".O",,1 "'-1 ______________ _

Test Plate Thickness: _20 to 16 gao Thickness Range: __ 20 gao to 12 ga. ___ Dia. Range: N/A

Filler Metal Spec. No .:_-!A"S'-' . .z.9 ____________ F. No .: _____________ _

Weld Classification: __ ----"E"R"""3,,0"'8"'L"-____ _ Position: ___ --"3"F ___ Progression: _--.!D""ow=n'--___

Electrical Characteristics Current: _____ -'D~C"'-___ ______ Polarity: ___ ~N=e5g~. _____ _

FOR INFORMATION ONLY Flux for Submerged Arc or Gas for Inert Gas Shielded

Filler Metal Diameter and Trade Name: Arc: N/A 0.03S" Washington Alloy

Radiographic Results: For alternative qualification of groove welds by radiography in accordance with:

N/A

Laboratory Test No. : ____________ _

1.

2.

3.

AWS 01.3 & 4 .2A

Fractured Surface:

Weld Appearance:

Acceptable &4.4

~tisfactory ~tisfactOry

Macroech Test (Fillet Weld Test Only): II • .,J-\. 0 Satisfactory

Acceptable

o Unsatisfactory

o Unsatisfactory

o Unsatisfactory

We certify that the statements in this record are correct and that the test welds were prepared; welded and tested in accordance with the requirements of AWS Code 01.3.

Customer Witness: __ N~)~4L_ ____ _:_---------------

Certified By: ~\ AA)L...i,I:A,.11~,,:..!.:fh~'--'---lU~~<Ir___-----Date: _________ _

Date: _4--'----';Z~(p'_. _--,,--,-, __

Page 41: Century Industries P.O. Box 17084, Bristol, Virginia 24209

,

?,,'r :~-'~r~:w._~~~'" ~"f, ::: ~ i'~' ...... .- .... 'l.""h.y,y..,.-.... ~ q~"""", : ..... -,'-. f '"

'No~confo~ance· Report D21-' -fNRlft " -. Rev. I ' . "

Nonconformance Report (NR) I: _-'00=-::.=15.::-. _____ _

Contract: 10-0007 B&WY-12

Century Industries

Date:

P.o. Box 17084 Bristol. VA 24209

423-646-1864

04.-19-11

Component: 55 gallon Versa-Pac

Part ss to PG and SB-l 10 PH

Customer P.O.· .. ___ -,4",3",000=.:..75"-7",7,,,7-,-__

Owg. No"'.:_-'S:.:S:..Vc:;P_-O;;.O;;.:.:lD:;;..... ___ Rev. 3 Piece Mk.: 10562 thru 10571 & IOS761hru 10625

Other.

ESCRIPTlOlf 0)' JlOHCOlDORIIAlI'CB: (attachmellts, Describe nonconformance in detail using sketches, draWings, etc. as required.

The WPS voltage parameter for GTAW is IistedaslS-24_ The voltage displayed during the welding process

indicated a voltage of between 10 and 12, this has been determined to be due to arc length and contact

distance.

t,.- '3,-'1 ate

ecommended disposition & basis for acceptance and corrective action taken to prevent recurrence. OVED DJBP08ITIOII'.IAttachments: At!ach,the corrected wps

D Repair" CAR Required: YesD NoX CAR No. ______________ _

a Scrap o Use as is" Yes a NoX Part 21 Applicable: Yesa No X Accept as i v ....... -;7.;t'-<c..I('h(

A Manager ru>provaJ.~L:~~' ~· ~:'~~~~C~""~'/72~K~RL--':'-- Date: l/. I .!l¢o", iCe..; : J.\ut ~/2-/11 Customer Approval (as reiluired):

A It-L'f l..

Date:

echDlca1 Jastift.,.,uo .. , AWs 1;1 allows for. voltage zanga of:tll6'l1o, with, tJa4i. an. 1'llD&e and pzoducUon quipment belDe employed fD the fil"rfaIi~1l althe package890ltaP "Cosl~ned"J' the an: diataIlce nel Dot by eOD~1 ... pnrvloualy estal>lfiIIaed. To rectify the voltage .u~]Iil:Iloy the WPS Is to be acljuste4

reBeet: the appropriate weld panu:aeter_

o pJe'Yent ~ ..... mo .hall ... -.. .... to botIl QA/QC and Production ~ aelcUtional netruotloll OD the bnportallce 01 checJd:ng Illl weIdiDa: ptUallletel1l .. matter of practi""'~

welda effeoted were lDapectecl and fouad to be accepbble .. part. 01 the Jlonnal ~OD and pect:lon pnI"" and did~_..a.wt the "eaJso conclitione of tho pzoclllct. . P Approved By: U 1 dk~;:"'~ Date: <.f' I 'I -0 ,f, ple",ootatiqn Completed:.. ! ' I ;JJ AIi.1L Yr~ If

. . Vprififfi Rv' «? #~ ~ OA'''' ..:uyh"u.0:.:::>a;'~/~_~ __

I

Page 42: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries P.O. Box 17084, Bristol, Virginia 24209 Phone: 423-646-18641276-628-7553

Additional Technical Justification For

NR#0015

Nonconformance Report Number 0015 was written to report voltage out of the allowable range provided by the WPS and the 25% allowance provided by A WS D1.1 without revision to the WPS. As reported the voltage being employed by the production welder was found to be between IO and I3 volts on contact with the welding surface. As stated A WS D 1.1 provides a 25% tolerance for the GT A W voltage without revision to the procedure, the bottom range of the WPS was 13.5 volts. With GTAW (TIG) when equipment does not allow for direct control of the voltage, it is controlled by the arc length and distance to the work surface.

In order to comply with the specification the WPS was revised to provide an acceptable range for the equipment being employed in making the weld. AWS Dl .l Section 3.6 allows for the revision of the WPS to address variables within the procedure including voltage.

The blind nut, which is welded to both the top flange and lower stiffening rings, is also welded on the underside by the GMA W process, with the top GTA W weld acting as a top flange sealing surface. The welds as produced are consistent with the welding conducted on the original test series packages, which proved through HAC testing that they produced acceptable results.

In addition, all packages were welded using the appropriate welding materials, qualified personnel and all welds made were inspected, found acceptable by NDE methods and recorded on the Fabrication Control Records. We therefore find that there are no significant conditions adverse to quality in the packages previously produced and have no impact upon the end product.

We are instituting during the course of normal fabrication, a policy to conduct additional verification of the WPS parameters, as a mater of practice. QAlQC and Production personnel have been issued a memo on the importance of verification to the WPS being employed.

William M. (Mike) Arnold President

Page 43: Century Industries P.O. Box 17084, Bristol, Virginia 24209

Century Industries

WELDING PROCEDURE SPECIFICATION (WPS)Yes XO PREQUALIFIED X QUALIFIED BY TESTING ___ _

OR PROCEDURE QUALIFICATION RECORDS (PQR) Yes 0

Company Name: Century Industries Welding Process( es):cc-__ G=T'-'A'-'W'=-_-".=-cc-___ _ Supporting PQR No.(s): Pregualified

JOINT DESIGN USED Type: fillet Single O X Double Weld 0 Backing: Ves 0 No 0

Backing Material: Root Opening NI A Root face Dimension NI A Groove Angle: N/A Radius (J-U) N/A Back Gouging: Ves 0 No 0 Method

BASE METALS Material Spec. ASTM A-36 Type or Grade Carbon Steel Thickness: Groove N/A Fillet Unlimited Diameter (Pipe) _-'N"'/C!.A!...... __________ _

FILLER METALS A WS Specification __ --=5",.I."S=-=-_______ _ A WS Classification __ .EE~R"--7LlO!:iS!:-2"--_______ _

SHIELDING f lux N/A Gas Argon

Composition 100% Electrode-flux (Class) N/A flow Rate 10-40CFH

Gas Cup Size #2-S

PREHEAT Preheat Temp., Min SO°F Inter-pass Temp., Min N/A Max

Identification #: WPS-I (A WS) D 1.1-2000 Revision: 3 Date: 04-/9-11 By: WMA Authorized by:~ ·W Date: 04-19-11 Type - Manual OX Semi-Automatic 0

Machine 0 Automatic 0

POSlTJON Position ofGroove:_.JN::!J/:£:A~,...-_Fillet: Fillet Vertical Progression: Up O X Down 0

ELECTRICAL CHARACTERISTICS

Transfer Mode (GMA W) Short-Circuiting 0 Globular 0 Spray 0

Current: AC 0 DCEP 0 DCEN 0 Pulsed 0 Other,...-~,-_~~~~ _________ ___ Tungsten Electrode (GTAW)

Size: 1116" 1/8" Type: Carbon Steel

TECHNIQUE Stringer or Weave Bead: StringerlWeave Multi-pass or Single Pass (per side)---'S"'in"'g"'le'--____ _ Number of Electrodes __ -,-..iSllinWg!\!lE,e".-..,--:-c,...-__ _ Electrode Spacing Longitudinal.,.,-N=/A:L-__ _

Lateral N/A Angle.-"N,:!!/~A,--____ _

Contact Tube to Work Distance.--'.N"/!:!A~ ______ _ Peening N/A Inter-pass Cleaning: Brush/Grind As Required

POSTWELD HEAT TREATMENT Temp. N/A Time N/A

WELDING PROCEDURE Pass or Filler Metals Current Weld Type & Amps or Wire Travel

Layer(s) Process Class Diameter Polarity Feed Speed Volts Speed Joint Details

1 GTAW F6 1116 DCSP 90-120 9-16 N/A

~ 2 GTAW F6 1116 DCSP 90-120 9-16 N/A 3 GTAW F6 3/32 DCSP 110-150 20-28 N/A 4 GTAW F6 3/32 DCSP 11 0-150 20-28 N/A 5 GTAW F6 118 DCSP 125-180 22-32 N/A

F==l ( 6 GTAW F6 118 DCSP 150-200 22-32 N/A r)

L