ML20024A180

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Responds to FOIA Request for Records Prepared by Us Govt Employees Re Alliance for Survival,T Carpenter &/Or Ongoing NRC Investigation of Facilities.Forwards App a Documents. Search for Addl Documents in Progress
ML20024A180
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 04/14/1983
From: Felton J
NRC OFFICE OF ADMINISTRATION (ADM)
To: Carpenter T
ORANGE COUNTY ALLIANCE FOR SURVIVAL
Shared Package
ML20023B057 List:
References
FOIA-83-131 NUDOCS 8306160052
Download: ML20024A180 (2)


Text

. _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

Pb3 - o W a " %,,#

UN11 E D sT ATEs j p.~, 9' g NUCLEAR REGULATORY COMMISSION g /, 44 7,'

C WASHINGTON. D. C. 70555 9.....

April 14, 1983 Mr. Tim Carpenter Director Orange County Alliance for Survival 654 North Hariton IN RESPONSE REFER Orange, CA 92668 TO F01A-83-131

Dear Mr. Carpenter:

This is in response to your letter dated March 14, 1983, in which you requested, pursuant to the Freedom of Information Act, records prepared by U.S. Government employees in connection with the Alliance for Survival, Tim Carpenter and/or the ongoing NRC investigation of San Onofre Nuclear Generating Stations I, II, and III.

Appendix A is a list of documents responsive to your request.

These are enclosed. Additional documents which may apply to your request have been made available on previous F0IA requests. Access to these documents j

may be obtained by contacting the NRC Public Document Room (PDR) 1717 H Street, N.W., Washington, DC 20555 and requesting folders F01A-82-528, Ellie Cohen, F01A-82-565, E. Earl Kent, F01A-82-614, Billie Garde, and F01A-82-618, Billie Garde.

The search for additional documents which may be responsive to your request is continuing. When completed, you will be notified of our determination.

Should you have any questions regarding your request, please call Nina L. Toms, (301) 492-8133.

Si

rely, s

/

M

/. M. Felton, Director Division of Rules and Records Office of Administration

Enclosures:

As stated 8306160052 830414 PDR FOIA CARPENT83-131 PDR

Re:

f 01 A-83-131 Appendix A 1.

9/22/82 Letter to the Department of Labor Standards and Enforcement from H. E. Book.

(1 page) j 2.

10/13/82 PN0 82-41, " Media Interest in Welding Allegations".

(1 page) 3.

10/20/82 Memorandum for Dane Smith from Owen Shackleton, "Telecon on October 19, 1982".

(12 pages) 4.

10/29/82 liemorandum for Darrell G. Eisenhut from Jesse L. Crews, " Request for Technical Assistance Allegations' by E. Earl Kent (San Onofre).

(8 pages) 5.

10/29/82 Letter to Carlton Kammerer from Senator Alan Cranston.

(3 pages) 6.

11/8/82 Memorandum for D. G. Eisenhut from R. H. Engelken, " Recommendation for Licensing Board Notification Regarding Velding Related Alleoations at San Ohofre Unit 3".

(7 pages) 7.

11/10/82 Memorandum for ASLAB from Thomas M. Novak, "Information Item -

Notification of Welding Related Allegations at San Onofre 2/3".

(9 pages) 8.

11/17/82 Memorandum for ASLAB from Thomas Novak, "Information Item -

Notification of Welding-Related Allegations at San Onofre 2/3 and Midland 1/2". (9 pages) j I

9.

11/30/82 Memorandum for ASLAB from Thomas Novak, "Information Item -

l Notification of Welding-Related Allegations at San Onofre 2/3 l

and Midland 1/2". (11 pages) l 1

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SEP 2 01982

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/ C' Department of Labor Standards & Enforcement 9

8765 Aero Drive Saite 120 San Diego, California g2123 Attention: Mr. R. Mundo Deputy Labor Conaissioner Gentlemen:

Subject:

Claim fl0-14803/150 This refers to the telephone conversation held between yourself and.'ir.

M. Cillis of this office on September 20, 1932. The conversation concerned an allegation that was made by a former 3echtel Poaer Corporation employee.

The allegation suggested the possioility that San Onofre's Unit 2 Nuclear 3enerating Statica radiation protection program was not in comoliance with regulnor rscuirrents as described in Title 10 of the Code of Faderal l

j 3egulations.

An investigation with respect to this iten was conducted by Mr. Cillis during the week cf Septe::ber 13-17, 1982.- The investigation consisted of selective examinations of representative records, interviews with personnel and observations by the inspector. The inspection did not include an investip tier.

of any possible infractions to 10 CFR 19.15(c) requirements.

No items of noncompliance or deviations pursuant to 10 CFR 19.11, 10 CFR 19.12 or 10 CFR 20 were identified within the scope of this inspection.

The results of the investigation will be described in Region V Inspection Report 50-362/82-20 which will be available from the NRC Public Document Room in approximately 30 days.

Should you have any questions concerning this inspection, we will be glad to discuss them with you.

Sincerely Origtal stFM 3Y

k. E. BocW 4

p ocK 05000i d 5~20922

~ ~ '

. E. Book, Chief 0

Radiological Safety Branch

_cc:

F. A. Wenslawski 1

0. Shackleton bec: DMB/ Document Control Desk (RIDS) i

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Distributed by RV: State of CA; LFMB; RHE

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nac ronu sis oo-aemacu cm OFFICIAL RECORD COPY usc o:mi de

Pkt'LIfbARY NOTIFICATION OF EVENT Uh UHU5UAL OCCURRENCE -PNO-V-Q-g' D 4

Y This preliminary notification constitutes EARLY notice of events of POSSIBLE safety cr'public interest significance.

Tne information is as initially received without verification'or'ii evaluation and is basically all that is known by IE staff on this date.

3-

~ '4 J Licensec Emergency. Classification:

alif nia Edir.cn Company Notification of Unusual Event FACIIIT): Souther *.

0 gg-Wir3c MT.M;pr-e arumtref'EIMt#AIert Y'

San Clemente. Calilurnla Site Area Err.ergency Dutket Nos. 50-361 & 50-36 General Emergency SULI. LLC I:

MEDIA INTFREST IN WLLDING AlI ECATIONS y

Not Applicable A former Bechtel Power Cor pot aticn quality control tilspector has made public allega-tions concerning weiding pratlites at San Onof re Units 2 and 3 The Region V of fice was prvviously aware of the allegar. ions. Widespread media interest is occurring in Seuther n California.

Region V -es made aware cf the allegations t.ont erning San Onofre during a routine inspectian at the site in carl) September.

The alleger had raised his concerns with the licensee. Souther n Cal 1forr.ia Fdison Company.

Region V inspectors reviewed the 1icensee's investi.ptson ann concInded that the Iicensee had taken coo:prchensive investigative action and adequately addressed all issues.

The item was considered closed.

On Octaber 6, a Los Arigeles Times ir.ve tigative reporter contacted Region Y conccrning-the alleger and his conr. erns, the reporter sunsequently arranged for the alleger to call Region V directly.

The alleger then expressed some concerns in addition to thor.e he had raised with the 1icensee earlier. The 1.os Angeles fides Wrote ahnut the alleger and his concerns in Luda.y's editions.

The alleger subsequently has been widely interviewed by other area media.

Regicn V har. heen responding to redia inquiries indicating that Region V plans an inspection into the eddition61 allegations next week.

Neither the licensee nor the NRC plans to issue a news release.

Region V (San Francisco) ipspector at 8:30 a.m.

received nulif ication oflh(rvdia stories from an on-site

$ 4 N M M M M @.00fd M n M @st g i 4 9 t

nn Octcher 13. 1982.

CONTACT:

D. F. Kirsch I

W. Slshop FT5 463-3723 TT5 453-3751

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DISTRIBdTTON:

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MNRR Phillip; ~ E/W 3;y(Willste Mail:

'ChE rman Pallodinc EUU NRR IE NM55 ADM:0MB Conn. Gilinsky PA OIA RES 00T: Trans only Comm. Ahearne MPA AF00 Cormi fronerts Fl D Cenn. Asse!stine Air Rignts TNPO SECY

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FOR Regions: I p..IY. ;tE.

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'o UNITED STATES

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NUCLEAR REGULATORY COMMISSION

. f 8,pggYd gt

'c REGION V i

c 1450 MARIA LANE.5UITE 210

%, s e WALNUT CRE E K, CALIFORNI A T4596 October 20, 1982 MEMORANDUM FOR:

Dave Smith, Materials Engineering Branch, NRR FROM:

Owen C. Shackleton Jr., Acting Director, OISFF0

REFERENCE:

Tel econ on October 19, 1982 Enclosed is a copy of the statement of E. Earl KENT obtained by Investigators of this office on October 16, 1982. Also enclosed is a modified version of this statement written as amended by Mr. KENT.

If we can be of any further assistance, please contact FTS 463-3711.

Orstz.acctbis 1

pden C. Shackleton Jr.

Acting Director, OlS FF0

Enclosures:

As stated 4

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CCC9 Spruce Court Cypress, Calif:rni:

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Date: _Odeber 16, aC Time: /c ; 30f3,,,.

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I, I. Icrl I;ent, voluntarily make the follouing stctement to

!essrs. Philip V. Joukoff and Cuen C. Shael:leten Jr. who have identified themselves to me as investi;;ators for the U. 5.

I:uclear Regulatory Cor=ission (!! C).

I cche this statecent freely with no threats or promises of reward having been mede to me.

Jute l Me. t A..

3 I am 37 years old cnd have ucrked since N% JS!G as a e

uelder, uelding ouality centrol inspector, velding engineer FI' Q

and author of welding articles.for velding journals.

In 19g:73'.1,(4/@3 I received a diple=a fer completion of the Structural Engineer-s.

ing Course from the ~nternational Corres?cndence School, scranton, Tennsylvania.

I worked for Eechtel Feuer Corpora-f tion as a Genicr Cuality Centrcl Ent;ineer in velding at the M'

San Cn%fre !:uclear Generating Station (SCGS) fre

October, 1920 until ? ;tu..'cr, 1961.

(rX shi/$0+f~

During ny emnloy=ent at SGGS I identified the fcllouing cen-cerns which vere identified to me by the ?]C personnel who in-torviewed me on Gcteber 15, 1982 as possibly affecting nuclear saict;.'{systecs,,$N12 eys'g;;,. /rgiyj',

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(1) Pi~e fittersjlused,pire cutters to make scribe-earhs for

~

sechet veld fitup mecourecents.

These scrif+ carks caused grooves inboth stain 1 css =nd carbcn steel f.ipes about 1" back frca the veld area.

I at conTerned that M.'_

these greeves uight cause stress raisers.

These condi-tiens enist en nochet velded fittings h ier Units 2 and 3 $.$'ff/32f' A f/3/L'/N UNff*/r O' M /2*l// k 4f ///

gC. N t

(2) Eecht;el designersc.__ _ use fillat velds en uswe'e

.[].f connectic=s of he%':b in utre suppcrts cad tray hc=cers and Ofy.cAf do not veld all arcund the .cint te restrain forces in all 70 M/f/7?c//M_ d.iracji g s.

I feel this is a cede violatien.

o oroto-N.

g ',

  • tyce testguere cenducted to verify the adecuacy of these k/MMrs

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uelds.

Cherefore, electricaltrayhan"or/ttpfgtegveldsusedorthethe actual structu actual =cterial'at Sd:GS uly hnoun.

This also,,,

aui-lids to f pe cupportsM,J.- not".tp*? eel that the fdIlure /.4'/NdSN) i

'I alst'

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to vel:1 c11 nround the joint is a generic rroblem.

M

,,Cn f o rt un at elg an d._% f r ::i;.ign, won +1-:r, the ccdes dcfirar~.//A/ph U ) rrc-- de==n6jL.D$$!"?$Ni.47!,3gi.-vEg,lI c:..:.$etJ G f c Vi y & t.*s T "'

r-recui. es cae: u :e rcot ~ene tYaf.c.. o ucldt.

Nfk I recall' thct crne of the' vender sucrlied uelded hard:;are e= not hcve anecuate root ;enetratiena.

he ene vender 4 / N5.A~~""D

.A.

I can reen11 in *:.ach, I believe a su;. lier af Tl..C ecuit-

en t.

I re= ember cne ir rtance en a,icce cf Zach harduare

ere a fillet veld ui:h i~nn lenus'te r e.ar.+trat"on 1.pj /,.C/jef//

.a 4:,,,,- e E30e 1 O

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.W F/2 I:ntinued State ent of E. E rl

'ent..........)....~.-age 2 vas identified durin ; inspecticn on site. / Chis instance was ield repa'.r 't-e tre installatien in

//

subsecuentir corrected b".i c

V'"

the ulant.

I dcnt remember if this, equipment uas used in SCMGS v

~

I reccerend th.-t the :'EC exacine.the ber; inning

' h'f,7 p,~<j7',,,9.. Units 2 or 3 7

to aasure rect v.enetratien at these 77/Mf.-7-l6 o and end of fillet welds #

iMt dest.J ed'cythisven5N[ctivetestingofselectedsuttortsto determine if other filleE uelds dlM-/~p/Zi, mud supp'N' and conduct

-aceas

.:::g'.gp s have inadequate root yenetrations Ci7 Ca ffss't 4.~p1 i%./,/yu'4y, r

y y,,.h

~ ~..... _

i (4) A steel bracke%.ae--c.h:-

between a Unit 1 hydrogen.line on f/

trip for steam generator.

This was done because the h;,-drogen line e

g iff,*g had worn thin due to rubbing with another line.

I believe main-tenance pecple at the site who we're vorhing during the period

.c f,,/p '. < p rf*.

hen decare due tc the Unit 1 diesel generater fire was being f
ccrrected uculd recenber and be able to locate the design jgf-g 'jyrg,fz j

change and s acer.

I don't recall the enact location of the e

hydrogea 7".

Tc my best racellection there :csn't equircent uithin ten feet.

I den't renember if there aas any nuclear safety-related equipment nearby.

I am concerned fcr the integrity of the :otential for loss of human life and firi.n.earby, and about,dhould this line nuclear safety-related equip =ent, if located ruct're.

I reconcend HRC conduct'an examination of this hydrogen u

line and cahe certain it has sufficient u 11 thickness to be N

safely oyer.,ted.,!fcf;,zigt #f, f j.& gjg;st gp },,ffJ.g.2,a,stg jp 73(spy

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AN' RTO5.Jff H150 TMtEbi;yJ C/r filiD /s(hz.Gkit;)}y'cz.Ypnf 7/m ' l j

(5) I agc:2ti.. that veld end returns are not recuired"on '.:ecntel e'

- 6 5 T N.v'

.VirIu'.ncs.

This is in vielation of.,yJS-D1.1, 'Sectt::n 6,fpara #

Wi p/ /,y/f.M'

raths o.5.6, 8.2.6.1, and 8.6.6.2."' These conditions exist en de-e 3

M e:-:: structural applic'ationCg,.4 tuo pa e 3echtel Feuer

~

/O/N'g 'Eali j

,y,4' Corporation table establisher. that coitain rire sup orts must k

4/yp c 72GF /J

g. ),

conferm to N.1S-D1.1 requirements.

(6) 3echtel Ccnstruction Snecification C'S - F207, 2cvision 7, Md dated istril' 18, loco, para ;ranhs 5.6 and 5 7, contains visual examinatien criteria used by Bechtel fcr pipe supports and

[.L

reference the ASME 3&FV Code,Section III, Subsection HF. I /,fA-f //f,4f/p teld Jo's.n_,C'3 ell, investicative re orter for the I.os A:yeles in accord-f pg/p/. <p.." 'Tifie's, thahthe visual criteria of CS - $2C7 are not Once uith r.e above code Tecuirerients, articu3 nrly.in CS - FP.07 vara r:nhs ~5 5.1.3 ( norosit" and sla:-). veld ccnvexity heicht accertnrre criterir., 'i.6.1.0 (underfilled ;ronve veld craters),

5.6.1.11 (arc stribe nece -tance criteri:, and 5 7.2 (allouids

-rocve velds with li13ct cans to be uelded as fillet uelds).

( [ U.' M 'i N O.) Y. A (7) 3echtel nenerated al2 pa e UCil en electfic;l tray tanc'ers.

I cuestion ui. ether the velds Pnde on electrien1 autrorts nrior r"f..:e o tr the dC reac1nticn ue:ej<fiuad.--- -.

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C) 2ech cl hns not}ccrrlied uiti-v:e reruire:.:ents' cf A.:.2 31.1 (1o/4 editionE nnrarr..hs 3 12.1... ( 2. 0.'; nn d s.15 1 3,

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.Js. gO JN ': -

rerardin<- fillinr; of o"en veld craters en ;;rcy h..ncern'to full 077!Gt a.

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u, s1 s.

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veh' w

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Cen:inued statemen: cf 2. Carl ;*en:.................. Fare 3 g

g c.jf, cross section of the veld.

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3),3 _sgg, r/z Bl. 4,W6 W $* *i g-y' fj /A//v//j (9) 3echtel h:s no'f removedjarc strikesj rom base =etal @ I e._, y d

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supycrts er strue: ural steel as required by N.!S D1.1 paragrath 4.4*

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/jsp }/c'T~B SB N.

be A (10) I cbserved instances where run off elates "~u st.used as required by id!S D1.1 paragraph I'.6 '? groove weld terminations.

o I cannot recall any specific locations, but I do recall ob-serving tSis condition en beam and girder splices,j-f ff/// /,/g/7 7

y 9 V' A r~,!-l&f4f*~ CMEC JMb/W/z s M (11) I believe that a seacer nlate is missing en the unner inside doer hince of the Unit 2' contain' ment personnel hat'ch because U

I observed a gap in the weld joint of about 1/4 inch.

I.. p f p g jj7 7g-brougn: this to the attention of my superviscrfaho also shared that belief.

I believe that by brint:ing this condition to the attentica cf my supervisor I had properly perferred my

, duty te identify this conditic:..

I did not centcre the draw-

).* g ing recuirecents to the installed ccndition in naking this 6/%.

deterzination cf a nissing apacer plate y [i.$41.pfi; pff'f 1.WC'fA/fCA-A$t'N INf'l0dnW4 TC,WS Wd'/~j l' M*M ")YG.[/diV9C/L! !%*S4?i/'1O" !.9/uZfsf~/y f t / (12) I believe that Zechtel has misinternreted the recuirements of r the ASI;I Section III welding stand:5-ds regarding ' socket weld f C enrac;ec ene. lenrth.uithout initiating a code case and obtaining /947&d 7L" 199rbyri*1:e code relief. Che ASHE. code requires ajag betueen fjjggp/j-y;. the pipe end and the fittin of"approxicately 1/.1r_o. inch". I e believe that the code shculd urovide a =cre definitive accentance criteria than cerely "approxi=ately 1/16 inch". fN/ g7.cA/7%,'%<Igfqgg,. ' / n%..J/m 'M't Oi:+.WNfic. t.pn;g '4 h (13) 3echtel specification WC-2,% dj /J MR.d1 rms P/M /S,r.wr.c sheet 20, note 1, requires "shall ,y 7* not exceed 1/3 inch..." recarding naximum groove veld reinforcement /tf /[/E-///M.:e'3~gQ This requirement should read "shall not exceed 1/8 inch..." '4b / Dv:dgj4'f "j.g,"jg y / as required by the ASI E Section III code on groove veld reinforcement. M' 'M. ot-The 1/3 inch.heich:fis=icelemented at San Cnofre. 'MM 5s;.414e Mnrdks.P M. f/gr(' (14) I believe that the caliber of individuals employed by Feabody Testing [t to perform ncndestructive examination (HDE) on welds in nuclear i service annli..c.a_tiens uns not accettable. This belief is based on 1.x " s. 4f the observation of many stelling errors, such as the incorrect..e g 0 ~ . f/6!//).'Eg'G'y,, pspellings of the words ' 'f'illet" and " weld",%ES ~r@FE'~p'repared . g ', by these individuals. Becausa cf these observed stellinegEWors, # #Nb I cuestien the abilities of these UDE personnel t'o perform the E N /Z ~~ '.^. A/ p f t'h$t ' e's:ab~1' led indus:R7 int'andards reg:rdinr:. the cualification of .J re uired examinatians as recuired by their procedures. I believe !.'r.4,.

!D2 persennel are not suf?icient to assure an adequate level of r

M E' personnel capability and knculedge in thi.s very importer.t area .l.\\{L7 0fd?T/"t-cf i=cisction-rml<'4/ca,' 2 4/f19 R,.K / I have rdviced the above nc=ed U.:.I tersonnel of other conc' erns I have re ardin.- inadequacies that I % 1=d,ciat' in ndustry Codes and Standards (i.e. A'.!S, A3::I, AI5C, etc ). The IGC represen:ctives have told =e that these areas are not ui:hin }the jurisdiction of the I!F.C and although I do _,, %Qag r.c rMW htmi//!.unaw tono, 4 ,e l ,* f$ { l, e l* oh e

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1 ./ j C cat inu e d St at eEen t o f E. Earl Kent.........................# b,..Fage 2 4 }{J*Y 09 ) not necessarily agree with this, I de understand that this -ia-the case.- The HRC rerresentatives have also told =e that I can retort my areas of E [dFi*W $ carding Codas to the avplicable code co=citt concern re i /~/ f6 /9. W 4 G N 6 l p, representatives that "I have many cencerns,4 g i en ncn-nuclear safety re!.ated systems and equipment.j,,, regarding welding done g I have been advised by the NRC representatives that these areas are also i nc within the jurisdiction of the NRC. The liRC representatives have told #4 ce that I can report these concerns directly to the utility, SCE, or g 'e whatever other local, state, or federal a5ency that has jurisdiction. hbl$ft $Wdi&Mo. ?!M15i/I r#c i UMi16p GVre,. lV66pll9%p M R 9 & t a m s Mro m T!!M.gggw'gsu9r; CK 4 i l m I l "m g e 9 l 1 l l t 2 ^

Continued State,.ent of E. Earl "ent...........................Page 3 I have read the foregoing statenent consisting of this and four other ~ typewritten pages. I have nade and initialed any necessary corrections and have signed cy na:e in ink in the nargin of each page. I suear that the foregoing statenent is true and ccrrect. Signed en at Signattire : E. Earl Kent. Subscribed and suorn to before ce this day of 1982 at i Investigator: I Cuen C. Shackleton Jr. Uitness: l Philip V. Jcukoff -investigator, O _S ___,0 .2 1 l m. , Y 4 6 m e e G 9 =N e 4 0 4

9 9809 Spruce Court Cypress, California 90630 Date: October 16, 1982 Time: ~~12:30 p.m. I, E. Earl Kent, voluntarily make the following statement to Messrs. Philip V. Joukoff and Owen C. Shackleton Jr., who have identified themselves to me as investigators for the U.S. Nuclear Regulatory Commission (NRC). I make this statement freely with no threats or promises of reward having been made to me. I am. 57 years old and have worked since June.1942 as a welder, welding quality control inspector, welding engineer, etc., and author of welding articles for welding journals. In January 1955, I received a diploma for completion of the Structural Engineering Course from the International Correspondence School, Scranton, Pennsylvania. I worked for Bechtel Power Corporation as a Senior Quality Control Engineer in welding at the San Onofre Nuclear Generating Station (SONGS) from October,1980 until August, 1981. During my employment at SONGS, I identified the following concerns which were identified to me by the NRC personnel who interviewed me on October 15, 1982 as possibly affecting nuclear safety systems, and oth'er items. i (1) Pipe fitters sometimes used pipe cutters to make scribe pg/ks for socket weld fitup measurements. These scribes marks caused grooves in both stainless and carbon steel pipes about 1" back from the-weld area. I am concerned that these grooves might cause stress raisers..These conditions exist on socket welded fittings at random in Units 2 and 3, and possibly a few in Unit 1. ' (2) Bechtel designers use fillet welds on connections of beams in pipe supports and tray hangers and often do not weld all around the joint to restrain forces in all directions. I feel this is a code violation. No proto-type tests, to my personal knowledge, were conducted to verify the adequacy of these welds. Therefore, the actual structural strength of the electr.ical tray hanger / tube steel welds used or the actual material at SONGS may not be truly known. This also applies to pipe supports. I also feel that the partial joint strength (less than full joint integrity) and failure to weld. all around the joint is a generic problem. Unfortunately, and in my opinion, the codes do not always demand fuel strength welding, whether all around or not. (3) ASME requires adequate root penetration of f.illet. welds. I recall that some of the vendor supplied welded hardware appeared to not have adequate root penetrations. The one vendor I can ' recall is Zack, I believe a supplier of HVAC equipment. I renember one ~

  • instance on a piece of Zack hardware where a fillet weld with inadequate welding was identified during inspection on site. This instance was subsequently corrected by weld repair after insttilation in the plant.

I don't remenber if this equipment was used in SONGS Units 2 or 3. I recommend that the NRC examine the beginning and cnd of fillet welds to assure root penetration at these areas, and verify that all craters are filled, and conduct destructive testing of selected supports supplied by this vendor to determine if other fillet welds, and groove welds, have inadequate root penetrations or other code violations. (4) A steel bracket would be placed, I was told, between a Unit I hydrogen line on trip for steam generator. This was done because the hydrogen line had worn thin due to rubbing with another line. I believe maintenance people at the site who were working during the period when damage due to the Unit I diesel generator fire was being corrected would remember and be able to locate the design change and spacer. I don't recall the exact location of the hydrogen line. To my best recollection, there wasn't equipment within ten feet. I don't remember if there was any nuclear safety-related equipment nearby. I am concerned for the integri,ty of nuclear safety-related equipment, if located nearby, and abo'ut the potential for loss of human life and fire, should this line rupture. I recominend NRC conduct an examination of this hydrogen line and make certain it has sufficient wall thickness to be safely operated. Most likely, I prevented a major fire in Unit 1, and probably saved the lives of several (or more) workers there. , [ (5) I am of the opinion that weld end returns are not required on Bechtel drawings. This is in violation of AWS-D1.1, Section 8, 1974 Edition, paragraphs 8.8. 6, 8.8. 6.1, a nd 8.8. 6.2. These conditions exist on details in many structural applications. A two-page Bechtel Power Corporation table establishes that certain pipe supports and other items must conform to AWS-D1.1 require-ments. (6) Bechtel Construction Specification CS-P207, Revision 7, dated April 18, 1980, paragraphs 5.6 and 5.7, contains visual examination criteria used by Bechtel for pipe supports and reference the ASME B&PV Code, Section III, Subsection NF. I may have told John O' Dell, investigative reporter for the Los Angeles Times, that I believe the visual criteria of CS-P207 are not in accordance with the above code requirements, particularly in CS-P207 paragraphs 5.6.1.3 (porosity and slag), weld convexity height acceptance criteria, 5.6.1.9 (underfilled groove weld craters), 5.6.l.11,(ate.s.trike acceptance criteria),and 5.7.2 (allowing groove welds with fillet caps to be welded as fillet welds). ^ (7) Sechtel generated (I was told) a 92-page NCR on electrical tray hangers. I question whether the welds made on electrical supports prior to the NCR resolution were adequately or completely fixed. ..-a

3-(8) Bechtel has not, in my opinion, complied with the requirements of 4 AWS-D1.1 (1974 Edition), paragraphs 5.12.1.5.(2).(b) and 8.15.1.3, regarding filling of open weld craters on tray hangers and other items to full cross section of the weld. (9) Bechtel has not, in my opinion, removed all arc strikes or blemishes from base metal on pipe supports or structural steel as required by AWS-Dl.1, paragraph 4.4. (10) I observed instances where run off plates had not been used as required by AWS-D1.1, paragraph 4.6, of groove weld terminations. I cannot recall any specific locations, but I do recall observing this condition on beam and girder splices, as supplied by at least 'one vendor. i (11) I believe.that a spacer plate is missing on the upper inside door hinge of the Unit 2 containment personnel hatch because I observed a gap in the weld joint of about 1/4 inch. I brought this to the i' attention of my supervisor (Don Martin), who also shared that belief. I believe that by bringing this condition to the attention of my supervisor I had properly performed my duty to identify this condition. I did not compare the drawing requirements to the installed condition in making this determination of a missing spacer plate, because my supervisor had indicated to me that it w'as the vendor's problem to correct it. I had other work to do immediately. (12) I believe that Bechtel has misinterpreted the requirements of the ASME Section III welding standards regarding socket weld ingagement length without initiating a code case and obtaining appropriate code relief. The ASME code requires a gap between the pipe end and the fitting of "approximately 1/16 inch." I believe that the code should provide a more definitive acceptance criteria than merely "approximately 1/16 inch." Evidently, Bechtel will allow any ' dimension, as long as the pipe is not totally withdrawn from the socket. (13) Bechtel specification WQ-2, sheet 20, note 1, requires "shall not 3 ~ exceed 1/3 inch..." regarding maximum groove weld reinforcement height at Midland Michigan's Twin Nuclear Plant. This requirement, should read "shall not exceed 1/8 inch.'.." as required by the ASME Section III code on groove weld reinforcement. The 1/3 inch height may be, also, mistakenly implemented at San Onofre. (14) I believe that the caliber of individuals employed by Peabody Testing and others to perform nondestructive examination welds in nuclear service applications was not acceptabTe7(NQE) on This belief is based on the observation of nany documentation mistakes i and spelling errors, such as the incorrect spellings of the words " fillet" and " weld," as " filet wel," on NDE reports prepared by m__ these individuals. Because of these observed spelling ~and other i (

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_4 errors,,I question the abilities of these NDE personnel to perform the reauired examinations as reauired by their procedures. I believe that established industry and Bechtel standards regarding the qualification of NDE personnel are not sufficient to assure an adequate level of personnel capability and knowledge in this very important area of inspection. I have advised the above named NRC personnel of other concerns I have regarding inadequacies that I know exists in Industry Codes and Standards (i.e.'AWS,ASME,AISC,etc.). Some of these allow inadeouate welding processes (for example, short-circuiting arc in gas metal arc welding). Adhesion instead of cohesion is possible in critical areas. The NRC representatives have told me that these areas are not within the jurisdiction of the,NRC and although I do not necessarily' agree with this, I do understand this may be the case. The NRC representatives have also told me that I can report my areas of concern regarding Codes to the apolicable code committee. However, where safety and life is at stake, I ask them to help my efforts as much as possible, not only at San Onofre, but all nuclear plants in the United States. I need help in resolving problems that I know exists. I further have advised the NRC representatives that I have many concerns regarding welding done on non-nuclear safety-related systems and equipment. I have been advised by the NRC representatives that these areas are also not within the jurisdiction of the NRC. The NRC representatives have told me that.I can report these concer'ns directly to the utilitf', SCE, or whatevet other local, state, or federal agency that has ju,rifdiction. e e . O e. O

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5-I have read the foregoing statement consisting of this and four other l typewritten pages. I have made and initialed any necessary corrections ]- and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on j at Si gna ture: E. Earl Kent 1 Subscribed and sworn to before me this day of 1982 at Investigator: Owen C. Shackleton Jr. i lli tness: philip V. Joukoff Investigator, 0ISFF0 a M e.- pu e 9 + a e ee s e g J , i, ,,_s. - -., , _., - -, + - * - - - -,,. _...,., -., _,,,,, + .,c- ,.c,w, .m, , a

l [ j Octo ber 19, 1982 On Saturday, October 16, 1982, at approximately 2:44 p.m., in the city of Cypress, California, E. Earl KENT stated to the undersigned that he would not sign his attached sworn statenent. Mr. KENT, in response to questioning, further stated that the statement, as amended by him, was tnje and correct as amended. ~. f INVESTI GATOR: y f, Ay / ~ den C. Shackleton Jr., Ac g Director, DISFF0 N' ! WITNESS: PhilipV.goukoff,InveR4fi,DISFF0 4 G m 4

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./ 0s,#o UNITED STATES l [\\3, NUCLEAR REGULATORY COMMISSION s \\ s REGloN V h 1450 MARIA LANE. SUITE 210

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,o WALNUT CREEK. CALIFORNIA 94596 OCT 2 91982 i MEMORANDUM FOR: Darrell G. Eisenhut, Director, Division of Licensing, NRR 4 FROM: Jesse L. Crews, Director, Division of Resident, Reactor Projects and Engineering Programs 4

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE j ALLEGATIONS BY E. EARL KENT (SAN ON0FRE) This memorandum is to confirm discussions on the above subject between R. H. Engelken and H. R. Denton and members of my staff (T. W. Bishop / D. F. Kirsch) and the NRR staff (H. Rood /D. Smith). I 1 i In the course of RV's special inspection (currently in progress) into l allegations by Mr. Kent, we recognized that some could potentially impact upon license issuance for San Onofre Unit 3, and that the resolution of some issues may require technical assistance from NRR. Attached.is a copy of a statement obtained from Mr. Kent which relates his principal allegations. Harry Rood has been of great help in coordinating NRR assistance in this . matter, and has arranged the participation of David Smith.. To date, discussions i have been held by telephone between my staff and Harry and David to keep them abreast of technical issues as they have developed. An early draft copy of the attached statement was provided to Mr. Rood, and Dennis Kirsch has had numerous telephone discussions with Mr. Smith on these issues. 1 At the present time, we anticipate the need for NRR technical assistance in the resolution of items (2), (5), (6) and (8) of Mr. Kent's statement. It is our intention to have a satisfactory resolution on all of the allegations i 1 by Mr. Kent prior to license issuance for San Onofre' Unit 3, tentatively estimated by Region V as November 15, 1982. Your assistance in this time frame would be appreciated. We have discussed with Messers. Rood and Smith the prospect of Mr. Smith accompanying NRR personnel on a planned visit to the San Onofre site on November 3, 1982. At that time, Mr. Kirsch will be in a position to provide a substantial amount of technical information related to the issues for which NRR assistance is requested. This visit will also provide an opportunity for additional discussion with SCE and Bechtel personnel relative to these issues, should that be necessary. Fp b o A fP

i Darrell G. Eisenhut OCT 2 91982 ? Your cooperation in this matter on relatively short notice is appreciated. Should you have questions, please give me a call. W. i Jesse L. Crew, Director Division of Resident, Reactor Projects and Engineering Programs Attachment a/s cc:w/ enc H. R. Denton, NRR T. A. Ippolito, NRR H. Rood, NRR R. L. Baer, IE 4 .. - - = -, - - _,,

t 9809 Spruce Court Cypress, California 90630 Date: October 16, 1982 Time: 12:30 p.m. I, E. Earl Kent, voluntarily make the following statement to Messrs. Philip V. Joukoff and Owen C. Shackleton Jr., who have identified themselves to me as investigators for the U.S. tiuclear Regulatory Commission (flRC). I make this statement freely with no threats or promises of reward having been made to me. I am 57 years old and have worked since June 1942 as a welder, welding quality control inspector, welding engineer, etc., and author of welding articles for welding journals. In January 1955, I received a diploma for completion of the Structural Engineering Course from the International Correspondence School, Scranton, Pennsylvania. I worked for Bechtel Power Corporation as a Senior Quality Control Engineer in welding at the San Onofre fluclear Generating Station (50tlGS) from October, 1980 until August, 1981. During my employment at SONGS, I identified the following concerns which were identified to me by the flRC personnel who interviewed me on October 15, 1982 as possibly affecting nuclear safety systems, and other items. (1) Pipe fitters somatimes used pipe cutters to make scribe marks for socket weld fitup measurements. These scribes marks caused grooves in both stainless and carbon steel pipes about 1" back from the weld area. I am concerned that these grooves might cause stress raisers. These conditions exist on socket welded fittings at random in Units 2 and 3, and possibly a few in Unit 1. (2) 'Bechtel designers use fillet welds on connections of beams in pipe supports and tray hangers and often do not weld all around the joint to restrain forces in all directions. I feel this is a code violation. tio proto-type tests, to my personal knowledge, were conducted to verify the adequacy of these welds. Therefore, the actual structural strength of the electrical tray hanger / tube steel welds used or the actual material at S0tlGS may not be truly known. This also applies to pipe supports. I also feel that the partial joint strength (less than full joint integrity) and failure to weld all around the joint is a generic problem. Unfortunately, and in my opinion, the codes do not always demand fuel strength welding, whether all.around or not. ) (3) ASME requires adequate root penetration of fillet welds. I recall that some of the vendor supplied welded hardware appeared to not have adequate root penetrations. The one vendor I can recall is Zack, I believe a supplier of HVAC equipment. I remember one .....a.s..

. instance on a piece of Zack hardware where a fillet weld with inadequate welding was identified during inspection on site. This instance was subsequently cor-ected by weld repair after installation in the plant. I don't remenber if this equipment was used in SONGS Units 2 or 3. I recommend that the NRC examine the beginning and end of fillet welds to assure root penetration at these areas, and verify that all craters are filled, and conduct destructive testing of selected supports supplied by this vendor to determine if other fillet welds, and groove welds, have inadequate root penetrations or other code violations. (4) A steel bracket would be placed, I was told, between a Unit I hydrogen line on trip for steam generator. This was done because the hydrogen line had worn thin due to rubbing with another.line. I believe maintenance people at the site who were working during the period when damage due to the Unit I diesel generator fire was being corrected would remember and be able to locate the design change and spacer. I don't recall the exact location of the hydrogen line. To my best recollection, there wasn't equipment within ten feet. I don't remember if there was any nuclear safety-related equipment nearby. I am concerned for the integrity 'of nuclear safety-related equipment, if located nearby, and about the potential for loss of human life and fire, should this line rupture. I recommend NRC conduct an examination of this hydrogen line and make certain it has sufficient wall thickness to be safely operated. Most likely, I prevented a major fire in Unit 1, and probably saved the lives of several (or more) workers there. (5) I am of the opinion that weld end returns are not required on Bechtel drawings. This is in violation of AWS-DI.1, Section 8, 1974 Edition, paragraphs 8. 8. 6, 8.8. 6.1, a nd 8.8.6.2. These conditions exist on details in mar.y structural applications. A two-page Bechtel Power Corporation table establishes that certain pipe supports and other items must conform to AHS-DI.1 require a ments. (6) Bechtel Construction Specification CS-P207, Revision 7, dated April 18,1980, paragraphs 5.6 and 5.7 contains visual examination criteria used by Bechtel for pipe supports and reference the ASME B&PV Code, Section III, Subsection NF. I may have told John O' Dell, investigative reporter for the Los Angeles Times, that I believe the visual criteria of CS-P207 are not in accordance with the above code requirements, particularly in CS-P207 paragraphs 5.6.1.3 (porosity and slag), weld convexity height acceptance criteria, 5.6.1.9 (underfilled groove weld craters), 5.6.1.11 (arc strike acceptance criteria),and 5.7.2'(allowing groove welds wi,th fillet caps to be^ welded _as..Lilht_ welds). (7) Bechtel generated (I was told) a 92-page NCR on electrical tray hangers. I question whether tae welds made on electrical supports prior to the NCR resolution were adequately or completely fixed. l

4 . l (8) Bechtel has not, in my opinion, complied with the re AWS-D1.1(1974 Edition), paragraphs 5.12.1.5.(2).(b)quirements of and 8.15.1.3, regarding filling of open weld craters on tray hangers and other i items to full cross section of the weld. (9) Bechtel has not, in my opinion, removed all arc strikes or blemishes from base metal on pipe supports or structural steel as required by AUS-D1.1, paragraph 4.4. (10) I observed instances where run off plates had not been used as required by AWS-01.1, paragraph 4.6, of groove weld terminations. I cannot recall any specific locations, but I do recall observing this condition on beam and girder splices, as supplied by at least one vendor. (11) I believe,that a spacer plate is missing on the upper inside door hinge of the Unit 2 containment personnel hatch because I observed a gap in the weld joint of about 1/4 inch. I brought this to the attention of my supervisor (Don Martin), who also shared that belief. I believe that by bringing this condition to the attention of my supervisor I had properly performed my duty to identify this condition. I did not compare the drawing requirements to the installed condition in making this determination of a missing spacer plate, because my supervisor had indicated to me that it was the vendor's problem to correct it. I had other work to do immediately. (12) I believe that Bechtel has misinterpreted the requirements of the ASME Section III welding standards regarding socket weld engagement length without initiating a code case and obtaining appropriate code relief. The ASME code requires a gap between the pipe end and the fitting of "approximately 1/16 inch." I believe that the code should provide a more definitive acceptance criteria than merely "approximately 1/16 inch." Evidently, Bechtel will allow any dimension, as long as the pipe is not totally withdrawn from the socket. (13) Bechtel specification WQ-2, sheet 20, note 1, requires "shall not exceed 1/3 inch..." regarding maximum groove weld reinforcement height at Midland Michigan's Twin Nuclear Plant. This requirement should read "shall not exceed 1/8 inch..." as required by the ASME Section III code on groove weld reinforceaent. The 1/3 inch height may be, also, mistakenly implemented at San Onofre. (14) I believe that the caliber of individuals employed by Peabody Testing and others to perfonn nondestructive examination (NDE) on welds in nuclear service applications was not acceptable. This belief. is based on the observation of many documentation niistakes and spelling errors, such as the incorrect spellings of the words " fillet" and " weld," as " filet wel," on NDE reports prepared by these individuals. Because of these observed spelling and other .,.a ~ ^

. errors, I question the abilities of these NDE personnel to,oerform the reouired examinations as reouired by their procedures. I believe that established industry and Bechtel standards regarding the qualification of NDE personnel are not sufficient to assure an adequate level of personnel capability and knowledge in this very important area of inspection. I have advised the above named NRC personnel of other concerns I have regarding inadequacies that I know exists in Industry Codes and Standards (i.e. AWS, ASME, AISC, etc.). Some of these allow inadeouate welding processes (for example, short-circuiting arc in gas metal arc welding). Adhesion instead of cohesion is possible in critical areas. The NRC representatives have told me that these areas are not within the jurisdiction of the NRC and although I do not necessarily agree with this, I do understand this may be the case. The NRC representatives have also told me that I can report my areas of concern regarding Codes to the applicable code committee. However, where safety and life is at stake, I ask them to help my efforts as much as possible, not only at San Onofre, but all nuclear plants in the United States. I need help in resolving problems that I know exists. I further have advised the NRC representatives, that I have many concerns regarding welding done on non-nucl~ar safety-related systems and equipment. I have been advised by the NRC representatives that these areas are also not within the jurisdiction of the NRC. The NRC representatives have told me that.I can report these concerns directly to the utility, SCE, or whatever other local, state, or federal agency that has jurisdiction. O e A M A N M d.aga Ma N C Ne o O 8 C I ^ ^^ ^A'^

i 5-I have read the foregoing statement consisting of this and four other typewritten pages. I have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on at Si gna ture: E. Earl Kent t. Subscribed and sworn to before ne this day of 1982 at Investigator: Owen C. Shackleton Jr. lii tness: Philip V. Joukoff Investigator, OISFF0 J 4 i 4 1 9 1 e I s e- =F-e b-eme + - y y w -g +eM w-cy y v --1 -pM-pem-m vy wy -C

4 Octo ber 19, 1982 On Saturday, October 16, 1982, at approximately 2:44 p.m., in the city of Cypress, California, E. Earl KENT stated to the undersigned that he would not sign his attached sworn statenent. Mr. KENT, in response to questioning, further stated that the statement, as amended by him, was tnJe and correct as amended, l 1 / ~ / 1 INVESTIGATOR: 7 2 ' ven C. S'hackleton Jr., Actyg' Director, OISFF0 WITNESS: M! Philip V.[oukoff, InveM4 f', DISFF0 9 5 f a h # .c e / i A d* ' $1 P- .j ^* J

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