ML20078N727

Marked-up Transcript of Ee Kent 831016 Statement Re Inadequate Welding Practices

ML20078N727
Person / Time
Site:	San Onofre, 05000000
Issue date:	10/16/1982
From:	Kent E AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20077K923	List: ML20077K919 ML20078N720 ML20078N723 ML20078N727
References
NUDOCS 8311020175
Download: ML20078N727 (10)

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9Co? Spruce Court Cypress, Califernic fiC630 Date toc.1chec /6, / Sn?

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Icr3 rent, voluntarily make the following stctement to

Iossrs. Philip V. Joukoff and Cuen C. Shackleton Jr. who have identified thenselves to me as investi;;ators for the U. S.

I!uclear 2esulatory Coccission (ICC).

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

Eun iTM t$4 I am 57 years old :nd have worked since 9--9. l?!@ as a M'

velder, uelding ouality centrol inspector, velding engineer FIl g and author of welding articles.for velding journals. In 19hd/g/[f3 I received a dipicca for completien of the Structural Engineer-,

ing Course fron the International Corres::endence School, Scranton, yennsylvania.

I worked for Eechtel Feuer Corcora-r g.

tien as a Genier quality Centrol Incineer in velding at the'

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.3an Cn%fre 1:uclear Generating Station (SCGS) fren October, 1900 until 4 tu Jer, 1981.

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During ny omnloyment at SCGS I identified the ic11ouing. cen-cerns which were identified to me by the ;CC personnel who in-tgrvieued me en October 15, 1982 cs pessibly affecting nuclear safot;.}systens, frN& cyggyz. /rggff, y*)g (1) Fi e fitters)g?Wi14Ws4 f/d i

. sed pire cutters to make scribo-carks for sechet veld 4itup =ecsurecents.

Th.:se scri O cr ks caused grooves irpoth stainless snd carben s, teel r.ipes about 1" back frca the weld area.

I ac con'ferned that f(/,',

these grcoves cight cause stress raisers.

These condi-tions e::ist on cochet welded fittin:

and 5 f.4ff/SLP A M. Win UNir/,fA;s ahi-=cver Units 2 c%

/rrAInwini (2) 3echt;el designers,'$b in uire supports cnd tray hcn :ers an use fillet velds en

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-[4f connections of be'A do not weld all around the ~'cint te restrain forces in all 70,d,P S?/7ic//M-d.iracjic,,ns.

I feel this is a cede violatien.

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tyne, test guere cenducted to verify the adecuacy of these f

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uelds.

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Therefore, the actual structural stren-th of the [b4f T electricci tray hancer/tu teel ucids used or the

<z actuni =cterial at Sc"GS not y uly Snoun.

This alsoj cite.:urtorts{#'I alsc*~ feel that the(TEI5ure /N/3MMg ar liis te

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to' veld c11'n'round the joint is a ceneric rroblem.

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.the, cedes de gg7,.fgit.<pff g'Cnfertunategfgnd.j_i"h,ng:.:igion, gng,/Q:--:

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I recall' thct cr=e of the vender sue lied uelded harduare e not have adecuate root ene:ratiens.

The ene vendor

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er of..1..C couin-I can recall in Zach, I believe a su...1:.

n:en t.

I retomber cne iratance en a gicce cf Inch harduare there a fillet weld with innieaua'te r " w.e:-radon IOEl C/////

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Ocntinued Statement of 2. Zarl Yent.......... l....Pa5e 2 tras identified durin:; inspection on site.f This instance.was

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subsequently corrected by wold repa'r be cree installation in V

the 3;1 ant.

I dont recember if this, equip =ent uns used in SCMGS

.. Units 2 or 3 I recommend thrt the :'RC enanine.the beginning 8

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77/d*T.'S' O

• and end of fillet welds to aasure root nenetration at these M

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f;?f!-ry/zy,J/J4 suppd'ed by this venEIr[ctive testing of selected suceorts -to areas and conduct destr qy have inadequate root penetrationsy C/2 Ca XW/c. ri.:.pf Vig.jycarc, r

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l, (f+) A steel braMeae--p-hed between a Unit 1 hydrogen.line on b

trip for steam generator.

This uns done because the h:,dro5en line e

i had worn thin due to rubbing uith another line.

I believe main-ggig *g tenance reo le at the ite who we're vorhing during the teriod b.U6h.I when dac'are due to th init 1 diesel (;enerator fire was being 5

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ccrrected uculd re=enber and be able to locate the design chenre and s acer.

I don't recall the e::act locr. tion of the

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j..L hydrogen line. To my best recellection there vasn't equircent e

uithin ten feet.

I dcn't rececber if there uns any nuclear safety-related equip =ent nearby.

I am concerned fer t!.e integrity of nuclear safety-related equip =ent, if located gearby, and a'cout the potential for loss of human life and fire,,, should this line rupture.

I reconcend HRC conduct an examination of this hydrogen line and cahe certain it has sufficient unl1 thichness to be

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. safely operat ed.jfc 77-4/,g 'fp J2 gji;A9 q,,J,,ff,J.fg..z pp,gg pig?g/pp.--l/

+H' fit &TI.d5/C/"f4/MD '1'l dht:yj CF f/Ji.Ws./4 h:M fc /t y h /c 2.Y ;,2 9 W t y

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l (3) I argc+2t+. that weld end returns are not recuirei en he;ntel

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This is in' violation of,A.y.!S-D1.1,'Sectibn 6,ipara- '

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3raths 8.6.6 8.0.6.1, and 8.6,6.2.'

These conditions exist en de-Mr g'/)/,y /pA' g t'a_1h e::==, structural applicatien,C a tuo pa e 3echtel Feuer

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/MNf Corporation table establishen that certain ei-e sup orts must ye,4(

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conform to A'c!S-D1.1 requirements.

- 4 N D / 7 7 4 /2 (6) 3echtel Construction Specification C'S - F207, Revision 7, I 7' N N dated Atril' 18, lo00, parar;ranhs 3.6 and 5 7, contains visual examinatien criteria used by Bechtel fcr 3.ipe supports and

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reference the ISTE S&FV Code,Section III, Subsection UF. I Af/f-f //ffpp:

told Jot.n_.C' Dell, investigative re orter for the Los I.ngeles 7 grf jp/. 'p. I' 7iiie~s, thahthe visual criteria of CS - F2C7 are not in accord-l ance uith tne abeve code recuirerients, particularly in CS*- F7.07 1

vara ranhs '.4.6.1 3 ( norosity and sla:-). veld ccnve::ity height

.6.1.9 (underfilled ;renve weld craters),

l nece-tnr ce c:-.tcrir.,

l 5 6.1.11 (are strike acce-tance criteric, nnd 5 7.2 (allouids.

-rocve velds with fi13 et car.s to be velded as fillet velds).

f.i~lt*H 7Np) DC (7) 3echtel r;cnerated n 92 =a e dCR cn electfic l tray 'hanc~ers.

,M' I ouestion ui. ether the welds Ande on electrien1 autrortn,rior ff tho uC roaclutien uere[fi::3 2.' # M p ;.9 ( c. W W. 9 t e

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(C) 3echtel hns not} ccr..: lied uith t'te recuirements' cf A!.i D1.1 3 12.1 5. ( 2. O') mid 6.15 1. 3,, __ _

of oren veld craters enitrcy h..nnernjto full,. y p

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(1674 edi-ion), -.rnera ;hs M'

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-H, Continued Statement of E. 2arl Kent..................Page 3

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cross section of the ueld.

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--i p//AfjvNj (9) Eechtel h:s no} ren'ovedgare strikes from base =etal d h,pg, q a

supports or structural steel as required by AUS D1.1 parcgrath 4.4 lates }" 9 J/c7*gtGR/ Q..

l.4 (10) I cbserved instances uhere run off p? groov n at used as required by AUS D1.1 paragraph 4.6 o e weld terminat. ions.

I cannot recall any specific locations, but I do recall ob-serving this condition on beam and girder splices,j-f ft//j /./g/p a

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y (11) I believe that a s:acer vlate is missing en the upper inside docr hinge of the ITnit 2 centainhent personnel hatch because M

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

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f,,y pg brougnt this to the attention of my supervisorf.<no also,

shared that belief.

I believe that by bringing this condition to the attention of my supervisor I had properly perferred my duty tc identify this condition.

I did not ccatare tne draw-ye ing require =ents to the installed cendition in naking this

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determinatica cf a missing spacer plate fig /s/pp:pf,vf QiXc///ftVL Al.4;b f

y INP/C)*/f~ 4 70,$/S TYd-f"l1'il/sUr )!!

(12>, I believe that 3echtel has misinte]rpreted the recuirements ofG[/GiVyC/L'f /7/4*S

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the ASMZ Section III welding standards regarding" socket weld

'(g. f en=agement lenrth.wi.thout Jnitiating a code case and obtaining ///S/M T4

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ap;Eofrikte code relief. Che ASME. code requires a' kap between,,,Qffpj}y, the pipe e.,d and the. fitting of"approxicately 1/[ inch". I believe t'.nt the code should urovide a core definitive accettance criterit. than nerely "approxthately 1/16 inch". [L/ p.ci/r$*ffd,y;rg-

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y#M (13) 2echtel specification UQ-2, % 4) LWs.J.$ TW P/,og /S/,wr9 tV/Ti4.

sheet 20, note 1, requires "shall not exceed 1/3 inch..." recarding caximum groove weld reinforcement f#M 7'-

/t f-/[/FM/Fh'eight This requirement 5culd read "shall not exceed 1/8 inch..."

g.gf"ffg/g/ 9 as req)uired by the ASME Section III code on groove veld reinfor

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'fi!//Al h $ $/E-The 1/3 inch. height is icelemented at San Cnofre.

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p7/g7 ~' (14) I believe. that the caliber.af individuals employed by Peabody Testing h to perform' nendestructive examination (IIDE) on welds in nuclea.t-service atelicatiens uns not acceptable. This belief is based on gH

. MI//fr//L';dhr;he observe er cf nany spellin8 errors, such as the incorrect.s gg t

0 pellin s a m wrds fillet" and " weld",

TDE reports prepared by these individuals. Because of these obse@rved spellin;(Mors, '

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I questien the abilities of these !!DE persennel to perform the EE8-j.M/p requi eiexaminatiens as required by their procedures. I believe

/that es aillanec.naustr72ntandards regarding, the. saalification of l

f, iItP r I !!O h4. ? pers~tersennel are not auf?icient to acaure an adequate level of ennel capability and :nculedge in this very important area

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I have ndvised the above na=edriiF.O tersonnel of other conc'ern's I have r

re ardinn inadequacies that I(54e?:Mcist' in Industry Codes and Standards (i.e. s.!S, A3"E, AI3C, etc.). The li2C representatives have told =e that' these areas are not within }the jurisdiction of the I!RC and although I do

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Continued State *=ent of E. Earl Kent........................

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not necessarily agree with this, I do understand that this -6 the case..

The DRC representatives have also told me that I can report niy areas of fiFF67?' R MG H.4r SnWS,.fMH Tnsw ?? P6 g

I further have advised the NRg M P' regard'ing velding done on non-n,rapresentatives thatuclear safet e cany concerns pp I have been advised by the NRC representatives that these areas are also not within the jurisdiction of the HRC. The URC representatives have told

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ce that I can report these concerns directly to the utility, SCE, or whatever other Iccal, state, or federal agency that has jurisdiction.'

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I Continued State;.ent of E. Earl Kent...........................Page 5 p

i I have r.ead the foregoins statement consisting of this and four'other typewritten pages. I have nade and initialed any necessary corrections a 0

have sign'ed my nane in ink in the margin of each page. I svear that the l-foregoing statement is true and correct. Signed on i

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I Signat0re:

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E. Earl Kent..

l4 Subscribed ~and suorn to before ne this 1982 at day of

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L Investigator:

s, Cuen C. Shackleton Jr.

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Philip V. Joukoff Investigator, OISF70 9'

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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. fluclear Regulatory Cornission(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 e Power Corporation as a Senior Quality Control Engineer in welding at the San Onofre Nuclear Generating Station (SONGS) from October,1980 until August, 1981.

k During my employment at SONGS, I identified the following concerns-if 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 mpfks for

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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 ve.rify the adequacy of these welds. Therefore, the actual structural strength of the electr.fcal 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 arcur.d thc 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 renember one '

2 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 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 integri,ty 'of nuclear safety-related equipment, if located nearby, and about 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 Most likely, I prevented a major}hickness to be safely operated.

fire in Unit 1, and probably saved the lives of several (or more) workers there.

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(5)

I am of the opinion that weld end returns are not required on Sechtel drawings. This is in violation of AWS-01.1, 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 AHS-DI.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 3&PV Code,Section III, Subsection NF.

I may have told John O' Dell, investigative reportar for the Los Angeles Times, that I believe the vi:u-1 rit:.-b Sf CS-P207 are not in accordance with the above

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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), 5.61.11.(ate. s.trike acceptance criteria), and 5.7.2 (allowing groove welds with fillet caps to be welded as fillet welds).

(7) Bechtel 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.

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(8) Bechtel has not, in my opinien, complied with the re AWS-D1.1 (1974 Edition), paragraphs 5.12.1.5.(2).(b)quirementsof 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

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from base metal on pipe supports or structural steel as required by AWS-D1.1, paragraph 4.4.

(10) I observed instances where run off plates had not been used as.'-

required by AWS-DI.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 s.

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

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ASME Section 111 weining 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 lo.ng as the pipe is not totally withdrawn from the socket.

(13) Bechtel spec 1fication WQ-2, sheet 20, note 1, requires "shall not exceed 1/3 inch.;." regarding maximum groove weld reinforcement height at Midland Michigan's Twin Nuclea,r Plant.

This requirement.

should read "shall not exceed 1/8 inch..." as required by the ASME Section III ccdd cr. grceve weld reinforcement.

may be, also, mistakenly implemented at San Onofre.The 1/3 inch height (14) I believe that the caliber of individuals employed by Peabody l

Testing and others to perform nondestructive exam.ination I

welds in nuclear service applications was not acceptabfe!(NQE) on This belief is based on the observation of nany documentation mistakes 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-l l

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errors..I question the abilities of these NDE personnel to. perform

• the required examinations as required 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 crit.ical 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 hive nany 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 utilit?', SCE, or whatevel other local, state. or federal agency that has jurispiction.

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I have read the foregoing statement consisting of this and four other typewritten pages.

I have made and initialed any necessar and have signed my name in ink in the margin of each page.y corrections I swear that the foregoing statement is true and correct.

Signed on L

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Signature:

E. Earl Kent Subscribed and sworn to before me this day of 1962 at Investigator:

Owen C. Shackleton Jr.

Ili tness:

Philip V. Joukoff Investigator, OISFF0 j

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