ML20129A569
| ML20129A569 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/12/1984 |
| From: | Stokes C AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20129A429 | List:
|
| References | |
| FOIA-84-745 NUDOCS 8506040659 | |
| Download: ML20129A569 (11) | |
Text
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Armcheur
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2-Affidavit My name is Charles Stokes.
I am submitting this affidavit to the Nuclear Regulatory Commission (NRC) to inform them of material false statements and other evidence of activities which could compromise the quality of the Diablo Canyon nuclear power plant, if it should be turned on.
l The misconduct involves welding, procedure qualification tests, and plant modifications during the hot functional tests.
In my professional judgment, if these issues alone are confirmed as examples of general practices, the plant could not possibly be licensed to go critical under the NRC's legal requirements in 10 C.F.R.
In fact, the practices revealed below and others I have disclosed would even flunk Bechtel's own standards.
I am enclosing as Exhibit 1 portions of Bechtel's " Field Engineer Pocket Hanger Reference," Of ablo Canyon Project, Bechtel Power Corporation. Bechtel's booklet is not a bad document. Although there are a few minor errors, it describes a reasonable design control and qualityassurance(QA) program.
Unfortunately it was not issued on-site before I left.
I obtained a copy before distribution was stopped.
I can understand why Bechtel didn't want the booklet released. The plant wasn't built at all like the system described in Bechtel's own handbook. The handbook will be discussed in more detail below.
(1)
In reply to PG&E's letters no. OCL-84-067 and no. DCL-84-078 concerning welding of A-325 bolts.
PG&E contends that "10 supports were identified which used welded A-325 bolt design." That is highly misleading.
In reality, there are many more cases where bolts have been used.
8506040659 841211 PDR FOIA DEVINEB4-745 PDR
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Because of inadequate documentation, welded bolts have been used and it is impossible to say whether they are A-325 or A-307 or anything else.
Even QA Personnel concedes not knowing.
In two specific cases, for which I can provide the support numbers, undocumented bolts were used to connect support members to structural steel.
In my opinion, PG&E's reply is so far from complete that it does not provide accurate information to the NRC concerning the use of A-325, A-307 or other bolts.
The two specific supports do not even have a weld symbol describing how they were welded on the drawings.
The QA inspector was not able to visually inspect the connection.
(2) A second illustration of deficient documentation for welding bolts is inadequate material traceability. Material was not stamped for traceability back to the Certificates of Compliance as required. The significance of stamping for traceability is that without this traceability there existed no methodology to ensure that the material used in many hangers, or other seismic class one structures, complied with the requirements (e.g., proper metallurgical properties).
In ANSI B31.7 chapter 10723, entitled " Materials," it is stated that "all material shall be clearly identified" by "the applicable material I
specification and grade, heat number, or heat code of the material, and any additional markings required to facilitate traceability of the reports of l
l the results of all tests and examinations performed on the material." Ah!!
i B31.7 also states that "Certificant of Compliance with the material spedfica-l tions may be provided in lieu of Certified Material Test Reports unless other-I wise required by the design specification." (Emphasisadded)
3-Material traceability is only one aspect of the required traceability.
In ANSI B31.7 Para. 1 727.5.3 and Para. 1-727.6, weld traceability is also required.
"The welder or welding operator shall identify it as his work by applying his assigned symbol for permanent record in a manner specified by his employer.
As an alternative, the employer shall keep a record of the joints and of the welders working the joints." This is also true under ASME Section IX QW-301.3, entitled " Identification of Welders and Welding Operations," which states:
"Eace qualified welder and welding operator shall be assigned an identifying number, letter, or symbol by the manufacturer or contractor, which shall be used to identify the work of that welder or welding operator."
In discussions with Pre-inspection Engineers, QC and QA inspectors, some of whom have worked for as long as ten years at Diablo, it is obvious that neither material nor welder traceability was maintained. All that was required was that the " Certificate of Compliance" be provided. This super-ficial attempt to comply with the requirements of ANSI B31.7 and ASME Section IX does not satisfy the code requirements. This is evidenced by past and present industry practice at other plants across the United States.
The abuse of traceability distroys the foundation of a valid Quality Control Program -- accountability and traceability.
Since many of the pre-inspection engineers and QC, QA personnel have never before Diablo worked at a nuclear plant nor othe'r heavy industry construction site nor read ANS! B31.1, B31.7 or ASME Section IX, they worked at Diablo under the false assumption that the work was being performed correctly, and that management was implementing all the necessary directives for them to do their work. Management did not train personnel, nor did they correct this misconception.
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4 Having worked on other nuclear plants, I know the importance of these sections in ANS! B31.7 and ASME Section IX. At other plants almost everything in Class I systems was stamped and logged, and records were kept to insure that traceability was maintained.
Per 831.7, "The marking or marking code shall be transferred to all pieces when material is cut to make more than one piece." In my experience at other plants, this was required for all Class !
material except miscellaneous material, such as " gaskets, packing, seals, springs, bearings, retaining rings, weshers, fluids for hangers, etc." This was not done at Diablo Canyon. The practice of using "non traceable" steel was widespread throughout the plant. At other plants shim stock was not required to be stamped, and I suppose shim stock was considered to be "etc."
B31.7 states in the case of miscellaneous items that "A list of such materials shall be furnished, and such materials.do not require certified materials test reports or certificates of compliance as defined in 1-723.1.2."
(Emphasisadded) Management at Diablo Canyon have failed to provide the chain of documentation which is necessary under 10 C.F.R. 50 before the plant can be operational. Not only did they fall to provide an "up-to date heat number log," but also failed to publish a list of material that did not have to meet the scrutiny of ANS! B31,7.
(3) Deficient training reinforced the problems, and perpetuated them.
QA inspectors told me that their training consisted of reading ESO 223 for one week and being given a list of suggested reading. This list contained 831.7, B-31.1 and other codes, in one conversation, when I asked if'the QC inspectors were required to read the suggested readings, his reply was "no, we only had l
to know what 831.7 was, not what it says."
"I and others thought that these codes had been incorporated into ESO 223 by management." This was, and remains, a wrong assumption. The inspectors undoubtedly performed to the best of their
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ability. However, the instruction, training, and practices necessary to adequately perform their functions were deficient. The inspectors only discovered their " wrong beliefs" through discussions with better trained, more experienced inspectors from companies other than PG&E.
(4)
In letter no. DCL 84-094, PG&E states, " Pipe support number 100-111, 7
identified for NRC review by Mr. C. Stokes, resulted in a minor modification
... This change was made for consistency with Project Standard Practices l
even though analysis showed the change was not necessary to meet acceptance criteria."
! don't know if PGSE reported other modifications performed during the hot functional testing to the NRC.
I do know of at least one other support I
which was modified during hot functional testing.
I can not give the support l
J number here. My informant would be tsunediately on the " firing" line.
I will supply the support number to NRC inspector Isa Yin, if the NRC supplies a list of supports to me for which they know modifications have been performed.
(5)
In PG&E's answer to the intervenor's motion to reopen Itcensing issues on Construction Quality Assurance, " Affidavit of 0. A. Rockwell, L.R. Wilson,"
Paragraph 3 states in part: "Since this contact is provided by the plate of l
the clamp to the Unistrut, the plate is not necessarily horizontal and may f
appear ' cockeyed.'" This statement is too incomplete to be meaningful.
I The use of the term " cockeyed" is not explained or supported nearly enough to support any conclusion that the clamping plates were correctly installed.
If incorrectly installed, the clamp will tend to slip off the structural steel to which it is attached. See sketches below of correct installation compared to incorrect installation.
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m Correct. Notice Line contact at Incorrect. Line contact but not at toe and heel of plate. When bolt toe. When tongued, this tends to slip is tongued properly, clamp should off the steel marker.
not be easily displaced.
In both the examples above, the plate is " cockeyed." One is correct, and if installed correctly, should not be easily moved. On the other hand, the incorrect installation could slip easily. This fact can be checked by l
consulting engineering manuals fromeither Unistrut. Superstrut, or other f
brand names.
(6)
In paragraph 5 as a remedy for possible slipping, PG&E states, "For support type 5221, U-bolts were torqued and U-bolt nuts tack welded.
For other support types, the Unistrut channel was directly welded to the beam fl ange. "
(Emphasis added) Based on my experience in the nuclear industry, the proposed fix by PG&E/Foley would do more damage than good. To my know-ledge, there are no engineering documents presently available or in use that support the practice of welding Unistrut or similar material.
In fact, the material type used in making "Superstrut" and similar products should not be welded In a phone call on 3/27/84 with a Superstrut Product Engineer, I was told that Superstrut is coated with an electro-plated galvanized chromate coating (an epoxy paint) which burns when welded, giving off toxic gases.
Two problems result from welding it.
(1) Air quality problems for the welderand(2)thejointcorrodes. The Product Engineer said he would never
7 advise that Superstrut be welded when used as Class I supports in a nuclear i
j plant near, the ocean. He said that the material could be destroyed in one f
year if exposed to adverse conditions.
(7)
In reply to intervenor's Petition to reopen Construction Quality Assurance, Affidavit of H.R. Arnold. F.C. Breismesiter and R.K. Rhodes Paragraph 6.
"During a planned review of existing brazing procedures for copper and stainless steel by Foley QA Personnel in September 1981,1,t, could not be verified that stainless steel tubing PBS number M0045 had been qualified in all braze flow positions (vertical-up, vertical-down, horizontal and flat) since the procedure qualitfication tests performed in 1977 did not include the vertical-up flow position. This variation was properly documented on Foley Non-Conformance Report (NCR) #8802-675 in accordance with approved procedures."
(Emphasisadded) The statement quoted above is in direct contradiction to the first line in Para.1 and line, Page 1.
"This allegation is completely false. The procedures in question were qualified prior to their use."
(Emphasis added) To correct this problem, l
one worker was tested. Under ANSI B31.7 and A$ lie Section IX, each welder
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must be qualified to perform the work to which he is assigned.
Foley's solution does not correct the use of the procedure from 1977 to 1981 for i
l brazing a vertical-up joint as was originally stated in the procedure.
I Nor does it resolve the issue as to whether the brazers before 1977 were g
qualified to perform work. The test of one worker does not satisfy ASME requirements that each worker be qualifted unless the worker tested was the only person on-site who was assigned the brazing work. Nor do the present 8
tests qualify old work, since past. work could be considered training thus I
not qualifying as acceptable work. ASME section IX requires that the welder be qualified first before work is performed.
There is a reason for this,
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which is to ensure that the work is performed correctly. The other point not sufficiently covered in Foley's reply is that "Neither the ASME Code nor i
Foley procedures require documentation of these inspections. Therefore none were documented." Nor in the statement that "ASME Section IX recognizes the function of independent mechanical test contractors such as Central Coast Lab, and does not requre them to witness the actual brazing."
(Paragraph 3, page6and7) This is an example of Management 's near-sightedness.
Can they say that this documentation is not rv. quired in 831.1, 831.7, ASME Section IX, AWS D1.1-79 or 10 C.F.R7 From my previous experience in the nuclear industry, it has been the practice to test and document results therefrom for welders. This would certify that the weld was made by the specific welder and that the test results were for the welds performed by that individual.
These logs and records were controlled and monitored by the QA. The policies at Diablo by PG4E, pullmen, and Foley are at the opposite end of the scale from what has been typical industry practice. Where documentation was in question, other plant owners considered it good engineering practice and a good policy to go ahead and provide documentation to prevent the problem of a future question. At Diablo, just the opposite is true, i
(8)
In a discussion with a friend, I was shown a Discrepancy Report written against Unit #2. This document Itsted many anchor and smaller supports which did not have acceptable full penetration welds at the stantion to pipe and l
were to be reworked. The problem with this work was that there had been no process sheets issued for the removal nor had the pipe been ultrasonically tested to ensure that the minimum wall remained after grinding away the old material.
The new stanchions were installed without an ultrasonic test (UT) being performed. The tests were performed seven months later.
Per ASME Section IX and ANSI B31.7, the ultrasonic testing should have been conducted
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j at the-Ume-efter removal and before new stanshions were welded in place.
When ultrasonically testing this type of joint, incorrect readings are possible.
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A worker who was familiar with this Discrepancy Report (DR) on Unit 2
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realized the same problem might have occurred on Unit 1.
I was shown a I
copy of a Preliminary Discrepancy Report listing about 15 supports in Unit 1 which the worker had determined had the same problem as the Unit 2 problem.
narrated above.
I can supply the OR number on Unit 2 and the author of the Unit.1 DR. This will be suppled under similar conditions listed on a previous issue to Isa Yin.
(9)
In closing and as the only exhibit to this affidavit, I have a copy of a document which was scheduled to be issued to all field engineers to aid them in their work at Diablo.
It was prepared by Bechtel Power Corporation.
The title of this document is Field Engineer Pocket Hanner Reference. This document was sent to the field for issuing, but was recalled under the excuse that it contained errors which needed to be corrected.
! and other engineers at Olablo had copies of this document.
It contains valuable information to which an engineer could refer and rely upon during his work.
In truth, this document represents Bechtel policy at previous jobs.
Neh of it is in direct contradiction to the procedures used to build Otablo. Had it been issued many problems would have surfaced in a relatively short time. Why is this 'true?
The document puts at finger tip location contradictory guides, providing typical industry practice in many areas, to the procedures and management directives issued at Diablo.
There are minor errors in this document. However, I have reviewed it and have found it to,be a valuable and handy document to have when working in the field.
It should have been checked, corrected, issued and used.
C
. i Enclosed are pages 1-10 and 1-11. " Notes: Pipe Insulation Chart."
In reading these two pages several points are evident which were not complie(,
with at Diablo:
(1) vapor barrier requirements; and (2) the application of a double layer of insulation on high thermal lines.
In PG4E's answers to the staff concerning stress walkdown, they tried to explain away inter-forences by local crushing of calcium silicate. Note, this is not acceptable on Page 1-10.
Also enclosed is a copy of page 1-13. " Insulation Removal Request Flow Chart" and page 1-14. " Request for Insulation Removal."
I am not aware of either of these procedures being followed at Diablo.
l Also enclosed is a copy of Section 7. " Welding Instruction." On page 7-2, item 15, it is stated that there are no dihedral angle limitations for skewed T-joints.
I feel this policy will cause problems by design personnel failing to consider welds shown as fillet as partial penetration groove welds unless a note specifically stated that it should be considered otherwise.
I personally know rany engineers will assume a fully effective throat for any weld indicated as a fillet.
I suggest a test at site on this point before a decision is mada on how to represent a skewed T-joint.
t' Also on page 7-5, see " attachment !."
Either I don't understand this table or no allowance was added for the throat deduction for inadequage penetration.
This last conclusion was also that of a pre-inspect engineer at Otablo Canyon.
Lastly, on pages 7 7 thru 7-10, I would Itke to point out the concise clarification of weld symbol terminology. Had this part of the book been in effect at Diablo, many questions would have been resolved (although many
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11 ether questionable practices would have become evident to many field personnel).
I have read the above 11.page statement and it is true and correct to the best of my knowledge and belief.
h Charles Stokes l
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GOVERNMENT ACCOUNTABluTY PROJECT I institute for Policy Studies 1901 Que Street. N.W., Woshington. D.C. 20009 (202)234 9382 March 2, 1984 Mr. Thomas Bishop Division Director U.S. N.R.C. Region Five 1450 Maria Lane, see 210 Walnut Creek California 94596 Re: PACIFIC GAS AND ELECTRIC (Diablo Canyon Nuclear Power Plant, Unit 1), Dkt. No. 50-275
Dear Mr. Bishop:
Enclosed with this letter is a copy of a ' petition filed with the Commission pursuant to 10 C.F.R. 2.206 on March 1, 1984, together with Attachments 1 through 17 thereto. Also enclosed for your use, bound separately in this package, are three documents that were not included in the petition filed on Febru-ary 2, 1984: Exhibit 4 to Attachment 2, and two Discrepancy Reports inadvertently omitted from Attachment 7. Best wishes in your continuing investigation. Sincere
- yours,
___I k o Clewett
Enclosures:
A/S 94cemn 2S - _ _ _}}