ML20132C955
| ML20132C955 | |
| Person / Time | |
|---|---|
| Site: | Midland, 05000000 |
| Issue date: | 04/12/1985 |
| From: | Hood D Office of Nuclear Reactor Regulation |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20132C960 | List: |
| References | |
| FOIA-85-249 NUDOCS 8505010026 | |
| Download: ML20132C955 (4) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
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April 12, 1985 Docket Nos. 50-329 and 50-330 MEMORANDUM FOR:
Hugh L. Thompson, Jr., Director Division of Licensing THRU:
Thomas M. Novak, Assistant Direct for Licensing Division of Licensin Elinor G. Adensam, Chief f
Licensing Branch No. 4 Division of Licensing FROM:
Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing
SUBJECT:
RECOMMENDATION FOR SUPPLEMENTAL BOARD NOTIFICATION REGARDING GAP LETTER ON NRC's HANDLING OF E. KENT ALLEGATIONS - MIDLAND PLANT, UNITS 1 & 2 The enclosed letter of March 6, 1985, from Ms. B. Garde asks the Commissioners to appoint a member of the ASLB to review, investigate and issue findings about the NRC staff's handling of the allegations of Mr. Earl Kent.. Mr. Kent's allega-tions are the subject of contentions by Ms. M. Sinclair which have been admitted, but not yet litigated, in the Midland OL hearing. The letter and its several attachments are supplemental to previous Board Notifications82-117 and 83-102.
I recommend that the Midland ASLB be advised of this information according to the procedures of Office Letter 19.
g rL Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosure:
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Docket Nos:
50-329 OM, OL 50-330 GM, OL MEMORANDUM FOR:
Chairman Palladino Comissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech FROM:
Hugh L. Thompson, Jr., Director Division of Licensing
SUBJECT:
SUPPLEMENTAL BOARD NOTIFICATION REGARDING WELDING-RELATED ALLEGATIONS AT MIDLAND 1 AND 2 (BN 85-045)
This supplemental Notification is provided directly to the Commission in accordance with NRC procedures regarding Board Notifications.
The information is deemed material and relevant to issues before the Board in the Midland OL hearing.
The appropriate Boards and parties are being informed by copy of this memorandum.
g In Enclosure 1 dated March 6, 1985, Ms. B. Garde asks the Commissioners to appoint a me.mber of the ASLB to review, investigate and issue findings about the NRC staff's handling of the allegations of Mr. Earl Kent.
Mr. Kent's allegations are the subject of contentions by Ms. M. Sinclair which have been admitted, but not yet litigated, in the Midland OL hearing.
The letter and its several attachments are supplemental to previous Board Notifications82-117 and 83-102.
The staff notes that the Board and hearing parties are on the service list for direct receipt of Mr. C. Norelius' March 22, 1985, letter (Enclosure 2) to Consumers Power Company.
That letter forwards a report-by our contractor, Brookhaven National Laboratory, addressing Mr. Kent's allegations.
It also sets forth the NRC's plans for resolution of these allegations relative to the Midland Plant.
Hugh L. Thompson, Jr., Director Divisinn of Licensing
Enclosures:
As stated cc: SECY (2)
C. Bechhoefer, ASLB OPE J. Harbour, ASLB OGC F. Cowan, ASLB EDO A. Rosenthal, ASLAB Parties to the Proceeding T. Moore, ASLAB ACRS (10) 3 l
o MIDLAND BN ADDRESSES Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Stewart H. Freeman Assistant Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Ms. Julie Morrison Midland Daily News 124 Mcdonald Street Midland, Michigan 48640 Mr. R. B. Borsum Nculear Power Generation Division Babcock & Wilcox 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 Mr. Don van Farrowe, Chief Division of Radiological Health Department of Public Health P.O. Box 33035 Lansing, Michigan 48909 Resident Inspector's Office U.S. Nuclear Regulatory Commission Route 7 Midland, Michigan 48640
-Mr. Paul A. Perry, Secretary Consumers Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 Mr. Walt Apley c/o Mr. Max Clausen Bettelle Pacific Northwest Labs SIGMA IV Building Battelle Blvd.
Richland, Washington 99352 Regional Administrator, Region III U.S. Nuclear Regulatory Commission, 799 Roosevelt Road Glen Ellyn, Illinois 60137
41.
.l MIDLAND BN ADDRESSES (CONT'D - PAGE 2)
Mr. Ron Callen Michigan Public Service Commission 6545 Mercantile Way Lansing, Michigan 48909 Geotechnical Engineers, Inc.
ATTN:
Dr. Steven J. Poulos 1017 Main Street Winchester, Massachusetts 01890 Billie Pirner Garde Director, Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W.
Washington, D.C.
20009 Commander, Naval Surface Weapons Ctr.
ATTN:
P. C. Huang White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Mr. I. Charak, Manager NRC Assistance Project Argonne National Laboratory 9700 South Cass Avenue Argonne, Illinois 60439 ATTN:
Clyde Herrick Franklin Research Center 20th & Race Streets Philadelphia, Pennsylvania 19103 Mr. Patrick Bassett Energy Division Norwest Bank Minneapolis, N.A.
8th and Marquette Minneapolis, Minnesota 55479
Dircks GOVERNMENT ACCOUNTADIUTY PROJECT 1555 Connecicur Avenue, N.W., Suite 202 stello
[ Washington. D.C. 20036 (202)232 8550 Denton (GCunningham Keppler 3of" 1
March 6, 1985 EDO R/F Chairman Nunzio Palladino Commissioner Thomas Roberts Commissioner James Asselstine 2
Commissioner Frederick Bernthal Commissioner Lando Zech U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Commissioners:
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The Government Ac' countability Project regretfully requests that the Commissioners appoint a member of 'the Atomic Safety and Licensing Board (ASLB) to review, investigate and issue findings about the Nuclear Regulatory Commission Staff's handling of the allegations of Mr. E.
Earl Kent.
We request this procedure because, frankly, the system established by your agency to protect the public's health and safety has failed for three years.
And, it continues to fail to provide adequate responses to the questions raised by Mr. Kent as well as those raised by the public about the NRC's gross bungling of this matter.
Mr. Kent's experience with your agency has involved inspections by two Regions, the Office of Nuclear Reactor Regulation (NRR), the Office of Investigations (OI), the Office of Inspector and Auditor (OIA), and now the Brookhaven National Laboratories (BNL).
Yet, his concerns about the
. generic welding procedure deficiencies remain unanswered.
If the OIA and BNL investigations had been competent and I
thorough, our request would not be necessary.
Unfortunately, the OIA report is sophomoric, self-serving and short-sighted.
The BNL report, although not yet publicly issued, is, allegedly, a regurgitation of the same flawed analysis that has plagued this inspection and investation from the outset.
This request is not filed under 10 C.F.R. 2.206.
The Staff., through its numerous branches, has had many opportunities to address Mr. Kent's alleg'ations and/or the inadequacies of the agency's inspection efforts.
Instead, we request the 3
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March 6, 1985 Commission exercise its authority and appoint a judicial proceeding, conducted by the agen'y's adjudicatory branch.
c Backcround Three years ago, in March 1982, E. Earl Kent was fired from his job as a Bechtel Quality Engineer at the now-defunct Midland nuclear power plant.
terminated because he could not adjustHe was told that he was being to the way things were being done at Midland.
He was also told by his Bechtel super-visors that he had f ailed the oral part of a Level I examination.
Mr. Kent knew then, as he knows now, that he was fired from the Midland site because he found and reported too many serious problems with the welds, the qualifications of the welders, the welding techniques and procedcres, and the quality of the plant.-
Mr. Kent immediately reported his concerns to the NRC through Region III inspectors.
Soon thereafter, he also reported his concerns to a local citizen intervenor.
In July 1982, he submitted, through the Government Accountability Project (GAP), an affidavit outli.ning his concerns about the Midland welding defects.
In August 1982, Mr. Kent visited Region III to check on the status of the investigation into his concerns.
Region III had nothing to report to hi=.
They did not tell him that, at that time, Region III had already decided that his concerns were of no safety significance.
In early September, af ter he (!c:. Kent) decided to contagt Southern California Edison (SCE), the owner of San Onofre Nuclear Generating Station (SONGS),and tell them, as opposed to telling the NRC or Bechtel, about the generic welding procedure deficiencies, his allegations were dismissed almost immediately by SCE.
However, they were duly reported to the Region V NRC office.
The NRC accepted the disposition of Bechtel and SCE without comment.
Mr. Kent then contacted the local citizen interve'nor group in California, the Alliance for Survival (Alliance), and told them of his concerns, and his frustrations about the failure of the NRC and SCE to study his safety concerns about defective Bechtel welding procedures.
The Alliance put Mr. Kent in c'ontact with a Los Anceles Times reporter, Mr. John Odell.
In October', Mr. odell began calling the NRC and SCE and Bechtel to get to the bottom of the problems Mr. Kent had raised.
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Page Threa March 6, 1985 On October 13, 1982, article about Mr. Kent and his concerns.the Los Anceles Times ran a large The bureaucratic reasponse was swift.
OI, in concert with Region V, immediately interviewed Mr. Kent.
Some weeks later, they took him on a site tour of San Onofre.
Less than six weeks later, the NRC released, at a press conference, its ins Kent allegations - pection and investigation effort into the which. reveal ~ed, predictably, that there was no substance to his allegations.
For six months, the NRC conclusions. GAP investigators probed the basis for In a June 20, 1983, letter, GAP reported the results of its probe to the NRC Commissioners and Congress.
Another six months passed and in January 1984, its own probe into the Kent Affair.
CIA began That report was submitted -
to the Commissioners for their review in April 1984, and was obtained'by GAP in July 1984.
ib the fall of 1983, Region III submitted Meanwhile, the Kent materials to BNL for an analysis of the generic welding concerns raised by Mr. Kent about the Bechtel. welding procedures at Midland, San'Onofre and the Palisades nuclear power plant.
That study has been completed by BNL and submitted to the NRC.
It has not yet been released to the public.
Since BNL has never contacted Mr. Kent to determine what his allegations are, GAP does not expect the BNL report to adequately answer Mr. Kent's concerns.
The Report of the Office of Inspector and Auditor
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On April 4,.1984, the Acting Director of OIA issued his repett to the Commission on their investigation of the Kent Affair.
The OIA investigation was prompted by a June 20,
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1983, letter from GAP to the Commissioners regarding the fumbled Staff efforts to deal with the Kent issues up to that time.
The report, released to GAP under FOIA, is enlightening --
both on the issues the report addresses and on those it does not.
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To summarize, the report confirms the following allegations about the NRC Staff's actions:
(1)
Region III " sat on" the allegations of generic welding problems provided to it by Mr. Kent from March through October 1982.
(OIA Review of a Government Accountability Project Complaint Concerning NRC's Treatment of E. Earl Kent, at 1).
(2)
Region III's OI investigator provided to Region V investigators' only " credibility" (i.e., defamatory) information about Mr. Kent (given by Bechtel to the NR'C).
(Id. at 2).
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(3)
Region V OI investigators utilized " strict interview and documentation standards" when obtaining informa-tion for Kent which were not applied to anyone else during the course of the subsequent Region V inspection.
(jgi. at 2).
(4)
Alternatively, when " pursuing the validity of Kent's allegations, Region V personnel conducted casual interviews of unidentified licensee and Bechtel personnel and documented these interviews by informal notes which were later destroyed."
(1d. at 2).
(5)
Region V Office of Inspection and Enforcement (IE) personnel denied Kent " inspection tools, guages, ladders, and other measuring equipment"-
during an October 25, 1982, site tour of the San Onofre plant.
(jgl. at 2).
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(6)
Region V management personnel decided to conduct a press conference on December 6, 1982, in which they reported that Kent's allegations had been unsubstantiated.
That did not notify Kent or his counsel (GAP), nor provide either with a copy of the inspection report.
(jgi. at 2).
(7)
Region V destroyed copies of drafts and notes of the final IE inspection into Kent's allegations.
(jpl. at 2).
(8)
Region V "is not able to support or verify its inspection activity with confirming records or data."
(pl. at 4).
(9)
Region V responded to the Kent allegations only after major' media interest followed the publication of the October 13, 1982, Los Anceles Times article.
(jgi. at 2).
(10)
The NRC never obtained a written statement from Mr. Kent.
(As noted, the NRC has never conducted an adequate interview of Mr. Kent in order to understand his allegations.)
(Id. at 3).
(11)
Other miscellaneous findings of inspection and investigation irregularities or inadequacies were discovered by OIA investigators.
(See report su= mary).
7
Pago Fiva
, March 6, 1985 The OIA report substantiates all of the GAP allegations which it addresses of procedural pishandling of Mr. Kent's concerns..However, the investigation does not address at all the most important questions that we raised.
That is:
The second category, although separate from
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the actual hardware issues, is the question of the NRC's technical review of the issues raised by Mr. Kent.
For example, although Region V requested assistance from the Office of Nuclear Reactor Regulation (NRR) to evaluate the technical details of Mr. Kent's allegations, it appears that, in fact, no independent review was done.
Under the Freedom of Information Act we requested and received the communications, notes, memoranda, etc., that surrounded the issues raised by Mr. Kent.
Review of these documents found a circular trail of verification that simply relied on the industry -- both Bechtel and Southern California Edison -- to interpret and explain Mr. Kent's allegations away.
We have found no evidence of independent analysis of review by the NRC.
(June 20, 19 8 3, letter, p. 6).
Questions that remain not only unanswered, but apparently unasked, are:
(1)
Why did NRR adopt, virtually verbatim, the technical analysis of Kent's allegations, performed by Bechtel and provided to the NRC?
(2)
Why didn't Region V officials include in their inspection report that the basis of their conclusions about Mr. Kent's allegations came from Bechtel?
(3)
Why did Region V allow Bechtel and SCE to dictate the conclusions of the Kent allegations?
Also not addressed is the serious charge that "(t)he Kent inspection was curtailed and prejudiced at the onset by SCE and Bechtel influence."
OIA investigators apparently " defined out" of the scope of the investigation the evidence of impropriety in regards to the two-week NRR " blitzkrieg" inspection.
(pi. at 15-16).
OIA did not interview anyone from NRR at alA regarding their involvement in the shoddy disposition of Kent's allegations.
Instead they based a conclusion that the Kent inspection was thorough on the totally self-serving statements of the alleged targets of the investigation.
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Pagg Six March 6, 1985 OIA's conclusion simply is not supported by the facts and documents gathered during GAP's investigation.
The investigators failed to perform basic interviews necessary for adequate disposition.
For example, (1)
The OIA investigators have never contacted Mr. Kent or GAP to determine whether the scope of their investigation was adequately addressing the concerns raised to the Commissian.
(2)
BNL has never contacted Mr. Kent to determine what Mr. Kent's alleg"ations are, therefore the "new independent look at the Kent allegations is severely handicapped, if not totally crippled, because it draws the allegations from an inadequat.e and fatally flawed interview, an unsigned statement, a su= mary affidavit, and the self-serving interpre-tations of the allegations provided by Bechtel (3)
The OIA investigator never contacted any representatives of Bechtel, SCE or Consumers Power to deter =ine their knowledge, or establish the veracity of the NRC's statement.
(4)
It is our information and belief that OIA removed from the record, without explanation, memoranda dr portions of memoranda about Mr. Jim Foster's deal,ings with Earl Kent.
GAP believes that.the evidence suggests the OIA investi-gation was deliberately narrowed in scope.
We also have reason to believe that the report finally submitted to the Commission is far less comprehensive than the original report.
Those drafts were as usual withheld from the public.
GAP will soon file suit.under the Freedom of Information Act in U.S. District Court to ob'tain the materials which the NRC refuses to disclose.
We are co=mitted to discover all the facts behind the Kent Affair.
OIA obviously is not.
Clearly, OIA either cannot or will not address the key issue of the Kent affair -- the curtailment of an NRC inspec-tion by the Bechtel Corporation.
It is therefore up to the Commission.
GAP unfortunately realizes that this issue has become so adversarial that it'is no longer possible for_any branch of the NRC Staff to resolve it.
In the past, the Com=ission has
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page Savan March 6, 1985 requested special administrative proceedings to resolve similar matters.
This appears to be the only re=aining agency remedy.
Sincerely, OQ f
Billie Pirner Garde Citizens Clinic Director D
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-Q..g,i April 4, 1984 MEMORANDUM FOR:
Chairman Palladino Comissioner Gilinsky Comissioner Roberts Comissioner Asselstine Comis ener Berntha FROM:
,yg ne - d George
- ssenger, etingDheter Office of Inspector and Auditor
SUBJECT:
DIA REVIEnt OF A GOVERNMENT ACCOUNTASILITY P COMPLAINT CONCERNING NRC'S TREATMENT OF Auditor (OIA) of infomation in a JuneThe attached report documb 20, 1983, letter from the Government Accountability Project (GAP) to the Comission.
E. Earl Kent of specific and generic welding flaws at San Onofre Nuclear Generating Stations (SONGS) Un our review of the material sent by GAP, we detemined the following three Based on issues were appropriate for investigation by OIA:
NRC's treatment of Kent in regard to his allegations to the NRC.
Region V compliance with administrative procedures and inspection m in addressing allegations by Kent / GAP.
technical analysis of Kent / GAP concerns.The confidence le Our investigation into the first issue disclosed that Kent's allegations regarding Bechtel welding procedures, which were initially brought to the attention of Region III in March 1982, wert generic in nature and applied to Bechtel's Midland Nuclear Project as well as other Bechtel constructed nuc facilities.
Region III inspected Kent's allegations as thef related to Midland; however, Region III did not address the overall issue of whether Bechtel's welding procedures were in compliance with professional society welding standards.
Bechtel's welding procedures and presented additional weldin 1
pertaining to SONGS.
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CONTAC :. Hollis Bowers, DIA 650 % ocal
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DE1AAISI DU g
i On October 13, 1982, Kent's allegations were reported by the _Los Anceles
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In response to the media coverage, Region V interviewec Kent and Tire s.
i recorded Kent's allegations regarding welding deficiencies by tape record transcripts, and a statement.
standards which were used when obtaining information from Ke applied to anyone else during the course of the subsequent Region V inspection.
In pursuing the validity of Kent's allegations, Region V personnel conducted casual interviews of unidentified licensee and Bechtel personnel and documented these interviews by infomal notes which were later des troyed.
On October 25, 1982, site tour at the San Onofre Plant during which Kent was pro tunity to point out his concerns.
gauges, ladders, and other measuring equipment.However, Kent was denied ins that potential licensee insurance liability prevented Kent from unlimitedRegi macy of the site tour is questionable. access within the plant; however, u tour, we believe the necessary equipment'should have been made av Kent could have fully demonstrated his concerns.
Our investigation did not disclose any overt effort on the part of HRC to personally discredit Kent as alleged by gap. The fact that notations are made in a file concerning an alleger's background and work history is not inappro-priate.
indicates Kent's credibility rather than a review of his alleg substance of the cornunication between Region III and Region Y personnel.
At a Dece.ber 6,1982, press conference, Region V reported that Kent's alleg tions had been inspected b'y the NRC and were unsubstantiated.
Copies of the inspection report were provided to the press.
GAP was not infomed of the press conference nor provided a copy of the inspection report.
Although
, Region V personnel claimed this was an oversight, in 01A's view NRC should have been more responsive to the alleger. To correct this shortcoming Region Y Administrator instituted a new regional program to improve com, the tion between NRC and allegers.
unica-DIA investigation into Region V compliance with NRC administrative procedures and inspection methods when addressing Kent's allegations revealed that NRC, in responding to a Freedom of Information Act (FOIA) request by EAP, was unable to produce documents to support the findings and conclusions in the Region V inspection report.
tion of Kent's concerns was not thoroughly conducted or documents we inappropriately destroyed in violation of FOIA and the NRC Inspection and Enforcement Manual.
DIA learned, however, that the lack of documentation prepared during the Region V inspection and routine destruction of drafts were the reasons why there were no documents available for release.
Our investigation did not disclose any withholding or destruction of documents which violated the provisions of the NRC Inspection and Enforcement Manual or FOIA.
While OIA does not have the expertise to technically evaluate the Region V inspection re Regulati,on's, port nor the Division of Engineering, Office of Nucle
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crrMAL Ubt (JNI Y preparation of an independent technical ~ analysis by the Division of Engineering in addition to the Region Y inspection report indicates that technical attention was given Kent's allegations by NRC.
Our review of GAP's concerns over the handling of the NRC inspection /
investigation of Kent's allegations detennined that the inadequacies in Region Y's perfomance in addressing Kent's allegations were procedural and administrative in nature.
We believe, regardless of the procedural and acninistrative shortcomings, the efforts of Region V and NRC Headquarters personnel demonstrate that NRC was com.itted to a thorough technical evalua-tion of Kent's allegations.
Attachment:
As stated cc:
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CIA EVIm T A smeT un%.TAsnzn PRCLTET C&2IALT 02iCERiING IGC'S TrTJCCsT T E. EAEL KE2.T WZAQS PREPARED BY:
Albert 3. Pug h DATE: Kff,cgg In m cigator Office of Inspe::*r and Atriitcr
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BACKGROUND During the week of January 9 through 13, 1984, Office of Inspector and Auditor (OIA) Investigator Albert B. Puglia traveled to NRC's Region V office, Walnut Creek, California to review Region V's performance in addressing alle-gations concerning welding procedures at the San Onofre Nuclear Generating Station (SONGS), San Diego County, California made by Mr. E. Earl Kent. This OIA review was conducted based on assertions that the NRC mishandled an
. inspection of Kent's allegations. These assertions were made by the Government Accountability Project (GAP) on behalf of Kent in a June 20, 1983, letter (Attachment 1).
SUMMARY
An analysis of GAP's concerns identified three broad issues which were addressed by OIA. These issues are (1) NRC.'s treatment of Kent in regard to his allegations to the NRC, (2) Region V compliance with NRC administrative procedures and inspection methods in addressing the allegations by Kent / GAP, and (3) the confidence level that can be placed in NRC's technical inspection i
i and technical analysis of Kent / GAP concerns.
l 1.
NRC's treatment of Kent in reoard to his allegations to the NRC I
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Initially, Kent telephonically reported his allegations regarding welding practices at Midland to NRC Region III personnel in March 1982. He i
subsequently furnished an affidavit to Region III in Jul I
documented his concerns over Bechtel Power Corporation (y 1982, which Bechtel) welding procedures in general end the welding procedures used at Bechtel's.
Midland Nuclear Project in particular. Additionally, in August 1982. Kent travelled to Region III, Glen Ellyn, Illinois and expressed his concerns to Region III personnel. Upon completing his interview with Region III personnel in Glen Ellyn, Illinois, Kent returned to Southern California and began pursuing his concerns regarding Bechtel welding procedures at nuclear power plants built by Bechtel in general and at SONGS in particular.
On September 6,1982, gap, on behalf of Kent, wrote to the Region III Administrator, James P. Keppler, complaining about the lack of HRC response to Kent's concerns.
On September 7,1982, Kent expressed to Southern California Edison Company (SCE) his concerns regarding the adequacy of Bechtel welding
' procedures at SONGS SCE conducted a review of Kent's allegations. During the week of September 13, 1982 SCE also reported Kent's concerns to the NRC during a routine inspection of the facility. The NRC inspector reviewed SCE's action to resolve Kent's allegations. This review con-sisted of discussions with SCE personnel and an examination of docunenta-tion. The inspector reported in his Inspection Report, 50-362/82-27, that
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l he was satisfied SCE had taken appropriate action to resolve welding issues raised by Kent.
On October 6,1982, Mr. John O' Dell, a reporter for the Los Anceles Times contacted Region V and related he had been contacted by YeEt on t
September 27, 1982, and Kent had described faulty welding practices at SONGS. O' Dell asked for an NRC response to Kent's allegations. O' Dell wa infomed of the Inspection Report noted above and SCE's action with regard to Kent's concerns.
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On October 13, 1982 Times which also gen,erated significant additional media intere i
i story. Kent was further interviewed by other Southern California media organizations. Based on the significant media interest generated by the O' Dell article and to more properly respond to media inquiries, Region V decided that inspectic'n activities were warranted into Kent's alle-gations.
While the subject of GAP's June 20, 1983, Region V's perfomance in addressing Kent's concerns, Region III'sletter prin perfomance in reacting to Kent is also noted.
Kent had expressed his allegations to Region III on three separate
- cccasions, March, July, and August of 1982. In GAP's view.the lack of an NRC response to Kent made necessary a GAP letter co= plaint on September 6,1982, to the Regional Administrator. Moreover, GAP claims it was not until November 1982 (well after Region V is heavily engaged in the Kent aTroie Region III's cou)rse of action in responding to his allegations a l
Midland.
- is a series of memoranda and Inspection Report
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50-329/82-04 prepared in Region III which outlines Region III's actions in addressing Kent's allegations.regarding welding, flaws at Midland. In sum, Region III did document their contact with Kent 'and did conduct an inspection at I
Midland; it did not address generic welding procedures u After the publication of the media story in Soutfiern California on October 13, 1982, Kent was contacted by Region V NRC and a meeting was scheduled for October 15, 1982, noted that in GAP's letter complaint of Juneto discuss his concerns. It should be 20, 1983, it is implied that Region V contacted Kent only after Kent had offered his* assistance and infomation on welding flaws at SONGS to Region V and only after the news articles appeared in the press. While Region III had had extensive about through press inquiries and not from Kent or Region III. co In responding to Kent after the media coverage, Regien V Office of Investigations (01) investigators met Kent on October discu'ss his allegations. This meeting was tape recorded.15, 1982, to In addition, it
- and that a succinct written statement would be prepared for Ke sigilature. Kent subsequently refused to sign the statement on the advice
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y of his counsel, GAP. During his interview with Region Y OI personnel, Kent identified two other individualj who he felt could support his allegations,"
land interviewed these two'indi[viouais an Region V OI personnel subsequently l
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tape recorded the meetings.
After Region V OI personnel documented Kent's concerns regarding welding deficiencies, via 'the tape recordings, tre.nscripts, and a statement, this information was given to Region Y who proceeded to look into the matter.
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Concerning the distribution of the tape recordings,and transcripts of Kent's interview, on about October I4,1982, Region Y 01 personnel agreed, in a conversation with GAP representatives, to voluntarily furnish GAP a copy of the tape recordings of the meeting with Kent. A developed between 01, Region V, and Mr. Victor J. Stello Executive Director for Regional Operations and Generic Recuirements, on how best to release the tape recordings and transcripts to GAP. Region V personnel explained that they were concerned that the transcripts were inaccurate and required review and correction before they could be released.
On November 8,1982, GAP filed an FOIA request to obtain this material. k' hen confronted with GAP's FOIA request, NRC released the tape recordings'and the transcripts in mid-December 1982. The transcripts had i
not been corrected.
On October 25, 1982, Kent, NRC personnel and licensee personnel conducted a site tour at the San Onofre plant during which Kent was provided an opportunity to point out examples of his concerns. However, Kent was denied inspection tools, gauges, a ladder, and other measuring equipment.
i Region V personnel proffered that potential licensee insurance liability prevented Kent unlimited access within the plant.
On December 6,1982, Region V held a press conference and disclosed that Kent's allegations had been inspected by the NRC and they were unsubstantiated. Copies of the Inspection Report were made available to i
the press. During OIA interviews of Region V personnel, it was stated that the purpose in holding a press conference was to make public NRC
inspection of Kent's allegations and to expedite the release of the NRC s
information. The Region V Public Affairs Officer informed OIA that the l
Kent matter had generated substantial media attention and that during the l
course of the inspection, the Region was repeatedly asked the completion l"
date of the inspection. Rather than responding to media organizations -
individually, it was decided by Regional management that a press con-ference was the appropriate means of making known NRC's inspection of Kent's concerns. Regional management denied that they were attem'pting to discredit, or embarrass Kent and stated that the decision to utilize a press conference was appropriate in this case in view of the significant level of media attention to the matter. DIA inquired as to the reason Kent or his counsel, GAP, was not furnished a copy of the Inspection Report, was not advised the inspection had been completed, or was not alerted that a press conference was planned. Regional personnel claimed it was an oversight.
GAP, in their complaint of June 20, 1983, to the NRC concerning NRC's inspection of Kent's allegations, indicated that there was an overt effo'rt to personally discredit Kent and engage in malicious conduct
SIDU toward Kent. GAP make particular mention of notes of a telephone conversation between Region III and Region V which are contained in Region V files concerning Kent's background and work history. GAP obtained this material from a FOIA request. Prior to comitting agency resources t~o review and inspect.an alleger's concerns 01 Region V considered it appropriate to obtain infomation concer,ning the allegers background, edu:ation, expertise, work history, etc. This was accomplished in Kent's case. 01A's review of the notes in question indicated the emphasis of the telephone conversation was Kent's credibility rather than his allegations.
OIA conferred with the newly appointed Region V Administrator concerning Region V's treatment of Kent. He stated that, independent of this OIA
. review, he had also reviewed the Kent matter and as a result, substantial allegers and their concerns. Specifically, the Region V Adm attempted to institute a program in which allegers such as Kent are treated with a high degree of tact and courtesy when bringing their concerns to the attention of the NRC. Attachment 3 is the newl mented Region V policy which formally institutes this program.y imple-Essen-tially, Region V has comitted itself to improving comunications between the NRC and allegers, intervenor groups, and GAP-type organizations. It should also be noted that the Region Y Administrator has independently corresponded with GAP concerning the Kent matter (Attachment 4). In sum, it is the Regional Administrator's view that allegers need to be apprised t
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of the status of their allegations and concerns and that generally speaking, allegers should be treated with the same degree of courtesy and tcet thct is extended to licensee representatives.
2.
Reoion V comoliance with administrative procedures and inspection methods in accressinc allegations by Kent / GAP GAP, in their letter complaint of June 20, 1983, to the NRC, indicated that the inspection procedures utilized by Region V in addressing Kent's concerns, were inadequate and not in compliance with existing NRC re-quirements. GAP, upon receiving a copy of the completed inspection report, submitted an FOIA request to the NRC to obtain the background material, draft report, notes, and interviews utilized in preparing the final NRC inspection report. The NRC, in responding.to the FOIA request, was unable to produce the materials and documents which fimly supported the findings and conclusions documented in the final inspection report.
GAP, therefore, concluded that either the inspection of Kent's concerns was not conducted and/or that documents were inappropriately destroyed in violation of FOIA requirements. In sum, GAP called into question the validity of the inspection that was undertaken to address Kent's allegations and Region V found itself in the position of not being able to support or verify its inspection activity with confiming records or data. For example, while Kent's allegations were tape recorded, transcribed, and put into a statement, Region V personnel were unable to produce identification data and supporting documentation pertaining to the persons they interviewed during their inspection of Kent's allegations. In pursuing the validity of Kent's allegations, Regional personnel conducted infomal interviews of unidentified licensee and Bechtel personnel, and took infomal notes which could not be produced
/
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Or M. IJS E OM.Y ~
y 1
when an FOIA request was submitted. In the final analysis, the validity of the inspection report prepared in response to Kent's allegations essentially rests on the personal integrity and professional assertions of Region V personnel that they had, in fact, put forth a good faith effort in a,ddressing Kent's concerns.
GAP, in their letter complaint to the NRC, also suggests that the Kent inspection had a predetemined completion date and was curtailed at the outset by licensee and Bechtel influence. In support, GAP cites meeting notes from a Region V meeting on October 14, 1932, and a letter to the Office of Nuclear Reactor Regulation (NRR) on October 29, 1982.
The meeting notes noted above were the result of a Region V meeting at the time Region V was made aware of Kent's concerns as published in the Los Anceles Times. The notes state, in part:
"(1) Interview Kent for all his concerns; (2) Need full investigative support; (3) Tech positions iiReg III and V _have to be the same (Engelken);
(4) Have NRR reaffirm their position on the code. ASME Code; (5) Call Fitzgerald/ Ward and discuss the matter with him."
~
OIA inquiry with the Region V 0I Field Office Director, detemined that-the list can be described as a tasking list developed at the initial meeting of Region V personnel to address Kent's allegations. It essentially outlines Region V's plan to address Kent's allegations.
Region V attempted to carry out these actions during the course of the Kent inspection and nothing is contained in the list to suggest that the inspection was curtailed or prejudiced.
GAP then makes reference to an October 29, 1982, memorandum from Jesse -L.
Crews, Supervisor, Region V, to NRC Headquarters, in which Crews stated:
"It is our intention to have a satisfactory resolution on all of the allegations 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."
GAP goes on to state that the above noted paragraph indicates that the i
Kent inspection had a predetemined time frame for completion.
Region V management advised that Crews' memorandum attempted to alert NRC Headquarters that,their prompt assistance would be required to resolve Kent's allegations if the NRC was to maintain its proposed target date -
for the license. Crews' memorandum also states:
i "In the course of Region V's special inspection (currently in progress) into allegations by Mr. Kent, we recognized that some could potentially impact upon license issuance for San Onofre Unit I
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DECLLSIDU 3 and that the resolution of some issues may require technical assistance from NRR.*
Region V management indicated that to read into the Crews' memorandum that Region V was not connitted to seriously looking into Kent's alle-gations is a wrong reading of the memorandum. Region V was simply alert-ing NRC Headquarters that their prompt assistance was required to resolve Kent's allegations in a timely manner. Further, a concerted effort is a license issuance date.normally made to resolve all open allegations befor GAP has also suggested that additional documents exist in Region V and had been inappropriately withheld from release under FOIA provisions. OIA
. review of Region V files as well as discussions with FOIA personnel did not disclose any improper withholding of documents under FOIA provisions.
gap further asserts that agency documents concerning the Region V in-spection in response to Kent's allegations were destroyed in violation of Inspection and Enforcement (IE) Manual and FOIA. In support of this contention, GAP quotes paragraph 201, Section 1005-20, IE Manual, "Although draft inspection reports will not be disclosed as a routine basis, they will be available to members of the public upon request," as NRC policy prohibiting destruction of draft inspection reports. However, the tem " draft inspection report" is defined in paragraph 102, Section 1005-04, of the IE Manual, and Section 1005-40 of the Manual outlines the format and content of draft inspection reports (Attachment 5). DIA detemined that the Kent inspection repor.t was initially drafted and that routine supervisory and management review resulted in non-substantive corrections and changes. These actions resulted in ratyping of the report. Draft reports, such as these, which are only earlier versions of the final report, do not fall within the meaning of draft inspection GAP as prohibition against the destruction of the draft report apply in this instance. With regard to notes obtained by inspectors during the Kent inspection, they were personal in nature and assisted the writer in the preparation of the inspection report. They were destroyed upon incorporating their substance in the inspection report.
Personal notes are not considered agency records as long as they have not been circulated to others and have not been co-mingled with agency records, and there are no prohibitions against destroying personal notes after the information has been incorporated into the inspection report.
[ Porter Company Chapter Isaak Walten League v. AEC (N.D. Ind 1974) and British Airports Authority v. CAS 531 F. Supp. 408 (D.C. Dist Ct 1982)]
j 3.
The confidence level that can be placed in NRC's technical insoection and 1
technical analysis of Kent / GAP concerns-OIA does not have' the expertise to evaluate the technical sufficiency of the Region V inspection report or the Safety Evaluation Report (SER)
(Attachment 6) prepared by the Division of Engineering, Office of Nuclear Reactor Regulation.
The Division of Engineering review, which is docu-mented in the SER, was an independent analysis of sore of Kent's allega-tions.
The review involved (1) interviewing the people who accompanied Kenyon a walk.through tour of SONGS, (2) repeating the tour and
/
OTEQUSIDy!.Y inspecting those welds which Kent pointed out were of concern to him, and (3) reviewing the documents provided by the applicant which demonstrated compliance with applicable codes.
The preparation of the independent technical a,nalysis by the Division of Engineering was in addition to the inspection report by Region Y.
DFTAILS
- 1. Report of Interview, James G. Hanchett, dated January 11, 1984.
- 2. Report of Interview, Bobby H. Faulkenberry, dated January 11, 1984
- 3., Report of Interview, William V. Johnson, dated January 12, 1984
- 4. Report of Interview, Dennis F. Kirsch, dated February 1,1984
- 5. Report of Interview, Ida M. Alexander, dated January 12, 1984.
- 6. Report of Interview, John B. Martin, dated January 11, 1984.
- 7. Report of Interview, JaBes E. Foster, dated January 31, 1984.
- 8. Report of Interview, Owen C. Shackleton, dated January 11, 1984
- 9. Report of Interview, Thomas W. Bishop, dated January 12, 1984. - Letter to Conmission from gap dated June 20, 1983.
- - Region III memoranda and Inspection Report pertaining to Kent's allegations. - Region V Instruction No.1303 dated January 6,1984
' Attachment 4 - Letter to gap from NRC Region V dated December 5,1983. - IE Manual Chapter 1000 dated March 28, 1977.
- - Safety Evaluation Report dated November 17, 1982.
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. NUCLE AR REGULA.08 r D.. 35W Office Of Insper.or and Auditor Ja: mary 27, 1984 0.u.ei,...m.u.a
_Recort of Interview James G. Hanchett, Public Affairs Officer, Region V. Walnut Creek, California stated that upon Mr. Kent holding a press conference in the Los Angeles area in which he voiced his concerns regarding Bechtel welding procedures Region V received numerous inquiries from media organizations requesting comme,nt.
Hanchett described Kent's press conference as, generating significant media attention in which Region Y was repeatedly asked for a coment as to the validity of Kent's concerns. Region Y's initial response to the press was that an NRC inspection was planned and that upon completion of the inspection NRC would be in a better position to coment on Kent's concerns.
During the course of the inspection, media organizations repeatedly inquired as to the completion date of the inspection. Hanchett went on to explain that because of the large number of media organizations that were following up on Kent's concerns, it was determined by Region Y management that the most efficient manner to respond to the media was via a press conference in the Southern California area rather than responding individually to the media representatives who had been inquiring as to NRC action in the matter.
Hanchett claimed that the decision to hold the press conference.on December 6, 1982, in Southern California was made to expedite the.NRC response to Kent's
~
concerns and to provide the NRC response on one occasion rather than responding to the media organizations individually.
Hanchett further stated that at the press conference copies of the NRC inspec-tion report were furnished to the media and NRC management officials made a brief statement and were available for questions. When asked why Kent or his legal.cou'nsel, Government Accountability Project (GAP), was not also provided a copy of the inspection report, Hanchett replied that it was an oversight. To his knowledge, there had been no discussion or decision to deny Kent access to the inspection results or participation in the NRC press conference..Hanchett was further asked if Region V was engaged in an inappropriate game of "one-upmanship" in responding to Kent's press conference with an NRC press conference. Hanchett denied this had occurred and stated that the NRC press conference on December 6,1982, was merely gn effort to provide service to the press in the most effective manner.
i
...... Janua:v 11, 1984 3
Albert B. Puglia W.
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., i,........ Ja n ua r y 27. 1984 Reoort of Interview William V. Johnson, Assistant Director for Materials and Qualifications
. Engineering, Division of Engineering, Nuclear Reactor Regulation (NRR), was telephonically interviewed. Johnson stated that his staff had reviewed Kent's concerns which had been referred to his office from Region V. Johnson further stated that his office had concluded that Kent's concerns were unsubstantiated. Johnson went on to explain that his staff travelled to the San Onofre Nuclear Generating Station and conducted a site tour to inspect and review Kent's concerns. It should be noted that this site tour was 1 of the Kent / Region V site tour in which Kent pointed out his concern.ndependent
- s. Johnson indicated that the technical analysis conducted by his office examined Bechtel welding procedures, appropriate professional society codes, NRC requiements, and a review of Kent's specific concerns. Johnson went on to indicate that NRR recognized that the various professional society codes have different acceptable standards and are not in unanamity. Consequently, an analysis of I
the issues' raised by Mr. Kent required a determination as to the appropriate code provision to be applied. Additionally, an independent safety analysis was conducted by NRR as to Kent's concerns. Jchnson reiterated NRR's conclusion that Kent's weldino concerns were without technical merit and that he had confidence NRR technical analysis was comprehensive and complete. NRR's inspection and analysis report was prepared and forwarded to Region V (See ).
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was subsequently interviewed telephonically because he and his staff were on assignment during the Office of Inspector and Auditor (OIA V. Kirsch said that substantial Region V inspection resourc)es were committedr to addressing Kent's concerns. Kirsch indicated that he had a good grasp of Kent's concerns, that they were examined and inspected to detennine whether they had technical merit. Kirsch further stated that he was aware of the subsequent controversy concerning the treatment of Kent and the iss'ues raised in the drafting of the inspection report. Kirsch noted that these topics have resulted in substantial changes in Region V inspection procedures. However, Kirsch reiterated that the application of technical resources to Kent's concerns were significant and the inspection was conducted in good faith.
Kirsch complained that he was disturbed that doubt has been cast on his professional integrity and the quality of the technical inspection based on reporting requirements and~ other administrative matters. Kirsch confirmed that he was confident in the technical conclusions and that Kent's ccncerns were unsubstantiated.
Kirsch said that the reporting format and record keeping procedures employed in the Kent affair were in compliance with Region V inspection procedures up
.to that point in time. Subsequently identified shortcomings in reporting and inspection procedures were not peculiar to the Kent inspection and that the Kent inspection was conducted and reported in good faith.,
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January 31, 19e4 Reoort of Interview Ida M. Alexander, Chief, Administrative Services Branch, Region V, Walnut Creek, California stated that she is the FOIA Coordinator in Region V and that pursuant to FOIA re Accountability Project (GAP) quest 83-618 submitted by Governmental
, an extensive search for documents was conducted in Region V. Alexander indicated that to her knowledge, the FOIA request was handled in a proper manner. Alexander further indicated that there have been instances in Region V when Region V personnel have not promptly responded in searching for documents and that some Region V personnel do not appreciate the importance of prompt compliance with FOIA provisions. Alexander went on to repeat that the FOIA requests that were received from GAP concerning the Kent affair were handled routinely and promptly. Alexander was not cognizant of any improper destruction.of documents or withholding of documents from release under FOIA provisions.
~-
The Region ~ Y and Office of Investigations (01) Headquarters file of FOIA request 83-618 was exar.ined and no discrepancies or indications of improper handling were identified.
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l January 12, 1984,
,, _ Walnut. Creek, Calif.
82-82 Albirt B.
Pucli Investigator, OIA January ll, 1984 m
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o.u i..u..... Januarv 31, 1984 Report of Interview John B. Martin, Regional Administrator, Region V, Walnut Creek, California stated that upon being assigned as the Regional Administrator in Region V he reviewed the Office of Investigations (01) Royce/Gunderson report and the Region V Kent inspection report. At the time Mr. Martin assumed the duties as the Regional Administrator, Region V was the subject of severe criticism from GAP and an intervenor group at the Palo Verde Nuclear Power Plant. Martin said it was his initial determination that comunications between Region V and
, these groups required dramatic improvement. Consequently, Martin said he made a detemined effort to meet with these groups to discuss problems of mutual interest.' Martin indicated that the mere fact that these groups had an opportunity to meet with NRC representatives and discuss mutual problems substantially improved relations between these groups and the NRC. Martin also said that he followed up these meetings with confiming correspondence (Attachment 4).
Martin stated that it was his position that Region V had not treated individual citizens and citizen groups with the degree of courtesy and tact'.
that should be forthco'ning)from a public agency such as the U.S. Nuclear Regulatory Comission (NRC. Martin indicated that, as a general rule, he hoped ir.dividual citizens and citizen groups who come in contact with the NRC would be treated with the same de' gree of courtesy that is extended to licensee representatives.
As a further result of Martin's review of the Kent situat' ion, he said that he
~
instituted new procedures within Region V that carefully detailed a femal
' program of receiving, inspecting, reporting and notifying individuals who report conditions relating to NRC's responsibilities to regulate the nuclear industry (Attachment 3).
Martin indicated that his review of the Kent inspection report and the GAP-complaint detemined that NRC's treatment of Mr. Kent was not what it should have been. Further, the inspection and reporting procedures that existed in Region V at the time the Kent inspection was conducted were inadequate. Martin said the newly instituted procedures within Region V strengthen inspection and reporting requirements and should alleviate many of the criticisms pointed out by gap. Martin further stated that it was his detemination that the technical inspection and technical analysis of Kent's concerns by Region V were adequate in spite of other sho'rtcomings. Martin said, from an exclusively technical standpoint, Kent's concerns had been addres' sed and he had confidence that the technical conclusions reached in the report were valid.
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Januarv 30, 1984 Report of Interview
' Bobby H. Faulkenberry, Deputy Regional Administrator, Region V, Walnut Creek, California stated that the Kent affair occurred during the tenure of the previous Regional Administrator. Faulkenberry said that the Kent affair arose abruptly in Region V as a result of a press conference held by Mr. Kent in Southern California. While Kent had had prior dealings with the NRC in Region III, Region V was not aware of his activities in Region V. Consequently the initial media inquiries for a Region V response to Kent came upon them without warning. Faulkenberry indicated that from the beginning of the Kent affair, it was Region V's intention to expedite the inspection of his concern and to disseminate a prompt response to the public. Faulkenberry acknowledged that some of the shortcomings that have been identified in Region V's handling of the Kent affair have merit and, upon reflection, resulted in changes in Region V procedures. Faulkenberry indicated that the Kent affair was handled in Region V utilizing routine inspection methods which, at this point in time, had been detemined to be. shortsighted. However, Faulkenberry further indicated that at no tirne was there any effort to discredit Kent personally or not to address his concerns in good faith. Initial meetings with the then Regional Administrator were directed at comitting Region V resources in good faith to complete a prompt and thorough inspection of Kent's concerns.
i Faulkenberry said that FOIA provisions were complied with in spite of the limited inf omation that was available for release. Moreover, while individual,
inspectors had destroyed their notes, they had incorporated their infomation into the inspection report and there was no attempt to hide information,from public exposure. Additionally, the destruction of initial. drafts of the inspection report resulted from routine administrative revisions and corrections and was not a deliberate ' attempt to limit the content of the re port.
Faulkenberry went on to describe new procedures that have been instituted in Region V concerning the documentation of Region V inspections. These new procedures better preserve information and fully identify persons interviewed.
Additionally, a femal system of obtaining citizens concerns and fomerly corresponding with them to report the progress of NRC's effort to resolve inspection issues has been instituted in Region V. Faulkenberry noted that th'ese new procedures were principally instituted as a result of the criticism received after the issuance of the Kent inspection report.
Concerning the tape recording and the transt.ription of Kent, Faulkenberry noted that this was the then nomal practice employed in obtaining citizen concerns. Faulkenberry went on to acknowledge the confusion that resulted between the Office of Investigations (01) and the Region V staff concerning releasing the tape recordings and transcripts of Kent to gap.
January 11, 1984.n minut Creek, California 83-82 Albert B, Puolia vesticater, CIA
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2-Faulkenberry concluded the interview by restating that it was Region V's objective to address Kent's concerns in a good faith manner and to apply the the level of public interest that was generated regarding Kent's i
to the public and media, Faulkenberry acknowledged shortco concerning NRC's' relationship witt. Kent and his legal counsel, Government Accountability Project (GAP). Faulkenberry indicated with t
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its handling of the Kent affair.
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Report of Interview
. James E. Foster, former Investigator, Region III, Glen Ellyn, Illinois, presently assigned to the Region III Inspection' Staff, was interviewed telephonically and stated that he had numerous conversations with Mr. Kent during 1982 regarding his concerns of welding flaws at the Midland Nuclear Project. Foster denied the GAP allegation that he had ignored Kent and did not
. take appropriate action to pursue resolution of Kent's concerns. Foster
' directed OIA attention to a September 24, 1982, memoranda with attachments which he had prepared for Regional Administrator James P. Keppler which
.i outlined his meetings with Kent during 1982. This memoranda was prepared in response to a GAP letter dated September 6,1982, to Keppler regarding the Midland site. Attached to the cover memorandum is additicnal correspondence dated March 3, 1982, March 4, 1982, March 5, 1982, March 22, 1982 (2),
March 24, 1982, and August-11,1982, which reports Region III's meetings, l
conversations, and inspection of Mr. Kent's concerns (Attachment 2).
Forter denied GIP's allegation that Region III had not taken action regarding Kent's concerns and referred to the above noted memoranda which documented Region III's response to Kent's concerns.
Foster stated that he had not alerted Region V of Kent's concerns as they pertained to the San Onofre site and indicated that he was involved in "re-spending to GAP's September 6,1982, letter to Keppler in. late September 1982.
Foster indicated that he had planned to refer Kent's information to Region V, but Kent's press conference in Southern California had occurred prior to his having an opportunity to alert Region Y of Kent's concerns.
Foster denied he had discredited or embarrassed Kent while addressing Kent's welding concerns at Midland.
83-82
. January 31, 1994
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January 31, 1984 Report of Interview Owen C. Shackleton, Director Office of Investigations (01) Field Office the attention of Region V based on inquiries.from a los Anoeles Ti reporter, John O' Dell. O' Dell was developing a newspaper article based on Station (SONGS). Shackleton, indicated that 01's involvement
'respon' ding to Kent's concerns was to conduct the interview of Kent. It was a regional inspection. Shackleton said that he was requested conduct the interview of Kent and take a statement from him. Shackleton the said he contacted O! Headquarters and was advised that his participation in the Kent affair would be limited to taking a statement from Kent and turning i
the information'over to the-Region so that the inspection could be conducted.
Shackleton said 01 was not the " lead organization" within the NRC concerning i
resolution of Kent's concerns.
Shackleton said that he and a member of his staff met with " Kent on Oct'ober 15, 1982, in Southern California and conducted the interview. This interview was tape recorded. Shackleton also stated that he conversed with GAP officials I
prior to interviewir.g Kent and had agreed to furnish them copies of the tape j
recordings made during the interview of Kent.
I Uoon completing the interview of Kent, Shackleton said' thit he reviewed the tape recordings and prepared a statement which outlined Kent's concerns and presented it to Kent for signature. Kent refused to sign the statement.
Additionally, Shackleton forwarded copies of the tape recording to HRC Headquarters for transcription.
Shackleton said that he and his ' staff also interviewed I
~2anda
' X.]his allegations regarding welding flaws at SONGS. These two individu upport
. These interviews were also tape recorded.
Shackleton then said he contacted 01 Headquarters at which time he was in-structed to terminate his involvement in the Kent effair and to turn over the tape recordings of Kent to the Region for forwarding to the Government
. Accountability Project (GAP). Shackleton indicated that in his conversations with GAP he had agreed to turn over copies of the tape recordings, however, when the transcripts of the tape recordings were received they contained numerou.s errors and which required " clean up" and correction.
_ January 11,1984d/
,, Halnut Creek, E2Wemia 83-82 a.,
A11ert'B. Puelia', Investigator, CIA o,,,,,,,,,,
January 31, 1984 o = a c. t e n we to a ='e t a c a w ir an m e w o. - -- -- --
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Shackleton was then asked the reason why GAP had not been sent the tapes after he had agreed to do so. Shackleton replied that he was directed by 01 Headquarters to tenninate his involvement in the Kent affair and turn the tapes over to the Region so they could send the tapes to GAP. Shackleton pointed to sev,eral office memoranda in which he requested the Region to forward the tapes to GAP. Shackleton indicated that the delay in sending the tapes was linked to correcting the written transcripts which had to be per-i formed in Region V and which no one was' willing to do. Consequently, there was considerable delay in sending the tapes and/or transcripts to GAP. Advice was also sought by the Region from Mr. Victor Stel.lo, Deputy Executive Director for Regionel Operations and Generic Requirements, concerning releasing the tapes.
It should be noted that GAP eventually received the tapes, transcripts..and unsigned statement via a FOIA request after thef had determined that the NRC was not going to voluntarily comply with its previous agreement. Further, 01A sees little difference between oral tape recordings and written transcripts of the oral tape recordings. Additionally, the written transcripts have never been corrected nor has a signed statement ever been obtained from Kent.
Shackleton said that Region V inspection personnel had obtained sufficient infonnation from the tape recordings and the unsigned statement to proceed with their inspection. Consequently, no one in Region V was willing to take the necessary time to correct the transcripts or pursue obtaining a signed statement from Kent. Shackleton also indicated that subsequent to the Kent affair 01 had changed its policy concerning tape, recording interviewees.~01 no long:r t:p: r:::rd: interviewees.
Shackleton then said that a member of his staff accompanied Kent and' Region Y
' inspectors on a site tour of SONGS. The purpose of the site tour was to provide Kent an opportunity to point out specific examples of his concerns.
. Shackleton stated that the licensee had indicated " insurance liability" prevented Kent from having unlimited access to the plant. Consequently Kent was not provided such things as a ladder or test equipment, i.e., gauge,s, -
during the site tour.
Shackleton indicated that upon being brought into the Kent affair, he contacted Mr. James Foster, 01 Region 111, on October 12, 1982, to find out Kent's prior involvement with Region III personrel. Shackleton said he made notes of his conversation with Foster and the purpose of the conversation was to obtain background material on Kent and his concerns as they related to the Midland site. Shackleton characterized this conversation as routine and an attempt to gather background material prior to his interview with Kent.
Shackleton denied GAP's claim that this conversation was an attempt to embarrass and discredit Kent.
Shackleton then stated that the fenner Regional Administrator conducted a staff conference on October 14, 1982, in which Region V's response to Kent was discussed. Shackleton said that he took notes at this meeting which described Region V's plan to respond to Kent's concerns. Shackleton denied GAP's claim that the list of actions to be taken suggest that Region V was attempting to curtail and prejudice the Kent inspection. Shackleton said he agreed with the plan, ar noted, and the impression of this meeting was that Region V was prepared to conduct a good faith inspection of Kent's concerns.
L
DU M 8
. l Concerning FOIA requirements, Shackleton said he knows of no instances in which documents were destroyed concerning the Kent offer, and that he has complied with FOIA requirements in releasing material to GAP concerning the i
Kent affair.
Shackleton denied that he had discredited or embarrassed Kent at any time.
Shackleton said that information contained in 01 files concerning Kent's work history, background, education, etc. was appropriately gathered. Shackleton indicated that prior to comitting Agency resources in an NRC inquiry, it is appropriate to obtain infonnation on the credibility and reliability of the person bringing forth concerns as Mr. Kent had.
e e
e i
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1 3
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a 9
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-...- - - - w e, ; s y, ', '
UcLEAR REoULATORY COMMissi q
J Office gf inspecizr and Auditor g
o
.. i,..,, u. _
Janua:y 31, 1984 Report of Interview Thomas W. Bishop, Enforcement Coordinator, Region V, Walnut Creek, Califor stated that he coordinated the preparation of the Kent inspection report.
f Bishop indicated that subsequent to the completion of the Kent inspection have been made in Region V's procedures in respondin the attention of the NRC from individuals, such as Kent. Bishop further Kent's concerns, was the failure of the Region to get ba correspond with Kent upon completing the Region V inspection. Additionally,* y the Regional procedures for documenting interviews during the course of an inspection were determined to be deficient, particularly after GAP called into question the validity of the NRC inspection effort.
Bishop stated that Region V has substantially revised its internal procedures in addressing concerns brought forward by individuals and organizations that require the comitment of NRC inspection resources. The Kent affair and the
'l subsequent controversy surrounding Region V's inspection of his concerns exposed the shortcomings in Region V's procedures to address these type matters.
V's hanoling of Kent's concerns was the failure of the Regi understand that it had to conduct or caintain a dialogue with gap in address-ing Kent's concerns. Had this point been better understood by the Region much of the controversy.which ensued could have been avoided.
Concerning alleged destruction of documents which has. been proferred by GAP, Bishop said that to his knowledge all FOIA requests have been properly responded to and that all infomation concerning Kent's allegations has been released. Bishop went on to say that routine administrative revisions of the initial inspection report had occurred, however, the changes made were administrative and gramatical in nature. Bishop said that the Kent inspection report received routine processing and no effort was made to preserve earlier editions of the inspection report. Bishop also said that the inspectors incorporated notes they had obtained in the report and subsequently destroyed them. At that point in time, this had been the routine practice in Region V.
J.,
t 1
+
L,..
_ January 12, 1984/ k
,, W1 nut Creek, California 83-82
,7
_ Albert B. Puglia, Investigator, CIA e......,,,_
January 31, 1984
'o UNITED STATES g
!y
' NUCLEAR REGULATORY COMMISSION
\\ ;1,,.,g r;
- 3 p) 2.%!;d/ !
wasmucros. o. c. nosss
....../
(10V : 71992 s, -
i Docket Nos: 50-329 and 50-330 I W4%
i I
e
(
j V
MEMORANDUM FOR:
The Atomic Safety Licensing Board for the Midland Plant, Units 1 a 2
FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
SUBJECT:
INFORMATION ITEM - NOTIFICATION OF WELDING-RELATED ALLEGATIONS AT SAN ONOFRE 2/3 AND MIDLAND 1/2 (Board Notification No.82-117)
Tne attached memorandum (Engelken to Eisenhut, dated November 8,1982) summarizes allegations made by a fomer Bechtel employee regarding welding practices at the Midland and San Onofre Plants.
We presently do not consider these allegations to represent a safety concern since none of the allegations have been substantiated.
However,'if any change in our position occurs, we will issue a further notifica-T tion.
]
- n &
' Tfiomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: See next page S
hu v,. v.ivJ y. ysu:., )
6
/
.1
. MIDLAND Mr. J. W. Cook Vice President Lee L. Bishop
,m
( j\\ Consmers Power Company Harmon & Weiss 1
1945 West Parnall Road 1725 I Street, N.W., Suite 506 Jackson, Michigan 49201 Washington, D. C.
20006 cc: Michael I. Miller, Esq.
Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.
Division of Radiological Health Alan S. Farnell, Esq.
Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza.
Lansing, Michigan 48909 Sist floor
- Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consmers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Of fice Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consmers Power Company
(,)
720, Law Building 212 W. Michigan Avenue (j
Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Pax Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III.
Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 Mr. Ron Callen Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way O
124 Mcdonald Street P.O. Box 30221 Q
Midland, Michigan 48640 Lansing, Michigan 48909
/'
'tc, UN(TED STATt5
['
- '). //
NUCLEAR REGULATORY COMMtSSION
- )
nEcsoN v A
W,0 heasssa Latet.5UITE 210
'is, 4., o /
WALNUT CRE E K. CALIFORNIA MSDE
=. '
N0Y 8 1982 MEMORANDUM FOR:
D. C. Eisenhut, Director. Division of Licensing NRR FROM:
R. H. Engelken, Regional Administrator, Region V SUUACT:
RECOMMENDATION FOR LICENSING BOARD N0i'll'1 CAT 10N REGARDIN t
EtolNG RLLATCD Al.i.ECATIONS AT SAN ONOFRE UNIT 3.
i
+ -
DOCKET NO. 50-352 l
A.
Backg.r.ou.nd During the week of september 13. 10M. Lhu 1icent.ce notified the
.. inspector that certain allegations had been received by SCE regarding.
velding adequacy at 50NG5 2 and 3.
The licensee had interviewed the j
.oalleger on Septecer 7,1982 and had documented and resolved the
,V concerns expressed by the alleger.
The inspector reviewed the licensee'.s acLions to rcsolve the allegations and noted that the l
lir.ensee's investigation did not substantiate any of the alleger's 1
concerns.
~
On Octouer 6,1982 the NRC, Region V, was contacted by a reporter tor the Lus' Angeles Times who relayed.several concerns, which had '
~
been expressed to the media by Llic elleger.
The alleger contacted l
Lhu NRC on October 6,1987 and reluyed additional concerns, in addition to the f our prcViously expressed to the licensee on Septeit6er 7,1982..
The a11eger was interviewed by two Rogion V Investigators and one r.
- i
$cction Chief on Octnber 15. 1982.
The concerns expressed by the
. alleger were summarized into a stateuwnt and presented to the alleger for review and signature on October 16, 1932.
The alleger refused i
Lo sign the 3,Laterr.ent.
The fourteen concerns sumerized in the r.totenent included the original four expressed to the licensee on Septecer 7,1987 and addillunal concerns expressed during the NRC j in te rv i ew:..
The statement is attached to this menorandum.
B.
Region V Action
~ A team of NRC personnel, consisting of two inspectors and one regional supervisur, conducted an inspection at the Son Onutre Nuclear Gener4Litig
]
Station site, during the period of October 18-27, 1982, to examine p
procedures, installed plant conditions and documentation related to -
5(
the concerns expressed by the alleger.
Region V has completod the special inspections and did not substantiate any of the allegers concerns.
7rm m.
S '**n 2. P
(
2-Region V currently anticipates complullon and issuanew of the spwclal i
inspection report by mid December,19P,2.
Certain allegations regarding the adequacy of and implementation of Cude requirwment have been referred to NRR for technical evaluation.
The results of the NRR evalualon will be included AS en attachment to the special inr.pection report.
C.
Issues Before the Board The allegations pertain to engineering and 0A/QC issues which have been addrer. sed by the licensing board.
~ 5*.~)l:-:5E~A
.q
/ <- R. H. Engelken
(
1 Regional Administrator
Attachment:
As stated
- r -
Cc:
M. Williams, ONRR H. Road, NRR,iB3 G. Knighton, LU3 I
f
- "N h'.C9deruceCourt (j\\
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n.vpross, California.9C6'50 Date: Oc:/ che c /6. / WI i
'fic e : / 4 ! h,.
i 1,.:. Carl i;en:, vo:untar-1: cake t.he followin-istate=ent to
'r
- liessrs..-hili V. Jouhoff and Cvon C. Chackleton Jr. who,have
'.t identifieo themselves to me es inventi ators for the rD. 3. i
- i.uclear.?c:elster Co=ciscion (3:.sc).
- raske this statement frec2y.titn no.hrer.ts or. ronises of reward having been.nede to me.
.Tua]ffz$N I a:: 5'l vecrs old nd have ucrked since
- - k. ' c4 'as a velder, uelding ouility centrol insnecter, weldin ; engineerjM g-cnd suti or of weldin ; artt eles for weldin;; journals. In F)93 k g g I receive a di, lor.c. for conrletion of the otructural Engineer v ">
in:; Co.irce frou t.;e "nternational Corre..nondence Jchool, Scranton,.cnns.'.vnnis.
! werhed for 3cchtel icwor Cornora- -
' ~ ' " * ~ ~ " ' ' " ~ * ' " ' ' ~ ' ' " ' ' ' ""*" '"*"**' *" "* "" "' '"*
TJ'
.Jan inkire.uclear.Jenerat:.n ; Jtaticn (SOCO) frcs October, 19.'.C un t :.1 -.v-t c:.:er, 1 9:31.
[,A /! V$t4 f~
64 I it ent.fied the fellowing cen-
'urinr, re' cn Gc 7ni.:nt at cern: vi'ich were taentified to ce by the C:C t.cruennel who in-tervie.<ed i.*e en october l',19d2 os ;ossidi:t affectin; nuclear.
safatfg.':tcuo A N t2 c7Wfsz. / 7f Mf, 5'j.*
p)
I w.>.-
Cit ':c r.f.We p.W.; c,;.
t, v
(1 /. i.:
qr :f.:a pi;e cutterc to :sahc scribe car'. s for'
= c ci:e t und titu; e.b.eurc~ents.
- .ne scrii.e m4rks c::u cd t:rcove.: i.$cth ntsiale::.. c :d ccrben gteel 'ginen obnut 1" t, ch frc= the ueld arec.
I ce conTcr ed that
[e./,',-
thcau :;rcovo: : ia;..: cauae streur raicers.
'.'h os e c on di-c tiens e.':ist or ::o che t welded fittip and y, Ur$QS.' f f [j'st.'/ll l.! Nit-/i *,;s ai-l~vver L'nita 23 [2
' #f 7 /2dNA-M /W (2) licci tel riesiiners -
use fillet weldu on #---%
-.5.
g,
[, /,
cennectior.s of cckI in i e :sunperte: and tray ht.nrers and OAratv d :.: not ucic all urce::c tho lcin
- c rentrain forces in all I
fb 4 4.:z r u c N4.. riir. pct:.onn.
I feel *.. in is a cede violaticn.
!!o troto-r t!. ne t'eEt'sy.ere condected to verif:t the ndeeuccy of these Wffit4
, j.
/~h,rit.//.M,, g~)
s.e l d er.
'.hernfero, the netual structt:rul stran th of the ciec:r:c"1 trait han cr/tiib g,j'.
cc.cn t ant e aini n t. :.,: ::. d(Yy stci'l'. Sic 1*ic use b
['
nothttl' hnown.
n 1 i..:
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a ;cncric rroble(m.
- M tc e, eld all arcunti the d.oin t.:
g.nfertunat ejg gtnj d 1;11nn, wpiadr, the cedes do a cyj/g/gs/f Jg ;Elg ::t.)c,n.b p
r i
\\ 3)'am cna uf--, :.re6
/q M e/, vee e
eN.. of T l' lot s c1[N a-e"e roccare.2 : ue.ur.tc roct.
g*
{~l,k I rcenii t'u t ce:se of the ve:'icr :uorlied welded hardware g >g g g.g 4en r.ot hkve naccuate root :enetrations.
'.'he one vendor I can ocn11 1.
"rek, I believe a su..ilier of liVt.C couio-nont.
I re: ecker ene inntence en a.icce of Cach. hardware '
- here a fillet.mld.siti. 'r.Meour2tv LAmn+4ratten gfgt,4/g,(
p p, p/ h. F c
- 60 ) ' Mq a
ae em o 2 ens yPP' m
he$
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continued 3:n:cuen: o f I:. :.'.arl 1:e n t.........../....I age 2 was idertified durin-incyection on site. f This instance.was s
3,,
aut secuently corrected by we ld re9u*r h-fs installattion in O ' - '
the lant.
I dcn't rcmencer if this eouitment was used in ECfiG3.
'y bnit:; 2 or 3.
I reco..cr.d th-t the !!'lC exacine.the be.,inningo
~
E M M lb cnd end of fillet +eldJ re a sure root ecnetration at the.se -
t/2,4ff /7).////' st.pplie.nd conductd :r t...c vcnNr[ctive testinof' selected supporto -
a; e u..
i
- estr i Iid(.
to de ermine if ether fillet we1da,.4ao.Ar.tposhoch$
g:jy-havo inc.ieouste ront pene;rati ons CA 477/.Qt sjes,pf }</gigg,%,
y
,,e y 34 -
! (4) A steel bracket}W betteeen a 'Jnit 1 hydrogen line on y
trin for steam icnerntor.
This was done beenuse the h;drogen line e
gsg g had Nors thfn due to rubbinr t;ith another line.
I believe main.,
tenance 'co lc at the sito who were worhin:; durinr: the yeriod kM,c U, g
.iion dema e due te the Unit 1 f.iesel encrator fire was being j
gf f; 7, g.f e ccrrected wuld re: er.i er,, o be chtc to locate the desit;n
/
c en :e ur. i
.p a c e r.
I don't recall the c::act location of the
- j..
hydro en line. ?o
't.i b e r.: r: ccilection there.::.cn ' t ec.uisment irithi-ten feet.
2 dcn't venember if there traa nny nuclear safety-rela t e d c a u _ cr.ic n
- nearby.
I am concerned fer t':e integrity of nuclear n;fetir-relt.ted ocuircont, if located Acarby, and about
, t::e votent2a1 for loss of au..:an life and fire,, ndould this line rusture.
I reconnend i.14C conduct an enamination of this hydror;en
- iino ac: cs':c certain it 1 an.aufficient wall thickneaa to be N
(Q),,,
c errtad./fcig,{tygAV,T,tk g/L:49Y()}-)fff*,7 Js.2s psif.gry-f nnie1::
Nh3 7afj.d,t 'J f.4b'da > 7WG fvi.t f C/ ft/ jrf/./4 (t/t.$/r/rf)e}c}nlCXX/w$ Y;pq
N (5)
'I a g o.e-4r
. t.at t.a.tf e tt ;. 2leturnn are not requiroc cn :.
tel in vi olction cf,..y.!3-D1.1, Section 6,fuara #gg W'f' ' d'drhwin'n.
.1 i s ir P' 2
()f.)/,yf(*C*
- ra ns P... d, l. i. U.1, and 0.d/5.2T*'*These conditions exist on de-M P
/G N f g. t a'ili i~nl==:- s:ru c t u ral a ir.licat ion,f,;p i two pn e 3echtel T*ower l
Corr.nration tr.ble es oblishe.. ttst certain ni-e sunnnrts must Fr/'
C,.c, eonf cr. t o. N..::;-J1.1 rcquirerier ta.
gNp cTAt#/2 (6) Bec}-tel Ccnatruction einecifien rinn CS - (207, Revision 7, STMf dated noril 1!..
l[*UO, ara ranha i.6 nr.d 5 7, centsina visual examina:1cn criteria uned er.iechtel for. ire supports and
[A r e f e= r e r.c n M.e i.E*,.;'.iV Code,.3ecticn I!!, ducaection !!T. I AfM' Ngf:
told nohr... 'Je11, investigative re-orter for the Los ta:;elen J ff4,ift y tTinc'u, thoQLhe vi.v't.1 cr:terin of CG - Y2C7 are not in' accord-onco uiti t..e abave code -ect i recen tn, enrticulnriv in CT. - F207 enrn r'..hs i. e.1. 4 i
,o ro:ii t?'.'nf s1.a-). uci d cenvenitir height acco tn rc critorit. s. h.1. - (:inderfilled. ro vc weld' craters),
'i. O.1.11 tare n:ri"e* acce.tanco criteris, r.nd 5.7.2 (allowing f rroove ' cld 2 vith f 11et en s to be welded as fillet velda).
(Cf.L'M To L ov.) (M '
(7) fechtal.enernted :: 5,2 ta c.':C.1 on electric"1 tray hanpors.
1 nue:-t c u!.other tr.c steldeydo c.
electrien1 nur.vorts urior k
tho :C.' rca.~. u ticn ucreff'nad.
- d f;;. q t.W 17,'i.$ ' tit.,.:t"+fff,g y yg y te
. (I.).iuc! t cJ n.s not
.s19: t':o rasnuirer.9nto of,s.;;; D1.1
/
'1174 odtt'en)'je...lio:
Jfm,!.'
r. r:..ha 8:.10.1. S. (2 ). ( V) un d 0.1 %1 3,,,,
.., gy 1
pc..crcia.. til 17.: og o or..:e.1.d craters en.tre.*/ hterern[tc ful.1 ; OThI9%
1 l
\\
(n.!" / A,i
/12WJ (r,.
(M
%d
q O
~
Continued, atement t' '
v r.g,-
I:. 7.arl K en t................. 6ar.e 1 -
m..
g croan nac:fon ci t o veld.s Q
,,g,
//z. Bl.c'M/$4'G ' TrA-
~.
SM.8
..s p//A//v//j (c) Ecchtel h c no): cr.nvedgr.rc strihes frem b:se metal OM
- e. y.
a sup: orts er ntructural nieel as required by.AU6 D1.1.parcgraph.'
- . 4 '
jyjp //gf~gfdY &
l (10) I obse-rved instanece uhcre rt n off alates me.v.a-mot. used as...
w required by AuS D1.' p. ra';ra-h 4.G W ; roove weld terminat. ions.9 i -. '
I c.unot reccll any s9ecific locations, but I do recall ob-
- s..
cervint; this condition on benm and girder splicesy.ft,' /P//#)P ',
/
i F V' F-t * /fdff" 0//f J,/fNDC'/E. r JGAf
- *3*t.
i:
(11) I believe that a n-' sect vlate i.: missin ; on the unner inside.a-t door hin; e of the Unit 2 containment nersonne1 ha'tch because
'M
~
I observed a.;ap in tt:o wcld.icint of about 1/4 inch.
I, jpg]
crour;ht this to t?e attent'en of my supervisorfw o also,
n
- c. arco t.:s: beli e f.
I believe th..t by brint: int; this condition,
J to the attentien of my cuuervisar I had proterly perforced my
'2uty te identify this condition.
I did not ccm are the draw-in!; requirements to the installed condition in making this determination of a misnint, spacer plate y MWg,aff" jeff'g/hs%W-.
Wl'.'fNsip It Y6 '7Wd-f'/ f IV)$ 'f/'/g lits @r/Z,!f P)teNaE*M'*/p 4yg, (1&) I believe that :'.cchtel he.s misinternroted the requirenents of. gfgr-):p/;f gnb@
n.t'a..SM.:: Joction III weldini; standards re ;urding socket veld enragemon'. lenrth without initiatinc a code case and obtaining /l/0/AC 7# F.
s approbriate coce relier. ;The ASHE coce requires a gap between /yggpyggg, the pipe end ar.d the fittin:; of"aperoximately 1/16 inch". I.
~
believe that the code shoulc provide a more definitive acceptance criteria than morely "approximately 1/16 inch". 84/ (%/r:4.fgrN,p/pg g"
/
ll%.dhk ~.ddl OW.M4 tr.V di Ly/A.J$ 174 P//.5 /S,civf".rbra. /ggirppg v
(13) 3echtel specification UQ-2,,heet. 20, note 1, requires "shal.1,. hp g g,. q, '
s not exceed 1/3 inch..." roc;2rding maxi =um groeve weld reinforcement
. f,-[~,4[/F AhMQ This requiremont should read "shall not exceed 1/8 inch.;.."
N. -
fj,fg4*jjy '/
as required by the sis 4E 3ection III ccide on groove weld reinforce =ent.
. Twi.e l'A'Mk.he 1/3 inch heirht im innlemented at San Onofre.. L. pry.5s;_41.4,. y,9,,.ys;g p-g T
p/ g g' (14) I believe that the caliber of indivs' duals employed by peabody Testing /cg' to perform nondestructive exanination (UDE)..on welds in nuclear p8 service anplications, wan not neceptable. This belief is based an g g,.
,0('ll//,l'/'A'T/r;,, p.sncilin.,:a cf t he words }' fillet".ud " weld",%HDE 'riports p'repared the obscrystion o' raony..pellinr: crrors, such as.the incorrect l4 pgg,.
~
,4 7 g-,rf, by these individuals. Because of those observed opellinye? riffs,~# +NA 1
I ouestien tne abilities of these HDh' personnel to perform the
' NM.
f4A/P required examinatiens as required by their procedures. I believe
. that ' cat Ill'l ~h'ed~iridiffir'gnt udards rerardine the nualification of e't.' s s personnel ennability and knowledne in this very important area
. i!LF personnn1 cro not sufficient to assure an adequate level of
- . 4' st p[!" h(N~k'f}~4 of inapoction.
,..,4 't. 4,s j:' y./ Vt-$
y m.
I have udvised the above named. U2C norsonnel of other cone.erna I have re' ardin-insdecuacios that I We1:.hiet in Ihdustry Coden and standards g
(i.e. AVS, AG!:E, AI~C. etc.). The HitC representatives have told me that those areas, are not within}the jurisdiction of the JIPC and although I do
[//
spur re tw Sr k uutMa wv.w kn.m M.m (s;,r. m,wi, en: iia.,.~.u.
a n aa, u ur.
Ti o f E. Earl Ken t........................ W N....Page. 4.
p C stinued Statenent t
)(kY69 not necessarily agree with this, I do understand that this to the game..e 4
The 11RC representatives have also told me that I can report rey arotr of e i A/
concern regarding Codes to the anplicable code con =ittee.
fkff!W f h/'6' /9 & 4Gkf[,[ME 17/SN Tc Hg gl';f,l l
tffc.e n k,'// @
plygypf '
sh I have cany concerne@pp I further have advised the NR representatives that
- g regarding veldin
- ; done on non-nuclear safety related systems and equipcents#C I have been advised by the NRC representatives that these areas are also V not within the jurindiction of the NRC. The NRC representatives have told #Ft ne that I car. recort these concerns directly to the utility, SCE,.cr
- pp whatever other local, state, or federal agency that has jurisdiction.
hNffr1l
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UNITED STATES v
! j'.
3(f,' i NUCLE AR REGULATORY COMMISSION 1/ j W ASHIN G TON. D. C. 20555 3-
' em t,%.
/5 NOV 101982 i:Nj m
h-tr my Q 1 Docket Nos.:
50-361 q
and 50-362
'l MEMORANDUM FOR:
The Atomic Safety Licensing Appeal Board for San Onofre Units 2 and 3 FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
SUBJECT:
INFORMATION ITEM - NOTIFICATION OF WELDING-RELATED ALLLEGATIONS AT SAN ON0FRE 2/3 (Board Notification No.82-117)
The attached memorandum (Engelken to Eisenhut, dated November 8, 1982) sumarizes allegations made by a Bechtel employee regarding welding practices at the plants.
We presently do not consider these allega-tions to represent a safety concern since none of the allegations have been substantiated.
However, if any change in our position occurs, we will issue a further notification.
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.h, &)l% u Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc:
OPE' l
SECY OGC 01 Region V Administrator Service List l
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9 pp.
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7 p)
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DISTRIBUTION FOR BOARD NOTIFICATION
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Before the Atomic Safety and Licensing Appeal Board r
San Onofre Units 2&3 Docket Nos. 50-361/362
_ACRS Members Stephen F. Eilperin, Esq.
Dr. Robert C. Axtmann Dr. Reginald L. Gotchy Mr. Myer Bender Dr. W. Reed Johnson Dr. Max W. Carbon James L. Kelley, Esq.
Mr. Jesse C. Ebersole Dr. Cadet H. Hand, Jr.
Mr. Harold Etherington Mrs. Elizabeth B. Johnson Dr. William Kerr Janice E. Kerr, Esq.
Dr. Harold W. Lewis Alan R. Watts, Esq.
Dr. J. Carson Mark Mr. Gary D. Cotton Mr. William M. Mathis A. 5. Carstens Dr. Dade W. Moeller Mrs. Lyn Harris Hicks Dr. David Okrent David R. Pigott, Esq.
Dr. Milton S. Plesset Richard J. Wharton, Esq.
Mr. Jeremiah J. Raye Charles R. Kocher, Esq.
Dr. Paul G. Shewmon Phyllis M. Gallagher, Esq.
Dr. Chester P. Siess Charles E. McClung, Jr., Esq.
Mr. David A. Ward l
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,,,, = =t w,q'e UserTED STATE 5
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E' NUCLEAR REGULATORY COMMISSION Q....' k ucsou v c
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1450 Maassa Latst. 5UITE 210 g
p WALNUT CREEK, CALIFORNIA MES6
=>
<..a NOV 8 B82 l
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MEMORANDUM FOR:
D. C. Eisenhut, Director. Division of Licensing, NRR e
FROM:
R. H. Engelken, Regional Administrator, Region V i
SUUACT:
RECOMMENDATIONFORLICENSINGBOARDNOIlficAT10NREGARDING:'
t i
WELUING RLLATED Al.i.ECATIONS AT SAN ONOFRF UNIT 3.
DOCKET NO. 50-362 i
A.
Backg r.ou,nd During the week of September 13.10M. the 1icentue notified tho
.. inspector that certain allegations had been receivad by SCE regarding welding adequacy at SONGS 2 and 3.
The licensee had interviewed the s
alleger on September 7,1982 and had docunented and resolved the concerns expressed by the alleger. The inspector reviewed the licensee's actions to resolve the allegations and noted that the licensee's investigation did not substantiate any of the alleger's concerns.
On October b. 1982 the NRC, Region V, was contacted by a reporter for the Los Angeles Tinws who relayed.several concerns, which had q
been expressed to the media by the alleger.
The alleger contacted the NRC on October 6,1982 and relayed addit.funal concerns, in addition to the f our previously expressed to the licensen on Septer.ber 7.1982..
The a11eger was interviewed by two Region V Investigators and one e.
Section Chief on October 15. 1982. The concerns expressed by the a
. alleger were sumarized into a statement and presented to the alleger l
for review and signature on October 16, 1982.
The alleger refused l
Lo sign the statement. The fourteen concerns sunnarized in the statenent included the original four expressed to the licensee on September 7,1987 and additional concerns expressed during the NRC 1 interviews.
The statement is attached to this cenorandum.
B.
Region V Action
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A team of NRC personnel, consisting of two inspectors and one regional f
supervisor, conducted an inspection at the San Onofre Nuclear Generating i
Station site, during t.he period of October 18-27, 1982, to examine p
procedures, installed plant conditions and. documentation related to I
Lj the concerns expressed by the alleger.
Region V has completed the t,
special inspections and did not substantiate any of the allegers concerns.
W I ' 0 0 rlA & A_
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_ hC, B 2 bl 9 0'3s t P o c
-, Region V curr ently antti.ipates compluLlors and issuance of the special i
insper. tion report by nild December. 19P,2.
Certain allegations regarding the adequacy of and implenentation of i-Code requirement:, have been referred to NRR for technical evaluation.
The results of the NRR evalualon will be included as an attachment to the special insper.tiori report.
C.
Issues Defore the Board The allegations pertain to engineering and 0A/0c issues which have been addrer. sed by the licerts ing board.
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2.~11..N/S_ ! -
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/;u R. H. Engelken C. ;z._'
Regional Administrator Attachmerit:
As stated O.
cc:
M. Williams, ONRR H. Rood, NRR,183 G. Knighton, Lu3
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m 9l.CO deruce Court
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C.T,ross, California.9C6%
Date: Oc:t clue r 16. / 9Y" Tine: Je : 30/>,.
i 1,
.C. Carl i;en ;, vo;untar.1. eake r.he followin ;; statement to
'r '
lie ssrs..' hili: V. Jouhoff and Cven C. Ghackleton Jr. whoshave t
identifiea tP.ecselves to me as inventi ators for the rD. 3. i
- i.uclear Mc clater Corciscion (;:. ;C).
I make this statement -
frec3y.t i t r. n c.hrects or. romises of reward having been.nede to =e.
Zum)ffz$2-N g-I as 5'? Yects old nd have ucrked since '='- % 5T M as a and autPor of.:eldinc articles. tor welding journals.centrol ins velder, ueldinr ouilit.v In M
! receive-a di-lc..c f,r cc: rletion af the otructural Engineer i.
"3 in:; Coarce frou t.:e "nternational Corren"ondence Jehool,
- ieranton,.cnns.'.vnnis.
! wort:ei for 3cchtel icwor Corr. ora-s.
t.i on s. a "cni. :. t : lit: C.:ntr.:1 f.n -incer in welding at' the
/.
Jan i.nkire.uc] ear.Jenerat:.n ; Jtaticn (00GS) fres October, "A
192.0 unt:.1 e. ce, 1901 Q, VSt'+ r-
.turing r;'r en Gc";sent at
- 4..iG I it;entified ti.e fellowing cen-cern:.ti' ch were.uer.tified to ce b:t tho.N;:0 1.orsennel who in-terv.te.ved s'e en (,ctcber l'.,19.;2 oc gossinl:t affectin; nuclear
.~.3 f a t "I:.";t c:.'s; AN O C 7 +'.f/Z / 1'C t)f=[,
Q*
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fit ': ors.W WW ~ EA N-(1 /
.1 r :::a p;e cutter to na :c scribe car..s for s
=cci:ct ve3 d itu: r.k.a.;ure. ents.
'Jh. ne scrii.e marks c::u cd creove.: i$oth ::tsinican c :d cerben gteel tineo obout 1" baci: fro = the uelit arec.
I am conTcrned that Ol-
~
titcae grcove
- ..i r;..: cause streer raiser =.
' hose condi-tions e:ist or coci:e t welded fittip an d 3, UrHp,9 f J ft.w/pt UHit-/, e',';s atl=uver Unita 23 M/MA'AW /d g
(2) liechtel desit ncr
~ cce fillet welda on < tc d.
er -
- g.,.,.,.
c nnectior.s of cce=i: in i e r.::perte and tray hrngers and CAyy;p de not welc all urcunc the.' c in t c rentrain forces in all 70 /.4.7?j7p c N4.. dir;7ctionr..
I feel.>in in a code violaticn.
.Mo troto-
?
tyne t'el'tsg:ere conit'.cted to verif:t the udeeuncv of these WfG4
.Tujf./,,M) s.c i d s.
. hert:f t ro, the actual structurul atran th of the g,j'.
ciec:r:c'T tent: han cr/tuby, :tcol. weisc used or the m ::. 4 ~2r.otShul' Snown. This also,, M
'I cc. cat nnte ital at.
a:nne; t.b'I alsc ~lc'el that' the(TaIlure /NM/ /
n l i..: t e-i+
to e, eld all avern:. the i.oint :: a ;cnoric rroblem.
M f
g '.nfertunat ' gry. d
-- <.:i;4* fc; 1,#cn e, wcguah, the codes 9n,
- 13) 'not-i.cnur y -
e at scl
~~4 re:.:n c.s : ae ur.tc roet g'
Fv,2 I recall tw:. me of the ve: 4cr ::uorlied welded hardware Y
- t## i ""*
J/[#t: //ZEr.7 6 I=
- ' ' '. "
- k* 5. lieve a su.111cr of.."V..Ccouin-can ocill 1.-
,"c
_ ce s
menL.
I : -: er-L e r en e it.ntence en a 4 oce cf Zach hardware hore a fillet welc wit).
r.v counte tA*rwtrat+cn gfgt.fV/g-N*
(d in e -
ru, en s w (Q
I ',d.,4 '
I iL) s sito2 ens
},
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.-e d Pr77z.
Continued 5tn:cuen: a f T.;. Carl 1:en t.............. I ag e 2 inspection on site.,I Ohio instance was was identified durin-i,,
subseeuently corrocted bll weed remu.r h f w installattion in
... g d
C-. e the lant.
.! den't romen'cer if this eouitment was used in SGG3.
'gfp g,,,,p inita 2 or L 1 r.-c o.: mend th-t the !!'lC examine.the ber; inning,.
and end of fillet -reld 2 r a acsure root eenetration at these N M M, f/tdff:/tj,M/J# suppli.~ +.nd conductt...c vend'rr[ctive testing of' selected ounnorto -
- k..
n; e a.-
- .e s t r to determine if ether fillef welds,.4.t/aAspe6he's
- A6 ed : '-
t
- gyp, navo inadequate root pene:rationc Cx C77Me sje, par y/grypy, y
h M:
! (4) A steel bracket); --- -
' - - - - between a Unit 1 hydrogen line on
//
tri, for eteam generntor.
l'his was done beenuse the h,drogen line g
hjg,sg g had worn thin due to rubbin.7 ::ith canother line.
I believe main,
tenance 'co-lo at the site who were worhine durinr the period
,5.e s-c A, r-
. ben d:ma e due tc the Unit 1 diesel encrator fire was being
/geg '7rf.f.e, ccrrected m uld rte:er.cer n.o be ante to locate the design c en e un.
.p acer.
I don' recall the o::act location of the
- 1..
h:/dro en 1;ne. ;'o ri 'ier.: r:ccliection there non't oct.innent withi ten feet.
2 dcn't recember if there was a*.y nuclear safety-reinted equ caen* nearby.
I am concerned fer the integrity of nuclear n..fet r-rel:.t ed ecuir:ont, if locatedAcarby, and about
..the vo ential for loc: of human life anc'. fire,,ab.ould this line ru7ture.
I recoor.cnd LHC ccnduct an exa=ination of this hydror;en
'iinc an: na':n certain it ! an.;ufficient wall thicknean to be N
'~
nnie1:: c :er: tcd.,V/c177,e tygg9, ~,. Gest:L:/,'rq) } ffJ,Tc" /z );~s. 2f /Ji JigY,sy-/
M M7a!).dS'l' f4 Vca> rug /4,1;*$ C/~ fD/ Ff/ /4 (I/t..#,ft/tf)e}e}ntelft.txta$ ym **
(5) I a goce+ i
- t..a t wer f
+
ea geturnn nre not recua.roo en :.
Fdiswin:n.
21 is i.x in violction cf,.,.ya-D1.1, Section 6,fpara # y 95 17'f' ~
pp)'/,y /#.V
- ra
- ns E... U... s. 6.1, and c.46.2f*These conditions exist on de-k
- g. ta'il'c'ln}a:= : c ructural a:iv:licat ion)p.i two 1 n e ilochtel Power
~
/<4NV Corr. oration tr.i:le ear.nblishe.. that cortain ni-e sunnnrts must 7t/(
@~,
confor to N.3-J1.1 requirceents.
4N.D #7.iF#/2 (6) BecFtel Conatruction ebecification CS - i207, Revision 7, II#/d da r.cd arril 1L, 15'00,. ara ranhs %d a.d 5 7, containa visual examina:1en criteria t.ned a:: 3echtel fer.ien sitpports and
[4.'
reference P.he :J...',.~.i V Code,.';ection III, Sucaection NT. I Af/f /Gjejr:
t old o o.r
' Jell, investigative re orter for the Los f.ngeles u..
" ' Tir.ic'c. ti.c h the vi.vir.1 criteria of CG - F2C7. are not in accord-J pg,/,e/ ;<:.
ance uiti r.. c above code -ecu iromen tn, rarticularl v in CF, - 1207 entn r
.).s 1.a.1.x i morottit?' ant' s1.a-)
ucld cenvenitar heiaht accertn ee c rit o ri r..
.i.1.- (:inderfill ed. ro-vc weld craters),
":.0.1.11 ture n:ri' e acce wtance criteria, e.c.d 5.7.2 (allowihr f rroove.cldo uith fillet en s to be welded as. fillet velds).
( C LL
- N P L ov )
f.s*<
(7) :'echtel. enernted n 5.2 ca e !!C.1 on electric I tray hancers.
I oue.-tica ui.ott:cr t:.e we3 d: r:do c.
electrien1 nur.rerts *rior M'
te thc..: ? rca..; u;ic. ucreff'nud.
- AfifgL@fy.'i5 * //L.. &fffgyyp _
Z
. (!.}.itici t e) n.a not
. l io 2.n t': t':c resnuirercnto of,s 3 D1.1
'1"74cdtt'en)'je.
"r...ha 2:.1;2.1. % (2 ). ($ nn d 6.1% 1.,3,,,,
y gp ve"t.rCin-U l' i.-
or c or..: eld crator= cn ' tic.': hunrernjtafu11;
/ fyrf C.
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Continued :,:stement c ! C. Earl K en t..................We re 3-tr r g.
cros.. nection cf t,c weld.
$^1.8
.s -
3/4~~M/H W ' g
~
y
,,yt.,
//L f//A'/v//,
(c) 3ee'itel. c no} rennyedge.rc utrikeajfrem be.no metal
, y. p 4.- : 7.. w.~
.:up: orts er ntructural steel na required by AUS D1.1.parcgraph.* -
- . i '
4.4 JUp //cf*Bd0tY. O (10) I obs*rved instances uhcre rrn off plates war.e-mot. used as. -
'w required b.i Avi: M.'
parar rach 4.6 oi, roove wcld terminat. ions.)
Me I cannot rec.11 any r. ocific locations, but I do recaill ob-
- s..
serving this con:iition on benn and girder splicesg gg,' ///p)P
/
a s
?5 l ' d-T*' Nfdff~ Ch'd A/fWDC! r 5A
' ' M 'I
- I (11) I believe that a n-'acer vlate i.: missin'; on t,he upner inside I
door hin, e of the ilnit 2 containment nersonnel hatch because
'M I observed a. ap in t' e wcld jcint cf'about 1/4 inch.
I.
crourht t :Is to t' e attent # cn of my supervisorgwno also,
pg]
- c. arco t.:a: belief.
I believe thct by brin : int; this condition,
2 to the attention of my cunerviser I had prouerly perforced my outy te identify this condition.
I did not ccen are the draw-ing requirements to the installed condition in nakisc this determinat' on ci a mis.'-ir.:: n :acer vlate gg44pfsc pffpf%Ef/s%1t.-
g
/*Vf'.'U'/~i;D i
W J/l* 'T's d f / f /UJ 'r* 7/,t{ l/E-A &xYL!f f)af M 6 Ar p W y M ~
(1E) I believe that f.cchtel h... mi.sinternroted the requirements of -
g
/
t ' a. 81-;.::.Jection III weloina; stancardo re.iardinr; socket weld -
fT Oi onra >emon*. lenrth without initiatinC a code case anci obtaining /// CAC 7F A
~
4 approbriate come relief. ;'.'he AS1iE coce requires a gap between /4/g/pp/jpg, the pipe end and the fittin. of"apcroximately 1/16 inch". I.
believe that the code shoule provide a more definitive acceptance criteria than morely "approximately 1/16 inch". gv//4'#r;t.f'Mrgg, g"
/As;t.A4H. LAW [?/.W.hv4 c.
ge,. d, (13) 3echtel specification UQ-2, % 4iisW6.)$ f)4' P/i;r /S A
sheet.20, note 1, requires "shall -
4917 4 not exceed 1/3 inch..." rog2rding maxi =um groove weld reinforcemen pg R,M/FMfhS~@ ired by the /.S 4E 3ection III code on groove weld rein
'?his requiremont should read "shall not exceed 1/8 inch 4.."
j/ff f,,4'/ g j j y 9 as requ f
The 1/3 ir.ch heicht is:icolemented at San Onofre.
TW/.d A't'Mei L-g y. sg.p.pe the caliber of indivi$pyygggAr- &&
g f/g/.7 ' (14) I believe that uals employed by Peabody Testing h to perform nondestructive examination (UDE).on welds in nuclear service annlications wan not acceptable. This belief is based an g8
[('l/.//)'l~#7"/;r, panellin.3a cf t he words }' fillet" : tad " weld",[oitthe. observ
-NDE 'ribrts~p'repared p.7 g-gg, by these individuals. Because of those observed spellinggfr:pfs,[
f.
I oucation tne abilities of these HDE nersonnel to perform the N,A/P renuireo.examinatiens as required by their procedures. I.believe
. that 'estallWh'ed~ irid'Fr.f.t indards recarding the nualification of u
f air f
- i!DE personnel oro not sufficient to assure an adequate level of
-3J 8 personnel ennability and knowledite in this very importent area l A[!;- $fch'Q2 of inepoction.
(-s.,Q.a g fhj {rt4 y
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I have advised the ubove namedlil2C norsonnel of other concerns I have ree ardin-inadeo'sacies that I"Ahist in Industry Codes and Standards (i.e. AtlS, AS':E, AI C. etc. ). The HRC representatives have told me that those aream are not within}the jurisdiction of the HRC and although I do Q sj n rs rW Sr k uW/K w w w k wis, M.un (ww,m,, w :-si,~..~
.u,.., n ao.. n ur.
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,d Continued State ent of E. Earl Kent........................
..Page 4 over i
not necessarily agree with this, I do understand that this to the easse..t The !!RC representatives have also told me that I can report my areas of i i Ar fW$W !.'garding Codes to the anplicable code coc:nittee./y/plW ' /f 41 W
- giggs,'y '
concern re j
6 regarding veldins; done on non[, nuclear safety related I further have advised the NR representatives that I have many e oerns gg;g ;
I have been advised by the NRC representatives that these areas are also o not within the jurisdiction of the NRC. The NRC representatives have told - #W4 ne that I car. resort these concerns directly to the utility, SCI,.or pg whatever other local, state, or federal agency that has jurisdiction.
fHofm W AS Nur
?ht?VT9 /M YW Ugira,Gxr,,,,2 Nsso Nsi-p is ESQI4tgffircpg,;_
Tgyyjgjpggg197y,
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'O Continued Statement of E. Sarl Kent...........................Page 5 k
I have read the foregoins; statement consistin6 of this and four other ;-
i tytewritten. ar.co. I have made and initialed any necessary corrections and have sir;ned cy name in ink in the mart;in of each page. I swear that ths- -
)
foreccing statement is true and correct. Signed on at Signature:
E. Earl Kent.
Subscribed ano sworn to before me this day of 1982 at Investigator:
Owen C. Lihackleton Jr.
Uitness:
Philip V. Joukoff Investigator, OISITO b
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