ML20211J171
| ML20211J171 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/22/1984 |
| From: | Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML16341D790 | List:
|
| References | |
| NUDOCS 8606260251 | |
| Download: ML20211J171 (14) | |
Text
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I a-nresently werkins in 2erion III,
'e nr.me is iss 'lin.
r as a Senior :*echanical' Enrineer.
.ivision of T,n:ineering
~. elative te the Diablo Canyon Luclear Power Flant I was assigned the (DC::?? ) tear investigation effort, i
res:ensibility of followinn up on some bf the allerations p
r.ade by F.r. Charles Stokes. The specific investication i
site small bore (S/B) f.
areas were restricted to the piping susrension system design control. However, due to hardware deficiencies observed during plant walkdown, the licensee desir.n control measures for large bore system had also been included as a part (L/h) pipin.e of the overview inspection and evaluation.
of the investiration and inspection findings, As a result i reactor is r.y prcfessional opinion that the Unit it should not be permitted to go critical at this time.
Th.e reasons for such determination are as follow:
all of the Stokes allegations assigned to 1.
Almost me for followup had been substantiated. Based on the 10CFR50 the many assessed violations against
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fror followup on Appendix B criteria resulting these allegations and the independent overview it was concluded that there had inspections, been apparent QA program breakdown in the areas of S/B and L/B piping design centrol.
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paa Devine Dchibit 3 h
2.
Pipine systems car.r.ot be subjected to true function-ability tests until after severe transient cor.ditions, such as an earthouake, hac occurred. The ensurdnce of systen operability relies principally on ar.'alytical methods. In spite of this dependence on theory and analysis, the lack of licensee L/B and S/B piping system design control that had resulted in an alarmingly large number of calculation errors and deficiencies that had slipped through various review and checking staces, is indicative of the failure of the Corrective Action Program conducted by the Diablo Canyon Project (DCP) group in the past two years.
3.
Issues raised in respondin,; to the staff's initial concerns were discussed during a meeting held with DCP personnel at IGC-ImR office on December 15, 1983.
Discussions included onsite design personnel training, document control, audits, design verification, thermal loading release within the rigid restraint gaps, e
and snubber / rigid restraint interaction. At the time of the meeting, none of the issues was considered to be a problem by DCP. However, during followup inspections, all the above items had resulted in staff assessment of violation items. The event-S
- t and reflected DCP's lack of concern for establishmen implementation of a sound design control QA program.
snubber and rigid Hardware problems involving 4.
bber restraint interaction that could make the snu
'fied inoperable under design conditions were identi tion in La Salle Unit 1 just before the NRC opera and had resulted in licensee license hearing, and removal and
- report, filing of a 10CFR50.55(e) ll size replacement of hundreds of large and smain regarding mechanical snubbers. The DCP's position i
be not the same situations. identified at DCHPP to e
I in a problem recuires in-depth review and evaluat o by the staff.
with fuel loaded in the Unit 1
. At the present, 5.
including complicated
, reactor, the access control and the poor air quality resulted security system, tion f rom system hot functional testings, makes inspec inside the containment difficult and intolerable.
ty p,2(at;.n will be: (a) sub-With the e:g e:ticr. that there tion stantial amount of staff and licensee reinspec ification activities, and (b) some system hardware mod to allow reactor low power testing f
and re-work, dis-before resolving the existing problems could d could courage additional inspection effort an hinder any required corrective actions.
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i My name is Harold Hudson.
I am submitting this affidavit freely and voluntarily, without any threats, inducements or coercion, to Mr. Thomas Devine, who has identified himself to me as the legal director of the Government Accountaoility Project.
This statement supplements my i
utA
~ (GVtalf
,1984 affidavit, because I am deeply concerned about two I
major problems at Diablo Canyon that the fluclear Regulatory Commission
(;1RC) staff overlooked in its recent recommendation to permit low-power operations:
1)
Large portions of the plant were not built or inspected to 10 CFR 50, Appendix B, the ilRC's legal quality assurance (QA) regulations.
2)
The ;iRC based its recocrendation for low power operations on false statements in Pullman's file or in February 1983 Pacific Gas and Electric (PG&E) letters to the NRC. This abuse was especially prevalent for Pullman's respcases to the 1977.luclear Services i
Corporation (;4SC) audit findings of a severe quality assurance break-down.
I know, because as Pullman's internal auditor for 2.5 years until late 1932, I became intimately familiar with the quality-related documentation.
l I am deeply disappointed that the NRC did not discuss with me the contents of report 83-37, the staff evaluation of the 1977 NSC audit.
I do not The eventual report represents an attempt to rewrite history.
know if the ilRC was duped or is part of a coverup.
But I could have easily set them straight.
I tried to take the initiative, by submitting three reports to the llod
'b 22 $3
.iRC between :lovember 1983 af 21.:.., '.:33 and January 1984.
- Further, during January 1984 I met with the :iRC on three occasions to dise.tese.
Devine Dthibit 4
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quality assurance (QA) violations. These violations complemented the issues in the ?iSC audit, but were not identical to those being researched by the staff for Report 83-37.
I did not even know the staff was working on Report 83-37.
I did, however, inform the staff that as Pullman's internal auditor I had thoroughly researched the ilSC audit.
I also told the staff that liSC was right.
I also told the staff that l
I had tried to implement corrective action.
I also told the staff that management refused to permit necessary correcti::e action.
Finally, I 1
explainedtothestaffhgwmanagementharassedandretaliatedagainst me so much that in M 1983 I resigned my job,and returned to Diablo e
Canyon as a pipefitter.
In case there is any question about what I
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told the i1RC, I have tapes of the meetings.
1 Under the circumstances, I cannot conceive of any good faith e:: plana-tion tnat the IIRC failed to discuss the :lSC (or Pullman) audit with me or tell me that they were working on the issue.
There is no excuse for the gross inaccuracies in the ilRC's findings.
It is as if my knowledge were threatening, or might get in the way of something they had already decided.
I also want,to emphasize that the ;tRC staff never had any followup meetings with me to clarify the issues I raiseo, or to test whether PG&E's defenses were bluffs.
That is odd, since I disclosed over 80 1
SINoJJ Ac4 pages of my own s'rle spaced reports and affidavits to summarize over soM of no4
}
a thousand pages of documentation.
I only learned of PG&E's ansQers, g
i because GAP xeroxed them and gave me copies. The :lRC staff complimented I
hi,ghly the analysis in my reports, but they never got back to me.
11
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disclosed A allegations to the NRC, out of the 170 in a January 31 legal petition.
Any statement that the NRC staff followed up with me personally after I first raised my charges would be tptally false.
I have no idea what the NRC staff did to resolve my allegations, other than to have PG&E respond to some in letters.
SomE Of M f
After I received PG&E's letters from GAP I studied my files and s.-
4 saw that some of the responses represented false statements. After GAP provided me with a copy of Report 83-37. I saw that it relied on false statements and missed the most significant issues.
If the NRC had chosen to speak with me, I would have discussed in detail the issues and evidence introduced for the record below.
If the NRC ever convinces me tnat it will look seriously at the general issues below, then I
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will write up specific allegations with detailed analysis.
i 1)
I am particularly concerned that until at least 1982 Pullman's p
program-for pipe supports and pipe rupture restraints did not comply with 10 CFR 50, Appendix B.
I cannot understand why the NRC would not have f
t covered this issue in Re' port 83-37, since that is what the NRC is all
-j about.
Presumably there should be some effect if the NRC's recommenda-
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i tions are not part of the picture.
In a previous affidavit I recalled i
L how on several occasions Mr. Karner told me that we didn't have to comply with 10 CFR 50, Appendix B.
f Mr. Karner was tnoroughly familiar with company policy. The official excuse was that Pullman's program complied with Section Three of the
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American Society of Fechanical Engineers (ASME) 1971 code requirements, which are consistent with 10 CFR 50, Appendix B.
(See_ June 13, 1978
14 L %
pl 3q l -
l audit, enclosed as Exhibit 1, at p 2.)
The problem is that the ASiiE code did not cover pipe supports and rupture restraints.
That left us on our own.
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While PG&E paid general lip service to Appendix B, it did not enforce that policy on us through contract requirements.
An October 13, i
1977 Pullman meno on the NSC audit (Exhibit 2 at p. 2) explained, "We WE
, d. Lg have not been required by h"...2n to update to Appendix B."
An unsigned, undated draft report on the flSC audit (Exhibit 3) explained further:
f.-
'"" "Tio attempt, however, was made to totally
]
revise the program to incorporate specifics of 10 CFR 50, Appendix B."
(I,d., at p. 4.) On page 9 of the draft, the author implies NRC approval C
for failing "to update the program to match Appendix B...."
(I,d., at p. 9.)
- 2) After conceding the problem of not meeting 10 CFR 50, Appendix B.
Pullman chose to perpetuate it.
A November 3,1978 program description (Exhibit 4) did not make any references to 10 CFR 50 in the charts and
]
g.4 9;fE Soffod.T5 Aub attac'hments forgpipe rupture restraints.
The ESD's, or installation L-procedures, are the only guide for the QA program.
(Id_., Chart #3 and J -1. )
1
- 3) Actua]ly the problem was worse.
In effect there was no formal g@QA program forg Pi?E Su mmers AND 1
pipe ruptJre restraints.
The problem first was identified
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in a ;iovember 1973 audit (Exhibit 5) which conceded that the QA Manual g@
h M *>oFioS TSAND skipped pipe restraints.
Instead there was only ESD-223, the installation 3
procedure which the auditor called "in essence, an ' alternate QA, program' RES @EeJ7 /,iEC.4 ANICA E NCl4&
PI R ECS* R O I-approved by theg:r:t. ath.t-r:g-:r, instead of the3QA Frs :r as requi red.
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ddd 3.pH 4) Although Pullman identified many deficiencies of ESD 223 in 1973, the company did not learn its lesson.
The NSC audi,t repeated f
similar findings in 1977. C h^#4LhPA%P8C N
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- 5) A January 10, 1977 memo from Pullman.QA manager J. Runyan explained another major point:
Tne pre-December 1973 pipe supports were installed " prior to implementing the inspection program" (Exhibit 6)
- 6) A November 13, 1978 memorandum from Pullman's Senior QA l
Engineer R. J. Manning (Exhibit 7) conceded that "in the past" Pullman "did not conduct audits or practices to ASME or 10 CFR 50, but I feel I
it very essential to do so now." As demonstrated by my own personal experience, the author's advice was ignored.
From my own reviews, I g
know that the early audits which existed were well-intentioned, but crude, uncontrolled and infomal. Tney were too sloppy to constitute a minimal program.
For example, a 1973 audit referenced conclusions about pipe rupture restraints to the contract for pipe supports, which didn't apply to the work in question.
(Exhibits,Suora.)
l I
- 7) Until at least November 1978, some parts of the QA program had never been audited.
As revealed by Mr. Manning, "The Diablo Canyon program has been audited extensively only in hardware areas. The entire program has not been evaluated."
(Exhibit 7) 8)
In Report 83-37 the NRC accepted uncritcally PG&E and Pullman's position that Nondestructive Examination (MDE) personnel have met the
't American National Standards Institute (ANSI) N45.2.6 requirements since
M g.Y 9
1973 or 1974.
That is false. !*.anagement ha recognized a problem since 1973, but as of July 1982, they had nd upgraded the program to comply with ANSI H45.2.6.
In the meanti:ne, aarious managers recomended comitments to honor ANSI, but it simply did not happen.
For a December 1974 example of the recorr.1endations, see enclosed Exhibit 8.
The Pullman QA manager's July 1982 refusal ta honor ANSI'N45.2.6, is enclosed as Exhibit 9.
Don't forget again, even ASME compliance DoEs Mot ONW M would not cover the entire QA program, since AS:1E +k-4ps pipe supports g
and rupture restraints.
9)
The reason Pullman didn't meet the DSI requirements is that it was not willing to pay for the experiencef personnel required under 6
tae professional code.
As Pullman's QA canagr explained in a May 13, l
1975 me.r.o (Exhibit 10),
"[I]t is virtually tpossible to comply totally to N45.2.6 because of experience requirements. We cannot hire personnel
{.' I that meet the experience rqquirer.ents for tM salary scale we offer."
l,
,i 10)
In its Report 83-37 the,;RC agreed 4ith Pullman and PG&E that i
the personnel files demonstrate adequate recIrds for welder and NDE certification. As a result, the staff decidef that NSC was arong.
That is false.
A September 15,1977 memo si p
ciMefo.4 cf suAug Assutwr(c.ned September 22), from Pullman's p G r nc vke,.. c.,-:last to the sik QA manager, (Exhibit 11),
" Generic 3DE and Inspection Records", includ:ng - " lack of evidence showing the necessary records" to support the certifications;'iack of any certifications; certifications dated 'Is much as a year" after the inspectors began work; and " lack of evi'mca supporting previous work experience and Level I and Lavel II qua'dfications at a previous employer", among many o,ther deficiancies.
in corporate conclusions of
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generic deficiencies were based on a review of 95 files.
The NRC looked at the same files and found nothing wrong.
What happened?
i 11)
I decided to thoroughly research one of.the 95 deficient files.
I chose Pullman's liDE supervisor Don Geske, who certainly should have I
had adequate qualification records.
Reviewing Mr. Geske's file i
revealed the magnitude of the inaccuracy.
His records say he passed tne three Magnetic Particle exams with flying colors -- a score of I
a 98%.
But records on the three specific exams record the following l
results for the supervisor:
.[and]
There are no i
grades recorded for his perfor:1ance on individ.;al tests.
The records I
are attacned as Exhibit 12.
li
- 12) On September 25, 1980 an in ernal Pullman audit (Exhibit 13) e.
admitted that two NDE technicians were certified for advanced (Level E
G E
II") responsibilities, despite " letters in their personnel files stating they are not qualified to perform Level II functions...."
Pullman's " solution" was for Mr. Gaske to backdate letters to July 24, 1980 (Exhibit 14) that said the opposite -- that-the two men were qualified.
I do not believe that rewriting history is any way to solve quality problems.
13)
I also challenge the accuracy of QA l tanager Harold Karner's M
i ilDE quali fications records.
In 1979 when' he was originally ce,rtified AT tiguo, Mr. Karner's certification did not cover NDE.
(Exhibit 15)
But on July 27,1981, when 11r. Karner was recertified after the required two years, he was certified as Level II for liagnetic Particle Testing ( *,P);
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Radiography (RT); and Liquid Penetrant Testing (LPT), as well as m-------
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99 cevel I for Ultrasonic Testing (UT)h From my own experience, as the internal auditor with Mr. Karner during that general time frame, I know he could not possibly have obtained the 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of required practical experience even for MT -- let alone the other two disciplines.
14)
In 1976 Pullman reported that Mr. Geske allayed concerns about 1200 suspect weld attachments by reinspecting 314 with magnetic lM foul 1
particle tests in +,+ days.
(The attachments had been in question due 6
CSSG CArEb #m?)y5 WEtts 69&b 1
to noncompliance with preheat requirements.) E. m m - - ~..
g 35 % *secub W Aun rwc evnr,'uwe-wcos evse. Tat NCvf two tAy5.
They all passed.
Unfortunately, the maximum possible number h
of magnetic particle ezams that an inspector can perfonn in a day is around 50.
The 1976 inspection findings are enclosed as Exhibit 17.
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15)
The signatures on weld process sheets -- which insure the h
work was not done in an ad hoc manner -- were phoney. A blank sheet was signed and then xeroxed.
This is evident from a review of multiple 1
/,
. veld process sheets -- the signatures are too perfectly identical.
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I also confirmed this practice with engineers from the early years.
Examples are enclosed as Exhibit 18.
16)
In Report 83-37 the :lRC made the following finding on page 18:
2 "The inspector examined the 90 day welder's log and found that no void existed between 8/72 and 12/72." This was the basis for NRC findings, I don't know who is responsible, but that statement is false. Ja TNF i
g SC5foV56 To TAE NSC-A vbiT April 1978 w.m.41 Pullman n =.da: (Exhibit 19, at p. 25.F concluded the opposite:
"There is a void in the 90 day weld log from August,1972 to December,1972." Any excuse based on a purported reconstruction of the log cannot wash.
The NRC should know, because i
my."ovember 1983 report to Commissioner Gilinsky should have been
y--
q.9 reviewed by the 3RC staff months before Report 83-37 was issued at the 2.0 ng 1Avf %cticio 40W EA*4 1{4 end of February 1984. C' g.p. C '. L F J-I challenged the reconstruction g
as not being reliable, due to inconsistencies and omissions that rendered impossible any confidence in the results.
17)
During the early years of construction QA/QC personnel intemingled responsibilities with production personnel.
Because of this phenomenon, the quality of early audits was sacrificed beyond I
repair.
For example, part of the reason for the informal, unprofessional nature of 1971 and 1972 audits (Exhibits 20,21) is that they were per-i formed my individuals identified in the signature log (Exhibit 22) as the snop and field engineers.
It appears that the shop engineer even audited the shop.
Due to their unreliable nature these audits could not reasonably substitute for required audits, such as for the welding E'C$
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- 18) The practice of intermingling QA/ production duties continued i
into 1976, as a QC weld inspector named Art Mullis inspected the same drawings he had prepared as a field engineer, (assigning field weld numbers and weld symbols).
(Exhibit 23) 19)
Contrary to Pullman's assertions, in response to the NSC 1
audit, the quality of QA/QC suffered due to these conflicts-of-interest.
To illustrate, Mr. ilullis accepted his own practice of having one ido!P process sheet for five weld joints.
@ His was also the xeroxed signature for numberous blank weld process sheets (Exhibit 18, suora.)
- 20) Management's refusal to back me against harassment from production made it more difficult to do my job properly.
To illustrate, 1
on August 13, 1982 I attempted to report harassment -- such as, rifling my desk and taking an audit notebook.
Mr. Karner refused to let the memo be sent, and threw it out.
I kept a copy, which is enclosed as Exhibit 24.
'l
- 21) The PG&E response to my report on minimum valve wall thick-nesses is so incomplete and internally contradictory that it could be the basis for numberous allegations.
I will list a few of the high-lights here.
PG&E asserted that procedure qualifications tests were not necessary because the inspectors calibrated their tools.
But that
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l is a totally uncontrolled response, and one which the inspector should take anyaay.
Additionally, my January 1984 affidavit to the NRC and i
my January 1984 report on minimum valve wall thicknesses also demonstrated j
the unreliability of calibration data for the equipment.
In many instances, there was no calibration data. Obviously, this was no sub-stitute for procedures whose reliability is proven by tests -- the normal QA foundation -- especially for valves with key safety functions.
I wondar if the 3RC has considered this issue in connection with PG&E's request to waive previous licesning commitments in the FSAR.
22)
PG&E's response on the inability of valve thickness test s
equipment to catch specific eccentricities were accounted for through a CRT screen.
Unfortunately, the test procedure doesn't use a CRT
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screen.
Instead, it uses pulse echo digital readout equipment.
23)
PG&E's responses to welding allegations suffers from a 3
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1t,ams to d. _ at. _
. p _..s us.d to f
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-11 verify tne quality of the welds were the same as those specified by -
From the sketchy Code 7fB to install the welds in the first place.
m infomation provided by PG&E, I know there are significant differences.
letter to the NRC takes credit
- 24) PG&E's February 17,1984 for having prepared the final approved drawings (original and revisio
=
futLIMV dag without exception. That is false.
A September 18,1973-!!iDE audit aus Hangers."
revealed, "PG&E is not approving the design of any 2" and under C~
(Exhibit 25)
I have read the above 11 page affidavit, and it'is true, accurate and complete to the best of my knowledge and belief.
I MD Harold Hudson j
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..a AFFIDAVI'T_
B My name is Harold Hudson.
I am submitting this affidavit freely and volun,tarily without any threats, inducements, or coercion, to Mr. Thomas Devine, who has identified himself to me as the Legal Director of the Government Account-i I am submitfing this state-ability Project of the Institute for Policy Studies.
I ment to evidence my concern over a comprehensive quality assurance (QA) breakdown for the work of Pullman Power Products at the Diablo Canyon Nuclear Power Plant.
There is no possible justification for allowing this nuclear power plant to go critical until the iluclear Regulatory Comission (NRC) confims the full scope of QA breakdown; identifies the causes; and monitors completion of a corrective action program, including a full reinspection of safety-related work at the plant.
In many instances, the reinspection may be the first legitimate quality control coverage the hardware has had.
I base this conclusion on my four and a half years experience at Diablo Canyon in Pullman's quality assurance / quality control (QC) program, including two and a half years, through 1982, during which I was the Internal Auditor. The basic lesson I learned is that the conclusions of a Nuclear Service Corporation audit of Pullman are more true today than when first published in 1977--the program does not meet the requiren.9nts of 10C.F.R. 50, Appendix B; and it does The latter has been demonstrated not have an operative corrective accion system.
1979-1983. While before, by the further deterioration in corrective action from the system was merely failing to identify and solve problems, now it is actively This has been especially true with respect to welding, non-covering them up.
destruct.ive examination procedures (NDE), and hydrostatic tests--alf of which I learned'were consistently uncontrolled, and that some of the procedures for the first two items were not qualified by a testing process which proves the procedures l
actually work as claimed.
-3kgN!
Devine Exhibit 5
2 The system also broke down for vendor quality assurance, where Pacific Gas and Electric (PG&E) management ordered Pullman inspectors to stop reporting cracked welds found in structural steel restraints supplied by vendors such as Boston Bergen and American Bridge.
As an auditor trying to work within the Pullman site and corporate QA system, I learned the cause of the QA breakdown and why it has not been corrected.
Pullman QA Management does not want to know about QA/QC violations. Management's corrective action has been to harass, threaten, and intimidate QA/QC personnel who identify problems, and to dismiss those who persist. Although I exhaustively reported deficiencies, the major effect of my disclosures was to prompt orders from the QA manager to only look where I was told, and his angry threats to "get rid of me"During one such exchange.he exclaimed Pullman's bottom line: we're not committed to building this plant to 10 C.F.R. 50, Appendix B.
In that case, I do not see any legal basis for the NRC to allow this plant to operate.
I am not opposed to nuclear power.
Rather, I believe in the technology enough to insist that it receive the proper respect.
I began working in the nuclear power industry in 1974 at the Trojan Plant and have worked at the Humboldt Bay Plant.With the exception of two months in 1979, I worked at Diablo Canyon for Pullman from September,1978 until Friday the 13th,1984, when I was laid off. The layoff occurred the day after I finished a two-month series of disclosures to the NRC.
For my first three to four months on site, I was a documents reviewer. For nineteen months I worked as a weld inspector in the pipe rupture restraint program.
In August, 1980, I was promoted to QA Internal Auditor.
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, My responsibility was t.o' evaluate and monitor the entire QA/QC program for compliance with our legal obligations.
This is how I learned that Pullman does not consider 10 C.F.R. 50 a legal obligation for work at Diablo Canyon.
In January,1983, I was removed as internal auditor, but remained in the QA program to help close out Discrepancy Reports (DR) and Deficient Condition Notices (DCN), as well as to complete my pending audits. QA Manager, Harold Karner, restricted me to carrying out his specific assignments.
The harass-ment was so intense that in mid-May I resigned.
Through my union, the next day I return to Diablo Canyon as a pipefitter.
There simply had been too many headaches attempting to work within the corporate system.
On my own time, at home, I finished organizing and summarizing my evidence of QA violations.
In November, I completed an initial report.
On November 28. I sent it to NRC Commissioner, Victor Gilinsky. 'On December 6,1983, his office wrote that I would be contacted by the Office of Investigations (OI).
Although OI never called, on January 6, 9, and 12. I was interviewed extensively by a series of NRC inspectors from Region V.
On January 13. I was laid off.
This statement will summarize the information and list the allegations in three written reports already disclosed to the NRC.
My affidavit also is to submit a written record for allegations which I have only described to the NRC in interviews and identify allegations not yet described to the NRC.
I.
QUALITY ASSURANCE BREAKDOWN FOR WELDING With a few exceptions, from the onset of construction, the welding program for structural steel essentially has been uncontrolled--in vjolation of legal requirements, as well as contract and design specifications.
The techniques to circumvent quality assurance included unqualified welders; I
i 1
unqualified welding procedures; use of welding procedures so irrelevant for the assigned work that, in effect, safety-related welding was widely conducted without procedures; reliance upon unqualified inspection procedures to check the quality of the welds; informal changes of contract specifications without the required administrative review or distribution; falsification of records; and harassment and intimidation of QA personnel who identified and attempted to obtain corrective action against the violations.
The abuses occurred both during original construction, and during the current modifications due to the Bechtel/PG&E seismic design review program.
The list below represents a more detailed summary of the allegations and evidence that form the basis for the above conclusions.
The list is drawn primarily from my November 28, 1983, disclosure and attachments to Commissioner Gilinsky, which are enclosed as Exhibit 1.
1.
Weld procedure Code 7/8 for piping and plates has been used improperly to weld numerous forms of structural steel on pipe supports. What happened is that Pullman substituted American Society of Mechanical Engineers (ASME) pipe welding procedures for the American Welding Society ( AWS) struc-
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tural steel procedures, as implemented.
This practice exceeded the legally-approved limitations for use of the procedure.
The limits were logical, since the two types of jobs have little in common.
Pipe welding involves working around a circumference. In structural steel welding the axis of the weld is on a. straight plane (Exhibit 1, at 2).
2.
Code 7/8 has been used improperly to weld tube steel on pipe Tube steel involves a different type of metal than the F-1 material supports.
covered by ASME procedures.
This is significant, because the NRC has identified G
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use of the same metals as a precondition to use ASME procedures for AWS work.
In fact, tube, steel welding is so unique that the AWS Code has a special sec-tion for it (Id., at 2-3).
Code 7/8 was improperly used to weld threaded weld studs 3
3.
which bolt plates to civil steel on Class I safety-related pipe supports.
The type of welding used for these studs is not listed within Code 7/8, and it bears almost no resemblance to the work lega'lly covered by Code 7/8 (Id., at 2).
The welding for threaded studs did not even honor the require-4.
Instead, process ments of Code 7/8, which calls for the use of a backing bar.
sheets operated by the construction department imposed backgrinding, which is a totally different operation (1d.).
Code 7/8 has been used to weld at least eight pipe support 5.
including flare bevel groove welds, and double bevel i
joint ::-'f ;:-It ent,
Each of these configurations repre-groove welds, not covered by Code 7/8.
sents a unique welding task and legally must have its own approved weld procedure specification detailing the joint configuration (Id at 3).
process sheets that guide quality control coverage did 6.
not consistently call for inspection to verify the fitup of flare bevel groove welds; one of the joint configurations not covered by the 7/8 pro-That leaves the quality of the ensuing welds cedure in the first place.
This uncontrolled work has been occurring as part of doubly unreliable.
I have read a the current design modification construction work (Id.).
pG&E memorandam ssserting that QC fitup inspections are not requi' red for That memorandum is not sufficient to overrule engineering flare bevel welds.
6 i
~
specification ESD 264, which requires inspections of groove welds and full penetration welds.
7.
Code 7/8 has been improperly used on pipe rupture restraints to weld five types of metal different from the ASME approved P-1 material.
These restraints prevent a pipe ruptured during an earthquake from whipping back and forth, which could damage the rest of the equipment (M., at 4).
i 8.
Code 7/8 was improperly used to weld two structural steel shapes on pipe rupture restraints that are not covered by the procedure--W shapes and tube steel (M.).
i 9.
Code 7/8 was improperly used for at least 11 joint config-urations not covered by the procedure itself.
These joint configurations were not generically prequalified per the AWS Code and were without Procedure i
Qualification Reaords and/or were not detailed on the Held Procedure Specification (M.,at4-5).
The result of the procedural breakdown was uncontrolled 10.
t i
welding. To illustrate, in one example, pipe rupture restraint square groove welds were conducted without any established or documented procedure that applied to the work in question.
In some instances, welds had been completely removed without any QC record of their disappearance.
The records reflected QC accepted welds where none existed.
For documented repairs, there was only erratic QC coverage due to unexplained procedural changes that deleted the requirement for nondestructive examinations (M., Attachment 2).
l
11.
Pullman has recognized the error of applying ASME welding l
procedures to AWS work in an uncontrolled manner and issued Welding Technique Specification No. AWS 1-1, in an attempt to clarify the proper use of Code 7/8 on AWS work. But the scope of corrective action was inadequate.
It only covered the work in a weld crack repair program on pipe rupture restraints (M.,at5-6).
The misuse of Code 7/8 far exceeds the use of l
AWS 1.1.
The crack repair program only covered about one-fourth of the pipe rupture restraints, and none of the pipe supports.
l
- 12. AWS 1-1 failed to fully correct the improper use of Code 7/8 for welding in the weld crack repair program.
The procedure uses a steel not contained in the list of acceptable AWS base metals, without evidence that it had been individually qualified to prove its reliability (M., at 6).
13.
The above violation was approved on December 20,1979, by V. J. Casey, who signed off as Cognizant Welding Engineer.
Sixteen days earlier, however, he had been appointed Pu11 man's Assistant QA/QC manager, according to an interoffice memorandum.
To my knowledge, Mr. Casey has never been l'isted on the Pullman organizational chart as a Cognizant Welding Engineer. The only way his approval would not represent a false statement is if he were simultaneously a construction and QA official.
That would be a violation of the NRC's requirement for a QA program independent of construc-tion (M.,at6-7).
14 I also have serious reservations about Mr. Casey's qualifica-tions, based on his judgment in the field.
In 1978, Mr. Casey was my He instructed me to measure supervisor when I began as a welding inspector.
fillet welds by the throat, when the AWS Code requires the measurements from o
-c-1 s
the leg of the weld.
For approximately two months, I inspected welds to the
)
I wrong standard, because Mr. Casey gave me a makeshift gauge not designed to measure fillet welds.
Other inspectors informed me that Mr. Casey has changed the rules on the spot for equipment anchor modifications in the containment.
They stated his instructions were to work to a " relaxed" engineering' specification ESD 243.
15.
Through loopholes in its Engineering Specification ESD 223, Pullman improperly exempted itself from AWS design, fabrication, and erection requirements for all structural steel pipe support welding.
Writing off the rules in this fashion violated the PG&E contract specification:.
To my know-ledge, there is no documented authorization from PG&E to deviate from the Code requirement, which is still in the contract (1d., at 7-9).
16.
PG&E contract specifications on welder qualifications were changed without required review and au;horized approval.
The rules were changed through a cryptic, unexplained note.
The changes involved the qualifications standard for all rupture restraint welders before July 10, 1979..The use of ASME qualification standards for welders doing unrelated AWS work mirrors the breakdown in welding procedures. Again, however, the 1979 corrective action only applied to rupture restraints (1d., at 9-12).
17.
The PG&E contract requirement for Charpy, or notch impact strength tests, was waived for Code 7/8 and other welding procedures.
Charpy tests are necessary to be sure the welds installed under the procedure can meet relevant design and professional code requirements for strength.
Deleting this requirement was a serious step, which should have gone through the Con, tract Specification Change Notice process to assure proper engineering i
review and approval.
Instead, in January,1974, a PG&E piping superintendent
--_,,__.-_w-__,-,,__
,-,,,,.-_.-_.--,--.,c,-
w,_,,
.,,m.__
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. removed this significant QA check with a one-word penciled response, "No",
when Pullman asked in a letter if weld procedures for rupture restraints required Charpy impact tests (M., at 12-13).
18.
In violation of still unrevised contract specifications, specific corrective action commitments on relevant Nonconformance Reports i
(NCR), and relevant procedures for the weld crack repair program, none of the full penetration welds less than 9/16 in. thick among rupture restraints were ultrasonically tested.
This means that the welds in rupture restraints since July,1979, were not fully covered by quality control tests in a signiff-cant number of. cases.
PG&E engineers accepted the loopholes to Pullman's program in July,1979, again without the required review and approval, and without revising the relevant contract specification that was being ignored 4
l (M., at 13-15).
19.
Another weld procedure, Code 88/89 for carbon steel piping, has been used to weld pipe support structural steel shapes and plates.during both
~
original construction and repair work in the current design modifications.
Structural steel shapes and plates are not covered by Code 88/89 (Id.,at 16).
20.
In violation of the contract specification, Code 88/89 has been used to weld carbon steel plates and structural steel shapes to rupture restraints with two welding processes Shielded Metal Arc Welding (SMAW) and Gas TungstenArcWelding(GTAW).
GTAWisnotcoveredby.therelevantAWSCode(M.')
i 21.
In August,1979, PG&E issued Welding Technique Specification No. AW! 1-3 to clarify the use of Code 88/89 for AWS welding.
Unfortunately, the " solution" again repeated the problem.
AWS 1-3 covers a welding process, (GTAW) and a base metal ( A-515) not covered by the relevant AWS code provision (M., at 16-18).
i m
-. _,. _ _. _. ~ _.. -
22.
Pullman also substituted welding procedure Code 92/93 for pipe rupture restraints when the process sheets specified that the work would be done to Code 7/8. The Pullman Assistant QA manager accepted the switch in an August 15,19'/8, memorandum without changing the process sheets--
which left a record of work to a different procedure than was actually used.
(M., at 18). The only records accurately reflecting the weld procedure used were the weld rod requisition forms (M., at 21-22).
- 23. The informal approval of the welding procedure switch was based on a false premise--that both procedures were qualified to unlimited thickness and were technically equivalent.
In fact, they only bear a passing resembl ance. For example, Code 7/8 does not include a type of welding in Code 92/93 that is only universally approved by the AWS for welds up to 1/4 in, thickness.
Nor did Code 92/93 have its own procedure qualification test to verify its reliability on the welds greater than 1/4 in th'9.
In effect, that welding was uncontrolled and its quality is legally indeterminate. The two welding procedures are also different with respect to joint configurations, joint details, tacking the joints, weld processes to be used, backing bar requirements, and welding techniques, such as the allowable heat input from AMPS and maximum volts. The controls for clearly distinct special processes cannot be legally intermingled through a memorandum (M., at 18-21).
24 Contrary to contract specifications, welders qualified to ASME-based Code 92/93 were used for structural steel welding without being properly qualified to the AWS Code. The switch was accepted on August 15, 1978, Interoffice Correspondence, rather than through an accountable procedure with review, authorized approval and a Contract Specification Chanje Notice j
(M., at 20-21 ).
9
.j
11 25.
An April 14, 1983, Discrepancy Report on 1972 welding in I
the Spray Ring Piping System for the Unit No.1 containment, dome DR #4713, failed to identify an organizational breakdown far more significant than the issue it disclosed (variations between the SMAW weld process used and the process reported in the process sheets). DR #4713 also revealed that the j
process sheets and rod requisition forms referenced different weld rods than had, in fact, been used. The response of the QA/QC manager was to accept the violation as is.
The DR did not mention one of the most signiff-cant violations:
the production department substituted an unauthorized, unapproved procedure and process for the procedure which had been properly selected and approved by the QA system and the third party authorized inspector from the State of California. This was done in order to avoid delays when QA issued the wrong weld rod for Weld procedure 128.
Production could not wait to correct the weld rods, so the foreman just changed the procedure.,In other words, the production department's " solution" was to achieve compat-ibility by making the procedure as wrong as the weld rod.
DR #4713 endorsed the procedure switch (1d.. at 23-25).
If production can overrule the QA system so easily on such casual grounds, it means that controlled welding procedures occurred only when tolerated by the construction department.
Under the circumstances.there can be no basis for confidence that the quality of the welding was controlled. Most significant, in April,1983 Diablo Canyon management was still satisfied with this result.
26.
DR #4713 missed another equally significant violation: QC inspectors had approved all the welds after visual examination, although the GTAW and SMAW welding procedures do not look the same. The 1972 failure raises ' serious questions about the reliability of QC inspections at the
,y,,
I-12-i The failure of DR #4713 to even note the QC inspection failure demon-time.
strates that 11 years later, the acceptance standards have not yet become realistic. Significantly, before it was issued, this DR was reviewed three times by Bechtel and PG&E management, which must assume responsibility for a QA report that failed to disclose, at all, the most significant QA violations i
I Qd...at25-28).
I
- 27. The breakdown in records for the weld rod and weld process sheets render it impossible to verify the qualifications of early welders by reconstructing weld rod and process records, as asserted by Pullman in response to 1977 Nuclear Services Corporation findings that the qualifications could not be established for welders in late 1972.
I demonstrated this effect of DR #4713 by applying its findings to a case study on a welder whose qualifica-l tions were challenged in the original NSC audit (I,d. at 28-30).
M/ attempts to perform my audit duties on welding led to 28.
sustained management hostility, including restrictions on my organizational freedom, harassment and intimidation, and retaliation through personnel actions. On January 28, 1983, the harassment reached a climax. I had already been removed as internal auditor on pretextual grounds (infra, at 23 4) and was doing research for pending audit reports that I had issued, in this I was at my Unscheduled Internal Audit #35 on pipe rupture restraings.
case desk reviewing the records on three full penetration welds that had been Mr. Karner approached tested to the wrong nondestructive examination process.
and wanted to know what I was doing. When I told him, he asked if I had been directed t; identify those problems. Because I was completing a pending audit He then shouted of which Mr. Karner disapproved I accurately answered, "No."
l at me that I was no longer the internal auditor and could no longer identify j
l
,-a-,
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n v,.-.,_-
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13-discrepancies unless he specifically ordered me to. At the time, j was Mr.
still a quality assurance employee, helping to close out DCN's and DR's.
Karner's orders to restrict my inquiries violated th'e requirement for organizational freedom in 10 C.F.R. 50, Appendix B.
- 29. During the January 28, 1983, confrontation, Mr. Karner also threatened that if I repeated this type of behavior, he would "getr rid of me."
From his demeanor. I was unsure whether he was referring to my presence on the job, or my presence--period. Mr. Karner's threats eventually convinced f
me to resign and to take a pipefitting job.
The pervasive atmosphere of intimidation was too counter-productive for an employee to successfully uphold' i
l required QA/QC standards within Pullman's quality assurance program.
- 30. Although Pullman has gotten rid of me, the company has kept the problem of unqualified welding procedures. When I left in January,1984, I
we were still working to the same welding procedures I had audited. Nothing i
I l
has changed except that after all the notice, it is clear that Pullman and PG&E's violations are deliberate. There can be no excuse of ignorance.
Corrective action has been nonexistent or ineffective.
There were discussions on-site of attempting to qualify Code 7/8 after the fact, which would have been ineffective anyway, since it was the sponsoring procedure for considerable i
work that it did not describe. As of my departure, however, even that halfway step had not occurred.
1 II.
QUALITY ASSURANCE BREAKDOWN IN NONDESTRUCTIVE EXAMINATIONS Nondestructive examinations to test the welds and other hardware were as unreliable as the procedures to conduct the welding in the first place.
The indeterminate quality of the testing process leaves the quality of the l
e
_ _ _ _ _ ~. _ _
_ _ r In some cases, NDE best.
hardware in the same status--indeterminate, at at manag'e-i l tion results were compromised due to simple man pu aT PG&E had ment direction.
ts (UT) over with a different the NDE personnel do certain ultrasonic tes mber of rejectable welds.
j t
approach, after the tests had identified a large nu j
i l
d involves A good illustration of the quality assurance break own m
the reactor coolant 1972 tests used to measure Seismic Class I valves onin response i,
r-f
,~
pressure boundary for minimum wall thicknessThe UT pro l'
y Commission (AEC) directive.
nyway, because the procedure
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l l
determine its reliability, which was questionab e aThere is serious ques did not measure the entire surface of the valves.amined, i c'!
l t
CShether all relevant valves were exNot all the equipment use s
L l
j' ip-The former violation invalidates usage of the equ
.~l records.
i i
tion in the
[
traceable and calibrated.
to 48 percent, The latter affects the accuracy of UT results by up F
Informal changes of contract i
ment.
when the AEC required 98 percent accuracy.
al, again facilitated specifications, without the required review and l
d
{
i the QA violations.
entative of a l
The unreliability of valve measurements was represIn I
l i
tions.
general QA breakdown for nondestructive exam na senting three forms of 1
I checked 21 such procedures--seven were de l
The l
nondestructive to demonstrate that test pro-exams i
l
/
basic flaw was that records were not availab eAfte l
cedures were qualified.
ordered me not to, find out where l
l steam generator feedwater nozzle, the OA managerThe resp l
a related test procedure was In some instances, there still used.
problems was to sit on them for over a year.
f
V9 l
[
has not been effective corrective action.
QA management reneged on solutions to which we had agreed. The situation became so frustrating, that I conducted an audit on corrective action and sent the results to Pullm'an corporate head-The response was to reprimand me for breaking ranks, while the QA quarters.
violations continued to be ignored. Below is a more detailed listing of related allegations.
- 31. - In some instances, the unreliability of nondestructive examinations is due to manipulation of the test results in order to mask deficiencies. This allegedly occurred in 1982, with respect to tests involving around 230 Unit I full penetration welds--some in the containment--where UT examinations revealed large numbers of rejectable conditions. Witnesses described the defects to me as voids, slag, and lack of fusion in the roots
)
of the welds--which raise questions about weld bonding.
I was also informed that Bechtel and PG&E management responded by manipulating the UT procedure in a manner that would lower the number of rejected indications. The welds were then " accept (ed) as is" (Id., at 15).
In other instances, the QA violations are more deeply rooted.
The case of Engineering Specification ESD 234 for ultrasonic measurement of valves on the reactor coolant pressure boundary is a microcosm of the break-down. On January 18, 1982 I initially reported QA violations through Internal
- Audit #101.
I tried again in November, with unscheduled Internal Audit #34.
On January 2,1984, I finished a report to Commissioner Gilinsky on this still
)
uncorrected problem, which I have since forwarded to the NRC inspectors at Diablo Canyon.
It is enclosed as Exhibit 2.
There is no evidence that the ultrasonic thicknes's measurement 32.
e
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1.
procedure was qualified through tests to demonstrate the 98 percent level of accuracy required by the AEC. The valve measurements were conducted with an uncontrolled procedure, and therefore cannot be accepted as the basis for conclusions about the quality of the valves.
In my audit, I could neither find evidence of a Procedure Qualification Record (PQR), nor a Procedure Qualification Test (PQT) (Exhibit 2, at 2-3).
- 33. There is no evidence of " procedure verification tests,"
required by ESD 236 for the transducers, that take into account the curves, ridges, and irregularities that exist on every valve and significantly affect the measurements ( M., at 3).
34 Management appears to have conducted the measurements without any qualification test, despite prior warning that the procedure was too unreliable to support its findings.
An April 17,1973, " Interoffice Corres-pondence" had disclosed:
3.
The transducers available are adequate for flat smooth surfaces. There are no adapters, shoes or wedges available should they become necessary.
4.
At this time, it appears the transducers supplied may not be the correct type for thickness readings.
If this is true, we will have to order new transducers.
5.
The effect of surface contour and roughness must be tested prior to making any reportable results.
6.
There is no available equipment on the U.T. equip-ment for review.
It is doubtful that any meaningful results can be obtained at this time and it is definite that-none can be reported until the above-mentioned problems are solved.
(M., and related attachments) m
__________ 35.
Pullman QA manager Harold Karner improperly refused to' take corrective action in January,1982, when I disclosed the lack of pro-cedure qualification records or tests for ESD 236 and ESD 244, the UT Thickness Gauge Procedure. The problem remains uncorrected. His excuse was that these procedures were only nondestructive measurements rather than nondestructive I
tests, and therefore did not represent "special processes" whose quality must be control. led (I.d., at 4).
d That semantic distinction is irrelevant.
The reason to require reliable, controlled procedures is to assure the quality of sensitive, safety-related hardware. Indeed, in 10 C.F.R. 50, Appendix B, Criterion X, the terms " examinations, measurements, or tests" are used interchangeably.
The safety-related purpose for qualified NDE procedures is magnified for ESD 236. ESD 236 was instituted in response to an AEC directive to the nuclear induMry after discovery of valve problems at a series of plants.
- 36. Mr. Karner's manipulation of definitions is wrong. UT measure-1 ments constitute a special process which must be qualified.
They are a special process because they are uniquely created to perform a specific quality-related function.
Further, pG&E contract specifications and 10 C.F.R. 50, Appendix B, Criteria IX, " Control of Special Processes," identify nondestruc-tive testing as an example of special processes, not as the boundary of the concept.
]
37.
VIA #34 of 254 Valve Wall Thickness Data Reports demonstrated that the Data Reports are incomplete and, therefore, are not traceable, as required.
For example, none listed the size, shape, or manufacturer'-s designation for the transducers that performed the wall thickness.
The ESD
- -., - _.., _ _ _ _.. _, -.,,, _ -. - -. - - - _. ~, - _
- _ - - - - _., -. -. -. - ~ _ _ - -,,. - - -
_g 236 Documentation Packages do not provid] any information on the testing equipmen't beyond the serial numbers.
In some cases, there were not even serial numbers for the UT machines and the micrometers used' as a mechanical backup measuring device (H., at 5-6).
38.
The Data Reports offered unreliable, inconsistent infomation.
For instance,19 reports listed two different UT machines as having conducted the same valve measurement. Serial numbers for UT thickness equipment and micrometers could not be verified independently. Ten percent of the valves checked physically had serial numbers different from those listed in the Data Reports. In many Data Reports, original infomation had been whited-out and altered without signature or explanation (M., at 6).
39.
Necessary records to demonstrate calibration of the measuring equipment were not consistently available.
To demonstrate the potential effects, on th ;o UT measurements whose accuracy was tested, the pre-and post-calibration checks showed variations of 10 percent, 48 percent, and 2.6 percent (M., UI A #34, Attachment 5).
The maximum error permitted by the AEC was 2 percent.
40.
The AEC acceptance standards were violated when valve l
measurements from equipment that failed minimum reliability standards (#39, suora) were used to accept the valves as sufficiently thick (M.).
41.
Forty-two Data Reports disclosed that the valves were below the minimum thickness, but on the paperwork they were marked as " accepted" l
without explanation (M.).
l 47.' In 11 cases, the measurements were incomplete. The records simply skip results for required areas of the valve, such as the flat pad at the bottom (M.).
I I
i,
43.
In 14 valve locations, there was no documented evidence that the valves had been examined at all (H.).
- 44. There was no documentation to indicate that weld repairs on the valves were controlled, as required by the AEC. To illustrate the absence 3
of verifiable controls, the Data Reports do not have a requirement to list j
whether valves were weld-repaired, or the weld procedure used (M., at 7).
t 4
- 45. During my research for UIA #34 I discovered that none of the valves meet AEC and PG&E design requirements. Westinghouse, the manufacturer, j
had explicitly declared that they "were not designed to meet the minimum wall thickness requirements of ANSI B16.5"--one of the relevant professional codes i
listed by the AEC in 1972.
By comparing Westinghouse's communication with PG&E contract specifications. I learned that the valves also do not meet the designrequirementsinthecontract(M.).
9
- 46. To my knowledge, there still has not been any corrective I
action on this problem.
If there had been good faith attempts I should have j
been. contacted as the originator of the audit.
I remain available to help follow through.
I i
- 47. Similar to UT thickness measurement procedures, nondestructive test procedures lacked documentation of Procedure Qualification Records or Tests.
In IA #101 I found this flaw in seven procedures out of 21 examined.
1 Beyond the UT thickness procedures, there were five cases where no evidence existed that NDE procedures had been qualified. As a result, the quality of i
work examined under those procedures remains indeterminate.
These included:
1)
ESC 23', fcr UT Inspection of Groove Welds on pipe rupture restraints prior to 1979; ESD 241, for UT examination of Safety Yoke Rods on Safety l
I s
Valves; ESD 246, for Magnetic Particle testing, with unknown use; ESD 247, for Magnetic Particle examination of welds in the crack repair, program on Unit il Steam Generator Feedwater Nozzles; and ESD 270, for Liquid Penetrant examinations, with unknown use. On January 12, 1984 I completed and delivered to NRC inspectors, a draft report to Commissioner Gilinsky on IA 101.
It is enclosed as Exhibit 3.
48.
The corrective action for procedure ESD 234, consisted of unreliable, "a f ter-the-fa ct" Procedure Qualification Tests, whose use was not controlled and accomplished using qualified procedures.
Ironically, this is the same flaw the late PQT were supposed to correct.
Further, there is no evidence that management reviewed and approved the procedures for the PQT (Icf., at 2-3).
49.
QA Manager Harold Karner improperly prevented any corrective action for the lack of procedure qualification records on ESD 270.
Instead, he:
directed that the Procedure Qualification Pecords for a similar procedure, ESD 210 should be used for ESD 270. That is unacceptable.
If the two pro-cedures have separate numbers, there are at least some dissimilarities. Those,
unique features of ESD 270 inherently will not have a proven demonstration of their ability to identify defects. This QA violation remains ignored.
- 50. No investigation was performed to determine where ESD 270 was used. Instead, the QA manager told me to just write up what I hadlearned already as an audit finding.
l 51. ESD 241 for UT of the safety valve yoke rods involves the most significant violations.
In addition to the lack of a PQR, the hardware was tested from December 17-20, 1973, before the UT. procedure itself was even issued _on December 26,1973, and prior to approval of the UT procedure p
y e -
4 y,s by PG&E on February 12, 1974.
The testing was totally uncontrolled for the yoke rods on these valves, which I believe control the release of radiation l
from the containment (M., 8 at 4).
52.
ESD 241 was deficient because it violated instructions from Dresser, the vendor for bolts and studs. The Dresser instructions required j
the rods to be examined prior to threading. At,Diablo Canyon, the UT's were conducted after the threading.
Further, ESD 241 did not use the Dresser instructions to determine the reference point for sensitivity and the criteria to report questionable items (M., at 4-5).
- 53. The existing documentation for the tests fails to meet the standards both of ESD 241 and the Dresser Instructions. Required information on the testing surface and instrument calibration was not included (M., at 5).
54 Both ESD 241 and the UT inspection records failed to reflect ccmpli...:: ith : M'.: imposed requirement for backup inspection "with the liquid dye penetrant technique to check the yoke rod ends for indications of cracking that might extend into the threaded area of the yoke ends" (M., at 5-6).
- 55. No DR was issued to PG&E on ESD 241, although this corrective action had been agreed to both by Mr. Karner and the NDE supervisor. Mr. Karner improperly reneged on the basis of a memorandum from John Guyler, my successor
's internal auditor. Mr. Guyler dismissed the detailed, documented DR which I a
had proposed with the following assertion: "PPP has accomplished this per instruction from PG&E.
It is evident that a nonconformance does not exist and a DR is not necessary" (M., at 3-4).
Mr. Guyler's response was in'a'dequate.
First, the procedure violated PG&E instructions (see #54, supra). Second,
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22 even PG&E does not have the authority to validly instruct Pullman to violate 10 C.F.R. 50 Appendix B, Criterion IX- "Special Processes." Third, Mr.
Guyler did not document his asserted conclusion.
- 56. Overall, Pullman violated NRC reporting requirements and PG&E contract specifications by only reporting the deficiencies for two out of the seven nondestructive procedures to PG&E on Discrepancy Reports (ld. at 6).
d
- 57. PG&E dispositioned the DR for ESD 246 " accept as is", although there is no information indicating where the nondestructive test was conducted.
Since the identity of the affected hardware could also impact on the evaluation criteria, PG&E's acceptance was premature (M., at 7).
- 58. The reason the location of work tested under ESD 246 could not be identified is that iIr. Karner improperly prevented me from looking. After I learned that ESD 247 was used for welds in the crack repair program on feedwater nozzles in the Unit I Steam Generator, he ordered me not to check where ESD 246 -
had been used (Id at 6).
although the Magnetic Tests in the procedure were referenced to ANSI standards, rather than the relevant ASi1E Code Section I; and although the qualifications of the MT personnel conducting the test cannot be verified from the records available(M.).
- 60. The corrective action for ESD 246 and 247 involved procedure qualifications after-the-fact (I_d,.
at 7). After-the-fact procedure qualifica-tions should not excuse PG&E from accountability under NRC rules. 'kt best, it means that the damage has been minimized. But it also inherently means that b
. _ _. -. _. _ _. - -, - - - - ~ _ _. - - - - -
-23 10 C.F.R. 50, Appendix B, was violated, because special processes were con-ducted under uncontrolled conditions.
61.
Even if it is ecceptable to conduct procedure qualification tests after the fact, the tardy test must be performed under controlled cir-cumstances.
In this case, PQT's were conducted with different equipment than had been used originally (Id.). No documentation was supplied to support the asserted Corrective Action Response that the new equipment made the results more conservative.
62.
QA Manager Karner was responsible for the deliberate failure to provide reasonably prompt corrective action for IA 101. On January 18, 1982, I initially disclosed IA 101; on March 23, 1982, it was finalized after I provided Mr. Karner with additional information which he had requested., On April 6,1982, corrective action for the first finding in the audit' o.n lack of procedure qualification tests was approved.
Before implementation, how-ever, he changed his mind. Although the official time limit for corrective action is ten days, the audit was not closed out for over another year, despite my repeated memoranda and attempts to formally notify Mr. Karner of his obligation to address the issue of unqualified NDE procedures (Id., at 8-11).
63.
Pullman corporate QA Director A. Eck was notified of the failure to take corrective action and improperly refused to help.
Instead, he reprimanded me for bringing the matter to his attention. On June 14, 1982, I notified Mr. Eck, through an Interoffice Correspondence, of the overdue i
corrective action. He did not respond. On July 6,1982, I performed and submitted Unscheduled Internal Audit #31 to Mr. Eck on the lack of corrective action required by ESD 263 within 10 days. This time I received a response.
Both Mr. Eck and Mr. Karner reprimanded me for submitting the audit to Mr.
Eck directly, rather than letting it proceed through the chain of command.
i
This violated ESD 263, they explained. My audit was voided. Both individuals neglected to mention the violation of ESD that I had raised -
the QA violations were not getting fixed (g., at 9-10).
64 In January 1983, I was further punished for Mr. Karner's improprieties.
I was removed as internal auditor because only 5,instead of the required R audits had been closed out. Part of.the problem was due t o circumstances -
beyond my control. Mr. Karner or supervisors were sitting on some of my audits beyond the required deadline. Mr. Karner also was loading me down with ancillary assignments.and unscheduled audits were not counted.
- 65. On January 28, 1983, during the meeting in which Mr. Karner threaten'ed to get rid of me for looking at quality -related issues without bein'g assigned (Supra, Nos. 27-28), I informed Mr. Karner that he had violated 10 C.F.R. 50, Appendix B.
He responded twice that we are not committed to 10 C.F.R. 50, Appendix B, and that it was "O.K." for him to violate the Code of Federal Regulations and related contract specifi-cations.
III.
BREAKDOWN IN OUALITY ASSURANCE FOR HYDROSTATIC TESTS.
Hydrostatic testing at Diablo Canyon from 1975 to 1978 does not have the necessary QA documentation to prove the reliability of the tests.
In hydrostatic tests, water is run through the plant at higher pressures than normal to see if the piping is reljable.
In February.1981 I conducted Internal Audit 86, in wMch I i
1 learned that nearly all hydro ~ static piping tests for a year, during 1980 and 1981 were conducted without required QC documentation.
In April 1982 NRC inspection identified that documentation problems identified l
1 in Internal Audit-86 were not properly -corrected.
I becane convinced that.
serious problems may exist with the hydrostatic tepts. In March 1983 I completed Internal Audit 106, which examined the records for 79 original hydrostatic tests and 118 retests conducted from 1975 onward. I learned that the test documentation did not have evidence of required QC oversight, QA records, consistent procedures, or controlled. test conditio'ns.. In short, there has been a generic breakdown in the QA requirements for hydrostatic tests. They must be redone.
Internal Audit 106 is enclosed as Exhibit 4
]
My specific allegations follow.
66.
The procedures for hydrostatic tests c'onducted before January 27, 1975 are fundamentally inadequate, due to their failure to include documentation requirements, and due to lost pages, the inability to even entirely reconstruct the procedure requirement.
67 Almost all hydrostatic tests and retests from 1975 onward lack required QA documentation. The most significant omission involves QC coverage documented on a piping system closecut - F98 Department Release.
This activity is necessary to assure that departments per for.ning the test comply with procedure checklists. Unfortunately, departments only complied sporacically with the requirement to complete and maintain the form whichdex,nstrates compliance with the test pro-cedure.
In other cases, ther! is not necessary backup documentation to verify the conclusions in the release.
(Exhibit 4, AAR #1).
69.
Fro-December 1977 - April 1978, in 28 cases Pullman test requirement forms did not have information necessary under the 9
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l procedure ESD 229. Fundamental data, such as the type of fluid, pressure and temperature, simply is missing (g., AAR #2).
r 69.
In 28 cases. Pullman's HT procedure data form does not match PG&E requirements. This form is the guide used to conduct the test, so the distinctions translated into different test conditions that dksqualify the results from Pullman's hydrostatic test. To illustrate.
in one test Pullman's procedure only had a pressure of 2485 PSIG, when l
PGLE's acceptable minimum was 2812 PSIG.
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- 70. The absence of backup documentation continued after 1978.
From March 1978 to April 1980, there were 14 hydrostatic retests without a 1
l signed QC field pipe release, dispite the conclusion by Quality Engineering 1
in the test records that QC had verified the results (M. AAR 173).
- 71. The problems with hydrostatic tests offer another example of management harassment of QA personnel.
During the May 1982 NRC inspection, I spoke extensively with. NRC representatives. After the interview Mr. Karner expressed anger at' the length of the meeting. At a later meeting, uuring this general time frame, he threaten to get rid of me.
IV.
BREAKDOWN IN VENDOR QUALITY ASSURANCE.
Although I was not as actively involved with vendor QA as with special process and hydrostatic test procedures, I observed the symptoms of a generic QA breakdown after becoming familiar with two One case involved a vendor examples of QA violations involving vendors.
that calibrates micrometers, a precision measuring device for Pullman tools and the impact of weld repairs, among other functions. Although the vendor had a clean bill of health and was on the Approved Vendors
List (AVL) until my Octo~ber 1981 audit, there was virtually no quality assurance
~
program. Unfortunately, corrective action was solely progpective - to remove the firm from the AVL. The damage that already has been done will remain.
The second case involves 1980 and 1982 orders by PG&E for Pullman inspectors to stop reporting the large number of cracked shops welds found in Boston Bergen and American Bridge.workIhese hardware defects should have been reported on DR's, but instead were ordered to be ignored because they came from a vendor. Specific allegations follow.
- 72. The reliability of Pullman's Approved Vendors List is indeterminate, due to the inclusion of Microsurface Engineering. This firm only had a token quality assurance program, yet had been approved' and passed previous vendor audits. My audit demonstrated that Microsurface did not conduct audits, did not 'have a written procedure for calibration, condue'ef ea ra*ae'1ed inspections, lacked traceability for use on Pullman tools, failed to disclose laboratory standards for calibration, and did not have required documentation for training of laboratory personnel.
The 'viclations were so ingrained and pervasive that it is not credible to conclude they only sprang up since the vendor passed an audit the previous year.
73.
Corrective action for the Miscrosurface QA violation improperly was restricted to the prospective step of removing the firm from the AVL This was inadequate, because the accuracy of measurements made with Microsurface tools is indeterminate. The effects of previous vio-lations will remain undisturbed.
G
74.
In July 1979 Pullmth inspectors began finding signifi-cant quantities of cracks in welds received from two vendors, Boston f
Bergen and American Bridge.
Until 1980 Pullman inspectors svnete 19 Discrepancy Reports on the welds, which displayed a consistent pattern of 23 linear indication. The DR's are enclosed as Exhibits 5-)(,
On April 3, 1980, however, Mr. Marvin Leppke of PG&E issued a memorandum directing Pullman to stop issuing Discrepancy Reports on these " shop" welds. The memorandum is enclosed as Exhibit 75.
In 1982 PG&E repeated the improper restrictions on QA enforcement against the same shop welds. This time PG&E instructed Pullman to delete shop welds from the formal walkdown program that represents a final visual check on quality. Relevant supporting documenta-tion is enclosed as Exhibit Je V.
RECORDS FALSIFICATION Beyond instances of contradictory and impossible information in the records, in some cases I am sufficiently familiar with the cir-cumstances of false records to state that they were intentionally falsified.
Examples involve the qualifications tests for QC inspectors.
As a prospective welding inspector I failed one of~my initial test and was then given a copy of the tett to study to ' assure passing on the second attempt.
Another inspector was certified after taking-a test which upon review months later he.was found to have failed. He was retested at that time and passed with the assistance of coaching. The test was backdated to the original test date to cover work performed during the intermin period. The latter example occured in 1980.
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29 VI. CAUSES OF THE QUALITY ASSURANCE BREAKDOWN.
- 77. The most significant cause for the QA breakdown is the environment of repression and the predictable retaliation against QA personnel who diligently try to identify and correct QA violations. The problem goes well beyond the loss of or'ganizational freedom. Upholding the Atomic Energy Act at Diablo Canyon can represent professional suicide.
Most significant, the sacrifice is for nothing.
The violations remain, uncorrected. My own experience is a case study. Mr. Karner threatened to "get rid of" me on three occassions when I persisted in attempts to obtain corrective action. Mr Karner restricted my freedom as an inspector until I could only look at specific problems assigned by him.
I was reprimanded, verbally and in writing, for communicating with corporate QA management about such a fundamental violation as the failure to take corrective action against unqualified NDE procedures on safety re' lated work. To add insult to injury, in January 1983 I was demoted for not finishing enough assignments. The demotion was due in part to Mr. Karner's refusal to act on. my audits, which made it impossible in some cases for me to' finish my assignments.
- 73. The final act of reprisal against me occurred on January 13, 1984 I was laid off from 'my job as a'pipefitter, the day after making my third disclosure to the Nuclear Regulatory Commission. NRC inspectors already had told me that site management had a copy of my first report on welding procedures, and that Bechtel was studying it. On Friday, 50 pipefitters were laid off, supposedly due to a lack of parking space. The usual praetice for these layoffs is to let workers from the local union stay until last.
In this instance 4 6 out of the 50 employees laid off were " travel cards"
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30 from out.-of-town unions. Although more travelers were available, four employees from the local were swept out with the travelers. One of the four was having conflicts with his supervisor and one had an absenteeism problem.
1 The other two were my partner and myself.
My foreman protested to the super-visor not to lay off my partner and me, and asked for permission to pick someone else. The supervisor referred him to the resident construction 1
manager, who refused the request and told the job steward that we had to be the ones laid off. My foreman and the job steward recounted these events to me on the day of the layoff. That day the job steward also informed me of the perception of site that my layoff was due to " politics" and was decided " higher up".
On January 25,1984, the day after retaliation was widely discussed at Congressional hearings, management called me back to work but not my partner.
The pattern represented by my case illustrates why a significant number QA violations have gone unreported, and why the quality of Diablo Canyon is indeterminate.
Those who persist in reporting the violations are dismissed, or harassed relentlessly until they resign, or give up and stop trying.
- 79. Another cause for the QA. breakdown is subordination of PG&E's and Pullman's QA department to construction. Until recently, PG&E site QC did not review Pullman Discrepancy Reports. PG&E's Resident Mechanical Engineer, a con-struction offical, reviewed and approved corrective action to discrepancies. As of May 1983, Pullman Internal Audits were not submitted to PG&E site QC for review but instead submitted to the Resident Mechanical Engineer.
- 80. Another cause for the QA violations was lack of resources. To illustrate, from August 1980 to September 1982, Mr. Karner was the only permanent employee in the QA/QC site management. He did not have an assistant QA Manager, and the QC Supervisor was a temporary employee.
I
(. repeated occasions, I identified meny of' the issues in this affidavit to a variety of officials within the PG&E supervisory and management staff.
Although some officials listened and expressed agreement and/or sympathy, none of the violations were corrected. I believe that PG&E and Pullman have been gambling that the NRC will not enforce the QA laws, even if they are caught. For the sake of the public's health and safety, I hope that the NRC calls their bluff.
I have read the above 31 page affidavit, and it is true, accurate and complete to the best of my knowledge and be' lief.
! ( t s.
Harold Hudson SUBSCRIBED AND SWORN this '
' day of January,1984, in Cali fo'rnia.
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NOTARY PUBLIC
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My Commission Expires:
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THE M.%IELLOGG COMPANY i
l December 12, 1974 7'
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SUijECT...AXSI-M.3. 2.e.6 Qgalificastpg,,qi..J.nspe,g.t.$.cm.,Jr.a=1,na.t.io,L,, and f:!
Testing Personnel for the Construction Phase of Nuclear Power Plants t
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J. Bowes W. J. Mitchell E. Curcio D. Cockrana S. Handler J. Townsend
!~i W. Wills P. Runy Pedro Elorza R. Walters?
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Earlier this year I sent out a memo to all of you indicating that the l
, Atomic Energy Ccanission had begun to require qualification of j
inspection and testing personnel in addition 'to non-destructive
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examination personnel all in accordance with ANSI-N45.2.6.
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f Tc acconodate this requirement, the Williamsport QA Manual was
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revised on 3/19/74, Pield Installation Manual on 4/1/74 and Dav's y
- Cockrane was notified to change the Paramount Manual accordingly.
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during that same period of time. The M. W. Kellogg Company's standards policies regarding qualification, certification and
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,j training of both non-destructive examination and inspection and j
testing personnel are all outlined in Quality Assurance Procedures
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QAP-1 through QAP-4 all dated M y 1, 1974.
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Apparently my suggestion was not taken too seriously and now we have the
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9 I would strongly reconnend that the respective QA Managers implement j
the Inspection and Testing Personnel Qualification and Training 1
Programs outlined in QAP 3 and 4 immediately.
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om July 30,1982 to H. Karner QA/QC Manager nca H. Hudson, Internal Auditor
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Exit Conference with PG&E Auditors concerning Program Audit #20705, l
susject
" Quality Assurance Program".
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The Exit Conference with PG&E Auditors was he.1d on 7-29-82 and W
audit findings were discussed. It was stated that the scope of the audit was a Supplier and Program audit. The main concern was the implementation' of the administration of Quality Assurance. See the attached list for conference attendees.
The following items were oiscussed:
1.
Previous audit findings were looked at.
Noted that the Internal '
Audit schedule was very effective. Noted that Management audits were okay and that QA interfacr. was okay.
2.
Internal Audits were adequate. Stated that the last two years, a gced mdit program was in effect. Two recomendations:
I A.-
Cases where Inspectors or others did not follow procedures, the Steps to Prevent Recurrence were to reindoctrinate.but there was no documentation to back this up. Recommended E
as use Internal Auditor letters reminding of procedure Pullman provide form to dacument reindoctrination as well requirements. becw u
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Internal i$8Itor qualif1E[1on appears to Te b["d5Sl" Standard'fg*y?*f^*
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but no statement that it is. Recommends Pullman state Internal t
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Auditor it qualified to ANSI Standard.
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3.
Training of NDE Inspectors to SNT-TC-1 A was adequate. But other Inspectors J;hould.be..quajif_f.ed._to_. ANSI N45m 2,.f standards, There is no evidence that they are. This will be an open item to re-R nudit at a later date. /? G.d.
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Discrepancy Reports were okay except Steps to Prev /gu ent Recurrence T4G
- d. f/ /s% needs back up documentation when a person has received reindoctrina-2.4 A re Lw tion.
M A recommendation was made about the use of tape over penciled in circles which PG&E used to mark the recommended disposition they k
wanted implemented on a Discrepancy Report.
The tape was used to preserve the pencil marks from wear.
The auditor called this system i
" hokey".
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m H. Karner QA/QC Manager cart July 30,1982 Exist Conference with PG&E Auditors concerning Prograin Audit #20705,
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" Quality Assurance Program".
not no.
2 5.
Continued 1M sones A
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y erse y s. 7N fff,4ys **>aS "Acco"*** *'o Lyte **ce r* 4 g He recommended N T 9EEn d. s izeNetnoYEe implemented for PG&E to indicate their preference in Discrepancy Report Oispositions.
The auditor also made an observation about the number of open Discrepancy Reports going back to 1978.
Pullman responded. that these open Discrepancy Reports were Unit III work still in progress.
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- 6.
Purchase Orders were being let before the QA/QC Manager sign off. 4%"/ v Need to establish management control. The receiving of purchased
- /* f material was under' control. Need to comply with procedure require-ments. This would remain as an open item to be reaudited at a later date. 'An observation was made about Site Approved Vendor's 4-Aw***
List. There was no approval by PG8E of the list but approval' was A m**
f done on an individual bases by purchase order.
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7.
Design Control was adequately implemented.
WR'g 8 4 rawing_ Con (rol was adequately implemen_ted.
0 9.
Document ControT had an observation made about Isome1,ric packages.
Iso packages were complete but documentation not properly arranged into categories per-QA Instructions. Stated related documents such as Inspection Check Off Lists were the same way. Al l infomation
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was available but located in different places. Concerned about only one person knowing where documents are located.
If he dies, control may be compromised.
Iso packages audited were 1-14-86A,1-14-85A,1-14-78A an'd 1-21-3B.
- 10. Monthly Maintenance Surveillance Reports were audited, and only two reports available for July. Pullman response was reports are not turned in until the end of'the month.
- 11. Control of Measuring and Test Equipment had no problems.
- 12. Control of Inspection and Test Status had an observation concerning piping process sheets. The last two steps on the process sheet were blank due to NDE' findings. Recommended that process steps not used have 'a statement explaining why. 1'#e.sreys rexe cuecy her htf*'#e he to Ptwou s cu~pwro.4 op veureM-w sonorms<. srys w se G Special Processes of NDE, Welding, Welder Qual [fication and Welding [# #f d
13.
Material were adequate.
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