ML20213F973
| ML20213F973 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/05/1982 |
| From: | Foster J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20213F939 | List: |
| References | |
| FOIA-85-213 NUDOCS 8705180063 | |
| Download: ML20213F973 (83) | |
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MDIORANDUM FOR: Region III Files, Midland
- FROM: James E. Foster, Investigator
SUBJECT:
ADDITIONAL (X)NTACT, AI. LEGATIONS RE WELDING AT MIDIAND (REF. POSTER MEMO DF MARCH 3, 1982) 1 i
I recontacted Mr. E. Earl Kent at approximately 8:21 p.m. on March 2,1981, to gather additional information regarding his concerns over'velding at the Midland site, i
Kent again indicated that the socket veld size concern was " generic" to the plant, and covered stainless steel and carbon steel welds, pipe schedules 40, 60 or 80, line diameters from 3/4 inch to 4 inches, and line pressures i from 159 psi to 3,000 pai. After additional questioning, he indicated deficient velds could be found in "Q" piping in the lowest level of the auxiliary building.
Eent then located some no6es on a sample of welds inspected as a part of an informal " audit" (no report was generated) of thirteen socket welds. Of these, he characterized three welds (91, 90 and 89) as unacceptable, with welds Nos 90 and 89 being the worst. These velds were on drawing FSK-M-1RBC-58-2 (1 ster determined to be a service water line).
i Kent discussed various disagr+===nts he had with the provisions of some Bechtel welding specifications, such as the allowable length of time for cold E-7018 (low hydrogen) weld rod to be utilized, the argon purge specification allowing 1-4 cubic feet per minute argon flow (he felt that this 4
I was allowing too much latitude), and not checking the dew point on argon utilized for purges. )
Kent emphasized his expertise in the welding field, indicating that he was i
a former welding instructor, had published several technical articles in welding journals, and was listed in the " welding encyclopedia". He also stressed his continued desire for confidentiality. I again advised that both Bechtel and the licenses would undoubtedly be aware he had contacted h Region III When we looked.into the specific issued he had recently raised onsite.
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p' Conta entity of the call was concluded at approximately 9:06 p.m. idential e The calls.Resident Inspector for llidland, Ron Cook, contacted me following these I provided him with the information I had gained from Kent, and he indicated at the Midlandhe andsite.Kavin k'ard would begin their review the following morning James E. Foster Investigator 4
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Bechtel Power Corporation I inter-office Memorandum Te QC Personnel File Date February 22, 1982 E. Earl Kent #504721 Subject Jcb 7220/ Midland Project From E. Smith Diplayee Counseling Session of Quality Control copies to At Midland, MI Job No. 07220 204 On February 12, 1982 a formal counseling session was held with CQCE E. E. Kent regarding unsatisfactory work performance. During the discussion it was noted that previous informal counseling sessions on the same subject had already been held.
We main topic of discussion during this session was Mr. Kent's failure to achieve certification as a level I COCE. It was noted that Earl has not passed the Certification Examination for POCI PW-1.00.
Further Mr. Kent was advised that I had assured myself that he had received adequate training (more than average for a new hire) to enable him to pass the Certification Exam.
No valid explanation frca Mr. Kent regarding his lack of progress toward achieving certification was provided. It was concluded that Earl must make a more concerted effort toward becczning certified which will hopefully result in success.
In view of Earl's background (education and experience), the fact that he has been certified as a level II COCE on two previous Bechtel jobs and the amount of training he has received at Midland, it is felt that he should have passed the Certification Examination discussed above.
Earl was informed that unless he demonstrates his capability by successfully passing the level I CQCE Certification Exam for PQCI EW-1.00 by February 26, 1982 that administrative action will be taken in accordance with Bechtel's Personnel Policy 322.B(4), which requires termination for lack of necessary skills or abilities.
E. Smith Project Field Quality Control Engineer Q_,_, g ES/jlb ,,
Acknowledged:
g4 ay! es Ae.b I }o Y9"'b Date: hMl
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Acknowledgement of counseling only, does not inply agreement or disagree nt n
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Bechtel Power Corporation Inter office Memorandum To QC File
) Date March 8, 1982
- subject Midland Proj ect , Units 162 From W. J. Creel /
Investigation of Undersize D. Fredianelli Weld Allegations - Interface of with MPQAD and NRC . Quality Control
{ Copies to At Midland, MI l Job No. 7220 4
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During his last two weeks on the Midland Site Earl made allegations i to the PFQCE and the LPMQCE that hundreds / thousands of undersize i
welds had been accepted by QCE's and that certified QCE's were not competent in the measurement of fillet welds. In this period Earl was requested to identify specific welds in question and name QCE's who he felt incompetent. He declined to name any QCE's and only spoke in broad general terms regarding welds with the i exception of one main steam (MS) butt weld of which he had concerns.
Earl was requested to show a QCE from the Welding Technical Group ,
- examples of his concerns. He took and he In (room) at pointed outand other concerns.
one tri random began inspecting i
welds. p He he chose identified an area eight welds as undersize and was subse-
' quently informed that these undersize welds had been previously identified and were documented on a Nonconformance Report (NCR 2920).
Earl wasHeagain cerns. developed requested a list to of provide welds sp(ecific later determined examples to of be hisacon-random selection from the weld record log) and a second trip to the field was made during which Earl, accompanied by i
examined 13 welds, three of which he had stated concerns. Listed i below are welds and concerns identified by Mr. Kent (not including eight welds which were known to be undersize and previously docu- j mented on-NCR 2920.)
Drawing Weld Concerns l M-632 Sheet FW-1 Undersize - Below Flush i FSK-M-1HBC-58-2 FW-89 Undersize FSK-M-1HBC-58-2 FW-90 Undersize FSK-M-1 HEC-58-2 FW-91 Surface Condition 1
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QC File Bechtel Power Corporation !
Mfrch 8, 19E:
Page 2 ;
Mr. M. Curland, MPQAD Site Superintendant was informed of Mr. Kent's allegations on 3/2/82 by Bechtel QC E. Smith and W. Creel. He was further informed that an investigation had been initiated to address these allegations.
On 3/3/82 BQC was informed by MPQAD that the NCR had received allegations regarding undersize welds at the Midland Site.
On 3/3/82 D. Fredianelli LWQCE and Level III, W. Creel LPMQCE and R. VanDenBosch Level II Welding QCE, were on elevation 584' of the aux. b1dg. examining FW-89, 90 and 91- (FSK-M-1HBC-58-2) when MPQAD T. Charette, R. Davis and R. Whitaker and NRC R. Cook and K. Ward arrived on the scene to examine the same welds.
MPQAD and NRC personnel stated allegations received identified these welds as undersize. MPQAD and NRC personnel examined the three subject welds and other welds in the area and found the welds satisfactory.
Later on 3/3/82 MPQAD R. Davis and NRC K. Ward informed BQC that additional information had been received regarding a main steam
- line weld. MPQAD and NRC were informed of BQC's investigation into FW-1 of M-632 Sheet 2.
On the morning of 3/4/82 BQC D. Fredianelli, W. Creel and R. Van-I DenBosch with MPQAD R. Davis and NRC K. Ward went to the-field.
R. Davis and K. Ward examined FW-1 (M-632 Sheet- 2) and found it to be satisfactory.
s The BQC investigation relative to the E. Kent allegations is continuing. Results of this investigation are to be reviewed by BQA, MPQAD and NRC personnel after completion.
D. L. Fredianelli, LWQCE W. J. treel, LPMQCE i
Foster:
This is a recording of a meeting taking place on August 12, 1982, at approximately 10:25 a.m. with Mr. E. Earl Kent, James Foster, Kavin Ward and William Key participating. (Responding) Yes, I don't personally know, but I contacted back in March of 1982.
Kent:
Were you aware that when we first looked at the main steam lines coming out of the containment that he did agree, he did concur that it did need additional welding because it was concave?
Foster:
That is not what he told me during the conversation on March 17.
Kent:
I understand during that conversation he said something to the effect "see for yourself" or "look and see what you think," something of that 4 nature.
Foster:
Yeah, he's uh, my notes indicate that he felt that you had some concern regarding the transition area, however, the weld did to him appear to meet Code requirements, within the acceptable range.
- Kent
Very definitely, he agreed with me initially that it was to concave and that it did need additional reinforcement, it did need additional repair work and that was his statement that it did need it. Secondly, being non-commital, I'certainly did not blame him for not putting himself in jeopardy, but by the same token, I think he should have come forward and said what l he knew about the particular weld joint.
i Foster:
0.k. Earl, let me do a couple of things if we could, just to get a little order here. If you would, tell me about your involvement with Midland starting with the time period your worked there and what your duties were.
Kent:
Yes, I wa,s Seni,or Quality control Engineer at the Midland facility, and basically when 'I first arrived there I noticed a number of things that -
were not in'conformance. For instance, unequal leg fillet welds on sockets being recorded as being full when they were not, when they were j still undersized, and if you like I will draw you some diagrams on the board here to explain my position to show you the conditions they were l..
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4 inspecting to, and show you the reason why they thought that they were in conformance. It may have been that they were never really knowledge-4 able in measuring fillet weld sizes as they should have been. With-i inadequate training, it could have been insufficient directions. I do
- not think that it was totally deliberate, I think there is a wide range j of ignorance there. I wouldn't say incompetence totally, but it borders l at times on incompetence.
Foster:
Let me get back to when you worked at the plant and what your duties were. You say you were Senior Quality Assurance -
Kent:
j' Control Engineer -
(
l Foster:
i 4 Quality. Control Engineer -
I Kent:
That's correct -
Foster:
j i In the field of welding?
l Kent:
Yes, my expertise is in weldiag basically, and metallurgy.
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! Foster:
I i And were you assigned to duties as an inspector? Welding inspector?
i Kent:
Welding engineer, inspecting the work with the other inspectors. I
- . inspected the work, even though my title was Senior Quality Control i Engineer, I did actually observe and watch and followup on the inspectors j doing the actual measuring of the fillet welds and things like that, you know, like in socket welds and things of this nature and this is what I
] was telling you at first, this had gone for several years at least. In
! our conversation here with the, welder who refused to put additional welding on a particular socket weld, because he had been doing that for j years and had been allowed to'do it and yet it was unequal les fillet in i
' a socket, and if you like I will draw a diagram on the board so you will understand, you know.
4 Foster:
I am very interested in having you diagram that for us and explain to us. Were you a Level I, II or III inspector?
2 I
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Kent:
I was a Level I in San Onofre, California Units I, II and III and Level I up in Palisades plant and a -
Foster:
Was this Level I visual?
Kent:
Well, no, not just visual, also dye penetrant in San Onofre as well, but
, what occurred, and if you will check my boss at Palisades, he thought I was extremely qualified and Mr. Jack Huron is his name and you can contact him at any time and see what caliber workman he thinks I am. He knows firsthand my ability as a welder, as a welding instructor, as a welding engineer, as a quality engineer, and Senior Quality Control Engineer. I was even Quality Assurance Engineer before with joy manu-facturing. I'm not new to this field, I have spent all my lifetime, I have been related to metals and welding, I have been a welding author in my own rights since 1961. One engineering data sheet per magazine I had the June issue, you'll see my name there own copyright, worldwide copyright, the June data sheet in 1961 in the Welding Engineer magazine and also September issue 1961, I had two out of twelve engineering data sheets in that year. Again I had two out of twelve engineering data sheets in 1974. I had other than that. And I published two books, welding structural steels and structural steels. These are all my own copyrights, all ey own research, all my own efforts. I'm not a novice '
when it comes welding and I do know a lot about measuring fillet sizes and welds, not only as an author, but as a journeyman and I was absolutely appalled when I saw this in Midland, that they had been able to document that these socket welds were full when they were not full.
Key:
What do you mean by full?
Kent:
I'll draw you a diagram on the board if you like, I'll show you the inscribed isosceles triangle and then the deviation from that. I have fillet weld gauges right here with me, I brought them in this morning and then to show you the variations in the using of the gauges, what different answers you will find, the different answers you will find in correctly or incorrectly use of the gauges. All of you are familiar with the gauges and how to use them, convex, concave and so forth? 0.k.,
if you like I will draw you some diagrams on the board, are you ready for that?
Foster:
Let me do something first here, just for the sake of the record of this meeting and bring whoever might be reviewing it up to speed. On March 2 we had a conference call with you, myself, Bob Warnick, Bill Key, 4
3 1
Duane Danielson, Mr. Bill Paton of our Executive Legal Director's office and Ms. Barbara Stamaris and discussed your concerns relative to welding deficiencies. I recentacted you the evening of March 2,1981 and we went over some of your concerns again. During that conversation you were able to describe to me specific welds that were on Drawing FSK-M-1HVC-528-2 and we also discussed contacting -
Kent:
That is correct -
Foster:
And we discussed a couple of other things. I contacted our Resident Inspector, Mr. Ron Cook at Midland and spoke with Inspector Kavin Ward a couple of times on March 3, 1982, let me see my date here, 81 is a typograph. Mr. Ward and Mr. Cook were able to locate some of welds on that particular drawing, and looked at them as well as doing a selection of socket welds. I was able to get in touch with on
, March 17, 1982 and I also had some additional contacts with Mrs. Stamaris on March 17, 1982. From the understandings that I got back from talking with the various people and from talking with you the same time, it was my understanding that you had taken the test to be certified as a Level I welding inspector at the Midland site. That test had not shown a passing 4 grade.
l Kent:
Because they refused to give it to me, and like a driver's license, if they don't let you have a license you are not going to operate. I do not understand why I did not get a Level I because I had it at San Onofre and I had it at Palisades. I used I, II, and III at San Onofre and also at Palisades, o.k ? And so, I'm not a beginner to this by any means and having seen the questions on the examination, I do not know why they did not pass me because I believe that my grade was at least as good if not better than some of the people that did pass. My honest opinion is that they did not want me to pass, it's my honest opinion that they did not want me at the Midland facility.
Foster:
Did they allow you to take the test a second time?
Kent:
Oh, yes they did because they had to, legally, legally they had to and this is why I don't understand, because if you'll check the, if you have the records, my test paper versus the other test papers of the people that passed I think I've done just as good as some of them that said they passed, if not better.
3 4
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- Foster
1 I Should there, would there, have been some reason not to want you j working as lead inspector there?
! Kent:
i Oh yes, very definitely, because I don't like to rock the_ boat, but by the same token I'm not going to stand still and see things like this occur in a nuclear facility, no way. If it costs me my job, it costs 8
me my livelihood, if it costs me my assets, I'm not going to stand by v
] and see it. ,
t Foster
! I gather, making an assumption here, and let's discuss it for a moment, j that before taking the level I examination you'd already expressed some concerns about the welding.
, Kent:
i +
! Yeah, very definitely, and the first week I was in there, I expressed I
, my opinion in a number of ways on some things that I saw that did not I conform to the ASME Code and violations, out and out violations and I -
i wasn't appreciated there even the first week, in fact, Bill Creel said :
if he had had his way certain people wouldn't be there. - !
Foster: [
Meaning you?
l Kents i i
) Well I don't know, I took that to mean me, but that was his comment. He '
said some people transfer in and he can't help it. I did transfer and 1
they very noncommital when I asked him if he was referring to me. I very ;
definitely felt that he did not want me there.
I Foster:
Because of the concerns that your were expressing?
1 Kents .
l Most likely because he could see that I would not stand still for the 4
lack of qua11ty that was apparent there in the Midland plant. ,
i
. Foster:
t l
What sort of things were you seeing?
j !
i i 5
Kent:
I was seeing a lot of things. A lot more than I had been able to discuss here with you. For instance, some of the welds on some of the hangers were not correct and this is another subject that has never been brought forward, I believe, in my conversations before. I've seen lots and lots and lots of things, but uh first things first and in my mind the high pressure socket welds are very very important, o.k.? And in the ASME Code it recommends 1/16 of an inch gap between the bottom of the socket and the actual pipe coming in to tne socket. Bechtel allows anything as long as it is not withdrawn totally from the socket. To me ASME has never concurred that they would allow that, yet Bechtel has gone out and said that anything, as long as it is not withdrawn from the socket is acceptable. To me it is a gross violation.
Eey:
i Do you know how the Code addresses that?
Kent:
Yes, yes, they have a diagram, they have a diagram in here (indicating Code Binder) showing a 1/16 of an inch clearance at the bottom of the socket.
Key: -
Uh, that's exactly what they have, but they also state that it should be at least 1/2 inch, 1 mean 1/16 inch, it doesn't give an upper limit.
Kent:
Yes, but wait a second, the main reason for that is so they can't bottom out. So they want to withdraw it 1/16 of an inch, o.k.7 Key:
But it says at least a 1/16 of an inch.
! Kent:
Yeah, to keep it from bottoming out, because if it bottoms out and you do run the weld around there, you'll create, could create, not would but could create residual stresses up to a point where you could possibly have rupture. If you had "0" clearance in the machined surface, to machined surface with no room for contraction and expansion, you can crack the weld out. This is the reason for the 1/16 of an inch, that's the reason for the 1/16 of an inch.
E*11 That's the reason that they do state at least 1/16, they have no upper limit over 1/16. So if you went over a sixteenth -
6
A Kent:
But they say approximately, they say approximately 1/16 of an inch. Now ideally that's their target, approximately the target is approximately.
If you have 32nd of an inch you are safe, if you have three 32nd of an inch you are still safe, but you have to have approximately 1/16 of an inch.
Foster:
I believe what Bill is trying to indicate and I dealt whether this section of the Code some years back, is that the Code does not provide a maximum disengagement -
Kent:
But the intent is 1/16 of an inch or thereabouts, little bit less, little bit more but the target, the target is 1/16 of an inch gap, that's their target. They certainly d not have a target of any extraction from the pipe from the fitting, or almost the y extraction of it. According to Bechtel, just anything as long as it's not withdrawn from the pipe.
Key:
Is that the way it was stated in the specifications?
Kent:
Bechtel specs allow anything, as long as it is not withdrawn from the pipe. It can be a 64th of an inch inside if the fitting is acceptable.
To me, it's a gross violation of the ASME intent. What I would like to know is why someone doesn't go back to ASME and ask them their opinion on this. Get a ruling. As a Code case. Now, they do grant Code cases if it is acceptable to them, if they want the burden of saying 1/8 of an inch maximum or 3/16 maximum, 1/4 inch maximum, that's up to them, that's their perogative, they can do that, but I believe that they would be appalled at this comment that anything is allowed as long as it is not withdrawn from the socket. That is my honest belief and I think that if you check with the ASME Code, the people that wrote the Code that they would concur that it's not their intent.
Key:
What specifications of Dechtel's is this where it says anything -
Kent:
Well, it's in one of their letters that is from the San Francisco Home Office, 50 Beale Street, that uh, I have it right here, I have the information right here, o.k.? and I'll read it to you. The date of the remo -
7
Ward:
Being that's a letter, is that information incorporated into the Bechtel specs then? Or is that -
Kent:
This is incoroporated into the Bechtel specs sir, as part of the specs, what you use to inspect to, and this is what they were using to inspect to, so there is probably, not possibly but probably you had tremendous numbers of socket welds out there with with quite a gap. I don't know whether some of the gaps would be 3/8", 1/2", 3/4" or what. O.k. Here you go.
Vard:
At a certain period of time it would be out of the fitting itself.
Kent:
Oh no sir, as long as it's not withdrawn from the fitting. In other words a 64th of an inch, or one thousandth of an inch, it's still not withdrawn from the fitting. Which in my opinion is assinine.
Foster:
Did you see any welds that looked like they might be that far withdrawn from the fitting?
- Kent:
You'd have to have x-ray to really go back through and check the depth of the pipe within the fitting to determine what gap you'd have, whether it's a sixteenth of an inch, quarter of an inch, three-eighths of an inch, one half inch or whatever.
Foster:
Don't they follow the standard marking practices when making a socket weld?
Kent:
This is one thing that 1 did see them do, they did mark some of the socket welds cause they knew that the engagement had to be at least 1/16 of an inch away from the bottom, but they could pull it out and I've seen them do this, J've seen them pull it out because knew that any depth was o.k.
EEI!
l Are you saying that they did not mark it? l 8
I Kent:
I l Pardon?
l Key:
l Are you saying they did not mark it?
l l Kent:
No, I say that I have seen them mark it. After they mark it they know that they have had more than 1/16 of an inch at the bottom and no problem with them pulling it out beyond 1/16 of an inch. Do you understand what j I am saying?
l Key:
Uh-huh Kent:
l I Could I read all of this to you, I don't know if I have time here, but l
1et's see, uh, read this for you -
Foster l If that is your affidavit, I have a copy, unsigned copy.
Kent:
You have the affidavit, unsigned. Did Mr. Crow give you a copy?
Foster:
Uh, I don't know Mr. Crow, we were provided one by the Government Accountability Project, this was an unsigned edition of that we were provided, they may have given us an updated one since...
Kent:
Do you have a copy of this?
Foster:
No I have not seen this, this a letter to you from Mr. David Crow, dated June 28, 1982.
I Kents Yes and you see my marked up copy there in red? ;
9 l l
l l
- Foster:
! Yes, yes, I have not seen...
l Kent:
That's the copy that I gave him.
Foster:
I have not seen a copy of the marked up or revised affidavit.
Kent:
That is correct that is the revised affidavit right there. O.k., here it is on page 3. "If Bechtel had made these changes only to take account of particular needs of Midland that would have been one thing, but in the area of welding where I was qualified to judge the new specifications were inadequate to the needs of a nuclear facility. There is an inter-office memo dated 24 April 1981 which I had in my files. It is between the project QC head, E. Smith and the main office Materials and Quality Services Official, D. Hackney. The subject is socket weld engagement length. Hackney states that as long as the pipe is not withdrawn from the fitting it will be approved. This means that a gap of nearly any length will be tolerated between the end of the pipe and the bottom of ,
the socket. These gaps weaken the joint and make it susceptible to failure, especially during vibrations. The ASME Code has for this
- reason established a much more rigid specification." Now the end of l the quote and back to 1/16 of an inch that they recommend as a target.
I Eey:
They are maintaining the 1/16 -
Kent:
Pardon?
! E*Y!
l j They are maintaining the 1/16 of an inch, is that what you are stating?
Kent:
No, no, I didn't say they maintained the 1/16 of an inch.
E*XS i
( I mean, at least 1/16 of an inch.
l Kents l
! Oh yes, at least 1/16 of an inch withdrawing from the socket, yes.
i 10 1
Key:
But you're saying that they are also withdrawing almost out of the accket?
Kent:
I didn't say they were almost withdrawing it almost out of the socket, I say that it is allowed to withdraw as long as it has some engagement within the socket, and in order that they can almost withdraw it, they weren't concerned about the actual depth. Gap.
Foster: i As long as they had more than 1/16 -
Kent:
Yes, 1/16, whether it's more 3/8 of an inch, or a quarter or anything, you know. This is not the intent of the ASME Code in my opinion. If you would go back to the ASME Code and ask for a Code case on this I'm quite sure that you will find that they will say that is a targit 1/16"
( gap, although a little less or a little more would be acceptable.
Ef23 So you are saying that that is the limit that they expect -
Kent:
I believe that ASME had the intent, by reasoning, of having a gap of 1/16 of an inch and knowing that you cannot get exactly 1/16 of an inch as long am the 1/16 of an inch in gap is not going to bottom out, is not going to contract, they will not have metal to metal and con-traction there and failure due to residual stresses induced in the weld.
, Ward l
Do you have any numbers or anything to point out any of these situations? '
Where they are like this?
l l Kent:
I have seen many things, not only at San Onofre in policies and also at Midland, but Midland is the worst that I have seen yet. Also with
! the drawings for welding. I have seen cases where I passed by a major support on a steam line and looked at the diagonal brace off the concrete wall, off the plate, and it looked like it was inadequate.
I've taken the marked number down and gone and checked the print and l it has b.mn approved and bot;ht by the Bechtel inspector and also con-curred to by the NRC inspector and still was not adequate welding. I showed them the missing welds and they rewelded it.
l l 11 l
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Foster:
k'here was this?
Kent:
This was one of the nuclear facilities not too long ago, not too many months ago, it was at Palisados.
[oster:
Palisades?
Kent:
Palisades. Yes. Now this is just one main example, I've seen numerous areas at San Onofre too, but not as bad as Midland. I've seen places in Palisades where corrosion was very, very evident in the 4" emergency water lines, cause we cut into them, and spliced aad rerouted, etc. and there was massive corrosion in the bottom, especially, and sometimes even the top and sides of some of these steel lines. Some of these pipes, if you took a TH (thickness of material) reading on them you'd probably find the violation of the minimum wall.
E*Xl You mentioned that in your affidavit here - what, what measurement -
how are you measuring this?
Kent:
The thickness of materials, o.k.?
E!!II But how are you measuring this? That's what I'd like to know.
Kent:
You have TM digital readers. Are you familiar with TH digital readers, you put them on and it will read the actual thickness as you go along the pipe?
E2XS Uh huh -
Kent 0 k., it'll actually come out numerical, like .24, .25, .26, .27. You go to major corrosion spots, especially in the bottom of the pipe as I had seen there in Palisades for instance, and measure the bottom of your pipe and we have seen pits, isolated pits that were quite deep -
12
i E2X; Now when you say quite deep, now is this uh, are you saying it's below the minimum wall thickness?
Kent:
a
! believe it to be a violation of minimum wall, that is actually -
l ES2:
u j What you believe and what is actual, that's what I'd like to know. Now is it actually below the wall, or is it -
Kent:
You'd have to take actual readings at a specific spot. We were, we were working in the modification, for instance at, Palisades and we
]
saw this, o.k ? And you'd see isolated pits that were quite deep, in the ws11, on the inside of the wall. We didn't have the time to take
!. TH readings on it. We were under pressure to get the job back on l stream.
I Foster:
1 l Earl, let me back up here for just a moment for a second - are wo 1 talking about carbon steel pipe here?
Kents Yes sir.
Foster:
And are you describing an ultrasonic examination?
j Kents j Well, the TM guages really are UT.
Foster:
Yes, yes, o.k. And they were doing UT examinations for wall thickness i on carbon steel piping at Palisades -
Kentt No, very, very little well, I've seen them use the TM, thickness of material UT equipment, on them, o.k. but very seldom, very, very rare, very rare. And what I'm saying is if you went with TM equipment on the bottoms of all of the carbon pipe in Palisades ! thtnk you d be appalled.
13
foster:
Is this what they were doing? They were examining -
Kent:
No, no. They, only where they had to. Only where they were instructed to, only where they were given isolated case of using any TM equipment, and the same goes for San Onofre, because I've seen massive corrosion at San Onofre also. I worked in Units 1, 2 and 3, and especially in Unit 1. I saw a hydrogen line, for instance, to an emergency trip valve, in San Caofre aubbing against another line and I got a ladder and went up overheail rnd saw these two lines rubbing together in the shadow, I thought wera, due to the vibrations at San Onofre, Unit 1.
And I went up on the ladder with a flashlight and I looked to be sure they were. They were chapping, rubbing together. So I came down off the ladder, I was on my way for another inspection, I wasn't directly concerned with that but I saw it, so I walked, I became concecned about it and I went and got one of the maintenance men and asked him to 30 and climb the ladder and look at the lines chapping one against the otherandhedidandhesaid"MyGod,it'stheemergencyhydrogenline for the trip valve for the generator for Unit 1 in San Onofre! He thanked me for showing him that the wall had been worn quite deeply.
He said that they would get a bracket - he did separate them, physically, with tape and he said they would get a steel bracket and hold the line captive to where it wouldn't happen again whether he did that or not I do not know. But I know many, many, other things. I can take you over Unit 2 in San Onofre and show you that the door built by Chicago Bridge Iron (CB&I) had a gap in it that I could take and put my ring binder back up in the gap where they should have had a plate, a spacer plate, at the top hinge, not the bottom, the top, in tension is more serious at the bottom in compression, on the main door in Unit 2. One of the main doors in the containment, and I tried to get a plate put in and welded around solid and did not accomplish this because they said that this had been accepted from CB&! and if they did any welding on it they might be responsible for it, that CB&I was the one that had originally fabricated it and they gave it to them and that's the way it was. I can give you the names of the people involved there if you like and you can so there and see the door there if you like, and you can almost put your hand back in behind of the plates in the top hinge in the back of the door. You can almost get your four fingers in the gap where the plate belongs. I actually took my ring binder that I had in my notebook, full ring binders spiral binders, andactuallyslippeditupinthere,andIwentandgotmgbossand showed him how this binder went inside there and he said well it shouldn't be like that. It shouldn't have a gap like that."
Foster:
I'd be interested in knowing the people who are involved.
14
l
- Egni Would you liko names 7 Foster:
If possible.
Kont: ,
I'll dig out names if you'd like that, o.k.7 Foster 0.k.
Kent:
Uh, I have another better request than that that is someone go to San Onofre to Unit 2 and look at the actual door, the top hinge, and take photographs of it.
Foster:
That's what I have in mind.
Kants 0.k. good, I'd like to see that.
E*YI This is the personal access hatch into containment?
Kant:
Yes it is, yes it is. I'd like some people to take a flash camera, so in there and measure and show the gap.
I Foster:
What I'd like to get back to, and, I appreciate that information, we'll
- see if we can get some to -
Nant I know a much, much, much more, because ! didn't have time on the phone to sit there for hours and tell you these things.
- fonter
! I'd like to get back to your affidavit here, specifically in the area i where you are talking about this TH readings, uh. which in the copy I have in page 5 and, I got your marked up copy, which I'd like to make a copy of before you leave if that's alright.
15
Kent:
Oh, you are perfectly welcome to make a copy of anything I have, anything I own.
Foster:
What I have here I had uh, I guess made an improper assumption, you mentioned uh, TM readings and you mentioned yourself performing these readings. "When I performed the thorough readings myself using TM readings ! discovered extensive corrosion." This relates to the
- Palisades plant?
Kent:
Yes sir, basically, but we also had TM readings, we had uh, different ways of taking thickness of material readings. You can take thickness of material readings with gauges, you know, with calipers, you can take i them with depth gauges, you can take them with pit gaugen you're familiar with pit gauges, iro you not?
1 Tonter:
I Not personally.
kantt
- 1 Vell, we had pit gauges, uh at Palisades basically, and we uh, uh we i
could determine the depth of the pit with the pit gauges. But the most common for the ultrasonic was at San Onofre, and here again it's only when they saw manufacturer's stainless steel pipe for instance was visually too thin, and they went in and checked it with the ultrasonic equipment down there. And the material they had accepted, j the stainless steel at San Onofre, Unit 2 was then cut out, because it was not thick enough. And yet it got through the manufacturer's QC l people, and it got through receiving at San Onofre and got incorporated and actually was welded in before they (found this).
1 Fostert 0.k., it might be worth while to go through the affidavit briefly, and then I'm interested in seeing your diagrams.
Kent:
Sure, would like to start at the beginning?
Eoster:
Yes, please.
Erni You want me to read it, or are you going to read it?
16
(
I i !
l . ,
l !'
Foste_r i
l Oh no I don't think that's necessary. Basically, let me look through the pages and if a question comes up we'll discuss it. 0.k. we've dis-cussed the inter office memo on page 3, and that relates to Hidland and to Bechtel generically. Mention on page 4 the Hackney memo and then you ;
get into that problem - i kent! I Which was incorporated, which was incorporated in the Buchtel's acceptance standards - '
o ter!
[,o,s Alright. And you go on to mention downgraded specifications, la this referring back to the llackney memo?
E* fill l
Part of it, part of it and part of it is other things that Bechtel '
han uh in their favor. If you'll road Bechtel's specs vs. the AS!!E !
Codo you'll find that they have slanted this in Bechtel's favor. l Tostert i llow so? !
E*!!!8 Well for instance, the enforcement of groove welds, uh, for instance ;
in the 1971 A5!!E Code it calls for certain thicknesses of uh pipe, to have certain reinforcement heights, o.k.7 And commonly you'll find a l certain thickness, we'll say a wall approximately 3/8 or 1/2 inch wall. l or something like that, may very well have an 1/8 of an inch reinforce- !
ment height maximum, as a maximum, in the Code. Road Bechtel's specs and you'll find that the heights of certain groove welds is 1/3 of an i inch maximum. Now there's a lot of difference between 1/8 of an inch and 1/3 of an inch maximum. This is another thing they taught me, t
E2XI One third of an inch 7 i Eil118 l
Yes sir, one third of an inch. Now it could have been a typing error.
It could have been unintentional. But it's in Bechtel's favor. I i
Yeys j That is in the specifications?
17
- . - - . . ._~ . . - _ - . _
i Kent ;
In Bechtel's specs.
1 Egy: ;
Can you tell me what specification number that is in?
Kents
{ Not off hand, I'd have to go back through all my notes and my material l i and research. I don't havo it with me right now, but ! do know I had
- read it and I was appalled when ! saw it and at first ! , pardon? ;
} E*%!
What you are saying in that you get damn near 2/8 of an inch of crown i
.l there?
! Kont l j 1/3 of an inch crown is allowed, right, that is, point .333 of an inch j is allowed instead of .125. pardon?
l Etts l Are you aware that the Code doesn't allow you, for any thickness more i than 5/16. S/32 inches?
E* fill I i The Code allows reinforcement relative to the thickness. The height J of reinforcement relative to thickness of pipe, thickness of wall. 0 k. ,
i now the Code does change and a later Code has changed that table from the 1971 edition to a different table, but, if you look at Bechtel's !
I specific inspection specs, supposedly derived from the ASME Code, for i I the maximum height of reinforcement where it normally should read 1/8 l of an inch it reads 1/3 of an inch as a maxtmum. I was appalled when !
saw some of the reinforcement of soma of the welds.
! Egy:
1 l'd like to know - (interrupted)
I E!!!18 i
- I'd like to draw you a diagram, I'd like to draw you a disgree of one in the doisel generator room that I saw, that you can 30 there and look at it yourself and you'd be appalled, you can take pictures of it.
E*xt What I would like to know is what specification that is in so ! can review that specification.
i 18 l
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Kent:
I I was under the opinion that you would have all of the Bechtel specs here a copy of everything that they were inspecting too and then we J
could just flip it open and I'd go to it and say "this is it."
[opter Earl, did you point this out to anyone there onsite?
Kent:
Well this is, yes, and this, this unfortunate because I got myself in deeper and deeper water doing this.
Foster:
What was their response?
Kent
, Their response is " don't worry about it," say it o.k., it's in the Code.
- It has all been approved and all been signed for and everything else.
(inaudible)
{ rosters i
l Do you recall who you discussed it with?
i
! Kent:
J
- I discussed it with a number of people Bill Creel for another, he was my' boss, and the answers ! get from him are uh " don't worry about it, it s all been approved, there's a signature on it - you can see that. Well sure, I don't care if there is a signature on it or not.
Fontart i None of them said that it was a typographical error or anything like l that?
E*.E18 No, gardt
! But sometimes you see an 8, some typewriters, you know, kinda makes it
! look like a 3, too, i
- Kentt No, no, it's definitely a 3 when it was typed but it was in Bechtel's favor. I was appalled when I saw the reinforcement of some of the welds 19
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i there, and the grinding on them, in fact I'd like draw you a diagram on the board anytime you are ready for one in the deisel generator room and you can take a flash camera up there and take photographs of it with a ruler on the side of it and see.
Foster:
l If we can I'd like to get back to that in just a minute.
l Kent:
I'd like to draw that diagram before I leave the room, o.k.?
Foster:
Sure, and I'd like for you to. Matter of fact I've got the bulletin board and the paper over there which might be handler if possible. Uh, going through the rest of the affidavit if we might, uh, talking about fillet welds not being full across the blade pertains to Midland?
Kem :
This is the, this is the blade up here -
Foster:
Yep, and that's what you are going to show us.
Kent:
That's 45 degrees right here, in fact I'd like to draw it for you right now if you'd like.
Foster:
I'd like to go through the affidavit if it's alright.
Kent:
Sure, sure Foster:
Talk about undersized and improperly done welds - that relates back to the fillet weld gauge.
l Kent:
Yes (pause) yes, very definitely.
Foster:
You mention high pressured piping up to 150 psi -
20 i
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E Kent:
. No, not 150, 1500.
Foster:
1500. They.have welds, are these' referring back to socket weldst Kent:
Some of them are socket welds, that lo carry pressure that high.
Foster:
} 0.k. e've already gone through .the thickness and corrosion. Did you have~a problem with the thickness of materials at the Midland site?
' Kent:
I would bet you 100 to 1 if you went through and inspected every single
, pipe in the Midland facility you will find that the manufacturer did not always give you the minimum wall all the way around the 360 degrees around the pipe for the full length of each pipe. If you took a actual reading, a Thickness of Material reading, ultrasonic reading on the pipes I think you would be appalled at what you will find.
Foster:
}' Can you suggest some areas to us, systems?
Kent:
Random sampling might give you an idea, but-it would only be a rough idea.
Fo.ter:
Did you see any pipes that looked below minimum wall?
Kent:
I saw some that I believed were.
Foster:
Do you recall their location? Even general?
Kent:
After grinding some of them,-I very definitely believeLthey were below minimum' wall, after I got through grinding them, yes.
21 s
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. Foster:
Do you recall the location?
Kent:
Well for example, one in the Emergency Deisel Generator Room.
-Foster:
Uh-huh Kent:
And let me draw that for you right now while I have it on my mind, or do you mind, or uh -
Foster:
Sure, go ahead.
Kent:
0.k. If you will look in Emergency Generator Room, I'll enlarge this, it's not quite this large, but this is what it looks like - this is enlargement, (pause, he is drawing on the board) o.k. If you will take and put a blade, measuring blade across here and bring it down to here and like this and back across here and then put a wire in.
here, a given diameter wire, you see what I'm talking about?- Here's your measuring rule right here and here's your gap for the under-grinding that they should have not done on the welds. Now this was a weld at one time. The weld evidently is one like this in one of the Emergency Diesel Generator rooms. In grinding, they had actually violated the wall thickness from here to here and this transition, is not according to the Code, you follow what I'm saying, the Code demands that certain slope minimum.
Foster:
0.k. Do you have a -
Kent:
This is one of the vertical pipes, this is one of the rings, weld rings-you know, that they had accounted for weld metal and in grinding down the weld they not only had a violation of transition slope which goes like this, according to the ASME Code. But they- also ground down in one of the pipes at the top of one of these welds and you will find it if you search. And if you take a thickness of material reading here ultrasonically I believe that you will find that they violated the minimum law on that.
l 1
22
e Foster:
f Can you give us an idea of the size of the diameter of-the bore?-
Kent:
It's probably is in the area of 4 inches nominal.
Foster:
0.k.
Kent:
I figure it would be Schedule 80 or heavier -
Foster:
r Carbon Steel? -
e Kent:
Yes, carbon steel, but looking on the outside you can't tell what the actual schedule is of course, because all you are looking at is the actual transition, and here again when they were grinding this off this metal ring around here violates on this side all the way around.
Violation at the bottom and violation at the top.
Foster:
Did you point this out to anyone?
Kent:
I Yes, I did.
Foster:
What did they tell you?
Kent:
" Don't be concerned about it." You see lot of things. I, uh, I didn't have the time to take an actual reading with my ruler because I needed different thicknesses of wire to go in here to see what actual-diameter it was. O.k.? I wish I had had the time. I would like to have taken an accurate reading on that cause ycu will find-it in Midland in one of the Emergency Diesel Generator Rooms all along the vertical pipes.
Foster:
Can you give me an idea is it nea- the ceiling, near the floor, or uh -
^
23 i
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+ ~ t,
Kent:
It's about, I'd say on the order of 5 or 6 feet off the deck.
Foster:
Someone else had already looked at this weld and accepted it?
Kent:
Yes, it had already been accepted. And this is appalling to me how any Federal inspector or engineer could accept it first, and second, how any NRC inspector could concur that it was adequate.
Ward:
Well most pipe is oversized. Lot time when you grind like that, it looks worse than it really is, and then when you take a inr reading lot of time you see it still isn't below minimum wall, you know. Because I've -
Kent:
I've seen brand new pipe from the supplier not meet minimum wall and was accepted as minimum wall, like at San Onofre, the stainless I mentioned earlier. One particular case case where they were cutting in to do two modifications and they noticedLthat it appeared to be too thin and they took readings and sure enough, it was too thin, yet it had gotten all the way through the system, and gotten welded into the system.
Ward:
That's very seldon, that I, with my experience, have known pipe to even come right on enough to say about. It's always over.
Foster:
I think I've been aware another of at least one instance. Let me uh, uh go on. This relates back to the thickness of materials, comment which is partially relevant to Palisades, and partially relevant to Midland.
Kent:
Yes, yes, but this was in Midland site, Diesel Generator Room.
Foster:
Understood. You mentioned a problem with allowing electrodes to be taker. out of their hemetrically sealed containers for eight hours.
Kent: ,
Yes.
24
Foster:
. I assume this is like 7018 low hydrogen coated rod.
Kent:
That's correct, E7018. You are well aware, are you not, that the ASME Code has tightened it up to four hours maximum now and only one re-drying cycle? On the 1971 Code, Bechtel can leave it out for eight hours maximum.
Foster:
Do they use weld rod heaters?
Kent:
Yes they do, and sometimes they are not always plugged in, sometimes they are not always hot. I've seen heaters that were perfectly cold.
Foster:
0.k. Typical.
Key:
So, as a QC inspector what did you do?
Kent:
I notified the people that were involved and taking care of this, uh, I notified the welder first, it's his responsibility, the burden is on his shoulders, make sure his heater is not only plugged in,but the temperature is within the range prescribed.'
Key:
What was his actions then?
Kent:
Well, somebody... Well, one in particular, the fellow didn't know it was unplugged. He was working around and it accidently had become disengaged with the socket and it was not hot, it was cold.
Key:
You felt the electrodes and as a QC Engineer you only informed the welder you didn't insist that he take them back...?.
Kent:
No, this went in my report also.
25
Key:
You didn't insist on him taking them back to the issue room?
Kent:
Pardon?
Key:
You did not insist on him returning them to the issue room and being placed back in the oven?
Kent:
I told him that it was a violation, and that the burden was on him to make sure that those rods are hot. Now I can't take a crow-bar and beat him over the head.
Key:
You can make him return them to the weld rod as a QC inspector.
Kent:
e i
I told him there's a violation there. He had the burden of making sure that he did not use these rods in that condition.
Ward:
The purpose of you at Midland really was to be, was to be trained as a Level I, right?
Kent:
And operating as a Level I.
Ward:
Right, but to be trained, not to, if you saw things to go to their, to make out reports, to go to certain people aslas example to see that the welding rod was to be returned. Your purpose.was to be trained as a Level I weld inspector.
Kent:
Yes, and I had already - accomplished this in Units 1, 2 and 3 at San Onofre - .
Ward: I Right -
26 i
i m_._______._______.-._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . - _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ . . _ _ _ _ _ _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ . . m _ ._._.__ __ ___ .______ .___ _ __.. __ .__ _ ___
Kent:
And also at Palisades with no problems (interruption) Pardon -
Ward:
Only Midland now we are talking about.
Kent:
Now I have had worked as a welding journeyman, a welding instructor for years, a welding engineer for years, quality engineer for years, quality control and quality assurance engineer, and senior quality control engineer. I've been an author since 1961 in my own right.
My own research, my own welding data presentation, and you will see in the welding encyclopedia if you look under fillet welds you will see my name there.
Ward:
Just for the records though, we want to get this straight that the purpose for you at Midland was you were to be trained as a Level I.
Kent:
This is what they indicated, but evidently I was rocking the boat too much. And if I may, in the meantime I'll draw several diagrams on here on the fillet welds. As you are well aware, the largest inscribed isosceles triangle is size of fillet welds. The equal leg fillet weld, like this, o.k.? As it should be, I should take this and erase it and show you the blade and and how some of them were accepted. Do you agree that the actual size is the inscribed isosceles triangle as shaded here?
This actual size? The axis from here to here? Pardon?
Kent:
Do you concur that this the actual way to measure? The inscribed triangle as the actual two sides of the fillet weld as allowed in the Code? O.k. What occurred here is that the, as long as the 45, as you see here on the blade, this point or this point touched any part of the weld as shown here or vice versa it was being documented as being full when it was not full.
Key:
What size of fillet are you talking about?
Kent:
For instance, if your fillet had to be 3/8 of an inch and this read 3/8 of an inch from here - As is right here, alright? - let's just draw it back so you mark here and you mark here-just for talking purposes we'll say that this reads 3/8 of an inch, o.k. If this blade hit any part of the weld, they were documenting this as a 3/8 inch weld.
27
Key:
r How much are you allowed by Code for leg, unequal leg?
Kent:
The Code says that the smallest, the Code says the inscribed isosceles triangle which is this one right in here that is shaded like this - this is the actual weld metal the rest of the way here - this is the weld metal here, but the true size of this_right in here is different from the size here.
Key:
So you have unequal legs.
) Kent:
3 You have unequal legs.
a Key:
Then, how much does the Code permit you to be out?
Kent:
As it reads, the Code says the largest inscribed isosceles triangle - it doesn't say you are allowed 1/16 of an inch, or 1/8 of an inch, or any-thing else like that, it says the largest inscribed isosceles triangle.
This is what you have here, the largest inscribed isosceles triangle -
M:
Where can you show me that in the Code?
Kent:
In fillet weld sizes. Take a look at, all right, under fillet welds, the words " inscribed isosceles triangle," and here again the other literature bears this out in measuring fillet welds. For instance, the AWS, structural welding Code D1.1. Ok...(Reading) fillet weld test procedures and so forth...inscised...You have the AWS Structural Welding Code D1.1.? here by any chance, so that I can show you that in' there, measuring fillet welds the inscribed isosceles triangle?
Foster:
I believe we've got a copy, it's up in the library, maybe we can get it in a minute.
Kent:
Would you please? I'll show you in'that and I wanted to dig it out in this but I know where it.i.s.in the AWS D1.1 code but as you appreciate 28 4
this triangle here is 45 degrees here and 45 degrees here and for an unequal leg across here like this, you know, this is excess metal shaded this way, this is the true size metal shaded this way, o.k. and yet when you put the blade on it, for instance if it touched any point, they were calling it that size, and documenting it as being acceptable when it 's really not acceptable. They've been doing this for years.
This is the part right in here where I mentioned that one of the welders, refused, he refused to put the rest of the weld in here as it belongs straight across the blade, across the flat of the blade. If he had put it across the flat of the blade he would have gone on up as shown here-dashed. Then the theoretical throat would have been across here on up to that blade. As it is the theoretical throat is from here to here -
forty-five degrees on the triangle shown as here as the inscribed isosceles triangle. Being this distance here on the throat instead of this distance on out through here down to the root...
Key:
Then, what you are telling me is that you have a undersized weld?
Kent:
Yes, very definately, it was documented. Many, many, many, many times as being full when it's not. In fact one fellow refused , like I said, for two years. He'd been allowed to do this and he refused to put the additional weld on_there as required. John Pinsky was going to accept it because it barely touched the blade on one side. I said,
" hey John, don't accept it yet, let me draw you a diagram, let me show you." I took him aside and drew him a diagram like I'm showing you right here, and then he realized that it was not full, that the dashed line, the weld should have been across and through the dashed line, and flat straight across the blade with no light under it for that size here being touched here and being in touch here. Then he would have had a 45 degree weld in here and his inscribed isosceles triangle would have been this size here. Now you go through the Midland plant and you will probably find thousands of socket welds very similar to this, or the opposite, uneven on that side or on this side within 360 degrees around -
Key:
e Was this on piping and on structural steel?
Kent:
I have seen it both places, yes. But the piping worries me more than the structural steel does, the high pressure piping does. I've been appalled at a lot of things I've seen, not only at Midland but also Palisades and San Onofre.
Key:
I gather that from reading your affidavit here.
29
Foster:
Let me get back to the affidavit again if I can for a minute here, and then I'll see if I can get you our copy of D1.1. On page 6 on past the discussion of the 7018 hydrogen low rod being out, you mentioned x-ray
-inspections of welding performed under the conditions has revealed porosity, did uh, was this your experience at Midland?
Kent:
Yes, they had major rejections at Midland.
Foster:
Based on the x-rays of -
Kent:
Yes, excessive porosity.
Foster:
Can you give me an idea of the system, uh, where these -
Kent:
The emergency water piping for instance, you know the carbon steel, the four-inch diameter lines. A lot of those were cut out again and again because they had excessive porosity, they weren't acceptable.
The basic reason they had excessive porosity was they had too much moisture. The basic source of the moisture was in the coating of the electrodes. The basic reason he had that moisture in there was that he was allowed to use electrodes outside the hermetically sealed con-tainer for eight hours before he actually used it. The AWS structural welding code has tightened that down to four hours of maximum now for structural static buildings, for instance. We are talking about nuclear plants, we are not talking about static structures. For God's sake, it should be more stringent, not more lenient. It's just the opposite of what i- should be. In fact, my personal opinion would be that you would allow two hours maximum, because you can have the absorption of water vapor within two hours, getting up to the point where you will get porosity in your welds. Just read the record of the number of welds.that have been cut out, not just one or two, but one weld after the next. weld, after the next weld, after the next weld later, linear, in a given length of pipe like carbon steel pipe. Like weld 57, weld 58, weld 59, weld 60 and weld 61 and look at the cut in weld 58, and reweld of weld 58, the cut out of weld 59 and sometimes rejection on top of that. I have seen d
as high as four separate welds in one joint before it's acceptable in x-ray.
Key:
All because of porosity? l I
30 l
Kent:
Basically because of porosity, that's correct. Because~ porosity was excessive they had in the joint. It did not pass x-ray basically due to
, porosity. It's the biggest. bug-a-boo. .It's very simple, you eliminate i the moisture in the electrodes, in the' coatings, and keep them' dry, absolutely bone dry and hot and you'll drop your porosity way, way, way, down.
Key:
Now, evidently, what you are telling us is that at Midland the practice is to remove the electrode from the hermetically sealed cans, bypass.
l placing them in an oven and sending them right out to the field or just
! let them lay there and uh, for a period of time -
.I Kent:
Up to eight hours.
Key:
Prior to before they even put them in the oven?
Kent:
Even before they-put them in the cannisters in the quills.
Key:
Now that's a violation of the ASME Code'and, also of AWS because both of them state that when you open the hermetically sealed cans you will take them out and put them in a holding oven for a period of time until such '
.1 time as you are going to issue them at 250 degrees or 300 degrees.
Kent:
) Well, I have seen them use electrodes that were cold -
Key:
Now well, you're telling me, let me, hear me out. You're telling me that the cans are open, the 50 lb cans are open - and then they are issued directly out of those cans without going to the oven. Is that what you are telling me?
Kent:
I say that this is allowed under Bechtel's Codes, under Bechtel's specs. ,
They are allowed to be out in open air for eight hours prior to use, from l the hermetically sealed container. Look at Bechtel's Codes, Bechtel's Inspection. Criteria, their specs, and you will find that you can allow these electrodes to be out for up to eight hours prior to use.
31 i
T r- .- , - -- , , - - - - , , - . ..e, .
i
.. l Foster:
Is this in the specifications that the QC inspectors are using to make their judgements.
Kent:
Yes, very definitely.
Foster:
0.k. That should be very easy to determine.
Kent:
Yes, and this is another thing that appalled me the first week I was in there, why they would allow this, you know, I mean it should be far more stringent, not more lenient, in nuclear applications than in static structures like the AWS D1.1 structural welding code. Now if they tighten.it up for static buildings and static structures, for God's sake why don't they tighten it up even more in nuclear work? It's well established that the primary source of porosity is moisture, and the primary source of the moisture is in the coating in the electrodes.
Now if you had a maximum of one hour in nuclear work, actually using the electrode from the time it was hot, say at 300 to 350 degrees Fahrenheit, it shouldn't have any real porosity due to the moisture because it takes time to absorb it. .From the ambient air, but it's just like if a sponge will soak up water the coating on the electrodes will soak up the ambient humidity. 0.k. on D.1 page 3, it says the effective throat shall be the shortest distance from the root to the face of the diagrammatic weld. 0.k., under fillet welds, it's Paragraph 2.3.2 - the effective area shall be the effective weld length multiplied by the effective throat thickness. Stress and fillet welds should be considered as applied to this effective area for any directional applied load. The effective length of the fillet weld should be the over all length of the full sized fillet including end returns. No re- and this is another thing - you try.and find end returns on a lot of Bechtel's work, I would ask you to try and find the end returns, just try and find them, on your hangers in particular, just search for any end returns and just document the few, if you ever find any.
Ward:
Describe an end return.
Kent:
An end return is normally as it turns around the corner two times the weld size. If you have a weld and you have a junction, let's say throat vs oh say you have something like this you have a square and it's shown to be welded on both sides, o.k.7 This is hollos. Uh, it shows to be welded on both sides your symbol shows this and: this and-for instance S is here, this is for talking purposes o.k.? Normally, 32
it would indicate that you would get a weld like this and like this, o.k., because you don't have access to this unless it's.a large tank.
If you have a large tank, this is the fitting surface here, and con-sequently the other weld would be on the inside if you have access to it, but if you don't have access to it this is the fore side - this is the opposite side and this is the arrow side. The end. return is normally two times the weld size around the corner this way which I will do this to - if this is a quarter inch weld, normally this is a half inch around the corner, this is a half inch around the corner here and normally it turns a half inch around the corner here. I ask anyone to find any of those on any of Bechtel's hangers.
Ward:
Those are really run-off pads?
Kent:
As they turned around the corner, two times the weld size - if this is a quarter inch here and this is a half inch, if S equals 1/4 of it, remove the S and put 1/4, o.k. If this is 1/4 here then around the corner here by Code it would be two times S (END of TAPE).
Apparently Mr. Kent is doing his drawings on the board and this first part of the tape is inaudible.
We'll say X for this distance, for the crater here and the crater here, and the creater here.
Kent:
But it says in the Code here that inner turn shall be shown on the design and detail drawings. You try and find any of them on Bechtel's drawings anywhere at anytime. I challenge anyone to find them, cause I have never seen thec on the drawings, on any of Bechtel's drawing anywhere, at anytime -
Foster:
Does this require D1.1 to be on the drawings?
Kent:
Yes, in the, design drawings and in the detail drawings. And I have never ever seen them on any of the detail drawings for Bechtel.
Foster:
Is that the section -
33 i
w r iw-- vr -
g- -
Kent:
Pardon?
Foster:
Is that the section you were just reading to us?
Kent:
No, I'll, I'll show you the end returns right here right now if you want the additional information on the details of fillet welds here. You look at page 4, it also gives you a diagram of details of fillet welds and uh (utterances to himself) let me get this for you for~the end returns let's pick it out for end returns in uh, o.k., uh - it says here in Paragraph 2.3.2.1 - the effective length of a fillet weld shall be the overall length of the full sized fillet including end returns. You try and find r
end returns on any of Bechtel's designs or detail drawings. I dare anyone to.
Foster:
Does it say that that's supposed to be on the design and -
Kent:
i-Yes sir, right in here, I'll show it to you, I'll give it to you in just a minute. Uh, let me dig it out for you.
Foster:
While you are doing that may I make a copy of your uh -
I Kent:
Surely. I'll have to bc going in just a minute cause uh -
Foster:
Yes, I'm looking at the time.-
Kent:
Let me get this for you here, uh, you might make a copy of any of this that you like in this, but it's in this area right in here. It's in this first part right in here. Uh, this is the uh 77 edition. It reads slightly different in the '71, '71, '73, '74 editions, but the intent is essentially the same. Under fillet welds here, and di, I'll tell you another place you will find it - you'll find it in AISC, American Institute of Steel Construction in the Blue Book, in returns; and then also in uh fillet sizes and being shown on the design and the field drawings as mandatory it says "shall".not "should," it's mandatory.
34 i
Foster:
Well, I think we can look up that detail. Let me run by my. understanding of a couple of things, Earl, and make sure that I've got this correct.
And I've got a couple of dates here which may or may not be correct.
I guess it's my understanding that y.=u started work at the Midland plant in November of '817 Kent:
I think December -
Foster:
December? Alright, and that you were there as, in a training status until approximately February 9, 19827 Kent:
March 1, 1982 was my last day.
Foster:
That's my understanding, that February 9, 1982, you were first given the Level I visual examination.
Kent:
And I really don't know why I did not pass it, because I passed it at San Onofre, Units 1, 2 and 3 and I passed Palisades, and ask my boss at San Onofre, and ask my boss at Palisades what they thought of my caliber of inspection.
Foster:
Understood. And my other understanding was that I guess it was on the 26, February 26th that you were given the visual Level I test the second time.
Kent:
I do not know why I did not pass that, unless they wanted to kick me out of the plant and never give me the actual passing grade on it. Just like a driver's test, if they don't pass you you're not-going to drive. You have to have a license.
Foster:
0.k., I understood you were told on the following day that you were going I to be terminated. On February 267 l
35 1
l
o .
' Kent:
That's about right. Yes.
I Foster:
4
- And you called to the Ann Arbor office at Bechtel subsequent to- that?
Kent:
No, I was told - I didn't call the Ann Arbor Office then. I was told that I was to wait. (pause) and I would talk to the head of QC and QA
'in Ann Arbor - I was being terminated on the 28th. 0.K.? I did not call them before that, but during this process of termination they told
- me - " hey wait a minute, we got a call from Ann Arbor and your process l out is going to be held up," o.k.? Now, I didn't know - I didn't know who called Ann Arbor, I believe one of my bosses, and I do believe they had reason to call them and hold up the termination. But the termination 1
was aborted (avoided?) temporarily.
Foster:
Did someone -
Kent:
Their prerogative.
Foster:
Uh-huh. Did someone from Ann Arbor come and discuss your concern with-you? .
Kent:
I Yes sir. 1 Foster:
Who's this?
Kent:
i The head of QC/QA.
Foster:
i Do you recall his name?
j Kent:
Uh - right now I've got to get downstairs, I'm in a h- , pardon me for
- just a second. I'm running late, if you don't mind.
l 36 i .
Foster:
That will be fine. Would you like me to go over to Build'ing 3 and uh -
Kent:
'I'll tell them I'm in Building'4 and I'll be right back, o.k.?
-Foster:
0.k.
Kent:
(Referring to family members)
I'll tell them to go back to the restaurant'or wherever they were and they said they were going for uh, ice cream.
(Tipe recording stopped)
(Tape recording begin)
Kent:
Would that by any chance be Don Daniels?
Foster:
No, not personally, I don't. This individual that came and talked to
- you -
Kent:
Yes, at the Holidy Inn. They did' abort my termination on February 28 and he told me that uh, someone had called Mr. Don Daniels at the
- Ann Arbor Office and requested him to speak to'me, someone in personnel.
They may have been afraid of what I was going to say or what I had said.
Anyway they did contact him and he did request.that.they hold up the i
termination until he had a chance to talk to me.
Foster:
0.k. And what was the result of that talk with you?
Kent:
The result of that was that he said that - the inspectors were qualified and knew what they were doing, they had passed the - test and consequently they thought the fillet was being sized while.they were (inaudible).
They were capable, they had passed the test, they knew what they were-doing. They had passed Bechtel's requirements, and I drew him the same
- diagram I drew you, right there. 0. k .' ? In his opinion, they should have known better than to have done something like this, but'they probably 37
' weren't doing that, so, I mean, that's his opinion that they probably weren't doing that, well then that's fine. You know, it's his opinion.
He's entitled to his opinion.
Foster:
I gathered from your affidavit that you had occasion to read the inspection report that we generated as a result of locking at your concerns at Midland.
Kent:
Some of them I did, uh, I'm not reading this entirely like you gave this to me this morning. This is something I hadn't seen.
Foster:
Uh, have you read the section that deals with the concerns expressed to us?
Kent:
Basically, yes.
Foster:
Then you are familiar that we looked at sample of socket welds as well as some of the particular ones that you pointed out to us.
I Kent:
Yes, for instance. Ones that are twelve out twelve that were under-sized that and I looked at that day, that we uh, went at random through one area, just at random he said let's go through this room here and look at socket welds on piping and we did and I think there were twelve out of twelve that were undersized in a sequence. None of them were to size. Did tell you this?
Foster:
Yeah, I remember - I'll have to'look at my notes, I remember discussing it with him.
Kent:
Twelve out of twelve failed to come up to size. Twelve out of twelve was the correct number that were similar to the ones we were talking about right here, unequal legs.
Kent:
And says - well, we could spend the rest of our lives here checking these welds and he said a dozen like that found in a row is good enough for him.
38
Foster:
I've got my notes here and my discussion with , this was on March 17, 1982, 9:10 p.m. I asked him about the " informal ~
audits," he says socket welds - eight out of eight. These welds were done years ago and were listed on a generic nonconformance report.
Kent:
But they had been inspected and accepted by QC from Bechtel and also concurred to by the NRC inspector, Resident inspector, as being full sized.
Foster:
The resident inspector concurred?
Kent:
Initially, initially, if this is not true -
Foster:
The resident inspector concurred? The resident -
Kent:
Initially, -
4 Foster:
Let me finish, please. Does the resident inspector concur in weld inspections?
Kent:
Normally. It has been my experience that uh, that uh, you usually have the NRC inspector there, and with his concurrence they finalize the welds.
Foster:
Sir, you are wrong, Kent:
It has been my experience that the NRC inspector has been at the site of a lot of the inspections and when you inspect the welds and you ask the NRC inspector to be there, and you tell him you are inspecting the weld and you inspect the weld, and if he agrees that that weld is acceptable he puts his signature on t'e inspection report as being acceptable. I've seen the same thing at San Onofre, I've seen the same thing at Palisades, I've seen the same thing at Midland.
l 39
J t
Foster:
That the NRC inspector signs a welding record?
Kent:
I His name is there on thi uh - maybe not on all the welding records, but i on a lot of the welding records.
Ward:
You don't mean the authorized Code Inspector?'
, Kent:
The AI.
l Vard and Foster:
The AI-(Asking for clarification)?
- .. Kent
At San Onofre, I've had the occasion .I've had the occasion of uh -
7 Foster and Ward:
l That's not the NRC inspector. ,
4 Kent:
The ANI, Authorized Nuclear Inspector -
Foster:
7 i Is not an NRC employee.
Kent:
l No, I didn't say he was an NRC employee, but he's an agent, is he not?
i Foster: ,
He's not employed by us, he's -
L Kent:
No, but he's an agent for the NRC, is he not?
Foster and Ward:
i" No.
t 40
Vard:
Insurance Company - Hartford.
Kent:
But I thought he acted as an agent for the NRC, as no record, no?
Foster:
He's in no way an agent for us, generally such people work for insurance organizations like Hartford Steam Boiler Insurance Company and they are present, they will review nonconformances dealing with safety-related section three welds, component supports, that sort of thing, there's usually more than one at your typical site, uh he may do a surveillance, or he may ask to have a hold point imposed on different types of welds.
Kent:
Yes - but the ANI, Authorized Nuclear Inspector, it is my understanding that his function was to verify Bechtel's inspections, and so forth and that consequently, he was doing this for, not directly being employed by the NRC, but he was the eyes for the NRC, so to speak.
Foster:
No, No.
Kent:
This was the understanding I was given at San Onofre initially.
Foster:
No, I'm sorry you're...
Key:
That has nothing to do with us.
Kent:
Because I was misinformed at San Onofre then.
Foster:
My notes with indicate that he says that uh, " Earl knew of this generic nonconformance on the undersize socket welds." and he gave you the number of the nonconformance. Uh, we also discussed the uh steam line and the inservice inspection weld preparation...
41
,-we
~
- Kent:
That's'another thing - on the steamline - if you wil1~get uh a 11e detector test and I'm quite sure that would take one, that took one, he will tell you that uh, he told me that not only initially when we first saw it: it needed additional welding because it was too concave, but later in a, private telephone conversation with him he said there was a definite violation of the Code, the ASME Code, in transition, that the slope was not adequate. But...
Foster:
- Was additional work done on the welds?
Kent:
No sir.
Foster:
Our inspector, Mr. Ward here, has looked at that weld.
4 Kent:
) What about the ultrasonic evaluation on the transition on the inside 1
of it, from one thickness to the other thickness. The . s lope .
- Ward
1 What about it? (Laughter)
. Kent:
Well, this is what tells me that, confidentially in a private tele-phone conversation, that there is a violation in a transition of the ASME Code. That it still needs repairing. That it still needs repairing.
Key:
i
! What does your drawing call for? Did you look at the drawing?
Kent:
l The inspection calls for transition of three to one. One of rise to I three of run, in a slope.
Ky:
But was -it on the drawing and was it -
Kent:
l It's in the specs. The specs show a transition from one thickness to I another thickness. The transition is one of rise to three of run.
l 42 '
Ward:
This weld wasn't the same thickness on both sides?
Kent:
No sir, no sir, not from what told me in a private telephone conversation, definitely not.
Key:
You read many of Bechtel's specifications, I assume.
Kent:
Pardon?
Key:
You read over many of Bechtel's specifications, I assume, and you are aware, I assume also, that specifications do take precedence over the Code in some cases.
Kent:
If you'll check the number of times that they take precedence over, you'll see it slanted in Bechtel's favor, basically.
Key: ,
That's why they take precedence and Codes, because the Code is a minimum requirement, not the maximum, not the ultimate, the minimum.
Kent:
No, but BechtII, Bechtal is more lenient in lot of areas, like I said the depth in the socket welds. And the amount of reinforcement on the grove welds.
Foster:
Let me read you my notes -
Kent:
And I know -
Foster:
Let me read you my notes when I talked with on March 17, we discussed the main steam line and I'm using my notes here to add to my recollection. He said " Earl had a concern regarding the ISI (Inservice 43 1
Inspection) weld preparation, that there was a transition area. '
said the area did meet Code and he had no concern that the transition was well within the acceptable range for the transitdon."
Uh, this is what he told me in conversation.
Kent:
0.K. Will you ask him to take a deposition under oath that he had a private conversation with me at my apartment and that he told me in that private conversation that there was a violation yet in the transition
- with that particular steamline?
, Foster:
I will at least discuss with him, I will consider taking a statement under oath.
1 Kent:
has always been my friend and I hate to do this to him, but uh it's not only his life and lives of other people that are involved. I mean this is a serious offense as far as I am concerned of having a violation hidden and remain hidden.
Foster:
' Regardless of what he told you in a private conversation, Mr. Ward here looked at the weld and it was his feeling that the weld was acceptable.
It's so documented in our report.
Kent:
i It may documented in the report, but if you take ultrasonic equipment and go in there and check it on the transition, and so forth, you'll probably find that was correct and it still was a violation in the transition.
Ward:
i What number are we talking about? The number of the weld?
Kent:
It's not before me, I don't have it before me.
Ward:
Let's make sure we are all talking about the same weld.
Kent:
Right off the mainsteam line, coming out of containment. Very, very, very important weld.
44
h Foster:
Let me understand something, and I hear what you're saying. You were doing a visual inspection, but it would require ultrasonic examination to determine this?
Kent:
It would require complete equipment to really determine the inside condition of the pipe, not just visually on the outside. Look at the outside of a cake. You see it shining, o.k., but you can't tell the inside just by looking at the surface of a shining cake. You can't.tell the ingredients, you can't tell the depth, you can't tell whether it's hollow, you can't tell whether it's solid or anything else. You just see a shiny surface. Similar in steels, you look at a shining surface on the outside, it doesn't tell you the composition of the steels, it doesn't tell you the depth of the steel, it doesn't tell you the depth of the steel, it doesn't tell you it's hollow or anything else. Just looking at it visually.
Foster:
1 Has this weld got an inservice inspection weld preparation? Has it been blended?
Kent:
, It's supposed to have been blended, but the first time I saw it I was' concerned enough to go to Dutch and tell him that I was concerned about one of the main steamline welds there and he came out and looked at it 4 and said "yes, Earl, very definitely that weld needs to be repaired, even ,
though it has been accepted by the ANI, has been accepted by Bechtel, it still needs re-work and it still has to be rewelded."
Foster:
1 1 Do you know if the baseline ultrasonic examination has been performed on that weld?
Kent:
) I did not have time to go through the documentation on that particular
Foster:
You know why they do the inservice inspection blending and that there l 1s a baseline UT -
Kent:
Oh yes, yes, there's supposed to be.
l 45
.- - . - . . ~ - - . - .. - -~ .- -- . -.-- ..
Foster:
0.k.
Kent:
s But I was told that originally for years some of the QC people documented things as being acceptable and didn't even look at them. Quote, unquote.
-In the field, They're setting at the desks they documented that they were acceptable without even actually looking at the welds. Quote, unquote.
Foster:
0.k. Aside from that, and I take that for what we can make of it, a weld with an ISI prep is intended to have the baseline UT done, so the test i that you are suggesting, either has been or will be performed.
, Kent:
i Or should be done correctly. You can go on with ultrasonic or you can I go x-raying it, you can go in a combination, because the combination is best. Cause UT will not show you everything that x-ray will and vice versa. You can have water clear films and x-ray will have major fine j porosity.
! Foster:
J I am assuming this is a Section 3 weld which is radiographed.
$ Kent:
i j Yes.
Foster:
l Then it will have both the tests that you've suggested?
i
! Kent:
Ideally, it should have both. Very often they only have x-ray. ,
j Foster:
i~ You just said it had an ISI weld prep, so they will do - !
l Kent: l As far as I know, I was told they had an ISI weld prep. I was told this.
j I didn't have time to read the documentation or search the documentation or research it or get the documentation; cause I'd seen errors in documen-
- tation. I'd seen things that were actual mistakes in the documentation.
The real proof would be to go out and run an ultrasonic and x-ray combination, 360 degrees around it and check every single point on not 4
46 7
only that weld, but the other welds that are in the vicinity of it and the other extremely important welds. I believe in most important things first, and second most important things second, and third most important things third. In that order, right on down.
Foster:
It sounds very logical, I'd agree with that.
k'a rd :
Do you know what is the surface of a weld should look like when its repaired for inservice inspection or preservice?
Kent:
Yeah. Sure. All my life I've been related to welding and metallurgy and quality. As a journeyman too, I mean not just in theory, I've been on both sides of the fence.
Foster:
Earl, let me show you a couple of weld records and see if this rings a bell with you, and see if you can tell us anything about these welds.
Those are copies from the site of welds that you mentioned to me in our discussions about problems.
Kent:
Uncontrolled copies. Hummm -
Foster:
These should be welds on Drawing FSK-M-1HPC-58-2, I think.
Kent:
58-2, yes that's right - FSK-M-11-1BC-58-2. That's right.
Foster:
That's the Drawing that you and I discussed on March 2, 1982.
Kent:
Uh huh and it's signed here by Paul Schultz who didn't understand the fillet size right here for one individual, besides John Kunsky (phonetic).
Paul Schultz was absolutely amazed when I drew the diagram for him. I showed him the same diagram. I see his initials here - Paul Schultz.
Foster:
1 0.k. These were, I believe, the three welds, 91, 90 and 89 that you described to me on that date as being the worst of several of thirteen, apparently that had been - ;
I 47
)
i
Kent:
Thirteea? Thirteen?
Foster:
Huh - that's according to my notes.
Kent:
I don't actually recall that these were the exact numbers but they may have been. The pipe diameter seems to be the two inch size, it's about two inches, in the nominal diameter.
Foster:
0.k.
Kent:
Incidentally, did agree on the welds in question, whether these were the welds or not, as he climbed up there with me and shone the light around and he said yes, very definitely they're unequal leg welds and very definitely they need rewelding. You can take a deposition to that ef fect and uh see, if he wasn't with me when we shone the light around them he took a look at them and said that they needed rewelding.
Foster:
0 k. These welds were among the samples that we looked at, and we particularly looked at them because you ennumerated them to us.
Kent:
Let me ask you a question. Are you sure they weren't rewelded?
Foster:
In what period?
Kent:
When I first objected to them.
Foster:
When did you first object to them?
Kent:
When Dutch and I were up there with the light. Because they were very definitely unequal legs, l
48
4 Foster:
When was that? The records -
Kent:
- Probably the last of January or early February or somewhere in there.
Somewhere in February, I think.
Foster:
The records indicate no rewelding work.
Kent:
Is it possible they had rewelding when uh they don't have records? I know for a fact, for a fact, that this has occurred, but they have had rewelding without the knowledge of the ANI, and I'll give you an example.
Foster:
I'd be interested in an example.
Kent:
J 0.k. At San Onofre, ANI had passed a weld that appeared to_be alright, o.k.? And on piping, and he looked at it briefly, we pressure tested it and it leaked, had repairs, had bubbles from water tests; and then the then the-visual, I can see where he might have overlooked it, o.k.? But the second time he looked at it, ANI: looked at it, on this piping weld he looked at it without turning the pipe over. After he was through with it I turned the pipe over and there was a pin hole that was as'large of at least the end of this ballpoint here and I would guess here, down 3/16 of an inch deep - a visual pin hole,'right down the middle of the weld.
Foster:
What kind of weld is this where you turn the pipe over?
Kent:
You look 360 degrees around the pipe, if you have a joint. This is a spool, o.k.?
Foster:
Yes.
Kent:
0.k. Now a good inspector will look 360 degrees all around, he won't
- just-leave it laying on the table and look at the visual sides where you can see, he will look underneath the weld joint, as well as on the top 49
f and around it. He will actually lift, regardless of what it takes, he will actually lift the-spool, even if it takes a crane, lift the spool and look underneath the welds and check all of the weld 360 degrees around.
Foster:
0.k. .So the ANI missed a pin hole on one section.
Kent:
Yeah, a major pin hole. Yes.
- Foster:
0.k.
Kent:
And that that's just one example *I happened to see, o.k.?
Foster:
Was there any rework done without any welding records? ~
- Kent:
Pardon?
Foster:
How does that relate to rework being done without weld records?
Kent:
Alright, alright, I was told, I was told that this was quite common in the Zimmer Nuclear Plant. I was told that there had been cases in the Zimmer plant where very definitely the ANI would be going through and would object to something and while he was-in another area in the plant a welder would jump on it and weld it and when he came back without 'l official o.k. or anything like that, the weld was different because it l
had been rewelded while he was at another area-in the same plant. Less than two hours later.
Foster: I l
Who told you this? !
Kent:
For example, one-of the inspectors at the, one of the people at the Midland plant told me this - they had worked in the Zimmer plant.
50 .
1 1
Foster:
0.k. Who told you this?
Kent:
One of the inspectors, I don't remember his name. I remember the combination because I was surprised, I had heard this before about the Zimmer plant being low quality in nuclear work, and I said well that doesn't suprise me because I've heard things like that before.
- Foster:
0.k. Any evidence of that occurring at Midland?
Kent:
1 I don't know specific examples where it occurred at Midland, I do not know that. But I would request that you get a deposition of every welder that is currently working at Midland and everyone that has worked there and_see if they do not know of something of this nature. But I think you will find things that you will want to find. If you ask a welder if he's ever done anything wrong in welding or in violation of Bechtel's Code and l the ANI work that is required for the ANI for inspection and the ASME Code, I think it will be a fine eye-opener.
Key:
Are you aware of the duties and responsibilities of the ANI sir?
Kent:
The authorized nuclear inspector goes and checks on the fitup, on the cleaniness and on the weld after its completion, to his satisfaction.
Key:
4 Of every weld?
1 Kent:
No, what he is called to. What he is called to. now he puts a hold point
, on the weld and'says this is a hold point. I want to inspect it after it is welded. That's his prerogative, o.k.?
~
When he puts a hold point on it
' he goes that weld and says,'and he can say, "well I don't have time _for that," you know go ahead and, and he doesn't have to be there and you can go ahead and pass his hold point. But if he puts a hold point it and says
, "I want to see this weld when it's completed," that weld is not accepted until he comes there and basically sees it. It's his' prerogative to say "I want to to see the fitup, I want to see cleanliness, I want to see finished condition and so forth. It's up to him, it's_ impossible-for him~
to be every place every single weld is, watching every single bead that is run, it's absolutely impossible.
1 51
. Key:
- You are saying that he will...
Kent:
Pardon?
Key:
You are saying that he will -
! Kent:
He will select.
Key:
You are saying that he will identify just a certain portion of the weld he wants to see, or the whole thing?
4 Kent:
It's his prerogative to see everything he wants to see. It's his per-rogative to stand there and watch the guy weld it if he wants. It's his prerogative to spend a whole day with one welder if he wants.
Key:
Have you known many places where this has happened?'
Kent:
Not spend the whole day with one weld, no.
Key:
One day with one complete weld, from fitup, right on through the complete
, weld?
Kent:
Where the ANI has been there, watched every single part of the welding?
I've never - huh, pardon -
Key:
We're talking complete weld.
Kent:
I've never seen an ANI stand there from the very beginning of the pre-paration to the actual end for hours on weld, Never. The authorized nuclear' inspector is usually busy other places - he's being called, he's 52
being paged, he's being requested to go to the other welds and observe fitup, cleanliness etc, and things of this nature. He can't be.in two places at the same time. That's understandable.
' Foster:
I've been going through my notes here, Earl, to refresh my memory here siace I've been rather busy since March, and I note that in my talks with Mr' Cook and Kavin Ward who is here, on March 3. Mr. Cook advised ~
me that'steamline pipe had be ultrasonically tested and approved.
Kent:
When was it UT?
Foster:
I do not have that information.
. Kent:
What date? Years ago?
Foster:
I do not have that information here.
Kent:
I agree that you will probably find this years ago when things were far more' relaxed and they are starting to tighten up a-little bit. But when welding inspectors sit at their desks and approve welds that have been done without visually looking at them this is absolutely beyond my comprehension.
Ward:
I What welds are we talking about?
Kent:
They told me at Midland that, told me for instance, I'm not quite sure, he was the one that told me that years ago.some of the welding in-spectors sat at their desks and approved welds that had never been looked at.
1 Ward:
What welds?
Kent: '
Numerous welds, different welds, socket welds or whatever. I was told that some of the original inspectors at Midland, eight, ten years.ago, ).
53
'l
were too lazy to go out in the field and actually look at the welds, that they just sat their desks and approved them for years.
Ward:
And who said this?
Kent:
I believe it to be (End of tape side, turning tape over) And a reaudit of a lot of fitup welds that did not pass.
Key:
Would you say that was eight to ten years ago?
Kent:
Pardon?
Key:
Would you say that that was eight to ten years ago?
Kent:
Aw for years, it could have went on for years but it stayed in the back in the earlier years of the plant basically. This has been going on here un-equal legs here, even this year, 1982. They were documenting this as being full sized, touching one point on the blade, instead of straight flat across the blade as shown here, even this year 1982. Pardon?
Key:
Do you know of any welds, any place, where that is going to happen and is being, touch, in the as-welded condition, all the way acroas? Whether you are going to have a concave or convex surface?
- Kent:
The burden is on the welder to make sure that the weld is at least full for the given size, whether it' s slightly over-welded or not, if he has to slightly over-weld it at some point at 3o0 degrees, that is one of the things that is a fact of_ life, that he has to do. If he has to put another bead on it and put another layer on it, what he has to do, he has to pull it out full, it cannot be less, it can be more. I've seen a lot of them that were a lot less.
Ky:
Than what was called for in -
54
Kent:
Yes, very definitely and being documented as being the size when they were not the size.
Foster:
You were talking about an inspector by the name of Morris - ,
i Kent:
Morris?
d Foster:
Yes.
Kent:
What about him?. I wasn't discussing him. John Kuntsky (Phoentic),
John Kuntsky was the fellow that I first showed it to and John Schultz.
was the second one I showed it to. And both of them were appalled when I drew the diagram, they had been doing it wrong for years. And admitted they were both doing it wrong for years. I do not know how many hundreds if not thousands of welds that were bought that way that weren't of size.
I have no idea. I was absolutely amazed that they couldn't read the fillet guages correctly though. That's their function.
Foster:
Now, I was going over my notes here and . informed me of as I recall that they were also aware that they had had problems with a specific inspector, that his welds had been reinspected, which was all documented.
Kent:
The specific welder.
Foster:
No, a specific inspector, by the name of Morris.
- Kent
Morris? I'm not involved in his work at all.
Foster:
0.k., I didn't say you were.
Kent:
I thought maybe you were of the mind that I would be.
55
,n - , . , - .- ,,,s. , - - - - -
-.- - . - .-~. .. . . - .- . - .
-l I
i Foster:
In looking over'my notes and talking with on the 17th,
- and among other things I asked him if he-had any problems with. generic j
- things. He indicated to me he's in a technical review group and he felt that any problems were identified and corrected. He stated he had no Leoncerns_tv report. Said he had been onsite for three years and had
-previously worked with.you at San Onofre.
Kent:
1 _Yes,_he.did. I consider him to be a very good friend of mine and at San Onofre we worked very well together. -_I tell you something else, at San Onofre that is well aware of.is the two fillet welds, and I don't know if you know about the 90 some page report that uh Bechtel had on this subject, but when you have a plate, and you have a tube, I'll just break l this and this being the inside wall of the square tube or the rectangular
, tube, etc.'and it calls for fillet welds, uh, you can check this out -
Bechtel has the report in excess of ninety pages relative to the people, '
etc. relative to the welds that are something like this, but some of them-are not of this configuration but-like I'll show you'here - something like-this (he's illustrating on the chalkboard) the' square and rectangular tube especially to hangers, beams, girders,'etc., the steel girders - what is on the outside you see a weld from here.to here, but the depth can be.
radically different and I have seen sections cut with these quite shallow.
i Bechtel found their own tables-on those welds were ambigious the way the i _ tables could be interpreted numerous other ways. So they.added additional
- tables. But some of these are major hangers not just in San Onofre,-but i' also in Palisades and also in Midland. Hangers for your electrical ducts and electrical cables, some of these cables were like this. Sometimes you have side by side, these large cables, sometimes you have very, very. heavy "
weights cxt this, from way on up you1have different levels of trays hanging off of some of these welds. Your stylized stress flow lines go from the tube up through the weld and to the girder or whatever it is on top 4
j holding it in place and you can have. concentrated stresses at those points in excess of the theoretical.
Key:
, A while ago you were talking about the transition from where~you drew a _
little pipe up there, is that what you were talking about? And you were
! saying looking on the outside of it and you can't see on the-inside of it - and that you had to use radiography and ultrasound and all that -
~
- and is that what you are giving us a definite uh'-
Kent:
i You can use UT, you can use ultrasonic equipment. Here, for instance, you can use x-rays, you can use combination x-ray and UT, o.k.? .If you use i your probe,_the UT probe here you get the. thickness through this way
- (demonstrating on the chalkboard) o.k.? You use the probe here, you can j
get the thickness through this way. If you use 'a 45 angle probe, you can
} get it different ways 45 degree that comes off like the angle probe.this.
56 L
way, so your crystal is coming in at 45 degrees, etc. You don't have to have a straight 90 degree normal line probe, you can hava a 45 degree probe.
Key:
- Then what you are telling me if I put a transducer on that slope I'm going to go across the uh -
Ward:
To the other side of the pipe?
Kent:
No, no - not the other side of the pipe, say this is the wall, say this is your wall thickness, say this is the wall (diagramming). this is the '
inside of the pipe, like this, o.k.? Say that you had a weld like this,-
o.k. and your weld was like this right here, o.k.? You can determine what this thickness is going to be through here, you can determine what it is going to be here, you can come back over here and you can determine this in through here, you can tell what the transition is going to be.
Foster:
Among other things from what I'm inferring, from what you've told me, is aware of serious problems at Midland.
Kent:
(Interrupting) Very Definately.
Foster:
And has not done anything about them.
Kent:
Well, I don't know what he's - I don't, I don't - with no proof that.he hasn't done anything, because maybe he has, I don't know about it. Maybe he did tell someone, maybe he did tell his superiors, I don't know. That's between him and his superiors. He's definitely aware, he's definately aware of a lot of serious problems at Midland.
Foster:
I would have to assume that he lied to me since I was discussing your l concerns with him.
Kent-If you tell someone to "look for yourself" or "what do you think," it's not really a lie. In a roundabout way it might be asking them to commit themselves to their opinion. But if he had said "No, I know that nothing is wrong with this weld," that would be different.
57
1 i
i Foster: 1 My notes indicate he told me that he thought that the transition area was acceptable and within the acceptable range. If my memory serves me right, and perhaps Kavin can help here that -
Kent:
This is all by telephone, this all by private telephone conversation in my apartment with to his home that he said there is definitely a transition violation yet and that particular steamline weld that I dis-cussed with him was concave. Even in Bechtel's specs, and read Bechtel's specs, none of the groove welds can be concave. They all have to be convex. Very definitely, this one was concave in quite an area.
Foster:
This is what he told you on the phone.
Kent:
Yes. There's still transition area, still transition violation to the ASME Code, thickness, you know, taper, taper violation , relative to the Code.
Foster:
k' hat does that - I'm not familiar with that section.
Kent:
Here, I'll draw that transition, the transition is, one of rise to three of run. If you have say just (for talking purpose) one inch of rise, you have three inches of run in transition You can't have a steeper transition like this. 0.K. You can't have two to one or two to three.
This over here can't be two to three or anything like that. One vertical to three horizontal is the maximum for ASME.
Foster:
You don't feel the transition met this?
Kent:
Pardon?
Foster:
You do not feel this transition met this?
Kent:
I do not feel this?
58
l
, l Foster:
That's a question.
K*Z:
That the transition - you feel that the transition was not three to one.
Kent:
Oh yes, yes, very definitely, from what told me, that the transition internally, some, at some point he knew...
K1U Internally?
Kent:
Pardon?
1(ey :
Internally?
Kent:
In my conversation with him privately, at my home, I was under the impression that it was internal, but the way he stated it was that, yes it still is a violation of the ASME code in transition, in slope, and I believe it to be internally.
Ky:
Seems to be strange because normally when a pipe is fitup sir, the insides is brought right together so that you can still see on the side and you have another side here and we'll put a little transition on this one - (Diagramming)
Kent:
That is correct, that weld has to slope one of rise to three of run.
Key:
That's on the outside, not on the inside.
Kent:
Yes, o.k.
K*Z:
That's why you want to keep this, this way and not on the inside, like such. (Key is diagramming on the chalkboard) 59
Kent:
Sometimes you have both.
Key:
Very rarely, (inaudible)
Kent:
Sometimes you have both.
Key:
You won't have on many of your nucleer plants because of the fact that.
if you have something that comes in here like so and goes up like this too much and you have water coming in there -
Kent:
Uh huh, sure (Kent is speaking over Key, making it impossible to understand Key) turbulence and lamilar flow...
Bey:
Inaudible.
Kent:
I'm aware of that and all.
Key:
And a lot of cavitation and everything else that's going to come in there -
Kent:
That's right, that's right, but I have seen pipe that wasn't perfectly concentric on both sides.
Key:
I have seen that too, but that's why this is usually machined on the inside or around (Kent interruption) on both the pipes.
Kent:
I've seen them grind it very often.
Key:
I've done that too.
60
Foster:
So this, this weld was made years ago from what you told me and you looked at it visually.
Kent:
From the outside.
Foster:
From the outside.
Kent:
And this is what I saw from the outside - was a strip about this long curved. It was concave, it had a transition from one thickness to another thickness on the outside, I don't know what the inside looked like, but the containment wall looked like this. As it came through the containment wall, and this is your pipe through here, the concavity was very, very apparent for about this distance on an arc, and I showed to this concavity here and he agreed that very definitely it needed to be reworked, rewelding, it needed to be filled in with weld metal. Now that was the original conversation that I had with when we first looked at it.
Ward:
Was this adjacent to the weld because like, like large diameter pipe, uh, you know how when they weld all the way in the pipe tends to suck in a little bit?
Kent:
It will on very thin wall pipe, suck in, and this is very thick wall.
Key:
How thick?
Kent:
i Quite thick. In excess of one inch.
Key:
I have one more question I would like to ask you sir. At San Onofre, and Palisades you were QC engineer, QC inspector, under what standards were you qualified to then?
Kent:
Level I.
61 ;
l
Key:
Under what standards?
Kent:
Bechtel's standards.
Foster: .
You were called Level I at Midland?
Kent:
No, no - not Midland - he said Palisades. San Onofre and Palisades. I was Level I at Units 1, 2 and 3 at San Onofre and Level I at Palisades.
Ask any of my bosses at San Onofre, ask any of my bosses, I don't care who worked with me, at Palisades, of my caliber-and my inspection work, and get their opinion, a full scope of the people I worked with, both places. See what they think of my ability.
Key:
You all stated that you were PT inspector, under what Standard or what Code were you qualified then?
Kent:
Well, you take the Bechtel test, that is relative to the ASME code.
Relative to the Society of Non-destruction Testing.
Key:
You were Levels I, II and III.
Kent:
I didn't say Levels I, II and III, I said Level I.
Key:
You said Level I, Kent:
At San Onofre, Units I, II and III. I worked at all three units down there.
Foster:
Level I visual?
62
Kent:
And Level I PT down at San Onofre. And I did PT also up at Palisades, cause I was Level I PT as well as VT. Ask any of the people that I worked with at San Onofre, ask any of the people that I worked with at Palisades what they thought of my ability, my expertise in welding, my level of work, my concern to quality.
Foster:
Yeah. I think we're getting near the close here. Along that line, and since we're discussing qualifications, after your first Level I visual did they discuss with you the questions that you had missed on the test?
Kent:
Not in depth. They told me I hadn't passed the exam. I said well "why."
Well they said"it wasn't to their satisfaction." I said, "well, why wasn't it to your satisfaction?" You know? They said "well, you hesticated before you answered, for one thing."
Foster:
Hesitated?
Kent:
Yeah, I hesitated before answering.
Foster:
This was a verbal test?
Kent:
I Yeah, it was a verbal, one of the verbal tests - they said that if I you had known the answer you would have come back just like that (snap of the fingers). But they said you hesitated before you answered. I said I was weighing the question for the best answer.
Key:
Well, there was no written test?
Kent:
There was also a written test, but there was also a verbal - in practice, in-depth, you know. When you are out in the field, I can't read the guy's mind, o.k. I don't know what answer he wants me to give right off the cuff and the exactly what he has in his mind, o.k.? But they said that I, 1
one tester told me that one of the reasons I failed was I hesitated too long after he asked me the question before I gave him any answer whatsoever.
63
\
Foster:
Then you passed the written and failed the verbal?
Kent:
They didn't say I passed either one. They said I didn't pass.
Foster:
They never showed you the results?
Kent:
They were supposed to give me a copy and I never received a copy.
Foster:
That's usually my experience. Standard practice is that if a gentleman doesn't pass the exam, uh -
Kent:
He should show him where he doesn't.
Foster:
Yes.
Kent:
Exactly, exactly. I certainly would have like to have had a copy of it and I would like to have a copy of all the other people that did pass and compared mine relative to theirs. And see if I df1 just as good if not better than some of the others.
Foster:
The same thing happen the second time?
Kent:
Yes sir, same thing.
Foster:
And they failed you because of the verbal the second time?
Kent:
They told me, they told me, too much hesitation from the time they asked ;
me the question until the time that I started to give the answer. If you j had known the answer, you would have como right back, just like (snap of j 64 i
the fingers) that and give the answer that he' expected. You thoroughly knew it 100*4. Sometimes in asking the questions, several of the questions I didn't actually hear all the ways that the questions were put. Some of it was in mumbling and I asked one fellow will you please repeat the
! questions louder and slower and let me see.your line of thinking, what you actually want.
Key: .
Was this during your period of training?
Kent:
Yes, on my work up there. Evidentally, they didn't want me to have certi-r fication, Level I, up there. I had it already in San Onofre on Units 1, 2 and 3, also at Palisades. And it is my honest belief that they did not j want me to remain at Midland.
- Ward:
Is that the same type of tests that these other sites as Midland gave?
Kent:
- Basically, it is, uh, except at Midland you have all the extra garbage of the source of it, how it was originally put together from the ASME and the Federal and then Bechtel's interpretation of-it, and things of this nature, '
you know, the other history on how it was assembled, which is not really germane to the actual inspection of whether the weld passes or not.
Ward:
On the Level I PT, did you interpret the results of your pts er did you just perform the liquid pentrant examination? Or what?
Kent:
l There have been times I have actually performed then myself, there have been times I have actually watched people perform them, like say some of the inspectors observed how they ran a penetrant test, and uh if it was correct it was acceptable, if it was not acceptable, why, etc.
r K*I:
As a Level I?
Kent:
As a Level I.
E*I:
1 Did you interpret the results or witness the interpretation?
65 E
4 .
-- , -m - . . .---,--,,.-,--,e - -- - , ,.-,,-. -- , -- - , n - - , - ~ ,,
- - Kent
i I witnessed the interpretation.
' Key:
1
'As a Level'I?
Kent:
As a Level I. I'll tell' you something else, up at Palisades, uh if you check the welds that originally came in on the battery racks up there, the emergency batteries that they had up there, the supports of those
, batteries, that was horribly sorry welding in there. If you get the
- original vendor's procedures and look.at them you.will find out he used short arc, short circuiting metal transfer under microwire .030 diameter wire, thereabouts, and you will find that. they had to reweld all those welds on the battery racks up there cause none of the welds was adequate.
Key:
Yes, that was reported to us on a 50.55(e).
Kent:
'You can actually slip a piece of paper back in under the-filet weld.
, There was that much of a actus1 crack underneath of-the executed fillet j weld.
Ward:
Did you ever request or anybody mention about you taking a Level II exam?
Kent:
I would like to take that Level II examination and even later Level III 1 exam. But you have to do that when they deem that you are ready for it.
You don't have the prerogative of going and saying that I am going to take Level II or Level III, you can't do that.
Ward:
Why did you leave San Onofre?
1 Kent:
The work was finished there. I got a letter of commendation from the
- head of QC on my work, because see we had completed the work and uh -
Ward:
On what unit?
66 i
. Kent:
I worked at Units 1, 2 and 3.
Ward:
.They completed all~their work?
Kent:
No, no,, I said I had completed my area of work. I was working in Unit 1 the last - but if you will check Unit 2 with the main personnel door that Chicago Bridge and Iron made and see if you can get a quarter of an inch plate in back of that hinge on the top hinge,-be amazing, I'm quite sure you will be able to get at least a quarter inch thick plate if not 5/16 plate.
Ward:
Did you say you wrote a nonconformance report on that door?
Kent:
I brought it to my boss's attention, verbally. I took him out there'and showed it to him.
i Ward:
7 Could you have written anything, documented this yourself on that particular door?
Kent:
That was outside my realm of work. It wasn't the burden on my shoulders
, to comment on it, but since I was in the area and I did see it, exclusive of my work, I had to execute it. I did bring this to my boss' attention
- and I did bring him back out there and did visually show him what I had
] seen, and he said if we welded on the door, which means Bechtel, then it
- would take some of the burden off of Chicago Bridge and Iron, on the door if anything happened to the top hinge. I told him then why don't you take photos of it and send it back to Chicago Bridge and Iron and have them send one of their people out and verify that it needs to have a filler plate in there and welded in solid and then let them stand the expense of it. He said no, it had already been accepted by Bechtel at San Onofre in Unit 2.
Ward:
Why did you want to leave Palisades?
i 2
Kent:
i I finished up my work there. I didn't particularly want to leave there -
67
Ward:
Oh, you finished your work there too -
Kent:
I liked working at Palisades, I liked working at San Onofre. But like I said the hydrogen line had almost worn in two on the uh, on the uh trip uh switch on the generator there, o.k.? If that line had finished wearing through you could have a good hydrogen fire because you can't smell hydrogen and you can't see it, you can't taste it, you don't know it's there until you get burned by it, and you would have a real good leak there very shortly, maybe within a week or a month or whatever, wearing away. Because it had worn the wall extensively at that point in time. And if I can walk by and see these, I can't understand why the other people in the plant. Maintenance people, can't see them. I don't understand this.
Key:
You think it's possible they are not looking as closely as you are?
Kent:
I just happen to be walking by, to my job in another area and just happened to see it. Two lines touching together, in the shadows up overhead and that's why I went and I got the ladder so I could get up there and look at it. And I did.
M:
Are you aware of the ANSI standards Mr. Kent?
Kent:
Sure.
Ky:
Which one does the QC inspectors qualify under?
Kent:
31.1 if they're piping, basically. B 31.1, 1
Ward:
I believe at Palisades it was operating, what was your purpose in going to Palisades?
68
Kent:
- They needed to have a. position for me when I finished up my San Onofre work, so they offered me the job of working at Palisades, they said they 4
needed me there. I finished up my work on a Friday and I was working Monday, at Palisades the next week.
Ward:
What did you do then at Palisades, being it was an operating plant?
1
, Kent:
1
- We were modifying it.
Ward:
i Oh, you did some modifications?
Kent:
J
, Oh yes. Emergency cooling water, like 4" carbon steel lines. I have seen many many things, it would take me days and days and days to discuss with you and I had many, many notes on this -
Ward:
Just for curiosity, on Midland, what was your, what would please you to j get this over with? You know, to actually resolve the problems you had at Midland? What would satisfy you where you would feel that you wouldn't have to come to us anymore?
Kent:
Well, actually the training program should be modified to where people 3 are really competent in welding and inspection or they shouldn't be inspecting.
Ward:
l The training of the QC inspector, QC - ?
Kent:
That is correct. They are totally inadequate as far as I'm concerned.
It borders on incompetence. When an inspector cannot read ~a fillet weld
-gauge, he's out there documenting, that it is to size when it is not the i size, to me this is gross negligence and training.
I Ward:
l What else?
I 69
}
Kent:
An independent audit that is thorough, not just with x-ray. But also with a combination x-ray and UT, cause one shows up things the other one won't, like your left hand and your right hand. You need both of them. One is complimentary to the other.
Ward:
When you say audit, you mean a random sampling or you mean 100% or -
Kent:
No. I mean, I mean, like I said earlier here, first things first. The most important things first, steam lines, etc., in my opinion, every single item of critical importance should be completely audited.
Ward:
By audit, do you mean UT and RT of every weld?
Kent:
Both, both. I said of the critical ones, like on your steamlines starting out with 16 inch diameter steam lines for instance, and getting those all completely, 100% audited by x-ray and UT. Not just documentation. I've seen errors in documentations, I've seen actual out and out errors. I've seen documentation in Bechtel's work where you had one sheet with about ten welds on them and about eight of they were cut out, and the others -
Ward:
Well, as far as the errors go, on UT it's only as good as the operator.
Kent:
That's true, but if you have an active operator, I mean from an outside laboratory, not just Bechtel's UT, but -
Ward:
They don't have any UT people.
Kent:
I say, an independent audit.
Key:
Well, you wouldn't be satisfied then with the present radiographs on the Class I welds? i I
l 70
. - - - _ . . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . - - _ _ _ - - _ _ _ _ - - - - _ - - - --- - - - - - ----------I
Kent:
No, no, no way.
Key:
Why not? That's a permanent record.
Ward:
How could the x-rays lie unless -
Kent:
They may be a permanent record, but I've been told that they did find some of those that were duplicates that someone had actually put them in again.
Ward:
0.k. Say you take uh, when you have radiograph, it's like a fingerprint you know, of the surface, the surface condition that (Kent interrupts)
Kent:
But if you have people that introduced the same weld a's another weld, document the same weld as the fingerprint (inaudible) you are talking about similar situation, as another one and it's very similar. And it's not.
Ward:
If you can see ripples and things in welds, uh, mismatch, dingleberry and things like this, and if you, and if it was area 1 to 2 and you took another weld that was 1 to 2 and you seen the same dingleberry or anything like that, that's understandtble. But say, like this was supposed to be uh weld No. 1 and you look at that radiograph that was weld No I and weld No. 2, etc., and if you didn't - you know it's supposed to be steel stamped. there's supposed to be a way to correlate -
Kent:
It's supposed to be a lot of things and a lot things is not.
Ward:
Well, I'm talking about radiography. You're supposed to be able to correlate the radiograph with the lights and things like this -
Kent:
Yes, I concur.
71
_ ._ . . - ._ ._ __ _ . _ _ _ _ _.. _ = - - _ _ . . _ _-. - _ - _ _ __._
Ward:
Now why would that have to be re-radiographed again when you could see
, the. surface on the radiograph, you could see the weld number on the pipe, ,
4 you could - and then go to the radiograph - I don't understand. l 3
Kent:
i If you have someone who is shuffling the x-rays, then putting the x-rays in parts of two different welds when it's really for one weld.
Kent:
If you have an individual, if you have an individual that does that -
Ward:
i j Tell us about that -
i Key:
! Are you stating that now? Are you saying this?
I Kent:
i
- I have been told this.
I
! Key and Ward together:
- Who told you this7 a
j Kent:
)
I was told that this actually happened -
Key:
Who told you this?
J Kent:
, That's what I'm trying to remember, that this has actually happened, i that they had substituted - ,
Key:
4 d
In other words, you are saying that radiography of one weld that is good
! has been documented on other welds and passed -
4
{ Kent:
j I'll, I'll give you an example that net's directly germane to it. I'll give you an example - the Alaskan Pipeline, the fellow who said this as
! 72
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an examplo, as an example. He opened up a whole can of worms by saying that one single sentence.
Ward: .
I was there the day, on the audit that happened.
Kent:
Pa'rdon?
Ward:
I was on the audit when that happened, on the pipeline.
Kent:
Uh-huh. And what did they do? Did they give the fellow a stick of dynamite in his pickup truck with his name on it?
(Chuckle from everybody in the background)
Foster:
Are you referring to the pipeline, when you are talking about someone redoing an x-ray?
Kent:
Yeah, the Alaskan pipeline, I said that as an example, where you can have that situation occur, o.k.? With no one knowing about it.
Foster:
(Aside) Let me do this. Speaking about the Midland Nuclear Power Plant - has someone advised you that at that plant or for that example the Palisades Plant that someone has duplicated radiographs -
Kent:
I heard that several of the x-rays had been duplicated. I don't know for a fact which numbers they are, o.k.?
Foster:
Who told you this?
Kent:
I don't recall exactly who told me this, but sometimes when you are in a conversation with a number of peog's and you discuss the things with different people you pick up dif fere:: things and it's in one of the conversations that I discussed, I was di. cussing something with some people, they said it was a very small amount.
73 1
Foster:
In one of the conversations when you were discussing with people. Which people?
Kent:
That's what I'm trying to recall, whether it was the QC people in Midland or the people in Palisades. Someone told me, or I heard it in a conversa-tion that there was an actual duplication of x-rays but a very small number.
Foster:
And the location?
Kent:
I don't know the exact location, no.
1 Foster:
i Well, I mean the plant for example, for example, the plant.
Kent:
To the best of my memory it was, it was probably, Midland and probably, I'm not sure now, it was probably relative to the liner plates. I think so, I think it was in the liner plates in the containment. Just thinking back here. I think that they did say that they were, x-rays that were with excessive porosity in some of the joints in the liner plates.
Foster:
That's different than a radiograph being falsified, there was a problem identified.
Kent:
0.k. I think in the same conversation that they said that they found a few, or several, or whatever, or small percentage on the order of the x-rays there that the contractor had done that vere duplicates. I'm quite sure that's where it was.
Foster: ,
You've read our report you find that we have talked about radiograph interpretations, shop weld radiographs on the liner plates of Units 1 and 2. This is on page 4 of our inspection report.
Kent:
I think I did read that.
74
Foster:
0.k., then we are aware of that condition.
Kent:
Let me -
Foster:
Uh, I know you must have some time constraints but I have two points that I wanted to get to very briefly. If you have any notes or other documents that you feel would be of interest -
Kent:
I have lots of (Tape ends)
Kent:
I have publications there and every single bit of that I generated, I'm the author of every single page in there, every single bit of it. That will show you something of my background, you thumb through it and you will see the publication Welding Engineer magazine with my uh world wide copyright, that's this one is, for instance here's a sample of it.
Here's Welding Engineer magazine, here's the Engineering Data Sheet, the only one, and here's my world wide copyright, my name right here, the year 1974, for instance o.k.?
Foster:
Uh-huh.
Kent:
You'll see numerous of those in there. You'll see this one also in there.
Foster:
(Reviewing magazine) !
It's interesting. '
Kent:
You run through and you'll see like this over in here, copyright here.
This goes in Welding Engineer magazine January 1970, I think it was made !
in 1969.
l Ward- l l
l Earl, you said No. 1 training QC welding inspectors; No. 2, independent
75 l
~
.r Kent:
I'd hold an in-depth survey under oath of every welder in Midland as to whether or not they knew of any violations at anytime, anywhere on any of their work that they had executed or anyone else had executed. An in-depth survey, under oath, depositions.
Key:
You have those documentations that we can copy?
Kent:
No, I have a lot at home. I'm just giving you a sample of some of my work here.
Key:
Now what we'd like to get is some documentation pertaining to the accusations or the problems that you have - (interruption by Kent)
Kent:
Like this one right here - you don't have documentation today on this one.
And you know it's very, very common, o.k.? I have documentation at home on it and Bechtel has a hell of a lot more documentation than I have cause I never got a copy of Bechtel's ninety some page report on it.
Foster:
Referring to a ninety page report on San Onofre.
Kent:
In excess of ninety page report. But this problem is not only at San Onofre, it's also at Palisades and also at Midland. It's on electral tray hangers.
Foster:
Let me rephrase the question. Do you have any notes or documents that would help us in reviewing your concerns at the Midland plant? If so, we're interested in getting that and making copies if possible.
Kent:
Let me uh review my material on California that I have in notes. Causo what I said on this one here is that I do not have a copy of the report in excess of ninety pages that Bechtel has on it. I do not have that.
But you will find it if you check with San Onofre's work and the Norwalk main office does have a copy of that report.
l l
76 !
1
,r=~
Foster:
It is my intention to refer your concerns regarding San Onofre to the cognizant regional office down there and ask that they look at these concerns.
Kent:
0.k.
Foster:
I had one last question and then I know that you have people waiting for you and I'm advised that there is someone that wishes to see you. Did you call the Detroit office of the FBI on February 26?
Kent:
Yes, I asked them for personal protection.
Foster:
May I ask why?
Kent:
I uh honestly thought my life was in jeopardy.
Foster:
Why did you feel this way?
Kent:
Well, for a number of reasons. One, (pause) I had heard stories before that sometimes when people complain about nuclear things they disappear.
Foster:
Ay least all the people I have dealt with, they have not disappeared. I don't mean that facetiously.
Ky:
We've held many, many investigations and we have yet to lose any uh, one that said anything, at least not to our knowledge. (laughter)
Kent:
l Ask some of the people at Palisades about the Navy fella that disappeared !
and he was gonna have some complaints about some of the Navy nuclear work -'
and they never saw him again. l l
i 77 l
1
.h**
. Foster:
0.k. That's a new story to me. But, uh, I've~been working in the NRC'I gitess for something approaching or passing six. years and at least to my.
knowledge, we haven't lost one yet. We hope to maintain a-good record.
Kent:
I hope you do.
Foster:
I'm advised that your son was out in the lobby and will be back.
Kent:
Oh boy, well they're very anxious to be on the road.
Foster:
Let me express my appreciation for the time you've spent with'us and the trouble you've taken in coming here.
Kent:
You're welcome.
Foster:
And I think with that I'm going to close this tape recording. This'is Thursday, October 12, 1982, the time is approximately 12:45 p.m.-
.78
- p. .
GOVERNMENT ACCOUNTADIUTY PROJECT j
155.5 Connecicut Awmue N.V. Suite 202 t Woshington. D.C. 20036 (202)2324550 l
I March 25, 1985
- Freedom of Information Act Request Director FREEDOM OF INFORMATK)N l office of Administration ACT REQUEST U.S. Nuclear Regulatory Commission i
Washington, D.C. 20555 hM., g- 2./ 3 To Whom It May Concern: g8d k2 [
Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C.
g Section 552, the Government Accountability Project (GAP) requests 8
copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, inter-view reports, procedures, instructions, engineering analyses, l i
drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, tele-phone messages, computations, voice recordings, computer runoffs, l
any other data compilations, interim and/or final reports, status !
reports, and any and all other records relevant to and/or gener-ated in connection with the Brookhaven National Laboratory (BNL) investigation of the allegations of Mr. E. Earl Kent, and all drafts, materials, etc. , developed by Brookhaven. This request includes all correspondence (of any type) between BNL and the Bechtel Corporation, Consumers Power Company, Southern California l Edison, and any representatives or staf f members of the profes-sional societies (i . e . , AWS , ASME , ANSI, etc.).
This request includes all agency records as defined in 10 C.F.R.
Section 9.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980) whether they currently exist in the
' NRC official, " working", investigative or other files, or at any other location, including private residences. l 1
If any records are defined in 10 C.F.R. Section 9.3a(b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed af ter this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a des- i l
cription of the action (s) taken relevant to, generated in connec- l tion with, and/or issued in order to implement the action (s) . l GAP requests that fees be waived, because " finding the infor-mation can be considered as primarily benefitting the general pub-lic," 5 U.S.C. 552 ( A) (4) ( A) . GAP is a non-profit, nonpartisan
%pb25 W , .
- ~
i
Freedom of Information Request March 25, 1985 Pago Two public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Citizens Clinic, GAP of fers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens Clinic is currently assisting several citizens groups, local governments and intervenors in the mid-Michigan area concerning the construction of the Midland plant.
We are requesting the above information as part of an ongoing monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants.
For any documents or any portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is rele-vant to the document or portion of the document withheld. This index is required under vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974).
We look forward to your response to this request within ten days.
D IN Billie Pirner Garde Citizens Clinic Director 1
I I
1
b BROOKHAVEN NATIONAL LABORA t
h(ll ASSOCIATED UNIVERSmES. IN!
Uptort Long lelond. New York 11973 i (516) 282s Fis 666'7005 January 10, 1985 Mr. R. Varnick .*
DPEP, Region III 799 Roosevelt Road, Ridg. 4 f
Clea Ellyn, II.L 60137'
Dear Bob:
the welding allegations at the Midland Eclear power Station. A tions made by you and your staff at the meeting in your' o 12, 1984.
If you require any additional information please call me.
Very truly yours, rGL ha E. Taylor, Croup Leader 1 ant Systems and Equipment Analysis Group AT/jr set R. Bari T. Burns '
C. Caajkowski
.' R. Es11 W. Este E. Boots ~
- J. h eks
.~
l l
gT(f.424($
Fl
- f -
i JAN 29 sB5 .
i l nn
1
+. : l
< 3 Report on Welding Allegations Prepared by Brookhaven National Laboratory LICENSEE: Consumers Power FACILITY: Midland Nuclear Power Station, Units 1 & 2 TECHNICAL SPECIALISTS: A m / /8 [
/ Car jkowski' /Dati) 7- lll5lrf Thomas Burns (Date)
REVIEWED BY: / J 8I John H. Tiylor (Date) t$44 -
Robert E. Hall
~ ? /A/As
'(Date)
(f~f f,0 O/h lI 0 9 z) M (cr\ Ul(J L ( 7 3h 6
-,
- CONTENTS Page I. Sununary.......................................................... 1 II. Allegation Categories............................................ 2 A. - De s c ription of Allega tion Ca tego rie s . . . . . . . . . . . . . . . . . . . . . . . . . 2 B. All e ga t i o n So r t by Ca t e g o ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 III. Allegation Analysis and Re s pons e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Attachments
- 1. Allegation Sort By Originator 1
I O
/ 1 e
- I.
SUMMARY
This report is an analysis of sixty-one allegations made by an alleger against the welding program at the Midland Nuclear Power Station in NRC Region III and two other Nuclear Power Plants in Region III and V, respectively.
The allegations have been grouped into categories which are described in Section II. The analysis and response to each allegation is contained in Sec-tion III. And finally, Attachment i lists all of the allegations in chrono-logical order and identifies the source documents from which the allegations were formulated. The alleger's name or inferences to the alleger's identity are not used anywhere in this report.
Four of the allegations (Category A) are non technical and should be referred to the Office of Investigation for resolution.
Thirty of the allegations (Categories B & C) have been responded to on a technical basis. Two of the allegations (#13 - pg. 13, #24 - pg. 15) in this category require a response or action, but are not significant. Allegation
- 57 (pg. 23) identifies an are strike, which should be corrected.
Seventeen of the allegations (Category E) were either 1) applicable to other sites, and therefore not addressed, or 2) were too general and undefined and therefore could not be addressed by BNL.
Finally, eleven of the allegations (Categories D & F) required large scale physical inspection programs, which could not be conducted by BNL in the time available.
k
, - - + , - ,- -
i 1
-f
, .m II. ALLEGATION CATEGORIES A. ' Description of Allegations Categories Category A - Office of Investigation - These allegations are outside of the scope of work for BNL. Due to the nature of the allega-tion, no technical response can _be provided and we recommend' the item be referred ' to the NRC _ Office ,of Investigation . (or
- other appropriate agency) for resolution.
i Category B - Code Requirements alleged to be inadequate - These allega-tions are an expression that those Codes, Standards and l Practices utilized by industry are inconsistent, contain I errors, and/or conflict in some areas. These. allegations do !
not specifically identify or address an unorthodox or devi- J ant condition or practice at the Midland Plant site.- 'j l
Category C - Technical response can be provided - These allegations were i evaluated and a response provided which is based on a tech-nical analysis, document search, compliance verification, actual item examination or other observation.
Category D - Procedures / Specifications fail to ' comply with Code ( ASME) or, are inadequate - The allegations assigned to this cate-gory are too generalized-for a meaningful response to be developed. No item is specifically identified such_that a particular specification or procedure _can be evalusted for code compliance.- However, a response could.be developed based on the selection and review, for code compliance, of erection, fabrication, procurement and welding specifica-tions and procedures. The selection would be made such that the sample would include safety related components, items, structures and systems which perform a pressure retaining
+
function of th'e reactor coolant pressure boundary or its support.
Category E - Allegation not site specific or too general-Dismissed - The following allegations are not specific to the Midland Plants and therefore could not be substantiated or verified during this recent site visit. Also, we are including those alle-
! gations in this category which do not warrant further_ action
- due to their vague and subjective nature.
Category F - Additional Work / Investigation required - These allegations, although considered by BNL to be broad subjective and gen-eral are such.that a meaningful technical response could be provided when based on an analysis of results obtained from a specific inspection plan or ef fort. -This effort was not made due to the obvious magnitude involved. It is entirely possible that a response could be provided which will be
, based on the data obtained during overinspection, corrective action and/or other quality verification plans and programs i
- which have been (or will be) accomplished at the Midland 1 plants.
l
- 3 l
, a i
l l
B. Allegation Sort by Category Further No Re-Category Allegations Responses Work sponse Provided Required Required A 16, 17, 7, 20 X B 32, 42, 48, 50 X C 3, 9, 10, 11, 13, 14, 15, 24, 25, 26, 28, 29, X 30, 31, 33, 41, 44, 46, 51, 53, 54, 55, 56, 57, 58, 59 D 2, 6, 7, 8, 34 X E 1, 5, 12, 18, 21, 22, 23, 35, 37, 38, 39, 40, X 45, 47, 49, 52, 61 F 4, 11, 27, 36, 43, 60 K Note: Due to category definition, certain allegations will be found classi-fied in more than one category. However, one response has been provi-ded in the report text.
O 9
9
g 4
, III.. Allegation Analysis and Response
~
The allegations are grouped by category in this section for ease of re-sponse. For reference the allegations are listed below in chronological order with corresponding page number.
ALLEGATION NO. PAGE NO.' ALLEGATION NO. PAGE NA 1 27 32 6 2 26 33 20 3 0 34 26 4 2. 35 29 5 27 36 32 6 26 37 29
- 7 26 38 29 8 26 39 29 9 9 40 30
. 10 10 41 20 11 10 & 32 42 7 12 27 43 33 13 13 44 20 14 14 45 30 15 14 46 21 16 5 47 30 17 5 48 8 18 27 49 30 19 5 50 8 20 5 51 21
~
21 28 52 '31 22 28 53 21 23 28 54 21 24 15 55 21 25 16 56 22 26 17 57 23 27 32 58 23 28 18 59 24 29 18 60 33 30 19 61 31 31 20 l
- + - - r
o 5 CATECORY A
. Office of Investigation The following allegations are .outside of the scope of work for BNL. Due to the nature of the allegation, no technical response can be provided and we recommend the item be referred to the NRC Office of Investigation (or other appropriate agency) for resolution.
Allegation 16:
"#RC inspections ften failed to correct problems. (This was because the NRC inspectors seemed too willing to trust the Bechtel inspectore when they made their tours.)" <
A11eration 17:
'RRC inspectors were handicapped by their practice of not coming in unan-
- nounced. To the best of my knowledge, there were no NRC inspections that weren't preceded by preparation directed by Bechtel, during which prob-less would be repaired and sometimes modified."
i- A11eration 19:
"I can only believe that I was fired for insisting that there were ser-ious problems at Midland which my superiors refused to acknowledge, and
- hence refused to repair."
Allegation 20:
"I told them T felt that Bechtel was not adequately investigating the serious pro! s I had tried to bring to their attention, and that I felt I had been fired for trying to do this."
4-O 4
6 e
9 e- ~~ - - ,, , , , - ,- , ,- n -- _ ,r -,-w w - --- -rw- vr-,
6
,. . CATEGORY B
, Code Requirements Alleged to be Inadequate 4
The following allegations are an expression that the Codes, Standards and Practices utilized by-industry are inconsistent, contain errors and/or con-flict in some areas. These allegations do not specifically identify or address an unorthodox or deviant condition or practice at the Midland Plant site.
Discussion:
The codes specifically identified are in fact, not identical and. were not ' intended to be so. The codes referenced differ in many areas as they were
- developed for completely different applications. The reference to "AWS" is presumed to mean the American Welding Society (AWS) Structural Welding Code -
, Steel (AWS D1.1). This document is an American National Standard approved by the American National Standards Institute. This code-is prepared by the AWS Structural Welding Committee and is intended to cover welding requirements
- applicable to the construction of welded structures-(buildings, bridges and tubular structures).
The reference to "ASME" is presumed to mean the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code. This document is also an American National Standard and is prepared by the ASME Boiler and-Pressure Vessel Committee. The scope of this document is extensive and it consists of eleven sections and numerous subsections. The stated purpose of the Committee (through the issue of this code) is to establish rules of safety governing the design, fabrication, and inspection during construction of boil-ers and pressure vessels.
The stated purpose of each of these codes is clearly different and are not intended to be interchanged. Since there are areas where similar proces-ses and materials are used, it is understandable that differences might not be !
apparent to infrequent users. The evaluation and development of these codes has occurred over a span of many years by two entirely different and separate industrial bodies. Therefore , differences - are . not " inconsistent". "discrep-ant" or in " error" and, these differences are not cause for alarm. Given the specific purpose of each code, they cannot (and were never intended) to be identical (even for similar processes).
Each of these codes has been in use for their respective applications for a combined total of over one hundred years (AWS-1911, ASME-1928) and through use, review, comment and revision have evolved into a formidable set of re-quirements which have kept pace with the advances in construction technology.
Allegation 32:
"Pg.125, para 3 - A11eger states a discrepancy exists between AWS and 1
ASME stating: AWS limits the size of electrode for vertical and overhead -
position welding to 5/32" diameter - ASME does not." -
9
- - - , , - , , . . , - , , - , . - ,-..,,-,-,.,,,y. -
- . , ,_ y-y-,-,r.--, ,-- %, . - -.-,--- -
.' 7
-Response:-
I' This difference does exist between the two referenced codes and should not be considered " discrepant" since AWS permits use of "prequalified" l
I Joint configurations-in specific positions while ASME requires qualifica-tion of all procedures. Each code requires the qualification testing of
- .welders in specific positions to qualify for "all" position welding.
Allegation 42:
" Alleger expresses concern of the lack of dew point control in argon '
gas."
Response
The results of inspection revealed that argon gas procured for welding at l the Midland site was obtained as " welding grade" with.no specific dew point specified. The term " welding grade" in and of itself does not de-note a specific dew point or moisture content.
There is no requirement for the control of dew point (moisture content) of gas or gas mixtures used for shielding or backing in the performance of welding in accordance with the requirements of ASME Section III (Divi-j sion 1 - Nuclear Power Plant Components). There is a requirement in AWS 4
DI.1 (Para. 4.13 Shielding Cas) that gas or gas mixtures used for shield-ing in two specific welding processes (gas metal arc or flux cored are welding) shall have a dew point of -40*F(-40*C) or-lower.
1 Pressure retaining components (to include the reactor coolant pressure boundary) are fabricated and erected in accordance with the requirements of ASME III at the Midland site therefore, no nonconforming condition exists as regards the dew point of argon gas procured and used in these i activities. Due to time constraints, we were unable to determine if
- welding had been performed on safety related components or structures under the rules of AWS DI.1 using the referenced processes.
We note that this " allegation" is not made to identify a nonconforming practice but, was an expression of " concern". The control of this vari-able in argon gas is a matter of engineering judgement since it is not a predominant source of-weld defects. In the event construction activity
, should resume at the Midland site, we believe this ites can be resolved
- by the following activities
- a. Determine if welding had been performed on safety related structures l and/or components under the rules of AWS Dl.1 (any edition as far
! back as 1972) using the gas metal arc or flux cored arc welding
- processes.
a
- b. Determine if the gas or gas mixture used was procured with a dew point of -40*F or lower.
)4 As of this date, the allegation was not substantiated.
)
, , . , . . , , , . _ _ . . . , . , , . . - - - , __m - m , n ..-.,,,..,y. _.,,,__._y , , .,- ,,,.t
.' 8 Allegation 48:
. s
" Alleger expressed concern over the code not addressing weld ripple spacing.
Response
The weld acceptance criteria is adequately specified in both referenced codes and, both codes address the weld profile and surface appearance (AWS DI.1, Para. 3.6, 8.15 and ASME - NX4424) in substantial detail to include " weld ripple".
Allegation 50:
"Pg. 51, para. 2 - indicates alleger was upset that there were several instances of inconsistencies or errors between AWS and ASME."
Response
The response is provided in the discussion portion of this allegation category.
t l
e 1
. .. ... . -. . . . .. - . - . . . . . ~ . -- .~ . . - . - -- .
.' 9:
i
< . .' CATECORY C Technical Response Provided by BNL The following allegations were evaluated and a response provided which is based on a technical analysis, document search, compliance verification, act-ual item examination or other observation.
i Allegation 3:
j "Bechtel has hired engineers and QC' inspectors who were not adequately
- qualified or trained for the complicated work in a modern nuclear plant."
Response
A review of the Bechtel Power Corporation qualificat' ion requirements for
. engineering personnel could not be accomplished.since travel to their San l
Francisco headquarters would be required for file search and evaluation..
Allowable time did not permit.BNL to accomplish this review. The re-sponse we have provided to allegations 26 and 46 is appropriate to the concern the alleger has expressed regarding the qualifications and train-ing of QC inspectors. This allegation has not been substant.iated.
3 Allegation 9: 1
?
l "(The subject is socket weld engagement length.) ... stated that'as long. l l as the pipe is not withdrawn from the fitting, it will be approved. This j means that a gap of nearly any length will be tolerated between the 'end j i ,
of the pipe and the bottom of the socket. ...the ASME code has, for this i reason, established a much more rigorous- specification." i
Response
i i The following documents which govern the socket veld fit up requirements- )
, for those systems being fabricated and erected in accordance with ASME i III - Division I were reviewed at the Midland site. I
- 1. GWS-SN, Rev. 3 (7/16/76) and Amendment #9 (7/22/83) - General Welding Standard (Stainless and Nickel)
- 2. GWS-F:!, Rev. 4 (7/16/76) and Amendment #10 (7/22/83) - General Weld-i ing Standard (Ferritic and Martensitic)-
- 3. GWS-NF,' Rev. 2 (8/7/78) General Welding standard (Nonferrous)
These documents were found to contain specific and : detailed requirements for.the fit up of socket velds. The instructions contained specific gap.
requirements (1/16" approximately. - later increased to 1/8" approximately 1 in the above referenced amendments) with procedural requirements for ver- '
ification. These gap requirements are in compliance with that found in-ASME III - Division I. No items of noncompliance with the ASME code were i identified in the Bechtel requirements for socket weld fit up. This allegation is not substantiated and we recommend this item be closed without further action or investigation.
4
?
1 10
-l i
Allegation 10:
" Equally as serious as the problem of downgraded specifications were the problems created by the incompetence and igaorance of QC. .Even something l j
-basic like knowing how to use the fillet gauges correctly to measure the size of welds was beyond the ability of some of the Bechtel inspectors and ... ..
One QC engineer was also _there to hear the explanation, and he admitted
~
af ter I 'showed him the diagram that he'd been approving bad welds him- <
self, mistakenly determining inadequate fillet welds as being adequate." l l
,' Response:
Allegations 10 & 15 (page 14) - These allegations have been combined and an identical response provided since their basic contention is the saine and, they are highly subjective. During the BNL visit to.the site, the records for qualification and training were examined for thirteen person-nel (including the individual identified by name) and, no items of non-compliance were identified. All personnel had been trained, were tested and qualified to perform their respective tasks. Also, subsequent to
. qualification, periodic training sessions were held to appraise the in-spector(s) of ongoing changes in procedures and specifications.
We noted that the requirement existed for all welders (involved in weld-ing under the requirements of ASME, ANSI B31.1 and AWS DI.1) to be -quali-fied in accordance with requirements established in the respective code (usually ASME Section IX or AWS for structural welding). These require-ments are extensive and very thorough and could hardly be considered "less than formal". Inexperienced welders will not be able to success-fully accomplish these tests satisf actorily.
Implementation of the recommendations for allegations 4 and 60 (page 32, 33 - Category F) would supply further information as to the substance of
- this allegation. Presently, we find the allegation not substantiated and recommend this item be closed without further. action or investigation.
~
I Allegation 11:
2 "Because of this, I was very concerned to discover that many welds in the piping had been improperly ground down, grinding down the pipe wall thickness along with it."
Response
Technical Specifications for Weld Fabrication and Installation of Piping for Nuclear Service for the Consumers Power Company, Midland Plants,
- Units 1 and 2, Midland, Michigan 7220-M-204(Q) Rev.15, 6/16/81, page 11, para. 5.2.6 Wall Thickness Requirements states " Minimum wall thickness for fabricated assemblies.as finally fabricated shall be at least
- a. 87 1/2% of the nominal wall thickness for pipe specified by nominal ;
1 vall, or i
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J 11
, b. The minimum wall thickness for pipe specified by minimum wall.
c.- 75% of the' nominal wall thickness for'12-inch and under HCB and HCC class pipe only.
Paragraph 3, codes ands 'tandards of this document states:
"All material, f abrication, installation, . testing and examination shall be in accordance with the American Society of Mechanical Engin- ,
eers (ASME) Boiler and Pressure Vessel Code Section III, herinaf ter referred ~ to as the Nuclear Power Plant Components code, and applic-able portions nf the Pipe Fabrication Institute (PFI) standards as referenced,-A' I N45.2.1 and ANSI N45.2.2.
Documents incorporated by reference into these Specifications shall be the ' issue (including latest Addenda), in effect on the date of issue of the specifications. Adoption of any Code Cases, interpreta-tions and rulings, or subsequent issue of codes shall be subject to the approval of the Project Engineer. Code Case 'N-282 is . approved for use.
All nuclear piping is classified in one of'three Nuclear Piping Clas-sifications. The Nuclear Piping Classification is shown on the Pip-ing class Sheet. All piping systems shall be fabricated in accor-dance with Nuclear Power Plant Components Codes and these Specifica-tions for the Nuclear Piping Classification shown on the Piping Class Sheet."
i Same title document Rev. 23, 6/8/84, page 13, para. 5.2.1 states:
" Care shall be taken in handling and installation of piping to pre-vent surface damage. Defects such as scratches. gouges, and pits shall be acceptable provided the depth -does not violate minimum wall
, thickness requirements (see Section 5.2.6) and is not greater than 1/16 inch deep. Arc strikes are acceptable if there are no visible cracks and the crater depth is not greater that 1/16-inch and does not violate minimum wall thickness requirements (see Section 5.2.6).
Deposited weld metal need not be ground out in order to inspect the are strike. Surface porosity is not a criterion for rejection."
. Same document, para. 5.2.6, Wall Thickness Requirements states:
" Minimum wall thickness for fabricated assemblies as finally fabri-cated shall be at least:
- a. 87-1/2% of the nominal wall thickness for pipe specified by nomi-nal wall, or j l
- b. The minimum wall thickness for pipe specified-by minimum wall. .
! c. 75% of the nominal wall thickness for 12-inch and under HCB and
- HCC class pipe only. '
i
- d. As specified in the material specification for pipe made from i plate.
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12 g'
- ~ '
-The'as-installed wall. thickness of piping assembly may be less than that required by Items a through d above provided that it is greater than or equal to the minimum required thickness, t , determined using the procedure in Appendix C. Cases in which the as-installed wall thickness is between that generally required by Items a through d above and ot shall be documented via field change. notice. Field calculations are to be done in accordance with Specification 7220-G- ;
35(Q)."
Appendix C, Rev. 22 is attached. The code applicability of this specifi-4 cation is called out- in para. 3, Codes and Standards.
"All material: fabrication, installation, testing and examination shall be in accordance with the Arnerican Society of Mechanical Engin--
eers (ASME) Boiler and Pressure Vessel Code,Section III, hereinaf ter referred to as the Nuclear Power Plant Components Code, and applie-l able portions of' the Pipe Fabrication Institute (PFI) standards as referenced, ANSI N45.2.1 (1973) and ANSI N45.2.2 (1972). Howeve r ,
i certain equipment supplied by vendors as part of a package may be specified to other codes as appropriate. . Examples include, but are not limited to, the following: rotameters, venturis and flow ele-ments from Babcock & Wilcox (ANSI B31.7), decay heat removal heat ex-changer and makeup pump lube oil coolers from Babcock & Wilcox (shell side to ASME VIII), steam generator main feedwater ring from Babcock
, & Wilcox (ANSI B31.1), auxiliary feedwater- pump turbine driver from Terry Turbine (none), and piping embedded in reactor building base-I ment from Southwest Fabrication and Welding Company (B31.7).
- ASME Section III Code-effective dates and approved code cases shall y be as stated in Specification 7220-M-324(Q).
J All nuclear piping is classified in one of three Nuclear Piping Clas-sifications. The Nuclear Piping Classification is shown on the Pip- -
ing Class Sheet. All piping systems shall be fabricated in accor-dance with the Nuclear Power Plant Components Code ' and these Specifi-l cations for the Nuclear Piping Classification shown on the Piping
, Class Sheet.
I Piping Class sheets for the Consumers Power Company, Midland Plant, Units
, 1 and 2 Midland Michigan, 7220-M-481(Q),- Rev. 26, 6.6.84, Code applica-
! bility attested to by licensed P.E. Manoher, L. Hora, Engineer No. 25292 4 (State of Michigan).
"I, the undersigned, certify that these Piping Class Sheets accurate-ly define the requirements prescribed in Subparagraphs NA-3252(b),
NA-3252(f) of ASME III, Division 2. Boiler and Pressure Vessel Code, i 1971 Edition with Addenda through Summer 1973."
The above listed specifications take into account the evaluation of mini-sum wall thickness requirements. Additionally, the Ouality' Control In-struction used for pipe weld inspections (PW-1.00, Rev. 3,10/12/81) states in Section 21. " Verify that the pipe, pipe fitting, piping subas- ;
sembly, valve or in line component is f ree from damage." This document references Spec. M204 para. 5.2.1, 5.2.3, 5.2.6 and 6.3.2. A sign off i
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c 13 section for this attribute is also found on Quality Control Inspection Record POCI No. ' 7220/PW-1.00 Form 19517. The specifications take into account minimum wall thickness and _ these requirements have been transla-ted into inspection documents. These engineering and inspection proce-dures would be adequate identifying non-conforming conditions of over grinding if implemented correctly. For a complete evaluation of this allegation, a detailed physical inspection is required therefore, this allegation was not substantiated due to time constraints. This allega-tion is also listed under Category F.
Allegation 13:
"...Bechtel allow . Iow-hydrogen electrodes used in velding to be taken out of their hot ovens or hermetically sealed containers for up to eight hours before use. The American Welding Society (AWS) standard allows only four hours maximum in the open air."
Response
This allegation is identical to 31 and has a concern regarding the expo-sure time of low hydrogen electrode to the environment af ter removal from their hermetically sealed containers or drying /sto' rage ovens. It is our understanding that the portable rod heaters (or, caddies) do not consti-tute a drying / storage oven since their temperature requirements do not comply with that specified in AWS DI.1. As a result of the review of the '
Bechtel Welding Standard (WFMC-1, Rev. 6, Amend. 8) for the control of weld filler metal at the Midland site, these allegations have been sub-stantiated. The Bechtel weld filler metal control policy was not in com-pliance with the requirements of AWS D1.1 at the time the allegation was made. The program as amended on November 29, 1983, was still not in com-pliance. Specifically (as amended), the specification permits electrodes having low hydrogen coverings to be exposed to the atmosphere for a per-
' iod which exceeds that specified in AWS Dl.1 (10 hrs. vs. 4 hrs.). This requirement is found in AWS D1.1 (para. 4.5.2, 4.5.2.1 and Table 4.5.2).
Relief is granted by AWS Dl.1 from this requirement (time limit is in-creased to 10 hrs. maximum) if the user established, through testing, what the maximum allowable exposure time can be without degradation of weld quality as affected by changes in the moisture content of the elec-trode coating.
Bechtel personnel at the Midland site believe their program has NRC approval.
Several. documents were examined which indicate an alternative program was submitted to the NRC and accepted by the Division of Reactor Construction Inspection, IE (dtd. December 8,1977, G.W. Reinmuth to R.
H. Engalken) but, was specific to the Palo Verde site. Inference is made in this memo that the alternative program was acceptable for "any nuclear plant". An internal Bechtel memorandum of April 28.-1978, B. D. Hackney to P. A. Martinez (of the Midland Project) states that the alternative program "has been submitted to and accepted by the NRC as a Topical Report thereby permitting generic use of the alternative electrode con-trol practices and procedures described." ,
- Since documentation specifically approving the program for use at Midland could not be located, BNL recommends that this item not be closed until
. -i
[ 14 -
. . documentation can be produced which unequivocally states that the alter-native program has been approved by the NRC either generically.for all
. plants or.specifically for Midland.
Allegation 14:
"One QC engineer who has been at Midland for many years told me that in his opinion over 90 percent of the piping in the entire plant has hadJto be cut out and replaced at one point or other. In my mind, this raises serious questions o. safety ~... .
Response
Two documents were reviewed in the investigation of this allegation -
Bechtel Power Corporation Project Ouality Assurance Activity Report No.
80-5 dated 6/2/80, which outlined (page 5, Chart lA) a twelve week trend-ing for all Final Inspection Radiographed Rejects (pipe welds). . The-graph plotted the rejects over the 12 week period of 2/2/80 - 5/9/80.
The reject rate was 2.87% (percent of welds rejected /no. of welds radio-graphed). The second document reviewed was a Bechtel Site Construction -
Midland Nuclear Project - X-ray Welds % Form (W-1). . This form covered the period of January 1982 - September 1983 and showed a reject rate varying between approximately 28% to approximately 9% during the per-iod. This form also covered final inspected welds. . It should be noted i that during the course of construction, there may have been in-process -t repairs which would not be recorded on these forms. The performance of i
inprocess repairs is not considered unusual and is a common and necessary 3 practice. Since the reject rates recorded on these documents is signifi-cantly lower than 90%, this allegation is not substantiated. j Allegation 15:
They have happended because Bechtel has -hired inexperienced engineers, welders, and inspectors.
There were few formal requirements to become a welder, or even an inspector.
If this was supposed to be corrected through a thorough training program, 4 it didn't happen.
The training periods were only a couple of weeks, and based on my experi-ence in working with the engineers, welders, and the inspectors, I can state that they were not properly trained."
Response
l Allegations 10 (page 10) & 15 - These allegations have been combined and !
an identical response provided since their basic contention is the same j and they are highly subjective.
l
! During the BNL visit tc the site, the records for qualification and training were examined for thirteen personnel (including the individual
! identified by name) and, no items of noncompliance were identified. All l l
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, 15-1 personnel had been . trained'. .were tested and qualified to perform their -
respective tasks. Also, subsequent to qualification.. periodic training
- sessions were held to. appraise the inspector (s) of ongoing changes in j procedures and specifications.
l-We noted that the requirement existed for all welders (involved in weld-ing under the requirements of ASME, ANSI B31.1 and AWS D1.1) to .be quali-fied in accordance with requirements, established in the respective code l- (usually ASME Section IX or AWS for structural welding). These require-ments are extensive and very thorough and could hardly be considered "less than formal". Inexperienced welders will not be able to success-
- fully accomplish these tests satisfactorily.
I Implementation of the recommendations for allegations 4 and 60 (page 29,
, 30 - Category F) would supply-further information as to the substance of
! this allegation. Presently, we find the allegation not substantiated and
- recommend this-item be closed without further action or. investigation.
4 Allegation 24:
"Bechtel Specification WQ-2, sheet 20, note 1, requires "shall not exceed-1/3 inch ..." regarding maximum groove weld reinforcement at Midland, 4
Michigan's Twin Nuclear Plant. This requirement _should read "shall not exceed 1/8 inch ..." as required by the ASME Section III code on groove veld reinforcement."
Response
Allegations 24 & 33 are identical and were made in regards to both the j Midland plants and the San Onofre plant.- The same document (WO-2 Bech-tel Power Corporation, Welding Standard, Performance Specification) would apply at both sites since this is the Bechtel practice. An examination
, of this document (Rev. 2, April 4,1980) reveal that the referenced " note
- 1" does read " Butt and corner joint reinforcement shall not exceed 1/3" i
and shall have a gradual transition to the plane of the base metal surface."
The referenced document is one which contains the requirement for the qualification of welders to make acceptable welds, in accordance with AWS i
D1.1 and AWS D12.1. The specific requirement on " sheet 20" of WO-2 is
- titled " Visual Inspection of Weld Profiles" and is identified as Drawing WQ-2-8, Rev. O and " note 1" is made in reference to .the sketch of a butt weld which shows a case of excessive convexity (reinforcement). The sketch is specifically identified as an unacceptable butt weld profile.
This document does not apply to or govern the field welding of any compo-nents, structures, piping or attachments thereto whether safety related or not. Its sole function is to establish the procedure for conducting the welder qualification test and, sheet 20 illustrates the required weld profile for qualification tests performed using plate test material.
i This dimension (1/3" appears to be a typographical error since the code
{ ( AWS D1.1) requirement is 1/8" maximum.
There is no deleterious effect as a result of.this typographical error.
The work accomplished by welders at the Midland site is subject to in-spection and' acceptance by an independent quality organization which I
l 9
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. 16
, . ' derives.its acceptance criteria from specifications which govern the fieldLfabrication and erection of ASME components. These specifications are independent of the referenced -WQ-2.
Therefore, although these allegations have been substantiated, we recom-send that this item be corrected by Bechtel Power Corporation and then closed without further action.
Allegation 25:
"I believe that the caliber of individuals employed by Peabody Testing to perform nondestructive examination (NDE) on welds in nuclear service applications was not acceptable. This belief Lis based on the observation of many spelling errors, ... ."
4
. Response:
Allegations 25 and 53 (page 21) - Since Peabody was an NDE contractor at the Midland site under the name of G.E.0. Construction Testing as well as Peabody, we examined (by random selection) the following G.E.0. Construc-tion Testing, Certified Report of Nondestructive Examination (Form 112-6843). The following reports covered dye penetrant examinations:
Examiner Date Weld No.
Donna A. Dorsey 3/11/82 PW100 FSKri-ICCB-45-3-24 3/11/82 PW100 FSKH-ICCB-45-3-31 3/5/82 PW100 FSKM-ICCB-45-3-32 3/5/82 PW100 FSKM-ICCB-45-3-33
, 3/5/82 PW100 FSKM-ICCB-45-3-34 Steven Bonnell 3/2/82 PW100 FSKM-ICCB-45-3-35 3/4/82 PW100 FSKM-ICCB-45-3-36 3/4/82 PW100 FSKM-ICCB-45-3-37 Donna A. Dorsey 3/4/82 PW100 FSKM-ICCB-45-3-38 l 3/4/82 PW100 FSKH-ICCB-45-3-39 ,
3/4/82 PW100 FSKH-ICCB-45-3-40 l 3/4/82 PW100 FSKM-ICCB-45-3-41 1 3/4/82 PW100 FSKH-ICCB-45-3-42 3/4/82 PW100 FSKH-ICCB-45-3-43 1
3/4/82 PW100 FSKH-ICCB-45-3-44 H. D. Lyles 5/3/82 PW100 FSKM-ICCB-54-2-H1 Craig C. Tapani 3/23/82 PW100 FSKH-ICCB-54-2-H3
, Brain Hanni 4/6/82 PW100 FSKM-ICCB-54-2-22C1 l David K. Waun 9/29/82 PW100 FSKM-ICCB-54-2-22C3 i
No spelling errors were noted on any of the reports reviewed and, each i report had been checked and signed by a Bechtel Level II NDE examiner.
The following Peabody Testing Radiography Reports (Form 102E) were also reviewed:
l l
. . - ~ . . . . - - . - - .. - . - -.- - - __ _ _ _ _ _ - _ - - - _ _
h 6 f 17 i
. . Examiner Date Weld No.
i Cary Smoot 8/7/78 2 HCB M614 SH3 TW 10 R1 W. M. Pardee - Bechtel 8/8/78 Cary Smoot. _ 7/20/78 2 HCB M614 SH3 FW 10 W. M. Pardee - Bechtel 7/21/78 C. W. Stoughton 5/29/79 2 HCB M614 SH3 FW 53
. E. R. Stankiewicz - Bechtel 5/29/79 R. Cook .. -6/28/79 2 HCB M614 SH3 Mi 8 E. R. Stankiewicz - Bechtel 6/28/79 Each of the radiographs listed above were reviewed by Bechtel NDE per-sonnel as indicated with results recorded on a Radiographic Review Form
} (BBS10844).
No spelling errors (or other errors) were noted on these reports.
The qualification records of all the Peabody (GEO) personnel listed
- above were reviewed and, it was determined that each examiner was a Level II qualified by examination to ASNT-TC-1A. Die qualifications i were certified by a Level III' examiner (also to ASNT-TC-1A) in the j
appropriate discipline as follows:
Examiner Discipline Level - Date Bonnell . Penetrant 2 - 7/24/81 Lyles Penetrant 2 - 4/2/81 Dorsey Penetrant 2 - 9/8/81 Tapani Penetrant 2 - 1/27/82
- Hanni Penetrant 2 - 11/12/81 Waun Penetrant 2 - 7/14/81 Smoot Radiography 2 - 7/12/77 1
Cook Radiography 2 - 2/16/79 Staughton Radiography 2 - 3/20/79
- No items of noncompliance were identified during the review. Therefore, these allegations have not been substantiated and we recommend the items i be closed without further action.
Allegation 26:
I i "I believe that established industry standards regarding the qualifica- !
l tion of NDE personnel are not sufficient to assure an adequate level of personnel capability and knowledge in this very important area of in-spection."
Re sponse:
j Allegations 26 and 46 (page 21) - The Nondestructive Examination (NDE)
- qualification program established by Bechtel Corporation for the Midland project requires that personnel be qualified in accordance with ASNT-TC-
.lA. There are no age requirements established in ASNT-TC-1A although i there are very specific education, employment, vision, general and I
, specific verbal and written test requirements.
i
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I
. . 18
.These requirements are extensive and, are recognized throughout industry-as an acceptable qualification standard for NDE personnel. The qualifi-cation records for eleven NDE inspectors at the Midland site were exam- 2 ined for. compliance with the requirements of ASNT-TC-1A. These records
' of inspector qualifications were selected at random from the years ,1979 l thru 1982 and, no items of noncompliance were found. All inspectors had been qualified in their respective discipline.
' Additionally, the training records for . two QC . Inspectors were examined.
It was found that :he inspectors had received training in those specifi-cations, procedures (as they were revised) and test ~ methods within their '
area of responsit'.lity. Therefore, we conclude that this allegation is ,
not' substantiate. and recommend this item be closed without further action or investigation.
4 A11eestion 28:
4 i "It is alleged that Bechtel designers used only fillet welds on web-to-web connections of beams and pipe supports and tray hangers and did not weld all around to restrain forces in all directions. A11eger also j
questions seismic loading calculations and. feels that there is no actual j test on welds under seismic conditions. A11eger states also that AWS i
1 D1.1 demands and returns on fillet welds and these were lacking in many places."
j Response:
4 i
' Allegations 28, 44 (page 20), and 51. (page 21) - These three allegations are identical and are considered to apply to the Midland plants since
~ the alleger does not identify specific locations. The allegations have their origin with the Structural Welding Code, AWS D1 1 (para. 8.8) 'and, our review reveals that this Code does not require or demand "and re-t
- turns" (also known as boxing) of side or~ end fillet velds. The termi-nology used in AWS Dl.1 is "wherever practicable" and therefore an ele-ment of engineering judgement is implied rather than the establishment of a mandatory requirement. Should the Engineer decide to use "end re-turns" or " boxing of side or end fillet welds, the AWS D1.1 code re-quires that this be indicated on the drawings. Due to the lack of available time while at the site, BNL was unable to verify the use of
- "and returns" and, whether they were specified on the drawings when they were, in fact, used.
t Allegation 29:
1
)
It was stated that ASME code requires adequate root penetration of fil-let welds and states that vendor-supplied equipment did not always con-j form to this requirement. Specifies Zack Co."
4 Rii~iiFonse:
As a result of our investigation, it was determined that the vendor j ,
identified as "Zack Co." did not, and was not, under contract to supply 1 1
any equipment, components, parts, materials or appurtenances of any type in which the ASME Code was the Code of design, fabrication or installa- t j tion at the Midland site. An examination of the "Zack Co." purchase t
e c c. . - , c-.-----we-r --..,--,--w 4 y r-ra-- - - - - - - - - - - --- ,,e, y , .-- . - . , - , - - - - - - - ..m. .,.%--. me - ,
19
, , contract revealed that this vendors. responsibilities were limited to the fabrication and installation of Heating, Ventilation and Air Condition-ing (HVAC) equipment. These. fabrication and installation activities are governed by codes and standards unrelated to the ASME Boiler and Pres-sure Vessel Code.
This allegation is not substantiated and we recommend closure of this item without further investigation.
Allegation 30:
"It was stated that A-7 rim steel may have been used in critical appli-cations on SONGS.
Response
Although this item was not specific to the Nddland Plants, BNL personnel verified that the referenced material (ASTM A-7) had not been procured i
for use at Midland in safety related applications or in safety related structures.
1 A comprehensive review was performed on the following specifications:
A. 7220-C-233(Q) Rev. 24 and prior revisions - Technical Specification for Purchase of fuscellaneous Metal.
B. 7220-C-36 Rev. 0 (initial issue and subsequent revisions) - Techni-cal Sp~ecification for Furnishing, Detailing, Fabrication, Delivery *
, and Erection of Structural Steel.
These specifications were found to specifically identify by standard that ASTM A-36 was to be procured for the structural applications. We note that ASTM Standard A-7 was discontinued in 1957, and replaced by Standard A-283 and A-306 with A-36 being added in 1973.
I Additionally, the following Bechtel field purchase orders were selected at random (from the very early years of the project) to verify that structural steel for "O" (quality) had been purchased to meet the re-
- quirements of Standard A-36.
Purchase Order Material Size Quantity F28141 (6442) 3"x2"x3/8"x40' 200 ft. - channel F17797 (2575) 2'x2'x3/16" 10 pes. - plate F33818 (8365) 2"x2"x1/8" 100 ft. - channel M106AC (4158) - 1977 4"x4"x1/2" 100 ft. - channel F19512 (3090) - 1977 7'x12'x3/8" 4 pes. - plate F3134 (8467) 6'x6'x1 3/8" 4 pes. plate M106AC (4185) - 1977 2'x20'x1/4" 5 pes. plate All items were identified as ASTM A-36.
1 4
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. 20 All.egation 31:
"A11eger questions the code adequacy of Bechtel's procedures regarding E7018 electrode out of oven time."
l Response: j l
See response to Allegation 13 on pg.13. ;
. Allegation 33:
! "It is stated tha' reinforcements of groove welds on Bechtel from WQ2, Sheet 20, differ from ASME code requirements."
Response
See response to Allegation 24 on pg.15.
Allegation 41:
"A11eger states that runoff plates were not used on structural members."
Response
A resolution to this allegation was not pursued during our visit to the
. Midland site due to time constraints. However, based on our past exper-t ience at numerous other Nuclear construction sites, there is a very high probability that this statement is true. We also offer the following:
~
- 1. De code of origin is AWS D1.1 (para. 3.12) and the use of un-off plates is not a requirement of this code. Additionally, their use is not a requirement of any other code, standard or guide that we are aware of.
- 2. De use of run-off plates is considered good welding practice when i using welding processes which utilize extremely high rates of heat I input (submerged arc, electroslag, etc.) and where weld termination
- does not lend itself to the level of control which can be exercised
, with manual processes. He welding processes utilized at Midland l for joining structural members (shielded metal arc, flux-cored and i gas tungsten are) lend themselves to a very high level of control by the welder. His level of control is such that run%ff plates are
! rarely necessary with no compromise of weld quality at the termina-i tion of the joint.
We believe further action regarding this allegation to be unneces- '
sary and, no nencompliance exists.
Allegation 44:
"A11eger states that many examples of non-existent end returns on welds l are at SONGS, Palisades, and Midland."
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, Response:
See respone to Allegation 28 on pg. 18.
Allegation 46:
"A11eger expresses the concern that many young people were inspecting welds with no real knowledge of welding."
Response
See response to .511egation 26 on pg. 17.
Allegation 51:
4 "A11eger contends that end returns are not specified on Bechtel Power Corporation detail drawings in violation of AWS D1.1, para. 8.8.6, 8.8.6.1 and 8.8.6.2."
Response
See response to Allegation 28 on pg. 18.
Allegation 53:
"The alleger was concerned that since there were many spelling errors .on nondestructive test reports by Peabody Testing that the examinations performed by these people may be questionable."
. Response:
See Allegation 25 on pg.16.
Allegation 54:
"Hain steam pipe just outside of containment before first relief valve had weld with unacceptable concavity."
Response
Specific welds were not identified by the alleger therefore, two welds in main steam piping outside of primary containment and before the first relief valve were selected for examination with attention to the weld profile (specifically, concavity). The welds examined were:
- 1. 632 - SH2 FW1
Allegation 55:
"Some pipe hangers of questionable construction," (no welding on hanger flanges)."
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-. Response:
A review of a memo .from Perry to Sanders, dated June 20,-1984, Subject -
- Midland Energy Center Project Technical Trending of HRP Activities was l
- made for this allegation. The document reviewed was a Technical Evalua- ;
tion of the hanger reinspection program nonconformance reports for the ,
' Midland site which_ stated in part that "... At ~t he time-that the NCRs I utilized by this report were generated, the " rate of rejection" of in-spected . pipe suppe-ts was 90%, i.e., 9 out of 10 pipe supports were found to have one ar more rejectable attributes, thus the 445 NCRs uti-lized for this report' represent:approximately. 500 (445/.9) inspected supports ..."- [page 3, Section 3.1, third paragraph]. Additionally, Section 3.2 Significance of Data, subparagraph 1. Weld Deviations states "The family.of weld deviations comprises. 47% of all significant;devia-
- tions. In addition, weld deviations represent 41% of all identified de- l
. viations. ' ThisHis the largest contribution of any deviation family." ,
[page 3] Even though more than half of these deviations could be~
' accepted "as is" by an engineering evaluation, an approximately 50% ini-
. tial reject is sufficient cause for the allegation .to be considered sub- l stantiated. However the reinspection programs established by the licen- l see should have identified the hanger deficiencies had the plant not i been shut down.
l Alleestion 56:
l
" Deficient socket velds could be found in'"0" piping in lowest level. of the auxiliary building."
Response
~
No specific identification was provided for these socket welds. Due to the va5ueness of this. allegation, a random selection of socket welds in ]
"0" piping was made in the lowest level of the auxiliary building. :The-following welds were visually inspected- for required size and profile-
- 1. 1HCB-4-1 FW9 l
- 2. 1ECB-4-1 FW10 I
- 3. 1(CB-36-1 FW23 l
- 4. 1GCB-36-1 FW24 H
- 5. 1GCB-36-1 FW25 l
- 6. 1GC5-36-1 FW41
- 7. 1GCB-36-1 FW40
- 8. 1GCB-36-1 FW42 1
- 11. 1GCB-36-1 FW47-
- 12. 1HCB-270-1 FW43
- 13. 1HCB-270-1 FW45
~ 14. FSKM-610-4-20 FW2
- 15. FSEM-610-4-16 FW1
- 17. ICCB-36-2 FW6 )
- 18. 1GCB-36-2 FW7
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- 19. 1GCB-36-2 FW9
- 20. ICC3-36-2 FW10
- 21. 1HCB-16-612--3-2 FW35 (Top off valve'TN 3-3)
No nonconforming conditions' vere identified..
Allegation 57:
! " Welds #89, 90, 9: on drawing FSK-M-1HBC-58-2 (service H 2 O) lines being the worst."
' Response:
.Three welds were' specifically identified in- this ~ allegation by drawing and field weld number (FW89, 90 and 91 on Drawing FSK-M-1HBC-58-2).
These three welds were located.and visually inspected for required size and profile. The weld size and profile were found to be acceptable
~
although'a rejectable are strike crater was identified on FW91. The allegation that these three welds constituted a " worst" case was not
. substantiated by the inspection results.
Allegation 58:
"Bechtel spec. for argon purge allowing 104 cfm Ar (he feels .too much flow rate latitude), does not require checking dew point on Ar used for purges."
Resoonse:
- The reference in this allegation to "104 cfm" for' purge gas.is believed-to be in error. The volume of purge gas specified on the most commonly used Bechtel weld procedure specification (WPS) for the joining of stainless steels (no purge is required for carbon steels) is 1 to 40 4
efm. ' This volume-is specified on WPS P8-AT-Ag for veld root closure and
~
! the second pass (which is optional).
4 The flow rate permitted provides a generous range for a number of valid technical reasons. Among them are:
- 1. These procedures are useable on all pipe diameters. This range is extensive and would cover every diameter from 2" to 20'.
- 2. The use of purge dans would greatly affect-the volume of purge gas.
- 3. The inability (in certain welds) to use a purge dam or, the ability to " dam" only one end of the system or pipe.
i
- 4. Amount of turbulence in the immediate area.
Also, the rate of purge flow (and its use) is not an essential variable of ASME 1X. The use of a purge gas and its control within a narrow range is not essential to the completion.of the weld with the achieve-
~
, ment of a high degree of quality. More importantly, the percent of oxy-q gen in the exiting gas is the true measure' of whether one has provided
i J .' 24
, .- the necessary degree of protection for root closure. When the purge is
+
initially introduced, the flow rates would be exceedingly high for large diameter pipe but, would be reduced as the argon displaced the air and, oxygen content was reduced to low levels (usually 1 1/2 to 2%). ~At this time, the ' flow- rate would- be reduced to a level which would maintain this low oxygen content. The bechtel corporation WPS and the General Purge Specification'(CPS-1, Rev. 4) provides for the testing of exit gas-to assure the purge is effective.
he range specifie is not abnormal for the welding variables encounter-ed in the use of this procedure. No item of non-compliance has been
- identified and further investigation of this allegation not recommended.
, Allegation 59:
i
" Undersized welds had been accepted by. Morris and his qualification l revoked."
i Resoonse:
4 Items reviewed in the investigation of this allegation include:
- 1. Bechtel Thermal Power Organization Construction Quality Control Training Record - for Morris, A.' C. (4/13/81).
- 2. Bechtel Thermal Power Organization Construction Quality Control Edu-cation and Experience Resume - for Morris, A. C., 7/21/81.
. 3. Bechtel Thermal Power Organization Construction Ouality Control-Physical Examination Record - for Morris, A. C., 5/19/81.
- 4. Bechtel Thermal Power Organization Construction Quality control- Cer-tificates of Qualification for Morris, A. C.,l(3), 1/29/83.
Os Bechtel Nonconformance Report No.' 4084,.3/18/82.
- 6. Bechtel Power Corporation memo to QC File from Fredianelli, D. L.
(LWOCE) and Creel, W. J. (LPMOCE), 3/12/82.
The- referenced memo (6) stated in part "Following the rescission of A.
Morris' certification on 1/19/82, an ongoing overinspection of his work 1
. prior to decertification-has identified many undersized weld...". The final results of this overinspection were documented in Nonconformance Report No. 4084 (5). The reference memo (6) also documented an inspec-
- i. tion of 5. socket welds per 'esch Construction Quality Control Engineer COCE to determine if a generic problem existed at the line'of the inci-dent. . The memo' stated that no generic problem existed at Midland. This inspection does lend support to the ' conclusion that OC inspections did have an adequate knowledge of fillet weld sizing 'and weld _ gage use. See allegation 60, pg. 33. We conclude that this allegation is substanti-ated but, is of no technical significance. Information provided within j the referenced documents reveals that the condition was identified by the constructor -(not the alleger) and, once ' discovered, the constructor undertook appropriate actions to assess the extent'of the condition and' l
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establish corrective measures. This action'p 5vides confidence in the effectiveness of;the quality program at the: Midland site. We recommend !
this-item be closed without further action.
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, .
- CATEGORY D '
Procedures / Specifications Fail to' Comply With Code (ASME) or, are Inadequate i- The allegations assigned to this category are too generalized for a mean-ingful response to be developed as a -result of the time available for investi-
.gation. .No item was defined or specifically identified such that a source
~ document or activity cou;d be directly examined for. code or _ regulatory compli-ance. .However,.a response to a generalized and vague allegation can be
- developed by the review of a selection of safety related components, items..
structures and systems- rom their specification stage through erection or in-sta11ation. This would necessarily be a broad scale effort.
Allegation 2:
"Bechtel Corporation' has systematically downgraded standards for safety-related equipment to the point where I believe that much of the con-struction will not withstand the stresses it should be built to take.
j Allegation 6:
- I was astonished to see that in numerous places, Bechtel has estab-lished standards which . fell below those of the ASME Code."
( Allegation 7:
"Despite this, Bechtel in some cases made the decision, based on their own engineers' opinions or short-term testing in San Francisco, to modi-fy these standards."
Allegation 8:
"But in the area of welding, where I was qualified to judge, the new specifications were inadequate to the needs of a nuclear facility." ~
Allegation 34:
i "Pg.133, para.1 - It is stated that Bechtel welding procedures leave a
- lot to be desired." ;
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, , CATECORY E Allegation Not Site Specific or Too General - Dismissed Allegations 12, 35, 37, 38, 39, 45, 47, 49 and 52 were not specific to the Midland Plants and therefore, were not addressed during the site visit.
Also, included in this category are those allegations which do not warrant further action due to their vague and. subjective nature.
Allegation 1:
"It is my profes= tonal opinion that the Nddland plant is the worst nuclear facility have ever seen."
Response
A response cannot be provided to this allegation because of its broad and subjective nature. We find this allegation is not substantiated as made and recommend no further action or investigation.
Allegation 5:
"I will also give examples of the unhealthy degree of reliance that cer-tain NRC inspectors have placed in the Bechtel personnel whom they are supposed to monitor. ... the inspection reports that were supposed to represent a completely separate check on Bechtel. performance often wound up basing their approval on Bechtel's evaluations of its own work."
Response
A complete review of all af fidavits, statements and records of inter-views with the alleger was made by BNL and no specific " examples" could be identified. Therefore, this allegation is not substantiated by fac-tual data and investigation by BNL was not carried further. I 1
Allegation 12:
l "Although the OC reports appear to assure that the piping is of safety-grade quality, these reports fail to reflect the problems of the piping l systems which I discovered (i.e., severely corroded pipe is approved for l safety-related systems)." l
Response
This allegation was not made specifically at the Midlend Plants but, was applicable to the Palisades facility.
l Allegation 18:
i 1
"Never in my life have I ever seen so many critical welds accepted in !
nuclear work and then found to be unacceptable."
0
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.a- f 28
, Response:
A response to this allegacion cannot be provided due to its broad and
, general nature.
Allegation 21:
"After nearly twenty years of work as an engineer and welding authority, I know a deficient veld when I see one, and I know many of these welds and other problems went undetected (or ignored) by the men responsible for inspecting them."
Response
This allegation could not be addressed'due to its lack of specificity.
, An allegation of such a broad and general nature could only be addressed in a large scale re-inspection of the welding activity. We believe that -
were the "nuality Verification" portion of the " Construction Completion Program" (CCP) to be accomplished, the results would form the basis to refute or substantiate this allegation. We recommend this item be closed without further action. .
Allegation 22:
"Bechtel has shown by its attitude that it cannot be trusted to perform work of the high quality necessary in a nuclear plant."
Response
I A response to this allegation cannot be provided due to its broad and un-defined nature. We recommend this item be closed without-further action or investigation.
Allegation 23:
J "The ASME Code requires adequate root penetration of. fillet velds. I ;
recall that some of the vendor-supplied welded hardware appeared to not have adequate root penetration. I recommended that the NRC examine the l beginning and end of fillet welds ~ to assure root penetration at these- '
areas and verify that all craters are filled, and conduct destructive testing of selected supports-supplied by this v'endor to determine if other fillet welds and groove welds have adequate ' root penetration or other code violations.
4 i Response:
BNL technical specialists were unable to conduct an indepth investiga-tion of this allegation due to the lack of identification of the equip-ment or vendor involved. From the wording of the allegation, it appears that it may'be directed at a support of some type (pipe, electrical, cable tray or HVAC ducting and/or equipment). . Also, we were unable to l deduce (from the statement) whether this allegation applied specifically to Midland or, the San Onof re plant. We believe an adequate investigs-tion could be conducted if further (more specific) information were l
l I
29
. . provided regarding the equipment or vendor. Otherwise, attempts to pro-vide a meaningful response would be futile. We recommend this item be closed unless and until further information becomes available.
Allegation 35:
" Alleger stated that transition welds at Palisades were seen which did not meet the weld transition requirements in ASME."
Response
This allegation i not site specific to Midland therefore, no response is provided. Al . the allegation is such that it does not lend itself-to generic consiceration based on the particular practices of the Architect / Engineer.
Allegation 37:
"A11eger describes inadequate throat thickness in welds at SONGS."
Response
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the particular practices of the Architect / Engineer.
Allegation 38:
" Alleger mentions the inadequate levels and weld transitions; mentions Palisades."
Response
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the particular practices of the Architect / Engineer.
d Allegation 39:
" Alleger discusses a 92-page Bechtel non-conformance report on electri-cal cable trays on SONGS."
s Response: !
Although this allegation was site specific to SONGS, BNL believed the problem was potentially generic and undertook to evaluate it further as l applies to the Midland plants. During our visit to Midland, BNL deter- I mined that the Nonconformance report in question (NCR E-1941) was evalu-ated by Bechtel Corporation as a " potential problem" on Deficiency Eval-uation Report No. 69 (11/4/80) for the Midland site. The evaluation concluded that the Midland site was not subject to the problem which 4
.. 30 originated at SONGS. We terminated our investigation of this allegation
.-* .~ after our review of the evaluation report. The allegation was not con-sidered to be applicable to the Midland plants.
Allegation'40:
4
' "A11eger discusses the qualifications of '"Hilti-type" studs and a stud that failed in a brittle manner."
Response
1 We were unable to further define the nature of this allegation. Since the statement (s) made do not identify or constitute a nonconforming con-dition we recommend this item be closed without further action or inves-tigation. l Allegation 45:~
"A11eger states extensive pitting on pipe at Palisades was seen."
Response
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend -itself-to generic consideration based on the particular practices of the Architect / Engineer.
Allegation 47:
" Alleger expressed concern that there were bolts at SONGS which were not torqued down with several threads appearing above the nut, specific to anchor bolts."
Response
This allegation is not site specific to Hidland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the particular practices of the Architect / Engineer.
Allegation 49:
"A11eger elaborates on a spacer being installed on a SONGS 1 hydrogen '
line."
Response
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the particular practices of the Architect / Engineer.
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Allegation 52:
" Alleger stated that a spacer plate was missing on an upper inside hinge on SONGS Unit 2."
Response
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the particular practices of the Architect / Engineer.
Alleration 61: ,
" March 22 memo of Foster, pg. 2, last paragraph - all welds onsite should be reinspected."
Pesconse:
A response to this allegation cannot be provided due to its broad and un-defined nature. We recommend this item be closed without further action or investigation.
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- o. ' '33 CATECORY F I
_. o*
Additional Work / Investigation Required
.The following allegations, although~ considered by BNL to be broad,-sub-jective and general are such that a meaningful response could be provided when based on an analysis of results obtained from a specific. inspection plan or effort. This effort was not made due to the obvious' magnitude involved. It-is entirely possible that a response can be provided which will be based on
, the data obtained during_overinspection, corrective action and/cr other qual-l ity verification plans and programs which have been (or will be) accomplished at the Midland plants.
A11eration 4:
4 "I have seen Bechtel personnel, both OC inspectors and engineers with QC responsibilities, routinely accept sub-standard work."
Response
We presume the alleger is referring to weld related items. Lacking fur-4- ther definition, our recommended approach is as stated above unless spe-cific cases or details can be identified.
Alleration 11:
s "Because of this, I was very concerned to discover that many welds in the
- piping had been improperly ground down, grinding down the pipe wall thickness along with it."
Response
See response to allegation 11 on page 10. This allegation was not substantiated.
Allegation 27: ,
i i
- "It is alleged that pipefitters used pipe cutters to place scribe marks '!
on socket weld fitup sessurements." i Response: l I
j This allegation was site specific to the San Onofre nuclear plant and I therefore, was not pursued further at Midland. If the allegation is con-sidered to be a generic concern (with the alleged practice to have also taken place at the Midland plant) its resolution can be accomplished by the development and implementation of an inspection plant for examination of socket welds for evidence of " pipe cutter" use for placing scribe marks.
A11ecation 36: _
l "P.139, para. 4 - A11eger states that at Midland undersized fillet welds j were documented as acceptable." '
4 l,
e 33
,Rdtpense:
See response to Allegation 4 on pg. 32.
Allegation 43:
"Pg. 223, para. 2 - A11eger states that in Region III plants inspectors documented undersized fillet welds as being full sized socket welds when they were not."
Response
See response to Allegation 4 on pg. 32.
A11eration 60:
"Both Midland and Region III inspector did . not know how to use a fillet veld gauge properly."
l Resoonse:
A sample examination of fillet welds would refute or substantiate this allegation. If we presume that unf amiliarity with the use of the fillet gauge was widespread, the data accumulated would If substantiate.the alle-unfamiliarity with j- gation by high reject rates upon reinspection.
' the use of the gauge were minor or localized, a sample (regardless of its size) could refute the allegation. Additionally, see response to allegation 53 on page 21.
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