ML20237G396
| ML20237G396 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/12/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20237G338 | List: |
| References | |
| FOIA-84-744 NUDOCS 8708140053 | |
| Download: ML20237G396 (60) | |
Text
ITG j/C7
- 1/12/84
[ Tape starts in middle of a sentence] .
...ask that if you did get a' hold of my either DCM logs or dailies or any kind of documentation would you be willing to provide me with copies of that?
INTERVIEWEE: I'm afraid that I can't do that because those
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were given to the Nuclear Regulatory Commission as part of the licensee's obligation to provide us whatever documentation we I
feel is necessary, if in.the conduct of our investigation or inspection. It does not ... I'm bound, as I see it, by my integrity to them, and with that understanding to maintain those i documents in.my possession.
INTERVIEWER: Did you catch Frank Layoti's statement that Steve had quit when he was talking to you and we were in the '
office that afternoon?
INTERVIEWEE: I don't particularly care what the individual said one way or-the other, it doesn't make a whole lot of
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difference to me.
INTERVIEWER: Yeah, I just, I take that.... '
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INTERVIEWEE: Well, I don't see that it's material one way
'or another.
f NEW INTERVIEWER: It would be a false statement to a Federal ,
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~z Investigator, subject to the same penalties as perjury.
$x0 INTERVIEWER: Lou, would you care to address that?
SSE LOU: I missed the upshot of the entire comment.
p Information in this record was deleted
-CI 4- in accordancewith th re m ofpformatich k k Q I 'l-12 1 g *
/ i Foi A .8 97M/ %8 9 a-
INTERVIEWER: you can, if you care to, put that in context.
INTERVIEWER: Frank Layoti is our Assistant 'QATC. Manager.
When Dennis asked for our records on Friday past, Frank Lavoti was standing there and when he started asking about Steve's records, Frank Layoti specifically said that the man cuit and when .the man quit he initialed and dated all the ... all his documentation that he left. But I just wanted to get that across, that Frank Layoti told Dennis that the man quit rather than that he was terminated for being out of his area according i to-them. What I'd like to talk about tonight...
KIRSH: Just a moment. The time is 8:24 p.m., the date January 12, 1984. Present with the Nuclear Regulatory Commission are Lou Schoenberger, Regional Attorney - Region 5; Gonzalo Hernandez, a Reactor Inspector in Region 5. My name is Dennis
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Kirsh, I'm with Region 5. Mr. John Clewett, lawyer from Government Accountability Project, Mr. hanemployeeof Pullman Power Products no a concerned citizen, and Mr. Steve Lockert, an ex-employee of Pullman Power Products and again a concerned citizen. For the convenience .of the transcriber would each of you please state your name so that the transcriber will l i
be able to recognize who is speaking. j CLEWETT: My name is John Clewett, I'm working with the Government Accountability # Project from Washington, D.C.
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)Mynameisi 'm a Pullman QC Inspector
- - g at Diablo Canyon. I i
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LOCKERT: My name is Steve Lockert and I'm the former PC Inspector for Pullman.
DENNIS KIRSH: My name is Dennis Kirsh. .
HERNANDEZ: My name is Gonzalo Hernandez, I'm a Reactor I nspec tor .
SCHOLENBERGER: And I'm Lou Scholenberger.
KIRSH: Okay, you have quite a pile of documents in f ront of you, ould you please go through what kind of documents and what kind of a ' concern each of these documento is purported to address.
Okay. I have provided you copies of my complete set of inspec/ tion daily records for your comparison to whatever copies you received from Pullman Power Products. I am concer ed that Pullman may not have included dailies that I have filed on the issue concerning intimidation and harassment of Inspectors in the field.
CLEWETT(?): Can I assist you?
. N Sure, why don' t you sit down, okay. This is a the first one. - hall I just list them as Attachment 1 or as 1
numerically listed?
KIRSH: You want to just go through them all or would you like to discuss each one?
?: Oh, whatever you feel...
7: ...give a rough cut of how many documents, which piles are which thing so that we have an overview or an outline of what's coming. ,
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i Okay, we've got basically as dailies here are my I records and' things that have happened to me up to this point. A good deal of these are supporting documentation concerning packages that show the.... What I'm gonna try and shbw tonight is the lack of adequate training for inspectors, craf t and engineering out there. I'm gonna talk about harassment and intimidation of inspectors by not only craf t supervision, but also DC Supervision and I'd finally like to end it on welding procedures and performance qualifications and the non-compliance thereof with the codes that they are stated in the contract specifications to adhere to. On that issue I'd like to just start out with a certain package here that is titled "Hancar 249R". This is on the diesel fuel oil system, System 21.
KIRSH: Where's that one at in this document that you gave us?j -
Sir, it would be one of these on file here.
['KI RSH: Let's see, what do we got here.
Sorry that these aren' t better organized.
KIRSH: I would be pleased to receive all of this, but I'm finding a bit of dif ficulty piecing it all together. Is there any way that we can meet at another time af ter things are more collated with issues that each of the documents represents, appropriately identified. .
I think actually maybe they appear more disorganized' right now than it is. Ma: we could go off the tape for five minutes and see if that recess would get things organized enough that we can proceed expeditiously. Does that
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sound reasonable? I'm concerned that we want to furnish you with information as promptly as possible because I know that you are in the midst of an investigation and I want to get material to you as promptly as possible, and I think we can do that in a way that will be understandable.
KIRSH: All right, we'll do that, let's go of f tape then.
1 7: The time is 8:30.
KIRSH: We'll look at "249-R".
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) This is in reference to my daily inspection
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report. It started on....
KIRSH: I suggest we 10 of f tape again for a time until we find all of this and that way we'll conserve tape; I've only got two hours left here.
7: The time is 8:34.
pIRSH: ,The time is 8:40, back on tap'e .
What I'd like to talk about that's one of my major
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concerns at this time, I'm gonna address this report tomorrow, it has to do with the use of unqualified materials and unqualified welding procedures at Diablo Canyon. This concerns studs, welded studs used on Systems 14, System 12, System 10, System 9, System 8, System 7, System 6, both Units 1 and 2. The unqualified materials are the use of A307 and A325 bolts as weld studs and the use of unqualified materials A108 and A307. I have .
documentation here that I'm able to provide you with partial copies. I can give you complete copies of what I have here and you can examine this, showing where Pullman Engineering has approved and production has used bolts ordered; I have copies of N
k-12-84-5
purchase orders and typical copies of field warehouse requisitions where bolts were ordered out of the warehouse, the heads were cut of f the bolts, and they were used as studs attaching to the containment liner on System 12 and the various parts of hangers on the other systems.
The problem we have here is that none of these materials is ,
qualified by either of the codes that we' re using out there.
I've seen cases, hanger weldings reference to ASME Section 9, the containment liner studs, in some cases are referenced to AWSD 113 qualifying procedures, and either case, the materials are not, in the case of AWS, pre-aualified, and in the case of ASME they are not listed as applicable materials for the welding procedures that are being used. The procedures they are using are Well Procedure 7A and Well Procedure .,203, which are qualified for P1 materials, which are basically l'ow carbon steels with less than
.30 carbon content.
ASQMA 325 especially concerns me because it's a high-strength bolt that they use . .. t, hey have a carbon content in that bolt that goes anywhere f rom .30 to .45. With that carbon content you have to be preheating things before you weld them, and you also have to have a qualified welding procedure to use that material, attaching it to a P1 material. As you can see from those, there is quite a few cases there where bolts were Issued, the bolt head was cut off and was used as a welded stud.
,KI RSH is And this picture shows the chiseling and the. ...
They are chisel pointing it now, that's another thin \g' . .. where the ASME qualified welding procedures, that is l j
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s not approved on the welding procedures specifications as beino an allowable deviation f rom that procedure, and the ASME (pardon me, that's ASME that we're talking about), and AWS pre qualified welding procedures, ' number 1, you have to write a wel, ding procedure specification that shows that joint design'you're going _
to use in production, Pullman has not done that with this joint design right'here, And number 2, it's not listed as . . . anyone of these materials are not listed as pre-qualifled materials for i
use with ANS pre-qualified velding procedure.s, so they would have to qualify welding procedure and have a welding procedure qualification record.
KIRSH: If I r'emember correctly you discussed this issue quite- at length in our last talk. ,
We discussed it in relation to the containment ,
spra'y ring wh'ich at that time I.was only aware of its use there. Since then I've become aware of it's use on the other systems that we've described: System 6, 7 , 8 , 9 , 10, 12 and 14.
KIRSH: Were they attached to the contain..?
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Well, we're not.... System 12 attaches to the conta nmen' I don' t know the exact locations but f rom the warehouse requisition we could look at the hangers and see where they were attached to members cf~the hangers or whatever they attached them to. ,
7: We also have another unqualified material. The material is ... ASTM A325 high strength carbon steel bolts.
KIRSE' I believe that already discussed that v
as an unqualified material in accordance ith AWS.
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7: Yeah, but you were asking . . . you were saying that we already talked about this last time.
KIRSH: Understand that, yes. Last time we dise,ussed A307 in 1, Leu of A108. ;
4 Yeah, A108 is a low carbon steel and from ASME requirements, it approximately meets the chemistry of a P1 material. I'm not as concerned with the welding of A108 as I am with A307 and A325. It's not good engineering practice from a we'1 ding standpoint to take something that comes in on a bolt specification ... in the case of A307, it comes in on a specification that requires, in the specification, no vendor heat traceability of the material, and no upper limit on carbon. The upper limit on carbon in A325 is beyond the limits of unqualified weldability. You definitely should be preheating the material with thosel kind of carbon contents. I think this points up a general lack of understanding by the Engineering Department as to what actually happens when you are welding and a very poor choice of materials for this application.
I CLEWETT__ they're not preheating this material?
/ N To my knowledge, they don' t preheat it. In the welding proc'edure specifications that they' re using to weld it, there's no preheat requirement.
CLEWETT: There's nothing in any other procedure that would be applicable?
\ No, not to nly knowledge. To my knowledge, they do not preheat hese materials.
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CLEWETT just for the tape, the package that yoc were
, s referring to you, which is held by Dennis, is a package of 27 pages, the first of which is numbered 1 in the upper lef t hand corner.. The first page has a drawing of a bolt, is that
?
No, that, all of these are copies from the Pullman Steel Warehouse requisitions that I have come across in my search as a OA, basically as a OA troubleshooter for the OA Piping De par tment.
CLEWETT If I could I'd like I,o touch on what's going on in the QA Department out there right now.
?: Okay, just for a second, have you seen the welding ongoing or what is there that leads you to have the concern, in addition to the papers that you've seen.
, My concern is from the material and from knowina what happens when you weld this kind of material, and knowing the codes that you're supposed to be welding it to. I have not seen this welding. Now, the way . . .
?: - ?
No. The way that I've come across this is, what's happening in 04, this copy that you see here is copied from the warehouse copy, which is the yellow copy of a 3-copy form. The light copy original goes to the QA Department as soon as this material is QA-approved, which requires this signature down here. You'll notice on . . . I don' t know, some of these do and '
some don' t have a OA signature. All Class 1 material requires a 04 signature down at the bottom of that. What's happening now is I'm going out . .. QA, when they complete their piping isometric l-12 9
drawing review, they have to include in that package all of the original copies of the field warehouse requisitions for the material in that package. Without those copies, you've got a breakdown in your QA program, which means you may not;have the traceability that you' re required to have. Now, my function right now is to go out ... when the 04 auditor that looks over the package here cannot find a copy of the warehouse requisition for whatever reason, the original copy, I go down to the warehouse and I look through the warehouse copies to see if I can find a copy of it. If I find a copy of it, I make a cooy just like you have here and I get that to the auditor, and they include that in the package as verification that there was a warehouse requisition. Just today I wsu told to go out and look at a lug attachment to a pipe, which is a Class 1 stainless
. . . which I have supporting documentation for somewhere in this pile ... and the problem with this was they could not find a warehouse requisition original and I could not find one down in the warehouse, so I was told to go out, look at the lug that was on the pipe, bring back the P.O. and t' s heat number that's on that lug. . . .
CLEWETT_: ,
P.O. is Purchase Order?
Purchase Order and heat number for traceability requirements, and f rom that number that I brought back, P.O. and I
heat number, they would " reconstruct a field warehouse r equisi tion" . And they are the piping OA people.
KIRSH: Which hangar was this?
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) If you could go of f tape for a minute, I could l l find it. /
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KIRSH: -
Okay.
These two hangars were support 7324R. [-
KIRSH: Just a second, read it again.
7324R.
CLEWETT: That's the hangar symbol?
That's the hangar symbol. The line is 1S2-42-6, Design Class 1, Code Class B. It's a centrifugal charging pump 11 suction line, ISO # 1821. It's a System 8 which is the chemical and volume control system. And what I did is I went out -
there today and looked at Item No. 11 on the hangar drawing, Sheet 17, which is a stainless steel band that's formed and welded around the pipe. When I went out there, I noticed that it was not welded per the design drawing. That was the first thina I noticed. I did <e: a P.O. $ 9697 f rom there.
KIRSH: P.O. number. Now what does this P.O. number have to do with this? %
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Okay, this is because the OA Department did not have the original warehouse copy of this, and I went and looked for the copy for 2 weeks approximately in the warehouse. I could not find their copy so today we went out and we got the heat and the P.O. number of f of what was actually attached to the pipe.
KIRSH: Okay, so it's P.O. $96977 -
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P.O. 9697, Heat (A072803. That's a Field Weld s /
G X 81A'. Wel8ed by welder...
KIRSH: 81A?
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1-12 11 m /
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818.
KI RSH: Welder, what? EY7
- EYI. What I did was I came back with that P.O.
number and I believe they just wrote up a warehouse requisition right there without a DR or without any kind of documentation to describe how that was done. I told the OA auditor th'at it was not welded per the design drawing. There was a tolerance clarification that allowed them to change the weld symbol that's shown on this sheet and apply that to the upper location of Item 11. And basically they swapped symbols. What you have here is you have a quarter Phillip all around on the top, and a partial penetration groove weld on the bottom. Well, the bottom was inaccessible due to where these lugs are, so they switched assembles, and what I noticed was on the bottom they did not have an all around Phillip weld. They had approximately three 2-inch long welds that were spaced at 120 degrees around the pipe.
There may have been four, I'm not certain on that, but I know it was not welded completely around. And I went back and I told them that, and they just said, "Well, here's a guy that's bought of f the welding on the process sheet, so all I really care about is getting this P.O. number out there so we can close the package." That seems to be the general feeling that I get f rom working with these people, both in hangars and in piping ihat, well, senebody's already bought it, so we're not gonna really l
look at that even though it is a discrepant condition.
LOCKERT: And you couldn't write an NCR or discrepancy related. . .?
84 - 12 l \s .
l I am going to on this. I wanted to bring it up
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for the p'u rposes of illustrating the general attitude that we're dealing with out there. .
S CHOLENBERGER: Do you want to indicate for the iecord what page, where it's .
FK IRSH: Page 2, marked in the upper left hand corner. The field welds are ... let me circle them in red. Is that one?
That's one.
KIRSH: And, this one?
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Yes. Okay, those have been changed in the original design drawing, so we would have to look at that. I was not able to get a copy of that. These copies were basically to get the location plans so I could locate it out in the field. I also did the same thing on hangar 73-24.
SCHOLENBERGER: Which is marked page #37 Upper left hand cornpr.
Could I see that other one first?
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CLEWETT: While he's looking at that, I want to ask you a question. Are these numbers on his copy or on your copy?
HE RNANDEZ : On his copy. We can' t find them.
KIRSH: Oh wait.
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Why can' t you do that?
I just gave you some boous info. I was looking at the wrong ha'ngar there. The hangar that we just talked about was P.O. 9697, A072, 803, filled wall 81A. Sorry. It's number l 7411A . Okay, this line number is 1S241-4, Code Class B. ISO 8-30. All other information on that is .
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Okay.
7 RIRSH: '
Okay, except that's the volume control tank
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outlet. It's not the charging outlet.
7 CLEWETT Volume control outlet of . . . what?
It's the volume control tank outlet, it's the line that comes out of the volume control tank.
CLEWETT: That's part of the chemical and volume control syst9m?
Yes, that's the main . I'm really sorry about that. N
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CLEWETT: One of the things I meant to ask before, when i
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is before the question o,f confidentiality of * ,/
rods. I think, correct me if I'm wrong that we would request that you ... as I assume that you vnl do, but I just want to say this, that you maintain the confidentiality of these documents, both as to their existence and as to the content of them with respect to PG&E and Pullman. You may well do your own investigations as to what this means, but we would ask that you not let either Pullman or PG&E or any other organization at the site or individual knew that these have been provided to you or what their contents are. Is that an acceptable request.
KIRSH: Insof ar as we can, yes, I will do that. There may be a point ... it may come to a point where, in order to adequately reference a document, I a.ay have to, or one of us may have to show a copy of it. And say I want to see that ... the original. But, insof ar as we can, we'11 do that, yes, but I can' t guarantee that we'11 do that. I can' t do that in every case. I'm sure you appreciate that position. I'll try.
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CLEWETT I understand that it's dif ficult to do investigation,s
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without some of that problem arising.
These are mostly to support what we' re talking about here as f ar as what's going on, and these just {ref erence where it's occur ring. I believe this are pretty much typical.
,CLEWETTL Typical in what way?
Typical in the attitude that everybody has out there that, let's just get it by, and let's not worry about any other problems that are already down the road. Or you know, if you go out and you see something, basically just ignore it, look at what we want you to, and we'll take it f rom there.
CLEWETT: Let's go off tape for a second please.
KI RSH: Date time 9:07 PM.
LOCKERT: Perhaps, Dennis, I could make a stab at describing what our understanding is, and you can correct me if I'm wrong.
CLEWETT: We've agreed to take a 24-hour, or thereabouts, hiatus in this meeting for the purpose of seeing whether all of the documents can be organized and be easily accessible to exhibits so there is no cuestion about what is being discussed.
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We've agreed that ill take back the documents that he's supplied to NRC Investigators earlier this evenino, and will organize them in a f ashion that will make it easier to auickly understand what documents are being referenced. With the exceptions of the two pages that Dennis had notes on, all of this -
stuff will be returned then, and we'll meet again here tomorrow at 7:007 Does that sound reasonable to pursue. . . .?
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KI RSH s ' Suro. Wa'11 maot at 7:00 tomorrow nicht. Perhaps we can get through and cover this area in a bit more timely fashion.
~ t Good, yeah, I think that's a better i ay to proceed. And this way we get out before midnight. 'Before a quarter after nine even.
KIRSH: (Laughs.) Okay, thank you very much for your cooper ation. I'll look forward to seeing you again tomorrow night.
/ s KIRSH: The time is 9:09. 'has indicated that there are cover-up activities c ently going on in Pullman.
i would you please describe those activities.
Okay, yesterday we had a corporate vice president i
out that made about a 15-minute pep talk on how avality was the number one objective of Pullman Power Products. If anybody had a problem to please bring it to the highest levels of management.
Af ter you came in last Friday a.nd inspected DCN records....
CLEWETT: Was that the meeting with Leoty?
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Yeah, that was the meeting with Frank Leoty last Friday. I would like to ask you why was Frank allowed to be there. Was that an independent type....? You weren' t actually coming out and questioning people. You were just asking for their records. .
KIRSH: The reason that Mr. Leoty was there is because I had the requested copies of several QC inspectors, DCN logs and dailies. And to verify what I had received, Mr. Leoty would 1-12 16
writo down on' a sheet of paper, such and such a book' f rom such and such an individual.
I would initial it, yes, I received it, and then I went and copied.
I see. He . . . well . . . his presenef there when you were asking me about the non-conformance report and that, made me rather uneasy. I knew he couldn' t fire me for what I said there, but I was just kind of uneasy about that.
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KIRSH: Well', '
'I had asked the same questions of Mr. Day prior to doing this th[ng with you. I didn't want to make it sees that. I was f avoring one over the other.
What they're doing now, is they've issued a notice, although they . haven' t . . . they've issued it partially to some people, and other people haven't been told about it.
Myself, I'm one that hasn' t been told, but the company is requesting everyone to turn in their cover sheet of that DCN log so they can compare that with the records that they currently have, and I believe this is a move that they're making so that they can update their files in case they are rigorously investigated, and they can provide whatever copies of whatever DCNs people have turned in at Dave, like you said in your- end of the system. One in particular I'd like to talk about was my numbered 7 that you have in the copies that you made. That one never made it into the system, although I turned it into my lead man. It was supposedly hand-carried down to the office. That -
concerned unauthorized changes to my original DCN $6 where a piping engineer made a statement on the original DCN in my statement. block, and he didn' t initial or date it as to who made
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the chang 2, wh2re it cano f rom, and what he said was not entirely
. correct. He said that the items that were damaged were renoved due to a bad . Well, I can' t verify that because the on the process sheet was never signed of f. I belteve what happened was they welded them on, thentheyreali5edtheymissed a hole point, they went back and rounded them off, damaged the pipe, and.... The main point I was making with that was that there was an unauthorized addition to that DCN, in my statement.
CLEWETT: You said DCN $7.
pOCKERT: Did you say you knew who made that change?
No, I did not know who made it. I got my copy back of that thing and I was highly incensed that somebody could make a change like that to it because, number one, I did not agree with that. That was, in my opinion, not what had happened. If that had a signed of f, then I would have believed it, but because there were no bid-ups on jobs....
Because there was no rod requisition that allowed welding that night. It's all pretty much described in the DG. The main point was that that DG ... this was just about 2 weeks prior to our ASME audit ... and that DCN never found its way into the t
system, although it was hand-carried down to the office.
CIENETTs, $7 never made.
- 7, 6
yeah.
,KIRSHd do we have a copy of that? ,
Yes, I can give you a copy. Well, you do have a copy of that.
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CLEWETT: We were just gonna address cover-up activities and we're getting off into stuff I would probably take up at another time. I just want to get you back onto the cover-up thinos goina on right j
now., -
Yeah, the . . . by recuesting everyode's DCN loos, I think that's their aim is to compare that with what they do have.
HERNANDEZ : Do you have a copy of it now? DCN?
KIRSH: We've got it in our file.
HERNANDE3 : I realize that, but do you have it now?
)/ Yeah, I do have a copy in this stack that I can
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give'you now.
HERNANDEZ : I just want to see if you could point out - the change. If you could go on, and maybe Steve can look for it or something.
CLEWETT: When you said they were requesting everyone's DCN..,,
/ Well, not everyone. I'm sorry, I should cualify that.- They g quested certain individuals ... because I was never informed by my lead man. That's another thing I'd like to address just to get it out there is, the lead men don't get the information across to the people in the field. Your training is very limited. You're not encouraged to find out what you're really supposed to do. And if you can' t find it in the codes that you're working to, the ESDs that are supposedly all accrued ,
by PG&E, and in accordance with all your other applicable codes, you're not encouraged to look in the other codes when you get into a situation where it's not really addressed in the ESD.
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You' re told, well, if it's not in the ESD, you' re going to ha ve to buy it. And I don't really go along with that. I don' t really go along with that. This is pretty much obvious in the piping process sheets out there. That's another thing I'm doina in QA . They're bringing inspectors in that have signed of f piping process sheets out in the field and making changes to those sheets because things don' t agree with the warehouse requisitions they have. What I think happens there is the people in the field a lot of times are not trained that they have to check that warehouse requisition, and make sure that what the numbers are on that are the numbers on the lug and that everything is in accordance with that requisition. I was never formally instructed prior to ever doing piping that that was what (
had to be done. We did have one or two training sessions, but the training sessions are sporadic and they're run in a very non-professional manner. And they're also run at the end of a shif t when everybody comes in, and you' re tired, and you may have worked 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and most people are half asleep at these sessions anyway. You also have these things that are steps to 1
prevent recurrence on DCNs and VRs that are written against you. The document that you've been retrained. And the way those I
generally work... that's number 6. Here's a copy of number 7 i right here. The items that I' d like to. . . .
. 1 CLEWETT: Your DCN $77 {
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1 l Yeah. Here's . . . this is on #6.
I CLEWETT: This is your original now? l
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This is a copy. The original . The items that are highlighted there, as you can see, were not initialed or dated as to who added those on there. You know, as far as I'm conerned that's an unauthorized addition to that DCN.; The following page there describes my feelings on the matter at the time. That one never did make it into the system.
CLEWETT: I don' t see a void, or whatever. Is there supposed to be a void that it's not entered into the system?
It should be voided. Well, the reason there's nothing on that one is because what you're looking at there is my copy that I made. Well, you can see that this thing did get through. It was signed ... heh, this is 96. This is 97. If you look at #7 there's another sheet like this that you'll have in your DCN records that you f rom me that shows the reasons for writing on that one.
CLEWETT: So what I'm looking at is #6, and then #7 actually
... this is another one.
This is another DCN, but this is the violation here. This is what caused me to write, #7. It was that comment put on. And I had also done some f urther investigation. (No, that's not even part of that.) I've done some more investigation and found out what really happened on that DCN. The problem there was that DCN pretty much points up a complete lack of filler rod control out there in your welding, because when the rods check back into the rod room, the welder is supposed to count it and tell the attendant how many rods he burned in a night. I think the attendant should be the one counting that, e -
s
'l-12 21
/l
because what happened in this case, I believe, is the welder welded it up. They realized they screwed up, they ground it all of f, damaged the pipe, turned their rod back in saying they didn't use any rod that night, because the rod slip for that evening when the location verification of the cleanino was signed of f, the next step would be fit-up. If they came in on night shift, they didn' t have a fit-up bought of f yet, they welded it anyway, then they realized that they'd screwed uo, ground the plates off, damaged the pipe and turned their rod slip back in saying they didn't use any electrode that night. Well whoever checked them back in should have realized that they did, but because they didn't count it or for whatever reason, they voided out the rod slip so....
KIRSH: I have a question for you, I How is it going to be possible for us to go back and independently retrace this line '
... this deficiency, and verify that, yes indeed it happened.
It's fine for you to tell us that it happened. How am I going to go back and retrace the steps to track and establish the same conclyions that you came to.
You should be able to find it on the piping process sheets, although they may not have the original sheets because another sheet had to be issued now. See here, it says
" issue a process sheet to blend gouges and remove all def iciencies" .
KIRSH: I still need to know the answer to the question.
How do you expect me to go back in and verify what you've told me
... the validity of what you've told me, ane 3 arrive at the
'l-12 22
/
same conclusion? It's gone. The record is . . . the track is gone. This is written in. 8/8/83, it's written. I mean, how can I go back and do an independent verification of it. I don' t know how right now. ;
I don' t know if you'll find those rod reauf sitions either. They should be in the oackage but, you know, I agree with you. I think it should be traceable myself.
CLEWETT: Did you investigate this concern? All this that l
you told us, you are aware, you saw, or you verified all this?
' l Yes, I did. You got to take my word as an \
l inspector on there that that is true.
1 I LOCKE RT: did you want to continue on the subject of '
f coverup that you started on, or do you want to ? Are you i fini hed on,this particular matter?
I s
Yeah. The question you asked does bother me. You know, how can) you cet in there and independently Withoutverify.
this being in the system, all you' re going to find is, you' re going to back and you'll see a pi61ng process sheet that was issued to clear that DCN.
KIRSH: Even given that it may not even be in the system, and given that all I've got is your ... this one here, just by >
trying to walk back through the rod room from 8/8/83 and say, what happened, there isn' t . . . it would take a saint to remember exact,1y what happened August 8th,1983.
I agree.
)LOCKERT: That's the reason for documentation systems. I think part of the ... if I understand this correctly, part of the
/ ,
Il-12 23
/
problem that's being brought to your attention is a lack of material traceability here. And so if the documents don' t exist, then there's your resolution. Material traceability ,in the OA/QC system broke down at this point. And can' t be recons.tructed.
/ -
I That's the problem. You touched on it when you talked to me last Friday, was that there's two systems. There's one here that Harold Carner decides what's gonna be a DCN and what's gonna go through the system and conveniently loses these packages or just turns them back to the inspector and says, this is not ... if you look through those DCNs yet, you'll notice there were some in there that were voided fer a conversation with Harold Carner. Those were usually done by my lead people who told me that, well, this really isn' t a deficient condition. One of them was dings and hammer marks on a safety injection line, in Unit 1 containment, which is the first day I was out there of f of training, they threw me right into Unit 1 containment. You know, you' re not really ready yet to be out there, but the story I was given was, well, there are rounded hammer marks in the top of the i
pipe and it's a Schedule 160 stainless pipe, I believe it's like an 8"-line or a 10"-line, so it's a pretty heavy duty line, but l to me those are still stress-raisers in the pipe and they should at least be blended of f.
KIRSH: What's the codo requirement for blending blemishes or marks? ,
It's blending a 2-1/2 to 1 taper and making sure you don' t go beyond a wall thickness of 12-1/2%, which I believe I
l they would have no trouble reaching in that case. I had my lead
/ ,
'l-12 24
man come up and look at it. He said,-well, no, this really isn' t a deficient condition. I was....
KIRSH: Can you remember what pipe it was or where it was?
If saf ety injection line, where was it?
I have that in my DCN log. It was on the south side, I believe, of Unit 1 containment.
KIRSH: This was the first day that you were on the job in containment, therefore it probably was one of your first DCN log items.
I believe that was No. 2. Yeah, I really wasn' t aware of these ... I believe I was very poorly trained to be out j
there in Unit 1 containment by any. ., . .
KIRSH: Do you believe that you are knowledgeable enough now
- to be able to perform your functions?.
I i
Yes, I do now. But th'at's only because I ask a f
lot of questions and, when I don' t know the answer I ask people l until I find out, or I look at it myself. We're not encouraged to do that, and I believe that's the reason why they have me in a situation where I do not have any direct relation with the craf t out there. It's my opinion that the craf t, and it's been pointed out by other people too, the craf t comes to our supervision and tells them what kind of inspectors they feel we are for, like they probably say I'm a nitpicker, I'm always shooting down their work, and really require high ouality standards out of them, and they tell my managemer;t, Frank Leoty and Harold Carner, that we don' t really want this guy inspecting our work. And I've had another person tell me that he confronted Frank with the same 1
l 1-12 25
/
issue and Frank told him that he didn' t "believe everything that they told him".
LOCKERT : Are they the production people ?,
Frank said, and this is in reference t'o an inspector, Craig Neer, who was denied his raise because Frank told him, well, I hear you're a nitpicker. The hiring and the raise, policies are very inconsistent out there for. ...
KIRSH ,
That's totally out of our jurisdiction. )
) Yeah, I understand that, but I think it points uo a general harassment by our management as well as production i management that really doesn' t encourage an inspector to find out what he really should be doing. You're kept in the dark, you're poorly trained. Harold Carner's answer is, well, there's an ESD over there. You can go read it just like everybody else. That's his idea of training. Your welders....
/ %
. CLEWETT: Excuse me, Don't you have a training program that you go through and you read certain things, you take certain tests that qualify you?
That's your fitst two weeks out there. You're <
allowed three weeks for that training program, and' af ter that you' re pretty much on your own. You have training sessions as '
they're scheduled, which are usually in times like right before the ASME audit, we had a training session. When drawing control gets out of hand, we have a session. It's not anything on a regular basis. In fact, you sign a sheet every week saying you attended a weekly safety meeting when, in fact, it was your lead man that attended that meeting.
1.-12 26
, KI RSH: Is this weekly saf ety meeting ... what kinds of :
topics ' are discussed in that meeting?
General safety out there. One week it; might be - 1 rattlesnake bites in the summer, and another week it might I be hazardous chemicals.. It's generally a session where you can _cet together with your . .. the way the craf t work it, is they have, their foreman attends the meeting and then, I believe, they come back and they meet for about half an hour and discuss the meeting, and discuss any problems that they see. Our manacement doesn' t want us out of the field that long, so they basically just pass around a sheet that says, you know, you' ve been . . .
you'll read a letter on it, or whatever it was that they talked about. And that's' suppose to suffice for training. I've-been involved in training of welders.
I worked as a welding instructor out h'ere at the local prison last summer. I don't feel that the level of training out there is consistent with the responsibility and the related items of safety of what you' re dealing with.
SOIOLENBERGER: Out there at Diablo.
Yeah. You've got inspectors that really don' t know what they're doing or what they' re dealing with, because they are not trained in aspects like how the plant operates, what systems are vital, things like that. ,
K14H: What other training would you recommend that an inspector get?
I think an inspector should at least get an overview of how the plant operates, an idea of some of the basic i l
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/
'l-12 27
components and their f unction, and what they do as f ar as safety of the plant or operation. I think they should at least have a weekly session where you pull two inspectors out of the field at a time, you know, on an on-going basis, and just ask-them what the problems they see are, let them know what the problems other people have been involved with who got burned for a DR. An incident we had, two inspectors were given this letter f rom Carner that he's been passing out lately, that we talked about last time, for buying of f non-traceable pipe end, basically SME Section 1 piping that didn't have heat or P.O. numbers on the pipe. I think everybody should be made aware of what they did so that they have the benefit of knowing that that happened and what happened to these guys, and that way everyone benefits f rom it instead of two people just getting burned for it, and everybody else 'may still be out there dealing with the same thing. I think another area that really should be addressed on training is the training program for the crgf t out there. It's my understanding i
that on other nuclear sites you go f rom anywhere from 4 to 12 working days in a training program where you' re taucht good j welding techniques, how you should weld certain materials, a little welding metallurgy wouldn' t hurt, and things like that. j Out here all you got to do is come out and pass a test and you're out there as a welder. I've done a lot of research on the .
subject and I know that at other plants you have regular training I
sessions.
KIRSH: . Have you ever worked at another nuclear plant.
l-12 28 I
1
). ;
l 1
1
/ No, I haven' t. I've gotten this out of the welding journal. Articles on training that they write at other i nuc sites. I believe Duke Power in South Carolina was one of the ref erenced articles I read, where they have a stringent training j
program for all their welders before they' re ever put out in the i field.
KIRSH: So you don' t f eel that the . . . I guess what I' m j hearing frca you is you don' t feel that it is sufficient for a welder to merely pass a welder / welding qualification test in a I
booth,or on a test coupon, and.... I No, I've been a welder for 10 years and I can tell you the easiest part of the deal is passing the test. When you got to get out there and climb into a cramped space and make an
, x-ray quality....
KIRSH: Then as I understand it, what you' re taking issue with/s the adequacy of the ASME: code requirement.
No, not at all. I'm saying, from what I see out there, I see really poor welding ltechnioues, especially when we talked about the gas tungsten are process, I see welders that dors't even know what a welding procedure specification is. They do t' t know how to read the drawing. They just get in and weld it a lot of times.
KIRSH: .Are the welders cualified to ASME:?
'Our welding procedures are. They.... '
KJRSH: _ Are the welders qualified to ASME:7 Yes, they are.
,/
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A-12 29
n KI RSH: Okay, does-the ASME recuire the kind of program that i
you' re - talking about? Not that I'm arguing with the rationale or logic behind it. What I'm trying to oet to is whether or not- 1 Pullman, in your opinion, Pullman Power ~ Products qu lifies their welders as required by codes and standards.
I can point up where' they are deviating from ASME in the f act that they have welders qualify on our qualification sheets, that come out every week, it's called a Weekly Welder Qualification, where welders are actually aualified in excess of l
the thickness of the procedures cualified to weld, and welders, I believe that the maintenance of qualification out there, the l requirement that you use the process on a production item to ;
read, to maintain your qualification, I think that they are deviating f rom that a great deal. You've got foremen out there....
KI RSH : . Do you have first-hand knowledge of any deviation from.that. ;
Yes, I have copies of the Weekly Welder certs where I can show that there are welders who are in certain procedures that are qualified to a thickness that is creater than the procedures qualify to weld. Now that is a deviation from ASME Section 9 because you have to follow a cualified weldino procedure specification, and if you're within the limits of that welding procedure specification, you know, you can' t be welding a thickness greater than the procedures qualify .
KIRSH: Can you point up some of the welders that are welding that are not qualified to those thicknesses. And indicate where they haye welded for us?
h-12 30
/
No, I can' t say that I have seen them out there !
' \ .-
l welding. I'm pointing this out as more where they're not conforming. They. don' t understand the requirements of the ASME code in that respect. .
KIRSH: i Dave, do you have the copy of the Weekly Welders '
form there. .
S CHOLENBERGER: Yeah, I'll get it right out. Here in the stack....
KI RSH: Perhaps you can highlight those welders that you ;
don' t feel are qualified to the thickness requirement of the procedure during our next meeting and we can take a look at that situption. ,
I I'd also like to discuss the maintenance certification ( To my knowledge, the way they do it out there ...
ASME requires ... the ASME code requires that you use the procedure that you're qualified for within 3 months. If you use any other welding process within that 3-month period, it will maintain your certification for; the other processes that you're qualified for- within the essential variable limits of. .. . We're talking processes like stick welding, shield and metal arc, gas tungsten arc, combination processes. If you use one of those processes within a 6-month period, you still maintain your certification. Well, and this is especially true of the foremen out there, the foremen are listed with a whole string of '
certifications in there and a lot of them, the way they maintain that certification is they go to the test bay, they burn off about 1 inch of an electrode and they have an auditor audit the
- 'Ns k-12 31 s
, cur rent- basically, with a tong meter, and if that current is 1
within the specified parameters of the welding procedure and the bead looks good,-I take it, the guy maintains his :
certification. The problem with that is the guy hasn't welded
... you know, they're all qualified for type test 6G and if the I guy gets out in the field and does have to make a 5G or 6G weld, i
a lot of times you run into problems. We had a problem, it was !
)
in the J100 area, it was mostly an x-ray reject down in the line j behind the sample sink there . . . I could get the specific line '
numbers tomorrow (phone rings - Tom Walsh? calls).
KIRSE: Time is 9:44 PM, January 12. We've agreed to meet January 13 again at 7:00 PM. /
KIRSH: This is the secon nterview. The date l is January 13, 1984. This is an interview Mf ho has presented a bo,oklet of a number of concern to the NRC. The time is 7:19 PM. would you take us through your i bookpet? _
Okay, we have previously lined out a number of each section'of the booklet. . . .
LOCKERT: Why don' t you just for the record review what those, are j.ust up top, so we have a table of contents.
Yeah, that's what I was going to do. This booklet is in relat n to incidents of harassment and intimidation. .
Incidents where I was coerced into possibly accepting workmanship that I didn' t feel was adequate and was out of our code 1 requirements as well. It's in relation to . . . well, I'll just oo ;
l through what we got. The first section is a copy of copies of my n }'
r, Il-12 32 3
,s'
daily inspection reports that I maintain as my own personal record for comparison to the copies that were submitted to Mr. Kirsh by Pullman Power Products. Section 2 is a discrepancy ,
report that was submitted by myself on this date, January 13, 1984, concerning the use of unqualified materials and unqualified welding procedures on welding studs throughout Diablo Canyon Nuclear Power Plant Units 1 and 2 on safety related items.
Section 3 is a group of dispositions and accepted DRs that I would like to use to trace the DR process and to show how it's now being carried out through our quality control insurance program. Section 4 are copies of my deficient
]
condition notices (DCNs), f 6 and 97, and we would like to clear up the DO4 process and events that occurred to produce these ;
2 DCN s. Section 5 is a training record of a DOI that was written against me that I did not feel was a legitimate deficient condition, and I have written similar DCNs for the same situation i i '
that Harold Carner voided for reasons that will be discussed when we get to that section. Section 6l is a hangar package, hancar
- 249R, which I will use to illustrate the use of unqualified welding procedures and the use of harassment and intimidation to inspectors to accept workmanship that is not f acceptable. And the last item is a copy of a memo that I wrote to Harold Carner on January 10, 1984 which I've received no
' i response for, concerning the lack of training of inspectors, and {
this is in relation to preparation and authorization of field warehouse requisitions. So if you guys would like to. . . .
1-12 33 l
________-_______________________A
KIRSH : Well, let's begin. Oh, present for the ... to get another f ormality out of the way, present for the United States Nuclear Regulatory Cmmission is myself, Dennis Kirsh, Gonzales Bernandez, a reactor inspector in Region 5 is present. The full name . Mr. Steph n Lockhert is also present, and they are represented y Government Accountability Project, and present for the G0verment l l
Accountability Project is John Clewett. Go ahead {
\ l Okay, I' d like to call your attention . . . we'll be flipping back through the dailies and I'll be able to give you dates so we can tie these items down. The first thing I'd like to call your attention to is Item 2, which is the discrepancy report that I submitted today. I'd like to explain how this report was handled when I submitted it. If you would like you can take a minute to read it here, or if you want to listen to me talking while you're looking at it.
KIRSH:, Continue talking.
/ g Okay, this discrepancy report (DR) is in relation to .'.. a serious problem that I see as an inspector and as a welding engineer, although my duties for Pullman Power Products are not as a welding engineer; while doing research for field warehouse requisitions for the Quality Assurance department, to find copies of requisitions that they've lost in the field, CA is required to have the original copy of the field warehouse requisition in the package that they turn over to PGsE as their ISO package. When they can' t find the original copy of that field warehouse requisition, the warehouse keeps a copy of that,
/ s 1-12 34
the foreman or the engineer also ... there are 3 copies that come out with that. The original- white copy, a yellow copy for the warehouse, and a pink copy that's kept by the foreman.or the engineer. Generally, the f unction of the' of nk copy ib to accompany the material' to the site of installation, and generally that copy's trashed. Nobody keeps it. It's just thrcwn out. I '
was looking through warehouse reauf sitions for the containment spray ring, System 12, in both Units 1 and 2, and I cam'e across a very disturbing item. The A307 bolts had been requisitioned as welded studs, the heads were cut off the bolts and these bolts were used and subsequently welded to the containment liner, which is a P1 material and it s with ASME Section 9. That would be the 1977 edition, which is referenced in our ESD 223 as requiring welding procedures to be cualified to that addition ofi ASME Section 9. The disturbing thing about usino a bolt as a i welding stud, number one, is it's not designed to be welded.
A307, by specification, has no upper limit on carbon; it han no specification requirement for quality assurance heat traceability of that material. It comes into our plant on a certificate of compliance, which you can see by referencing the attached purchase orders at the back of this Section, which are not part of the DR package. It should (n' t?) include 6. hat. The purchase orders are for reference only, so that you can cet a general idea of the kind of purchasing specifications that we're using. I'm looking right now at Purchase Order 9287. That would be the number right up in the corner there. And you can see that that purchase order ... It would be the first one ... that purchase
'l-12 35
order is strictly for A307 Grade B bolts and A194 washets. I'm mostly concerned with the bolts. There are references to this purchase order throagh these material requisition copies that are included with the DR . . . these purchase orders are just for 9eneral info so you can get an idea of the specifications. I'd like you to look at page 2 of 2 and see that BB1 only requires as i
a specification, a manuf acturer's certificate of compliance indicating that materials furnished are in compliance with this purchase order with specifications which is taken to mean ASTM A307, or listed in the supplier or manufacturer's catalog. ASTM A307 is not listed as a P1 material in ASME Section 9, therefore to weld this material you must qualify a welding procedure.
Pullman Power Products does not have a cualified approved welding procedure to weld this material to a P1 material. i e 3 3 KIRSH: As I understand it, this is merely a documentation of a concern that you forgave us the first night that we met. Is that a fact?
,e
,/ This is the of ficial report to Pullman Power of my findings as a discrepancy.
KIRSH: Okay, I think we had gone through ouite a bit of this the first night, so perhaps we can go on. It's not that I'm not interested in it, but I think that we understand the situation.
f -y .
7 Right, okay, I'll explain a little further. The other night /we were talking about A108 and A307. And since that night I've come acrocs documentation that you'll find in the first 3 pages of material requisitions, af ter the written part of
/*
l-12 36
,/
\
the DR there, where you can see that what they' re using . . .
actually it's the first 4 pages . .. is not A307 on these. This is System 14 component cooling system. They' re using A325, which is a high-strength bolt. And the carbon content on AI25 is suf ficient to warrant special welding considerations, such as preheat and close-weld heat treatment at the very least, to insure any kind of notch toughness in that weld. To my knowledge, I do not know of any preheating done on these, and there is also no qualified welding procedure for welding this material to any P1 material on a hangar or containment line or anything. I address this problem on the DR, which has been turned in but has not been given a number yet. This would be listed as number 032 in my DCN/DR log, because the way I would work is I would assign this . .. if it were a DCN, it would be number 1604-032. It's logged in my book as such.
I This morning at 10:00 I submitted this to my lead man, Joe Watson, for his required initial and approval on this form. He read it over for about 10 minutes and I looked at .him and asked him, are you conna sign it so I can take it over and get engineering to disposition and take care of putting an engineer's signature on it. The way it works is like a DO4 You have to first get your lead man's signature on this form and, second, you have to get an engineer's signature indicating that he has dispositioned the DR or DCN, or agrees with the thing. And you're supposed to consult with the engineer. Together you work out an approved disposition.
KIRSH: Did you consult with the engineer and work out an approved disposition?
f 3
'l-12 37
]
I was not given the DR back to go consult with engiheerina on it. The dispositions that I have on here I was instructed f rom another inspector who's f amiliar with, writing these, as to what the proper disposition should be on,- this. And like I say, I was not able to get over to engineering because my lead man took the DR and said that he could not sign it. He wanted to have another supervisor review it. Merrill Ledoerton or Dennis Clark.
HE RNANDEZ : Who is your lead man?
My lead man is Joe Watson, at the time. So I said, fine, ['ll come back later and see what the status on this is. I came back at 12:00 and right af ter lunch, and I asked Joe what happened to the DR, and he said that, well, and this is a auote, he said, "It's down at Leoty's office and Leoty's probably still heaving over it." Which I: took it to mean that Frank Leoty was not very happy with the DR. And I believe it's of a very serious nature because it covers quite a bit of safety-related equipment out there. I asked Joe' if he signed the DR, and he never directly answered my question. He told me, well, I gave it to Russ Nolly and Russ Nolly took it down to Frank Leoty and it's down there and I assume Carner has seen it by now, and they' re deciding what to do with it. That was the end of the conversation. As f ar as I know this DR is down there on Harold Carner or Frank Leoty's desk, and they're deciding what they're gonna do with it.
LOCKERT: Dennis, I know you have an awf ul lot to do. I would make a suggestion that to avoid the possibility of tipping
- s 1-12 38
/
your hand to them about knowing about this, that you hold off for a few days on making any inauiries about this to oive them a chance,, in the normal course of events, to respond to,it.
What is the responding procedure for nbn-conformance reporting.
LOCKERT: Is this the non-conformance report?
I believe it should be. As we discussed the other night, Dennis said to me, why don' t you just write a non-conformance report, because my instruction in the field, until just recently, was I was to address all issues on a DCN.
Recently a memo was issued by Harold Carner stating that anything that would require physical work in Unit 1 will go directly on a DR. That's the format I took to write this DR.
LOCKERT: And so did you write an NCR?
Well, t'he way I' ve been instructed is that I turn this into Harold Carner and Harold decides whether it's an NCR or not. And another thing I would like to explain is that what's gonna happen to this is this is going to be rewritten, and I question the legality of Harold being able to just completely rewrite my statement on this thing to suit whatever his needs may be. I believe that's ... I can' t say for sure, but I believe that's what's gonna happen to this DR, because of tue nature and the widespread rework or repair that could be resultant of it.
When I lef t today, I lef t early at 2:00. I got a slip for an early out. And when I lef t I noticed Harold Carner standing out in front of the OC trailer talking to my lead man, Joe Watson, and it's very rare that Harold Carner ever comes up to the QC
/ %;
'l-12 39
I trailor to talk about cnything. He usually stavs behiad his desk.
HERNANDEZ :
What time was that?
That was at approximately 2:00. ,-
HE RNANDEZ :
At 2:00 I went with Harold Carner to the QC i trailer. To go talk to some QC inspector to go out in the field and talk to some welders and fitters that I was interviewing.
i It would have been . .. I lef t at approximately 4 minutes of 2:00 and when I left Harold was standing out in f ront of our office talking with Joe Watson.
HE RNANDEL : I met Joe Watson at the time and. . . .
Did you meet him at the QC trailer?
HERNAND2Z : And Dennis Clark, and Dennis Clark took me out to the field.
LOCKERT:
You ret all of them at the QC trailer?
- Yes, at about that time.
KIRSH: So then it appears there was probably no ulterior motive other than going with Gonzalo over to look at this information.
. w I didn' t see Gonzalo there when I left.
CLE ETT: Gonzalo just said, I believe, that he met all of them over at the QC trailer.
HERNANDEZ : I went over to Harold Carner and I asked him, I want to go out and talk to some welders and fitters and I said I'd go out there by myself but I don' t know where you're doing work. He said, I'll take you out to the QC trailer, we'll meet with Dennis Clark and Joe Watson. . . .
e (1-12 40
/
/
Okay, sorry, that was my misunderstanding. You went up to th'e office then and. . ..
HERNANDEZ : I went up and went to Harold Carner's of fice, f rom there we went to the QC trailer, and then I waited like 10 or 20 minutes because Dennis Clark was quite busy.
Then you were in the office with Dennis?
HERNANDEZ : Yes, with Dennis, and then Dennis took me out in the f,ield tq....
) Was Harold out f ront then with Joe Watson?
s /
HERNANDEZ: Yes.
h Okay, that's when I saw Harold Carner talking to s
Joe Watson.
yRNANDEZ: And I had to be back by like 2:30, so. . . .
[ i Yeah, as I understand it, there is a reporting requirement 'for non-conformances that . . . I'm waiting to see how this DR will be handled.
HERNANDEZ : Well, we won' t say anything. Obviously it's got to go through the chain and, you're right, we shouldn' t. . ..
KIRSH: I'd rather not glitch it before it cets a chance to go through it.
CLEETT: Definitely. I would like to see how it works as such.
LOCKERT: What was the number on that? DR2 ?
It's not numbered yet as a DR, but it's logged in myhokasfl604-032.
LOCKERT : At what point is a DR usually numbered?
l
, N y-12-84-41 i
f, The way it's dons is it'c turned in, af ter you aet the appropriate signatures on it, it's turned into Harold's of fice, and Harold's DR . secretary, Karen Aguada, will look them over, make sure everything's correct, hasreferenceshothe proper specifications, things that need to be in there, and then she will submit them to Harold for his lookino, or he'll take and look at it then. I handed one in approximately, I'm not sure now, but 4 days ago thereabouts.
)
, KI RSH , Another DR7 '
Another DR that was 6031 on the DCN numberino
)
series. My log number. . . .
?:
Have it in here?
i No I haven' t included this. I can provide you i
with copies later. This also referenced an unqualified welding 1
procedure which was used to attach nuts onto a base . We l 1
talked at length with this the other night on 12.
KIRSN: This is the one that's on the containment wall?
, Yeah, the outer wall' .
KIRSH: Unit 1 over on the northwest side.
I believe it's 1048-8B, no, pardon me, ASL is the hangar.
KIRSH: It's that big place with the nuts the bolts like that.
/ '
Yeah. '
KIRSN: I know which one it is.
They' re half nuts. They have ouite a in the . They' ve accepted that. What I didn't accept on 1-12 42
I that was the workmanship per RESD standards for old work and the welding used, because in my opinion, it's an unqualified welding pr ocedur e.
CLEWETT: af ter Karen Aguada forwards ,0CNs to Barold Carner, does he under all circumstances number them. Or does he just number them and return them to you?
Karen is the DR specialist. The one that handles the DCNs is a girl named Peggy Shallowitz. No, the DR number is assigned as soon as Harold approves the DR. If Harold decides it's a DR, then it gets a DR number. I f he doesn' t, then it's kicked back to the inspector or something'll have to be done to get it to where Harold will accept it.
CLEWETP: If you wrote it as a DR, is it then voided? Is there a written void across? For instance, this one that you' re showJng us in your. . . .
I have never had a DR voided. I' ve had DCNs voi'ded and sometimes generally the way the DCN gets voided is a lead man or a supervisory person .'will tell the inspector that, no, this really isn't a deficient condition, we're gonna take care of it and let it go at that. Because you look through my DCN log, you notice that some of my numbers in my log had copies in the book that I wrote " log voided per verbal instructions of my lead man". Now the reason I did that ... normally those would just be torn up and thrown away, but I felt that I should at least document that I made an effort to identify these situations and that I was instructed by my lead man that these really weren't deficient conditions. In the case of the earlier DCNs, I r
'l-12 43
wcs, lika I say, our training is not as good as I feel it should be, so that I really wasn't aware of what was a DCN c .iition and what wasn' t. And so I got some more field experience.
EE RNANDEZ : Are you telling us then that not al DCNs are logged into the system.
, No. Not all . . . the ones that Harold accepts go into the system. If they are voided per the lead man, or voided
... if they' re voided by Harold, they' re logged into the system. If they're voided by a lead man or verbal conversation ,
and instructions, they are not logged into the system. They can be resubmitted at a later date. I have one in there that I was gonna resubmit at a later date, but I just haven' t got around to doing it. We'll talk about that, but I know I made reference to t i t. s CLEWETT: I think we've probably got enough on our plates ,
here tonight anyway.
\. Yeah,sorry. Just to show you how DRs ao through the mill, we /could look at Section 3 in here. These are copies of discrepancy reports that were filed for violations of mineral wall conditions.
HE RNANDEZ : Before you get going on that, I'm still interested in the DR. I'm f amiliar at other sites that, you know, there's a log that's kept of NCRs, nonconformance reports, l and' what happens is if you want a nonconformance report form like '
this, you then pull a number. Is this the case here? Where did you get the form to write it?
f
'l-12 44
\ / ,
l l
i
, N211 thm discrepancy report forms are kept in our office, and they are accessible now. But as far as writing, I'm '
not aware that this in itself is a nonconformance report. I know the definition of a . . t HERNANDEZ : This is a nonconformance report. !
It is?
KIRSH: This is what Pullman defines as a nonconformance report. They. just don't call it a nonconformance report. It's a discrepancy report, and is processed the same way a nonconformance report in other sites is.
/
I see. And that's what this 10TFR21 is, it's an unattached ref erence at the top, what does that have to relate ;
to? i HERNANDEZ : Probably a reportable condition.
Deportability. I see. '
CLEWETT: So then you' re saying that all discrepancy reports are turned into the NCR?
HERNANDEZ : No, no. i CLEWETT: All NCRs are. '
KIRSH: No.
HERNANDEZ : No.
CLEWETT: Oh, I thought that was one of the .
HERNANDEZ : No, what you're talking about is a DCN, is the lower level system. The system that determines whether a system is nonconformance. If it is determined to be a nonconformance, it then becomes a nonconformance. Pullman then has called a nonconformance a DR, discrepancy report.
%-12 45
/
t Whan does tha reportabilit3 requirement enter into this once the criteria for the. . .. !
KI RSH: I think your counsel probably knows what the deportability requirements for 10CFR21 regarding defective component , basic components and material on . . . and hat the deportability requirements for 10CFR50.55E, the significant cons truction . deficiency reporting requirements are.
t I was told that. . .
~J KIRSH: This is something though that the licensee communicates to us. It is not something contractors ever do. It is always licensee's responsibility to report.
/
/ Alright. Anyway...
KIRSH: It is not even the requirement that Pullman or . . .
Pull. nan evaluate their discrepancy reports or 50.55E applicability or for a Part 21 applicability. It is however, the requirement that the licensee when he sees all of these, reevaluate,s._ f ull deportability.
I see.
CLEWETT: He has a procedure.
KI RSH :
They have a system to accomplish that evalution.
And that relates to the out-code, and how a s pe cifi ca tion. . . .
KI RSH: No, not necessarily.
r m p I guess I'll have to look at those ..
CLEWETb I'm sorry we interrupted you. You were discussing '
something.
s 1-12 46
e
, Oh, I just wanted to show in these reports copies of DRs that have been written that were dispositioned basically over the phone by PGsE. These were wri tten . . . most Qf them were violations of minimum wall thickness on sprav ring typing. l CLEWETT: This is number 3. . . .
Yeah this is Item 3.
KIRSH: You say, over the phone. What is the problem with 4 dispositioning something like this over the phone if they already have a copy of it?
Apparently it looks like it's a legitimate way to disposi tion, but I'm just showing this as a way that PG&E uses to disposition. We' re looking at number 5269 here. . . .
KIRSH: What is specifically wrong with doing it over the telephone. t LOCKERT : He's trying to tell you.
KI RSH: _
Okay.
It's just that it's a general ref erence what I feel is the way a lot of this stuff basically gets swept under the rug in some cases. Like with that DP that we had on the earlier one. We discussed in our other meeting, where it was all done over the phone and some guy in San Francisco said this is acceptable. These are little more legitimate because they back it up with some calculations. I still feel that in the case of that other one, where they have the nuts welded on the hancar and they've violated minimum thread engagement, and those kind of things, a telephone call from a guy in San Francisco saying this is acceptable without ever knowing the situation, really is p s
'l-12 47
/
inadequate. What we have in this is we have the original DR report, 5269, as an example, and you can see the disposition is to accept as is per the attached 927 telecom, via Nichols to Stan Carnez, and it's got something about Warren's file Nol 146.10. i This is signed by foreman, Frank Leoty, who must be Harold Carner and designating QA/QC manager for the day. If you look, we have an NBE thickness report here that was done with an ultrasonic thickness calibration. The nominal wall thickness of the pipe is
.280. That would be right in there. The minimum wall allowable per the code NC3317 is 12-1/2% of that nominal wall thickness could be reduced, so your minimum wall allowable is .245 and the actual at the lowest reading is .239. The guy lef t out the . Now that's, you know, maybe 7/1000ths, 6/1000ths under the low wall conditions,'and PG&E hears a report on the next page of where it is. It's right next to a weld and the nozzle on the spray ring is approximately 334 degrees. This is the backside of the UT report showing where the location is. And then we have a telephone call log. #030785 where we show minimum wall for the lines, a calculated minimum wall beyond that, and because the calculated minimum wall per design requirements, which are not really stated in here, but I can't auestion designer forms. . . . They say that these conditions of minimum wall are acceptable per their calculated design requirements.
HE RNANDES : Could we identify one point only below minimum wall. ,
Could you go back?
Yeah, we have . . . what was the minimum wall here. They show the readings there. The minimum wall is .245.
f t-12 4 8
,/
As you can see there's quite . a f ew . . . there's a .243, .243,
.245, .244, .239. I don' t see where they have the .239 on there.
KIRSH: Do you believe it is or -is not allowable, for the ASME code to utilize the calculated minimum walls based on pressure temperature relationships in lieu of the nominal' 4
minimum wall requirement of 12-1/24 less- than the nominal wall. f I
j No, I'm not f amiliar with ASME Section 1, or I whatever app'11 cable section requirements apply this. This is ref erenced to be 317.
KIRSH: It is allowable to do that, believe me.
It makes sense that you would do . I was just using these to show that....
KIRSH: Well, ; based on this, I would have no reason to question the validity of the response, because it is an allowable situation in accordance with the code.
- Here's an interesting one. This one's been revved once. There/s a discrepancy report here, f 5267. It appears that it was first issued except as isi with a note here to blend and grind the gouge areas and, I believe, when they blended on this that they violated the minimum wall, and there is a cuestion as to how the depth was taken. One guy used a depth gauge and the other supposedly used a UT technique to get through the wall.
Again these aren't that major of a level wall violation and were rejectable to our specifications, but accepted by PG&E. We have >
a copy of the trf report here, that's a copy of the original. It says, it cannot be located.
KIRSE: Where's this one?
/1-12 49
/
) This wcs ths 1 cat paga of . Soe, thare's a coupheoftheyereportsinvolvedinthisone. What happened here was the guy had to go out, so we have this as a reconstruction due to the original being lost.
KIRSH: So he had to go out and redo it.
The first W inspector that went out rejected it ontI11sform ight here. And then another inspector went out and found that it was acceptable. It says they accepted the W repair area, found it acceptable, and . And that would be EF5267 there. It should be the last page of that.
I 3 CLEWETT: You're saying, that these NCRs that you' re j showing us here are, or rather discrepancy reports, are examples of questionable dispositions en your mind. !
r
,I'm not questioning them by looking how f ar of f they'are Id a ;iust to show that the way these are disposi tioned. . . .
KIRSH: Oh, they' re still below minimum wall. Once you identified there was something below minimum wall, you got to do something about it. You either got to go make them run a recalc
... calculations on the pipe, based on design pressure and temperature relationships, or you've got to go and verify and prove that th'e thina was not below minimum wall one way or the other.
CLEWETT: Or you repair it. -
Or you repair it.
KIRSH: Or you repair it, that's right.
r . i
'l-12 50 l
- - o
t ~,
/ These don' t really seem to be all that . I l
just wanted to use that to illustrate the way these DRs go '
through the system dispositioned over the telephone.
KI RSH: Okay, so you feel that the telephone dispositions are npt acceptable and would tend then to cover up or. . ..
I wouldn' t say they' re not acceptable, but they could.be'used to cover things up. In the case of the other incident that we talked about where obviously they have deficient
)
conditions, that a. guy on the phone may not be aware of them, i
Nuts that aren't getting their f ull thread engagements, they wall monitor , whatever it may be.
)
KIR3H: Oh that's why it's so extremely important to write up a good nonconformance report that thoroughly and accurately
, describes the situation as it exists. {
, LOCKERP can I ask you a question. Are these s '
semepimes dispositioned over the phone, or always, or. . .. !
No, it depends on the situation. I really can' t say because I don't know how PGsE goes about dispositioning them all the time. I've only had two of them go to a DR and they were not items that were rejectable to the code, like that pointed out, low wall conditions that are code violations.
I LOCKERT: Do you know why the dispositioning official, the PGsE of ficial at the other end of the phone, was just told about this DR over the phone or whether he actually had a copy in front of hip and gst dispositioned it over the phone?
I could not say. I really don't know how
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they . So moving on to Item 64 here, this is DCN 41604006 l
l-12 51
/
I and fl604007. To got an idaa how this all came about, let ' s start with my daily for August 8,1983. This first thina I got involved on this hangar, you'll see 185R listed as the very last one on the 8th. It seems to me that I had one othe}r dealing with
~
this hangar prior to that.
KIRSH : This is DCN 006?
006, yeah. Yeah, I did have another. On the 5th, was \when I first was involved with this hangar, and the way that it occurred is the welders that were working on the hangar called me up and wanted me to take a look at some fit-ups on some Phillip welds. Well Phillip welds don' t require a fit-up so I explained that to them, and you could see by these dailies that we were f airly busy those days, and I really didn' t even take a look at the pipe at all or I would have noticed these conditions then, but on the 8th I was called over for a fit-up, and when I looked at the fit-up I noticed these grounding gouces, are strikes, etc. listed on the daily for the 8th that were obviously damaged pipe conditions, so I wrote DCN 91604006. At the same time there was existing what they had was a doubler plate or a bumper plate welded onto the pipe. They decided that was necessary was to increase the area of this plate, so two additional plates were to be welded on either side of it. WhatI observed when I came and really took a close look at that pipe was something that appeared to be a linear indication running out .
of the vertical fill-it weld that was attaching the plate on the right hand side, which would be the east side of it as you're looking north at the line. It was down in the component cooling
/
L-12 -8 4 - 5 2
4 water haat exchcngar room cnd the line is 1K104-20, code Class C. At the time we were concerned about this linear I indication because it appeared . . . we don' t call them cracks cut there, we call them linear indications, but it appbared to me that it could have been a crack related to'the stress put on the pipe from the vertical fill-it weld. We called over the PT and you can see here we did an informational PT which indicated 3 linear indications. We followed that by light grinding to make sure we were ... we were not quite sure whether' if it was a crack or if it was possibly a surf ace defect of a burst or lamination type def ect of the pipe. Af ter light grinding, it appeared that it was getting better, but we didn't quite get rid of the indication. They came in and did the regular PT on it that night, and we came back in the next day, which would be the 9th !
... yeah, it was the 9th. There's 2 pages for the 9th. We came back in the next day and the PT was, as I remember everything was alright. And on the 9th we have a reference to 185R where I consulted with a field engineering lead, Tony Pacifica, to find out how the plates were ground of f without a process sheet, because it appeared with the process sheet that they had, there was a location and cleaning verified but- no fit-up was ever 1
verified for that weld. So as we look through there we see that there was a location and cleaning verified by Ray Nogee on .. . I believe the date's shown on the attachment. .
LOCKERh What was your question regarding specific code
{ number?
t s
1-12 53
,/
4 I asked him how these lugs could be ground of f a pipe when the're is no process sheet that allowed him to do that. The fit-up was accepted on July 2,1983. .
,LOCKERT : This is from a weld rod ? :
I No, this is the ' field process sheet. The piping l'
process sheet.
KIRSH: Where's that at?
\
The first copy that you have af ter the writeuo of.
the DCN #007 s ... mainly it was copied to show that there was a weld rod stores reauf sition for the nicht of . .. it's a really poor copy, but it was for the night of July 2nd. We can go back....
LOCFTRr: ~
I need to put my tape over here.
/
j ... and look through your requisitions or to the '
s files, you'should be able to find this rod requisition, even -
though it was voided. It was for 7:45 PM for approximately 50 electrodes for this hangar. Af ter f urther research, I had i determined that what happened was they drew rod at 7 :45 PM, according to this rod requisition right here. The craf t never I got the fit-up verified, as you can on the next page, which is a copy of the process sheet. They have the location signed of f, verified off, and they have their cleaning signed of f. The next step would be to tack the plates up there and get the fit-up )
bought off, at which time the inspector would audit the welder to make sure he was qualified to weld for that procedure, and make sure his electrode was properly stored, etc. No fit-up was ever signed off. I believe . . . a.nd this is a line where they welded 12 54
/
with water behind the line. That's why we were concerned with the linear indication coming out of the weld. They didn't get the fit-up signed of f. They came in and, maybe between the shif ts or betweeri whatever, they started welding on it, they realized that they were welding without a fit-up acceptance, they got scared, they ground off the lugs _that they were ... pardon me, the plates they were attaching to the weld to the pipe.- I believe what happened was they did not have a weld recuirino inboard edges of each plate they were addina on, to be tied on to the other weld of the existing plate that was there, and they wore up on them on the side that wasn' t welded. Anyway, they never got their fit-up signed of f. From the grinding gouges from j the sketch 2 pages back here, you can see pretty much that the welds on the top part and the bottom part here were made. They were completely welded and when they did, what I believe happ5ned was the plates that they were putting in here, there was no l
requirement to be welded in here originally. Af ter these were '
cutoff and the pipe was damaged, they came back for the process sheet and they .
You can also see it on this one here.
They had empletely welded on there ... on the pipe. This was one side of the pipe; this was the other side of the pipe. They came back in, they ground them off, gouged the pipe, damaged the pipe, very sharp gouges, and then they came back with the process sheet that now they required f ull penetration welds for approximately 2" on this surf ace, tying the plate that they put on on either side ... this is your existing plate right here.
They required a weld approximately 2" in here of Deger weld to s
tio the plate into th2 othat weld, using the other weld to get a beveled edge. I KIRSH : How is that done?
It was in a really tight location. .. .
~
{ c KIRSH: No, what I'm asking is under what process sheet ... l I
was that un, der. a process sheet.
} That was done under a process sheet that was )
issued to ... I'm not sure if they issued the original process sheet to finish the welding, or if they came up with a ,:ompletely new one for the DCN disposi tion. You can see the disposition of 96, which was the original DCN, and the item that really was the cause of $7 was this comment highlighted right here. That was put in by the piping engineer who has to also disposition this DOI . When I write a DCN on piping, I have to get, number one, a field engineer's signature on it, and I ran around for auite scenetime trying to get a field engineer's signature on this particular DCN. I talked to 4 field engineers for $006 and all of them refused to sign it because of the line that I put in there that says the craf t working the hangar today, which were the people I was involved with, were not responsible for removal of Items 17, for places during which removal grinding gouges occur. These field engineers felt that if they signed that they would be implicating the night shif t, and although they' re not explicitly implicated by that statement I believe they did the -
damage to the pipe.
CLEWETT: Who are the 4 field engineers you talked to?
4 12 56
a s
I I
)Iwasnswct the tima and I wasn' t too aware of getting that' kind of documentation, so I don't know who I talked to.
, s LOCKERT :
you work with a certain inspecfor or engin,eer or s eth ng that you usually go to?
We usually have an area engineer that'll be assigned to work with us hangars. Those are the people that you j usually contact first and, in many cases, they refuse to sign my DO(s, so what my only recourse there is to give it to my lead, or I'll take it over to the engineering lead. If the engineering lead ref uses to sign it, as Mr. Pacifica has on several occasions, then I have no choice but to just note that and give it to my supervisor and let it go from there.
LOCKERT: Is this in accordance with the procedure for DCNs? Is there a procedure for DCNs that says this is how you accomplish....
The written procedure says that if you will get tog'ther e wit a field engineer and together you will come up with
.a disposition for the DCN. That's the intent of the field engineer's signature to them. I feel that once I write this doi, all I should have to do is put it in the box and it should be channeled to the field engineer there. You know, speed up . . . to keep production running and everything you oet the field engineer in the field. A lot of times some of these are things that -
really can' t be dispositioned in the field. Now, you know, work shift is no problem. I've written other ones with
( ' lack of document control where I find drawings that are not I
/ m l l- 84 - 57 1
otemped in should be out in the field and I write DCNs on that, and all the engineers sign it because they' re af raid if they sign it, foist it upon them. You can see the steps that prevent recurrence here were to 1*nstruct craf t to greater care . You'll notice "these l
attachments, spelled "attac", it looks like "n", that's HERNANDEZ: Was there ever a condition identified that maybe there was a violation of minimum wall? Is there any subsecuent action to vetify that there....?
On this particular one?
HERNANDES: Yeah.
Yeah, the process sheets were issued here and as i a you can see that disposition of the issuing sheet, the blend gouging and resove are strikes f rom the ASTC7 line, blend these
, o linear indications is on the same process sheet that PT and LTF require. New those PT and UT reports will have to be included with the original copy . That's another item. I never see those disposition PT and UT reports when I get one of these back. If I'm not satisfied with this when I get one back
" closed", I can go down to the of fice and look at it, but per se, I never really see that the actual field work has been done.
That's all taken care of through the process here. The thina that bothered me about this whole thing was if they instruct .
craf t to use greater care on grinding off a , for one thing no effort was made to find a craf t that ' lid that. Because the way it was done, they took these wrapper plates of f and they I h Il-12 58
/
just flung thsm about the room, hoping that nobody'd find tham.
It took the people that came back to work on this, they had the craf t guy there, the welder and fitter told me that they spent a couple hours looking around that heat exchanger rocin to find these wrapper plates to put them back on the pipe.
CLEWETT: You keep indicating that these component cooling water lines .were f ull of water when they did all this welding.
Yes, they were.
s HERNANDEZ : Can you lead me to any other person or any other documentation that would indicate that, yes, the lines were full ,
of water when this was done, r
The requirement for a line clearance is the reason that I know there was water in those line. You can also stick your hand up there and feel that when it's 50 degrees, you know '
there's water in the line. All the welding that I was involved with, documented on all these dailies in the heat exchanger room on CCW piping, I can tell you they were all f ull of water.
HERNANDEZ : Is this line....
KIRSH: Did you ever identify that on a DDN?
Ah, no.
KIRSH: '
That the line was full of water?
r .
l
- I don't even know what a DDN is. I KIRSH: Excuse me, DCN.
r s '
t) DCN? Ah, no, because per our specifications, .
'that's not Ideficient condition. I brought it up to Frank Leoty i and to my immediate supervisor saying that I didn' t f eel that welding a pipe full of water was very good practice, especially r
1-12 59 l
whan tha- carbon content of that pipe can go up to .30. Normally
)
you wouldn't have a problem welding up to .30, _althouah when you get past .25, you got to start thinking about special weldino consider a tions. But when you put a water heat sink behind it, you' re putting a pretty good quench raid on that weld which is not normally gonna occur, and with carbon on the high end of the l A53 specification, you could be getting under-bead cracking and i
not welding.
KIRSH: Okay, this is a reiteration of a problem that you had talked to us about the other night then, also.
Yeah, I was wondering if that crack or linear i indication coming out of the fill-it weld may have been a result of that .
, s HEFNANDEZ : Is there a . . . a cuestion again on this,'
Last time you indicated something about a p' reheat or a postweld
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heat treatment required. Are you sure that there was that requirement on that? Was there something in the field process sheet that said that there was a requirement for preheat or postwelding? ;
3 .
J No, that was on a dif ferent hangar. That was a fire protection system. But it was ... what I was told by the i
piping engineer over that thing was it was basically an '
interpretation of the code between two different engineers. One engineer was interpreting it as being anything 1" and above as a lug material would require preheating or postweld heat treating for 33107 and 331. The other engineer was interpreting it as anything over 1", so that up to 1" was not. . . . (This side of tape ends. )
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