ML20206H812

Rept of Inquiry Q3-83-001 Re Allegation of Improper Welding & Termination of QC Inspector Employment.Inquiry Closed Based Upon Seriousness of Allegation That Kent Terminated Due to Contact W/Bechtel Personnel.Related Documents Encl

ML20206H812
Person / Time
Site:	Midland
Issue date:	09/14/1983
From:	Pawlik E, Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206H499	List: ML20206H495 ML20206H725 ML20206H786 ML20206H812
References
FOIA-85-213 Q3-83-001, Q3-83-1, NUDOCS 8704150451
Download: ML20206H812 (55)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION b- f OFFICE OF INVESTIGATIONS FIELD OFFICE, REGloN ill

,8 GLE EL LL IS61R REPORT OF INQUIRY Date: September 14, 1983

SUBJECT:

MIDLAND NUCLEAR POWER PLANT ALLEGATION OF IMPROPER WELDING AND TERMINATION OF QUALITY CONTROL INSPECTOR'S EMPLOYMENT REPORT NUMBER: Q3-83-001

1. This Inquiry was conducted at the request of the Administrator, NRC Region III (RIII) predicated upon information that a quality control inspector's employment was improperly termi,uted after that inspector had made alle-gations to the Bechtel Power Company of improper welding at the Midland Nuclear Power Plant.

2. In March 1982, E. Earl KENT, a welding inspector formerly employed by the Bechtel Power Company at the Midland facility, contacted RIII and made allegations concerning the adequacy of pipe welding at the Midland site. KENT's contacts with the RIII Enforcement and Investigations Staff were documented in a series of memoranda and his technical con-cerns were reviewed in RIII Inspection Report No. 50-329/82-04(DETP);

50-330/82-04(DETP). In July 1982, KENT gave an affidavit of his alle-gations to the Government Accountability Project (Attachment 1).

3. On August 12, 1982, KENT was interviewed by 01 Investigator J. E. FOSTER and RIII Inspectors W. J. KEY and K. D. WARD. The interview was tape recorded with KENT's consent and knowledge. In the transcript of that interview (Attachment 2) KENT provided information of a technical con-cern pertaining to the Midland site, and to a lesser degree the Palisades, San Onofre and Zimmer facilities. Also, KENT alleged Bechtel Power Company terminated his employment, as a quality control inspector, after his informing Bechtel of improper / inadequate pipe welds at the Midland Nuclear Power Plant.

4 During September 1982 a series of memoranda (Attachment 3) pertaining to KENT's allegations and employment termination were received from Bechtel Power Company. On their face these documents indicate that KENT's employ-ment was terminated for " lack of necessary skills or abilities." The documents appear to reflect Bechtel's decision to terminate KENT was based upon his having met level II certification requirements at other Bechtel jobsites, but having failed to achieve a passing score on the Bechtel Level I certification examination at the Midland site.

5. On September 7,1983, James E. F0 STER, RIII Compliance Specialist, was interviewed by Investigator C. H. WEIL. F0 STER stated that on March 2, 1982 he informed KENT of the Department of Labor provisions against job discrimination and KENT did not express any interest in contacting the Department of Labor. F0 STER provided a written statement (Attachment 4).

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Q3-83-002 Page Two 6.

Based upon the seriousness of KENT's allegation that he was terminated due to his contact with Bechtel Corporation personnel concerning improper /in-adequate pipe welds, this Inquiry is being CLOSED, with the information to be incorporated into 01:RIII Investigation 3-83-007.

Charles H. Wei , Investigator Office of Investigations Field Office Region III APPROVED BY: bh Euene/~. Pawlik, Director Office of Investigations Field Office Region III a

Attachments:

1. KENT's Affidavit to the

Government Accountability Project

2. Transcript of 8/12/82 Interview

3. Bechtel Power Corporation Memoranda

4. Statement of Jares E. FOSTER dtd 9/7/83 cc w/ Attachments:

J. G. Keppler, RA:RIII A. B. Davis, RIII W. J. Ward, 01:HQ P. E. Baci, 01:HQ

0. C. Shackleton, 01:RV k

._- =u ROUTING AND TRANSMITTAL SUP itk (Name, onice aymbol, room number, T /f Q r fin ltions' Dese sullahng, Agency / Post)

1. JAMES G. KEPPLER g, BURT DAVIS 3.

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/ Action File Note end Retum Approwel For Oeerence Per Corrversetion As Requested For Correction Propero floph C6erutete / For Your Information See Me u.

2Domment investigste SignaturM.

g/Coord6 notion Justih C47a HD4AAM8 I have noted that a recent 1 o you '

suggests impropriety in the handling of the interview of Mr. E. Earl Kent, and requests that you listen to the tapes of the interview.

Therefore, this is to transmit one copy of the l

interview tape for your review. Please return the tape to me on completion of your review.

As this is an on-going investigation, no further release can be made at this time.

00 NOT vee this form os e RECORD of opprovels, concurrences, disposals, clearances, and namner actions pnoeL org. symbol en ROOM NO S $*

James E. Foster, Acting Director 01 Chicago Field Office Phone N[odI sKs.nor Om0NAL FORet 41 (ftev. 7-76)

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l T~ 3. Not prequalified for_ gas metal arc welding using short circuiting transfer.

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s. M AST E R OC sNSTRUCTION TI TLE y- QUALITY CONTROL INSTRUCTION 7220 FABRICATION, WELDifiG, HEAT TREATING, AND NON-DESTRtlCTIVE EXAMINATION OF ASME SECTION III - PIPING h JOB NO.

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Dwg. 7220-M-480 Piping Class Summary Sheets 11*

Owg. 7220-M-481 20* Piping Class Sheets '

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• NOTE Rev. Nos. sh )wn in Block 7 only identify the applicable r 3 visions of inspection critieria documents us ad to prepare Rev. 4 of this PQCI. I Subsequent r3 visions to the inspection criteria I that require revisions to this PQCI shall be noted appropriatelf in Block 11, i.e., "PQCI revised to

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GENERAL INSTRUCTIONS Purpose The purpose of this PQCI is to provide sufficient inspection activities to assure that the required quality for welding, heat treating, non-destructive examination, installation or rework of piping components (i.e., pipe, pipe fitt'ngs, piping subassemblies, valves, or in-line components) of any s17- or material has been achieved for ASME Section III, and non-ASME "Q" itsted Piping / Mechanical items.

Scope This PQCl covers the fabrication, welding, heat treating and non-destructive examination of ASME Section Ill and "Q" listed non-ASME Piping / Mechanical items installed by Bechtel personnel.

A. All ASME Welds shall be identified by individual weld number on the PQCI inspection Record (IR) PW-1.00. The scope of the IR shall be considered as extending from the scoped weld joint to include the piping in both directions to the next field weld joint or flange joint. Base metal repairs shall be shown on a

" Temporary Attachment Record" (QCF-41) and attached to the IR.

B. Temporary Attachments to ASME Sectica III Items.

1. Fit-up lugs and preheat /postweld heat thermocouple nuts used in conjunction with the fit-up and weld conditioning, shall be identified in the " Remarks Section" of the IR for that weld-joint and shown on a " Temporary Attachment Record" to be included with that weld's inspection record.

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2. Wnen attached or removed by Field personnel lifting lugs, pad eyes and other temporary attachments, used for handling, transportation or construction aids, that are not associated with a particular weld joint, shall be documented on a separate IR for installation and/or removal. A " Temporary Attachment Record" shall be initiated showing location of the attachment and attached to the IR.

C. "Q" listed, non-ASME Welding and Fabrication

1. "Q" listed, non-ASME piping / mechanical welding and fabrication (e.g. ANSI piping) shall be inspected in accordance with this PQCI.

D. Installation of a thermowell into a piping system shall be inspected in accordance with this PQCI.

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^ INSPE T ION INW SUPPLEb NrARY gg ACTIVITY DLSCRIPTION SPECIAL INSTRUCTIONS

1. Wnen preparing the " Reference Criteria," on the IR, the CQCE shall enter the documents necessary to perform the designated in-spections. These documents shall include, but shall not be limited to: (1) the primary specification (s), revision number (s) with all specification change notices (SCNs) and applicable field change requests (FCRs), (2) project engineering approved drawings with all drawing change notices (DCNs) and applicable FCRs. The primary specifications are those identified in Block 6 of the PQCI cover sheet.

NOTE: Reference criteria for active PQCIs/ irs shall be reviewed daily and changes in revisier, recorded on the IR. An active IR is one which the CQCE is implementing.

2. All documents used as inspection criteria for quality verification shall be " controlled" documents.

3. Where project engineering approved documents exist within the scope of work to be performed, the project engineering approved document shall be used.

4. If, during the review of the reference criteria documents or at any time later during the performance of these inspections, the CQCE determines the reference criteria documents are not adequate to per-form the required inspections (i.e., incomplete or omitted details, lack of cross-raferencing between drawings, documents requiring clarification, etc.), the lead discipline CQCE shall be notified.

The lead discipline CQCE shall discuss the problem with the project field quality control engineer (PFQCE) who will take the necessary action for resolution. The CQCE shall complete the inspection in compliance with the resolution.

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5. The inspection activity codes in Column 6 of the PQCI for in-process and final inspection activities are supplemented by one of three dif ferent symbols to further define the type of inspection required:

A. Visual Inspection (V) - to inspect by visual examination.

B. Measurements (M) - to inspect by physical measurement of dimensions or count of required quantity.

C. Visual Inspection and Measurement (V&M) - to visually ,

t examine to detect the apparent worst condition, take a measurement to verify acceptance, and visually compare the other items based on this measurement.

6. Incomplete items and nonconforming items noted during these inspec-tion activities shall be controlled in accordance with AAPD/ PSP G-3.2 to prevent their inadvertent use or installation. The type of documentation generated shall depend on the nature of the item as -

described in AAPD/ PSP G-3.2. Incomplete items which require documen-tation shall be recorded on the inprocess inspection notice form. All discrepancies recorded on the inprocess inspection notice (IPIN) must be closed out prior to final sign-off of the relevant activity.

7. The unique IPIN number shall be progressively recorded on the IR as each new IPIN is added to the report.

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Special Instructions (continued) f i 8. Either the Field Welding Engineer (FWE) or the Construction Qualitly Control Engineer (CQCE) shall make the " General Information" entries on the Inspection Record. In either case, the Level II CQCE shall review the data provided for technical compliance, and certify by' signature that the information provided is correct. Subsequent changes to the " General Information" need not be reviewed by a Level II CQCE.

Revisions to the QCIR necessitated by a change to the PQCl need not be reviewed by a Level !! CQCE if the new QCIR revision is prepared by a CQCE.

9. When welds are scheduled, the LFWE prepares the " General Information" and reference criteria sections of the QCIR and submits it to the responsible Level II CQCE for certification of its correctness.

The responsible Level II CQCE then obtains the Authorized Nuclear inspector's designated " Hold Points". The green copy may be retained by the Authorized Nuclear Inspector (at his discretion), and the white, yellow, and pink copies are retained in the QC files. When cleanliness inspection is required, the CQCE places them in a protective plastic

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envelope on or as near as' practical to the weld. After all of the activities on the IR are initialed and dated by the CQCE, he returns I the white and yellow copies to the QC office for a final Level 11 review. Af ter review, the yellow copy is returned to the LFWE, and the white (record) copy is retained in the QC vault. If the weld

requires NDE, the white copy is left at the weld joint, and the yellow i copy is removed and submitted to the QC NDE Coordinator with an NDE

! request. The Coordinator arranges for the appropriate NDE and when

completed, the white and yellow copies are returned to him with the i

NDE Report. After his review and sign-off, the yellow copy is returned to the LFWE, and the white copy is returned to the QC office for the final level !! review, and then retained in the QC vault. The pink

. copy is for use by the LFWE.

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10. Upon completion of the NDE with acceptance or rejection, the NDE Coordinator shall notify the LFWE and Superintendent of the status of the weld. A new IR, with the designation R1, R2, etc., shall be issued for each rejected weld requiring weld repairs. " Cut-out" shall be designated by adding a "C" suffix following the weld number. A new IR with the designation C1, C2, etc., shall be issued for each cut out.

11. At the direction of the PFQCE, UT, MT, PT and LT examinations may be performed by Bechtel QC Engineers certified to SNT-TC-1A Level II requirements using Bechtel NDE procedures. Bechtel QC Engineers responsible for reviewing, witnessing, and monitoring the , work performed by NDE Subcontractors shall also be certifled to SNT-TC-1 A Level 11 requirements.

12. An entry of N/A shall be made on the IR for inspection activities which are made not applicable by the entries in the " General Information" section. The Level II CQCE shall certify these N/A entries as correct by signature and date in Block 22. No initials and dates are required with N/As.

13. The responsible Level II CQCE shall coordinate the Authorized Nuclear Inspector's (ANI) review of ASME IR's to assure the ANI has ample opportunity to identify on the IR all required inspection witness and hold points.

.14. The CQCE shall coordinate the In-process and Final Inspection Activities with the Superintendents and Field Engineers responsible for production to assure that the required In-process and Final Inspection Activities including the ANI's witness and hold points are performed.

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15. The CQCE or FWE shall advise the ANI sufficient time in advance of designated witness and hold points so that the ANI may perform the required inspections and initial and date the IR.

16. Tne CQCE shall coordinate with the responsible Field Engineer or Superintendent on matters concerning rework or acceptability.

17. When welds are rejected by NDE, the NDE Coordinator shall complete Activity 5.2, and note the NDE reject in " Remarks". He shall maintain the open inspection record in his files until the weld is reworked, and accepted, Inprocess Inspectice Notice (IPIN) shall not apply to welds rejected by NDE.

18. When piping subassemblies are fabricated in the shop by Bechtel personnel, a Shop Release Form (QCF-47) shall be completed by the CQCE and the ANI prior to release of the subassembly from the shop.

19. The responsible Field Welding Engineer shall monitor the inprocess fabrication to the requirements of FPW-4.000. Evidence of this shall be provided by initialing and dating the PW-1.00 in the space provided.

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^f uo acisviiv oescairtior4 'Ns,*, y T 'o,N s,N5P c 9, 1.0 PREREQUISITES The following activities shall be accomplished after the IR is scoped for a given work operation, but prior to the performance of any in-process inspection activities.

1.1 Review the " Reference Criteria" to assure that all required criteria is None R listed with the current applicable revision and verify that the " Reference Criteria" is understood.

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QUALITY CONTROL INSTRUCTION 4 7220 7220/PW-1.00 4 tNsPE Y t ON th$ SUPP EM *8IAAV ACTIVITY DESCRIPTION NO 2.0 IN-PROCESS INSPECTION ACTIVITIES Ine following inspection activities shall be performed to verify that the in-process work is in accordance with the applicable " Reference Criteria" shown on the IR.

2.1 Verify that the pipe, pipe fitting, piping subassembly, valve or in-line M-204 5.2.1 I(V) component is free of damage. 5.2.3 5.2.6 6.3.2 2.2 A. Verify that the internal cleanliness of the pipe, pipe fitting, piping M-342 I(V) subassembly valve or in-line components is in accordance with Engineer-M-480 ing requirements.

B. Verify that proper precautionary measures are initiated to protect Mfg. Inst. 1(V) valve body and internals from the heat effects of welding and/or post weld heat treatment.

2.3 Verify that the parts to be joined are properly preheated prior to G-27 I(M) welding, when required preheat is in excess of 70*F. (GWS)(WPS)

NOTE: Record the thermometer number and calibration due date.

2.4 Verify that the Field Welding Engineer has initialed and dated None R the IR in the space provided.

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2.5 Verify that the pipe, pipe fitting, piping subassembly, valve, or in-line M-204 4.1.3 I(V) cc.nponent complies with the material requirements specified in the IR 5.2.3 reference criteria and the material identity (traceable identification) M-48) is correctly entered on the IR. When the piping subassembly is reworked, check to see that the required transfer of identification to maintain traceability of the components has been satisfactorily performed.

2.6 Assure that both Engineering and Field verified final closure points M-214 7.A-8-A R are evaluated for misfit in accordance with the requirements of the 7.B-8-8 specification.

2.7 Postweld Heat Treatment Inspect the in-process work necessary to perform the postweld h' eat M-204 5.1.5 treatment to verify that: G-27(PHT-501)

A. Temperature controlling, indicating and recording devices are I(V)

! calibrated.

NOTE: Record the serial number and calibration due date on the IR, B. The thermocouples are properly attached and located. I(M)

C. The heating elements are correctly applied. I(V)

D. The area surrounding temporary attachments have been marked prior I(V) to their removal.

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^'f uo Activity oescairvion 3.0 FINAL INSPECTION ACTIVITIES The following inspection activities shall be performed to assure that the completed work meets the quality requirements contained in the " Reference Criteria" shown on the IR.

3.1 Verify proper configuration and orientation of the parts to be joined. Dwg. I(M)

M-204 4.2 NOTE: The CQCE shall measure arrangement dimensions, as necessary to 5.2 verify that the configuration requirements of the drawing are M-214 48 being maintained. 5A 3.2 Welding .

Inspect the completed welds for the following characteristics: Dwg.

M-204 5.185.2 A. Minimum / Maximum specified weld size. G-27 I(M)

B. Minimum / Maximum specified weld length. I(M)

C. Weld location. I(V)

D. Weld contour. I(V)

E. Surface appearance. I(V)

F. No unspecified welds have been added. I(V)

G. Welds correctly identified on the pipe. I(V)

H. Welder's symbol on his work. I(V)

s. Pact ni ocuss

,,, , g

. - _ . . . . _ . . _ _ , .-. . _ . _. _..m__ __.m . _ _ . . - - _ _ _ _ _ . . _ _ . _ . . _ , . - . _

1 1 M ASTE R OC eNaTRUCTSON NO IKEV l

N PW-1.00 i g t' lif! QUALITY CONTROL INSTRUCTION *'"**'"""'""" "'"

d 7220 7220/PW-1.00 a

' ~ sueetsuaNT Rv Activity pescaserion saS**j',',o,a e,a,se

[of 1

3.2 Welding (continued)

1. Satisfactory removal of temporary attachments and fit-up lugs. I(V) Temporary Attachment-NOTE: When these attachments are welded to ASME pressure retaining Record material, their removal areas shall be examined by the liquid penetrant or magnetic particle method.

J. Surface of weld and adjacent base metal are in satisfactory condition  !(V) for performing NDE and obtaining interpretable results.

3.3 Review the welder's qualifications to verify that the assigned welder (s) G-27(WQ-1) R is qualified for the procedure used, thickness and diameter of material being welded.

NOTE: Record the welder's symbol on the IR.

i 3.4 Nondestructive Examination G-27

A. Radiography I(V)(M) RT Reports and Film Verify acceptance in accordance with Engineering requirements.

! 8. Ultrasonic I/R*(M) UT Test.

Reports i Verify acceptance in accordance with Engineering requirements.

i C. Bubble Testing  !(V) BT Test Reports Verify acceptance in accordance with Engineering requirements.

a ses ronu issssa * ' ^ 14 ' 17 "' '

i

.. .su o oc .NsTauci.oN No. j , v.

I PW-1.00 1 g QUALITY CONTROL INSTRUCTION "'"'

7220 JOB NO.

7220/PW-1 E <

SUPPL EME NT ARY

^f uo Activery oescairrion 8NSPE CT 80N $NS 3.4 Nondestructive Examination (continued)

D. Magnetic Particle I/R*(M) MT Test Reports Verify acceptance in accordance with Engineering requirements.

E. Liquid Penetrant I/R*(V) PT Test Reports Verify acceptance in accordance with Engineering requirements.

• NOTE:

(R)actcodeapplieswhenNDEisperformedbyasubcontractor.

(!) act code' applies when NDE is performed by Bechtel personnel.

3.5 Postweld lleat Treatment Review the post weld heat treatment temperature / time recorder chart for G-27(PHT-501 R PifWT Chart weld identification, heating rate, cooling rate, heat treatment time and temperature.

3.6 Review the attached inprocess inspection notices (IPINs) to assure that None R the IPINs have been completed.

88S FORM 18555 2

• '^ '15 '17 '

. - Asuo oc INsuocTIo~ N a ja m PW-1.00 g.

[ gf!N QUALITY CONTROL INSTRUCTION 7220 JOB NO. a 7220/PW-1.00 INSP CTION INE SUPPLEMENT AMV

^f uo I activity oesca:Preou 4.0 REVIEW 0F SUPPLEMENTARY RECORDS Tne following supplementary records identified in Column 7 on the PQCI shall be reviewed to verify that the required quality documentation nas been satisfactorily completed and is available for filing with the IR. NDE Reports shall be reviewed by personnel certified to SNT-TC-1A Level Il requirements.

4.1 Postweld Heat Treatment Charts R 4.2 RT Test Reports and Film (original of RT test report with IR and copy of R RT test report with film) - Record NDE Report Number .

4.3 UT Test Report - Record NDE Report Number R 4.4 BT Test Report - Record NDE Report Number R 4.5 MT Test Report - Record NDE Report Number R 4.6 PT Test Report - Record NDE Report Number R 4.7 Temporary Attachment Record R 4

s.PAGE or OCG65 86S FORM 18555-2 g

l M ASTEle oC NSTHuCTiAN N3 H ( V.

PW-1.00 g

[ l QUALITY CONTROL INSTRUCTION 7220 raosect oc iusrauctiou wo a a v.

[k,g'-

JOB NO. 7220/PW-1.00 4

^'I uo Activirv oescaserion ins,eg t son

, ,, " ,,i,wg,, suert,eue,at

, , , Aav 5.0 EXCEPTIONS 5.1 Review the completed IR to verify that the applicable inspection activities None R nave been performed without any exceptions. If any exceptions exist, complete Activity 5.2.

or 5.2 Any inspection activity exceptions noted on the IR are to be identified None R and described on the IR under " Remarks" and processed in accordance with PSP G-3.2.

ses ronu issss 2 S. RAGE of OCG65

/gffl b- , ,, ,, D in.60H OUAL.

R _

CONTROL INSPECTION RECORL s

% OC Fila No E O X -/72 -/ /'IbO '55 - 2 8 6,,

POCl NO. 7220/P W-1.00 REV. / ppg s s ,ow ,,s,, .w .., WELDING HEAT TREATMENT AND NDE OCIR No. M-##8-SF" GENERAL INFORM ATION ACT ITEM ACCEPTANCE Unit No. / NO; DESCRIPTION

1. C E COCE Date l ANI lDate Location 1.0 PREREQUISITES N 'd /-N-Weld Type ( ) FPG ( Wocket ( ) Attachment see meterence 1.1 Reference Criteria Reviewed and Understood R k ([)g

2. Engineering Specification No. cnipria snee' 1.2 ANI Recuirements R bb \k

3. ISO or Drawing No. J# // ////4..ff 2 2.0 IN. PROCESS INSPECTION

4. Weld No. 7/ 2.1 Materials Free of Damage I b Ihip-

Repair No. #

5. Original 2.2 Internal Cleanliness  ! 02<

(h$/*

d

6. System or Component gg g 2.3 Weld Prehea L cE ' '

7. Pipe Diameter Therm No. cat oue hlh$/@

8. J int Thickness # a)e, A g,gg g p

9. Socket Welds: v ~

Wall Thickness / Weld Size < .2/[ .[

- S , 2.5 Matenal Requirements

)(Scribe Dimension # 1 b / .28.~f/ - ded to

~

10. SA/ ASTM Material 8 M ee Type and Grade

• yea f 2.7 vew m Postweld Heat Treatment R Q$ Md i sion No. & f ****'**'*C*'*'***'O**-

~

12. Filler Mat'l Type [M) Oj FIN AL INSPECTION

{ U I'M-insert Mat'l Type l.he Configuration and Orientation

13. B cking Rings Requi ed M g M Completed Weld I b f-?cd4 k Inserts Requiree Purge required 3.,

4' Gas Type #,

%T) Welder Qualificat(on W .I Symbot(s): v-1 % 4 R hg (.29R )i

14. qa$ NDE ACC. REJ. '

Flow Rate W CS a. RT I .

15. Priheat Temp. O 'F Minimum

• b.UT l/R

{

Interpass Temp. JR *F c.BT l

16. PWHT Temp f.A > 'F c d. MT 1/R  ;

Holding Time 2A* Hrs.

2 )e.PT 1/R t

17. RT Spec. No. '/* Rev. j)4 ostweld Heat Treatment R ,k

18. PT Spec. No.

• Rev.A /* N 'flN No. KlD R [ l-2962. l

19. MT Spec. No. 42 Rev.> " EdfrifgUPPLEMENTARY RECORDS I

20. Other NDE Spec. No. M U Rev.O N-'t "*iostweld Heat Treat Chart R b I 4.2 RT Reports and Film R 1 I g , h

'Pripared by (FWE)(COCE)

Da

[ 2 4.3 4.4 UT Test Reports BT Test Reports R

R

22. ABOVE REQUIREMENTS CERTIFIED CORRECT 4.5 MT Test Reports R 4.6 PT Test Reports R v o- b e.};,g '

,' Date / -I', 6L' 4.7 Temp. Attachment Record R @ /-2967 COCE Level 11 5.0 EXCEPTIONS

23. Authorized Nucle r 1 3 cto) Hold Points 5.1 No Exceptions I'N Act(s) No. M C-- /4 N or Indicated exceptions bl 5.2 described in Remarks

?4 RImtrks [ / k . ;'hc, ) ,. g /-p$"y L _

I "h, h ; @ . [ 7 " ^. 9 r -,g t it :- t, a

-* - -s v., , ;,

25. Hold Points reviewed and Acetoted (ANI) ON - Date d 'b b

26. Abova Results Certified Co:ver.t (COCE Level 11) -

MI Date--o'L48L ---

"*S' ' '

p. _',~ -

7Mtttntirt:0PY"-~'M -

OUALITr CONTROL INSPECTION RECORD '

~b Php'fh POCl NO. 7220lP W-1.00 REV.J OC Fil'e N "

Log No !NdD-ses now *w? aav se, WELDING HEAT TREATMENT AND NDE OCIR No. /M- M-6fI

'I GENERAL INFORM ATION ACT ITEM ACCEPTANCE

1. Unit No. / N O.

DESCRRION C E COCEI Date ! ANI ICate Location O./'-['

1.0 PREREQUISITES g h-2W2.

Weld Type ( ) FPG (-1 Socket ( ) Attachment 1.1 Reference Cnteria Reviewed R

2. Engineering Specification No.

see aete'eece C'de"e 5"e" 7.2 and Understood ANI Reouirements R I

) /

(

3. ISO or Drawin No. [J/- d/MC M- J 2.0 IN PROCESS INSPECTION

4. Weld No. 2.1 Materials Free of Damage 1 Onginal - Repair No. #

VMIWU .I

5. L i I 2.2 Internal Cleanieness I System or Component / j/f'I f / i 6.

7. Pipe Diameter < ,<

2.3 Weld Preheat Therm No. Ca oue

, g l

8. Joint Thickness W p E,, pgG p

9. Socket Welds:

Wall Thickness / Weld Size < .) // 2.5 Matehal ReQunements Scribe Dimension E' W ided to:

' iN

10. SA/ ASTM Material NM d***o7 88 :2,( a 2.6(30 Type and Grade R l @ by l h '

Postweld Heat Treatment vision No. /- / d/ '

1. • C '8 S* canoration oue ___ //A

12. Filler Mat'l Type [ '/' d d E CM FIN AL INSPECTION 7

Insert Mat'l Type Xi^ c: M Configuration and Orientation j 7MZ- l

13. Backing Rings Required 4 ^- (- h Completed Weld l l hy, ?2-S d /l Inserts Required he .

3$ Weider Qualificatton .i ] l

14. Purge required A9 Gas Type # 3 (2'5.r

. 3 Symbol (s) M L* "'

\ M lL2'282 / I

'g

,_3 NDE ACC. REJ. .

Flow Rate M .

a.RT I s IS

15. Preheat Temp. *F Minimum ( -N.,$ b.UT 1/R j interpass Temp. _ >>A 'F ,Q c.BT I

16. PWHT Temp Holding Time 11

• M*

• F Hrs.

([.i d.MT e.PT 1/R llA Y h\~~

g ((l'-h Postweld Heat Treatment

17. RT Soec. No. B* Rev. 4'

• R dL I 18 19.

PT Spec. No.

MT Spec. No.

M P

,_Rev Ad/

Th ,/>^

~

4.0 IPIN No. 4 A-SUPPLEMENTARY AECOADS R ( '2 -M2. l I

20. Other NDE Spec. No#IMYRev.O 4.1 Postweld Heat Treat Chart R 4.2 RT Reports and Film R .

f

~ $ 7 4.3 UT Test Reports R

21. Date drspared by (FWE)(COCE) 4.4 BT Test Reports R

22. ABOVE REQUIREMENTS CERTIFIED CORRECT 4.5 MT Tast Reports R 4.6 PT Test Reports R 4

v. y , I, b l' -42.- Date /-U.E '- 4.7 Temp. Attachment Record R M M6*L l COCE Levet il 5.0 EXCEPTIONS Act(s o. 1 [7/& r indi ed c ptions U 5.2 described in Remarks

4. R; mirks -

r'"r y/% ff" y O f 5 ~'"' @

i ~ *.: , ' '?. .

,L U .

, Es.g.-

q. * ,- - -

. _ >}

h

23. Hold Points reviewed and Accepted (ANI) #/8tM /d / Date I8'~N

26. Abova Results Certified Correct (COCE Leveli Md Date 2 't8~h

-w Pag? of 8__

fI -

QUAL'Il T EONTROL INSPECTION RECORD OC Fila No. I H K '=-6-2 _

POCl NO. 7220lP W-1.00 REV.3 W $

S%b '

Log No.

es ron; mo may .., WELDING HEAT TREATMENT AND NDE OCIR No.N/M/4[85f'8 GENERAL INFORM ATION ACT ITEM ACCEPTANCE

/ S ON ,COCEl Date ANI lDate

1. Unit No. NO. C E Location OM 1.0 PREREQUISITES D 5 P26 Wild Type ( ) FPG ( -7Tocket ( ) Attachment 1.1 Reference Critena Reviewed R q see Reference and Understood )

2. Engineering Specification No. C'd.a smeet 1.2 ANI Reouirements R I ISO or Drawing No. ^ d'/ N'd 2.0 IN. PROCESS INSPECTION 3.

4. W;ld No. / 7 2.1 Materials Free of Damage 1

& l-2962.

5. Original - Repair No. >>'

6. System or Component /Mb II h,$"freheat l

Pipe Diameter Therm No Cai Due 7.

8. J: int Thickness M' Dap g _g ,,

9. Socket Welds:

Will Thickness / Weld Size

, j// /// 2.5 Material Requirements Scribe Dimension d kh w, n.

I 2M

10. SA/ ASTM Matenal N/D I 5I 8 bd  % p_ $ (oC) s Type and Grade g g/pf a m oto E :-rnit,B a

Verified Closure R Qq 2,; gt l

11. Wilding Procedure and R; vision No.

d' 26

~'

! .)

/ ( n 3,$

"'CC'O S*

FIN AL INSPECTION caubration Due _

jr A,4 N

12. Filler Mat'l Type '

Insert Mat'l Type jfA F '*M Configuration and Onentatio S 229 1

13. Bicking Rings Required M j Completed Weld I %b 2 ~2 -p I I

Welder Qualifi tion Interts Required > > ' d ;.7 Symbol (sr nG ( R .g.2 M )

14. Purge required Flow Rate 1,f l 5-Gas Type .M*

(TM NDE a.RT ACC. REJ. \ __

I #

g rD

15. Prsheat Temp. O *F Minimum,;,. ,, b.UT 1/R f' -

'interpass Temp. /J' 'F dh;as c.BT I g- Y

16. PWHT Temp A'd *F

{ d. MT llR f/A N g

Hoiding Time >>' Hrs. e.PT 7 RT Spec. No. //' Rev &' 3.5 Postweld Heat Treatment R g; l 17.

10. PT Opec. No. //2 Rev. "

Rev. gr.:

3.6 IPIN No. M R' Q 2 2-8 *-.

19. MT Spec. No. ,* 4.0 SUPPLEMENTARY AECORDS

20. Other NDE Spec. No. (4 -D'/'8 Rev.O 4.1 Postweld Heat Treat Chart R /N 4.2 RT Reports and Film R /

A '^ 4.3 UT Test Reports R s .s 21.

Date '. /

" Prepared by (FWE)(COCE) 4.4 BT Test Reports R 4.5 MT Test Reports R

22. ABOVE REQUIREMENTS CERTIFIED CORRECT 4.6 PT Test Reports A 1 (of D.3L D ~ Date l* 2 b F>? 4.7 Temp. Attachment Record R M g.7.gg l COCE Level 11 5.0 EXCEPTIONS

23. Authorized Nucle Act(s, No. A/d o clor Hold P i ts M 7

5.1 No Exceptions k$ 2'28E.

, or Indicated exceptions 5.2 described in Remarks

'24 R; mirks

, ,E-4 - .. .,

9 fI* fh P. E W' " n.: . N .b ?, '

IN h3 U h.? . ,

Y y

23. Hold Points reviewed and Accepted (ANI) IhM64A-- ' Date M'_7'T"

26. Abova Results Certified Correct (COCE Level 11) O Mh Date MS I2.

edY AFFIDAVIT l

My name is E. Earl Kent. I am making this stathment of my own free will to Mr. David Crow, who has identified himself to me as an investigator for the Government Accountability Project. I am speaking without threat j or promise of material benefit. My reason for making this statement is to express my deep concern over the

/N NNLfMt W08K 6fNHAuk' quality of constructiongat the Midland, nuclear plant, IN Afy'OflN(CW, where I was terminated in March of 1982 for persistently g

b' ringing defects in construction and specifications totheattentionofmyf;r y M [/9"h##88//9 M ,

I have worked for seventeen years in engineering, '

~

hew most recently at six nuclear plants. I -hem the title of 8enior Quality Control Engineer.for nuclear welding.

I have been a member of the American Society for Otrality Control, and have published several books Before coming o on welding and structural steels.h6NWit AN WfAP/NR Bechtel, I worked as an engineerjfor Litton Industries, as a field N 1 ding pector or Boyle Engineering

- ifJR d(Wff# AN>

Corporation, and as a lding gupervisor for Fluor Engineers. Ihavealsoworkedasakualityfssurance andhalitykntrolIngineerforJoyManufacturing.

. I have attended more than half a dozen professional education courses on engineering and quality control. .

Prior to moving to the Midland plant, I had. worked units, Pal isades

. for Bechtel at two of its other nuclea Q3-83-001; Atch. 1 W

Pega Two Ah> $W l and San Onofre Plants Onej and Twoj In both of these earlier Bechtel positions, I served as Senior Quality Control

• l Engineer. I received top recommendations from my

• supervisors at both these plants. There is a letter on file with Bechtel's office, from the Vice President of Bechtel's Los Angeles Power Division, for my work there.

SNGINpftr/N4)gP Basedon)(myyearsofjexperienceinnuclearplants, it it my professional opinion that the Midland plant .

is the worst nuclear facility I have ever seen. This affidavit will detail instances where Bechtel Corporation-has systematically downgraded standards for safety-related equipment, to the point where I Whmondr believe that much of'the construction will not withstand the stresses it should be built to take. Bechtel has hired engineers and OC inspectors who are not adequately qualified or trained for the complicated work in a modern nuclear plant.

I have seen Bechtel personnel, both OC inspectors and engineers with QC responsibilities, routinely accept substandard work. ,

I will also give examples of the unhealthy degree of reliance that certain NRC inspectors have placed in the Bechtel personnel whom they are supposed to monitor. NRC

\

field inspectors showed a surprising willingness to let the Bechtel personnel do all the dirty work involved in supposedly independent investigations. Becaune siL inspectors of, ten didn't themselves try to take the l

Pag 2 Three measurements, or climb into less accessible areas, the inspec-tion reports that were supposed to represent a completely i separate check on Bechtel performance of ten wound up basing their approval on Bechtel's evaluations of its own work. ,

f}/41W6fAJMSAND My expertise is in weldingginspection. When I first came to Midland, in December 1981, I reviewed Bechtel's specifications and procedures. I was astonished to see that in numerous places, Bechtel had established standards which fell below those of the ASME Code. The ASME Code reflects the best judgment of the national society of professionals in this f.gfGAtt6flANP area. It is the result of many years ofgtesting. Despite this,Bechtel in some cases made the decision, based on their flNicNJ OK own engineers' short-term testing in San Francisco, to modify these standards.

If Bechtel had made these changes only to take account of particular needs at Midland, that would be 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 I e in my files. It is between the project QC head, E. Smith, and a 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 with- ,

drawn from the fitting it will be approved. This means that a l gap of nearly ~any length will be tolerated betNeen the end of 1

\

the pipe and the botton of the socket, Theno gep: ..cah.in th: 1 FAILVilfo?dhf6fAlbf DC)Lidd joint, and make it susceptible tojvibration. The AS:lE Code

• l l

Paga Fcur has, for this reason, established a much more rigorous specification.

This is only one example of the systematic downgrading of welding standards I saw at Midland. The Hackney memo became-one of many sheet-memos placed in the specifications book.

. Equally as serious as the problem of downgraded specifi-cations were the problems created by the incompetence and ignorance of QC. Even something 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 inspectorsj JNb #A/4W/4Af, In early February, I was working with one of these Bechtel QC inspectors, John Kunski. John was about to approve a fillet weld when I saw that it had not been fully welded. .

Fillet welds have to be full across the blade, not just touch-ing one edge of the blade. I drew John a diagram to show him this. When John looked at the diagram, he saw that I was right.

But_the welder refused to put any more weld on -- he sa.id he'd been doing it that way for two years, and his boss had always approved it. We finally had to call his boss in, and explain CDOLO it to him, before we 6 get the weld h redone. Paul Schulz, another QC f/Vd/YM

.i. _ i r,ywas also there to hear the explanation, and he admitted af ter I showed hi'm the diagram that he'd been approving bad welds himself j ///fr///4Ng F/40##A/77A/c

/({p68Il/ AJJKWADf Unfersized AS$2/M74PERV4%

and improperly done welds were . serious problems, but at least they didn't affect the intearity of the piping 450C.Of itse1f. High-pressure piping, bwhicip$L95'd[AfsirTi!-M ontains up to 1500 pounds sGC ddN i

per square inch, is very vulnerable material. Itjreact)( like

l

. . 1 Pr.g3 Five a balloon to a pinprick. A weakness in any part of the piping is a danger to the entire length. 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 h - s w ^ ll<7z4 0 4T Y$Z- lllA dEWn -

This was not only a violation in itself. It was part of a larger problem having to do with inspections of the parent metal for the piping systems. In small bore piping, the only

'TN0140VGHN' WSAAD)2/ /M 791Abffff,M way tojinspect the inside of the piping forjcorrosion,is to of -

take what is called a thickness W materials (TM) reading.

This[BMMMM OH.d_Nf PIPS, IRIS Ccypjffytf' AMP isga time-consuming process if donejcorrectly. To the best of my knowledge, the Bechtel QC inspectors rarely took the time necessary to do this type of verification. They usually relied on visual inspection only. Visual inspection

• can detect corrosion only on the outside of the pipingj 0fMO6ft' When I performed a thorough inspection myself of the piping, using readings for the inside of the pipe wall, I

~

discovered extensive corrosion. Although the QC reports appear to assure that the piping is of safety-grade quality, these reports fail to reflect the problems of the piping systems which I discovered. To allow severely corroded piping to be approved for safety-related systems is,in my opinion jinexcusable, l and certainly very dangerous to the successful operation of >/A/

p plant.

Another piping problem with which I wasjersonally lCV-Ht'D)20GffI familiar developed because Becht ci allowedgelectrodes used in Nor OYGNS #A welding to be taken out of theirg hermetically-scaled containera

s Paga Six t)P fo l forgeight hours before use. The American Welding Society (AWS) hfMIkWhf standard allows only four hoursjin the,open air. When the i electrodes are left out, the chemicals in their coating attract s

ambient humidity. When this moisture is absorbed, it will become steam under the heat applied duri jn the welding process.

AkVT Each speck of moisture will expand toj 750 times its initial m ,. . _ . . . . ,,.-,,y volume anb'r.esults in substantial porosity, or simply empty

, space, within the completed weld. The weld will appear strong, but be weakened from within. The AWS standard is used for -

ordinary bridges and office buildings, but apparently Bechtel thought that twice as lenient a standard was appropriate for a nuclear plant. .

X-ray inspections of welding, performed under these ,

i conditions has revealed porosity. The welds have had to be j

OtW 4een out and redone, not just once but many times, of ten within the same joint. This is one more exan.ple of Bechtel's not doing it right the first time. Every time they had to tear the welds out and do them again, it added to their costs and to their profits.

Bechtel has a cost-plus contract, and had routinely wasted large amounts of money because they have little incen-tive to do the work right the first time. Each time further expenditures are required to redo work, it adds to their fee.

I have seen work ripped out because of shoddy installation, redone, and then ripped out and redone again because it still wasn' t right. One OC engineer, who has been at Midland ci..cc--

Fon- #fdh'Yl's4M, 1

1

P gs Ssven JM f]IG Of/NIDM, e.: i ;i. 9 g, told me thatj over 90 percent of the piping in the entire plant has had to be cut out and replaced at one point or other. In my mind, this raises serious questions of safety, but it also makes me wonder who is going to wind up paying the bill for Midland. Bechtel's indifference to quality will cost the ratepayers a bundle,.if they are allowed to ,

pass on their costs to the public.

1%fts/AUE The defects I have described are genericj to the Midland plant They have happened because Bechtel has hired inexperi- -

/Nff//f encedjwe ders a.ond inspectors. There were few formal require-mehts to become a welder, or even an inspector. If this was 1

supposed to be corrected -through a thorough training program, j 1

it didn't happen. The training periods were only a couple of.  ;

B NGIN W l weeks, and based on my experience in working with thejwelders ,

'and the inspectors, I can state that they were not properly AN9 $$6/WLkfBf trained. When inspectorsjdon't know how to use a fillet gauge to measure welds, you know that the overall program standards J

cannot be yery high,4H0 d COnl/*S15JMW4fid4YlcNJG RHtt/t4Nf1;O, 1 NRC inspections of ten failed to correct problems. In l the area of the inside wall corrosion in small-bore piping, NKe this was because theg i nspectors seemed too willing to trust the Bechtel inspectors when they made their tours. It was generally the echtel people who actually climbed around on -

the piping and called out their measurements, which the NRC inspectors would then write down. As a result, trany of the ,

inspection reports do not reflect anything more than Becht.el's own assertions.

_ _ _.3,..

l 1

Pags Eight 1

Even when the NRC inspectors did show a willingness to -

0FnW l carry out a real inspection, they wouldjbe handicapped by their practice of not coming in unannounced. To the best of j my knowledge, there were no NRC inspections that weren't pre- -

ceded by two-ez O.r;; da,; ci preparation directed by Bechtel, AfD.D/f/2D, during which problems would be repaired and someimes -W.

fB414vV As a result, the inspectors emner saw the plant as it really l

l operated on an every-day basis.

My alarming experiences with the field welding and the '

SAIGN5Mitf AND QCji nspebtors led me to speak to my boss, Mr. William Creel, numerous times in December and Ja'uary.

n Bill generally had the same response: he said that all his men had passed the Bechtel tests and were fully qualified, and he was willing to take their word for it if they said construction was safefND 4PA56/#Te My real problem began when I tried to talk to the head

.of Project QC, Mr. Eugene Smith. He told me what Bill Creel was saying, that everybody was qualified and so there couldn' t 1

be problems like the ones I was telling him existed.

l On Friday, February 26, Eugene Smith called me into his of fice and told me I was to be terminated. Bill Creel was also there, and the two of them told me that I hadn't been i

able to adjust to the way things were done at ' Midland, and so )

they would have to let me go. They asked me if I had any ,

l WYitten comments to make on the termination notice. I wrote

~

down; ",I do not agree with any of the above, and ask for a complete investigation of this and all other main proble:ns, l l

by the San , Francisco home of fice, and especially Mr. S. Bechtel.

. \

1 l

P2g2 Nina 06hf TO V critical welds Never in my life have I MP'THfM ever seen so many}NffG644 FCUNPI)M

, accepted in nuclear worg , If this many errors are allowed to exist, the results could be catastrophic."

~

Af ter I wrote . this down, Mr. Smith must have called Ann Arbor Headquarters, because he told me to go see Mr. Don Daniels on Monday. Mr. Daniels met me at the Holiday Inn in Midland, and I tried to explain to him the problems I had seen in the field and with QC. I drew him the same diagrams I had drawn for John Kunski, about the welding standards. All he GNGINt4 said to this was that all thegwelder% s and inspectors were qu'alified . The feeling I got was that even if I proved what I was saying, Daniels wouldn' t do anything about it. He SVIOSNTL.Y couldn't believe what I was telling him -- hejbelieved in the, papers that told him the Midland personnel were qualified.

Before Daniels finally told me that I would have to be fired, he made another phone call. I believe it was to Eugene Smith and Bill Creel. Creel was the one who most wanted me to go, IAl Mr D// Alto /V-I was also told that in addition to my bad adjustment to Midland, I was being terminatcti b cause' I had failed to pass the Bechtel te'sts for Lere '. 7 A engineer. Now as I

$ddlN6BHMS stated earlier, I have seventeen years ofgcxperience in QC and' welding. At other Bechtel installations, Palisades and -

t SanOnokfre,IheldbothLevelIandLevelII certificates.

Midland was not that different from these other Bechtel opera-tions. I cannot believe that I hadn' t passed the Level I test gt Midland.' I was never given a copy of the written part of

1 Paga Tan

~~. ,

i the test. I can only believe that I was fired for insisting 1 that there were serious problems at Midland which my superiors refused 'to acknow1 edge p hMP N2HCf KSFuiSP 7b Ed/5ffR, Because of the way I had been terminated by Bechtel, a and because I felt that my observations had not received anydpsfu(; ,

attention from the internal hierarchy, I decided that I should speak to the NRC. On March 2, 1982,'I arranged for a telephone interview with Roger Warnick, William Paton and Don Danielson i

of NRC. In that interview I told the$2NS&4W mjwhat I have detailed here in this affidavit. I told them I felt that Bechtel was not adequately investigating the ' serious problems I had tried to bring to their attention, and that I felt I had been fired for trying to do this.

After I spoke to the NRC, they sent out an inspector)[

to look into my allegations. His report indicates that he

, spent three days on-site. I don't think that a full investi-gation could be conducted in such a short period of time, by only one inspector. However, I do feel that the report con-firmed my charges, based on what happened when the inspector met with the top men from consumers, Fr. Marguglio and Mr. Bird.

The inspector found them to be extremely hostile to any sug-gestion that there were serious deficiencies with welding and with QC procedures and qualifications. The inspection report 1

~ found that\ further investigation was warranted in this area.

j . l l

Although l

the report noted the need for further oversight, i it seemed to feel that voluntary menibri4 9 a _,c..a el oy Consumers would clear up the problem. The problems are too 1

I

Prg3 Eleven serious and widespread j to be lef t,to be corrected by the people who created them. I believe that only an independent JNo and comprehensive investigation, by the NRCias by outside -

Witc. BS experts, can provide the assurance that Midland sej properly built. '

I am sure that consumers and Bechtel will respond to my charges the$h auqr WW way they responded to the NRC in-JW MYC/mto They will deny the p%roblems and promise voluntary spection.

4 ,

ef forts "to cure them. They will try to ruin my credibility, by, saying that I was incompetent,' that I couldn't pass the basic tests. Nevertheless', I stand by my statement. After-

. AND Wi& DING A01WCEj nearly twenty years of work as an engineerj I know a defi- .

cient weld when I see one, and I knowJhme many of these welds and other problems went undetected (or ignored)by the men responsible for inspecting them. Bechtel has shown by its attitude that it cannot be trusted to perform work of the high quality necessary in a nuclear plant. I feel that a full investigation into its management and construction practices will show that much work will have to be redone before Midland can go into operation. The cost will be enormous, if it can be done at all. Despite the cost, .

I cannot stand by and watch the plant go on-line in its present st te of safety. To do so would be to betray my responsibilities as a professional, as an engineer, and i

e i

l

i Ptga Twelvo , , l i

as a citizen, ,

I have read the above twelve- (12) page affidavit. To the e

best of my knowledge, it is true, accurate and complete.

J E. EARL RENT '

SUBSCRIBED AND SWORN TO before me .

this dday of [v/_P,1982.

.. . a .o Notary Public

, 1>'*~~~==~--a,_. ,

OfflCIAL SEAT '

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Dete ROUTING AND TRANSMITTA1. SUP 8 // M TO: (Name. office symbol, room number, initials Date -

building. Agency / Post)

3. KAVIN WARD

2. DUANE DANIELSON

3. CORDELL WILLIAMS

4. WILLIAM KEY

5. ROBERT WhRNICK -- --

7

/ Mon File '

Note and Retum

[ Approval For Clearance Per Conversation As Requested For Correction Prepare Reply Circulat8 IFor Your Information See Me

/ Comment investigate Signature ~~-**

1. YCoordination Justify ,

REMARKS

. E. Earl Kent, former welding inspec or trainee at,the Mi land facility, will, e visiting t the RIII office,0:00 toinorrow a.m.. (8/12/82) at approximately 1 He wishes toediscusE '

his concerns relative to welding at the Midland plant. I want to have him detail his concerns in complete detail, and then have some discussion j

as to our previous review of his concerns, and' possibly discussions if some of his points'are not clear or technically correct.

I tentatively plan to have the session tape recorded, and would appreciate the participation of any of those on the above list, other duties permitting.

DO NOT use this form as a RECORD of approvals, concurrences, disposals, clearances, and sJmilar actions FROM: e, org. symbot e ost) Foom No.--Bldg.

ames . os er, Acting D rector, OI Chicago Field Office h No.

2668 1-102 OPTIONAL FORM 41 (Rev. 7-76)

Prescateed er GSA

• cPO e 19 81 0 - *

• l 12 9 (17 0 3 FPa8R (41 Cfh) 301-11.3o6

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l NRC Form 3o7 (1142)

( ALLE7ATlIN DATA FORM Instructons on reverse side

.s. NUCLEAR REGULATORY COMMISSION RECEIVING OFFICE Docket Number (if applicable)

1. Facility (les) Involved: (Namel (if more than 3. or if generic, wnte GENERIC)

N/)OM)

2. Functional Area (s) Involved:

(Check appropnate bon (es) ) , operations _ onsite health and safety construction offsite health and safety

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4. Source of Allegation:

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_ licensee employee news media

_ NRC employee private citizen

_ organization (specifyl

_ other tspecifyl MM DD YY

5. Date Allegation Received:

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6. Name of Individual (First two initials and last namel * /

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(11-82) Instructions on reverse side l RECEIVING OFFICE Docket Number (if applicable)

1. Facilitylles) Involved: (Namel (if more than 3. or if genenc, write GENERIC)

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2. Functional Area (s) Involved:

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_ NRC employee private citizen

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5. Date Allegation Received: g ,

6. Name of Individual Receiving Allegation:

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{ly o f [. /$Ulfh / l$ W/ h E_.!' -

lf' f LeGoff: In his three-month. probe of the Midland Nuclear Power Plant, Channel 7 Investigative Reporter, Steve Handelsman, discovered 4

evidence of serious welding problems in the Plant's vital water 4

piping. Steve is here now with part two of his special report.

Steve.

.4 Handelsman: Thanks a lot, Jack. There's a system of checks and rechecks at

[ any nuclear power plant. One worker does a job, then that work is inspected, the inspection is inspected and so on. -But a former top nuclear welding official who worked at the Midland Nuclear Power Plant says that system checks and balances broke

' down at Midland in the area of critical welding. Here's part two ,

of my Target 7 report.

Like a human body, the Midland Nuclear Power Plant has a circulatory system. The Plant's lifeblood is high pressure steam and water. Its veins and arteries are steel pipes and, unfor-tunately, like the human circulatory system, Midland's system can have flaws - flaws that could cause the nuclear equivalent of a heart attack. The reactor is cooled by one set of pipes. That

! loop is cooled by a second system. The heat from that system 4

produces steam in a third loop, cooled by a fourth loop, backed j up by a fifth loop and so on. And all of the piping here is i welded together.

Earl Kent lives in California. He calls himself a welding expert l i i and has the credentials to back up that claim. He has written  ;

two' books on welding and numerous technical papers. Kent has )

4 l

j rp1082-0655a-96 h /2 - ,

• 2 been a Senior Quality Control Engineer at the San Onofre Nuclear Plant in California and at the Palisades Nuclear Plant here in Michigan. In December of 1981, Kent came to work for Bechtel at Midland. Earl Kent says when he came to Midland's Nuclear Plant he was shocked by what he's convinced were many poor-quality welds, many incompetent welders and many poorly trained welding inspectors.

Kent: Basically, anyone with a high school diploma, just a general high school diploma, could be a candidate to be a welding inspector.

When you bring people in off the street and give them, say, two or three weeks' training, you can't really expect them to be very knowledgeable and very adept in inspecting welds if they haven't had the real exposure to working as a journeyman for many years in this field. There were some people that really shouldn't have been welding at all and, consequently, many, many welds were torn out, joints were rebeveled and welded again. And I have seen a case, for instance, where one particular joint was welded four times which is, in my opinion, inexcusable.

Handelsman: What's worse, I would think, is that they're making bad welds and nobody notices. Did that happen?

Kent: Yes, very definitely. What occurs, many of the welds that were passed for many years as being adequate were proven to be inadequate and undersized, yet they were documented _as being t

adequate. l l

l rp1082-0655a-96 i

I

3 4

Handelsman: Who proved them to be inadequate and undersized?

Kent: The welding engineers and the welding inspectors basically had the burden of accepting or rejecting. Very often they didn't understand simple things in measurement like fillet weld gauges, how to check welds to make sure they were full sized. Many, many, many welds were undersized and were documented as being full sized.

Handelsman: These are welds that you saw to be undersized?

Kent: Yes, I saw numerous welds undersized, yes.

Handelsman: Let me play the devil's advocate for a second. A lot of people say, okay, so they weren't up to code. Isn't it possible that they're plenty strong enough to last for a hundred years even done the way they were done?

Kent: No.

Handelsman: Fifty years?

Kent: No.

Handelsman: Ten years?

Kent: Some of them will survive ten years, undoubtedly. There have been welds that have lasted for weeks, months and then failed.

There have been welds that have lasted for years and then f ailed.

There have been welds that lasted for decades and then failed.

I rp1082-0655a-96

Handelsman: So you're saying it's not just that I'm angry that they didn't conform to a certain rule and regulation? You're saying the

. welds aren't strong enough?

Kent: Basically, the welds leave a lot to be desired. Basically, a lot of the welds are inadequate.

~

Vassar: He sounds sincere. But we had those we1ds that he was concerned about checked out. And one group, you know, were already written up on the Nonconformance Report by another inspector. The system had caught them and, you know, we agreed that they need to be I reworked. He was subsequently asked to go look at -

bring up anything else he knew was of concern and he took the inspectors cut and they looked at an additional eight welds out in the field. Kent agreed that five of the welds were good and he didn't like three of them. Our people said, "They are good."

The Consumers people checked and said they are good. The NRC came in and checked them and then checked, you know, not only them. They said, "h' ell, while we're here, we're going to do some more checking," and they checked another 30 welds or so. And we think we have a very good program.

Handelsman: So what you're saying about Earl Kent, all told, bottom line, is l that he's wrong and we're right?

Vassar: That's correct.

Handelsman: James Cook of Consumers Power is ultimately responsible for the welding at Midland. He too believes Kent's charges are groundLdD55 rp1082-0655a-96

,3 - 5 Cook: In terms of the specific overview that my quality staff does of all of the Bechtel X rays of our welding done here onsite, I have no reason to believe that our welding doesn't meet all of the requirements that it's supposed to meet.

Kent: My experience with Consumers Power is that they are not to be trusted.

Handelsman: You're convinced that what you're describing could cause a problem in the operation of the Plant?

Kent: Absolutely.

Handelsman: Vould you feel safe living in the City of Midland, for example 7 Kent: No, I would not. No way.

Handelsman: Like the charges of cable substitutions detailed in my report yesterday, Earl Kent's serious charges that welding at Midland is j .

suspect will be investigated by a special team of the Nuclear Regulatory Commission. That's good. What's bad is that the flRC has known about Kent's charges now for three months and, so far, the NRC has'not begun its promised investigation. Tomorrow, problems with the ventilation system at Midland. Doris.

l 10/13/82 rp1082-0655a-96 l

s 2s

. u s set t ,.i. wi cou.ic,s. t INVESTIGATIOfi STATUS RECORD IUCTe0NS Th.s tc,em et to be compteted mae awse s _

so o., ,ews.as pe,.oa. . ew. we c p .f o." t a*t e:%.t g has otoreec *e'at.ve to . Case c* .: +e4 1 e.*'s 30 d.,s if no c'.4"g*occu h.:rred O.,' e we r i . uoc. een ne o,.s a. .n re u c va .no seae o,e cooy io se.oa,,.ne,.. .

oH ice of in.est Sat *ont CASE Nuwata CattGoa, os s ect o - Oetmais%G miacion s INoiveDuat Lect %5f t 3-83-007 E * 'ESNA"CUc '"

v .vt%oca

" * *""'a t s.

• ut t Region III a orn a

• ssicNto ro C. H. Weil susac' Midland Nuclear Power Plant Allened Inoroner Emolovment Terr'ination of or,___

siATus tsoce,rrom. ,as scovior , or,er aesces eni Insoeetor September 8, 1983.

A former quality control inspector claimed he was improperly fire.!lv Bechtel Power Corporation after he raised questions of pipe veld adequacy. Bechtel ' - er 1 i

claimed the inspector's employment was terminated for " lack of necessary skills or abilities." (NOTE: 01 Inquiry No. Q3-83-001 September 8, 1983 was converted to 01 Investigation No.was initially opened on this matter and en 3-83-007.)

9/30/83 Field investigati on har not co tmenced.

l l l

l 1 l

' 10/31/83 No change from last reporting period. Completion date unknown.

Case to be re-assigned.

l i

l 11/30/83 No change from last reporting period. Completion date unknown. _ -_

Case to be re-assigned.

l 12/31/83 No Change. Completion date unknown.

l 1

1/31/84 No Change. Completion date unknown.

-Es IT- ML -

. s

mC FORM 306 C411

• UE. NUCLE AR Rf CULATORY Cowul&Seoh INVESTIGATION STATUS RECORD sTnucTrow5: Th.. sor- . io t= compic.o *nea, ..en.eani .cimir we accon.o r.ic.

to e c.w or ei i n rv 30 e.v.. sv cuner u. occo,..o ow,.n, m.

so oev a.,o,..po,ses s.r.o. 6noot. "No CNage" in the n.tus tilod. K p the orpn.I wim the c.w fel. .no wM one copy to He.oou.rters, inon..es.oni.

CASE muu.E R CargGomy os psCE

_ o .oesnar. o neacTon a moiviount Lice =sas X C mtaCTom umDan OI FIELD OFFICE 3-83-007 - coa 5'auctio "*"*""'""

V -VENoOR x . Ofe.E m REGION III assic=so To suenc7 Midland Nuclear Power Plant: Alleged Improper Employment Termination of a O.C. Inspector.

STATUS (30. city cipre. .rNrprovide a besef alstrupfenf 02/29/84 No change from last reporting period. ECD Unknown.

03/31/84 - No change - ECD unknown.

04/30/84 - No change 05/31/84 - No change 06/30/84 - No Change 1 1

1 i

l 1

07/31/84 - No Change

PAGE 3 NRC F0au aos

"*' U.S. NUCLE AR REOULATORY COMMIS8t0es INVESTIGATION STATUS RECORD lesST"UCTiosas:

F Tbs term in to be completed wherever sayuficoat activity hee occured retetive to e coes or et leest every 30 deys. If no change has oixwred dur ng the 30 day reportang period, ind cose **No Change ** in the asetue blocdt. Keep the original with the case file and send one copy to Headquarters.

l. . Ofr.as of investigations.

TAI.CAsasse n CAffoo8tv , orrect a . oPiftATeseo AE ACToft e . sesosvtouAL LICENSEE 3-83-007 1 e ge g ga _

= . = Area Amrus' OIF0:RIII

. . vs x .or ea Amo=<o ro

(

- : Unassigned su=*" Midland Nuclear Power Plant: Alleged Imp,w c. - -

Employment Termination of a OC Inspector STATUS (Snec/& atore, niif proveelt a briief aimeritation)

• /31/84 - No change 9/30/84 - No Change Qj T0/31/84 - No Change 11/30/84 - No Change. ECD Unknown.

12/31/84 - Due to resource constraints, no field work has been initiated, nor is any anticipated in the inmediate future.

e Q,01/31/85-anticipated Due to resource in the constraints, inmediate future. no field work has been initiated, nor is any (4

PAGE 4 -

~

us.muetsAR REGULATOAV CotAmtsecte aus seem ses

" M PERTIGATION STATUS RECOftD

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• • =c' MIDLAND - Alleged Improper Employment lemination of a QC Inspector IF Galanti _

if mas.=use a a se mangerens TA YUS t$ e4 sk.r.

02/28/85 - Due-to resource constraints, no field work has been initiated, nor is any anticipated in the imediate future. .

03/31/85 - Due tc resource con'traints, no field work has been initiated, nor is any anticipated in the :nediate future.

04/30/85 - Due to resource cons traints, no field work has been initiated, nor is any anticipated in the '.nediate future.

/

05/31/85 - No Change.

l 06/30/85- No Change.

]

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( 07/31/85 - No Change.

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KRC 80PM W UA.180 CLEAR REQULATORY COneutsalone INVESTIGKHON STATUS RECORD

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90CT10ses: This term a to be comp 6sted erhensier espifiennt activMy hes securved rototive to e sees or et least every 2 days if no shenge has escurred dwing we I 2 day reportg pored, trulate "9to Change ** en tr e asetwa basek, Keep the artyAel with the seus flee and send are espy to Headowerters, 0*fas of lavesteens, CAsg sevesota CJrE00mv 08 FICE G3-B3-ooI O . 0PtRAT#eso alAC70ft y C . =,r=

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