ML20206H725

Marked-up Comments on Developments in Investigation of Allegations.Reiterates 2-month Old Plea to Get Investigation Effort Going & Request for Opportunity to Make Input Into Structure.New Investigators Should Be Appointed to Case

ML20206H725
Person / Time
Site:	Midland
Issue date:	09/06/1982
From:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20206H499	List: ML20206H495 ML20206H725 ML20206H786 ML20206H812
References
FOIA-85-213 NUDOCS 8704150425
Download: ML20206H725 (5)

Text

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GOVERNMENT ACCOUNTABILITY PROJECT Institute for Policy Studies 1901 Que Street. N.W Washington. D.C. 20009 (202)234 93B2 g------......

• September 6, 198 . . .

f. .,

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3 Mr. James Keppler .

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Director, Region III "

U. S. Nuclear Regulatory Commission , ,

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799 Roosevelt Road - *-

Glen Ellyn, Illinois 60137 f , ~ ~ ~ ' I s- - -- :. . .... _ . ML Of *

Dear Mr. Keppler:

As you know, the Citizens Clinic for Accountable Government of the Government Accountability Project (" GAP"), the Institute for Policy Studies, has adopted the Midland case. GAP investigators have completed an intensive two-part investigation into worker allegations on the Midland site. Further, Citizens Clinic staff have worked closely with citizens, local and statt leaders, and organizations to determine the level of anxiety and public opinion about the Midland plant. Our findings have confirmed that ,ty . plant qualifi.es for its position as one,of the,f,ive worst in the nation.

In June of this year I was impressed by your announcement of plans to begin a special investigation team to deal with Midland's intense problems. In a conversation with Mr. Norelius in May 1982 concerning our Midland investigation I requested the opportunity to provide input into the planning of that special investigation team. Much has happened since June 29 when GAP submitted the original set of six allegations to your office. Unfortunately, l the arrival of the promised special investigation team has not been one of those happenings.

Admittedly, both GAP and Region III have had an intense workload in the past two months. However, a number of developments recently are of great concern to our clients and the Project. I am taking the liberty of addressing these in this letter, as well as a number of administrative matters. _I look forward

_-..+. tyour,c;1arification.and/or response.

l I. The Zack Corporatior. as regards the Midland Nuclear Power Station i Although your office has expended a great deal of time on the problems identified in the Heating, Ventillating and Air Conditioning ("HVAC") system at the LaSalle

, plant, I am not aware of any ongoing efforts at the Midland site. I am aware that comonwealth Edison's situation at LaSalle has been a priority item in  !

the three-plant examination. It is, however, no longer justifiable to delay an investigation into the actions by Consumers Power Ceepany's Midland Project Quality Assurance Department ("MPQAD") .

The facts in the Midland case reiterate the lessons of our experiences at Zimer and LaSalle. MPQAD is not an effective substitute for a strong NRC inspection programs instead, as Mr. Terry Howard and the Zack QA Department 8704150425 070413 PDR FOIA /

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Mr. James Ke3pler September 6, 1982 discovered, MPQAD is worthless in protecting workers.

If there had ever been a second thought in your mind as to the Consumers Power Company drive to have Midland meet its Dow Chemical deadline, rega'zdless of the bigger price tag it may have for public health and safety, the Eack incident sh* p uld have sealed your conclusions. Not only was Consumers Power painfully aware of the Zack QA breakdown after Mr. Dean Dartey exposed the 2ack deficiencies in 1980, they were the first utility of the three affected to be contacted, having an entire month longer than Commonwealth Edison and Illinois Power and Light.

Consumers Power also participated directly in the manipulation of the QA breakdown by supplying an employee, Mr._Howard McGrane, to pgorm an intensive Audit, This is a sickening example of manipulating the regulatory process to serve the utility. I am deeply disappointed that you have not taken the initiative to take appropriate action at the Midland site.

At a recent meeting with Commonwealth Edison over their future handling of the Zack allegations, you imposed a third-party audit because you indicated that the public has lost confidence in Comed's ability to give open unbiased information to either the NRC or the public about problems. Consumers Power's credibility was destroyed long before the latest Zack incident. This latest event only confirms the public's mistrust of a utility caught in a " Catch 22" contract.

? (Attachment 1, at 9.) If the situation at Midland was historical in nature, I would defer this letter to a later date. Unfortunately, the luxury of extra time at Midland has run out. According to our sources, condi + ns E Midland deteriorate daily.

II. The Systematic Appraisal of Licensee Performance ("SALP") rating debate Consumers Power Company has been quite demonstrative toward your office in regards to the 1981 SALP ratings they received. It appears that Consumers' intent is to keep both regulators and public interest groups as busy as possible in defensive positions. Although I have a deep appreciation for their need to do so, nevertheless it does nothing toward either improving or guaranteeing the construction quality at Midland.

The recent meeting held on the SALP rating debate certainly did nothing to improve the construction quality at Midland, nor encourage utility spokespersons to cease their bantering about the deserved low SALP ratings. Even the local paper took exception to the NRC's focus on the SALP debate. (Attachment 2.)

It is our position that the SALP rating in support systems, VI, was totally inaccurate and far too generous. Eack never improved their 94 program. They merely agreed to transfer the paperwork responsibility to the utility, which has an even greater vested interest in the outcome of the monitoring of Zack's work. In fact, the bottomline in the Eack incident on the Midland site comes down to questions that Region III has not yet asked:

Mr. James Keppler Setpember 6, 1982

1) Why didn't Consumers Power report the Zack QA breakdown to the NRC in the fall of 19817 i

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2) When did the Zack problems become apparent to the NRCg(Regional i or on-site) following the Dartey investigations? Under what circufhstances? j

. 3) Will the independent audit apply to Midland also? If not, why? l 4 If it does, under what arrangements?

I III. The recent meeting between Mr. Earl Kent, former Midland worker, and l

Mr. James Foster, NRC Investigator Mr. Earl Kent recently contacted me with concerns about the status of the I investigation into his allegations about the Midland Nuclear Power Station.

) His concerns are well founded and I have agreed to contact you directly con- ,

t cerning the Midland investigation. This letter represents the joint ccanments  !

of Mr. Kent and myself. i Mr. Kent has an impressive and credible background. He has been a welder for almost two decades, rising to a position of respect and confidence among his professional peers. His information is iron-clad. Two months ago, he and M three other wo'rkers submitted affidavits on Midland. I tiet week Mr. Kent made f//

a personal trip to the Glen Ellyn of fice2t o check on the status of the inventi-j gation into h_is allegations. What he discovered shocked him. It does not shock me -- I wish it did, i 3Mr. Kent met with Mr. James Foster. The meeting was taped. During the 1 -hour _2 N4 1 meeting, Mr. Kent detailed the inherent welding problems at Midland. He detailed 2A M j with diagrams extensive problems with fillet welds and described the inspection ,

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errors. HeexplainedthathisaffipvittoGAPwasonlyanoverviewofthe problems at Midland and that he was anxious to aive explicit details -- pout l J Midland, Palisades and the San Onofre plants he had worked on. However, A was told that it would be months before'he was recontacted, and only to answer specific que_stions that might arise, It is intolerable and inexcusable for

! Region III to continue to deal with nuclear witnesses as distant observers.

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O Mr. Kent volunteered to point out to the NRg on the site the areas where the welding problems were most extensive. Yet, he was told that nuclear witnesses _

l _can't go on the_ construction site to identify the problemal An incredulous ent statement in the light of the LaSalle worker tours and the involypwas +of Mr. Howard and Ms. Marello in the Zack investigation. Finally he Md f

j tRat Region III would get to Midland when it had time _.

Mh. Keppler, if Region III doesn't have time for Midland now, it will be

necessary to have enough time for another Einuner later. I am not challenging your priorities for the past two months. But Midland's problems!have to be

' addressed, promptly and effectively, and I was deeply distressed at the comments I learned from Mr. Kent.

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i s Mr. James Keppler September 6, 1982

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i I urge you to personally listen to the tapes of the conversation between.

Mr. Foster and Mr. Kent at your earliest convenience. It apptars to both Mr. Devine and myself, as well as to Mr. Kent, that an independent-audit of the welding problens will be mandatory. .

Mr, Kent, as you know, has remained relatively discreet in his public allegations.

Helis one of those protected by your confidentiality agreement. In keeping with that, we request you consider this information under his file, or remove his name and any identifying information from it before releasing it. Further, I have included a copy of Mr. Kent's amended notarized affidavit which he said Mr. Foster did not have. (Attachment 3.)

IV. Bechtel's secrecy agreement As I have indicated to you previously, we have encountered a larger amount of intimidation on the part of nuclear workers at the Midland site. This "intimi-dation," unlike that encountered at Zinner, is apparently a result of a serious misunderstanding between Bechtel's employees and outside interests in the safety of the Midland Nuclear Power Plant.

In researching the problem of werkers being fearful of talking to angfoutsider, whether your agency representatives, GAP, or the press, we discovered that they I overwhelmingly believed they could be sued by Bechtel on "breadiof contract."

I This situation has extreme ramifications for the premise of 10 C.F.R.19 that guarantees protection for and, in fact, requires workers to report safety defects.

I understand that you are clarifying this situation. _Please address the NRC's y[gositiononthisBechteldocument. (Attachment 4.)

V. Nuclear Regulatory Commission Investigators and the Government Accountability Project For the past two years members of the GAP staf f and your own staf f have worked on several nuclear cases. Recently our efforts at Zimmer and LaSalle have taken the majority of our Project's time. Understandably we are of ten in conflicting positions, representing those internal nuclear witnesses who did, not find an effective avenue for their concerns and/or dissents. We believe this is a natural part of the " checks and balances" system of our government.

The Government Accountability Project has attempted to be cooperative and to assist your own investigators, while maintaining a commitment to the best interests of our clients. We do place the public health and safety as our highest priority. Of ten we must ensure confidentiality and protection for l GAP's clients and other witnesses in order to convince them to deal with the j government at all. I am convinced that you understand our position, and l regard it professionally with the best intentions.

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Mr. James Keppler September 6, 1982 However, it appears your best intentions may be seriously compromised if your staff fails to perceive their role as defenders of the public interest, not the utilities' timetables. _

You have been anxious for us to work toward a better attitude on py'ur offorts to, improve the quality of investigations. I believe they have improved. The Zack situation was a costly, embarrassing lesson. It has placed us in a difficult position in our dealings with members of your staff. We ,mus_t protecji W..witnes_ses,_from_ poor _judgmen,ts of, Jour investigators., as well as from the utilities' vested interest. It's a position we would rather not be in.

Unfortunately, the recent reorganization of the NRC investigators has not yet been clarified. Until it has been I am unsure of where to address specific concerns raised by our clients over individual investigators.

,I anticipate that the administrative reorganization will be explained shortly, f and thank you ahead of time.for_your explanation.

In conclusion, I reiterate both GAP's two-month old plea to get the investigative effort going on the Midland site, as well as my request for the opportunity to make input into the structure. I believe that now, more than ever, new investi-P gators from the Office of Investigations be appointed to the Midland case.

i Sincerely, '

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bG..a ', f G . b' BILLIE P. GARDE f Director l Citizens Clinic for Accountable Government i

BPG/mcy Attachments - 4 1

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Attachnent 1 t

STATEMENT OF DILLIE PIRNER GARDE CITIZENS CLINIC FOR ACCOUNTADLE GOVERNMENT s

ON Tile MIDLAND NL' CLEAR POWER FLANT l

LANSING, MICHIGAN June 20,1982 i

Government Accountability Project 1901 Que Street, N.W.

Washington, D.C. 20000 ,

202-234-03S2 Nojd6i[~

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I. INTROD1'CTION On behalf of the Government Accountability Project of the lastitute for

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' Policy Studies, or " GAP," and on behalf of the Lono Tree Council it is an henor I

and a privilege to appear before you today.

A brief description is in order of who we arc, how we became involved at Midland, the events leading up to this press conference and the issues we believc the public needs to be aware of.

II. BACI< GROUND The Government Accountability Project is a project of the Institute for Policy Studies, Washington, D.C. The purpose of itr program is to broaden the understanding of the vital role of the pt611e employee in preventing waste and corruption, to offer Icgal and strat egic counsel to whistleblowers, to provide a unique legal education for law students, to bring meaningful and significant reform to the government workplace, and to expose government actions that are repressivc,

, wasteful, or illegal and that pose a threat to the health and safety of the American public.

Presently the Project provides a program of multi-level assistance for government employees who report illegal, wasteful or improper actions by their agencies. GAP regularly monitors governmental reforms, offers expertise to i

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Executive Branch offices and agencies, and responds to requests by Congress and state legislatures for analysis of legislation to make government more accountabic l

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to the public. l l

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The Government Accountability Project also includes a Citizens Clinic for Accountable Government. The clinical program, modeled after GAP's successful l

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-Legal Clinic, would assist and instruct citizens groups and individual's who seek i

'to uncover government misconduct, monitor government investigations or force regulatory agencies to recognize significant public health and safety dangers. It is the Citizens Clinic, with GAP Investigators, that has adopted the Midland case.

i Since its inception, GAP has seen the adverse effect of misdirected government investigations on whistleblowers and communitics. Large institutions 1

2 that are the focus of investigation -- whether they be a public utility ignoring safety issues, goternment contractors bilking the taxpayers, a factory polluting a neigh-borhood or a government agency controlled by corrupt private interest -- will

" clobber" the community or public interest groups with the conclusions of any official probe that does not clearly prove wrongdoing. An inconclusive result gets translated by public relations departments of the institution that is the subject of the probe into " total exoneration." In the wake are often left cynical, intimi dated, harassed and sometimes broken victims who had the audacity to challenge a local power structure.

! Public interest or community groups can sometimes reverse the result but it is an incredible uphill struggle. As word of its accomplishments has gotten

'out, Individuals and citizen-oriented groups have sought GAP consultation. Often i  :

those requests focus on how to force local and state governments to confront major i community problems, how to monitor government efforts once initiated, how to l

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) 1 i encourage agencies to take effective and appropriate action and how to turn white-washes into exposts. It is this skill that GAP and the Clinic was asked to bring j to Midland.

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In January,1982, we were contacted by the Lonc Tree Council of Midland, Michigan. For years.they told us, workers -- some anonymous, some named --

@ad been contacting their organization to talk of serious problems on the Midland site. They alleged that the citizen intervenors had similar experiences and that as the allegations become more serious they decided to seck help in directing these workers. They were referred to the Government Accountability Project by other Washington-based public interest gmups.

We listened with great interest to the history of the Midland site and the massive problems facing the future of the plant. Our expericr.ces at the Zimmer nuclear power plant in Ohio had been a sobering one. We were also aware of the fact that the Nuclear Regulatory Commission's own Office of ' Inspection nnd tx?itor had labeled Midland as one of the five worse plants in the nation. We urged the Lone Tree Council to send us more information.

In March, after an extensive review of the history and an analysis of the problems at Midland, two GAP investigators went to Michigan. They talked to former workers, citizens and intervenors.

They reviewed documentation from the Nuclear Regulatory Commission, court transcripts, and testimony from public hearings. A second investigative trip I

f was made in May, and countless hours were spent with witnesses, verificatica studies, 1

.and technical research.

The Clinic identified nine major areas of concern about the Midland nuclear power plant. To summarize:

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It is 1200% over its original cost ,

dollars. That cost ,

1) The cost of Midland. hen the plant .. ' ,7, *  ;

projections - now priced at 3.39 billion .-

will be passed on to Consumer's customers whigan Public l t payers -'

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l is deemed "usenble and useful." The MicServ -

• l for this decision.

4 Major safety related buildings y sult of '

i i 2) The soll settlement issue.haveliterally sunk and sub ',

the soils problem. The "fix" for this i Board pro ofkthe con-  :

f approved by the Atomic Safety and Licens n

• l tinues because of a legalloophole. ,

! Midland's nuclear power of 51,400.

i 3) The location of the plant. i

! plant is located within the city limits ile of ofthe a town lemen-l l

There are 2,000 industrial workers within{ o

• 1 j tary school.

i The plant will emit extra- ,

nd in /

4) The environmental Impact. i eleases ordinary will amounts of f '

which the This routine fog will and" rainout" accidental and "radioact ve r ice out" heavily be entrapped.

l populated areas.

Also included is theh unresolved e into issues o i high level waste storage on site and the waste disc arg the Tittsbawassee, I I Midland's nuclear

5) The allegations of plant workers. orn state - r i

h e dozen

' site workers have begun to come forward d items.

allegations about plant safety and other relate sight.

1 ility

6) Inadequate Nuclear Regulatory Com ility to live l even in the face of repeated failures of the ut up to its promises of reformation.

Repeated QA/QC program tions,

7) A Qunlity Assuranec brenkdown. t have major deficienc h have's built-i and audits since 1973. The program co

,l in conGict of interest. ranging being l 8) Intimidation and reprisals acninst wor l

threatened for pursuing their allegations.

', _ _ _ _ . . . - _ . _ _ _ _ _ , _ . _ , . . . _ . , , _ ~ , _ . _ __.___. ..__ .__.,_ _ __... _.. .______.,...__.._._. . . . _ _ . . ,

A " Catch 22"

9) Contract. There is no casy answer to this problem._

Consumers Power Co. is under a con'.roct to produce ,.

. steam by December,1984 for The Dow Chemical Co. -

If the contract is broken, so is Consumers Power Co.

". To assure that Midland can be built safely by a manage-ment thnt faces financial ruin if the deadline is not met is at best, hopelessly naleve.

Ill. WillSTLEBLOWER ALLEGATIONS Since 1975 the Government Accountability Project has provided legal and other assistance to those who blow the whistle on fraud, waste, mismanagement and health and safety hazards. In fact, since 1979 we have legally represented nearly ninety such individuals. During that time we have developed a methodology that might vary in particular circumstances, but which nevertheless remains fairly consistent.

First and foremost, we do not dictate for those who bring information to us how that information will be used or where it will be taken. Those decisions are made solely by those who have obtained the information. If we are not willing to abide by the conditions imposed by the whistleblower, we will decline to use the information in any way. We are ethically bound to protect the client and to keep his or her interests very much in our mind.

If employ.ees are. afraid to risk going through the internal channels the utility has outlined, then we would indeed risk our own credibility by encouraging

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employees to " walk the pla nt" If we decide to legally represent the person who brings information forward, we would violate our own professional ithics by advising the client to use defective internal channels.

Unless we have sufficient evidence that an "open door"is truly open

.or an office to deal with problems does not view the w h istl eblower as?th e problem",

i.we will not advise employces to pursue those internal procedures.

. Consumers Power Co. has indicated great distress that we are not working with their own QC/QA program with our Midland allegations. Please do not think that we have made any determinations about theirquality assurance complaint pro-cedures or system. Unfortunately, at this point we do not krow enough about their organization to make a valid judgment. Some employces have expressed doubts to us. To allay their skepticism and our own reservations, we would need to hear from the employees who have tested their allegation procedures.

In fact, we respectfully requested that Consumers Power Co. allow us to speak with those who have reported problems to them publically and openly through their system. If the only employees to use the procedure are ones who have done so anonymously, we would appreciate very much if Consumers Power Co. would somehow convey to them our desire to speak with them anonymoesty about the allegation procedures and their experiences with them. Mennwhile, we hope they will give us some information about the types of complaints that have come through their allegation channels and what the final disposition of the alleged problems have been.

Until our ownquestions can be answered to our satisfaction about Consumers Power Co.'s internal procedures, we will continue to deal directly w th the Regional Office of the Nuclear Regulatory Commission out of Chicago.

We will also continue to stand by and aggresively pursue pytection

.for those workers and former workers whose information we will pr'esent to the I Nuclear Regulatory Commission for investigation.

Furthermore, we will monitor the NRC's investigation into these alle-gations. At Zimmer, the initial hTC investigation was exposed as a " cover up" leading to a $200,000.00 fine for the utility. We will not tolerate that again at a

Midland -- timo lost due to an incomplete or inadequate inspection is simply a luxury that Consumers Power Co. does not have and can't afford.

IV. RECOMMENDATIONS FOR ACTION We are calling for the construction to be halted until the NRC can judge the full secpc of the problems at Midland. We believe this will be the most time efficient way to get a complete hold on the situation.

If this is unicasibic, GAP respectfully requests that the Affice of Insestip-tions (OI) adopt Midland, at the recommendation of Mr. Keppler, as its first case.

The OI has no vested interest in covering up Midland's problems and it is composted of highly respected NRC investigators. O1is to be the " SWAT TEAM" of the NRC that was set up by and reports to the Commission directly. We look forward to

. their involvement in major plant site investigations. Midland would be a good

- place to start.

Mr. Keppler has indicated his own reservations about Midland. He has announced a special five-person team to deal with Midland's pro'leibs.

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! Regional reorganization should compliment the O! investigation or some other  !

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third party audit as called for by the United States Senate recently. This Senate Bill co-signed by Senator Levin, sets aside funding for a test of an indcpendent audit and inspection on three selected plant sites. Because we believe so strongly in "someone else"looking at Midland's problems, we would like Senator Levin and other members of the Michigan delegation to consider their role in bringing this nuclear plant under control.

V. SPECIFIC ALLEGATIONS In our investigation GAP has completed seven affidavits and verifica-tion studies. These affidavits have been sent to Mr. James Keppler, Director of

Region III of the NRC.

Issues included in these affidavits are listed below

- Welding standards below ASME specifications f,7 . "

--Improper socket weld engagement length i -- Poorly trained quality control inspectors

-- Countless welds improperly inspected for years by at least one inspector

-- Undersized welds

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-- Improperly ground down welds

-- Substandards welds

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-- Extensive corrosion inside the small bore piping ,

-- Unqualified welders i

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i -- Reduced specifications for welding electrodes that led io corrosion L

-- Anchor bolts in the battery room not meeting the specifications

-- Presence of debris in small bore piping i

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-- Substituted cables leading to the control room _

-- Conduit supports that exceed weight specifications $-

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-- Lack of inspection for compliance with wcight specifications on conduit supports

-- Improper use of type 30 conduit supports

-- Non-compliance to blueprints

-- Diversion of equipment for personal use

-- Lack of material traceability

-- Questionable anchor bolta

-- Undetermined weld rod control in the past

-- Alcohol and drug abuse problems among workers in safety related arens i -- Theft of plant equipment

-- hianufacture of belt buckles and barbecue skewers out of stainicss steel and nickc1

-- Bechtel undermining the construction through a variety of work slow down techniques VI GAP'S PLANS TO h!ONITOR NRC'S INVESTIG ATION For the past decade the NRC and Consumers Power Co. have repeatedly offered their reasonable assurances that QA/QC programs would improve. Yet, repeated failurcs in the design and construction of essential safety systems, as  ;

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reflected in public documents, indicate the contrary. l QA and construction deficiendes continue, yet the NRC has been unwilling  !

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l to enforce what could be very effective regulntionsto assure the safe construction of this nuclear plant. We will accept nothing but the " letter of the law"when Public benith and safety are concerned.

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I We are concerned to see a pattern of leniency that has compromised 4

. the regulatory concept. As we found at Zimmer, the NRC Region H! staff gives ithe benefit of the doubt to the utility far tcooften. We believe the utility will *ook i

out for its own best interests. The NRC is paid by the taxpayers to look out for the public interest, i

Some examples of this pattern of leniency include:

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1. The NRC resolving " findings" only based on statements

, with vested interest.

2. The NBC acceptance of relaxed design and construction specifications and procedures.

3. Serious conflict of interest within investigations and inspections.

4. Continued acceptance of substandard material.

5. Few, if any, unannounced NRC inspections on site.

6. Excessive deferral to the financial hardships and time deadlines of the utility, weighed against public safety standards.

Even worse, the above structural flaws and patterns of non-compliance do not include the unacceptable potential for human error at Midland We have yet

{ to find a single employee witness who has denied our witnesses charges of wide-spread drunkeness on the job at the construction site, it is difficult enough for 1 l

-a sober worker to construct any nuclear power plant safely. We shudder at the consequences of drunLen employees trying to cope with the handicaps at Midland. l

! Region DI has begun to recognize the seriousness of the problems at i

Midland, as evidenced by htr. Keppler's recent announcement of a specini inspec-i tion team for hildland. Shoddy work has been piling up for almost a decade, 1

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halting future violations is not good enough. Far too many witnesses have con-firmed thzt this plant is a disaster waiting to happen. General Public'lftility's S$4 billion lawsuit blaming Three Mile Island on the NRC for not regulating strictly enough illustrates the desperate consequences even for a "near-miss "

The public drew the line at Three Mile Island and Love Canal. Workers inside and citizens outside the Midland plant want to be heard. We represent their collective voices.

A Billie Pirner Garde Government Accountability Project i

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f tac,h nnt 2 1 1

Midland Daily News

' Charles A. Spence, runn.h., .

John A. Palen,re , .

Norman C. Rumple, even.her sm.ritu.

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NRC should focus "

on ' major concerns I Consumers Power Co. Is still """'~~' '"'~ " "

complaining about the latest negative SALP (Systematic Assessment of Licensee Per O u r.v. ie w e formance) rating given by the -

U.S. Nuclear Regulatory Com- lilinois to attend.

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mission to the Midland nuclear

• For its part, Consumers sen*

plant. -

reprosentatives from Chicago The utility has a right to and Jackson.

' complain, of course. But Who pays when federal offi-

.shouldn't the manpower short clals fly around the country to .

NRC i

be handling this matter attend a meeting that, by the

,*more efficiently so it can devote NRC's own admission, could

• more of its resources to settling have been handled by a teie-

.some of the more serious phone conference call? The

, questions about the plant? taxpayers.

Walle the Midland project is Robert Warnick, acting direc-4 undergoing a barrage of critic- for of the NRC's Office of ism based on. allegations made Special Cases and one of those by 'former plant workers that a 'hursday's meeting, questionable construction prac- s Midland plant has i fices may effect the plant's safe receiveo w much public critic-operation, a gathering of NRC ism that the agency felt it would*

and utility officials was held in be better to conduct the SALP-Midland ' Thursday to argue business in a public forum. ,

politely about SALP ratin,gs the Yet none of the points argued, N RC has said it won't change. over in Thursday's meeting Meanwhile, a promised NRC really go near the heart of' investigation into the workers' concerns about the nuclear-allegations still hasn't been . plant. Operating in the open is, started, nearly a month after absolutely essential- but even, the charges were ,made. The .so, some judgment has to be reason? The N RC says 11 doesn't '

exercised about what is import

• have the manpower. ant and what isn't. *

• The NRC apparently can't We think the public would, spare the inspectors to check out have been better served had the the allegations, yet two inspec- money and effort that wer'into fors were flown from Illinois to this posturing been spent on' Midland for Thursday's more- checking into the allegations.

• or less pointless session., Two about the Midland plant.

t other NRC officials flew here Let's ground the unnecctsary from Washington, D.C:, and flights and get the investigation palr arrived

'.another

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Attachment 3 ,

AFFIDAVIT My name is E. Earl Kent. Iammakingthisstjtement of my own free will to Mr. David Crow, who has id'entified '

4 himself to me as an investigator for the Goverranent Accountability Project. I am speaking without threat j [.M or promise of material bonofit. My reason for making this statement is to express my deep concern over the IN AVCLf4tt. Wocx f,N quality of constructionjat the Midland,29ftsMk nucicar V' plan;, -

mIMf

f. R CPIN/JH,inated in March of 1982 for persistently wherej was term l .

bringing defects in construction and specifications to the attention of my superiors 4WO FCw' AFhWMs [< M I have worked for seventeen years in engineering, most recently at six nuclear plants.

Kw W.

I Jeeksi the title of Senior Quality Control Engineer for nucicar welding.

G<.U.

I have been a member of the Ancrican Society for Ounlity Control, and havo published several books on welding and structural steels. B foro coming to htyexWE).pik6$NtriNCn- &j Bechtel, I worked as an engine ,.4Norgfor Litton Industries, j as a fieldO's Velding Inspector for Boyle Y~A4 AnnEngineering WupiN4 h &Nfra [ l'a Corporation, and as a Velding $upervisorgfor Fluor f.U s W Engincorc. I have also worked as a kaality kssurance T.A.' ff-and koality Ocntrol Ingineer for Joy Manuf acturing.

, T.Y. fN, ff, I have attended more than half a dozen professional l educationcoursesonenginnoringandqualityconkrol. .

Prict to moving to the Mid and plant, I had.ucr W. I for hechtel at two of it s other nuclear units, Pa) isados Ex l

1 1

P2g3 Two

• ', =.

g,y . w r> b c,

, W-In both of these earlier

\

and San Onofre Plants Onejend Twoj Bechtel positions, I served as Senior Quality Contr.pl

. Engineer. I received top recommendations from my ,-

• J. supervisors at both hese plants. There is a letter on c/2 Walk V O' file with Bechtel's sentomi office, from the Vice President my work there.

of Bechtel's Los Angeles5NGINff*!'/M1 Power Division, AND y,fg//r Based on my years ofgexperience in nuclear plants, it it my profossional opinion that the Midland plant ,

is the worst nuclear facility I have ever seen. This affidavit will detail instances where Bechtel Corporation hassystematicallydowngradedstandar),sforsafety-related 57M-equipment, to the point where I Wheaumb 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 lant. I have seen Bechtel personnel, both QC inspectors and engineers i

with OC responsibilities, routinely accept substandard work.

I will also give examples of the unhealthy degree of reliance that certain URC inspectors have placed in the ,

, Bechtel personnel whom they are supposed to monitor. NRC

\

field inspectors showed a surprising willingness to let l

the Bechtel personnel do all the dirty work involved l in supposedly independent investigations. Becatism .Nh-inspectors ofton didn't themselves try to take the

~

., P2g3 Thrca e

measurements, or clin.b into less accessible areas, the inspec-tion reports that were supposed to represent a completely separate check on Bechtel performance of ten wound _up basing their approval on Bechtel's evaluations of its owh work. ~

2' AWN 6JS/N4 UD (//.

L My espertise is in weldingj inspection. When I first came to Midland, in December 1981j 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 Rg46)RtyMP f/. '.

area. It is the result of many years of gtesting. Despite this,Bechtel in some casos made the decision, based on their yf. CPisttrw v1L f./<&

own engineers'j short-term testing in San Francisco, to modify these standards.

If Bechtel had made these changes only +.o take account of particular needs at budland, 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 nucica-facility. There is an inter-office memo, dated 24 April 1931, AhV [.Sr ,

which I home .,n my files. It is between the project OC head, E. Smith, and a main office materials and quality services official, D. Hackncy. 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 gap of nearly an length will be tolerated betwee,n the end of l

! the pipo and tb b' otto" of tha sechet e ca : va..h.m *. h:

fhlt.vK04 E//tEth LV pl'4 # f, # *

\

joint, and make it susceptibio to gvibration. The AS:lt Code

.. . POg3 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 Hackna'y memo became-I 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 gaugos correctly to measure the size of welds was .

beyond the ability of some of the Bechtel inspectorsj AAlp G4Myra, i;

In early February, I was working with one of these M*

Bechtel QC inspectors, h itunskD John was about to approve N .__,,_... .~

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-h ing one edge of the blado. I drew John a diagram to show him this. When John looked at the diagram, he saw that I was right.

l But the welder refused to put any more weld on -- he said he'd 1

been doing it that way for two years, and his boss had always approved it. o call his boss in, and explain f We finally hadj U. $

'~

tryLt> 5'./4 it to him, before we wee 6d get the weld W redone..,. Paul

~

fMS/Nff t [ /4 '

~Schulz

~~ d,, another QC ,in ;::t:r, was also there to hear the explanation, and he admitted after I show d him the diagram that he'd been approving bad welds himselfj 4/3/H####Dftv##N&#4 ;

. /A/ADfAWTF Fasfr /t'rt.oj AJ 56/b'A .4DdW4Wo f /4

' Undersized and improperly done welds were serious problems, t

but at 1 cast thay didn't aff ect the integrity of :the piping JcMtriMr) f/4 itsc1f. High-pressure piping, whichgcontains up r.o 1500 pounds cM KA per squaro inch, is very vulnerablo material. Itjreactg liko M

\

., PagaFivd 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 1

concerned to discover that many welds in the piping had been improperly ground down, grinding down the pipe waji thickness ,

along with it.

This was not only a violation in itself. It was part of

! a larger problem having to do with inspections of the parent in ystems. In small bore piping, the only metalforthepip$.g THetteLMklY in L n6 sN fM is f

&N ,toH CA- Q way tojinspect the nside of the pipin forgeorrosion j tf .

C//

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

yurd sot c8 AN Y Piff, o r 'S ff, agrierstrAND f /4 This isja 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 I usually relied on visual inspection only. Visual inspection

^

can detect corrosion only on the outside of the pipingj s/>UA4LM

-G J. .

When I performed a thorough inspection myself of t e piping, using TM 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, those reports fail to reflect the problems of the piping systems I which I discovered. To allow severely corroded piping to be l approved for safety-related systems is in my opinio 1,nexcusable,

. /,4 .

and certainly very dangerous to the successful operation of ANV

, g74$neplant.

Another piping problem with which I was 7ersonally LCW- AWStGW '

f amiliar developed because Becht ci P.11cvedgolcetrodt e us in

! Her pVfMJ (A.

welding to be taken out of theirgho:motJcally-scaled cot:hhinera (S.

- . . _ = _ ~ - _ _ . , _ . - - - - --,n c, c.,- , - - - - _ - - - - . - - - - , , -

s .

• Page Six vf W hE' forjeight hours before use. The American Welding Society (AWS)

MM/MtM ff standard allows only four hoursjin the,,open air. Whea the electrodes are left out, the chemicals in their coating attract ambient humidity. When this moisture is absorbed, it will 1

become steam under the heat applied during the welding process.

nur y;/t Each speck of moisture will expand top 50 times,its initial volume, and results in substantial porosity, or simply empty space, within the ecmpleted weld. The weld will appear strong, but be weakened from within. The AWS standard is used for -

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

X-ray inspections of welding, performed under these conditionsj has revealed porosity.

ff. The welds have had to be T4 h curteem out and redono, not just once but many times, often within the samo joint. This is one more example of Bechtel's not doing it right the first time. Every timo they had to tear the wolds 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 secq work ripped out because of shoddy installation, I ,

redone, and then ripped out and redone again because it still wasn' t right. One QC engineer, who has been at Midland c'm FrfL MANY YfdM, O f.M .

l

• ~

. Pag 3 S3vcn p*y/*

$.,//, /N P/f AY'M/SA's

" ginnsag, 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 fuestions of safety, but it also makes me wonder who is going to wind up L'

paying the bill for Midland. Bechtel's indifference to quality will cost the ratepayers a bundle,.if they are allowed to pacs on their costs to the public.

ft/'et:4W hok The defects I have described are genericq to the Midland plant. They have pened because Bochtel has hired inexperi-EA!Giktf4 f encedg welders,and in'spectors. There were few formal requiro-

! ments to become a welder, or even an inspector. If this was supposed to be corrected through a thorough training program, it didn't happen. The training periods were only a couple of ENA *4'ffM, &

1

weeks, and based on my experience in working with the welders j and the inspectors, I can state that they were not properly 4no ChGt"Etal f,/f TX, trained. When inspectorsjdon't know how to uso a fillet gauge to measure wolds, you know that the overall program standards ,,

car.not be very hi 40 A CcMMT+' Mi'f ffWTHN IV /t'4Lt h'WA NRC inspections of ten f ailed to correct problems. In the area of the inside wall corrosion in small-bore piping, nab A'r this was because thejinsp[ectors seemed too willing to trust ,

the Bechtel inspectors when they made their tours. It was generally the pec 1 people who actually climbed around on

• I

, the piping and called out their measurements, which the NRC inspectors would then write down. Asaresult,eknyofthe inspectio: reporto do not reflect cnythiity more than Beeh*.01'n own assertions. ,

l l

6

. . Pag 3 Eight Even when the NRC inspectors did show a willingness to '

vFra CA carry out a real inspection, they would be g handicapped by their practice of not coming in unannounced. To the best of

- my knowledge, there were no NRC inspections that bran't pre- -

. 0, 4

. ceded by temer Y_M W preparation directed by Bechtcl, g k'tpiF/fD during which problems would be repaired and sometimes eeeeenled, fit.DirM' As a result, the inspectors aseen sawWthe plant as it really operated on an every-day basis.

My alarmingjx eriences with the field wolding and tho ,

GN6tNCCG4 MP Pe e OC 3 inspectors led mo to speak to my boss, Mr. William Creel, numerous timos in December and Ja'nuary. Bill generally had the same responso: he said that all his mon had passed the Bechtel tests and woro fully qualified, and he was willing to tako their word for it if they said conntruction was safo AND

[A j AOK4T4Tv, My real problem began when I tried to talk to the head of Project QC, Mr. Eugene Smith. Ile told Ino what Bill Creel was saying, that everybody was qualified and so thero couldn' t be problems like the onen I was telling him existed.

On Friday, February 26, Eugene Smith called me into his office and told me I was to be terminated. Bill Creel was also thero, and the two of them told no that I hadn't been able to adjust to the way things were done at ' Midland, and so

. they would have to let me go. They asked me if 1 had any ,

w'ritton comments to make on the termination notice. I wrote down; ",I do' not agree with any of the above, andj ask for a can'plete inventigation of thiv ar.d n!J cthor main proble: tit, by tho Sun Francisco home oftice, and especially fir. S. Dochtcl.

Page Nine, Never in my life have I ever seen so many critical welds AND THfk hs'n Twas w de s,Iphte efrdfLEo &

, accepted in nuclear workJ , If this many errors are allowed to exist, the results could be catastrophic." 7 Af ter I wrote this down, Mr. Smith must have called Ann Arbor Headquarters, because he told mo to go seo Mr. Don Daniels on !!onday. 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 SM/ndik, f ff, said to this was that all thegwolders and , inspectors were qualified. The feeling I got was that even if I proved what I was saying, Daniels wouldn't do anything about it. He gnockn Y couldn't believo what I was telling him -- ho believed g i[h thef, l

papers that told him the tiidland personnel woro qualified.

l Before Daniels finally told me that I would have to bo

! fired, he mado another phone call. I believe it was to Eugono f

Smith and Bill Creel. Creel was the one who most wanted me to go, IN MY d'/'/NICN

• f$.

I was also told that in addition to my bad adjustment to Midland, I was being terminated because' I had f ailed to pass the Bechtel tests for Level I QC engineer. Now on I fM/i/NW5KINI .d5 stated earlier, I have seventeen years ofgoxperience [in QC and welding. At other Bechtel instellations, Palisades and

e San Ono o, I held both Level I and IAivel II certificates.

Midlan3 was not that different from these other Dechtel opera-tions. I cannot believe that I hadn't panced the Level I test at Midland. I was never givon a copy of the written part of

PagJ Ten f . * *,"

the test. I can only believe that I was fired for insisting that there were serious problems at Midland which my superiors refused to acknowledgk e 4No ATNN UFVffa 70 $1PAM

• kk Because of thesway I had been terminated bh Bechtol, 4.

4 and because I felt that my observations had not received any drJuAt 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 Rogor Warnick, William Paton and Don Danielson 6tMSULLY V, .

4 of NRC. In that interview I told them g what I have otalled ,

hero in this affidavit. I told them I felt that Bochtel was y adequately invostigating tho ' serious problems I had tried to bring to their attention, and that I felt I had been fired for trying to do this.

Af ter I spoko to the NRC, they sent out an inspector)( f/(

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 ono inspector. However, I do feel that the report con-firmod my chargos, based on what happened when the inspector met with the top mon from Consumers, Mr. Marguglio and !!r. Bird.

The inspector found them to be extremely hostilo to any sug-gestion v. hat there were serious deficiencies with wolding and .

with QC procedures and qualifications. The inspection report

\

found that further investigation was warranted in this area.

I

• Although the report noted the need for further oversight, it seemed to f ool tht.t volutary m.s.it.:21..y d c...... d by Consumorn would cicar up the problem. The probler..s are too

Page Eleven serious and widospread j to be left to be corrected by the

. F.A'.

people who created them. I believe that only an 4ndependent investigation, by the NRC 4NO

- and comprehensive ear byf" N.

outsido -

Wis.L BK [S 1, experts, can provide the assurance that Midland g properly

• fr.

built.

I am sure that Consumers and Bochtel will respond W*

to my chargos the.fAMAmay way they responded to the NRC in-spection.

IN MV(6NIf% $5 They wil1 dony the prob . 4 cms and promise voluntary l~/4 4 efforts to cure them. They will try to ruin my credibility, by saying that I was incompetent,' that I couldn't pass the basic tests. Nevertholess, I stand by my statement. After 1 -

,pp k swin4 A VTMcK, [,,df nearly twenty years of work ar an engineerj I know a defi-cient wold when I see one, and I know jnany of those C N*

wolds and other problems wont undotected or ignorod)by the mon responsible for inspecting them. Dechtel has shown by its attitude that it cannot be trusted to perform work of the high quality necessary in a nucicar plant. I fool that a full investigation into its managomont 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-lino in its

'present state of safety. To do so would be to betray I <

my responsibilities as a professional, as an engineer, and e

e

.. "i '

' *

• Page Twelve ,

as a citizen. ,

I have read the above twelve- (12) pageaffidavij.. To the ,

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

Y E. EARL KEllT

~

a.

1 SUBSCRIBED AND SWORN TO before me .

this dday of [v/ P,1982. ,

a _

Notary Public

'**"**** N o n., m s.

.. Cf'808At lui i,thg

. KhNif C. F.Lm

,1 woi e , ,w...e . c.,,,,,g, , , ,

• si~:rai o,..n ,,,

m' Commessing gepf,.F1 he Nr ' .

G e

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O s e h i -

6 0

. App ^ndix B

. . s f' .* o Attgylent 41 ACItEEMENT AND ACE %O%LEDCMENT OF OSLICATION TH15 AGREEMENT AND ACKNOWLEDGMENT OF OBLIGATION,is esecuted by the undersigned Employee and deinered to Bechtel on the date set forth below.

I, I hereby ackno. ledge that I understand and agree that the provnions hereof are part of my employmeni con-tract wsth Bechtel, and tha: my employment by Bechief and the payment of the compensation i receive from Bec by and in coniedetetion of my agreement to such provisions, and my acknowledgment of my obliga6cas boeunde 2.

As uwd herein, "Bechtel" shall mean Bahtel Group, Inc., et Bechiel Pomet Corporation and any affiliate or pubsidiary of Bechtel Pomet Corporation, of Bahtel Petroleum,Inc. and any affilisie or subudiary se Bechtel Civil & Minera!s, Inc. and any affsliale of subsidiat) of Bechtel Civil & Minerals,Inc. " Chant" shall mean any pers et entity for whom Bahit! performs services or from whom Bechief or Employee obtains information;"informati any information, knowledge, or data relating to plans, specif cation, documents, inventions, methods, procenes operations of Bechtel et Chents; and " employment" shall include employment for hourly mages, for salary, o

3. I secognJe that the buuness of Bechtel and the naiute of my employment mill permit me to have acceu to information of Bechiel and its Clients, that such information u the property of Bechtel and of ris Cleents, and that an) tiaed disclosure thereof may be hight) prejudicial to their interesis. I funher recognite that I may during the term of in ment make inventions, d.scoveries or improvements.

d. I shall noi disclose et vu, directly or indirectly, at any time, any information as above defined, unten such disclosure or use is in the course of my emplo)tnent by Bechiel or has been empressl> authorned in enting b) B act remove any entirigs containing 6nformation from the premises et poneuion of Bechtel or 6ts Clients unlen I empteu authotuation in enting b) Bechtel to do so.

3. Any and all ideas, inventions, discoveries and improvements which I conceive, discover, et make during the of my employment,in try may relating to the buuntu of Bechtel et arising out of or resulting from my emplo)1nen the sole and esclusive property of Bechtel et its nominee. I shall prorriptly advise Bechtel of each such idea,invention, d and imptovement and, unenever requested by Snhiel,I, my esecutors, administtstors,lesa!!y appoinied guardians, cons of representatives shall eithout funher compensation promptly esecute any and alllastruments which Bechsel may d enary to auign and eenvey to it,its succtuors or suigns, all the right, title and 6nterest in ud to each such ides,in cover) and itnprovement, and Letters Patent for the samt, et such other iviterests therein as I may acquire, togethe instrutnents deemed necenat) b) Bechiel to apply for and obtain Letters Patent of the United liaies or foreign countries,it being understood and ag'eed that all espense incident to the secuting of such applications and Letters Paten Bechtel,its succenots of assigns. I understand and agree that such obligation to esecute such inatturrients shaft con termination of rn) emplement by Bechiel with respect to each such ides,iniention, discoset) and improvemens. wh ch teived, discovered or made r du ing the term of m) emplo) ment,in any may relaung to the businen of Bechtel of of itsuliing from my ernplopent.

6 This Ag'eement and Acknomledgment of Ot!>ganon shall be effectne as of the dait thai i commenced et mill commence vny employment eith Bechtel.

Dated Employer (Signaiurel This agreement does not apply to an 6nvention for ehich no equipment, supplies. f acility, or trade sectet informa.

tion of Bahielis used ud whgh 6s developed entitely (Typedi en my con time, and tal shgh does not relait II) to the i business of Bechiel of f21 to Bechtel's actual of demon. A'lesi!

ettably anticipated teseasch of development, et (b) whsh does not fesult from any work petformed b) me for (Signaturel Bechtel.

(Typed) 96o3 (10/8l) Empletee laventlane sad Stetter Agreement

-* o 4

% e

. g 3

' On the occasion of the termination of your employment we should like to remind you of the nondisclosure and secrecy agreements which you have signed while in t the employment of Bechtel Power Corporation and any affiliate or subsidiary of Bechtel Power Corporation and Bechtel Incorporated and any affiliate or subsid-lary of Bechtelincorporated.

You can obtain information concerning the contents of any rJch agreements to which you are a party by contacting either the undersigned or the Legs! Depart-4 ment of Bechtel.

i We bring to your attention the fact that the provisions of any secrecy agreements which you have signed while an employee of Bechtel remains in force until they l expire by their terms and apply whether or not you are employed by Bechtel.

Thus you are bound by such agreements after termination of your employment with Bechtel to the same extent as heretofore.

Your secrecy commitments form the basis for similar agreements which Bechtel has given to certain of its valued clients; hence your full cooperation in complying strictly with the terms of your commitments is of extreme importance and necessity and will be assumed and appreciated by Bechtel.

Yours very truly, l

1 l

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i by l

l l

I Isagaedi

' Tatle E mployee A .

ITypodl-l '

j 10 ORDER THE oROuP INSURANCE CONvtMsiON LETTER ust P ORM NO.11e24 ORIGIN AL - Maste' Peteenael File fit me> led, etteth **Ce'tdieste of Me.t.ne" he'e I YELLOW = Employee Copy sti PEMsONNE L PROCEOumts MANu AL P OR INSTRUCTIONS.

I 3433 18 001

^

.. JCTL IYK

.* . ..e,% UNITED STATES 8 NUCLEAR REGULATORY COMMISSION REGION 111 5 I o 799 ROOSEVELT ROAO g GLEN ELLYN,1LLINOIS 60137 ee...  ;

G 24 82 i

e Docket No. 50-329(DETP)

Docket No. 50-330(DETP)

Consumers Power Company ff " j 3

A*ITN: Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen:

This refers to the routine safety inspection conducted by Mr. K. D. War of this office on March 2-4, 1982, of activities at the idland Plant, Units 1 and 2, authorized by NRC Construction Permits N . CPPR-81 a No. CPPR-82 and to the discussion of our findings with Mr. and others at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

No items of noncompliance with NRC requirements were identified during the course of this inspection.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than seven (7) days are available for your review,

% kb H y @

es t

a .

l

.p7a' ,;32 Consumers Power Company 2 8 "" "

• please notify this office promptly so that a new due date may be estab-lished. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure.

This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, j

fd;. E. Norelius, Director Division of Engineering and Technical Programs

Enclosure:

Inspection

• Report No. 50-329/82-04(DETP) and No. 50-330/82-04(DETP) cc w/ enc 1:

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris -*

Mary Sinclair Wendell Marshall Steve J. Gadler

U.S. NUCLEAR REGULATORY COMMISSION REGION III f Report No. 50-329/82-04(DETP); 50-330/82-04(DETP)

Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 W. Parnell Road Jackson, MI 49201 Tacility Name: Midland Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: March 2-4, 1982 h/bw4 Inspec.tcr: / K. D. Ward

~

3!'* d'k

/JNdN b~--- 3},,j;>u Approved By: D. H. Danielsen, Chief Materials & Processes Section Inspection Summary Inspection on March 2-4, 1982 (Report No. 50-329/82-04(DETP); 50-330/82-04(DETP))

Areas Inspected: Reports and radiographs of shop welds; previous inspection findings; nondestructive examination (NDE) personnel certifications of CPCo individuals; allegation. The inspection involved a total of 30 inspection-hours ensite by one hTC inspector.

Results: No items of noncompliance or deviations were identified.

a 9e

DETAILS Persons Contacted Consumers Power Company (CPCo)

• B. Marguglio, Director QA

• W. Bird, Manager QA

• R. Whitaker, Section Head - Fluids and Mechanical QA

• R. Davis, NDE/ Welding Group Supervisor QA M. Curland, QA Superintendent Bechtel Power Company (BPCo)

• E. Smith, QC Engineer

• M. Dietrich, Project QA Engineer D. Fredianelli, LWQCE V. Creel, LPMQCE A. Van Den Bosch, CQCE A. McClure, PQAE The inspector also contacted and interviewed other licensee and contractor e=ployees.

• Denotes those attending the exit interview.

Licensee Action on Previous Inspection Findings (Closed) Deviation (329/80-01-02; 330/80-01-03): "No positive way of track-ing design changes and assuring that completed work is modified in accordance with design changes and no procedure for handling design changes made after completion of work." The inspector reviewed the final response to RIII from CPCo dated May 15, 1980 and the following procedures which state the required information.

. Bechtel, Design Change Packages Interim Drawing Changes Notices, EDP14.47.1

. Bechtel, Functional Turnover of Systems, Subsystems and Items, AAPD/PSPG-11.1 (Open) Unresolved Item (329/80-17-02; 330/80-19-02): " Radiographic linear indications of welds in two borated water storage tanks." In the Summer of.1982, the tanks may be drained and made available for radiography.

(Open) Unresolved Item (329/81-21-01): Possible altered radiographs.

Waiting results of RIV inspection of Grinnell. Four welds of altered radiographs were found out of 46,505 shop radiographic views reviewed on site. ,

2

Functional or Program Areas Inspected

1. Allegations

a. Region III received allegations indirectly from an individual who was previously employed at the Midland site by Bechtel Power Corporation for the purpose of training to be a Level I weld inspector in accordance with Bechtel Quality Control Instruction, Level I Fabrication, Welding, Heat Treating and Nondestructive Examinations of ASME Section III - Piping, PW-100. The individual failed the Level I test two times and was terminated.

The allegations were as follows:

. Socket welds not being completely welded.

. A steam line weld had concavity.

. Problems in containment liner plate weld radiography.

BPCo had previously identified questionable areas in the inspec-tion efforts of one QC welding inspector assigned to inspect socket welds. CPCo was notified of the problem March 2, 1982.

BPCo is going to review 100% of the one QC welding inspector's efforts and random sample other inspector efforts in inspecting socket welds. CPCo may monitor the BPCo program. This is con-sidered an unresolved item (329/82-04-01; 330/82-04-01) and '

the inspector will review this in depth at the next inspection.

The inspector visually examined the following socket welds in accordance with ASME Section III,1971 Edition, Summer 1973 Addenda.

Line # Field Weld # Diameter FSK-M-1HBC-58-2 FW50 2" 51 2" 56 2" 61 1" 62 1" 63 1" 64 2" 65 2" 88 2" i 89 2" 1 90 2" l 91 2" f

FSK-M-1MBC-57-5 10 2" 11 2" 12 2" n

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Line # Field Weld # Diameter FSK-M-2HBC-57-1 118 2" 122 2"

" 2" 123 124 2" 125 2" 126 2" 127 2" FSK-M-2HBC-57-1 128 2" 129 2" 130 2" 131 2" 132 2" 133 2" The inspector visually examined steam line 2ELB-11 field weld 1, 36" diameter, nominal wall thickness 2.375". There is a slight offset which met ASME Section III,1971 Edition, Summer 1973 Addenda. The weld has been blended for inservice inspection and appeared to be acceptable.

CPCo recently contracted Hartford Steam and Boiler /NDT Engineering, a company with qualified / certified radiographic film interpreters, to interpret the shop weld radiographs of Units 1 and 2 containment liner plates 100%. This consisted of approximately 900 views. The results of the review found that approximately 20 welds had weld quality or radiographic technique problems. The results are docu-mented in nonconformance report #M-01-9-2-025 issued February 19, 1982.

b. CPCo received four allegations concerning B&W NDE work from an individual previously employed at the Midland Site (File 16.0, Serial 98FWA80, dated April 11, 1980). Three of the allegations were closed (Reference NRC Report No. 50-329/80-27; 50-330/80-28 and No. 50-329/81-06; 50-330/81-06). The fourth allegation has not been resolved to date. CPCo management in Jackson, Michigan is reviewing the allegation and has hired Teledyne Engineering Services to analyze the as-welded conditions for acceptability.

No items of noncompliance or deviations were identified.

2. Radiographic Review of Shop Radiographs (See NRC Report No. 329/81-21; 330/81-21 The inspector reviewed several nonconformance reports on the 46,505 l shop radiographs reviewed in 1981. Approximately 50 items that were radiographed were found to be unacceptable in weld quality or radio- i graphic techniques. The items are to be resolved in the near future. l

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No items of noncompliance or deviations were identified. l l

4 ,

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3. NDE Personnel Certifications The inspector reviewed the following CPCo NDE personnel certifications in accordance with SST-TC-1A, 1975 Edition:

Name RT _PT M

_T R. Davis II II II T. Charette II II No items of noncompliance or deviations were identified.

4. Review of Shop Radiographs The inspector reviewed radiographs and reports of the following shop components.

a. Radiography performed by ARMCo for Guyon Alloy Company in accordance with ASME Section III, 1977 Edition, Winter 1978 Addenda.

System Weld Diameter Thickness Date RT SN0-8842 1P 12" 1.371" 8/8/80 i SNO-8843 IP 12" 1.371" 8/8/80

b. Radiography performed by Peabody Testing, X-Ray Engineering Company for Bechtel Corporation in accordance with ASME Section III, 1974 Edition, Summer 1974 Addenda.

Component Diameter Thickness Date RT 5346-14-1-8 Gate Valve 4" 1/8" - 1 1/2" 10/13/76

c. Radiography performed by Taylor-Bonney Division for McJunkin Corporation in accordance with ASME Section III, 1977 Edition, Winter 1978 Addenda.

1 Component Weld Diameter Thickness Date RT 90 Ell 802352 14 18" 0.395 12/17/79

d. Radiography performed by ITT Grinnell Industrual Piping Inc. for CPCo in accordance with ASME Section III, 1971 Edition, Summer 1973 Addenda.

System Weld Diameter Thickness Date Rt

, 2CCB-6-S-604-9-L E 4" 0.593" 1/25/77 2HCB-2-5-613-5-11 CR3 18" 0.437" 8/9/76 5

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. 2HCC-84-S-604-18-1 B 2 1/2" 0.192" 9/26/77 l 2ELB-11-5-632-1-1 BUZ 36" 1.379" 10/30/78 2HCB-16-S-604-6-2 C 6" 0.156" 6/22/77 2FCB-18-S-604-5-9 A 6" 0.312" 4/25/77 No items of noncompliance or deviations were identified.

Unresolved Matters Unresolved matters are items about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during this inspection are discussed under the paragraph 1.a.

Exit Interview The inspector met with site representatives (denoted in Persons Contacted paragraph) at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection noted in this report. The in-spector has been going on inspections to Midland since September 1978 and this was the most hostile exit interview ever encountered. The acting NDE and Welding Supervisor, Section Head, Fluids and Mechanical QA and the new Site QA Superintendent were very concerned with the socket weld problem noted in paragraph 1.a. The Site QA Superintendent informed the inspector prior to the exit that CPCo would establish an overview program to check into the welding and . inspection of socket welds and qualification of QC personnel. However, at the exit this program was completely unac-ceptable to the QA Manager and Director. This matter is an unresolved item and this area will be reviewed indepth during,a subsequent inspection.

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D/D \ ?;.r) 4/D May 12' 1982 WR&PL A8 bu i James Foster DESTI [

Inspection & Enforcement DEP&OS File j (J

~3 Region III, NRC

Dear Mr. Foster,

l We have been in contact regarding certain welding allegations at the Midland plant. I note favorably that these allegation issues are considered unres'olved in Inspection Report 82-04. There are several cuestions about 'these issues which tst!'11 trouble me.

According to the IAE Report, the ihdividual who made these alle-gations failed to pass his Level I exam twice. However this inspector was a Level I and Leve l II inspector previously and has extensive welding and OC expe rience (enclosed resume). This individual believes that he "fa!!ed" his Level I examibecause of his open criticism of OC pract. ices rather than because of a l ack, o.f competence on, his pa r t .

This inspecto'r attempted to woric w.ithin the established system, alerting his superiors to specific OC Inadecuacies and seekinc reinspec-tion. of work previously accepted by inferior OC standards. Af ter about a month of unsuccessful efforts in this regard, this individual was fired.

He made a written statement disagreeing with the terms of his termination

~

and calling for a top 1evel Bechtel revifew of onsite welding conditions at the Midland plant.

Due to the circumstances regarding this inspector 5 open and ongoing criticism.,. a welding . investigation was probably anticipated. The welding 1 i

in question could have been redone. Welding rework prior to NRC inspection l

occurred 'at the ;Zimmer plant to discredit allegations in this fashion.

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9 MAY l 7 E82

One example of possible welding rework involves the reported con-cave condition of the 36' main stema pipeline from the containment build-ing. The 1-li foot concave condition was witnessed by another insp.ector who,according to the alleger, agreed it was defective at the time they saw it together.When NRC Inspector Ward sought corroboration of th4 :e.11eget statement,the secondlinspector was "noncommital* saying something like "look for yourself- what do you think?",(as you related to me.rollowing the inspection). Inspector Ward found the main steamline weId adecuate

'when inspected. But the question as to whether this weld was previous!v concave, has not been pursued by the NRC.

In response to my questions about poss ible weld rework, Res ident inspector, Ron Cook, replied that the NRC had checked the records and found no paperwork Indicating recent rework of any of the welds inspected.

He considered such rework highly implausible. However if the NRC does not thoroughly investigate this possibility, important safety issues could go undetected.

The NRC has recently testified before Congress that their inw sti-gations seek to learn the root causes of problems as well as their speci-fic effects. The possibility that a concerned individud! has lost his Job because of his willingness to speak up over the inadequacies he saw, should be pursued by the NRC. The second inspector could be placed under oath to answer questions about the malm steamline weld. The job performance of the alleger and records of his " failed" Level I examinations should be thor-oughly inesstigated.

Tne description of the exit interview as "the most hostile exit interview ever encountered" by this inspector since 1978 and the re s is t ance l

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of OA Director MargugIlo and OA Manager Bird to the commitment of the new Site CA Superintendent *to establish an overview program to check welding and cualifications involved, raises serious cuestions about the functlon-ing of the reorganized OA department,(an issua Mr. Keppler intended'to closely monitor and assess,'R/2/82* testamosy,7697-6)

Due to the seriousness of these welding allegations and the relat-ed issues, I would !!ke to see the following questions addressed by the NRC. I) Are QC inspection practices conservative enough to identify inferior welding 7 Have they been so in the past?

2) Are CC (Level I,II) certification criteria so subjective that pass / fail decisions could be based on f' actors other than individ-ual competence?

3) Are OC inspectors able to raise concerns and make criticisms within the OA MC framework without fear of losing their Jobs?

4) Does the OANC program address generic implications of Identified problems even if that entails reviewing work previously Judged acceptable by identified inadequate CC methods?

Perhaps you are already pursuing some of these cuestions in your continuing investigation. I note that Audit Finding Report MOI-217-1-03F of 3/2/82 identifies inadequate wild allowables in 6 of 10 calculations audited.

Thank you for your ongoing efforts concerning these welding allegations.

Sincerely Barbara Stam!ris 5795 N. River Freeland, Mich. 48623 cc: W. Paton NRC T- DMins GAP:

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1 Government Accountability Project Institute for Policy Studies ATTN: Ms. Billie P. Garde Director Citizens Clinic for Accountable Government 1901 Que Street, NW Washington, D.C. 20009

Dear Ms. Garde:

I have reviewed your September 6, 1982 letter to me and appreciate the opportunity to respond to your concerns.

The Midland allegations submitted by the Government Accountability Project earlier this year have been forwarded to the NRC's Office of Investigations for review and investigation. Region III will provide technical assistance for the investigators on the case.

Your consnent that the special inspection team "has not arrived" is simply not true. The Office of Special Cases was formed in mid-July 1982 and the selection of personnel was made at that time. Robert Warnick is director of the new office and Wayne Shafer is chief of the Midland Section. They have been actively involved since then. I understand from Mr. Shafer of my staff that you would like to meet with the Midland Section personnel. I certainly encourage these types of meetings and urge you to schedule a meeting when it is convenient for both you and my staff.

1 One point needs to be clarified. I did not organize the Midland Section to perform investigations. They are performed by the NRC's Office of Investigations, and all investigators formerly assigned to me now work for )

i James A. Fitzgerald, Acting Director, Office of Investigations. Region III continues to perform technical inspections and provides technical support for OI as requested. Inquiries about investigation policies should be addressed to Mr. Fitzgerald at the NRC in Washington, D.C. ,

Regarding the Zack Corporation problems, you are quite correct that the LaSalle plant has had priority over Midland. Many of the problems, however, have generic applicability to all the sites where the Zack Corporation is involved. As the investigation at the LaSalle plant and Zack corporate office continues, many of the generic problems that coul1 apply equally

to the Midland site are being reviewed. Specific Zack problems at the Midland site will be investigated as manpower availability permits. The

! Consumers Power Company investigation of the Zack allegatl.ons will not be

! a substitute for the NRC inquiry; we intend to both assess the adequacy  !

of the Consumers Power investigation and continue our own :nvestigation l

! of the allegations relating to Midland. We have set January 1983 as a tentative date for completion of the Zack investigation. IMtil the

, investigation is complete, we will not be able to discuss the findings.

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aa Government Accountability Project OCT 1 2 T2 As I as sure you know, the Systematic Appraisal of Licensee Performance

! (SALP) Program is an assessment of licensee performance based on input from all the inspectors involved in inspections with the licensee. The SALP rating in Support Systems, VI, applied only to Consumers Power Company's quality effort, not to the Zack Corporation. You may wish to discuss this with the Midland Section when you meet with them. NRC procedures require that the licensea be provided the opportunity to respond to the SALP findings, and the meetings we have held with Consumers Power are to fulfill that requirement.

• Regarding the question of why Consumers Power Company did not report the Zack QA breakdown to the NRC in the fall of 1981, the documents provided by another alleger revealed that Consumers Power and Bechtel concluded that the problems would not have adversely impacted the safety of operations at the Midland plant. The basis for this decision will be reviewed during our site specific inspection at the Midland site.

The NRC became aware of the Zack Corporation problems in October 1981 when the Commonwealth Edison Company submitted a 50.55(e) report.

I have made no decision as to whether an independent audit of Zack work i

vill need to be conducted at the Midland plant. Consumers Power Company is presently selecting one or more independent contractors to perform an independent third party review of a critical plant system or subsystem.

In addition, Consumers Power plans to have an independent contractor conduct an INPO type construction project evaluation. My decision regarding  !

an independent audit of Zack work at Midland will be based on the findings of our investigation and special inspections and the scope and findings of the licensee's third party independent assessments.

j Regarding the interview with one of the allegers whose affidavit was presented to NRC by GAP, as you stated, the interview was taped. My staff has reviewed the transcript of this interview and noted no discussion regarding NRC.

whether or not this person could go to the site to assist the i

welding Some of the alleger's concerns have been looked at by our Region III specialist. The balance of the allegers concerns will be addressed l

either by investigation or special inspection.

Our policy for taking personnel to the site is well known. The information provided by this individual is being reviewed by my staff. When our review is coupleted he will be contacted by the NRC and requested to accompany us on site.

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Government Accountability Project OCT 1 2 G*f l

Regarding the Bechtel Employee Inventions and Secrecy Agreement, form 3002, we view this doc eent as a standard form used by companies to protect the company's proprietary information and inventions. I have no knowledge of anyone being fired for talking to the NRC with this doceent used as a j basis for dismissal. l Ef fective later this month, new regulations will be in effect requiring i licensees, including nuclear construction sites, to post notices informing employees of their protection against discrimination for providing information to the NRC. We will review the Bechtel form and its use further to determine if the workers' perception is that it prohibits discussions with NRC personnel. Certainly, the new posting requirement may help alleviate any perceived intimidation for werkers desiring to provide information to the NRC. A copy of the required posting. NRC yorm 3 is enclosed.

i In closing. I want to personally assure you that the NRC is diligently working on the allegations that have been presented to us by GAP. I j sa sure that GAP wants our office to do a complete and thorough inves-i

> tigation and that is exactly our intent, but this is time consuming. We

must assign our priorities to the most safety significant issues sad I consider the Midland Remsdial soils Effort the most safety significant issue at the site. As priorities dictate, all relevent safety issues will be investigated.

l Purther, we sincerely do perceive our role as representatives of the public interest and certainly do not feel constrained by the utilities' i timbtables. Similarly, we should not feel bound by timetables called for by other interested individuals or organisations. This region has taken and will continue to take, appropriate and decisive action when problems are identified at nuclear plants.

Sincerely.

Ja.aes G. Esppler Regional Administrator

Enclosure:

As stated bec w/ enclosure: ,

H. R. Denton D. G. Eisenhut W. D. Paton R. C. DeYoung

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