ML20092G761

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Affidavit of L Kinney Re Concerns for Inadequate Controls on Early Concrete Pours & Lingering Effects on Condition of Plant
ML20092G761
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 06/01/1984
From: Kinney L
PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML20092G713 List:
References
NUDOCS 8406250225
Download: ML20092G761 (3)


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C. Field QC Inspectors did not " affix a hold tag to all discrepant items reported on a DCN".

During the Final Walkdown Inspection Program for Rupture Restraints no

......... hold. tags were affixed when a deficient condition was identified and then listed on the QC/Eng. Walkdown sheet.

Deficient (discrepant) conditions were identified on

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paper, but were 'not identified in the field by having a These deviations from ESD 273 and ESD 268 hold tag affixed.

were carried out by Field QC Inspectors and Engineers

' . based on verbal instruction from QA/QC and Engineering Man-

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agement.

Additional noncompliancies to ESD 273 were identified on DCN#476-030 (5/16/80):

1. Field QC Inspectors did not reference assembly drawings Verbal instructions for their examinations of the U Bolt.

on QA/QC Management to Field QC instectors was to only assure U Bolts were in place and not perform detailed 273.

examinations to the drawings as required by CES "W (cold kOh

2. Field QC Inspectors did not check pipe li;innc:

gaps) as required by ESD 273.

3. Field QC Inspectors did not examine assembly drawings I componentdfscriptionsagainstinstalledassembliestoin-sure all components had been installed. Verbal instructions from QA/QC Management were to only assume that U Bolts were in place and not to perform detailed examinations to the .

drawings.

ESD 273 would be revised by Pullman bnplementing the verbal in-structions used to perform all Unit I Final Inspections after the PG&E would approve whole Unit I Walkdown program was completed.

this revision in late May/early June 1980. k6ek The Unit I Final Walkdown Inspection Program would home identified significant numbers of discrepancies and resulted in major rework. Pullman DR#4259 is representative of the type of discrepancies identified. DR#4259 identified that connections on Rupture Restraint 126, modified in March 1976, were not to specification.

The following discrepancies were identified:

8406250225 8406R1 PDR ADOCK 05000275 A MVS

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1. A plate added was not documented on a material requisition or marked to identify source.
2. FW 32, designed as a full penetration weld on d three ' sides'of the added plate, was 1/16"-below flush an the weld'had not been ultrasonically examined and was

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t now inaccessable.

3. Original eight bolt holes in the receiver plate were The technique used plug welded without documentation.

did not comply with AWS DI.0-69 code. --

4. The four new lower bolts were drilled through FW 32 The backing strap was not trimmed and its backing strap.

to facilitate full seating at the bolt head and the strap had a maximum gap of 1/4".

5. Design required eight 5/8" A 325 bolts but eight 3/4" Washers were installed under A490 bolts were installed. Bolts the turned element but not under the bolt head.

were not documented on a material requisition or marked to identify source. '

6. The top south bolt had received air arc damage resulting in fusion of the nut and bolt.
7. The bottom north bolt did not have full engagement.
8. All bolts have been tensioned, evidenced by torque seal, however, process sheets were not documented.
9. Splice plate had been installed with a 1/16" gap at top and 1/8" gap at the bottom without shims. .

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1982.

l10k The Unit II[ Final Walkdown Inspection began i d toindelete June from To expedite the Walkdown process ESD 273 was rev i sseinstalled

- . pct h5N tho Walkdown process all bolted and welded connect o

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Action to after 1/24/79. ~ ~

79-RM-005, dated 1/24/79, which stated under Corrective developed and Prevent Recurence that " Pullman Power Products

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~~ design has implemented a program which' assureis adequatedeveloped control of Training and indoctrination programs have been inspection changes.

and implemented which assures adequate performance of

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ffice.

parsonnel."As Internal Auditor, in a July 7, 1982 Pullman Intero nsideration Correspondence to the QA/QC Manager, I requested ltedaand reco .

of the deletion of Final QC Walkdown Inspection of Bo"There is docume te per-Welded Connections installed after 1/24/79: d cvidence available which raises questions about the "a equaS formance of inspection personnel". findings concerning discrepancies been approximately one hundred (100) ld QC Inspectors or noncompliances to procedures, committed by Fie cted by QC or committed by others but not identified and/or corre l These findings are documented on Pullman Interna Inspectors. Most of these Audit Reports and PG&E Minor Variation Reports.The areas of dis findings involve Unit #2 work. i Process compliances identified were Quality Control Inspectialons, Removed Sheet Discrepancies, Discrepancies with Installed l Storage Materand and To be Reinstalled, Discrepancies with Materia Requisition Traceability and Discrepancies with Field Warehouse and Material. d Unit But Pullman QA/QC Management would not reconsider an hYinalWalkdownswerenotperformedonpost1/24/79rup lt in g4e work.

The Unit II Final Walkdown Inspections would also resu Subsequently, Pullman Field major rework of rupture restraint. 1/24/79 work Engineers wrote several Discrepancy Reports on post yEtiewtby Also

\kh84whentheworkwasinad=3etslyreviewedbyEngineer 1

ifying Deficient Condition Notices would be written ident documentation. problems missed in pre-1979 work.

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-,- o In 1982 serious problems were identified in the calibration li ,

process for torque wrenches used in the rupture restraint bo t ng program.

The problem extended beyond rupture restraints kto PG&Els.

enlibrated equipment used on ANSI B31.7 and ASME code wor i .

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Ggneral Construction'Depa'rtment had been providing'calibrat on cOrvices to Pulbnan at the Diable Canyontorqui'

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site wren'ches, since at least 1974.

PGGE calibrsted 'a vafi'ety,of" tool's' including:  :

hydrogages, thermometers, heat temperature recoriers, hygrometers As a result of Pullman Vendor Audits gf cnd' trip-volt-ohhh meters.in PG&E's General Const i b3ing forwarded to PG&E's Nuclear Plant Operations for QA calibrat on.

PG&E's NPO calibration service had never been Pullman, subjected through to a myself, program audi.t by Pullman as required. 1982 performed a vendor audit of PG&E's NPO Department in October cnd identified the following deficiencies:

1. There were no documented instructions for the of Pullman torque wrenches and subsequent documentation.
2. The traceability of calibration operation for their be torque wrenches and subsequent certification could not assured because:
a. The identification of the torque wrench on related documentation was not consistent.
b. The certification documentation was confusing and in-adequate. d
c. Documentation necessary for maintaining nerated.

traceability an

. certification proving traceability was not ge

3. The calibration documentation for NPO Standard .

deficiencies:

a. There were no documented calibration frequencies for a standard used in a calibration process,
b. Calibration information labels attached to NPO equipment did not provide positive identification of the devices for which the information was intended.

i d t{P As a result of the audits in PG&E's General d Vendor'sConstruc frrev Departments, Pullman removed PG&E frein its Approve res to until such a time as corrective action measures and mea preclude recurrence were completed and approved.

c. . e s Subsequently PG&E'would write a Minor Variation Report #M-4406 cgainst Pullman. The discrepancy would identify that Pullman had procured calibration services from PG&E General Construction Depart-ment without written contract or. specification wh.ich delineated.

Quality and Technical requirements. This calibration service had been going on as far back as 1974 without Quality and Technical requirements. -

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' iAlso".in 198E, significant Program'deficiAncies were identified in the application of Weld Procedure Code 7/8 to Rupture Restraint Welding. In August, through Pullma'n Unscheduled Internal Audit #32 I identified"in both Units of the plant a large number of

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cquare groove welds made in one inch thick material using code 7/8.

These type welds were not a prequalified joint detail of the AWS Welding Code. Weld Code 7/8 did not have Procedure Qualification Records for the Type Weld as required by the AWS when joint details -

differed from those prescribed by the code. PG&E and Bechtel res-ponded on 1/24/83 to a Pullman letter concerning this problem by In stating that the square groove welds would not be allowed.

addition, the PG&E and Bechtel letter stated :" Weld procedure specification code 7/8 has been approved for the precess and joint configuration itemized on the WPS. There itemized parameters are considered prequalified by AWS or are supported by tests and pro-cedure qualitication records. If Pullman wishes to use WPS Code 7/8 for processes or joint configurations not itemized a new WPS and PQR's are required."

Based on this PG&E and Bechtel letter, my Pullman Unscheduled -

Internal Audit #35, dated 12/1/82 with a final prepared date of 3/23/83, identified in both units of the plant a number of single db S /evel groove welds in skewed T joints with special fit up require-ments and fillet welds with special fit up requirements which were not prequalified AWS welds. The welds were made with Code 7/8 without establishing Procedurc Qualification Records.

In addition, eight other types of joint configurations were identified as made with Code 7/8, but which were not itemized in the code 7/8 WPS. These welds did not conform to the intent kA

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of the PG&E and Bechtel letter and were nonconformances to the Weld Procedure Code. Other Weld Procedure Code 7/8 deficiencies were also identified. Pullman spent 1983 and 1984 implementing corrective action to these Weld Code 7/8 problems. But the

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cor'ective r aEtion has not' addressed all the problems. Code 7/8 wa's revised and new weld procedure #AWS 1-10 generated which addressed joint configurations not listed in Code 7/8. But the ac-tual welds in'the field made in non'conformance to Code 7/8 have not been addressed. The Pullman Power Products construction program for Pipe Ruptures Restraint has a long and continued list-ing of discrepancies and nonconformances to PG&E specification QCkand10fFR50AppendixB.QualityAssuranceRequirements.Therecan be no assurance that all of the problems have been identified, reported and corrected. PG&Einf.S. #8833XR defines Quality Assurance as those planned and systematic actions necessary to establish confluence that material (equipment and systems) will perform satisfactory to services. PG&E defines Quality Control as those Quality Assurance actions which provide a means to con-trol the quality of material supplied (and work performed) to predeterminded requirements. ' Pipe rupture restraints have had a continuing history of failure to meet basic codes and quality assurance standards. Perhaps quality assurance is all irrelevant.

If QA matters, however, there is no basis for confidence that if an earthquake occurs, the piping will be sufficiently res-trained to avoid damaging surrounding equipment.

I have read the above Z page affidavit and it is true, accurate and complete to the best of my knowledge and belief.

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. Signed C O- M Date b d-b k h Harold Hudson -

D STATE OF CALIEPNIA

95 CXUIY OF SAN LUIS OBISPO Oy

<t g-On June 5, 1984, before me, the undersigned, a Notary Public in and for said County, personally appeared HAROLD 0. H12 Soli, proved to me on the basis of satisfacto::-

~' n 3 evidence to be the person whose name appears in the above instru: rent, and acknowledged

\./ . o' to me that he executed same.

k HH/nw WIEESS my hand and official seal. Il m Il L'u LM Lisacienter, Motary Public Qg m' ..

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5 5.CAUlT AFFIDAVIT

  • 84 EN 21 no:43 My name is Larry (D ) Kinney. .I am submitting this J,..v affidavit- freely and voluntarily, without any thteats, inouce-ment, or coercion to Mr. Thomas Devine, who has identified him-self to me as the legal director of the Government Accountability Project. This statement evidences my concern for inadequate con-trols on early concrete pours at the Diablo Canyon Nuclear Power Plant and any lingering effects on the condition of the Plant, particularly if the plant shoold be subjected to the stresses from an earthquake. I am also concerned about the effects on consumers who have to pay for Diablo Canyon, if the waste that I observed continued during the ten years after I left.

I worked for Pacific Gas and Electric Company (PG&E) at Diablo Canyon from 1968-January 1973, initially as a surveyo:: but primarily as an inspector for early concrete pours and instal-lation of rebar at Unit I and Unit II. I also served as night shift inspector for the breakwater, and as an inspector for cad-welds. I resigned in 1973. Among the reasons for my resignation were the following:

1) Failure to review as-built drawings. Supposedly -

as-built drawings were checked after being signed off. I suspected that was not the case, however and decided to test my suspicions. In mid-late 1972 I signed drawings as "Roy Rogers,"

" Gene Autry," " Donald Duck" and " John Wayne." I then waited to  !

be challenged. No one noticed.

2) Harassment of field inspectors. Field inspectors

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from Pittsburg Testing were nired to check reinforcement bar  !

steel. They regularly complained to me of threats from PG&E 's steel contractor, Pacific States Steel, if they wrote up problem i reports for. conditions such as excessive n. umbers of voids in cadwelds. I recall the reports of harassm'nt e as follows: "We pay your check, so keep your mouth shut or you 'll be fired." I

3) Management veto of enforcement efforts. One of the  :

l main reasons I resigned was that there were too many things. that I couldn ' t sign of f, but management wouldn ' t let me reject. ,

Man-agement consistently overrode my attempts to stop work. One ex- ,

ample involved reinforcement bar steel that had been bent back and forth. I wrote up the practice, because it establishes break  ;

points and compromises the strength of the steel. This is a basic rule of concrete work. Even on this issue however, manage-ment overrode me. -

4) Too much payola on the job. Construction  !

l supervisors offered me $100 per night to keep my eyes shut during  ;

the breakwater work. I declined but was disillusioned both with the offer and myself fo'r briefly considering it.

5) Advance warning and gag orders for Atomic Energy Commission inspections. In my four years on-site, management always gave us at least one day advance warning before all Atomic Energy Commission (AECl inspections. Management told the inspectors not to ask questions or volunteer any information beyond what was specifically requested by the AEC.
6) Waste. I feel strongly that a significant amount of the construction costs were indefensible. One example

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. js involved $30,000 that was sp to build the guards shack and fence. I . told my. boss. that. it was unacceptable to spend ,so much ,

for so little. To the best of my recollection, the message that he communicated to me could be summarized as follows: "You might as well accept'it, because we can just go to the Public Utilities Commission and get it all back. The plant will be paid off six months after iti begins operating."

With Mr. Devine as my legal representative,,I will cooperate with any good faith NRC attempts to follow up on this disclosure and will help direct Commission personnel to specific examples of the conditions described above.

-I have read the above page statement and it is true, accurate and complete to the best of my knowledge and belief.

y inney naw /

, Larry p

i State of Idaho, Kootenai County SS On this i day of bJr L ,1984, before me, Ukalun h a Notary Public in the for sd.id county and state, personally appeared 8 Larry Kinney , know to me to be the person who executed the foregoing '

instrument, and acknowledged to me that he executed the same.

In witness whereof, I have hereunto set my hand and affixed my official seal i the day and year in this certificate first above written. 1 i

0afnitir o n t it9 U >t b V i

Notary Public residihg at:

Coeur d' Alene, Idaho I

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