ML20127G034
| ML20127G034 | |
| Person / Time | |
|---|---|
| Site: | Midland, 05000000 |
| Issue date: | 06/29/1982 |
| From: | Garde B AFFILIATION NOT ASSIGNED |
| To: | Keppler NRC |
| Shared Package | |
| ML20127F538 | List: |
| References | |
| FOIA-85-213 NUDOCS 8506250332 | |
| Download: ML20127G034 (14) | |
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- DO NOT DISCLOSE Contains identi'y t of e, confidential source AFFIDAVIT - .
My nane is E. Earl Kent. I am making this statement of my own' free will to Mr. David Crow, who has identified .
- himself to me as an' investigator for the Government Accountability Project. I am speaking without threat or promise of material benefit. My reason for making this statement is to express my deep concern over the mr
- quality of construction at the Midland nuclear plant,
^9 . where I was terminated in March of 1982 for persistently I9 bringing defects in construction and specifications
- 60 I to the attention of my superiors. .
Or - I have worked for seventeen years in engineering, N most recently at six nuclear plants. I hold the title of senior Quality Control Eng,ineer for nuclear welding. I have been a member of the American Society for Quality Control, and have published several books - on welding and structural steels. Before coming to Bechtel, I worked as an engineer for Litton Industries, as a field welding inspector for Boyle Engineering
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Corporation, and as a welding supervisor for Fluor f? Engineers. I have also wo'ked r as a quality assurance
, gnd quality control engineer for Joy Manufacturing.
I have attend'd e more than half a dozen professional 1 education courses on engineering.,and quality control. Prior to moving to the Midland plant, I had worked l for Bechtel at two of its other nuclear units, Pallisades I e
Paga Two ) ,
,'. Contains identity' of confidential 4
- purce. DO NOT DISCLOSE and San Onofre Plants One and Tdo. In both of these earlier . .
! Bechtel positions, I served as Senior Quality Control
- Engineer. I received top recommendations from my .
l . supervisors at both these plan.ts. There is a letter on file with 3echtel's central office, from the Vice President l of Bechtel's Los Angeles Power Division, for my work there. Based ony my years of experience in nuclear plants-, it it my prUfessional opinion that the Midland plant , 1
- is the worst nuclear facility I have ever seen. This.
affidavit will detail instances where Bechtel Corporation has systematically downgraded standards for safety-related equipment, to the point where I do not_ believe that much of the construction _will not withstand the stresses it j should be built to take. Bechtel has hired engineers and QCinspectorswhoarenotadeqIatelyqualifiedor, trained for the complicated work in a modern nuclear plant. I , have seen Bechtel personnel, both QC inspectors and engineers with QC responsibilities, routinely accept substandard work. . I will also give . examples of the unhealthy degree of reliance that certain NRC inspectors have placed in the
. Bechtel personne,1 whom they are supposed to monitor. NRC -
field inspectors showed a surprising willingness to let the Bechtel personnel do all the dirty work involved
- in supposedly independent investigations. Because NRC
. inspectors often didn't themselves try to take the t
h
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- f. . neasurements, or climb into less accessible areas, the inspec-tion reports that were supposed to represent a completely
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', separate check on Bechtel performance often wound up basing their approval on Bechtel's evaluations of its own work. 8,.
~~~ s My expertise is in welding' inspection. When I first came to Midland, in December 1981, I reviewed Bechtel's specifications and procedures. I was astonished to see that in numerous places, Bechtel had established standards which
/ ffellbelowthoseof.theASMECode. The ASME Code ref.lects the
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I best judgment of the national society of professionals in this , area. It is the result of many y' ears of testing. Despite i this Bechtel in some cases made th'e decision, based on their own engineers' short-term testing in San Francisco, to modify these standards. If Bechtel had made these changes only to take account of particular needs at Midland, that would be one thing. But' in the area of welding, where I was qualified to judge, the new specifications were inadequate to the needs of a nuclear facility. There is an inter-office meio, dated 24 April 1981, which I have in my files. It is between the project QC head, E. Smith, and a main office materials and quality services official, D. Hackney. The subject is socket weld engagement length. Hackney states that as long as the pipe is not with , i j * ' drawn from\ ;th e fitting it will be approved. This means that a i gap of nea ly any length will be tolerated between the end of the pipe and the bottom of the sobkst. Thcsc gar:. vcaken the l joint, and make it susceptible to vibration. The ASME Code e e
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.- ' has, for this reason, established a much more rigorous specification. -
This is only one example of the systematic downgrading of welding standards I saw at Midland. The Hackney meno became one of many sheet-memos placed in the specifications book.
. Equally as serious as the problem of downgraded specifi-cations were the problems created by the incompetence and ignorance of QC. Even something basic like knowing how to use the fillst gauges correctly to measure the size of welds was -
beyond the ability of some of the Bechtel inspectors. In early February, I was working with one of these Bechtel QC inspectors, John Kunski. John was about to approve a fillet weld when I saw that it had not been fully welded.
, Fillet welds have to be full across the blade, not just touch-ing one edge of the blade. I drew John a diagram to show him this. When John looked at the' diagram, he saw that I was right.
But the' welder refused to put any more weld on -- he said he'd been doing it that way for two years, and his boss had always approved it. We finally had to call his boss in, and explain it to him, before we would get the, weld to be redone. Paul Schulz, another QC inspector, was also there to hear the explanation, and he admitted af ter I showed him the diagram that he'd been approving bad welds himself. e Undersized and improperly done welds were serious problems, but at least they, didn't affect phe integrity of the piping . itself. High-pressure piping, which contains up to 1500 pounds per square inch, is very vulnerable material. It reacts like
Page Fivo C ntains identity of confidential source. D0 !!OT DISCLOSE 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 a
concerned to discover that many welds in the piping had been, improperly ground down, grinding down the pipe wall thickness b 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 metal for the piping systems. In small bore piping, the only way to inspect the inside of the piping' for corrosion is to 2:c.r , . . take what is called a thickness and materials (TM) reading. This is a time-consuming process if done correctly. To the , best of my knowledge, the Bechtel QC inspectors rarely took the time necessary to do this type of verification. They usually relied on visual inspection only. Visual inspection, can detect corrosion only on the outside of the piping. l When I performed a thorough inspection myself of the l . piping, using TM readings for the inside of the pipe wall, I l discovered extensive corrosion. Although the QC reports' appear
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to assure that the piping is of safety-grade quality, these reports fail to reflect the problems of the piping systems which I discovered. To allow severely corroded piping to.be approved for safety-related systems is in my opinion inexcusable, a'nd certainly very dangerous to the successful operation of ghe plant. Another piping problem with which I was personally familiar developed because Bechte,1 allowed electrodes used in welding to be taken out of their hermetically-sealed containers
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- J for eight hours before use. The American Welding Society (AWs) standardI allows only four hours in the open air. When the ,
electrodes are left out, the chemicals in their coating attract ambient humidity. When this moisture is absorbed, it will . become steam under .the heat applied during the . welding process. 3 Each speck of moisture will expand to 750 times its initial volume, and results in substantial porosity, or simply empty
, , space, within the completed weld. The weld will appear strong, j but be Wdikened fr6m within.
The AWS standard is used for * ) ordinary bridges and office build,ings, but apparently Bechtel thought that twice as lenient a standard was appropriate for a nuclear plant. . X-ray inspections of welding performed under these , conditions has revealed porosity. The welds have had'to be torn out and redone, not just once but many times, often within the same joint. This is one more example of Bechtel's not doing it right the first time'. Every time they had to tear the welds out and do them again, it adjed 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-r t'ive to do the work right the first time. Each time further -
. , expenditure \s are required to redo work, it adds to their fee.~
e ! I I have sees work ripped out because of shoddy installation, redone, and then ripped out and r,ddone again because it still wasn' t right. One QC engineer, who has been at Midland since O
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Contains identity of confidential Pa9e Seven sourcs. DO NOT DISCLOSE N .. , the beginning, told me that over 90 percent of the piping in
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, the entire plant has had to be cut out and replaced at one ' '
, point o'r other. In my mind, this raises serious questions of safety, but it also makes me wonder who is going to wind up paying t1:a bill for, Midland. Bechtel's indifference to quality will cost the ratepayers a bundle, if they are allowed to pass on their costs to the public. -
, The defects I have described are generic to the Midland plant. Ei6ey have happened because Bechtel has hired inexperi-
- enced welders and inspectors. Th,ere were few formal require-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
; weeks, and based on my experience in working with the ' welders and the inspectors, I can state that they were not properly trained. When inspectors don't know how to use a fillet gauge to measure welds, you know that the overall program standards cannot be very high. -
N'RC inspections often failed to correct problems. In the area of the inside wall corrosion in small-bore piping, this was because the inspectors seem'ed too willing to trust the Bechtel inspectors when they made their tours. It was
. , generally the Gechtel people who actually climbed around on '
the piping and called out their measurements, which the NRC inspectors would then write down.j As a result, many of 'the - inspection reports do not reflect anything more than Bechtel's own assertions. s O
'N Paga Eight, icontain's identity of confidantial courcs. DO NOT DJSCLOSE Even when the NRC inspectors did show a willingness to carry out a real inspection,.they would be handicapped by
. their practice of not coming in unannounced. To the best of my knowledge, there were no NRC inspections that weren't pre- ,
ceded by two or three days of preparation directed by Bechtel, during which problems would be repaired and som'etimes concealed. As a result, the inspectors never saw the plant as it really - operated on an every-day basis. My alarming experiences with the ' field welding and the u v=" i
- QC inspectors led me to speak to my boss, Mr. William Creel, numerous times in December and January. Bill generally had the same response: he said that all his men had passed the Bechtel tests and were fully qualified, and he was willing to take their word for it if they said construction was safe.
My real problem began when I tried to talk to the head of Project QC, Mr. Eugene Smith. He told me what Bill Creel t was saying, that everybody was qualified and so there couldn't be problems like the ones 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 I also there, and the two of them tol'd me tha't I hadn't been ( able to adjust to the way things were done at Midland, and so th'ey would have to let me g'o. They asked me if I had any
. written e comment's to make on the termination notice. I wrote down; "I do not agree with any of the i above, and ask for,a
. complete investigation of this and"all other main prebicms, by the San Francisco home office, and especially Mr. S. Bechtel.
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Murce. DO NOT DISCLOSE Never in my life have I ever seen so many critical welds accepted in nuclear work. If this many errors are allowed to -
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, exist,/the results could be catastrophic."
- After I wrote this down, Mr. Smith must have called Ann Arbor Headquarters, because he told me to go see Mr. Don
- Daniels on Monday. Mr. Daniels met me at the Holiday Inn in Midland, and I tried to explain to him the problems I had seen '
I in the field and with QC. I drew him the same diagrams I had l dran f'$f John Kunski, about the welding standards. All he *
- saio to this was that all the welders and inspectors were qualified'. The feeling I got was th,at even if I proved what i I was saying, Daniels wouldn't do anything about it. He couldn't believe what I was telling him -- he believed in the 4
i j papers that told him the Midland personnel were qualified. j . Before Daniels finally told me that I would have to be
, fired, he made another phone call. I believe it was to Eugene Smith and Bill Creel. Creel was the one who most wanted me i
\ \ to go.
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I was also told that in addition to my bad adjustment to Midland, I was being terminated because I had failed to l pass the Bechtel tests for Level I CiC engineer. Now as I l stated earlier, I have seventeen years of experience in QC F ~ and welding. At other'Bechtel installations, Palisades and - i e San ononfre, I held both Level I and Level II certificates. y - Midland was not that different from these other Bechtel opera- - tion's. I cannot believe that I hadn'( passed the Level I test at Midland. I was never,given a copy of the written part of n . - - - - ,.--,r ,.,m_ -r- g,.. , , , . , , _ , . . , , _ - _ _ ,,,, ,- - --- ,..n
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% %.., g the test. I can only believe that I was fired for insisting that there were serious problems at Midland. which my superiors .
refuses to acknowledge. ' l Because of the way I had been terminated by Bechtel, *
, and because I felt that my observations had not, received any
. attention from the internal hierarchy, I decided that I should speak to the NRC. On March 2, 1982, I arranged for a telephone interview with Roger Warnick, William Paton and Don Danielson of NRC.WEIn that interview I told them what I have detailed .
here in this affidavit. I told them I felt that Bechtel was not adequately investigating the serious " problems I had tried to bring to their attention, and that I felt I had been fired for trying to do this. After I spoke to the NRC, they sent out an inspectors to look into my allegations. His report indicates that he spent three days on-site. I' don't think that a full investi-gation could be conducted in such a short period of time, by , only one inspector. However, I do fee ,that the report con-firmed my charges, based on what happened when the inspector
- , met with the top men from Consumers, Mr. }hrguglio and Mr. Bird.
l - The inspector found them to be extremely hostile to any sug-l gestion that there were serious deficiencies with welding and
. with QC procedures and qualifications. The inspection report found that further investigation was warranted in this area.
) Although the report noted the need for further oversight, , 5 it seemed to feel that voluntary monitoring, of Bechtel by Consumers would clear up the problem. The problems are too
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..' DO NOT DISCLOSE serious and widespread to be left to be corrected by the .
people who created them. 'I believe that only an independent and comprehensive investigation, by the NRC or by outside -
, experts, can provide the assurance that Midland is properly built. '
I am sure that consumers and Bechtel will respond to my charges the say way they responded to th NRC in-3 spectio,n 3 They will deny the problems and promise voluntary , 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. Nevertheless, I stand by my statement. After nearly twenty years of work as an engineer, I know a defi-cient weld when I see one, and I know how many of these welds and other problems went undetected or ignored by the men responsible for inspectin'g them. Bechtel has shown by its attitude that it cannot be trusted to perform work of the high quality necessary in a nuclear plant. I feel that a full investigation into its management and construction practices will show that much work will have to be redone
, before Midland can ,go into oyjeration. The cost will be enormous, if it can be done at all. Despite the cost, I canno.t st'a nd by and watch the plant go on-line in its -
present state of s,afety. To do so would be to betray my responsibilities as a professi pal, as an engineer, and
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, as a citizen.
I have/read the above twelve- (12) page affidavit. To the best of my knowledge, it is true, accurate and complete.
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E. EARL KENT SUBSCRIBED AND SWORN TO before me this day of , 1982.
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' ' ,"C,','g' 3" - ALLEGATION DATA FORM e s r,ucae n m.auer., cc.c 1ssics s, jnstfuCt'One on f3verSP Sade '.'. RECEIVING OFFICE
- 1. Facilitylles) Involved: themet
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- 2. Functional Area (s) Involved:
(Check enpropriate bon (es) ) , _. operations _ onsite health and safety construction _ offsite health and safety
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_ other aspecityl 3.
Description:
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- 4. Source of Allegation:
(Check appropriate boml _ Contractor employee _ security guard _ licensee employee . news media _ NRC employee 7 private citizen organization Especity) M 4 #" _ other tspecityl d/If ##E140I MM DD YY
- 5. Date Allegation Received:
- 81. Name of Individual trirst two initi is and inst namel TbUMM Receiving Allegation:
- 7. Office:
7 l ACTION OFFICE
- 8. Action Office
Contact:
trirst two initi is and seit nemen I1 NISOA
- 9. FTS Telephone Number: g g 3 3 .
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- 10. Status:
(Check one) Open, if followup actions are pending or in progress j l Closed, if followup actions are completed l MM DD YY
- 11. Date Closed:
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- 12. Remarks: lg lg lyly lNlj; l7l g l0 l l cl, lf,j plf. lg l7.lyl, I/VI lBle I TIE I (Limit to 50 chorecters)
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- 13. Allegation Number:
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, March 8, 1983 ML l I'"~: 4 JL l~i.2TE-Murj MEMORANDUM FOR: James G. Keppler -
Yind. &k Regional Ariministrator, Region III FROM: Guy Cunningham, III Executive Legal Director
SUBJECT:
AFFIDAVITSSUPPLIEDTOREGIdN'IIIBYGAP As you know the Government Accountability Project furnished six affidavits to Region III in June 1982. I understand that initially it was believed that the allegations contained in those affidavits were to be investigated by the Office of Investigation. However, it has been brought to my attention that during a recent meeting in Region III it was determined that five of the affidavits would be referred to Region III. The sixth affidavit is being investigated by OIA.
. Consumers Power Company's attorneys involved in the Midland proceeding have indicated that they wish to engage in discovery with respect to those affidavits but have voluntarily refrained from conducting any l discovery at our request. Although they were initially told that 01
,. would investigate these allegations they were recently advised that l five affidavits will be referred to Region III for investigation. We are not certain now whether they will continue to voluntarily refrain from engaging in discovery. l All issues arising out of the December 6,1979 Order modifying construc-i tion permits, except those involving quality assurance have been fully submitted to the Board. As you know, a hearing on the quality assurance issues is scheduled to begin on Tuesday, April 26, 1983. Because these matters are of importance to the Board I wanted to bring them to your attention so that you can take whatever action you deem appropriate. L d
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Guy H. Cunning' nam, III Executive Legal Director I
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UNITE 3 STATES NUCLEAR REGULATORY COMMISSION [A g nEGION lli / , [ g s y 7ee noosEvELT ROAD Q, GLEN ELLYN, ILUNof 5 60137
***** SEP 17 G82 MEMORANDUM FOR: James G. Keppler, Regional Administrator THRU: R. F. Warnick, Acting Director, Office of Special Cases FROM: W. D. Shafer, Chief Midland Section SUEJECT: GAP COMMUNICATIONS (MS. BILLIE GARDE)
On September 17, 1982, I was requested to contact Ms. Billie Garde to answer some general questions about the Midland project. To the best of my recall, the following was discussed: ((1) She asked about the status of the six GAP affidavits. I explained that the 01 investigation was progressing and that some of the people had been contacted. I stated that when the investigations were completed that OI would turn the information over to our staff for technical review and inspection. (2) She asked about the status of the Zack investigation. I informed her that the investigation was progressing and that Midland had priority after LaSalle. I also told her that CPCo had a copy of the Zack affidavit. She said they did not get it from GAP. She stated that she was very concerned that we have not pursued the issue as to whether CPCo should have reported the Zack problem under 10 CFR 50.55(e). I explained that this issue would be addressed in our investigation and inspection effort. (3) We discussed several current issues at the site as follows: (a) Investigations
- 1. I stated that the investigation into the March 10, 1982 meeting where Messrs. Cook and Landsman alleged they had been lied to was nearing completion and
- that a final report would be forthcoming.
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- 2. I informed her that a request for an investigation into the potential violation of the board order had been forwarded to OI in HQ. I told her 1-did not know if an investigation had. commenced. ,
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f (b) Discussed the development of the Work Authorization Procedure I stated that RIII had determined that a formal communications 1 mechanism was needed to ensure that all work authorizations j would be in writing. 3 (c) Pipe Support and Restraint Problems
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I discussed Isa Yin's inspection report and CPCo's subsequent inspection find,ings in this area. I stated that we have informed CPCo that we want a 100% reinspection of all supports and restraints installed prior to 1981. (d) Misrouted Electrical Cables I stated that we had informed CPCo that a reinspection of all > SR cable was mandatory. (e) Midland Section I identified the Midland Section personnel and stated that the remedial soils work interface was the highest priority we had.
'J I also stated that we were waiting for CPCo's conmitments for improving their program and that you would not allow any major soils work to proceed until the Midladd Section was satisfied that the program was acceptable.
(4) After discussing item 3(e) above, Ms. Garde stated she was l disappointed that GAP input was not solicited during the formation I of the Midland Section. I stated that this was a management decision
'and could not, connent furthat'. However, I stated that she was welcome to contact me at ai.;::ime in order to ensure good communi-cations. Ms. Garde a W ed te would like to meet with the Midland i Section and would (St. t,th . ) me regarding!when. I encouraged her to do so. She gMeu wt open conmiunications were very byor- i j
tant in that when she made a press release she would be able to discuss what the NRC was doing.
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James G. Keppler gpp j 7 ggy (5) Hs. Garde discussed the SSER and wanted to know if R. Landsman'sI concern about the board violation would be addressed in it. said I doubted if it would. The SSER document would extensively identify the design elements for the remedial soil underpinning activities. We expected the SSER to be issued on October 4, 1982. (6) Ms. Garde stated that she was preparing to meet with D. S'aunders and was trying to obtain his affidavit. I wished her good luck and stated that we would be reviewing the relevant allegations we have obtained from Mr. Saunders. (7) I informed Ms. Garde that our section was developing a monthly status report which would indicate the status of RIII's effort at Midland. I told her the report would be docketed and if she wanted access to it she would have to request it through formal channels. She said she would do that. I believe that this summary was the extent of our conversation. It was not necessarily in the order I have described above, but I do believe I have I intend to send Ms. Garde a copy of this covered the most salient issues. summary. Should you have any questions regarding this communication, I will be happy to discuss them with you. i j:).
/J,D.Shafer, W. hief l
' Midland Section ec: A. B. Davis l .}}