ML20214Q101
| ML20214Q101 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/19/1983 |
| From: | Hayes B NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Palladino NRC COMMISSION (OCM) |
| Shared Package | |
| ML20214Q093 | List: |
| References | |
| FOIA-85-213 NUDOCS 8612040520 | |
| Download: ML20214Q101 (2) | |
Text
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September 19, 1983 MEMORANDUM FOR: Chairman Palladino FROM: Ben B. Hayes, Director Office of Investigations
SUBJECT:
NOTIFICATION OF OPENING OF 01 INVESTIGATIONS l The Comission has directed that you be infortred whenever 01 opens a new investigation. The attached documents briefly set forth information responsive to this requirement. If you desire more detail on any 01 investigation, please let me know.
Attachment:
Investigation Status Records, N,
- Case No. 3-83-007 3-83-008 Distrib~ution:
/CaseNo. 3-83-007 3-83-008 01 Commission 01 s/f Notification / Opening of 01 Investigation 01-c/f 01-r/f I Pending 5520/ NOTI 83/0 -
OI M 01 f 0 WJWard/jh RAFcfrtuna BBH, ayes 09/14/83 09g83 09/ 83 i
8612040520 861124 PDR FOIA GARDE 85-213 PDR z
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a UNITED STATES .-.
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SUMMARY
l TITLE:
MIDLAND Inspections-NRC staff acted File No.: Inq 85-33 i improperly per Brookhaven National Date Opened: 4/17/85 Laboratory's report Investigator: C. Kraus III NRC REGION: Inspection:
SITE: MIDLAND Investigation:
(criminal-integrity-ED>C g )
Review:
LICENSEE:
CONTRACTOR:
ALLEGATION: Brookhaven National Laboratory contracted by Region III to conduct inspections into certain allegations made by GAP witness involving Midland Nucacar :: Station.
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SIGNIFICANT DEVELOPMENTS DATES: .
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BROOKHAVEN NATIONAL LABORATORY Q(l[ ASSOCIATED UNIVERSITIES, INC.
e Uptort Long Iskmd.New York 11973
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January 10, 1985 l
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Mr. R. Warnick i s
DPRP, Region III 799 Roosevelt Road, Bldg. 4 Glen Ellyn, ILL 60137 s
Dear Bob:
Attached you will find BNL's r'eport dated January 1985, which addrysses the welding allegations at the Midland Nuclear Power Station.
The report has been revised to include format and clarification sugges- 1 tions made by you and your staff at the meeting in your~ offices on Decembe'r '
12, 1984.
- l If you require any additional information please call me.
. Very truly yours.
ha B. Taylor, Group Imader ,
1 ant Systems and Equipment Analysis Group l 1
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cc: R. Bari T. Burns C. Caajkowski !
.' R. Ball W. Kato .
E. Routs J. Weeks
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JAN 201985 6'1
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s Beport on Welding Allegations Prepared 'oy Brookhaven National laboratory to LICENSEE: Consumers Power FACILITY:. Midland Nuclear Power Station, Units 1 & 2 TECHNICAL SPECIALISYS: s e / /8 7[
/ Car jkowski' fDath) 4 M7L Thomas Burns i/a/,r (Date)
REVIEWED BY:
/ } I John B. Tiylor (Date)
An !!A9 Robert E. Hall
/'(Date)
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CONTENTS fagg I. 5uummary.......................................................... 1
-II. Allegation Categories....................................... .... 2 A. Description o'f Allegation Categories......................... 2 B. Allegation Sort by Category.................................. 3 III. A11egstion Analysis and p oponse................................. 4 Attachments
- 1. Allegation Sort By Originator i
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SUMMARY
This report is an analysis of sixty-one allegations made by an alleger against the welding program at the Midland Nuclear Power Station in EtC Region III. and two other Nuclear power Plants in Region III and V, respectively.
The allegations have been grouped into categories which are described in-Section II. The analysis and response to each allegation is contained in Sec-
- tion III. And finally, Attachment 1 lists all of the allegations in chrono-logical order and identifies the source documents from which the allegations were formulated. The alleger's name or inferences to the alleger's identity are not used anywhere in this report.
Four of the allegations ('ategory b A) are non technical and should be referred to the Office of Investigation for resolution.
Thirty of the allegations (Categories B & C) have been responded to on a technical basis. Two of the allegations (#13 pg. 13, #24 pg. 15) in this category require a response or action, but are not significant. Allegation
- 57 (pg. 23) identifies an are strike, which should be corrected.
' Seventeen of the allegations (Category E) were either 1) applicable to other sites, and therefore not addressed, or 2) were too general and undefined and therefore could not be addressed by BNL.
Finally, eleven of the allegations (Categories D & F) required large scale physical inspection programs, which could not be conducted by BNL in the time available.
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II. ALLEGATION CATEGORIES A. Description of Allegations Categories Category A - Office of Investigation - These allegations are outside of the scope of; work for BNL. Due to the nature of- the allega-tion,'no technical response can be provided and we recommend .
l the iten be referred to the NRC Office of Investigation (or l other appropriate agency) for resolution.
Category B - Code Requirements alleged to be inadequate - These allega-tions are an expression that those Codes. Standards and Practices utJ11 sed by industry are inconsistent, contain errors,:and/or conflict in some areas. These allegations do not specifically identify or address an unorthodox or devi-ant condition or practice at the Midland Plant site.
Category C - Technical response can be provided - These allegations were evaluated and a response provided which is based on a tech-nical analysis, document search, compliance verification, actual item examination or other observation.
Category D - Procedures / Specifications fail to comply with Code (ASME) or, are inadequate - The allegations assigned to this cate-gory are too generalized for a meaningful response to be developed. No item is specifies 11y identified such that a particular specification or procedure can be evaluated for l code conspliance. Bowever, a response could be developed
" based on the selection and review, for code compliance, of erection, fabrication, procurement and welding specifica-tions and procedures. The selection would be made such that the sample would include safety related components, items, structures and systems which perform a pressure retaining function of the reactor coolant pressure boundary or its support.
Category E - Allegation not site specific or too general-Dismissed - The following allegations are not specific to the Midland Plants and therefore could not be substantiated or verified during
" this recent site visit. Also, we are including those alle-gations in this category which do not warrant further action due to their vague and subjective nature.
Category F - Additional Work / Investigation required - These allegations,
~^ although considered by BNL to be broad subjective and gen-eral are such that a meaningful technical response could be provided when based on an analysis of results obtained from a specific inspection plan or effort. This' effort was not ande due to the obvious magnitude involved. It is entirely possible that a response could be provided which will be based on the data obtained during overinspection, corrective action and/or other quality verification plans and programs which have been (or will be) accomplished at the Midland plants.
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- 5. A11esstion Sort by Category Fu.rthe r .No Re-Category A11egations' Responses Work
! sponse Provided Required Required A 16, 17, 19, 20 1 3 32, 42, 48, 50 I C 3, 9, 10,3 11,43,14, 15, 24, 25, 26, 28, 29, X 30, 31, 33, 41, 44, 46, .
51, 53, 54, 55, 56, 57, 58, 59 D 2, 6, 7, 8, 34 I E 1, 5, 12, 18, 21, 22, 23, 35, 37, 38, 39, 40, I 45, 47, 49, 52, 61 F 4, 11, 27, 36, 43, 60 I i
j Note: Due to category definition, certain allegations will be found classi-fled in more than one category. Bowever, one response has been provi-ded in the' report text. )
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4 III. Allegation Analysis and Response The allegations are grouped by category in this section for ease of re-sponse. For reference the allegations are listed below in chronological order with corresponding page number.
A11ECATION NO. PACE NO. ALLEGATION NO. FACE NO.
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1 27 32 6 2 26 33 20 3 9 34 26 4 32 35 29 5 27 36 32 6 26 37 29 7 26 38 29 8 26 ,
39 29 9 9 40 30 10 10 41 20 11 10 & 32 42 7 12 27 43 33 13 13 44 20 14 14 45 30 15 14 46 21 16 5 47 30 17 5 48 8 18 27 49 30 19 5 50 8 20 5 51 21 21 28 52 31 22 28 53 21 23 28 54 21 24 15 55 21 25 16 56 22 26 17 57 23 27 32 58 23 28 18 59 24 29 18 60 33 30 19 61 31 1 31 20 i l
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_ CATEGORY A Office of Investigation the following allegations are outside of the scope of work for RNL. Due to the nature of the allegation, no technical response can be provided and we recommend the item be referred to the NRC Office of Investigation (or other appropriate agency) for resolution. -
. Allegation 16:
. WITHHELD FROM PUBLIC DISCLOSURE .
Allegation 17: l' l WITHHELD FROM PUBLIC DISCLOSURE.
Allegation 19:
WITHHELD FROM PUBLIC DISCLOSURE Allegation 20:
WITHHELD FROM PUBLIC DISCLOSURE .
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CATECORY B - - - .
Code Requirements Alleged to be Inadequate he following allegations are an expression that the Codes, Standards and Practices flict in some utilised by industry are inconsistent, contain errors and/or con-areas. hese allegations do not specifically identify or address site.
an unorthodox or deviant condition or practice at the Midland Plaat Discussion:
he codes not intended to bespecifically so. identified are in fact, not identical and, were The codes referenced differ in many areas as they were developed for completely different applications.
He reference to "AWS" is presumed to mean the American Welding Society (AWS) Structural Welding Code -
Steel (AWS DI.1). his documdat is an American National Standard approved by the American National Standards Institute. This code is prepared by the AWS Structural Welding Committee and is intended to cover welding requirements applicable to the construction of welded structures (buildings, bridges and tubular structures).
He reference to "ASME" is presumed to mean the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code. This document is also an American National Standard and is prepared by the ASME Boiler and Pressure Vessel Committee. The scope of this document is extensive and_it consists of eleven sections and atmerous subsections. He stated purpose of the Committee (through the issue of this code) is to establish rules of sa'fety governing era and pressure vessels.
the design, fabrication, and inspection during construction of boil-The stated purpose of each of these codes is clearly different and are not intended to be interchanged. Since there are areas where similar proces-
- ses and materials are used, it is understandable that differences might not be apparent to infrequent users. The evaluation and development of these codes has occurred industrial bodies. over a span of many years by two entirely different and separate Derefore, differences are not " inconsistent", "discrep-ant" or in " error" and, these differences are not cause for alare. Given the specific purpose of each code, they cannot (and were never intended) to be identical (even for similar processes).
Each of these codes has been in use for their respective applications for a combined total of over one hundred years (AWS-1911. ASME-1928) and through user, review, comment and revision have evolved into a formidable set of re-quirements which have kept pace with the advances in construction technology.
Allegation 32:
l "Pg.125, para. 3 - A11eger states a discrepancy exists between AWS and ASME stating:
position' weldingAMS limitsdiameter the size- of electrode does for vertical and overhead to 5/32" ASME not."
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j Response:
This difference does exist between the two referenced codes and should not be considered " discrepant" since AWS permite use of "prequalified" joint configurations in specific positions while ASME requires qualifica-tion of all procedures. Each code requires the gus11fication testing of welders in specific positions to qualify for "all" position welding.
Allegation 42:
"A11eger expresses concern of the lack of dew point control in argon gas."
Response
he results of inspection revealed that argon gas procured for welding at the Midland site was obtained as " welding grade" with no specific dew point speci'fied. The term " welding grade" in and of itself does not de-note a specific dew point or moisture content.
There is no requirement for the control of dew point (soisture content) of gas or gas mixtures used for shielding or backing in the performance of welding in accordance with the requirements of ASME Section 111 (Divi-sion 1 - Nuclear Power Plant Components). here is a requirement in AWS D1.1 (Para. 4.13 Shielding Gas) that gas or gas mixtures used for shield-ing in two specific welding processes (gas metal arc or flux cored arc welding) shall have a dew point of -40*F(-40*C) or lower.
Pressure retaining components (to include the reactor coolant pressuBp boundary) are fabricated and erected in accordance with the requirements of ASME 111 at the Midland site therefore, no nonconforming condition exists as regards the dew point of argon gas procured and used in these activities. Due to time constraints, we were unable to determine if welding had been performed on safety related components or structures under the rules of AWS D1.1 using the referenced processes.
We note that this " allegation" is not made to identify a nonconforming practice but, was an expression of " concern". The control of this vari-able in argon gas is a matter of engineering judgement since it is not a predominant source of weld defects. In the event construction activity should resume at the Midland site, we believe this ites can be resolved by the following activities:
_a. Determine if welding had been performed on safety related structures and/or componente under the rules of AWS D1.1 (any edition as far back as 1972) using the gas metal are or fluz cored are umiding processes.
- "-b. Determine if the gas or gas mixture used was procured with a dew point of -40*F or lower.
As of this date, the allegation was not substantiated.
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o g Allegation 482 "A11eger expressed concern over the code not addressing-weld ripple spacing.
Response
De weld acceptance criteria is adequately specified in both referenced codes and, both codes address the weld profile and surface appearance (AUS DI.1, Para. 3.6, 8.15, and ASME - NX4424) in substantial detail to include " weld ripple".
Allegation 50:
"Pg. 51, para. 2 - indicates alleger was upset that there were several instances of inconsistencies or errors between AWS and ASME."
Responses 9, he response is provided in the discussion portion of this allegation category.
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CATECORY C
, Technical Basponse Provided by BNL The following allegations were evaluated and a response provided which is based on a technical analysis, document search, compliance verification, act-sal ites examination or other observation. ,
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Allegation 3:
- "Bechtel has hired engineers and QC inspectors who were not adequately qualified or trained for the complicated work in a modern nuclear plant."
Response
A review of the Bechtel Pbwer Corporation qualification requirements for engineering personnel could not be accomplished since travel to their San Francisco headquarters would be required for file search and evaluation.
Allowable time did not permit BNL to accomplish this review. The re-sponse we have provided to allegations 26 and 46 is appropriate to the concern the alleger has expressed regarding the qualifications and train-1 ing of QC inspectors. This allegation has not been substantiated.
Allegation 9:
"(The subject is socket veld engagement length.) .. . stated that se long ,
as the pipe is not withdrawn from the fitting, it will be approved. This !
means that a gap of nearly any length will be tolerated between the end '
of the pipe and the bottom of the socket. ...the ASME code has, for this reason, established a much more rigorous specification."
I Responses <
l The following documents which govern the socket weld fit up requirements
- for those systems being fabricated and erected in accordance with ASME III - Division I were reviewed at the Midland site:
- 1. GWS-SN, Rev. 3 (7/16/76) and Amendment #9 (7/22/83) - General Welding Standard (Stainless and Nickel)
- 2. GWS-FM, Rev. 4 (7/16/76) and Amendment #10 (7/22/83) - General Weld-l ing Standard (Ferritic and Martensitic) l w .
- 3. GWS-NF, Rev. 2 (8/7/78) General Welding standard (Nonferrous)
These documents were found to contain specific and detailed requirements
- for the fit up of socket welds. The instructions contained specific gap
~ ^ requirements (1/16" approximately - later increased to 1/8" approximately in the above referenced amendments) with procedural requirements for ver-ificatioh. These gap requirements are in compliance with that found in ASME III - Division I. No items of noncomplisuce with the ASME code were
- identified in the Bechtel requirements for socket veld fit up. This l allegation is not substantiated and we recommend this iten be closed l without further action or investigation.
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10 Allegation 10:
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- squally as serious as the probles of downgraded specifications were the problems created by the incompetence and ignorance of QC. Even something basic like knowing how to use the fillet gauges correctly to measure the sise of welds was beyond the ability of some of the Bechtel inspectors '
and ... .
One QC engineer was also there to hear the explanation, and be admitted af ter I showed him the di% gram that he'd been approving bad welds him-self, mistakenly determining inadequate fillet welds as being adequate."
Responses i
Allegations 10 & 15 (page 14) - These allegations have been combined and an identical response provided since their basic contention is the same
'and, they are highly subjective. During the BNL visit to the site, the records for qualification and training were examined for thirteen person-nel (including the individus1 identified by name) and, no items of non-compliance were identified. All personnel had been trained, were tested e and qualified to perform their respective tasks. Also, subsequent to ;
qualification, periodic training sessions were held to appraise the in-
- spector(s) of ongoing changes in procedures and specifications.
We noted that the requirement existed for all welders (involved in weld- I i
ing under the requirements of ASME, ANSI B31.1 and AWS D1 1) to be quali-fled in accordance with requirements established in the respective code (usually ASME Section IX or AWS for structural welding). These require-ments are extensive and very thorough and could hardly be considered "less than formal". Inexperienced welders will not be able to success-
- fully accomplish these tests satisfactorily.
Implementation of the recommendations for allegations 4 and 60 (page 32,
- 33 - Category F) would supply further information as to the substance of this allegation. Presently, we find the allegation not substantiated and recommend this ites be closed without further action or investigation.
! Allegation 11:
"Because of this, I was very concerned to discover that many welds in the piping had been taproperly ground down, grinding down the pipe wall thickness along with it."
Response
Technical Specifications for Weld Fabrication and Installation of Piping for heelear Service for the Consumers Power Company, Midland Plants.
Units 1 and 2, Midland, Michigan 7220-N-204(Q) Rev.15, 6/16/81, page 11
-.- para. 5.2.6 Wall thickness Requirements states "Minteum wall thickness for fabricated assemblies as finally fabricated shall be at least:
- a. 47 l'/22 of the nominal wall thickness for pipe specified by nominal ,
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- b. The miniana us11 thickness for pipe specified by minimum wall.
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75% of the moniaal us11 thickness for 12-inch and under NCE and NCC l class pipe only.
Paragraph 3, codes and standards of this document states:
"All asterial, fabrication, installation, testing and essaination shall be in accordance with the American Society of Mechanical Engin-ears (ASME) Boiler and' Pressure Vessel Code,Section III, herinaf ter referred to as the Nuclear Power Plant Componente code,a,nd applie-able portions of the Pipe Fabrication Institute (PFI) standards as 4
referenced ANSI N45.2.1 and ANSI N45.2.2.
Documents incorporated by reference ~1nto these Specifications shall
' be the issue (including latest Addenda), in effect on the date of issue of the specifications. Adoption of any Code Cases, interpreta-tions and rulings, or subsequent issue of codes shall be subject to the approval of the Project Engineer. Code Case N-282 is approved for use.
t All nuclear piping is classified in one of three Nuclear Piping Clas-l
' sifications. The Nuclear Piping Classification is shown on the Pip-ing class Sheet. All piping systems shall be fabricated in accor-dance with Nuclear Power Plant Components Codes and these Specifica-tions for the Nuclear Piping Classification shown on the Piping Class Sheet." -
,_ Same title document Rev. 23, 6/8/84, page 13, para. 5.2.1 states:
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' " Care shall be taken in handling and installation of piping to pre-vent surface damage. Defects such as scratches, gouges, and pite shall be.. acceptable provided the depth does not violate minimum wall thickness requirements (see Section 5.2.6) and is not greater than 1/16 inch deep. Arc strikes are acceptable if there are no visible cracks and the crater depth is not greater that 1/16-inch and does not violate minimum wall thickness gequirements (see Section 5.2.6).
! Deposited weld metal need not be ground out in order to inspect the arc strike. Surface porosity is not a criterion for rejection." i l Same document, para. 5.2.6 Wall Thickness Requirements states:
" Mini == well thickness for fabricated assemblies as finally fabri-cated shall be at least:
) a. 87-1/22 of the nominal wall thickness for pipe specified by nomi-
- mal well, or
- b. The miniman wall thickness for pipe specified by mini == wall.
, c l e. 7J% of the nominal wall thickness for 12-inch and wader BCE and '
) NCC class pipe only. '
! d. As specified in the material specification for pipe made from piste.
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. l The as-installed well thickness of piping a Eembly may be less than that required by Items a through d above provided that it is greater than or equal to the einfaum required thickness, t., determined i
i using the procedure in Appendix C. Cases in which the as-installed !
well thickness is between that generally required by Items a through l d above and t,shall be documented via field change nottee. Field {
i calculations are to be done in accordance with Specification 7220-G-j -
35(Q)." '
Appendix C. Rev. 22 is attkehed. The code applicability of this specifi-cation is called out in para. 3 Codes and Standards.
"All materials, fabrication, installation, testing and examination shall be in accordance with the American Society of Mechanical Engin-eers (ASME) Boiler and Pressure Vessel Code, Section 111, hereinaf ter referred to as the helear Power Plant Components Codd, and applic-able portions of the ti referenced. ANSI N45.I.pe Fabrication 1 (1973) and ANSIInstitute N45.2.2 (PFI) (1972).standards as Bowever, certain equipment supplied by vendors as part of a package may be
! specified to other codes as appropriate. Examples include, but are not limited to, the following: rotameters, venturis and flow ele-ments from Babcock & Wilcox (ANSI B31.7), decay heat removal heat ex-changer and makeup pump lube oil coolers from Babcock & Wilcox (shell i
side to ASME VIII), steam generator main feedwater ring from Babcock i & Wilcox (ANSI 331.1), auxiliary feedwater pump turbine driver from Terry Turbine (none), and piping embedded in reactor building base-ment from Southwest Fabrication and Welding Company (531.7).
ASME Section III Code-effective dates and approved code cases shall be as stated in Specification 7220-N-324(Q).
All nuclear piping is classified in one of three Nuclear Piping Clas- !
sifications. The helear Piping Classification is shown on the Pip-ing Class Sheet. All piping systems shall be fabricated in accor-dance with the helear Power Plant Components Code and these Specifi-
, cations for the helear Piping Classification shown on the Piping Class Sheet.
Piping Class sheets for the Consumers Power Company Midland Plant Units I and 2 Midland Michigan, 7220-N-481(Q), Ref. 26, 6.6.84, Code applica-bility attested to by licensed P.E. Mancher, L. Mora Engineer No. 25292 (State of Michigan)
"I, the undersigned, certify that these Piping Class Sheets accurate-ly define the requirements prescribed in Subparagraphs NA-3252(b), !
NA-3252(f) of ASME III Division 2 Boiler and Pressure Vessel Code, j 1971 Edition with Addenda through Summer 1973."
j . .The above listed specifications take into account the evaluation of mini-m e well thickness requirements. Additionally, the taality Control In-
! structiongused for pipe weld inspections (PW-1.00, Rev. 3,10/12/81) i states la Section 21. " Verify that the pipe, pipe fitting, piping subas-i sembly, valve or in line component is free from damage." This document references Spec. M204 para. 5.2.1, 5 2.3, 5.2.6 and 6.3.2. A sign off 4
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section for this attribute is also found on Quality Control Inspection Record pqcl No. 7220/pW-1.00 Form 19517. De specifications take into account minimum us11 thickness and these requirements have been transla-
ted into inspection documents. Rese engineering and inspection proce-dures would be adequate identifying non-conforming conditions of over grinding if taplemented correctly. For a complete evaluation of this allegation, a detailed physical inspection is required therefore, this allegation was not substantiated due to time constraints. This allega-tion is also listed under Category F. .
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Allegation 13:
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"...Bechtel allowed low-hydrogen electrodes used in welding to be taken out of their hot ovens or hermetically sealed containers for up to eight hours before use. De American Welding Society (AWS) standard allows l
only four hours maximum in the open air."
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Response
! his allegation is identical to 31 and has a concern regarding the expo-sure time of low hydrogen electrode to the environment af ter removal from their hermetically sealed containers or drying / storage ovens. It is our understanding that the portable rod heaters (or, caddies) do not consti-tute a drying / storage oven since their temperature requirements do not comply with that specified in AWS D1.1. As a result of the review of the j
Bechtel Welding Standard (WFMC-1, Rev. 6. Amend. 8) for the control of weld filler metal at the Midland site, these allegations have been sub-stantiated. He Bechtel weld filler metal control policy was not in coa-pliance with the requirements of AWS D1 1 at the time the allegation was mode. He program as amended on November 29, 1983, was still not in com-pliance. Specifically (as amended), the specification permits electrodes ,
having low hydrogen coverings to be exposed to the atmosphere for a per-iod which exce e ds th a t specified in AWS DI.1 (10 hrs. vs. 4 hrs.). This requirement 'is found in AWS D1.1 (para. 4.5.2, 4.5.2.1 and Table 4.5.2).
Relief is granted by AWS DI.1 from this requirement (time limit is in-j creased to 10 hre. maximum) if the user established, through testing, what the maximum allowable exposure time can be without degradation of weld quality as affected by changes in the moisture content of the elec-
! trode coating.
4 Bechtel personnel at the Midland site believe their program has NRC approval. Several documents were examined which indicate an alternative program was submitted to the NRC and accepted by the Division of Reactor i Construction Inspection, IE (dtd. December 8,1977. G.W. Beinmuth to R.
', ~ E. Engalken) but, was specific to the pelo Verde site. Inference is made in this meno that the alternative program was acceptable for "any nuclear .
plant". An internal Bechtel memorandum of April 28, 1978, 3. D. Backney to p. A. Martines (of the Midland project) states that the alternative
" program *has been submitted to and accepted by the NRC as a Topical Report thereby permitting generic use of the alternative electrode con-trol prac.tices and procedures described."
' Since documentation specifically approving the pr$ gram for use at Midland could not be located, BNL recommends that this item not be closed until l
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Allegation 14:
"One QC engineer who has been at Midland for many years told as that in his opinion over 90 percent of the piping in the entire plant has had to be cut out and replaced at one point or other. In my mind, this raises serious questions of safet'y ... ." ,
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Response
Two documents were reviewed in the investigation of this allegation -
Bechtel Power Corporation project Quality Assurance Activity Report No.
80-5 dated 6/2/80, which outlined (page 5. Chart 1A) a twelve week trend-ing for all Final Inspection Radiographed Bejects (pipe welds). The
. graph plotted the rejectd'over the 12 week period of 2/2/80 - 5/9/80.
The reject rate was 2.87% (percent of welds rejected /no. of welds radio-graphed). De second document reviewed was a Bechtel Site Construction -
Midland Nuclear Project - X-ray Welds % Form (W-1). This form covered the period of January 1982 - September 1983 and showed a reject rate varying between approximately 28% to approximately 9% during the per-tod. his form also covered final inspected welds. It should be noted that during the course of construction, there may have been in-process i repairs which would not be recotded on these forms. De performance of inprocess repairs is not considered unusual and is a common and necessary practice. Since the reject rates recorded on these documents is signifi-
! cantly lower than 90%, this allegation is not substantiated.
Allegation 15:
"They have happended because Bechtel has hired inexperienced engineers, welders, and~ inspectors.
, There vert few formal requirements to become a welder, or even an intpector.
i l If this was supposed to be corrected through a thorough training program, it didn't happen.
l ,
l Be training periods were only a couple of weeks, and based on my experi-i ence in working with the engineers, welders, and the inspectors, I can
_ etate that they were not properly trained."
{
- nas ,on..:
Allegations 10 (page 10) & 15 - These allegations have been combined and
_ _ an idestical response provided since their basic contention is the same >
and they are highly subjective.
i , During t e SNL visit to the site, the records for qualification and training were esamined for thirteen personnel (including the individual identified by name) and, no items of noncompliance were identified. All 1 :
15 personnel had been trained, were tested and qualified to perform their I
respective tasks. Also, subsequent to qualification, periodic training sessions were held to appraise the inspector (s) of ongoing changes in procedures and specifications.
i t
We noted that the requirement existed for all welders (involved in weld-ing under the requirements of ASME, ANSI B31.1 and AWS D1.1) to be quali- l "fied in accordance with requirements established in the respective code (usually ASME Section II or AWS for structural welding). Rese require-ments are extensive and we'ry thorough and could hardly be considered "less than formal". Inexperienced welders will not be able to success- ;
fully accomplish these tests satisfactorily. 1
) Implementation of the recommendations for allegations 4 and 60 (page 29, 30 - Category F) would supply further information as to the substance of {
this allegation. Presently, we find the allegation not substantiated and '
recommendthisitenbecpsedwithoutfurtheractionorinvestigation.
Allegation 24:
l "Bechtel Specification WQ-2, sheet 20 note 1, requires "shall not exceed l 1/3 inch ..." regarding maximum groove weld reinforcement at Midland, I i
Michigan's brin Nuclear Plant. This requirement should read "shall not exceed 1/8 inch ..." as required by the ASME Section III code on groove a
weld reinforcement."
Response: l
)
i I
j Allegations 24 & 33 are identical and were made in regards to both the l Midland plants and the San onofre plant. The same document (WO-2, Bech- :
l tel power Corporation, Welding Standard, Performance Specification) would l
! apply at both sites since this is the Bechtel practice. An examination of this document (Rev. 2 April 4, 1980) reveal that the referenced " note 1" does read " Butt and corner joint reinforcement shall not exceed 1/3" and shall have a gradual transition to the plane of the base metal surface." .
! Se referenced document is one which containq the requirement for the qualification of welders to make acceptable welds, in accordance with AWS
! D1.1 and AUS D12.1. The specific requirement on " sheet 20" of WQ-2 is titled " Visual Inspectica of Weld Profiles" and is identified as Drawing WQ-2-8, Bev. O and " note 1" is made in reference to the sketch of a butt j
!' weld which shows a case of excessive convexity (reinforcement). The ;
sketch is specifically identified as an unacceptable butt veld profile.
t ~ This document does not apply to or govern the field welding of any compo-aanto, structures, piping or attachments thereto whether safety related or not. Its sole function is to establish the procedure for conducti; j the welder qualification test and, sheet 20 illustrates the required t Ld
,, _ profile for qualification tests performed using plate test asterial.
1 H is dimension (1/3" appears to be a typographical error since the code (AWS DI.)) requirement is 1/8" maximum.
I 1
There is no deleterious effect as a result of this typographical error.
he work accomplished by weldera at the Midland site is subject to in-spection and acceptance by an independent quality organisation which l
. -T 16 derives its acceptance criteria from specifications which govern the field fabrication and erection of ASME components. These specifications are independent of the referenced WQ-2.
Therefore, although these allegations have been substantiated, we recom-mend that this iten be corrected by Bechtel Power Corporation and then closed without further action.
Allegation 25:
"I believe that the caliber of individuals employed by Feabody Testing to perform nondestructive examination (NDE) on welds in nuclear service applications was not acceptable. This belief is based on the observation of many spelling errors, ... ." l Response l Allegations 25 and 55' (page 21) - Since Peabody was an NDE contractor at the Midland site under the name of G.E.O. Construction Testing as well as Peabody, we examined (by random selection) the following G.E.0. Construc-tion Testing, Certified Report of Nondestructive Examination (Form 112-6843). The following reports covered dye penetrant examinationet l Examiner Date Weld No.
t l
s .
Donna A. Dorsey 3/11/82 PW100 FSEM-ICC F45-3-24 3/11/82 FW100 FSEM-ICCD-45-3-31 3/5/82 PW100 FSEM-ICCD-45-3-32 3/5/82 W100 FSEM-ICC5-45-3-33 3/5/82 PW100 FSEM-ICCS-45-3-34 Steven Bonnell 3/2/82 FW100 FSEM-ICCD-45-3-35 4
3/4/82 PW100 FSEM-ICC5-45-3-36
".- 3/4/82 FW100 FSEM-ICC5-45-3-37 Donna A. Dorsey 3/4/82 PW100 FSEM-ICC b45-3-38 i " " "
3/4/82 FW100 FSIM-ICCD-45-3-39 3/4/82 PW100 FSEM-ICCD-45-3-40 3/4/82 FW100 FSEM-ICCD-45-3-41 3/4/82 FW100 FSEM-ICCb45-3-42 3/4/82 FW100 FSEM-ICC5-45-3-43 3/4/82 FW100 FSIM-ICC5-45-3-44 E. D.' Lyles 5/3/82 FW100 FSEM-ICCB-54-2-R1 Craig C. Tapani 3/23/82 FW100 FSIM-ICCD-54-2-53 Brain Banni 4/6/82 FW100 FSIM-ICC5-54-2-22C1 David L Waun 9/29/82 FW100 FSIM-ICCF54-2-22C3 No spelling errors were noted on any of the' reports reviewed and, each report had been checked and signed by a Bechtel Invel II NDE avaminer.
The following Feabody Testing Radiography Reports (Form 102E) were also
- reviewedt
/
1 .
)
. - . . .- . _ .. - ~ _ . . .- . . --
17 Examiner Dete' Weld No.
Gary Smoot 8/7/78 2 BCE M614 SR3 W 10 R1 W. M. Pardee - Bechtel 8/8/78 " " " " " " "
Gary smoot 7/20/78 2 BCS M614 553 FW 10 W. M. Pardee - Bechtel 7/21/78 * " " " " "
C. W. Stoughton 5/29/79 2 BCS M614 553 FW 53 E. R. Stankiewies - Bechtel 5/29/79 f- * * * "
R. Cook : 6/28/79 2 BCS M614 SE3 FW 8 4
E. R. Stankiewies - Bechtel 6/28/79 " " " " ""
Each of the radiographs listed above were reviewed by Eechtel NDE per-sonnel as indicated with results recorded on a Radiographic Eaview Form (BBS10844). i No spelling error / (or other t
errors) were noted on these reports.
h qualification records of all the Peabody (GEO) personnel listed above were reviewed and, it was determined that each examiner was a inval II qualified by examination to ASNT-TC-1A. The qualifications were certified by a 14 vel III examiner (also to ASNT-TC-1A) in the appropriate discipline as follows: _
Examiner Discipline Level - Date Bonnell . Penetrant 2 - 7/24/81 i
Lyles Penetrant 2 - 4/2/81 Dorsey Fenetrant 2 - 9/8/81 Tapani Fenetrant 2 - 1/27/82 Banni Penetrant 2 - 11/12/81 Wann Penetrant 2 - 7/14/81 smoot .
Radiography 2 - 7/12/77
, Cook Radiography 2 - 2/16/79 Staughton Radiography 2 - 3/20/79 l.
l No items of noncompliance were identified during the revit't. h refore, these allegations have not been substantiated and we recommend the items ,
l be elooed without further action.
Allegation 26:
~
"I believe that established industry standards regarding the qualifica-
' tion of NDE personnel are not sufficient to assure an adequate level of -
personnel capability and knowledge in this very important area of in- '
spection."
~
l Esaposse
- Allegations 26 and 46 (page 21) - N Nondestructive Esamination (NDE) qualiffiation program established by Bechtel Corporation for the Midland project requires that personnel be qualified in accordance with ASNT-TC-1A. h re are no age requirements established in ASNT-TC-la although there are very specific education, employment, vision, general and i
specific verbal and written test requirements. .
d e
- - , , -,e we,
18 These requirements are extensive and, are recognised throughout industry as an acceptable qualification standard for NDE personnel. The qualifi-cation records for eleven NDE inspectors at the Midland site were exam-ined for compliance with the requirements of ASNT-TC-1A. These records of inspector qualifications were selected at random from the years 1979 thru 1982 and, no items of noncompliance were found. All inspectors had been qualified in their respective discipline.
Additionally, the training records for two QC Inspectors were examined.
It was found that the inspectors had received training in those specifi-cations, procedures (as they were revised) and test methods within their area of responsibility. Therefore, we conclude that 6nis allegation is not substantiated and recommend this ites be closed without further action or investigation.
Allegation 28 l
- It is alleged that Bechtel designers used only fillet welds on web-to-l
' web connections of beams and pipe supports and tray hangers and did not weld all around to restrain forces in all directions. A11eger also questions seismic loading calculations and feels that there is no actual test on welds under seismic conditions. A11eger states also that AWS D1.1 demands and returns on fillet welds and these were lacking in e6ay places."
Responses Allegations 28, 44 (page 20), and 51 (page 21) - These three allegations are identical and are considered to apply to the Midland plants since the alleger does not identify specific locations. The allegations have their origin with the Structural Welding Code, AWS D1.1 (para. 8.8) and, our review reveals that this Code does not require or demand "end re-turns" (also known as boxing) of side or end fillet welds. The terei-l nology used in AWS D1.1 is "wherever practicable" and therefore an ele-sent of engineering judgement is toplied rather than the establishment l
' of a mandatory requirement. Should the Engineer decide to use "and re-turns" or " boxing of side or end fillet welds, the AWS D1.1 code re-quires that this be indicated on the drawings. Due to the lack of available time while at the site, BNL was unable to verify the use of "and returns" and, whether they were specified on the drawings when they were, in fact, used.
Allegation 29:
'. "It ves. stated that AgME code requires adequate root penetration of fil-let welds and states that vendor-supplied equipment did not always con-fore to this requirement. Specifies Zack Co."
leYponses .
As a result of our investigation, it was determined that the vendor identified as "Eaci Co." did not, and was not, under contract to supply.
any equipment, components, parts, materials or appurtenances of any type in which the ASME Code was the Code of design, fabrication or installa-tion at the Midland site. An examination of the "Zack Co." purchase .
e
19 ccatrcet revaoled that this vendors responsibilities were limited to the '
fabrication and installation of Beating, Ventilation and Air Condition-ing (EVAC) equipment. These fabrication and installation activities are governed by codes and standards unrelated to the ASE Boiler and Pres-sure Vessel Code.
This allegation is not substantiated and we recommend closure of this ites without further investigation.
Allegation 30s -
"It was stated that A-7 rim steel may have been used in critical appli-cations on SONGS."
i Responset Although this ites was not specific to the Midland Plants, BNL personnel
. verified that the referenced material (ASTM A-7) had not been procured for use at Midland in safety related applications or in safety related structures.
A comprehensive review was performed on the following specifications:
t A. 7220-C-233(Q) Rev. 24 and prior revisions - Technical Specification for Purchase of Miscellaneous Metal.
B. 7220-C-36 Eav. 0 (initial issue and subsequent revisions) - Techni-cal Specification for Furnishing, Detailing, Fabrication, Delivery and Erection of Structural Steel. '
These specifications were found to specifically identify by standard that ASTM A-36 was to be procured for the structural applications. We note that ASTM Standard A-7 was discontinued in 1957, and replaced by Standard A-283 and A-306 with A-36 being added in 1973.
Additionally, the following Bechtel field purchase orders were selected at randon (from the very early years of the project) to verify that structural steel for *0" (quality) had been purchased to meet the re-quirements of Standard A-36.
Purchase Order Material Sise Quantity
~
- 728141 (6442) 3"z2*z3/8"z40' 200 ft. - channel F17797 (2575) 2'z2'z3/16" 10 pes. plate F33818 (8365) 2"z2"z1/8" 100 ft. - channel i
M106AC (4158) - 1977 ' 4"z4"z1/2" 100 ft. - channel
' F19512 (3090) - 1977 7'a12'z3/8" 4 pes. - plate
' F3134 (8467) 6'z6'z! 3/8" 4 pes. plate M106AC (4185) - 1977 2'z20'z1/4" 5 pes. plate
- 1 All items were identified as ASTM A-36.
I e i .
I .
-,----n e,----.m.e ..,_w-n,ar.w,,
6
. 20 Allegation 31:
"A11eger questions the code adequacy of Bechtel's procedures regarding E7018 electrode out of oven time." '
tasponse:
" See, response to Allegation 13 on pg.13.
Allegation 33:
"It is stated that reinforcements of groove welds on Bechtel from WQ2, Sheet 20, differed from ASME code requirements."
Response
See response to Allegation 24 on pg.15.
Allegation 41:
"A11eger states that runoff plates were not used on structural members."
l Response:
1 4 A resolution to this allegation was not pursued during our visit to the i Midland site due to time constraints. However, based on our past exper-ience at numerous other Nuclear construction sites, there is a very high probability that this statement is true. We also offer the following -
- 1. The code of origin is AWS DI.1 (para. 3.12) and the use of run-of f plates is not a requirement of this code. Additionally, their use is not a requirement of any other code, standard or guide that we 4
are aware of.
1 2. The use of run-off plates is considered good welding practice when i
' using welding processes which ut111:e extremely high rates of heat input (submerged are, elect aslaIg, etc.) and where weld termination does not lead itself to the level of control which can be exercised ,
with annual processes. The welding processes utilised at Midland '
i' for joining structural members (shielded metal are, flux-cored and gas tungsten are) lead themselves to a very high level of control by i the welder. This level of control is such that run off plates are' ;
rarely necessary with no compromise of weld quality at the termine-1
. tion of the joint.
- We believe further action regarding this allegation to be unneces- !
j sary and, no noncompliance exists. i
) IIITkation 44:
l "A11egal states that many examples of non-existent and returns on welds i
are at SONGS, palisades, and Midland." l t
i
- : l l
1
-_-__-_- - - - . . . - . - - - -_ - .. _1
. 21
Response
see respone to Allegation 28 on pg. 18.
Allegation 46:
"A11eger expresses the concern that many young people were irspecting welds with no real knowledge of welding."
Response: e <
See response to Allegation 26 on pg. 17.
Allegation 51:
"A11eger contends that end returns are not specified on Bechtel Power Corporation detail draw $ngs in violation of AWS DI.1, para. 8.8.6, 8.8.6.1 and 8.8.6.2."
Response
See response to Allegation 28 on pg. 18.
Allegation 53:
"The alleger was concerned that since there were many spelling errors on
. nondestructive test reports by Peabody Testing that the examinations I performed by these people may be questionable."
Response
See Allegation 25 on pg.16.
Allegation 54:
" Main steam pipe just outside of containment before first relief valve had weld with unacceptable concavity."
Response .
q Specific welds were not identified by the alleger therefore, two welds in main steam piping outside of primary containment and before the first relief valve were selected for examination with attention to the weld profile (specifically, concavity). The welds examined weres
- 1. 632.- SE2 W1 .
- 2. 632 - 853 W1 The velds examined were found to be acceptable to the criteria of ASME III - Division I, para. NK-4426.2.
Allegation 5[
"Some pipe hangers of questionable construction " (no welding on hanger flanges)." '
e i
! l
22
Response
1, A review of a meno from Ferry to Sanders, dated Ane 20, 1984 Subject -
Midland Energy Center Project Technical Trending of ERP Activities was ande for this allegation. The document reviewed was a Technical Evalus-i tion of the hanger reinspection program nonconformance reports for the Midland site which stated in part that "... At the time.that the NCRs utilised by this report were generated,'the " rate of rejection" of in-spected pipe supports was,902, i.e., 9 out of 10 pipe supports were found to have one or more rejectable attributes, thus the 445 NCRa uti-lised for this report represant approximately 500 (445/.9) inspected supports ..." [page 3 Section 3.1, third paragraph]. Additionally, Section 3.2 Significance of Data, subparagraph 1. Weld Deviations states "The family of weld deviations comprises 472 of all significant devia-tions. In addition, weld deviations represent 412 of al1 identified de- 6 vistions. This is the largest contribution of any deviation family."
[page 3] Even though more than half of these deviations could be accepted '"as is" by an engineering evaluation, an approximately 50% ini-tial reject is sufficient cause for the allegation to be considered sub-stantiated. Bowever the reinspection programs established by the lican-see should have identified the hanger deficiencies had the plant not been shut down.
4 Allegation 56:
" Deficient socket welds could be found in "Q" piping in lowest level of the auxiliary building."
Responses No specific identification was provided for these socket welds. Due to
' the vagueness of this allegation, a randon selection of socket melds in "Q" piping was made in the lowest level of the auxiliary building. The following welds were visually inspected for required size and profile l
- 1. 1ECB-4-1 FW9
- 2. IECD-4-1 FW10
- 3. 10CD-36-1 FW23 ,
- 4. 10CD-36-1 FW24 ,
- 5. 10C5-36-1 FW25
- 6. 10CD-36-1 FW41 -
- 7. 10CD-36-1 FU60
- 8. 10C5-36-1 FW42 i
, 9. 10CD-36-1 FW45
- 10. 10C5-36-1 FU43
- 11. 10C5436-1 FW47 *
! 12. 15CB-270-1 7943
' ~^
- 13. 15CD-270-1 FW45
- 14. FSEN-610-4-20 FW2
- 15. FSEM-610-4-16 FW1 *
- 16. 10C4*36-2 FWS
- 17. 10C5-36-2 FW6
- 18. 10CB-36-2 FW7 ' '
- k I
a l . .
4
- . . - . - , . - . - , .,r_,_-n. , - - . _ , , , _ . - _ . _ , . , _ _ _ ,
9 23
- 19. 1GCD-36-2 FW9
- 20. 1GC3-36-2 FW10
- 21. IEC5-16-612-3-2 FW35 (Top off valve TN 3-3)
No nonconforming condftions were identified.
Allegation 57:
" Welds #89, 90 W1 on drawing FSK-M-18BC-58-2 (service 2E 0) lines being the worst."
Response
Mree welds were specifically identified in tfits allegation by drawing and field weld number (FW89, 90 and 91 on Drawing FSK-M-135C-58-2).
Rese three welds were located and visually inspected for required size and profile. He weld size and profile were found to be acceptable although a rejectable are strike crater was identified on FW91. He allegation that these three welds constituted a " worst" case was not substantiated by the inspection results.
Allegation 58:
"Bechtel spec. for argon purge allowing 104 efs Ar (he feels too much flow rate latitude), does not require checking dew point on Ar used for purges."
Reeponse h reference in this allegation to "$4 efs" for purge gas is believed to be in error. The volume of purge gas specified on the most commonly used Bechtel weld procedure specification (WFS) for the' joining of stainless steels (no purge is required for carbon steels) is 1 to 40
- cfa. His volume is specified on WPS F8-AT-Ag for veld root closure and the second pass (which is optional).
The flow rate permitted provides a generode range for a number of valid technical reasons. Among them are .
- 1. N ee procedures are useable on all pipe diameters. His range is j estensive and would cover every diameter from 2" to 20'.
J
- 2. N use of purge dans would greatly affect the volume of purge gas.
1 ~
- 3. h inability (in certain welds) to use a purge dan or, the ability i to "das" only one end of the system or pipe.
i
- 4. Amount of turbulence in the lamediate area.
Also, the rate of purge flow (and its use) is not an essential variable of ASMg AI. h use of a purge gas and its control within a narrow range is not essential to the completion of the wald with the achieve- ,
' ment of a high degree of quality. More importantly, the percent of oxy-gen in the emiting gas is the true seasure of whether one has provided ;
4 I
- % e
a the necessary degree of protection for root closure. When the purge is initially introduced, the flow rates would be exceedingly high for large diameter pipe but, would be reduced as the argon displaced the air sad, oxygen content was reduced to low levels (usually 1 1/2 to 22). At this t1w, the flow rate would be reduced to a level which would asintain this low oxygen content. The bechtel corporation WPS and the General Purge Specification (GPS-1, Rev. 4) provides for the testing of exit gas to assure the purge'is effective. ,
a h range specified is no,t. abnormal for the welding variables encounter-ed in the use of this procedure. No item of non-compliance has been identified and further investigation of this allegation not recommended.
Allegation 59:
" Undersized welds had been accepted by Morris acJ his qualification revoked."
Re s ponse:
Items reviewed in the investigation of this allegation include:
- 1. Bechtel thermal Power Organisation Construction Quality Control Training Record - for Wrris, A. C. (4/13/81).
- 2. Sechtel Thermal Power Organisation Construction Quality Control Edu-cation and Experience Resume - for Morris, A. C., 7/21/81.
- 3. Bechtel Thermal Power Organisation Conetruction Quality Control Physical Examination Record - for Morris, A. C..,5/19/81.
- 4. Bechtel Thermal Power Organisation Construction haality Control Cer-tificates of Qualification - for Morris, A. C., (3),1/29/83.
- 5. Bechtel Nonconformance Emport No. 4084, 3/18/82.
- 6. Bechtel power Corporation meno to QC File from Fredianelli, D. L.
(LWOCE) and Creel W. J. (LFMQCE), 3/12/$2.
The referenced meno (6) stated fu part "Following the rescission of A.
l
' Morris' certification on 1/19/32, an ongoing overinspection of his work prior to decertification has identified many undersised weld...". h final results of this overinspection were documented in Nonconformance Report No. 4084 (5). h reference meno (6) also documented an inspec-tion of 5 socket welds per each Construction Osality Control Engineer C0CE to 3etermine if a generic probles existed at the,1ine of the inci-dent. h meno stated that so generie probles existed at Midland. This inspection does lend support to the conclusion that CC inspections did
__ have an adequate knowledge of fillet veld sising and weld gage ase. See allegation 60, pg. 33. He conclude that this allegation is substanti-sted but is of no technical significance. Information provided within the referenced documents reveals that the condition was identified by the constructor (not the alleger) and, once discovered, the constructor '
undertook appropriate actions to assess the estent of the condition and Y
e
~ -
- 25 .
establish corrective seasures. This action provitto confidence in the effectiveness of the gus11ty program at the Midland site. Es recommend this ites be closed without further action.
I 1
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a e
4 0
9 8
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& N e'
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- ~ ~ - - - - - . . - . - _ _ _ _
t
, 26 v.
CATECORY D Procedures / Specifications Fail to Comply With Code (ASME) or, are Inadequate ,
The allegations assigned to this category are too generalised for a mean- !
ingful gation.
response to be developed as a result of the time available for investi-No ites was defined or specifically identified such that a source document or activity could be directly examined for code or regulatory compli-ance. Eowever, a response to a generalised and vague allegation can be !
developed by the review of a selection of safety related components, items, i structures and systems from their specification stage through erection or in- l stallation. This would necessarily be a broad scale effort.
Allegation 2:
I "Bechtst Corporation had systematically dowagraded standards for safety-related equipment to the point where I believe that auch of the con- ,
struction will not withstand the stresses it should be built to take.
i Allegation 6
{
l "I was astonished to see that in numerous places Bechtel has estab-lished standards which fell below those of the ASME Code.*
Allegation 7: 1 I
"Despite this, Bechtel in some cases made the decision, based on their own engineers' opinions or short-ters testing in San Francisco, to modi-fy these standarda."
Allegation 8:
"But in the area of welding, where I was qualified to judge, the new ;
apecifications were inadequate to the needs of a nuclear facility."
Allegation 34s "F3.133, para.1 - It is stated that Bechtel welding procedures leave a lot to be desired." -
1 e mW I
S s *
--_ _ _ _ _ _ _ _ _ _ _ _ - _ - - - , - - - - - - , _ , - - - - - . . , . - - . , , e7 -
y-, ,- ,.---__y-. , , , , - - -r-* "^r --
----v='-'"--v' * - - ' * - -* " - * - * - -
c .
j 27 CATECORY E Allegation Not Site Specific or Too General - Dismissed Allegations 12, 35, 37, 38, 39, 45, 47, 49 and 52 were not specific to the Midland Plants and therefore, were not addressed during the site visit.
Also, included in this category are those allegations which do not warrant further action due to their vague and subjective nature.
Allegation It "It is my professional opinion that the Midland plant is the worst nuclear facility I have ever seen."
Responset A response cannot be provided to this allegation because of its broad and subjective nature. We ffad this allegation is not substantiated as made and recommend no further action or investigation.
Allegation 5:
"I will also give examples of the u'nhealthy degree of reliance that cer-tain NRC inspectors have placed in the Bechtel personnel whom they are supposed to monitor. ... the inspection reports that were supposed to represent a completely separate check on Bechtel performance often wound up basing their approval on Bechtel's evaluations of its own work."
tesponses A complete review of all affidavits, statements and records of inter-views with the alleger was made by BNL and no specific *esamples" could be identified. Therefore, this allegation is not substantiated by fac-tual data arad investigation by BNL was not carried further.
Allegation 12:
y/ITHHEL.D FROM PUBLIC DISCLOSURE l
Eseponset.
l This allegation was not made specifically at the Midland Plants but, was applicabla to the Palisades facility. ,
Allegation 182 l
"Never in my life have I ever seen so many critical welds accepted in l nuclear , work and then found to be unacceptable."
0 0
(
./
28 '
Response
A response to this allegation cannot be provided due to its broad and general nature.
Allegation 21 "Af ter nearly twenty years of work as an engineer and welding authority.
I know a deficient veld when I see one, and I know many r,f these welds and other problems went o'ndetected (or ignored) by the men responsible for inspecting them."
Response
This allegation could not be addressed due to its lack of specificity.
An allegation of such a broad and general nature could only be addressed in a large scale re-inspqction of the welding activity. We believe that were the *0uality Verification" portion of the " Construction Completion Program" (CCP) to be. accomplished, the results would form the basis to refute or substantiate this allegation. We recommend this item be closed without further action.
Allegation 22:
i "Bechtel has shown by its attitude that it cannot be trusted to perform work of the high quality necessary in a nuclear plant."
Response
A response to this allegation cannot be provided due to its broad and un- i defined nature. We recommend this iten be :losed without further action or investigation. l Allegation g
\
"The ASME Code requires adequate root penetration of fillet welds. I j recall that some of the vendor-supplied welded hardware appeared to not have adeguate root penetration. I recommended that the NRC examine the l beginning and and of fillet welds to assure root penetration at these 0 areas and verify that all craters are filled, and conduct destructive testing of selected supports supplied by this vendor to determine if '
other fillet velds and groove welds have adequate root penetration or other code violations.
~
Basponses ,
BNL technical specialists were unable to conduct an indepth investiga-tion of this allegation due to the lack of identification of the equip-
_. _ ment or vendor involved. From the wording of the allegation, it appears that it may be directed at a support of some type (pipe, electrical, cable tray or EVAC ducting and/or equipment). Also, we were waable to deduce '(from the statement) whether this allegation applied specifically.
to Midland or, the San Onofre plant. We believe an adequate investiga-tion could be conducted if further (more specific) information were O
4
, _ , , . - - . , ,, ,, -n .- . . , - . - - - - , , , , - , . . , . . .
?
e' 29 provided regarding the equipment or vendor. Otherwise, attempts to pro-vide a meaningful response would be futile. We recommend this iten be closed unless and until further information becomes available. '
Allegation 35:
WITHHELD FROM PUBLIC DISCLOSURE Response: '
This allegation is not site specific to Midland therefore, no response is provided.
I Also, the allegation is such that it does not land itself- l to generic consideration based on the particular practices of the Architect / Engineer.
Allegation 37: /
WITHHELD
Response
FROM PUBLIC DISCLOSURE This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not land itself-to generic consideration based on the particular practices of thq Architect / Engineer.
Allega' tion 38:
WITHHELD FROM PUBLIC DISCLOSURE Response: ,.
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the partiev*ar practices of the Architect / Engineer. .
Allegation 39:
WITHHELD FROM PUBLIC DISCLOSURE
~
Rasponse '
Although this allegation was site specific to SONGS, BNL believed the problem was poteatially generic and undertook to evaluate it further as
_ _ applies to the Midland plants. During our visit to Midland, BNL deter-mined that the Nonconformance report in question (NCE Fe1941) was evalu-ated by,.Sechtel Corporation as a " potential probles" on Deficiency Eval-untion Esport No.
69 (11/4/80) for the Midland site. The evaluation .
concluded that the Midland site was not subject to the problem which t.
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30
,t e
originated at SONGS. We terminated our investigation of this allegation after our review of the evaluation report. The allegation was not con-sidered to be applicable to the Midland plants.
Allegation 40 '
"A11eger discusses the qualifications of "Rilti-type" stude and a stud that failed in a brittle manner."
.asponse .
We were unable to further define the nature of this allegation. Since the statement (s) made do sot identify or constitute a nonconforming con-dition tigation.
we recommend this ites be closed without further action or inves-Allegation 45:
WITHHELD FROM PUBLIC DISCLOSURE . .
Response
This allegation is not site specific to Midland therefore, no respcase is provided. Also, the allegation is such that it does not land itself-to generic consideration based on the particular practices of the Architect / Engineer.
- Allegation 47:
WITHHELD FROM PUBLIC DISCLOSURE . .
e ,onse . .
This allegation is not site specific to Midland therefors, ao response is provided. Also, the allegation is such that it does not lend itself-to generic consideration based on the particular practices of the Architect / Engineer. .
Allegation 49:
WITHHELD FROM PUBLIC DISCLOSURE Response: ,
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lead itself-
_ _ _ to generic consideration based on the particular practicas of the Architect* / Engineer.
[.
e e
e
, 31 Allegation 52:
WITHHELD FROM PUBLIC DISCLOSURE
Response
This allegation is not site specific to Midland therefore, no response is provided. Also, the allegation is such that it does not lend itself-to generic consideration; based on the particular practices of the Architect / Engineer.
Allegation 61:
" March 22 meno of Foster, pg. 2, last paragraph - all welds onsite should be reinspected."
Response: /
A response to this allegation cannot be provided due to its broad and un-defined nature. We recommend this item be closed without further action or investigation.
0 9
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p' 32 '
CATECORY F Additions 1 Work / Investigation Required the following allegations, although considered by BNL to be broad, sub-jective and general are such that a meaningful response could be provided when based on an analysis of results ebtained from a specific inspection plan or effort. This effort was not made due to the obvious magnitude involved. It is entirely possible that a res'ponse can be provided which will be based on the data obtained during overinspection, corrective action and/or other qual-ity verification plans *and programs which have been (or will be) accomplished I at the Midland plants.
Allegation 48 i "I have seen Bechtel personnel, both QC inspectors and engineers with QC l responsibilities, routindly accept sub-standard work." l l
Response
We presume the alleger is referring to weld related items. Iacking fur-ther definition, our recommended approach is as stated above unless spe- I cific cases or details can be identified. , 1 Allegation 11:
"Because of this, I was very concerned to discover that many welds in the l piping had been improperly ground down, grinding down the pipe wallg !
thickness along with it." 3 ,
I
Response
See response to allegation 11 on page 10. This allegation was not substantiated. l l
Allegation 27 , i "It is alleged that pipefitters used pipe cutters to place scribe marks '
on socket weld fitup measurements."
Raeponse:
~
This allegation was ' site specific to the San Onofre nuclear plant and therefore, was not pursued further at Midland. If the allegation is con- i sidered to be a generie concern (with the alleged practice to have alry l taken place at the Midland plant) its resolution can be accomplished by the development and implementation of an inspection plant for avaatnation W of socket welds for evidence of " pipe cutter" use for placing scribe j aarks.
Allegation 3 :
"P.139, para.'4 - A11eger states that at Midland undereised fillet welds were documented as acceptable."
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e
- 33 W
Respons7 See response to Allegation 4 on pg. 32.
Allegation 43:
"Pg. 223, para. 2 - A11eger states that in Region III plants inspectors documented they were not." undersized fillet welds as being full sized socket welds when
Response
See response to Allegation 4 on pg. 32.
Allegation 60: 9 "Both Midland and Region,III inspector did not know how to use a fillet weld gauge properly." l
Response
A sample examination of fillet velds would refute or substantiate this allegation. If we presume that unfamiliarity with the use of the fillet gauge was widespread, the data accumulated would substantiate the alle-gation by high reject rates upon reinspection. 11 unfamiliarity with the use of the gauge were minor or localized, a sample (regardless of its size) could refute the allegation. Additionally, see response to allegation 53 on page 21.
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9
m i GOVERNMENT ACCOUNTABluTY PROJECT e 1555 Connecncut Awnue. N.W. Suite 202 ;
o Washington, D.C. 20036 (202)232-8550 March 25, 1985
- Freedom of Information Act Request Director FREEDOM OF INFORMATK)N Office of Administration ACT REQUESI U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 hp g ']_) 3 To Whom It May Concern
- gsd J [
Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C.
, Section 552, the Government Accountability Project (GAP) requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, inter-view reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, tele-phone messages, computations, voice recordings, computer runoffs, any other data compilations, interim and/or final reports, status reports, and any and all other records relevant to and/or gener-ated in connection with the Brookhaven National Laboratory (BNL) investigation of the allegations of Mr. E. Earl Kent, and all I
drafts, materials, etc., developed by Brookhaven. This request includes all correspondence (of any type) between BNL and the Bechtel Corporation, Consumers Power Company, Southern California Edison, and any representatives or staff members of the profes-sional societies (i.e., AWS, ASME, ANSI, etc.).
This request includes all agency records as defined in 10 C.F.R.
Section 9.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980) whether they currently exist in the NRC official, " working", investigative or other files, or at any other location, including private residences.
If any records are defined in 10 C.F.R. Section 9.3a (b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed af ter this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a des-cription of the action (s) taken relevant to, generated in connec-tion with, and/or issued in order to implement the action (s) .
GAP requests that fees be waived, because " finding the infor-mation can be considered as primarily benefitting the general pub-lic," 5 U.S.C. 552 (A) (4) (A) . GAP is a non-profit, nonpartisan
-858 c44 / 77- {/p
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\
_. Frcedem of Information Request
? March 25, 1985 Page Two public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens Clinic is currently assisting several citizens groups, local governments and intervenors in the mid-Michigan area concerning the construction of the Midland plant.
We are requesting the above information as part of an ongoing monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants.
For any documents or any portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is rele-vant to the document or portion of the document withheld. This index is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974).
We look forward to your response to this request within ten days.
kk'M Billie Pirner Garde Citizens Clinic Director I
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