IR 05000430/2009005

Staff Exhibit S-17,consisting of Forwarding Safety Insp Repts 50-456/85-21 & 50-457/85-22 on 850430-0905 & Notice of Violation Re Failure to Document Activities Affecting Quality

ML20214B806
Person / Time
Site:	Braidwood, 05000430
Issue date:	08/13/1986
From:	Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
OL-S-017, OL-S-17, NUDOCS 8705200420
Download: ML20214B806 (29)

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NOV 4 1985

'87 APR 24 P4 :44 sucun etcuuren comuission  !

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'l Docket No. 50-456 y,,,,,,,, A Ed'/.5*# C CCC C ..,; ou N'

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Docket No. 50-457 '

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Commonwealth Edison Company ;3 n:mto ATTN: Mr. Cordell Reed m., nutcao Vice President Post Office Box 767 C"4 "'

" g /,g.gd Chicago, IL 60690

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Gentlemen: ,

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This refers to the special safety inspection conducted by Messrs. J. Neisler and R. Mendez of this office on April 30 through September 5, 1985, of activities at Braidwood Station, Units 1 and 2, authorized by NRC Construction Permit No. CPPR-132 and CPPR-133 and to the discussion of our findings with

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Mr. D. L. Shamblin on August 30, 198 .

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Appendix. A written response is require In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Roo The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 We will gladly discuss any questions you have concerning this inspectio

Sincerely, 8705200420 860813 PDR g

ADOCK 05000456 PDR ...)

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by J. J. .,,,,, --

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J. J. Harrison, Chief  ;

Engineering Branch

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Enclosures:

Appendix, Notice .

of Violation . Inspection Reports No. 50-456/85021(DRS); 'h. %T No. 50-457/85022(DRS) *M 4s.3 JEU s N[ %V '

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See Attached list For Distribution

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Comonwealth Edison Company 2  !

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NOV 4 1985 .l

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REGION III==

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Report Nos. 50-456/85021(DRS); 50-457/85022(DRS)

i Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago,*IL 60690 .

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Facility Name: Braidwood Station, Units 1 and 2

. Inspection At: Braidwood Site, Braidwood, IL

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! Inspection Conducted: April 30-May 3, May 7-10, June 24-25, August 28-30, and September 5, 1985

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, Inspectors: R. Mendez /dM 9/8f Dat ' ' /Or >9-25

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Approved By:

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. C. Williams, Chief

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Plant Systems Section Date

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Inspection Summary .

Inspection on April 30 through September 5, 1985 (Report No. 50-456/85021(DRS);

50-457/85022(DRS))

Areas Inspected: Special, unannounced inspection of allegations; and licensee i

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actions on allegations. The inspection involved a total of 152 inspector-hours by two NRC inspectors including 18 inspector-hours of in-office inspection and 30 inspector-hours during off-shift Results: Two violations were identified (failure to follow procedures -

Paragraph 2.a(2); failure to provide documentation of activities affecting

quality - Paragraph 2.d(4)).

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DETAILS

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5 ' Persons Contacted

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Commonwealth Edison Company (CECO)

• J. Wallace, Project Manager

+ L. Shamblin, Project Construction Superintendent

+ W. Shroeder, Project Licensing and Compliance Superintendent

1. T. E. Quaka, QA Superintendent

• M. Preston, Director-Quality First

1. E. F. Wilmere, QA Supervisor

+E. E. Fitzpatrick, Assistant Manager QA

1. G. E. Groth, Assistant Construction Supervisor

+L. M. Kline, Project Licensing and Compliance Supervisor

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1. C. Mennecke, Project Construction Department Supervisor

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• W. E. Vahle, Project Field Engineering Manager

1. E. Netzel, QA Supervisor, Electrical +J. Gieseker, Project Field Engineer

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L. K. Comstock and Company (LKC) ,

1. R. Simms, QA Supervisor ,

"J. J. Klena, Project Engineer

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+I. F. Dewald, QC Manager

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The inspector also cor.tacted and interviewed other licensee and contractor personnel during this inspectio * Denotes those personnel attending the May 10, 1985, exit intervie '

1. Denotes those personnel attending the August 30, 1985, exit intervie l

+ Denotes those personnel attending the May 10 and August 30, 1985, i exit interview l 2.' Followup on Allegations j On March 29, 1985, 24 L. K. Comstock (LKC) QC inspectors went to the NRC l

Resident Inspectors' office at Braidwood Station with allegations I concerning quality issues. These allegations (NRC Tracking l No. RIII-85-A-0072) were subsequently sent by NRC Region III to the licensee for its review and resolution. This action was acceptable to the licensee and the LKC inspector Prior to going to the NRC Resident Inspectors' office, some of the QC inspectors had expressed some concerns to NRC Region III regarding LKC's  ;

QA program. These concerns were received by Region III and tracked as l

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allegation numbers RIII-85-A-0062, RIII-85-A-0067.and RIII-85-A-006 Several of those concerns were similar to the allegations (RIII-85-A-0072)

( received on March 29, 198 ,

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During this inspection, discussions were held with LKC personnel

' including 16 randomly selected QC inspectors and other personnel to review the LKC inspectors' concerns and allegations. The inspectors '

interviews included some of the inspectors who provided the allegations  ;

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and concerns. The NRC inspector also reviewed the licensee's actions '

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regarding the issues expressed by the QC inspectors as documented in allegation No. RIII-85-A-0072. The allegations and concerns expressed )

by LKC inspectors are addressed below in the order they were received by the Regional Office, (Closed) Allegation (RIII-85-A-0062)

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- On March 13, 1985, the Senior Resident Inspector received information '

regarding lack of qualification of LKC personne (1) Concern

The alleger cited an example where one QC supervisor was not

- certified as a Level II inspector in the areas of cable tray,

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concrete expansion anchors, and receipt inspection. The alleger also named two other QC supervisors who were not certified in

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the areas they supervised. The alleger cited LKC Procedure-

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4.1.2, Section 1.21, which states in part, " Quality Control -

Supervisor...shall be trained and knowledgeable in the assigned

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areas of responsibility and certified to Level II capability in those areas."

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NRC Review

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During interviews of the 16 randomly selected LKC QC inspectors, many expressed the opinion that almost all of the QC supervisors were neither qualified nor certified as Level IIs in the areas they supervised. The LKC inspectors felt that they could not depend on the QC supervisors to answer questions in the areas where QC inspectors were uncertain of QC related matter ;

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- Deficiencies in the LKC QC supervisors' certifications had been  !

previously identified in the licensee's Braidwood QA Audit Report #QA-20-84-556 dated December 19, 1984. The audit ,

report identified certain LKC QC supervisors as not having i sufficient work experience. The report also concluded that  !

some supervisors lacked certification as Level II inspectors in j all the areas they supervised. The audit report finding required that training and experience be provided as appropriate and that supervisors be knowledgeable in the assigned areas of responsibility. LKC Procedure 4.1.2, Revision C, was reworded such that a QC supervisor is required to obtain certification as a Level II inspector after they attain the position of QC superviso However, supervisors do not perfom Level II reviews prior to receiving certification in their areas as specified by the governing procedures and regulations. Formerly, the procedure required that the employee be a Level II inspector before becoming a QC superviso .

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This Braidwood audit finding had not been closed out and requires.that the subject supervisors receive the required

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training to become certified Level II inspectors in the areas they supervis .

. Conclusion ,

The allegation regarding supervisor qualification was substantiated in that s_ome of the QC supervisors were not 1 certified as Level II inspectors in all areas they supervise i While this lack of certification is not contrary to any explicit l NRC certification requirement, it is contrary to the licensee's procedure and therefore 10 CFR 50, Appendix B, Criterion '

The CECO Braidwood Site QA had identified the lack of qualifi-cation and/or certification of Supervisors in an audit report on December 19, 1984, before the allegation was made on March 29, 1985, and adequate corrective actions had been ,

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initiated. Therefore, for enforcement purposes this is '

considered to be a licensee identified ite ~ ~ ~ ~

(2) Concern

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The alleger cited as an example two QC inspectors who were .

selected as lead inspectors but were not qualified and were therefore, unable to perform their assigned duties adequatel I The alleger stated that one of the lead inspectors did not have j any qualifications and that the second lead inspector had qualifications only in receipt inspections. (During the onsite interviews of the 16 randomly selected QC inspectors, an additional six lead QC inspectors were alleged to be improperly qualified.) The alleger cited LKC Procedure 4.1.2, j Sectio'n 1.22, which he indicated stated that "QC inspectors be certified as Level II's in the area the inspector has lead responsibility".

NRC' Review The inspector reviewed the qualification records of the eight LKC lead QC Level II inspectors who were alleged to have less than the required qualifications / experience. The results of the review indicated that the inspectors had the required background and training with the exception of those mentioned below:

There was one instance where an individual (this QC inspector was alleged to not have any certifications) was assigned as a lead inspector in concrete expansion anchors (CEAs) on March 10, 1985, but did not receive his Level 11 certification until March 21, 1985, due to administrative  !

delays. This individual had passed the written and I practical inspection tests for CEAs on March 5, 1985, and j

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was.previously certified as a Level II CEA. inspector at another site. Although assigning this individual as a lead before being certified as a Level II violated procedures, a review of about 2,000 CEA travelers / inspection reports completed before March 21, 1985, indicated that -

this QC inspector did not sign / approve any CEA quality document '

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• A QC inspector was alleged to have been certified only for receipt inspections but was a lead inspector in other

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areas for which he was not certified. This inspector was assigned as a lead inspector in concrete expansion

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March 1985. The effective revision of LKC Procedure 4.1.2, " Position Delineation," during the period August 1984 to March 1985 was Revision B that stated, in part,

" Quality Control Lead Inspector...is responsible for -

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immediate direction of fellow QC inspectors in their i designated area (s) (i.e., cable pulling, welding configur-ation, etc.)...sust.be certified Level II in designated I area (s)...." While the individual was certified for hanger

. . configuration, there was no documented evidence that this .

lead inspector was certified in CEAs and calibration '

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LKC personnel stated that although the QC inspector was assigned as a " lead" in CEAs and calibration,.their review of a sample of calibration and CEA documentation did not reveal any quality documents where the inspector had signed

, as a Level II reviewe ANSI N45.2.6-1978 states that personnel who are assigned ,

the responsibility and authority to evaluate the validity l and acceptability of inspection, examination and testing i

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results shall be certified as Level II. LKC's " Master Qualification List" classifies 11 functional areas for Level II capability, one of which is calibratio However, the NRC inspector determined that, contrary to LKC's belief that the QC inspector did not sign any quality documents, on May 25,.1984, this QC inspector signed two " Variable Calibration Records" under the column

" Level II Review" for torque wrenches as A-531 and A-828, although the QC inspector was not certified in calibratio * A second QC inspector who was designated as lead inspector in calibration from March 1985 to May 1985 was not certified as a Level II calibration inspector. The NRC inspector determined during the records review that this QC inspector ,

did not sign quality records in areas where he was not  !

certified. This issue was identified by the NRC inspecto l l

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Conclusion )

This allegation was substantiated. There was one example where '

due to an administrative error, an individual became a lead

inspector in a specified area without first being certified as ,

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a Level II inspector in violation of the LKC procedure however, there was no evidence that this individual signed / approved any quality documents in that area before he was for:nally certifie Two other lead inspectors were not certified Level II in violation of the LKC procedure. Additionally, contrary to ANSI N45.2.6 one of these QC inspectors signed two calibration

- inspection checklists under Level II review although he was not

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. a certified Level II-in calibration. These failures of the

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licensee to assure that activities affecting quality be accomplished in accordance with instructions and procedures is a violction of 10 CFR 50, Appendix B, Criterion V

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_( 456/85021-01; 457/85022-01). ,

. (0 pen) Allegation (RIII-85-A-0067)

This allegation consisted of three parts, two of which were reviewed

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by the NRC inspector during this inspection. The third issue involving welding will be addressed during a separate NRC inspectio ,

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(1) Concern One part of the allegation related to the alleger who was an

. LKC QC inspector being reprimanded for absenteeism and poor work performance. The alleger felt that LKC quality control was under production pres,sure and that his reprimand was based on his failure to meet quotas set by LKC managemen NRC Review The alleger had been given verbal warnings regarding excessive absences on S&ptember 27, 1984, and January 27,~1985, and a l written warning on February 20, 1985. On March 19, 1985, the alleger received a second written warning for absenteeism and l poor work performance. The LKC action on the alleger's absenteeism j was prompted by the alleger taking a total of 16 sick / personal l days from June 1, 1984, through March 18,.1985. From 1 January 28, 1985, through March 19, 1985, the aileger had performed an average of 1.6 inspections per' day while the average for his particular speciality (welding inspections) was 9.3 inspections per da With respect to the allegation regarding production pressure to meet quotas, the inspector interviewed the alleger and other selected QC inspectors. All of the QC inspectors stated that LKC management appeared to be more interested in production rather than the quality of the inspections. Some of the inspectors indicated that LKC management was probably concerned

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about losing the electrical contract with the license Additionally, it was stated by the QC inspectors'that one of the QC Supervisors vigorously conveyed the message that manage-

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ment was more interested in production rather than quality by pressuring QC inspectors to perform more inspections. However, ,

none of the LKC inspectors indicated that they would accept

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discrepant work under any conditions. LKC management and the licensee met with LKC QC personnel on May 13, 1985,.to resolve-the QC inspectors' concerns and reaffirm the licensee's and LKC's commitment to quality and to discuss improving communica-

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tion between LKC's management and their. inspector '

Conclusion

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This portion of the allegation could not be substantiate . Some of the QC inspectors expressed opinions about a QC supervisor who projected a production oriented attitude that ,,

some QC inspectors felt would affect quality; however, the*e was no evidence that this led to procedure violations or to LKC inspectors accepting discrepant wor ..

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(2) Concern *

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One part of the allegation was that QC inspectors were not

being properly trained in conduit specifications. The individual cited Procedure 4.3.13, " Installation of Junction

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Box and Equipment", which referenced the conduit specifications for grounding of junction boxes.

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4 NRC Review Section 3.5.6.1 of LKC Procedure 4.3.13, states that, " Junction boxes...will be grcLnded in accordance with the conduit specifi-

, cations." Procedure 4.3.13 also references S&L Standards and

approved drawings. Currently, QC inspectors who are certified J Level II QC inspectors in the area of " Equipment / Junction Box

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Installation" are required to have knowledge of Procedure 4.3.13. A review of training records of 5 of the 12 QC Level L

II conduit inspectors indicated that they attended lectures and demonstrations on Procedure 4.3.13. Additionally, records

indicated that the QC inspectors had been trained to Specifica-i tion L-2790 and S&L drawings 20E-0-3391A and 20E-0-30000 which i are the specifications for groundin During the discussions with the 16 LKC inspectors addressed ,

in Paragraph 2.a above, none of the inspectors could provide an example where junction boxes were not grounded per the applicable conduit drawing or specificatio .

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Conclusion

This portion of the allegation could not be substantiate Installation Procedure 4.3.13 for junction boxes references conduit grounding and it appeared QC inspectors were being '

trained in the provisions of the procedure. There were no documented examples of failure to ground conduit per the

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applicable specification or drawin '(Closed) Allegation (RIII-85-A-0068)

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Three allegations by LKC QC inspectors were received by the Region

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on March 20, 1985. The allegations are addressed below:

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(1) Concern .

The LKC QC inspectors stated that the pressure on quality *

y control inspectors to perform a large number of electrical inspections would affect the motivation of the QC inspectors

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and their ability to identify all safety issues. The individuals stated that.LKC management was concerned about production and not quality-and that a continued " production

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push" by management would necessitate a complete re-inspection ,

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effort by LK NRC Review During discussions with the QC inspectors, none indicated ; they would accept discrepant work. ' Although, the general perception among QC inspectors was that LKC management pushed production, no discrepant quality issues were identified to the NRC inspector (Also see Allegation RIII-85-A-0067 and RIII-85-A-0072). A review of quality documents such as travelers and inspection reports in view of LKC's alleged production push revealed no programmatic problem Conclusion This allegation could not be substantiated.

(2) Concern A QC inspector alleged that he found a structural steel base metal reduction problem in the auxiliary building. The  !

individual said he told the lead inspector and that the lead responded, "Do your electrical assignments." The individual said he told his supervisor about his concern and that the supervisor responded, " Keep up production or I'll take you off of overtime." The individual did not think this problem was 1 being handled in accordance with applicable procedures and he believed he was being pressured into overlooking problems by having his overtime taken away.

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J NRC Review t

The alleger's statements based on NRC examination and - i discussion have not been corroborated by the lead or the  !

supervisor during interviews. That is, there is no corroboration .

l that the alleger was told not to concern himself with the base metal reduction problem and that he would be taken off overtim !

The alleger had originally identified the base metal reduction  !

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problem on December 8,1984, and documented the discrepancy in a memo to the QC manager. On December 18, 1984, the QC manager sent the memo through the proper channels to the s G. K. Newberg, the civil / structural contractor, for resolutib The alleger also referred the base metal reduction problem.to a LKC Field Engineer. At the time the alleger brought the

, base metal reduction concern to the LKC Field Engineer, LKC's procedures and specifications did not allow them to repair

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structural steel. Subsequently, S&L Specification L-2790 was

. changed to allow LKC to repair or rework base metal reduction problems on structural steel when caused by electrical rewor This change was incorporated per Amendment 46 and Engineering Change Notice 25862 into S&L Specification L-279 ' ~

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. On July 30, 1985, Inspection Correction Report (ICR) No. 10991 was issued to correct the base metal reduction problem

identified by the allege i'

Conclusion

This allegation could not be substantiated. Based upon review

of documentation relative to this allegation, the inspector determined that the base metal reduction issue was properly

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referred to the responsible contractor for disposition. With respect to the alleged threat that the alleger's overtime would be taken away, his overtime has not been taken away based on discussions with the allege (3) Concern The LKC QC inspectors alleged that many new electrical inspectors are being qualified and certified in the areas of welding and I configuration in one week. The allegers felt that it was- )

impossible to be adequately knowledgeable in all of the detailed l reference tables and drawings necessary to perform the inspections in one week, and that the quality of inspections by inspectors qualified in one week was questionabl NRC Review Hany of the LKC QC inspectura intervi=wed expressed concern'

about other inspectors being certified expeditiously. Some of the inspectors indicated that they had knowledge of unqualified

. inspectors and supervisors (This is also discussed in more detail in Paragraph 2 for lead inspectors.)

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"' ~ The NRC inspector reviewed the certification and qualifications of 10 new LKC QC welding inspectors. (Thisgroupdoesnot include the eight lead inspectors reviewed in Allegation

l RIII-85-A-0062.) The review included the background experience

as a QC inspector and/or as a craftsman under a quality program l

at previous places of employment, and the results of written l and practical exams prior to certification as a QC Level II i

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inspector for LKC. The records indicated that nine of ten new inspectors had the proper background and training to be certified Level IIs per ANSI N45.2.6 and LKC Procedure 4.1.3,

" Qualification and Training of QC Personnel."

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One QC inspector did not have the required experience for

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- certification as a welding inspector. This individual was hired r

on November 21, 1983, and was certified as a Level II welding inspector on January 4,1984. This person's background was

,i electrical and he had no prior weld inspection experienc .

His lack of qualification was identified by the licensee's Braidwood QA surveillance in report no. 3372 on February 5, 1984. Initially, Braidwood QA found problems with the

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- certification of this individual since the person's certifica-i - - tion package only contained documentation of previous electrical *

experience. There was no documentation of welding or welding inspection experience. 'Braidwood site QA accepted th individual's certification based on the person's background as

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a QC supervisor in the use of vernier calipers, scales and torque wrenches. Final acceptance by Braidwood Site QA was

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accomplished by including the individual's welding experience acquired as a Level II welding inspector at Braidwood. The

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use of his experience acquired while apparently improperly certified as a Level II welding inspector requires further NRC examination. This significant issue is that the .

. acceptability of his inspection activity during the period when his certification / qualification was questionable remains to be

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assessedandisconsideredanunresolveditem(456/85021-02; 457/85022-02).

Conclusion This allegation was partially substantiated in that one

- instance was identified where a new LKC inspector with no previous experience either as a craftsman or as a QC inspector in welding became a Level II welding inspector within six weeks of being hired by LK !

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' (Closed) Allegation (RIII 85-A-0072)

On March 29, 1985, six LKC electrical quality control inspectors presented allegations to the Braidwood NRC resident inspectors

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regarding the quality of QC inspections, QC supervisor qualifications, .

intimidation a,d harassment of QC inspectors, and closing noncon-formances without field verification. A second meeting between the NRC resident inspectors and 24 LKC QC inspectors was held later in the day. The concerns as presented to the NRC resident inspectors were submitted to the licensee for resolution. The licensee agreed y to interview the LKC inspectors and attempt to resolve their concerns.

.. In addition to meeting with individual LKC inspectors, the licensee- -

, removed a QC supervisor from his po,sition until the allegations were

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resolved and scheduled a meeting between the licensee and LKC QA/QC and management personnel to re-emphasize the licensee's QA policies and commitment . A summary of the LKC inspectors' concerns as expressed to the

. licensee and the licensee's subsequent actions are documented in J Commonwealth Edison's Quality First Group as Braidwood Record of Concerns numbers QF-85-1188, 1229, and 2026. On April 25, 1985, the~ ~

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licensee completed its reviews of the LKC QC inspectors' concerns and allegations. The concerns and allegations of the QC inspectors -

are addressed belo (1) Concern

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l* A QC inspector alleged that "L. K. Comstock is asserting the

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quantity of inspections rather than the inspection qualit Therefore, the quality of th'e L. K. Comstock inspections is suffering."

'I Licensee Review The licensee found that some of the QC inspectors felt that the QC manager pushed production after the Construction Manager let it be known that inspections had to be done. However, the

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licensee also determined from the LKC inspectors that quality was appropriately emphasized. The LKC QC inspectors indicated

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that one QC supervisor vigorously pushed inspections but if QC inspectors questioned quality the QC supervisor would refer to the procedures so that quality was not sacrificed. In certain

. instances the licensee determined that this supervisor had been unduly abrasive in his professional relationships with the QC inspectors.

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NRC Review The NRC inspector examined licensee trend analyses of quality assurance deficiencies identified during audits and surveillances

of LKC activities. None of the analyses indicated that the quality of the LKC quality control inspections had deteriorated

as a result of the alleged emphasis on increased inspector

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l productiv.ity in that the percentage of. inspection findings per report had remained about the same as before. In addition,-

review of three of LKC's quarterly trend analysis reports showed

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no adverse trends in.the quality of inspections as evidenced by

, no observed decline in the numbers of inspection finding Review of quality control manning tables revealed that the contractor increased the number of inspectors as workload increased. For the month preceding receipt of this allegation the inspector compared the number of inspections performed and the number of inspectors in the field and determined the average inspector performed approximately 21 inspections per week which in the NRC inspector's view was not excessive. None of the inspectors interviewed stated that they had personally ,

performed inspections where they had asserted quantity rather than quality.

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Conclusion Based on review of trend analyses, personnel manning tablet, inspection records and interviews with quality control

. . inspectors, this allegation could not be substantiated since .

. there was no evidence that production pressure affected the quality of inspection .

(2) Concern QC inspectors alleged that "a Comstock QC supervisor was not qualified for his position, as he was not certified in all  !

of the inspection areas which he supervised."

l Licensee Review The licensee investigation identified one instance wherei LKC QC inspector related an incident in which a QC supervisor wanted an NCR written in a discipline where he lacked certification. The licensee found that the LKC inspector refused to write the NCR until he went out and observed the situation in the field at which time the QC inspector agreed to write the NCR. The licensee's review also included the adverse audit finding in which site QA identified the LKC supervisors who did not hold certifications in all the areas they supervis '

NRC Review Neither NRC regulations nor ANSI Standards require quality control supervisors to be certified in all inspection areas they supervise. However, this is required by LKC procedure The NRC inspectors identified an instance wnere a supervisor /

lead inspector did not have the certifications required by

. procedures. This finding is described in the NRC Review of Allegation RIII-85-A-0062 abov ,

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Conclusions i Based on NRC review of personnel certifications this allegation

. is substantiated.in that one individual was not certified in all areas in which he supervised inspectors. See the conclusion ,

for Allegation RIII-85-A-0062 above for further explanatio (3) Concern QC inspectors alleged that one QC supervisor was constantly intimidating / harassing the LKC inspectors to sign off NCRs and

, ICR .

Licensee Review

> The licensee investigation substantiated the QC inspectors'

allegations against the QC supervisor. The licensee stated

- that on March 31, 1985, LKC indefinitely suspended the subject QC supervisor. On April 2, 1985, LKC concluded that the accused QC supervisor should be removed from the job site, the

licensee concurred and the QC supervisor was remove ~ ' -

NRC Review The NRC inspectors interviewed QC inspectors, including the allegers. The QC inspectors nach stated that the supervisor had an abrasive and aggressive personality and was very quick to lose his temper when inspectors' findings or interpretations

,,

were counter to his interpretations of procedures or require-ments. At that time, it was alleged that he would become abusive and berate and threaten the inspector with dismissal; however, none of the inspectors could remember an instance where an inspector had actually been dismissed nor did any

inspector remember an instance when he had signed off an

inspection as a result of pressure from his supervisor. Some of the individuals interviewed stated that some of the inspectors would goad the supervisor into losing his temper-since they enjoyed his outburst The supervisor was dismissed as a result of his ordering a QC inspector to close out an inspection report before the '

i inspector received the documentation authorizing the closeout and final disposition. The disposition of the inspection had been reviewed by engineering and the documentation had been

, sen ,o, but not yet received by, the QC inspecto The licensee has initiated a training program for LKC QC control supervisors in basic management techniques to prevent a recurrence of the intimidation / harassment issu '

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Conclusion The allegation that the supervisor intimidated, harassed and berated QC inspectors was substantiated. However, this occurence has not impacted the QC inspector's perfonnance of quality i related activities. The action to dismiss the supervisor and *l

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implement the supervisor training program are adequate i corrective actions for resolution of this issu l (4) Concern -l QC inspectors alleged that 93 hanger inspections on one check-

- list containing 1100-1200 welds were signed off in one day by

• - an identified inspector. .The allegers considered this to be too many inspections for a single inspector to make in one day without the quality of the inspections sufferin Licensee Review This concern was not addressed by the licensee. None of the QC inspectors interviewed by the licensee provided an example where an individual accepted hanger inspections without going out to the field to verify the wor , ,

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NRC Review The QC inspectors interviewed identified the person alleged to

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have performed 93 hanger inspections in one day. The identified person was questioned regarding this issue and he responded

that to his knowledge this did not occur. The LKC inspectors could not provide an inspection report or date of the alleged occurrence. Consequently, the inspection checklist where 93 hangers were accepted by the QC inspector who is the subject of the allegation was not located during QC records reviews by the NRC inspecto A similar concern was examined regarding another QC inspector

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as follows. On November 12.-1980, a LKC inspector documented the acceptance of 129 hangers and 1,215 welds on one inspection l 1 checklist. According to LKC management, QC welding inspectors l kept daily logs of the hanger inspections. When all of the l hanger inspections for an area were complete, the QC inspector  ;

would sign off for all of them on one inspection checklist and

. send the hanger numbers to PTL. This record therefore reflected a number of days of inspection effort. Subsequently, PTL would perform nondestructive tests on 10% of the welds and would J accept or reject the welds. In this instance, PTL reviewed 122 l (10% of the total) welds and rejected 16 welds on 10 hanger The LKC QC inspector reviewed the 1,215 welds and found them all acceptable. It is not clear why additional PTL nondestructive tests were not perfonned to include a larger sample since about 13% of the welds were rejected by PTL. The licensee stated that there was no instruction to require additional nondestructive

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test based on any identified failure of the sample teste ;

That is,' PTL would reject the welds when required based on

the NDE tests and identify the rejected welds to the contractor. The contractor would rework or repair the welds,

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but the current procedures do not require nondestructive testing ,

i of more of the welds submitted for test. Additionally, no 4 record exists which specifically documents acceptance of the ,

individual welds associated with a hanger. The licensee stated that the inspector's inspection logs were not filed with the inspection report. This program area requires further review and evaluation and is considered to be an unresolved item

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(456/85021-03; 457/85022-03). , ,

A related issue identified during this inspection involved the disposition of the 16 hanger welds mentioned above. On November 19, 1980, PTL completed its report of visual inspection of structural welding on the subject ten hanger .

As mentioned before,16 of the 122 welds reviewed by PTL were i rejected and the report was sent to LKC for dispositionin ,

However, at the time of the exit interview on August 30, 1985, '

the licensee could not provide documented evidence that the

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16 welds had been dispositioned or whether corrective action

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had been implemented to repair the identified discrepant weld On September 5,1985, the NRC inspector was informed that two of the ten hangers were deleted by S&L and three of the hangers were repaired; however, the licensee could not provide documented evidence that would indicate whether the remaining five hangers (CC-23, CC-36, CC-87 and two type CC-34) were reworked, repaired or accepted-as-is. ANSI N45.2-1977, Section 18, states, in part, that " Sufficient records shall be prepared as work is performed

, to furnish documenting evidence of the quality of items and of -i activities affecting quality." The licensee has committed to

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reinspect welds on the remaining five hangers to provide inspection documentatio Conclusion

! This allegation could not be substantiated. However, examina-tion of a similar issue involving another QC inspector showed that the record of inspection identifies many welds that were

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inspected on different days. It is not clear from the existing record (s) whether any specific weld was inspected, only when it was reported. The issue identified above wherein the quality records for the rejected welds on five of the ten hangers were unavailable constitutes a violation of NRC requirements. That is, the failure to assure that sufficient records be maintained l to furnish evidence of activities affecting quality is a l violation of 10 CFR 50, Appendix B, Criterion XVII (456/85021-04;

457/85022-04). , ,

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(5) Concern .

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A QC inspector alleged that an LKC QA Engineer was assigned to the records vault for the sole purpose of closing nonconformance ,

report The alleger stated that this individual never went -

into the field to verify the condition (work to be accomplished per the NCR) before closing the nonconformance report Additionally, this individual was alleged to be both a QC inspector and a QA auditor who would inspect first, then do the QA audit. Some LKC inspectors also indicated that QC inspection reports were being signed,without the inspector going into the field to verify completed wor Licensee Review The LKC QC inspectors interviewed by the licensee indicated that they had no knowledge of inspectors signing off QC -

inspection reports in the office or vault without going out into the field to verify the conditio .

NRC Review

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The NRC inspector interviewed the alleger and the individual

. who allegedly closed the reports and performed the audits,

,- reviewed the closed out reports and audits, and discussed the issue with the QC manager and the LKC site QA manage The alleger stated that he had no first hand knowle'dge that the other individual had closed nonconformance reports in the vault and performed audits of inspection activities in which he was involved, but that he had heard that this had happene He stated that this had occurred over a period.of about two weeks or maybe two days, but was not sur The NRC inspector's interview with the other individual was conducted by telephone since the individual was no longer at Braidwood. He stated that he had been detailed to work for quality assurance to assist in the preparation of a report for submission to the licensee. His duties in the vault were to research nonconformance and inspection reports for material to be included in the report. He further stated that he had closed no reports during that period. He further stated that he had never participated in an audit involving LKC at Braidwood. The QA and QC managers agreed that the individual did not close reports or perform audits during this perio The NRC inspector's examination of the nonconformance report log did not reveal any reports that had been closed by the individual during the two weeks he was working in the records '

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Conclusion

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Based on interviews with the alleger, the individual, the

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quality managers, and the NRC inspection of nonconformance logs, this, allegation could not be substantiate .l (6) Concern The QC inspectors stated that they had spoken to the Braidwood

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Quality First Team without gaining any satisfactory response to their concern " ~

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Licensee Review .

The licensee interviewed LKC inspectors starting on February 13, 1985. These interviews were completed on March 11, 1985. As a result, on March 4,1985, the Quality First organization

- documented a LKC QC inspector concern dealing with the adequacy of trainin As a result of ongoing investigations by the

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licensee, some of the concerns were combined into investigations 1188, 1229 and 2026. At this time the licensee had not  ;

. completed its investigation of all the concerns. The most '

, recent Quality First concern (QF 85-2026) was documented to track the concerns of the LKC QC inspectors who met with the resident inspectors on March 29, 1985. The licensee is investigating the comprehensiveness of the initial Quality

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First response to these inspector concern NRC Review The NRC inspector examined Quality First documentation relative to this allegation and interviewed Quality First Team personne The inspector determined that the LKC QC inspectors had been interviewed by the Quality First Team in February 1985. These interviews were part of a program to establish baseline data for the Quality First Team and included all QC~ inspectors from all contractors. The LKC QC inspector's concerns were reviewed within the Quality First group and assigned for investigation on March 4, 1985. At the time the allegation was made to the NRC resident inspectors, the investigation into QC concerns had

, not been complete The NRC inspector examined the completed report dated April 25, 1985, of the investigation of the QC inspector concerns. The report addresses the concerns expressed during the Quality

, First Team interviews and the allegations made to the NRC on March 29, 1985.

l Conclusion The allegation was substantiated in that the QC inspectors had not received a response from the Quality First Team; however, the NRC inspector determined that the QC concerns were properly i

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addressed and adequate corrective action had been initiated by I the licensee.

i (7) Concern

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One QC inspector stated that hangers are not inspected, just as-built. No inspection report or nonconformance reports were written. Walkdowns were being done and drawings made to show as-built configuratio .

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Licensee Review The licensee determined that NCRs 708 and 709 were issued to document and provide direction for the overall program to walk down (inspect) hangers that were not installed in accordance with design drawing NRC Review The inspector reviewed the hanger reinspection program based on Commonwealth Edison NCRs 708 and 709 and the inspection

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documentation generated through the disposition of these NCR .

The inspection activity referred to in the allegation is being performed pursuant to NCR 708 and NCR 709. Since the inspection is performed to correct the situation described in an NCR, no other NCR would be issued since the problem has already been identified. The inspector determined that inspection reports are being written for the inspection activities according to approved procedure Conclusion Based on the inspector's review of NCRs 708 and 709 an inspection reports related to the NCRs, this allegation could not be substantiated.

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(8) Concern A LKC QC inspector alleged that he was constantly watched by his supervisor. This LKC inspector visited the NRC office and according to him was transferred without reason from field inspections to a job in the records vaul Licensee Review I l

The licensee determined that the subject of this concern was a QC inspector whose personnel certification package is being i held by Braidwood QA. The QC inspector in question copied the l I

same inspection checklist several times and later filled in some of the blank spaces in violation of procedures. The QC inspector's work is being re evaluate .

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NRC Review The NRC inspector examined a licensee surveillance report that identified deficiencies attributed to the alleger's weld inspections. He was observed with copies of the same '

inspection checklist on which he could fill in blank spaces, in violation of procedures. The licensee cedered LKC to

- remove him from field inspection in October 1983. Items inspected by the alleger using the copied checklists were reinspected by other inspectors. The NRC inspector determined that the alleger has not been permitted to perform weld

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inspections since October 1983 when he was transferred to the records vaul Conclusion -

Based on the inspector's review of documentation relating to '

a the alleger's transfer from the field to the records vault, this allegation could not be substantiate ~

(9) Concern

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It was alleged that an inspector cannot remain proficient -

in all of the certified areas without a decrease in the quality of the inspections, and that LKC management promised more money to inspectors who were certified in multiple area '

Licensee Review The licensee determined from discussions with the LKC '

inspectors that they would be more comfortable if they could remain in a specified area rather than to move around the site. However, no inspector felt that his request for

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additional refresher training would be turned dow NRC Review During the NRC inspector's interview of LKC QC inspectors the QC inspectors stated that they agreed that it was difficult to maintain proficiency in more than one inspection area, but they also stated that when an inspector was moved from one inspection area to another area that they could ask for retraining if they felt it was needed. None had been denied retraining when they had requested it. No QC inspector felt that the quality of the inspections he perfohr.ed had decreased because of his multiple certification l In interviews with the LKC QC manager and QA manager they stated that it was LKC policy to provide retraining to their personnel at the request of the QC inspector. In addition, changes in procedures and specifications affecting an area of inspection are transmitted to all inspectors certified in that area whether or not they are working in their certification l

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Conclusion Based on interviews with inspectors and managers that revealed that persons may be retrained to maintain their certification proficiency upon that person's request, the allegation could .

not be substantiate .

(10) Concern l

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QC inspectors alleged that lead QC inspectors are being picked based on who would sign off the most quality documents (NCRs 1

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and ICRs).

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Licensee Review The LKC inspectors interviewed by the licensee indicated that

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some of the QC inspectors were picked as leads based on who was signing off the most NCRs or ICRs. However, the licensee concluded that leads were never picked on the basis of who

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, would sign off the most document NRC Review ,

Some of the inspectors interviewed by the NRC inspector stated

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that the selection of lead QC inspectors may have been based on who signed off the most quality documents; however, none could give an example where this actually occurred. No examples were provided regarding improper signing of inspection reports or violations of procedures. NRC examination of personnel records did not disclose any irregularity in this regar Conclusion The allegation could not be substantiated. There was no evidence '

that LKC picked QC lead inspectors on the basis of who signed the most NCRs or ICR (11) Concern It was alleged that some NCRs have been dispositioned by LKC Engineering as " retrain inspectors". Also, some NCRs have been initiated and dispositioned by Field Engineering without an involvement of QC inspector Licensee Review The licensee did not address this concern in its investigatio NRC Review .

Some of the LKC inspectors interviewed by the NRC inspector

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thought that NCRs were being initiated and dispositioned by Field Engineering without any involvement of QC inspector However, none could provide an example. With respect to NCRs being dispositioned by LKC as " retrain inspectors", the QC

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inspectors mutually agreed that if there was an issue where -

the finding clearly violated procedures or specifications they could prevail upon LKC Engineering to change their position No LKC inspector indicated he or she knew of one instance where 4 a NCR was improperly dispositioned. NRC. review of NCR's has not disclosed any significant deficiencies in this regar Conclusion The allegation could not be substantiate (12) Concern It was alleged that if inspection quotas were not met, overtime was not given to individuals.

Licensee Review

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The licensee determined that there was one occasion when overtime '

)- was not given because the person was not getting work done. It was reported that the inspector bragged about how little work-he was doing. The QC manager stated that " Busy people work overtime. Don't give overtime to people who sit around."

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j NRC Review

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Some of the allegers indicated that LKC was more concerned with production rather than quality, but none knew of an example of quality being compromised or inspection quotas being established by LKC quality management. The licensee issues a j Daily Status Report which trends inspections. It is possible the inspectors thought that the report was used to stress l l productio )

Sene of the inspectors indicated they were reprimanded for not producing enough inspections. These inspectors stated that some inspections take more time than other inspections, and consequently their number of inspections were low. A review of the records of three inspectors who had been reprimanded i indicate that all of them had a history of absenteeism and had

received written warnings regarding their absenteeism; however, they had not received any written warnings for failure to meet any inspection quote Cor.::1usion ,

The allegation that overtime was not given to inspectors who '

did not meet inspection quotas could not be substantiate . _

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However,.one related instance was identified by.the licensee where an individual was denied overtime because the individual

was not as productive as was desire l

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l (13) Concern It was alleged that three inspectors at LKC were supposed to be terminated, and if they were terminated LKC inspectors were going to walk.

. Licensee Review N The licensee reviewed the situation that led to the LKC QC .

inspectors threatening to walk out if three . inspectors were .

fired. The licensee concluded that the situation was caused in part by LKC's practice of giving every individual on permanent

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i' payroll 8 days of personal time plus two weeks. vacation a yea Before individuals used up all their personal days in an ,

apparently improper manner, verbal warnings were given. The

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i- licensee determined that three individuals had been given verbal and written warnings for absenteeism. The licensee

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concluded that if the individuals continued their practices, ,

dismissal was possibl NRC Review j The NRC inspector ascertained that the three inspectcrs were j not terminated.

4 Conclusion This matter is a management and not a regulatory issue. No violations of NRC reauirements were identifie (14) Concern

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It was alleged that NCR 1616 and ICR 2900 were inappropriately dispositione NRC Review

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The NRC inspector examined the disposition of NCR 1616 and ICR 2900. The corrective action relative to NCR 1616 and ICR 2900 was reviewed and approved by both the contractor's

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engineering department and the design engineer. Final.close i out of the NCR and ICR was accomplished by a certified Level II 6 QC inspector on August 8, 198 '

Conclusion . -

l The NRC inspector deterr.ined th'+ +ha % al' disposition of the NCR and ICR was proper and that the closeout of both reports was accomplished in a timely manner. Based on the NRC inspector's i review, this allegation could not be substantiate .

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i: r (15) Concern It was alleged that one QC supervisor continually violated procedures during inspector certification *

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NRC Review The NRC inspector reviewed the procedure for training and i

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certification of QC inspectors. According to the procedure, inspectors are not certified or recommended for certification by QC supervisor Review of randomly selected inspector certifications show that personnel are certified by management *

after recommendation by the training department and the Level II inspector who conducts the on-the-job training test for .

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inspector Conclusion Based on the inspector's review of certification procedures and records that revealed that QC supervisors do not certify inspectors, this allegation could not be substantiated.

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(16) Concern

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The allegers stated that there were no certified calibration

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inspector NRC Review The inspector reviewed inspector manning charts and tables and determined that there have been certified calibration inspectors on site since LKC began work at Braidwood in 197 Conclusion I This allegation could not be substantiate ,

l (17) Concern .

It was alleged that a QC supervisor lied to get a QC inspector l

fire j

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Licensee Review The licensee did not review this allegation since it was never brought to the attention of licensee managemen NRC Review .

During discussions with the alleger, he. stated that the circumstances surrounding the incident in which he was i

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threatened with dismissal. involved a. lost company owned tape i

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, L measur According to the alleger he was asked by the QC

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, ' supervisor (who was later removed from his position but not

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>r for'this incident) if he had a tape measure that had been in

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the QC inspector's possession. The alleger stated that he did

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not - at which point the QC supervisor made a " profane"  ;

statement. The QC supervisor stated (according to the alleger)

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that the QC inspector Was negligent with his equipment and continued to use profanity and told the QC inspector to get out

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of his office. The alleger told the QC supervisor that he i didn'.t have to take the abusive language. On January 13, 1983, 4 a ; " ;

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the QC supervisor initiated action to fire the QC inspecto The letter of dismissal states, in part, the QC inspector "has V .

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' ' shown remiss and insubordinate actions in performing those

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' duties assigned by his supervisor c'.ong with not being responsible for company. tools he was issued." The-alleger -

j' was not fired and did not identify any quality concerns. The QC supervisor involved is the supervisor discussed in Paragraph i-2.d.(3) above who was dismissed for inspector harassment /

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intimidation reason Conclusion

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oth allegation could not be substantiated. However, no -

quality issues pertaining to this incident were identifie Licensee's' Summary of the Allegations and Concerns Discussed Above (Paragraphs 2.d.(1) through 2.d.(17)

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Rkgarding the LKC organization, the licensee concluded that certain

' areas such as administration, communications, training and supervisi~o n need additional management attention. The licensee also stated in its summary report of LKC QC inspector concerns and allegations that a labor union issue divided management and inspectors. It was the licensee's conclusion that except for the situation which resulted in the removal of one QC supervisor, no serious quality related problems exist. The licensee stated that many issues were resolved with the termination of the subject QC superviso . NRC Inspector Summary The inspectors determined that the licensee's examinations and conclusions regarding the allegations that the licensee reviewed g

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were appropriate. The two unresolved items identified by the inspector are not directly involved with the allegations. The first instance involves an inspector who was certified as as a Level II in welding within six weeks of being hired but had no prior welding experience. The licensee and LKC later certified the QC inspector based en his experience at Braidwood. However, the QC-inspector's previous work was never re-inspected to determine his original capabilit It is in this context that the unresolved issue was raised by the NRC inspector. This is an isolated instance

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experience. The second instance involves the lack of instructions and procedures to direct what actions should be taken regarding j, additional nondestructive testing of hanger welds when a significant *

- percentage of the test sample of welds is rejected by PT Two adverse issues were identified by the NRC inspectors which i

were related to allegations made by the QC inspectors. One involved lead inspectors who were not certified as Level IIs in their designated disciplines. This violated L. K. Comstock's procedures. The second issue involved lack of documented evidence ,

to indicate that discrepant welds on 5 hangers were repaired or properly dispositioned. Both of these issues are characterized as violations in this repor The problems between LKC management .

- and the QC inspectors generally stemmed from a lack of communication between management and employees, and the bullying tactics of one >

QC supervisor who was removed from the construction site. These

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cencerns have been resolved or are in process of resolution by the license ,

3. Unresolved Items

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Unresolved items are matters about which more information is required

+ in order to ascertain whether they are acceptable items, items of violations or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 2.c.(3) and 2.d.(4).

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, 4. Exit Interview

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The inspector met with representatives.(denoted in Paragraph 1) at the conclusion of the inspection. The inspector summarized the scope and findings of the inspections noted in this report. The inspector also discussed the likely informational content of the inspection report with

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regard to documents or processes reviewed by the inspector during the inspection. The licensee did not-identify any such documents / processes as proprietar .

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