ML20083C542

Affidavit of Rl Bower,Answering Ohio Citizens for Responsible Energy 831125 Motion to Reopen Record on Comstock Issues

ML20083C542
Person / Time
Site:	Perry
Issue date:	12/19/1983
From:	Bower R CLEVELAND ELECTRIC ILLUMINATING CO.
To:
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ML20083C535	List: ML20083C532 ML20083C542 ML20083C560
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NUDOCS 8312230178
Download: ML20083C542 (30)

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e AFFIDAVIT OF RICHARD L. BOWER 6

gDRADOCK8312230178 05000440 831219 PDR

December 19, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF. RICHARD L. BOWER County of Lake )

ss:

State of Ohio )

Richard L. Bower, being duly sworn, deposes and cays as follows:

1. I, Richard L. Bower, am Quality Control Manager for Comstock Engineering, Inc. (Comstock), Perry Nuclear Power Plant. My business address is 10 Center Road, Perry, Ohio 44081. A statement of my professional qualifications and expe-rience is attached. I have personal knowledge of the matters set forth herein and believe them to be true and correct.

2. I have reviewed the Motion to Reopen The Record On Comstock Issues,' dated November 25, 1983, filed by Ohio Citizens for Responsible Energy (OCRE), including the two l

newspaper stories attached to OCRE's Motion. The stories discuss allegations by two former Comstock quality control inspectors, Phillip G. Hendrickson and Gene F. Mathis. I have

, also reviewed OCRE'S Ilovember 30, 1983 letter to the Licensing Board, which attaches a newspaper story discussing allegations by a former Comstock inspector, Steve E. Balazs. The purpose of this Affidavit is to answer the health and safety allega-tions discussed in the three newspaper articles-cited by OCRE.

3. I am the senior Comstock' quality manager working at the Perry site. A number of other Comstock corporate QA/QC managers, above me in the management chain, come to the site periodically to give senior management attention to various as-pects of the implementation of Comstock's QA/QC program at Perry. One of those senior managers is Robert E. Marino, who is mentioned in one of the newspaper stories. Mr. Marino is Manager of Comstock Corporate QA/QC Services.

Phillip Hendrickson

4. OCRE's motion attaches an article from The Plain Dealer, dated November 19, 1983, discussing an interview with Mr. Hendrickson. Mr. Hendrickson is quoted in the article as making the following allegations: (1) that he " felt verbally intimidated by supervisors, particularly Bob Marino, a Pittsburgh Comstock official, during one training session"; (2)

__ that his supervisors were " disgusted" with him after raising l questions about records on steel at Perry; (3) that, in

O e connection with the steel records issue, Mr. Hendrickson was ,

fired 15 minutes after asking for permission to go to the NRC (implying that he was fired for asking questions, and because

-he asked to see the NRC); (4) that morale among inspectors was poor because the inspectors "are not treated like people, but like tools" (a similar quote is attributed to Mr. Gildner, the NRC resident inspector). These allegations are not justified, for the following reasons.

Background

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5. Phillip Hendrickson began working for Comstock at Perry on September 29, 1983, and was terminated on October 20, 1983, prior to being certified to perform inspections at Perry.

During the approximately three weeks th'at Mr. Hendrickson was i employed at Perry, he participated in Comstock's inspector indoctrination and training program. The program is designed to train inspectors in the Perry QA/QC program and procedures applicable to Comstock's scope of work. At the completion of l training, which normally lasts 3-4 weeks, inspectors are tested I

to determine whether they meet CEI-approved certification re-

'quirements. After successfully completing these tests, inspectors are certified by Comstock and presented to CEI for concurrence prior to performing inspections at Perry. Mr.

Hendrickson was terminated prior to the completion of training,

! -tcsting and certification, and thus performed no inspections at l

the plant. At'the time Mr. Hendrickson was hired, he was 4

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2 notified in writing that all new Comstock employees are subject 4

to a 90-day " evaluation period." New employees understand that they can be terminated without advance notice during their evaluation period.

6. In his first week at Perry, Mr. Hendrickson, and other new inspectors, were given numerous written materials describing Comstock's' program and prccedures at Perry, including applicable regulations, procedures,~and standards is-sued by the NBC and'CEI. I personally met with Mr. Hendrickson and the other new insp'ectors. As is my standard practice, I told the inspectors that my door is always open if they wanted 1

to discuss questions or concerns with me personally. Most of the inspectors I have worked with, including Mr. Hendrickson, have freely come to me to discuss a variety of issues.

7. Comstock's policy is to actively encourage employees to bring any concerns to management's attention. We make it

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clear to our employees that they are also free to discuss concerns with CEI or the NRC. We make sure that new employees know the location of the NRC Resident Site Inspector's office i at the Perry plant site, in case they wish to contact that i

! office. The written CEI policy on reporting safety concerns to management or the NRC, a copy of which is attached. is clearly posted on the bulletin board outside my office and at numerous other locations around the site. (The attached copy is smaller in size and print than the actual poster.) The policy " Remind-er" urges each Perry employee "to contact his or her employer, 1

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or if the employee prefers, to directly contact the Nuclear Regulatory Commission" with any safety concerns. The policy Reminder publishes the NRC Resident Inspector's telephone number, and the Region III telephone number (noting that Region III accepts collect calls). The Reminder also states that em-ployees can bring safety concerns to their supervisors, to CEI's QA department, "or to Senior Management" of CEI. The Re-minder concludes that " Reporting all safety concerns is essential to assure the safe construction and operation of the Perry Nuclear Power Plant." On the same Comstock QA/QC bulle-tin board, and at other site locations, is a copy of NRC Form 3, a copy of which is attached. (The attached copy is smaller in size and print than the posted Form.) NRC Form 3 tells workers of their right to talk privately with the NRC, lists the address and telephone number of NRC Region III (noting that collect calls are acceptable), and also tells workers of their right to file complaints with the Department of Labor if they i

believe they have been discriminated against for providing in-formation.to the NRC.

Mr. M.' rino's Remark '

8. The November 19, 1983 newspaper article states that Mr. Hendrickson " felt verbally int 4midated" by Mr. Marino dur-ing "one training session." First, Mr. Marino never partici-pated in a training session with Mr. Hendrickson. The situa-tion mentioned in the article occurred when Mr. Marino met for

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i about 15 minutes in my office with-Mr. Hendrickson and two other new inspectors, welcoming them to Perry. I was present during the discussion, as was Clarence Hart, Comstock's Assis-tant QC Manager. During a brief discussion, which was entirely friendly in tone, Mr. Marino asked the inspectors why they had decided to leave their previous jobs to come to Perry. Another inspector stated that the inspector had been fired from his previous job for disagreements with his management. In re-sponse to this statement, Mr. Marino pointed to a black and

, white bottle of " white-out" ink on the desk and said, "If I say the bottle is black and white, and you say it is orange, it is black and white." The statement was not made in a threatening manner, nor did it have anything to do with raising health and safety issues or any specific inspection activities.

Mr. Hendrickson's Questions

9. Almost from the beginning of his participation in j training classes Mr. Hendrickson would interrupt classes by raising generic issues and questions, based on his work at the Washington Public Power Supply System (WPPSS) nuclear project in Washington, which had little or no relevance to Comstock's scope of work at Perry. Rather than listen and cooperate in l

l training sessions so that he could become knowledgeable, he spent time arguing and repeating questions. His instructors and supervisors concluded that he was either not able, or not interested in, learning and adapting to Comstock's program.

One of the purposes of our training program, and of the standard 90-day evaluation period, is to decide whether individuals have the required competence and attitude to per-form well as an inspector.

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10. During Mr. Hendrickson's first or second week on the job, during an exchange with an instructor, he asked the in-structor why steel used in Comstock's program was not individu-ally marked for material traceability purposes, and why Comstock's steel was not separated'in the yard (i.e., prior to installation) according to safety classification. He referred to American Society of Mechanical Engineers (ASME) standards, and to his experience at WPPSS. His instructor explained to him that Comstock's scope of work at Perry was covered by the American Welding Society (AWS) Code, and not by the ASME Code, showing Mr. Hendrickson the applicable Comstock and CEI project 4 procedures. The instructor further explained that the AWS Code

'does not separate stee'l into various classes, as does the ASME P

Code; that all of Comstock's steel received and accepted for use at the site is purchased to the same requirements; and that, in contrast to requirements applicable to ASME steel, Comstock is not required to individually mark, or physically I

separate, its steel for material traceability purposes. Mr.

Hendrickson did not seem to understand the instructor's expla-nation. Also, the instructor knew that Mr. Hendrickson had l previously raised the same question with other supervisors.

After the discussion, the instructor came to my office to

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discuss the situation with me and Clarence Hart. Mr. Hart and I then met with Mr. Hendrickson and went through the same ex-planation he had previously been given. This time, Mr.

Hendrickson appeared to understand and accept the explanation.

Still, I told him that he was welcome to review applicable document.s further if he had questions. Over the next two weeks, there were periodic problems with Mr. Hendrickson argu-ing with instructors' explanations in a manner that was dis-ruptive to the other tr'ainees who were present.

Sequence Leading To Termination

11. On October 20, 1983, approximately two weeks after my discussion with Mr. Hendrickson, the following occurred. In a welding training class, Mr. Hendrickson raised with the two in-structors present the same material traceability question he had raised earlier with me and other Comstock supervisors, con-tinuing to make reference to the ASME Code and his experience at WPPSS. Even after the instructors attempted to carefully explain that the ASME Code, and the situation at WPPSS, did not apply, Mr. Hendrickson was not satisfied and continued to press the subject and disrupt the class, which was being held to train personnel in a particular Comstock procedure. At this point, because Mr. Hendrickson kept referring to the ASME Code, one of the instructors asked Mr. Hendrickson in a straightfor-ward manner if he was able to define the differences between Class I, II and III piping under the ASME Code. Mr.

Hendrickson replied belligerently that the instructor was

" intimidating" him. To avoid a confrontation, the instructor immediately left tha room and came to me to discuss the situa-tion. After the first instructor left, Mr. Hendrickson stated to the other instructor and the other members of the class that if he could not fit into the program he would like to be termi-nated. After discussing Mr. Hendrickson's conduct with Mr.

Hart and both instructors, and based on Mr. Hendrickson's conduct during the first three weeks of his evaluation period, I concluded that Mr. Hendrickson was unable or unwilling to be trained in Comstock's program and that he should be terminated.

As supervisors, we must have confidence that our inspectors can understand and properly implement their responsibilities. In Mr. Hendrickson's case, we simply lost confidence in his abilities and attitude.

12. After deciding to terminate Mr. Hendrickson, I in-structed my secretary to draw up the necessary termination forms, and I asked.one of Mr. Hendrickson's instructors to find Mr. Hendrickson and escort him to my office. A short time after the instructor left, and before the instructor contacted Mr. Hendrickson, Mr. Hendrickson came to my office stating that he had just been " intimidated" by his instructor in a training class, and that he wanted to discuss the " intimidation" with the NRC. This was the first mention Mr. Hendrickson made to me of wanting to contact the NRC. Clarence Hart and Mr.

Hendrickson's instructor came to my office shortly after Mr.

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Hendrickson arrived, and joined-the discussion. I told Mr.

Hendrickson in a friendly manner that he was more than welcome to meet with the NRC, but that the Resident Site Inspector was en vacation and that there were no other NRC site representa-tives at the site that day. We discussed his conduct in the class that day, and his previous conduct, and I told him that we had decided to terminate him because of his inability to adapt to Comstock's program at Perry. I told him he was free to discuss any matter with the NRC or CEI, and offered to call in the CEI Construction Quality Section Electrical Uni.t Super-visor, Jim Kerr. Mr. Hendrickson said he did want to talk to Mr. Kerr, who then came to my office at my request. Mr. Kerr discussed with Mr. Hendrickson, Mr. Hart, the instructor, and me, the steel traceability issue, and the exchange that had occurred in the training class that day. Mr. Kerr explained to I Mr. Hendrickson that Comstock was not violating requirements by l not individually marking, and segregating, its steel. Mr. Kerr also stated that he did not believe there was intimidation in-volved in the classroom incident, based on the facts presented by Mr. Hendrickson and his instructor concerning their ex-change. At the conclusion of this meeting, I reviewed with Mr.

j Hendrickson the termination forms which had been prepared, and discharged Mr. Hendrickson at that time. Prior to leaving my l office, Mr. Hendrickson indicated to me that he planned to

! complain to the NRC about the matters we had discussed (and 4

presumably about his termination).

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13. The newspaper article states that Mr. Hendrickson was terminated for asking questions, and because he asked to see the NRC. Neither is true. His request to see the NRC had nothing to do with his termination. The termination decision 1 was made prior to any statements by Mr. Hendrickson about con-tacting the NRC. Mr. Hendrickson was encour' aged to talk to the .

NRC. He was not fired for asking questions to understand his job, but because he was unable or unwilling to make the neces-sary effort to learn Comstock's program, and because his dis-i ruptions in classes were interfering with instruction of other inspector trainees.

The Allegation Regarding Poor Morale

14. The newspaper story quotes Mr. Hendrickson as saying that Comstock inspector morale was poor. No specifics are given. To my knowledge Mr. Hendrickson did not complain to

management about poor morale (either his own, or that of other i inspectors) while at Perry. I strongly disagree with the alle-gation. I also disagree with the charge that Comstock treats I

i its inspectors "like tools." I don't think the facts, as discussed in this Af'fidavit, support that charge. I want to i stress that Mr. Hendrickson was at the site a very short time

( and never performed an inspection. As the senior Comstock l

quality manager at the Perry site, I do everything possible to encourage open communications and to make sure that inspectors are well treated. As with any job, I hear many criticisms and 3

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suggestions from individual inspectors about a wide variety of r

topics, ranging from salary and benefits, to difficulties with procedures and personalities on the job. I make every effort

! 'to respond to all questions, as do the supervisors under my di-rection. While each of my inspectors is, I'm sure, not per-fectly happy with all aspects of his or her job, I don't think

} this is unusual on a job as l'rge a as ours. It is certainly not unusual to have terminated employees criticize the management that terminated them. In any case, we take all criticisms se-riously, whether made by present or former employees. In answer to the generalizations about " poor morale," there are not, based on my daily contacts with inspectors, any widespread morale problems among Comstock inspectors. This matter is further addressed in E20 of my Affidavit.

Gene F. Mathis l

15. OCRE's motion attaches an article from The Plain Dealer, dated November 23, 1983, discussing an interview with Mr. Mathis. Mr. Mathis is quoted in the article as making the following allegations: (1) that a cable tray, " filled with garbage, electrical wiring and welding materials," which he photographed, represented "a typical problem"; (2) that work ,

was done "that did not relate to engineering drawings";

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(3) that the drawings "are all wrong" (referring to cable trays); (4) that " pressure from CEI to keep the job on schedule causes work to be done without proper quality control checks,

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i and then requires the work to be redone after problems are found," *. hat there is " daily harassment frcm production," and that " quality control concerns were ignored if they slowed con-

struction"; (5) that "[t]his is one of the worst jobs for i

morale and turnover," and that "the best inspectors tend to l leave or get fired out of frustration"; and (5) that "proce-4 dures were changed without reason." These allegations are not I justified, for the following reasons.

The Reasons For Mr. Mathis' Termination

! 16. Gene Mathis began working for Comstock at Perry on i

February 22, 1982, and was terminated on October 14, 1983.

During his tenure at Perry, Mr. Mathis worked as a Level II inspector primarily in the areas of cable tray and conduit in-stallation. Mr. Mathis demonstrated good technical proficiency i as an inspector. However, as mentioned in the newspaper arti-i i cle, "his temper was a problem." Mr. Mathis' temper problem ,

was noted on all three written performance evaluations which Mr. Mathis received while at Perry (the evaluations are issued every six months), and was the subject of disciplinary action in September and November 1982, well before Mr. Mathis was ter-minated. After a series of incidents involving temper flare-ups with other workers, and with a security guard, Mr.

Mathis was warned in writing in November 1982 that he wculd be terminated for any further incidents involving serious losses of temper or fighting with other employees. Mr. Mathis'

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termination folicwed two incidents on October 14, 1983, neither of which had anything to do with quality concerns being ig-nored. The first involved Mr. Mathis' losing his temper and becoming belligerent toward several records clerks who Mr.

-Mathis felt were slow in retrieving some documents he was re-questing. Mr. Hart and one of Mr. Mathis' supervisors met with Mr. Mathis after his temper outburst and told him that his lead inspector would assist him with any records request problems, and that he should refrain from fighting with the records -

clerks or any other workers. Later the same day, a craft su-pervisor personnel came to Mr. Hart's office complaining about a disagreement involving Mr. Mathis on another matter. Mr.

Hart called Mr. Mathis to his office to try to settle the dis-agreement, but after a brief conversation Mr. Mathis became very hostile toward Mr. Hart, saying he did not like working for Comstock and that Mr. Hart could fire him because he could find another job. Because of these incidents, and previous i incidents of a similar nature (about which he was warned), Mr.

Mathis was terminated.

The Cable Tray Filled With Garbage

17. The cable tray photographs mentioned in the article are attachments to a nonconformance report (NR) generated by Mr. Mathis on October 10, 1983. The NR has been closed out.

The cable tray in question was in an area of the plant in which an unusual amount of construction was occurring, and was not i

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" typical" as stated in the article. One of Mr. Mathis' functions as a raceway inspector was to identify raceway areas containing excessive debris, which is exactly what he did in the ir. stance discussed in the article.

Work Not Relating To Drawings, And Drawings Problems

18. The November 23, 1983 newspaper article quotes Mr.

Mathis as saying that there were problems with " work that was done that did not relate to engineering drawings," and that "the drawings are all wrong," with reference to cable trays.

No specifica are given. There appear to be two issues raised.

The first, that there was work done that did not comply with the drawings, is a fact at Perry and every other nuclear plant.

Such nonconforming work is supposed to be identified by the inspectors. Mr. Mathis properly identified on inspection reports and on NRs instances involving work that did not relate to engineering drawings. Again, it was Mr. Mathis' job as an inspector to identify and document just such conditions. As to the suggestion that drawings were "all wrong," Mr. Mathis and other inspectors formally identified and documented various problems with the design drawings. These problems were primar-ily related to translating details and cross-references from master drawings to individual layout drawings used by Construc-tion and QC personnel in the field. Such problems are not uncommon in the nuclear electrical area, due to the quantity and complexity of information contained on the drawings. In

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response to findings of Mr. Mathis and other inspectors, a series of reviews of drawings problems was performed by 4

Comstock QA/QC management between April and September 1983, and corrective actions were implemented.

Production Pressure 4

19. Mr. Mathis states in the article that there is " daily harassment from production," and t;.at " quality control concerns were ignored if they slowed construction." I do not agree.

The inspection workload has been heavy during Mr. Mathis' em-ployment at Perry. There has also been a special effort to re-duce the inspection backlog in the electrical area. However, .

Mr. Mathis inspection records show that he actively identified nonconformances throughout his time at the plant. Mr. Mathis was never discouraged from documenting quality problems. In fact, in his February 1983 performance evaluation his supervi-sors. complimented him for doing an " excellent" job in the area of nonconformance documentation. A review of Mr. Mathis' in-spection reports indicates that he initiated approximately 68 -

nonconformance reports while at Perry. The number and type of NRs Mr. Mathis generated demonstrates that he was adequately identifying and documenting quality problems in his areas. I know of no situation in which production pressure, or heavy in-spection schedules, have interfered with the ability of Mr.

Mathis or other inspectors to identify and document quality problems. Since November 1981, Comstock's QA department has

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issued twelve stop work notifications. This is one measure of our commitment to take the necessary steps to fix quality problems, regardless of cost and schedule implications.

Bad Morale And Turnover

20. Mr. Mathis is quoted as saying that morale and turn-over were unusually bad. The largest turnover experienced by Comstock's QA department during Mr. Mathis' employment was in the fall of 1983, when there was a particularly heavy competi-tion from other nuclear plants for qualified nuclear electrical inspectors. Between September 1983 and November 1983, 14 inspectors left Comstock, out of a total of 51 inspectors employed during that period. Of these, seven were recruited i

away to work at other nuclear plants (Marble Hill, Midland, and the South Texas Project), which were heavily recruiting for electrical inspectors and offering special salaries and benefits. Another three inspectors voluntarily quit during this period because they and their spouses wanted to move to i

other parts of the country. One inspector left because he was unhappy with his salary. Three inspectors -- Mr. Hendrickson, Mr. Mathis, and one other -- were terminated. Other than this exceptional period, Comstock's turnover has not been excessive.

It-is undeniable that, during the time Mr. Mathis worked at Perry, many of Comstock's inspectors were upset with the NRC's and CEI's criticisms of their QA/QC effort following the NRC's electrical investigation in 1981 and 1982, and the issuance of

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the 81-19 Report. Also, Comstock's inspection program has been subjected-to an unusual degree of scrutiny by CEI and the NRC since that time. The 81-19 issues, and the Comstock issue in the NRC licensing hearings, have also received negative media attention. All this increased attention has, from time to time, adversely affected morale; and perhaps, has contributed to turnover.

Procedures. Changed Without Reason

21. Finally, the article quotes Mr. Mathis as alleging that " procedures were changed without reason." I do not know whether Mr. Mathis had specific procedures in mind when he made the statement to the reporter. In general, procedures are often changed because of engineering considerations unrelated to the QA/QC program. To the extent the QA department partici-pates in drafting procedures, this is done by quality engineers, not inspectors. Mr. Mathis and the other inspectors have been encouraged to give input, and have in fac.t given input. However, the inspectors do not have responsibility for writing, amending, or approving procedures.

Steve E. Balazs

22. OCRE's letter to the Licensing Board attaches an ar-ticle from The Plain Dealer, dated Ncvember 28, 1983, discuss-ing an interview with Mr. Balazs. Mr. Balazs is quoted in the article as making the following allegations: (1) that " serious electrical problems have not been repaired" and that "he was prevented from writing reports on the deficiencies"; (2) that "he found exposed wires in the motor control cabinets, plus a maze of unidentified wiring from-the reactor to the control room and hundreds of improperly nstalled lugs in electrical panels in the diesel generator rooms"; (3) that, by his estimate, "16 inspectors have been fired, quit or transferred in the last two months"; and (4) that he and other inspectors "got pushed out because we tried to do their job right." The allegations are not justified, for the following reasons.

Mr. Balazs' Resignation

23. Steve Balazs was employed by Comstock at Perry from September 29, 1981 until September 28, 1983, at which time he voluntarily left his employment with Comstock. While at the plant, Mr. Balazs primarily worked as a Level II inspector in the area of electrical terminations. In notifying Comstock of his resignation, Mr. Balazs made general statements about

" safety concerns," and not being able to write nonconformance reports. He mentioned nothing about "a maze of unidentified wiring from the reactor to the control room," as was mentioned in the newspaper article. Mr. Balazs also did not complain that he, or other inspectors, were being " pushed out," as was

. stated in the article. After Mr. Balazs notified Comstock man-agement that he was quitting, and that he had safety concerns, Mr. Balazs' supervisor and I, on separate occasions, requested Mr. Balazs to provide us with specifics, and asked Mr. Balazs m

to document any nonconforming conditions or safety concerns prior to leaving Comstock. He did not document specific concerns in response to our requests. The only two issues he verbally identified at the time of his resignation relate to alleged deficiencies in diesel generator control panels and in motor control cabinets, which are both mentioned in the November 28, 1983 newspaper article.

Motor Control Cabinet Wiring Issue

24. Mr. Balazs' first concern, described in the newspaper article as " exposed wires in the motor control cabinets," was documented by a'Comstock inspector other than Mr. Balazs, and was properly handled. The problem arose in October 1982, in connection with some electrical testing that'was performed by the Project Organization within the motor control cabinets. In conducting the tests, some wires had to be moved to provide access to different internal sections of the motor control cabinets. When the wires were moved, some of the wires became exposed. The exposed wires were identified on three Comstock inspection reports, all dated October 4, 1982. The physical work to co'rrect these items was completed in November 1982.

Two of the inspection reports were closed on November 11 and November 12, 1982, respectively. The third inspection report was closed on February 4, 1983. Thus, the matter was appropriately identified and corrected.

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25. The November 28, 1983 newspaper article quotes Mr.

Balazs as saying, in connection with the motor control wiring issue, that "he wanted to write a report about the problem and was told to leave it alone." The articles states "NRC

. inspectors found the problem three months ago and Balazs was blamed for having approved it in the first place." I. have checked with Mr. Balazs' previous supervisors, and can find no evidence to support these statercents. In any case, as I.have indicated, the matter was adequately documented and reviewed.

Diesel Generator Control Panel Electrical Problems

26. In the November 28, 1983 newspaper article, Mr.

Salazs is quoted as saying that "he discovered hundreds of lugs

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were installed improperly in the diesel generator areas," and that all the lugs "should be replaced because they could cause a fire or cause equipment to malfunction." He is also quoted as saying that "it was five months before this was written as a nonconformance report and then only after the problem was found by an official working for CEI." The statements are inaccurate and misleading. The facts are as follows.

27. The diesel generator control panels mentioned by Mr.

Balazs were supplied to CEI by General Electric. After the panels had been placed at their location within the plant, General Electric, not Mr. Balazs, identified workmanship

._ deficiencies with the lugs located in the panels. General Electric subcontracted Comstock to perform the necessary repair

i work on the lugs, and provided Comstock with two engineering i

change documents describing the lug deficiencies and prescribing the repair work to be performed by Comstock.

General Electric instructed Comstock's QA/QC management that, if Comstock inspectors identified any concerns with the panels that fell outside the~ scope of the repair work being performed on the lugs, these were to be documented on inspection reports

- and submitted to General Electric for their QA/QC.and engineer-ing evaluation. This was explained to Mr. Balazs, who was assigned the QC inspection task of verifying the adequacy of the lug repair work.

28. While performing his inspections in February 1983, i

Mr. Balazs identified vari us items in the panels, other than the lugs being repaired, which Mr. Balazs believed were defi-

! cient. The items of concern-were not associated with the <

GE-subcontracted repair work, and were technically under GE's QA/QC responsibility. It had been previously agreed that Comstock would document such concerns for GE's review and con-sideration. Therefore, Mr. Balazs was told by his management to document his concerns on inspection reports. This was done t

on February 24, 1983. Comstock then held a number of meetings with General Electric regarding the inspection criteria to be used in evaluating whether the items of concern constituted nonconformances. Comstock also discussed the issue with Project Organization.CQS personnel. Based on the discussions between Comstock and GE, and after discussions between Comstock

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and the Project Organization, Comstock and the Project

't Organization jointly concluded that the conservative approach would be to write nonconformance reports, and these were issued under Mr. Balazs' signature on April 5, 1983. The NRs have not been closed out, but are being reviewed and tracked by the Project Organization, which has the responsibility for correc-tive action with regard to these items.

29. In short, Mr. Balazs' concarn was with items he iden-tified outside the area of the control panel lugs, not with the lugs themselves, which were 'previously identified by General Electric as being deficient and requiring repair. Mr. Balazs' concerns were all documented on inspection reports. The delay in drafting noncon'formance reports, which Mr. Balazs has criti-cized, is explained by the fact that the items technically fell under General Electric's design and QA/QC jurisdiction, not Comstock's; and General Electric's and Project Organization's input was required before deciding on the appropriate QA/QC disposition of the items. How. eve r, the items were properly identified and reviewed in accordance with Comstock's QA/QC e program.

l i

t I

Turnerer

30. Mr. Balass' statement in the November 28, 1933 nawapaper article regarding recent turnover of Comstock inspectors is answered in 1 20 cf this Affidavit.

Y l  %

Richard L. Bower p

subscri and sworn to before me

%is /9 ay of December, 1983.

4.e k '

NOTARY PUBLIC My Commission Expiresi

/ /- / 3 - / 9 77 ,

l l

24-

ATTACILMENT 1 A REMINDER

~

l Any employee having a concern about an activity that could i adversely affect plant safety is urged to contact his or he-l employer, or if the employee prefers, to directly contact the Nuclear Regulatory Commiazion.

Contacts can be made to your l supervisor, to the Quality Assurance Department of the.Dluminating Company, or to Senior Management of the Illuminating Company.

Contacts to the NRC can be made, l anonymously if desired, to the Resident Inspector at 259-3810, or to i the Region III Office of the NRC at (312) 932-2500. Region III will accept collect calls.

Reporting all safety concerns is essential to assure the safe construction and operation of the Perry Nuclear Power Plant.

The Bluminating Company

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RESUME RICHARD L. BOWER CLASSIFICATION Quality Control Manager EDUCATION William Byrd High S:hool Vinton, VA - 1965 Roanoke County Vocational School Sales, VA - 1964 - 1965 National Technical Schools - 1975 - 1976 U.S. Air Force - 9/65 - 3/69 Aircraft Technical School (C-130)

Aircraft Maintenance (C-130)

Aircraft Crew Chief (C-130)

EXPERIENCE July 1982 to L. K. Comstock Engineering.Co., Inc.

Present Perry Nuclear Power Plant Perry, OH Quality Control Manager - responsible for implementation of the site Quality Control program as applicable by contract documents and/or Nuclear Regulatory commission require-ments. Review and approve the Quality Con-trol program for completeness and effective-ness and revise as required. Administrative responsibility for the total electrical Quality Control program at the Perry Site representing L. K. Comstock Engineering Co.Inc .

October 1981 to Gilbert / Commonwealth July 1982 Enrico Fermi II Nuclear Project Monroe, MI I

Quality Control Inspector Level II, Electrical l

responsible for surveillance and inspection

! of Startup Electrical Testing. Reviewed completed Test Data records. Participated in the development and review of quality pro-cedures and instructions pertaining to sur-veillance and inspections.

l 1

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l

Resume Richard L. Bower October 1980 to Lord Electric Company, Inc.

October 1981 Everett, WA

~

Quality Assurance Administrator, Level III -

responsible for, but not limited to, the im-plementation of Lord Electric's Quality Assurance Program and Procedures and revise as required. Perform audits of Lord Electric's Quality Assurance Program and Procedures at the Project Level.

October 1978 to Fischbach/ Lord Electric Company, Inc.

October 1980 WPPSS Nuclear Power Project No. 2 Richland, WA Lead Field Engineer / Field Engineer - Lead Engineer for inside containment (Drywell)'.

Assignment of work activities to Field

- Engineers to support construction activities.

Responsible for, but not limiteff to, the following: Design of raceway sup. ports and raceway routing. Review of change notices from client's Engineer and verification that the necessary material to support the con-struction schedules are approved and availa-bl e. Assure that the necessary drawings are available for field use to support activities involved. Coordinate with CPM Engineer all schedules which require Engineering input Coordination and Monitoring of subcontractors who are interfacing with Fischbach/ Lord's l Construction activities.

March 1975 to Fischbach/ Lord Electric Company, Inc.

October 1978 Hanford No. 2 Richland, WA Quality Assurance System Status Coordinator Level III - assisted in the development of Quality Assurance / Quality Control procedures utilized at Washington Public Power Supply System Nuclear Project No. 2. Responsible for Quality Assurance Documentation. Main-tain Quality Assurance files and records for retrievability and audit purposes. Perform audits within Fischbach/ Lord, subcontractors, and vendors. Responsible for the status of equipment and systems. Acting Site Admini-strator in the absence of the Quality Assur-ance Site Administrator.

X Y__

I -

Resume Richard L. Bower Continued March 1975 to Quality Assurance /Ouality Control Field October 1978 -'

Supervisor Level ;I - responsible for super-vision of Quality Assurance / Quality Control Inspectors and for the indoctrination and training of new inspectors. Approve In-spection Reports and initiate Ncnconformance Reports and Stop Work Orders.as required.

Review construction and subcontractor's pro-cedures to insure compliance with contractual requirements. Maintain Quality Assurance filet and records in the absence of the

. System Status Coordinator. Acting Site Administrator.

January 1974 to Brown and Root, Inc.

March 1975 Brunswick StecT. Electric Plant SouthPort, NC Quality Assurance Electrical / Instrumentation System Turnover and Acceptance Inspector Level I - inspected systems, components, and documentation of Electrical / Instrumentation Systems for " Release for Test" and " Final Turnover" to client.

1969 to 1974 Piedmont Airlines Roanoke, VA.and Wilmington, NC Stock Room Supervisor - responsible in setting up stock room shipping, receiving, requisitions, and inventory of all aircraft components, parts, and ground equipment.

1965 to 1969 U.S. Air Force Crew Chief of C-130 Aircraft - 1967 - 1969 l

Phase Dock Inspector and Coordinator - 1965-l 1967.

' EC1

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