ML20211B944
| ML20211B944 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/17/1986 |
| From: | Shamblin D COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#486-1126 OL, NUDOCS 8610210230 | |
| Download: ML20211B944 (54) | |
Text
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UNITED STATES OF AMERICA USNPC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAA6 0CT 17 A1136 GFF.
j In the Matter of
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h COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456-0
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50-457-ok l
(Braidwood Station Units 1
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l and 2)
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REBUTTAL TESTIMONY OF DANIEL L.
SHAMBLIN Q.l.
Please state your full name for the record.
A.1.
Daniel L. Shamblin.
Q.2.
Who is your employer and what is your occupation?
A.2.
I am employed by Commonwealth Edison Company (CECO).
I am the Project Construction Superinten-dent for Braidwood Station.
I have held that position since May 1984.
Q.3.
Please state your educational background.
A.3.
I received a B.S.
in Civil Engineering from Michigan l
l Technological University in 1972, and an MBA from the University of Chicago in 1982.
I am a Regis-tered Professional Engineer in the State of Illinois.
Q.4.
Please state your professional work experience.
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I have been employed by CECO since July 2, 1972.
Between 1972 and 1973, I was assigned as a Construc-tion Field Engineer at CECO's Zion Nuclear Power Station.
Between 1973 and 1978, I was a Construc-tion Field Engineer at LaSalle and was responsible for Main Building construction.
In 1978, I became Staff Assistant to CECO Vice Presidents Byron Lee and Cordell Reed, where I performed a variety of duties.
My next assignment was as Project Coordinator for LaSalle County Nuclear Power Station, where I reported to the Manager of Projects.
My duties included coordination-and preparation of schedules and budget, as well as troubleshooting for major project problems.
I then served as Staff Assistant to the LaSalle County Station Project Manager.
My responsibilities included advising the Project Manager on construction related matters as well as assisting the Project Engineering Department during Unit 1 and 2 piping support design.
From May 1982 until January 1984, I served as LaSalle's Project Construction Superintendent, and was responsible for start-up construction support of Unit 1 and construction completion of Unit 2.
In addition to these duties, I assumed the respon-sibilities of the Project Field Engineering Manager
l s at Braidwood Station in April 1983.
I held both o.
l positions until January 1, 1984.
In January 1984, I left the LaSalle Project and assumed full-time responsibilities at Braidwood.
Q.5.
What is the purpose of your testimony?
A.5.
My purpose is to provide rebuttal testimony on several topics, including:
my involvement with the Comstock QC department, particularly as it relates to assertions that QC management was encouraged to emphasize the quantity of inspections over the thoroughness and quality of inspections; my involvement in Mr. Puckett's termination and in Mr. Seeders' transfer; and the actions taken to address the Comstock QC inspector concerns in the summer and fall of 1984 and the early part of 1985.
Q.6.
What is your responsibility in regard to the contractors at the Braidwood Site?
A.6.
As Construction Superintendent, I administer the Braidwood construction contracts assigned to the Project Construction Department, including Comstock and the other major on-site contractors.
This means that I oversee the production, engineering and quality departments in the assigned contractor organizations.
I implement the CECO Quality
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Assurance Manual procedures and monitor on-site contractor quality control' procedures and work performance to ensure the quality of construction.
I accomplish building quality into the construc-tion by first ensuring that skilled contractor engineers and craftsmen are employed on the work; that these personnel receive the appropriate training for their job; and that they perform their work to approved installation procedures.
I verify the quality of completed construction by ensuring that trained and certified quality control inspectors using approved inspection procedures inspect the construction work and by ensuring that the contractor's quality organiza-tions are independent of contractor production organizations.
I also assure that the contrac-tor's Quality Assurance organizations conducts audits and surveillances of their engineering, production and quality areas.
Q.7.
Is it appropriate for you, as the CECO construction superintendent, to oversee a contractor quality department?
A.7.
I believe it is.
As stated above, I am responsible for building quality into the construction and for verifying that quality has been built into the construction.
I recognize that quality must i
remain and function independent of engineering and a
production.
However, all three areas must function as a team to achieve successful completion of a project.
It is important that engineering personnel and craftsmen be indoctrinated with quality principles, so that the work is correctly performed in the first instance.
It is equally important that quality personnel be indoctrinated with the same quality principles and that they report back to the craft the results of QC inspections in timely fashion, so that adverse trends in craft work can be identified and corrected.
By oversee-ing all three areas I ensure that the proper checks and balances necessary for the contractor to produce a quality product are maintained.
My own management philosophy is that the Construction Superintendent must place equal emphasis on production and on quality.
When I took over this position at Braidwood in May 1984, my main goal was to assure that these separate functions in the contractors' organizations operated efficiently and harminously.
l Q.8.
Does your oversight of the contractor OC departments allow them to maintain sufficient independence of cost and schedule to ensure they perform thorough inspections?
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A.8.
Yes.
Maintaining sufficient independence from cost and schedule for a contractor QC department is achieved primarily by providing that the contractor's QC department does not report to the contractor's production department.
Comstock's site QC department reports to their regional QA department, which reports to their corporate QA department, which in turn reports to the head of Comstock Engineering, Inc.
Comstock's production department,'on the other hand, reports to L.
K. Comstock and Company.
Both companies are members of the Comstock Group.
As the owner's representative, I oversee both production and quality functions, and I see no conflict in my role.
My job is to assure both that the work is performed and that it is performed in a quality manner.
Successful completion of a project depends equally on both elements and my recognition of this determines my management style.
To complete these organizational checks and balances, CECO site and corporate QA conduct audits and surveillances of the contractor QC departments and also of my department.
CECO site QA does not report to me, Mr. Wallace or Mr.
Maiman, but to CECO corporate QA, which reports directly to Edison's Chairman and President.
Q.9.
Several quality control inspectors have testified that CECO pressured the QC managers at Comstock to emphasize quantity of inspections over thoroughness and quality of inspections in their supervision of the QC inspectors.
Are these assertions true?
A.9.
As I understand the assertions, they suggest that CECO was more interested in completing numbers of QC inspections than in assuring that these inspec-tions were conducted in a thorough and quality manner.
This is not true.
It is true that several problems existed in the Comstock QC department because of work backlogs, and it became my responsi-bility to resolve these matters in May 1984.
liowever, I have never taken any action to pressure Comstock QC management to emphasize the quantity of inspections over the thoroughness and quality of inspections.
Indeed, my past actions indicate otherwise.
Moreover, I am quite certain that my subordi-nates at CECO did not pressure Comstock QC management to emphasize the quantity of inspections over their quality.
I am equally certain that my superiors, Mike Wallace and Tom Maiman, did not impose any such pressure.
It was I and my staff, not Wallace and Malman, who participated in the day-to-day contacts with Comstock QC management.
Ilad such pressure been imposed, I would have known about it because of the close working relationship I had developed with Irv DeWald.
o O.10.
What were the problems confronting Comstock in May 19847 A.10.
I found that Comstock QC management was having difficulty coping with the existing inspection backlog problems.
They had not fully defined the dimensions of the work facing them.
As a consequence, they did not fully understand what theie manpower needs were, either as to the number of inspectors needed or as to the appropriate allocation of those inspectors.
The result was that current installation work had proceeded far ahead of the related QC inspec-tions.
In addition, the number of open ICRs and NCRs was increasing because craft rework needed to correct identified deficiencies and the.OC inspec-tions needed to close them out were not being performed.
Further, several ongoing reinspection programs were not progressing satisfactorily because of the lack of inspection support.
These matters concerned me because the lack of first line inspections created an expknding volume of installed work of indeterminato quality.
Also, because these inspections were not being kept current, adverse quality trends in the ongo-ing installation work might not have been identi-fled soon enough to be corrected in a timely o
fashion.
Finally, the increasing number of open NCRs and ICRs and the slow progress in completing various reinspection programs suggested that the Comstock QC Department was experiencing difficulty in managing their entire workload.
Q.11.
What action did you take first to help eliminate these problems?
A.ll.
I recognized that resolution of these problems required an in-depth analysis and reevaulation of the Comstock QC effort.
I also realized that this would take a few weeks to accomplish.
In the meantime, I took immediate steps to alleviate the obvious shortage of QC inspectors.
I arranged for l
the reassignment of four Sargent & Lundy QC inspec-tors to perform work for Comstock.
I informed Comstock of this step in a letter to Mr. DeWald on June 1, 1984 (Shamblin-1).
Q.12.
What did you conclude from your evaluation of the Comstock QC offort?
A.12.
I considered the alternatives of either suspending the safety-related production work until comstock eliminated the inspection backlog or continuing the work while simultaneously attempting to elim-inate the backlog.
I concluded that, with proper organization, Comstock QC could cope successfully i
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with both the work backlog and the need to keep up with inspections to support ongoing installation work.
I developed a plan with Comstock management that would enable them to address both matters.
I also concluded that unless positive results were realized quickly from the plan, it would be neces-sary to suspend work.
0 13.
Ilow did you and Comstock develop the plan for addressing the backlogs?
A.13.
I immediately held a series of meetings with Comstock management in order to understand the nature of the problems more fully and develop solutions with Comstock.
There were several categories of inspection backlogs.
These included inspections of welding and hanger configurations, junction boxes and small equipment, cable pan and conduit configurations and cable terminations and wiring revisions.
The focus of the discussions was a list of six priorities that I described to Comstock for the redirection of their QC work offort.
Based on the discussions, Mr. DeWald suggested a plan for meeting the first three priorities, which he outlined in a memorandum on June 5, 1984 (Inter-venors' Exh'ibit No. 12).
Mr. DeWald's plan
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included a schedule for eliminating the inspection
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backlogs.
All of the backlog inspection categories were targeted for completion in June and July 4
except for junction boxes and small equipment, which was targeted for September 1984.
4 Further discussions led to development of an l
agreed management action plan, with additional remedial steps being taken to permit the target i
date for junction boxes and small equipment to be advanced to July 1984.
I memorialized the details of this plan in a letter to Comstock on June 9, 1984 (Shamblin-2). I understand that this document has been admitted in evidence as Intervenors' Exhibit 8, but with the last page missing.
Attachment A to my letter outlined the priorities I had established for Comstock.
Attachment B set forth twenty action items which I developed to reorder, reallocate and reduce the workload on Comstock's QC department.
0.14.
What were the priorities you set for Comstock?
A.14.
I made the first priority the performance of first-line inspections on work already installed because I saw this as the most serious problem facing Comstock.
My second priority was the performance of inspections on newly installed work in order to prevent a new backlog from developing.
My third priority was placed on the inspections necessary to close outstanding ICRs and NCRs.
o My fourth, fifth and sixth priorities were on the inspections necessary to support ongoing reinspec-tion efforts.
0.15.
What were'your plans for implementing these priorities?
A.15.
The first priority of reducing the backlog of inspections on installed work was addressed in the action items Uet forth in Attachment B to my June 9, 1984 letter.
I directed a review of the then current inspection backlog of installation reports to identify installations that were either incomplete or completed against drawings that had subsequently been revised.
These installation reports were deleted from the backlog and returned to Production for work completion.
Both Produc-tion and Engineering were instructed to assure that installations were completed to the latest drawing revisions prior to issuing inspection requests to the Oc Department.
Other measures were directed to improving the efficiency of the OC inspection activity, by cross-training more inspectors and by reviewing work practices to climinate unnecessary activities.
Also, manpower resources were reallocated to support the backlog reduction effort.
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1 The second priority of keeping current with newly installed work was also addressed in Attach-ment B.
First, I directed reallocation of craft personnel to work on correcting deficiencies that were the subject of open NCRs and ICRs and'to work on nonsafety-related installations.
These actions had the effect of reducing the rate of newly installed work requiring QC inspection.
- Further, j
I recommended the increased use of in-process inspections to facilitate more timely first-line l
inspections.
The third priority of closing out open ICRs and NCRs was addressed by first directing craft to complete on a more timely basis the rework being i
j tracked by these quality documents.
Additional manpower resources were directed to this task.
i I
The number of ICRs and NCRs being generated were l
also reduced by issuing Field Change Requests j
where appropriato instead of improperly issuing ICRs or NCRs, by ascertaining the root causes for L
the large numbers of the ICRs and NCRs and taking 1
A appropriate corrective action to avoid recurring i
j deficiencies, and by imbuing craft personnel with an awareness that quality begins with doing the t
job right in the first place.
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The remaining priorities of improving progress in reinspection program activities were addressed by recommending the use of statistical sampling-where appropriate as an inspection technique and exploring whether S&L Engineering and craft could assist QC reinspection activities in nonessential areas of the reinspection program activity.
Q.16.
In your June 9 letter you state that " positive results...must be seen very shortly."
What did you mean by that?
A.16.
Comstock had been responsive to my request for action by submitting their June 5 plan.
- However, it was imperative that immediate improvement occur in order to avoid making the problem worse.
If this improvement was not realized very shortly after my June 9 letter, I was prepared, as indicated earlier in my testimony, to change my approach and suspend the safety-related production work.
Q.17.
Did you begin to see such improvement?
A.17.
Yes.
I held periodic meetings to monitor progress and I requested that LKC QC provide me with weekly status reports.
The purpose of these reports was to provide Comstock and CECO with data to judge whether we were accomplishing our objectives and to provide foodback information for formulating further improvements and action items.
Within the first few weeks of receiving these status reports, it became apparent to me that the situation was improving.
I recall that by June 25 I concluded that Comstock was making significant progress toward eliminating the backlog.
Q.18.
Did you use your periodic meetings with Comstock QC management to pressure them to increase improperly the number of inspections?
A.18.
No.
These meetings were constructive, not coercive.
In addition to Comstock QC management, Comstock Engineering and Production, CECO Project Construc-tion and our Site Quality Assurance Department participated.
We reviewed the status of progress with the backlog inspection effort, discussed ways to allocate our resources effectively, and reviewed further actions we might take to facilitate the effort.
As I explain later, when it became apparent that our original completion schedule had been s
optimistic or circumstances changed, I agreed to extensions.
I made it clear to Comstock at these meetings that maintaining the quality of the inspections was just as important as getting the job done.
Indcod, as further evidence of how important I felt it was that Comstock do a quality job, I asked Tom Quaka and Gene Fitzpatrick of our Site QA department to participate in these discussions.
Q.19.
Did you use the weekly status reports as tools to squeeze more production out of the Comstock QC department?
A.19.
No.
The periodic status report was merely one way for me to monitor whether or not our plan of action and the improvements we anticipated were being effectively realized.
If we could see positive progress with the backlog, it would be an indication that the plan was effective.
If progress did not meet expectations, that would be an indica-tion that we would need to take different action.
A very helpful feature of the status reports was that they provided disaggregated information for each inspection area.
If a status report indicated that a particular inspection area was falling behind, we could concentrate on that area to see if procedural changes, additional inspector cross-training or additional inspection personnel or outside resources might help.
For example, we have frequently found that by working with the procedure users (in this case, the QC inspectors) we have been able to effect changes that facilitated
'the installation or inspection process.
Q.20.
Was the backlog of inspections eliminated by the July 1984 target date?
A.20.
No.
It became apparent as I monitored progress that Comstock QC would not eliminate the backlog by the July 1984 target date for several reasons.
First, Comstock's schedule for resolving the backlog had assumed that they could hire a~certain l
number of additional qualified inspectors to assist in the effort.
Comstock was not able to obtain additional qualified personnel as rapidly i
as anticipated.
In addition, more time was needed than initially anticipated to complete the review l
of certification packages for OC inspectors who were being newly certified or being recertified.
1 This process added to the manpower shortage.
Second, some of the backlog inspections could not
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l be completed until Comstock QC obtained additional information from Comstock Engineering or CECO i
Engineering.
Further, additional uninspected work
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was discovered, thereby increasing somewhat the i
nunber of inspections requiring completion.
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For these reasons, and because I saw that i
Comstock was making reasonable progress towards completion of the backlog inspections, I agreed to l
l schedule extensions.
The result was that the l
backlog was climinated in September 1984.
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4 I was pleased with Comstock's effectiveness in dealing with this potential quality problem.
I sent Comstock a letter congratulating them on performing this task without sacrificing quality standards.
(Shamblin-3).
Q.21.
Mr. Seeders testified that during the summer of 1984 Ceco caused Comstock management to pressure the QC inspectors improperly to increase the-output of inspections.
Were you aware of Mr.
Seeders' allegation in the summer of 1984?
A.21.
Yes.
When I became aware of Mr. Seeders' letter of August 17, 1984, I asked Jim Gieseker to meet with him to try to understand his concerns better.
Gieseker wrote me two memorandums summarizing his meetings with Seeders.
I understand that these memorandums have been admitted in evidence as Applicant's Exhibits 92 and 93.
One of Mr. Seeders' complaints was a concern that pressure was being exerted on Comstock QC management.
Q.22.
What was your understanding, in August 1984, of the nature of Mr. Seeders' concerns about pressure?
A.22.
Mr. Seeders' letter of August 17 indicated that there was pressure to train new people.
I understood Mr. Seeders to be stressing the fact that many inspectors were anxious to be cross-trained to be eligible for pay increases and that Comstock's inability to train these people quickly was con-tributing to a pressure situation.
Mr. Gieseker o
indicated that Seeders was also concerned about pressure being imposed on Comstock QC management.
I concluded that Mr. Seeders was referring to the efforts to reduce the backlog as I have described them earlier in my testimony.
Q.23.
What action, if any, did you take with respect to Mr. Seeders' concerns about pressure?
A.23.
As I will explain later in my testimony, I was taking aggressive action to resolve'the training problem.
With respect to the question of pressure resulting from our efforts to reduce the inspec-tions backlog, I did not believe that undue or improper pressure was being exerted on Comstock QC management.
It seemed to me that Seeders was really complaining about the type of stress that normally exists whenever a priority task, such as reducing the backlog, is addressed.
Q.24.
How did you assure that your zeal to eliminate the backlog did not result in a drive by Comstock QC management to complete large numbers of inspec-tions even at the expense of the quality of the inspections?
A.24.
Ensuring that the quality of work that Comstock QC was performing would not suffer was just as impor-tant to me as ensuring that the work be performed on schedule.
I used a variety of means to assure myself that the quality of inspections was not
deteriorating.
I have explained that I involved Tom Quaka and Gene Fitzpatrick of Ceco Site QA in the backlog completion effort.
I asked them to independently monitor the quality of Comstock inspection work through their regular program of surveillances and audits and advise me of their findings.
During the summer of 1984, CECO QA conducted numerous surveillances and several audits of Comstock's work.
I specifically asked Fitzpatrick and Quaka whether they had confidence that Comstock was maintaining the quality of their.
inspections.
I understood that based on their audits and surveillances they did have such confidence.
In addition, I personally reviewed these audits and surveillances in detail.
They indi-cated to me that Comstock QC was performing in an acceptable manner.
The deficiencies in these reports were of a routine nature and were not numerous, and there were no problems with the great majority of the work.
In particular, CECO General Office QA performed a thorough audit of Comstock's implementation of its Quality Assurance Program in September 1984.
I found that the results of this audit were positive.
In fact, part of the overall assessment of the auditors stated that Comstock had undergone numerous per-sonnel, procedure and management changes in recent 1
t
l l,
months and that these changes appeared to be improving the implementation of Comstock's QA-program.
In addition to CECO QA surveillances and audits, I reviewed PTL unit concept inspection reports throughout the summer of 1984.
These reports, which were generally issued on a weekly basis, in my view corroborated the conclusion that the overall quality'of Comstock's work, including QC inspections, was being maintained.
All of these findings were reinforced by'my personal observations Jul the field.
Although I am not a certified electrical inspector, my 15 years of experience in the construction industry allow me i
to make an informed judgment about the quality of construction work, including electrical installa-tions.
During the summer of 1984 I'made it a practice to personally observe completed inspec-tion work in the field.
In no case did I find any evidence of poorly inspected work.
l In short, I had a variety of sources avail-l able to provide data on the quality of Comstock's inspection work.
I monitored these sources closely and found that they uniformly indicated the quality.of inspections was not deteriorating despite the significant additional effort being undertaken to eliminate the backlog.
l
- Q.25.
Did you take any other actions in response to Mr.
Seeders' letter of August 17?
A.25.
I took several actions.
As stated earlier, I asked Jim Gieseker to meet with Seeders to try to understand his concerns better.
Mr. Gieseker indicated in his memorandums of these meetings that Seeders was concerned about fear of losing his job because of his August 17 letter, about harassment he had experienced, and about deteri-orating inspector morale.
I told Gieseker at the time to explain that CECO was familiar with some of those problems, to explain what we were doing about them-and to emphasize that inspectors were free from the pressure of production schedules.
I also asked Gieseker to explain that Seeders' August 17 letter would in no way affect his job status.
Gieseker reported to me that Seeders indicated he felt much better after discussing the actions CECO was taking and said if he had any additional concerns he would raise them with CECO.
In parallel with this effort, I directed Irv DeWald to investigate the matters involving Seeders' work situation and.the alleged harassment he had experienced.
I also continued to take action to address the pay, training and working condition situations that were causing discontent among the inspectors.
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Q.26.
Did DeWald. conduct the investigation?
A.26.
Yes.
Mr. DeWald immediately commenced an investi-gation and verbally advised me that many of Seeders' statements simply did not reflect the situation at Comstock.
Based on this information, I concluded that there was considerable doubt about the credibility of Seeders' allegations and statements.
Mr. DeWald subsequently forwarded to me a copy of a memo he wrote on September 25, summarizing the results of this investigation.
Based on DeWald's conclusions, Gieseker's reports to Iae, and Seeders' statement that he felt better about his concerns, I concluded that no further action to' address his concerns about his personal situation was necessary.
Q.27.
Please explain the nature of the pay, training and working condition problems referred to in answer 25.
A.27.
I had been aware since the spring of 1984 that some inspectors were dissatisfied with their new pay structure.
It became apparent during the summer of 1984 that even though many inspectors had received significant salary increases, some of them were still unhappy because they objected to future raises being tied to obtaining additional certifications.
Moreover, some problems were i
experienced from the outset in implementing the program, which led to further inspector discon-tent.
Some new inspector hires were placed first in the training sequence for their initial certi-fications, so that they could be assigned.to perform inspections in the field.
Because the existing inspector workforce was required to conduct this training, their own training for additional certifications was necessarily delayed.
Furthermore, in July 1984, CECO established an upgraded standard for contractor QC inspector-certification procedures, which required contrac-tor procedure revisions and reevaluation of existing inspector certifications against these new procedures.
Both the training of new hires and the recertification requirements interfered with the cross-training of inspectors for addi-tional certifications, thus delaying their pay increases.
Several problems existed with respect to working conditions.
A fire had damaged and dis-rupted the Comstock QC offices in late spring 1984.
The temporary quarters were cramped and generally unsatisfactory, causing unhappiness among the inspectors.
Communication between Comstock OC management and the inspectors needed improvement.
a In my view management was becoming isolated from the inspectors because it was perceived as uncar-ing and not supportive of their needs.
Q.28.
What actions, if any, did you take to eliminate these problems?
A.28.
I met with Irv DeWald and others many' times through-out the summer of 1984 to explore what we could do to alleviate the delays in scheduling cross-training and in reviewing inspector certification packages.
We engaged in an expedited search for a replacement training coordinator to avoid delays in inspector. training.
Comstock regional and corporate management helped assemble, review and expedite the certifica-tion and cross-training packages that were submitted to CECO for approval.
I requested CECO QA to work overtime in order to complete sooner the review of the inspectors' certification packages.
Irv DeWald spent many late nights and weekends reviewing and finalizing the certification packages so that his inspectors could receive their raises.
In the fall of 1984, because of complaints Irv received from inspectors, he convinced his corporate manage-ment to grant the pay raise upon approval of an additional certification by Comstock's Level III reviewers, rather.than waiting until CECO's OA department had reviewed and accepted the certifica-tion package.
I directed'that additional facilities be provided to improve the temporary offices used by the QC inspectors and directed construction forces to expedite the restoration of the LKC offices so that we could return the inspectors to a single office.
When I learned that the inspectors wanted a kitchen unit in their offices,.
I authorized one to be installed.
When I learned that inspectors were complaining about the air conditioning system in their offices, I directed that priority be given to fixing it.
We'took a number of steps to improve communi-cation between QC management and the inspectors, which appeared to be a general problem.
For example, we made a special effort to recognize the inspectors' accomplishments through a CECO-sponsored party held at the completion of the backlog inspection effort.
I also suggested that l
.the individual accomplishments of QC personnel be recognized at the weekly QC meetings.
l In addition, I encouraged increased field involvement by OC management in walking throughout the plant and talking to inspectors.
Along with this, I encouraged managment to obtain feedback from QC inspectors about' inspection procedure revisions and practices and to otherwise involve them in training activities and procedure develop-i ment and revisions.
Finally, Comstock attempted to encourage communications further through resump-tion of the departmental meetings which had been suspended because of the fire and remodeling.
I was informed.that at these meetings, ways of improving the QC organization and the working relationships among personnel were discussed.
Positive feedback for goal accomplishemnt was provided to inspectors by posting weekly and monthly status reports for all inspection areas.
My view is that morale is improved when individuals participating in a team effort are kept informed of the group's accomplishments.
Finally, I directed Irv DeWald to reemphasize to the inspectors that their work should be per-formed independently of any pressures of production.
I wanted to make sure they understood that while we had schedules to' meet, quality was never to be sacrificed to mbet those schedules.
Irv conducted such a training session in September 1984 and supplied me with a log of the attendees.
In an October 4, 1984 letter to Mr. Wallace,
- I outlMned the hetions taken by Comstock QC manage-ment a[td Project Construction Department management to address these problems.
Some of the efforts outlined in that memo had been underway for some time.
A copy of that letter, which has been marked as Applicant's Exhibit 118, is attached as Shamblin-4.
Q.29.
Was the certification log-jam broken?
A.29.
Yes.
By the end of 1984 we saw significant in-creases in the number of certifications per in-spector, and a further significant increase had taken place by May 1985.
These advances were achieved despite a substantial increase in the number of inspectors during that period.
The following tabulation summarizes this.
Average Number Number of Number of of Certifications Inspectors Certifications Per Inspector Jan 84 54 103 1.9 Jan 85 62 167 27 May 85 77 251 3.3 Q.30.
Do you believe your efforts to alleviate discontent about pay and working conditions were successful?
A.30.
I believe that we had success in resolving the working condition problems.
We had some success in resolving the pay concerns insofar as inspectors were now able to attain their pay increases through the certification process.
- However, during the same period I was aware that there was increasing tension in the QC department at Comstock because of the upcoming union election.
The efforts to unionize the Comstock QC inspector workforce-sparked a good deal of emotion.
Comstock management opposed the idea and there was a split among the inspectors.
Many of them were quite vocal in either their support or opposition to the union.
Issues involving pay, work rules and management rights were central to the controversy.
Under these circumstances, I decided that CECO should refrain from further involvement in these issues until after the election.
Q.31.
Did the inspectors vote in favor of the union?-
A.31.
Yes, a vote was held in late November 1984 in favor of the union.
However, the union was not certified as the official representative of the inspectors until April 10, 1985.
The delay in certification was due to appeals taken by Comstock and one inspector to the National Labor Relations Board contesting the election results.
Q.32.
Did the question of inspector dissatisfaction with pay, training and working conditions come to your attention after the union election?
A.32.
Yes.
Quality First conducted baseline interviews with the Comstock QC inspectors in mid-February 1985.
Among other matters, those interviews identified continuing discontent among some inspectors on these issues.
Q.33.
Did you take any action on these matters?
A.33.
No.
The status of the union was indeterminate in February 1985 because of the pending appeals to i
the NLRB.
As I testified earlier, I did not believe it was proper for CECO to become involved in these matters involving the union.
t
_~ _..
Q.34.
Did you ever threaten Comstock management with the loss of the contract if the production of Comstock's QC Department did not improve?
A.34.
No.
Since May 1984, I have been generally satis-fied with the performance of-Comstock's QC Department.
Q.35.
Are you aware of any other CECO management official who may have threatened such action,~ such as Mr.
Maiman or Mr. Wallace?
A.35.
No.
t 0 36.
Why was some work on Braidwood Unit 2 given to another contractor?
A.36.
In November 1985, the remaining electrical raceway work in the Braidwood Unit 2 Reactor Containment, Main Steam Isolation Valve Rooms and Main Steam Tunnel was assigned to Gust K. Newberg Co. Not all of the Unit 2 electrical construction work was assigned to Newberg.
The portion that was assigned was essentially structural in nature, consisting of the erection of auxiliary steel, hangers, cable pan,. conduit and junction boxes in the Unit 2 Reactor Containment, Main Steam Isolation Valve Rooms and Main Steam Tunnel.
Comstock retained this type of work in the Unit 2 auxiliary building and turbine building.
Comstock also retained the L
more traditional electrical work, such as cable pulling, terminations and electrical testing support.
I I took this action because in late 1985 Com-stock was the busiest of the contractors.
Comstock had the most Unit 1 work remaining of any of the major contractors.
This is typical of the final stages of a nuclear power plant project, because the electrical work is the last to be installed.
Com-stock's work was therefore on the critical path for completing the construction to meet the fuel load schedule.
In addition, Comstock management had substantial involvement in the ongoing licensing hearings.
Consequently, with Comstock management being required to devote so much attention to Unit 1 and the licensing effort, I concluded that CECO could minimize the risk of failing to meet the Unit 2 schedule by bringing in a different contrac-tor.
Newberg had essentially completed its primary scope of work and therefore had an experienced man-agement team which.could be exclusively devoted to the Unit 2 installation effort.
The decision to assign a portion of the electrical work to Newberg was a prudent one.
I did not take this action because I was dissatisfied with Comstock's performance, and in particular with the performance of their QC department.
L. K. Comstock management understood our decision as a sound business deci-sion for the project at the time it was made.
I should emphasize the fact that BESTCo provided QC. inspectors to both Comstock and Newberg.
Thus, the QC inspectors were not affected by the-reallocation of the work.
Q.37.
Did you participate in the decision to terminate Mr. Puckett?
A.37.
Yes.
On August 27, 1984 I met with Jim Gieseker and Irv DeWald and we discussed Worley Puckett's termination.
Since I had reviewed Mr. Puckett's resume at the time he was hired and had approved his hiring, I was requested to review the basis for his termination.
3 8.
Did you concur in the decision to terminate Mr.
Q Puckett?
A.38.
Yes.
Q.39.
Mr. Puckett testified that he was fired because Comstock and CECO believed he had raised too many safety concerns.
Did this form any part of the basis for your judgment?
A.39.
No.
My judgment was based on information I received from Jim Gieseker and Irv DeWald.
From this information I concluded that although Mr. Puckett was able to identify potential problems in Comstock's welding program, he was not effective at either problem definition or problem. resolution.
a Prior to the August 27 meeting, Mr. Gieseker described to me a meeting which he had attended with Mr. Puckett on August 22.
I understood that the meeting was convened with Sargent & Lundy personnel and the CECO site GA Level III to resolve technical concerns raised by Mr. Puckett.
Mr.
Gieseker explained to me that Puckett agreed with the technical analysis and resolution reached at the meeting.
Nonetheless, the next day, Puckett acted as if the meeting had never taken place and renewed his previous concerns.
I concluded that he was unable to participate effectively with people who were supposed to be his peers in resolv-ing technical problems.
In addition, at the August 27 meeting, Mr.
DeWald stated that Mr. Puckett wasn't performing up to his expectations of a Level III welding inspector, that Mr. Puckett had not been certified since he had failed his practical examination, and that he hadn't proven himself during his 90-day probation period as someone who could meaningfully contribute to the solution of problems in the LKC welding program.
Comstock needed a Level III welding inspector who could function in a management position and take charge of their welding program by resolving
=.
problems that might arise.
I had authorized the hiring of Mr. Puckett because my review of his resume had suggested that he could fill such a I
position.
However, based on the information provided by Gieseker and DeWald, I concluded I was i
mistaken anc concurred in DeWald's recommendation that Mr. Puckett be terminated.
Q.40.
Did you participate in the decision to transfer Mr. Seeders from the Comstock Q.'C.
Department to the Comstock Engineering Department in late September 19847 A.40.
Yes, I recommended this course of action to Comstock's QC management.
I i
O.41.
Mr. Seeders testified that he was involuntarily i
transferred because of a letter he wrote to Mr.
DeWald on August 17, 1984.
Did this letter form part of the basis for your recommendation?
A.41.
No.
Q.42.
What was the basis for your recommendation?-
A.42.
I reviewed Comstock's reasons for terminating Mr.
Seeders, and because his work performance was substandard, I believed that termination would be justified.
I also believed, however, that Mr.
Seeders might be able to perform satisfactorily in i
a less challenging position.
I knew that Comstock f
was hiring additional personnel for their Engineer-i l
ing Department.
My understanding was that these
. o personnel.would be filling essentially clerical positions, such as document' control and tracking the status of construction work.
These positions required a person who was familiar with the Braid-wood site and with Comstock's organization and operating procedures.
Mr. Seeders had this knowl-edge and he seemed an obvious candidate for one of these positions.
The alternative would have been hiring a new person and training him from scratch.
Mr. Seeders accordingly was transferred to Comstock's Engineering Department in the capacity of an engineering clerk with no decrease in pay.
Some time later I inquired as to Mr. Seeders' performance in the Engineering Department.
I was told that he was doing quite well.
J
I Shamblin-1
-N Comm:nwealth Edis:n Co.
Os
) Braidwood Station RR 1, Box 81 Braceville, IL 60407 Telephone 816/458-2801 7
June 1, 1984 BR/PCD 84-86 L. K. Comstock Company Braidwood Project Site Braceville, IL 60407
Subject:
Braidwood Station - Units 1 & 2 Quality Control Inspector Assistance Attention:
Mr. Irv DeWald Quality control Manager
Dear Mr. DeWald,
This letter documents an agreement to provide L.K. Comstock Company (LKC) with additional " loaned Servant" quality control inspection personnel.
Additionally, since these personnel are already certified as Level III source inspectors and hold AWS Certified Weld Inspector or Certified Associate Weld Inspector cards, certain of the training requirements outlined in L. K.
Comstock procedure can be waived and/or reduced as outlined below.
Four (4) Sargent & Lundy " Loaned Servants" (Messrs, M. Provenzano, S.
Kleven, P. Kosiniak, and C. Watson) are assigned to LKC for the purpose of performing current backlog and in-process field inspections. Commonwealth Edison is attempting to acquire additional Level III personnel for assignment to LKC. Messrs. Provenzano and Kleven are currently working with LKC and other site contractors on the QC Inspector Reinspection Program. This program has been stopped and these people will be available until the program work continues at a later date.
The above four (4) individuals must be certified as LKC Level II Inspectors. The below minimum qualification and training requirements must be met for these individuals.
1.
ANSI N45.2.6-1978 Level II education and experience requirements.
2.
LKC quality program familiarization training requirements as designated by the LKC QC Manager.
3.
Eye test requirement.
4.
One (1) hour formal lecture in area of certification.
i t
Shamblin-1 9
i 5.
Eight (8) hours lecture / demonstration and mock inspection in area of certification (Braidwood Site 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> mock inspection requirement is being waived since these four (4) individuals have been performing overview inspection of LKC work and are currently certified as Level III source inspectors and hold AWS Certified Weld Inspector or Certified Associate Weld Inspector cards.).
6.
Pass General Inspection Proficiency Test, Specific / Practical exam and Quality Assurance Exam in area of certification.
4 -
This letter shall also become part of these individuals certification
^
package.
Please initiate actions to certify the four (4) individuals. Contact the undersigned if any questions or problems need further action.
Very truly yours, A._J1LL D D. L. Shamblin Proj Construction Superintendent Braidwood Station Reviewed and Concu T. E. Quak [
]s Quality Ass rance perintendent cc: T. E. Quaka C. A. Mennecke L. Tapella E. R. Wendorf F. Rolan - LKC R. Kurtz - S&L M. Provenzano - S&L S. Kleven - S&L P. Kosiniak - S&L C. Watson - S&L D. Gallagher - S&L (0542a)
O
f Commonwealth Edis:n Ca.
Shamblin-2
~
Braidwood Station i
R R 1, Box 81
/ Braceville, IL 60407 s
j Telephone 815/458-2801 June 9, 1984 BR/PCD 84-99 L. K. Comstock & Company, Inc.
Braidwood Project Site Braceville, IL 60407 Attention.
Mr. F. Rolan Project Manager Mr. I. DeWald Quality control Manager
Subject:
Braidwood Station - Units 1 & 2 Sargent & Lundy Specification F/L-2790 Electrical Installation Work
Reference:
(1) Comstock Engineering, Inc. Memorandum (I.F. DeWald) to Commonwealth Edison Company (C. Mennecke), Control No.
84-05-10-05, dated May 18, 1984.
(2) Comstock Engineering, Inc. Memorandum (I.F. DeWald), Control No. 84-06-05-06, dated June 5, 1984.
Gentlemen:
This letter confirms a series of discussions and meetings held with you and L. K. Comstock & Company, Inc. (LKC) Management in the past three (3) weeks regarding the large backlog of uncompleted quality control inspection work. Additionally, this letter outlines a number of Action Items assigned to L. K. Comstock (LKC) and Commonwealth Edison Company personnel. Completion of these various Action Items should improve LKC's ability to maintain timely quality control inspection of ongoing work activities, yet complete various reinspection and retroinspection programs.
/
Commonwealth Edison Company is very concerned about the large existing backlog of uncompleted quality control inspections. Current records show this backlog at over 6000 field inspections not completed. Reduction of this backlog must be the first priority of LKC Production, Engineering and Quality control personnel. LKC has instituted numerous actions to address our concerns. These actions include adding quality control supervisory and field inspection personnel and shifting present emphasis from reinspection type programs to current work. The results of these actions have yet to be totally realized. Training of these new personnel has not been completed in many cases. Additionally, during the week of June 4, 1984, Regional and Corporate quality assurance / control management came on site to assist in the planning and implementation effort for further actions to address the current backlog.
Shamblin-2 LKC has requested additional time to reduce the current inspection backlog. We concur with their request, but positive results (i.e. significant current inspection backlog reductions) must be seen very shortly. The plan
{
presented by Reference (2) represents positive results if implemented as presented. Additionally, through discussions with you, Commonwealth Edison Company understands this plan has already been modified as stated below to improve the junction box and equipment inspection completion date.
(1) Four (4) additional inspectors have been assigned for training and certification in the Junction Box and Equipment areas.
(2) Certain additional design and status information related to junction boxes and equipment has been provided by Project Construction Department personnel to LKC Quality Control Department. This information should result in a decrease in QC research time and resultant increase in inspections per day completed. Additionally, 4
this information should assist in determining those non-safety junction boxes and equipment not requiring detailed inspections.
4 overall, it is expected the above actions will result in completion of j
junction box and equipment inspections in July 1984.
LKC will reflect this schedule improvement in this plan document once the above improvements are implemented.
Note 6 of Reference (2) stated the Phase II document review is not j
included in this schedule. We accept this conclusion for the present. We request that as soon as necessary personnel become available, this retroinspection program be completed. Additionally, PCD engineers will work j
with you to ascertain if further outside resources can assist the restart of this program sooner.
LKC is to report every Monday to the Project Construction Superintendent on previous week progress. A meeting has been established for June 25, 1984 at 3:00 p.m. in the Project Construction Superintendent's office to review with you the implementation progress and any further actions necessary.
Additionally, it is expected LKC Site management will call upon Regional and l
Corporate management as necessary to assist in the above efforts.
i The attachments (Attachment A & B) to this letter outline agreed i
priorities and Action Items which will be reviewed in future Commonwealth Edison Project Construction and Quality Assurance and LKC Production, Engineering and Quality control meeting.
t Very truly yours,
_.D L. %1L DLS/kje D. L. Shamblin j
(0553a)
Proj. Construction Superintendent Braidwood Station ec:
M. J. Wallace E. E. Fitzpatrick j
G. E. Groth C. A. Mennecke T. E. Quaka R. Anderson - LKC j
T. Paserba - LKC R. Marino - LKC I
Shamblin-2 Attachment A Jtine 9, 1984 Priorities - LKC Ouality Control Effort Priority Description 1
Incompleted Field Inspections (Current Backlog) 2 Ongoing Work Activity Field Inspections 3
Field Inspections Necessary to Close ICR's/NCR's 4
Field Inspections Resulting From the Phase II Documentation Review 5
Field Inspections Resulting From the WANG Installation / Inspection Status Effort 6
Field Inspections Related to All Other Reinspection and Retroinspection Efforts i
i l
l (0553a)
Shand)lin-2 e
Attachment A June 9, 1984 Priorities - LKC Ouality Control Effort Priority Description 1
Incompleted Field Inspections (Current Backlog) 2 Ongoing Work Activity Field Inspections 3
Field Inspections Necessary to Close ICR's/NCR's 4
Field Inspections Resulting From the Phase II Documentation Review 5
Field Inspections Resulting From the WANG Installation / Inspection Status Effort 6
Field Inspections Related to All Other Reinspection and Retroinspection Efforts (0553a)
l Shamblin-2 o
Attachment B June 9, 1984 I
Action Items - LKC and Commonwealth Edison 1.
Review the current inspection backlog for those uncompleted installations to the latest drawing revision where installation reports have been turned into Quality control for inspection. These installation reports shall be returned to Engineering and Production tor further installation work.
Action: LKC Production, Engineering and QC 2.
Review the current inspection backlog for those installations currently shown as requiring quality control inspection, which have inspection work completed. This situation exists due to the lack of a sufficient tracking system of installation reports versus completed quality control inspection.
Action: LKC Production, Engineering and QC 3.
Initiate or improve LKC Production and Engineering control systems to assure that installations are complete to the latest drawing revisions prior to request for final quality control inspection.
Action: LKC Production'and Engineering 4.
Improve the LKC Production control systems placing increased emphasis on first-line supervirion (i.e. craft foremen and general foreman) responsibility for quality of the product and assuring the product meets quality standards prior to request for inprocess and final quality control inspection. The use of incentives for performing quality work may be part of this program improvement.
Action: LKC Production and Engineering 5.
Explore other measures whereby LKC Production and Engineering personnel can perform functio.s currently being performed by Quality control.
Quality control cou.1 then perform an overview (i.e. statistically based) function. Assistance from Corporate and Regional management (Production, Engineering and Qualiti C.'ntrol/ Assurance) should be included in this review effort.
Action: LKC Production, Engineering and QC (0553a)
Shamblin-2 6.
Undertake a joint Production and Engineering effort to ascertain the root causes for the large number of ICR's and NCR's currently being initiated. Additionally, it is commonwealth Edison's perception that ICR's and NCR's are being generated in lieu of a Field Change Request (FCR), thus needlessly distorting the ICR/NCR numbers. Work with CECO PCD-Electrical to report deficiencies and non-deficiencies on correct documents.
Action: LKC Production, Engineering & Ceco PCD Electrical 7.
Undertake a " quality awareness" program at the craft level including the use of incentives and disciplinary actions. We suggest the discussion of quality workmanship be made part of weekly safety meetings. An increased emphasis on "doing the job right, the first time" should be presented.
Action: LKC Production and Engineering 8.
Crosstrain Quality Control field inspection personnel to improve personnel availability and flexibility.
Action: LKC QC 9.
QC Supervisors should review the actual work practices of field inspection personnel with the goal of increasing inspector productivity and resulting inspection output.
j Action: LKC QC 10.
Explore whether S&L people can perform the necessary research effort regarding welders not qualified to 1" plate (i.e. 3/4" thickness limit) or write CECO NCR to disposition.
)
Action: Jim Purrazzo j
PCD Electrical i
11'.
Segregate those inspections required in DG Room for possible special effort to closeout.
3 Action: LKC Engineering and QC 12.
Explore Production personnel performing kellum group inspection and rework with statistical based overview by LKC Quality Control.
l Action: Jim Putrazzo PCD Electrical 13.
Explore Production personnel performing junction box "0" - ring / splash guard inspection with statistical based overview by Quality control.
Action: Jim Purrazzo PCD Electrical (0553a)
Shamblin-2 14.
Explore S&L performing 1" separation for pan with side of hanger review.
Action: Jim Purrazzo PCD Electrical 15.
Establish meeting between LKC/PCD/ Midway to ascertain if different priorities for painting can be established.
Action:
D. L. Shamblin PCD Supt.
16.
Explore S&L or PTL performing 4" x 6" x 1/2" plate lamination inspection.,
Action:
T. Quaka/J. Purrazzo QA Supt./PCD Elect.
17.
Ascertain exact junction box and equipment inspection requirements and other methods / assistance that can be given to improve schedules.
Action: Jim Purrazzo PCD Electrical 18.
Assign four (4) Sargent & Lundy " Loaned Servant" personnel currently working for PCD to LKC.
Certify as Level II inspectors for inprocess and ongoing work activities.
Acticn:
D. Shamblin/T. Quaka PCD Supt. / QA Supt.
19.
Review current need for QA Department hold point to review ANSI N45.2.6 inspector certification packages. Until such time as hold point removed, effect quick review turnaround of packages.
Action:
T. E. Quaka QA Supt.
20.
Explore rescheduling Unit 2 penetration work to a later date.
Action:
C. A. Mennecke PCD Electrical
/
(0553a)
Comm:nwealth Edistn C2.
Shamblin-3.
Braidwood Station R R 1. Box 81 Braceville, IL 60407
?-
Telephone 815/458-2801 p
- b September 25, 1984 BR/PCD 84-282 L. K. Comstock & Company, Inc.
Braidwood Nuclear Power Station Braceville, IL 60407 Attention:
Mr. F. Rolan Project Manager Mr. Irv DeWald Quality Control Manager subject:
Braidwood Station - Units 1 & 2 Sargent & Lundy Specification F/L-2790 Electrical Installation Work
Reference:
BR/PCD 84-99, dated June 9, 1984
Dear Mr. DeWald,
Commonwealth Edison company wishes to recognize the accomplishment achieved by L. K. Comstock Engineering, Inc. Quality Control personnel with the completion of the backlog inspections. The reference letter above outlined for your group a very formable task in June, 1984. Your personnel rose to the task and completed the assignment in a professional and quality manner.
It is through the dedication and hard work of yourself, your management and supervisory personnel and individual quality control inspectors that Braidwood Station will be completed and receive a license. We thank you for your efforts. Please relay our thanks to your personnel.
Very truly yours, n.'a0 L. SUL D. L. Shamblin Proj. Construction Superintendent Braidwood Statior.
DLS/kje (0893a) cc:
M. J. Wallace C. A. Mennecke j
G. E. Groth J. W. Gieseker F. Rolan/LKC
W, Shamblin-4 7-wo. reg I 77 % stru 4 J'
s nt n co inn,m T. M 8 3 a
w wm. w ~
ef.ri w sac
Subject:
Braidwood Station - Units 1 & 2 94 # e L. K. Comstock Engineering Incorporated Quality control Inspector M Ihl Morale Concerns Mr. M. J. Wallace, I wish to report to you regarding the actions taken by L. K. Comstock Engineering, Inc. management and Project Construction Department to address the apparent morale problems with the L. K. Comstock Quality Control Inspectors. These morale problems were identified in August, 1984, through various sources.
I believe that the management attention given to these concerns has been effective in improving the overall morale of the L. K.
Coastoex Quality control staff. While we will never be able to satisfy every individual I believe the actions are responsive to the concerns.
L. K. Comstock Engineerine Incorporated InDrovements Specific improvements undertaken include the following.
1.
A kitchen unit was installed in the Quality Control area.
1
/2.
An afterhours pizza party was held in recognition of the effort in l
completion of the inspection backlogs.
l 3.
A picnic was held in late September for all L. K. Comstock and their families.
i 4.
L. K. Comstock and Company, Inc. corporate personnel were brought in to help review and expedite the Q.C. Inspector certification package preparation and reviews.
5.
L. K. Comstock and Company Inc. corporate management visited the job site and spent time explaining the benefit packages to the Quality control Inspectors.
6.
The Quality control Inspectors involved in the backlog inspections have bpen put into training or scheduled for training.
7.
-The Site Quality Control management personnel have evaluated ways to improve their every day working relationships with the Quality control personnel including management training courses.
8.
All Quality control personnel are row back in the same area after a restoration from the fire at the L. K. Comstock offices.
.c
Shamblin-4 9.
There is increased field involvement and walking throughout the plant by Quality Control Department management. These walk arounds are aimed at assisting the Quality Control personnel in performance of their jobs and recognition of the efforts by the Quality Control personnel.
10.
Weekly Quality control departmental meetings are held on Fridays.
This weekly activity was temporary halted due to the fire and remodeling.
11.
Weekly Lead Quality Control Inspector meeting are held every Tuesday with the Quality Control Manager. At this meeting, ways of improving the Department and its working relationships among Personnel are discussed.
12.
Lead Quality Control personnel and supervisors are nos imputting into the training activities.
13.
There is a daily staff meeting in the Q. C. Department to discuss items related to progress.
14.
Weekly and monthly status reports for all inspection areas are posted so personnel can check the progress towards the overall goals.
15.
At the weekly Q. C. meeting any incoming correspondence which y
recognizes a job well done or any favorable coimeents of the Quality Control Department activities are passed on to all Quality control personnel.
16.
Q. A. section is involving Quality Control Inspectors in procedure development and revisions to obtain their imput on how to make the inspection procedures better.
17.
Another Quality control departmental supervisor has been added to assist the management and spread the management burden better.
Additionally, on Friday, September 28, 1984 during the weekly departmental meeting, the Quality Control manager and Assistant Quality Control manager reviewed the L. K. Comstock and Company, Inc. quality policy statement (copy attached). Specifically, this policy statement states Quality Assurance personnel assigned responsibility for implementation of the Q. A.
program are independent from the pressures of production. It is the policy of l
the L. K. Comstock and Company, Inc. that the quality of the work comes first versus the quantity of the work.
Cosumonwealth Edison Company Proiect Construction Department Actions Project Construction Department has taken the following actions to assist L. K. Comstock and Company.
1.
Two Senior level Engineers (J. W. Gieseker and L. Tapella) have been added to the Project Construction Department staff to assist the l
L. K. Comstock and Company, Inc. effort. Their focus has been primarily quality related issues.
.c
Shamblin-4 2.
Project Construction Department personnel have meet with individual Comstock Quality control Inspectors to hear their complaints, etc.
3.
Numerous sessions have been held between Project Ccastruction Department and Quality Assurance Department to explore methods to review Inspector certifications packages.
As stated above, I believe there has been responsiveness to the morale questions. I consider the morale question closed in the sense that actions have been taken. There will always be need for room for improvement and we shall continue to improve the working relationship between management and working personnel. Please contact the undersigned if you have any questions.
bJ.LLJL D. L. Shamblin Proj. Construction Superintendent Braidwood Station DLS/kje (0959a) i l
l i
l l
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Q, Shamblin-4
.s. A. C0lllul0Ck C C0llipully. inC. ELECTRICAL CONSTRUCTI P
38 OLD RIDGEBURY ROAD, DANSUR', C T. 06810 o
May 1, 1980 1.0.0 POLICY STATEMENT TO WHOM IT MAY CONCERN:
L. K. Comstock & Company, Inc. vests authority with the Manager of Quality Assurance to establish and implement a Quality Assurance Program which will satisfy the requirements established by the Cor-porate Quality Assurance Operating Procedures, Customer Contract Documents, the Code of Federal Regulations Title 10, Chapter 21 and 50, " Reporting of Defects and Non' compliance" and Appendix 3,
" Quality Assurance Criteria for Nuclear Power Plants," respectively. -
The Quality Assurance personnel assigned.this responsibility are
(,
independent from the pressures of production. They are responsible for hiring, certification, firing, promoting and demoting of the quality personnel needed to implement the Program.
Responsibility is to be retained by the Quality Assurance Manager even when the work of establishing or executing the Program is delegated to other y-organizations.
g, Authority and duties of persons within this organization include, but are not limited to, auditing, inspection, surveillance, identifying problems, initiating, recommending or providing solutions, verifying implementation of solutions, and controlling further processing, deliv-ering, installing of a nonconfirming item, deficiency or unsatisfactory condition until proper disposition has occurred.
Very truly yours, L. K. COMSTOCK & COMPANY, INC.
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Lester O. Wuerfl, J.
Vice Prasident/ General Manager LOW,Jr:jb l
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Shamblin-4 L. K. COMSTOCK A COMPANY. INC.
BRA M CCD 4.1.3 gA,,c7 L. K. COMSTOCK & COMPANY. INC.
PERSONNEL INSTRUCTION LOG INSTRUCTION HAS BEEN GIVEN TO THE FOLLOWING PERSONNEL Asst. Q.C. Mgr.
BY:
I.F. DeWald / t_c seene Quality Control Manager 9-28-84 Name Polition Date j
General Q.C. Meeting See Below See Below Topit Specification / Procedure Revision INSTRUCTION 08JECTIVE: Insnector Information NO. OF Hout$ 1/2 Hour
/h Review Policy Statement 1.0.0 SUSJECT:
Rev. 5-1-80
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(2) Level II review must be completed by an inspector certified in the discipline covering the document that is being reviewed, for exampIe Configurations Form 7 should be reviewed by a certified Level II Configuration Inspector.
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L. K. COMSTOCK & COMPANY. INC.
BRA 3 WOOD 4.1.3 CLA SECT L. K. CONSTOCK & COMPANY, INC.
PERSONNEL INSTRUCTION LOG INSTRUCT!DN HAS BEEN GIVEN TO THE FOLLOWING PERSONNEL Asst. Q.C. Manager 8Y:
I.F. DeWald / L.C. Seese Quality Control Manager 9-28-84 Name Position Date General Q.C. Meeting See Below See Below 1
Topic Specification / Procedure Revision l
INSTRUCTION 08JECTIVE: Tnanector Information NO. OF HOURS 1/2 Hour SUSJECT: (1) Review Policy Statement 1.0.0 Rev. 5-1-80 (2) Level II review' aust be completed by an inspector certified in the discipline covering the document that is being reviewed, for exampIe Configurations Form 7 should be reviewed by a certified Level II Configuration Inspector.
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O PEPSONNEL INSTRUCTf0N LOG INSTRUCTION HAS BEEN EIVEN TO THE FOLLOWING PERSONNEL Asst. Q.C. Mgr.
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I.F. DeWald / L.G. Seese Quality Control Manager 9-28-84 NasMr Position Date General Q.C. Meeting See Below See Below Top 1c
$Pec1ficat1on/Procecure Revis1on INSTRUCTION OBJECTIVE: Innnector Information NO. OF N0ut$ 1/2 Hour
SUBJECT:
(1) Review Policy Statement 1.0.0 Rev. 5-1-80 (2) Level II review must 'ba completed by an inspector certified in the discipline covering the document that is being reviewed, for exampIn Configurations Forn 7 should be reviewed by a certified Laval II Configuration Inspector.
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O PERSONNEL INSTRUCTION LOG INSTRUCTION MAS BEEN GIVEN TO THE FOLLOWING PERSONNEL 9h/
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Topic specification /Proceeurs Revision INSTRUCTION 08JECTIVE: Innnector Information NO. OF HOURS 1/2 Hour SUSJECT: (1) Review Policy Statement 1.0.0 Rev. 5-1-80 (2) Level II review must be completed by an inspector certified in the discipline covering the document that is being reviewed, for exampIe Configurations Forn 7 should be reviewed by a certified Level II Configuration Inspector.
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htLAT ED CORRESPONDENCt DOCKETEE U %RC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- E6 0CT 17 All 2f7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFILi J-
'e 00CKE TIL a t '.%I In the Matter of:
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BR A N'."
COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456
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50-457 (Braidwood Station,
)
Units 1 and 2)
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CERTIFICATE OF SERVICE I,
Peter Thornton, one of the attorneya for Commonwealth Edison Company, certify that copies of the Rebuttal Testimony of Daniel L. Shamblin have been served in the above-captioned matter on all persons listed on the attached Service List by United States mail, postage prepaid, this 15th day of October, 1986.
~
k Peter Thornton e
Isham, Lincoln & Beale Three First National Plaza Chicago, Illinois 60602 (312) 558-7500 Dated: October 15, 1986
SERVICE. LIST
/
Herbert Grossman, Esq Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary United States Nuclear Regulatory ~
Washington, DC 20555 Commission Washington, DC 20555 Ms. Bridget Little Rorem 117 North Linden Street Dr. Richard F.
Cole P.O. Box 208 Administrative Law Judge Essex, IL 60935 Atomic Safety and Licensing Board United States Nuclear Regulatory Robert Guild Commission Douglass W. Cassel, Jr.
Washington, DC 20555 Timothy W. Wright, III BPI Dr. A.
Dixon Callihan 109 North Dearborn Street Administrative Law Judge Suite 1300 102 Oak Lane Chicago, IL Oak Ridge, TN 37830 60602 Charles Jones, Director Stuart Treby, Esq.
Illinois Emergency Services Elaine I.
Chan, Esq.
and Disaster Agency Office of the Executive Legal 110 East Adams Director Springfield, IL 62705 United States Nuclear Regulatory Commission William Little, Director Washington, DC 20555 Braidwood Project Region III Atomic Safety and Licensing United States Nuclear Regulatory Board Panel Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, IL 60137 Washington, DC 20555 Ms. Janice A.
Stevens Atomic Safety and Licensing United States Nuclear Regulatory Appeal Board Panel Commission United States Nuclear Regulatory 7920 Norfolk Avenue Commission Phillips Building Washington, DC 20555 Bethesda, MD 20014
~
(For ADDRESSEE ONLY) i George L.
Edgar, Esq.
I Thomas A.
Schmutz, Esq.
Newmsn & Holtzinger, P.C.,
1615 "L"
- Street, N.W.
Suite 1000 Washington, DC 20036 l
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