ML20214B212

Staff Exhibit S-7,consisting of marked-up 840906 Memo Re 840428 Allegation by Former Employee of Faulty Welding Procedures Used by Lk Comstock Co.Interview W/Former Employee Scheduled for 840911

ML20214B212
Person / Time
Site:	Braidwood
Issue date:	07/02/1986
From:	Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Norelius C, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
OL-S-007, OL-S-7, NUDOCS 8705200186
Download: ML20214B212 (4)

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'87 APR 24 pg 44 September 6, 1984 GFF,.

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3?t MEMORANDUM FOR: C. E. Norelius, Director, Division of Reactor Projects R. L. Spessard, Director, Division of Reactor Safety FROM: C. H. Weil Investigation and Compliance Specialist

SUBJECT:

ALLEGATIONS RE: WELDING BY L. K. COMSTOCK COMPANY AT BRAIDWOOD (50-456; 50-457) (ATS NO. RIII-84-A-0123)

On August' 2'8, 1984 a fomer employee of the L. K. Comstock Company at the Braidwood Nuclear Station contacted L. G. McGregor, SRI-Braidwood with information regarding the L. K. Comstock Company (Enclosure 1). On August 31, 1984, the former employee telephoned Region III and spoke with C. C. Williams, Chief, Plant Systems Section-DRS. The caller provided the following infonnation:

f L. K. Comstock Company welders have been welding SA-446 material to A-36 WCT'l*

WEa j material; however, a weld procedure was not available. These welds were contrary to AWS D.1-1975 according to the alleger. A nonconformance report (NCR) was eventually written (NCR No. 3099). Documents relating to the problem are August 10 and 11, 1984 memoranda from the alleger to I. DeWald and a August 22, 1984 sumary memo written by DeWald. The alleger questioned the qualification of the weld when joining SA-446 material to A-36 material, as SA-446 is not addressed in the AWS code.

" 2 h The alleger contended the L. K. Comstock Procedure No. 4.1.14 was M d '## 'O e qualified to the SG weld position, but the procedure was used to weld all positions.

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g g,,ju, 4 h The alleger stated that language inconsistencies exist within the procedure (e.g. instructions to use magnetic particle testing on stainless steel).

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% The procedure was used to make bimetalic welds, but the procedure is not a bimetalic procedure.

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1. "*K 1 Bimetalic welds have been made, but L. K. Comstock does not have a

~M procedure to qualify its welders for bimetalic welds . Therefore, welders J;C M are not qualified to make bimetalic welds. p F#' A In general the L. K. Comstock weld procedures are filled with errors and I$ .

W7W 7f / inconsistencies (e.g. decimal fraction Conversion tables shown "

0.750 = 32/32. .

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• 5. g. L. K. Comstock Company does not have any weld filler material controls, as the procedure is only now being written.

8705200186 860702 PDR ADOCK 05000456 1

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• C. E. Norelius/R. L. Spessard September 6,1984 f

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7' i[ Filler material withdrawal forms have inconsistent heat numbers. The alleger could not find any paperwork to back-up heat numbers in the possession of either L. K. Comstock or Phillips-Getschow.

. Phillips-Getschow provides the filler materials to L. K. Comstock.

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The alleger has found that L. K. Comstock Company does not have any ~

N control of construction materials in terms of heat numbers or other traceability. '

",' Welds were made without the required preheat. A procedure was developed that did not require weld preheat, but quality control did not participate by observing the making of the weld coupon qualifying the procedure.

%~I..,>T The alleger has reviewed welder qualification records and has 7-8 pages

( . -) of welders' names that have inconsistencies in their welder qualification records which make their qualifications indetenninate. .

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Many of L. K. Comstock field welders are qualified to L. K. Comstock (Y,,y'

,,g, ad u,.9 Procedure 4.7,1. However, the procedure is not traceable to L. K. Comstock I weld procedure qualification records. The welders were originally tested l

cO> &c.fi on Schedule 80 pipe, but the current procedure refers to test on plate.

JOI The alleger reviewed welder qualification records and found:

(Tfer.:ua37Aiu?h c e r -" a: Welders took their qualification tests on }" plate, but no limiting

t say'h parameters were listed on their qualification records.

1'",$, JK Welders were tested on i" thick material, but records showed the welder with an unlimited thickness range.

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Welders were tested on 6" Schedule 80 Pipe, but welder records showed an unlimited thickness range. AWS D1 shows a lower range of I 0.187" thick, but actual welding is down to 0.105".

4 .' Welders with rejected positions only took one test on retesting.

P"'O The alleger contended that the code required two retests, not one.

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4s g. Records showed that an unidentified welder had a rejected test on a I

'N d 1" thick plate and that the welder performed two additional tests on

'#" d ; #C'" the same day. The alleger thought it was impossible and the record was wrong.

) d The alleger believes there are many instances of record falsification (e.g.):

• .- ~ "fNrq ' Nt i / An unidentified welder took three test coupons and got the results all in one day. The alleger stated that this was administratively j d , re,u 9,

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t EXEMPT E101 M83083E .

C. E. Norelius/R. L. Spessard September 6, 1984 pfe nu M V. Face bend and root bends were done on 1" thick plate material which i the alleger contended was physically impossible; .!

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tu<w "" , M Overheard that an inspector inspected 1,000 welds in one day. The "9 '

alleger provided the name of a possible witness.(EZIDtv A-o//9) n*c"

" " - p2$ The alleger reviewed the " Master Hamer Log" and found a welder was i assigned welder stamp numbers 23 and 123, but two other welders were also 1 1

assigned the same stamp numbers. The welders were W. Godsey, R. J. Murphy and K. VanDuyne. The alleger found other inconsistencies in the Master Hamer Log, but was prevented from making a formal finding because he was not certified in that area.

Bob Wickes, a Level 2 Quality Control Inspector, was responsible for the 7,,"g,5 m'

• )i. welder test booth. Wickes was also assigned to inspections in the fabrication shop and routine field inspections; consequently, no inspectors watched welder testing in the qualification booth. The alleger considered this to be inadequate control of the' welder testing program and inadequate or no quality control involvement in the weld

• qualification test implementation.

" Y j,. BobdMarino, the L. K. Comstock Company's Corporate Quality Assurance

,[' Manager, intimidated quality control inspectors during discussions on compensation by telling the inspectors that he had twenty people ready to take the places of the inspectors.

Subsequent to C. C. Williams' conversation with the alleger I telephoned the alleger to establish a mutually agreeable time for a personal interview. The '

alleger indicated that he would be willing to come to the Region III Offices I during the week of September 10, 1984. I infomed the alleger that this was acceptable and that I would be in contact with him as to the specific arrangements for the interview. During this conversation the alleger indicated that he felt his had been improperly terminated from his employment with the L. K. Comstock Company because he had identified too many quality

1. "" concerns. I informed the alleger that he had thirty days to provide a written j%, complaint to the Department of Labor, Wage and Hour Division and I furnished the alleger with the address and telephone number of the Wage and Hour Division Area Office in Cincinnati, Ohio, as it was the office closest to his residence. I also informed the alleger that if he decided to contact the Wage and Hour Division that they were obligated to inform the L. K. Comstock Company of the nature of his complaint and his identify; therefore l confidentiality could not be assured. The alleger indicated that he was not concerned with the confidentiality of his identity and that he would be in contact with the Wage and Hour Administration. On September 4, 1984, Glenn A. Fierst, Area Director, Wage and Hour Division, Cincinnati,- Ohio, was telephoned and informed of the alleged discriminatory employment temination.

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C. E. Norelius/R. L. Spessard September 6, 1984 l 1

l On August 31,.1984, R. L. Spessard, Director, Division of Reactor Safety (DRS) -

was apprised of the allegations. Spessard advised that the issue should be assigned to the Division of Reactor Projects (DRP) for resolution with the DRS providing technical support to DRP. On September 4,1984, the matter was coordinated with E. T. Pawlik, Director, Office of Investigations, RIII. It was decided tha~t this matter would be recoordinated with 01:RIII after RIII has interviewed the alleger and obtained more specific infomation about the record falsification issues. Accordingly, this matter is assigned to DRP for resolution.

On September 5, 1984, the alleger was recontacted and arrangements were made to have the alleger visit the RIII Office for an interview. Arrangements were also made to have a court reporter to be present for the interview. It is requested that a DRP representative familiar with the Braidwood Facility and a DRS welding inspector be available for the interview. The interview is 1 scheduled for 9:30 a.m., Tuesday, September 11, 1984 in Conference Room C. l Also, it should be noted that L. G. McGregor's request for a CAT inspection at Braidwood (second last paragraph of Enclosure 1) is not within the purview of the Region III Investigation and Compliance Specialist. On September 4, 1984, McGregor was telephoned and it was suggested that he contact the Director, DRP on the matter.

Charles H. Weil

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Investigation and Compliance Specialist

Enclosures:

1. 8/28/84 memo, McGregor to Weil

2. ATS Form cc w/ enclosures:

A. B. Davis D. H. Danielson W. L. Forney W. S. Little )

E. T. Pawlik j R. F. Warnick l SRI-Braidwood ,

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