ML20214B534
| ML20214B534 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/03/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| OL-S-010, OL-S-10, NUDOCS 8705200310 | |
| Download: ML20214B534 (128) | |
Text
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ORIGINAL 5-/g)
V' UNutu STATES mgy NUCLEAR-REGULATORY COMMISSION
'87 TPR 24 P4 :
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IN THE MATTER OF:
DOCKET NO:
ALLEGATIONS INTERVIEW NUCLEAR RtutATOH WIN w*t "' g.y'r/,V /FY iciat hh ha-m; eo in the matts of
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ntamto Applicant _
latervens _
Cont's Mr 7'O' DATInn p. m4d e t* -
)? A Reportw -
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t.OCATION:
6LEN ELLYH, ILLIN0IS PAGES: ~ 1 -114 e
DATE:
TUESDAY, SEPTEMBER 11, 19814 SE d
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PDR ACE-FEDERAL REPORTERS,INC.
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347-3700 NAMOSE N I
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CERTIF ATE OF OFFICIAL REPORTER s
This is to certify.that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COtei1SSION in the matter of i
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MAME OF PdOCEEDING:
ALL:c.gTIO!!S IN':TnVIEU g
l DOCKET NO.:
NONE 50-45d 52*iY J
' PLACE:
ctEN ELLYN, ILLINOIS
'DATE:
TUESDAY, SEPTEliDER 11, 1984 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear segulatory Cormnission.
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m PED) c,gg,3,g3733 gp,7;93 Official Reporter Reporter's Affiliation Sauline.Tancs & Assneintos 53 Ucst Jachsen 71vd.
chicano, Illinois en604 O
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MORLEY nWEN DUC1:ETT, i
2 called as a-witness herein, having been first duly a
sworn to tell the truth, the whole truth, and nothing a
but the truth, was examined and testified as follows:
i 4
EXAMINATION s
BY MR. WEIL:
s Q
Will you, Mr. Puckett, for the record p _..q
.j 7
please give us your full name and address?
i i
4
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s A
My name is Worley O.
Puckett, W-o-r-1-e-y
'"s 0-w-e-n P-u-c-k-e-t-t.
My address is 3672 Spring Gr'ove i
to Road, Be thel, Ohio, 4 5106.
21 Q
Mr. Puckett, the information you're about to 12 give us, is this stated freely with no threats or promises or of a reward having been made against you?
2:
~
24 A
Yes, it is.
2s Q
Is that correct -- okay.
as Okay, if you will, give us an idea of 27 your background in the nuclear industry.
i I
i.
i as A
Well, I was spent 20 years in the United States
- l. sj 19 Navy.
I attended their Class C Welding School in F-; ~-1 20 San Diego, California, which was for 32 weeks, which at dealt with nuclear component welding and non-destructive l,
se testing, mag particle inspections, dye penetrant as inspections as well as your visuals.
Af ter getting out of the Navf I spent s4 1
i
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3 1
somewhat ov,er eight years at the Zimmer Nuclear Power 8
Plant as a Level 2 QA inspector, as a lead mechanical i
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8 inspector, and later.as their project' weld' engineer.
l l
4 Q
Mr. Puckett, when were you terminated at 5
Zimmer?
r --
s A
This was on the 27th day of August of this t
7 year.
a Q
And what were the reasons you were terminated, 9
sir 7 to A
Now, this termination -- you're talking about 21 at Braidwood, right?
22 Q
No, I'm --
2:
A At Zimmer?
)
24 Q
-- in your background --
as A
Ch, well --
3 26 Q
You know, we brought it up to Zimmer.
And then 1
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27 4
obviously, you went from Zimmer to Braidwood --
l'VR4 1s A
Oh, I'm sorry.
l to i 2e
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g;- [j Q
That's what I'm trying to establish.
80 A
l's sorry.' I*was terminated in January.
I think it was somewhere around January the 2nd of this 22
'88 past year,.
s Q
19847 24 A
Yes.
They closed down Zimmer and I was laid off ad a result of that.
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4 1
2 Q
Okay.
Thank you.
From January of '84 until -- well, yes --
a until what period of time?
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4 A
Until May --
s Q
May --
r s
A
-- I was unemployed.
I applied for and i
received a job with Comstock Engineering in Braidwood, s
Illinois around the 27th day of May of this year, s
Q And what position were you hired for?
so A
I was hired as their level 3 QC inspector, l
j 11 Q
What disciplines were to be the Level 3 as in welding?
l 2:
A In welding.
l 24 Q
Just -- any other areas?
s A
As far as I know, welding was the --
. as Q
Okay.
27 A
primary.
s g",
- ; as Q
Okay.
Were you ever certified as an inspector j
i I .. ' is at Braidwood?
so A
At Braidwood I was in the process of qualify-i as ing.
They have a mandatory qualification program and i,
's:
I was qualifying.
At the time of the tere $ nation 1 ss hadn't received my full qualifications.
s4 Q
When were you terminated 7 A
on the 27th day of August of this year.
1 e
.J _._ _ __ ';_..._. _ _ ____. _ _ __ _ _____
.1._._._,______
's 5
were the reasons fer the Q
Okay..What 3
ermination?
2 t
The reasons that were given to me by the
'A s
QC Manager is he was looking at my qualification f
one of the exams that I had 4
records and he said that the s
aken, even though I had a passing score on t
a That was xam, he expected a higher score from me.
e he gave me for the th'e basic, the basic reason that s
l terminatien.
And who was the QC Manager?
Q Okay.
J to Tha t ' s D-e-w-a-1-d.
Irvin Dewald.
A 23 Referring you to a memorandum that Q
Okay.
It cover s I gave you, it's dated September 6, 1984.
2:
your conversations with our inspection staff during 24 1984.
We will be 28 and again on the 31st, August for the interview.
is using this as the guide so to speak, 24 Please feel free to make any Thit is our outline.
',,q And what we will be looking for is 17 corrections to it.
s..,,, i 33 amplification and try to go into as much detail as
.1 r---I is
- have, possible and also obtain copies of records that you so these contentions.
brought along to support L. K.
si Going to the first issue, Okay.
Comstock Welders have been welding SA-446' material to However, a weld pr,ocedure was not A-36 material.
24 available, u
s o
2 These welds were contrary to AWAS D 1975.
p,oint -:L and hyphen (D.1) 2 A Non Conformance Report was eventually.
4 written.
That was NCR No. 3099.
There are several l
other documents relating to this problem which identified 5
-- and their memorandum between you and Mr. Dewald.
It s
is my understanding that your basic problem here is 1
the qualification of the weld joining SA-446 material s
to A-36 material as SA-446 is not addressed in the s
1 American Welding Society Codes.
2o sir?
Is that essentially your concern, 21 A
Yes.
The 446 is listed in D-1.3.
That's 22 for materials, sheet materials that are less than an 23 24 eighth inch thick.
i as Q
Okay.
A I have copies.
I have a copy of the Non as l
n Conformance Report that is mentioned here, 3099.
I 2s Q
Um-hum.
2, A
I also have. copies of these memos, if --
',f,;
l so Q
Okay.
Let's take a look at those.
l BY MR. WARD: *
'l s1 A
Do you also have a copy of that welding 4
procedure that you --
I did not bring any copies of the weld A
procedure s --
Q I sea.
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a A
- wit _h me.
This is a copy of the Non Conformance 1
3 1
Report.
Do you know the' number or the name of that 3
Q welding procedure that you referred.to?
43
- 4.3.3 is their structural welding s
A procedure.
e... -
I have copies here of two memos that 7
they stop work
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I sent Irv Dewald recommending that s
they stop work on these particular 9
order
- that that time procedures because it was my contention at 10 j
the procedures were not qualified.
11 that I have a letter from Irv Devald to 12 F. Roland, which was the Project Manager dealing 13 And in a particular instance here 14 with these memos.
they stop work on the 3 -- 4.3.14 15 he did recommend that procedure, which is their stainless procedure.
16 he recommended I think the reason thet f
17 that it did not impact stop work on this was the fact is i.
the time as we weren't the job or the schedule v.
19 1..,
I ' ' 'i fdE32 s
velding any stainless steel.
o He mentioned'the carbon steel velding 21 said that it should be procedure in here, but he just 22 qualified, requalified as soon as possible.
23 24 BY MR WEIL:
o I
l 8
1 Q-Mr. Pu cke t, let's stop at this point.
What I'd like to do is just take these issues one by one.
s s
A Okay.
4 Q
And we'll bring out your document at that time as we 're already several documents ahead here.
s
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s A
All right.
~
v Q
So let 's go back to the issue of welding a
SA-446 to A-36.
e A
All right.
so Q
If you will please, what is your concern 33 in this area?
u A
Well, the A-446 material is not listed in sa the D-1.1 Code.
The D-1.1 Code was never meant to be used for welding any material that is under 1/8 34 is inch thick.
The materials that we are dealing with in the 446 category there at Zimmer, they're unistrut, as being the heaviest gage, which is 12 gage.
17 se Q
Excuse me.
Zimmer or Braidwood?
I '. '
3, A
Braidwood.
Pardon me.
Braidwood.
The so heaviest gage sheet steel in 446 that we are using
,3 there at Braidwood is 12 gage, which is 0.105 in thickness.
~
I might say that I recommended these stopworks on the 3.1.14 procedure, which is the stain-less procedure, because they only had it qualified in
t 9
I 2
one position, the $-G position.
2 Q
Um-hum, s
A They also only qualified their welders in 4
the 5-G position.
s Q
Okay.
Well, again we're getting a little a
shead.
3 A
O, okay, a
Q Are we still --
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1 A
We're still on the 446,.right.
I'm sorry.
go Q
-- still trying to digest that.
22 A
Right.
2:
BY MR. WARD:
2 Q
In the welding procedure, is it contrary to 24 welding the A-446 materi-al to the A-367 Is it what does it say about that or does it address it?
2s A
Well, they had two technique sh'eets or 2s 3,
attachments as they call them in the back of the body of the procedure that dealt with welding A-446.
One i.
s of the se was A-446 to A-500.
Well, both of them was.
3, Both of them was for A-446 to A-500 material.
There so was no reference anywhere, A-446 to A-36 material.
33 And that's approximately 70 percent of i
the welding that they're doing is A-446 to A-36 materia 1.
Q What is 446 material?
A It is your sheet steel and your unistrut.
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Q That is the 446 material?
8 A
Yes.
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s Q
Okay.
Then the A-16 that you are speaking 4
about, what 4
5 A
That is -- most of your structurai steel p_.--
e other than your tube steels -- any of your structural
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7 steel plates.
They call it flag material that they a
weld to the ends of the unistrut where they make their o
attachments to your heavier structural steel.
1 20 BY MR. WEIL:
I 11 Q
For my, really, education more than anything 12 else, is there a code provision that would prevent c
2 446 from being joined to A-367 14 A
Yes, in facts in the Non Conformance Report 25 that was initiated, they mention a certain portion of as it in there.
I think it was in Section 5 of the D-1.1 75 17 Code.
And the note I think was 5.5.2, in that area.
4 1s It says in there that any material with a tensile
- _;;1,,
as strength less than 50,000 psi can be joined to any to other material listed in 10.2 with a tensile strength i
at less than 50,000 psi.
se However, 446 is not listed in 10.2.
It further says in a lower note in the same column that sa
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a procedure will have to be qualified at any time you s4 change grade or type of material.
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l 11 The Non Conformance Report was i
i s
inisted, and it went thr ough CE CO, commonwealth Edison C' mpany, the client a.nd to Sargent and Lundy (ph.), who o
a 4
reviewed it, and they -- we had a meeting *concerning s
this, and it was their contention that Grade A-500 and A-36 material were -- weren't that much different and that they could use two technique sheets, Technique i
s Sheet H, and Techni,que Sheet 0 to do this welding.
I j
However, at this time I pointed out l
to them that Technique Sheet 0 was a reject, that they 3,
22 could not use that, that it had been rejected -- how-q ever, it was still in our manual -- and that the l
Technique Sheet 0 -- H that they were referring to 24 was qualified for a 3/8 minimum nine fillet weld --
as was for a 3/8 minimum size fillet weld.
And the welds that they were doing to the unistrut and to the sheet as i
av steel were eighth inch and quarter inch fillet welds.
)
j as BY MR. WARD:
2, Q-Do you have any specific weld numbers where i
s
'. _7 j somebody could walk right down and see where they are
,o in violation of their procedure?
,3 A'
Well, they never pe'r se issued amid numbers.
They installed them by component numbers, by hangers H
2:
f or whatever the case might be.
But specific numbers?
l No, I never got any of those.
I wasn' t in the field
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12 i
2 actually' doi,ng the inspection.
I was just reviewing i
8 the procedures and taking note of what welds were j
s being made inasmuch as in the fabrication shop they i
4 were doing,most -- I would say 70 percent of their a
weld was A-36 to A-46, using 7018 electra.
- F.
t ie s
Q Do you know of any rooms or buildings or --
- t E
7 A
This was --
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A
-- you know --
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s A
This was all safety related work that I'm 1
I.
referring to.
It is all safety related.
It is for so i
as their unistruts and the cable pans, anything to do 1
with -- on your risers, your cable pans --
i i
is BY MA. WEIL 1
.l i
24 Q
I think we're pretty well exhausted this area i
s for the time being.
Let's move on to the second issue l
s dealing with L. K. Comstock Procedure 4.1'.14 and 27 qualified to the 5-G position.
But that's my under-p i
is standing the procedure was also used to use all other c*
l
' 2.,
se positions.
i so A
Yes.
s Q
Will you expand on that, please?
's:
A To qualfiy a procedure in accord,ance with as AWS D-1.1 which they are using for their criteria, j'
,the uode requires tha t you qualify.a procedure in all the i
i i
i s
i t
13 i
2 positions that it's going to be used in.
2 It is my understanding from talking to a
QC Inspectors there at Braidwood that they had been doing welding in the dield in the verticle position 4
3 4
i s
and in the horizontal position using this 4.1.14 weld i
e procedure.
3
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In the back of their procedure they had a PQR, shich is Procedure Qualification Record, and it s
reflects there that the materials that they use for the to qualification was SA-312 to SA-312, which is pipe to i
P Pe and in the 5-G position.
i 22 as And under veld procedure specification, j
which is the next sheet that is used to oktline what 23 i
/
you can veld with this, they have -- that you can weld 24 1
SA-312 to SA-240, which is plate.
However, they did 3,
i l
not qualify any procedure using SA-240 maperial.
3,
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Q For the sake of the record, what is the 5-G 27 1
]
position?
3, l
A The 5-G position is when the pipe is in the 3,
l l
j, ;_,
f, horizontal position.
q ok'ay.
A And the welding is being done in the verdicle
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position and the overhead position and the* flat position, i
ss l
But in no case have they done any welding l
s4 l
that involves horisontal welding.
l 1
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1 BY MR. WARDr s
Q Do you know if it's documented anyplace a
that they were using this procedure in welding in j
another procedure -- welding in another position --
4 a
A Thi s --
Q
-- they were using this procedure, but welding a
7 other than the horizontal?
Is it documented anyplace?
)
e A
I would think that on their WR's, Welding l
e Inspection Records or Weld Installation Records --
3' Q
What is that called?
i n
A Weld Installation Records.
They refer to it i
u as a WIR.
The Weld Installation Record will have the component's name and the procedure assigned to it.
2:
1 i
The 4.1.14 procedure, as I stated before, 34 requires that when you're welding with it under AWS, ss i
)
that it be qualified in all the positions that it's a
n going to be used in.
u And in addition, the welder should be qualified in the 2-G and the 5-G position to ' qualify him I
a i
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so in all positions.
i And as it is now, unless it's been changed m
since I left there, the Procedure is only qualified l,
sB j
in the 5-G position, and the welders that qualified to ij-the procedure only qualified in the '5-G posit' ion.
as And again, they qualified pipe to pipe, 4
1
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s l
I 4
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SA-312 to SA-312.
And the welding that is being done i
in the field is plate to plate.
i s
MA. MA. WEIL:
4 4
Q You've reached an area that I'm'having'some trouble understanding.
Do you have any idea why L. K.
i I
Comstock would be qualifying pipe to pipe.
It's my I
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understanding that as an electrical contractor, they
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wouldn't be welding any pipe.
i J
A I really have no idea.
.I asked the same h
I question.
The only reason chat I can think of is the
~
20 l
23 contractor that was doing the electrical contracting i
there prior to Comstock was E. C. Ernst (ph'.), and 3
they qualified a lot of their welders on a 6 inch 3,
34 Schedule 80 pipe.
as Q
Um-hum.
i l
A By doing this in the 6-G position, they 1s t,
^
would only have to cualify 1
the welder in one position, 37 i
a n d h e wou ld ha v.e.a u t oma_t i c a...l.ly a l l== =4 ei nn because as a
I
{,.}. j '
of the incline of the pipe covers all positions.
3, But with the 3.1.14 as stated, that's i
j the only type of material that we had in our warehouse
,3 i
because I was setting up to qualify a proepdure, SA-240 I
to EA-312; and we did not have any of the material on ss j
hand and never hed had.
They had one piece of pipe l
l s4 there thgt they were using for test coupons, i
1 l.
- ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
i i
16
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1 2
Q I just can't imagine why Comstock is --
r Jur involved in plate at all.
It baffle,a me.
i A
There wa s a~ lot of things that baffled me 4
about it.
s BY MR. WARD:
c s
Q Pipe is harder to weld than plate.
Maybe t...
they thought, you know, maybe because --
i.
A I, I do not know the reasoning.
I have no idea.
I asked and they could not give me a satis-factory answer.
3, 22 BY MR. WEIL:
l as Q
But a historical point at the moment, you 23 said E. C. Ernst, was that not a predecessor of L. K.
Comstock?
24 t
j A
Yes.
ts 9
Weren't they the same company or --
r 2s A
It's my understanding --
37 s
L t.;,
Q
-- joint venture.
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3, I'
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[i A
It is my understanding that they were, but as Ef5S they had a different set of procedures altogether.
Q Okay.
,3 1j, A
They had procedures that 'were E. C. Ernst j
procedures, the equivalent to the 4.3.3 that we nentioned i
j earlier.
The predecessor to it was a 9.2. which is an s4 j
Ernst procedure.
i 17 2
Q-Okay.
Is there any more information you'd like to share with us on the veld position qualifi-a s
estion before we move, on?
a 4
A No.
The note B here pertains to this 4.1.14 s
Q But for the moment the --
s A
No.
7 Q
-- the note B is that the language incon-a sistances exist within the procedure.
As an example, t*
instructions to use magnetic partical testing on
~
3, stainless steel.
If you will proceed to explain it to 22 us, please.
22 A
Yes, in the body of the procedure, and this i
23 was pointed out, and for some reason, I don't know why, they never immediately made a change to it; 4
34 but in the body of the procedure it za says if you are checking for cracks in stainless steel, you will either use an 2s acid etch or a magnetic particle inspection.
27 f.,$.,.
- And anyone that knows anything at all s
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2, -
about stainless steel knows that it is non-magnetic, so and that you cannot do a magnetic particle inspection on it BY MR. WARD:
O I Q
There wasn't anything in there where they were
'as meant to talk about liquid penetrants?
a A
No, nothing at all.
Nothing in there at all abou s4 liquid penetrant, which should have been the test that e
1*
I 2
was-going to be used, an ultrasonic test, an ex-ray a
or a dye penetrant test if you were looking for indications that's open to the surface.
s 4
Q.
And this is in 4.1.14.
s A
.14
-Q To refresh my recollection, 4.1.14 pertains
[. :.
to welding or the materials or -- I'm trying to --
(
A The procedure in itself, you have the body to the procedure which tells you how this is supposed --
I.
what test and inspections are to be performed and so 33 gives you a list of the materials, the specifications tha t you're working to.
22 as Q
Okay.
A And the PQU and the WPS, which is the procedure 34 qualification record and your weld procedure specifica-3, tions in the back show that the procedure has been as
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3, qualified, what positions it's been qualified in, your I
amperage and your voltage range, things of this nature, 2s b.
F--
so Q
Let me, I guess, ask -- try and ask two
),;l ;'
questions.
k!
I'm having a little difficulty understanding s
why, again, as an electrical contractor, L. K. Comstock would be involved with stainless.
ss g
4 I do not know.
They do have some stainless welding that they have been doing.
I don't know -- I 8'
think it might have to do*with stainless steel junction boxes.
' ' ~
i 19 i
2 Q
Correct, correct.
In other words, reject --
2 just dawned on me.
Okay.
That answers the one question.
\\
The second question,.the procedure itself, and let's 4
broaden all these issues, but this brings'to mind this s
Point.
Is this a problem, or at least to your knowledge, is this a problem just with L. K.
Comstock at Braidwood?
Or is this more of a generic corporate type of problem with L. K.
Comstock procedure 4.1.14 at Perry -- I know that procedure exists over there, as an example, i
A I really don't know if it is a problem any-20 where other than at Braidwood, I know that they have 12 22 one. corporate weld manager by the name of Voght, i
e 2:
V-o-g-h-t, I think is the spelling of it; and 24 supposin'ly he was the one that wrote all these t
procedures.
3, However, one of the things that upset 2a l
17 me so greatly was these procedures had been submitted j'
to and accepted by the client, which is CE CO, and by 3,
the contracting engineer, which was Sargent and Lundy, so u...
as well as our own people.
And how an inconsistency like that could pass all of these people and get their blessings is beyond me.
Q Did the authorized nuclear inspector look at them and sign them by any chance?
Do you know?
s4 A
An authorized nuclear inspector is not
,_.,..n,.,
20 1
involved with work being done to D-1.1.
That is 8
only ASME work.
s Q
Any other type of a stayed (ph.) or any 4
other type of a --
5 A
As far as I know, there is no other inspec-a tion other than what we do ourself.
i a
Q Okay.
Is there any oversight, overviev s
inspection done by Commonwealth?
so A
I think that they do have PTL, which is an 21 independent testing agent, Pittsburg Testing Laboratories.
I rnink they do some overview inspections.
And I think u
2 that they also occasionally have Sargent and Lundy to 34 overview some of this.
is Q
Okay.
Getting back to this item 2 b, ve is talked about the inconsistency in language as the one example of mag particle being used on stainless steel, 37 i
Are there any other inconsistencies of is as language that come to mind?
A No, not off the top of my head there isn't, Q
Okay.
Move on to the next point.
Wa s i t gg still within L. K. Comstock procedure 4.1.1,4, the SB
~~
procedure was not a bi-metalic procedure.
Would you please amplify for us.
M"
t 21 2
A The procedure was qualified stainless pipe to 8
stainless pipe.
And it is my understanding through a
talking to the inspectors that welds had been done in 4
the field where they were welding stainless steel plate to stainless steel plate, using stainless steel s
'l s
Plate to carbon steel plate.
Q Okay.
Do you have any idea where in the field a
'such welds had been made?
A The -- my understanding-is, the word I heard, it was the junction boxes.
Some of the junction boxes so 21 were being welded.
Q I would assume if we are talking about 22 stainless, we are talking in the vacinity -- immediate 23 24 vacinity of the reactor.
A Yes.
as Q
Okay.
Would you be able to give us the names of the inspectors that gave you that information?
27 A
Well, I had an inspector -- it was a couple of weeks prior to my termination, and his name was John 2e x
.~
Miner.
But he came to me and they had assigned him to do an inspection, and it was a bimetalic weld that he al was to inspect.
And he came to me with the inspection ss record and says, because he had heard me talk about the 4.1.14 procedure and says did he he've a procedure for 84 making this weld.
And I said, no.
He said, well, then, I don't guess there's i
- - z~
~z
~
22 4
i write it We'll just then.
ny reason to inspect it Now, if it was written up on a noncompliance 2
a p.
u eport or whatever, I really don' t know.of seeking a s
r sort So he was just l
Q 4
A Yes.
which
- point, this fiows into the next Q
- Now, d
but Comstock was that a bimetalic weld has been ma e, have a procedure to qualify its welders on does not Therefore the welders are not bimetalic welds.
Would you please amplify qualified on bimetslic welds.
20 point?
I for us on that To qualify a welder to do a bimetalic weld, 22 A
figura-you're only qualifying the welder for the con 22 are and to the fillet materials that
~
33 tion of the joint nge.
going to be used in the amperage and voltage ra u
to qualify the welder,'you could in 3,
- Now, ld be facts qualify him stainless to stainless and he wou If you have a qualified to make a bimetalic weld.
3, will make a bime talic procedure that is qualified, that 2s d
But what was meant by this is because the proce ure l weld.
be qualified-is not qualified and the welder can't because we don't have a procedure.
So if I understand this, then we're s2 Q
Okay.
procedur,e 4.1.14 --
still really talking about ss 34 A
Yes.
0 I
w
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,,g e,
--nw
-y,om r--
{.
23 2
Q where it's not qualified to make bimetalic
-e s
welds, but,the procedure was used.
Similarly, the welders were making bimetalic welds, and they were in
~
s 4
effect qualified to D, not D, but to procedure 4.1.14 s
which wasn't qualified for these types of welds.
s A
Aight.
y Q
So really we have come sort of a full circle, s
A Well, yes, the welders -- in the back of the procedure, they've got a welder's qualification' test so record as weld.
And it reflects on there that the 21 material that the welder welded was SA-240 to SA-312 2
And this is a fallacy.
The only test coupons they had as was SA-312.
So the welder had to make an SA-312 to 34 SA-312 versus SA-240 to SA-312.
Q You made mention of the coupons.
How did 2s you know the coupons were not made to these grader of as material.
Did you check yourself.
27 A
I checked our records.
I checked with the 3,
people there that had previously given welder's quali-3, fication on the stainless.
And they said --
Q Who are those?
A Bob Wickes (ph.)
38 Q
Go ahead, please.
as A
And he said that they, the positions and the 94 weld that they gave was in the 5-G position, and it was pipe to pipe.
SA=240 material is plate.
~--n
.n.
,_,,,--g-y w-
\\
l 24 1
Q Okay.
Okay, is there any other information s
you would like to share with us on the procedure 4.1.14, a
s pe cifically, before we move on?
4 A
No, other than like I say, the memo that I s
initiated, it's one of the memos that we have here.
7 3
e initiated it to stop work using this procedure and as 7
a result,it was several days later;, but they did in s
.f n.e t s pu t out a letter recommending they stop work.
e
'Q Do you know if they in fact did stop work?
20 A
Well, I don't really believe they had t o in-asmuch as we weren't' doing any stainless steel welding 11 u
at that time.
So it did not impact the work schedule when it was recommended by our QC Manager, Irv Dewald is 34 to stop the work using this stainless.
However, on
~
the other procedure we were discussing, the 4.3.3, he is had that memo at the same time and he did'not recommend u
3, tha t they stop work using that because it would have impacted the job and I had a Non Conformance Report u
as ini ta te d.
That was the only way 'that I got the work stopped.
Q How would it imp act a job?
m A
Approximately 70 percent of the welding that they were doing at the time was A-446 to A-36.
a BY MR. WARD:
Q Were any of these welders qualified to r.
7
.__,.,,y,
-y.-
I s
25 1
Section 9. 'I know it 's AWAS?
8 A
No, no.
All D-1.1.
s Q
Had they been or were they or do you know?
4 A
No, S and L give us the option or gave Comstock
~
s the option, okay?
They said?
They said that they could i e
qualify them either in accordance with Section 9 or AUS T
D-1.1 75.
And they chose the D-1.1 75.
And to the a
best of my knowledge, none of them was qualified for o
Comstock under Section 9.
to BY MR. WEIL:
11 Q
I guess this is just a question again for te my own education, Comstock is just in the installation l
s phase, and they haven't proceeded much-- much past 24 cable, pan, tray, hangers, and whatnot; is that correct?
as A
Yes.
is Q
Okay.
1 17 A
They are doing some cable pulling terminations.
u Q
Mave they started already?
u A
Yes.
J s
Q I assume that they're protecting cables.
A Yes, they seem to be.
,g Q
Okay.
A The individual.QC Inspector there at as Braidwood se' ems.to be a good inspector and ve'y professional.
r 94 Q
Okay.
A But the procedures that they have to inspect
~l.
(
g.
i 26 1
at is another thing in question.
s Q
Go ahead and amplify on that point.
s A
Well, I mean there's so mamy inconsistencies' 4
in their procedures.
As an example, in their 4.3. 3 s
weld procedure.
We have a procedure that is qualified s,.
s in four position.
And they have anywhere from 7 to 13 7
records in the back, more or less giving them an option s
'what to use to make a weld with, You only have four positions, you shouid e
have four WPS's back there reflecting each position to and an amperage and' voltage range.
21 u
And some of the procedures they had there they -- I know a -- attachment E that they had, they to had 11 of these WPS's in the back of that procedure.
u Some of them qualified only with eighth inch rod.
Some u
of them qualified with a combination of l/' 8 and 3/32 is 27 rod.
And some of them qualified with just 3/32 rod.
But f or the amperage and voltage ranges as as they changed, of course, with each WPS.
And there's really no way of knowing what kind of amperage or voltage so range the man used in the field because they have mostly a
post weld inspection on this stuff.
It's installed and they might inspect it two or three months la ter.
Now, we do have an in process-inspector.
But his primary function in the field is he goes out and
r-27 checks ' individual welders to update their welder's 2
i t
qualification.
He takes 10 percent of the welders a week or whatever the case might be over a three
.s 4
month's period of time.
He inspects all t'he welders and actually witnesses them doing welding in process s
to update their welder's qualification.
a But as I said, the procedures, they've a
got inconsistencies in them like the note 4 that we a
have here.
They have in their inspection procedure, i
and I think the number of that i s 4. 8, they have a u
category there that lists.the effective throats of 33 welds Jor inspectir.g welds and it gives you a decimal u
and then it gives you a fraction equivalent.
And it gives you a decimal that is pretty close to this point u
750.
And the decimal that it gives for (inaudible) is u
32/32, which is nowhere near that.
It's almost a
quarter f an inch off.
H n
And little clerical errors in the pro-cedure that i n some cases may even. change the meaning of the procedure altogether.
But I know if I was audking their procedures and I would see that the procedures was in,the condition that they were, I would be wondering what as type of work that they were doing in the field.
as Q
Again, just to your knowledge, this procedure e
+7 er 7---
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28 I
deficiency just applies to Braidwood, you don't s
know?
A Ies.
Now, I did receive some copies of some s
4 procedures that was sent up from Perry, just to look 8
at, because we were going to rewrite our procedure, p-';;:
s
(..
our 433; and I looked at theirs and I did find a few
[
T small inconsistencies in their procedures too, l'
s But off the top of my head, I could not i
e tell you what these are.
to Q
This was in the Perry procedure?
21 A
Right, it seemed to me though that they only had their procedures qualified in three positions.
as g
ss Again it requires that you qualify them in all positions
[
what you are going to be welding ~in.
24 1
ss BY MR. WARD:
L a
Q
'l In No.'4 you're talking about procedure 4. 8, i
I n
is tha t what you said?
i 1,
1.
as A
Yes, this is an inspection procedure, now.
[.
This is in their inspection procedure that y
it ha s y..
a chart there that reflects your throats 'of your fillet
,o welds when their inspection are for a flare beveled a
.a
- groove, if you're checking your throat size on it.
And it gives you a thickness of the material and it tells you what the effective throat s should be on that, particular thickness of the material.
And then it m
~. _'.,,
.[
_e,,
29 1
gives you t_he fraction equivalent.
And 750 being a a
half inch and 32/32 being one inch, that's just a i
s 1ittle bit of an inco.nsistency.
l 4
Q What type of individuals approve' this s
procedure?
s A
Again, the inspection procedures, as far as I. ~
7 I know, goes through CECO and through Sargent and Lundy s
as well as of our own office.
Q Do you know the name of the individual at CECO.who does the approval, who that would be?
to A
No, I do not.
n u
Q Or Sargent and Lundy, the individuals?
A I do not know the individuals there that 2:
do the approving of the procedures.
3,
{.
BY MR. WEIL:
3, Q
When you said, to our own indiv'idual office, l
are y u talking now of Braidwood, L. K.
Comstock at n
Braidwood?
u A
Well --
Q any --
p...-
so A
of course we review them and as far as I m
know, the corporate office looks at these too.
m Q
And it 's -- Pit t sburg --
as A
It's in Pittsburg, right.,
sd Q
-- Bob Marino.
A' Right.
It is a John Voght who is our project
--m
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,._y
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.-,,..y-.w,g.
30 1
Weld Manager that supposin'ly writes these procedures a
to start with.
They have revisions made to
- them, We have three individuals there'that are supposin'ly
- a 4
QA.
s We have the QC Department.
The had three divisions there that a QA are from the same e
yc..
[-
t company that does the auditing within our own files
't
~
s and makes changes to the procedures, t
s BY.MR..WEIL:
1, -
Q This i s probably somewhat of a unfair a
~
}.
question, considering I am trying to go back many n
u years in time.
But going back to E.
C. Ern s t, did Com s to ck, to your knowledge, L. K.
Comstock take u
E. C. Ernst procedures and just accept them at u
.t face value without reviewing them?
a.
A It is my understanding that frcm' the work, the records that I 've looked at there because I was p
v.
- c.,
checking out an audit on this very thing, and it u
(', > u seems that when E. C. Ernst left a project and L. K.
K2*_[4 Comstock took over the project, they were given a so period of time that they could use the E. C. Ernst procedures up until they developed their own.
a And this was something like a 90 day period.
I do know because it was on one of the as audit findings that they did qualify welders using the
'"~ ~
~
- ~ ' ", -, ~ - -
~, ",~,
---ve-"
w
31 2
E. C. Er'nst precedure af ter that 90 day period, s
Q But that is an audit finding?
i A
Yes.
a 4
Q Okay.
So really at the moment we don't know a
whether we've had a problem here. for several years because
[~[
s Ernst made a mistake and then Comstock just copied it, n,
"~
y A
Well, in some cases, that's just exactly what happened.
In some cases E.
C. Ernst would qualify s
a welder on 1/2 inch plate and they would give them 10 unlimited thickness on this plate.
L. K.
Com s t ock n
inherited these velders when E.
C. Ernst left.
And in u
some cases these welders would terminate from the site
(-
for a period of two months or three months and then
.[
return to the site to work again.
And their qualifications would still be current.
However, we would issue them a qualificatier.
2e F.
card reflecting that they had qualified to our procedure, r..
21 i:(-
4.7.1 is for welders' qualification.
And it reflects i.
u that they had unlimited thickness and that they had
=
taken their test on 1 inch plate.
They just reissued 1
so them a card and they never went back and checked their at record to see what they initially had.
m However, E. C. Ernst would give them a
1/2 inch plate, and give them an unlimited thickness S
---,,y
.__.,y.y-
Y l
32 1
on it, which is a no, no too.
8 Q
I think we're going to get into that further a
on, 4
A Yes, that's part of it.
s Q
Let me stop for a moment and take reading.
e Why don' t we go ahead and jump ahead 7
to I believe it's No. 10.
And we'll flow with the s
comments that we've already had here, and that was your review of the welder's qualification records.
s 1o And you found at least five areas of concern here, the n
first of which is welder took their qualification test on the half inch plate and no limiting parameters were u
listed on their qualification records.
I as i
Would you please, you know, explain here.
u i
u A
Yes.
A s by the D-1.1 Code, the welder's u
qualification:
To qualify a welder for unlimited thickness, he gets a qualification on a 1 inch plate.
n A 1 inch plate would give the welder unlimited chickness l,,.
for welding.
r--
However, on some of the welder's quali-fication test records that we have on file there for s
both E. C. Ernst and L. K, Comstock, they gave welders'
]
qualifications onhalf inch plate and gave them unlimited thickness with this test.
In addition, in some cases, a welders' l
-l
_-,-,.x..-----_z.
-z,...-....-
1
(
q.
33 l
1 qualific.ation would run out and L. K.
Comstock would l
s require that he come back to our test facility and
'r,e t e s t and'they would retest him on a 3/8 inch plate a
and again give him un11mited thickness whe.n he should 4
s never had it in the fir st place.
e BY MR. WARD:
7 Q
Is this D-1.1 757 s
A Yes.
e Q
Do you have any names of the welders that to A
Yes.
21 Q
Qualified like --
u A
I have several pages.
This was part of j
as the review that I was doing at the time of my termi-t 24 nation.
And these are in alphebetic order.
I never as started with A.
I started in the middle of the records se a s some of the other records were tied up.
But, however, 27 I do have it by welder and by their welder's employee u
number and a list of the discrepancies.
And I only se listed what I considered was major discrepancies.
I'm i
ao sure there's others there such as whiteouts and forms at being made out in multicolor ink, information that has i
been changed on the forms without initials and dates, es as forms that do not have signatures at the bottom for the --
I like for ourself, our QC Manager is supposed to sign as all the forms.
We have some forms that do not have the
~
~
34 1
signature at-the bottom, giving the acceptance of the s
., form and the welder.
We have some forms that reference s
t'ha t the welder was accepted but it didn't say what 4
type of test that he took.
That is, inasmuch as was s
it a bend test, a side bend, a face bend, whatever the e.,
s..-
a case might be.
7 There is some forms listed in there I.
s referencing that the gave a welder a 1 inch plate test l
(
e and that they done face bends and root bends on it.
That's almost an impossibility.
With the equipment we so at ha've there, it is an impossibility, u
Q Would you explain that for us, please?
{
i sa A
The reason that they have the different l
34 type tests in the D-1.1 Code that you can give is because of the thickness of the material, as
, he way the t
dyes are set up, and things of this nature, as n
And for 1 inch plate it requires that you j
u do a side bend on it, because of the thickness of,the l'
se 1 ine'h.
t....
And on your 3/8 plate or your half inch spiace, or if you're using a pipe for a test that has a thin so vall, you would use root bends and face bends.
sa BY MR. WEIL:
I as Q
So when you say you didn't have the equipment there, what you're saying is that L. K. Comstock could as have made the required bend test or (ina udible) the not w_i
35 1
the bend tests that are listed, s
A L. K. Comstock themself does not even have a
, bending machine.
We use the bending machine in the d
test lab of Philips Cetschew.
s Q
Okay.
.s A
And they only have two sets of dyes set up, y ' '- -
j 7
And they have the dyes set up for the side bend for 4
(;
.s your 1 inch place or your heavier wall pipe.
And for e
the root and face bends of your thinner wall pipe and g,
10 your thinner plate.
11 BY MR. WARD:
u Q
Did you give this information to comstock u
a f ter --
14 A
1 did not have an opportunity to, 4
}
1s Q
I see.
- 4..
1s A
I was called up in the office in the middle t
17 of the review.
I was in the vault.
In facts at the
\\.-
i
- f.,'...
time I was called out of the vault, I was doing this u
["&m,}.
"~
u review.
And I come up to the office, and I was told pl.Li, so I was going to be terminated.
And they pushed a form 21 in front of me and said if I knew of any noncompliances I
.se or nonconformances I was supposed to tell,them about it.
as And I told them that if I made any state-as ment at all I would like to have the resident NAC Inspector present, and they chose not to have him there; e--.-
Y 36 1
so I chose not to sign their form.
s BY MR. WEI L:
Q Okay.
Did they give a reason to you why a
4 they wouldn't have the resident inspector present?
- s A
No, they did not.
{}-C}
s
('
s Q
Who is "they"?
}-
i.
S 7
A In the office at the time of my termination was Irv Dewald, who is the QC Manager and Larry Seese, a
[(-
s which is an assistant QC Manager.
I to Q
In our section on record falsification we --
n we just covered one issue which was a face bend.
And the u
root bends were done on 1 inch thick plate material C
l so which you thought it wa s impossible because --
~
a s.
4 34 A
Well, there was another thing there that I as thought that was impossible, being a welder myself for
{. '.i
'g.', f as many years.
We had a condition and it's ' listed on the --
e:-
n in the names.
It's written out on the form s there,
{Z.[i
',M%k; y
2s the welder that was involved in this.
But in checking MQ se his test record 'I noticed that he had a reject in the so 3-G position, which is a vertical plate position with i
m the welding progression being vertical up.
I noticed that
. se he had a reject in the 3-G position.
And I was checking 1
the records to make sure that he in facts did take two as as other. welds in the same position that he had failed and that they met all the test requirements.
And in D
m
,,.[_,_,
'y 37
\\
2 looking at this, he had the two records in thene s
r e fle c ting.. t ha t he had taken two additonal tests.
But I
s n'11 the records' were. dated the same day.
i 4
And it usually takes a good welder s
approximately a day and a half to run one of these T'- ~
- j. ~
s tests and to cut his coupons and get the m bent.
For 7
a man to run three in one day and cut them and bend a
them all in the same day, I think it's an impossibility.
s We had conditions on the test records,
}
20 the welders' qualification test records, where informa-it tion was changed by a clerk.
She's presently employed with Comstock in one of the QC offices.
u
's 2:
Q What's her name?
i, 24 A
Her name off the top of my head -- her last u
name is Franco.
She is married to a guy there by the l'
l.'
1s name of Franco.
l-27 Q
That 's sufficient.
Go ahead with your story.
'g.~ <
g,,'j j u
A Tanja.
Tanja is her name.
p
%' 0 2
to Q
Okay.
s'o A
In doing a review of the welder's qualification as test records, I kept seeing where information had,been changed on the test records and a set of initials put se as there with no dates.
And -- inquiring about this, I as was told that they were Tanja's initials.
I asked her and she said, yes, she in. facts did do some changing 9
- ^
,v y
_____.._-..,,_..,.,.__,.._,,_.,.,,,m..
y.
38 2
of some of those records.
s In some cases she made an incorrect a
~
record out of them by. changing them.
J 4
Q What types of changes did Tanja 'make?
s A
In the material specifications.
In the f) s materials that said that the test was given on a 6 7
inch schedule 80 SA-106 pipe.
And she drawed a c.
line through the SA-106 and changed it to A-36, which s
C.
1 s
would now make the record read that the text was given in the 6-G position on A-36 6 inch Schedule 80, so which would be completely incorrect.
21 t
1s BY MR. WARD:
18 Q
Who would tell her to do this?
[
~
H A
I have no idea, l
.t u
BY MR. WEIL:
g....
as Q
Do you have any idea why she would in the
{ ....'.
e 27 first place?
t.-
[2. Il u
A p. :.n, I would think if she made those changes that k
p_ ~,j r
ze she.did not realize that she should be doing it (sic.).
I think they were -- my. personal feeling so si is that they were trying to make these records look a at little better than what they were.
I don't know whether they were trying to doctor the records up or what they sa as were trying t o do.
But by putting somebody there that didn 't I
I-
1
\\'
39 i
1 know what they were doing, if anything they'd make s
a scapegoat of her.
She was the one that was making
'the falsification of the documentation.
a 4
Q I understand, but I guess I'm having trouble s
g.__.3 understanding.
What gain would there be in altering (9...
4 the records?
{ ', _ -
7 A
I really don't know at this time.
I think a
there was some test that was given on A-36 plate and s ~
they used the form referencing the form that was to prefilled out, with the exception of the welder's 11 name and his identification number.
And I think this
?
12 may have come into play there, c
as I think they were using a preprinted
,i i
g-24 form that was already printed out for 6 inch Schedule j
u 80 pipe, and they gave the test on A-36 plate and then i
as marked through the information and changed it.
- l -
17 BY MR. WARD:
I-
[
m Q
What are these documents?
How are they docu-i --
u mented.
How could a person walk up to one and look at so one -- what she'has changed?
What would they be a
called or --
se A
It's a welder's qualification test record.
~
~
BY MR. WEIL:
as Q
Are the welders mate ment. ion of in your notes that you provided?
9
~ ' ' ' ' ~ '
t 40 2
A Yes.
Q Okay.
The names are in there A
Right.
4 BY MR. WARD:
s Q
Oh, the names are in there.
s A
Right.
I did not get an opportunity to go 2
through all of the records, s
MR. WEIL:
I understand, o
BY MR. WARD-so Q
So this would be documented here where we 22 oculd get the name of --
l 22 A
Yes, all the information is there.
2:
Q Okay.
24 A
But one -- back, skip back, something that 2s I wanted to bring out that is not mentioned here on 2s some of our welding procedures.
I noticed inconsistencies 27 in the procedure qualification test records in the back as your PQR's and your WPS's where information had been 2:'
changed inasmuch as in your ampe' rage and voltage range's as so and had been initialed and dated in the one that was s2 issued to the field.
's:
However, in checking the master record in the vault of when this procedure was run and when it was made, it was qualified.
The original record s s4 had not been changed.
1 a_.
.__--,_____-,,_.._._.__.,_._..__y
41 1
BY MR. WE1 :
s s
Q
.Okay.
Which procedure was this, do you j
s recall?
4 A
4.3.3.
a Q
And which revision?
g.
a A
Well, it's rev.
C.
But I think all their
(
7 revs. in that procedure -- they have a half a dozen 1
a revs. and they're all C.
They a rev. C and then they give a date with it.
i 20 Q
I see.
22 A
That would have been the rev. prior to my 22 dismissal, t-2 Q
Okay.
So what we're really saying here is 24 that not only they're unauthorized or seemingly. authorized i'
j is changes to the procedure, but also it see.ms that there 1
are uncontrolled copies of procedures being distributed as i
..t 27 to the field for use.
[.
2s A
Yes.
o.
8 I
2, Q
Is that my understanding (sic.).
h2[-
,5 A
When I brought up some of these things on the welder's qualification test records and the procedures, 33 the QC Manager, which was Irv Dewald said 'that they had y,,
in some cases reconstituted copies in the welder's i
qualification test records.
And in some cases I did find reconstituted copies.
l
d 42 2
But my understanding is a reconstituted copy is a copy where you make corections or change th.e information to another form and then you run it the 3
4 same route that it went originally for original i
a signatures.
g-a The only signatures on his reconstituted f,
y copies is his own.
He did not take it back through
-Pittsburg Testing Laboratories for them to add their s
information.
so Q
And what does PIL have to do with these is procedures?
4 22 A
]
PTL i s the independent agency there that i
does all the testing and inspection of our welders' 23 24 qualification.
1 Mr asevv4 as Q
The non (ph.) examination?
2s A
Yes, they do the final buy-offs on the bends.
I sv Q
Any radiography performed on the bends?
1 ss A
No.
In facts, our inspection procedures in I '.* -
2s Comstock does not deal with a full penetration weld of
- ~~
so any kind.
All they deal with is your flare beveled i
s1 welds and your fillet welds, and -- they were doing
's some welding in the electric shop.
And they were making some full penetration welds.
And I went to Irv at'that time and I told nia that those welds was going to require a radiograph, that the configuration was such that they couldn't be radiographed and it required that they be t
I
1 43 2
And there was nothing in his 8
inspection procedure that covered this.
And his first outlook on this was, no, 4
all we have to do is a final visual inspec' tion.
And I told him that in S and L Standards which gives us s
1 s'
our inspecition criteria, what we're to write our 7
procedure from, Form 1701, and there's a chart there e
that reflects what type of welds gets what type of e
inspection.
so And it's my understanding at this time 22 that there has been full penetration welds done on the 22 project before.
sa But the only inspection that they ever received was a visual inspection 24 I
15 BY MR. WARD:
I ss Q
What would that be welding of?
17 A
Well, the inspectors that I talked to there is in your risers for your cables, cable tulls, your sa 1
2o risers.
They have got an attachment in there that's to got a finger type attachment on it that your cables s2 hang on.
They have the sleeves on them and then the
~
i
.sleeves hanga on these finger type attachapnts.
-ss 1
There was supposin'ly full penetration s4 welds ~done on those.
And the ones that were being a
done in the shop was on a flow control indicator.
se+.
--_---,c'- * - - - - - - - -
' - " ' ' ~ ~ '
s 44 2
It was'a bracket.
They ordered them in and it was 2
too long.
They had to cut a section out and reweld it back together.
4 And to the best of my know1' edge, there was no further inspection done on those other s
r.--
- f. ".. s f-than a visual, even after I told them that it required
{
7 a radiograph.
i f
s BY MR. WEIL:
s Q,
Approximately when did this occur?
~
- to A
Some of these flow control valves were still Y
t
(
22 on the bench when I'left on the 27th of August.
12 Q
Okay.
Let's drop back to the -- of your t
4-23 review of the welder qualification records.
And you've I
24 already discussed to a degree that welders took the t*
25 qualification test i
1~
on a half inch plate, but no limit-ing parameters were listed on qualification records se r.
I-i h.~)i and also welders were tested on half inch thick 17 t-j is material.
N'&
The records show (inaudible) were given p 3.-}
so unlimited thickness range.
so A
Yes.
1 s1 Q
I think we have covered those already.
Is there any more material that you'd like to, discuss?
ss sa A
Well, on the test that was given to the s4 E. C. Ernst welders, and in some cas'e the L. 'K.
Comstock welders, the test was given on a 6 inch Schedule 80
a g.
l i
45 pipe, which by D-1.1 Code in the 60 position gives the 3
welder unlimited thickness on the maximum scale.
He can weld any greater thickness.
But it also gives a s
4 minimum that the welder can weld, which is 0.187.
E'.- "'
And as I mentioned earlier, the heaviest gzge unistrut s
t
[..
that we are welding there and our cable pan is 12 gage, t.l' which is.105, which is lesser in thickness than the C
procedure is qualified for.
Now, these welders may have -- I would 8
assume if they're doing electrical installation that 20
- i..
they are going t o be velding on this unistrut, and they 22 t
are going to be welding on this sheet
(.
22 steel, and they-would have not been qualified to weld on that, taking 23 t-i..
their qualification test on 6 inch Schedule 80 pipe.
u i~
BY MR. WARD:
25 7
],. -
Q What code would they have to go to, to be as h.k 27 qualified to.1057 n-. a p' y A
Both ASME and AWS gives a lower limit for as t.~-
- ~ ~ ~ '
2, Pipe welding.
It gives you a lower limit and an upper limit.
On plate it doesn't give that.
Had they taken their test on 1 inch plate, it just doesn't give. the
,3 lower limit.
It just says unlimited.
But-when they take their test on pipe, it gives a diameter, a lower diameter, an' upper diameter and it also gives a lower 1
range of thickness that you are not supposed to weld
.below..
-e-v
,_,.,.,,v.--..m.,,,...
m m ww w m v r e w m - -, w-m,- -
j 46 2
BY MR. WEILi 2
Q What is their comm!tement?
Is it AWS?
a A
AWS, D-1.1, 1975.
However, I noticed on some 4
of our velder's qualification test records that that was also changed and they changed it from 75 to 77 for g.- ;
a o
I. s.
s some rea son.
I have no idea why.
But it has been L.. "
F...
changed and I tnink I might -- well, I don't know if 7
~
s I reflect on that or not; but I know it's some of the
}
same welders that are reflected there.
so Q
Okay.
Was this another one of Ianja's b
22 pencil changes?
t 22 A
No, there was no initials or date for this l
as change.
There was a lot of forms that had changes
~
u made.
There was whiteout on some of the forms and they were either initialed with no date or just completely Is hgmed abgener, bst he dages make.
as I..
BY MR. WARD:
n R,,,1 f..,;t Q
Was the 75 addition (edition), was t' because ss n
w E'-l of the contract dat+ or how did they arrive --
se I
A I think that that was b?,en. se of the contract so
- date, That was the specificat!sn
- cat S and L in their s2 A L-2 7 90.
That's their specification there for the
- s2 electrical installation.
And that's what they said as we were to use, the 1975 edition, D-1.1.
s4 BY MR. WEIL:
47 2
Q So I -- to try and summarize on this point,
.,the welders in the field are actually welding unistrut s
and plate materials in the thickness range of.105 3
4-when in fact their qualifications are an upward -limit a
towards a range of.187.
. r-a A
- Yes, b.'.
p--
7 Q
Therefore, they are really unqualified to do
[
s
'any field welding?
o A
Yes, on the unistrut and cable pans.
Also so on one of their WPS's, I think it was technique or 22 attachment C they call it, they referenced.on'that one 22 I know for sure and some of the other that they used 23 a 10 gage unistrut.
But in doing some checking I found out 24 as that 12 gage is the heaviest unistrut that we've ever F
se received on site.
There is no 10 gage and there ^
27 DEVff WES.
6 l 1.
as Q
The next point is welders with rejected 5.
j'.
1 Positions when you took one test on ratesting.
And as s6 it's your understanding of the Code that two retests 33 are required?
A Yes.
a, Q
I believe it 's two consecutive tests, is it not?
A You take -- the way the Code reads, it says if a weld test is found rejectable, a welder must take two i
---4
.--_--.--~,%--
\\
48 tests in the-position in which he was rejected.
And 2
I a
chose tests pass all the required testing inspections.
t s
I found in reviewing some of the welder's qualification test records, they have a weld 4
a history on each rec'ord in his own file.
I found in some cases there where a man had rejected test, but f:(,-:
a nowhere.coulde 1. find that he had taken more than one
{-
7 s
retest in a particular record.
In some cases the welder did in facts e
[
take two tests and pass both tests; but there's some 20 t
22 cases where the man only took one additional test and I.
to was qualified based on that.
They will be listed on 3
2 there.
]
q 24 Q
Okay, thank you.
Okay.
[
I' ~
I think the next issue may be one and the as r-i.
same.
If you refer to thememo that we're using as the 2s I
outline.
Issue 10-E and 11A.
27 T.-
E - '. " '
A Yes.
ss
- 6... 1 I
Q Are they the same issue?
EN.[.,
1, A
Yes.
,o Q
Okay.
Now, I think we have already discussed
,3 that, the issue of three test coupons done in one day along with the results being given to band test being sa done.
M A
All the welders' qualification records -- now,
~~"*~* "~ -*1
^ 1
49 2
there's a passibility that this welder may have taken this j
s over a period of time.
What I'm stating is what I state a
oh the form here, that all three of the forms had the '
4 same dates on 'em.
And it would appear by those forms s
that he done it all in the same day.
s Q
Let's move on to another possible falsification f.
issue, and that was that you had overheard that an
(-
I inspector had made 1,000 weld inspections all in one -
a day.
~
A Yes.
to Q
Could you elaborate, please?
33 A
Well, I was working in the office space that 22 t
3 3,
also had about 15 Level 2 QC Inspectors working on --
k and here for the last three or four months at Braidwood 24 33 they have trying to been -- they've been pushing --
well, as I call it for numbers.
as t.
27 They have had a schedule set up where they are doing inspections and they are working 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />' r
as
, ~ -
j -
se days, and in some cases 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days, and they're working
\\'-
j 21, Saturdays to get these numbers knocked out.
Now, this is all what they refer to as backlog.
A lot of this backlog consists of post
~
welding inspections, welds that have been done and th'e welders has just run off and left the QC Department and now they're going back and inspecting welds that e
e
? *
.,,___y_____.
_,r.
,,-,,.,-v%
.~n...-+.-..,.w.,,-,i
I 50 2
that have been done, two, three, four months, in some 2
cases.
And I overheard one of the inspect ors 4
in there that was complaining.
He was saying that the s
inspection that they were doing on the. backlog, the a
latest ones, that they were doing it with the ones 7
that everybody had passed up before.
They'd go over h'.'
s to' inspect.the component, and they'd look up and they s.
was maybe a hundred and fif ty welds involved.
So V
so they had the roughest one yet to go.
l' g
22 And supposin'ly our QC Manager, who b-
~
22 was at one time an inspectorchere, had made the comment 23 that he had inspected a thousand welds in one day.
24 Q
Okay.
This is Irv Dewald?
i(
2s A
Yes.
And this is what one of the inspectors r*
2s 1.
f' 27 said and at that time I thought it was a physical t'..-
C as impossibility and I still do.
Maybe it was just a b:f..:*::
P rase that he was using.
But I do know that he did h
yc;-),j 2e
$12 do inspections in the welds, and that I looked at some no of the welds that he supposin'ly inspected, and I would
,3 not have accepted 'em.
BY MR. WARD:
Q This guy -- how do you spell his last name?
A D-e-w-a-1-d.
And unfortunately, he's an old retired Navy chief too.
'o J
51 2
Q You wouldn't know when or approximately he 2
could have.--
A No.
4 Q
-- looked at all these?
s A
No, I just know that he gave me a run through ff a
the plant there one day and he had pointed out some of the
]t -
2 t hing s that he had inspected and later when I was in the field with some of the other inspectors that were going a
back and doing some reinspection, -they had pointed out some of the welds thdy said had his stamp on them.
They 3o
.1 22 also said if it hadn't had his stamp on it and had already been accepted--I was inspecting the veld, 1 22 23 would have rejected it.
24 Q
When you say reinspection, you mean they were
~
going back and reinspecting some of this --
as 7
A Some of this they have lost documentation on, 4
ss 1
27 I'm sure of that.
They even lost documentation while mr.
Es..
as I was there.
l ~-
j.',
as Q
So they were going back looking at their old so welds which some of these --
33 A
Some of these were.
3 Q
That they could have looked at again.
A Well, they got their system all backward to start with.
They do their complete" weld inspection of an installed component.-
And after they inspect and buy off all the welding on this component, then they
- I
,=- =
2, 52 had the configuration people to come out and inspect 2
s the component.
And quite often the configuration p'eople would come out.and look at it and say it's in a
4 the wrong location.
Cut it out.
And so they have s
to reinstall it.
[T ~]
s I.really think it should be the other f_..
7 way around.
They should find out that it's in the 8
'I.
a right location before they buy off all the welding on it.
s BY MR. WEIL:
h.
so Q
Are we intimating here 'that Mr. Dewald is s.
I unqualified or is it being said that he, for lack of 22 i
be tter phra se, b' ought off cheap?
I 23 a
2 A
I really don't know.
I think that -- I don't
{
~
think it would be a bad idea for -- to possibly identify
~l 24
}
1s and look at some of the welding that he done.
I really
+
{'..
26 don' t believe that he could have done an inspection v,p 27 on a thousand weld s in a dpy, even on a production line.
sa BY MR. WARD:
3J.j Q
Do you know when he was an inspector, what s
7 r
so period of time?
A It was in the earlier stages of Comstock.
31 j.
taking over there at Braidwood from E.
C. Ernst.
But I'm not at all sure when it was, s4 Q
You don't know what year, approximately, that vas?
+
l e
e
________________-....--.,m.,
.,u.
.._,,u-.._..
.,,,_,-,_.4
,_,__._,,_,._,,,,._mm_.,.,m...._,,,,,,,_..,,,...-%,__-n,,,,_e,c,_m
4
~
53 1
A I thought I heard him mention once that it s
wa s in ' 82,.but I really don't know, not for a fact.
s BY MR. WEIL:
Q Do you have any idea what types of inspections 4
1 a
he would have done?
F-,,
[', ' '-
s A
Visuals, only.
.I
~ '
s Q
Visuals only.
L s
A That's all they have their people qualified e
i g.
i, e
to do.
f i
so Q
Okay.
So they're not doing -- they're just j
i is doing -- they're just doing visuals?
E A
Just visuals, 12 r.
as Q
No, if there is any PT or MT required, it is 24 A
is requested that PTL do that.
L.
2s However, none of the inspe' tors ever e
L r.; _.
27 recalled anybody requesting that any radiography be LP.7' 6~ eN 2a done on a full penetration weld or UT or MT.
1 IS
- t E1I21 ss Q
Okay.
That's opened up another area.
What I just wanted to nail down on Mr. Dewald is, do you so 1
si have any idea what components or structures he would have been --
A Just on electrical installation, cable pans, hanger ~s, Q-Cables and hangers, okay.
m-m
>r.,
n.,,4
,--,___.,,a-e.__
,,e,.
-..usm w
54 4
2 A
Support steel, s
Q Maybe this comes from just my general lack o'f understanding here., but I am having difficulty understanding why why Comstock would need' procedures 4
a that discuss MT as one example where we have MT on stainless when anything besides visuals is being done s
7 by Pittsburg Testing Lab.
Why would Comstock even need a
these procedures?
A I really don't know.
Quite a few of the 3e procedures that I looked at it seemed to me that the si people that wrote f em just found an area in the Code 22 that dealt with the particular thing that they were 23 discussing and wrote it word for word out of the Code.
24 Q
Would not Pittsburg Testing Lab be operating 25 under their own procedure, their own quality program?
A Yes, they do have their own quality program and 2s n
27 their own procedures.
2s BY MR. WARD:
(;
- 2, Q
Are they working for Comstock or' for --
~~
so A
No.
Q CE CO?
,g I
A They are working for CE00 3,
Q And they're at the same plateau, same level sa as Comstock in -- Comstock works directly for CECO and PTL works directly for CECO?
A Yes.
'~
t, 55 1
2 BY MR. WEILr 2
Q 0,kay.
Is there any other information you'd like
~
s to pass on, on the welders, your review of the welder i
4 qualification records?
j s
A Well, basically, what I have is is listed I',
s on the form there.
I do know, like I say, presently, i
v now, with our currently qualified welders that we have
.'i
'on the project now, a lot of those welders took the a
test on the site back during the period of E.
C. Ernst; l
20 and they took the test t ha t E.
C. Ern s t wa s givin '
i e
then for the qualifiestion, which was a 9.2 procedure, q
22 2:
Later, through loss of their card or through termination and coming back to the site, they la 24 did not take any additional testing.
However, they I
is were issued a Comstock Card that now says they took
}"
2s the L. K.
Comstock procedure, 4.7.1 which deals with I
\\
their welder's qualification and it reflects in a lot 17 b~'l 1.-
1s of cases that they took the test on plate when in fsets h~.
i 15 ~
2, the only test they ever took was on pipe.
And it was F- ~1 so for a different contractor.
at EY MR. WARD:
's:
Q And you said that is in here?
You referred to a form.
A-No, no.
I do not have that in there.
Yet 34 some of those welders are involved.
These are current
~
b
--..-- r.
m%
_.,,,,4___mi.
,,_.,._,,_---,.,,_.,,....._.p,,..w,--,.c
,.y.,-.,2--v.y..
y--.y-ey
4 56 1
welders that I was talking about that took the test, 8
that -- presently, right now, because I had one to come a
back to the office, s'nd I can't remember his name.
4 Here, a short while ago they were checking on his quali-5
.fication for some reason.
And I noticed that the welder 's s
qualification card that he had had 4.7.1 on it and I 7
had to pull his qualification record for some reason, s
and he had taken the E. C. Ernst 9.2 procedure and had s
qualified to it and it was for 6 inch Schedule 30 pipe.
to So I know that some of the current v Icer:
i 11 that they have now that qualified originally fr>r E.
C.
Ernst and only qualified on pipe now have an L. K, u
Comstock qualification card saying that they qualified 2:
to our procedure 4.7.1 and that they run their tests 24 ss on plate.
as BY MR. WARD:
n Q
Do they still have copies of that other 3
company's procedure around that they qualified to?
t A
Yes, they have copies of the procedure and u
I -- -
supposin'ly it is equivalent ' to our 4.3.3 procedure go which we are doing our welding to in 'the field or the at 4.741 which we are "use" for testing our we'iders in the test facility.
In facts, I think Ernst may have had ss a little better-procedure than what we do.
There are not near as many inconsistencies in it as there was in our own.
l
57 2
Q This next issue I surmise goes fairly closely with your review of welder quslification records, and s
that's the issue of the hammer log where you found s
one welder was simultaneously given stamp' numbers 23 4
and 1.3 and at the same time two other welders were 3
assigned those same stamp numbers.
7 Would you go into some detail on that please?
A Yes.
In a review of the welder qualification so test records, I noticed that the one welder, his name 22 ison the. list there, and it's outlined on there --
Q For the same of the record, could you use 22 sa the name please.
It would be a little easier.
A Well, I would have to find it.
It's on here.
24 It w uld take a moment, but I'm sure I could find it.
as Q
We're talking about Godsey, Murrey or 26 Vanduyne, if that will help you.
27 i"
A It seemed like.to me that it was Godsey.
sa BY MR. WARD:
29 Q
It says the welders were Godsey and Murphy.
and then --
s2 A
Okay, I have it here.
I have it, written out here, W. Godsey, and his. brass number was 772:
Test record reflects test was given on a'6 inch Schedule 80 s4 Pipe, A106 Thickness range reflects unlimited.
Thickne s:
T-'
r 1
58 should b'e 0.187 to max 3 welding.
Welder's stamp on qualification form is 123.
This stamp belongs to N, Vanduyne.
Welder's stamp on the qualification s
card is 123.
This stamp also issued to R.. J. Murphy.
4 In checking this hammer log, I i
noticed -- of course, I wasn't doing a review on it.
'h;[)f I was trying to clarify this record.
1:.
j
[-'
In checking this man's record I found out that he had two test records in there reflecting I
tv different stamps.
And I thought it was a clerical so c
j 1,.
2 22 error, typographical.
i.
as I went back and pulled the old master hammer log, which is the unique identifier for the 7
2 welder, his stamp issued, that he stamps all of his 24 j
welds with.
I pulled the stamp log to see just what 3,
t stamp this man did have.
He was assigned stamp No. 23.
36 s.
1.
And I also found another individual, i
17 just in a quick review, just a matter of seconds, that t.:.11
[, ~,;F 1 also had that number:
And the 123 belonged to an-a s. r. i 3'
r
'N entirely different individual.
And it was also assigned Shi&
'30 to several other people.
And I just went back up to s1 l
1, and I looked at it and I could see that there was ss two on three Wifferent people
- assigned No, jl. as well.
ss Now, this is ta unique (d.entifiep.
No i
S4 welder is auprssed to be assigned but one stamp, and t
l L
.\\
59 these welds ~in the field, they are identified with 1
a his stamp. number.
That tells what welder done that i
a Weld. And if you've got a half a dozen welders or 4
more or with the same stamp number, it mak'es it pretty f,-
1 s difficult.
A welder's qualification is considered g..-
j e
indeterminate or something and you've got to identify i
7 the welds that he's done in the field.
s BY MR. WARD:
j o
Q Did they have a procedure of some type of how these are to be issued so that only one person is to so l
n receive a stamp?
u A
They have a procedure that says that the i
welder will be issued a unique stamp.
That is in the u
Procedure that governs the testing of the welders in u
u the weld test lab.
Q Do you know what number that --
u A
That's the 4.7.1.
p
- ,',}
But in the procedtre that they have there,
' ~ - -
there's inconsistencies in it as well, because in one g
area there, and this was pointed out to the people a week or so after I got to the site, that it says in there that the welder will mark his test coupons with j.
as his initials.
You feasibly could have two or three
- a sl People'in the test lab at i
the same time with the same initials on the plate.
I I
4
~.
60 a
Since then they came up with a unique identifier for identifying the plates inasmuch as they s
s use the first-two digits of the year like 84, and then s
4 give a welder a number that reflects the time that he l
I2?Il a tested in the test lab as 64 dash 1, meaning the first
(-
j-welder in the year, 84, 84-2, and so forth and so on.
I i
l 7 However, that is an entirely different
]
s
. number than is issued out of the master hammer log.
l These numbers are in-supposin'ly they started wi th-No. 1 and it went to the first welder that welded on the a
n Project and then No. 2, and it's up in the 400's now.
l u
It's up somewhere around 456.
And I'm sure we'd have
)
l a lot more test records than 456 3
I i
And one welder for some regson requested u
a number in the 500 series and they gave it to him.
t
.L They donic have a procedure that says how 'it will be r_.,
f.?-,i done.
It just says that they will be given a number, f
-\\
[u the next one in line from the master hammer log.
f,"',',l Q
When some -- when an individual is terminated one way or the other, evidently they're to be returned.
A They -- basically what they issue 'em, depending on what their number is, if it's a two-digit number, it's l
SR two low stressed stamps.
And they will usually weld these as toget'.ser and weld them to the metal handle to make them i
se into a hsemer for stamping their v~ elds. -
j
-. _ _ _.. _. _ -. _. _ _ - - _ _ _ _.. _ -..., _, _ - - _ _ - - - ~ _ _., - -. - _, _ _ _
4 61 2
They do in facts, turn these in when they terminate from the site.
They turn in the welder's a
qualification card an.d the hammer log.
But up until I s
4 got there in May, there was nothing in the' procedure that made anybody responsible for receiving these a
hammen and these weld cards and getting them into a
Y the test records.
s I instructed the stuward, who was usually e
the person, the job steward that he was to return this hammer to me and the welder's qualification card so so I can make sure the correct thing was done with them, st u
Before that. time, it's my understanding l
that we would just give it somebody in QC, anybody in 3
34 QC and that they were supposed to turn it in and see l
1 as that this welder's qualification card got into the 1
man's weld history.
as Incidently, in all the ones that I've 37 1
u checked, there is very few that has any welder's quali-i.
,j, y
fication cards in that had been turned in.
Ib 4
Q Are these hammers locked up at the end of the day so no individual can, you know --
at A
I really don't know.
I know they have their gang boxes in the field and that they -- I'm assuming as they would lock them up.
But again, like I say, they're as made with a low stress stamp; and you could invert the
7 t.
62 l
l 1
numbers if you didn't weld them together, and there --
l no requirem'ent that they will weld them together.
The s
n'mbers could be inverted or used in any manner seen s
u 4
fit or anybody with a set of low stress stamps could s
make any number they wanted.
py -]
f,_
e MR. WEIL:
Any more?
i I,-
7 MR. WARD:
No.
f,
~
s BY MR. WEIL:
s Q
Let's move to an issue that I think we have i-so started.
I don't know if we finished with it.
It was 11 No. 9 in the outline.
t u
Many of the L. K. Comstock field welders are qualified to procedure 4.741. However, the procedure u
}.
34 is not traceable to Coastock welder procedure quali-fication' records.
Welders were originally tested on Schedule 80 p$ pes.' But the current procedure is first t '.... :
to test on plate.
\\
[ii1 I
k-4 A
Yes, that was --
E s -; u F - '.
'Q Continue with that.
to A
-- the one that I mentioned a moment ago that the original test they took was for E. C. Ernst.
s' And they took it on 6 inch Schedule 80 pipe.
And e
~
invariably through termination or loss of card, or whatever they were reissued a welder's qualification card; and the qualification card that they were issued now
/
/
l
t.
63 1
references that the qualification they took was in accordance with Comstock 4.7.1, which is not a
so.
There i's no record in their records that references that s
they took anything other than the 6 inch Schedule 80 pipe 4
s a nd to E.
C. Ernst procedure 9.2.
-Q Okay.
By.the phrase, loss of card, what do you mean?
What do you mean?
A Well, a welder could lose his card.
He could e
take it home with him.
His wife could wash his clothes, or it would be destroyed, or just over a period of time it w uld get worn.
n Q
What about having his card revoked, could that be included?
18 A
To the best of my knowledge, that never 14 happened there.
I think a lot of the inspectors were 18 t'
aware that if a welder's welding in the field was of a as Ig' poor quality that they could recommend a requalification.
17
[.
But I don't know that that was ever done there.
t...-
u.
Q (Inaudible) ever instructed not f.~..M to proceed 18 with such a meth'od that you know of?
so A
I mentioned to the QC Manager there again m
and to Bob Seltman (ph.), who is the QA Manager that 93 there was welders in the field that had these quali-as fication cards and that they weren't qualified to our as procedures, and that the qualification card should be brought back and corrected reflecting that they took
\\
I 64 I
an E.
C. Ernst procedure and that it was on 6 inch Schedule 80' pipe and just make some notation that it s
i c
a is equivalent to our 4.7.1 procedure.
4 BY Md. WARD:
s Q
Couldn't there be a copy of that card or l
p.-.
s something in the file someplace instead of -- would l
7 there just be that one particular card and not
.s A
That's the only one, that one particular card.
l e
Now, I don't even know what kind of qualification cards that was issued by Ernst.
to
)
at I know the ones that we issued in my l
opinion is a very poor grade.
I think it would be u
very easy, because the information is typed on there, 13 I think it would be very easy for the information to 24 as be changed on there.
l~
1s It was my intention had I not been f,,at terminated that I was going to revise the 4.7.1 procedure j.l,:.;
that deals with this,,and I was going to cover it more u
l'*.1 t... - -)a to thoroughly.
And I yas going. to recommand a laminated
- ~
welder's qualification card where changes could not be so at made on it.
as BY MR. WEIL:
[
1 i
as Q
Why would the welder's car.d bear that much significance, when I would think controlled records as would be the actual documents of concern.
.------.y-~-----_n,m,.,_-,~-y.~,-_.v,,..--__.,,.,m,
_____r_s-_____._._....e_.,-
.,,,m__..-_-_..-._,_.,,.,__,.,....__....m._,
2
)
i 65
~
1 A
For a welder to draw filler material from s
the fillet. material withdrawal room --
a Q
Um-hum.
4 A
-- he's got te present his welder's quali-a fication card.
And the one that he has, like I say, one that has been reissued, gives him unlimited thickness and he can weld any thickness that he chooses with it.
Whereas if he had one for E. C. Ernst,
it should have reflected that he had a lower range that he could not veld below.
33 Q
So what we're really saying here is the significance of the card is for field verification u
when materials are issued?
A Yes.
Q Okay.
And any changes, alterations made to it could lead to materials being issued to a welder
}
17 1
who wasn't qualified wo work with those particular --
to A
yes, sir.
to N -- '
Q
-- materials.
so A
One of the fallacies of their 4.7.1 procedure was they use that to qualify welders for all types of m
welding.
That is, if they were going to qualify a as welder f,or aluminum, they would use s 4. 7.1.
If they were going to qualify the welder for stainless or carbon l
__ e
_.._..,,,,_,.,._,m_
1 66
{
or for just using 6013 electrode, which is an entirely 1
a different procedure.
They qualify them all to 4. 7.1.
1 s
All their qualification test records reflects this 4
number, 4.7.1 other than what procedure th'at they would be qualified to weld to in the ['teld.
p
- 'i s
4 e
Also, in the top righthand corner of f,
the form it has an area there that you are supposed 7
c s
to fill in the welder's identification number.
A e
L. K.
Comstock has used his brass number i
no up there.
All the forms that I've seen previous to this in other parts of the industry, that area ~has
~
n
~
been reserved for the unique identifying number that t
u 3,
you assign to the welder.
Because a welder will 1
j.
terminate, and he comes back and they give him a
(
u different brass number.
And there is some welders u
1 a
that have terminated a half a.dores*diffe' rent times',
{.,.
and come back and retested.
They have a half a dozen
.6 y...y different weld forms, and each of them have a different 7.. :
identifying number in the top righthand corner of their welder's qualification test record.
And it only reflects that they qualified to 4. 7.1.
It does not say what they can -- what procedures they,can weld as in the field, m
Q Item Fo. 8 on the outline I know we've covered, and that's your list of welders. -
)
e
-w-w
i c7 1
7 Yes, that is these.
s MR. P.r.I L t That is the vellow pages, fine.
s 8
BY MR. P7RD:
i O
can you state -- these are about half of the i
a pages that you looked at --
s b
Yes.
Fell, I have these --
T 0
-- that they have --
s 7
7 vent throuch the ?!'s.
Let re get this over here where 7 cbt: Lon.v IT 77 Prrbt.cr I heve ther Ielelef, e
the $1's, the P's, the r's, the K's and the L's enr1 so then L's and then T not Fach into the 1's and B's.
gg 7 cot the T's and the ".'s enf 7 got the F's and the g
J's end all the rest nf ther 7 never act around to 3,
checkine there.
y O
So about what vereentacc would you say that you as looked at of the velders there, approximately/
Is 7
7.nproxirately 50 nereent.
rne 7 found vhat T 37 i
consider raior inconsistency in at Icest 50 percent of p[j.., ' '
those records, and sore other rinor inconsisteneies.
l
)
l.
E;;'q' O
!!ow r.any welfers do they heve altocether at constock, arrroxtretely?
tt's ry understanding now that they have sor$cvherc
- A around a hundred and eichty welders, but through the m
years they've been a lot of welders --
O tir-hur.
A That have terrinated.
68 s
BY MR. WEIL:'
a Q
Two questions.
First, this list that you l
'have here and your review of the welder qualifications.
s l
4 It's my understanding that it represents those welders that are current employes.
A No, these are just welders -- in facts, these are welders that are not current.
They are not t.
i there now.
- 1.,.,
Q I see.
l i
i A
I have a record here that I had started s
no earlier of some of the welders that were current l
welders.
Q Okay.
\\
n i
A Okay?
There's 15 of these that are current i
j welders that I found fanles within their papers, but as when I started this review, I was just going for those things that were what I considered major inconsistencies.
i i
8' i
These are some minor things there.
P-NB b*,,
Q Could you for the sake of the record explain l?".,;
I T
as g;;.
what you consider to be the major inconsistencies?
'I A
Code violations, i
at Q
Euch as?
i '.
m l
A Thickness ranges, types of tests that are as I
l' performed on a procedure to give it
- acceptance or for as welder's qualification.
Basically, that's what I'm
t 69 L
covering, ahd the number of tests taken.
2 I
8 Q
Okay.
Let's go to the problem with preheat.
s helds were made without the required preheat, that 4
L. K. Comstock developed a procedure in which they s
could make the weld without preheat, but during the qualification of the procedure the quality control e
people did not monitor the making of the weld coupon.
l
{
v l
A Let me explain this.
s Q
Yes, please do.
A I was involved in this myself.
3 I
21 Q
All right.
A We had a condition in the field where one 22 t
of the inspectors came to me and he said I was required j
is to do a post weld inspection on this weld and we have
{
34 l
an attachment plate to a beam that is greater in 3
, thickness than an inch and a half.
They used a pre-g qualified procedure to weld it with.
He says, what 3,
can I do about this.
He says, according to our pro-u i-cedures it required that they use an elevated preheat.
a l
I says, yes, if you're welding--, any time that you're i
welding above an inch and a half thickness it requires st
)
an elevated preheat.
I would suggest that you write
).
. si j
a Non Conformance Report.
l sa They wrote the Non -Conformance Report s4 and there was a little bit of hassel about it there 1
i
--w-r-.m----m..-,
+. -, -
,,,-.,-,.,.--,--,w-,.~
-_,_,...~......-.s..
--,_..-----.,,...n...--.,
,,,-m._.
70 j
2 at fir s t.
They were saying rather than -- well, how rather than can you say the man didn't use preheat, 8
how can you say the m.an did use preheat.
There was s
4 no reference to it on the welding installation 5
record.
So they finally let ' em write t he NR on i t.
[" '
And they wrote the NR and it went to the engineering s
5.-
department downstairs, 7
s They, in turn, came back to me and b
asked me what can we do about the problem.
I said, j
so well the first thing that they're going to have to do --
I said you could have a generic problem here.
I said 22 this happens to be one weld.
I said but there could 22 c
23 be many welds out there like this.
I said, so I would
)
suggest that you do a mas partical inspection of this 24 particular weld to make sure that we don' t have any 18 g
surface cracks or any cracks of this type.
2s 1
And I says, then it is my suggestion l
(hi,{
i 27
- --n1 that we qualify a procedure using the types of material
)
{l,];j 1s j
laL-s 2'
without preheat so that we can make a satisfactory weld I said that's the only way you!re 80 without preheat.
i So he going to justify this Non Conformance Report.
32 says, okay, but I'll need to know what ty, pes of coupons
- sa to have made up for the procedure, qualification.
i sa So I gave him all the measurements of ll s4 the coupons that I needed made up, and it was approximate 1 i; i.
--..--,--m.__
..___.~,.~,---m__...,,...._-..-____-..-,s._,_..m.
71 three weeks later this engineer came back to me and he 1
said I need you to come over to the feb shop with me.
s s
And I went over there and he said there's your test 4
plates.
They were laying on the bench.
They were s
welded out and ready to go for test and inspection.
a I said, wait, who welded them?
Who witnessed the 7
test.
And he says, no one, I just thought you needed s
'em welded cut so they could test fem.
And I said, no, e
that isn't the way it's done.
I said, now, we're going to have to get new materials and requalify this so as procedure.
u And I said, everything has got to be i
t 1s monitored.
I said we've got to check the fit-ups and 72cA the son on the coupons, the root openings; and I said 24 as we got to check the amperage and voltage on each pass, the rate of travel, I said, the whole bit.
I said, we've r
is j-n got to have the material by heat number, the thickness I..'.
I,,-
u range, the whoe bit, and he said well, as far as I know, as they've always done it this way, so I said, no, you've got to be wrong.
I st
. sincerely hope you are.
And I said, meanwhile, if you this procedure qualified you're going to have to se want t
as get some more materials.
I think there was a 572 se haterial involved in this.
And they hadn't done that up to the point that I left.
l 72 Q
Okay.
So we don't know as we sit here s
whether they ever went back to qualify the procedure l
s horrectly?
j 3
l i
4 A
No, I do not.
The Non Conformance Report would still be open'because it was disposition tha t 1
a s
they requalify a procedure 7
BY MR. WARD:
s Q
What procedure is this that you're talking e
about, do you know?
so A
4.3.3.
1 i
21 BY MR. WEIL:
1 j
u Q
Okay.
Who was the individual that said l
i that this is the way we've always done business?
2s 1
u A
His last name, I don't know.
He was one of I
the lead engineers downstairs and his name is Dave.
ss a
He was the one that I was qualifying the procedure for.
i
{
37 I think he was the one that made the dispotition on the
['.. ',
y Non Conformance Report.
I' ~
i l'
Q Okay.
[2-..,'
A And incidently I don' t have a number on the so at Non Conformance Report.
.in Q
That's no problem.
se MR. WARD:
That was going to be my next question, as the number.
BY MR. WEIL:
.--.. L
A l
i
/
73 1
)
i 2
Q Do you have anything else?
s A
Seem like his name is Bran Kamp or Brad Kamp s
or something of that nature, Dave Brankamp (ph.).
4 Brankamp or something of that nature.
I've heard his i
s name mentioned,.but I just referred to him as Dave.
e Q
Let's go then to item 13 on the outline memo, 7
where you're concerned with Bob Wickes who was the QC i
s Inspector in charge of the weld test boltage test booth, i
e and Wickes also has conflicting assignments to make i
no inspections in the fab shop and also routine inspection
]
st in the field, i
]
u It was your observation that -- with 4
sa these conflicting job assignments that no one is from 24 quality control watching the test booth.
i i
A This was through Bob's own statements.
~
ss as Q
Okay.
i r,
}
n A
When I got to Braidwood, I knew that I was l
going to be in charge of welders.' qualification.
And u
1
- 1. asked who was currently handling that, and they said u
l...
j so Bob Wickes.
I went and found Bob Wickes and I got him i
j m
to take me down and show me the test facility and.
j m
explain to me how they were running their test down as there.
)'
as He seemed to be the most qualified i
person at this time in the organization to run the e
r w-,rw--me,,,,---,m---- - - - - - - -
-ww,w-m,g--r-,--m,
,n-w--,n,_m_-,
.,n w-,,nm.,,,,
e n-ww
,----m----w--n-.e
i s-2 1
74 I
1 welders! qualification test lab.
He was pretty l
)
s knowledgeable on what he was doing.
His complaint 1
t' was that they wanted him to run 'the test facility as 4
well as do the inspection in the shop and in some s
cases go in the field and do inspections there.
o It was for that reason that he requested' 7
-- be taken out of the test chop altogether.
I wanted a
to get him back in there to test my welders for me, s
but he didn't want no part of it because he didn't so think it wa s going to change,. that he would still be 21 required to do shop inspections and field inspections, n
and that he couldn't cover the welders the way that 4
as they should be, 34 Q
Was this ever brought to Irv D'vald's r,
e
[:
as attention?
v.'
F -.;,
as '
A Ye s, y e s, i t wa s m o s t d e fini t e l'y wa s.
I L,I jy ;j 17 told him that I needed a fulltime person for the test b' SU u
facility and he just out and out refused it.
He said l
u-that person can also do the inspections there in the so shop.
m
,Q And what was his reason?
l-
'm A
He did not give any reasons.
We,11, at one as time he did.
When I told him that we should have a as representative in the weld rod issue shack to oversee the issuing of, fillet materiah he said something to j.
b
75 1
to the effect that I've already got 60 assholes to a
watch.
I ain't got room for no more.
s Q
Okay.
So you're saying too that QC does 4
not do c there is not pr e sent for veld rod issue --
A Oh, there is -- they have no control over it s
whatsoever, y
Q Could you e7aborate on that phrase, "no
. control over it whatsoever"?
A Well, they have a procedure that tells how this fillet material is to be issued.
But it is issued to a craf tsmag from a craftsman and it is --
n l
or the procedure that they had while I was still there, u
3:
I finally hounded them until they were making some changes in that procedure.
But the procedure that 34 as they were using when I.get to Braidwood is the welder r
f, did not have to return any unused fillet ' material.
He u
T could check out 20 pound of fillet material on one 1
n
(:.,i rod slip for one component and if he only used two pounds 7,
l-.*
S on that component, he did not return the remainder.of that.
He could use it on any other component that he so s o desired --
BY MR. WARi):
Q Do you know the number --
A
-- and there would be no reference.
Q Do you know the number of that procedure ?
A Of the fillet material control procedure
76 2
it seems like to me that it is -- it 's either 3.10 or s
4.10.
It ' $ 3.10.1 or 4.10.1.
And it was bad.
They have designated recep,tacles in the buildings, in the s
l turbin buildings and things where they dump their 4
s electrode stubs.
But in turn the laborers come around s
and take those receptacles and dump them into a big p.
dumpster there and there's all the fillet material, 7
e all different types that you might want right there in e
the open.
so MR. WEIL:
She just paged me.
Probably si the representative of labor is here.
Why don't u
we continue.
I think we are starting to come s
into No. 5A, Kavin, which was the area's
[-
to material traceability and weld fillet mat'erial
~
u b
controls.
So if you could continue.
a as
?
MR. WARD:
You want me to continue?
u
{
(Brief recess.)
n
.MR. WEIL:
We now have a representative of
/. ' '.
zs lJ:'.*:2.'
the Department of Labor with us.
A6d we'll go
+
u b".
~
e-il back on the record.
t EY MR. WE1L:
s1 as Q
When we broke we were discussing material 1
se traceability.
We've pretty much. entered into what is 1
ss outlined as 5A, the -- Comstock does not have any l
1 l
weld material controls and the procedure was being written at the time of your termination.
I think
.i r
77 we had pretty much explored --
2 A
Well they had -- they had a procedure that
'supposin'ly was to control -- well it was a fillet a
4 material control procedure.
But they had no controls.
~
That's why we were rewriting the procedure so they s
e could regain a little bit of control on the fillet 7
material.
s BY MR. WEIL:
s Q
So this I and 5 is bein's now written --
so A
Yes.
n Q
-- and the rewritten is the same.
3' u
A This was some of the things that'I brought up when I first got there.
I was on the fillet q
24 material control, and I kep pushing on it and shoving as on it and shoving on it and finally they did in start--
'I u
in fact start making changes.
n BY MR. WEIL:
L..
f ' '.
u Q
Okay.
So what we're talking about is a Li_
w rewriting of an existing pr6cedure.
so A
Right.
32 Q
The second item that we had listed as -- and
'l an it was listed as 5-B was fillet material withdrawal as forms have inconsistent heat numbers that you cannot se find ar.y paperwork to back up the heat numbers in either L. K.
Comstock or Philips-Getschew's files.
v
.,m,
t.
3 76
~
2 Wbuld you please elaborate there?
s A
Yes, this was on a -- one of the findings of a
yo'ur resident inspectors there at Braidwood.
He checked 4
a period, 5-25 through 7-22 of '83, approximately three i
i s
months, and he found some inconsistencies; and they I
e sere written up.
O y
I done a follow-up on this.
And in the a
Process of doing this follow-up, I checked some dates Prior to these and some after that right up until '64, e
seeing if we had possibly a generic problem here.
And so at in facts it did exist.
I wrote a memo to Irv Devald u
on ths stating that there was some other inconsistencies as and that a Non Conformance Report should be inisted for the three types of fillet material, that is heat u
as numbers that I could come up with no certification
~
.a papers on.
Our material is all issued to us through n
u Philips-Getscheu Company or through direct order that 3,
comes through the client CE CO.
I obtained a master list so of all of the heat numbers that Philips-Getschew had si received and the three heat numbers that I found on g
the fillet material slips were not on their master list and I went through all the records of CE00 that they as as Permitted me to look at any way, and there was three heat numbers, the same three heat numbers that I could
- -,.., - - -, - - - -, -. - + - - - - -
79 s
not come up with.
One of these was on 6013, and the others,-- two were on 7018 fillet material.
a
's A lot of the fillet material withdrawal slips that we had there had such~ things on them as 4
f
{}
s E 6013 rod, but the heat number. reflected was for a
E7018 rod.
And in some cases we had conditions where we had a rod slip that reflected the E 7018 and the 7
s a
heat number on the rod slip for the fillet material o
turned.out to be 6013 rod.
And this does seem pretty so "pervelent" (ph.).
I checked rod slips in May, June, and 2
u July of '82.
Again I checked rod slips in September of '83, January of '84, and July of '84.
And we did ss have problems in these areas as well.
But it was just 24 i...
a 4, quick -- I just went down and looked at 'em.
I didn't u
L.,
. se take down to many numbers other than some' heat numbers I :. "
['
27 that looked unfamiliar to try to check their authenticity.
T..l u
Q
- Okay, y
A I have the memo here that I issued to Irv Dewald that deals with that, these dates, and what my so at recommendations was.
ga BY MR. WARD:
4 as Q
And these have the heat numbers that you're se talking about?
A Yes.
~
o 80 1
This is also a memo on the same thing, s
This was the one that--
a BY MR. WEIL:
4 Q
Let me stop -- was a Non Conformance Report or any sti.r controlling document written as a result f " of thir ne m nndum?
the best of my knowledge,there was not, 7
A
.s i
This was the one that your resident a
inspector was concerned with.
These were three heat e
to numbers that he came up with, that the rod slip reflected 7013, and the material turned out to be 7018, that is 11 u
the heat number wa s for 7018 material.
There was one la rod slip amoung about 14 or 15 that he found that referenced 7018, and the heat number was for 6013 rod.
14 Is Q
So this concern then and it's a memorandum 1s dated April 15, 1984, really started you, to look at 17 fillet material traceability.
A Yes, I want to find out if what your inspector u
. found in the two or three months that he was looking
~
1s just rod slips that was issued during that period of so at time may be generic throughout the --
si l
ss Q
Okay.
Then the' results of your efforts to follow up on NRC's concern are documented in this as e
os Augu'st 17, 1984 memorandum?
A Yes.
-,em,
81
~
1 Q
And that'.s the one we have already discussed a
where there were three heat numbers that you could a
not find the certificates of conformance or documen-4 t a tion you needed -- the Philips-Get schew, L. K.
s Comstock, Commonwealth Edison files, correct?
e A
It is my understanding that we also received l.
7 some fillet material from another contractor there which f
s is Pallman.
o I called their QC representative, and so I gave him these three heat numbers and he checked his 11 records and he had no records of these three heat numbers u
either.
as JIY.MR.. WARD :
24 Q
He took these numbers off of the --
i i
as A
Off of the rod slips.
as Q
Off of the rod slips themselves.
You wouldn't 27 know what the rods themselves or the cans'.or whatever --
1..
7-i.;.
u could there have been a typo on the slips and --
L::.
- 4. qj u
A I tried to cross these heat numbers with E50 I go purchase order numbers, with lot numbers, with any other number that may be listed anywhere.
I tried to se invert some of the numbers used part -- apart -- there as was no way I could trace them to anything, as I honestly tried, and in facts that one there I even made a call for the company, you know.
I Save them an out for it.
u 82 1
BY MR. WEILt s
Q Which supplier was that?
A This was the one there where they were con -
a corned with the 6013 rod.
This was the on.e that your 4
a resident inspector picked up.
I made the mention there s
that the fillet material that was issued was 7018, that it could be used in lieu of 6013.
Its strength was 7
exceeded or matched that.
That was required for the a
components that wa s being welded.
Q Item No. 6 on the outline I think probably so e
relates to what we have already covered, and that was that 32 N
2 you found that L. K. Comstock does not have any control 3
J
~
of its construction materials.
This is different
.f 13 i4
['}
u w were talking about --
R y
ts A
Yes, we was talking about fillet material.
'i:
3Ris is construction materials.
\\
.~
9 se
,}
27 Q
Right.
In terms of construction materials, n
[]
s[..
Ar terms of heat numbers or other traceability, would u
S.
j p
3pm expand on that, please?.
.g.
O,',
g,
}..- - s
'so A
Yes.
When I fir st went to work for Co'bstock E-
%Igot a little tour of their smiding fabrication shop, m
N ebb electrical fabrication shop, which is directly
.m h bhtsw our office spaces.
And I was looking at some
> kj se af' the completed components there, components that they I
sa tra inspecting and I did not see where they had any
-*+I
l 83 i
2 kind of heat traceability on them, on the component.
i s
And I asked the inspector at the time, s
I'think it was -- in fact, he was the inspection j
4 supervisor.
His name was Saklak.
And I asked him s
about their traceability on the' material.
And he e
said that all their materials are just received FT' with a purchase order number on them and that it was
(
k.
s CECO's statement that all of the material that they s
received was a certified material and that they did not so have to transfer any heat or lot numbers to any of these n
materials,that they j:ust use the purchase order number.
.n This purchase order number was painted 3:
on to the material, could very well wash off.
A 3
iP ece of material could be cut off and a number get --
n 1s the wrong number being put on it.
3,s And the materials in the field that I br done my in process inspection on there, I found no kind
?
l..a of numbers whatsoever that would tell you even what
,,, w' type of materia'l it was, much less a heat number or a i
g.
~t Q
lot number for it.
m I explained to them that 10 CTR50, Bendex B, Criteria 8 said that we would maintain traceability on materials up until time of installation.
And L2790, which was contract specification said as much.
I asked them about our procedure that controlled t
s,.
t 84
~
1 materials and it appears that we had one at one time, a
but they took it out of the book because CECO said it s
wksn't necessary that they worry about heat traceability, 4
that all of their material was good materials.
.s SY MR. WEIL:
s Q
Do you have this documented any place or any --
7 A
No, but it's very easy to check for yourself.
.s You look at any piece of material in the field.
You o
can go-out there and point out a piece of -- in so electrical now.
I can't speak for the other contractors.
It I don't know about those.
But you can go out and pick u
out any electrical component and point out a piece of as material on it and say come up with a heat number ror this and they won't be able to do it because there is 34 2a nothing on there that tells them anything.
Their weld inspection records shve no place to 'put heat
- d so i
i.,
sv numbers on it for the materials of any type.
!'. 1 "
- 1.. ~.:..l ss BY MR. WEIL:
se Q
Before we move on to the area of intimidation and harassment and your employment termination, are so there any other technical concerns that we need to si discuss that you'd like to bring about?
i se A
Well, at this time, no.
I mean, nothing as other than what I've already got listed, you know, that as l
pretty well covers it with the exception in the test I
.4-
^
85
\\
tecility.
In the period of time that I was there, they kept reminding me that I wasn't qualified and I
- asn't supposed to sign any quality documents.
I
. ' $Ld not sign anything during the period of time there
- i Ikat I consider a quality document.
I did in facts sign some welders qualification test records reflect-k'ingthat I had witnessed the test.
s I don't think I would have to be 9tsalified to witness a test as the ~ buy off of this <
" E-Idst is being done by an independent agency.
a
" I I was finally told that they didn't even idikat me to wi tne s s the te st s.
They didn't want me
%( she test facility down there signing records.
It
~
"!) Ibis my contention at that time, you know, that I would a
- f$lther have a procedural violation than I'would a 8
vioistion as the people they had that was going p
(..~[.
. W ts conducting the tests down there were not qualified y_
('S
)s'de this t'e st.
They didn't know what was supposed
. 'in
$w$ ts-done.They didn'L know their fiteup requirements, 6 they were to inspect the tests, any of this.,
h f.e The people that they had there that was k
fled to run the test facility or work in the test i
N W
,%y I had to qualify.
Now, it's like I say.
In the procedure
86
~
2 it says that the welder would stamp his test with a
his initials.
I did not allow that to be done.
In a
the procedure it says that the welder will return 4
his :est coupons to the tool room at the end of the a
day.
I didn't do that either.
I had a metal box made, and I locked them up in the test facility so 4
e y
they would be maintained under our control.
And I was in the process of rewriting s
the 4.7.1 procedure when I was terminated.
But they e
to had no control of the test coupons.
The welder n
would take them out of the test fixture of a night, u
Put them in his tool box, and turn them into the tool 2
room.
It was one craftsman turning h.i.s test coupon 24 in to another craftsman.
It might be his brother-in-1s law, for all I know.
a And feasibly those test coupons could j :..
leave the site and be completely welded out and brought n
y... -:
1.,,y!:
back in the next morning and issued to the welder.
u n
Without having full coverage in the so test facility, that could very well happen.
If you have a person there at all time that knows at what.
,3 portion the welding was done; the welder done his as welding when he quit the eve,ning before, he could as Pretty well stay on top of that.
But with the way they had it set up, they did not maintain control,
67 2
e'ven of'the_ test facility.
They did not have anybody there fulltime.
s Q
Okay. You alluded to the people that were 4
running the test booth were unqualified.
Who were s
they and why weren't they qualified?
s A
Well, as far as I know, Bobbie Wickes did l
7 not have any formal training in running a test s
facility.
He read the procedure and he tried to go by the procedure and he done a pretty good job.
e The assigned two other inspector s with so One of them was a man by the name of King that I
)
21 me.
tried to qualify for running the test facility, but u
he was one of the se shaky type people.
It was very 23 24 difficult.
He didn' t really comprehend. what I wa s ss telling him.
There was another guy by,the name of as If John Miner who done most of my testing for me and 27 n.
signed on my documents and things of thi s nature, E>.'
j m
k.
'I He was a very good inspector and E,
p..
i n
presently he's the only one that they have other than so possibly Bobbie Wickes that is qualified to run the at test facility.
And again he'is also the inspector in the fabrication shop.
He's got to do the inspection se in there as well.
i as
~.--
88 1
They had no kind of rules whatsoever 8
in telling the welder what his responsibilities was a
going to be in the test facility and how he was to 4
run his test.
They had the procedure there that the a
welders were required to read and they were required e
to sign a form saying that they had re.sd the pr~ocedure 1
7 governing the running of the test facility.
s But there was particulars there such as down hand welding and excessive weaves for tests and e
10 at what points there was mandatory hold points.
None of this is reflected in the procedure.
11 u
I wrote a set of inspections for the 13 shop that told 'em where these mandatory hold points 14 were and what the welder could or could not do.
I also wrote in there that a welder could be terminated is se at any time during a test if it was apparent that his i
17 ability didn't meet job requirements.
i.' '. !
ts Now, thpy were a little bit upset with u... :
[. 24
~
to that because it appears that.no welder has ever been r-so busted out of their test lab before he completed a test.
Regardless of what his welding looked like, they.always si m
ist him complete the test.
I was the first person to ever bust a welder out visually.
And the man just could as sa not veld.
It wa s on th.e r ou t e.
He admitted, "I can't d o it."
I terminated the test and it was t.he first
89 1
that -- since Comstock has been there.
s Q
Who told you that you couldn't be in the s
t est booth?
4 A
Bob Seltman (ph.).
s Q
Bob who, please?
7 e
A Bob Selton (ph.).
7 Q
And hat --
A He is --
s o
Q Who is Bob Seltman?
so A
Bob Seltman is their -- a QA Manager there.
t He has a staff 'of two and they do audits on the rest.
n u
Q Okay.
He's a Comstock QA?
A Yes.
1 l
u Q
What was the reason he'gave you?
as A
He said that I wasn't qualified to do any
== any inspections or anything down there.
The way 3
I., " '
f their procedure says, the way their procedure reads, n
I.
-t I._,lj it says that a QC Inspector will be present in the u
innt; T.-
test facility.
A QC Inspector there could just as well
,---s be a conduit inspector or a termination inspector, so They're all QC Inspectors that has no knowledge m
whatsoever of welding.
That vas one of the fallacies.
I told him, I said, I would rather have a procedure SB violat' ion than I would a Code violation.
And rig ~ht now we are violating the requirements of the Code..
-*s.,,yo r
.-v-
~ +
y, y
-v,
,,r,,...-
90 What does the Code require?
2 Q
Wel'1, the Code requires that you monitor s
A s
the test facility and that there is certain requirements in there for testing a. welder inasmuch as that the 4
welder keep his coupons in the fixed position, that s
J he doesn't do any downhill welding unless they're s
qualifying a procedure for that purpose in the 3-G f-T he in position and that -- well, basically, that s
f acts does the welding himself all in position --
e is in a position to weld -- and to instruct him 10 that 12 how the coupons are to be cut and to answer any questions u
that they might have about the exam, why they're taking 1s it.
14 Q
Okay.
u MR., WEIL:
Do you have anything else, Kevin?
as BY MR. WARD:
17 Q
That procedure that is being written, going to be revised for the test booth --
u i
u A
Well, I doubt that it will be now.
I wa s in f.
' ' ' ~" so the process of writing it when I was terminated, l '. -
m Possibly they'll get somebody else.
But right now they have the same procedure that I've been telling you se se about.
as Q
Right.
And does that say approximately how I
long an individual, that,an individual shall be in the test booth or -- I take it back -- the QC Inspector
k 01 2
should be in the test area while an examination or s
welding is"being performed --
s A
No, it does not.
4 Q
Remember at Zimmer we went through -- I 4
s don' t know if you remember or not--
s A
Yes, I know.
7 Q
You and I went through the same thing.
t s
A Well, this is one of the things -- I'm s
kind of living in the past.
I seen so many incon-so sistencies at Braidwood, that we had to hash it out i
n over a table with people like yourself there at u
Zimmer, the same mistakes being made over again.
And u
I talked to my management people there.
I said, look, u
I'm speaking from experience.
I've seen this happen 1s before.
..l a
I said we had inconsistencies that were nowhere near the magnitude of what you've got here and n
u they closed us down.
I said I want to head this.cff I-
'a at the pass if possible, identify this in house.
And 1.
' n b'
m.?.. so I said then we can come up with a resolution on how we can handle these things, and I said we can addr,ess m
.m those that we have no control over.
And t.he only thing that I seemed to get from management is they as would try to explain my way as not being a problem as j
or make excuses for him ort saying okay, you have
~
92 identified it, now fix it.
s But I was never given the time to do s
ahy fixing.
I would no more than get started on'one i
4 thing that I would be assigned to and I would get s
pulled off and put on something else, a
BY MR. WEIL:
y Q
Any other technical concerns that you would s
.like to express?
A No, Not at thi s time.
I
~
H Q
Okay.
Let's move on to what we have called No. 14 on the outline, and that was that Bob, u
Marino -- it's my understanding tha t Bob is the u
corporate QA Manager in Pittsburg, was at the site, and intimidated the QC Inspector during the discussion --
u of conyersation by telling inspectors that he had I
u-20 people ready to take the place of the. inspectors.
u would you elaborate on those comments?
'l n
I A
Well, this was a meeting that initiated by I- ~
a lot of the QC people there.
They were on the verge of a walkout.
I know in the room that I was in alone there was 12 or 14 people waiting for somebody to a
j, make the break, and they wer.e going to follow them
~
off the site --they were going to quit.
It seems for months and' months now the only as way that a QC Inspector there has been able to get a
\\
4
,%-.,..-.,_~,
I 5
93 raise is that if he gets another, an additional 2
s qualification and these inspectors have been trying to s
c'ross train in all of this, and it seems like that
\\
4 every time they'll start to cross train something will come up and change the requirements, whereas they s
can't get cross trained in this right now, you know; s
y and they were dissatisfied, the individual inspectors.
And they were at the point where they were going to walk off the site.
And they -- the leads of these inspectors and there was five or six a
of the se that.were involved, they went to speak to n
Irv Dewald and tell 'em we want a meeting, we want u
to discuss salary and we are going to walk off the 3,
site if we don't have somebody to talk to us about u
it.
as And so Irv called the home' office and u
a got ahold of Bob Marino who come out and gave them the
'I i-
}.,-
p f.,f same pep talk that he always has:
Get it done, you'll E--
get another qualification, you'll get some more money.
The inspectors are complaining because they have inspectors that have been there for two or three years, are good inspectors, some of them lead inspectors, they've l
been told that they have a ceiling on salaries there.
First, they said the ceiling was $1O ar houx and then it wa s $ 12 an hour.
And a couple days later they'd
.-.,_,,r.y,-.,, -
a 94 1
hire people in for.514 and $15 an hour.
~
a And the thing about it is you had your s
' leads and your people that had been there for a couple of years making $12 a' hour trainig people that were
)
4 s
making $16 a hour.
And that was their concern and r-s what they wanted to talk to Mr. Marino about.
And v
when Mr. Marino come out there, he told the inspectors, s
well, if you don't want to work, I've got 25 people e
that I can bring up from Perry to replace you.
so Q
I understand what you're saying in terms at of frustrations over wages, j
We define intimidation more'as an u
3 action taken by management against the inspector or l
a group of inspectors that would. cause them to look 24 3a at their job differently and to gloss over inspection i
items or along these lines.
t..
as s
+
A Well, now, I have the one letter that you l.ja.~. ;,' u u
have in that group of papers there I think.
It was
[': ;;
(..
w a letter addressed -- no, this is it here.
This was
[rT]
written by John Seders (ph.).
This is not really -- it m
i does, it brings in that, the same thing that I mention m
there.
as Q
I'm familiar with Mr. Seder's Ietter.
as
'A put John approached me With this letter and as he showed it to me and asked me to read it.
And I read
~~ '
. _.. - _ _ -,, _ _, ~ -. _ _.
L 95 1
it.
And he'says, what do you think this letter (sic.).
s I said, John, if what you're saying here is true, I s
s' aid this is as serious as a heart attack.
And I 4
said I think you know you ought to carry on through
~.
s with it, if you're, you know, if this is what you're e
saying it is.
7 He did come to me for --
e Q
So as far as you know, the only inspector j
1 s
that was intimidated in any respect was Mr. Seders?
to A
He is the only one that I have personal 21 knowledge of, I mean, you know, and that's what he n
says there.
I did not witness this intimidation.
I 3:
was ther when Mr. Saklak come up and started raising 24 hell with him, you know.
I is I never did understand why this happened i
j se and why at this time, I guess it would..you would n
consider what he is and what isn't intimidation; but t.
f.'.'
u when I was -- this was on-like a Thursday afternoon so that I had written a letter that I recommended that so they stop all velding because their procedures and the inconsistencies of them and because of the moral st
. se of the welders.
You know I told him we were close to si a complete breakdown in there, you know, with the as moral and the proc edures.
i And they contacted Mr. Marino on this
i 96 1
i 1
and he was pretty upset, according to Mr. Seltman, s
He was the,one that was doing the talking at this time.
hnd Mr. Dewald who was the QC Manager was listening,
- a 4
a nd Mr. Seltman says that Bob Marino had instructed a
me since I had found these noncompliances that I had s
until the following Friday to take. care of these 1
l fi 7
noncompliances.
He winted me to do a complete review.
l
.s I told him I says, well, am I going to e
get 'some help with this.
There's no way physically that so I can do this in the length of time that you want me n
do it.
i.
as He says, no, you will not get any f
as help and you will get it done by next Friday.
And I i
u said, well, I guess I best get started.
And this 1s was on a Thursday af ternoon and I worked on it Thursday u
afternoon.
I put in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on Friday. ' And I put in f.
i another 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> on Saturday.
And I was up in the 27 t '..'...
F f~!
afternoon on Monday when they called me up and terminated
=
l L..
h_,.1j i
3, me.
so Q
Do you know of any instance where inspectors m
may have been instructed to for lack of a better phrase, i
'm buy off cheap during inspection?
A No, I don't think so.
I got the impression l'
as that when I got there that one of'the reasons that I was there is that if they had a weld in the field that
- - _, - - - - ~, -, -, - - - - -,,
. - ~ _ _, - _ _ _ _. _ _.., -,.. -,
c-,-,..------_..y
s 97 1
the inspector rejected and the craf t sman disagreid
^
s with his rejection, that I was to inspect it and a
make a final determination on it.
4 And I was kind of led to be a little s
bit lenient.
But I instructed them that in no case a
would I humiliate an inspector in the presence of T
the craf tsman and cut down on his credibility.
I s
.said if he has a rejection there and it is a e
rejection, I said he should call it as such and 10 write it up.
I said if he is rejecting a weld that
]
11 is acceptable, I said I might take him aside and i
ut explain to him what the requirements are and ask him to reinspect it.
I said but I will not accept 13 t
14 anything over a QC Inspector that is already t
i rejected because it will cut down his credibility with is is the craftsmen.
1 rr Q
It's my understanding that -- no.
Before f.
u we go on.
I saw several other documents undemeath
. l * - --
u your memo.
Is there anything else we need to go over?
so
.A.
Oh, this -- well, there was one.
I'm really not si sure about this myself, but this deals with the
'ss aluminum weld procedure that they had there.
I as They asked me to qualify a welder, another welder to chair aluminum weld procedure.
as I
don't recall the number on this procedure.
I went out--
2 the only agchine they had for welding aluminum a
seg (ph.) and it was in the fields, so we were a
to qualify the welder on his station in the f:
4 The already had one qualified w.
s out there.
And in looking at the procedure th; ney
~~"s were using it was a General Electric procedure t
7 they were qualifying welders to.
And I got to r
.ing, s
. and all the welders that they had qualified, ti j
e had only qualified in the 5-G position and tha so were in facts doing horizontal welding which ti 21 werent' qualified to do.
j u
So I suggested tha* we take the s er 2:
that was already qualified in the 5-G position a
~
24 give him the additional 2-G position.
And the j
1s welder that they wanted qualified, qualify him 1 a
l as in the 2;G position and the 5-G position.' And s
i 17 is the test that we gave the welders in the fie l.'
as And I got to looking into thei:
u-ll. 'E a
mentation and I found out that CECO was buying 2
a.___:
so Procedure qualification off with just a tensi st.
i j
m They would.just use a tensile.
Now, I'm not s.
what the Code requirements are.
The don't de h
3 as aluminum that much in there.
But I haven't o
i procedure yet that you could buy-o'ff by just si i
a tensile on it and that was all that was evt l
..y.cs-,..,+-.,,.-,,--.------------me..,-e--e
..-+r v.
- - - ~ ~ - -
.----------y,
- - -- - - -, _. - - - - -. - -. -. - - - + - ~ ~
l s.
9 2
on these welder's qualification.
s And there's several of the welders a
that I had listed in.chere that was also qualifier to i
4 their aluminum procedure that was only qualified s
the 5-G position.
And there was horizontal welding s
done in the field.
And they were not qualified to 7
do it.
These are welders that's no longer on the s
-s i t e.
Th at 's --
e I held these coupons because I did:
so want to accept the responsibility of this test.
I told them I don't buy this procedure and I don't : 111y is u
buy thi s, these tests as qualifying the welder det u
a tensile.
And I was requested through this G --
this G.D. Teer (ph.) from TCD that I would turn t e u
ss coupons over to him.
as So on a memo I did give him the coupons 27 and he did in facts --
,it u
Q I see this is non-safety related wor,k.
9 l-se A
Yes.
s
}.,....,.
so Q
This memo.
Did they do any safety relate d m
aluminum welding.
l.
se A
I do not know if they did or not.
But l
whether it be safety related or non safety rel:
the as we1 der was not qualified to weld horisontal.
m Q-I understand your point.
Bear in mi
..~y+-.-..e-
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- - +, _
-, ~, -. - -, - - - - - -, + - - =
we--=-.+----
a.._-.
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-s
.m-a 1C A
Yes.
1 i
s Q
We have regulatory authority, l
A Yes.
This is the letter that I addresse
.co a
4 Irv Dewald recommending that they stop all work or 1
"-~ ~l s
all welding.
And that was the one that Mr. Marint s
got so upset over.
Q What is Marino's problem with this.
This y
is a letter dated August 22, 198 --
I A
This -- he was upset over it, first of a:;,
because I thin he was upset because of the moral o 3,
i the QC Inspectors out there.
He had just left goi ;
n back to the home office af ter talking to the QC n
Inspectors and I mentioned the fact that their mo:. a1 2:
was low there and the fact too by stopping weldin; l
u it would have such an impact on the schedules tht.t they u
i j
were pushing to accomplish at the time I,left there, 3,
s.
l they had been pushing for like three months to catch p
s.
t on all the backlog of all the welding that had:been
- t...
done in the field up to that date and there was thousands of welds that were involved originally, that the inspectors were inspecting.
Q Okay.
What else do you have?
l'.j A-This is a speed letter to Frank' Rolan' om a J. Dachar (ph.).
I think he is 'a weld engi-or CE CO.
And this is where he's telling them th.
p g,
~
1
- il 1
nonconformance report, 3099 that we were dealing wt a
f a
there, that they could use this attachment, H and t' o make these weld s with.
And this was during this s
s 4
period of time that I told them that they could ne:
... 3 a y use the attachment H and O because they were nct u
+[
qualified either.
One of them was for 3/8 fillet
[
eld minimum size, and the other one was for a complete 3
a
.r ej e ct ; and they had it in the back of their procedure.
[
Q Okay.
so A
Here is the original copy of that --
Mr. Teer where I turned ove'r those coupons to him n
u for testing, 2a Q
Okay.
Well, as we originally agreed, I'll i
copy these before you leave today.
u e,
na A
yes.
a Q
And you can have your documents back and L
g.
\\
we will have the copies for our files to work from.
n A.t..
.4.-
I guess we have pretty well explored
.ss a
your technical concernt, I. don't think from -- we i
asked several times now whether there any additional so concerns we should explore and let's ask one more time.
na en A
Not at this time I can't think of anythir off the top of my head, as as Q
Okay.
We have pretty well exhausted -
body of knowledge, then?
W-
-.er em.
- -..w,<-
- n--r-
2 1
A At this time, s
Q Okay. The last issue, and this why we have
'the representative from labor here is you had expressed s
4 a concern that you feld that you were fired from your s
position with L. K. Comstock at the Braidw6cd Nuclear s
Plant for having brought forth too many quality 7
- concerns, i
s Would you explain that for me, please.
e A
Well, when I hired on at Comstock, which to around the 27th of May of this year, right away I n
started pointing out the inconsistencies in their t
procedures, in the welding, in the weld test area, u
i l
s in their fillet material control and things of thi s 24 nature and they just seemed to get more.or less as upset when I would bring one of these things up.
as They would say such things as well, n
now, you've identified it, fix it.
I was always u
assigned to something else whereas it was difficult 3,
for me to do this, especially during the time we i
no were testing welders.
I guess during the three menths period of time I was there we tested 10 or 12 welders 1
a
.g and it took a pretty considerable amount of time the test facility to do that.
ss sa I was also doing so~me follow-ups audits and finding by your own NRC Inspector, O
a
1 1C I
1 resident inspector and -- they would get upset when I would bring one of these things up rather than say, 8
s
'Ok a y, let's write it down.
Let's address it and let's 4
fix it.
They would g'et upset.
The would try to
~}
explain it away or find excuses for it.
I s
s When I would bring up things such as the welder's qualification test records, they would 7
say, well, we got reconstituted records in there a
e that will take care of that.
10 I would -- going out to the QA people It in there that were performing the audit.and who were rewriting the procedures, the inconsistencies that u
they had in the procedures and they just didn't seem 1s 14 to be concerned with them, u
And during all this time I was doing my practical examinations andmy field examinations la 17 for my own qualifications.
And every time I'd mention u
something like this, they'd say you aren't qualified,
- r. -..
l u
And I guess a couple times I made the no statement that, well, eventually, I will be qualified m
and I won't have to recommend these things, I can write them on a conformance report of my own.
. se And I got the idea that they were as se dragging their feet about qualifying me because re was one inspection that I done where I rejected j
1 c omponent because it didn't have a welder's r
1 1
on it.
There happened to be two other weld inspect rs s
in the area at that time and I got them to take a
~
s look at it.
I said, hey, take a look at this.
I 4
says, do you see any welder's stamp on this component
' ~
anywhere.
And they inspected it and one of the s
s inspectors' name was J. D. Hunter, the other was a 7
new man that he was breaking in, and they could not s
. find any welder's stamp on it, e
Well, later I found out that that so test was rejected because another inspe ctor went c :
and inspected and he found -- welder's stamp on it 33 And they rejected the test and they said, well, I'd u
as have to take another.
So I took another test --
24 Q
Let me stop right there.
Are you saying is that the welder's stamp were added to --
as A
No, I'm saying'that I did not see them there 32 and that there was two other inspectors that look ct j
l u
it and they said they didn't see them there.
- And, is then later ansthen later an inspector went out an4 so inspected and said, yes, there was welder's stamps there.
si 3,
Q Do you know who the last inspector was c this?
A I can't think of his name.
I know whr is.
se O
as
. Q.
Oka'y. '
A And I can't think of his name right t
,wy
,e p..
y 4
3.-
103 C
1 Q
Okay.
When did it occur, the occasion s
occur that you and the two other inspectors --
a A
I would say that this was in early July.
4 Q
Early July.
And what type of component are a
we talking about and --
~'
3 s
A We were talking about a strut that comes 7
off of a cable pan to the floor, it was a floor attach-a ment.
e Q
And do you recall where that was.
so A
It was in the Aux Building.
I'm sure just 33 exactly where at this time.
One of the upper elevations 1
in the Aux Building.
as So they told me that I really needed to 24 take another test.
So I go out in the field and I us take another test.
This was also on a cable pan run.
as I done the inspection on this.
J. D. Hunter inspected t'
gy it and I got a hundred percent on the exam.
But I un also had to have now they said that won rejectable.
I 1.
I' had an acceptable. component.
Now, I had to go find one u,
j so that was rejectable or they would assign one and I gg would inspect it and if it was rejectable, then that as would satisfy my requirements.
I was given another componen't by one f
ss as the leads there by the name of Joe H'ie (Ph.).and I went and done the inspection on this one.
And
^
4 O
P g
106
~
1 in a rejectable situation.
I turned the papers, all a
my papers were marked for information only because I Yisjust doing a field inspection as a preliminary s
4 type thing.
V' s
Joe went and inspected this component s
himself.
And'when he got back, I asked him, I said 7
how did.the' inspection go.
He said you got a a
hundred percent on it.
It's good.
And I said, nell, o
great, that finishes up everything.
Now, I can get so my qualifications through.
j 23 A couple of days later when -I never heard anything fr om the p'eople that handle this, I u
as went down there and they said, well, we have no record 34 of that.
And so I go back to Joe His and he says I
- l as turned your qualification papers over to Seese who as was Assistant QC Manager, Larry Seese, and John Saklak 17 which is the inspection supervisor.
And I run these' people down.
And they i
as u
says we don' t have them.
i So I says is there anything wrong with me going back and getting Joe Hie's paperwork because a
he done the actual inspection on the component.
The component hadn't been inspected up until I as ss inspected,'and then he went and done the actual inspection.
And he had come with the same so)
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i 107
~
I that it was rejectable.
And he had issued a ICR, 8
l which an in process correction report on it to make a
repairs t o it.
4 And so I went back and I asked for I
a the component by number that I inspected, which r,q
.; ;"-M; incidentally was H-1311.
That was the hanger number.
s n
~ ' '
7 And they had no record oc it in the vault.
And so a
I went back up to Larry Seese's office and I went e
and pulled the log out tha t reflect s the ICR's.
And 30 this was in the middle part of July.
And I checked i
21 in the early part of July through the month of n
August, up to date, and there was no reference in there is anywhere that Joe Hie had issued an 1CR on the 34 component.
as So it was at this point that I begin 38 to realize that these people seem to be dragging 17 their feet about getting me qisalified.
So the --
m Q
Let me stop you there.
Joe Hie told you se all along that he had done the inspection.
so A
And that I received a hundred percent on it.
at Q
And he had turned in the paper and now l
- se you're saying that in your research you couldn't ff,d -
~
as any --
j as A
Neither my paper nor the papers that hr supposin'ly had done the actual inspection for.
e y
7--,m_.
--r v---
+-t
--e
106 1
Q iet's go on.
That's what I'm concerned a
with a t the momen t.
Okay, go ahead.
s A
And the component number wa s H-1311, 4
because I was digging into it.
f:-:C) s Q
Okay.
,'...l s
A Well, they had came up with a new method
.S 7
of doing your practical examination.
They came up
.s with a number of like 14 welds that were numbered
}
e 1 through 14 And they had them in a conference room i
no where you would go down.
You would take a test paper n
that was numbered I through 14 You would inspect u
this weld and put down a disposition.
If the weld as was rejectable, then you would put down the reason i
u for rejection.
If it was acceptable, you would put as acceptable on it.
as So I took their practica1' exam down there and it was a very simple exam, I thought, the n
rejects on the test were very obvious, and the u
u accepts wer'e obvious.
In one case they had an accept so there that I made a note of the veld stamp they had sz there which was for a fillet weld and it was a flare beveled weld., And I just made the note there the a
so weld is acceptable.
However,, you know, it's not fillet veld, it's a flare beveled groove.
as And that test then I checked o-hr I.,
c 109 3
following day.
I said how did I do on it.
They a
said well,.swe sent it up to Irv Dewald for a grade.
s
~
And a couple days later I asked Irv Dewald about it.
d I said how about that test that I took down in the
~{
s conference room.
I said that will finish up my
..i
~l1 s
qualifications.
He said, well, I've got it up there 7
somewhere..
s And I still haven't found out what I e
done on that exam, because I was called up and terminated M
on Monday.
They reached the 90 day period and I got 11 the impression that they kept putting it off and putting u
it off and putting it off up until such time that they as could terminate me.
24 Now, the reason that he gave for it was H
a test that was acceptable.
They had an acceptable M
test.
But he thought that I should have 'se' red higher o
17 on that test, than what I did.
And I probably should
.....}
u have.
I must have been in a dare, because it was a L
u very simple test.. You know, it's one of those where so you look at one answer and you mark another answer.
I still had I think an 86 percent on it s:
'sn and that was his reason for termination that he gara as me.
I should have scored higher on there.
That t
- t so I had ' taken two months earlier.
If he had wantet t erminate me, why didn't he do it then., He di(-
. _ _. _ _.,., -,,, ~ -.,,, -. - - -
s 110 1
he do it then.
He didn't have to wait 90 dahs to a
do that.
s But that was the reason that he gave 4
me was because I had that rejection, or it,was an pq acceptable test but I should have scored higher on it.
s
]
s There was another field inspection that 7
I had that I accepted that another inspector bought off.
e It was the type of inspection that 12 people could e
inspect it and 6 would accept it and 6 would have 30 rejected it.
It was on a unistrut.
There was a very at little bit of undercut th er e.
We are allowed between 8 and 10 thousandths.
And you use a calibrated eye u
as f or it because they don't have anything to measure 34 that.
as And when I looked at it, the location as of it and all, I thought it was not in an. area that n
had any structural value to it and there was a little j-
,[
u bit of undercut there.
I seen it.
But I accepted it.
!- ~ ~
u And an inspector went back out at a later date and he so rejected it, But most of my written exams, I kney at m
on the, one on the CFR, 10CFR-50 and' 21 I received a hundred percent on those and I know that on my, lot as se of my' field exqmination, practica1 exam, =- rece' I
a hundred percent on those.
..~-.4.
_. ~,. _.. _ _ - _ _..... _., _ _ _... +..
_-,,,_.....y.
.....,,-,.m.,.,-,.y._~_
.,,,-.._..mmm..,,--
111 l
1
~
And the one that I was told that I 8
was terminated for I received a passing grade on it 8
as well.
But they never let me get to the point 4
where I was qualified, because I guess maybe they 8
overheard me say, you know, that once I'm qualified
(
e I won't have to recommend these stopworks.. I'll be 1
7 in a position where I can implement them, because I a
was very serious about this.
o Q
okay.
Much earlier in the discussion you u
u sed the phrase " reconstituted records".
Will you define that for me, please?
11 n
A Well, they.had reconstituted welder's
)
is qualification test records.
There would be something l
M evidently that was at fault with the first one.
And 15 they would take a new test record and put all the H
required information on it, and resign it'.
17 The way I understand a reconstituted
~
.J.
u
, document, if you reconstitute a document, they're j
i to supposed to take it by everybody that had a signature i
so authority on it.to let them review it and approve this at document as well, the changes that were made.
as The reconstituted documents that they've as got there only has one signature on it, Irv Dewalc He se transferred all the information that PTL had' on t!
document for the test numbers and all but had rc rt
i 112 this document back by PTL for their approval, for their 1
a signature.
s And ineidentally, to ther.best.of,my knowledge and from talking to the other QC Inspectors, 4
~]
I'm the first person that was ever termina ted, QC s
person that wa s terminated there at Braidwood other than e
5 one fellow thait went out one day and got drunk and come back and tried to climb over the fence late.
a s
But I know for a fact that there has been QC people there because I've heard them talking to n
about it that had failed an exam.and they were allowed to take that exam over and over until they passed it, se And for me to get, terminated because I passed one, it u
24 just, you know, was uhbelievable t'o myself.
u Q
Do you know off hand who the people were who' as took --
l i
n A
Well, they have records of all of them.
If
'l '
u you check the Q -- there's numerous, several of them.
Like I sayf these people are trying to cross train them as 6
and you have some people that really -- that came there I
as weld inspectors that had no background in terminations at or in unistrut or -- pardon me -- in configurations r,d
's
~
j things of this nature and they are trying to cross
.in ss 1
as
/ou in this.
And they have t~o take certain exams order to do that.
And I know the tests that the e
i given -- in facts so'me -- made a little bit of a a: it
l 113 1
about the weld test tha t they 're giving them.
s They had a couple of girls there to
'make up the test and they made the test up out of the-e D-1.1 Code, which is perfectly all right to make it 4
up I~"II, s
out of the D-1.1 Code, but it was my contention that a
the people are inspecting procedures and not the Code
{
7 and that their tests should come from their procedures e
and not from the Code, a
MR. WEIL:
At this point I think the Nuclear Regulatory Commission has just about exhausted to 11 where we want to go this morning. And I'm sure Labor would like to take over.
So I'm about u
j as ready to close the record.
s 24 Is there anything else you would like i
u to bring up, let's do it before we close the i
se record.
l l-17 MR. PUCKETT:
Nothing else that I can think of.
- ? ~
\\
i--
u BY MR. WEIL:
u Q
Just a couple things I just want to cover I
l se so we have it on the record.
It's my understanding i
that you have already been in touch with the Department si i
j
's of Labor and the Wage and Hour Division and have filed a
i as your written complaint of discriminatory oaploymer as practice?
't A
Yes.
1 4
,__s-..,_,__-_-,
)
114 Q
Is that true?
Okay.
The other issue we talked about on the s
phone, and "that deals with how to handle your identity and you know with -the. information we had discussed tha t 4
the agency normally considers the information con-fidential and would not release it to anyone.
- However,
[d.il e
( )v since' we're also discussing with the Department of oj. )
l Labor, Labor is required to identify you to the company,
_g that you understood that and that you did not have e
any concern with your identify being associated with 30 j
i this information that you've given us.
Is that still your position?
MI 4
A That's still my position.
Most of the i
ui things that I brought up and talked to you here about i.
14 l
today I talked to my own management people before 3
as this time.
So they will know where the're coming i
from.
17 l
[..; }
Q We will of course will not bandy about un
.I r
.c, your name but certainly because of what I just 8'
(~ '. i i
described -- cannot keep it totally confidential.
l so I 'just want you to realize where we are at.
A Sure, I understand.
- e MR. WEIL
Okay.
Well, at this point we're abrut as ready to close.
We have just a very short stateme se here that I need you to answer.
t
'.w._
-ww.
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115 1
BY MR. EIL:
s Q
The information that you've given us today, s
is.it the truth to thi best of your knowledge and 4
belief?
s A
Yes, it is, p-.]
f 8
Q Do you so swear under penalty of perjury?
7 A
Yes, I do.
s
.t.
MR. EIL:
Thank you very much and we will 8
colse the record now.
8' (Record closed.)
11 1
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