ML20214B593

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Applicant Exhibit A-110,consisting of 850405 Partially Withheld Memo Re Allegations Concerning Lk Comstock QA Program at Plant.On 850329,six Lk Comstock QC Inspectors Provided Info on Quality of Insps
ML20214B593
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 08/12/1986
From: Weil C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
OL-A-110, NUDOCS 8705200330
Download: ML20214B593 (6)


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MEMORANDUM FOR:

Charles E. Norelius, Director Division of Reactor Projects FROM:

Charles H. Weil, Investigation and Compliance Specialist

SUBJECT:

ALLEGATIONS RE:

L. K. COMSTOCK QUALITY ASSURANCE PROGRAM AT BRAIDWOOD (50-456; 50-457) (ATS NO: R!il-85-A0072)

On March 29, 1985, at approximately 10:00 a.m. the Graidwood Resident Inspt ctors (L. G. McGregor, R. D. Schulz, and W. J. Kropp) telephoned the Region III Office and advised that six L. K. Comstock quality control inspectors had visited the residents' office that morning.

The Comstock inspectors provided several allegations which are sumarized as:

1.

Comstock is asserting the quantity of inspections rather than the inspection quality. Therefore, the quality of the L. K. Comstock inspections is suffering.

g 2.

Rick Saklak, Comstock QC Supervisor, was not qualified for his position, as he was not certified in all of the inspection areas which he supervised.

3.

Saklak was constantly initimidating/ harassing the Comstock inspectors.

4.

. Ninety t ree hanger inspections, containing 1100-1200 welds, were

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h signed off in one day by an unidentified inspector. The allegers considered this to be too many inspections for a single inspector to l

make in one day without the quality of the inspections suffering.

1 5.

SB523gggy (phonetic spelling), a Comstock QA inspector, is assigned to the records vault for the sole purpose of closing nonconformance reports. 15Equ!y never goes',to the field to verify the condition before closing the nonconfonnance reports.

All of the allegers claimed to have spoken to the Braidwood Quality j > M 6.

First Team without gaining any satisfactory response to their

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concerns.

The allegers indicated that they represented 50-70 Comstock quality) control inspectors.and there would be a job action on Monday (April 1,1985 if something was not done about their7cTic~ erns.

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The allegers were d*meuE!Weh

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p and BSkS@8kB (all phon' etic spellings).

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allegers requested confidentiality and each agreed..his_iden_tity_could be_.used J

1,fl.DAcis sary.-

(NOTE: A series of allegations irivolving L. K. Comstock at Braidwood were received by Region III beginning March 9, 1985.

These allegations (RJII-85-A-0058; RIII-85-A-0052; RIII-85-A-0067; and RIII-85-A-0068) generally Gncompassed those identified above.

Further,6 was the source of a'llegation RIII-85-A-0068 which concerns the push of production quantity over inspection quality.

On March 29, 1985, the allegations were discussed among the Region III Staff (C. H. Weil. W. L. Forney, and C. C. Williams).

The Regional Administrator, Deputy Regional Administrator and the Director of the Division of Reactor projects were also infomed of the allegations.

It was decided that the allegations should be forwarded.to Commonwealth Edison Company for resolution.

However, the allegers should be contacted before providing the information to Consnonwealth Edison and infomed of the proposed course of action.

Accordingly, at 12:00 p.m., March 29, 1985, the Region III Investigation and Compliance Specialist spoke by telephone with the allegers assembled in the k Resident Inspectors' Office.

They were infomed of the plan to bring Commonwealth Edison into the allegation resolution process and none of the allegers expressed any dissatisfaction with the concept.

Further, they restated that they did not desire to remain confidential.

Other Comstock inspectors accompanied the original six allegers to the Resident inspectors Office.

The total number of Comstock inspectors eventually numbered 24.

In the one half hour period of the telephone call (the call taking place between 12 and 12:30 p.m. during the inspectors lunch period) thirteen inspectors were briefly interviewed. None of the additional inspectors requested confidentiality. The Resident Inspectors were requested to obtain the Comstock inspectors' address and telephone numbers for follow-up by the NRC (e.g. furnishing the inspectors with copies of this memo and subsequent

, reports).

INSPECTOR COMMENT.

6 Rich Saklak continually violates procedures during inspector certifications.

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Saklak threatened @ for not closing an inspection f

report which still had an open engineering change notice.

@ refused and Saklak stated, "if beating was legal you would be dead." @ later checked with QA and found that his position on the issue was proper.

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'N John Walters ( W lead) and Ken Worthington chb (tshwrusta supervisor) toldN that he would lose s

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I his job if he did not hurry up and produce more l

inspections.

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Charles E. Norelius 3

APR 5m Saklak threatened an inspector (unidentified) for not closing an inspection report even though the engineering change notice had not been issued for it.

"Comstock wants us to work with blinders on."

l 6

"More than a little bit of intimidation by more' than one supervisor."

ammEhrnesEBusta On November 5,1984 Saklak told him to finish an inspection even though drafting errors were noted. 4E23 complained to Comstock management about this issue, but did not rece,ive any satisfaction.

6 h observed a base netal reduction problem in a s tructural weld. @ told his lead, John Walters, and Walters told M to stay within the scope of his job and not worry about base metal reduction. h also f-told Daryl Landers.

Landers informedh to keep up !.i'"7 his production or he would lose his overtime. (See j

<J allegation RIII-85-A-0068) 6m Inspector productivity overrides the quality of the inspection.

(At that point a show of hands was done. The Resident Inspectors indicated that the Comstock inspectors agreed 100t with that statement).

(NOTE: amma provided infomation under allegation RIII-85-A-0067) g g S t>

Comstock emphasized inspection quantity first, not inspection quality.

6 Saklak berates inspectors. Many inspectors have been re.., "

discriminated against at one time or another by Irv DeWald, su.4 Comstock QA Hanager. DeWald's attitude is "how caF I' hang N

you, not how can I help you.*

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ggggIIng, Constantly intimidated by Saklakl.

Saklak lied to get

'pfA 6 fired. 6 stated that he has written statements from several witnesses to back-up his statement.

N Saklak uses forms contrary to procedures.

For several months sken.was the only welding inspector, and everything was done on a hurry-up basis. Comstock has,f 7hg consistently been undermanned and has one crisis after

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another.

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Charles E. Norelius 4

4 43333r is constantly being watched by his supervision. As an example, he recently visited the NRC office.

The following day he was transferred without reason from field inspections to a job in the records vault. (NOTE:

the Investigation and Compliance Specialist provided the Resident Inspectors with the address and telephone number for the Department of Labor, Wage and Hour Division, and requested that it be given to M should he desire to further this complaint).

(On April 1,1985, Daniel P. New, Area Director, U. S. Department of Labor, Wage and Hour Division, was contacted and infomed of 6 information pertaining to alleged employment discrimination. New advised that the Wage and Hour Division would await the filing of the written complaint required by 29 CFR 24.3 before initiating an investigation into the matter.)

1g 3 3 3 3 5l3 3 3 m Hangers aren't even being inspected, just as-built.

No Nk inspection reports or nonconfomance reports are written, g, ',jg Walkdowns are being done and drawings made to show

-as-built configuration.

Comstock management promises more money to inspectors who are certified in multiple areas. Although it's nice to get more money, an inspector cannot remain proficient in G M ',

all of the certified areas; therefore, the quality of x

l inspections goes down.

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h(phonetic spelling) is both an inspector and l auditor. Manywill inspect something then do the QA

't overview audit. M believes this to be a conflict of x

interes,t.

At approximately 12:45 p.m.. March 29, 1985 Eugene T. Pawlik, Director Office of Investigations Region III Field Office, was infomed of the allegations and concluded that an investigation by 01:RIII was not warranted at this time.

At approximately 1:15 p.m., March 29, 1985 Tom Maiman, Connonwealth Edison Vice President and other Comonwealth Edison officials were telephoned at the Braidwood Facility by Messrs. W. L. Forney, C. C. Williams and C. H. Weil.

Connonwealth Edison was told that the NRC had received general allegations fom twenty-four Comstock inspectors and in general tems the allegations concerned Comstock's push for inspection quantity not quality, Saklak's perceived I

perfortnance and the inspectors perception of the perfomance of TAC Quality

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First Program.

Maiman stated that Comonwealth Edison would begin to look I

l into the matters that afternoon and would recontact Region III with an action l

plan by the close of business on March 29, 1985.

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APR Charles E. Nore11us 5

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At approximately 4:30 p.m., March 29, 1985 Comonwealth Edison officials telephoned Region III.

Comonwealth Edison had decided to act upon the issues with both short range and long range action plans.

The long range plan was not developed, but Comonwealth Edison would be in contact with Region II,I during the week of April 1,1985, to discuss the long range plan.

The short range plan identified below would be ac.complished by the close of business on March 29,1985.

1.

Comonwealth Edison Management at Braidwood met with onsite Constock management officials in production, quality control and quality

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assurance.

Comonwealth Edison discussed areas identified by the Braidwood Quality First Program and the above identified allegations.

The Comstock officials indicated they were generally aware of the concerns with Saklak's perfbrmance.

Commonwealth Edison emphasized the need for L. K. Comstock Company to perfom within the Comonwealth Edison and Comstock quality assurance programs.

Comonwealth Edison officials were not certain if L. K. Comstock site officials had informed Comstock corporate of the problems.

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2.

Saklak was administrative 1y removed from his supercisory position until h fp.*,

the allegations are resolved.

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3.

Comonwealth Edison issued a memorandum to all L. K. Comstock QC/QA personnel in which Comonwealth Edison announced a meeting for 8:00 a.m., Monday, April 1, 1985. At that time Comonwealth Edison plans to reemphasize its quality assurance policies, as well as allow the Comstock inspectors to air their grievances. Comonwealth Edison will also announce a method for a private airing of grievances should that be desired by an individual Comstock inspector.

4.'

A monwealth Edison Quality Assurance Project Letter was also issued to reemphasize the Comonwealth Edison Project Quality Assurance Policies.

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.s Charles E. Norelius 6

APR 5 585 kg

At approximately 5:00 p.m., the Regional Administrator Deputy Regional Administrator and the Director, Enforcement and Investigation Coordination Staff were informed of the Comonwealth Edison plans described above.

/

Charles H. Weil Investigation and Compliance Specialist

Enclosures:

1.

AMS Form 2.

March 29,1985 memo, McGregor, and Schulz to Warnick and Weil cc w/ enclosures:

RIII:RA0 i

RIII:DRS 01:RIII E. G. Greenman J. F. Streeter SRI-Braidwood L'

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