ML20214E413

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Applicant Exhibit A-72,consisting of 840828 Memo Re 840828 Note & Subsequent Telcon W/Wo Puckett,Former Lk Comstock Level III Weld Inspector Re Shoddy QC Practices & Possible Falsification of Insp Records
ML20214E413
Person / Time
Site: Braidwood  
Issue date: 07/01/1986
From: Mcgregor L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Weil C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
OL-A-072, OL-A-72, NUDOCS 8705220076
Download: ML20214E413 (3)


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MEMORANDUM FOR:

C. Weil, Investigation Coordinator N&

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R. Warnick, Chief, Projects Branch 1 FROM:

L. McGregor, Senior Resident, Braidwood

SUBJECT:

CONCERNS OF A FORMER L. K. COMSTOCK LEVEL III WELD INSPECTOR On August 28, 1984, at approximately 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />, I received a note from an individual who works at the Braidwood site. The note requested that the NRC call W. O. Puckett at the following telephone number (513)734-6310 because it was very important.

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I placed the telephone call and received the following information from Mr Puckett:

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"'O'\\f"0-I was' terminated out there (Braidwood) yesterday (August 27, 1984).

The excuse that was used was that it was the end of the 90 day period (a requirement of L. K. Comstock to have a 90 day try-out period).

I was terminated because I was too quality conscious. I worked for L. K.

Comstock for 90 full days, I was hired on as the Level III inspector.

I was the project weld engineer at Zimmer before it closed down. It is my contention that I started to make too many waves to soon, before the 90 days were up; that's why they terminated me.

I predicted: it and knew it was coming because I was the one who instituted and requested the first stop work order. That was on the procedure for the A36 to the A446 (that's the galvanized sheet).

I initiated a stop work order on the stainless steel welding procedure because it was not qualified except in the SG position. The procedure was qualified in the SG position and qualifie'd'on materials they were not using in the field (on site). There were a number of problems, but it all came,to a head, more or less, yesterday (August 27, 1984) when Irv Dewald (L. K.

Comstock QC Supervisor) called me in, he had Larry present and told me I was terminated.

I told him I was kind of expecting it.

I had predicted it because I had written a letter to Irv Dewald. I had done some preliminary reviews of our procedures and welder qualification test records, of our weld rod fitLer material slips and in this letter '

wrote to Irv, I recommended that we stop all welding until such time as a complete review could be made to determine the magnitede of our problems and how to approach it.

I made a recommendation to Irv that with this problem and things being what they were and with the GC moral so low we were approaching a point where we were losing. complete control.

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August 28, 1984

. Mr. Marino (so) (L. K. Comstock Corporate QA) became upset with what I said. Marino said "OK Con August 23, 1984), you identified the problem now you got until Friday (August 30, 1984) to fix it. Well I could not have ccmpleted this review (review of atL:

(1) welder qualifications, (2) weld rod fitter material records and (3) welding procedures) if I would have lasted that long. I did work on it Tuesday, Friday and eight hours on Saturday then was terminated Monday.

I did not do a complete review - but - I would say that at least 60% of the records are undetermined.

There have been changes made on the records for intentional or unintentional -

the only thing I can call it is falsification.

I am not sure it was an s

intentional type thing. The changes were made by a clerk, and I don't kn'ow who gave a clerk permission to make changes to a quality document. We have test records which start out saying that a welder took his qualification test on SA 106-6" schedule 80 pipe and now the test record states 6" schedule 80 A36 plate in the 6G position. The clerk changed the SA106 to A36. Test records also show root bends and face bend tests on 1" plate. They just didn't happen - that test is reserved for a 3/8" plate.,

We have numerous occasions in test records when they done a test on a 1/2" plate and they gave the welder unlimited thickness. By the code 0.1.1 if a welder takes a test on a 6" schedule 80 pipe the thickness i

f range that he qualified for is f rom 0.187" to maximum to be welded..

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There is a lower range and L. K. Comstock forgot this lowir. range.

All cable pan and uni-strut in Braidwood is less than 0.187 inches -

its' thickness is 0.105 therefore the velders are not qualified for the correct procedure to weld cable pan er uni-strut. I keep finding these Little things and each time I would oring it to their attention they would try to justify the problem away and not correct it.

Every time I started a review on something it would be compounded - for example:

welder test qualification records in the vault stated the welders stamp number as 22. I found another record which stated his number as 122 -

I thought wett, its a typo, a error, so I pulled the hammer tog and found out that this welder was never assig7ed either number but something else. I can't remember the number - I did find out that welder numbers 1, 22 and 23 are assigned to several dif ferent welders.

I do know there is an awful tot of pressure on QC to get things done in whatever fashion. They are interested in quantity and not quality. They are at L out to get numbers done.

Even Marino - as far as that goes -

I don't think it was intended as being intimidating, but he has stated you will do the job or I will rectace you - I have 25 people out there qualified to do your job. A Q.C. person should not let himself be pushed in this way.

Even yesterday, when Irv catted me in - I didn't argue with him - I had predicted they would find some kind of a penny ass excuse to terminate me because I have made too many waves. I have pointed out too many procedure errors.

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August 28, 1984 Procedures are written which are not corree,t and they insist in using them or not to correct them for examole - Procedure 4.7.1, the welder qualification procedure had the welder who was doing his qualification test to stamp his initials in his test coupon - There are no controls-over the' coupons or what initials were used or by what welder did the actual weld. The shop test inspector for the qualification process was required to do field inspections - so how could he maintain futt coverage of shop test coupons or welders. Also, when the welder finished work that-day he took his coupon out of the jig put the coupon in his tool box and put the tool box in the tool room. There was no control over that--

test coupon. I have since written new rules to be used in the qualification shop you wiLL see them on the wall - but L.K.C. does not have them in

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their procedures.

From L. McGregor:

As I talked with Mr. Puckett he seemed very calm and very sure about U

the findings he was reporting to me.

He was assigned as the project

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weld engineer at Zimmer and worked very closely with the NRC to rectify the welding problems there. His statement to L.K.C. was that'you have

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the same problems here at Braidwood and I would like to help you identify

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these problems and get a correct solution to them.

As S'enior Resident Inspector at Braidwood I would recommend NRC request the Construction Assessment Team (from Headquarters) to do a full examination of th'e electrical contractor, the piping contractor and the HVAC contractor now, immediately, and that the independent design verification program be continued by Headquarters of Sarger.t and Lundy/

Ceco design and design review work.

Some of these allegations appear to correlate with John Seeder's allegations, of August 17, 1984, such as managements atleged concern with quantity rather than thorough inspection efforts.

7 77 g-L. G. McGregor Seni,or Resident Inspector L

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