ML20214E802

Intervenor Exhibit I-ROREM-17,consisting of 851216 Certificate of Qualification for I Dewald for Level III Welding.Weld Insp Checklist & Visual Test & Other Related Info Encl

ML20214E802
Person / Time
Site:	Braidwood
Issue date:	05/07/1986
From:	COMSTOCK ENGINEERING, INC.
To:
References
OL-I-ROREM-017, OL-I-ROREM-17, NUDOCS 8705220258
Download: ML20214E802 (16)

Text

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]';vn, g CERTIFICATE OF FUAllFICATION c, Lfg; fgg 7_ g {

e L. K. COMSTOCK & COMPAN% INC.

S/~7[F6 c7 TO 22 Pd :29 CUALITY CONTROL DEPARTMENT ONM- !

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FOR REFERENCE ONJ NAME' 5Yuf AJ s (L)

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4 AREA OF CERTIFICATION Ale / d/LJ*

LEVEL

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EDUCATION Adull Alra A Sabe s / h/en,~

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EXPERIENCE USED FOR QUALIFICATION _

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DATE GIVEN / 0 -J N~Y 1 TEST SCORES: GENERAL PRACTICAL /dd 5 DATE GIVEN

//-0 *9 C The individual named above has satisfactorily completed all appropriate requirements of L. K. Comstock l

Procedure 4.1.3, CUALIFICATION, CLASSIFICATION. AND TRAINING OF OC PERSONNEL, has physica' characteristics suitable for the stated area of certification, and meets the requirements of ANSI N45.2.6 (1978; CERTIFICATION DATE:

/I~I 5 ~ $I EXPIRATION DATE: /O-14-@b

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/Al/6lGJ VEL 111 dAT!i Performance Evaluation:

Due Completed by Date Due Completed by Date

[ ] This certification has been supercedet Date t

QC MANAGER 00015'S, J

PREPARED APPROVED REVISED TITLE CRIG. DATE REVISION FCAMe D

ROM AJT RVS PROCEDURE 01/04/77 03/20/85 56 l

0705220258 060507 PDR ADOCK 05000456 C

PDR

L K. COMSTOCK & COMPANY, INC.

BQAIOWOOD 4 E 3 WELD INSPICTION CHECKLIST 3.1 FILLER METAL E309 0 Exxic w E' ER n O.

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3.2 FIT UP COMPONENTS IS CORRECT, Wl ll I

3.3 UNDER CUT IS WITHIN MINI $1UM REQUIREMENTS.

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3.4 CRACKS / DISCONTINUITIES DO NOT APPEAR IN JOINT OR PARENT METAL.

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3.S SURFACE PORCSITY 15 WITHIN MINIMUM ACCEPTABLE LIMITS.

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3.6 SLAG OR OTHER INCLUSIONS DO NOT APPEAR IN FINISHED WELO.

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V 3.8 FILLET SIZEfrHROAT, GEOME T

vEDURE Rl II I

REQUIREMENTS AND OR E

g 3.9 ARC STRIKES OUTSIDE OP mRMANENT WELD AREA HAVE BEEN GROUNO l

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SMOOTH, OR REPAIRED AS NECESSARY.

3.10 WELD AND SURROUNDING SURFACES HAVE BEEN THOROUGHLY CLEANED MRR 08 SLAG. SP ATTER. FLUX AND OXio!ZEO PAINT. ETC.

3.11 WELDER AND INSPECTOR IDENTIFICATION ARE INDICATED BY ASSIGNED 31 IR SYMBOLS STAMPED NEAR THE WELO JOINT.

3.12 WELO IS A RESULT OF A REPAIR PER ICR, NCR NO.

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000,UU" PREPARED APPROVED REvlSED TITLE CRIG. DATE REV.DATE PCRM NO.

RAB RR RAB PROCEDURE 05/26/80 A

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10/1/82 SCORE 6$7e NAME 7 b u

%, 2 g ym g y; VISUAL INSPECTION 33T (GENERAL)

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$3 One of the Qualifications for a Level II Visual Inspector is passing the eye examination.

FOR REFEREEE 00'

^

• ~

B. false I

i What is the standard for the eye test?

2.

A.

Be able to read J - 1 letters on standard I

i test chart.

B. Passing a color vision test.

O C.

Both A and B.

D.

Passing a physical exa=ination test.

b Which NDT =ethod is cost suitable for detecting surface cracks on weld =ents?

3 A.

Neutron testing.

I I

B.

Leak testing.

M C.

Magnetic particle testing.

D.

Acoustic e=ission method.

I I

All welds fabricated for class 1E systems requires visual inspection.

4.

A.

true M

B.

false i

I Joint configuration, joint design, weld sise and finish are specified in the drawing using the AWS Standard Welding Sy=tol.

5.

A.

true 8

B.

false C

6.

000,Sr.,:;;

PCge 2 2)s >~ uo NAME /

DATE et-av-#?

What is the max 1=u= joining gap for welding fillet welds to AWS Code?

(Less than 3" plate) 6.

A.

3/8 inch r-1 f

B.

3/16 inch C.

1/8 inch 1

l D.

5/16 inch I

I When OXY-fuel cutting is used, the inspector is most concerned for which of the following?

7.-

A.

Travel speed to fast, f-l B.

Clean cutting tip.

I I

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C.

Kert too wide.

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D.

Surface roughness of cut.

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A 3/8 inch fillet weld has a notinal.

1 8.

A.

Throat dimension of 3/8 inch.

I I

B.

Both leg dimensions of 3/8 inch.

[E53 C.

Width di=ension of 3/8 inch.

I I

D.

None of the above.

L__J A weld sy=bcl refering to the arrow side of a joint appears.

9.

A.

Above the reference line.

I I

B.

Below the reference line.

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C.

At the end of the reference line.

I I

D.

On the arrow.

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" Direct visual ext:ination" is a ter: used when the eye distance to the surface inspected is not more than 24 inches and at an angle not less than 30 degrees.

10.

A. true

[E5l B. false i

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" Remote visual examination" is a term used for examination using visual aids such as mirrors, telescope, boroscope, magnifying glass, cameras, or other suitable instruments.

I M

11.

A.

true f^u"~~~,"d.L:En"*e

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false s

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A welder qualified by making a horizontal groove weld on one inch material, is also qualified to weld.

,12.

A.

Plat and hori: ental position groove welds oni'/.

I I

B.

Plat and horizontal fillet welds only.

C.

Both flat and he::1: ental groove and fillet welds.

M D.

One inch or less flat and horizontal groove welds.

O Welders qualified for the 40 position are also qualified for i

13 A.

3F position

[

l B.

4F position C.

3G posi, tion C

D.

43 position I

i If you suspect or see what appears to be a crack, what tool can be used to quickly deter =ine if it is a crack?

14 A.

High intensity viewer and a flashlight.

U i

B.

A flashlight and a 5x magnifier.

Q C.

A 5x magnifier and a high intensity viewer.

D.

A borosecpe and a droplight.

C 9

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10/1/82 roco NAME /. d s.sa J DATE so. a v-P3 A welder qualified for SMA'n' using E6013 electrode is also qualified to weld with 15.

A.

E6010 B.

E7018 R

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C.

E7024 8

D.

E6016 I

i Check the type of defect to inspect during inspecting tack welds.

16. '

A.

Crater cracks C

B.

Lack of penetration C.

Base Metal D.

Burn through C

A tack weld is normally used for fit-up and will be welded over during welding.

Therefore, the person performing tack welding need not be qualified, if tack weld will be incorporated into the final weld.

17.

A.

true I

I B.

false Surfaces of deposited weld metal required to be liquid penetrant inspected shall be visually inspected prior to doing penetrant testing.

18.

A.

true B.

false I

I koking at a welders supply of electrodes to see if there are two different types of weld metal caixed together in the tote tex oven and the welder using the proper weld rod is a part of visual inspection.

C/

19.

A.

true B.

false Q

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10/1/82 Pese 5 NA.E

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Checking the preheat temperature as required in the welding procedure is a part of visual inspection.

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20.

A.

true U

FOR REFEREME Om fe SPECIPIC VISUAL EXAMINATION TEST A fillet weld to AWS requirements requires visual inspection of the final layer.

List 5 unacceptable ite=s you would inspect for:

21.

A. %,.., y B.

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When perfor=ing visual examination of safety related welds on seismic hangers and attach =ents, acceptance criteria shall be in accordance to:

22.

A.

AWS D1.1-75,Section VI I

I B.

ASE I!!, Subsection NE R

s-

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C.

ASE III, Subsection' N3 R

D.

AWS D1.1-75,Section V What type of defect is found in each of the numbered ARIAS in the sketch below?

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/e - a V-f 3 List of Defects:

/e.v.u LAP 26.

Area 2 cas,eo L c.c.c e C-23.

Area 1 Uo e ss- 01 1-r-24 Area 3 % -s,w; /c,tas e s /s uc, 27.

Area 4 !_ % aL %. umea 25.

Area 5 st w Wh e ut f

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A.

Acceptable L_j B. Not acceptable @

Reason l o sC., e m e-L-4 k

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29.

A. Acceptable i

I E.

Not acceptable l

Reason I o e> uN. c_, c. o-k rc, UUV2 b(3 's.}

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FOR REFERENCE DE 3 0.-

A.

Acceptable B. Not acceptable i

31.

For Butt joint, F indicates the A.

Included angle O

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B.

Effective throat @

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C.

Root openin, (j'

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D.

Groove 32.

For fillet weld, F indicates the A.

Leg n

B.

Throa:

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Face M

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33 The welding sy=bol below represents:

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a A.

Fillet weld k" throat dimension, full penetration R

3.

Fillet weld k" les dimensions, full penetration

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C.

Double bevel k" throat dimension, full penetration 1

I D.

Single bevel k" thr6at di=ension, partial penetration M

34 The welding symbol below repres'ents:

T* k

^

er A.

Single bevel k" leg di=encion, melt-thru grind surface l

l B.

Single bevel k" throat dimension, melt thru, grind surface Q

C.

Vee bevel k" throat di=ension, full penetration grind surface M

D.

Double bevel k" throat dimension, celt-thru, grind surface I

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Which of the welding sy=4ols have correctly represented the welded joints below?

A. C

^

B.

U

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c. O You have two plates welded together and have to visually inspect to the following criteria:

36, Welds and base metal 1/2" from toe of the veld shall be free of cracke, or any linear discontinuities.

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36.

Is discontinuity No. 1:

A. Acceptable C

B. Not acceptable 8

Reason Am-

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M R EFERtNUt un.

, 37 Is discontinuity No. 2:

A. Acceptable

,O B. Not acceptable Act di M h cl u:u el /do n' Benson d w r E. atv. i._x,,

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38.

Is discontinuity No. 3:

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A. Acceptable B. Not acceptable U

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39 Is discontinuity No. 4:

gers A. Acceptable B. Not acceptable i

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Reason W Su gg o e g WAC M C/. / /9W 3/g e on )

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Records or Veld Test results shall be kept by the manu*acturer or contractor and shall be available to those, autheri::ed to exa::ine the=.

TRUE or PALSE 00015G05

L, K> COMSTOCK & COMPANY. INC.

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WELD ICPECTIEN CHECKLIST cwas. 2 o G - o - 339 3 d-REv.

43 e

welcer No.

E.5 ITEM / TYPE HO C<

GD 0 A L ITEM /ECUIPMENT NO.

M /A No. of Welcs Inspected -

S LOCATION 772A/A>/A>b bo" FCR/ECN, ETC.

NA DETAILS 4NSPECTED S S 2. 4 82 MMed7/o o ACC.

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N/A 3.2 WELD WAS SUFFICIENTLY CLEANED AS NOT TO IM

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INSPECTION, PER PARA. 3.2 3

gg I. ' 3.3.

FILLET SIZE / THROAT, GEOMETRY NFIL 4

RM TO MINIMUM PROCEDURE REQUIREME AND ORAWING DETAILS PER PARA. 3.3, 3.4, 3.5, 3.6, 3.9, 3.10, 3.11, 3.12

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3.7 CRACKS, THE WELD HAS NO VISIBLE CRACKS PER PARA. 3.7 M

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3.8 THOROUGH FUSION EXISTS BETWEEN WELD METAL AND BASE METAL, PER PARA. 3.8,3.15

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3.13 SURFACE PCROSITY IS WITHIN MINIMUM ACCEPTABLE LIMITS PER PARA. 3.13 N

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3.14 ARC STRIKES ARE WITHIN ALLOWABLE REOUIREMENTS 4

AS NECESSARY PER PARA. 3.14 h

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g 3.18 FIT UP COMPONENTS IS WITHIN ALLOWABLE REQUIREMENTS PER PARA. 3.18 AND WELO SIZES INCREASED ACCORDINGLY(

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3.19 SURFACES AND EDGES OR BASE METAL ARE WITHIN MINIMUM g

REQUIREMENTS FOR NICK, GOUGES, CUT EDGES, OR OTHER N

SURFACE IMPERFECTIONS PER PARA. 3.12, 3.19, 3.20

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3.21 WELDER (S) STAMP IS INDICATED BY ASSIGNED SYMBOL NEAR WELD JOINT

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REMARKS: 33 IMtd t4 ISL; L1 G Ln # 4 U c_.

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CC inspector Levos 11 ins;+ctor

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PREPAAID APPROVE 3 REV13E0 TTiu ORIO.DATI REY.DATE PCAM e RAB RR ATS PROCEDURE 5/26/80 G 10/15/84 19

L. K. Comstock & Company, Inc.

WEl.D INSPECTIEN CHECKLIST 3.1 PTL Ret No.

DWGS. 20/ 0 ~ 22 93 M R EV.

V Werder No.

C"' 5 (TEMfTYPE W0e k' bAdridAl No. of Welcs j

ITEM /EQUlPMENT NO.

M /4 Inspected e

LOCATION R4 /s/n )e a a FCR/ECN, ETC.

H /4 DETAILS INSPECTED 88 ACC.

REJ.

N/A 3.2 WELD WAS' SUFFICIENTLY CLEANED AS NO il l'

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INSPECTION, PER PARA. 3.2

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. ' 3.3.

FILLET SCE/ THROAT, GEOMETRY en FILE CONFORM TO MINIMUM PROCEDURE REQUIREMENTS AND DRAWING DETAILS PER PARA. 3.3, 3.4, 3.5, 3.6, 3.9, 3.10, 3.11, 3.12

(

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3.7 CRACKS, THE WELD HAS NO VISIBLE CRACKS PER PARA. 3.7

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3.8 THOROUGH FUSION EXISTS BETWEEN WELD METAL AND BASE METAL, PER PARA. 3.8,3.15 M

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3.13 SURFACE POROSITY IE WITHIN MINIMUM ACCEPTABLE LIMITS PER PARA 3.13

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. Ih>1d cc m;cw Date V-2 2'-6 Signed Date dignes A uve, u mmy PREPAAED APPAQVED AEVISED TTTU CRIG. DATI AEV.DATE FCRM e RAB AR ATS PROCEDURE 5/26/83 G 10/15/84 19 j

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QC INSPECTOR HAPASSMENT CONTENTION Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B, and 10 C.F.R. Se c t i on 50.7, Commonwealth Edison Company and its electrical it[g contractor, L.K. Comstock Engineering Company have failed to provide sufficient authority and organiza-tional freedom and independence from cost and sche-dule as opposed to safety considerations to permit the effective identification of and correction of quality and safety significant deficiencies.

Systematic and widespread harassment, intimidation, retaliation and other discrimination has been direc-ted against Comstock QC inspectors and other employ-ees who express safety and quality concerns by Comstock management.

Such misconduct discourages the identification and correction of deficiencies in safety related components and systems at the Braidwood Station.

Instances of harassment and intimidation include at least the following:

1.

At various times since at least August 1984, including in March 1985, more than twenty five (25)

Comstock QC inspectors,have complained to the NRC about harassment and intimidation by Comstock super.

visors.

Such harassment und ihtimidation has been carried out or participated in by QC Manager Irv

.DeWald, Assistant CC Manager Larry Seese, QA Manager Bob Seltman and QC Supervisor R.M. Sakalac.

Such harassment included widespread pressure to approve deficient work, to sacrifice quality for production and cost considerations and to knowingly violate established quality procedures.

Harassment and retaliatory treatment included threats of violence, verbal abuse, termination of employment, transfer to undesirable jobs or work in areas where quality deficiencies could not be noted, assignments to perform burdensome or menial "special projects" and other adverse treatment.

Such discriminatory action was taken because of the victim's expression of quality or safety concerns.

Former Level II QC inspector John D. Seeders has knowledge or these widespread instances of harassment.

By letter of August 17, 1984, Seeders complained to the NRC, Edison and Comstock management regarding instances of harassment directed against him.

Subsequently, Mr.

j Seeders was involuntarily transferred to the position l

of Engineering Clerk in retaliation for his expression of quality concerns.

Such assignment was intended by Comstock to keep Mr. Seeders away from sensitive work areas.

Although QC Supervisor R.M.

,rn l

's ATTACHMENT B PAGE 2 Sakalac was finally terminated in 1985 for his mis-treatment of QC inspectors and other elsconduct, the effects of his harassment remain uncorrected and systematic harassment continues,at Comstock to the present.

The existence of widespread harassment impugns the integrity and effectiveness of on-going corrective action programs designed only to address other widespread-QA failures at Comstock.

2.

Comstock management, including CC Manager Irv DeWald and Corporate QA Hanager Bob Marino harassed, discriminated and retaliated against, and ultimately terminated Level III QC Inspector Worley O. Puckett because Mr. Puckett made numerous complaints about safety and quality deficiencies which he identified in the course of his duties at Braidwood.

Mr. Puckett was hired by Comstock in May 1984 in the newly created position of Level III QC Inspector whose duties included conducting a review of Comstock procedures, tests requirements for the more than 50 Level II QC Inspectors, rev,iew of the Level II's inspection work, and the resolution, of inspection disputes.

Mr. Puckett was highly qualified with 20 years' nuclear Navy and nine years' nuclear power (f) experience.

See, Resume,' Exhibit B.

During the course of his employment with Comstock Mr. Puckett was shocked by the widespread deficiencies in procedures, qualifications and workmanship.

He identified numerous instances of improper construc-tion procedures, improper qualification of welders,.

and material traceability deficiencies.

He ultimate-ly recommended a complete stop work order for all welding activity to permit effective corrective action.

See, Memos of August 10 and August 17, 1984 Exhibits C and D.

Finally, he warned CC Manager Irv DeWald that "we are approaching a complete. breakdown in our QC p ro g ra m."

August 22, 1984 Memo, Exhibit E.

Puckett was subjected to harassment and retaliation because he raised these safety and quality concerns and was terminated on August 27, 1984 b y D e W a l d o n* t h e pretext that he should have scored higher than his 865 on a qualification test.

He filed a complaint with the U.S. Department of Labor, alleging violation of the employee protection provisions of the Energy Reorganisation Act, 42 USC 5851.

Letter September 5, 1984 Exhibit F.

The U.S. Department of Labor d"%

Area Director sustained Mr. Puckett's complaint finding unlawful discrimination by Comstock against

asanchne.ni 6 e46t J Puckett and ordered relief.

Notes of Decision.

November 6, 1984 Exhibit G.

Mr. Puckett presented his case at a hearing before an Administrative Law Judge on Comstock's appeal.

See, Complainants' Pre-Hearing Exchange, Exhlbit H.

Comstock settled Mr.

Puckett's claim before putting on its case.

The terms of settlement are subject to a non-disclosure agreement between Comstock and Mr. Puckett.

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Charles E. Norelius, Director, Division of Reactgr 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 N0: RIII-85-A0072)

On March 29, 1985, at approximately 10:00 a.m. the Braidwood Resident Inspectors (L. G. McGregor, R. D. Schulz, and W. J. Kropp) telephoned the Region III Of fice and advised that six L. X. 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.

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 intimidating / harassing the Comstock inspectors.

4.

Ninety three hanger inspections, containing 1100-1200 welds, were signed off in one day by an unidentified inspector. The allegers considered this to be too many inspections for a single inspector to make in one day without the quality of the inspections suffering.

5.

N (phonetic spelling), a Comstock QA inspector, is assigned to the records vault for the sole purpose of closing nonconformance reports. N never goes to the field to verify the condition before closing the nonconformance reports.

6.

All of the allegers claimed to have spoken to the Braidwood Quality First Team without gaining any satisfactory response to their 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 their concerns.

/

Charles E. Norelius 2

APR 5 1955 The allegers were h S N and W (a!rlrenigin N, N l

phonetic spellings).

None of the allegers requested confidentiality and each agreed his identity could be used if necessary.

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

These allegations (RIII-85-A-0058; RIII-85-A-0062; RIII-85-A-0067; and RIII-85-A-0068) generally encompassed those identified above.

Further, CEElp was the source of a'11egation 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 Of rector of the Division of Reactor projects were also informed 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 provi. ding the information to Comonwealth Edison and informed 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 Resident Inspectors' Office. They were informed of the plan to bring Comonwealth 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 acccmpanied 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 repo rts).

INSPECTOR COMMENT SgrEglttys Rich Saklak continually violates procedures during inspector certifications.

1 4.*

p Saklak threatened 4tgl3r for not closing an inspection report which still had an open engineering change notice.

ORS refused and Saklak stated, "if beating was legal you would be dead." (23 later checked with QA and found that his position on the issue was prcper.

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John Walters ( N lead) and'Xen Worthington (6 supervisor) told 6 that he would lose his Jcb if he did not hurry up and produce more inspections.

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Charles E. Norelius 3

APR 5 us 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."

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

1 h

On November 5, 1984, Saklak told him to finish an inspection even though drafting errors were noted. 1EED complained to Comstock management about this issue, but did not rece,ive any satisfaction.

6

& observed a base metal reduction problem in a structural 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. 4l$ngs also told Daryl Landers.

Landers infomedettDag,to keep up his production or he would lose his overtime. (See 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 100% with that statement).

(NOTE: RE:S provided information under allegation RIII-85-A-0067)

M Comstock emphasized inspection quantity first, not inspection quality.

6 Saklak berates inspectors. Many inspectors have been discriminated against at one time or another by Irv DeWald, Comstock QA Hanager. DeWald's attitude is "how can I hang you, not how can I help you."

r 6

ConstantlyintimidatedbySakla[.

Saklak lied to get 6 fired. WWW stated that he has written statements from several witnesses to back-up his statec:ent.

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Saklak uses foms contrary to procedures.

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

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1 i

IAPP 5 bo3 Charles E. Norelius 4

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Aggggut 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

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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 to12EEEQL 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 informed 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.)

s e g g st g t s e n.

Hangers aren't even being inspected, just as-built.

No inspection reports or nonconformance reports are written.

Walkdowns are being done and drawings made to show as-built configuration.

rMmunspuma 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 all of the certified areas; therefore, the quality of inspections goes down.

6 erh(phonetic spelling) is both an inspector and auditor. IB M p will inspect something then do the QA overview audit. !!!!EC) believes this to be a conflict of interest.

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

At approxicately 1:15 p.m., March 29, 1985 Tom Maiman, Connonwealth Edison Vice President and other Commonwealth Edison officials were telephcned 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 form twenty-four Comstock inspectors and in general terms the allegations concerned Comstock's push for inspection quantity not quality, Saklak's perceived performance and the inspectors perception of the performance of TAC Quality First Program. Maiman stated that Commonwealth Edison would begin to look l

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

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

1

APR 6 by Charles E. Norelius 5

/

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 III during the week of April 1,1985, to discuss the long range plan.

The short range plan identified below would be accomplished by the close of busines,s on March 29, 1985.

1.

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

Comanwealth 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 perfbraance.

Comonwealth 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.

2.

Saklak was administratively removed from his supercisory position until the allegations are resolved.

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 Comonwealth Edison Quality Assurance Project Letter was also issued to reemphasize the Comonwealth Edison Project Quality Assurance Policies, s

APR 5 585 Charles E. Norelius 6

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

7 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 RIII:0RS OI:RIII E. G. Greenman J. F. Streeter SRI-Braidwood 1

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March 29, 1985 MEMORANDUM FOR:

R. F. Warnick, Chief, Projects Branch 1 C. Weil. Investigation Coordinator FROM:

L. McGregor., SRI Draidwood R. Schulz, SRI Braidwood

SUBJECT:

QUALITY CONTROL ALLEGATICNS FROM L.

K.

COMSTOCK INSPECTORS On March 29,'1984 at approxima'tely 08:15 hours, six quality control inspectors from L. K. Comstock walked into the NRC Braidwood office with numerous allegations which "effect" the quality of work being accomplished by the electrical contractor.

The meeting began with the resident inspector advising these men of the right to remain anonymous and if they choose not to the NRC would like to have their names, phone number or address in order to obtain further information and/or to advise them of the results of this meeting.

The six individuals gave the following information:

Inspector X:

We were going to have a lot of people come over but we figured it was better to have a small number. We have 109 people there now and all are about to walk if conditions remain the same.

Inspecto X, who came to the NRC with allegations on March 13, 1985, said:

My supcrvisor Rick said to me "You should close them" (ICRs) (normal route is through engineering)

"out and be done with the thing." He said "I should evaluate it myself and close it out".

Rick said "you know what engineering is going to write and what the disposition will be so close it out".

I said "That's not my functicn."

Rick said "No wonder we have such a back log of documents you won't evaluate them or close them out".

I said "I have to follow my procedure - It's not my decision to close out ICR's or NCR's."

Rick said "I can put you in the vault or whatever and make you do it all".

Rick came back to my desk and said "At times you make me so pissed off that if beating was legal you would be dead" I have several

witnesses to this statement.

I didn't agree with fh$

the man but he meant what he said.

He has jumped on my ass before - he flies off - just like that -

he has done it many times before. The biggest thing is this is not the first time and everybody knows about it, but nothing is ever done.

He (Rick) is not certified in my area and he is telling me what to do and my Lead is not certified so I am stuck in.the middle so far as procedures go.

I gave the NRC these problems Mar,ch 13, 1985

• and I don't know what is being done about it.

Rick doesn't want to admit he is wrong, which he was - dead wrong and I didn't agree with the man -

its' always been an En0 neering function when and i

ICR or NCR is involved so I don't know where he got the idea I should close them out.

He has jumped on my ass before - he has always been wrong

- what do you expect, the man isn't qualified and yet he is giving orders to inspectors on things he doesn't know anything about - areas where he is dead wrong.

It is done just to get the paper work completed so the numbers look good.

Another Individual: One of the biggest things is this isn't the first time he done this and we are getting tired of this shit.

I know of at least five guys that he has jumped on and nothing gets done - they just give him a new title or transfer him to another area - they have cut his responsibility down to four areas, yet he is only certified in one of those four areas and is still telling inspectors what they should do.

Why is he threatening me with other thin 0s - he is telling me what I have to do - he is not certified in my area - he doesn't even have a background in calibration.

I know he got.EEIm out of there (an inspector removed from his job) - he was railroaded out.

It wasn't EEE3d s f ault because the department was messed up - nobody was certified in that area.

Rick had a grudge against dGD2P so he got him moved out.

They have to do something about this guy -

know they have taken some of his power away -

I don't know if he is holding that against people or because he has lost files there or what.

They got leads now - new leads, and I could (f) walk up to them - except for two guys and ask them a question in their area and they cannot answer it.

They are getting in a bunch of new people and making them teads - NRC why is that? Because they will do what they are y

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told to do - sign what needs to be signed and Agg get the NCR's or ICR cleared away.

This is C

50 because the new people are under a 90 day period of surveillance and could get fired at any time.

They want to keep their job - who doesn't.

These people are closing out NCR's and they don't even know what the hell they

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mean.

They have no idea that there is a disposition needed on them and they are just

~

signing them off.

Our Leads were more or less told in a meeting last Friday that as long as our numbers stay down (the numbers of NCR's or ICR's they generate) they (the inspectors) won't be evaluated.

If you don't keep them down to a fair level then you will go back on eight hours you will lose your overtime a'nd they will jump all over your ass.

This is not one area but in all areas.

They are going through out status now (numbers of inspections completed and number of NCRs or ICRs written) they are always interested in numbers - not quality - in fact we had a guy written up last week because he didn't have enough numbers.

The quality first or what ever you call it sucks - It's Ceco working for Ceco and all this bullshit reporting anything hasn't done a damn bit of good.

I have not seen one improvement since it started.

We were going,to take 50 guys and walk over here and do nothing until something was done about it.

I was in a room - I started doing inspections - I started writing up,NCRs -

cable pans - the welds were bad.

Then I started on configuration.

I started to find many problems and writing up NCRs so they threw me out.

They don't want somebody that will do the inspection they want somecne to l

sign the paper.

They went and sent five engineers up to that same room and they did every cable hanger and didn't find one problem - not one - no deficiencies.

They are as-built walk downs.

They make the problem fit the as built condition so it doesn't look like any problems exist.

We have done - I don't know - one hundred and (I) some odd hangers this past week on a walk down probably a hundred - all but one or two are no good.

o

One supervisor who was not certified in my area wanted me to close out several of my ICRs and I refused to do it and so I got a disposition from engineering.

Rick said "We know what's going to happen in this area -

why don't you just close them out".

They are going through our status reports now and the word is out now that they are going to weed out _ three inspectors and that what they are basing it on is the number and not the quality.

NRC: Are the new people, the people who get the NCRs or ICRs completed, getting the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> or overtime?

Individual:

Yes, they are getting bought-of f - they are going straight' to the' vault closing the documents out -

hangers might not even be there.

Another craft may have cut it down and this guy is saying

" accept as is" and the hanger is lying on the ground.

NRC: Do you men find any problems with the craft problems of intimidations or harassment of any kind in the field?

Individual:

No, we never have any problems at all - There are a few inspectors claim they have problems - but I think its mostly a personality conflict.

The new people are afraid of Rick because of the 90 day period - I have had a couple of people (the new people) tell me we are with you but we can't do anything until o*ur 90 days are up.

There are approximately 40 or 50 new people.

I can show you time sheets if you want to know the truth - how many guys are working Saturday, Sunday working at home and getting paid because they have suction power or whatever you want to call it.

We have been training these guys.

The easiest way to do it is to walk into the office and ask them how many certs (certifications) do you have and ask him can he accurately do one? For example,IEEEpn asked our Lead if she could get some cable pulling going because she is going on nights.

She asked if she could do some actual inspections so she could catch on.

She just got certified last week.

He told her no, she has 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training and they are going to throw her en night shift with no ggh practical experience in cable pulling.

These new people don't even know where the work points are.

I have bitched to Ceco about the engineers (L. K.

/Sg Ccestock has only 6 cetual engineers) completing the NCR's with "use as is" I must have over 1,000 NCR and only 5 or 6 have had actual rework.

I have seen a cable pan voided on an NCR.

This person passed 93 cable pan hangers with 1,114 welds and all these welds were accepted.

These 93 cable hangers were completed in one day.

They had a guy from QA assigned here for approximately two months who was cTosing ICRs.

QA doesn't do Level.

II inspections in the field.

How is this guy ng to do a QA audit on himself? They have now

,. iled him out - he was working directly at the vault.

fnspector A:

I was told flat out Friday that we are making these people (new hires) the Leads because they will get the job done.

That's what my supervisor said you know what kind and amount of paper work they will complete.

Inspector B:

I have been inspecting for 15 years and this is the first nucicar job I have seen where quantity is first - not quality.

Inspector C:

I was a Lead at one time and give it up because of the intimidation.

I was present one day when Rick was using extreme profanity towards one of the inspectors.

This inspector asked to please stop it but Rick refused and kept on.

His attitude is how can I hang you and not how can I help you.

Inspector 0:

My Lead (Mr. A) told me unless my production is increased overtime would not be warranted.

I also witnessed Rick trying to order an inspector (4Egh@ to sign off an ICR.

Rick said it is being addressed - sign it.

(he pointed his finger in the inspectors face and said " sign it off - sign it of f - sign it of f - now".

Inspector E:

It is true we have intimidation from more than one supervisor or Lead.

Inspector F:

I have had so many run ins with Rick.

Rick demanded that I should write up an electrician and if I didn't I would lose my qualification.

It had something to do with items not up to par or not correct on a drawing.

ffhInspectorG:

I am now being watched all the time - I must work to an hourly schedule of specific jobs for each hour. They are keeping book so they can fire me.

All of the inspector's stated that they thought quantity was

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first and quality work or inspections were secondary.

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The resident inspector called the region for a conference call

(')'whenthesecondgroupofinspec'torscameintotheoffice.

The resident inspectors feel that the region shod 1d send an inspector to the site to interview these Q.C. inspectors individually and to investigate NCR-1616 and ICR 2900 which the inspectors claim have been inappropriately dispositioned.

It appears at first glance with the information we have received that a shut down or seme other aggressive action of the electrical work may be necessary to establish the quality of past work and the quality -

of the ongoing work.

The lac! of action by. Ceco QA in this area needs to be addressed along with Ceco managements slowness or inability to take corrective action.

The resident inspectors appraised Ceco management last fall of the problems in L. K Comstock Quality Control Department.

L. ficGregor SRI Braidwoo,d R. Schulz SRI Braidwood I

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7 March 29, 1985 MEMORANDUM FOR:

R. Warnick, Chief, Projects Branch I C. Williams, Chief, Plant Systems Section FROM:

L. McGreGor, SRI, Braidwood l

R. Schulz, SRI, Braidwood

SUBJECT:

TELEPHONE CONFERENCE CALL WITH COMMONWEALTH EDISON IN REGARD TO L.

K. COMSTOCK OllALITY CON 1HOL PROBLEMS.

4 d

During the course of the normal work day (Friday, March 29, 1985) the NRC Resident Inspectors were confronted twice by L. K.

Comstock Quality Control Inspectors, first by six inspectors and again later that same day (noon hour) by twenty-four inspectors, all with allegations of 1) intimidation, browbeating threats of cuts in overtime hours, harassment and to put bodily fear in i

front of the quality control inspectors, 2) quality control inspectors are training their lead inspectcrs and supervisory personnel who are managing the L. K. Comstock QC organization (management personnel are not qualified or certified within the disciplines which they are governing) and 3) the quality of i

inspector work has become secondary to managements insistence on quantity of and completion of inspections.

This memorandum 1

outlines Commonwealth Edison's corrective action program, as i

described to the NRC, to alleviate.the immediate problems and inspire a conscientious quality assurance and quality control program at the L. K. Comstock Company, i

Present in the residents of fice at the Draidwood site are L.

McGregor, R. Schulz, (NRC) and f rom Commonwealth Edison (Ceco)

Gene Fitzpatrick and Lou Kline.

At the Region III office are, R.

Warnick, R. Learch (sitting in for P. Pelke) R. Mendez, C. Wiel, and C. Williams.

Warnick/ Williams 2

March 29, 1985.

Mr. Fitzpatrick stated:

Commonwealth Edison-(Ceco) actions will include both short ters and long term items.

First cf all I'll

~

tell you of the short term actions that we have already ccmpleted or are in process of completing which will be finished before the and of the day.

The first thing we did was (Ceco management Maiman, Fitzpatrick, T. Quaka and D. Shamblin) to meet with -

Comstock site management to express our concerns over (1) cencerns submitted to the Quality first program and (2) the concerns over the allegations made today.

Point I of Short Term:

We told L. K..Comstock that Ceco expected them to perform their work in accordance with, or consistent with the quality assurance and qual *ity control requirements and in particular with their own policy statement, which is section 1.0.0 out of their Quality Assurance nanual.

Comstock said they ware aware of some of the problems and were investigating them under their program and especially concerns or issues of Mr.

Saklak.

Part 2 of Short Term:

CECO has requested, and L. K. Comstock has agreed to administratively remove Mr. Saklak from his duties pending completion of their investigatior relative to allegations concerning harassment by Mr. Saklak.

CECO will be involved in the review of Comstock's investigation and depending what that review indicates we may have a cicar course of action or we may have some additional digging.

Part 3 of Short Ters: There is a memo being issued this afternooon setting up a meeting (r.cquested by Ceco) with all j

quality control personnel of L. K. Comstock (managers, i

supervisors, inspectors) to (1) reiterate the Quality Policy (2) to confirm Ceco's concerns about the concerns given to the Quality First Program and (3) any other concerns that may be j

lurking out there that we are unaware of at this point and time.

Wa will give them (inspectors) an opportunity to express either cpenly or privately throughout the Quality First Program or j

through other vehicles that they may elect to choose other than the Quality First program.

Ceco will make a firm commitment to J

rosolve those concerns and any other concerns that they have.

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Part 4 of Short Term: We are issuing a joint quality assurance l

project letter reiterating our commitment to a strong quality program in support of L. K. Comstock corporate Quality Assurance, 4

Quality Control policy.

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4

Warnic k/ Williams 3

March 28, 1985

@ These are the four actions we have Going or have completed today end we have also an expectation that we will be prepared by the ciddle of next week, to meet with the residents on the status of o longer range plan.

Any questions on what I have said?

Region III:

When is the meetin0 to take place?

CECO:The. meeting with L. K. Comstock Quality Control Organization will take placa at 8:00 Nonday morning.

Region III:

As you think about this long range plan you might give consideration as to what Ceco wasn't doing or what you can do to keep a better finger on the pulse of what is happening at Comstock and other subcontractors so that your guys get feed back, as to the problems as they are formulating rather than waiting till the problems get to the point they are so severe; the individual feels they have to go to the GRC to get some cction and relief.

CiCo:

Yes, that is the ideal situation to be in - we have an awful lot of things going on - that for example we were aware in the past of moral problems in L. K. Comstock organization.

A lot of that was attributed --- to perhaps the dollar situation and the certification process these guys had to go through.

I Region III:

Has L. K. Comstock corporate been readied at all with this?

Ceco-No, L. K. Comstock corporat,e personnel are on site for this meeting today. We will make sure they are informed, but that has not been done as yet.

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I Warnic k/ Williams 4

March 28, 1985 i

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Region III and the residents were satisfied with CECO's comprehensive and extremely swift corrective actions taken this afternoon.

An agreement was made to keep the NRC appraised of the treetings to take place early next week and Ceco's long range plans to address quality assurance and quality control prcbleras,

identified at L. K. Comstock Ccmpany.

I 4

L. G. McGregor R. D. Schulz t

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_ _ _ _