ML20214E898

Intervenor Exhibit I-ROREM-22,consisting of Summarizing Results of Investigation Into Lk Comstock QC Inspector Concerns.Meeting to Discuss Findings Suggested. Related Info Encl

ML20214E898
Person / Time
Site:	Braidwood
Issue date:	05/08/1986
From:	Quaka T, Shamblin D COMMONWEALTH EDISON CO.
To:	Dewald I COMSTOCK ENGINEERING, INC.
References
1806A, BR-PCD-85-338, OL-I-ROREM-022, OL-I-ROREM-22, NUDOCS 8705220306
Download: ML20214E898 (12)

Text

!

50- 45 ? s/57-sc sk/sc T- / dam - 2. L

'[ '

Comm:nwealth Edison C2.

O Braidwood Station R R 1. Box 81

' {~T l t

L \\

Bracevine, IL 60407 Tele;: hone 815/458 2801 April 29, 1985

'87 AFR 22 P6 :50 BR/PCD 85-388 di 00CP L. K. Comstock and Company. Inc. (LKC)

Braidwood Nuclear Power Station

/

Braceville, IL 60407 b;.60 b

Attention:

Mr. Irv. DeVald N

~

0. c.y#(&

Quality Control Manager

Subject:

Braidwood Station - Units 1 & 2 Sargent & Lundy Specification J-2590 i

Electrical Erection Work

Reference:

BR/PCD 85-288, Dated March 29, 1985

Dear Mr. DeVald:

Commonwealth Edison Company has completed their investigation into the LKC Quality Control Inspector concerns brought to the attention of our Quality First Department. The investigative material is filed with Record of Concern QF85-ll88, 85-1229 and 85-2026. Our Quality First Department will be responding to those LKC Quality Control Inspec ors who initiated the original concern.

The following summarizes the results of our investigation.

(1) The intimidation incident of March 28, 1985 involving Mr. R. Saklak, Quality control Supervisor, and a LKC Quality Control Inspector working for him has been substantiated. LKC has taken appropriate action on this incident in accordance with their Corporate policy.

(2) No other cases of intimidation or harassment by LKC Production or Quality control management were found during our investigation.

(3) The LKC ANSI N45.2.6 Quality control Inspector qualification and

' certification program is being effectively implemented.

(4) The concern that LKC Quality Control management is more concerned with production than quality was not substantiated. LKC Quality control management is effectively implementing Policy Statement 1.0.0 dated May 1, 1980.

8705220306 860508 PDR ADOCK 05000456 09 00019 sis 3 0

PDR

ER/PCD 85-388 Page 2 of 3 (5) Signatures are only being placed on quality documents (i.e.

nonconformance reports) in the LKC office when field verification has first been accomplished.

(6) LKC has since August 1984 continued to devote management attention towards improving the overall morale of the LKC Quality Control l

staff.

We have the following recommendations for your consideration.

(1) LKC should initiate a corporate level procedure which formalizes their current method for investigating concerns brought thru their organization. All LKC personnel should be advised of this procedure.

(2) Quality Control management should spell out and communicate to Q.C.

Inspectors the rules and circumstances covering refresher retraining i

of Inspectors.

(3) Quality control management should explore the possibility of giving Inspectors work in the area of new certification upon certification to that area for a period of time (i.e. one to four weeks).

(4) LKC Production already does a large amount of craft and foreman training. A procedure governing under what circumstances and which craft and foreman receive training should be developed by LKC Production.

(5) Quality control management s.hould standardize on-the-job training (CJT).

(6) Quality Control management should identify methods for better communications between LKC Management and Q.C. Inspectors. As an example, the purpose of the Daily Status Report has apparently not been properly communicated. Inspectors should be made aware that this report is: a tracking vehicle for the 30 day report; a method of trend analysis to ascertain those inspection areas falling behind; and a vehicle to monitor individual performance to determine capabilities or training needs.

b) Quality control management should review the need for interpersonal skills training for Q.C. management and supervisors. We can provide assistance through our Project Training Coordinator in this area.

We would like to discuss the above recommendations at your convenience.

We also plan to communicate our investigation results and recommended actions to L. K. Comstock Quality Control personnel. An open meeting will be scheduled for the near future. Commonwealth Edison wishes to express their 1300194S0 m

-m

}

BR/PCD 85-388 Page 3 of 3 thanks to L. K. Comstock for their cooperation and professional attitude displayed during our investigations. The temporary inconvenience caused by our investigation was far outweighed by the seriousness of the issues involved. We consider the issues raised by these Record of Concerns closed.

very truly yours, ha L.WA D. L. Shamblin Proj. Construction Superintendent Braidwood Station site Q.A. Superintendent Braidwood Station DLS/kje/1806a cc:

M. J. Wallace E. E. Fitzpatrick T. J. Maiman W. J. Shewski/G. F. Marcus G. E. Groth C. A. Mennecke/J. W. Gieseker E. R. Netzel R. M. Preston (6)

F. Rolan - 1.KC R. Seltman - LKC 4

B0013433

i l

d] AK 7.DA l C.

^- " *' o '

pg / #7.

l vase

2) ATE A 7Aeny TLM (.5_.E J./S M %

/ocmoN So 8

H S-1kic>>tne l67 #'"S

+' D ' k.2> G&

M ^' W Y A.rs/GNEb

'3:oeA.W.

TRmmUQ l& /67 krek l,*,,,

p.cxA waxes onwarer>w g.,o a.m reswM S/7/8f" u w -a*m r,

cener n.:ea r m R. Bnowd 2VJ'ncrrrrs p p tj 1::g rm, 72.n~wd 8l7/8f Pun-r Twr 3 3.~ Rn7 b. Cerdy Orss~7mW i w scaz,<f s:3s n n.

ru;xim 1?o nm. 2>. fir.a'v A r,*rrir~r'st' 3/7/Ps*

xis ns.t fn hauef8x/M 8{S/2f a m m sra y.$: er. r~ C s it'r

' N m

cr e n-w.

S/9/8f cegy r., !

$ tr 1~ G ts' I ** 0/ /

.r 1.:: 1. m.

W 8/iz/8r cxus x,t/ l9 p ro.

7 ErroLE ~

flt-d

_ Efi3/ar S//4/8C' l

g S//r/Bf e/to/gr f

I

! y M, 77.swwg wn.m rzsr E47/er rwe nu.

iz:a em > ara'y zc m a n7n g eJr irg,pe, 6/R/2f' caut F. sit 95, ri>- T Cm, &

f<rf.e/

PM,cA t.

g o ~ A.n],

unm r>

S/2o/27_c" csz, z rsu.,3.3: w. 7 Si>i//

, Mr,. /

/ nc tr-Arfr- " 5 3.n EA'

ilson m G

~7" S/zo/ss -

,g,7,isn:.e vi~ n.D. Gr4 LDessnrs ;-r-nn.aw s os u M.srz.sr> w

~73 S/2 //8.7 rr? ~m -

Y3.~ &

1~ 3~lr //

NNVW o-

.- :: A r.

liC0194S4 Sl*N5~~ Mkomm y:30 nm 7~ Smi/s-f)st,/

$;o: A.M, V

Tr/ /n / n Y Y.

PM.

Y C' f

S/f" Y

S T A R 'l. D ^ t L o*3-e' m2 or z.

MAFfE bhW A' 7th'iTV 71_M L $_ M$1GNFb %

letATn3M 0TT

$:o: p.a, J/ fcjaspx/ES

$V M*4??L'A5 Y

o! #

7~ CMf//

fEf/W on

't.or a.m

1. Ybf 7treg wdrs Y:

tm T Tri /F SfW i

g c.77 8'00 A**,

Y8f < 77rphat7515 % pr7

~7~ W/7'bl/

kWl c:rr 8.oe sx-0 1f*./ N /A f ry.;A 3 f n j'sv_ T s T. s i//

/} W x

.n.sa,,n4

1. lU/8r rr.,,,,1&,,s d,%. D. t-rdv nongl u

wwn~ rur a wa s.??

0.77~

/?:3://U.

l 1~ Y //

f* W l

3 ff 7t:crintyrlo.S 4. Err 6

ec,ecra Leere 8:n Am, Y If8 V 'P rpb & _ * '

fn* Y.

'k-S f

~

y __

r s

i

[

4 l

. l i

f 1

1-t i

i I

i i

l C9 B00194E5 4

-~

w w..-mw rr y-.---

---

Tw.-

g g

n-c-

-gee--

,y--y,

-.n

• -------mg y--,,wwyyyw

-.y--e.y

-wwrwvy y

-w--p--

w.we-g=m-ve-*u---

rw9-f--y9 47 e-7

I l

l i

t

%IF~

~..

Comstock Engineering, Inc.

Memorandum D. Sha=blin of fice:

3 raid cod

,o; From.

so,,e:: 3R/PCC E5-368 cate:

0~i W :5 Control No.

QA85-08-20 The following is a response to Ite= #1 of the CECC reco==endations incorporated in the subject letter.

L.K. Cc= stock Quality Assurance has revieve:i the subject reco-a-da-* en to initiate a corporate level procedure for investigating concerns an:1 feels with the prega= available to LC e=ployees and/or the Q:

Inspectors and clerical supplied by Bestco, this for= alining of or proga=s into a procedure is not necessarf, 2e reason behind this decision is that LKC has develope and d

i.ple=ented several pre ga=s and policies over the years and has encouraged ou e=ployees to exercise these policies.

Quality concerns related to plant hardware are re;crted to =anage=en via P ocedures L.11.1 "Non-confor=ing Ite=s" and h.ll.2 " Corrective Actica"

% ough these procedures, a Non-confor=ance or Inspection Correction Report are issued a=:1 hold tazs applied to prevent inadvertent use or =odification to the deficient ite=.

? ocedral concerns er suggestions under ou-CA/QC Prega can te sub=itt ed t/ any LKC e=ployee in accord.ance with P oced.r e 3.1.1

" Revisions to the Quality Assurance / Control Pro pa "

-' li cing Attach =en: A " Procedure Suggestion For=".

Section 3.2 of this procedre is as follovs:

3.2 Vehicle and Recuirenents for Surrestine Revisions 3.2.1 Suggested revisions to the procedure vill be sub=itted to the 1.

Cc= stock QA Cepart=ent or Engineering as applicable by =e=orantiu=

(Attach =ent A).

Se

=e=oranciu= shall indicate the proble: or unsatisfactorf situation pe-tinent to the topic, proposed re=edial action an:1 the expected results.

3.2.2 All persons responsible for the i=ple=enation of i

the QC pro pa: =ay =ake suggested changes to the pro pa=.

A copy of the suggestion for: is attached.

t

. 9001M

C9 i

~- -

I In.. situations where quality related activity is ne: proced a'.ly

- addressed or the activity may cause danage, deterioration or ina'.verten 4

operation =ay :ause futher deficiencies, the G Inspe::o- * ' a --

i.

instructed -(=e=o sk-05-02-lS) to '"Stop Work" until =anagenen attention or the ite= can be re=edied.

"Stop Work" actions are described in Procedu e h.11.3.

• hese actions have been enfor:ed in the pas: and have resulted in satisfactory corrective action to alleviate the proble=.

Since the ~ reorgani:ation that. occu red recently on site with the C Inspector Union organizational

effort, and the reassign =ent of inspectors under Bestco, the inspectors and cleri:a1 staff also have an avenue to pursue ad=inistrative concerns.

"hese are reported to their respe::ive shop stevard in the for= of pievancer.

~his ite:

is dicussed under Article IX in the 3estco/306 IAbor Agee=c.t attached.

During e=ployee exit interviews of resignation, ter=ination, e.,

it is.a policy of Co= stock Engineering, Inc. to discuss with the d

individual how the com;mny vill finalize -any or all benefits: to the e=ployee. As. ;ar* of this exit interviev, a for: letter is presented to the individual.

Contained in this-letter is a state =en asking if he/she is aware of any reportable conditions that have not been reported under the regulations of 10CFR50, Appendix 2,

10CFR Part 21 or 10CE50.55(e).

In the past, this policy, has been exercised and thoroughly investigated by Co= stock.

lastly, all LKC e=ployees and e=ployees under our =anage=en; have been instructed concerning Co==onwealth-Edison 's

" Quality First" pro pa=,

that it is available to the if they dee: necessary.

We have encouraged these individuals to address the ite: to IZC Manage =ent first, but in no vay construed that it was =andatory.

L.E. Co=sto:k also has established - an open door policy to the Nuclear Regulatory Co=nission (.TRO) if the inspector feels that this is a necessary step.

In the past, this policy has been encouraged and suggested to the inspector to assist in the resolution of the proble (reference I.

DeWald's =e,o Sh-03-10-01).

As stated previously, these policies and pro'gn=s have been reiterated to the e=ployee via procedural training sessions, interoffice me=cs, veekly staff =eetings, etc.

L.K.

Co= stock feels confident of ou-i policies and propa=s which have " produced a satisfactory track record concerning these issues in the past while under scrutiny of CECC and the NRC.

We have reviewed your reco==endation. and appreciate the effort put forth by CECO to assist L.K.

Co= stock in resolving this partic" h-issue, but do not dee= it necessary at this time to initiate a corporate level procedure.

f this deter =ination changes, ve. vill infor= Cen=envealth-Edison Co=pany of this.

Respectfully, 1 Wo Es/lf R. selt= ann B0019475 Quality Assurance Manager e:

I. DeWald F. Rolan T. Quaka

7. Paserba R. Preston QC File

1m num W

. CC?AS70CX & COMPANY. INC.

BRA ObCCD 3.1.I c,A sg:-

PROCEDURE SUGGESTION FORM i

IN REGARD'TO:

s 1

I PROPOSE:

EFFECT OF PROPOSAL:

4 P

Signature Date COMMENTS:

~

3-_

i

+ -

~

e-QA/ MANAGER DATE i

AnAcHMENT A U001947G REV. B, 09/18/84 QAS &

9*6 e

-em

+

-n-.--a

-r e-

+s w-

=

vv

~ * -+*'vn*ww'V'vv'Ms*w'*

*~*'H^

I ment and an other relevant documents referred to sentative of the Local Union and de Employer's work hereinsbove in the following manner. Telegraphic site representauve shall meet and endeavor to adfun notice of the Sling of such enfortement proceedirigs the matter within three (3) working days after timely shall be given to the other pany. In the proceeding to notice has been given. The Employer shall respond to obtainatemporar orderenforcingthe Arbitratofs the Local Union's representative at the conclusion of

/

Award as issued under (d) of this Article all parties the meeting but not later than twenty-four (24) hours waive the right to a heanng and agree that such thereafter. If they fail to resolve the matter within the proceedings may be ex parte. Such agreement does prescribed period. the grieving pany may, within not waive any party's right to participate in a hearing forty-eight (48) hours thereafter, pursue Step 2 of the for a Snal order of enforcement. The Court's order or Gnevence Procedure provided the grievance is re-orders enforcing the Arbitratofs Award shall be duced to writing, setting forth the relevant information served on all panies by hand or by delivery to their concerning the alleged grievance, including a short last known address or by registered mail.

description thereof, the date on which the grievance

'*eurred, and t pro n(s) of the Agreement (f) Any rights created by statute or law governing g gg

~

arbitration proceedings inconsistent with the above procedure or which interfere with compliance there.

Step 2. If the grievance is not resolved under Step 1, with are hereby waived by the panies to whom they it shan be referred to the Business Manager of the accrue.

Local Union and a representative of the Employefs ec anager who shah meet and attempt to resolve (8.) The fees and expenses of the Arbitrator shan the gnevance within seven (7) working days after time-be civided equaHy between the moving party or par-ly receipt of the written grievance. If such parties fail ties and the party or part:es respondent.

to reach an agreement, the dispute may be appealed in (h) In any action to recover damages for breach of writing in accordance with the provisions of Step 3 paragraphs 1,2,3 or 4, any detennmation under the within Sve (5) working days thereafter.

procedures of this paragraph 5 by the permanent Step 3. If the grievance shall have been submitted arbitrator concerning whether such a breach has oc-but not adjusted under Step 2, it shall be referred in curred wiu not be binding upon the tribunal to which writing by either party to the General President of the the damages issue is submitted and the existence of a breach may be relitigated by either party, Intentational Union, or his designee, and the Emplov-efs Senior Representative, or his designee, who may

6. The procedures contained in paragraph 5 *hau be negotiate a Snal and binding settlement of the dispute applicable only to obtaining expadited relief from within twenty (20) calendar days from the date of time-alleged violations of paragrsphs 1, H,3 or 4 of this ly receipt of written notice to them.

Article. Disputes alleging violation of any other provi-Step 4. (a) If the grievance shah have been submitted sion of this Agreement, including any underlying dis-but not adjusted under Step 3, either the General Pres.

putes alleged to be in justi5 cation, explanation or ident of the International Union or the Employer, or mitigation of any violations of this Article, shall be their representative designees, may request in wt.t.

resolved under the grievance arbitration procedures of ing, within ten (10) calendar days thereafter, that the Anicle IX.

Krievance be submitted to an Arbitrator mutuaHy 8

agreed upon by them. The Union and The Employer ARTICLE IX shall, after the execution of this Agreement, attempt Grievance Procedure mutually to selee.: a permanent panel of Sve (5) arbitra.

L Any question arising out of and during the term of tors but if they are unable to do so, they sha!I request this National Agreement involving its interpretation the Federal Mediation and Conciliation Service to pro-and application (other than trade jurisdictiot.al dis-vide them with a list of arbitrators from wm,en suen, a putes) shan be considered a grievance and subject to panel shan be selected. The Arbitrator appointed to resolution under the following procedures:

hear and decide any grievance dispute hereunder shah be selected from such panel. The Arbitrator will sched.

Step 1. When any employee subject to the provisions ule and hold a hearing within thtrty (30) days after the of this Agreement feels he is aggrieved by a violation of close of the hearing or, wbere briefs are subnutted, j

this Agreement, he, through his job steward, within

. within thirty (30) days after the receipt of briefs by the Sve (5) working days after the occurrence of the viola-Arbitrator. The decision of the Arbitrator shall be Snal j

tion, shah give notice to the Employefs work site rep-and binding on all parties. The fee and expenses of such resentative stating the provision (s) alleged to have Arbitrator shall be borne equally by the Employer and been violated. The job steward or the business repre-the Union.

j 5

t B0019 &/

l 1

58 ho

/%

g f........ _

m -a.

t_y ;

~~

Comstock Engineering, Inc.

Memorandum To ALL OA/QC PERSOW EL off,c, B raidwood r

From I. F. DeWald

Subject:

Stoe Work Authoritv and Responsibil des Date:

5-2-84 Control No.

84-0 18 i

All C QA/QC Personnel, while performing inspections, shall have the autho rit to "STOP WORK" on any LKC construction activity that may cause damage, d ;erioration, inadvertant operation, or cause to be non-conforming any item, material or equipment. This includes all activities such as cable pulling, equipment installations, welding causing hot sparks or slag to f all on unprotected equipment, etc.

If immediate action is not taken by the production crew, the Inspector shall notify the QC Manager or Proj ect Manager who shall take immediate action to correct the defi~cient situation.

In cases involving other contractors observed perfor=ing activities that may cause damage to equipment or cause a non-conforming condition, the production crew shall be advised of the condition. The Inspector shall then notify the cognizant Ceco Engineer, or the QC Manager, whichever is the most expedient.

or %/L

1. F. DeWald Quality Control Manager IFD/j f ec:

T. Paserba F. Rolas LA. Seltmann QC Fue QC Manager File T. Quaka.

i l

l B0019478' l

d

---..-.-,e

,,.-7.

,_,y

,m._

,,m.

,m_

1. --..pr

---.--r*-ee--e-

@V W

~

Comstock Engineering, Inc.

Memorandum File - Themas F. Smith office:

Braidwood 7,;

I. DeWald From.

Subiect: Concerns Expressed By Thomas F. Smith Om.

3/9/6' Control No:

84-03-10-01 e

During Mr. Smith's resignation exit interview conducted on 3/9/84 he expressed that he had concerns pertaining to the Braidwood Site and L. K. Cc= stock. The list of concerns was generated by Mr.

Smith and a copy was given to Co=monwealth Edison on 3/9/84 by F. Rolan, L. K. Comstock Proj ect Manager.

Commonwealth Edison was at this time having an exit interview with the NRC.

Mr. Smith's list of concerns was presented to the NRC at this time.

Mr. T. Smith was informed by F. Rolan, L. K. Comstock Proj ect Manager, and I. DeWald, Co= stock Engineering, Inc. QC Manager, that if he requested, a meeting could be scheduled i==ediately with Cc==en-wealth Edision Co. and the resident NRC inspector for him to address the concerns. When informed of this he stated he did not want a meeting with Co=monwealth Edison Co. and the NRC.

~

Mk I

DeWald Q ali Co-1 Manager L

K.

o toe ineering, Inc.

l l

I I

F. Rolan IFJ/j=b Project Manager L. K. Comstock Company, Inc.

I cc:

T. Smith F. Rolan 001'3 T. Paserba R. Marino 9

L. Tapella E. Netzel D. Cesaro C. Mennecke QC file QC Mgr. file 1

l i

l

MO COMSTOC K BR AIDWOOD NUCLE AR POWER PLANT R.R. = 1. P.O Box S3A2 s nce f 904 Bracevshe !L 6C407 Comstock Engineering.Inc.

A CoMSToCM G20VP CoupANf I,

E=ployee #

an e=ployee of Comstock Engineering, Inc., in connection with my forthco=ing resignation / termination of my employ =ent on do hereby (Date) voluntarily make the following statements with the understanding and consent that my statements may be used by Comstock Engineering, Inc.,

or its customers in fulfilling its obligation involving 10CTR50, APPI. "B",10CTR50; 50.55(e) and 10CTR Part 21.

I do hereby, state that I am unaware of any reportable conditions end/or def ects that have not been properly reported to this Co=pany's management.

/

Employee Signature Date NOIE: If unable to affirm the above statement, indicate to management in writing, prior to leaving, all reportable conditions and/or def ects.

I also do certify I am not taking propritory information, business correspondence, company manuals / procedures and/or drawings from the premis es. I understand it is a violation of Company policy to disclose any propritory information.

/

Employee Signature Date

~

QC MANAGER PROJECT MNIACER

(

Date Date 99 C9 H00194G0 ATL/.NTA. Cs.CAGO NE7/ VC AK ctTTS2VAGH SAN *AANC;SCO

+

+