ML20215E677
| ML20215E677 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/05/1985 |
| From: | Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20215E651 | List:
|
| References | |
| FOIA-85-777 NUDOCS 8610150444 | |
| Download: ML20215E677 (7) | |
Text
- _ _ _
/p NUCLEAR REGULATORY COMMisslON k
g[
a-MEGION ill
'e p
199 mOOSEVELT ROAD M
GLEDs ELLYN. 0LLtpeOIS 60131
%..... /
APR 5 1985 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 N0: RIII-85-A0072)
On March 29, 1985, at approxirrdtely 10:00 a.m. the Braidwood Resident Inspectors (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 summarized 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.
b was not qualified for his
( ition,)as he was not certified'in all of the inspection areas 2.
pos which he supervised.
( ]was constantly intimidating / harassing the Comstock inspectors.
3.
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.
( igned (phonetic spelling), a Comstock QA inspector, is 5.
ass o the records vjutit the sole purpose of closing nonconformance reports. L_.
never goes to the field to verify the condition before closing t e 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.
GUILD 85-777 PDR C[6 OF'//[& [0 kVh),
rae.saxpernw.
APR 5 1985 Charles E. Norelius 2
The allegers weref
~
l j(al'1phoneticspellings).
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 Braidwood were received by Region III beginning March 9, 1985.
These allegations (RIII-85-A-0058; RIII-85-A-0062; RIII-85-A-00f).; g,qi RIII-85-A-0068) generally encompassed those identified above.
- Further, I
was the source of allegation RIII-85-A-0068 which concerns the p[EhT production quantity over inspection quality.
On March 29, 1985, the allegations were discussed among the Region III Staff (t. 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 infonned of the allegations.
It was decided that the allegations should be forwarded to Conrnonwealth Edison Company for resolution.
However, the allegers should be contacted before providing the information to Commonwealth 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 infonned 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 addition.al 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).
j INSPECTOR COMMENT I
(
lontinuallyviolatesproceduresduring
~
inspector'Te'rtifications.
~~
(
lthreatenedb.)for not closing an inspection por which still h d"T1 open engineering change notice.
refused and lstated, "if beating was legal
\\later checked with QA and found you would be dead."
.heTsue was proper.
that his position on supervisor) told
_ l lead andf
{
[I ils job iMe did not hurry up and Fo[that he would lose duce more inspections.
O.
Charles E. Norelius 3
APR 5 885
[Vos]ing an inspection report even though the engineering threatened an inspector (unidentified) for not change notice had not been issued for it.
"Comstock wants us to work with blinders on."
{
"More than a 'little bit of intimidation by more' than one supervisor."
~
D old him to finish an
~
{
On November 5,1984, t
inspection even thoug drat.ing errors were noted. (
I complained to Comstock management about this issue, Tut ~
did not rece,ive any satisfaction.
[ ] observed a se tal reduction pr.gplem in ctral weld.
toldhislead,L and
~
told Bowman to stay within the scope of Ms job worry abou,1 bay megl reductip. U also an n told informedL.. _ jto'E"eep up his production orle Wuld To[se his overtime. (See allegationRIII-85-A-0068)
{
7 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:
]provided information under allegation RIII-85-A-006
{-
Comstock emphasized inspection quantity first, not inspection quality.
{-
]
] berates inspectors. Many inspectors have een scriminated agairtst on ime or another by F
~ j.
attituie is "how can I hang
'you, not how can T he p you.
)iedtoget
{
]
Cons ntly inti datg by L
fired.
.sta d that hT has written statements Trom several w nesi'es to back-up his statement.
{ ]uses forms contrary to procedures.
For several months (/lwas the only welding inspector, and everything was done on a hurry-up basis. Comstock has consistently been undermanned and has one crisis after another.
i IAPR 5w Charles E. Nore11us 4
6l n eGhple, he recently visited the NRC office.
Dis constantly being watched by his supervision.
As 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, e and Hour Division, and requested that it be given to
}hould he desire to further this complaint).
(On April 1,1985, Daniel P. New, Area Director, U. 5. Department of Labor % age gnd Hour Division, was W
contacted and informed off finformation pertaining to alleged einployment 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.)
{
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.
'I 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.
l(phonetic spelling) is both an inspector and
[itor.ldit.{iwillinspectsomethingthendo
{
}
aud overview au
] believes this to be a conflict of l
interest.
f 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, Comonwealth 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.
l Conunonwealth Edison was told that the NRC had received general allegations fonn twenty-four Comstock inspectors and in general terms auggations concerned Comstock's push for inspection quantity not quality, perceived performance and the inspectors perception of the per ormancT"kf-TAGluality Maiman stated that Comonwealth Edison would begin to look First Program.
into the matters that afternoon and would recontact Region III with an action plan by the close of business on March 29, 1985.
l
~
Charles E. Norelius.
5 APR 6y At approximately 4:30 p.m., March 29, 1985, Comonwealth Edison officials telephoned Region III. Commonwealth 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 Commonwealth 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 business on March 29, 1985.
1.
Comonwealth Edison Management at Braidwood met with onsite Constock management officials in production, quality control and quality assurance.
Comonwealth Edison discussed areas identified by the Braidwood Quality First Program and the above identified allegations.
The Comstock officia_ls indicated they were generally aware of the concerns with perf'omance.
Commonwealth Edison emphasized the need for L. K. Comst'5ck Company to perfom within the Comonwealth Edison and Comstock quality assurance progr:ms.
Comonwealth Edison officials were not certain if L. K. Comstock site officials had informed Comstock corporate of the problems.
~
{ Tlegations are resolved.was' administratively removed from his superci 2.
D ie a 3.
Comonwealth Edison issued a memorandum to all L. K. Comstock QC/QA personnel in which Commonwealth 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 Assuranc*e Project Letter was also issued to reemphasize the Commonwealth Edison Project Quality Assurance Policies.
o '.
Charles E. Norelius 6
APR 5 885 At approximately 5:00 p.m., the Regional Administrator. Deputy Regional Administrator and the Director. Enforcement and Investigation Coordination.
Staff were infonned 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 k'arnick and Weil cc w/ enclosures:
RIII:RA0 i
RIII:DRS OI:RIII E. G. Greenman J. F. Streeter SRI-Braidwood
'1 l
jIl l'
,,,, Z ;E'ht 3
=-
s o
t w
(,
_g,gyI o
1 f
- s. 4 s=
f e
8 I
e Ww
/
M m p mP't.
I
't n n=
A t.
I t
$,, 1Me I
I e
0 g *y, tt i
I I
e.
ta a,.
r ;
i ee I
s rg M;l o-I 1
.v t
I N
l t e
Cc r
',a o
n I
x I
- c c
g 'e
_s e
s g
s
~
I R
i
/*
o:
",,'c s
i e e
(
i o-
>;ds s
I l
A e
O s p r y g. 2 I
o Y Mg e
g
't I
l g
I l
o
- s. ls
- _ A I
I p
I A E. g, n r f 9 I
w,, t I
I I
t
- x. y j, e e *_ r-
,. r, I I
t I
n r T I
I W/A E i
l r
t n
e o
e er p
&W *gf t
t a
n I
l p
I s
s t
,m l
9 i
t e
p-9 s
w jf zM-f i
l I
fj l
a
&_T t
W. wW i
l
,4<m I
c M
l I
,T fa
' gA
.e "a
,_ 9 J m L
c y
a.
T I
I I
S 1
R l
,, / d r.
I r
N suF U
I Z
yJ l
s f
e I
'a l
)
c
$ t G s j:srM c
r A
r I
's F
T M m.
I l
n v
I l
e v
N l
t o
f 2
,=o
, f R<
I t
t
- i. T o r 'a l
e t
l e
.r.
W'4 l
s
- r. f a
'y / g 7a
% f i
w I
s e
I u
o.
l r_ r I
" I' r j
A p1x:
t cr M. y g 1, g yw a
a v
L 2
1 I
.=
L x
1 gt r,t 1
I t
. c s
1 e
xf r I
N 1
?
s r
G 9*
f., y y cY e
. w e
A z I
e.
l y t e
. =
r )o y I "o%'
1 r
I S
Y mf-9 1
I e
+it n
,7 1
n e%m_An h.
l i
1 t
se w
a s
. e "4
1 h.
i w.
4 l
1 o
Q*
m A 1
e w
Y
'M 1
r e
I r
, m,_
n i
a e
u G C r.bi t
r t
i A.
.s e A 1
1-t e
1 p
r
- e 8
v d.
f a Z. w, I
s t
t n
a n
7 r
h A 7'- 1
/ r+
C 4
7 t
P e
'8
_ f6 2 n 'r A R e
1 e
I t
e I
W w-O I
1 r
, r. A :'
r t
J s
t
_yt 6
I E
c a
i C
1 C
s C
+
C a
t n r.
i I
1 1
i C /
IL vi I
t
, m
/
.I I
1 z
t t
P e
e S
r N!-
1 n
I r
ni s r v
i 5
F Y
w e2_ r f W t
r E
A o T t
o c.
o ;-
l a
o c
e 1 s_
I O
i a
R I
T I
A M l n.
eG %
u N
3 I
C i r y
VI A
t t
r.
4 s, "
l O
- i c
2' A
T, C H a.
r 9.
W*t.
s T.
OA m
I i
L I
F r.
n T
o f
t
(
t w
C I
A o
o
- t. 2+
e, C
A A o
. d,.
A t
I 9
- 7. j A,~u t
A e.
e A.
T I
0 s
1 t
, m, w
v w
d A
1 4S.
L t
Lz o ,,. n.
n.-2 e
s I
t
=
Qnr I
V u.
i e
e r o s
f w
r i
_ t,. 6tx c
v n
t 1
r s
- s E
s e
. " '.,', =
rc e K r
I 1
R e
f es a
o.",,,,-
r
'O
,e e
$r V e
1 v
l 1
e rr
- t. P a e
g a r9 a
,e o
'r t
1 t
n
$rN r
t 9
t a
e
?
6 i
1 r
t l_
.e 0
g h
u a.
I 1
r w
o i
8 d_.o y
e n.
y,, n
,g 7
1 s
T t
I
. s Aa r
A J t
1 t
e, 1
fv
.e
^ n 1
,v 4
_hI a
w
.i W~
2 "t
ee 0
=
s 1
r 9
r
=
t.
w A h+ A r-s Jee t
m'e l
e t
t t
1 e
dm
.s
/
I l
1
- r. -
_n
/
. e m., _
t a
MS Ns A 9 9 D
.T
- e e_ y,. C
_S.
1a w
l l
s o
1 t
e O
r
,r t
s I
l U. e.
2 c s
I l
I
. ~
r c
I l
I Oa v
a An *FM f_
n.
w -
t i
t l
t 4.ASurNm u r g
x n
c s
e r i
Cu n e
e t.
I s
n/h y' e
l T
i e
=
e o
a c.
r a,
1 l
a*
He%
.'a ma e
R I
l' s
4
's v
t e
n I
l e
2 o
- / o t
ee v
r s
y s
o.
e kD.
e.
.f r
a p
I l
n
,N1 b o :t 4
e v a
4 q
I vv t
s I
l e
G_!_
f a
i a e
f&
s wU a
l w v
.C I
a 7
u u
y
,1 n
e e,
o a.
.g i
,. T. ~ r.
I l
t Mov,$tSWm a
r r
i
- i e
wr>
I l
- C o
m a
r fW c e
9 i
e I
l e
- r c
l e g A
I_
m i
/y e
i l
i k
M mj o 9 g
g I
l e
v t
l i
t i
/_ < r T
1, P.
I r
.A n
M H mP e
1 I
l i
w r
e u
1 I
tep
.= O s
a
. Wco p A
I rer a
N r
- I e
=l 9
l
...'r 1
_ /.
e
- 6, g
l e
l l Y
- f r s mh i
o f_ s 4 t 2 v
Pr o
t a
f a
"o t
e., PM.
l i
.s - W1
-.f
.f o n )2' l N f t y
r 4
i
(
e,.
Snt
. E' y ;$ p ;1 ej u
0 e e 3
r s
M t
s 1
t E.h e?
a e
c,,N.wY1 n
t l
f C
i o
jW t Ci t
(
l a
T s
o l
(ar
,v,a.t - 4 sA I
w#
_ f_
s i
e 1
aa e.
t sy
,o e.
(t e
A.
t r
a t
l M
t a
e r s
[
8 S=
e.
sr ur a*m t
r o s.
t 1 o 0
tv s.
ont r
J
=
e l
8 ta
=
9 c.
n a
o c$v M
m$ s n
V e D fot t
r W
i C
a r
n t
a A
a.
e e.
e x
t s
t, ev e
- e. $Ne r e A 7
a a
8
. Y A t
S 1* w 6 3
f e
t e t e
?
e i
g s
j b 1
l g'
),
f.
c
!@ bjL g
.