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IM ejtj ip January 2,1984
- d i
c3nl Mr. Mark Padovan Resident, U S N R C j
[d[)
l P. O. Box 369
!I,j Avila Beach, CA 93424
@fq
Dear Mr. Padovan:
19 id; This letter is the information we discussed in my Dec. 23 C
phone conversation with you.
I was a quality control inspector for
%j Pullman Power Products, Diablo Canyon from July 25 to Dec.15 of l';3 1983.
During this time I worked in the rupture restraint and piping De support programs performing visual, dimentional, and welding inspec-1 tions in unit I and unit 2 Dates mentioned in this report before Dec. are approximate
{
i because all paperwork including personal notes, inspection logs and i'
memos were confiscated by Pullman.
Information copies of the' doc-f uments that I needed to properly make this report were flatly denied j
Y{
by Pullman.
However, should you find that this report has no legal
- 6, standing without that data: could the N RC make those papers ava11-
' ".e '
able to me so that I may assemble a legal report?
\\ ;p, WJ; The allegations in this report have serious consequences.
?c.
The incidents are presented in a chronology to show how Pullman f!'
provided for evaluation of deviations presented by myself and others.
A (m d o M -Ltid a W M h ds / )
Q, i]i Sevt 20 { V4locAh'Y Av.sr/M$tjh acA;M.shht))) &f aprS}
k
(.,DD Homannp w D i.D'l
- 1. Deviation from the requirements of contract specification 8711.
ij
- 2. Failure to notify purchaser (PG&E) of past and present devi-Q
- ations, j
- 3. Failure to notify the Commission as required by 10 C F R 21.21 b)
".:i i
Addressed memo to Harold Karner, Pullman's Q A manager, re-
}fj garding PG&E's contract specification 8711, Sec.1, Para 7,10.1.
(, q The contract stated that all GTAW shall be performed with a power
~
- y supply equiped with 1) High frequency for arc initiation, 2) Rheostat
_l i
6~
for stepless control of current.
i ou 3
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Research indicated that in the 1977 revision of weld pro-
- lj cedures Pullman had failed to include this requirement in their updated Weld Procedure Specifications, WPS s.
Further, P G &E
-j g(Q approved of the Pullman changes to the weld procedures and in.
effect ceased to enforce PG&E's own procurement document.
%py In verbal discussion with Harold Karner I informed him j
that none of Pullman's GTAW machines could presently meet the specifications of 8711.
Harolds reply was " if PG&E doesn't en-Fd force the contract Pullman doesn't' intend to."
I then informed Har-
@N old that in lieu of the high frequency the welders were scratch starting each time the are had to be initiated thus contaminating g
I also told him of the defects I was q
seeing as a result of no current control devices and no off/on J.)
switch on the power supplies Pullman was using.
The defects
..)
occur at the end of the weld cycle when the welder tries to ex-Qi tinguish the arc by pulling the tungsten electrode directly out of Zi the area over the weld pool.
The weld pool is kept molten as M
the arc elongates but then starts to freeze as the are and mag-Af netic field collapse, oscillating the still liquid pool, and creating llf:s a hole at the center point of the weld pool.
f PG &E's contract writers were aware of these types of de-fd fects typical to GTAW when they wrote 8711 specifying the type y
of equipment to be used.
Certainly a higher level of quality is 1
obtained when using the proper equipment and if this higher level
.4 of quality was thought to be obtained when documents such as the J.y FSAR were written: then a problem has occured.
3 No reply to my memo has been recorded as of my termination date 12/15/83.
?A Sept 22 behl)IY m,x$
- 1. Failure to impliment the quality assurance program as spec-p.)[;
ified in 10 C F R 50, a p p e n dix B, criteria II & X.
e "M
A welder was going to start welding when I asked him to at-ly,j tach an argon flow meter near the torch in his GTAW process.
The
.g welder refused to cooperate saying that as long as there wasn't a H
holdpoint on the process sheet for it the inspector didn't have to d
check it.
The welder's foreman and my QC supervisor were called Q
in to mediate.
The QC supervisor, Merle Edgerton, said he thought y{
my inspection was a bit excessive.
I reminded Merle that a 20 CFH fl fl?." rate was specified by the WPS and that if I'was not allowed to Q
check it, when I thought it necessary, then he could 'get someone
/4 else to do the job.
- r M
I was requested to perfonn inspections elsewhere and left..
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- 1. Failure to issue and maintain adequate document control jy as ' required in 10 C F R 5 0, appendix B, criteria VI.
M jsi I requested a copy of Pullman's welding procedures at
'j least five times from my superiors Gary Sawer, Jim Cunningham, a
Russ Nole, Pat Watson, and Harold Karner.
Mr. ' Karner's response i
h was that too many copies of the weld procedures had already been Sy]1 issued and that the' logistics of controling them had become un-j W-mana gable, j
(f4
)
- I Y I * !'
(LcNLSO Oct. 4 y
- 1. Failure to provide adaquate control over inspection and pro-
@d cess monituring as required in 10 C F R 50, appendix B, T
criteria X.
I i
a-i
$O I was requested to inspect a full penetration weld attaching f
a stanchion to a pipe. Upon arriving I found the craft had welded
]l i
the cover plate on the free end of the stanchion.
I didn't accept the work because I was not given an opportunity to evaluate the j
(;,,(
profile of the back side of the weld.
QC supervisor, Russ Nolle, q
W!
instructed me to accept the work.
I protested that the cover should
)
be removed by breaking the tack welds and the back side of the C.]
weld inspected. Russ would not permit the cover to be removed
'/ T, saying that the visual inspector had limitations that sometimes did 3
]
not allow the inspector to view the back side of full penetration M
2 Started to notice that the welding machines were not cal-ibrated on a regular basis and that tong type portable amp meters
)
6i were not issued and were rarely seen in the field.
- 2]
Oct 6 (
St M
- 1. Over-extention of weld proced to situation out ide scope of original qualification limits. Violation of 10 C FR 50, i
As appendix B, criteria IX.
bE I was a sked to inspect the fit-up of a threaded stud being
.Q welded to the containment liner.
After looking at the weld proced-r/j ure being used I determined that welding small diameter studs.was
~
dh',
not included in the ' scope of the procedure.
I called Harold Karner
^
-pj and pointed out that there was almost no similarity between the
,d,
-.i 3
s Q]
j
, pr.
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.I original procedure qualified on pipe and the present application.
k Harold assured me that the 7/8 procedure was qualified W-for the situation and that they had welded thousands of the studs.
Q[i,j :
using that procedure.
I replied to Harold that if. Pullman had in-tended' welding thousands of them perhaps a procedure should. have b
been qualified which specifically included the ' solutions to prob;'
@d s
lems unique to welded studs' It was decided that since' I had '
j such deep reservations about the procedure being used another in-P[j spector was asked to perform the inspection.
~
Iater, QC supervisor Russ Nolle came 'out to explain how ifj WPS 7/8 was used to ' weld studs...Russ told me that the backing
@}
strip could be ~ delete,d provided a' back grind was used.
I count-ered Russ' by pointing out that if.back grinding was intended then h
the procedure would have included direction as to what the re-y quirements of the back grind would be.
Q Further research on this subject has shown that the stud
?d material'most often being used by Pullman is a bolt material, A 307
~
(j; The _ stud is made by taking an A 307 bolt and cutting off the: head,
$1 then the bolt is cut with a chisel point and subsequently called a d
stud.
The problem is that A 307 is 'not a P1 material and can not be used in the present Pullman welding procedure 7/8. (See attach-qt ments 1' & 2 for information copy of part of WPS ' 7/8.)-
Further, bolting material A 307 'was never intended as a fi welded stud because the only chemical limitations on the product are phosphorus and sulfur contents.
Iastly, the material can'not:
0 be traced _because individual heats of steel are not identified in-p3 the finished product. (See attachments 3,4, &5) m Oct. 10
(_ (i k-f N
- 1. Work performed without instructions-, procedures,. or draw-T!;j ing control in violation of 10 CF R 50, appendex B, cri-6 terias V & VI.
{G..] -
-g I had noted that in the rupture restraint work in unit two -
4 fillet welds. originally performed by ~American Bridge had enchroached; d
on the' areas around bolt holes' that resulted 'in many bolts not-24 seating properly.
As a solution the fillet; welds were ground 'back; 1
lIs However, I asked the RR engineer _ if' measures were being taken E!
to revise the ' weld sizes in the area of the bolts on the. weld
[
sheets'. _ RR engineer, Dale Warren, replied!that to.his. knowledge 1
the drawingsLwere not being revised..
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[.,kt.Y Oct 12 hc
- 8) I i
M; (nue+ W m )
~:
- 1. Fallure to update procedures to current criteria as required'..
i h[$
appendix B, criteria VI.
in procurement document 8833-XR, violation of 10 CFR 50, t
[
Upon rejection' of out of tolerance washers to criteria set 6
forth in ESD 243. pertaining to hardened' steel washers, ' Dale. Warren, N
the unit two 'RR engineer found.that the information presented;in. the M
ESD was out of date.
I relayed the information to Harold Karner, 1
the QA manager, who then failed, to notify other inspectors that:
j the ESD was out of date and that new criteria was in.effect.- As-
~
of Dec.15 ESD 243 h'ad still not been revised and the other in-
{
h spectors still did not know of the new criteria.
6
-- O ct, 17 ( Q '
N
E
'l f,[
/
Kf g
- 1. Failure to provide for inspector evaluation:of defects 'found
?A in items verses the requirments of the procurement documents, q
l'
- 2. Misdirection to inspector by QC supervisor, denial to procure--
]
p.j,
ment documents, and itimidation for perfonning inspection' j
3 activities as described in 10 C F R; 50, appendix B, criteria 'I.
'l
- wgj I had found defects in A-490 bolts sent to the' field for in-
?W stalation in Rupture Restraint. work being performed: in unit two'.
$lrj The bolts had forging laps ;visable on the head and I: had occasion-1 ally seen longitudnal quench cracks on the shaft.
I consulted the y
procedures,.ESD 243, and found that the ESD: had no rejection cri-yy teria for the bolts.
Q I rejected the bolts and then proceeded' to search for the pro-
~
- fj curements, referenced in the ESD to find -the' proper _ status of-the.
pi items in question. While making copies of an ASTM _ standard in M
the office Russ Nolle' asked me_'outside for a discussion. ' Rus's
[
said that I would no longer be allowed to look at or makeL copies -
d; the AISC Construction Manual, the ANSI or ASTM Standards, y
of:
or the ASME Codes.
By seeking informatfon,in' those documents :
you are beyond' your scope as an' inspector, "you have your ESDs."'
- h I replied that ESD' 243.did not address inspection criteria i
(d[jI'
?*
for A-490 bolts.
Russ said to me l"any conditions found outside i
of the scope of the ESDs shall be accepted." I told Russ that I.
would not be.able to abideL by that and if the. ESDs did not cover -
q],
the ' situation, then, I would-seek inspection' criteria elsewhere.?
Russ got pissed and said that 'he and Harold Karner have "had..it
~
'e up to here," pointing to his neck.
"You _ got _ one foot out the door, if Mr. Iockert, one more wrong move and you're gone."
9i M
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4,:4 id
%g4 C e f. M i m.) h M " M " -$ 4 fA Oct 20 ht i
- p h<
1 Deviation from the technical requirements included in the M
procurement documents 8833-XR and AWS Dl.0-69..
((
- 2. Failure of both-PG&E and Pullman to regularly review the status and adequacy of the QA program in violation of h
10 C F R 50, appendix B, criteria II.
Mgj I had reviewed Pullman's ESD 202,. Welding Electrode Con-W*
trol,. verses my _own copy of AWS DI.1-83, Structural -Welding Code.
In the area of storage of low-hydrogen electrodes I had found a yM discrepency in that Pullman's requirements were below those speci-fled in the code.
I sent a memo to Frank Lyautey, ' assistant-QA ' manager, tel-
@[i -
ling him what I had found and asking him to check his copy of fj AWS DI.0-69, the document referenced in 8833-XR, to see if we nG really had a problem.
Pullman's ESD. stated that the minimum re-M quired storage temperature for low-hydrogen electrodes was' 225* F fj while I had noticed that AWS required 250* F.
qj Some time later I was contacted by Frank and informed that Q
I was correct in'that.the 69 version of the code also required the y
higher temperature.
Frank went on to assure me -that~ he had per-ri '
sonaly. checked the logs and that no violations had' occured and
.j that he was issuing a memo immediately. to notify all-'other con-y]i
..J cerned parties, 24 hc h M h U Oct.
/
fjg
- 1. Over-extension of welding procedures outside the ' scope of bj original qualification limits.
Misuse of prequalified pro-h.y@l cedures per AWS in violation of 10 CFR 50,appe'ndix B,
jy crit eria IX.
m k,)
I examined the procedure qualification requirements of AWS '
Qi D1.I and compared them to Pullman's Rupture Restraint welding pro-A gram. It appeared to me that Pullman had; taken a WPS qualified 4
M under. the ASME Sec. IX criteria and transfered the qualification to-the 'AWS criteria. To my knowledge this is 'permiss ible in that the g%
mechanical requirements of the PQR (tension and bend tests)lare transferable to both codes.
J.a However, one of the main points in the;applicationLof the -
9 WPS to field welding is that joint design is an essential variable -
@Ly1 in' the AWS D1.1 code while.in ASME it is not.
I started to look at the process sheets. coming lout 'to the field:and noticed that o..
/8 6
J' A
SY
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~,m: mgrTy m p
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7 Pullman-was welding a variety of seven different joint designs _and (v
calling it all out as one WPS 7/8 i' i+
A closer examination of' Pullman's RR welding program re -
.j
-1 vealed that they were working with two documents: WPS 7/8 and
.j a Welding Technique Specification' called AWS 1.1 ( see attachments -
$j 6 thru 11, and 12 thru 14.). The welding procedure 7/8 when. applied to AWS welding only qualifies the original joint design used in the l't PQR because joint design is an ' essential variable.
The. Welding 1 N
Technique Specification. AWS 1.1 has been used as some kind of.
. prequalified procedure: not-able to stand on -its own. but in. some -
,h way attached.to WPS 7/8 A clo'se look at AWS.I.1 will show how the nature of this document changes:
4M
)
D
- 1. The title of the document says.' Welding Technique Speci-
. fication" but notice that it.also called a1 WPS on' pages 2
'& 3 (upper right corner).
53
- 2. Note that the supporting PQRs are prequalified., Why,
would a technique ' specification require any qualification record? A. technique specification has 'no legal bearing -
S I.
>A under any code but a ~ WPS-surely would.
e9
- 3. The permissible base metals listed include A-515 and g
A-588.
The former is not listed under the: steel specifi-
- M Qi cation requirements of AWS D1.1, Table 4.1.1 and.the latter -
requires special welding procedures for-impact loading or i%
weathering applications (see note 6-of TableL4.1.1.)'-
Qg]
In order for Pullman to use prequalified ' joint de' signs for M
its use in rupture restraints: all mandatory code requirmentsImust.
di be met as shown in AWS.Dl.1,. Table El.: notl to mention' the least y?
of which is a written _WPS. Pullman can not use~ prequalified joint 3,
i designs because " Welding Technique Specification AWS 1.1" is' not-a WPS nor does WPS 7/8 extend.into the realm of prequalified i
a;g.
procedures because it does not incorporate all aspects.of DI.1-d either.
My first coinments on the apparent discrepency were with -
Q@.
Russ Nolle.
Russ said not to get excited because-someone had:
1 already caught it in an audit. (Could Russ be refering.to audit # 35 i
6" performed by Harold. Hudson back in March of 83 7)
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Oct. 25
(((
't%L4 d
y[:
kbg tion of its own procurement documents.
' fi :
- 2. Failure to notify the Commission of deviation from procure-
- h.
ment document 8711, violation of'10. CF R 21.21.-
q$
%Il I was still. concerned that work was being perfonned out-
]
side 'the scope of 8711, PG&E's' contract with Pullman for-piping
_j
@f f
and pipe supports.
Recently, I had heard of 200 l welds in. sched-ule 10 stainless steel pipe that had_ failed to meet radiographic -
standards.- I researched the problem by asking the reader of the.
/$
radiographs, Pu11 mans Level III NDT Mike Mckray,..what types of defects he was seeing.
Mike told me that many of. the defects i
kh appeared to be -grouped either at the start or end of. weld passes
$33 and that because of the thickness-of the pipe defects"(porosity:
Wh mostly) larger than the head of a~ pin had to be rejected..
{
Thinking that the lack of dated:GTAW equipment might be'
.i
!g contributing to the problem I called PG&E's NPO -Welding Engineer y,ji Dave Stupi.
Dave-had asked for several days to research:the; pp 8711 contract himself so that this was my second contact with him.
Ni Dave' told me that 8711.was a very old document written at leasts
.d ten years ago and that,I had probebly stumbled' on an old. copy-j IIg that had never been updated.
Dave refered,me to another PG&E.
Mj engineer and said I was not to include him in-any more ' discus-g sions on the matter.
..4 j
+,
h (L
M Nov 2
$i I
'd Presented Harold Karner, ' Pullman. QA Manager, written noti-L gii fication of my finding with regards to rupture restraint welding L
'I Af with the WPS 7/8 & AWS 1.1 combination.
- .:Q e
g%%].
Nov. 8 ( 3 /cRS.)
g q.4
- 1. Failure to recognize a significant. condition adverse to qual-'-
gj ity,. failure to take corrective' action,- violation of 10J C F R 50, Q
appendix B, criteria XVI.
.;D
%[
. I performed an inspection. directly underneath the unit two' -
pressurizer;in which I ' observed old ; work that would;be absolutely'_
gy
.i 3;{f unacceptable' under 'any code.
Welds were on Rupture. Restraints '
8' 4
py m
f s
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twow p g u g g yppu}y2i?vf e.wne qp.suu9" f - T,N d'.f
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- t-L LtLL N
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~
g<f originally built by another contractor, American. Bridge, with the manual SAW or, possibly, FCAW process.
I brought my concerns
.j N(.$
nothing can be. done about it be. M to Russ Nolle but he said no'
/
~
1 g,at se it was another contr9ctor a d 'already acce t
. #Rj@
44t5 M QJ4 h44 M. 4 -N 90
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- Nov. 16
(
h4 a
f{eh
- 1. Failure to take corrective action to preclude repetition of.
},
significant condition adverse.to quality in violation of Aa 10 C F R 50, appendix B, criteria XVI.
h~
2 Failure to provide evaluation'in a' timely manner and co--
ercion to perform-inspections to procedures shown to rea-h sonably questionable, violation of:10 C F R 50,; appendix B, criteria II.
j 5.;j Two weeks before I had informed Harold Karner_ the prob-
$11 lems I was having justifying the welding being performed on.rup-4 ture restraints.
Now I was being ' asked to inspect again.to pro-O@d i cedures I had shown were questionable.-
q f
I told my leadman, Jim Cunningham,1what I. had found and:
l that I had not' rec eived 'a proper response - from Mr. Karner.
.Un-
.i d
till I get one I don't feel I should go inspect.- Jim told ' Russ' Nolle Q
and Russ acompanied me to Harold's office..
N I explained to Harold.my situation.
Harold said I: was en-9 titled to my opinion but that PG&E had already approved the,, pre-4 sent procedures.
Further, he said I had a'choise: I could go :out 3
and inspect or I could look for a new' job..I informed Harold' that E.d I had done everything in my ' power to get a qualityoproblem cor-rected and that if he was going to threaten me with my job then
,j I had no real choise but to go and inspect.
M Dec. 8 ( /Z1'Ykbbd5 &&
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.d Temporarily assigned to the area 10. fab shop. - The area 10.
L ff fab shop also houses the welder. qualification test' bay so that I h
had.the opportunity to witness some' of the' welders as they per--
^
51 formed their tests.
After some questionsL Ihad directed at the _
li Vd the welders,I noticed that there were perhaps-six'or. seven welders
[iff proceding' through the activities of the test with no QC ~ interaction'.
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later on, in the afternoon, 'after observing more testing with no QC participation I walked into the small office area and struck up a conversation with'.the production foreman, Art Savacou.
[
I asked Art where the QC inspector was at.. Art replied th,ey.
D. b didn't have one at the moment but that he and Pat Watson had (d
&n understanding." I thought that was pretty _ interesting'so I~ asked Art if he was qualified as an inspector.
Art replied no.
W+3 3
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Dec. 9 (M j'
MN
- 1. Failure to provide for assurance that all. prerequisites-for-N6i 4y testing have been met, violation of 10 C FR 50, appendix-b B, criteria XI.
kSl M
I learned this morning that the QC normally assigned to NM the welder qualification tests had quit on Dec. 7;at.09:00. - Af-M ter further observance of tests being performed with no QC inter-M action, I checked the requirements of Pullman's Quality Assurance O
Manual and reviewed the statements in ASME,Sec III.
M Wrote memo to Pat Watson, the area 10 leadman/ welding i
qualification supervisor,. noting that Bill Bailey was gone and that -
[.%s I' had observed an apparent lack of QC ' participation in-the testing.
A I reminded Pat that the QA' Manual's -paragraph KFP 15.2 - specifically N
stated.that a field inspector shall be assigned to the test ~ shop and that ASME, Sec III, paragraph NA 3764.i d would not allow aL
";g
- production foreman to determine the quality of production welders, g
When Pat came on his walk'through the ' fab-shop'I~ handed-t.
him the-memo'.
Pat after reading: the Tmemo would: not accept -it
!jj and walked off.
Sometime later Pat returned. and finally; accepted gli the memo.
' At approximately 14:00, Frank I.yautey 'and Chris' Neary ap-t.]
peared and wanted to know.what was going. on. Frankiis the as-I sistant QA manager and 'Chris. is Pullman's welding engineer from i
^lfj Williamsport, PA.
I related the story and told Frank.that I had y!T n'otified the proper person in'the chain of command about the ap-
[yj parent discrepency.
Frank explained that Bill Ba'iley had quit and that a new inspectg was scheduled to start in the' welder R
qualifications on the 12 In - the absence 'of either inspector, 3
Pat Watson was perfonning duties as fieldLinspector in the test
$)
shop.
N:
I admitted to Frank that I had seen Pat Watson 'in 'the test. bay twice on Thursday, the 8th, but that for the majority d
of the time I had noted no QC. at all.
Frank assured'me there
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- O8 was' no problem and then Pat Watson joined us and he assured' me:
the inspections had been performed.
I asked Pat what his inten-it sions were regarding the welders I had seen qualifying with _no
~
N QC-around.
Pat said he had no requalification tests in mind.be-M cause there was no quality' problem.
Frank then asked me to s
join Chris Neary,and add any comments I had to Chris' revision -
I of Pullman's rupture restraint welding.
.My discussion with Chris' covered his'intensions to:
3,:
- 1. Restrict application of WPS 7/8 to the original' joint
?
design shown in-the PQR..
(Note:that there is no joint-i -
shown in the' PQR' but only a reference to sheet 2 of 10. ?)
ff{)ll 2.Use of prequalified procedures for all other applications.
o
]@
After examination of Chris' notes I brought up the point that b:1 he intended to use the same eight 'or' nine prequalified joint designs
)
M they had been using before but that he was still grouping them all.
under one procedure number, AWS 1.1.
'I said this' could be con-1g fusing and that it did not appear to satisfy.the requirement of a 3
written procedure for each procedure.
For instance, how can a h.y single bevel corner joint have the same written procedure:and num-Va ber as a; double V butt weld that requires back grinding and welder 6
access from both sides?
pj I reminded Chris that under AWS joint design 'is' considered
!9 an essential variable. Chris did not see that this was a problem.
n,.
Dec. 12
$N ro d@i I reviewed the events leading up to the confrontation' on the U
th 9
and determined that there'still existed some doubt as to' wether J
i.%
the qualification tests had been performed properly.- Frank Lyautey and Pat Watson had personally assured' me that there was..'no prob-fj) lem, yet, they had not willingly showed me ~ evidence' of the in-gj spection records.
In my own mind several questions remained-to
]
j;1 be answered:
Q
- l. Why had I observed the qualification tests. being per-g formed with no QC including Pat Watson present?
/g.
d 2.Why. did Art Savacou the production ' foreman who had ap-N peared to, be running the show refer to an " understanding" A. 4 with. Pat Watson.
+
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- 3. Did Harold Karner know of. the problems I had witnessed 93 '
in the test shop.
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I refered to the QA Manual and found instructions :that 4] ~
said the QA manager was to be. informed of problems affecting.-
quality.
I initiated DCN. 1/1640-021 that told of what I had ob :
~~--
served and that it appeared Pullman was performing work outside d
the scope of. its own QA Manual-The Deficient Condition Notice required an: engineers signature to be submitted so I ' asked Mike,.
M the area 10 engineer, to cosign the DCN.
N Mike declined to sign the DCN-because it 'showed no hard evidence of a hold point being' passed.
Mike did - say, how-ever, that if:1 did provide evidence then he would sign the DCN.
h Dec.13 ( dA j
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- 1. Failure to provide inspector access to records showing:
ft 44 that a function pertaining to quality was adequately per-
{]
formed,in violation of 10 CF R 5 0, a p p' e n d i x - B, _ cri-Z teria I.
hy After informing RR engineer ' Dale Warren that I would not Q
accept their previous performance of a stich' weld observed: on y
the construction 'of. square beams, I decided.that I would inspect-3 the records of the test shop during the time of Bill' Bailey's: ab-I.1 sence.
[(j I went to the test bay and: explained to Art Savacou_ that :
dj I had reason to doubt that the welder qualification test'surviel '
D lance inspections 1.e. materials; process,: position, fitup, root-3.i pass, WPS parameter verification, final visual, bend tests had; 3
been performed.
h Art refused me access to the records'saying that only his bJ direct supervision could look at the records.
I. informed Art that gj by doing so he was denying a QC inspector the right to inspect W.;
recortis.
Art's reply was "what are they going to do put me in jail? "
n.
7, fs, I left the test bay and contacted Pat Watson asking to
)
see his_ records for Dec. 7,8,&9 concerning welder qualifications.
After some discussion Pat showed me what he!had, the ' records' M
showed a summary of the welders who had qualified, who. passed?
who failed.
I told Pat that this was just _e. summary and tha't the 7jl records did not show wether the required inspections had been.
l
-d performed.
Upon leaving, I reminded Pat that I was' still waiting
);,9 for a written response to the memo.
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.I Dec 14 (
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- 1. Failure to notify authorized personnel of changes in Quality
$j Assurance Program in violation of 10 CF R 50, appendix B, criteria VI.
dild
.]
For the events of the morning supposedly causing my termi-41 nation see Pullman's Termination Notice to Payroll Dept., pages I
.' 3 -
and 2 and my grievance addressed to Mr. Stieger, pages 1-5. (At-
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-)]
tachments 15 through 21) l n
In the afternoon after checking a portable rod oven that had yielded repeated violations of the minimum temperature allowable 1
for low hydrogen electrode storage, I asked the welder to get a-hy nother rod can because this one appeared defective.
The QA rod
?a room attendent came over after checking the can and asked what h,
the problem was.
I replied that it was below the 250 F min. re-kj quired by AWS DI.1.
hp He said that the ESD only required 225 F.
I replied that ESD 202 had been changed back in October.
The QA rod room at-p; tendant didn't believe me because he had n't recieved a memo on
- L the subject. I showed him my copy of Dl.1 and he agreed that -
%i was what the code read but that he couldn't change the rod oven l
"j j temperatures until he recieved word from his supervisor.
- $A
Dec.15 (
ej See page four of grievance (attachment number 21.)
N e;j
'ud The events'I have presented have been shown to be in
/.y disregard of procurement documents, codes and standards, and 3
g.[,
Federal Regulations.
Of course, only the Commission has the
.d right to interpretation of the Federal Regulations but that does not mean that each person involved in the nuclear industry is M
denied their own inference.
M I have provided what documentation I could and I ask
$[)
that the.NRC provide me access to the records on site so that I may provide you with the necessary hanger and rupture restraint 3/
p(;)
numbers for your own investigation.
All events and conversations are true and accurate to the best 'of my knowledge.
<; c oud h
Respectfully, Y
.R r) yn
$p Steven Lockert 1
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$;;n; December 17, 1983 I
4 af,d Paul Stieger 1?j Project Manager yd Pullman Power Products O:4 Diablo Canyon Nuclear Power Plant-Avila Beach. CA 93424
?.3
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Subject:
Gnevance regarding the termination of Steven Lockert on 12 /15 / 8 3 filed through U. A. Iocal Union No. 403. Plum-
""Q bers-Steamfitters and Apprentices.
- e :
. s.
I@ft
Dear Mr. Stieger:
' 4; I was employed as a quality control inspector by Pullman Pow-er Products from July 25 to Dec. IS,1983.. During this period I J ',
had established myself as a reliable employee and a good inspec-M My performance as an inspector has been discussed on two tor.
s 2d occasions with Frank Lyautey.
On Nov. 7 and again on Dec.12, both times Mr. Lyautey agreed that my conduct as an inspector j ',
was deserving of a raise in pay.
t.;
q./
.My designated work area for several months has been unit two Z
containment.
However, on Dec. 8 and continuing to Dec.15 I
[@I%
was put on temporary assignment for the area 10 fab. shop. Each.
day I was told in the morning that area 10 would be 'my work place, but I was not informed as to how long this arrangment would last y
{
and I was not told that I would be the only one responsible for this area.
At 06:30 on Dec.14 I reported to work and found in my
@j mail:
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- 1) Two packages that required " steps to prevent reoccurance",
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STPR, training specifically addressed to me.
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- 2) An urgent request from Peggy Sharitz asking 'me to provide j' g -
explanations for the missing DCNs from her log.
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- 3) Two final A/B inspection packages from unit two being re-e q
turned to me for further action..
. '#G* /
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Additionally, there were four more. STPR training packages being
]
1 distributed by Jim Cunningham, my leadman, to all members of
,.j; his crew.
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Attach. 17
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page.2 of 5
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$M From 06:30 to 06:50 I looked over_ the STPR training packages 6
in the QC office.
During this time Jim Cunningham told me ihat MN I would again be assigned to the-area 10 fab shop.
I respondid
~
M to Jim that.1 had questions about one of the STPR packages ad-dressed to me and that I would like to look at the item being questioned. Also, I said some other unit two paperwork had piled
@N.
up and I would like the opportunity to catch up.. Jim replied' to.
(N.
me that this would be acceptable to him 'provided that I cover area 10 ASAP.
?W y
y$[t,]
At 07:00 I reported to my unit two work station and ' requested 3
from QC inspector Mike Hinze my DCN log.
Between 07:00 'and h]2 09:10 I determined what steps would be necessary to complete the paperwork and did the following:
q f1 A) Reinspected the item being questioned in the STPR. training
@d package.
'.:7 y B) Assembled the appropriate DCNs requested by Peggy Sharwitz.
lig
[,.s C) Attached an accept tag and completed the documentation re-
?{
quired for one of the final A/B packages.
fj 3
D) Requested Field F.ngineer JerTy Arnold to sign two DCNs I d.1 had initiated the week before.
Jerry said that he would have, to
$,1 inspect them first and after his inspection ~ said that he would have
.-ci to talk with his leadman, Paul Hemmingway.
3-To11owing the discussion with Jerry, Paul, and myself I re '
j ported back to the QC office at 09:20 and distributed the complet-M ed paperwork.
Supervisor Jeff Charboneau reprimanded' me for be-G ing out of my work area and asked me what;I had been doing.
I Q
replied that I had gotten the DCNs requested by. Peggy and_ com-
,h -
plated other unit two' paper work that had fallen behind.
Jeff did not ask 'any further questions but did-proceed to tell me my pri-
+
} l,j mary function was to cover the craft.
My-final comment was to
$9 say that I was sorry for the' situation and then I promptly left to
$y cover area 10.
wy.:
j,g The following day, Dec. IS, I was notified that I had been W
terminated.
Harold Karner informed me.that my dismissal was not -
7,j up for c" cussion and that I was to remove my. personal belongings.
9 y;,
and myseu from the job site, k'. $
h";
1 Attach. 18 1.
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page 3 of 5'
~
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.The morning of Dec.14 has been accounted for and my a~c-
']
71 tions can be traced through the papers and peoples mentioned.
i N
-The allegations presented in the termination notice given to me on
@M$
Dec.15 and the refusal of the Pullman QC supervisors and Isad-man to hear my side of the story demand that I file'this grievance.
A i
((1 -
I had informed Jim Cunningham~ where I would be and what my -
/
intentions would be. Jim told Russ Nelle what my intentions were 1
but, according to the events presented on page one of the termin-j ation notice, Russ did not pass that information to Pat Watson.
d;/3i Why did Pat Watson decide to hold up the craft waiting for a temporary inspector when three permanent inspectors already in yi area 10 could have perfonned the necassary inspections ?
M$
Page two of my termination notice states that I was out -of my area and, further, that I was pursuing a wild goose.
My ' lead-
/k.)
man, Jim, has included a statement with his signature.
Appar-d;]
ently, Jim doesn't agree with the statements made on page two.
G]j g.
I ask that as part of my grievance hearing that Joe Watson and Jeff Charboneau be present to-elaborate on the goose I was ~ sup-J pcsedly chesing.
Sfj3 I have presented the side of the story that was denied a hear-A ing at the time of my termination. The grievance may be handled k!!l with just the information mentioned above or some additional back-ground incidents that I feel have a definite bearing on my tennin-
!.id ation on Dec.15 may be consulted.
The incidents; presented in
@.ij the attachment to this letter are confrontations.with Pullman QC l
- g supervison personnel.
The confrontations' occured when I had de '
y?j
'termined that Pullman was perfonning work outside the boundaries j
Q of codes, contracts, and standards.
I chose to: work withir. the 1
- L system and' notified my supervisors of the problems I had discov-
/j ered. the paragraph numbers of the document I was referencing, i
FA and asked that I~be ' notified as to what their solution would be.
M I leave it to the reader to decide wether the confrentations lead-
!#1 ing up to the Dec.14 incidents had ' bearing' in my dismissal.-
1 p,a -
y bk!
G Jg Respectfully, p1 Steven Icekert
,m 3
Attach. 19
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,page 4"of 3 i
Q~1 A tra chment to grievence showing the chronology of events f
leading up to the Dec.15 termination'.
Dates shown before Dec.
are approximate.
Y
- l'
(%
Dec. 15 At 06:30 I left a note with Frank Lyautey informing f,%.
him of engineering's solution to a pacblem we had discussed con-M carning the wrong application of an intermittent weld symbol to fd the construction of a beam for rupture restraints. Although the 5
solution was an improvement over what had previously been done, the weld symbol still did not reflect the as-built condition.
up At 10:20 I called Frank asking if the solution engi-h neering had intended using was acceptable to him.
He said. no M
but that we would have' to get them to change the ~ symbol later.
I then informed Frank that the area 10 fab shop was still unaware 4
of the requirement per AWS of a 250 F minimum temperature for jM welding electrode storage.. I had pointed out to Frank in late i
cct. that ESD 202 was out of code with AWS.
Frank had sent ~
lQ.y a memo to me showing the revision to ESD 202,- assured me that-M he had checked the past logs and there had been no violaticas, W@"
told me that the revision was out for general distribution.
At 12:00 I was notified of my tennination with. Pullman.
7:.$
Dec. 13
_ At 15:00 I requested from the test shop foreman, Art, Yj access to the field QC inspectors records from the week before.
I had doubts about the fitup, rootpass, final. visual, bend test g
location, and welder surveillance inspections supposedly performed N
on Dec. 7,8,9.
Art refused to allow me access to the records.
!Q saying that only his direct supervision could look at the records..
EI I told Art that by doing so he would be ~ denying a QC inspector-
%j the right to inspect records. Art's reply was "What - are. they go-QJ ing to do-put mein jail?"
M At 15:30 I requested from the area 10 leadman, Pat Wat-W4 son, his records concerning' the inspections of Dec. 7,8,9.
Af-
[%
ter some discussion Pat' reluctantly showed me what he-had.
The t;,
records were a summary of the welders who had' qualified, show-
),d ing who passed, who failed.. I told Pat that this was' just a : sum--
?]
mary and that the reconi did not show wether the inspections re-M quired for qualification had been ' performed.
I 'also told ' Pat that -
r ; ",
I was still waiting for the reply to the memo I had given him on 3
Dec. 9.
O y
Dec. 12 After consideration of the incidents observed in the -
[M test shop en Dec, 8,9, I was still unaware of the CC manager's:
knowledge in the matter.
I initiated DCN 1/1640-021 that told of pq 0
M Attach. 20 '
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the apparent lack of QC participation in the welder qualification 4
process.
The area 10 field engineer, Mike, after reading the' DCN FSI did not want to sign it because I did not have any documentation
~
f' showing that hold points had been passed.
sm Dec. 9
-After observation of no QC field inspector again this.
h:
morning, for most of Dec. 8, and hearing that Bill Bailey, the former QC inspector for the test shop area, had quit at 09:00 on
%j
$p Dec. 7: I decided that perhaps I should write a memo to Pat re-M minding _ him of the regyirements of the QA Manual's KTP-15 stat-
]
fjId ing that a QC field inspector shall be assigned to the test shop.
pj I also included a reference from Sec. III, ASME stating that pro-g g:)i duction personnel could not oversee the quality of production.
- $j Dec. 8 I observed very little QC participation in the welder qualification tests being performed in the test shop. In the after-
)
sj noon I went to talk to the production foreman who was apparently running the shop.
I asked where the QC inspector was.
Art re-78j plied'that they did not have one at the moment but that he and O
Pat We'tson had "an understanding."
I asked Art if he was qual-i,J ified as a QC inspector. Art replied no. -
]
- 7, l
n Ap Nov. 16 I was asked to inspect the welding for rupture restraints j
after being on hangers for about a month.
1 had previously sent ry a written notice to Harold Kamer informing him that I felt the pre-
~
sent welding procedures for rupture restraints were in' my opinion 9
unqualified.
It had been several weeks and I had not had a reply
.9 from Harold.
I refused to perform inspections to procedures that i
I pointed out were unqualified.
Russ Nolle sent me to talk to pSt Harold, Harold said I was entitled to my opinion but. that if I did -
j$
not go out and inspect that I no longer had a job' I said that I had done everything in my power to get the ' procedures' changed y
and that I felt the procedures were unqualified. However,.if you.
l W
insist that the procedures' are qualified and threaten me with my
)1 job:. I have no choice but to go inspect. (Note that' as of Dec 9 all current rupture restraint welding procedures are being revised)
+
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