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Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities
	ML20023D035
Person / Time
Site:	Clinton, Midland, LaSalle, 05000000
Issue date:	07/26/1982
From:	Arlette Howard; AFFILIATION NOT ASSIGNED
To:	;
Shared Package
ML20023A480	List: ML20023D030; ML20023D031; ML20023D032; ML20023D033; ML20023D034; ML20023D035; ML20023D036; ML20023D038; ML20023D039; ML20023D042; ML20023D046; ML20023D055; ML20023D066; ML20023D138; ML20023D140; ML20023D145; ML20023D146; ML20023D147; ML20023D172; ML20023D181; ML20023D188; ML20023D191; ML20023D196; ML20023D209; ML20023D213; ML20023D214;
References
	FOIA-82-366 NUDOCS 8305190108
	Download: ML20023D035 (55)
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{{#Wiki_filter:' AFFIDAVIT My name is Albert T. Howard, I am giving this statement to Ms. Billie Garde of the Government Accountability Project of the Institute for Policy studies. I make this statement freely, with no threats, inducements or promises of rewards having been made to me. I do this because I believe there has been a serious quality assurance breakdown at the Zack Company, my former employer. The nuclear power plants in Midland, Michigan and in LaSalle and Clinton, Illinois, are being constructed with equipment in the heating, ventilat-ing and air conditioning ("HVAC") areas that have been purchased through Zack as a sub-contractor. My statement covers events that I witnessed during my employment with the Zack Company as a Supervisor of Quality surance Documentation in its Chicago headquarters from October 19, 1981- through April 30, 1982. During this six and a half month pe'riod, I personally 'became aware, through evidence in documents, letters and discussions, of problems that had existed for years at the Zack Company.. It is the~ cumulative effect of the problems in quality 7 assurance documentation and the responso of corporate, utility and government officials to my disclosure of these problems, that made me realize public exposure was necessary to achieve substantial improvements. As a retired

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junior high school science teacher , a 'f'akher of,te',n children an.d 'a grand- . father, I feel an extraordinary commitment to challange unsafe nuclear power plants that could threaten our environment. It is intolerable to my values as a father, a citizen and sensitive individual to allow problems of , this magnitude to go unexposed. Since I have lost my job, I belieye as a result of trying to work within the system, I contacted a number of other . ' government and public interest organizations to help co-workers who were similarly dismissed to present the full and true picture of the Zack problems 8305190108 830311 PDR FOIA 4 PRENDER82-366 PDR . aw ___ t mm - - -':. =r. - =.;y**e- -erm-. +- , , w # + --+*i #4 e*- +*t**t+y-m***i

to interested and concerned agencies. ! i Prior to accepting the Zack position in Chicago, my family and I lived in Massachusetts. I retired from teaching junior high school science in the public schools in Shrewsbury, Massachusetts. My 25 years ,in education included 22 years as a classroom instrr.ctor and later as a teacher on Otis Air Force Base, Massachusetts, to the dependent children o'f Air Force personnel, 3 years as a principal, and other assorted assignments. My, employment record ~

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with the Mass.achusetts public schools igveals tue. highest reccamendations and community support. I was also involved as an officer in local teachers unions and participated in various leadership roles in the community. In addition, I had started mir'o'wn company s(Hems & Co.) in December, 1974, dealing with sales and services in the real estate field. That company is still viable today and the business is handled by my oldest daughter in Massachusetts. I have a Bachelor of Arts in Earth Sciences, and a Masters of Arts in Education / Administration from the University of Massachusetts at Bridgewater. . Finally, I have 45 hours of post-graduate work funded by a grant from the National Science Foundation. The hours in courses such as physics, chemistry, geology and ecology, were taken at the College of the Holy Cross, a Jesuit Catholic University in Worcester, Massachusetts. In addition to the above mentioned degrees, I have attended various college seminars and workshops'in generic education and science continuing education topics. (See Resume, Exhibit 1.) In September,1981, Mr. David Calkins, Quality Assurance Manager of the Zack Company and a personal friend of mine for over 10 years, contacted me by telephone. He was aware of my interest in a new career and also my intense backgrcund in science-related areas. He rec::uited me over the phone for the position of Quality Assurance Engineer / Documentation with the Zack Company l - .

in Cicero, Illinois. On or about September 30, 1981, I accepted.the job and arranged to move myself and my family to the Chicago area., Zack is a family-owned corporation, founded in the 1920's. It is now run by the original owner's daughter, Christine Zack DeZutel. Zack is a heating, ventillating and air conditioning (HVAC) subcontractor. In the early 1970s, Charlie Howard, then Vice-President and General Manager, helped Zack move into the nuclear power plant business.- They bid on and were contracted to do the HVAC work on three nucisar plants - Midland, LaSalle and' Clinton. I In order to meet the criteria of 10 CFR 50 Appendix B, Zack was to have established a Quality Assurance Department. (This "QA" function was to meet the requirements of Appendix B of 10 C.F.R. Part 50.) The General Contractor's own QA program also must meet the Nuclear Regulatory Commission's criteria. Zack . Company had a great deal of personnel turnover in QA managers, and in the last two years had several major departmental reorganizations. An individual who seemed to have played a major role in Quality Assurance is Carl Eichstaedt, the Vice-President in charge of operations.. He has had some QA responsibility with Zack for the past several years. , In the past two years, four people have had the responsibility of trying to straighten out or supervise QA: Ed Thompson and Michael D' Haem, who came

 ,        from Midland; David Calkins who came from a consulting firm in June,1981; and i

Martin Skates who occupied the position when Mr. Calkins was assigned to Midland. l The Quality Control manager was Harry Geyer until August, 1980, when he went to LaSalle to be QC manager. Then Charlie Richards took over the function l _ until-he was-demoted recently to QC inspector. G. Calkins previously had been employed with a contract consulting firm i in Maryland -- NUS. Prior to that time he worked with Westinghouse Corporation.

In June, 1981, he was hired by Christine Zack DeZutel as QA manager. According

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l to many detailed conversations that I have had with Mr. Calkins since September, 1981, that he realized the QA department he was hired to supervise was in a

, shambles. Mr. Calkins also told me that Zack he.d been plagued by problems like work stoppages, plant shutdowns and strikes.' He also' told me that soon after he began he discovered severe problems with material documentation. He mentioned i examples like missing, inaccurate or ' incomplete reco'rds and altered documentir.. Mr. Calkins had in fact investigated and reported the QA problems Zack was having to the Site Managers of the Midland, LaSalle and Clinton plants. 'In letters dated August, 28, 1981 to the Midland Site Manager (Exhibit 2) and September 25, 1981 to the LaSalle Sita Manager and a september 25 Corrective Action Request (" CAR") to the Clinton Site Managers. (Exhibits 3a and 3b respectively). Mr. Calkins reported his initial findings oT the QA problems at Zack. CAR's were attached to all of the letters and outlined Zack's commitment to complete'its own internal investigation on the records. The commitment included -- 1) review of all ' material test reports for accuracy and completeness; 2) verification of questionable documents, 3). investigation of those responsible-for improperly modifying the' supplier test reports with the results going to Zack's president .. I for appropriate disciplinary action; 4) notification to the utilities of all technical discrepancies found in material test report reviews; 5) notification to the utilities of the results to decide if reports should go to the Nuclear l. Regulatory Commission ("NRC") under 10 CFR 550.55(e) or 10 CFR Part 21 to reveal significant deficiencies. The corrective action plans became the basis for a major QA reorganization for all three sites. It was at this point, in the fall of 1981, that six others and myself were hired by Mr. Calkins to " repair the damage" done by Zack in the QA documentation for the three nuclear sites. _ On October, 19, 1981 I started work at the Zack company as an entry level employee in the QA department. As part of my introduction to the job, Howard s

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e McGrane, of the Midland Project Quality Assurance Department ("MPQAD") presented ! me with the attached CAR #14.(a-b). (Exhibit 2, supra) On November 5,1981 I was formally appointed. Supervisor of the Documents Quality Assurance Department. This promotion entailed two basic responsibilities: First, I would be in charge of the departmental tasks as a technical director, overseeing establishment of a system to evalutate and discover all QA documentation deficiencies left in the Zack files. Second, I was to monitor the document ; control centers as they developed on the sites. I was asked to and did develop my own job description. (Exhibit 4). During the first few weeks of my employment at Zack I reviewed the QA Paperwork. From my review, I became increasingly aware of the " serious deficiencies" Mr. Calkins had mentioned that he hired me to straight'en out. I also began to suspect that some of the QA documentation had been altered improperly. In view

       ,  of my growing suspicions, on November 11, 1981 I posted prominently on the door of the QA Department a written notice stating that alteration of QA documents is a violation of federal law, and that removal of documents violates internal QA p'rocedure approved by Zack.

On November 18, 1981, Howard McGrane, a Midland QA contract employee loaned

to Zack, directed Sharon Marello and I to sign a Zack " Training Form." (Exhibit 5)

We had in fact received no formal training. At the time we signed the form, however, we were not aware of what constituted industry regulated training for our jobs. We were mistaken in our belief that the informal introductions and l self-study of industry codes and regulations were on-the-job training. We were 1

l. not informed otherwise by management.

On November 30, 1981, Mr. Calkins gave me copies of a series of documents which included his October 9,1981 letters to the utilities. (Exhibits 6a and 6b) These letters with attached interim reports by his staff identified the status of y-y,.,g. ,.e. -- erm--ee,g.i--w es er

the ::ack documentation review that was a part of the follow-up on CAR -#14. (Exhibit 2, supra) The reports attached to tne letters claimed (erroneously, it turned out) to cover 84 and 70% of the document reviews at LaSalle and Midland, re-spectively. The reporcs also conceded that'che categories listed some of the discrepancies found. The letter, signed by Calkins, promised that his review would be finished and finalized by October 26, 1981. In the letter he notes:

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                   "This should allow ample time to advise the NRC that the,possible 10 CFR 50.55 (e) should be withdrawn or to confirm its applicability." The interim reports that were attached to the October 9 letters included references to items.such as "certs altered", " white out used and retyped"; and " heat number altered to agree with certification"; missing signatures; certifications missing lack of test data for purchases; correspondence that steel had been purchased without verification and traceability; and stickers indicating compliance with pro -

fossional standards. As the sumary noted on the latter item, " Authenticity . of the signatures is questionable." On October 2, Mr. McGrane' confirmed similar findings for the purchases ' sent to Clinton. He provided the sumary to Mr. Calkins. -(Exhibit 7) ' On November 30, 1981 I also received from Mr. Calkins the third interim report dated October 23, 1982 (Exhibit 8) This report leaves little need for interpretation. It begins with the admission that - There has been a breakdown of the quality assurance program as related to criterions VI - Documents control, and VII - Control of purchased material, equipment and services, of Appendix B to Title 10 CFR 50. This breakdown resulted in an incomplete review l and acceptance of procurement documenting evidence (material certifications) and access to these documents by unauthorized personnel resulting in improper modifications being made. The six-part report went on to describe the safety implications, results of the review, eiraluation of data, and identification of deficiencies requiring engineering evaluation. The finals two segments " Corrective Action" and N 4 "' S*' W -*a h_wap_

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                       " Attachments" - are the most interesting. They reveal the effects of
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inherent conflicts of interest in straightening out the problems identified in the report. For instance, the corrective action was basically to promise

                        - with a plan - not to repeat the misconduct. The offender (s) received a reprimand and additional training. None were' dismissed. The " demoted" individual (s) - were not identified officially even within the company. Only one official, Charles Richards, was demoted. Unfortunately, Mr. Richards was one of the most innocent parties at Zack. Besides, he received a raise.

The attachments applied the conclusions to individual plants. For instance, at L2Salle, only 94 out of 374 packages were correct and acceptable. Eleven packages had alterations and siaChad stickers. Nine packages were s judged "No Good for Lasalle." (emphasis in original) . . I was informed by Mr. Calkins and Mr. McGrane that the October 23 report had been provided to each of the utilities and that the utilities had been responding to the QA problems. in different ways. To illustrate, they told me that Consumers Power had called a meet'ing at the Midland site on November 3,1981, ,, in response to the October 23 report. I did not learn of the contents of the l meeting until January, 1982, when I saw the minutes. (Infra, at ) Commonwealth l

                   ' Edison had sent a surveillance team to the Zack headquarters to audit the QA

( l 1 documents on October 9, when Mr. Calkins presented them with his October 9 letter and attached interim report. It was around this time that it became apparent to me that the LaSalle situation was particularly unnerving to Zack management. Commonwealth Edison had been " pushing" for a final report - a complete and total update of the pacerwark problems as they affected LaSalle. They needed the update so that the engineering departments could make whatever evaluations had to be made. s

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l Mr. Calkins had promised this final report by December 1,1981. In an internal October 30, 1981 memorandum (Exhibit 9), Mr. L.J. Burke, LaSalle's Project Construction, Superintend.mt at that. thne,' notified five of the top , Lasalle project managers of tne October 23 report and that Commonwealth Edison was still reviewing the extent, the corrective action planned, ard the engineering resolutions. . On November. 2,,1981, a Commonwealth Edison engineer, W.H. Donaldson, wrote a letter to Zack President Christine DeZutel requesting " additional information... urgently

needed for engineering to ex-peditiously evaluate the indeterminate or unacceptable material properties."

(Exhibit 10) The letter set 'a deadline of November 13,:1981 for Zack to suhait necessary nonconformance repor:s. The November 13 and Decem.7er.1 deadlines. wore not met, .because it was impossible for our new QA docu:entation department to audit the remaining purchase order packages by those. deadlines. Theretwere approximately 1,300 purchase order packages reviewed for the October 23 report; but at least another 1,600 to 2,000 remained left to audit. It,was the review of these documents that Conunonwealth Edison so desperately needed. As a result of the information provided me durinilate November,1981, I

was becoming more aware of the true extent of the QA breakdown at Zack. At , this point in time, the entire QA staff was under constant pressure by Zack management to produce measures to meet the hunediate concerns of the utilities f about documentation deficiencies. on or abaut December 14, 1981, Mr. Calkins told me that Christine Zack DeZucal wanted to fire a member of mh QA staff, Ms. Sharon Marello. We discussed the fact that Ms. Marello was an excellent employee and an asser to the QA 1 s 7 , ., .v g -- - - ys-, ' 8 -

_4 . t i department. The matter was dropped, however, a few weeks later and Ms. 4 Marello remained on t}ie staff. r The Bechtel Corporation was the General' Construction contractor at Midland. In a Deciember 31,' 1981 letter from'Mr. L.E. Davis to Mr. 5. Groune of the Zack Company (Exliibit 11), Bechtel referenced both the preliminary August 28 letter and the October'23 report, and'specifically addressed "Bechtel"s evalt.4 tion of reportability under 10 CFR 50.55(e);" ' Bechtel concluded that

the reported deficiencies were a paperwork problem, and ultimately the safety I i of the operations at t.he Midland plant would not be affected even if the paper-h work deficiency had gone undetected and unresolved. I was deeply disturbed by cerrain statements in this letter, particularly the statement on page 2 of the i letter that: "It is highly probable thit.'Zack ordered correct materials for the ! s Midland project from their subtier vendors and that the vendors' intent was to comply with Zack's purchase order requirements." (Exhibit 11, at 2) ' To me, that type of reassurance ~ was not good enough. -

The statements in the letter raised serious questions in my mind about

                                     - the ethics, ability or intent of Dechtel Engineering. In his letter, Mr. Davis                                   '

admitted that all of Bechtel's conclusions were based on information supplied by Mr. Calkins and supported by a Zack internal report / audit. I realized that Mr. Davis' letter attempted to absolve the Midland project of the responsibility of notifying the NRC (under CFR 50.55 (e)), by referring to the actions of Clinton and LaSalle. He defined the Zack problem as one of " indeterminate safety l concern." He seemed to vindicate Midland by using the fact that the " indeterminate" safety concern was based on " preliminary and superficial information." I viewed as irresponsible Mr. Davis' assumption that the greater detail provided to him

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in the October 23 report made him less accountable under '10 CFR 50.55 (e) . I was aware of the 538,000 fine already levied against Consumers Power by the NRC N w--e ,. .p y- _ -- wr y ej. wow- e 9% w --e,

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for Zack's errors, and the subsequent actions in removing Zack from the N - Quality Assurance program on the Midland site. As a result, I questioned the decision to rely entirely on Zack, both to define and 'in effect resolve the problems at Midland. At this point I was both confused and disallusioned about the QA situation at Zack. On January 4,1982, soon after the December 21st letter from Bechtel was received, I approached Mr. Calkins about Mr. Davis' conclusions in the letter. I was concerned about what I viewed as glaring inconsistencies in Bechtel's conclusions and the apparent lack of information on which they based the conclusions. I pointed out to Mr. Calkins that, as both he and Mr. McGrane knew, the full determination tes not yet_ completed as there were 2,600 + purchase orders to evaluate, not just 1,300 as reported in October. I further pointed out to Mr. Calkins that I recently had seen Christine DeZutel's November 12, 1981 letter to Mr. J.W. Cook of Consumers (Exhibit 12) and that it appeared extremely misleading. The letter made it appear that Mr. Mc Grane had completedthe'"totaldocumentcontrolaudit"ofZack. I reminded Mr. Calkins l that was simply not true. The " total document audit" was not. complete then - (early January, 1982) and to the best of my knowledge, is still not complete. 2w

                       ~~ Yet, the Zack Company told the utilitie r te.t everything was well under control.

l That was not su' bstantivsly accuratt, $ . ; ins lishned but did not respond.

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Ronald Perry and I had a secono meeting with Mr. Calkins the same day about the- fourth interim report for LaSalle. We reiterated our concerns that the October 23 interim report was inaccurate. Again, he winced and responded vaguely, without any commitments. Shortly after the January 4 meetings, the QA staff was subjected to harrassing and intimidating actions by Zack management that were to continue at least for the duration of my empioyment at Zack. Examples included derogatory ccmments about dress, accusations of petty misconduct such as using the company phone for personal

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g . . r \ l [_ l calls, and other distractions. At the and of January, 1982, the Q.A Superintendant at LaSalle s$nt a second surveillance report (Exhibit 13) on the Zack Company. On the whole

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this report indicates that the audit thatother three' employees and I'we're working on was going very well. In fact, it even excused Zack documentation from further review of the Architect / Engineer Sargent anji Lundy ("S '&' 9) . f- . .. 7 , . . as had previously been required. As the Surveillance Report explairied, S & L -

                   , deleted the requirements for 'submitti$tg on site contractor documentation .(such as Zack's) to S & L for review. This re-view is now the responsibility of the Zack Campany... Based on this change, S & L's letter accepting Zack's documentation is no longer required.

At this point, we had been going through the documents for over three months. However, there was still much work lefL. There was an incredible pressure on Zack to complete thle LaSalle audit / review by March 15, because that was the day scheduled for fuel loading. It was most interesting to me to note that the Commonwealth Edison stirveillance report had found two " purchase orders not yet

identified by Zack. In the first two weeks of February, 1982, Mr. R.A. Perry and I discussed . I the seriousness of the Zack QA breakdown. We then discussed with Martin Skates and David Calkins several times the fact that material did not conform to site - specifications and the fact that many of Zack's vendors were unapproved a"s' suppliers of material to nuclear sites. Our conversations led to no response from Zack management. This inaction prompted R. Perry to contact L. Shewski-Commonwealth Edison's QA manager for the LaSalle site, in mid-FebruarIyl982 about what we had found. Mr. Shewski turned Mr. Perry's allegations into a complete sham by immediately contacting Zack management. This led to more j intensive intimidation of all of us, including Mr. Perry, by Zack management. Mr.Shewski also informed Consumers Power at the Midland site. Mr. Perry and I were informed that Christine Zack De32tel did not appreciate our calls

outside the company. . On' February 16,17 and 18,1982, Baldwin Associates, prime contractor at tha Clinton site, conducted an audit of the Zack company. This was a result of serious problems that Baldwin Associates had with the materials supplied by Zack and quality assurance documentation related thereto. Even though the Zack QA deficiencies targeted by this Baldwin audit were cited as a significant factor in the June 1982 stop-work order at_Clinton, the February Baldwin exit interview

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certified Zack's documentation as " excellent." . .

                       ~On February 19, 1982, while I was out of.the office, R.A. Perry's three month contract expired.

Mr. Perry informed me at the time that he had been called into the President's office and questioned extensively by Christine Zack DeZutel, Joe DeZutel, D. Malzahn, Martin Skates And David Calkins. , They had apparently-questioned him intensively concerning any contact he may have had with any o.f the nuclear sites' management.. .

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The following Monday, February 22, 1982, I was called to the President's office for a similar interrogation by the same Zack management officials, with the addition of Carl Eichstaedt .I was asked at great length about the condition of Zack's QA files. My response was that the files were in serious need of control and that training for the QA department was also needed. Christine and Joe DeZutel said they personally would come to'the QA department to see if they could help.

There was incredible pressure on our department to finish a final audit for Commonwealth Edison's LaSalle plant by March 1st. Finally, on March 1, 1982, Zack compiled an updated report for Commonwealth Edison o.n the purchase order breakdowns at the LaSalle plant. I prepared this report. Each entry detailed the discrepancy and/or flaws and what the material problems were that resulted from either the quality assurance breakdown or the lack of approved vendors. These purchase order breakdowns resulted in a wide variety of problems.

These are ,t

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l divided into six sections. (Exhibit 14) There were 35 minor discrepancies. My greatest concern involved a section which states that: . .

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                              "...the following list is an accountidg of the P.0/CMTR No. 's that were considered to have, in part, a discrepancy _ that might possibly reflect on the integrity of the materials concerned...."

I knew this list of approximately 259 major discrepancies was devastating

to the integrity of any construction site, but for a nuclear pcwer plant it was i [. even worse. I also found 25 welder' qualification discrepancies._ _ 2 - A good example of the impact of the paperwork fia'sco is " Purchase Order Number 696, ,U.S. Steel coils". The list noted that "these coils cannot be certified to ASTM standards". Thereportalsofoundrivetsandfabeners "not to site specifications". Zack management wanted me to calT the report " final", but I refused to do that. Making a " final" report would mean that CAR #14 could be closed. I wouldn't close the report until Zack met its own responsibilities, such as the corrective action commitznents. There were still hundreds of discrepancie's left. Although Christine DeZutel promised that she and Joe DeZutel, her husband and the Executive Vice-President, would be in to assist us, they never showed up. Later Mr. DeZutel told me that I could hold training sessions with upper management. This promise was not honored either. As a result of the February confrontation and the departure of Mr. Perry, i another Zack employee, Andrea Crawley. from Clinton,' was brought in .to help us for three weeks starting March 1, 1982. I told Mr. Skates that this monitoring of our work constituted harassment and further intimidation. Ms. Crawley wasn't with us more than two hours the first day when she said "I don't know why I am here." She observed that obviously we knew what we were doing and she had no idea of our procedures. She had recently been hired by D. Calkins for documentation at Clinten and had no previous experience with the manner of our document control process. l , l- , -

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                                                      -la-During the week she stayed at Zack, Ms. Crawley witnessed several verbal assaults against me by Mr. B&s.iaga, threatening my dismissal.- She also witnessed
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similar threats by Don Malzahn towards Mr. Calkins, that he would be fired. I believed that the threats to Mr. Calkins and myself were motivated by Zack . management's fear of losing control of the as yet unexposed QA breakdcwa. On March 4,1982, David Calkins showed me a collection of Zack documents. He related to me that Don Malzahn had threatened to fire him.that day and was going to call the DeZutels (whc were out of town) to get their approval for dismissal. Mr. Calkins said that these statements by Malzahn were , made in the presence of Basiaga and Skates. Mr. Calkins told me that he had done two things that day to protect his jobi (1) he called Mr. H. Leonard, the Midland Project QA Manager, and (2) he gathered a coIlection of material which contained documen.tation~ of'the QA breakdown at Zack (including a report to Consumers Power that he and Christine DeZutel had presented in Jackson, Michigan some time in October 1981) .' At this point I realized my own job and reputation might'be in jeopardy.' ' j I obtained copies of the documents Mr. Calkins broug'ht to my house. _I also 1 began to keep a personal file and a journal on the events that transpired on the job. The documents revealed a history of deception and incompetence. For example, on November 5,1980, the Bechtel Power Corporation sent a letter to the Zack Company. This letter, which I reri, makes it clear that Bechtel Power Corporation had sufficient knowledge of n aerial being shipped to the site in non-conforming condition. Bechtel requested'Zack to stop sending nonconforming material and to return any al' ready received. (Exhibit 15) On the following day, November 6,1980, around 19 purchase orders were altered with the addition of adhesive stickers. (For example, see Exhibits s -

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ld and , infra.) These stickers were attached to the original certification and the authorizing signature was forged. I believe from reviewing Zack's files that the months of November and December 1980 were spent in a " paperwork correction blitz". This is evidenced by the large number of documentation alterations that later became apparent through the investigation that members of the Quality Assurance doctunentation staff discovered. A list of these alterations and the types were later compiled for the top level management of the Zack Company. It is this list that was provided to the utilities in the first and second interim-reports ( supra,at 4 ) and also discussed in detail in the October 23, 1981 report (supra,at 6 ). Several sets of U.S. Steel purchase orders (see, Exhibit 16 ) contained the adhesive stick,ers. These stickers contain signatures of questionable authenticity. The documentation also conf.ained another example of attempts to correct, after the fact, the " bad" documentation by going back to the vendors and asking for certifications. These certifications would show that the

           -material they had supplied was, indeed, adequate for use in nuclear power plants.

The catch was that Zack had already accepted the materials without the required certifications. So Zack wisited out the original approval signatures and asked the " suppliers to send the missing information. The cha'nges would disguise-the original illegality. To illustrate, on January 23, 1981 a request was made that U.S. Steel certify the material test reports and add the correct quality assurance information on each individual CMTR. Copies of the very form that had been altered were attached. Only the signature of the authorizing agent, in this case a Mr. Belkins, had been whited out. (Exhibit 17) On February 6, 1981 many letters were written to various vendors for nuclear items. (Exhibit 18a-d) They requested the vendors to certify that their

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                                    .                                          products were in compliance with the appropriate standards. One of these companies, the Seas Corporation (Exhibit 18 ), to the best of my knowledge, did not respond to the February 1981 letter requesting quality certification for hex nuts that had been purchased. Instead,'it did'nothing. 'A full                                  "

year later, in 1982,-an audit by Mr. Ken Shaeffer of Zack staff revital'ed"that Seas, Inc. had not responded because it: ,

                              "...has been determined that this organization will not be
                 -           able to meet the minimum established quality requirements as established'by the Zack Co. From'-the information ~;*--

received they cannot verify any product furnished...." This is a shocking conclusion and indicates a significant non-conforming condition. In February 1982, a full year after the problem was known, Zack performed a survey / audit and I noted on this audit (as well as others done by K. Shaeffer) that a resurvey / audit should ba.done. (Exhibit 19) It appears to me that U.S. Steel was beginning understand the depth of a problem at Zack in the fall of 1981. A September letter to the purchasing agent at the Zack Company lists purchase orders referring to orders from Zack to U.S. Steel from December 1980 through May 1981 that contained a. serious misunderstanding. (Exhibit 20) The letter lists the 26 purchase orders at all. .. l three sites and the letter points out that the Zack documentary " confirming orders" all read " Safety-Rel'ated". The U.S. Steel letter points out that first, the orders had not been purchased as " Safety-Related"; and second, that since the purchase orders were not called in as safety-related, they were not handled through the "V&T" (Verification and Testing) program. Finally, Mr. Peters asked, as well he should have, what obligation Zack had attempted to impose by adding on the term " Safety-Related" to Zack's purchase orders from U.S. Steel. U.S. Steel's concerns were well-founded. Zack's use of the term " Safety-Related" implied that the items received the quality verification required under 10 C7R 50, Appendix B. I do not know what actions, if any, were taken on the part of Zack management to either mollify U.S. Steel, or to deal with the problem I. -

      ~ of purchase orders of non safety-related materials on the three nuclear plant                               sites.

( _fW e v ee = w oney em +m+p-e 4-*=3 __y,_ _ _ , g y- *gD

Also included in the documents were examples of vendors unapproved for supplying material to nuclear plant sites. For. example, Edgccmb Metal supplied steel beams for use at the Clint'on site. These' beams were purchased from several different sub-tier vendors through Edgeomb. The entire shipment was sent to be galvanized at Reliable Galvanizing and finally forwarded to the Clinton site. This entire purchase process took place 'in the sunner "of 1979. In September 1981, a survey and evaluation was performed by the Zack Company's new QA Department (Mr. Jchn O'Connell) on Edgcomb Metals.' (The September 23, 1981 audit results and attachments are enclosed as Exhibit 21.) The results need no explanation from me. -

                                " Findings

1) The lines of organizational' structure, responsibilities, and inter-functional relationships were not de'lineated in the Q.A. Manual.

2) No performance of a program evaluation.

3) No NCR/ CAR plan to identify, analyze and take action to correct' deviations from quality requirements.

4) No identified plan for the maintenance of Quality records.

I

5) No provisions tc ensure that purchased material meet quality ,"

requirements. ,

6) No evidence of callibration records for caliper.

7) No vendor evaluation.

8) No check of CMTRs against received materials.

9) Contrary to Edgcomb's Q.A. Manual, no receiving inspection report is presently being utilized.

10) No management evaluation of the Quality Program."

On September 22, 1981 the vendor Edgeomb Metals was placed on unacceptable status. (Exhibit 21, sucra) AlthoughIbad no way of determining now whether Edgccmb ever met the requirements of doing business with the nuclear industry, it appears that Zack had not imposed those restrictions on Edgcomb in the pa'st. In other

/-

words --even though beams purchased through Edgce=b Metals might meet the physical and material characteristics for use in nuclear plants, their overall N quality and country of origin remains a mystery, alt. hough Ms. DeZutel thought they might have ccme from Argentina. (Exhibits 22a-c)' N If the beams are truly acceptable, that is' totally g seite g Zack's purchase order quality assurance system. A June 1979 purchase order (Exhibit 23) does not contain the required clause under 10 CFR 50, Appendix B, notifying the vendor that this material could be used in a nuclear power plant. The material never went through the system of " checks and balances" that the NBC imposes. Another vendor, the Delta Screw Ccapany, also failed a fall audit. (Exhibit 24) A fall 1981 Zack letter from Mr. Calkins allegedly removed Delta Screw Co. from the approved vendors list-for failure to comply with the requirements of a Quality Assurance program as requir d by the NRC. However, I knew that Zack Company did not follow its own " approved vendors list." A list 3 of the P.O.s from December 21, 1981 to Febru y 1982 reveals that, in fact, Delta Screw received approximately 38 purchase orders frem the. Zack Company before being put back on the approved vendors list in February 1982. (Exhibit 25) - Another issue that came to my attention in the documents was the lack i of proper qualifications for the Quality Control Audit personnel. Proper qualifi-cation is very important because Quality Control Audit personnel that have not < been adequately trained cannot perform their function correctly. The auditors at Zack did not meet the minimum specifications for their positions. Personnel paperwork was not numbered and personnel failed to take such elementary tests as written examinations. I r h-s -ww wew wwwe -w-=m - - * -wee _,we ww- . -. ,m..e -% e-

                                                                                                 - , . - - ,   . , . . . .  ,--.e.--    -rj wm--,wemNmi-

l Zack had an auditor, Ken Shaeffer. He was found to be " unsatisfactory" in the August 1981 audit. (Exhibit.26) In a February 1981 evaluation,'Mr.

Shaeffer had been rated as " average" and certified from March l981 through March 1984. In light-of all the QA/QC-problems inherent to the Zack Company, I found it extremely interesting that Mr. Calkins was given the assignee status for the Zack" president -in evaluating and certifying QA personnel. (Id.) The .. President of Zack, Christin'a ~Zack DeZutel, did 'not qualify in ~QA, -yet:it-is

                ~    ~

she who assured the utility management that all problems relating to the - Zack QA/QC breakdown were under control and under her personal supervision'.

(Exhibit 27a and 27b) . On August 31, Ms. DeZutel finally was. formally qualified on the basis of one hour'.s " training" in government and professional codes, which was obviously inadequate. (Exhibit 28) ' s Although I was already familiar with the Octobe'r 23, 1981 Zack" report to the utilities, I' was' very surprised at the no'tes of a November 3,1981 meeting at the Midland sitie. (Exhibit 29) The sunniary no'tes of that meeting concentrate l on discussions about materials as they relate to health and safety. In fact, employees from Bechtel Power Corporation, Consumers Power Co., and MPQAD personnel" along with twa Zack personnel who made the presentation were in attendance. It was most interesting to note that the first topic of discussion was whether or _ := not to report the QA breakdown under lO"CFR 50.55(e) to the NRC and to then query the Zack personnel on how the other utilities had handled the information. Notes of the meeting also detail the discussion, by categories, of discrepant conditions in the sheet steel and coil, nuts, bolts and screws. It appears from the notes that the management in attendance at the November 3,1991 meecing was prone to accept the Zack explanations and predictions on the safety-- related impact on materials of the paperworu deficiencies. The reported conclu-sion of the November 3 meeting emphasi::ed the mt :ually beneficial findings that N

         \
 ._ ..;       _ m_,

U j . . k' the material pieces affected "would be acceptable", and that possibly-at the worst--additional testing would be required to prove that the material was in fact s.afe. N

    \                              It is also revealing to me that the chief concern, or at least the primary evident concern of.the. management in attendance at.this meeting, was.what; position
 ~
                        . the other two utilities (also compromised by Zack's quality assurance breakdown) were going to take. Although the discussion is not included verbatim ^ in the minutes, the summary. notes of _ the meeting make it quite clear that at least one of the other utilitias deeined the problem to be reportable, and the other found                '

it " indeterminate". This term seems to be the escape valve on which to rely. A list of 12 Action items that are included in the meeting notes are also particularly revealing. These items required Zack to state in writing "that all items with C4TR listed' as below 36 KSI*are, greater than 30 KSI", to prepare a list s of all suspect material purchases", to "try to get material certified to federal . specifications..."' and repeatedly to revise or clarify existing requirements so that the purchases would be acceptable. The summary of the meeting, as relayed in these minutes, woul.d lead tie uninvolved observer to believe that Zack and the Midland Project management had everything under control and that tihe Zack .. problems were nothing more than a paperwork breakdown. Another example involved three 1981 Delta Screw purchare orders numbered C-4286 (dated February 4,1981), C-4473 (dated August 26, 1981), and C-4484 (dated September 11, 1981). (Exhibits 30a-c, respectively) All involved some I . 114,000 hexheads, bolts, nuts and similar items. Two of these purchase orders were for Midland. One of them was for " stock" and could have been used in all three plants. The specification that was not met was the ASD4 requirement that "A 307 bolts must have manufacturers identification markings." In fact, none i 2" . - ____;_~1._,__n____

                      ~,-~-~--:-------              t -_      -
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I 1 1 l of the 114,000 hardware pieces from these purchase orders contained the l identification marks of the manufacturer,.as required. Zack took inconsistent action on the Delta Screw P.O.'s. On September 22, l a nonconformance report was prepared for P.O. 4484. Mr. Eichstaedt' did nothing until three months later on December 17, 1981~, when he apparently ' secured Delta's approval for return of all the shipments. (Exhibit 30c) He took this action . through " Change Number .1", dated December 22, 1981 and attached'to Ioach purchase order. We were suspicious, because the hardware in part already had been delivered to the various sites. (For notes of Mr. Richard's research confirming shipments to Midland and LaSalle, see Exhibit 31.) After further checki:ig, Mr. Latema confirmed to me that the material was not in fact returned for credit. In other words, Mr. Eichstaedt's December-22 " Change Number 1" was not accurate. It is also inexplicable why he wrote a nonconformance report for one-P.O. - (4484) and not the, rest. They all . suffered from the .same deficiency. : .On- -

       " December 30, 1981 he .al,so . closed out the nonconformance.                    In the process he rejected
         ,his own December 22 position and dispositioned the NCR                         " Material. accepted Per Bechtel SDDR 2187." (Exhibit 32)                                      .                    .

On Monday, March 8, Mr. and Mrs. DeZutel met with D. Calkins. The outccme was a $12,000 raise and one extra week of neation for D. Calkins. For the rest __ =% of us in the QA department, the situation worsened in terms of harassment and internal pressure. During this week, the third secretary in as many months was fired, and a member of the Quality Assurance staff, Sharon Marello, was hospitalized. She told me her doctor said the tension and exhaustion from L working six days a week,12 hours a day and all of the internal harassment and intimidatien led to her hospitalization. t I requested a meeting with Mr. Calkins for Saturday, March 13, 1982. At this meeting, I discussed with Mr. Calkins all of the internal pressure that the Quality Assurance department was experiencing in attempting to do the job that (, ,, 2 ., - , - . - , , ~ - ..----~~~c -- - - - " " - ~ ~ ' ~ ** ~ ~ ~ ~

                      .__ _ _                       T.                -

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                                                                                                                  's'                          .

he had hired us to.do. He agreed to have an immediate Quality Assurar.ca j departmental meeting and to get everything straightened out. However, D Calkins never followed through with his assurances. .Instead, the remaining six weeks is N

a diary of increasing intimidation and verbal abuse 7

                                                                                                          -Management took'many a;eps x

to encourage my resignation. ~ ' At one point, I was even invited to interview at the Midland site for a possible appointment with Consumers Power Company and Bechtel Power Corporation. ,

Cn March 25,'during my interview at ' Midland, I related to Mr'. H. ' beon'ard / of MPQAD th'e awkward difficulties that the QA department at Zack was experiencing. . Mr. Leonard agreed that Zack had had a large number of problems over the years, and that if I wanted to make specific allegations about the problems, I should do so. He further told me that my job was protected under the law and that he would give me a confidentiality agreement. s Upon my return to Zack, I continued to help " clear" 99 NCRs for the LaSalle site. Although I requested adequate time and coope..:-ration in order

                                                                ^
                                                                                                   ~

to' perform 'this task properly, th'ere was no assistance forthcoming.' The atmos-phere had deteriorated 'significantly as the pressure to meet impending 'sitie deadlines became very intense. The Quality Assurance Documentation Department " t staff resisted the intimidation, threats and harassment and continued to do the job as accurately as possible under the circumstances. On April 5,1982, in a meeting with David Calkins, I was asked to lead a group of relatively untrained QA employees in writing all the Supplier Deviation bisposition Requests ("SDDRs"), and Discrepant Material Forms for the Midland site. I told him to be patient. 6

                                        /    e

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                                                                                           - - - - - '   ~

95 , e On April 7, 1982-I had another discussion with Mr. Calkins to inform him that in my opinion it was not possible to-complete the documentation review within the deadlines, even if the QA staff continued to work the extensive

overtime we had been putting "in. Mr. Calkins gave me no guidance or hope that the situation could be resolved. Again, he was mute in his response. On April 13, 1982 I called Mr. Hank Leonard, MPQAD, and spent approximately two hours relating t' he types of problems going on at Zack. I told Mr. Leonard thattodooubjobscorrectlytheentiredepartm'entneededprotection'andrelief

'~

frem the stressful 'situatio'n' we were working under. ~ He promised that rekief' prctection. 'I decided to mak'e the allegations officially, hoping .that he would ' initiate action on his own. He did not. On April 15, I called again and made official allegations through the MPQAD Allegation System. (Exhibit 33) I did not give'my permission to Mr. I4cnard to release my identity. On April 16, 1982, Mr. Calkins called me into his office and told me I had betrayed him and that he was not going to speak to me anymo:.e. He also asked me to send him "six suspect files" as examples to prove my allegations. , I .. had already shown him many more than six examples. . Soon after I left his office, I received a copy of a memo addressed to "All Zack Personnel" from Christine Zack DeZutel. (Exhibit 34) without mentioning me by name, this memo referred to and then denied the allegations I had made to Mr. Leonard. It also denied us access to the files without upper management permission. Mr. I4onard then flew down frem Midland and conducted a two-day " investigation" which amounted to little more than a review of Zack's handiwork. He only questioned four QA people. Two other so-called ' experts' from Bechtel and Consumers took occasional, sketchy notes. I know because I watched their every move. 4, 9 ggm. ma. -a y ae -- =-.m * ----=w - eem , ==

L_,_ g On April 21, 1982, Mr. Leonard said he wanted to see me away from the Zack Company premises. We agreed to meet at his room in the local Holiday Inn. My wife' Den to the meeting with me as a witness. Mr. Leonard told me he found nothing of substance wrong with the Zack QA documents. This meeting lasted three hours, duririg-which nothing constructive occurred. At one point, Mr. Leonard

                                       \               '

made the foreboding. remark to me: ,"I was fired once,~too, you know." Shortly after the departure of Mr. Leonard and his investigative team from Midland, the management at Zack gave some indication that they would be

                                              /s                                                           .4       -

I making concerted efforts to, maintain the integrity o. f the, quality assuracce program they had been required to set up. Christine DeZutel made s.ome promises about improvements, i,.e_. better environment, pay raises, etc. - On April 27, 1982, Ray Basiaga, the so-called Quality Assurance Training Instructor, gave the only formal QA training any of us ever received during six and a half months of doing major QA wor'k. (Exhibits 35) On April 28, 1982 a Corrective Action Report (#20) was written. (Exhibit 361 - It requested that I " formulate a training plan" for the document control depart-ment. I responded the following day, April 29, with a two-page letter (Exhibit

37) outlining a Quality Assurance Training Program, and other much-needed reorganizational efforts to ensure that the QA program would meet the letter of the law.

The next day, April 30, 1982, I was called in front of a top-level 1 management meeting and, after a scathing attack by Christine Zack DeZutel, was told that my services were no longer needed. (See her April 30, 1982 letter of dismissal, attached as Exhibit 3,8, which repeated the subnance of her tirade , and announced Mr. McGrane would replace me on CAR #20.) One of Ms. DeZutel's basic criticisms was that my staff and I were incompetent. Her attack created a dilemma for Zack. We had alleged the QA " reform never occurred, due to mismanagement. She in effect agreed with us and noted that the i N

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3, pf ack QA performance was " appalling". She simply blamed me. It does not matter - whom you point your finger at regardless of blame, Zack's work was no better than before the August 28, 1981 report that conceded the QA breakdown in the first place. Within minutes the rest of the QA documentation department was told the same thing. We were handed our final checks and told to leave, taking only our personal belongings. Mark Cioni, one of the QA ctaff employees, had left the job early that day for a doctor's appointment. He called me at home that evening

                                        '~            ~

and rela 5ed to me the contents of a Mailgram he had rei:eived. ' The Mailgram was signed " Christine Zack'DeZutel', ' Pres'ident", and informed him he had been

                     " terminated" on April 30 "due to structural reorganization." (Exhibit 39)

The first working day after our dismissal, May 3,.1982, I went personally to talk to the NRC. I spent three hours with a team of investigators, including James Foster, Gerald Phillips, Charles Weil; Harvey Wescott, Cordell Williams, Wayne Schaeffer and Jim Peschel. Mr. Wayne Schaeffer of the NRC office was the

                      ' host' investigator. Their reaction was cooperative. I had the impression that they would investigate seriously. They asked for more documents to copy, which I supplied.

During those three hours I d'iscussed all the issues in this affidavit, and._ left them almost all the documents attached here as Exhibits. I cannot be sure, since I have not yet received the receipt they promised to send. Not receiving

the receipt is disturbing, especially since last Monday Mr. Norelius of Regicn III said he had sent it the previous day. In addition, I left with the NRC other disturbing, pertinent evidence. The additional evidence involved more cases of alterations, possible_ forgeries and suspicious discrepancies. ~

                                                                                                                                                           ~
                                                                                                                                                                               /

For example, I gave them January 22, 1982 correspondence between Zack and RMC, Inc., who sold Zack copper tubing. (Exhibit 40) Mr. Eichstaedt asked s

     - - -                                              -.m_mhm__...._ma.-.__.2._m_muu_m.m.__..m__.n___m                     _______ __m  -m.mm._.m_a  i_mn.a._m_.am.m_._m.        _ _ _ . _ _ , -._.mh.J

RMC.to certify the traceability of certain safety-related materials and even enclosed a model' letter. Rather than check the records, RMC merely retyped the model letter verbatim and returned it. They even typed in the same spelling errors. Miraculously, their confirmation letter was dated January 22, 1982, the same date as Eichstaedt's original letter- of inquiry. L . .. .. Another example involved the Weldstar Company, which sells weld electrodes. .

                                                                                                                                          ...       .a--

Weldstar did not have the 1978 certifications Zack needed, but they were most

 .                                                                             .                   . . . .            . ..          . , z . :. .                .

cooperative. In an April 6 letter to Mr. Eichstaedt, Weldstar sent a certification 7+- - " . 9,'- form and told Zack to just fill in the blanks. (Exhibit 41) I also showed the NRC an internal September 14, 1981 Zack audit (Exhibit

42) which noted, "Zack has historically not performed any surveys on approved vendors, nor is there any historical data to back up qualification of vendors."

The recommended corrective action was t h equalify all vendors. Another finding confirmed "there is no disposition or identification of. material as safety or non-safety related". Overall, the audit concluded the above problems represented

       " serious program deficiencies." Other relevant documents I believe that I shared with the NRC are enclosed as Exhibits 43a-43w.

The NRC description of its LaSalle report of our meeting is absolutely . false. I spoke in great detail and said my findings applied to all three sites. I emphasized problems at LaSalle more than Midland. I left my records with the staff that day, and more the next day. From May 3 until July 21,,1982, no one from the NRC office has contacted me for further information, although I called close to half a dozen times. I came to the NRC office that many times and spoke with Messrs. Foster, Phillips or Wild. But they never got started on the investigation. Finally I decided to try someone who was interested. Althought I told the NRC how the documents covered LaSalle, I do not believe that any of this information was included in the recent NRC investigation of that plant. This is unfortunately, since even a simple review of my LaSalle informatien m would indicate serious problems in determining the integrity of materials used. _ y 9 --,,ee

                                   ,            - ww -                    ., -                                                          -       ~.          . - - -    - - -

I was convinced then, as I remain, that there were two basic reasons we were dismissed. The first was for doing our job too well and thereby becoming dangerously familiar with the quality assurance breakdown at Zack, along with the safety implications that breakdown had on the three nuclear power plants. The. second reasori is that my contact with Mr. Leonard through the April 15 allegations led to Zack's decision to eliminate the QA documentation team. i , Although I have seen the Consumers Power Co. letter to the Government Accounta-bility Project which requests that -GAP investigators bring all allegations 'to - MPQAD (Exhibit 44 ), my personal experience dictates that action would be personally disastrous for any others who notify MPQAD of serious problems. It has been a sobering education to realize that the information I brought forward in good faith because I was concerned about the safety of my fellow Americans in Michigan and IllinoTs'has led to incredible financial hardship for my family. What is even more sobering is to accept that the NRC has received all of the information concerning Zack, including evidence, and failed to act on it until they were publicly embarrassed. I have read. the above 27 page affidavit and it is true, accurate and complete to the best of my knowledge and belief. e. A. Terry H6 ward SUBSCRIBED AND SWORN TO BEFORE ME this ,A 4 Cl, day of July,1982. YA4 N. 444. _

                             !!ota:y Pu.blic.
                                 . ". VICLA H. BURKE NOTARY PU8'.lC DISTRICT OF COLUMBIA My, Commission Empires January 2,1986
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9 ' Albert T. Howard-EMPLOYMENT HISTORY: SUPERVISOR RECORDS MANAGEMENT Zack Company Chicago, Ill.

                                                                                                                                                      '\s Responsible for leading a task force temn                        .\ N-
                             .                             '. ~                          especially formed to reslove problems of documentation and records management.
                 -                                                                      Responsible for-lending technical assistance to Control Centers of three nuclear sites.

Responsible for writing and instructing

                -                                                                       Records Management / Document Control procedures.

1981 present. CONSULTANT - Hems & Company ,

                                                                                     'Milford, Ma.

Owner-operator of consultant service organ-

                                                         * -                           ization lending advisory assistance in the.

field of real estate construction and invest-ment.. 's

1974 - 1980 .

 -                                                                                     INSTRUCTOR / CONSULTANT              s Shewsbury, Ma.                          ,

I - ' Responsible'for the design and use of effective laboratory facilities and techniques in the

 -                                                                                     field of science education.                                -
                                                      .'..                             1969 - 1979                                                  ,

DIRECTOR / CONSULTANT North Smithfield, RI

j Responsible for developing Special Education

                                                                                     ; project for State and. Federal funding.,

1965 - 1969

                                                               ~                      INSTRUCTOR / PRINCIPAL Otis Air Force Base Responsible for the educational leadership in

two educational facilities. Responsible for

(

                                                                            ,         contributing consulting service to engineers in the construc' ion of three plants.

l < 1956 - 1965 . [ PERSONAL: Married; excellent health. l

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August. 28, 1981

                        , Bechtel Power cdrpora tion N                                              7220-H-151.-C/n 538 P.O. Box 21G7, Midland,-Michigan 48640                                                  '

nttn: Mr. L.E. Davis Site Manager Re: Consumers Power Comiiny k Midland Power Station 7220-M-151 Gentlemen; During a recent Quality Ashurituce review of the cortifications for the Midland Project IIVAC matorials, a nutuber of i nconsist-ancies were determined. These inconsistancies were discussed with Mr. 11 . 1;conard, Manager of 0. A. for MPQAD and verified to also exist in the copien on si tc , These inconsistancies have been identified and catagorized into the fo-1]owing four arcas: 1. Material certifications ~ with incor:fplotc information. " 2. Material certifications with technical inaccuracies. 3. Material certifications with possible unauthorized

  .                                            and improper modifications.,

4. Possible person / persons improperly modifying material certifications. While.The Zack Company has not yet completed it's investigation " as to the extent and validity of the above mentioned inconsist-

        .                ancies, it did feel that the indications were of enough substance that The Zach Company may need to solicit. nechtel Corporations assistance                and participation, if those inconsistan ic es are deter-mined to be deficiencies,in the evaluation and determination of a possible 10CFR50.55 (e) reportable defect.-

Attached is the Corrective Action Request generated by The Zack Company Quality Assurnnce DepartMont, which identifies the prob-lem, contains a plan of action to determine the extent of the problem and the time frame for it to be completed. Upon completion of this ' activity' and evaluation of the information 4athered, a recommended corrective action will bc determined. ' At the present . time The Zack Coinpany does not action re:;uir. d.. by Bechtel Corporation or by Consumcru Power Company isfeel any addit This position i s ,na.i apon t he following considerations:

                             - FOUNDED TO SOI.VE THE UN: CUE t.1Fi At FADN; CATION t!EEDS O tNOU~.iTRY *

DED;CATED TO Ct.EAM.*FJ ^ *;!' D J'i' * 10t'-O h T AH ; N l '' Gh*

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1. Many of. thu errors on.1/or inconnistanc:len may be only -

l clerical oversightn. \

2. Recent corrected certifications be.ing received are

         .                                                completely acceptable.

l

                                       ,         3.       Fabrication and crection operations of forming, welding galvanizing, etc. have not indicated any problems which would indicate that the material has any significantly different properticu.                                    s
                                                                                                                                                     ~

l 4. The inherent design conservatisms may be able to accept i any minor descrepancies, s l l 5. The limited number (19) of affected material certifications ! identified to date. The Zack Company will keep Dechtel Power Corporation fully informed

                    .           of developments as they occur and will discuss all results and evaluations prior to any final reports being issued.

We thank you for your cooperation and support in this matter and should you have any questions or problems, please do not hesitate -

                     ,          to contact us.at (312) 242-3434.                                                      -

Very truly yours, , i David E. Calkins, . Quality Assurance Manager . . . DEC/br

                                                                                                                  '         ~

cc: R.C. Ash, Field Contracts Admin. ,, H. Leonard, QA Mgr.,MPQAD C.Z. DeZutel , J.C. DeZutel ,

C.L. Eichstaedt, Jr.

                                                                                            *                           ~ ~ ' ' '

R.B..BcCarley Files / Midland . Files / Chicago , l . l

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     ,          1. CAlt 1111MMER                              *
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3. PHOJECT _ .!! ldh"0 l*:!'df;8' J* l d i of1. .. . _ . .. . 4. 1.OCATIOrJ_ Z;n;k .Cu_/Claj r ae,,,. r_.s.Fic,. ,

5. ACTIOrd A1; SIGNEE. O..L lly A'.rrniiluut_. . 6. LC111:DtJLED CO:4PI.1 rIOri DATE_1 U')O/81

~1.

DUf;CRIPTIO;3: _An va'idit'i"" n F M i d ' "id I'@c.!; M Mal._c4. , ' i f i < a i < -- h .- kn:pl.dtha folle. ri tie. d i . c.. ..p;i.g g . _ ,[

1. Incompletcr material te;.t rei, orts. '

4

                              *                        .Anwu cus i.itiTrIIIT-'t'Uf;C*1TipoTCs.

3. Tranm- a,1 v =am<11 F i r eths;.,. repr** t +-

*4.

Possibility of Individual (s) uithin Thu %wk Company 3mproperly. u.au... 14 3 m .i. iup u.s.

8. RECOMMEl:DED/ DIRECTED CORRECTIVE ACTIOt:(n) : lJL ordr r tn rle t <.m t..<- 1 M. r v t <. n t- r the seriousness .of these deliciencien t hc following 'inventigations u ;.l ,..

and eval-( Jmil im w..J.. dud. . l. Thn O. A. Mer. will dirc.ct-[t ham of {Q,d puroa 2 n t- '{%ch orid (1 ) MPQAD w .,,ldm %., rep. .to review tall 2natorial test reports for accuracy and 177--itr/UO/61. - 2. For Test Neoortn* nusnected of br.ing mo.11fied will 1.<e verified v.i th

                                      ,               the respective supplier. Schtw2. cornpletion 10/30/81, (continued, page 2)-                                           ~

((gd*g Fjh Qg 4

9. QA MANAGEit/DETE ' El 10. PRESI g /DA"E' -

11. ACTIO!4 TAKEN:

I i i . i

12. ACTICil AS!:IG13EE/DAT!?

13. VERIFICATIO! - .-

A I K. l __ 14 ACCI'PTED/RE.IECTED _ _ _ L y 9y, re , T*"r "T* f r

                                                                                                                                   .u-_.a                ;-                         '  ~~' -                        i""--'" ~

s u . .:. t w i . .; .1 s t a s s.. ;isi .: (g ;,t.) ! (}tc l(st4 , liEC:0.D* fra sr:p/131gg.(, .. .;;g3 c,g,3 ggg,,'pj y .; 3, .,.I('!3 (*3)

L ses s1 i ss d 3.

Individu.al(u) im.i.1 i c.ited or . ss .ss. s:t s d tof isi.pr o3. .' EY sundii in Uttpplier terst. s eport w 8 I t a. - ol>t.oines1 u tJ 1 3,., t uvm.t. ej.it e.1 genil i he evidence fc 2 w.it d. d t t, 'ilit. / it.P. tt. g,,,y p a g . g g

                                                                                   +8pjsrup: Ant u d t:.e pliis,,, y neg ;on,                                                                                    1                --

4. tJpon complit los. or :. steri sl. te?.t. rt:; ,rl ruview : 11 technical cliscrepouc.a c::

Corporat. ion for wL11ev.ilu.it1.e id nt *t i
t1.ind forw.arded t.o !!cchtel Powe'-

it.n. , 5. dpon ecomislution (40 Action'. I tjant 4, !!ct.htel Power Corporation wlg. l>tt cont.tcted .ind a det.or,siin,,t inst it a ponnilslu 10Cnt50.55(e)/ OC. sat *:1 reporct t.hould he inalt.icat.ed. i -

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          ,h9t 60 A . CO.,                                   -

i

                                        ,                           j '                                                                     CUSTOM META 1. FABRICATION

, w .r - - cepte .ber 23,;1981 Commonwealth Edicon Co. LaSalle County Nucluor Station ~

                               ,         Rural Routu.#1,llox 220,                                                                                                -

2601 N. 21st Road, .

Marseeilles, IL G1341 . .-

Attn: Mr. L'illiaza Donaldson - - f Site Mgr. - -

      ./                             lRE:             LaSalle Power Station, ifVAC Contract #J-2590 Cc:nmonwealth Edison Co.

I g Centlemen: During a recent Quality Asnuranco revipw of the/*certi11c.stions for the LaSalle Project UVAC materialu, a nuteher .of inconsistancies were determined., Thusie inconclutincies 'have been identified nnd catagorized into the following four areas: t -

                                          \                   1,         Haterial certifications nith incomplete information.                                                                                   '
                                                                                                                                                                                                                                  ~

2. Material certifications with technical inaccuracies. a Material certifications with possible unnutherized

3. -

and improper modifications.

4. Possible person / persons improperly modifying material certifications.. -

While The Zack Company has not yet co:npleted it'h investigation as' to the extent and validity of the abc.ve mentiioned inconsistancies, it.did feel that the indications were of enough substance that The ' ' Zack Company may need to solicit Cor:cnonwealth Edison Company's

assistance and, participation, if these inconsistancies are determined to be deficiencies, in the evaluation and determination of a possible 10CFR50.55 (e) reportable defect. .

i - Attahced 'is the Corrective Action Request generated by The Zack Company - goality Assurance Department, .which identificu the prohlem, contains a plan of n2 tion to deterriina t.h:r extent of th:: problem and the time . frame for it to be completed. 18pon crupletion of t.his cctivity and evaluation.of the infon:tstion gatheered, a recor::nonded corrective action will be determined. At the present time The Zack Company 'doen not fee 1 any adattional action by Cor:znonwealth Edison Co. is required Thin position is based upon the . following considerations; ; .-

TOUNDED TO SOLVETHE UN;OUE METAL T AHR ( A7;ON r.gg,OG OF IN.NSTRY * -
DEOJCATED 10 CtEANING AND CUVICMIMiJti IHE / tin C4 U IE. WORLD * ._

x ,

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4..w -mn- a_ _e_3 ys , _ y_--_ ___.3%,.yL_a__ 2_2 - u.e_e-_w_- 2_ _,ar-h a m us e w w w w -

                                                                                                                                     '                   ~

2. Itecuiit correct'ed < es t i Cic..it.ionn f.eing recoiv.ed azu cunpletOly accept.nble.

3. F.shritj.ition anct s ec:t lon oper.at. ion:: of forming, velding galvanir.ing, etc. have not: indicated any giroblems which would indicate t hat. flat u.it.urial han any nigni ficantly difYurent propert.ieu.

4. The inherent de$ign cronnervatint.in may be able: to accept any

              .                                                 atinor doucroprenelun.

5. Tho' limite:d nua. bur of af fected waterial certifications identitit.d to deito. .

The Zack Company will keep Coewanwe.alLh Edinon Ct). fully informed of

developmentu ar. they occur nad will dinuuan all r6nult.u and evaluations .

prior to any 2inal report.a being isnued. . He thank you for you'r cooperration and nupport in t hin mat.tcr and should you have any quantions or problem:s, please do not. husitat.c to contact us at (312) 242-3434. - I .

                      .         Very truly yours,                                             -

f TIIE ZACK COMPANY p AE&dx David E. Calkins, s Quality Assurance Manager - DEC/br . cc: C.Z. DeZutcl , , J.C. DeZutel C.L. Eichstaedt, Jr.

C. Baumgardner
Q.A. Files / Chicago * -

mQ.A Files /LaSallw- /, '

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5. ACTION ASSICtJM:.!2. .A.. I'I .

                                                                                         /I_*".'.it I .81 t ,.                 f. 1;CLEtull.Lis CuttPL1:TIOta ilATU-                                                                _

1

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            ;*1. DESCRIPTION: Au ggel uitt. inn n f Tot;. I l.                                                                1.*     <ii e.t it.i t .. . i .. I ( r.r t 1 r ( r.. e i . .. .                                  5. v rcavstaled the folley.elnes dit: crop.inde.r

1.

Incorrpluto natorial, tent s eyrtn. -

2. Incorrect material ton,t re:.oet ,t. ~

3. 3mproprarly riodified tent r espset.:. *-

                                 . 4.

l'ossibility of individual (nh withiti The Zas:1: comeanv imnronterly ' ch.snging tout reportn.

                                                                                                             ..                       ..              ..                      . .               .. . . . .         . s.

g . i . . . - . Tn nrde

9 n dr t c.e .f n r. t b O. RECOMMENDED / DIRECTED CORRECTIVE AChlON(u): a* a n *-

and the certouuness of thesee deficie.ncion th follrwino invan t-im+ f en a nr1

              .       evaluations shall be r:nnducted:                                                                                                              /*

1. The Q. A. Itcyr. will direct a ticam of four (4) docomant Trrh nnr1 ena (1 )

MPOAD Rep. to revic*w all mater al test reent ts for occurdev and completeness by 10/30/81'. fenntinuell noe nane '11'

                                                                            /lYCYb8/

h b A l.t l$ r L b ug h . s

9. QA HANAGEH/D5TE Chrintide/7..10. PngrI' BENT 0_.?n t r.1 /,DATs-4 /M /3 V

11. ACTION TAKEN:

1 .

12. ACTIOil Ar.dIC137.3/DATE j

13. VERIFICATION: ~

( _

14. ACCEL'TED/ REJECTED '

  ,     _                   .       _.        . . . . . . , .                 .          35. QA, MANAGER /DATc                                                      16. PRESIDENT /DATE
  =:. - . _

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                                                                               ... ... ; =.:: - :.: ...u.._...                       - : ..: 2. . . ......

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                                                                           .'.c.,*. ;.Q .-?:7. :. .h W **, : m 's.; p t :*. ' s t~~w ~ * . .*: -*                                ,    -~~ . . . . . . .                    .
                                                                                                                                                                                                               ~~"v3l = ** c .na-   m . 3

_. - _ . . . _ , . , _ ,_.._m. _ ____.s._-___._._____

u, 1. ..p..c i i v c ... 0,. .... . : . . .. . . . . . . . . . . . . . .. . ,. . . I 3. Individu.61 (s.) isaplinit.ed or ;nt.pucted of. $inpie pt.r.ly sw.etif yinst

s. .

supplice ter.t. rep.setu wil t 1,<. Inve:.t igat ed used line evid. neo obtained will be forwarded.to The 7 iet Co.uteany Prer.ident for appropriate '

            -                                      dinciplinary action.                                                                                                                                            ,

4. Upon cotnplot. ion..ot' an.iterial tend releuct. ruv.luw all technic $1 discrepancice will ha ident i tled and for.v.si de.d to Co.wr.on.nralt.h Edluun Co. for evaluation

5. Upon coinpintion or Actionu 1 thtu 4, connonwealth Edle.on Co. will be contacted and a deterr.:ln.it.ie,n if a por.nibio 10CPR50.55 (c)/10CPR21 report

                                                                                                                       ~
                                                                                                                                 " ' ' ' ~ ~ ~ ~ ~ ~ ~

should be initiat.ed.

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                                                                                --                                             CUSTOM METAL FABRICATION
                                                                                                                            .            september 25, 1981
                                                               -/                                                                        #K-2910-CZB-297 Baldwin Associates

P.O. Box 306,

Clinton, IL 61727 -

Attn Mr. William Harrington - Project Manager

~~

Ret Illino'si Power Co. Clinton Power Station - HVAC/K-2910

Baldwin Associates
Gentlemen; ,

During a recent Quality ' Assurance review'of the cebtifications for , the Clinton Project HVAC materials, a number. of inconsistancies were determined. , catagorized into the These l'nconsistancies following four1reas: have been identified.and. .

     .W
                                         .        1. , Material certifications,with incomplete information,                                                                                                    -
                                                . 2.                                                                                                                        ,                   .
                                        '                  Material certifications with technical inaccuracies.

3. Material certifications with possible unauthorized and improper modifications. - - '

           .                                      4.
            -                                             Possible person / persons improperly modifying material
             -                                            certifications.                                                           ,                                   ,

While The Zack Company has not yet completed it's investigation as i t

             .                        to the extent and validity of the above mentioned inconsistancies,                                                                                                      -

it did feel that the indications were of enough substance that The

                                  .Zack company may need to solicit sargent & Lundy's assistances and participation, if these inconsistancies are determined to be defic-iencies, 55(e)                in the evaluation reportable"~           defect. and determination of. a porsible IOCFR50.

)- . ' . - Attached is the Corrective Action Request generated by The Zack Company Quality Assurance Department, which identifies the problem, contains a plan for it of toaction to determine the extent of the problem and the time frame be completed. Upon completion of this activity and evaluation of the determined. information gathered, a recomended corrective action will be At the present, time The Zack Company does not feel any

additional action ~

                                  ~by Paldwin Asccciatos is require.l. 'Ihic position is based upon the

followihg considerations: -

N TO SOLVE TrtC UNICUE *.*ET,1L FA9RICATIO.N .NICOS C \ L . . . .

     " ~ ~- 4 2** FCUNCED                           NW                                                                                                    NCESTR.Y,,*

4M*d:-Q.c:mi__

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                                                                                                                                                                                               .. ~

1. Many of the errors and/or inconsistancies may be only. clerical ' ;

oversights. . *

                                                    . 2.                Recent corrected ' certifications being received are completely

acceptabla. .

3.

Fabrication and erectibn operatio'ns of forming, welding galvanizing, etc. have not indicated any problends which would indicate that the

                                          ,                          . material has any significantly different properties.

4. The inherent design conservatisms may be able to accept any minor

        ,                                                               descrepancies.

5. The limited number of a'ffected material certifications identified to date. - - ~

                                                                                                                                                                                                                                                  .~
                                       '     The Zack Company will keep Baldwin Associates fully informed of developments prior to any final reports being issued.                                                                                                                                        '

We thank you for your cooperation and support in this matter and should you have any questions or problems, please do not hesitate to contact us at (312) 242-3434. -

                                                                                                                                                           .                                s' Very truly yours, THE ZACK COMPANY                                                                                            --      ,                                 .

d d' az d m - David E. Calkins, , . .

                                            -Quality Assurance Manager                                                                                               -
                               .             DEC/br.                              -

cca C.E. DeZuf.el J.C. DeZutal . C.L. Eichstaedt, Jr. *

T. Packy B. LaRoache .

                                                                                                                                                                                  'y                     ,                                                      if
                        '                    ~                                                                                                                                                       '

G. Bennett Browne, Supt. Subcontracts (BA) .

3. Smart, BA/QA

Q.A. Chicago - *

                                                            .Q. A.-Clinton -                                   .

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              ' 1. CAIE inIMist.H . #l'I *II'                                                        .

2. I'AT( 9. '4i . 'll .. .. 9. . . .

3. PHLif ECT . 12.1 L.as.1w u 4;t.1.I4 4.. . 4. I.' 8 'l*T I ON U ** i . * 8. .' I ' ' " ' O I I I C'?

s

5. Al.Tiota Aus tt: NEE' .A N2. 't J u..h! ad. _ 6. tciti:ssist.Eu n.cl*!J. TION DATE gy,jo ,

N e I'

7. DESCRIt* TION: an . .va 1 i, , e I un . . r r t ,j , , , , , , , v..,,j,,., .. ,..:i c...,:.-

                                                                                                                                                                .g,                  y rm,vem.a , h<..           rn n ..a ... . .iim ,m              me1.... .

1. i n coi.. .t e ,. c..+ .,iz,1. ,,.. e . , c, . a . , .

2. Incorrect m.Lerial tiut s ug4,rts.

3. Improperly modified test. ru1>cr t s .

4. Possibility of individual (s) wil.hin The ".ack Cosnt.any improperly .

u. 4mp443 wuss s wi.v a u.

8. RECOMMENDED / DIRECTED CORRECTIVE ACTION (s): Tn o ra s. r en a n e n % ; ,,. *wn .,+mm*

and the seeriousnens of these deficinr>< ir u *ka rn 1 1 n. ,4

                                                                                                                                                  ,, 4 , m o e + t r = * < n n .- e ., A evaluations shall be conducted:                                                       *
                                                                                                                     .                  f

1. The O.A.. Mar. will direct a e, am n r rnne (4) anc, man

r. w =nA ~m (1) MPOAD Reo. 'to review all material *eer r.-n**e fn- = ce 3-a c.- snA comoleteness by 10/30/81. (enneiEmA_ ena ewn n C[, * .

9. QA MANAGER /DATE / 10 .dg N{/DgTp ,

11. ACTION TAKEN: .

P J s

12. ACTION ASSIGNEE /DATE -

                                                    \/                                                                                                   .

i ! 13.. VERIFICATION: - h

14. ACCEPTED / REJECTED

15. QA MANAGER /DATE 16. PPISIDENT/DATE

               \                                                                                                                                                     .
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1 or T. rit- it. p.: t : r.ir al. . e . il . .t'

                                                                                                                       ! iii.: n li rii 1 w il 1,u vutatled with the rus.p stIvo asus.pllit.                                        ;*.;ln .l.a 1.:i1 e .ssiig I ..t i s,n 10/10/81.
                                 .t . Indi vielu.il (u)                      inig el is .s t uit a r suppl Ic.r tu..t                       s eq= n t.n wi 11 1,. ..r.g :cI ed c.f is .pe opo e iy niud i fyi ng                                                                      -

invest iy.it. I .ind tise evl.lence obt ai ned wi l l 1.o f .t w...1.! I ce Tlic :* . :k t'..u.t .iny t> i. .ident

                                        +41'1'2 OI.r ies te di scipl i a...                                                                                                                     for

y ... t ion.

4 Upon cornpletion of si.at'ee i.nl t.tist :.: tort s .. v i ew a l l t.eches ical discropinef for evtaluation. eu .will 1,o f el. ne i fied .ind f . w..:.1 d to naldwin Associates e . - . . ~

5. Upon cumpletion of Act. ions 1 t.hsu 4,. Imh! win Au:.oelates will be

                                  - - contact'ed               and report should be initiat ed.       a      detonnincit               ion     i  f   a  pun.sil,1c                lucrH50.55(o)/10CFR21 e

f e - h & O # 4 e 4

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                                                           ]. .           ,            POSITION CHARACTERIZATION OUTLINE.

I. N .. TIT.LE . '; _. .. - i-

                                                                                                                         ~                                                                       -

II. DESCRIPTION OF DUTIES ,'**

                                                                                                                                                                                                                                                                     ,           N x
          ,                     III. RESPONSIBILITIES                                                  ,

I

        . ..                      IV.      EXPECTATIONS V. QUALI.F,ICATIONS
                                                                                                                      ,,              (,
     . -                          VI.      REMUNERATION / BENEFITS                                                                                                                                                                                                              .
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 !:..                                 I. TITLES .;,,,l ~.*e                                -

Manager-Record Systems, Quality Assurance,'

    "; '.          .~2                             "9'...                                                                                                                                                                                                                                      .
       ,,1 .

Zack Co.,-Chicago and subsidiary client sites. i- II. DESCRIPTI'ON OF DUTIES: To initiate arid promulgate an effective records 7' E.' -"

                                                                                                                      , system for TheJack Co. and applicable clients
                                                  " , T'                                                            ~ in the realm of nuclear-related manufacturer-vend'or-client field.
                 .                                  ..t..                                                                                                                                                                      *
             ~.-                                                                  .
                                                                                                                                                                                                             ~                                                                                      -
                                                . .-:.7.%. :.
     ~                                                                                                                                                                    .

. 'III. RESPONSIBILITIES: *Directly interface with the Quality Assurance.

v ,.

                                                             ,f ,
                                                                                                                 ,      Manager and related personnel in order to carry
                                                       .                                                                out the expected duties.

IV. EXPECTATIONS: .

To be concerned with and be knowledgeable ir$ all

                                                                                                 ' ~.
                                                "'4                                                                I aspects of procurement, manufacturing, vendor 4 .:
                                                                                                                     ,' identity, fabrication, sub-contracting and client                                                                                                                    .

acceptance in the nuclear industry. To become .

                                                    .; q.                                        *              -
                                                                                                                .      knowledgeable and proficient in Federal Regulatory

Statutes as they relate to the commercial / nuclear

                                                  ,.f.,                   ,

1

                                                ~~.~.                                                                  industry.                                                   -

\ . V. ' QUALIFICATIONS: - GeEeralist with strong background in written and

                                                                                                                 or&1 con.munic ation skills BA/BS;'MA/MS' desirable
                                                                                             ~~

but not mandatory. Ability to manifest leadership functions and substantial people control / orientation ' background essential.' . l' VI. 'RDIUNERATION/ BENEFITS: 35-45K depending on referential background and ninety-day trial period. Company paid expenses when applicable. Company paid life and medical 1 insurance, five (5) sick days, six (6) paid ~ ,

                                                                                                                    -holidays.                                                                                                                                    '

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QUALITY ASSURANCE TRAINING REPdRT

1. DATE - ochh N O

THE BELOW LISTED INDIVIOUAL(S) RECEIVED QUALITY ASSURANCE TRAINING IN

                                   . ACCORDANCE WITH THE ZACK COMPANY QUALITY ASSURANCE TR AINING PROGRAM
                                                         \                         .

NAME INITIAL. POSITION

2. b'B'"I ~I~ *u8N'^

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11. ,

DESCRIPTION OF TRAINING SESSION CONDUCTED

12. Ne b ' ' "vt.ae*=- N '"t1= C M C'" m** - "To "'NEw' N '*3 0 #~

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Q.A. TRAINING INSTRUCTOR l CO. G.A. MA**AOER FILE-SITE. OC DEPARTMENT .

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                                                                 .,.                                      CUSTOM METAL FABRICATION
                                                     .~ r October 9,1981 Comonwealth Edison Co.

LaSalle County Nuclear Station Rural Route #1, Box 220, 2601 N. 21st Road, Marseilles, IL 61341 ~ Attn: Mr. William Donaldson ,

                  ,                                  site Manager RE: Documentation Discrepancies
                              .      Gentlemen; Enclosed is an interim report on the. results obtained to date in the review Project.                           of the material certifications for the LaSalle It is important to note in reviewing this rapor , that the defici-encies shown for each purchase order have only been recorded.

This report does not address the corrective action being initiated with the suppliers.to obtain corrected certifications. At the present rate of review, it is anticipated that The Zack

                               ,e October Company              26, will 1981. be ready to present a final report, on or before This should allow ample time to advise the NRC that       the it's applicability. possible           10CFR50.55        (e) should be withdrawn or to confirm'             "

i , Should you have any questions or problems concerning this. report, l please do not hesitate to contact me at (312) 242-3434.*

very truly yours, THE ZACK COMPANY

David E. Calkins, Manager Quality Assurance DEC/br Encl: cc: L.J. Burke, Site Project Supt. T, Quaka, QA J. Dearbeck (CECO) C.Z. DeZutel J.C. DeSutel C.L. Eichstaedt, Jr. l C. Bar.mgardner Q.A. Chicago /LaSalle Site i s

FOUNDED TO SOLVE THE UMCUE METAL . F? cmt'w=' **--*~ - ' -- -

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4600 W.12TH PLACE
CHCAGO(CICERO)ILt.60650 t 312/242-3434 401 WESTERN . 'FUNT MCHIGAN 48506
313/736 2040' 7 .~.. _

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thed E% %L. co. CUSTOM METAL FABRICATI N

       ..                                 %.#                                                 October 5, 1981 To:        Dave Calkin.s                                                                    ,

From: R.A. Perry

Subject:

. Interim Report - Documentation Review Results-LaSalle. Station 6nly, as of October 5, 1981 Su=marv:

The attached sheets tabulate the results of subject review. Approximately 84% 374 reviewed, 445 total (from LaSalle site) packages have been located and reviewed. All packages have been attached in individualbinders and filed in the fire resistant cabinets in accordance with the requirements of the draft work instruction for " Control Content a'nd-Maintenance of QA Purchase Order / Certified Material Test Report Files". ' . The tabulation lists " packages". .The number of certifications

 '~              . in each package. varies between one and twenty. For the purpose of categorization-only the more major discrepancy in each package has been tabulated.

( Discussion The~results of tile review have been categorized as follows: Clerical Errors - Lack of reference to " ASTM" revis, ion year, , or complete lackof standard designation. l Sicnature missing -lack of a written, signature. ,,. l Signature Errors - Typed signature and handwritten ' signature I or initials are not identical. 1 Chem / Mech Test Data - Chemical analysis and/or mechanical test data missing and/or not in accordance with ASTM standard requirements. - U.S. Steel Letter - Indicates P.O. 's listed in U.S. Steel Co. letter to Zack Co'mpany stating that material on P.O. 's were _not processed thru U.S. Steel V & T program. Letter dated

                     -9/21/81.
      ~~~~

Missing Certifications - Self explanatory. Certain packages lack certification for all, or for only certain items. (Major-l ity appear to be missing Reliaboe Galvanizing Co certs) . C of C o_n_ly, - Packages containing a certificate of compliance ' ~Jf. lNo test data) ! ..--+ ._ ..-~ __j. , ,,

*'

pc.go '2 october 5, 1981 Alterations - Apparent alteration of certification by typed '

or hand.,ritten additions. - Stickers - Gumed labels applied to certifications or certi-Tication cover sheets. These typed and signed to indicate compliance with ASTM standards authenticity of the signatures ' is questionable. w . 4

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I o m l W: D.tve Calkitin . . l FlKel: II. 14cCrano 1 l Sk81 JIX*T: Inturim Ihtport - Dck:ument. t ion R. view rotsult s:, . Clinton Statit.as ondy. S'.1:4 malty: The attached sheetu tabulato th arsultn of subject revicu. Approximate-ly 25 P.O./ccrt packages lit.ttxl on the Clinton liut (telecopy from site) remain to be located / reviewed. .

      !                            l                                                    *
     .'                      DISCUSSION:

The results of the review haves b.en categorized as follows: , Clerical Errors - Lack of reference to .STM"; rcydsion year, or any ASTM Standard. ., Signature Missing - Lack of written sign.iture. i Signature Erroi - Typed signature and written' signaturc/ initial not iden-

tical.

                                    ' Chemical / Mechanical Test Data - Chemical analysis and/or mechanical test

data missing or not in accordance with ASTM standard requirements,.

Alterations - Apparent of certification by typed or handwritte. additions. .. Stickers - Gummed labels applied to certifications,or cover sheets. These typed and signed to indicate compliance with ASTH standards (" ASTM"-year) -

            .                        Authenticity of the' signatures is questionable.

Missing Certifications - Self explanatory. Certain packages lack certi-fication for all, or for only certain items. ! U.S. Steel

Letter - Indicates P.O.'s listed in U.S. Steel Company letter to Zack Company dated September 21, 1981 indicating that such P.O.'s were not processed thru U.S. Steel's v & T program. .

{ ,. .

            ,                        Volded Purchhse Order - P.O. number (control number) listed 'ny Clinton site as appearing on traveler but voided in Zack Company filas.
                   '                 Other - Various discrepancies - P.O. :nissing (2) and cort reference grade of steel not listed in ASTM standard - (1) .

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ML20023D035: Difference between revisions

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Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities
Person / Time
ML20023D035
Site:	Clinton, Midland, LaSalle, 05000000
Issue date:	07/26/1982
From:	Arlette Howard AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20023A480	List: ML20023D030 ML20023D031 ML20023D032 ML20023D033 ML20023D034 ML20023D035 ML20023D036 ML20023D038 ML20023D039 ML20023D042 ML20023D046 ML20023D055 ML20023D066 ML20023D138 ML20023D140 ML20023D145 ML20023D146 ML20023D147 ML20023D172 ML20023D181 ML20023D188 ML20023D191 ML20023D196 ML20023D209 ML20023D213 ML20023D214
References
FOIA-82-366 NUDOCS 8305190108
Download: ML20023D035 (55)
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ML20023D035: Difference between revisions

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