ML20198D546

Insp Repts 50-456/85-21 & 50-457/85-22 on 850430-0905. Violation Noted:Failure to Follow Procedures Re Qualifications of QC Supervisors & Failure to Provide Documentation of Activities Affecting Quality

ML20198D546
Person / Time
Site:	Braidwood
Issue date:	10/29/1985
From:	Mendez R, Weister J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198D518	List: ML20198D514 ML20198D528 ML20198D546
References
50-456-85-21, 50-457-85-22, NUDOCS 8511120370
Download: ML20198D546 (25)

See also: IR 05000430/2009005

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/85021(DRS); 50-457/85022(DRS)

Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133

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Licensee: Commonwealth Edison Company '

P.O. Box 767

Chicago, IL 60690

j Facility Name: Braidwood Station, Units 1 and 2

Inspection At: Braidwood Site, Braidwood, IL

Inspection Conducted: April 30-May 3, May 7-10, June 24-25,

! . August 28-30, and September 5, 1985

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l f b'xAb?<

] Inspectors: R. Mendez - /OS 9[ff

Date

J. l(e 'U /

/O - > 9-Ks

Date

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William (s, Y Chief "

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Approved By: .C.

Plant Systems Section

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Date

29-EA~

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Inspection Summary

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Inspection on April 30 through September 5, 1985 (Report No. 50-456/85021(DRS);

50-457/85022(DRS))

Areas Inspected: Special, unannounced inspection of allegations; and licensee

, actions on allegations. The inspection involved a total of 152 inspector-hours

by two NRC inspectors including 18 inspector-hours of in-office inspection and

30 inspector-hours during off-shifts.

! Results: Two violations were identified (failure to follow procedures -

i~ Paragraph 2.a(2); failure to provide documentation of activities affecting

quality - Paragraph 2.d(4)). f

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8511120370 851104

PDR ADOCK 05000456

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DETAILS

1. Persons Contacted

Commonwealth Edison Company (CECO)

• M. J. Wallace, Project Manager

+D. L. Shamblin, Project Construction Superintendent

+C. W. Shroeder, Project Licensing and Compliance Superintendent

1. T. E. Quaka, QA Superintendent

• R. M. Preston, Director-Quality First

1. E. F. Wilmere, QA Supervisor

+E. E. Fitzpatrick, Assistant Manager QA

1. G. E. Groth, Assistant Construction Supervisor

+L. M. Kline, Project Licensing and Compliance Supervisor

1. C. Mennecke, Project Construction Department Supervisor

• W. E. Vahle, Project Field Engineering Manager

1. E. Netzel, QA Supervisor, Electrical

+J. Gieseker, Project Field Engineer

L. K. Comstock and Company (LKC)

1. R. Simms, QA Supervisor

• J. J. Klena, Project Engineer

+I. F. Dewald, QC Manager

The inspector also contacted and interviewed other licensee and

co'1 tractor personnel during this inspection.

• Denotes those personnel attending the May 10, 1985, exit interview.

1. Denotes those personnel attending the August 30, 1985, exit interview.

+ Denotes those personnel attending the May 10 and August 30, 1985,

exit interviews.

2. Followup on Allegations

On March 29, 1985, 24 L. K. Comstock (LKC) QC inspectors went to the NRC

Resident Inspectors' office at Braidwood Station with allegations

concerning quality issues. These allegations (NRC Tracking

No. RIII-85-A-0072) were subsequently sent by NRC Region III to the

licensee for its review and resolution. This action was acceptable to

the licensee and the LKC inspectors.

Prior to going to the NRC Resident Inspectors' office, some of the QC

inspectors had expressed some concerns to NRC Region III regarding LKC's

QA program. These concerns were received by Region III and tracked as

allegation numbers RIII-85-A-0062, RIII-85-A-0067 and RIII-85-A-0068.

Several of those concerns were similar to the allegations (RIII-85-A-0072)

received on March 29, 1985.

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During this inspection, discussions were held with LKC personnel

including 16 randomly selected QC inspectors and other personnel to

review the LKC inspectors' concerns and allegations. The inspectors

interviews included some of the inspectors who provided the allegations

and concerns. The NRC inspector also reviewed the licensee's actions

regarding the issues expressed by the QC inspectors as documented in

allegation No. RIII-85-A-0072. The allegations and concerns expressed

by LKC inspectors are addressed below in the order they were received by

the Regional Office.

l a. (Closed) Allegation (RIII-85 + 0062)

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On March 13, 1985, the Senior Resident Inspector received information

regarding lack of qualification of LKC personnel.

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l (1) Concern

' The alleger cited an example where one QC supervisor was not

certified as a Level II inspector in the areas of cable tray,  ;

concrete expansion anchors, and receipt inspection. The alleger

1 also named two other QC supervisors who were not certified in

! the areas they supervised. The alleger cited LVC Procedure

4.1.2, Section 1.21, which states in part, "Qua. ity Control

Supervisor...shall be trained and knowledgeable in the assigned

areas of responsibility and certified to Level II capability in

those areas."

NRC Review

During interviews of the 16 randomly selected LKC QC inspectors,

many expressed the opinion that almost all of the QC supervisors

were neither qualified nor certified as Level.IIs in the areas they

supervised. The LKC inspectors felt that they could not depend

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on the QC supervisors to answer questions in the areas where QC

inspectors were uncertain of QC related matters.

l Deficiencies in the LKC QC supervisors' certifications had been

. previously identified in the licensee's Braidwood QA Audit

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Report #QA-20-84-556 dated December 19, 1984. The audit

report identified certain LKC QC supervisors as not having i

i sufficient work experience. The report also concluded that . '

some supervisors lacked certification as Level II inspectors in

all the areas they supervised. The audit report finding

required that. training and experience be provided as appropriate

and that supervisors be knowledgeable in the assigned areas of

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responsibility. LKC Procedure 4.1.2, Revision C, was reworded

such that a QC supervisor is required to obtain certification

as a Level II inspector after they attain the position of QC

3 supervisor. However, supervisors do not perform Level II

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reviews prior to receiving certification

j in their areas as specified by the governing procedures and

regulations. Formerly, the procedure required that the

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j employee be a Level II inspector before becoming a QC supervisor.

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This Braidwood audit finding had not been closed out and

requires that the subject supervisors receive the required

training to become certified Level II inspectors in the areas

they supervise.

Conclusion

The allegation regarding supervisor qualification was

substantiated in that some of the QC supervisors were not

certified as Level II inspectors in all areas they supervised.

While this lack of certification is not contrary to any explicit

NRC certification requirement, it is contrary to the licensee's

procedure and therefore 10 CFR 50, Appendix B, Criterion V.

The Ceco Braidwood Site QA had identified the lack of qualifi-

cation and/or certification of Supervisors in an audit report

on December 19, 1984, before the allegation was made on

March 29, 1985, and adequate corrective actions had been

initiated. Therefore, for enforcement purposes this is

considered to be a licensee identified item.

(2) Concern

The alleger cited as an example two QC inspectors who were

selected as lead inspectors but were not qualified and were

therefore, unable to perform their assigned duties adequately.

The alleger stated that one of the lead inspectors did not have

any qualifications and that the second lead inspector had

qualifications only in receipt inspections. (During the

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onsite interviews of the 16 randomly selected QC inspectors,

an additional six lead QC inspectors were alleged to be

improperly oualified.) The alleger cited LKC Procedure 4.1.2,

Section 1.22, which he indicated stated that "QC inspectors be

certified as Level II's in the area the inspector has lead

responsibility".

NRC Review

The inspector reviewed the qualification records of the eight

LKC lead QC Level II inspectors who were alleged to have less

than the required qualifications / experience. The results of

the review indicated that the inspectors had the required

background and training with the exception of those mentioned

below:

There was one instance where an individual (this QC

inspector was alleged to not have any certifications) was

assigned as a lead inspector in concrete expansion anchors

(CEAs) on March 10, 1985, but did not receive his Level II

certification until March 21, 1985, due to administrative

delays. This individual had passed the written and

practical inspection tests for CEAs on March 5,1985, and

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was previously certified as a Level II CEA inspector at

another site. Although assigning this individual as a

lead before being certified as a Level II violated

procedures, a review of about 2,000 CEA travelers / inspection

reports completed before March 21, 1985, indicated that

this QC inspector did not sign / approve any CEA quality

documents.

A QC inspector was alleged to have been certified only

for receipt inspections but was a lead inspector in other

areas for which he was not certified. This inspector

was assigned as a lead inspector in concrete expansion

anchors (CEAs) and calibration from August 1984 until

March 1985. The effective revision of LKC Procedure

4.1.2, " Position Del.ineation," during the period August

1984 to March 1985 was Revision B that stated, in part,

" Quality Control Lead Inspector. .. is responsible for

immediate direction of fellow QC inspectors in their

designated area (s) (i.e., cable pulling, welding configur-

ation, etc.)...must ba certified Level II in designated

area (s)...." While the individual was certified for hanger

configuration, there was no documented evidence that this

lead inspector was certified in CEAs and calibration

during the period August 1984 to March 1985.

LKC personnel stated that although the QC inspector was

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assigned as a " lead" in CEAs and calibration, their review

of a sample of calibration and CEA documentation did not

reveal any quality documents where the inspector had signed

as a Level II reviewer.

ANSI N45.2.6-1978 states that personnel who are assigned

the responsibility and authority to evaluate the validity

and acceptability of inspection, examination and testing

results shall be certified as Level II. LKC's " Master

Qualification List" classifies 11 functional areas for

Level II capability, one of which is calibration.

However, the NRC inspector determined that, contrary

to LKC's belief that the QC inspector did not sign any

cuality documents, on May 25, 1984, this QC inspector

signed two " Variable Calibration Records" under the column

" Level II Review" for torque wrenches as A-531 and A-828,

although the QC inspector was not certified in calibration.

A second QC inspector who was designated as lead inspector

in calibration from March 1985 to May 1985 was not certified

as a Level II calibracion inspector. The NRC inspector

determined during the records review that this QC inspector

did not sign quality records in areas where he was not

certified. This issue was identified by the NRC inspector.

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Conclusion

This allegation was substantiated. There was one example where

due to an administrative error, an individual became a lead

inspector in a specified area without first being certified as

a Level II inspector in violation of the LKC procedure however,

there was no evidence that this individual signed / approved any

quality documents in that area before he was formally certified.

Two other lead inspectors were not certified Level II in

violation of the LKC procedure. Additionally, contrary to

ANSI N45.2.6 one of these QC inspectors signed two calibration

inspection checklists under Level II review although he was not

a certified Level II in calibration. These failures of the

licensee to assure that activities affecting quality be

accomplished in accordance with instructions and procedures

is a violation of 10 CFR 50, Appendix B, Criterion V

(456/85021-01; 457/85022-01).

b. (0 pen) Allegation (RIII-85-A-0067)

This allegation consisted of three parts, two of which were reviewed

by the NRC inspector during this inspection. The third issue

involving welding will be addressed during a separate NRC inspection.

(1) Concern

One part of the allegation related to the alleger who was an

LKC QC inspector being reprimanded for absenteeism and poor

work performance. The alleger felt that LKC quality control

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was under production pressure and that his reprimand was based

on his failure to meet quotas set by LKC management.

NRC Review

The alleger had been given verbal warnings regarding excessive

absences on September 27, 1984, and January 27, 1985, and a

written warning on February 20, 1985. On March 19, 1985, the

alleger received a second written warning for absenteeism and

poor work performance. The LKC action on the alleger's absenteeism

was prompted by the alleger taking a total of 16 sick / personal

days from June 1, 1984, through March 18, 1985. From

January 28, 1985, through March 19, 1985, the alleger had

performed an average of 1.6 inspections per day while the

average for his particular speciality (welding inspections) was

9.3 inspections per day.

With respect to the allegation regarding production pressure to

meet quotas, the inspector interviewed the alleger and other

selected QC inspectors. All of the QC inspectors stated that

LKC management appeared to be more interested in production

rather than the quality of the inspections. Some of the

inspectors indicated that LKC management was probably concerned

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about losing the electrical contract with the licensee.

Additionally, it was stated by the QC inspectors that one of

the QC Supervisors vigorously conveyed the message that manage-

ment was more interested in production rather than quality by

pressuring QC inspectors to perform more inspections. However,

none of the LKC inspectors indicated that they would accept

discrepant work under any conditions. LKC management and the

licensee met with LKC QC personnel on May 13, 1985, to resolve

the QC inspectors' concerns and reaffirm the licensee's and

LKC's commitment to quality and to discuss improving communica-

tion between LKC's management and their inspectors.

Conclusion

This portion of the allegation could not be substantiated.

Some of the QC inspectors expressed opinions about a QC

supervisor who projected a production oriented attitude that

some QC inspectors felt would affect quality; however, there

was no evidence that this led to procedure violations or to

LKC inspectors accepting discrepant work.

(2) Concern

One part of the allegation was that QC inspectors were not

being properly trained in conduit specifications. The

individual cited Procedure 4.3.13, " Installation of Junction

Box and Equipment", which referenced the conduit specifications

for grounding of junction boxes.

NRC Review

Section 3.5.6.1 of LKC Procedure 4.3.13, states that, " Junction

boxes...will be grounded in accordance with the conduit specifi-

cations." Procedure 4.3.13 also references S&L Standards and

approved drawings. Currently, QC inspectors who are certified

Level II QC inspectors in the area of " Equipment / Junction Box

Installation" are required to have knowledge of Procedure

4.3.13. A review of training records of 5 of the 12 QC Level

II conduit inspectors indicated that they attended lectures

and demonstrations on Procedure 4.3.13. Additionally, records

indicated that the QC inspectors had been trained to Specifica-

tion L-2790 and S&L drawings 20E-0-3391A and 20E-0-30000 which

are the specifications for grounding.

During the discussions with the 16 LKC inspectors addressed

in Paragraph 2.a above, none of the inspectors could provide

an example where junction boxes were not grounded per the

applicable conduit drawing or specification.

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Conclusion

This portion of the allegation could not be substantiated.

Installation Procedure 4.3.13 for junction boxes references

conduit grounding and it appeared QC inspectors were being

trained in the provisions of the procedure. There were no

documented examples of failure to ground conduit per the

applicable specification or drawing.

c. (Closed) Allegation (RIII-85-A-0068)

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Three allegations by LKC QC inspectors were received by the Region

on March 20, 1985. The allegations are addressed below:

(1) Concern

The LKC QC inspectors stated that the pressure on quality

control inspectors to perform a large number of electrical

inspections would affect the motivation of the QC inspectors

and their ability to identify all safety issues. The

individuals stated that LKC management was concerned about

production and not quality and that a continued " production

push" by management would necessitate a complete re-inspection

effort by LKC.

NRC Review

During discussions with the QC inspectors, none indicated

they would accept discrepant work. Although, the general

perception among QC inspectors was that LKC management pushed

production, no discrepant quality issues were identified to

the NRC inspector (Al;o see Allegation RIII-85-A-0067 and

RIII-85-A-0072). A review of quality documents such as

travelers and inspection reports in view of LKC's alleged

production push revealed no programmatic problems.

Conclusion

This allegation could not be substantiated.

(2) Concern

A QC inspector alleged that he found a structural steel base

metal reduction problem in the auxiliary building. The

individual said he told the lead inspector and that the lead

responded, "Do your electrical assignments." The individual

said he told his supervisor about his concern and that the

supervisor responded, " Keep up production or I'll take you off

of overtime." The individual did not think this problem was

being handled in accordance with applicable procedures and he

believed he was being pressured into overlooking problems by

having his overtime taken away.

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NRC Review

The alleger's statements based on NRC examination and

discussion have not been corroborated by the lead or the

supervisor during interviews. That is, there is no corroboration

that the alleger was told not to concern himself with the base

metal reduction problem and that he would be taken off overtime.

The alleger had originally identified the base metal reduction

problem on December 8, 1984, and documanted the discrepancy in

a memo to the QC manager. On December 18, 1984, the QC

manager sent the memo through the proper channels to the

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G. K. Newberg, the civil / structural contractor, for resolution.

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The alleger also referred the base metal reduction problem to

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a LKC Field Engineer. At the time the alleger brought the

base metal reduction concern to the LKC Field Engineer, LKC's

procedures and specifications did not allow them to repair ,

structural steel. Subsequently, S&L Specification L-2790 was

changed to allow LKC to repair or rework base metal reduction

problems on structural steel when caused by electrical rework.

This change was incorporated per Amendment 46 and Engineering

Change Notice 25862 into S&L Specification L-2790.

On July 30, 1985, Inspection Correction Report (ICR) No. 10991

was issued to correct the base metal reduction problem

identified by the alleger.

Conclusion

This allegation could not be substantiated. Based upon review

of documentation relative to this allegation, the inspector

determined that the base metal reduction issue was properly

referred to the responsible contractor for disposition. With

respect to the alleged threat that the alleger's overtime would

be taken away, his overtime has not been taken away based on

discussions with the alleger.

(3) Concern

The LKC QC inspectors alleged that many new electrical inspectors

are being qualified and certified in the areas of welding and

configuration in one week. The allegers felt that it was

impossible to be adequately knowledgeable in all of the detailed

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reference tables and drawings necessary to perform the

inspections in one week, and that the quality of inspections

by inspectors qualified in one week was questionable.

NRC Review

Many of the LKC QC inspectors interviewed expressed concern

about other inspectors being certified expeditiously. Some of

the inspectors indicated that they had knowledge of unqualified

inspectors and supervisors (This is also discussed in more

detail in Paragraph 2 for lead inspectors.)

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l The NRC inspector reviewed the certification and qualifications  !

of 10 new LKC QC welding inspectorc. (This group does not l

include the eight lead inspectors reviewed in Allegation

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RIII-85-A-0062.) The review included the background experience

as a QC inspector and/or as a craftsman under a quality program

at previous places of employment, and the results of written  !

i and practicci exams prior to certification as a QC Level II I

inspector for LKC. The records indicated that nine of. ten

new inspectors had the proper background and training to be

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certified Level IIs per ANSI N45.2.6 and LKC Procedure 4.1.3,

" Qualification and Training of QC Personnel."

One QC inspector did not have the required experience for  !

certification as a welding inspector. This individual was hired

i on November 21, 1983, and was certified as a Level II welding

inspector on January 4, 1984. This person's background was [

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electrical and he had no prior weld inspection experience. '

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His lack of qualification was identified by the licensee's

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Braidwood QA surveillance in report no. 3372 on February 5,  !

, 1984. Initially, Braidwood QA found problems with the ,

i certification of this individual since the person's certifica-  !

i tion package only contained documentation of previous electrical

! experience. There was no docun.entation of welding or welding ,

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inspection experience. Braidwood site QA accepted the

individual's certification based on the person's background as i

j a QC supervisor in the use of vernier calipers, scales and ,

j torque wrenches. Final acceptance by Braidwood Site QA was

i accomplished by including the individual's welding experience  ;

i acquired as a Level II welding inspector at Braidwood. The l

!' use of his experience acquired while apparently improperly i

certified as a Level II welding inspector requires further

j NRC examination. This significant issue is that the

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acceptability of his inspe<  ;

his certification /qualifice,. cian tion was

activity during theremains

questionable periodtowhen be '

assessed and is considered an unresolved item (456/85021-02;

457/85022-02).

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Conclusion

This allegation was partially substantiated in that one

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instance was identified where a new LKC inspector with no l

previcus experience either as a craftsman or as a QC inspector ,

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in welding became a Level II welding inspector within six '

weeks of being hired by LKC.

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d. (Closed) Allegation (RIII 85-A-0072)

On March 29, 1985, six LKC electrical quality control inspectors

presented allegations to the Braidwood NRC resident inspectors

regarding the quality of QC inspections, QC supervisor qualifications,

intimidation and harassment of QC inspectors, and closing noncon-

formances without field verification. A second meeting between the

NRC resident inspectors and 24 LKC QC inspectors was held later in

the day. The concerns as presented to the NRC resident inspectors

were submitted to the licensee for resolution. The licensee agreed

to interview the LKC inspectors and attempt to resolve their concerns.

In addition to meeting with individual LKC inspectors, the licensee

removed a QC supervisor from his position until the allegations were

resolved and scheduled a meeting between.the licensee and LKC QA/QC

and management personnel to re-emphasize the licensee's QA policies

and commitments.

A summary of the LKC inspectors' concerns as expressed to the

licensee and the licensee's subsequent actions are documented in

Commonwealth Edison's Quality First Group as Braidwood Record of

Concerns numbers QF-85-1188, 1229, and 2026. On April 25, 1985, the

licensee completed its reviews of the LKC QC inspectors' concerns

and allegations. The concerns and allegations of the QC inspectors

are addressed below.

(1) Concern

A QC inspector alleged that "L. K. Comstock is asserting the

quantity of inspections rather than the inspection quality.

Therefore, the quality of the L. K. Comstock inspections is

suffering."

Licensee Review

The licensee found that some of the QC inspectors felt that

the QC manager pushed production after the Construction Manager

let it be known that inspections had to be done. However, the

licensee also determined from the LKC inspectors that quality

was appropriately emphasized. The LKC QC inspectors indicated

that one QC supervisor vigorously pushed inspections but if QC

inspectors questioned quality the QC supervisor would refer to

the procedures so that quality was not sacrificed. In certain

instances the licensee determined that this supervisor had been

unduly abrasive in his professional relationships with the QC

inspectors.

NRC Review

The NRC inspector examined licensee trend analyses of quality

assurance deficiencies identified during audits and surveillances

of LKC activities. None of the analyses indicated that the

quality of the LKC quality control inspections had deteriorated

as a result of the alleged emphasis on increased inspector

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productivity in that the percentage of inspection findings per

report had remained about the same as before. In addition,

review of three of LKC's quarterly trend analysis reports showed

no adverse trends in the quality of inspections as evidenced by

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no observed decline in the numbers of inspection findings.

Review of quality control manning tables revealed that the

contractor increased the number of inspectors as workload

increased. For the month preceding receipt of this allegation

the inspector compared the number of inspections performed and

the number of inspectors in the field'and determined the

average inspector performed approximately 21 inspections per

week which in the NRC inspector's view was not excessive." None

of the inspectors interviewed stated'that they had persJnally f

performed inspections where they had asserted quantity rather

than quality. -

Conclusion

Based on review of trend analyses, personnel manning tables,

inspection records and interviews with quality control

inspectors, this allegation could not be substantiated since _ _

there was no evidence that production pressure affected the "

quality of inspections.

(2) Concern

QC inspectors alleged that "a Comstock QC supervisor was not

qualified for his position, as he was not certified in all

of the inspection areas which he supervised." m -

Licensee Review

The licensee investigation identified one instance wherein a

LKC QC inspector related an incident in which a QC supervisor

wanted an NCR written in a discipline where he lacked

certification. The licensee found that the LKC inspector

refused to write the NCR until he went out and observed the

situation in the field at which time the QC inspector agreed

to write the NCR. The licensee's review also included the

adverse audit finding in which site QA identified the LKC

supervisors who did not hold certifications in all the areas

they supervise.

NRC Review

Neither NRC regulations nor ANSI Standards require quality

control supervisors to be certified in all inspection areas

they supervise. However, this is required by LKC procedures.

The NRC inspectors identified an instance where a supervisor /

lead inspector did not have the certifications required by

procedures. This finding is described in the NRC Review of

Allegation RIII-85-A-0062 above. < .

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Conclusions

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Based on NRC review of personnel certifications this allegation

N is substantiated in that one individual was not certified in

all areas in which he supervised inspectors. See the conclusion

for. Allegation RIII-85-A-0062 above for further explanation.

(3) Concern-

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QC inspectors alleged that one QC supervisor was constantly

intimidating / harassing the LKC inspectors to sign off NCRs and

ICRs.

Licensee Review

The licensee investigation substantiated the QC inspectors'

allegations against the QC supervisor. The licensee stated

that on March 31, 1985, LKC indefinitely suspended the subject

QC supervisor. On April 2, 1985, LKC concluded that the

'N accused QC supervisor should be removed from the job site, the

licensee concurred and the QC supervisor was removed.

j NRC Review

l The NRC inspectors interviewed QC inspectors, including the

! allegers. The QC inspectors each stated that the supervisor

had an abrasive and aggressive personality and was very quick

to lose his temper when inspectors' findings or interpretations

\ were counter to his interpretations of procedures or require-

s

ments. At that time, it was alleged that he would become

.; abusive and berate and threaten the inspector with dismissal;

however, none of the inspectors could remember an instance

where an inspector had actually been dismissed nor did any

inspector remember an instance when he had signed off an

inspection as a result of pressure from his supervisor. Some

of the individuals interviewed stated that some of the

-inspectors would goad the supervisor into losing his temper

since they enjoyed his outbursts.

The supervisor was dismissed as a result of his ordering a

QC inspector to close out an inspection report before the

inspector received the documentation authorizing the closeout

and final disposition. The disposition of the inspection had

been reviewed by engineering and the documentation had been

sent to, but not yet received by, the QC inspector.

The licensee has initiated a training program for LKC QC

control supervisors in basic management techniques to prevent

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a recurrence of the intimidation / harassment issue.

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-_ . _ - _ - _ _ _ _ _ _ _ _ _ - - _ . ._ _ - _ _ _ _ - - _____ __ _ _- - -____ -___-__- ______-_-_ - __ ______-

. - . . _- - .. ..

E

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Conclusion

The allegation that the supervisor intimidated, harassed and

berated QC inspectors was substantiated. However, this occurence

has not impacted the QC inspector's performance of quality

related activities. The action to dismiss the supervisor and

implement the supervisor training program are adequate

corrective actions for resolution of this issue.

-

(4) Concern

QC inspectors alleged that 93 hanger inspections on one check-

list containing 1100-1200 welds were signed off in one day by

an identified inspector. .The allegers considered this to be

too many inspections for a single inspector to make in one day

withoutthequa}ityoftheinspectionssuffering.

Licensee Review

This concern was not addressed by the licensee. None of the

CC inspectors interviewed by the licensee provided an example

where an individual accepted hanger inspections without going

out to the field to verify the work.

NRC Review

The QC inspectors interviewed identified the person alleged to

have performed 93 hanger inspections in one day. The identified

person was questioned regarding this issue and he responded

that to his knowledge this did not occur. The LKC inspectors

could not provide an. inspection report or date of the alleged

occurrence. Consequently, the inspection checklist where 93

hangers were accepted by the QC inspector who is the subject

of the allegation was not located during QC records reviews

by the NRC inspector.

A similar concern was examined regarding another QC inspector

as follows. On November 12, 1980, a LKC inspector documented

the acceptance of 129 hangers and 1,215 welds on one inspection

checklist. According to LKC management, QC welding inspectors

kept daily logs of the hanger inspections. When all of the

hanger inspections for an area were complete, the QC inspector

would sign off for all of them on one inspection checklist and

send the hanger numbers to PTL. This record-therefore reflected

a number of days of inspection effort. Subsequently, PTL would

perform nondestructive tests on 10% of the welds and would

accept or reject the welds. In this instance, PTL reviewed 122

(10% of the total) welds and rejected 16 welds on 10 hangers.

The LKC QC inspector reviewed the 1,215 welds and found them all

acceptable. It is not clear why additional PTL nondestructive

tests were not performed to include a' larger sample since about

13% of the welds were rejected by PTL. The licensee stated that

there was no instruction to require additional nondestructive

,

j

14

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test based on any identified failure of the sample tested.

That is, PTL would reject the welds when required based on

the NDE tests and identify the re,jected welds to the

contractor. The contractor would rework or repair the welds,

but the current procedures do not require nondestructive testing

of more of the welds submitted for test. Additionally, no

record exists which specifically documents acceptance of the

individual welds associated with a hanger. The licensee stated

that the inspector's inspection logs were not filed with the

inspection report. This program area requires further review

and evaluation and is considered to be an unresolved item

(456/85021-03; 457/85022-03).

A related issue identified during this inspection involved

the disposition of the 16 hanger welds mentioned above. On

November 19, 1980, PTL completed its report of visual

inspection of structural welding on the subject ten hangers.

As mentioned before, 16 of the 122 welds reviewed by PTL were

rejected and the report was sent to LKC for dispositioning.

However, at the time of the exit interview on August 30, 1985,

the licensee could not provide documented evidence that the

16 welds had been dispositioned or whether corrective action

had been implemented to repair the identified discrepant welds.

On September 5,1985, the NRC inspector was informed that two

of the ten hangers were deleted by S&L and three of the hangers

were repaired; however, the licensee could not provide documented

evidence that would indicate whether the remaining five hangers

(CC-23, CC-36, CC-87 and two type CC-34) were reworked, repaired

or accepted-as-is. ANSI N45.2-1977, Section 18, states, in part,

that " Sufficient records shall be prepared as work is performed

to furnish documenting evidence of the quality of items and of

activities affecting quality." The licensee has committed to

reinspect welds on the remaining five hangers to provide

inspection documentation.

Conclusion

This allegation could not be substantiated. However, examina-

tion of a similar issue involving another QC inspector showed

that the record of inspection identifies many welds that were

inspected on different days. It is not clear from the existing

record (s) whether any specific weld was inspected, only when it was

reported. The issue identified above wherein the quality

records for the rejected welds on five of the ten hangers were

unavailable constitutes a violation of NRC requirements. That

is, the failure to assure that sufficient' records be maintained

to furnish evidence of activities affecting quality is a

violation of 10 CFR 50, Appendix B, Criterion XVII (456/85021-04;

457/85022-04).

15

.

.

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(5) Concern

A QC inspector alleged that an LKC QA Engineer was assigned to

. the records vault for the sole purpose of closing nonconformance

reports. The alleger stated that this individual never went

into the field to verify the condition (work to be accomplished

per the NCR) before closing the nonconformance reports.

Additionally, this individual was alleged to be both a QC

inspector and a QA auditor who would inspect first, then do

the QA audit. Some LKC inspectors also indicated that QC

inspection reports were being signed without the inspector going

into the field to verify completed work.

Licensee Review

The LKC QC inspectors interviewed by the licensee indicated

that they had no knowledge of inspectors signing off QC

inspection reportc in the office or vault without going out

into the field to verify the condition.

NRC Review

The NRC inspector interviewed the alleger and the individual

who allegedly closed the reports and performed the audits,

reviewed the closed out reports and audits, and discussed the

issue with the QC manager and the LKC site QA manager.

The alleger stated that he had no first hand knowledge that

the other individual had closed nonconformance reports in the

vault and performed audits of inspection activities in which

he was involved, but that he had heard that this had happened.

He stated that this had occurred over a period of about two

weeks or maybe two days, but was not sure. -

The NRC inspector's interview with the other individual was

conducted by telephone since the individual was no longer

at Braidwood. He stated that he had been detailed to work

for quality assurance to assist in the preparation of a report

for submission to the licensee. His duties in the vault

were to research nonconformance and inspection reports for

material to be included in the report. He further stated

that he had closed no reports during that period. He further

stated that he had never participated in an audit involving

LKC at Braidwood.- The QA and QC managers agreed that the

individual did not close reports or perform audits during

this' period.

The NRC inspector's examination of the nonconformance report

log did not reveal any reports that had been closed by the

individual during the two weeks he was working in the records

vault.

!

I

j 16

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- ~ ~ - ^ ~

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Conclusion

, Based on interviews with the alleger, the individual, the

! quality managers, and the NRC inspection of nonconformance

l logs, this allegation could not be substantiated.

t

(6) Concern

j The QC inspectors stated that they had spoken to the Braidwood

Quality First Team without gaining any satisfactory response

to their concerns.

4

Licensee Review

i The' licensee interviewed LKC inspectors starting on February 13,

1985. These interviews were completed on March 11, 1985. As

a result, on March 4, 1985, the Quality First organization

documented a LKC QC inspector concern dealing with the adequacy

of training. As a result of ongoing investigations by the

licensee, some of the concerns were combined into investigations

1188, 1229 and 2026. At this time the licensee had not

completed its investigation of all the concerns. The most

recent Quality First concern (QF 85-2026) was documented.to

track the concerns of the LKC QC inspectors who met with the

resident inspectors on March 29, 1985. The licensee is

investigating the comprehensiveness of the initial Quality

First response to these inspector concerns.

NRC Review

The NRC inspector examined Quality First documentation relative "

to this allegation and interviewed Quality First Team personnel.

The inspector determined that the LKC QC inspectors had been

interviewed by the Quality First Team in February 1985. These

interviews were part of a program to establish baseline data

for the Quality First Team and included all QC inspectors from

all contractors. The LKC QC inspector's concerns were-reviewed

within the Quality First group and assigned for investigation

on March 4, 1985. At the time the allegation was made to the

NRC resident inspectors, the investigation into QC concerns had

not been completed.

The NRC inspector examined the completed report dated April 25,

1985, of the investigation of the QC inspector concerns. .The

, report addresses the concerns expressed during the Quality

First Team interviews and the allegations made to the NRC on

March 29, 1985.

Conclusion

The allegation was substantiated in that the QC inspectors had

not received a response from the Quality First Team; however,

l .the NRC inspector determined that the QC concerns were properly

17

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.

.

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addressed and adequate corrective action had been initiated by

the licensee.

(7) Concern

One QC inspector stated that hangers are not inspected, just

as-built. No inspection report or nonconformance reports

were written. Walkdowns were being done and drawings made

to show as-built configuration.

Licensee Review

The licensee determined that NCRs 708 and 709 were issued

to document and provide direction for the overall program to

walk down (inspect) hangers that were not installed in accordance

with design drawings.

NRC Review

The inspector reviewed the hanger reinspection program based

on Commonwealth Edison NCRs 708 and 709 and the inspection

documentation generated through the disposition of these NCRs.

The inspection activity referred to in the allegation is being

performed pursuant to NCR 708 and NCR 709. Since the inspection

is performed to correct the situation described in an NCR, no

other NCR would be issued since the problem has already been

identified. The inspector determined that inspection reports

are being written for the inspection activities according to

approved procedures.

Conclusion

Based on the inspector's review of NCRs 708 and 709 and

inspection reports related to the NCRs, this allegation could

not be substantiated.

(8) Concern

A LKC QC inspector alleged that he was constantly watched

by his supervisor. This LKC inspector visited the NRC office

and according to him was transferred without reason from field

inspections to a job in the records vault.

Licensee Review

The licensee determined that the subject of this concern was

a QC inspector whose personnel certification package is being

held by Braidwood QA. The QC inspector in question copied the

same inspection checklist several times and later filled in

some of the blank spaces in violation of procedures. The

QC inspector's work is being re-evaluated.

18

. . _ . . . . ._

,

.

NRC Review

The NRC inspector examined a licensee surveillance report that

identified deficiencies attributed to the alleger's weld

inspections. He was observed with copies of the same

inspection checklist on which he ccald fill in blank spaces,

in violation of procedures. The licensee ordered LKC to

remove him from field inspection in October 1983. Items

inspected by the alleger using the copied checklists were

reinspected by other inspectors. The NRC inspector determined

that the alleger has not been permitted to perform weld

inspections since October 1983 when he was transferred to the

records vault.

Conclusion

Based on the inspector's review of documentation relating to

j the alleger's transfer from the field to the records vault,

this allegation could not be substantiated.

P

i (9) Concern

It was alleged that an inspector cannot remain proficient

in all of the certified areas without a decrease in the

quality of the inspections, and that LKC management promised

more money to inspectors who were certified in multiple

areas.

Licensee Review

!

The licensee determined from discussions with the LKC

inspectors that they would te more comfortable if they could

i remain in a specified area rather than to move around the

site. However, no inspector felt that his request for

additional refresher training would be turned down. ,

NRC Review

i

"

During the NRC inspector's interview of LKC QC inspectors

the QC inspectors stated that they agreed that it was difficult

, to maintain proficiency in more than one inspection area, but

they also stated that when an inspector was moved from one

inspection area to another area that they could ask for

,

retraining if they felt it was needed. None had been denied

i

retraining when they had requested it. No QC inspector felt

'

that the quality of the inspections he performed had decreased

because of his multiple certifications.

In interviews with the LKC QC manager and QA manager they

stated that it was LKC policy to provide retraining to their

, personnel at the request of the QC' inspector. . In' addition,

changes in procedures and specifications affecting an area of

inspection are transmitted to'all inspectors certified in that

area whether or not they are working in their certifications.

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4 .

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,

9

Conclusion

'

.

) Based on interviews with inspectors and managers that revealed

i that persons may be retrained to maintain their certification

proficiency upon that person's request, the allegation could

not be substantiated.

(10) Concern

i

QC inspectors alleged that lead QC inspectors are being picked

, based on who would sign off the most quality documents (NCRs

j and ICRs).

^

Licensee Review

j The LKC inspectors interviewed by the licensee indicated that

i some of the QC inspectors were picked as leads based on who was ,

4

signing off the most NCRs or ICRs. However, the licensee

concluded that leads were never picked on the basis of who

) would sign off the most documents.

i

! NRC Review

, Some of the inspectors interviewed by the NRC inspector stated

that the selection of lead QC inspectors may have been based ,

j on who signed off the most quality documents; however, none

] could give an example where this actually occurred. No

l examples were provided regarding. improper signing _of inspection

reports or violations of procedures. NRC examination of

! personnel records did not disclose any irregularity in this

l regard.  ;

i c

! Conclusion

j The allegation could not be substantiated. There was no evidence

i that LKC picked QC lead inspectors on the basis of who signed

the most NCRs or ICRs.

i <

1 (11) Concern

It was alleged that some NCRs have been dispositioned by LKC t

Engineering as " retrain inspectors". Also, some NCRs have been

,

initiated and dispositioned by Field Engineering without an

, involvement of QC inspectors.

l Licensee Review

I The licensee did not address this concern in its investigation.

NRC Review

,

{ Some of the LKC inspectors interviewed by the NRC inspector

l

!  !

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20

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thought that NCRs were being initiated and dispositioned by

Field Engineering without any involvement of QC inspectors.

However, none could provide an example. With respect to NCRs

being dispositioned by LKC as " retrain inspectors", the QC

inspectors mutually agreed that if there was an issue where

.the finding clearly violated procedures or specifications they

could prevail upon LKC Engineering to change their positions.

No LKC inspector indicated he or she knew of one instance where

a NCR was improperly dispositioned. NRC review of NCR's has not

disclosed any significant deficiencies in this regard.

Conclusion

The allegation could not be substantiated.

(12) Concern-

It was alleged that if inspection quotas were not met,

overtire was not given to individuals.

Licensee Review

The licensee determined that there was one occasion when overtime

was not given because the person was not getting work done. It

was reported that the inspector bragged about how little work

he was doing. The QC manager stated that " Busy people work

overtime. Don't give overtime to peopis who sit around."

NRC Review

Some of the allegers indicated that LKC was more concerned

with production rather than quality, but none knew of an example

of quality being compromised or inspection quotas being

established by LKC quality management._ The licensee issues a

Daily Status Report which trends inspections. It is possible

the inspectors thought that the report was used to stress

production.

Some of the inspectors indicated they were reprimanded for not

producing enough inspections. These inspectors stated that

some inspections take more time than other inspections, and

consequently their' number of inspections were low. A review

of the records of three inspectors who had been reprimanded

indicate that all of them had a history of absenteeism and had

received written warnings regarding their absenteeism; however,

they had not received any written warnings for failure to meet

any inspection quotes.

Conclusion

The allegation that overtime was not given to inspectors who

did not meet inspection quotas could not be substantiated.

21

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However, one related instance was identified by the licensee

where an individual was denied overtime because the individual

was not as productive as was desired.

(13) Concern

It was alleged that three inspectors at LKC were supposed to be

terminated, and if they were terminated LKC inspectors were

going to walk.

Licensee Review

The licensee reviewed the situation that led to the LKC QC

inspectors threatening to walk out if three inspectors were

fired. The-licensee concluded that the situation was caused

in part by LKC's practice of giving every' individual on permanent

payroll 8 days of personal time plus two weeks vacation a year.

Before individuals used up all their personal days in an

apparently improper manner, verbal warnings were given. The

licensee determined that three individuals had been given

verbal and written warnings for absenteeism. The licensee

concluded that if the individuals continued their practices,

dismissal was possible.

NRC Review

The NRC inspector ascertained that the three inspectors were

not terminated.

Conclusion

This matter is a management and not a regulatory issue. No

violations of NRC requirements were identified.

(14) Concern

It was alleged that NCR 1616 and ICR 2900 were inappropriately

dispositioned.

NRC Review

The NRC inspector examined the disposition of NCR 1616 and

ICR 2900. The corrective action relative to NCR 1616 and

ICR 2900 was reviewed and approved by both the contractor's

engineering department and the design engineer. Final close

out o+ the NCR and ICR was accomplished by a certified Level II

QC in:,pector on August 8,1985.

Conclusion

The NRC inspector determined that the final disposition of the

PCR and ICR was proper and that the closeout of both reports was

accomplished in a timely manner. Based on the NRC inspector's

review, this allegation could not be substantiated.

22

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(15) Concern

It was alleged that one QC supervisor continually violated

procedures during inspector certifications.

NRC Review

The NRC inspector reviewed the procedure for training and

certification of QC inspectors. According to the procedure,

inspectors are not certified or recommended for certification

by QC supervisors. Review of randomly selected inspector

certifications show that personnel are certified by management

after recommendation by the training department and the Level II

inspector who conducts the on-the-job training test for

inspectors.

Conclusion

l

Based on the inspector's review of certification procedures

and records that revealed that QC supervisors do not certify

inspectors, this allegation could not be substantiated.

(16) Concern

l The allegers stated that there were no certified calibration

inspectors.

l NRC Review

l

The inspector reviewed inspector manning charts and tables

and determined that there have been certified calibration

inspectors on site since LKC began work at Braidwood in 1979.

I

!

Conclusion

This allegation could not be substantiated.

(17) Concern

'

It was alleged that a QC supervisor lied to get a QC inspector

l fired.

Licensee Review

The licensee did not review this allegation since it was never

brought to the attention of licensee management.

NRC Review

During discussions with the alleger, he stated that the

circumstances surrounding the incident in which he was

threatened with dismissal involved a lost company owned tape

23

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.

.

measure. According to the alleger he was asked by the QC

supervisor (who was later removed from his position but not

for this incident) if he had a tape measure that had been in

the QC inspector's possession. The alleger stated that he did

not - at which point the QC supervisor made a " profane"

statement. The QC supervisor stated (according to the alleger)

that the QC inspector was negligent with his equipment and

continued to use profanity and told the QC inspector to get out

of his office. The alleger told the QC supervisor that he

didn't have to take the abusive language. On January 13, 1983,

the QC supervisor initiated action to fire the QC inspector.

The letter of dismissal states, in part, the QC inspector "has

shown remiss and insubordinate actions in performing those

duties assigned by his supervisor along with not being

responsible for company tools he was issued." The alleger

was not fired and did not identify any quality concerns. The

QC supervisor involved is the supervisor discussed in Paragraph

2.d.(3) above who was dismissed for inspector harassment /

intimidation reasons.

Conclusion

This allegation could not be substantiated. However, no

quality issues pertaining to this incident were identified.

e. Licensee's Summary of the Allegations and Concerns Discussed Above

(Paragraphs 2.d.(1) through 2.d.(17)

Regarding the LKC organization, the licensee concluded that certain '

areas such as administration, communications, training and <

supervision need additional management attention. The licensee

also stated in its summary report of LKC QC inspector concerns and

allegations that a labor union issue divided management and

inspectors. It was the licensee's conclusion that except for the

situation which resulted in the removal of one QC supervisor, no

l serious quality related problems exist. The licensee stated that

I many issues were resolved with the termination of the subject QC

l supervisor,

f. NRC Inspector Summary

l The inspectors determined that the licensee's examinations and

conclusions regarding the allegations that the licensee reviewed

were appropriate. The two unresolved items identified by the

,

inspector are not directly involved with the allegations. The

! first instance involves an inspector who was certified as as a

Level II in welding within six weeks of being hired but had no prior

welding experience. The licensee and LKC later certified the QC

inspector based on his experience at Braidwood. However, the QC

inspector's previous work was never re-inspected to determine

his original capability. It is in this context that the unresolved

issue was raised by the NRC inspector. This is an isolated instance

24

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.

1

1 .

and no other individuals were determined to lack the required

experience. The second instance involves the lack of instructions

and procedures to direct what actions should be taken regarding

additional nondestructive testing of hanger welds when a significant

percentage of the test sample of welds is rejected by PTL.

Two adverse issues were identified by the NRC inspectors which

were related to allegations made by the QC inspectors. One

involved lead inspectors who were not certified as Level Ils in

their designated disciplines. This violated L. K. Comstock's

'

procedures. The second issue involved lack of documented evidence

I to indicate that discrepant welds on 5 hangers were repaired

or properly dispositioned. Both of these issues are characterized

l as violations in this report. The problems between LKC management

l and the QC inspectors generally stemmed from a lack of communication

! between management and employees, and the bullying tactics of one

QC supervisor who was removed from the construction site. These

concerns have been resolved or are in process of resolution by the

licensee.

3. Unresolved Items

Unresolved items are matters about which more information is required

in order to ascertain whether they are acceptable items, items of

violations or deviations. Unresolved items disclosed during this

inspection are discussed in Paragraphs 2.c.(3) and 2.d.(4).

4. Exit Interview

The inspector met with representatives (denoted in Paragraph 1) at the

conclusion of the inspection. The inspector summarized the scope and

findings of the inspections noted in this report. The inspector also

discussed the likely informational content of the inspection report with

regard to documents or processes reviewed by the inspector during the

inspection. The licensee did not identify any such documents / processes

as proprietary.

l

l

l

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