IR 05000456/1986036
| ML20214N795 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/26/1986 |
| From: | Muffett J, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214N759 | List: |
| References | |
| 50-456-86-36, 50-457-86-28, NUDOCS 8612030751 | |
| Download: ML20214N795 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/86036(DRS); No. 50-457/86028(DRS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-59; No. CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Lraidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: July 11 through November 14, 1986 OW j Inspector: Rolf. estberg I Date d% ON Approved By: James. W. Muffett, Chief II Plant Systems Section Date Inspection Summary Inspection on July 11 through November 14, 1986 (Reports No. 50-456/86036(DRS);
No. 50-457/86028(DRS))
Areas Inspected: Special, unannounced inspection of electrical (Cables &
Terminations) review of QA implementing procedures (510C18), electrical (Cables & Terminations I) observation of work and work activities (510638),
and electrical (Cables & Terminations I) review of quality records (510658).
Results: Of the three areas inspected, no violations or deviat, ions were identified in two areas; one violation was identified in the remaining area (failure to promptly document a nonconforming condition - Paragraph 2b(2)i).
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DETAILS
. Persons Contacted
_ Commonwealth Edison Company (CECO)
M. J. Wallace, Project Manager D. A. Brown, Quality Assurance Supervisor C. W. Schroeder, Services Superintendent
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J. W. Gieseker, Electrical Group Leader
- M. R. Dougherty, Project Construction Engineer D. L. Cecchett, Regulatory Assurance A. J. D' Antonio, Regulatory Assurance P. L. Barnes, Regulatory Assurance Supervisor The inspector also contacted and interviewed other licensee and contractor personnel during this inspectio . Allegation Followup (Closed) RIII-86-A-0079: On April 30, 1986, a BESTCo QC inspector came to the resident inspector's office to discuss a quality '
concern. The ccncern had the following two parts:
(1) After an April 28, 1986 meeting between L. K. Comstock Company
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(LKC) QC supervision and BESTCo QC inspectors, he was told by his lead inspector that multiple QC inspectors would no longer i be used on second shift cable pulls. The Alleger then wrote a l memo to his lead requesting the assistance of an additional QC inspector to pull Cable No. 2DG005. This cable pull was
approximately 350 feet long consisting of 12 bends and it was to be pulled through seven rooms and two floors. This memo was not acknowledged verbally or in writin The Alleger's concern was that the new philosophy of one QC inspector for a cable pull was not enough, in all cases, to adequately cover the cable pulls. The Alleger also requested a meeting with his lead and his QC supervisor to'-discuss his
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J concern. When they did not meet with him, the Alleger contacted the NR The NRC staff interviewed four QC inspectors, the CECO QC inspector responsible for monitoring second shift cable pulling, the Alleger, and the first and second shift lead QC inspectors -
relative to the adequacy of cable pulling inspections on the second shift. The Staff reviewed the applicable cable pulling procedures; the inspection records for Cable No. 2DG005, including the Cable Release Form (CRR), the pull cards, and the -
inspection check list; CECO QA Surveillances of second 'sh'ift i
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cable pulling from July 1985 to April 1986; and all CECO audits of in process cable pulling and pre pull activities. The staff also verified the route of Cable No. 2DG005 with the QC inspector who replaced the Alleger on the pull and witnessed in process cable pulling activities on the second shif *
The Staff's reviews and interviews produced the following information:
(a) The number of QC inspectors required to verify cable pulling attributes is not specified by any site procedures or any nationally recognized standards because it is a number based on the complexity of the cable pan / conduit syste If a cable pull has transitions between rooms or floors, multiple bends, and a combination of cable pans and conduit runs a single inspector may not be adequate coverage. The pull described by the Alleger appeared to
. be sufficiently complex enough to require more than one QC inspector; however, subsequent review of the inspection records of this pull and'an interview with the QC inspector who completed the inspection indicated the following: The pull was completed on April 28, 1986, by one pulling crew and inspected by one QC inspecto No deficiencies were identifie . The pull consisted of one Cable, No. 2DG005, 376 feet long. It started at Cubicle No. 17 of 4160 volt ESF switchgear (EQ No. 2AP05EL) on the 426 foot elevation and ended at the generator and auxiliary power j
section of the main control board (EQ No. 2PM01J) on j the 451 foot elevatio * ~ The QC inspector stated that he did not consider this a difficult pull for a single inspector since the _
pulling crew had to pull the cable in three section This involved stopping the pull in between sections in order to set up for the next section (pull and coil method). This allowed the QC inspector to follo~w the head of the cable and to watch portions of the cable through the entire cable pan ru . The QC inspector also stated that the cable pulling crew was very experienced and conscientious and that they.were willing to help the inspector and wait for him to reach his position for observation prior to proceedin . The Staff verified the route of the cable pull with the QC inspector and concluded that the pull was adequately inspected by one inspecto )
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(b) Interviews of a sample of first and second shift QC inspectors and supervisors indicated that the customary method for obtaining additional QC inspectors for cable pulls (which was not proceduralized) was to talk it over j with 'the lead QC inspector upon completion of the pre-pull
, inspection. Then, based on the complexity of the pull and the previous experience of the lead inspector, additional '
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. help would be granted or refused. Writing a memo was more l' time consuming and not the customary method. When questioned, the. Alleger stated that he did not save a copy
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of the mem The interviews also indicated that in'the past multiple -
- QC inspectors were routinely employed on cable pulls, but
- that this practice was due to considerations in addition to quality. ,The primary t easons were that fewer cables were being pulled in this time period and that the QC inspectors best utilization was by gaining additional experience in
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cable pulling inspections. During.this period excess QC inspectors may have been employe (c) Interviews with four BESTCo QC inspectors were conducted ,
relative to the adequacy of coverage of cable pulling on second shift, since the large pulls nonnally occur on that shift. All four stated that they never had a problem obtaining additional help and they felt comfortable with the quality of the cable pulling operation. The Lead
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Inspector was also interviewed relative to the assignment 4 of additional QC inspectors to cable pulls. He stated I that he employed a general " rule of thumb" of one QC
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inspector per craft pulling crew (six or seven men) and '
that he had never refused extra help based on sound
- judgement by an inspector. When questioned, he stated
- that he assigned another inspector to the cable-pull in question because the Alleger said he felt uncomfortable inspecting the cable pulling operation alone. Since he-i refused to sign the Alleger's memo, he did not receive a copy.
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Review of additional inspection records for cable pulls in
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the same time frame indicated that the extra QC inspectors
- or " helpers" do not sign the inspection report so the' .
i number of inspectors on a specific pull cannot always be i ascertained; however, the Staff concluded that a ratio of
one QC inspector for every'seven craft appears adequat (d) Review of LKC Procedures No. 4.3.8, ". Cable Installationf "
Revision G, and No. 4.8.8, " Cable Installation-
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j Inspection," Revision D, indicated, that while the
> completion of the QC Cable Pulling Checklist (Form No. 3',7)
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was a requirement (mandatory), the only attributes that'
i required 100% inspection or witnessing were conduit ' .
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swabbing, cable pushing in conduit less than 25 feet, cable pull-out and re pull, and cable re-reelin Therefore, the rest of the attributes could be verified on a sample basis using the inspectors judgement. The
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completion of the pre pull portion of the QC checklist was a requirement for release of the cable prior to the pul (e) Review of 16 CECO QA surveillances of second shift cable pulling from July 1985 to April 1986, and two Ceco QA audits, No. QA-20-85-557 and No. QA-20-86-544, which
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witnessed in process cable pulling and pre pull inspections, indicated that these audits and surveillances had identified deficiencies in the program; however, no problems were identified relative to QC coverage of the pulls. CECO has had a mandatory QA Witness Notification
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Point, No. WP/HP-5, in effect since April 9,1984. This witness point requires CECO Site QA to be present prior to
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the start of all power pulls installing safety related cable. In addition, there has been a CECO QC inspector (Pittsburgh Testing Laboratories (PTL) employee)
permanently assigned to monitor second shift cable pulling since July 1985. This PTL inspector was interviewed and he stated that he was satisfied with the quality of the cable pulling and had never witnessed any problems caused by insufficient QC coverage of cable pullin Based on the above, the NRC inspector concluded that the QC coverage of cable pulling on the second shift was acceptabl (2) As a result of writing the memo referenced in (1) above, the Alleger believes he was harassed based on his being given the monthly hold tag verification inspectio The NRC Staff interviewed the Alleger, the Alleger's lead, and the General QC Supervisor relative to this incident. The Staff also reviewed the hold tag inspection records and the applicable procedures. The interviews and reviews indicated the following:
, (a) The incident occurred on April 28, 1986. The hold tag inspection, which is required monthly, had not been accomplished. This meant that there were only two days left to get the inspection complete (b) A review of the previous hold tag inspection records indicated that the Alleger had been assigned this task every month from September 1984 to July 198 Consequently, he was the most experienced inspector in this area and he was not on a cable pull on April 29, 1986 because of the incident described in (1) abov (c) As a result of this incident, the Alleger conducted the hold tag verification inspection for April; however, in
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May, the inspection was given to two other QC inspector In June and July, all hold tags were verified 100% during the third shif (d) The Alleger did not return to cable pulling inspection after the alleged incident; however, this was not a direct result of this inciden It was due to his being harassed by an LKC cable pulling foreman. This incident was investigated by the CECO Quality First Program and documented in Report No. QF 86-1240M where they concluded that the incident was not work related but a personality clash. Subsequently, the foreman was fired and the Alleger was permanently assigned duties in the status departmen (e) The assignment to verify hold tags may'have been viewed by QC inspectors as a punishment; however, it is required by the LKC Procedures No. 4.11.1, " Nonconforming Items," and No. 4.11.2, " Inspection Correction Report," every 30 days and must be accomplished by a QC inspector. Of the five BESTCo inspectors interviewed besides the Alleger, three had previously done this tas (f) When the Alleger contacted Region III in April 1986, he was asked if he wanted to contact the Department of Labor .
(DOL) to report the harassment and informed that he had 30 days to make such a report. The Alleger was contacted on August 13, 1986, relative to reporting the harassmen He stated that since he was still certified as an inspector and had not suffered any decrease in pay that he did not consider that he was harassed and had not reported it to DOL. He also opined that his new job in statuing could affect his layoff status in the positive direction, that is, he could be kept on longe Based on this incident only, the Staff concluded that there was insufficient evidence to either prove or disprove harassment and that this incident did not lead to an inadequate inspection of any safety-related hardwar i (Closed) RIII-86-A-0096: On Junt. 4, '.986, a QC inspector for BESTCo telephoned Region III and expressed concerns relative to cable pulling at the Braidwood Nuclear Station. These concerns were as follows: placing production over quality; lack of guidance relative to inspection procedures; pressure to get the cable pulled; ignoring of non safety discrepancies or damage; and poor worker attitude ;
The Alleger stated that he had compiled a five page listing of the 1 above concerns and agreed to mail a copy of the list to Region II On June 10, 1986, the Alleger contacted Region III. He stated that he had discussed his concerns with his supervisor and that his supervisor had talked to the LKC QC Manager. He also stated that as a result of these discussions the QC Manager had taken care of most of his concerns. The Alleger had not yet mailed the letter to
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Region III detailing his concerns, but agreed that he would still mail that letter and annotate which concerns had been corrected and
.. how they were correcte On July 16, 1986, the Staff interviewed the A11eger relative to his concerns. During this interview, the Alleger produced a copy of his list and agreed to mail the original to Region III. The 1.ist was
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not annotated as-to which concerns were closed, nor was there any indication of how they were closed. Upon questioning, the Alleger stated that only one of his concerns had been resolved, the one relative to the lack of guidance on inspection procedure On August 7, 1986, the Alleger contacted Region III with additional concerns. These were, that he was told that he would be one of the first inspectors on the second shift to be laid off, that the union would be compiling the lay off list for September 1986, and that he was told that he would not be allowed to transfer to the first shif On August 8, 1986, the Alleger contacted Region III and stated that he had filed another transfer request on August 7, 1986, and that if this request was denied he would be contacting the Department of Labor (DOL).
On August.8, 1986, the Alleger was contacted by Region III and informed that the internal NRC memorandums regarding his allegations were being released to the Atomic Safety Licensing Board (ASLB). He agreed that his identity could be released to the board and other parties that had a need to know; however, he did not want his name
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given to his employer, anyone at Braidwood Station, or the general public. Subsequently the A11eger contacted Region III on August 13, 1986, and stated his displeasure with having his name released and further stated that he did not want his name released to anyone to indicate his involvemen On August,18, 1986, the Alleger contacted Region III with additional concerns. These were, that he felt that his latest transfer request was denied because of his contacts with the NRC, that two other inspectors were transferred because they found too many problems, that the other QC inspectors do not want to get involved with quality problems because they do not want to lose their jobs, and that the other inspectors would not answer questions from the NRC because they did not want to be involve On August 19, 1986, the Staff met with the Alleger; LKC QA/QC i
management; CECO project construction; Local No. 306; and General l
Electric-Multi Craft. Inspection Services, (GE-MCIS, who replaced i BESTOCo) at the Alleger's request. At this meeting, the Alleger's i transfer request and quality concerns were discussed. As a result l of this meeting, the Alleger's name was made public and he was subsequently subpoenaed to appear before the ASLB on September 9, 198 .
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On September 2, 1986, the Alleger contacted Region III with an additional concern. He stated that he had heard that LKC had picked the employees to be interviewed by the Staff. The Alleger also stated that he had prepared questionnaires about LKC work at Braidwood. He had circulated questionnaires to 12 inspectors and six had been returned. These six seemed to support his previous concern ,
(1) Relative to the Alleger's concerns, the Staff reviewed the
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(a) LKC Procedures:
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1 No. 4.3.8, " Cable Installation," Revision G No. 4.8.8, " Cable Inspection," Revision D and Revision E No. 4.3.9, " Cable Termination Inspection," Revision F No. 4.11.1, " Nonconforming Items," Revision.G
, No. 4.11.2, " Inspection Correction Report,"
Revision F (b) CECO Procedures (1) CECO Quality Procedure No. 15-1, " Reporting Quality Nonconformances During Construction and Test,"
Revision 1 (2) Project Procedure No. PM-09, " Quality First Program."
(c) LKC Nonconformance Reports: No. 3773, " Upgrade of ICR No. 7865 - Cable Damage, Aux. Building, 463'-5" Elevation, Column 11.5, West of Q Line." Dated January 16, 198 . No. 3774, " Upgrade of ICR No. 7866 - Cable Damage, Aux. Building, 463'-5" Elevation, Column 11.5, West of Q Line." Dated January 16, 198 . No. 3775, " Upgrade of ICR No. 7864 - Cable Damage, Aux. Building, 463'-5" Elevation, Column 11.5, West of Q Line." Dated January 16, 198 . No. 3717, " Bend Radius Violation - Aux. Building, 463'-5" Elevation, Column 16, M Line." Dated December 12, 198 .
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. No. 4831, " Cable Damage - Aux. Building, 463'
Elevation, Between Columns 24 and 25, Between N and P Line." Dated January 9, 198 ~ No. 4987, " Cable Damage and Bend Radius Violations -
Aux. Building, 463'-5" Elevation, Between Columns 23 and 25, Between Q and M Line." Dated March 19, 198 (d) CECO Nonconformance Reports: No. 840, " Cables Not Properly Installed in Cable Pan, Unit 1 - Safety-Related Risers on 463' Elevation."
Dated September 9, 198 . No. 841, " Cables Not Properly Installed in Cable Pan, Unit 2 - Safety Related Riser on 463' Elevation."
Dated September 5, 1986.
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(e) LKC Memorandum, dated January 3,1986, identifying cable
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installation problem on 463' Elevation, Between Columns 24
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and 25, Between Lines N and (f) Sargent & Lundy (S&L) Cable Separation Criteria Violation (CSCV) No. 1988 - Unit 2 Remote Shut-down Panel. Dated July 7, 198 (g) Minutes of Weekly QC Meeting - Monday, June 16, 198 + (h) Deposition of the Alleger taken on September 3, 198 (1) ASLB Hearing Transcripts: Tuesday, September 9, 1986
. Wednesday, September 10, 1986
' Thursday, September 11, 1986 (j) Safety-related Cable Inspection Packages: AR029 AR032 IAR095 3 1AR161 AR178 IAR194 IAR196 AR207
! IAR208 1 AR233 1 AR234
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1 IAR235 1 IAR236 1 AR237
- 1 AR242
- T AR243 1 IAR244 T IAR245 1 AR250 2 AR251 2 AR252 2 IAR253
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IAR258 2 AR259 Y AR260 2 IAR261 .
2 IAR266 2 IAR267 2 IAR268 4 3 IAR269 l l .
ISI676 2AR277 33, 2AR278 3 AR279 <
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35. 2AR280
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]]. 2CC003 37, 2SX007 (k) LKC Cable Separation Conflict Reports (CSCRs) No. 511 through No. 55 (1) LKC Inspection Correction Report (ICR) No. 15749.
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(m) Meeting Minutes documenting the August 19, 1986, meeting with the Allege (n) Braidwood FSAR Section 8.3.1.4. ,
The Staff interviewed the Alleger on July 16 and September 17, 1986; eight of the nineteen QC inspectors, with cable pulling certifications, on first and second shift relative to his concerns between July 11 and July 16, 1986; and all QC inspector with cable pulling certifications between September 19 and October 7, 198 (2) The Alleger's specific concerns and the Staff's conclusions '
follow:
(a) Concern No. 1 - Production seems to over-shadow qualit !
The Alleger gave an example of where he was not allowed l time to document an apparent separation criteria violation l during the installation of safety-related Cable No. 2SX007 because he was needed for a " hot pull"'(one CECO needed
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immediately for testing). The Staff determined this to be
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a true statement. He was not allowed to complete the i paperwork that day; however, he was the only QC inspector i not assigned to a pull that day and the next day he was given the assistance of two trainees to help complete
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CSCRs No. 511 through No. 550. The Staff concluded that this_ example did not appear to be a deliberate attempt to
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keep him from identifying quality problems or putting
- production first. Further, the Staff's review of LKC Procedure No. 4.8.9, " Cable Separation conflict Report,"
and CSCRs No. 511 through No. 550 determined that no procedures were violated and that the apparent separation -
criteria violation had been properly identifie The CSCRs were subsequently investigated by S&L on CSCV
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No. 1988 on July 7, 1986. They determined that the cables
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were not in violation of the separation criteria per Section 8.3.1.3.2.2 of the Braidwood FSAR. The Staff inspected the referenced cables in the field and reviewed both the CSCV and the FSAR section and concurred that there was no violation of the separation criteri The A11eger was contacted relative to this concern on September 17, 1986. He stated that he was satisfied with the resolution to this concer (b) Concern No. 2 - Clarification of what procedures QC inspects to was required. The Alleger gave the following example. While cutting safety-related cable, No. ISI676, on May 1, 1986, non-consecutive footage marks were discovered. LKC Procedure No. 4.3.8, " Cable .
Installation," Section 3.5.1.1, states that the LKC Cable Engineering Department is to be contacted immediately and pulling from the affected reel suspended until the
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discrepancy is documented by the Engineering Department and so noted on the pull card. He stated that the above i procedure section was not followed and that when he asked
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the QC supervisor in the Area about it, he was told, "We -
do not work to 4.3.8 and to continue cutting."
The Staff's review of this concern indicated that the following guidance was given at the General QC Meeting of
. June 16, 1986, and the General QA/QC/ Construction Meeting of June 19, 1986: If a reel has non-consecutive markers, craft will indicate N/A on start and end footage and write actual measured footage on reel and pull card < Other problems - contact LKC Cable Engineering.
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Subsequently, a procedure change was initiated to implement
this guidance. When the Alleger was interviewed on July 16, 1986, he indicated that he was no longer. concerned about this ite Safety-related Cable, No. ISI676, is cable is a No. 16 gauge twisted pair in the reactor protection channel No. 4. It runs entirely in conduit from junction box No. 1JB1284A to junction box No. 1JB936A. The cable reel, No. BR120, was imprinted on the cable and recorded on the inspection records; thus traceability was maintaine The incorrect footage markers. affect cable accountability only; therefore, this item has no safety significanc ,
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(c) Concern No. 3 - The A11eger had a feeling of being rushed by production and gave two examples: .
1 On June 3, 1986, he was not given enough time to do a proper pre pull inspection on a " hot pull" and had to run to check cable pans ahead of the pull. He also found some problems during the pull, but_they were
not conformin The Staff's review of LKC Procedure No. 4,3.8, Section 3.3.3, indicated that for safety-related pulls, the foreman must notify the QC Department in sufficient time to allow for a pre pull walkdown in accordance with Procedure No. 4.8.8. Section 3.9.1, states that for safety-related cables, LKC QC shall be notified to perform pre pull and in process -
inspections. The use of the word "shall" indicates that this was a requirement. This requirement is'
further amplified by Procedure No. 4.8.8, Section 3.2, which states that upon notification fro ^m construction for the cable pull, QC shall perform ~the following pre pull checks and document on Form 37,
"Cdble Pulling Checklist." Item No. 3.2.16 of the Form 37 is that the pre pull inspection is complete and the cable is released for pull. Therefore, if the cable pull started before the QC inspector completed the pre pull inspection, it would be a procedure violation and the QC inspector would be required to generate either an NCR 'or an ICR to document the violatio Review of the inspection records for Cables No. 2AR277, No. 2AR278, No. 2AR279, No. 2AR280, and No. 2SX007
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inspected by the Alleger on June 3,1986, indicated that he had signed off on Item No. 3.2.16 on the Form 37, indicating the completion of the pre pull ,
inspection. No NCRs or ICRs were written by the !
Alleger on June l
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. Another QC inspector had a pull 1700 feet long consisting of 25 cables and he was still walking down the cable routes as they were being pulled. That QC inspector also identified previously pulled cable in a wrong conduit and wrote an ICR, but all they did was to switch the conduit number label The Staff review of the inspection records for cables pulled by this inspector on June 1, 1986, indicated that this long pull had been in process for several days. It had been previously walked down three times in accordance with the procedure by qualified inspectors. .Therefore, an abbreviated pre pull inspection was acceptable. As in the previous example, the QC inspector had released the cable for pull on the Form 3 The Staff review of the inspection records for Cables No. 1AR252, No. 1AR253, and No. 1AR235 produced ICR No. 15749, dated June 6, 1986. This ICR documented cable identification number discrepancies on the
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respective Cable Raceway Release (CRR) forms onl No conduits were actually mislabele Between September 19 and October 7, 1986, all QC inspectors with cable pulling certifications were interviewed. When asked if they ever felt pressured or rushed by production, six said they had; however, they all stated that they had been able to complete their inspections and that the quality was not compromise The Staff concluded that the examples given had not caused inadequate inspections or the installation of unacceptable hardwar (d) Concern No. 4 - Inspectors have been told to ignore non-safety discrepancies or damage and the Alleger was not aware of any program to identify such damag Non-safety-relate'd construction is outside the Category I QA program; however, the LKC new employee orientation covers the responsibility for identifying nonconforming conditions and Quality First Program indoctrinatio Project Procedure No. PM-09, " Quality First Program,"
includes non-safety-related concerns. It defines them as
" management concerns."
The Staff interviewed seven QC inspectors other than the Alleger. None of the seven had ever been told to ignore non-safety deficiencies and all were cognizant of the Quality First Program. However, as a result of this
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concern, CECO committed to drafting a memorandum to LKC QC personnel reinstating the PM-09 policy relative to non-safety-related constructio Based on the above, the Staff concluded that this concern had been adequately addressed and that it is not a policy to ignore defects in non-safety related component (e) Concern No. 5 - There is a feeling on this job that if you make waves you will regret i ,
Between September 19 and October 7, 1986, 23 QC inspectors
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were interviewed blacklisted relative toquality for identifying making concerns.waves and being' sample This
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included all the first and second shift cable pulling inspectors and second shift welding and concrete expansion
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anchor (CEA) inspectors. The interviews indicated that a majority (87%) of inspectors did not believe that they would be blacklisted and a majority (78%) did not feel
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they would regret making waves. (identifying quality concerns).
The inspectors who believed there was a blacklist or felt that they would regret making waves were asked for
specifics examples of where QC Inspectors were blacklisted for making waves. This produced two examples. The Staff reviewed both examples and found that they involved inspectors who had been interviewed previously and they i had stated that they did not consider themselves
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blacklisted for identifying quality concerns. One other inspector believed in in the blacklist and stated that he had been " jacked" around, but further stated that it was not due to quality concerns.
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representative of the feelings of the majority..of the QC inspector i 1 (f) Concern No. 6 - A good inspector who went by the book had
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been reduced from an inspector to a reviewer because he i did his job too wel !
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The Staff had previously reviewed this example. See l
2.a.(2)abov '
(g) Concern No. 7 -The Status Report of Work Completed was no )
longer being used. The Alleger gave this as an example of
production being given emphasis over qualit The Staff's review of this concern determined that this 4 report was an unofficial tracking system used by the lead
inspectors to track completion of cable pulls for input j into the status syste It was only used on the second l
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shift for a period of 30 days and it was neither a commitment nor a requirement of the LKC QA progra Further, it was never intended to be used as a " report card" for QC inspectors lor as input into a layoff lis This concern was discussed with the Alleger during the July 16, 1986 intervie He stated that he understood what the Status Report's intended use was and was no longer concerne (h) Concern No. 8 - Craft personnel walk on the cable. The Alleger was concerned that safety-related cable, +. hat was pulled off the reel and laying on the floor prior to being pulled, was not being respected and people were walking on i .
The interview with the A11eger and eight of the other cable pulling QC inspectors between July 11 and July 16, 1986, produced one example where safety-related cable was walked o This incident, which occurred on May 8, 1986, involved a Phillips Getschow pipefitter and several CECO employees. The incident was investigated by Quality First and as a result a memorandum was issued by the CECO Project Construction Superintendent to all project personnel regarding protection of electrical cables on June 11, 198 The cable was subsequently pulled on May 10, 1986. The Staff's review of the inspection records for Cables No. 1AR029, No. 1AR032, No. 1AR095, No. 1AR161, and No. 1AR178 which were pulled on May 10, 1986, indicated that the cable was not damaged by this inciden The Staff concluded that this example did not lead to the installation of any damaged hardwar (1) Concern No. 9 - NCRs are written, but not closed in a timely manner and the NCR disposition "use as is" is being employed excessivel During the July 16, 1986 interview of the A11eger, he
cited NCR No. 4987 as an example of a nonconforming condition in the Unit 2 Upper Cable Spreading Room not being addressed in a timely manner. The Staff's review of this example produced the following: I Similar conditions of cable damage, bend radius ,
violations, and overfill had previously been '
documented in the' Unit 1 Upper Cable Spreading Room on LKC ICRs No. 7864, No. 7865, and No. 7866. These i ICRs were subsequently elevated to LKC NCRs No. 3773, l No. 3774, and No. 3775. In addition, LKC NCR No. 3717 l also documents a similar conditio I 15 l
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2. Due to the above conditions, LKC Cable Engineering sent a memorandum to LKC QC on January 3,'1986, which requested that a QC inspector inspect and document similar conditions at Aux. Building elevation 466 feet, Columns 24 to 25, and Lines N to P (Upper Cable Spreading Room Unit 2).
This inspection was completed and nonconforming conditions were documented on LKC NCR No. 4831, dated January 9, 1986. Hold tags were placed on the damaged cables in accordance with LKC Procedure No. 4.11.1, " Nonconforming Items." The Alleger stated these hold tags were still attached when he inspected other cables in the same general area on March 4,198 . The A11eger then brought the conditions in the Unit 2 Upper Cable Spreading Room to the attention of his supervisor. His supervisor looked at the cables and agreed that there was a nonconforming conditio They then discussed how to write the NC The A11eger wanted to write an NCR identifying all the specific cables involved while the Supervisor wanted to write a generic NCR identifying the problems in the entire area. Because of their basic disagreement, they decided to discuss it with the General QC Supervisor. He was not available because of shift overlap, so the Supervisor told the A11eger to write a memo to him documenting the conditions observed. The Supervisor was interviewed on-October 7, 1986 relative to this incident. When asked why he wanted a memo instead of an NCR, he stated that he did not want it to fall into a crac He also stated that he was not awar'e of the January 3,1986, memorandum from LKC Engineering which led to NCR No. 4831. The memorandum was written and subsequently given to the General Supervisor three days late . On March 19, 1986, the cable spreading room conditions were verified by the General Supervisor, !
the LKC Construction Area Manager, CECO Project I Construction, and the A11eger. All the parties concerned agreed that there were nonconforming conditions existing. The Alleger was instructed to write a Generic NCR on the entire area, which he subsequently did (No. 4987). "
5. The NCR was dispositioned by LKC Engineering on April 7, 1986, giving recommendations for corrective action subject to CECO and S&L evaluations. At the time of the allegers initial contact with Region III, neither CECO nor S&L had completed their review .
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, NCR No. 4987 and No. 4831 were evaluated by CECO and S&L in accordance with CECO Quality Procedure No. 15-1, " Reporting Quality Nonconformances During Construction and Test," and a CECO NCR No. 841 was generated on September 5, 1986. This NCR gave the corrective action to LKC which was to inspect each cable for damage, to retrain the cables to achieve proper installation and to add additional horizontal support The Staff interviewed the All'eger' on September 17, 1986, and he stated he had read the disposition of CECO NRC No. 841 and was no longer concerned with conditions in the cable spreading room The Staff's review of LKC Procedure No. 4.11.1,
" Nonconforming Items," indicated that'Section 3.3 requires ,
the completion of the first section of Form No. 14 (Nonconformance Report) upon detecting the nonconforming condition. Section 3.3.1.1 requires the originator to sign and affix hold tags to those items affected by the nonconformance within one working da CFR 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality
. such as failures, malfunctions, deficiencies, deviations, defective materials and equipment, and noticonformances are promptly identified and correcte The failure of the LKC corrective action system to document a nonconforming condition for 15 days after it was first recognized is considered to be a violation of 10 CFR Part 50, Appendix B, Criterion XVI (457/86028-01(DRS)).
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Subsequent to the exit meeting, CECO issued'a memorandum to LKC emphasizing the importance of prompt' identification of nonconformances and requesting a training session for QC and engineering personnel. The staff' reviewed this memorandum and concluded that it should be sufficient to prevent further recurrence since the previous reviews and interviews showed this to be an isolated case. Therefore, no further response is necessary and this violation is considered close The Staff reviewed the NCR log and selected 10 additional cable NCRs for review. This review determined that the disposition "use as is" was not being abused relative to cable pullin (j) Concern No. 10 - He had been told that he would be one of the first inspectors on the second shift to be laid of _ _ ..
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On August 19, 1986, the Staff interviewed the person who was alleged to have told him this. He denied making the statement, but did admit to having a conversation with the Alleger. Further, he felt that the Alleger may have read more into the conversation than he actually said. During a meeting with CECO and LKC QA/QC management, also on August 19, this concern and the previous interview were discussed with the Alleger. He admitted that he was not
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told directly that he would be laid off first, but rather that is how he had interpreted the conversatio !
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The Staff concluded that this concern did not have a basis
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(k) Concern No. 11 - He had heard that the union would be- )
1 compiling the layoff list for September 198 The August 19, 1986 meeting with the Alleger, CECO, LKC
, QA/QC management, GE-MCIS, and the Local 306 Steward
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- The LKC QA Manager stated that the Alleger could not be one of the first inspectors to be laid off since
any layoff list would be generated by him and that he had not ygt started on . The QA Manager also stated that they were currently hiring, not laying off. Because of the work load, nine new inspectors had recently been hired for second or third shift with two of the'nine designated for cable pullin Further, four first shift inspectors had been transferred back to second shift because of the increased work load and one of the four was certified in cable pullin ~ The union does not initiate the layoff Iis LKC i
does that based on the work loa The Staff concluded that this concern had been-sufficiently addressed and did not concern the quality of installed hardwar i (1) Concern No. 12 - He had been trying to transfer to the day shift and he was told he would not be allowed to transfe The Alleger requested transfers from the second shift to the first shift in writing on June 2,1986; July 10,1986; and August 7, 1986. These transfer requests were either ignored or denied. When the Alleger contacted Region III on August 18, 1986, he stated that his latest (August 7, 1986) transfer request had been denied and he felt that it was because of his contacts with the NR i
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The Staff's review of this concern produced the following information:
- The June 2 request denial was made by the General QC Supervisor based on work load and' seniority consideration . There is no official seniority list; however, all QC inspectors hired after July 24, 1985 were hired for i
second or third shift with the understanding that
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they could work their way to first shift in time.
j Inspectors with more time on site have priority concerning shift assignments;
- The transfer of three QC inspectors in June was the result of a request from CECO to supply personnel for
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Area Turn Over (ATO) and Release for Operations (RTO). They were certified in cable pulling and one
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had submitted a transfer request previousl . The inspector transferred in August was certified in weld inspection, an area in which the Alleger was not certified.
. The Alleger was offered a chance to go to the first shift in early August, but declined it because he would have to work for a supervisor and a lead with
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whom he had disagreement . It is a true statement that the August 7, 1986 transfer request was denied in part because of his contact with the NRC. The Alleger was told on
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June 24, 1986, that it might look unappropriate if
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they removed him from an area where he had previously
,i expressed concerns. The Alleger's name was known by LKC because his name was on the NCRs and CSCRs the Staff was given as examples of his concerns. He had also shown a copy of the list of his conce'rns to his supervisor.
l The Alleger was informed of his rights and asked if he was going to DOL claiming harassment. He stated no, that he was not harassed, rather he was discriminated agains Subsequent to the Staff's review of this concern, the ,
Alleger was transferred to the first shift. No charge of 1
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- that LKC had acted conservatively in denying his transfer !
because of his concerns and that this concern had been 1 j addresse !,
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(m) Concern No. 13 - Two inspectors we're transferred because they found too many problem The Staff determined that one of the inspectors had been previously identified and that concern was previously
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reviewed (see 2a.(2) above). The other inspector's name indicated a new concern. .The Staff met with the LKC QC General Supervisor for Unit No. 1. This meeting produced
- the following information
- The QC supervisor stated that the individual i identified by the Alleger was not transferred because he found too many problems as a welding inspector, but rather that the individual showed an aptitude for cable pulling inspection and cable pulling had the greater workloa . The alleged incident occurred after all second shift welding inspectors were cross trained into cable l pulling inspection. The inspectors that were good at
- cable pulling inspection were kept in cable pulling i and new welding inspectors were hired. Additionally,
- the new welding inspectors cross trained in cable i pullin The Staff concluded that this was not a deliberate attempt "
to keep inspectors from identifying quality problem (n) Concern No. 14 - Inspector morale is poor and they are afraid to express concerns to the NRC on penalty of their job ,
The Alleger expressed th.is concern as an example of-inspector frustration because of the emphasis on j production. He also quoted examples of things he had heard other inspectors had said venting their frustrations such as: "it gets to the point where all you want to do is pull the wire and that's that; all these' things never
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get taken care of; no one cares; and I'm just here for the money, as long as I get paid I'll sign the papers."
The Staff interviewed eight out of the 19 cable pulling QC inspectors (including the caller) from July 11 to July 17, 1986. Of these inspectors, no one had ever been threatened with any kind of disciplinary action if they contactJ the NRC with quality concerns. As to the morale of the inspectors, one other individual could recall hearing other inspectors referring to their frustrations in a similar manner; however, no examples were given of any inspector not working up to his full potential or of
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inadequate hardware being accepid by QC inspector .
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The Staff concluded that since no examples of inadequate inspections were given, this concern had no safety !
significanc (o) Concern No. 15 - QC inspectors do not want to'get involved with problems because they ou not want to lose their job Also, they will not be truthful in their responses to the NRC because they do not want to be involve The Alleger gave as an example violations of separation criteria in cables that had been previously inspected and accepted above the Unit No. 1 remote shut-down panel. He contended that the other inspectors did not docurilent this condition because it was a big problem and they did not want to be involved. The Staff determined that the Alleger was referring to a condition that was documented by S&L as acceptable. (See Section 2b(2)(a) above.)
Additionally, the interviews with nine of the 18 cable pulling inspectors did not support the Alleger's concer The Staff concluded that the example given to support this concern had no safety significance.'
(p) Concern No. 16 - LKC chose the employees to be interviewed by the Region III inspector assigned to resolve the concerns. The Alleger was told that LKC only picked veterans so that no adverse information would be given to the NR The Staff interviewed QC inspec, tors in the following manner: after reviewing a current list of all inspectors pulling cable on first and second shift, the candidates for interview were selected by the NRC inspector at random. Both veterans and relatively recent new hires were chosen. These inspectors were all certified in cable pulling with the most experienced since October 20, 1984, and the most recent since February 17, 1986. In addition, the leads from first and second shift were sel.ecte The Staff concluded that there was no basis in fact for this Concer (q) Concern No. 17 - The Alleger prepared questionnaires regarding the quality of LKC work at Braidwood and gave them to 12 QC inspectors. Six of the 12 questionnaires were returned to him and some of the answers supported his positio The Staff obtained copies of the six questionnaires and reviewed the answers to the questions about the quality of the plant. Two of the six indicated that there were quality concerns that had not been addressed. The Alleger
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was contacted on September 17, 1986 relative to the identities of the inspectors who returned the questionnaires. He stated he did not remember who had returned them; therefore, the Staff made arrangements to interview all QC inspectors with cable pulling certifications. The Alleger said that he had given his questionnaires to some CEA inspectors also, so they were included in the interview Twenty-three inspectors were interviewed between September 19 and October 7, 1986. They were asked the same questions as the ones on the Alleger's questionnair In addition, the inspectors were asked to comment on the views of the Alleger which had been widely publicized in the Chicago and local newspapers and asked whether they were ever asked to fill out an anonymous questionnaire for the Alleger. The results of those interviews follows: When asked if they had been asked to fill out a questionnaire for the A11eger, eight responded they ha . Four of the six inspectors who returned questionnaires to the Alleger admitted it. Their answers to the questions indicated that they did not have any quality concerns. The two inspectors who returned questionnaires tha't' alluded to quality concerns did not come forwar . When asked if they supported the allegers views, two agreed, two partially agreed, and 19 disagree . During the interviews, the inspectors were asked if they had any concerns, quality or otherwise. This produced nine additional concerns. These concerns
will be covered in Section b(3) of this repor Based on the above, the Staff proceeded to address all quality
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concerns detected by the interview proces (3) The interviews with the 23 QC inspectors conducted from September 19, to October 7, 1986, produced nine additional concern (a) Relative to these additional concerns, the Staff reviewed '
the following documents: LKC Procedures
' No. 4.11.1, " Nonconforming Items," Revision No. 4.11.2, " Inspection Correction Report,"
Revision F.
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. No. 4.3.9, " Cable Termination Installation,"
Revision No. 4.8.9, " Cable Termination Inspect' ion,"
Revision *
~ LKC Work Instruction No. WI-4.3.13-01, " Work Instruction for Box Evaluation," Revision . Okonite Cable Jacket Repair Procedure, dated March 15, 198 . LKC Nonconformance Report No. 496 (b) The specific concerns and the Staff's conclusions follow: Concern No. 1 - Craft personnel need'more training in quality control procedure The Staff's review of this concern indicated that QC procedures are written in a parallel manner to the craft installation procedures; however, the QC procedures normally address inspection requirements ;
and acceptance criteria while installation procedures normally address installation criteria, such as methodology and tolerances. Craft personnel receive training on requirements that are common to both types of procedures such as mandatory QC hold point The Staff concluded that the craft installation procedures contained sufficient information on QC requirements based on the previous review of both QC and installation procedure . Concern No. 2 - Only the craft foremen and the General Supervisors get retraining in~ procedure changes and new procedures. Craft personnel do not atten .
The Staff's review indicated that, for the most part, this is true. Procedure training to minor procedure changes is conducted to the foreman level, who in turn may give documented training to appropriate craft personnel. However, the current training program's initial indoctrination for newly hired personnel requires training in the specific procedures employed in the area which they will be assigned. Additionally, for major changes to installation procedures and for unique work instructions / guidelines, all craft personnel are given documented training by the LKC Engineering Training Departmen ,
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The Staff concluded that the craft training program was acceptabl . Concern No. 3 - We could use five to ten more QC inspectors for termination The Staff reviewed the number of QC inspectors certified to inspect terminations in the same time frame (September) as this concern and determined that there were 26 QC inspectors who were certified to perform inspections. Of these 26, two had certified in Septembe In addition, one new hire for terminations was hired in September and one other person certified in terminations on October 3,198 All personnel certified in terminations were not performing termination inspections in September. The normal practice was to shift personnel over to termination inspection based on the work loa Looking at this concern in this light, a total of five people were shifted to termination inspection between August 6 and October 3, 1986. The Staff concluded that termination inspection was adequately manne . Concern No. 4 - I need my own set of drawings for special termination I had to borrow the drawings from the craft personnel to do my inspectio The Staff's review of this item indicated that the QC Department has two complete sets of controlled drawings. Drawings (details) are issued to the inspectors as required for their inspections. The Staff determined that this concern described an isolated case because it was for a special termination using the manufacturer's drawing . Concern No. 5 - Form 36 (termination inspection) says to inspect conductor for damage where the jacket has been stripped back for damage, but the work is completed prior to the inspection and this area is already tape The Staff's review of LKC Procedure No. 4.8.9, " Cable Termination Inspection," indicated that Section 3. requires that the inspector verify that the conductors have not been cut, nicked, or damaged'where the jacket ,
has been removed. The procedure also requires 1 in process inspection of at least one phase of all
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scheduled for tape or heat shrink tubing installatio Further, Section 6.5.1 of the procedure requires a once a month in process inspection on . ten cable ends for cable jacket stripping to ensure that the conductors have not been cut or damaged where the jacket has been remove The Staff concluded that the concern sas justified since the procedure was not clear as to what the QC inspector was required to verify and when was he required to accomplish it. . Discussion of this concern with CECO PCD indicated that Section 3. referred to inspecting visible conductor from the point where the Jacket was stripped t6 the end, while Section 6.5.1 referred to in process inspection of the stripping process only. As a result of this concern, CECO committed to training the LKC QC inspectors on the content of the above sections in the next procedure revision trainin . Concern No. 6 - Disposition of NCR No. 4966 said to repair cut area of cable No. IVP004 per Okonite Drawing No. D-5715. When the NCR was evaluated by Project Field Engineering, they said to reject the LKC recommended disposition and substituted their own paragraph instead. The inspector was concerned that they had rejected the cable manufacturer's recommended repair while substituting their ow The Staff interviewed the CECO Project Field Engineering Supervisor who stated that he had personally inspected the cable and determined that
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the jacket was not cut through to the insulation therefore, repair per Drawing No. D-5715 was not appropriate. He further stated that the paragraph they substituted gave Okonite's recommended repair from Drawing No. D-5721. The Staff verified that the paragraph written by Project Field Engineering and Drawing No. D-5721 were identical; therefore, I this concern is close l Concern No. 7 - On junction box walkdown, per the work i instruction, craft repairs certain minor items such as seg code, cleanliness, missing cover screws and adding square washers. These items normally require an ICR under regular inspection l The Staff reviewed LKC Work Instruction No. WI-4.3.13-01,
" Work Instruction For Box Evaluation," Revision D. This
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work instruction was generated to address the generic corrective actions recommended by five previous NCR o These NCRs were No. 665, "0-rings in Wet Areas"; No. 687, l
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" Grey Paint in Boxes on Containment"; No. 707, " SIS Wire"; ;
No. 723, " Aluminum Paint in containment"; and No. 763,
" Marathon Terminal Blocks." The Staff's review of the work instruction indicated that the cra5t could only repair certain minor items. They could not perform any work that would require major rework or pull-out and re-termination of cables. The work instruction was an approved procedure which had received approval from LKC management, QA, QC, and engineering. It had also been 4 approved by CECO PCD and Q In addition, it required ,
that corrective action documents be generated for rework and that the QC inspector complete a QC checklist which required engineering evaluatio '
The Staff concluded that this corrective action work instruction was acceptabl . Concern No. 8 - LKC does not have a procedure for repair of jacket or insulation damag The Staff's review of LKC Procedure-No. 4.8.8, " Cable Installation Inspection," indicated that Appendix D contained CECO's criteria for evaluation of damage to cables. This appendix requires that LKC notify CECO by NRC if minor kinks, twists or gouges are foun '
i The lack of a LKC procedure was discussed with the Ceco Project Field Engineering Supervisor. He stated that the .
intent of the Appendix to the procedure was to assure that
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his department would personally inspect all damaged cable. Then in turn, they would give the required corrective action via the NCR. In the case of minor
- Jacket damage the manufacturers procedure, which was reviewed and approved by S&L, is employed. For major damage such as exposed conductor, the cable is cut and spliced using the approved LKC Procedure No. 4.3.9,
" Cable Termination Installation."
The staff concluded that the inspectors had adequate guidance for damage to cable .
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Concern No. 9 - NCRs and ICRs have to be reviewed by a supervisor before a number will be issued. The QC
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inspector was concerned about having to argue with a supervisor in order to write a NCR/ICR when they disagreed l
about a possible nonconformanc The staff's review of LKC Procedures No. 4.11.1,
" Nonconforming Items," and No. 4.11.2, " Inspection Correction Report," produced the following information:
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(a) Section 3.1.2 of the ICR procedures requires review and concurrence by a Supervisor / Designee prior to
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obtaining a numbe (b) Section 3.3 of the NCR procedures requires the inspector to complete the first section of the NCR and the hold tags, with the assistance of the QC Records Clerk who will provide the NCR number, prior to review by the QC Manage The contents of the procedures was discussed with the General QC Supervisor. He stated that the reason'for the reviews was to prevent unnecessary NCRs/ICRs. When asked
to explain unnecessary he stated that LKC has a large i number of NCRs and ICRs that had been written and later voided or closed-out without any corrective action required. He further stated that the inspectors were encouraged to write NCRs, and not the opposit The Staff's interviews with the inspectors did not indicated any undue pressure on the inspectors relative to writing NCRs/ICRs. The staff concluded that the existing system is acceptabl .
3. Exit Interview The inspector met with licensee and contractor r epresentatives denoted in -
Paragraph I during and at the conclusion of the inspection on November 14, 1986. The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection repor The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur .
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