ML20198D546
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: |
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
//>
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
G PDR
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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
- T. E. Quaka, QA Superintendent
- R. M. Preston, Director-Quality First
- E. F. Wilmere, QA Supervisor
+E. E. Fitzpatrick, Assistant Manager QA
- G. E. Groth, Assistant Construction Supervisor
+L. M. Kline, Project Licensing and Compliance Supervisor
- C. Mennecke, Project Construction Department Supervisor
- W. E. Vahle, Project Field Engineering Manager
- E. Netzel, QA Supervisor, Electrical
+J. Gieseker, Project Field Engineer
L. K. Comstock and Company (LKC)
- 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.
- 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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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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.
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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
.
.
.
(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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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
, 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
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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-
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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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'
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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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,
-
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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
25
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