IR 05000254/1988025
| ML20154L806 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/20/1988 |
| From: | Schapker J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20154L791 | List: |
| References | |
| 50-254-88-25, 50-302-88-26, NUDOCS 8809260302 | |
| Download: ML20154L806 (6) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report Nos.:
50-254/88025(DRS);50-265/88026(DRS)
i Docket Nos.: 50-254; 50-265 License Nos: DPR-29; DPR-30
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Licensee: Comonwealth Edison Company
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Post Office Box 767
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Chicago, IL 60690
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Facility Name: Quad Cities Station, Units 1 and 2 Inspection At: System Materials Analysis Department, Maywood, IL
Inspection Conducted: September 8and14,1968 l
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Inspector:hJ. F. Schapker 7/l W /'
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cxd7 hb Approved By:
D. H. Danielson, Chief M2e //'
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'Mcterials and Processes Section Da te
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Inspection Sumary Inspection on September 8 and 14, 1988 (Report Nos. 50-254/88025(DRS);
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Areas Inspected: Unannounced special inspection of licensee's written practice for nondestructive examination pertaining to the "25% Rule" as described in
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SNT-TC-1A and review of NDE personnel qualification records in accordance with
the 25% Rule.
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Results: Review of the wr.tten practice - Ceco SPPM Procedure 1-1-0,
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Revision 24, disclosed the following:
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The procedure reflects the words of SNT-TC-1A in regards to the
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25% Rule.
The description of the Radiograph (RT) Interpreter, Level II's duties
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f does not adequately describe the limitations of his/her qualifications.
i Certification requirements for experience is not adequately
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i described for the RT Interpreter Level !!.
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c Review of the Ceco personnel quclification records revealed the following:
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Ceco NDE personnel were qualified to perfona/ survey nondestructive
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i testing in the disciplines referenced in their NCE qualification
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Certain personnel who qualified as RT Interpreters, level II, do
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in SNT-TC-1A for a Level II radiographer.
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Resul tsj, continued:
Although the written practice did not adequately descilbe the RT Interpreter's working limitations and the training :nd experience of the RT Interpreter's reviewed was not adequate for these individual to perform code acceptance of radivgraphs, the actual perfornance of individuals qualified in this categotj is e Quality Assurance / Quality Control function and no coda acceptance nf radiographs is performed by these individuals.
The licensee has committed to revise SPPM 1-10 to reflect the working limitations of Level II RT Interpreters and specify the appropriate qualification requirements for this of the individuals identified in Unresolved Item (50-235/88011-04)ponsibilities classification. These corrections will clarify the duties and res The
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licensee's corrective action to resolve this item is comn.ensurate with SNT-TC-IA and applicable Code and regulatory requirements, t
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DETAILS 1.
P_ersons Contacted Comonwealth Edison Company (CECO)
System Meterials Analysis Department (SMAD)
- W. Witt, Chief, Level III, NDE R. Gaitonde Supervising Staff Engineer C. Polito, Panager, SMAD The NRC inspector also contacted and interviewed other licensee and contractor employees.
- Denotes those contacted at the telecon final exit interview on September '.4, 1988, 2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item 50-265/88011-04:
BACKGROUND A routine safety inspection of station activities at Quad Cities Station, Units 1 and 2, was conducted by the NRC NDE Mobile Team of the NRC's Region I office during April 18 thrcugh 29, 1988. A part of the NRC inspection activities consisted of a selective examination of procedures and representative records. The NRC inspector, during his review of Ceco's Special Process Procedure Manual (SPPM), made an observation that the requirer;ents in CECO's '/9M are not consistent with or do not meet the intent of the SNT-TC-1A. As a result, Mr. J. J. Harrison, 'iRC Pegion III, requested a written response to the item (No. 50-255/88011-04) in a letter dated June 21, 1988 to Mr. C. Reed, Comonwealth Edison Company.
The iia.C inspector'
abservation pertains to the "25% Rule" in recomended Practice Nn. SNT-10-1A, June 1980 Edition, published by the American Society 'or Non-Dostnctive lesting (ASNT) and the requirements in the Procedure 1 1-0, Revision 24, of Ceco's SPPM. The NRC inspector stated that the CECO procedure in the SPPM has improperly used the SNT-TC-1A 25%
rule and that a possibility exists that Ceco NDE personnel could fulfill certification requiremer.ts without satisfying the ASME rv. wirements for minimum experience.
The conclusion was based on the review of the certification of one CECc individual who spent most of his work time on Quality Control (QC) related activities not involving actual application of NDE. The NRC inspector believed this individual may have been certified using the 25% rule. The individual referenced here is actually certified as a "Radiographic Interpreter", a special category of NDE personnel identified in Ceco's SPPM.
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INSPECTIQN The NRC Region III inspector reviewed the CECO response to tne unresolved item. CECO believes that the application of the 25% rule and qualification requirements of "Radiographic Interpreter" are two separate issues. Firs t, the response to the 25% rule was as follows:
Table 6.2.1A of SNT-TC-1A contains a statement "credit for experience may be gained simultaneously in two or more disciplines.
The candidate must spend at least 25 percent of his work time on each discipline for which experience is claimed." This provision has been incorpora:ed into procedure 1-1-0, Paragraph 6.1.1 of Ceco's SPPM in which it is required that "an individual may gain field experience in two or more NDE methods simultaneously. The individual must spend at least 25% of his work time on each NDE method for which field experience is being claimed." T s clearly shows that CECO's requirements in the SPPM are consistent with those in the SNT-Tr 'A.
PERSONNEL QUr /ICATION REVIEW The licensee reviewed the qualifications and certification of all present and past Comonwealth Edison Com)any personnel where the SNT-TC-1A 25%
rule was used. The results of tie review of the certification records showed that, of the seventeen NDE inspectors qualified within the Commonwealth Edison system, six work in SMAD which is a group dedicated full time to performing NDE. The remaining eleven are assigned to various generating stations. Of those eleven, eight are qualified and experienced individuals who were hired into Comonwealth Edison from outside NDE companies.
It was the licensee's understanding that the question of adequacy of training and experience pertains to neither the SMAD NDE group nor ' ith respect to experienced inspectors recruited from outsidt testing companies. The question was raised in regard to those Ceco qualified individuals who are not full time NDE personnel. The licensee's records show only three inspectors fell into this category. Two are certified to perform only penetrant testing (PT) and one is certified to performthePTandmagneticparticletesting(MT).
If the
)rovision in the SPPM and SNT-TC-1A for simultaneous qualification
using t1e 25% rule was to be used, it would have been in the case of
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this one individual who is certified in both PT and MT. The review of this certification showed that the 25% rule was not invoked. He had
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l logged one month's work experience as defined in the SPPM for each
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discipline separately before he was certified as a Level I inspector. He j
also worked an additional two months as a Level I PT inspector before
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becoming a Level 11 PT inspector, and an additional three months as a
Level I MT inspector before being certified as a Level II MT inspector.
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Even though Ceco's SPPM provides for use of the 251 rule as stated above, I
a review of personnel certification records showed that this rule was not invoked for CECO qualified inspectors.
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The NRC Region III inspector's review of NDE personnel qualification
i records confirmed that the licensee's review was accurate excepting
the qualification of the Level II Radiographic Interpreters in which the
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licensee responded as a separate issue. The response is as follows:
Radioaraphic Interpreters
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A special subcategory of NDE personnel certified as "Radiographic
Interpreter" is identified in the SPPM.
This special "RT Interpreter"
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category was created to develop individuals who would have sufficient
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knowledge of RT method to review radiographic work done by outside testing contractors. As specified in Cearnonwealth Edison Company's
"writtenpractice"(SPPM),an"RTInterpreter's"dutiesarelimited to reviewing the radiographic work performed by the others to ensure
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that radiographs are of good quality and that proper codes and standards have been followed and that defects have been properly identified and evaluated. These RT interpreters are neither trained to perform actual radiography nor are they allowed to specify teciniques or test parameters. We believe that with these limitations, the subcategory of RT Interpreter, is acceptable and meets the intent i
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of the code because:
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It is permissibic according to the SNT-TC-1A recommended i
practice to create subcategories of NDE personnel depending
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responsibilities, qualification requirements, and any limitations on their certification are described in the employer's written practice.
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b.
Paragraph IWA-2300.a.3 of ASME Section XI, Winter 1980 Addenda,
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states that, "... training for NDE personnel who perform
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only one operation of a non-destructive examination method that
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contains more than one operation, or who perform non-destructive L
examination of limited scope, may be less than that reconrnended
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in Table 6.2.1A of SNT-TC-1A...".
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The licensee believes that reading and reviewing radiographs is only
one aspect of multiple tasks involved in radiographic testing.
CECO RT Interpreters receive extensive classroom training and they spend a minimum of three months reviewing radiographs under the supervision r
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of an experienced and certified RT person.
Finally, they take a
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I practical film interpretation test to demonstrate their ability to l
Ceco's Chief Level III before being certified as Level !! RT r
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j Interpreters.
These Interpreters played a valuable role in l
overviewing quality of a voluminous amount of RT work performed by
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the contractors during Connonwealth's nuclear plant construction program.
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The NRC Region III inspector pointed out to the licensee that i
Paragraph 5.1.5 of CECO's SPPM 1-1-0, Revision 24, which describes i
i the duties of an RT Interpreter, level II, does not adequately
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describe his/her duties as to limit him/her from performing ASME
Code acceptance work.
Paragraph 5.1.5 states:
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"A Level II Radiograph Interpreter may interpret radiographs, and evaluate the results with reference to ap)11 cable codes and specifications. He shall be familiar wit 1 the principles of i
radiography but shall neither make radiogrcohs nor specify techniques for doing so."
The licensee agreed to revise this paragraph to reflect the
limitations intended, as described in the above CECO description of the radiographers interpreter's Level II duties and limitations.
In addition, the lic.ensee agreed to revise Paragraph 6.2.C of SPPM
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1-1-0, Revision 24, which describes the certification requirements of a Level II RT interpreter. The revision in this paragraph is to specify the experience requirements methodology where two hours of film interpretation equals one day of experience. This formula
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applies only to the RT Interpreter position.
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CONCLUSION
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L The licensee does not utilize the RT Interpreter Level II position for
code acceptance of radiographs. However, the written practice, CECO I
procedure SPPM 1-1-0, Revision 24, did not adequately describe the RT Interpreter's Level II limitations as to code acceptances of radiographs.
The revision of the written practice as describad within this report will resolve this issue.
The licensee's revision of their written practice is adequate to assure that the ASME/SNT-TC-1A requirements are not violated.
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Exit Meeting The NRC inspector contacted the licensee representative (denoted in Paragraph 1) at the conclusion of the inspection on September 14, 1988.
The inspector sumnarized the scope and findings of the inspection activities. The licensee representative conveyed the changes in the l
licensee's written practice as described withir, this report. The i
inspector also discussed the likely informational content of the inspection i
report with regard to documents reviewed by the inspector during the
inspection. The licensee did not identify any such documents as r
proprieta ry.
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