IR 05000461/1979011

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IE Insp Repts 50-461/79-11 & 50-462/79-01 on 791030-1102. Noncompliance Noted:Inadequate Procedures & Practices Relative to Qualification of Testing Personnel
ML19211D295
Person / Time
Site: Clinton  
Issue date: 11/26/1979
From: Hayes D, Maxwell G, Suermann J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19211D296 List:
References
50-461-79-11, 50-462-79-01, 50-462-79-1, NUDOCS 8001170455
Download: ML19211D295 (8)


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U.S. NUCLEAR REGULATOD.Y COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-461/79-12; 50-462/79-01 Docket No. 50-461; 50-462 License No. CPPR-137; CPPR-138 Licensee:

Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:

Clinton Power Station, Units 1 and 2 Inspection At:

Clinton, Site, Clinton, IL Inspection Conducted: October 30-November 2, 1979

$ b N. h J. F. Suermann @

Inspectors:

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Approved By:

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. [ ayes, Chief

//-- 2/- /3 73 Engineering Support Section 1 Inspection Summary Inspectio-on October 30-November 2, 1979 (Report No. 50-461/79-11; 50-462/79-01)

Areas Inspected:

Routine, unannounced inspection:

review of licensee action on IE Bulletins and Circulars; review of qualification procedures for inspection and testing personnel; observaticn o containment structural concrete testing work; review of qualification records for testing personnel.

The iaspection involved a total of 41 inspector-hours on site by two (2) NRC inspectors.

Results: Of the four areas inspected, one item of noncompliance (an infrac-tion - inadequate procedures and practices relative to the qualification of testing personnel).

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DETAILS Persons Contacted Illinois Power Company AL. Koch, Vice President

  • J.

McHood, Vice President

  • J.

Geier, Vice President

  • E. Connon, Assistant Director, Construction F. Brashear, Site Manager
  • J. Hampton, Supervisor, Construction QA
  • R. Weber, Engineer, Construction QA
  • M. D' Haem, QA Electrical Engineer G. Wuller, Licensing Administrator
  • J. Spencer, Project Engineer M. Tindill, QA Engineer
  • R. Folck, QA Engineer
  • J. Smart, Senior QA Engineer Baldwin Associates
  • J. Linehan, QC Manager
  • G. Lane, Senior Electrical QC Engineer
  • D. Stephens, Senior Electrical Engineer
  • C. Winfrey, Senior QC C/S Engineer U. S. Testing Company
  • J. Grimm, Site Manager
  • D. Cook, Level III QC Inspector Hartford Steam Boiler Insurance Company
  • M. King, Authorized Nuclear Inspector
  • Denotes those present at the exit interview.

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Section I Prepared by J. F. Suermann Reviewed by D. W. Hayes, Chief Engineering Support Section 1 1.

Containment Structural Concrete - Procedures and Records The IE inspector reviewed the training and qualification procedures of U.S. Testing Company prior to reviewing the records of company personnel presently hired and who are currently performing inspection and examination services on concrete activities. The inspector had no comments on U.S. Testing Company Procedure QCP-6, " Training of Inspection and Test Personnel." Review of Procedure UST-TQ-1, Revision 9, " Training and Qualification of Inspection, Test and Audit Personnel," dated March 23, 1979 indicated that the procedure allowed experience factors, as a basis of qualification, that were significantly less stringent than the minimum capabilities specified in ANSI N45.2.6-1973.

The IE inspector reviewed the qualification records for 12 U.S. Testing Company personnel (1 - Level III, 7 - Le'el II and 4 - Level I).

The records were reviewed for conformance to U.S. Testing procedures and ANSI N45.2.6 with the following results.

(Note:

U.S. Testing Company is committed to ANSI N45.2.6 by Paragraph 111.1 of Specification No.

K-2937, Rev. O, dated December 10, 1975).

a.

UST Company Procedure No. UST-TQ-1, Revision 9, states in Section V, Paragraph 3.2 (Level I Requirements)

"To be considered for certification a candidate must (subject to the conditions of 3.1.2) satisfy one of the following requirements:

High school graduate plus six months of related experience in equivalent testing, examination or inspection activities at power plants, heavy industrial facilities or other similar facilities."

ANSI N45.2.6 - 1973, states in Paragraph 3.1.1, Level I, "To be considered for certification, a candidate must satisfy the fol-lowing requirements:

High school graduate; plus one year of experience in quality assurance, including testing or inspection (or both) of equivalent construction and installation activities."

b.

UST Company Procedure No. UST-TQ-1, Revision 9, states in Section V, Paragraph 3.3 (Level II Requirements)

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"To be considered for certification a candidate must (subject to the conditions of 3.1.2) satisfy one of the following requirements:"

"(1) One year of satisfactory performance as Level I, or (2) High school graduate plus three years of related experience in equivalent testing, examination or inspection activities at power plants, heav) industrial facilities or other similar facilities.."

ANSI N45.2.6 - 1973, states in Paragraph 3.1.2, Level II.

"To be considered for certification a candidate must satisfy one of the following requirements:"

"High school graduate, plus four years of experience in testing or inspection (or both) of power plant, nuclear plant, heavy industrial or other similar equipment or facilities."

Contrary to the above, of the 12 record files reviewed, only the files of the Level III inspector appeared to meet the requirements of both the company precedure and ANSI N45.2.6.

Of the remaining files, each one was found to contain one or more of the following discrepancies:

(1) Site conducted training, proficiency tests and visual /

physical tests post dated the date of the Document of Qualification, yet the qualification cited the proficiency tests as a basis for certification.

(2) Personnel did not meet the specified procedural requirements for prior experience and/or education at the time of hire.

(3) Experience and/or education was not verified to be correct and in some cases was not relevant to the work being per-formed as a QC inspector.

(4) Several Level II inspectors who were marginal in meeting the procedural requirements for Level I qualification at the time of hire were qualified to the Level II position five or six months later on the basis of a proficiency test and personal observation of the Level III inspector and then assigned to supervise Level I inspecurs. The proficiency tests implied the procedural requirement for one year's experience as a Level I was being waived.

Paragraph 3.1.2 of UST-TQ-1, Revision 9 and Paragraph 3.1 of ANSI N45.2.6 are recognized. These paragraphs state in part, that the education and experience requirements specified for the various levels should not be treated

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as absolute when other factors provide reasonable assurance that a person can competently perform a particular task.

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Based on the information provided to the inspector, the prior exper-ience of the subject U.S. Testing personnel does not appear to meet the intent of ANSI N45.2.6.

Further, UST Procedure TQ-1 is not considered consistant with ANSI N45.2.6 in that the experience require-ments for certifying Level I and Level II testing personnel are less restrictive than specified by ANSI N45.2.6.

This matter is considered in noncompliance with the requirements of 10 CFR Part 50, Appendix B, Criterion V.

(461/79-11-01; 462/79-01-01)

2.

Containment Structural Concrete - Observation of Work As a part of the overall records and procedures review af U.S. Testing Company, the IE inspector questioned four of twelve cur ent U.S. Testing Company employees and observed their performance of required concrete tests during a concrete pour in the Control Building. All four inspectors were able to adequately describe the required method of test and the frequdney of testing required by the pertinent specification and demonstrated that they could perform the tests satisfactorily in accordance with ASTM requirements.

No direct observation or specific information was obtained that would indicate at the present time that Laboratory Testing personnel are performing tests for which they are unqualified.

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Section II Prepared by G. F. Maxwell Reviewed by D. W. Hayes, Chief Engineering Support Section 1 1.

Licensee Actions on IE Bulletins and Circulars - Units 1 and 2 In regards to the following bulletins and one circular, the a.

inspector observed 4160 volt switchgear buses contained in switchgear numbered 1AP07, IAP09 and D.C. buses contained in battery chargers numbered IDC06E and 1DC08E.

The buses were stored in site warehouses.

(1) Bulletin 76-02 There were no General Electric HFA, HGA, HKA or HMA relays installed on the above buses.

(2) Bulletin 76-03 There were no General Electric STD transformer differential relays on the above buses.

(3) Bulletin 76-05 There were no Westinghouse BFD relays installed on the above buses.

(4) Bulletin 77-01 There were no ITE Imperial relays (catalog nos. J20T3/J13P20 and J20T3/J13P30) installed on the above buses.

(5) Bulletin 77-02 There were Westinghouse relays on the above buses. The licensee and S&L, through correspondence, indicated that they have not and will not use such type and vintage relays as described in Bulletin 77-02.

(6) Bulletin 78-01 There were no G.E. relays marked with manufacturers date code between E. D. (May 1968) and A. J. (January 1973) on the above buses. The licensee and S&L, through correspon-dence, indicated that they have not and will not use Celcon contact-arm retainers as described in Bulletin 78-01.

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b.

In reference to Bulletin 78-04, the inspector discussed the use of NAMCO D2400X or EA-740-40100 SNAP LOCK switches with the IPC Licensing Administrator. The inspector was shown correspondence from S&L and G.E. which indicated that such switches would not be used for safety related equipment inside containment.

The inspector reviewed internal correspondence which was written c.

by IPC engineering personnel in reference to Circular 76-04 wherein similar neutron monitoring bypass switches will be used at the Clinton Station. However, correspondence also revealed that the particular switches (identified as parts number 1931100G001 and 193B11G002) that are discussed in G. E. Document SIL 111, Revision I will not be used at the Clinton Station.

d.

The inspector discussed Bulletin 77-07, concerning containment electrical penetrations, with IPC engineering personnel. The inspector was informed that the Clinton Station will not use the type penetrations prescribed in Bulletin 77-07.

Further, that Conax will supply the penetrations for the Clinton Station and Clinton's penetrations have not yet been delivered to the site.

The inspector informed licensee personnel that each of the aforementioned items (1.a through 1.d) will be further evaluated by RIII inspectors after additional applicable equipment has been received at the site.

(461/79-11-02; 462/79-01-02)

No items of noncompliance were identified.

2.

Other - Units 1 and 2 a.

The inspector toured the site and interviewed several Baldwin Associate's (B. A.) and IPC personnel; as a result noted the following:

(1) Approximately 3% of the total safety related conduit has been installed.

(2) Approximately 23% of the total safety related cable trays / tray hangers have been installed.

(3) The site 6.9KV and 4.16KV switchgear is scheduled to be installed on or about March, 1980.

(4) Safety related MCC's are expected to start arriving at the site on or about December, 1979. The installation of these MCC's are expected to start in January, 1980.

(5) Safety related cable installation is not expected to start before June, 1980.

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b.

The inspector discussed with site electrical inspection and engineering personnel, some of the generic conditions which have occurred throughout the industry - concerning the instal-lation of Class IE equipment.

c.

The inspector was informed that the procedures which will be used for installation of Class 1E equipment (other than cable tray / tray hangers) have not yet been written / approved for use.

Further, that the electrical test proceOtres have not yet been finalized.

No items of noncompliance were identified.

Exit Interview The inspectors niet with site staff representatives at the conclusion of the inspection on November 2, 1979. The inspectors discussed the scope and findings of the inspection which were acknowledged by the licensee.

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