IR 05000461/1985051

Safety Insp Rept 50-461/85-51 on 850924-26 & 1025.Violation Noted:Lead Instrument Verification Engineer Did Not Meet Educational Requirement Per Baldwin Assoc Resident Engineering Job Description

ML20136H264
Person / Time
Site:	Clinton
Issue date:	11/19/1985
From:	Danielson D, Kaufman P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136H218	List: IR 05000461/1985051 ML20136H212 ML20136H224
References
50-461-85-51, NUDOCS 8511250071
Download: ML20136H264 (6)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/85051(DRS)

Docket No. 50-461 License No. CPPR-137 Licensee:

Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted:

September 24-26 and October 25, 1985

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Inspectors:

P. D. Kaufman Date

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Approved By:

D. H. Danielson, Chief Mate.ials and Process Section Date Inspection Summary Inspection on September 24-26 and October 25, 1985 (Report No. 50-461/85051(DRS))

Areas Inspected:

Routine, unannounced special safety inspection of allegations.

The inspection involved a total of 26 inspector-hours onsite by one NRC inspector.

Results: Of the areas inspected, one violation was identified (failure to follow documented instructions - Paragraph 2 [ Concern 1]).

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

• S. B. Fisher, NP&S Manager

• J. W. Wilson, PPM

• D. Hall, Vice President

• R. W. Greer, Manager, Q&TS J. Loomis, Construction Manager R. F. Schuller, Supervisor, Technical

• H. Daniels, Jr., Project Manager

• J. Greene, Manager, Startup

• J. Perry, Manager, Nuclear Program Coordinator

• K. A. Baker, Project Engineer, I&E Interface l

• F. Spangenberg, Manager, Licensing and Safety l

W. Connell, Manager, QA C. E. Calhoun, Quality Projects Coordinator

• D. C. Shelton, Manager, NSED

• R. E. Campbell, Director, Quality Systems and Audits Baldwin Associates, Inc. (BA)

• E. P. Rosol, Project Manager

• J. Thompson, QE Manager L. Campbell, Technical Assistant /TPRG C. L. Solter, TPRG Engineer B. S. Auer, Technical Assistant /TPRG L. Osborne, Manager, Q&TS Stone and Webster Engineering Corporation (S&W)

P. H. Seidel, Manager, TPRG

• Denotes those attending the exit meeting.

2.

Followup on A11egaticas (Closed) Allegation RIII-85-A-0047 An alleger contacted the Clinton NRC Resident Inspector's office on May 22, 1985, and again on May 31, 1985, with additional concerns other than those previously identified and documented in Region III Inspection Report No. 50-461/85026. The technical aspects of the additional concerns have been evaluated and are closed as described in the following paragraphs:

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Concern (1)

Baldwin Associates Resident Engineering " Lead Engineers" are not technically qualified to perform their jobs. Most are not degreed engineers and most have insufficient nuclear construction related experience to properly carryout the duties and responsibilities of their job descriptions.

NRC Review This inspection encompassed confidential interviews of personnel and reviews of the following documents: job descriptions, personnel resumes, and organization charts. The Baldwin Associates Resident Engineering (BARE) organization is separated into the following sections:

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Mechanical, Field Engineering, Traveler Preparation and Review Group (TPRG), Electrical, and Civil / Structural.

Comprised within these various groups are approximately 20 designated " Lead Engineer" staffing positions which were the source of this review sample.

A review of the BARE job descriptions, which outlines responsibilities, educational, and experie ice qualification requirements for each defined

" Lead Engineer" category, was compared to the individuals' resumes holding those positions.

It should be noted that these " Lead Engineer" positions within the BARE organization are called engineering in title only and that the defined activities performed by these individuals are not considered to be engineering intensive. The tasks conducted by the individuals in these engineerint positions would only require a good understanding of construc-tion practices, an ability to read and understand specifications and drawings, and be able to prepare appropriate paperwork for the craftsmen.

The technical design engineering functions are performed by Sargent and Lundy, General Electric, or IP's Nuclear Station Engineering Department.

The BARE engineers develop Field Change Requests (FCRs), which are then submitted to the above engineering design organizations for resolution to the field problems.

Of the 13 lead engineering personnel qualifications verified, it was determined the individuals met their job description education and experience qualification requirements pertaining to their specific position titles with the exception of the " Lead Instrument Verification Engineer" whose job description educational qualification requirement specifically requires an engineering degree.

This particular individual did not have a college degree, but did have some college credits accumu-lated in an engineering related discipline and five years related work experience. The educational requirement stipulated on the BA job description did not permit for a waiver of the engineering degree require-ment based upon equivalent work experience.

A personal interview with the above individual revealed that this position was held by this person from approximately July 1983, through February l

1984, and again from December 1984, to the present. While in this post-tion, one of the individual's activities consisted of rerouting Seismic Category I instrumentation lines inside the Drywell on the Nuclear Boiler

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(NB) System ( Since this individual did not meet the BA job description educational qualification requirements the licensee was requested to evaluate the significence of this, along with determining what other work was performed by this person and sample the individual's previous work.

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Additionally, the individual had not seen nor was aware of the specific job description pertaining to this lead engineering position until being shown a copy by the NRC inspector.

Conclusion The concern was substantiated, in that one of the 13 individuals reviewed did not meet the specified educational requirements for the defined position as required by Baldwin Associates Resident Engineering job descriptions. The licensee was informed that failure to follow prescribed l

documented instructions, procedures, or drawings is a violation of 10 CFR 50, Appendix B, Criterion V (461/85051-01).

Concern (2)

Baldwin Associates (BA) supervisors are advising subordinates not to perform required reading under BA's training program, but to just sign the required reading list form and do the reading at a later date.

Later never came, therefore the reading never got done.

This is a common practice onsite.

NRC Review This inspection encompassed reviews of Baldwin Associates Resident Engineering (BARE) personnel training files, selected confidential interviews with engineers, supervisors, and technical assistants, and procedural reviews of BA's Project Training Plan, Revision 8, and BA's Turnover Training and Qualification Manual, dated November 26, 1984.

Resident Engineering personnel have training matrices associated with their individual or group job responsibilities established by Department Managers and Senior Discipline Superintendents. This matrix identifies both Mandatory Reading and Required Reading for each job position. An individual denotes the completion of the entire list of required readings, which is comprised of procedures, codes, standards, and specifications by initialing and dating opposite each applicable document identified on the JV-931 form, " Employee Required Reading." The reading of subsequent procedure revisions or specific department reading is documented on a JV-1002 form, " Mandatory Reading."

The inspector reviewed several training files of TPRG personnel to assure that a current JV-931 form was completed, -igned off, and dated of the required reading for the individuals' current job responsibilities which is a prerequisite before performing the job. After verifying the above, the individuals were personally interviewed by the NRC inspector to ascer-tain if they were ever approached by supervision to just sign and date the JV-931 form and complete the required reading at a later date, of which later never came, so the reading never got completed.

In conjunction with

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TPRG personnel interviewed, the tiRC Clinton Resident inspectors interviewed two individuals who had worked for the alleger's previous supervisor (FieldCoordinator/ Subcontracts). Of the individuals interviewed, none indicated that they had ever been asked by their supervisors to sign off the required reading list and complete the reading material at a later date.

In addition, none of the individuals had ever heard of this type of prac-tice being conducted anywhere on the jobsite. With regard to not reading the material, they mentioned that it would be to a person's disadvantage not to read the required reading material, since a lot of the piecedural information pertained to their everyday work assignrrents.

The forn;er supervisor of the alleger was interviewed by the f4RC Clinton Resident inspectors to determine if he had ever either suggested or directed his employees to sign the mandatory reading list without first reading the material. The response given was that he was unable to ren. ember if he had ever either made such a suggestion or given such directions. However, he emphatically stated that as a matter of policy, all required reading n;ust be completed, even if the material does not directly apply to the job at hand. He further stated that the reading materials were kept in a central file after the reading list was signed for reference purposes and that anyone who had not completed the reading would be free to access the file to complete the reading.

, Conclusion Based on the above NRC review, it was deterniined that insufficient supporting inforniation existed to ascertain if the allegation had merit, as to whether or not the person making the allegation was ever told to sign-off the JV-931 fom without first doing the required reading.

However, based on interviews with other engineers and technical assistants in the BARE organization, it was evident that none of those persons interviewed were ever told to just sign the required reading list form and conplete the reading at a later date.

Em p l oymep,t, _D,i_s c,r,i m i n a t i_o n, A1,1 es a,t_ip n.

In addition to the individual's technical concerns, he also filed a complaint of employment discrimination (10 CFR 50.7) against Baldwin Associates with the U.S. Department of Labor. By letter dated July 3, 1985, the U.S. Department of Labor Employfrent Standards Administration.

Wage and Hour Division, concluded,

... Our investigation did not verify

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that discrimination was a factor in the actions comprising youi complaint.

Conversely, it is our conclusion that your allegations are unprovable for the following reason: The layoff was found to be part of a planned reduction in force..."

The individual subsequently appealed the above decision to the U.S.

Departrnent of Labor Chief Administrative Law Judge. On November 4, 1985, the Department of Labor Administrative Law Judge issued an Order of Dismissalstating,[n"PursuanttothewrittenMotiontoDismisssubmitted at the Hearing by amed individual's] attorney advising that [ named individual)nolongerwishestopursuethesecases,itisOrderedthat these cases be and hereby are DISMISSED."

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3.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

on October 25, 1985 and discussed the scope and concerns of this inspection. 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.

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