IR 05000528/1982032
| ML20028C976 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/27/1982 |
| From: | Fiderelli G, Andrea Johnson, Johnston G, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20028C973 | List: |
| References | |
| 50-528-82-32, NUDOCS 8301140362 | |
| Download: ML20028C976 (7) | |
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- U. S. tiUCLE.AR PICUIATORY COMMISSIOli
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PIGIo!! V Report i;o. 50-528/82-32
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Docket :to. 50-528 License rio. CPPR-141 Safeguards Group Licensee: ' Arinna Public Service Co.
P. O. Box 21666 Phoenix, Arizona 85036 racility Itace: ~ Palo Verde Nuclear Generating Station Unit 1 Inspection at:
Palo Verde Site, Wintersburg, Arizona Inspection condu ced:
November 18 - December 17,,1982 Inspeetors:
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Approved by:
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T. Young, Chief, actor oj s Section 2 Date signed
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Oate Signed
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Inspection on November 18 - December 17, 1982 (Report No. 50-528/82-32)
Areas Inspected: Special, unannounced inspection of prerequisite testing.
The inspection involved 130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br /> onsite by the resident inspectors and the enforcement officer.
Results: No iten.s of nonccmpliance or deviations were identified.
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Persons Contacted
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'a.'. Arizona Public Service Company?(APS)
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. *G. C. 'Andogninti Electric 0pbations' Vice President
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?J.' Roedel,, Corporate Quality. Assurance Manager
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- J. Kirby,. StartupL Manager-
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~ *G.7 Pankonin, Startup Quality' Assurance / Quality Control (QA/QC)
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W. Craig, -Startt.p Quality Control Supervisor -
J. Barrows, Nuclear Engineering Manager
. B. Gourley, Quality ~ Control' Inspector
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Bechtel Corporation
J. Zeruka, Prerequisite Startup Manager
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J. Roberts, Electrical Project Group Engineering Supervisor Fifteen Startup Engineers.
R; Moody, Training Coordinator i
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- Attended Exit Meeting 2.
General-A special inspection was conducted to review the circumstances associated with a communication received by the NRC from a startup
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test-engineer employed at Palo Verde Nuclear Generating Staticn who expressed concerns about the test completion quota system being
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administered by the Bechtel prerequisite startup organization.
The individual, who was a contract employee assigned to the~Bechtel
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electrical prerequisite startup organization, had been terminated recently by the Bechtel Corporation because of work performance related reasons.
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Prerequisite Quotas One of the concerns of the startup engineer who had contacted the
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NRC, on November 17, 1982, was related to the use of a test completion l
' quota system that had been in effect for about one month and which t
was imposing undne pressure on test engineers. A total of fifteen l
prerequisite testing personnel, who were interviewed by the inspectors, i
informed the inspectors they were working with the understanding that a quota system (bean count as they had characterized the quota system)
was being used to establish a completion rate-for prerequisite testing.
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This quota was understood by most to be one completed test per person
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per shift.
(A Bechtel letter dated October 27, 1982, indicated that 100 test per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be needed if project milestones were to be
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met.) The understanding of the responsibility for meeting this quota,
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varied.with individuals. 'A few individuals indicated'that the
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-quota was considered to be a goal to be' achieved,'others felt it to be a firm rule and if. not met could result in termination.
In some
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cases individuals had been criticized by supervision and management for-not meeting the quota.
One of the main criticisms was that the program was unfaii and created undue pressure with the loss of employment as a possible consequence. While some. tests could be done in several hours, others required several shifts.: In addition to the actual time required to do the" tests, varying amounts of time were required to carry out test preparation.which could be extensive because of tagging delays, test package omissions, craft. support delays, and
.special reports which.had to be filled out when unusual problems were encountered.' = Most individuals felt these delays were not taken into account by prerequisite startup management. Of primary
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concern by most was the' potential for compromising the quality of testing because of-the undue' pressure placed on people to meet test
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One' individual who was involybd in balance of plant testing had
indicated some personal: experiences with'a non-safety system he was
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testing in which'his work had to'be repeated because of what appeared to be failure of others'to follow proper administrative controls.
He speculated that this could_ have been created by the quota system.
Another indicated a la::k of understanding by one individual,-
responsible for. the direction of a test, on how to fill out the first page or preparation portion of the test-data sheets. Another case was cited where one individual.did not fill out a formal.
startup field report used to document deficiencies because of time
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constraints imposed by the quota system.
In a few cases, individuals understood some supervisors as pressing the completion of tests.
One instruction revealed to the inspectors was'"I don't care how the test gets _done, just get it done."
Several individuals indicated that they were not concerned about
.the quota system and all stated that, while the potential for test bypassing or falsifying test information could result from undue pressure, none would compromise their professional standards and l
'all would do the job properly regardless of the consequences for
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not meeting testing quotas. None of the individuals interviewed indicated that supervision or management directed or indicated that testing should be short circuited to achieve quotas.
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x Each of the'indiv'iduals ' interviewed indicated that'he had not been
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-involved in the practice 'of performing substandard testing and none we're aware of or could provide * specific known cases where this had
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occurred. - A letter dated September 21, 1982, from Bechtel Management to its startup employees stating se' vere disciplinary action would be taken for violation of procedures-or work rules _is on file.
One of the-statements made by,the indisidual who contacted the NRC
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was that 500 prerequisite test h~ad been completed the week previous
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to his termination.
It was' determined by a review of test completion statistics by the inspectors that'the number referred to actually-represented the number:of prerequisite tests which had gone through the Bechtel review process that week. These tests could have started earlier-than that week. A review of statistics indicates that during the past seven weeks, test review completion averaged approximately 675 per week.
Discussions were held with two test engineers who stated one of their principal responsibilities was to review completed test packages. Both informed the inspector that among the many items checked was questionable and inaccurate data. When found, packages were returned to-indviduals or their supervisor for resolution.
Both stated the frequency of test returns was steadily decreasing.
They assured the inspectors that maintaining a high quality of test results was their primary objective.
~A review of randomly selected completed test packages by the inspectors prior to their review by the Test Review Group and quality control (QC) indicated that with minor exceptions data sheets were complete and test data appeared to have been entered in accordance with procedures.
As an APS follow-up action,' the inspector was informed that test engineers will be informed that project testing goals will continue to be maintained in order to meet project milestones, however no individual " bean count" will exist.
Furthermore, the quality of testing will continue to be stressed over production.
A letter to this effect has been issued to test engineers by the Bechtel startup manager.
No items of noncompliance or deviations were identified.
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Tes' ting Duplications A majority of the individuals interviewed confirmed that some prerequisite testing had been duplicated, however, the reasons for this varied with individuals.
Some test directors believed duplicate testing was related to the quota system, while others felt it to be associated with the need for additional program debugging.
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Some ' speculated thht' a test 'in progress known to be duplica'ted but
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be' stopped because it would have a negative;effect on meeting test quotas. 'Some individuals attributed the long lag time required for t
.the completed. tests to undergo review, distribution, and status entry into the test schedule as the cause for duplication.
In such cases completed. tests could be reassigned because the test. schedule did not recognize the. test to be completed. Others. felt inaccuracies in the test schedule, the document which identifies the' tests required and their status, contributed to.the duplication. One test involving a lightning. arrestor was mentioned by several individuals as having been done several times.
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None of the iridividuals felt' that retesting created a safety problem.
At worset, some components might be. receiving additional wear, would require earlier replacement and the practice represented a less
' than optimum utilization of resources.
APS manLgement recognized the duplication of testing as a problem.
. Improve'ents had been made during recent months in which duplication had been reduced from 8 percent to.1 percent.
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As an APS: follow-up action, the inspectors were informed that-several e# forts are in progress to minimize duplicate testing. One involves the continued upgrading of the test schedule.to accurately reflect testing status.
The other involves the centralization of several key document controls to improve the logistics, control, and accounting of testing information.
No items of noncompliance or deviations were identified.
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Equipment Tagging and Clearances Two cases of equipment tagging administrative control violt.tions were provided to the NRC by the individual. Of concern was the feeling that undue pressure placed on startup engineers to complete tests would lead-to a reduction in " personnel safety."
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past, the inspectors had discussed tagging violations with the applicant in the context of a reduction in administrative control.
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APS has taken a firm stand on this issue which includes the policy l
I that persons violating-tagging controls would be terminated if the circumstances warranted the action.
Recently one test director who was associated with_one of the tagging violations provided to the NRC was terminated.
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As a follow-up effort, the inspector was'infonned that continued l
' training will be stressed with strict disciplinary action taken
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when violations-occur.
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l No items of noncompliance or deviations were identified.
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Prerequisite = Testing Support Ma'ny of the concerns expressed to the inspectors by fthe individuals -
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interviewed were related to testing support in the form of work areas, desks, training, 'and test package completeness.
In-recent months Bechtel-had increased its testing staff by approximately-130. test' engineers, approximately.85 in the electrical testing discipline...This action has impacted significantly'on training of
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personnel and the availability of working accomodations..Some individuals = complained of a lack of desks and work space. Cases were cited that, because of the shortage of desks and work tables, documents left on desks or. tables. at the completion of the shift-could not be located 'the next shift when testing was to be resumed.
. Individuals expressed a feeling of frustration that these conditions resulted in schedule delays and low morale.
Test' directors are provided test pickages when assigned tests to be
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completed.
Some: individuals indicated test packages had not always
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contained the required documentation.or informtion. This required the individual to take time to secure the proper reference and test information resulting in, delays in testing.
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Several' individuals expressed varying comments on testing procedures.
These comments varied from excellent and comprehensive to incon-sistencies-between procedure and data sheets. All had confirmed that the exercise of technical judgement in the conduct of component tests was required'and had conducted their testing accordingly.
As a follow-up action, Bechtel informed the inspectors that procedures reviews are' ongoing.
Comments received from test engineers will be factored into procedure revisions. Also other support items such as the issuance of radios will be reviewed to help test engineers.
No items of noncompliance or deviations were identified.
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Certification and Training Records Several individuals interviewed commented that the training they had received was minimal. One individual who has since left the project indicated he felt uncomfortable in the testing of high voltage equipment. - Others indicated that there should be more training in administrative controls while several indicated a disappointment in the technical training received.
None expressed that the testing they did was incorrect, but indeed required more time and more help than should have been necessary had they received more training.
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A review of personnel training and' certification ' records indicate training activi d es were conducted in accordance with the program description. - Certifications:of test directives wera on file-as well as training records which indicated some technical on-the-job training and administrative training (mostly reading assignments and some class instruction) had been given to those interviewed.
Classroom training on administrative controls was noted to be inconsistent among test engineers..
As a follow-up action, APS informed the inspectors that training needs will unaergo further review. One effort discussed was the confirmation in writing by experienced test engineers that newly.
hired test engineers have actually implemented key administrative critical. procedures properly and understand their responsibilities-for proper implementation.
No items of noncompliance or deviations were identified.
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APS Follow-up-Action'
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Two follow-up actions were undertaken by APS to investigate and review the circumstances associated with the complaints about the test' quota program by Bechtel,startup test engineers. One action consisted of the review of completed startup test packages to determine that testing procedures were followed.
Results from this review which were done prior to the required Test Review Group review revealed.that only minor discrepancies existed with established procedu're ~(test packages receive a level three review by Bechtel Startup, APS QC, 'and the APS. Test Review Group).
In addition, a
' sample of tests which were completed during the past 30 days will be redone.to compare test data.
A second follow-up effort involved the'. interview of test engineers by a panel of senior staff members
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from APS'and Bechtel.
Findings and recommendations from the investigation
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have been made to APS management for appropriate action.
No items of. noncompliance or deviations were identified.
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Exit Meeting
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A meeting was held on December 1,1982, with Mr. G. C. Andognini,
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Vice President of Electric Operations, and his staff and with Mr. G. Pankonin, Manager Startup QA/QC. The findings of the special inspection were presented to Mr. Andognini who provided the inspectors copies of the APS task force report.
He also assured the inspectors-corrective action to the findings would be made. These have been noted in the body of the report.
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