IR 05000528/1984052
| ML17298B655 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/20/1984 |
| From: | Clark C, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17298B654 | List: |
| References | |
| 50-528-84-52, NUDOCS 8412140420 | |
| Download: ML17298B655 (13) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-528/84-52 Docket No. 50-528 Iicense Nos.
CPPR-141 Licensee:
Arizona Public Service Company P.
O. Box 21666 Phoenix, Arizona 85036
'Facility Name: Palo Verde Nuclear Generating Station - Unit 1 Inspection at:
Palo Verde Construction Site, Wintersburg, Arizona Inspection conducted:
October 15-19, 1984 Inspectors:
u/~o/gy Approved by:
C.
. Clark ac r Inspector
. Miller,
, Chief ctor.Projects Section 2'ate Signed Date Signed Summary:
Ins ection on October 15-19 1984 (Re ort No.'0-528/84-52)
of an allegation, regarding qualifications of test personnel.
The inspection involved 37.5 inspector-hours onsite by one NRC inspector.
Results:
No violations were identified.
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DETAILS 1.
Persons Contacted a.
Arizona Public Service Com an (APS)
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Ide, Director, Corporate QA/QC Souza, Assistant Manager, Corporate QA/QC Hamilton, Quality Monitoring Supervisor Russo, Manager, Quality Audits and Monitoring W. Lossing, Quality Investigation Group Supervisor G. Moring, Quality Investigation Group Engineer The inspector also contacted other licensee personnel, including test engineers, QC document reviewers, document control personnel, and TWG members.
="Denotes those present at the exit interview.
2.
Pur ose of Ins ection This inspection was conducted to examine the technical aspects of the allegation regarding improper test personnel.
3.
(0 en) Alle ation Number RV-84-A-0097 Characterization:
An anonymous caller expressed concern that resumes of Level III certified contractors were routinely falsified at Palo Verde.
The contractors involved were said to be primarily non-Bechtel, e.g.
CALTEST, VOLT, EI, etc.
The falsification was primarily that individuals would falsely identify the title of their previous work experience, and the duration of that experience.
This falsification enabled them to receive a higher pay, since most contractor pay scales were said to be related to Ievel designation of the individual.
The alleger said that 50/ of the hundred or so Level III's he was familiar with had done this.
Some individuals were named as examples of people who received Ievel III certification based on falsified work experience on their resumes and in one case an unwarranted waiver of Level III requirements.
Im lied Si nificance to Plant Construction or 0 eration:
The startup test group is involved in technical acceptance and testing of the various systems in each unit. Therefore, acceptance of work and/or systems by improperly certified contractors/personnel could result in improper testing.
Assessment of Safet Si nificance:
a.
Technical Approach to Resolution
Examine licensee's procedures for qualification and certification of startup test personnel and compare these to licensee commitments for test personnel qualification.
I Review selected resumes for previous work experience, and determine if, the licensee's requirements were met.
Determine if the licensee has a program to verify the work experience stated in resumes.
Inspection Performed and Findings Identified
~Summa'he inspector examined the licensee's procedures and found that the licensee's procedures met their commitments.
In the course of the examination the inspector was made aware of the fact that the licensee had received a similar allegation through their "Hot Line" program, and had done extensive investigation into test personnel qualifications.
The same individuals identified to the staff had also been identified to the licensee by the 'Hot Line'elephone call.
The inspector elected to audit the effectiveness of the licensee's
"Hot Line'rogram while examining the efforts of the licensee's resolution of the similar allegation.
Thus, the inspector partially utilized the licensee's information to examine this allegation, The licensee's investigation showed that test personnel had received minor waivers in their experience requirements for Level III certification.
Although waivers are allowed by ANSI N45.2.6., this option was not available in the licensee's procedure at the time.
The licensee has subsequently revised their procedure to formally allow minor waivers and to provide guidelines for what can be waivered and how to document such authorized waivers.
The licensee also found, in verifying background experience of test personnel, one person (out of about 100 fully verified to date)
whose stated experience and education could not be verified and who chose to resign rather than explain the circumstances (thus indicating that his experience/education were falsified).
The licensee had not completed their investigative actions at the time of inspection and has not yet fully assessed the safety significance of the individual with an apparently falsified resume.
The inspector determined that the licensee's examination of these allegations is sufficiently thorough that an exhaustive independent NRC investigation is not warranted.
The NRC will examine the licensee's final actions in a future inspection as noted in the body of this report.
(1)
Procedure Review The inspector examined the following current licensee site procedure Palo Verde Nuclear Generating Station Manual Procedure No.
90-AC-OZZ17, Revision 4, dated June 6, 1984; titled "Startup qualifications, Certifications, and Training".
Startup Department Instruction Number SD184P, Revision 0, dated June 21) 1984; titled "Personnel Certification Guidelines" The procedures above are the current versions of the licensee's procedures applicable to test personnel qualification.
The procedures had been revised as a result of the licensee's investigation of test personnel qualification.
Specifically the procedures had been revised to specify that waivers of experience and education could be granted.
Guidelines for allowable waivers and forms to document such waivers were added.
In addition Amendment 12 to the FSAR was submitted which revises the APS committment to ANSI N45.2.6 to allow waivers to the ANSI recommendations for education and experience.
The types of waivers that can be granted and alternatives to verify skills have been proceduralized in instruction SD184P listed above.
As a result of the procedure review the inspector concludes that while the old certification procedures incorporated the ANSI recommendations without, provision for waivers licensee startup management authorized waivers to the experience and educational recommendations.
This option is recognized in the ANSI standard but was not included in the licensee's procedure at the time. It is clear the management had a basis for their actions in the ANSI standard, and there was, therefore, no detriment to safety.
The licensee's action to revise the procedure subsequent to their investigation was found to be proper and in accordance with the ANSI standard.
Review of the licensee's actions on a similar allegation made to them through their "Hot Line" program.
During the initial investigation, the inspector was informed that the licensee appears to be investigating similar allegations reported to them on the APS gA "Hot Line" as Hot Line file numbers 84-09 (dated December 27, 1983)
and 84-29 (dated August. 29, 1984).
The allegations concerned whether or not some contractors had falsified their resumes and personnel may not have adequate testing qualifications, (i.e., education and experience).
The scope of the licensee investigation was identified to pertain to the qualifications of Startup test personnel who have performed or are performing prerequisite and/or preoperational test activities, including Unit 2 Instrument and Control (ISC) Ievel II and III test personnel, supervision, and management, Test Working Group (TUG),
TWG
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Subgroup, and all Startup personnel elevated to status I,evel III "during the one year period from September 6,
1983 to September 7,
1984" (when improprieties in upgrading to Level III were alleged).
The licensee initiated a quality investigation plan (investigation no. gI-84-0004 Rev.
1) to investigate the above concerns.
As of October 17, 1984 the licensee has:
(a)
Reviewed one hundred thirty four (134) contractor's test personnel packages out of approximately five hundred eight (508) certified personnel identified on a September 14, 1984 list of Ievel I, II and III personnel.
(b)
(c)
Verified that approximately ninety six (96) of the one hundred thirty four (134) contractor's personnel packages/resumes appeared accurate enough to substantiate the level of certification assigned.
Identified fifty seven certifications with minor deviations in work and educational experience in the Startup group of personnel elevated to status level III during the one year period from September 6,
1983 to September 17, 1984.
These required additional review.
In this group the licensee has performed some examinations and, to date, no significant problems have been identified.
The licensee is reviewing the initial ninety (90) days of work performe'd by selected personnel, who had received a waiver of minimum qualifications to perform higher level work.
(d)
Identified one employee from the startup group whose educational and work experience could not be confirmed.
The licensee is still working on this item.
The involved individual has,resigned and needs to be contacted to authorize the release of information by former employers and educational institutions.
This is an unfinished examination rather than a negative finding.
(e)
Identified and terminated (approximately September 17, 1984)
one employee whose resume educational achievements could not be verified, and who elected to terminate instead of providing substantiating data.
The licensee has issued Car No. Cg-84-0272 to determine the scope of this individual's work and the affect on test validity.
Pursued independent (APS vs contractor) verification of education and/or work experience of the sampled contractor test personnel.
(g)
Reaffirmed to contractor organizations that by contract they are required to perform an investigation/verification
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of the actual work history and educational background presented by their personnel.
The results of the licensee's investigation, to date, show that the NRC alleger's statement on falsification of the title of revious work ex erience and duration of that ex erience on resumes, is corroborated in only one of the approximately 100 test personnel verified to date.
For the 57 test personnel who had been previously certified to Level III with minor work experience/education deviations which had not been documented, the licensee is in process of documenting the waiver and rationale utilizing their current procedures and forms.
These 57 cases appear to be
'insufficiently documented management decisions rather then a
falsification issue.
(3)
The inspector reviewed a sample of 12 contractor personnel packages, the initial licensee quality investigation plan, the applicable procedures, and the licensee's documentation of the allegations, and determined that the licensee's actions to verify job experience and education appear to be done in an accurate manner.
Substantiary telephone records and letters were available on completed verifications.
Staff Position The licensee's actions to investigate their "Hot Line" allegation appear to adequately cover the scope of the allegation received by the NRC.
This allegation remains open pending review and verification of the work experience on two individuals identified in the NRC allegation, and pending the licensee's completed assessment of deleterious effects on test validity.
At the exit interview the licensee was informed of the allegation received by the NRC and the apparent correspondence to the allegation received on the APS "Hot Line".
Actions Re uired Licensee management personnel were informed that their final actions on their Hotline allegation would be'considered a followup item.
Specifically, the NRC will examine in a future inspection:
the final results of the work experience/education verification sampling the APS evaluation of the safety significance, if any, of the one case (to date) of apparent falsification the APS final decision on the need to expand their verification sample size
I-A The above is considered a followup item (Followup Item 50-528/84-52-01).
Exit Interview An exit meeting was held on October 26, 1984 'with the persons denoted in paragraph 1.
The scope of, findings ofi.the inspection as described j.n this report were discusse ~
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