ML19247B598

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IE Insp Rept 50-341/79-13 on 790508-11.Noncompliance Noted: Failure to Follow Procedures,Failure to Assure Performance of Nondestructive Examination by Qualified Personnel & Failure to Control Measuring & Test Equipment
ML19247B598
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 06/04/1979
From: Harrison J, Knop R, Phillips H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19247B591 List:
References
50-341-79-13, NUDOCS 7908100234
Download: ML19247B598 (11)


See also: IR 05000341/1979013

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U.S.' NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION Ah3 EhTORCEMEh7

REGION III

Report No. 50-341/79-13

Docket No. 50-341

License No. CPPR-87

Licensee:

Detroit Edison Company

2000 Second Avenue

Detroit, MI 48226

Facility Name: Enrico Fermi Unit 2

Inspection At:

Fermi Site, Monroe, Michigan

Inspection Conducted:

May 8-11, 1979

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Inspectors:

h. S. Phillips

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J.J f. Harrison

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R. C. Knop, Chid]f

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Approved By:

Projects Section

Inspecticn Summary

Inspectior on May 8-11, 1979 (Report No. 50-341/79-13)

Areas Inspected: Wismer & Becker Contracting Engineers' indoctrination

and trainir.s; of craf t supervisors, engineering, purchasing and

quality pertonnel; qualification of quality contrcl inspectors. The

inspection iavolved 52 inspector-hours onsite by two NRC inspectors.

Results:

Two areas were inspected and items of noncompliance were

identified in each area.

(Infractions - failure to follow procedures,

Paragraphs 1 and 4; failure to

assure hTE is accomplished by

qualified personnel, Paragraph 2; failure to control measuring and

test equipment, Paragraph 3.)

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DETAILS

Persons Contacted

  • T.

A. Alessi, QA Director

  • W.

M. Everett , Edison Project Superintendent

  • l.

A. Walker, Project QA Engineer

,

  • A.

Alexiou, Assistant Project Superintendent

  • G.

Carter, Edison QA Engineer

  • C.

R. Bacon, Field Project Engineer

Other Personnel

  • J. G. Bolt, Project QA Manager, Daniel International (DI)
  • J.

T. Blixt, QA Manager, DI

  • D.

E. Seifert, Project Manager, DI

  • M. R. Majumder, Discipline Engineer, DI
  • C. Keller, Project QA Manager, Wismer & Becker (W&B)
  • L. Holland, Proj ect Manager, W&B
  • R.

Taylor, Project Training Coordinator, W&B

The inspectors also talked with and interviewed several other licensee

and contractor employees, including members of the quality, technical,

and engineering staffs.

  • Denotes those attending the exit interview.

Functional or Program Areas Inspected

On May 2, 1979, Region III received a telephone call from an Enrico

Fermi 2 worker who stated that Wismer & Becker Contracting Engineers,

the site piping / mechanical contractor, have quality control inspectors

who are not qualified to perform inspections, yet management directs

these inspectors to perform inspections on safety related activities.

As a result, Region III inspectors initiated a special inspection to

evaluate the subject contractors' personnel training and qualification

program.

Although the specific allegation could not be substantiated, other

problems were identified in related areas which did support the

allegation.

1.

Wismer & Becker Indoctrination and Training

The subject contractor's QA manual,Section IV, outlines the

minimum indoctrination / training and qualifications of personnel

who perform inspection, examination and testing and of personnel

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who perform activities affecting quality.

The Construction

Division Manager, Quality Assurance and Control Manager, Site

Quality Supervisor and Construction Supervisor, Manager of

Engineering and Training coordinator are responsible for the

indoctrination and training.

Indoctrination and Training of Construction Personnel

a.

The RIII inspector and the W&B training coordinator established

a base number of 65 foremen and supervisors who were

currently required to receive training.

Paragraph 4.1.1

cf Seetion IV requires that craft personnel down to the

foreman level receive the following training.

  1. Personnel

Subject

Trained

  1. Required

Introduction to Nuclear Construction

65

65

Safety

Contract Specification / Drawings

0

65

Welder Testing

0

65

Electrode Classification Storage and

60+

65

Control

General Fabrication Practices

45

65

Tool and Gauge Control

8**

65

Cleanliness Procedures / Requirements

65

65

Drawing, Specification Control and

54

65

Operation Traveler

  • An additional 30 attended a course on related subject matters.
    • An additional 9 attended a course on related subject matters.

b.

Indoctrination and Training r.f Engineering and Purchasing

Personnel

The RIII inspector found the following personnel had nv

received training required by Section IV, Paragraph 4.1.2:

  1. Personnel

Subject

Trained

  1. haquired

Introduction to Nuclear Code

44

44

Design Requirements

16

30

Stress Analysis Reports

0

30

Design Interface

44

44

Weld Technology

6 to 24***

30

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Drawing Control /Submittals

19

44

ASME Code Section III

16

44

ASME Code Section II

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44

ASME Code Section V

0

44

ASME Code Section IX

0

44

      • Several different types of training sessions on welding

showed varied attendance.

c.

Indoctrination Training and Qualification of Quality

Personnel

The inspector found the following personnel had not received

the training required by Section IV, Paragrap t . 2.1:

  1. Personnel

Subject

Trained

  1. Required

Introduction to Nuclear Inspection

27

27

Contract Specification / Drawings

5

27

Introduction to Welding

4

27

Electrode Qualification

27

27

Introduction to NDE Methods

1

4

Tool and Gauge Control

25

27

Receiving Inspection

17

27

Drawing / Specification Control

14

27

Operation Control

20

27

Records Retention

14

16

d.

quality Control Inspector Qualification

(1) The RIII inspector reviewed Wismer & Becker General

Procedure QA-TM-1, Personnel Qualification Manual to

determine minitum qualifications of inspectors.

Thirty-two inspectors' qualifications were reviewed

and were found to meet the requirements of Paragraph

5.5 except three Level II inspectors did not meet the

experience requirements, that is, high school graduate

plus four year of experience in testing or inspection

(or both) of power plant, nuclear plant, heavy industrial

or other similar equipment or facilities.

(2) The inspector reviewed written examinations administered

to QC inspectors per Wismer & Becker QA&C procedures,

Section IV and QA-TM-1.

The written examinations

demonstrated adequate knowledge of the subject except

as follows:

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(a) The~ test grade weight factors for examinations

was not consistent with the number of test

questions; examples follow:

Welding Inspector Test - 17 questions,

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value 7 points

Welding Inspector Test - 20 questions,

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value 5 points

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Welding Inspector Test - 20 questions,

value 2 points

Hydrostatic / Leak Testing Test - 12 questions,

.

value 5 points

Mechanical Test - 10 questions, value 5 points

.

(b) The actual grading of examinations is questionable

because numerous cases of incorrect answers were

not marked as being incorrect.

One individual

(Mr. Fosholt) was given the identical examination

approximately six months apart and missed the

same question on both occasions on the welding

inspection visual examination.

Examples of test

with incorrect answers not identified were for

Messrs. Schick, Fang, Austin, Spencer and LeBar.

The examination and resulting certifications of

the personnel described above is not totally

adequate. Employees should be advised that

answers to welding questions were wrong and the

correct answer should be reviewed and/or

retraining / retesting should occur as necessary.

Management of the Indoctrination, Training and Qualification

e.

Program

The inspector found that training problems have been

experienced during the last two years. That is, two or

three training coordinators have been replaced resulting

in a lack of continuity both in training activities and

records. The present training coordinator appears to be

doing a good job, however, he has not been able to organize

records that will result in effective scheduling /

rescheduling and course development.

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The training # program outline in Wismer & Becker QA&C

Manual,Section V, lacks clarity in that the training

required in Paragraphs 4.1 and 4.2 are too general.

Additionally, the procedure states that all personnel

shall receive the courses, however, the contractor stated

this was not the intent of the procedure. Daniel

International audits, (August 1977 and May 1978) had

documented similar training shortcomings.

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The licensee contacted Region III subsequent to the inspec-

tion and states that the subject procedures will be revised;

records will be properly organized and a matrix will be

developed to assure that minimum training requirements are

met.

Additional resources will be committed to assure

that the problem is corrected in a timely manner.

,

The findings in Paragraphs 1.a-e describe several examples

where personnel did not receive indoctrination / training or

were not qualified to perform inspections. This finding

represents a noncompliance t o 10 CFR 50, Appendix B,

Criterion V, and to the applicable licennee and contractor

procedures referenced in previous paragraphs and in

Appendix A, Item 1.

(341/79-13-01)

2.

Nondestructive Examination Personnel Qualifications

The inspector reviewed the following precedures for qualification

of nondestructive personnel for content and compliance. The

text of these procedures and compliance with these requirements

was acceptable except as follows:

a.

Daniel Construction Company NDE personnel qualification

records for five individuals were reviewed for magnetic

particle, liquid penetrant, and radiographic testing

methods. All qualifications were for Level II.

The file

records contained resumes, training records, examinations,

certifications and visual acutiy test.

The records reviewed

appeared to be satisfactory with the exception of certifi-

cation for Messrs. Siefert, Hritz, Kennedy and Blitz for

Level II radiographic testing that failed to meet the

requirements of Section A.4.3 of Daniel procedure 7.1,

Rev. 1, dated February 2,1976. This section states in

part that " Demonstrated proficiency in selecting and

performing examination and evaluating the results

. . ." The practical examination for the

obtained .

perscanel in question was to " evaluate the results

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obtained" only by reviewing the radiographic film and the

certification should have so stated; i.e. " Restricted to

the Review of Radiographic Film Only."

b.

Wismer & Becker (W&B) personnel qualification records were

reviewed for thirty-five examiner / operators for Level I,

II and III. Qualifications were for Ligaid Penetrant,

Magnetic Particle and Radiogranhic Testing methods and

,

qualification performed in act

lance with procedure

QA-TM-2, Rev. 4.

Records folders contained resumes,

training records, log sheets, examinations, certifications,

visual acuity test and other pertinent data. These records

were well organized and appeared to be satisfactory with

the following exceptions:

(1) W&B personnel (Mr. T. Alford) who failed an examina-

tion on October 13, 1978, for Level I Liquid Penetrant,

specife part, was re-examined on October 30, 1978,

without providing additional training. W&B procedure

QA-TM-2, Section 6.3.3, states in part ". . .

a retest

is permissible af*.er a fifteen day waiting period,

provided additional training is furnished

."

.

(2) W&B Les,' III site personnel were certified by personnel

other tha those required. W&B QA/QC manual Section

IX, Paragraph 4.6.4.3 states in part that "the Corporate

Quality Assurance and Control Manager shall certify

the site Level III."

Mr. Benke (Site Level III) was

certified by Mr. Eddy on May 16, 1978, for RT practical

and reviewed by Mr. Kearney (Corporate QA/QC Manager)

on May 16, 1978.

Mr. Benke was also certified for

Level III PT practical by Mr. Crawford on December 26,

1978. The requirement for certification in this case

is for one individual to perform this task. Review

is not acceptable.

(3) W&B personnel were not certified to meet the minimum

test score required by procedrra QA-TM-2, Section

6.3.2.

Mr. K. Timmons was tested o.

April 13, 1979,

for Level I Liquid Penetrant Testing Method.

Specific

examination No. I was administered and consisted of

twenty questions. Six questions were missed resulting

in a score of 70.

The answer given for test question

number twenty was incorrect compared to the master

answer sheet. The examiner failed to mark the answer

incorrect. This individuals score was less than 70,

the minimum test score.

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(4) W&B personnel were being tested for qualification by

an examination that did not meet the requirements of

Section 6 of procedure QA-TM-2 for the specific part.

Specific test questions for Level I liquid penetrant

given to Mr. T. Alford on October 13, 1978, were of

the general type questions for SNT-TC/1A supplement

for liquid penetrant.

Specific test questions are

required to pertain to the equipment, operating

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procedures, and test techniques required by the

employers written practice and also cover the specifi-

cations or codes and acceptance standards used by the

employer in his NDE procedures. The individual in

question failed to pass this examination, however, he

was subsequently retested on the correct type of

specific examination.

(5) Log sheets were not being maintained for some NDE

personnel (example:

Mr. Bruno) to document the hours

worked for the method certified to permit examination

to higher level as required by Section B.I.3.

Nuclear Energy Services (NES) NDE personnel qualification

c.

records were reviewed for thirty-six examiners / operators

for Level I, II, and III for the radiographic testing

method in accordante with NES procedure 99-CNTP-001.

Qualification records included resumes, training records,

certifications, examinations and visual acuity test and

appeared to be satisfactory with the exception of:

Visual acuity test for three individuals, Messrs. Sisson,

Harris and Goans, failed to indicate the results of the

color contrast test as required by Section 6.2 of procedure

99-CNTP-001.

The inspector stated that the corrective action should

address any nondestructive examinations previously performed

by the personnel in question.

The findings described in (a), (b), and (c) above are contrary

to 10 CFR 50, Appendix B, Criterion IX and Edison QA

Manual QAP 10 and is an item of noncompliance as identified

in Appendix A of the report transmittal letter.

(341/79-13-02)

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3.

Control of Measuri'ng and Test Equipment

The inspector reviewed calibration procedures for content and

procedure implementation related to nondestructive examination

measuring and test equipment.

Procedures and equipment were

found to be generally acceptable with the following exceptions:

Daniel Construction Company procedure QCP-VI-01, Rev. 1,

a.

,

" Quality Control Procedure for Interpretation of RT Film,"

Section 3.6 requires "a calibrated step wedge film be

utilized to calibrate the densitometer." The film strip

(S/N 1846B) being utilized by Danf 1 to calibrate the

densitometers was certified at purchase on August 1, 1977,

and has not been certified since that date.

Daniel procedure AP-Vll-04, Rev. 4, calibration and control

of measuring and test equipment, failed to address the

certification /recertification of step wedge density film

strips. This lack of control neglects to assure film

strip densities are periodically verified to be correct.

b.

Wismer & Becker (W&B) procedure WB-Q-11B, Rev. 5, Radio-

graphic Examination, Section 6.5.2 requires " calibration

of densitometer by checking with a calibrated step wedge

film."

The film strips (3) being utilized to calibrate

the densitome:ers were not currently calibrated. One film

strip (S/N 107712) was last calibrated at purchase

December 29, 1977. The other two strips were not certified.

W&B procedure WB-E-104, Rev. 2, Calibration, Certification

and Control of Measuring and Test Equipment failed to

address the certification /recertificatian of step wedge

density film strips.

It shoulo also be noted that this

procedure does not contain requirements for calibration

intervals, tolerances or a list of contcolled NDE equipment

or other equipment.

Nuclear Energy Services (NES) is perforting radiography to

c.

the requirement of W&B procedtre WB-Q-110, same require-

ments as noted in (b) above.

NES was utilizing two step

wedge density films to calibrate their densitometers on

which the calibration was not current.

One strip had

never been calibrated while the other (S/N 9001) had not

been calibrated since April 12, 1973.

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A total of srx densitometers were being utilized on site

for film density acceptance and were being calibrated by

six step wedge film strips which were not currently

calibrated.

These densitometers have been used to accept

filn, densities required by the ASME Code. The inspector

stated that the corrective action should address all

dispositioned radiographic film prior to density strip

certification.

,

The items denoted in (a), (b), and (c) above are contrary to

10 CFR 50, Appendix B, Criterion XII, and Edison QA Manual,

QAP-13, and is an item of noncompliance as identified in

Appendix A, Item 3.

(341/79-13-03)

4.

Control of Special Processes, Nondestructive Examination

The inspector reviewed procedures, facilities and equipment

utilized to perform nondestructive examination, all were noted

to be generally acceptable with exceptions noted below:

a.

Wismer & Becker (W&B) procedure WB-Q-110, Rev. 5, Radio-

graphic Examination used by Nuclear Energy Services (NES)

to perform this testing method and was not being complied

with as follows:

(1) Section 6.4.2 states that " lead identification numbers

be permanently attached to the penet ameters." The

lead numbers for penetrameter No. 1. used by the

first shift radiographers was missing.

(2) Penetrameters and shims are manufactured to meet the

requirements of ASME Code,Section V, Article 22,

SE-142.

Penetrameter design and use requires a plane

surface to project a true quality image on the radio-

graphic film.

Several penetrameters and shims were bent to fit the

radius

f small pipe, thus, distorting the image.

The standard practice for penetrameter placument on

small piping sizes is to place the longitudinal axis

of the penetrameter parallel to the longitudinal axis

of the pipe. W&B procedure WB-Q-110 does not address

this subject.

It should be noted that approximately 10 to 15 percent

of the penetrameters and shims in use were inspected.

The remaining percent were locked in the radiographers

tool boxes.

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b.

Section 12.1 requires ". . . a radiographic shooting

sketch for each technique utilized .

. ." This procedure

further defines each technique by listing several required

attributes: two being wall thickness and source to film

distance. Each change in thickness and pipe size would

require separate shooting sketches.

Radiographs of five

welds separate shooting sketches for two of these welds,

FW-P44-3558-1 WF1 (6" 280" wall) and B21-4416-3W F1 (12"

688" wall) were not prepared.

Shonting sketches for other

"

various standards and special pipe sizes were also not

prepared.

The items denoted in (a), (b) and (c) above are contrary to

10 CFR 50, Appendix B, Criterion V and Edison QA Manual QAP-9

and is an item of noncompliance is identified in Appendix A,

Item 1.

(341/79-13-04)

Exit Inte rview

The inspectors met with site staff representatives (denoted in the

Persons Contacted paragraph) at the conclusion of the inspection on

M o/ 11, 1979. The inspectors summarized the scope and findings of

the inspection, including the apparent items of noncompliance identi-

fied in the Results paragraph of this report.

The licensee acknow-

ledged the findings.

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