ML20095B264
| ML20095B264 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/22/1982 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX19-023, CON-BX19-23, FOIA-84-96 OL, OM, NUDOCS 8408220064 | |
| Download: ML20095B264 (120) | |
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01/22/82 UNITED STATES OF Af1 ERICA NUCLEAR REGl!LATORY COM!ilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the liatter of CONSuttERS POWER C0f1PANY Docket Nos. 50-329 Ori & OL 50-330 OH & OL (liidland Plant, Units 1 and 2)
TESTIriONY OF RONALD N. GARDNER CONCERNING THE QUALIFICATIONS OF BECHTEL OC PERSONNEL Q.
Please state your nane and position with the NRC.
A.
ljy name is Ronald N. Gardner.
I am a Reactor Inspector (Electrical), Plant System Sections, Region III.
Q.
Is a statement of your professional qualifications attached to your testimony?
A.
Yes.
Q.
What is the purpose of this testimony?
A.
This testimony discusses an item from the liay 1981 inspection which still remains open. (Inspection Report No. 81-12--Staff ExhibitI).
CPC QA engineers had been performing "overinspections" of items which Bechtel QC personnel had been inspecting.
In the f4y 1981 inspection, the Region III inspectors observed that the QA engineers had been identifying numerous occasions in which QC inspectors were accepting nonconforming conditions. The QA engineeers documented these instances in nonconformance reports. (NCR's).
The construction activities 8{
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2 primarily responsib?e for generating NCR's were cable pulling and cable terminations.
The Region III inspectors at the May 1981 inspection observed two potential deficiencies with the experience and training of the DC 4
inspectors. First, they had little or no prior QC experience.
- Second, they were certified as cable pulling and cable termination inspectors within three weeks of their reporting date.
From October 6 to October 9,1981, the NRC Staff conducted another inspection of the Midland site.
(Inspection Report No. 81-20). They deternined that the item still remained open.
Q.
Please state your involvement with the inspection of this matter.
A.
As a nenber. of the Region III inspection team I was personally 4
involved in the May 1981 inspection.
I was also a co-author of Section IV of Inspection Report 81-12, which addressed this natter.
4 0.
As a result of the Region III inspectors' concerns with respect to the qualifications of QC personnel, what action did they take?
A.
We required CPC to (1) determine if previous inspections performed by the aforementioned OC inspectors were acceptable and (2) verify the adequacy of the training, qualifications and exanination of Bechtel QC personnel.
Q.
What action has CPC taken to neet the above requirements?
A.
The licensee has conducted two audits of the Bechtel QC Department. Audit No. D-01-24-1 was conducted fron June 2 to July 3, 1981 and Audit No M-01-72-1 was conducted from November 2 to November 6, i
T 3-1981. These audits evaluated the adequacy of the Rechtel DC training and
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certification progran. As a result of the audits, the following improvements have been made in the area of DC training; (1) Rechtel is now documenting on the job training as part of its certification / training process for QC inspectors and (2) 11P0AD site personnel are overviewing Bechtel's training / certification program to assure that the certification of inspectors meets flidland Project requirements.
Q.
What has the Staff done to assure itself that Bechtel's QC training and certification program is now acceptable?
A.
I selected three QC inspectors to be questioned concerning two Quality control Instructions (OCI's) for which they had previously been certified. Both QCI's involved cable pulling and cable temination, the construction activities in which the greatest nunber of flCR's occured.
The selected QC inspectors were each hired in 1981, had no prior Or, experience and were certified within approximately three months of their i
reporting date.
In answering my questions, the QC inspectors denonstrated acceptable knowledge in the two areas.
i Q.
Do you believe that there is a need at the flidland site to require higher standards than are set forth in Regulatory ruide 1.58 which incorporates ANSI standard N45.2.67 9
A.
No. Although problems have arisen due to the vagueness of the j
regulatory guide, I do not believe the licensee has abused these provisions. Since Bechtel is now documenting on-the-job training as part of its certification / training crogram and HPQAD site personnel are overviewing the progran, prior problems should now be alleviated. These i
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changes should also enable the NRC to conduct a better audit of CPC's use j
of these provisions.
Q.
Are you satisfied that certification of OC inspectors neets tiidland Project requirements and NRC requirements?
A.
Yes.
Q.
What is the status of CPC's connitment to "overinspect" the inspections performed by OC personnel against whon NCR's had been i
initiated?
A.
We are waiting for the results of the overinspection so they i
may be evaluated.
I expect to make that evaluation prior to testifying a
in the first week of February 1982.
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.I i-1 Dated at Bethesda, Maryland this 22nd day of January,1982 i
l
PROFESSIONAL OUALIFICATIONS OF RONALD N. GARDNER I an a Reactor Inspector (Electrical), Plant Systems Section, Region III.
I have been with the NRC since October 20, 1980.
Previously I have served ih years as a termination engineer at a connercial nuclear plant, 3 years ar. a Systens Engineer involved in the construction of commercial nuclear plants. I was also associated with the overhaul of nuclear subnarines for 1 year and was an Electrical Test Engineer involved in the construction of naval nuclear plants for 3b years.
I received a B.S. in Electrical Engineering from Virginia Polytechnic Institute.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tNISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSUMERS POWER COMPANY h
Docket Nos. 50-329 OM & OL (Midland Plant, Units 1 and 2)
)i 50-330 OM & OL CERTIFICATE OF SERVICE 4
I hereby certify that copies of " TESTIMONY OF RONALD N. GARONER CONCERNING THE QUALIFICATIONS OF BECHTEL QC PERSONNEL" and " PROFESSIONAL QUALIFICA OF RONALD N. GARDNER" in the above-captioned pro:eeding have been served on the following by deposit in the United States mail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 22nd day of January,1982:
- Charles Bechhoefer, Esq.
Frank J. Kelley Administrative Judge Attorney General of the State Atomic Safety and Licensing Board of Michigan U.S. Nuclear Regulatory Commission Steward H. Freeman Washington, D.C.
20555 Assistant Attorney General Environmental Protection Division Ralph S. Decker 525 W. Ottawa St., 720 Law Bldg.
Administrative Judge Lansing, Michigan 48913 Route #4, Box 190D Cambridge, Maryland 21613 Ms. Mary Sinclair 5711' Summerset Street E
Dr. Frederick P. Cowan Midland, Michigan 48640 Administrative Judge 6152 N. Verde Trail Michael I. Miller, Esq.
Apt. B-125 Ronald G. Zamarin, Esq.
Boca Raton, Florida 33433 Alan S. Farnell, Esq.
Isham, Lincoln & Beale
- Dr. Jerry Harbour One First National Plaza 4
Administrative Judge 42nd Floor Atomic Safety and Licensing Board Chicago, Illinois 60603 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 James E. Brunner, Esq.
Consumers Power Company Myron M. Cherry, Esq.
212 West Michigan Avenue 1 IBM Plaza Jackson, Michigan 49201 Chicago, Illinois 60611 9 =
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1 Ms. Barbara Stamirts
- Atomic Safety and Licensing Board 5795 N. River U.S. Nuclear Regulatory Commission Freeland, Michigan 48623 Washington, D.C.
20555 James R. Kales
- Atomic Safety and Licensing Appeal 203 S. Wast.fngton Avenue Panel Saginaw, M'.nhigan 48605 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Wendell H. Marshall, Vice President Midwest Environmental Protection
- Docketing and Service Section Associates Office of the Secretary RFD 10 U.S. Nuclear Regulatory Commission Midland, Michigan 48640 Washington, D.C.
20555 Jeann Linsley Steve J. Gadler, P.E.
Bay City Times 2120 Carter Avenue 311 Fifth Street St. Paul, MN 55108 Bay City, Michigan 48706 Paul C. Rau Midland Daily News 124 Mcdonald Street Midland, Michigan 48640 Et Michael N. W11 cove Counsel for NRC Staff j
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in the correct vias and is neatly trained within the cable tray.
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Construction did not follow the regairernents of F7E 4.000.
Bechtel CCE was inattentive in th5 ir.spection of this cable cull.
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Determine why this cable pull was not installed properly.
2)
Review FPE 4.000 " Installation of Electrical Cables", with crew responsible for this pull.
- 1) & 2)
L E Davis 3)
Determine why CCE was remiss in his inspection.
4)
Recertify the CCE to PCCE E-4.0
- 3) & 4)
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y Page 3 of 3 Serial no: M-01-9-;-;26 Date: April 15, 1951 File no: 16.3.4 & 16.3.6 Continued:
- 12) "As is" nonconforming condition versus "as required" condition wid refs:
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Contrary to the above, during an overinspection of Cable #13B 2423 : es.
following deficiencies were noted:
(a)
Cable was routed into cable tray BFC instead of BI'd as repired by Drawing E-37 and the cable pull card.
(b) Cable was outside of horizontal tray BFF 13 rather than neatly trained and tied inside.
(c) Cable crossed over split tray barrier and into tray BIG 01 at junction box BJ 470.
(d) Cable was not protected from physical damage (sharp edges).
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Eschtel Field Procedure FPE-7.000, Rev 7, paragraph 6.6. sta:es in part:
"The stripping back of the ou:er Jr.cke: of a cable shall not ES:ith b2 more than necessary for the individual condue: ors to reach their LEDavis points of cennection.
Contrary to the above, cable C336807 C-1 was stripped back 31/4"
- re c:n free its closest point of connection and 0336807 E-1 was s: ripped L*R31rd b,N,U bsck 4 1/2" fro: its closest point of connection.
Jk' Cook TCCooke('2)
These ter=inatiens had been accepted by Bechtel Quality Control.
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Although this condition exceeds the requirenents of the Field Prpeedure, the excess amount in this case does not warrant re-work as it is not detrimental to safe plant operation.
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~erminatien electricinn stripped :he cables back :cefar when terzinating the cables.
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Reinstruct QC Engineers on ter=ination requirements and provide docu=ented evidence of instruction. (E Smith) k2.
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MADietrich GUAI.lTY. ACTION
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Start Up Syste:n: Indetert::inate 8'N rsus11o REQUEST priority - 10 SKT/CAC i
Trend Code: 13 MPQAD Routing File 16.10.3.2 DRKeating/ELJones, MPQAD A!: S-677 To:
Q C ontr 1 0 ment ref.:
CAR I ent. No.:
b Sh' PF@
F-028 Trend Graph Chart 13 Ac: ion Recuested:
The Oualiev Trend Craoh Chart 13-0C fori_eeriod 12/18/80 throuch 1/21/81 has been evaluated and it was found that ur of six deficiencies involved QC errors) 3 recording data, improper sign uff, and failure to follow procedure.
It is t
requested that PFQCE indicate actions being taken to reduce and/or prevent future occurrences.
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NRC Inscection Reports 79-10, 79-19 275. NRC Inspection Report 79-10 covered an inspection conducted in May 1979.694/
In the report Mr. Gallagher, one of the inspectors, indicates a dissatisfaction with the ANSI qualifications of quality control personnel in the area of containment post-tensioning.
He did not issue a non-compliance concerning the matter.
ANSI, the American National Standards Institute, comprises c'ommittees which represent experts in particular engineering areas.696/
The commitees set industry-wide standards for a particular discipline.697/
Mr. Gallagher is not a member of any ANSI Committee.698/
Mr. Gallagher testified that, in the technical judgment of Consumers Power, the post-tensioning inspectors were quali-(
fied under applicable ANSI standards, but that he disagreed with this analysis.699/
In September 1979 Consumers Power management and Mr. Gallagher met to resolve this differ-700/ The NRC is nov satisifed with the inspector's ence.
qualifications.701/
694 / Gallagher, Tr. 2427-28.
695/ Id.; Stamiris Exhibit No. 3, Attachment No. 10.
696/ Gallagher, Tr. 2458.
k 697/ Id.
3 698/ Id.
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699/ Gallagher, Tr. 2460.
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f 700/ Gallagher, Tr. 2428.
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701/ Gallagher, Tr. 2428.
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276. The question of quality control inspector quali-4 fications also arose in the context of the planned remedial work on soils.702/ Mr. Gallagher expressed the view that Consumers Power, as well as other nuclear construction permit holders, have misused an exception in an ANSI stan-dard (ANSI N.45.2.6).703/
He opposes the exception in the standard which permits the substitution of certain educa-tional or experiential requirements for inspectors if an equivalent level of competence can be demonstrated. 04/
In Mr. Gallagher's opinion, the debate over qualification of quality assurance personnel is "the biggest problem facing our industry today."705/
It was not peculiar to the Midland site, but endemic to the industry.706/ Mr. cordell Williams, the chief inspector for Region III in the civil area, 07/
(
disagrees with Mr. Gallagher's assessment of the ANSI waiver provision.708/ He believes the flexibility it provides is necessary. 09/
702/ Gallagher, Tr. 2432.
703/ Id.; Gallagher, Tr. 2460.
704/ Gallagher, Tr. 2432.
705/ Gallagher, Tr. 2433.
i 706/ Gallagher, Tr. 2433.
707/ Williams, Tr. 2197-98.
708/ Williams, Tr. 2207.
709/ Id.
,..~..
-174-277. According to Mr. Marguglio, the Midland quality control and quality assurance inspectors are well qualified.710/
For example, as a part of the recent improvements in the MPQAD quality assurance program, quality control inspectors are required to be certified on particular inspection plans, a requirement in excess of ANSI standards. 11/ John Gilray, from the NRC Staff, cited these upgraded qualifications in his affirmative assessment of Midland's quality assurance program. 12/
In the recent MAC audit, qualifications of 7
both Bechtel and Consumers Power inspectors were reviewed.
The auditors found the inspectors properly qualified for the tacks to which they are certified.714/
g 278. Mr. Williams tified that thonur e'r of persons presently on p idipnd civil qua-n rance st,af
/
/
adequate.7127 However, fo some of e planned remedial
/
/
differytly quahfied personnel ma[be neces'sary.716/
wer s arr[has pledged to acquire Coisumersdower ware of
[
as a conditio[ recedent to.the remedial work.717/
such rs 710/ Marguglio, Tr. 1529.
711/ Marguqlio, prepared testimony at p. 32, following Tr.
1424.
712/ Gilray, Tr. 3713.
713/ Staff Exhibit No. 4, at p. 10.
714/ Id.
715/ Williams, Tr. 2216.
716/ Id.
i 717/ Marguglio, Tr. 1529.
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i 229. Another adverse finding of the May 1981 inspection involved the qualification of personnel doing first-line inspection. Tr. 2202-03.
It appeared to the Staff that quality control personnel did not have adequate experience for quality control inspection. Tr. 2202. CPC's own records also demonstrated NRC's basis for this concern. Tr. 2203. Staff witness Cordell Williams testified that NRC discovered certain failures of the sort that an experienced quality inspector would not make. Tr. 2206. He recognized that the ANSI Standard N45.2.6, which is recognized by the NRC Regulatory Guide 1.58, allows a fairly liberal interpretation concerning the qualifications of inspectors. Tr. 2206. The NRC questioned the extent to which CPC is applying the ANSI Standard. Tr. 2206. Mr. Williams later testified, however, that the NRC's concerns about the adequacy of experience and education of QC and QA personnel arising out of the May 1981 inspection is one that has been addressed at nearly all plants and that the problems are no worse at Midland than they are at other plants. Tr. 2212.
230. Staff witness Gallagher criticized the industries' standards for qualification and experience of inspection and testing personnel as permitting too much latitude in provisions for waiving educational and experience requirements. Tr. 2432. He testified that the provision of the industries' standard addressing waiver of requirements is in his opinion abused not only at the Midland site but also at a number of other sites where the issue has been raised. Tr. 2432.
231. On cross-examination by CPC Mr. Gallagher agreed that the American National Standards Institute is comprised of committees which are representative of collections of experts and that their purpose is to derive
//Rc 4
s
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t industry-wide standards for particular disciplines. Tr. 2458-9.
Hr. Gallagher acknowledged that the committee responsible for ASNI Standard N45.2.6 has discussed, debated and given consideration to modifying the standard but as yet they have not done so. Tr. 2460.
232. We asked Staff witness Gilray.his views concerning the waiver l'
provisions of the ANSI Standard. Mr. Gilray testified that he thinks the flexibility permitted by the waiver provisions needs to be there to certify, l
and. qualify an individual that does not have high school or graduate f
L education. Tr. 3845-46. He stated that whenever the waiver provisions are I
used there should be documented justification as to what proficiency tests or j
qualification tests the individual went through.
Tr. 3846. He further stated that the sort of documentation required is presently being studied by j
the NRC. Tr. 3846.
233. The testimony in this proceeding demonstrates certain problems that arise from the lack of definitive standards for waiving the education and experience requirements of ASNI Standard N45.2.6 for QA inspection personnel.
In light of testimony that these problems have been addressed by the appropriate committee of the American National Standards Institute-and the NRC and that no changes have resulted to date this " card does not believe it appropriate for it to undertake corrective action in that regard.
234. Another subject within quality assurance on whic tiere was extensive cross-examinationTonyrned the effect of the Mijland Project s
Quality Assurancc,,D6p'artment (MPI AD)--the,ne[ integrated o'rganization
/
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described by Wr. Marguglio in his direct testimony. Marguglio, p. 4, e_t seq.
t In res o e to Intervenor cross-examination Mr. Marguglio testified that Y-
QUALIFICATIONS ObNALD h. GARDNER-PROFE55101 I am a Reactor Inspector (Electrical) Plant Systems Section, Region III.
I have been with the HRC since pctober 20, 1980.
Previously I have served 1h ypars as a termination engineer at a
~
connercial nuclear plant, 3 years as a Systens Engineer involved in the construction of commercial nuclear.phanti.- I was also associated with the overhaul of nuclear subnarines foj 1-yearIand was ' art. Electrical Test Engineer involved in the construction ~ of naval' nuclear plants for 3S years.
I recetjed a B.S. in Electrical Engineering from Virginia Polytechnic Institute.
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cerufted, that's a-far as we can pursue e
A follow so NRC Laspecuoe is Oc this at thm ume" unMes more specific
- A 5 8 percest error cate in routing gggg r,,e ;eq ta, s,tuauos was cca.
compiaanta are received. Gardner said."
eiectrical cab 6ee har teem found among unuang and that some Beca:el QC work prewmusly inspected by ain' inspectors had litue or no prer QC IN OTHER tesumany Fnday. NRC Quaffty Controt (QC) eiectrical inspec. espenence." Some weae certified as witnesses said they are contiauseg to ters at the Msoland suelear plant.
Nuclear R egulatary Commissaos officasia
- Inspectors *for ' wort.
withan three weesa o evaluate the need to reoshee under.
tesufsed Prada r in Midland. -
reporung according'- to g ground pipes at the nuclear plant.
One of the une nad sa arreand"se;eiL3.Gardner a unties tesumosy. . la muca of 2e soia nearmg. Con.
.. ~.
'sumers ' and the NRC nave beer
- percent. aad the NR C a roquesungAhat THE NRC TIIER requsred Consume t.ammering out piana to ade massive
- 100 percent of tant man'e. esectrical to audit the wort and qualificatens of concrete supports to the foundations of.
inspectwns. be tremapected by. Con.- enectncal inspectors a the Secatet se eral buildings which have sostained sumers Power Ca. Qaality Assurance defaru cracked walls. These probeems have (QA) perscanal, accorsung so Ronald N.. yngaynene. Two' audita were done.
Gardner informed the ASLB of been traced to t8e mid-18'Os when Gardner. se eiectnese mapector from the results. and of an on going -exam.
poorty compacted sods were piseed la the NR C s Regies!3offico sa niasma.
. inauon of wora inspected by 'Jie mane---
many aress at1be plant' Cosamners "has. set.,at, this tune,,.n,3 perg,cu!ne-The lategnty of the underground pipes
, agreed to deitis.J1 may and up beeng a 1 He tend the A&LB tisas the athe were le new Demg quesucced because they
. requarament" Gardner note a penet.os senected' for scruusy because nom.
were buried la une same deficient soilm.,
- admmistrouve.judgeofrom the Atanrio conforinance reports had been wrttten All of the piper bems renewed ar*
agamst theter by Consumery as a resuf]t vttal to various piant safety. systems: l
'. Safety and Lacensaar-Soard. =bch fs..
presadang ever thefederal haanag om Vf '"a sud?ts some will Costana air for controi to sosi pro 64 ems at the Midlaad nuciear Of f.C44 caone mstauauons previousiy operators, some reactor caroiant p6 ant icapected by the ame, es cables were others fuel for the plant's. dJ As NBC inspecuos at the plant 12st found to be misrouted. e 3.8 percent generators, which weeJ4 De uses' May detarmined that Bechtet Power error rete.Gardner tesufied.
emergencies. The pipes eary a 1
Corp. QC mspectors were aeproving Neartyhaif the aperouted cables were meter from 1.3 to 36 menes.
,eie:trisah wort. thea, abould, have beem ' found is work inspected IWoct of the QC
' la entten tesumeny. NRC offk said pipe profileTeste indicate 2e p.,"
-ca** *. ' Inspectors, who se longer
- worts for a Bechtet. Gardner said; Reasspecues of deviste trorm I to le inches fion thC
$1 500 of this mes's inspectsone revealed 30 Intended locat!ona. The' NRJ a '
9 misroutad cables, and the,NRC asaed Consumers have' agreed taats3 lacfret ' l
- that all of 2e f.147 inspect! ens doee by movement is.the grehtest acceptah I
p + e enan be ~ " ' - * * - '
ever the ed year life of the plant j
saa misrouted cables had not L The NRC believes the loose emis j swe been found in the andata, ther. rou&d allowed 2e pipes to sma froar their i
have. beest. detected and corrected miended locauons, possibly over.
ettaout damage to plant systems eurmg stressing them. The concern is that 4
pre 4paranoaal tesu of efectrical cir.
"eveifastan** may have occurred to the cuatry, accordmg tp Bruce Pect pipes' shapes. teductog theit flow ystes.
Caes lar**umers* constructme supenntendent,, CON $tilbfERS-ALREADY has reased a-'
l *IPecaL was not a witness' at the seG and rebeddei hundreds of feet of piping
, ' hearing. )Ls opsmon was sougat today by due to these concerfts, acccedag to L the Da61y News. ' ' * ' '
teenmeny. Other pspes may be rebedde(
Deepite the '8R f*** *a'%e * **"*
if pendag tests show they escoed 4
- G4rdner said Se ni u=ame to a tr-rute percent ovalizauoac
'.. the misrwteo cam es > =.acs of trainsng_*
Joseph Fane, se NRC gootechascal
) amore ne CC mseer.an engmeer. said the papes will be i. ""KTt'aovgn be s a id t.nree of the rme. sausfactm ilthey are within linches of inspectors had onsv tPr weens frave' their atended locanons. He sa4d this
- F'?rT"Ter% cation. he sa id there requarement is not normal for nuclear st aopears a be no c rre atien tmt=*-a plaats under construcuon.
%..r.r n am ermet
- ..Why we're doing it.at nGdland is la f.
' Gardner noted taste.he 'amtee weit.
ea
- m v a
recognation ob 2e sod settlement
. 'tbRpeu emr rm problem." Kane tasufted.
- sU.oo a weev
- mM ~re tan 9 10 -. Kane, la a break during the hearmg.
fGrs of empene9ee and pooses*ed a said Consarmers has agreed to repiace -
. 3 tic N a a, - w er eiectnc ia n : d e-d.
act just rebed - and StWoot lenges of
'; ej5I ' mat e =-
a t
-=
341ach prpo which iesd fram the rsectors f c,,reistion ette,*n er'*aenee a4 to the service water pump structure
'- (Frors." he saut V These pipest carry water from 12
- cooling pond
==
. ME TEST!FTED 1st fear of the fMe_
, Dari Itood, the NRC*a protect st*
ha d. be e - e*Med mreens the *mer ager for the Midlant plant. saed then flocequr tne chcas:on Ad ptpes seed to be replaced "because of a F- - t enerett
., remests of tre Ame tesa inabihty to prove, to the sausfacuoa,
Tetice.al N
- !sst tute Es g the (NRC) staff. that the condatma of tb m e s r,c,...-,- e. w,- *-r" pipe now and a the future is sausfac.
7ut the NRC mapector load 2e A3L3 tory." -
. witnesses said tem he finds the waiver procedure accept-Other NRC able because ANSI standards are not. pend. tag further smalysis. =ome of th "absolates and bocaase proficiency pipes apparert!y will be safe durtag 2; can be saown in other ways.
plant's hfe..
f infpectors by QA personner view cf N' '
Gareer said that am ove Consumers han laimed that the loca -
{
as ts bu:n. sosis may not ha' e esclusseely cause.
i
- lm a m m ;.a.6n* * *v in - tie pape setuements. UUllty witnesee.
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, nasure sae wasvee procese '9s not _ have said some,npes ese base be?
J
. placed too low rrtginally, or that weld 2r bybias.
rte siao tesufled 2at ad MRC probe after placementcauseethem to stna.
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tote allegedly. deficaens wert by QC ' Ease tesoflec Fnday;"I'tn act sure i I
electrical inspectora employed by - could ever come to that Last conclusic%
Comssach. a subcontractor at the p; ant. ; Theee (papes)' vere cheched when the /
. has ended because 2e man who made.,M..re inssailed. and they were withia
.%the allegeupes.could not bb blaftalerancee."t. p e.
..... ~..- % - M iKane also said the NRC wouM hhe to
- clauen.
w.
"The gentleman tedicated he could not' ' 430 4 satuanoam where railrr,ed cars 6deaufy any linee which consaamed used to ship fiaal and other materta!s ut, defacient mastallarmas. Howeeer. be' and out of t3e pient, wouad be left for named two peop;e he felt were not days over the buried pipes.
quaufted." Gardner said in answer to a-put be added.":t (a tram) passed ever quetuon from NRC attorney %chaef the pipes and didn't stop, that would be i
W acovo.
1 no pacb6cm. And if it did that many Gardner saad a records exammauon umes a day, that would sull be true."
showed tae two er an are quailfred a two The hearink has been reces.*1 unti!
er mort areta (d masceCtate. "la March 30.
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Emi Bechtel Quality Control 7-2/-8/
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Mid n 1 and 2 i
I.
AUDIT SCOPE AND OBJECTIVES The scope of the audit was training and certification of Bechtel Quality control personnel. The purpose was to assess compliance with, a_nd the adequacy of, the cresent* program'.
It is noted that Revision 4 of PSP G-81 became effective dur-ing the audit. Also, an assessment was made as to how the present Bechtel QC training program meets Revision 1 of Regulatory Guide 1.58 as discussed in the NRC Generic Letter 81-01 dated May 4, 1981.
II.
IDENTIFICATION OF AUDITORS The audit was perfonned by the following personnel:
DR Keating - Audit Team Leader AE Schlaifer - Technical Specialist III. PERSONS CONTACTED DURING AUDIT The following Bechtel personnel were contacted during the course of the audit:
Attended Entrance Attended Exit Name Title Meeting Meeting E Smith Project Field Quality Control Engineer X
X E Urbanawiz QC Training "oordinator X
IV.
AUDIT
SUMMARY
A.
An audit entrance meeting was held on June 2, 1981, with personnel in attend-ance as noted in Paragraph III.
'Ihe audit team was introduced, and the audit scope, plan and schedule were discussed.
B.
Audit checklists were developed from PSP G-8.1, ' Qualifications, Evaluation, Examinatio'n, Training and Certification of Construction Quality Control Personnel," Revisien 3, and ANSI N45.2.6-1973.
Specific sections from the documents are as noted on the checklir*.s. Data was collected by pro-ceeding through the checklists which are attached to the file copy of this report.
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C.
The audit resulted in two findings which are attached to this report.
1 D.
Se following observations were made as a result of this audit:
1.
The amount of training in particular Quality control instructions prior to certification varies considerably. No =inimum training requirement was evidenced, nor was there documented evidence of '
credit taken for previous experience or certifications. It appears that considerable on-the-job training in QCIs is being performed that is not documented which provides an erroneous f
impression that training is less than actually performed.
J (Also reference AFR M-01-24-1-01. )
2.
Section 8.3.2 of PSP G-8.1, Revision 3, required that the effec-tiveness of the job site training program be evaluated by a review of the corrective Action Log described in PSP G 3.2.
Here was no documentation of this review. It is noted that PSP G-8.
Revision 4, deletes this requirement and that the new PSPs which went into effect on June 29, 1981, do not require the Corrective Action Log. Discussion with the PFQCE indicates that, rather-than reviewing the log, he has and will continue to review the MPQA tend program output, administer the Bechtel NCR program, and through these items and discussions with his lead QCEs, will continue to direct the training program based on the PFQCE's evaluation of its effectiveness.
It is suggested that an evalu-ation be made of these actions and should be incorporated into PSP G-8.1.
E.
The following Unresolved Items were identified:
1.
Section 4.2.1.4 of PSP G-8.1, Revisien,3, indicates that Imvel I personnel provide on-the-job training for uncertified constru*c-tion Quality Control Engineers as a job responsibility.
It is considered that Level IIs should also have on-the-job training of uncertified personnel as a job responsibility. Consideration should be given to revising PSP G-8.1 to show that training uncertified QCEs is a responsibility of a I4 vel II.
M-01-24-1-01 (URI) 2.
Section 8.3.1 of PSP G-8.1, Revision 3, that discusses monthly training sessions, requires clarification. It has been constn ed previously that this section required that each QC engineer attend a minimum of one, one-hour training session per month.
Presently, Bechtel QC considers that not to be the case. The procedure does not literally require all QCEs to attend a session.
It was observed during the audit that some QCEs had not attended any training sessions during certain months and that others had attended only half-hour sessions during the month.
M-01-24-1-02 (URI)
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PA2 L OP 4 3.
There are no set criteria available for use that provides reason-able assurance that a person can competently perform an assigned task where specific education and experience requirements are not met. There also is no bas,is available for determining " equivalent" experience.
It is not cleaf that successfully completing the cer-tification process is a satisfactory substitute for education and experience.
M-01-24-1-03 (URI) 4.
Section 8.5 of PSP G-6.1, Revision 5, requires, in part, that:
"...the necessary training and orientation in the application and use of each new and revised PQCI..." prior to implementation in the field. It was observed that, in one case of ten reviewed, no training in the QCI was performed prior to certification (QCE Vantoorne in QCI C-2.10).
This training is conducted so that each CQCE responsible for performing the inspections fully under-stands the requirements contained in the PQCIs. There is no basis for determining whether such training is "necessary" or not. Con-sideration needs to be given to clarify this point.
M-01-24-1-04 (URI)
F.
An audit exit meeting was held on July 3,1981, with those in attendance as noted in Paragraph III. Draf t audit findings, observations and unre-solved items were presented and discussed. Bechtel Quality Control did not concur with the findings or Unresolved Item M-01-24-1-03 (URI).
Discussion ensued. Based on discussion and additional information pre-sented in the exit meeting, as well as discussions with Bechtel QC sub-sequent to the exit meeting, the final audit results are as presented in this report. Bechtel is requested to respend to the audit findings, observation No. 2, and the Unresolved Items.
G.
Responses are to be sent to:
4 Mr D M hrnbull 4
Consumers Power Company Midland Project Quality Assurance Department PO Box 1963 Midland, MI 48640 Responses are requested within 30 days of the receipt of this report.
i v
V.
EVALUATION OF EFFECTIVENESS,
w.
,The Bechtel Quality Control Training Program and its implementation, n general,~ " ~
m::ets the regulliements of PSP"G-8~.1[and[ ANSIN45.2.6l.~ here are ares ~where~ ~ ~
~
~
~ ~
clarifications and improvements would help clearly demonstrate compliance to the requirements. These items are covered in the Recommended Corrective Actions of the findings uryd the observations.
It is noted that there have been several rccent improvements and positive actions in the area of QC training. Sese include:
1.
The naming, in February 1981, of a full-time training coordinator.
It is al o planned to add an assistant to the training coordinator, and t
upon spproval',"there vil,1 be two, persons administering the training pro-gram full time.
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The training coordinator has recently attended a formal seminar conducted j
2.
by Stat-A-Matrix in training of inspection personnel.
Bechtel QC has obtained the " Construction Technology Transfer Program" 3.
which is a Bechtel slide / tape presentation covering various specific sub-l l
jocts such as cable terminations, cable pulling, etc. The program covers all disciplines and is being integrated into the certification process.
Additional visual aids are being prepared to cover other aspects of the l
QC program.
t Further standardizing of performance and oral certification is being 4.
accomplished by the QC training coordinator.
Bechtel QC has begun documenting on-the-job training as part of the cer-5.
This training, which has been conducted, tification/ training process.
was not previously documented and resulted in the training documentation not actually representing the total' number of training hours received prior to certification.
ULeJresent_Bechtel_ Quality Control program does not meet the position in the NRC Gena.ric_ Letter which proposes compliance with Revision 1 of Regslatory Guide 1.58.
Education, and, experience are considered absolute in Revision 1, and the _Bechtel_
program does not considei+them absolute (reference Section 6 of Regulatory Guide).
Also, Section 10 of the Regulatory Guide indicates that, where it is desired to establish that an individual has the required qualifications in lieu of required -
cducation and experience, documented evidence in the form of proceglures and a record of a written test must be available. Jechtel does not administer _a__
. ritten. test or provide.. evidence _in lieu of_the_ education and. experience other _
w than certification to the QCIs.
The Management Analysis Company (MAC), during their QA program assessment,Their reviewed one-fourth of the certified Bechtel Quality Control Engineers.4 conclusion is that the training and certification records are acceptable to the requirements of ANSI N45.2.6 and PSP G-8.1 (rafarence Final Report for Censumers Power Company dated May 27, 1981, MAC project No MAC-81-G-31, pages 367-369).
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PROJECTS. ENG6MEEUtesG AM) cohsTIUCTioN =
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l ANSI N45.2.6-1973, " Qualifications of Inspection Examination, "f""hteIOC l
cnd Testing Personnel for the Construction of Nuclear Power
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Plents," requires that on-the-job training be part of the July 3. 1981 program (Section 2.2.1 Training).
rr.agg While on-the-job training is conducted by Bechtel Quality su n a n =:
Control, there is no documentary evidence available that WRBird it is conducted.
GAEhien/KFH/ CMC JWCook MADietrich CSKeeley BWMarguglio DBMiller JARutgers GSehlei-fer ESmith DATA gg' art RAWell's JLWood ALAB-2 MPOAD Routine am. a e.im:m.m:.:
1.
Document on-the-job training as part of the certification process.
(Bechtel has begun documenting this training.)
N7DE ACI;a Art.MJr:.
t Bechtel Quality Control did not concur that this item constituted a finding.
A for=al response, detailing the Bechtel QC position, is requested within 30 days of receipt of this report.
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QC AI 12513 MPQAD AFR M-01-24 1-01 QA AI S-920 Quality Control (2C) has revised and formalized the method of documenting on the job training as an additional good man-cgement practice only.
Documentation of on the job t' raining is as described il QC Administrative Instruction No. 801.
The above action <as not taken_to comply with ANSI N.45.2.6 As it is and has been QC's position that our or PSP G-8.1.
training program is in full compliance with the stated require-ments.
Additionally, the recent CPCo Audit of the Quality Control training program :onfirmed that the QC training program meets I
and exceeds ANSI requirements.
The audit did not identify any findings, but did note that Quality Control has a good and pro-gressively improx ing training program.
T/N 23440 l
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Bechtel Power Corporation Inter. office Memorandum Date October 6,1981 Ta All QCE's From E. Sinith subi.et Documentation of On The Job Training of Quality Control At Midland, MI Ext. 204 copin to D. L. Daniels Job No. 07220 ADMINISTRATIVE INSTRUCTION No. 801, Rev. O_
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1.0 Purpose 1.1 This procedure is issued to provide a standard method of
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documenting on-the-job training (0.J.T.) towards certifi-cation in a specific PQC1.
1.2 The checklist referenced in this instruction is used to identify the subject areas in which 0.J.T. is conducted.
This checklist does not establish a uinimum number of training activites or time hours, as these variables are dependent on the availability of 0.J.T. opportunities, classroom training, personal study, and previous exper-ience.
2.0 Responsibility
/
- The CQCE Administering training (CQCE certified level I, "II, or III in the PQCI) is responsible for identifying the training activities as shown in the attached example (Exhibit 1) 2.2 The QC' Training Coordinator is responsible for transfer-ing the total du-ation hours of training to the respec-tive individual training records (Figure 8.1 - 4).
3.0 Organizations Affected This administrative instruction affects only the Project Field Quality Contml Organization.
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4.0 Foms Required 0.J.T. Checklis't & Field Training Summary. No. 7220/
QCFF-T-1 Rev. O.
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5.0_ Procedure A
' 5.1 The 0.J.T. Checklist & Field Training Sumary shall be processed in accordance with the instructions provided on the form. The data on this form shall be neatly printed.
Reference E2ibit I for typical entries.
5.2 The completed 0.J.T. Checklist & Field Training Sumary shall be submitted with the oral and perfonnance demon-stration records for incorporation into the individual training record (Figure 8.1 - 4).
E. Smith Project Field Quality Control Engineer j
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D. M. Thrnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp.
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I QC AI 1251A MPQAD AFR M-01-24-1-01 QA'AI S-920 After giving consideration to the request of MPQAD in QA AI S-920, and evaluating the requirements of ANSI N45.2.6 and AA/ PSP G-8.1, it is the position of Bechtel Quality Control that our current program for documentation of training is in compliance with these standards.
QA AI S-920 indicated that on the job training must be documented to provide the detail necessary to render the quality of the docu-The following items provide more than adequate ment determinate.
assurance that training and certification documents support qualification of Bechtel CQCEs.
r, Training necessary to establish the minimum level of ed-1.
ucation is always documented in accordance with AA/ PSP G-8.1.
On the job training is documented when necessary to support 2.
certification where minimal related experience, exists.
The approximate duration of which on the job training takes 3.
place can be identified by the difference between the com-mencement of CQCE training and the certification evaluation dates.
Finally a comprehensive oral and performance evaluation is 4.
conducted by a level II Quality Control Engineer which at-tests to the fact that a satisfactory level of training and/
or experience exists prior to certification.
In view of this response, Bechtel Quality Control will continue with their current program of training documentation; however, if formally requested by the client, Bechtel Quality control will begin documentation of on the job training relative to initial certification in a given PQCI.
T/N 23428 J
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.KEQUEST FOR FURTHER RESPONSE
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FNOW D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp.
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QC AI 1253 MPQA AFR M-01-24-1-01 QA AI S-920 The above reference identifies that on the job training is to It also states be a part of the QCE certification program.that on the job training is being c Control, but not documented.
8.5 of AA/ PSP G-8.1 Rev. 4 sets forth specific require-It is the position Para.
ments for documentation of training sessions.
of Bechtel Quality Control that this reference as well as ANSI N45.2.6 Section 2.2.1 identify the documentation requirementsQuality Control for formal (i.e. classrocm) training sessions.is and will continue to do Quality Control feels that this meets the requirements of PSP G-8.1 and ANSI N45.2.6.
The frequency of documenting on the job training has increased in the past five (5) months for the purpose of evaluating the total amount of training being conducted within Quality Control.
s Bechtel Quality Control's position that we i
are meeting the requirements of the appropriate standards and In summary, it procedures in respect to documentation of training.
No further action'by Quality Control is therefore required.
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t PftoJEcT3. ENQiNEEMNG AMo CONstCUCTioN-AUDI.
FI U. NG h,?0 L.. OuALITY ASSURANCE DE l
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1-3 /I-3 Start Up: Indeterminate AI: S 921 an sa so
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- 1) ANSI 45.2.6-1973, Table 1, indicates that only Level II's
((,241-02 I
' may " Evaluate inspection and test results" and that " Reporting Bechtel QC of inspection and test results" is done exclusively by Level IIs July 3, 1981 anwamunos:
- 2) Paragraph 4.2.2(4) of AAPD/ PSP G-8.1, Revision 3, dated March 14, 1980, lists " review and acceptance of report of in-
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spection and tests results" as a Level II, not a Level I, duty WRBird and responsibility.
- 3) Quality Control Instruction (QCI) 7220/C-2.00, Revision 1, CAChien/KFH JWCook Activity 3.1 calls for the following:
MADietrich
" Test Review 03KI'7 A.
Review and sign Lab Test Reports verifying:
BWMarguglio Quantity of fines is reported (PPM).
DBMiller 1.
Completeness of for=s (all applicable blanks filled in).
JARutgers 2.
Proper date and location.
AESchlaifer 3.Review and sign Lab Test Reports verifying quantities of ESmith B.
fines meets specification requirements for:
DATaggart 1.
Individual wells RAWells NOTE:
If fines exceed the specified tolerances, resam-JLWood ALAB-2 ple in accordance with Activity No. 2.1.B.
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Ravise any pertinent procedures and instructions so as t.o assure that all reviews 1) for evaluation or reporting of inspection and test results are made only be a Level II QCE.
- 2) If the explanation above is the official position, revise the QCI Act. No, to re-flect what the Level I is actually inspecting.
(Continued on care 2) concur that it var inappropriate for a Level I QCE to sign off on c m,m.=n. m.,,u:.
Bichtel QC did not A formal response detailing the Bechtel QC position is requested within Act. No. 3.1.
30 days of the receipt of this report.
FDK8 fulGEJ cla cCascasM cac 32J ital clas Datz W C/a cour*.3nce:
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ATR SERIAL NO: M-01-24-1-02 PROJ/ DEPT: Bechtel QC DATE: July 3, 1981 FILE:
18.4.3.6 i
CONTINUED:
"AS IS" CONDITION VERSUS "AS REQUIRED /"AS NEEDED" CONDITION 3.
Average quantity of the systemIf the average quantity of the system exceeds those spec I
2.
NOTE:
If the con-subcontractor has 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to correct the condition.
dition has not been corrected, individual wells shall be resampled and tested in accordance with Spec. C-88, Section 6.A.2 (re-sampling in accordance with Activity No. 2.2.5 an'd C)."
Contrary to the requirements of Paragraphs 1 and 2 above, the activity de-scribed in Paragraph 3 above was signed off by a Level I in one of five cases 4) i reviewed.
Reference QCIR C-2.00-31.
An explanation was forwarded indicating that the Level I was only inspecting 5) to ascertain that the test report was available and properly approved by a Bechtel Level II.
RECOMMENDED CORRECTIVE ACTION:
Review any QC records in which a Level I QCE has performed evaluation or re-3) porting of inspection and test results.
Have a Level'II QCE review the referenced QCIR and any others identified as a result of the review in #3 above and correct in accordance with PSP G-7.1.
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C011 Sum 8f5 Dmurnbun, ecAD no POW 8r oat October 9, 1981 sussccv MIDLAND PROJECT,-.
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-a-w File 16.0 Serial 141536 INTraNAL Coastspo=otnet cc CAChien Dehorn ESmith File 18.4.3.6 I feel that the atriit finding takes a rather narrow view of the word " review,"
and that the problem is one of semantics rather than a violation of the QC program.'
In Activity 3.1, the inspector is inspecting a piece of paper to specific In my opinion, this accept / reject criteria which are included in the PQCI.is within his area o It is, perhaps, unfortunate that the instruction uses the word " review" G-8.1.
instead of " inspect" or " read."
It is my opinion that the word " review" in the context of ANSI N45.2.6 involves It differs from " inspect" which a measure of judgment requiring experience.
involves only comparing a characteristic with a specification or a pre-estab-lished criterion.
Since both auditors involved in this audit have lef t the site, I am a! mini-
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Na 23437 PLEASE RECEIPT AMo RETURN BECHTEL POWER CORP.
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e QC AI 1252B MPQAD AFR M-01-24-1-02 QA AI S-921 Per conversation with MPQA QAE D. Horn on 10/1/81, the.Bechtel Quality Control position regarding Level I/II review and ac-ceptance of inspections was evaluated and accepted as meeting the requirements of ANSI N45.2.6.
The basis for concurrence were two points:
When reviewing documentation, the Level I QCE is only 1.
comparing data for accuracy and completeness.
2.
.All inspection records with attachments are reviewed and accepted by a Level II QCE.
Additionally, D. M. Turnbull letter to E. Smith #14153 concurs that AFR M-01-24-1-02 is a completed item and that no further response from Quality Control is required.
T/N 23437 O
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9/21/81 A E Schlaifer M
VIJ.,CATICN OF GRLIER RESPCNSE Response-QC AI-1252-A, dated 9/14/81, restates the BPCo to AA/ PSP C-8.1 paragraph 4.2.1, that a Level I QCE's duties and re-position with respect spensibility is in the performance of designated inspection and tests as specified in the The response also recites AA/ PSP G-6.1 paragraph r.pplicable PQCIs, specifications, etc.
- 3.3.3 which states that review means "To examine any form of documentation for the purpose of establishing its acceptability to specific requirements."
"Si.gnof f by the CQCE on the IR will be performed upo'n review PSP G-6.1 goes on to state:
cnd acceptance of said documentation."
According to ANSI N45.2.6-1973, as recited it. the earlier Request for Further Response, Evstluation of inspections and tests; Maintenance of surveillance over inspection and tests (Continued on page 2)
COCICGI, CA"A/AC 3 RKC.v ;
Provide corrective action as recorr: ended by the referenced docu= tent.
DISTFl3LTICN CCREScr :.
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RFFR - AI: S-921 Page 2 of 2 EVALUATION OF EARLIER RESPONSE: (Continued)
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performed by others; determining the validity - are clearly the functions of Acceptance of documentation is definitely a Level II func-a Level II -QCE.
tion.
If " acceptance" of documentation is intended to mean merely " receipt" of documentation, then it should be defined as such.
The fact that a Level II CQCE signs at the bottom of the IR is not relevant to the matter of Review of Documents by a Level I for Acceptability. The following transaction is recited from CPCo Serial 312FQA79, J L Corley to File 0.4.2, September.14, 1979:
"....Mr Callagher countered that these people had signed Inspection Records and, therefore, they had individually accepted the items. Mr Marguglio stated each individual htd signed for the characteristics he had inspected but that a Level II signature reviewing what they had done was necessary.
Mr Callagher countered by stating the Level II's were not looking at the specific " tests" that these people were performing (which, in actuality, are measurements and observations and not tests)...."
Thus, when a Level I CQCE signs an Inspection Record opposite the line word
" Review" where review of documentation means " review and accept", it con-stitutes an act that is not in conformance with ANSI N45.2.6-1973, Paragraph 3.2.2a.
In its response to the earlier Request for Further Response, BPCo QC failed to address the matter of the Further Request.
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23427 PLEASE RECEIPT AND RETURN E
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INTioNVENDORS: ALL FINAL ORAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANS UtENCIES.
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i QC AI 1252-A MPQAD AFR M-01-24-1-02 QA AI S-921 AA/ PSP G-8.1 para. 4.2.1 states that a Level I QCE's duties and responsibility is in the performance of designated in-spections and tests as specified in the applicable PQCI's speci-fications etc..
AA/ PSP G-6.1 para. 3.3.3 identifies the methods to be used for performing the ins?ection activities.
One of these methods is the review, which states, "To examine any form of documentation for the purpose of establishing its accept-ability to specific requirements".
PQCI C-2.00 requires the Level I QCE to review the test report for completeness and ac-curacy.
It must be noted that a Level II QCE has in all cases reviewed this test report'previously to evaluate the results of the test and determine the validity of the test data in com-pliance with the project specifications and subcontractor pro-gram requirements.
This Level II QCE review and acceptance is documented on the test report.
In summary it remains the position of Quality Control that the requirements of PSP G-8.1 and ANSI N45.2.6 are being. met.
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9/1/81 9/3/81 l A E Schlaifer 551 l/ALCATICN CF hm RES?CNSE Eased on the ANSI N45.2.6-1973 definitien of the qualification i of level I vs Level II persons, CPCo's position is that the observations noted in referenced ATR nre in conflict with the program requirements. This is vs BPC 'pos'ition to the contrary.
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L BPC position is based on the statement, among others, that:
.. 2) The Level I is only comparing data for accuracy and completeness..."
According to ANSI N45.2.6-1973, Para 3.'2.2a, a Level I person is quilified to:
1.
Perform inspections and tests.
2.
Be familiar with the tools and equipment to be employed and be proficient in their use.
3.
Be familiar win inspection and measuring equipment calibration and control methods.
. (CONTINUED)
EITIC:3.L CA"A/AC""CN RE UI.. 2 Provide Corrective Actiofas reco= ended by the referenced document.
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'CA RDCTING IIGINAICR WIL"? FILE CKL*'.:t 7/3/81 DISCCSSED WITH E Smith CN (CATE)
The Audit Finding Report noted that BPC QC did not concur with the Audit Finding, NEXT REFLY AGREED TO BY (DATE)
PITASE REPLY BY (DATE) 9/11/81 GIVING DATE BY WHICE NEXT c rLY CAN BE Ee.
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Evaluation of Earlier Response (cont'.):
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Varify that the equipment is in proper condition for use;
) o Laval II person is qualified to:
s, 1.
Parform inspections and tests.
g 2.
Evaluate the results of inspections and tests.
- 3. - Supervise or maintain surveillance over the inspection and tests parformed by others.
4 ~. Calibrate or establish the validity of calibration of inspections and consuring equipment.
5.
Plan and set up tests.
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Deter =ine the validity of test results.
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FRoM D. M. Turnbu,11, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp.
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-MPQA AFR M-01-24-1-02 QA AI S-921 Quslity Control's position is that the observations noted in ref-orenced AFR are not in conflict with program requirements for the following reasons:
All test reports were reviewed and acce?ted by a Bechtel 1)
Level II QCE as being in compliance with specification re-quirements prior to being submitted to the QC department.
The Level I is only comparing data for accuracy and com-2) pletness.
All inspection records with attachments are reviewed and 3) accepted by a Level II QCE as a QCIR closure function.
In summary, it is Quality Control's position that the require-ments for review and acceptance of data by a Level II QCE are and therefore there is no deficiency and no action is being met, required.
T/N 23416 4
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a ConSum8FS u power Company a
MW6end Preiset: PO ter 1563 Midland,MI 44440 *(817) 8314 951 0::tober 29,1981 Mr E Smith Bechtel Power Corp PO Box 2167 Midland, MI 48640 MIDLAND PROJECT.- CONSUMERS PohT.R AUDIT M-01-24-1 6
Serial 14448
References:
1.
ESmith to DMTurnbull, FQL-844 dated October 9,1981.
2.
DMrurnbull to ESmith, Serial 14068 dste October 15, 1981.
'Ihis letter documents the closure _of Unresolved Item (URI) 03._,
Faference 2 documented the closure of Observation 2 and URIs 01,;02 and 04.
'Ihe basis for closing URI 03, which involved the specificity of criteria used by certifiers in evaluating candidates for Level I inspection certifi-cates, is described below.
a 4,4s,. u m
You stated, by telephone on October 29, 1981, that the practical training whic!Lled to certification would be shown on candidates' "Redord ofyaining".
%6 the future.
'Ihe MPQAD will conduct its own evaluation of the certification process aM of tEEcahdidates on 'an~engoinifbisi~s as'discribed h mp'l'estE SdifaT~14076
'raDieF~th~an dependinci'en programmatic ~or Tocumentary chahgh's Tri~theBechte
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system.
'Ibe above has no relationship to the matter of Revision 4 of AAPD/ PSP G-8.1 being put into effect without MPQA approval. I understand that you are works.ng to correct this now.
4 %. A.
D M 'Darnbull.
Site QA Superintendent DHT/ dea CC WRBird, P-14-418A BWMarg.)glio, JSC-220A MADietrich, Bechtel QAE TKSubramanian, Midland QA y
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Compuy Mienend Proleet: Po Ben 1943, Midland, Mi ass 40 (3177 s:;1-oest October 15, 1981 Mr E Smith Bechtel Power Corporation PO Box 2167 Midland, MT. 48t;40 NO MIDLAND PROJECT - YOUR FQCL-844, File 16.0 Serial 14068 AI: S-1087 Your response to Observation #2 is accepted in light of the way in which this observation was worded. However, you are aware, I am sure, that the auditors involved in this audit are no longer on site, and so your responses must be evaluated by different personnel. This naturally introduces some different thoughts on the subject.
As I see it, Rev 3 of AAPD/ PSP G-8.1 contained a commitment to evaluate the Revision ef fectiveness of the job site training program on an ongoing basis.
4 of this docu=ent deleted this commitment and I am unable to find anything Your respense, referenced above, says you do evaluate the which replaces it.
program on a continuous basis, which mades me feel comfortable about the pre-sent, but the deletion of the co=mit=ent causes me concern about the future, I would appreciate your and must be viewed as a degradation of the program.
comments on this aspect of the problem, and I would also appreciate having a print of the MPQA approval of Revision 4.
We are not able to find it in our files.
Your response'to URI-01 is accepted in light of the wording used in 4.2.1 of Revision 4, which can be' read as saying that providing training to uncer-tified QCE's is a duty, as opposed to a responsibility, of Level I personnel.
The thrust of URI-01 was that such responsuility should rest with Level II people, even if the actual work was delegated, on eccasion, to a Level I.
Your response to URI-02 is acceptable.
Your response to URI-03 does not resolve the basic problem we have. My k interpretation of Criteria V and XVII of 10CFR50 is that QCE qualification
- folders should contain enough data to permit objective evaluation, by a third party, of the competency of the individual to perform his assigned At present, all we have is a certificate that in, th_e opinion of the tasks.
certifier, based onhown criteria, the person is cot:petent.
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, s 55rici 14068 We do not record any details of the certifier's evaluation of an applicant's past experience, or his assimilation of training, or the nature of the y
This does not permit questions he asked during the oral examination.
independant evaluation of the process or the capabilities of the person,
/
which is the intent of criterion IVII of 10CTR50.
It is also my opinion that the guidelines provided to the certifier lack specificity, particularly in the area of education and experience require-ments, and what deficiencies in these areas can be made up for by training.
We f requently rely on Section 5.1.2 of G 8.1, which abrogates the specificity of Section 5.2, but without providing alternate speifics. This places all our reliance on the personal judgement of the certifier, which can vary from person to person and from time to time, depending on how badly we need people.
Bearing in mind that the competency o'f histing personnel is to be evaluated
}yanupcomingspecTalaudit,andthatimprovementstotheprogramwemake now need not impact past activities, it is requested that you approach this subject in a constructive manner and see if you can provide the documentation necessary to eliminate the need for special audits in the future, or the need for MPQA to witness certifications.
Your response to URI-04 is accepted.
i D M Turnbull MPQAD Site Superintendent DMI/tka CC WRBird JVCook MADietrich BWMarguglio DBM111er RAWells JLWood DCC 18.4 3.6 e
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"."MicNgan 4864o Midland FIELD QUAL!iY A3 SURA? ICE October 9, 1981 IdDLAF.'D, MICHIGAN ncison mui ELT v
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P. O. Box 1963 mur ro rits Midland, MI.
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- Attention:
D. M. Turnbull
Reference:
Midland Project, Units 142 CPCo Audit fM-01-24-1 Observations 2 6 4 URI's as detailed below FQCL-844
Dear Mr. Turnbull:
Reponse to M-01-24-1 Observation #2:
Quality Control evaluates the effectiveness of the QC training pro-gram on a continuous basis through previously established programs i.e. review of NCR's, MFQAD Trending etc..
Therefore, Quality Control has determined that a revision to PSP G-8.1 is not war-rented.
Response to M-ol-24-1-01 URI:
PSP G-8.1 Rev. 4 para. 8.3.1 requires that a one hour minimum training session be held at least once each month by a Level II Additionally, training records substantiate a signi-or III CQCE.
ficant amount of training for uncertified CQCE's by Level II CQCE's.
Therefore, Quality Control has determined that a revision to PSP G-8.1 is not warrented.
Response to M-01-24-1-02 URI:
these Clarification of PSP G-8.1 Rev. 4 para. 8.3.1 is as follows:
. consistent with training sessions shall be attended by CQCE's.
work operation in progress, it is logical to assume that a CQCE may not have a minimum of one hour training per month.
Although we strive to give all CQCE's a minimum of one hour training a month, PSP G-8.1 Rev. 4 does not specifically require that all CQCE's receive a minimum of one hour training per month by a Level II or III.
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-Mr. D. M. Turnbull October 9, 1981 Pa'ge 2 J
Response to M-01-24-1-03 URI:
Current requirements in PSP G-8.1 Rev. 4 require that an oral and performance evaluations be made by Level II's prior to issuing certification in a PQCI.'
Equivalent" experience is evaluated s
during training for certification.
Because a prior determination of "how much" training an individual will require cannot be made by reviewing a resume', all perspective' applicants for certifi-cation receive standard orientation and PSP training.
Additional-training in specific PQCI's varies depending upon how quickly the applicant " picks up" on the paper flow and actual field work operations.
Response to M-01-24-1-04 URI:
S In the case stated, Mr. Van Doorne's verification of training exists in the proper completion of Appendixes 8.1.1 and 8.1.2 of PSP G-3.1 Rev. 4, the oral and performance documentation, with the recommendation of certification statement in the remarks section on the bottom of the forms.
Additionally a completed QCIR reviewed and ap? roved b the Level II or III giving certification assures that the candidate can perform the work operations.
As stated above the determination of whether the candidate was ready for certification was based on interviews with the QCE during on-the-job training.
If you have any further questions concerning the above, please 4
contact this office.
Sincerely, E. Smith Project Field Quality Control Engineer hf' ES/SDK/BTF/jmk L
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PLEASE SCCEIPT ANo RETURN TR N$[IINI"L bRM 11/17/81 oat:
SUBJECT CODE
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8 D. M. Turi 2 bull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp.
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NRC Inspection Reports 79_10. 79-19 275. NRC Inspection Report 79-10 covered an inspection conducted'in May 1979. D In the report Mr. Gallagher, one of the incpectors, indicates a dissatisfaction with the ANSI qualifications of quality control personnel in the area of enntainment post-tencioning.695/
He did not issue a non-compliance concerning the matter.
ANSI, the American Nat.ional Standards Inr.titute, comprises c'ommittees wnich represent experts in particular engineering areas.696/
The commitees set industry-wide standards.for a particular discipline. N Mr. Gallagher is not a member of any ANSI Committee.698/
Mr. Gal 3 agher testified that, in the technical judgment of Consumers Power, the post-tensioning inspectors were quali-fied under applicable ANSI standards, but that he disagreed with this analysis.699/
In September 1979 Consumers Power management and Mr. Gallagher met to resolve this differ-700/
ence.
The NRC is now satisifed with the inspector's qualifications.701/
694/ Gallagher, Tr. 2427-28.
695/ Id.; Stamiris Exhibit No.
3, Attachment No. 10.
. _ 696/ Gallagher, Tr. 2458.
697/ Id.
698/ Id.
699/ Gallagher, Tr. 2460.
l 700/ Gallagher, Tr. 2428.
1 701/ Gallagher, Tr. 2428.
L.
~,
l 4
-173-276. The question of quality control inspector quali-
[
fications also arose in the context of the planned remedial 02/
work on soils.
Mr. Gallagher expressed the view that Consumers Power, as well as other nuclear construction permit holders, have misused an exception in an ANSI stan-dard (ANSI N.45.2.6). 03/ He opposes the exception in the J
standard which permits the substitution of certain educa-tional or experiential requirements for inspectors if an equivalent level of competence can be demonstrated.704/
In Mr. Gallagher's opinion, the debate' over qualification of quality assurance personnel is "the biggest problem facing our industry today."703/
It was not peculiar to the Midland site, but endemic to the industry.706/
Mr. Cordell Williams, 07/
I the chief inspector for Region III in the civil area, disagrees with Mr. Gallagher's assessment of the ANSI waiver provision.708/
He believes the flexibility it provides is necessary.709/
4 702/ Gallagher, Tr. 2432.
703/ Id._; Gallagher, Tr. 2460.
704/ Callagher' Tr. 2432.
705/ Callagher, Tr. 2433.
706/ Gallagher, Tr. 2433.
707/ Williams, Tr. 2197-98.
708/ Williams, Tr. 2207.
1 f
709/ &
,--y 7.-
r.-,
r,_
-~.,
-174-277.,According to Mr. Marguglio, the Midland quality control uld quality assurance inspectors are well qualified.710/
For example, as a part of the recent improvements in the MPQAD quality assurance program, quality control inspectors are required to be certified on particular inspection plans, a requirement in excess of ANSI standards.711/
John Gilray, from the NRC Staff, cited these upgraded qualifications in his affirmative assessment of Midland's quality assurance 712/
program.
In the recent MAC audit, qualifications of both Bechtel and Consumers Power inspectors were reviewed.71'3/
The auditors found the inspectors properly qualified for the tasks to which they are certified.7147 g
278. Mr.. W:'O testified.that the number of persons present1 the b land civil a ance staff is some of the[ planned remedi"al ade te.715/
o w e'; e r,
s
/
ork, differ ntly quhlified personnel may,be"<necessary'.716/
/
,/
/
p.-
6 Poyid,r is aware of th'is andda/s pledgef 'to acquire
/
Consum ernons as a c.onditiy/recedent to the iemedial work.717/
/
.r-
{'
such 710/ Marguglio, Tr. 1529.
711/~Marguglio, prepared testimony at p.
32, following Tr.
1424.
712/ Gilray, Tr. 3713.
713/ Staff Exhibit No. 4, at p.
10.
714/ Id.
715/ Williams, Tr. 2216.
716/ Id.
O 717/ Marguglio, Tr. 1529.
..,. -.. - +.,. - - -
'~
I
/
l e
C G) 3{/
10 9 -
v 229. Another adverse finding of the May 1981 inspection involved the qualification of personnel doing first-line inspection.
Tr. 2202-03.
It appeared to the Staff that quality control personnel did not have adequate experience for quality control inspection._ Tr. 2202.
CPC's own records also denonstrated NRC's basis for this concern. Tr. 2203. Staff witness Cordell Williams testified that NRC discovered certain failures of the sort that an experienced quality inspector would not make.
Tr. 2206. He
{*
recognized that the ANSI Standard N45.2.6..which is recognized by the NRC Regulatcry Guide 1.58, allows a fairly. liberal interpretation concerning th(
qualifications of inspectors. Tr. 2206. The NRC questioned the extent to which CPC is applying the ANSI Standard.
Tr. 2206. Mr. Williams later testified, however, that the NRC's concerns about the adequacy of experience O'
and education of QC and QA personnel arising out of the May 1981 inspection is one that has been addressed at nearly all plants and that the problems are no worse at Midland than they are at other plants. Tr. 2212.
230. Staff witness Gallagher critic'ized the industries' standards for qualification and experience of inspection and testing personnel as permitting too much latitude in provisions for waiving educational and experience requirements. Tr. 2432.
He testified that the provision of the industrics' standard addressing waiver of requirements is in hi' opinion s
abused not only at the flidland site but also at a number of other sites where the issue has been raised.
Tr. 2432.
231. On cross-exanination by CPC Mr. Gallagher agreed that the Merican j
National Standards Institute is comprised of committees which are g
representative of collections of experts and that their purpose is to derive g--
- --->e&
F
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industry-wide standards for particular disciplines. Tr. 2458-9.
Mr. Gallagher acknowledged that the committee responsible for ASNI Standard
,1 N45.2.6 hos discussed, debated and given consideration to modifying the standard but as yet they have not done so. Tr. 2460.
232. We asked Staff witness Gilray his views concerning the waiver provisions of the ANSI Standard. Mr. Gilray testified that he thinks the flexibility permitted by the waiver provisions needs to be there to certify and qualify an individual that.does not have high school or graduate education. Tr. 3845-46. He stated that whenever the waiver provisions are used there should be documented justification as to what proficiency tests or qualification tests the individual went through.
Tr'. 3846.
He further stated that the sort of documentation required is presently being studied by
~
the NRC. Tr. 3846.
233. 'The testimony in this proceeding demonstrates certain problems tnat arise from the lack of definitive standards for waiving the education and experience requirements of ASNI Standard N45.2.6 for QA inspection personnel.
In light of testimony that these problems have been addressed by the appropriate committee of the American National Standards Institute and the NRC and that no changes have resulted to date this Board does not believe it appropriate for it to undertake corrective action in that regard.
234 Another subject within quality assurance on which there was extensive.cro's's ex ation concerned the effect of the !!idl nd roject j
.1 Gality Assurance Department (MPQAD)--the new. integrated organization described by Mr. Marguglio in his direct testimony. Ma rgugl p'. 4, g seq.
In response to I tdrv'enor cross-examination Mr. Narguglio testified that
6912 mammu-
- M
- gj CliAII::' AU EEClHIO R'E R :
Mr. Gardner.
1-13. MILLER:
Ilr. Gardner, yes, sir.
That prcesss l was undcruay and we'bclieve that the staff would be able 3
,3j.to present testimony.
Eut one of the items that ::r.
i Gardncr requestad be donc and which the applicant agreed g
to do was to have a 100 percent over inspection of the
,t l
t
,5 electrial work iny_spect_ed by inspectors whose qualificatio..3 I
r e Tc p c e St-i.2 I had been subject to his audit and as to which thcre was_
4 r
s c r.ic c_ u e s t i o n.
a I
That request was made in early January ar.d at yg l the time that it was mads, when the company agreec to it, I
y we believed that we would be able to complete it in adequat:
I time for Mr. Gardner to review the results and present 7
i i
- 4
- testimony.
The scope of the work has increased dramatically 3,
I q!
in the sense that it was not known at that time just
'7 how many inspections these indiviuuals had been involved I
- 3 in.
tie have now determined that there was a significant I
M]
number of inspections.
The over inspection progrc:.' is 70 l proceeding, but it is not yet completed.
So it is for 21 that reason, I guess, that the staff will not be
'n l presenting 2:r. Gardner's testimony at this ti.ne.
I would 71 hope that cometime the week of the 16th perhaps we will i
74 Le in a position to have closed this item out.
/ *,.
The final preliminary matter that I nad really
)
ALDERSON REPORTING COMPANY. INC.
~
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i m.
6913 2-1rt2 i
.1 is a question to Judge I: arbour, who I understand was the I
2 ona of the board who was responsible for this, and that l
1 3
is the question of what issucs, if any, concerning the 4
quality assurance program on tha und2rpinning work does 5
the Board wish to receive testimony on?
M
-N A
6 l
!!R. PATON:
Mr. Chairman, I would li);c to respond.
I l
^
a_
7 to that before the Court responds to.the third of those N
1 8
8 three preliminary natters.
f N
i ad 9
CIAIR:A;i B ECliEO;:FER :
Fine, finc.
You may.
o G
10 11R. PATON:
Number onc, ?f r. Miller indicated E
l 11 that exceptions were taken to tae remand prcceeding by a
p 12 intervenors othar than Dou.
I think Mr. !!arshall would l
c prehably like the record to show that that do2s not include y
13 i
m j
j 14 the ::aoleton intervanors.
t j
E 15 l
MR. MARSEALL:
Correct.
I was going to state w
4, 16 that.
That is absolutely ccrrect, f
a g
i d
I g
17 i C I A I R M A'.4 D EClil:OEFEn:
I might say the Board wa:
1 72 18 received a copy of a motion f or exto:ision of time to file I
I h
it looked like; 19 exceptions and we just referred our copy g
s i
n and we referred it to the Appeal 20 an original almost 21 Board.
22 MR. MARSliALL :
It has been already denied and i
23
!!r. Paton is correct.
We do not participate in that.
24 C llA I R M A;4 B UCll!!OEFE R :
All right.
25 pdc MR. PATON:
I would also like to note for the LWW9-ALDERSON REPORTING COMPANY. INC.
_______.m____
6914 rt: 3 g g (_
- rilcove, 1
toard the appearance of co-counsel ilichael N.
r 2
U-i-1-c-o-v-c.
!!e ha s entered his appeara::ce in this i
3 proceeding.
4 With respect to the natter involving
!r. Gardacr,.
5 we didn't learn until very lata last wock of the greatly o
Ae d
6J expanded scope of that work or I think we vould have o
Rji 7
advised the Board about it. I think in fact that the final E
8' decision that it was going to be such that we couldn't u
06 9
get the job done, I learned of it I think on Friday
-i afternoon.
But I think before we, I think we should
.h 10 i
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5 11 '
get, try to get from the Applicant as specific information
<a d
12 -
as we can as to when he would be finished and be in a B
I l.
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position uhere the NRC could then go in and complete its t
a c
14 inspection.
t l
The other matter is that with respect to the E
15 i'
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questien to Judge liarbour about his questions on QA.
j d
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17 l I uculd ask the Board if we could, if possible, tnat we x
I 18 ]
pass over that and any other preliminary natters that l,
C would take any time if possible until we complete :tr.
g 19 j n
20 Keppler's testimony.
I have advised the Board that he t
21 has a very serious scheduling problem, and if there are i
22 any of these prelininary matters that we could handle 1
23 after he has completed his testimony, we would appraciate 24 it.
I i
2*
25 t
1 I
t s
ALDERSON REPORTING COMPANY. INC.
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6941
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1 JUDGE DECKER:
Mr. Marguglio, are you familicr 2
with these two audit. reports, Consumers Exhibit 22 and 3?
4 3
A (Mitness Marguglio)
Yes, more familiar with 4
ths latter because the latter was performed during the g
5 period when I had more responsibility with regard to E
g 6,
Midland.
t
-k7 JUDGE DECKEn:
You said that you read these M
j 8
and that if you saw cha,nges in there that were a particular i
d6 9
concern or a particular seriousness that you tcck some z'o i
g 10 t action.
Did you do that in either case here?
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A (Uitness Marguglio)
With regard to the second l
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MS. STAMInIS:
I am sorry to interrupt, but c
t 14 ;
when you say "second," do you mean the November?
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9
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I g pibi ej 15 A
-(Witness Marguglio)
The latter one.
With a
y 16,
regard to the November audit, the November, '81 audit, l
i l
17 the report for unich was published December 14.
w t
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18 I should make a clarifying point that when the l
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19 G At bi + 13 i
other audit was published, my responsibilities with g
20 regard to Midland were limited, as I had already testifica ;
i 2I to the Board.
22 l
CHAIRMAN BECilllOEFER :
At this stage we will turn.
23 back to you.
I think we wanted to demonstrate what relat-24 ionship Mr. Marguglio had.
1 i
25,
JUDGE DECKER:
Yes, I guess I'd better ask the i
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6943 }
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5-2,pjl the distribution And you are on JUDGE DECKER:
do you do with these when you get 1
- tt i r,
2 list for these.
What g
3 them?
These audit reports or any (Witness Bird) 4 A
formance report quality action request or non-con 5
audit the as are most of l
y I,
that is written by MPQAD, nf 6
report so my comments go peoole who are on the distribution --
R' i 's My' actions are similar to Mr. Margugl o 8
7 i
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8l for all of them.
1 I have i
tried to reflect back on what 4
I 9'
I read them.
there that is any threads 3
see if there f
10 f seen before to is specifically require more specific action than
=
5 13 might I read them in any of those given reports.
5 y
12,
called out they really could be under-sure that o
I for clarity to make 13 can be no miscommunication in there 5
' stood, that there m
specifically loo' I4 5
And I anybody could misunderstand.
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15 l is being classified as the root cause, is that y
16 f to see on what is being proposed in these appropriate d
f h
II l the action that ALL G. S.
m b
I8 to prevent recurrence.
That's all I have.
E JUDGE DECKER:
19 Stamiris, you may Ms.
Cl! AIRMAN BECH!!OEFER:
20 take a morning break for 15 think we will 2I resume, but I 22 minutes.
MR. MILLER:
May I just inquire, Mr. Chairman f
2 l
examination of these cross as to how much additional 24 1
25 witnesses?
s ALDERSON REPORTING COMPANY,INC.
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6972 i,pj 2-3 48 h
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I suggest who-you should bring in.
MR. MILLER:
Yes.
2 l 3
' CHAIRMAN B ECll110EF ER :
It appeared of these two 4
that Mr. Bird would be somcwhat more knowledgeabic.
5 MS. STAMIRIS:
Judge Bechhoefer.
g I
6 CllAILMAN BECHIIOEFER:
Yes.
a G
f MS. S T A M I R,I S :
Regarding that ruling then, when f
b 7
A explaining where I was going with this, you know,
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8:
I was i
9 I explained how it related to Item J and I think we have d
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l 10 settled that now.
3 i
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II CHAIRMAN BECHHOEFER:
All right.
The other
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12 question I might ask, why don't you ask it now, because l
, s" l
e 13 that may --
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i I4 J MS. STAMIRIS:
Well, I will ask it now.
v.
a l
E is l-CHAIRMAs BECriHOErER:
wcil, I do not mean right L
5
.j now, but'today.
16 v.
N I7 MS. STAMIRIE:
Okay.
But my only -- the ques-
"a l;
{
18 tions that I have to ask that have to do with Mr. Turn-I E
bull's actions as documented in letters along with this I9 '
)
I e.
l n
20 first audit report, Exhibit 23, they will take -- you l
21 know, it will take a little bit of building up to that.
t t'
it will be a series of questions.
I do not want j
22 l I mean, i
23 to simply ask Mr. Marguglio "Did Mr. Turnbull's change i
24 in position have anything to do with these items,"
l 25 because obviously I think he said that he wasn't deeply l
ALDERSON REPORTING COMP ANY. INC.
[
6973 l,
j Q-3, p j.3 i
involved in this first audit report; and, secondly, I g
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answer of no if that be 2 l do not want to just accept an 3 ;
the case if I have something that I would like to question I
l.
I 4
about.
5 For that reason, I do not care when I ask my e
A but if I ask my l
6 questions, whether it be now or later, n
j l
it will take a R
J am preparing you that j
l questions now, I
b 7
there.
If I ask my questions a
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series of questions to get s
U to be precluded from asking anything l
o 9
later, I do not want l
y.
L 2
10 about the organizational change.
LJ E
l en other words, what I am trying to say is I II N_ I2 )i Turnbull M
think the questions I have to ask regarding Mr.
i-13 will flow from the Item J cross examination that is scing
% S 15 If I could also at that time
.l I4
- to be postponed until later.
v i
few questions about how it a
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15 be permitted then to ask a i
then maybe ne can JI C
5 I0 related to the organizational change, h
II '
put the,whole thing off until later.
But that's the W.
e 18 situation that I am faced with.
3 j
t9 5
19 i g
l t
a 20 21 22 23 1
(:: ll ALDERSON REPORTING COMP ANY. INC.
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_._m 6974 :
$9-lrtl'.
L MR. !! ILLER :
I don't know what sert of claborci.c 1 >
t 4
~
extent ths.y deal I'
r 2
questions !!rs. Stamiris has, or te the tnE :
3 with t he organizational change, let's get tnem out on 4
tabic now.
!!r. 24arguglio was here and I do not intend l
\\
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l to recall him, unicss dir:cted otherwise.
X.
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CI: AIR: A i LECl:! OEFEn :
Uhy don't you start at A
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6, 7
! least and see to what ex tent ycu have te get into the t
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details.
O d
9 BY MS. STA. :IPcI S :
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lir. :4arguglio, are you familiar with an October o
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11 15 letter of Mr. Turnbull's which is I believe six p: gen is I
y, 12 from the end of the pcchst of papers in Exhibit 23?
c
.. g 13 A
(Witness Marguglio)
I just rescanned it during i-c l
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14 this racant break.
ii b
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15 -
0 In his second paragraph when he speshs of l
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- l 16 Revision 4 of ALPDPFPG S.1 which deleted a commitmant v'.
d 17 for evaluating the effectiveness of job site training f
w I
18 program, are you familiar with that revision?
E 19 A
(Witness 1:arguglio) Not specifically.
But if l
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20 you road the next paragraph, it obviously was :tr. Turnbull'.
21 opinion that Revisien 4 was a good thing because he I'
22 accepted the closure of the unresolved item basea on 23 Revision 4 and based on the response that was made by 24
!!r. Smith on October 9, Which is also included in tnis O-
'l Let me sce.
Yes, thrse er four pages back.
25 l pachaga.
ALDERSON REPORTING COMPANY. INC.
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e 6975 19-Irt2 1
O Would you be more specific?
I don't kno wh<re.
j 2l A
(Witncss Marguglio) 1.*c l l, you just rcfurroc I
3 me to a letter signcd by :ir. Turnbull on October 15.
4 0
Yes.
p 5
A (Uitness Marguglic)
If these package.s arc e
l collated consistently, turn one, tuo, thres, four pcces
[
6-g 7
and you should cer..e to a letter fron I;r. 5:ai th to.ir.
7.
8 8
Turnhull dated October 9.
And in,the second paragraph of r3 ci 9
that letter 21r. Smith gives his response to unrasciv.'
i cg 10 i
Igen 30, 1,
7-
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ll How, if we go back to L;r. Turnbull's letter j
=
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12, of October 15, wa see in the third paragrap.: of t h a. t 5
I 5
j letter that Ir. Turnbull accepted that response partially 13 '
i
=
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I4 l v:
on tha basis of Revision 4.
So I concluded that.r.
Eb
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15 Turnbull was satisfied.
Ec
.=
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Do you follo: that?
I N I7 ll 0
Yas.
But I have to re-read.
I follow that, u
e:
It doesn't say I agree with it.
I am not sure.
I uculd 18
~s" 19 g
have to re-read this and see.
l 20 This is very difficult without, you know, i
i 21 building up the whole chain of communicaticns back and 22 I forth between Bechtel and :tr. Turnbull and others at i
f
' ut I'm Consumers that resulted from the original audit.
s 23 f
going to take -- if I'm to do it nou, I need to take 24 25j, a mi ote to read this and sec.
ALDERSON REPORTING COMPANY. INC.
_.--ne.,
m.
6976 j
'-Irt3
- I MR. MILLL'n :
With all du.c respect, I don't 2
understand what sort of claborate build-up is nccessary
~
l
_l i
to get from these communications, which seem to me to 3
4 deal with the details of the audit report, to any qucstions y
going to the organization or the re. organization.
- Hrs, 5
n 0
Stamiris articulated a question that I uould certainly
^n like to hear the ansucr to and I suspect the Board would 7
I 3
i I think it is unstr.cr 8
8 too, which is whcthcr :ir. Turnbull o
i 0
ci 9
Turnbull's performance in ec..ncetion with this audit Mr.
.7e y
report had anything to do witn his change in assignr.ent.
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11 And I don't know that a n-r elaborate build-uo i
B I
r3 12 z
with respect to details of the audit findings is necessar2
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l E
14 MS. STA'ILIS:
Well, by asking that questien j
y I
~
E 15 we would get to Mr Marguglio's answer, but we uculdn't x
t B.
get to it by way of viewing the documents which might i
16 r.
((
17 I disagree with his answer, w
c:
15 18 MR. !!I LLL'R :
Well, excuse ac, why don't w e g e t.
A f
8 his answer on the record; and then if you have s o:.:e tni n g 19 n
20 which you thin). impeaches it from these documents, let's I
21 i
show it to the witness and get his ansuer again, l
MS. STAMIRIS:
I avoided asking the qucstion but 23 I'didn't want to be closed out then, you know,.on the I
e I
basis of his response.
I didn't want to be closed out 25 1i from pursuing it.
1 I
ALDERSON REPORTING COMPANY. INC.
1
.1
_.u a__
6977
.-Irt4 l
,?
.1 MR. MILLEn:
Well, excuse me, Mr. Chairmen.
i O+2 I'think that what Mrs. Stamiris hoped to do is get 3-soranthing that she evidently feels that she can argue 4
'from these documents, that any ansuer that Mr. Marguglic to Mr.
5 gives to the ultimate qucstion with respect g
[
6 Turnbull's change of responsibilities is wrong or is not 9-R That's an 7
borne out by what's in these documents.
7.[
8 argument that she can make in the, supplemental f i n -!in g.s
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9 or whatever.
i e
7.
these witnesses with details of. thc.s t o
g 10 But to tax E
a 11 audit findings and then in order to -- I don't know, E
the record as the datails cf ths g
12 somehow spread it on audit finding, I think is improper. This document is J!
13
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i and make whatever arguments you wish.
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14 -
now in evidence t
2 15
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16 kr; p
17 i
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18
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20 21
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23 24 25j ALDERSON REPORTING COMP ANY. INC.
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6978
' 9 - 3,'j 1-1 MS. STAMIRIS:
I think th a t part of the dif-3 w
2l ficulty here is that I really don' t want to ask Mr.
I 3
Marguglio for his answer and then a tt emp t to impeach his 4
answer or his testimony because I'm not certainly in a l
l I mean who am I, without any inside l
g position to 5
i g
6 information, to deny wha.t he says is true.
I don't think 9
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of this.
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I think that what I would be able to show by 2'
h 10 going through some of these things that had to do with c
l how Mr. Turnbull was a cting in response to at least II l
is I mean I2 #
these audit findings here, I think would.show E_
13 to be very frank, it seems like Mr. Turnbull was trying
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matters and some of the problems with how Bechtel was i
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16 responding.
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17 I may or may not be correct in that, but I 18 think that by virtue of the importance of Mr. Turnbull's
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change to the whole organizational structure, it might l
I9 20 be worth reviewing what kind of a job he was doing.
I MR. MILLER:
Well, maybe you ought to ash I
II l
2 Mr. Marguglio those questions as to what his evaluation 23l Turnbull's handling this issue.
gf Mr.
CHAIRMAN BECHHOEFER:
Why don't you do that 4 'g 25 in that form.
Just because you may get a general answer 4
ALDERSON REPORTING COMPANY. INC.
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5-8 6979 9 - 2, pi.2 1
first doesn't preclude you from exploring it a little bit.
i 2
BY MS. STAMIRIS:
I 3
O Well, are you familiar with Mr. Turnbull's l
4 actions in response to the July, June and July audit e
5 report?
I X
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A (Witness Marguglio)
Sufficient 3y I think to n
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further questions you might have, yes.
7 respond to any f
X i
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0 Did you not say a short, time ago that your a
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knowledge of 'this document was fairly limited though?
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A (Witness Marguglio)
No.
I said that I re-l o
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discussion.
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16 l these audits and to the change in his job position?
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17 A
(Witness Marguglio)
In response to the first, "e
18 I the point I would like to make is that I agree with your i
E 19 carlier assessment a moment ago that Mr. Turnbull uas g
e.
Bechtel 20 I aggressively pursuing the Bechtel -- appropriate i
2I action in response to these resolved items.
And I think 22 that his actions were entirely appropriate or at least 23 almost entirely appropriate.
There are one or two things 24 that are of very minor na ture with which I would disagree.
But in general I am very well pleased with the way he 25 j t
I ALDERSON REPORTING COMPANY. INC.
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2 Secondly, there is no connection between his 3
performance in response to this audit and his revised 4
responsibilities in the current organization.
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His performance that you spoke of in regards to-g n
3 6
this first audit report, was he acting as the QA site
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superintendent?
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A (Witness Marguglio)
Yes, ma'am.
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In performing those duties?
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A (Witness Marguglio)
Yes.
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why would you change it from being the QA site superinten-I3
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15 A
(Witness Marguglio)
I think the testimony was l
a 16 given in that regard aircady.
But first let mc reiterate that my statement about his performance has to do with
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e 18 this audit and his follow-up actions in response to this E
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audit.
i 20 l
It was decided to address the organiza.tlon for 21 a number of reasons:
First, there was the recognition 22 that we needed a higher level of management present at 23 the site; namely, my personal presence at the site for
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the majority of my time.
And with the recognition of that 24 need, because of the importance of the job, the state of 25 I
6 ALDERSON REPORTING COMPANY,INC.
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6951 E9-2,Pi4 the job at this particu]ar 1
the job,_the criticality of t
2 point -- that decision, it was a]so decided that it would lines of communica-to reduce the -- or narrow the 3
be best especially tion between myself and the section heads, 4
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personally I know I wanted to be involved in the detailed 5
I So that was one factor, i
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6
- day-to-day activities.
i 7
The other factor that became abundantly l
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8 obvious was that the site QA superintendent's job was 9
too large for one person to handle if one also had to i
b 10 get involved in the day-to-day activities in detal) and o
5 5
II get involved in all of those day-to-day activitics i r.
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12 detail.
So we decided that that superintendent's j o'r 5j 13 would be abolished.
And if I recall at the time this s
e there was a meeting before the m
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- testimony was given, E
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15 l berch at which some of the reasons were offered, which
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If I'm to follou your answcr correctly, he 2
am I correct in understanding you to be saying that when i
8 3
you proceeded that the site superintendent's job was toc 1
I decided to deal with that -- I am 4
large, that the way you g
talking about befort there wera any NRC desires expressed.
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A (Witncss Marguglio)
Yes.
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The way you darided to deal with that was to I
N 8
8 abolish it?
i 0
o 9
A (Witness Marguglio)
No, ma'am, that was only 2.1;f i
e 10 of what was done.
As I poin'.ed out, the most important II fact of what was done was to name me as the persen
- 1..
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II the Midland Project office directly responsible for the i
~c operation of the Midland Project Quality Assurance l "E 13 Department and to position ma for the majority of my time I4 e
at the time.
And I wouldn't call that half.
I eculd call
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i that 75, 20 perecnt of more o'f the impact of the chang-2.
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site OA superintendent positien and essentially givt
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18 the
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to Mr. Turnbull the responsibility for administration ana I
n special projects which I testified was a significant 0
21 job in and of itself.
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But aside from the shifting of organi cticnal 22 the respensibilitics that you spoke of, you did not, 23 1
Consumers did not, ccc fit to bring in a new persrn O*
25 until such time as the 14RC in essence required.it; is thct 4
r ALDERSON REPORTING COMPANY. INC.
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I correct?
2 MR. MILLCR:
You knou, we are now going L ci.
3 over ground that's been ploucd at least twice by Art.
4 Stamiris and once by me and once by the Board.
e 5
MR. HARS11ALL:
I haven't had a chance yet Lut E
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6 I will.
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7 MR. IIILLEn :
Suro.
5 E
8 CII AIR::A:1 B ECl!! OET ER :
I think that questica has N
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been asked and answered.
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10 MS, SOAMIRIS:
Okay.
Y-5 11 BY liS. STA;IIRIS :
'c specific qutstien
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Did you say -- I kncw I had a I wanted to ask and I can't remember it.
If I can just
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g 14 think for one minute, I might remcabcr it.
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15
-Regarding the findings in tha first audit rapert i
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16 which you said you were pleased uith the ucy they utre v.
d 17 being handled by Mr. Turnbull regarding the Lechtel i
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18 Consumers Interface on these open issues, do ycu believe
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that there was some foot-dragging on the part of bechtel h
19 '
n 20 regarding changes that needed to be made to improve
'2I quality control certification?
22 MR. MILLER:
I am going to object.
I really 23 think that is beyond the secpc of any ruling the Loard 24 has mcdc with respect to'these audit findings, and that 25( subject at the barc minimum is one thct has been deferrea l
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I for further discussicn at a later'timo.
2l C III.I R M idi E LCII!!OEl'E R :
We think the questien l
3 is within the scope of what we have permitted to be ashcd 4
about ncnt time, but since Mr. Marguglio won't bc nerc, I
y 5
he certainly can answer it now.
So we will overrule the i
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objection.
l R
A (Witness Marguglio)
"Give me a minute to 100).
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8 at the documentation, please.
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I think that Bechtcl had an hencst difference of P.C g
10 l opinion with regard to unresolved Ite:a No.
3.
I woulun't Z-I II cell it foot-dragging on their part.at all.
I wculd 3
p 12 just call it an honest cifference of opinion which they l
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communicated in the letter cf Octchar 9 to Mr. Turneu11.
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6 I4 Tha area involvcd with regard to unraselvas i-M l
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15 Item tio. 3 is one fer which the situation is very i
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Without going into detail with regard to l
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Item No.
3, there are generic industrial matters which j
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CHAIR:*AN BECHUOCI'ER :
Uould it bc in. gene 1
2 WIT:iESS MARGUGLIO:
The standard U452.0 requit 3
inspectors to have certain educational and experience 4
levels, so many years of colicgo or so many ycars of g
experi'ence.
This was the 1973 version and industry coulcn't 5
6 live with those requirements throughout the United States.
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8 8
was the chairman of the. work group responsible for that ac 9
standard.
- zo In 1930 a revision to that standard was issued g
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II and the requirements _
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levels of experienct were cel'etsc in lieu p
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y 13 I of recommendations, and the emphasis was placed on oral 1
5 I4 and written and physical demonstration tests of candidates, i
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15 fer inspection certification.
That's how things arc denc g
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-d now.
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I7 l In recognition that different individuals run e
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18 the track at different speeds, the emphasis is placed Y
g through the testing mechanism, cither oral testing, I9 n
20 written testing or demonstration testing or a combination II of both.
The emphasis is placed on that medium or on 22 l those media as mechanisms for determining the qualification 23 and certifiability of an individual candidate.
24 So the question arose in this arca, you h:.eu, 25 $ the question arose, well, how do ycu know how much traini:,5 1
i ALDERSON REPORTING COMPANY. INC.
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6936
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l0-lrt2 ion and to give to an individual relative to his educat -
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l is a totally opinionated question.
2 cxperience?
It there no guidclines 3
C 11 A I n n t.II BECI:itoEFE!::
Were 4
or standards?
are no guidclines There 5
UITNESS nl.2GUGLIO:
e
'A to how much training ycu N
score, as i
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industrywide on that i
absolutaly no guidelines other than in E
7 get.
Thcrs are S
spe.cifi.cally relate to non-destructive M
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9 exanination as covered in edcy liquid penetrant, negnctic particle,
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types of inspections that ue are k
d 12 But in the n
there are no guidelines whats:cvar.
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13 talking abc ut hers,
l So Mr. Turnbull cerely raised a questien, you m
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how do you knew he* nuch education -- I mean aou e
b 15 kn ove,
to provide to an individual based en that a
j 16 much training and,the responsa thet un g:t w
individual's past exptrience, h II !
one could have expectau.
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18 fron Bcchtel was about that they ucrc !!r e U
Bird just pointed out 19 Mr.
8 Keating 's questions originally and not fir Turnbull's,
n 20 Mr. Keating is the one which is a, proper correction.
22 I
that phrformed the audit.
CII A I R M A:1 LLCIIliOEFEn:
I take it lir. T u r ni,u l l,
~
24 i
since he urote those menos, though
- r. Keating had left our employ -
25 WITNESS DIRD:
ALDERSON REPORTING COMP ANY. INC.
i 6987 o*
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. ment sometime after he had donc this audit and I assigncd 2j Don Turnbull as the most senior guy out there to follcu-uy i
3' to get this all closed out.
4 CIIAIR:1.T 2 LECliliOETE ::
Okay.
Let me fc11cu-up a 5
little bit.
This, you mentioned this unresolved Item in Ej
'6 3.
Was thtre not also a dif fircree of opinion betweer.
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6.
7 Consumers and Lcchtel concerning a commitzt.snt to cvaluatt A
8-the. ef fectivcness of the job site training program o..
an O
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l on-going basis?
The thing that is referred to in x
15 litter.
o O
10 the second parag raph on !!r. Turnbull 's Oc t.ober
'd UIT!iESS EIRD:
The difference of opiz.icn was h
II t
is f
I2 not in the issue itself of whether thers needs te bc cn-I c
The going evaluation of the effectiveness of training.
a 13 5a 1
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14 issue uas whether the deletion of that one specific E
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dccument was apprcpriate or not. There was neve.
a qusstien u
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It was e
h I7 just whether do t hey hava to bc there to be sure it is z
h 181 an on-going commitment in a uritten program.
E I9 CliAIR:!I. ; EECHl:OETER:
I sec.
So you are saying 8
If i
20 the deletion of a commitment somehou docs not delete i
21 the obligation to ce.rry on the activity?
l i
22 UIT11ESS l1.;RGUGLIO :
Or two reasons, I,
23 UIT!;ESS DIRD:
Ilay or may not.
You were questicr..
t ling that one specific question that it was deleted.
24 B
25'g t
UIT:1ESG ll.RGUGLIO :
Any time we havc a require c..
1 ALDERSON REPORTING COMP ANY. INC.
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.l 6988
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f to perform training or a requirement to do anything a.lci 1
t he r e i s a c or..r..i te:.n t 2
under the quality assurance program, l
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that is understood.
It is like an unwritten warranty, 4
so to speak.
It's an employed warranty so to speak that e
5 if you have got a requirement, there has got to be a i
5 l
6 follow-up to assess the requirencnt, and uhy single out i
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7 the respcasibility for assessing the effectiveness of
,f8 senething only in the training area?
U Lechtel could have duplicated that responsisility o
9 l
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10 10,000 time.s with 10,000 other prcesdural commitments z
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11 which they have, and I think that was the undcrlying 8
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12 basis for their position.
They were not trying to te.ll l
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14 the training.
They were simply saying tnat if tacy had E
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16 to say that thcy were always concerned with the cffoetive a
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d 17 i ness of 9,999 other requirements that they have got E
k 18 and it stands to reason that they arc.
It is obvious h
i 19 that they are.
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l 25 l ALDERSON REPORTING COMPANY. INC.
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CHAIRMAN BECHiiOEFER:
Well, they weren't here cco 1
2 talk,ing about writing it down, though, were,they?
They 3
were talking about deleting what was already written down.
f 4
WITNESS MARGUGLIO:
I don't have a response to I
that point other than that was their position'.
a 5
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CHAIRMAN BECHl!OEFER:
Is it also not true that j
(
7 NRC has some special requirements concerning training?
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8 WITNESS MARGUGLIO:
The requirements concerning i
o0 9
training are very general.
They a re, if I recall cor-E rectly, with regard to design and construction phasc.,
G 10 v.
k11 they are along the lines that training shall be accom-t l
12 plished to the extent necessary to assure that the
- 3 individuals are capabic of performing the jobs, along 13 5
l l
14 those lines.
That's not anywhere near an exact quote, l
E 15 but that's the kind of statement that we are dcaling 5
16 with.
g e
(17 Again, with the exception of non-destructive h
18 examination personnel, for which the training is very h
19 specific.
20 CHAIRMAN BECllHOEFFR:
Now, to go back to Ms.
1 21 Stamirls' question, is there any, do you feel that l
22 Bechtel was somohow f alling down in its responsibilities I
23 to have taken the position they did concerning the chango 24 from revision 3 to revision 4 concerning the evaluation 25 :
of the ef fect of t;ho job training?
The same question l
ALDERSON REPORTING COMP ANY. INC.
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~
1 I
6990 1S-2 pj2 l
.I tts. Stamiris asked you about the other one.
2 WITNESS MARGUGLIO:
Okay.
I don't know how i
l i
I 3'
to answer this, but there were four unresolved iter.s and 4
two findings.
As I said, from my cursory and quick e
5 re-reading of this documentation, it looks like the two E
y 6
l findings and three of the resolved items were satis-R 7
factory closed to Turnbull's satisfaction.
This one, s
with regard to No.
3, was not, and may not be now.
I
[
8 O
d 9
don't know.
I would have to check.
g 10 But I think that it has to bc Icft to super-5 11 visory judgment as to how much training an individus1 l
l because not only is his education and experience y
12
- gets, 7
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E 14 pick up, as Bechtcl has stated, is a factor.
Some per-l E
sons need 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of training to be abic to understand
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15 l
c 16 the same amount of information that others will undcr-g u
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17 stand in ten hours.
The focus is on the testing of the f18 individual, and essentially what Bechtel does is they I
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offer oral tests, they offer written tests, they offer I9 n
20 demonstrations prior to certification and they offer follow-up of the evaluation of the person's on-the-job 2I i
l 22 performance after he has been certified.
23 CllAIRf!AN DEChh0ETER:
Ri g h t.
Well, docon't this second paragraph also refer to the evaluation of 24 I
e 25) the job training program generally rather than on an l
i l
ALDERSON REPORTING COMPANY,INC.
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6991
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'l0-2,pj3 that as something, individual basis or -- I was reading
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somewhat of a more general requirement.
I 2
WITNESS MARGUGLIO:
Yes, it does, but I a.
not 3
understand your point, sir.
4 sure I CHAIRMAN BECHHOEFER:
Well, as a separate 5
=
E all with the position do you disagrec at I
l 6
requirement l
in essentially the second paragraph of R
R 7
Mr. Turnbull took
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8 the October 15 letter?.
n WITNESS MARGUGLIO:
I do not think I cither o
i a
9 On one hand I certain3y agree that g
10 disagree or agree.
least assessment of the x
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effectiveness of the training is necessa,ry.
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fact that E
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13 other hand, I
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14 a periodic assessment of all of our responsibilities, 5
E and that's why we have audits, E
15 procedures is necessary, 5
that's why we have 16 J
that's why we have over inspections, g
I do not put the weight that w
t' 17 supervisory rev,iews.
n Turnbull did in the reduction of the, you 4
18 cvidently Mr.
19 know -- I do not put the weight that Mr. Turnbull did E
g of the document.
n 20 in the deletion of that aspect 21 CHAIRMAN BECHHOEFER:
The fact that Mr. Turnbull 22 apparently put some weight on that and regarded it of some have affected Mr. Turnbul1's 23 importance, would that I
24 l
later reassignment?
WITNESS MARGUGLIO:
Not at all.
If there was I
25 j l
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it would have been for failure to f
.I going to be any impact, f
certainly wouldn't be for bringing 2
bring up points.
It 3
up points.
Did the relationship thc.t 4
CllAIRMAN BEC11HOEFER:
Turnbull and Bechtel itscif, either 5
developed between Mr.
here or in any other circumstances, have anything to do 0
R I
b 7
with the re. assignment?
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8 WITNESS MARGUGLIO:
No.
No, not that I can E
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think of.
I hesitated just a minute because I haven't g
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10 even thought of it in that sense and this in the first Nothing that time I've even thought of it in that sense.
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CHAIRMAM EUCUHOLTE3:
It has nothing such as I
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well, Mr. Turnbull is,a little rough on our contractors, 3
so let's find somebody cisc7 4
UITMESS lihRGUGLIO :
Mo.
No, not at all.
No.
5 CHAIRMAN BECHUOEFEn:
Miss Stamiris, you can e
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e 6
resume.
I k7 Ms. STA::InIS :
Okay.
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8 BY MS. STAMInIS-0o 9
Q Mr. Marguglio, when you spcah of the difficulty l
2 with having quantifiable and rigid rules of cortification, o
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h 11 you spoke of the difficultics that come into play b caus:
D inspectors coming into these roles have various y
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E I4 shility, which would make it vary for each parsen.
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matter, at least a more direct uay of dealing with it 16 a
instead of the input of what training that
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to receive, to focus on the end result er the output of 19 l
g n
i 20 what knowledge and skills they now posssss?
21 MR. MILLEn:
Excuse me, I am going to have te l
22 I
object.
I realize that Mr. Marguglio in response to a question by !!r. Ecchhoof sr of hou a position of hou 23 l
24 this training matter has cvelved over the years, but I
I 25 really think us are now far renoved from any possible i
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l ALDERSON REPORTING COMPANY. INC.
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. - 3 r,t2 ask that subjsct matter in this prococding cnd I 1
relevant off'now on the grounds cf 2
the linc_of questioning be cut 3
relevancy.
4 MR. PATON:
I agrec, ifr. Chairman.
e 5
MR. MAnsnALL:
I agree.
A l
6 MR. PATON:
I do not see what that is reisvant e
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7 to.
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8 CHAIRMAN btCdHOEFER:
I think tha t onje ction s
d o
9 was sustained.
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10 gy its, s;;,3Ip,Is :
in defending nochtel's positicn regcrdin; i
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- nell, a
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E" this s.t objective criteria that Mr. Turnbull was I
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13 5e
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14 do you believa that it uculd be possibic to put in s:r.s-U one's fils some kind of objective evidsnes that uculd j
15 a
16 shcu the training or the quclificaticas that they :cd as g
e informative then d
17 a result of training that vould be mere 1
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scntence the certificate which is mentioned in the last M
18 E
in the opinion of the 19 on the October 15th letter, g
certifier based on an unhnewn criteria, the persen is i
20 21 competent?
Same objection, Mr. Chairr..c: 4.
22 HR. MILLEn:
Ue are going into details of heu qualifications are 23 to be establishcd, quite apart from the resolution of 24 25 1 the audit finding reports or anything having to do with
.i ALDERSON REPORTING COMP ANY. INC.
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Do--3 r t 3 G995
.,,,1 quality assurance issues.
2 14 S. STTJ1 IRIS :
I uculd just add that 3
CHT.IR:iAN El:Ci!!!OI;F T.;2 :
Wall, I think at tna very i
4 least that question is not appropriate today, but should 5
bc --
a El 6
Okay, I would agree that should be asked then in relation to tha Item J questions later.
7
- l 8
CI: AIR::A:2 LECI!!!OF.F:n :
Right.
1 a;
9
I juct achd it because he did 0
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10 make that ' statement and I wanted him to justify one way o
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11 or the other ths statement that he already mada, tnat
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12 you, you knew, defending Bechtel's position on that.
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13 CHAIa:.iA:: B CI:lloEFEn:
usil, there may to scme a
g 14 more questions on that aspect.
When the J item co: es up, m
a that is pretty much in detail.
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y 16 21S, STA: IRIS :
Mc11, I guess I do not have vi l[
17 :
any more questions at this tine that relate to the l
'i 18 organi::ational chango.
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20 21 22 23 24 e
ALDERSON REPORTING COMPANY. INC.
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7008
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Does he have any other responsibilitics tnan l
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2 site quality assurancs superintendent or -- ycs, ansucr 3
that question.
4 A
(Witness
!arguglio) 1:o.
y Q
Are there any pl:ns -hat he will have?
5 a
6 A
(Ultness Marguglio)
No.
^c.
b 7
MR. PATON:
Mr. Chairman, I need just one ninute g E
i j
8 to see if uc have any other questiens, otherwise I a r.;
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finished.
.zog 10 (Erief interru;.ticn.)
x 5
1 4
II MR. PATOS:
I just want to ask one last ciutt.ticn I
e
(
12 which can be ansucrsd by either witnoss.
That rcgards
~c 5
- .:r. Bird's rcsponsibility bafore and after January 12, 13 '
m I
"5 I4 l 1932.
I Arc there any changas in !!r. Lird's respensi'si: 1-
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16 ! tics before and after January 12, 1S227 l
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A (Uitness ::crguglio) i: o.
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18 BY MR. PATO;;:
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Q Or the tine that ho spends at the site?
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A (Uitness :targuglic) :lo.
II MR. PATO;; :
That is all I havo, !!r. Chairman, i'
226 JUDGE DECnta:
!!r. :: iller said this racrning tha t 23 the scope of the over inspection cor.:.itncnt turns cut to l
I i bs much greetcr than you criginally anticipated.
l 24 25I A
(Uitness Marguglio)
Yea, sir.
f ALDERSON REPORTING COMPANY,INC.
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JUDGE DECKEn:
I can't r,emember uhy he said y
that.
Was it because --
2 lI MR. MILLER:
I will cxplain why.
I think I l
3' was anticipating -- the reason that Mr. Gardner would not 4
be available. for testimony tomorrou, that uas my only
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5
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6 purpose in making the cou.cnt.
N e
k7 JUDGE DECKEn:
I realiz tlict, but what I an getting at is when you made the commitment to provids 8
the information so that the hearing could deal with thct j
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10 question on the 15th, the week of the 15th, you thougc.:
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11 you could handle it.
The scope turned out to be larger, i
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so now you feel ycu can't handle it in that tima span.
d 12 z
E Will ycu tell me again why?
Phat happenec?
d 13 1
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14 A
(Witness Eird)
It actually has to 4 with f
n When that commitment was made -- and it was' j Ce 2
15 I c. Gardner.
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made in the context thsy would like to see us de sorr.e-
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thing -- ue thought we could casily do it.
He at the h*
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time believed there were four inspectors in question and a
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18 I
19 that, in fact, there werc at the most dozens of insyt:tien E
X records which those four inspectors would have dealt with.
20 So our commitment was to go out to redo --
21 22 Consumers redo at the most those do:cns of inspections.
JUDGE DECKER:
What surprises me is that you 23 24 didn't aircady knou that.
Can you respond as to why ycu i
25 ! didn't know that?
l ALDERSON REPORTING COMP ANY. INC.
_m.:. 2 7010
!1'- 4 r t 3 1_
A (Witness Dird)
Yes, sir, it was purcly e q
i matter of ' -- with the-f our pcopic -- a best g ue s c ti:ac te 2
3 from the timo franc for which they had their incl.netion certification to the other ground rule to the point 'u!.cre 4
there was an open non-conformance on those peopic of hou
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many inspecticns that they would have done.
nl 6
R In fact,.the inspection records for the tu:
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8 comnoditics *.ve are talking about, that is, cabic t c r..i n -
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ation and cahic pulling, are not filed at all agcir.st e
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- 3 10 any way to ecsily retricyc who the inspectors ucre.
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11 And the only uay we knou how nany total inspectienc ther were was to go thrcugh page by pcge 23 fi.le drawers which
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filed by inspsetion -- e>: cuss me, by tabic schcm2 y
13 are
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And it turned out there was over 2,000 rtccrts.
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15 3UDor D:cnra:
That sounds like a shertcomi..,
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i effort to find out just how many inspections were being b.
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W made by people who were uncertified or unadequately
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19 certified or something.
20 Do you plan any sort of change?
21 A
(Witncss Marguglio) It's not vicued as a short-I It's viowed as poor judgment on the 22 coming in the system.
the information as to j
23 part of techtel when they gave us 24 j
heu many inspectione night bo involved.
But filitig the 25 j inspection repcrts by cable schematic nunbar, escentia*ly 1
6 1.
ALDERSON REPORTING COMPANY. INC.
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i by the iten of harduare uffected, is I think tha prSpur I
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can't anover'uhy bochtel estir.ated 2
thing to do.
I I
there to have baen so fou inspections and so few 3
4 inspectors involved.
All I can say is --
5 8
6 JUDGE DECnt3:
The shortcor.ing I ara talhing fy about is that apparently neither nochtel or Concuners i
i realizc0 hou nony inspectors and inspections had Latn 1
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dor.c Ly peopic uith qucationable qualificationt.
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ALDERSON REPORTING COMPANY. INC.
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(Witncss Bird)
I would.like to respond by f
i q'6&liti-1 that we made was to lay to rect 2
saying the commitment 3
finally the fact that those individuals were, in fact, g..
And the only reason i
really qualified to do their job.
i 4
whi'ch was in the initial population 5
why those four people, 1
there was just one point in their i
l 6
as identified -- that I
had caught career whore an outside agency, mainly MPOAD, 7
So --
them up in tome inspection incffoctiveness.
I 8
81 9
JUDGE DECKER:
All right.
Are you, Mr.
.% re; u ej l i :.
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now fully satisfied that MPOAD has a good handic or the l3 10 i'
number of inspectors and incpoetions they make?
l
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W A
(Witness Marguglio)
Yes.
g 12 f
JUDGE DECKER:
How do you know that?
What 13 g
f14 gives you that assurance?
15 A
(Witness Marguglio)
We are reviewing 100 per-cent of the.incpcetion records to ascertain the total l
g' 16 population of inspection records applicabic to the ninc t'
17 18 inspectors in question.
Now, we don't have as a result 5
of this new information that a 100 percent re-inspoetion 19 20 of determinations and of the tables that woro pulled in i'
that the population --
21 appropriato in view of the fact l
You are changing the subjcet on 22 JUDGE DECKER:
i i
23 m'o.
24 A
(Witnoss Marguglio) oh, I am sorry.
25 JUDGE DECKER:
I said are you now fully
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ALDERSON REPORTING COMPANY INC.
l
701J I
D.1-5,pj2 1
satisfied that you and NPOAD have on odcquato way of l
l 2
dctormis.ing whether or not how many i.in;poetions a re being made by poopic of questionabic qualification and 3
4 training, and you said, "Yes" and I asked you how you a
5 know.
Don't got off on the 100 -- the inspection or h
3 6
whether that's necessary.
7 Now, what you have told me is the only way
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j 8
you can find out is to go through a jillian odd records, m
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the way it's going to be in l
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23 file drawers.
Is that 6
or are you going to have a better technique
{
[3 10 the futuro, for deterrt.ining which inspectors are questionably quali-11 C
y 12 ficd and how many inspections they mado?
5 13 MR. MILLER:
Judge Dockor, I am a littic bit I
5 two E
14 confused because I think the question -- there are t
b And I do_n't are the inspoctors quallfled.__
h, 15 '
issues:
- one, the witnesses would respond if you asked then E
10 knou what h
I7 if those electric.al quality control inspectors are now~
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qualified.
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Then the second part of the question seems to I9 g
l me to go to how did the conpany deal with inspoetions l
20 21 that woro performed in the pact by individuals whose e
And that is what Icd qualifications were questionabic.
l 22 23 to this review of the 23 filo drawers or whatever the 24 I
number was.
25 But I'm trying to -
.I want to be helpful.
ALDCRSON REPORTING COMP ANY. INC.
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t 7014 11-5, pj 3 1
JUDGC DECXCRt Thank you.
My problem, if I f,
2 can finally state it, la that both Bochtel and Consuncro 3
seem to have boon surprised at how many inspections were 4
mado by questionab1v qualified poopic.
Bochtel gevo you g5 apparently a vast undorostimato of the job that was there.
$6 They apparently didn't have any way of determining -- of 7
having a good handle on this.
And apparently you didn't
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That grabs me as r,omothing -- a condition that f.
9 10 is not too healthy.
What I am driving at is thoro somo-II thing that has happened since to help both you and Bochte
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stay on top of this question.
l E
I3 l
(Witness Marguglio)
Let me try to ancuor that 4
g A
h I4 and then I am going to lot Walt answer it alco.
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15 understand the setting:
We are at an interview with the
=
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I7 como to a point at which it's recommended that g
we re-innpoet some of the cable terminations and some of the i
18 h
t' not some, but all that II g
cabic pullings that woro not 20 were mado by theco inspectors.
21 And there is a Bechtoi person in the room, and 22 he offers an estimate of how much work is involved.
23 '
Based on that estimate, someone also in the room says, j
24 "okay, the company or the !!POAD will make that over-l f
inspection."
That kind of spur of the moment type of 25 1
ALDERSON RCPORTING COMPANY. INC.
~~-
7015 l
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commitment I am discouraging.
2 I wasn't in the room at the time.
If I were, I would have discouraged it.
But it was made.
And it 3 l 4
was made in good faith, I am somewhat surprised 5
I agree with you that a
X 6
also that the individual in question, Ron Bechtel, volun-3 have a basis R
information when he really didn't I
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teered,that U.
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l reasonable judgment obviously as it
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But nevertheless, it was made.
All we are 0
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trying to do, Judge Decker, is follow-up on that cos.it-l
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.7UDGE DECKrn: I know that is whet you arc l
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2 trying to do.
You just said you ucre soncwhat suri.riscd i
3l that this Bechtel man offered this estimate becausc ha
~
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4 had no basis for it.
That's the heart of my quastic:.ing.
f I
5 Why isn't there some basis for it other than having to g
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go through 23 feet of file cchincts to find out just 9
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7 how much inspection is being don by questionably trci:.cd
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8 inspectors?
G There are ecscntially two c
9 WIT::Ess ::7.aGUGLIO :
i y
10 cptions.
One can file the inspection racords by --
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5 II in relation to th2 c q uipi.:e n t er itcm3 to which the reccres
=
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file the inspecticr. racords in rc12tien y
12 apply or one can the inspectic:.s.
c 13 the inspsetion personnel who made 5
to f
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Industry practice, as far as I knou, has bacn tc file m
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15 the inspection reccrds in relation to il 16 and items to which they apply.
I think it is univsrsal.
a e
I have never heard of it done in our industry any other
- h. I7 }
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18 way.
~s a condition arises in which the 19 Nov, when 8n of a given inspector are questioned beccuse 20 inspections 21 of the potential for that inspector to have been unqual-ified, under that scheme there is no -- of filing th:
22 23 records, t here is no chcice but to look at all cf the and that's wnat wc records for the givcn period of-time, are doing.
But I don't consider that to be an inaucquacy, 25 ih i
ALDERSON REPORTING COMPANY. INC.
7017
-.2*-IrtG J
I would considcr filing the rccords in terms of the 1
l individuals who performed those inspections as bcing I
2 !
i 3
less effective because at the time that we have functiencl' turnover from the constructor to the company, those 4
turned records for ths items and materials which are bcing 5
e X
l 6
over are being re-reviewed on an itcm-by-item, material-g e
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by-matsrial basis, and uo would,have to have the capability G
3 those inspection records whics 8
to draw from thz files and materials which are l
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9 apply to the components,
- io If we didn't have that capability, r
g 10 ! bcing turned over.
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one of our major control points.
F 11. we uculd loss could I a s ), a questien,
l MR. P.'.T O R :, Judge Decker, Y
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I4 JUDGE DECKEn:
Please do.
1 v.
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O Mr. Marguglio, tne original estimate of rcquircd l
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I think, 135, something like that?
v.
N I7 over inspecticns was, w
b.
18 ;
A (Witness Eird)
The original number given to us e
i F
l and also in answer to your question, 19 ! by Eechtel was 10, g
not en Consumers part n
l
!, there was another misunderstanding 20 l
in that n2xt meeting and later.
but on -Bcchtel's part, 2I that va meant 22 They didn't quite understand by 100 percent 23 everything.
They didn't catch the 100 percent.
They 4
24 thought they wanted five from everybody and the rcasen 25 thers was three on the fourth guy was that th:t'c all the a.
I ALDERSON REPORTING COMPANY. INC.
70)S 112-irt3-i 1
inspections that they thought ha had donc at the ti r.s.
2l MR. PATON:. That is what I was going.to dcvelcp a
l 3I Judge Decker.
I thought I had heard --
j i
4 BY fin. PATON :
I i
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Your understanding is that uechtel didn't l
5 6
really understand that it was to be_100 percent, that
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somehow they get the idca thet'it was a sampling, is that u
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8 ccrrect?
d C
9 A
(Witnes: Lird)
Yss, sir, ie g
10 l
MR. PATOS:
Okay.
E t
II JUDGE DE Ci*.E 2:
Well, if I have und er s tc cd t'.u s U
y 12 whole line of questioning, there is no quantitativ-vay 5
g 13 at this time and no plans to generats ont for cita:r you a
E I4 or Ecchtel to have at least a scai-guar.titativa fccl for m
F e
2 15 the fraction of or total number of inspections that era wa g{
16 going on today by people of questionabla qualificatiens, e
N II is that correct?
Mcll, excuse me.
- 4ay I
=
s 8
ask a question to perhaps clarify this and put it in 19 n
i 20 i
perspective.
3
~2I BY MR. MILLEn:
i i
O Mr. Marguglio or Mr. Bird, to your knowlaugo 22 i
the qualifications of any person perforzaing clietrical 23 are 24 ! quality control insp3ctions at the ::idland site n o.: c p o:4 l
25 :t to uunstion?
I
-5d ALDERSON REPORTING COMP ANY. INC.
t
r-7019
@-lrt4 byus.f A
(Citness bird)
- sot j
A
( itness liarguglio)
Well, I would like to uolify 2
l-t that.
3 I
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okay.
4 t
A (uitness I:arguglio)
Ue are going to have t.o 5
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back into 1.istory. -
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O I an talking about right now.
m E,
I A
(Uitness tiarguglio)
Well, right now it's still E
8 u
N an open point.
In my opinion there is an s.x tr cr.it l y 9
i
- E small chance that there could be sone individual unquali-10 I
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11 find, but based on a rather large amount of data that i::
I have before me, all of th= nine in_s_pectors in questi:c.
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g appear to be tctally qualified for th_s tuo things that E
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we are talkinc about hsrs, ter=inations and cab'.c pull :.7 E
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15 sut since the over inspectica is still ongoing I chesa i
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e 16 to br conservative in my responsa.
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I, ALDERSON REPORTING COMPANY. INC.
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You mean the rcasen for your qualificction was l
i
.2 you wanted to wait for the results of the over inspecticn? l 4
3 A
(Witness Ilarguglio)
I've got a large amount of 4
over insp2ction data in f ro::t o f r:.a, namely over 500 ovar-and in my 5
inspections, ove_r 2,000 have been. completed, e
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g staggeringly in favor of the l
6 I
opinion the statistics are so y
k that I have vcry S
7; qualifications of those individuals e
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little doubt the t any of the:a vill turn out to be unqual--
e 2
Od 9
ified.
i g
10 M2. III LI,E T. :
I apologize, Judge D2ckcr.
o i
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=
5 II JUDGE DECEEn:
Ch, no, I have no further i
d 12 questions.
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13 i CET.12:'J. :; E E C E;i O E F Z n :
I would like tc turn i
t e
Walt Eird just mads' e
E I4 WIC ESS M'.P.GUGLIO:
flay I s,
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15 a point that I think ought to go into the record, if I i
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16 could just restate his point, I
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We are not making thess over inspcetions because,
we think that ajgJf_t_hese individuals were unqualified.
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individual:
I95 If we thought'that,we would have precludad these t*
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n He are raaking 20 from doing any inspections to begin with.
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inspections to demonstrate to the regulatorv II these over
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people that the inspectors are in fact qualified, to w..-~.,.
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l demonstrate to their greater degree of intcrest, 3'
l if you will.
We are happy to have this information bacc use 24 i
i 25 "
it confirms our original, you know, information.
Eut I.
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i ALDERSON REPORTING COMP ANY. INC.
R
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7021 i
'.' i 12 '
1 think that it is important to understand that if we ncd 2
any significant doubt -- and there is always doubt, ycu i
+
3 I know, but any significant doubt, uc would stop thc.t 4
inspector from doing any work.
I am sorry, CHAIRIA U E E C l!!! O E T E R :
I was going to turn to i
5 a
4 Exhibit 21, CPC Exhibit 21, the dologation of authority
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7 which I guess is Enclosurc 3, and then turn to the s1cticn.
R guess vill be illustrated by Section 5.1.2, 8
8 The first onc, I c
9 ! whtre it says that the manager reports to the dircctor y
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10j of envircnmental and quality assurancc.
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11 My question is, is that really accurate or t
whc does the manager report to the director of !!PGAD, y
12 l
,3 y
13 happens to be the same perscn I might add, but I am c
c 5
14 just wondering how that fits, how that works?
7 b
l urTNEss ::AnotCLIO :
I think ycu are correct.
E._.15 e
y 16 He docs report to the dire,ctor of :IPQAD.
V.
p 17 CH AIR:!AN EECEEOEFER:
The reason I asked thct 9:
5 18 is I didn't see any responsibilitics for the director e
5 sau it as a name on the chart.
19 IiPQAD. I just g
20 WITNESS :.!ARGtGLIO :
Only because it's one and n
I i
9 S&OA or E and QA rather.
astigadirector 21 the same 22 CII A i RIIAN E E C!IH O E F E !t :
Well, my question is real'ly two positions or should the chart just 23 are these 24 k reflect one or the other?
In your capacity, did you 25 do.different things in the tuo positions?
)
ALDERSON REPORTING COMPANY. INC.
t
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/-1,pj3-I I
O In response to Judge Decl:er you said that l
1 l
2' regarding the November audit report that you had taken 3
some action in your response to -- I believe it was in 9
l Would you describe what you neant 4
response to a concern.
e 5
by that, if I understood you correctly?
n.
3 6
A (Witness Marguglio)
The November audit report December l to me because that is the 7
didn't pose any concern l
u if I'm correct, Exhibit 23.
8 audi t O
o 9
MR. MILLER:
It is 22, Mr. Marguglio.
The x'
10 audit dates are November 2nd through 6th, but the audit c
x E
e 11 report is dated in December.
l y
?
WITNESS MARGUGLIO:
Okay.
Right, it's 22, g
12 l'
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l 13 Exhibit 22, the audit conducted in early November but I4'I
- reported on in early December didn't pose any concern to 5
i E
E 15 me because it was - _it had favorable results.
l i
5 16 Nevertheless, one of the things that I put down g
W as a personal follow-up item was to assure that the f
17
^
18 Midland Project Quality Assurance Department overviewec P
I9 Bechtel quality control personnel certifications in the g
20 future.
Since that time the Midland Project Quality 2I Assurance Department has overviewed eight such personnel l
22 certifications and we have found, in addition to these 23 audit findings, that the certification process employed 1
. rz e :~ 5 24 ?
by Bechtel is consistent with the requirements.' #C06#
l sJAv.=!C ',
I O
Was that overview of their certification 25j i -
1 ALDERSON REPORTING COMPANY. INC.
I
l
.I.
6954 7-1,pj4 1
process that you spoke of, was it not also raised in the I
2 June and July audit report?
4 3-A (Witness Marguglio)
I do.n't think so.
There 4
were two findings in the earlier audit; One finding had 5
to do with whether or not the on-the-job training which e
En 3
6 is conducted by Bechtel quality control of its personnel Ry 7
should be documented; and although it was not at that time ee i
g 8.
it is now.
I d
f q
9 The other had to do with the responsibility of zo g
10 J the level 2 quality control engineer to review the z
P
=
1 11 inspection report issued by the level 1 quality control a
y 12 engineer, and now such a review by the level 2 person is E
I d
13 '
conducted and the level 2 person signs the inspection i
v.
14 report to indicate he has reviewed it.
5 U
7-2 2 15 x
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24 25-ALDERSON REPORTING COMPANY. INC.
f
^
l
6955
.'2rtl 4
Was the November audit report a follow-up to the O
Iit j
Junc and July audit?
I
~
2 A
(Witness liarguglio)
They were on tne same subject
- ~.
3 t
but I wouldn't call them a follow-up.
It was just another I
4 I
periodic audit of the certification prccess but it was not e
5 g
N a f llow-up.
N 6
e 0
So it was not intended to ever really refer j
7 finality the itccs in any more specifically or close out 8
N O
of the earlier audit report?
d 9
A (Witness I*arguglio) dot to my understanding.
i S
to o
0 Did you believe that the scope of the second t
5 l
5 11 audit report was -- well, how -- do you believe that the V
d 12
~.
E less thorough than the first audit second audit report was E
13 p
i I
A 14 ;
report?
E A
(Witness Marguglio)
Not at all.
15 i
x i
Q Fould you explain?
e 16 u
A (Witness 2:arguglio)
I think within the scope l
M g
17,
the audit was therough.
I don't knou how of the audit, E
18
=
to explain I guess other than to.refar to -- refer you b"
19 8
20 to the second page of Exhibit 2, specifically Paragraph n
which describes what was audited Roman nuneral V,
C, 2) 22 and what the results were.
23,
O Did you say that you were you had more to 24 do with the second audit than you did with the first audit, is that not correct?
25 g ALDERSON REPORTING COMPANY. INC.
6956 7-2rt2 1
1 A
(Witness Marguglio)
I'said that at the time 2
of the first audit represented by Exhibit 23, my responsi-3 bility for the Midland Project Quality Assuranca were i
4 limited, and I previously testified as to what those e
5 limitations were.
E 6
At the time of this audit report, of the issuance E
7 of.the audit report marked Exhibit 22, my responsibilities 8
were broader.
They were full scope responsibilitics 0
o 9
with regard to quality assurance and, ' th e r e f o r t, I viewed Y
10 l this report differently than I did tha earliar report.
i i
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=
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g 11 l Eut I'm personally satisfied with both.
j B
i I
j 12 !q Q
Okay.
Can you tell me hcw you were involved 5
)
y 13 i in this second, in the November audit report, what was c
l x
5 14 ;
the scope of your involvsmant?
b 15 '
A (Witness Marguglio)
I was I
e I
16 l MR. MILLER:
I really believe that question was g'
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b.
17 :
asked and answered by Mr. Marguglio in an answer in x
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18 '
respense to Mr. Decker.
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19 Ms, s;AMInIs:
well __
n 20 CHAIRMAN DECUHOEFER:
I think Judge Dccker 21 did ask the same question.
I 22 MS. STAMIRIS:
Okay.
l 23,
BY MS. STAMIRIS:
i e
l i
24 Q
Then your response, the responses that you gave i
i 25 l to Judge Decker as to your involvement with that, thera
\\
1 ALDERSON REPORTING COMPANY. INC.
. ~..
i_
I
-?rt3-6957 weren't any others, there aren't any others, any more
'I i
2 direct involvement in what you expressed 'Eo Judge Decicr 3
l with this audit report?
4 A
(Witness Harguglio)
I think Mr. Deckcr's g
question was what did I do with this report. Your question 5
N r;
j nay be somewhat different in tzrns of -- I have to admit d
6 E
will withdraw my objection.
7 MR. MILLER:
I A
k 0
A (Witness I:argcglio)
It may be somewhat different.
i 0
asking what was my involvement with this audit.
y 9
She is xoF 10 I
MR. MILLER: Okay.
i e
z
=
1 5
II A
(Witness Marguglio)
My involvament stcrted in B
1 NI a meeting with the NRC inspector, at whien time I dcciusd N
I 5I Ue would have an audit of the Bschtel QC certification
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process.
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15 l
If I recall, the meeting with the iRC inspector i
"y may have been in October.
I am not absolutely sure of 6
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I7 I that date.
But as you can see, in November there was
=
M 18 such an audit.
Eut the audit was at my direction.
P 19 The remainder of my involvement was at t.ac
'j
~
n 20 conclusion of the audit when the audit report was 4
published, as I testified in response to Judge Dechcr's 21 22 i
ouestion.
23 BY lin. STA.MIRIS :
Q In the October, I tnink it was 3rd through l
25 Ir 6th I:nC inspection, 6120, in which this Item J was on, 5
5 6-ALDERSON REPORTING COMPANY. INC.
6958 2r'ta O
I familiar wiAh that inspection report and Itcu J are you I
2 of that inspection report, referring to the audit of l
~
I 1
1 3
Dechtel QC qualifications?
4 (1.'itness Marguglio)
I think I am.
I w i s t.
I A
g had it in front of me, but I thini. I am.
5 n
f 6
CII AIRM AN B E C l;I; O E F E R :
Off the record.
^n 7
(Discussion off the record.)
M 8
8-BY MS. STAMIRIS:
3 n
0 7.
O The statement in that paragraph on Pag 2 4 c
9 i
as Item J that says:
"In response to Inspection 8112 l
oF 10 p
an audit had been performed on the Eschtel QC inspector 11 '
- c qualifications."
And then there is a statement:
"An c
12 z
c audit was performed in June, 1981.
However, the results d
13 Dc E
14 t audit were uncenclusive."
p l
of the 15 l' e
' ' - = '
b Can you explain whether that stateme"'
c I
=
i 4
"The results of the audi: were unconclusive," was a 16 I
i judgment of the NRC or.of the Applicant?
j 6
17 e
e A
(Witness Marguglio)
URC.
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18 7-3
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20 I
21 t
22 23 24 N
25 rl 1
ALDERSON REPORTING COMP ANY. INC.
I
6959 3rtl e
Q And would it be in response to this itcr. that 7
yu remember this October meeting 4/ith NRC that you spoke 2
f which led to the Hovember audit?
i 3
A (Witness Marguglio) Yes, it was.
I believe it 4
was I who made the comnitment.
e 5
X Do you )2 ave morc?
-j 6
Q A
(Witness Marguglio)
Well, the commitment was
^
o 7
8 [ made by either Walt Bird or by me.
We have N
O Do you rencmber what the NRC expressed to you 9
5.
as to uhy they believed that the earlicr audit wcs 10 e
unconclusive?
p j;
B A
(Witness.'!arguglio)
I don't remembar.
d 12
?.
Do y.u, Walt?
13 om A
(Witness Bird)
Yeah, I remember, E
14 w
s!
15 Q
W uld ycu explain?
w A
(Witness Bird)
The unconclusivsness goes back 1
x 16 3
M to being able -- the NRC in complete conscience to be g-j7 w
' able to sign off of the unresolved iten from the.!ay
)
b 18 F
19 inspecticn.
And the concern that was voiced was they 8
wanted a harder look at the specifics of the examination 20 21 Process that Eschtel goes through to certify the 22 inspectors.
Basically we honed in on that in great detail, 23 24 a large enough look that we, Consumers, with confidencc 25 's at the end of the audit supposed we could.
In fact, uc p
I.
ALDERSON REPORTING COMPANY,INC.
6960 l 2 3.r t 2 l
do believe that that
~
1 have been able to say, yes, ue 2:
certification process is in order.
And !r. Gardncr has I
since been back and expressed his satisfaction with that, i
3 4
0 I did not -- I was unable to find any specifics l
to why the certification 5
for the basis of that conclusion as e
X this audit and Process was nou acceptab1c by you in Nl 6
^n 7
! apparently by the NnC.
M l
8 8
I would like to go back to the first audit C1 I
c; 9
report and ask some questions, and I think it will z.c lp e
Y
-I z
I am going as far as some of the specifics o
fgetwhere 10 i.
g 11 that I would like cleared up.
I don't see them heir.g
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y 12 cleared up in the second audit report as you say.
[
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So I am sorry for that introduction.
Eut I will ash M
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14 scms questiens from the first audit report.
On Pagc 2 M
1 i
E 15 well, the secend page of this document of Consumers Exai2it.
?
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23 is an item E under the following unresolved itsms J
16l 1
p 17 '
which were identified.
The first item speaks of the f
l x
5 18 Levei 1 and the Level 2 quality control enginecrs.
e 19 Mr. Bird, would you briefly define the diffsrence s
g n
20 between a Level 1 and a Level 2 quality control engineer?
21 A
(Witness Eird)
Level 1 is a lesser certifica-22 tion; in other words, a person with a Level 1 cert-t 23 ification has very specifically limited responsibilitics 24 as far as his -- what he can do, what he can inspect, the i
25 W amount of -- the actual scope of his job is a let less than i
ALDERSON REPORTING COMPANY. INC.
. ~~
6961
-3rt3' i
I a Level 2.
2 O
Ar~e there also Level 3 quality control enginscrs?
3' MR. MILLER:
Excuse me, I am going to ob cet, 3
4 Judge Bechhoefer.
We arc about I think to plunge inte detailed examination of the early audit report pcrhaps 5
a e
3 the l
6 to conpare its findings with the following one or e
I The whole C
E 7
secon'd audit which was conducted in November.
documcnts, was M
the in.troduction of these 8
8 basis for these, e
N t
d forward and describe o
9.
simply to permit the NRC to come for the Board and the parties how they closed out one cg 10 B
h 11 item en an inspection report that was issued in Cctober.
k well, I have the p'
12 That was the Eoard's ruling of 5
It was Page 5412 on December 1st, y
13 transcript page number.
c 1,
m 5
I4 1931.
inspecticn report was admittsd C
15 Ite= J of that 5
y 16 into evidence.
We are about to go into thc details of W
thcsc audit reports with Mr. Eird and Mr. Marguglio, and g
17 l
u M
18 I don't believe that is really pertinent to anything that e
P 19 is really before the Board.
These audit reports get g
20 introduced -- this is not the first time this has happened-n and then we wind up with hours and hours 21 for one purpose, 22 of examination on the details of the reports.
They really 23 - have nothing to do with the issue that the Board is 24 attempting to resolve.
I 25 MR. PATON:
Mr. Chairman, it cocs s e c r. t h a t.
ALDERSON REPORTING COMPANY. INC.
.. l
6962
-3rt4 relation to Item J.
I did note that I
these have some 2
apparently we have shifted from the change in the QA a
littic But I do have some 3
organization to Item J.
Stamiris on this one.
l 4
bit of sympathy with 24rs.
5 If the staff is going to produce a witness 12. tc r.
g l
6 with respect to Iten J -- and I think maybe that was the "l
l
-- and these i
S she was addressing.before 7
matter that g
K in evidence, which they are as 8
8 audit reports are is i f onc of thess O
C 9
Applicant 's exhibits, maybe thc answs:r z
g 10 witness' was available at the time we take up Item J.
c 5_
II I guess she wants to take up uhatever part of Item J t;.tc2 g
12 witnesses are knculedgcabic about.
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ALDERSON REPORTING COMP ANY. INC.
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e-6 M oJECTs. ENGINEERING Awg gggg 3;UCTioN -
CDn3J oUA1.lTY AsSURAN0g gg p ARTW E NT w' CC'1 NO*NCONFORMANCE REPORT CDEFL:1 un-e Priority: 4 Trend: B-3 Start Up: Indeterminate AI: S782 pe 1 e3
- 3. ps.:t ; 3/vc:
7.
DE ONr"7>CEO FAFT K:
4.
N3:#709C33 PAA7 BAC:
1.
R:3 {*r**J.'. _h;;_1.c.15 v.
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- Midland 1 and 2 NA Cable Installation 5/6/81 9 sIMA, FJMED:
- 10. CAs. Cw;;=N3 4:
- 11. AAZA/:M. C' M:
3 LA, W RIV g.A Service Water Bldg l
NA Bechtel Const/QC N/V Valve Pit
'*N 3 t & 16.3.A
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A. Drawing E-42, Sheet 103, Rev 4, Paragraph 15, states in part:
" Insulated conduit bushings shall be used throughout the LEDavis installation or T&B insuliner sleeve.
.", PQCI E-4.0, ES=ith Activity 2.5A Contrary to the above, cable was pulled through conduit lAA017 mro Cen:
at box 1AJ643 without an insulated bushing being installed.
WRBird GK'.'an dling QC inspector was made aware of the require =ent during the cable JVCook SKI /CAC pull.
(The T&B insuliner sleeve was not used either.)
TCCooke(2).9 CAD Routi (CONTINUED ON ATTACED SEET)
MADietrich JFFirlit WDGreenwell
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GSKeeley A.
Construction shall install insulated bushing and delete the BWMarguglio incorrectly pulled cable.
(1.EDavis)
DBMiller B. QC open PQCIs and reinspect in accordance with designated ref-JARutgers
- $f.58::NJf5AE:':s(Eghq l y;,.
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S:G. AL*2. t*.37.
NA NA 3..
is:x.a cr re: a a:r:a=a.
- 34. 1:. VI?.*
- .M PART C/A 6 K.0 IAS
- 37. MJ '"_ -"~ ' n j.A = ;
$ :::.7733 00*C"t=ep F*FCVA:/M=:
(PART & FKocIss CA CDC. =?
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PROJECTS. ENGINE ERING AND CONSTRUCTioh t@ ii:F" NONCONFORMANCE REPORT ouALITY ASSURANCE.:, a r oc DEPARTW E NT cngany PROCESS CORRECTIVE ACTION
,A= 1_ ce s i
3..
u A3ms,e: CsAx: a misa i
1.
Construction not working in accordance with Drawing E-42, Sheet 103, Paragraph 15, and Drawing E-37.
e 2.
QC not inspecting work in accordance with PQCI E-4.0, Activities 1.3, 2.5, 2.o and 3.1.
- 35. AC7M RCCT CAZtt). U 'UTT.72s! T*:n AEVE LE II CCPT.::::, r! CAs. RIs7CN332 FCA DCCI s CA):
kC. DCCI33 Cs R A W TB:M:
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1.
Cognizant QC personnel to be instructed on the above listed requirenents and document training.
(EScith) 2.
Cognizant construction personnel to be instructed on the above listed require-nents and docunent training.
(1.EDavis) k2. 50C33 CA ?J 2: TAXD IT CR4(3) CIICIC 3 31ccK kl & LA3 CF COT.IOC3is 4).
MISCD CF FK4I53 CA VDlT*.*.AMW:
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S'40. CF CA;. hE170!G32 F08 90CZ33 CA 82.~..TT ;3 CM2 Mob:
65 FPC CA CDKT2nDa.IAJE Fe,;ess h
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Pag 2 3 of 3
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i
_NCR:
M-01-9-1-045 I'
DATE: 5/6/81 FILE: 16.3.4 and 16.3.6 12.
"AS IS" NONCONFOPJENG CONDITION VS "AS PIQUIRED" CONDITION WITH ?275:
(continued) 3.
Cable is to be routed in accordance with Drawing I-37 which is the sane as the cable card.
PQCI E-4.0, Activities 1.3, 2.6 and 3.1.
I Contrary to the above, cable 1AIO62B was routed through 1AJ 643, lAA017, lA1H005, lAA022 and 1ATA019 which is not in accord-ance with the cable card, j
This was part of pull package P5048.
The QC Inspector and Field Engineering were =ade aware of the above noted discrepancy during the cable pull.
It was noted that there was a second cable with the sa=e cable nu=ber, lAIO62B, that was routed in accordance with the cable card.
e
Revised 2/13/81
-=
+ - Frieritv c.. tw ifr--.... tses NOJECs. thCintgarwc Am) CC=s?Kuc?ich -
I AUDli FI ND IN G REPOR CuaLITY ASSURA=CI CEPARTMENT Ca,.a.gur,t,1 I
Trend Code: 31 AI S-629
.. a ra.=:= o sa as am:us r.:.u = ac===.:n urposa.
asso m.
Per 10CFR50 Appendix B Criteria V and VI, activities af fecting M-01-02-1-06 quality shall be prescribed by documented instructions or pro-
"y' { { 'Constructier 3
cedures. These documents are to be reviewed for adequacy and approved for release by authorized personnel.
Januarv 27. 1981 rnx r>axn.
Contrary to the above, conduit installed and accepted by QQ is 18.A.'.6 r.
in 6 s_t being 'reverked without a docunented and ap. proved precedure.
[yg[7 SKT/KJK Deficiency noted.with conduit 1BLB003.
A V
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A procedure to be documented, reviewed for adequacy, and approved by authorized.
personnel.
c:aw=vs ac:= a c.ms Bechtel Field Engineering to issue a documented and approved procedure by (Tebruary 12,1983 un er c.. e,r :==
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