ML20100H528
| ML20100H528 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/06/1984 |
| From: | Cain J LOUISIANA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| W3B84-0818, W3B84-818, NUDOCS 8412100024 | |
| Download: ML20100H528 (90) | |
Text
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- P O W E R & L I G H T ! NEWOFMANS,LOUSUWA m ee-70100 O ("JO4)SEMHi204 ES$EsS$
December 6, 1984 J.M. CAIN Preside'nt W3B84-0818 A4.05 Director of Nuclear Reactor Regulation ATTN:
Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Waterford 3 SES Partial Response to Items from Waterford Review Team
REFERENCES:
- 1) Letter W3384-0817, J.M. Cain to D.G. Eisenhut, dated November 21, 1984
- 2) Letter W3B84-0807, J.M. Cain to D.G. Eisenhut, dated October 31, 1984
- 3) Letter, D.G. Eisenhut to J.M. Cain, dated June 13, 1984
Dear Mr. Eisenhut:
The purpose of this letter is to submit revised responses supplementing Issues I and 10.
These revisions are provided in accordance with references 1 and 2.
To facilitate your review, change bars have been provided in the right hand margins of the revised responses to indicate the portions which have been revised.
The revisions to the responses have been reviewed and verified by LP&L QA in accordance with Procedure QASP 19-13.
The designated subcommittee of the Waterford Safety Review Committee also has reviewed the adequacy of the revised responses for resolving the issues raised. The subcommittee scope of responsibility does not include independent validation of the facts.
We understand that the Task Force has essentially completed its validation of the responses to all the issues, including the revisions being submitted herein. Although we believe such an event is unlikely, the Task Force has committed to notifying me and the NRC chp O
<lc
Mr. Darrell G. Eisenhut.
Page 2 W3B84-0818.
'immediately'should it find.significant deviations in the course of its-validation.' In the event of such notification, LP&L will amend individual' responses as may be necessary.
Sincerely, J.M. Cain
'JMC:DED:pel Attachments cc': -.(See next page) 4
m Mr. Darrell G. Eisenhut, Director Page 3-W3B84-0818 November 21, 1984 cc:.Mr. R.S. Leddick.
Mr. J. Harrison Waterford 3 QA Team Leader
.Mr. D.E. Dobson Region III 700 Roosevelt Rd.
Mr. R.F. Burski Glen Ellyn,'IL 60137 Mr. K.W. Cook Mr. J.E.[Gagliardo Director of Waterford 3 Task Mr. T.F. Gerrets Force Region IV Mr. A.S. Lockhart 611 Ryan Plaza Suite 1000 Arlington, TX 76011 Mr. R.P.-Barkhurst Mr. D. Couchman Mr.' L. Constable NUS Corporation
.USNRC - Waterford 3 910 Clopper Road Caithersburg, MD 20878 Mr. R.D. Martin U.S. Nuclear Regulatory Commission Mr..R.L. Ferguson Region IV UNC Nuclear Industries 611 Ryan Plaza Suite 1000 1200 Jadwin, Suite 425 Arlington, TX 76011 Richland, WA 99352 Mr. D. Crutchfield Mr. L.L. Humphreys U.S. Nuclear Regulatory Commission UNC Nuclear Industries Washington, D.C. 20555 1200 Jadwin, Suite 425 Richland, WA -99352 Mr. G. Knighton, Chief Licensing Branch No. 3 Mr. G. Charnoff Division of Licensing Shaw, Pittman, Potts &
l Washington, D.C.
20555 Trowbridge 1800 M. St. N.W.
Mr. M. Peranich Washington, D.C.
20555 Waterford 3 Investigation and Evaluation Inquiry Report Team Dr. J. Hendrie l
Leader 50 Bellport Lane l.
Bethesda, MD 20114 4340 E.W. Hwy. MS-EWS-358 Bellport, NY 11713 l.
Mr. R. Douglass
(
Mr. D. Thatcher Baltimore Gas & Electric
_ aterford 3 Instrumentation & Control 8013 Ft. Smallwood Road W
Leader.
Baltimore, MD 21226 7920 Norfolk Ave. MS-216 Bethesda, MD 20114 Mr. M.K. Yates, Project Manager l
Ebasco Services, Inc.
Mr. L. Shao Two World Trade Center,'d0th l
Waterford 3 Civil / Structure Team New York, NY 10048 l
Leader i
-5650 Nicholson Ln.
Mr. R. Christesen, President l
Rockville, MD Ebasco Services, Inc.
Two World Trade Center New York, NY 10048 E
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- PROGRAM PLAN ISSUE:
1 DATE:
'12/4/84 TITLE:
Inspection Personnel Issues DESCRIPTION OF ISSUE:
Verify the proper certification of
'te QA/QC personnel or requalify the work performed by these personnel.
LP&L APPROACH TO RESOLUTION:
A verification program has been established to review the professional credentials of 100% of the site QA/QC personnel, including supervisors and managers who performed safety related-functions at Waterford III during its construction. The discussions that follows applies to all contractors except J. A. Jones, Fegles, and CEO (CMT), which are addressed in Issues 10 and 20.
Criteria for certification or qualification of QA/QC personnel will be based on ANSI N45.2.6-1973 and SNT-TC-1A for QC inspection personnel and contractor QA program requirements for QA personnel.
Priority has been placed on dispositioning of potential deficiencies for contractors required to support safety evaluations on systems required for fuel load.
In addition, background investigations will be performed for personnel in all groups. If certification of an individual can not be verified appropriate site nonconformance documentation will be initiated to document evaluation of safety
~
significance and corrective actions, including reinspections of work performed as necessary.
For Ebasco, LP&L and other site construction related QA/QC personnel remaining on site, a reverification of proper qualification is being accomplished in accordance with ANSI-N45.2.6-1973.
LP&L operations Quality Control personnel will be reverified in accordance with ANSI N-45.2.6-1978 as committed to in FSAR section 17.2.
Quality Control functions currently being undertaken as part of the inspections in progress are being performed by personnel reverified as qualified under ANSI-N45.2.6-1973.
WORK INSTRUCTIONS AND PRCCEDURES EMPLOYED:
COMPANY PROCEDURE NUMBER TITLE Ebasco QAI No. 32 Instructions for Verifications of QA/QC Personnel Qualifications LP&L QASP 19.12 Review of Contractor QA/QC Personnel Qualification Verification QASP 19.13' Response Validation 1-1 i^
ORGANIZATIONS INVOLVED:
ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS Ebasco 1.
Verification Education / Experience 1.
Training Requirements to QAI-32.
of QA/QC personnel (except LP&L and Ebasco).
2.
- a. Review program requirements of.
2.
Ebasco's Quality Resources Training Manual-1 (QRTM-1) all contractors, review and delineates the requirements for qualifying records collect data (except LP&L and reviewer. QAI-14, " Training and Qualification Ebasco) and identify inspectors Requirements for Quality Assurance Records Personnel" whose qualifications are not endorses QRTM-1 and requires all. reviewers have verifiable against ANSI training on procedures they are reviewing to.
For-N45.2.6-1973, SNT-TC-1A and QA qualification / certification files, training Program requirements for QA requirements are QAI-32 and ANSI N45.2.6.
personnel,
- b. Determine, to the extent feasible, inspections performed by personnel whose qualifications are not verifiable.
- c. Disposition quality documentation generated by LP&L in item 5 below.
LP&L 1.
Audit Ebasco's implementation of
.l.
- a. Indoctrination / training to LP&L and Ebasco QAI-32, procedures, ANSI N45.2.6-1973 and 1978 ANSI N45.2.23-78, SNT-TC-1A-75, and interpretations.
- b. Orientation as to task objective, organizations, and associated responsibilities and duties.
- c. 0.lT for three days co assure knowledge, understanding, and proficiency demonstration.
1-2 i
m c3
i ORGANIZATIONS INVOLVED: CONT'D
]
ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS-LP&L (Continued)
- d. Individuals selected have inspection related experience and/or were invalved in the training / certification or review of inspection personnel,
- e. Personnel involved in this process have not worked for Ebasco or any of the contractors under review.
- 2. Review all LP&L and Ebasco-as well
- 2. Same as item (1).
as those verified by Ebasco.
- 3. Sample Education / Experience
- 3. Same as items (1).
verification of contractors performed by Ebasco.
- 4. Perform final maner'-ent
- 4. Review Board-Three senior LP&L QA personnel qualified to determination of Gw qualifications ANSI N45.2.23 (1978).
of individuals who are potentially unqualified.
- 5. Initiate suitable quality
- 5. LP&L lead auditor who is qualified to ANSI N45.2.23 documentation in cases where (1978).
inspections were performed by personnel where qualification could not be verified.
- 6. Make final determination on
- 6. LP&L QA and Project Management dispositioning of quality documentation mentioned in 4. above by Ebasco.
- 7. Validate response per QASP 19.13 to
- 7. Validation will be performed-under the direct assure positive statements of fact
' supervision of the LP&L lead auditor who is qualified to are substantiated..
ANSI N45.2.23 (1978).
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ATTACHMENT 1 FLOW CHART-INSPECTOR QUALIFICATION REVIEW Initial LP&L Review Additional Background LP&L Review Board Group Determinations Investigations Determinations Final Results Qualified Qualified J k i
m Administrative F Qualified
Background
Deficiency Only E
. Verification i
d (Qualified)
File Merger 6
wr Not Inspector Files Qualified Reviewed From 4
Qualified t
Ebasco & LP&L 1 r Potentially Qualified Not m
I Qualified Not Qualified IP Indeterminate 4
Not CAR (Considered Not y Qualified p
Written &
4 Qualified) 3 Dispositioned Not
_4 Qualified 1-5 i
o CD
PROCRAM PLAN ISSUE:
10 DATE:
12/4/84 TITLE:
In:pector Qualification (J.A. Jones and Fegles)
DESCRIPTION OF ISSUE:
Varify the proper certification of QA/QC personnel and evaluate the impact of any deficiencies found.
LP&L APPROACH TO RESOLUTION:
A varification program has been established to review the professional credentials of 100% of the site QA/QC personnel for J.A. Jones and Fegles, including supervisors and managers who performed safety related functions at Waterford III' during its construction. Criteria for certification or qualification of QA/QC personnel will be based on ANSI N45.2.6-1973 and SNT-TC-1A for QC inspection personnel and construction QA-program requirements for QA personnel.
In addition, background investigations have been performed for all QA/QC personnel.
If qualification on an individual' cannot be verified, appropriate site nonconformance documentation will be initiated to document evaluation of safety significance and corrective actions, including reinspection of work performed as necessary.
WORK INSTRUCTIONS AND PROCEDURES EMPLOYED:
COMPANY PROCEDURE NUMBER TITLE Ebasco QAI No. 32 Instructions for Verifications of QA/QC Personnel Qualifications.
LP&L QASP 19.12 Review of Contractor QA/QC Personnel Qualification Verification.
QASP 19.13 Response Validation 10-1
ORGANIZATIONS INVOLVED:
ORGANIZATION-FUNCTIONS PERFORMED PERSONNEL OUALIFICATION/TRAININC REQUIREMENTS Ebaco (1) Verify Education / Experience of (1)' Training Requirements to QAI-32.
QA/QC personnel, t
j (2) a.
Review program requirements of (2)
Ebasco's Quality Resources Training Manual-1 (QRTM-1) l J.A. Jones and Fegles, and delineates the requirements for qualifying records 1
identify inspectors whose reviewer. QAI-14. " Training and Qualification qualifications are not Requirements.for Quality Assurance Records Personnel" verifiable against ANSI endorses QRTM-1 and requires all reviewers have j
N45.2.6-1973, SNT-TC-1A and QA training on procedures they are reviewing to.
For-program requirements for QA qualification / certification files training 7
personnel, requirements are QAI-32 and ANSI N45.2.6.
)
b.
Determine, to the extent j
feasible, inspections j
performed by personnel whose qualifications are not l
veriffable.
s j
c.
Disposition Quality
{
Documentation generated by-LP&L in item (5) below, LP&L (1) Audit Ebasco's implementation on (1) (a)
Indoctrination / training to LP&L and Ebasco i
j QAI-32.
procedures, ANSI N45.2.6-1973 and 1978, ANSI N45.2.23-78, SNT-TC-1A-75 and interpretations, i
j (b) Orientation as to task objectives, organizations, i
and associated responsibilities and duties.
)
(c) OJT for three days to assure knowledge, understanding, and proficiency demonstration.
l I
(d)
Individuals selected have inspection rela'ted j
and/or were involved in the training / certification or review.
1 10-2 A
'M i
.ORCANIZATIONS INVOLVED:
(Continued)
ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS (1) (e)
Personnel. involved in this process have not workedL for Ebasco, J.A. Jones, or Fegles.
(2) Review all those verified by (2) See Item 1 above.
Ebasco.
(3) Sample Education / Experience (3) See Item I above.
verification of J.A. Jones and Fegles performed by Ebasco.
(4)
Per' form final management (4)
Review Board - Three Senior LP&L QA personnel determination of the qualified to ANSI N45.2.23 (1978).
qualifications of individuals who are potentially unqualified..
(5)
Initiate suitable quality ~
(5) LP&L lead auditor who is qualified to' ANSI N45.2.23 documentation in cases where (1978).
Inspections were performed by personnel where qualifications could not be verified.
(6) Make final determination on (6) LP&L QA and Project Management..
dispositioning of quality documentation mentioned in.(4) above by Ebasco.
(7) Validate response per QASP 19.13 (7) Validation will be. performed under the direct to assure positive statements of supervision of the.LP&L' lead auditor who is. qualified fact are substantiated.
to ANSI N45.2.23 (1978).
ATTACHMENTS:
1.
Flow Chart - Inspector Qualification Review 10-3 a
~
t '
ATTACHMENT 1 FLOW CHART-INSPECTOR QUALIFICATION REVIEW Initial LP&L Review Additional Background LP&L Review Board Group Determinations Investigations Determinations Final Results
' Qualified Qualified i k 4
I Administrative
' Y ualified
Background
Q
. Deficiency Only I
I Verification i
(Qualified)
File Merger I
tr Not Inspector Files Qualified I
Reviewed From 4
Qualified Ebasco & LP&L I
wr Potentially Qualified Not Not Qualified D
I Qualified IP Indeterminate I
Not CAR
'(Considered Not Qualified Written &
d Qualified)
N I
Dispositioned Not
) Qualified 10-4 e *
RESPONSE
ITEM NO:
1 (Revision 1)
TITLE:
Inspection Personnel Issues NRC DZSCRIPTION OF CONCERN:
As a part of the NRC staff's review, the credentials of quality assurance and
. quality control inspectors were examined.
Included in this effort were the verification of previous job experience and qualifications and certification of personnel as inspectors.
The following items were found.
(1) NRC reviewed ins'pector certifications for 37 of 100 Mercury QC inspectors, including certifications for all Level III personnel.
Twelve inspector certifications were found questionable due to insufficient education or experience.
(2) The certification records of 38 Tompkins-Beckwith (T-B) QC inspectors were selected at random and reviewed.
Fourteen inspector certifications were found questionable due to insufficient education or experience.
(3) A 30% sample by the staff of inspector certifications of the Mercury QC work force revealed that no verification of past employment was documented.
A sample by the staff of inspector certifications of the Tompkins-Beckwith QC work force produced similar results.
The safety significance of these findings is that unqualified inspectors may have inspected - safety-related systems, thereby rendering verification of the quality of these systems indeterminant. LP&L shall: (1) verify the professional credentials of. 100% of the site QA/QC personnel, including supervisors and managers, (2) reinspect the work performed by inspectors found unqualified, and (3) verify the proper cercification of the remaining site QA/QC personnel to ANSI N45.2.6-1973.
DISCUSSION:
A verification program was implemented to review the professional credentials of 100% of the site QA/QC personnel who may have performed safety-related functions at Waterford 3, concentrating on inspection personnel and including supervisors, managers and remaining QA/QC personnel.
This verification program included the QA/QC personnel of all site organizations which performed safety related functions.
Personnel from the following organizations will be addressed in this response:
(1) LP&L (9) Gulf Engineering (2) Ebasco (10) Mercury Company of Norwood (3) American Bridge (11) Nisco 3
(4) B&B Insulation (12) Nooter (5) Chicago Bridge & Iron (13) Sline (6) Combustion Engineering (14) Tompkins-Beckwith (7) Fischbach and Moore (15) Waldinger (8) GEO (NDE) 1-1
The responses ' to ' Issues No. 10 and 20 discuss inspector qualifications for
'Fegles, GEO (CMT) and J.A. Jones'QA/QC personnel.
~.The progra'm, which is. being performed -under the overall direction of ' LP&L, consists of three. major elements:
o.
' Collection and verification of personnel data.
o-Evaluation of qualifications against specified standards.
o Dispositioning of deficiencies resulting from cases where inspections and tests were conducted by personnel whose qualifications against the appropriate standards could not be confirmed.
Collection and Verification of Personnel' Data Most of the contractors which performed safety related work on Waterford 3 have demobilized.
Personnel data was collected from various sources, including site files, contractor home office files, personal contact with individuals or
~
supervisors and through a back round verification program.
t Personnel. data for LP&L QA/QC personnel was compiled under the supervision of LP&L. Personnel data for Ebasco QA/QC personnel and that of the QA/QC personnel
- of other site contractors was compiled under the supervision of Ebasco.
- Efforts were made to verify the education and work experience of 100% of the site QA/QC personnel by researching Waterford 3 contractor records and by contacting schools, former employers and others.
The background verification effort for site subcontractor personnel was a joint LP&L/Ebasco effort.~
LP&L.
' performed the verification of the backgrounds of its own employees and of Ebasco employees.
Ebasco personnel were ' used to some extent in this effort 'under.
overall LP&L control. LP&L also audited and sampled the background verification performed by Ebasco. While the success rate of this effort was good, there were cases where confirmatory information was not obtainable.
In such cases, the judgement of the LP&L Review Board, as described below, was used to rule on the reliability of the available information.
Evaluation of Qualifications to Specified Standards QA/QC personnel data were evaluated in order to classify individuals as either having verified qualifications or not.
Training, education and work experience were the qualifications of primary concern.
These qualifications were verified against the following criteria:
(1)
Inspectors - ANSI N45.2.6-1973 (2) NDE Personnel - ANST SNT-TC-1A 1968 or 1975, as appropriate.
(3) Other QA/QC Personnel - QA Program requirements 3
(4) Operational QC Personnel - Regulatory Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) 1-2
' Initial qualification determinations - for Ebasco. and LP&L : QA/QC personnel were performed by an LP&L review. group.
Initial qualification determinations for QA/QC personnel of other contractors ' were performed first by Ebasco and then separately.by the LP&L review group.
In ' order to control the consistency of these determinations, approved procedures were utilized. Determinations related primarily to balancing education, experience and training factors.
The LP&L review. group' qualification determinations-were rendered in two categories:
" qualified" and "potentially not qualified".
"Potentially not qualified". determinations were referred to an LP&L Review. Board comprised. of senior LP&L QA personnel.
The Review Board was ' supported by contractor personnel and a consultant very familiar with - inspector qualification and related standards. This process resulted in a final determination for all QA/QC personnel as either " qualified" or " unqualified".
In addition to the redundant reviews indicated above. LP&L has specifically requested the NUS/UNC Pre-Licensing Issues Task Force to verify the qualifications to applicable standards of all LP&L QA/QC personnel and to sample Ebasco QA/QC personnel.
The' qualification review process is described in QASP 19.12 and QAI-32.
The following points further clarify the process:
1.
The meaning of the term " unqualified" must be amplified.
In some
-cases determinations were made
- that, based on verified
- data, individuals' backgrounds did not warrant qualification to ANSI N45.2.6-1973.
In other cases, however, individuals were considered
" unqualified" as an expedient in rearaing resolution to the concern.
'This occurred in cases in which:
a.'
Research of records, inquiries to past employers, contact with schools and verification of training received was either not possible or could not be concluded in a reasonable period of time.
b.
Apparent discrepancies existed between' background information provided by some individuals and that obtained in.the verification process, and ' resolution could not be achieved on a timely basis.
Minor discrepancies were excused;
- however, significant discrepancies generally rendered any other-i significant but unverified data as suspect.
l l
2.
In the process
- used, being judged as
" unqualified" to ANSI N45.2.6-1973 did not automatically render the individual's work as invalid.
For example, an individual may not have the education and ll experience qualifications for all inspection work, yet be fully competent through specific training or other means to perform the particular tasks assigned to him, which might have been very simple and repetitive in nature.
Such an individual potentially satisfies l
ANSI requirements, which ultimately require that an individual's qualifications be sufficient to provide reasonable assurance that the individual can competently perform a particular task.
Whether or not
[
the individual meets all the requirements of the appropriate standard, i
the individuals' work can be deemed valid.
I t
i 1-3 L
3.
During I the E construction i period, ' some contractors - made undocumented
- judgements-with. respect to
- the. needL for eye. examinations for inspection personnel.
Such :-judgements; were. based on the level of visual'. acuity or color perception required.. to achieve competent inspections.
Such judgements : vere:.also made.as part of the.
verification - program and disposition process: and will be documented. -
.It,is noted that such judgements are specifically suggested ; in ANSI
-N45.2.6-1978Property "ANSI code" (as page type) with input value "ANSI</br></br>-N45.2.6-1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
This factor was not deemed disqualifying.
-4.
-Some individuals.were classified as inspectors but performed.no-safety-related inspections.
Disposition of Deficiencies For.each contractor which performed safety related work, the LP&L Review Board compiled. a list 'of " unqualified" inspector personnel, and Corrective Action
- Requests ~;(CAR) were-written to formally track and disposition potential-deficiencies.
Disposition required ' research into. inspections performed by individuals, further research into an individual's background, reinspection, a
engineering evaluation, analysis of previous reinspections or proof tests.(NDE,
. hydrostatic _- tests),
statistical analyses or rework in order to assure tacceptability of the plant ' components inspected by the personnel in question.
. Determination of --the method of dispositioning was on a contract-by-contract or individual-by-individual basis. The dispositioning process for many individuals includedi 'further investigation of background and education and/or~ the identification of specific job functions performed.
With this additional
. information, dispositioning in many instances. is on the basis that individuals were, in fact, qualified for the work performed -or performed no safety related iinspections. Such cases are explained on a contract-by-contract basis.-
For most contractors who performed safety related work, the disposition of deficiencies generally has not required a large degree of reinspection.
In :the case of Mercury, substau' tial reinspection was. initiated, particularly the N1 instrumentation tubing installation.
More importantly, as a result - of the
. entire QC inspector Verification Program, no significant rework was required.
4 The qualifications. for LP&L and Ebasco and. any other. inspection personnel involved in the overinspections and reinspections were addressed in the review and resolution of inspector qualifications and functions for those respective companies.. On' that basis,.it can be. stated that, where credit' was taken for overinspections or reinspections by qualified inspection personnel, their qualifications have been verified.
Included in Attachment I are the verification program results for inspectors and-L descriptions. of how deficiencie.s stemming from those found not qualified were resolved.
-Remaining Site QA/QC Personnel The, qualifications of personnel currently performing QA/QC functions on site g
have been included in the verification program.
1-4 4.,
CAUSE:
. ANSI' N45.2.6-1973 allows substitution for education and experience' levels by noting that "...' education _and experience requirements specified for the various
. levels should<not be_ treated at absolute when other factors provide reasonable assurance that a person can competently perform a particular task."
Waterford 3 contractors,.to varying degrees, employed such substitutions in certifying the
. qualifications of their - QA/QC personnel.
However, the verification - program revealed ' that verification of. background data was not adequate or documented, documentation of the justification for - substitution was sometimes not provided or lacked depth, and/or was not always totally in accord with contractor procedures or the ANSI Standards, as currently interpreted.
GENERIC IMPLICATIONS:
This issue has~been treated generically. The scope of the verification program included 100% of the QA/QC personnel of all site contractors who performed safety related work.
With regard to future work, qualification and certification of inspectors (including NDE, personnel) will be administered through strict compliance with LP&L Nuclear Operations Procedures which meet the requirements of Regulatory 4
Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) and SNT-TC-1A-1975, as applicable.
SAFETY SIGNIFICANCE:
The results of the effort employed in responding to this issue further confirm l
the many other methods (including independent (ANI, etc.)
inspection, l_
nondestructive
- testing, prerequisite /preoperations/ integrated
- testing, and l
special analyses) which were employed at Waterford 3 to gain adequate confidence l
-that-the Waterford 3 -systems, structures, and components will perform satisfactorily in service.
l_
CORRECTIVE ACTION PLAN / SCHEDULE:
l Priority attention has been given to - completion and dispositioning of QC
'_(inspector). issues, since actual inspections have a more direct bearing on the
- quality of the constructed plant.
The review of QA (non-inspector) personnel qualifications is over 90% complete and, to date, no significant concerns have been identified. These personnel will be addressed in the final report.
ATTACHMENTS:
Verification Program Results and Disposition of Deficiencies, by Contractor.
REFERENCES:
b 1.
QASP 19.12, Review of Contractor QA/QC Personnel Qualification Verification ll 2.
QAI-32, Instructions for Verification of QA/QC Personnel Qualifications 1-5
.--. - - - - - --- - - - - - -, - - - - - - -- -- -- - ~ ~ ~-~- ~ ~~-
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'9 -
l ATTACHMENT 1
,a
- SITE ORCANIZATIONS WHICH PERFORMED SAFETY RELATED WORK
- INDEX o
(y s
A.
LP&L
- B.
Ebasco C.
'American Bridge D.
B&B Insulation E..
~
.i F.
Combustion Engineering G.
Fischbach and Moore H.
GEO (NDE)
I.
Gulf Engineering J.
Mercury Company of Norwood K. -
Nisco L.
Nooter M.
Sline N.
Tompkins - Beckwith 0.
Waldinger
- Fegles, GEO (CMT) and J.A. Jones are included in Items No. 10 and 20.
E
+N 1-6
=
1
I' ATTACHMENT 1 A.
LP&L 1..
On-Site Dates: April 1975 to present
. 2.
Scope of Work:
'0wner 3.
Scope of Inspection:
a.
Construction Phase - Reinspection of selected -construction activities.
b.
Startup Phase - Inspection of designated startup activities.
c.
Operations Phase - Inspection during:
1)
Maintenance 2)
Modifications 3)
Repair 4)
Material Receiving 5)
Storage Activities 4.
QA Program Requirements:
a.
INSPECTORS 1)
Construction Phase La)
QASP 2.12 "QA Section Qualification and Certification of Inspection Personnel" 2)
Startup Phase a)
ANSI N45.2.6 - 1978(Regulatory Guide 1.58.
Revision 1, September 1980) 3)
Operations Phase a)
ANSI N45.2.6 - 1978(Regulatory Guide 1.58 Revision 1, September 1980) b)
QI-010-001 " Inspector Qualification" b.
AUDITORS 1)
Construction Phase a)
ANSI N45.2.23 - 1978(Used as guide only) b)
QASP 2.3 " Qualification and Certification of Audit Personnel" 2)
Startup Phase a)
ANSI N45.2.23 - 1978(Regulatory Guide 1.146-1980) b)
QASP 2.3 " Qualification and Certification of Audit Personnel" 3)
Operations Phase a)
ANSI N45.2.23 - 1978(Regulatory Guide 1.146-1980) b)
QASP 2.3 " Qualification and Certification of Audit Personnel" A-1
~
ATTACHMENT 1 A.
LP&L (Continued)-
'5.
. Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified four (4). LP&L QC personnel whose !
qualifications were initially-determined as.
not meeting the requirements of ANSI N45.2.6-1973.
All were contract personnel.
- Corrective. Action Requests _ (CAR) EQA84-8 and EQA84-24 were initiated
_to disposition this deficiency.
The work assignments and qualifications of _ these individuals were further evaluated and the deficiencies were dispositioned as follows:
The Verification Program assigned one individual as " Indeterminate"
~
status uecause the activities he was authorized to inspect were not listed on his certification.
Subsequently, it was determined that his responsibilities included Electrical, I&C,.and Receipt Inspections.
.A l
review 'of this individual's education and experience supports his i
competence to perform in these particular areas.
Therefore, the activities performed by this individual in these disciplines are concluded to be satisfactory.
.One individual did _ not meet the ANSI requirements for Level II Electrical.- The LP&L QC' Manager determined that this individual did not perform inspections in'the electrical discipline which required a determination of acceptability. He did, however, perform surveillance inspections to determine procedural compliance with-electrical ~
activities.
Based on his education and experience (which includes ils.
years of college and over 5 years of nuclear plant field work) together with his verified Level II certifications in I&C' and Mechanical, the surveillance-activities performed by him in the electrical. discipline are concluded to be satisfactory.
6 One individual did not meet the ANSI requirement for Level II l
Mechanical. His certification was active for only one month prior to his resignation.
It has been determined that he did not perform r
inspections for the installation or maintenance of plant equipment during this one month period.
In any event, this individual had over 17 years of verified inspection-experience in the mechanical - and electro-mechanical disciplines.
During his tenure his assigned responsibility was to perform ' independent surveillance of Phase I and Phase II Startup activities.
7 One individual did not satisfy the ANSI requirement for Level II I&C.
It was determined that this individual performed no inspections for j
the installation or maintenance of plant equipment while employed by l
LP&L.
In any event, he had over 10 years of related and verified electrical inspection /craf t experience prior to his employment.
His assignments at Waterford 3 were to perform independent surveillance of Phase I and Phase II Startup activities.
On these bases, there is sufficient assurance that the work inspected by the identified individuals was satisfactorily performed.
c A-2 5
ATTACHMENT 1 B.
EBASCO 1.
.On-Site Dates:. April'1972 to present.
2.
~ Scope of Work:
a.'
l Architect / Engineer b.
Construction Management c.-
Installation and Construction 3.
Scope of Inspection:
a.
Receiving Inspection b.
Surveillance of Contractor activities c.
Inspection of Ebasco installation and construction (all disciplines) d.
Independent QC inspection of construction activities through 1977.
4.
QA Program Requirements / Contractual Commitments:
a.
QAE Personnel Basic Site Orientation or QA and Safety Orientation b.
Quality Management / Supervisors - Basic Site Orientation or QA and Safety Orientation.
c.
QA Auditors - Ebasco Procedure QA G.3, " Qualification of QA Audit Personnel". Qualification requirements are based on education, nuclear experienes, related Engineering, or manufacturing experience and professional credentials.
d.
QA Records Reviewers - Ebasco Procedure QAI-14, " Training 'and Qualification Requirements for Quality Assurance Records Personnel".
Qualification requirements are-high school graduate or G.E.D., QA Indoctrination, procedural training, and on-the-job training.
e.
Nondestructive Testing Personnel - SNT-TC-1A and Ebasco Procedure NDE-1, "Ebasco Service Incorporated Procedure for Training,-
Examination, and Certification of Nondestructive Examination Personnel".
f.
QC Personnel - ANSI N45.2.6, 1973 and Ebasco Procedure ASP-I-3,
" Indoctrination and Training".
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified sixty (60) Ebasco QC inspectors who performed safety related inspections and whose qualifications were initially determined as' not meeting the requirements of ANSI-N45.2.6-1973 or SNT-TC-1A, as appropriate. Corrective Action Requests (CAR) EQA84-13, EQA84-28, and EQA84-32 were initiated to track the g
disposition of this deficiency.
B-1
ATTACHMENT 1 B.
EBASCO (Continued)
Because of the number of identified individuals and the importance of the functions performed, extensive effort was ~ expended during - the dispositioning of these CARS.
A principal characteristic of this extensive effort is mentioned on page 1-4 of the basic response and is.
? quoted here for emphasis.
."The dispositioning process for many individuals included further
-investigation of background and education and/or the p
identification - on specific job functions performed.
With this additional information, dispositioning in many instances was on the basis that individuals were,.in fact, qualified for the work
-performed, or performed no safety related inspections."
l Following this' effort which included a detailed review of the extent, j
type, timeframe, and discipline involved in the inspections performed (if any) by each of the individuals, the CARS were dispositioned on an (
individual-by-individual basis.
For simplicity of explanation, the i
dispositions are summarized by category as explained below, a.
Five ~ (5) of the identified individuals did, in f act meet the ANSI requirements.
l b.
Six (6) of~the identified individuals served in a Level III capacity as supervisors or managers-and performed no hands-on or j-sign-off of inspections or, to. the degree they did do so, such inspections were Level II functions, for which they were l
qualified.
Further, it was determined that these individuals did
{
not certify any QC inspection personnel nor did they have sole i
responsibility for review and approval of QC procedures.
c.
Fifteen (15) of the identified individuals were found not to have i
performed QC functions while employed by Ebasco at Waterford 3.
l d.
One (1) of the identified individuals had been certified Level II l
prior to attaining sufficient experience.
However, a review of his inspection records indicate that he did not perform Level II type inspections until suitable proficiency was attained and he was thereafter determined to be qualified to the standard.
E The above results in a balance of thirtv-three (33) individuals who actually conducted inspections while not found to be qualified to ANSI- '
N45.2.6-1973 standards.
The work inspected by these individuals was dispositioned also on an individual-by-individual basis as follows:
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ATTACHMENT'1 B.'EBASCO (Continued)-
e.-
For seven (7) : identified-individuals who performed quality control receiving inspections,- the education, and experience required i to substantiate.their level of csrtification was not I
'able to be verified.
One (1) of these individuals was also determined to be not certifiable. as a Level I Civil Inspector.
The records : for the Civil Inspections that he performed were
- reviewed and it 'was determined that these inspections - were not
' safety related. ' These seven.(7) individuals were dispositioned as follows:
- 1) _
One (1) L individual was -later determined to be qualified to the requirements of ANSI N45.2.6-1973 based on additional j
information that was obtained regarding his experience.
2)
One (1) ' individual.was certified as Level II but was' verified _ to be qualified only as Level I.
However. - his inspection documentation was. reviewed and accepted by a qualified QC Lead Inspector (Level II or III).
3)
Five (5) individuals were certified as Level I but were determined. to, be - not certifiable to that Level.
Their inspection documentation was also reviewed and accepted _by a J
qualified QC Lead Inspector (Level II or III).
This Lead Inspector was able. to provide - close supervision over these individuals. since his office was.in the immediate vicinity of the materials receiving area.
In any event, in view of 1the overall inspection process,
- materials receipe inspection is considered an interin inspection between- -manufacturing inspection-and final installation inspection.
At Waterford 3 it is primarily intended to verify -
that
- there are no overages or shortages ' in.the shipment, that damage has not occurred to the material or equipment, and that material-traceability is maintained.
Acceptability of.the material / equipment during manufacturing is assured ' by Ebasco's-vendor QA representative and/or the vendor's 'QA program.
,I Acceptability of the installed -equipment -is assured by the 1
installer's QA program.
- Further, Fischbach & Moore, Gulf Engineering, Mercury, NISCO and Tompkins-Beckwith maintained' f
separate receipt inspection programs which served as an additional check on the condition of the material / equipment prior y[
to acceptance from Ebasco storage for installation.
l.
- f.
Two (2) of the identified individuals primarily performed-overinspection of contractor's work.
The quality of the work overinspected by these individuals has been determined to be acceptable without using the overinspections which they performed.
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ATTACHMENT 1 B.
EBASCO (Continued) g.
One '(1) - of the identified : individuals performed a limited number of electrical inspections.
A review-of the inspection-
' documentation revealed that the items which were inspected by him, were all terminations of cables associated with space heaters which were subsequently determinated under CIWA 009388.
h.-
One (1) of the identified individuals performed a limited number
. of weld-inspections.
A review of the inspection documentation
' revealed that 15 of the welds which he inspected were subsequently Ultrasonically Tested.
The remaining accessible safety related. welds which he. inspected were reinspected under LP&L Procedure QASP 19.10.
These welds were found to be acceptable with no rework required.
1.
One (1)- of the identified individuals only signed weld rod
- requisitions with the exception of one HVAC duct installation inspection.
For this single HVAC inspection, his work was reviewed and signed by a qualified inspector.
j.
Nine-(9) of the identifisd individuals were. determined to have been qualified for the-inspection activities actually performed on the basis of the limited type of inspections performed and the training received on those specific activities.
k.
Seven (7) of the identified individuals were found to have i
performed HVAC inspections. The collective significance of 'that concentration on the HVAC systems triggered a
sampling reinspection program which was instituted under LP&L precedure QASP 19.19.
The results of the reinspections 'were evaluated by.
Engineering and were found to be satisfactory.
1.
Four (4) of the identified individuals were found unqualified in the civil area and performed inspections at. the concrete test station.
Inspections or tests at that station were in addition to those conducted ~ independently by GEO-CMT and which were i
resolved in the response to Issue 20. The engineering evaluatica concluded that the concrete testing was acceptable.
On that basis and the simplicity of the tests and inspections involved there is reasonable assurance that the safety aspects of the related construction has not been compromised.
One (1) of the identified individuals was initially determined to m.
not meet the requirements of ANSI N45.2.6-1973 as a Level II Electrical inspector due to insufficient experience and training.
The individual was, however, properly certified as a Level II Electrical Material Control inspector and accumulated approximately 3 years of nuclear inspection experience prior to his original departure from the Waterford project.
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E ATTACHMENT 1 B.
EBASCO -(Continued)
. He - returned 9 months later, at which time ' he was given a proficiency evaluation and found qualified by Ebasco and certified as a Level II Electrical inspector. After 3 months his performanc.e as a Level II Ele'ct'rical inspec' tor was evaluated and found satisfactory.
His annual evaluation was ! accomplished 8 months later and his competency as an electrical inspector was
. rated as " satisfactory" to " excellent."
Ebasco's qualification program was revised shcrtly thereafter and he was given oral and. written Level II Electrical examinations for which he scored 100% and 90% respectively. One year later he was given a written Level III Electrical eramination and scored 90%.
Based on the individual's nuclear inspection experience in the j
electrical discipline, his proficiency-evaluations which demonstrated his ir.provement over time, and successful completion of testing in the Level II and III electrical disciplines, it is-concluded that the individual has demonstrated the required level of. competence to function as an electrical inspector.
On these bases, there is sufficient assurance that the work inspected 4
by the identified individuals was satisfactorily performed.
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ATTACHMENT 1 C.
AMERICAN BRIDGE-1.
On-Site Dates: March 1977 to May 1980 2.
Scope of Work:
Erection of main and miscellaneous structural steel in the following areas; reactor building, reactor auxiliary building, fuel handling-building, cooling tower area, turbine generator area, circulating water system and construction trestle.-
3.
Scope of Inspection:
a.
Receiving inspection (upon receipt from Ebasco warehouse).
-b.
Fit-up,. in-process, and final visual inspection of welds on structural steel.
c.
Inspection of high strength bolting, including torque inspection.
d.
Inspection of installation of expansion type concrete anchors.
e.
Calibration of inspection and testing equipment.
f.
Housekeeping inspection.
- 4.
QA Program Requirements / Contractual Conunitments:
a.
QA Personnel except Auditors - ANSI N45.2.6 and Procedure 14
" Personnel Training and Qualification".
b.
QA Auditors - ANSI N45.2.23, Quality Assurance Manual Section 1.18 and Procedure 8. " Audit Procedure".
c.
QC Inspectors - ANSI N45.2.6 and Procedure 14, " Personnel Training and Qualification".
5.
Inspector Qualification and Dispositioning of Deficiencies:
(
The Verification Program determined that American Bridge QC inspectors met the requirements of ANSI N45.2.6-1973.
E 8
o l
C-1
_.. _ _. - _ _ _ _. - - _ _ _ _ _ _, _,. _. ~ _. - _.. - _ _, _ _. _ _ _ _..
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i ATTACIDGNT 1 l
I D.
B&B INSULATION 1.
On-Site Dates: April 1982 to Present 2.
, Scope of Work:
Installation of penetration,-radiation shields, fire stops, and s.
air seals.
t b.'
Installation of ventilation equipment providing ventilation for curing penetration seal materials.
c.
Installation of flexible boot seals.
d.
Seal internal conduit seals.
e.
Drill holes in flange of HVAC penetration for sealing material.
f.
Installation of protective envelop-for cable tray,-conduit, cable-airdrop and junction boxes.
3.
Scope of Inspection:
I' 1
a.
Material Receiving Inspection b.
Inspection performed on Electrical Cable Tray and Conduits are as fallows:
1.
Penetration Seals Inspection 2.
Cable Tray Wrap Inspection 3.
Fire Protection Inspection
- 4..
QA Prosras Requirements / Contractual Commitments:
a.
QA Personnel - No procedural requirements for qualification.
b.
QC Inspectors -- B&B Procedure QCP-0010, " Certification of Inspection and Examination Personnel", which meets the intent of l.
l 5.
- Inspector Qualification and Dispositionina of Deficiencies:
The Verification Program identified twenty-five (25) B&B QC inspectors whose qualifications were determined as not meeting the requirements 3
Corrective Action Request (CAR) EQA84-09 ~ was initiated to track the disposition of this deficiency.
A quality assurance program meeting the requirements of 10CFR50, Appendix B and ' ANSI N45.2.6 is not required for the work performed by B&B.
B&B work is not considered a safety related activity.
- However, i
the nuclear insurers require that an independent verification of the installation of conduit 1 seals, penetration seals, and fire barrier j
wraps be performed.
The B&B Quality Assurance Program was established, and approved by'the insurers, to fulfill this requirement and B&B provided appropriate training and supervision.
5 a
J 1
D-1 f-
ATTACHMENT 1 D.
B & B INSULATION (Continued)
- Waterford _3 was one of the first nuclear power plants to extensively
-utilise newly. developed technology associated with the installation
_ of. conduit seals, penetration seals, and fire ' barrier wraps.. As developer of this new technology for Waterford 3, B&B is probably one of the most cognizant and experienced sources of knowledge concerning installation and inspection / inspector. requirements.
To fulfill _ the requirement for qualified personnel, B&B instituted an extensive on-site program (QCP-0022 - Training of' Quality Personnel) to impart its knowledge and experience to its QC Inspecto*s.
t As part - of the approved B&B Quality Assurance _ Program, Procedure
_. QCP-0010 '(Certification of Inspection, Examination, and Testing Personnel)' was generated to " describe the guidelines and methods for the certifications of personnel performing quality related functions".
Per paragraph 2.0 of QCP-0010, "this procedure was developed utilizing the intent of ANSI N45.2.6, but does not imply full compliance with its requirements".
B&B inspectica personnel met the requirements of the B&B QA program.
In addition to the B&B QA and Training Programs, there are additional considerations that add to the credibility of the B&B QC Inspection Program and quality of the work performed.
These considerations include:
1.
The structure and language of the B&B installation and Quality Control Procedures.
B&B Procedures are clearly structured so -
that the hold points and acceptance criteria are well defined and require a minimum of field interpretation.
2.
Ebasco Quality Assurance Audits.
The Ebasco Quality Assurance Department has performed audits of the B&B installation and Quality Control Program.
3.
The use of craf tsmen familiar with the senerci mechacies of the installation. Although the application of this technology to the nuclear industry. is a recent development, it draws, wherever possible, upon existing commercial practices.
An experienced labor pool did not exist for Quality Control Personnel. However,
'B&B was able ' to utilize and train craftsmen experienced with similar commercial installations.
For example, the seal pumpers that B&B utilized were supplied from Local Union #75B.
This single local supplies pumpers to other nuclear projects, as well' as to commercial high-rise building projects, which apply similar sealing compounds.
C D-2
ATTACHMENT 1 D.
B & B INSULATION (Continued) 4.
B&B Quality Control Inspection - Reports.
B&B Quality Control personnel generated inspection reports covering deficiencies in material and field -installation of conduit seals, penetration seals, and Appendix R. wrap.
The quantity and content of the
. inspection reports demonstrates B&B's capability to identify, document, and resolve such deficiencies.
Further confidence in the quality of B&B work is provided by-the following independent inspections or verifications of the work, which were performed by personnel who were qualified for the stated activities:
- 1. -
The implementation of Ebasco Procedure ASP-IV-140 (Inspection of Seals and Barriers).
This procedure resulted in a 100% visual verification of conduit seals,. penetration seals, and Appendix R Fire Barriers as the work was accomplished. Performance of this verification by Ebasco was totally independent of the B&B Quality Control Program.
2.
Third party verification on behalf of the nuclear insurance carriers.
To fulfill the requirements of the nuclear insurance carriers, a final visual verification of each of the conduit seals, penetration seals, and Appendix R fire barriers was performed.
This program was performed by Ebasco personnel and was totally - independent of the ASP-IV-140 verification program and the B&B Quality Control Program.
The primary B&B QC inspection function which would not have been verified by 1 and 2 above was density testing of the sealing compounds.
As performed by B&B this check was reduced to the simple determination of a sample weight.
No calculations of any kind were required.
In addition this check was performed prior to installation of these sealing compounds.
The above factors provide a high level of confidence in the quality of B&B work and related inspections.
4 l
h D-3 4
1 1
ATTACHMENT l' 1
l E.
1.
On-Site Dates: June 1976 to April 1978
-l 2.
Scope of Work:
a.
Erect Steel Containment-Vessel complete ' with all appurtenances, equipment hatches, personnel locks and penetrations.
b.
Post-weld heat treat Steel Containment Vessel.
c.
Test Steel Containment Vessel.
-d.
Purchase Order includes applicable NDE.
L e.
Purchase Order, also covers design, fabrication, delivery, and handling of Steel Containment Vessel.
3..
Scope of Inspection:
a.
Receiving inspection.
b.
Visual inspection of welds, which includes fit-up, in-process, and final weld, c.
Perform and evaluate NDE of welds (MT or LP and RT, as applicable).
d.-
Dimensional inspection.
e.
Witness and evaluate site testing within CB&I work scope.
f.
Assure calibration of jobsite M&TE is performed within CB&I work scope.
3 Test of Steel Containment Vessel includes Soap Bubble Tests.
Overhead Pressure Test, Leak. Plate Tests (including personnel locks) and operational testing.
4.
QA Program Requirements / Contractual Commitments:
a.
QA Personnel - CBI Procedure'TIP-1, " Training-Indoctrination and Qualification Program". This procedure references CBI's QA manual Appendix'C for auditors and Appendix J for NDE personnel.
NDE personnel-are certified to SNT-TC-1A requirements.
b.
QC Personnel - CBI Procedure TIP-1, " Training Indoctrination and
. Qualification Program".
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program determined that - Chicago Bridge & Iron QC inspectors met the requirements of ANSI N45.2.6-1973.
C E-1
ATTACHMENT 1 F.. COMBUSTION ENGINEERING 1.
On-Site Dates: March 1982 to January _1984 2.
Scope of Work:
a.
Provide Reactor Vessel Internals installation assistance, b.
. Perform related work.
c.
Related work includes providing installation procedures, technical direction, services and drawings, and QA personnel.
.t 3.
' Scope of Inspection:
a.
Limited onsite inspections of specialized NSSS vendor activities.
4.
QA Program Requirements / Contractual Commitments:
L a.
All QA/QC Personnel Training to CE QA Program, Standards, Specifications, Codes, QA responsibilities and documentation, b.
QA Auditors - Orientation and training, examination, on-the-j ob training, and maintain proficiency through active participation.
c.
Records Control Personnel QC Software
- training, time requirements are based on level of certification.
d.
Inspector Personnel Visual Inspection to SNT-TC-1A and Dimensional and Mechanical to ANSI N45.2.6.
1Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 5.
Inspector Qualification and Dispositioning of Deficiencies:.
The Verification Program identified six (6) Combustion Engineering QC inspectors whose qualifications were initially determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Request (CAR) EQAS4-06 was initiated to track the disposition of this deficiency.
Based on additional investigation of background, education and/or specific job function, as described in the - basic response, it was determined that the identified individuals were qualified to perform their functions.
One (1) identified individual did not perform QC inspectione at Waterford 3.
He is a certified examiner who administered examinations to CE-Chattanooga QC personnel.
Two (2) of the identified individuals are employees of Electro-Mechanics, Inc. (E-M) and performed QC inspections during a field wiring modification of the Control Element Drive Mechanism Control System at Waterford 3.
These inspections were performed to C
the same performance standards as those in force at the E-M e
i manufacturing facility where this equipment was manufactured.
F-1
ATTACHMENT 1
~
F.
COMBUSTION ENGINEERING (Continued)
One (1)' identified individual's qualiheations to perform as a Visual ~
l (VT)
QC inspector were initially questioned because supporting documentation (VT certification) was not in his personnel ' file.
1 Subsequently..
. Combustion Engineering provided the required certification, which covered the period of time in question.
One (1) identified individual who was certified for NDE Level II (MT, PT, and: RT) was disqualified by the Verification Program because his high school education could =not be verified.
Verification of satisfactory completion of the General Educational Development (GED)
Tests administered by the United States Armed Forces Insititute was later obtained.
One (1) identified individual who was certified as a Level II' (Visual) inspector was disqualified by the Verification Program because no examination records could be established for Level II visual inspection.
Research of Waterford 3 inspection records revealed that he performed no visual inspections at Waterford 3.
He performed only mechanical inspections at Waterford 3, for which he was qualified.
On these bases, there is sufficient assurance that the work inspected by the identified individuals was satisfactorily performed.
?
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C r-2 4
_ _. _ _.. ~, _. -.
ATTACHMENT 1 G.
FISCHBACH AND MOORE
~ 1. -
On-Site Dates: May 1977 to December 1983
~
2.
Scope of Work:
a.
Installed safety and non-safety equipment, accessories, raceways, cable and non-vendor furnished interconnection between equipment, connections to all equipment, accessories and devices.
b..
Installed seismic and non-seismic conduit, tray and box supports (AWS D1.1).
c.
Installed expansion anchors and bolting of structural steel.
3.
Scope of Inspections:
a.
Material Receiving inspection.
b.
Support fit-up and final visual inspection.
c.
Inspection of installation of equipment.
d.
Inspection of routing and connection of trays and conduit.
e.
Inspection of routing and termination of cable.
f.
Inspection for proper bolting'(Torque and tension testing).
3 Magger/ continuity testing of cable and equipment.
4.
QA Program Requirements / Contractual Commitments:
a.
QA Personnel - 10CFR50 Appendix B and ANSI N45.2.
b.
QA Auditors Personnel Documented experience of previous auditing, orientation, and training in QA program, procedures, and activities to be audited.
ANSI N45.2.6 and Fischbach & Moore c.
Inspector Personnel Procedure QAP-101W3, " Personnel Qualification and Certification".
5.
Inspector Qualification and Dispositioning of Deficiencies:
1 The Verification Program identified twenty-seven (27)
F&M QC l
i inspectors whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Requests (CAR)
EQA84-10 and EQA84-29 were initiated to track the disposition of this l
deficiency.
The F&M inspector qualification deficiencies were i
primarily unverifiable inspection experience and unverifiable high school education.
(
Disposition of_the CARS was based on the F&M Training and QA Programs, which qualified personnel for ' specific tasks and monitored their performance.
In addition, during the Startup Test Program, LP&L conducted independent tests of F&M on installed electrical equipment.
l
- Also, during construction 'LP&L and Ebasco performed several C
L reinspections of F&M work.
For example, LP&L performed a complete l
reinspection with regard to electrical circuit separation for safety l
related cables.
LP&L and Ebasco personnel performing those reinspections were verified as being qualified to perform the safety activities.
I c-t I
l
., _,.. _. _., _ _ ~. _ -..
ATTACHMENT 1 C.
FISCHBACH & MOORE (Continued)
Field QC Supervisors were responsible - for activities within their assigned areas and had final approval of all inspection results.
F&M inspection reports
. are reviewed, approved and countersigned by w
Qualified Field QC Supervisors.
Functions and Monitoring of the 27 Personnel's Activities A review of F&M QC files was conducted to determine whether the monitoring program described above was applied to the 27 identified individuals.
It was determined that 26 of the 27 such individuals were Level I inspectors, only 4 of which were designated as " leads" for discretely identified tasks such as coordinating inspection schedules, obtaining scaffolding or otherwise assisting Level II lead inspectors for whom they performed these tasks.
Any actual inspections performed by the 26 individuals were performed under a Level II " lead" or field QC supervisor, the latter of which reviewed, approved and countersigned the inspection reports.
The one remaining individual was on site for 6 months, 3 months of which were as a Level II, was never designated as a " lead" or field QC supervisor and thus his work was monitored by a " lead" and reviewed, approved and countersigned by the appropriate QC supervisor.
Thus the program, as outlined above, and which provided tierad monitoring and review of base level inspector activities, was f<
. owed and provides sufficient assurance of the adequacy of both thc e inspections and the hardware involved.
LP&L/Ebasco Testing and Inspection In addition to the P&M/QC inspections, the quality of the F&M construction activities is ft;rther confirmed by the following. testing and inspection activities by LP&L and Ebasco.
a.
Ebasco performed receipt QC inspections of permanent material to be installed by F&M prior to issuance to F&M.
The receipt inspection performed by F&M was thus a redundant site inspection performed to verify that the material received was the correct type and was not damaged.
b.
As a part of the LP&L Startup testing program, walkdowns of electrical installations were performed by LP&L Startup, c.
Ebasco and LP&L performed a walkdown to inspect conduit span lengths. NCR-7168 required Ebasco to reinspect supports, d.
The LP&L Startup program required that terminations of cables be checked.
0 e.
LP&L Startup inspected for proper bolting torque on electrical busses and cable terminations.
In addition to this, Ebasco QC under NCRs 7169, 7164 and 7186 verified the proper torque of over 1000 anchor bolts installed by F&M.
G-2
ATTACHMENT 1 G.
FISCHBACH AND MOORE (Continued) f.
LP&L Startup also performed insulation resistance / continuity testing of cable and equipment.
In addition to the above, LP&L Startup Phase I and II test programs required
- "ta.tional electrical testing and system testing of electricaJ squipment which have been performed.
On the basis of the above, sufficient assurance is provided that the hardware installed by Fischbach and Moore will adequately perform its intended functions.
3 I
i i
i s
O G-3
ATTACHMENT 1 l
H.
GEO (NDE) i
'l i
1.
On-Site Dates: May 1977 to Present 2.
Scope of Work:
a.
Performance of Nondestructive examination of items and welds.
'b.
Process and evaluate test results.
c._
Prepare' reports.
d.
Identify defects.
3..
Scope of Inspection:
a.
Nondestructive examination methods include but are not limited to: Radiography, Magnetic Particle, Ultrasonic, Liquid Penetrant, and Leak Detection.
b.
Client has final acceptance or rejection of welds.
c.
Although leak detection was included in GEO scope of work, GEO was not required to perform any tests.
4.
QA Program Requirements / Contractual Commitments:
a.
QA Personnel except Auditors - No Procedural rsquirements for qualification.
b.
QA Auditors - GEO Procedure 5.2, " Qualification and Certification of Audit Personnel" which references ANSI N45.2.23.
c.
Nondestructive Examination Personnel SNT-TC-1A and GEO Procedure CEO-2.3,
" Qualification and Certification of NDE Personnel".
5.
-Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified five (5) GEO (NDE) personnel whose qualifications were initially determined as not meeting the requirements of SNT-TC-1A for radiographic testing.
In addition, one of the five was determined as not meeting the requirements of SNT-TC-1A for magnetic particle testing and penetrant testing.
This determination was based on being unable to verify their high ' school attendance or sufficient training.
Corrective Action Request (CAR)
EQA84-18 was initiated to track the disposition of this deficiency.
Based on additional investigation regarding education and/or experience, as described in the basic response, it was determined that four (4) of the identified individuals did meet the requirements of ASNT SNT-TC-1A.
D 9
H-1
ATTACHMENT 1 H.
GEO (NDE)
A review was conducted in order to determine the inspection functions performed by the remaining identified individual. This individual was only involved in field radiography work and the interpretation and acceptance of his radiography results were carried out by qualified Ebasco personnel.
In addition, certain radiographs were reviewed by the ANI.
Improper field technique would have been detected during the interpretation of the radiographs.
On these bases, there is sufficient assurance that the work performed 4
by the identified individuals was satisfactorily performed.
I 4
e 0
o H-2 i
- - - _ _, _ _ _, _ _ _ _. ~., _., _ _ _ _ _ _ _ _ _ _ _ _. _. -. _... _ _. _ _ _ _ _ _ _ _ _ _ _,. _, _ - _ _ _
ATTACIDENT 1 I.
GULF ENGINEARING 1.
On-Site Dates: January 1977 to November 1983 2.
Scope of Work:-
a.
Install ASME III Safety Class I, II, III, and Non-safety related (331.1) equipment tank,' pressure vessels, etc.
b.
Install ASME III Class III piping systems.-
c.
Install Seismic Class I supports.
d.
Hydrostatic / Pneumatic testing on all systems erected.
3.
Scope of Inspection:
.a.-
Material Receiving Inspection.
b.
'. Fit-Up and Final Visual for structural welds.
c.
Fit-Up and Final Visual for pipe velds.
d.
Insulation Resistance Testing Inspection - PR-9.2.
e.
Grouting Inspection PR-11.1.
l 4.
QA Proaram Reeutrements/ Contractual Commitments:
a.
QA Personnel with exception of Auditors - Gulf Engineering QA Manual Section 20, Indoctrination and Training, Gulf Procedures PR 17.0 and 20.0, " Indoctrination and Training".
b.
QA Auditors - ANSI N45.2.23 and Gulf Procedure PR 18.0,
" Auditing".
4 c.
QC Inspectors - ANSI N45.2.6 and the Gulf Program requirements listed in (s).
l l
- 5..
Inspector ovalification and Dispositionina of Deficiencies:
The Verification Program identified ten (10) Gulf Engineering QC inspectors whose qualifications were initially determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action-Requests (CAR) EQA84-27, EQA84-30 and EQA84-33 were initiated to track the disposition of this deficiency.
It was determined thats a.
Based on additional investigation regarding education and/or experience, as described in the basic response, it was 4
determined that three (3) of the identified individuals were i
qualified to perform their functions and did meet ANSI N45.2.6-1973.
b.
The review found that two (2) of the identified individuals did not perform safety-related inspections prior to acquiring proper qualifications and certifications.
I-1 l-
ATTACIDENT I I.
GULF ENGINEERING (Continued)
A review was conducted in order to determine the inspection functions performed by the remaining five (5) - individuals and such functions were found to be acceptable on the following bases:
a.
One (1) identified individual who was certified as a Level. I inspector only performed routine preventive maintenance inspections on installed mechanical equipment.
This included checking for damage, heat on motors,' nitrogen blankets, rotation of. pumps and motors, and witnessing meggering of motors.
b.
One (1) identified individual who was certified as a Level II inspector for installation of mechanical and electrical equipment performed inspections limited to setting, leveling.-aligning, and grouting in-place mechanical equipment such as pumps, motors,
-heat exchangers, and tanks.
Gulf did not make the electrical or mechanical connections to the equipment. This individual also performed routine preventive maintenance inspections per. Ibasco Care and Maintenance Instructions (CMI).
c.
Three (3) identified individuals were certified as Level III inspectors for installation of mechanical and electrical-equipment.
The actual scope of their inspections was limited to the same scope as for the Level II individual discussed above.
One of these individuals also inspected a small amount of safety related piping in the dry cooling towers.
That such piping is satisfactory is supported by the fact that the piping has subsequently been nondestructively examined, hydrostatic tested and accepted by the ANI.
Gulf management has, in the case of all of the identified individuals, attested that they received adequate training to perform the inspection functions described, the formal portions of which are documented.
Additionally, Gulf was required by contract (Paragraph MC-1) to submit their work and inspection packages (travelers) to Ebasco and LP&L.
A primary purpose in this requirement was to ensure that both Ebasco and LP&L had the opportunity to review and ensure that the appropriate owner inspection hold points were specified.
Once these were established-LF&L QA was then notified when these hold points had been reached in order to overinspect the more sensitive equipment installation steps.
C c
I-2
ATTAC10GNT 1 I.
GULF ENGINEERING (Continued)
Added confidence in quality of the Gulf construction activities was I
gained during the LP&L Startup program as follows:
1.
During prerequisite testing the motors were a.
messered and/or continuity checked to assure proper wiring b.
electrically checked for proper rotation 2.
During preoperational testing a.
motors were run uncoupled and coupled (i.e. pumps, etc. were operated) b.
often flanges were disconnected which necessitated re-aligning the pumps / motors c.
component functions were tested during system and cold / hot functional test.s On the above bases, there is adequate assurance that the equipment installed by Gulf will perform satisfactorily in service.
a 4
1 D
0 I-3 I
I
ATTACHMENT 1 J. MERCURY CGIPANY OF NORWOOD 1.
On-Site Dates: September 1978 to November 1983 2.
Scope of Work:
a.
Install ASME III P2 and P3 local instrument racks, cabinets, and tubing systems.
b.
Install seismic Class I supports and tubetrack.
c.
Install non-seismic /non-safety instrument air system.
d.
Install non-seismic supports.
e.
Hydrostatic or air test all tubing erected.
3.
Scope of Inspection:
a.
Receiving Inspection b.
Dimensional Inspection c.
Structural Inspections d.
Pressure Test Performance e.
Welding Inspection f.
Piping and Tubing Inspection 3
Installed Equipment Inspection 4.
QA Proaram Requirements / Contractual Commitments:
a.
QA Engineering Personnel - Mercury Procedure QCP-3070, " Personnel Indoctrination and Training".
b.
Quality Managers / Supervisors Mercury Procedure QCP-3070,.
" Personnel Indoctrination and Training".
c.
Quality Assurance Auditors-Mercury Procedure QCP-3060, Qualification of "QA Program Audit Personnel" which satisfies the requirements of ANSI N-45.2.23.
d.
QA Records Reviewers - Mercury procedure QCP-3070, " Personnel Indoctrination and Training".
e.
Nondestructive Testing Personnel Mercury employed no NDE personnel.
f.
QC Personnel ANSI N45.2.6 and Mercury Procedure QCP-3050,
" Qualification of Inspection, Examination and Test Personnel".
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified 136 Mercury QC inspectors whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Request (CAR) EQA84-15 was initiated to track the disposition of this deficiency.
C C
J-1
ATTACBENT l' J. MERCURY COMPANY 0F NORWOOD (Continued)
Disposition of CAR EQA34-15 is based upon the extensive reinspections of Mercury work against established installation criteria and upoa extensive testing and engineering evaluation of the as-built installations.
Based on these factors. LP&L has a high degree of confidence in the ability of the installation within the scope of Mercury's responsibility to perform its intended safety functions and support safe plant operation.
In light of the extensive verification, this conclusion is justified even if a substantial number of Mercury inspectors do not satisfy; qualification requirements.
Attachment No. J-1 provides a matrix - of inspection and NDE tests performed as part of the in-process installation activities in Mercury's work scope. The various reinspection, test and engineering.
verification activities are also tabulated in relation to the impacted Mercury installations.
Attachment No. J-2 is a description of several of the verification activities additionally considered in this assessment.
Attachment No. J-3 is an assessment of safety significance with respect to the findings identified in the N1 installation reinspections recently completed by LP&L.
The figure contained in Attachment J-4 represents Mercury's work scope pictorially for the categories of installations described above.
Mercury's construction activities which are affected by QC inspector qualifications have been categorised as follows:
l A.
N1 Installations l
N1 installation include tubing, instrumentation and related hardware which perform a function required to mitigate the consequences of a design basis accident and allow the operator to 1
safely shutdown the plant.
I-i B.
N2 Installation N2 installations include tubing, instrumentation and related hardware required to maintain pressure boundary integrity that do*
not perform a direct plant safety function.
C.
l;eismic Catemory I Instrumentation Sunoorts. Tube Track, and
- ,astrumentation Stands h
These installations are required to withstand a safe shutdown earthquake and thus assure the integrity of N1 and N2 installations.
1-2
i ATTACBENT 1
. J. MERCURY COMPANY OF NORWOOD (Continued)
D.
Primary Samplina Pipina and Related Supports / Restraints These installations consist of Seismic Category 1 pipe supports and ASMR Class 2 piping.
Verification activities independent of-the initial in-process inspections are discussed in relation to each category of Mercury installation.
A.
N1 Instrumentation Due to its importance to safe plant operations, N1 instrumentation has undergone the most extensive re-verifications of any Mercury installation-category.
These verification activities are summarised as follows:
1.
Reinspections Reinspections performed in relation to N1 instrumentation include the fo11owingr a.
N1 Reinspection Proaram As a result the LP&L Review of NRC Issue No.
I regarding Mercury QC qualifications, LP&L - deemed it prudent to undertake a further extensive reinspection of Mercury - work.
Accordingly, LP&L procedure QASP 19.15 was established to reinspect the sensing -lines and associated hardware (e.g.
tube track, support, etc.)
for the N1 instrument installations, which perform a
safety-related function and provide a
pressure boundary. The reinspection is complete and no discrepancies impacting plant safety were found. This reinspection covered most of the installation attributes which are subject to in-process QC inspections.
Certain attributes.such as anchor bolt torquing and weld fitup inspection were not included since reverification cannot be performed without destroying existing installations.
Such attributes, however, were subjected to many in-process inspections and subsequent documentation reviews as is evidenced by the numerous NCRs which were dispositioned in these areas. The adequacy of Mercury anchor bolt installations was further later verified by Ebasco based on the h
corrective action required to close NCR 5864. This NCR required tension test verification of 108 Mercury installed anchor bolts.
J-3
?
ATTACHMENT 1 f
J. -MERCURY COMPANY OF NORWOOD (Continued)
An evaluation of the reinspection findings 'was performed for safety significance.
The evaluation results and inspection findings are discussed in detail in Attachment J-3.
It has been concluded that, while deviations from established installation criteria were identified, none were judged to be safety significant.-
- Purther, in relation to the quantity of items reinspected, the number of identified discrepancies is small.
j b.
LP&L QA Inspection of Redundant N1 Instrumentation Impulse Lines for Mechanical Separation
[
This reinspection was performed.under direct LP&L supervision in accordance with LP&L Procedure. QASP 19.9.
The inspection required the reverification of l
mechanical separation requirements for redundant N1 instrumentation installations.
As a result. of this program, 2 out of 82 instrument installations inspected t
were reworked to assure proper mechanical separation.
[
c.
SCD 57 Correction Action Proaram This reinspection effort commenced in July,1982, and subsequently involved the reinspection of all N1 and N2 instrumentation installed in full or in part prior to-July 1982.
Although these reinspections may have been 4
i performed by some of the QC inspectors whose F
credentials are currently suspect, this is mitigated by-the fact that Ebasco Engineering participated in the tubing installation walkdowns.
LP&L QA and Startup also participated in many of the walkdowns.
d.
Selective Reinspection Programs Impacting N1 i
Installation Various reinspection programs were initiated by LP&L and Ebasco QA in relation to established review programs in the 1982-1983 time frame.
These reinspections impacted N1 Instrumentation',
and are described as follows:
1)
Ebasco QA Records Review Program Reinspections During the records review process a limited number of reinspections were performed in order to reverify specific attributes related to tubing f,
installations.
Refer to Attachment No. J-2 for more detail.
J-4
m ATTACHMENT 1
' J.
MERCURY COMPANY OF NORWOOD '(Continued)
- 11) LP&L QA Turnover Status Review A limited number of field verifications were conducted by LP&L QA as part of a system turnover
-status review.
These field verifications established' a satisfactory level of confidence that the as-installed conditions were reflective of the approved installation details. Refer to Attachment No. J-2 for more detail.
2.
Testing Various NDE and testing programs have been implemented which provide additional assurance with respect to the adequacy of 1
N1 installations.
These programs are summarized as follows:
a.
Pressure Boundary Tests In general, 'N1 and ASME Class 2
and 3
tubing installations were integrity tested in accordance with code requirements.
Certain N1 HVAC installations were exempted from integrity testing.
In addition to Mercury QC inspectors,.ASME integrity tests were witnessed by Ebasco, LP&L Startup and QC personnel, and in ' the case of Class 2 installation, the Mercury ANI representative.
b.
Non-Destructive Testing N1 ASME Class 2 installations welds were subjected to liquid penetrant tests which were performed by an independent contractor (GEO).
c.
Hot Functional Preoperational Testing During Pre-Core Hot Functional
- Testing, N1 instrumentatien was placed in service under normal plant operating conditions.
The integrity of these installations was verified under thermal growth and pressure conditions by LP&L.
Instrumentation loop functionality under plant startup and normal process flow conditions was also verified.
These same systems will again be tested during Post Core Hot Functional Testing, prior to initial criticality.
g J-5
- - _ -. =--..
j--
ATTACHMENT 1 l
J.
MERCURY COMPANY OF NORWOOD (Continued)
B.
N2 Installations
'f N2 installatior.s were subj ected to many of the same reverification programs. The major LP&L programs which did not s
involve N2 installations are the N1 instrumentation reinspection r
conducted by LP&L (Item A. I.a) and the LP&L QA inspection of redundsat N1 instrumentation for Mechanical Separation (Ites A.I.S).,
Thegnost noteworthy revarification efforts with respect to N2 inatallations isvolve the SCD 57. corrective action programs and pre-core. hot functional testing programs.
The comprehensiveness of these two programs sitigate the consequences resulting from the QC ' inspection qualification conce as.
Attachment No. J-3 discusses the justification for not atending the reinspection program conducted under QASP 19.15 (Ices A. I.a) to include N2 installation.
C.
Seismic Category I - Supports. Tube Track and Instrumentation Stands As has been the case with N1 and N2 installation, Seismic Category I supports, tubetrack and instrumentation stands have been subjected to various reinspections and verification programs. The most notable are discussed below.
J I.
The N1 reinspections conducted by LP&L under procedure QASP 19.15 included reinspections of Seismic Category I supports
/
installed in N1 instrument loops.
Attributes inspected included support location, wekt size and workmanship, anchor
[
bolt embedmont,
- spacing, and ' correctness of hardware installations (i.e.
- nut, bolts,
- washer, etc.).
Approximately 1600 supports were inspected under the program.
2.
The Ebasco QA Records Review Program Reinspection i
The QC reinspection conducted by Ebasco in 1982-1983 involved approximately 35%
of all Mercury installed instrumentation seismic supports.
These reinspections verified support configuration, locations and weld size.
/ Partial inspection for only certain attributes (i.e. support type or weld size, etc.) were also conducted.
In addii: ion 4.
to Seismic Category I supports, the QA Records review
, [jh resulted in the full reinspection of 100% of the Seismic Category I instrument stands installed by Marcury and approximately 67% of the tube e track installation including hardware and welds.
Anchor belt ambedment and torque were reverified in 896 instances. Mote detail with respect to the impact of the Ebasco QA records review on Seismic Category I hardware is provided in Attachment No. J-2.
J-6 a
y
ATTACHMENT 1 J.
MERCURY COMPANY OF NORWOOD (Continued)
D.
Primary Sampling Piping and Related Supports / Restraints This portion of Mercury work has been reverified in several ways.
These are summarized as follows:
1.
Reinspection a.
Piping fillet _ welds were reinspected under SCD 62 which involved identification and repair of undersized fillet welds. not meeting ASME Code requirements.
Although reinspections may have been done by some of the same QC inspectors whose. credentials are currently under question, the impact of their involvement is minimized since at.teast 2 inspectors looked at each weld.
b.
All the Primary Sampling Supports / Restraints were reinspected by Ebasco QC during the QA records review
- process, c.
Both the piping and supports / restraints were verified by Ebasco ESSE as part of the 79-14 program.
d.
Primary Sampling Supports / Restraint were reinspected by LP&L QA as part of the QASP-19.7 pipe hanger inspection program.
2.
Testing a.
ASME Code Hydros of Primary Sampling Piping ASME Code hydros were witnessed by the Mercury ANI, o
LP&L Startup and Ebasco Engineering.
b.-
Non-Destructive Testing Since the primary sample tubing is ASME Class 2. all fillet welds were liquid penetrant tested by GEO.~
c.
Hot Functional Testing (HFT)
During Pre-Core HPT, the Primary Sampling System was i
subjected to normsl operating pressure and temperature conditions.
Formal verification of the adequacy of
(
installation was documented under the thermal l
monitoring program conducted during HFT.
Similar postcore testing will-be performed.
r l_
E t..
t j
J-7 i
7 ATTACHMENT 1 J. MERCURY COMPANY OF NORWOOD (Continued)
The extent of reinspection testing and engineering verifications conducted in relation to the Mercury installed Primary Sampling System is so comprehensive that.the impact of QC inspector qualifications is insignificant with respect to plant safety.
SUMMARY
AND CONCLUSIONS In each installation ' category, several reverification and testing activities. have been performed which did not involve Mercury QC inspectors. When reinspection activities were performed by Mercury QC inspectors,. credit is taken in this assessment due to either of two factors:
1.
The Mercury QC inspector was accompanied by either an LP&L or i
Ebasco representative or both (eg. SCD 57 walkdowns, hydros, etc.)
9 2.
The reinspection was a duplication of previous reinspections, and thus the impact of inspector qualification to ANSI N45.2.6-1973 is minimized.
In conclusion, the extent to which Mercury installations were reverified by either
. testing, reinspection or engineering verification, substantially independent of the Mercury QC inspection
- process, provides sufficient confidence that safety related instrumentation has been properly installed.
l C
J-8
e ATTACNMENT J-I I&C PRIMARY WELD QC INSPECTION ASME CODE INTEC. DOCUMENT REVIEW COMPONENT CLASS QTT. INVOLVED CONFICURATION PFRFORMED INSPECTION NDE TEST MERC.ESASCO LPL OTHER Tubing
.P2NI 51 Travelers 1/8" Socket
- 1. Cleanliness Indep. exam.
Indep. 1001 1001 1001 151
!) SCD $7 4
(Approx.)
- 2. Component Verified by Kemper Exam.
- 2) GASP-19.15
- 3. NT Component No, Insurance By CEO
- 3) QASP-19.9 Verified Record Liq.
- 4. NT & Type Filler Review Penet.
Metal (1001)
(1002)
- 5. Fit-Up Physical
- 6. Final Inspection
- 7. Walder ID (Approx 21)
- 8. Weld No.
- 9. Mechanical Separation
'4 Tubing P2N2 35 Travelers I/8" Socket
- 1. Cleanliness Indep. exam.
Indep. 1002 1001 100I 15I
- 1) SCD 57 (Approx.)
Wald
- 2. Component Verified by Kemper Exam.
- 3. NT Component No.
Insurance By CEO j
Verified Record Liq.
j
- 4. NT & Type Filler Review Penet.
Natal (1002)
(1002)
- 5. Fit-Up Physical
- 6. Final.
Inspection i
- 7. Walder ID (Approx 22)
]
- 8. Weld No.
j Tubing P3NI 189 Travelers 1/8" Socket
- 1. Cleanliness 1001 100I 1001 152
!) QASP-19.15 i
(Approx.)
Wald
- 2. Component Verified With
- 2) QASP-19.9 a,
- 3. NT Component No.
Except
- 3) SCD 57 Verified of
- 4. NT & Type Filler NVAC l
Natal
- 5. Fit-Up 1
- 6. Final
- 7. Walder ID
- 8. Weld No.
- 9. Mechanical Separation J-9 I
Q (M
4 I
4 ATTACHWENT J-l I&C PRIMARY WELD QC INSPECTION ASME CODE INTEC. DOCUMENT REVIEW COMPONENT CLASS QTY. INVOLVED CONFICURATION PERFORMED INSPECTION NDE TEST NESC.ESASCO LPL
'OTHER 4
Tubing P3N2 95 Travelers 1/8" Socket
- 1. Cleanliness 1001 1001 1001 15Z
- 1) SCD 57 (Approx.)
Wald
- 2. Component Verified With
- 3. NT Component No.
Except Verified of
- 4. NT & Type Filler NVAC Metal
- 5. Fit-Up
- 6. Final
- 7. Welder ID
- 8. Weld No.
P2 Sample P2 10 Drawings 1/4" socket I. Cleanliness Indep. Exas. Inder. 1001 1001 100E 15I
!) SCD 62 Pipe Weld
- 2. Component Verified By Keeper Exam
- 2) SCD 57
- 3. NT Component No.
Insurance By CEO Verified Record Liq.
- 4. NT & Type Filler Review Penet.
Metal (100Z)
(2001)
- 5. Fit-Up Physical l
- 6. Final Inspection i
- 7. Walder ID (Approx 22)
- 8. Wald No.
1 Strong Back P3NI 7 Tanka 1/4" Socket
- 1. Cleanliness 100I 1001 1001 151
!) SCD 57 Piping for Weld
- 2. Component Verified
- 2) QASP-19.15 Level
- 3. NT Component No.
- 3) QASP-19.9 Switches Verified
- 4. NT & Type Filler Metal
- 5. Fit-Up
- 6. Final
- 7. Walder ID
- 8. Wald No.
- 9. Mechanical Separation Tubetrack Seismic 650 Fillet 100Z 101 I) 67% Under QAI-23 CL I (Approx.)
- 2) QASP 19.15 (NI Only)
'J-10 i
i e
O "E
Q
--.1 ATTACIMENT J-l I&C PRIMARY WELD QC INSPECTION
- ASME CODE INTEC. DoctMENT REVIEW
- COMPONENT CLASS QTY. INVOLVED CONFICURATION PERFORMED INSPECTION NDE TEST MERC.EBASCO LPL OTHER Tybi:E &
Seismic 5100 Fillet
- 1. Cleanliness 751 100I 10I
!) 351 under Q41-23 Trbetrrck CL I -
.(Approx.)
- 2. Component Verified
- 2) QASP-39/15 (N! Only)
Supports
- 3. West No. Component Verified
- 4. NT & Type Fillet Metal
- 5. Fit-Up
- 6. Walder ID
- 7. Weld No.
- 8. Final
'Bsrgsa-Seismic.
310 Fillet
- 1. Cleanliness.
Not 1001 101 I) Ebasco QC 1001 reinspection Paterson.
CL I (Approx.)
- 2. Component Verified Comp.
- 2) 79-14 Walkdown Supports
- 3. NT No. & Type
- 3) QASP-19.7 Filler Metal
- 4. WWlder ID
- 5. Weld No.
- 6. Fit-Up
- 7. Final Ins t rument seismic 200 Fillet
- 1. Cleentiacas Not 100I 102
- 1) 1001 Under QAI-23 Stss_da CL 1 (Approx.)
- 2. Component Verified
- Comp,
- 2) QASP-19.15 (N1 Only)
- 3. HT Ho. OF Component Verified
- 4. NT & Type Filler.
Metal
- 5. Walder ID
- 6. Wald No.
I
- 7. Fit-Up l
- 8. Final i
J-Il J
t t
1 e
e 9.
ATTACHMENT NO. J-2 VERIFICATION OF THE ACCEPTABILITY OF MERCURY INSTALLATIONS Since the Stop Work Order.on Mercury safety related activities was issued in July 1982, Mercury installed systems have been heavily scrutinized by LP&L and Ebasco.
The~ Mercury installations have-also been subjected to NRC field review. Additionally, Kemper Insurance participated in the ASME Section III N-Stamp application process and, as. such, was required to witness hydrostatic testing of all ASME Safety Class 2 installations.
The following is a brief discussion of some of the significant LP&L and Ebasco verification activities with respect to Mercury installations.
1.
A direct result of the Stop Work Order, was the initiation in July 1982 of joint Mercury and Ebasco walkdowns of instrumentation installations on a startup system basis. LP&L QA and Startup were involved in the initial phases of the program.
Walkdown results were documented on punch lists and evaluated for nonconforming conditions and establishment of corrective action.
The walkdowns were conducted in two phases.
The first phase consisted primarily of tubing along with the associated tubetrack and clamps.
The second phase, which commenced in January 1983, consisted of a walkdown of supports.
The walkdowns resulted in the generation of a large number of NCRs and rework. Attachments t
2, 3 and 3F of the response to NRC Issue 23 discuss de significance of the NCRs.
2.
In addition to LP&L QA participation in the corrective' action walkdowns discussed above, LP&L QA performed a status review at the time of system turnover -in accordance with the requirements of LP&L Procedure QASP 17.5.
This review consisted of a minimum 10% review of'the documentation, and a random field sampling of hardware versus as-built drawings.
Portions of the Mercury installation for the following startup systems were field verified:
18-3, 25-9, 36-1, 36-3, 39, 43A, 43B, 43E, 43H, 43J, 46A, 46B, 46C, 46D,.46E, 46H, 52A-1, 52A-2, 52B, 52C, 53A, 55A,56A, 58, 59, 60A, 60B, 60C, 66, 71B, 73 and 76.
As a result of these reviews, LP&L was able to conclude that the 4
as-built conditions generally reflected the system drawings, and that no significant hardware deficiencies were encountered.
3.
Ebasco conducted various other field verification activities relative to Mercury installations.
These are summarized as follows:
6 C
4 J-12 c..
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ATTACHMENT NO. J-2 VERIFICATION OF THE ACCEPTABILITY OF MERCURY INSTALLATIONS (Continued) a.
As part of the. closure of SCD 57, Ebasco QA initiated a corrective' action supplement which consisted in part of a sample field inspection of various attributes related to Mercury installations.
This inspection took place in February, 1984.
1 b.
Ebasco Engineering conducted a plant walkdown in order to identify and correct miscellaneous hardware deficiencies which normally result from ongoing construction activities.
This walkdown was conducted in accordance with Ebasco Procedure ASP-IV-141 and included all safety related areas of the plant.
Deficiencies, along with QA/C verification of corrective action. on safety related
- items, were documented on punch lists. The. program was established in support of the area closeout and transfer process, which took place in March, 1984 through May, 1984.
This walkdown provided another level of assurance on the Mercury installations.
c.
Since August 1982, the Ebasco QA Surveillance Group has conducted 48 documented surveillances of Mercury hardware and documentation.
Any findings were resolved and, when necessary, NCRs were initiated to evaluate potentially significant discrepancies.
The activities of the Ebasco QA Surveillance Group are discussed in greater detail in to the response to NRC Issue 23.
Generally, this in-process surveillance program provided ' another means of monitoring Mercury activities, thus ensuring the adequacy of the installations.
4.
The most significant activity, aside from the corrective action walkdown discussed in Item 1,
involved the Ebasco QA records review of Mercury documentation.
This review was necessary due to the demobilization of Mercury in August of 1983 without the completion of -the Mercury records review.
The review commenced in November, 1983 and was completed in March, 1984.
A group of 46 QA reviewers, inspectors, supervisors and clerical staff was
~
assembled for this effort.
The review was conducted in i
accordance with QA instruction QAI-23. As deficient or missing documents were identified, QC inspectors were dispatched to reverify the installations.
As a result, approximately 67% of l
tube track installations were reinspected; approximately 35% of Seismic Category 1 supports were reinspected; and approximately 24% of the Mercury installed anchors were reverified for proper torque.- Attachment SA to the response to NRC Issue 23 provides a summary of the review and reinspection scope resulting from the 6
f Ebasco QA records review.
Available records indicate that an insignificant amount of rework resulted from the reinspection process.
J-13
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4 ATTACHMENT No. J-2
SUMMARY
OF THE EBASCO QA RECORDS REVIEW (Continued)
I.
The following is a summary of the work scope related to the Mercury documentation review conducted by Ebasco QA.
Further, a summary of field QC verifications resulting from the review process is provided in Section II.
A.
Tubing Installations Records Review ASME Section ASME Section Review Scope III-Class 2 III-Class 3 Total Number of Systems 13 36 49 Number of Mercury Travelers (OCRs) 86 284 370 Number of Instruments 150 835 985 B.
Seismic Category I Support, Tube Track, and Other Miscellaneous Hardware Installations Review Scope Quantity Tube Track Supports 5142 Primary Sample Line Pipe Supports 314 Tube Track Installations 665 Instrument Stands 184 Bulk Fabricated Supports / Fittings /
Anchor Plates 7230 (Approx.)
Instrument Mounts 267 II.
QA reinspections were initiated in order to resolve documentation deficiencies identified in the review process.
A sunstary of reinspections is as follows:
A.
Tubing Installations Reinspections were initiated to verify the following:
Attribute Quantity Heat Number 30 Material Identification 15 Walder's I.D.
11 Tube Slope 4
Verify Repair of Damaged Tubing 7
Wall Thickness 2
Defective Wald 1
{
Instrument Installation 3
TOTAL 73 (Note 1)
J-14
. ~..
I 1
o ATTACHMENT NO.-J-2
SUMMARY
OF THE EBASCO QA RECORDS REVIEW (Continued)
B.
Supports / Tube Track and other miscellaneous Seismic Category 1 installations.
Reinspections were initiated to verify the following:
Attribute Quantity Support Configuration, Location & Welds 2058 Tube Track 514 Instrument Stands 211 Torque Verification of Anchor Bolts Including Proper Embedment and Thread Engagement 896 Support Type only 159 Final Visual of Support Weld Only 88 Pipe Support Configuration 77 Miscellaneous Attributes (Ht. No.
Walder I.D.,
Etc.)
216 TOTAL 4219 (Note 1)
As a result of these reinspections, a total of 113 NCRs and 1035
' Discrepancy Notices were dispositioned.
NOTE 1:
Some duplication of reinspection or unsuccessful inspection is included in these numbers.
s v
8 a
J-15
ATTACHMENT NO. J-3
SUMMARY
OF MERCURY REINSPECTIONS RESULTING FROM NRC ISSUE NO. 1 As a result of the LP&L review of NRC Issue No.
I regarding Mercury. QC qualifications, LP&L deemed it prudent to undertake a further extensive reinspection of Mercury work.
Accordingly, LP&L procedure QASP19.15 was established to reinspect the sensing lines and associated hardware (e.g. tube track, support,. etc.) for the N1 instrument installations, which perform a safety-related function and. provide a pressure boundary.
The reinspection was performed by qualified inspectors, and no discrepancies.'specting plant safety
.were found.
The discrepancies were sorted into the following nine categories for evaluation:
A ~.
Overspan on tubing B.
Missing hardware (e.g. missing nuts, bolts, lockwashers, tube clamps)
C.
Incorrect tubeclamp type (2D,3D)
D.
Insufficient weld on support E.
Incorrectly assembled hardware, track, support, etc.
F.
Undersized tubing weld G.
Anchor bolt embedment H.
Anchor bolt spacing I.
Arc strike / grind mark on weld Table I summarizes the number of findings in each category.
The purpose of this attachment is to discuss the ramificacions of the identified conditions with respect to plant safety and to discuss the need for further reinspections.
Category A - Overspan on Tubing The most significant overspanned conditions found during the reinspection were analyzed under design loading conditions and determined to be within ASME code allowable stresses. The 15 cases identified as rework items involved minor relocation of clamps and. were reworked rather than submitted. for complete engineering _ evaluation. It was judged, however, that there was no safety significance with the respect to the as found conditions in this category.
Category B - Missing Hardware Missing hardware was further broken down into two categories:
a) Missing lockwashers b) Missing tube clamps, missing nut or bolt for tube clamp assemblies, and tube track support or track splice connections.
Missing lockwashers pose a concern in that the nut is more likely to loosen C
under seismic conditions.
Since the nuts were found to be tiSht in these instances, the bolts should not loosen under short term seismic conditions.
J-16 6
-_a__a,.--
n
ATTACHMENT NO. J-3
SUMMARY
OF MERCURY REINSPECTIONS RESULTING FROM NRC ISSUE NO.1 (Continued)
Induced vibration in..tubetrack/ tubing installations due to plant normal operating conditions is minimal, and should not cause loosening of the connection.
With respect to the missing tube clamp hardware, such cases were treated as an overspan condi. tion for evaluation.
Stress analysis evaluation of the identified discrepancies concluded that the as-found condition would not result in overstressing the tubing under design loading conditions.
Missing tubetrack hardware likewise results in an overspanned condition.
The resultant deflections would not result in failure of the tubing pressure boundary under design Ioading conditions.
In summary, none of the missing hardware items degrade the overall system integrity and thus do not preclude the system from performing its intended safety function.
However, missing hardware items were reworked in accordance with installation requirements.
Category C - Incorrect Tube Clamp (2D & 3D)
The as-found conditions can b'e broken down further as follows:
1.
Two dimensional (2D) clamps used in lieu of a three dimensional (3D) clamp.
2.
Three dimensional clamp used in lieu of a two dimensional clamp.
The'first condition represents no safety significance in that a 3D clamp simply provides axial restraint as well as lateral and vertical restraint.
Axial restraint is also achieved by clamps installed on the tubing as it changes direction.
(That is, tube clamps in a tube run on a perpendicular plane of direction to the run to be restrained will provide restraint to that run),
The condition in which a 3D clamp is used in lieu of a 2D clamp may pose a concern in that axial thermal growth would be restricted. The only case where this condition may pose a problem is when there is a straight run of tubing between two 3D clamps coupled with high maximum operating system temperatures.
Only two such cases were noted out of the 68 total clamp discrepancies.
Approximately 2600 cube clamps were inspected.
The probability that these lines would fail is low, since restricted growth due to ' cyclical. thermal loading of the tube in itself would not cause a pressure boundary failure.
Frequent cyclical thermal loading is not anticipated on
. Waterford since it is LP&L's policy to backfill instrumentation legs rather than
- blowdown the line.
In the unlikely event of a tube failure for the two h
identified instrument loops (had the cases not been corrected), the failure would not have been of safety significance.
i J-17
,n-.,,,,--,,-,.nn.
ATTACHMENT NO. J-3
SUMMARY
OF MERCURY REINSPECTIONS RESULTING FROM NRC ISSUE NO. 1 (Continued)
Category D - Insufficient Weld On Support The two identified conditions. in this category were evaluated and found to be acceptable as installed, under design loading conditions.
Thus, no item of safety significance was identified in this category.
Category E - Incorrectly Assembled Hardware The 49 identified conditions consisted primarily of loose bolts. Many instances involved one loose nut in a four bolt tube track splice assembly.
In such instances one bolt alone would be sufficient.
In instances of loose tube track to support bolts or tube clamp bolts, the loose nut _ and bolt assembly provided some clamping action, ensuring no overspan condition existed that would degrade the overall system integrity under design conditions.
The instances of this condition occurring are isolated throughout all the reinspected installations, which further reduces the impact on individual system integrity.
Category F - Undersize Tubing Welds Twenty-Five undersized welds were identified. Thirteen were acceptable based on a previous analysis (refer to NCR-W3-5850).
The remaining 12 welds were repaired to meet ASME code requirements.
However, in LP&L's judgement, had these undersized conditions gone undetected, the structural integrity of the weld to perform under design loading conditions would not have been compromised.
Also, hydrotests performed on non-atmospheric installations provide further evidence relative to the adequacy of the weld.
Given that only 12 out of the approximately 4800 welds reinspected were found to be undersized, LP&L believes that additional reinspection is not justified.
None of these conditions represent an item of safety significance even though repairs were required based on ASME code requirements.
Category G - Anchor Bolt Embedments Three of the identified conditions in this category were reworked to be consistent with installation criteria required.
These were later analyzed and it was found that rework was not required and none of these conditions posed a concern relative to safety significance.
Category H - Anchor Bolt Spacing Violations j
The as-found conditions in this category were evaluated and determined to be acceptable as-is under design loading conditions.
Therefore, no item of safety significance was noted.
h J-18 I
ATTACHMENT NO. J-3
SUMMARY
OF MERCURY REINSPECTIONS RESULTINC FROM NRC ISSUE NO. 1 (Continued)
Category I -' Arc Strikes & Grind Marks Arc strikes or grind marks were identified on base metal pressure boundaries or at a.. weld.. When buffed and measured, the as-found conditions were determined not to exceed established minimum wall thickness criteria or minimum weld size
- requirements. Thus no condition of safety significance was noted nor were any repairs required.
SUMMARY
AND CONCLUSIONS 1
" Conditions that have been designated for rework were done so generally to meet code requirements and to satisfy specific installation criteria.
Had these conditions been left uncorrected, in LP&L's judgement, they would not have impacted the overall ability of the system to function under design loading conditions. Further, tha limited number of discrepancies found in each category as compared to the total number of items inspected does not justify further
' reinspection of Mercury installations.
This is further substantiated by the fact thac most of the rework performed involved minor hardware discrepancies (i.e. i:stegories B, C and E).
. All Mercury N1 -instrument e.ubing installations were reinspected and no safety significant deficiencies wire found.
N1 instrumentation accounts for a large
~ percentage of the Mercury safety related work and Mercury N2 installation was accomplished using the same personnel, procedures and techniques as were used in N1 installation.
Therefore, it is concluded that reinspection of N2 instrumentation, which is only safety related with respect to its pressure boundary integrity function, is not warranted.
As noted, significant pressure boundary concerns were not identified in the N1 instrumentation reinspection.
Only - 12 out of 4,800 welds were repaired, and these repairs were due to code requirements, and not as ' a result of a degraded pressure boundary integrity condition.
f I -
i l
i 0
O J-19
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-TABLE 1
SUMMARY
BY DISCREPANCY TYPE VIOLATION APPROXIMATE TOTAL DISCREPANCIES TOTAL NUMBER OF ACCEPTED CODE TOTAL ITEMS
-IDENTIFIED
- REWORK ITEMS AS IS INSPECTED **
CITED ACTUAL A
10,500 ft.
55 21 15 6
B 5,500 75 67 67 0
C 2,600 68 68 68 0
D 3,700 15 2
0 2
E 5,500 60 49 49 0
F 4,800 25 12 12 0
G 3,600 40 3
3 0
H 3,600 88 42 0
42 I
10,500 ft.
7 7
0 7
TOTAL 430 274 221 53 QASP19.15 contained basic design criteria that had to be inspected against.
This procedure did not account for previous analysis, unique installation details or certain criteria identified in the installation-details notes section.
The actual number of discrepancies reflect the valid violations from the specified detailed design criteria.
Estimate based on typical installation of 10,500 linear f t. of tubing with accessories.
I 4
J-20
Attechment'J-4 s
_S_C O P E OF MER CUR Y'S WORK i
Significant Reinspections & NCR's 6 '82 '83 Wolkdowns Or Inspections By Others Mercury / Ebosco / LP8L -
4 100 % Of P2 /P3 Syseems
+
Tubing, Tubehack & Supports l
Additional Scope llems B-P Supports By Others= '8y Mercury NI (Sofe Shutdown) Instruments (~235)
-Ebosco OC ~100%
-Strongbacks For Level Or N2 (fiessse Boundary) lastruments (~800) v i.
P2(Chas 2 Pipe & Tubing
-Geo PT 10 0 %
E sco OC-6T%
j R 6159
/
P3 (Class 3) Tubing
]
o o!
lo o N
/
/
/
-LP8L leydros 100%
Tube Clamps Fillings
/
Nih esception of HVAC oj g
l 0
o
-Welded Or
/
i
-Swogelok Seismic Supports 1
l
~
-Ebosco OC ~35%
l j
{
lo}
lr, lol
-NCR's a 5819,6512,6585 a n6 C
- rd g
- rg-j I
I Iol f
Drilled-in Anchors
-Ebosco OC ~ 24 %
Plotes g
/'
-NCR 5864 j
al 5
o o
/
\\
i 4
o ol l0 o lastrument Slonds
-Ebosco OC ~100%
1 1
I
_l
!J-21 l
i
ATTACHMENT 1 K.
NISCO 1.
On-Site Dates: August 1978 to October 1983 2.
-Scope of Work:
a.
Installation of Reactor Coolant Pumps.
b.
Installation and final setting of reactor vessel and (2) steam generators.
c.
Installation of Reactor Vessel. head.
d.
Installation and assembly of fuel handling system.
e.
Fabrication and installation of seismic Class I supports.
f.
Installation of pool seal ring / rolling missile shield.
g.
Perform hydrostatic testing on all systems installed.
h.
Perform insulation resistance testing on electrical equipment.
1.
Assembly and installation of CEDM system magnetic jack assemblies.
3.
Scope of Inspection:
a.
Material Receiving Inspection.
b.
Inspection of fit-up and final welds.
c.
Inspection of Proper Bolting (Torque and Tension).
d.
Installed Equipment Inspection.
e.
Hydrostatic Testing Inspection.
f.
Insulation Resistance. Testing Inspection.
4.
QA Program Requirements / Contractual Commitments:
a.
Quality Personnel (including Auditors, QC Inspectors, and - QA Surveillance Personnel) - Nisco's contract required all personnel to receive indoctrination and technical training.
b.
QA Auditors - Nisco Procedure ES-116-3, " Qualification Certification of Audit Personnel" required completion of self study
- courses, on-the-job
- training, and oral or written examinations.
c.
QC Inspectors /QA Surveillance Personnel - ANSI N45.2.6, Nisco Procedure ES-116-2,
" Qualification and Certification of-Inspection Personnel", and Nisco Procedure ES-117, " Inspection, Testing, and Examination Personnel Training Procedure".
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified five (5) Nisco QC inspectors whose qualifications were initially determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Requests (CAR)
EQA84-4 and EQA84-19 were initiated to track the disposition of this deficiency.
K-1
ATTACHMENT l' K.
NISCO (Continued)
Based ~
additional investigation of background, education, and on specific job functions, it was determined that the identified individuals were qualified to perform their functions.
Subsequent evaluation and background verification effort determined that:
a.
One (1) identified individual's qualifications to ASNT SNT-TCIA as a Level III Examiner was questioned based on the lack of s'upporting documentation in his personnel file. NISCO's scope.of work at Waterford 3 did not include Non-Destructive Examination (NDE).
Therefore, this individual was not required. to function in the capacity of a Level III (NDE) Examiner at Waterford 3.
b.
One (1) identified individual's prior work history could not be adequately verified to permit a firm conclusion. that he was certifiable as a Level II. inspector.
However, his inspections were generally part of the installation process which received multiple inspections or was followed by satisfactory PT or RT inspections by an independent subcontractor or overinspections by a qualified inspector.
On that basis, his inspection activities are deemed' satisfactory.
c.
One (1) identified individual could not be qualified for his Level II Mechanical and Receiving Inspection qualifications prior to July 1980, but performed no Level II Mechanical inspections e
i prior to that date and records reviewed indicated he did not per. form receiving inspections while at Waterford 3.
Based on experience through June 1980, and the fact that he successfully passed (90%) a mechanical inspection proficiency evaluation, this individual was deemed qualified to perform Level II inspections
[
after that date.
l'
[
d.
One (1) identified individual was certified as a Level II l
inspector on February 2, 1980 and performed in this capacity for about three months until May 7, 1980.
As a result of LP&L Audit 80-25 (May 2-23, 1980), a Stop Work Order was issued contending that he was not qualified to be certified as a Level II inspector.
NISCO promptly reclassified him as a Level I and reviewed the weld inspections performed by him during the period in question. They were visual weld inspections which were backed up by independent subcontractor NDE reports.
On-that basis the work inspected prior to May 7,
1980 is concluded to be satisfactory.
On August 24, 1981, the identified individual was l
determined to be properly qualified and was recertified as a Level II.
1 o
K-2 l
ATTACHMENT 1 K.
NISCO (Continued) c.
One (1) identified individual was certified as a Level II inspector, and performed in this capacity at Waterford from June 4, 1979 to May 7, 1980. As a result of LP&L Audit No. 80-25 (May 2-23, 1980) a Stop Work Order was issued contending that he was
~
e
-not qualified to be certified as a Level II inspector.
His qualification-records were reviewed
- and, considering the experience he gained during the period in question, he was properly recertified; as a Level II inspector.
The inspections performed by this individual between June 4, 1979 and May 7, 1980 have been identified.
They were visual weld or fit-up inspections, which were backed up by independent subcontractor NDE Reports.
This. individual's work performance is therefore considered
' satisfactory both before and after his recertification.
On these bases, the work performed by NISCO is deemed satisfactory.
e 4
K-3
ATTACHMENT 1
-L.
N00TER
'1.
On-Site Dates: ' July 1976 to December 1981 2.
Scope of Work:
Fabricate and Erect a.
Refueling Water Pool Liner b.
Condensate Storage Pool Liner c.
Reactor Building Canal Liner including Floor Embedments, Floor and Wall Embedments, and Refueling Cavity Seal Bed ~ Plate d.
Spent Fuel Storage. Pool Liner a.
Spent Fuel Cask Storage Pool Liner f.
Refueling Canal Liner
.g.
Spent Fuel Cask Decontamination Area Liner
-h.-
Decontamination Room Liner 3.
Scope of Inspection:
a.
Receiving Inspection b.
Radiographic c.
Magnetic Particle d.
Ultrasonic e.
Leak Detection (Vacuum Box Testing) g.
Calibration of Test Equipment h.
Final Visual Weld Inspection 4.-
QA Program Requirements / Contractual Commitments:
a.
Quality Assurance Engineer (includes Auditors) - No requirements for qualification, b.
Quality Assurance Technicians (includes Record Reviewers) - No requirements for qualification.
c.
Quality Assurance Management / Supervisors - No requirements for qualification.
d.
Field Inspectors - Nooter Procedure SP-18, " Qualification of Inspectors", field requirements are High School education and/or prior experience in manufacturing and construction.
Natural or corrected near distance visual acuity such that ' individuals are capable of reading the J-l letters on the standard Jueger test chart.
Color vision evaluated for personnel performing color sensitive evaluations.
In
- addition, prior to performing inspection, the inspectors are briefed on job requirements.
SNT-TC-1A and Nooter e.
Nondestructive Examination Personnel Procedure NDE-10. " Nondestructive Examination Personnel Qualification and Certification".
L-1
_~
~ _
ATTACHMENT 1 L. N00TER (Continued) b 5.
Inspector Qualification and Dispositioning of Deficiencies:
~
The Verification Program identified three (3) Nooter individuals whose qualifications were determined as not meeting the requirements of' ANSI j N45.2.6-1973.
Corrective Action < Request EQA84-2 was initiated to i'
track-the disposition of this deficiency.
Review of inspection files revealed that two of those personnel acted as administrative supervisors and performed no inspections or examinations at Waterford.
The remaining individual although qualified Level II for visual and NDE' tasting, was determined not qualified for LT (vacuum box testing).
Inspection documentation revealed he ' was involved with visual, NDE, soap solution and vacuum box examination.
The majority of his work concerned the inspection of 177 - 3/4" non-structural plugs and cover plate welds in the liners of the Refueling Water Storage Pool (RWSP) and Condensate Storage Pool (CSP).
(These plugs were installed after grouting beneath the liners.) Documentation revealed he performed the following examinations in a seven day time frame.
a.
Visual inspection of cover plate fillat welds, root pass and filler welds on plugs.
(Qualified)
- -(
b.
PT of plate fillet welds and plug filler welds.
(Qualified) c.
LT (vacuum box) of cover plates.
(Not qualified)
Because of the non-structural nature of the work in question and the individualsf visual and PT qualifications the portion of the work on these pools inspected by him is deemed acceptable except for concerns over leakage.
Subsequently some repair work was done on both pools.
This repair work was completed, inspected, and documented. Additionally a highly sensitive helium pressure test was performed beneath the RWSP liner.
The test indicated minor leakage.
Leakage points were repaired, inspected and documented.
Presently both pools are filled and no leakage is evident.
I
{'
Based on the aforementioned facts, LP&L is confident that both pools are structurally sound and able to properly carry out their intended safety functions.
The review also indicated so2e inspections in the Fuel Handling Building on the Spent Fuel Cask Storage Pool Gate housing plates were l-visually examined by the individual in. question.
Again it is noted that he was qualified for this type of inspection.
Additionally Ebasco QA reinspected these welds under-NCR-W3-5804 EBFA/ MECH (NB-1;TP-1). On these bases the work involved in those inspections is l-considered acceptable.
L-2 l
l
_ _ _. _,. _ ~ _ _ _
ATTACICENT 1 L. N00TER (Continued)
?
The final task where records show that the individual in question also
~
performed leak testing is on a liner plate weld in the Spent Fuel Cask i
Storage Pool. The weld in question was successfully tested by visual
. and liquid penetrant inspections.
The weld also passed the system standing water leak rate test upon completion of all Fuel Handling Building. pool liner welding.
The local leak rate test that he performed was merely a precursor to the final standing water test.
Liquid penetrant testing combined with the standing water leak rate test would show any leak defects in the weld.
Based on the above, the work inspected by the identified individual is judged acceptable.
e 9
L-3
-ATTACHMENT 1 M.
SLINE 1.
On-Site Dates: December 1977 to August 1984-2.
Scope of' Work:
a.
Application of Service Level I, Service Level II and Balance'of Plant Equipment and Structure coatings.
3.
Scope of Inspection:
a '.
Surface Preparation Inspection b.
Product Selection Inspection c.
Paint and Protective Coating Application Inspection d.
Workmanship Inspection e.
Receiving and Issuing Material Inspections f.
Calibration Inspections 4.
QA Program Requirements / Contractual Commitments:
a.
QA Personnel except QA Manager - No procedural requirements for F
qualification.
Sline Procedure W3-1,
" Certification and b.
QA Manager Qualification of Inspectors", which requires QA Manager to be a Level III.
c.
Inspector Personnel - Sline Procedure W3-1, " Certification and l
Qualification of Inspectors".
^
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified twenty (20) Sline QC inspectors whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Request EQA84-26 was initiated to track the disposition of this deficiency.
Disposition was primarily on the basis that the Sline QA program requirements were sufficient for the particular tasks being performed and well documented records confirm the identified individuals met these requirements.
j While it is important to closely follow specifications related to the f
application of nuclear coatings, the inspections -associated therewith are relatively simple and can be competently performed with little or I
no previous experience following minimal training and testing on
(
specification requirements, inspection procedures, and the use of relatively simple tools.
(
The Sline Quality Assurance Program requirements included documented on-the-job training, classroom instructions, and review of education l
credentials.
A review was conducted of the records of the identified Sline personnel. This review of the well documented Sline program M-1 ve-w-,
e v --,
,,.--v.w.,,---.,,-.-
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,r-,,,r-vree-*--*~---%,--e
-g--,=g-==isr-s-+=---T
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$--='-e-v--
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ATTACHMENT 1 1
M. - SLINE (Continued) supports a conclusion that the identified individuals met the Sline program requirements. This conclusion, coupled with the simplicity of the required inspection tasks, provides reasonable assurance that the identified Sline individuals were competent to perform their inspection functions.
Further confidence in the quality of the Sline work is provided by the
~following additional considerations:
a.
Prior to and during the initial start of work, representatives from the coating manufacturers were on site to review the program and application methods.
On site coating manufacturer representation occurred periodically during the construction process.
The purpose of the manufacturer representation was to confirm, compliance with recommendations and provide further technical direction as necessary. Visual examinations of various applications (i.e., steel, concrete, etc.) were' performed by the I
representatives to assure proper surface preparation, application and curing.. Coating manufacturer representation provides added confidence in the quality of the finished product.
b.
Over 1000 individual tests (adhesion. Tooke Gage, Textex Tape, etc.) were performed by Sline and/or the paint supplier and
- Ebasco, many of which were discretionary.
Results were satisfactory.
c.
Over 35 field surveillances were also conducted by Ebasco covering either specific or random inspection points such that over a period of time all technical attributes of Sline performance were reviewed for adequacy.
Results were satisfactory.
d.
Dry Film Thickness (DFT) readings and visual examinations have been performed by Ebasco, both randomly and for specific purposes. Only minor deficiencies were identified.
L e.
During recent weld inspections throughout the plant, significant difficulty was encountered in the removal of paint to facilitate inspection, reflecting the quality of the coating application.
f.
An Ebasco NY Lead Corrosion Engineer made frequent site l
inspection visits to provide additional overview of quality.
On the above bases, there is adequate assurance that the coatings installed at Waterford 3 will perform satisfactorily in service.
l I
i M-2 l
1 ATTACHMENT 1 N. TOMPKINS - BECKWITH (T-B) 1.
On-Site Dates:
June 1977 to June 1984 2.
Scope of Work:
a.
PIPING 1.
Installation of ASME III Safety Class I,
II, III, and Non-Safety related (B31.1) Process Piping Systems.
2.
Installation of Pipe Flange Bolts.
3.
System Hydrostatic Testing.
b.
HANGERS 1.
Installation of associated Seismic and Non-Seismic Pipe Hangers / Supports (ASME Section NF, AISC(Fabrication) or AWS l
D1.1).
2.
Installation of Pipe Rupture and Whip Restraints including structural steel, U-bolts, restraining plates, spacers and shims for piping systems installed by T-B.
3.
Installation of expansion anchor bolts for systems installed by T-B.
3.
Scope of Inspection:
a.
PIPING 1.
. Fit-up and final visual inspection.
2.
Inspection of pipe flange bolts, i-3.
Hydrostatic testing.
b.
HANGERS / RESTRAINTS 1.
Fit-up and final visual inspection.
2.
Inspection of high strength bolting.
3.
Inspection of expansion anchor bolts.
c.
GENERAL 1.
Material Receiving inspection.
4.
QA Program Requirements / Contractual Commitments:
a.
Quality Assurance Auditors T-B Procedure TBP-8,
" Quality.
Assurance Audits",
requirements shall have or be given appropriate training or orientation to develop their competence for performirg required audits.
b.
Quality Control Inspector /QA Surveillance - ANSI N45.2.6 and T-B Procedure TBP-4, " Indoctrination, Training, and Certification of QA/QC Personnel".
5.
-Inspector Qualifiention and Dispositioning of Deficiencies:
The Verification Program identified 38 T&B QC inspectors whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Requests EQA84-12 and EQA84-23 were initiated to track the disposition of these deficiencies.
N-1
ATTACHMENT 1 N.
TOMPKINS - BECKWITH (T-B)
(Continued) 1-There has been a, significant amount of required and elective.
l overinspections, reinspections, tests and reviews conducted -by T&B, Ebasco, LP&L and others.. Personnel performing overinspections and reinspections were qualified to carry out their ^ stated activities.
These~ are displayed on.the attached Tables I
II.
Brief explanations, keyed to the tables, are:
PIPING AND PENETRATIONS (1)
T-B contracted Hartford Steam Boiler, Inc., to provide third party.
Authorized Nuclear. Inspection services.
The Authorized Nuclear Inspectors (ANI) inspected in-process and completed work.on a sample basis.to. independently assure compliance 'to the ASME Code.
These inspections were performed on items and processes that were also inspected by T-B QC personnel.
(2)
T-B inspectors only performed visual examinations of welds. All other Non-Destructive Examination (NDE) was independently performed by Peabody /GEO Testing.
GEO NDE included radiography, liquid penetrant, magnetic particle and ultrasonic testing.
(3) All radiographs were independently reviewed by a qualified Ebasco Examiner.
(4-) Independent Preservice Inspection (PSI) of piping, pipe welds, and
. pipe supports per 'ASME Section XI requirements was performed ' by -
Virginia Corporation under contract to LP&L.
This inspection consisted of both visual examination and ultrasonic testing of critical safety related installations previously installed and inspected by T-B personnel.
i (5) All safety-related piping systems were hydrostatically tested to I'
assure system integrity.
In addition to T-B QC personnel, these tests were witnessed by the T-B ANI (Hartford), Ebasco Start-Up personnel, LP&L Start-Up personnel, and the LP&L ANI (Factory Mutual - witnessed Class 3).
1 (6) All piping documentation was reviewed by T-B and Ebasco QA personnel.
On a sampling basis, LP&L QA personnel reviewed a minimum of 10%. of -
i l
this documentation.
The LP&L QA documentation review included field verification of approximately 3% of the installed hardware of small bore piping.
I (7) The Pre-Core Hot ' Functional Test has been performed and this test verified the integrity.of the pipe welds under pressure and thermal
-loading based on simulated actual plant conditions.
l' N-2
ATTACHMENT 1 N.
TOMPKINS - BECKWITH (T-B)
(Continued)
(8) Verification of piping configuration was accomplished as part of Ebasco Engineering IE Bulletin 79-14 program.
The Pre-Core Hot Functional thermal monitoring program further established the adequacy of the as-built piping configuration to function as designed.
SEISMIC PIPE SUPPORTS (9) Ebasco. Engineering has performed a field verification of Seismic Category I support / restraints'which consisted of the following:
a.
Support / restraint location and functionality (IE Bulletin 79-14).
b.
Completeness of hardware installation (10) Support / Restraint functionality was verified during the Pre-Core Hot
' Functional Thermal Monitoring Test program.
(11) As a result of Significant Construction Deficiency No. 60 (NCR 4010),
T-B QC inspectors reinspected over 4500 safety-related pipe supports.
(12) Ebasco QA has performed a detailed as-built inspection of over 200 highly stressed hangers.
(13) LP&L QA has inspected 3500 hangers in accordance with procedure QASP 19.7.
(14) LP&L contracted Helmut
- Thielsch,
'a noted metallurgist, to independently review the support / restraint assembly structural welds.
In-his report he concluded that even those welds that were considered marginal in appearance, exceeded load carry requirements by a considerable amount.
Further, he judged the structural welds to be comparable to other nuclear power plants.
(15) The LP&L Piping Verification Group is responsible for the following activities to be performed during Phase III testing program:
a.
Monitor mechanical snubbers for cold / hot settings b.
Monitor spring hangers (except 2" & under non-seismic /non-safety) for cold / hot settings.
c.
To clear the deficiencies found during the pre-core hot functional testing, a portion of safety class (high energy)'
piping will be monitored for thermal expansion.
(16) All hanger documentation was reviewed by T-B and Ebasco QA personnel.
On a sampling basis, LP&L QA personnel reviewed a minimum of 10% of this documentation. The LP&L QA documentation review included a field verification of approximately 3% of the installed hardware.
N-3
ATTACHMENT 1 N.
TOMPKINS - BECKWITH (T-B)
(Continued)-
The above reviews and inspections-confirm the overall acceptability of the work performed by Tompkins-Beckwith.
Therefore, there is adequate assurance that the safety related piping and supports will ' satisfactorily perform their intended functions and no further construction-related inspections or tests are warranted.
8 9
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1 ATTACHMENT 1 l
0.
WALDINGER 1.
On-Site Dates: April 1977 to June 1979 2.
Scope of Work:
a..
Install HVAC duct, duct accessories, and supports.
b.
Install HVAC equipment.
c.-
Perform pre-operation, balancing, and functional testing of HVAC systems.
d.
Install plant stack.
e.
Install duct insulation.
f.
NDE by others.
g.
Waldinger's contract calls for furnishing and fabrication of ductwork, acceesories,.and supports; as well as installation.
h.
Includes safety-related and/or seismic and non-safety related/non-seismic.
1.
Leak and pressure testing of HVAC systems performed by Coastal
' Air Balance (W3-FB-19) with TWC QC witness.
3.
Scope of Inspection:
a.
Receiving Inspection.
b.
Inspection of on-site fabrication.
c.
Inspection of installed concrete expansion anchors.
d.
Inspection of duct-duct connections.
e.
Fit-up and final visual inspection of structural welds..
f.
Inspection of equipment setting (including bolt torquing).
g.
Witness leak and press'ure tests.
4.
QA Program Requirements / Contractual Commitments:
a.
QA Personnel - ANSI N45.2.6 paragraph 3.1 per Waldinger's QA Manual.
b.
QA Auditors - Waldinger Procedure SqCP 18.1-1, " Audit" which is compatible with ANSI N45.2.23.
c.
QC Inspectors - ANSI N45.2.6 and Waldinger Procedure SQCP-2.1-1,
" Qualification of Inspection, Examination, and Testing Personnel."
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified thirteen (13) Waldinger inspectors whose qualifications were initially determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Requests ~(CAR)
EQA84-01 and EQA84-25 were initiated to track the disposition of these deficiencies.
One of the identified individuals was determined to have performed no safety related inspections.
One identified individual's work was reinspected by a qualified inspector.
0-1
ATTACHMENT 1 0.
WALDINGER (Continued)
Two identified individuals achieved qualification and certification for Level I. while employed at Waterford 3.
Records show that they performed no quality inspections prior to proper certification.
For the remaining nine (9) identified individuals, the construction feature of predominant concern involved structural welding on duct supports because of the lack of subsequent proof testing or significant overinspection and the importance of satisfactory workmanship thereon. Therefore a sample reinspection of structural welds was performed by qualified personnel. This reinspection was performed under LP&L Procedure QASP 19.19.
Approximately 25 joints for each of the nine inspectors (a total of 220 welds) were reinspected and evaluated.
Sixty-five welds were reinspected with paint removed to better ascertain the quality of welds..
All reinspected welds were found to be acceptable without rework.
The remaining inspection tasks did not require reinspection on the following bases:
Receipt Inspection and On-site Fabrication Safety related and special HVAC duct sections were prefs.bricated (welded) in the shop by Waldinger and shipped to the site.
All material was receipt inspected upon arrival at the site.
If
. any rework was required the rework was then reinspecten by Waldinger field inspectors.
The majority of these inspections were performed as part of the erection process which involved multiple inspections and considering subsequent satisfactory system testing the ducting is judged to be adequate to perform as intended.
Inspection of Installed Concrete Expansion Anchors Hilti expansion anchors are conservatively designed and have considerable reserve capacity.
In accordance with NRC IE Bulletin 79-02, they are designed for a nominal safety factor of 4 in tension.
Therefore it is considered that an isolated defective bolt installation will not endanger the structural integrity of the system and for this reason such postulated situations are acceptable.
In addition, the site anchor installation activity was addressed by Ebasco in December of 1981.
Ebasco Corrective Action Report 4
(C.A.R.)
82-3-2 was written against all companies installing safety related expansion anchors.
Ebasco nonconformance report NCR-W3-3316 was written in conjunction with the C. A.R. 82-3-2.
0-2
~
ATTACHMENT 1 O. IWALDINGER (Continued)
The C.A.R.
-identified the fact that contractors installing.
expansion anchors did not fully comply with design specifications 1564-468 (seismic. applications)
.and 1564-467 (non-seismic.
{.
applications).
The major specific violation noted in the C. A.R.'
was that the spacing distance of anchor bolts between adjacent plates was less than 10 bolt diameters and the distance of-installed. anchors to free edge was less than 5 bolt diameters.~
As a result of this Corrective Action Report, Nonconformance Report (NCR-W3-3316) was initiated to evaluate all identified cases where the spacing criteria were not met.
This NCR required a walkdown by Ebasco Quality Control' to identify previous installations and required Ebasco Design Engineering to evaluate those cases identified as violations.
This 'walkdown was.
completed, violations were evaluated and the NCR was closed after all identified items were resolved.
Inspection of Duct-to-Duct Connections and Witnessing of Leak and Pressure Tests Duct-to-duct connections -are inspected in process primarily to facilitate the efficient conduct of leak and pressure tests. The~
in-process inspections were. limited to visual examination of bolted flange connections and presence of gaskets.
No bolt torquing inspections were required or -involved.
Waldinger QC personnel witnessed a portion of the initial pressure and leak--
tests.
The final pressure and leak tests were performed byLthe Startup Test Group and were witnessed by LP&L, Ebasco QC, Ebasco Construction Engineers and Ebasco Site. Support Engineers. 'The test results ensure that the systems performed in accordance with specifications.
Inspection of Equipment Setting Inspection of equipment setting included verification that bolts (and washers, if required) are in place and tight, and/or welds are completed.
Since there are no torquing requirements for the setting of HVAC equipment, the inspection of' equipment setting required only inspection for installation of bolts and washers which require a minimal level of knowledge and experience.
On these bases, there is-adequate assurance that the' Waldinger HVAC installations.will perform satisfactorily in service.
0-3
_____.-__-_-_.--..c-.._...__-__.___.~..._,.___.-_-
_..u,.._-.._
RESPONSE
ITEM NO.: 10'(Revision 1)
TITLE:
Inspector Qualification (J.A. Jones and Fegles)
NRC DESCRIPTION OF CONCERN:
The NRC staff reviewed the qualification and certifications of QC inspectors in the civil / structural area.
The review included the qualifications of four Ebasco inspectors, five J.A. Jones inspectors, and eight Fegles inspectors. The inspector qualifications were compared against the requirements of ANSI N45.2.6 and the contractor's procedures.
The staff found that four of the five J.A. Jones inspectors and two of the eight Fegles inspectors failed to meet the applicable certification requirements related to relevant experience.
Since these inspectors were involved in the inspection of safety-related activities,. the fact that they may not have been qualified ~ to perform such inspections, renders the quality of the inspected construction activities as indeterminant.
LP&L shall review all inspector qualifications and certifications for J.A. Jones-and Fegles against the project requirements and provide the information in such a form that each requirement is clearly shown to have been met by each
, inspecter.
If an inspector is.found to not meet the qualification requirements, the licensee shall then review the records to determine the inspections 'made h
by ti e unqualified individuals and provide a statement on the impact of the deficiencies noted on the safety of the project.
DISCUSSION:
A verification program was implemented to review the professional credentials of 100% of the site QA/QC personnel who may have performed safety-related functions at Waterford 3, including supervisors, managers and remaining QA/QC personnel.
The responses to ' Issues No.
I and 20 discuss inspector qualifications for Waterford 3 contractors other than J.'A. Jones and Fegles.
The program, which is being performed under the overall direction of LP&L, consists of three major elements:
o Collection and verification of personnel data.
o Evaluation of qualifications against specified standards.
o Dispositioning of deficiencies resulting from cases where inspections and tests were conducted by personnel whose qualifications against the sppropriate standards could not be confirmed.
10-1
Collection and Verification of Personnel Data Personnel. data were collected from various sources, including site files, contractor home office files, personal contact with individuals or supervisors and through a background verification program.
Efforts were made to verify ; the education and work experience of 100% of the J.A. Jones and Fegles QA/QC personnel by researching Waterford 3 contractor records and by-contacting schools, former employers and others.
The background verification effort for J.A. Jones and Fegles personnel was a joint LP&L/Ebasco effort..While the success rate of this effort was good, there were cases where confirmatory information was not obtainable.
In such cases, the judgement of the LP&L Review Board, as described below, was used to rule on the reliability of the available information.
Evaluation of Qualifications to Specified Standards QA/QC perscnnel data were evaluated in order to classify individuals as either.
having verified qualifications or not.
Training, education and work experience were the qualifications of primary concern.
These qualifications were verified against the following criteria:
(1)
Inspectors - ANSI N45.2.6-1973 (2) Other QA/QC Personnel - QA Program requirements Initial qualification determinations for J.A. Jones and Fegles QA/QC personnel weite performed first by Ebasco and then separately by an LP&L review group.- In order to control the consistency of these determinations, approved procedures were utilized.
Determinations related primarily' to ~ balancing education, experience and training factors.
The.LP&L review group qualification determinations were rendered in two -
categories:
" qualified" and "potentially not qualified".
"Potentially not qualified" determinations were referred to an. LP&L Review Board assisted by contractor personnel and a consultant very familiar with inspector qualification and related standards.
This process resulted in a final determination for all QA/QC personnel as either " qualified", or " unqualified".
The qualification review process is described in.QASP 19.12 and QAI-32.
The following points further clarify the process:
1.
The meaning of the term " unqualified" must be amplified.
In some cases determinations were made
- that, based on verified
- data, individuals' backgrounds did not warrant qualification to ANSI N45.2.6-1973.
In other cases, however, individuals were considered
" unqualified" as an expedient in reaching resolution to the concern.
This occurred in cases in which:
10-2
l a.
Research of records, inquiries to past employers and employees, contact with schools and verification of training received was 1
either not possible or could not be concluded in a reasonable period of time.
b.
Apparent discrepancies existed between background information j
provided by some individuals and that obtained in the verification process, and resolution could not be achieved on a timely basis.
Minor discrepancies were excused;
- however, significant discrepancies generally rendered any other significant but unverified data as suspect.
2.
In-the process
- used, being judged as- " unqualified"- to ANSI N45.2.6-1973 did not automatically render the individual's work as invalid.
For example, an individual may not have the education-and
. experience qualifications for all inspection work, yet be fully competent.through specific training or other means to perform the particular tasks assigned.to him, which might have been very simple and repetitive in nature.
Such an individual potentially satisfies ANSI requirements, which ultimately require that ~ an individual's qualifications be sufficient to provide reasonable assurance.that the individual can competently perform a particular task. Whether or not 4
the individual is technically qualified, the individual's work can be
- deemed valid.
3.
During the construction period, some contractors made undocumented judgements with respect to the need for eye. examinations for inspection personnel.
Such judgements were based on the level of
- visual acuity or color perception required to achieve competent' inspections.
Such judgements were also made as.part of the verification program and disposition process and will be documented.
i It is noted that such judgements are specifically suggested in ANSI N45.2.6-1978. This factor was not deemed disqualifying.
4 4.
Some individuals were classified as inspectors but performed no safety.
related inspections.
Disposition of Deficiencies For J.A.
Jones and FegJes, the LP&L Review Board compiled a list of
" unqualified" inspector personnel, and Corrective Action Requests (CAR) were written.to formally track and disposition potential deficiencies. The manner in
' which the deficiencies were resolved is attached and is briefly summarized as follows:
J.A. Jones For J.A. Jones, CAR EQA84-22S1 identified 28 QC personnel whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973. Twenty of
]:
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4 these were ' found to have performed safety related inspection functions on
~ concrete placements.
The construction activities inspected by the identified l'
J.A. Jones inspection personnel with respect. to the Common Foundation Basemat g
and Engineered Backfill were also inspected by qualified Ebasco inspectors and l
the inspected work was deemed acceptable on this basis.
I i.
~'J A Jones inspector qualification deficiencies in the balance of the Nuclear Plant Island Structure (NPIS) have also been evaluated.
The evidence of
. competent Ebasco overinspections in this-phase of concrete inspection activities, ranging from Level I inspections up to Level III, is the predominant factor in' accepting the remaining work inspected by the identified J.A. Jones individuals who performed safety related inspection functions.
This evidence served as ' a basis for accepting essentially all of - J. A.
Jones inspection activities up to the end of 1977 by which time the NPIS concrete construction was approximately 85% complete.
Subsequent inspection activities of the identified J.A. Jones individuals is accepted based on their prior involvement with overinspected work, evidence of co-signature by qualified Jones inspectors, observation ~by qualified Jones supervisory personnel, and Ebasco field engineering endorsement for placements, all of. which serve as part of. guided on-the-job training to qualify the individuals to perform inspections.
On these bases, the work inspected by the identified J. A. Jones individuals is j
considered satisfactory.
~!
Fagles a
For Fegles, CAR EQA84-20S1 identified eight QC personnel whose qualifications r
were determined as not meeting the requirements of ANSI N45.2.6-1973.
Four of those individuals were found to have performed no safety related inspections.
r The remaining four individuals performed preplacement inspections on-a-limited scope of slip form operations. The construction activities inspected by the identified Fegles personnel were aleo inspected by qualified Ebasco QC inspectors. Accordingly, inspection by the Fegles personnel does not render the quality of the inspected construction activities as indeterminate.
Adequacy of the innpected construction activities was independently confirmed by qualified inspectors, CAUSE:
j ANSI N45.2.6-1973 allows substitution for education and experience levels by
~
noting that "... education and experience requirements specified for the various
~
levels should not be treated as absolute when other factors provide reasonable
}
assurance that a person can competently perform a particular task."
J.A. Jones and Fegles, to varying degrees, employed such substitutions in certifying the qualifications of their QA/0C personnel.
However, the verification program 1-revealed that verification of background data was not adequate or documented, documentation of the justification for substitution was sometimes not provided
.or lacked depth, and/or was not always totally in accord with J.A. Jones /Fegles
. procedures or the ANSI standards, as currently interpreted.
i 10-4 i
i
. ~,
_..,~_.._,_,-_~_.,_.m
._,,.__-,___.__._,,,.~.,_-_.-m,
GENERIC IMPLICATIONS:
This issue has been treated generically.
In response to this Issue and Issues 1 and 20, the verification program included 100% of the QA/QC personnel of all site contractors who performed safety related work.
With regard to future work, qualification and certification of inspectors (including NDE personnel) will be administered through strict compliance with LP&L Nuclear Operations Procedures which meet the requirements of Regulatory Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) and SNT-TC-1A-1975, as applicable.
SAFETY SIGNIFICANCE:
Satisfactory disposition of CAR EQA84-22S1 (J.A.
Jones) and CAR EQA84-20S1 (Fegles) provide adequate assurance that the installations by J. A. Jones and Fegles will perform satisfactorily in service and poses no constraint to fuel load or power operation.
CORRECTIVE ACTION PLAN / SCHEDULE:
Corrective actions required to disposition CAR EQA84-22S1 (J. A. Jones) and CAR EQA84-20S1 (Fegles) have been satisfactorily completed as described in.
The review of non-inspector personnel qualifications is complete.
No significant concerns have been identified.
ATTACHMENTS:
1.
Results of Verification Program for J.A. Jones a*nd Fegles.
~
REFERENCES:
1.
QASP 19.12, Review of Contractor QA/QC Personnel Qualification Verification 2.
QAI-32. Instructions for Verification of QA/QC Personnel Qualifications e
10-5 L
ATTACHMENT 1 A.
J.A. JONES 1.
On-Site Dates: October 1975 to March 1981 l
2.
Scope of Work:
a.
Concrete Construction b.
Concrete Masonry c.
Concrete Reinforcing Steel d.
Dewatering and Excavation e.
Waterproofing f.
Waterstops g.
Mechanical Splicing of Reinforcing Steel h.
Filter and Backfill i.
Structural Steel 3.
Scope of Inspections:
a.
Material Receiving Inspection b.
Site Fabrication Assembly & Installation Inspections c.
Structural Inspections d.
Civil Inspections 4.
QA Program Requirements / Contractual Commitment:
QA/QC Personnel, except Auditors, ANSI N45.2.6 and Manual TR-1, a.
" Training / Certification Program",
Procedure POP-N-505,
" Qualification / Certification of Personnel" and Procedure POP-N-702, " Personnel Training / Qualification / Certification".
b.
Q.A.
Auditors ANSI N-45.2.23 and Manual TR-1,
" Training / Certification Program",
and Procedure P0P-N-505,
" Qualification / Certification of Personnel" and Procedure POP-N-702, " Personnel Training / Qualification / Certification".
5.
Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified 28 J.A.
Jones personnel whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.
Corrective Action Request EQA84-22S1 was initiated to track the disposition of this deficiency.
Eight of the 28 identified individuals were found to have not performed any safety related inspection functions.
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f COMMON FOUNDATION BASEMAT The Common Foundation Basemat was inspected by both J.
A. Jones and Ebasco inspectors.
Where an inspection activity was performed by the identified ?J.A.'
Jones individuals, the qualifications of the Ebasco inspector who performed the overinspection of the same activity were checked.
In this manner it was demonstrated that each of the Common Foundation Basemat placements were inspected by one or more qualified inspectors.
Therefore the adequacy of the inspected work is confirmed.
OTHER REMAINING JONES ACTIVITIES The quality of reinforcing bar cadwelds which was inspected by J. A.
Jones has been addressed in the response to NRC Item No. 11 for the entire NPIS and was resolved satisfactorily therein.
The structural backfill inspections performed by J.A. Jones were also overinspected by qualified Ebasco inspectors.
In
- addition, statistical studies were performed which demonstrate-the consistency
.of the work.
See.the Response to NRC Item No.
7.
The clam shell filter. blanket quality was addressed in NCR-W3-5997, including consideration of the identified J.A. Jones ind'.viduals and was resolved satisfactorily.
The limited welding performed by J. A.
Jones was addressed in the response to NRC Item No.
9.*
J.A.
Jones welding was resolved satisfactorily therein.
REMAINING J.A. JONES CONCRETE ACTIVITIES The review of concrete inspections determined that, in other than the Common Foundation Basemat and soils areas, inspections were performed by 18 of the 20 identified J.A. Jones individuals who performed safety related inspections.
Concrete placement packages were reviewed and the inspection activities performed by the J.A. Jones 18 individuals were identified.
This review and evaluation was time phased and the 18 identified J.A.
Jones individuals were divided into the following five (5) groups:
Group 1 - Pre-1978 Level I Inspectors and Trainees (3 Individuals)
These individuals performed concrete inspections before the end of 1977 when Ebasco QC was conducting overinspection on site.
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r Essentially all inspection activities by these individuals were
.either overinspected by qualified Ebasco -inspectors or cosigned by other' qualified J.A.' Jones inspectors.
It is considered-that on-the-j ob training in a particular inspection activity for a
~
-minimum of two (2) placement packages following the classroom courses and -tests is sufficient to perform that inspection competently. These individuals received such training.
.On' this basis,. inspections performed by _ the individuals in this group, coupled with. the qualified overinspections, have been evaluated to conclude that the inspected work is satisfactory.
Group 2 - Pre-1978 Level II Inspectors (6 Individuals)
The review of the concrete inspection. records showed that the Level II function was limited to providing approval of preplacement inspections for subsequent. concrete placement.- The identified individuals routinely ' performed Level I concrete inspections, for which they_ were qualified, in addition to the approval. function, and can be expected to have had sufficient knowledge regarding
' acceptability of the preplacement inspections.
Furthermore, each Level. II approval provided by these individuals was Jendorsed by a qualified :Ebasco QC.
inspector.
An added level of confidence is provided by the fact that all phases of preplacement inspections were overinspected by qualified 'Ebasco inspectors before ' the preplacement status was presented for approval.
Thus, there is adequate assurance that the work inspected by z individuals in this group is was satisfactory.
Group 3 -Post 1978 Level I Inspectors and Trainees (3 Individuals)-
These individuals performed concrete inspections without Ebasco QC overinspection.
In this review, emphasis was placed on identifying and evaluating these individuals' initial inspection involvement.
As before, specific on-j ob-training for a minimum of two (2) placement packages following the classroom courses and tests was considered sufficient training to perform.the assigned inspection competently.
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It was found that prepla'coment inspections were conducted under
- the surveillance of competent.J.A. Jones supervisors who approved and cosigned these inspections for subsequent concrete placement.
Added confidence is provided by the pre-placement review. by Ebasco Engineering representatives..who. also provided approval prior to placements.
With rare exceptions, other qualifie'd inspectors participated in concrete curing inspections during the required day period, so that deficiencies would have been identified and corrected if required.
Moreover, the curing inspection is accompanied by records of concrete temperatures which have met the specification-requirements.
Bas.ed on the foregoing there exists adequate assurance that the work inspected by individuals in this group is satisfactory.-
Group 4 -post 1978 Level II Inspectors (3 Individuals)
One individual, determined as not meeting Level II requirements, actually performed no Level II functions.
This individual did perform Level I inspections for which he was determined to have been qualified.
The remaining ' two individuals provide.d approval for concrete placement without Ebasco QC overinspection.
A review of personnel files and inspection records revealed' that.both individuals had performed all ' phases of concrete' inspections in -
the Level I capacity (for.which they were qualified) quite extensively prior to.being authorized to approve preplacement inspections.
Based' on ' their specific inspection experience on the job, there is a reasonable assurance that their Level II function was performed competently.
-Where these individuals -provided an approval for. placing concrete, there was also an endorsement. by an Ebasco Field Engineering representative who performed surveillances prior to releasing placement L areas for concrete placement, and who' also confirmed that Ebasco Engineering forces. had completed their extensive check-out programs.
This served to provide ' an added level of confidence to the approval given by the identified Level' II individuals.
Based on the above observations, the work inspected by individuals in this group is satisfactory.
s O
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Group 5 - Level III Inspectors (3 Individuals)
The evaluation of these individuals is provided in Appendix C of the response to CAR EQA84-22SI.
Inspections performed by these individuals were Level II type inspections and are considered acceptable based on the fact that these individuals are considered qualified at that level.
CONCLUSION The evidence of competent Ebasco overinspections in all phases of concrete inspections at all levels, ranging from Level I inspections up to Level III approval of procedures, plays an important part in accepting the work performed by J.A. Jones individuals who performed safety related inspection functions and whose qualifications are in question.
This acceptance criterion served to clear practically all J. A. Jones inspection activities up to the end of 1977 by which time the Nuclear Plant Island Structure (NPIS) concrete placements had progressed to approximately 85% completion.
In the review of J.A. Jones inspection activities not overinspected by Ebasco QC inspectors, emphasis is given to identifying evidence of cosignature by other qualified J.A.
Jones supervisory surveillances and Ebasco Field Engineering endorsement for concrete placement. This evidence, in turn, is used to qualify the work covered by their inspection activities in the fol1.owing period.
On these bases,.there is adequate assurance that clie J.A. ' Jones installations will perform satisfactorily in service.
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F l
I l
' ATTACHMENT 1 B.
FEGLES 1..
On-Site Dates: December 1975 to August 1976 (Shield Wall)
February 1979 to February 1980 (Dome) 2.
Scope of Work:
a.
Designing. furnishing, fabricating, erecting and dismantling slip forms for shield wall construction and conventional formwork and supports for dome construction.
b.
Handling, placing and fastening reinforcing steel.
c.
Detail reinforcing steel for shield wall slip form construction.
d.
Handling, placing and setting to line and grade all items to be embedded in the shield wall and in the done.
a.
. Forming for blockouts in shield wall, installing waterstop, removing forms and patching voids or honeycomb areas.
f.
Placing, finishing and :uring concrete by the slip form method for the shield wall and the dome by conventional 2 staae construction.
3.
Scope of Inspections:
a.
Material receiving inspection b.
Form erection inspection c.
Placement area preparation inspection d.-
Concrete placement inspection-e.
Concrete finishing and curing inspection f.
Concrete repair inspection g.
Dome form decentering inspection h.
Reinforcing stee'l placement inspection 4.
QA Program Requirements / Contractual Commitments:
Fegles - Shield Wall Construction: December 1975 to August 1976 a.
QA/QC Personnel except Auditors ANSI N45.2.6 and Fegles Procedure QAP-303,
" Quality Assurance Plan" and OAP-303 Supplement #2, " Personnel Qualifications".
b.
QA Auditors - QA auditor must be a Corporate QA Manager.
Fegles - Dome Construction:
February 1979 to February 1980 a.
QA/QC Personnel except Auditors ANSI N45.2.6 and Fegles Procedure QAP-303.21, " Qualification of Inspection Personnel".
b.
QA Auditors - QA Auditor must be a Corporate - QA Manager (Level III).
B-1
1 5.-
Inspector Qualification and Dispositioning of Deficiencies:
The Review program identified eight (8) Fegles QC personnel whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.- Corrective Action Request EQA84-20S1 was -initiated to track the disposition of this deficiency.
Four of the eight identified individuals were found to have not performed any safety related inspection functions.
The remaining four identified inspectors performed quality inspections as shown in the Concrete Preplacement Checklist Form QCIP-6.1. The quality inspections performed by these inspectors were duplicated by five qualified Ebasco QC. inspectors using an expanded Concrete Preplacement Checklist Form QCIP-6.2.
One of the Ebasco Inspectors who performed the overinspection was qualified as a Level III Electrical Inspector and was not a qualified Civil Inspector.
Upon review of the QCIP-6.2 Forms, it was verified that this individual inspected only the electrical aspects of the QCIP-6.2 forms, for which he is qualified.
Accordingly, adequacy of the inspected construction activities was independently confirmed by qualified inspectors.
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.