ML20107K646
| ML20107K646 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/17/1984 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| (NMP2L-0204), (NMP2L-204), NUDOCS 8411130226 | |
| Download: ML20107K646 (8) | |
Text
C M Y NIAGARA RUMOHAWK NIAGARA MOHAWK POWER CoRPORAT10N/300 En:C DOULEVAHD WESL GYRACUCE N Y 13202/ TELEPHONE (315) 474-1511 October 17, 1984 (NMP2L 0204)
Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Commission Region I Division of Project and Residei t Programs 631 Park Avenue King of Prussia, PA 19406 Re: Nine Mlle Point Unit 2 Docket No. 50-410 Ocar Mr. Starostecki:
On August 31, 1983, Niagara Mohawk submitted a final report in accordance with the provisions of 10CFR50.55(e) documenting the identification by Stone &
Webster Engineering Corporation of Field Quality Control Inspectors who had performed inspections in areas for which they were not formally certified.
The investigation, which resulted in the identification of this concern, was initiated in response to the findings identified in Nuclear Regulatory Commission Inspection Report No. 82-13. A followup investigation, which involved a review of inspections dating back as far as September 1981, has now been completed. The results of this investigation are contained in the i
attached report.
j As you will note, the investigation has established that the identified deficiencit.5, had they remained undiscovered, would not have affected the safe operation of the plant. Preventive actions are identified in our letter of June 30, 1983.
Very truly yours, DOM \\
C. V. Mang(nJ Vice President NJclear Engineering & Licensing TL:Ja Attachment xc: Project File (2)
R. Gramm, NRC Resident Inspector Dako!oo8j[o PDR A
A1 -
NIAGARA M0 HAWK POWER CORPORATION NINE MILE P0 INT NUCLEAR STATION UNIT 2 D0CKET NO. 50-410 Supplemental Report for a Problem Concerning Uncertified Field Quality Control Insoectors The initial list of uncertified inspectors was identified in a Niagara Mohawk Power Corporation investigation conducted in response to the findings identified in Nuclear Regulatory Commission Inspection Report 82-13. The corrective actions to this problem are discussed in the June 30, 1983 Niagara Mohawk response to the " Notice of Violation and Proposed Imposition of Civil Penalty" (which was transmitted to Niagara Mohawk from the Administrator of Region I on April 26,1983).
This report describes additional uncertified FQC inspectors that were not reportedinthefinal10CFR50.5S(e)reportsubmittedAugust 31, 1983.
1.
Description of the Problem An inspector was identified as having performed rigging and handling inspections for which he was not certified, as evidenced by the initials in blocks 66-68 of Inspection Report Nos. M1009322, M1009350 and M1009351 dated December 1, 7 and 7, 1981, respectively.
Analysis of Safety Implications These three inspections were performed in the presence of a certified Level II inspector as a method of on-the-job training, which is substantiated by a written statement received from the certified inspector.
Although the signing of the formal inspection reports by an individual receiving on-the-job training is a deficiency, a certified Level 11 inspector was present during the inspections; therefort, this condition would not adversely affect the safe operation of the plant.
2.
Description of the Problem An inspector was identified as having performed receipt in sections 1,r which he was not certified. A total of nine inspections were performed that involved 583 items and are documented on the fo110 wing inspection reports:
Inspection Report Number Specification Date Issued M1001806 P304V 12/19/81 11001768 P800A 12/12/81 11001745 1A 12/5/81 11001740
- 0A 12/5/81 11001742 P800A 12/5/81 11001743 P800A 12/5/81 i
11001744 P800A 12/5/81 l
11001746 P800A 12/5/81 11001741 P800A 12/5/81
+
Analysis of Safety Implications All of the items documented on these inspection reports had been released from the supplier's shop after inspection by a Procurement Quality Assurance representative of Stone & Webster Engineering Corporation or General Electric. The inspections that were performed consisted of six attributes:
a.
Documentation b.
Shipping Damage c.
Cleanliness d.
Protective Covers / Seals e.
Assigned Storage Levels f.
Identification The above inspections performed by the inspector document that 158 items were unsatisfactory, of which 152 items were subsequently reworked and reinspected by a certified inspector, and the remaining six items were upgraded to a nonconforming status and documented in Nonconformance &
Disposition Report No. 3250.
The inspector had approximately 9-1/2 /esrs of inspection experience prior to performing these inspections. He had been certified as a Level
!! inspector with Stone & Webster Engineering orporation since June 1978 in the mechanical discipline. Additionally, the inspector had received training in the area of these inspections, which included eight hours of on-the-job training.
Although the inspector was not certified in receipt inspections, he was certified as a Level 11 inspector in the contract monitoring discipline on August 1, 1981.
The duties performed by the inspector in this discipline included surveillance of the contractor's receiving activities, as evidenced on Type C Inspection Report No. MIG 00041 dated August 24, 1981.
Inordertoobtainadditionalasssuranceofthesubpectinspections,a certified Level II inspector performed a review of 51 of the nem>
previously documented on the Inspection Reports identified above uttitzing the same attributes. The results of the review were satisfactory.
Although a deficiency existed in that the inspector war not formally certiftad to perform the identified inspections, based on the above explanation (which includes a partial review of the inspector's findings),itwouldnothaveadverselyaffectedthesafeoperationofthe plant.
3.
pescriptionoftheProblem Aninspectorgeneratedonecadweldinginspectionreport(No.S1017294)on October 31, 1981, for which he was not certified.
L G
Analysis of Safety Implications The inspector completed the required readings on August 1, 1981 and had received 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> of on-the-job training (for cadwelding) prior to
' October 31, 1981. The_ inspection. involved verifying the sleeve type, identification, bar centering, marks,-check for voids and slag and cadwelder qualification.- Considering the basic inspection attributes for o
cadwelding and the fact that he was a certified Level I inspector (August 12,1981) in concrete placement and had received 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> of on-the-job training in cadwelding,~ this deficiency would not have adversely affected the' safe operation-of the plant.
4.-
Description of the Problem An inspector _ generated one testing of concrete inspection report (No.
S1016442) on September 28, 1981, in which his initials appear in blocks 66-68. _The inspector was not certified in testing of concrete.
Analysis of Safety Implications Although the inspector was not certified in testing of concrete, the Inspection Report was cosigned.by a certified Level II inspector, and a statement was provided that when performing the laboratory work, he was under direct supervision; therefore, this deficiency would not have adversely affected the safe operation of.the plant.
5.
Description of the Problem An inspector _ performed two inspections, one for vermiculite (No.
51017018) on October 20, 1981,-'and one for concrete placement (No.
S1017520) on November 11, 1981, in which his_ initials appear in blocks 66-68. The inspector was not certified in these areas.
' Analysis of the Safety Implications Both _ inspection reports were cosigned by a certified Level II inspector, and a_ statement was provided that, when performing the~ inspections, the inspector in question was under direct supervision; therefore, this deficiency would not have adversely affected the safe operation of the plant.-
6.
Description of the Problem An inspector generated three receiving inspection reports (Nos. M1001412, M1001396 and M1001484) on September 29, 25 and October 14, 1981, respectively, for which he was not certified.
His certification was to perform receipt inspections of " source-inspected equipment / material,"
i.e., Stone & Webster Engineering Corporation Procurement Quality Assurance inspected items and not General Electric source-inspected equipment / material.
. Analysis of Safety Implications Both of these activities are covered by Stone & Webster Quality Assurance Inspection Plan No. N20QAD77FA001 under " materials / equipment source inspected," and require inspection of identical generic attributes.
--,s
c
..i t-The mtjor difference between these two inspaction activities is the documentation received.
The documentation for the identified inspection reports was re-reviewed and found acceptable on December 29, 1983.
Based on the re-review of the documentation, this deficiency would not have adversely affected the safe operation of the plant.
7.
Description of the Problem An inspection supervisor generated one in-process coatings inspection report (No. S1016660) on September 15, 1981,- one day prior to his q
certification'at Nine Mile Point Unit 2.
4 Analysis of Safety Implications The inspection supervisor performed an inspection one day prior to his formal certification which does constitute a deficiency; however, based on his experience and prior certification in coatings at another plant (the inspection supervisor was previously certified Level II in coatings on March 20,.1981 at another plant), the deficiency would not have adversely affected~the safe operation of the plant.
8.
Description'of the Problem
-A senior inspector generated one studwelding inspection report (No.
-S1016751) on October 10, 1981, for which he was not certified.
Analysis of Safety Implications The senior inspector has been AWS certified since November 1979; part of this certification in Section 4,.Part F, on studwelding.
In addition to his AWS certification, he has been a certified Level II structural
-inspector since January 24, 1977. -This certification. included studwelding as it pertained to structural steel erection.
Based'on the senior inspector's prior experience and certifications, this deficiency would not have adversely affected the safe operation of the plant.
9.
Description of the Problem An inspector generate'd one prequalification studwelding inspection report (No.-S1016142) on September 14, 1981, one coatings inspection report (No.
S1017182) on October 26, 1981 and one application inspection report (No.
S1017181) on October 26, 1981, for which he was not certified.
Analysis of Safety Implications In the case of' Inspection Report No. S1016142, the inspector had received ten hours of on-the-job training and had been a certified Level II inspector in the'~ civil /structurai' discipline since November 10, 1980.
In addition,.the inspector had accumulated six years, eight months.
experience as an t'nspector/ technician for Pittsburgh Testing Laboratories
-infcivil/ structural,forwhicihe-wascertifiedLevelIinthat b
~ '
t m-.
t discipline in April 1979. Bastd on the inspector's exp;rience, his Level II certification in civil / structural, the nature of basic inspection attributes performed (equipment setup, stud cleanliness, operator qualification, base metal preparation, preproduction testing, preheat, arc shields and a bend test), this deficiency would not have adversely affected the safe operation of the plant.
In the case of Inspection Report No. 51017182, the coatings inspection report was a finish coat for beam ends which has the surface preparation record and the coatings record attached and cosigned by a certified Level II inspection supervisor for that inspection.
Ir.spection Report No. 51017181 was generated on the same day as the Inspection Report noted above and was an in-process inspection performed at the paint shop for miscellaneous electrical supports. Based on the type of inspections performed and the Inspector's Level II certification as an inspector in the civil / structural discipline, the deficiencies would not have adversely affected the safe operation of the plant.
- 10. Description of the Problem Four inspectors were identified as having performed storage inspections for which they were not certified. A total of six inspections were performed and documented as follows:
Inspector Inspection Report No.
Date Issued Inspector A P1009230 10/29/81 P1009279 11/16/81 Inspo-or B W1009312 11/25/81 W1009299 11/20/81 Inspector C M1009373 12/18/81 Inspector D M1009145 9/18/81 Analysis of Safety Implications Further evaluation of the certifications of the four individuals has revealed the following:
a.
Although Inspector A and Inspector B were not certified in storage inspections, both were certified as Level II inspectors in contract monitoring prior to the performance of the inspections. This certification allows the inspector to perform surveillance of contractors' work activities to ensure compliance to their quality assurance program and verify compliance to specification requirements.
b.
At the time of Inspector C's and Inspector D's inspections, they were certified as Level II and Level I, respectively, in the mechanical discipline, in which they were working. The inspections that were performed by both inspectors were of equipment / materials which would fall within their area of assigned responsibility for installation.
L
In' view cf the a'bove, it is our conclusion that the inspectors in question had. sufficient training and/or experience to perform their inspections and are considered qualified but not formally certified; therefore, this deficiency would not have adversely affected the safe operation of the plant.
- 11. Description of the Problem An-inspector performed inspections of stud welding operations for which he.was not certified. ThEse' inspections were documented in Inspection Report Nos. E2006689 and E200eou sa March 29 and January 16, 1982, respectively. _The work documented on these inspection reports could not be reinspected due to inaccessibility and was subsequently documented on Nonconformance and Disposition Reports Nos. 4969 and 5315.
1 Analysis of Safety Implications Both Nonconformance and Disposition Reports were dispositioned accept-as-is on the basis that the inspector was a certified ANSI Level II inspector.for AWS Dl.1 visual weld inspections and inspection of this work by Construction was also documented as satisfactory.
'Although_the inspector was not formally certified for the inspections performed, based on the above, this deficiency would not have adversely affected the safe operation of the plant.
.12. - Description of the Problem
.An inspector performed inspections (Nos. E2006058 and E2006078) dated February 19, 1982 of stud welding and support welds for which he was not certified.
Analysis of Safety Implications The work in question has since been reinspected by a certified
. inspector. Within the scope of the reinspections of the previous work, two inspection reports (Nos. 53043785 and S3043929) document satisfactory results. -0ne inspection report (No. S3043771) identified three unsatisfactory welds. An engineering evaluation has since determined that the welds would not have resulted-in an overstressing. The welds have been reworked. Therefore, it this problem were to have remained uncorrected, it would not have adversely affected the safe operation of the plant.
13a. Description of the Problem Two inspectors performed an equipment installation inspection (No.
E2009646) on September-16, 1982 for which they were not certified.
Analysis of Safety Implications The work was reinspected in February 1983 by a certified inspector and
.was found satisfactory. The inspections were documented on Inspection
. Reports Nos. E3005282, E3005289 and E3005359.
Although these two insp:ctors were not formally certified for the inspection performed, based on the reinspections, this deficiency would not have adversely affected the safe operation of the plant.
13b. Description of the Problem An inspector also performed one equipment installation inspection (No.
E2009474) on September 9, 1982 for which he was not certified. The report was cosigned by a certified Level II inspector.
Analysis of Safety Implications This work has since been reinspected by a properly certified inspector and has been found to be satisfactory. The reinspection results were documented on Inspection Report No. E3006485.
Although the inspector was not formally certified for the inspection, based on the reinspection, this deficiency would not have adversely affected the safe operation of the plant.
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