ML20127G172
| ML20127G172 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/15/1984 |
| From: | Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Crutchfield D NRC - WATERFORD 3 TASK FORCE |
| Shared Package | |
| ML20127B509 | List: |
| References | |
| FOIA-85-123 NUDOCS 8506250375 | |
| Download: ML20127G172 (8) | |
Text
_
- raco UNITED STATES ]
g ,g NUCLEAR REGULATORY COMMISSION S REGION 111
[ ,
, f e g CLEN ELLYN, ILUNOIS 60137 AUG 15 884 MEMORANDUM FOR: D. Crutchfield, Director, Waterford Task Force NRR FROM: J. J. Harrison, Chief, Section ID, DRP, Region III
SUBJECT:
WATERFORD TASK FORCE F0LLOWUP On August 8,1984, you requested I proceed to the Waterford Nuclear Plant in
-- Taft, Louisiana, to perform a review of the LP&L program being utilized to verify the QC inspector qualification issue and to specifically review the charge that unqualified personnel were performing these reviews. I visited the site and conducted this review on August 9 and 10, 1984. The attached trip report details my visit.
Should you have any questions or coments please feel free to contact me (FTS 388-5635). i 1
) -
[-hd J. J. Harrison, Chief Section ID, DRP
Attachment:
As stated cc w/ attach:
D. Eisenhut L. Constable FC /A -IS $3 8[9 8506250375 850411 PDR FOIA PDR BERNABE85-123
r NRC TRIP REPORT Docket No.: 50-382 Construction Permit No.: CPPR-103 Licensee: Louisiana Power & Light Company (LP&L) 142 Delaronde Street New Orleans, Louisiana 70174 ,
Facility Name: Waterford Steam Electric Station, Unit 3 Location: Taft, Louisiana Dates: August 9 and 10, 1984 Person Making Visit: J. J. Harrison, Chief, Section ID Division of Reactor Projects, Region III Principal Persons Contacted:
LP&L Mr. J. M. Cain, President and Chief Executive Officer Mr. T. Gerrets, Corporate Quality Assurance Manager Mr. C. J. Savona, Quality Assurance Representative Mr. D. Dobson, Project Manager Ebasco Mr. T. Cutrona, Quality Program Site Manager NRC Mr. W. Crossman, Chief, Reactor Projects Section B Mr. L. Constable, Senior Resident Inspector Other licensee and contractor personnel were also contacted during this trip.
Purpose:
The purpose of this visit was to review the program being utilized by LP&L to verify the QA/QC personnel qualifications, to review the qualifications of those performing this verification and to review the project plan and the qualifications of the third party performing an overview of the NRC Task Force findings.
i o
Summary: ;
The NRC visit included reviewing procedures, personnel training, personnel qualifications, preliminary verification results and interviewing key personnel. The LP&L program plan, with some adjustments, appears to be adequate to address the issues identified by the NRC QA Records Review Team as stated in the NRC letter to LP&L (D. Eisenhut to J. M. Cain) dated June 13, 1984. Some questions and concerns were identified relatiye to the NUS third party activity.
Results:
- 1. Procedure Review The following procedures were reviewed and comments provided to LP&L (actions had previously been initiated by LP&L to resolve these comments).
- a. LP&L Procedure OASP 19.12, Review of Contractor QA/QC Personnel cualification verification, Revision 1 dated August 4, 1984.
Section 5.2.1 stated that LP&L would review " selected" files, previously reviewed by Ebasco. This requirement is being changed to a 100% review by LP&L.
Section 5.2.2 stated that " reviews would be accomplished to an applicable acceptance critaria; ANSI Standards, Codes, and the contractors programs. This requirement is being changed to read
" accomplished to ANSI N45.2.6-1973" as some contractors programs did not meet the 1973 standard.
- b. Ebasco Procedure QAI No. 32, Instructions for Verification of QA/QC Personnel Qualifications, Revision 2 dated July 24, 1984.
Section 6.2 stated that the team members would prepare an " acceptance criteria" for each category of QA or QC personnel based on the
" contractors contractual commitments and Quality Assurance Program requirements." This requirement needs to be changed to reflect the licensee's commitment to ANSI N45.2.6-1973. Also stated is "other factors provide reasonable assurance that a person can competently perform a particular task, it should be noted in the individual's file." This needs to be changed to read "shall be documented" making this review basis mandatory. This problem of lack of documentation was one of the causes that originated the initial issue identified by the NRC Task Force.
- 2. Overall QA/QC Personnel Verification Program Review The licensee has assigned Ebasco the responsibility of verifying the back-grounds (education and experience) of all contractor personnel and reviewing the qualifications for all QA/QC personnel that worked at the Waterford site (this is a preliminary review). LP&L will perform a verification of all LP&L and Ebasco QA/QC personnel backgrounds and will sample the back-ground verifications performed by Ebasco.
2
LP&L plans to review the qualifications for all QA/QC personnel that per-formed any quality related activities on safety-related systems at the Waterford site. Additionally the LP&L QA Audit Group will be performing independent audits of the verification program. LP&L has also contracted with the NUS Corporation to perform an independent third party overview of this effort.
LP&L is currently developing procedures to address the QC reipspection program for those QC inspectors identified as having inadequate qualifica-tions.
The program as reviewed appears to be adequate and is being properly managed. The Ebasco verification effort is well underway (90% complete) and the LP&L effort just beginning.
- 3. Personnel Qualifications of the Verification Team
_ The qualifications for personnel performing the QA/QC inspector verifica-tions is essentially the same as those of a " Records Reviewer." The Regula-tory Guides and ANSI Standards do not require an individual to be certified to perfom this type of a task. The basic requirements necessary to per-form this task include appropriate and related QA/QC experience, knowledge of ANSI N45.2.6, procedures to accomplish this task and the necessary training to assure adequate and consistent performance.
Three Ebasco individuals were singled out as having questionable qualifica-tions. A review of their personnel files revealed each was previously assigned as a " Records Reviewer", all had related QA experience ranging from 2 to 15 years, all had nuclear experience ranging from 5 to 16 years, and all three had been trained to the applicable procedures and ANSI Standard (N45.2.6-1973).
It is also key to note that the Ebasco effort is a preliminary review function to identify QA/QC personnel qualification problems, if any, perform background checks, and compile the QA/QC personnel data into individual packages. These packages are then forwarded to LP&L where the final review for acceptance or rejection, including the determination for any necessary reinspection, will be performed. Attached are an organiza-tion chart and a flow chart of the QA/QC inspector verification process.
Several individuals performing the various verification and background checks and the qualification reviews for LP&L and Ebasco were interviewed as to the actual procedure they were implementing. All were knosledgeable of procedural requirements and the documentation being generated appeared to be adequate. The process appears to be working very well.
- 4. Independent Third Party Review During this visit the third party effort of the NUS Corporation was also reviewed to determine if this program was adequate. Included in the review was their scope of work, personnel qualifications, independence, and the work controlling Project Plan. This review effort was not completed 3
during this visit. Some concerns and questions did, however, evolve.
These issues need immediate attention by LP&L and NUS:
What criteria was utilized to establish independence?
. What protocol is being utilized to assure independence is naintained?
. The Project Plan or procedures were not available at the site, although the review has been underway for some time.
. An organizational chart to denote responsibilities and assign-ments within NUS was not available on site. This was needed to verify the individual qualifications versus their respective assignments.
. The resumes of all NUS personnel were not available on site or at LP&L corporate offices thus creating the appearance that
~
LP&L has not verified the qualifications of those individuals involved at Waterford.
. NUS is performing hardware inspections utilizing their own inspection personnel. Evidence of qualifications and certifica-tion of these individuals was not available on site.
. . NUS is performing inspections utilizing LP&L procedures. Is this acceptable? Is this part of their Project Plan? Were their personnel trained to these procedures?
. NUS is currently in the process of developing a sampling plan to overview the various issues identified by the NRC Task Force. Is this part of the Project Plan? What is the basis for the sampling plan? How will acceptance / rejection be determined?
These issues need to be resolved to assure the NUS effort will be meaning-ful, be able to stand alone, be totally independent, was performed by com-petent individuals, cannot be compromised, and will be above reproach.
- 5. Meeting On August 10, 1984, a meeting was held between the NRC and LP&L-to discuss the LP&L response to the NRC Task Force issues identified in the letter of June 13, 1984. The topics of discussion evolved around the issues identi-fied by the QA Records Review Team, with the thrust of the meeting directed toward item 1, the QC inspector qualification issue. Meeting participants were as follows:
J. M. Cain, President and Chief Executive Officer, LP&L T. Gerrets, Corporate Quality Assurance Manager, LP&L D. Crutchfield, Director, Waterford Task Force, NRC (telecon)
L. Lazo, Technical Assistant, NRC (telecon)
L. Constable, Senior Resident Inspector, NRC J. Harrison, QA Records Review Team Leader, NRC 4
- 6. Conclusion It appears that the LP&L plan to resolve the QC inspector qualification issue is sound and is being properly implemented. The efforts pertaining to the other issues identified by the NRC QA Records Review Team appear to likewise be on course to satisfy the requirements of the Eisenhut letter.
The issues pertaining to the independent third party need to be resolved by LP&L as soon as possible to assure that the NUS effort will be totally independent and provide unquestionable results. I suggest that my team and the other teams continually monitor the LP&L plan, its implementation and the developing product in the early, middle, and latter stages to assure the final product is one we can accept in the end.
Attachments: As stated 5
Y :h ,
- i yhi '
.g d+ $' $, LPE. WCANIZATION 1. : ,*..~ , ~-L* d ,f . -2 ,' ,,:
b'L.; ..
'w .- .,a
, y R. % :1 Vi .m j COIIIRACIOR g;i QA/QC VERIFICATI0lt FilOJECT ,;/ -
. e
< ubL corp.
.'I.*i, QA Manager J r.' .
+.&,
r 1 >, '
i4 ..- '* (T. F. Cerrets) *-
Lr6L Review ~i i Board -
- .,rp.
LF6L QA
$<curity e Unacceptable packages Proj. Coord. "~~~~~~~~~~ (E. Beckendorf) e Indeterminate packages (C.J. Savona) (E.T. Fond) e Group determinations ,
e Group recommendations
. g LF6L QA
- g Rev. Coord. g
. , clerical (R. Dube) g o Status .g o Filing , g o Typing g o copying g I
I
- . g Lr6L qA 1. Directs reviews LFE QA LrbL Backgtouted Review Group 2. Determination of Follow-up Coord. BIV Coord. Investi gat. lon Leader follow up action (S.C. retty) (F. Baron) Agency (M.W. Johnson) 3. Interface with (P. E rover) other groupe 1. Coordinite/ interface 1. Review IVR's for with Ibasco Completeness e Investigative
- a. Obtain additional 2. Transmit /Rev. ICR's Pool I I information with Investigators Ir6L QA 'o NRC identified e All other Lrth qA b. Obtain clarification 3. Maintain status Special personnel QA/QC pers. Review Group e. Perform trend 4. Coordinate with Review Croup e Ebesco QA/QC reviews 2. Provide logistical Review Croups personnel . support to review 2
e Special reviews groups i
m
- 1. Perform final reviews
- 2. Provide technical support
- 3. Request followup action
- 4. Complete IVR Ebw e ' i, Qeanw cwo e ,
pv dma a * *-i.l <,
t e vistiscr A d i
F 1 , ,
8 -
Et)oau ,
4 6ergq..s a ,
h .w.aaA.-
jt i
. i ; -
' I
, 1 e
l b
r a e t -
ge p av , e nin t , c Lat o n , c
& Mci omt e wd A P
Lt rc et crcm soas h Ler
&i a L ,
crA af ps P vo e, eo b rme LeB jC E eI s , R t:f o P s ,
r A P .
e :],[ . , ;
l b \s a ' s . '
t l s
p
- Jf e ,
g c -
' c _ .- ,
a ,.
i n , ;:, h U
.,,j
- Il .l .['I pfj '
- .l
N O p: . = '
I i
' y, .!
T ~. ,. ' .q A i C '
}q' I ,
F I
R T E RE V r - OC f PA
'L&QC ER ,,
RO j
P/ p T
LA YS u R/.I Q - AE R
w o f ML O l MI T l J UF C o S .
A F R 5l T
N
.. . .[: .f O .
.}
C -
' e ;f.
. ' I
!I ,; ,t.1 ' : l ,f i o +
n N o
di ,
nt ua og ;
ri .
gt ,
e k s l s ce w b e .
av Le
&i a Y ,
B n t I P v p Le e -
R . c .; ,
f c
i A
?
_~
g s e n e g
i m a o k c c n a
- I P