ML20134A636

Informs of Allegation Received by B Little on 850205 from QC Level III Electrical Inspector Re QC Supervisor Failing to Follow Procedure QCP-ZZ-01001 in Certification of Level III Personnel.Info Deleted.Related Info Encl

ML20134A636
Person / Time
Site:	Callaway
Issue date:	10/22/1985
From:	Patricia Pelke NRC
To:	Weil C NRC
Shared Package
ML20134A622	List: IR 05000483/1985002 ML20134A620 ML20134A628 ML20134A632 ML20134A636
References
FOIA-85-655 NUDOCS 8511070456
Download: ML20134A636 (79)

Text

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NENORAMDUM FOR: C.H. WeiI FROM: P.R. P e l ic e , Project Inspeefor

SUBJECT:

CALLAWAY ALLEGATION On Februar y 5, 1905, Bruce Little rect ived an allegation from "~

Level III el ec trical t r. t p ec. tor .

lH S name is) s ated that the DC super vi sor failed to fol l ow p rocedur e QC P - ZZ -

01001 in the cer ti ficat.i on of Level III personnet. The supereisec

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. f ai l ed to subaiL the l e t ter of cer ts fi ca tion to a corre nt III for arproval. Two ex 4mpi e s toere g s ven who ch app e a r to be f ac tual .

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COSCQ f'-4 3 March 10, 19 F '.

To: S.L. Bode J.S. Diluvio J.A. Smith R.A. Barnes R.L. Brummet H.L. Holman D.U. Peters V.P. Pcrtell K.M. Robson J.M. Speek J.L. Pearson R.D. Swank D.S. Turley J.G. Carrigan M.J. Eelcher W.R. Vandelcecht C.A. Uudtke R.L. Pflueger J.A. Ulltsn P.L. Herring R.L. Dudicy T.V. Ridder T.E. Ccines 5.L. Brewer C.P. L urie W.D. Battle J.D. Guynn E.D. Yockey R.L. Nave L.M. Zahara

Subject:

Effective Connunication In past weeks, there have been nurerous instances demonstrating a lack of effective cen=unication within the O.C. Departrent. In -

addit ica, there have been instances where connunicatica out of the departnent has been less than effective. On some occasions , the re have been tvo or three parallel paths of ceanunication in which somet ites dificrent resolutions were reached. This is not only confusing, but ccunter productive.

r In cy le:ter COECQ E4-23, I stated that "t.11 merorandu.s. ictters cnd cther cerresronden:e with :: ups, de::r:re.ts or in.;viceals other than Q.C. ru=: te sitncd :y re or L.':. ::ht.ra, sr.d sr.culd be initialed by each ci the superviser personnel through v'.iich they rep: t to ':r. Zahara". We cust have stric: adhcrcnce t: :his polic-;

to clininate future cenzunicarica proolens.

I reald likc ta take the cpportunity to state, ence again, that it is rv policy, as well as that of U.E. cann:crent, to r.sintain gn coc- do r f r conru.icarica d ir ec ti:. with 0.C. supervi- crs , as we' l Sr. i:atie ..:n2:cecn: p e r s e nr.e1. To this vr:. I ask u. : you brir:

pret;ers c: rec t l:. to vaur next line of sur r. 2 sion (i.e. R.L. Nave

,or L.". ~.ahara as apprcpriate). If a s tist cier:. soittien c.nnet he reechcd at ths: Isvel thcn bring it t: :- Jirec: :::cn icn of the next supcivisor:. level. Our sin is :c ::: ve preth r a : ' . r c u r.1 connunica t ion, nc t create ther. I wouie -:-c : ke to 3:' that m" dosr is always open if "ou thir.k veu nac d :O ;cne dircctl. to e becausc of the na:ure of the p rob l e.: If a resciution c;nnot he reacl.ed at ry level,1 vili arrance for y ur eeting with the next l'evel of canagenent to persue the problen.

E.

n, Per r.uit of Ouality Related Problens: Tren time to time, a qualitv related probler. cay not be resolved in a way that is immediately acceptable to you as an inspecter. In those cases, you are obli;ated to bring those concerns to your supervisor. When it has reached my level, you have fulfilled your procedural requirement as a Q.C. Inspector. You should never feel that you have the full weight of Quality en your shoulders.

Ultimately, Quality decisier.s may be made at ey level or higher. You should have confidence that management is concerned and conpetent to ~~

pursue the issues that you have raised.

In additien, to those points already stressed I would like to add the following requirement. On at least a dail: basis, your In Sasket must be cocpletely gone thrcugh and enptied. In sone cases, material has been put in an unintentional state of indefinite held after being placed in an individual's in basket.

We have cone a long way in the past 6 months, but we still have a lcng way to go. Keep up the good work.

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TI.s/j p cc: P.T. Appleby J.E. Davis ZCiU0SCQ G57.72 s

L'05CQ 84-23 l'ebruary 18,19s4 To: All QC Fersonnel Ornanizational Responsibilit.ics The attached organization chart provides further definitien of many of the currently existing personnel responsibilities. Sc: :

changes have been made..which should enhance our ability to deal vith the many new demands and challenges we are currently facine.

Your attention,is directed to the fo]Iowing changes and realign:ents.

1. Three clerk positions have been added. Two of these cierks vill report to Mr. R. L. Ua e for all reutine catters. Anyone requiring clerical services should coordinate their require:.ents with Mr. Nave, or at a ninitun, assure that he is cognizant of all work re-quested of these clerks.

2. Jean Poeschel vill retain responsibility for overall administrative clerical functions, but will eventually

,e ; be relieved of cost routine discipline-related clerical tasks by the two clerks assigned to Mr. Nave.

3. Mr. L. M. Zahara will begin working more clasely with me, so as to reinforce our capacity for addresting the myraid interfacing requirerents with other departments.

In'o,rder to " free-up" Mr. Zahara, most of his currently assigne,d routine administrative responsibilities will be reassigned to Mr. Nave, as indicared in the attached chart.

4. "Cail-ins"forillnessoroccasionalrequirementefor time off should generally be coordinated through first-line supervisory personnel (Icads or assistant supervi-scrs), who will keep Mr. Zahara advised of these .stters.

All such time eff cust be docunented by neans of a three-part ecmorandum to the first line assistant supervisor to whom they report (e.g., electrical, ecchanical and VT personnel report to Mr. Nave; receiving and NDE personnel to Mr. Zahara) . This

• remorandum nust be retained by the assistant sucervisor who will utilize it in verif ying tir.c sheets and over-all trending.

5. If first Icvel supervisory perronnel are unavailable for illness call-ins, t he cal le r :.ud . atteupt to

contact the next highest level of supervision in succession. If af ter completing t his effort I have not been cont acted, one of the persons listed below, outside of the caller's discipline, nust. be contacted.

R. L. Save S. L. Bode J. M. Speck J. S. Diluvio J. L. Pearson V. portell Call-ins to any other individual is not an acceptable way of reporting illnesses. The person accepting the call shall document the call on a three-part nenorandum to the apprepriate assistar.t supervisor, for record purposes. In addition to this ree,uirement, Mr. L. M.

Zahara shall be pro:ptly informed either verbally or in writing of all unscheduled absences.

6. Vacation requests should also be coordinated with first line supervisory personnel, who will review work load and other pertinent requirements and initial the re-quest to provide preliminary approval of the request.

The lead and/or supervisor will coordinate with me or Mr. Zahara to obtain final approval of all vacation requests. First line supervisor.= will not approve vacations which may limit the group's ability to address known requirenents.or those which might have been reasonably anticipated to be requirenents during the vacation period. Approved vacations will not be cancelled by supervisor except where an absence constitutes an unacceptable burden on other personnel.

Vacations which are veluntarily cancelled and re-scheduled are again subject to the censiderations stated above.

7. All recorandun:s, letters and other correspondence with groups, departtents, or individuals other than QC, must be signed by me or L. M. Zahara, and should be initialed by each of the supervisory personnel through which they report to Mr. Zahara, as shown on the attached chart.

V. portell should receive a copy of all correspendence which is of other than administrative or personal nature.

i Your careful attention to the itens discussed above should cr nce our ability to function as the cohesive unit that QC should be. $1. .w '. d you have any questiens regardint this organization. }ylcase refer tha-to V. Porte11. - ,

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cc: T. L. Shaw L. M. Zahara V. Portell J. Poeschel R. L. Nave J. L. Pearson S. L. Bode J. M. Speck R. D. Swank J. S. DiLuvio R. Robson H. Holman J. G. Garrigan J. A. Smith P. E. Herring C. A. Wudtke T. E. Gaines R. A. Barnes D. W. Peters B. D. Yockey D. S. Turley W. Vandeloecht J. Ullman T. Ridder M. Belcher R. Pflueger N. Brewer C. Laurie R. Dudley J. Guymn R. L. Bru=ct

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Y REQUEST FOR CORRECTIVE ACTION hM Form N-67(4-84)

1. IDENTIFIC ATION F8502-035 Rev. O L,y,g; 1 lssue Date: 02/22/35 Pa ge 1 of .2_

adumber and Revision:

P. T. Appleby

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PTAOC To: Organization: Org:

00scription of Condition: (44 characters) QC Inspectors Don't Have Needed Experience

2. DETAILED DESCRIPTION OF CONDITION:Recommended (Requirement vs. Deficiency; include Originator Action if appropriate.)

I SNUPPS-C FSAR Chapter 3A states in part, under Regulatory Guide 1.58 that "The the qualification of UE QC personnel or contracted QC personnel performing work at plant shall be in accordance with Regulatory Guide 1.58 (ANSI N45.2.5-1978)."

The next paragraph under Regulatory Guide 1.58 states in part, that "In instances where the education and experience recommendations of ANSI N45.2.6-1978 are not met by QC personnel, UE will demonstrate by documented results of written examinations and evaluations of actual work proficiency that these individual possess comparable or equivalent competence."

Ssction 3.2 of ANSI N45.2.6-1978 requires in part that "A Level I person shall be capable of perfor=ing the inspections, examinations, and tests that are required to bo performed . . . and shall be familiar with the tools and equipment employed and shall demonstrated proficiency in their use."

Ssetion 3.3 of ANSI N45.2.6-1978 requires: "A Level 11 person shall have all of the capcbilities of a Level I person for the inspection, exami*iation or test category or class in question. Additionally, a Level 11 person shall have demon-strated capabilities in planning inspection., examinations, and tests; in setting up tests including preparation and set-up of related equipment, as appropriate; in eupervising or maintaining surveillance over the inspections, examinations, and tests; in supervising and certifying lower level personnel; in reporting inspec-tion, examination, and testing results; and in evaluating the validity and accept-ability of inspection, examination, and test results."

(Continued)

T. L. Shaw. P. T. Appleby, J. E. Davis Th3 concern (s) identifiec by this RCA was discussed with 2/15/85 and S. E. Miltenberger Cn .

Surveillance Report No.: 850209

, Condition Noted in:

R2sconse Due Date: /NI4 ' Ef $ W'# E A " *nW 'r'W h b N Yn/W Suoervising Engineer. Da'te

~

RC A ldstiator. Date

3. EVALUATION OF CORR. ACT.: 4. VERIFIC ATION OF CORR. ACT. 5. RC A CLOSED:

R3sponse: CliC Accepted Imple me nt a tion: CD Complete

$* CZ Rejected [] incomplete Suoervising Engr. Date E 6A 4 - / -FC 0 TR 3 RC A Initiator Date RC A Initiator Date oy oc y yy

7. DISTRIBUTICN: 8. R EM AR KS:

AD5RCA (QA Record) AD5RCA (File) ,

FDF. RLP, JVI', JRV, WZ, CSP', k'AI TLS, JEDI SEM, WR (Action), DFS Y l Tss'S '

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• RCA P8502-035, Rev. O Page 2 of 3 Section 3.4 of ANSI N45.2.6-1978 requires that, "A Level III person shall have all of the capabilities of a Level II and Level I person for

' the inspection, examination or test category or class in question. In addition, the individual shall also be capable of evaluating the adequa-cy of specific progra=s used to train and test inspection, examination, .

i and test personnel whose qualifications are covered by this Standard."

I Sections 3.5.1 and 3.5.2 of ANSI N45.2.6-1978 then list the recommended education and experience for, respectively, Level II and Level III personnel.

Contrary to the above, based on a review of available documentation and interviews with the individuals, the following personnel did net meet the experience require =ents specified for their educational ba:kground, and certification level nor had they received a documented evaluation of actual work proficiency in lieu of such experience. In the case of the Level III individual, based on interviews with the man, he also did not have all of the capabilities of a Level II person as defined by the current UENO program in either the Civil or Electrical discip'ines. . He did not have experience ir planning and setting up certain civil tests and electrical inspections, nor in the reporting of certain civil tests and electrical inspection, nor in evaluating the validity of the results of certain civil tests and electrical inspections. The Level III also did not have all of the capabilities of a Level I person in that he had not demonstrated proficiency in the use of the tooYs required to perform all civil tests or electrical inspections covered by the current UENO QC program.

R. A. Barnes, Level II Mechanical R. A. Barnes, Level II Electrical R. L. Bru==et, Level II Mechanical J. L. Pearson, Level II Electrical i

D. W. Peters, Level II Electrical D. W. Peters, level 11 Civil V. P. Portell, Level III Civil V. P. Portell, Level III Electrical

! R. D. Swank, level II Electrical i

! L. M. Zahara, Level II Electrical i

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RCA P8502-035, Rev. O Page 3 of 3 Recom= ended Remedial Action (s):

I At this time, although others may be available, QA can anticipate only

.one or a combinations of the following six courses of action as accept-able ccrrective action to make the above listed certifications valid. .

Options:

{,

1. L'ithdraw the current certification (s) until full capability is

achieved and verified.

2. .v.:dify the current certification (s) (i.e. delimit, list tasks certified to perform) to reflect individual capabilities.

3. Redefine current program i

1 a. To list items that a particular cerrification means that a l

person can perform certain tasks (same as 2, but in program).

b. Go to a "VT" type program where we do not certify by disci-pline. ,

4. Provide additional information which would support current cert (s).

5. Eave a non-questioned Level 111 certify the men in question and l, provide the required documentation.

6. C

nduct a perforcance demonstration to " prove" ability to perform all inspection for which man is currently certified.

An evaluation of the impact on the plant of non-certifiable personnel perfor=ing inspection / assessment activities must also be provided to i complete corrective action on this RCA.

j If further review of actual inspection activity or other pertinent

• inferrat 8 is obtained which indicates plant impact is negligible. QA

{ will consider a reduction in the level of this RCA to level 2.

1 4

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2 RESPONSE TO REQUEST FOR CORRECTIVE ACTION Forrn N-87(184)

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• P8502-035, Rev. O Level: 1 P a g e .J. of .1.

hknnber and Revision:

Th3 response to the referenced 'Recuest for Corrective Action' is provided below for your evaluation and verification. The response includes three parts in the following order: A. Cause of Condition; B. Action Taken to Resolve Problem; and C. Action Taken to Prevent Recurrence.

A. CAUSE OF CONDITION This condition was apparently caused by a more strict interpretation of the standard at the time the RCA was generated than was used during the preparation, review and approval process for the procedures. The amount of detail from the standard required to be reproduced in the procedure apparently has also undergone a similar interpretation change over this same time period, thus centributing to the cause of this condition.

B. ACTION TAKEN TO RESOLVE PROBLEM QA Surveillance Report S50209A vill provide a detailed accounting of the action taken, presently underway or planned for the near future associated with resolving the concerns of this RCA.

C. ACTION TAKEN TO PREVENT RECURRENCE To prevent recurrence of the concerns similar to those identified in this RCA, the QC Inspection, Training, and' Certification Programs vill be reviewed and revised or developed as aparopriate following a sequence / outline similar to the following:

1. Perform a task analysis for each arca of t'ae Inspection Program to identify what inspection activities will be performed.

2. Determine which inspection activities vill require inspection procedures (so=e of the simpler ones eay not actually recuire a procedure - inspector qualificatiens and training vill suffice).

3. Prepare the required procedures (Part of the Inspection Program).

4 Develop the required training plans and tests, and the proficiency de=onstrations, including example hardware as appropriate. (Part of the Training Program.)

5. Develop the recuired procedural controls to outline the contents of the documentation package that vill be required to support a certification. This will contain or reference documentation relative to education, experience, training, (This is considered

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testing, and proficiency de=onstrations.

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• to be the initial certification portion of the overall Certification Program.)

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b G'ERhhC..c Effective Date: see page 2 of 2 see page 2 of 2 Addressee. Date

e RESPONSE TO REQUEST FOR CORRECTIVE ACTION Form N 87(1-8M

.L P850?-035. m o toy,q: 1 p a g ,,2,gy ,,;,

Numb:r and Revision: _

The r:sponse to the referenced ' Request for Corrective Action

• is provided below for your evaluation and v;rification. The response includes three parts in the following order: A. Cause of Condition; B. Action Taken to Resolve Problem; and C. Action Taken to Prevent Recurrence.

6. Develop the required precedural controls to support evaluation and recertification of individual certifications.

This should include, as appropriate, elecents allowing for retraining, proficiency demonstrations, and documentation of actual inspection activities previously perforced. (This would need to be part of all three programs.) ,

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Effective Date: 12-31-85 _

3Ob 1A Addeeshee, Date( ) /

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REQUEST FOR CORRECTIVE ACTION

{I 1. IDENTIFICATION Form N-6 7(4 sa' j

Number and Revision: P8502-039. Rev. O 2 t , y ,g.

issue Date: 02/22/85 Pa ge 1 o f .2_ ,

I To: P. T. Appleby Organization: UENO-QC Org: PTAOC D';scription of Condition: (44 characters) Cert / Qual Procram Deficiencies

2. DETAILED DESCRIPTION OF CONDITION: (Recuirement vs. Deficiency; include Origmator Recommended Action if appropriate.) j

1) The Operating Quality Assurance Program (OQAP), as described in the SNCPPS-C F5AR, .

Rev. 7. Section 17.2.5, states in part: "The OQAP shall contrcl activities l affecting quality by providing measures for: .. 2) provisions for the inclusion I in these documents of quantitative and qualitative acceptance criteria for l verifying that an activity has been satisfactorily accomplished; ..."

Contrary to the above, the UENO-QC certification / qualification program for Non-NDE inspectors does not provide qualitative or quantitative acceptance criteria to determine what part or portion of a person's past work experience may be " counted" when determining if the experience and education requirements of ANSI N!.5.2.6-1978 are met. This program is described in procedures OCP-ZZ-01001, Rev. 2 and QCP-ZZ-01002, Rev. 2.

Additionally, the UENO-QC qualification / certification progra= for Non-NDE inspectors does not provide quantitative or qualitative acceptance criteria for what is required in a "docu=ented evaluation of actual wcfrk proficiency".

2) ANSI N45.2.6-1978, Paragraph 2.1.2, states in part: "The need for formal training programs shall be determined, and such training activities shall be conducted as required to qualify personnel who perform inspections, examinations, and tests.

On-the-job participation shall also be included in the program, with emphasis on first-hand experience gained through actual performance of inspections, examinations, and tests. Records of training, when used as the basis for certification, shall be maintained."

(continued)

Th9 concern (s) identified by this RC A was discussed with T. L. Shaw, P. T. Appleby and Cn 2/15/85 . J. E. Davis Condition Noted in: cerveill ece Recort No.- 850209 Resconse Due Date: /SkdAf - W M M ft' d' !"L W Y]ld dk Y //!/PS~

" RC A initia tor. Date Suoervesmo Engineer. Date

3. EVALUATION OF CORR. ACT.- 4. VERIFIC ATION OF COR A. ACT. 5. RCA CLOSED:

R3sponse: C I' Accepted imple me nt a tion: CJ Complete C3-'ReQcted [] incomplete Sucervismg Engr. Date

/p g[. '3'

6. RETRIEVABILITY CCDE:

RC A Initiator Date RCA initiator Date 02 QC 33 26

7. OtSTRIBUTION: 8. REMARKS: n g/

AD$RCA (QA Record) ADSRCA'(File),

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• RCA P8502-039. Rav. O Pcge 3 of 3 l

l The UENO-QC program for certification / qualification of Non-NDE QC Inspectors defines "QC Level I", "QC Level II", and "QC Level III" personnel. These definitions do not contain all of the capabilities listed in the standard for each~ level of capability.

Additional definition or qualification requirements which would .

assure that the minimum capabilities, per the standard, are met by inspector candidates are not further specified in the UENO QC program. Also, the UENO-QC program, via the definitions of the levels of inspectors, implies, but does not require, that- an individual should meet the requirements of that level of inspector. This program should be clarified to assure conformance with the ANSI standard.

O

o O s RESPONSE TO REQUEST FOR CORRECTIVE ACTION Fonn N 87(184)

P8502-030 Rev. O Level: 2 Page.Lof 2 Numb:r and Revision.

The rcsponse to the referenced 'Recuest for Corrective Action

• is provided below for your evaluation and verification. The response includes three parts in the following order: A. Cause of Condition; B. Action Taken to Resolve Problern; and C. Action Taken to Prevent Recurrenct c. s. . C

- .* f 2 \,/ w

-.. p A. CAUSE OF CONDITION CW_.AW AY PLxMT This condition was apparently caused by a more strict int e r'p'rCEist4nCN5 of the standard at the time the RCA was generated than was used during the preparation, review and approval process for the procedures. The amount of detail from the standard required to be f reproduced in the procedure apparently has also undergone a similar interpretation change over this same time period, thus centributing to the cause of this condition.

E. ACTION TAKEN TO RESOLVE PROBLEM QCP-ZZ-01001 Rev. 3 and QCP-ZZ-01002 Rev 3 were issued on 3-6-85 to address the concerns numbered 4 and 5 in the RCA. The second item of concern within concern number 3 dealing with initial certifi-cation documentation for the case where the individual does not meet the initial education and experience requirements has also been addressed by these revisions. The concerns identified in concern numbers I and 2 and the first concern of number 3 have not been addressed in these revisions and vill be addressed only from the standpoint of preventing recurience as described in section 3 below.

C. ACTION TAKEN TO PREVENT RECURRENCE The following is a su= mary of the action that either has been or vill be taken to address the concerns of this RCA:

1. OCP-ZZ-01002 vill be revised to provide a " guidance only" definitien of related experience. It will clearly indicate that the amount of previous experience which is considered "related" is subjective and within the judgment of whoever is recom=ending

! and certifying the inspector. ANSI N45.2.6-1978 and Reg.

Guide 1.58 do not clearly define related experience in apparent recognition that it is a subjective determination to be made on a case-by-case basis. Therefore, the intent of this procedure revision is only to provide some guidance and is in no way to be construed to be an absolute requirement or even a minimum requirement. The final determination rests with the certifying individual's judgment. QCP-ZZ-01001 vill be revised to better describe the documentation requirements relative to the evaluation of proficiency documentations used in lieu of or as part of the related work experience.

2. QCP-ZZ-01002 vill be revised to provide better guidance relative to when training vill be required relative to initial certification and recertification. This will be coordinated with the revision described in item (1) above since it will be see nace 2 of 2 See page 2 of 2 Effective Date:-

Addressee. Date

m_

P RESPONSE TO REQUEST FOR CORRECTIVE ACTION Forrn N 87(184) k _ [.,_ I P8502-030 Rev. o (,y,i: y pag 3 ,,;,gg ;

Nurnb:r and Revision:

The r:sponse to the referenced ' Request for Corrective Action' is provided below for your evaluation and verification.

The response includes three parts in the following order: A. Cause of Condition; B. Action Taken to Resolve Problern; and C. Action Taken to Prevent Recurrence.

related to the amount of previous experience for which the individual to be certified can be given credit. This revision vill also better describe the documentation requirements relative to how the training documentation vill be traceable to or part of the cettification packages.

3. Again OCP-ZZ-01002 vill be revised in conjunction with the revision described in item (1) above to provide guidance relative to initial capabilities of a first-time candidate for certification. Again this will only be guidance since it is a subjective decision by the certifying individual. The revision to QCP-Z2-01001 vill address the concern associated with documentation of the basis 'ar certification when the individual does not meet the initial education and experience (based upon the results of the subjective related experience determination) requirements.

4 QCP-ZZ-01001 Rev. 3 section 4.4.1 was issued on 3-6-85 to resolve this concern. This change is considered adequate to e

resolve this concern.

$. QCP-ZZ-01002 Rev. 3 sections 2.1, 2.2, and 2.3 was issued on 3-6-85 to resolve the concern relative to the capabilities listed in ASSI N45.2.6-1978. In the same revision sections 4.1 4.2 and 4.3 were revised to make the capabilities described in sections 2.1, 2.2, and 2.3, respectively, part of the qualification requirements. These changes are considered adequate to resolve the concerns of this item.

It should be recognized that the above discussion addresses specific procedures which vill contain various specific pieces of the pregram to resolve various concerns. A revision of this magnitude and the fact that QCP-ZZ-01001 also addresses the ASME and SNT certification programs, could result in an overall restructuring of the four procedures involved. A definite possibility presently exists to have only three procedures, one for ANSI, ASME and SNT and thus move the QCP-ZZ-01001 requirements, as appropriate, into each program procedure. If this occurs, the intent of the above described changes vill still be followed, however the procedure numbers and pessibly the section' numbers within those procedures may no 1cnger be accurate. If this restructuring does occur, this RRCA vill not be revised to provide another point-by-point accounting of the concerns versus the changes based upon the fact that the intent of the changes will still be incorporated into the program.

Effective Date: 4-30-85 is vc @ bAAl MitTf Addressek, Date (J

s REQUEST FOR CORRECTIVE ACTION

• 2%' Form N-67(4+8 4)

1. IDENTIFICATION P8502-03'.. Rev. O Loy,i: 3 issue Date: 02/22/85 Page 1 of.2 Number and Revision:

P. T. Applebv Organization: (IENO-0C Org: PTAOC Tc:

0:scription of Condition: (44 characters) Insufficient Records to Support OC Certs

2. OETAILED DESCRIPTION OF CONDITION: (Requirement vs. Deficiency; include Originator Recommended Action if appropriate.)

The accepted QA Progra requires, in FSAR Section 17.2.17, paragraph 3. Rev. 8, that quality assurance records include documentary evidence related to i qualifications of personnel. l Ccntrary to the above, insufficient records were available to support the certifi-ccticns of the following individuals at the Level indicated:

R. A. Barnes, Level III Receipt J. M. Speek, Level II Mechanical D. S. Turley, Level 11 Mechanical L. M. Zahara, Level 111 Receipt The specific records needed were developed during interviews with the above indi-viduals. During these interviews the personnel orally listedrexperience which, if docu=ented and accurate, would fulfill the requirements of ANSI N45.2.6-1978 for certification at the listed Level of capability in the listed disciplines. The list of docu=ents which must be added to the certification filk or otherwise added Gs QA records to support their certification are listed on the attachment to this RCA.

(Continued)

T. L. Shaw, J. E. Davis and Th3 concern (s) identified by this RCA was discussed with en 2/15/85 .

P. T. Appleby Surveillance Report No.: 850209 Cencition Ncted in:

Response Due Date: /M4 M / /ze e / r< " '

?N#MA1s .* />~//

RC A Initiator. Date Suoervising Engineer. Date

3. EVALUATION OF CORR ACT.: 4. VERIFIC ATION OF CORR. ACT. 5. RC A CLOSED:

Response: E"I Accepted implementation: Complete C Rejected O Incomplete Suoervising Engr. Date

,- Y 6. RETRIEVAEILITY CCCE:

x Hyr 24xa s R D 22 RC A initiatir Date RC A initiator Date

7. DISTRIBUTICN: 8. REMARKS:

AD5RCA (QA Record), AD5RCA'(File I, TDF, RLP', JVL', JRV, WHZ, CSP, WAL ',

JED', TLS', WRR'(Action), SEM' 6

v. .

s4 R1v. O

' RCA P8502-034 Pcg2 2 of 2 CERTIFICATION DOCUMENTATION REQUIRED NAME Barnes, R. A. Receipt-3; Provide additional details of experience in receipt activities at DIC, including the percentage of, time in these activities. Provide the same information for the receipt activities at Morrison-Knudsen.

Speek, J. M. Mechanical-2; Provide details of mechanical related work while in the Navy.

These details should include what is required for an individual to become a U.S. Navy QA Supervisor at the Pearl harbor Submarine Base.

Turley, D. S. Mechanical-2; Provide details of mechanical related work experience in the Navy and at Callaway.

Zahara, L. M. Receipt-3; Provide documentation of previous certification in receipt activities for previous employers. Also provide more details of experience in receipt at UE and other compa-nies.

~

coa in . RESPONSE TO REQUEST FOR CORRECTIVE ACTION Form N 87(184)

U, P S 502-03 t. . Rev. O L,y,g; 3 p , g, ,y, g 9 ,, ;

Number and Revisiort The response to the referenced 'Recuest for Corrective Action

• is provided below for your evaluativi and verification. The response includes three parts in the following order: A. Cause of Condition; B. Action Taken to Resolve Problem; and C. Action Taken to Prevent Recurrence.

A. cal'SE OF CONDITION This condition was apparently caused by a more strict interpretation of the standard at the time the RCA was generated than was used during the preparation, review and approval process for the procedures. The amount of detail from the standard required to be reproduced in the procedure apparently has also undergone a similar interpretation change over this same time period, thus also contributing to the cause of this condition.

B. ACTION TAKEN TO RESOLVE PROBLEM The inspectors lacking documentation have acquired the additional infor:ation or have incorporated it into their resu=es. The revised resu=es will be added to their certification packages.

C. ACTION TAKEN TO PREVENT RECURRENCE QCP-ZZ-01001 Fev. 3 was issued on 3-6-85 with section 4.4.1 strengthened to better define the requirements 'of a certification package.

NOTE: Based upon additional reviews of various inspector training and certification docueentation by QC and OA, the action described in Part B will be taken for any additional inspectors falling into the sare categer: as those described in this RCA.

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1 February 22. 1925

Safety-Related SURVEILLANCE REPORT Surveillat.ce Peport No.

850209 Surveillance Dates: 02/07-15/85 No Response Required TO: P. T. Appleby Assistant Manager. Support Services TROM: C. S. Petzel. Quality Assurance k'. A. Ruhlman Quality Assurance Co:.s01 tant

]

SUBJECT:

Review of Certifications of UENO Quality Control i

Inspectors

PERSONNEL CONTACTED

(Listed on Attach:ent A) l J REFERENCES / CONTROLLING DOCUMENTSt (Listed on Attachment B) i RESULTS:

i j

Quality Assurance has reviewed the certificat;on documentation for '

i current UESO receipt, mechanical, electrical, and civil inspection I

personnel. This docu=entatien was compared to current UE program commitments; (i.e. controlling document numbers I, 2. and 3) for.

i 1 inspection, examination, and testing personnel. The specific commit ent is: "The cualification of UE QC personnel or contracted OC personnel performing work at the plant shall be in accordance with Regulatory l Guide 1.58 (ANSI N45.2.6-1978)." The exception UE has taken to this commitment is: "In instances where the education and expertence rete:-

i j

mendations of ANSI Na$.2.6-1978 are not met by QC personnel, UE will i

demonstrate, by docueented results of written examinations and evalua-tions of actual work proficiency, that these individuals possess compa- 1 rable or equivalent competence." The QC inspectors were interviewed to l determine if they could provide apy additional information to support 1

j their certifications. The results of this review and interviews are

! cabula:ed below:

RECEIVED i

FEB 2 5 !?i5 i

CALLAWAY E

,pg TECHNICAL SUPP0pd 7

,_.,__,._..._.-- m._.-.--.. _.___m . . . _ - . . . - . . . _ . . . _ _ . _ _ _ _. __ _ _ _ _ _

i 4

l ,

. Sury. Report No.: 850 09 4

• Page 2 of 7

, Ee:arns:  ;

1 Meets ANSI h45.2.6-1978 Meets CE's Exception See Note  ;

Education & Experience Listed l Requirements (At time to ANSI Na$.2.6-10'8 Belev of Certification) (At tiee of Cert.) ,

Name/ Certification 4

f l

R. A. Barnes YES 2

j Level 3 - Civil- 50 NO 2

l Level 2 - Electrical NO NO

! Level 2 - Mechanical NO NO r Level 3 - Receipt l i

} R. L. Bruneet No 50 .

j Lovel 2 - Mechanical  !

i 1 D. L. Heider YES ,

i e

Lovel 2 - Electrical '

t i E. L. Irvin YES Level 2 - Mechanical 1

i R.-L. Nave YES j tevel 3 - Mechanical '

I ,

2 i J. L. Pearson NO NO Level 2 - Electrical f l YES l j *ovel 2 - Mechanical YES 3

Level 2

• Receipt i t

i  !

2 i D. V. Peters NO NO 2

! Level 2 - Civil 50 NO l Level 2 - Electrical YES 2

Level 2 - Mechanical i 2 j V. P. Porte11 NO NO l

Level 3 - Civil No 50 2 7 Level 3 - Electrical YES Level 2 - Mechanical i T. W. Ridder YES I

Level 2 - Electrical  !

l J. M. Speek 1 YES I Level 3 - Electrical NO NO 1 Level 2 - Mechanical 2

R. D. Swank NO NO Level 2 - Electrical YES

Level 2 - Mechanical YES t

Level 3 - Receipt i  ;

i i I i

i i

Surv. Report No.: 550209 Page 3 cf 7 Recarks:

- Meets ANSI N45.2.6-197o Meets CE's Exception See Note Education & Experience Listed Require =ents (At time te ANSI Na5.2.6-1978 Below (At t e of Cert.)

of Certification)

Stee/Certificat:en D. S. Turley YES  !

NO Lovel 2 - Electrical 50 Lovel 2 - Mechanical NO  :

L. M. Zahara 50 Lovel 2 - Electrical YES .

Level 2 - Mechanical 50 NO Level 3 - Receipt N0!!S:

records and discussion with the individua;, CA helieves

1) Based upen insufficient the listed level / area coch natten; hewev-that the individual is certifiable at the certificat;en.

er, additional docueentation is needed to support 2)

Based up:n insuf ficient reccids and no additional detn11s believe that disc'.: sedisduring a the incividual discussion with the individual. QA does not certifiable at the listed level / area cembination.

insufficient RCA ?8502-035, Rev. O has been written to address 1. the RCA P5500-03., Rev.

reccids issue listed in the above table via Note the '.'E p r e g r a: requireeents O has been written to address the issue that been set. This :ssue is fer certification of QC inspectors have not;.

'.isted in the above table via Sote/ 2 4..;

In reading the cenclusions listed in the table. QAinn:tes that ANSI equivalent inspec-Ne!.2.6 uses the terminology "related experience tien, exa=ination, or testing activities" in defining education anddefined tnis term ex;erience for each inspection level. QC has not egy in any of their procedures; thus, there were no qualitative orpart or quantitative criteria to determine what past work experience can be " counted" when taking requirements have anbeenevaluation cat. Thisto determine if the ANSI N45.2.6-1978 lack of qualitative and quantitative acceptance criteria has been cc::ined with other prograematic inadequacies and addressed by RCA PE502-039. Rev. O.

following criteria

'"hile

. ccnducting this surveillance, QA utilized the if it in taking an evaluation of past work experienceinspection, to determine examination, constituted "related or testing activities." experience in equivalentThe bases for these criteria we as well as published guidance in this area in SNT-TC-IA (1975 and 1980) experience with current industry applications at other nuclear power plant sites.

L _

. -- .- -- .- . - - _ _ ~ ~ - - - - - - - - - . - - - . .

4 i

Surv. Raport No.: E!O:09 l Page 4 of 7 l 1'

d In order to be counted on a one-for-one basis, the person must have spent at least 25* of his time actually werking in the

' 11

discipline. This is based on SST-TC-1A's criteria.

i in the nuc* ear Navy

) For a mechanical certification, time spent ,

{ in ratings such as Machinist Mate. Engineman. Electrician's j Mate and similar ratings in other services was counted on a j one-for-one basis after the person completed basic training i

(and began actuai field work). Boilermakers, stea= fitters,

! shipfitters, pipetitters, and similar construction crafts were Electrician's Xates were l l also counted on a one-for-one basis. i i counted because replacement of bearings on motors is virtua11v i

! the same as replacement of bearings on pueps; torquing of  ;

i bolts on motor mounts is the same as torquing bolts en pumps  !

j ' or flanges; alignment of electrical equipment is the same as ali6nment of eechanical equipment. On the basis of similar l

logic, welding experience in the commercial industry was

]

J counted when a persen was involved in the " fit-up" aspects. l I

3) Tor an electrical certification, time spent in the nuclear l Navy as an Electrician's Mate, 1-C man, and similar ratings in l

J other services was counted an a one-for-one basis after the j

person completed basic trLinirs and began actual field work. t Construction electricians were also counted on a one-fer-one l basis. While Nuclear Power Schtoi does teach basic electri-cat, work as a Machinist Mate doss net involve work with I

l cables, terminatio ^s, controllers and other electrical activi- I ties. Therefore, no credit was given since 25 of Nuclear However, if a Power School is not devoted to electrical.

Machinist Mate qualified as Engineering Vatch Supervisor (EWS) l l

i or as an Auxiliary Electrician Aft (AEA), er as an Electric Plant Control Panel (EPCP) operator, or as a Shutdown j Electrical vacchstander (SEV) or similar posittens in other i services, then the basic electrical school as well as a I i

portion of his service time was counted 1. determining I experience.

'I. For a civil certification, none of the current QC inspectors j a) had any service time which was considered " equivalent."

i" However, time in the Marine construction battalions (C-5s) and ,

~

similar service rate which involved work in soil compaction, structural steel and concrete placement would have been '

counted on a one-for-one basis. Similarly, construction time  !

i spent in a civil test lab or a commercial-testing facility )

]

would be counted. Prir.arily, because of the broad spectrum of I

civil activities included in QCP-ZZ-07000, Rev. O, a person

! was evaluated with respect to a wide variety of civil tests.- l j A civil certification was the most difficult for a person to l receive a satisfactory evaluation upon during this surveil-  !

l lance without docueented work experience in civil testing activities since QCP-ZZ-07000 covers such a broad range of  ;

inspections. i

i l l 5

'. Surv. Report No.: 650209 Page 5 of 7 For a receipt certification, a wide variety of previous work 5) experience was accepted as equivalent en a one-for-one basis.

inspec-Unlike a Civil certification, the current UE receipt 3 and QCP-ZZ-0300c, Rev. ,

tion procedures. QCP-ZZ-03000, Rev. Since 2, define a very narrow range of skill requirements.

very few measurements are required during our receipt inspection, a UE Level 11 Receipt inspector would not require the same amount of specific work experience as a Level Il Receipt inspector working for DIC at Cal *away during cccstruc-tion. Therefore, virtually any previous experience that required an individual to locate acceptance criteria documents and then determine that an object cet the require:ents of those documents, was considered " equivalent."

f' No evidence was found where any of the current inspectors had been given a "docu=ented evaluation of actual work proficiency." This ccac!usion t was based upon a knowledge of the NRC's interpretation of that part of UE's exception to the education and experience requirements of AN51 N43.2.6-1978. During our (UE) meeting with the SRC representattve pr;or to their acceptance of our QA program (including Chapter 3A cf the SNt*PPS-C TSAR), this excepcion was interpreted to mean dccumentat;:n of actual work proficiency in the particular tests that a man would be certified to perform. That is, a civil inspecter would have te perfare a concrete slump test; an electrical inspector would have to observe a i I

cable pull and determine if cable stress criteria P.ad beenalignment to motor satisfied;and a

mechanical inspector would have to inspect a ;ut; a receipt inspector would deter =ine if acceptance criteria had been met; have to deter =ine what type of sampling require:ents These are, ofapply if a sa:pling course, only receipt inspection process is authorized.

examples; a wide range -- approximating all c! the !YPES of tests or inspections to be performed -- would have Bothtoacceptable be included andinunacceptable the actual docc:ented performance demonstration.

samples would have to be included to determine if an inspector c:uld dif f erentiate (i.e. , it would not be consicered adequate iffu'.1 an ef electri-cal inspector was taken into the field and shewn a cabinet acce; table ter=inations; he would have to be sncun a ter inal board with bcth acceptable and unacceptable terminations and be required to actual-ly identify which ones were which). t Because the program does not include these requirements nor any qualita-tive or quantitative criteria for conducting and docu=entinghas thisbeen activity which is required by the QA program, RCA P8302-039 written wh'ch includes this and other progratsatic deficiencies.

Curing review of the certifications of Non-NDE QC personnel QA has Two of the deficiencies have been identified some program deficiencies. The certification / qualification previously mentioned in this report. Rev. 2 and QCT-ZZ-01002, Rev. 2 is also i

pregram defined by QCP-Z:-01001 deficient in the following areast

1) The program does not provide for determination of the need for formal training programs either on a generic basis or on a case-by-case basis for qualif ying personnel who perform  ;

inspection, examination, and test activities. The program  !

l

. Surv. Repo7e No.: 650009 Page 6 of 7 does not specifically provide for OJT.

The determination of need for formal training is required by ANS! N-5.2.6-1978, Paragraph 2.1.2.

2) The program does not provide for deter:1ning the Thisir.it isiarequired l '

capability of a candidate for certification.

It also dces not prcvide by ANSI S45.2.6-1978. Paragraph 2.2.

for the documentation required by Reg. Guide 1.58. Rev. 1.

the =ininue Position C.10 for when an individual dces not cectN;5.2.6-1973.

education and experience requirements of ANS:

infor:ation is re-

3) The progra= does not state what minieu ANS!

quired to be on a letter of certificatten as requiree 5;.

545.2.6-1978. Paragraph 2.4

) The definitions cf "QC Level ;", "QC *. eve; !!", and "QC 1.ve; III" that appear in QCP-ZZ-01000, Rev. 2 de net agree with the levels of capability f or an individeal as stated in ANSI A;s

N45.2.6-1978 Paragraphs 3.2, 3.3, and 3.4 re spective ;:. .

this procedure, via the definitions of the levels cf inspec-tors, ieplies that an individual of a certain level shculd be able to perform a given capability (task) in the definition; a however, the procedure does not specifically require that person be capable of performing that capability. This is required by ANS1 545.2.6-1978, Paragraphr3.1.

RCA P8502-039 Rev. O has been issued to address the progra: de f ic ie n-cies listed above.

During interviews with the various QC inspectcrs, a cencern was raised with respect to dispcsitions cade to cable repairs.

As a result of this concern, the original scope ci this surveillatee was expanded to include a review of Nonconforming Material Reports (NMRs).

A review was cade of over 1300 NMRs in the QA vault and in the QC Depart ent files. The reviewer looked specifically fer cases where Based on this "prcble=s" documented dealt with cables or tereinations.

review, 26 cases of electrical device or wiring da age were found.

Several cases gi incorrect dispositions were found. This issue is en RCAPB502-0}(,F Rev. O. This portion of the surveillance was conducted by Mr. L. E. Petty, QA Consultant.

-fW.Stevi Petrel sMC '

/ k{A. kthl:an.~' / 2. As W.

QA Engineer QA Consultant g Y 3.!1'~

C S P :'.' AA: s a s See Page 7 for Distribution

Surv. Roport No.: 65C:09 Page 7 ef 7 Personnel Contacted During Survei*1ance Attach:e.cs: A) B) Refereness/ Controlling Documents DISTR:!sTION cc: A*!S050209 (As a CA Record)

A355850209 TR, QC (File)

5. E. Stiltenberger F. D. Field R. L. Powers

2. H. Zvanut

.,. V. Laux

., R. Veatch

.. C. Cearhart T. J. Forck V. R. Robinson (info)

C. S. Petzel V. A. Ruhlman T. L. Shaw J. E. Davis P. T. Appleby D. F. Schnell e

. . - --. _ --__=_. _-- . - . . . .

ATTACKMENT A Surv. Report so.: 0$0209 1

l PERSOSSEL CONTACT!D DURING SCEVE'LLANCE Services P. !. Appleby - Assistant Manager, Suppert R. A. Barnes - QC Inspector J. E. Davis - Superintendent. Ceep11ance D. L. Heicer - QC Inspector I

E. L. Irwin - QC Inspector j

5 S. 5. Land - QC Inspector f

R. W. Laughlin - QC Inspector '

,I R. L. Save - Assistant Superviser, OC J. *.. Pearson - QC Inspector I

t D. V. Peters - QC Inspecter i

V. P. Perte11 - Assistant Supervisor. QC f

I. L. Shaw - Supervisor. QC J. M. Speak - QC Inspector R. D. Swank - QC Inspector  ;

D. 5. Turley - QC Inspector L. M. Zahara - Assistant Supervisor, QC I

f I

1 i ,

- - - . ,- ,.,n ,- , - ,,--,,m-s . - , - - - - , . , - - - , - -,n-, , --v, --- - .- - - -, - -, . - - - ,,

ATTAC10'ENT B Sury. Roport No.: 850209 i

RETERENCES/ CONTROL'.:NC DOCLNENTS

!) 55tPP-C FSAR, Rev. 7. Appendix 3A, Coer.itzent to Regulatorv Guide 1.58

2) Regulatory Guide 1.58. Rev. 1 - September, ;960, Qualificati:n of Nuclear Pewer Plant inspecti:n. Exa=inatten, and Testing Personnel

.1) Standard ANSI N45.2.6-1978, Qualification ef Inspecti ..

Examination, and Testing Personnel for Nuclear P:wer ?. ants

4) OQAM, Rev. 7. Section 17.2.10 - Inspection

5) Quality Control Procedure. QCP-ZZ-01001. Rev. 2, certificatt:n of Quality Control Personnel r

6) Quality control Procedure. QCP-ZZ-01002. Rev. 2. Cualification I of Qualiev Control Personnel for Ne -NDE Inspection Activities

7) Technical Specification 6.5.2.9b

TYPICAL INSPECTION AREA Qt'ESTIONS FOR QC INSPECTORS (SR 850209)

During discussions with each inspector who was certified in a mechanical, electrical or civil area, certain questions were asked to attempt to ascertain the degree of familiarity of the inspector with certain " common" inspection or testing aspects in his discipline. The below listed questions are typical. Not every inspector was asked each question, and the answers from one question may have lead to a slight variation in asking other questions. These questions were not used as a

" negative" basis for any of the certificates in question, but were considered on a positive basis when deciding if additional documentation alone would provide a basis for certification.

Civil Describe how to perform a slump test. How do you perform cadwell tests for ultimate strength? For what and how do you test rebar? Describe a typical rebar/cadwell sampling plan. When qualifying a person fcr cadwelding, what are the important attributes (position)? Describe what you would consider important about aggregate. How do you perform a seive test and what do you look for? What is the significance of moisture on aggregate? How do you periarm a compr(ssions test on concrete? How do you obtain a concrete sample? How do you use a surface comparitor (for paint surfaces)? What do you look for in a

' finished surface? Describe how you would determine coating thickness.

How do temperatuse and humidity affect coatings? What is a " fish-eye" and a " holiday" when referring to coatings?

Electrical Describe what you look for in a termination? How can you (or can you) tell if the proper crimping tool was used if you weren't there! How can you (or can you) tell if a cable was overstressed during the pulling process? If you weren't there? How do you determine if minimum bend radius criteria have been met? Do you know any " rules of thumb" for making this determination? How many leads can be terminated under a single screw on a terminal board? Can you overstress a cable (single conductor) with orly a single man performing the pull? What are (are there any) requirements for the use of lubricants on a cable pull?

Mechanical Describe how you perform a cleanliness inspection. Describe the important " things to look for" on a blue check. Explain what point you would look for or what is critical when replacing a bearing. Scaled?

Sleeve? What do you Icok for when replacing "EQ" items? What is important when observing torquing? Vhat is critical in (how do you inspect) equipment alignment?

fj 'N or;p; - m ; u g f f Parch 25, 1985 Safety-Related SUFVEILLANCE REPORT Surveillance Report No: 850209A Surveillance Dates: 03/09-25, 1985 -

No Response Required TO: P. T. Appleby Assistant Manager, Support Se rvices l

PROM: T. V. Stotlar, Quality Assurance Engineer W. A. Puhlman, Quality Assurance Consultant

SUBJECT:

Peview of Additional Documentation and OC Action Relative to Certification of UENO Quality Control Inspectors OBJECTIVE: Review of Additional documentation relative to UENO Quality Control Inspectors' training and certifications and review ongoinc OC Department evaluations being conducted and documented as a result of Surveillance Report 8850209 PERSONNEL CONTACTED:

P. T. Appleby - Assistant Panager, Supoort Services '

J. E. Davis - Superintendent , Compliance -

T. L. Shaw - Supe rvi sor ,CC V. P. Porte11 - Assistant Supervisor, OC L. M. Zahara - Assistant Supervisor, OC L. D. Russell - Quality Control Inspector J. L. Pearson - Quality Control Inspector P. L. Bruneet - Quality Control Inspector PETERESCES/ CONTROLLING DOCUMENTS: (Listed on Attach =ent A)

RESULTS:

As a result of the OC group's corrective action taken to resolve RCA's P B 502-034, P8502-035, and P8502-039, additional information has been obtained for OA review. That additional information includes the following:

a) Trainine records

- b) Performance evaluations c) Pesults of evaluation of all OC inspectors employed by UENO under the operations OA progran (85 total inspectors) d) Pesults of the Work Authorizing document review for involvement of OC inspectors whose certifications are cuestionable (scheduled to be completed on 3/29/85).

Based on OA review of training records (items 8-11 on Attachment A), A_ of tht previously identified 7 inspectors _with questionable . certifications would This be

, certJ fiable if satisf actory_perf6r_mance- -

demonstrations were documented.

.c Survaillance Raport 850209A Page 2 of 5 D. In addition, determination is identified by Note ?.. 3 on Attachment Pearson, R. L. Brumeet and V. P. Porte11.

J.

interviews were conducted with Based on these interviews J. L. Pearson's Electrical Level II certification ,

could be supported when additional information is documented in theR. L Ce rtification file.

could be supported if a satisfactory performance demonstration is documented.

V. P. Portell's Civil Level III and Electrical Level III could be justified based on the use of " management pre rogatives" specified in ANSI V. P. N45.2.6-1978 Section 3.5. (See At tachment D and G f or further discussion).

Portell's Electrical Level II certification could be supported if a F.

In addition, A.

satisf actory performance demonstration is documented.

Barne's Civil Level III broad-based certification cannot be supportedThis because of .the limitation identified on his Civil Level D Note 2. 11 certification.

condition is identified on Attacheent perforrance evaluations were 0A also determined f rom a review of records that These evaluations were documented (pass /f ail) on all certificates pe rf o rme d. In three cases, the actual cuestions asked were approved docume nted.

by Mr. Schottel.Fowever, OA's review of the general nature of these cuestions, their lack of coverage of all areas and tasks, and with a knowledge of the NRC's interpretation when they accepted Union Electric's clarification in FSAP

1. 850209, Page 5 of 7. second paragraph f or Chapter 3A (See Surveillar.ce Report the a discussion of this meaning. ), leaLOA_ ttthe conglusion. that the in, tent tf UE's coer.itment to pe,rf ormance,,demonstrati_on_given does . not meetas modified by UE's clarification in P ANSI N45.2.6-1978

+

However,~thi~ additional documentation reviewed during this Surveillance does the indicate that OC management did perform activitiesthe Although which they felt ret clarification was in intent of Union Electric's commitments.

effect when Mr. Schottel conducted his performance demonstration evaluations, the NPC had not yet ret with Union Electric to clearly define their interpretation. Although the Superintendent, Compliance (to whoe the Supervisor, OC reports) was later an attendee at the in the OCceetines with the organization was NRC directly when the position was annunciated, no one i nvolve d. The failure _tojull L mplement,an i acceptable performance demonstration program may have resulted f rom the f ailure of OA and upper level managers to_ assure that OC canagement was aware of NRC's interpretation of Union Electric's clarification of ANSI N45.2.6-1978.

0A's detailed recommendations relative to the qualification / certification process which should be implemented have been delivered to UENO for inclusion in their review and assessment of the overall OC program. In addition 0A also recormends that OC suoervision monitor the actual inspections or tests cerformed b'y each newly certified inspector until they achieve a level of confidence in the individual's performance. This " monitoring" is in addition to the certification program items previously submitted, and is considered to be in excess of the minimum recuirements established by Union Electric's commi t ment s , but the monitoring represents what GA believes would be prudent

< management action.

F

t Surveillence Feport 250209A Page 3 of 5 Feview of Ongoing Evaluations Beine Conducted and Docueerited bv OC:

The first action taken as a result of the original Surveillance was on RCA the .

decertification P8502-035. OC manacement of all individuals identified as cuestionablehad All of this als initially identified as cuestionable by OA.

Civil inspector not that additional action is considered conservative based upon the f actone OC inspector (J. L.

documentation reviewed by OA has indicated thathis past experience and seven Pearson) could be recertified by documenting others (indicated by Note 3 on Attachment D) could be recertified based on corpletion of a performance denonstration.

OC managecent, as part of their investigation to records deternine the scope of the of all 85 OC personnel cuestionable certifications, also reviewed the who cay have perforred reviews or inspections under the operational CA program. They used acceptance criteria similar to that utilized by QA during As a result of that investigation, QC identified the initial surveillance. be (in Reference 13) 15 additional individuals whose cert'ifications right cuestionable.

Vhen the OC Department's review was conducted, thev looked at the files fer d

this increased scope accounts for the fact previously employed OC inspectors: Howeve r, they that they identified 15 additional cuestionable certifications.

also looked again at current eeployees and identified thef same inspectors The OC review did not previously identified by QA with one exception.

identify J. M. Sceeks' Level II Fechanical certification as cuestionable even though OA had listed it on RCA PE502-034 The OA review had identified that Mr. Speek's file only needed to include an expanded resume which could detail i

• the tasks which he had previously accomolished which were suitable for consideration as "eouivalent experience" in order to recove any cuestions This exeanded resure had been_

about his Mechanical level II certification. thus Fe was not identified as included in his file prior to the OC review, questionable nor were his certifications cuestionable at the tiee the OC review was ccepleted.

OC canarement's detailed actions, which include a review of activities perforced by any inspector whose certifications are cuestionable, isonriven thesein At tachre nt E. The Engineering /0A evaluation of the possible impact )

activities is ongoing. (It was begun on 03/12/85.) All actions cocoleted to i date as part of this Engirmering/0A evaluation have been conservative, and none has indicated any adverse impact on installed structures, systems or components.

As of March 25, 1985, approximately 95% of all work recuests had been reviewed; approximately 285 involvef inseeetors with enantion_akte Based on an Engineering /0A certifications rWththe activitv.

evaluation of the actual activity conducted, none of the 265 identified to date had any adverse impact on installed hardware.

0A originally identified nine OC inspectors with cuestionable certifications. of the OC When combined with the 15 additional inspectors' identified as part to be review, this yielded a group of 24 inspectors whose work activities However, were OA considered J.

reviewed by OC as described in Attachments E and F.f orth in the following l D. Schottel toInbeaddition, certifiableQA for did the not reasons list setH. L. Holean as an ir.spector with paragraph.

ouestionable certification since he was never certified by Union Electric.

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.' Surveillance Report 850209A I

Page 4 of 5  ;

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4 that he ray have j Mr. Holman was listed as questionable by OC based on the factMr. Holman's nace l I conducted some reviews even though he was never certified. Al t houg h ,

1s part of the document search documented in Attachments E and F.  ;

J. M. Speek and D. S. Turley were identified as having questionable l

certifications in surveillance report 850209, they have been elleinated as needing further evaluation based on additional inf ormation incorporated into their certification file. Eliminating these two individuals yields the list of 20 inspectors considered by OA to be of questionable certification as listed on Attachment D.

'4 i the fact that be QA's evaluation of Mr. Schottel takes into account: his coroleted the Electrical training course and all electrical examinations: his CA l B.S. in Metallurgical Engineering and his M.S. in Nuclear Engineerine:

i l experience at other Nuclear Power Plants; and his cumulative 32 :onths of OA/0C experience. We note that the Standard would recuire only six months And, of l related experience for a Level 11 certification with a B.S. degree.

while the Standard recuires five years of related experience for a B.F. decree in order to be a Level III, CA f eels that some part of his Master's degree comican ng 4

be counted as part of this five years with the remainder of the credit f rom his 32 months of actual equivalent experience in th( nuclear industry.

In addition, Mr. Shottel's certification was given because no Level III existed at the time of certification. This utilization of management the prerogative , and consideration of other f actors adeouately support

' certification and complies with ANSI N45.2.6-1978, Sec tion 3.5.

CONCLL'SICN:

i Eased on the review conducted by OC as surveilled by OA during this Surveillance, and based on the conservative interpretations relative to all OC education / experience / training which have been applied, we conclude that inspectors with cuestionable certifications have been identified as listed on =

Attacheent D. We also feel that OC management's approrch to the l

I identification of the insoections and reviews performed by personnel with questionable certifications has likewise been thorough and conservative to I date. And, whEn coupled with the Enginee ring /0A evaluation which is being conducted, we believe that possible adverse ef fects on installed hardware will i be identified if any exist. t 4,

As mentioned on RCA P8502-035, Rev. O, CA will consider downgrading the l identified inadecuacies to a Level 2 if there has been no significant ad ve rse impact on installed equipment. We do not anticipate that it will be possible 1

j to make this determination (of possible impact) until the Engineering /0A j

evaluations have been completed and any reinspections, if needed, have been

! conducted and reviewed. .

Now that the full extent of quer,tionable certifications has been identified l the issue can be placed in proper perspective. Attachment B provides the results of the OC department's evaluation of cuestionable certifications of inspectors who were not identified $f the previous surveillance, including disposition of certain cuestionable tertifications. This evaluation j

identified (a) 11 certifications /3 inspectors in which no tasks were performed

, - - , - - , - , ,. , , , - -.,,..-r -,.-my,.---e ,,.,,,-,..,,w-.-,,y,w-.,m,,y,,,-,-c,._,mem..,,,,,.,,-.v,wwmy,,y.-,,m.~.,,-,,,y.m.m.o.,,----

Surveillance Report 850209A Page 5 of 5 which reautred certification, therefore no f urther evaluation was necessary in this area, (b) 9 certifications /8 inspectors in which additional 17 certiinffications/10 ormation could be added to the file to support certification, (c) inspectors whose previous certification, training, experience,Attachsen education,  ;

performance cannot be's'upported in the broad base category. ~

lists 75 inspectors with 207 certifications that' comply vith UENO prorr;4 Attachment D lists 20 inspectors with 29 certifications s?

i c ommi tmen t s. 'v These inspectors along with J. M. Speek and D .

'm:

remain cuestionable. 4 pnk i ce r' are being identified as stated earlier for further evaluation. ug p p;*

inspectors with 247 certifications have been evaluated, 207 ce 4 : se p ti e is meet UENO program concitments and 22 inspectors with 29 (11.7*

remain cuestionable.

Based on personal interviews with current employees and based on the review of work activities completed to date, there have been no cases where ary inspectors performed inspections in areas where they were not qualified and capable of performing adeouate inspections.

' 3-$fo-6 [ ,

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W. A.~Ruhlman T. V. Stotlar Quality Assurance Consultant Ouality Assurance Engineer WAR /IVS/ldj gg DISTFIBUTION:

AD5S850209A ( As a OA Record)

AD5S850209A OC (File)

F. D. Field

. R. L. Powers J. C. Gearha rt J. V. Laux J. R. Veatch F. J. Forck W. H. Zvanut W. R . Robinson (info)

S. E. Miltenberger C. S. Petzel ,

L. E. Petty T. L. Shaw J. E. Davis Y

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• ATTACKMENT A to Surv. Report No.: 650209A Page 1 of 1 J

REFERENCES / CONTROLLING DOCUMENTS 1)

SS1*PPS-C FSAR, Rev. 7. Appendix 3A, Commitment to Regtlatcry Guide 1.58

2) Regulatory Guide 1.58. Rev. 1 - September, 1980, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel Examina-

3) Standard ANSI N45.2.6-1978, Qualification of Inspectien.

tion, and Testing Personnel for Nuclear Power Plants

4) OQAM, Rev. 7, Section 17.2.10 - Inspection 2, Certification of

5) Quality Control Procedure QCP-ZZ-01001, Rev.

Cuality Control Personnel

., Qualification of Quality Control Procedure. QCP-ZZ-01002, Rev.

6)

Quality Control Personnel for Non-NDE Inspection Activities

7) Technical Specification 6.5.2.9b

8) Mechanical QC Inspector Training Program Course Description f

9) Electrical QC Inspector Training Prograc Course Description l

10) Training Progra= Attendance Records, Electrical and Mechanical QC Inspectors

11) Exa=ination Answer Keys, Electrical and Mechanical QC Inspector Exa=inations

12) Els.ctrical and Mechanical QC Inspectors' Grsded Exa:inations i

13) Memo, L. D. Russell and V. P. Portell to J. E. Davis, dated 03/09/85 i

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M ATTACWINT B to Surv. Report No.: 850209A Page 1 of 5 EVALUATION OF QUESTIONABLE CERTIFICATIONS Previous l

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Certification / Acceptable Areas Experience Previous U.E.

l Certification of Certification Na=e Other than UE VT-2 II (a) See Note 1.

(Batey, R. J.) Doc. Tech. I VT-3 II (a)

VT-4 II [ Limited to Doc. Revies] (a)

Civil II (c) Civil II Battle, W. D. Civil II - Cencrete i

- Concrete - Complete (includes

- Soils Orypack)

- Coatings Civil II (Limited) i

- Drypack - Scils

- Lead Aiiditor - Coatings

- Surface Mounted Plates & Expan-141on Anchors ,

Receipt II-(b) Reference Letter of Brewer, N. L. Doc. Tech II Justification for

- Complete Receipt II Certi-

. ficatton - See Note 7.

t Mechanical II (c) Mechanical II Brevn, L. D. Mechanical II - Instrucentation

- Instru entation - Complete

. Welding II

- Cczplete Electrical II .

Raceway VT-3 II (a) See Note 3.

Mechanical II Erevn. J. K. VT-4 II (a) VT-2 II

- Instru=entatio'n

- Hydro f' Receipt II

- Cocplete i.

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ATTACHMENT B to  ;

Surv. Report No.: 650209A  !

Page 2 of 5 Previous Certification / Acceptable Areas ,

Experience Previous U.E.

Certification of Certification Na=e Other than CE VT-3 II (b) VT-2 II Gaines, T. E. Mechanical II Reference Letter of

- Hydro VT-4 II (b)

Justification for VT-3 6 '. Level II Certification -

See Note 6.

Mechanical II (c) Mechanical II Herring, P. L. Mechanical II - Hydro

- Hydro - Co=plete

- Hangers

- Hangers VT-1 II (b) Reference Letter of Non-Q (Trainee III) Justification for

- Limited to valve insp. VT-1, Level II Certification - See Note 6.

e See Note ..

Doc. Tech. II Receipt II (a)

(Lawson, M. L.) - Complete Mechanical II (c) Mechanical II

.~.echner, S. J. Mechanical II - Instrumentation

- Instrumentation - Co:plete Pipe

- Pipe Electrical II

- Complete Mechanical II (c) Mechanical II McFarland, R. A. Mechanical II - Pipe

- Pipe - Complete

- Hangers

- Hangers Welding II

- Complete Welding II VT-2, Level II (b) Reference Letter of Morgan, J. Justification for

- Structural VT-2 Level II Certification -

See Note 6.

=,

., A!!ACRMENT B to Surv. Report No.: 850209A Page 3 of 5 Previous Certification / Acceptable Areas Experience Previous U.E.

Certification of Certification Name Other than UE Civil II (c) Civil II Orf, D. L. Civil II - Concrete

- Concrete - Complete

- Blockwalls

- Blockwalls - Fire Rated Doors

- Fire Rated Doors

- Subcontractor surveillance Civil II (c) Civil II Pasley, J. M. Civil II - Soils

- Soils - Complete

- Coatings

- Coatings

- Subcontractor Civil III (a)

- Complete See Note 2.

surveillance Mechanical II (c) Mechanical II Pruitte, V. R. Mechanical II - Instru:entation

- Instrucentation - Complete

, - Pipe

- Pipe Welding II

- Complete NDE II

- PT Mechanical II (c) Mechanical II Scheperle, G. P. Mechanical II - Pipe

- Pipe - Complete

- Equip =ent

- Equipment Civil II (a) Civil II (Thomas, D. R.) Civil II

- Pre-Pour

- Pre-Pour - Complete

- Cadwelding

- Cadwelding

- Soils

- - So ils - Structural

- Structural See Note 5.

Wudtke, C. A. Mechanical II 'VT-1 II (a) VT-2 II

- Hydro VT-3 II (a) See Note.5.

VT-4 II (a)

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ATTACKMENT B to Surv . Report No.: 850209A Page 4 of 5 Previous Certification / Acceptable Areas Experience Previous U.E.

• Certification of Certification Name Other than UE Civil II (c) Civil II Barnes, R. A. See RCA P8502-035 (Limited)

- Complete Civil III (c)

- Co=plete Electrical II (c) t^

- Complete Mechanical II (c) 4

- Complete VT-1 II (c)

VT-2 II (c)

VT-3 II (c)

VT-4 II (c)

J r

Mechanical II (b) See Note 6.

Speek, J. M.

Mechanical II (b) See Note 6.

Turley, D. S.

Start-up Engineer None Nene issued. ,

(Holman, H. L.) '

Draftsman l

Electrical *I (b) See Note 6.

Pearson, J. L. See RCA P8502-035 t - Complete t

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Receipt III (b) See Note 6.

Zahara, L. H.

Based upon discussions with the individual's QC Supervisor, the following inf ormation applies. Letters or other documentation has or vill be placed on file to substantiate or reiterate the information in these notes.

NOTE 1 - Individual did not perfore any duties requiring Level II certification.

NOTE 2 - Individual did not perform any duties requiring Level III certification.

NOTE 3 - Individual did not perform any VT-3 and VT-4 inspections, i NOTE 4 - Individual did not perform any receipt Level 11 inspections.

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ATTACKMEST B to Surv. Report No.: 850209A i Page 5 of 5

)

NOTE 5 - Individual was assigned only VT-2 inspection work.

l NOTE 6 - Additional information was supplied to substantiate ~

certification at the indicated area / level. This information was documented and added to file.

k Additional Annotations:

(a) Denotes a questionable certification; however, no task requiring certification was performed in this area.

No further evaluation is necessary for this certification.

7 (b) Additional information was supplied to the certification file prior to this Surveillance Report. This certification C.

meets UENO program co=mitments and is included on Attach =ent (c) These broad based certifications are questionable; however, the docu=entation supports limited certification. These j

certifications require further evaluation and are included i

on Attachment D.

i (d) Inspectors do not appear on Attachment C or D.

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ATTACHMEMI C to Surv. Report No.: 350209A Page 1 of 5 CERTIFICATIONS THAT COMPLY WITH UENO PROGRAM COMMITMENTS ,

NAME U.E. CERTIFIED

5. J. Adams Electrical. Level II Mechanical, Level II T. L. Antweiler T. H. Ar: strong Mechanical, Level II R. A. Barnes Receipt, Level II & III J. H. Baxter Electrical. Level 11 M. J. Belcher Receipt, Level II VT-1, 2, 3, 4, Level II D. Bettenhausen Mechanical, Level II & III S. L. Bode Receipt, Level II VT-1, 2, 3, 4 Level II VT-2, 3, 4, Level II P. A. Bohnert (Li=ited to Doc. Reviev]

VT-2, Level 11 G. E. Erandov Mechanical, Level II R. H. Erock=eier Receipt, Level II Mechanical, Level II B. G. Brocan Welding, Level II VT-2, Level 11 J. K. Brown NDE 11. MT-PT, Level II R. L. Bru==et VT-1, 2, 3, 4, Level II Receipt, Level II N. L. Brewer T. J. Buersceyer Electrical. Level II Mechanical, Level II P. J. Cody Receipt, Level II Welding, Level II Mechanical, Level II E. J. Crawford

ATTACRMENT C to Surv. Report No.: 850209A Page 2 of 5 NAME .U.E. CERTIFIED Electrical, Level 11 J. S. Diluvio

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Mechanical. Level II Welding, Level II NDE - PT, Level 11 NDE - MT, Level II VT-1, 2, 3, & 4. Leve! II VT-1, Level II M. E. Dubeau VT-2, Level II VT-3, Level II VT-4, level II NDE - MT, PT, Level II

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B. J. Dudley VT-2, 3, 4, Level II

[ Limited to Doc. Reviewi R. L. Dudley Receipt. Level II Electrical, Level II J. L. Edmondson e VT-2, 3, 4 Level II K. S. Edwards

[ Limited to Doc. Review}

NDE - MT, PT, Level II S. E. Febles VT-2, 3, 4 Level II Welding, level II T. E. Gaines Receipt, Level II VT-2,' Level II l

J. G. Carrigan VT-1, 3, 4 Level II 1

' J. N. Guynn Receipt, Level II R. Hagar Electrical Level II Receipt, Level II G. W. Hamilton Mechanical, Level II VT-I, 2, 3, 4 Level III 1' Electrical, Level II B. W. Haugen D. L. Heider Electrical Level II S. M. Henage. VT-2, 3, 4 Level 11

[ Limited to Doc. Review]

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! P. L. Herring VT-2, 3, 4 Level II i

L..P. Hume Electrical. Level II Welding, Level II i

ATTAC:OtEET C to Surv. Roport Wo.: 850209A Page 3 of 5

.i NAME U.E. CERTIFIED E. L. Irwin Mechanical. Level II '

VT-1, 2, 3, 4. Level II Welding, Level II ,

VT-2, Level II S. W. Jesse Electrical, Level II i

A. J. Kemple Welding, Level 11 S. N. Land NDE - MT, PT, Level II R. W. Laughlin NDE - MT, PT, Level II VT-1, 2, 3, & 4 Level II 2

Welding, Level II C. P. Laurie Receipt, Level II S. J. Lechner Welding, Level 11 1

Mechanical, Level II M. J. Major Electrical, level II T. L. Matheny VT-1, 2, 3, 4 Level II H. T. Moon

[ Limited to Doc. Review]

1 Electrical, Level 11 D. L. Moore Civil, Level II D. E. Moreland Morgan VT-2,~ Level II l J.

Mechanical, Level.II & III R. L. Nave VT-1, 2. 3, & 4,' Level II Electrical, Level II & III D. W. Neterer Mechanical, Level II >

NDE -.PT, Level II Receipt, Level II VT-2, Level II D. R. Oelrichs Mechanical, Level II i

VT-2, 3, 4, Level II P. S. Olsen i

J. L. Pearson Mechanical. Level II f Receipt, Level II l VT-1, 2, 3, 4 Level II I Mechanical, Level II D. W. Peters .VT-1, 2.'3, 4, level II I

Welding, Level II

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ATTACHMENT C to Surv. Rsport No.: 850209A Page 4 of 5 NAME U.E. CERTIFIED R. L. Pflueger Receipt, Level II ,

Mechanical, Level 11 V. P. Porte11 NDE, PT, Level II VT-1, 2, 3, 4. Level Il

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K. R. Richey Electrical. Level II Electrical, Level II T. W. Ridder VT-3 & 4, Level II K. M. Robson i

Mechanical, Level III i J. D. Schottel Receipt, level III

VT-1, 2, 3, & 4, Level III J Velding, Level III l Electrical, Level III Receipt, Level II D. L. Smith d

VT-1, 3, %. Level II l J. A. Smith Electrical, Level II, I E. P. Smola Electrical, Level II & III J. M. Speek Mechanical, Level II VT-1, 2, 3, & 4, Level II T. W. Stites Electrical. Level 11 Mechanical,. Level II R. D. Swank Receipt, Level I!

Welding, level 11 VT-1, 2, 3, 4, Level II l Electrical, Level II D. S. Turley Mechanical, Level II VT-1, 2, 3, & 4. Level II Electrical, Level II J. A. Ullman J. W. Vandelicht Electrical Level II Electrical, level II W. R. Vandeloecht Electrical, Level II G. G. Weinzettle T. C. Weisenberger VT-2, Level II i

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ATTACRMEST C to Surv. Report No.: 850209A Page 5 of 5 NAME U.E. CERTIFIED VT-2, Level II F. A. Wadake ,

B. D. Yockey Mechanical, Level II Mechanical, Level II L. H. Zahara NDE, PT-MT-VT, Level III VT-1, 2, 3. 4 Level III Welding, Level III Receipt. Level III S

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ATTACHMENT D to

,I Surv. Report No.: 850209A Page 1 of 2 COMPOSITE LIST OF ALL QC INSPECTORS WITH REMAINING QUESTIO

^

BASED ON A QA SURVEILLANCE AND QA'S EVALUATION OT QC'S REVIEW -

NO~ES QUESTIONABLE ARE,*./ LEVEL QC INSPECTOR'S NA'1E 2

R. A. Barnes Civil. Level-III 3 Electrical, tevel II i Mechanical, Level II 3 VT-1, 2, 3, 4. Level II 3

R. L. Brum=et Mechanical. Level II J. L. Pearsen Electrical. Level II 4' i

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Civil, Level II D. W. Peters Electrical, level 11 3 l I.

a V. P. Portell Civil Level III 5

Electrical, Level III 3

l Electrical, Level II e

3 R. D. Swank Electrical Level II L. M. Zahara Electrical Level II 3 l

i 2 Civil, Level II i

W.D. Battle i 2 L. D. Brovn Mechanical Level II 2

j P..L. Herring Mechanical Level II l

2 Mechanical, Level II l S.'J. Lechner

. Mechanical, Level II 2 l R. A. McFarland i

2,6 Civil, Level III D. L.-Orf s 2 J. M. Pasle;.

Civil, Level II 4

5 Mechanical, Level II 2 V. R. Pruitte Mechanical, Level II 2 i G. P. Scheperle 1

4 i Electrical, Level II

.D. L. Bettenhausen l 4 Electrical, Level II S. L.. Bode l 4 Electrical, Level II R. H. Brockreier l 4 Electrical, Level II C. V. Hamilton

, t

.._ _ . . . . . . . ~ . . .._ -._. _ _ _ _ - _ _ _.- __.__..m . . _ . . _ . _ _ _ . _ . .____ .

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ATTACEMENT D to Surv. Report No.: 850209A l Page 2 of 2 i

j

, NOTES:

Based upon the lack of records and the lack of additional inforcation obtaine,d during the personal interviews, QA does not believe(See that the individual is l 1)

RCA P8502-035. Rev. 0.)

l certifiable at the listed area / level combination.

I 2)

Eased on limited certification by the previous employer, this individual's A CE certifi-experience will not support the broad-category UE certification.

cation in the areas certified by the previous employer or where UESO program has l

' been followed would be acceptable.

3) Based on training records and course outlines reviewed as well as the individu-al's docu=ented education and experience, the inspector would be certifiable at the indicated area / level ce=bination if a satisf actory perfor=ance demonstratien were docu=ented.

However, since he is no lenger f 4) This inspector is the same as Note 3 above.

j employed as a QC inspector, completion of a satisfactory performance de=enstra-tion 13 not considered appropriate.

5) Although this inspector's education and experience do not meet the literal i

require:ents of ANSI N45.2.6-1978 for certification as a Level III, he could be certified by UENO management based on the use of " manage =ent prerogatives" as i

- set forth in Section 3.5 of the Standard.

Additional details are contained in .

the Surveillance Report under the Discussion heading.

j part of

6) At the time that QA conducted this Surveillance, this inspector was not i the UENO QC organization. However, prior to issuing this Surveillance Report, CEQA was made aware of potential plans to rehire this inspector and certify hic in the areas where he was previously certified under the DIC program. QA concurred that such certification would be acceptable, l

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ATTACRMENT E to l Surv. Report No.: 350209A Page 1 of 3 t

QC FOLLOW-UP ACTION.TO SURVEILLANCE REPORT #650209 i

1. 850209, the QC To resolve the concerns of the Surveillance Report Department has initiated the following action:

A. A review of documentation to determine which additional QC i personnel have questionable certifications that will require review of the work performed. This included a review of computer listing of personnel and a review of the QA record l files for all QC certifications issued by UENO. UEQC j

Supervisors have reviewed the list of questionable the 85 QC j certificates thus generated and have concurred that personnel identified, as a result of the review, represents ,

l the total QC inspector population under the Operations QA j

Program. This task was completed on 03/09/85.

4 i

B. Utilizing the list generated in A above, the QC Department ,

j performed an evaluation / comparison of certifications, '

education, and experience received outside of UENO anc the l UENO QC certifications received. The QC Department utilized 1

j criteria similar to that established in Surveillance Reperc

1. 850209 for performance of this review. 'An attempt was made

{

' to categorize subdisciplines in which an Inspector was

' certifiable. Attachment B is a su= ary of the results.

Quality Assurance's review of the QC Department's evaluation

[

l perforced in A & B above consisted of a review of '

l certification, education, training and experience for the l following per.sennel:

1) ' a' . D. Battle I i

2) L. D. Brown

3) S. L. Bode l' 4) R. H. Brockmeier

5) J. D. Schottel

6) D. W. Neterer

• 7) P. L. Herring This review verified that the evaluation performed by the QC

. Department was adequate and conservative. The evaluation has l

identified additional UENO QC personnel whose certification is questionable based on the criteria specified in Surveillance l

Report #850209. . Attachment D identifies those individuals vhose certification remains questionable.

C. Review of Startup Maintenance Authorizations (SMA), Work Requests (WR),'and Repeating Work Requests (RWR) is being

' conducted as follows:

I l

ATTACEMENT E to Surv. Report No.: 850209A Page 2 of 3 1

4  !) Work authorizing documents are currently being reviewed to identify work that involved individuals whose ,

certification is questionable. These individuals are i identified as a result of B above. Currently, researchof UENO is being conducted to determine the involvement QC during the startup phase. The results of this research will determine whether Startup Maintenance Authorizations (SMAs) require evaluation. At the time of initiation of the Startup Work Request (SWR) Pregram by the Startup organi:ation, operations was utilizing a Vork Request Program. To administrative 1y allow CENO maintenance and therefore UENO QC involvenent, CENO vrote a Work Request per operations program cec =iteents using the SWR as justification. Therefore Startup Work Requests will not contain evidence of UENO Quality Control involvement. The QC involvement with SWRs activities will be documented on Work Requests.

2) The work authorizing documents identified in C1 abcVe are being reviewed by QC to determine if the scope of work j

performed by the QC inspector was within an area in which j

he/she was not certifiable. These areas include 1

preparing the Hold / Witness / Monitor points, preparing and approving Maintenance Inspection Checklists, and Field l

j Inspections. Attachment F outlines the criteria utilized

)

for determining the need for Engineering /QA reviewers evaluation.

D. The QA/ Engineering reviewers evaluate the work documents, identified in C2 abcve, for actual work performed and task 4

performed by the QC inspecters with questionable i certification. The evaluation incluces:

1) Acceptability of Hold / Witness / Monitoring points, based on agreement of the reviewers that the appropriate inspec-tion attributes were identified.

' 2) Acceptability of the maintenance inspection checklist, based on agreement of the reviewers that the checklist 4

contains appropriate inspection attributes and acceptance criteria to perform the task.

3) Acceptability of inspection, based on agreement of the reviewers that the inspection was a) within the skills of the QC inspector (like kind replacement, routine activi-ties performed by skilled craft; e.g., turn-of-the-nut torquing, routine terminations, etc.), b) conducted with adequate inspection instructions, or c) there was no impact on equi; ment.

?

. . . ... _....._... _ . . - . . _ . _ - . . . _ _ _ - . . . . . . _ . _ ~ . _ . . . _ --_ . _ - _ _ . - - - . . . . _ _ _ . _ . . - - . . . . . . -

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ATTACHMENT E to Surv. Report No.: 850209A Page 3 of 3

+

9

?

verification, Based on the above criteria, equipment history, and retest ,

the task force determines the need for reinspection. .

i Based on QA's reviews and involvement and the corrective action to date

by the.QC Department, the actions being taken to resolve the concerns identified in Surveillance Report #850209 are currently acceptable.

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' **TACRtENT T to

. .rv. Report No.: 850209A Page 1 of 1 HOLD / WITNESS / MONITOR (H/W/M) - 50 INSPECTION SPECIFIED Check H/W/M - Prepared By 1 i L

snot Certifiable C;C) i Certifiedm' r-

\/

4 s/ Engineering /0A OK 4

1 HOLD / WITNESS / MONITOR (H/W/M) - INSPECTION SPECIFIED I 1

) I i

Check H/W/M - Consent to Proceed Certified 7 ) Not Certifiable (NC) e i

Cheer.MIC*(

Insp. Perfereedh Waivid Inspection or Not Signed t

j V NC Engineerine/QA

. Approvef. By '

Prepared Ev - NC ( . ) Certifiable 4

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Check Field Inspector t

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• Maintenance Inspection Checklist

- . _ . _ , _ . . , _ . , , ,. ., . , . _ , . . , . , . , . _ . . _ _ . . . - - , , . . _ _ . _ . , _ _ . _ . _ _ , . _ . _ ,,___.-,,..-...,-,.,,____.m... _ _ _ _ .

. . - _ -. ._ _ _ __ . _ _ _ . _ _ _ ~ ___ __ . _ _ _ _ _ . __

Attachment G to 4

Surveillance Report 850209A Page 1 of 2 ,

i  !

' DISCUSSION To preclude any misinterpretation of this Surveillance, a Discussion Section is being added to provide details which would not normally be included. If l .

additional clarification of any of the issues covered in this Surveillance is desired by the recipients, they should contact the authors or the authors' management.

Note 5 on Attachment D indicates that UENO management could recertify Mr. V.

P. Portell based on canagement prerogatives allowable under and described in ANSI S45.2.6-1978. In order to do so, UE0A believes that management should establish that extenuating circumstances exist. Manageme nt would also need to

! define, as part of that recertification process, the pertinent factors that they considered when concluding that they had reasonable assurance that Mr.

Porte11 can competently perform as a Level III. Section 3.5 of ANSI S45.2.6-1915 lists two other factors -- demonstrated capability in a given tob based on previous performance or satisf actory comolecion of capability testing

-- which eay be used. Of course, other factors might also be relevant.

b*hile OA does not recommend nor rule out the action to recertify Mr. Fortell i

under the provisions of management prerogative. 0A also believes that such a certificatien would not be opposed to safety or cuality considerations nor would it be contrary to the 00AP. As UENO management is aware, the OA I interpretation -- one independent of cost and schedule an'd other similar canagement considerations -- is only required to be implemented (by 10CFR50, Appendix B) when the proposed action is opposed to safety or quality consideratiens or when it would not implement the OQAP. (

References:

10CFR50, Arrendix B, Criterion I, 7th sentence; 00AP (FSAR Chapter 17.2),

l Section 17.0.1, 5th paragraph, 2nd sentence; ANSI N18.7-1976 Section 3.2, 3rd paragraph, 1st sentence.1 1

Throughout this and the . original Surveillance. 0A used the terminology "not ce rtifiable** or " questionable certification." These teres do not reflect in l any way or. the capability of the person relative to ability to actually l

perform OC inspections. UE's commitments, as outlined in the OA program, are designed t: provide management (the NRC and the public) with a description of ,

l "all those planned and systematic actions necessary to provide adeouate l j  ;

{

confidence : hat a structure, system or component will perf orm satisf actorily 4

in service."* This is accomplished by including in those commitments "the l - canagerial and adminstrative controls to be used to assure safe operation."*

' It is therefore possible to establish controls which are written in such a way that. a person who is highly capable is not certifiable. The obverse is also t ru e , bu t .ess likely: A person who is not cap 3ble could be certifiable. The i Standard (and UE's commitment thereto) is designed to deal with the " normal or ave rare" case. For those cases, the' established controls provide adeouate 2 confidence that acceptable action will occur.

i Pecognizit the above potentials, OA normally takes the more conservative i approach. Fowever, the more conservative approach may not be economical or efficient and it is therefore acceptable to implement a less conservative approach as long as such action is not opposed to safety considerations and it implements the 00AP.

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At tac hme nt G to Surveillance Report 850:09A Page 2 of 2 ,

However, to remove all uncertainty relative to performance, QA has and continues to recommend actual performance demonstrations be oe formed prior to certification of inspectors.

Such a course is the only way in which it can be -

" proved" that a given inspector is capable or qualified to perform an inspection. Therefore, since QA only reviewed the exoerience/ training / education of the inspectors, the only determinationA which t they could (or did) make was that a person is or is not certifiable.

paperwork review does not allow a determination that a person is or is not cualified.

QA also does not see any attempt on the part of QC management to circunvent the established oualification program nor any intentional violations of procedures. A discussion of the possible reasons for the dif ference in interpretation is given in the Surveillance on page 2.

• Ouoted from 10CFR50, Appendix B. Introduction.

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4-Safety-Related April 23, 1985 S1'RVE1 LLANCE REPORT Surveillance Report No. : 850209B

• Surveillance Dates: 3/12/65 - 4/18/85 i No Response Required To: S. E. Miltenberge r From: T. V. Scotlar/S. M. Pohl Ti tle : Quality Assurance and Engineering Evaluation of OC Inspections Obj ec tive : Detereine the impact on plant hardware due to inspection activities by Quality Control personnel with cuestionable certifications. I' I

Quality Assurance / Engineering Evaluation Tene

Participants:

, 1) T. W. Stotlar - OA Engineer '

2) L. E. Petty - OA Consultant

3) T. M. DeVincentis - Assistant Engineer

4) S. M. Pohl - Engineer

5) S. M. Bond - Assistant Engineer

6) C. W. Polowy - Engineer

7) J. P. Lueckenhof f - Engineer

8) W. A. Witt - Assistant Engineer I

9)- M. D. Haag - Engineer

10) J. R. Meehan - Engineer Personnel Contacted:

P.' D. Swank E. Li t t le R. Goldscheidt L. D. Russell J. M. Speek P. Johnson  ?

J. E. Davis V. Beche rle J. E. McLaughlin D. Kaf tor Feferences/ Controlling Documents:

1) 00AM Section 17.2.10, Rev. 7

2) OCP-ZZ-04001, Fev. 3 ,

3) - OCP-ZZ-04002, Rev. 2

4) OCP-ZZ-04003, Rev. 0

5) Maintenance Procedures

6) M-02 P61D Dravings

7) E07000

8) APA-ZZ-00125, Re v. 1

9) APA-ZZ-00126, Fev. 0 9

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Surveillance Report No.: 8502005 Page 2 of 6 Summary To Management As documented in Surveillance Reports 850209 and E50209A, OA and OC identified 22 Quality Control inspectors who were certified in areas for which their experience and on-the-job training did not support certification. The Ouality Control group conducted a review of all work authorizing documents since the OC identified the work activities which start of the Operations OA program.

inve.ved UENO OC inspectors with questionable certifications. A primary portion of the corrective action program undertaken by UENO managerent, documented in Request for Corrective Actions PE502-034, PE502-035, and P8502-039, was to evaluate the impact on plant hardware due to activities ,

performed by OC inspectors with questionable certifications.

i i

Therefore, a Quality Assurance / Engineering Evaluation Tean was established to provide an independent review of work documents which involved activities I performed by OC inspectors with qu'estionable certifications. The team was utilized to deteredne if any adverse impact on plant hardware exists due to j this condition. In addition, to provide an additional confidence in the

> evaluation team's conclusions, 6 work recuests were chosen and the work performed was field verified.

' The four member evaluation team reviewed 681 Work Requests, 53 Preventive Maintenance Task Sheets, and 165 Start-up Maintenance Authorizations. The team concluded that there was no adverse impact on plant hardware function or l

cuality. Management recommendations and further details of the results of the i

evaluation are provided in the body of this report.

i Evaluation Details The team, consisting of 2 OA Engineers and 2 Plant Engineers, perforced the i

l evaluations. Each document was reviewed by each rember of the teae. Each item was dispositioned by agreement of the team members.

4 The scope of the 4 member team's review included evaluations of the actual i

work that was performed by the craf t and the activities perforced by the OC ,

inspector. The OC activities evaluated included:

l I

1) Preparation of the Hold / Witness / Monitoring' Point (HWMP) Notification

2) Approval of the Maintenance Inspection Checklists (MIC)

. 3) Field Inspection of the activity.

The guidelines utilized to perfore the evaluation were as follows:

1) Adecuaev of the FWFP Notification OC incpectors prepare the NWMP Notification and attach it to the work document. This notifies the craf t that OC should be present when

these ac tivities are perf ormed.

Each team member reviewed the HWMP Notification to determine that appropriate Hold / Witness Monitoring points had been specified. The team meebers evaluated the scope of work perforned and actual work performed. This ine.luded consideration of the safety significance of

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Surveillance Report No.: 850209B Page 3 of 6 the activity, the recuired craf t skill level, the previous work performed on that hardware , and component retest requirements.

2) Adecuacy of Maintenance Inspection Checklist .

OC inspectors document inspection attributes, acceptance c riteria, and results of the inspection on the MIC. The team members' evaluation of MIC's consisted of the following:

a) The scope of work to be perforced and the actual work performed.

This included consideration of the safety significance, skill level reout red by the craf t and QC inspector for performance of this activity, previous work perf ormed on the component, cause of failure if appropriate, and component retest requirements.

b) Conf ormance to appropriate standards, specifications and design documents.

Each tear cember determined that appropriate attributes were specified and adequate acceptance criteria was provided.

3) Acceptabilitv of Inspection The team member's evaluation of the impact on the quality and function of Fardware due to QC inspections perf orced by personnel with cuestionable certifications considered the following:

a) Scope of work actually performed.

This included consideration of safety significance, required skill level of the craf t and OC inspector f or the actual work docueented.

b) Extent of procedural controls f or the work activity.

This included the evaluation of the adequacy of established acceptance criteria provided in the MIC, the procedural controls utilized by the craft, and the programmatic controls utilized for retesting the hardware af ter the work activity was conpleted.

c) Assumptions eade concerning the skill level of OC inspectors with questionable certifications consisted of the following:

1) The OC inspector had limited technical knowledge in the activities which he/she was recuired to inspect.

ii) The inspector had adecuate knowledge in the mechanics of pe rf orcing inspections. The inspectors meet the reouirerents f or Level I inspectors pe r ANSI N45.2.6-197 8.

d) Activities determined by the evaluation tean to be within the skills of all of the subject OC inspectors with questionable certifications are as follows:

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! Surveillance Report No.: 850209B Page 4 of 6

'l' '

1) Like kind t eplacements

2) Determination with reterminations of electrical components l 3) Minor disassembly with reassembly of components -

! 4) Verification of cleanliness

5) Reading gauges, meters, and charts I

6) Monitoring procedural compliance

7) Ability to f ollow specific instructions, procedures, and l d rawi ngs E) Utilization of simple reasuring devices j 9) Determining visual gross damage of parts 4 Itecs e and d are considered conservative in that all inspectors j involved held valid cerfications in other areas, which assures basic knowledge of inspection program requirements.

i Results:

4 j There was no adverse impact on plant hardware due to Ouality Control i inspection activities. The team concluded that the ma,iority of work perf ormed j was within the normal skills of the craf t and QC inspectors and required only minimum or no instructions. The team determined that soldering, crieping

]

i complex component disassembly / reassembly (e.g. pumo rebuilding), fire barrier installatior. and initial terminations (new installations) are exangles of

] activities that would reouire enhanced skills of the craf t and OC inspectors or adequate instructions. The team determined that adequate instructions were provided to the craf t and OC inspectors for these activities.

A The team reviewed a sample of 53 Preventive Maintenance Task ('MT) sheets.

7 The teae determined that OC coverage was adeauate and the work activities were l within the skills of the craf t and inspector. The PMT sheets and associated Feveating Fork Recuests (RWP) provide adequate instructions to perfore the activities. Due to this evaluation no further evaluations were conducted on 4

PMT sheets and PWR's.

4 1

i Field verifications were utilized as strictly a confirmatory step and provide

! additional confidence in the results of the work doeurent evaluations. The l following is a summary of the verifications perf ormed:

1

1) WR $46070 - Verified cable ID, E27000 application, quality of j termination WR #3226 I,

l 2) VR 5 4607 3 - Verified proper type of lug for wire size and proper crito WR #4215 i

j 3) WR *46072 -- verified heater size and type, wiring condition, proper i lugs operable WR f!4839

, 4) VR 743629 - Verified vi re type, cabling termination accuracy, proper

! lugs and crimos WR #27853 i 5) WR #43627 - Board installed. If board was not installed the SA I system would be disabled. WR #7661

'aa .

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1 4

Surveillance Report No.: 850209B J Page 5 of 6

6) WR e43631 - Verified breaker replacement , 30 emp to rerlace 10 amp, termir.ation and wire size and type WR #9296 j 7) WR #43632 - Verified phasing per E07000 motor direction of rotation

• j correct , motor terminations were inaccessible WR #4840

8) WR 843628 - Verified proper installation and density of fire barrier 3 VR #26859 These verifications were perf ormed utilizing MIC's generated by a certified OC l The inspection team participants included OA, craft, and certified inspector.

OC inspectors. The inspection was witnessed by the site resident NRC Inspector.

The results of each work document evaluation were recorded on "OA/ Engineer Evaluation of _ Work Document" sheets. Attachment A provides a sample of the i evaluation results. The enti re set of Evaluation Sheets are available in the OA data file.

d

Conclusions:

(

l The results of the evaluation and field verifications provide assurance that OC inspectors have adequately verified conformance to applicable documented 1 instructions, procedures, drawings, and specifications as reauired by the 00AM

. Chap te r 17.2.10, Pev. 7. Since the deficiencies identified with OC certifications had no adverse impact on plant hardware, the level for Recuest J f or Corrective Action P8502-035 will be lowered f rom Level I to 2.

i l

The team believes that process monitoring of on-going activities needs to be increased in the areas of like kind replacement, criccing, and terrinations.

The team believes that these activities are important to safety, and OC does

> not have adequate documented justification for the current moni tori ng frecuency. The team recoemends that QC evaluate the current process monitoring f recuencies and establish a basis for subseouent monitoring 4 activities as required by the 00AM Chapter 17.2.10, Fev. 7. This condition is

provided as a recommendation and not a RCA due to the corrective action initiated bv QC prior to this report.

l Although criteria were established for the performance of this review, the

evaluations included opinions of the team. However, the opinions of the team j

we re conserva tive. For example, the team did not take credit for the Callaway Plant Training and Qualification programs for the craf t, during the_ course of l

the evaluations. These programs provide specific instructions for maintenance

craft in defined areas. In addition, Quality Assurance Audits and i Surveillances, Technical Specifications surveillances, and other associated program =atic controls provide an additional level of confidence that work activities are conducted correctly.

r in addition, management's actions taken in Quality Control prograe revisions will provide Union Electric Company with an enhanced and more effective inspection program for verification of compliance with documented instructions, procedures, drawings, and specifications.

I

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1 Surveillance Report No.: 650209B Page 6 of 6 If you have any questions concerning this surveillance, contact J. V. Laux, Supervising Trgineer, Quality Assurance Technical Support.

f - ffh , ~/.N A + . 23 . g .

'

• T. W. Stotlar

. M. Pobl Engineer f OA Engineer f/k' 8 I TVS/ldj l cc: AD55850209B ( As a OA Record) j.

AD5SS50209B OC (file)

T. D. Field w/a  !

R. L. Feuers w/a V. H. Zvanut w/a J. V. Laux w/a J. C. Gearhart w/a 4 F. ' J . Forck w/a J. P. Veatch w/a j T. W. Scotlar w/a l L. E. Pe t ty w/a P. T. Appleby w/a J. E. Davis w/a T. L. Shaw w/a V. R. Campbell w/a

1. M. DeVincenti s w/a S. M. Pohl w/a

3. M. Sand w/a ,

G. V. Polowy w/a J. P. Lueckenhof f w/a V. A. Vitt w/a P. D. Eseg w/a J. R. Meehan v/a l K. K. Eammann w/a s

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Attachment ^

L" SH.8502093 . ..

t } A./ ENG.I.M.EE.R. .l'.V.A.l 1f.A.T.I. .ON .OF WORK DOCIfMENTS

- Page j _ of. 10.. ..

- Participants thwnment Title Wo. r k . R. e.1u e s t. .

1EP

. __.- \:WP TWS .IPl.

Closed Comp. Actual ~ lank l'erl ormed Open Document Ill spos i t I,o_n_

1. D. Work Performed By s}nestlonable 1)CI ,

Number MIC Adequate C EN-V-lI Cleaned Valve Stem MIC/ RAM 5222 Insp., Visual within skills of...C.I. O This is Non Q, "Q" C 30614 FC insul. Modify Insul. Insp/in.n 2 ".isual . .......... . .

spec if led C

3801 FCP-AN-1001 Nothing IIWMP Adequate this is Non'"q" C 7640 RM Calibrate Analyzer. IIWMP/RDS Non-specified Replace I*fiter q__

IIWMP/VPP Non-specif ied IIWMP Adequate 3686 NE01 & 02 Material IlWMP/Nonr' _ . . _ _ . _ _ _ . ..'

( . . .

4821 NE01 6 0. __

d.1othing C

MIC/VPP MIC Ade'lunte 4903 NE01 fFrtedBrushes ilWMP/VPP _IIWM.P. .A_d.e qu.a.t.e. . . . . ___ _ . . _ _C . ._

6963 NE01 Cleaned gen, .... . ..._.

1.1; - . . .

tilC Adequate Enough inst .

Insp./RDS n i v e n f o r. ..f. }.C I. .t.o Pe.r.f_o_r.m__ .. ._......C_.

3227 NF106 Reland wire ins.

4 t

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Attachment A to SR 8502098. ,

QA/ENt:l NEER EVAL.tI.AT.IO.N 01, WORK IH)CIIMENTS Page .2.."I.10.

~

i Parttelpants Date of Evalunt ion.3/19/g3..- .

GWP Doiument Title Work Requests I.El,, ,

TWS .I I' t .

1:lo u d  :

Comp. Actu l Task l'erl ormeil Ojuan . .

Document Dispositlem .

Number 1. D. Work I'erformed ny. .. ques t l onab.l.e. . .Q.C1

.. .. ...... ... ... _.. .-...... ._ _ -.._C. ..._ ._

-. 5441 .. . ._- N . .E~10 6. . .. _. . . V.o. i d. e.d . .

3

__. .__.. abtain document, No QC .

q i NE106 Scheme Check llWMP MissinR. ...... i.n.spe.ction required i 22001 .. ..

Visual verif(cation to MIC/JI.p

• C insp/RDS . I .V 1 sua l. .Ve rif .. .. If98. Within the skills 2 '

3225 ,,,,

NE107 ,,

Reland Wires ,,

of QCl Obtain document calibrated No llWMP Sheet S AT . .Na. . .QC. .i n s pe c t 1on. . . . _. __...C._.._

l 21996 NE107 Scheme Check required Calibrated SAT C

NE107 Rep. lac.ed. Relay.' . .. l.l.W. M. P. /.JI.P..Non-sPccif j ed 5862 ..

i Install I hr. fire C MIC Adeq.uate b.a r r.i.e.r. w..ra. p._ ._.. . .. MIC/VPP 34.334_.. S E. .. R.E.- 1. 8 _ .

Retest SAT llWP Aslequ. n. t c. _ . _ _ ___ . _ C_ _ _ . .. .

i 1560 CC-536 Calthrate & JDstall llWP. /.II..P. . No. P.-sPPCi fied

.. . s 1*ound connector MIC Adequate ____._C__.... .

RCK. . 0. 5 A. _ .. . bro.ke.Ipose. .... _.

Bf lC/S.II.. . . . . . . . . . . . . . _ _ . . . . . .

34404._.

2 ...

4 . . .. ..... . . _ . . . .

attarnment. ,,, A . , ..

to SR 8502098_. _ , .

QA/ENGl,NF.ER l'VAI.liAT,10N OF Page 3 of 10

• WORK DOCllMr.NTS .

Participants Date of Evalunt ton 3/19/8$ - - - - -

l'or nme n t Title Work Request,

_l.EP, ..TWD.

,,TWS _SMPo

.__.__.....__._____.. _4 Actual Tank Per f ormeul

. ..... liluposI.t.l.on. .__.._.__ . . . . _ . pen .

romp. O flocument By Questlonablc ,QC,1 Work PcrIormed Number i. D. ..

Adequate OC coverage IIWMP RAC, MIC/RAR C Install booster II/T Non Q 32194 CGI.04 f an brac Inti I"SI? . / R An WR was "Q" however work Install access ,was,Non Q,HWMP, adequate ,,___,___Q,,__ ,

IlWMP/ FRO . Non-spec i f. igd .

GI .D- 315 , , , , pane l .pe r .CM1?

25614 or \bove C As,Above...WR.25614.... ...... .6s Above t!R 75614 25615 GLIh316 _ _ k.'R 25614 ,_. ,,.,

C Determ., remove MIC/RAn, DWP._ _._. ......___.. MIC.. Adequate._ __

675I Actna, tor _ __ _ ,_, Inspection visual within GI.-[17.-.3 2 -.2 . insp. RAn Replace gasket I. ). .C. l e.a n. l. i.n e s s_ .2 ) _T.o. r.qu e . _ .. .s k.i. l. l.s ._o. f. .c. r.a f.t. .a n_d_QC.I_

18796 GL-V-004 torque bolts. ..

Snme as C Same,a,s,WR,18796 _ , ,, _ ,__,, S a m e a s ,,WR, ,1,8 7.9 6, _ _._ ,, ,,,,

18120 G1,-V-00R2__ WR,18796_,,,, , , , ,

Within the skills of Swap A & C Phase Insp/Jr.P C OCI l.),,Ra y, Cl c,m , ,2 ),,,Re t e rm .

SGlcl0D _ ___ n.n d..,R ay Chem , , , , , ,

i l 4.840_ _..

( .... -__..... . .

l

- . _ _ . . . ~. ..---.. .. _-_-. ._ ...._ _.......

l.... . . . . . _ _ . . . . .

I

Attachment J,,

' to SR 8502098 - --- -

QA / E,NG I N.EE.R. EV.Al .ll AT.I.O.N s i F Pa F.c 4 "I 10 WORK luiGitMENTS Participants Date of Evaluation 3/19/85 TWS TMD/GWP thirument TItIc Work Request, I.EP SMPo . .

Closed j Dim p . AcIual Tnnk Per f ormeet Document Di spos i_t.i.n.n. _ Opeu . .-

1. D. Work Performed By. Q.ues t iona.b.l.e..QC l ..

Number a

.MIC. . A.dequa te C ..

7690 GN-III S-9 Re p l.a c. e . . . . . . . .. .. MIC/Rng . . .............. .... . c n not ver led  ;

' Replace Card Retest SAT C GN-PY-938 and Cal. IIWMP/Non-specified

3577 MIC/VPP insp./RDS

~ '

Y1IC 5cicquate insp. visual GN-TE-60

.wi

+

C-Replace. Elements . 1.). 1,, t. k. o. .k i.n. d .2. ).. . R. e t e . m . . . . . t.h. i.n. s k. i. l l s. o f..Q. C f l- 5._7 3 0. _ . . .

t 62 _.....

... Retest SAT i

Removed and sent i

l .II.W.MP. .A.d_equa t e - = - =C .

8408 GN-TR to vendor... .. . llWM.P/.R.AM .N.on .sP.ccif icd

- ~

Removed C IIWMP/ RAM Non-specified IlWMP Adequate r 31471 PBBotC Articulation Arm Vendor support provided Reassemble RV after I nsp/S.11,, RAM 4 26672 RBB-OI fuel load .

1) GO-NO-GO hole sizinP' InsP. visual C

t 2T Clean 1iness

3) installation of econoscal _-. -._- . . . . . .

J.

i ..- .

1 t

- - ~ . . . . . _ ~ . . ..

. . . . . .. .. N

.m +

....m i

m

. .g . . . . . . . . g . ee.,, ego m w 6-.. . . ..

..... ..&. .hh .M..MM..NM

. 4D N. 'N .

• -.S+.e,e. . . . . . m .- es e.& e e .

I Y .. .. s . a......e....

e.p .. . . . . ....e . * - * * * * . . . . . - . . e . . .

U . .me '. .. . . - - . . . . . . . . . - . . . . .  ?

1

.. , . . . . . . ~......... . . . . . , . . . . . . . . . . . . . . _ . . .

... .. . . . - . . . . . . . . . . . . . , . . . . . . ...4

. .4 .

i . . _ . . . . . . . _ . . . _

1

... . . .. . . . . 4 i e .-...+ ....

i .e . . . . . .*. * . . . . . . .........ee k i .m -. . e.me--.. . . g e. . . ..

8 _w,. .. . . . , .,.lp. .. .. e .

T I

1

. - . - .. - . - . - - - - ~ . . - . - . - . . .- . - . - ~ - - . - . - - . - - , _ - - . . . . - - . - _ - . . . - - . . . - -

I Attachment ..A..- . . ,

i to SR -950209B- ~ - -

QA/l'.NGINEER l', val.ltATION 0l** Page 5 of 10 EURK i.iOCliM'E'N'rs' ~ ~ .

Partleipants Date of Evaluation 3/l4/85 Document Title Work. Request.-. ,

f..EP. . S. M. Po '.

SMB,

. IWS.

Closed ,

Comp. Aef tvel 'Innk l'er l'ormed Open l Document Work Performed ny Ques t.l.ona.b l e. .QCl . . . . . ......... isposItinn D

Number I. D. .

insp/JLP, Vpp MTC Adequate, inspection  ;

Remove Strain gauge M I C/.ll.P 1). .I,ike .k ind . 2) .Re tcrm . . . ... . visual within the skills C  :

2683 send, t.o. vendor BC-PT..120.. ...

of craf t and QCI

. . . . . . . . . . . .. . . . . - . - ~ ~ - - - . .....---- __.~.

MIC/.II.P insp/VPp MIC Adequate, inspectinn ,

Replace. strain visual within the skills C 2 6 8. 2 . _.. . .. BC P.T-l.?O. M,a u g.e. . . . . . . . . 1.)..I.tke kind.2) Reterm as of craft and QCT determed. t t

.... ....--- --- - . - - - - . - - - - - - i l C Voided Voided Voided 1837 RG-PT-120 No like kind verification specifled. Retested SAT C i 00606 BG-TB-127 Replace card.... il.WM.P./ R.D.S. . .N.o,n. .spe c i f i ed MIC/RDS insp/JLP MIC Adequate. Inspection visual. Retested SAT C 1.). .L.i k e. .k. i n q 4858 BC-TE-1.07_ - . R.epl.a_c.e. .R.T.D. .c.l.e.m.en,t. '

rBG-OSB rrepare pump for C ilWMP./.P.I,Il. . No.n. .sp.e.c.i.f.i.e.d. . . . - .il.W.M.P. .Adequa t e _

. 37779.... uni.t. 2 . - - . . . .

s h,i p.m.e n.t. . ...- .. . I e

npare . .....--..--.

i . . . . . . . . . . . . . . - - - . . - - - . . - - - - - .

l . . . . . . . . _ . . . .

... ...... . . . _ . . _ - . , - _ . . - . . - . . . .......... . .....-... t i

... .. ..... ... .. . . ... ~ . . . . . . . ..

l . . . . - .

At tarlimen t ,3, to SR 850209B - - - - .  ;

QA/ ENGINEER EVAI,1 FAT,10N OF WoltK 110ClfMENTS page 6 of 10 l'a r t I c ( pa n t s '

D.mument l'ille Work Request

. l.EP. SMPo. ,

TWS SMn .

'I a n k l'e r f o rmed Closed Document Comp. Ae t u:: 1 '

Work l'er f o rmed I'v Ques t i onab l e, ,Q01 , , , . Dispps i t inn, Open Number, I. II .

, , ,!R written concerning QC HG-liC T - C ,

17829 8357n Swi tcli input leads insp/VPP. , , .

,not being notified. -

IR closed BG-l.n- I.lke kind replacement not See SR for C 5769 106C & D Re.p l a.c e .ca rd .. .

llWMP .No.n .s.p.e.c i f. i.e.d . . . ... .s p.e.c i. f. i ed. .

discussion

~ ~ ~

RG-l.CV- IR written for not Ins.p/VPP no t.i.f y i.n g Q C.,. .I.R. .c l o s ed C

?7333 Il2A Ca l i b. r.a t e I.B. .Ca rd. .

RC-I,QY- 1.lke kind replacement 2141 105 Replace card 11WMP/RI1S Non-sp.ec.i f.i.e.d . . . _ not s p e c i f i ed. . S.e.e. _S.R. .f o.r. ...

. - .__._._C____..._

discussion.

~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~ ' ~ ~ ~

BG-I,T- W i red HG-lir-I l 2 3195 1.49 w l,t li, HC-l.T- l 4 9 , , M I C /,1 1.P, , , _ , , , _ _, , _ , , _, __ _ , _ _ ,M I,C_,Ad,equa t e _ _C__

RC-PI- MIC Adequate M I C / R AR ., Di,0, , ,I n sp,. _0,I.0 _ ,_ , . Inspection visual C 28017 190 Re i n s.t a l 1 ,I _n,s u l...._ .

--- .- - . = . _ . _ . . . - _. .. , . . - _ - . . . - . . . . .. - - . _. ._. .

At t acliment ... A.. .

,t to SH 8'iO2098 -- - --

e!A/I'NGlWEER l', val.IIATION OF Pa s',e __ 7 f

' . WottK 'O'siClHliNIN o f. . . .I O .

l'a rt I c I pant 9 Dat e of Eva lun t f on.. 3. /.14 /_85..- . __ ,

Document TILle Work, Request, . ,

. l.EP. . S.MPo SMn .

T.WS .

Clo9eil l Comp. Actual Tank Petformed Open Occument. ... . . . . D i s po s.i.t.l.o_n.

Number 1. D. Work Performed n y qu.e.r.t.i.o.na.b l..e. .Q.C.I. . . .

MIC/VPP insp./RAB MIC Adequate insp, visua!

• C 00770 Replace xmitter .. 1) l.tke k .wi th in ,sk i l. l s o f c.r.a_f.L . . .. __

.._.. ..... nG .. _rT-111

..~..-. .

M.Term . . . determ,.

. . . i. nd 2) C. l.eaand nl QC i.n.e. s. s. . 3

. . - . . . . . . . . . . . .. I

+

. . . . . . . . . . _. . .. MIC not consistent with 3

?

pre,vinus WR 00770. Retest C 33177 BC-rT-Ill Replace xmitter MIC/DWP, , . .. .

Satisfactory t

. . _ . . - - . . - _. - ._............ i MIC did not address cIcan1iness. Retested C __. ,

5798 nG-TT-183 Reptace xmlt.ter. .. M.1.C./.vPP. . . . ....-.. ..........

Satisfactory. ,

I.tke kind not verifled.

C It.e.p.l.a..c.e. ca rd. .. . . . . . I NH. P./.R.D S .. No n.- s p e.c,i.f. l ed . . . . . .S.e.e..S.R. .f.o.r. d.i.n.c.u.s.s.f.o..n 8569._..

. .. . B.C...T.V. .l 1 I.

Install chart mig Adequate C t 3R646 RG-rY-11I recorder to monitor MIC/Rfn t

( tiput /otst pu t

_ . . . +

. - . .._ + . . . . . - . _ . 6 k

L v

s J

. . .. .. . 4 . . . . . . _ - . . . . - - - - .

.... .. . . . . . . . . . ~ . 'I

't

_ . _ . _ . _ . . _ _ . . _ . _ _ _ _ . , . . _ . . _ _ - . , . . _ _ . . _ _ _ . _ . _ . _ __ _ _ . _ .. _ . _ _ _ _ _ - . . _. _ m.__.__ __m i

Attachment A ,

t  :

to SR .850209B.. .

yA/ ENGINEER EVAI.IIATIOM 01'

' WORK DOC'th1E'N1 S~ ~ '

Page 8 - oI 10 -- ..

Pa rt Ic i pant s Date of Evaluation 3/14/85 Document Title Work Hequest.

..L. E. P. . SMPo

.TWS. SMH.

i. . Cl"sc'l comp. Ar t n.i l Tank Performed

Document H. . B.y. .Q.ues t t ona.b.l.e. .qc t . . -

.... hispnslt(on ,

Open .

Number I. ..Wo r.k P.e.r.f.o.rm.ed. .

Replace Hechanical Verification of Procedure steps MPM-nc-QP002, -

. C 4260 I.n.s. p /.R.. AB -

. . . . . - - P_BC .05.A. . . . .Sea l. .. .

- - . . . . . . . . . ~ . . .MTM ./.7.-OW001 within the

.s.k i.l ls -. . . -- - -.- ---. . - - - - - - - -

Replace Mechanical Same as above WR 4260 C 3.269..

P.BC-. O. S P, . . . Seals.. .. . ... in.sP/RAB.. . . . . . . . . . . .

' Inntall concrete C

.M. I.C. Ad e.qua t e . .. . . -_. . - . _

33538 N/A curbs CMP-84.-0508.. M.T C./.R. A. R. .. ... . . . . . .

MIC Adequate Term & determ MIC/JI,P, VPP i . . . . .. .nsp/VPP visual within the skills 1

4 C BG-FI-138A Rep l a c e, .m.e t e r. .& c.a l 1 ) T..e r.m. .&. .d.e t e.r.m . i 1852 .

of craft and QCf

. . - - - . . . - . . . ~ . -

...... . -... . . . . . . . . . - . . ~ . . . - - -

I,lke kind not verified by fnstall..K...ca T..... C 2921 HG-FQV-215A new card IIVMP/VPP None Specified QC. See SR for discussion.

Retest SAT.

Visual within skills of f

' Remove, Reinstall C insp/ RAM - .- ..__. craft and QC[

B.G__F..T. .i.l 0. _.x m.i .t.t.e.r.. . .I.n.s P.cc.t.,. .

i 27448. _

.. .- - -. .. . . . . - . . h i ..................-..a ~

4

-...g . *- . . .-- .-. . . . . - * ..*-w*-- --

4 , . . . . . . . . . . . . . . . . . . e ..e. . -. . -..-.. . . ..

k . . . . . . _ . . . . . . - . . . .

! t 4

i **

f . ..

m.

e r -n-v -

r v v , - e

. _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . . . . . _ - - _ . _ _ _ _ _ _ _...m . . ... _ _ -.m. _ _ - - _ . _ _ _ _ _ _ -_ . . . . . _ _ ~ . - _

Attachment -..A ,

k tn SH ,85020')n . .  ;

q A/ENG I N.EE.R . EVAL.t'AT. IOM. OF WoltK 110Cl!MENTS Pagc 9 o f. 10_... .

i Participants Date of Evaluatinn 3/14/85- -:

l D. ocument Title Work Request. . ,

i 1 E_P__...S.M. Po .  :

t TWS, SMR * .

. . . . . ~ . _ . . - . - - - - - . . - . . - . - ,

. ~

4 C.l o.s ed comp. Actual Task Performed Op.en nocument W By .Que s.t l.ona.b.l.e. .Q.C.I . . . ..... Dispositinn .

. or.k Perform.ed ...

N.u.m.be. r . .. _ I .. D .. - . . .

.M. I. C. . A.d. e.qu a t e C_

rep laced,& Mod...

M I. C. / R An. , D.ih. . ........... ..

30618 Insulation  :

Ad. e.qua t e 33704 Insulation Replaced.& Mod.. MtC/.nl.o. .. . . .. .

.M.TC..did MIC not require C  !

MIC/HDS. No i.nspe.c.t t.on. . ve. r i. f..i. c a...t.i.. on .o.f. . l_ _i ke .k.. i nd .

7637 BC-TS-137A Replace. card .

See SH for discussion.

. . _ ~ . .... - . . .. . . . . . . . . . _ . . .. . . . . . . . . . .

i

. - .. l MIC Adequate ,

MIC/DWp Temp Mod 84E44,5 _ _. . C _ __. _ >

24735 DP-RG-02B Re pa. i r.__B r.ca.k e r. . MIC and Inspection within  ;

Install on pump i w MTC/SJ1, skills of craft and QCI -

_C  !

2 16495 PBG-04 Within the skills of the 1

k.eversed output s.e. . insp/

n . .a r.eho.u . . . _tis I) Cleanliness C i i 33384 l'RG-04 of controller 2) 1.ike kind 3) Switching craft and QC.I ~

.. ...--.. - ~ . - - . . . . . - . - - . .

. . . . . _ . . Iines 9 Replace head insp/ RAM !) Parts 2) Torque Within the skills of the C i i .

ga.s.k.e.t.s. . ..- 3.). .C.l.e.a.n.l.i.n.e.s.s. . . . . ... _ - - craft and QC.I 4 3.2784... P R.C_-04 -.

1 l

4

. _ _ _ . t i

... .. ...... ... ....... .._..... . . . . . d-1 . -_ . . _ _ _ . _ .

i . . . . . - . . . . . . . . . . _ . . . - _ . . . .. .

. . . ... . . . . ....-........... . . . . . . ..-....... ... . _ . . . . . . . - . i

- _ _ _ - ~ ~ .

? .. . . . . .. . . .. . _ . . . . ._ .

j . . . . . . . .

. _ = - . . ., =r -, - . . .

At tachment . . A ..

-~ -

yA/12;1F3EER. . EVAL.ltA

.T ,1ON Ol' Page 10 of to ,

Wol4K Dot.In1ENIS .

Pa rt Ic I pant s Darc of Evaluat ton 3/ t4/85 Do.nment l'i t l e Work, Request.

I EP._ .SMPo

. _TV. S . SMB.

Closed Comp. Actnal Task I'er formed Open Document Bv Questlonable ,8{CI Disposition Number 1. D. Work I'erformed ,

filC Adequate IR 84-820 BC-IICV- 128 C

,yritten_to address _QC__ _.

19979 BC-1CV-129 Hework. Air Supply _ ff!C/CS. . .

failure to witness job.

BC-PCV-131 BC-TCV-381A SNUnnrR Modify 1nsulatton, IMil'/GS .Non-specif(cd .. .. _I!k7!P . Ad("lua te 2160') nc_ , , . . , .

Pfl C/ RArt insp/ RAM Wittiin tiie skills of the lit ;- rT- l 'i f. ,,_...C.,

1) Verify. integrity craft and QCl visual _ ,,,,.

24568 RC,-l;'T- 16 0 , Tighten Vent Cap does not leak BG26-R505 6 Modify insulation IMiP Adequate C R507/242 .lacket IMfP./.CS. ..N.o.n. .s.p.ec i f ied 26293 .. . .

M I C / DI.O . RAR Inspected DI.0 Within the skills of craft Pfod i f y insulation C 30403 .lacket 1) Remnval 2).T.aggi.ng. __.._. a.n. .d._O.C.I. v i sua l

.. .._.... I n s.u.l a t ion 3) Securing Modify Insulation C_

insulation .lacket IM4P/CS _ Non-sp.ec.if led _ _..__ _. .IMfP. Adequate 305R9

bd. -

MANAGEMENT SYSTEM ALLEGATION j RUN DATE: 850903 ALLEGATION NUMBER - RIII-85-A-0021

/I

. DOCKET / FACILITY /UNITt 05000483 /

/ CALLAWAY I /

DOCKET / FACILITY / UNIT /

/ /

DOCKET / FACILITY / UNIT

/

iDOCKET/ FACILITY / UNIT

ACTIVITY TYPES - REACTOR

' MATERIAL LICENCES -

FUNCTIONAL AREAS

- CONSTRUCTION TWO LEVEL 3 DESCRIPTION - PROCEDURES NOT FOLLOWED IN CERTIFICATION OF QUALITY CONTROL INSPECTORS.

1 l CONCERNS -

I CONFIDENT - IMP SOURCE - CONTRACTOR EMPLOYEE i

/ R3 RECEIVED - 850205 BY - BH LITTLE

- (FTS1388-5695 ACTION OFFICE CONTACT - GC WRIGHT BOARD NOTIFICATION - NO SOFETY SIGNIFICANCE - NO i

SCHED COMPLETION - 850801 DATE CLOSED -

STATUS - OPEN ALLEGER NOTIFIED -

ALLEGATION SUBSTANTIATED -

01 ACTION - NO O! REPORT NUMBER =

REMARKS - THIS ALLEGEATION WAS REVIEWED IN INSPEC ION REPORT NO.

50-483/85002 (PARAGRAPH 4) AND INSPECTIf i REPORT NO.

i' 50-483/85$12 (IN DRAFT). THE ALLEGATI0t OF A PROCEDURAL j

VIOLATION WAS SUBSTANTIATED.

A 10 CFR 2.206 PETITION WAS ALSO FILED HASED ON VARIOUS PUBLIC ACCOUNTS OF THIS ALLEGATION.

CLOSED SYSTEM - RECORD CHANGED - 850715

! ENTERED SYSTEM - 850402

\*

RI e

.J/ . . . ,

g 5

6 7

- E 9

to 11 12 5

=

~

M 5* J .

,a p -

Y v"

s<h v -

Q hD o e L '

X _

9 e + .

s E

r W

~N

e ' .1 Q r1 Une 1985, COLUMBIA, MISSOURI 20 PAGES - PRICE 25'

~

UE adds 15 inspectors to roles of unqualified operating in December, generates plants, Garde said, including the CHRISTOPH SZECHENYI of the Tribune's staff 1,150 megawatts of electricity for Wdham H. Zunmer plant in Ohio, a UrJon Dectric Co. has identified customers in St. lauls and dozens of Madland, Mich., plant and the Mar-

= inspectors - 15 more than initial. Mid-Missouri towns such as Ashland ble Hill plant in Indiana. All three ly reported - who lacked quahfica- aM Moberly. The plant is 35 miles have been shut don for severe def>-

tions to ensure the safe operation east of Columbla. ciencies. Quality control questions and maintenance of its Canaway Mike Geary, a Union Electric have also been raised at the Co.

County nuclear power plant, a Nu- spokesman, said utility officials de. mardse Peak plant near Glen Rose, clear Regulatory Commission offi- chned to comment on their investi. Texas.

cial said this week. gation of the inspectors' work. "We Gaary said Union Electrie engl.

The official, Bruce Utile, said util- don't see a need for a blow-by-blow neen are carefuUy evaluating the ity engineers and auditors wbo account of what's being done," be }obs performed by the inspectors began icvestigating inspectors' said. But be connrmed that = in, with questionable credentials.

backgrounds last month have identi- spectors lacked certain credentials. "We're l* king at the nature of the 6ed about E inspetions performed Uttle said he erpects the utility to u ork involved," he said. "If it didn't by the E inspectors during the past require wrap up its study by the end of we*U probably a high level of expertise, three years. March. At that time, Ocary said, assume it was done A special utility task force has Union Electric wd! provide the com- all right. We'll also check to see if found that the n inspectors were mission with a report d its f% the work had been subjected to addi-quahfied to do all =0 of the }obs n- Utile plans to file a report of his own ti nalinspectiom."

viewed as of Friday, Utile said. The findings aM recommendatiom by The utility's engineers have not task force has found nw evidence of the eM M AprH. reinspected any areas yet, Ocary deficiencies in the plant's hard- In early March, the utility con, said Some reinspections may be dd-wan. cluded that seven of its present in- ficult, if not impossible, to perform The St. Ieuis utility is reviewing spectors lacked sufficient training tecause plant materials have be-about it000 = ork orders, said Utile

• come radaoactive.

or czperience in some areas d work a commissim inspector at Cal- they had been doing at the plant As A longtime nuclear power oppo-la way. a result, Union Cectric suspended nent, Kay Drey of University Oty, He said his agency win waft for the men from doing certain jobs. said yesterday she and the Coalition Union Dectric to complete its study for the Emtronment wiU file a peti-before considertry; action. He said Uni n DWe employed 13 d the tion asking the commission to shut the utility is conducting a thorough n inspecton, Uttle sad Seven d down the Causway plant.

de the r sh i

• kes all mr b-ne rs a r nd illie Garde a staff me ber with the Government Acteuntability whi belped

(**

d the tan -

Ct8 I"'

ula ry ion to shut d plant untu Union Electric can dem-

, Pro}ect, a pubbe in'.erest group in onstrate that the systems are Washingtan, D.C., voiced doubts. Nuclear plant inspectors check ,,f, ~,,

"The system had to have broken electrical, mechanical and civil en-don in a fairly significant fashion," gineering work throughout the plant, she said. "The NRC's appruch to includmg systems such as pipes and this is dangerously inadequate.~ valus in the rmte bidldmg. THE WEATHER j Utile said he cannot assess Garde said Danic! International

! whether the ury;uahfied personnel belped build Kansas' Wolf Creek nu. Cloudy Ioday, with a 70 percent influenced the safety of the plant clear power plant, which has been chance of showers. High around near Fulton until be looks at the plagued with structural flaws. The SC, with southwest winds at to to work ordes and, if necessary, es- regulatory commission recently 15 rnites per hour. Tonight,60 per amines the inspectors' fseld work. gave the plant near Burhngton, cent chance of showers, with the He plans to start that part of his in- Kan , an operating license, low in the rnid 30s. Tomorrow, vestigation on Monday. Inspection problems have turned cloudy with a 30 percent chance p 1he $3 bilhon plant, which started up at severa clear power of showers. High in the mid-40s.

. 9 Yearlongworkers' rift revealed in L E safety assurance problem:

By CHRISTOPl! SZECHENYI Shaw's inspectors "I would expect a supemsor to of the Tribune's staff competent in inspection phuosophy."

Friction between inspectors and their supervisors at Several inspectors said such a management attit:

the Callaway County nuclear pcwer plant had surfaced and supervisors' shortage of expertise spurr.d insp nearly a year before Union Electric Co. started inves- tors

• complaints to Powers' office, which 6d the au&t tigatmg its deteriorating quality control system, an in- outlined inadequate training, education and esperica

.ternal memo reveals. among seven of 13 inspectors - including Porten and Company documents show thatr 3'M " W sistant supervisor 1.M. Zahara - and spaded susp quality control supervisor Terry Shaw ordered inspec- sion of sorne of their duties.

Lors urder him to take technical problems to him or to an Following the audit's suggestion, the company C assistant supervisor before approaching other depart- pended inspectors from some tasks untU their qualif:

g ment managers. tions are established. Union Electric is also repeo g "In past weeks, there have been numerous instances some 12,000 work orders to determine whether disqr N demonstrating a lack of effective communication within fied men did inspections that could jeopardue

% the quality control department," Shaw wrote in the plant's safety.

e rnemo to 30 people, many of whom were inspectors. Ite St. leuls utility is also reviewing the credent:

"Our aim is to solve problems through communication, and work of 50 to 60 more inspectors employed by a 9 not create them." that helped build the plant, which sttarted genera:

But some inspectors said th!s week that they repeated- electricity in December.

~*

{ ly got no action fro:n Shew when voicing concerns about The Nuclear Regulatory Commission's inspector supervisors who were unqualihed to m..ke technical de- Canaway is also planning to review some work orde y cisions for ensurmg safety. In ad& tion, the utility con-hrmed today that mspectors took their concerns to Yesterday, the Fulton Sun quoted plant spokes::

Mike Geary as saying that "we have a good system h Shaw's boss in early December, nearly two months be- for recourse...I'm not sure why the inspectors 6dn't fore the utihty started an audit of problems. up the quality control chain of command "

Several inspectors said they did not trust some super- But today, Ceary adtnitted that statement was 5 visors because they lacked expertise in certain quality true. lie said he tad been unawart of the inspectors control areas. On a day to day basis, you're going to forts wben he talked to the Fulton newspaper, have technical questions," said one informed source lie conceded that seven or eight inspectors had On who requested anenymity. " Management wants us to go their concerns in early December to Paul Appleby; to them for answers, yet bow can they &seuss these assistant plant manager who oversees quahty con problems when they're not technicaDy qualihed?" operations.

One assistant supervisor, Vernon Porte11, recently lost Geary said the inspectors' concerns ",ere (t certihcation Ior two types of inspections at the $3 bilhon taken seriously." After the interviews, deary said, plant naar Fulton. Reacting to the fmished autt, dated pleby put together a plan for corrwtave actaon. Ch Feb. 22, plant manager Steve Miltenberger suspended said he 6dn't know what changes Appleby had )

PorteU's certihcation. Portell, however, retains his su- posed.

pervisory role. Inspectors said this week that they grew impa:

"A supervisor does not have to be certified at any level with Appleby's efforts, and so they asked Powers' q~

in any &scipline," said Robert Powers, assistant maa- ty assurance othee to investigate. Powers noted tha ager of the drvision that oversees the effectiveness of spectors have the right under company pobey to G plain to his division.

Auditors concluded managers had broken wri THE WEATHER ***P'"7

'*$ '" **"r*"a'ta"c*' by **N

'."The inspectors check electrical, rnech inspectors cini and material work throughout the plant, inclu Falt tonight with a low in the upper 30s. MostlY systerns in the reactor buildmg and other key cor sunny tomorrow. High around 60. pents.

MARCH 7,1985, COLUMBIA, MISSOURI 52 PACES - PRICE 25'

alifiedplantinspectors The Canswey County nuclear -

power plant, with the Wissourt J River in the distance.

' Cavid nees photo

. * . s 7

,. , . u.,.1. F Or/ds((MhsE--.- W *.W *n .,

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• c.

WD ~-

u.

.4 . ,

34.3. %_

k$ wi

y,,

• w ?*tA a- Regdatory cotwussion inspector 96 Utue said s.destepping company

$ t pobey vloistaa federal rden. Ren.

p- g ] $c 3'

s' anted beenses to bund aM operata

= . w Cataway,l'nlon Dectric pledged to uphold NRC regdatms sa weU as company pohcies, Utue noted.

On Tuesday, Ceary said, "We do e not believe we have comrnatted any violauons." Bat Union Dectnc, Ut-I. . Ce stressed, knows the rdes.

7 - Until the utihty and Utue com-l f' plete their reviews of the cert. fica-

• < con problem, Utue said, the prob-ll

' lems are cons dered " potent;al vio-

',4

' T. ,y$* I< lauons" that codd lead to dwtphr>

,, m .#4. v . . . . .> .f,' ary actice or fanes by the comT.la-

. d alon.

m In addjuon to suggesting that the

, f,

.*j eertficauons be pd;ed froen the p ;

. Mg.,

seven inspectors unta their qual.fo ceuons are estabuabed, the audit E. ,

aos -

/ .

proposed several other steps f or im-

/ 5

' proving the certifwauon pricess.

k' .j In responM, Powers said, e group J i of Inspectors, managers and quality p r tirannet worters wti recommend specific thanges to match or etceed L4 g TL'- d w the prevaihng indarry r.andards

&.sq-Wp_= m _Q --

for certLficauott.

Posen said the review of mair:te-

-.' ,g r.ance work orders would show I whether some plant syr. ems need F

< relAspection. Unt3 the review is fir >

lshed Ceary added Urdon Doctric

- has contracted to bite two more in-F apectors to meet the wortjoad.

Ceary said the men everage two in-

['

spect6ons a day, In explaining the ortgtn of the eer-8 canon problem. Powers said some inspectors had been hired by Urdon

' Dectric from contractor Darde! In- ,

ternauonalCo.Then, company rean-l agers geve them new ceruleauons based on.everty broad interpreta-tions of indur,ry standarda, Powers cald/ he standards say efficials b stay take .se;ated expersence inta f

• I , etnsidersuon tor y. .- ., ~

in certt>trg Said one inspector: "They abused inspec-the term *related extenence? The bottom kne is we have a lousy man-ogement situsuon."

I Two plant workers close to the problem said enanagers had hoped for cervective actice: Canavsy plant manager Steve M3- 'ts own rules by esempting some to save rooney by tams inspectors for muluple dates instead of fartng ee quahty control as- tenterger suspended PorteU's dual men from the ersterta without docu- more employeea.

Vernon Porten, certaficatAon. He retains his supere menung why, After tirashtrig their report, aude Powers derued cost savings sa e ry expertence in civ0 aory positon.Ceary said. but be has inspections, fields be been barred frori further ettu oc k,rs whitued the hst of unquahfied mouve. "We felt there were some electrical lnspectAons. Inspectors to seven by vertlytag prograrn weaknessea tid perhaps resporWble for approv.

• Most of the 13 men had authority techrucal prowess with documents some judgments that shouldn't ha ve teen made. I consider any violabon on cf inspectern, quah- for inspections in more than one of er in interviews with the other in-of the program as a sfgt.llecant core Terry Shaw,en the four tochtscal categories - to. spectors, atace Oct. 22 violat- tahng 3g certafleations among them

• On five procedural points, quall- cern."

rWes for cerulying in. - but half of those eeruficauens ty controt managers dodged Uruen This story was ampded aid erst-were found queouenable. In same Doctric's own written pobetes for that shee recem- cases,the men &d not meet ertierte proper eeruficanon et the inapectors tem ey Tnoune reporters avtatoph certif 6ed far two technb accepted withan the industry. In charged with erisuring Ce!;away's .tserheng asd DWores 27uskennan Porten. tast week, emers, Useen Doctrie had isnered eare opereuen. and esser Past sieberts-

VOL, LXXXVI: NO,137 THURSDAY, MARCH 7,1985, COLUMBIA, M )

l UEtargets unqualifiedp:

poncern surfaces about quality, pafety assurances at Callaway.

.- w

4'"

(C) IMS Columbia DaDy Tnbune its eristnal price estimate - sup-  ?

• * ' ' Mr *r,'..

Uruon Dectne Co. has aUowed un- pbes 1.150 megawatts for about 1 e' O

hfied inspectors for more than enilhoo Union Doctric customers la three years to help ensare Uw safety $L !.ouis aM dozens of Mad-Missourt d its Ca.naway County nudear communides, such as Ashland and '" M a -

~8**

w

kj W

),

pwir plant. De utility recendy sus- Moberty. After eight years of coo- .

8, pended seven Lnspectors from nu- struccon, the plant, which is 35 merous duties after an internal in- mDes from Columbia, sr.artad Destgstion revealed shortcomings operating in December.

9 their training, education or expe- N-Any cit:. ten snay pettion the NRC

• Dee. to ha:t the plant's opersuon untG the De discovery has raiud comp 4cy safety reytew Ls finished. Unsche- ,

d cials' doubts about the plant's daled shutdowns, the company has "

safe operauon, leading Wm to esumatad, would cost the utiuty bgtn revampir4 the quanty control about 8"50.000 a day.

insyction system. Doubts about inspections strike at Cocesrns won't be resolved unt3 the heart of the plant's quauty assur-the unlity completes a ma.ssive re- ance program pol'ard said. "De view of Inspectors' wort daur4 tech paper process is the ' say they G 101, ecmpany oftetals sam yes- have to assure pubhc ety."

Erday. De r* view is expected to Robert Powers, the plut's assis-Oke Et least three more weeha. tant quatty assurance manager, "We're interestad in seetr4 if sam interviews with distuattled in-there tre any safety problems." sam spctors revealed that whea they en-cePany spokemn M,te Cleary, countered work outside their areaa * ' * " ,**

and in correctag inem if eer of uperun, they passed e4 job cxist." alor4 te quattled men, i The St. teula utCity Ls reviewing

! cort by W to M more inspectors em-

"We don't have any concern about the plant's cons'.ruction," be aaded, '

pt - .

Mf@.'yr.

@loyed by a contractor who helped notmg tyat the inspectors Cd a3 l build the plant near Fu: ton. (lr. ion their wort durtr4 what Ls considered Cectric wants to ensure that inspec- the plant's operatonal pha.se, since tors had adequate skills and ctrtS- cudyear 1961, etion. One worter, who requested ano-A recent company audit, prompt- nymity for fear of supertors' repri-C9 by Lnternal complainta, unee- sala, said be found certScation vered 4tficiencies with seven of 13 papers ce his desk a few months ags ut!hty inspectors. As a result, the suortr4 him to do inspectons for utgity began studytag about 12,32 eMch be lackad complete training. A Wau work ordrs this weet to determine He and other worters said manag- f., g,1!.

atzther unquahfied men conducted ers wanted to improve efficiency by s*J,th i

faalty inspecucna, huncreds of us24 mulucertfied trLspectors.

such were done in key safety re'.st- "I was afraid. I m!ght get asked led systems. "We need to revtew to do scrnething I had no expertence i

i those records to find out what they in," the worker said this week,"and

' actua!!y did," said James Gear *. sit, at that point I would have had to <

the Uruon Dectric employee who su-pervLsed the audsL say,'Get somebody else in here who -

knows what they're doing."' t W

The Nucler,r Regulatory Comnus- Other worters said they never re-sica has not moved to altar plant ca: seeing or bearing of an Lnspector

• opersuons in the wake of the find- wbe proceeded with an inspection lings. Brues Utue, cornrn!utan in- far such tw wam't quahfied. la i spector at CsDa eay, said he wCI re such instances,the workers said,the

-trJ some utiuty work orders So. kupector a! ways turned to someone far, the stuity has reported no evt- quttled. But the employees noted dence that the unquatfied trJPGC. thatthfinspeC'ersinquestion-and

• tors compromised asfety; Utte their wort - have reured alarm .

sam. , about the quality controlI r;grameA -

De tsency's regional ofnce to final runr4 about aatety can coma CNeags, responsiue for everseeing only when reviews are nnlahed, the Canarsy's operstloe, has alerted its worters agreed.

Lop t, vision chJefs aM the ftwe corn- Two vuuty 41 visions are trw key erassaoceri Ln Washington D C. Ut- players; the e.uahty control tranch, ce said the stC!ty might have violat- wbch laspeda analntenance wort ed NRC rules, aM repalts to make sure they meet Bob Pocard, e staff member of the strict safety regulauons; and four requests for corrective action: Canaway plant manager St Uruon of Concerned $ctenusta to Powers' quauty assurance wing.

• One of three qua!!ty control sa- tenberger saspended Porte Wahar.gton and a former commte- which reports only to corporate a:stant supervLsors, Vernon Porten eettafgauon. He retains Na tien workst, aald regulators should headquarters aM functions to er> tacked necessary espertence La civ0 avry penauen, Cleary said, b shut down the plant until the utluty eure that members of the quauty aM electrical inspectAons, fields he teen barred frorn further

, completes its revtevs. cetrol staff perform corredJr. oversaw. electrical Inspectona.

' t.amtadng the federal agency's in late January, the quhty assur- e ne man responsible for approv.

• Most of U:e 13 mes hed e inocuan, Pouard sau: "That's es- anee emco received complaints tr4 cerufication of trapectors, qualb for inspectaens in more tha actly what the datf)culty La over at frorn inspectors who questJoned the ty control supervisor Terry shaw,on the four techrucal categort the NRC, Instead of proof that a credentais and etcues of other three octasior.s since Oct. 22 violat- taung 28 tertificauona amt plant t2 safe, they operate on the at> quauty control Inspectors aM twe ed compey rules for cefufying in- = but half of those certa sencs of proof that it la dariger. divtasce supervisors. Powers said speders. were found quesuor. sue.

i eus." his se.ditors tegan.Lnvesudsting t.he One person that Shaw recom- esses, the men did.not mee-

n. a m en Can v.y pi - nui e, e -in m.aa be e., a e.me,ta wiu e i-u l -,i.tw ai me,e an ave omes .- i. 4m.er.re .a,v, ga a ea sugai de.esPewa.ufw fe, two i.--

B. u.i week. e,s, Use. med,*ya _

~ .. . . .

l u s NUCLE AR r,EGUL ATORY COMMISSION mac s~m w ALLEGATION DATA FORM (t 1-821 instructons on esvsese sede RECEIVING OFFICE )

Docket Number (if applicable) '

1. Facility (ies) Involved: (Nem*I l t,, ,- . ,m ., a CALLwAY '

0 5' R 0 OI4_ f_1 generec, wnte GENERICI

2. Fonctional Area (s) involved: onsite health and saf ety (Check appropnaie boitesi l operations construction offsite health and safety safeguards _

emergency preparedness Other tspecity) 3.

Description:

lPJAlolcitlolul&lelf_l IA/lalrDrJvl'14.laMalol Irl (Limit to 100 characte's) l g lgj jgj geljj l5ln/slPlelcirlolairl l l l 1l l l l l l l_1 IIIIIIIIIIIIIIIIIIIIIIIIII

4. Source of Allegation:

ICheck approp<ete bo.) _

, contractor employee __ security guard

_ licensee employee , _ _ news media

__ NRC employee ___

private citizen

_ _ , organization tspecifyl other tspecityl MM DD Yv

5. Date Aftegation Received:

6. Name of Individual tree s, e. 6nii..i. .no i.., n.mes SI Receiving Allegation:

7. Of fice: g ACTION OFFICE

8. Action Of fice

Contact:

tr., i ewo 6n,ti.i. .no i. n.mei MW

9. FTS Telephone Number: ,

g 9

10. Status:

(Checa onet

- Open,if followup ections are pending or in progress

_ Closed, if f ollowup actions are completed MM 00 vy

~~~

11. Date Closed. l

_ ._ 1

'2. ,ne,na,wsL , ,,

.c e.,

[doJnIrje.lchirM#lal41rl(1:I Isj/tyJZef,rl I 1 I I I I l_ I T I I I I_l I_l I I I n l I I I I IJ

- }* *L ""'"' N f f_f g- f}$ A'd_$ ) /

13. Allegation Number: