ML20134A636
| ML20134A636 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/22/1985 |
| From: | Patricia Pelke NRC |
| To: | Weil C NRC |
| Shared Package | |
| ML20134A622 | List: |
| References | |
| FOIA-85-655 NUDOCS 8511070456 | |
| Download: ML20134A636 (79) | |
Text
...
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 is)
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Level III el ec trical t r. t p ec. tor.
lH S name 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 f ai l ed to subaiL the l e t ter of cer ts fi ca tion to a corre nt
(,e v e l III for arproval.
Two ex 4mpi e s toere g s ven who ch app e a r to be f ac tual.
9o mod
- V~.VgL Q' P. R, Pelke
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P 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
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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
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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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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.
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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
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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.
"Cail-ins"forillnessoroccasionalrequirementefor 4.
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.
Your careful attention to the itens discussed above should cr nce i
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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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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QC ORGANIZATION 2/20/84 (UOsen 84-23) l 6
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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 PTAOC To:
Organization:
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Org:
00scription of Condition: (44 characters) QC Inspectors Don't Have Needed Experience 2.
DETAILED DESCRIPTION OF CONDITION: (Requirement vs. Deficiency; include Originator Recommended Action if appropriate.)
SNUPPS-C FSAR Chapter 3A states in part, under Regulatory Guide 1.58 that "The I
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 Cn 2/15/85 and S. E. Miltenberger Surveillance Report No.: 850209 Condition Noted in:
$ W'# E A " *nW
'r'W h b N Yn/W R2sconse Due Date: /NI4 ' Ef
~
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.
AD5RCA (QA Record) AD5RCA (File)
FDF. RLP, JVI', JRV, WZ, CSP', k'AI TLS, JEDI SEM, WR (Action), DFS Y
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a 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."
Sections 3.5.1 and 3.5.2 of ANSI N45.2.6-1978 then list the recommended I
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 UENO program in either the Civil or Electrical discip'ines.
He current 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 demonstrated proficiency in the use of the tooYs required to perform not 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):
At this time, although others may be available, QA can anticipate only I
.one or a combinations of the following six courses of action as accept-able ccrrective action to make the above listed certifications valid.
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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).
l, 5.
Eave a non-questioned Level 111 certify the men in question and 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.
If further review of actual inspection activity or other pertinent j
inferrat 8 is obtained which indicates plant impact is negligible. QA
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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 VM Forrn N-87(184)
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 The response includes three parts in the following order: A. Cause of Condition; and verification.
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,
}[* ;I testing, and proficiency de=onstrations.
(This is considered to be the initial certification portion of the overall Certification Program.)
' 4. 3 J A 's v.. s..'.
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b G'ERhhC..c Effective Date: see page 2 of 2 see page 2 of 2 Addressee. Date
RESPONSE TO REQUEST FOR CORRECTIVE ACTION e
Form N 87(1-8M
.L P850?-035. m o toy,q:
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Numb:r and Revision: _
The r:sponse to the referenced ' Request for Corrective Action
- is provided below for your evaluation The response includes three parts in the following order: A. Cause of Condition; and v;rification.
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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12-31-85 Effective Date:
Addeeshee, Date( )
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REQUEST FOR CORRECTIVE ACTION
{I Form N-6 7(4 sa' 1.
IDENTIFICATION j
Number and Revision:
P8502-039. Rev. O t, y,g.
2 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/
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AD$RCA (QA Record) ADSRCA'(File),
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s RCA P8502-039. Rav. O t
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 Also, the UENO-QC program, via the definitions of the program.
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
oO RESPONSE TO REQUEST FOR CORRECTIVE ACTION s
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 The response includes three parts in the following order: A. Cause of Condition; and verification.
B. Action Taken to Resolve Problern; and C. Action Taken to Prevent Recurrenct C.* f 2 \\,/ -. p
- c. s.
w.
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 f
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.
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 Effective Date:-
see nace 2 of 2 See page 2 of 2 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 The response includes three parts in the following order: A. Cause of Condition; and verification.
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.
vc@ bAA MitTf 4-30-85 is Effective Date:
Addressek, Date (J
l
s
- 2%'
REQUEST FOR CORRECTIVE ACTION 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:
(IENO-0C P. T. Applebv Organization:
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 2/15/85 P. T. Appleby en Cencition Ncted in:
Surveillance Report No.:
850209 Response Due Date: /M4 M
/
/ze e / r< "
?N#MA1s
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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:
,-Hyr 24xa s x
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
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RCA P8502-034 R1v. O Pcg2 2 of 2 NAME CERTIFICATION DOCUMENTATION REQUIRED 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 U,
Form N 87(184)
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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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 Inspectors i
PERSONNEL CONTACTED:
(Listed on Attach:ent A) l J
REFERENCES / CONTROLLING DOCUMENTSt (Listed on Attachment B) i RESULTS:
Quality Assurance has reviewed the certificat;on documentation for i
j current UESO receipt, mechanical, electrical, and civil inspection I
personnel. This docu=entatien was compared to current UE program i
commitments; (i.e.
controlling document numbers I, 2. and 3) for.
inspection, examination, and testing personnel. The specific commit ent i
1 "The cualification of UE QC personnel or contracted OC personnel is:
l performing work at the plant shall be in accordance with Regulatory i
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:-
j mendations of ANSI Na$.2.6-1978 are not met by QC personnel, UE will demonstrate, by docueented results of written examinations and evalua-i 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 CALLAWAY E
,pg TECHNICAL SUPP0pd i
7
m._.-.--..
_.___m i
l 4
Sury. Report No.:
850 09 4
Page 2 of 7 Ee:arns:
Meets ANSI h45.2.6-1978 1
Education & Experience Meets CE's Exception See Note to ANSI Na$.2.6-10'8 Listed l
Requirements (At time of Certification)
(At tiee of Cert.)
Belev Name/ Certification 4
l f
R. A. Barnes YES 2
j Level 3 - Civil-NO 50 2
l Level 2 - Electrical NO NO Level 2 - Mechanical NO r
NO Level 3 - Receipt l
i
}
R. L. Bruneet 50 No j
Lovel 2 - Mechanical i
1 D. L. Heider YES i
Lovel 2 - Electrical e
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 f
l Level 2 - Electrical YES l
j
- ovel 2 - Mechanical YES Level 2
- Receipt i
3 t
i 2
i D. V. Peters NO NO Level 2 - Civil NO 2
50 l
Level 2 - Electrical YES Level 2 - Mechanical 2
i 2
j V. P. Porte11 NO NO l
Level 3 - Civil 50 2
7 No Level 3 - Electrical YES Level 2 - Mechanical i
T. W. Ridder I
YES Level 2 - Electrical l
J. M. Speek 1
YES 1
I Level 3 - Electrical NO NO Level 2 - Mechanical 2
R. D. Swank NO NO Level 2 - Electrical YES Level 2 - Mechanical YES Level 3 - Receipt t
i i
i I
i i
i
Surv. Report No.:
550209 Page 3 cf 7 Recarks:
Meets ANSI N45.2.6-197o See Note Meets CE's Exception Education & Experience te ANSI Na5.2.6-1978 Listed Require =ents (At time of Certification)
(At t e of Cert.)
Below Stee/Certificat:en D. S. Turley YES Lovel 2 - Electrical NO 50 Lovel 2 - Mechanical NO L. M. Zahara 50 Lovel 2 - Electrical YES Level 2 - Mechanical NO 50 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 Based up:n insuf ficient reccids and no additional detn11s disc'.: sed during a believe that the incividual is 2) discussion with the individual. QA does not the listed level / area cembination.
certifiable at insufficient Rev. O has been written to address the 1.
RCA P5500-03., Rev.
RCA ?8502-035, listed in the above table via Note the
'.'E p r e g r a: requireeents reccids issue 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..;
table. QA n:tes that ANSI In reading the cenclusions listed in the in equivalent inspec-Ne!.2.6 uses the terminology "related experience tien, exa=ination, or testing activities" in defining education anddefined tnis term QC has not ex;erience for each inspection level.
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 an evaluation to This requirements have been cat.
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 experience to determine inspection, examination, constituted "related experience in equivalentThe bases for these criteria we or testing activities."
as well as published guidance in this area in SNT-TC-IA (1975 and 1980) industry applications at other nuclear power experience with current plant sites.
L
_ ~ ~ - - - - - -
4 Surv. Raport No.:
E!O:09 i
l Page 4 of 7 l
1' d
In order to be counted on a one-for-one basis, the person must 11 25* of his time actually werking in the have spent at least discipline. This is based on SST-TC-1A's criteria.
in the nuc* ear Navy i
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 (and began actuai field work).
Boilermakers, stea= fitters, i
shipfitters, pipetitters, and similar construction crafts were Electrician's Xates were l
l also counted on a one-for-one basis.
i counted because replacement of bearings on motors is virtua11v i
i the same as replacement of bearings on pueps; torquing of bolts on motor mounts is the same as torquing bolts en pumps i
j or flanges; alignment of electrical equipment is the same as On the basis of similar ali6nment of eechanical equipment.
l logic, welding experience in the commercial industry was
]
counted when a persen was involved in the " fit-up" aspects.
l J
I in the nuclear 3)
Tor an electrical certification, time spent l
Navy as an Electrician's Mate, 1-C man, and similar ratings in other services was counted an a one-for-one basis after the l
J person completed basic trLinirs and began actual field work.
t j
Construction electricians were also counted on a one-fer-one l
While Nuclear Power Schtoi does teach basic electri-basis.
involve work with I
cat, work as a Machinist Mate doss net l
cables, terminatio ^s, controllers and other electrical activi-I Therefore, no credit was given since 25 of Nuclear ties.
Power School is not devoted to electrical.
However, if a Machinist Mate qualified as Engineering Vatch Supervisor (EWS) l or as an Auxiliary Electrician Aft (AEA), er as an Electric l
Plant Control Panel (EPCP) operator, or as a Shutdown i
Electrical vacchstander (SEV) or similar posittens in other j
i services, then the basic electrical school as well as a I
portion of his service time was counted 1. determining I
i experience.
'I.
For a civil certification, none of the current QC inspectors a) j had any service time which was considered " equivalent."
However, time in the Marine construction battalions (C-5s) and
~
i 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
in a civil test lab or a commercial-testing facility
]
would be counted.
Prir.arily, because of the broad spectrum of
)
spent 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 receive a satisfactory evaluation upon during this surveil-l 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 certification, a wide variety of previous work For a receipt 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 inspector would not require inspection, a UE Level 11 Receipt the same amount of specific work experience as a Level Il inspector working for DIC at Cal *away during cccstruc-ReceiptTherefore, virtually any previous experience that tion.
required an individual to locate acceptance criteria documents and then determine that an object cet the require:ents of those documents, was considered " equivalent."
No evidence was found where any of the current inspectors had been given f
This ccac!usion a "docu=ented evaluation of actual work proficiency."
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 During our (UE) meeting with the SRC representattve pr;or N43.2.6-1978.
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 i
an electrical inspector would have to observe a I
a concrete slump test; cable pull and determine if cable stress criteria P.ad been satisfied; a to motor alignment and 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 apply if a sa:pling receipt inspection process is authorized.
These are, of course, only examples; a wide range -- approximating all c! the !YPES of tests or inspections to be performed -- would have to be included in the actual Both acceptable and unacceptable 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 if an electri-fu'.1 ef 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 include these requirements nor any qualita-Because the program does not tive or quantitative criteria for conducting and docu=enting this has been 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.
i pregram defined by QCP-Z:-01001 Rev. 2 and QCT-ZZ-01002, Rev. 2 is also deficient in the following areast The program does not provide for determination of the need for 1) 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 The determination of specifically provide for OJT.
does not 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 ir.it ia l capability of a candidate for certification.
This is required by ANSI S45.2.6-1978. Paragraph 2.2.
It also dces not prcvide for the documentation required by Reg. Guide 1.58. Rev.
1.
the =ininue Position C.10 for when an individual dces not cect N;5.2.6-1973.
education and experience requirements of ANS:
The progra= does not state what minieu infor:ation is re-3)
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 N45.2.6-1978 Paragraphs 3.2, 3.3, and 3.4 re spective ;:..
A;s:
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; however, the procedure does not specifically require that a
This is person be capable of performing that capability.
required by ANS1 545.2.6-1978, Paragraphr3.1.
de f ic ie n-RCA P8502-039 Rev. O has been issued to address the progra:
cies listed above.
During interviews with the various QC inspectcrs, a cencern was raised with respect to dispcsitions cade to cable repairs.
ci this surveillatee was As a result of this concern, the original scope 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.
26 cases of electrical device or wiring da age were found.
- review, 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.
k{
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A. kthl:an W.
QA Consultant g Y Stevi Petrel QA Engineer 3.!1'~
C S P :'.' AA: s a s See Page 7 for Distribution
Surv. Roport No.:
65C:09 Page 7 ef 7 Attach:e.cs: A)
Personnel Contacted During Survei*1ance B) Refereness/ Controlling Documents DISTR:!sTION A*!S050209 (As a CA Record) cc:
- 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
PERSOSSEL CONTACT!D DURING SCEVE'LLANCE l
Services P. !. Appleby - Assistant Manager, Suppert R. A. Barnes - QC Inspector J. E. Davis - Superintendent. Ceep11ance D. L. Heicer - QC Inspector E. L. Irwin - QC Inspector I
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 I. L. Shaw - Supervisor. QC f
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
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ATTAC10'ENT B Sury. Roport No.:
850209 RETERENCES/ CONTROL'.:NC DOCLNENTS i
!)
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 a -m. -
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 to ascertain the degree of familiarity of the inspector with attempt 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 f f g
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 Peview of Additional Documentation and OC Action Relative to
SUBJECT:
Certification of UENO Quality Control Inspectors Review of Additional documentation relative to UENO Quality OBJECTIVE:
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 be This
, 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 J.
?.. Pearson, R. L. Brumeet and V. P. Porte11.
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.
P. Portell's Civil Level III and Electrical Level III could be justified based on the use of " management pre rogatives" specified in ANSI N45.2.6-1978 V.
V. P.
(See At tachment D and G f or further discussion).
Section 3.5.
Portell's Electrical Level II certification could be supported if a In addition, F. A.
satisf actory performance demonstration is documented.
Barne's Civil Level III broad-based certification cannot be supported because This of.the limitation identified on his Civil Level 11 certification.
D Note 2.
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 by Mr. Schottel.Fowever, OA's review of the general nature of these cuestions, docume nted.
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
- 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 activities which they felt ret
+
Although the clarification was in intent of Union Electric's commitments.
Schottel conducted his performance demonstration evaluations, effect when Mr.
the NPC had not yet ret with Union Electric to clearly define their Although the Superintendent, Compliance (to whoe the interpretation.
Supervisor, OC reports) was later an attendee at the ceetines with the NRC in the OC organization was directly when the position was annunciated, no one L mplement,an acceptable performance i nvolve d.
The failure _tojull i
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 addition 0A in their review and assessment of the overall OC program.
also recormends that OC suoervision monitor the actual inspections or tests cerformed b'y each newly certified inspector until they achieve a level of This " monitoring" is in addition confidence in the individual's performance.
to the certification program items previously submitted, and is considered to be in excess of the minimum recuirements established by Union Electric's the monitoring represents what GA believes would be prudent commi t ment s, but management action.
F
t Surveillence Feport 250209A Page 3 of 5 Feview of Ongoing Evaluations Beine Conducted and Docueerited bv OC:
action taken as a result of the original Surveillance was the The first on RCA decertification of all individuals identified as cuestionablehad als P8502-035.
OC manacement All of this 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.
of their investigation to deternine the scope of the OC managecent, as part records of all 85 OC personnel cuestionable certifications, also reviewed the who cay have perforred reviews or inspections under the operational CA They used acceptance criteria similar to that utilized by QA during As a result of that investigation, QC identified program.
the initial surveillance.
be (in Reference 13) 15 additional individuals whose cert'ifications right cuestionable.
looked at the files fer Vhen the OC Department's review was conducted, thev this increased scope accounts for the fact d
previously employed OC inspectors:
Howeve r, they they identified 15 additional cuestionable certifications.
that eeployees and identified thef same inspectors also looked again at current The OC review did not previously identified by QA with one exception.
identify J. M. Sceeks' Level II Fechanical certification as cuestionable even The OA review had identified that though OA had listed it on RCA PE502-034 Speek's file only needed to include an expanded resume which could detail Mr.
the tasks which he had previously accomolished which were suitable for consideration as "eouivalent experience" in order to recove any cuestions i
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, the tiee the OC questionable nor were his certifications cuestionable at review was ccepleted.
OC canarement's detailed actions, which include a review of activities perforced by any inspector whose certifications are cuestionable, is riven in on these The Engineering /0A evaluation of the possible impact activities is ongoing. (It was begun on 03/12/85.) All actions cocoleted to
)
At tachre nt E.
i date as part of this Engirmering/0A evaluation have been conservative, and none has indicated any adverse impact on installed structures, systems or As of March 25, 1985, approximately 95% of all work recuests had components.
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 were reviewed by OC as described in Attachments E and F.
However, OA considered J.
f orth in the following D. Schottel to be certifiable for the reasons setH. L. Holean as an ir.spector with paragraph.
In addition, QA did not list ouestionable certification since he was never certified by Union Electric.
I
-. ~....... - _. ~.. _ _. - - - -
i Surveillance Report 850209A I
Page 4 of 5 1
k 4
that he ray have j
Mr. Holman was listed as questionable by OC based on the factMr. Holman's nace l
conducted some reviews even though he was never certified.
I Al t houg h,
1s part of the document search documented in Attachments E and F.
Speek and D. S. Turley were identified as having questionable J. M.
850209, they have been elleinated as l
certifications in surveillance report further evaluation based on additional inf ormation incorporated into needing Eliminating these two individuals yields the list their certification file.
of 20 inspectors considered by OA to be of questionable certification as listed on Attachment D.
'4 the fact that be i
QA's evaluation of Mr. Schottel takes into account:
his coroleted the Electrical training course and all electrical examinations:
l his CA B.S. in Metallurgical Engineering and his M.S. in Nuclear Engineerine:
i other Nuclear Power Plants; and his cumulative 32 :onths of l
experience at OA/0C experience. We note that the Standard would recuire only six months of l
- And, 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 can comi ng 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.
4 Shottel's certification was given because no Level III In addition, Mr.
existed at the time of certification. This utilization of managementthe prerogative, and consideration of other f actors adeouately support certification and complies with ANSI N45.2.6-1978, Sec tion 3.5.
CONCLL'SICN:
Eased on the review conducted by OC as surveilled by OA during this i
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
=
We also feel that OC management's approrch to the D.
Attacheent l
identification of the insoections and reviews performed by personnel with I
questionable certifications has likewise been thorough and conservative to And, whEn coupled with the Enginee ring /0A evaluation which is being date.
I conducted, we believe that possible adverse ef fects on installed hardware will i
be identified if any exist.
t 4,
l As mentioned on RCA P8502-035, Rev. O, CA will consider downgrading thead ve rse identified inadecuacies to a Level 2 if there has been no significant We do not anticipate that it will be possible impact on installed equipment.
to make this determination (of possible impact) until the Engineering /0A 1
j evaluations have been completed and any reinspections, if needed, have been j
conducted and reviewed..
the full extent of quer,tionable certifications has been identified l
Now that Attachment B provides the the issue can be placed in proper perspective.
results of the OC department's evaluation of cuestionable certifications of inspectors who were not identified $f the previous surveillance, including This evaluation disposition of certain cuestionable tertifications.
identified (a) 11 certifications /3 inspectors in which no tasks were performed j
-.,,..-r
-,.-my,.---e
,,.,,,-,..,,w-.-,,y,w-.,m,,y,,,-,-c,._,mem..,,,,,.,,-.v,wwmy,,y.-,,m.~.,,-,,,y.m.m.o.,,----
Surveillance Report 850209A Page 5 of 5 which reautred certification, therefore no f urther evaluation was necessary in this area, (b) 9 certifications /8 inspectors in which additional inf ormation 17 certi fications/10 could be added to the file to support certification, (c) inspectors whose previous certification, training, experience, education, Attachsen be's'upported in the broad base category.
performance cannot lists 75 inspectors with 207 certifications that' comply vith UENO prorr;4
~
i D lists 20 inspectors with 29 certifications s?
c ommi tmen t s.
Attachment
'm: 'v remain cuestionable.
These inspectors along with J. M. Speek and D r'
pnk i ce are being identified as stated earlier for further evaluation.
4 inspectors with 247 certifications have been evaluated, 207 ce ug p p;*
4 : se p ti e is meet UENO program concitments and 22 inspectors with 29 (11.7*
remain cuestionable.
Based on personal interviews with current employees and based on the review of work activities completed to date, there have been no cases where ary inspectors performed inspections in areas where they were not qualified and capable of performing adeouate inspections.
3-$fo-6 [
, - - l R g /j, /g y -
A.~Ruhlman 3
W.
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
l l
I
ATTACKMENT A to i
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 1 - September, 1980, Qualification of 1.58. Rev.
- 2) Regulatory Guide Inspection, Examination, and Testing Personnel Nuclear Power Plant Examina-
- 3) Standard ANSI N45.2.6-1978, Qualification of Inspectien.
and Testing Personnel for Nuclear Power Plants
- tion,
- 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 Mechanical QC Inspector Training Program Course Description 8) f Electrical QC Inspector Training Prograc Course Description l
9)
Training Progra= Attendance Records, Electrical and Mechanical QC 10)
Inspectors Exa=ination Answer Keys, Electrical and Mechanical QC Inspector 11)
Exa=inations Els.ctrical and Mechanical QC Inspectors' Grsded Exa:inations i
12)
Memo, L. D. Russell and V. P. Portell to J. E. Davis, dated 13) 03/09/85 i
h i
-m
- - -,. - - -, =..,
-,-.,-,--n,..
a-
.-m.
,.., -,n,
M ATTACWINT B to Surv. Report No.:
850209A Page 1 of 5 EVALUATION OF QUESTIONABLE CERTIFICATIONS Previous l
~
Certification /
Acceptable Areas Experience Previous U.E.
Other than UE Certification of Certification l
Na=e (Batey, R. J.)
Doc. Tech. I VT-2 II (a)
See Note 1.
VT-3 II (a)
VT-4 II [ Limited to Doc. Revies] (a)
Battle, W. D.
Civil II Civil II (c)
Civil II
- Cencrete i
- Concrete
- Complete (includes
- Soils Civil II (Limited)
Orypack)
- Coatings
- Scils i
- Lead Aiiditor
- Drypack
- Surface Mounted
- Coatings Plates & Expan-141on Anchors,
Brewer, N. L.
Doc. Tech II Receipt II-(b)
Reference Letter of Complete Justification for Receipt II Certi-ficatton - See Note 7.
t Brevn, L. D.
Mechanical II Mechanical II (c)
Mechanical II
- Instrucentation
- Instru entation
- Complete
. Welding II
- Cczplete Electrical II Raceway Erevn. J. K.
Mechanical II VT-3 II (a)
See Note 3.
VT-4 II (a)
VT-2 II
- Instru=entatio'n
- Hydro f'
Receipt II
- Cocplete i.
I
ATTACHMENT B to Surv. Report No.:
650209A Page 2 of 5 Previous Certification /
Experience Previous U.E.
Acceptable Areas,
of Certification Other than CE Certification Na=e Gaines, T. E.
Mechanical II VT-3 II (b)
VT-2 II VT-4 II (b)
Reference Letter of
- Hydro Justification for VT-3 6 '. Level II Certification -
See Note 6.
Herring, P. L.
Mechanical II Mechanical II (c)
Mechanical II
- Hydro
- Co=plete
- Hydro
- Hangers
- Hangers Non-Q (Trainee III)
VT-1 II (b)
Reference Letter of
- Limited to Justification for valve insp.
VT-1, Level II Certification - See Note 6.
e (Lawson, M. L.)
Doc. Tech. II Receipt II (a)
See Note..
- Complete
.~.echner, S. J.
Mechanical II Mechanical II (c)
Mechanical II
- Instrumentation
- Co:plete
- Instrumentation Pipe
- Pipe Electrical II
- Complete McFarland, R.
A.
Mechanical II Mechanical II (c)
Mechanical II
- Pipe
- Complete
- Pipe
- Hangers
- Hangers Welding II
- Complete Morgan, J.
Welding II VT-2, Level II (b)
Reference Letter of 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 /
Previous U.E.
Acceptable Areas Experience of Certification Other than UE Certification Name Civil II (c)
Civil II Civil II Orf, D. L.
- Complete
- Concrete
- Concrete
- Blockwalls
- Blockwalls
- Fire Rated Doors
- Fire Rated Doors
- Subcontractor surveillance Pasley, J. M.
Civil II Civil II (c)
Civil II
- Soils
- Soils
- Complete
- Coatings
- Coatings Civil III (a)
- Subcontractor surveillance
- Complete See Note 2.
Pruitte, V. R.
Mechanical II Mechanical II (c)
Mechanical II
- Instru:entation
- Instrucentation
- Complete
- Pipe
- Pipe Welding II
- Complete NDE II
- PT Scheperle, G. P.
Mechanical II Mechanical II (c)
Mechanical II
- Pipe
- Complete
- Pipe
- Equip =ent
- Equipment (Thomas, D. R.)
Civil II Civil II (a)
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)
- -. ~
~
ATTACKMENT B to Surv. Report No.:
850209A Page 4 of 5 Previous Certification /
Previous U.E.
Acceptable Areas Experience Other than UE Certification of Certification Name See RCA P8502-035 Civil II (c)
Civil II Barnes, R. A.
- Complete (Limited)
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.
Nene issued.
(Holman, H. L.)
Start-up Engineer None Draftsman l
t Pearson, J. L.
See RCA P8502-035 Electrical *I (b)
See Note 6.
- Complete t
i 1,
Receipt III (b)
See Note 6.
Zahara, L. H.
Based upon discussions with the individual's QC Supervisor, the following inf ormation Letters or other documentation has or vill be placed on file to applies.
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.
l
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:
Denotes a questionable certification; however, no task (a) requiring certification was performed in this area.
No further evaluation is necessary for this certification.
7 Additional information was supplied to the certification (b)
This certification file prior to this Surveillance Report.
C.
meets UENO program co=mitments and is included on Attach =ent (c) These broad based certifications are questionable; however, These the docu=entation supports limited certification.
certifications require further evaluation and are included j
on Attachment D.
i l
(d) Inspectors do not appear on Attachment C or D.
i I
s i
)
4 1
~
I h
ATTACHMEMI C to Surv. Report No.:
350209A Page 1 of 5 CERTIFICATIONS THAT COMPLY WITH UENO PROGRAM COMMITMENTS U.E. CERTIFIED NAME Electrical. Level II
- 5. J. Adams Mechanical, Level II T. L. Antweiler Mechanical, Level II T. H. Ar: strong R. A. Barnes Receipt, Level II & III Electrical. Level 11 J. H. Baxter 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 N. L. Brewer Receipt, Level II Electrical. Level II T. J. Buersceyer 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
.U.E.
CERTIFIED NAME Electrical, Level 11
~
J. S. Diluvio 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
(
VT-2, 3, 4,
Level II B. J. Dudley
[ 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
VT-1, 3, 4 Level II J. G. Carrigan 1
J. N. Guynn Receipt, Level II Electrical Level II R.
Hagar G. W. Hamilton Receipt, Level II Mechanical, Level II VT-I, 2, 3, 4 Level III 1'
Electrical, Level II B. W. Haugen Electrical Level II D. L. Heider VT-2, 3, 4 Level 11 S. M. Henage.
[ Limited to Doc. Review]
i VT-2, 3, 4 Level II P. L. Herring i
Electrical. Level II L..P.
Hume Welding, Level II i
ATTAC:OtEET C to Surv. Roport Wo.:
850209A Page 3 of 5
.i U.E. CERTIFIED NAME Mechanical. Level II E. L. Irwin 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 NDE - MT, PT, Level II R. W. Laughlin VT-1, 2, 3, & 4 Level II Welding, Level II 2
C. P. Laurie Receipt, Level II Welding, Level 11 S. J. Lechner Mechanical, Level II 1
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 D. E. Moreland Civil, Level II VT-2,~ Level II l
J.
Morgan 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 D. R. Oelrichs VT-2, Level II Mechanical, Level II i
VT-2, 3, 4, Level II P. S. Olsen i
Mechanical. Level II f
J. L. Pearson 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
m ATTACHMENT C to Surv. Rsport No.:
850209A Page 4 of 5 U.E. CERTIFIED NAME Receipt, Level II R. L. Pflueger Mechanical, Level 11 V. P. Porte11 NDE, PT, Level II VT-1, 2, 3, 4. Level Il
)
Electrical. Level II K. R. Richey Electrical, Level II T. W. Ridder VT-3 & 4, Level II K. M. Robson Mechanical, Level III i
J. D. Schottel i
Receipt, level III VT-1, 2, 3, & 4, Level III J
Velding, Level III l
Electrical, Level III Receipt, Level II D. L. Smith VT-1, 3, %. Level II l
d 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 Electrical. Level 11 T. W. Stites 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 Electrical Level II J. W. Vandelicht Electrical, level II W. R. Vandeloecht Electrical, Level II G. G. Weinzettle VT-2, Level II T. C. Weisenberger i
l
ATTACRMEST C to Surv. Report No.:
850209A Page 5 of 5 U.E. CERTIFIED NAME F. A. Wadake VT-2, Level II 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
n.
...................................... ~... -.. _. ~.. ~...... _,.
ATTACHMENT D to Surv. Report No.:
850209A
,I 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
Civil. Level-III 3
R. A. Barnes Electrical, tevel II 3
i Mechanical, Level II VT-1, 2, 3, 4. Level II 3
Mechanical. Level II R. L. Brum=et 4'
Electrical. Level II J. L. Pearsen i
i.
Civil, Level II D. W. Peters 3
l Electrical, level 11 I.
a Civil Level III V. P. Portell 5
Electrical, Level III 3
l Electrical, Level II e
3 Electrical Level II R. D. Swank 3
Electrical Level II l
L. M. Zahara i
2 Civil, Level II W.D. Battle i
2 Mechanical Level II i
L. D. Brovn 2
Mechanical Level II j
P..L.
Herring l
2 Mechanical, Level II l
S.'J. Lechner 2
Mechanical, Level II l
R. A. McFarland i
Civil, Level III 2,6 D. L.-Orf s
2 Civil, Level II J. M. Pasle;.
4 2
Mechanical, Level II 5
V. R. Pruitte 2
Mechanical, Level II 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 1
i 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 l
1) believe that the individual is during the personal interviews, QA does not l
certifiable at the listed area / level combination.
(See RCA P8502-035. Rev. 0.)
I Eased on limited certification by the previous employer, this individual's 2) the broad-category UE certification.
A CE certifi-experience will not support cation in the areas certified by the previous employer or where UESO program has l
been followed would be acceptable.
Based on training records and course outlines reviewed as well as the individu-3) al's docu=ented education and experience, the inspector would be certifiable at indicated area / level ce=bination if a satisf actory perfor=ance demonstratien the were docu=ented.
However, since he is no lenger This inspector is the same as Note 3 above.
f 4) employed as a QC inspector, completion of a satisfactory performance de=enstra-j tion 13 not considered appropriate.
Although this inspector's education and experience do not meet the literal 5) 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
i forth in Section 3.5 of the Standard.
Additional details are contained in set the Surveillance Report under the Discussion heading.
j part of the time that QA conducted this Surveillance, this inspector was not 6)
Atthe UENO QC organization. However, prior to issuing this Surveillance Report, i
CEQA was made aware of potential plans to rehire this inspector and certify hic QA in the areas where he was previously certified under the DIC program.
l such certification would be acceptable, f
concurred that i
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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
- 850209, the QC To resolve the concerns of the Surveillance Report Department has initiated the following action:
A review of documentation to determine which additional QC i
A.
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 Program. This task was completed on 03/09/85.
j 4
B.
Utilizing the list generated in A above, the QC Department i
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
- 850209 for performance of this review. 'An attempt was made
{
to categorize subdisciplines in which an Inspector was Attachment B is a su= ary of the results.
certifiable.
Quality Assurance's review of the QC Department's evaluation
[
perforced in A & B above consisted of a review of l
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 The evaluation has
. Department was adequate and conservative.
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.
Review of Startup Maintenance Authorizations (SMA), Work C.
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
Work authorizing documents are currently being reviewed 4
!)
to identify work that involved individuals whose certification is questionable. These individuals are identified as a result of B above.
Currently, research i
of UENO is being conducted to determine the involvement QC during the startup phase. The results of this research will determine whether Startup Maintenance At the time of Authorizations (SMAs) require evaluation.
initiation of the Startup Work Request (SWR) Pregram by the Startup organi:ation, operations was utilizing a Vork Request Program. To administrative 1y allow CENOCENO vrote maintenance and therefore UENO QC involvenent, 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 performed by the QC inspector was within an area in which j
he/she was not certifiable. These areas include j
preparing the Hold / Witness / Monitor points, preparing and approving Maintenance Inspection Checklists, and Field 1
j Inspections. Attachment F outlines the criteria utilized l
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 performed by the QC inspecters with questionable i
certification. The evaluation incluces:
4 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 contains appropriate inspection attributes and acceptance 4
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-
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s/
Engineering /0A 4
OK HOLD / WITNESS / MONITOR (H/W/M) - INSPECTION SPECIFIED 4
1 I
1
)
I Check H/W/M - Consent to Proceed i
) Not Certifiable (NC) e Certified 7 i
Insp. Perfereedh Waivid Inspection Cheer.MIC*(
or Not Signed tj V
Engineerine/QA NC Approvef. By
. ) Certifiable Prepared Ev - NC (
4
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V Engineering /QA t
Check Field Inspector t
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Engineering /QA E
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Maintenance Inspection Checklist
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_ _ _ ~ ___
Attachment G to 4
Surveillance Report 850209A Page 1 of 2 i
DISCUSSION To preclude any misinterpretation of this Surveillance, a Discussion Section l
included.
If is being added to provide details which would not normally be 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 Mr.
they considered when concluding that they had reasonable assurance that 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 perform OC inspections. UE's commitments, as outlined in the OA program, are l
l designed t: provide management (the NRC and the public) with a description of "all those planned and systematic actions necessary to provide adeouate l
j confidence : hat a structure, system or component will perf orm satisf actorily
{
in service."*
This is accomplished by including in those commitments "the 4
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 Standard (and UE's commitment thereto) is designed to deal with the " normal or i
ave rare" case.
For those cases, the' established controls provide adeouate confidence that acceptable action will occur.
2 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 Such a course is the only way in which it can be certification of inspectors.
" proved" that a given inspector is capable or qualified to perform an Therefore, since QA only reviewed the inspection.
exoerience/ training / education of the inspectors, the only determination which they could (or did) make was that a person is or is not certifiable.
A t
paperwork review does not allow a determination that a person is or is not cualified.
see any attempt on the part of QC management to circunvent QA also does not the established oualification program nor any intentional violations of A discussion of the possible reasons for the dif ference in procedures.
interpretation is given in the Surveillance on page 2.
Ouoted from 10CFR50, Appendix B. Introduction.
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4-April 23, 1985 Safety-Related 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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~
i 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 start of the Operations OA program.
OC identified the work activities which 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 Therefore, a Quality Assurance / Engineering Evaluation Tean was established to i
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 l
team concluded that there was no adverse impact on plant hardware function or 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 l
i 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 l
inspector. The OC activities evaluated included:
1)
Preparation of the Hold / Witness / Monitoring' Point (HWMP) Notification I
2)
Approval of the Maintenance Inspection Checklists (MIC) 3)
Field Inspection of the activity.
i 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 and OC inspectors document inspection attributes, acceptance c riteria, 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 Itecs e and d are considered conservative in that all inspectors 4
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.
The teae determined that OC coverage was adeauate and the work activities were 7
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 PMT sheets and PWR's.
4 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
VR 743629 -
Verified vi re type, cabling termination accuracy, proper lugs and crimos WR #27853 i
5)
Board installed.
If board was not installed the SA I
system would be disabled. WR #7661
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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)
Verified phasing per E07000 motor direction of rotation correct, motor terminations were inaccessible WR #4840 j
8)
Verified proper installation and density of fire barrier VR #26859 3
These verifications were perf ormed utilizing MIC's generated by a certified OC l
inspector.
The inspection team participants included OA, craft, and certified 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:==
(
The results of the evaluation and field verifications provide assurance that l
OC inspectors have adequately verified conformance to applicable documented instructions, procedures, drawings, and specifications as reauired by the 00AM 1
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 activities as required by the 00AM Chapter 17.2.10, Fev. 7.
This condition is 4
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 we re conserva tive.
For example, the team did not take credit for the Callaway j
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 Surveillances, Technical Specifications surveillances, and other associated i
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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Surveillance Report No.:
650209B 1
Page 6 of 6 contact J. V.
- Laux, If you have any questions concerning this surveillance, Supervising Trgineer, Quality Assurance Technical Support.
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. M. Pobl T. W. Stotlar f/k' 8 I OA Engineer Engineer f
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cc: AD55850209B ( As a OA Record)
AD5SS50209B OC (file) j.
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
- Page j _ of. 10....
WORK DOCIfMENTS
- Participants thwnment Title Wo. r k. R. e.1u e s t..
1EP
\\:WP TWS
.IPl.
Closed Document Comp.
Actual
~ lank l'erl ormed Ill spos i t I,o_n_
Open Number
- 1. D.
Work Performed By s}nestlonable 1)CI C
MIC Adequate 5222 EN-V-lI Cleaned Valve Stem MIC/ RAM Insp., Visual within skills
...C.I. This is Non Q, "Q" C
of O 30614 FC insul.
Modify Insul.
Insp/in.n 2 ".isual spec if led C
3801 FCP-AN-1001 Nothing IIWMP Adequate this is C
7640 RM Calibrate Analyzer. IIWMP/RDS Non-specified Non'"q" Replace I*fiter 3686 NE01 & 02 Material IIWMP/VPP Non-specif ied IIWMP Adequate q__
(
IlWMP/Nonr' 4821 NE01 6 0.
d.1othing C
MIC/VPP MIC Ade'lunte fFrtedBrushes 4903 NE01 6963 NE01 Cleaned gen, ilWMP/VPP
_IIWM.P..A_d.e qu.a.t.e..... ___ _.
_ _C.._
1.1; -...
tilC Adequate Enough inst.
3227 NF106 Reland wire Insp./RDS n i v e n f o r...f. }.C I..t.o Pe.r.f_o_r.m__..._......C_.
ins.
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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,,
.I I' t.
.t 1:lo u d Document Comp.
Actu l Task l'erl ormeil Dispositlem Ojuan..
Number
- 1. D.
Work I'erformed ny... ques t l onab.l.e...Q.C1
-.._C.
-. 5441...._-
..E 10 6.... _... V.o. i d. e.d..
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abtain document, No QC 3
i i.n.spe.ction required q
22001 NE106 Scheme Check llWMP MissinR.
.... Visual verif(cation to i
MIC/JI.p NE107 Reland Wires insp/RDS. I.V 1 sua l..Ve rif.... If98. Within the skills C
2 3225 of QCl Obtain document calibrated l
21996 NE107 Scheme Check No llWMP Sheet S AT..Na...QC..i n s pe c t 1on.... _. __...C._.._
required Calibrated SAT C
5862 NE107 Rep. lac.ed. Relay.'...
l.l.W. M. P. /.JI.P..Non-sPccif j ed i
Install I hr. fire C
34.334_..
S E... R.E.- 1. 8 b.a r r.i.e.r. w..ra. p._._..... MIC/VPP MIC Adeq.uate Retest SAT i
1560 CC-536 Calthrate & JDstall llWP. /.II..P.. No. P.-sPPCi fied llWP Aslequ. n. t c. _. _ _
C_ _ _....
s 1*ound connector MIC Adequate
. ____._C__....
34404._.
RCK.. 0. 5 A. _... bro.ke.Ipose..... _. Bf lC/S.II..
2 4
attarnment.,,, A.,..
to SR 8502098_. _,
QA/ENGl,NF.ER l'VAI.liAT,10N OF Page 3
of 10 WORK DOCllMr.NTS Date of Evalunt ton 3/19/8$
Participants l'or nme n t Title Work Request,
_l.EP,
..TWD.
,,TWS
_SMPo
_4 flocument romp.
Actual Tank Per f ormeul O
Number i.
D.
Work PcrIormed By Questlonablc,QC,1
...... liluposI.t.l.on..__.._.__.... _. pen.
IIWMP RAC, MIC/RAR Adequate OC coverage Install booster II/T Non Q C
32194 CGI.04 f an brac Inti I"SI?. / R An WR was "Q" however work Install access 25614 GI.D-315,,,, pane l.pe r.CM1?
IlWMP/ FRO. Non-spec i f. igd.
,was,Non Q,HWMP, adequate
,,___,___Q,,__
or \\bove C
25615 GLIh316 _ _ k.'R 25614,_.
As,Above...WR.25614..........
.6s Above t!R 75614 Determ., remove C
675I GI.-[17.-.3 2 -.2.
Actna, tor _ __ _,_,
MIC/RAn, DWP._ _._.......___..
MIC.. Adequate._
Inspection visual within Replace gasket insp. RAn 18796 GL-V-004 torque bolts.
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_
Snme as C
18120 G1,-V-00R2__ WR,18796_,,,,
Same,a,s,WR,18796 _,,, _,__,,
S a m e a s,,WR,,1,8 7.9 6, _ _._,,,,,,
Within the skills of Swap A & C Phase Insp/Jr.P OCI C
l.),,Ra y, Cl c,m,,2 ),,,Re t e rm.
i l
4.840_ _.. SGlcl0D _ ___ n.n d..,R ay Chem,,,,,,
(
... ~...---.... _-_-.._...._ _.......
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 WORK luiGitMENTS Pa F.c 4
"I 10 Participants Date of Evaluation 3/19/85 TWS TMD/GWP thirument TItIc Work Request, I.EP SMPo Closed j
Document Dim p.
AcIual Tnnk Per f ormeet Number
- 1. D.
Work Performed By. Q.ues t iona.b.l.e..QC l Di spos i_t.i.n.n. _
Opeu h
C a
7690 GN-III S-9 Re p l.a c. e........... MIC/Rng....................
.MIC.. A.dequa te c
n not ver led Replace Card Retest SAT C
3577 GN-PY-938 and Cal.
IIWMP/Non-specified
~ '
Y1IC 5cicquate insp. visual GN-TE-60 MIC/VPP insp./RDS l-5._7 3 0. _..
t 62 _..... 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 C -
5 wi
+
L i
Retest SAT i
Removed and sent l
8408 GN-TR to vendor...
llWM.P/.R.AM.N.on.sP.ccif icd
.II.W.MP..A.d_equa t e
- = - =C
- ~
Removed 31471 PBBotC Articulation Arm IIWMP/ RAM Non-specified IlWMP Adequate C
r Reassemble RV after I nsp/S.11,, RAM Vendor support provided
- 1) GO-NO-GO hole sizinP' InsP. visual C
4 26672 RBB-OI fuel load 2T Clean 1iness t
- 3) installation of econoscal J.
i 1
f t
- - ~..... _ ~..
N
....m
.m
+
i
- -.S+.e,e.
m.-
es e.& e e.
4D N.
'N.
.hh
.M..MM..NM 6-..
.g g
ee.,, ego m w m
I U
.me '...
e.p
....e
. * - * * * *..... -.. e...
s a......e....
Y
?
1
.4
...4
..,...... ~.........
i 1
4 i
T
_w,.
.,.lp.
.... e.
.m e.me--..
.. g e.
.e
- ...............ee e.-...+
i k'
i 8
I 1
- - - ~.. -. -. -...-. -. - ~ - -. -. - -. - -, _ - -
Attachment
..A..-
I to SR -950209B i
- ~ - -
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 '.
. IWS.
- SMB, Closed Document Comp.
Aef tvel
'Innk l'er l'ormed l
......... isposItinn Open D
Number I. D.
Work Performed ny Ques t.l.ona.b l e..QCl.....
Remove Strain gauge M I C/.ll.P insp/JLP, Vpp MTC Adequate, inspection visual within the skills C
2683 BC-PT..120..
send, t.o. vendor 1)..I,ike.k ind. 2).Re tcrm.......
of craf t and QCI l
MIC/.II.P insp/VPp
...... -. - ~ ~ - - -.
.....---- __.~.
MIC Adequate, inspectinn Replace. strain visual within the skills C
1.)..I.tke kind.2) Reterm as 2 6 8. 2. _.....
BC P.T-l.?O.
M,a u g.e........
determed.
of craft and QCT t
t i
l C
1837 RG-PT-120 Voided Voided Voided No like kind verification C
i 00606 BG-TB-127 Replace card....
il.WM.P./ R.D.S...N.o,n..spe c i f i ed specifled. Retested SAT MIC/RDS insp/JLP MIC Adequate. Inspection visual. Retested SAT C
4858 BC-TE-1.07_ -.
R.epl.a_c.e..R.T.D..c.l.e.m.en,t.
1.)..L.i k e..k. i n q rBG-OSB rrepare pump for C
37779.... uni.t. 2.
s h,i p.m.e n.t.
ilWMP./.P.I,Il.. No.n..sp.e.c.i.f.i.e.d.... -
.il.W.M.P..Adequa t e 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 Closed Document Comp.
Ae t u:: 1
'I a n k l'e r f o rmed
,,,. Dispps i t inn, Open
- Number, I.
II.
Work l'er f o rmed I'v Ques t i onab l e,,Q01
,,,!R written concerning QC HG-liC T -
C 17829 8357n Swi tcli input leads insp/VPP.
,not being notified.
IR closed I.lke kind replacement not BG-l.n-Re.p l a.c e.ca rd...
.No.n.s.p.e.c i f. i.e.d......
.s p.e.c i. f. i ed..
See SR for C
llWMP 5769 106C & D discussion IR written for not
~ ~ ~
RG-l.CV-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..
Ins.p/VPP 1.lke kind replacement RC-I,QY-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 28017 190 Re i n s.t a l 1,I _n,s u l...._
M I C / R AR., Di,0,,,I n sp,. _0,I.0 _,_,
. Inspection visual C
-. =
At t acliment... A..
,t to SH 8'iO2098 -- -
e!A/I'NGlWEER l', val.IIATION OF
. WottK 'O'siClHliNIN Pa s',e __ 7 o f....I O.
f 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 T.WS SMn Clo9eil l
Occument.
Comp.
Actual Tank Petformed Number
- 1. D.
Work Performed n y qu.e.r.t.i.o.na.b l..e..Q.C.I..
....... D i s po s.i.t.l.o_n.
Open MIC/VPP insp./RAB MIC Adequate insp, visua!
C 00770 nG _rT-111 Replace xmitter..
M....... i. nd 2) C. l.ea nl i.n.e. s. s..
.wi th in,sk i l. l s o f c.r.a_f.L..
- 1) l.tke k 3
....~..-.
Term determ,.
and QC I
+
MIC not consistent with 3
?
33177 BC-rT-Ill Replace xmitter MIC/DWP, pre,vinus WR 00770. Retest C
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.
8569._..
B.C...T.V..l 1 I.
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 C
Install chart 3R646 RG-rY-11I recorder to monitor MIC/Rfn mig Adequate C
t" t
( tiput /otst pu t
+
+..... -. _.
6 k
L v
s J
........... ~.
4...... _ -.... - - - -.
'I
't
m.__.__
__m Attachment A
i 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.
Tank Performed Cl"sc'l Document comp.
Ar t n.i l
.... hispnslt(on Open.
Number I.
H.
..Wo r.k P.e.r.f.o.rm.ed..
. B.y..Q.ues t t ona.b.l.e..qc t.
Verification of Procedure Replace Hechanical steps MPM-nc-QP002,
. C I.n.s. p /.R.. AB 4260 P_BC.05.A.....Sea l....
- -......... ~...MTM./.7.-OW001 within the
.s.k i.l ls
_........ Replace Mechanical 3.269..
P.BC-O. S P,... Seals........
in.sP/RAB..
Same as above WR 4260 C
Inntall concrete C
.M. I.C. Ad e.qua t e.....
33538 N/A curbs CMP-84.-0508.. M.T C./.R. A. R.........nsp/VPP MIC Adequate Term & determ MIC/JI,P, VPP i
1 visual within the skills C
4 1852 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 of craft and QCf
-............ -.. ~... - - -
- - -... -... ~. -
fnstall..K...
T.....
I,lke kind not verified by ca 2921 HG-FQV-215A new card IIVMP/VPP None Specified QC. See SR for discussion.
C Retest SAT.
Visual within skills of f
Remove, Reinstall C
craft and QC[
i 27448.
B.G__F..T..i.l 0. _.x m.i.t.t.e.r....I.n.s P.cc.t.,.. insp/ RAM h
i
..................-..a
~
4 4
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..e.
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...--.-..... - *..*-w*--
k t
4 i
f m.
e r
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e
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Attachment -..A k
tn SH,85020')n q A/ENG I N.EE.R. EVAL.t'AT. IOM. OF Pagc 9
o f. 10_...
WoltK 110Cl!MENTS i
l Participants Date of Evaluatinn 3/14/85- -:
D. ocument Title Work Request.
i 1 E_P__...S.M. Po.
t
..... ~. _.. -. - - - - -.. -.. -. -,
~
C.l o.s ed 4
nocument comp.
Actual Task Performed
. ue s.t l.ona.b.l.e..Q.C.I...
..... Dispositinn Op.en Q
N.u.m.be. r
.. _ I D.. -...
. or.k Perform.ed...
By W
l
.M. I. C.. A.d. e.qu a t e C_
f rep aced,& Mod...
M I. C. / R An., D.ih..
30618 Insulation 5
Ad. e.qua t e 33704 Insulation Replaced.& Mod..
MtC/.nl.o....
ve. r i. f..i. c a t.i on.o.f.. l_ _i ke.k.. i nd.
7637 BC-TS-137A Replace. card MIC/HDS. No i.nspe.c.t t.on..
See SH for discussion.
i
~.
l MIC Adequate C _ __. _
MIC/DWp Temp Mod 84E44,5 24735 DP-RG-02B Re pa. i r.__B r.ca.k e r..
MIC and Inspection within skills of craft and QCI
_C Install on pump MTC/SJ1,
- k. n..a r.eho.u s.e..... _
insp/ tis I) Cleanliness Within the skills of the i w 2
16495 PBG-04 eversed output C
i 1
i 33384 l'RG-04 of controller
- 2) 1.ike kind 3) Switching craft and QC.I
~
- ~. - -..... -. - -..
Iines 9'
i Replace head insp/ RAM !) Parts 2) Torque Within the skills of the e
C i
3.)..C.l.e.a.n.l.i.n.e.s.s........ _ - - craft and QC.I 4
3.2784...
P R.C_-04 ga.s.k.e.t.s....-
l 1
4 t
i d-1 i
i
- _ _ _ - ~ ~.
?
j
. _ = -.
=r
At tachment.. A yA/12;1F3EER.. EVAL.ltA,1ON Ol'
-~
.T 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 Document Comp.
Actnal Task I'er formed Disposition Open Number
- 1. D.
Work I'erformed Bv Questlonable,8{CI 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 2160')
nc_,,..,
Modify 1nsulatton, IMil'/GS.Non-specif(cd....
_I!k7!P. Ad("lua te Wittiin tiie skills of the Pfl C/ RArt insp/ RAM lit ;- rT-l 'i f.
craft and QCl visual _
,,_...C.,
24568 RC,-l;'T-16 0,
Tighten Vent Cap
- 1) Verify. integrity does not leak BG26-R505 6 Modify insulation C
26293 R507/242
.lacket IMfP./.CS...N.o.n..s.p.ec i f ied IMiP Adequate Pfod i f y insulation M I C / DI.O. RAR Inspected DI.0 Within the skills of craft 30403 I n s.u.l a t ion
.lacket
- 1) Remnval 2).T.aggi.ng. __.._.
a.n..d._O.C.I. v i sua l C
- 3) Securing Modify Insulation 305R9 insulation
.lacket IM4P/CS _ Non-sp.ec.if led _ _..__ _.
.IMfP. Adequate C_
bd.
ALLEGATION MANAGEMENT SYSTEM RUN DATE: 850903 j
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 -
CONSTRUCTION FUNCTIONAL AREAS 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 SOFETY SIGNIFICANCE - NO BOARD NOTIFICATION - NO STATUS - OPEN SCHED COMPLETION - 850801 DATE CLOSED -
i ALLEGER NOTIFIED -
ALLEGATION SUBSTANTIATED -
O! REPORT NUMBER =
01 ACTION - NO 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 VIOLATION WAS SUBSTANTIATED.
j 10 CFR 2.206 PETITION WAS ALSO FILED HASED ON VARIOUS A
PUBLIC ACCOUNTS OF THIS ALLEGATION.
RECORD CHANGED - 850715 ENTERED SYSTEM - 850402 CLOSED SYSTEM -
\\*
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 e
9
+
s E
r W
~N
'.1 Q
e r1 Une 1985, COLUMBIA, MISSOURI 20 PAGES - PRICE 25' UE adds 15 inspectors
~
to roles of unqualified CHRISTOPH SZECHENYI operating in December, generates plants, Garde said, including the 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 u ork involved," he said. "If it didn't 6ed about E inspetions performed Uttle said he erpects the utility to by the E inspectors during the past wrap up its study by the end of require a high level of expertise, three years.
March. At that time, Ocary said, we*U probably assume it was done all right. We'll also check to see if A special utility task force has Union Electric wd! provide the com-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-come radaoactive.
about it000 = ork orders, said Utile
- 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 Ct8 I"'
illie Garde a staff me ber with
(**
plant untu Union Electric can dem-ula ry ion to shut d the Government Acteuntability whi belped d the tan -
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:
ment managers.
tions are established. Union Electric is also repeo gg "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:
{
ly got no action fro:n Shew when voicing concerns about But some inspectors said th!s week that they repeated-electricity in December.
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-Yesterday, the Fulton Sun quoted plant spokes::
hrmed today that mspectors took their concerns to 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 $3 bilhon taken seriously." After the interviews, deary said, plant naar Fulton. Reacting to the fmished autt, dated pleby put together a plan for corrwtave actaon. Ch Feb. 22, plant manager Steve Miltenberger suspended said he 6dn't know what changes Appleby had )
PorteU's certihcation. Portell, however, retains his su-posed.
pervisory role.
Inspectors said this week that they grew impa:
"A supervisor does not have to be certified at any level with Appleby's efforts, and so they asked Powers' q~
in any &scipline," said Robert Powers, assistant maa-ty assurance othee to investigate. Powers noted tha ager of the drvision that oversees the effectiveness of spectors have the right under company pobey to G plain to his division.
Auditors concluded managers had broken wri THE WEATHER
- P'"7 '."The inspectors check electrical, rnech
'*$ '" **"r*"a'ta"c*' by **N 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
,. u.,.1. F Or/ds((MhsE--.-
7
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- c.
W *.W *n.,
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w ?*tA a-Regdatory cotwussion inspector 96 Utue said s.destepping company t
pobey vloistaa federal rden. Ren.
p-g
]
3'
$c s' anted beenses to bund aM operata Cataway,l'nlon Dectric pledged to
=
. w uphold NRC regdatms sa weU as company pohcies, Utue noted.
On Tuesday, Ceary said, "We do not believe we have comrnatted any e
violauons." Bat Union Dectnc, Ut-I.
Ce stressed, knows the rdes.
7 Until the utihty and Utue com-l f' plete their reviews of the cert. fica-l l con problem, Utue said, the prob-
',4,y$*
lems are cons dered " potent;al vio-
' T.
I<
lauons" that codd lead to dwtphr>
.f,'
ary actice or fanes by the comT.la-
,, m.#4. v.
d alon.
m In addjuon to suggesting that the
, f, eertficauons be pd;ed froen the p
.*j seven inspectors unta their qual.fo
. Mg., ;
ceuons are estabuabed, the audit E.
/
aos -
5 proposed several other steps f or im-
/
k'
.j proving the certifwauon pricess.
J In responM, Powers said, e group of Inspectors, managers and quality i
tirannet worters wti recommend p
r L4 g specific thanges to match or etceed the prevaihng indarry r.andards TL'-
d w
& Wp_= m_Q for certLficauott.
Posen said the review of mair:te-
.sq-
,g r.ance work orders would show F
I whether some plant syr. ems need 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 I, etnsidersuon in certt>trg inspec-f tor y..-., ~
Said one inspector: "They abused 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 ee quahty control as-tenterger suspended PorteU's dual men from the ersterta without docu-for muluple dates instead of fartng Vernon Porten, certaficatAon. He retains his supere menung why, more employeea.
ry expertence in civ0 aory positon.Ceary said. but be has After tirashtrig their report, aude Powers derued cost savings sa e 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 on cf inspectern, quah-for inspections in more than one of er in interviews with the other in-teen made. I consider any violabon Terry Shaw,en the four tochtscal categories - to.
- spectors, of the program as a sfgt.llecant core 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 were found queouenable. In same Doctric's own written pobetes for This story was ampded aid erst-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
)
UEtargets unqualifiedp:
poncern surfaces about quality, pafety assurances at Callaway.
.- w
4'"
(C) IMS Columbia DaDy Tnbune its eristnal price estimate - sup-
?
Uruon Dectne Co. has aUowed un-pbes 1.150 megawatts for about 1 e'
- ' ' Mr
- r,'..
O
kj three years to help ensare Uw safety $L !.ouis aM dozens of Mad-Missourt
~8**
- hfied inspectors for more than enilhoo Union Doctric customers la w
),
d its Ca.naway County nudear communides, such as Ashland and '" M a 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.
N-9 their training, education or expe-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, Mf@.'yr..
pt -
The St. teula utCity Ls reviewing "We don't have any concern about i
! cort by W to M more inspectors em-the plant's cons'.ruction," be aaded,
@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 faalty inspecucna, huncreds of us24 mulucertfied trLspectors.
i 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 those records to find out what they in," the worker said this week,"and i
' actua!!y did," said James Gear *. sit, at that point I would have had to W
the Uruon Dectric employee who su-say,'Get somebody else in here who -
t pervLsed the audsL knows what they're doing."'
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.
about the quality control r;grameA -
sam.
I 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.
One person that Shaw recom-esses, the men did.not mee-his se.ditors tegan.Lnvesudsting t.he i eus."
e.me,ta wiu
.- i. 4m.er.re. ga a,v, a ea sugai de.es wa.ufw fe, two i.--
a e i-u e -in m.aa be e.,
- n. a m en Can l -,i.tw ai me,e v.y pi -
nui e,
e,s, Use. med,*ya Pe B. u.i week.
an ave omes
~
l mac s~m w ALLEGATION DATA FORM u s NUCLE AR r,EGUL ATORY COMMISSION (t 1-821 instructons on esvsese sede RECEIVING OFFICE Docket Number (if applicable)
- 1. Facility (ies) Involved:
(Nem*I CALLwAY 0 5' R 0 OI4_ f_1 t,,,-.,m., a generec, wnte GENERICI
- 2. Fonctional Area (s) involved:
(Check appropnaie boitesi l operations onsite health and saf ety 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 Receiving Allegation:
- 7. Of fice:
g ACTION OFFICE MW
- 8. Action Of fice
Contact:
tr., i ewo 6n,ti.i..no i. n.mei
- 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
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'2. ne,na,wsL,,
[doJnIrje.lchirM#lal41rl(1:I Isj/tyJZef,rl I 1
.c e.,
I I I I l_ I T I I I I_l I_l I I I n l I I I I IJ N
}* *L f f_f g-f}$ A'd_$ ) /
- 13. Allegation Number: