ML20136A993
| ML20136A993 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/28/1983 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20136A539 | List:
|
| References | |
| FOIA-85-59 PTM-002, PTM-2, Q1-QP-2.1-3, NUDOCS 8601020378 | |
| Download: ML20136A993 (71) | |
Text
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l l REVISICN l ISSUE
, TEXAS UTluTIES GENERATING CO. l INSTRUCTION PAGE l
NUMSER
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1 f6 PREPARED SY:
N QU OF APPROVED BY:
ELuTruCn INSPECTION L
- A7-j AND TEST PERSONNEL
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- 1. 0 REFERENCES i
l 1.A CP.QP.2.3, " Documentation Within QA/QC Personnel l
I Qualifications File" l
18 CP.QP 2.1, " Training of Inspection Personnel" 2.0 GENERAL I
i i
The ' purpose of this Instruction is to de fine speci fic l
1 inspection functions and capabilities for electrical l
inspection pe rsonnel.
TUGC0 Quali ty Engineering will I
assure tha t the required training is accomplished.
The l
requirements contained herein are not applicable to l
ma teri al, parts or components under the jurisdiction of l
l the ASME Code,Section III, Division I.
i i
l 3.0 INSTRUCTION I
j 3.1 ELECTRICAL QC TECHNICIAN INSPECTION FUNCTION Inspection functions may include, but are not limited to, the l
following :
a.
Perfoms installation inspection of embedded and exposed raceway.
b.
Pe rfo ms installation inspections of wi re and cable l
installations.
c.
Perfoms inspections of cable terminations and splices.
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d.
Perfoms inspections of electrical and ins trumen ta tion equipment installation and maintenance.
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i e.
Witnesses electrical testing of cables and equipment.
f.
Documents inspection resul ts.
1 TtGCC oA 8601020378 BD1113 PDR FOIA ppg G AR DE6 5-59
INSTRUCTION ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CMES QI.QP.2.1 3 8
M 2 8 583 2 of 6 3.1.1 Training and Examination i
Electrical' QC Technicians shall have knowledge and skill to adequately perform their assigned task.
The following shall be used as a
guide for training and examination of Electrical QC Technicians:
I a.
Construction specifications and procedures.
4 l
b.
Basic inspection plans and procedures.
c.
Specific instructions, checklist, and reports used in l
performance and documentation of inspections and tests.
1 d.
Electrical and structural blueprints and drawings.
e.
" Hands on" experience using inspection and test equipment.
f.
Familiarization wi th required measuring and test equipment.
i I
g.
Minimum on the job training (0JT) requirements are defined on each Electrical Technical Outline (Figure 1) and docunented per Reference 1.A.
3.2 ELECTRICAL QC INSPECTOR INSPECTION FUNCTION Inspection functions may include, but are not limited to, the following:
a.
May perform duties as an Electrical QC Technician in the activities for which qualified / certified.
2 i
b.
Prepares and interprets reports.
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c.
Provides technical direction to Electrical QC Technician (s).
t 3.2.1 Training and Examination Electrical QC Inspectors shall have sufficient knowledge and l
skill to adequately perform their assigned tasks.
The following shall be used as a guide for training and examination of Electrical QC Inspectcrs.
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TUGCO CA 1
4 i
INSTRUCTION ISSUE REVISION PAGE
^
TEXAS UTILITIES GENERATING CO.
3 f6 R 2 S 1983 a.
Construction specifications and procedures.
b.
Basic inspection plans and procedures, c.
Specific instructions, checklist, and reports used in performance and documentation of inspection and tests.
d.
Electrical and structu ral blueprints and drawi ngs.
e.
" Hands on" experience using inspection and test instructions.
f.
Familiarization wi th required measuring and test equipment.
g.
Interpretation of test results.
3.3 TRAINING DOCUfENTATION T
i Quali fication of electrical inspection personnel shall be i
documented in accordance with Reference 1.B.
Electrical inspection ~ personnel ~ shall' complete the General Training Outline (required by Reference 1 8) and the i.lectrical General Technical Outline (Figure II).
On canple. tion of the General Training Outline, the QC Super.
4 visor or his designee shall interview the trainee and sign 4
and date the Outline.
In addition to the Electrical i
General Technical Outline, speci fic Quality Instructions have been developed by Quali ty Engineering, for each electrical inspection activi ty.
These fo m the basis of infonnation required for a particular inspection function.
Electrical QC personnel are certified in a given inspectior.
function / activity.
A Technical Training Outline (Figure Il docunenting quali fication requirements for a
given inspection function / activity will be completed and verified by the cognizant QA/QC Supervisor.
3.4 QUALIFICATION MATRIX (WORD PROCESSOR PRINT 0tJT)
A matrix shall be maintained by the Electrical QC Supervisor l
to identify the specific inspections an individual is qualified to perform.
These specified inspections shall be i
indexed by the Quality Procedure or Instructions.
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INSTRUCTION ISSUE WSION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
4 of 6 JR 2 8 33 3.5 TRAINING CERTIFICATION Inspection Certification per Reference 18 certifying satis.
factory completion of training in accordance with this Instruction will be placed in an individual file for each t
QC employee, signed by the Site QA Supervisor and Quality Control Supervisor or their designees.
Certification in a particular Inspection function will be for a period of 1 year.
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1 TUGCO CA m asa,
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INSTRUCTION ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES 8
QI-QP-2.1-3 jut 2 8 1983 5 of 6 I
FIGURE 1 QUALITY CONTROL TECHNICAL TRAINING CUTLINE QC ELECTRICAL OEPARTMENT C1. Ass'1E CON:u!T RACEdAY IN3PECT!CN (QI-GP-11.3-23)
NAME DATE C:st4ENCC:
A.
COMPLETE STEPS F, G, H AND J CF THE ELECTRICAL GENERAL TECHNICAL CUTLINE.
LEAD INSPECTCR CATE 3.
PERFORM A MIN!Mt.W HOURS *CN-THE-JC8,CF fiQ TRAINING IN.NIS ACTIVITY.
ELEC. CC SUPERV!s0R OATE C.
OEMCNSTA.tTE PRCFICIENCY IN PERFORM!Nta fNSPECTICN.
ELEC. CC suPERV!s R OATE 3.
- EMCNSTRAIE PROFICIENCY IN CCMPLETING THE INSPECTICN CHECKL!sTL$J.
LEAD INSPECTCR OATE E.
ATTEND FORPAL TRAINING SESSICM FCR THIS ACTIVITY.
INSTRUCTCR OATE l
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EXAMINAT!CN COPPLETC.
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ELECTRICAL CC SUPERVISCR 2 ATE 1
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INSTRUCTION ISSUE N
DATE TEXAS UTILITIES GENERATING CO.
CPSES QI-QP-2.1-3 8
& 2 8 1983 6 of 6 i
FIGURE 2 j-CPSES CUALITY C0VfRCL CEPARTPfmf ELECTRICAL GEMEPAL' TECHNICAL CUTLINE j
MAME DATE CO**EMCED:
Rosa and discuss the following Precedures and Instructions witn Lead Inspectors.
A.
GaH Specificatica ES-100.
- Electrical Erection Specification' Trat nee /Date Lead Inscoctor/Cate
.i 5.
F5AA Chaeter 8. " Electric Power
- Trainee / Gate Lead Inspector /cate i
C.
CP-CP-2.0. Isolamentation of CP5ES QA Pregram" Trainee / cate Lead Inspector /Date D.
CP-CP-3.0, "CPSES Site QA/QC Organization" i~
Trainee / Cate Leao Inspector /; ate E.
CP.CP-11.3, " Electrical Inspection Activities
- Trainee /cate Lead Inspector /cate t
F.
CP CP-13.0, " Control of f4TE' j
trainee /ga te Leac Inspector /; ate G.
CP-CP-15.0, " Tagging system
- j Trainee /Date Leae I.
eye H.
CP-CP-16.0, "Monconformances and Deficiencie Trainee / Date Lead inspector /Date I.
CP-CP-16.1, *5f gnificant Construction Deficiencies
- l Trainee / Cate Lead Inspector /Cate J.
CP-CP-18.0, " Inspection Pecort" t
reu neetcate Leno inspector /; ate QC* SUPERVISCA*5 !NTERVIEW:
ga te signature T1.JGCC CA p.,,,, g,
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.A-3% indicated there were. several instances in which he felt pressure had been exerted on him not to write NCRs. A-36 stated that within the past month, he AQE-1 learned of a problem in the Control Room of Unit-I in which electrical < ables were being removed withn"t emner dar"mant=rion.
A-36 indicated that he wanted to write an NCR on the lack of documentation, but that V-l
. a QC supervisor, had instructed him not to write the NCR.
. 38 told of another situation which occurred within the past month in the Safeguards Building in which cable was removed without documentation.
A-3 6 said Wi he again tried to write an NCR and that it was rejected twice by A-36 said that after the third time he submitted the NCR, it was accepted but that he did not know if it was placed in the system.
3.36 described another situation within the last couple of weeks involving flex,
c_onduit in the Fuel Building. Conduit was replaced and not repaired as described Age-3 by an NCR. A-38, said he had been told by his Lead, V - 2.
. to disposition the NCR, but that he had not yet complied with his lead's orders.
4-A-36 recalled another occasion in which his Lead, U-7_, directed him to "close out" an NCR that he was not certified to do. Ae-3S said 'that this NCR concerned conduit and that he told 0-2. he was not certified to do the job, but that told him to do it anyway. A-3D said he closed out the NCR and it was later
" kicked back" and corr ected. L oob ' d'T o 2~~) M C "- S
-A-b recalled another, situation, in April 1983 in Unit 1, in which craft needed an i
NCR Closed 50 they could proceed with the pulling of cable. %-36 said that problems with the (%ble tray had not been correctoi. A-36 said he remembered A9I-5 there was trash in the rahla trav) cuts in parts of the cable, and the cable wa,5, ajsointerwoven..A-3b. said he refused to close out the NCR.
A-36 said that *his Lead,0-2, was contacted by someone in craft (identification unknown) who told him 0 t_
to.have A-3 close out the NCR. A-36 said tha: U-2_ told him, "I'm not telling you that you have to do it, I'm telling you that they want it done." 4-35 r-b G3
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9 stated he refused to close out the NCR 4s-35b indicated he was directed by 0-2L to reinspect again, and that he again refused to close out.the NCR. 4 3fb 'said' 493T-5 that 0-2.10t 'a'nother" inspector'to'close out the NCR, and that U-b (no longer dan +.
employed by B&R) was the general foreman who was a witness to this incident.
4(-33 concluded that based on these above instances, he. felt he' had been harassed as a QC inspector and that his supervisor had made attempts to intimidate him to keep him from performing his duties. J(.3fc said he had earned the nickname " Shut'em Down A-30," and that this title was used to belittle him.and create pressure from his co-workers g(-37) stated that when he came to work at CPSES, (1-dW the supervisor, told him, "This company does not care about people, it just cares about getting the job done. You'll do your job as you're told and nothing more."
JL'3a said it was his opinion that quality control was not their first concern, but rather production was the important thing.
i' 4-3B> was asked for the NCR identification numbers, but stated he did not recall the NCR numbers. -A.-36 said he wculd obtain the identification numbers of the NCRs and give them to the Nuclear Regulatory Commission.
INVESTIGATOR'S NOTE: Subsequently, 3(-jt> was contacted on four different occasions and explained he had not been able to identify the NCRs in question.
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-A-3S indicated there wer several instances in which he felt pressure had been exerted on him not to write NCRs. A-36 stated that within the past month, he iQE-1 learned of a problem in the Control Room of Unit-I in which electrical _lables were be@oyed without_.pcoper e v ant =? ion. A-36 indicated that he wanted to write an NCR on the lack of documentation, but that u-g
, a OC supervisor, had instructed him not to write the NCR.
f-3Stold of another situation which occurred within the past month in the Safeguards Building in which cable was removed without documentation.
A-3 6 said M'E he again tried to write an NCR and that it was rejected twice by A-36, said that after the third time he submitted the NCR, it'was accepted but that he did not know if it was placed in the system.
3-36 described another situation within the last couple of weeks involving flex,
conduit in the Fuel Building. Conduit was replaced and not repaired as described
.Q c-3 by an NCR.. A-38, said he had been told by his Lead, U - 2.
. to disposition the NCR, but that he had not yet complied with his lead's orders.
~
-A-36 recalled another occasion in which his Lead, U-Z. directed him to "close.
out" an NCR that he was not certified to do. A;-3S said that this NCR concerned QIi conduit and that he told 0-Z. he was not certified to do the job, but that 4
told him to do it anyway. A-3D said he closed out the NCR and it was later
" kicked back" and corrected, l.oo b 8'W 2.7 iJ C G S
-A-y> recalled another, situation, in April 1983 in Unit 1,.in which craf t needed an NCR closed 50 they could proceed with the pulling of cable. %-36 said that p_roblems with the othle tray had not been correht. A-38, said he remembered 6'S there was ttisA_,.ip tha nahla travI cuts in parts of the cable, and the cele,,a3.
agointerwoven. A-3b said he refused to close out the NCR. A-36 sa i'd tha t *hi s Lead 0-2, was contacted by someone in craf t (icentification unknown) ano told him 0 '2.
to.have A 3 close out the NCR. A-3E said that U-7._
told him, "I'm not telling you that you have to do it, I'm telling, you that they want it dye." 4 -J E
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' stated he refused to close out t'he NCR. -A-G, indicated he was directed by U-2_
j to reinspect again, and th'at he again refused to close out the NCR. *3E 'said' W-5 that 0-2. lot a'nother' inspector'to'close out the NCR, an'd that 0-$
(no longer C m+.
employed by B&R) was the general foreman who was a witness to this incident.
A-38 concluded that based on these above instances, he. felt he had been harassed as a j
QC inspector and that his supervisor had made attempts to intimidate him to keep i
him from performing his duties. A 3S said he had earned the nickname " Shut'em l'
Ocwn N-30," and that this. title was used to belittle him and create pressure from his co-workers. A-3h stated that when ~he came to work at CPSES, o -4 i
the supervisor, told him, "This company does not care about pecple, it just' cares about getting the' job done. You'll-do your job as you're told and nothing more."
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<2, said it was his opinion that quality control was not their first concern, but rather production was the important thing.
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-k36 was asked for the NCR identification numbers, but stated he did not recal.1 the NCR numbers. 4-36 said he would obtain the identification nu:.bers of the NCRs and give them to the Nuclear Regulatory Commission.
4 INVEST! GATOR'S NOTE:
Subsequently,.A-30 was contacte.d on four i
different occasions and explained he had not been able to identify the NCRs in question.
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0G6<.J.Csq G CCMANCHE PEAK OPEN ISSUE ACTION plan-
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Task: Failure to. complete, process, issue, void, and disposition NCR's.
- Also, allegation that inspection reports were used instead of NCR's.
I Ref. No.:
AQ-30, AQ-31, AQ-32, AQ-AQO-11,AQO-12,AQO-13,A[4AD-1A_ 10-17 A
1,AQE-4,AQE]QO-8,AQO-9,AQO-10, AQP-1, AQH-2 Characterization: Various concerns involving NCR program, including:
a.
Generation of NCR's b.
Disposition of NCR's l
c.
Voiding of NCR's d.
Use of inspection reports instead of NCR's Initial Assessment of Sionificance: NCR's may not have been issued, when required or NCR's may have been improperly dispositioned. This makes the validity of l
construction, inspections, or rework subject to question.
Source: QA allegations; see allegations list Aoproach to Resolution:
1.
Review NCR procedures for adequacy. Review procedure changing NCR system to inspection report system.
2.
Examine a sample of NCR's and see if they conform to procedural requirements.
Sample should include craft areas mentioned in allegations and some areas outside those mentioned in allegations. -
l 3.
Examine a sample of inspection reports and' determine if inspecti'on report i
items should have been NCR's.
4 Examine a sample of items reworked.or actions taken in response to NCR's to conform disposition in accordance with NCR and procedural requiremehts.
5.
Interview sample of QC inspectors, supervisors, and craft personnel to ascertain implementation and knowledge of NCR procedures.
6.
Evaluate threshold for generating NCR's and placing them in system.
7.
Refer any examples of wrongdoing to TRT manager.
8.
Evaluate allegations.for generic / safety implications.
9.
Report on results of review / evaluation of allegations.
1 Related Ocen Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
i from the tracking system open item list.
(Region IV identify and add to this work package.)
2.
Review activities necessary to close or partf ally close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
~
l 3.
While performing physical inspections above, examine surrounding systems, components, and structures for related apparent defects or indicators of faulty workmanship.
4.
If workm n are still in the area of a physical inspection, interview them for related knowledge of other potential deficiencies.
5.
Ccmplete portion of IE Module on QA/QC Nonconformances.
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g COMANCHE PEAK OpEN ISSUE ACTION h_AN Task: Determine if inspectors, welders, supervisors are qualified.
Review procedures and training requirements.
Ref. No.: AQW-1, AQW-AQW-3,AQW-4,AQW-5,AQW-6,AQW-7,Ah4-11,AQC-9, AQO-27 E,
Q-23, AQ-24, AQ-26, AQ-27, AQ-28, AQ-29, AQ-63 Characterizationh:
C Various ' concerns involving procedures, training of personnel and inspections by unqualified personnel, and welding and other practices.
1 Initial Assessment of Significance:
Initial disposition in IR reports for i
several of these allegations. There appears to be enough specificity to warrant i
followup on these allegations.
The allegation related to 00L (Department of Labor) on Dunham should be treated separately from the facility training, unqualified personnel, and other general allegations.
Source:
QA/QC Category 12 - QC inspector (or. supervisor) qualification / training
(
Acoroach to Resolution:
1.
Review IR
-09, IR 79-20, IR 79-11, IR 79-15, IR 79-12, IR 83-52, IR 82-11, and
_. -04 to determine if documentation adequately supports findings.
M g,.
If not, appropriate action to close allegation.
ps 'y#
Review training and OJT procedures, in question, for adequacy. Were 2.
training standards and/or FSAR commitments met?
)
3.
Otscuss adequacy of procedures with persegmel involved with welding and' i
y7 training. Discuss adequacy of other' OJT *elding procedures. Examine weldments, as appropriate, that are associated with any inadequate procedures or training activities identified during interviews.
4.
Review sample of similar-type welding / training procedures for adequacy.
5.
Refer any examples of wrongdoing or significant deficiencies to TRT canager.
6.
Evaluate allegations for generic / safety implications.
7.
Report on results of review / evaluation of allegations.
8.
00L on Dunham should be reviewed separately (contact TRT).
1 j
Related Ocen Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
from the tracking system open item list.
j to this work package.)
\\(Region IV identify and add l
2.
Review activities necessary to close or partially close ~ related items, either based on inspection conducted above or reasonable additional i
insoection while the inspector is familiar with the areas.
3.
While performing physical inspections above, examine surrounding systems, components, and structures ~ for related apparent defects or indicators of faulty workmanship.
4
. If workmen are still in the area of a physical inspection, interview them j
for any knowledge of other potential deficiencies.
5.
Complete portion of IE Module on welding and/or, training if it relates to effort made on allegations.
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COMANCHE PEAK OPEN ISSUE ACTION PLAN Task:
Ref. No.: AQ-28, AQE-30, AQO-?
003, AQO-16, AQO-17, AQO-18, AQO-19, AQO-20, AQO-23, AQO-29c, QE,
08-1, AQ-52, AQ-61, AQ-78, AQ-79 Characterization:
1.
Craf t would satisfy a component..odification card (CMC) on an inadequate weld by welding over it instead of cutting its defects out per procedure.
2.
Safety-related welds were repaired with weld tech (W.T.) holdpoints instead of QC holdpoints in violation of procedures.
3.
There are various technical and procedural problems in coatings QC dept.
at CPSES.
4 Coating dept. supervisors are not properly implementing QC procedures.
5.
The supervisor of the paint QC dept. gave verbal instructions to perform inspections at "an arm's length" instead of performing visual inspections (close to the paint surface) as required by QC procedures. This inadequate inspection will cause inspectors to accept substandard coating work.
6.
The same supervisor in 5, above, forced QC inspecters to allow painting operations to continue even though it was not in accordance with procedures.
7.
Inspection acceptance / rejection criteria for inspecting "backfit coating" operations were vague.
8.
Numercus design change authorizations (OCA) have been issued to downgrade.
the surface preparation requirements from SP10 to SP6; i.e., nuclear standard to heavy industry standard surface prepa,stion. Management allows SP6 requirements to be downgraded by allowing DCA to be dispositioned "do the best you can" in areas where access is difficult. Note: NRC CAT team -
did an extensive review of OCA system.
l 9; DCAs are also written to deviate from AS 31 specs. At least 40% of the DCAs are nonconforming condition.
- 10. There are problems regarding the calibration of the Dimetric automatic welding machines.
- 11. The CPSES coating program does not satisfy ANSI 1.014 requirements.
12.
A QC supervisor repeatedly told QC inspectors to violate inspection procedures; do not do i n p roce s s i n sp ect i.o n ; QC buv i ng o f f ta rm f u t f - *.at_.are-.r.ot in accordance with orocedures/ drawing _s.
13.
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Inspection of Hilti bolt documentation packages may have been approved
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desofte inspectors recognizing that the documentation package does not 4
~
conform to CPSES procedures.
14.
Out of round pipe was heated and reformed with engineering authorization and/or procedures.
15.
Valve maintenance (i.e. disassembly-reassembly) was not controlled and parts of different valves intermingled making material traceability invalid.
16.
Supervision advocates following proc.edures until "we get in a jam where something is_ holding up something and we want something welded immediately, then go ahead and weld it out of procedure."
17.
There have been improper sigt: offs on ". hold points" on travelers.
-18.
Craf t by passed, procedures by telephoning orders to the fabrication ~ shop in lieu ~of sending drawings.
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~._c COMANCHE PEAK OPEN ISSUE ACTION PLAN Task:
,M Ref. No.: AQW-15, AQW-16, ACW-17, AQW-18, AQW-19, AQW-27, AQE-h AQB-2, AQ-38, AQ-39, AQ-50, AQO-7, AQO-14 Characterization:
Inadequate and/or improper certification of the qualifications of QC personnel.
Initial Assessment of Significance: Possibly indicative of a general breakdown in the QA program.
Source: Various Accroach to Resolution:
1.
Review procedures, codes / standards, design requirements, NRC requirements, and licensee commitments for adequacy at time work was performed; were codes / standards, FSAR, contractor requirements, and other commitments met?
2.
Discuss adequacy of procedures with personnel involved. Examine installation, as appropriate, that is associated with any inadequate procedures identified.
3.
Refer any examples of wrongdoing or significant deficiencies to TRT manager.
4 Evaluate allegations for generic / safety implications.
5.
Report on results of review / evaluation of allegations.
Related Ocen Issues Review activi+1es necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
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PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UBUTIES GENERAENG CO CMES CP-QP-2.1 15 1 of 13 7
b
- 7//b PREPARED BY.
TRAINING OF INSPECTION N
g CATE. ' '
PERSONNEL WMlfY f
a APPROVED BY:
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1.0 REFERENCES
None CONTROL _ED40PY, 2.0 GENERAt The purpose of this MNk ID.to e stab s the minimum requirements for training, qualification and certification of personnel perfoming inspection to provide assurance that these, personnel have and. maintain the appropriate knowledge and skill to properly perfom their assigned responsibility.
~
The,requi rements contained herein apply to inspection personnel involved with activities ~ not under the juris-diction of the ASME Code,Section III, Division I.
3.0 PROCEDURE The TUGC0 QA Supervisor is responsible for the training and certification of inspection personnel.
In order to develop professional growth, the cognizant QC discipline supervisor is delegated responsibility to develop individual Training outlines for inspection personnel, depending on experience and education.
Level I personnel performing inspection shall have experience in and shall have completed a technical training course and examination in the area of inspection responsibili ties.
1 Level II personnel perfoming inspections shall have experience in and shall have completed a technical training course in the area of inspection responsibilities.
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PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
SES CP-QP-2.1 15 FEB 17 1984 2 of 13 l
The education, experience and on the job training, specified in : this procedure or supplementary instructions may be i
redaced by -the Site QA Supervisor when other factors i
can ' provide reasonable assurance chat personnel under 4
his di rection can competently perfo m a particular task as prescribed by detailed written Quality Procedures /
Instructions.
Such deci sisnt_ <h211 be. documented as p.t rt of the certification process and shall be included ir, the inspector's personnel file.
......... ~..,
The Training Coordinator is designated responsibili ty to maintain the inspector personnel file consistant with this Procedure and applicable Instructions, within the Permanent Plant Records Vault.
The Training Coordinator will review the training records for legibility, completeness, and identification of the item involved.
3.1 I!OOCTRINATION AND TRAINING The following are, minimum indoctrination and training requirements for, inspection personnel.
Indoctrination requirenents shall nonnally be satisfied within the first sixty days of empVoyment, And shall be documented on Figure 1.
Personnel satisfying documented $ technical training require-ments may be assigned to inspectton or testing functions prior. to completion of. the QA indoctrination requirements.
i a.
10CFR50, Appendix B; ANSI N45.2
-The method of presentation of this material will be by infomal di scussions,
reading / study assignment,
~
An oral checkout seminars or other appropriate means.
covering ANSI N45.2 and the 18 Criteria will be given by the responsible supervi sor who shal l,
upon satisfactory completion, so note by signing the General Training' Outline (Figure 1).
b.
IndustrhSta'ndards Inspection personnel should become famili ar wi th prepared standards ( ANSI, IEEE, ASME, etc.) applicable to assigned duties.
The method of presentation may be s
through dtudy, fomal seminars, or other appropriate means. l Suoplemental _exogsure is acqui red by daily association with these standards. The familiarization is a continuing procesi rad as such requires no fomal Checkout.
TUGCO CA 3
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PROCEDURE ISSUE PSVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES CP-QP-2.1 15 FEB 17 1924 3 of 13 c.
10CFR50.55(e) and 10CFR 21 The niethod of presentation will be by assigned reading, study and/or training sessions.. Upon completion and understanding of the basic requirements as they relate to job duties and responsiblities, the individual shall so note by signing the Training Outli ne.
Formal or infonnal training sessions shall emphasize the need for prompt reporting of product deficienci es or failures to the TUGC0 Site QA Supervisor.
3.2 PERSONNEL CAPABILITIES There are three levels of qualification.
The requirements for each level are not limiting with regard to organiza-tional position of professional status, but rather, are limiting with regard to functional activities.
3.2.1 QC Technician (level I) Capabilities A QC Technician shall be cabable of performing the inspec-ti ons, examinations, and tests that are requi red to be performed in accordance with documented instructions.
The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use.
The individual shall also be capable of determing that the calibration status of inspection ~ and measuring equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved.
3.2.2 OC Inspector (Level-II) Capabilities A QC Inspector shall have all of the capabilities of a QC Technician for the inspection,
examination or test.
Additionally, a
QC Inspector shall. have demonstrated capabilites in planning inspections, examinations, and tests; in setting up tests including preparation and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations, and tests; in reporting inspection,. examinations,- and
. testing results; and in evaluating the validi ty and acceptability of inspection, examination, and test results.
3.2.3 level III Personnel Capabilities
'A Level III Derson shall have all of the Capabilites of a QC Inspector 'for the inspection, examination or test.
In
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PROCEDURE ISSUE REVISION PAGE NUMBER DATE ps unuBES GENERATING CO.
CP-QP-2.1 15 FEB 17 1984 4 of 13 addition, the individual shall also be cabable of evaluating the adequacy of specific programs used to train and test inspection, examinations, and test personnel whose qualifi-cations are covered by this procedure.
3.3 EDUCATION AND EXPERIENCE The following is the recommend'ed personnel education and experience for each level.
These education and experience recommendations should oe treated to recognize that other factors may provide reasonable assurance that a person can competently perfonn a particular task.
Other factors which may demonstrate capability in a given job are previous per-fonnance or satisfactory completion of capability testing.
Use of the reasures outlined in this section to establish that an individual has the required qualifications in lieu of required education and experience shall result in documented objective.. evidence (i.e., procedures and record of~iTrItiten" test) demonstrating that the individual indeed does have " comparable" or " equivalent" competence to that which would be gained from having the required education and experience.
This detennination shall be made by the TUGC0 QA Site Supervisor.
3.3.1 QC Technician (Level I) f A QC Technician shall have:-
a.
High school graduation and six months of related experience in equivalent inspection, examination, or testing activities, or b.
Completion of college level work leading to an Associate Degree in related di scipline plus three months of related experience in equivalent inspection, examination, or testing activities, or c.
Four-year college degree with no experience in equiva-lent inspection, examination or testing activities.
3.3.2 QC Inspector (Level II)
A QC Inspector shall have:
a.
One year of satifactory perfonnance as QC Technician in g g reg onding i nspection, examination or test TUGCO CA
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ISSUE PROCEDURE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES FEB 17 1984 CP-QP-2.1 15 5 of 13 b.
High school graduation plus three years of related experience in equivalent inspection, examination, or testing activities, or c.
Completion of college level work leading to an Associate Degree in a related discipline plus one year related experience in equivalent inspection, examina-tion, or testing activities, or d.
Four-year college graduation plus six months of related experience in equivalent inspection, examination, or testing activities.
3.3.3 Level III A Level III shall have:
a.
Six years of satisfactory performance as a QC Inspector in the corresponding inspection, examination or test category, or b.
High school graduation plus ten years of related ex-perience.i n equivalent inspection, examination, or testing activi ties, or high school graduation plus eight years experience in equivalent inspection, examination, or testing activities, with at least two years as QC Inspector and with at least two years asso-
/
ciated with nuclear facilities--or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or c.
Completion of college level work leading to an
~ Associate Degree and seven years of related experience in equivalent inspection, examination,. or testing activities, with at least two years of this experience associated with nuclear facilities--or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or d.
Four-year college graduation plus five years of related experience in equivalent inspection, examination', or testing activities. - with at least two years of this experience associated with nuclear facilities--or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility.
Tuoco oA
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTIUTIES GENERATING CO.
CPSES CP-QP-2.1 15 FEB 17 igy 6 of 13 l
3.4 PHYSICAL REQUIREMENTS Each person who perfoms inspections shall be physically capable of perfoming the assigned task.
As a minimum, inspection personnel shall have:
a.
Natural or corrected near distance acuity such that the inspection person is capable of reading J-1 letters on a standard Jaeger's test type chart for near vision or equivalent test type.
This test shall be perfomed annually.
b.
Color vision as applicable.
NOTE:
Waivers may be granted on a case-by-case basis by the TUGC0 Site QA Supervisor.
3.5 ON THE JOB TRAINING (0JT)
Minimum on the job training requirements are established within each di scipline instruction.
On the job training shall be under the di rect supervi sion of a quali fied Inspector or Instructor. Qualification as an OJT Instructor snall be certi fied on the Instructor qualification fom.
(Figure 2).
3.6 EXAMINATIONS
/
Examinations may be oral, written, practical or any combina-tion thereof.
Discipline or functional supervisors are re-sponsible for administering oral and/or practical examina-tions and assembling the results in a manner suitable for a review by the Quality Engineering
- staff, who shall administer a
written examination.
Waivers for any examinations must be approved by the TUGC0 Site QA Supervisor.
3.7 CERTIFICATION Inspection personnel shall be certified by the TUGC0 Site QA Supervisur as being qualified to perfom their assigned tasks.
The Inspection Certification Fom-(Figure 3) shall be used to document this certification.
The Inspection Certification Fom shall be placed in the person's file along with the individual's Training Outline (s).
The effective period of certification shall be one (1) year, at which time the person will be re-evaluated and, if appropriate, additional training will be conducted. He may pm TUGCO CA
+
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
.CPSES CP-QP-2.1 15 FEB 1'l E84 7 of i3 then be recertified and doctanented on the Quality Control Recertification Fonn (Figure 4) and this will be filed in the person's file.
When project requirements dictate an individual may be certified to a limited scope of an inspection activity. The limited scope certi fication shall be doctanented on the Inspection Certification Fonn (Figure 3) and shall clearly delineate the inspection autho rity given the ins pector.
Discipline or functional supervisors may require additional training and recertification of personnel under their control at any time that performance warrants.
3.8 MAINTENANCE OF PERSONNEL CERTIFICATIONS 3.8.1 The TUGC0 QA/QC Training Coordinator shall be responsible for updating of QC technician's/ inspector's certifications when procedures / instruction revisions are made.
~
3.8.2 This certification saintenance shall be by fannal training and/or required reading.
Fonnal training will be conducted by the TUGC0 QA/QC. Training Coordinator or the cognizant discipline Quality Engineer.
Updating by required reading shall be the responsibility of the Discipline / Building QC Supervisor under the direction of the TUGC0 QA/QC Training Coordinator.
3.8.3 This certification saintenance will be documented on a
/
fonnal Classroom Attendance Sheet (Attachment 5) or a Required Reading Completion Fonn (Attachment 6).
The applicable fann will be maintained by the TUGC0 QA/QC Training Coordinator in the technici an's/ inspector's training file.
1 i
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PROCEDURE ISSUE PAGE REVISION NUMBER DATE TEXAS UTILITIES GENERATING CO.
FEB 17 1584 a of 13 CP-QP-2.1 15 FIGURE 1 Civ4Ancit. ftAK SIC /Je fLfCTalC 11A!Itst crao4 70A141"Wi @T,f MC 70 St C39LETED ST:
(no asys Arter taeloy-wr.t) 1 RAM !
00Ctwaft 5fGnattjat / Dart 1.
Flaal Safety Analys6s assert Chapter (s) 17 2.
Title 10 Code of feeeral tegulattent.
Part 50. Aeosadia 5 and am11 #45.2 3.
anc ae platory Gutees (As Assipes) 4 Industry Standards (As Assigned) 5.
GA/0CProceewresandInstructions.
(As Assiped) 6.
Title 10 Case of Federal segulattes.
Part 21 and 10CT150.55e
[
F.
Other aoslicatIe Documeata ae IIstad beleet b
VLktritJ si it Oufting Aeonovt0 8ft DATtt TUGCO CA
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1 PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
{ FEB 17 1984 _
g of 13 FIGURE 2 TQA5 UTILIT!!3 CDUATIM C3'fMY
$1ALITY A1522MCC CIPaADOT 1R5TRUCTCA CUALIFICATION nmet:
CATT LDEL & CDTIFICATICm:
ACTITITT CUTIFIt3 70 PERFCRMr 1*JCCD Mt0CEDutt/taSTauCT!ON MO.:
TYPE F DAMIRATIGI S!TDs OstAL ut!TTU PRACTICAL RESULT & UAMIRAT!Gl(s):
a CDeqENT32 8ased soon a constcarstion of t>e som:stian, provtous wort espertance, formal trsteing in tDe current rewtsten of tDe CF5(1 proceeare/
instruction, and the todividual's em on the-jet trstetag, a previous certtf tcatten nas been ases for this 0.C. Technician in tais activity.
A sattsfactory evaluetten of tne indtvidual's demonstrated proficiency to the performance of daily wert has new been ases and, with recognitten that the CP2$ QC inspector training program addresses specific CC inspeC*.e ten functions, it is falt that tDere is ressmatie assurance that the individual can cessetently pertere as an OJT QC Instructor in this activt y.
This certification specifically covers giving NT instrWCrien in this precedure, including the use of personal knowleege and esservatten to participate in the (b.% 0.C. Tratnee's Instruction.
.This QJT Tratatng Cartificatten empires in one year if no tospections are
[
perfereed in this activity by the indiviesel, and regardless, en 5 9er,iser TUGCO CA Form Na 3 Y
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
cPSES CP-QP-2.1 15
!FEB17 EBd l 10. of 13 s
FIGUPI 3 1
i i
TEIAS UTILITIES GENERATING COMPAttY i
QtlALITY ASSURANCE DEPARTMENT INSPECTION CERTIFICATION I
John seith 11/23/81 e
napg OATE t
I LEVEL OF CERTIFICAT!GIQC Technictan--Randon Conduit Fabrication M TIVITY CERTIFIED TO PERFORM: Evaluation of Randon Conduit
-Fabrication Acttwities -
UNTIL.11/23/83 aATE
. TUECO PIE 3CEOURE/INSTIBICTION NO.: CP-CP-11.3-30 TTPE OF EIAMINAnJK GIVEN: IX ORAL II' WRITTEN II PRACTICAL g
MSIA.T OF EIAMINATI*.N(5): Satisfactory Oral in 0C Office: 82.2%
'on M tted eiamination: Practical examination with satisfactory results before QC Supervisor H. Williams.
CDGENTS: Trainee qualified with examinations. OJT training an(h 14 years' experience.
Mhk E!X ED EXPERIENCE:
'I' YEARS EIRICATION: H.5'." pius 3 yearse not yet GRA(RIATION/DEMEE
.couege FOMAL TRAININE!'eev: 14 of orecedure 11.3-'30 C M LETED GJT TRAINING: $dtIsfacto'ry -
43.5 HOURS THIS ACTIVITY
[EIARINATION: "Sati sf actory -
82.2 EVALUATED ON:- 11/23/81.
1 WITH CONSIDERATION OF REC 3RDS OF EDilCATIGI. EXPERIENCE AND TRAINING, JOB PROFICIENCY AND DEMONh STRATED SKILL ST: ' H.' Williams. QC Supeniser
.PNETICAL HEALTH: 54tisfactory -
FOR ASSIMED TASK OF THIS PROCEDURE / ACTIVITY. RECartENO A55fGmENT AS LEVEL 1
~
itITM JE-EVALUATION OF JOB PERFORMANCE AMO PROFICIENCY ABOUT:
J
-11/23/82 I
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CP-QP-2.1 15 FEB 17 1984 11 Of 13 F!GURE 4 TE:tAS tmuTTES GENERATING COMPANY QUALITY ASSURANCE DEPARTMENT GUALITY CCNTACL RECERTIFICATICN MAME:
DATE:
cc TECHNICI AN DEL d LEVEL CF CERTIFICATICN:
ACTiv!TY CERTIFI C TC PERFORP:
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A TU$C0 PROCEDURE /INSTRUCTICN M0.(S):
=
TYPE OF RECERTIFICATION EXAM GIVEN:
CRAL
'*R!TTEN PRACT! CAL RESut.TS OF RECERTIFICATICN EXAM:
l CMNiS: k S C CM PREVICUS CERTIFICATICN IN THt$ ACTIVITY, AND CCNTINUC SATISFACTORY PERFORMANCE, THE ARCVE NAPC [NDI-VfDUAL IS sERGY RECERTIFIC AND AUTHCRIZE TC PDFCRM ACT!vE l
GC INSPECTIONS AT CPSES IN THE AREAS L!sT C ABCVE. TH!3 RECER-TIFICATION WILL EXP!RE IN CNE YEAR IF NO INSPECT!CNS ARE PU FORPED, AND REGARDLESS CM SUPERVISCR.
APPRCVAL DATE CATE i
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- P-QP-2. 6 2
1AAY 1519g4 l
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PREPARED d
I fiE CERTIFICATION OF
/
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CSTS PERSONNEL APPROVED BY:
A
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f DATE' v'
-u C0% TROLL r
CONTROL No-
1.0 REFERENCES
1-A CP-Q P-19.6, "Suneillance of Cons truction and Startup/
Turnover Activities" 1-B CP-QP-2.1, " Training of Inspection Personnel" 1-C CP-Q P-2. 3,
" Documentation Within QA/QC Personnel Qualification File" M
2.0 GENERAL A
b / h 2.1 PLRPOSE l
2.__.
The purpose of this procedure is to establish the minimum requirements for training, qualification, and certification of personnel assigned to suneillance of construction and startup/ turnover activities in accordance with Reference 1-A.
3.0 PROCEDURE 3.1 EDUCATION AND EXPERIENCE Certification as a Surveillance Specialist requires:
)
a.
High school graduation plus six years experience in a technical field with at least two years experience in nuclear quality assurance; or:
b.
An associates degree fran an accredi ted institution in engineering, physical science, mathematics, or quality assurance wi th at least four years of experience, two of which must be nuclear quality j
assurance; or:
I c.
Bachelors degree from an accredi ted institution in engineering, physical
- sciences, mathematics, or quality assurance with at least two years experience in nuclear quality assurance.
)
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ISSUE PROCEDURE REVISION PAGE NUMBER DATE TEXAS UTIUTisS GENERATING CO.
mg 1. 5 ISB4 2 of 6 3.2 INDOCTRINATION Persons assigned to su rveillance of cons truction and startup/ turnover activities shall receive the following indoctrination as required by Reference 1-B:
QA/QC orientation
" Introduction to Nuclear Power Codes a.
and Standards," completion to be docunented by entry on.
b.
General knowledge of documents listed on Attachment 2 and a working knowledge of Reference 1-A Personnel shall also hava a working knowledge of the following documents as applicable to their area of surveillance:
1). Operations Administrative Control and QA Plan 2). Station Administration Manual l
~
3). TUGC0 Construction QA Procedures l
i 4). Startup QA Plan j
6). B&R'QA Manual 7). CPSES Section XI Program Manual Completion of required study is to be documented on 3.3 TRAINING After conpleting the indoctrination program, each trainee shall be required to participate in at least two site surveillance activites conducted by certified surveillance l
personnel.
- r 3.4 CERTIFICATION Upon completion of the training program, the trainee will be interviewed by the CSTS Supervisor or his designee to detennine.the individual's qualifications in the following areas:
a.
Surveillance planning
)
(
TUGCO OA
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PROCEDURE ISSUE REVISION PAGE NUM8ER DATE TEXAS UTIUTIES GENERATING CO.
MAY 15 W 3 of 6 b.
Checklist preparation c.
Perfonnance of surveillance activities d.
Follow-up and closeout of discrepancies If it is detensined the trainee is qualified, the QA Surveillance Certification (Attachment 3) wil.1 be signed by the CSTS Supervisor and approved by the TUGC0 Site QA Manager.
Certification will be for a period of one year.
3.5 DOCUMENTATION Records of training and certification (Attachments 1, 2 and 3) will be filed and maintained in accordance with Reference 1-C.
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REVISION PAGE NU MER TEXAS UTIUTIES GENE 4ATING CO.
enEE 2
MAY 15 M4 CP-QP-2.6 4 of 6 ATTACHMENT 1 TRAIN [NG RECORt*
CDP %M04 PEAK STEAM ELECTRIC $TATION DATE!
TM ueER$1GED ACMMM.EGE RECEIFT & SPECIALIZED TRAINING [N GIVEN SYr (INSTTtUCTOR) TNIS DATE, AT CDPWOE PEAK PEECT.
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'2 5 of 6 ATTACl# TENT 2 COMANCNE PEAK STEAM ELECTRIC STATION CENERAL TRAINING OUTLINE To sE COMPLETED sY:
160 Days After Employment)
NAME W'
t 1.
Final safety Analysis Report Chapter (s) 17, 2.
Title 10 Code of Federal Regulations Part 50, Appendix 5 and ANSI N45.2 3.
NaC angulatory Guides (As Assigned)*
4.
Industry Standards (As Assigned)*
e S.
QA/QC Procedures and Instructions (As Assigned)*
e e
o e
6.
Title 10 Code of Federal Regulations, Part 21 and 10CFRSO.$5E 7.
Other applicable documents as listed belows a
VERIFIED BY DATE OUTLINE APPROVED BY R. G. Tolson DATE
- NOTE: If Item *NOT APPLICABLE
- so State on outline.
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NUMSER REVISION ISSUE CATE PAGE CPSES 01-0P-2.6 2
gg4 6 of 6 ATTACHMENT 3 l
TE2AS UTILITIES GENERATING COMPANY QUALITY ASSURANCE DEPARTMENT QA $URVE!LLANCE CERTIFICATION NAM:
DATE TUGC0 PROCEDURE /INSTRUCITON NO:
TYPE OF EXAMINATION GIVEN:
ORAL nNI!TTEN PRACTICAL RESULTS OF E2 AMINATION (s) i CONENTS:
i 4
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This certification will empire on supervisor i
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REVISION PAGE TEXAS UTIUTIES GENERATING CO.
M ES
- P-QP-0.12 28 MAY 15 1584 1 of 2 Q
QA/0C NON-ASME PER(ONNEL TRAINING MANUM TABLE OF CONTENTS (
gg 00CUMENT EFFECTIVE NUMBER TITLE REVISION CP-Q P-2.0 IMPLEMENTATION OF THE CPSES QA PROGRAM 1
CP-QP-2.1 TRAINING OF INSPECTION PERSONNEL 15 QI-QP-2.1-1 QUALIFICATION OF CONCRETE INSPECTION AND TEST PERSONNEL 5
Q I-Q P-2.1-2
. QUALIFICATION OF SOILS INSPECTION AND TEST PERSONNEL 4
Q I-Q P-2.1-3 QUALIFICATION OF E'#ECTRICAL INSPECTION AND TEST PERSONNEL 8
QI-QP-2.1-4 QUALIFICATION OF PROTECTIVE COATING INSPECTION PERSONNEL 6
QI-QP-2.1-5 QUALIFICATION OF RECEIVING INSPECTION PERSONNEL 5
QI-QP-2.1-8 QUALIFICATION OF INSTRUMENTATION INSPECTION AND TEST PERSONNEL 8
QI-Q P-2.1-9 QUALIFICATION OF NON-A91E PIPE SUPPORT INSPECTION PERSONNEL 4
QI-QP-2.1-11 QUALIFICATION OF CONCRETE EXPANSION ANCHOR INSPECTION PERSONNEL 3
QI-QP-2.1-12 QUALIFICATION OF AS-BUILT PIPING VERIFICATION PERSONNEL 3
QI-QP-2.1-14 QUALIFICATION OF SEISMIC CONOUIT SUPPORT INSPECTION PERSONNEL 4
QI-QP-2.1-15 QUALIFICATION OF STRUCTURAL STEEL INSPECTION PERSONNEL 4
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TUCCO CA
f-ISSUE PROCEDURE REVISION PAGE NUMBER DATE TEXAS UTIL!YlES GENERATING CO.
CP-QP-0.12 28 gy i ;.554 2 of 2 EFFECTIVE DOCUMENT NUMBER TITLE REVISION QI-QP-2.1-16 QUALIFICATION OF DESIGN CHANGE VERIFICATION PERSONNEL 2
QI-Q P-2.1-18 QUALIFICATION OF FIRE PROTECTION 3
i PERSONNEL I
~
QI-QP-2.1-19 QUALIFICATION OF WELO INSPECTION PERSONNEL I
- QI-QP-2.1-21
- QUALIFICATION OF BASEPLATES FOR GROUTING VERIFICATION PERSONNEL 2
QI-QP-2.1-22 TRAINING AND CERTIFICATION OF RECEIVING 0
INSPECTION PERSONNEL FOR ASME SECTION XI ITEMS CP-QP-2.2 IN00CTRINATION OF RECORD VERIFICATION PERSONNEL 2
CP-QP-2.3 DOCUENTATION WITHIN QA/QC PERSONNEL VERIFICATION FILE 4
CP-QP-2.4 NONDESTRUCTIVE EXAMINATION PERSONNEL TRAINING QUALIFICATION, AND CERTIFICATION. 4 CP-QP-2.6 CERTIFICATION OF MONITORING PERSONNEL 2
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FOLDER NO.
a Draft No.
Date COMANCHE PEAK ALLEGATION WORK PACKAGE blaTes
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Q W P2+ r y ' Adherence to Procedures A11eqation Numbers: AQ-28, AQE-30, AQO-2, AQO3, AQO-ISc-4GCL-17, AQO-18, AQ0-19, AQO-20, AQO-23, A00-29c, /AQE-6, FQB-1, A0-52, AQ-61, AQ-78, AQ-79 U[
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l Statement of Allegation: Safety-related work activities were not conducted in l'
accordance with specifications, industry standards and QC/ construction procedures in the following areas: weld repair, coatings, automatic welding with Dimetrics j
machine, electric 1_l, Hilti bolt documentation, out of round pipe repair, valve maintenance, procurement orders to fab shop, inspection hold points, and general disregard for following procedures.
Reference Documents:
See source documents marked on attached pages from allegation list.
Source of Allegation: Various allegers - see allegation list Data Received: Various f
The above information prepared by H. S. Phillips 6/6/84 Name Date Group Leader Name Date Assigned Team Members Date Assigned Fate Assigned Date Assigned Date Assigned
}/
e
-e.
COMANCHE PEAK OPEN ISSUE ACTION PLAN Task:
Ref. No.: AQ-28, AQE-30, AQO '
003,'AQO-16, AQ0-17, AQO-18, AQO-19, AQO-20, AQO-23, AQO-29c, QE,
QB-1, AQ-52, AQ-61, AQ-78, AQ-79 Characterization:
- DVL, 1.
Craf t would satisfy a component.. dification card (CMC) on an inadequate weld by welding over it instead of cutting its defects out per procedure.
2.
Safety-related welds were repaired with weld tech (W.T.) holdpoints instead of QC holdpoints in violation of procedures.
3.
There are various technical and procedural problems in coatings QC dept.
at CPSES.
4 Coating dept. supervisors are not properly implementing QC procedures.
5.
The supervisor of the paint QC dept. gave verbal instructions to perform inspections at "an arm's length" instead of performing visual inspections (close to the paint surface) as required by QC procedures.
This inadequate inspection will cause inspectors to accept substandard coating work.
6.
The same supervisor in 5, above, forced QC inspectors to allow painting operations to continue even though it was not in accordance with procedures.
7.
Inspection acceptance / rejection criteria for inspecting "backfit coating" operations were vague.
8.
Numerous design change authorizations (DCA) have been issued to downgrade the surface preparation requirements from SP10 to SP6; 1.e., nuclear standard to heavy industry standard surface prepamation. Management allows SP6 requireme9ts to be downgraded by allowing DCA to be dispositioned "do the best you can" in areas where access is difficult. Note: NRC CAT team did an extensive review of OCA system.
9.
OCAs are also written to deviate from AS 31 specs. At least 40f. of the DCAs are nonconforming conditico.
- 10. There are problems regarding the calibraticn of the Dimetric automatic welding machines.
- 11. The CPSES coating program does not satisfy ANSI 1.014 requirements.
12.
A QC supervisor repeatedly told QC inspectors to violate inspection procedures; do not de in process inspection; OC buvinc nff ta* inattane
- hi+
'ra_not in accoryance with crecedures/ drawings.
13.
i,,rf Inspect on of Hilti bolt documentation packages may have been approved C"L;,
dese'.ce insoectors recognizing that the documentation package does not conform to CPSES procedures.
14.
Out of round pipe was heated and reformed with engineering authorization and/or procedures.
- 15. Valve maintenance (i.e. disassembly-reassembly) was not controlled and parts of different valves intermingled making material traceability invalid.
16.
Supervision advocates following proc.edures until "we get in a jam where something is holding up something and we want something welded immediately,..., then go ahead and weld it out of procedure."
- 17. There have been improper sign offs on " hold points" on travelers.
- 18. Craf t by passed procedures by telephoning orders to the fabrication shop in lieu of sending drawings.
1
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4 Initial Assessment of Significance: The disregard for following procedures concerning work activities described. in the previous paragr;aph pertain to i
work that is safety related. The degree of safety significance would depend on the system and location of weld for example inside or outside containment J
or primary coolant versus secondary piping, etc. The same would be true for coatings, terminations, Hilti bolt, pipe reforming, and unauthorized purchase a
i of materials. It appears that several of these items have potentially high
)
safety significance if procedures resulted in defective systems, parts, components, or materials.
Source: Various allegers. See allegation list.
r i
Approach to Resolution:
)
1.
Review background material referenced in the allegation list.
2.
Review project procedures index to determir.e applicable specifications and procedures.
1 3.
Review applicable procedures.
4.
Interview a sample of QC, engineering and construction personnel responsible i
for implementing the applicable procedures. Also coordinate with team member the task No. f_or AQW-10. 15 #._
i 5.
Examine the specific work activittes in progress (if possible) to determine j
if procedures are followed. Select one or two other areas to determine if procedures are routinely followed.
6.
Refer any examples of wrongdoing to the TRT manager.
7.
Evaluate the allegation for generic / safety implications.
+
j 8.
Report on results of review / evaluation of allegations.
i Related Open Issues t
i 1.
Using system codes,. pull open items, previous inspection findings, etc.,
from the tracking system open item list. (Region IV identify and add i
to this work package.)
1 2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional i
inspection while the inspector is familiar with the areas.
1 3.
While performing physical inspections above, examine surrounding systems, components, and structures for related apparent defects or indicators of faulty workmanship.
4.
If workmen are still in the area of a physical inspection, interview them L
for any knowledge of other potential deficiencies.
5.
Complete portion of IE Modules pertaining to welding, coatings, Hilti bolt,
. valve maintenance, misuse of DCAs versus use of NCRs, ~elacuical terminations, unauthorized purchases, and heating / reforming of piping.
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Support:
Estimated Resources:
Estimated Completion:
CLOSURE:
Reviewed by:
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QA/QC Category JE - Inadequate Inspection And Certification i
i Allegatian Numbers:. AfW-LS, ACW-16, ACW-17, A0W-18, A0W-19, A0W-27, ACE-7,
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i Statement of ' Allegation: Inadequate or improper certification of the i
j qualificatfons of QC personnel.
l Reference Documents:
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See source documents marked on attached pages from allegation list.
i Source of Allegation: Various 4
Date Received: Various 1
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AQW-15, AQW-16, AQW-17, AQW-18, AQW-19, AQW-27, [ AQE-lh Ref. No.:
AQB-2, AQ-38, AQ-39, AQ-50, AQO-7, AQO-14 Characterization: Inadequate and/or improper certification of the qualifications of QC personnel.
Initial Assessment of Stonificance: Possibly indicative of a general breakdown in the QA program.
Source: Various Approach to Resolution:
1.
Review procedures, codes / standards, design requirements, NRC requirements, and licensee commitments for adequacy at time work was performed; were codes / standards, FSAR, contractor requirements, and other commitments met?
2.
Discuss adequacy of procedures with personnel involved. Examine installation, as appropriate, that is associated with any inadequate procedures identified.
3.
Refer any examples of wrongdoing or significant deficiencies to TRT manager.
4 Evaluate allegations for generic / safety implications.
5.
Report on rest.its of review / evaluation of allegations.
Related Open Issues Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
2-Status:
Review lead:
Sucocrt:
Estimated Resources.:
Estimated comoletion:
CLOSURE:
Reviewed by:
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4A416 Category g-QC Inspector (or Supervisor) Qualification / Training
' Allegation Numbers: AQW-1, AQW-2, A0W-3. AQW-4, AQW-5, AQW-6, AQW-7, A0W-11, AQC-9, AQO-27 /AQE-8,) AQ-23, A0-24, AQ-26, AQ-27, AQ-28, AQ-29, AQ-63 V t
Statement of Allegation: Various concerns related to welding / training and general qualification / training program, including:
a.
.Irproper weld practices g.
Lack of QC training and unqualified b.
Nonqualified welders.
QC inspectors c.
Weld inspectors not qualified h.
Supervisory personnel not' qualified d.
Inexperienced personnei 1.
Electrical inspectors not qualified e.
Vendor welds inspected t'y j.
00L desposition of Dunham unqualified inspector k.
Recertification of inspectors with f
Training inadequate answers given i
i Reference-Coc'ments:
See source documents marked on attached pages rom allegation list.
Source of Allegation: Various - see enclosed allegations list Date Received: Various - 1979 - 84 The above information prepared by D. M. Hunnicutt 6/11/84 Name Date 4
Group Leader Name Date Assigned Team Members Date Assigned Oate Assigned Date Assigned i
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S' ';; :.. y.., 1-CR Activities Allegation Numbers: AQ-30, AQ-31, AQ-32, AQ-34, AQ-36, AD-37 AnO-8, A00-9, A00-10, A00-11, AQO-12, AQO-13 fA0E-1, AQE-4, AQ:- g AQp-1, A0H-2 Statement of Allecation: Various concerns involving Nonconformance Report (NCR) program including:
a.
Generation of NCR's b.
Disposition of NCR's c.
Voiding of NCR's d.
Use of inspection reports instead of NCR's Reference Documents:
See source documents marked on attached pages from allegation list.
~
Source of Allegation: Various - see allegations list Date Received: Various - 1980-1984 The above information prepared by R. Wessman/D. Hunnicutt 6/14/84 Name Date Group Leader Name Date Assigned Team Members Date Assigned Date Assigned Date Assigned Date Assigned j
W b
0 G 6NA ' OC COMANCHE PEAK OPEN ISSUE ACTION Pl.AN Task: Failure to complete, process, issue, void, and disposition NCR's.
- Also, allegation that inspection reports were used instead of NCR's.
Ref. No.
AQ-30, AQ-31, AQ-32, AQ-An-1E_ 16-17 AQO-8, AQO-9, AQO-10, AQO-11,AQO-12,AQO-13,A[41,AQE-4,AQE-QAQP-1,AQH-2 Characterization: Various corcerns involving NCR program, including:
a.
Generation of NCR's b.
Disposition of NCR's c.
Voiding of NCR's d.
Use of inspection reports instead of NCR's Initial Assessment of Sionificance: NCR's may not have been issued, when required or NCR's may nave been improperly dispositioned. This makes the validity of construction, inspections, or rework subject to question, Source: QA allegations; see allegations list Aeproach to Resolution:
1.
Review NCR procedures for adequacy. Review procedure changing NCR system to inspection report system.
2.
Examine a sample of NCR's and see if they conform to procedural requirements.
Sample should include craft areas, mentioned in all'egations and some areas outside those mentioned in allegations. ~
3.
Examine a sample of inspection reports and determine if inspection report items should have been NCR's.
4 Examine a sample of items reworked or actions taken in response to NCR's to conform disposition in accordance with NCR and procedural requirements.
5.
Interview sample of QC inspectors, supervisors, and craft personnel to ascertain implementation and knowledge of NCR procedures.
6.
Evaluate threshold for generating NCR's and placing them in system.
7.
Refer any examples of wrongdoing to TRT manager.
8.
Evaluate allegations for generic / safety implications.
9.
Report on results of review / evaluation of allegations.
Related Open Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
from the tracking system open item list. (Region IV identify and add to this work package.)
2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
3.
While performing physical inspections above, examine surrounding systems, components, and structures for related apparent defects or indicators of 1
faulty workmanship.
4.
If workmen are still in the area of a physical inspection, interview them for related knowledge of other potential deficiencies.
5.
Complete portion.of IE Module on QA/QC'Nonconformances.
ki i
4
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1/
COMANCHE PEAK OPEN ISSUE ACTION PLAN Task: Electrical 10 - QC Inspector Training /Qualificai: ion Ref. No.: AQE-8, parts of AQE-4 AQE-6, AQE-12 Characterization: Some electrical QC inspectors are inadequately.
qualified.
Initial Assessment of Significance: Question of whether the positions of RG 1.58, R1, and ANSI N42.4.5-1978 as augmented by the FSAR, Section 17.1.2 are being met.
Source: Various allegations Approach to Resolutions:
1.
Review all pertinent ' documentation (procedures, codes, standards, etc.)
2.
Discussed adequacy of procedures, etc.
3.
Review training / certification program 4
Review training / certification files 5.
Interviev QC personnel 6.
Evaluate review findings 7.
Report on results Related Open Issue Identification: None Status: Open Review Lead: Jose Calvo Support:
Estimated Resources:
10 man-days Estimated Completions: July 26, 1984 CLOSURE:
Reviewed by:
TRT Leader
~
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1 g ^,
C0hANCHE PEAK OPEN ISSUE ACTION R.AN Task: Determine if inspectors, welders, supervisors are qualified. Review procedures and training requirements.
Ref. No.: AQW-1, A
-3, AQW-4, AQW-5, AQW-6, AQW-7, AQW-11, AQC-9, AQO-27, Q-23, AQ-24, AQ-26, AQ-27, AQ-28, AQ-29, AQ-63 Ob Characterization:) Various concerns involving procedures, training of personnel and inspections by unqualified personnel, and welding and other practices.
Initial Assessment of Significance: Initial disposition in IR reports for several of these allegations. There appears to be enough specificity to warrant followup on these allegations. The allegation related to 00L (Department of Labor) on Dunham should be treated separately from the facility training, unqualified personnel, and other general allegations.
Source: QA/QC Category 12 - QC inspector (or supervisor) qualification / training Aoproach to Resolution:
1.
Review IR
-09, IR 79-20, IR 79-11, IR 79-15, IR 79-12, IR 83-52, IR 82-11, and R 81-04 o determine if documentation adequately supports findings.
- ehp, l.
If not, appropriate action to close allegation.
}0A'g*A Review training and OJT procedures, in question, for adequacy. Were 2.
~
training standards and/or FSAR commitments met?
)
3.
Discuss adequacy of procedures with persennel involved with welding and y7 training. Discuss adequacy of other OJT welding procedures. Examine weldments, as appropriate, that are associated with any inadequate procedures or training activities identified during interviews.
4.
Review sample of similar-type welding / training procedures for adequacy.
5.
Refer any examples of wrongdoing or significant deficiencies to TRT manager.
6.
Evaluate allegations for generic / safety implications.
7.
Report on results of review / evaluation of allegations.
8.
DOL on Dunham should be reviewed separately (contact TRT).
Related Ocen Issues 1.
Using system codes, pull open iteins, previous inspection findings, etc.,
from the tracking system open item list. \\(Region IV identify and add to this work package.)
2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
3.
While performing physical inspections above, examine surrounding systems, components, and structures for related apparent defects or indicators of faulty workmanship.
4.
If workmen are still in the area of a physical inspection, interview them for any knowledge of other potential deficiencies.
5.
Complete portion of IE Module on welding and/or training if it relates to effort made on allegations.
l i,
< Status:
Review Lead:
Succort:
Estimated Resources:
Estimated Comoletion:
CLOSURE:
Reviewed by:
e 9
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1 1 12. r 2 -i J
/
17 Finding - The SRIC wishes to acknowledge that the statements attributed to him by the alleger regarding a " Grandfather Clause" were substantially as made by the SRIC. The phrase "Grandfathtr Clause" is frequently applied in. situations where state or federal regulations regarding the certification or registration of individuals to perform certain functions are involved and these regulations are changed subsequent to a given individual's initial certification or registration.
A typical situation is that of registration as a professional engineer.
Some states have allowed persons meeting certain experience criteria to be registered when the regulation first becomes effective. Later, the state may require other factors, such as education, experience, and the passing of a written examination in order to become a professional engineer.
The earlier registration on experience alone, however, is not voided an'd remains in force.
In_.thet.spiciffWa~se-involved; BegDTEtoBCGUTd~e~T!580Rivffion 17b~ecame ' effective on September 1,'
ted conmitment' tot
- 1980Os3RCCguidanceJ 'Idell.icinsee~accep'disiit 15.of the FSAR.'
Revfstorliotthe:JeguTatory: Guide..inTAiEen MCApr.il:30T_198}] Prior to that date, the licensee was not 9
connitted to either the basic version of Regulatory Guide 1.58 or to Revision 1, although he had unofficially followed the basic version for several years. The basic version of Regula-tory Guide 1.58 endorsed N45.2.6 with very few qualifications and did not state that a high school or equivalent education was necessary. but rather only recommended it.
Revision 1 of Regulatory Guide 1.58 revised the NRC position on education such as to essentially require that all candidates for certification as QC inspectors under N45.2.6 have a high school education or a GED certificate. The key word is candidate since that is defined as "a person who seeks office, honor, or title, etc." by the SRIC's dictionary. Thus, any licensee or licensee agent employee certified as a QC inspector under N45.2.6 prior to April 30, 1981, would be an incumbent rather than a candidate and could retain his certification without necessarily having either a high l
school education or a GED certification and, thus, was considered
" Grandfathered." TheESRIC' has discussed this~ matter with senior -
Pers~cnnel of therQuality Assurance, Branch of the NRC Office of
]
JtuclearReactor Regulation who concurred that the SRIC's-interpretation.was correct.f 8.
Other Activities During the inspection period the SRIC also assisted and/or participated in a number or routine and special. inspections and investigations performed by Region IV inspectors and investigators.
The SRIC also participated in the hearings before an Atomic Safety and Licensing Board on the matter of TUGCO's application for an operating license for Comanche Peak Steam Electric Station.
3 /gr
~~
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PROCED RE REVISION PAGE TEXAS UTILITIES GENERATING CO.
CPSES CP-QP-0.1 216 JUL 101931 1 of 4 QUALITY PROCEDURES MANUAL
. TABLE OF CONTENTS CONTROLLED COPY QUAL m DOCUMENT nut 4BER TITLE CONTROL No. m. coa REVISION CP-QP-2.0 IMPLEMENTATION OF THE CPSES QA PROGRAM 1
CP-QP-2.1 TRAINING OF INSPECTION PERSONNEL 15 CP-QP-2.2 INDOCTRINATION OF RECORD VERIFICATION PERSONNEL 2
CP-QP-2.3 DOCUMENTATION WITHIN QA/QC PERSONNEL QUALIFICATION FILE 4
CP-QP-2.4 NONDESTRUCTIVE EXAMINATION PERSONNEL TRAINING, QUALIFICATION AND CERTIFICATION 4
CP-QP-2.S TESTING PERSONNEL TRAINING, QUALIFICATION AND CERTIFICATION 1
CP-QP-2.6 CERTIFICATION OF MONITORING PERSONNEL 2
4 CP-QP-3.0 CPSES SITE QUALITY ASSURANCE / QUALITY CONTROL ORGMIZATION 14 CP-QP-5.0 QUALITY ASSURANCE REVIEW OF SITE GENERATED PROCUREMENT DOCUMENTS 1
CP-QP-6.0 PREPARATION OF QUALITY PROCEDURES AND INSTRUCTIONS 5
CP-Q P-7.1 ISSUANCE AND CONTROL OF QUALITY PROCEDURES AND INSTRUCTIONS 8
CP-QP-8.0 RECEIVING INSPECTIONS 3
CP-QP-8.1 SUPPLIER EV4.UATION 1
CP-QP-11.0 CIVIL ItGPECTION ACTIVITIES 3
CP-QP-11.1 CONCRETE, SOILS AND REINFORCING STEEL TESTING ACTIVITIES
,1 POM-85-SC '
b/ J72 3
Tucco cA.
t PROCEDURE I
REVISION PAGE l
TEXAS UTILITIES GENERATING CO.
0m CP-QP-0.1 216 2 of 4 QUALITY DOCUMENT NUMBER TITLE REVISION CP-QP-11.2 SURVEILLANCE AND INSPECTION OF CONCRETE ANCHOR BOLT INSTALLATIONS 7
i CP-QP-11.3 ELECTRICAL INSPECTIONS ACTIVITIES 4
CP-QP-11.4 INSPECTION OF PROTECTIVE C0ATINGS 7
i CP-QP-11.5 GENERAL PROCEDURE FOR RANDOM INSPECTION 0
CP-QP-11.8 INSTRUMENTATION AND CONTROL INSPECTION ACTIVITIES 3
CP-QP-11.10 INSPECTION OF ELECTRICAL RACEWAY SUPPORT SYSTEMS 2
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CP-Q P-11.11 REINSPECTION OF CP DIESEL. GENERATOR AUXILIARY SKID AND SUPPORT BRACKETS 2
' INSP. OF INST. OF RADI0 ACTIVE WASTE MANAGEMENT SYSTEMS (RWMS) 15 CP-QP-11.13 AS-BUILT VERIFICATION 6
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CP-QP-11.14 STRUCTURAL STEEL INSPECTION ACTIVITIES 1
CP-QP-11.15 PERMANENT EQUIPMENT TRANSFER VERIFICATION 4
CP-QP-11.16 INSPECTION OF SEISMIC CATEGORY II SUPPORTS AND STRUCTURAL STEEL 1
CP-QP-11.17 ELECTELICM. STARRJP INSPECTION ACTIVITES 2
- NONDESTUCTIVE EXh11 NATION ACTIVITIES 1
CP-QP-11.20 INSPECTION OF FIRE PROTECTION 2
CP-Q P-11. 21 WELD INSPECTION 2
. CONTROL OF MEASURING AND TEST EQUIPMENT 2
CP-Q P-15.0 TAGGING SYSTEM 4
CP-QP-15.2 STARTUP/ TURNOVER QA ACTIVITIES 3
i TUGCO CA 3
l-PROCEDURE I
REVISION PAGE TEXAS UTILITIES GENERATING CO.
JUL 101984 CP-QP-0.1 216 3 of 4 QUALITY DOCUMENT NUMBER TITLE REVISION CP-QP-15.3 QUALITY ENGINEERING REVIEW OF STARTUP WORK PERMITS 2
CP-QP-15.4 DESIGN CHANGE VERIFICATION 6
CP-Q P-15.5 TRACKING OF NRC INSPECTION FINDINGS.
1 CP-QP-15.6 SDAR STATUS TRACKING 1
CP-QP-15.7 TRACKING OF AUDIT REPORTS / CORRECTIVE ACTION REPORTS 2
CP-QP-16.0 NONCONFORMANCES 14 CP-QP-16.1 SIGNIFICANT CONSTRUCTION DEFICIENCIES 5
CP-Q P-17.0 CORRECTIVE ACTION 4
CP-QP-18.0 INSPECTION REPORT 19 CP-QP-18.2 IMPLEMENTATION OF THE PERMANENT PLANT RECORDS MANAGEENT SYSTEM 3
CP-QP-18.3 PERMANENT PLANT RECORDS SYSTEM ORGANIZATION 2
CP-QP-18.4 PERMANENT PLANT RECORDS RECEIPT CONTROL AND STORAGE 2
CP-QP-18.5 AUTOMATED RECORDS MANAGEMENT SYSTEM IMPLEMENTATION 2'
CP-QP-18.6 RECORD TURNOVER TO TUGC0 OPERATIONS GROUP O
CP-QP-18.7 N-5 AND N-3 CODE DATA REP' ORTS 0
CP-QP-18.8 RECORDS VERIFICATION 1
CP-QP-19.0 AUDITS 2
CP-QP-19.3 SURVEILLANCE OF PIPING ERECTION O
CP-QP-19.4 TACK WELD SURVEILLANCE O
CP-QP-19.5 SURVEILLANCE OF PLANT CONDITIONS.
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PROCEDURE REVISION ISSUE PAGE TEXAS UTILITIES GENERATING CO.
CP-QP-0.1 216 JUL 101984 4g4 QUALITY DOCUMENT NUMBER TITLE REVISION CP-QP-19.6 MONITORING Of CONSTRUCTION AND INSTALLATION -
ACTIVITIES 6
CP-QP-19.7 MONITORING WELDING ACTIVITIES 1
CP-QP-20.0 SURVEILLANCE OF PRESERVICE INSPECTION 3
CP-QP-22.0 SURVEILLANCE OF THE CPSES CONTAINMENT 1 STRUCTURAL ACCEPTANCE TEST 2
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V COMANCHE PEAK STEAM ELECTRIC STATION QUALITY ASSURANCE DEPARTMENT QUALITY CONTROL RECERTIFICATION NAME:
DATE:
LEVEL OF CERTIFICATION:
ACTIVITY CERTIFIED TO PERFORM:
TUGCO PROCEDURE / INSTRUCTION NO. (S) :
MOTE:
SEE RECLASSIFICATION EVALUATION FORM.
COMMENTS:. BASED ON PREVIOUS CERTIFICATION IN THIS ACTIVITY, AND CONTINUED SATISFACTORY PERFORMANCE, THE ABOVE NAMED INDIVIDUAL ^IS HEREBY RECERTIFIED AND AUTHORIZED TO PERFORM ACTIVE QC INSPECTIONS AT CPSES IN THE AREAS LISTED ABOVE.
THIS RECERTIFICATION WILL EXPIRE ON SUPERVISOR APPROVAL DATE DATE O
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,',)a-M C2 COMANCHE PEAK STEAM ELECTRIC STATION RECERTIFICATION EVLAUATION RECORD TO:
DATE:
The certification on procedure for is due to expire on Please conduct and oral and or written / practical evaluation with the above named individual ( and document the results below).
This evaluation will help with determining whether or not recert-ification should occur.
1.
'.ias the individual been active in inspection in this area during the last 6 - 12 months.
YES NO (la)
If above answered "NO".and you desire individual recartified, additional training and or OJT should accompany this form
.back to training QE.
2.
Is individual knowledgable of current procedure requirement revelent to this area of inpsection?
YES NO (2a)
If 42 answered "NO" refer to (la) above.
COMMENTS:
INSPECTOR / TECHNICIAN DATE QC SUPERVISOR / LEAD DATE TRAINING QE/ DISCIPLINE QE DATE QE SUPERVISOR DATI
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Yl 10 Interviews of Electrical OC Suoervisors On. March'12, 1981, Individuals C and N...e individually interviewed.
Individual C stated his Supervisors allow him the independence and latitude to manage his Department as it should be.
Individual C stated he maintained a good relationship with Craft Supervisors however, his primary goal is to~ ensure that the Quality Control objectives at CPSES are achieved.
Both Individuals C and N stated they were totally independent from craft pressures and that they had never been pressured by their own Supervisors or production management to compromise Quality Control standards.
(Investigators Note: While conducting the foregoing facets of this investigation a possible noncompliance with CPSES procedures was identified, relating to NCRs, within the electrical QC Department.
Investigative findings concerning this matter are contained in this report.)
Allegation'No. 5 lectrical QC personnel are inadequately qualified; were helped to the Certification Tests and their experience requirements were pas
" pencil whipped."
i Investicative Findings On February 24, 1981, Individual A was interviewed.
Individual A stated.
that several persons working as QC inspectors in the area of f teemmseson were not qualified for their positions when they began working as QC inspectors.
These persons were identified as Individuals H, I and
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Individual A stated esummmmmmmy therefore the experience portion of their applications must have been " pencil whipped."
certain degree of experience.)(Falsified to Bacument them as having a Individual A related that Individual I has worked hard and would probably now be qualified, due to the experience level achieved.
hired as a QC inspector due to Individual's C being a close friend of Individual J's brother.
as electrical QC inspectors and also some electrical craftsman concurr in the aforementioned evaluations of Individuals H, I and J.
Interviews of Electri' cal QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals 0, E, F, and K wer ndividually interviewed.
Individual 0 identified Individuals and as being only marginaly qualified for their duties as QC inspectors.
Indi idual 0 stated that Individuals I and J seemed to make no effort to improve their ability and due to their having apparently gained the favor of their Supervisors (Individuals C and N) they can usually be G,. a..
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found sitting in the office talking.
Individuals E and F stated they felt all persons working as electrical QC inspectors are qualified for their iobs.
Individual G stated Individual H was qualified and works hard. Aividual G' related having never ' worked with Individuals I and J, but stated ammur-
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inspectors, whom he refused to identify, are " W Review of Former QC Insoectors On March 9, 1981 and March 11, 1981, Individuals L and M were individually interviewed.
Individual L stated that Individuals H and I were pretty good workers and are probably qualified in all phases of the inspections they perform.
Individual L stated Individual J, at best, was probably only marginaly qualified as a QC inspector and was a very poor performer.
Individual L stated that electrical QC Supervisors displayed an obvious favoritism towards Individuals H, I and J over other QC inspectors, which would probably account for th* Mnn less field work and spending more time around the office. M vidual M 3 ated a belief that all QC inspectors are qualified, but stated some (nor. iaentified) are "%."
Interview of B&R Electricians On March 9, 1981, Individals P and Q, B&R electr.icians, were indiv' dually interviewed.
Individual P stated that Individual J was not adequately qualified as a QC inspector.
Individual P related that on occasions Individual J would ask questions about work being inspected which would indicate a lack of knowledge regarding the field.
Individual P stated that Individuals H and I also do not appear adequately knowledgeable regarding ele ~ctrical QC work.
Individual P also identified Individual R as probably not being qualified and performing poorly.
Individual Q stated Individual J may not be qualified as a QC inspector and related details regarding occasions when Individual J did not understand simple aspects of work to be inspected.
Individual Q related no knowledge regarding Individuals H and I being qualified as electrical QC inspectors.
Review orbe&R OC Oualifications ano iraining necorus m On February 26, 1981 and March 12, 1981, CPSES requirements fur QC inspectors qualifications and the training records for Individuals H, I, J and R were reviewed.
It was determined that each met the required background qualifications and satisfactorily completed the required written and oral examinations and the required on-the-job training necessary for certi-fication as electrical QC inspectors.
It was noted that Individual J passed the certification exam for the inspection of electrical terminations with a score of 84 percentile, subsequent to the disqualification of two incorrectly answered questions.
Examination of other electrical terminations certification exams taken by other persons during a similar time frame disclosed the same questions had not been disqualified.
It was determined that Individual J would not have passed this certification exam had these questions not been deleted from the exam.
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12 Interview o C f&R Oualitv. Encina <>Em On March 12, 1981, Individuals 5 and T, B&R electrical Quality Engineers p were interviewed.
Each explained that 2 c--'#
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Individual S stated " --+i'i m inn am. w " -^" t : "'E, subsequent to which an oral exam is
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'nu m aual 5 stav t the QE, based on the results of the oral as the richt to adjust upward or downward, the score of the written examination.
i..u vivuoi S stated the certification can be denied solely on the results of the oral exam.
Indiv' dual 5 stated; WpzMhowever, that a person who displays a obvious understanding of the material p{cor f required for certification, but has not scored above the 80% required on g_ y,# p, the exam, is usually required to take the examination again.
Individual S V,
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gn~#j#' was no longer employed at CPSES; therefore no reason could be provide for the disqualification of questions on the written exam of Individual J.
Interviews of Individuals H, I and J On March 11-12, 1981, Individuals H, I and J were each separately interviewed by an NRC inspector (Electrical' Specialist) and NRC investigator in an effort to determine their respective qualifications.
The interviews indicated that each possessed an adequate degree of familiarity with the inspection procedures and techniques to perform the termination inspection requirements.
Individuals H, I and J also indicated that they freely exercise the prerogative of asking their Supervisors for the answers to any questions that they encountered during the performance of inspections, both technical and administrative.
These interviews determined that QC inspectors H, I and J were each qualified to conduct the QC inspections in the area of electrical cable termination inspections or instructed by site procedures. When specifically queried concerning the possiblity that Individual C had influenced Individual J's employment in the QC Department and influenced certification, Individual J related having no personal knowledge to support such allegations and stated no personal relationship existed with Individual C, aside from a professional one.
Interview of Electrierr uc SuoervisorQ On March 12, 1981, s C and N individually were interviewed.
When questioned concerning the qualifications of Individuals H, I and J, as electrical QC inspectors, Individuals C and N each stated they believed those individuals to be qualified.
Both stated a belie' that the training program for QC inspectors was sufficient, but each added that more training would be desirable.
Individual C stated that as an adjunct to the initial training program, new electrical QC inspectors are encouraged to always ask questions of either Supervisors or more experienced Electrical QC inspectors when they had questions concerning an area they were inspecting.
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Individual C stated that Individuals H, I and J, due to their inexperinece, had required more assistance of the Supervisors during recent months, which may have been misunderstood, by some, as favoritism or special attention. ' Lastly, Individual C stated he was a personal friend of Individual J's brother; however, this had in no way influenced Individual J's receiving a job within the electrical QC department.
Furthermore, Individual C stated that he had not been responsible for hiring Individual J nor had Individual J's brother been aware that Individual J was being transfered to the electrical QC Department.
Allegation No. 6 Electrical terminations were being made and " bought off" by some,
electrical QC personnel, in nonconformance with drawings.
Investigative Findings On February 24, 1981, Individual A was intervieve.d.
Individual A stated he believed electrical terminations have been " bought off" (approved by inspectors) which are in nonconformance with drawings.
Individual A stated this situation is specifically attributable to some electrical QC inspectors being unquallfied for their job, rather than any intentional wrongdoing.
Individual A provided two examples of nonconforming con-ditions which were approved by electrical QC inspectors (Individuals I and J).
Individual A was unable to provide any additional information pertinent to the identification of nonconformances which have been approved by electrical QC inspectors.
Insoection of Alleged Nonconforming Conditions On February 25, 1981, an inspection of the alleged nonconforming conditions, approved by Individual J, was conducted.
The inspection disclosed that no nonconformances existed in the alleged component, at this time.
On February - 26, 1981, a review of the documentation. relating to the allegedly nonconforming conditions approved by Individual I was conducted.
The review disclosed the work associated with this inspection required only a visual inspection after the work was completed.
The documentation for this work indicated that Individual I had visually observed and approved the work and additionally the work was also independently approved by one other electrical QC inspector at another time.
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8 FOREWORD (17 sis Forewordis not a part of the American NationalStandard on Qualification ofInspection, Examination, and Testing Personnelfor Nucle.:r Power Plants.)
This Standard delineates the qualifications required of personnel who perform inspections, examinations, and tests that assure the quality ofimportant parts of nuclear power plants prior to and during the con..
struction, pre. operational, and startup testing and operating phases.The Standard was originally developed by the American National Standards Committee N45 on Reactor Plants and Their Maintenance.
In May of 1969, the'll45 Committee of ANSI established an ad hoc committee (N45-2.6) on Qualifica-tion of Personnel.The purpose of this committee was to prepaie a standard for general industry use that would define the qualifications of personnel whose activities result in or assure attainment of quality con-struction. The ad hoc committee was composed of representatives of key segments of the nuclear industry including utilities, reactor suppliers, construction contractors, component manufacturers, and consultants.
The orismal version of the Standard was issued in 1973 as ANSI N45.2.6-1973.
In August,1973, the U.S. Atomic Energy Commission issued Regulatory Guide 1.53-Qualificatien of Nuclear Power Plant laspection, Examination, and Testing Personnel. The regulatory position in this guide was that ANSI N45.2.6-1973 should be extended in scope to include pre-operational and startup testing and the operational phase of a nuclear power plant.
Accordingly, the N45-2.6 Work Group met to revise the Standard to satisfy Regulatory Guide 1.58 and to make other improvements in the Standard, especially with regard to education and experience considera-tions. The Standard contained herein was developed from these activities.
In 1975, the N45-2 Subcommittee was reorganized into the ASME Committee on Nuclear Quality Assur-ance and began operating under the accredited ASME Procedures for Nuclear Projects which received ac-creditation on January 15,1976. The ASME Committee on Nuc! car Quality Assurance was chartered to develop the overall nuclear quality assurance codes and standards for nuclear power plant design, construe-tion, and operation.
. Suggestions for improvement gained in the use of this Standard will be welcomed.They should be sent to the Secretary, Committee on Nuclear Quality Assurance, American Society of Mechanical Engineers, United Engineering Center,345 East 47th Street, New York, NY 10017.
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Work Group on N45-2.6 (The N43-2.6 Work Group Included the following personnel during the development of
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- 8. W. Maryworio, Chairman, Consumer Power Company, Jackson, Mississippi L. M Duff, General Doctric Company, San Jose, California E S Geffney, Babcock & Wilcos Company, Barberton, Ohio W. F. Griffith, Stone & Webster Engineering Corporation, Boston, Massachusetts 1 E Kennedy, Peabody Testing Company, Foster City, California A E Sece, Florida Power & Light Company Miami, Florida D. L. Vendemot, Bechtel Power Corporation, San Francisco, California
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ANSI /ASME N45.2.6 1978 AMERICAN NATIONAL. STANDARD OUALIFICATIONS OF INSPECTION, EXAMINATION AND TESTING PERSONNEL FOR NUCLEAR POWER PLANTS
- 1. INTRODUCTION His Standard is to be used in conjunction with ANSI N45.2.
1.1Property "ANSI code" (as page type) with input value "ANSI N45.2.</br></br>1.1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Scope e requirements apply to personnel of 'the his Standard delineates the requirements for the owners, architect. engineers, nuclear power plant sys-qualification of personnel who perform inspectica, tem designers and system suppliers, plant designers examination, and testing to verify cenformance t and plant constructors, equipment suppliers, outside specified requirements of nuclear power plant items test ng agencies, and consultants, ne ASME Boiler (structures, systems, and components of nuclear and Pressure Vessel Code, as well as other ANSI Stan-power plants) whose satisfactory performance is re-
. dards, have been considered in the development of quired to prevent postulated accidents which could the Standard, and this Standard is intended to be cause undue risk to the health and safety of the pub-c ble wis M #mts.
lic; or to mitipts the consequences of such accidents if they were to occur.De requirements may also be extended to other items of nuclear power plants when specified in contract documents.
1.3 Responsibility O
It is the responsibility of each organization par.
1.2-Appliesbelity tici ating in the project to assure that only those per-P De requuements of this Standard apply to person.
sonnel within their respective organizations who meet nel who perform inspections, exammations, and tests the requirements of this Standard are permitted to during fabrication prior to and during receipt ofitems perform inspection, examination, and testing activities at the ww.wtion site, during const:uction, during covered by this Standard that verify conformance to preoperational and startup testing, and during opera-quahty requirernents.
tional phases of nuclear power plants. The require-ments of this Standard do not apply to personnelwho De organization or orpaizations responsible for perform inspections for government or ~91 establishing the applicable requirements for activities authorities, or who perform as authorized inspectors covered by this Standard shall be identified and the.
in accordance with the ASME Boiler and Pressure scope of their responsibility shall be documented.
Vessel Code.
The work of establishing selection and training prac-tices and qualification procedures and of providing The requirements of this Standard are notintended the resources in terms of personnel, equipment, and
'l to apply to personnel who only perform inspection, exammation, or testang in accordance with ASNT services necessary to implement the requirements of
" Recommended Practice No. SNT-TC-1A", since this Standard, may be delegated to other qualified or-these personnel are certified in accordance with the genizations and such delegations shall also be docu.
mented, it is the responsibility of each organization requirements of SNT-TC-1 A and its applicable supple, u8i88 personnel covered by this Standard to conform ments. The requirements of this Standard are op-tional, at the discretion of the employer, for applica-
'to the requirements of this Standard applicable to the -
e organization's work.
tion to personnel who perform calibrationor to crafts, men who perform installation checkouts as part of it is the responsibility of the organization perform-their basic instaBation responsibility to ready the ing these activities to specify the detailed methods installation for preoperational resting.
and procedures for meeting the requirements of this O.
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QUALIFICATIONS OF INSPECTION, EXAMINATION AND TESTING PERSONNEL FOR NUCLEAR POWER PLANTS ANSI /ASME N45.2.6-1978 0
(7) results'ofphysicalexaminations,whenrequired nations, and tests;in supervising and certifying lower (S) signature of employer's designated represen.
level personnel;in reporting inspection. examination, tative L id testing results; and in evaluating the validity and acceptability of inspection, examination, and test (9) date of certification and date of certification nsults.
expiration 2.5 Physical 3.4 Level ll1 Personnel Capabilities he responsible organization shall identify any A level 111 person shall have all of the capabilities special physical characteristics needed in the perfor-of a level 11 person for the inspection, examination mance of each activity. Personnel requiring these or test category or class in question. In addition, the characteristics shall have them verified by examina-individual shall also be capable of evaluating the tion at intervals not to exceed one year.
adequacy of specific programs used to train and test inspection, examination, and test personnel whose
- 3. QUALIFICATIONS qualifications are covered by this Standard.
3.1 Ge ral 3.5 Education and b~rience-bcommendations he requirements contained within this Section define the minimum capabilities that qualify person.
De following is the recommended personnel nel to perform inspections, examinations, and tests education and experience for each ievel.nese educa-which are within the scope of this Standard.
tion and experience recommendations should be Bere are three levels of qualification.De require-treated to recognize that other factors may provide ments for each level are not limiting with regard to reasonable assurance that a person can competently organizational position of professional status, but perform a particular task. Other factors which may rather, are limiting with regard to functional activities demonstrate capability in a given job are previous per-which are within the scope of this Standard, f nuance w sausfactory completion of capability testing.
3.2 Level 1 Personnel Capabilities 3.5.1 Level i A level I person shall be capable of performing (1) Two years of related experience in equivalent the inspections, examinations, and tests that are re-faspection, examination, or testing activities, or quired to be performed in accordance with docu.
mented procedures and/or industry practices.Le in-(2) High school graduation and six months of dividual shall be familiar with the tools and equipment related experience in equivalent inspection, examina.
to be employed and shall have demonstrated profi-don, a tesung ames, a ciency in their use. He individual shall also be capable (3) Completion of college level work leading to an of determining that the calibration status ofinspection Associate Degree in a related discipline plus three and measuring equipment is current, that the measur.
months of related experience in equivalentinspection, ing and test equipment is in proper condition for use, examination, or testing activities, and that the inspection, examination, and test proce-3.5.2 Level 11 um am *pproici (1) One year of satisfactory performance as level 3.3 Level 11 Personnel Capabilities I in the corresponding inspection, examination or test category or class,or A Level 11 person shall have all of the capabilities of a level I person for the inspection, examination or (2) High school graduation plus three years of test category or class in question. Additionally, a related experience in equivalent inspection, examina-level Il person shall have demonstrated capabilities in tion, or testing activities, or planning inspec.lons, examinations, and tests;in set-(3) Completion of college level work leading to an ting up tests including preparation and set-up of Associate Degree in a related discipline plus one year related equipment, as appropriate;in supervising or related experience in equivalent inspection, examina-maintaining surveillance over the inspections, exami-tion, or testing activities, or 3
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QUALIFICATIONS OF INSPECTION, EXAMINATION AND TESTING PERSONNEL FOR NUCLEAR POWER PLANTS ANSI /ASME N45.2.0-1978 O
Table 1 Minimum Levels of Capability for Project Functions Level L,,
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L]jj Project Function Recording inspection, examination, and testing ev X
X X
Imple r;enting inspection, examination, and testing prth:edures X
X X
Planning inspections, evelwations, and tests; setting up tests including preparation and setw of reisted equipment X
X Evaluating the validity and acceptability of inspec.
tion, examination, and testing results X
X Reporting inspection, examination, and testing results X
X Supervising equivoient or lower fewel personnel X
X Qualifying louvor level personnel X
X Evoluedng the adequecy of specific programs used to train and test inspection, examination and testing personnel X
Ouelifying same level personnet X
- Escept es exempted by Section 4 s,f this Standard.
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