ML20136F600
| ML20136F600 | |
| Person / Time | |
|---|---|
| Issue date: | 11/29/1985 |
| From: | Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20136F549 | List: |
| References | |
| REF-QA-99901033 99901033-85-01, 99901033-85-1, NUDOCS 8601070437 | |
| Download: ML20136F600 (8) | |
Text
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. ORGANIZATION: POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA REPORT INSPECTION INSPECTION NO.:
99901033/85-01 DATE(Sh 10/15-17/85 ON-SITE HOURS: 40 CORRESPONDENCE ADDRESS: Power Inspection, Inc.
Post Office Box 216 12330 Perry Highway Wexford, Pennsylvania 15090 ORGANIZATIONAL CONTACT: Kris Kumar, President TF1 FPWnNF N!!MRFR-(417) Q"49 7111 PRINCIPAL PRODUCT: Nondestructive Examination Services NUCLEAR INDUSTRY ACTIVITY: Eddy Current testing constituted approximately 10% of 1984 sales.
ASSIGNED INSPECTOR:
M
// 2 1 8 5 T. Conway, Rea ive Inspection Section (RIS)
Date OTHER INSPECTOR (S):
E. Yachimiak, Jr. (RIS)
. [J\\A1)L _ hk
//-if-6'.C APPROVED BY:
E' W. Meirschoff, ief,'RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50 and 10 CFR Part 21.
B.
SCOPE: This inspection was made as a result of the receipt of an allegation pertaining to certification documents for the calibration of eddy current testing equipment.
PLANT SITE APPLICABILITY:
Palisades (50-255) and Beaver Valley 1(50-334).
86010/o437 esim Nol$$f NEI
ORGANIZATION:
POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA
. REPORT INSPECTION NO.: 99901033/85-01 RF.SULTS:
PAGE 2 of 7 A.
VIOLATION:
1.
Contrary to Sections 21.6 and 21.21 of 10 CFR Part 21:
a.
Copies of 10 CFR Part 21 and Section 206 of the Energy Reorganization Act were not posted (85-01-01).
b.
Appropriate procedures to evaluate deviations or inform the licensee or purchaser of the deviation did not exist (85-01-02).
B.
NONCONFORMANCES:
1.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Procedure No. PI-A-04, it was noted that eddy current testing equipment and calibration services were obtained from Zetec in 1984 and 1985, but procurement documents were not prepared, processed and approved for the purchase of these items (85-01-03).
2.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 5.4 of Procedure No. PI-A-IV, there was no documented evidence that Power Inspection (PI) had indoctrinated and trained any personnel since the company was incorporated in 1982 (85-01-04).
3.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 5.6 of Procedure No. PI-A-04 and Section 5.3.1 of Procedure No. PI-A-12, it was noted that Zetec, a supplier of eddy current testing (ET) equipment and calibration services, was never surveyed or audited by PI; and internal audits of the QA Program have never been performed by PI (85-01-05).
4.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Procedure No. PI-A-06, it was no'ted that eddy current instruments (2), magnetic tape recorders (2), strip chart recorders (4),
vector analyzer (1), and M-17 mixers (2) were never calibrated in 1985; and a Master Index of M&TE (Form No. 2026) and M&TE Data Sheeti (Form No. 2027) did not exist for any of the items requiring calibration (85-01-06).
5.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 6.0 of Procedure No. PI-A-07, and SNT-TC-1A, a review of NDE records for one-Level III, three-Level II, and five-Level I examiners revealed (85-01-07):
ORGANIZATION:
POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA REPORT INSPECTION NO.: 99901033/85-01 RESULTS:
PAGE 3 of 7 a.
The records for all nine examiners did not contain a statement showing completion of training in accordance with PI Procedure No. PI-A-07.
b.
There was no eye examination for 1982, and it was overdue for 1985 for the Level III. One Level II was missing eye examinations for 1984 and 1985, and a 1985 examination was overdue for another Level II.
c.
Copies of examinations given in 1983 for the Level III and in 1985 for one Level II were missing.
6.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 9.7.3 of SNT-TC-1A, it was noted that PI Procedure No. PI-A-07
" Certification of NDT Personnel" did not address the area of duration of interrupted services requiring re-examination and re-certification (85-01-08).
C.
OPEN ITEMS:
None.
D.
OTHER FINDINGS OR COMMENTS:
1.
Persons Contacted
- K. Kumar, President
- J. Lint, Vice President
- F. Lovate, QA Manager
- denotes those attending the exit interview.
2.
Allegation In September 1985, the NRC Regio'n V office received a phone call alleging that PI was using ET equipment whicn had not been properly calibrated.
The inspector reviewed Procedure No. PI-A-06 " Control of Measuring and Test Equipment" dated December 1, 1981 which deser,thed the calibration and certification system for M&TE used t e )
9rsonnel.
It was noted that the individual (s) who prepared, rt>(
,and approved the procedure was not identified on the titYe*,m,e.
ORGANIZATION:
POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA REPORT INSPECTION NO.:
99901033/85-01 RESULTS:
PAGE 4 of 7 Calibration records for two eddy current instruments, two magnetic tape recorders, four strip chart records, one vector analyzer and two M-17 mixers used on testing for Duquesne Light Company (DLC) in 1984 and 1985 and Consumer Power Company (CPC) in 1982, 1983, and 1984 were reviewed. The testing equipment (identified by S/N) consisted of oscilloscopes (B012079 and B118167), detector amps (072, 073, 224, and 234), frequency drivers (040 and 082),
magnetic tape recorders (011 and 016), strip chart recorders (11557, 13643, 15395, and 19321), vector analyzer (009), and M-17 mixers (016 and 055).
The equipment was used on ET of control room air conditioning condensers, component cooling water heat exchangers in the reactor and turbine plants, and other heat exchangers (diesel generator, recirculation spray, and blowdown) at Beaver Valley Unit No.1, and steam generators and a main condenser at Palisades.
It was noted that a Master Index of M&TE (Form No. 2026) did not exist at Pl.
In addition, an M&TE Data Sheet (Form No. 2027) for each item of the test equipment requiring calibration was nonexistent (see Nonconformance B.4).
The NRC inspector was told by the President of PI that the purchase or lease of ET equipment from Zetec as well as calibration services performed by Zetec were handled on a verbal basis, and P0s were not generated (see Nonconformance 85-01-03).
The only documentation at PI to verify that a particular item was calibrated is a certification and invoice from Zetec for the services performed. A review of the invoice file and a June 19, 1985 letter from Zetec to PI which listed the outstanding invoices indicated that Zetec had calibrated three strip chart records (S/N 19321, 13643, and 11557) in October 1984. A magnetic tape recorder (S/N 011) was calibrated in January 1985 (Invoice No.
14009 dated February 4, 1985). ' Calibration certifications were also in the files to confirm the above calibrations.
A further review of calibration certifications indicated that a magnetic tape recorder (S/N 016); detector amps (S/N 072, 073, 224, and 234), and a magnetic tape recorder (S/N 011); and a M-17 mixer (S/N 055) were calibrated in February, June, and July 1984 respectively.
However, there were no Zetec invoices in the files for the above items.
^
ORGANIZATION:
POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA REPORT INSPECTION N0.: 99901033/85-01 RESULTS:
PAGE 5 of 7
=
There was no documentation to show that frequency drivers (S/N 040 and 082), oscilloscopes (S/N B012079 and B118167), a M-17 mixer (S/N 016), and a vector analyzer (S/N 009) were ever calibrated; or the other items noted above, with the exception of the magnetic tape recorder (S/N 011) were calibrated in 1985.
Based on the inspector's review and evaluation of the QA records pertaining to the calibration of M&TE, the inspector substantiated the allegation.
3.
NDE The NRC inspector reviewed the qualification and certification records of NDE personnel (one-Level III, three-Level II, and five-Level I) to determine whether the individuals performing ET were certified to SNT-TC-1A.
The written practice of PI for all phases of certifying NDE personnel was also reviewed. The title page of Procedure No. PI-A-07 " Certification of NDT Personnel" was dated December 1, 1981, but there were no initials or signatures to indicate who prepared, reviewed and approved the document. With the exception of failing to address the area of interrupted service vs.
re-examination /re-certification, the procedure appeared to be consistent with SNT-TC-1A (see Nonconformance 85-01-08).
The 10 DLC P0s(eight in '84 and two in '85) to PI required NDE personnel to be certified to SNT-TC-1A (June 1975 Edition).
Section 14 of CPC Contract No. NDT-82-01 " Consulting and Nondestructive Testing Services with Power Inspection, Inc." dated March 25, 1982 required that SNT-TC-1A be the recommended practice for PI's written practice. CPC's nine P0s(three in '82, four in '83, and two in '84) to PI referenced Contract No. NDT-82-01.
Records for the Level III included a Personnel Certification Summary (PCS) document dated September 3, 1981.
The PCS gave test scores, educational and exp'erience background and was signed by a Level III examiner, but it did not contain a specific certification statement (e.g., to SNT-TC-1A).
In addition, there were no records in the files to verify the certification of the Level III examiner.
Copies of the general, specific, and practical examinations were all dated September 2, 1981.
It was noted that the general examination with a score of 92 percent was an identical copy (with the exception of name, date, location, and instructor in the information block) to copies of a general examination in the file of two Level IIs
1 ORGANIZATION:
POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA REPORT INSPECTION N0.: 99901033/85-01 RESULTS:
PAGE 6 of 7 (Polaski and McGregor). A copy of page one of the general examination with spaces for "name, date, location, and instructor" in the information block whited out was also in the file.
A March 31, 1583 letter from a Level III consultant to the President of PI stated that PI's Level III successfully completed his written examination and was certified to Level III-ET.
However, copies of the three examinations, as well as scores, were missing, and there was no documentation on the certification of the Level III consultant.
The eye examination for 1982 was missing and the examination for 1985 was overdue by two months.
A PCS dated January 3, 1983 for Level II (Polaski) was signed by a Level III examiner, but there was no documentation attesting to the certification of the Level III examiner.
Four PCSs dated in January and May 1983 and March 1984 and 1985 did not indicate to what requirements the individual was certified. The " discrepant" general examination was dated October 12, 1981 with a score of 92 percent.
Four PCSs dated December 1982, May 1983, and March 1984 and 1985 for Level II (McGregor) did not contain a specific certification statement. The eye examination for 1985 was overdue by four months.
The " discrepant" general examination was dated October 12, 1981 with a score of 89 percent.
A PCS dated October 15, 1985 for Level II (Williams) did not contain a certification statement, and there were no copies of any examinations.
Eye examinations for 1984 and 1985 were also missing.
For all five Level I examiners, copies of examinations were missing and the PCSs did not contain a certification statement.
For one examiner (Griter), there were no eye examinations.
Nonconformance 85-01-07 was identified in this area of the inspection.
4.
Reporting of Defects The 10 P0s from DLC and the nine 90s from CPC imposed the require-ments of 10 CFR Part 21 upon PI for the ET testing at Beaver Valley Unit No. I and Palisades.
It was noted that PI failed to have a procedure for reporting defects and deviations; and failed to post the appropriate documents as required by 10 CFR Part 21 (see Violations 85-01-01 and 85-01-02).
ORGANIZATION:
POWER INSPECTION, INC.
WEXFORD, PENNSYLVANIA REPORT INSPECTION N0.: 99901033/85-01 RESULTS:
PAGE 7 of 7 5.
QA Program Although Section 5.4 of Procedure No. PI-A-IV " Quality Assurance Program-Administrative Policy" required that personnel performing activities affecting quality be indoctrinated and trained via group lectures or personal instructions with subsequent record of attendance being maintained, there was no documented evidence that any employee had been trained and indoctrinated (see Nonconformance 85-01-04).
Procedure No. PI-A-12 " Audits" requires that audits of QA activities be conducted by PI personnel to ensure compliance to QA program requirements. There was no documented evidence that audits had ever been corducted of the specific elements in PI's QA program.
In addition, external audits of vendors supplying equipment and calibration services were never conducted.
Nonconformance 85-01-05 was identified in this area of the inspection.
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