ML20148G611
| ML20148G611 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/02/1987 |
| From: | Beck J, Young J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20148G457 | List: |
| References | |
| RTR-NUREG-0797, RTR-NUREG-797 NUDOCS 8801260554 | |
| Download: ML20148G611 (138) | |
Text
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lO COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAPt I.d.1 Title QC Inspector Qualifications REVISION 1 O
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IssusAoordinatorf Dare /
R Tesa 14adar '
/2/.// D Y7 Date AoA Jop.Seck,ChairmanCPRT-SRT
/24/s v Date O
8801250554 880118 PDR ADOCK 050 5
l Rovision: L Pego 1 of 138 RISULTS RZPORT ISAP 1.d.1 QC Inspector Qualifications
1.0 DESCRIPTION
Page J 110) OF ISSUE IDENTIFIED BY NRC (NUREG 0797, Supplement 7, No.
"The TRT examined electrical QC inspector training and certification files, and requirements for personnel testing, on the job trair.ing, and racertification.
QA/QC personnel. The TRT also interviewed selected electrical The TRT found a lack of supportive documentation regarding personnel qualifications in the training and certification files, as required bY procedures and regulatory requirements. Also, the TRT found a laci. of documentation for assuring that the requirements for electrical QC inspection recortification were being met. 3pecific examples are:
One case of no documentation of a high school diploma or General Equivales.cy Diploma.
one case of no documentation to waive the remaining 2 months of the required 1 year experience.
One case where a QC technician had not passed the require d color vision examination administered by a professional eye specialist.
O A makeup test using colored pencils was administered by a.QC supervisor, was passed, and then a waiver was given.
Two cases where the experience requirements to become a Level I technician were only margically met.
One case of no documentation in the training and certification files substantiating that the person met the experience requirement."
2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement No. 7, Page J 111)
"Accordingly, TURC shall review all the Electrical QC inspector training, qualification, certification and re certification files against the project requirements and provide the information in such a form inspector.that each requirement is clearly shown to have been met by each If an inspector is found to not meet the training, qualification, certification or re certification requirements. TUIC shall then review the records to decernine the adequacy of inspections nada by the unqualifiwd individuals and provide a statement of the impact of the deficiencies.,noted on the safety of the project."
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Revision: 1 RESULTS REPORT Pa5* 2 of 138
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ISAP 1.d.1 ,
(Cont'd) v 3.0 SACKGROUND
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Prior to 1978, Brown & Root,
, as part of their overall responsibility as constructor, r,2intained a QC inspector certification program covering both ASME and non ASME site inspection activities. TU
, Electric QA initially established a QC inspector certification progras t in 1978, when TU Electric assumed responsibility for the non ASME QA program.
1 Brown & Poot retained responsibility for the ASME QA program
{ and maintained their own separate QC inspector certification program to support the ASME QA program.
Since its inception in May 1978, the TU Electric QC inspector certification program had been based on certifying personnel in a r given inspection function / activity as delineated in a specific
?
instruction discipiire. rather than a general certification of an individual in a The TV Electric approach was consistent with the practice of some other asabers of the nuclear industry. The more coanon opproach in the certifications fornuclear inspectors. industry is to issus general discipline If properly implemented, the TU Elcetric approach was conservative in that it required additional training and examinations beyond what is normally required by programs in which general discipline certifications are issued. However, because of the increased number of certifications and attendant certification requirements, the TU Electric approach was more difficult to administer than the alternate approach. Both approaches sre acceptable if effectively implemented.
a Since 1978, the Brown & Root QC inspector certification program, which certifies personnel by discipline rather than inspection function / activity, has been significantly less complex than the TU Electric certification program. ?
certification, and qualification of inspection personnel wereIn 1978, requirements 1 c atained in the Brown & Root Quality Assurance Department "Quality Assurance Personnel Training Manual". Although this manual contained requirements for the certification of a wide range of inspection disciplines, since May 1978 the mam.a1 was used only to certify nochanical inspection personnel and nandestructive examination (NDE) persornel in the areas of visual examination (VT), radiographic +
examination (RT), ultrasonic examination (UT), magnetic particle examination (Iff), liquid penetrant examination (PT), and leak detection (LT). The mechanical inspection certification under this '
manual was generally based on ANSI N45.2.6, "Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants," guidelines.
The NDE certifications addressed the requirements of the Amerie4n Sociaty'for Nondestructive Testing's "Recommended Practice for Personnel Qualification and Certification",
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Revision: 1 Pago 3 of 138 ISAP I.d.1 (Cont'd)
O, 3.0 BACRCROUND (Cont'd)
SNT-TC 1A, as modified by ASME Code requirements. In February 1981, the Brown & Root "Quality Assurance Personnel Training Manual" was replaced by the following threc procedures:
CP-QAP 2.1, "Personnel Training and Qualification *,
QI-QAP 2.1 1, "Nondestructive Examination Personnel Certification",
QI-QAP 2.1-3, "Training and Certification of Mechanical Inspection Personnel".
On January 30, 1981, Amendment # 14 to the FSAR consit: Ad TU Iloctric and Brown & Root to the requirements of Regulatory Guide 1.58 Revision 1, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel".
This Regulatory Guide invokes, the requirements of ANS1 N45.2.6 - 1978 (as modified by the Regulatory Guide) and Slff TC 1A as modified by the ASME Code.
j A detailed description of the TF Electric QC inspector certification s
procedures is contained in the Results Report for ISAF I.d.2, "Cuidelines for Administration of QC Inspector Test".
]
Ths NRC TRT concerns, described above in Sections 1.0 and 2.0, focused on TU Electric electrical QC inspectorn. In addition to the I
electrical QC inspectors, a decision was made to evaluate all TU Flectric and Brown & Root QC inspectors employed onsite as of March 1985, as mart of the ISAP I.d.1 evaluation. This decision was based on the following considerations:
By reviewing all TU Electric electrical QC inspectors, including those inspectors who had left the jobsite prior to March 1985, a significant amount of information regarding the adequacy of the
' overall historical Comanche Peak QC inspector certification progrse would be developed.
Review of all current QC inspectors would determins if the current TU Electric and Brown & Root QC inspector certification programs were adequately implemented or, if required, would enabis . appropriate correctiva action to be identified.
Subsequent to this decision, ISAP VII.c, "Construction Reinspeeiton/ Documentation. Review Plan," came into existance. Bscause documentation review is an'isportant component of the VII.c evaluation and because the majority of the documentation evaluated is QC O
l Revision: 1 Page 4 of 138 REST. s REPORT j ISAP 1.d.1 (Cont'd) 3.0 BACKCAOUND (Cont'd) inspectionwere inspectors documentation, reviewed. certifications of the associated QC
- Inspectors whose certifications were l
- identified Reports. as questionable or inadequate were documented on Deviation 1 These Deviation Reports were reviewed by QA/QC Review Team personnel who participated in the implementation of ISAP I.d.1, and )
che inspectors received a I.d.1 typa evaluation that included Phase III re'.nspections as required.
- *A later decision was made to conduct !
j a I.d.1 type evaluation of inspectors identified during the ISAP VII.c 4 documentation review process, whether or not their certifications were identified as questionable. ;
j This decision was made because of i
! procedural inadequacies identified during implementation of ISAP I.d.2 and the substantial number of inspectors who were identified as
- requiring scope Phase of ISAP I.d.l. III evaluation during implementation of the original i
The specific valid Deviation Reports for QC
, inspector certification problems and the results of the I.d.1 type
! evaluations identified during this process were considered in the
! final conclusions on the overall adequacy of the CPSES QC inspector _ ;
certification program addre wed in this ISAP. In addition, posrible i impact of these deviations and evaluations on the ISAP VII.c results wcs identified.
Some inspectors identifiad during implementation of ISAP VII.t.8,
} "Fuel Pool Liner Documentation," ISAP VII.b.1, "On Site Fabrication,"
and ISAP VII.b.3, "Pipe Support Inspections," were also referred to
' the QA/QC Review I'eam I.d.1 group for I.d.1-type evaluations. As a j resuit of ISAPs VII.c, VII a.8, VII.b.1, and VII,b.3, an addi.:ional 268 TU Electric, Brown & Root,
- have received I.d.1-type evaluationsand other site subcontractor personnel in addition to the 319 inspectors I.d.l.
evaluated in accordance wi.ch the original scope of ISAP As a result of the evaluation of the additional inspection personnel associated with ISAPs other than I.d.1 listed above, a decision was made to increase the scope of ISAP I.d.1 to include these additional evaluations in the final conclusion on the overall adequacy of the CPSES site QC inspector certification program. The total number of TU Electric, Brown & Root, and other subcontractor QC inspectors who have received I.d.1 type evaluations comprises almost 70% of all QC inspectors who have oeen utilized through March 1985 during construction at Comanche Peak, It should be noted that thi'. inspectors identified during the ISAP VII.c documante. tion reviews formed a large subset of the insoectors whose work was recreatable and was reinspected during ISAP Vil.c reinspections.
Revision: 1 Pego 5 of 138 ISAP I d.1 *
(Cont'd)
3.0 BACKGROUND
(Cont'd)
The evaluation methodology specified in Section 4 of this Results
- Report was established and implemented well in advance of the issuance of Revisions 2 and 3 of the CPRT Program Plan, including the associated Appendix E. "CPRT Procedure for the Resolutio.2 of Discrepancies Identified by the CPRT'. Appendix E defines the classification implementationand resolution of discrepancies identified during the of ISAPs.
Because of the advanced stage of implementation of ISAP I.d.1 when Appendix E came into effect, no attempt was made by tne QA/QC Review Team to backfit all the detailed requirements of Appendix E. However, the intent of the latest requirements addressed by of theResults this CPRT Report.
Program Plan and Appendix 1 are adequattly Although discrepancies in individual inspector certification files were not documented as construction deviations, Inspector Certification Evaluation Summaries (ICES), shown in Attachment 1, were(completed and are equivalent to construction Deviation Reports. The discrepancies noted on the ICEB were evaluated evaluations (Phasein Phase II and III) were required. a determination nada whether further If an inspector failed Phase III evaluation, a root cause/ generic implication analysis was required (as it would have been for a construction deficiency) and the possible impact on the safety function of the associated hardware was i
" evaluated.
l ISAP I.d.1 results were reviewed and trends identified and evaluated. Potential
! hardware implications were also considered for those inspectors whose Phase III evaluation results vers indeterminate.
The results of this review for trends are described in Section 5.7 of this Resul6s Report. Hardware discrepancies identified during Phase III reinspections were separately documented as required by the TU Electric / Brown 4: Root nonconformance system. All of these hardware discrepancies were evaluated to determina if any were reportable to the rRC by TU Electric in accordance with the requirements of 10CPR50.55(e).
4.0 CPRT ACTION FIAN This Action Plan was originally developed to address specific NRC TRT concerns regarding TU Electric electrical QC inspector qualifications.
As described above in Section 3.0, the decision was made to include the I.d.1-type evaluations made in conjunction with other ISAPs in the overall scope of ISAP I.d.l. This Action Plan is closely related to and complements ISAP I.d.2.
Evaluations of the addttional inspectors associated with ISAPs VII.c, VII.a.8 VII,b.1, and VII,b.3 also g
prnidad a significant amount of information that was useful for evaluating the effectiveness of the overall CPSES QC inspector certification program.
Data from the evaluations associated with O
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Rcvision: 1 Pego 6 of 138 RESUI.TS REPORT ISAP I.d.1 (Cont'd) i 4.0 CPRT ACTION PIAN (Cont'd) these scope. ISAPs was included with the results of the original ISAP I d.1
- This information, along with the ISAP I.d.2 results, was utilized to reach an overall conclusion on the adequacy of the TU Electric, Brown & Root, and subcontractor QC inspector certification programs.
Section 4.1 describes the scope and methodology utilized for the original scope of ISAP I.d.1, that included evaluation of all TU Electric historical electrical QC inspectors and all current TU Electric and Brown & Root QC inspectors.
Section 4.2 describes the scope and methodology utilized for evalucing inspectors associatid with ISAPs VII.c, VII.a.8, VII b.1, and VII,b.3.
4.1 Scone and Methodolory. Orizinal ISAP I.d.1 1he original oojectives of this action plan were to address the specific TRT concerns regardi.ng the electtical QC inspector qualifications and to provide input into the overall assessment of the adequacy of quality control inspection. In order to meet these objectives, all current TU Electric and Brown & Root QC inspsetors and TU Electric historical electrical QC inspectors were selected for evaluation from the population of current and historical QC inspectors.
The methodology for accomplishing the major objes:tiver of this evaluation was as follows:
Phase I. Training, qualification, certificction and
! racertification files for all TU Electric elu,etrical QC Inspectors, for all current Brown
& Rcot QC inspectors and for the remaining current TU Electric QC inspectors were reviewed against Project requirements.
Phase II. If inspectors' qualifications were found to be questionabis or unverified in Phase I they were further evaluated to determine whether a basis existed to resolve the concerns utilizing available or obtainable documentation.
1 Phase III Finally, a portion of work completed by those I inspectors whose qualificacious could not be ,
verified in Phase II was reinspected. I l
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Reviston: 1 Pcgs 7 of 138 RESULTS REPORT l
ISAP I.d.1 ,
(Cont'd)
O 4.0 CPRT ACTION PI.N (Cont'd)
Concurrent with the implementation of this portion of this ISAP, TU Electric conducted a review of their QC inspector qualification improvements.records system and identified and Laplemented 4.1.1 Phase I - Evaluation of Inspector Qualification Documentation The objective of Phase I was to perform a review of the available documentation of the qualifications of inspectors against the criteria contained in Attachments 2 and 3.
The results of this review were documented to demonstrate, where possible, the adequacy of inspector qualifications.
The review was conducted in two parts.
TU Electric QC Inspector _ Review The review of TU Electric QC inspector qualification documents was initially conducted by the TU Electric Audit Group (TAG). The TAG initiated this review in late 1984 and completed
() their work in January 1985. This TAG effort was subsequently redone by the QA/QC Review Team to meet expanded requirements of the CPRT frogram l that were established subsequent to this work.
This initial TAG review does not form a basis for any results or conclusions contained in this Rasults Report. The QA/QC Review Team review was based on the criteria contained in the matrix shown in Attachment 2.
Brown & Root QC Inspector Review The QA/QC Review Tesa conducted a review of the procedures for certifying / qualifying Browr. &
! Root QC inspectors to identify project requirements and, for the current Brown & Root procedures, to assure compliance with applu:able standards and codes. The QA/QC Review Team also reviewed the certification records of current Brown & Root QC inspectors to verify compliance with these procedures and the criteria established in.the attached matrix (Attachment
- 3) . *. .
O t
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Revisicn: 1 Pego 6 of 138 RESULTS REPORT ISAP I.d.1 *
(Cont'd) 4.0 CPRT ACTION PIAN (Cont'd)
. For inspector certification documentation reviews, a specific inspector.certificatim ~mry was generated for each Ihe certification suemary pm M des a listing of the individual's initial and discrepant certifications and any concerns / discrepancies noted regarding r.he individeal's specific classroom t. raining, ot '.he jch training and examinations in eddition to educetion and experience.
Inspectors whose qualification documentation was lacking in one or more aspects listed on the carcification summary were idantified for further review during Phase II.
4.1.2 Phase II Further Evaluation The objective of Phase II was to evaluate qualifications that could not be verified in Phase I and, based on these results, determine whether further evaluation of the inspector's capabilities was required during Phase III.
A Special Evaluation Team (SET), comprised of external consultants who hed no responsibility for administering the CPSES Inspector Training / Certification Program and whose qualifications are described in paragraph 4.4 of this plan, evaluated the Phase I reviews conducted by the QA/QC Review Team to validate the reviews.
SET evaluated questionable TU Electric QC and Brown & Root QC inspector records for acceptability using the criteria established in Attachments 2 and 3. These evaluations included consideration of the specific circumstances as applicable in the following areas:
Experience of the inapactor I
Education of the inspector I
l Formal training at CPSES On the job training that demonstraces practical proficient.y Exam,inations that demonstrate knowledge of procedures, O
Revision: 1 Pago 9 of 138 RESUI,TS REPORT ISAP I.d.1 (Cont'd) 4.0 CFRT ACTION FIAN (Cont'd)
Other valid cercifittnions in related areas Other considerations deemed appropris':e by SET.
These considerations were documented by SET.
For TU Electric QC inspector certifications prior to January 1981, the following additional criteria, listed in descending order of importance, were also used by the SET to evaluate inspector qualifications:
TU Electric procedure CP-QP 2.1, Revision 0 through Revision 6, and the associated "daughter instructions" (QI-QFs). These "daughter instructions" define specific inspection functions and capabilities, requirements for documenting training activities and requirements for qualificatton ef inspection personnel. -
SET judgment based on ANSI N45.2 and ANSI N45.2.6, that have been industry consensus /
practice since 1973.
O -
Consideration of the TU Electric method utilized to limit certifications to specific inspection procedures containing detailed instructions /
1 steps, rather than attempting to certify personnel in a specific discipline, och as "electrical", to perform any and all electrical inspections.
Related experience, if it had a direct relationship to the inspections for which l
certified. (e.g., hands on, power plant l
construction or QC inspection activities equivalent to activities for which certified.)
For Brown & Rcot QC inspector certificacicns prior to January 1981, the Brown & Root "Quality Assurance Personnel T.aining Manual" and judgment based on ANSI N45.2 and i.NS1 N45.2.6, that have been industry conseanus/ practice since 1973, were used co evaluate ir.spector qualifications.
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Lovision: 1 Pegs 10 of 138 RESULTS REPORT ISAP I.d.1 '
(Cont ' t.)
4.0 CPRT ACTION PIAN (Cont'd)
Certification summary sheets, typ h al of Attachment 1 were performed preparedby SET. for each inspector to reflect the evaluation ,
TU Electric was requested e orovide additional information or verifications on a basis. .4 by case
'Ihe QA/QC Review Team Leader (RTL) or the Deputy RTL and the Issus Coordinator we.e responsible for performing a review of all additional information obtained by W Electric to update certification records. Copies of these records are retained in ene ISAP I.d.1 working file.
Based on the results of this evaluation, the RTL or the Deputy RTL, in conjunction with the Issus Coordinator, was responsible for accepting the qualifications without further action, or, for those inspectovs whoas qualifications to Project requirements could not b6 demonstrated, placing them into Phase III for further evaluation.
4.1.3 Phase III Reinspection The objective of Phase III was to evaluate a sample of work completed by each of those inspectors whose qualifications could not b e verix'ied in Phase II. The purpose of this evaluation was to determine the following:
Whether the inspectors were able to conduct inspections properly despite weaknesses or inadequacies in their qualification documentation.
Whether additional evaluations were required of the impact on the safee; function of hardware inspected by personnel failing Phase III evaluation or whose capabilities to satisfactorily conduct inspections were indeterminate or inconclusive.
Reinspections were conducted of the initial work for those
-inspectors whose qualifications were not accepted in Phase I or Phase II.
Evaluations that focus on the intrial inspections of individuals we o enosen because it is reasonable to conclude that added experience will increase an inspector's.
more familiar w, capability. As time progresses they boccae f
ith their assigned tasks, and the chance of 9
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Revisicn: 1 Pogs 11 of 138 ISAP I.d.i (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
- error decreases. There fore , the items to be reinspected were drawn, where possible, from an inspec. ors initial work conducted in the first 90 days after iss';.ance of the applic.able questionable certification.
A similar three phase evaluation process, including the Phase III reinspectiona described below, has been utilized at another nuclear facility as an effective method to determine if an inspector was capable cf performing the required inspections.
P Pood aion The population to be sampled included the identified applicable inspections performed by each of those inspectors placed into Phase III.
Sample Selection Process Lists of inspections and inspection records were reviewed to identify work / inspections that each inspector pstformed O during the first 90 daye following the issuance of the discrepant certification. This engineered selection of items, rather than a randos selection from the whole population, is conservative because of the increased l likelihood of inspection errors occurring while the inspector was relatively new to the work.
A review of the records of each ites chosen for reinspection determined if subsequent work had been performed that would disturb or change the condition of the ites since the initial inspection. A determination l was also made as to whether the ites was still accessible, the inspection was recreatable and if the ices had been reinspected by others after the initial inspection.
Inspections for which the ites had bean disturbed, changed, reinspected, or were inaccer- le and inspections that were not recreatable were rene on the sample.
The definitions of "inaccessible" and .4ot recreatable" are as follows:
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i Revision: 1 i Page 12 of 138 RESULTS REPORT s
ISAP I.d.1 (Cont'd) 4.0 CPRT ACTION PIAN (Cont'd) i "Inaccessible" is defined to mean a condition !
where extensive dismantling would be required to
~ gain access for direct reinspection, such as in the case of piping, reinforcing steel or conduit i that 1.,
embedded in concrete. j
" ot recreatable" is defined to mean a condition where a process or event cannot be recreated, such as pull forca during cable pulling, interpass weld temaerature or receiving inspection.
I Each inspection condue.tel during the first 90 days was reir.apected. 11. the event that this first sample was too small (1er,, than 50 items) to make a judgment on an inspecorm qualifiestians, selection continued in ~
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s'.;uantial ord.c until the sample reached 50 items or included all of the identifiable recreatable work accomplished by that inspector. :
Reinspection of Hardware Each icou in the sample was reinspected usin6 TU Electric or Brown & Root inspectors, who were presently certified to conduct the requireci inspections (verified by the QA/QC Review Team) and nat personally involved in he original :
inspection activities in question, with a 100% overview by !
independent third party QA/DC Review Team inspectors. The same TU Electric or Brown & Root inspection procedures utilized on the initial inspection were used for the i reinspection.
Care was taken to assure that the ites was reinspected to the same criteria as that used for the initial inspection. Prior to conducting the reinspections, the objective / subjective designation of each inspection attribute was decernined. Discrepancies identified during the reinspection were processed in accordance with TU Electric / Brown & Root nonconformance procedures, ;
i The results of the reinspection were compared to the original inspection results in accordance with the i following:
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Revision: 1 Pego 13 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
- O 4.0 CPRT ACTION PLAN (Cont'd)
For objective type attributes there must be a 95% or greater agreement rate between the
- results of the original inspection and the results of the reinspection. This figure (954) was chosen based on the fact that objective attributes are repeatable and are not subject to interpretation nor require judgment. For example, measurement of physical dimensions to i verify compliance with dimensional tolerances is '
an objective attribute.
For subjective type attributes there aust be a 90% or greater agreement race between the results of the original inspection and the results of the reinspection. This figure (904) was chosen based on the fact that subjective attributes require interpretation, and the specific ites being inspected may be viewed -
differently by various inspectors. For example, determining if a weld is smoo: ' ermugh so that any existing surface irregular ta will not l / interfere with interpretation ei a radiograph O) that is to be taken of that veld is a subjective attribur.o .
The results of the reinspection vera compared to the original inspection to determine if this agreement rate was equal to or greater than the requirement of 954 for cbjective attributes and 90% for subjective attributes. If the inspector failed to meet this rate, the sample was required to be expanded to include the next 90 days of work.
The same criteria for a minimum sample size of 50 was applied.
The same process of reinspeceicn was repet:ed and 180 daythe period.
cumulative results calculated for a If the inspector failed, (i.e.
less chan 954 agreement of cumulative results for objective type attributes and/or less than 90% agreement of cumulative results for subjective type attributes), a 1004 reinspection of all the inspector's work was required to be O .
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c Revision: 1 Page 14 of 138 RE.,,5ULTS REPORT ISAF 1.d.1 (Cone'd) 4.0 CPRT ACTION PIAN (Cont'd) conducted, unless otherwise recossended by the QA/QC Review Team based on the results of root cause/ generic implication analyses or other relevant information.
The Issus Coordinator, in conjunction with the QA/QC Deputy RTL, evaluated the results of the Phase III reinspections. In cases where the required number of inspections was obtained within time frames reasonably close to the initial disc.repant certification, inspectors were determined to the reinspection be acceptable or failed, depending on results. In cases where the required number of inspections was not obtained or where inspections occurred in time frames substantially after the initial certification, inspectors were determined to have failed, to be of indetermina:e acceptability, or to be substantially positive if there was a substantial amount of positive information regarding their capabilities.
Root cause/ generic implication analyses were co h ted for inspectors failing Phase III and QA/QC program deviations and deficiencies that occurred were identified and referred to IV Electric for correction.
4.1.4 Qualification Records System Review In addition to the review of records for individual inspectors TU Electric took action to identify improvements to their qualification records systee and procedures.
The objective of this review was to establish a qualification records system that collects qualification data in a clear and concise form that is easily retrievable.
4.2 Scope and Methodolocy for Evaluations Associated With Related 18.Ms ISAPs VII.c, VII.a.8, VII.b.1, and VII.b.3 included requirements forQC' by the inspectors.
review and evaluation of documentation that was prepared As a check on the validity of this documentation, the certifications of the QC inspectors who prepared the documentation were reviewed for adequacy. All inspectors who were identified during these documentation reviews were subjectou to a I,.d.1 type avaluation.
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Rovioien: 1 Pass 15 of 138 ISAP I.d.1 (Cont'd) 4.0 CPRT ACTION PIAN (Cont'd)
The methodology for conducting the evaluations associated with
- related ISAPs was as follows:
For ISAPs VII.c, VII.b.1, and VII b.3, documentation review checklists contained attributes to verify that QC inspectors associated with the documentation being reviewed had valid certifications. In those cases where the certifications appeared discrepant, DRs were prepared and they forwarded to the ISAP were processed I.d.1 Issue Coordinator where as follows:
- 1) ISAP I.d.1 personnel reviewed the DRs and, as -
appropriate, validated or invalidated the DRs.
- 2) I.d.1-cype evaluations were performed on these inspectors, whether or not the associated DRs.
were valid or invalid. Where valid DRs existed, the specifics of the certification deviations were addressed in the I.d.1-type evaluations.
For ISAP VII.a.8, the ISAP Issua Coordinator transmitted a O list of all QC inspectors identified during implementation of the ISAP to the ISAP I.d.1 Issue Coordinator. A I.d.1-type evaluation was performed on all these inspectors.
For ISAPs VII.c and VII.b.3, QC inspectors associated with documentation reviews for whom no DRs regarding certification had been written were identified from informal documentation maintained by the QA/QC Review Team Inspection Group. A simila" type list of inspectors associated with ISAP VII.b.1 for whom no DRs had been written was provided to the ISAP I.d.1 Issue Coordinator by the ISAP VII b.1 Issus Coordinator. A I.d.1 type evaluation was performed on all these additional inspectors.
The ISAP I.d.1 Issue Coordinator provided the results of the I.d.1 type evaluations, including the status of related DRs, to the applicable Issue Coordinators.
Results of the additional I.d.1.cype evaluations associated with related ISAPs were included with the results of the svaluations associated with the original ISqI.d.1 scope. The combir.ed results were utilized to O
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Rovision: 1 Pags 16 of 138 ISAP I.d.1 l t
(Cont'd) l i
4.0 CPRT ACTION PIAN (Cont'd)
) - reach a conclusion on the overall adequacy of the TU
- Electric and Brown & Root QC inspector certificat. ion programs.
The I.d.1 cype evaluations were conducced using the same three phase methodology described in Section 4.1 and as detailed in the following sections:
4.2.1 Phase I Evaluation of Inspector Certification Documentation The Phase I evaluations of QC inspectors associated with related ISAPs were conducted by the QA/QC Review Team under the direction of the ISAP I.d.1 Issue Coordinator utilizing the same review criteria specified in Section 4.1.1. In addition to QC inspectors from TU Electric and Brown & Root, QC inspectors from Chicago Bridge & Iron (CBI), Sahnson, Mason Johnston, R. W. Hunt, and Freese &
Nichols were evaluated. Except for CBI, criteria contained in Attachment 2 were utilized for the review.
In the case of CBI, criteria contained in Attachment 3 were utilized for the review. <
A specific certification summary was generated for each inspector. Each summary provided a listing of the individual's initial and discrepant certifications. The sumanary also identified any concerns / discrepancies noted regarding the individual's specific classroom training, on-the. job training, examinations, and education and experience. Concerns related to DRs were also referenced and described in the summaries.
Inspectors whose qualification documentation was lacking in one or more aspects listed on the certification summary were identified for further review during Phase II. The certification summaries for these Phase II inspectors were also transmitted to the TU Electric Quality Training Supervisor for further action and resolution of the
' outstanding concerns.
4.2.2 Phase II Further Evaluation The objectives.and methodology for conducting Phase II evaluations of inspectors associated with related ISAPs !
was the same as described in Section 4.1.2 with the following exceptions:
Revision: 1 RESULTS REPORT Pc52 17 of 138 ISAP I.d.1 '
(Cont'd) f3 V
4.0 CPRT ACTION PLAN (Cont'd)
The Phase II evaluation was conducted by the ISAP I.d.1 7.ssus Coordinator and the QA/QC Deputy RTL. The SET did not participate in any evaluations of inspectors associated with related ISAPs.
The Phase II evaluation was conducted utilizing the TU Electric response, including any additional information, to the concerns noted in the certification summaries. Evaluation criteria were the same as noted in Section 4.1.2. In the case of subcontractor QC inspectors, applicable requirements of the subcontractors' QA/QC programs and inspector certification procedures and requirements were also considered in the Phase II evaluation process. -
Based on the results of the Phase II evaluatione, the Issus Coordinator and the Deputy RTL accepted the qualifications without further action, or, for those inspectors whose qualifications to Project requirements O could not be demonstrated, placed them into Phase III for further evaluation.
4.2.3 Phase III - Reinspection The Phase III reinspections of inspectors' work associated with related ISAPs were conducted in the same manner as described in Section 4.1.3.
4.3 Participants Roles and P.esponsibilities 1
4.3.1 Special Evaluation Team (SIT) 4.3.1.1 Evaluated the QA/QC Review Teaa Phase I reviews for the original ISAP I.d.1 scope of work.
4.3.1.2 Conducted evaluations of inspectors where qualification documentatioa was inadequate or not available during Phase II for the original ISAP I.d.1 scope of work.
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- l 4.0 CPRT ACTION PLAN (Cont'd) 4.3.1.3 Personnel Mr. J. W. Sutton
. Mr. M. L. Curland 3 4.3.2 TU Electric QA t
4.3.2.1 i Provided additional information or verifications i, on a case by case basis during Phase II evaluations.
j 4.3.2.2 Identified recreatable inspections for those inspectors placed into Phase III, 4.3.2.3 Provided qualified inspectors to conduct Phase III reinspections.
4.3.2.4 Identified improvements to the TU Electric QC inspector qualification records system and procedures.
4.3.2.5 Personnel Mr. P. E. Halstead Quality Control Manager, Site Mr. A. M. Contino Quality Training Supervisor 4.3.3 QA/QC Review Team 1
4.3.3.1 Reviewed Brown & Root and TU Electric QC inspector qualification documents in Phase I for the original ISAP I.d.1 scope of work and for inspectors associated with related ISAPs.
4.3.3.2 Reviewed Phmso II evaluation results and determined whether individual inspectors were acceptable or required further evaluation in Phase III for the original ISAP I.d.1 scope of work.
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(Cont'd) 4.0 CPRT ACTION PIAN (Cont'd) 4.3.3.3 Conducted Phase II evaluations for inspectors associated with related ISAPs and determined whether they were acceptable or required further evaluation in Phase III, 4.3.3.4 Conducted 100% overview of TU Electric / Brown &
Root Phase III reinspections.
4.3.3.5 Reviewed current Brown & Root procedures and instructions for qualifying and certifying QC inspectors to verify compliance with FSAR requirements and reviewed the results of the TU Electric action to upgrade the QC inspector l qualification records system and procedure.
4.3.3.6 Reviewed results of Phase III evaluations and.
i accomplished the following:
! Identified and classified trends.
Conducted root cause/ generic implication analysis.
Identified QA/QC program deviations.
Identified additional evaluations required to determine and resolve the potential impact on the safety of hardware inspected by personnel whose capabilities were indeterminate or inconclusive after Phase III evaluation.
4.3.3.7 Personnel Mr. J. L. Hansel QA/QC Review Team Leader Mr. J. D. Christensen QA/QC Deputy Review Team Leader Mr. J. E. Young Issus Coordinator O
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(Conc'd) 1 1
4.0 CPRT ACTION PLAN (Cont'd) f 4.4 Qualifications of Personnel i l
4.4.1 QA/QC Review Team inspectors were certified to )
1 the requirements of ANSI N45.2.6 and Regulatory Guide 1.58.
4.4.2 TU Electric and Brown & Root QC inspectors who l conducted the Phase III reinspections were certified at least Level II in accordance with (
applicable TU Electric and Brown & Root inspector certification requirements. !
I 4.4.3 SET personnel had, as a minimus, 5 years of management / supervisory level experience in QA/QC, and met the qualification requirements specified in the CPRT Program Plan.
4.4.4 QA/QC Review Team personnel met the qualification requirements specified in the CPRT 1
Program Plan and had, where required, prior experience in the area of inspector qualification / certification and training.
1 4.5 Procedures l The following QA/QC Review Team procedures and instructions were l
applicable to this action plan:
QI-005, "Evaluation of Inspector Performance" CPP 025, "QC Inspector Qualification Evaluation" 4.6 Standards / Acceptance Criteria Per FSAR coenitments, the following standards / acceptance criteria applied to this action plan:
CPSES Quality Assurance Program Requirements Regulatory Guide 1.58, Revision 1 ANSI N45.2.6 1978 ASME Code Req resents '
ASNT SNT TC-1A O
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i Revisten: 1 Pego 21 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 4.0 CPRT ACTION PIM (Cont'd) 4.7 Decision Criteria There were three primary decision points in the action plan. At each declaion noint, criteria were established to ensure that action continued to be taken on questionable items until an adequate and documented basis existed for disposition.
4.7.1 Phase I Evaluation Unless an inspector's available qualification documentation clearly met the criteria of Attachments 2 or 3, the documentation was referred to Phase II evaluation.
4.7.2 Phase II Evaluation Phase I concerns were evaluated along with additional information provided by TU Electric or Brown & Root to .
determine whether a basis existed for resolving the concerns. If not, the inspectors in question were placed into Phase III for further evaluation.
4.7.3 Evaluation of Phase III Results The results of the Phase III reinspections were reviewed to determine if an inspector was acespeable, if thera was substantial positive information available, if he was of indeterminate acceptability, or if he failed. Additional evaluations inspectors. were conducted for indeterminato and failed 5.0 IMP 1.EMENTATION OF ACTION FIAN AND DISCUSSION OF RESULTS 5.1 Introduction The major objectives of this Action Plan were as follows:
To address the specific TRT concerns stated in SSER 7 by assessing the qualifications of all TU Electric electrical QC inspectors and assessing the qualifications of all current Brown & Root QC inspectors and current TU Electric QC inspectors. These assessments comprise the original scope of ISAP,I.d.1.
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IMPIRGNTATION OF ACTION PIAN AND DISCUSSION OF RESUI.TS (C
) -
To evaluate the adequacy of the qualifications of all
( .
i inspectors identified during documentation reviews
{ associated with ISAPs VII.c, VII.a 8, VII.b.1, and VII.b.3. These evaluations provide additional information j' regarding the validity of the documentation that was
- reviewed during the implementation of these ISAPs.
To determine the overall adiquacy of the CPSES QC inspector certification program utilizing the data fron the evaluations described above and the results of ISAP I.d.2.
4 i
In those cases where inspector qualifications could not be l
verified by Phase I and Phase II evaluations of the applicable 1 certification files, a Phase III reinspection of a portion of
- each such inspectors work was initistad to confirm the capability
{ of the inspector to conduct the required inspections. Additional
! evaluations were required to be conducted to identify the impact on the safety of affected equipment for those inspectors who
{
failed Phase III.
J Implementation of this Action Plan was complemented by ISAP I.d.2, which evaluated the adequacy of the current TU Electric QC 9
inspector certification program (both procedures and implementation) in meeting FSAR commitments. In addition, during the course of the implementation of ISAP I.d.1, the current Brown
& Root QC inspector certification procedures were reviewed to verify the adequacy of the current Brown & Root QC inspector certification program.
The combined results of ISAP I.d.1 and ISAP I.d.2 provide the basis for final conclusions on the past adequacy of the TU Electric and Brown & Root QC inspector certification programs reported in Section 6.0 of this Results Report.
The results of the implementation of this Action Plan are described in this Results Report as follows:
Section 5.2 - Original I.d.1 Scope Section 5.3 - Evaluations Associated with Related ISAPs O
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(Cont'd)
O 5.0 IMPLINENTATION OF ACTION PIAN AND DISC 03SION OF RES Section 5.4 Other Actio.u 5.4.1 Review of Brown & Root QC Inspector Certification Procedures 5.4.2 - Qualification Records System Review 5.2 Original I.d.1 Scope The original scope of ISAP I.d.1 consisted of the evaluation of all TU Electric historical and current electrical QC inspectors, all remaining current TU Electric QC inspectors, and all current Brown & Root QC inspectors. During the implementation of this portion of this Action Plan, inspector qualification documents for a total of 319 TU Electric and Brown & Root QC inspectors were reviewed.*
Implementation of this portien of the Action Plan began in October 1984 and was completed in January 1987. Durin5 th*
course of the activities, the roles of the various groups responsible for implementing the Action Plan (TAG, SET, and the QA/QC Review Team) changed and evolved. Nevertheless, the work was still conducted in three phases, as prescribed in Sections 4.1.1, 4.1.2, and 4.1.3 of the ISAP. The following sections
- describe the methodology and results of the work that was conducted during each phase.
(
5.2.1 Phase I During Phase I, training, qualification, certification and recortification files for all TU Electric historical electrical QC inspectors and all current TU Electric and Brown & Root QC inspectors were reviewed.
Thirty four of these 319 inspectors were current Brown & Root inspectors who were also certified by TU Electric. Thus there were actually only 285 individuals who were certified inspectors.
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5.0 IMPLENENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Co
- Table 1 details the numbers and types of QC inspectors whose certification packages were reviewed during the implementation of Phase I by the QA/QC Review Team.
Documentation of Phase I reviews for each of the 319 inspectors is contalaed in the ISAP I.d.1 Results Riport files.
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Revision: 1 RESULTS REPORT Pcss 25 of 138 ISAP I.d.1 (Cont'd)
O 5.0 IMPLEMINIMION OF ACTION PIAN AND DISCUSSION OF RE TABLE 1 QC INSPECTORS REVIEVED DURING PHASE I ORICINAL I.d.1 SCOPE 1.
TU Electric Total
- Historical Electrical QC Inspectors (Non-ASME) - 86 2.
Current TU Electrie QC Inspectors (Non ASME) 166 Total
- Electrical
- 33 Reviewed I&C/ Radiation Wasco Mansgement System -
4 Reviewed NDE/Thermolag -
6 Reviewed Civil 2 Reviewed Protective Coatings 13 Reviewed Test Laboratory O 6 Reviewed 1
Mechanical
- 44 Reviewed Level III
- 24 Reviewed Brown & Root QC Inspectors Maint eining TU Electric Certs (Hilti's) 34 Reviewed Note: These M inspectors are also included with the 67 current Brown & Root QC Inspectors noted in Itana 3, below.
- 3. Current Brown & Root QC Inspectors (ASMI) 67 Total *
- 4. Total Number of Inspector 0 Reviewed - 319 l
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- NOTE:
Current TU Electric QC inspectors are those employed onsite as of March 11, 1985. TU Electric historical elecerical QC
- inspectors are those who were not on the March 13., 1985 list and were employed prior to that date. Current Brown & Root QC inspectors are thoae employed onsite as of March 20, 1985.
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(Cont'd) 5.0 IMPI.EMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Co
- - of the 319 inspectors reviewed during Phase I, only 17 Brown & Root inspectors maintaining TU Electric QC l certifications. one test lab inspector, one TU Electric mechanical inspector, and one historical electrical inspector were not advanced into the Phase II evaluation.
5.2.2 Phase II The objective of Phase II was to evaluate qualifications further that could not be verified in Phase I and, based on the results of that evaluation, determine which inspectors required further evaluation during Phase III.
In the case of TU Electric QC Inspectors, the SET reviewed the results of the Phase I screening process conducted by the QA/QC Review Team and, based on this review, resolved some concerns and documented the remaining concerns on Inspector Certification Evaluation Summaries (ICES).
These forms were transmitted to TU Electric for further action and resolution of the outstanding concerns.
Attachment 4 categorizes the concerns regarding TU Electric inspectors that were identified during Phase I and evaluated during Phase II by number and type.
In the case of Brown & Root QC Inepectors, the SET worked directly with Brown & Root personnel to evaluate and resolve the Phase I evaluation results prepared by the QA/QC Review Team. After review of the concerns and resolution of these concerns where possible, the SET documented the results on ICES for each inspector.
Attachment 5 categorizes the concerns regarding Brown &
Root QC inspectors that were identified during Phase I and evaluated during Phase II by number and type.
Aftar receiving TU flectric responses to concerns regarding TU Electric inspectors on ICES and after completion of the ICES by the SET for each Brown & Root QC inspector, the Review Team IAader, the Deputy Review Team leader, or the Issue Coordinator reviewed the ICES to determine which inspectors were acceptable and which inspectors required further evaluation in Phase III. In the case of Brown & Root QC inspectors, 65 of the total of l
67 inspectors. evaluated in Phase II were determined to e
I Revision: 1 l Pego 27 of 138 i ISAP I.d.1 *
(Cont'd) 5.0 IMPLDGNTATION OF ACTION PIAN AND DISCUSSION OF RESULT have acceptable qualifications at the completion of the Phase II process. For TU Electric QC inspectors 191 of 232 inspectors evaluated in Phase II were determined to have acceptable qualificaties. The majority of concerns resolved during Phase II evaluations related to the following typical actions taken by TU Electric or Brown & 3 Root as applicable:
Missing, misfiled or backup documentation that related to activities er items such as on the job training, examinations, recertifications, and physical examinations were located and placed in the files.
Education and/or experier.co chat had not previously been verified was verified.
Additional information regarding related work.
experience was obtained.
Details regarding lapsed certifications or lapsed physical examinations were provided for evaluation.
Table 2 categorizes the 43 inspectc.*s that were placed into Phase III as a result of Phase II evaluations, l
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.QC INSPECTORS PMCED IFF0 PHASE III ORICINAL I.d.1 SCOPE Inspector Certification 1 Number to Phase III I
! TU Electric Historical Electrical QC Inspectors 22 I
1 Current TU Electric QC Inspectors Electrical 7 I&C/ RUNS 1
NDE/Thermolag 2
Civil 0
Protective Coatings 1 Test Laboratory 0 Mechanical 3 Level III 4 Current Brown & Root QC Inspectors Maintaining Non ASME Ceres (Hilti's) 1 Current Brown & Root QC Inspectors 2 Total Number of QC Inspectors to Phase III 43 O
- i. . .. _ .. -
Revision: 1 Pego 29 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPTJMENTATION OF ACTION PIAN AND DISCUSSION OF RESU During the Phase I and Phase II evaluations, a problem was identified that was closely related to QC inspector qualifications but which was not directly tied to individual inspector capabilities. For the purposes of this report, this probles (of which a description follows) has been termed the "NDE exclusion" problem. Three electrical inspection procedures for conduit, cable tray, and cable tray hangers contained requirements for visual inspection of welding during varying periods of time from December 1978 to December 1979. During these periods of time, the procedures did not clearly specify that welding inspections were only to be conducted by inspectors certified to inspect AWS welds visually. During these scas periods of time, electrical inspectors were trained and certified to those same procedures but in a number of cases were not trained and certified to conduct the welding inepections required by the inspection procedures.
Although the inspector certifications issued to these inspectors for these three procedures did not exclude welding inspection, the certification backup documentation clearly did.
l Although TU Electric vau of the opinion that inspection personnel during thesa periods of time clearly understood that welding inspections covered by chose procedures could only be conducted by inspectors certified to inspect AUS welding, the procedures and certifications were not clear that this was the case. Although the "NDE exclusion" problem is primarily related to a lack of clarity in the three inspection procedures, the QA/QC Review Team decided to place inspectors without welding inspection qualifications and who had been certified to these procedures during this time frame into Phase III.
The purpose of placing the inspectors into Phase III was to determine if welding inspections were or were not conducted by unqualified electrical inspectors. A detailed explanation of this prob 1en and the results of the evaluation is in the Summary of Phase III Results for Original I.d.1 Scope beginning-on Page 37.
Attachment 6 provides descriptions of why each inspector
! was placed into Phase III. However, the reasons may be susanarized as follows:
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Revision: 1 Pcgs 30 of 138 ISAP I.d.1 i
(Conc'd) 5.0 i
1 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF R Lack of experience - 13
- l Lack of education - 8 i Failed examination - 8 i
i i
i NDE exclusion -
6
}
j Lacked experience and NDE er.clusion - 4 i
Lack of experience and education * '
! Except for two Brown & Root inspectors, all of these inspectors were TU Electric QC inspectors (non ASME). .The two Brown & Root inspectors were placed into Phase III because scored. of failed examinations that were incorrectly 5.2.3 Phase III l The objective of the Phase III evaluations was to '
determine whether the inspectors were able to conduct inspections satisfactorily despite weaknesses in their documented qualifications. A further objective was to determine whether additional evaluation and/or inspection of hardware was required if inspectors were incapable of conducting inspections or if inspectors were identified whose abilities to conduct inspections properly were indeterminate.
When an individual inspector was identified as requiring a Phase III evaluation, the QA/QC Review Team requested that TU Electric provide a chronological listing of the inspections performed by the inspector during the first 90 days after issuance of the questionable certification or for the first 50 inspections, if less than 50 were conducted in the initial 90 day period. Only reinspectiens that were of a type appropriate to seasure the ability cf the inspector in the area of questior,able certification were utilized. In the cases that involved failed examinations or NDE exclusions, only the specific types of inspe,btions in which the certification problem occurred were utilized to obtain the required 50 inspections.
Revision: 1 Peg 2 31 of 130 RESULTS REPORT ISAP 1.d.1 (Cont'd)
O 5.0 IMPLDENTATION OF ACTION PIAN AND DISCUSSION OF RESU To provide the required listing for each inspector TU Electric obtained a print out itos a site computerized daca base from which a listing of inspections conducted by individual TU Electric inspectors can be obtained.
Utilising the print out, TU Electric then obtained co;ies of the inspection reports that document the inspections on the print out and reviewed them to identify non recreatable and inaccessible inspecticns. As a minianas,10 percent of this inspection identifi. cation and report evaluation work conducted by TU Elactric was reviewed by the QA/QC Reviaw Team to decorvine adequacy.
'IV Electric then provided the listing of accossible and recreatable inspections to the QA/QC Review To m , a!.ong with associated drawings, QC inspection procedures, and inspection reports completed by the inspector in question.
Prior to eenducting the reinspections, each applicabla checklist attribute was r aiewed by a QA/QC Review Team Level III inspector and a TU Electric or Brown & loot QC representative and was identified as a recreatable or nonrecreatable attribute and as an objective or subjective attribute as defined by Section 4.1.3 of this Results Report. The reinspections a re then conducted by an O ppropriately qualified TU Electric or Brown & Root QC inspector who had not been personally involved in tha inspection activities in question.
The reinspections were all witnessed and the results recordad on reinspection sacrix forms by qualified QA/QC
( Review Team inspectors. 'Ihe reinspection matrix forms identify applicable inspection atenbutes, whether the attributes are nonrecreatable or inaccessible, whether the attribuces are objective or subjective, the results of the original inspections, and the results of the reinspections. Typleal disagreements noted between the original inspections and the reinspections included t's following:
Hardware items with discrepant cond!,tions not neced during the original inspection.
I Requirements that were in effect ac the t.w of I the original inspection were used to identify these cond',tions. If ths noted conditions were sein discrepant in terms of the latest O
fi Revinien: 1 Pago 32 of 138
!!_SULTS REPORT ISAP I.d.1 *
(Cont'd)
, 5.0 IMPIEGNTATION OF ACTION PLAN AND DISCUSSION OF RESULTS inspection requirements the condition was docueented in accordance with TU Electric or Brown & Root nonconformance procadures.
Failure of the inspector to document the inspection properly.
Examples include fsilurv to record required inspection information correctly, such as material traceability or identification numbers, sp cification or drawing numbers and revisiens, and failure to record properly the inspection of each attribute requiring ins pction.
In addition to the reinspect!on matrix forms, the QA/QC Review Team prepared a duca base report for each reinspection. This data base report recorded the number of satisfactory decisions made by the original inspector l aloag with the nwber of unsatisfactory decisions made.
The totals from these forms provided the numbsrs from 1 which the final disagreement rates for each inspector w re calculated. It shodd be noted that multiple decisions may be associated with an attribute. For ersaple, if an item con ained six welds and the attribute to be inspected involved checking for veld size, this attribute would havs six decisions associs.ted w.th it. If one weld was under size that was misssd by the original inspector and the remainder were s:tisfactory, there would be five correct decisions and ww unsatisfactory decision. The final disagreement rates in percent for an inspector were calculated by dividing the total number of unsatisfactory decisions by 100. by the total number of decisions and multiplying A separate verific'ation of the accuracy of the L. Electric computer data base used to identify the lists of inspections for inspectore was conductri by the QVQC Review Tor.a. The TU Flectric cguter dats base was originally developed to provide TU Electric Operations with listings of construction generated documents relating to plant equipmene. Its purpose was not to identify inspections conducted by individual inspectors. The data base is, howver, the only convenient mechanism available O
Revision: 1 Peg 2 33 of 138 ISAP I.d.1 *
(Cont'd)
O 5.0 IMF12MMATION OF ACTION PIAN AND DISCUSSION OF R to obtain this information other than by the manual
- examination reports.
of a large number of individual inspection This verificatier. consisted of selection of 113 inspection reports from 1979 through 1986 from TU Electric Inspection' Report logs. Individual inspectors were then identified from the inspection reports. It was then determined if these inspections were included in the computer data base.
Except for two year? (1980 and 1981),
where over 80% of the reports were included, substantial omissions in the data base were identified during this verification process. The potential inao.apleteness of the data was considered during evaluation of the Phase III data and is identified where applicable in this section of the Results r.eport.
The followinC paragraphs summarize the results of the Phase III evaluations. Results of the Phase III -
evaluations for each inspector have o'sen categorized in one of the following four ways:
l Acceptchie or of No Concern In these cases, either the targeted number 32 50 reinspections have been successfully completed or other factors have been identified that eliminate ar.y concern. is example, there would be no concern if there was evidence that an i inspector did not conduct any inspections in the area of a questionable certification.
Substantial Positive Information In these cases, there is a substantial amount of information indiewting that an inspector was capable of properly conducting requirsd inspections or that the inspector never conducted iespections in the area of concern.
However, because of the lack of completenests, the available infor' nation is not conclusive.
An example would be the case of an inspector for which only 27 recreatable 1.spections instead of the targetea 30 could be 11er.cified, all of which were succescfully teinspected within the allowed uissgr .aent races, l '
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IMPROGNTATION OF ACTIO*t PIAN AND DISCUSSION OF Indeterminate i In these cases, there is insufficient information to make any determination of an 4
inspector's capability. An example would be if no recreatable or only e small nuber of recreatable inspecticas could be conducted, leaving the ability of the inspector to conduct the required inspections properly unknown.
Failed In these cases, there was less than a 954 agreement rate for objective typs tenibutes or 90% for subjective type attributes =her sample expansion as specified in Section 4.1.3. .
TU__ Electric Historical Electrical OC Inspectors.
Twenty two TU Electric historical QC inspectors were referred to Phase III for further svaluation. The detailed results of these Phase III evaluations, ineluding the reinspection results, are described in Attacnnent 7.
The following table depicts the evaluation results for these inspectors.
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(Cont'd) i 5.0 IMFuMENTATION OF ACTION PIAN AND DISCUSSION OF RE i
TMu 3 TU Electric , Historical Electrical QC Inspector Phase III Evaluation Results INSPECTOR !
EVAd1ATION RESULT INSPECTOR EVALUATION RESULT HE-1 NDE Exclusion HE-12 Acceptable, NDE !
hE-2 Exclusion '
Indeterminate HE 13 Indeterminate HE 3 No Concern HE 14 Acceptable HE-4 Indeterminate HE 15 NDE Exclusion HE 5 Acceptable HE 16 NDE helusion HE 6 Indatatninate NDE Md 17 Acceptable Exclus*cn HE 7 Acceptable HE 18 Indeterminate HE 8 Failed Hk 19 Indeterminate HE 9 Acceptable HE 20 No Concern, NDE HE 10 Exclusion Substantial Positive HE 21 Substantial Positive, HE ll Acceptable NDE Exclusion HE 22 Substantial Positive l
TU Electric Current Electrical QC Inspectors Seven TU Electric current electrical QC inspectors were referred to Phase III for further evaluation. The l
detailed results of these Phase III evaluations, including the reinspection results, are described in Attachment 8.
' he following table depicts the evaluation results for these inspectors.
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Revisten: 1 Pego 36 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLEMINTATION OF ACTION PIAN AND DISCUSSION OF RE TABLE 4 TU Electric Current Electrical QC Inspector Phase III Evaluation Resills, j
INSPECTOR EVALUATION RESULT CE 1 CE-2 Substantial Positive No Concern CCA CE 4 Substantial Positive Acceptable CE 5 CE-6 NDE Exclusion No Concern CE 7 Acceptable -
W Electric Current I&C/ Radiation Vaste Management Systes (RWMS) QC Inspectors !
One inspector, IC 1, was placed into Phace III for !
evaluation, the detailed result of this evaluation, including reinspection results, are described in Attachment 8. IC 1 was evaluacad to be acceptable.
i W Electric current NDE/thermolas OC Inspectors !
Two inspectors, NT 1 and NT 2, were placed into Phase III for evaluation.
Attachment 8. NT The detailed results are described in i acceptable. 1 and NT 2 were both evaluated to be W Iloctric Current Protective Coatinas OC Inspectors One inspector, PC 1, was placed into Phase III for evaluation from this grouping. 'The 6 tailed results are described in Attachment 8. PC 1 Uas of no concern.
W Electric Current Mechanical OC inspectors Three inspectors were referred to Page III for further evaluation froar this group. The detailed evaluation results are described i. Attachment 8. The following table depicts the evaluation results.
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(Cont'd) )
l 5.0 IMPLEMINTATION OF ACTION PIAN AND DISCUSSION OF RE TMu 5 !
TU Electric Current Mechanical QC Inspectors Evaluation Results INSPECTOR EVALUATION RESULTS NM 1 Acceptable NM-2 NM 3 Indeterminate NDE Exclusion TU Iloctric Current IAvel III QC Ihspectors There were four inspectors in this category placed ince' Phase III. The8.detailed evaluation results are described in Attachment The following table depicte the results of the evaluations.
O TASM 6 TU Electric current IAvel III QC InsDectors Evaluation Rasults INSPECTOR EVALUATION RESULTS L1 No Concern L2 No Concern L-3 No Concern L-4 NDI Exclusion Current Brown & Root OC Inspectors Maintainina TU Electric Certifications (Hilti Solts),
One Hilti bolt inspector, H3-1, required Pfu.se III '
evaluation in this category. Detailed evaluation results are discussed in Attachmant 8. HB 1 was evaluated to be of no concern.*., "
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_C wrent Brown & Root QC Inspectors Two frominspectors, AM 1 and AM 2, were placed into Phase III this car ,orw.
be of no conc..,n. AM 1 and AM 2 were both evaluated to Details are contained in Attachment 9.
Summary of Phase III Results for Oriainal I.d.1 Scope Ten inspectors NDE were evaluated in Phase III because of the exclusion problem.
We inspectors are HE 1, HE 6, HE 12, H 15, M 16, H 20, M 21, CE-5, NM 3, and L 4.
The inspection procedures involved were QI-QP 11.3 4, "Exposed Conduit, Condulet. Electrical Box and Support Inspection"; QI-QP 11.3-5, "Cable Tray Inspections"; and QI-QP 11.3-2, "Cable Tray Hanger Inspection". The first two procedures visual did not originally contain requirements for weld inspection. In December 1978, QI-QP 11.3 4 was revised to include visual inspection of welds.
QI-QP-11.3 5 was similarly revised in January 1979.
QI-QP 11.3 2 was originally issued in June 1978 and included requirements for visual inspection of welds.
Although it was TU Electric's practice to use only AWS I4 vel 11 certified inspectors to conduct these inspections, these three procedures did not clearly define this practice, and the inspection checklist included an attribute for the visual inspection results to be recorded
%ese procedures were revised in December 1979 to exclude visual welding inspection clearly fron their scope.
During the evaluation, five instances vera identified in which visual weld inspections were conducted by inspectors M 1 and HE 12 during this time period.
Because of inaccuracies in the computer data base, it is likely that cases other than those identified during the Phase III evaluation exist. Also, inspectors certified prior to December 1978 to QI-QP-11.3 4 or prior to January 1979 to QI.QP 11.3-5 without qualification to conduct visual welding would not have been identified for Phase III evaluation by the QA/QC Review Team because the procedures at that time did not contain requirements for visual weld inspection. However, following the procedural revisions that added visual welding, these same inspectors would have been subject to the same NDE exclusion problea as those identified by the,QA/QC Review Team for Phase III l
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-f Revision: i Pago 39 of 138 i ISAF I.d.1 (Cont'd) 3.0 IMFIRGNTATION OF ACTION PIAN AND DISCUSSION OF RESULTS ovaluation after the procedure revisions. It is concluded
- that, because of the procedural weaknesses identified 1 above, a small percentage of welds visually inspected in accordance with QI-QF 11.3 2, QI-QF 11.3 4 c.nd QI-QP 11.3-5 between December 1978 and December 1979 were inspected a-wi accepted by unqualified inspectors. QA/QC Program Deviation Report PDR 56 was written to document this condition.
QA/QC Program Deviation Report PDR 70, involving inspector IC 1, was issued to document the lack of definitive procedural requirements relating to the identification of instrumentation supports. '
Of the 22 TU Electric historical electrical inspectors referred to Phase III, six have been verified to be _
acceptable and cetpable of satisfactorily conducting inspections because the targeted number of reinspections were limitsconducted andISAP specified by the results I.d.1. were within the error One inspector had 49 instead of the targeted 50 reinspections. It is felt that O there is sufficient information to judge that this inspector was capable of conducting the required inspections. Two inspectors were decernined to be of no concern b-scause work is to be reinspected as part of a correceiva action program or no work had been conducted in the area of concern. An additional three inspectors were only involved with the NDE exclusion problem noted above.
One inspector did not have the required 50 reinspec': ions but had 28 reinspections. There is a substantial amount of information available that this inspector was capable of satisfactorily conducting inspect: .ns. Two other ;
- inspectors had the required 50 reinspections with acceptable results but, because of the time periods which elapsed between their initial certifications and the reinspections, there is a lack of conclusive evidence that they were initially capable of conducting the required inspections. However, there is a substantial amount of positive evidence that they were both J.nitially acceptable. Six inspectors were considered to be indeterminate as to their ability to satisfactorily conduct inspections. For four of these six, only non recreatable cable pulling and maggering inspections were identifie4. For the remaining two indeterminate
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e Revision: 1 GEULTS REPORT Pc50 40 of 133 ISAP I.d.1 (Cont'd) 5.0 IMPLEMINTATION GF ACTION PLAN AND DISCUSSION OF inspectors, no recreatable inspections could be identified
- for one and one had only 12 :screatable inspections with an objective error rate above the acceptable limit (7.29%
versus 5% required). One inspector failed Phase III based upon the combined results of an initial group of 50 reinspections and a second group of 50 reinspections.
There was a total of 19 TU Electric current QC inspectors referred to Phase III. Three of these inspectors have been discussed above in the description of the NDE exclusion issue. Six of these inspectors have been verified to be acceptable and capable of satisfactorily conducting inspections because the cargeted number of reinspections were conducted within the error limits specified by ISAP I.d.l. Another seven were judged to be of no concern because they had either not conducted inspection related activities, had not conducted safety related inspections or the area of concern is to be
, retaspected as part of a corrective action program. For one inspector there was substantial positive evidence that this individual did not conduct inspections involving discrepant certifications and for or.e inspector, 21 reinspections provided substantial positive information that this individual was capable of conducting the required inspections. The capability of one inspector was indeterminate.
In the case of Brown di Root current QC inspectors (ASME),
one inspector was verified to be of no cor.cern because no inspections were conducted which involved the certificattor. in question. The second inspector was also of no concern because the number of inspections were limited and were restricted to simple activities or conducted under the direct supervision of a qualif'.ed invol II inspector.
Ihe overall results of the Phase III evaluations, as described above, are summarized in Table 7.
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V Rovision: 1 Pc5S 41 of 138 ISAP I.d.1 (Cont'd) 5.0 IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF RE TABLE 7 SIDDIARY OF PHASE III EVALUATION RESULTS
- 1. NDE Exclusion Problems identified with 2 of 10 inspectors indicate further evaluation is required.
- 2. TU Electric Historical QC Inspectors Acceptable or No Concern 9 Indaternitute 6 NDE Exclusion only (see 1. above) 3 Substantial Positive Information 3 Failed 1
TOTAL 22 3.
TU Electric current QC Inspectors (Includes Brown & Root Current QC Inspectors Naintaining Non ASME Certifications)
Acceptable or No concern 13 Indeterminate 1 NDE Exclusion Only (see 1. above) 3 Substantial Positivs Information 2 TOTAL 19 4
Brown & Root Current QC Inspectors Acceptable or No Concern ?
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5.3 Evaluations Associated Jith Related ISAPs As described in Section 4.2, all inspectors who were identified during documentation reviews associated with ISAPs VII.c.
VII.a.8, VII,b.1, I.d.1-type and VII.b.3 were subjected to a three phase
< valuation.
associated with each ISAP are as follows:The numbers of evaluated in ISAP VII.c -
23' ISAP VII.s.8 -
19 ISAP VII.b.1 -
12 Total 268 Seven inspectors were identified that were associated with ISAP VII.b.3. However, all seven had previously been evaluated with ISAPs VII.c, VII.a.8, or the original scope of ISAP I.d.1. In addition, a significant number of inspectors who were identified in association with ISAPs VII.c, VII.a.8, srid VII.b.1 had already been evaluated in the original scope of ISAP I.d.1 and are not included in the above numbers. For the purposes of this portion of the report, the inspectors have been grouped as TU Electric his,torical QC insoectors Brown & Root historical QC inspectors, and subcontractor QC inspectors. Historical QC inspectors are, as for the original I.d.1 scope, IU Electric QC inspectors who terminated employment prior to March 11, 1985 inspectors who terminated employment prior to Marchand 20,Brown 1985. & Root QC Six inspectors (three TU Electric and three Brown & Root) were 1 identified that should have been classified as current inspectors.
Of these six, one was hired after the March 1985 print outs wors issuad, four worked in receiving inspection and vare not included in the March 1985 print outs, and one was ir. advertently left out of the origini ISAP I.d.1 scope of work by the QA/QC Review Team.
None of these six were sent to Phase III evaluation and, for ease of reporting, are included with the historical inspectors evaluatad during this portion of the work.
Although they are included with the hir.corical inspectors in this portion of the report, they have been properly categorized as current inspectors in the overall summary of results contained in Section 5.6.
The evaluations were conducted in three phases, as described in Sections 4.2.1, 4.2.2., and 4.2.3.of the ISAP. the following sections describe the 'inethodology and results of the work that was conducted during each phase:
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ISAF I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RES 5.3.1 Phase I During Phase I, training, qualification, certification and recertification files for all TU Iloctric Brown & Root, and subcontractor QC inspectors associated with related ISAPs (and not previously evaluated under the original scope of ISAP I.d.1) were reviewed by QA/QC Review Team personnel assigned to the ISAP I.d.1 Issus Coordinator.
In addition, these same personnel reviewed DRs related to QC inspector certification referred to them from ISAPs VII.c, VII.a.8, VII.b.1, and VII b.3, and validated or invalidated them as appropriate.
Table 8 details the numbers and types of QC inspectors whose certification packages were reviewed during the implementation of Phase I reviews for this portion of the work.
Documentation of Phase I reviews for each of the 268 inspectors is contained in the ISAP I.d.1 Results Report files.
One TU Electric historical electrical QC inspector, inadvertently overlooked in the original I.d.1 scope of work, is included in this portion of the evaluation.
< O of the 268 QC inspectors reviewed during the implementation of Phase I on this portion of the work, only one TU Electric historical mechanical QC inspector, two TU Electric historical civil QC inspectors, four Brown
& Re,ot historical mechanical QC inspectors, and one Brown
& Root civil QC inspector were not advanced into the Phase II evaluation.
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ISAF I.d.1 1 (Cont'd) l 5.0 IMPLINENTATIOtt OF ACTION PIAN AND DISCUSSION OF RES
_ TABLE 8 l
QC INSPECTORS REVIIVED DURING PHASE I 1
REIATED ISAPs l
- 1. TU Electric Historical QC Inspectors Electrical Mechanical 1 Reviewed Civil 49 Reviewed 15 Reviewed
- 2. Brown & Root Historical QC Inspectors Mechanical Civil 136 Reviewed 20 Reviewed
- 3. Subcontractor QC Inspectors R. W. Hunt Chicago Bridge & Iron 8 Reviewed Mason Johnston Freese & Nichols 6 Reviewed 13 Reviewed lh Bahnson 6 Reviewed 14 Reviewed 4 Total Number of Inspsetors Reviewed 268
)
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w__ __ ___. _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - --r
Revisicn: 1 Pass 45 of 138 ISAP I.d.1 (Cont'd)
V 5.0 IMPIEGNTATION OF ACTION PIAN AND DISCUSSION OF RE Results of the Phase I reviews were documented on ICES by the QA/QC Review Team and transmitted to TU Electric for further where Applicable. action and resolution of outstanding concerns, Specific concerns identified in validated DRs related to QC inspector certification were included in the ICES. The concerns identified during this portion of the work were similar in neture to those depicted in Actscheents 4 and 5.
During Phase I review of DRa, a problem regarding proper documentation of weld fit up, weld joint alignment, and finished joint inspections by Chicago Bridge & Iron (C8&I) was identified. These inspections were documented on a temporary form by the C8&I inspectors and the results transferred by a QA supervisor onto a permanent record.
The camporary forms were then destroyed and there was no record of who conducted the inspection nor the initial results of the inspection. QA/QC Program Deviation Report QA/QC FDR 7 was issued documenting the inspection record problem. Additional research including interview of a CB&I supervisor, was conducted by the QA/QC Review Team.
O A list of all inspectors was developed and the qualifications of these inspectors reviewed. It was decernined that they all had adequate qualifications to conduct the subject inspection. Based on the qualifications of the personnel, the C8&I procedures, and the interview, it was concluded by the QA/QC Review Team that the required inspections were conducted by personnel who were adequately qualified to perform the work.
5.3.2 Phase II As for the original I.d.1 scope of work, the objective of Phase II for this portion of the work was to evaluate qualifications further that could not be verified in Phase I and, based on the results of that evaluation, determine which III.
inspectors required further evaluation during Phass Upon receipt of the ICES from the QA/QC Review Team, TU Electric conducted additional investigations of the identified concerns and provided written responses to these concerns along with,any additional relevant information which might be useful in resolving the concerns. After receiving TU Electric responses to O
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(Cont'd) 5.0 IM D ATION OF ACTION P W AND DISCUSSION OF RESU concerns regarding the QC inspectors, the Issus
. Coordinator or the Deputy Review Tess Leader reviewed the ICES to determine which inspectors were acceptable and which.; inspectors required further evaluation in Phase III.
Of the total of 260 inspectors reviewed during Phase II, 234 were determined to have acceptable qualifications at the completion of the Phase II process. Table 9 categorizes the 26 inspectors that were placed into Phase III during this portion of the work as a result of Phase II evaluations.
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ISAP I.d.1 (Cont'd) 5.0 IMPIJKdNTATION OF ACTION FIAN AND DISCUSSION OF RE
- TABI2 9 l l QC INSFECTORS FIACED INTO FHASE III ~
RELATED ISAPs
{
Inspector Certification ;
Number to Phase III TU Electric Historical QC Inspectors Electrical Mechanical 0
- 9 Civil 0
Brown & Root Historical QC Inspectors Kochanical ~
- 7 Civil 0
Subcontractor QC Inspectors
] -
R. W. Hunt Chicago Bridge & Iron 1 0
Mason Johnston 0
Freese & Nichols 0 Bahnson 9
Total Number of QC Inspectors to Phase III 26 F
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u Roviolen: 1 Pcgs 48 of 138 REsUt.Ts REPORT ISAP I.d.1 (Cone'd) 5.0 IMFIRENTATION OF ACTION PLAN AND DISCUSSION OF RESUI.TS Attachment was placed 10 intoprovides Phase III. descriptions of why each inspector
' However, the reasons may be susunarized as follows:
Insufficient experience 13 Insufficient education -
6 Insufficient experience and education - 3 Failed exam - 2 Questionable work - 1 5.3.3 Phase III N objective and methodology for conducting Phase III evaluations for this portion of the work was identical to that described in Section 5.2.3 of this Results Report. -
h following fearagraphs susanarises the results of the Phase III evaluations which have been categorized in a manner idet.cical to those for the original I.d.1 scope of work.
TU Electric Historicel Mech =ical OC Inspectors Nine TU Electric historical mechanical QC inspectors were referredofto portion thePhase work. III for further evaluation during this The detailed results of these Phase III evaluations are contained tu Attachment 11. The following table depicts the evaluation results for these inspectors.
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Paga 49 of *.38 1 RESUI.Ts REPORT ISAP I d.1 (Cont'd) 5.0 1MPLINENTATION OF ACTION PIAN AND DISCUSSION OF R TM u lo TU Electric Historical Mechanical QC Insnector Thase III Evaluation Results INSPECTOR EVALUATION RESULTS TM 1 Acceptable TM 2 No Concern TM 3 TM 4 Substantial Positive TM 5 Substantial Positive Acceptable TM 6 Failed TM 7 Acceptable TM 8 No Concern TM 9 Indeteminate t Brown & Root His torical Mechanical QC Inspectors Seven Brown & Root historical mechanical QC inspectors t were placed into Phase III during this portion of the work.
l The detailed results of these evaluationa are described in Attachment 12. The following table depicts the evaluation results for these inspectors.
TABLE 11 Brown & Root Historical Mechanical QC Inspector Phase III Evaluation Results INSPECTOR EVAIEATION RESULTS BM 1 BM 2 Indeteminate BM 3 Substantial Positive BM 4 Indeteminate Failed BM 5 Failed BM 6 BM 7
- Substantial Positive
. Indeteminate O
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Revision: 1 l Pego 50 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) l l
4 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) j Subcontractor QC Inspectors A: total of. ten subcontractor QC inspectors were placed into Phase III during this portion of the work.
l Descriptions of the evaluations for these inspectors are contained in the following paragraphs.
HU 1, who was certified by R. W. Hunt as a concrete
- inspector in June 1976, was placed into Phase III because i
of lack of experience. He was identified during implementation of ISAP VII.c only because his signature, transmitting test data prepared by others, was nnotated with an indication that he was a I4 vel II inspector. This individual's actual job title was Administrative Assistant Manager and it appears, based on documentation identified during ISAP VII.c implementation, that he was not assigned responsibility for performing inspections. This was confirmed in an interview conducted with this individual by the QA/QC Review Team where he stated that he had not performed inspections during his employment at CPSES.
Based on this information there is no further concern regarding this individual's ability.
Nine Bahnson inspectors, who were responsible for conducting HVAC duct and duct support inspections, were placed into Phase III. BN 1 lacked adequate education and experience; BN-2, 3, 4, 5, 6, 7 and 9 lacked adequate experience; BN 8 lacked adequate education; and BN 4 had conducted questionable work while employed by Brown & Root (see BM-3) as a mechanical QC inspector. Because the Bahnson record system did not allow ready identification of inspections conducted by individual inspectors and because a major corrective action program was being developed to correct other significant problems, no reinspections of these inspectors work were conducted.
However, QA/QC PDR 45 was issued documenting the inadequacies of the certifications of these inspectors and requesting that these inadequacier, be factored into the overall corrective action program for Bahnson installed equipment.
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Summary of Phase III Results Associated with Related ISAPs Of,the nine TU Electric historical mechanical QC inspectors evaluated in Phase III, three were determined to be acceptable because the targeted number of reinspections were exceeded and the results were within the specified error limits. Two inspectors were deter.-tusd to be of no concern. For an additional two inspc.cors, there was a substantial amount of information available that they were capable of conducting the required inspection. The capability of one inspector was indeterminate based on the lack of recreatable inspections and computer data base inaccuracies. One inspector failed when the reinspection results for instrumentation inspections and tubing welding inspection fell outside the acceptable error rate limits.
Of the seven Brown & Root historical mechanical QC inspectors placed into Phase III, there was a substantial amount of positive information for two inspectors, indicating that they were capable of conducting the required inspections. Three inspectors' capabilities were indeterminate based on the lack of recreatable inspections and computer data base inaccuracies. Two inspectors failed because of reinspection results falling outside ISAP I.d.1 specified limits.
Of the ten subcontractor QC inspectors placed into Phase III, one inspector was identified es being of no concern because he did not conduct inspections. The remaining nine inspectors were from Bahnson and, because inspections conducted by individual inspectors could not be easily fdentified, no reinspections were conducted. A QA/QC program deviation, QA/QC PDR 45, was issued to document the Bahnson certification inadequacies.
Three other QA/QC program deviations were issued as a result of Phase III activities for this portion of the work. QA/QC PDR 79 was issued as a result of questionable resolution of TU Electric and Brown & Root identified concerns regarding the adequacy of QC inspector certifications for QC inspectors TM 6, EM-1, and BM 3.
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Two other QA/QC program deviations, similar to each other, were issued. QA/QC PDR 81 was issued when six inspections of: welds on electrical equipment supports conducted by BM 3 and BM 7 could not be reinspected because no original inspection acceptance criteria could be identified. In addition, QA/QC PDR 80 was issued when inadequate acceptance criteria for inspection of cable tray welds, for inspections conducted by the same two inspectors, were also identified.
5.4 Evaluation of QA/QC Proaram Deviations A total of seven QA/QC program deviations were issued during the implementation of this ISAP. Each of these PDRs was evaluated by the QA/QC Review Team to determine if it should be classified as a QA/QC program deficiency. A QA/QC program deviation is classified as a QA/QC progras deficiency if it meets one or both of the following criteria:
Inadequacy of a QA/QC progras element such that substantive revision of the program or other corrective O action is required to bring it into compliance with the regulatory requirements, FSAR couaitments, or other licensing couaiteents; or Extensive evaluation is required to determine the effect on the quality of construction.
The following are descriptions of the results of these evaluations.
5.4.1 QA/QC PDR 56 This PDR was issued to document the NDE exclusion probles that is described in detail in Section 5.2.3 of this Results Report. In susmary, three electrical inspection procedures for conduit, cable tray, and cable tray hangers contained requirements for visual inspection of welding during the time period between December 1978 and December 1979. The procedures did not clearly specify that welding inspections were only to be conducted by inspectors certified to inspect AWS welds. During this same period of time, electrical inspectors were trained and certified to these procedures but were not trained and certified to O
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Revision: 1 Pcgo 53 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) conduct the weld inspections. During Phase III evaluations, five instances were identified where welds were inspected by inspectors who had not been trained and
~
certified to conduct veld inspections per AWS requirements.
An evaluation was conducted by the QA/QC Review Team to !
determine if this deviation shocid be classified as a ,
QA/QC program deficiency. Based on the small number of I occurrences of problems, and the low probability of a major problem remaining undetected, it was concluded that neither an extensive evaluation nor extensive corrective action would be required. As a result, the PDR remained classified as a QA/QC program deviation. PDR 56 requests TU Electric to conduct.an evaluation of the potential impact of this problem on the hardware.
5.4.2 QA/QC PDR 70 QA/QC Program Deviation Report PDR-70 was evaluated by the QA/QC Review Team to determine if it should be classified as a QA/QC jaogram deficiency. This daviation, involving W
inspector IC-1, documenced the lack of definitive requirements relating to identification of instrumentation supports. Because use of proper material had been previously verified by QC during fabrication of the support, this identification problem is not related to the adequacy of support material, nor is it indicative of any actual problem with the ability of the instrumentation supports to perform their function. Therefore, it was determined by of the QA/QC Review Team that neither ar extensive evaluation nor extensive corrective action was required, and PDR 70 remained classified as a QA/QC program deviation.
5.4.3 QA/QC PDR-7 QA/QC PDR 7 was issued to document that C&&I destroyed temporary forms that documented weld fit-up, weld joint alignment, and finished joint inspection. As a result, there were no records of who conducted the inspections nir the results of the initial inspectiot.s. The QA/QC Review Team identified all the inspectors who had conducted tnese
)
inspections and determined that they were all adequately O
Revision: 1 Pcgs 54 of 138 RESULTS REPORT
! ISAP I.d.1 l (Cont'd) 5.0 IMPLDGNIATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) qualified to conduct these inspections. Because neither extensive corrective action nor extensive evaluation to determine hardware impact was required, QA/QC PDR 7 remained classified as a QA/QC program deviation.
5.4.4 QA/QC.PDR 79 QA/QC PDR 79 was issued as a resuit of questionable resolution of the adequacy of QC inspector certifications for QC inspectors TM 6, BM 1, and BM 3. In these cases and in others, when reinspection of work done by inspectors with questionable capabilities was conducted by TU Electric and Brown & Root, documentation of these reinspections was incomplete. In addition, proper consideration of data base inaccuracies in identifying the original inspections was not made by TU Electric. At times, problems with individual inspectors would be documented on NCRs and at other times, documentation was in the form of menos. The QA/QC Review Taas determined that QA/QC PDR-79 was a QA/QC program deficiency because of the rather extensive evaluations that will be required of TU Electric to verify that problems with QC inspector's capabilities were satisfactorily resolved, thus eliminating concern regarding th< inpact of this problem on the adequacy of construction.
5.4.5 QA/QC-PDR 30, 81 Two QA/QC program deviations, similar to each other, were issued. QA/QC PDR-81 was issued when six inspections of welds on electrical equipment supports conducted by BM 3 and BM 7 could not be reinspected because no original inspection acceptance criteria could be identified. In addition QA/QC PDR 80 was issued when inadequate acceptance criteria for inspection of cable tray welds, for inspections conducted by the same two inspectors, were also identified. Both QA/QC PDR 80 and 81 were determined to be QA/QC program deficiencies by the QA/QC Review Team because of the likelihood of rather extensive evaluations being required to determine the impact on the adequacy of construction.
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R visien: 1 Pego 55 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) 5.4.6 QA/QC-PDR 45 This PDR documented specific certification discrepancies for nine Bahnson inspectors, along with certain etreification procedure inadequacies. Normal Phase III evaluations of these inspectors were not conducted because inspections conducted by individual inspectors could not be easily identified. The QA/QC Review Team determined that this FDR was a QA/QC program deficiency because an extensive evaluation was required to determine the effect of the problems on the quality of construction. The root cause/ generic implication analysis of this QA/QC program deficiency is discussed in Section 5.8 of this Results Report.
The root cause/ generic implication analyses for QA/QC-PDR 79, 80, 81, and 45 are discussed in Section 5.8 of this Results Report.
5.5 Other Actions Conducted 5.5.1 The QA/QC Review Team reviewed the current Brown & Root QC inspector certification procedures to verify that they ade.tuately address ANSI N45.2.6 and Regulatory Guide 1.58 as invoked by the FSt.R. The following procedures were revisved:
CP-QAP 2.1, Revision 13. "Personnel Training and Qualification," dated F6bruary 18, 1986 QI-QAP 2.1 5, Revision 9 "Training and Certification of Mechanical Inspection Personnel," dated November 20, 1985 including Document Change Notice numbers 2, 3, and 4 QI-QAP 2.1-1, Revision 7, "Nondestructive Examination Personnel Certification," dated November 20, 1985, including Document Change Notice number 1.
QI-QAP 2.1-1, in conjunction with CP-QAP 2.1, covers qualification of Brown & Root NDE inspectors. These procedures were reviewed,and determined to address the requirements of ASNT SNT TC-1A, 1980 satisfactorily.
QI-QAP 2.1 5, in conjunction with CP-QAP 2.1, covers 9
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Rsvision: 1 Pego $6 of 138 RESULTS REPORT ISAP I.d.1 (j (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) qualification of Brown & Root mechanical inspectors. .
These procedures were reviewed and determined to address the requirements of ANSI N45.2.6 1978 and USNRC Regulatory Cuide 1.58, Revision 1 satisfactorily.
5.5.2 Qualification Records System Review During 1985, an internal action was undertaken by TU Electric to improve their QC inspector qualification records system and procedures. This action was related to but separate fron the actions prescribed in ISAPs I.d.1 and I d.2. -
T'J Electric acquired an experienced training specialist to coordinate this effort. The primary output of this effort was the issuance in August 1985 of QI-QP-2.123, "Training / Certification Records Processing." This procedure provided requirements for the review, proper access, control, safekeeping, and preservation of training / certification records. QI-QP 2.1 23 was reviewed and evaluated as satisft: tory by the QA/QC Review Team O during implementation of ISAP I.d.2. The files of :urrent active inspectors were revised and upgraded by TU Electric to comply with QI-QP 2.1 23. In addition, generic DR
- C87 01137 was issued by TU Electric to document record problems in inactive training / certification files, and an ongoing effort is underway to put these files in order.
5.6 Overall Summary of Results Of the 148 TU Electric historical QC inspectors reviewed during Phase I and II, 31 were referred to Phase III for further examination. The Phase III evaluaticns determined that 17 of these 31 were acceptable, of no concern, or were in Phase III only because of the NDE exclusion problem. For an additional five inspectors, there was a substantial amount of positive information that they were capable of conducting the required inspections or hs.d not performed inspections in the area of concern. For the remaining nine inspectors, seven were indeterminate because of the lack of recreatable inspections and two failed based on reinspection results.
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ISAP I.d.1 '
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
A total of 169 TU Electric current QC inspectors was reviewed, and 4'9 were placed into Phase III for further evaluation.
Sixteen vere determined to be acceptable, of no concern, or were in Phase-III'only because of the NDE exclusion problem. There was a substantial amount of positive information that two inspectors were capable of conducting the required inspections.
One inspector's capability was indeterminate because of the lack of recreatable inspections.
Of the 153 Brown & Root historical QC inspectors evaluated, 7 were referred to Phase III. For two inspectors, there was a substantial amount of positive information available that they were capable of conducting the required inspections. Three inspectors' capabilities were indeterminate and two inspectors failed based on reinspection results.
Seventy Brown & Root current QC inspectors were also evaluated with the result that two inspectors were placed into Phase III.
These two inspectors were determined to be of no concern because of other factors.
Table 12 summarizes the results of the evaluation of TU Electric and Brown & Root QC inspectors described above.
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O (Cont'd) 5.0 ' IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
, TMu l2 OVERALL
SUMMARY
OF ISAP I.d.1 EVALUATION RESULTS Percent Percent Acceptable Substantial Number Number to or no Group Positive Percent ?ercent Evaluated Phase III Concern Information Indeterminate Failed
- 1. TU Electric 148 31 90.5% 3.4% 4.7%
Historical 1.4%
- 2. TU Electric *169 19 98.2% 1.2% 0.6% --
Current
- 3. Brown & Root 153 7 95.4% 1.3% 2.0% 1.3%
Historical
- 4. Brown & Root 70 2 1004 -- - --
( Current
- 5. Total *540 59 95.64 1,74 2.04 0.7%
Personnel Certified
- NOTE -
The 169 Current TU Electric and the 540 Total Personnel Certified include 34 Brown & Root QC inspectors who were also certifisd under TU Electric's certification program to inspect Hilti Bolts.
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A total of 47 subcontractor QC inspectors were evaluated in Phase I and II. Of these 47, 10 were placed into Phase III for further
. evaluation. One of the ten was an R. W. Hunt QC inspector who was determined to be of no concern because he did not conduct inspections. The remaining nine inspectors were from Bahnson.
Concerns regarding the certifications of these nine inspectors were documented in a QA/QC program deficiency which will be addressed by TU Electric in their Corrective Action Program to resolve concerns in the overall work conducted by Bahnson. No subcontractor QC inspectors from CB&I, Mason Johnston, or Freese
& Nichols required Phase III evaluations.
As could be expected, a higher incidence of problems that required Phase III evaluations occurred in the TU Electric and Brown & Root historical QC inspector grcupings. Problems with TU Electric QC inspectors particularly in the hiatorical electrical QC inspector groupings, were more prevalent, on a percentage basis, than for Brown & Root. The four inspeccors who failed Phase III based on reinspection results were all in the historical QC inspector groupings, two from TU Electric and two from Brown & Root. Of the seven indeterminate inspectors, only one TU Electric QC inspector fell into the current QC inspector groupings and the remainder were included in the historical QC inspector groupings.
5.7 Trend Analysis A total of 587 inspectors who were certified by T'J Electric, Brown & Root, and subcontractors were included in Phase i and Phase II evaluations associated with the original ISAP I.d.1 scope and related ISAPs. These evaluations determined that the qualifications of 69 inspectors required further evaluation in Phase III to determine whether, daspite deviations from qualification requiraments, they were capable of satisfactorily conducting inspections for which they were certified. The substantial number of inspectors failing the Phase II evaluations is considered to constitute a trend. This trend can be further depicted by organizations as follows:
TOTAL NUMBER TO PERCENT TO ORGANIZATION EVALUATED PRASE III PRASE III TU Electric 317 50 15.8%
Brown & Root 223 9 4.04 Subcontractors 47 10 21.3%
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V (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
The following sections describe the results of the trend analyses for TU Electric, Brown & Root, and the subcontractors:
5.7.1 TU Electric A total of 50 TU Electric QC inspectors, out of 317 evaluated, were placed into Phase III. Of these 50 inspectors, 40 were evaluated in Phase III to be acceptable, of no concern, or there was substantial positive information that they were capable of performing the required inspections. Two inspectors failed but the root cause analyses, contained in Section 5.8, indicated that only one of the two failed inspectors is cause for concern. Eight of the 50 inspectors who were evaluated in Phase III were indeterminate because of the lack of recreatable inspections. Six of the eight indeterminate inspectors wsre historical electrical inspectors, one was a historical mechanical inspector, and one was a current mechanical inspector.
Five of the six indeterminate electrical inspectors conducted a substantial number of cable pulling O inspections. Most of the important attributes related to cable pulling are nonrecreatable. For example, checking that the raceways were free of cable pulling hazards, verification that conduit raceways were swabbed, verification of cable lubricant type, and verification of pull tension are all important attributes that ensure cables are not damaged during the installation process and that are not recreatable. Althou8h subsequent testing (i.e., meggering) provides some information regarding damage, some problems (attributable :o damage) may not be detectable or occur until sometime later during the operation of the station. ISAP VII.c placed substantial reliance on the inspection documentation for cable installation. Based on the lack of reinspection information, the quantity of indeterminate inspectors, and the substantial lack of experience of these indeterminata inspectors, a concern remains regarding the adequacy of the cable installation inspections. Thus, these indeterminate electrical inspectors constitute an unclassified trend and a root cause/ generic implication analysis i, included in Section 5.8 of this Results Report.
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As stated above, only two of the 317 TU Electric inspectors were determined to have failed Phase III evaluation, and only one of the two was determined to have questionable capabilities to conduct inspections properly.
The overall ~ combined error rate for these two inspectors was 5.79% compared with an overall error rate of 2.574 for the remaining TU Electric Phase III inspectors. A review of the nonconformances that were identified during the reinspections of the two failed inspectors was conducted by the QA/QC Review Team. No previously unidentified type of construction deficiencies, unclassified deviations, adverse or unclassified trends were found during this review of the nonconformances. There were three nonconformances identified, all out of-scope ol che original inspection requirements, that were l'.P.aly to hcve been categorized as construction deficiencies. Two of these deficiencies involved loose conductor terminations on terminal blocks and one involved cracked Weidauller terminal blocks. Because these deficiencies were outside the scope of the original inspection requirements they were not counted as inspection errors. In addition, ISAP VII.c had identified similar problems and corrective action was already underway that would have corrected these deficiencies. None of the other nonconformances were of concern nor were they related to existing CPRT findings.
It is concluded that no adverse trend exists regarding the remaining TU Electric QC inspectors who were placed into Phase III. This conclusion is based on the following considerations :
- 1. Eighty percent of the TU Electric QC inspectors placed into Phase III were determined to be acceptable, no concern, or there was a substantial amount of positive information indicating that they were capable of conducting required inspections.
- 2. The overall error rate of TU Electric inspectors placed into Phase III, including the failed inspectors, was 2.934. This is not l substantially higher than the overril deviation l rates identified during implementation of ISAP VII.'c, particularly considering that the ISAP I.d.1 methodology, which considers small O
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- 3. While the overall error rates of the two failed inspectors were somewhat larger than the error rates for the other Phase III inspectors, the majority of the errors made by the failed inspectors were paperwork errors that did not translate into hardware concerns. For inspector TM 6, where there was actual hardware concern, a contributing factor to the poor performance vss unclear, insdequate, and difficult-to use inspection requirements.
4 The majority (584) of the TU Electric QC incpectors placed into Phase III were electrical inspectors. All 111 Electric electrical inspectors were evaluated during implementation
- of this ISAP. There are no additional evaluations to be done in this area.
Except for the area of cable installation, the reinspection results, as summarized above, provide adequate positive information to conclude that additional evaluations of tha indeterminate and re.saining unevaluated l TU Electric QC inspectors are not warranted. Additional l engineering evaluation of the area of cable installation is warranted and is discussed further in Sections 5.8 and 6.0.
l 5.7.2 Brown & Root A total of nine Brown & Root QC inspectors, out of 223 evaluated, were placed into Phase III. Of these nine inspectors, four were evaluated in Phase III to be acceptable, of no concern, or there was substantial positive information that they were capable of performing the required inspections. Two inspectors failed but the root cause analyces, contained in Section 5.8, indicated that only one of the two failed inspectors is cause for
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concern. Three of the nine inspectors placed into Phase III were indet,erminate because of the lack of recreatable inspections.
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Two of the indeterminate inspectors, BM 1 and BM 3, had previously been identified by Brown & Root and TU Electric i
1 as inspectors with questionable capabilities. Both had been evaluated but QA/QC PDR-79 was issued, in part, because of questions regarding the adequacy of thsse evaluations. The indeterminate status of those two inspectors should be resolved in conjunction with the resolution of QA/QC-PDR-79 by TU Electric. This will leave only one indeterminate inspector.
There was only a limited number of reinspections conducted during Phase III evaluations of the nine Brown & Root QC inspectors. The overall combined error races for the two failed inspectors, only one of whom is a concern, was 7.894. The overall error rate for the one additional QC inspector for whom reinspections were conducted was 1.3%.
A review of the nonconformances that were identified during the reinspections of the two failed inspectors was conducted. No previously unidentified construction deficiencies, unclassified deviations, adverse or unclassified trends were found during this review of the nonconformances. Three nonconformances were identified that were related to existing CPRT identified findings or ongoin5 TU Electric corrective actions. Two of these nonconformances involved improper clearances between pipes and supports and are related to an ISAP VII.c identifiod adverse trend for which reinspections are being conducted.
One nonconformance involved a cable tray hanger clamp that did not have full bearing. The cable tray hangers are being reinspected as part of an ongoing TU Electric corrective action program and the reinspections include attributes that would identify this type of problem. No effort was made to determine if these nonconformances were construction deficiencies because of the existence of l ongoing corrective action programs that have been established to resolve these type of generic problems.
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None of the other nonconformances were of concern nor were they related to existing CPRT findings,
! It is concluded that no adverse trend exists regarding Brown & Root QC inspectors placed into Phase III. This conclusivn is based on the following considerations:
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- 1. Only nine QC inspectors, or 4% of the total number of Brcts & Root QC inspectors evaluated, were placed into Phase III for evaluation. This is a much lower percentage than for TU Electric.
In addition, unlike TU Electric, where lack of experience was the primary cause for inclusion in Phase III, there was no clear pattern of causes for inspectors being placed into Phase III.
- 2. Two hundred and eighteen of the 223 Brown & Root QC inspectors evaluated (97.8%) were acceptable, of no concern, or there var a substantial amount of positive information available that they were capable of performing the required inspections.
- 3. Tha overall combined reinspection error rate for the three Brown & Root inspectors for whom reinspections were conducted was 6.554. These results appear to be consistent with the larger amount of reinspection results collected for the
' W Electric QC inspectors. While the overall error rates for the two failed Brown & Root QC inspectors were somewhat larger than the other TU Electric and Brown & Root QC inspectors placed into Phase III, a substantial amount of the errors were associated only with paperwork errors.
No additional evaluations of the remaining unevalucted Brown & Root QC inspectors are warranted based on toe results of this trend evaluation.
5.7.3 Subcontractors For subcontractor QC inspectors, problems were primarily related to Bahnson QC inspectors. Of the total of ten subcontractor inspectors placed into Phase III, nine were Bahnson inspectors and one, who was determined to be of no concern, was a R. W. Hunt inspector. Because a QA/QC program doficiency was prepared to address the Bahnson QC inspector certification problem, this area will not be included in this trend analysis. With regard to the O
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remaining subcontractors, no adverse trend is considered l to exist, based on only one inspector, wha was certified '
in the early stages of the Project in 1976, being placed into Phase III. This inspector conduct:ed no inspections.
The QA/QC program deviation reports that were issusd as c. result of the implementation of this ISAP were reviewed for trends.
Seven QA/QC program deviation reports were issued during the course of the work. Of the seven PDRs, four addressed procedure problems. Two of the four procedure problems were dett rained to be QA/QC program deficiencies. The root cause(s) of the problem of inadequate inspection procedures will be addressed in the Collective Evaluation Report. Two of the remaining three PDRs are QA/QC program deficiencies, which require root cause/ generic implication analyses. Therefore, no trending of these is required. The remaining PDR is restricted to an inspection record problem involving only CB&I and does not constitute a trend.
5.8 Root Cause and Generic Implication Analyses ISAP I d.1 requires root cause/ generic implication analyses to be conducted for all inspectors who failed Phase III evaluation. In addition, the CPRT Program Plan requires root cause/ generic implication analyses to be conducted for QA/QC program deficiencies and unclassified trends. The following paragraphs contain the root cause/ generic implication analyces for the four failed inspectors, four QA/QC program deficiencies, and one unclassified trend identified during implementation of this ISAP.
5.8.1 Inspector HE-8 Root Cause HE 8 failed Phase III evaluations primarily because of errors related to one attribute. The attribute in question required inspection of site-installed internals in electrical panels and boxes. The inspector marked this attribute "satisfactory" in many cases when there were no site installed internals. The overall result of these errors was that additional inspections were conducted of vendor supplied internals that were not required to be site-inspected. If this~one troublesome attribute were removed from the overall results, the inspector would have 9
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V) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESNLTS (Cont'd) fallen well within the required error limits. The exact root cause of the problem with the one attribute cannot be determined, but inexperience may have been a factor. A detailed description of the root cause analysis is contained in Attachment 13.
Generic Implications Based on the root cause analysis conducted for the Phase III failure of inspector HE 8, no further reinspections of this inspector's work are required. The failure was primarily related to one attribute. The errors related to this attribute resulted only in additional unrequired inspections being conducted which, in turn, had no adverse hardware impact.
Discounting thia problem attribute, HE 8 had a composite objective error rate of 1.364 and a composite subjective error rate of 0.004. These error rates fall well within the ISAP I.d.1 error rate limits.
() 5.8.2 Inspector TM 6 Root Cause A review of the reinspection results for this inspector indicates that the work evaluated consisted of Hilti bolt inspections, instrumentation inspections, and instrumentation tubing weld inspections. The following are the reinspection results for each of these types of inspections:
Objective Error Subjective Error Type Rate Rate Hilti Bolts 1.70t 3.384 Instrumentation 28.174 On Instrumentation Tubing Welds 7.234 On O
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
As stated earlier, the results of the Hilti bolt reinspections are satisfactory. The reinspection results for the instrumentation inspections indicated a 28.17%
disagr'eement rate. This was based on 40 disagreements out ;
of 142 objective decision points. Investigation indicated that 17 of these disagreements were against attributes that had been marked acceptable for which there were no defined acceptance criteria. These disagreements are not attributable to inspection error. They are procedural inadequacies. No QA/QC program deviation report was issued to document these procedural problems because TU Electric had already issued Stop Work Order 85 05 in October 1986. This Stop Work Order was issued because of inadequate installation and inspection criteria for instrumentation. Resolution of this overall TU Electric-identified problem will resolve the specific problems identified by the QA/QC Review Team. Of the remaining 23 disagreements, 10 were for marking attributes satisfactory that related to nonsafety-related items.
These attributes should have been marked not applicable (NA). The remaining 13 disagreements were spread among nine attributes, with the largest number against any one attribute being three. These all appear to be related to inspection error with no apparent pattern. These 13 disagreements alone are sufficient to fail the inspector in this area.
The reinspection results for the instrumentation cubing welds resulted in 106 disagreements out of 1,466 objective decision points. Ninety-three disagreements occurred because TM 6 had marked the attribute for veld reinforcement satisfactory when the welds that were being inspected were fillet welds. This attribute should have been marked NA. The weld inspection checklist that was being used was a general checklist that applied to both bute and fillet welds. TM 6 did mark other attributes on the checklist, such as backing strip and purge dam, as NA as should have been done. Based on data obtained from reinspection results on other inspectors, it was apparently common practice for TU Electric inspectors to check this attribute satisfactory for fillet welds.
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Of the remaining 13 disagreements, four wore for inspections for which the required inspection report (IR) was not prepared. Another three were for marking an at' tribute for inspection of flex tubing NA when flex tubing was installed. The remaining six disagreements were for referencing the incorrect revision of the inspection procedure on the inspection report.
The lack of education and experience of this inspector, when coupled with the inadequate and confusing TU Electric instrumentation inspection requirements, virtually guaranteed the failure of this inspector to meet ISAP I.d.1 reinspection acceptance criteria in this area. TM 6 was capable of conducting the less complex and better defined inspections of Hilti bolts. Also, for instrumentation tubing welds, the bulk of the errors involved incorrectly accepting one attribute that was not applicable. By far the majority of this inspector's problems involved failure to fill out paperwork properly and to comply with existing paperwork requirements. These
() errors can likely be attributed to lack of education and experience.
i The root causes of this inspector's failure are the lack of education and experierce and marginal and unclear inspection requirements.
Generic Implications Inspector TM 6 held TU Electric certifications for inspection of concrete anchor bolts, instrument tubing fabrication and instrument and tubing installation, and fabrication of instrument supports and rack assemblies.
, He also held Brown & Root certifications for liquid penetrant and visual weld examinations.
The root cause analysis indicates that the major area of hardware concern is this inspector's lack of capability in the area of instrumentation inspections. These j inspections were complex and were guided by inspection requirements that were marginal, difficult to understand, and in areas, inadequate. However, inspector TM 6 may >
have made a hi,gher-than desirable number of inspection errors on more complex inspections, such as instrumentation supports. For less complex inspections, O
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TM 6 appears to have been capable of conducting required work adequately. The problems in the tubing veld inspection area are centered on one attribute that is not related to the acceptability of the hardware. The incorrect marking of this attribute appears to be a comron problem for TU Electric inspectors as it was apparently the practice to mark it satisfactory rather than NA. See Section 5.10 for further recommendations.
5.8.3 Inspector BM 4 Root Cause Inspector BM 4 failed the Phase III evaluation with a 9.51% objective attribute disagreement rate. A total of 50 reinspections, consisting of 610 objective decision points, were conducted. Fifty eight of the 610 decision points were in error. Although 32 of the 50 reinspections were of Hilti bolts, all 58 of the errors were associated with the 18 pipe support inspections. The errors were grouped as follows:
ll Attribute Number of Errors Undersized fillet welds 29 Location of support 14 Bolt hole location 8 Dimensions not per ISO 3 Base plate dimensions 3 Configuration of weep hole 1 It is concluded from the error grouping that weld inspection is an area of concern for this inspector. Weld reinspections were limited to size, length, and location.
Remaining weld reinspection attributes, such as slag, undercut, weld splatter, etc., were considered to be nonrecreatable because the welds were painted. The ability of this inspector to inspect these other veld inspection attributes properly is also questionable.
The errors related to support location require discussion.
Although information is currently available from which support location could be determined, the information apparently available to BM 4 at the time of the inspection did not contain this information. The supports that were 9
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[V t (Cont'd) 3.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) reinspected were correctly located. Under the circumstances, it may be appropriate to discount these 14 errors. However, even when discounting them, this inspector still fails. The remaining errors all involved the inspector's failure to verify the overall ]
configuration of the support to the drawing requirements properly.
The supports that were reinspected were classified as ASME Class 3. At TU Electric's request, no further reinspections of pipe supports inspected by BM-4 were conducted because of the Hardwaro Validation Program (HVP) then being developed.
Based on the above analysis, it is concluded that this inspector was not capable of inspecting pipe supports properly. In particular, his ability to inspect velds does not appear to be adequate. No problems were identified regarding this inspector's ability to inspect Hilti bolts. No clear cause for the identified lack of ability can be determined. However, pipe support p(f inspections are complex inspections and BM 4's lack of formal education could possibly have been a hindrance to his ability to conduct the work properly.
Generic Implications Inspector BM 4 held Brown & Root certifications for visual examination of welds (ASME and AWS), mechanical installation and fabrication inspection (MIFI), liquid penetrant examination, concrete anchor bolt inspection (CEI-20), and vacuum box leak testing. He also held a TU Electric certification for inspection of concreta anchor bolts (QI-QP ll.2).
The TU Electric computer data base shows only ASME pipe support inspections having been conducted by this inspector until his termination date of September 1980.
As mentioned earlier, ISAP I.d.1 reinspections were terminated at the request of TU Electric because they expected the HVP that was under development to address any problems. This corrective action program will resolve all concerns regarding pipe support inspections with one exception. Review of the HVP indicates that veld
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' reinspections under this program are limited. The HVP requires reinspection of welds only for length, location, an'd cracking. Other attributes, specifically veld size, are not included in the HVP. There is a possibility that undersized welds in pipe supports originally inspected by BM 4 may exist, even after completion of the HVP. Other veld problems, such as slag, undercut, etc., could also possibly exist because of uncertainty regarding this inspector's capability to conduct veld inspections. Based on Phase III results, the certifications likely to be of most concern are visual velding certification and the MIFI certification. Although the computer data base was reasonably accurate during the time period in question, some errors could still exist and inspections conducted by this inspector may not be identified in the data base. .TU Electric did conduct a manual record search for Unit i except for ASME pipe supports and no additional inspections were iden ified.
The generic implications extend to all weld inspections performed by this inspector. The HVP addresses only three weld attributes, with reinspections through coatings, for Unit 1 and Common. Additional evaluacions beyond the HVP will be required to address the generic implications. See Section 5.10 for further recommendations.
5.8.4 Inspector BM 5 Root Cause The 78 pipe veld inspections that were reinspected for this inspector were all of socket welds. Out of 936 decision points, there were 78 objective disagreements.
All 78 disagreements were for marking the attribute for weld reinforcement satisfactory rather than NA for fillet velds. This same situation occurred for inspector IM 6 and as well as other inspectors identified dur%g I.d.1 evaluations. No other disagreements, either objective or subjective, were identified during the reinspections for thin inspector.
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Ceneric Implication i The practice of marking reinforcement satisfactory rather than NA on the generic weld inspection checklist appears I to be common for TU Electric weld inspectors. Other attributes that are clearly not applicable were marked NA.
It is concluded that this practice had no potential for negativa impact on the hardware. Fillet veld sizes, based on reinspection results, were adequately inspected.
5.8.5 QA/QC PDR 79 Root Cause This PDR identified ther following conditions with regard to previous TU Electric and Brown & Root efforts to resolve concerns regarding QC inspector qualifications:
- 1. Problems were sometimes. documented on NCRs and other times were documented by internal menos.
- 2. Reinspection results were not fully documented and, in one instance, either were not done or were incorrect.
- 3. The computer data base was utilized to identify inspections where 1004 reinspection had been determined to be required. However, this data base is incomplete.
Based on the varying methods that were used to evaluate and resolve similar problems, the root cause of the first two conditions is that no clear policy or set of guidelines existed on how such problems should be resolved. Although use of the nonconformance system was one means of resolving these type of concerns, it was not a requirement that this system be utilized for these concerns. Whether such problems were handled under a formal nonconformance system or by evaluations outside the nonconformance system, the investigations and results of these investigations rhould have been clearly documented.
The problem regarding utilization of the data base by Quality Assura,nce Group personnel can be attributed to O
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' involved in the resolution of QC inspector problems were not responsible for the data base and, in general, had no reason to suspect that it was inaccurate.
Generic Implications It is possible that some of the past evaluations and dispositions conducted for suspect QC inspectors from TU Electric and Brown & Root are inadequate and that hardware that should have been reinspected as part of the evaluations / dispositions was not reinspected. See Section 5.9 for recommended corrective action.
5.8.6 QA/QC PDR-80, 81 These PDRs document inadequate inspection procedures and inadequate acce.ptance criteria for inspection of cable tray welds and welds on electrical equipment supports.
Because a number of inadequate inspection procedures were identified during implementation of other CPRT activities, the root cause/ generic implications of these inadequate procedures are being determined during the Collective Evaluation process. Therefore, these two PDRs have been referred to Collective Evaluation and will be included in the root csnse/ generic implication analyses reported in the CPRT Collective Evaluation Report.
5.8.7 QA/QC-PDR 45 l
Root Cause This PDR documents problems with the certifications of Bahnson QC inspectors and with the Bahnson QC inspector certification program. In addition to the problems regarding individual QC inspector certifications and certification program inadequacies noted in this PDR, implementation of ISAP VII.c identified deviations during reinspections that rese~ted in an unclassified trend. The root cause analysis for this unclassified trend of hardware deviations was determined to be a less than-adequate development and implementation of an overall KVAC program to ensure that HVAC supports were installed in accordance with design requirements. The QC inspector certification problems formed a portion of this overall program problem.
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Because TU Electric made a decision to terminate Bahnson services in early 1987, this root cause analysis will concentrate only on why TU Electric. failed to identify the overall Bahnson problems, including the inspector certification problem, rather than on determining what the specific internal causes were within the Bahnson organization. ,
A detailed description of the history of Bahnson program problems and the root cause analysis is contained in Attachment 14 In summary, the probable root cause of why TU Electric did not identify and correct Bahnson problems in a timely fashion was the failure of previous TU Electric QA management to ensure that Bahnson was i
' implementing an effective QA program. This occurred because TU Electric had not established an effective subcontractor monitoring program that would identify and correct subcontractor problems in a timely fashion. In addition, previous TU Electric QA management failed to identify the seriousness of the Bahnson problems that had been identified. There were a number of aajor contributors to this root cause as follows: -
TU Electric did not conduct ongoing QA surveillances of Bahnson activities for an extended period of time (1980 1984). Industry experience has shown that an ongoing, day to day QA surveillance program with hes.vy emphasis on hardware related activities is desirable, if not necessary, to supplement QA audit programs. '
There was not an effective interface between the Engineer and Bahnson in that no effective review l of Bahnson installation drawings to verify they i
met the design intent was conducted. Had such a t review been conducted by the Engineer, many '
problems would likely have been eliminated. '
There was a change over of responsibility for 't overall control of Bahnson from Brown & Root to TU Electric which occurred in 1980 and resulted ,
in a failure to continue to identify, pursue, '
ar.d resolve Bahnson problems.
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There was a poor interface between TU Electric's site QA organization and the Dallas QA organization. This resulted in a lack of coordination of resolution of problems identified during procedure reviews conducted by Site QA and audits conducted by Dallas QA.
Generic Implications The potential generic implication of this QA/QC program deficiency is that problems relating to site subcontractors, other than Bahnson, may have gone undetected by TU Electric. This implication is more appropriately addressed by the CPRT Collective Evaluation process and has been referred to Collective Evaluation for resolution. See Section 5.9 for recommendations for correction of this specific problem.
5.8.8 Unclassified Trend for Indeterminate TU Electric QC Inspectors Conducting Cable Pulling Inspections Root Cause A substantial percentage (15.8%) of TU Electric QC inspectors evaluated during implementation of this ISAP were placed into Phase III. Over half (584) of these inspectors that were placed into Phase III were electrical inspectors. A substantial amount of information regarding the reet-cause of the prob 1was that resulted in TU Electric electrical inspectors bein5 placed into Phase III can be obtained from the ISAP I.d.2 Results Report. That Results Report identifies vaaknesses in the TU Electric certification procedures that would be likely to lead to the types of problems found in the qualifications of Phase III inspectors. For example, of the 50 TU Electric QC inspectors placed into Phase III, lack of experience was a l
cause or one of the causes for inspectors being placed into Phase III in 27 cases. Prior to August 1985, the TU Electric procedures generally gave only guidelines for experience rather than specifying minimum requirements or specific alternates to the recommended experience levels.
This inevitably led to a lack of consistency in decisions on the acceptability of individuals being made by different persons. Thus, a sizable number of TU Electric
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) ISAP I.d.1 l
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N,s (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cent'd) inspectors were placed in Phase III based on lack of experience because no definitive set of requirements were utilized in determining what was an acceptable level of experience.
The root cause of the unclassified trend for indeterminate TU Electric QC inspectors conducting cable pulling inspections is inadequate QC inspector certification procedures.
Generic Implications Because extensive reinspection results were available for TU Electric QC inspectors who conducted other types of inspections and because these results were generally satisfactory, the area of concern regarding indeterminate inspectors is limited to the area of cabla pulling. The combination of a substantial number of indeterminate inspectors and the heavy reliance of ISAP VII.c on the documentation produced by some of these same inspectors O does not provide adequate information to conclude that cable installation at CPSES was always properly conducted ;
without cable damage that m1 5 ht result in later hardware problems. See Section 5.9 for recommended corrective action.
5.9 Recommended Corrective Action Based on the results of the ISAP I.d.1 evaluations described in previous sections of this report and requirements of Appendices E '
and H of the CPRT Program Plan, the following recommendations for additional corrective action have been identified: -
! 1. QA/QC PDR 79 documented problems regarding the proper resolution of problems identified by TU Electric and Brown
& Root involving QC inspectors. It is recommended that TU f Electric review inspector certification files to identify .
cases where these problems occurred and evaluate these !
cases to verify that they were properly resolved. All ,
cases identified should be evaluated considerir; the following points:
Doek adequate documentation of the resolution of
, the problem exist?
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Vere reinspections, where conducted, adequace?
Was proper consideration given in the disposition to computer data base inaccuracies?
It is also recommended that TU Electric develop additional policies or guidelines to ensure that any future QC inspector performance inadequacies are resolved in a consistent manner with adequate technical reviews and documentation.
- 2. QA/QC PDR 80 identified inadequate procedures for inspection of cable tray velds. Specifically, weld inspection attributes such as size, length, and location were not specified and.for a one month period, there were no criteria for veld inspection. TU Electric should investigate this probles to determine the length of time that it existed and the possible impact of the inadequacies on the acceptability of installed cable tray.
- 3. QA/QC PDR 81 identified six welding inspections of electrical equipment supports for which there are no criteria for veld inspection. TU Electric should investigate to determine the extent that inspections in this area may have been conducted without appropriate inspection criteria and what impact this practice may have had on the equipment.
- 4. QA/QC-PDR 45 identified that a number of Bahnson inspectors were not properly certified and identified problems in the Bahnson inspector certification program.
TU Electric should conduct an evaluation, considering corrective action programs planned and underway, for evaluating the impact on the Bahnson installed equipment of the inspectors with questionable qualifications. The overall impact of the discrepancies in the inspector certification program should also be considered during this evaluation. TU Electric should also verify that their current QA program is adequate to control site contractors in accordance with 10CFR50, Appendix B and FSAR requirements and is adequate and to preclude the repetition of similar problems with other site contractors. *.
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, 5. TU Electric should conduct additional evaluations to determine the impact, if any, of the unclassified trend l for indeterminately qualified TU Electric QC inspectors conducting cable pulling inspections on the adequacy of installed electrical cable.
5.10 Recommendations for Improvement A number of QA/QC program deviations were identified during implementation of this ISAP that were judged by the QA/QC Review Team to not be QA/QC program deficiencies. In addition, the failure of inspectors TM 6 and BM 4 to pass the ISAP I.d.1 Phase III acceptance criteria was determined not to be a QA/QC program deficiency, adverse trend, or construction deficiency. '
Never the-less, based on the understanding of these deviations that resulted from the QA/QC Review Team evaluations, the recommendations for improvement are made. l
- 1. It is recommended that TU Electric take further action to resolve hardware concerns related to possible acceptance of unsatisfactory work by inspectors TM 6 and BM 4. Root A cause/ generic implication analysis indicates that there is no concern regarding hardware for the two remaining failed inspectors, HE 8 and BM 5. The following are additional details regarding this recommendation for TM 6 and BM 4:
- TM 6 The TU Electric resolution should consider the following factors:
1
- 1) The root cause/ generic implication analysis indicates TM 6 had difficulty j
vich complex inspections, but was capable of conducting simple.
l reasonably well defined inspections tasks.
! 2) The planned corrective action for instrumentation should be reviewed by ,
TU Electric to assure that it resolves l procedural inadequacies typical of l l
- those identified during the root cause i analysis for TM 6.
G
. - - - - - - --------r-- ,- - - -,--- - , , - , - , . - , - - - - - - -
1 R:visien: 1 Page 79 of 138
_RESULTS REPORT ISAP I.d.1 (Cont'd) j 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
- 3) Because of data base inaccuracies, some inspections conducted by TM 6 may not be identified.
BM 4 The TU Electric resolution should consider the following factors:
- 1) The HVP does not cover veld size or veld quality, areas for which BM 4 was found unsatisfactory or questionable.
- 2) Because of data base inaccuracies, some inspections conducted by BM 4 may not be identified.
- 2. QA/QC-PDR 56 identified the fact that a small number of visual veld inspections were conducted by unqualified inspectors. The periods of time and inspection procedures in question are identified in Section 5.2.3, Summary of Phase III Results, of this Results Report and in the PDR.
It is recommended that TU Electric evaluate the impact, if any, of this problem in the identified areas and time frames to determine if additional action is required.
Consideration should be given to possible data base inaccuracies and to any evaluations and corrective action programs planned or underway when conducting this evaluation.
3.
QA/QC-PDR 70 identified the fact that there was a lack of definitive requirements specified regarding marking, inspection and recording of marking of instrumentation supports. Based on the lack of definitive requirements and apparent informal pra.ctices that evolved in this area, it is recommended that TU Electric evaluate and determine whether past practices regarding instrumentation marking and documentation were adequate for installed instrumentation supports.
- 4. QA/QC PDR 7 identified a lack of CB&I records documenting inspection of weld fit up, alignment, and final visual inspection. le is recommended that TU Electric, in conjunction with the recommended action for QA/QC PDR 45, O
?
Rsvision: 1 Page 80 of 138 RESULTS REPORT C, ISAP I.d.1 (Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) ensure that their current system for control of site contractors is adequate to prevent similar problema from occurring.
6.0 CONCLUSION
S The following conclusions have been reached as a result of the implementation of this Action Plan:
The evaluation confirmed the validity of the NRC issues identified in NUREC 0797, Supplement 7, Page J 110.
The ongoing Brown & Root QC inspector certification program as defined in the procedures referenced in Section 5.5.1 of this Results Report is satisfactory. The ongoing TU Electric QC inspector certification program has previously been evaluated and found satisfactory as described in the ISAP I.d.2 Results Report.
The TU Electric QC inspector certification program, particularly O the historical electrical QC certification portion, produced a substantial number of inspectors who were certified with questionable qualifications. The TU Electric QC inspector certification program improved over time as illustrated by the fact that initially, 93.94 of TU Electric historical QC inspectors were acceptabis, of no concern, or there was substantial positive information that they were qualified. This figure increased to 99.44 for TU Electric current QC inspectors.
l A similar similar improving situation existed for Brown & Root.
However, the Brown & Root program never produced as high a
- percentage of inspectors with questionabis certifications as the TU Electric program. This can be attributed to the following factors
- 1) The Brown & Root QC inspector certification procedures were reasonably good.
- 2) The Brown & Root QC inspector certification program was primarily restricted to mechanical and NDE type inspections and the base inspector certification requirements, as dictated by ASME and ASNT SNT TCLA, were more precisely defined than the requirements for civil and electrical type inspections.
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F Rovisitn: 1 Page 81 of 138 RESULTS REPORT ISAP I.d.1 '
(Cont'd)
I 1
6.0 CONCLUSION
S (Cont'd)
- 3) The checks and balances inherent in an ASME program, l including ANI monitoring and periodic ASME surveys, played I a positive role in ensuring that the Brown & Root QC inspector certification program was in compliance with requirements.
The past TU Electric QC inspector certification program, despite the procedural inadequacies described. in the ISAP I.d.2 Results Report, was adequate in that its application cons 12tently resulted in the certification of a high percentage of inspectors capable of conducting the required inspections. The Brown & Root QC inspector certification program was also adequete for the same reason. This conclusion is supported by the following results:
- 1) The overall error rate for all Phase III inspectors for whom reinspections were conducted was 3.114. This is not substantially higher than the overall deviation rate identified during ISAP VII.c reinspections, particularly when consideration is given to the fact that ISAP I.d.1 methodology will result in an inherently higher error rate than will be identified by ISAP VII.c reinspections.
- 2) Review of CPRT ISAP results, particularly ISAP VII.c, reveals that the cause of significant hardware problems remaining undetected was generally not attributed to inspector error.
- 3) The TU Electric program for certifying electrical QC inspectors was an area of particular concern on the part of the NRC TRT. Therefore, all historical and current TU Electric electrical QC inspectors were evaluated during implementation of this ISAP and, except for the area of cable pulling inspections for which no recreatable inspections could be conducted, no areas of concern were identified or remain unresolved.
- 4) TU Electric evaluated all the nonconformances that were written to document the hardware discrepancies that were identified during Phase III reinspections to determine if any were reportable to the NRC in accordance with 10CFR50.55(e) requirements. None of the nonconformances were reportable.
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V Revision: 1 RESULTS REPORT Pale 82 of 136 ISAP I.d.1 g (Cont'd)
6.0 CONCLUSION
S (Cont'd)
Results of the trend analysis in Section 5.7 indicate that no further action is warranted regarding the CPSES QC inspectors who have not been subjected to ISAP I.d.1 type evaluations.
Additional action, as detailed in Section 5.9, should be taken by TU Electric to resolve specific outstanding concerns regarding the unclassified trend for indeterminately qualified QC inspectors inspecting cable pulling.
Vith the exception of the unclassified trend for indeterminately '
qualified inspectors conducting cable pulling inspections, there is no significant indication of any adverse impact on the results of ISAP VII.c because of unqualified inspectors having originally conducted work on inaccessible or nonrecreatable attributes. In reaching this conclusion, consideration was given to the two failed inspectors for whom there was potential hardware impact.
These two inspectors appeared in six ISAP VII.c populations.
Inspector TM 6 was involved in sample items from the piping welds (PIVM), tubing welds (TUWM), and instrument support (INSP) .
populations. Inspector BM 4 was involved in samples from the fuel pool liner (FP1Jt), large bore pipe supports rigid (LBSR),
and small bore pipe supports (SBPS) populations.
Because determinations of the adequacy of nonrecreatable j
attributes in these populations depend upon satisfactory documentation, some of which was signed by these two inspectors, an evaluation of the impact of potentially questionable Vocumentation on the conclusions presented for these populations was undertaken. This evaluation included an analysis of the nonconformances identified during ISAP I.d.1 reinspections of these two inspectors
- work. This analysis took into account the nature and scope of the reported nonconformances and considered the possibility that such nonconformances might result in a construction deficiency, adverse trend, or an unclassified deviation or trend for these six populations.
The analysis determined that with three exceptions, the reported nonconformances were all of a relatively minor nature, and were similar to deviations noted during the ISAP VII.c reinspections l
of randomly selected sample items from applicable populations.
The three exceptions were related to an existing adverse trend and an established TU Electric corrective action program. These conditions would have been corrected by existing corrective action programs. It'was therefore concluded that inspection discrepancies of the type and severity documented during this ISAP implementation, whether they were to occur on a reinspection O
I i
at Revision: 1 Page 83 of 138 RESULTS REPORT
, ISAP I.d.1 i (Cont'd) -
s
6.0 CONCLUSION
S (Cont'd) or on a document review attribute, would not result in a construction deficiency, adverse trend, or unclassified trend or b
deviation: occurring or being identified that was not already a covered by existing corrective action. Thus, the conclusions presented in the ISAP VII.c Results Report remain valid.
l Recommendations for additional actions regarding these two inspectors are included in Section 5.10. A summary of the evaluation of daviations regarding QC inspector certifications identified during implementation of ISAP VII.c is contained in Attachment 15.
I 7.0 ONGOING ACTIVITIES The CPRT considers the implementatior of this ISAP to be complete.
There are no ongoing activities except those being conducted by TU Electric to resolvs the recommendations contained in this Results Report.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE IVIVRE O
Both the current TU Elactric and Brown & Root QC inspector certification programs are adequate. Continued management involvement in regularly evaluating the adequacy of these programs and their subcontractor programs and promptly correcting any identified discrepancies should avoid further problems.
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i Rsvision: 1 Pego 84 of 138 RESULTS REPORT ISAP I.d.1 f.)~- (Cont'd)
- Attachment 1 Inspector Certification Evaluati-" Summary Name':
- SSs:
epplicable Education: __
Manner of Verification:
Applicable Verified Prior Experience:
Initial and Discrepsnt Certifications:
Level Certification Date Certified Discrepancies Noted:
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x R vision: 1 Paga 85 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 1 (Cont'd)
Name-SSm:
Recomended Corrective Action: _
Signature:
Date:
Corrective Action Taken:
Signature:
Date:
[ Acceptable [ Unacceptable Signature:
Signature:
Date: Date:
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RESULTS REPORT
- r :: a .
ISAP I.d.1 (Cont'd)
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Revision: 1 !
Pago 88 of 138 )
RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 4
.The following pages of this attachment categorize the concerns regarding TU
- Electric inspectora.that were evaluated during Phase II. On January 30, 1981, TU Electric committed to ANSI N45.2.6 and Regulatory Cuide 1.58. As explained in Section 4.'l.2 of this Results Report, pre 1/31/81 and post 1/30/81 Phase II evaluation criteria differed. .This difference is reflected in the summary charts on the following pages of this attachment.
The following is an explanation of the categories:
- 1. Cert issued without education During the review, thero was no objective evidence available to indicate that the individual had the proper education to support certification.
- 2. Cett issued without experience - During the review, there was no objective evidsnce available to indicate that the individual had the proper experience to support certification.
- 3. Verification education and experience NRC IE Circular No.
80-22: "Confirmation of Employment Qualifications" which recommends verification of technical and education qualifications, dated 10/2/80, was used as the requirement date.
4 Physical requirements During the review, missing eya exam l
certs, lapse in eye exams, etc., were identified.
S.
Indoctrination / Training - During the review, no objective evidence was available to show that indoctrinstion and/or formal training has been completed.
- 6. OJT/ Training / Experience / Exams - Concerns were identified with waivers of OJT, training, experience and exams.
- 7. Exam (W, F/P, 0) - During the review, the exams contained errors, omissions, were missing, etc..
- 8. Certification /recertification problems - During the review, concerns were identified such as lapses in certifications, no annual evaluation, failure to exclude NDE, etc..
i
- 9. Documentation Concerns were identified with missing documentation, missing signatures, incomplete documents, conflicting documents, etc..
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Revision: L Pcge 89 of 138 RESULTS REPORT ISAP 1.d.1 (Cont'd) *;
Attachment 4 (Cont'd)
I CURRENT TUGCO QC INSPECTORS - 166 TOTAL PRE 1/31/81 POST 1/30/81 ANSI PROCEDURE ANSI PROCEDURE
- 1. CERT. ISSUED W/O 4 2 2 1 EDUCATION
- 2. CERT. ISSUED W/O 7 2 20 EXPERIENCE 2
- 3. EDUC./EXP. NO ED: 2 ED: 16 VERIFICATION EXP:1 EXP:14
- 4. PHYSICAL REQUIREMENTS 4 34
- 5. INDOC./ TRAINING 48 77
- 6. WAIVERS 37 153 OJT/ TRAINING /EXP./ EXAM
- 7. EXAMS (W,F/P,0) 5 50
- 8. CERT./ RECERT. 1 17 118
- 9. DOCUMENTATION 57 357 TOTALS 15 172
.: 52 792 I
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Revision: 1 Page 90 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 4 (Cont'd) s, TUGCO HISTORICAL ELECTRICAL QC INSPECTORS - 86 TOT PRE 1/31/81 POST 1/30/81 ANSI PROCEDURE ANSI PROCEDURE l
- 1. CERT. ISSUED W/O 2 1 EDUCATION
- 2. CERT. ISSUED W/O 24 2 7 EXPERIENCE 1
- 3. EDUC./EXP. NO ED: 25 VERIFICATION ED: 16 EXP: 3 EXP: 6
- 4. PHYSICAL REQUIREMENTS 12 11
- 5. INDOC./ TRAINING 38 6
- 6. WAIVERS 34 72 OJT/ TRAINING /EXP./ EXAM
- 7. EXAMS (W,F/P,0) 31 14
- 8. CERT. / RECERT. 11 26 37
- 9. DOCUMENTATION 73 63 l TOTALS 65 216 30 204 O
W
Rovision: 1 Pago 91 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 5 The following page of this attachment categorize the concerns regardin5
. Brown & Root inspectors that were evaluated during Phase II. On January 30, 1981, TU Electric committed to ANSI N45.2.6 and Regulatory Guide 1.58.
As explained in Section 4.1.2 of this Results Report, pre-1/31/81 and post-1/30/31 Phase II evaluation criteria differed. This difference is reflected in the summary chart on the following page of this attachment.
The following is an explanation of the categories:
- 1. Cert issued without education During the review, there was no objective evidence available to indicate that the individual had the proper education to support certification.
- 2. Cert issued without experience - During the review, there was no objective evidence available to indicate that the indivi( al had
, the proper experience to support certification.
- 3. Verification education and experience NRC IE Circular No. 1 i
80-22: "Confirmation of Employment Qualifications" which recommends verification of technical and education qualifications, dated 10/2/80, was used as the requirement date. l 4
Physical requirements - During the review, missing eye exam certs, lapse in eye exams, etc., were identified.
- 5. Indoctrination / Training During the review, no objective evidence training haswas available been completed. to show that indoctrination and/or formal
- 6. OJT/ Training / Experience / Exams Concerns were identified with waivers of OJT, training, experience and exams.
- 7. Exam (W, F/P, 0) During the review, the exams contained errors, omissions, were missing, etc.. i
- 8. Certification /recertification problems - During the review, concerns were identified such as lapses in certifications, no annual evaluation, failure to exclude NDE, etc..
- 9. Documentation - Concerns were identified with missing ;
documentation, missing signatures, incomplete documents, conflicting documents, etc.. l l
i
- l O
I 1
1
i Revision: L Page 92 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 1 Attachment 5 (Cont'd)
CURRENT B'&R QC INSPECTORS - 67 TOTAL PRE 1/31/81 POST 1/30/81 l ANSI PROCEDURE ANSI PROCEDURE
- 1. CERT. ISSUED W/O EDUCATION
- 2. CERT. ISSUED W/O EXPERIENCE 1
- 3. EDUC./EXP. NO ED: 1 VERIFICATION ED: 4 EXP:3 EXP:10
- 4. PHYSICAL REQUIREMENTS 1 1
- 5. INDOC./ TRAINING 9 4 41
- 6. WAIVERS 1 14 OJT/ TRAINING /EXP./ EXAM
- 7. EXAMS (W,F/P,0) 29 153 l
- 8. CERT./ RECERT. 1 1 23 120
- 9. DOCUMENTATION 50 126 TOTALS 5 112 19 456 l
l l
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1 Ravision: 1 Pago 93 of 138 RESULTS REPORT f ISAP I.d.1 (Cont'd)
Attachment 6 Explanation for Placing into Phase III l 1
Original I.d.1 Scope Historical Electrical - I HE 1 The Technical Training Outline stated that NDE visual was to be excluded from the QI-QP 11.3 5, "Cable Tray Inspections", certification; however, the exclusions were not noted on the certification.
HE 2 This individual was certified Level II, "Electrical Cable Installation Inspections", with insufficient experience to support certification. It was maiden also noted that the H.S. education was unverifiable due to unknown name.
HE-3 This individual failed the QI-QP 11.3 46, "Electrical Inspe.ction of Electrical Conductor Seal Assemblies", examination and was subsequently ll certified to this procedure via the Level II to CP-QP 11.3 "Electrical Inspection Activities".
HE 4 This individual was certified Level II to QI-QP il.3 13, "Inspection of
'Hilti' Drilled in Bolts, Hole Patch and Torque Unistrue Material", with insufficient experience to support certification.
HE 5 This individual was certified Level I to QI-QP-11.3 26, "Electrical Cable Installation Inspection", with insufficient education and experience.
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Revision: 1 Page 94 of 138 f RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
, HE 6 This individual was certified Level I to QI-QP 11.3 1, "Embedded Conduit and Sleeve Inspection", and to QI-QP-11.3 11. "Conduit Fabrication Inspection", with insufficient experience to support certification. Also.
QI-QP 11.3-5, "Cable Tray Inspection", did not exclude NDE as required by the Technical Training Outline.
HE-7 This individual was certified Level II to QI-QP ll.3 13. "Inspection of
'Hilti' Drilled in Bolts, Hole Patch, and Torque Unistrut Material", to QI-QP il.3-il, "Conduit Fabrication Inspection", and to QI-QP-ll.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", with insufficient education to support certification.
HE 8 This individual was certified Level II to QI-QP-ll.3 30, "Class 1E Conduit l
() Fabrication" and QI-QP 11.03-28, "Class 1E Cable Terminations", with insufficient prior experience to support certification.
HE 9 i
I This individual was certified Level I to QI-QP 11.3 23, "Class 1E Conduit Raceway Inspections", without the education to satisfy the requirement of Reg. Guide 1.58 and ANSI N45.2.6.
HE 10 i
This individual was certified Level I to QI-QP ll.3 26, "Electrical Cable Installation", with insufficient experience to support certification as required by ANSI N45.2.6.
v Rcvision: 1 l RESULTS REPORT ISAP I.d.1 ;
(Cont'd)
Attachment 6 (Cont'd)
- HE-ll This individual was certified' Level I to QI-QP 11.3 28, "Class lE Cable Terminations", with insufficient experience to support certification.
HE-12 This individual was certified Level II to QI-QP-11.3 5, "Cable Tray Inspections", with insufficient experience to support certification. Also, the Technical and QI-QP ll.3 Training 6, Outline for QI-QP ll.3-5, "Cable Tray Inspections" "Exposed Conduit, Condulet, Electrical Box and Support Inspections', stated that NDE was to be excluded from these certifications.
This exclusion was not noted on the certification.
HE-13 This individual was certified Level I to QI-QP ll.3-26, "Electrical Cable Installation Inspections", with insufficient education and experience to support certification.
HE 14 This individual was certified Level I to QI-QP il.3 24 "Inspection of Cable Repairs", to QI-QP 11.3 38, "Class lE Electrical Equipment Installation", and to QI-QP 11.3-28, "Class lE Cable Terminations", without the education to satisfy the requirements of Reg. Cuide 1.58.
HE-15 The Technical Training Outline stated that NDE was to be excluded from the QI-QP-il.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification.
certification.
The exclusion was not noted on the HE 16 The Technical Training Outline stated that NDE was to be excluded from the QI-QP-il.3-4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification.
certification.
The exclusion was not noted on the O
i Revision: 1 Pegs 96 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
,'HE 17 This individual was certified Level II to QI-QP ll.3 26, "Electrical Cable Installation Inspections", QI-QP-ll.3 27, "Class lE Power Cable Meggering",
and VT Limited, Class V Hangers, with insufficient experience to support certification. '
HE-18 This individual was certified Level I to QI-QP 11.3 26, "Electrical Cable Installation Inspections", with insufficient experience as required by ANSI N45.2.6.
HE-19 This individual was certified Level II to QI-QP il.3 26, "Electrical Cable Installation Inspection", with insufficient experience to support certification.
HE 20
(~')/
\~~
The Technical Training Outline for the Level II QI-QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", stated that NDE was to be excluded from the certification. The exclusion was not noted on the certification. Also, this individual was subsequently certified to mechanical Level III with insufficient experience.
HE 21 This individual was certified Level I to 35 1195 CEI 20, "Installation of
'Hilti' Drilled in Bolts", with insufficient experience to support certification. Also, the Technical Training outline for QI-QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", stated that NDE was to be excluded from the certification. The exclusion was not entered on the certification.
HE 22 This individual was certified Level I to 35 1195 CEI-20, "Installation of
'liilti' Drilled in Bolts", with insufficient experience to support certification.
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1 1
R".vis ien : 1 Page 97 of 138 RESULTS REPORT ISAP I.d.1 l
)
(Cont'd) ,
Attachment 6 (Cont'd)
. Current Electrical CE 1 This individual failed the exam for QI-QP 11.3-42, "Electrical Inspections l of Seismic CAT I Instrument Rack Assemblies", and failed the exam twice for l CP-QP-ll.2, "Surveillance and Inspection of Concrete Anchor Bolt !
Installation". The inspector was subsequently certified Level II to the CP-QP il.3, "Electrical Inspection Activities", which encompassed the QI-QP ll.3 42 certification. It was also indicated that the Level II CP-QP-11.3 certification encompassed the failed CP-QP-11.2 certification.
CE-2 I
This individual failed the exam for QI-QP 11.3 42, "Electrical Inspection of Seismic CAT I Instrument Rack Assemblies", and was subsequently certified Level II all electrical to CP-QP 11.3, "Electrical Inspection Activities".
QI-QP-11.3-42. The all electrical certification did not exclude CE 3 l
This individual failed the exam for QI-QP-11.3 50, "Cable Grip Support j Installation Inspection", and was subsequently certified Level II all '
electrical to CP-QP 11.3, "Electrical Inspection Activities". The all electrical certification did not exclude QI-QP ll.3 50.
CE-4 This individual was certified to CEI 20, "Electrical - Hilti Bolt Inspections", with no prior experience to support certification.
CE-5 '
I The Technical Training Outline for the QI-QP ll.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification noted that non destructive examination (NDE) for veld inspections was not to be included. The certification did not exclude NDE. !
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e l
Rsvision: 1 Page 98 of 138 RESULTS REPORT j ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
.CE 6 This~ individual fai' led.the exam for QI-QP ll.3-29, "Electrical Separation",
and was subsequently certified Level II all electrical to CP-QP ll.3, "Electrical Inspection Activities", with no exclusions regarding QI-QP-11.3 29.
The recertification recommendation form indicated (via the Elect. Level III) that QI-QP 11.3 29/QI-QP ll.3 29.1 and QI-QP il.3 53 should be excluded from the CP-QP ll.3 certification.
CE 7 This individual was certified Level I to QI-QP ll.3-28, "Class lE Cable Terminations", with no verifiable electrical experience as required by ANSI N45.2.6.
I&C/RWMS ~
IC 1
\
This individual was certified Level I to QI-QP-il.8-5, 6, and 8,
,_s/ "Inspection of Instrument Tubing Fabrication and Installation, and Instrument Installation", with insufficient experience to support certification as required by ANSI N45.2.6.
NDE/Thermolag NT 1 This individual was certified Level I to' CP-QP ll.2, "Surveillance and Inspections of Concrete Anchor Bolt Installation", and to QI-QP ll.0 15 "Verification of Base Plate for Grouting", with insufficient experience to support certifications as required per ANSI N45.2.6.
NT 2 This individual was certified Level I to QI-QP 11.2 1, "Installation of
'Hilti' Drilled in Bolts", with insufficient education to support certification as required by Reg. Guide 1.58.
Protective Coatings PC 1 This individual was certified Lavel II for Concrete and Steel Coatings without sufficient education as required per Reg. Guide 1.58 and ANSI N45.2.6.
O y m- .- -,- ,- -- -,- .-- -
- R vision: 1 Paga 99 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
. Mechanical NM 1 The educational requirements to support certification as a Level I to CP-QP-11.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", could not be validated.
NM 2 This individual was certified Level I to CP-QP il.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", with insufficient education as required by Reg. Guide 1.58 and ANSI N45.2.6.
NM-3 The Technical Training Outline stated that non destructive examination (NDE) was to be excluded from QI-QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification dated 7/16/79, however, no exclusions were noted on the certification.
Level III O L1 This individual is categorized as a Level III due to his certification status at the time of review. He was initially certified Level II to CP-QP-il.2, "Surveillance and Inspection of Concrete Anchor Bolt Instzllation", without a H.S./GED as required by Reg. Guide 1.58.
L2 This individual was certified Level III electrical with insufficient education and experience to support certification as required by Reg. Guide 1.58 and ANSI N45.2.6.
L3 This individual was certified Level III, "Protective Coatings", with insufficient experience to support certification as required by Reg. Guide 1.58 and ANSI N45.2.6.
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Rovicien: .1 Pags 100 of 138 RESULTS REPORT ISAP I.d.1
\
(Cont'd)
-(&
Attachment 6 (Cont'd)
,L-4 This individual is categorized as a Level III due to certification status
~
at the time of review. The Technical Training Outline for the Level I QI-QP 11.3 2 certification, "Cable Tray Hanger Inspections", noted that non destructive examination for weld inspections was to be excluded. The certification did not state this exclusion.
Brown & Root Non-ASME HB-1 The exam for CP-QP il.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", certification was incorrately scored allowing certification based on a failed exam.
() The general exam for the Level II Mechanical Fabrication Inspector was incorrectly scored, allowing certification based on a failed examination.
AM-2 The general and specific exam for the Level I Mechanical Fabrication Inspector were incorrectly scored, allowing certification based on failed examinations.
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Attachment 7 Phase III Evaluation of TU Electric Historical QC Inspectors Original I.d.1 Scope 1
8 l
' Twenty-two TU Electric historical QC inspectors were referred to Phase III for further evaluation. The results of the Phase III reinspections are tabulated on the last page of this attachment. Historical electrical inspectors HE-5, 9, 11, 12, 14, and 17 all had at least 50 inspections reinspected with acceptable results. Because the target number of inspections was obtained within a time frame reasonably close to issuance of the discrepant certification, possible inaccuracies in the computer data base for these inspectors are considered to have no impact.
Inspectors HE-1, 15, and 16 were placed into Phase III only because of the NDE exclusion problem. Inspection reports for the applicable periods of time were identified from the data base to determine if visual weld
' inspections had been conducted by these inspectors. For HE-15, 184 cable pulling inspections had been conducted between October 1979, when the 1
certification was issued, and December 1979, when the visual weld inspection requirements were removed from the procedure. No visual veld
' inspections conducted by this inspector were identified. Similarly HE-16 conducted 53 conduit inspections between September 1979, when the certification was issued, and December 1979, when the procedure was revised. No visual weld inspections conducted by this inspector were identified. In the case of HE-1, 51 cable tray inspections were identified
$ as having been conducted between July 1979 and December 1979, when the procedure was revised.
Of the 51, three were found signed off as having t
visual weld inspections conducted by this inspector. Two of the three had been reinspected by qualified inspectors because the original inspection had been identified as unsatisfactory by'HE 1. There was no evidence that :
the remaining item had been reinspected after acceptance of the welding by HE-1. This item was covered with Thermolag and was identified as )
inaccessible. The time periods in question coincide with a time period in ;
I which the computer data base was less accurate than desirable. Concerns regardin5 the NDE exclusion problem have been documented in QA/QC-PDR 56, which is discussed in Section 5.2.3 of this Results Report.
HE-2, who had only been certified to conduct inspections of cable pulling, was placed into Phase III because of insufficient experience and the inability print outto verify high school education because of name changes. The identified approximately 68 of this type of inspections. This work had been conducted between March 1980 and July 1980 when the data l base was reasonably accurate. Because cable pulling has been identified as a non recreatable inspection, 'the ability of inspector HE 2 to conduct inspections properly is indeterminate.
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Attachment 7 (Cont'd)
- HE 3 failed the examination relating to the procedure for inspection of
. electrical conductor seal assemblies. This person was placed into Phase III because of the subsequent issuance of an "all electrical certification" without retesting and without exclusion for conduct of inspections to the subject procedure.
An "all electrical certification" encompassed certification to all existing electrical inspection procedures. During the time period in question (October 1983 to September 1985), the computer data base identified seven inspections conducted per the procedure. Further examination of the inspaction reports indicated that the inspections should have been conducted using a different precedure. As a result. TU Electric issued NCR E86-250456 to re evaluate the equipment that had been inspected.
This inspector was also evaluated under TU Electric CAR 050 regarding inspection of pre insulated environmentally sealed splices and, as a result, witnessed was byterminated because documented inspections had not actually been the inspector. The period between October 1983 and September 1985 was one in which an undesirably high error rate in the computer data base was identified. Because of this, TU Electric conducted a manual search of the inspection packages for all applicable electrical conductor seal assemblies and identified five that had been inspected by HE-3. TU Electric was requested by the QA/QC Review Team to reinspect and/or evaluate the acceptability of these assemblies. TU Electric agreed to do so.
TU Electric is also proceeding to resolve concerns identified in the above-referenced NCR and CAR. There is no further concern regarding this inspector's ability to inspect the subject electrical conductor seal assemblies adequately.
HE 4 was placed into Phase III because this individual had been certified Level II to several electrical inspection procedures without having sufficient experience in April and June 1979. The data base identified over 1,000 inspections between April 1979 and February 1980. One thousand one hundred and sixty three of these inspections were cable pulls and meggering that were determined to be non recreatable. Meggering of all safety related electrical cables is repeated during startup testing. For this reason there is no further concern regarding maggering inspections conducted by HE 4 Twelve conduit and raceway inspections that were conducted in April and May of 1979 were identified as recreatable. These twelve inspections were comprised of 96 objective decisions, seven of which were incorrect, and 16 subjective decisions, all of which were correct.
The objective disagreement rate of 7.296 for these twelve inspections falls outside of the 54 limit. The ability of this inspector to conduct inspections properly for the procedures for which he was certified is indeterminate. ,
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Attachment 7 (Cont'd HE 6 was initially certified without having sufficient experience to inspect embedded conduit and sleeves and conduit fabrication in December 1978.
In addition, the NDE exclusion problem for cable tray inspection was evaluated between June 1979 and December 1979. No inspections for this inspector other than coatings inspections were identified in the computer data of base between December 1978 and January 1980, which was the time period concern. This was in a period in which the computer data base was determined to be less accurate than desired. A manual search of Unit 1 inspection records was conducted by TU Electric for this period of time.
No thisinspections, other than coatings inspections, were identified during search. Because coatings were declassified as non safety related, none of the coatings inspections were reinspected. Because the manual records search did not include Unit 2 records, the ability of this inspector to conduct inspections adequately is indeterminate. Concerns regarding the NDE exclusion problem have been documented in QA/QC-PDR-56, which is discussed in Section 5.2.3 of this Results Report.
HE 7, who was placed into Phase III because of insufficient education, was certified to inspect Hilti bolts, conduit fabrication, and conduit and support installation.
Over 200 inspections were identified as having been conducted during the period of concern between July 1979 and January 1980.
A total of 49 recreatable inspections was identified and reinspected with satisfactory results. Although this is one short of the desired 50 inspections, there is a sufficient amount of data to conclude that this inspector was capable of conducting the required inspections.
HE 8 was placed into Phase III because of insufficient experience to support the initial certifications to inspect conduit fabrication and electrical termination inspections in November 1980. Fifty recreatable electrical termination inspections, initially conducted between November 1980 and March 1981, were reinspected with a 6.24% disagreement rate on objective attributes.
Because the objective disagreement rate exceeded the five percent limit, an additional 50 recreatable inspections were selected for reinspection. These inspections that were initially conducted between March 1981 and October 1981 were also all termination inspections. The composite results of the first 50 reinspections and the second 50 reinspections rate.
disagreement were 5.40% objective disagreement rate and 0.004 subjective Because the composite reinspection results for objective attributes exceed the 54 limit, HE-8 failed the Phase III evaluation. A root cause/ generic implication analysis of the failure of this inspector to meet the Phase III acceptance criteria was conducted and is described in Section 5.8 of,this Results Report.
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Attachment 7 (Cont'd HE-10 was placed into Phase III because of lack of experience for the initial certification. For the time period in question, which was March 1983 to June 1984,la total of 54 inspections was identified by TU Electric from the computer data base. Of the 54, 28 inspections were recreatable and were reinspected with satisfactory results. The accuracy of the data base is lower than desirable for the applicable time period. However, there is substantial positive evidence based on the 28 inspections that were reconducted that this inspector was capable of satisfactorily accomplishing the required inspections.
HE-12 was placed into Phase III because of lack of experience for his initial certification for cable tray inspection and because, between July 1979 and December 1979, the NDE exclusion problem for cable tray and conduit inspection existed. As shown on Attachment 7, 50 recreatable inspections were reinspected from the time of his initial certification with acceptable results. With regard to the NDE exclusion problem, TU Electric identified 72 cable tray and 75 conduit inspections from the computer data base that had been conducted by this inspector. One visual weld inspection of cable tray was identified that may have been conducted by this inspector. In addition, during the processing of other
/
reinspection documentation, the QA/QC Review Team identified another visual weld inspection of cable tray that had been conducted by this inspector during the time period in question. HE 12 is acceptable except for the NDE exclusion problem, which is documented in QA/QC-PDR-56, which is discussed in Section 5.2.3 of this Results Report.
HE 13 was placed into Phase III because of insufficient education and experience to cupport his certification for cable pulling and meggering.
The computerized data base identified over 300 inspections, all cable pulling, conducted during the time of concern between July 1980 and October 1980, during which the data base was reasonably accurate. Three of the inspections were conducted prior to issuance of the certification in July 1980.
TU Electric has issued NCR E86-103066X to document and resolve this problem. Cable pulling and meggering have been identified as non recreatable inspections and the ability of this inspector to conduct inspections adequately is indeterminate.
HE 17 was placed into Phase III because he had insufficient experience to support his initial certification in July 1980 to conduct electrical cable pulling inspections. In September 1980 he was certified to conduct meggering, also with minimal experience, and in November 1980 he received certifications that allowed the inspection of Class V pipe support hangers.
There was also insufficient experience to support the latter certifications. Electrical cable installation and maggering inspections are not recreatable. inspections. Fifty reinspections of Class V pipe O
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Attachment 7 (Cont'd c supports were successfully conducted. Considering the relative difficulty I of pipe support inspections, these reinspections provide reasonable assurance that HE 17 was capable of conducting inspections for which he had been certified despite the lack of required experience. HE 17 is acceptable.
HE 18, who was placed into Phase III because of insufficient experience, was certified only to inspect cable pulling and meggering. The data base identified over 400 cable pull inspections between March 1983 and May 1983.
This time frame is during a period in which the data base accuracy is less than desirable. Cable pulling and meggering have been identified as non recreatable inspections, and the ability of this inspector to conduct inspections adequately is indeterminate.
HE 19, who was certified only to inspect cable pulling and meggering, was placed into Phase III because of a lack of experience. The computerized date. base for HE-19 identified over 1,000 cable pull and maggering inspections between February 1980 and June 1980, the period in question.
Inis time frame is in a period during which the computerized data base appears to be reasonably accurate. These inspections have been identified as non recreatable, and the ability of this inspector to conduct inspections adequately is indeterminate.
HE 20 was initially placed into Phase III because of the NDE exclusion problem for conduit and support inspection. The period of time of concern was from July 1979 until December 1979. From the computer data base, TU Electric identified 91 inspections during this time frame and no visual inspections of welds were conducted by this inspector. This work was accomplished during the time in which the computer data base was less accurate than desirable. In April 1984 this same inspector was certified as a Level III mechanical /velding inspector with insufficient experience.
In June 1984 this inspector was transferred to TU Electric Dallas office as i
a QA auditor and was not utilized as a Level III inspector at Comanche Peak. Concerns regarding the NDE exclusion problem have been documented in QA/QC PDR-56, which is discussed in Section 5.2.3 of this Results Report.
No concerns exist regarding the Level III mechanical / welding certification because HE 20 did not utilize this certification. HE 20 had a four year college degree ~and substantial experience in the electrical area. There were no concerns identified regarding his electrical inspection certifications or his auditor certifications.
HE 21 was placed into Phase II,I because of insufficient experience to i
support his initial certification in October 1978 for inspection of Hilti bolts. He was also in Phase III because, between July 1979 and December 1979, the NDE exclusion problem for conduit raceway inspections existed.
j From the computer data base, TU Electric identified approxinately 75
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Page 106 of 13a l RESUI.TS REPORT
^
l ISAP I.d.1 (Cont'd)
Attachment 7 (Cont'd inspections of cable tray hangers (probably of Hilti bolts for the hangers)
' from October 1978 until July 1979 None of these inspections were reinspected because of the extensive rework program being conducted by TU Electric on cable tray hangers. It is possible that this inspector also conducted other inspections during this same time period that do not appear on the data base because of data base inaccuracies. Fifty recreatable conduit raceway inspections that were conducted between July 1979 and August 1979 vere identified.
results. These items were reinspected with acceptable Because of the extensive period of time (nine and one half months) between his initial certification and the recreatable inspections, there is not conclusive evidence that this inspector was initially capable of conducting the required inspections. However, the results of these 50 reinspections provide a substantial amount of positive information that his lackwas HE-21 capable of initially conducting the required inspections despite of experience. With regard to the NDE exclusion probles TU Electric identified 201 conduit inspections from the computer data base for which no visual veld inspections were conducted. The NDE exclusion problem is documented in PDR 56, which is discussed in Section 5.2.3 of this Results Report.
C
\ HE 22 was also placed into Phase III because of insufficient sxperience to support his certification in October 1978 for inspection of Hilti bolts.
The computer data base identified 101 cable tray hanger inspections (probably of Hilti bolts for the hangers), two lighting conduit inspections, two lighting termination inspections, and nine conduit fabrication inspections between October 1978 and April 1979. No inspections were identified between April 1979 and December 1979. The 114 inspections described above were identified as nonrecreatable. It is possible that other inspections were conducted that were not identified because of computer data base inaccuracies. In December 1979 and January 1980, 50 recreatable conduit inspections were conducted. These were successfully reinspected. HE-22 was initially certified for this type of l
t conduit inspection in December 1979. Because of the 14-1/2 month period between the initial Hilti bole certification and the recreatable conduit inspections, there is a lack of conclusive evidence that this inspector was initially capable of conducting the required Hilti bolt inspections.
However, the results of these 50 conduit reinspections, which are more difficult to conduct than Hilti bolt inspections, provide a substantial amount of positive information that HE 22 was capable of initially conducting the required inspections despite his lack of experience.
The reinspection results for the TU Electric historical QC inspectors are tabulated on the following page.
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Page 107 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 7 (Cont'd Historical
'. Electrical Error Rate Reinspections Inspector Conducted Subjective Obiective HE-1 NDE Exclusion -- --
HE-2 0 -- --
HE 3 0 - --
HE 4 12 On 7.29%
HE-5 50 On 3.81%
HE 6 0 - --
NDE Exclusion -- --
HE 7 49 6.19% 4.964 HE-8 100 04 5.404 HE 9 84 4.194 3.894 HE 10 28 HE 11 On 4.41%
90 On 3.91%
HE-12 50 0.654 4.73%
NDE Exclusion - --
HE 13 0 -- --
HE 14 50 04 0.76%
HE-15 HE 16 HE 17 NDE Exclusion NDE Exclusion lh '
50 On 4.204 HE-18 0 - --
HE-19 0 - --
HE 20 NDE Exclusion - --
0 -- --
HE-21 50 04 0.26%
NDE Exclusion - --
HE-22 50 6.45% 4.724 I
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( ISAP I.d.1 (Cont'd)
Attachment 8 Phase III Evaluation of TU Electric Current QC Inspectors Original I.d.1 Scope The following sections:of this attachment describe the detailed Phase III evaluations that were conducted for TU Electric current QC inspectors.
These are grouped as electrical QC inspectors, I&C/ radiation vaste management system QC inspectors, NDE/thermolag QC inspectors, mechanical QC inspectors, protective coatings QC inspectors, Level III QC inspectors, and Brown & Root inspectors maintaining TU Electric certifications. The reinspection results are tabulated on the last pages of this attachment.
TU Electric Current Electrical QC Inspectors Seven TU Electric current electrical QC inspectors were referred to Phase III for further evaluation. The results of the Phase III reinspections are shown on the last pages of this attachment.
CE-1 failed examinations for inspection of instrument racks and Hilti bolts.
CE 1 was placed into Phase III because of the subsequent issuance of an "all electrical certification" that did not exclude these two areas
/~ ' for which no re-examinations had been conducted. An "all electrical certification" encompassed certification to all existing electrical inspection procedures. During the period in question between May 1982 and February 1985, the data base showed over 5,000 inspections, none of which were for instrument racks, and 32 of which were for Hilti Bolts. A manual l
review of all the inspection records for all safety-related instrument racks was conducted by TU Electric, and it was verified that CE-1 did not conduct any inspections of instrument racks. Therefore, no concerns remain regarding inspection of instrument racks by this inspector. Of the 32 Hilti inspections, 21 were recreatable and were reinspected. Results of these reinspections were within the error rate limits. There is substantial, but not conclusive, evidence that this inspector was capable of inspecting Hilti bolts.
CE 2 also failed the examination for the inspection of instrument racks and was subsequently certified in same manner as CE 1 without an exclusion for this type of inspection. For the period between December 1982, when the certification was issued, and December 1984, when this type of inspection was excluded from the certification, the data base shows over 4,000 inspections were performed, none of which included inspection of instrument racks. The manual review of all the inspection records for all instrument racks that was conducted by TU Electric also confirmed that CE 2 did not conduct any inspections of instrument racks. No concerns remain regarding this inspector. '.
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' ISAP I.d.1 (Cont'd)
Attachment 8 i
(Cont'd)
In a manner similar to that for CE 1 and CE-2, CE-3 failed an examination to conduct cable grip support installation inspections and was subsequently ;
issued an all electrical certification without re examination in this area.
The applicable time period between April 1983 and January 1986 showed over 2,000 inspections being conducted, none of which were for this activity.
The inspections shown in the computer data base provide substantial positive information that this inspector did not inspect cable grip support installations. However, because of computer data base inaccuracies, a totally conclusive determination cannot be made from the available information.
CE 4 was placed into Phase III because of lack of experience to support a certification in December 1978 to inspect Hilti bolts. In January 1979, CE 4 was certified to inspect cable trays, also with insufficient experience.
1979.
The computer data base did not list any inspections until June A total of 50 recreatable cable tray inspections were identified in the period from June 1979 until November 1979 and were successfully reinspected.
These reinspection results provide adequate avidence that CE 4 was capable of conducting inspections for which he had been certified despite the lack of required experience. CE-4 is acceptable.
CE 5 was placed into Phase III because of the NDE exclusion problem for conduit support inspections for the period of time from September 1979 until December 1979. From the data base, TU Electric identified 44 of these inspections for which no visual inspections of welds were conducted.
The time period in question was during a period when the data base was less accurate than desirable. Concerns regarding the NDE exclusion problem have been documented in PDR 56, which is discussed in Sectim 5.2.3 of this Results Report.
CE-6 failed an examination for electrical separatic' ' cs4 ' 4 and was subsequently certified all electrical in December . 42 A So re-examination in this area. Because of this and * " f.e , ime two years later he was again recertified all electrical desp w .xemo 'tions from the Level III electrical inspector that electrical _ a rdion .spection and inspection of the surface preparation of penetrati v a lr' ick flanges be excluded, CE 6 was placed into Phase III. The data u '
Lested that over 9,000 inspections were conducted during the period in question between December 1982 and May 1986, none of which covered the areas in question.
Subsequent information not obtained from the computer data base was l
identified by TU Electric and made available to the QA/QC Review Team.
This information indicated that; CE 6 had conducted a substantial number of electrical separation inspectiohs. An interview of ".his intpactor by the QA/QC Review Team indicated that he had not conducered any inspections of the surface preparation of penetration weld neck flanp s. and no further
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RESULTS REPORT s ISAP I.d.1 (Cont'd) ;
Attachment 8 I
(Cont'd) i
- evaluation in this area is required. Data base inaccuracies during the '
time period in question exist, and electrical separation inspections are not recreatable. However, TU Electric has initiated NCR CE 87 4577, which will result in an overall program to correct generic electrical separation problems. This program will encompass reinspections of electrical ,
separation that were conducted by this inspector. Therefore, the ability of this inspector to conduct inspections of electrical separation ;
adequately is of no further concern. l CE 7 was placed into Phase III because of insufficient experience to support his November 1983 certification for cable termination inspections.
A total of 50 recreatable inspections was identified in the period between i December 1983 and March 1985. It should be noted that all but four of these inspections occurred in the December 1983 to June 1984 time frame. l Of these remaining four, three were conducted in September 1984 and one in March 1985. These 50 inspections were reinspected with results within the agreement rate guidelines, indicating that CE 7 was capable of conducting the required inspections despite the lack of required experience. CE 7 is acceptable.
O TU Electric Current I&C/ Radiation Vaste Management System (RWMS) QC Inspectors IC 1 was placed into Phase III because of an inadequate amount of experience to support his certification in March 1982 for instrumentation inspection. A total of 50 recreatable instrumentation inspections were identified in the computerized data base and reinspected. Thirty of these inspections fell into the first 90 days and 20 into the second 90 days.
Just after these reinspections were completed and before the data was -
compiled, an additional 21 Hilti bolt reinspections were identified in the first 90 days. The composite results of the 30 instrumentation reinspections and the 21 Hilti bolt reinspections for the first 90 days was a 5.064 objective disagreement rate and a 1.324 subjective disagreement rate, which fell slightly outside the ISAP I.d.1 acceptable rates. It was noticed that the instrumentation reinspection results were not as good as those for the Hilti bolt reinspections. The results of the 50 instrumentation reinspections were then compiled and determined to be a 6.64% objective disagreement rate and a 1.894 subjective disagreement rate.
There were no objective disagreements and only a 14 subjective disagreement race for che 21 Hilti bolt reinspections. Analysis of the reinspection data indicated that a large number of disagreements were concentrated.on the attributes that required i,dentification and recording of unique identification numbers on instrumentation system supports and racks.
Further investigation revealed that the historical TU Electric requirements were vague and ambiguous in this area. As a result, QA/QC PDR 70 was O
Rsvision: 1 Page 111 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 8 (Cont'd)
. issued to document this lack of definitive requirements relating to identification of. instrumentation supports. Because of this problem. the results regarding this attribute have been excluded from the reinspection results for IC 1. IC 1 has been found to be acceptable based on the composite results of the 50 instrumentation inspections and the 21 Hilti bolt inspections.
TU Electric Current NDE/Thermolag QC Inspectors Inspector NT-1, who was placed into Phase III because of insufficient experience in the areas of Hilti bolt and baseplate grouting inspection, had 50 reinspections conducted on his first three month's work with acceptable results.
negative impact on these Possible data base inaccuracies did not have any results.
NT 2 was placed into Phase III because he was certified to conduct Hilti bolt inspections in November 1983 without a high school GED. NT-2 obtained a high school GED in Harch 1984. Fifty reinspections were conducted with acceptable results for this inspector. These 50 reinspections consisted of 36 Hilti bolt and two Richmond Insert inspections initially conducted between December 1983 and April 1984 and an additional 12 visual weld inspections initially conducted in July and September 1985. NT-2 was certified to inspect welds visually in June 1985. Since both the 38 Hilti bolt / Richmond Insert inspections and the 12 welding inspections occurred close to the initial applicable certifications, they were considered to be adequate measures of any impact that lack of education may have had upon this inspector's ability to conduct the required inspections. NT 2 is acceptable.
TU Electric Current Protective Coatings QC Inspectors There was one inspector (PC 1) in this area placed into Phase III because of lack of education. He was certified only to inspect coatings. The computer data base identified over 3,000 inspections performed between October 1977 and May 1982. All inspections were coatings inspections.
Because protective coating are no longer classified as safety related at CPSES, none of these inspections were redone. No concerns remain regarding this individual. -
TU Electric Current Mechanical QC Inspectors Inspector NM 1 had the required number of reinspections conducted with acceptable results. NM 1 was'placed into Phase III because the education cited in his certification documentation could not be validated. He was initially certified to inspect Hilti bolts in April 1982. The 50
Rsvision: A RESUI.TF REPORT ISAP I.d.1 (Cont'd)
Attachment 8 (Cont'd)
.reinspections that were conducted consisted of 30 Hilti bolt inspections I originally conducted in April and May 1982 and 20 instrumentation inspections originally; conducted in September, November, and December 1982.
The reinspection results indicate that this inspector was capable of conducting the required inspections despite the lack of required education.
NM 1 is acceptable.
NM 2 was certified in December 1983 but had no high school GED until February 1984. This inspector's certifications were inactivated by TU Electric in September 1985 because of his failure to pass an examination for visual intpaction of welding. As a result, TU Electric issued FCR M85-200285.
The data base identified a total of 439 inspections, primarily of cable tray hangers, conducted by this inspector from December 1983 until September 1985, the time period in question. No cable tray hangers were reinspected because of the extensive rework program being conducted on cable tray hangers. None of the remaining inspections (27) could be recreated. The ability of this inspector to conduct the required inspections adequately is indeterminate.
In the case of NM-3, the NDE 2xclusion probles relating co inspection of O conduit raceways occurred during the period between July 1979 and December 1979. From the computer data base, TU Electric identified that 91 conduit raceway inspections were conducted, none of which included visual inspection of welds. This work was accomplished during a period of time in i
which the data base was less accurate.than desired, and these inaccuracies l
' should be considered during resolution of the NDE exclusion problem.
Concerns regarding the NDE exclusion probles have been documented in PDR 56, which is discussed in Section 5.2.3 of this Results Report.
TU Electric Current level III QC Inspectors There were four inspectors from this category placed into Phase III.
Because Level III inspectors do not normally conduct field inspections, the circumstances regarding each of these individuals requires explan u on.
Inspector L 1 was initially certified as a Level II inspector for Hilti Bolts and cable repair in September 1980. In January 1981, ANSI N45.2.6 and Regulatory Guide 1.58 became TU Electric commitments, and inspectors were required to have a high school diploma or a GED. Because this inspector did not receive a high school GEO until May 1982, he was placed into Phase III for this period of time. No inspsetions were included in the computer data base during ,this time frame, for which most of the data base appeared to be reasonably Accurate. In addition, the position that this individual held during this period of time did not normally involve conducting inspections. No concern remains regarding this individual's certification package discrepancies or on possible hardware impact.
R visien: 1 Page 113 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 8 (Cont'd)
,L 2 was initially certified as a Level III Electrical in July 19?.c.. It was discovered by TU Electric in May 1985 that he had neither the required education nor experience for: this certification. A review of this individual's work by TU Electric indicated that he had not certified any inspection personnel nor had he conducted any inspections. He had, however, been involved in the revision and/or approval of nine TU Electric inspection procedures. As a resule, the QA/QC Review Team reviewed these nine inspcetion procedure revisions and determined that the changes were either editorial chan8es or process improvements. No concerns remain regarding this individual's discrepant certifications or on possible ,
hardware impact. l L 3, who was certified as a Level III Coatings inspector in January 1984, was placed into Phase III becauss of insufficient experience. The computer I data base identified approximately 12 inspections, all of coatings, as having been conducted by this individual. Because coatings are no longer classified as safety related, no reinspections were conducted. No concerns remain for this individual.
L-4 was placed into Phase III because of the NDE exclusion problem relating i to inspection of cable tray hangers. The period of time in question was l from October 1979 until December 1979, during which the computerized data base identified six cable tray hanger inspections. No visual weld inspections were identified as having been conducted by this inspector l until after his certification in this area in early January 1980. This l work occurred during a time in which the computerized data base was less accurate than desirable. Concerns regarding the NDE exclusion problem have been documented in PDR-56, which is discussed in Section 5.2.3 of this Results Report.
Current Brown & Root QC Inspectors Maintaining TU Electric Certificatiens (Hilti's)
Only one Hilti bolt inspector was evaluated in this category. This inspector (HB 1) was certified for inspection of anchor bolts in March 1984 after failing his examination Ursorrectly scored). A search of the computerized data base between datch 1984 and August 1986 identified over 300 inspections, but only seven were anchor bolt inspections. Of these
- seven, two were recreatable. The seven inspections were conducted on ASME l
supports and equipment for which the discrepart TU Electric certification was not applicable. As a result of this information, Brown & Root revoked his ASME certification in this,arca, conducted retraining, and successfully re examined him. An interview was conducted by TU Electric QA with HB 1, and he stated that he had not performed any inspections of Hilti bolts O
i 1
Revision: 1
- I' RESULTS REPORT I ISAP I.d.1 (Cont'd)
Attachment 8 (Cont'd) under the discrepant TU Electric certification. In addition, the Hardware
. Validation Program for ASME pipe supports includes reinspection of Hilti bolts. No outstanding; concerns regarding this inspector remain.
The reinspection results for TU Electric current QC inspectors are tabulated on the following two pages of this attachment.
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Attachment 8 (Cont'd)
' Current Error Rate Electrical Re~ inspections Inspector Conducted Subjective Objective CE 1 21 5.004 2.67%
CE 2 0 - --
CE-3 0 -- --
CE-4 50 on 1.82%
CE 6 0 - --
CE 7 50 On 2.17%
I&C/RVMS Inspector IC 1 71 1.314 2.72%
NDE/Thermolag Inspector NT 1 50 8.45% 0.67%
NT-2 50 On 2.954 Protective Coatings Inspector PC 1 Coatings only -- --
Non ASME Mechanical Inspector NM 1 50 4.284 1.20%
NM 2 0 - -
NM-3 NDE Exclusion - -
Level III Inspector L1 0 - -
L2 0 L3 Coatings Only - --
L4 NDE Exclusion - -
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Attachment 8 (Cont'd)
B&R ASME Inspectors
- Maintaining TU Electric Error Rate Non ASME Reinspections Certifications Conducted Subjective Obiective HB 1 2 On 04 O
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.__,w. , ,-ww%--- -m-,-e--- - -
- Rcvision: 1 RESULTS REPORT ISAP I.d.1 (Cont'd) l Attachment 9 Phase III Evaluation of Brown & Root Current QC Inspectors Two inspectors placed into Phase III in this area were evaluated. AM 1, whose examination had been incorrectly scored, had failed the examination for mechanical fabrication inspection. The data base indicated only one mechanical fabrication inspection was performed between July 1980 and February 1981, the period in which the inspector held the discrepant certification.
This inspection was not recreatable because the inspection had been reconducted. The time period in question coincided with the time j period in which the computerized data base is considered to be reasonably accurate.
No concerns remain regarding this individuals discrepant certification or any possible impact on the hardware.
AM 2 also failed the examination for mechanical fabrication inspection but had been certified in July 1983 because the examination had been incorrectly scored. When the examination error was identified, Brown &~
Root re examineo him and recertified him in June 1986. From a search of the computer data base, Brown & Root identified 38 inspections conducted under this certification. None of these inspections were recreatable. A review of the e n aciated inspection reports indicated that the inspections consisted primarily of verification of proper transfer of material heat numbers during cutting operations in the fabrication shop. The only other activity identified was participation in hydrostatic testing of RPV Control Rod Drives under the supervision of a Level II inspector. AM 2, who is still employed as an inspector at CPSES, was interviewed by the QA/QC Review Team.
This interview confirmed that the above activities were the only ones conducted by this individual under this certification. AM 2 spent the bulk of his time conducting radiography and only helped in the areas noted above on an as needed basis'~when his radiography work load would allow. Based on the AM 2 interview, verification that applicable inspections were limited to hydrocests under Level II supervision and to material heat number transfer verification, and coupled with the simplicity of the involved inspections, no concerns remain regarding this individual's discrepant certification or any possible impact on the hardware.
Error Rate Reinspections Inspector Conducted Subjective Objective AM-1 0 -- -
AM 2 0 -- -
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Attachment 10 Explanation for Placing Inspectors for Related ISAPs Into Phase III c Mechanical TV Electric Histori'al TM 1 This individual was certified 14 vel I to CP-QP 11.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation," on 3/17/82, CP-QP ll.10 "Inspection of Electrical Raceway / Support Systems" on 3/26/82, and CP-QP ll.14 "Structural Steel Inspection Activities" on 3/26/82 with no high school diploma or GED as required by Regulatory Guide 1.58.
TM 2 This individual was certified Level II to QI-QP-11.8 1, "Instrument ano Tubing Installation Inspection", and to QI-QP 11.8-3, "Instrument Installation Inspection", on 8/6/80 with insufficient experience to support the Level II certification.
TM 3 This individual was certified level II to QI-QP 11.8-1, "Instrument and
- Tubing Installation Inspection", and to QI QP il.8-2, "Inspection of the Fabrication of Instrumentation Supports and Rack Assemblies", on 1/15/80 with insufficient experience to support the Level II certification.
TM 4 This individual was certified level II to CP-QP il.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation" on 11/30/80 with insufficient experience to support the Level II certification.
TM 5 l
This individual was certified Level I to CP-QP-il.2, "Surveillance and Inspections of Concrete Anchor Bolt Installation", on 8/28/81 with insufficient experience to support certification as required by Reg. Guide 1.58.
I TM 6 This individual was certified Level I to CP-QP-il.2, "Surveillance &
Inspection of Cor. crete Anchor Bolt Installation", on 11/5/80 with insufficient experience and had not received a GED as indicated. This O
Rovision: 1 Pcgo 119 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 10 (Cont'd)
. individual was then certified Level II to QI-QP 11.8 1, "Instrument and
. Tubing Installation. Inspection", on 2/11/81 with insufficient exp4rience and no CED as required-TM 7 This individual was certified Level I to CP-QP ll.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation", and to CP-QP ll.10,"
Inspection of Elect.
Raceway / Support Systems", on 12/15/82. His education could not be verified as required by Reg. Guide 1.58.
TM 8 This individual was certified Level II to QI-QP 11.41 through 17, Coating Inspections, on 10/9/80 with insufficient experience to support the Level II certification.
TM 9 This individual was certified Level I to CP-QP 11.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation," on 11/13/80 with no high school diploma or CED and a low test score on the exam. This individual was re-examined on 12/16/83, failed the exam, and the certification was not re issued.
Brown & Root Historical Mechanical BM-1 The education and the relevance of experience used as the basis for certification could not be substantiated. The certifications vert for visual examination (VT) and Fabricator Inspector (MIFI) granted 9/8/80.
BM 2 This individual was certified Level II visual examination (VT) on 8/11/78 after re administration of the same exam one day after failure with no documentation of retraining to show evidence of capability.
BM 3 This individual was certified to Visual Examination (VT) and Liquid Penetrant Examination (PT) on 10/26/78 and to QI-QP-11.3 2, "Cable Tray Hanger Insp.", to QI-QP 11.3 4,'"Exposed Conduit, Condulet, Elect. Box &
Support Insp.", and to QI-QP-11.3 5, "Cable Tray Insp", on 3/21/79.
However, there was documented evidence that the activities performed by ll l
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( (Cont'd)
Attachment 10 (Cont'd)
.this individual were considered to be questionable (i.e. performed cable
- tray hanger and accepted required welds that had not been performed and weldsents were accepted that could not have been welded per the design drawing), but no docuakntation of corrective action was available.
BM 4 This individual was certified Level II for Liquid Penetrant Examination (PT) ondiploma.
school 7/19/79 and Leak Testing (LT) on 8/24/79 based on having a high school. However, this individual had not graduated from high BM 5 This individual was certified Level II for visual examination (VT) on 1/26/78 after having taken the Practical Exam twice the same day, first-failing and then passing it.
BM-6
() This individual was certified Level II for Liquid Penetrant Examination (PT) and Visual Examination (VT) on 1/30/79 based on a BA Degree.
this individual's However, school or collegeeducation level. could not be substantiated at either the high BM 7 This individual was certified Level II for Visual Examination (VT) on 7/20/78 without sufficient experience to support the Level II certificatien.
Subcontractor QC Inspectors Hunt HU l This individual was certified as a Level II concrete inspector on 6/28/76 with insufficient experience to support the Level II certificction.
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(Cont'd)
Attochment 10
' Cont'd)
.Bahnson BN 1 This individual was certified as a QC Inspector (no level designator) with insufficient education and experience to the support certification. There was no objective evidence of OJT, and no written exam was available to substantiate capability.
BN-2 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support the certification. There was no evidence of a written exam to substantiate capability.
BN 3 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support certification. There was no objective evidence of OJT and no written exam to substantiate capability.
BN 4 This individual had performed questionable work while employed by Brown &
Root (see BM 3).
BN 5 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support certification. There was no evidence of a written exam to substantiate capability.
BN-6 This individcal was certified as a QC Inspector (no level designator) with insufficient experience to support certification. There was no evidence of a written exam to substantiate capability.
BN 7 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support certification.
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Revision: 1
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RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 10 (Cont'd)
,BN 8 This individual was certified as a 14 vel II, with insufficient education to support certification.
BN 9 This individual was certified as a Level II, with insufficient experience to support certification.
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Attachment 11 Phase III Evaluation of TU Electric Historical Mechanical QC Inspectors Related ISAPs I
Nine TU Electric historical mechanical QC inspectors were referred to Phase III for further evaluation during this portion of the work. The overall results of these Phase III reinspections are shown on the last page of this atta:hment.
Descriptions of the eva.'.uations for each of these inspectors are contained in the following paragraphs.
Inspector TM-1 was placed into Phase III because of inadequate education to support his initial certifications for inspection of Hilti bolts, electrical supports, and structural steel. The computer data base identified over 500 electrical support inspections during the initial 90 days after certification from March 1982 to June 1982. This was a period during which the computer data base accuracy was less than desirable.
However, 110 reinspections from the initial 90 day period after certification were conducted with satisfactory results. Inspector TM 1 is acceptable.
TM 2 was placed into Phase III because of insufficient experience to support certification for inspection of instrumentation. The computer data base identified approximately 69 Hilti bolt inspections, 16 of which were recreatable, 1980.
during the period of concern between August 1980 and October l This was during a period of time when the computer data base was reasonably accurate. The 16 recreatable inspections were reinspected with I satisfactory results. Although the Hilti bolt inspections are not a direct measure of this inspector's ability to conduct instrumentation inspections, the ability to conduct these 16 inspections properly provides some additional confidence that if this inspector did conduct unidentified instrumentation inspections, the results would be satisfactory. The combination of the 16 Hilti bolt inspections, the lack of instrumentation inspections in the computerized data base, and the short period of the time of concern, provide reasonable assurance that this inspector is of no concern.
TM-3 was also placed into Phase 3 because of insufficient experiance to support certification for inspection of instrumentation. The time period in question was January 1980 through November 1980. This time period coincides with the time period during which the computer data base was reasonably accurate. A total of 176 inspections were identified fror the computer data base. Of the 176 inspections, 40 were recreatable and sere reinspected with acceptable results. The 40 inspections, which were all of instrumentation or instrumenta, tion supports except for two Hilti bolt inspections, were originally conducted between March 1980 and November 1980.
These 40 reinspections provide substantial positive information that this inspector was capable of satisfactorily performing the requ!rsi inspections.
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Attachment 11 (Cont'd)
The computer data base identified over 500 Hilti bolt inspections for
' inspector TM 4. The time period of concern was between November 1980 and July 1981. TM 4 va~s placed into Phase III because of lack of experience to
~
support the initial certification for inspection of Hilti bolts. During time frame of concern when the computer data base was reasonably accurate, a total of 51 recreatable inspections were identified and reinspected with acceptable results.
Because these 51 inspections extend over a period of eight months there is less than conclusive evidence that this inspector was initially capable of conducting the required inspections. However, the overall acceptability of these 51 inspections provide a substantial amount of positive information that TM 4 was capable of satisfactorily conducting the required inspect. ions. .
TM-5 was placed into Phase III because of insufficient experience for certification to inspect Hilti bolts. During the period of concern from August 1981 through November 1981 the computer data base identified over 500 Hilti bolt inspections. A total of 260 inspections was reinspected with satisfactory results. TM 5 was acceptable.
TM 6 was placed into Phase III because of insufficient education and h
A. / experience to support initial certifications issued for Hilti bolt inspection in November 1980 and for instrumentation inspection in February 1981. For the Hilti bolt certification, 51 inspections conducted between November 1980 and February 1981 were reinspected with acceptable results.
TM 6 was capable of conducting Hilti bolt inspections. For instrumentation, a total of 30 recreatable inspections were identified, 19 of which had been conducted between July 1981 and December 1981 and the remaining 11 between December 1981 and June 1982. The results of the reinspections for these 30 inspections were unsatisfactory with an objective disagreement rate of 28,174. Subsequent to conducting the instrumentation inspections it was discovered that 35 recreatable instrumentation tubing weld inspections had been conducted by TM 6 between December 1981 and January 1982, a period of time that fell between the '
initial and final 11 instrumentation inspections described above. These 35 inspections were reinspected, also with unacceptable results. Inspector TM 6 was employed until July 1982 and in December 1982, TU Electric prepared NCR No. I-82 02354S, Revision 1 which stated that it had been determined that a 1004 reinspection of instrumentation installations inspected by TM 6 was required. Although a number of nonconforming conditions were identified during the disposition of this NCR, the TU Electric reinspections were not completely documented and did not identify some discrepant conditions. QA/QC PDR 79 was issued to document this condition as well as other reliced problems regarding TU Electric disposition of QC inspector certification problems. An additional 67 O
9 Revision: 1 Page 125 of 138 l RESULTS REPORT '
ISAP I.d.1 h (Cont'd) 1 Attachment 11 (Cont'd)
- ,. recreatable instrumentation tubing veld inspections were reinspected with unacceptable resul_ts. All recreatable or accessible instrumentation inspections that have<been identified have been reinspected. TM 6, although acceptable for Hilti bolts, failed.
TM 7 was placed into Phase III because of insufficient education. A total of 130 recreatable support inspections conducted during the first 90 days after this inspector's initial certification in December 1982 were reinspected with satisfactory results. TM-7 is acceptable.
TM-8 was placed into Phase III because of insufficient experience to support the initial certification for inspection of protective coatings.
No other certifications were held during the period of concern between October 1980 and May 1981 when the computer data base was reasonably accurate. The computer data base identified approximately 750 coatings inspections as having been performed by this inspector. No reinspections were performed because of the reclassification of coatings as non safety related. There are no remaining concerns with this individual.
TM 9 was placed into Phase III because of lack of education to support certification to inspect Hilti bolts in November 1980. This inspector had previously been certified for visual weld inspection by Brown & Root in ,
accordance with ASNT SNT TCLA requirements. ASNT SNT-TCLA requirements for i education and experience are less restrictive than Regulatory Guide 1.58 requirements. The computer data base identified over 1500 ASME pipe support and spool weld inspections between November 1980 and July 1984.
Seven of these inspections were recreatable spool weld inspections that were reinspected. The remaining ASME pipe supporc inspections were not reinspected because of planned TU Electric corrective action in this area.
A manual search of inspection records for Unit 1 did not identify any additional recreatable inspections. This inspector was ratested for inspection of Hilti bolts in December 1983 after the normal termination of his certification and failed the examination. He was not racertified for Hilti bolt inspection. The ability of this inspector to inspect Hilti bolts adequately is indeterminate.
The reinspection results for these Phase III evaluations are shown on the following page of this attachment.
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Attachment 11 (Cont'd)
Historical **
Mechanical : .
.Reinspections Inspector Conducted Subjective Obiective TM 1 110 4,07%
TM 2 3.12%
16 5.41% og TM 3 4 TM-4 0% 2.924 1 3.96% 0.254 TM 5 8.20% 0.434 TM 6 (Hilti bolts) - On TM 6 (Other) 132 04 9.084 TM.7 130 3.554 3,olg M8 0 - ..
- u. ,
7 o% 04 O
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'I Rsvisicn: 1 Page 127 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 12 Phase III Evaluation of Brown & Root Historical Mechanical Inspectors Related ISAPs Seven Brown & Root historical mechanical QC inspectors were placed into Phase III during this portion of the work. The results of reinspections conducted during Phase III evaluations are shown on the last page of this attachment. Descriptions of the evaluations for each of these inspectors are contained in the following paragraphs.
Inspector BM-1 had insufficient education and experience to support his initial certifications for visual weld inspection and mechanical installation and fabrication inspection in September 1980. In December 1981, this same inspector was certified Level III for mechanical equipment ;
installation inspection, also with insufficient education and experience.
No recreatable inspections were identified from the computer data base. A manual search of Unit 1 inspection records identified a small number of additional inspections, all of which were nonrecreatable. TU Electric had identified concerns regarding the ability of this inspector in 1984 and had committed to a 1004 reinspection of his work. Documentation of these reinspections is limited and, based on the Unit 1 manual records search, incomplete. This situation is also addressed in QA/QC PDR 79, that was initially written to address questionable resolution of certification problems relating to TU Electric QC inspector TM-6. The ability of .
i inspector BM-1 to conduct the required inspections satisfactorily is indeterminate.
During Phase I reviews, it was noted by the QA/QC Review Team that inspector BM 2 had failed an examination for visual veld inspection.
Because the same examination was administered the following day with no evidence of additional training, BM-2 wa~s ultimately placed into Phase III for additional evaluation. The computer data base contained over 2,000 entries, and 50 recreatable pipe veld inspections were identified and reinspected. These inspections had been originally conducted over a period of time from August 1978 to July 1980. Although only eight of the 50 inspections were conducted in the first 90 days after certification, the agreement rates were well within the limits. Although not totally conclusive, there is a substantial amount of positive information that BM 2 was capable of conducting the required inspections.
BM 3 was placed into Phase III because information contained in his certification file indicated that inspections of non-existent welds had been documented by this inspector. This problem had originally been identified by the NRC.
The lack of documentation of the evaluation and correction of this concern by' Brown & Root is addressed in QA/QC PDR 79 referenced under evaluations for TM 6 and BM 1 above. The computer data O
l Rovision: 1 Page 128 of 138 ISAP I.d.1 O. (Cont'd)
Attachment 12 (Cont'd) f base identified over 200 cable tray hanger inspections conducted by this
- inspector.
These cable tray hangers were not reinspected because of the cable tray hanger correctivt action program. A manual search of the inspection records for Unit 1 identified .five inspections of welds on electrical equipment supports that could be recreated. However, because no
' inspection criteria for these inspections could be identified, QA/QC PDR 81 was issued and the inspections were considered to be non recreatable for ISAP I.d.1 purposes. The manual search also identified 15 cable tray veld inspections that could be recreated. In a similar. fashion, the original inspection criteria were identified to be incomplete and the inspections could not be recreated. QA/QC PDR 80 was issued to document this problem.
The ability of this inspector to conduct inspections properly is indeterminate.
BM 4, who was initially certified in July 1979, was placed into Phase III because of lack of education. Fifty recreatable inspections were identified during the time period between January 1980 and May 1920. These 50 inspections, consisting of 32 Hilti bolt reinspections and 18 pipe supports, were reinspected with a 9.51% objective attribute disagreement rate, which is well outside the acceptable 54 limit. All 32 Hilti bolt inspections were associated with ASME pipe supports. The computer data base was researched for additional inspections from May 1980 until the termination date of this inspector in September 1980. The only inspections l
i identified during this time frame, when the data base was reasonably accurate, were pipe support inspections, which were not reinspected because of the TU Electric corrective action program being implemented in this area. This inspector failed the evaluation of his inspection capabilities.
A root cause/ generic implication analysis of the failure of this inspector to meet the Phase III acceptance criteria was conducted and is described in Section 5.8.
In January 1978, BM 5 was given a practical examination for visual l
inspection of welds as part of the re certification process. Because this inspector failed the initial examination and was given the same examination with acceptable results the second time on the same day, BM 5 was placed into Phase III. A total of 78 pipe weld inspections were identified during the 90 day period and were reinspected with an objective disagreement rate of 8.33 percent. This disagreement rate falls outside the ISAP I.d.1 limit for acceptability. Prior to conducting any further reinspections, a root cause/ generic implication analysis was conducted. This analysis, described
' in Section 5.8, indicated that the failure was related to one attribute that had no negative impact on,the acceptability of the hardware being inspected. Although BM 5 technically failed Phase III, the root
' cause/ generic implication analysis indicated that no further reinspections or evaluations were required.
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Attachment 12 (Cont'd)
.BM 6 was placed into Phase III because of insufficient education. Because
'of concerns regarding this inspector's ability Brown & Root reconducted over 300 liquid penetrant inspections in 1979 that were originally conducted by this inspector on the fuel pool liner with acceptable results.
hangerthe From computerized data base, TU Electric identified only 21 cable tray inspections. These cable tray hangers were not reinspected because of the corrective action program in this area. A manual search of Unit i records did not identify any additional recreatable inspections. Although no reinspections were available for witness by the QA/QC Review Team, the extensive number of reinspections conducted by Brown & Root with no identified discrepancies provides a substantial amount of positive information that this inspector was capable of conducting the required inspections.
BM 7 was placed into Phase III because of insufficient experience to support certification for visual ilmpaction of welds in July 1978.
Although over 2,000 inspections were identified in the computer data base, they were all cable tray hanger inspections, which were not reinspected because of the TU Electric corrective action program, or conduit inspections that were not recreatable. A manual search of Unit 1 inspection records identified 94 cable tray veld inspections and one electrical equipment support weld inspection that could be recreated, but, as for inspector BM-3, inadequately defined inspection criteria made these inspections non recreatable. These problems are documented in QA/QC PDR 81 and QA/QC PDR 80. The ability of this inspector to conduct the required inspections adequately is indeterminate.
The reinspection results for these Phase III evaluations are shown on the following page of this attachment.
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Attachment 12 (Cont'd)
' Historical Mechanical Error Rate Reinspections Inspector -
, Conducted Subjective Obiective BM.1 0 -- .-
BM 2 50 On 1.784 BM.3 o .. ..
BM 4 50 BM 5 5.004 9.51%
78 3M.6 On 8.334 0 .- --
3M.7 0 .. ..
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Attachment 13 Root Cause Analysis of Phase III Failure for HE 8 Inspector HE-8 failed the Phase III evaluation. This individual was certified as a Level II inspector for conduit fabrication and electrical cable termination inspections in November 1980. At the time of certification, HE 8 was a high school graduate and had six months experience as a electrical QC inspector trainee. TU Electric procedures stated that this inspector "should" be a high school graduate and have two years experience in electrical inspection and testing. ANSI N45.2.6 -
1978, which along with Regulatory cuide 1.58 became a TU Electric commitment in January 1981, recommends that a Level II inspector with a high school diploma have three years of related experience in equivalent inspection, examination, or testing activities. Forty hours of on the job training were normally given by TU Electric to candidates for certification in the two areas in question. HE 8 received the standard forty hours of on the job training for the conduit fabrication inspection certification and 69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> for the cable termination inspection certification.
Examination scores were 844 for cable termination inspection and 874 for conduit TU Electric. fabrication inspection. A grade of 80% was considered passing by There was a significant lack of experience for this inspector from what was normally required. The additional 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> of on the job training in the one area was considered inadequate by the QA/QC Review Team to compensate for this lack of experience; thus, this inspector was placed into Phase III.
A review of the reinspection results was conducted to determine if particular attributes or areas played a more significant role than others in this inspector's failure. In the first 50 reinspections there were 881 objective decision points, of which $5 were in error. Of these 55 disagreements, 40 involved one attribute. In the second 50 reinspections, there were 1323 decision points, of which 64 were in error. Forty nine of these 64 were also related to one attribute, which was the same attribute that involved the 40 errors in the first 50 reinspections. The remaining 15 errors in the first 50 reinspections and the remaining 15 errors in the ,
second 50 reinspections were distributed among 12 different l attributes / items with the maximum number of errors relating to any single attribute being 8.
The attribute with 89 errors (40 plus 49) required the inspector to verify internals in panels and boxes. The detailed procedural instructions relating to this attribute clearly indicated that this inspection was only to be conducted on field installed components. The 89 errors involved HE 8 marking this attribute as "sat'isfactory" when there were no field installed components. The attribute should have been marked "not applicable". There were some cases identified in the 100 reinspections where HE 8 correctly marked the checklist "not applicable". Two other inspectors in Phase III
s R2 Vision: 1 Fage 132 of 138 RESULTS REPORT ISAP I.d.1 O (Cont'd)
Attachment 13 (Cont'd)
. during this same time frame that had reinspections of terminations had similar problems with this attribute. The not result of these errors appears to be that many vendor installed components received an additional site inspection that was not required. When these 89 errors are removed from the composite inspection results, the objective attribute error rate is 1.364. Except for this one problem attribute, for which there is no negative hardware impact, HE 8 fell well within the acceptable error rate limits.
The exact cause for HE 8's problem with this attribute cannot be determined. Although two other inspectors during this same time frame had similar problems, other inspectors in a somewhat later time frame did not have similar problems, although the inspection requirements were essentially the same. Inexperience may have been a factor in causing this problem.
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I Attachment 14 '
Root Cause Analysis of QA/QC PDR 45 The CPSES HVAC subcontractor!s (Bahnson) lack of a satisfactory inspector certification program was one of a number of problems identified regarding this subcontractor's performance. ISAP VII.c determined that the frequency and the potential severity of some deviations resulted in an unclassified trend. The root cause was determined to be a less than adequate development and implementation of the HVAC contractor's program to ensure that HVAC supports were installed in accordance with the design. The discrepancies noted in the Bahnson inspector certification files clearly indicate that Bahnson's control of inspector qualifications was less than adequate. TU Electric failed to ensure that Bahnson developed and implemented an effective QA Program.
In an effort to determine the reason that Bahnson was not adequately controlled by TU Electric, the procurement history of Bahnson services by Brown & Root and TU Electric was reviewed.
Bahnson was awarded the contract in 1977 by Brown & Root. The contract between Bahnson and Brown & Root contained appropriate quality assurance requirements. Brown & Root conducted a p'te award survey of Bahnson and Bahnson's contract award was conditional on the correction of four major findings. In addition, Brown & Root performed reviews of the Bahnson QA Program snd procedures and conducted surveillance and audits of Bahnson work activities during 1978 and 1979. Significant problems were noted by Brown & Root and corrective action was pursued.
TU Electric started to assume control of Bahnson in 1980. This transition was evidenced by a TU Electric /B&R joint QA audit conducted in February 1980. During 1980 and 1981 the responsibility for the control of the Bahnson QA Program shifted from Brown & Root to TU Electric. The TU Electric / Brown & Root audit conducted in February 1980 resulted in 14 deficiencies, six concerns and two observations. In March 1981 another joint TU Electric / Brown & Root audit revealed 11 deficiencies in the implementation of the Bahnson QA Program. However, there is no evidence of any surveillances having been conducted of Bahnson during 1980 or 1981 by either Brown & Root or TU Electric.
In April 1982 TU Electric conducted an audit of Bahnson that resulted in no deficiencies being noted. This audit failed to discover any of the problems that were noted by the NRC in early 1983.
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Attachment 14 (Cont'd)
During 1983 and thg first half of 1984. TU Electric conducted eight audits of Bahnson activities that resulted in over 50 deficiencies being identified. Even though Bahnson was attempting to correct specific identified problems, their overall prograsumatic controls were weak. It is noteworthy that TU Electric did not reach this conclusion until a new supervisor was assigned to the TU Electric QA Services Group. As a result of this evaluation, a meeting was held with Bahnson management, and TU Electric inspection personnel were assigned to observe and verify the adequacy of the Bahnson effort. It seems clear that the previous TU Electric management failed to appreciate the meaning of the previous audit results and the need to take more aggressive action to improve the effectiveness of the Bahnson QA Program.
During the second half of 1984, Bakson's performance apparently improved and TU Electric decided in early 1985 to audit Bahnson only on an annual basis in lieu of the quarterly audits that had been conducted since early 1983. TU Electric inspection personnel also ceased routine inspections at j this cine.
l In early 1986, a comprehensive site surveillance program was implemented on Bahnson activities under the direction of the W Electric Site QA Organization. These surveillances resulted in many deficiencies. It became clear that significant problems remained uncorrected. The Bahnson contract was terminated by TU Electric in early 1987.
The lack of delineation of responsibilities between TU Electric and Brown &
Root may have contributed to the lack of effective control of Bahnson. In addition the lack of defined organizational interfaces between W Electric Site QA and W Electric Dallas QA contributed to a lack of appreciation of i
the magnitude of problems being noted in the Bahnson QA Program. There did not appear to be a clear understanding of which group was responsible for conducting surveillance of Bahnson.
TU Electric QA did not implement.a comprehensive system to verify the adequacy of Bahnson's activities. It appears that W Electric intended to exercise QA control primarily by means of an annual audit of Bahnson activities. Given the complexity of the Bahnson HVAC scope of work and the quality problems noted by Brown & Root. TU Electric management should have been aware that additional measures were necessary. Review of TU Electric site QA procedures indicates that procedure CP-QP 19.2 entitled "Site Surveillance" was developed in,1979. However, it was deleted in January 1980. Procedures CP.QP 19.0 and CP.QP 19.6 vaguely reference site surveillance; however, it is not clear that they were ever intended to apply to surveillance of Site subcontractors. As a result, no TU Electric surveillances were performed of Bahnson until 1984
I R: vision: 1 Page 135 of 138 ISAP I.d.1 (Cont'd)
Attachment 14 (Cont'd)
TU Electric had a system for conducting reviews of Bahnson procedures. !
This system ensured'that tho' appropriate Bahnson procedures were routed to Brown & Root. TU Electric Engineering, TU Electric QA and also Cibbs & Hill l 1
Engineering. However, it was not clear what the review responsibilities of the various groups were. I Therefore many 7roblems thst were noted during the implementation of Bahnson's QA Program were not identified and corrected during the review process.
As previously discussed, it does not appear that there was any exchange or coordir.ation of information between TU Electric's Site QA organization, which was reviewing Bahnson's procedures, and the TU Electric Dallas QA organization, which was conducting audits of Bahnson.
The failure to implement a comprehensive system consisting of effective .
reviews, surveillances, and audits was caused by the apparent lack of full appreciation by previous TU Electric QA management of TU Electric's role in ensuring that Bahnson was implementing an effective QA Program. This is considered to be the root cause.
A contributing cause for TU Electric's lack of control of Bahnson was determined to be the lack of an effective engineering interface between Gibbs & Hill and Bahnson. The Engineer did not review the contractor's faorication drawings to verify that these drawings mer the design intent of the specification.
If these types of reviews had been conducted it is likely that the inaccurate data and inadequate duct support drawings would have been noted and corrected in a timely manner. This review process would also have resulted in fabrication being done to reasonably accurate drawings and it would have been far less difficult to prepare the as built drawings.
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[d (Cont'd)
Attachment 15 Summary of the Results of the ISAP I.d.1 Evaluations of ISAP VII.c QC Inspector Certification Deviations ISAP VII.c documentation reviews of inspection documentation included the verification that the inspector who prepared the inspection documentation was properly certified. Specifically, the fellowing attributes related to QC inspector certification were checked for each documentation review package:
A valid certification exists for the inspection activity being conducted.
The level of certification (i.e. , Level I, II, or III) was appropriate t
for the inspection work being conducted, and The inspection work was conducted during the period for which the certification was valid.
Approximately 3,600 Deviation Reports (DRs) were written during implementation of ISAP VII.c and were evaluated by ISAP I.d.1 personnel.
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( Approximately 1,800 of these DRs were determined to be valid. These valid DRs were categorized by type for evaluation purposes. The following are descriptions of categories, the quantity of valid DRs in each category, and a characterization of the impact of the deviations:
- 1) Inspector not Certified in the Area, Discipline, or Procedure for the Type of Inspection Performed There were a total of 950 valid DRs issued in this category. This category pointed out that a specific certification had not been issued for the inspection instruction being utilized by the inspector as required by certification procedures. During the evaluation of these DRs by the I.d.1 personnel, an investigation was conducted to determine whether records of training and examinations, related specifically to the activities that had been performed, existed.
The individuals evaluated in this category, despite not having the proper certification, were determined to have the necessary background and experience and sufficient amounts of training and examinations to show capability and they were considered to be qualified to perform the required inspections.
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(Cont'd) l Attachment 15 l
(Cont'd)
' 2) Inspectors Certified to General Inspection Procedural Series (CP-QP- ) Without Training or Examination Documentation Related Directly to Area Being Inspected There were a total of 183 valid DRs issued in this category. Durin8 the evaluation of the DRs, if applicable documentation of training and examinations could not be located, the DRs were validated. Further i !
evaluations were conducted to determine if the individual was capable l
l of conducting the required inspections. These evaluations considered the individuals overall experience and education, certifications held ,
l in the same area or discipline but issued by another contractor (i.e.,
' a TU Electric QC inspector holding Brown & Root QC inspector certifications), or a similar certification closely related to the inspection work that was performed.
The individuals evaluated in this category, despite not having the l proper certification, were determined to be capable to perform the required inspections.
- 3) Inspector Certification not Current at the Time of Inspection A total of 157 valid DRs were issued in this category. This category of DRs identified inspectors who had performed inspections during the time period after successful completion of training and examinations but prior to the completion of the official certification documentation. They also identified inspections that occurred after expiration of certifications but prior to racertification.
The individuals in this category, despite not having valid certification documentation, vers determined to be qualified to conduct the required certifications by virtue of the fact that training and examinations had been successfully completed or they had been performing inspections continuously in the area of certification and the certifications had lapsed for only a relatively short period of time.
- 4) Inspector Certified Without Certification Expiration Date Noted on Certification Form Af ter January 1981 A total of 116 valid DRs were issued in this category. ANSI N45.2.6, which became a requirement in January 1981, required certification expiration dates to appea'r'on certification documentation. Although 9
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Attachment 15 (Cont'd) th6 documentation was technically incorrect, the related inspections were all conducted during the period of times in which the certifications we're valid.
5)
Inspector Certified Level I Where Level II Certification was Required Six valid DRs were issued in this category. These six DRs involved three inspectors Level II inspector.whoFurther signed attributes without a co signature by a evaluations of these inspector's qualifications, including education, experience, training, etc., 1 versus the attributes in question, determined that they were capable l of conducting the required inspections.
- 6) Individual Conducting Inspection was not a QC Inspector Only one DR was issued in this category. This DR identified a case in which one of four attributes for inspection of the fuel pool liner was conducted by an individual who could not be identified. This is an isolated case and because the fuel pool liner is not safety related, there are no further concerns regarding this DR.
O' 7) Inspector lacked Sufficient Education and/or Experience 4
A total of 373 DRs, involving 14 inspectors, were placed in this
. category. These DRs would have been invalidated under normal circumstances, except that the Phase I and II evaluatior.s identified insufficient lack of education and/or experience that resulted in these inspectors being placed into Phase III for additional evaluation. The Phase III evaluations determined if the individuals were capable of performing the required inspections despite their lack of education and/or experience. The 14 inspectors are HE 1, HE 4, 2
IC 1, NM 1, TM 1 TM 5, TM 6, TM 7, BN 2, BN 5, BN 6, BN 7, BN 8, and BN 9.
ResultsThe results of the Phase III evaluations are suamnarized in this Report.
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