ML20151P336
| ML20151P336 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/21/1988 |
| From: | Jason Christensen, Young J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#288-6114 OL, NUDOCS 8804260140 | |
| Download: ML20151P336 (62) | |
Text
,
(NEE 45" 1
4 6//9 00CKETED Filed:
April 21, 1980 UNITED STATES OF AMERICA
'58 APR 21 P3 :54 NUCLEAR REGULATORY COMMISSION
'.n.e c - - ~ -
before the Oc c.. i. i.,,,.
g ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES ELECTRIC
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Recardina Action Plan Results Report I.d.1 In accordance with the Board's Memorandum; ProDosed Memo-randum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Poak Response Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan I.d.1, "QC Inspector Qualifications."
Openina Reauest:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
All checklists used during the implementation of ISAP I.d.1 are attached, as follows:
BeOA2kSO R
PDR O
hh
]>5
1.
Attachments 1, 2, and 3 included in the Results Report j
were used as aids in conducting the reviews and evalua-tions and documenting the results.
2.
Checklist for the review of Brown & Root procedures CP-QAP-2.1, Rev. 13, and QI-QP-2.1-1, Rev.
7, to the requirements of ASNT-SNT-TC-1A, 1980 3.
Chucklist for the review of Brown r; Root procedures CP-QAP-2.1, Rev. 13, and QI-QAP-2.1-5, Rev.
9, to the requirements of ANSI M45.2.6, 1978, and Regulatory Guide 1.58, Rev. 1 4.
The ERC reinspection matrix, as defined in QI-005, was used to document reinspection results and the compari-son of results.
Question No. 1:
1.
Describe the problem areas addressed in the report.
Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it dis-cover about the QA/QC documentation for those areas?
How extensive did it believe the problems were?
Response
This Action Plan was prepared to address the concerns raised by the NRC's Technical Review Team (TRT), which found in the training and certification files a lack of the supportive documentation required by procedures and Regulatory Requirements for personnel qualifications.
The NRC TRT concerns focused on TU Electric electrical QC inspectors.
Based on the following considerations, a decision was made to evaluate, as part of the ISAP I.d.1 evaluation, all,
TU Electric and Brown & Root QC inspectors employed on site as of March 1985.
1.
A review of documentation for all TU Electric electri-cal QC inspectors, including those who had left the job sita prior to March 1985, would develop a significant amount of historical information regarding the adequacy of the overall Comanche Peak QC inspector certification program.
2.
A review of documentation for all currant QC inspectors would determine if the current TU Electric and Brown &
Root QC inspector certification programs were ade-quately implemented or, if required, would permit appropriate corrective action to be identified.
In addition, a decision was later made to conduct a I.d.1-type evaluation of inspectors identified during implementation of ISAPs VII.a.8, VII.b.1, VII.b.3, and VII.c.
Subsequently, the scope of ISAP I.d.1 was broadened to include these addi-tional evaluations in the final conclusion on the overall ade-quacy of the CPSES site QC inspector certification program.
The evaluations confirmed the validity of NRC issues identified in NUREG-0797, Supplement 7, Page J-110.
Problem areas and objectives are described in section 3.0 of the Results Report, "Background."
Section 4.1 defines the methodology used to evaluate the NRC TRT concerns and to accomplish the major objectives of this Action Plan.
No further action was taken to define problem I
\\
\\
e
~
l areas, other than to review inspector certifications as required by tne Action Plan and described in the Results Report.
Section 6.0 summarizes the conclusion reached as a result of the imple-mentation of this Action Plan.
Question No. 2:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be inter-preted or applied.
Response
Quality Instruction QI-005 details the use of the reinspec-tion matrix (checklist).
Other checklists extracted specific requirements from applicable standards, Regulatory Guides, and procedures and were prepared and used by experienced personnel, knowledgeable about the specific requirements, as an aid in con-ducting the reviews and evaluations and documenting the results.
Question No. 3:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response
1 i
When reinspections were required in accordance with ISAP i
I.d.1 methodology, they were performed by qualified TU Electric or Brown & Root inspectors (overviewed 100% by qualified QA/QC l
Review Team inspectors) using the same revisions of the inspec-tion procedure and criteria as were used in the original l
inspection.
As explained in Section 4.1.3 of the Results Report, "Care was taken to assure that the item was reinspected to the sane criteria as that used for the initial inspection."
The completed ERC reinspection matrix, as defined in QI-005,
-4
listed the inspection attributes "expressed or implied" from the initial Project procedures.
Question No. 4:
4.
Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.
Response
Checklists used for evaluation or reviews were based upon the requirements of ANSI N45.2.6-1978, Regulatory Guide 1.58, Rev.
1, and/or procedures and did not contain fewer attributes than required for conformance to codes.
To determine if the original inspector was capable of performing the required inspections, the revisions of inspection procedures and criteria used during reinspections were the same as those employed in the original inspections.
However, attributes were not included in the sample if, for example, they had been disturbed or changed and subsequently reinspected by another inspector or if they were inaccessible or not recreatable to the initial inspection requirements.
The reinspection matrix forms identified all inspection attributes even if the attributes were inaccessible or not recreatable.
"Inaccessible" and "not recreatable" are defined as follows:
"Inaccessible" means that extensive dismantling would be required to gain access for direct reinspection, such as in the case of piping, reinforcing steel, or conduit that is embedded in concrete.
"Not recreatable" means that a process or event cannot be recreated.
Examples are measurement of pull force during cable pulling, measurement of interpass weld temperature, or performance of receiving inspection.
Question No. 5:
5.
(Answer Question 5 only if the answer to Question 4 is that the checklists do contain fewer attributes.)
Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.
ResDonse:
This question is not applicable because the objective of ISAP I.d.1 was to assess the qualifications of QC inspectors.
Question No. 6:
6.
Set forth any changes in checklists while they ware in use, including the dates of the changes.
Response
No substantive changes were made to the checklists during itaplementation.
Question No. 7:
7, Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other practical training.
If the train-ing has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
Response
No training was conducted in the use of checklists, nor was any required.
Personnel familiar with codes, standards, and l
procedures prepared the checklists, which were used by experi-enced personnel and certified inspectors familiar with the requirements.
In some cases, the person who used the checklist also prepared it.
QA/QC Review Team personnel who used the reinspection matrix (checklist) were required to read Quality Instruction QI-005 and attest by their signatures that they had read and understood the instruction.
TU Electric / Brown & Root QC inspec-tion personnel had current certifications to conduct the required inspections.
Question No. 8:
8.
Provide any information in Applicants' possession concern-ing th' accuracy of use of the checklists (or the inter-observer reliability in using the checklists).
Were there any time periods in which checklists were used with questionable training or QA/QC supervision?
If applicable, are problems of inter-observer reliability addressed statistically?
Response
Each attribute was reinspected by TU Electric or Brown &
Root inspectors who were currently certified to conduct the required inspections (verified by the QA/QC Review Team), and independent third-party QA/QC Review Team inspectors performed a 100% overview by witnessing all reinspections.
At no time were checklists used with persons with questionable training or supervision.
The issue of inter-observer reliability was not applicable.
Question No. 9:
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use of the checklists.
Provide the factual basis for believing l
that the audit and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the validity of conclusions.
Responsg:
Following is a list of five internal audits and two sur-veillances that were conducted on use of checklists by personnel implementing the ISAP:
ERC Audit 85-01, 9/23-26/85 ERC Audit 86-04, 7/21-31/86 ERC Audit 86-05, 8/18-22/86 ERC Audit 86-06, 9/15-19/86 ERC Audit 87-02, 2/23-27/87 ERC Surv. II8523, 12/11/85 ERC Surv. II8643, 10/17/86 No findings or discrepancies were identified except by the surveillance on December 17, 1985, which found discrepancies involving inadequate documentation of certain reviews conducted by the Special Evaluation Team.
These were documented on Corrective Action Request (CAR) CP-014.
Appropriate corrective action was taken by the QA/QC Review Team to resolve the con-cerns, and the CAR was closed on February 7, 1986.
Question No. 10:
10.
Report any instances in which draft reports were modified in an important substantive way as the result of management action.
Be sure to explain any change that was objected to (including by an employee, supervisor, or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.
Explain what the earlier drafts said and why they were modified.
Explain how dissenting views were resolved.
Response
After the initial evaluation of inspection personnel for ISAP I.d.1 and the preparation of Rev. O of the Results Report,
-8
the CPRT, with the concurrence of the SRT, decided to increase the scope of ISAP I.d.1 to include additional related data that was then becoming available and that would allow an overall con-clusion to be reached on the adequacy of the CPSES site QC inspection certification.
With the agreement of the QA/QC Review Team Leader, the Issue Coordinator, and the SRT, the scope was expanded so that the final conclusion on the overall adequacy of the CPSES site QC inspector certification program included evaluations from related ISAPs.
The increase in scope resulted in a I.d.1-type evaluation on an additional 268 TU Electric, Brown & Root, and other site subcontractor personnel, in addition to the 319 inspectors evaluated in accordance with the original scope of ISAP I.d.1.
Section 4.2, Revision 1, of the Results Report for ISAP I.d.1 describes the scope and methodology employed to evaluate inspectors for the related ISAPs.
Question No. 11:
11.
Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached.
How were each of these un-expected difficulties resolved?
Response
No unexpected difficulties were encountered in implementing I
this Action Plan.
Question No. 12:
12.
Explain any ambiguities or open items in the Results Report.
ResDonse:
Two open items resulted from implementation of this Action Plan.
These are discussed in Sections 5.8.6 and 5.8.7 of the Results Report and describad below:
- QA/QC-PDR-80 and -El document inadequate inspection pro-cedures and inadequate acceptance criteria for inspection of cable tray welds and welds en 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 were to be determined during the Collective Evaluation process.
Collective Evaluation determined that the experience level of personnel respon-sible for preparation, review, and approval of inspection procedures had been upgraded and the review requirements properly defined, concluding that the current QA inspec-tion programs were adequate under 10CFR50, Appendix B, Criterion X.
However, a recommendation was made that TU Electric review historical inspection procedures to iden-tify time periods in which safety-significant attributes were not subject to adequate inspection.
For attributes that were identified but not scheduled for reinspection in the Post-construction Hardware Verification Program, an engineering evaluation was to be performed, including consideration of available inspection data, to bound the potential safety consequences of deviations that might exist over the estimated range of as-built conditions.
In cases in which acceptable bounds could not be estab-lished, additional data was to be obtained through re-inspections or other means as necessary to demonstrate the adequacy of installed hardware.
- QA/QC-PDR-45 revealed that a number of Bahnson inspectors were not properly certified and identified problems in the Bahnson inspector certification program.
This PDR was classified as a program deficiency because of the extensive evaluation required to determine the effect of the deficiency on the quality of construction.
The potential generic implication of this QA/QC program deficiency was referred to collective evaluation for resolution.
During Collective Evaluation, the historical QA programs for control of site subcontractors were determined gener-ally to be adequate, with the exception of TU Electric's program covering work by Bahnson.
l Hardware discrepancies revealed during Phase III re-inspections were separately documented as required by the TU Electric / Brown & Root nonconformance system.
Any of these discrepancies determined to be reportable by TU Electric to the NRC, in accordance with the requirements of 10CFR50.55(e), were to be considered by the QA/QC Review Team during Collective i
Evaluation for impact on the overall conclusions about the ade-quacy of construction and the QA/QC program.
TU Electric l l
l.
completed this task before the Results Report was issued, and none of the items were considered reportable.
This item was considered closed.
Question No. 13:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or super-visor was reviewing or evaluating his own work or supervis-ing any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Response
To the best of our knowledge, no conflicts of interest exist.
Question No. 14:
14.
Examine the report to see that it adequately discloses the thinking and analysis used.
If the language is ambiguous or the discussion gives rise to obvious questions, resolvo the ambiguities and anticipate and resolve the questions.
Response
Mr. J.
E.
Young, the Issue Coordinator, has reexamined the Results Report and sees no ambiguities or obvious unanswered I
questions other than those addressed in question 12.
We believe j
that the extensive review process has eliminated any ambiguities.
Respectfully submitted, w
Jam'es E.
Young j/
[
ISAP I.d.1 Issue Coordinator l
- 12
I' l
b 0 dL h Jon D. Christensen Deputy Review Team Leader i
The CPRT Senior Review Team has reviewed the foregoing i
responses and concurs in them.
4 i
i i
i i
l P
- 13
CFRTIFICATIC~tLEVEL5 & OITIONS (TALIFICATION REgillrlVilWTS lit (D LEVEL 1 1.EVEL 11 IEVEL III II(M TO IfSE THE MATRIX Al.T.
1 2
1 1
2 3
4 1
2 3
4 5
6 7
8 181C31 SONIOL CRAI4*A1E X
X X
X X
EACll COLlHN REPRESENTS A SET OF ASS (III ATF DFCklE, REl.ATrD X
X X
X QUALIFICATION REQUIREtlENTS 4 YFANS COI.IFCE DFCHFr X
X X
X WHICH, IF MET, WOULD MAKE O RFIATED Inst. ENPFR.
X Tile CANDIDATE CERTIFIABI.E.
1 prNrilS Fl.LA11'D INSP.
EXI'lI21EMCE X
~
All OF Tile X's IN A COLUMN PRIST 4 PWTils Rl:1.AT11) INSP.
BE NET, Til0S TIIERE ARE TIIREE (3)
CHITRIENCE X
X ALTERNATIVES OR SETS FOR IIVEL I 1 YFAk FEIATED INSP.
CERTIFIC/ TION, ANY ONE OF 1411CH EXPFRIl fE X
MICitT APPLY ETC. FOR LEVEL II 3 iTARS RELATED INSP.
& III.
GItkiENCF X
5 YTARS REl.ATED INSP.
LEVEL II ALT. I REQUIRES TifAT Tile X
INSPECIOR llAS HAD PRIOR TXITRIENCE 7 YFARS REIATED INSP.
CERTIFICATION PfEETING ONE OF 11fE IVPIRIFNCE X
ALTERNATIVES IINDER LEVEL I.
10 YEARS RELATED INSP.
EXITRIFFE X
"RE1ATTD" EXPERIENCE IS INSPECTION SItFFICIENT NtK' LEAR OA EXPERIENCE PER THE PROCEDURE.
17AINING X
X X
n cn 5 YEARS RELATED INCL..
NCTTES: ANSI STANDAkD N45.2.6, 1978 O#
- o 7 YTARS P1'O EAR X
REQUIRES:
N ea tr. d b 7 YiAQS RFLATTP 11401..
21 TARS litfCIIAR X
I. 6 YEARS AS A CORRESPOffDING LEVEL
- f. YEARS RFLA1TD INet. 2 II QC INSPECTOR.
Y1SKS QC lt:SP. & 2 YEARS
- 2. 2 YEARS AS CORRESPONDING LEVEL ON Ntf0.FAR (PMr1E 2)
X II QC INSPECIVR.
- 3. IlSE OF CORRECTIVE CIASSES NOT 1 YEAk SATISFACTOEY ITktDRt1ANCE IN CURRESPOt: DING ADDRESSFD.
AP. O (p* 1F(11tilCI AN (twrlY R)
X
- 4. COI.OR VISION TEST N(Fr ALWAYS IYEARS SAIISFACI1*Y REQlllRED.
Pe rDMIANCE IN O*RESPONDitK:
- 5. PERFORMANCE CAPABILITY NOT AS A Gr it:SI'ECTOR (N(TTE 1)
X MANDATORY AND MAY NUT BE PART M 1 EARS RELA 10D IXPERIENCE OF CERTIFICATION EXAM PROCESS.
I INCL. 2 YTARS QC INSPECTION
- 6. O_lT DEPENDS ON PRIOR EXPERIENCE
$k" (NETTE 2)
X AND CDNTENT NOT DEFINITIVE.
PitYSICAl. EXAttit:AT!ON(tNITE 7)
- 7. NO SPECIFIC REQUIREMENT FOR A O
FYF TFST (VISIOi4)
(turTE 1) X X
X X
X X
X X
X X
X X
X X
X PIIYSICAL EX.sM EXCEPT lilE EYE k "*
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(?!nTE 4)
TEST.
INItRI"TRINATION - 4A X
y X
X X
X X
X-X X
X X
X X
X
- 8. IF "QC TEGINICI AN" & "QC ItttI:RAtttATIC TRAltilix; INSPEC10R" MEANS CERTIFIED AS Pr21Y*t1AnC1' 14 tt AS11 ATION LEVI:L I & II RESPE(TIVELY T1 TEN IN11 M tills COMPLIES WITil ANSI.
- i. w. ga
. 'l CFRTIFICATION LEVELS & OITIONS It&R 1RA1NI'X; & CFRT.,
ilLCil. INSP.
"0R CED" WAS ADOED IN 1
11 III REV. 1 JAN. '84 IN Ql-QAP-2.1-5 Rev. 7 1
2 1
2 3
4 1
2 3
4 5
6 7
8 REV. 5 "QA TECHNICI AN WIT 11 IIICH SCH001. & ZERO 11C11 50 001. CRAD. OR CI D X
X X
X X
FXPtRIENCE" WAS ADDED; j
bS$MI ATE IECFFF, RFIATID X
X X
X IN REV. 6 JUNE '84 IT
& YEAkS 011tECI' CRAD.
X X
X WAS DELETED. OT11ERWISE 1 PEOnt3 PELATFD INSP. f:XPt:R.
X
_ THIS NATRIX WAS APPLICABLE 6 PtWTit3 RI'LATFD INSP. EXPER.
X X
FROM JAN. 14, 1982 TO DATE.
1 YTAR RE1.ATFD INSP. EXITR.
X 1 YFARS MFIA1TD INSP. EXPFR.
X QI-QAP-2.1-5 REV. 7 X
11/15/84 REFERS TO ANSI 5 TFARS REIATFD INSP. EXITR.
X N45.2.6 1978 BUT ICP 7 TTARS REIATFD INSP. FXPER.
10 YFARS RFIATED INSP. EXITR.
X REC. CUIDE 1.58, I YLAf: AS IIVFL i X
REV. 1, HOWFVER IT 6 YFARS AS LEVEL !!
X APPEARS TO MEET T11E REC.
CUIDE REQUIREPENTS AT
. YEARS RELATfD INSP. EXPER.
X LEAST FOR !!ICH SCHOOL y
INCL.imitX'. 2 N11CL.
7 YlARS RF1.A1FD INSP. EXPFR.
DIPLOMA, IF ICE 70R Nmm X
SPECitTING ALTERNATES O$
it.CLifDitx; 2 tilTL.
t.tri. OA TRAININC X
X X
TO Tile RE00ft1 ENDED EDUCATION r, s AND EXPERIENCE CUIDELINE:
a'. o.
ft YEARS RFI ATFD INSP. EXPER.
trM'lFDING 2 hlTI.. A 2 LEVE1. 11 SEE PAR. 3.2.1 "OIlfER X
FACIORS...... ".
OR FfltIIVAI.lM M YEAES FFIATFD INSP. EXPER.
1 PRIOR TO JAN. 1982, Init' DING 2 AS LEYit 11 OR FrtflVALENT X
QI-QAP-2.1-1 REV. 1 F XAtt, Cl OSI D B(OK, CEN
- L X
X X
X X
X X
X X
X X X
X X
2/13/81 APPLIED TO B(7TH j
1:X Att, OITN NWW, SPI'CIFIC X
X X
X X
X X
X X X X
X X
X MECH. INSPECTORS & NDE I:XAt*, PRACTICAL.
K X
X X
X X
X X
X X
X X
X X
PERSONNEL. ITS SCOPE 75Att, EYE, AWITY & CotDR X
X X
X X
X X
X X
X X
X X
X WAS TO MEET Ti1E INTENT OF l'FADitM; ASSICt#WNT X
X X
X X
X X
X X
X X
X X
X ASNT-TC-1-A, ASME CODE SEC l'OPttAL CI ASSR(sel TRNC OR 0.lT X
X X
X X
X III DIV 1, AWS DI.1, ANSI 5.d B31.1,AND ANSI N45.2.6
- W ANST-TC-1A 1975 WAS REITRENCED,
- 8 AND "1974 JITIE EDITION" WAS
' k **
GIMPllTTED TO (APPARENTLY I
MEANT 1975). ASME CODE OF 1974 VAS GM911TTFD TO, AS WAS ANSI N45.2.6 (NO DATE).
i Revision:
2 Page 17 of 20 ISAP I.d.1 (Cont'd)
ATTACHMENT 3 INSPECTOR CERTIFICATION EVALUATION SLW.ARY Name:
SS#:
Applicable Education:
A
/>
Manner of Verification:
hv Applicable Verified Prior Experience:
/>
\\(
V Initial and Discrepant Certifications:
Level Cer ti ficAtio Date Certified M N)
//H
' \\"<
v
\\ v Diser a les Noted:
A V
Signature:
Date:
RCvision:
2 Page 18 of le
~
ISAP I.d.1
~
(Cont'd)
ATTACHMENT 3 (Cont'd)
INSPECTOR CERTIFICATION EVALUATION SLTtARY (CONTINLTD)
Name:
SSf:
Recommended Corrective Action:
A
~V (Np
\\ V/
/
A Signature:
Date:
~
^
_xx-Corrective Action Taken:
p N)
/
't b
/(
Signatur Date:
C Acceptt.ble C Unacceptable t
l Signature:
Signature:
Date:
Date:
f,D.I -3 d-l Pcg2 1 of 24 000001
ISAP I.d.1 QC INSPECTOR QUALIFICATIONS
Title:
Review of Specific Brown & Root Procedures to the Requirements of ASNT-SNT-TC-1A, "Personnel Qualification and Certification in Nondestructive Testing" Prepared by:
b V
Date
//6/8 t
Approved by: _
Date
/ f 7
/
/
This instruction / checklist.provides specific direction to aid in the review / evaluation of the following Brown & Root written procedures to the requirements of ANST-SNT-TC-1A, 1980:
1.
CP-QAP-2.1, Rev. 13, "Personnel Training and Qualification" dated February 18, 1986.
2.
QI-QAP-2.1-1, Rev. 7. "Nondestructive Examination Personnel Certification" dated November 20, 1985 including Document Change Notice Number 1.
Each question is directly related by section or paragraph to SNT-TC-1A
. and will be evaluated and answered on an individual basis.
An overall evaluation / conclusion statement is provided in Attribute 34 of this instruction / checklist.
Completion of items 1 through 33 are self-explanatory.
Complete item 34 by entering an overall evaluation / conclusion statement.
1)
Are the definitions used in the proceduras consistent with the definitions for qualification, certification, certifying agency, recommended practice, employer, and training given in SNT-TC-1A (paragraph 2.1 of SNT-TC-1A)?
yes
, no Answer:
1492/ MISC 11
Pcge 2 of 24 obood2 2)
Do the procedures address qualification and certification of NDE personnel for the following methods (paragraph 3.1, SNT-TC-1A)?
Radiographic Testing (RT) i Magnetic Particle Testing (MT) f Ultrasonic Testing (UT)
Liquid Penetrant Testing (PT)
Neutron Radiographic Testing (NRT)
Leak Testing (LT)
Acoustic Emission (AE) yes no Answer:
3)
Do the procedures require that while in the process of being qualified and certified as NDT Level I, personnel should be considered as trainees, that they should work with a certified individual and shall not independently conduct any tests, interpret or evaluate the results of tests, or report test results (paragraph 4.2, SNT-TC-1A)?
yes no Answer:
i l
l l
l 1492/ MISC 11 i
Pcge 3 cf 24 G.00003 4)
Do t he procedures define three levels of qualification as follows (paragraph 4.3, SNT-TC-1A)?
NDT Level 1 - An NDT Level I individ- ' should be qualifieo to properly peiform speci,, ;<'ibrations, specific tests, and specific evaluationa for acceptance or rejection determinatier.s according to written instructions and to record results.
The NDT Level I shall receive the necessar; instruction or supervision from a certified NDT Level II or III individual.
NDT Level II - An NDT Level II individual should be qualified to set up and talibrate equipment and to interpret and evaluate results with respect to applicable codes, standards, and specifications.
The NDT Level II should be thoroughly familiar with the scope and lititations of the aethods for which the individual is qualified. and should exercise assigned ponsibility for on-the-job training and guidance of rt trainees and NDT Level I personnel.
The NDT Level II should be able to prepare written instructions, and to orpu.ize and report the results of nondestructive tests.
NDT Level III - An NDT Level III individual should be capable of establishing techniques and proceduces; interpreting codes, standards, specifications, and piacedurest and designating the particul'ar test methods, techniques, and procedures to be used.
The NDT Level III should be responsible for the NDT operations for which qualif'ad and to which assigned, t.d abould be capable of in arpreting and evaluating results in terms of existing codes, standards, and specifications.
The NDT Level III shculd have sufficient practical background in applicable materials, fabrication, and prodact technology to establish techniques and *o assist in establishing acseptance criteria where none are otherwise available.
The NDT Level III should have gennral familiarity vich other appropriats NDT methods, and should be qualified to tra n and examine NDT Level I and Level II personnel for certification.
1492/ MISC 11 i
Pegs 4 of 24
(
00000.4 4)
(Cont'd) yes no Answert l
r 1
5)
Do the procedures describe the responsibility of each level of l
certification for determining the acceptability of materials i
or cesponents in accordance with the applicable codes.
l standards, specificati0cs, and procedures (paragraph 5.2, l
SNT-TC-1A)?
yes no Answer:
1492/ MISC 11
i l
Page 5 cf 24 0.00005 6)
Do the procedures address the recommended training and experience factors contained in Table 6.3.1 of SNT-TC-1A for NDT Levels I and II (Section 6.3, SNT-TC-1A)?
yes no Answer:
7)
Do the procedures state the following criteria should be addressed for NDT Level III (Section 6.3, SNT-TC-1A)?
Have graduated from a minimum four-year college or university curriculum with,a degree in' engineering or science plus one years experience in nondestructive testing in an assignment couparable to that of an NDT i
Level II in the applicable test method (s).
or:
Have completed with passing grades at least two years of engineering or science study at a university, college, or technica: school plus two years experience in assignments at les et comparable to that of NDT Level II in the applicab); test method (s).
or:
i Have four years experience in an assignment at least comparable to that of an NDT Level I: in the applicable testing method (s).
i 1492/MISCll
"*tMdbs When the individual is qualified by examination, the above requirements may be partially replaced by experience as a certified NDT Level II, or in assignments at least comparable to NDT Level II, in othar methods listed in Par. 3 of this Recommended Practice as defined in the employer's written practice.
yes no Answers e
8)
Do the proc Jurcs address the following itema regarding training (Section 7. SNT-TC-1A)?
Personnel being considered for certification should complete sufficient organized training to become thoroughly familiar with the principles and practices of the specified test method related to the level of certification desired and applicable to the practices t
to be used and the products to be tested.
The training program should include sufficient examinations to assure tnat the necessary information has been comprehended.
Provide for training course outlines for Levels I and 11 personnel which eay be based on technical source material teferenced in paragraph 7.3 of SNT-TC-1A.
yes no l
l i
Answer?
l l
1492/MISCll i
Page 7 ef 24 000007 9)
Do the procedures state that an NDT Level III or his designated representative should administer anu grade examinations (paragraph 8.1, SNT-TC-1A)?
yes no Answer:
l s
10)
Do the precedures state examinations to verify physical and technical qualifications should consist of the following items (Section 8.1, SNT-TC-1A)I Physical (1)
The examination should assure natural or corrected near-distance acuity in at least one eye such that the applica7t is capable of I
reading a minimum of Jaeger Number 2 or l
equivalent type and size letters at a distance of not less than 12 inches (30.5 cm) on a standard Jaeger test chart. The ability to perceive an Ortho-Rater minimum of 8 or similar test pattern is also acceptable.
(2)
The examination should demonstrate the I
capability of distinguishing and differentiating contrast between colors used in the method.
(3)
The examination should demonstrate additional physical capabilities as required by the employer.
(4)
The examination should be administered on an annual basis.
1492/ MISC 11
Prge 8 ef 24 000008.
(5)
Examination results are to be kept on file for the period of certification (see Par.
9.7).
General (Written) (For NDT Levels I and II)
(1)
The general examinations should be addressed to the basic principles of the applicable method.
(2) la preparing the examination, the employer should select or devise appropriate questions covering the applicable method to the degree required by the employer's written practice.
(3)
The questions and answers provided in the applicable separate Question Booklets (see 8.2) are suggested as guidelines for the development of the general examination.
Specific (Written) (For NDT Levels I and II)
(1)
The specific examination should address the equipment, operating procedures, and test techniques that the applicant may encounter during specific assignments to the degret requi, red by the employer's written practice.
(2)
The specific examination should also cover the specifications or codes and acecptance criteria used by the employer in his nondestructive testing procedures.
Practical (For NDT Levels I and II)
(1)
The candidate should demonstrate familierity with and the ability to operate the necessary test equipment, record, and analyze the resultant informatica to the degree required.
l (2)
At least one selected specimer. should be tested and the results of the test analyzed j
by the candidate.
(3)
The description of the specimen, the test procedure, including check points, and the resul'cs of the examination should be documented.
NDT Level III examinations should be in accordance with Par. 8.3.3 of SNT-TC-1A.
yes
__ _ n a 1492/ MISC 11
P ge 9 cf 24 000009 Answer:
11)
Do the procedures state written examinations should be administered without accces to reference material (closed book) except that necessary data, such as graphs, tables, specifications, procedures, and codes, may be provided (paragraph 8.3, SNT-TC-1A)?
yes
_,,, n o Answer:
1 1
1492/ MISC 11 2
Page 10 of 24 0.00010 12)
Do the procedures require all questions used for Level 1 and Level 11 examinations to be approved by the responsible Level III (paragraph 8.3, SNT-TC-1A)?
yes no Answer:
l 13)
For NDT Level I, do the procedures address the following recommendations (Section 8.3.1, SNT-TC-1A)?
General Examination - The recommended minimum number of i
Level I questions which should be given are:
Test Method Number of Questions Radiographic Testing 40 Magnetic Particle Testing 30 Ultrasonic Testing 40 Liquid Penetrant Testing 30 Eddy Current Testing 30 Neutron Radiographic Testing 40 Leak Testing 20 Acoustic Emission 40 Specific Examination - Tht recommended minimum number of questions which sheuld be given are:
Test Method Number of Questions Radiographic Testirg 20 Magnetic Particle Testing 20 Ultrasonic Testing 20 Liquid Penetrant Testing 20 Eddy Current Testing 15 Neutron Radiographic Testing 15 1491/ MISC 11
Pcgo 11 cf 24 000011 Leak Teeting
- 1. Bubble Tsst 15
- 2. Absolute Pressure Leak Test (Pressure Change) 15
- 3. Halogen Diode Leak Tist 15
- 4. Mass Spectrometer Leak Test 20 Acoustic Emission 20 Practical Examination - Proficiency shall be demonstrated in performing the applicable Londestructive tests on one or more samples approved by the NDT Level III. At least ten different checkpoints requiring an understanding of test variables and the employer's procedural requirements shall be included in this practical examination, yes no Answer 14)
For NDT Level II, do the procedures address the following recommendations (Section 8.3.2, SNT-TC-1A)?
General Examination - The recommended minimum number of Level II questions which should be given are:
Test Method Number of Questions Radiographic Testing 40 Magnetic Particle Testing 30 Ultrasonic Testing 40 Liquid Penetrant Testing 30 Eddy Current Testing 30 Neutron Radiographic Testing 40 Leak Testing 20 Acoustic Emission 40 1492/ MISC 11
Pcge 12 of 24 000012 f
Specific Examination - The recommended minimum number of questions which should be given are:
Test Method Number of Questions Radiographic Testing 20 Magnetic Particle Testing 15 Ultrasonic Testing 20 Liquid Penetrant Testing 15 Eddy Current Testing 15 Neutron Radiographic Testing 15 Leak Testing
- 1. Bubble Test 15
- 2. Absolute Pressure Leak Test (Pressure Change) 15
- 3. Halogen Diode Leak Test 15
- 4. Mass Spectrometer Leak Test 40 Acoustic Emission 20 Practical Examination - Proficiency should be demonstrated in selecting and performing the applicable nondestructive tests on one or more samples approved by the NDT Lavel III. At least ten different checkpoints requiring an understanding of test variables and the employer's precedural requircaents should be included in this practical examination.
yes no Answer:
l l
l 1492/MISCll
.x
"6'o*6dia 15)
For NDT Level III, do the procedures address the following examination requirements (Section 8.3.3, SNT-TC-1A)?
Basic Examination (Required only once when more than one method of examination is taken).
(a)
Twenty (20) questions relating to understanding the SNT-TC-li, document.
(b)
Fif teen (15) questions relative to applicable materials, fabrication, and product technology.
(c)
Fifteen (15) questions which are selected from or are similar to published Level II questions for other appropriate NDT methods.
Method Examination (For each method).
(a)
Thirty (30) questions relating to fundamentals and principles, which are selected from or are similar to published ASNT Level III questions for each method, and (b)
Fifteen (15) questions relating to application and establishment of techniques and procedures which are selected from or are similar to the published ASNT Level III questions for each method, and (c)
Twenty (20) e,uestions relating to capability for interpreting codes, standards, and specifications relating to the method.
Specific Examination (?or each method).
(a)
Twenty (20) questions relating to specifications, equipment, techniques, and proceduces applicable to the employer's product (s) and methods employed, and to the administration of the employer's written practice.
yes no Answer:
1492/ MISC 11
l P ge 14 of 24
~000014 16)
Do the procedures allow we.iver of Level III examinations only i
on the basis of demonstrated ability, achievement, experience.
and education, as defined in Par. 4.3.(3) of SNT-TC-1A and, if so, do they state that written certification should be provided and evidence supporting the certification should be on file (paragraph 8.3.4, SNT-TC-1A)?
yes no l
Answer:
I I
17)
Do the procedures require that an NDT Level III or his designated representative be responsible for the administration and grading of examinations for NDT Level I and Level II personnel (paragraph 8.4.1, SNT-TC-1A)?
yes no Answer:
1492/ MISC 11
P go 15 cf 24 000015 18)
Do the procm'.ures require Brown & Root to be responsible for the administration and grading of examinations for Level III personnel even though the actual administretion and grading may be performed by a designated representative of Brown & Root (paragraph 8.4.1, SNT-TC-1A)?
yes no Answert 19)
Do the procedures define how a composite grade based upon the general, specific, and practical oft upon the basic, method.
and specific examinations should be determined (paragraph 8.4.2, SNT-TC-1A)?
yes no i
Answer:
1 l
l i
1492/MIScli
Pcgo 16 cf 24 000016 20)
If weighting factors are used, do the procedures require the total of the weighting factors to equal 1.0 and do the procedures state the weighting factors should be within the following ranges (Section 8.4.3. SNT-TC-1A)?
NDT Level 1 Weighting Factors (a) General - 0.2 to 0.6 (b)
Specific - 0.2 to 0.5 (c) Practical - 0.3 to 0.7 NDT Level II Weighting Factors (a) General - 0.3 to 0.7 (b)
Specific - 0.2 to 0.6 (c)
Practical - 0.2 to 0.5 NDT Level III Weighting Factora (a) Generni - 0.2 to 0.5 (b) Specific - 0.3 to 0.6 (c) Practical - 0.2 to 0.4 The composite grade (Gc) is deterniaad as follows:
Levels I & II; Ce = (Gg x Vg) + (Gs x Ws) + (Gp x Wp)
~
Level 1111 Ge = (Gb x Wb) + (Gm x Wm) + (Gx x Ws)
Where Ge = Composite grade i.g
= Actural grade from general examination in percent Wg
= Weighting factors of general examination Gs
= Actual grade from specific examination in percent Ws
= Weighting factor of specific examination Gp
= Actual grade from practical examination in percent tip
= Weighting factor of practical examination Gb
= Actual grade from basic examination in percent Wb
= Weighting f actor of baLic examination Gm
= Actual grade from method examination in percent Vm
= Weighting factor of method examination yes no Answer:
1492/ MISC 11
Page 17 ef 24 000017 21)
For exari. nations do the procedures specify or recommend that a composite grade of 80% is passing and that a grade of 70% is passing for each general, specific, and practical or the basic, method, and specific examination (paragraph 8.4.4 SNT-TC-1A)?
__,__ yes no Answer 22)
If examinations are administered and graded for Brown & Root by an outside agency, and the outsice agency issues grades of Pass or Fail only, do the procedures require documentation to be in the form of a certified report and indicate the Pass grade may be accepted as 80% for that particular examination (paragraph 8.4.5 SNT-TC-1A)?
yes no Answer:
1492/ MISC 11
Pcge 18 of 24 000s18 23)
Do the procedures require those failing to attain the required grades to wait at least 30 days or show evidence of having received suitable additional training before re-examination (section 8.5, SNT-TC-1 A) ?
yes no Answer:
24)
Do the procedures specify that certification of all levels of NDT personnel is the responsibility of Brown & Root (paragraph 9.1, SNT-TC-1A)?
yes no Answer:
1492/MISCll
Pcg3 19 of 24 0.00019 25)
Do the procedures require certification of NDT personnel to be based on satisfactory qualification, i.e. education, training, and experience; training programs; and examination as defined in sections 6, 7, and 8 of SNT-TC-1A (p6tagraph 9.3, SNT-TC-1A)?
yes no Answer:
26)
If an outside agency is used to provide Level III services, do the procedures require Brown & Root to retain responsibility for certification (paragraph 9.4, SNT-TC-1A)?
yes no Answer:
1
(
l l
l 1492/MISCll
c Page 20 cf 24 0.00020 27)
If outside services for training and examination are utilized, do the procedures require that these services be conducted in accordance with Brown & Root written practices (paragraph 9.5, SNT-TC-1A)?
yes no Answeri 28)
Do the procedures require the following records of certified individuals to be maintained (section 9.6.1, SNT-TC-1A)?
Name of certified individual.
Level of certification and test method.
Education background and experience of certified individuals.
Statement indicating satisfactory completion of training in accordance with the employer's written procedure.
Results of the physical examination prescribed in Par.
8.1.1 of SNT-TC-1A.
Current examination copy (s) or evidence of successful completion of the examinations.
Other suitable evidence of satisfactory qualifications when such qualifications are used in lieu of examinations.
Composite grade (s) or muitable evidence of grades.
Dates of certification and/or recertification and the dates of assignment to NDT.
Signature of employer's designated representative.
1492/ MISC 11
e Pcte 21 of 24 000021 28)
(Cont'd) yes no Answer 29)
Do the procedures require NDT personnel to be recertified at least once every 3 years based on evidence of continuing satisfactory performance or re-examination in those portions of the examinations deemed necessary by the NDT Level III (Section 9.7.1, SNT-TC-1A)?
yes no Aasver 1492/ MISC 11
Pcg3 22 of 24 000022 30)
Do the procedures state NDT personnel may be re-examined any time at the discretion of Brown & Root and have their certifications extended or revoked (paragraph 9.7.2, SNT-TC-1A)?
yas no Answer:
31)
Do the procedures address rules which should be invoked which cover the duration of interrupted service which will require re-examination and recertification (paragraph 9.7.3, SNT-TC-)A)?
yes no Answer:
I l
1492/MISCll
\\
Fcge 3o 24M 32)
Do the procedures specify that an individuals certification is revoked when employment is terminated (paragraph 10.1 SNT-TC-1A)?
yes no Answer 33)
Do the procedures specify that NDT personnel whose.
certifications have been terminated may be recertified to their former NDT levels based on examination provided all of the following conditions are met (section 10.2, SNT-TC-1A)?
The employee has proof of prior certification.
+
The employee was working in the capacity to which he certified within 6 months of termination.
The employee is being recertified within 6 months of his termination.
yes no i
Answer:
I l
l l
1492/MISCll
o P:ge 24 cf 24 00002.4 34)
Evaluation / Conclusion Statement Signature of Reviewer Date 1492/ MISC 11
E3 0.1, 3 g.,g Revisiont 0
.. December 2't 1986
- 1.d.1 N45.2.6 Checklist Page 1 of 11 0.00001 ISAP I.d.1 QC Inspector Qualifications
Title:
Review of Specific Brown & Root procedures to the Requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58. Rev. 1.
Prepared by:
Ik {
L Dater
/ ~ /,
(3 IM h ((
Approved by:
Date:
This instruction / checklist provides specific direction to aid in the review / evaluation of the fellowing Brown & Root written procedures to the requirements of ANSI N45.2.6 - 1978 and Regulatory Guide 1.58 Rev. 1:
1.
CP-QAP-2.1, Rev. 13. "Personnel Training and Qualification" dated February 18, 1986.
}.
QI-QAP-2.1-5, Rev.
9',
"Training and Certification of Mechanical Inspection Personnel" dated November 20, 1985 including Document Change Notice Numbers 2, 3, and 4 Each question is directly related by paragraph to N45.2.6 and applicable section of Regulatory Guide 1.58.
Each question will be evaluated and answered on an individual basis, with an overall evaluation / conclusion statement provided in Attribute 21 of this instruction / checklist.
Completion of items 1 through 20 are self-explanatory.
Complete item 21 by entering an overall evaluation / conclusion statement.
l l
l l
1470/MISCB
Revision:
0 Perctber 2, 1986 I.d.1 N45.2.6 Checklist
~
000002
- 1) Does/Do the procedure (s) clearly define personnel to which the requirements are applicable.
(N45.2.6 Para. 1.2)
YES I l
NO R answer 2)
Is/are the procedure (s) reasonably clear, in not being applicable to ( Reg. Guide 1.58) for the following.
KDE personnel under SNT-TL-la conducting, RT, NT, PT, UT, ET ar.d LT7 Pre-operations, start-up, or operations Test personnel?
YES Q.
. NO R answer:
- 3) Does/Do the procedure (s) assure that only personnel who meet the requirements of N45.2.6 are permitted to perform inspection, examination and testing activities (N45.2.6 para 1.3)?
i YES R No i l
answers l
l 2
1470/ MISC 8
4 R.',visien:
0 December 2, 1986 I.d.1 N45.2.6 Checklist 0.00003
- 4) Does/Do the procedure (s) clearly identify, who is responsible for establishing and implementing the requirements for selection, trsining, qualification and resources necessary, to comply with the requirements of (N45.2.6 para 1.3)?
'* E S I l
NO l l
answer:
- 5) Does/Do the procedure (s) define inspection, examination and testing, in a manner consistent with (N45.2.6 para 1.4)?
YES l l
NO I l
answer:
- 6) Does/Do the procedure (s) define or assign responsibility for planning for staffing, indoctrination and training of personnel in adequate numbers to perform required inspections, examinations and test.
To allow adequate time for aswignrent/ selection / training of required personnel (N45.2.6 para 2.1)?
i YES I l
NO R i
answer:
I 3
1470/ MISC 8
R:visica 0
D;cember.2. 1986 1.d.1 N45.2.6 Checklist 0.0000.4
- 7) Does/Do the procedure (s) adequately address indoctrination of personnel, as to the technical objectives of the project. codes and standards to be used; QA elements to be employed (N45.2.6 para 2.1.1)?
YES [__j NO l 1
answer:
I
- 8) A:
Is the need for formal training programs addressed?
YES U NO I I
B:
Does/Do the procedure (s) adequately specify how they are to be addressed?
YES C NO R C:
Is on-the-job training (0JT) included in the program with emphasis on, actual performance of inspections?
YES I l
NO l l
D:
If training is the basis for certification, are records required to be maintained?
(requirement for A thru D N45.2.6 para 2.1.2)
YES l N0 l l
answer:
4 1470/ MISC 8
Revici:n 0
December 2, )986 I.d.1 N45.2.6 Checklist 2
000005 9)
Are the capabilities of 4 candidate for certification, initially determined by suitable evaluation of the candidates education, experience, training, test results or capability determination.
(N45.2.6 para 2.2)?
YES
[__]
NO l l
answer:
10)
Is job performance of personnel, re-evaluated at least every three (3) years, and are re-evaluations done by evidence of continued satisf actory performance or by redetermination of capability per para 2.2 -' N45.2.6 (N45.2.6 para 2.3)?
YES l l
NO l l
answer:
- 11) Does/Do the procedure (s) provide for the removal of persons from an activity, if during the periedic evaluation or at cry other time, it is determined by the responsible organization that their capabilities are not in accordance with the job qualifications (N45.2.6 para 2.3)?
YES l l
NO I l
answer:
5 1470/MISCB
R:visien:
0 December 2','1986 I.d.1 N45.2.6 Checklist 000006
- 12) Does/Do the procedure (s) require re-evaluation of an individual who has not performed inspection, examination, or testing activities for a period of one (1) year (N45.2.6 para 2.3)?
YES R NO U answer:
- 13) Does the certification record form contain the following information (N45.2.6 para 2.4)?
YES l l
NO I l
employer's name.
identification of person certified.
level of capability.
activities certified to perform.
basis used for certification, including records of education, experience and training.
a.
b.
Test results, where appropriate.
c.
results of capability demonstration.
rest'ts of physical exaninations, wl.ere required.
signature of employer's designated representative.
date of certification.
date of certification expiration.
answer:
6 1470/ MISC 8
R;visitn 0
December 2, 1986 I.d.1 N45.2.6 Checklist
- 14) Does/Do the procedure (s) identify any special physical characteristics need in the performance of activities? If so, is there a requirement for verification by examination at intervals, not to exceed one year (N45.2.6 para 2.5)?
YES I"l NO l l
answer:
- 15) Does/Do the procedure (s) define the minimum capabilities that qualify personnel to perform inspections, examinations and test, at the various levels in accordance with the following:
Level I (N45.2.6 para 3.2)
YES R NO U A Level I person shall be capable of performing the inspections, examinations, and tests that are required to be performed in accordance with documented procedures and/or indust ry practices.
The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of inspection and measuring equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved.
Level II (N45.2.6 para 3.3) l YES j j
NO l l
A Level II person shall have all of the capabilities of a Level I person for the inspection, exar.ination or test category or class in question. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations, and test; in setting up tests including preparition and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations, and tests; in supervising and certifying lower level personnel; in reporting inspection, examination, and testing results; and in evaluating the validity and acceptability of inspection, examination, and test results.
7 1470/ MISC 8 t
Revisitn 0
D ce:ber 2, 1986 1.d.1 N45.2.6 Checklist 000008 15)
(Cont'd)
Level III (N45.2.6 para 3.4)
YES l l
NO I l
A Level III person shall have all of the capabilities of a Level II person for the inspection, examination or test category or class in question.
In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to train and test inspection, examination, and test personnel whose qualifications are covered by this Standard.
Level III (Reg Guide 1.58 section C.5)
YES U NO l l
Level III individuals should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and. test objectives.
ansver:
- 16) Does the commitment to Reg Guide 1.58, take exception to the recon =endations for, education and experience described in Section 3.5 of N45.2.6.
(Reg Guide 1.58 Section C.6)
YES 1
NO l l
answer:
T 8
1470/MISCB j
R;visient 0
December 2, 1986 I.d.1 N45.2.6 Checklist 000009
- 17) If the answer to 18 above is No.
Does/Do the procedure (s) require, education and experience for the various levels, in accordance with para 3.5.1, 3.5.2 and 3.5.3 of N45.2.67 YES I l
NO l l
answer:
- 18) Does/do the procedure (s) require, that personnel who are assigned responsibility and authority to perform the functions listed bnlow, have as a minimum, the level of capability shown.
(N45.2.6 para 4)
YES I I
NO l l
t I
s
}
l I
i
(
I i
9 1470/ MISC 8 i
Revision:
0 December 2, 1986 I.d.1 N45.2.6 Checklist 000010 18 (Cont'd)
Level Project Function L-I L-II L-III Recording inspcetion, examination, and testing data X
X X
Implementing inspection, examination, and testing procedures X
X X
Evaluating the validity and acceptability of inspection, examination, and testing results X
X Reporting inspection, examination, and testing results X
X Supervising equivalent or lower level personnel X
X Qualifying lower level personnel X
X Evaluating the adequacy of specific programs used to train and test inspection, examins'.on and testing personnel X
Qualifying same level personnel X
answer:
10 1470/ MISC 8
R:visicn 0
D;cember 2, 1986 1.d.1 N45.2.6 Checklist 000011 19)
If the procedure (s) provide for a single inspection or test to be implemented by a team or group and personnel not meeting the certification requirements, are used for data taking or in-plant or equipment operation, is there a requirement that these personnel have sufficient training to ensure an acceptable level of competence and performance and that they are supervised or overseen by a qualified individual, participating in the inspection, examination or test.
(N45.2.6, para 4; Reg Guide 1.58 Section C.7)
YES I I
NO 1 I
answer 20)
Is a file of records of personnel qualifications, established and maintained by the employer and is collection, storage and control, in accordance with, ANSI N45.297 (N45.2.6, para 5)
YES l l
NO C answer:
- 21) Evaluation / Conclusion Statement, i
i Signature of Reviewer Date 11 1470/ MISC 8
o Page 1 of 5 ONMATigggy EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM QUALITY INSTRUCTION FOR ISSUE GPECIFIC ACTION PLAN I.d.1 INSTRUCT'ON NO: QI-005 REVISION:
3 ISSUE DATE: 04/23/86 EVALUATION OF INSPECTOR PERFORMANCE Prepared by:
Date:
4-/22//6
/
V[42. 2[P d Approved by:
- -M Date:
Issue Coo inator
/
/
/
4/!d3 h/
Approved by*
. [.
C h dsf Date:
On-Site QA Represen tive 4!M 86 h
Date:
Approved by:
QA/QC Review Team Ifeader a
s QI-005 R vision 3 a
1.0 PURPOSE This instruction defines the reinspection, documentation, and reporting activities required of the ERC Inspection Group to support completion of the actions defined in Action Plan I.D.1.
2.0 APPLICABILITT This instruction applies to all inspectors in I.d.1, whose qualifications were not satisfactorily substantiated by Phases I &
II.
3.0 REFERENCES
3.1 CPRT Action Plan I.D.1 Phase III, Revision 2 4.0 GENERAL 4.1 Responsibilities 4.1.1 The ERC Inspection Group is responsible fort 1.
Assuring that all reinspections, identified in Phase III, are properly performed and documented.
2.
Assuring that tabulation of reinspection result comparisons are accurate.
3.
Reporting final results, for each identified inspector, to the appropriate Review Team Leaders.
4.1.2 All inspectors vill be certified in accordance with ANSI N45.2.6-1978 and Reg. Guide 1.58.
4.2 Policy TUGC0 and/or Brown & Root, as applicable, will provide the ERC inspection group with the information defined in paragraph.
4.1.3.2 of the Action Plan. As a minimum ERC will validate the accuracy of those inspections designated "not recreatable" or "not accessible", by reviewing approximately 10% of the respective records / installation.
e 2
QI-005 Revisicn 3 6
4.0 GENERAL (Cont'd) 4.3 Definitions l
Since ISAP I.d.1 is intended to evaluate Inspector Performance to historical criteria, the term Inaccessible has been broadened to include "without invalidating previous tests / inspections". The meaning defined in the "CPRT App B" was intended to be used in selecting Hardware reinspection samples to be reinspected to current criteria regardless of previous inspection or test.
4.3.1 Reinspection Reinspection, by a qualified TUGC0 or Brown & Root inspector being overviewed 100% by a qualified ERC inspector, using the same revisions of the inspection procedures and criteria as the original inspection.
4.3.2 Inspection Attribute - Each individual activity within an inspection process which requires an accept / reject decision, i.e. weld length, weld profile, lug criup location, anchor embedment length, etc.
4.3.3 Not recreatable Inspection - An inspection attribute (s) which cannot be reproduced. (i.e., weld fit-up, cable pull tension, etc.) or which has been altered from the originally inspected condition, (i.e., subsequently reworked, replaced, or further construction activity affected, such as a separation).
4.3.4 Objective Attribute - An inspection attribute that is not subject to interpretation and does not require any judgement.
(i.e., conductor landed on correct terminal point).
l 4.3.5 Subjective Attribute - An inspection attribute that is subject to interpretation and the specific item being inspected may be viewed slightly dif ferent by various inspectors.
(i.e., conduit marking visible from floor)*.
4.3.6 Inaccessible - A single attribute, or group of attributes which cannot be properly inspected without extensive dismantling or invalidating previous inspection / test results.
i 3
o QI-005 Revisien 3 s
5.0 PROCEDURE 5.1 The appropriate ERC Inspection Discipline Level III is responsible for assuring that the appropriate Inspection Procedures and respective IR's are reviewed and the necessary reinspection matrixes developed to effect satisfactory reinspection and results comparison. The reinspection matrixes shall be reviewed and approved by the Level III prior to use.
5.1.1 The rainepection matrix. Attachment 6.1, will compile the following information:
A.
Identification of all inspection attributes either expressed or implied within the Inspection Procedures.
B.
Correlation of inspection attributes to procedure instructions and or accept / reject criteria.
C.
Objective / subjective designation of each inspection attribute.
D.
Recreatable (A) not recreatable (B) designation of each inspection attribute.
E.
Inspection results, of both the original inspection and the reinspection.
F.
Identification of all inspection criteria used during the ERC overview.
5.2 The ERC Inspection Group will assure that all required reinspections are performed and documented in accordance with the reinspection matrix instructions.
5.3 The ERC Discipline Level III will tabulate the reinspection results for each inspector and provide those results to the QA/QC RTL J., Hansel.
As a minimum, the results reports will identify:
A. Total number of attributes reinspected.
B. Total number of disagreements per objective attriSutes.
C. Total number of disagreements per subjective attributes.
D. Results of review per 4.2 above.
5.4 Final reports will be provided to the I.d.1 Issue Coordinator.
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o QI-005 R;visi!n 3 i
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6.0 ATTACHMENTS 6.1 ERC Reinspection Matrix 9
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5
o Attcchment 6.1 QI-005 Revision 3 Page 1 of 2 ERC REINS? CTION MATRIX Action item /s 1
Page of Reinspected item (T)
Orig. inspector h Inspection Criteria:
Proc /Rev h
DWG/Rev h DCA's Inspection dates: Original b
ERC Inspection: POST IN-P ESS INSPECTION ATTRIBUTES Ql) Qy Q,2)
Q2)
ORIGINAL 0 3)
~ERC 04)
& REFERENCES A
B OBJ SUBJ S
N0/NA LF F
C.D.
U C. D. indicates that the characteristic is either not accessible or not observable for other reasons. All C. D. entries will be explicitly explained in remarks attached to the Matrix.
TUGC0 Inspector ERC 1.evel III Approval ER Inspector Date 15 Date QI-005.1, Revision 1
Att:chment 6.1 QI-005 Revision 3 ATTACNNENT COMPLETION INSTRUCTIONS 1.
Enter applicable A. I. number.
2.
Enter Type of Inspection Item identification, and appropriate additional information desired for case of tracking or tabulation.
3.
Cor.secutively number each page of the matrix and attached remarks or other information.
4 Enter name of original TUGC0 or B&R inspector.
5.
Self explanatory.
6.
Self explanatory.
7.
Self explanatory.
8.
Self explanatory.
9.
Enter type of ORIGINAL inspection.
- 10. Complete in accordance with paragraph 5.1.1 A & B.
- 11. Complete in accordance with paragraph 5.1.1 D.
- 12. Complete in accordance with paragraph 5.1.1 C.
- 13. Enter the original inspection results by checking the SAT /UNSAT block where appropriate.
In the case of N/A or NO the ERC entry in that column will be the same, not a checksark.
14 Enter a checknark in the SAT /UNSAT column as appropriate.
In the C. D. column, enter a checknark if reinspection cannot determine 4
sat /unsat, or enter N/A if the iten did not apply.
NOTE:
When the attribute is designated as
'B' (not recreatable) the TUGCO, B&R and ERC portions of block 13 & 14 for that attribute will be xxx'd out to prevent comparative entries.
TUGC0/B&R are responsible for documenting all non-conforming conditions noted during these reinspections.
- 15. Sign & Date this block when the overview and matrix are complete.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES ELECTRIC
)
COMPANY et al.
)
)
(Appli ation for an (Comanche Peak Steam Electric
)
Oport._ing License)
Station, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I,
Thomas A.
Schmutz, horeby certify that the fore-going Answers To Board's 14 Questions was served this 21st day of April 1988, by mailing copies thereof (unless otherwise indicated,, first class mail, postage prepaid to:
- Peter B.
Bloch, Esquire
- B.
Paul Cotter, Jr.,
Esq.
Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Alan S. Rosenthal, Esq.
Assistant Director for Chairman Inspection Programs Atomic Safety and Licensing Comanche Peak Project Division Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission P.O.
Box 1029 Washington, D.C.
20555 Granbury, TX 76048
- /
Asterisk indicates service by hand or overnight courier.
O o
V *Juanita Ellis Robert D. Martin President, CASE Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory Commission William R. Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000
& Rothwell Arlington, Texas 76011 Suite 700 1025 Thomas Jefferson St., N.W.
Dr. Kenneth A. McCollom Washington, D.C.
20007 Administrative Judge 1107 West Knapp
- William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C.
20555 Suite 1250 1050 Connecticut Avenue, N.W.
- Billie Pirner Garde Washington, D.C.
20036 Government Accountability Project
- Janice E. Moore, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory
-Appleton, WI 54911-4897 commission Washington, D.C.
20555 Susan M.
Theisen, Esquire Assistant Attorney General
Environmental Protection Division Suite 600 P.O. Box 12548 Washington, D.C.
20005 Austin, Texas 78711-1548 Lanny A. Sinkin Robert A. Jablon, Esquire Christic Institute Spiegel & McDiarmid 1324 North Capitol Street 1350 New York Avenue, N.W.
Washington, D.C.
20002 l
Washington, D.C.
20C05-4798 Nancy Williams
- Elizabeth B. Johnson CYGNA Energy Services, Inc.
Oak Ridge National Iaboratory 2121 N. California Blvd.
P.O. Box X Building 3500 Suite 390 Oak Ridge, Tennessee 37830 Walnut Creek, CA 94596
- Dr. Walter H. Jordan David R. Pigott l
881 West Outer Drive Orrick, Herrington & Sutcliffe l
Oak Ridge, Tennessee 37830 600 Montgomery Street San Francisco, CA 94111
0' o i
- Robert A..Wooldridge, Esquire I
Worsham, Forsythe, Sampels i
& Wooldridge l
2001 Bryan Tower, Suite 3200 Dallas, Texas 75201
- W.-G.
Counsil Executive Vice President Texas Utilities Electric -
Generating Division f
400 N. Olive, L.B.-81 Dallas, Texas 75201 l
t l
c Thomas A. Schmutt.
()
Dated:
April 21, 1988 i
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