ML20198D424

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Partially Withheld Assessment of Allegation AQ-3 to Allegation Category Qa/Qc 2, Document Control Re Improper & Inadequate Training & Supervision of Personnel Performing Prerequisite Testing
ML20198D424
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Watson V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230253
Download: ML20198D424 (2)
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1. Allegation Category: QA/QC 4, Training and Qualification
2. Allegation Number: AQ-91
3. Characterization: It is alleged that personnel performing prerequisite testing have received improper or inadequate training and that these personnel receive little or no supervision during testing.
4. Assessment of Safety Significance: After reviewing facility training requirements (procedure CP-SAP-19 and ANSI N45.2.6), the NRC Technical Review Team (TRT) found that there were no specific training requirements for craft personnel providing support to system test engineers (STEs) during prerequisite testing. However, as a shop guideline, the craft personnel supporting STEs were required to read the applicable startup administration procedures (SAPS) or to attend classes on SAPS and startup prerequisite test instructions. Completed originals of the "Startup Personnel Indoctrination Record," "Startup Personnel Training Record,"

and "Startup Personnel Qualification Record," are maintained within the startup group office.

The TRT found documentation verifying that applicable procedures had been reviewed by craft personnel. Additionally, all craft personnel supporting prerequisite testing were journeyman craftsmen (or second class craftsmen in a few cases), and were subject to STE approval for work on a specific system. These craft personnel were specifically instructed, orally, by their supervisors not to perform prerequisite testing unless the STE was readily available. The TRT interviewed'a sampling of STEs, all of whom expressed a high level of confidence for all craft support personnel. The TRT reviewed the education and training records of 15 STEs for compliance with CP-SAP-19, " Training / Qualifications Requirements for Startup Personnel,"

Rev. 5, and found proper documentation satisfying the training and quali-fication requirements for startup personnel. This allegation is also addressed in Test Program Category 4, allegation AT-14.

During the TRT review of the training requirements for craft personnel performing prerequisite tests, it was noted that the file in the Brown &

Root (B&R) electrical general foreman's office did not contain the signed copy of the " Electrical Test Group (ETG) Indoctrination" reading lists for i

I a specific craft test person. The TRT reviewed the originals in the office files of a Texas Utilities Electric Company (TUEC) startup QA specialist.

He informed the TRT that he would try to find the copy requested. The TRT l was reviewing training records when the TUEC startup QA specialist called

! to say he had the copy. He then gave the TRT a copy of the form, signed in ink by the craft person, dated July 15, 1983. The TRT then asked how a copy dated over a year earlier had just been found in very good condi-l tion and why there were no copies available in either file. After making a few phone calls, the TUEC startup QA specialist responded that "the j original was lost and a new one was just now filled out."

l A followup investigation by the NRC Office of Investigation (01) confirmed that the new "ETG Indoctrination" record had been completed and post-dated by the craft person at the request of the general foreman, and had not been reconstructed from historical records. The craft person also informed l . - - . . .

pg g3860512 0-131 GARDE 85-89.. PDR _ J

the NRC Office of Investigations representative that he had indeed completed the "ETG Indoctrination" reading list prior to performing pre-requisite testing.

5. Conclusion and Staff Position: Based on its review of facility require-ments, examination of training records, and interviews with startup personnel, the TRT found that craft personnel had reviewed the procedures specified in the facility training requirements.

Instructions given .to craft personnel and interviews with STEs about the qualifications of the craft personnel they supervised indicated that craft personnel were adequately supervised.on the job.

In one instance, the TRT found a post-dated training record that demon-strated a questionable attitude toward recordkeeping in this area, even though the document in question was not required by station procedures for testing qualifications. The TRT concludes that sufficient emphasis was not placed on the accuracy and completeness of records or on the proper metnod of revising or altering records.

A letter summarizing the findings regarding the concerns of this alleger has been sent to the alleger. No further contact with this alleger is anticipated.

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7. Attachments: None.

Reference Documents:

1. CPSES startup administrative procedure CP-SAP-19,

" Training / Qualifications Requirements for Startup Personnel,"

Rev. 5.

2. ANSI /ASME N45.2.6-19'8, " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants."
3. STE personnel qualification files.
8. This statemerit prepared by: h0;euw M bdh 6/6/Ff V. W. Watson, TRT Date '

Technical Reviewer Reviewed by: fd/sPt&

H. Livermore, M Ir Date Group Leader Approved by:

V. Noonan, Date Project Director 0-132

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