ML20199G107

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Partially Withheld marked-up Memo Re T Workinger Comments on Draft Qa/Qc Sser,Category 4 Concerning Training & Qualifications
ML20199G107
Person / Time
Site: Comanche Peak, 05000000
Issue date: 01/28/1985
From: Tang R
NRC
To: Livermore H
NRC
Shared Package
ML20197J178 List: ... further results
References
FOIA-85-59 NUDOCS 8606250077
Download: ML20199G107 (7)
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JAN 2 8 1985 flote to: Herbert Livermore QA/QC Group Leader From: R.C. Tang o

Subject:

Comments by TRT Consultant Ted Workinger on

  • Draft QA/QC SSER, Category 4 - Training and Qualifications The following comments are submitted kconsideration with respect to preparing the final SSERs for QA/QC. These comments address the content or meaning of statements in the SSERs, rather than editorial corrections. flote that these comments pertain to draft copies of the QA/QC SSERs that were sent to me in mid-December.

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A0-23, 24, 26, 27 and 108 .(Draft 5 10/29/84) u (,- e ' - ' r' s "

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fio comment M A0-73 (Rev. 2, 10/24/84)

It is not clear how the implied safety significance, resulting from a lack of a formal orientation training program for document control clerks will be -

provided in the QA/QC Category 8 SSERs. Do we need to make this statement at ,

the end of Section 5, on page 3? O '

p.M k-AQ-91 (Rev. 2, 10.24.84) w Q.W ytb -

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1. It is suggested that the first paragraph on page 2 be condensed; i.e. the document was not required. Could we say, after the first sentence, The I

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i original signed copy of the "ETG Indoctrination" reading list for that person had been lost. The TUEC Startup Specialist provided a replacement copy, dated July 15, 1983, newly signed by the individual whose record had been lost. ha AA

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2. Section5,ConclusionandStaffPositionsingeneral,haveincEeda finding as to whether the allegation was substantiate'd and a statement about safety significance relevant to the finding. Should such a paragraph be added here? # * -
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We question whether an action is required with respect to something that is not required. We made our point in Section 5; accordingly, it is suggested that the statement in Section 6, page 3, be deleted.

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These comments are reflected p copies of the attached SSERs.

R.C. Tang

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] Revision 2 10/24/84 AQ-73 / CP 5 SSER u

9 M. Allegation Group: QA/QC Category No. 4 Training / Qualification

2. Allegation Number: AQ-73
3. Characterization: It is alleged that document control clerks received -

(7 poor training regarding how to process travelers and other types of ~

documentation.

4.

A:sessment of Safety Significance: The implied significance of this allegation is that if the assembly of documentation and traveler packages is incomplete and incorrect, installation and inspection of hardware by the craft and inspection personnel who use these documents may be incorrect.

The NRC Technical Review Team (TRT) found that document control clerks were responsible for: (1) .'eceiving controlled documents and assuring that the correct document number, revision number, number of copies, and all design changes had been incorpcm_:ed and entered into the design change log book; (2) assuring that C packages requiring travelers had e

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Rev. 16. Th'e'TRT'also concludes that numerous past errors were made in the manual legs, the ccmputer data base, and the files in the DCC and its

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satellites. The implied safety significance of this allegation is 9 p',-

provided in the SSER writup for QA/QC Category No. 8, which'"cc'mpares "

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installed hardware with the as-built design documents. [k

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6. Actio'ns Recuired: TUEC shall review'the training and orientation program for all DCC personnel to determine its status and e'ffectiv'eness.

Appropriate corrective action will be taken where applicable.

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8. Attachments: None.

i 9. Reference Documents.-

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j 1. Brown & Root procedure CC?-3 and all revisions.

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i Rsvision 2 10/9/04 SSER AQ-91/ CP2 O-a ..

SSER

1. Allegation Group: QA/QC Category No. 4
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 Sienificance: The implied significance of this s allegation is that if unqualified personnel were performing prerequisite testing, the test results may be invalid and the quality of the tested equipment would be indeterminanc.

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After a review of facility training requirements, the NRC Technical Review Team (TRT) found that there were no specific training requirements for craft personnel providing support to system test engineers (STE) 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.

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i l ,* s QA/QC No. 4 lg \) .

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During the TET review of the training requirements for craf t personnel i performing prerequisite tests, it was noted that the file in the a

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l Brown & Root (B&R) Electrical General Foreman's of fice did not contain the signed copy of the "ETG Indoctrination" reading lists for a specific craft test person. The TRT reviewed the originals in the m

office

  • files of a Texas Utilities Electric Company (TUEC) Startup QA Specialist. Be informed the TRT that he would try to find the copy requested. In the meantime, the TRT was reviewing training records when the TUEC Stamp Specialist called to say he had the copy. He then gave the TRT a copy of the form, signed in ink by the craf t's person, g

dated July 15, 1983. The TRT then asked how a copy dated over a year

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()h ago had just been found in very good condition and why there were no copies available in either file. After making a few phone calls, the TUEC Startup Specialist responded that "the original was lost and a new one was just now filled out."

1 The TRT found documentation verifying that applicable procedures had i

been reviewed by craft personnel. Additionally, all craft personnel supporting prerequisite testing were journeyman craf tsmen (or second

! class craftsman in a few cases), and were subject to STE approval for work on a specific system. These craft personnel were specifically

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f instructed orally not to perform prerequisite testing unless the iTE 1

j was present. The TRT interviewed a sampling of STEs, all of whom l

i expressed a high level of confidence for all craft support personnel.

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QA.

/QC No. 4 O ..

The TRT reviewed the education and training records of 15 STZs f or cc=pliance with CP-SAP-19, " Training / Qualifications Requirenents for Startup Personnel," Rev. 3 and found proper docu=entation satisfying the training and qualification require =ents for startup persennel.

5. Conclusien and Staf f Positions: Based on its review of facility requirenents, examination of training records, and interviews with '

startup personnel, the IRT found that craft personnel had reviewed the procedures specified in facility training require =ents. In ene instance, the TRT found a post-dated training record that de enstrated a very questionable attitude toward record keeping in this area, even though the docu=ent in question was not required by station procedures for testing qualifications. Instructions given to craf t persennel and interviews on their qualificatiens with STEs who supervise them

. p indicate that they are adequately supervised on the job. ,&g W b%# W Aqu ~ MM ~L , MY& b g

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6. Actions Required: The licensee shall address the corrective action pbc/'

required to assu=e that after-the-fact recording on records has been f C su==arily stopped. The licensee shall address and specify ccrrective action to prevent recurrence.

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