ML20210U053
| ML20210U053 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1987 |
| From: | Mcintyre R, Stone J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20210T978 | List: |
| References | |
| REF-QA-99901067 99901067-86-01, 99901067-86-1, NUDOCS 8702180376 | |
| Download: ML20210U053 (14) | |
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. ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION INSPECTION N0 : 99901067/86-01 DATE: 11/3-7/86 ON-SITE HOURS: 99 CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operations ATTN: Mr. G. R. Brown, General Manager ,
Nuclear Field Services 175 Curtner Avenue San Jose, California 95125 ORGANIZATIONAL CONTACT: Mr. W. R. Vinters, Mar.ager, Quality Assurance TELEPHONE NUMBER: (404) 447-7225 NUCLEAR INDUSTRY ACTIVITY: General Electric Company, Nuclear Energy Business Operations (NEB 0), has a work force of approximately 2500 assigr.ed to domestic and foreign nuclear power activity.
9 ASSIGNED INSPECTOR- 2 /o /7 h R. Pf McIntyre, Special Projects Inspection t S (SPIS)
OTHER INSPECTOR (S): K. C. Leu, SPIS D. J. Lynn, Co sultant APPROVED BY: _
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N/fJ Date JaysC. Stone,ActingChief,SPIS,VendorProgramBranch INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21 and 10 CFR Part 50.
B. SCOPE: The purpose of this inspection was to follow-up on allegations involvirg qualification and certification of Nondestructive Examination (NDE) personnel at General Electric (GE), Nuclear Field Servicer !
Department, Norcross, Georgia.
PLANT SITE APPLICABILITY: Brunswick 1 & 2 (50-325/324)
Ih 99901067 870213 VGENE PDR g - - - . . . - - . - - ,, , , . _ - - --, . - - - - , - , ,
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. JRGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 2 of 9 A. VIOLATIONS:
None.
B. NONCONFORMANCES:
- 1. Contrary to GE Procedure No. QC-2, " Procedure for Qualification and Certification of Nondestructive Examination Personnel," a GE NDE technician was certified as a Level II Magnetic Particle Examiner and Tester, however, he feiled to attain a passing grade of 70% on his Magnetic Particle examination. (86-01-01)
- 2. Contrary to GE Prncedure No. QC-2, " Procedure for Qualification end Certification of Nondestructive Examination Personnel,"'three instances were identified where examination grades were increased after full or partial credit was given for incorrect answers, thus allowing the individuals to attain a passing grade on the examin-ations. The same person was responsible for all three occurrences.
(86-01-02)
C. UNRESOLVED ITEMS:
None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
None.
E. OTHER FINDD'GS OR COMMENTS:
- 1. Backaround This inspection was corducted to examine six allegations with respect to the alleged falsification of NDE Level III recertification and the cualifications of several NDE personnel. During the timeframe of the allegations Inspection Services was part of the Division of Nuclear Plant Services under GE Apparatus and Engineering Services. Presently, ,
Inspection Services is part of the Nuclear Field Services Department under the Nuclear Energy Business Operations (NEBO), San Jose, l California.
- 2. Review of GE NDE Qualification and Certificatinn Requirements The NRC inspectors reviewed GE Procedure No. QC-2, " Procedure for Qualification and Certification of Nondestructive Examination Personnel," Revision No. 4, dated December 5, 1985, and compared it
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. 0RGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 3 of 9 with the requirements of the American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A, 1975 and 1980 editions.
.The comparisons were conducted in the following areas:
Nondestructive Test Methods Level of Qualification
- Education, Training and Experience Examinations Certifications
- Terminations The NRC inspectors noted that the QC-2 requirements are, in general, comparable to, and in some cases, more stringent than those of SNT-TC-1A. For instance, the required ninimum training time for LevelIIRadiographicExaminer(RT), Option 3(grammarschoolor equivalent); Level II Liquid Penetrant Examiner (LT) halogen diode (HDLT), Option 3; and Level I LT HDLT, Option 3 are respectively:
100, 40 and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in accordance with CC-2, versus 80, 20 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by SNT-TC-1A.
Section 2.2 of GE OC-2 procedure further states that additional qualification requirements may exist in other specifications, such as ASME III, VIII, and XI, MIL-Std-271, or NAVSEA 250-1500-1, and shall take precedence over QC-2 and SNT-TC-1A, when differences exist. As a result of the above review and comparisons, the NRC inspectors found that GE OC-2 procedure requirenents meet the intent of SNT-TC-1A with respect to NDE certificatien and qualification.
SNT-TC-1A provides guidelines for proficiency levels required for personnel involved in nondestructive testing.
- 3. Review of Allegations l
The inspectors reviewed the certification, qualificaticn, and written examination records of those individuals identified in the allegations. l A total of eight personnel files were reviewed and compared to GE l QC-2 and other applicable codes and standards. The inspectors also conducted interviews with personnel to provide a wide spectrum of NDE personnel perspectives. The written exam records for the different NDE methods were also reviewed.
Based upon a review of the eight personnel files, the requirements in education, training, work experience, and examination results and certification were satisfactory and consistent with the requirements delineated in OC-2 procedure.
o
~6 ORGANIZAT10N: GENERAL. ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 4 of 9 The six allegations, along with their inspection results are summarized below.
I a. Allegation: The manager of the GE Division of Nuclear Plant Services, a level III NDE technician, had his Level III recertification falsified in February 1985, when another Level III signed off the manager's recertification without administering the required examinations. The allegation contained additional information which is listed below.
(1) The alleger stated that this falsification took place sometime during late February 1985 and that the Level III had certifications in MT, PT, RT, UT and VT.
(2) The alleger stated thgt the individual who maintained the examiner ticket would have his examiner ticket expiring on March 12, 1985.
Irspection Finding a.(1): The following tests and dates were verified in the Manager of Nuclear Plant Services' certifi-cation package.
Method Exam Dates Level Previous Exam Ultrasonic (UT) 1/28/85 III 1/10/82 Magnetic Particle (MT) 1/29/85 III 1/9/82 Liquid Penetrant (PT) 1/29/85 III 1/10/82 Visual (VT) 1/28/85 III 1/8/82 Radiography (RT) N/A III 1/8/82 No radiograph (RT) exams were given in 1/85 since radiography is not being conducted by GE. Additionally, these certification exams were given over a two (2) day period and included four (4) disciplines and not given in one day and for five (5) disciplines, as alleged.
Inspection Finding a.(2): The Level III NDE examiners certifica-tion for being an examiner expirer April 15, 1986.
Based on the above data, this allegation was not substantiated. ,
- b. Allegation: The Manager of the GE Division of Nuclear Plant i Services does not have sufficient NDE expertise to hold a level III certification.
". . l ORGANIZAT10N: GENERAL ELECTRIC COMPANY i NUCLEAR ENERGY BUSINESS OPERATIONS RAM .in<r -ratT nDNTA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 5 of 9 Inspection Finding: A review of the individual's qualifications and certifications was completed and an interview witif the individual was conducted by the inspectors. Specific exams taken by the individual in question were also reviewed to assure compliance to GE's qualification and certification program.
The results of the review of the individual's education, train-ing, experience ard work history are as follows:
Individual's Experience Method Level Time Training Hours Education RT I 11/71 RT-136 hrs. BS MT I 11,/71 UT-136 hrs. Admn. Mgmt.
PT I 11/71 MT-40 hrs.
UT II 6/72 PT-40 hrs.
UT II 11/74 VT-24 hrs.
RT II 12/74 MT II 12/74 PT II 12/74 MT III 6/78 PT III 6/78 UT III 6/78 RT III 6/78 Visual Weld AWS-CWI 5/71 MT III 6/79 PT III 6/79 UT III 6/79 RT III 6/79 MT II 6/80 PT II 6/80 UT II 6/80 RT II 6/80 MT III 1/82, 1/85 PT III 1/82, 1/85 UT III 9/81,1/82,1/85 RT III 9/81, 1/82, 1/85 VT III 1/82, 1/85 Based on the above data, this individual meets and/or exceeds the personnel training, experience and education levels reouired by SNT-TC-1A and GE Procedure No. QC-2, " Qualification and Certification of Nondestructive Examination Personnel," for certification as a Level III.
e o ORGANIZATION: GENERAL ELECTRIC COMPANY llVCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 6 o' 9 Based on the above, this allegation was not substantiated.
) CP&L's Brunswick nuclear plant during the cutage in October 1984, did not have sufficient NDE expertise to hold the Project Manager position or a Level III certification.
Inspection Finding: Based on GE's standard operating practice (not written), as stated by GE, a Project Manager is selected for a given assignnent by the Manager of Inspection Services based on experience, job performance, and administrative skills, as well as technical competence. GE does not require that this position be held by an individual certified as a level III.
To further review the allegation that the irdividual did not have sufficient NDE expertise,a review of the individual's background was performed to determine if the individual met the requirements of SNT-TC-1A as well as GE's written practices and was certifiable to a Level III NDE status.
The results of this review indicated that the individual ret the education, training and experience requirerents as out-lined in SNT-TC-1A and GE Procedure No. QC-2, for certification as a NDE Level III eveniner.
Based upon the above, this allegation was not substantiated.
- d. Allegation: The GE Project Manager initially assigned respon-sibility for GE work at CP&L Brunswick nuclear plant during the outage in 1985 did not have sufficient NDE expertise to hold the Project Manager position or a Level III certification.
Inspection Finding: Based on GE's standard operating practices (not written), a Project Manager is selected for a given assign-ment, by the Marager of Inspection Ser/ ices, based on experience, job performance, and administrative skills, as well as technical ccmpetence. GE does not require that this positien be held by an individual certified as a level III.
1 The Project Manager ir questior held a level II certification in l VT, PT, MT, UT, and RT.
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. ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 7 of 9 A review of the individual's background was performed to deter-mine if he was certifiable to a Level II NDE status, and met the requirements of SNT-TC-1A and GE's written practice Procedure l No. QC-2.
The results of this review indicated that the individual met the education, training and experience requirements as outlived in SNT-TC-1A and GE Procedure No. QC-2 for certification as a NDE Level II examiner.
Based upon the above, this allegation was not substantiated.
- e. Allegation: GE Project Management forbade any contact with NRC stating that any contact was the responsibility of project naragers. ,
Inspection Finding: The inspectors reviewed GE Procedure No.
QA-1, " Procedure for Quality Assurance Irdoctrination and Training." This procedure has a section with guidance for client contact but does not include any stipulations for contact with the NRC. GE NEB 0 Procedure 70-42 "Reportino of Defects and Nonccmpliances Under 10 CFR Part 21" defines the requirements for compliance to 10 CFR Part 21 and establishes reporting mechanism for any employee in the crganization to report a potential defect or noncompliance for evaluation for reportability to the MRC. The NRC inspectors could find no written practice which reouires only Project Managers to talk to or cortact NRC personnel at plant sites.
The inspectors interviewed five NDE personnel, including two individuals who previously held Project Manager positions at Brunswick during the time span described in the allegatiens and three individuals who were NDE technicians. All the indi-viduals interviewed stated that they were instructed to be cooperative and give factual answers to questions asked by NRC ,
representatives at nuclear plant sites. All interviewees stated j they never geve instructions, or were given instructions not to make contact with or talk to NRC.
i Based upon the above, this allegation was not substantiated,
- f. Allegation: GE NDE technicians were not I intergranular stress corrosion cracking (properly IGSCC) certified work due to for significant variances in calibration on known standards.
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6 ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 8 of 9 Inspection Finding: In additinn to the review of persernel qualifications and GE's Procedure No. QC-2 requirements, a complete review of calibration records for the year 1984 was completed. The records were specific to Brunswick site work.
Although minor deviations in completed responses were noted during this review, the deviatiers were attributed to variables, e.g., equipment, transducers, wedges, etc. No significant variances were noted that would indicate that the operators were calibrating in a different mede.
Based upon the above, this allegation was not substantiated.
- 4. Additional NDE Personnel Certification Review In addition to the eight individuals identified in the allegations, the inspectors also selected seven other NDE personnel for review of their certification packages to determine if they met the require-ments of GE QC-2 Procedure for education, training, experience, and qualification level (includiro examinations).
During this review the inspectors identified three instances in which examiration scores were increased after full or partial credit was given for inccrrect answers on Level II Visual Method (VT) ovalifica-tion examinations. It should be noted that all three VT exams were administered and graded by the same NDE Level III examiner. The change in examination scores allowed the individuals to pass the exams. GE personnel agreed that the enswers were not correct, but could give no reason why these individuals were given partiel and full credit for incorrect answers. GE personnel stated they would look into this item to determine its extent.
The inspectors also identified one Level II NDE technician who was certified as a Level II Magnetic Particle (MT) inspector, although he failed to make a passing grade of 70% on the examination, as required by GE Procedure QC-2. This certification was included on his latest Certificate of Gualification and sent to the varicus sites where he was assigned, thus allowing the project manager to possibly assign the individual work for which he was not qualified.
Nonconformances 86-01-01 and 86-01-02 were identified during this part of the inspection.
. 1 6 ORGANIZATION: GENERAL ELECTRIC COMPANY j
NUCLEAR ENERGY BUSINESS OPERATIONS '
RAN .1ntF. FAIT:nRNTA REPORT INSPECTION NO.: 99901067/86-01 RESULTS: PAGE 9 of 9 l i
The inspectors identified several instances where wrong answers were listed on the computerized NDE Examination answer sheet. This answer I sheet is originally attached to the examination itself and is removed when the exam is administered. This answer sheet is used by the examiner to grade the exams and if it includes '.4rong answers, it greatly increases the chances of errors being made when grading the exams. The inspectors did not identify any exams where this had occurred, but GE stated they would revise the examination answer sheets to reflect the correct answers for each question.
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