ML20211F234
| ML20211F234 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/10/1984 |
| From: | Shelburne E NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| Shared Package | |
| ML20150F241 | List:
|
| References | |
| FOIA-85-378 NUDOCS 8610310108 | |
| Download: ML20211F234 (1) | |
Text
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/ t UNtTED STATES 8 NUCLEAR REGULATORY COMMISSION 475
$ W ASHINGTON, D.C. 20555 h 2
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OF FICE OF THE SECRETARY ,
CERTIFICATION 18 I hereby certify that the attached pages contain a true copy of the Letter dated Mav 18. 1981 fo rm 11. T . Collins to Brown & Root Co., Inc. regardi no LCVI P inspection by Mr. D.F. Fox on April 13 - 17, 1981, together with
. that letter's attachments.
on file with the t)nited States Nuclear Regulatory Commission's Public Document Room, 1717 "H" Street, N. W. , Washington, D.C.
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Y Docket ;.o. WJ00502/31-02 drown and Root Incorporated ATTi;: Mr. W. ri. Rice 4
. Group Vice President, Power Group
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-100 Clinton Drive Post Offica Box 3
.wuston, Texas 77001 Gentlemen:
This refers to the inspection conducted by .'ir. D. F. Fox of this office en Acril 13-17,1W1, of your facilities at Houston, Texas, and to the ciscussions of our finoings witn you and members of your staff at tne conclusion cf tne inspection.
Areas examined curing tnis inspection and our findings are discussec in :he enclosea inspection report.. Witnin the:c areas, tne inspection consisted of an axarr.ination of procecures and representative records, interviews with personnel, anc ocservations oy tne inspector.
During this inspection it was found that you failed to meet certain :iRC req. re-ments. The specific findings and references to the pertinent recuirements an iuentified in the enclosures to this letter.
Tne ..ctice of Violation is sent to you pursuant to the crovisions of 10 CF2 2
l Part 2.2.01. You are required to sutait to this office within 30 cays of tr.c
> cate of this letter a written statement containing, (1) a description of steps tnat nave oeen or will be taken to correct tnese items, (2) a cescription of ste::s tnat nave oeen or will be taken to prevent recurrence, and (3) the catas your corrective actions and preventive measures were or will be completec. Ocn-sic = ration may ce given to extanding your response time for gccc cause shcun.
You are also requested to suomit a similar written statement for eacn iter.
unien appears in tne enclosed liotice of Monconformance.
This is the fourtn inspection in wnich Engineering and Ocality Assurance traiain; and qualification recorcs were founo to oe not maintained as cormiitted (See
!.otice of :ionconfonnance enclosure, Item C and previous Inspection Report aos. 99900502/30-01, 99900502/oG-03, and 99900502/81-01.)
- This suggests a breakdown in the effective implementation cf the Erown and ". cot
, 3;, duality Assurance ?rogram in this area for the Couta Texas Project.
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- ;G consequently, in addition to responding to tne specific items identifiec in the T; notice of i;onconfomance enclosure, please define the specific steps :nat . iou have taXcn, or plan to take, to assure that your corxtitments in :ne area cf l
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477 Brown and Root, Incorporated 2 In accorcance with 10 CFR 2.790 of the Commission's regulations, a copy of tnis letter and the enclosed inspection report will be placed in the iRC's Public Docunent Room. If this report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of your intention to file a request for withholding; and (b) sub-mit within 25 days from the date of this letter a written application to this office to witnhold such information. If your receipt of this letter has been celayed sucn tnat less than seven days are available for your review, please notify tais office promptly so that a new cue date may be establisned.
Consistent with Section 2.790(b)(1), any sucn application must be accompaniec by an affidavit executed by the bwner of the information wnich identifies the cccurent or part sougnt to oe withnelo, and which contains a full statement of tae reascns on tne basis wnicn it is claimec that the information snoulc be wit.inela frca puolic disclosure. This section further requires the statecent to accress wita specificity the eqnsiderations listed in 10 CFR 2.790(b)(A).
Tne information sougnt to be withneld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear frem you in this recara witnin the specifico periods noted above, the report will be placec in
- ne Pealic Cocumen: Acom.
Snould you nave any questions concerning this inspection, we will te pleasec to ciscuss them with you.
Sincerely, Jonn T. Collins Acting Director Region IV
Enclosures:
- 1. t.otica of Violatien I. lictice of Nonconfomance 1 3. Inspection Report ao. 99500502/81-02
. 478 Brown and Root, Incorporated Docket No. 99900502/81-02 NOTICE OF VIOLATION Based on the results of NRC inspections conducted on September 29, through October 3, 1980 and April 13-17, 1981, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
Section 21.21 of 10 CFR Part 21 requires that "A director or responsible officer subject to the regulations of this part . . . shall notify the Commission when he obtains information reasonably indicating a failure to comply, or a defect
. . . Initial notification required by this paragraph shall be made within two days following receipt of the information . . . . If initial notification is by means other than written communciation, a written report shall be submitted to the appropriate Office within 5 days after the information is obtained."
Contrary to the above, Brown and Root failed to submit a written report to NRC within the required five days that a significant safety defect existed .in delivered piping supports. The responsible officer determined on July 3, 1980, that safety concern number 57 was reportable under the provisions of 10 CFR Part 21. Houston Lighting and Power verbally reported the item to NRC on July 3, 1980, but Brown and Root did not submit a written report to NRC until July 11, 1980.
This is a Severity Level VI Violation (Supplement II).
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99900502 PDR
. 479 Brown and Root, Inc.
Docket No. 99900502/81-02 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted April 13-17, 1981, it appears that certain of your activities were not conducted in accordance with NRC require-ments.
A. Criterion V of Appendix B to 10 CFR Part 50 states that activities affecting quality shall be accomplished in accordance with instructions and procedures.
Sections 3.0 and 2.5 of Brown and Root procedure STP-PMO-022 (Procedure for Evaluating and Reporting of Defects, Noncompliances and Deficiencies) respectively state in part that, "Each defect, noncompliance or deficiency evaluated by the Incident Review Committee will be recorded on an NCR (or ADR, if appropriate). All subsequent documentation related to such defect, noncompliance or deficiency shall reference the governing NCR (or ADR).
The NCR (or ADR) in turn will have an attachment listing all related documents to effect a cross-referencing mechanism. . . . The total docu-mentation package shall be filed under the NCR (or ADR) and stored with the classification of a permanent QA record. Therefore, all documentation relating to a possibly reportable or reportable incident including correspondence, meeting minutes, telephone minutes, evaluation reports and written reports will be identified for file copy by the NCR (or ADR) number and tr=.nsmittec to the Quality Assurance Record Center. . . .
"A .,ritten report is required to be submitted to the NRC on each defect, noncompliance or deficiency reported to the NRC per 10 CFR 21 or 10 CFR 50.55(e). .
An outline for these written reports is provided in Attach-ment C to this procedure."
Contrary to the above, safety concerns 9, 22, 23, 26, 45, 46, 53, 66, 69, and 20 others evaluated by the Incident Review Committee were not recorced on an NCR or ADR, nor did all subseouent documentation related to these safety concerns reference a governing NCR or ADR. In addition, the total documentation packages for these concerns (1) were not stored witn the classification of a QA record; and (2) were not transmitted to the Quality Assurance Record Center. Furthermore, the written report submitted to NRC regarding safety concern 81 (Cable Tray Hanger Design Deficiency), and others, did not contain all the information required by Attachment C to the Brown and Root precedure.
09900502 PR I
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B. The NRC Letter of Acceptance of the Brown and Root Topical Report B&R-002A (revision 3, September 1977) states in part that, " Programmatic changes by Brown and Root to this topical report are to be submitted to NRC for review prior to implementation. Organizational changes which do not affect the program are to be submitted no later than 30 days after announcement."
Contrary to the above, programmatic and organizational changes made to the program by Brown and Root during the past year were not submitted to NRC as required. Refer to Details Section paragraph C.3. for details.
C. Criterion V of Appendix B to 10 CFR Part 50 states that activities affecting quality shall be accomplished in accordance with instructions and procedures.
Brown and Root South Texas Project Procedure STP-PM-006 (Personnel Training) states that, "Each personnel qualification file shall include . . . Pro-jected or completed Procedural Reading List (Form 200.81) . . . Projected or completed Training Requirements Checklist (Form 200.129) . . . Evidence of completion of QA Introductory Series."
Contrary to the above, the qualification files of four employees hired since February 12, 1981, did not include Form 200.81 (two of the employees), Form 200.129 (three of the employees), nor evidence of completion of QA Introductory Series (all four employees).
O. Sections 6.2.1.1.3.8 and 3.11.5.2 of the FSAR for the Scuth Texas Project nuclear power generation station state that, " Mechanical and electrical components of safety-related equipment were qualified for their potential normal operational environment and worst-case accident (DBA) environment.
The two general categories of postulated accidents considered in equipment cualification were LOCA and MSLB . . . For in-containment equipment, the DBA LOCA source term is an equivalent 100% core meltdown."
Contrary to the above, the material used for the inflatable seals of the containment personnel and auxiliary air locks was not fully qualified for the worst-case accident (DBA) environment in that the Beta radia-tion resistance of the seal material had not been determined to date, nor was the requirement for qualifying the seal material to withstand Beta radiation (1.4 x 10' Rad, per NUREG-0588) included in the pro-curement documents for the air lock.
E. Criterion V of Appendix E. to 10 CFR Part 50 states that activities affect-ing quality shall be accemolished in accordance with instructions and procedures.
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3 Brown and Root procedure OL 035 (Power Personnel Services Procedure for Verification of Education and Experience) states in part that, "The applicant shall provide documented evidence of completion of high school or college attendance, as applicable. Documented evidence is understood to mean an original transcript- or diploma which may then be xeroxed by a Personnel Services Specialist if additional copies are required. The copies shall be initialed and dated by the Personnel Services Specialist to verify authenticity."
Contrary to the above, a Personnel Services Specialist did not authenticate by initialing and dating copies of transcripts or diplomas that were contained in the personnel department record files of four of the eight examined files of newly hired employees.
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[ 482 U.S. NUCLEAR REGULATORY COMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900502/81-02 Company: Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3 Houston, Texas 77001 Inspection Conducted: April 13-17, 1981 Inspector: II D. F. Fox, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch Approved by: '
le, Chief
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Date C. JC @ Systems Section ReactTr Vendor Inspection Branch Summary Inspection on April 13-17, 1981 (99900502/81-02)
Areas Insoected: Implementation of Title 10 CFR Part 50, Appendix B, and Topical Report B&R-002A, including follow up on previous inspection findings, design process management, and technical personnel background verification. The inspec-tion involved 46 inspector-hours on site by one NRC inspector.
Results: In the three areas inspected, one violation and five nonconformances were identified. No unresolved or follow up items were identified.
Violation: Follow up on Previous Inspection Findings: Failure to submit a written report of a significiant defect in piping supports within the time required by 10 CFR Part 21. (See Notice of Violation)
Nonconformances: Follow up on Previous Inspection Findings: Failure to adhere to the requirements in the Brown and Root 10 CFR Part 21 implementing procedure (See Notice of Nonconformance, Item A). Design Process Management: Failure to submit to NRC changes in the QA program and organization described in the Brown and Root Topical Report (See Notice of Nonconformance, Item B); Failure to include Beta radiation resistance requirements in the specification for personnel and auxiliary air lock inflatable seal material (See Notice of R
483 2
Nonconformance, Item C); Failure to maintain required training records (See Notice of Nonconformance, Item D). Technical Personnel Background Verifica-tion: Failure to follow procedure for authenticating copies of educational diplomas or transcripts of new empicyees (See Notice of Nonconformance, Item E).
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DETAILS A. Persons Contacted
- R. J. Vurpillat, Manager, Quality Assurance
- H. T. Faulkner, Project Coordinator H. L. Bell, Project Staff Manager G. C. Priddy, Manager, Personnel
- P. A. Padden, Manager, Engineering Documentation R. W. Peverley, Assistant Engineering Progject Manager
- J. R. Childers, Houston Quality Assurance Coordinator
- B. F. Mitchell, Manager, Design Quality Engineering "P. S. Jordan, Manager, Nuclear Licensing Staff
- K. R. Cook, Project Deputy General Manager
- S. J. Kelly, Training Coordinator M. Weintraub, Subcontracts General Manager
- J. A. Signorrelli, Manager, Technical Staff J. F. Halsey, Manager, Special Problems Group
- A. H. Geisler, Manager, Nuclear Licensing
- 0enotes those present at the exit meeting.
B. Action on Previous Insoection Findings
- 1. (0 pen) Follow up item (Report 80-02,Section II.C.3.e). The status of the Brown and Root Vendor Control Evaluation and Correction Program will be evaluated.
The program consists of seven phases which implement the Brown and Root management commitment to NRC to define (and subsequently execute) a program that provides for a complete and thorough review and audit of the procurement documents, vendor control and surveillance activities, and release of safety related equipment and material to the site that is in full compliance with all Brown and Root commitments to NRC.
The phases, approximate status, and initiation and completion dates provided to, or determined by, the inspector are as follows:
- a. Establish Priorities and Schedule - June 15, 1980, tnrough January 31, 1981; 100% Completed as of March 15, 1981. One hundred and sixty procurement actions were identified, prioritized and scheduled for review, i
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- b. Generate "PO Baseline Requirements" - November 3,1980, through July 17, 1981; 8% Complete versus 58% projected.
- c. Independent NUS Audit - September 1,1980, through September 8, 1981; 2% Complete versus 62% projected.
- d. Resolution of Audit Findings - February 15, 1981, through October 9, 1981; 0% Complete versus 25% projected.
- e. Update Purchase Orders - March 1, 1981, through November 6, 1981; 0% Complete versus 17% projected.
- f. Correct Vendor Deficiencies - March 15, 1981, through December 4, '
1981; 0% Complete versus 11% projected.
- g. Release of Equipment and Materials - February 15, 1981, through December 4, 1981; 0% Complete versus 20% projected.
Procurement of safety related equipment and materials will continue to be closely monitored by NRC during future inspections.
- 2. (Closed) Deviation (Report 80-03, deviation 0). Superseded QA procedures were not destroyed nor stamped void.
The inspector verified the corrective action and preventive meast es described in Brown and Root letters dated December 16, 1980, January 20, 1981, and March 18, 1981. Specifically:
- a. Quality assurance reviewed the QA Manual for procedures with non-unique identification ard for reference to voided or superseded cocuments.
- b. A list of non-unique QA procedures and inapprocriately referenced documents in QA procedures was generated and distributed to hoicers of QA Manuals,
- c. A draft revision of tne QA Manual was issued for internal review and comment.
- d. The revised QA Manual is committed for issue prior to the ASME resurvey which is currently scheduled for August 1981.
- 3. (Closed) Unresolved Item (Report 80-03,Section I.D.3.b.(2). An apparent violation exists in that Brown and Root was not adhering to their procedure for implementing 10 CFR Part 21 requirements.
486 5
This item was elevated to a violation as well as a nonconformance.
See Notice of Violation enclosure and Notice of Nonconformance enclosure, Item A.
- 4. (Closed) Follow up Item (Report 80-03,Section I.B.4). Verify imple-mentation of a management plan to assure that commitments to NRC will be performed as stated and be effectively implemented.
The inspector verified that Brown and Root developed a system and a form (NRC Action Item Commitment List) which was implemented for inspection 81-01 findings.
The system and form require the following:
- a. Each NRC identified deviation, unresolved item, or other out-standing item be listed (as well as the individual responsible for action thereon) and distributed accordingly,
- b. An internal commitment date be established that is earlier (generally two weeks) than the date committed to NRC.
- c. Quality Assurance is responsible for following the implementation and completion of corrective actions.
- d. Prior to the commitment date to NRC, Quality Assurance is to independently veri fy, by review of objective evidence, thct the corrective actions have been completed. The Senior Vice President is to be notified for each specific failure to complete corrective action by the internal commitment date.
- e. The status of open B&R commitments to NRC be routinely reported 1
at the STP - Quality Assurance Management Review Board meetings.
The effectiveness of the system will be followed during future
- inspections.
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- 5. (Closed) Nonconformance (Recort 81-01, Item A). Corrective action committed in a Brown and Root response to a previous finding had not been completed as schedulec.
The inscector verified the corrective action and preventive measures described in Brown and Root letter of response dated February 16, 1981. Soecifically:
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- a. Brown and Root developed and implemented a system to identify and assure completion of commitments made to the NRC. See related Item B.4 above for details.
- b. An "NRC Action Item Commitment List" was transmitted to appro-priate management personnel for action / followup on January 15, 1981.
- c. A management meeting was held and documented on January 13, 1981, at which the importance of meeting commitments to NRC was stressed to all South Texas Project management by Brown and Root executive management.
Brown and Root completed the corrective action during inspection 81-01.
- 6. (Closed) Nanconformance (Report 81-01, Item B). Unapproved Technical Reference Documents were contained in the South Texas Project Design Manual.
The inspector verified the corrective action and preventive measures described in Brown and Root letters dated February 16, 1981, and March 18, 1981. Specifically:
- a. All STP Design Manuals were reviewed and brought into conformance with the procedural requirements for the content and control thereef.
- b. Procedure STP-DC-007 was cancelled in its entirety on April 17, 1981, and was reolaced by three new procedures issued on the same day. STP-SD-001-B (STP Design Manual), STP-50-002-B (System Design Description), and STP-SO-003-B (Technical Reference Documents) collectively contain the germane requirements of STP-0C-007 and all committed changes thereto.
- c. Nine additional STP procedures have been revised to date,
- d. Training on the new and revised procedures was completec or committed.
- 7. (Closed) Nonconformance (Report 81-01, Item C). The Engineering Document Control Center did not publish a document status list as required.
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The inspector verified the corrective action and preventive measures described in Brown and Root letters dated February 16, 1981, and March 18, 1981. Specifically:
- a. A current document status list was issued as committed. The list consisted of two separate issues, one of which (Brown and Root Document Status List) identified the current status of Brown and Root generated design documents. The second list, (Vendor Document Status List) identified the current status of vendor design documents received by Brown and Root.
- b. A new organization was formed on February 16, 1981, the EDC (Engineering Document Control), and assigned the responsibility for control and bi-monthly issue of both document status lists.
- c. Procedure STP-DC-028-B was revised to reflect the new Engineer-ing Document Control organization.
- d. The design document control system was' revised and upgraded to provide additional control over the generation, revision, verification, issue, and distribution of design documents,
- e. All affected STP procedures are to be revised to reflect the new organization and document control system by May 1, 1981.
C. Design process Management
- 1. Objectives The objectives of this area of inspection were to examine the estab-lisnment and implementation of quality related procedures for the design process to verify that:
- a. The design process system is defined, implemented, and enforced in accordance with approved procedures, instructions, or other documentation for all groups performing safety related design activities.
D. Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures,
- c. Appropriate quality standards for items important to safety are identified, documented, and their selection reviewed and approved.
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- d. Final design can be related to the design input with this traceability documented, including the steps performed from design input to final design.
- e. Design activities are documented in sufficient detail to permit design verification and auditing.
- f. The methods are prescribed for preparing design analyses, draw-ings, specifications, and other design documents so they are planned, controlled, and correctly performed.
- 2. Methods of Accomplishment The preceding objectives were accomplished by:
- a. Review of the following document's to determine if procedures have been prepared, approved, and issued to prescribe a con-trolled system for the management of the design process that is consistent with commitments to NRC and objectives a.
through f. above.
(1) Sections 17.2, 17.3, 17.5, and 17.6 of the NRC accepted Brown and Root (BIR) Topical Report, B&R-002A Revision 3, and amendements thereto, to determine the B&R corporate commitments relative to managment of the design process. l (2) Sections 2, 3, 5, and 6 of the B&R South Texas Project (STP) QA Manual, to determine if the B&R corporate commitments relative to managment of the design process were correctly translated into quality assurance policies and procedures that provide control over activities affecting the quality of design within the B&R scope of supply.
(3) Thirteen STP applicable design control procedures that are contained in the STP Engineering Procedures Manual, to verify that procedures have been established to implement the committed quality assurance program and to prescribe design activities that are within the B&R scope of supply,
- b. Review of Section 3.8 of the PSAR, Sections 3.6, 3.11, 6.1, and 6.2 of the FSAR, and Section 3/4.6 of the Technical Spec-ifications for the South Texas Project, to determine the regulatory requirements, safety classification, technical requirements, specific design inputs, and quality assurance requirements of the three containment air locks and other containment penetrations.
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- c. Review of the design specifications 1C15-501 and 2C26955006 (both titled " Steel Liner Work for Reactor Containment Structures"),
subcontract procurement files (35-1197-0011 with the Pittsburg -
DeMoines Steel Company), three B&R and 33 Woolley drawings, and the Executive Design Review of the South Texas Project Personnel Air Lock, to determine if sources of design input, such as PSAR/FSAR commitments and regulatory / quality requirements, were correctly and traceably translated into verified final design documents and the ultimately procured personnel air lock.
- d. The following additional documents were reviewed to determine if the quality assurance program for the management of the design process was being effectively implemented for the current B&R activities affecting the quality of the design within the B&R scope of supply:
(1) Calculations (four),
(2) Design verifications (five),
(3) Drawings (twenty-two),
(4) Personnel training records (four),
(5) Safety :encerns (seventy-seven),
(6) Specifications (five),
(7) System Design Descriptions (eleven), and (8) Technical Reference Documents (eleven),
- 3. Findings
- a. yonconformances Three nonconformances were identified in this area of the inspec-tion. See Notice of Nonconformance enclosure, items B.. C.,
and D.
(1) With respect to nonconformance B.
The following nonexclusive list of differences between the in place QA Program and the program described in the Brown
- and Root Topical Report B&R-002A (Revision 3, September 1977, including amendments dated October 17, 1978, and March 24, 1980) were identified by the inspector:
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. Some organizational structures and titles are different from those described in the Topical Report.
. The QA Manager does not report to the Power Division Group Vice President.
. The position of " Assistant Quality Assurance Manager" has been added to the QA organization.
The actual in place QA and Engineering organizations, interfaces, and functions are not as described in the Topical Report.
The revisions of the Regul'atory Guides endorsed by the in place QA Program are different from those identified in the Topical Report. l
. Review and approval of procurement documents by Engineering, Quality Assurance, and Purchasing is not as described in the Topical Report.
The responsibility for, and execution of, the QA Audit and Vendor Surveillance activities are not as described in the Topical Report.
(2) With respect to the inflatable seal personnel air 'ock:
(a) Section 3.t.l.l.6 of the South Texas Project 'SAR states in part thet:
". . . Access into the Containment Building is provided by an equipment hatch, a personnel airlock and an auxiliary airlock. The personnel airlock is an approxi-mately 10-feet diameter welded steel assembly with double doors. The auxiliary airlock is a 5-1/2 feet diameter welded steel assembly with double doors, Each coor is hinged and furnished with double 0-ring gaskets, with leakage test taps between the gaskets. . . ."
(b) Subsequently, the design evolved to use inflatable seals, rather than compression seals, reportedly to facilitate access for heavy equipment. Section 3.8.2.1.2 of the South Texas Project FSAR states in part that "The personnel and auxiliary aia locks are double, inflatable seal airlocks with pressure bar-Piers . . ."
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11 The appropriateness of the inflatable seal design was independently questioned by a B&R reviewer and NRC inspectors. Specifically, the ability to assure long-term sealing without having access to the inner seals for maintenance, and the dependence upon active non-fail-safe systems to maintain seal tightness and thus containment integrity, were questioned.
A subsequent independent " Executive (Design) Review" was conducted by a consulting organization for Brown i and Root. The review concluded that ". . . the inflat-able seal concept planned for STP should provide adequate safety. Details of the STP personnel air lock door sealing systems need further review and analysis as described hereir to insure acceptable performance j
under accident conditions. . ."
The Brown and Root Senior Vice President of Engineer-ing stated that the design of the personnel and auxi'iary air locks would be reevaluated within the next month and a decision made to either conduct the failure mode and effects analyses and qualifica-tion program recommended by the independent reviewers or to re-engineer the doors to deploy compressive 0-ring seals.
- b. Unresolved and Follow Up Items None were identified.
D. Technical Personnel Background Verification
- 1. Objectives To verify that measures have been established and art being effectively implemented that assure:
- a. The education anc work experience information contained in employees' joo applications are ceing verified by the employing organi:ation.
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- b. There is oojective, documented evidence or records that attest to the employees' education and experience.
- 2. Method of Accc plishment The preceeding objectives were accomplished by an examination of:
- a. Brown and Root Procedure OL-035, Revision 0 dated May 21, 1980, (Procedure for Verification of Education and Experience).
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- b. Personnel department record files for the following individuals:
(1) Six individuals who were extended an offer of employment, but have not yet reported for work.
(2) Eight employees who started to work during the first quarter of 1981.
(3) Three employees who started to work prior to 1981.
- 3. Findings One nonconformance was identified in this area of the inspection.
(See Notice of Nonconformance enclosure, Item E).
The Personnel Manager stated that procedure OL-035 would be revised by June 10, 1981, to include specific requirements for verification and documentation of the alleged education and experience of newly hired or transferred employees who are engaged in nuclear safety related activities. Subsequently, the personnel files of all such employees will be reviewed and retrofitted by June 30, 1981. Specific actions will be taken on a case-by-case basis for those individuals whose alleged education or experience can not be verified or was falsified.
E. Exit Meeting -
An exit meeting was conducted with Brown and Root management personnel at the conclusion of the inspection on January 8, 1981. In addition to those individuals indicated by an asterisk in paragraph A. of this report, the meeting was attended by:
J. R. Ayres, Manager, Materials K. M. Broom, Senior Vice President S. M. Dew, Assistant Engineering Project Manager T. L. Porfilio, Discipline Quality Engineer W. M. Rice, Group Vice President, Power Group E. A. Saltare111, Senior Vice President The inspector discussed the scope of the inspection and the details of the findings identified during the inspection, including the processing of identified safety enneerns. Management comments were generally for information only or for acknowledgement of the statements of the inspector with respect to the nonconformances presented.
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