ML20211J737

Rev 6 to Instruction QI-QAP-2.1-1, NDE Personnel Certification. Related Info Encl

ML20211J737
Person / Time
Site:	Comanche Peak
Issue date:	03/01/1984
From:	Douglas Dodson BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:
Shared Package
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References
FOIA-85-59 QI-QAP-2.1-1, NUDOCS 8606260478
Download: ML20211J737 (14)

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REVISION nacWN AND IcoT, nic.

NQf5DL CFsts QI-QAP-2.1-1 6

IlAR 011984 1 of 13 REVIEWED BY:I ~d EE:

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y DATE N0NDESTRUCTIVE APPROVED SY:

% ~ UU EXAMINATION E Lb el III QATE PERSONNEL d

CERTIFICATION APPR6VED'BY:

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1.0 REFERENCES

1-A American Society for Nondestructive Testing. SNT-TC-1A,1980 1-8 American Society of Mechanical Engineers ASME Boiler and Pressure Vessel Code,Section III, Div.ision I.

4 1-C CP-QAP-2.1, " Personnel Training and Qualification".

2.0 GENERAL

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2.1 PURPOSE This instruction defines the personnel

training, qualification and certification requirements implemented at CPSES to meet the intent of Referes.ces 1-A and 1-8.

2.2 SCOPE This instruction applies to personnel perfoming nondestruc-l tive examinations (NDE) or providing technical support of NDE at CPSES.

2.3 DEFINITIONS

,s 2.3.1 Nondestructive Examination 1

A method of examining materials for the detection of l

discontinuities without impairing the usefulness of the ma terial. The methods used at CPSES are Radiographic Examination (RT), Ultrasonic Examination (UT), Magnet'ic ji Particle Examination (MT), Liquid Penetrant Examination (PT), and Leak Detection (LT).

j as required.

Other methods may be added

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2.3.2 Qualification Skill, training and experience required for personnel to properly perfonn the duties of a specific job.

2.3.3 Certification Doctmented testimony by the Site NDE Level III to the acceptability of the qualifications of NDE personnel.

2.3.4 Levels of Certification-There are three levels of certification in each method:

a.

Level I b.

Level II c.

Level III 2.4 GENERAL REQUIREMENTS 2.4.1 Certification

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Personnel qualified to perfonn NDE. shall be trained and certified in accordance with this procedure.

NDE personnel currently certified at CPSES are considered certified until the expiration of their current certification.

i Recertification shall be in accordance with this instruction. ~

t Level III personnel certified to equivalent B&R NDE Level III approved procedures at other B&R nuclear projects, may be certified by the Site QA Manager without re-examination, providing:

a.

The Site QA Manager has reviewed and accepted the program under which the indiv.idual was certified as being equivalent to this program; b.

The individuals previous certification was by examination; and

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The certification and supporting docunents have been i

placed in the employees certification file.

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JOB 35-1195 QI-QAP-2.1-1 6

MAR 011984 3 of 13 I

The CPSES certification (s) shall be effective for three years from the date of the certification (s) by examination.

The effective period of certification for all certifications issued in accordance with this instruction shall be three years.

Certification ~ of qualification shall be documented as prescribed in Reference 1-C.

Certifications may be revoked / suspended by the Site NDE Level III when reason exists to question the individual's ability to perfom NDE satisfactorily.

2.4.2 Qualifications Three levels of certification are specified for personnel 4

who perfom NDE in accordance with approved CPSES procedures or instructions.

Education, training and experience requirements for each level of certification are prescribed i

in this instruction.

Personnel nay be qualified and i

certified to perform examinations of limited scope at each 4

respective level of certification.

i The nianber of hours of training and the amount of work time 4

experience required for inspection personnel do perfonn i

only one operation of an examination method that consists of i

more than one operation, or perform examinations of limited scope may be less than that specified in Attachment 1, as approved by the Site NDE Level III.

Personnel holding limited certifications perfonn only those operations allowed within the restricted scope of the certification.

When performance of an examination requires operations beyond the scope of the limited certification, i

personnel qualified to perfonn those operations shall be utilized.

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Certification limitations are doctanented in the candidate's certification file.

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2.4.3 Prior Exoerience or Training i;

Previous trair.ing and/or work experience nay be used to i.

partially or fully satisfy the qualification requirements l'

prescribed in this

)rocedure, when documented and approved by the Site NDE Leve' III.

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j 2.4.4 Examinations Candidates for certification are given examinations covering the general, specific and practical aspects of the method.

4 Examinations are prepared and approved by the Site NDE Level III and administered by the Site ~ NDE Level III or his designee.

2.4.5 Gradino of Examinations A minimum composite grade of 80 percent is required for qualification of Level I and Level II personnel.

In ad-dition, individual passing grades for the general, specific 3

and practical examinations are 70 percent or greater. Test objects used in the practical examination contain known indications, and at least 90 percent of the known indications must be found during the practical examination.

For Level III, a composite grade of 80% is required,and individual passing grades for the basic, method and specific are 80* percent or greater.

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Failure by a candidate to naet the above required grades will result in denial of certification.

2.4.6 Gradino Factor A percentile weight factor is app', lied to the rav scores of the various exar.inations, i.e.

general, specific and practical. These factors are as follows:

Level I and II:

t General 0.3 Specific 0.3 Practical 0.4 1

Level III:

Basic 0.3 i

Method 0.3 i

Speci fic 0.4 4

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MAR 011984 5 of 13 4j':

2.4.7 Re-examination Personnel who fail two consecutive examinations for the 1

same certification, are not eligible for certification in that method.

2.4.8 Recertification NDE personnel are recertified at least once every three years in accordance with one of the following criteria:

a.

Re-examination in the practical aspects of the method using a grade factor of 1.0; or b.

Re-examination in the general, specific and practical aspects of the method using the grade factors shown in

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2.4.6.

i QC Supervisors shall notify the Site NDE Level III of NDE personnel under their supervision having interrupted service exceeding six months.

NDE personnel having interrupted service exceeding six months shall be recertified as described in 2.4.8 a.

2.4.9 Temination and Reinstatement All certifications are automatically revoked when personnel teminate employment at CPSES.

4 The certification of employees teminated and re-hired within six months may be reinstated without additional testing, if approved by the Site NDE Level III or by the Site QA Manager for NDE Level III personnel.

New employees may be racertified to a fomer level of 1

certification, granted by an employer other than B&R, based on an examination in acconlance with this instruction provided all of the following conditions are met to the satisfaction of the Site NDE Level III:

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The new sployee has proof of prior certification and

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such documentation is placed in his certification file; b.

The not oployee's number of hours of training and work time experience are veri fi ed, and meet the requirements of Attachment 1; c.

The new employee was working in the capacity to which he has been certified within six months of his temination; and d.

The new employee is being recertified within six months of his temination.

l 3.0 INSTRUCTION 3.1 GENERAL Prior to perfoming Code-required inspections or i

examinations, inspection personnel.must satisfactorily complete the applicable requirements of this procedure and 4,

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be certified as either Level I, II, or III.

3.2 EDUCATION, TRAINING AND EXPERIENCE t

Personnel considered for certification are required to have sufficient education, training and experience to ensure understanding of the principles and procedures of those areas of responsibility in which they are being considered for certification.

Education and experience requirements are prescribed on Attachment 1.

3.3 RESPONSIBILITY 3.3.1 Trainee In the process of being qualified and certified to at least Level I, an individual is considered a Trainee.

A Trainee works along with a certified individual and does not conduct independently any test, interpret any results of a test, or write a report of test results.

j 3.3.2 Level I l

A Level I individual shall be qualified to properly perfom specific calibrations, specific tests and specific evalua-l tions according to written instructions and to record the results.

He shall receive the necessary guidance or supervision from a certified Level II or III individual.

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3.3.3 Level II A Level II individual shall be qualified to set up and calibrate equipment and to interpret and evaluate results

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with respect to applicable codes. - standards and specifications. He shall be familiar with the scope and limitations of the method and shall exercise assigned responsibility for on-the-job training and guidance of Trainees and Level I personnel. He shall be able to prepare 1 7 written instructions and to organize and report nondestructive testing investigations.

3.3.4 Level III An NDE Level III shall be responsible for establishing

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techniques; interpreting codes, standards and specifications; and designating the particular test method and technique to be used. He shall be responsible for the complete operation he is qualified for and assigned to, and shall be capable of evaluating results in tems of existing codes, standards and specifications.

He shall have sufficient practical l

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background in applicable techniques to assist the design

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engineer in establishing acceptance criteria where none are otherwise available. He shall have general familiarity with other commonly used methods.

He shall be responsible for the training and examination of Level I and Level II personnel for certification.

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3.4 LEVEL I AND II EXAMINATIONS t

Each candidate for Level I and II certification is given a three-part examination covering the general, specific and practical aspects of the NDE method.

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All three parts of the examination are administered by the Site NDE Level III or his designee.

1 The written general and specific examinations are administered without access to reference material (closed

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book) except for reference material specifically approved and deemed necessary by the Site NDE Level III.

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MAR 011984 8 of 13 I

r 3.4.1 General Examination General examinations shall cover the basic test principles relative to the applicable method.

The designated msnber of questions is as follows.

LEVEL I LEVEL II TEST ETH00 QUESTIONS QUESTIONS

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Radiography 40 40 Magnetic Particle 30 30 Ultrasonics

• 40 40 Liquid Penetrant 30 30 l,.

Leak Testing (Bubble Test) 20 20 I

3.4.2 Specific Examination Specific examinations shall cover the equipment, operating i

procedures, examination techniques, project specifications

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or codes and acceptance criteria in the project examination procedures or instructions.

The designated number of questions is as follows:

LEVEL I LEVEL II TEST ETH00 OUESTIONS OUESTIONS Radiography 20 20

' l Magnetic Particle 20 15 a

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Liquid Penetrant 20 15 Leak Testing (Bubble Test) 15 15 l

l 3.4.3 Practical Examination Proficiency shall be demonstrated in selecting and performing the applicable nondestructive examinations and evaluating the results obtained on one or more samples

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containing known indications, approved by the Site NDE Level i

III.

l At least 90 percent of the known indications mJst be j

detected.

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At least ten different checkpoints requiring an understanding of test variables and QA Procedure or Instruction procedural requirements shall be included in the practical examination.

The description of the specimen, the examination procedure including checkpoints, and results of the examination shall be documented.

NOTE:

The designated mmber of questions for test methods of limited scope may be less than that specified when approved by the Site NDE Level III, i.e. UTDT.

3.5 LEVEL III CERTIFICATION REQUIREENTS The B&R Site QA Manager is responsible for examining and certifying the Site NDE Level III in accordance with this procedure.

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l 3.5.1 Level III Education and Experience Requirements

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Individuals being considered for NDE Level III in any one I

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method sust meet one of the following educational and/or experience requirements:

a.

Graduate of a four-year accredited engineering or science college or university with a degree in Engineering or Science plus one year's experience in an assignment comparable to that of a Level II in the applicable test method; 11 ;"

b.

Completion with a passing grade of at least two years 1

of engineering or science study at an accredited university, college or technical school plus two years experience as a certified Level II in the the applicable test method; or c.

Four yean experience as a certified Level II in the applicable testing method.

3.5.2 level III Examinations 1

The Level III examination consists of the following:

l' Basic Examination (Required only )once when more than a.

one method of examination is taken.

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ung (}1 g 10 of 13 Twenty (20) questions relating to understanding the SNT-TC-1A document.

Fifteen (15) questions relative to applicable materials, fabrications, and product technology.

Fifteen (15) questions which are selected from or are similar to published Level II questions for other appropriate NOT methods, l

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b.

Method Examination (for each method).

9 Thirty questions relating to fundamentals and principles, which are selected from or are similar to published ASNT Level III questions for each method, and t

Fifteen (15) questions relating to application and estalishement of techniques and procedures which are selected from or are similar to the published

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ASNT Level III questions for each method, and 4

Twenty (20) questions. relating to capability for interpreting

codes, standards, and specifications t

relating to the method.

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Specific Examination (for each method).

Twenty (20) questions relating to specifications, equipment, techniques, and procedures applicable to L.

the employer's product (s) and methods enployed, and to the administration of the employer's written practice.

3.6 VISION REQUIREENTS 3.6.1 Near Distance Visual Acuity Each qandidate for certification in inspection nethods to l

Level I,

II or III shall be examined for near distance 1; j visual acuity and color perception on an annual ba si s.

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MAR 011984 11 of 13 A

I The examination is given to assure natural or corrected near distance acuity in at least one eye such that the candidate is capable of reading a minimum of Jaeger Number 1 letters on a standard Jaeger Test, at a distance of not less than 12 inches (30.5 cm).

The ability to perceive an ortho-rater minimum of 8 is also acceptable. Similar tests may be used if approved by the Site NDE Level III.

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3.6.2 Color Perceotion Individuals shall be capable of distingui shing and

.I differentiating contrast between colors, as evidenced by correctly identifying at least 10 out of the first 11 plates l,-

of the Ishihara Color Perception Eye Examination.

I ~,'l Personnel failing to correctly identify at least -10 of the i

l; first 11 plates shall be given a practical examination

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approved by the Site NDE Level III using colors which the individual can expect to encounter in his specific i,-

assignment.

The results of the practical eye examination shall be documented on the eye examination fom.

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The personnel training files of each certified individual shall contain a copy of the completed eye examination fom.

pl' 3.7 TRAINING PROGRAM Training programs for each NDE method are developed by the -

cognizant NDE Quality Engineer and approved by the Site NDE Level III.

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3.7.1 Reference Material

!I Reference mterial used as sources of infonnation for the training program shall be approved by the Site NDE Level III.

3.8 CERTIFICATION RECORDS REQUIREMENTS 3.8.1 Training Documentation

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Training doctanentation shall be in accordance with Reference 1-C.

l 3.8.2 Certification Doctanentation 4

Written certification is provided in accordance wi th Reference 1-C. The following itens shall be documented on

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the personnel certification:

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Name and Social Security Number; b.

Level of certification and test method; c.

Highest level of education completed; d.

Training received;

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. Date of eye examination; e

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Total accredited work time experience; g.

Certification exam nebers, date completed, and scores; h.

Percentile weight assigned to each examination; i'

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Remarks or comments on above areas;

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Date of certification or recertification; j.T.

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Date of certification expiration;

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Signature of certifying authority; 3.9 DOCUENTATION FILING Docmentation shall be paintained in accordance wi th i

Reference 1-C.

1 l' 3.10 SUBCONTRACTED NDE PERSONNEL Subcontracted NDE personnel, including the NDE Level III are certified by the subcontractor in accordance with written i

procedures which comply with Reference 1-A and 1-B and have j

been approved by the Site QA Manager.

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The Subcontractor's personnel qualifications shall be reviewed by the Site QA Manager to verify compliance with

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the Subcontractors written practice. The Subcontractors NDE -

Level III shall be authorized by the Site QA Manager to act for Brown & Root.

Approval of the written procedure and personnel qualifications shall be documented by memo to the subcontracted agency by the Site QA Manager.

Copies of these records shall be retained and a copy of each transmitted to the Owner.

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m ficiency or additienal i

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For level 11 certif! cation, time esperience shall comelot of time at level I.

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,f directly to I4 vel II with me time at level I, the required esperience shall canetet of the seen of the times g

8, regef red fo. lmvel I and tavel II as a tralmee and tine hours of training required for invol I and Level II le L -

total shall apply.

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Credit for esperience may be gained almultaneously la tuo or more disciplines. The candidate. met speed at g

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least 25I of his work time la each discipline for ubich esperience to being claimed.

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Trasming requiremmate may be entiefied by the course described is ceneral seguiremente of the Instructies.

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This training may be satisfied through directed instrincties under the supervielen of the site UDE Imvel III.

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accumented training time, in the oppiteable upC mettied, ear be credited to the candidate's training requiremente H

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for certification if approved upon evaluetten by the Site Wet Imsel III.

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Training is outlined and administered by use of approved lasses plane.

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DCT 3 1983 In Reply

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r Dockets:

45/83-2 50-446/83-14 L

--54 Texas Utilities Generating Company ATTN:

R. J. Gary, Executive Vice President & General Manager 2001 Bryan Tower

'n Dallas, Texas 75201 V

i Gentlemen:

This refers to the inspection conducted by Mr. L. E. Martin of this office during the period June 27 through September 16, 1983, of activities authorized by NRC Construction Permit CPPR-126 and.CPPR-127 for Comanche Peak, Units 1 and 2, and to the discussion of our findings with R. G. Tolson, and other members of your staff at the conclusion of the inspection.

This inspection was the Region IV' followup to the Construction Appraisal Team's (CAT) inspection as documented in NRC Inspection Report 50-445/83-18; 50-44G/83-12.

The scope of this inspection was to perform a more in-depth review and evaluation of the " Potential Enforcement Findings" (unresolved issues) which were identified in Appendix B of the CAT report and referred to Region IV for resolution.

Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.

These findings are documented in i.he enclosed inspection report.

Within the scope of the inspection, no new violations or deviations were identified, in this report.

Four violations were identified as a result of the CAT inspection and documented in NRC letter to TUGC0 of May 31, 1983, and the attached Notice of Violation.

One unresolved item is identified in the Electrical and Instrumentation Construction Area of the enclosed inspection report.

l The Region IV inspector reviewed the/p~o_stfconstruction v~erification-pro 3Lramsy and procedures for piping and supports, electrical, and room walkdowns.

These t

l programs and procedures contain the appropriate elements to ensure that the actual as installed components and systems will be in accordance with the latest design requirements.

The actual implementation of t!)elpostw cconstructionTerM_icatisaJr_o_graros will be followed through subsequent i

Region IV inspections on a room or area basis as required by the NRC

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These reports provided test data to meet the requirements of Section 3

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of NRMCA Certification and Section 10.3 of ASTM-C94.

This item is considered closed.

Procurement. Storace. and Material Traceability CAT Potential Findino

" Contrary to 10 CFR 50, Appendix B, Criterion XIII, FSAR Section 17.1.13, CP-QAP-8.1, Revision 5, CP-CPM-8.1, Revision 1, and MCP-10, Revision 7, storage of certain safety related equipment in outside lay-down areas and installed in the plant was not properly controlled (Section VI.B.2)."

This potential finding was, reviewed by the SRIC and determined to.be a Severity Level V Violation.

This violation was identified in Appendix A of the Region IV letter to TUGC0 dated May 31, 1983.

This item will be followed by the SRIC.

L Quality-Control-Inspector-Ef5&Jviness ;lf 1.

CAT Potential Findina

" Contrary to 10 CFR 50, Appendix B, Criterion II and FSAR Section 1A(B),1,7/ '(see Attachment) individuals pre certified'ttr-levels of capability-without-the requisite experi,

AnneeleRMbed'in~Re@ Tito rfGuide 1. 58 (,Secti on'VII. B. 2.'a(2)). "

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Section VII.B.2.a(2) - identifies four. areas in which QC inspectors were certified with less experience than required.

The specific areas of concern will be discussed later in this paragraph.

i CPSES FSAR Section 1A(B), page 1.A(B)-24 commits to implement Regula-tory Guide 1.58, Revision 1 for the construction phase.

Regulatory Guide 1.58, Revision 1 is the regulatory guidance and NRC position on ANSI N45.2.6-1978, " Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants."

/CPSES'FSAR-Section ~1A(B)-states., "For inspection activities outside the scope of ~thTASME' Code, inspection personnel are l

qualified in general compliance with the requirements of Regula-tory Guide 1.58 Revision 1...."

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/'ANST N45:25-19187hiragraph.2.2_ states, "The capabilities of a i

candidate for certification shall be initially determined by a suitable evaluation of the candidate's education, experience, l

training, test results, or capability demonstration."

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"6J-197R, _ paragraph 3.5_ states, "The following is the recommended personnel edur:ation and experience for each level.

These education and experience recommendations should be treated to recognize that other factors may provide reasonable. assurance that a person can competently perform a particular task.

Other factors which may demonstrate capability in a given jcb are

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v 21 previous performance or satisfactory completion of capability testing."

ARegiDitory-GuideZ 'r58 dos.it.lon15.,5 endor,.geC$1c_ tion-3:Syfr 1

G5d.6yh the aduitional requirement of a high* school diploma f

% r GED~ equivalent.

Angulat6*y:GUHE~~G5fi/Po'itinn Cdo,;4adorsas Sec.tle!L2 2 ofs-s gee-t 5Nfth the requirement that measures for initial qualifica-1f' tion used in lieu of education and experience should result in occumented objective evidence (i.e., procedures and record of writter test) demonstrating comparable or equivalent competence.

The Region IV inspector reviewed the following B&R and TUGC0 proce-dures:

CP-QAP-2.1

" Personnel Training and Qualification" QI-QAP-2.1-5 Training and. Certification of Mechanical Inspection Personnel" 7

CP-QP-2.1

" Training of Inspection Person'nel" The abov's procedures meet the requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1.

These procedures address the implementation of Sections 2.2 and 3.5 of ANSI N45.2.6 and Posi-tions C.6 and C.10 of Regulatory Guide 1.58, Revision 1.

The Region IV inspector reviewed approximately 35 inspector certifica-tion records covering the four areas identified in the CAT report i

j-The Region IV inspector then contacted the responsible CAT inspector

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to establish the exact concerns of the CAT and the names of the

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individuals that were considered to be inappropriately certified.

Th2 responsible ~ CAT inspector provided the Region IV inspector with

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names and the respective area of concern for each individual.

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Region IV inspector had already reviewed the records of five of the The t

individuals and then reviewed the remaining certification records of

.i the indi:/iduals identified by the CAT inspector.

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,'j The results of the above review are as follows:

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a.

"Three individuals w'ere certified Level I'I (L-II) mechanical 4

j inspectors having authority to witness pump or component dis-assembly and reassembly with qualifying experience only in welding and nondestructive examination."

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-j Four individuals were identified that could be fitted into this i

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22 Individual 1 was hired by B&R in June 1979 as a welder and then was transferred to QC in March 1982.

This individual was

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certified Mechanical Installation / Fabrication Inspector (MIFI)

Level II on July 9, 1982, based on an AAS degree in Welding Technology, 3 years welding experience, a 92.44 tiest score, and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of "on the job training" (0JT).

This individual was certified Mechanical Equipment Inspector (MEI) Level II on June 22, 1983, based on the AAS degree, 1 year experience as an MEI Level I (January 20, 1983), a 88.71 test score, and 16.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> OJT.

Individual 2 was hired by B&R in June 1982 as' an inspector. This individual had a nonrelated AAS degree but had 2 years of verified previous experience in welding inspection' and NDE.,

This individual was certified as MIFI Level II on March 24, 1983i based on 2 years 9 months experience, high school diploma, a 83.65 test score, and 55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br /> OJT.

Individual 3 was hired by B&R in May 1978 as a welder and then i

was transferred to QC in October 1982.

This individual was certified MEI Level II on November 125 1982, based on 4 years,

previous experience, a GED certificate, a 84.78 test score, and i

22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> OJT.

This individual was certified MIFI Level II on November 21, 1982, based on 4 years experience, a GED certificate, a 93.5 test score, and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> OJT.

Individual 4 was hired by B&R in May 1981 as a wolder and then l

was transferred to QC in May 1982.

This individual was certified MIFI Level II on June 25, 1982, based on 1 year experience, an l

AAS degree in Welding Technology, a 90.37 test score and 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> i

OJT.

This individual was certified MEI Level II on March 10, 1983, based on 1 year 10 months experience, AAS degree, a 94.00 test score and 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> OJT.

With the exception of Individual 2 all the above met all of the requirements.

Individual 2 by time requirements of N45.2.6-1978 was 5 months short on time between MIFI Level I (August 3, 1982) and MIFI Level II (March 24, 1983) and was 3 months short on MEI Level II.

However, utilizing the capability testing requirements of ANSI N45.2.6, paragraph 2.2, and the documentation requirements of Regulatory Guide 1.58, Revision 1, Position C.10, the individual was certified to Level II based on documented performance.

b.

"One individual was certified Level II as a mechanical inspector I

i having authority to witness pump or component disassembly and

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reassembly using education as a factor in the qualification process when the education was from a nontechnical, unrelated college degree."

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0 The CAT inspector interpreted ANSI N45.2.6 to require a technical or related degree if a 4 year. college graduation is utilized as a factor for certification.

ANSI N45.2.6-1978, paragraph 3.5.2(4) for educatidn.and experience recommendatiels for Level II states; "Four year college graduation plus six months of experience in equivalent inspection, examination, or testing activity."

There is no requirement for a 4 year degree to be technical or related in ANSI M45.2.6-1978 or Regulatory Guide 1.58, Revision 1.

There were two individuals with nontechnical 4 year Bachelor of Arts degrees.

Both individuals had more than 1 year experience that was directly related and validated as equivalent.

The certification of these two individuals met the requirement.i of ANSI N45.2.6 and Regulatory Guide 1.58.

For clarificatirn, by review of QI-QAP-2.1-5 and the associated training outlines, the Region IV inspector determined that both MEI and MIFI inspectors can witness valve, pump or component disassembly and reassembly.

However, f,inal alignment / installation of equipment is limited to MEI Level II by job description.

("Dat.1ndividual wa'sTeftified"LuVitl T elei:tVidlTidipector after, c.

IDE vljeE3f 'al.e' tri. cal jMpection.axper_f ance. "

C Electrical inspector as a title is restricted to Level II certification at CPSES.

There are no Level I " electrical inspectors" by certification at CPSES.

However, the Region IV inspector did identify an individual who had received certifica-l tion as Hilti bolt inspector Level I and conduit inspector Level I in less than a month after joining electrical QC.

The CAT inspector confirmed the identity of the individual.

This individual was hired by B&R in March 1981 in the QC docu-ment area and then transferred to QC on November 15, 1981.

This individual was certified Level I Hilti bolt on February 15, 1982, with a test score of 80 and Level I conduit on December 8, 1981, with a test score of 91.66.

This individual was a high school graduate with 1 year of college and had 8 years of previous QC experience.

The passing test scores and 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> OJT was the basis of certification.

I d.

"Two individuals were certified Level I anchor bolt inspectors with less than 1 month inspection experience."

The Region IV inspector identified two individuals who were high school graduates who did not have 6 months experience prior to certification as Level I anchor bolt inspectors.

The CAT inspector confirmed the identity of the. individuals.

One of the individuals had a high school education, was hired in November m-----*-~~"'"~~~"~~'~"

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24 1981, and was transferred.to QA in December 1981.

This individual scored 88 on his exam and had 206 hours0.00238 days <br />0.0572 hours <br />3.406085e-4 weeks <br />7.8383e-5 months <br /> of OJT for his certifica-tion as a Level I Hilti bolt inspector on February 24, 1982.

1 The other individual had a high school education, was hired on December.1, 1981. This individual scored 80 on his* exam and had 47 hours5.439815e-4 days <br />0.0131 hours <br />7.771164e-5 weeks <br />1.78835e-5 months <br /> OJT for his certification as a Level I Hilti bolt inspector on December 22, 1981.

Both certification folders also contained recommendations by Level II inspectors for Level I certification of the individuals based on high performance.

On this basis the requirements for Level I certification were met.

The certifications of the above inspectors is generally consistent with the requirements of ANSI N45.0.6-1978 and Regulatory Guide 1.58, Revision 1.

9]~1 The Region IV inspector recognizes that the provisions of capability i> ' testing in lieu of actual experience could definitely be taken F.,.

advantage of and used to the extreme.

However, the Region IV inspector

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did not consider this to be the case with the certifications reviewed

']j;(duringthisinspection.

1. This item is considered closed.

2.

CAT Potential Findino

" Contrary to 10 CFR 50, Appendix B, Criterion X, and FSAR Section 17.1, 18/ (see Attachment) inspection records were prepared and accepted by Level I inspectors as the ' inspector of record' rather than the required Level II ' inspector of record' required by ANSI N45.2.6 (Section VII.B.2.b(1))."

Section VII.B.2.b(1)b.

- indicates that the intent of ANSI N45.2.6- '

1978 is that a Level II inspector be the " inspector of record."

The CAT identified areas in civil QC, electrical QC, and non ASME i

mechanical QC where the " inspector of record" was a Level I inspector

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and there was no Level II sign-off for the validity of the results.

The Region IV inspector, after a careful reading of ANSI N45.2.6-1978, does not agree with the CAT on their interpretation of the intent of the standard with respect to the " inspector of record." To have a Level II sign as the " inspector of record" when that inspector was totally removed from the inspection would not meet the intent of ANSI N45.2.6 or 10 CFR 50, Appendix B. 'The CAT found that inspection reports in most areas were being reviewed by Level II or a senior i

Level I inspector but were not being signed by the reviewer.

With the exception of the civil area, the CAT inspector was satisfied that the reviews were in fact being accomplished, but the reviewer was not signing the inspection report.

ANSI N45.2.6 does not require a Level II signature, nor does it require Level II evaluation on every inspection report.

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,5/25/84 Allegation No. 12 It has been alleged that Quality Control inspectors are not qualified or have insufficient training.

Evaluation of Validity

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Our evaluation of this allegation indicates that the training and certification programs (ASME and Non-ASME) at Comanche Peak are in full -

compliance with ANSI N45.2.6, SNT-TC-1A, and Regulatory Guide 1.58.

These programs require z.9 evaluation of an inspector's education, experience, and formal training. Quality Control supervisory personnel evaluate an inspector's proficiency prior to recommending certification. This evaluation of ability continues after certification.

If any situation develops' which causes supervision to question an inspector's ability to perform an inspection activity h

adequately, that person i~s removed from that activity and work d

inspected by him is reinspected.

In isolated instances, individuals have performed inspections for which they were not properly certified.

Those instances have been documented on nonconformance reports, and appropriate corrective action has been taken.

Periodic surveillances and audits conducted by TUGC0 and Brown & Root ensure compliance. Various outside agencies such as INPO, CAT, NRC Region IV, Hartford Steam Boiler, and ASME have evaluated and concurred with the training and certification of inspection personnel.

Safety Sionificance None

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Generic Imolications on Other Systems or Contractors f

Not applicable F01A-85-59

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FOLDER NO.

47 Draft No.

Date COMANCHE PEAK ALLEGATION WORK PACKAGE QA/QC Category 12 - QC Inspector (or Supervisor) Qualification / Training Allegation Numbers: AQW-1, AQW-2, AQW-3, Anw-4.30W-S, AQW-6, A0W-7. A0W-11.

ACC-9, A00-27, AQE-8,CAQ-23, AQ-24. At-2b, AQ-27, AQ-28, AC-Zv,Ay-63]

ve 7

Statement of Allegation: Various concerns related to welding / training and general qualification / training program, including:

a.

Improper weld practices g.

Lack of QC training and unqualified b.

Nonqualified welders QC inspectors c.

Weld inspectors not qualified h.

Supervisory personnel not qualified d.

Inexperienced personnel 1.

Electrical inspectors not qualified e.

Vendor welds inspected by J.

DOL desposition of Dunham unqualified insoector k.

Recertification of inspectors with f.

Training inadequate answers given Reference DocumentJ:

See source doc.ments marked on attached pages from allegation list.

Source of Allegation: Various - see enclosed allegations list D te Received: Various - 1979 - 84

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The above information prepared by D. M. Hunnicutt 6/11/84 Name Date l

Group Leader Name Date Assigned Team Members l

Date Assigned Date Assigned i

Date Assigned Date Assigned F0lh RRAo y g(

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