ML20215G003
| ML20215G003 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/18/1986 |
| From: | Young J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1972 OL, NUDOCS 8612240182 | |
| Download: ML20215G003 (78) | |
Text
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- o. 4 Filed: Dcccmbar 18, 1986
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[ AD DtC.T 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the I ATOMIC SAFETY AND LICENSING BOARD l
)
In the Matter of )
) Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC ) 50-446-OL COMPANY et al. )
) (Application for an (Comanche Peak Steam Electric ) Operating License)
Station, Units 1 and 2) )
)
ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report I.d.2 In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan I.d.2.
i (Guidelines for Administration of QC Inspector Tests),
i 8612240182 861218 5 PDR ADOCK 05000
te -- 1 Opening Request:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
All checklists utilized during the implementation of ISAP I.d.2 are attached. The checklists are as-follows:
- a. Checklist for Review of CP-QP-21, Revisions 17 and 18 and CP-QP-2.3, Rev. 5 and QI-QP-2.1 -23, Rev. O
- b. ~ Checklist for Limited Review-of CP-QP-2.1, Revisions 6 through 16 and CP-QP-2.3, Revisions 2 through 4
- c. Qualification Training, and (Re)
Certification of CPSES Non-ASME QC Inspectors Attribute Checklist Approved 4/28/86
- e. Review of TUGCO's Current Test Bank of Certification Examination Questions, to a Specific Procedure / Instruction
- f. Qualification, Training, and (Re)
Certification of CPSES Non-ASME QC i
-o J Inspectors Attribute Checklist Approved 8/19/86.
Question:
- 1. Describe the problem areas addressed in the report. Prior.to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further? How did it believe the problems arose? What did it discover about the QA/QC documentation for those areas?
How extensive did it believe the problems were?
Answer:
As stated in Section 4.1 of the Results Report, the objective of the Action Plan was to ensure that the TUGCO CPSES training and certification program for QC Inspectors complied with FSAR commitments. No action e
was Laken to define the problem areas further other than to conduct the reviews of applicable precedures as required by the Action Plan and as described in the Results Report. A root cause analysis is described in Section 5.5.1 of the Results Report and postulated causes for inadequate procedures are addressed. No QA/QC documentation was examined during the implementation of this Action Plan except for the verification of the implementation of the current TUGCO QC inspector certification program. Results of this evaluation are described in Section 5.2.3 of the Results Report. Problems which may have been caused by
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F e ,1 inadequate QC inspector certification procedures are currently under evaluation under ISAP I.d.1, "QC Inspector Qualifications."
Question:
- 2. Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.
Answer:
No procedures or other internal documents exist or are required to understand how the checklists should be interpreted or applied. In general, the checklists extracted specific requirements from applicable standards, Regulatory Guides, and procedures. The checklists were used by experienced personnel, knowledgeable of the specific requirements, as aids in conducting reviews and evaluations and as a method of documenting results. In some cases, the same individual who prepared the checklist used the checklist.
Question:
- 3. Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes. (This question is applicable only to construction Results Reports.)
Answer:
, 3 This question is not applicable to this Results Report. The checklists were not inspection checklists nor were there any original TUGCO documents or checklists comparable to those used by the QA/QC Review Team.
Question:
- 4. Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.
Answer:
The checklists were based upon the requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1 and do not contain fewer attributes than are required to verify conformance to their requirements.
Question:
- 5. (Answer question 5 only if the answer to question 4 is that the checklists do contain fewer attributes.) Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.
l j Answer:
This question is not applicable because of the answer to Question 4.
Question:
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- 6. Set forth any changes in checklists while they were in use, including the dates of the changes.
Answer:
No changes, except for corrections of obvious typographical errors, were made in checklists while they were in use. These corrections were marked by hand on the checklist by the reviewer and are included in the Results Report files.
~
Question:
- 7. Set forth the duration of training in the use of checklists and a-summary of the content of that training, including field training or other practical training. If the training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
Answer:
No training was conducted in the use of the checklists nor was any required. The checklists were prepared for use by personnel familiar with the requirements of the codes / standards / procedures and were used by personnel who also were experienced with the requirements contained therein. The purpose of the checklists was to provide a list of requirements and space on which results of the evaluations of the documents could be recorded. This is turn provides a record of the review and ensures the important
, i requirements are not overlooked during the evaluation process.
Question:
- 8. Provide any information in Applicants' possession concerning the accuracy of use of the checklists (or the inter-observer reliability in using the checklists). Were there any time periods in which checklists were used with questionable -
training or QA/QC supervision? If applicable, are problems of inter-observer reliability addressed statistically?
Answer:
No inform.ation is available concerning the accuracy of use of the checklists, or concerning inter-observer feasibility.
Question:
- 9. Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use of the checklists. Provide the factual basis for believing that the audit and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the validity of conclusions.
Answer:
Two internal ERC audits, both of which covered use of checklists by personnel implementing the Action Plan, were conducted. These audits were as follows:
- a. ERC Audit 86-05, August 18-22, 1986
- , I
- b. ERC Audit 86-06, September 15-19, 1986.
No findings of deviation or Audit Action Requests were issued as a result of the audits.
Question:
- 10. Report any instances in which draft reports were modified in an important substantive way as the result of management action. Be sure to explain any change that was objected to (including by an employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.
Explain what the earlier drafts said and why they were modified. Explain how dissenting views were resolved.
Answer:
The initial drafts of the Result Report were prepared by the Special Evaluation Team (SET). Upon SET's departure in May 1986, because of medical and personal commitments, the status of the draft Results Report was evaluated by the Externe.1 Source Issues Deputy Program Manager. As a resttlt of this evaluation, the following additioaal actions were undertaken by the QA/QC Review Team:
- a. CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5 were reviewed to comply with the latest documentation requirements of QA/QC Review Team procedures issued l
l
, i subsequent to the procedure reviews conducted by SET
- b. CP-QP-2.1, Revision 18 and QI-QP-2.1-23, Revision O were reviewed to comply with the latest documentation requirements of QA/QC Review Team procedures issued subsequent to the procedure reviews conducted by SET. This review also verified these revisions appropriately resolved the QA/QC Program Deviation identified during the review described in paragraph a above
- c. A verification of the adequacy of implementation of the current TUGCO CPSES TUGCO QC Inspector Certification Program was conducted.
The draft Results Report was then totally rewritten to describe initial SET activities and the results of the additional actions undertaken by the QA/QC Review Team described above. This revision did not substantially change the description or conclusions of SET's activities described in the previous draft Results Report.
It did provide additional documentation as
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e :- 8 required by the latest QA/QC Review Team procedures and identified a QA/QC Program Deficiency not previously identified in the original draft Results Reports.
No changes made in the draft Results Reports were objected to by any employee, supervisor or consultant during the course of the development of the final issued Results Report.
Question.
- 11. Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached. How were each of these unexpected difficulties resolved?
Answer:
No unexpected difficulties were encountered in implementing this Action Plan.
Question:
- 12. Explain any ambiguities or open items left in the Results Report.
Answer:
There are three open items resulting from the implementation of this Action Plan. These items, which are discussed in Sections 5.5.1 and 5.5.2 of the Results Report are as follows:
,, e
- a. The question of whether senior TUGCO management was remiss in assigning inexperienced personnel to the QC inspector certification procedure development activity will be addressed during the collective evaluation process.
- b. The possible certification of unqualified inspectors will be addressed during the implementation of ISAP's I.d.1 and VII.c,
" Construction Reinspection / Documentation Review Plan," and evaluated during the collective evaluation process,
- c. The determination of whether other inadequate QA/QC procedures existed will be finally evaluated during the collective evaluation process using information from this and other Results Reports as well as results from any additional investigations which may be warranted.
These three items have been formally transmitted to the QA/QC Review Team Collective Evaluation Supervisor for follow-up and closure.
Question:
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- 13. Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his own work or supervicing any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Answer:
No actual or apparent conflicts of interest were identified during the implementation of this Results Report.
Question:
- 14. Examine the report to see that it adequately discloses the thinking and analysis used. If the language is ambiguous or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.
Answer:
The QA/QC Review Team is unaware of the existence of any ambiguities or obvious unanswered questiotis other than those addressed in Question 12 above.
Respectfully submitted, 0f Jame# E. Youg r_ - e Y fs Action Plan T.d.2 Issue [ coordinator i >l T
/
J '/ D . christensen External source Issues Deputy Program Manager
._ _ . - . - _ _ . . . _ _ ---_-__ _ L
9 ,4. A d-22 M Hansel RT QA/QC Review Team Leader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Ravinw Tamm.
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CERTIFICATE OF SERVICE I, Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on December 18, 1986, I made service of the within Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report I.d.2, by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission ,
U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Nancy Williams Administrative Judge Cygna Energy Services, Inc.
881 W. Outer Drive 101 California Street, Suite 1000 Oak Ridge, Tennessee 37830 San Francisco, California 94111 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555
l Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000.P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.
Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Ms. Billie P. Garde Midwest Office 3424 N. Marcos Lane Appleton, Wisconsin 54911 _
G '
Robert K. Gad III
Revision: 0 June 10, 1986 Page 1 of 13 ISAP I.d.2 Guidelines for Administration of QC Inspector Tests
Title:
Review of Specific TUGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1.
Prepared by:
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( m- Date 6 /d I /
U Approved by: 'Date b, / , 7d This instruction / checklist is to provide specific directions, to aid in the review / evaluation of TUGCO's written procedure CP-QP-2.1 Rev.17, October 30, 1984, Rev. 18 August 19, 1985 Training of Inspection Personnel and CP-QP-2,3, Rev. 5 and QI-QP-2.3-23 Rev. O to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. I as committed to by TUGCO.
Each question is directly related by paragraph to N45.2.6 and applicable section of Regulatory Guide 1.58. Each question will be evaluated and answered on an individual basis, with an overall evaluation / conclusion statement provided in Attribute 23 of this instruction / checklist.
Complete item 1. by entering applicable procedure / instruction (s),
Rev. and Date of issue. Use cont'd sheet if required.
Complete item 2. by entering the applicable procedure / instruction title (s). Use cont'd sheet if required.
Completion of items 3. thru 22 are self-explanatory.
Complete item 23 by entering an overall evaluation / conclusion statement.
1031/ MISC 8
3-Revision: 0 June 10 '966 .
I.d.2: Review of Specific TUCCO procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 1) CP-QP/QI-QP No(s):
Rev:
Issue Date:
- 2) CP-QP/QI-QP Title (s) *
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- 3) Does/Do the procedure (s) clearly define personnel to which the requirements are applicable. (N45.2.6 Para. 1.2)
YES l l NO R answer:
- 4) Is/are the procedure (s) reasonably clear, in not being applicable to (Reg. Guide 1.58) for the following.
- NDE personnel under SNT-TL-la conducting, RT, MT, PT, UT, ET and LT?
i Pre-operations, start-up, or operations Test personnel? l YES l l NO l l answer:
2 1031/ MISC 8
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!> ~ f exab,,inat3, o. n Hnd' test, ing a :tivities' (N45.2.6 para 1.3)? ,
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- 6) Doas/Do the' procedure (s) clearly identify, sho is responsible for est.ablishing and implemerting the regt:.freannts for selection . '
training, qualification and resources nece.ssi.ry, '
to comply with the requirements of (N U.2.6 para 1.3)? -
YES l l NO l l 1
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- 7) Does/Do the procedure (s) define irlopection, examination and 's testing, in a manner consistent with (N45.2.6 para 1.4)?
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.e I.d.2: ReviewofSpebificTUGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide d
- 1,58 Rev. 1. (Cont'd)
'3 8')1 ' Does/Do the procedure (s) define or assign responsibility for planning for staffing, indoctrination and training of personnel '
in adequate numbers to perform required inspections, examinations and test. To allow adequate time for assignment / selection /trair g of required personnel (N45.2.6 para 2.1)?
'YES R NO U
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- 9) Does/Do the procedure (s) adequately address indoctrination of personnel, as to the technical objectives of the project,. codes and standards to be used; QA elements to be employed (N45.2.6 para 2.1.1)?
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- 10) A: la the need for' formal training programs addressed? s YES l l , NO R B: Does/Do the procedure (s) adequately specify how they are to be addressed?
YES I l NO l l '-
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I 4 1031/ MISC 8
Revision: 0 June 10, 1986
.-( I.d.2: Review of Specific TUGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
, 10) (Cont'd)
C: Is on-the-job training (0JT) included in the program with v emphasis on, actual performance of inspections?
YES l l NO R D: If training is the basis for certification, are records required to be maintained? (requirement for A thru D N45.2.6 para 2.1.2)
YES l l NO l l answer:
- 11) Are the capabilities of a candidate for certification, initially determined by suitable evaluation of the candidates education, experience, training, test results or capability determination.
(N45.2.6 para 2.2)?
s YES f"l NO l l answer:
5 1031/ MISC 8
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. o Revision: 0 June 10, 1986 I.d.2: Review of Specific TCGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cent'd)
- 12) Is job performance of personnel, re-evaluated at least every three (3) years, and are re-evaluations done by evidence of continued satisfactory perfccmance or by redetermination of capability per para 2.2 of N45.2.6 (N45.2.6 para 2.3)?
YES I l NO R answer:
- 13) Does/Do the procedure (s) provide for the removal of persons from an activity, if during the periedic evaluation or at any other time, it is determined by the responsible organization that their capabilities are not in accordance with the job qualifications (N45.2.6 para 2.3)?
YES I l NO l l answer:
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- 14) Does/Do the procedure (s) require re-evaluation of an individual who has not performed inspection, examination, or testing activities for a period of one (1) year (N45.2.6 para 2.3)?
YES l l NO l l answer:
6 1031/ MISC 8
Revision: C June 10 1986 1.d.2: Review of Specific TUCCO procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Con,t ' d)
- 15) Does the certification record form contain the following information (N45.2.6 para 2.4) ?
YES l l NO l l
- employer's name.
identification of person certified.
level of capability.
activities certified to perform.
basis used for certification, including
- a. records of education, experience and training.
- b. Test results, where appropriate.
- c. results of capability demonstration.
results of physical examinations, where required.
signature of employer's designated representative.
date of certification.
- date of certification expiration.
answer:
7 1031/ MISC 8
. o Revision: 0 June 10, 1986 I.d.2: Review of Specific TUGC0 procedure's), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 16) Does/Do the procedure (s) identify any special physical characteristics need in the performance of activities? If so, is there a requirement for verification by examination at intervals, not to exceed one year (N45.2.6 para 2.5)?
YES l l NO l l answer:
- 17) Does/Do the procedure (s) define the minimum capabilities that qualify personnel to perform inspections, examinations and test, at the various levels in accordance with the following:
Level I (N45.2.6 para 3.2)
YES l l NO l l A Level I person shall be capable of performing the inspections, examinations, and tests that are required to be performed in accordance with documented procedures and/or industry practices. The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of inspection and measuring equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved.
8 1031/ MISC 8
Revision: 0 June 10, 1986 I.d.2: Review of Specific TUGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 17) (Cont'd)
Level II (N45.2.6 para 3.3)
YES l l NO l l A Level II person shall have all of the capabilities of a Level I person for the inspection, examination or test category or class in question. Additionally, a Level II person shall have demonatrated capabilities'in planning inspections, examinations, and test; in setting up tests including preparation and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections examinations.
Level III (N45.2.6 para 3.4)
YES l l NO l l A Level III person shall have all of the capabilities of a Level II person for the inspection, examination or test category or class in question. In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to train and test inspection, examination, and test personnel whose qualifications are covered by this Standard.
Level III (Reg Guide 1.58 section C.5)
YES R NO l l l
Level III individuals should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish
, the inspection, examination and test objectives.
answer:
9 1031/MISCB
Revision: 0 June 10 1986 I.d.2: Review of Specific TUCCO procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 18) Does the commitment to Reg Guide 1.58, take exception to the recommendations for, education and experience described in Section 3.5 of N45.2.6. (Reg Guide 1.58 Section C.6)
YES l l NO R 4
answer:
- 19) If the answer to 18 above is No. Does/Do the procedure (s) require, education and experience for the various levels, in accordance with para 3.5.1, 3.5.2 and 3.5.3 of N45.2.6?
YES l l NO l l
, answer:
- 20) Does/do the procedure (s) require, that personnel who are assigned responsibility and authority to perform the functions listed below, have as a minimum, the level of capability shown. (N45.2.6 para 4) i YES l l NO R 10 1031/ MISC 8
Revision: 0 June 10, 1986 I.d.2: Review of Specific TUGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 20) (Cont'd)
Level Project Function L-I L-II L-III l
Recording inspection, i examination, and testing i data X X X Implementing inspection, examination, and testing procedures X X X Evaluating the validity and acceptability of inspection, examination, and testing results X X Reporting inspection, examination, and testing results X X Supervising equivalent or lower level personnel X X Qualifying lower level personnel X X Evaluating the adequacy of specific programs used to train and test inspection, examination and testing personnel X Oualifying same level personnel X answer:
11 1031/ MISC 8
Revision: 0 June 10, 1986 I.d.2: Review of Specific TUGC0 procedure (s), to the requirement of ANSI N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 21) If the procedure (s) provide for a single inspection or test to be implemented by a team or group and personnel not meeting the certification requirements, are used for data taking or in-plant or equipment operation, is there a requirement that these personnel have sufficient training to ensure an acceptable level of competence and performance and that they are supervised or overseen by a qualified individual, participating in the inspection, examination or test. (N45.2.6, pa a 4; Reg Guide 1.58 Section C.7)
YES l l NO l l answer:
- 22) Is a file of records of personnel qualifications, established and maintained by the employer and is collection, storage and control, in accordance with, ANSI N45.297 (N45.2.6, para 5)
YES U NO R answer:
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- 1031/ MISC 8
I Rsvision: 0 June 10, 1986 I.d.2: Review of Specific TUCCO procedure (s), to the requirement of ANSI.N45.2.6 1978 and Regulatory Guide 1.58 Rev. 1. (Cont'd)
- 23) Evaluation / Conclusion Statement.
Signature of Reviewer Date 13 1031/ MISC 8
I.d.:
Limited Checklist Rsv. O Page 1 of 14 ISAP I.d.2 GUIDELINES FOR ADMINISTRATION OF QC INSPECTOR TESTS
Title:
Limited Review of Specific TUGC0 procedures (s), to the requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58 Rev. 1.
Prepared by: -
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Approved by: [ Zh Ib I i This checklist provides specific directions to aid in the review of TUGC0 procedures CP-QP-2.1, Revisions 6 through 16 and CP-QP-2.3, Revisions 2 through 4. The review will be limited to six requirements extracted from ANSI N45.2.6 and Regulatory Guide 1.58 which were found discrepant during the review of CP-QP-2.1, Rev. 17 and CP-QP-2.3, Rev. 5.
Each question is directly related by paragraph to ANSI N45.2.6 and applicable section of Regulatory Guide 1.58. Each question will be evaluated and answered individually for each revision (rev. 6 through
- 1. Does/Do the procedure (s) provide for the removal of persons from an activity, if during the periodic evaluation or at any other time, it is determined by the responsible organization that their capabilities are not in accordance with the job qualifications (N45.2.6 para 2.3)?
1255/ MISC 10
I.d.2 Limited Checklist Rev. O Page 2 of 14 g
YES NO Comments:
1 Rev. 3 (partial)
YES NO Comments:
i i h. CP-QP-2.1 Rev. 13. CP-QP-2.3 Rev. 4 YES NO Comments:
}
1255/ MISC 10
I.d.2 Limited Checklist Rev. O Page 3 of 14
YES NO Comments:
- 2. Does/Do the procedure (s) require re-evaluation of an individual who has not performed inspection, examination, or testing activities for a period of one (1) year (N45.2.6 para 2.3)? ,,
1255/ MISC 10
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- I.d.2-Limited Check'.ist
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-Comments:
3
YES NO Comments:
Rev. 3 (partial)
YES NO Comments:
l l
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J. CP-QP-2.1 Rev. 15, CP-QP-2.3 Rev. 4 YES NO Comments:
- 3. Does/Do the certification record form contain the following information (N45.2.6 para 2.4)?
- employer's name.
- identification of person certified.
- level of capability.
- activities certifie3 to perform.
- basis used for certification, including
- a. records of education, experience and training.
- b. test results, where appropriate.
- c. results of capability demonstration.
- results of physical examinations, where required.
- signature of employer's designated representative.
- date of certification.
- date of certification expiration.
1255/ MISC 10
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YES NO Comments:
1255/ MISC 10
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Page 7 of 14 Rev. 3 (partial)
YES NO Comments:
J. CP-QP-2.1 Rev. 15, CP-QP-2.3 Rev. 4 YES, NO Comments:
l
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Limited Checklist Rev. O Page 8 of 14
- 4. Does/Do the procedure (s) define the minimum capabilities that qualify personnel to perform inspections, examinations and test, at the various levels in accordance with the following:
Level I (N45.2.6 para 3.2)
A Level I person shall be capable of performing the inspections, examinations, and tests that are required to be performed in accordance with doeurented procedures and/or industry practices.
The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of inspection and measuring equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved.
Level II (N45.2.6 para 3.3)
A Level II person shall have all of the capabilities of a Level I person for the inspection, examination or test category or class in question. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations, and test; in setting up tests including preparation and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations, and tests; in supervising and certifying lower level personnel; in reporting inapection, examination, and testing results; and in evaluating the validity and acceptability of inspection, examination, and test results.
Level III (N45.2.6 para 3.4)
A Level III person shall have all of the capabilities of a Level II person for the inspection, examination or test category or class in question. In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to train and test inspection, examination, and test personnel whose qualifications are covered by t his Standard.
Level III (Regula. .y Guide 1.58 section C.5)
Level III individuals should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives.
1255/ MISC 10 l
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E' I.d.2 Limited Checklist Rev. O Page 9 of 14
1
YES NO Comments:
t' Rev. 3 (partial)
YES NO Comments:
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- 5. Does/Do the commitment to Regulatory Guide 1.58 take exception to the recommendations for education and experience described in Section 3.5 of N45.2.6 (Regulatory Guide 1.58 Section C.6)?
)
i 1255/ MISC 10 1
- , - - - - - . - . - - _ _ ~ . _ , . _ . _ , _ . _ . _ . - _ _ , . . _ _ . - - . _ _ _ _ . _ _ - . _ _ , - _ . _ _ . _ _ . _ . _ _ , _ - _ _ . _ .
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9
YES NO Conuments:
Rev. 3 (partial)
YES NO Conuments:
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- 6. If the answer to 5 above is No. Does/Do the procedure (s) require education and experience for the various levels in accordance with para 3.5.1, 3.5.2 and 3.5.3 of N45.2.67
1255/MIScl0
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YES NO Comments:
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YES NO Comments:
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- 7. Evaluation / Conclusion Statement Signature of Reviewer Date 1255/ MISC 10
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Pas;a 1 ef 12
/ 7 QUALIFICATION, TRAINING, AND (RE) CERTIFICATION OF CPSES NON-ASME QC INSPECTORS ATTRIBUTE CHECKLIST EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM ISSUE-SPECIFIC ACTION PLAN I.d.2 Approved a /, [ 6 / b f Date:
Cate' gory'I Programmatic 4Is!r/
/
ISAP Supervisor Reviewert Date M/7/N ob se rve r t h , Wak/N Date S/')/f(/
0898/ MISC 6
BACKGROUND The Texas Utilities Generating Company (TUGCO) procedure CP-QP-2.1 addresses training non-ASME QC Inspectors at the Comanche Peak Steam Electric Station (CPSES). Based on ANSI N45.2.6, "1978" and Regulatory Guide 1.58, Revision 1, it establishes the methods to train, qualify, and certify those individuals designated to perform non-ASME QC inspection functions.
This attribute checklist provides guidance when verifying the implementation of the program relative to training, qualifying, and certifying non-ASME QC Inspectors at CPSES. Supplemental attribute checks may be added. When applicable, the source of each attribute check is indicated in parenthesis.
PERSONNEL CONTACTED R. Byrd, Senior Quality Engineer A. Contino Quality Training Supervisor J. Gallagher, Lead Training Coordinator L. Gladman, Certifications 2 0898/ MISC 6
s 1.0 QUALIFICATION !
Candidates for QC inspector certification are evaluated initially ,
based on their education and experience. l 1.1 ATTRIBUTE CHECKS (Findings are documented on Attachment 1.)
1.1.1 Candidates for QC Inspector Level I have evidence of !
(3.2.1):
- a. A high school diploma or general educational !
development (GED) and
- b. at least 6 month's experience in equivalent inspection, examination, or testing activity; or
- c. An associate's degree in a related discipline and
- d. at least 3 month's experience in equivalent inspection, examination, or testing activity.
1.1.2 Candidates for QC Inspector Level II have evidence of (3.2.2): ;
- s. A high school diploma or GED and
- b. at least 1 year's satisfactory performance as a QC '
Inspector Level I/QC Technician in the applicable inspection, examination or test categoryg or
- c. A high school diploma or GED and
- d. at least 3 year's experience in equivalent '
inspection, examination, or testing activity; or
- e. An associate's degree in a related discipline and
- f. at least 1 year's experience in equivalent i inspection, examination, or testing activity; or 3 A bachelor's degree and
- h. at least 6 month's experience in equivalent i inspection, examination, or testing activity. !
.l 1.1.3 Candidates for QC Inspector Level III and i Administrative and General Level III personnel have '
evidence of (3.2.3):
- a. A high school diploma or GED and
- b. at least 6 year's satisfactory performance as a QC Inspector Level II in inspection, examination, or tests or
- c. A high school diploma or GED and
- d. at least 10 year's experience in equivalent inspection, examination, or testing activityg or
- a. A high school diploma and
- f. at least 8 year's experience
- in equivalent inspection, examination, or testing activity or 3 0898/ MISC 6
A
'~
6 A j i
- Experience shall include at least 2 Jf ear's associated with nuclear facilities, or in lieu of such nuclear experience, inuoctrination in the QA aspects of a'avelear facility and at least 2 year's as a QC
.Y .
Inspector level'7.I. 4
- g. An associate's degree and ' ,
- h. at least 7 year's experiance** in equivalent
+,
inspection, examination, or testing activity; or '
, ** Experience shall include at least 2 year'a .
ascociated with nuclear facilities, or in lieu of.such nuclear experience, indoctrination in the QA aspects of a nuclear facility.
, i. A bachelor's degree nel J. at least'S year's experience *** in equivalent
. inspection, examination,'or testing activity.
- Ex'perience shall include at least 2 year's 4
experience associated with nuclear facilities, or in lieu of such r.eclear experience, indoctrination in the QA aspects of a nuclear facility.
4 2.0 VERIFICATION The Quality training Group verifies the. education and any applicable experience of QC Inspector candidates prior to their certification.
4 2.1.1 Thern is evidence that the QC Inspector <:andidate's applicable education and experience was verified (3.2.4).
2.1.2 There is evidence that the QC Inspector candidate's applicable education and experience was verified prior to his or her certification at CPSES (3.2.4).
3.0 INDOCTRINATION AND TRAINING QJalic'y pers6nnel including QC Inspectors, Administrative and General I.evel III personnel, the Site QC Manager, Quality Engineers i receive indoctrination in Quality Assurance and training in select site procedures and specific work activities, er on-the-job training. Doewmentation provides evidence of the completion of any required indo::trination and training.
3.1 The scope of indoctrination in QA, as typically indicated on '
the " Training Record" form, includes (3.5.1.a):
I 4 0898/ MISC 6 i
y f
- a. the philosophysof quality;
- b. Codes and -
- c. standards; +
- d. the CPSES Quality Program and ,
- e. organization; ; s
- f. project overview and
- g. Quality commitments.
3.2 Ccaplete " Training Record" forms typically indicate (Attachment 4): ;
i
- a. the date the instruction was provided;
- b. the topic;
- c. the name of the instructer;
- d. the names of the attendees,
- e. their signatures,
- f. badge numbers, and ,
- g. '
- h. social security numbers;'re, the instructor's signatu
- i. the hours of training provided, and J. the time the training was provid d.
3.3 The scope of general training, as typically' indicated on the
" General Training Outline", includes (3.5.1.b):
- a. the " core" of site procedures, and
- b. instruction common to all Quality functions at CPSES.*
- E.G., processing Non-conformance Reports, Inspection Reports, training requirements, qualification requirements, etc.
3.4 " General Training Outlin." forms typically indicate (Attachment 6):
- a. the appropriate revision designation of CP-QP-2.1;
- b. the name of the individual required to read the listed procedures; '
- c. the date he or she started to read, ,
- d. his or her signature; and i
- e. the date the procedure was read.
3.5 The scope of specific training, as typically indicated on the
" Technical Training Outline", includes instructions in 03.5.1.c):
- a. specific inspection procedures and/or instructions for the applicable discipline and ,
- b. other applicable documents.
3.6 " Technical Training Outline" forms initiated on or af ter 11/18/85 typically indicate (Attachment 7):
- a. the name of the individual required to perform any prerequisites, then read and discuss the listed documents; 5 0898/ MISC 6
C' .. *.~
4 1
- b. the date he or she started to read / discuss the l instruction (s) and I' c. any prcrequisite certifications;
- d. any prerequisite training and, as required,
- e. the signature of the authorized Certification Coordinator 4
verifying it and
- f. the date it was verified;
- g. any prerequisite reading and d' , h. the signature of the trainee and
- i. the date any prerequisite reading was done;
- j. the applicable inspection instruction;
- k. the signature of the trainee and
,u 1. the date the instruction was read / discussed;
- m. the signature of the responsible QC Supervisor, or designee authorized to implement the training program (2.3.2.b), and
- n. the date he or she discussed the instructions with the trainee.
- o. the signature of the Quality Engineer who approved them,
- p. the date they were approved, and
- q. his or her name printed.
3.7 Self-study, relative to required reading, is typically documented on " Required Reading Completion" forms, w
3.8 Complete " Required Reading Completion" forms typically indicate (Attachment 5):
- a. the applicable procedure number,
- b. its revision, and
- c. title;
- d. the printed names of the individuals required to read
! P U, the procedure,
- e. their signature,
- f. badge rumber, and
- g. social security number;
- h. the date the procedure was read;
- i. the Quality Training individual acknowledging receipt of the training record and s j. the date it was received.
. 3.4 On-the-job training is typically indicated on the "On-the-Job
[ ,
Training / Proficiency Demonstration Evaluation" form (3.5.1.d).
l 3.10 "On-the-Job Training / Proficiency Demonstration Evaluation" forms, completed for on-the-job training, typically indicate (Attachment 8):
- a. that it was used for on-the-job training;
- b. page number information;
- c. the applicable procedure or instruction number,
- d. its revision number, and
- e. and title; 6 0898/ MISC 6
- f. the minimum hours required;
- g. the total hours completed;
- h. the name of the Level III Inspector certified in the applicable discipline who established (i.e., prepared) the requirements and
- i. the date they were prepared;
- j. the name of the trainee,
- k. his or her social security number, and
- 1. badge number;
- m. the required work activities;
- n. the initials of the Level II or III Inspector certified in the applicable discipline supervising the training (3.5.1.d);
- o. the initials of the trainee;
- p. the number of training hours given and
- q. the date it was accomplished.
4.0 EXAMINATION Upon the satisfactory completion of the required training, QC Inspector candidates are tested to ensure they have sufficient knowledge in the current procedural requirements and exhibit those characteristics (e.g., visual activity, skills, etc.) necessary to perform their responsibilities.
4.1 The Visual Acuity Examination (VAE) (Attachment 3) forms typically document the results of those examinations administered to QC Inspector candidates (3.4.a).
4.2 The VAE forms typically indicate that certified QC Inspectors have satisfactory corrected or uncorrected near vision (3.4.a).
4.3 When, due to the scope of an inspection, it is necessary to correctly identify colors (3.4.b):
- a. VAE forms typically document the satisfactory results of a Ishisara Color Vision Test, or
- b. documented color test, other than a Ishisara Color Vision Test, indicate that the QC Inspector can discern those colors as required by the inspection procedure (3.4.b).
4.4 Color test, other than a Ishisara Color Vision Test, are conducted only with the approval of the Quality Engineering Supervisor or designee (3.4.b).
4.5 The Quality Training Supervisor, or designee endorses Visual Acuity Examination forms, or their equivalent (Attachment 3).
4.6 VAE forms typically serve to indicate that Visual Acuity Examinations are conducted at least yearly (3.4.c).
7 0898/ MISC 6
r s
4.7 Measures are established to ensure the security and confidentiality of written examination questions and answers (3.6.1.h). Such measures include:
- a. access code entry to the computer;
- b. restricted access to the examination questions and
- c. answers;
- d. the retention of the (hard) copy of the examination questions and answers in a secure file.
4.8 Written examination questions are developed from current procedural requirements (3.5.2 and 3.6.1.a).
4.9 Written examination questions are approved by (3.6.1.g):
- a. a cognizant Quality Engineer (for technical content) and
- b. the Quality Training Supervisor, or desi~gnee (for structure).
4.10 The elimination of incorrect and/or inappropriate examination questions are authorized by (3.6.1.c):
- a. a cognizant Quality Engineer and
- b. the Quality Training Supervisor, or designee.
4.11 Examination questions are selected for each test on a random basis (3.6.1.a) .
4.12 Each test, based on the same procedure, contains the same number of questions of equal value (3.6.1.b).
4.13 Written examinations are administered only after training in the procedure upon which the examination is based has been accomplished (3.6.1.d).
4.14 Members of the Quality Training Staff proctor written examinations (3.6.1.h).
4.15 Written examinations are scored accurately.
4.16 Personnel failing a written examination are retrained prior to a retest (3.1.6.e).
4.17 Re-examinations, including proficiency demonstrations, are administered (3.6.1.e):
- a. not before 2 days of the failed test, or
- b. not af ter 2 weeks of the failed test.
4.18 Any individuals failing two tests are ineligible for further examination (or certification) in that procedure (3.6.1.f).
8 0898/ MISC 6
4.19 "On-the-Job Training / Proficiency Demonstration Evaluation" forms document examinations relative to the QC Inspector l candidate's ability to perform inspection procedures (3.6.2).
4.20 "On-the-Job Training / Proficiency Demonstration Evaluation" forms, completed for proficiency demonstration, typically indicate (Attachment 8):
- a. that it was used for proficiency demonstration;
- b. page number information;
- c. the applicable procedure or instruction number,
- d. its revision number, and
- e. title;
- f. the minimum hours required;
- g. the total hours completed;
- h. the name of the Level III Inspector certified in the applicable discipline who established (1.e., prepared) the requirements and
- i. the date they were prepared;
- j. the name of the trainee,
- k. his or her social security number, and
- 1. badge number;
- m. the required work activities;
- n. the signature of the individual authorized to evaluate proficiency and
- o. the date is was evaluated.
4.21 Any inspector candidate failing a proficiency demonstration examination is given on-the-job training prior to ratesting (3.6.2.c).
4.22 Any inspector candidate failing two proficiency demonstration examinations is ineligible for retesting (or certification in that inspection procedure (3.6.2.d).
5.0 WAIVERS Other than education and/or experience requirements, waivers in the prerequisites normally specified in CP-QP-2.1 say be authorized when it is determined that the inspector candidate possesses comparable or equivalent knowledge and skill to that which would have been acquired through on-the-job training, etc.
5.1 Requests for waivers are submitted on a " Waiver" form (3.8) and typically indicate (Attachment 14):
- a. the name of the candidate,
- b. his or her social security number;
' c. the specific activity to be waived;
- d. justification for the waiver which concludes that the candidate currently possesses the knowledge skill that is comparable or equivalent to the normally required training; 9 0898/ MISC 6
- e. the applicable certification (s);
- f. the name of the individual requesting the waiver; '
- g. his or her title, and I
- h. the date the waiver was requested;
, i. concurrence by an appropriate Level III QC Inspector and ;
- j. date;
- k. concurrence by the QC Supervisor and
- 1. date;
- m. approval by the QC Manager, Site or General Level III and
- n. date.
6.0 CERTIFICATION Upon the completion of the required indoctrination, training and examination, qualified candidates are certified QC Inspector Level I, II. or III.
6.1 Candidates for QC Inspector Level I and/or II are typically evaluated and certified, as applicable, on a " Quality Department Inspection Certification" form (3.7).
6.2 " Quality Department Inspection Certification" forms typically ,
indicate (Attachment 9):
- a. the name of the Level I or II candidate and
- b. his or her social security number,
- c. the degree or diploma obtained,
- d. the date it was obtained, and
- e. the course of study;
- f. the length of any related experience;
- g. information relative to the level and discipline of any prior certification;
- h. the date training was completed;
- i. the score of the written examination (s);
- j. the date proficiency was demonstrated, (i.e., field practical date);
- k. notation of any waivers;
- 1. comments (e.g. , certification limitations (3.7.1);
- m. the date of the eye examination (s) and their results;
- n. the revision number of CP-QP-2.1 in effect at the time of certification;
- o. the applicable level,
- p. activity, and
- q. the correct inspection procedure (s) or instruction number (s);
- r. whether the certification is an initial one, or
- s. an upgraded one, (which includes the level);
- t. the signature of the QC Inspector Level III certified in the activity performing the evaluation (3.7) and l u. the date of the evaluation;
- v. the concurrence of the Quality Engineering Supervisor (2.3.2.b) and 10 0898/ MISC 6
- w. the date of concurrence;
- x. the signature of the individual authorized to endorse the certificate and
- y. the date of certification;
- z. the date of expiration (not to exceed 3 years from the date of certification) (3.7.2.).
6.3 Candidates for QC Inspector Level III are typically evaluated and certified, as applicable, on a " Certificate of Qualification" form (3.7.3).
6.4 " Certificate of Qualification" forms typically indicate
.(Attachment 13):
- a. the name of the Level III candidate;
- b. the appropriate level (III) designation and
- c. activity (e.g., Civil, Mechanical, Welding, Electrical, NDE, or I/C) (3.7.3.a through f);
- d. any restrictions;
- e. the date of certification;
- f. the signature of the QC Manager Site or
- g. the individual authorized to endorse the certificate, and
- h. his or her title.
7.0 RECERTIFICATION QC Inspectors are evaluated annually to ensure continuous satisfactory performance.
7.1 Recertifications are typically documented on a " Annual Performance Evaluation" form (3.7.2).
7.2 Racertification evaluation is conducted at leest annually for QC Inspectors Levels I, II, and III (3.7.2).
7.3 " Annual Performance Evaluation" fores typically indicate (Attachment 12):
- a. the name of the QC Supervisor and
- b. the date of the evaluation;
- c. the applicable inspection procedure or instruction and
- d. level;
- e. the name of the QC Inspector requiring recertification and
- f. the date his or her certification is due to expire;
- g. an indication of the inspector's performance during the past year;
- h. a mark to indicate whether recertification is required and, as appropriate,
- i. whether recertification is recommended at the current level, or to
- j. another Level, or to
- k. allow the current certification to expire; 11 0898/ MISC 6
l
/. ' ; -
- 1. the name of the individual qualified to witness and evaluate a proficiency demonstration,
- m. his or her signature, ;
- n. date, and I
- o. title or position;
- p. the signature concurrence of the appropriate QC )
Supervisor and
- q. date.
7.4 The " Quality Control Recertification" form typically serves as evidence of the satisfactory performance evaluation (3.7.2) .
7.5 " Quality Control Recertification" forms typically indicate (Attachment 11);
- a. the name of the QC Inspector;
- b. his or her social security number;
- c. the authorized level,
- d. activity, and e, number of the applicable procedure or instruction;
- f. the signature of the reviewer and
- g. the date the review was performed;
- h. the signature of the cognizant Level III Inspector and
- 1. the date of evaluation;
- j. the signature of the Quality Engineering Supervisor and
- k. the date of concurrence;
- 1. the signature of the certifying authority and the date of certification;
- m. the date of expiration (not to exceed 3 years from the date of recertification) (3.7.2).
8.0 SUPPLEMENTAL CHECKS 8.1 " Technical Training Outline" forms initiated from 8/19/G5 to 11/17/85 typically indicate (CP-QP-2.1, Rev. 18, Attachment 7):
- a. the applicable discipline;
- b. the nana of the individual required to read / discuss the listed documents and
- c. the date he or she started to read / discuss the instruction (s);
- d. the applicable inspection instruction number (s) and
- e. title (s);
- f. the signature of the trainee and
- g. the date the instruction was read / discussed;
- h. the signature of the responsible Lead Inspector and
- 1. the date he or she discussed the instructions with the trainee;
- j. the signature of the Quality Engineer who approved them and
- k. the date they were approved.
12 0898/ MISC 6
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/)Ib CPSES DISCIPLINE CERTIFICATION NON-ASME QC INSPECTORS ATTRIBUTE CHECKLIST EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM ISSUE-SPECIFIC ACTION PLAN I.d.2 Approved: b 4 Date: (, 9!$[o
$4tegory I Progrjamatic //
ISAP Supervisor l
Reviewer: Date:
4 Observer: Date:
1003/ MISC 8
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BACKGROUND The Texas Utilities Generating Company (TUGCO) procedure CP-QP.-2.1 addresses training non-ASME QC Inspectors at the Comanche Peak Steam-Electric Station (CPSES). Based on ANSI N45.2.6, "1978" and Regulatory cuide 1.58 Revision 1, it establishes the methods to train, qualify, and certify those individuals designated to perform non-ASME QC inspection functions. Specifically, revisions 18 and 21 of the referenced TUGC0 procedure require field proficiency examinations be administered by a cognizant individual certified to a Level III in that activity / discipline. Revisions 19 through 21 require personnel to receive training in.any revisions to the inspection procedure / instruction in which they wera initially certified.
This attribute checklist provides guidance _when verifying the qualifications of those individuals administrating and. assessing field proficiency examinations and determining whether training in revised inspection procedures / instructions is conducted as required.
Supplemental attribute checks may be added. When applicable, the source of each attribute check is indicated in parenthesis.
PERSONNEL CONTACTED 1.0 QUALIFICATION Field proficiency examinations are administered by cognizant individuals certified to a Level III in that activity / discipline as required.
1.1 ATTRIBUTE CHECKS (Findings are documented on Attachment 1.)
1.1.1 "On-the-Job Training / Proficiency Demonstration Evaluation" forms, completed for proficiency examinations administrated during August 19, 1985 to October 3, 1985 and May 8, 1986 to the present*,
typically indicate the signature of the cognizant individual certified to a Level III in that activity / area. (3.6.2.b.)
CP-QP-2.1 Revisions 18 and 21 ef fective dates.
2 1003/ MISC 8
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2.0 TRAINING Since October 4, 1985, personnel are trained in revisions to the inspection procedure / instruction in which they were initially certified.
2.1 ATTRIBUTE CHECKS (Findings are document 2d on Attachment 2.)
2.1.1 Training in revisions to the procedures, as required, is documented on a (3.5.2):
- a. Training Record for classroom training (3.5.2.a),
- b. Training Record for require'd reading (3.5.2.b), or
- c. Technical Training Outline (3.5.2.c).
2.1.2 The Training Record for classroom training indicates the (Attachment 4):
- a. date (after 10/4/85) the instruction was provided;
- b. topic, or instruction procedure / instruction in effect at the time the training was provided;
- c. name, signature, and badge and social security numbers of the inspector requiring training.
2.1.3 The Training Record for required reading indicates the (Attachment 5):
- a. number and
- b. revision of the procedure in effect at the time it was read;
- c. name, signature, and badge and social security numbers of the inspector requiring training; and
- d. the date (after 10/4/85) the procedure /
instruction was read.
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3 1003/ MISC 8
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2.1.4 The Technical Training outline indicates the (Attachment 7):
- a. name of the inspector requiring training;
- b. the date (after 10/4/85) training commenced; and
- c. the number and
- d. revision of the applicable procedure in effect at the time of the training.
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June 3, 1966 Page 1 of 3 I.d.2 Guidelines for Administration of QC Inspector Tests
Title:
Review of TUCCO's Current Test Bank of Certification Examination Questions, to a Specific Procedure / Instruction Prepared by: 2./w/
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Date: 4/; [6 r
Approved by: [j ( Date: (/.i $G ll '
This instruction / checklist is to provide specific direction to aid in the evaluation of TUGCO's current test bank of certification examination questions, for technical content as they apply to a specific written procedure / instruction and to evaluate these questions to assure they effectively measure the inspector's familiarity and ability to perform that specific activity.
- Complete checklist item 1. by entering the selected CP-QP/QI-QP's number, revision and issue date.
Complete checklist item 2. by entering CP-QI/QI-QP's title.
- Complete checklist item 3. by entering discipline of CP-QP/QI-QP.
- Checklist items 4. thru 10. self-explanatory.
- Complete item 11. by providing an evaluation / justification of the results of this checklist based on items 6 thru 10.
i 0999/ MISC 6
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- Fevision: 0 June 3 1986 I.d.2 Review of TUGCO's Current Test Bank of Certification Examination Questions, to a Specific Procedure / Instruction ,
a 1.) CP-QP/QI-QP No:
Revision -al Issue Date:
2.) CP-QF/QI-QP
Title:
3.) CP-QP/QI-QP Discipline: .;
4.) Total number of questions on exam:
5.) Total number of questions available for specific CP-QP/QI-QP:
6.) Exam is open closed book.
7.) Are exam questions clearly written?
Yes [__J No l 8.) Do exam questions address the technical aspects of the CP-QP/QI-QP?
Yes No 9.) Do exam questions serve to demonstrate the inspector's familiarity with the specific activity?
Yes (([] No 10.) Do exam questions serve to demonstrate the inspector's ability to perform the required inspection activity?
Yes [__] No 2 0999/ MISC 6
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Examination Questions, to a Specific Procedure / Instruction ii.) Evaluation /Juytification of exam.
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QUALIFICATION, TRAINING, AND (RE) CERTIFICATION OF CPSES NON-ASME QC INSPECTORS ATTRIBUTE CHECKLIST
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Catego'ry I Programatic VM '
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1260/ MISC 10 .
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Page 2 ef 4' BACKGROUND ANSI N45.2.6-1978 requires that quality assurance program personnel who plan and set up inspections, supervise or maintain surveillance over e
inspections, supervise and certify lower level personnel, report
", inspection results, and evaluate the validity and acceptability of inspections be certified to Level II capability.
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Subsequently, the NRC teported that:
"... coating quality assurance program personnel who
'N it planned and set up inspections, supervised or maintained surveillance over inspections, supervised and certified lgwer level personnel, reported inspection results, and evaluated the validity and acceptability of inspectione, were certified to a Level I capability in lieu of .the required Level II." (EA 86-09) g ,
This attribute checklist provides the guidance necessary to ensure that established TUGC0 procedures authorize only those individuals certified to a level II (or III) capability to plan and arrange; supervise or maintain; certify; report on; and evaluate activities / individuals, as required, and to ensure that Level I personnel do not perform any of those specific responsibilities.
.x PERSONNEL CONTACTED
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1260/ MISC 10
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Page 3 of 4' l.0 PROCEDURE ADEQUACY 1.1 Attribute Check The TUGC0 procedure CP-QP-2.1 requires quality assurance program personnel planning and arranging' inspections; supervising or maintaining surveillances over inspections; supervising and certifying lower level personnel; reporting on inspection results; and evaluating the validity and acceptability of inspections be certified to at least a Level II capability.
-Finding.
1260/ MISC 10
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2.0 IMPLEMENTATION 2.1 Attribute Check Level I personnel do not perform any activities assigned to Level II personnel as aquired by ANSI N45.2.6 Specifically:
- 1) Planning and arranging inspections.
- 2) Supervising or maintaining surveillances over inspections.
- 3) Supervising and certifying lower level personnel.
- 4) Reporting on inspection results.
- 5) ' Evaluating the validity and acceptability of inspections.
Finding 1260/ MISC 10 i
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