ML20235F285

Forwards Documentation of QA Audit & Associated Reviews Re Adequacy of Student Records & Instructor Requalification Program Under Control of Westinghouse Nuclear Training Ctr in Zion,Il

ML20235F285
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	05/18/1987
From:	Leblond P COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20235F277	List: ML20235F275 ML20235F285
References
NUDOCS 8707130317
Download: ML20235F285 (14)

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\ Commonwealth Edison I d One Fit:1 National Plaza. Chicago, Illinois c'. , / Address Reply to: Post Office Box 767

. \_/ Chicago, Illinois 60690 - 0767 1

May 18, 1987 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion Nuclear Power Station Units 1 and 2 Westinghouse Nuclear Training Center NRC Docket Nos. 50-295 & 50-304

Reference:

January 26, 1987 letter from C.J. Paperiello to Cordell Reed

Dear Mr. Davis:

The referenced letter provided Commonwealth Edison with an allegation regarding the adequacy of student records and the instructor requalification program under the control of the Westinghouse Nuclear Training Center in Zion, Illinois. The allegation stated, in part, that the records of students were inadequate and that the Westinghouse's requalification progran utilized to maintain instructor certification was ill-defined and varied according to the time allotted by Westinghouse.

Commonwealth Edison Company has reviewed this allegation and has been unable to substantiate the specific details. The Zion Station Quality Assurance Department conducted a formal audit of the areas in question and has uncovered no discrepancies in the areas related to the allegation.

However, the Quality Assurance audit did identify an area of concern unrelated to the allegation.

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The fundamental weakness noted in Westinghouse,'s Quality Program related to the retrieval, collation, and storage of records to sul, port an instructor's qualification. Westinghouse has responded to these concerns and the Zion Station Quality Assurance Department has found their response to be acceptable. Copies of the Quality Assurance audit report, Westinghouse's response, and a summary letter written by the Superintendent of Zion Station Quality Assurance are all enclosed.

In addition, the Zion Station Training Department has previously conducted reviews of various training programs presented by Westinghouse Nuclear Training Center in accordance with Zion's Procedures. This procedural guidance is routinely utilized to insure the quality of contracted training purchased for use at Zion Station. These reviews have not identified any deficient training that has been received by Zion Station personnel.

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Davis May 18, 1987~

Full documentation of the Quality Assurance audit and the associated reviews discussed above are maintained on file at' Zion Station.

These records are available for your review.

.If any further questions arise regarding this matter please direct them to this office.

Very truly yours, hP.C. LeBlond Nuclear Licensing Administrator cc:. Resident Inspector - Zion J.A. Norris - NRR l

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Commonwealth Edison r G a c p~?

C'> One First National P:ata Chicago Ilhnois s-C# Accress Reply to Post Ofhce Box 767

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Chicago. liknois 60690 7

' CA . t -v. V L- Q QUALITY ASSURANCE AUDIT REPORT G-87-237 i' Westinghouse ESSD - WNTC er r ... No. S83-A501 1

TYPE AUDIT: Special TO: J. L. Tain - W - Manager CECO. Projects PROJECT: WNTC _ Zion VISIT DATE: 2/9/87 REPORT DATE: 2/9/87 SYSTEM: N/A COMPONENT IDENTIFICATION: N/A MATERIAL DESCRIPTION: Trainino Services VENDOR: Westinghouse Trainino Center LOCATION: N/A ,

SUBCONTRACTOR: N/A -

LOCATION: N/A

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CONTACTS: N. Hammerick P.O. NO. Various SPEC. NO. N/A Recommended Inspections: As Scheduled Notes: The audit identified two (2) findings and two (2) observations. A written response is required by 3/15/87 for findings 1 & 2, and ,

observation 2. This report is issued open.

Auditor j,f J A2(( 6, 4. c6, , 4 f Date 1/N /d/

Lead Audit r d .-v N b w 5% - - Date A / u /d /

Reviewed 8 . [ Date 1/.#1///

1626R cc: Manager QA Project Manager Station Nucl. Eng. Manager Project Eng. Manager Director QA (Eng./Constn.)

Director QA (Operations)

Station Manager (Zion)

G.O. QA Audit Coordinator Auditee - WNTC Site QA Superintendent M. Hammerick - }i QA

y; FESdUARY ? '347 TO J.L. Toia

, Manacer CECO Projects RE. Quality

• Assurance Audit Report Number G-87-237 l Westingneuse ESSD - WNTC - 583-A501 PURPOSE: Tne purpose of th'ss audit was to verify'the Westinghouse Nuclear Training Center is implementing their Quality Assurance Program in the area of Westinghouse ESSD - Zion Sta. - 583-AS01. Specific areas and activi ties reviewed are t e sted under the scope.

SCOPE: This au dit reviewed the activities and documentation associated with the following items; Instructor Qualifications Document Control Simulator Trasning for Instructors Ma s ntenance of Student Records 8 I Design Control

SUMMARY

OF DEFICIENCIES.: The audit resulted in'2 Findings, and 2 Observa-tions.

A brief discussson of the. deficiencies follows. A more detailed description can be found en the Q.A. Au di t Repor t Follow-Up Forms (attached).

• FINDING $1 It couLd not be verified class files four or more years old are .

forwarded to NSID Pittsburgh for preservation.

FINDING $2 It could not be verified the West anghouse Nuclear Training Center Policie's and Procedures Manual is controlled or approved.

OBSERVATION et a

It could not, be veri fied en-process class f a tes are maintained current. (CLOSED) i!

OBSERVATION $2 a'

'i It couta not be verified that quataty training has been conducted in all cases.

AUDIT TEAM: The Audit Team included the following personnel:

W. Stone Lead Auditor L. Oberembt Auditor T. Blake Observer AUDIT

REFERENCES:

The audit was conducted using an approved checklist with questions from the following required references.

WCAP 9245, Rev. 9, Westinghouse Nuclear Training Center Procedures WTC-ADM-1 Rev. 1 WTC-ADM-7 Rev. 2. 10CFRSO App. B. Criteria II; I NRC tetter t/26/87 to C. Reed from C.J. Paperiello PERIOD OF THE AUDIT: An entrance meeting was held on 2/9/87 The attend-ees were as follows W. Stone Lead Au da tor L. Oberembt Audsfor T. Blake Observer I

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CAA C-B7-237 Page 2 9

N. Hammerick Westinghouse J. Evans Westinghouse M. Donovan Westinghouse Personnel contac ted du r ing the audit included N. Hammerick M. Donovan A. Meagher J. Evans N. Halverson An eist meeting was held on 2/9/87. The attendees were as follows.

W. Stone Lead Auds f or L. Oberembt Auditor T. Blake Observer N. Hammerick Westinghouse J. Evans Westinghouse M. Donovan ,

Westinghouse

SUMMARY

Area- Student Records /In-Process Class Records Nine randomly selected Zion SRO candidate files were feviewed for completeness. Included in this review were the class schedule, examina-tion results, evaluations, operational evaluation, s t u de nt data sheets, final examinations, certificates awarded and the operational training recorcs. The files were,found to be neat, legible and orderly. No . I d:Screpancies were noted in this area. Access to student records was controllec.

In-process student class. records were also found to be reasonably controlled and for the-most part were current with co'urse outlines. (See Otse- ' tion ti) ,i Area. Instructor Qualification A review of numerous Westinghouse Instructor training files was completed. Included in those files were the results of Westinghouse internal audit exams, simulator training as well as a detailed listing of courses completed. The files disclosed the proficiency of each instruc-tor and examination grade percentages were clearly adentified for each person. Each instructor's lecture style was also critiqued and docu-mented and a performance evaluation for each phase completed was found in file.

Instructor training was found to be conducted in accordance with WNTC procedures. Simulator training was completed commensurate with the candi cates back ground. The allega tions raised in the NRC letter of 1/26/87 are not substantiated.

Area- Adequacy of Lesson Plans Numerous instructor classroom presentation, lecture techniques and course content were reviewe d to assure West inghouse performed these cr i t iques.

It was verafsed they are routinely performed. In addition, both instruc-tor techniques and instructor technical k nowledge is reviewed. These evalua t ions reviewed inst ructor a t t i tudes, student handou ts, visual a ids used, class participation and facility considerations (lights, temper-ature, etc). No discrepancies were noted. The reviews were found to be quite comprehensive.

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GAA G-07-237

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Area- Document Control / Design Controt

'l Numerous discrepancies were f ou n d in the area of document control. We ak - I nesses were identified in the areas of procedure control and approval, i; transmitting completed in-process files to administration and the.trans- '

fer of completed class records to NSID-Pittsburg for preservation. A '

rev:ew of the WNTC Policies and Procedures Manual was comple ted to veri fy ,

adequate t r aining and cont rols we.. in place (See Finding it). Quality J Procedure Training was also reviewed (See Observatin $2). Records retention, document turnover and records protection was reviewed (See Finding $2). Procedures were found to be in place for the development, verification and documentation of computer coding.

EVALUATION AND ASSESSMENT: The fundamental weakness in the 14NTC Quality Program is the retrieval of records to document quality activities. In no instance could an anstructor's qualification not be documented.

Finding the information in a timely manner is the diffsculty. The records are not kept or filed in a consistent manner. Quality procedures are not consistent with quality activities. Considerable management at tention is required to resolve the quality concerns identified in this au di t . Organization of Instructor files, development and implementation of quality procedures are reeded to resolve the issues raised in the aude'.

Quat tv procedures in the area of document control ar'e not established or -

e f fec t e ve t y implemented.

The attegations as defined in the CJ Pape r iell,o let ter dated 1/26/87 l could not be substantiated. The instructor files reviewed were found to j contain documentation to support acceptable levels of qualification, that  :

each instructor received the correct number of hours on the simulator and that score tests and evaluations were acceptable.

REPLY: Westinghouse is regu s ted to subes t a written response for of this audit by 03/15/87. i This response shall include the,following:

Corrective action to corrac+ the deficiency Action to prevent recurts ce of the deficiency l Da te of completion of corrf ctive action Signature of respondent and Statsun Manager This audit is OPEN.

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CA AUDIT FOLLCw-up I GENERAL OFFICE AUDIT '

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n / C-87-237 Finding 1 Area Audited Westinghouse ESSD - WNTC - 583-AS01

~ Lead Auditor Storie W . Audit Date. 02/09/87 3 i

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• It cou Ld not be verified class files four or more years old are forwarded 3 to NSID Pittsburgh for preservation. 9 1 Discussion WTC-ADM-1 pa 5 requires class files four or more years be forwarded to NSID PittsN. f* r preservation. A tour of the file room disclosed quality records 5: ' rang back to 1971 were still being maintained at the training cen'

• wes also noted these records were kept en a room without fire :sson systems.

Discussions Tra 6ning Center personnel disclosed the records are occassiona . enced and there was no agreement from NSID as to permanent ret,a. . the class files.

Commetment WNTC will provide correcteve actions to be taken in their audit response.

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, G-87-237 Finding 2 Area Audited Westinghouse ESSD - WNTC - 583-A501 Leed Auditor Stone W Audit Date- 02/09/87 Finding 2 It could not be verified the Westinghouse Nuclear Training Center Policies and Procedures Manual is controlled or approved.

l Discussion 5 WCAP 9245. Section 2, page 6 states activities af fecting quality be per-formed in accordance with approved and controlled procedures. A review of the WNTC Policies and Procedures Manual was completed. The following items we r e n'o t e d .'

1) Table of contents did not list all quality procedures

2) Table of contents contained no revision levels

3) Numerous procedures are being revised but no obvious change controls

4) Non-quality related procedures are listed in the manual.

Commitment  !

WNTC to provide a response stating corrective actions to be taken.

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GA AUDIT FOLLOW-UP CENERAL OFFICE AUDIT C-87-237 Reservation 1 Area Audited. Westinghouse ESSD - WNTC - 583-A501 Lead Aucitor Stone W Audst Date. 02/09/87 Observation 1 It could not be ver s f eed in-process class files are maintained current. "

Descussion WTC-ADM-1 page 6 states sn-process class be maintained current. A review of the upper tevet instructor in-process class files was completed. Three of more than 20 class files completed since October 1986 were still found

-en the pending file.

Commetment The three (3) discrepant files were s mee di a te l y up-dated and the Training Center Manager issued an internal memo to all instructors apprising them of the need for attentiveness in this area. This Observation is considered CLOSED.

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CENERAL OFFICE AUDIT G-67-237 Observation 2 Area Audited Westinghouse ESSD - WNTC - 583-AS01 Lead Auditor- Stone W Audit Date 02/09/87 Observation 2

{9 It could not be verified that quality training has been conducted in all '

C is s e s .

s Discussion ,

WCAP 9245 Section 2 page 6 requires personnet performing quality activity i be trained to applicable portions of the quality program. A review of WNTC Training records disclosed the only quality training completed has been 10CFR21 notifications. An internal WNTC memo dated 2/6/87 defined four (4) other quality procedures that were needed.

Commetment WNTC Manager comestied to reviewing and establishing training for WCAP 9245 and the OPRs sooner than 5/87. a

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i Westinghouse Power Systems Nuclear Semte Electric Corporation n'*8'* S*8*

Box 355 Pmsbutgn Pennsylvania 15230-0355 SAQA-87-JJE-135 March 13, 1987 Mr. K. J. Hansing, Director Quality Assurance Engineering & Construction '

Commonwealth Edison Company P.O. Box 767 Byron,' Illinois 60690

Dear Mr. Hansing:

COMMONWEALTH EDISON COMPANY BYRON AND BRAIDWOOD STATIONS - UNITS 1 AND 2 4 Westinghouse Response to CECO Audit #G-87-237

- The attachment to this letter provides the Westinghouse response to the subject audit.

Should you have any questions or concerns relative to our response, please contact us and we will be happy to discuss them with you.

Very tr ly

. . Halls, Project Manager Mid-America Area M. A. Hamrick, Manager Systems & Audits Quality Assurance cc: J. D. Deress, CECO H. Stone, CECO ATTACHMENT:

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>>P FINDING 1 It could not be verified that class files four or more years old are forwarded .

to NSID Pittsburgh for preservation.

Westinghouse Response:

Corrective Action All class files past one year of age will be forwarded to Westinghouse Information and Record Services for microfilming and storage. One copy of the microfilm will be retained in Pittsburgh, and the second copy will be returned to WNTC. Transmittal of

. files to Pittsburgh will be done chronologically, beginning with the oldest files and moving forward in time. '

The student files contain duplicate information already contained in the class files only the information is arranged in a' student specific format. The applicable procedures and/or records flow schedule will be revised to identify the class files as the official quality records which require long term retention and the student files will be.

. - designated as supplemental records which are kept at the Zion Training Center-for information only.

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. Date of Completion for Corrective Action Preparation for shipment of class files (1971 through

- 1986) will begin immediately and proceed at a pace of approximately three years per month. In any event, all class files (1971 through 1986) will be forwarded to Information and Record Service for microfilming by December 31, 1987.

The records flow schedule will be revised by April 30, 1987.

Action to Prevent Recurrence An annual record review and purge will be conducted in the first quarter of each year, in accordance with the requirements of the Records Flow Schedule.

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FINDING 2 {

l It could not be verified that the Westinghouse Nuclear Training Center l Policies and Procedures Manual is controlled or approved.

Westinghouse Response:

1 Corrective Action l Training and Operational Services (TOS) will l implement a review of all TOS and WNTC policies and procedures:

1. To designate policies and procedures which are quality procedures.

2. To determine the need for additional department level quality related procedures.

3. To establish a Table of Contents of all active policies and procedures which lists the most recent approved revision and identify those procedures which are quality procedures and provide a system for controlling the Nuclear Training Center Policies and Procedures Manual.

4. To establish a control system which delineates the ,

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status of all policies and procedures which are in

. revision and which designates the individual responsible for overseeing each revision.

Date of Completion for Corrective Action Quality procedures will be differentiated from administrative procedures by April 30, 1987.

Additional department level. quality procedures that have been deemed necessary will be issued.by April 30, 1987.

A Table of Contents for all procedures will be developed and a system for controlling the Nuclear Training Center Policies and Procedures Manual will be implemented by April 30, 1987.

A control system for policies and procedures in revision will be developed by June 30, 1987.

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Action to Prevent Recurrence Implementation of the aforementioned process, including the issuance of a policy and procedure to formalize it, should prevent recurrence.

OBSERVATION 2 It could not be verified that quality training has been conducted in all cases.

Westinghouse Response:-

Corrective Action TOS will schedule and conduct training in those quality procedures already in place (10CFR50, App. B; 10CFR21; HCAP9245; N5ID-OPR-110-1; NSID-OPR-225-1; TOS-ADM-1).

TOS will schedule and conduct training in those TOS

. procedures designated as quality procedures (see response to Finding 2).

08te of Completion for Corrective Action Complete training for existing quality procedures by March 31, 1987.

Complete training for newly-designated quality procedures by June 30, 1987.

- Actions to Prevent Recurrence Within the first quarter of each year TOS will issue

- a training plan which includes training in quality procedures.

TOS will establish as part of the quality policy and procedure revision process (see response to Finding

2) that training is conducted on approved revised policies and procedure,s within two months of their issuance.

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April 10,1987 To: C.J. Schultz

Subject:

'WNTC Allegations As you are aware, the C.J. Paperiello letter of 1/26/87 detailed specific allegations they' received concerning the qualification of licensed instructors at Westinghouse's Nuclear Training Center. The letter directs Ceco to provide'the results 00 our review of those allegations. With technical assistance from the Zion Station Training Department, Site Quality Assurance conducted an audit of all relevant aspects of the Westinghouse

. Quality Assurance Program approved for use by CECO on 2/9/87.

Theauditidentkfied2Findingsand2 Observations. The assessment is as follows:

The allegations, as stated in the NRC letter of 1/26/87 could not be substantiated. The WNTC Instructor files reviewed were found to contain adequate documentation to support acceptable levels of qualification, that

each instructor' received the correct number of hours on the simulator and that

' test scores and test evaluations were acceptably reviewed.

The fundamental weaknesses in the WNTC Quality Program is the retrieval, collation and storage of records to support an instructor's

, qualification. Significant effort will be needed to organize and maintain l those quality records.

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The Westinghouse response to those deficiencies has been received and evaluated for acceptability by Site Quality Assurance. Corrective action follow-up remains to be accomplished in the next CO to 90 days, 'If corrective action implementation is effectively implemented, the audit will be considered closed.

This should provide you the necessary information to forward NRC regarding this matter. Should any other information be deserved, please notify Quality Assurance. 4 W. Stone Station Quality Assurance Superintendent Zion Station WS/ jet 1107u cc: W.J. Shewski/J.S. Bit 1/J.G. Marshall H.P. Studkirdfin ff/ f7 M. Carnahan/T. Blake