ML20235U752
| ML20235U752 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/16/1987 |
| From: | TELEDYNE ENGINEERING SERVICES |
| To: | NRC OFFICE OF SPECIAL PROJECTS |
| Shared Package | |
| ML20235U707 | List: |
| References | |
| TR-6710-3, NUDOCS 8707220576 | |
| Download: ML20235U752 (12) | |
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"vPTELEDYNE ENGINEERING SERVICES TECHNICAL REPORT '
TR-6710-3 TECHNICAL EVALUATION REPORT ON COMANCHE PEAK RESPONSE TEAM --
RESULTS REPORT REVISION 1 FOR ISSUE SPECIFIC ACTION PLAN ISAP I.d.2 GUIDELINES FOR ADMINISTRATION OF QC INSPECTOR TESTS -*
JULY 16, 1987 D
A DOCK 00 45 PDR m
U.S. NUCLEAR REGULATORY COMMISSION-DIRECTOR OF COMANCHE PEAK PROJECT DIVISION ~
OFFICE OF SPECIAL PROJECTS WASHINGTON, D.C. 20555 TECHNICAL REPORT TR-6710-3 TECHNICAL EVALUATION REPORT ON COMANCHE PEAK RESPONSE TEAM RESULTS REPORT REVISION 1 FOR ISSUE SPECIFIC ACTION PLAN ISAP I.d.2 I GUIDELINES FOR ADMINISTRATION OF QC INSPECTOR TESTS JULY 16, 1987
\
WTELEDYNE ENGINEERING SERVICES 130 SECOND AVENUE WALTHAM, MASSACHUSETTS 02254 '
617-890-3350
"RTELEDYNE ENGINEERING SERVCES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 1 FOREVORD Under contract with the NRC, Teledyne Engineering Services was directed to conduct a review of specific Comanche Peak Response Team Issue Specific Action Program Results Reports, to determine if the applicant adequately addressed issues of concern identified by the NRC in previous Supplemental Safety Evaluation Reports. Included in the NF.C's direction were tasks that required TES to:
o Review the reports and, as necessary, provide the NRC with Requests for Additional Information (RFAI).
o Evaluate the applicant's responses to the RFAI.
o Upon completion of the review of the Reports and RFAI responses develop and submit to the NRC a Technical Evaluation Report in a prescribed format for each Results Report. The TES effort did not include evaluation of the implementation activities performed by the CPRT under the individual ISAPs.
The TES evaluation of the Results Report (Revision 1) for ISAP I.d.2,
" Guidelines for Administration of QC Inspector Tests", follows:
"eTI:1 FTWNE ENGINEERING SERVICES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 2
1.0 INTRODUCTION
This Issue Specific Action Plan (ISAP) I.d.2, " Guidelines for Administration of QC Inspector Test", addresses the NRC's concerns that arose from the Technical Review Team (TRT) Electrical Group's assessments of Allegations AQE-8, AQE-4 and AQE-12. These assessments presented in Supplemental Safety Evaluation Report (SSER)-7, pages J55-J58, found that there was a lack of guidelines and procedural requirements for the testing and certifying of QC electrical inspectors.
The Applicant was initially informed of the concern in the Enclosure to the NRC's letter (D. G. Eisenhutt to M. D. Spence) dated September 18, 1984 (Ref. SSER-7 pages J103 and J104). The enclosure (pages J110-J112) cited a number of findings, requested that TUEC take specific action to review and resolve the findings and further stated:
"Accordingly, TUEC shall develop a testing program for electrical QC inspectors which provides adequate administrative guidelines, procedural requirements and test flexibility to assure that suitable proficiency is achieved and maintained."
"The deficiencies identified with the electrical QC inspections have generic implications to other construction disciplines. The implications of these findings will be further assessed as part of the overall programmatic review of QC inspector training and qualification and the results of this review will be reported under the QA/QC category on " Training and Qualification."
The TRT QA/QC Group's assessments of Allegations AQ-23, 24, 26, 27, 28 and 108 which pertain to the training and qualification of QC inspectors (other than electrical) are reported in SSER-11 on pages 0107-0111. The QA/QC Group's consensus regarding the TUGC0 Inspector)
(QC certification / testing program presented in SSER-11 Appendix P pages P-28 and 29, states in part:
"RTELEDYNE ENGINEERING SERVCES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 3 "There were also many problems with the certification testing program for the non-ASME inspectors. There was no time limit between a failed test and a retest, there were different scoring methods to grade the original test and the retest, there were no guidelines on how a test question should be disqualified, and there were no details on how the administration of tests should be monitored."
The Applicant was initially notified of the TRT QA/QC Group's finding as a QA/QC Issue in the enclosure to the NRC's letter to the Applicant (D.
G. Eisenhutt to M. D. Spence) dated January 8,1985. (Ref. SSER-11 pages 0277-0278 and Section 6, pages 0300-0301). The details of the TRT's findings were enumerated and item M on page 0301 cited the same TRT consensus as above.
The January 8, 1985 letter requested that TUEC evaluate the TRT findings and consider the implications of these findings on construction quality at Comanche Peak. Additionally, the letter stated: "We request that you submit to the NRC, in wri ting, a program and schedule for completing a detailed and thorough assessment of the QA issues presented in the enclosure to this letter. The TRT considers the construction QA/QC findings to be generic to both Units 1 and 2 and your program plan and schedule should address both units. This program plan shall: (1) address the root cause of each finding and its generic implications on safety-related systems, programs, or areas, (2) address the collective significance of these deficiencies, and (3) propose an action plan from TUEC that will ensure that such problems do not occur in the future."
It is significant to note that this ISAP addresses only training / testing / certification of TUGC0 QC inspectors. Inspector qualifications and the impact of the use of potentially unqualified inspectors are addressed in ISAP I.d.1.
"RTri FrT(NE ENGNEERNG SERVCES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 4 2.0 CPRT APPROACH In response to the action requested in the NRC letter dated September 18, 1984 (Ref. SSER-7 page J-103), the Applicant / Project formulated ISAP I.d.2 Revision 0 dated October 5, 1984 which addressed the concern related only to Electrical Inspectors.
ISAP Revision 1 dated June 21, 1985 was prepared by the CPRT to include the additional QC Inspector testing / certification concerns identified by the TRT's QA/QC Group in the NRC's January 8,1985 letter.
Revision 1 also considered any additional information, related to these concerns, which may have been identified in SSERs-7 (January 1985) and -11 (May 1985).
The Staff's review of revision I resulted in comments which were presented in the NRC's September 30, 1985 letter to the Applicant and the Applicant responded to the NRC by a letter dated November 22, 1985. ISAP Revision 2 issued January 24, 1986 reflected the applicant's response which expanded the listing of items considered in the evaluations conducted by the Special Review Team (SET) (Ref. ISAP Section 4.1). Also, TUEC's personnel and responsibilities were identified as well as the Decision Criteria.
The objective of this action plan is to ensure that the TUGC0 QC Inspector training and certification program complies with ANSI Standard N45.2.6 - 1978 and Regulatory Guide 1.58, Revision 1. The specific TRT issue primarily addressed the training and certification program for Electrical Inspectors. In light of the potential generic implication for other QC inspector training and certification, this plan addresses the training and certification program for all TUGC0 QC inspectors. To accomplish the objective the Review Team and TUEC QA conducted the following three tasks.
WTF1 PTWNE ENGNEERNG SERVK?ES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 5 A Special Evalua, ion Team (SET) consisting of individuals with no prior responsibilities .r administering the CP inspector certification program conducted the first task by a review of the applicable procedures.
The review considered a number of defined attributes to asses the adequacy of the procedural methods used by TUGC0 in the training, testing and certification program to determine compliance with TUEC's commitment in the Final Safety Analysis Report (FSAR). Upon evaluation of the results of this review the SET presented recommendations for program improvement to TUEC QA. The QA/QC Review Team Leader (RTL) will document his concurrence with the SET's recommendations. (Ref. ISAP Section 4.1.1).
In the implementation of the second task, TUEC QA evaluated the SET's recommendations and revised procedures and instructions as necessary. This TUEC evaluation was overviewed by the QA/QC Review TeamLeader(RTL).
Also, TUEC reviewed all inspector certification examination currently in use to ensure that they reflect the requirements of the revised procedures / instructions. Additionally, in conjunction with the inspector qualification records system reviews described in ISAP I.d.1 (QC Inspector Qualifications) a review was conducted by the RTL to determine if other improvements should be made to the program to enhance the training of inspection personnel. (Ref.ISAPSection4.1.2).
Under the third task the effectiveness of procedure changes was evaluated by the QA/QC Review Team by reviewing the Qualification Files for a number of QC inspectors who have been certified and/or re-certified since the issuance of TUGC0 Procedure CP-QP-2.1, Revision 18 dated August 19, 1985. (Ref. ISAP Section 4.1.3).
The Standards used for this plan were ANSI N-45.2.6-1978 as endorsed by Regulatory Guide 1.58 Revision 1. Acceptance was based on the criteria specified in the standards. (Ref. ISAP Section 4.5).
WTO lRNE ENGINEERING SERVCES Technical Repcrt .TER - ISAP I.d.2 TR-6710-3 Page 6 The Decision Criteria require the RT's assurance that the current inspector training / procedures clearly meet the requirements, the QA/QC RTL has concurred that the FSAR commitment has been satisfied, the revised procedures and their implementation are in compliance with the Standards Acceptance Criteria and the need for improvement in the training program has been identified. (Ref.ISAPSection4.6) 3.0 EVALUATION 3.1 Evaluation of CPRT Approach The ISAP, Rev. 2 deleted a commitment (see Rev. 1 Section 4.1.1 second paragraph) related to Craft Personnel's lack of awareness of a 1
fabrication / installation manual for junction box / conduit supports. The deletion did not diminish previous CPRT commitments since the concern is now more appropriately addressed in ISAP I.d.3, " Craft Personnel Training."
The issue is identified correctly and the plan addresses the specific details of the concerns regarding the QC inspector training /
testing / certification program which were identified in SSER 7 and the NRC September 18, 1984 letter to the applicant. The findings of SSER-11 were not addressed specifically in the ISAP Revisions 1 and 2, however, TES noted that the attributes applied to the procedure review (Ref.ISAP Section 4.1.1) correlate with the findings reported in SSER 11, page 0-300, Section 6, items A through H.
TES noted that the ISAP Revision 2 Section 4.1 second paragraph stated in part"...this plan addresses the training and certification program for all CPSES Inspectors"; however the methodology in Section 4.1.1 indicates that the plan addresses only the TUGC0 Inspectors. The Results Report Section 3.0, Background, page 4, first paragraph states that an RTL/SRT decision was made to focus this plan (ISAP I.d.2) on the TUGC0 certification program and not to review the related Brown & Root (B&R) procedures for certification of inspectors under the B&R ASME program. The
"RTELEDYNE ENGINEERING SERVCES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 7 bases for the, decision are accurately and adequately explained and justified since the adequacy of implementation of the current B&R certification program is being verified during the implementation of ISAP I.d.1, "QC Inspector Qualifications." TES' evaluation of I.d.1 finds that the B&R ASME program is addressed therein and the CPRT's commitment was not ,
diminished by the decision.
The SET reviewed the applicable procedures against TUGCO's commitment in FSAR Chapter 17, Section 17.1.2 and Appendix 1A(B) to determine compliance. The review considered defined attributes (Ref. ISAP Section 4.1.1) that are consistent with the specific requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58 Rev.1 that must be included in the implementing procedures. The procedures reviewed, CP-QP-2.1 and CP-QP-2.3, were identified by TRT as the source of the concerns 1 TES believes that the plan's methodology is adequate and appropriate to determine compliance, identify procedural weaknesses, and provide appropriate recommendat*ons to TUEC to revise the procedures. This plan relies heavily on the /
management / supervisory experience of the personnel (SET, ERC) conducting its implementation (Ref. ISAP Section 4.3). TES considers the RTL's overview of the SET's review a desirable action that will lend added assurance that appropriate recommendations are being provided to TUEC. TES finds that the methodology is adequate and appropriate for conducting the plan's first task (Ref. ISAP Section 4.1.1).
l TUEC's action to evaluate the SET's recommendations and, if necessary, issue revised procedures was overviewed by the QA/QC RTL. TES considers the RTL's overview an appropriate and necessary action to assure that the SET's recommendations were properly evaluated by TUEC and that the
- 1. It should be noted that the issue addressed in this ISAP is the training /t(sting / certification of inspectors. Procedure CP-QP-2.1 is entitled " Training of Inspection Personnel". However, the scope and purpose of the procedure states that it establishes the training qualification and certification requirements for quality personnel to perform inspections.
"RTELEDYNE ENGINEERING SERVCES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 8 revised procedures / instruction reflect compliance with the FSAR commitment.
Additionally the RTL's overview of TUEC's review and revision of current inspector certification examinations is appropriate and necessary to assure examiriations reflect current procedure requirements and that TUGCO's testing and certification of inspectors will be conducted in accordance with the revised procedures. In summary, TES finds that the action plan's second task provides adequate and appropriate methodology to assure that procedures and examinations have been revised as necessary to reflect compliance and the potential need for improvement in the QC inspector training program has been considered. (Ref.ISAPSection4.1.2)
The review of the qualification files for inspectors certified /
decertified since August 18, 1985 is appropriate methodology to evaluate the effectiveness of procedure changes. The file for each inspector contains the record documentation (e.g. training, verification of education / experience, waivers, tests etc.) necessary to reflect effective implementation of the RT's recommended revisions to the controlling procedure. It is noted that the revised procedures are also applied to the evaluations of QC inspector qualifications under ISAP I.d.1 (Ref. ISAP Section 4.1.3 - Third Task).
With respect to the Standards / Acceptance Criteria, the TRT's assessments confirmed TUGCO's FSAR commitment to 10CFR50 Appendix B, ANSI N45.2.6-1978 and Regulatory Guide 1.58 Revision 1. TES considers it appropriate that the plan applies the specific requirements of these documents as the bases for the conclusions resulting from the implementation of this plan. (Ref. ISAP Section 4.5)
TES finds that the Dec' .' ion Criteria appropriately address the RT's assurance that the plan has been properly implemented, the results of implementation have been evaluated, and the revised procedures and their implementat'on ensure that TUGC0's training, testing and certification of QC inspectors is in compliance with the FSAR commitment (Ref. ISAP Section 4.6).
"A'TELEDYNE
, ENGINEERING SERVICES Technical Report TER - ISAP I.d.2 TR-6710-3 Page 9
4.0 CONCLUSION
TES concludes that the issue is identified correctly, the FSAR commitment is accurately identified and the scope of the plan encompasses the issue. Implementation of the described methodology for the three basic tasks is adequate and appropriate to enable the RT's evaluation of the TUGC0 QC inspector training / certification program for compliance, recommend procedure / program changes and evaluate the effective implementation of the changes. It is TES' opinion that the results of proper implementation of this plan will meet its objective to ensure that the CPSES inspector training and certification program is in compliance with TUEC's commitment to ANSI Standard N-45.2.6-1978 and Regulatory Guide 1.58 Revision 1 as identified in the FSAR Chapter 17.1. Accordingly, based on this evaluation, TES concludes that this plan describes an adequate approach to evaluate and resolve the issue and is responsive to the NRC's requested action.
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