ML20246L519
| ML20246L519 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/26/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20246L515 | List: |
| References | |
| NUDOCS 8909060346 | |
| Download: ML20246L519 (8) | |
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j Comm::nw;alth Edison -
i 72 West Ad*.ms Street. Chcago, lilinois.
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- / Address Riply to Post offee Box 767 l
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. July 26, 1989 Lq t
Mr. A..Bert Davis Regional Administrator ~
U. S. Nuclear. Regulatory Commission Region III J
799 Roosevelt Road
.l Glen Elolyn, IL Subjects.~ Byron Station Units 1 and 2 NRC Allegation RIII-88-A-0112
-]
NRC Docket Nos. 50-454 and 50-455 I
Reference ' (a) ~ June 27, 1989, letter W. D. Shafer to Cordell Reed i
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Dear Mr. Davis:
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Reference (a) informed Commonwealth Edison that the previous response to NRC Allegation RIII-88-A-0112 was inadequate. Af ter contacting Mr. Shafer of your staff, Commonwealth Edison believes that Attachment A to this letter provides the requested additional information.
The attachment to this letter contains information which is exempt from public disclosure according to'10 CFR 2.790(a)(7).
)
Please' address any additional questions regarding this matter to this office.
Very truly yours, V
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T. J.
vach Nuclear Licensing Manager RAC/Im 3
Attachment cc Byron Resident Inspector j
J. Hinds RIII 8909060346 890815 PDR ADOCK 05000454
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- e b]TACIRiENI SUPPLEMENTAL RESIXMSE_JD_ALIEGAIIEN NRR-88-A-Oll2/RIII-88-A-0112 BACTERQLMD In your letter dated June 27, 1989, regarding Commonwealth Edison's response to an allegation (RIII-88-A-0112), you found that this response was inadequate for several reasons. We have evaluated these concerns and are providing additional information to clarify our investigation of the allegation.
1.
The results of your investigation relles on an audit of Allen Nuclear in 1986 t'o verify that their quality assurance program was adequate for a time period which is one to two years later.
The purpose of using information from the Babcock & Wilcox (B&W) audit of Allen Nuclear Associates ( ANA) performed in 1986 was not to evaluate the adequacy of their quality assurance program.
The work performed at Byron was done in accordance with the B&W QA program, not ANA's program.
During the outages of concern at Byron Station, ANA personnel worked for B&W and were certified by B&W to the requirements of th( B&W QA program. The B&W audit of ANA provided an instance where the training and experience of certain ANA
-personnel were confirmed to meet the applicable standards at a point in time just prior to the first outage of concern at Byron (November 1986 versus February 1987). Of the sixteen ANA employees used at Byron Station, fifteen were used during the Unit One refuel outage in early 1987_ and three were used during the short Unit One outage in May and June of 1988. During the B&W QA Audit, qualification records for 10 of the individuals that worked at Byron were reviewed. The B&W QA audit confirmed adequate qualifications for seven of these ten individuals. Corrective actions taken by ANA because of audit deficiencies qualified the three additional individuals.
2.
Your results do not specify the type of training received or work performed by the Allen Nuclear employees during the first six months of employment.
The applicable work assignment and amount of training for each ANA employee is detailed in Table 1.
Our original response referred to three individuals that had less than six months employment with ANA as the focus for evaluating whether or not " individuals with little or no experience were hired by Allen Nuclear" to meet contractual obligations.
The applicable standard, ASNT SNT-TC-1A contained in Attachment A, delineates the training and experi-ence requirements for eddy current testing personnel, which is dependent on the amount of formal education received.
It is possible for an individual to meet Level I requirements with only one month of experience and eight hours of training.
Therefore, we believe it is more prudent to review the actual training and experience of the involved individuals against the standard's requirements than for the first six month period of employment.
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3.
The.use of background screening records to establish the validity of employee training is questionable..
Our original response was not clear regarding the way background I
screening records were used.. The background investigations performed by independent agencies were used to confirm the levels of formal education attained by the ANA. personnel so that the appropriate requirements from the
.ASNT standard could be determined. These investigations were also used to l
confirm any previous employment with other NDT companies and to verify q
employment with ANA for. periods of time. when experience with ANA was l
referenced.
l
-1 4.
In your results, you did not provide any supporting evidence that there were no incentives for falsifying eddy current testing records during the data acquisitions phase.
l During the data acquisition phase, the operators are remotely controlling the computer assisted probe. The computer records the eddy current results for each tube on a magnetic tape that is then analyzed by'two separate analysts as described in the original allegation response. The
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contractor then provides a summary report documenting the analysis for each l
tube. The data acquisition operator is unaware of the results of the analysis at the time of acquisition. The analyst ensures that each tube is analyzed by entering the completed analysis into another computer that compares the
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analyzed tubes with those that should be analyzed. If any tubes were missed, the computer identifies the missed tubes and the analyst instructs the data acquisition operator to eddy current the missed tubes. Furthermore, for the May and June, 1988, emergency outages, the contracts for the eddy current testing were stipulated in a dollar amount per day plus salaries for each of
,j the employees at Byron Station. There were therefore no monetary incentives to complete the job early.
I Based on the method used to acquire and analyze the eddy current data, Commonwealth Edison does not believe there were incentives for falsifying eddy current testing records.
l ADDITINAL INF0JMATINJEGIESTED
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1.
Perform an independent verification of the education and employment
,l histories of the Allen Nuclear employer involved in eddy current testing.
l' Information from the following data sources has been gathered and
.l compared to confirm that ANA employee cCacation and employment histories are ir. compliance with the ASNT standard:
A.
B&W cerblfication records submitted to Byron Station prior to work initiation. The Station Quality Control Department reviewed these records prior to the start of eddy current testing to verify that the B&W personnel (including ANA employees) met the requirements of the ASNT standard.
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B&W Quality Assurance Audit No. 241-1 and responses. These documents contain information on ANA employees who were confirmed to meet the applicable standard at the time of the audit.
C.
B&W training records.
In some instances, B&W provided training to ANA personnel that met the ASNT requirements.
D.
-Vendor training records.
Some certification packages included records of training-provided by vendors.
E.
ANA Personnel Certification Summary-Records. These are the records meintained by ANA and submitted to a utility or a contractor to provide detailed.information on how the ASNT requirements are met.
F.
ANA NDT Work Experience Summary Records. These are the forms j
- maintained by ANA that provide the actual time worked on each NDT l
assignment and at what level.
i G.
Eackground investigation records.
As discussed previously,. this information was gathered by independent investigative agencies for the purposes of complying with utility security screening programs.
l These records include information on formal education and employment l
histories.
l l
1 H.
Radiation expost.e records. These records were reviewed to correlate periods of exposure at various f acilities with the listed NDT experience.
We believe that these multiple sources of information provide the l
basis of an independent verification of the education and employment historier i
l-for the ANA personnel that were subcontracted by B&W to do eddy current l
testing at Byron Station.
2.
Make a comparison of the results achieved in (1) above to the resumes they submitted.
In addition, compare the results of this effort to the requirements of the job (s) they were assigned at the Byron Station.
A summary has been prepared in Table 1 that compares requirements for the work ~ activities performed with the actual training and experience y
received.
The review performed for (1) above confirmed that the ANA personnel employed at Byron Station had the required level of training and experience
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needed for the NDT certification that B&W authorized. ANA did not submit resumes directly to Commonwealth Edison because they were. subcontracted to B&W.
B&W submitted certification packages to the Byron Station Quality Contol Department for review prior to the start of work activities. These packages included information based on ANA Personnel Certification Summary Records provided to B&W.
The review performed in (1) above compared the B&W certification data to other source documents.
Some minor discrepancies were identified due to transcription errors, typographical errors, and simplification of periods of employment; however, none of these discrepancies af fected the NDT qualification for the work performed at Byron Station.
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l-A final measure of assurance that the ANA personnel were in fact qualified to perform their work activities was provided by the certification testing that B&W conducted.
Since the ANA personnel were working to the B&W OA' program, it was necessary for B&W to certify them to the appropriate NDT classification. This required administration of an examination to each ANA employee that included questions on the theoretical and practical aspects of eddy current testing which corresponded to the education and experience levels required by the ASNT standard.
All ANA employees used by B&W successfully passed this examination prior to performing work at Byron Station.
3.
Conduct an overview inspection of a sample of ongoing eddy current testing and an independent inspection of a sample of completed eddy current testing to demonstrate that scheduled work of safety-related systems was in fact completed.
At the present' time thre are no ongoing eddy current activitles being conducted at Byron Station which would provide an opportunity for an overview inspection. However, there have been three previous audits performed by our Quality Assurance Department of work activities, including eddy current testing, conducted by B&W while at Byron Station.
These audits were performed in April 1987, April 1988, and February 1989 and included reviews of Inspection, Test and Operating Status Organization OA Program Instructions, Procedures, and Drawings Document Control Identification and Control of Faterial, Parts, and Components Control of Special Processes Inspection Control of Measuring and Test Equipment QA Records Performance of Internal Audits The audit results included the following conclusions:
B&W Ouality Control inspectors assigned to observe steam generator Eddy Current (ET) inspections...were administrative 1y independent of the crews performing the work activities.
QC inspectors performing quality inspections were found to be properly trained and qualified for the activities performed.
Non-destructive' examination of the steam generator tubes...were performed by qualified personnel in accordance with applicable codes and standards, using quall'ied procedures.
B&W CC inspectors verified the proper location of steam generator tubes that were plugged per the requirements of a B&W procedure.
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.:The Eddy Current inspections for the S/G; tubes listed the steam generator, location of the tube, and the station as Byron II for each tube inspected.-
B&W performed work activities, including the steam generator Eddy Current tube inspection...to written procedures which contained appropriate quantitative and qualitative acceptance criteria.
A review was conducted on statusing of inspections and tests to determine that the' results of the' examinations are properly documented in accordance with approved procedures. The B&W statusing program was verified to be as delineated in their procedure.
Test and Measurement Equipment used by. B&W for work at Byron Station were found to be controlled and calibrated at specific intervals.
Inspection status of steam generator tubes was documented on each computer gener'ated screen print for Eddy Current exams.
Inspectors performing the Eddy Current examination were verified to be properly quallfled per B&W procedures.
Records reviewed as objective evidence did not indicate records falsification Based on these findings we conclude that sufficient independent overview of the eddy current activities performed by B&W was conducted at the time work was in progress and that the scheduled safety-related activities were in fact completed.
4.
Provide the names of those employees of Allen Nuclear Associates Corporation, who were assigned to the Byron Station during the outage of 1987 and again during the May-June 1988 outage.
Table 1 includes the name codes and work dates for the ANA personnel assigned to Byron Station for the applicable outages. Table 2 provides a cross reference between name codes and the individuals' names. There were only two individuals (name codes 3 and 9) that were used during both of these outages.
HUMiAR1 Commonwealth Edison Company believes it has fully analyzed the allegation'and determined that the there is no substance to it and, consequently, no further actions are required to resolve it.
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