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- 1. Allegation Category: QA/QC 4, Training and Qualification
- 2. A11egation' Number: AQ-23, AQ-24, AQ-26, AQ-27, AQ-28 and AQ-108
- 3. Characterization: -It is alleged that quality control inspectors are not qualified due to inadequate trainirig, that there was widespread cheating
-on certification exams, and that training records are incorrect. There are also allegations that a small group of quality control (QC) inspectors in the design change verification group (DCVG) and a group of QC inspectors inspecting 2500 class 5 hangers were inadequately trained.
- 4. Assessment of Safety Significance:
The NRC Technical Review Team (TRT) reviewed 5 Brown & Root (B&R) procedures and 21 Texas Utilities Generat-ing Company (TUGCO) procedures to determine if they complied with. ANSI N45.2.6-1978, Regulatory Guide 1.58, Revision 1, and SNT-TC-1A-1980. The TRT also reviewed the training and certification files for 102 QC person-nel (13 Level I QC inspectors, 76 Level II QC inspectors, 8 Level III QC inspectors, and.5 QC. clerks). In addition, the TRT interviewed eight Level II QC inspectors, the training coordinator for ASME QC inspectors, and the training coordinator for the non-ASME QC inspectors. Of the 102 QC personnel whose training records were examined, 79 were ASME-certified.
In addition, 37 of the 79 ASME inspectors had non-ASME certifications for Hilti bolts. The TRT reviewed tests for Level II visual weld (VT) inspec-tors and Level I and Level II mechanical fabrication (MIFI) inspectors.
.The ASME personnel training and certification program was established by -
B&R procedure CP-QAP-2.1, a general personnel training and certification procedure, and the more specific B&R procedures QI-QAP-2.1-5, " Training and Certification of Mechanical Inspection Personnel," and QI-QAP-2.1-1,
" Nondestructive Examination Personnel Certification." These procedures were detailed and met or exceeded the requirements of ANSI N45.2.6, Regulatory Guide 1.58, and SNT-TC-1A-1980. The requirements for each in-spection discipline and level were well defined, with inspector education level and experience specified for each level of inspection. The proce-dures contained outlines for certification and recertification, and in-i ciuded detailed procedures for certification training. On-the-job train-i ing (0JT) was also outlined for each inspection discipline.
There were two areas in the QC testing program which were poorly defined i
- in the B&R procedures. The first area was that the type of test monitoring (i.e., proctor) for certification testing was not specifically defined.
Second, there was no specific program for periodically establishing new tests, except when procedures were changed.
One other area of concern to the TRT was B&R's and the Texas Utilities Elec-tric Company's (TUEC's) interpretation of the applicable ANSI standard, ANSI i
N45.2.6, paragraph 3.5, " Education and Experience Recommendations," which i delineates the education and experience recommendation for each level of i
i inspector. The standard also states that other factors which may demon-strate capability in a given job are previous performance or satisfactory
! completion of capability testing. Paragraph g of the "Value/ Impact of Action" in Regulatory Guide 1.58 states: " Regulatory Position 6 of the regulatory guide states that a commitment to comply with the regulatory fM52i365 ~ sib 05 ? #
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guide will mean that the education and experience recommendations of the standard will be followed." B&R and TUEC procedures quote the ANSI guide-lines as their standard of inspector certification; however, in practice, they did not follow the guidelines. Their system followed the exception by using "other fac. tors" as the normal method for qualification.
The non-ASME personnel training and certification program was governed by TUGC0 procedures CP-QP-2.1, " Training of Inspection Personnel,"
CP-QP-2.3, " Documentation within QA/QC Personnel Qualification File,"
and TUGC0 quality instructions QI-QP-2.1-1 through QI-QP-2.1-19.
Although, TUEC had committed to ANSI N45.2.6 and Regulatory Guide 1.58, the TRT has the following concerns about the lack of specificity of its procedures and quality instructions.
(1) There were no requirements for verification of education and work experience.
(2) Personnel capabilities were not specifically defined by levels (I, II,III).
(3) The specific inspection disciplines were addressed in separate quality instructions and were administered by a cognizant quality
. engineer in that discipline. There was no one individual who controlled the training programs. As a result, the overall quality training program lacked cohesion.
(4) Recertification could be accomplished by a simple "yes" from an inspector's supervisor.
(5) There were no guidelines for using waivers for OJT, even though waivers were frequently used.
(6) The certification testing program had many problems, including:
(a) No requirement for additional training between a failed test and a retest.
(b) No time limitation on how soon an individual could retake a failed exam.
, (c) No assurance that the same test would not be given consecutively.
i (d) Two different scoring methods used to average the results when two tests were taken.
(e) No guidelines on how or when a question could be disqualified on a test.
(f) No program for establishing new tests, except when procedures changed.
1 (g) No specific details on how tests should be monitored.
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(h) No limits on how many times an individual could be tested for a specific certification.
Many of the above concerns are also addressed in Safety Evaluation Report Supplement 7, Electrical and Instrumentation Category 7, allegation AQE-8.
In reviewing testimony and training and certification files, the TRT identified the following specific problems which demonstrated an overall weakness in the QA training and certification program.
(1) Of all the B&R and TUEC training and certification records reviewed, 20 percent contained no verification of education and/or past employ-ment and work experience. In addition, there were several instances where verification took place after the individual was certified; as long as 2 years later, in one case. There was one instance where an individual listed work experience on his resume that was false.
After receiving correct information from the individual's former employer, B&R noted the fact, but took no further action concerning the person.
(2) There were ten instances where the results of a B&R Level I certifi-cation test were recorded on the Level II certification. The time between the Level I test and the issuance of the Level II certifica-tion varied from 1 month to 6 months. Normal practice was to test individuals at each level of certification. The TRT was unable to determine why these ten individuals were not tested in the normal way.
(3) There were six instances where, after failing a certification test, applicants were permitted to take the identical test; in some cases as soon as the next day. This occurred with both B&R and TUEC applicants.
(4) There was one instance where a B&R certification was issued, but was not signed or dated. The explanation given was that this individual -
would not be used for inspections.
(5) There were two instances where white-out was used on certification examinations, contrary to CP-QP-2.3, paragraph 3.3.1(h).
(6) During one certification examination, two people observed a TUEC QC-inspector applicant leaving the testing area, going to his desk, reading something, then returning to the testing area. Even though his certification was subsequently voided, tests were supposed to be monitored and this one was not. This incident raised questions about how closely the monitoring policy was being followed. There was no apparent corrective action taken by TUEC in this case.
In reviewing B&R and TUEC records, the TRT found seven cases where the qualification of inspectors appeared to be questionable:
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(1) One individual, a millwright prior to his transfer to QC, had no back-ground in QC inspection or nondestructive examination. He was issued a Level 11 certification for liquid penetrant (LP) inspection work 4 months after his transfer to QC, and a Level II certification for magnetic particle inspection work 7 months after his transfer.
(2) Another individual was a carpenter prior to his transfer to QC inspec-tion and had no inspection background. Two months after his transfer to QC, he was issued Level II certifications for VT, MIFI and mechan-ical equipment inspector. After 3 months, he was issued a Level II certification for LP.
(3) A third individual was a laborer with no inspection background prior to entering QC. Four months after transfer to QC inspection, he was issued Level II certifications for LP and VT.
(4) A person who had been an iron worker prior to his transfer to QC had no experience in inspection. Less than 1 month after his transfer to QC inspection, he was issued Level II certification for VT and MIFI.
(5) Another person was a .floorhand on a drilling rig prior to entering QC and had no inspection background. Six months later he was issued a Level II certification for VT, and 7 months after he entered QC inspection he was issued a Level II certification for LP.
(6) In another instance, a carpenter's helper with no background in inspection was transferred to QC. Seven months after the transfer, he was issued a Level II certification for VT; 8 months after the
(7) An ANI liaison person with no background in inspection was also transferred to QC. One month after his transfer, he was issued a Level II certification for VT, and 2 months after his transfer he was issued a Level II certification for MIFI.
In an earlier review, B&R had found that a laborer was hired into QC in-spection with no work experience in QC inspection. Two months after his hire date, he was certified as a Level I inspector for Hilti bolts. A memorandum was sent to the QA manager requesting a waiver of the 1 year experience requirement on the grounds that the individual had received sufficient DJT and had passed a test. The waiver was granted by the QA manager. B&R subsequently discovered that this inspector's work was totally unacceptable and all of his inspection work had to be reinspected.
The requirements in QI-QAP-2.1-5 were intended to prevent an individual from taking the same examination conse- lively and specified that a person who failed three consecutive examina' ions for the same certification was not eligible for qualification and certification in that inspection ac-tivity. The B&R practice of not retaining failed examinations made it difficult to determine if an individual had failed three examinations or if he was retaking the same examination.
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With respect to the allegation that specifically questions the qualifica-tions of the QC inspector in the DCVG, the TRT reviewed the qualifications of all five QC inspectors in that group. The TRT concluded that all inspec-tors were qualified, with the possible exception of an individual whose certification was limited to document-review verification only. -
In reviewing the allegation concerning the inspection of 2500 class 5 sup-ports, the TRT reviewed the qualifications for 19 inspectors involved in that activity. Only one inspector was found to have questionable qualifications.
In the TRT/s review of craft personnel who transferred into QC inspection, five individuals were found to have questionable qualifications.
With the exception of the one case where TUEC identified an individual who had cheated on a certification test, the TRT could not find any docu-mentation that there was widespread cheating on certification examinations.
- 5. Conclusion and Staff Positions: Based on its review of the allegation concerning qualifications of inspectors assigned to the DCVG, the TRT concludes that these inspectors were qualified for the task to which they were assigned. The allegation was not substantiated.
The TRT reviewed the allegation that specifically questioned the q'ualifi-cations of inspection personnel inspecting some 2500 class 5 supports. The TRT reviewed the qualifications for 19 inspectors involved with this activi-ty and concluded that only 1 inspector had questionable qualifications.
The staff position is that, although a small percentage of the inspectors were not qualified, the quality of some of the hardware may be suspect; therefore, the allegation has substance.
With respect to the allegation concerning widespread cheating on QC certification tests, the TRT could find no evidence during interviews or documentation reviews to substantiate this allegation, with the exception of the one case documented by TUEC.
Based on a TRT review of allegations concerning inspector qualifications, certification, and training in general, the TRT concludes that the train-ing and certification program as written for the ASME inspection personnel is adequate with the exceptions already noted. However, in actual practice, this program is not followed scrupulously.
In the non-ASME training and certification program, the TRT found a lack of programmatic controls to ensure that the program achieves and maintains requirements as set forth in 10 CFR Part 50, Appendix B. Problem areas were: (1) in the documentation for qualification, including verification of education and experience; (2) in the training and certification program; (3) in the recertification program; and (4) in the certification testing program. The TRT concludes that these deficiencies in procedural require-ments and guidelines in the training and certification programs have potential safety significance.
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I The TRT does not i nfer from the above that all TUEC and B&R inspectors are unqualified. However, identified inspection deficiencies (as enumerated in the TRT's Electrical and Civil and Structural SSERs) or lack of inspec-tion thereof, indicate a root problem with inspection qualification that is directly traceable to TUEC's and B&R's lack of programmatic controls 1 and use of minimum requirements for the inspection certification program. f 1
In a meeting with the allegers on December 10, 1984, the TRT presented the results of the assessment of the allegations and the TRT's conclusions.
There were no major items of disagreement.
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- 7. Attachments: None.
Reference Documents:
- 1. B&R procedures: CP-QAP-2.1, CP-QAP-2.3, QI-QAP-2.1-1, and QI-QAP-2.1-5.
- 4. Regulatory Guide 1.58, Revision 1.
- 5. Recommended practice SNT-TC-1A, " Personnel Qualification and Certification in Nondestructive Testing," dated 1980.
- 6. QA Personnel Certification and Training Files.
- 8. RIV Inspection Reports 82-11 and 80-15.
- 9. A-5 Interview August 1, 1984, pp. 34-41.
- 10. A-1 Interview August 1, 1984, pp. 63-65.
- 11. A-3 Interview April 26, 1984, pp. 100-105. ,
- 12. A11eg'er Interviews, December 10, 1984, pp. 73-85.
- 8. This statement prepared'by: / low, kl. (4/Im 4/4/J:S-V. Watson, TRT Dat4 /
Technical Reviewer Reviewed by: M4an t 6 f[ H. Livermore Date Group Leader Approved by: _V. Noonan Date Project Director 0-127 e This page iptentionally left blank 0-128