ML20214T332
| ML20214T332 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/26/1986 |
| From: | Wolldridge R, Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Bloch R, Jordan W, Mccollum K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-896 OL, NUDOCS 8609300264 | |
| Download: ML20214T332 (44) | |
Text
'
WlC044/stMW@g f6 WOHSIIAM, FoRSYTIIE, SAMPELS Oc WOOLDRIDGE COLKETEE THIRTT TWO MUNDRED 2001 BRYAN TOWER bhh
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.OS "' R* n'.T.'S c teMotMY A. MACK ww. STEPHEN SOYO a$ PMER n.MILigNSEmOEm mOSEnf P. OktvER Mann SCMwamit 0~"Cvc 6 J* v"'<M September 26, 1986 CCCELIA J. Smus.Em JOC A. Davis tRfC H.PCTERSON Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory 881 West Outer Drive P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2): Docket Nos. 50-445 and 50-446
Dear Administrative Judges:
Applicants have this date delivered to Mr. Vincent S. Noonan the SRT approved Results Report I.d.2 Guidelines for Administration of QC Inspector Test.
As a part of our continuing effort to keep the Board apprised of matters which relate to the licensing of Comanche Peak, we are enclosing four copies of the Results Report. This material is not being offered into evidence at this time, and is provided for information only.
Respectfu'ly, 9609300264 860926 ,
PDR ADOCK 05000445 a - -
/ 4'/L/
Robert A.
ooldridge /N RAW:mh Enclosures cc: Service List hSh
CPRT-669 Log # TXX-6001 File # 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NORTH OLIVE NTREET. L.B. El . DALLAS. TEXAS 75201 September 26, 1986 eME"Ahif.7.*A Director of Nuclear Reactor Regulation Attn: Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 CPRT RESULTS REPORT
Dear Mr. Noonan:
We transmit herewith the SRT approved Results Report I.d.2, Guidelines for Administration of QC Inspector Test. The files which contain supporting documentation for the Results Report have been reproduced in their entirety and are available for public inspection in our Dallas office. Anyone wishing to inspect these files should contact Ms. Susan Palmer (214/979-8242).
We shall issue further Results Reports on a periodic basis as they are approved by the CPRT Senior Review Team.
Very truly yours, WOL W. G. Counsil WGC/amb Enclosure A UlVENION OY TRKAN llTil STEEN El EMTNEO CO.WYANY
CPRT-0668 LOG NO. TUS-4926 FILE NO. 10068 TEXAS UTILITIES GENERATING COMPANY
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Tff,,7,,",8,Cf September 26, 1986 MEMORANDUM TO: MR. W. G. COUNSIL
SUBJECT:
CPRT RESULTS REPORT We transmit-herewith the SRT approved Results Report listed below. The files which contain supporting documentation for the Results Report have been reproduced and are available in the Dallas file room for public inspection.
I.d.2 - Guidelines for Administration of QC Inspector Test - Revision i U.
John W. Beck Chairman, CPRT Senior Review Team JWB:tj Enclosure cc: CPRT File A ouvusson or nxAs smurrsus usammc contrasr
i' n
e COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.d.2
Title:
Guidelines for Administration of QC~ Inspector Test REVISION 1 O -
) Die ce &r- y ,/,/u.
IsswG Coordinjrtor Date ' '
[
i R
u%Li ew Team Leador Date' rhlu'
=- E sJ. 0 Joh# W. Beck, Chairman CPRT-SRT Date 9// 7/%
i O
Revision: 1 4 Page 1 of 40 RESULTS REPORT ISAP I.d.2 Guidelines for Administration of QC Inspector Tests
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7 Page J-111)
"The TRT found a lack of guidelines and procedural requirements for the testing and certifying of Electrical QC Inspectors.
Specifically, it was found that:
- No time limit or additional tr,aining requirements existed between a failed test and retest.
- No controls existed to assure that the same test would not be given if an individual previously failed test.-
No consistency existed in test scoring.
No guidelines or procedures were available to control the disqualification of questions from the test.
4
() -
No program was available for establishing new tests (except when procedures changed). The same tests had been utilized
- for the last 2 years."
i 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-111)
"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 i generic implications to other construction disciplines. The
{ implications of these findings will be further assessed as part of j t'he ~overall programmatic review of QC inspector training and
! qualification and the results of this review will be reported under I
the QA/QC category on ' Training and Qualification'."
3.0 BACKGROUND
1 Prior to 1978, Brown & Root, as part of their overall responsibility as constructor, maintained a QC inspector
, certification program covering both ASME and non-ASME site inspection activities. TUGCO QA initially established a QC
Revision: 1
, Page 2 of 40 l
I 0 ~
RESULTS REPORT ISAP I.d.2 (Cont'd)
3.0 BACKGROUND
(Cont'd) inspector certification program in 1978 when TUGC0 assumed responsibility for the non-ASME QA program. Brown & Root retained responsibility for the ASME QA program and maintained their own separate QC inspector certification program to support the ASME QA l program.
, Since its inception in May 1978, the TUGC0 QC inspector certification program has been base,d on certifying personnel id a given inspection function / activity rather than a general certification of an individual in a discipline. The TUGC0 approach is consistent with the practice of some other members of the i nuclear industry. The more common approach in the nuclear industry I
is to issue general discipline certifications for inspectors. If properly implemented, the TUGCO approach is conservative in that it would require additional training and examinations beyond what is normally required by programs in which general discipline i certifications are issued. However, because of the increased .
- ' number of certifications and attendant certification requirements, I the TUGC0 approach is more difficult to administer than the ;
alternate approach. Both approaches are satisfactory.
, TUGC0 was not initially committed to address the requirements of
- Regulatory Guide 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" and ANSI N45.2.6-1978, " Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants". However, Amendment
- 14 to the FSAR dated January 30, 1981, stated that "CPSES QA Personnel are in compliance with Revision 1 (9/80) of the i '
Regulatory Guide." This commitment was subsequently revised by Amendment #15 to the FSAR dated February 20, 1981, which stated the following:
7"1 g '
For inspection activities within the scope of the ASME i Code, inspectors are qualified in compliance with the j Q( requirements of Regulatory Guide 1.58, Revision 1. '
I j 2. For inspection activities outside the scope of the ASME Code, inspection personnel are qualified in general compliance with the requirement of Regulatory Guide l 1.58 Revision 1 except as follows:
J (A) Some inspection personnel qualifications are documented on a TUGC0 form and not on the Constructor's form.
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Revision: 1 Page 3 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd)
3.0 BACKGROUND
(Cont'd)
(B) Some of the qualification forms are signed by a TUGC0 representative and not by a constructor representative.
(C) Some Level III personnel are not formally designated by their employer. Rather, these persons performing corresponding activities are qualified based on demonstrated experience by the applicant.
- 3. Qualification records are collected, stored and controlled in compliance with ANSI N45.2.9 Draft 11,
, Revision 0, dated January 17, 1973 as included in the 4
' Gray Book'."
Amendment #18 to the FSAR dated April 21, 1981 made the following two changes:
i -
Item C above was deleted to prevent possible confusion based on comments from the NRC Staff.
A second paragraph was added to item 3. above which stated "For operational phase activities, CPSES-TUGC0 Operations will comply with the provisions of Reg. Guide 1.58 Rev. 1, for the qualification of quality control inspection personnel."
TUGC0 subsequently issued CP-QP-2.1, Revision 8, " Training of Inspection Personnel" dated August 4, 1981, in which substantial changes were included which appear related to the requirements of the FSAR commitment to Regulatory Guide 1.58, Revision 1 and ANSI N45.2.6 - 1978.
Tisubstantial number of revisions were made to CP-QP-2.1 between August 4, 1981, and October 30, 1984, when Revision 17 to CP-QP-2.1 was 1.ssued. Revision 17, along with CP-QP-2.3, Revision 5,
" Documentation Within QA/QC Personnel Qualification File," was the revision which was reviewed during the implementation of this ISAP.
The initial specific issue raised by the NRC TRT was the lack of guidelines and procedural requirements for testing and certifying electrical QC inspectors. Subsequent issues presented in
. Supplements 7 and 11 of the Safety Evaluation Report were an crpansion of this initial issue in terms of specific examples.
Attachment A of this Results Report summarizes these issues from Supplements 7 and 11.
I Revision: 1 Page 4 of 40 t
( RESULTS REPORT ISAP I.d.2 (Cont'd)
3.0 BACKGROUND
(Cont'd)
As reflected in this ISAP, a decision was made by the Review Team Leader with concurrence from the Senior Review Team to focus the review of procedures on the TUGC0 QC inspector certification program and to not review the related Brown & Root procedures which cover certification of inspectors under the Brown & Root ASME program. This decision was based on the following:
The NRC concerns were primarily aimed at the TUGCO certification program. In addition, SSER-il stated that the Brown & Root procedures met or exceeded the requirements of ANSI N45.2.6 and Regulatory Guide 1.58.
ASME Code Requirements introduce additional rigor into the Brown & Root certification program as evidenced by periodic l ASME Code Surveys and overview and participation in the
- certification process by the Authorized Nuclear Inspector.
The adequacy of implementation of the current Brown & Root O
certification program is being verified during the '
implementation of ISAP I.d.1, "QC Inspector Qualifications."
ISAP I.d.1 addresses NRC concerns regarding the qualifications of all historical electrical QC inspectors and also requires an assessment of the adequacy of the qualifications of all current i TUGC0 and Brown & Root inspectors in all disciplines. The I.d.1 -
, work is being conducted in three phases. During Phase I, the i
training, qualification and certification files for each applicable inspector are reviewed against project requirements and FSAR commitments by independent third-party personnel (QA/QC Review Team or Special Evaluation Team personnel). If concerns are identified for specific inspectors, they are further evaluated during Phase II by the same independent third-party personnel taking into consideration other appropriate factors including further information provided by TUGCO. Finally, if the qualifications of l
indi'vidual inspectors are still questionable at the completion of
(- the Phase II evaluation, they are placed into Phase III. In Phase' III a reinspection of at least a portion of the individuals' work j will be conducted to finally determine the adequacy of their qualifications.
I 4.0 CPRT ACTION PLAN 4.1 The objective of this action plan was to ensure that the TUGC0 CPSES training and certification program for QC Inspectors complies with ANSI Standard N45.2.6 - 1978 and Regulatory Guide 1.58, Revision 1.
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. Revision: 1
, Pags 5 of 40 RESULTS REPORT l
O'
- ISAP I.d.2 (Cont'd) 4.0 CPRT ACTION' PLAN (Cont'd) 3 The initial specific TRT issue primarily addressed the training and certification program for electrical inspectors.
In light of the generic implicatien for other TUGC0 QC inspector training and certification, this plan addressed the training and certification program for all TUGC0 CPSES inspectors.
4 i
The following tasks were Laple,mented to achieve the above objective:
Reviewed ' procedures, identified deviations from requirements and recommended improvements; i
Evaluated recommendations and revised instructions; and Evaluated adequacy and effectiveness of changes.
I 4.1.1. Procedural Review O A Special Evaluation Team (SET) comprised of individuals with no responsibility for administering the TUGC0 CPSES inspector certification program conducted an independent review of procedures CP-QP-2.1, Revision 17 dated October 30, 1984,
" Training of Inspection Personnel," and CP-QP-2.3, Revision 5 dated October 30, 1984, " Documentation l Within QA/QC Personnel Qualification File." SET made recommendations for improvement to TUCCO and the QA/QC Review Team Leader. The qualifications of SET members are described in paragraph 4.3.
The following items were considered during the SET 7 ;- review of the procedures:
- r, - -
Method of verifying education and work experience;-
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Methods of determining levels of capability; Method of establishing, controlling and updating questions to be used in examinations; l
i Methods of justifying performance for
! racertification;
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, Page 6 of 40 l RESULTS REPORT
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ISAP I.d.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Methods to ensure inspectors being examined do not have prior information on the specific examination questions to be used, i.e. that each examination is a valid measure of the inspector's knowledge of the test subject; Methods on how tests are monitored and for determining test scores; Methods for handling retesting of inspectors who have previously failed examinations; Methods for ensuring inspectors who have been previously tested and certified are ratested or requalified when significant changes are made to inspection procedures; Method of administering training in each O specific discipline; and Methods for determining waivers for OJT.
Recommendations for improvement were forwarded to TUCCO and copies transmitted to the QA/QC Review Team Leader for reconciliation and concurrence.
CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5 were reviewed by the QA/QC Review Team to identify specific deviations from FSAR commitments. This review was conducted to comply with the latest documentation requirements of QA/QC Review Team procedures issued subsequent to the procedure review conducted by f; SET.
27 - ,4.1.2 Evaluate Recommendations and Revise Instructions TUGC0 reviewed the recommendations submitted by SET and the QA/QC Review Team Leader and revised the instructions as necessary. The QA/QC Review Team Leader documented his agreement with the adequacy of the revised instructions.
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Revision: 1
, Page 7 of 40 RESULTS REPORT
' ISAP I.d.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)'
Additionally, the following subtasks were performed:
All inspector certification exams were reviewed and revised by TUGC0 to reflect current requirements. Examinations are now administered using these revised procedures.
A review was penducted to determine wheth'er other improvements should be made to the program to enhance training of inspection i personnel. This review was accomplished in conjunction with the QA/QC Review Team
- evaluation of the effectiveness of the procedure changes.- The results of this review are addressed in Section 5.2.3 of this results report.
j 4.1.3 Evaluate Effectiveness 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 1
CP-QP-21, Revision 18 dated August 19, 1985. The ,
results of this evaluation are addressed in Section 5.2.3 of this Results Report. :
4.1.4 Use of Results 1
a 1 The results of this evaluation will ba factored into
, the overall collective evaluations (Quality of
~'
Construction and QA/QC Program Adequacy) to be conducted during the final stages of the CPRT Program.
- 4i2 ~ Participant's Roles and Respons'bilities 4.2.1 Special Evaluation Team (SET) f 4.2.1.1 Reviewed the procedures for " Training of Inspection Personnel," and the " Documentation 4
Within QA/QC Personnel Qualification File"
- and recommended improvements to TUGC0 and the
! QA/QC Review Team Leader.
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Ravision: 1 Page 8 of 40 RESULTS REPORT
(}
ISAP I.d.2 (Cont'd) '
4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Provided comments to the QA/QC Review Team Leader on the adequacy of revised procedures.
l 4.2.1.3 Personnel l
Mr. J. W. Sutton Third-party Advisor Mr. M. L. Cur, land Third-party Advisor 4.2.2 TUGC0 QA 4.2.2.1 Reviewed SET recommendations and revised instructions.
4.2.2.2 Determined if recommendations apply to daughter instructions.
4.2.2.3 Reviewed and revised all current i
O certification exams to reflect current requirements.
4.2.2.4 Personnel P. E. Halstead Quality Control i Manager, Site A. M. Contino Quality Training
! Supervisor 4.2.3 QA/QC Review Team 4.2.3.1 Reviewed SET recommendations and documented
, ~f - { agreement.
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4.2.3.2 Reviewed procedures for compliance with FSAR commitments and documented agreement with revisions.
, 4.2.3.3 Overviewed TUCCO's consideration of daughter instructions.
. 4.2.3.4 Personnel
() Mr. J. L. Hansel QA/QC Review Team Leader
Revision: 1
, Page 9 of 40 RESULTS REPORT ISAP I.d.2 ;
(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Mr. J. D. Christensen QA/QC Deputy Review Team Leader Mr. J. E. Young Issue Coordinator 4.3 Qualifications of Personnel SET and ERC personnel had as a, minimum, five (5) years of management / supervisory level experience in QA/QC. Each person had experience in some aspect of training, either inspection of training programs or actual experience in the conduct of training and met the qualification requirements specified in l the CPRT Program Plan.
4.4 Procedures
- l l This action plan was conducted in accordance with the CPRT Program Plan. No specific procedures were developed for use i in this ISAP.
l l 4.5 Standards / Acceptance Criteria The Standards used for this review were ANSI N45.2.6-1978 as endorsed by Regulatory Guide 1.58, Revision 1. Acceptance criteria were these specified in these Standards.
- 4.6 Decision Criteria There were three primary decision points in the action plan.
4.6.1 Initial Review Conducted
'f--e" Unless the procedures, CP-QP-2.1 and CP-QP-2.3, clearly met the requirements, recommendations were forwarded to y, TUGC0 for reconciliation.
4.6.2 Review and Reconciliation by TUGC0 '
Recommendations were evaluated and procedures revised as necessary with concurrence from the QA/QC Review Team Leader that FSAR commitments were satisfied.
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Revision: 1
. Page 10 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.6.3 Evaluation of Results Implementation of revised procedures were evaluated during the implementation of this ISAP to determine if the revisions and their implementation were in
, compliance with ANSI N45.2.6 and Regulatory Guide 1.58, Revision 1 and to determine whether other improvements should be made to the p,rogram to enhance training of inspection personnel.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Introduction
- The objective of this action plan was to ensure that TUGC0 had implemented a training and certification program for QC inspectors which was effective and which complied with ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1.
Specifically, the following tasks were accomplished to achieve the objective:
SET and the QA/QC Review Team reviewed procedures which were in effect on October 30, 1984, identified deviations from requirements and recommended improvements to the procedures.
TUGC0 evaluated the SET recommendations and revised the procedures, effective August 19, 1985.
SET and the, QA/QC Review Team evaluated the revised
~'
procedures for adequacy, and the QA/QC Review Team 1
,; verified that they had been satisfactorily implemented.
L: Sections 5.2.1, 5.2.2, and 5.2.3 which follow describe in
, detail the results of the three tasks listed above.
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_---- _ .---. . _.-__ __- __--- -. , ,..- ~- - .- -_ - ..-- ---_.__,---,_~___-__-__-__-.. . .-........-_-- - __ _- -
Ravision: 1
, Pags 11 of 40 RESULTS REPORT i
ISAP I.d.2 (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2 Implementation of Tasks 5.2.1 Procedure Review l The procedures which were initially reviewed by SET and the QA/QC Review Team were CP-QP-2.1, Revision 17 dated October 30, 1984, " Training of_ Inspection Personnel" and CP-QP-2.3, Revision 5 dated October 30,1984,
" Documentation Within Q'A/QC Personnel Qualification File." CP-QP-2.1, Revision 17 addressed the following:
Responsibilities of the TUGC0 QA personnel for implementing the training and certification program; i '
Recommendations for education and experience for inspection personnel; Required capabilities of inspection personnel; Physical requirements for inspection personnel; 4
i -
Requirements for indoctrination and training of inspection personnel; and j -
Requirements for examination and
! certification of personnel.
! CP-QP-2.3 supplemented the requirements of CP-QP-2.1 by l - -- e defining the typical content of an individual inspector's personnel training file and by defining how L-and by whom these training files would be maintained.
A series of TUGC0 QA Instructions (QI-QPs) commonly referred to as " daughter instructions" also supplemented CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5. Attachment B contains the listing of these daughter instructions that were in effect at the time of the review, These instructions defined specific inspection functions and capabilities for inspection personnel. .They also defined specific requirements for documenting training activities and the qualification 5
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Ravision: 1 i , Page 12 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) of these personnel, including on-the-job training, demonstration of proficiency and completion of examination requirements. These " daughter J
instructions" were subsequently deleted and applicable requirements incorporated into the revised CP-QP-2.1.
Further details are contained in Section 5.2.2.
As previously indicated,, two reviews were conducted of CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5. The first review was conducted by SET and resulted in the submittal to TUGC0 of recommendations for improvement of the procedures. These recommendations, which are summarized in Attachment C, were provided to TUGC0 by
" marked up" copies of procedures, listings of comments and discussions with TUGC0 personnel.
Significant changes were made to QA/QC Review Team procedural requirements for documentation after the O initial review conducted by SET. Because of this, a second review was conducted by the QA/QC Review Team for the purpose of documenting-the procedural review in accordance with the latest QA/QC Review Tessi procedural requirements. This review consisted of a detailed evaluation of the adequacy of CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5 in addressing the
- requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1 as committed to by the CPSES FSAR.
This review concluded that the subject procedures did not adequately address the requirements of ANSI N45.2.6 and Regulatory Guide 1.58. It was further concluded ,
that the procedures had violated the requirements of I Criterion V, " Instructions, Procedures, and Drawings" l
, 7-5 -
of 10CFR50, Appendix B. As a result, the following i QA/QC Program Deviation was issued:
? z-l' QA/QC-PDR-35: The procedures violate the requirements of ANSI N45.2.6 and Regulatory Guide 1.58 requirements as follows:
- 1) The procedures did not specifically address the requirements that ,
persons be removed from an activity !
if it is determined th.st their !
O capabilities are not in accordance with the job qualifications.
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. Page 13 of 40 RESULTS REPORT
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ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 2) The procedures did not adequately
, address the requirement that a person who has not performed inspection, examination, or testing activities for a period of one year be i re-evaluated by a redetermination of required capability.
- 3) The ' procedures did not adequately require certification records to contain the information specified by ANSI N45.2.6.
- 4) The procedures did not address the requirement to conduct examinations of special physical characteristics (in this case, color vision tests) on an annual basis. These testing
!O requirements were allowed to be waived but no guidance was provided regarding limitations on waivers.
1
- 5) The procedure did not address the Regulatory Guide requirements which state that Level III personnel j -
should be capable of reviewing and approving inspection, examination i and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test l objectives.
, 6) The procedures did not specify that 7
i ,
a candidate should be a high school graduate or have a GED equivalent of a high school diploma. Also, there was no commitment that the specified education and experience
, recommendations of the standard be j followed nor was an alternate to the
, recommendations provided as is i required by the Regulatory Guide.
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Revision: 1
. Pags- 14 of 40 4
0
- RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
In addition, the procedures violate the requirements of Criterion V of 10CFR50, Appendix B. Criterion V states
" Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for
- determining that important activities have ,
been satisfactorily accomplished."
Specifically,'the procedures omitted i
definitive acceptance criteria for inspector certification and only provided guidance in most important areas of the certification process. The procedures allowed many (if not.
all) procedural requirements to be waived I
without adequate guidance to define, limit or control the use of waivers. As an illustration of this, Attachment D contains verbatim extracts of paragraphs and sentences O from the two procedures which provide only general guidance or allow waiver of requirements.
The end result of the procedural discrepancies described above in the deviation was that compliance with the procedures would not have assured compliance -
- with TUGC0 licensing commitments, nor would necessarily j have resulted in the certification of qualified inspectors. The purpose of CP-QP-2.1, Revision 17 was "to establish the minimum requirements for training, qualification, and certification of personnel performing inspection (s) and to provide assurance that these personnel have, and maintain, the appropriate
. -= knowledge and skill to properly perform their assigned responsibilities,...." Because no base set of minimum
~
l r- -
^ -
requirements was specified, the stated purpose of CP-QP-2.1 was not achieved. The vagueness and general tone of the procedures made it unlikely that any consistent application of standards or guidelines regarding training, examination or certification of inspectors would have occurred during implementation of the procedures.
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Revision: 1
, Page 15 of 40 RESULTS REPORT C(% . .
ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.2 TUGC0 Evaluation of SET Recommendations and Revision of
' Procedures The SET recommendations for improvements were initially provided to TUGC0 in November 1984, and formally discussed with TUGC0 in a meeting during March 1985.
In the same general time frame, TUGC0 was in the process of making pers,onnel changes within the QA organization. Most of the personnel responsible for development and implementation of procedures CP-QP-2.1 and CP-QP'2.3 were changed. The newly-assigned TUGC0 personnel also identified the need for improvements and the procedures were significantly upgraded'and modified.
CP-QP-2.1, Revision 18 was issued on August 19, 1985.
Attachment C describes how the SET recommendations were addressed in this revision. Effective at the issuance C) of Revision 18, the " daughter instructions" were deleted and the appropriate requirements incorporated '
into Revision 18. Specifically, personnel capabilities for the various Level I and Level II inspection functions were extracted from the daughter instructions, revised and included in Attachments to CP-QP-2.1, Revision 18. Also Revision 18 defined the method of certifying Level II inspectors to a discipline series of inspection instructions (providing '
training and examination requirements for each instruction within the series have been satisfied) and defined each discipline series. It also added requirements for technical training outlines, on the job training and proficiency demonstrations which had
'f~- ? previously been primarily covered in the daughter instructions. At the same time,-CP-QP-2.3 was deleted Tb ~ and QI-QP-2.1-23 Revision 0 was issued August 19, 1985, to govern " Training / Certification Records Processing."
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, (Cont'd) l
- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Separate from but closely related to the procedural i upgrades described above, TUGC0 undertook to computerize and upgrade their bank of examination questions used to test candidates for inspector certification. A computer program was developed and existing test questions were input into the system.
This work was completed in March 1985. TUGC0 personnel then spent an additiona,1 two months evaluating, editing, deleting and adding to the bank of test questions. The QA/QC Review Team conducted an evaluation of this updated computerized test question .
- bank and found the questions and the related l l '
application and control measures to be satisfactory.
The work conducted by TUGC0 resulted in a significant
- upgrade both in test question adequacy and the method in which examinations comprised of randomly selected i i
questions could be utilized. These two improvements !
! significantly increased the effectiveness of the 1
inspector testing program.
5.2.3 Adequacy of Revised Procedures and Verification of Implementation SET reviewed CP-QP-2.1, Revision 18 and QI-QP-2.1-23, Revision 0 to determine how their recommendations had been addressed. The results of this review, along with 4
supplementary information subsequently identified by i the QA/QC Review Team, are contained in Attachment C. i In addition, SET also verified that the appropriate l
portions of the " daughter instructions" had been l
- adequately incorporated into CP-QP-2.1.
l i ~ ~ = The QA/QC Review Team. reviewed the revised procedures !
~ '
I to verify compliance with Regulatory Guide 1.58 and l 3 L- ANSI N45.2.6 as committed to by the CPSES FSAR and to
" ~
j determine if the revised procedures adequately resolved l the previously-identified QA/QC Program Deviation.
- This review verified that the deviation hed been
} resolved. The revised procedures were much more l definitive and were judged to be in compliance with l FSAR requirements.
.:n iO t-
-,--,-,.,.,.,,wm,-.-,w ,.m, aw,- _ e-- 4
- R3 vision
- 1
, Pego 17 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) j 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Only one area of possible concern remained as a result ll of this review. Revision 18 of CP-QP-2.1 as well as l subsequent revisions (current is Revision 22) allow specific requirements of the procedure, with the exception of education and experience, to be reduced or l waived. The procedare does clarify the intent of waivers by stating that assurance is to be provided
- that "the individual does have ' comparable' or >
- ' equivalent' competence'to that which m id have been gained from the ites being waived." A discussion was
- held with TUGC0 regarding this possible concern. A i
recommendation was made by the QA/QC Review Team that
! TUCCO consider adding proficiency demonstrations and written examinations as items which cannot be waived for the initial certification of a Level I or Level II j inspector to an inspection instruction. As a result of
- this recommendation, Revision 22 to CP-QP-2.1 was issued in which the section 3.8 on waivers was replaced as follows:
"3.8 SUBSTITUTION OF TRAINING REQUIREMENTS i
Specific training, OJT and written
- j examination requirements as delineated in j paragraphs 3.5.lc, 3.5.1d, and 3.6.1 respectively, may be substituted for existing certified personnel who are candidates for I
Level I and Level II certification in comparable inspection activities. Such substitutions must be approved by the
! Administrative Level III (or General Level III) and documented on Attachment 14 These
.2 substitutions must be fully supported by CPSES site-substituted experience or training
- ,. or examination which provides assurance that 1
the individual does have ' comparable' or
' equivalent' knowledge to that which would have been gained for the iten being i substituted."
i This revision clarified TUCCO's intent and adequately addressed the QA/QC Review Team recommendation.
, R: vision: 1
, Page 18 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
) The QA/QC Review Team conducted a verification of the j implementation of CP-QP-2.1 since the issuance of
! Revision 18. The scope of this verification included the review of documentation for seventeen (17) inspectors and inspector' candidates certified by TUGC0 from August 19, 1985 until April 16, 1986. Although j some minor documentation errors and one concern j regarding alternate color vision tests were identified, i the overall compliance was satisfactory and provided assurance that inspectors are currently being certified in accordance with FSAR commitments. Further discussion with TUGC0 QA personnel resolved the QA/QC Review Team concern regarding alternate color vision l tests.
The practice of utilizing Level I personnel to plan and set up inspections, supervise or maintain surveillance i over inspections, supervise and certify lower level personnel, report inspection results and evaluate the validity and acceptability of inspections had been i identified in a Notice of Violation (EA 86-09) by the l NRC. As noted during the reviews and verification of implementation, use of Level I personnel by TUGC0 to function as Level Il personnel is not permitted by I proce: lure or allowed in practice. TUGC0 is not l currently asking it a practice to conduct inspections
- using Level I personnel, even with appropriate
, supervision of the inspections by Level II personnel as is allowed by Regulatory Guide 1.58, N45.2.6 and TUGC0 l procedures.
l During the implementation verification, the concern l f-e~ "
expressed above regarding waivers was evaluated. Seven
- waivers were identified and all involved reduction of 3
on-the-job training. The waivers all provided adequate justification for reducing on-the-job training, and in
! all cases proficiency to conduct the required l inspection tanks was satisfactorily demonstrated. It i was concluded that the application of the waivers as j
~
allowed by CP-QP-2.1, Revisions 18 through 21, was satisfactory.
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Ravision: 1 i Page -19 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3 Compliance with 10CFR50, Appendix B and the FSAR As discussed in Section 5.2.1, a QA/QC Program Deviation (QA/QC-PDR-35) applicable to CP-QP-2.1, Revision 17 and supplementary procedure CP-QP-2.3, Revision 5 was identified.
It can be concluded that the TUCCO inspector certification program was not in compliance with FSAR commitments nor in compliance with 10CFR50, Appen. dix B requirements from the time of the TUGC0 commitment to Regulatory Guide 1.58 Revision 1 on January 30, 1981, until the issuance of Revision 18 of CP-QP-2.1 on August 19, 1985.
The deviation was evaluated to determine if it should be classified as a QA/QC Program Deficiency. A QA/QC Program Deficiency is defined as a deviation satisfying one or more of the following criteria:
Inadequacy of a QA/QC program element such that O
substantive revision of the program or other corrective action is required to bring it into compliance with the regulatory requirements, FSAR conunitments or other licensing commitments; or Extensive evaluation would be required to determine the
~
effect on the quality of construction.
Based on this definition, QA/QC-PDR-35, which involves both the failure to comply with the requirements of Criterion V of 10CFR50, Appendix B and failure to comply with FSAR coassiements (Regulatory Guide 1.58 and ANSI N45.2.6), has been classified as a QA/QC Program Deficiency. The changes which
,, ,were made to the QC inspector certification program concurrent
- " ;with the issuance of Revision 18 of CP-QP-2.1 are substantive
.in terms of the first criterion of the definition of QA/QC
."2 frogram Deficiencies above. In terms of the second criterion of the definition, the major procedural inadequacies which were in existence prior to Revision 18 of CP-QP-2,1 can be directly linked to the inspector certification problems identified by the NRC. These problems in turn resulted in the establishment of this ISAP, ISAP I.d.1, "QC Inspector Qualifications" and contributed to the decision to establish ISAP VII.c, Construction Reinspection / Documentation Review Plan." Thus, extensive evaluations were required to be conducted to determine the effect of this deviation on the quality of construction.
. - .. - .- - - . _ . _= . - _ - . .
Rsvision: 1 !
, Pags 20 of 40 j
- RESULTS REPORT ISAP I.d.2 l (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4 . Trend Analysis The scope of this action plan was essentially limited to 4
identifying problems with one activity (certification of inspectors), correcting these problems and verifying the i current activity is being conducted satisfactorily. Therefore no trend analysis was required.
l 5.5 Root Cause and Generic Implica'tions j
5.5.1 Root Caush
~
The NRC-TRT, as documented in SSER-11, page 0-111, i found in the TUGC0 QC training and certification j
program "a lack of progransnatic controls to ensure that the program achieves and maintains requirements as set forth in 10CFR50, 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 racertification program; and (4) in the certification testing program. The TRT concludes that these deficiencies in procedural requirements and guidelines in the training and certification programs are of e jor concern." QA/QC-PDR-35, which, as discussed in Section j 5.3 above, is classified as a QA/QC Program Deficiency, confirms the NRC-TRT conclusion quoted above. As a result, a root cause analysis was conducted in accordance with CPRT Program Plan requirements. A description of that analysis follows. It should be 4
kept in mind that the QA/QC Program Deficiency is not applicable to the TUGC0 certification program after 1
~
-: August 19, 1985, when procedures were issued by TUGC0
- which fully complied with FSAR consnitments.
\ .-
l A detailed review of procedural revisions in effect i prior to Revision 17 of CP-QP-2.1 and Revision 5 of l CP-QP-2.3 was not within the scope of this action plan j and was not conducted. However, a limited review of i
these procedures indicated that many of the same discrepancies noted during the review of CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5 existed in earlier revisions. As further support to this
- O
F Rsvision: 1
, Paga 21 of 40 RESULTS REPORT j
~
ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) conclusion, it is the understanding of the QA/QC Review Team (based on discussions with TUGC0 personnel) that (
Revisions 17 and 5 were made in an attempt to address I NRC-TRT cor.cerns which had been verbally presented to TUGC0 during the course of the NRC-TRT evaluations.
The fact that inadequate procedures remained undetected in this area at least since the TUGC0 commitment to ANSI N45.2.6 and Regula, tory Guide 1.58 in 1981, can likely be attributed to weaknesses in the TUGC0 Audit Program and the Management Assessment Program, both of 2
which are being addressed in separate ISAPs.
The direct causes for the procedural weaknesses identified potentially can be attributed to one or more of the following three factors. The first is that the FSAR requirements, including the referenced codes and standards, were unclear. The second potential factor is that there were inadequate requirements for procedure preparation. The last potential factor is personnel failure. The following paragraphs discuss each of these potential factors.
Clarity of FSAR Requirements i The FSAR clearly applies the requirements of ANSI N45.2.6 and Regulatory Guide 1.58 to the
- TUGC0 inspector certif.ication program. It i
also, of course, very clearly applies the Criteria of'10CFR50, Appendix B to the work.
Although the nuclear industry struggled somewhat to address properly the intent of N45.2.6 and Regulatory Guide 1.58 after they f-- '
were issued. (Regulatory Guide 1.58, Revision I was issued in September 1980), by the time T-
~ '
of the TRT evaluation and the issuance of Revision 17 of CP-QP-2.1 in October 1984, i sufficient knowledge and experience had been gained within the nuclear industry to result in broad agreement that the requirements contained within these documents were intended to be applied as written. It is concluded that the clarity of the FSAR requirements was not a major factor in O causing an inadequate procedure to be written.
I
Revision: 1 ,
! , Page 22 of 40 i
RESULTS REPORT ISAP I.d.2 l (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Inadequate Requirements for Procedure Preparation
! A copy of TUGC0 procedure CP-QP-6.0, Revision 6, " Preparation of Quality Procedures and i
Instructions" dated October 25, 1984, was i
examined. This procedure governed the preparation and review of CP-QP-2.1 Revision 17 and CP-QP-2.3 Revision 5. This examination noted that the following requirements or guidelinee were contained in CP-QP-6.0:
(1) Individuals preparing or revising i documents were required to research 1 the FSAR, regulatory requirements, and related industry codes and jl standards to assure adequate incorporation of requirements.
1 (2) Authors were to consult other personnel knowledgeable in the
- document's subject for experienced input to assure that the document
, requirements were practical and
- efficient.
l (3) The procedure indicated authors should normally submit prepared 4
documents to " cognizant
- individual (s)" for review and comment.
.~
(4) Procedures were to be prepared under L the direction of the QE supervisor j and approved by the TUCCO site QA ,
- Manager or designee. '
)
l 3
}
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l
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, Page 23 of 40
()
U RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
It is concluded that CP-QP-6.0, Revision 6 was weak in its requirements for review of procedural revisions. While not considered a primary cause of the problem, the weakness may be a contributing factor. It was noted that the individuals responsible for the preparation and approval of CP-QP-6.0, Revision 6 were the same individuals responsible f'or the preparation and approval of CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5.
Personnel Failure Based on.the previous analysis it appears
, that personnel failure was the likely direct cause for the inadequacies noted in the discrepant procedure. Personnel failure O could be caused by a lack of capability, a lack of experience, an isolated or infrequent error on the part of personnel conducting the work or improper supervision of the persons conducting the work.
Capability of personnel (for this purpose defined as a person's inherent intelligence and ability to carry out reasonable tasks) is difficult to determine in an analysis such as this. However, a review of the resumes of the persons who prepared and approved the procedure provides some information from which some judgements regarding capability
~f - :~
can be made. The resumes for both persons indicated steady performance with reasonable L- - advancement in responsibilities and did not
" ^
reflect a pattern indicative of inability to conduct assigned work. The person who approved the procedure had a B.S. degree in engineering and had been a TUGC0 employee for
, eleven years. Lack of capability is not considered a likely cause for personnel failure in this case.
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Rovicion: 1 Page 24 of 40 h
U RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
A review of the resumes to determine the experience of the individuals who prepared and reviewed the procedures was also conducted. The procedure preparer had a substantial number of years of experience in the nuclear industry but primarily in field engineering organizations. He had less than one year of QA experience (not QC) prior to being assigned to the TUGC0 QA organization.
He had been assigned to the TUGC0 QA organization as a Senior QA Specialist for about one and a half years prior to issuance of the subject procedures and had been certified discipline Level III in the areas of Instrumentation, Mechanical and Receiving.
The individual who approved the procedures had been with the TUGC0 Dallas QA
' organization for about 11 years and had only been recently assigned to the construction cite. Although he had extensive QA experience and was a degreed engineer, he had no direct construction QC experience. His QA experience was limited to the Comanche Peak Project and he had no substantial exposure to other nuclear industry construction QC
- programs. It is concluded that lack of experience of involved individuals likely contributed to the preparation of inadequate procedure revisions.
The scope of the problems identified in the procedure make it difficult to conclude that l' " i this was an isolated error. However, it should be noted that CP-QP-6.0 required that Regulatory Guide 1.58 and ANSI N45.2.6 be researched for procedural revisions to ensure their requirements were addressed. This apparently did not occur or was not properly accomplished. On the other hand, the procedure was being revised and the preparer may have been given specific direction by supervision on what changes were to be made.
In fact TUGC0 memorandum TUQ-2363 dated
()
- September 24, 1984, directs the incorporation
Roviolon: 1
. Pego 25 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) of certain requirements into Revision 17 of CP-QP-2.1. Failure of the procedure preparer to adequately review applicable regulatory requirements and industry codes and standards may have contributed to the problem but this is not considered to be the likely primary cause of the problem.
In regard to improper supervision of the
, ork, CP-QP-6.0 requires revisions of w
procedures to be prepared under the direction of the QE Supervisor. It is difficult to clearly determine what impact supervision may have had on the revision of the subject procedures. It can only be noted that the revisions were not adequate and, as discussed above, specific direction may have been given to the procedure preparer on how the O procedures were to be revised. "On the more positive side, it is clear that an attempt -
was made in the revisions to address the specific problems identified by the NRC-TRT.
However, given the nature of the NRC concerns, it can be argued that a complete review and anclysis of the procedures versus the requirements was in order. This apparently was not conducted or was not properly conducted. It is concluded that improper supervision of the work may have contributed to the probles.
Based on the discussions above it is concluded that the
~f ~ 2~ likely root cause of the deficiency is inexperience on the part of the personnel who had the responsibility L- for the revision and approval of the deficient
~ ~
procedures. Other factors which may have contributed to the probles are as follows:
- 1) CP-QP-6.0, Revision 6 was weak in specifying requirements for review of procedures and procedure revisions. (Note - The fact that this procedure was also prepared and O
Revisien 1
, Pego 26 of 40 i
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RESULTS REPORT ISAP I.d.2 (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) approved by the same individuals who prepared i
and approved the deficient procedures i possibly strengthens the conclusion regarding
- inexperience being the likely root cause.)
- 2) There was an apparent failure to adequately review applicable regulatory and industry j codes and sta,ndards as required by CP-QP-6.0.
i
- 3) There was possible inadequate supervision of the work as required by CP-QP-6.0.
i Although the likely root cause of the procedural
- inadequacies has been identified as inexperienced personnel, the broader question of whether senior management was remiss in assigning inexperienced personnel to this activity requires further
, investigation. This question is beyond the scope of
) this ISAP and will be addressed during the collective evaluation process.
l 5.5.2 Generic Implications l
There are three areas which must be considered in j regard to the generic implications of the identified l QA/QC Deficiency. The first involves the possible certification of unqualified inspectors which in turn could result in serious nonconforming hardware
! conditions remaining undetected. ISAP I.d.1 and ISAP I VII.c are adequate in scope to address this area. The i
reaults of the implementation of ISAP I.d.1 and ISAP VII.c will be reviewed by the QA/QC Review Team during
~
-e the collective evaluation process to verify that the j generic implications of any past program problems have j .-
been fully identified, evaluated, and any required
. corrective actions identified.
l 4
i
!O
- . . - . . , - , . . _ _ . - - . . _ - , , _ . . - . _ . .- _ _ _ ..,_.,,., m..._- - - . _ -._ ._-.- . _ , _ - . ,,-r.,-,__-_mr_,.,,--
Revision: 1 Page 27 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The second area which must be considered is the l potential for other inadequate QA/QC procedures to have i
existed. As part of the collective evaluation process, all of the procedures and procedure revisions prepared i
and/or approved by the persons who prepared and reviewed CP-QP-2.1, Revision 17, CP-QP-2.3, Revision 5
{ and CP-QP-6.0, Revision 6 will be reviewed for i
adequacy. The results of these reviews will be '
evaluated and any additional required action, including further evaluations, will be identified. In addition, the results of other ISAPs which also require the
) review of additional QA/QC procedures and instruction
{ will provide additional data on whether this is a j
legitimate area of concern. Examples of other ISAPs which require these reviews include VII.a.2, "Non-Conformance and Corrective Action System",
VII.a.4, " Audit Program and Auditor Qualification".
VII.a.5, " Periodic Review of QA Progras", VII.a.6,
' O " Exit Interviews", VII.a.7, " Housekeeping and Systea Cleanliness" and VII.a.8, " Fuel Pool Liner Documentation." The resolution of this area will be addressed during the collective evaluation process and additional procedures will be evaluated if the results so dictate.
The third area is the possibility of the continued assignment of inexperienced personnel to make and approve procedural changes in the area of inspector training and certification. As mentioned in Section 5.2.2, most of the personnel responsible for'the development and implementation of the inspector certification program were changed. The new personnel l' ~ 2~ are experienced personnel and the adequacy of their work has been confirmed during the course of the implementation of this ISAP.
No additional actions beyond those already identified by the CPRT are necessary at this time to address the generic implications of the identified QA/QC Program Deficiency. l O
- . . ._. - . . . . . _ . - - . _ _ = _ - _. .. .-- . _ . . . _ .
i .
Revision: 1
. Page 28 of 40 RESULTS REPORT
- ISAP I.d.2 i
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 5.6 Recosamended Corrective Action i
TUGC0 has already corrected the procedural problems identified in this results report and, as indicated in Section 5.2.3 above, has implemented satisfactorily an effective QC
] inspector certification program which meets the requirements of Ragulatory Guide 1.58, Revision 1 and ANSI N45.2.6-1978.
In addition TUCCO has incorporated QA/QC Review Team recommendations for improvement into Revision 22 of CP-QP-2.1.
No further action is required.
6.0 CONCLUSION
S TUGC0 has implemented an effective training and certification program in compliance with FSAR requirements since the issuance of CP-QP-2.1, Revision 18 on August 19, 1985.
The NRC TRT concerns related to the TUCCO certification procedures contained in SSER's 7 and 11 have been satisfactorily addressed as documented in Attachment A. Final conclusions on the overall impact of past inadequacies in the TUGC0 inspector certification program will be addressed in the I.d.1 Results Report and QA/QC Review Team collective evaluation reports.
4 i
i 7.0 ONGOING ACTIVITIES
] The SRT considers the implementition of this ISAP to be complete.
i The final conclusions regarding root cause and generic implications of the QA/QC Program Deficiency identified during implementation of this ISAP will be handled as described in Section 5.5.
- c j 8.0 ACTIO,N TO PRECLUDE OCCURRENCE IN THE FUTURE
! Continued management involvement in regularly evaluating the adequacy of the inspector certification program and promptly correcting any identified discrepancies should avoid further problems in the TUCCO inspector certification program.
i O
.-___,___,........_._.__-.,_________..j_.__. . . _ - _ _ _ _ _ - . _ _ _ _ , _ . _ . . . _ _ _ _ _ . - - - . _ . _ . . _ _ _ .
- . _ - ..-. -__. _ _ . - _ _ - . . - . - - . - _ _ - _ . . . - . _ - =_
Revision: 1
. Page 29 of 40 RESULTS REPORT
- ISAP I.d.2 (Cont'd) i Attachment A TRT/NRC Concerns i
The following is a summary of the concerns reported in SSER's 7 and 11 by the TRT and NRC. They form the basis from which the SET focused attention on the programmatic aspects of the QC inspector qualification / certification process. Corrective actions by TUGCO are also identified.
I (1) No time limit or additional tr'aining requirements existed between a failed test and retest.
CP-QP-2.1, Revision 18. Section 3.6.1 required that any individual who fails a written exam be retrained and that retesting cannot occur less than two (2) days nor more than two (2) weeks following the failed exam. Revision 21 also j required retraining but stated ratesting will begin no sooner than one (1) week following the failed exam. Both revisions state that an individual who fails two (2) written exams is 4
O ineligible for re-test or certification in that specific activity.
4 (2) No controls existed to assure that the same test would not be j given if an individual previously failed that test.
} CP-QP-2.1 Revision 18, Section 3.6.1 required that examination *
- questions be selected randomly from a computerized bank of
- current questions to ensure the same test is not given consecutively.
(3) No consistency existed in test scoring.
Section 3.6.1 of CP-QP-2.1, Revision 18 provided adequate I
7 ~= guidelines to ensure consistency in the scoring of
- ' examinations. Revision 21 provided some additional guidelines j @ ~on how questions which may be disqualified are handled in
- regard to test scoring.
h
! (4) No guidelines or procedures were available to control the disqualification of questions from the test.
- CP-QP-2.1, Revision 18. Section 3.6.1 provided guidelines for l the disqualification of exam questions.
i
Revision: 1
, Page 30 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd)
, Attachment A j
(Cont'd) l (5) No program was available for establishing new tests (except l
i when procedures changed). The same tests had been utilized for the last 2 years.
CP-QF-2,1, Revision 18 required that each time an exam is l given that it be generated by randomly selecting questions from a computerized bank of current questions. Thus new exams are produced each time.
(6) No specific deta'ils on how tests should be monitored.
CP-QF-2.1, Revision 18, Section 3.6.1 established measures to assure the security and confidentiality of exam questions and answers and required proctoring of exams during testing periods.
(7) No procedures for establishing, controlling, and updating questions to be used in examinations. -
Section 3.7.2 of QI-QP-2.1-23 Revision 0 and Section 3.6.1 of CP-QF-2.1, Revision 18 adequately addressed the requirements for establishing, controlling, and updating exam questions.
(8) No procedures to ensure inspectors being examined do not have l
prior information on the specific examination questions to be used, i.e. that each examination is a valid measure of the inspector's knowledge of the test subject.
CP-QF-2.1, Revision 18 required each exam to be developed using randomly selected questions from a computerized bank of questions. Also see answers to items (5) and (6) above.
i (9)"No procedures for determining test scores.
~ 'Section 3.6.1 of CP-QP-2.1, Revision 18 adequately addressed this concern. Additional detail and direction were included in the same section of Revision 21 of CP-QP-2.1.
(10) No procedures for handling ratesting of inspectors who have previously failed examinations.
See response to item (1) above.
S
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, Page 31 of 40 t
RESULTS REPORT
- ISAP I.d.2 (Cont'd) 1 Attachment' A (Cont'd) j (11) No procedures for ensuring inspectors who have been previously tested and certified are retested or requalified when J
] significant changes are made to inspection procedures.
j CP-QP-2.1, Revision 19 adequately addressed this concern in Section 3.5.2 by requiring retraining whenever procedures are l revised. .
(12) There were no requirements for verification of education and work experience.
Section 3.2.4 of CP-QP-2.1, Revision 18 required verification of education and work experience to be completed prior to certification.
1 (13) Personnel capabilities were not specifically defined by levels (I, II, III).'
l
- O Personnel capabilities were defined by Levels in Section 3.3 and Attachments IA through IL in CP-QP-2,1, Revision 18.
2 (14) 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.
- With the issuance of CP-QP-2.1, Revision 18, applicable
- requirements from the separate quality instructions were
! incorporated into CP-QP-2.1 and the instructions deleted. In addition, Section 2.3 of CP-QP-2.1, Revision 18 and Section f - =2.2 of QI-QP-2.1-23 Revision 0 clearly defined j -responsibilities for the training program. The evaluation of -
Tb ' the adequacy of implementation conducted by the QA/QC Review l Team during the course of implementation of this ISAP has confirmed that a cohesive training, examination and certification program is in place.
) (15) Recertification could be accomplished by a simple "yes" from l an inspector's supervisor.
- Section 3.7.2 of CP-QP-2,1, Revision 18 provided adequate j guidance for racertification of inspectors. An annual j performance evaluation is conducted and documented on a form which requires the QC Supervisor to state whether the individual has performed satisfactorily in the applicable i
1'
Ravision: 1
, Pags 32 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd)
Attachment A (Cont'd) inspection area during the last twelve (12) months, whether maintenance of the certification is required, and whether he/she recommends retaining the current level of certification, upgrading the certification, or removing the certification. There is a space for documenting comments and for identifying who performed a field evaluation if required.
Section 3.5.2 of QI-QP-2.1-23, Revision 0 also requires tdat in the event a returned annual performance evaluation indicates that an inspector has been inactive, the applicable Level III shall be contacted for evaluation and determination of recertification requirements prior to further processing.
Revision 21 of CP-QP-2,1 further strengthened this area by the addition of a requirement in Section 3.7.2 that any individual who has not demonstrated activity in the discipline / area certified for a period of one year shall be re-evaluated by a demonstration of proficiency. ,
() (16) There were no guidelines for using waivers for OJT, even though waivers were frequently used.
Section 3.8 of CP-QP-2.1, Revision 18 stated that waivers shall be documented to provide assurance that the individual has " comparable" or " equivalent" competence to that which would have been gained from the item being waived. A form was requit'ed to be completed in which justification for the waiver must be documented. This practice is considered to be satisfactory.
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Revision: 1 Page 33 of 40 RESULTS REPORT ISAP I.d.2 (Cont'd)
Attachment B List Of " Daughter Instructions" The following is the list of " daughter instructions" in effect on October 30, 1984, the date of issuance of CP-QP-2.1, Revision 17:
QI-QP-2.1-1 Qualification of Civil Inspection Personnel, Revision 5, dated July 28, 1983.
QI-QP-2.1-2 Qualification of Soils and Concrete Test Personnel, Revision 3 dated December 17, 1983.
QI-QP-2.1-3 Qualification of Electrical Inspection and Test Personnel, Revision 9 dated September 13, 1984 QI-QP-2.1-4 Qualification of Protective Coating Inspection Personnel, Revision 6 dated July 28, 1983.
O QI-QP-2.1-6 Qualification of Receiving Inspection Personnel, Revision 5 dated July 28, 1983.
QI-QP-2.1-8 Qualification of Instrumentation and Radwaste Mechanical Inspection Personnel, Revision 9 dated September 13, 1984.
QI-QP-2.1-9 Qualification of Non-ASME Pipe Support Inspection Personnel, Revision 5 dated September 13, 1984.
QI-QP-2.1-11 Qualification of Concrete Expansion Anchor Support Inspection Personnel, Revision 3 dated July 29, 1983.
QI-QP-2.1-14 Qualification of Electrical Raceway / Support Inspection Personnel, Revision 6 dated September 18, 1984.
QI-QP-2. 1-15 Qualificnion of Structural Steel Inspection Personnel, Revision 5 dated September 13, 1984.
QI-QP-2.1-18 Qualification of Fire Protection Inspection Personnel, Revision 4 dated September 13, 1984 QI-QP-2.1-19 Qualification of Weld Inspection Personnel, Revision 1 dated July 29, 1983.
QI-QP-2.1-21 Qualification of Baseplates for Grouting Verification g Personnel, Revision 2 dated February 27, 1984.
QI-QP-2,1-22 Training and Certification cf Receiving Inspection Personnel for ASME Section XI Items, Revision 0 dated April 17, 1984.
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Attachment C SET Recommendations The following SET recommendations were provided to TUGC0 QC Supervision initially on November 30, 1984 and formally discussed on March 26, 1985.
In that same time frame, TUGC0 QC made a number of personnel changes.
This resulted in the SET recommendations not always being addressed directly, but rather indirectly as a result of TUGC0 QC self-initiated changes. The TUGC0 improvements are.also indicated along with each initial SET recommendation.
(1) Develop and use a check list of the data / documentation that should be included in each training and certification file.
The checklist can be printed or secured to the inside cover of the file and used to check off the items needed as they are 3 deposited therein. Reason: To help ensure that each file does in fact contain what is required and to maintain consistency.
) QI-QP-2.1-23 addresses this recommendation in Section 3.4.2.
(2) Consider modification of the TUGC0 Procedure (esp CP-QP-2.1) where specified requirements are unnecessarily restrictive and i beyond the guidelines of N45.2.6, e.g. It is not apparent that there is a need for the Ishisara color vision test. A color chart test may be adequate and can be made "Memoryproof"
~
by scrambling the order of the colors displayed. Reason: To
{ be more consistent, to avoid unnecessary requirements and to establish go, no-go criteria.
The Ishisara color vision test remains the primary color vision test. The method of conducting alternate color vision test as prescribed by CP-QP-2.1 Revision 22 is considered to
? the adequately "memoryproof". The current TUGC0 practices in
- u -'this area are satisfactory.
(3) Consider establishing guidelines for qualification and certification as a General Inspector, Reason: The skill, knowledge, experience, etc. should be appropriate for personnel expected to be capable over a broader spectrum of activities. After several specific certifications, documenting the justification for waiving OJT on remaining procedures when giving General Certifications would minimize i
questions on the judgment calls.
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Attachment C (Cont'd)
CP-QP-2.1, Revision 18, Section 3.3.2 addressed this concern by stating Level II inspectors are authorized to perform inspections in a discipline procedural series (a " general inspector" certification in context of the SET recommendation) provided training and certification requirements for each instruction within that series have been satisfied.
(4) Oral and or written examinatio'ns are currently permitted by the IUCCO Procedure. Consider inclusion of a more detailed description for bach method. For Example: Establish a bank of exam questions, (for each subject or. discipline).
Estiblish a means for randomly drawing questions to be used (could be by group).
Section 3.6.1 of CP-QP-2.1 Revision 18 specified that written examination questions are to be selected on a random basis from a computerized bank of questions. Oral examinations are t
no Imager given or addressed by procedure. Revision 18 requires cendidates to take a written examination and demaastrate their proficiency in the field.
(5) Consider using only written examinations.
As stated above, only written examinations are used in conjunction with the proficiency demonstration.
(6) Consider administering open book examinations with time limits. This will promote utilization of procedures. This was a suggestion and not a requirement.
TUGOD currently allows the use of both open or closed book
- = examinations. The criteria for a passing score is ten (10)
' ' ' points higher for an open book examination (90% versus 80%)
( - than for a closed book examination.
(7) Scramble the order of multiple choice answers for individual questions to further protecc the integrity and security of exams.
CP-qP-2.1, Revision 18 required that examinations be randomly selected from a bank of questions to ensure the same test is not given consecutively (different test each time) . Security s
meaarres have been established to limit access to the Os exanination bank. These practices adequately address the original SET recommendation.
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ISAP I.d.2 l (Cont'd) l l
l Attachment C I (Cont'd)
(8) File completed exams separate from certification file for further security and limit access to both exam banks and completed exams.
CP-QP-2.1, Revision 18, paragraph 3.6.1h. adequately addressed
~
this concern. Copies of completed examinations are not maintained in certification files. Only score sheets are currently placed in the certification files.
4 (9) Document results of evaluation of missed exam questions in terms of why the question was failed and what is to be done about it.
CP-QP-2.1, Revision 18, Section 3.o.1 requires individuals who fail.an exam to be retrained and retested. In addition, this section requires questions which have, for example, incorrect technical content or poor sentence structure to be O disqualified and removed from the computer bank. These requirements adequately address the SET concern. Current TUGC0 practice is to document the reason for any disqualification.
(10) Train examiners so as to obtain consistency in administration of exams.
This recommendation applied to oral exams and is no longer applicable because only written exams are now allowed.
(11) Consider acceptance of certification granted elsewhere on the basis of a knowledge and adequacy of the other certification process and its implementation. Include a minimum
, ~ -= probationary period (e.g. 90. days), and examination and
-performance demonstration for proof of capability. This was a 3: , suggestion and not a requirement.
TUGC0 elected not to accept this recommendation. The QA/QC Review Team endorses the TUGC0 position on this recommendation.
i- (12) Provide explanation for apparent inconsistencies between data sources, such as; between resumes and verifications, or why training is given subsequent to waiver of training for certification.
1
(}
Sections 3.4.1 and 3.4.2 of QI-QP-2.1-23 adequately address this SET concern.
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Attachment C (Cont'd)
(13) The term "QC Technician" and the term "QC Inspector" are defined as Level I and II Inspectors in only one place (Para.
3.1.1 & 3.2.1 of CP-QP-2.1). Consider a more specific statement that wherever the term is used it means Level I and II respectivaly. Reason: To avoid misunderstanding when giving credit f)r prior experience as a certified Inspector.
Revision 18 of CP-QP-2.1 clarified these terms throughout the procedure.
(14) Suggest that procedure include actions to be taken when a candidate fails an examination, i.e. waiting period before retaking exam, retraining required, etc.
Section 3.6.1 of CP-QP-2.1, Revision 18 addressed this recommendation. Revision 21 of CP-QP-2.1 stated that retesting cannot begin sooner than one (1) week following the O failed examination. If an individual fails two (2) exams he/she is ineligible for re-test or certification in that activity.
(15) Consider specifying that if the vision acuity test is passed with corrective lenses, the certification form should so state. Specified in CP-QP-2.1 Revision 18 (Draft). This is included on the Visual Acuity Examination Form only.
TUGC0 did not incorporate this recommendation. The Visual Acuity Examination Form indicates whether corrective lenses were used to pass the test. This form is included in the certification file, along with the certification form, and this practice is considered satisfactory.
(16)' Colleges normally require satisfactory completion of High 7- - School (or G.E.D.) . Consider obtaining college attendance and
~ -curriculum verification only when college level work is indicated on resumes.
CP-QP-2.1, Revision 18 requires verification of education sufficient to support certification. If credit is taken for a G.E.D. in supporting the certification, only the G.E.D. is normally verified by TUGCO. If an associate degree or B.S.
dagree is used to support certification, only the applicable O degree is normally verified by TUGCO.m The procedures are adequate to resolve this SET recommendation.
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Attachment C (Cont'd)
(17) Consider specifying that an Armed Services record in not a suitable substitute for verification of High School diploma.
The TUGC0 procedures do not specifically address this recommendation. The TUCCO procedures are considered satisfactory in that they require checks verifying that education is sufficient to support certification. It is not TUGCO's current practice to utilize an Armed Services record as verification of education.
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Attachment D Extracts From CP-QP-2.1, Revision 17 and CP-QP-2.3, Revision 5 Note - Underlined portions were added by reviewer to identify areas of concern.
"The following is the recommended personnel education and experience for each level." (CP-QP-2.1, Section 3.1) ,
"Related experience considerations for initial certification is as ,
follows:" (CP-QP-2.1, Section 3.1)
"Other color vision test may be implemented with approval by the QE Supervisor and documented as appropriate." (CP-QP-2.1 Section 3.3)
" Waivers may be granted on a case-by-case basis by the TUGC0 Site Quality Assurance Manager, per paragraph 3.8." (CP-QP-2.1 Section 3.3)
" Indoctrination requirements shall normally be satisfied within the first 60 days of employment." (CP-QP-2.1 Section 3)
"Waivering of OJT training requirements, may be granted if an inspector has at least 6 months experience as a Level I, and it is determined that the OJT activity being waived if sufficiently similar to other procedures in which he is already certified. OJT can be waived with the approval of the site QA Manager or his designee, per paragraph 3.8."
(CP-QP-2.1, Paragraph 3.4.4)
" Waivers for any examinations must be approved by the Site QA Manager."
(CP-QP-2.1 Section 3.5)
"All subse,quent pages of the test shall be similar to those in
~
Attachmeat[ 9A." (CP-QP-2.1, Paragraph 3.5.4)
"There Tshall be a significant number of test questions to adequately indicate proficiency and knowledge in the inspection activity."
(CP-QP-2.1, Paragraph 3.5.6)
"An inspector designated " Level II" shall be authorized to perform inspections in accordance with all instructions in that procedural series in which he is so designated. Waivers to this shall be considered based on the following:" (CP-QP-2.1 Paragraph 3.5.6)
"When project requirements dictate, an individual may be certified to a limited scope of an inspection activity. The limited scope certification shall be documented on the Inspection Certification Form (Attachment 6) and shall clearly delineate the inspection authority given the inspector." (CP-QP-2.1 Section 3.6)
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ISAP I.d.2 (Cont'd)
Attachment D (Cont'd)
"All waivers pertaining to this procedure shall have approval of the Site QA Manager or his designee. These waivers shall have documentation, per Attachment 11, providing assurance that the basis for the waiver is consistent with the applicable waiver guidelines, properly assessed, reviewed, approved and documented." (CP-QP-2.1 Section 3.8)
"The purpose of this Instruction is to sppplement the technical training requirements of Reference 1-A by:
- a. Defining typical content of a CPSES QA/QC individual's personnel training file;" (CP-QP-2.3 Section 2.0)
" Personnel considered for certification should meet recommended education, training and experience to ensure understanding of the principles and procedures of those areas of inspection in which they are being considered for certification, consistent with Reference 1-A."
(CP-QP-2.3, Paragraph 3.1.1)
C.)s
" Documented evidence of such education, training and experience should be made part of the individuals training file before he/she is certified. " (3.1.1) (CP-QP-2.3, Paragraph 3.1.1)
"Thus, for example, each QC Technician or Inspector will have in a personnel file or certification file at least the following:" (CP-QP-2.1 Section 3.2)
" Form referenced herein and identified as " TYPICAL" may be substituted for by similar forms which serve the same purpose (s) and which may pre-date this Instruction." (CP-QP-2.3, Section 3.5) b p
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