ML20210H511
| ML20210H511 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/03/1987 |
| From: | Bateman R, Rose J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| I-85-373-NPS, I-85-373-NPS-R01, I-85-373-NPS-R1, NUDOCS 8702110437 | |
| Download: ML20210H511 (101) | |
Text
TVA EMPLOYEE CONCERNS REPORT NUMBER:
I-85-373-NPS SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 1 TITLE: Documentation Of Required 0.J.T For N.D.E Personnel Certification
'R5 5Dti~5dR 55 VISION:
Added Corrective Action Plan - Attachment 8
SUMMARY
STATEMENT: Concerns Considered: XX-85-069-001, XX-85-069-001 R1, XX 85-069-007, and XX-85-069-X05.
No falsification of records was substantiated by WP.
However, falsification issue was addressed by the Inspector General Office.
PREPARATION PREPARED ltY:
Original Signed By R. M. Bateman 11-06-86 SIGNATURE DATE REVIEWS PEER:
Original Signed By J. E. Rose 11-06-86 SIGNATURE DATE f S !(
TECHNICAL REVIEW ONLY EUehL OMMbw.
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SIGNATURE DATR
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CONCURRENCES Original signed by CEG-il: J_L.!ewis 11/25/86 SRP:t ss m/s fU N
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- 8,7 SIGN 5T!!RE DATE
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SIGNATUR f [
DATE EPPHOVEDity:
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ECSP HANAudR DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Socrotary's signature denotes SRP concurrences are in files.
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s EMPLOYEE CONCERN f.
SUMMARY
SHEET Report Number:
I-85-373-NPS Report
Title:
Documentation of Required OJT for NDE Personnel Certification
- 1. CONCLRN CONSIDERED:
XX-85-069-OO1, XX-85-069-001, R1 XX-85-069-007 and XX-85-069-X05
Pursonnel for NO.
Employce's OJT records have been falsified.
2.
III. STAILMLNf ON CONCERN / ISSUE VALIDITY Validity:
Y X___,N
, Substantiated: Y X M,N MNo falsification of records was substantiated,
[b IV. EFILCl ON llARDWARE AND/OR PROGRAM Nono V.
JUS 11f1 CATION l-Issue one was substantiated and corrective action is required as l
specified by this report.
RLCOMMENDATION HND/OR CORRECTIVE ACTION NEEDED t
l VI.
Closure of NSRS Recommendations I-85-373-NPS-01, I-85-373-NPS-02, l
I I-85--3 /3-NPS-O3 and I-85-37 3-NPS-04.
VII. REIN'iPICIION NEEDED:
Y
,N X
Page a l
31581 i
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.O Report Number:
I-85-373-NPS
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ItiStlL ClOSURf diosure is based on this report.
IX.
All ACitMENlS 1.
NSRS Report I-85-373-NPS 2.
Text Of Employee Concern (XX-85-069-001) 3.
Foxt Of Employee Concern (XX-85-069-001, RI) 4.
lext Of Employee Concern (XX-85-069-OO7) 5.
Text Of Employee Concern (XX-85-069-X05) 6.
Summary of SQN specific employee concerns reviewed by Welding Project (WP).
7.
Program summarization of WP evaluation 8.
Corrective Action Pldn A.
Approval sheet (XX-85-069-OO1) 8.
Approval sheet (XX-85-069-001, RI)
C.
Approval sheet (XX-85-069-007)
D.
Approval shoot (XX-85-069-X05) 1 Page aa 11 Mi t
t WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS' ATTACHMENT 1 NSRS REPORT I-85-373-NPS I
NOTE: The Weld Task Group prooram endorsed the NSRS Report for employee concerns XX-85-069-00),XX-85-069-001 R1, XX-85-069-007 i
and XX-85-069-X05 only.
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L*NITED STATES GOVERN 3 TENT
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Mc2norand um TENNESSEE VALLEY AUTHORITY TO: !!. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FROM: K. W. Whitt Director of Nuclear Safety Review Staff. E3AB C-K FE B 18.1986 DATE:
SUDJECT: NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSHITTAL Transmitted herein is NSRS R5 port No.
T-85-373-UPS Subject DOCUMENTATION OF REQUIRED OJT FOR UDE PERS0tTNEL CERTIFICATION Concern Nos. c-mma -unwuly -002. -003 (Rev.0). -006
~007
-X13 and IN-86-230-001 and associated prioritized recommendations for your action / disposition.
This report contains one Priority 1 [P1] recommendation which must be addressed before startup.
It is requested that you respond to the attached two Priority 2 [P2] recommendations by April 17 1986 The Priority 3 [P3] recommendation will be looked at for corrective action follow through by June 1 1986. No response is required for this item.
Should you have any questions, please contact. W.
D.
Stevens at telephone 6231-K
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Reco: nend Reportability Determitkation: Yes I
No
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k Director, NSRS/ Designee
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Attachment ec (Attachment):
W.
C. Bibb, SQN W. T. Cottle, WBN l
James P. Darling, BLN R. P. Denise, LP6N40A-C G.
B. Kirk, SQN 6
D. R. Nichols, E10A14 C-K N.
QTC/ERT, Watts Bar Nuclear Plant I
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- r. LP6N48A-C J.
H. Su ivan, SQU l
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NSRS INVESTIGATION REPORT 110. I-85-373-NPS E!!PLOYEE CONCERN: XX-85-069-001
-002
-003 (Rev. 0)
-006
-007
-X13 IN-86-230-001
SUBJECT:
DOCUMENTATION OF REQUIRED OJT FOR NDE PERSO!DIEL CERTIFICATION DATES OF I!NESTIGATICN:
OCTOBER 30, 1985 - DECDIBER 19, 1985 Il STIGATOR:
J C. L. WILSON DATE STIGATOR:
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APPRO'/ED BY:
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BACKCROUND A Nuc1 car Safety Review Staff (NSRS) in'vestigation was conducted to determine the validity of an expressed employee concern received by the Quality Technology Company (QTC)/ Employee Response Team (ERT)~.
The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as II-85-069-001, stated the following:
Sequoyah. Many employees are certified but are not qualified. They do not have enough on the job training (0JT) even though it is documented that they do have enough OJT.
The concern existed from 1980 to present.
Details known to QTC, withheld to maintain confiden-tiality. NUC PR concern. CI (concerned individual) has no further information.
Since the concerns as worded on the following forms indicated that the issues were virtually identical to or encompassed by XX-85-069-001, they included in the same investigation and are also covered by this were report:
IU-86-230-001 Same as 001 except for Watts Bar and without the phrase "The concern existed f rom 1980 to present."
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II-85-069-002 Same as 001 except for Browns Ferry.
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II-85-069-003 (Rev 0)
Same as 001 except for Bellefonte; Rev. 1 is a different concern.
II-85-069-006 Same as 002 except without the phrase "The concern existed from 1980 to present."
IX-85-069-001 Same as 003 (Rev. 0) except without the phrase "The concern exicted from 1980 to present."
IX-85-069-X13 Reads as follows:
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" Chattanooga.
Employee's OJT (on the job training) records have been
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falsified (details to the specific cases are known to QTC and withheld to l
maintain confidentiality). NUC POWER i
concern. C/I has no further l
information."
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1.
In deference to the POTC, it should be recognized that a dif f erentiation can be made, between Work Time Experience, which is what OJT as used in this report is really referring to, and the proper usage of the tem OJT which denotes a dedicated, organized, comprehensive, and documented system'
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of formal training on actual work activity and equipment.
Concern XI-85-069-X13 originally assigned to the ERT for 2.
investigation was factored into this report because of the The ERT similarities in investigating these concerns.
Recommendations l
portion has been attached as attachment C.
to resolve noted deficiencies in this attachment are contained in paragraph IV of this report.
Additional infomation was requested from the ERT follow-up group which further specified the area of concern as being the adequacy and validity of documented OJT qualifications for certification of the nondestructive examination (NDE) inspectors performing inservice inspection tasks.
Initially, the investigation began with the centralized ISI group headquartered in the Chattanooga office complex (COC), but it was extended to include the SQN site QC-group because it also has certified l^
NDE inspectors and does do some inservice inspection work.
Personnel have historically. transferred back and forth between the dedicated ISI i
group and the site QC groups which share the same certification for those NDE disciplines which they have requirements (including OJT)
As used in this report, the term NDE is meant to include y
in common.
4 II.
SCOPE j
The scope of the investigation was determined from the stated A.
concern to be the specific issue of.the (1) adequacy and (2) i validity of documented OJT as coinpared with requirements for certification of NDE inspectors perfoming ISI tasks.
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I The approach employed to investigate this issue consisted of the
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following stept:
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Pertinent r,'aquirements were extracted from the hierarchy of TVA e
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commitment locuments applicable to this issue, beginning with and leading by reference to the applicable I
the Topica$ Report, fegulat6ry* Sui'de, ANSI /ASHEStandard,ASNTRecommendedPractice, l
g VA job descriptions for NDE personnel. TVA Nuclear Quality pssurance Manual, and Nuclear Training Program Procedure.
- 2. eNext, the extent of compliance or noncompliance with require-8 ments and commitments made in or referenced by the preceding commitment documents in the specific area of OJT experience documentation in support of NDE certification was determined via f
the following:
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t, the Since this concern covers the period of 1980 to presen i
ts applicable history of certain TVA commitments /requ remen a.
This effort was assigned by Nuclear was researched.
Licensing branch per annel, i
Interviews were conducted with personnel f rom the var ous groups associated with this issue, including the Power b.
h ISI Operations Training Center, the NCO Mechanical Branc A
Group, Site QA, and the Authorized Inspection Agency.
total of 35 persons were interviewed, including 17 NDE inspectors, 5 trainees 3 POTC instructors, 6 ISI managers,.
Because 1 QC manager, 2 licensing engineers, and the ANII.
of the nature of the information obtained during the interviews, the total number of persons intervi i
persons was terminated, however, when the informat on been stated, obtained was only redundant to what had already his Previous documents identifying and/or dispos i
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were obtained and discussed with applicable personn files Official certification record files, personnel containing unofficial certification copies and OJT d.
i t ined supporting data, and OJT supporting data records ma n a personally by trainees were samplad.
itial Based on preliminary negative findings,from the in lished interviews conducted, a plan of action was also estab e.
to determine the safety-significant impact upon SQN This specifically, should the concern be substantiated.(Details of plan was ultimately executed.results achieved are disc I
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SUMMARY
REQUIREMENTS VS. IMPLEMENTATION III.
Re,quirements and Commitments A.
I 1.
Topical Report
- .1 is actually The current Revis' ion 8 of TVA-TR75-1A, which i
i t under item J Chapter 17 of the Sequoyah FSAR, lists a comm tmenlity Assuran of Table 17D-3, Regulatory Guidance for Qua ii
- 1) of Station Operation, to Regulatory Guide 1.58 (Rev s on a
l Power Plant September 1980 entitled " Qualification of Nuc ear Regulatory Inspection, Examination; and Testing Personnel."
titled Guide 1.58 endorses ANSI /ASME standard N45.2.6 i
Personnel
" Qualification of Inspection, Examination, an l
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who perform inspection, examination, or testing in accordance with ASNT Recommended Practice No. SUT-TC-1A (no specific edition) are themselves to be certified in accordance with the requirements of SNT-TC-LA.
Under the comment section in item J.
TVA has stated the following exceptions and commitments:
' TVA's alternative.to qualifying personnel using the levels of capabilities outlined in Section 3 of N45.2.6 will be to qualify them to internal TVA levels of capability, Qualifications requirements are established and listed in the TVA job descrip-tion for inspection, examination, and testing positions. Only personnel satisfying these requirements are selected to fill these positions.
Any additional training received by personnel will be documented. Appropriate quality assurance groups will provide certificates for documenting this training.
ASNT recommended practice SNT-TC-1A-1980 will be
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used to qualify and certify nondestructive examinathan personnel. Personnel currently certified tr SNT-TC-1A-1975 are not required to recertify to SNT-TC-1A-1980.
f The current job descriptions for SE-3, SE-4, and SE-5 NDE lk, inspectors in the NCO Inservice Inspection Group of the refer to Mechanical Branch, Nuclear Services Division of NUC PR, the experience and formal training specified in SNT-TC-1A (no specific edition). The current job descriptions for SE-4 and SE-5 SQN Quality Control Inspectors require QA certification in a minimum number of " disciplines" (test methods at a'certain skill level); but they do no.t specifically state detailed NDE certification requirements because the range of duties is much i
l broader than NDE alone.
l 2.
Nuclear Oualitv Assurance Manual NQAM Part II, Section 5.3A, " Training and Certification I
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l Program for Quality Control Inspectors," specifically excludes NDE. disciplines, covering instead the five i
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inspection ar'eas of "Hechanical Electrical, Paint (special I
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coatings),' Civil, and Receipt."
i HQAM Part II, Section 6.3, " Nondestructive Examination,"
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paragraph 2.1, states that, "NDE personnel shall be certified in accordance with Program Procedure 0202.14 (formerly DPH No. N75C01), which establishes the NUC PR Program for certification of NDE personnel in accordance with the requirements of SNT-TC-1A."
Paragraph 5.l(a) states that, " Records of TVA NDE personnel certification (are) maintained by the Nuclear Training Branch" (POTC),
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0202.14
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Nuclear Training Program Proced'ure No. 0202.14. " Qualification and Certification Program for Nondestructive Examination Personnel," is a new procedure dated March 6, 1985, replacing DPH N75C01.
Section 4.1.5A, Requirements for Certification, refers to table 1 for the specific experience requirements for certifi-cation in the various NDE methods. Table 1 states specific experience t-ime requirements in fine detail, e.g., days or weeks in many cases.
The second paragraph in Sectica 4.1.5A states that, "A form similar to Exhibit A shall be used to document the candidates education." Exhibit A contains a large section in which to document'NDE experience.
The third paragraph in Section 4.1.5A reads as follows:
Candidates for initial Level I or Level II certifi-cation in a method may acquire minimum experience in the method during employment in NUC PR.
For such candidates, responsible supervision shall summarize this experience on a form similar to Exhibit D and submit this record to the NTB for inclusion in the individual's certification file.
Exhibit D is a very simple onc-line f orm which is included in this report as attachment A.
B.
Findings 1.
History of Requirements / Commitments s
Revision 8 of the Topical Report was approved by the NRC on April 9, 1985, and the Table 17D-3, item J, comment wording in Revision 8 is the same as that of Revision 4 (which was approved e' cept for two changes:
(1) by the NRC on August 18, 1980)
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.specifying the 1980 version (where previously no particular edition was state,d) of SNT-TC-1A, and (2) adding the last sentence.
Both of these and other proposed wording changes to the comment po'etion of item J were transmitted to the tTRC on December 12, 1983, as part of Revision 7.
The other statements included in the Revision 7 submittal were withdrawn after being questioned by the NRC, however, and the wording as it now stands did not get finalized until the Revision 7A submittai to the NRC in May of 1984 Items (1) and (2) were not changed nor were they questioned by the NRC.
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8 The importance of the preceding change record becomes apparent N
when a significant difference in tha 1975 and 1980 editions of SNT-TC-1A is noted. The last sentence of paragraph 6.2.1 in the 1975 version, which states that, " Records substantiating qualification shall be kept on either a monthly or hourly basis," has been deleted from subsequent versions (including 1980). No such specific direction for detailed OJT record-keeping remains in this or any other standard to which TVA is committed. Instead, all the standards tend to emphasize heavily that they are guidelines to employers in establishing their own written practices. Furthenmore, the preceding two sentences were also deleted, which had explained that, "The experience f actor in months is based on a normal 40-hour work week (175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> per month). When work is performed in excess of a 40-hour work week, credit may be based on total hours."
Interviews with Nuclear Licensing Branch personnel and others familiar with the regulatory history of TVA and URC interaction on NDE issues did not recall any discussions, much less verbal commitrants, with regard to OJT experience requirements or documentation thereof.
2.
Prior Identification of Concern Interviews with training center and site personnel revealed that this concern had been identified and documented in similar form in at least three separate instances:
a.
Reference 1 is a memorandum from the Authorized Inspection Agency (AIA) representative at SQN to the POTC NDE supervisor identifying a deviation for an apparent lack of 4
detailed backup data supporting the OJT qualifications of specific individuals.,Referenco 2 is an internal AIA memorandum discussing the question of supporting documentation to substantiate OJT qualification forms (Exhibit D from PP0202.14). The res'ponse' portion of the memorandum refers to a POTC memorandum to the AIA representative (Reference 3) wherein the following points are made:
.s (1) The pers6nnel documentation on file at the POTC (Exhibit' D) for the subject individuals does fulfill the requirements of PP0202.'I4 and SNT-TC-1A, 1980 edition.
l (2) The respective supervisors researched the question and l
"provided written confirmation that the miaimum work time experience has been attained by the subject individuals."
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"A new formal OJT program has been developed that should provide good documentation work time experience and should preclude questions (of this type).
The OJT program is scheduled to be implemented by January 1, 1986."
The response portion of the memorandum also states that the resolution as indicated abova by the TVA POTC is acceptable.
b.
Site QA Staf f Surveillance Section Inplant Survey Checklist No. 21-85-P-009, entitled " Quality Control / Inspections,"
listed an Area of Concern under item III.B.2 as follows:
Exhibit D of Area Plan Procedure 0202.14 is currently being utilized by responsible supervisors to document that the minimum experience requirements have been met for initial certification of NDE candidates.
In some instances there is insufficient documen-tation in the inspection los to verify that the experience and/or training documented on the Exhibit D form was actually received. To alleviate questions or concerns which may be raised in the future by other auditors con-cerning the Exhibit D documentation, some method should be initiated to provide addi-4 T
tional documentation upcn which the Exhibit D i
could be based.
V.
QA site surveillance personnel explained that the above concern arose from entries in the QC Inspection Los not containing any record of trainee participation.
In response to this area of concern, the QC Supervisor at the time decided to ensure that a form was being used individually by
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all trainees to keep documented records of their OJT; the.
form requires the training Level II to initial entries. He also indicated that in the past they usually, but not always, went back to the QC Inspection Los to extract
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trainee records before filling out the Exhibit D although this was "not locked in as e-policy"; and normally they just put down thegainimum experience necessary anyway.
c.
April 1987 ItTPO Evaluation of SQN Q' ality Control Inspector and Hondestructive Page 16, u
Examination Technician Training and Qualification i
Finding TQ.11-1 stated that, "A formal on-the-job training (0JT) program has not been devnloped fcr quality control personnel. Current practice is to document work experience
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"A new formal OJT program has been developed that should provide good documentation work time experience and should preclude questions (of this type). The OJT program is scheduled to be implemented by January 1 1986."
The response portion of the memorandum also states that the resolution as indicated above by the TVA POTC is acceptable, b.
Site QA Staff Surveillance Section Inplant Survey Checklist No. 21-85-P-009, entitled " Quality Control / Inspections,"
listed an Area of Concern under item III.B.2 as follows:
Exhibit D of Area Plan Procedure 0202.14 is currently being utilized by responsible supervisors to document that the minimum experience requirements have been met for initial certification of ND2 candidates.
In some instances there is insufficient documen-tation in the inspection log to verify that the experience and/or training documented on the Exhibit D form was actually received. To alleviate questions or concerns which may be raised in the future by other auditors con-cerning the Exhibit D documentation, some method should be initiated to provide addi-tional documentation upon which the Exhibit D could be based.
QA site surveillance personnel explained that the above concern arose from entries in the QC Inspection Los not containing any record of trainee participation. In response to this area of concern, the QC Supervisor at the time decided to ensure that a form was being used individually by
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all trainees to keep documented records of their OJT; the form requires the training Level II to initial entries. He also indicated that in the past. they usually, but not always, went back to the QC Inspection Log to extract
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trainee records before filling out the Exhibi,t D although this was "not locked in as e-policy"; and normally they just put down the_ minimum experience necess3ry anyway.
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April 1985'INPO Evaluation of SQN P$ge16, Quality'Contro'lInspectorandNondestructive Examination Technician Training and Qualification Finding TQ.ll-1 stated that, "A formal on-the-job training (0JT) program has not been developed for quality control personnel. Current practice is to document work experience 7
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in lieu of training on plant-specific systems. components.
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1 and procedures." INPO made the recommendation that SQN:
Develop and implement a plant-specific OJT program. Actions that should be addressed include the following:
(1) Identification of tasks to be performed, observed, simulated, or discussed; (2) Identification of individuals qualified to conduct OJT; (3) Ide'ntification of skills, knowledge, and required performance standards; (4) Identification of individuals qualified to conduct final checkouts; and (5) Ensuring that individuals have demonstrated competency prior to work assignment without close supervision.
The TVA response (on the same page) notes that, "Sequoyah is currently in the process of developing and implementing a formal plant-specific OJT program for quality control inspection personnel.
Sequoyah will utilize INFO Cood e
Practice TQ-501, where possible, and expects to have the j
OJT program in place and implemented by September 1985."
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3.
Detailed Results of Interviews a.
Adequacy of Documentation
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Interviews with training center personnel included discus-sion of the following documents,which were reviewed in detail:
(1) Reference 4 is a memorandum from D. A. Howard, Hechanical Branch ISI Croup Supervisor, to listed NDE
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supervisors which states that as of the transmittal date of-the memorandum (August 27, 1985), all work time ex'perience for persons seeking eddy current (ET) certification shall be obtained in accordance with tinu new program which requires, among other things, an identified trainer and an identified evaluator in order to validate the OJT.
It concludes by stating that a similar program will be utilized for other NDE methods, as they are developed and approved.
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(2) The new " Quality Control ar.d Nondestructive Examina-tion On-The-Job Training Manual" developed by the Nucleat-Training Branch was reviewed, which was introduced in the forward as being based on the ItfPO document TQ-501, " Development and Implementation of On-The-Job Training."- Part I states the objective of "providing a systematic method for obtaining the required job-related knowledge and skills that satisfy the qualification requirements for QC/NDE inspector certification." A section on NDE Program Practical Requirements Criteria requires that, "The minimum number of practical assignments to be completed for each NDE discipline shall be based on the number of work time experience hours defined in PH0202.14 Qualification and Certification of NDE Personnel."
The Completion of Requirements form for practical experience requires the signatures of the trainee, the designated evaluator, and the OJT program supervisor.
Note: At the time of this writing, ISI had approved an initial portion of-the formalized OJT program, but SQN-QC was still in the process of discussing it with the POTC.
Interviews with NCO, POTC, and SQN personnel generally indicated a high degree of awareness of prior concerns with regard to OJT e::perience documentation in support k
of NDE certification, but at the same time indicated a s
variety of approaches in dealing with the concern.
Some individuals expressed the opinion that since there was no specific requirement for OJT documentation other than Exhibit D, an individual's OJT status is basically whatever that person's supervisor has chosen to document on Exhibit.D until the new formal OJT program takes effect for new certifications. Others have started to keep detailed lists of day-by-day assigned tasks; and for trainees who began in the last six months, these are usually complete with verifying signatures for each entry. Five trainees were asked
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permission to see their personal OJT records (three in ISI and. tan) in SQN-QC), and all five readily produced s
well-mai'tained and detailed records with signatures or n
initinis of the Level II train,cr b,eside each entry.
(Various files were also sampled to determine the extent of OJT supporting documentation they contain.
These results are reported in Section III.B.A.)
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l b.
Validity of Documentation of the 17 NDE inspectors interviewed,15 expressed concerns in varying degrees with regard to the validity of some of the claimed OJT accumulations with which they were f amilla'r, in five cases including their own.
The concerns ranged from questionable or partially insufficient to essentially nonexistent OJT, involving a total of 50 individual NDE certifications. Normally the inspector does not see the Exhibit D which the NnE manager sends to the training center as evidence that that individual is ready for the training in terms of fulfilling the OJT requirements. Two of the 15 concerned inspectors stated that their interpretation of the intent of the Exhibit D was in question, i.e.,
if it only meant that a person had had some experienca in the stated discipline during the stated time period then it was correct, but if it meant to claim that the ' umber of days n
required in 0202.14 was being met then it was not correct.
For five of the specific certifications questioned, other opinions were expressed that the individuals did have the requisite OJT.
One influential NDE manager stated that, "A year (of OJT) just means a calendar year; we have not tried to be terribly exact in all OJT accounting." This statement appears to g-I represent an underlying interpretation which may have been ky
propagated within NDE management as transferred individuals
'would carry on practices and policies learned in their original sections.
Reasons why the interviewed inspectors suspect the validity of the claimed OJT for a given certification include the following:
(1) Personal knowledge of the amount of time a particular individual has spent in a given discipline.
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(2) The total amount of work available in a given
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discipline may be insufficient to provide the required
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amount of training in the claimed time period.
t.1 (3) Certain ' individuals may have perfor.:ed or assisted in a large majority (if not all) of the work in a given discipline and would therefore know how much training certain individuals received.
(4) Some inspectors may display or communicate an unfamiliarity with the work in a given discipline.
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(5) Discussions with fellow inspectors allow the assembly
\\g, or piecing together of. infctmation which corroborates the above.
Of the 17 inspectors interviewed 13 claimed that UDE managers have intentionally filled out incorrect Exhibit Ds for certain individuals. Motivation for this was described by those interviewed to fall into the following categories:
(1) Promotion to higher pay grades is dependent upon the number of certifications held by an individual.
Eight.
inspectors described separately the same specific instance wherein an individual believed to be given favored treatment was assisted in the pursuit of multiple certifications by an invalid Exhibit D, possibly more than one.
Ten inspectors claimed that favoritism was not only widespread (in both QC and ISI) but was also very pronounced.
(2) Work scheduling efficiency has been assumed to be increased by having individual inspectors capable of doing as many different kinds of examinations as possible. This is much more evident in QC than in ISI.
'f' (3) A large workload in a given discipline may be anticipated which could require more inspectors with
(,.
that particular expertise than are currently available.
Interviewed inspectors sometimes noted that even going out on an inspection as a trainee might not mean that very much was learned because the experience might consist of carrying.
equipment or holding it in place without actually participat-ing in (or even observing) the inspection itself.
Incidents j
of trainees not paying attention or even sleeping were
~
mentioned by inspectors who have provided training, generally with complaints along these lines being followed by UDE managers signing OJT documents for the negligent trainees anyway. On the other hand, several inspectors were cited as being dedicated and knowledgeabic trainers in specific disciplines, with extensive experience and pride in their knowledge thought to be the major strengths of those who were good at~ teaching.,,,
Five of the inspectors emphasized that the real learning comes only when a person is doing actual work and is responsible for it rather than being a trainee or even a certified individual who passed the tests and did have valid OJT but'only does work in other areas.' This was explained in the context of confidence in NDE testing being achieved gradually over a period of years, not after any specific g
training milestone, especially in the initial months of experience.
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In many cases an. inspector assigned to keep OJT records for trainees has compiled them for the UDE manager and, in some
\\s cases, has filled out the Exhibit Ds for his signature.
Incidents were mentioned during the interviews where the recordkeeper was observed to fill out the Exhibit Ds without looking at any records. Work coordinators, which hold an intermediate position between the inspectors and the EDE managers, have frequently planned and scheduled training for inspectors, including OJT, and have on occasion signed the Exhibit Ds in place of the manager. As the need for work in certain disciplines would arise, the coordinators would try, to have prospective candidates trained quickly, sometimes sending four or five trainees to accompany one inspector.
This multiple-trainee practice was strcngly criticized during the interviews as-being unworkable. Other incidents reported include doing a number of OJT inspections on a give'n day but dating each cf the reports on a different day so as to take eight hours of credit for each one.
Two of the interviewees mentioned seeing individuals sign their names as trainees to a number of reports for previously completed jobs. Both of these individuals reported that complaints resulted in the practice being terminated.
There are also differences of opinion extant regarding the acceptability of crediting OJT from previous employment towards certification in TVA.
Paragraph 10 TERMINATION, of
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SUI-TC-1A states that, "A Level I, Level II, or Level III whose certification has been terminated may be recertified to his former NDT level by a new employer based on examination as described in Par. 8 provided all of the following conditions are met to the new employer's satisfac-tion:
(1) The employen has proof of prior certification.
(2) The employee was working in the capacity to which he certified within six months of termination.
(3) The employee is being recertified within six months of his termination." The intent of these words is that OJT is transferable under controlled conditions even though certification itself is not. This is also current TVA policy as practiced by tKe POTC and the NDE group managers.
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and the SQN ANII is in full agreement with it-provided that the trail is. documented and auditable. However, it is not 6
known by all'the UDE inspectors and may be partially responsibre for the appearance of circumventing OJT timo requirements for certain new employees. Of 35 inspectors holding certifications questioned during the interviews, at least 12 (and probably many more) did have extensive FDE work experience prior to TVA DUC PR.
Experience from TVA Construction and TVA Fossil & Hydro is treated exactly like that from other employers; i.e., OJT is transferable but certification is not.
12
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Concerns were expressed, however, about the wisdom of allowing OJT to be transferred across organizational boundaries when the actual work may be very different. For example, the UT equipment used at CE may be identical to that being used in TVA NUC PR but what is being ' looked for may be entirely different. Conversely, any given examina-tion task may turn out to be unique in some respect no matter how experienced the inspector. Some inspectors and the ANII felt that noncode work such as turbine NT should not be counted as nuclear OJT, but some certifications have been based partly or largely this way.
In the past th'e training center has been aware of some individuals being sent to them for NDE courses without sufficient OJT, and the instructors have discussed this matter with the NDE supervisors who have s,igned the Exhibit Ds believed to not be factual. Trainees have on occasion been sent back-without taking the course, and in other cases they have been allowed to complete the course but with certification held in abeyance pending completion of satisfactory OJT.
Complaints by the training center to NDE managers regarding improper preparation of trainees have not always been well received, generally because they have been regarded as crossing jurisdictional boundaries. When the training center has questioned how trainees could
(
receive experience in NDE test methods which are rarely used, the NDE groups have replied that informal (not job required) work in those areas has been conducted for training purposes. The work records (inspection logs) do appear to substantiate this to a limited extent.
J In general, inspectors were complimentary regarding the training they received at the POTC, especially when compared i
with the training they received during previous employment, including that from contractors,doing past and present work for TVA.
The NDE instruction is regarded as being rigorous and difficult to pass, so much so that failure to pass initial and even recertification examinations is very
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Inspectors holding 'ertifications for years in
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c common.
other companies and even within TVA tut outside of NUC PR have had difEfeulty in becoming NUC PR certified.
6 Initially in this investigation, ten of the inspectocs stated that they feared repercussions, in the form of
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various adverse job actions, from openly discussing their concerns. Because of this many of them insisted on complete anonymity, including off-site interviews in a few cases.
Also, during the course of the investigation, a few reports of questioning interviewed individuals or expressed dismay by managers were received, sometimes with a request to N;
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e dilute the attention directed at those interviewed at some P
length by talking to others. Where possible or practical this was done.
Other individuals expressed no concern or k
fear from stating their opinions either openly or in private.
As time went on and more people became involved in the employee concern investigations the situation did appear to improve such that some of the same individuals who initially expressed fears felt free to openly discuss their conce rns.
4.
Detailed Results of Records Search Files at SQN, POTC, COC NUC PR Personnel (for QC), and COC ISI were examined for.35 inspectors, including both individuals whose certifications were and were not questioned during the interviews. The official and auditable NDE certification files are those held by the POTC, and they were much more complete than the personnel files. This is to be expected because the other files were never intended to ba complete, auditable records of TVA OJT.
Only 4 of 32 POTC files examined happened to contain backup details in some form for the' Exhibit Ds, but it is not a require-ment that this information has to be compiled, much less sent to the POTC or reposited by them.
In contrast, 10 out of 14 COC ISI files examined contained some backup OJT information, generally for more recently hired individuals. Of the 50 questioned certifications, partial backup documentation could be
\\
found for 6; of these, 2 were Level II, but the quantity of OJT appeared to be aimed at partially supporting a Level I.
None of the SQN or COC NUC PR personnel files examined appeared to contain OJT information.
In the absence of clear records aimed at substantiating certification OJT, it was difficult to trace directly to other records such as timesheets, inspection logs, NDE reports, etc.,
with the object of either confirming or refuting the claimed experience. This is true for a number of reasons, including:
~
ISI inspectors constantly travel between all,the plants, and a.
records are generally separated by plant and unit.
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b.
Often someone' will have participated in inspections, even a l
~
1arge number, with only the name of the lead inspector being l
i recorded on any paperwork.
Historically, personnel have freely transferred back and c.
forth among the various NDE groups in TVA OC, Fossil &
Hydro, NUC PR ISI, and NUC PR QC at various plants and even other companies making it extremely difficult to find where they were during a given time period, let alone what they did, because of the separate personnel files and differences in what is recorded.
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5.
Technical Impact on the Plant A total of 50 individual certifications were identified as being s
questionable by the interviewees but very few instances of actual work being performed by inspectors with questioned certifications were described. Attachment B lists seven peripheral issues or additional concerns which were encountered during the interviews, including five instances of actual work, and it also gives a brief evaluation of the potential technical impact of each item.
Even though very few specific instances of actual work being placed in question were mentioned, the assumption was made that initial work perfortiee af ter the questioned certifications were received was itself in question and therefore should be reinspected on a sampling basis to find any work areas that might be faulty. The sampling plan was constructed as follows:
a.
For each of the 50 individual certifications questioned, the date of the original certification at that level was obtain-ed from POTC records. Ten were actually never certified; i.e., what was being questioned was the OJT qualification for the training courses which were not passed; therefore, no work was done by those individuals under those certifi-cations. Six of the questioned certifications were Level I's which are not responsible for and do not sign for work;
(
,of these, four were for ET which is usually contractor work.
b.
Thirty-four questioned NDE cortifications remained under which work may have been performed. The particular groups the individuals holding the questioned certifications were in and the locations they were at after they received the certifications were obtained via:
(1) examination of the QC Inspection Log and PSI /ISI report records at SQN, and (2) discussions with various NDE managers and inspectors (including in some cases the subject inspectors themselves). Generally, it was clear where a given individual was doing work after the certification was received, but wherever there was any doubt the records for (1) QC-SQN (Inspection Log), (2) PSI-SQN (Basel'ine Inspec-tion Reports fn the QA Records Vault at SQN), and (3)
ISI-All Plants (SCANPLAN computer data base) were all searched. 'What has not been done is to go through these records at the other plants, except for the ISI computer data base which includen files from June 1982 forward and has been searched for all slants already. This remaining work will have to be included in the scope of work for a follow-up investigation by NUC PR.
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?f From he present effort it was found that four of the certi ications in question were obtained after the
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individuals had gone to other plants, and these must be researched at those facilities as part of the follow-up NUC PR investigation.
The remaining 30 certifications ' wore divided predominantly c.
into QC and ISI with a few exceptions that included time spent in both groups during the period following receipt of the certification. For those that were in QC-SQN, the QC Inspection Log was searched manually for work a given individual had done in the given !!DE discipline in question for a period of time after the certification was first received. For those that were PSI-SQN (Baseline Inspec-tion), the PSI reports were also manually searched similar to the QC Inspection Los although this is complicated by the fact that the PSI reports are only roughly (instead of exactly) chronological. The ones that were in the SQN ISI timeframe (fall 1982 to present) were easier because they could be computer searched. For the few exceptions wherein individuals had transferred shortly after receiving a certification and therefore had worked in more than one group, records were searched at each end of the move although no instances of questioned work in both work groups
.were found.
The time periods chosen for search were:
(1) 30 days after
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the certifications were received for those cases where a N
single interviewee had questioned it, and (2) 90 days whe're two or more interviewees had questioned it.
The month immediately following certification was chosen in recogni-tion of the fact that it is the most vulnerabic period; i.e., as actual experience,is gained the individual becomes more competent, and any instances of the individual taking
~
independent responsibility for~ work prior to "posteertifica-tion OJT" would be caught (unless there was little work in the specific discipline anyway; n. ore on this later). A 9'0-day period was chosen to, provide a proportionately greate'r degree of assurance that common-knowledge cases are screened for postcertification questionable work itself (not
. just OJT sufEiciency) being the origin of the doubt.
s Of the 30 Temaining certifications,16 were QC and 14 were ISI (about evenly split). Ten of these (five in QC and five in ISI) were questioned by more than one individual and thus were searched for 90 days. The other 20 were not discarded even though only a single individual had mentioned them because they serve the purpose of being a more general sample of the NDE examiners across the board with a slight (one sourec) bias towards being more likely to be question-abic.
In fact, at least 6 of the 20 did appear to have
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conflicting data or conflicting opinions, but they were left in the process both for conservatism and to broaden the sample base beyond the more questionable cases.
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i-f rch turned up zero l-plants SCA!TPLAll computer sea stion for 12 ISI inspections during the periods in queOf the remaining two have three The al d.
certifications.
d to have done hts recorded at BLl! during the seacomputer records but wa "pn" predated thefour UTs as the responsible party at S These fou line.
period as part of the Unit 2 Baserecorded on the the responsible tion.
of the 16 QC certifications, zero work asInspection Los during party was found recorded in theFor the remaining six:
periods in question for 10.
onsible Level II but One job was found done as the respNote that QC performs both
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d work with no l
turned out to be non-CSSC. safety-related and n (1) f
- distinction made in the log.
t One job was not done (craft no(which cann j
Four jobs were f ound:
two jobs were socket weld fit-upsd critical for this (2) be reinspected but are not consideret difficult to inspect ready);
likely to fail investigation because they are noin der operating during welding or initial testing un conditions); and the fourth job re welds.
issing for this f(( :.
The QC Inspection Los records are m (3) period in question.
d by both the
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d another Level II, but One PT was listed as being performe certified person in question ank Plan records showed that (4) d as the responsible examination of the actual Wor the unquestioned individual signeidual listed as a(This tur party with the questioned indivtrainee ev l II.
out to be a common occurrence antwo involve
( n CSSC)
Five VT3 jobs were fouEd: accepted; one involved (5)
- one work, and'it was rejected anywayfit-up w d one item was with none tion.
recorded on the test for reinspec s
the time in i
Five PT inspections were found dur ngOne.wa work was 1
(6) question: rejected as incomplete; one was done with tw done senior Level II; and another wast the individual in more senior level IIs, such tha ible inspector; and
- question did not sign as the responsthe period exam the last two inspections during were recorded for reinspection.
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j Llowing observations were made during the work records e.
The f o search'es:
Very little work was done as the responsible party by (1) the questioned individuals during the periods examined following certification. Generally, a large amount of work in other areas could be found, and a lesser but still large number of cases were observed wherein work was done with another inspector of equal certification but greater senineity in that particular discipline.
In 100 percent of the cases examined with more than one certified person involved, the (newly certified) individual in question did not sign as the responsible inspector.
, Subsequent discussions with managers and inspectors (2) previously interviewed yielded the unanimous opinion that it was common practice to have a newly certified individual be accompanied by a more senior inspector the individual felt confident in perfoaming until:
(1) solo examinations, and (2) that individual's supervi-sors shared that confidence. It was emphasized that accumulation of confidence is a gradual and continuous process which does not have any well-defined thresholds and is therefore not readily amenable to quantified As a comparison, OJT requirements and requirements.
NDE instruction are considered to be reasonable minimum I
h acceptance criteria, with postcertification " training"
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regarded as an upgrading.
Of the seven NDE tasks to be reinspected at Sequoyah, four f.
were UTs, two were pts, and one was a VT3 (ASHE Section III The ISI group was asked B&PV Code Visual Weld Inspection).
to do the first six, and'QC was requested to perform the visual weld exam because ISI inspectors generally only need
~
to be certified in visual weld bxams to Section XI of the ASME B&PV Code.
The two pts, both 3/4" socket welds on a uni ( 1 705' azimuth, X-44 penetration line>(weld map 0
elevation, 281 No. 1-CVC-52231W, welds 3199C and 3199A) passed reinspection 6
on December 21, 1985.
The VT3, on a unit 1 4" HPFP hanger at elevation 704 of the auxiliary building, A3&T lines (Equipment ID No.
1-HGR-26491-8-20) was reinspected on December 20, 1985 after No the paint was removed from the baseplate by maintenance.
problems were observed except for a very obvious baseplate are strike which could be seen from a distance; because it was'so evident it is probable that it was not present at the time of the original inspection. SQN QC agreed to submit an MR to have mechanical maintenance remove the are strike and repaint the baseplate.
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The f ur UTs, on welds F-108, -109, -188, and -190 in unit 2 conta nment in a 6" Ri!R line on both sides of the 63-644 valve and near the intersee' tion with the Loop 3 hot leg, passed reinspection on January 4, 1986. Delays had been encountered in getting the insulation removed and the weld's prepped (weld crowns ground flat.to meet new procedure requirements); 500 mR/ hour fields were encountered in some spots. Reference SI-114.2, drawing ISI-0003-C.
All reinspections were performed by different personnel than those who did the original inspections, and none of the reinspection certifications were in question.
IV.
CONCLUSIONS A.
Adequacy of' Documentation The written commitments made by TVA, with regard to the extent of OJT documentation in support of fulfilling certification require-ments for NDE inspectors do not constitute a "hard" (i.e., explicit) requirement for maintaining detailed supporting records or backup data. Also, TVA did document general exceptions to qualification methodology endorsed by the NRC.
However, it could be argued that since the 1975 version of SNT-TC-1A had the implied endorsement of the tTRC early on and since no explicit exception was ever taken to the detailed OJT record wording, a " soft"-(implied) requirement did
'(,
exist until the commitment was made to the 1980 version.
It could
\\
also be argued that the detailed OJT time requirements listed in PP0202.14 reasonably imply the need to record DJT experience data in at least detail comparable to the requirement.
1 As explained earlier, the need for improvement in this area has been well recognized and is being addressed by a program which will entall detailed OJT recordkeeping, suff,1cient to satisfy the requirements of 0202.14 and SNT-TC-1A.
In the interim, and for about the last four months, trainees are keeping detailed OJT records.
D.
Validity of Documentation it 1.
NDE management in' TVA early on took a very loose interpretation of OJT requirebents, and many of the individuals who trained under that policy and were subsequently promoted have continued and extended that practice.
This has apparently resulted in the production of a number of Exhibit Ds which are not correct and therefore both the documents themselves and any personnel actions taken on the basis of those documents must be redressed. Only a limited attempt has been made to accomplish m
19 j
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i this as pa t of this investigation because of the resources it would req tre; rather, efforts were primarily directed at assessing the technical impact on the plant.
A follow-up investigation by NUC PR will be required to remedy the findings documented herein.
Nonetheless, some observations are appropriate now in that they convey views expressed strongly and consistently during the interviews:
Inspection personnel in both QC and ISI have been placed in a.
a difficult position by a policy which has been originated and promulgated by individuals who are now more than two levels of supervision above them. Therefore they did not see much use in contesting it with their immediate supervisors / coordinators.
b.
All werk sections in any organization have some degree of dissatisfaction, promotion envy, personalit,y conflicts, etc., but for some unapparent reason the NDE groups, both QC and ISI, seem to have an inordinate amount. This observa-tion is shared by other investigators who have interfaced with a number of NDE individuals.
One manifestation of this situation is the high proportion of interviewed inspectors who expressed the conviction that voicing concerns invites adverse job actions, Hard copy proof of incorrect Exhibit Ds is exceedingly c.
difficult to obtain for reasons mentioned earlier. Because of this, concluding that they are incorrect is partly circumstantial (very little work in a given discipline at a given time and location) and partly corroborative (seven peers questioning a given certification, for example).
Additional information conveyed during the interviews is difficult to explain, however, such as individuals being sent back by the training center for insufficient OJT even though the Exhibit Ds purported otherwise; or other cases where individuals questioned their own OJT.
Therefore, the concern as stated is basically dubtstantiated even with only a very limited amount of hard copy proof, although more may be required for any redressment a'ction resulting from the follow-up investigation.
"~
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It is crucial'to understand that there is a direct connection between the personnel practices of the NDE groups and the safety of the plant. This is because the inspectors can only do their critical jobs well when they see that strict completion of technical training requirements, independence, and rigorous adherence to procedures are cultivated and rewarded rather than compromised.
20
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For a numb r of reasons explained earlier, individuals with 2.
questiona le certifications tended to not do work in those In some cases they were obtained for promotions, but the areas.
same minimal amount of work in that area that made it difficult to get OJT also meant that the likelihood of doing work in that.
On the other hand, if there was area was proportionately low.
sufficient work in a given discipline, it correspondingly meant that individuals were well practiced in that area who could provide on-the-job training or take responsibility for joint inspections until enough postcartification experience was This conclusion is based in part on the fact that a,
received.
very large data base of inspections yielded very few records of work being performed in the time periods inanediately following questioned certification.
Based on the,high failure rates and the comparisons those intervie'wed chose to make with other training they received, the 3.
NDE instruction at the POTC appears to successfully force its Therefore, since no inspec-requisite standards to be upheld.
tions were performed by individuals who did not pass, even individuals with less than s' comfortable OJT experience foundation possess certain basic knowledge necessary to perform i
the work.
The interviews yielded very few specific instances of actual These items are being addressed both 4.
work being questioned.
herein and as separate concerns.
4 The interviews were concluded when the information being i
received became repetitive, although there is no guarantee that 5.
all potentially questionable certifications were uncovered.
No adverse impact on safety-related equipment or components was determined by this preliminary investigation; however, suffi-6.
cient certification discrepancies'were noted to mandate an
~
extended evaluation by UUC PR of the TVA NDE certification program and resultant inspection activities.
.A
- V.
RECOMMENDATIONS a.
I-85-373-NPS-01, Adeo'uacy of NDE OJT Documentation A.
{
Ensure that whatever modifications to the new QC and NDE On-The-Job Training Manual are made, if any, do not result in 1.
diluting the commitment to detailed verification of required OJT.
l Until the new QC and NDE On-The-Job Training program is implemented, the POTC should not certify inspectors (stop work) 2.
without* receipt of detailed OJT verification in the form of inspection listings, including item-by-item initialing by the f
training inspector.
21
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4 This reco g endation was previously communicated by USRS on January 14), 1986, to the POTC via the Sequoyah Site Director and the NUC PR QA manager. This will require a change to 0202.14.
(P2)
B.
I-85-373-UPS-02, Validity of NDE OJT Documentation NUC PR must undertake a follow-up investigation to better define, in detail sufficient to remedy, the findings documented herein, including:
1.
correction of incorrect qualification documents and premature certifications.
~
2.
redressment of inappropriate personnal actions such as premature promotions and/or I&H and 3.
extension of the records search for work initially performed under questionable certifications at plants other than Sequoyah.
This, follow-up investigation should begin with Sequoyah Nuclear Plant. USRS considers this a startup issue for Sequoyah.
(Pl]
C.
I-85-373-NPS-03, Resolution of Employee Response Barriers 1.
NUC PR manageraent should consider cross training as a means of
[
rotating management which has become inbred in certain areas
(( -
such as QC/ISI.
2.
The employee concerns program has to be staffed with individuals who have had minimal personal connection or prior work association with their counterpart line managers. Otherwise, employees will lack confidence in the program and will take their concerns elsewhere.
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Criteria for promotions should be divorced from the present t
l 3.
requirements for a large number of certifications. Recognized ability as a good OJT instructor is one good substitute which might recognize real value to the group more equitably.
(P3]
'J.
D.
I-85-373-NPS-04, POTC Resolution of Identified Ouality Assurance Deficiencies POTC should evaluate and correct the following quality assurance discrepancies identified in its NDE certification program (see Attachment C, Details and Conclusions);
i 1.
Issue the " Quality Control and Nondestructive Examination On-The-Job Training Manual" after the noted discrepancies identified on page 4 of attachment C have been resolved.
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2.
Delete th use of.or revise the Exhibit D forms to more clearly define in ormation required to be put on the form.
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3.
Institute Document Control on NDE certification records.
4.
Perform an, evaluation of the documentation adequacy of certifica-tion forms. Use the input from recommendation I-85-373-NPS-02.
Correct deficient documentation.
5.
Withdraw certifications where eye examinations have not been taken.
[P2]
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de DOCUMEt S REVIEWED IN ItNESTIGATION I-85-373-NPS AND REFERENCES
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1.
Hemorandum from E. L. Farrow, Jr., ANII, to H. McCrary, POTC ITDE Supervisor, " SIS Record for Monitoring QA/QC Programs No. 15," dated June 26, 1985 2.
Internal Hartford Steam Boiler Office Memorandum on the stated subject of "SNT-TC-1A OJT" from E. L. Farrow, ANII, to C. A.-Ireland, ANIIS 3.
Memorandum from H. E. McCrary, QC/NDE Section Supervisor (of POTC), to E. Farrow, ANII, " Certification Records for Magnetic Particle (MT)
Examiner Identification, SIS Record Number 15," dated August 27, 1985 s
4.
Memorandum from D.>A. Howard, ISI Group Supervisor, to Those listed,
" Development of Edd; Current (ET) Level II Personnel," dated l
l August 27, 1985 1
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3g youu 1CAIlON /(
CTATITICATION PAGE Ad DATE f1 Alt U o E 85 t.
PROGRAM FOR NONa,<.STRUCTIVE.-
T.IAMINATION PERSONNEI, PROCEDURE (TormerlyDPMNo.Nf5C01)
No.
0202.14 DOIIBIT D.
Date:
TO:
Nuclear Training Branch, NDE Training Unit, POTC During the period from to has received -
months of NDE' experience, at least 257,'of whict was in the
. method.
Signed:
Name l
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t Title s
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e Attachment B List of Peripheral Issues, Additional Concerns, Etc., Which Came Out of the Interviews f or XI-85-069-001, Including Specific Work Questioned 1.
Two individuals were said to have openly stated that they didn't have the experience to perform as they should in UT, but it was also said that they may not have done UT work after they were certified.
Di$ position: A SCANPLAN computer search for all plants for 30 days af ter the individuals received initial Level II certification verified that they did no work in UT for that time period.
2.
One inspector was quoted as saying, "I didn't know what I was doing on visual weld inspection."
Disposition: This salf-questioned certification was included in the sample plan; results are stated in Section III.B.S.
3.
One individual was said to have inspected the unit i reactor vessel head bolts without being qualified (unit 1 Baseline or PSI, during 7-11-78 through 1-7-80).
Disposition: The surveillance instruction (SI 114.1, pg. 2 of 12 and Appendix A Table A) requires that;at least 18 of the 54 reactor vessel closure head bolt gssemblies have to be ISI'd (UT, MT, and VT on the washers) every inspection period l
(3-1/3 years). Eighteen of the 54 were inspected by South-(
west Research during the UIC2 outage and 18 others were inspected by TVA ISI during the UIC3 outage. The inspec-tions are done by serial number, not by position, and are done when the bolts have.been placed in racks, so there has been effectively a random locational reinspection of 2/3 of
' the bolt assemblies without rejection since U1 PSI.
4 Two other individuals were also said to have openly stated that they did not foul' confident doing UT due to insufficient training and experience, but it was also said that this was at BFN and the work was redone at the request of NRC.
A
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l
' Disposition: A search of the QC inspection los and P,SI records for SQU l
l verified that no work in UT was done as the responsible Level II for 30 days following initial certification of the two individuals in question.
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s' 5.
One inspector was s id to have openly stated that he didn't know what he was doing on MT, bu it was also said that he requested and received help i
from another certified individual who was more experienced and more comfortable.
i Disposition:
This questioned certification was included in the sample plan; it was verified that the individual holding the questioned certification did not do any MT work as the responsible Level II for 90 days following initial certification.
6.
Two inspectors expressed the concern that various individuals had performed D-meter (a dimentional thickness or depth measuring UT device)
I surveys on SQN steam generator feedwater piping in the vicinity of the gamma plugs without being qualified.
i Disposition:
Various knowledgeable individuals at \\?N explained that, 4
although this piping does receive periodic ISI, the D-meter work is not part of the ISI but is primarily done to detect i
wastage (e.g., erosion, corrosion, or other line thinning) 4
~
as general maintenance information.
7.
In addition to the NDE certifications, seven non-NDE (electrical and mechanical) certifications were also questioned by some of the l
interviewees.
I Disposition:
QC managers at SQN explained that electrical and mechanical k[ * '
inspections are more preventive in nature when contrasted with NDE which looks directly at the likelihood of failure.
l For example, electrical and mechanical inspection defects are likely to be caught during postmaintenance or post-modification testing, such as an incorrect crimp or leaking seal. Another way to compare electrical and mechanical inspections with NDE'is that whereas NDE usually involves very specializ'ed training and equipment which the crafts do l
not have, electrical and mechanical inspections are generally a verification of what should already be known to the crafts doing the work. Electrical and mechanical OJT requirements are not mandaEed by any group nr standard external to TVA, but are instead controlled st'rictly.
internally add are also administered very differently than NDE certification. For these various reasons, the electrical and mechanical certifications were not considered.to be within the scope of this investigation, nor were they considered to be as critical as NDE inspections relative to plant safety.
f i
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Attacnmant C
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CONCERN NO:
XX-85-069-OO1, XX-85-069-002, XX-85-G69-OQ3 (Rev. c),
XX-85-G69-006, XX-85-069-OO7, XX-85-069-X13.
IN-86-230-001 This invest igat ion of Nondestruct ive Exaraination (NDE) certifications at the Seouoyah Nuclear power Plant (SONp) and the Power Operations Training Center (PDTC) was perfortaed si rau l t aneous ly witn a
Nuclear Safety Review Staff (NSRS) investigation.
GTC will note that its evaluation of NDE inspector interviews supports the facts presented in the NSRS report and it'is not necessary to reiterate that subject.
The purpose of the* QTC investigation was to d et*erta i ne if NDE certifications had been falsified.
During the course of this investigation, several individuals were interviewed who requested their naraus be withneld.
Confidentiality developed during these interviews reina i ns with QTC.
No revelation of confidentiality between NSRS and QTC has or will occur.
QTC reali:es the at t achraent s to this report taay be, with little effort, identified to the correct individual.
It is not felt that these files are confidential and the naraes were deleted' cnly to etaphasize the dates involved.
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COMPANj P.O. BOX 600 Sweetwater. TN 37874 (615)365-4414 ERT INVESTIGATION REPORT PAGE 1 OF 7 CONCERN NO:
XX-85-069-OO1, XX-85-069-OO2, XX-85-069-OO3 (Rev.
O),
XX-85-069-OO6, XX-85-069-OO7, XX-85-069-X13, IN-86-230-OO1 CONCERN:
Employees OJT (on the Job training) records have been falsifiec INVESTIGATION PERFORMED BY:
M.
P.
Mills
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DETAILS PERSONEL CONTACTED:
CONFIDENTIAL DOCUMENTS REVIEWED:
f l
Procedure O202.14 Qualification and Certification Program for
\\(
Nondestructive Examination Personnel s
i SIS Record for Monitoring QA/DC Programs His and TVA Responses (7
pages)
Site Inplant Survey Checklist #21-85-P-OO9 SONP NDE Training Files (24)
SqNP ISI Training Files (16)
American Society for,Nondestruct ive Test ing -( ASNT) 1980 American Society for Nondestructive Testing (ASNT) 1975 Corrective Action Report HNCO-CAR-83-OO9-WB
~
Corrective Agt. ion Report MSG-CAR-85-08-012
~~
Audit MSO-83TS-05
- .e NDE certificatior[s are held'by.Ithe Inservice Inspection (ISI) group as well as the site Quality Control (DC) personnel.
These certifications inclu,de the following discip' lines:
ET - Eddy Current Examination.
PT - Liquid Penetrant Examination MT'- Magnetic Particle Examination RT - Radiographic Examination UT - Ultrasonic Examination VT (IX) - Visual *Examiniation - Section XI VT (III) - Visual Examination - Section III g'
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k PAGE 2 OF 7 ERT. INVESTIGATION REPORT CONCERN NO:
XX-85-069-OOi, XX-85-069-OO2, XX-85-069-OO3 (Rev. O),
XX-85-069-OO6, XX-85-069-OO7, XX-85-069-X13, IN-86-230-OO1
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DUA[L.S, cMtinued There are three levels of cer,tifi-cation, Level I,
Level II and Level -
III.
Level I
inspectors are basically trainees without the authori=ation to interpret examination results.*
Level II inspectors are authori=ed to administer examinations and interpret the t-esults of those examinations.
. Level III personnel administer NDE activities on the discipline or ptogram level.
They write' ptocedures, interpret requirements (codes and standards) and monitor / administer the training and certification program for NDE inspectors.
Because the Level I
inspectors do not interpret examinations and level III persorenel do not normally perform them, the tvaining file review was directed primarily at the Level II certifications.
A visit was made to the pOTC for the putpose of reviewing NDE r
certification /ttaining files.
pOTC NDE Supervisor- (name known) allowed
{
the review of the training files rnaintained by his department. He asked ds that he be informed of any discrepancies noted duting this file review.
(,
This was done.
A total of sixteen (16) ISI inspector files consisting of forty-three (43) NDE certifications and twenty-four (24) site DC inspector files consisting of eighty-two (82) NDE certifications were reviewed.
This review was tot
- 1) Determine the total amount of t irne devoted to NDE disciplines per.the exhibit "D"
forms and 2)
Determine the degree of compliance to TVA procedures for training /cortification files.
~
I t em til A
QC Supervi.sor (name known') provided a. current list of GC personnel performing hDE inspections at SONP.
From.thi's list,,, a chart was compiled to reflect the amount of job training for each,idspector (per the exhibit "D")
for 1983, 1983 was selected because the majority of SONP,QC inspectors were certified in that year.
After completing the chart, a review was made or the GC inspection log (which is required by AI-20) to determine the number and type inspection potformed by each inspector.
This information was added to the chart.
The disciplines reviewed were VT, pT, and MT.
It was not possible to maintain an accurate chart on VT because the DC inspection log failed to denote recorded inspections asSection III or Section XI. - The chart' produced 0
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ERT INVESTIGATION REPORT PAGE 3 OF 7 CONCERN NO:
XX-85-069-OO1, XX-85-069-OO2, XX-85-069-OO3 (Rev. O),
XX-85-069-OO6, XX-85-069-OO7, XX-85-069-X13, IN-86-230-OO1
__________=--
DETAILS, continued one very interesting fact.
The site QC group subrai t t ed to pOTC,**'
exhibit-
"D" f o rta s which indicated seven (7) months of MT had been perforraed at SONp during 1983, the DC inspection' log revealed three (3) inspections performed in this discipline during that year.
There exists the possibility of an error factor due to difficulty in reading ano unoerstanding the' casually raaintained inspection log, however, the error factor could not cover the stated seven (7) raont hs of MT inspections.
I t era t12 A
review was rnade of the training files for all forty (40) inspectors employed by ISI (16) and SONp QC (24).
Attention was directed toward 4
NDE certifications for Level II inspectors.
It is not practical to
[A list all discrepancies noted during this review due to the repetition and large
- numbers, however, the following are examples of those
(,' ' discrepanhies:
Corrective lens requirements not noted on certifications (names known).
Eye examinations which expired without the certification (s) being withdrawn (naraes known).
Exhibit. D "
ferros irnproperly completed, (see at t achraent s )
( naraes known).
" White out" used on certification ~hame or date ulth write overs (the certification is a quality record and " white #dut" is not allowed per Ref. AI-7(or NOAM (narnes known).
Individuals who failed o'e of the three certification tests but n
did not retake, all three as required, by 202.14(4.1.6-C)
( narnes known).
Exhibit "D" forras not dated (narites known).
Docuraents required for certification (test sheets, exhibit "D"
f orrns) which are located in the training / certification file are dated after the certification date (naraes known).
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ERT, INVESTIGATION REPORT PAGE 4'OF 7 CONCERN NO:
XX-85-069-OO1, XX-85-069-OO2, XX-85-069-OO3 (Rev. O),
XX-85-069-OO6, XX-85-069-007, XX-85-069-X13, IN-86-230-OOi DETAILS, continued
- pOTC personnel (names known) were questione6 regarding certification" dates which were earlier than test sheets and exhibit "D" forms.
They responded by stating the certifications were not* signed until after all required documents were available, reviewed and accepted.
They continued with the statement that the date typed on the certification sheet was the date the incividual was " certifiable",,even though the testing may not have been completed on this date.
They also pointed out that the certification date was certainly not the date the certification was signed.
When asked for data / documents to support the actual date the certification was signed, none could be provided.
In addition to the numerous discrepancies noted in the training files, it is imoossible to determine exactly wheti a NDE certification begins.
TVA has been made aware of difficulties within the NDE training / certification program on several occasions.
Cortective Action Report HNCO-CAR-83-009-WB (7-29-83),
Corrective Action Report MSO-CAR-85-08-012 (8-5-85),
GA Inplant Survey-Checklist H21-85-p-OO9 (7-26-85),
INp0 Evaluation - page #16 (April, 1985) Audit HSQ-83TS-05 (3-14/31-83) and ANII Report #15 (6-11/26-85) have all identified unique areas of the training / certification which required corrective action.
Even though no comprehensive study of the NDE certification program can be located, pOTC*has generated a preliminary document to rqsolve the majority of problems documented in this report.
The
" Quality Control and Nondestr'uctive Examination On-The-Job Training Manual" was originally projected for i ssue -in early
- January, 1986, however, several areas of the manual
- will require revision:
t The statement in the DJT
- manual, "The DJT-. Qualification Guide...does not require implementation",
d6wngrades this document'from a requirement to a guide.
This, document doe's not' state who is within its scope or who will be subject to its implementation.
Section II. B (2) (6) does not define the term "... based on...".
The manual fails to address what actions,will be taken if a
tvainee fails some portion of the manual.
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pAGE 5 0 7
INVESTIGATION REPORT ERT XX-85-069-OO3 (Rev. O),
XX-85-069-OO2, XX-85-069-X13, XX-85-069-OOi, XX-85-069-007, CONCERN NO:
XX-85-069-OO6, IN-86-230-001
~~
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DETd5LS[ cont [nbe5~ ~
was" for work time experience behind the ASNT requireraent following question:
the inspector w'as asked The logic questioned.
in NDE, pass the POTC Every individual with no prior experience "Can an (in any discipline)".
place inspector felt *the work course attached to Every this iraportance this inspector answered yes.
learned.
Withraonitoring/ documenting Not one the discipline wasthe necessity fot*
was where t irne experience, of certification becomes apparerst.
work aspect dur-ing CONCLUSION:
When discrepancies were noted for individuals responsible is substantiated.
" story" as to why the situation and were shown to the This concern or this investigation, was always a supported by pr'ocedure
[gdj}..these never be used to form
- items, ther e" stories" were the facts only must These
. existed.
Therefore, followings
( '
objective evidence.
include the These facts that conclusions.
interviewed NDE inspectors feel truthful (theirs and A very high percentage of correct or forras were not "D"
See the NSRS, report. *- ",
exhibit the wotding others).
in explaining exactly what
~
lack'of' definition The "D" form raeans.
in the exhibit forms wh,1ch cannot be of exhibit'"D" percentage
- l.s '
The "t'igh supported by objective evidence. forms compared to actual re e
n a, "D"
The DTC review of exhibit s
inspections in MT. *. control which exists at the POTC.
lack of document tation required The The signing of certification forms when doeuroen certification does not yet exist.
for that the actual date inability of anyone to determine or define The of certification.
At
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pAGE 6 OF 7 d
EP.T INVESTIGATION REPORT XX-85-CE9-CO3 (Rev. O),
XX-85-OG9-CO2, XX-85-069-X13, XX-85-069-001, XX-85-069-OO7, CONCERN NO:
XX-85-069-COE,
~~~~~~~~~~~~~~~~~~~~~~
IN-86-230-OOL
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
eye
when
~
DEThi~5[~~ccntinu o certifications as required to. withdraw not passed) failure by TVA (there f ore, t'aken The examinations are not by O202.14 programmatic RECOMMENDATION:
investigation clearly indicates both a TVA NDE
~
the within following of recoros the The results of thisfalsification Based on these
- findings, and tratning/ certification program.
breawoown
- Counsel, is recommenced:
to the Office of General and over o,f this reportlegal wrong doing, turn for investigation of against the 1.
The work order the (OGC) immediate until such time as stop an of NDE inspectorsd corrective act ion taken.
2.
TVA issue certification s
situation can be evaluated an which are dates ATTACHMENTS:
reflect signatureEven though statement Certificationfrom the certification dates.the level listed above",
sheets actual date of skates "...is hereby certified to different is used for the and h3.
date
- 16 earlier (typed)
- 2, attachments #1, certification.
~
the See certification..
f dates are typed on the record onote i
ed and dated are Certi.fication Exam 31'Esthis certification date.
were that being is clear all required criteria it after for certification, ithout 5A,.58, SC, G,
GA, CD, required were signed and authorized w4A, 40, 4C, 5, See attachmerAs H4,
't eq EC, 7,
7A, 70, 8,
BA, 9,
9A.
,raut.
revoked some flies which to be in neveralThis letter appearspractical 75 letter was notei(VT Section III). Sain and in volves a A
form in compliance certificationsGothard to Leo H.
which was not therefore, it
- 4D) from M.
E.
(one attachmentThis letter is not dated and, instituted.
Why examination it was used for with DpM N75COi.possible to determine Just whenfication record w
,i the bottom section of the certi is not D
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ERT INVESTIGATION REPORT PAGE 7 0F 7 CONCERN NO:
XX-85-069-OO1, XX-85-069-OO2, XX-85-069-OO3 (Rev. O),
XX-85-069-CC6, XX-85-069-OO7, XX-85-069-X13, IN-86-230-OO1 DETAILS contin ~Eed
~~~
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
6 its intended purpose (revoking certifications) is not known."'
DPM N75C01 requires anyone failing one section of the test to retake all three sections.
This was not'done.
See Attachment 40.
There are thrie basic criteria for' certification in the arka of NDE:
- 1) Current eye examination,
- 2) Documented evidence of work time experience, and 3) Successful completion of the formal training classes.
Examples were noted where the documented evidence of work time experience is dated sometime after the certification was issued.
It appears that the cortification was signed without all. required criteria being mot.
See attachments #5 and 5D.
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,l PREPRRED DY _
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____ ___ __ ____ ___ __, ~h_'hI,_ _
DATE vl j
REVIEWED BY ____ _
_____(___ ______________/_l/s($I____
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REQUE T FOR REPORTABILITY EVALUATION' Y
XX 9-001, XX-85-069-002, XX-85-069-003, XX-85-069-006 k
1.
Request No. _Xy-85-069-X13. XX-R5-069-007. IN-86-230-001 (EitT Concern No.)
(ID No.,
if reported) 2.
Identification of Item Involved:
NDE Certifications (Nomenclature, system, manuf.,SN, Model, etc.)
3.
Description of Problem (Attach related documents,
- photos, sketches,etc.)
Emplovees OJT (on the j,ob training) records have been falsified.
4.
Reason for Reportabilitys (Use supplemental uheets if necessary)
A.
This design or ' construction
.de fici ency, were it to have remained uncorrected, could have affected adversely the. safety
.of operations of the nuclear power plant oc any time throughout the expected lifetime of the plant.
The failure to properiv No _____ Yes
__X___ If Yes, Enalain:
evaluate work could result in unacceptable installations.
pND-
..'.a D.
This deficiency represents a sinnificant_
breakdown in any portion of the quality assurance
- program, conducted in accordance with the requirements of Appendix B.
..i......
No
___.Yes
- .X.___. If Yes. Explain
_._This deficiency violates 10 CFR 50 A.P.Pendix B, Criterion 2 (7)
./.
a-OR s
C.
This deficiency represents a i.innificant, deficiency in final design as approved und released for construction such that the design does not conform to the criteria bases stated in,the,.
safoty analysis report or construction permit.
No
_ __X_ Y e s ___._
I f Y e s, Explains __ ____.__ _____ _.
--________________...__________________8 O!1 4
ERT Form M
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REQUE T FOR REpCitrABILITY EVALUATION XX-85-069-001, XX-85-069-002; XX-85-069-003, XI-85-069-006 N
_ XX-85-060-X13. XX-LS-069-007, IN-86-230-001 s,
1.
Request No.
(ERT Concern No.)
(ID No.,
if reported) 2.
Identification of Item Involved:
NDE Certifications (Nomenclature, system, manuf.,SN, Model, etc.)
3.
Description of problem (Attach relatard documents,
- photos, sketches,etc.)
) records have been falsified.
_Empl.o_v_ees 03T (on the lob training
= - -
___ 4 ____
4 Reason for Reportabilitys (Use supplemental sheets if necessary)
A.
This design or construction, deficiency, were.it to have remained uncorrected, could have affected adversely the. safety tc any time throughout
.of operations of the nuclear power plant the expected lifetime of the plant.
The failure to properiv No _____ Yes
__X___
If Yes, Ein9 lain evaluate work could result in unacceptable installations.
I DHD D.
Thin deficiency represents a sinnificant_
breakdown in any portion of the quality assurance
- program, conducted in
.s.'.
accordance with the requirements of Appendix B.
.. This deficiency violates No ____. Yes _>X___ If Yes," Explain:
1._0,CFR _50__A.P.P_e n.d_i.x__B., _cr.i..t.e r i.o._n 2._(7_)
. r*
- i OR g
in final C.
This deficiency reordsents a piunifleant, deficiency desiUn as approved and released for construction such that the,
denign does not conform to the criteria bases stated in the -
nafuty analysis report or construction permit.
No
__ X. Yes If Yes, Exp1a'ine_
-__...__-_-.__e D11 i
t ERT Form M a.
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5 P.
C PERSONNEL Q ALITICATION At:D CERTIFICAT10ti RECORD -
ENNESSEE VALLEY AUTHORITY DIVISION OF NUCLEAR POWER
}
1.
Name of certified individual 2.
ITDE method and level of certification Liould Penetrant - Levet IT 3.
Percentage grade obtained on examinations for certification:
90 94*3 B.
Specific examination A.
General examination 82.1 C.
Practical examination 4.
Percentile weights assigned ea'ch examination for certification:
.20
.30 B.
Specific examination A.
General examination
.50 C.
Practical examination 88.S i
5.
Composite grade 6.
Tha above-named individual has satisf actorily completed the requirements listed in the TVA Division of Nuclear Power Qualification and Certification PT-II Examination and is hereby certified to the Program for i
l evn b A i atmihahnvef.//
[-/-gg TVA Level III 11/3/83 l Title Date
Name Corrective Eyewear Limits of certification (if any):
1 7.
Terraination of Certificationt i.
The above certification is revoked as of for the reason (s)
~
checked below l
l A) Individual transferred out of QA&C Branch.
yj, I
s tI l
l lB)
Individual has slot performed the duties of his level of certification satisf actorily (See attacivnent for details).
l l C) Individual has not passed required visual acuity examination for over 12 months.
l l D) Other (Se attachment for details).
Signed:
Dates TVA Level III, TVA 6780 (D!!P-10-82) j
cd
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PERSONNEL QU LIFICATION AND CERTIFICATION RECORD
~
T NNESSEE VALLEY AUTHORITY IVISION OF NUCLEAR POWER
[(
Nameofcertifiedindididual 1.
(
Liquid Penetrant Examination NDE method and level of certification 2.
Percentage grade obtained on examinations for certification:
3.
86.4 94.3 B.
Specific examination A.
General examination 94 C.
Practical examination Percentile weights assigned each examination for certification:
4.
.O
.30
_ 3, Sp,cggge examination A.
General examination _
.50 C.
Practical examination 92.6's 5.
Co:nposite grade The above-named individual has satisfactorily completed the requirements listed in the TVA Division of Nuclear Powe'r Qualification and Certificati 6.
PT-II Examination and is hereby certified to the Program for Invel A4pd ahnve[ ) /
(12/12/83 /
/ 3 8[,t TVA Level III Date 7 /
Title
- na*=
Corrective Evewear
\\'
Limits of certification (if any):
7.
Termination of Certificatiin s.
for the reason (s)
The above certification is revoked as of
- t checked below:
l l
l A')' ' Individual transf erred out of QA&C Branch.
'.,M
.1 Individual has not performed the duties of his level of
..l lB) ils).
l
' certification s'acisfactorily (Scr attachment for deta I
i Individual has not passed required visual acuity examination lC) for'over 12 months.
l l
lD) Other (See attachment for details).
)
i i
Dates Signedt IVA Level III TVA 6780 (DUP-10-82)
.s
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i PERSONNEL Q JALIFICATION AND CERTIFICATION RECORDTf-}
ENNESSEE VALLEY AUTHOR 11Y DIVISION OF NUCLEAR POWT't
. 1.. Name of certified in ividual Visual Weld Exa:nination (Section III). Level I
2.
NDE method and level of certification Percentage grade obtained on examinations for certification:
3.
72 96 B.
Specific examination A.
General examination 86.9 C.
Practical examination 4.
Percentile weights assigned each ' examination for certification:
.20
.30 3.
Specific examination A.
General examination 1
.50 C.
Practical examination I
8 6. 7*.
5.
Composite grade The above-named individual has satisf actorily complaced the requirements listed in the TVA Division of Nuclear Power Qualification and Certification 6.
VI-IIIII-Il
' Examination and is hereby certified to the f
P,togra:n fjf e (i..-s n4 e l Lhnvli.
7/14/83*/
.TVA Level III g
gy 6
Date Title U
y N.
Limits of certification (if any):
f t
7.
Termination of Certification:
for the reason (s)
The above certification is revoked as 'of i
checked below:
4 l
l"'A)
Individual tratisf erred out of QA&C Bra'nch.
%,J.
.t l
lB) Individual has riot performed the duties of his level of r
i for details).
certification satisfactorily (See attachment
,1 i
l l
lC) Individual has not passed required visual acuity examination for cver 12 months.
i l
l D) Other,(See attachment for details).
l r
l Signed:
- Date:
TVA Level Ill TVA 6780 (DNP-10-82)
J
-m_.,~.__.--_,,.,,..,_..__._-,n,,-
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,-...,,_,_ - -, me-__.,
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PERSONNEL Q ALIFICATION AND CERTIFICAT10!! RECORD ENNESSEE VALLEY AUTHOR 1H DIVISION OF NUCLEAR POWER jg
~
1.
llame of certified individual Inservice Visual Examination - Level II 2.
HDE method and level of certification 3.
Percentage grade obtained on examinations for cirtification:
74 2 70.9 B.
Specific examination A.
General examination 91.5 C.
Practical examination 4.
Percentile weights assigned each examination for certification:
.?0 A.
General examination
.30 B.
Specific examination C.
Practical examination.50 81.9%
5.
Composite grade 6.
The above-named individual has satisf actorily completed the requirements listed in the TVA Division of Nuclear Power Qualification and Certification Program for, VT-II-(XII Examination and is hereby certified to the
/kevel lidedl abod.i.
WA HDE Level III 1/31/84 4 me Title Date Lir.its of certification (if any):
7.
Termination of Certification:
The above certification is revoked as of for the reason (s) checked below:
~
l l A) Individual transferred out of QAIC Branch.
Y, g,
y.t,,
s
. -l.
lB) Individual has not performed the duties of his level of
' certification satisfactorily (See attachment for details).
l lC) Individual has not passed required visual acuity examination for over 12 months.
- l l D) Other (S e attachment f or details).
Signed:
Dates TVA Level III i
TVA 6780 (DilP-10-82)
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- pp TENNESSEE VALLEY AUTil0RITY DIVISION OF NUCLEAR POWER NDE LEVEL II QUALIFICATION EXAMINATION VISUAL INSERVICE EXAMINATION HETil0D Practical Examination No. VTI-II-P-02 s
,2///8d DATE:
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SS#:
g:
N Ib SCORE:
- 8. $
The percent of known unsatisfactory conditions
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properly detected and evaluated The number of incidences Humber of Correctly of where the location of Identified Unsatis-unsatisfactory conditions
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fact rv Conditions _
g9) g9, was recorded in wrong Score s Numoer of Known Id/ )
area Unsatisfactory Conditions The number of incidences (J ) g The number of ( p) g, where the required docu-minus incidences of mentation was not recorded
..r excessive overcalls k/ d
( 73 8
_) - (.f. ) -(O ) - (.I )
SCORE =
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REMARI:S ity to I have reviewed all questions which are missed, have'had an opportun
- U ch questJ,on.
ask questions,.and understand the correct ans er to ea. ' r#
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SIGNATURE
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REPORT ON INDIVIDUAL PARTICIPATION IN AN EDUCATIONAL ACTl\\
1.
i t ibuted only at t son sa the educational activity is voluntary. this report is completed and d s r for part6cipation 6n less then 75 percent of hours of instruction of fered.
3 JoD istle Engr Aide Orlicial 54allon erancn
,iion SequoyrJ.
0T.
til:0 PI:
T ype of Activity Inservice Visual Examination Training Level II Total hours attenced Total hours of 6nstruction olleree Date enoed Dale cegun 56
?/1/g4 I 12 *. /.' a Suojects covereo:
Introduction to visual examination.
ASIE Code requirements related to visual exarsination.
Visual exarnination procedures.
Perfomance of visual examinations.
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Records and reports.
Method of ins. ucton:
Lecture, demonstration and laboratory exercises.
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Unsatistactory
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{ Satisf actory Evaluat6on of partic.pation:
Comments >
- tlan certified Daltribution of topieg Partm6 pant Signature of Activity Le While Succevltor
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Loc al Personnel oflice Giue Empioyee's File Yellow Signature, of Personnet Ollitet or itanning ut
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TI!!.TESIE valli's* AtlT50r.:Tl PACE DIVISIO:! OT 1:llCI.IAR PotCR '
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C Exa:aination Answer Sheet D*.A'.fI!!AEIO ! !!O. V77 NA'!E SOCIAI. SI-*.:T4* NO
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ABChE 26.
AhCDE
- 51.
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- 76. ABCDE 2.@3CDE
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- 77. ABCDE ABhDE 53.
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- 78. ABCDE
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28.
4 ABCDE 29.
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- 79. ABCDE 5.
ABCDE
- 30. A@c D'E 55.h5CDE 80.
ABCDE 6.
ABhDE
- 31. haCDE
- 56. ABCDE
- 81. ABCDE
- 7. AB@DE
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- 57. A B C.D E
- 82. ABCDE
- 8. ABChI
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- 58. ABCDE
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- 34. AB@DE
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A,8 C D E 85.
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- 11. hBCDE
- 36. A5.DE 61".
ABCDE
- 86. ABCDE
- 62. ABCDE
- 87. ABCDE AhtDE 3J. hCDE 12.
- 63. ABCDE
- 88. ABCDE ABChDE
- 13. A (p3)C D E 38.
14 ABCOE
- 39. 4B@DE 64 ABCDE
- 89. ABCDE 65.
ABCDE 90.
ABCDE K./ BODE 40.hBCDE ABC@E
- 66. ABCDE
- 91. ABCDE
- 16. A@CDE 41.
- 67. ABCDE
- 92. ABCDE AhcDE
- 17. A@CDE 42.
68.
ABCDE
- 93. ABCDE ABCDh y/. A B h tf E 18.
94 ABCDE AhcDE
- 69.,ABCDE
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- 71. A B'C D E
. 96. ABCDE 47.
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- 72. A B d D.E
- 97. ABCDE N.AhdDE
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- 73.
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- 49. AB@q,E 74.
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- 75. A8CDE
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I have reviewed all questions which are missed, have had an opportunity to ask quest, ions, and understand the correct answer to each question.& / < 9
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VISUAL. UT.LD EXA!!INATIO!!S (SECTION III)
Subject:
A review of the Visual Weld Examinations (Section III) which vere ad:sinistered 28, 1983 has indicated that some of the practical examinations prior to April in full compliance with the requirements of Hote 5, Page 21, of
.DP!! M75C01, dated October 14, 1982. Based on this, the following corrective -
were not action has been initiated.
The certifications of all personnel possessing a discrepant practical examination 1.
have been revok6d effective either the date of their first II, Section 5 3.A.
or !!ay 1,1983 in accordance with OQAM Part Personnel vill be racertified after successfull completing a new This recertification shall be reinstated 2.
practical examination.
affective to the revocation date established in (1) above.
Personnel not successfully completing a new practical examination 3.
vill not be recertified until,the requirements of the above DPH A copy of this memorandum shall be sent to the have been met.
fnr enrracHva action.
cognitant quality assurance organf raHon
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Certification uns revoked for
$/1/83 and the following action has been taken:
on (Date) 5/5/83 A new practical was successfully completed on 1.
(Data) andcertificationisreinstatedeffechive ~
(Date) 1/13/83
.: or
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N/A 2.
tio prac,tical vill be taken per
-(Hame/Iitle)
H/A and a copy of this form was sent to g
- at N/A for corrective action,; or The new practical was failed, and a copy of this form uns sent to 3.
N/A il/A at (Address)
(Hame/ Title) for corrective action.
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- f-PERSONNEL QUALITICATIO!! AlfD CERTIFICATION RECORD TE!Tt1ESSEE VALLEY AUT!!ORITY DIVISI0tl OT !!UCLEAR PO'.!ER N
1.
!! ace of certified individual Flaenetic Particle - Level II 2.
I;DE method and level of certification Percentage grade obtained on examinations for certification:
3.
90 77 7 B.
Specific examination A.
General examination 93 7 C.
Practical examination Percentile weights' assigned each examination for. certification:
4.
. 2 0'
.30 B.
Spec (fic examination A.
General examination Practicalebamination
.50 C.
- 89. 0 5.
Composite grade The above-named individual has satisfactorily completed the requirements 6.
listed in the TVA Division of iluelear Power Qualification and certification M-T T M - Examination and is hereby certified to the Program for level list:cd M Tk'A ilDE Level III 3/29/84 ti 11cle Date
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Limits of certification (if any):
7.
Ternination of Certification for the reason (s)
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The above certification is revoked as of checked below l
l A). Individual transf erred out of QA&C Branch..b.
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Individual has not' performed the duties of his level of certification satisf actorily (See attactunent for deca 11s).
l l C)
Individual has not passed r'equired visual acuity examination for over 12 months.
l l D) Other (See attachment f or details).
Date e
Signed!
TVA Level III TVA 6780 (Dt!p-10-82)
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sr it R EPO RT NOlvlOUAL PARTICIPATl!N lN AN ED
.1 NAL ACT A
articipation in the educational activity is voluntary, this report is Completed and distributed only a ot made for oarteceoation in less than 75 percent of hours olinstrucilon offered.
Ime Job Title I %,ses < ca 7
j Engr Aide A Olrision BranCn opticial station s
tac PR f)E Watts Ear liuclear Plant Type of Activity Magnetic Particle Examination Training - 1evel II Dalebegun Date ended Total hours of instruction of f ered Total hours attenced 3/26/P.!
3/30/84 0 36 36
$u!letti Covereds Examination procedures N-HT-1 and N-MT-2 ASitE Code Sections III, V, and XI as related to Mr.
flagnetic particle examination theory and principle.s (Review).
t
*thod of instructions 1.ecture, demonstration, and }&boratorf exercises.
at Evaluation of participations y $atisfactory
. Unsatisfactory 0
Ctmmentit
- Was certified i
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Oltttibution of copies White Participant i
Pink Supervisor
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5egnature oI Personne Of ficer of T eammg Office TVA 1453 IPO l*794
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g, Record of Magnetic Particle Examination n
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Date of Examination:
3 o [f 4 Report No.: I v
Procedure No.:
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Rc Original Examination s/
Re-examination y
Weld Joint No.:
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'0D EI-N bh ltem or System
Description:
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Referenced Drawing:
AJ A Ma
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Method of Magnitization (Check if Applicable):
jo IL. 7~5 BMs 8^ ##/
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V-8' 7** M Equipmen Type:
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Pole Spacing:
6C Prod Spacing:
L:yu w t. rfd 9e*1-M 9/w/r.1
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515.759' Magnetizing Current:
J s.y.
(a o o p'
%f" Y~o. 3/^n t y gg.,,,
M a% DMO
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Particles Drand & Color:
- .gt<~g y./
Examination Results:
su Satisfactory Y
Unsatisfactory M
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d Explanation of Unsatisfactory Results:
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Examined Dys
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Level:
Tv A vi40A (orm441)
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DIVISION DE ;;J *.IAR FO*7.R Exami=stic: =sver Sh==:
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Sc~ A*. SI~URI~T NO.
DATI M
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- 53. A@CDI 78.
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- 54. AB@DI 79.
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- 55. @ 3.C*D E' 80.
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- 56. AB@DI 81.
ABCDI
- 6. hBCDI 31.
- 7. h3CDI
- 32. $BCDI
- 57. A$CDI E2.
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- 8. hBCDI 33.
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- 9. @3CDI 34 BCDI
- 59. $ B C D I S4.
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- 35. h5CDI
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- 36. @BCDI
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- 37. @BCDI
- 62. A@CDI
- 57. ABCDI hBCDI 38.
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- 63. AB@DI ES.
ABCDI 13.
h3CDI 39.
- 3CDI
- 64. $ 3 C D I 89.
ABCDI 14 15.
BCDI 40 hBCDI 65.
ABCDI 90.
ABCDI 16.
BCDI 41.
AB@DI
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ABCDI 92.
ABCDI 66.
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- 17. h3CDI 42.
A@CDI 67
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/BCDI 43.
AB@DI 68.- A B C D I
- 93. ABCDI 19.
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- 69. ABCDI 94 ABCDI h B,C D I 45' AB@DI
.-7 0.
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- 95. ABCDE 20.
k21. AhCDI 46.
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- 71. ABCDI
- 96. ABCDI 02.
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A B O:: I 72.
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- 73. ABC'DI
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Rev t::e d OCT 14 03-
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Date:
- l. /19/84 /(
]a Nuclear Traininr, Dranch, ilDE Training Unit.
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During the period from 3/7/83 to *
- 3/7/84
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'has received 12 mdnths of NDI r.,.
crperience, a t least 257. of sehich van in the HT
! methed.
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- has performed 28 inspections during this period.
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PERSO! ;EL QUALIFICATION AND CERTIFICATION RECORD TENNESSEE VALLEY AUTHORITY DIVISION OF NUCLEAR PCUER
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Name of certified individual 2.
NDE method and level of certification Liquid Penetrant - Level II 3.
Percentage grade obtained on examinations for certification:
A.
General examination 88.6 B.
Specific examination 84 C.
Practical examination 97 4.
Percentile weights assigned each examination for certification:
A.
General examination
.30 B.
Specific examination
.20 C.
Practical examination
.50 5.
Cooposite grade 91 9 6.
The above-named individual has satisfactorily completed the requirements listed in. the TVA Division of Nuclear Power Qualification and Certification Program for PT-II Examination and is hereby certified to the 1=u=1 liermal ale d.
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TVA Level III n..
Title
- / Dite Limits of certification (if any):
W, -
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Termination of Certification:
l The above certification is revoked as of for the reason (s) checked below:
(
l l A) Individual transferred out of QA&C, Branch.
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lB)
Individual has 'not performed the duties of his level of
' certification satisfactorily (See attachment for details).
l lC)
Individual has not passed required visual" acuity eAamination for over 12 months.
l lD) Other (See attachment for details).'
Signed:
Date:
s WA Level III l
WA 6780 (nNP-10-82)
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b PERSO NEL QUALIPICATION AND CERTIFICATION RECORD TEN!iESSEE VALLEY AUT110RIIT DIVISION OF NUCLEAR POWER
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Name of certified individual-2.
NDE method and level of certification-Liquid Penetrant - Level II
~
3.
Percentage grade obtained on examinations for certification:
A.
General examination 00*0 B.
. Specific examination 84 C.
Practical examination-97 4.
Percentile weights assigned each examination for certification:
A.
General examination-
.30 B.
Specific exar.ination-
.20 C.
Practical examination-.50 5.
Cociposite grade 91 9 6.
The above-named individual has satisfactorily completed the requirements listed in the'IVA Division of Nuclear Pouer Qualification and Cert Program for-PT-Il Examination and is hereby certified to the f.
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TVA Level III
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Title
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Li2::its of certification (if any):
"n a
7.
Terciination of certification:
w The above' certification is revoked as of checked below-for the reason (s) i I.
J^) Indiyidual transferred out of QA&C Branch.
s O.,,
7l lB), Individual has not performed the duties of his level of certification satisfactorily (See attachment for details).
l lC)
Individual has not passed required visual' acuity examination for over 12 months.
D) fi Other (See attachment for details).
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Signed:
Date:
IVA Level III IVA 6780 (D!lP-10-82) m
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F Record of Liquid Penetradt Examination
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- Date of Examination:-
'7/F /B2
_ Report No.:
8-I e
Procedure No: _
d-PT-/
Revision:
M Original Examination Y
Re-examination
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Weld Joint No.:
K p,,
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,R-%-% @ FF I
Item or System
Description:
AfA 7f I Part Temperature:
Surface Thermometer S/N Y 3 R 3 2.
A Penetrant Materials i
.k Brand Name:
Magnallux Spot Check
)c e
Sherwin Double Check Other:
Type Lot or Batch No.-
i Penetrant S l< L-HF Mill Remover Skc-NF 11 F o'S o Developer et s
s k b-t4 F 4 3 PO l' B Results of Examination:
Satisfactory Unsatisfactory
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Explaination of Unsatisfactory Results:
3r.n a l llorar luJ te J.*ma M
t N;m taco en
- , ex i tr-4Las $L rde.e e.
le.urd L be; &<eh \\.\\e.ow s eecd$fnc o i
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Examined By:-
Level:
I Evaluated By:
A/4 k
Level:
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, TENIISSEE VAI.I.EY AUTil0RITY (
PAC) iT DIVISION OF NUCLEAR POWER
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Examination Answer Sheet
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HAME,
EXAMINkTIONNO. F T.22-SOCIAL SECURITY NO.
22ssurM& fr DATE 7/8 /12 SCORE
- 1. ABC@E 26.
ABCDE 51.
ABCDE 76.
ABCDE
- 2. hBCDE 27.-
ABCDE 52.
ABCDE 77.
ABCDE 3.
A$CDE 28.
ABCDE 53.
ABCDE 78.
ABCDE 4.
A$CDE 29.
ABCDE -
54.
ABCDE 79.
ABCDE 5.
ABCOE 30.
ABCDE 55.
A B C D.E 80.
ABCDE
- 6. ABC@E 31.
ABCDE 56.
ABCDE 81.
ABCDE 7.
A(JCDE 32.
ABCDE 57.
ABCDE 82.
ABCDE 8.
ABCD@
33.
ABCDE 58.
ABCDE 83.
ABCDE 9.
A B(p D E 34.
ABCDE
'59.
A B'C D E 84.
ABCDE N10. _ A @ C hE 35.
ABCDE 60.
ABCDE 85.
ABCDE 11.
A$CDE 36.
ABCDE 61.
ABCDE 86.
ABCDE
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- 12. ABODE 37.
A B C'D E 62.
ABCDE 87.
ABCDE \\
13.
A@CDE 38.
ABCDE 63.
ABCDE 88.
ABCDE
- 14. ABC@E 39.
ABCDE 64.
ABCDE 89.
ABCDE
- 15. $ B,C,D E 40 ABCDE 65.
ABCDE 90.
ABCDE 16.
A 3)OD E 41.
ABCDE 66.
A B C'D E 91.
ABCDE
- 17. @BCDE 42.
ABCDE
,67.
ABCDE 92.
ABCDE
,1 - *18. @BChE 43.
ABCDE 68.
ABCDE 93.
ABCDE
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--19.
A@C@E 44.
A B C D.E 69.
A B'C D E_
94.
ABCDE t
20 A@CDE 45.
ABCDE 70.
A B C'D E 95.
ABCDE 21.
A B () D E 46.
ABCDE 717 A B C D E 96.
ABCDE 22.
ABC"D'@
47.
ABCDE 72.
ABCDE 97.
ABCDE
+ 23. hg) C, D E
,h85*ABCDE 48.
ABCDE 73.
ABCDE 24.
@DE 49.
A B C'D E 74.
ABCDE 99.
ABCDE
+
25.
@CD'E
- 50. A B.C D E
- 75. ABCDE 100. ABCDE REMARES I have reviewed all questions ubich are missed, have had an opportunity to as!
- , -----' -' correct answer to each question.
W/7ei 4 D__
DATE g
([d EXiMINER DATE s
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53 (PD.I.79) y
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re REPORT N INDIVIDUAL PARTICIPATION If4 At EDUrtA. TION At AC*
f When participation in the educational, clivity is voluntary, this report is comptentr*.and.disedinassionly are not made for participation in less tlian 75 percent of hours of instruction of fc=-3t.
lName Joe Title
!5asiair s,er Engr Alde
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AL,,- %.
i n.m eneun Branch is**.sJetl3a:sorr i
NUC PR i
QE h r: Pa:r Niexr Plant Type of Activity Liquid Penetrant Examination Training - Level II Date begun Date ended Total hours of snsameseniotitbir of
' Tio tasi nanses ats eno r
.)
7/5/E3
.7/8/83
~-
30 30 Suojects covereo:
Examination Procedures N-PT-1 thru ll-PT-6.
ASIE Code Sections III, V, and XI as related to PT..
PT test theory and principles (Review).
e.
Velhed of instruction
.u.
l Lecture, demonstration and laboratory exercises.
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..s Evaluation of participation:.
s,I Sallsfactory Unsa tisf actory Comments: -
- Nas certified.
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'*tribution of cop:es:
'te Participant Supervisor
'. se Local Per Sonnel O flice Signature en,ir.cwrty Leaa Y
venow Employee's p;i, Sigtatura: oIIFe sonnes or t*-
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PERS0! XEL QUALIFICATION AND CERTIFICATION RECORD
/
TENNESSEE VALLEY AUTil0RITY l
DIVISION OF NUCLEAR Pok'ER 1.
Name of certified individual 2.
NDE method and level of certification Inservice Visual (Section XIl-Level II 3.
Percentage grade obtained on examinations for, certification:
A.
General examination 80 B.
Specific examination 92.S C.
Practical examination 90 4.
Percentile weights assigned each examination for certification:
A.
General examination-
.30 B.
Specific examination
.20 C.
Practical examination
.50 5.
Cociposite grade
- 87. S'S 6.
The above-named individual has satisfactorily completed the requirements e
listed,in the TVA Division of Nuclear Power Qualification and Certificationf Pjograt- -. g4 Examination and;is hereby certified to the f
/T-f XIl-II
.t In o
~2/16/84,i
_(,
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Title Date Limits of certification (if any):
None 7.
Termination of Certification:
7 The above certification is. revoked as of for the reason (s) checked below:
l l A) Individual transferred out of QA&C Branch.
4 I
s 3
- -l l B), Individual has.not performed the duties of his level of certification satisfactorily (See attachment for details).
l lC)
Individual has not passed required visual acuity examination for over.12 months.
~
l lD) Other (See a,ttachment for details).
u Signed:
Date:
TVA Level III TVA 6780 (DNP-10-82)
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TEN 1.T.SSEI VALLEY Al.Tif0RITY DIVISIOl: OT NUCLEAR PO'GR NDE LEVEL II OUAN TICATION EXA.*lI;;ATION VISUAL I!! SERVICE EXAMINATION IET110D Practical Examination No.
17I-II-p.02 SSir:
DATE: __ m_/f y/,
SCORE:
@O
-artigi The percent of known unsatisfact'ory conditions properly detected and evaluated
/d O
,n et C
Number of Correctly Identified Unsatis-The number of incident t1i
-factorv Conditions of where the location or Score Number of Known -
( 3/ ) minus unsatisfactory conditions h[$hy Unsatisfactory (2/
)
was recorded in wrong
(
Conditions area
.sd j
The number of
)
In(
incidences of (.f )
The number of incidences 1
minus c,
i excessive here the required docu-(##
)*
c overcalls mentation was'not recorded
- y It SCORE =
(_ /0 0
)(
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)
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EXAMIh7.R Qjg&[*;. p$
, f
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I s.
=73
'"J 8
k1 REPORT
?
er10lVfDUAL PARTICIPAT!ON IN AN EDUCATIOt4AL ACTi\\
9 l
o the educational srlicroatson in less t, n 75 percent of hours of instruction offeredtivity is vo
/
Job Title social Securi
(
Entrr Aide MW ~.
Branen Of ficial Sta tion
~
R QS Jf Actsysty 11stts.".nr "ucicar F1 ax Inservice Visual Examination Training - Level II' sate cegun Date enced Total hours of instruction of fered 2/o/R4 Total hours attenced 2/17/;ta t
Suosects covered:
tA
'mX 55~
Introduction to visual exa::iination.
ASIE Code requirements related to visual examination Visual examination proc'edures.
Perfor:.ance of visual examinations.
Records and reports.
Aethod of ins
- uctecn:
Lecture, demonstration and laboratory exercises t
\\
Etatuation of rartic.pation:
t Sa tisf actos y i
CnIrnents:
bnsatisfactory has certified.
~~
D stribution of cop,ep Wh le i
Partictparit i
Supervison Local Personnet Of fire
~
Employee's File Signature of Ac'tivity Leaoer t
r Signature of Personnen Of f ecer or Training Oflicer
l
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(
PER ONNEL QUALITICATION AND CERTITICATION RECORD
/
/
TENNESSEE VALLEY AL*THORITY j
DIVISION OF NUCLEAR POWER
.\\
1.
Name of certified individual
'2.
1;DE method and level of certification Liould Penetrant - Levet ri 3.
Percentage grade obtained on examinations for certification:
A.
General examination 88.5 B.
Specific examination _
- 81. 8 C.
Practical examination _
n6 c 4.
Percentile weights assigned'each examination for certification:
A.
General examination-
.30 B.
Specific examination _
.20 C.
Practical examination
- 50 5.
Composite grade a 4_ > -
6.
The above-named individual has satisfactorily completed the requirements listed in the TVA Division of Nuclear Power' Qualification and Cer Program for DT-TT Examination and is hereby certified to the
[
A
/ I
/
'2/23/84'#
Name
~
Title Date Limits of certification (if any):
Corrective Evewear
- t.
7.
Termination of. Certification:
The above certification is revoked as of
~
_for the reason (s) checked below.
I l
l A)
Individual transferred out of QA&C Branch.
i.
l
'.s -
{
~~
(
lB)
Individual has'not performed the duties of his level of certification ' satisfactorily (See attachment for details).
i l
l
'] C)
Individual has not passed required visual acuity exaciination for ov,er 12 months.
l lD)
'(-
Other (See attachment for details).
s Signed: ~
Date:
TVA Level III l'
TVA 6780 (DNP-10-82) i
9)
,. REPORT ON tNOlVIDUAL PARTICIPATION IN AA EDUCATIO r,
NAL ACT for particsostion in less than 75 percent of hours of iDon in the educ
(
s completed and distributed only al
/
nstruction of f ered.
k Job Title i
15ccial Secu~
n Enry Aide 1Branen
- LC PR tw"~-*-.~.
OE ype of Actsvity Secuoynh Nucient Plan Liquid Penetrant Examination Training - Level II Date begun
' Date enced Total hours of instruction offered IXInXE::X 2/21/84 7/24'/84 0
~ Total hours attence Subjects coverra:
32 Examination Procedures N-PT-1 thru N-PT-6 PT test theory and principles (Review)ASPE Code Sect e to PT.
4 l
.ethod of instruction:
Lecture, demonstration and laboratory exercis es.
i r
9 Evaluation of partlCipationt *
.'. s -
,3 L
Ccmments:
Satisfactory i
Unsatisfactory t
i
- Was certified ution of copies:
'g t
Participant
\\...
Supervesor
. olu e j
Yettsw Local Personnet Of fice 7 /r y '
~
Employee's File S'gnature or actamy 1 eader
~
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r i
3 o.-
e-
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Record of Liquid Penetrant Examination Date of Examination:
d -M-fi #
port No.:
II -b
/
Procedure No:
d-M- I OFS. E Revision:
I Clan I Original Examination' Re-examinatio[
$ibL Weld Joint No.: b4 //
- % -h FF R8 Item or System
Description:
b$
/-M/A/7 e
Ref. Drawing No:
Ll M I
/
Part Temperature:
78 Surface Thermome
/N 90/0/d
(
Penetrant Materials d/6//T"M W #
.5 - N 9 0 0 4 Brand Name:
Magnaflux Spot Check
/p /4 Sherwin Double Check
/
- s.
Other:
Type LoLor Batch No.:
btL& L-c dE R Penetrant
~~
b P -Ao is 4 31 Dou B L-CHEK Remover i
be-G o 43ggo m.
Dou.6 c -cHGx Developer b-too.
$ 6-6,6 Results of Examination:
Satisfactory Unsatisfact s/
Explaination of Unsatisfactory Results:
8 ona/MA Eb MT ua /h _
/
l hne amafer 1%d 46
Examined By:
g Level:
f.[
Evaluated By:._
. Level:
t)
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C C
PERSONNEL QUALIFICATION AND CERTIFICA e
TENNESSEE VALLEY AUTilORITY RECOP.D f
DIVISION OF NUCLEAR Pok'ER 1.
Name of certified individual.
2.
NDE method and level of certification Percentage grade obtained on examina tion _ Visual 3.
s for certification:
A.
General examination __
88
_ Bi Practical examination _ 01. 3 Specific examination _
C.
72 4.
Percentile weights assigned each examin ti a
General examination _
on for certification:
A.
.30
_B.
Practical examination-Specific examination _
C.
.20 50 5.
Composite grade _
86.5%
6.
The listed in the TVA Division of Nuclear Poweabove-name mpleted the requirements frogrpm for1 rr-UTIl-II
_ Examination and is hereby certified t
- ' '--d = h/4e.
\\
~
TVA Level III e
Title
~ ~ '12/12/837 Limits of certification (if any): _ Conective Evewear pace
~
7.
Termination of Certification:
~
The above certification is revoked as checked below:
of -
_ for the reason (s) r l
} II Individual transferred out of QA&C Branch
.x g
.l lB)
Individual has not performed the duties of hi
~
certification satisfactorily.(See attachments level of for details).
l lC) for over 12 months. Individual has not passed required vis acuity examination l
l D)
Other (See attachment for details)
Signed:_
TVA 6780 (DNP-10-82)
IVA Level III
~ Date:_
s I
(
TE!!!!ESSEE VAEI.EY ACEHOE!Ti Q,,
PACI V
f DIVISION OT NUC!. EAR POWER I
D/
Examination Answer Sheet
\\
NA*!I,
- RII!!ATION NO. \\/'7'r, T o,
SOCI.*J. SECL?.IiT NO.
,f DA~E
/.% / 2 - f 8 _-
3RE v
A@CDE E. OBCDE 51.
ABCDE 76.
ABCDE I.ABCD@
.7. AB@DE
- 52.,A B C D E 77.
ABCDE J. @3CDE
\\2. @BCDE 53.
ABCDE 78.
ABCDE.
,44 A@CDE ABC@E' d'. @BCDE 3d. @BCDE '
54.
ABCDE 79.
ABCDE 55.
ABCDE.
80 ABCDE I[ AB@DE
@BCDE 56.
A B C,D E 81.
ABCDE
@3CDE 3!. @@ B C D E 32.
BCDE 57.
ABCDE 82.
ABCDE J'. AB@DE
- 58.,ABCDE 83.
ABCDE S( AB@DE 31/., AB@DE 59.
ABCDE 84.
ABCDE 1/. A@cDE 35[ A @ C D E 60 A.B C D E 85.
ABCDE r 1)'. A@CDE 3[. ABChE 61.
ABCDE 86.
ABCDE d A@cDE 3
AhCDE 62.
ABCDE 87.
ABCDE
- 1. A@CDE
\\. [$CDE
(
63.* ABCDE 88.
ABCDI AhCDE
. %CDE 64 ABCDE 89.
ABCDE 1
4I. h3CDE
.A@CDE 65.
ABCDE 90.
ABCDE
$ AhcDE h.ABdDE
- 66. ABCDE-91.
ABCDE h3CDE E2. $BCDE
- 67. ABCDE
- 92. ABCDE II. [ B C D E R3 A@CDE
- 68. 'A.B C D E 93.
ABCDE hBCDE Y.. @BCDE 69.
A B C,D E 94 ABCDE 2
AB@DE h
@BCDE 70 ABCDE 95.
ABCDE 2[.
3
'I. h3CDE A
@BCDE 71.
ABCDE 96.
ABCDE E
ABODE 47.
ABCDE
- 72. ABCDE 97.
ABCDE
[. @kE)C D E 48.
ABCDE
- 73. ABCDE
,hcDE 49.
A B.hD E 981 A B C D E 74 ABCDE
- 50. A'B C D E
- 75. ABCDE
~,
99.
ABCDE
.?.@3CDE 100. ABCDE RE.".GES I have reviewed all questions which are missed, have had an o au ee,%... and onder,taod tse correct an,me, to each so ci s
ppo: unity to wa-r....?
g---
on.
s DATE
^
_1:$h Yf h 9 7
....-.CA:E g e. ee N
=
c.
(
4(4 5
1 Record of Magnetic Particle Examination Date of Examination:__
~1W.'
Report No.: _ O VC- /-
Procedure No.:-
A/- /l1 T-f Revision: _.
Origmal Examination
[Re-examination Weld Joint No.:
A.3. 7 B
R.%.% F FF 1
d h.*
Item or System
Description:
no r 1
(' $
o (s e <
3 t n in ts ~i"~
P /__ t3 < s 1/,
e m >*e Referenced Drawing:-
- D N-e, ~ Tbo,rJy1_le, r l'As<
t Method'of Magnitization (Check if Applicable):
J- / 6,//7 m ET6f - I<
I
/
cal. WiU
{
l Yoke
-r Prods g
OLM b A. C.
D.C. '
A.C.
D.C.
cA t. att a-Equipment Type:
Y /
u/I l k Equipment Type: b4O 1
/
3A.D99/ /
a o /
e,,,z n x -_._ 4-S-s's".
Pole Spacing:
Prod Spacing:
[f [^10 k Magnetizing Current: _
bMf AI = [# b 4t f
Particles Bran'd & Color:
me,nd Fluy O <= b l'
~
E$ amination Results:
/
Satisfactory '
Unsatisfactory Explanation of Unsatisfactory Results:
/'lo a << t W' _
/ s 'rJ'.3 r-t ni n,cA r,a Al s r
n to24,.r*
-s '/.., J V,, it l
l
~
Ii Q.,
Examined By:_
e.
_ Level: -
Evaluated By:
[
/
Level:.- b m.
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Tv A 744o A (or,4,p.4 8.,y
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,a O.1 79)
C.
e REPORT ON INDIVIDUAL PARTICIPATION IN AN 4
EDUCATIONAL l
/.I maat for oartiCloatson in less than 75ertecipation in the educational activity DerCent of hours of instructson oIIerede ed and distrsbuted o
! Joe Title
\\
(Socad
,3 vision Pne'r Aide e
Branch 1.'JC PP.
~
8
-j Type of Actsysty l
On l
r:n..
~^ Visual Weld Examination Training - Level II oaie oegun I
i cate enced 1
3L5/??.
Totai hours of instruction ottered a
Totai hours ats 1?/1?!PT I
Subsects covered:
~
Av av Int roduction to visual examination.
Visual examination pro'cedures,ASME Code requirements rel i
amination."
Performance of visual examinations Records and reports.
1i Method of instruction Lecture, demonstration and laboratory exer i c ses.
j 0
Evaluation of participation:
5,N=
Commentsi
_ ['
Satisfactory Unsatisfactory ins cer' tified,
- l W
'ribution of copsest
.I hite
. Participant
~
enk
- Supervisor
' Olue s,
\\
Yetiow Local Personnet Office Employee's File Signature of Activity LNo
/
~
- c.
c sf PERSONNEL QUALITICATION AND CERTITICATIO:
jiy TENNESSEE VALLEY AUTit0RITY RECORD DIVISION OF NUCLEAR POL'ER NN 1.
Name of certified individual.
2.
ITDE method and level of certification Inservice Visual Examination - Lev 3.
Percentage grade obtained on examinations f I
(X or certification:
A.
General examination _
84 B.
Specific examination _ 87.S C.
Practical examination _
98 4.
Percentile weights assigned each examinatio n for certification:
A.
General examination _
.30
_B.
Specific examination __.20 C.
Practical examination-
.50 5.
Composite grade -
91 BY 6.
The listed in the TVA Division of Nuclear Power Qabove-n ompleted the requirements
/ Prog {am fpr _ YTI-II Examination and is hereby certified to the
(
i
('*
NAa(
TVA NDE Level III Limits of certification (if any): _ Corrective Evewe
~~
Y25/84 ' 'J
\\
Title Date
~
ar 7.
Terminaticn of Certification:
+
~
The above ' certification is revo' ked as of -
_ for the reason (s) checked below:
'~
l l
')
Individual transferred out of QA&C Branch T.,,,.
t.t
.l lB)
Individual has not performed the duties certification s,atisfactor13y (See attachme t fof his level of n
or details).
I lC) for over 12 months. Individual has not passed required vis ual acuity examination l
lD)
Other (See a.ttachment for details)
\\,
Signed:_
TVA 6780 (DNP-10-82)
TVA Level III j Date: _
j
-e
.5
-(
t raae n
(
=
1!75:7:
.". J Revisea
- (h g OCT 1 4 G32 EDiIBIT n "12
- jgg je TO:
liuelear Training Drancle }'-- r Tra in ing *i:,3, pg7 Durine the period from [~A I /971 r
.-c ra e 2,, a,, 74, -
r
__ E4 s recebeg; y
expe rience, a t lea s t 5*~ of whi ch Va s in tic -~
,4 f
_ me thoes.
Signe'd:
O' (f
j me.
O e
9B Y
6 es e a I
I-g L.=$
o O
g, e
e e
S e
"U4 mud
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Gener ) p,g.g,g,n
e.
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PEP.SONNEL QUALIFICATION AND CERTITICATION RECORI TENNESSEE. VALLEY AUTHORITY f
DIVISION OF NUCLEAR POWER A
I 1.
Name of certified individual 2.
NDE method and level of certification Hacnetic Particle t.evel II 3.
Percentage grade obtained on examinations for certification:
A.
General examination 80.5 B.
Specific examination 80 C.
Practical examination 93.7 4.
Percentile weights assigned each examination for certification:
A.
General examination _
30%
B.
Specific examination 30%
C.
Practical exhmination_
40%
5.
Co:sposite grade 85.5 6.
The above-named individual has satisfactorily complaced the requiremen listed in the TVA Division of Nuclear Power Qualification and Certificat Program for MT Level II on level-li= red ahnu.
Examination and is hereby certified to the (Y
/em/ W l.1 William R. Sneed,' Jr.
y' Name Iitle
' Dhte Limits of certification (if any):
I e
I 7.
Termination of Certification:
The above certificat' ion is revoked as-of checked below:
for the reason (s) l l A) Individual traniferred out of QA&C Branch.
s s.q l
] B)
Individual bas not performed the duties of his level of'
! l certification satisfactorfly (See attachment for details).
I l
l__
lC)
Individual has not passed required visual acuity examination
~
for over 12 months.
l t
P l
lD)
Ii Other (See attachment for details).
\\
Signed:l Date:
IVA Level III m-TVA 6780 (DNP-10-82) 5
e e.>
e
.n' y
i
(
\\
EMPLOYEE CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL NUMBER T50180 ERT has received the Employee concern assigned the indicated category and priority: identified
- below, and has
^
Priority: 1
- Concern 8 Category: 88 XX-85-069-001-R/
Confidentiality:
_YES
_NO (ISH)
Supervisor Notified:
_X_YES ___NO NUCLEAR SAFETY RELATED Concern:
SEQUOYAH:
YES MANY EMPLOYEES ARE QUALIFIED.
THEY DO NOT HAVE ENOUGH ON THE JOBCERTIFIED BUT ARE NOT THOUGH IT WITHHELD DUE TO CONFIDENTIALITYIS DOCUM TRAINING-TOJT)
EVEN
- OTC, INFORMATION.
NUC POWER CONCERN. DETAILS KN FURTHER C/ l HA.
t f
l
&/./
A' '
^
l i
MANAGER, ERT l
NSRS has En7E assigned i
tos responsibility for investigation of the above concenn L
ERT ___
NSRS/ERT _____
i NSRS___g(_
~
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OTHERS (SPECIFY)
W
/
[
Page 11 of 16
.4 RNS..(..C..'.n.t. i.n u..e d )
II. S.P.E.C. I F I C C ON.C. E..
]
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Descrlp} tion Comments
^
.[.
^ C o..ncern s
several recommended changes
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- t. o... t h. i s..p,r,o g r a m a n d NSR S...-.
will overview the
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... _.. considered by NSRS
-.. Coroll...-..
s t a r t-.u p issue for SON.
ary:
- X X.,8 5 0 6. 9 X O. S..... E...m. p l. o.y e e '..s..
D..J..T...r.e. c. o r d s T h e.. r e p.o r..t...i n.d i. c a t e s there
. dverse impact on f..
... mis no a
. q..
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. y
-- _' safety rela.ted equipment o. r...
....,...t.......s.........
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"m components as the result
.. =
.of.these concerns.
NSRS 4
has recommen.ded a detailed l.nv e s t i g a t i o n of the NO NDE
_...... Certif.ication P.rogram and.
ivities be
..r.e s u l.t.a.n.t. a c..t. NO.
initiated by.
Based 3.
upo the information
...._.........'............,....n reviewed. this issue should
.i sa ly c l. o s e d b e.Eh. t i s. f a c t o..r..i. t i o n o
'1 w{
the comple
..inve s t i g a t i on.a..nd e
- opc, r... r.~ e. 3, 6 -.,en, N*
w s........
- - - ~....
7-
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not. hamper start-up
..-.. s w
..- i..f f ?.
but
.y..
.......'.a c t.i v i t i e s. f o r SON:
-.,.. ;e...,.
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.should be addressed before
.......w
.c in t i o n s., u.,,
._ a d. d..i,_t i.o. n..a..l.,.I.S...I
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.j,a.f an... ac :.:.:. n..c..; 2Y.: %.t.c.... Js..a s.l. U.s e d. t.o 's_e'l.d E.3.16. _ ' _P..r.a. c.I:i c. e.,
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.--..-... ba.se maEeri-.'.
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. "_ 7.tq. :'o.,w e 1 d.i t. h. ~E. 309. w e 1
-type 316 base y.
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.--........-.s.
h a. s ' i. nv e s t i g a t e d..t.h.i s...
l
....r..
~_
~
IGTC) s-c concern in ERT i
investigation report XX-BS-
'..-. g.i 6-001 da'ted'8/22/85i O
. This concern.was c l.o s e d.. o. n 8/29/85.,...
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Paga 1 of 1 (EMPLOYEE CONCERNS)
C
,SSUE PLANT PRIORITY ORG QTC EGO INSP SD RD GD 10 ------CONCERN-------
*04/86
'3:15 XX-85-069-001 1
NSRS PROB: XXXXX f
'.WORDS:
NOT WELD RELATED THEY DO NOT ARE NOT OUALIFIED.
MANY EMPLOYEES ARE CERTIFIED BUTEVEN THOUGH IT IS DOCUMENTED T 1980 TO PRESENT.
DETAILS KNOWN TRAINING (OJT)
SEQUOYAH ENOUGH ON THE JOB Cl HAS NO THE CONCERN EXISTED FROM NUC POWER CONCERN.
HAVE DO HAVE ENOUGH OJT.TO MAINTAIN CONFIDENTIALITY.
TO OTC. WITHHELD FURTHER INFORMATION.
NO FOLLOW UP REQUIRED.
STAT:
RC:
IR:
TECHNICAL COMMENTARY:
(ma f
T e
g,'
i, 9
Attcciment 3 P4gs 1 of I a
11/04/86 (EMPLOYEE CONCERNS) 11:23:56 C'~
ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
S 1
SR XX-85-069-001-R1 WORDS:
QUALIFICATION INSPECTOR PROGRAM PROB: WCPol SEQUOYAHr MANY EMPLOYEES ARE CERTIFIED BUT ARE NOT OUALIFIED. TilEY DO NO ENOUGil ON Tile JOB TRAINING (OJT) EVEN THOUGH IT IS DOCUMENTED THAT THEY DO ENOUOH OJT. DETAILS KNOWN TO OTC. WITHHELD DUE TO CONFIDENTIALITY. NUC POWER CONCERN. C/l HAS NO FURTHER INFORMATION.
IR: 1-85-373-NPS STAT:
RC:
TECHNICAL COMMENTARY:
of e.
M S
g e
e
Atteclunant 4 Page 1 of 1 (EMPLOYEE CONCERNS)
CA, ISSUE PLANT PRIORITY ORG OTC EGO INSP SD RD GD 10 ------CONCERN----_--
6/86 9:33
. XX-85-069-00T OA B
PROB: WCPOI IWORDS:
OUAllFICATION INSPECTOR PROGRAM QUALIFIED. THEY DO NOT MANY EMPLOYEES ARE CERTIFIED BUT ARE NOT IT IS DOCUMENTED THAT THEY 00 THE JOB TRAINING (OJT) EVEN THOUGH NUC POWER DUE TO CONFIDENTIALITY.
BELLEFONTE.
TO OTC WITHHELD HAVE ENOUGH ON HAVE ENOUGH OJT. DETAILS KNOWN INFORMATION.
CONCERN. C/l HAS NO FURTHER STAT:
RC:
IR:
TECHNICAL COMMENTARY D
e 1
l eog
Attachannt 5 Paga 1 of 1 th/04/86 (EMPLOYEE CONCERNS) 11:24:33 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
S 1
SR XX-85-069-X05
.WORDS:
QUALIFICATION INSPECTOR FALSE SPECIFIC PROB: WCPol SON EMPLOYEES OJT (ON-THE-JOB TRAINING) RECORDS HAVE BEEN FALSIFIED.
(DETAILS TO THE SPECIFIC CASE ARE KNOWN TO OTC AND WITHHELD TO MAINTAIN-CONFIDENTIALITY).
Cl HAS MORE INFORMATION.
NUCLEAR POWER.
IR:
STAT:
RC:
TECHNICAL COMMENTARY:
e *S e e
9 e
9
Page 1 of 3
SUMMARY
OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XI-85-088-003 Alterations to Welder Not substantiated by ERT Qualification Records in Report XX-85-088-003 of Knoxville 3/8/86 (Attachment 3).
XX-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.
XX-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency.
I-85-560-SQN (Attachment 3).
WP concurs with report recommendations.
XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS Rejected NDE Items Report I-85-738-SQN (Attach-ment 3).
WP concurs with report recommendations.
SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3).
Interim corrective (Also Listed in actions are being the Generic formulated. Closure is based on these actions.
i Summary)
, Additional corrective actions may be implemented.
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN (Attachment 3).
XX-85-069-001 Inadequate OJI-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for N0 inadequate OJT-records was i
substantiated by NSRS Report XX-85-069-X05 l
XX-85-069-007 I-85-373-NPS (Attachment 3).
No falsification of records was substantiated. WP con-curs with report recommen-i dations.
05640 1
Page 2 of 3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-X02 Making Proper Welds substantiated; SQM-6-005-X02 was not substantiated by NSRS Report I-86-115-SQN (Attach-ment 3).
WP concurs with report.
XX-85-013-001 E309 Electrode Used to Weld This is an acceptable E316 Steels practice. ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
XX-85-049-001 Welder Certifications XI-85-049-001 was XX-85-049-X03 Updated Without Meeting substantiated as it relates to Welder Continuity Require-Requirements ments. This had previously been identified by NO in an audi t.' XI-85-049-X03 was not substantiated. Details and
-recommendations are given in NSRS Report I-85-135-SQN
.(Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be
~ closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
XX-85-054-001 QC lloldpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN (Attachment 3).
XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I-85-750-SQN (Attachment 3).
{
05640
D Page 3 of 3 EMPLOYEE WP ACTION CONCERN NUMBER ISSUE XX-85-083-001 SQN Weld Inspections not as Not substantiated by'HSRS Strict as WBN Report I-85-652-SQN (Attachment 3).
XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related.
Not Condenser. This issue is substantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3).
XX-85-100-001 Improper Weld Repair on en Not substantiated by ERT Undetermined Number of Report XX-85-100-001, dated 3/5/86 (Attachment 3).
Welds XX-85-101-006 Welder Certification-for ERI Report XX-85-1017006 the Construction Era (Attachment 3) with NSRS Recommendations indicates that this concern is sub-stantiated. WP takes excep-tion to this ERT Report based on subsequent information
'~
provided in Attachment 4.
WP exceptions, recommen-dations, and basis for closure were discussed with NSRS as documented in Attach-ment 5.
WP recommends this concern not be substantiated and that lt be closed based
~
on the WP-Bechtel Implemen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).
XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indications for Report I-85-735-SQN Preservice-Related Defects (Attachment 3).
XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS Report I-85-776-SQN XX-85-108-002 (Attachment 3).
\\
05640 PROGRAN SUMMARIZATION OF WELD PROJECT (Wp) EVALUATION This packagn summarizes the actions taken by the Welding Project (WP) to evaluate and disposition the subject SQN-specific employee concern which was previously evaluated by NSRS/Q1C/ERT and summarized in Wp Phase I and Phase II reports.
The Wolding Project analyzed each SQN-specific employee concern to determine the statement (s) being voiced by these individuals.
These statements were then evaluated both individually and collectivoi, to develop issues.
Each issue was then incorporated into the WP review activities of Phaso I,
" Procedural Assessment" and Phase II, " Procedural Implementation."
During Phase I, each issue was analyzed against requirements of the applicable policies, NSRS/QiC/ERT Investigation Reports, and other rainvant QA program, information to determine if program elements were deficient when evaluated against upper-tier requirements.
Phase II consisted of a sample reinspection of hardware and independant program audit by Dochtel.
In each area analyzed by Bechtel, the auditors found 'no objective evidence to substantiate the employee concerns considered. The following areas directly related to employeo concerns were investigated by the audit team:
1.
Waldor quallrication and attendant records Walder qualification and attendant on-the-job-training 2.
3.
Wolding inspections 4,
Welding inspectors training programs 5.
Wald matarlal tracuability 6.
Wolding inspections by craft personnel 7.
Wald material control Each of these areas was investigated by the auditors for both construction and operations phasos.
In all cases, there was no objective evidonen to The audit report concludes that both substantiate the employee concerns.
construction and operations phases have had and now have a functioning Wolding standard, and regulatory Quality Assuranco Program which meets code, requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.
3157T Page 1 of 2
ATTACl!!1ENT 7 The results of the reinspection program at SQN also give another, additional verification of the Wolding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and implementation of these programs through, hardware inspections and attendant document reviews.
In all cases, the components and items were found to be acceptable upon initial reinspection or found to be acceptable after engineering analysis.
The WP analysis of SQN-Specific Employee Concerns supplemented by the independent (lochtel Audit, reinspection of installed components and system, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified through the Employee Concern Program. The Employee C0ncern Program has simply esolved through existing V
r,eiterated problems which have been or are now being corrective action programs in the overall Nuclear Quality Assurance Program.
A summary analysis of the Wp evaluations and recommendations is included in Attachment.
i 1
1 I
l 5
Page 2 of 2 l
I-85-373-NPS Attachsent 8 Page 1 of 10 Corrective Action Plan The responses to specific recommendations from the subject report are follows:
A.
I-85-373-NPS-01,' Adequacy of NDE/0JT Documentation
( CATD,I-85-373-NPS-01-009)
Recommendation: Ensure that whatever modifications to the new QC and NDE OJT Manuals are made, if any, do not result in diluting the commitment to detailed verification of required OJT.
Response
The OJT Manual is based on the guidelines provided by INPO document TQ-501. Any modifications made to the OJT manual will be consistent with TQ-501. It is not expected that TQ-501 will reduce or dilute the currently recommended level of verification of OJT.
Responsible individual / organization - M. McGrary, Division of Nuclear Training.
Item 2 Recommendation: Until the new QC and NDE OJT Program is implemented, the POTC should not certify inspectors (stop work) without receipt of detailed OJT verification in the form of inspection listings, including item-by-item initialing by the training inspector, f
Response
Since February 10, 1986, the NDE Level IIIs at the POTC have not issued initial certifications without detail inspection listings validated by qualified inspectors in the field. This has been implemented through W. E. Andrew's memorandum dated February 10, 1986, and by agreement between the POTC and the Inservice Inspection Group (D. A. Howard).
B.
I-85-373-NPS-02, ~Va idity of NDE/0JT Documentation I
U I-85-373-NPS-02-010)
Office of Nuclear Power (ONP) must undertake a follow-up investigation to better define, in detail sufficient to remedy, the findings documented herein including:
Item 1 Recommendation: Correction of incorrect qualification documents and premature certifications.
j
Response
Two separate investigatiots have been performed to evaluate if incorrect qualification documents exist related to NDE 1r.spections performed at SQN from 1980 to the present. One investigation pertained to the SQN
I I-85-373-NPS
'a Page 2 of 10 I
site QC Inspectors certified in NDE and the other to Inservice Inspection (ISI) NDE inspectors.
A total of 141 Inspectors with certifications in 442 disciplines were included in these investigation.
(Elght individuals performed inspections for both ISI j-on a review of QC inspection logs which revealed 65 and QC.) The SQN QC Inspector investigation was-based inspectors who had performed NDE inspections at SQN since 1980. The Inservice Inspection (ISI) investis;ation included a total of 84 ISI personnel who had been certified to perform WDE inspections in the timeframes mentioned.
The detailed reports (QA records) resulting from the QC and ISI investigations will be included in RIMS as part f
of this report. Working copies will be maintained by the SQN Site Quality Organization. QA record flies for NDE inspectors which are maintsined at the POTC will be supplemented as necessary to provide for qualification or certification documents which are missind.
Results l
and conclusions derived from the QC and ISI investigations are described below:
1.
The program requirements for NDE OJT as defined in DPH N75C01 (PHP 0202.14) included only two required methods of documenting OJT or WIE (work-time experience) from January 1980 to the present, the Exhibit D and Exhibit A forms. During the period from 1980 to October 14, 1982, the Exhibit A form included in DPM N75C01 was used exclusivel'y for recording WTE.
From October 14, 1982 to the present, the Exhibit A has been used in conjunction with the Exhibit D form of DPH N75C01 (currently revised to PMP 0202.14) to document WTE/0JT.
A thorough search of the inspector certification files (QA records) maintained at the Plant Operations Training Center (P0TC) reveale'd that the appropriate Exhibit A or Exhibit D form could not be located for 7 inspectors covering 8 certification disciplines. Signed statements were obtained from'each of these individuals concerning the adequacy of OJT'or applicability of previous WTE prior to certification.
2.
The investigation results indicated that OJT for 116 inspectors with certifications in 299 disciplines could be substantiated based upon existing documentation.
The documentation substantiation total equals 67.6 percent of the initial inspector certification disciplines
I-85-313-NPS Attachmsnt 8 Page 3 of 10 reviewed. In addition, 53 inspectors with certifications in 109 disciplines (24.7 percent) were substantiated as having a level of training, knowledge, and experience necessary (although not all fully documented) to successfully complete the training program administered by the POIC and perform adequate inspections. These individuals had Exhibit D-forms in their flies with varying amounts of documented OJT from none up to the amount indicated in PMP 0202.14.
The substantiation of these individuals is based on a docuinented evaluation of the NDE training and c
examination program administered by the POTC and statements included.in NSRS Report I-85-373-NPS on pages 13 and 21 concerning the rigorous nature of the POTC program and the knowledge required for successful completion. The purpose of OJT is basically to ensure that an individual receives the experience necessary to obtain a certification in a particular d,lscipline. The adequacy of this experience is insured by the Individual's performance on the practical portion of the examination which requires that 90% of the sample defects be correctly identified.
3.
The remaining NDE discipline certification documentation which was not substantiated (34 representing 7.7 percent of the total) have been grouped and evaluated as follows:
Unsubstantiated Exhibit A experience (7 a.
certification disciplines) - Previous experience could not be verified in certain cases since some campanies have gone out of business and others would not release information on previous employees. A signed statement has been obtained from each of the four QC and ISI inspectors addressing the adequacy of OJT of the validity of the Exhibit A before f
certification.
1 b.
Level I or QC (Welding) certification documents could not be located (19 certification disciplines) - Although program requirements were j
met, there is not evidence of a Level I or QC (W) l certification document which would provide documentation for substantiation. Signed statements have been obtained from eight of the nine Individuals (with 17 certification disciplines) stating that OJT prior to certification was I
adequate. One QC inspector (with two certification disciplines) who is no longer employed by TVA had a WTE form signed by the TVA Level III Indicating that the individual had experience equivalent to a I
Level I.
,=.
I-85-373-NPS Page 4 of 10 c.
Exhibit A and/or Exhibit D missing (eight certification disciplines) - As previously stated in this report, signed statements have been obtained from each individual with missing Exhibit A or D forms indicating that adequate OJT was received prior to certification or that previous WTE had been obtained.
4.
The OJT substantiation total of 92.3 percent of the inspector certification disciplines included in the QC and ISI investigations indicates that no generic problem related to the adequacy of NDE OJT exists. In addition, the investigation results combined with statements from the subject NSRS Report and the Phase II Welding Project Report (Volume III) provide a basis for determining that no adverse impact on safety-related equipment exists as a result of unsubstantiated WTE/0JT for QC inspectors.
Allegations of records falsification could neither be proven nor disproven based on the results of these investigations. The Office of the General Counsel (OGC) is performing an investigation of possible records falsification which should be complete by September 1, 1986.
The issue of premature certifications was addressed in both the QC and ISI investigations with the results indicating that no evidence of premature certification exists except in the case of one individual whose certification in PT was apparently based on
[-
qualification data which was inaccurate. This individual was recertified as a Level II three months after his original certification and is currently A reevaluation of p'emature certification may employed.
r be necessary based on the results of the OGC Investigation.
Responsible individual / organization - J. Hamilton, SQN Site Quality Organization.
Item 2 Recommendation: Fedressment of inappropriate personnel actions such as premature promotions and/or IMI.
Response
Selections for promotion of salary policy personnel were made in accordance with the appilcable Articles of Agreement and are based on the merit and efficiency of the candidate. The gelevance procedure included in the Articles of Agreement provides an appeal mechanism for employees who disagree with supervision over the l
I-85-373-NPS Attachssnt 8 Page 5 of 10 interpretation or application of a policy. The QC and ISI investigations did not indicate any instances of premature promotions. However, a reevaluation of premature promotions may be necessary after OGC has completed their investigation of alleged falsification of records (due September 1, 1986).
Responsible individual / organization - J. Hamilton, SQN Site Quality Organization.
It is our understanding that I&H lasues are currently being handled by the Office of the Inspector General (OIG) and a completion date for the resolution of these issues'is unknown.
Responsible individual / organization - N. Zigrossi, Office of the Inspector General.
Item 3 Recommendation:
Extension of the records search for work initially performed under qualification documents and premature certifications for sites other than SQN will be complete January 1987.
I l
Response
The extension of the records search to evaluate the adequacy of qualification documents and premature certifications for sites other than SQN will be complete 4
January 1987.
Responsible Individual / organization - R. C. Parker, WBN Site Quality Organization; G. G. Turner, BFN Site Quality Organization; S. Johnson, BLN Site Quality i
Organization.
I-85-373-NPS-03,ResolutionofemployeeReskonseBarriers C.
(CATDI-85-373-NPS-03-Ol. Item 1 Recommendation: ONP management should consider cross-training as a means of rotating management which has become inbred in certain areas such as QC/ISI.
Response
Cross-training of management between the line and quality assurance for short timeframes would provide valuable experience and insight into the problems encountered by each organization but might not be advisable for permanent rotations. A significant level of independence with respect to production pressure is necessary within the Site Quality Organization, and line managers might not be able to provide this degree of independence without significant adjustments. -mn -.e.. n. .n.,, ,e -..w,---..,.
I-85-313-NPS ' Page 6 of 10 In addition, efforts to staff the new Site Qualitly Organizations and shifting of the plant staff have placed unusual restraints on available resources and made rotation of personnel unfeasible. The Employee Concern Program (ECP) currently in effect within ONP provides a variety of reporting mechanisms whereby a concerned individual can freely report a concern and be assured that actions will be taken to provide an evaluation and necessary corrective actions. The ECP program has helped to open communication channels and should provide an acceptable method of ensuring that concerned individuals have methods of voicing concerns even if their immediate management does not take what they consider to be appropriate action. Responsible individual / organization - J. Ilamilton, SQN Site Quality Organization.. Item 2 Recommendation: The employee concerns program has to be staffed with individuals who have had minimal personal connection or prior work association with their counterpart line managers. Otherwise, employees will lack confidence in the program and will take their concerns elsewhere.
Response
The ECP has been staffed with personnel with broad technical backgrounds and experience, and who possess the interpersonal skills identified as necessary for the job..ECP representatives are typically selected through a process which evaluates the individual's interpersonal skills through psychological and aptitude screening, panel interviews, and interactive role planning. This selection process has provided a group of well qualified individuals who are capable of effectively handling employee concerns. Program procedures prohibit investigation by staff having prior work association with the issue in question. Responsible individual / organization - E. S11ger, Employee concerns Staff. Item 3 Recommendation: Criteria for promotions should be divorced from the present requirements for a large number of certifications. Recognized ability as a good OJT instructor is one good substitute which might recognize real value to the group more equitable.
I-85-373-NPS Attach snt 8 Page 7 of 10
Response
New job descriptions for QC inspectors are being developed which emphasize inspector qualification in accordance with ANSI 45.2.6, ANSI 101.4 and SNT-TC-1A. These job descriptions will not prescribe a specific number of certifications in order to be promoted to a higher grade. Promotions in general will be based on an individual's performance and experience. The new job descriptions mentioned above will be completed by ' October 1, 1986. Responsible individual / organization - R. W. Dibeler. DNQA, Technical Support Manager. D. I-85-373-NPS-04, POTC Resolution of Identified Quality Assurance Deficiencies (CATDI-85-373-NPS-04-012) Item 1: Issue the " Quality Control and Nondestructive Examination On-The-Job Training Manual" after the noted discrepancies identified on page 4 of Attachment C have been resolved.
Response
The QC/NDE OJT Manual has been issued and is on controlled distribution to all affected supervisors. The following is provided in reference to QTC opinions pertaining to the QC/NDE OJT Manual: QTC The statement in the OJT Manual, "The OJT Qualification Guide. . does not require implementation," downgrades this document from a requirement to a guide. The OJT Manual'is, in fact, a guide for the performance
Response
of OJT. The Institute of Nuclear Power Operations recommends that OJT programs be developed in the form of OJT Guides. This built-in flexibility is needed because the manual cannot possibly be designed to anticipate all the OJT situations which offer valid and excellent training opportunities for trainoes. QTC: This document (the OJT Manual) does not state who is within its scope or who will be subject to its implementation.
Response
The scope of the OJT Manual must be defined by an additional implementing procedure or management requirement." Paragraph I.B of the OJT Manual states, "The OJT Qualification Guide shall be implcmented by a program procedure or other authorized TVA procedure or
I-85-373-NPS l o Page 8 of 10 by management policy statement." The various ONP divisions and organizations are responsible for determining the required training for their personnel. QTC: Section II.B(2) (6) does not define the term"... based-on.
Response
The complete sentence referred to above reads as follows: "The minimum number of practical assignments to be completed for each NDE discipline shall be based on the number of " work-time experience" hours defined in P.M.0202.14, " Qualification and Certification of NDE Personnel." The amount of work-time experience required for each NDE method is defined in P.M.0202.14 The minimum number of assignments required to complete OJT in 'a method is the i number done in accrual of the minimum required experience time defined in P.M.0202.14. The sentence in question is self-explanatory. It should be noted that controls are in place through I the certification process by Level IIIs to assure that the minimum amount work-time experience and thus OJT practical assignments are met. QTC: The manual falls to address what actions will be taken if a trainee falls some portion of the manual. The manual is designed to allow repeated OJT until the trainee has successfully completed each portion of the manual. If a trainee falls some portion of the manual, l controls are in place through the " trainee repeats that OJT portion until it is successfully completed. Responalble individual / organization - M. McCrary, Division of Nuclear Training. Item 2: Delete the use of or revise the Exhibit D forms to more clearly define information required to be put on the form. (P2)
Response
Since February 10, 1986, the use of the Exhibit D has been supplemented with detail inspection listings validated by qualified inspectors in the fleid. This has been implemented through W. E. Andrews' memorandum and by agreement between the POTC and the Inservice Inspection Group (D. A. Howard). These actions provide I i I 1 I ... ~. - - -
I-85-373-NPS Page 9 of 10 the assurance that the OJT has actually been performed which is the intent of this recommendation. Responsible individual / organization - N. McCrary, Division of Nuclear Training. Institute Document Control on NDE certification records. Item 3: A section instruction letter (see Attachment 8)
Response
Instituting document control of_NDE certification records has been prepared which compiles with QA Record Control requirements of the Nuclear Quality Assurance Manual. Part III, Section 4.1. Responsible individual / organization - N. McCrary, division of Nuclear Training. Perform an evaluation of the documentatio'n adequacy of Item 4: certification forms..Use the input from recommendation I-85-373-NPS-02. Correct deficient documentation. An evaluation of the ad'equacy of work-time experience
Response
documentation has been performed. The evaluation concluded that the work-time experience and associated documentation required by TVA procedure complies with TVA commitments. Adding the requirement for the detail inspection listings validated by quellfled inspection, as has been described in the responses above, has significantly increased the information documented in support of inspectors on-the-job experience and should j preclude this type concern in the future. Responsible individual / organization - N. McCrary, Division of Nuclear Training. Withdraw certifications where eye examinations have not Item 5: been taken. Eye examinations have been successfully completed for
Response
In all individuals where certifications are current. addition, eye examinations have been successfully completed where lapses have occurred. The QC/NDE Training Section has implemented a system whereby responsible supervisors are notified when lapses occur. The supervisors are recommended to initiate appropriate QA action relative to the specific lapses identified. As a result of the sections above, no certifications are required to be withdrawn. I
I I-85-373-NPS Attsch22nt 8 Page 10 of 10 Responsible individual / organization - M. McCrary, Division of Nuclear Training. E. Action to Prevent Recurrence The implementation of the program described above should correct all deficiencies noted and should provide complete control and consistent program guidance to correct other deficiencies that may exist and provent recurrence of problems of this nature. V I l t L.
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