ML20028G118
| ML20028G118 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/11/1983 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20028G114 | List: |
| References | |
| TXX-3606, NUDOCS 8302070419 | |
| Download: ML20028G118 (3) | |
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TEXAS UTILITIES GENERATING COMinNY m,nmss o nu,4u mmw m,s., m hl\Y/Q
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January 11, 1983 TXX-3606 Mr. G. L. Madsen, Chief Reactor Project Branch 1 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.: 50-445 Arlington, Texas 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0. 82-11/10 FILE NO.: 10130
Dear Mr. Madsen:
We have reviewed your letter dated December 13, 1982 on the inspection conducted by Mr. R. G. Taylor of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak, Units 1 and 2. We have responded to the finding listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the requirement and your finding followed by our corrective action. We feel the enclosed information to be responsive to the Inspector's finding. If you have any questions, please advise.
Very truly yours, R . J . Ga ry RJG:aq Enclosures cc: NRC REGION IV - (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Commission Washington, DC 20555 -f 8302070419 830202 PDR ADOCK 05000445 D PDR
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APPENDIX A l NOTICE OF VIOLATION Texas Utilities Generating Company Docket: 50-445/82-11 Comanche Peak, Unit 1 Permit: CPPR-126 Based on the results of an NRC inspection conducted during September 1982, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C),
47 FR 9987, dated March 9,1982, the following violation was identified:
Failure to Properly Indoctrinate and Train Personnel Performing Activities Affecting Quality Criterion II of Appendix B to 10 CFR 50 requires that personnel performing activities affecting quality be provided with indoctrination and training, as necessary, to assure suitable proficiency is achieved and maintained.
Brown & Root Procedure CP-QAP-2.1, Revision 7, " Personnel Training and Qualification," requires quality superintendents /
supervisors to provide employees with on-the-job training prior to certification. Brown & Root Procedure QI-QAP-2.1-1, Revision 4,
" Nondestructive Examination Personnel Certification," requires three months of work time experience (on-the-job training) to achieve certification as a Level II liquid penetrant examiner.
Contrary to the above:
The Senior Resident Inspector, Construction, has determined through interviews with an alleger, the alleger's supervisor, the Brown &
Root (B&R) site NDE Level III, and by a review of pertinent records that the alleger was certified by his supervisor to have had 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> or one month of work time experience (on-the-job training) for which there is only limited substantiation. The alleger has stated that he did not receive nearly 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> of on-the-job training at Comanche Peak in liquid penetrant inspection. The certificate, as worded, would have required the supervisor to have been in direct and immediate super-visory status over the alleger for substantially all of the time for one month. The supervisor has stated that this was not the case and that he does not know who was in direct and immediate supervision of the alleger during portions of his training. The formal certification of the alleger as a Level II liquid penetrant examiner by the site NDE Level III states that the.175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> or one month of work time experience (on-the-job training) gained at Comanche Peak was one of the factors used by the Level III in his certification, yet the supervir.or's certificate was not issued until nearly two weeks later. The other factors were that the alleger had taken the
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.o NRC Inspection Report 82-11/10 )
TXX-3506 Page 2 required classroom training and had successfully passed the examination which was coupled with two additional months of credited work time experience gained on another B&R project. The Senior Resident Inspector would note, for the record, that the alleger could have been certified upon initial employment as a Level II liquid penetrant examiner based on prior certification at two other nuclear projects.
Corrective Steps Which Have Been Taken and the Results Achieved:
A review of other NDE Inspector certification files during the time frame encompassed by the alleger's tenure was accomplished. Each affected inspector was requested to sign a statement attesting to actual work time experience received. In all cases, the affidavits and the certifi-cation records agreed.
Corrective Steps Which Will be Taken to Avoid Further Violations:
Brown & Root Quality Assurance Procedure CP-QAP-2.1, " Personnel Training and Qualification" has been revised to include an On-The-Job Training ,,
(0JT) Log on which the candidate for certification enters the date, inspection method, number of hours of on-the-job training in a particular method and signature. The 0JT Log will be signed by an inspector certified in the particular inspection method for which 0JT is being claimed. The 0JT Log, when completed, will be approved by the candidate's supervisor and forwarded to the Site NDE Level III along with a memorandum summarizing the 0JT Log, attested to by the candidate and his immediate supervisor. The 0JT Log and summarizing memorandum will be included in the candidate's personnel training and certification file.
Date When Full Compliance Will be Achieved:
Corrective action was completed October 29, 1982. Preventive actions were completed October 6, 1982.
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