ML17275B171

Responds to Generic Ltr 81-01 Re Qualification of Insp,Exam, Testing & Audit Personnel.Positions on Reg Guide 1.58 & Reg Guide 1.146 Provided

ML17275B171
Person / Time
Site:	Columbia, Satsop
Issue date:	08/05/1981
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.058, RTR-REGGD-01.146, RTR-REGGD-1.058, RTR-REGGD-1.146 GL-81-01, GL-81-1, QA-81-64, NUDOCS 8108130082
Download: ML17275B171 (12)

Text

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'EGULATOR NFORMATION DISTRIBUTION l EM (RIDS)

ACCESSIOiV NBR:8108130082, DOC ~ DATE: 81/08/05 NOTARIZED: NO -

DOCK FACILi:50-397 WPPSS Nuclear Project~ Unit 2E Washington Public 0003 WPPSS Nuclear Projecti Unit ii Washington Public Powe STN-50-508 WPPSS Nuclear" Project, Unit 3E Washington Public Powe'0-460 0

05000508 STN-50-509 WPPSS Nuclear Pr ojectr Unit 5) Washington Public 05000509 50'13 WPPSS Nuclear Project< Unit 4~. Washington Public Power 05090513 AUTH'.NAME'UTHOR AFFILIATION BOUCHEY<G.D, Wash,ington Public Power'upply System RECIP ~ iVAMEl RECIPIENT AFFILIATION EXSENHUT'ED ~ G. Divi si on of Li censing

SUBJECT:

Responds to Gener ic Ltri 81-01 re. qualification of insp<exam<.

testing 8 audit personnel'ositions- on Reg Guide 1 58 & ~

Reg Guide 1, 146 provided, DISTRISUT ION CODE.: SOO IS COPIES RECEIVED:,LTR L'NCL: g SIZE':: 'Q TITLEl: PSAR/FSAR AMDTS and Related Correspondence NOTES:PM: 2'opies of all material.i cy.BWR-LRG PM(CRIB) 05000397 Standardized Plant ~ 05000508 Standardized Plant; 05000509-RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMEl LTTR ENCL' ID CODE/NAME LTTR ENCLt ACTION:. A/D LICENSNG A/D LICNENSG L'IC BR ¹2 BC 1 LIIC BR ¹4 BC LIC BR ¹3 BC 1 L'IC BR ¹2 LA LICi BR ¹4 LA L'IC BR ¹3 LA AULUCKER ~ 04 1 LIC BR ¹4 PM 04 WHEELEREL ~ 04 1 INTERNAL': ACCID EVAL BR26 1 i AUX SYS BR 27 1 CHEM ENG BR il 1 1 CONT SYS BR EFF TR SYS BR12 09 1 CORE PERF BR 10 1 1 1 EMRG PRP DEV 35 1 1 EMRG PRP LIC 36 EQUIP QUAL BR13 3 3 FEMA-REP DIV 39 1 GEOSCIENCES 28 2 2 HUM FACT ENG 40 1 HYD/GEO BR 30. 2 2 I&C SYS BR 16 1 I &Ei 06 3 3 L'IC GUID BR 33 1 LIC QUAL'R 32" 1 MATL ENG BR 17 MECH ENG BR 18 1 1 MPA NRC PDR LIC BR PROC/TST REV 20,.

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Washington Public Power Supply System A JOINT OPERATING AGENCY P 0 BOX 968 3000 GEO WASHINGTON WAY RICHLANOIWASHINGTON 99352 PHONE I609) 372 5000 August 5, 1981 QA-81-64 Mr. D. G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Eisenhut:

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Subject:

QUALIFICATION OF INSPECTION, EXAMINATION, AND TESTING AND AUDIT PERSONNEL GENERIC LETTER 81-01

Reference:

1) Generic Letter 81-01, dated May 4, 1981, from Mr. D.G.

Eisenhut to All Licensees of Operating Plants and Holders of Construction Permits, same subject.

2) Letter QA-81-43, dated May 6, 1981, from G.D. Bouchey to W.P. Haass,

Subject:

Operational QA Program Description (WPPSS-QA-004).

In response to Reference 1), the Supply System positions on Regulatory Guides 1.58 and 1.146 are as follows:

I. Re ulator Guide 1.58 Rev. 1 Se tember 1980 A. Desi n 5 Construction Phase WNP-1 4 The requirements of Regulatory Guide 1.58, Revision 0 and ANSI N45.2.6-1973 were not imposed on prepurchased equipment suppliers for WNP-1/4.

The requirements of Regulatory Guide 1.58, Revision 0 and ANSI N45.2.6-1973 are being implemented by the WNP-1/4 site construc-tion contractors. As a result, regulatory posi tions C.5, 6, 7, and 10 of Regulatory Guide 1.58, Revision 1 are not directly imposed. The Supply System is currently complying with regulatory position C.8. The following are being implemented at WNP-1/4 and provide an alternate method of complying with the intent of the Regulatory Guide.

C.5. After inspection, examination and test procedures are approved by the contractor's organization, these pro-cedures are required to be submitted to the Architect Engineer (AE) for review and approval prior to imple-mentation. The AE's Engineering and/or QA organi zations review the contractor's procedures for technical compliance wi th the PSAR, technical specification, codes and 8108130082 ADOCK 05000397 810805LI'DR PDR,I pyyI I A

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Nr. D. G. Eisenhut gualification of Inspecti~, Examination, and Testing, and Audit Personnel (Generic Letter 81-01)

Page 2 A. Desi n & Construction Phase (cont)

~MNP-1 4 (cont) standards referenced therein, and for inclusion of adequate quality requirements to assure that the pro-cedures are adequate to accomplish the objective.

t C.6. The construction contractors are required to identify to the Owner/Engineer the names of gA/gC personnel as they are qualified. The acceptability of the qualifications are randomly verified during the performance of monthly surveillances of the applicable contractors. In addition a monthly review is conducted of all remaining qualifica-tions issued during the month which were not verified during the surveillance activities. Acceptability of an inspector's qualification is based on education, related experience, on-the-job-training, 'classroom training and documented proficiency testing. Points are assigned for each of these areas and a minimum number of points is required to qualify for each level of capability.

C.7. During the construction of WNP-1/4, inspections are 'per-formed on an individual item basis; therefore, the use of a "team or group" of personnel not meeting the requirement of the standard for data taking assignments is not probable.

Also, since the inspectors at WNP-1/4 are unionized,'it is required that inspections be performed during construction by union inspectors. As noted in C.6. above, gA/gC person-nel qualifications are verified for compliance wi th the requirements of ANSI N45.2.6-1973.

C.10. If an individual does not meet the minimum requirements of the position that person is being qualified for, objective evidence must be available to demonstrate that the individual does have competence comparable to that which would be gained from having the required education and experience. See C.6.

position.

WNP-2 The requirements of Regulatory Guide 1.58, Revision 0 and ANSI N45.2.6-1973 were not imposed on prepurchased equipment suppliers for WNP-2.

As of November 1980, WNP-2 complies with Regulatory Guide 1.58-September 1980 via the following alternate approach.

Prior to issuance of Revision 1 of this Regulatory Guide, personnel performing quality-related activities were provided indoctrination and training in the requirements of the applicable guality Assurance program, procedures, instructions, and drawings affecting their work.

Documented evidence of the above training was mai.ntained. The indoctrination and training complied with the requirements of 10CFR Part 50, Appendix 6 and ANSI N45.2.

Mr. D. G. Eisenhut gualification of Inspection, Examination, and Testing, and Audit Personnel (Generic Letter 81-01)

Page 3 A. Desi n 8 Construction Phase (cont) wNP-2 (cont)

As of November 1980, in addition to the indoctrination and training requirements noted above, requirements which meet this Regulatory Guide were imposed on site contractors for personnel performing inspections, examinations and tests.

These requirements specify that initial evaluations of educa-tion, experience and qualifications are to be performed and documented; however, formal certificates are not required to be issued because specific inspections, examinations and tests are performed in accordance with approved procedures. There-fore, specific capability identification and levels of certifica-tion are not required. Burns 8 Roe is committed to the above approach'echtel construction personnel who perform inspection, examina-tion and testing are certified in accordance with ANSI/ASME N45.2.6-1978 and Regulatory Guide 1.58, Revision 0.

General Electric (NSSS) endorses Regulatory Guide 1.58, Revision 1, except that "not all GE personnel who approve inspection and test procedures will be certified as meeting Level III capability requirements, however, personnel who approve inspection and test procedures will be determined by GE management through evaluation of their education, training and experience to be fully qualified and competent. The basis for determination will be documented".

WNP-3 5 The Supply System will direct Ebasco to review those contracts-which subscribe to ANSI N45.2.6-1978 and to, direct those contractors to include the provisions of the regulatory positions stated in Regulatory Guide 1.58, Revision 1 with exceptions noted herein.

The requirements of Regulatory Guide 1.58, Revision 0, and ANSI N45.2.6-1973, were not imposed on prepurchased equipment suppliers for WNP-3/5.

The requirements of Regulatory Guide 1.58, Revision 0, and ANSI

.... N45.2.6-1973 are being implemented by the Architect Engineer (AE)/

Construction Management Organization (CMO). For the AE/CMQ and those site construction contractors which subscribe to ANSI N45.2.6-1973, regulatory positions C.5, 6, 7, and 10 of Regulatory Guide

,1.58, Revision 1 are not imposed. The Supply System and AE/CMO comply with regulatory position C.8.

Hr. D. G. Eisenhut Qualification of Inspection, Examination, and Testing, and Audit Personnel (Generic Letter 81-01)

Page 4 A. Desi n 8 Construction Phase (cont)

~MNP-3 5 (cont)

For contractors subscribing to ANSI N45.2.6-1978, the following alternative methods for complying with Regulatory Guide 1.58 requirements will be implemented:

C.5. Inspection, examination and, test procedures are approved by the contractor's organization and submitted to the AE/

CMO for review and approval prior to implementation. The AE's Engineering and QA organizations, when applicable, review the contractor procedures for technical 'compliance with the specifications, codes and standardseferenced therein, and for inclusion of adequate quality requirements to assure that procedures are adequate to accomplish the objective.

C.6. The construction contracts require the contractor to submit procedures for qualification of personnel for AE approval prior to starting work. These procedures are subject to the review described in C.5 above, audited in a readiness evalua-tion prior to start of work, and individual qualifications are periodically reviewed in scheduled audits and surveillances.

C.10. As noted in C.5 and 6 above, the qualification of personnel are subject to approved procedures and periodic audit and surveillance. Determination of initial capability and evaluation of job performance is outlined in these procedures.

Supply System personnel performing inspections, examinations and tests during fabrication, receipt at the construction site and construction, comply with the requirements of the regulatory positions of Regulatory Guide 1.58, Revision 1 and ANSI N45.2.6-1978.

B. Initial Test 8 '0 e'rations Phase

WNP-'1 2 3 4 5 For WNP-2, the Supply System will comply with its position described in Appendix Section II.l of the Operational QA Program Description (WPPSS-QA-004), Revision 5, transmitted to the NRC vide Reference 2). For WNP-1/4 and WNP-3/5, the Supply System will follow a position similar to that for WNP-2 and will.be included in Appendix Sections II.2 and II.3 of WPPSS-.QA-004.

Mr. D. G. Eisenhut gualification of Inspection, Examination, and Testing, and Audit Personnel (Generic Letter 81-01)

Page 5 II. Position on Re ulator Guide 1.146 & ANSI N45.2.23-1978 A.'esi n & Construction Phase WNP-1 4 The requirements of Regulatory Guide 1.146 have not been imposed on the construction contractors at WNP-1/4. However, site contractors are required to have approved procedures which describe how personnel will be qualified to perform guality Assurance Program audits. These procedures meet the intent of ANSI N45.2.23.

As the Construction Management Organization (CMO), Bechtel Power Corporation is responsible to perform audits of the site contracts with the exception of ASME Division 2 contractors. Bechtel guality Assurance personnel performing audits of site contractors are qualified in accordance with the requirements of Regulatory Guide 1.146 - August 1980 and ANSI N45.2.23-1978.

Supply System Project gA personnel are qualified to the requirements of the Supply System Corporate gA Instruction which complies with Regula-tory Guide 1.146.

UE&C performs audi ts of ASME Division 2 contractors and prepurchased equipment suppliers. UE&C auditors are qualified to the requirements of Regulatory Guide 1.146.

WNP-2 The Supply System at WNP-2 satisfies ANSI N45.2.23-1978.

Bechtel Nuclear guality Assurance Manual commits to ANSI N45.2.23-1978.

General Electric is not committed to this Regulatory Guide, but instead states in its procedure number NED0-11209-04A, Revision 2, dated October 1980, that ----"The NEBG instructions required that gA audits be conducted using pre-established written procedures or checklists by appropriately trained personnel not having direct responsibility in the areas being audited".

Burns & Roe is not committed to this Regulatory Guide, but does endorse ANSI N45.2.23-1978.

Site contractors are not committed to this Regulatory Guide, but do maintain their audit programs in accordance with 10CFR50, Appendix B.

~NNP-3 5

.Regulatory Guide 1.146 is acceptable in its entirety.

Nr. D. G. Eisenhut gualification of Inspection, Examination, and Testing and Audit Personnel (Generic Letter 81-01)

Page.6 B. Initial Test & 0 erations Phase For WNP-1/2/3/4/5, the Supply System will implement the provisions of Regulatory Guide 1.146 (August 1980) and the requirements in the endorsed standard ANSI N45.2.23-1978 for initial test and operations phase activities.

Very truly'ours, G. D. Bouchey Director, Nuclear Safety

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