ML19318C821
| ML19318C821 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Peoples D COMMONWEALTH EDISON CO. |
| References | |
| CE-1-A-R-11, NUDOCS 8007020322 | |
| Download: ML19318C821 (2) | |
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NUCLEAR REGULATORY COMMISSION 3,,
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i-JUN 111980
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Mr. D. L. Peoples Director of Nuclear Licensing
-Commonwealth Edison Company P.O. Box 767 Chicago, IL F,0690
Dear Mr. Peoples:
By letter dated May i9,1980 you submitted Revision 11 to the Commonwealth ddison Company (CECO) Topical Report No. CE-1-A, " Commonwealth Edison Company Quality Assurance Program for Nuclear Generating Stations." This revision concerned the education and experience requirements for the position of t:1 CECO Manager of Quality Assurance.
We have evaluated this revision and find additional information is required from CECO to satisfy the enclosed staff position. To maintain our review schedule, your reply is requested by no later than June 27, 1980.
We'are available for a meeting or conference call with CECO to discuss our concerns.
Please call W. Belke on (301) 492-7741 to arrange for further discussions.
Sincerely, M:.2' 4
Walter P. Haass, Chief Quality Assurance Branch Division of Engineering
Enclosure:
Staff Position 8'007020 g g
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,A COMMONWEALTH EDISON COMPANY Staff Position The May 19, 1980 letter from D. L. Peoples to W. Haass and Revision 11 on page 1-7 of the Commonwealth Edison Company (CECO) Topical Report, CE-1-A, " Commonwealth Edison Ccmpany Quality Assurance Program for Nuclear Generating Stations," provided a response to NRC Q421.7.
Based on our review of the information presented, we are enable to determine the acceptability of your response.
CEC 0's qualification requirements for the position of the Manager of Quality a.
Assurance does not include the six months of the one year experience within the QA organization as described in ANS-3.1-1979, " Standard For Qualification and Training of Personnel for ilucliar Power Plants."
(Our intent is that the six months experience need not necessarily be obtained in CECO's QA organiza-tion.)
In lieu of this experience, your response indicates one year experience in implementing a QAP at a nuclear power plant.
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Revision 11 describes the educational raquirements for this position to be, as a minimum, "a Baccalaureate Degree or equivalent in Engineering or related science" without explaining what the term " equivalent" means. The term
" equivalent" is considered to be commensurate with the factors described in paragraph 4.1 (items a-j) of ANS-3.1-1979 and should be described by CECO in detail in order for us to evaluate these factors on a case-by-case basis.
The rationale for our position results from many examples of deficiencies in imple-mentation of the QA program that have been cited in the nuclear industry and NRC Inspection Reports.
In some of these examples, the lack of proper implementation of the. program,-among other reasons, can be attributed in some measure to the inade-quate qualifications of the management personnel, i.e., insufficient educational and experience requirements.
Consequently, this has contributed to improperly fulfilling the important responsibilities associated with the position relative to nuclear power plant safety-related design, construction, and operational activities. Therefore, we believe that the QA Manager's educational and experience qualifications should be at least equal to the person responsible for managing the site QA program as described in paragraph 4.4-5 of ANS-3.1-1979.
Please provide additional clarifying information regarding the type and extent of educational experience CEC 0 requires its offsite QA Manager to possess prior to appointment to the position.
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