ML19323F530
| ML19323F530 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/08/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Barcia J AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8005290140 | |
| Download: ML19323F530 (4) | |
Text
{{#Wiki_filter:k se gy.. m ,w c, 4 MAY 0 81980 DISTRIBUTION: LCentral File NRC PDR LPDR l NSIC l QAB Projects s QAB Chron. File t Mr. Jose F. Barcia, Chairman Board of Trustees NRR Reading File JSpraul, QAB Utility Employees Association FLiederbach, QAB P.O. Box 258 WHaass, QAB Richmond, VA 23202 t ~ ~ j
Dear Mr. Barcia:
In your letter of March 18,' 1980, you ask'ed for interpretation, of the bRC regula- ~ tions regarding the need for training in addition.to qualification testing of per-sonnel perfoming quality assurance functions. You.also questioned the validity i of the VEPC0 procedure of certifying individuals solely on the basis of passing a test which they helped to develop, and that this justifies the need for additional training. j The regulation regarding training and qualification testing 'of quality assurance i personnel is Criterion II of. Appendix B to '10 CFR Part 50 which states: The (quality assurance) program shall'prc, vide for indoctrination and l training of personnel perfoming activities affecting quality as neces-j sary to assure,that suitable proficiency is achieved and maintained.- i+ i For inspection, examination, and testing personnel, the NRC has endorsed (via ~ } Regulatory Guide 1.58, " Qualification of Nuclear Power Plant Inspection, Examina- ~ i tion, and Testing Personnel,"' August 1973 copy enclosed)~ an industry, standard (ANSI N45.2.6-1973, " Qualifications ~of Inspection, Examination, and Testing Personnel for l the: Construction Phase of Nuclear Power' Plants") as an adequate basis for complying ~ } with the regulation quoted above..The NRC endorsement extends 'the' standard beyond the construction phase into'the operations i tory Position 1), and.it also incorporates: phase of nuclear power plants (Regula- } the rec ~ossaended practice for. personnel i , performing nondestructive examinations given in SNT-TC-1A, its supplements and appendices, "Recocinended Practice for Nondestructive Testing Personnel Qualifica-tion and Certification" (Regulatory Positio~n 2). VEPC0 has cortnitted to qualify ~ QA/QC personnel:to ANSI-N45.2.6-1973 and NDE personnel to SNT-TC-1A. ~ -. n. q : s.:.. -y : f ;, ; <j s ANSI N45.2.6-1973 provides' general guidance on -the training and qualification 'of i , personnel, while SNT-TC-1A is more specific.1 Pertinent excerpts from ANSL N45.2.6-j 1973 follow; J,;, S jg,.W.g,y.5 ', y C .7 l
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.Q b e ;*Xo: P p W.W. '.~ '. ' ' ' = ,~ l' ^ k GENERAL REQUIRENF S TH!S1D0COMENT CON,TAINS 2.f 'f.E, > 1 " 'P00R Ql)AUTY PAGES ~ 2.1 Planning i' . m ^ [ Plans shall be develooed No'r antonino w itamna and trainine an p, ade quate number cf personnel to perfom the equired 1.ispections, exami na- ~~Tro wrad tests-ad shel1-ref ect thehehedrie of project activity-so - is -. . ta 0.19w.ad.e9u.a.tt t.i.m..far...m: mxpen.t..oc.se.11c.tfon.. antra.iningjoLthe =. .t ,.~v,.. Oi 1 s g g,[g yg q$ k WS. Seveesseeef pensetsese SPP968 8 9 97.
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eh b ~ 1 Mr. Jose F. Barcia MAY 0 81980 required personnel. The need for formal training programs shall be determined, and such training activities shall be conducted as required to qualify personnel responsible for inspection, examination, and ' i tes ting.... 2.2 Certification Each person who. verifies conformance of. work activities to quality l requirement.s shall be certified by his employer as being qualified to perfom his assigned work. This certification shall be supported by appropriate measures such as education or-training, testing, evaluation, and periodic review to ass,ure the initial and continued proficiency of each person.... 2.2.1 Training. When training pro' grams are required they shall include indoctrination of personnel with the technical objectives of the project; the codes and standards that are to be used; and the quality . assurance elernents that are to be employed, with guidance regarding their limitations and capabilities. On-the-job participation shall also be included. in the program, with emphasis _on firsthand experience gained i -through actual performance ~ of processes, tests, examinations, and inspec-tions. 4 -m g 5* v l 2.2.2 Proficiency Testing. In accorda'nce with the requirements of ~ SNT-TC-1A and supplements, tests shall be' devised for determining the capability and proficiency of personnel who perform nondestructive examina-tions; and each person who' performs these examinations shall be tested to i demonstrate his capability. The results of these tests shall be documented and placed in the personnel ' file- (see' paragraph 5) and shall be considered [ in the evaluation described.in paragraph 2.2.3. ogg g - a i l 2.2.3 Evaluation of P'erformance. T$e [ob' performance of inspection, j examination and. testing personnel shall be evaluated initially and at periodic intervals not to exceed two years, and the results of each evalua- . tion shall bec reviewed to.detemind the capability'idual are not in accordance of the individual. If-t it is determined that.the capabilities of an:iridiv l with the qualifications specified for the job, that person shall be removed i ^from operations untir such time'as he'has been' trained in the needed skill {_ and has been re-certified,as. being qualifiedJo perforin.the work. - . s.- r. yp~x ;y...y. %.,
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.f c u., .>.,4 j 2.2.4 Certificate:of Qualification. The'qualificatior.; of personnel shall be documented in an appropriate form, :The certificate shall include the following information:E
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- 4) Level of capability
- 5) Effective period of certification
- 6) Signature of Employer's Designated Representative (7) Basis u' sed for certification.
(Regarding this item, Regula-tory Guide 1.S8, Regulatory Position 3 indicates the basis should include both the general education and experience require-ments and.the specific technical requirements. The guide states i j further that the specific technical abilities of the person being certified should be related to the specific assigned tasks, e.g., electrical inspection, concrete inspection, etc.). SNT-TC-1A states: The employer shall establish a written practice for the control and admints-traticn of NDT personnel training, examination, and certification. SNT-TC-1A includes recomended training course outlines, references for each non- . destructive test method (i.e.,~ radiography, ultrasonic, etc.), suggested examina-tion questions, recomended grading. practices, and a description of the certifica-i tion process. As noted above, SNT-TC-1A is more specific than the ANSI standard. Should you desire a. copy of SNT-TC-1A, it can be obtained from the American Society { for Nondestructive Testing, 914 Chicago Avenue, Evanston, Illinois 60202. l In addition to the comitment to comply with Regulatory Guide 1.58 and thecendorsed standards, VEPC0 addresses the training of QA/QC employees in VEP-1-3A, " Quality Assurance Program.-; Operations Phase.", Section 17.2.2.6 of VEP-1-3A states: 7c. y. Trafning of new Vepco'QA/QC employees'begins with an indoctrination of compant policies and the. required reading of the Vepco Quality Assurance Manuals, A81 cal ' Specifications, Health Physics Manual. Emergency. Plan and selected portionJof1the FSARJ This is accomplished under the guidance of the-Supervisor . Qual.ity ~ Assurance Operations and Maintenance, utilizing an approved written' training plari and ~ appropriate codes and standards. ~ ~ ,s y_n Oncetheemployeehasidicone'thoroughlyoriented'withhisworklocation, ( he is normally assigned'for two or three. weeks full time training at the _ t-operating power-station: for familiarization with station systems. layout i and personnel.. ' The: subjects.to'be_ coverediduring this peridd are specified f in. an approved written. tpaigt,ng p.lg:..v.Qg.M,z ~(. '. Q.- t w: ,...;. cmys.m s my- .After orientation at the station ' specific ~ areas are s&lected for a~udit participation. by thernewaemployee; He is required to ' develop an audit - plan along with a specific' check Tist designed to guide tha audit effort. L This audit planandicheck. list. ts' subject to review and approval by experi-1 ~ enced QA/QC personnel. The results of initial' audits.are reviewed and n.4einimawysnn-w %.4,m g f m uv ~ -. _ _, ppyide-e sn't- .mesgr improved ~perf)rmance.J f .....#~. n ... -.. -. - ~ ~. ~. -. - ~' ...:.......#y -.... v.u eats k ...........J.!.~ .....L--.~.. --. ~ ~ -. 3ec PORM 318 @.f8) NRCM 0248 ' " ;
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.a + = g-l Mr. Jose F. Barcia MAY. 0 81980 i Various semir.ars dealing with quality assurance o'ffered by outside con-i sultants are selected for attendance by QA/QC personnel. QA/QC personnel i are encouraged to participate in, and comment on, industry standards developments. An annual review of personnelproficiency is required by Vepco corporate policy. ~During these reviews the station Resident Quality Control Engineer and the Supervisor - Quality Assurance, Operations and Maintenance deter-mine the proficiency trend for each suboedinate QA/QC Engineer and Engi-neering Technician. At this, time requirements to maintain current the individual's qualification are detemined. Fomal outside schools, fomal company training programs, reading programs, and specified on-the-job training may be assigned for requalification. Training records are main-tained by the Supervisor - Quality Assurance, Opera.tions and Maintenance. The HRC has found that VEPC0 has-described an acceptable method of complying with the regulation regarding training and qualification testing of quality assurance t . personnel given in the first paragraph.of this letter. In response to your specific concerns, it is not necessary that training.be conducted for each employee unless such training is required to qualify an individual for his assigned task. Our Off. ice of Inspection an'd Enforcement (IE) is responsible to verify, on a sampling basis, that VEPC0 is meeting its comitments. If you are aware of any instances where.VEPCO's practices are not in agreement with the program' discussed above, you should so notify IE. Mr. Donald Burke is the IE resident inspector at the Surry j Nuclear Power Station, and he can-be reached'at (804) 357-2101. Your lettei also questions the' validity of the VEPCO. procedure of certifying indi-i viduals solely on the. basis of passing a-test which they helped develop. This is i not in agreement with the intent of part 2.2. of ANSI N45.2.5-1973 which is. excerpted - above. Therefore, we have asked Mr.. Burke to investig' ate VEPCO's certification pro-I' gram for QA/QC personnel.to determine if,any corrective action is required. u. .y,a 3 933 g,,.- We trust the above information-provides a complete respons'e to your ' inquiry. If you require ~ additional information, please contact me or Jack-Spraul of my staff at(301)492-7741.
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