ML19347F501
| ML19347F501 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/06/1981 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8105190456 | |
| Download: ML19347F501 (3) | |
Text
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O Address Reply to: Post Office Box 767 Commonwealth Edison one First National Plaza. Chicago. Illinois Chicago, Illinois 60690
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Mr. Victor Stello wo Division of Operating Reactors
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Nuclear Regulatory Commission qG,.
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Washington, DC 20555 W,/ g,,y /
Subject:
Zion Station Units 1 and 2 Personnel Qualifications NRC Docket Nos. 50-295/304 Reference (a):
February 9, 1981 letter from G. Fiorelli to C. Reed.
Dear Mr. Stello:
This is to document the Commonwealth Edison Company position on a question regarding qualification of engineering personnel which was recently forwarded to IE Heaoquarters for resolution by Region III, as indicated in Reference (a).
The issue to be resolved seems to be:
Does everyone doing engineering work on a nuclear project need to have a written job description which includas i
specific technical qualifications for each technical functional task rather than generic technical qualifications applicable to a wide range of engineering tasks?
In regard to the Zion Project, Stone & Webster was l
contracted by Commonwealth Edison to perform IE Bulletin 79-14 verification.
In the process of assembling an engineering group to perform this task, Stone & W', ster obtained qualified personnel in I
accordance with the following program:
a.
People are carefully selected for employment, with particular consideration for their education and experience.
I b.
Qualification to perform a task is determined by-supervisory personnel who are responsible for the proper l
performance of that task.
l c.
The technical competence, proficiency and experience of an l
individual is evaluated with respect to th? task to be
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performed, not to an arbitracy standard.
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2-d.
All engineering work is reviewed as an inherent part of-the engineering process.
e.
Periodic audits are conductea to evaluate the process by which the work is performed, including qualification of -
assigned people, and the quality of the product itself.
f.
Division supervisors provide indoctrination and training for new employees based upon individual neeos.
For Stone & Webster, the ultimate responsibility for.
determination of the qualification of individuals rests with the Engineering Division Heac for each technical discipline.
This-responsibility extends from the hiring, indoctrination and training of personnel to the assignment ano evaluation of their performance of assigned engineering tasks.
It is important tc note that the quality of work performed by this group has not been questiond.
The technical work was evaluated in depth by the NRC Region III inspector, Commonwealth Edison Station Nuclear Engineering Department engineers, CECO Quality Assurance auditors, and senior engineering design personnel from Sargent & Lundy.
The Stone & Webster work was found, by all parties, to be acceptable and no concerns from a safety viewpoint were identified.
It appears that the approach followed by Stone & Webster in obtaining qualified personnel to perform engineering tasks is consistent with the approach used throughout the industry for-comparable type work, and that due caution and process was exercised-in obtaining qualified people.
In addition, since Region III felt the need to refer this question to IE Headquarters, it indicates a need f o.- clarif ication of qualification requirements for engineering personnel.
Criterion II, which references qualification of personnel, has been applied to engineering personnel to mean that they must be qualified to perform the task to which they are assignea.
The Criteria does not appear to detail the specifics or mechanics of how the qualification is to be established.
The methods of determining the qualifications vary among organizations doing engineering work for Commonwealth Edison, but in the final analysis the angineers must demonstrate to the Licensee's satisfaction that the work is acceptable.
4 It is our position that the approach used by Stone &
Webster to obtain qualified engineering personnel is acceptable.
Please contact Mr. Tom Tramm at (312) 294-3963 to confirm receipt of this letter and to advise us of your plans for resolution of this issue.
We would be happy to discuss this matter further or arrange a general discussion with an industry group at your convenience.
Very truly yours,
/-
V
./J.
. Abel P Director of Nuclear Licensing cc:
James G. Keppler l
3062B
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