ML19350E874
| ML19350E874 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/17/1981 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML19350E875 | List: |
| References | |
| REF-SSINS-9410 IEB-79-14, NUDOCS 8106230609 | |
| Download: ML19350E874 (2) | |
See also: IR 05000295/1980024
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UNITEJ STATES
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NUCLEAR REGULATORY COMMISSION
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GLEN ELLYN. B..LINCIS 60137
JUN 17 G81
Docket no. 50-295
Docket No. 50-304
Commonwealth Edison Company
-
ATTN:
Mr. Cordell Reed
Vice President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
This refers to scoe of the findings identified in a special inspection
of your ic:plementation of IE Bulletin 79-14 requirements at Zion Station,
Units 1 and 2, conducted by Mr. I. T. Yin of this office on December 10-11,
1980, at Stone and Webster Engineering Corporation, New York, New York.
These findings were addressed in Unresolved Items No. 295/80-24-01 and
No. 304/80-26-01, which we brought to your attention in Inspection Reports
No. 50-295/80-24 and No. 50-304/80-26 forwarded by cur letter dated
February 26, 1981. Due to a difference in interpretation of regulatory
requirements concarning the need for written personnel qualifications for
personne' performing safety related activities, we referred this matter
to our Headquarters for further evaluation.
This evaluation has been completed and our Headquarters position on this
matter is included in an enclosure to this letter. Additionally, our
Headquarters staff has reviewed your letter dated May 6, 1981 from
J. S. Atol to Victor Stello. The information provided in this letter did
not alter their position from that stated in the enclosure.
Resolution of the Unresolved Item and any concompliance relating to this
matter will be ascertained during a subsequent inspection of your IE
Bulletin 79-14 evaluation.
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Your cooperation with us is appreciated.
~ Sincerely,
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LC. E. Norelius, Acting Directar
Division of Engineering and
Technical Inspection
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Enclosure: Memo Jordan t.o
-Spessard dtd 4/16/81
cc w/ encl:
E.-.. Jordan, IE
E. B.'Blackwood, IE
J. B. Henderson IE
'J.
S. Abel, Director-
of Nuclear Licensing
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Graesser, Station
Superintendent
DMB/Documert Control Desk (RIDS)
Resident Inspector, RIII
Mary Jo Murray, Office of
Assistant Attorney General
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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APR 161981
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-MEMORANDUM FOR:
R. L. Spessard, Chief, Engineering Inspection Branch, Region I
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E. L. Jordan, Deputy Director, Division of Resident and Regiona
Reacter Inspection IE
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SUBJECT:
NRC REQUIREMENTS ON PERSONNEL QUALIFICATION
(AITS F03007331)
Your memorandum of February 10, 1981 asks three specific questions
discussion is in order. addressing those questions it appears that a littl
Before
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The inspection which inspired the questions was conducted as part of th
up on the licensee's response to It Bulletin 79-14, which generically identif
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inadequate or improper engineering on piping support systems
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other NRC requirements unexpectedly imposed on licensee's, hav
This 3alletin, and
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severe burden un the engineering offices of licensees, A-E's, NSSS
The normal resource of thoroughly trained and experienaed engineers
, and consultants.
designers, drafting and layout people, etc. is fully committed and oth
, stress analysts
limited skills must be employeed.
ers of
does place an added burden on supervision, to know in detail eIn itself this
.bilities and limitations, and to be sure that no one is assigned work
ach individual's capa-
capabilities.
Appendix B addressas this in Criterion I as follows:
activities affecting the safety-related functions of s
systems, and components shall be clearly established and delineated
in writing.
These activities include both the performing functions
of attaining quality objectives and the quality assurance functions "
.
With respect to the Stone and Webster position on " Indoctrination
.
appears that the inspector, Stone and Webster, and we may each look
and Training" it
somewhat differently.
Nuclear work, both design and construction, embrace the same
engineering disciplines and craft ski'Is utilized on ot'1er industrial work
e
difference is the need for uncompromising attention to quality in
The
understand why it is important to use those skills in
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every facet. It
be " indoctrinated".
activities individuals know the "right" way, but were using " sho
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techniques" etc.
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skills both as good personnel practice, and to satisfy a n
"simpli fied
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chased in the market place.
Now to answcr your specific questions.
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.R. L. Spessard
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APR 161981
(1) Are all personnel. involved in safety-related design activities required
to have a written description of authorities and duties?
Yes. The exact form which this must take is not prescribed by NRC. We
do not exput each individual to be issued a personal " qualification card"
such as is sometimes -issued to welders. There must however exist some-
where in the organization (perhaps in Personnel), a job description for
the various classifications. A record should exist which certifies that
each individual working in any job classification satisfies the require-
ments of the job description (with exceptions, if any, defined in detail).
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(2) Are personnel qualifications required to be established in writing in tarms
of the above authorities and duties?
Yes.
Documentation must exist which verifies that each individual working
in a job classification satisfies the requirements of the job description
.(with exceptions, if any, noted).
This documentation must be available to
the individual's direct supervisor and to the QA auditors.
(3) Are all personnel assigned to safety-related design activities required to
have indoctrination and training prior to engaging in these activities?
..
_
All new hires or transfers scheduled for nuclear work must have thorough
. QA indoctrination, including such things as " don't take shortcuts", "do it
. right the first time", etc. Periodic refreshers would probably be de-
sirabl e.
As for' skill training, that should be evaluated on a case basis.
We are act sure whether the inspector found evidence of unacceptable work performed
by unqualif'ed individuals, or is primarily concerned about the apparent lack of
a structured program. If specific exampies of unacceptable work are found, there
is a strong basis for citation.
If the limited sample does not disclose an un-
acceptable product, but there is no evidence of a systematic program to control
work assignments, there still is a basis for a Station (at a lowar severity level)
because the NRC sample, which is quite small, may not have included any examples of
deficient, product quality.
With respect to the last paragraph of your memorandum, we believe sufficient
-guidance is already available for utilities and contractors and that guidance
has not c5anged significt.ntly since the QA seminars in 1973. We plan no further
actions on this matter.
/ ordan, 'eputy Director
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Divf on of Resident and Regional
R actor Inspection, IE
cc: See next page
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R. L. Spessard
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APR 161981
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cc:
A. Giambusso
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Stone & Webster
1875 I Street NW
Washington DC 20006
E. B. Blackwood, IE-
J. B. Henderson, lE
M. W. Peranich, IE
E. Brunner,' RI
T. Martin, RI
R. Keimigh, RI
J. Joyner, RI'
R.~ Lewis, RII
- C. Murphy. RII
P. Kellogg, RII
A. Gibson, RII
R. Heishman, RIII
C. Norelius , RIII
R. Knop, RIII
6.-Fiat illi, RIII
W. Fishar, RIII
G. Madsen, RIV.
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' U. Potapovs , RIV
G. B,rown, RIV
J. Crews, RV-
H. Book. RV
B. Faulkenberry, RV ,
L. Norderhaug, RV'
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