ML20004A904
| ML20004A904 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/16/1981 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19350E875 | List: |
| References | |
| REF-SSINS-9410 NUDOCS 8105260568 | |
| Download: ML20004A904 (3) | |
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MEMORANDUM FOR:
R. L. Spessard, Chief. Engineering Inspection Branch, Region III FRGM:
E. L. Jordan. Deputy Director.- Division of Resident and ilegional Reactor Inspection. IE
SUBJECT:
NRC REQUIREMENTS ON PERSONNEL QUALIFICATION AND TRAININti (AITS F03007381)
Your memorandum of February 10, 1981 asks three specific questions. Before addressing those questions it apears that a little background development and discussion is in order.
The inspection which inspired the questions was conducted as part of the follow-up on the licensee's response to IE Bulletin 79-14, which generically identified inadequate or improper engincering on piping support systems. This Bulletin, and other NRC requirements unexpectedly imposed on licensee's, have imposed a vefy severe burden on the engineering offices of licensees A-E's, NSSS, and consultants.
The meal resource of thoroughly trained and experiended engineers, stress analysts designers, drafting and layout people, etc. is fully committed and others of l
limited skills must be employeed. In itself this is not necessarily bad, though it does place an added burden on supervision, to know in detail each individual's capa-bilities and limitations, and to be sure that so one is assigned work outside his capabilities. Appendix B addresses this in Criterion I as follows.
"The authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, i
systems, and components shall be clearly established and delineated l
in writing. These activities include both the performing functions of attaining quality objectttes and the quality assurance functions."
j With respect. to the Stone ar.d Webster position on " Indoctrination and Training" it appears that the inspector, Stone and Webster, ano we may each look on that phrase somewhat differently. Nuclear work, both design and construction, embrace the same engineering disciplines and craft skills utilized on other industrial work. The difference is the need for uncompromising attention to quality in ryery facat. It l
1s not sufficient to deternine that an individual possesses certain skills; he must understand why it is important to use those skills in the prescribed way - that is be " indoctrinated". Experience has shown that in many areas, including engineering activities, individuals know the "right" way, but were using " shortcuts", " simplified techniques" etc. Training is, of course, often needed to upgrade an individual's skills both as good personnel practice, and to satisfy a need that cannot be pur-l chased in the market place. Now to answer your specific questions.
8105 2 605(At CONTACT:
J. B. Henderson, IE U -ZIbbi
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3;p R. L. Spessard APR 161981 (1) Are all personnel involved in safety-related design activitias required to have a written description of authorities and duties?
Yes. The exact form which this uust take is not prescribed by NRC. We do not expect each individual to be issued a personal " qualification card' c
such as is sometimes irsued to welders. These must however exist some-where in the organf zqtion (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 fetail).
(2) Are personnel qualifications required to be estan11shed in writing in tenns of the above authorities and duties?
Yes. Documentation must exist which verifies that each individual working in a dob classificatic satisfies hbe requirements of the job description (with exceptiens, if a:.noted). This documentation must be available to the individual's dira. supervisor and to the QA auditors.
(3) Are all personnel assigned to sadety-related design activities required to have indoctrination and training prior to engaging in these activities?
All new hires or transfers r.cheduled 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 not sure whether the inspector found evidence of unacceptable work performed by unqualified individuals, or is primarily concerned about the apparent lack of a structured program. If specific examples of unacceptable work are found, there is a strong basis for citation. If the limited sample does not disclose an un-receptable product, b'it there is no evidence of' a systematic program to conteol work assignments, there still is a basis for a citation (at a lower 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 changed signiffrantly eence the QA seminars in 1973. We plan no further actions on this matter.
E. L. Jordan. Deputy Director Division of Resident and Regional Reactor Irspection, IE cc: ~$5e m t pagW M
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R. L. Spessard APR 161981 cc:
A. Giambusso Stone & Webster 1B75 I Street NW Washington, DC 20006 E. B. Blackwood, IE J. B. lier.;derson, IE M. W. Peranich IE E. Brunner, RI T. Martir., RI R. Kaimigh. RI J. Joyner, RI R. Lewis, RII C. MurpF RII J
P. Kellogg, RII A. Gibson, RII R. Heistaan, RIII C. Morelius, RI!!
R. Knop, RIII G. Fiorelli, RIII W. Fisher, RI!!
G. Madsen, RIV W. Seidle, RIV
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