ML20009H415
| ML20009H415 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/03/1981 |
| From: | Cross W FLORIDA POWER CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.058, RTR-REGGD-01.146, RTR-REGGD-1.058, RTR-REGGD-1.146 3-081-04, 3-81-4, GL-81-01, GL-81-1, TAC-47555, NUDOCS 8108100080 | |
| Download: ML20009H415 (3) | |
Text
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P..o..w...e.r August 3, 1981
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hB Mr. D. G. Eisenhut MJ Director, Division of Licensing
/ -f Office of Nuclear Reactor Regulation E liUG 0 7 ]S8;m 7 l
y.s.twunEmN h8' U.S. Nuclear Regulatory Commission
, u comr Washington, D.C. 20555 9'
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Subject:
Crystal River Unit 3 s
3 Docket No. 50-302 g
Operating License No. DPR-72 NRC Gener'c Letter 81-01, Dated May 4,1981 Qualification of Inspection Examination, and Testing and Audit P3rsonnel
Dear Mr. Eisenhut:
Your letter of Muy 4,1981, requested Florida Power Corporation to pro-vide commitments and implementation schedule to meet regulatory posi-tions C.5, 6, 7, 8 and 10 of Regulatory Guide 1.58, Revision 1 and Regulatory Guide 1.146 or alternative methods of complying with 10 CFR 50, Appendix B, regarding qualification of nuclear power plant inspection, examination, and testing and audit personnel.
Florida Power Corporation has a current alternative program which com-plies with the intent of Regulatory Positions C.5, 6, 7, 8 and 10 of This Regulatory Guide 1.58, Revision 1, and Regulatory Guide 1.146.
alternative program is described in detail in the attachment.
Should you require any additional information, please contact this office.
Very truly yours, u/ x a. w W. A. Cross Manager Nuclear Licensing pf4 lb[kOo$ 0$0 Lobo (R07)01-2 P
General Office 32o1 inirty fourin street soutn. P O. Box 14042. St. Petersburg. Fionda 33733 e 813-866-5151
.]
ATTACHMENT FPC RESPONSE TO REGULATORY POSITIONS C.5, 6, 7, 8, and 10 of R.G. 1.58, Rev. 1 and R.G. 1.146 FPC RESPONSE TO REGULATORY GUIDE 1.58, P.EVISION 1.
Florida Power Corporation limits the formal classification of Level I, Level II, and Level III identified in ANSI M45.2.6-1978 to those quality control, quality programs and engineering personnel certified to perform specific non-destructive examinations and 10 'FR 50 Appendix J leak rate tests.
All other forms of inspection, examination, and testing of safety related equipment are implemented by approved written procedures which individually address personnel qualification requirements by position title in lieu of Level 1, Level II and Levcl III. Job descrip-tions and/or minimum qualifications are documented for each management and bargaining unit position within the nuclear organization.
In each case, the qualifications applicable to these job classifications meet or exceed the education and experience recommendations of ANSI N45.2.6-1978.
REGULATORY POSITION C.5 Except for NDE and 10 CFR 50 Appendix J testing mentioned above, responsibilities corresponding to ANSI 45.2.6-1978 Level III activities are assigned to Section Head and Department Superintendent / Manager positions.
The education experience and capability requirements for these positions exceed those of ANSI N45.2.6-1978.
All procedures established for the NDE methods per SNT-TC-1A-1975 and visual examina-tions methods are reviewed and approved by a Level III examiner certi-fied in accordance with SNT-TC-1A-1975.
In addition, all other proce-dures established for inspection, examination, and testing of safety related systems receive prior review by the Plant Review Committee which is comprised of at least five (5) department or section heads (or their alternates), to ensure a multidisciplinary overview.
Several of these managers hold NRC operators licenses and, therefore, meet the education-al and experience requirements of 10 CFR 55 including the physical and requalification training criteria.
REGULATORY POSITION C.6 The education and experience requirements specified for management and bargaining unit positions engaged in equivalent Levei I, II, III activi-ties exceed the recommendations of ANSI N45.2.6-1978 and, as a minimum, include requirements for a high school diploma or GED equivalent.
In cases where personnel involved in testing or inspections do not meet this requirement, appropriate use of qualified personnel to supervise or oversee these activities will be employed.
Additionally, the use of QA/QC inspectors to oversee certain safety-related activities enhances FPC's capability to meet this connitment as an acceptable alternative. -.
J
REGULATORY POSITION C.7 Procedures for inspection, examination and testing will specify the per-sonnel qualification requirements.
It is our intent in specifying these qualifications, for each procedure, that qualified individuals only will participate in the activity except for training purposes, in which case, qualified personnel will oversee the evolution.
In addition, as a second level review of activities in progress, safety related procedures are reviewed prior to implementation for " hold points" or continuous involvement of Quality Control inspectors who meet the experience, education, and capability recommendations of ANSI N45.2.6-1978.
FPC will review the qualifications of personnel involved in inspections and testing that do not meet ANSI N45.2.6-1978 Level I requirements. An assessment of " sufficient" training to ensura an acceptable level of competence will be performed by January 1, 1982 and training will be conducted by January 1,1983.
REGULATORY POSITION C.8 Florida Power Corporation complies with this regulatory position and has established a training program for all plant personnel consistent with the ALARA concept of Regulatory Guide 8.8.
ALARA instructions to all inspection, examination and testing personnei will be provided by July 1, 1982.
REGULATORY POSITION C.10 It is Florida Power Corporation's policy to specify education and experience criteria which meet or exceed the requirements of the standard, and Regulatory Guide 1.58 Positica C.6 in the position des-criptions for personnel involved in inspection, examination, and testing of safety related systems.
The determination of initial capability is thereby made and documented ec the time of placement of personnel in an applicable position.
Rout'ne evaluations of personnel performing in applicable positions are made on at least an annual basis.
However, if FPC identifies personnel 11 positions responsible for tests and inspec-tions that do not meet the qualificatior requirements of ANSI N45.2.6-1978, appropriate occumentation will be developed to provide the desired objective evidence of qualification.
RESPCNSE TO RECULATORY GUIDE 1.146 FPC complies with the intent of Regulatory Guide 1.146 and full compli-ance will be achieved by January 1,1982.
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