ML20009H470
| ML20009H470 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/30/1981 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8108100156 | |
| Download: ML20009H470 (2) | |
Text
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e Omaha Public Power District 1'23 HARNEY 8 OMAHA, NEBRASKA 68102 m TELEPHONE S36-4000 AREA CODE 402 July 30, 1981
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Mr. Robert A. Clark, Chief U. S. Nuclear Regulatory Commission I
Office of Nuclear Reactor Regulation Mu l0 $8I" '
- -j Division of Licensing
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M Operating Reactors Branch No. 3 Washington, D.C.
20555 N
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Reference:
Docket No. 50-285
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Dear Mr. Clark:
The following is the District's response to the Commission's letter dated May 4,1981, concerning qualification of inspection, examination, and testing and audit personnel.
The District has reviewed the Commission's position on Regulatory Guide 1.146 and C.5, 6, 7, 8, and 10 of Regul& tory Guide 1.58, Rev. I and cor.1mits to the following:
Regulatory Guide 1.146 - The District presently conforms to the require-ments of ANSI /ASME N45.P. 23-1978 with Quality Assurance Procedure (QAP)
- 18. Thus, the District is presently in full compliance with Regulatory Guide 1.146.
Regulatory Guide 1.58, Position C.5 - The District presently has very strict capability requirements for an ANSI Level III position, although presently there are no ANSI Level III personnel.
The District is re-viewing its Level III capability requirements to insure they conform to Position C.S.
Full compliance is expected by January 1, 1982.
Regulatory Guide 1.58, Position C.6 - In general, District personnel in positions involving nuclear power plant inspections, examinations, and testing are required to have high school diplomas or the equivalent as a condition for employment. To insure full compliance, the District will add to its procedures the requirements to meet ANSI N45.2.6-1978 and Position C.6 of Regulatory Guide 1.58, Rev.1. The District will be in full compliance by January 1, 1992.
Regulatory Guide 1.58, Position C.7 - The District is presently review-ing its training requirements for personnel not meeting the requirements of ANSI N45.2.6-1978 to insure that only those personnel with an accept-(
abla level of competence are used in the activities specified in ANSI N45.2.6-1978, Section 4.
Additionally, personnel not meeting the require-ments of ANSI N45.2.6-1978 will continue to be supervised by a qualified individual participating in the inspection, examination, or test. The District will be in full compl' nce by January 1, 1982.
81081oo156$ h e5
Mr. Robert A. Clark July 30, 1981 Page Two Regulatory Guide 1.58, Position C.8 - It has always been District policy to enforce and implement procedures which maintain occupational radiation exposures as low as is reasonably achievable.
Instructions in radiation protection and radiation-dose-reduction considerations are provided on a periodic basis through Radiation Protection Training courses. The District is presently in full compliance.
Regulatory Guide 1.58, Position C.10 - By maintaining thorough quali-fication records of education, experience, and training and by frequently 1
evaluating performance, the District has available documented objective evidence which can demonstrate " equivalent" competence.
Regulatory Guide Position C.10 will be added to District procedures to insure full compliance by January 1, 1982.
The District is presently in full compliance with ANSI N45.2.6-1978 and intends to be in full compliance with Positions C.5, C.6, C.7, and C.10 by January 1, 1982.
Sincerel
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Jones Division Manager Production Operations WCJ/KJM/TLP/RWS:jmm cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036
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