ML20023D180
| ML20023D180 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/13/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 3F-0583-10, 3F-583-10, NUDOCS 8305190344 | |
| Download: ML20023D180 (2) | |
Text
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Power C p R P o a a T e O ss May 13,1983 3F-0583-10 Director of Nuclear Reactor Regulation Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Qualification of Inspection, Examination, and Testing and Audit Personnel
Dear Sir:
While preparing to submit our current Operational QA program to meet the requirements of 10CFR50.54(a)(2), Florida Power Corporation (FPC) identified an area of potentially overlapping or conflicting commitments relative to the qualifications of personnel; specifically inspection, examination, and testing and audit personnel. This letter is to e document FPC's commitment in this area and to eliminate any possible conflicts or misunderstandings. This is done primarily so that FPC managers will uniformly apply r
these commitments, and also so that you may be informed of our actions for purposes of determining acceptability and compliance.
This letter and the attachment thereto supcrsede all past commitments relative to ANSI N45.2.6-both the 1973 and the 1978 version-and to Regulatory Guide 1.58-both Revision 0 and Revision 1-which endorse that Standard. The position described in the attachment will be submitted as part of the current FSAR description of the FPC Operational QA Program to meet the requirements of 10CFR50.54(a)(2).
The commitments documented in the attachment also reflect the current management direction for activities at Crystal River Unit 3.
l Should you require any additional information, please contact this office.
i Sincerely, Q[
G. R. Westafer Manager
(/
Nuclear Licensing and Fuel Management Attachment AEF:mm 8305190344 830513 DR ADOCK 05000302 P
PDR General Office 3201 Trurry-sourin street soutn. P O. Box 14042 st. Petersburg. F onda 33733 e 813-866-5151
ATTACHMENT o
- The positions in this Attachment represent the FPC copmitments relative to qualification of personnel performing activities covered by Regukitory Guides 1.8,1.58 and 1.146. Specific i
commitments to these Regulatory Guides and the ANSI Standards which they endorse are given in the Technical Specifications and the Final Safety Analysis Report (FSAR) description of the Crystal River Unit 3 Operational Quality Assurance Program (Section 1.7). Areas covered by the. endorsed Standards other than personnel qualifications (e.g., Definitions, documentation and records, organizational responsibilities, etc.) are clarified in Table 1-3 of the FSAR which will be submitted as part of the current QA Program description to meet the requirements of 10CFR50.54 (a)(2).
- 1. -
The qualifications of each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Chemistry and Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and the Operations Technical Advisor, who shall have a Bachelor's degree, or the equivalent, in a scientific or engineering discipline with specific training in plant design and response analysis of the plant for transients and accidents. (This is a direct quote of Technical Specification 6.3.1.)
2.
Personnel performing inspections, examinations or tests which are NOT covered by Item 1 above or item 3 below shall be qualified as follows:
a.
Persons performing nondestructive examinations (NDE) and other activities covered by SNT-TC-1 A-1975 shall be qualified as specified in that Standard.
b.
QC personnel performing activities at the Crystal River site, whether FPC personnel or contract personnel, shall meet the requirements of Regulatory Guide 1.58 and ANSI N45.2.6-1978 which it endorses with the following clarifications:
(1)
FPC reserves the right to use personnel who do not meet the recommended education and experience requirements of Regulatory Position C.6. However, the use of personnel who do not meet these requirements will be: the exception rather than the rule; and in each case a documented evaluation and justification for the exception shall be prepared. An example of a justification would be a case where a person had extensive QC experience but no high school diploma or GED but who could demonstrate his competence by means of a performance test.
(2)
FPC also reserves the right to specify activities which may be conducted by use of documented position descriptions rather than using the specific LevelI, II, and III designation used in the Standard. However, the qualifications of personnel performing similar activities shall be consistent with the qualification requirements of the Standard except as noted under 2.b(1) above.
3.
FPC complies with the requirements of Regulatory Guide 1.146 and ANSI N45.2.23-1978 which it endorses for the qualification of QA audit personnel with one exception listed below.
Subsection 2.2.1 references ANSI B45.2 (assumed to be ANSI N45.2) which is not applicable to the operational phase QA program per SRP 17.2 (NUREG-0800). Therefore FPC shall comply with an alternate Subsection 2.2.1 as follows:
Orientation shall be conducted to provide a working knowledge and onderstanding of the Operational QA Program, including the ANSI Standards and Regulatory Guides included in FSAR Table 1-3 and FPC's procedures for implementing audits and reporting results.
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