ML20030B880

Notifies That Util Will Amend FSAR Section 1.8 to Include Commitments to Reg Guide 1.58,Revision 1 & Reg Guide 1.146, in Response to Generic Ltr 81-01 Re Qualification of Insp, Exam & Testing & Audit Personnel

ML20030B880
Person / Time
Site:	Clinton
Issue date:	08/10/1981
From:	Wuller G ILLINOIS POWER CO.
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 0970-L, 970-L, GL-81-01, GL-81-1, L30-81(08-10)-L, L30-81(8-10)-L, U-0273, U-273, NUDOCS 8108250083
Download: ML20030B880 (4)

Text

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Darrell G. Eisenhut, Director

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Division of Licensing Office of Nuclear Reactor Regulation 6 W c;h h~'

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U.S. Nuclear Regulatory Commission W :: -

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Washington, D.C. 20555

Dear Mr. Eisenhut:

Generic letter 81-01 In response to your May 4, 1981 letter concerning Qualifica-tion of Inspection, Examination, and Testing and Audit Personnel, Illinois Power will commit to the Regulatory Guide 1.58, Rev. 1, as clarified by attachment (1) to this letter, and Regulatory Guide 1.146, Rev. O, as clarified by attachment (2) to this letter to be fully implemented 90 days prior to fuel load (sche-duled January 1983).

Accordingly, Illinois Power will amend the FSAR Section 1.8 to reflect these commitments as discussed in attachments (1) and (2) to this letter.

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.c-u G.E. Wuller Supervisor-Licensing l

Nuclear Station Engineering AJB/prh Attachment (1)

Clarifications to Regulatory Guide 1.58, Rev. 1 (2)

Clarifications to Regulatory Guide 1.146, Rev. O a

cc:

H.H. Livermore, NRC Resident Inspector j

Director-Quality Assurance

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Illinois Power Co. letter U-0273 Dated August 10, 1981 ATTACRMENT (1)

Regulatory Guide 1.58, Rev. 1 (September 1980)

Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel 4

Project Position - The project complies with the following clarifications:

1.

Reference:

Reg. Guide 1.58, Paragraphs C.1 - The guidance of Regulatory Guide 1.58 shall be followed as it pertains to l

the qualifications of personnel who verify conformance of work activities to quality requirements.

The qualifications of plant operating personnel concerned with the day-to-day operation, maintenance, and certain technical services shall conform to the project position toward Regulatory Guide 1.8, "Personncl Selection and Training."

2.

Reference:

Reg. Guide 1.58, Paragraph C.5 - The regulatory guide and standard's stated scope is to delineate the requirements for the qualification of personnel who perform inspection, examination and testing.

Personnel who review and approve the inspection, examination, and testing proce-dures and who evaluate the adequacy of such procedures to accomplish the inspection, examination, and test objectives need not be qualified as meeting the Level III requirementr,.

However, personnel who approve the inspection, examination, and test procedures and who evaluate the adequacy of such procedures to accomplish their stated objectives will be determined by management through evaluation of their educa-4 tion, training, and experience to be qualified and competent to approve such procedures.

The basis for the determination will be documented.

3.

Reference.

Reg. Guide 1.58, Paragraphs C.6 - Where Section 3.5 of the ANSI standard specifies the requirement of a high school graduate, the candidate may have earned the General Education Development (GED) equivalent of a high school diploma.

The education and experience recommendations specified in Section 3.5 of the ANSI standard should not be treated as alanlute when other factors provide reasonable assurance that person can competently perform a particular task.

Other factors may be demonstrated capability in a given job through previous performance or satisfactory 4

completion of proficiency testing.

Candidates may be qualified using other factors such as previous performance 7

j and satisfactory completion of performance or capability i

testing in lieu of the recommended education and experience i

requirements.

Proficiency and capability testing programs are formally documented and the qualification certifications i

identify the basis for qualifications.

The Quality Assurance organization is advised when qualification waivers are approved in lieu of the recommended education and experience requirements.

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Reference:

Reg. Guide 1.58, Paragraph C.10 - This paragraph is interpreted to mean that personnel who are considered to L. ave suitable qualifications in lieu of the recommended education and experience may be qualified to the appropriate level provided that documentary objective evidence exists substantiating the capabilities.

Documentary objective evidence may include past performance records, written test records, and previous certifications from recognized com-panics or agencies.

5.

Reference:

ANSI N45.2.6-1978, paragraph 1.2 - That standard applies to personnel who perform inspection, examination, j

and tests during fabrication of items.

Supplier personnel performing inspection, examination, or test activities may not be required to meet the requirements of the standard.

The need to invoke the requirements of ANSI N45.2.6 will be evaluated during the review of procurement documents.

When it is necessary to review or verify the inspection activities of a supplier, we will use personnel qualified as auditors to the requirements of ANSI N45.2.23 or inspectors qualified to the requirements of ANSI N45.2.6.

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Illinois Power Co. letter U-0273 Dated August 10, 1981 j

ATTACHMENT (2) 1 Regulatory Guide 1.146, Rev. 0 (August 1980) t Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 1

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Project Position - The project complies with the following clarifications:

l.

Reference:

ANSI N45.2.23-1978, paragraph 2.2 Personnel selected for quality assurance auditing assign-ments shall have experience or training commensurate with the scope, or special nature of the activities to be audited.

It is not necessary to utilize qualified operators, design-ers, or fabricators as auditors provided that auditors are given appropriate training orientation to develop their competence for performing required audits.

2.

Reference:

ANS1 N45.2.23-1978, paragraph 4.2 I

This paragraph allous use of independent certifying agencies for development and administration of Lead Auditor examina-tions, but states that the employer shall retain copies of objective evidence regarding the type (s) and content of examination (s).

Examples of typical examinations administer-ed by independent certifying agencies will be retained on file by Illinois Power for informational purposes.

Signed certification of the independent agency testifying to the i

fact that an examination to ANSI N45.2.23 was given and the named person satisfactorily passed the examination will be maintained on file.

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