ML20032D736
| ML20032D736 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/02/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.058, RTR-REGGD-01.146, RTR-REGGD-1.058, RTR-REGGD-1.146 14605, GL-81-01, GL-81-1, NUDOCS 8111170436 | |
| Download: ML20032D736 (3) | |
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Consumers Power James W Cook 0
Vice President - Projects, Engineering and Construction Geaeral Offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788-0453
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N November 2, 1981 e$k lC Noy1 d W.
6 F9 iE Mr H R Denton i " "'
/A J Office of Nuclear Reactor Regulation d
US Nuclear Regulatory Commission M
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Washington, DC 20555 MIDLAND PROJECT -
DOCKET NOS 50-329 AND 50-330 RESPONSE TO QUALIFICATION OF INSPECTION, EXAMINATION AND TESTING AND AUDIT PERSONNEL (GENERIC LETTER 81-01)
FILE:
0.h.3 SERIAL:
14605
References:
A.
D G Eisenhut letter to All Licensees of Operating Plants and Holders of Construction Permits (Generic Letter 81-01), dated May L,1981 B.
D P Hoffman letter to D M Crutchfield (URR),
Subject:
" Docket s 50-155 & 50-255 - Licences DPR-6 & DPR Big Rock Point & Palisades Plants - Response to Qualification of Inspection, Examination, and Testing and Audit Personnel (Generic Letter 81-01)",
dated July 9,1981 l
Reference A requested our statement of commitnent to meet Regulatory t
Positions C.5, 6, T, 8 and 10 of Pegulatory Guide 158, Revision 1 and Regulatory Guide 1.146 or our alternative method of complying with 10CFR50 Appendix B regarding qualification of inspection, examination and testing and audit personnel.
Reference B inadvertently did not include the position for the Midland Nuclear Plants. The attachment to this letter provides our response for the Midland Plants. Our comments to Regulatory Guide 158, Revision 1 makes our position on this Reg Guide the same as our presently stated position in the Midland FSAR to the August 1973 version of the same Reg Guide.
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JGKeppler, NRC Reg III RCook, URC Resident Inspector, Midland DHood, NRR 0l 9
8111170436 811102 PDR ADUCK 05000329 61 A
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l Attach =ent to Scrial 1L605 MIDLMiD PROJECT - DOC E: NOS 50-329 AND 50-330-POSITIONS ON RG 1.53, REVISION 1 AND RG 1.'146 (RESPONSE TO NRC GENERIC IE"2ER 81-01)
Co==it=ents to =eet the Regulatory positions of Regulatory Guide 1.58, Revision 1 and 1.146.
The following positions apply to the Midland Project and to =odification projects cssigned to Projects Engineering and Construction.
Regulatory Guide 1.146 We co==it to adopting the =ethods given in Regulaterr Guide 1.146 by March 31, 1982, the date by which the NRC is scheduled to provide final review and approval of our Topical Report.
Regulatory Guide 1.58, Revision 1 cosition on C.5 Our position is that, while a Level III individual should be capable of reviewing and approving inspection, examination and testing procedures and of evaluating the edequacy of such procedures to acco=plish the inspecticn, 5xa=ination and test cbjectives, this is not construed by CP Co as requiring personnel who review, approve or evaluate such procedures to be qualified and certified as Level III personnel.
Position on C.6 Our position is that the education and experience reco==endations given in ANSI N45.2.6, Section 3.5 vill be treated as such,' since our qualification and certification progra=
is-based upon these reco==endations and, = ore si nificantly, upon satisfactory co=ple-tion of capability testing prior to certification.
It is our positier. that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.
Position on C.7 We cormit to i=ple=ent the guidance given in this section by March ~:., 1982.
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Position on C f We commit to i=pic=en t the guidance given in this section by March 31, 1982.
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Pssition on C.10 Our position is that we will maintain docu=ented objective evidence that demonstrates that an individual does have " comparable" or "equivaleot" competence to that which w:uld be gained from having the reqaired' education and experience. However, this may take the form of cocumentation other than " procedures and records of written test" cuch as documentatica of oral tests and on-the-job performance demonstrations.
General It is our positio,n that imposition of these Regulat.0 y Guides on CP Co suppliers and 5
subtier suppliers will be on a ciase-by-case basis, depending upon the item or service to be procured.
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