ML20038A872
| ML20038A872 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/18/1981 |
| From: | Tauber H DETROIT EDISON 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 EFZ-55-344, GL-81-01, GL-81-1, NUDOCS 8111240356 | |
| Download: ML20038A872 (2) | |
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Hzrry Teuber
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November 18, 1981 EF2 - 55,344 Mr. Darrell G. Eisenhut, Director I ?f f
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U. S. Nuclear Regulatory Commission Washington, D. C. 20555
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Dear Mr. Eisenhut:
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Reference:
Enrico Fermi Atomic Power Plant, Uni NRC Docket No. 50-341
Subject:
Qualification of Inspection, Examination and Testing and Audit Personnel (Generic Letter 81-01)
This letter is in response to your Generic Letter 81-01.
1.
Regulatory Guide 1.146 The established Design and Construction QA program, which predates the development of ANSI N45.2.23, is not committed to be in compliance with Reg. Guide 1.146.
However, the adopted practices for the training and qualification of auditor personnel meet the requirements of the ANSI standard.
The Operations QA program will comply with the requirements of Reg. Guide 1.146.
2.
Regulatory Guide 1.58, Rev. 1 The established Design and Construction QA program, which predates 'he development of ANSI N45 2.6-1973, is not committed to be in compliance with Reg. Guide 1.58.
Rather, it meets the intent of the endorsed ANSI standard.
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8111240356 811'158 PDR ADOCK 05000341 A
Mr. Darrell G.
Eisenhut November 18, 1981 EF2-55,344 Page 2 Inspection and examination personnel of site contractors have been qualified to the requirements of ANSI N45.2.6-1973 Present inspection personnel of Project Quality Assurance who perform first level inspection are also qualified to the same standard.
Edison test personnel, who are part of the Startup Organization and who perform the Checkout and Initial Operations and Preoperational testing, have been qualified to requirements that exceed the requirements of ANSI N45 2.6-1978.
During operations, the Operational QA program will be in compliance with N45.2.6-1978.
However, Edison takes exceptions to the Staff positions C.5 and C.6 of Reg. Guide 1.58, Rev.
1.
With respect to Staff position C.5, it is our posi-tion that cognizant engineering personnel, who will not necessarily be qualified as Level III, should be permitted to review and approve selected inspection and test procedures.
Our exception to Staff position C.6, regarding the educational requirements, is based on our concern that these requirements when applied to contractors and vendors would disqualify fully qualified inspec-tion personnel who lack the education but have demonstrated the ability to perform. Ability to per-form should be the only criterion.
Appendix A of the FSAR will be modified to reflect these positions.
Sincerely, Af Attachment ec:
Mr. L.
L. Kintner Mr. B. Little a