ML20039E648
| ML20039E648 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point, Palisades File:Consumers Energy icon.png |
| Issue date: | 01/04/1982 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| GL-81-01, GL-81-1, NUDOCS 8201110126 | |
| Download: ML20039E648 (3) | |
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O Consumers power o
Nuclear Lucenstrrg Administrator Generet offices: 1946 West Parnell Road, Jackson, MI 49201 * (517) 788-1636 h
N January 4, 1982 q
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Dennis M.Crutchfield, Chief
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g Operating Reactors Branch No 5 8
Nuclear Reactor Regulation y
US Nuclear Regulatory Commission b
Washington, DC 20555 7
g DOCKETS 50-155 AND 50-255, LICENSES DPR-6 AND DPR-20, BIG ROCK POINT AND PALISADES PLANT - REVISED RESPONSE TO QUALIFICATION FOR INSPECTION EXAMINATION, TESTING AND AUDIT PERSONNEL (GENERIC LETTER 81-01)
Consumers Power Company letter of July 9, 1981, provided a response to NRC Generic Letter 81-01 concerning " Qualification for Inspection Examination, Testing and Audit Personnel" for our Big Rock Point and Palisades Plants.
NRC letters dated November 16 and December 15, 1981 concluded that our commitments to meet the provisions of Regulatory-Guide 1.58, Revision 1, and Regulatory Guide 1.146 were acceptable.
With the recent completion of our new Quality Assurance Program Description (QAPD), Consumers Power Company Topical Report CPC-2, several exceptions to Regulatory Guide 158 have been identified and incorporated into the QAPD.
Therefore, our July 9,1981 letter is amended to reflect the following:
Regulatory Guide 1 58, Rev 1, September 1980 Section C.1 Requirement "However, for qualification of personnel (1) who approve preoperational, start-up and operational test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, start-up and operational tests, the guidelines contained in Regulatory Guide 1.8, Personnel Selection and Training, shou 31 be followed in lieu of the Guidelines of ANSI N45 2.6-1978."
Exception / Interpretation This requirement is interpretated to not apply to System Protection and Laboratory Services and Plant Modifications and Miscellaneous Projects (offsite support organizations).
These departments have developed their qualification programs based on ANSI Nh5 2.6 and provide services throughout the construction and operation phases of CPCo Nuclear Plants.
Their programs include the certification of their First Line Supervisors to ANSI Nh5.2.6-and additional specific requirements determined by the work activity involved.
8201110126 820104 PDR ADOCK 05000155 P
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DMCrutchfield, Chief Big Rock Point and Palisades Plant January 4,1982 Section C.5 Reauirement "In addition, the individual should be capable of reviewing and approving inspection, examination, and testing procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination, and test objectives."
Exception / Interpretation While a Level III individual should be capable of reviewing and approving inspection, examination and testing p*ocedures and of evaluating the adequacy of such procedures to accomplish he inspection, examination and test objectives, this is no construed by CPCo as requiring personnel who review, approve or evaluate such procedures to be certified as Level III personnel.
Section C.6 Requirements "Since only one set of recommendations is provided for the education and experience of personnel, a commitment to comply with the regulatory position of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and experience recommendations of the standard will be followed."
Exception / Int rpretation The education and experience recommendations given in ANSI Nh5 2.6, Section 3 5 will be treated as such, since our qualification and certification program is based upon these recommendaticus, and more significantly, upon satisfactory completion of capability testing prior to certification.
It is our position that a candidate should not be required to be a high school graduate or have earned the GED equivalent for the above reasons.
Section C.10 Requirement "Use of the measures outlined in these actions to establish that an individual has the required qualifications in lieu of required education and experience should result in documented evidence (ie, procedure and record of written test) demonstratf ng that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience."
Exception / Interpretation We will maintain documented objective evidence that demonstrates that an individual does have " comparable" or " equivalent" competence to that which would be gained from having the required education and experience. However, this may take the form of doewmentation other than " procedures and records of written test" such as documentation of oral tests and on-the-job performance demonstrations.
DMCrutchfield, Chier 3
Big Rock Point and Palisades Plants January h, 1982 General Imposition of these Regulatory Guides on CPCo suppliers and subtier suppliers will be on a case-by-case basis depending upon the item or service to be procured.
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David P Hoffman Nuclear Licensing Administrator CC Administrator, Region III, USNRC URC Resident Inspector - Big Rock Point NRC Resident Inspector - Palisades